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This alert contains information about the proposed agreement between NC Division of Air Quality and Duke Power and Carolina Power & Light which would allow most of the coal fired electric plants to exceed state visible pollution regulations until 2002. The Director of DAQ, Alan Klimek, may sign this agreement, the "SOC," this week. Please call (919-715-6233), email alan_klimek@aq.ehnr.state.nc.us, fax (919-715-7175), or write him (address below) after reading this alert. Thanks. posted 8/20/1999 August 16, 1999 CP&L and Duke account for 68% of the NOx emissions and 75% of the SO2 emissions from all stationary air pollution sources in North Carolina, almost 1.3 billion pounds per year Approximately 80% of the 54 million pounds of toxic release inventory compounds listed by CP&L and Duke Energy is airborne pollution CP&L and Duke Energy are out of compliance with state and federal regulations Both utilities seek to lower existing pollution standards The SOC's bypass normal rulemaking procedures CP&L employs delay tactics which prolong installation of pollution controls Recommendations The Director of DAQ should not sign the SOC's No reduction in the existing air quality standards should be considered The NC EMC should hold a series of public hearings on air pollution impacts The DAQ should do a statewide analysis of economic and environmental impacts of visibility regulations, acid rain and greenhouse gasses, ground-level ozone, and air toxics Acid Rain, Particulates, and Ozone The six CP&L coal-fired plants listed in
the SOC released 400 million pounds of sulfur
dioxide, nitrous oxide, carbon monoxide, fine
particles, and volatile organic compounds in
1996. Duke Energy's seven plants released
over 900 million pounds of these criteria
pollutants. Together the 13 plants account
for 68% of the nitrous oxide emissions and 75% of
the sulfur dioxide emissions from all
stationary sources of air pollution in North
Carolina. And particulate emissions (PM-10)
for the same plants account for 52% of permitted
point source discharges. Hazardous Air Pollution A Toxics Release Inventory (TRI) is now
required annually by the Environmental Protection
Agency for all coal-fired electric generating
stations. The six CP&L coal-fired
plant's listed in the SOC--Cape Fear, H.F. Lee,
Mayo, Roxboro, L.V. Sutton, and W.H.
Weatherspoon--released 32 million pounds of toxic
compounds in 1998, mostly air emissions. In
1998 Duke Energy's coal fired steam
stations--Belews Creek, Dan River, G.G. Allen,
Riverbend, Buck, Marshall, and Cliffside--emitted
approximately 22 million pounds of toxic
compounds. These emissions result from the
burning of thousands of tons of coal. The
releases include hydrochloric acid, sulfuric
acid, hydrofluoric acid, barium, manganese,
copper, chromium, zinc, arsenic, nickel, ammonia,
beryllium, chlorine, cobalt, lead, selenium and
mercury. Utilities Are Out Of Compliance With Existing Regulations Carolina Power & Light and Duke Energy
stipulate in their respective SOC's that each is
in violation of 15A NCAC 2D .0521 Control of
Visible Emissions. "The COMPANY has
discharged and continues to have the potential to
discharge visible emissions to the
atmosphere...in excess of the Visible Emissions
Standard." (SOC paragraph 1.D) Regulatory Roll-Back Section II.B of the SOC states that excess
visible emissions for each plant "will be
allowed" above the limits set in 2D .0521
(40% six-minute opacity) and 40 CFR 60.42 for
NSPS units (20% six-minute opacity). The
SOC does not contain an upper opacity limit which
effectively allows a 100% opacity standard for
any given six-minute period under the
exemption. The SOC contains criteria which
allow excess emissions (EE) and continuous
opacity monitor downtime (MD) of up to 8%.
This formula is included: Improper Rulemaking Request The orders state that CP&L and Duke Energy
may submit a formal request to the Commission and
DAQ for a rulemaking change to 15A NCAC 2D .0521
to establish alternative opacity standards.
This amounts to stealth rulemaking which seeks to
bypass the normal procedure of working group
discussions, legislative debate, committee
amendment process, and approval by the Governor. A Strategy of Delay The permits for these coal-fired steam
electric plants stipulate the use of
electrostatic precipitators (ESP) for the control
of visible emissions and particulate
matter. The public notice for the SOC
states, "This order allows the Company time
to evaluate the condition of their electrostatic
precipitators and to explore various improvement
measures." Electrostatic precipitators
were first developed in 1906. They are very
effective at removing fine particles from the air
and are in extensive use throughout the
coal-fired electric utility industry. The IRP states: "During Phase II,
which begins January 1, 2000, the SO2 reduction
goals are to be reached through more stringent
requirements at virtually all fossil fuel
generating units. All of CP&L's
coal-fired units are Phase II-affected
units."
(CP&L Integrated Resource Plan, p. 4-1, April
28, 1995) Concerned with more stringent emissions
requirements, CP&L outlined its plan:
"In order to maintain flexibility and
satisfy all SO2 and potential air toxics
requirements at the lowest cost, decisions on
investments in ESP equipment should be delayed as
long as possible. Second, decisions to switch to
lower sulfur fuel or to build a scrubber should
also be delayed for as long as
possible." (emphasis
added)
(CP&L Integrated Resource Plan, p. 4-10,
April 28, 1995) Code Red In April Governor Hunt announced his initiative to reduce air pollution visibility impacts from fossil fuel combustion. The CP&L SOC and the identical Duke Energy Corporation SOC clearly run counter to the stated intent of the Governor. The impact of these electric plants on the state's air quality is huge. The increase in bronchitis, asthma, respiratory distress, emergency room visits, and mortality from unprecedented levels of air pollution in North Carolina require caution above all. At a minimum, the people of North Carolina
deserve a full public debate on these
issues. Therefore, we request that the NC
Environmental Management Commission hold public
hearings on this matter and that they consider
the combined SOC's environmental, economic, and
public health impacts. We advocate a series
of hearings to be held in mountain, piedmont, and
coastal regions which would allow citizens
concerned with this issue to comment. Respectfully submitted, |