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Comments
of Louis Zeller to the NC Environmental
Management Commission
Reduce Nitrogen Oxide Emissions From
Coal-fired Electric Utility Boilers
Public Hearing July 17, 2000 Winston-Salem, NC
The Blue Ridge
Environmental Defense League advocates at least
an 80% reduction in NOx emissions from all 14
coal-fired electric plants operating in North
Carolina. This is possible through the use
of selective catalytic reduction controls which
have achieved a 92% NOx reduction at other
coal-fired utility boilers. And this level
of pollution reduction would raise the average
North Carolina household electric bill only about
$1.20 per month8.
Ozone levels are higher than ever and the
rate of increase is rising9.
Last year North Carolina had 540 violations of
the EPA eight-hour ozone standard and 20
violations of the one-hour standard4.
High ozone levels caused the state to issue
health advisories telling people to stay indoors
to avoid breathing problems, asthma attacks, and
respiratory infections. Ozone inhibits
plant growth and damages crops. NOx
emissions create ozone, reduce visibility, and
contribute to acid rain, nitrate hazards in
drinking water, and formation of toxic air
pollution10.
National parks and other Class I areas, which are
supposed to have the most pristine air in the
country, are more polluted than cities. In fact,
the two most polluted national parks in the
nation are the Great Smoky Mountain and the
Shenandoah national parks.12
Electric industry emissions are a major
cause of urban and rural ozone pollution.
Nationwide, coal-fired electric power stations
built before 1980 generate half of the nation's
electricity, but emit 85% of the NOx generated by
utilities5.
Because of the loopholes written into the Clean
Air Act, these coal-fired plants continue to rely
on pollution control technology developed 20 to
40 years ago5.
Some older plants operate with pollution rates up
to 100 times greater than newer units6.
This is no time for half measures.
Poor atmospheric mixing and air inversions can
increase ozone concentrations in populated areas
to dangerous levels in a matter of hours.
Rural mountain regions also suffer prolonged high
ozone levels. The risk to the very
young, the elderly, and to people with heart or
lung disease is especially serious.
We believe that nothing short of an 80% NOx
reduction will alleviate the ozone threat. Ozone
masses can be displaced 400-500 miles. Air
quality models in the Southern Oxidant Study
indicate that peak ozone levels may not be
reduced, and could even rise, unless this level
of reduction is achieved:
"Air quality attainment is predicated on a
large (i.e. 80%) reduction in NOx emissions,
while moderate reductions in NOx emissions of
less than 67% could bring about a period of
slightly increased peak O3 concentrations." 13
There is no disagreement among scientists
that this level would improve air quality.
The 80% reduction should be year-round in order
to protect the public and the environment from
other adverse effects of NOx. Utilities
should achieve this goal within five years.
BREDL advocates 90% NOx reductions within ten
years. We do not need one more computer
model to tell us why we cannot see the high peaks
of the Great Smoky Mountain National Park in the
summertime.
Our organization is working to reduce air
pollution from all fossil-fuel burning sources
including utility power plants and industrial
boilers. We advocate a regional approach to
the effort to reduce air pollution. Air
pollutants, including SO2, NOx, toxics, and
particulate pollution, are all part of the same
problem for communities. They affect
health, visibility, and the economy. In
1999 we developed the following Principles for
Clean Air.
(1) States should develop a strong SO2 reduction
program.
(a) State agencies should develop new rules which
go beyond or at least anticipate the upcoming
federal SO2 reduction regulations.
(b) States should establish ambient SO2 monitors
at all coal-fired power plants (for example, at
least three of Duke Power's coal plants have
violated ambient SO2 emissions in an erratic
patchwork testing program).
(c) States should employ the three hour rolling
average for determination of permitted emission
levels. The 24 hour block averaging method
approved by the NC Environmental Management
Commission in 1998 is a less restrictive method
which allows spikes of high SO2 emissions to be
averaged with lower levels, allowing higher
overall pollution.
(2) The ozone threat to cities and rural areas
should be addressed as a single problem.
(a) NOx emissions should be reduced to levels at
least matching the NOx State Implementation Plan
(NOX SIP).
(b) NOx emission reduction efforts must be part
of a total pollution reduction package for
coal-fired power plants, i.e., new devices or
retrofits should be accompanied by whole-facility
improvements which reduce other criteria
pollutants and toxins.
(c) Because ozone is created in part from toxic
air pollutants, the NC exemption for utility
boilers must be removed immediately.
Meeting the limits on toxic air pollutants at
property boundaries can be expected to contribute
to ozone levels reductions.
