February 8, 2001

Gail Taber Steele
Virginia DEQ
West Central Regional Office
3019 Peters Creek Road
Roanoke, VA 24019


Dear Ms. Steele:

COMMENTS REGARDING GLEN LYN POWER PLANT TITLE IV ACID RAIN PERMIT AMENDMENT

I am writing on behalf of the Board of Directors of the Blue Ridge Environmental Defense League. BREDL is a regional, community-based, non-profit environmental organization. Our founding principles are earth stewardship, environmental democracy, social justice, and community empowerment. BREDL has chapters throughout the Southeast. We are concerned about the potential increase in NOx emissions for the Glen Lyn Power Plant located in Giles County, Virginia. Thank you for this opportunity to comment.

Proposed Amendment

In lieu of the NOx Emission Limitation for individual units as listed in 40 CFR 76.5, 76.6 or 76.7, AEP has opted for an alternative contemporaneous annual emissions limitation (ACEL) - averaging plan. Although the NOx emissions increase at the 3 Glen Lyn units may be offset over the entire AEP 39 unit multi-state Averaging Plan, we are concerned about short-term and long-term impacts to the local area.

In 1999, the 39 AEP units included in the Phase II NOx Averaging Plan emitted 317,722 tons of NOx. Under the ACEL (2000-2004), these units would be allowed to emit up to 348,597 tons of NOx. That could amount to a 9.72 percent increase which would not meet the reduction goals of the Acid Rain Program.

Glen Lyn Power Plant - Phase II NOx Averaging Plan (2000-2004)

source: Glen Lyn Acid Rain Permit Phase II NOx Averaging Plan

Despite the Acid Rain Program, the annual NOx emissions for the Glen Lyn facility continues to increase. With the ACEL rates, the hourly emissions have the potential to increase up to 19.14 percent on Stack 5 (Units 51 and 52) and increase up to 9.89 percent on Stack 6. These bursts increase the possibilities of significant negative impacts on human, animal, plant, and ecosystem health in the local area.

* based on 3rd Quarter Summary for 2000

In order to meet the ACEL requirements, the Glen Lyn facility will need to reduce its hours of operation for each unit. This reduction will need to be significantly lower than the Year 2000 operating hours. If the same hours of operation for each unit in 2000 is applied for the proposed amendment, then the proposed NOx rates would increase annual NOx emissions by 1195 tons over the ACEL and 1411 tons over the projected 2000 NOx emissions. If each unit continuously operates using the proposed NOx rates, the NOx emissions would increase to an annual 8609 tons.

Glen Lyn Power Plant
Estimated NOx emissions (tons) for Title IV Permit amendment

* based on 3rd Quarter Summary for 2000
ACEL limits in Title IV Permit Amendment

We understand that the Virginia DEQ was concerned enough to perform SCREEN3 modeling for the proposed amendment. A worst case scenario did estimate that the proposed increases will stay just below the NAAQS standard of 100 micrograms per cubic meter in accordance with 9 VAC 5-30-70. The modeling showed a 95.07 ug/m3 annual impact.

Ambient Air Quality impacts from Glen Lyn Title IV Amendment
(micrograms per cubic meter)

- Virginia DEQ SCREEN 3 modeling - summer 2000

The background reading came from the nearest monitoring device which is located approximately 60 miles away in Vinton, VA. It is highly recommended that Virginia DEQ or the EPA place a monitoring device closer to the Giles County area. In 1996, the Glen Lyn Power Plant was ranked ninth in Virginia for NOx emissions from stationary sources. Hoechst Celanese, also located in Giles County, was ranked eleventh in NOx emissions.

Virginia NOx emissions from Stationary sources

source: Environmental Defense Scorecard

Virginia Impacts

The rate of acid deposition in Virginia’s mountains is among the highest in the country. From 1985 through 1997, nitrogen oxides from stationary and mobile sources have increased by 50 percent.¹ Increases in NOx emissions, even if not sustained, can have severe impacts.

