CAB Comment on DEP’s smog plan

Comments on DEP smog plan to the Pennsylvania Environmental Quality Board by Thomas Y. Au, President of the Clean Air Board, May 29, 2014

Summer will soon be here and that can mean high levels of pollutants in our air, specifically ozone and small particles, commonly known as smog. Meteorologists declare “Air Quality Action” days when they project that weather conditions are conducive for unhealthy air pollution. In 2012, an extremely hot year, the Pennsylvania Department of Environmental Protection (DEP) called eleven “action days” for the Susquehanna Valley due to high concentrations of ozone. In 2013, DEP called four action days in the Susquehanna Valley due to ozone.

We should heed those warnings. Recent scientific studies conclude that short-term exposure to unhealthy air pollution can have significant adverse effects on pregnant women, children, the elderly, and even the general population–especially those with pre-existing conditions such as asthma. There is increasing scientific evidence that exposure to ozone can lead to neurological disorders. Short term symptoms resulting from breathing high levels of ozone and fine particulate include chest pain, coughing, nausea, throat irritation, and congestion. These pollutants also aggravate 
bronchitis, heart disease, emphysema, and asthma—and can increase risks of stroke. Children, senior citizens, and those with asthma or other respiratory problems are urged to limit outdoor activities during action days.

Air Quality Action days are often declared when there is little wind and when the amount of ozone or particles in stagnant air are projected to exceed federal health standards. Smog is caused when chemicals including nitrogen oxides react in sunlight, forming ground-level ozone. Coal fired power plants are the single largest source of smog-causing pollutants in Pennsylvania. While nearly all of the state’s largest coal plants have the technology to reduce nitrogen oxides, many do not use the available technology. The Clean Air Act requires that existing sources of emissions which contribute to the ozone problem install reasonably available control technology. Reasonably available control technology (RACT) is defined as the lowest emission limitation that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility. Accordingly, RACT determinations must set limits as rigorous as could be met through use of feasible control technology.

The proposed regulation does not set reasonably available control technology for Pennsylvania coal plants anywhere close to the what can be achieved through control technology. Most of Pennsylvania coal plants have highly effective NOx emission controls installed, such as Selective Catalytic Reduction (“SCR”) and low NOx burners. However, in the emission limits proposed, the RACT NOx emission limit for a coal-fired boiler would be an extremely permissive range of between 0.45 lbs/MMBtu and 0.20 lbs/MMBtu. See Proposed 25 Pa. Code § 121.97(g)(1)(v)-(vi). These limits are far higher than recent emissions history and higher than RACT limits set in nearby states. The Sierra Club has submitted detailed information to the Department to document this point. (Sierra Club letter, Jan. 17, 2014)

This proposed limit is not only based on technology inferior to that already in place at nearly all coal-fired power plants in Pennsylvania, but is also significantly more permissive than what those facilities are capable of achieving. In fact, under the averaging rule proposed the coal plants would not need to achieve these limits during ozone action days. See Proposed 25 Pa. Code § 129.98(a). This is like bypassing your catalytic converter in your car to save a few pennies.

The most serious health risks from ozone are associated with high energy demand days when the non-SCR units are almost certain to be operating. Therefore it is imperative that these units be capable of curtailing their NOx emissions on these days so that they comply with emission limits consistent with the installation and operation of reasonably available emission technology found elsewhere in this region.

We continue to suffer from high ozone days during the summer. Air quality in Pennsylvania continues to violate national ambient air quality standards. To achieve compliance with the 2008 8-hour ozone NAAQS, reductions from all major sectors — in-state stationary sources, in-state mobile sources, and out-of-state stationary sources — are essential. This proposed regulation needs to be revised to achieve real reductions in smog causing pollutants.

Your comments on this proposal can be submitted directly to the Environmental Quality Board by June 30, 2014.

Online Comments

Comments, including the one page summary, may be submitted to the EQB by accessing the EQB’s Online Public Comment System at:

http://www.ahs.dep.pa.gov/RegComments

Note regarding the online system: If an acknowledgement of comments submitted online is not received by the sender within two business days, the comments should be re-sent to the EQB to ensure receipt.

Written Comments

Written comments and summaries can also be mailed to Environmental Quality Board, P.O. Box 8477, Harrisburg, PA 17105-8477.

All comments must be received by the EQB on or before the close of the public comment period.

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