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Proposed power plant near Bonanza should create concerns about air quality
Oct 2003

The author
Lyn Brock and her husband have a farm in Bonanza
 where they raise hay, cattle, and horses.  She has been
a teacher for Klamath County Schools and is an accountant.

By Lyn Brock
Guest columnist
     Residents of Langell Valley are concerned about the effect the proposed power plant, the COB Energy Facility, and emissions from this facility will have on our way of life and our rural agricultural valley 20 miles east of Klamath Falls.
        We received the Oregon Department of Environmental Quality's (DEQ) "Air Contaminant Discharge Permit Review Report," which states, "... the presence of ammonia in the exhaust stack increases the rate of secondary formation of fine particulates such as ammonium sulfate and ammonium nitrate. In the dry summers in the Klamath Basin, when visibility protection is most important, this added secondary fine particulates adds primarily to the regional haze burden. In the moist winters the secondary conversion rates are increased and aided by the winter stagnation in the basin ammonia contributes to increased nitrogen and sulfur deposition. Additionally, a portion of this deposition burden is acidic. There is a significant increased risk to the Class I resources when the mountains are immersed in clouds or fog. This form of winter deposition accounts for a significant portion of the total annual deposition. The lakes in the Southern Oregon Cascades wilderness areas are recognized as some of the most sensitive lakes anywhere in the world. The burden of increased industrialization in the Klamath Basin puts these sensitive lakes at significant risk to eventual deterioration from increased deposition. For these reasons the ammonia slip associated with SCB (selective catalytic reduction) should be controlled at the lowest level possible."
      If DEQ is concerned about lakes which are distant from site of this facility, shouldn't we be concerned about the river, Big Springs Park, farmland, and  children who will be exposed to these emissions?
     I e-mailed Thane Jennings of DEQ with questions about who in National Park Service or Forest Service would study material and raise concerns involving  emissions effect on these beautiful lakes. Below is excerpt from his response:
        "Both the National Park Service and the Forest Service can comment on our permits, we don't have to accept their comments but we don't disagree with them very often. The National Park Service handles Crater Lake, the U.S. Forest Service takes care of air quality in the other wilderness areas such as Mountain Lakes Wilderness.
    "Copies of the Air Permit application, draft permit and public notice all went to the National Park Service. We did not receive any comments or concerns from it."

Resources should be protected
      I know these agencies must be drowning in paperwork and this is one more item for them to handle. It is important, though, that we protect our Oregon resources and Crater Lake which is a world-renowned national treasure.
    According to Thane's correspondence, "the public has 40 days from the date of the public notice to comment on air quality issues, the due date for comments is Oct. 27. DEQ Air Quality will hold a public meeting at the Lorella Community Center Oct. 21 to provide information and receive comments."
        I requested from Thane the responses  from the Forest Service. One letter states, "In our earlier memo this office had recommended that the applicant be asked to conduct ambient monitoring for PM10 and NOx near any of the Class I areas in northern California for a minimum of three years to validate the modeled data. The draft permit conditions do not show this requirement. We recommend it as a permit condition."
    The letter from Bachman (Air Resource Specialist, Forest Service, Pacific Northwest Region) states, "The lakes in the Southern Oregon Cascades wilderness areas are recognized as some of the most sensitive anywhere in the world. The burden of increased industrialization in the Klamath Basin puts these sensitive lakes at significant risk to eventual deterioration from increased deposition. For these reasons the ammonia slip associated with SCR should be controlled at the lowest level possible."

        The Notice of Public Hearing from DEQ says, "All of the pollutants listed above can have adverse affects on human health and plant and animal life in high concentrations. The level of emissions increases for the pollutants except SO2 are above the state's Significant Emission Rate (SER). The SER is considered to be the point at which adverse air quality impacts may occur. An ambient air quality analysis was conducted by the permit applicant which demonstrated that emissions from the facility will not cause pollutant concentrations in excess of any ambient air quality standards or Prevention of Significant Deterioration (PSD) increment, will not have a significant impact (including visibility impairment) within any Class I area, and will not cause a significant impact on any non-attainment area."
    It lists Class I areas as Gearhart Mountain Wilderness Area and Mountain Lakes Wilderness Area. I have packed into both  and wouldn't want to see  them harmed. I don't understand, though, if our state law is more concerned with lakes and wilderness areas than with the human population of Klamath Falls and Bonanza. I guess I need to ask more questions.

What about sulfuric acid?
   Maybe we should be more concerned about the six tons a year of H2SO4 mist (sulfuric acid) which will be raining down upon us and our landscape. Is anyone in Klamath Falls concerned about this?
     I believe I understand the following, though, from Mr. Blackwell's letter (Regional Forester, Forest Service, Pacific Southwest Region), "... the draft permit contains emission limits based on short averaging periods ... The above limits do not apply during start-up, shutdown or malfunction."
        In other words, emissions can be higher than safe during these periods and it is allowed. You might notice that on the rare occasions when the city of Klamath Falls CoGen is running, it starts up and shuts down frequently. As I understand, that is because emissions are frequently approaching unallowable levels. I'm glad I don't live near that facility! And yet the one proposed for Langell Valley is much larger.
     As stated by Roger Hamilton who is very familiar with Langell Valley and was former governor's energy advisor, "I am opposed to the construction in Langell Valley of what would be the largest natural gas electric generating plant in the Northwest."  Also stated by him in his commentary [H&N, 9/1/03] was, "I'm sure the knee jerk reaction of many, including the national administration, to the northeast blackout is to want to build more power plants and more transmission lines ... The BPA high voltage transmission system is currently congested, particularly in the north to south direction which the COB facility would use to sell to California and Arizona markets. Transmission line congestion is one of the suspects in the northeast blackout." And I especially liked the following, "It seems only fair to me that consumers causing power plants to be built, residing in the areas to which the power from the COB facility would be delivered, should be the ones exposed to the noise and pollution of the power plant serving them. This same principle best serves the efficiency, reliability and security of the electric grid by distributing the stress caused by very large plants throughout the system. An 1100 MW power plant like COB, with the capacity to serve a city the size of San Francisco, Seattle or Portland, should be built in those places, not in a farming community like Langell Valley which will have no use for the electricity produced."





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