Comments on Glen Lyn Power
Plant Acid Rain Permit Amendment
April 19, 2001
Gail Taber Steele
Virginia DEQ
West Central Regional Office
3019 Peters Creek Road
Roanoke, VA 24019
Re: Glen Lyn Power Plant Title IV Acid Rain
Permit Amendment
AIRS ID No. 51-071-0002, Registration No.
20460
Dear Ms. Steele:
On behalf of the Blue Ridge Environmental
Defense League Board of Directors and over 2,200
members in Virginia, North Carolina, South
Carolina, and Tennessee, I write to provide
comments on the Glen Lyn Power Plant in Giles
County, Virginia. These comments are supplemental
to those provided in a letter to you dated
February 8, 2001 by Mr. Mark Barker, our Board
Vice President from Roanoke, Virginia.
General Comments
The draft permit dated January 5 incorporates
a NOx averaging
plan which would take the place of the standard
emission limits in units 6, 51, and 52. We
recommend denial of the draft permit based on the
failure of the alternative contemporaneous
emissions limitation plan to protect public
health in Giles County, southwest Virginia, and
in the nearby states of West Virginia, Kentucky,
and North Carolina.
The averaging of air pollution emissions among
electric generating units of a particular utility
group lacks the sound underpinning of science. It
is a political engine which results in pollution
hot spots, that is, higher levels of pollution in
some communities in return for a promise
of lower levels in another. But regional ozone
chemistry does not obey human laws. And the
proximity of other large pollution sources will
confound the predictions of the best computer
models. For example, Duke Power’s Belews
Creek coal-fired power plant north of
Winston-Salem is closer to the Glen Lyn plant
than AEP’s Clinch River units in Russell
County, Virginia. The huge levels of nitrogen
oxides, sulfur dioxide, hydrochloric acid,
sulfuric acid, and other pollutants from the
Belews Creek plant, added to the pollution of
Glen Lyn, will overwhelm the marginal predictions
of Virginia DEQ’s computer model which
already indicates that the proposed permit will
raise local pollution levels to over 95% of
national ambient air quality limits. AEP’s
39 unit multi-state averaging plan is a shell
game which, if approved by DEQ, would leave the
people of Giles County the losers.
Specific Comments
The permitting authority must include
explanations for proposed changes in emissions
limits and monitoring for the facility. The
DEQ’s draft permit’s Statement of Basis
cites the statutory and regulatory authority for
the issuance of the permit, but omits any
explanation or justification for DEQ’s
alteration of the existing permit. Nitrogen
oxides emissions are principally responsible for
ground level ozone pollution which causes
shortness of breath, asthma, and shortens
people‘s lives. Several questions arise
based on our reading of the draft permit:
| Will the permittee be required to do
more or less monitoring under the new
permit? If less monitoring is required,
what is the justification for the
reduction? If more monitoring is
required, how will it be done and under
what timetable? How often will the
permittee be required to perform ambient
monitoring? Do stack tests indicate
that the proposed averaging plan will
control pollution levels? How will public
health be protected under the alternative
contemporaneous emissions limitation
plan?
What data, other than computer
modeling, indicate that ambient ozone
levels will remain at or below current
concentrations? How will the permittee or
DEQ ensure that NAAQS will be maintained?
|
The statement of basis must
include DEQ’s rationale for new or less
strict monitoring requirements and the statutory
basis for the changes. A simple listing of
rules and regulations is insufficient. Federal
rules require that the permit application
compliance plans include more than an
identification of options under available to the
permittee under the law. The permit must include
additional information.
| 40
CFR Ch. I (7–1–96 Edition) §
76.9 (emphasis added) § 76.9
Permit application and compliance plans.
