12.3.19 Bailiwick News – NVEC Letter to Pa. DEP requesting public hearing on Penn State’s plan to add a Combustion Turbine-Heat Recovery Steam Generation unit to the West Campus Steam Plant in downtown State College.
By David Stone, on behalf of Nittany Valley Environmental Coalition
For further reference, see DEP’s proposed plan approval, reprinted in the Nov. 14, 2019 edition of Bailiwick News, at pp. 3-4.
To: Muhammad Zaman, Environmental Program Manager, PA Department of Environmental Protection, Air Quality Division, North Central Regional Office, Williamsport – email@example.com
Re: TVOP – 14-00003K
Dear Mr. Zaman:
The Nittany Valley Environmental Coalition (NVEC) requests that DEP hold a public hearing in State College regarding this West Campus Steam Plant (WCSP) combustion turbine permit application.
NVEC is an incorporated 501(c)4 organization whose members will be adversely affected by this proposed approval.
Furthermore, as a non-profit organization formed specifically to support local community environmental and due process rights guaranteed by the Pa. Constitution and our local municipal Environmental Charter Bill of Rights, we contend that DEP should schedule this public hearing as the legally mandated next step to ensure that DEP, NVEC, State College Borough, and other affected parties can reasonably assess the need for any further action.
On the face of it, the combustion turbine (combined heat and power/CHP) application itself shows that tons of pollutants are being added to the already heavily polluted downtown streets adjacent to new student high-rises towering up to 65 feet above the existing stacks.
NVEC members’ past participation has already prompted verifiable industry-wide computer modeling by a national developer, the Borough, our own expert, and even Penn State itself which demonstrates an increase in local pollution hotspots; as compared with the pre-gas conversion situation.
That coal-burning configuration, although deprecated in the context of overall regional air quality, had at least included a locally very effective baghouse filter and 199-foot stacks.
There is even a relevant Penn State study which shows that the fracked gas supply as actually delivered to Penn State contains radionuclides which exceed the level in the traditional gas supply; and already exit the existing East Campus Steam Plant (ECSP) stacks in detectable amounts.
This, in combination with the usual volatile organic compounds (VOCs), condensable particulates – and in fact all particulate matter (PM or fine particulates) – pose immediate health risks to the tens of thousands of students, and other residents, who live in, or visit, our downtown.
It is our position that DEP and Penn State, as Instrumentalities of the Commonwealth, are required to give “extra scrutiny” to this demonstrated air quality issue.
But there have been significant problems so far which have short-circuited such scrutiny and due process.
For instance, during the municipal comment period, State College Borough Council unanimously requested just such a public hearing, and indicated its serious concerns about the combustion turbine application as it relates to the downtown air quality situation.
It is our understanding that Council directed staff to resubmit this hearing request during the current public comment period which ends Dec 2.
It is our belief that further action to reinforce this request, and convey more specific concerns, would have been taken by Council; except for the fact that the DEP response letter was received Nov. 12 and the next voting Council meeting was Dec. 2, just after the close of business deadline for this comment period.
It is our understanding that in its interactions with Borough staff, DEP may have gotten a mistaken impression about the Borough’s resolve to pursue these matters.
A local public hearing amicably resolves any such discrepancy.
We also should inform you that Penn State has now, perhaps in anticipation of easy DEP approval, refused to continue to provide NVEC’s volunteer expert and the Borough with the data from PSU’s recent air quality modeling so as to allow us, and the Borough, to cross-check the modeling analysis which the University uses to justify not providing additional mitigations such as a higher stack and additional monitoring.
It should be noted that the Borough has already required funding from an adjacent high-rise developer to install one monitor.
A public hearing would help solidify and co-ordinate expansion of this limited monitoring capability with DEP and PSU.
Finally, there is a rather intricate historical narrative involving NVEC members and the Borough which must be reviewed by DEP staff in order to determine whether illegitimate “phasing” has been used in this application process; starting with the original conversion to gas, and the proposed lowering of the stacks from about 199 feet to 86 feet.
It should be noted that as a result of our extensive participation in that first phase several years ago, the stack was raised from a proposed 86-foot height to the current 99-foot height, and PSU agreed to voluntarily close Boiler #6.
This was in addition to negotiating a voluntary change in the high-pressure gas line route and significant increased physical security for certain vulnerable infrastructure.
It is disconcerting to us now that PSU is, in effect, claiming the closing of Boiler 6 as part of the offset for this supposedly independent CHP project many years later.
It had been our contention, as conveyed in extensive comments filed with DEP at that time, that the impacts of this planned CHP should have been analyzed as part of that original gas conversion.
We argued that it was the prospect of this eventual combustion turbine at the West Campus Steam Plant (WCSP) which unduly constrained PSU from implementing additional mitigations because of building layout space constraints, among other things.
In fact, PSU, in order to avoid extra scrutiny of the phasing issue – and to stay just under certain regulatory limits which would have triggered additional studies and mitigation requirements; ostensibly dropped the combustion turbine plan at that time.
However, we now see that that was just a tactic to avoid holistic DEP regulation of the complete project.
Classic “phasing” in fact.
Some other concerns as identified by our expert witness:
- VOC (volatile organic compound) emissions from the two (2) 25,000-gallon above-ground fuel oil storage tanks are not accounted for in the air permit application or Plan Approval limitations. Due to the size of tanks and firing capacity of combustion units, the tanks will experience many overturns even with limitation of 384 hours per year.
- NOx (nitrogen oxides) monitoring is not robust enough to ensure compliance with 39.9 limit which was taken to avoid Federal New Source Review permitting. See Section D, I, #003, a), i). The permitted NOx limit is 99.75% of the 40-tpy (tons per year) New Source Review Significant Emission Rate.
- BAT (best available technology) limits under Section D, I, #003, a) should also be separately established for the Combustion Turbine and Duct Burner. BAT should address each operational scenario outlined for emissions testing in Section D., II, #010, d.
- Pursuant to Section D., II, #011 and #012, emissions testing is required at or near peak load, but operation at other loads when SoLowNOx is not in optimum operation may lead to higher emissions that won’t be captured with annual emissions testing and monthly emissions calculations. Due to this project’s avoidance of Federal New Source Review and identified local air quality issues, a continuous emissions monitoring system should be utilized.
- Section B, #10 of the Plan Approval prohibits “phasing” of projects. However, the phasing of this project is not sufficiently addressed as it relates to the overall West Campus Steam Plant Conversion Project that was recently permitted.
- The proposed Plan Approval does not include the following condition which has been in other PADEP Plan Approvals: “[25 Pa. Code §127.12b] Plan approval terms and conditions. Nothing in this Plan Approval relieves the facility owner or operator from the obligation to comply with all applicable federal, state and local laws and regulations.”
A public hearing is required to facilitate the resolution and/or mitigation of these concerns.