Appendix A - Washington State Department of Ecology

United States
Department of
Agriculture
Forest
Service
Pacific
Northwest
Region
Sarah Rees
Air Quality Program
Washington State Department of Ecology
PO Box 47600
Lacey, WA 98504-7600
Dear Ms. Rees:
333 SW First Avenue (97204)
PO Box 3623
Portland, OR 97208-3623
503-808-2468
File Code: 2580
Date: November 3, 2009
On September 16, 2009, the USDA Forest Service received notification of the proposed Settlement
Agreement between the State of Washington Department of Ecology and TransAlta Centralia Generation
LLC on air quality matters. The proposed agreement includes both the determination of Best Available
Retrofit Technology (BART) for the NOx emission limits and voluntary mercury reductions at this
facility. Based upon our review of the BART documents, we are providing the following comments.
In brief we conclude:
• The TransAlta facility contributes to visibility impairment at 12 Class I areas (9 are FS managed) plus
the Columbia River Gorge National Scenic Area.
• This visibility impairment is modeled to occur up to 144 days per year at the most impacted FSmanaged
Class I area (Alpine Lakes wilderness). Mt. Rainier National Park is impacted even more
frequently at 168 days per year.
• New NOx controls as described in the BART documentation and the Settlement Agreement will do
little to improve visibility; reducing the number of days impaired by only 6% at Alpine Lakes to 135
days per year and only 3 % at Mt. Rainier to 163 days per year.
• Post-combustion control technologies are available that can do a better job of reducing NOx and
improving visibility than the Flex Fuels project alone. We encourage you to reconsider the value of
visibility in the Class I areas and require additional NOx reductions through either Selective Catalytic
Reduction (SCR) or Selective Non-Catalytic Reduction (SNCR).
• We advocate a reduction in permitted SO2 emission limits from the current limit of 10,000 tons per
year (tpy) to approximately 2900 tpy. This emission level has been demonstrated to be achievable by
the facility in the past two years and allows for upward adjustment for maximum heat input in the
past 10 years.
• The provisions associated with the BART determination should be independent from provisions
associated with voluntary mercury reductions, effectively removing the non-enforceability provisions
intended for the voluntary mercury reductions.
• Ecology should not limit itself from opportunities to reduce haze-causing emissions at the TransAlta
Centralia plant for the next 20 years.
The details of our concerns are presented below. Please direct questions to Rick Graw at 503 808-2918
Mary Wagner
Regional Forester
Enclosure
Final December 2010
Caring for the Land and Serving People Printed on Recycled Paper
L - 468