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Re: E-M:/ lung association announces power plant campaign

Enviro-Mich message from asagady@sojourn.com

At 05:32 PM 1/6/98 -0500, you wrote:

>FOR IMMEDIATE RELEASE                           CONTACT: Elliot Levinsohn
>Phone #:800/678-LUNG
>        The American Lung Association of Michigan announced today a
>campaign to clean up archaic coal-burning and oil-fueled power plants in
>Michigan as a way of improving respiratory health in Michigan, especially
>among children, the infirm, and the elderly.

As a former 15 year environmental director for ALAM, and leader of state
volunteer efforts to cut sulfur dioxide emissions in Michigan by nearly one
tons per year from the seventies to 1985, I'm particularly curious about
this new campaign.

How will this campaign explicitly get emission reductions from the largest

DE Monroe Power Plant, Monroe
DE Belle River Power Plant, St. Clair
DE St. Clair Power Plant, St. Clair
CE J.H Campell Plant, West Olive
CE Cobb Plant, Muskegon
CE Karn-Weadock, Essexville

>        The opportunity presented by the electric utility industry
>restructuring and

Actually, I think that this restructuring presents mostly environmental risk
and not 
opportunity, as industrial/commercial electric consumers seek the cheapest
power.   Maybe others can put a different spin on it, but I don't see any escape
from a "least common denominator" approach under deregulation to electricity
consumption where
consumers, particularly industrial/commercial consumers, seek the lowest
possible price for
electricity....which will come from the oldest, dirtiest, least debt ridden
coal burning plants or from
plants burning waste in some form.  But the lobbiests for Detroit Edison and
Consumers Power will probably find a way to save their hides on "stranded costs"
so that we'll continue to pay for expensive nuclear plants.

> the need to reduce greenhouse gas emissions to conform to
>the new global climate change treaty are additional reasons to end a
>two-decade-old "dirty air loophole" in the Clean Air Act, stated Elliot
>Levinsohn, air quality spokesperson for the American Lung Association of

Greenhouse gas emissions of carbon dioxide don't have anything at all
to do with ozone/asthma, unless you're willing to make a major argument that 
global warming has increased smog/ozone concentrations/occurrances in 
any particular area.......  I doubt that the data exists at this time to
make such a claim.

And what Clean Air Act  loophole???   Section 111 of the CAA provides for
new source performance
standards for new power plants.  There is also a provision for EPA approval 
of existing source guidelines that must be followed by the States.   However,
EPA never developed these existing source guidelines for many/most
source catagories and, in the absence of these guidelines, such sources are 
unregulated unless they are otherwise required to reduce emissions because
of a state implementation plan  requirements related to an existing ambient 
standard violation or they are regulated because they must reduce emissions
(at least somewhat for NOX) as part of an acid rain control program.   Your 
target shouold be EPA and various presidential administrations,  and not CAA

All Michigan power plants presently  have maximum rule-based emission
limitations for sulfur dioxide which
are stringent....equivalent to about 1.6 lbs of sulfur dioxide per million
BTU of
heat input.   The new source standard is 1.2 lbs of sulfur dioxide per
million BTU.   
In practice, many of Michigan's power plants are already emitting close to
the new
source value.

The real issues in Michigan  are nitrogen oxide emissions as to ozone
and mercury emissions as to fish contamination.   Most of the large electric
power plants in Michigan
are poorly regulated (to unregulated)  when it comes to NOX and completely
unregulated when
it comes to mercury.   EPA is presently trying to change this situation on NOX 
with the Ozone Transport Assessment Group process and rulemaking, but 
this is being vigorously resisted by the Engler Administration to the point
litigation is being contemplated and where Michigan was one of only 4 states to
object to the national control program.   A negative comment about Engler's
on NOX control from ALAM would have been more on-point.

>        "Imagine what it would be like if we relied on 30-year-old computer
>technology to run our offices," said Levinsohn. "America wouldn't be
>competitive. But that's exactly the kind of archaic technology we're using
>to generate the bulk of Michigan's electricity."

The issue isn't archaic technology.   The technical method for generating
electricity from fossil-fired electric utility plants for post-1977 electric
plants isn't different from pre-1977 plants.  The issue is the type 
of emission controls that are required to be installed to conform with the
necessary emission limitation requirements.   Plants with lower emissions
use low NOX burners, stack NOX control, low sulfur fuels, dry or wet 
scrubbing for sulfur dioxide control, baghouse controls for particulate 
control, etc.