“Recent declines in fish population and species diversity indicate, however, that episodic acidification is taking its toll. In a University of Virginia study on trout reproduction in the Southern Appalachian Mountains, researchers found nearly 100 percent death in the trout eggs and newly hatched fish after a severely acidic rainfall and steep increase in stream water acidity. This sharp acidic surge, due to acidic rainfall, altered stream chemistry, resulting in conditions fatal to fish at young and vulnerable stages. [Trout Unlimited, 1998.]”²

In a 1995 EPA Report titled “Acid Deposition Standard Feasibility Study, Report to Congress”, the EPA found that the eastern portion of the U.S. is most at risk from continued acid deposition. The targeted areas were the lakes and streams of the Appalachian Mountains.

The Virginia Trout Stream Sensitivity Study, which was released in October 2000, conducted by Trout Unlimited and analyzed by University of Virginia scientists shows that many of Virginia’s streams continue to suffer from acid rain. It showed that the number of “chronically acid” streams increased and will continue to increase. The number of dead streams is expected to more than double in the next 40 years.

According to the Southern Appalachian Mountains Initiative (SAMI), “the southeastern United States has more frequent episodes of air stagnation than most other areas of the country. During these periods, pollutants can remain over the mountains for several days at a time. The naturally high humidity of the area magnifies the haze generated by airborne particles.”

A 1999 National Oceanic and Atmospheric Administration report states, “It has been observed that major air pollution episodes are usually related to the presence of stagnating anticyclones. Such anticyclones may linger over an area for a protracted period (4 days or more). During this period, surface wind speeds can fall to very low values. The near surface circulation is therefore insufficient to disperse accumulated pollutants, thereby causing distressful and possible hazardous conditions for the inhabitants of the area.”³

In an annual mean sense, air stagnation events are most prevalent in the southern states. The trend in air stagnation days shows the Roanoke area is one of the SE regions which shows a positive trend or increase in stagnation days. From 1989 - 1998 (May-Oct.), in the Roanoke area, there were 23 cases of air stagnation days.

ROANOKE AIR STAGNATION DAYS
* air stagnation case of 4 or more days occurred

- source: (table compiled from NOAA maps/data)

According to the Power that Pollutes report, the demographics of the Virginia localities closely impacted by the Glen Lyn facility includes 876,969 people. This includes 189,061 children under age 17 and 120,639 senior citizens age 65 and older.⁴

Estimated Virginia citizens with lung diseases near Glen Lyn

- source: Power that Pollutes

This report did not include impacts to bordering West Virginia.

BREDL is also concerned about any further deterioration of the James River Face Class I Wilderness area.

In addition to the Acid Rain impacts, we are concerned about additional ozone concentrations in the region.

Summary

The Glen Lyn Power Plant is one of Virginia’s top NOx polluters. Despite the EPA Acid Rain Program, the Glen Lyn facility has gradually increased its annual NOx emissions over the last decade. Any increase in either hourly emissions or annual emissions should not be permitted. The Phase II NOx Averaging Plan allows for increases in NOx emissions for the combined 39 units when compared to 1999 emissions data. This Averaging Plan needs to be adjusted to encourage decreases in NOx emissions.

Thus, we respectfully request a public hearing on the proposed amendment.


Sincerely,



Mark E. Barker
BREDL SW Virginia Vice-President
1828 Brandon Ave. SW
Roanoke, VA 24015
mebarker@rev.net
www.bredl.org


(1) Power That Pollutes: A Status Report on Virginia’s Outdated Power Plants, Southern Environmental Law Center/The Izaak Walton League, p.1, April 2000

(2) EPA Progress Report on Acid Rain Program, p. 14, November, 1999

(3) Air Stagnation Climatology for the United States (1948-1998), Julian X.L. Wang and James K. Angell, April 1999

(4) Power That Pollutes: A Status Report on Virginia’s Outdated Power Plants, Southern Environmental Law Center/The Izaak Walton League, p. 22, April 2000



more info: April 19, 2001 - Comments on Glen Lyn Power Plant Acid Rain Amendment
Virginia's 9 coal-fired electric power plants