(d) Special areas where ozone levels remain
dangerously high for extended periods of time (as
much as 24 hours) should have increased ozone
monitoring and heightened ozone mitigation
programs.
(e) Relying too heavily on reductions from mobile
sources, which are harder to quantify and which
affect only certain areas of the state, must not
replace strict requirements for NOx reductions
from the big coal plants.
(3) No rollback in particulate emissions
standards should occur. BREDL recommends a
revocation of the Duke Power and Carolina Power
& Light Special Orders by Consent for the 10
and 20 year old visible emissions standards for
power plants. Visible emissions are integrally
related to other pollutants of concern, including
criteria pollutants and toxics.
In December North Carolina's Division of
Air Quality presented a new plan to reduce ozone
pollution caused by nitrogen oxides. The
plan would require the state's fourteen
coal-fired power plants to reduce emissions of
NOx by as much as two-thirds beginning in
2001. But the DAQ plan does not go far
enough; it does not meet EPA NOx reduction
requirements, but even this moderate proposal is
under attack by the utilities and their allies.
While utility spokesmen pontificate about
their "financial responsibility to our
customers and shareholders,"7
plants operated by Duke and CP&L emit over a
billion pounds of NOx per year11.
Both utilities emit high rates of nitrogen oxide
per ton of coal burned3
because of out-dated pollution controls.
Duke Power is the seventh largest electric
utility in the nation; Carolina Power & Light
is ninteenth1.
In total emissions of dangerous nitrogen oxides,
Duke is the fifth largest and CP&L is tenth2. Air pollution
is a national problem. Rather than seeking
delays, Duke and CP&L would best serve North
Carolina and the nation by leading us into the
new century with bold reductions in air
pollutants. It was irresponsible for them
to propose voluntary reductions only when more
stringent reductions are on the table.
Just over one year ago, North Carolina
Governor Jim Hunt invited other governors to a
Summit on Mountain Air Quality in
Asheville. But his words were as smoke on
the wind. This year North Carolina joined
with the electric power industry to challenge the
EPA on ozone reductions. The editorial
published in the Asheville Citizen said,7
"It is truly incomprehensible
that the state of North Carolina is
joining a lawsuit against the U.S.
Environmental Protection Agency filed by
utility and industry trade groups in
their continuing effort to avoid
implementing regulations that would
reduce nitrogen oxide emissions from
coal-fired plants."
"This lawsuit challenges directives
targeted at the emissions sources, the
power plants and industrial boilers
themselves. EPA regulations intended to
accomplish the same objective -- reduce
ground level ozone, a major air pollutant
-- aimed at 19 eastern states, including
North Carolina, were challenged by the
states in a lawsuit filed last year. A
federal appeals court ruled in favor of
EPA three weeks ago. Now, on Gov. Jim
Hunt's authority, North Carolina plans to
challenge that ruling, and adds insult to
injury by joining forces with the
polluters in another lawsuit."
North Carolina's government will ultimately
have to align itself with federal law and with
common sense. Does polluting industry have
the Governor's ear, or will he heed the call for
clean air from the people of North Carolina?
Respectfully submitted,
Louis Zeller
Clean Air Campaign Director
Citations
(1) Natural Resources Defense
Council, Benchmarking Air Emissions of Electric
Utility Generators in the US, June 1998,
p.15
(2) Natural Resources Defense Council,
Benchmarking Air Emissions of Electric Utility
Generators in the US, June 1998, p.18
(3) Natural Resources Defense Council,
Benchmarking Air Emissions of Electric Utility
Generators in the US, June 1998, p.30
(4) AIR Daily 1/10/2000
(5) Natural Resources Defense Council,
Benchmarking Air Emissions of Electric Utility
Generators in the US, June
1998, p.39
(6) Natural Resources Defense Council,
Benchmarking Air Emissions of Electric Utility
Generators in the US, June
1998, p.40
(7) Asheville, NC Citizen-Times, March 22, 2000
(8) Appalachian Voices policy paper delivered to
the NC EMC January 24, 2000 Science, Cost
and Benefit Factors in NOx Reductions in
NC, Dr. Harvard Ayers
(9) NC Division of Air Quality Trends in
Exceedences of the 8-Hour Ozone Standard
1978-1999
(10) Natural Resources Defense Council,
Benchmarking Air Emissions of Electric Utility
Generators in the US, June 1998, p.42
(11) US EPA Toxic Release Inventory, 1998
(12) Polluted Parks in Peril, Harvard G. Ayers,
Ph.D, October 1999
(13) Background Paper on NOx Sources as a Cause
of Ozone and Smog in NC and Surrounding States,
Orie L. Loucks, Miami University, February
1999
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