>        When Congress adopted the Clean Air Act Amendments of 1977, Levinsohn
>explained, many old, dirty coal-fired power plants that were expected to
>close down over time were granted exemptions to the strict air pollution
>control requirements that apply to new facilities. 

There isn't any provision of the Clean Air Act of 1977 that
exempts existing electric utility plants from EPA requirements to set
emission standards or that otherwise says this.
Section 111(d) of the Clean Air Act explicitly 
gives authority to EPA to promulgate such existing source standards.....they
never got around to doing it until recently when they have been 
proceeding under Title I of the act and the OTAG process  to set national

And any plants that were causing or contributing to violations of particulate
health standards were required to comply with reasonably
available control technology requirements which, though not as tough
as new source standards, are not exactly lenient either.

>   But 20 years later,
>these "grandfathered" older plants are still operating, spewing out far
>more pollution than permitted at modern plants. Many of these dirty plants
>are emitting up to four times or greater the smog-forming nitrogen oxides
>(NOx) and levels of sulfur dioxide permitted at newer facilities.

Not true for sulfur dioxide for all of  Michigan power plants....

And ALAM, under their former executive director, Robert Smith, is the party
was responsible for ensuring this was not the case on sulfur dioxide.    I
still remember
Morton Sterling, Detroit Edison's former vice-president for environmental 
affairs, visiting Bob Smith  in an unsuccessful attempt to 
try to call ALAM off on the Monroe Power Plant
sulfur dioxide issue......so much for ALAM 
institutional memory/history  after ALAM mergers and 
downsizing and new CEO....

>        According to Levinsohn, the American Lung Association of Michigan
>is committed to making 1998 the year that attention is brought to this
>pollution problem and will craft community-based programs to inform
>Michigan residents on how they can be part of the solution to clean up our

As they said in the civil rights movement in the south...."keep your eye 
on the prize"....which is, in this case, knowing how the environmental
groups are going to actually get emission reduction regulations on 
NOX, mercury and CO2 from Michigan power plants.....any other goal/program
is secondary.

The only power plant sulfur dioxide issues I see in Michigan go to
the failure to control short term (one
hour) ambient exposures of sulfur dioxide and not to longer term sulfur
dioxide emission
limitations.   This would also be important around sour gas, cement and 
refining plants.   

The real issue is whether ALAM, MEC and the environmental groups will 
step up to the plate and be responsible for advocacy, rulemaking petition,
legal, PR
and campaign strategies designed to achieve regulations to get those
emission reductions.  Just doing "community-based" public awareness
programs will never achieve this goal.   And the strategies and messages
need to be "home grown" for Michigan since many of the national
organization PR messages don't fit the Michigan situation very well.

I see a need to sharpen the issues on power plant emissions...   keep
the global warming stuff, the NOX issue and the mercury issues as 
separate issues.   Mixing them together just dilutes your messages and confuses
the public.  Each is extremely complex in its own right and deserves
separate discussion.

Did ALAM or anybody else comment on the proposed operating permits
for all of the power plants in Michigan???   That was the very first
opportunity to have
done something about all of this and if no comments were made it was
really a significant lost opportunity.   If there were comments, what legal
appeal and "Chicago EPA" strategies are being persued to force some
of the issues raised?

A petition for administrative rulemaking to set emission limitations for
mercury and nitrogen oxides at power plants, cement plants, incinerators,
boilers and selected other source catagories should be put in front of 
MDEQ Air Division.   Let Engler deny or waffle on this in time for the 

On mercury, it is probably time to enact a statewide ban on residential, 
apartment and commercial incinerators....someone should introduce
this as legislation.   Even MSU is still operating dirty, uncontrolled
incinerators in some of the dorms.....  and both UM and MSU are 
operating waste incinerators which have had some problems......
.....SEAC are you listening???   It wouldn't hurt to tighten the existing
open burning statute as well.   EPA is supposed to be developing 
toxic emission estimates on residential open burning in the next year
or so.   Because of past consumer product use of mercury, this should
be an issue.   Its also time to clamp down on mercury emissions from
sewage sludge incinerators.   Someone should also determine the 
mercury fluxes/emissions at the Marathon Oil Refinery in Detroit
and the Total Oil Refinery in Alma...

Alex J. Sagady & Associates        Email:  asagady@sojourn.com
Environmental Consulting and Database Systems
PO Box 39  East Lansing, MI  48826-0039  
(517) 332-6971 (voice); (517) 332-8987 (fax)

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