1
April 4, 2005
Mark Gorog
Regional Air Quality Program
Commonwealth of Pennsylvania
Department of Environmental Protection
Southwest Region - Field Operation
400 Waterfront Drive
Pittsburgh, Pennsylvania 15222-4745
Dear Mr. Gorog:
We have reviewed the preliminary determination and draft Prevention of Significant Deterioration (PSD) permit prepared by the Pennsylvania Department of Environmental Protection(PA DEP)for the construction and operation of the Greene Energy (Greene)plant. The proposed facility willinclude two, 290 (gross) MW Circulating Fluidized Bed (CFB) waste-coal boilers in Greene County in southwestern Pennsylvania. The proposed site is about 185 kilometers northwest of Shenandoah National Park (NP), a PSD Class I area administered by the National Park Service (NPS). Under the Clean Air Act, I have an affirmative responsibility to protect the visibility and other air quality related values of Shenandoah National Park from the adverse impacts of air pollution. Our role is one of consultation in our efforts to ensure the air quality in Class I areas is protected. As discussed below, based on information currently available, I have concluded that emissions from the proposed Greene project could adversely impact visibility and aquatic resources at Shenandoah NP. Consequently, I ask that the PA DEP not issue a final permit to Greene until our concerns are adequately addressed.
We appreciate the need to have facilities that can burn waste coal, but, like all power generating facilities, they need to be carefully controlled, or burning the waste coal may create more environmental problems than they solve. As proposed, the Greene facility will be a major source of sulfur dioxide (5,649 tons per year—tpy), nitrogen oxides (2,414 tpy), total particulate matter (1,207 tpy) and sulfuric acid mist (145 tpy). Our detailed comments regarding the Best Available Control Technology analysis and the air quality analysis are enclosed and summarized below.
We believe that Greene's impacts alone constitute an adverse impact upon visibility and may also contribute significantly to a cumulative adverse impact. In addition, based on the best science currently available, sensitive streams and fisheries in Shenandoah National Park have been seriously degraded by current levels of sulfur deposition. Less sensitive streams are also likely to be degraded in the future if sulfur deposition is not reduced. Because very sensitive resources in the park are already degraded by existing sulfur deposition, and other moderately sensitive resources are at risk from degradation unless sulfur deposition levels in the park’s airshed are substantially decreased, we consider Greene’s contribution to sulfur deposition to constitute an adverse impact to aquatic resources in Shenandoah National Park.
The air pollutant dispersion modeling analyses presented to date indicate that the 24-hour PSD increment for SO2 would be violated at Shenandoah National Park. NPS is continuing to evaluate these analyses to determine if Greene contributes significantly to any of these increment violations. Greene should provide additional information for its cumulative impact analysis. It may also be necessary for Pennsylvania to join Virginia, Maryland, and West Virginia to remedy these increment violations through revisions to their State Implementation Plans.
As discussed in detail in our enclosed comments, we believe that the PA DEP and EPA did not follow proper procedures regarding publication of the Public Notice and the FLM's review of the Greene application. To enable us to effectively work with the permitting authority and the applicant, these procedural requirements need to be followed. In addition, Greene did not submit complete cumulative SO2 and PM10 increment consumption analyses, nor any analysis of cumulative visibility impacts for Shenandoah NP. Therefore, we ask that the PA DEP delay further processing of the Greene application until we receive and complete our review of that information, and our adverse impact concerns are addressed. PA DEP should also remedy these procedural errors by providing “all relevant information” to the FLMs as required by the PSD regulations and then re-advertising its Public Notice and notifying the public of the degree of increment consumption.
We believe that, by working together with the PA DEP and Greene, we may be able to reach a solution that is mutually satisfactory to all parties. We ask that Greene investigate ways to reduce its emissions further. It may also be possible for PA DEP to accommodate the effects of new growth and mitigate the effects of Greene's emissions by reducing emissions elsewhere. Although we have submitted comments by the April 9 deadline, we believe that a better solution would be to allow adequate time for further evaluation and discussion of the issues we have raised.
Thank you for the opportunity to review the Greene PSD permit application and related materials. We would be happy to meet with you and Greene representatives to discuss our concerns. In the meantime, if you have any questions regarding this matter, please contact Patricia Kicklighter, Acting Superintendent,Shenandoah National Park, at (540) 999-3400, or Christine Shaver, Chief, NPS Air Resources Division, at (303) 969-2074.
Sincerely,
Craig Manson
Assistant Secretary for
Fish and Wildlife and Parks
Enclosure
cc:
David J. Campbell, Chief,
Permits and Technical Assessment Branch
U.S. EPA Region III
1650 Arch St.
Philadelphia, PA 19103
Clyde Thompson, Forest Supervisor,
Monongahela National Forests
200 Sycamore St.
Elkins, WV 26241
bcc:
NPS: Fran Mainella
WASO: Julie Thomas
SHEN: Gordon Olson
USFS: Cindy Huber
ARD-DEN: Permit Review Group, Reading and Project File
USDA-Forest Service: Cindy Huber
ADNRSS: Mike Soukup, Julie Thomas
SOL: John Carlucci, Barry Roth
NERO: Mary Bomar, David W Reynolds, Holly Salazer
ARD-DEN: Permit Review Group, Reading and Project File
ARD-DEN: Don Shepherd