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Sierra Club Appeals Air Pollution Permit for Longview Power Plant
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by Jim Kotcon | 2004

The proposed Longview power plant in Monongalia County would put communities at risk and illegally pollute Dolly Sods Wilderness Area and the Shenandoah National Park, according to our appeal filed April 2 with the West Virginia Air Quality Board.

The proposed Longview power plant in Monongalia County would put communities at risk and illegally pollute Dolly Sods Wilderness Area and the Shenandoah National Park, according to an appeal filed April 2 with the West Virginia Air Quality Board.  The appeal of the Longview air permit was filed by attorneys from the Appalachian Center for the Economy and the Environment on behalf of the Sierra Club, Trout Unlimited, and the National Parks and Conservation Association and seeks to block or reduce emissions from the plant.

The Longview power plant permit fails to meet the legal requirements of the Clean Air Act, thereby putting citizens at risk, according to the appeal.  Among the remedies being requested are requirements for better pollution control technology, increased protection for Wilderness Areas, lower emissions and enforceable monitoring requirements.

                The proposed power plant would be a 600-MW electric generating facility to be located at Fort Martin in Monongalia County, West Virginia.  It is being developed by GenPower, LLC, a Massachusetts firm that has never operated a coal-fired power plant.  Local residents overwhelmingly oppose the project.
            The air pollution permit, issued by DEP on March 2, allows
Longview to emit 3217 tons of sulfur dioxide, 2,962 tons of carbon monoxide, 2183 tons of nitrogen oxides, 528 tons of particulates and a variety of hazardous pollutants including mercury, sulfuric acid, benzene, beryllium, lead, hydrochloric acid, and hydrofluoric acid.  For several of these toxins, monitoring is required only once in five years.

                Best Available Control Technology

                The Clean Air Act requires that emissions from any new source to be limited to the level achievable using the Best Available Control Technology (BACT).   The permit approved by DEP for Longview allows the use of a conventional pulverized coal boiler.  The use of “Clean Coal” technologies such as fluidized bed boilers or Integrated Gasification/Combined Cycle boilers was ruled out as too expensive, even though analyses showed these would be more efficient and could save money in the long run.  Furthermore, a variety of relatively simple pollution control practices such as coal washing, already practiced at most coal-fired power plants, was not required.  The appeal argues that the emission levels allowed in the permit do not meet the BACT requirements, and therefore allow unacceptably high pollution emissions that threaten the health of local citizens.

Threat to Wilderness

One of the more controversial elements of the permit was a “Mitigation Plan” for impacts to air quality at Dolly Sods Wilderness Area and Shenandoah National Park.  Air dispersion models showed that pollution from Longview would significantly degrade air quality in these pristine areas and showed that, in combination with cumulative regional pollution emissions, Longview would contribute to an “increment violation” at these locations, contrary to the limits set by Congress in the Clean Air Act.  In particular, sulfur dioxide emissions would exacerbate acid rain and further damage streams already seriously impacted by acid deposition.  Sulfur aerosols were also shown to significantly reduce visibility by contributing to the acid haze in the atmosphere.  Because of these impacts, the National Park Service filed an “adverse impact” determination as part of their comments to DEP on the permit.  In addition, US-EPA issued a letter requiring DEP to identify and correct any increment violations within 60 days.

To address this impact, Longview accepted a proposed Mitigation Plan in which they would purchase “sulfur dioxide emission allowances” from other sources in a designated region surrounding Dolly Sods Wilderness Area.  Sulfur dioxide emission allowances are required under the Acid Rain provisions of the Clean Air Act and allow pollution sources that reduce emissions more than would otherwise be required, to “trade” those allowances to sources that emit more than their allotted limit.  Under the Mitigation Plan, Longview would be required to obtain these extra allowances from sources in the region that are also affecting Dolly Sods.  In theory, this should compensate for Longview’s impact, and reduce overall emissions to Dolly Sods. 

While the Mitigation Plan at first appears to be a step in the right direction, nothing in the permit prohibits the sources supplying allowances to Longview, from purchasing other allowances from outside the region, and thereby continue to “legally” pollute Dolly Sods.  DEP specifically addressed this issue and refused to insert a permit requirement that the sources supplying allowances to Longview must reduce their own emissions.  Thus the permit does not require ANY actual reductions in emissions or real improvement in air quality at Dolly Sods, and requires little more than a paper shuffling exercise for these other sources. In fact, if the allowances are sold to Longview at a higher price than the cost of allowances from sources outside the region, (a virtual certainty given the captive market of Longview), Longview would, in effect, be subsidizing the continued pollution of Dolly Sods.  Furthermore, nothing in the Mitigation Plan demonstrates that, even if successful at Dolly Sods, it would also address increment violations at Shenandoah National Park.

Mercury Contamination

Several hazardous chemicals, including mercury, beryllium, arsenic, lead, selenium, sulfuric acid, and hydrochloric acid, would be emitted by Longview.  Mercury is especially troublesome because high levels already exist in the environment.  The Pennsylvania Fish and Boat Commission has already issued fishing advisories in Dunkard Creek, less than one mile from the proposed Longview site, because of mercury contamination in fish.  A pollution control technology called “Activated Carbon Injection” has been shown to cut mercury emissions to less than 10 %, but was not required at Longview.  DEP accepted Longview’s claim that it was not economically feasible, even though it was shown that Longview’s cost estimates were based on mathematical errors. 

Mercury contamination already creates serious risks to unborn children.  An estimate from EPA predicted that one in six American women of child-bearing age already carry enough mercury in their blood stream to pose a risk of developmental defects in unborn children.  Coal-fired power plants are one of the largest sources of mercury in the environment.

Citizen Comments Ignored

Citizens have raised these air quality issues with DEP repeatedly over the last year, but have been consistently ignored.  Many local officials have stated that they trusted DEP to protect our health and the environment.  Instead, the DEP has betrayed us. 

Numerous technical comments were submitted by local citizens, scientists, engineers, federal agency staff, and medical professionals, yet none resulted in any substantive improvement in the permit.  DEP issued a 340-page “Response to Comments” document with the permit, in which they largely ignored every substantive issue raised.

                “We are simply asking that the state obey the law,” said Joy Oakes, of the National Parks Conservation Association.  “Instead they are acting to the detriment of our health, and the health of towns that benefit from low- impact outdoors-oriented tourism, such as recreational fishing.”
                Plans for the
Longview power plant were delayed late last year when local citizens challenged a tax break offered by the Monongalia County Commission.  A decision in that case is pending.  The West Virginia Public Service Commission is also reviewing an application for a Certificate of Site Approval for Longview.  At a March 31 hearing in Morgantown, dozens of local citizens objected, complaining about the air pollution, noise, and visual impacts of the proposed plant.

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