(c)
Information requirements for NOX
compliance plans. (1) In accordance with
§ 72.40(a)(2) of this chapter, a
complete compliance plan for NOX shall,
for each affected unit included in the
permit application and subject to this
part, either certify that the unit will
comply with the applicable emissions
limitation under § 76.5, 76.6, or 76.7
or specify one or more other Acid Rain
compliance options for NOX in accordance
with the requirements of this part. A
complete compliance plan for NOX for a
source shall include the following
elements in a format prescribed by the
Administrator:
(i)
Identification of the source;(ii)
Identification of each affected
unit that is at the source and is
subject to this part;
(iii)
Identification of the boiler type
of each unit;
(iv)
Identification of the compliance
option proposed for each unit
(i.e., meeting the applicable
emissions limitation under §
76.5, 76.6, 76.7, 76.8 (early
election), 76.10 (alternative
emission limitation), 76.11 (NOX
emissions averaging), or 76.12
(Phase I NOX compliance
extension)) and any
additional information required
for the appropriate option in
accordance with this part;
(v)
Reference to the standard
requirements in § 72.9 of this
chapter (consistent with §
76.8(e)(1)(i)); and (vi) The
requirements of §§ 72.21 (a)
and (b) of this chapter.
|
The proposed permit would
allow huge increases in nitrogen oxide pollution.
The draft permit contains maximum, rather
than minimum, annual heat input limits for units
6, 51, and 52. According to 40 CFR 76.11, a
maximum heat input value is required for utility
units requesting less stringent emission limits.
Therefore, it is fair to say that AEP expects
these three units to generate higher annual NOx emissions.
| §
76.11 Emissions averaging. (4) Each
unit included in an averaging plan shall
have a minimum allowable annual heat
input value (mmBtu), if it has an
alternative contemporaneous annual
emission limitation more stringent than
that unit’s applicable emission
limitation under § 76.5, 76.6, or 76.7,
and a maximum allowable annual heat
input value, if it has an alternative
contemporaneous annual emission
limitation less stringent than
that unit’s applicable emission
limitation under § 76.5, 76.6, or 76.7.
|
In fact, the three units at
Glen Lyn would emit 1,780 tons more NOx per year if the
draft permit is granted by DEQ (Table 1). Added
to the 7,022 annual tons of NOx
emitted in 1999, AEP’s emissions in Giles
County would increase by 25%. The Glen Lyn plant
would go from ninth to sixth place among the
dirtiest stationary sources in Virginia. As Mr.
Barker demonstrated in his comments of February
8, there has been a rising trend in annual NOx emissions at Glen
Lyn since 1993. The citizens of southwest
Virginia already bear a heavy burden from
emphysema (7,093), chronic bronchitis (46,884),
and asthma (adults 32,439, children 13, 847). The
proposed increases in NOx
and dangerous ground level ozone represent an
added risk to public health which cannot be
justified.
Table 1. Annual Increases in
Nitrogen Oxides Under Glen Lyn NOx Averaging Plan
| Glen Lyn Unit |
Present NOx limit
lb/mmBTU*
|
Proposed NOx limit
lb/mmBTU*
|
Annual heat input maximum* |
Annual increase in
NOx
Tons/year
|
| 51 |
0.45 |
0.47 |
3,146,000 |
|
| 52 |
0.45 |
0.47 |
3,146,000 |
|
| 6 |
0.46 |
0.70 |
14,307,000 |
|
*Data from
Virginia Department of Environmental Quality
Conclusion
The Glen Lyn coal-fired electric power plant is
one of Virginia’s top NOx
polluters; the plant has gradually increased its
NOx emissions
over the last decade. No further increase in
hourly emissions or annual emissions should be
permitted. Moreover, the Phase II NOx averaging
plan would allow increases in total NOx emissions
for all of AEP’s 39 units. The only
acceptable air pollution plan is one would
require lower emissions at each and every plant
operating in Virginia.
Respectfully submitted,
Louis Zeller
Blue Ridge Environmental Defense League
Clean Air Campaign Coordinator
PO Box 88
Glendale Springs, NC 28629
Feb 9, 2001 - Comments
on Glen Lyn Power Plant Acid Rain Amendment
Virginia's 9
coal-fired electric power plants
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