Subject: Comments on Bruce Mansfield Title V Operating Permit (TVOP-04-00235) and an Acid Rain Permit (AR-04-00235)
Dear Pennsylvania Department of Environmental Protection,
I am concerned about the dangerous air pollution emitted from the Bruce Mansfield coal plant. This is the largest coal plant in the state, so it is critical that it uses state of the art control technology to protect public health. However, the plant has been operating for five years under an expired air pollution permit that was originally issued in 2002. The DEP has produced a draft permit that fails to ensure compliance with the updated provisions of the Clean Air Act and Pennsylvania's laws. The shortcomings of the draft permit include the following:
-- Fails to protect human health and prevent harmful sulfur dioxide (SO2) air pollution in violation of Pennsylvania law;
-- Does not ensure compliance with the one-hour nitrogen dioxide (NO2) standard;
-- Lacks certain necessary reporting requirements on monitoring and non-compliance;
-- Lacks adequate monitoring requirements for particulate-matter emissions, and fails to set separate limits for fine particulates;
-- Fails to protect downwind states from harmful pollution;
-- Does not ensure that the best available pollution controls were evaluated to prevent regional haze;
-- Improperly allows unidentified future construction projects to proceed without a permit; and
-- Improperly limits the type of evidence needed to demonstrate non-compliance.
In addition to addressing these deficiencies, the final permit must not result in any increased disposal of coal ash at the Little Blue Run Impoundment. The settlement related to this site requires FirstEnergy to stop disposing waste materials in the impoundment by December 31, 2016. The air permit must also limit dust emissions from the Little Blue Run Impoundment.
