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Please send the following message to the email address below and sign the petition below. Please be sure to include your full name, phone number, and address in your email to the Pennsylvania Department of Environmental Protection.
Comments are due Monday, June 19th.
Subject: Comment on 65-00990F
I am writing to comment on Plan Approval No. 65-00990F regarding the Tenaska Westmoreland Generating Station. I’m concerned about certain proposed modifications and their impact on air pollution from the plant.
The application seeks to increase the startup time from 1 hour to 1.5 hours, which will unnecessarily increase air emissions during this longer period of startup time. Additionally, the application seeks to exclude tuning from its definition of “normal operation,” which would exempt periods of tuning from hourly emission limits. This is concerning to me because tuning, or regular maintenance, is a required activity. Tuning is not exempt from normal operations according to the New Source Performance Standards and National Emission Standards for Hazardous Air Pollutants at the federal level. In DEP’s review memo, it specifically states that tuning at the power plant is done “seasonally” meaning it is both “normal” and “routine” and therefore should not be excluded from pollution restrictions related to “normal operation.” Furthermore, regarding the two DEP permits Tenaska cites as examples of exemptions from normal operating pollution restrictions during tuning, one is the Entriken gas compressor station, which is a completely inappropriate comparison because it is a compressor station. The other example is TVOP #03-00975 for the Armstrong gas-fired power plant in Shelocta, PA. The comparison to this permit is even less applicable because DEP has established separate emission rates for nitrogen oxides, carbon monoxide and volatile organic compounds from each turbine during the periods of start-up and shutdown, turbine retuning, fuel transfers, and automatic runbacks while combusting diesel fuel. In permit #03-00975, DEP included specific hourly emissions standards for turbine retuning in source group restrictions #11 and #12. It is not appropriate to compare the hourly tuning emissions restrictions in TVOP #03-00975 to Tenaska’s annual emission limit and 1-hour NOx limit as DEP does in its review memo of this application.
Additionally, the proposal to modify the duct burner limitation limits from an hourly standard to a fuel consumption standard is inappropriate because by Tenaska’s own admission, the longer operating hours will be at “less than maximum heat input.” This lower heat input will result in more air pollution during the duct burners’ operating hours and Tenaska specifically mentions that the PJM dispatch of plant output significantly varies and could create significant fluctuations in air pollution based on varying heat inputs. Furthermore, operating duct burners at partial load is not accounted for in the permit's calculations and modeling. DEP must establish specific heat input standards and emissions limits to account for the abnormal operation of the duct burners. A fuel consumption standard is inappropriate to limit pollution from this source.
The Tenaska plant is a major source of air pollution and yet has been operating since 2018 without a Title V permit. It is inappropriate for DEP to refer to plan approval 65-00990C as a Title V operating permit (TVOP) as DEP does in its review memo of this application. DEP should require Tenaska to address start-up pollution and pollution during tuning before making a decision on this plan approval modification. Thank you for your consideration of this issue.
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