Legalectric

The new Draft Air Permit is out for the Laurentian “biomass” burner in Hibbing, and Comments are open until August 18, 2008.  This is the “clean energy” plant that was violating its air permit and was fined.  Now we’ve got the new one… what’s different?

Notice of Draft Air Permit

Draft Air Permit

Draft Air Permit – Technical Support Document

Comments should be sent, BY AUGUST 18, to:

Toni Volkmeier, Air Quality Permits Section
Industrial Division, Minnesota Pollution Control Agency
520 Lafayette Road North, St. Paul, Minnesota 55155
651-296-8717 – Fax

email: toni.volkmeier@pca.state.mn.us

I noticed in the permit’s Technical Support Document that although the federal rules have been vacated, they are issuing it “as if” noting that the federal rules were incorporated into the Minnesota Rules.  But as Alan notes, if the rules were vacated because they were ineffective, insufficient to protect the environment, what good is that? Here’s direct from the Technical Document:

2. Regulatory and/or Statutory Basis

New Source Review
The facility is an existing major source under New Source Review regulations. No changes are authorized by this permit.

Part 70 Permit Program
The facility is a major source under the Part 70 permit program.

New Source Performance Standards (NSPS)
The existing wood boiler (EU007) is subject to New Source Performance Standards Subpart Db. The applicability is not affected by the changes made through this permit action.

National Emission Standards for Hazardous Air Pollutants (NESHAP)
The wood boiler (EU007) is permitted as subject to NESHAPs Subpart DDDDD, which has been vacated.  All operating conditions remain the same; however, when the CEMS requirements were consolidated into a single group (GP003), any citations that were previously Subpart DDDDD requirements were changed to Minnesota Rules requirements.

Compliance Assurance Monitoring (CAM)
Since there are no actual changes to emission units, CAM is not an issue at this time.

Minnesota State Rules
Portions of the facility are subject to the following Minnesota Standards of Performance:
• Minn. R. 7011.0510 Standards of Performance for Existing Indirect Heating Equipment
• Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment
• Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion Engines
No changes to applicable requirements result from the changes made through this permit amendment.

So here’s my question… if the MPCA is issuing permits under federal rule, and if they’re doing their Part 70 Permits under federal delegation, and where the rule has been vacated because it didn’t cut it, on what basis, under what authority, are they issuing permits?  This seems to be an area where they’re wide open to challenge!  I would think that any permit issued under the Minnesota adoption of those rules that were deemed inadequate could be thrown out rather easily…

Bizarre, but true! Something that makes camping a lot easier — internet access! Week before last, we took a couple of days off  and went up to Lake Itasca so Alan could see more of Minnesota, and given we’ve both got “virtual offices,” it’s really a problem to be off-line. So hearing that Douglas Lodge at Itasca had wireless, yes, Douglas Lodage:

I figured it wouldn’t be that tough to go over there once in a while. Guess again, there was too much to do and then, after we finally got to the desk near the fireplace, and when telling management how much I appreciated having access there, I learned it was all over the park, and even IN THE PINE RIDGE CAMPGROUND! PERFECT.  Yup, here’s the proof, above!

And we had a wonderful visit with Rollie and Shar Jacobsen, who are living now up near Park Rapids, home of a real old fashioned ice cream parlor (Rollie knows what I like!). I so miss having them as neighbors and extended family right downstairs… as we left, Rollie handed me a genuine Jacobsen’s bag, and delight of delights, it was filled with Jerry Garcia Band CD’s, 10-15 (haven’t counted), I’m still on the second one and savoring every bit.

And yes, we did get out in a boat on Lake Itasca, and saw new baby loons, and one huge, HUGE snapping turtle swimming along.  The world’s biggest red pine is a little worse for wear…

No… this wasn’t the one swimming across the lake…

Another coal gasification bites the dust — yes, it took a coon’s age to get this posted, what can I say, the CapX hearings are taking up a lot of time… This was the best news in ages, continuing the theme that IGCC is a bad idea, too risky, too costly. This plant was one that seemed to have a lot of backing, which to me means that IGCC is done. When I’d posted about it, it garnered some wild NRG employee comments on this blog, ones that I hope that those employees’ bosses are aware of! I know NRG is watching, but I think some of their employees need to have their typing fingers taped together and/or not operate a computer while soused!

Here are a few articles with some choice comments:

From the Buffalo News:

Power Authority stops $1.6 billion plans for advanced coal plant at Tonawanda’s Huntley Station

Power Authority officials estimate that it would take an additional $175 million to $200 million per year in subsidies – on top of the significant aid already promised for the project – to bring the price of the electricity produced at the advanced coal plant down to the point where it could compete with other conventional sources of generation.

From newsday.com:

NYPA halts plans for clean-coal plant in Tonawanda

After pursuing various state grants and tax incentives, NYPA determined it is not possible to fully close the gap between what NYPA would have to pay for electricity and competitive market rates.

And from the Post Journal:

NYPA withdraws support for North Tonawanda clean coal project

”The economic, technological and regulatory obstacles are too great to warrant any further efforts at this time,” said Christine Pritchard, a NYPA spokeswoman.

… and…

NYPA officials were also uneasy about the technology. According to the company, there are only two IGCC plants operating nationwide, and 11 IGCC plants were either delayed or cancelled in 2007. In addition, the largest sequestration operation in the world is burying only 1 million tons of carbon dioxide underground annually, a third of what the NRG plant would be required to sequester – and carbon capture and storage technology has never been demonstrated off a clean coal power plant.

… and…

”It is also clear that an explicit and rigorous regulatory process with public support is a prerequisite for sequestration on a large scale. And while some amount of risk is necessary to prove new technology, the financial and environmental risk associated with this large-scale commercial power plant is simply too great,” the report concludes.

… and…

”Simply, at this time, the price gap is too large to overcome” said Pritchard of NYPA.

Tell us something we didn’t already know!!!

Yup, burning coal has an impact, you betcha.  Tell us something we didn’t already know.  But here’s a study that shows some specific results when comparing neurodevelopment of children exposed prenatally with those who were not exposed because the coal plant had been shut down.

Here’s the study:

Benefits of Reducing Prenatal Exposure to Coal Burning Pollutants

So what more do we need to know that shutting down coal plants is overdue?

The Clean Air Interstate Rule has been vacated, and here’s the real deal:

North Carolina v. EPA (consolidated with many more)

OK, one more thing to get figured out…