Coal Plant Design Flaws in Plant Washington Permits
Working on behalf of committed environmental advocates state-wide, GreenLaw recently submitted written comments challenging the air and water pollution permits that Power4Georgians has applied for in seeking to build a coal-fired power plant in Sandersville. No major power plant such as this can be built without both drawing in and discharging vast amounts of water, and Plant Washington is no exception. Similarly, any plant is going to emit large amounts of hazardous chemicals into the air in the coal-burning process. The expected productive “life” of such a plant is over 50 years, so getting the pollution levels set appropriately is absolutely vital to the immediately adjacent community as well as to those downstream and downwind of such a facility.
Unfortunately, the permit that the Georgia Environmental Protection Division (EPD) has proposed does a very poor job of protecting our air and water resources. The permit would allow the plant to withdraw up to 16 million gallons of water per day from the Oconee River or from 15 new ground wells drilled to tap into the Cretaceous Aquifer. The water table in Washington County has dropped 47 feet in the past 40 years. Plant Washington would also discharge both industrial wastewater and stormwater via a number of different outfalls into water already so contaminated by mercury that it can be unsafe to eat the fish. The plant would also be allowed to emit millions of tons of chemicals into air that is already so polluted that it fails to meet national health-based air quality standards.
Under federal and state laws, the State is required to regulate and limit pollutants that may reasonably be expected to be emitted into our air or discharged into our waterways to prevent these problems from occurring. The State is also required to ensure that there is enough water in our rivers to support aquatic life and sustain other uses for the water (agriculture, industry and drinking water). However, in the view of our experts and our legal team partners at the Southern Environmental Law Center, EPD has failed to do its job and threatens our air and water resources as follows:
Harming our Water Resources
(1) In times of lower flows, our rivers and groundwater resources can be drained too low. The permit is based on outdated and faulty models that overestimate the amount of water available from surface water sources. As a result, the plant’s operation could take too much water out of our rivers at the times when that water is needed most by downstream users and aquatic life.
(2) Waste ponds are likely to discharge polluted runoff into our rivers. The “plan” to keep runoff stored in giant liquid basins simply does not account for rainfall that we know Georgia can and will experience. Without proper planning, these basins containing waste from the coal plant will overflow and reach our groundwater and rivers.
(3) Even during normal flows, our rivers are so polluted from mercury that it is not safe to eat the fish from these rivers. To improve this situation, EPD set a limit on the amount of mercury that can be discharged from all the sources in the river basin near the Plant. Despite these dangers, EPD is planning to allow more mercury to go into our river from this one coal plant than it recommends from every single discharger in the basin, and that does not even take into account the massive amounts of mercury that will be emitted from the plant’s smokestacks.
Polluting Our Air
(1) Coal plant proponents call this plant “clean” while failing to mention that no one even considered using a technology – Integrated Gasification Combined Cycle or “IGCC” – that other companies, including Southern Company, have adopted. IGCC technology could result in 80% less “criteria” pollutant emissions each year. “Criteria” pollutants include sulfur dioxide, nitrogen oxide and particulate matter. Moreover, mercury removal rates of greater than 90% can easily be achieved with IGCC. IGCC technology would also result in significantly less sulfuric acid mist, beryllium, and hydrogen fluoride emissions from the facility.
(2) The permit contains no limits for carbon dioxide (CO2), although the plant will emit approximately 6 million tons of CO2 each year.
(3) Dangerous levels of small particles, called PM2.5, will be emitted from the plant in violation of federal law. Numerous scientific studies have linked particle pollution exposure to respiratory problems, decreased lung function, aggravated asthma and heart attacks.
We hope that our comments will persuade the EPD to deny the proposed permits because we do not believe that the situation can be adequately rectified. Alternatively, we expect EPD to fulfill its mission and impose permit conditions that protect the environment from the sort of harm that this plant is likely to inflict as currently envisioned. If EPD and the plant’s proponents do not correct these flaws, we will pursue all legal remedies available to us to protect Georgia’s environment.