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View Diary: Fighting for Environmental Justice in Omaha (5 comments)

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  •  If your health damage claim concerns (0+ / 0-)

    the 1 hr sulfur dioxide impacts from this plant, what does your modeling show about relationship between the 99% percentile value for the 3 year average of 1 hr SO2 ambient impact values from current emissions/operations and the level of the 1 hr SO2 NAAQS standard?

    In the case of that Maryland plant that had the very high SO2 impacts, EPA never found or determined that the area around the Maryland plant was a nonattainment area for the 1 hr SO2 standard.    This means Sierra Club's strategy won't actually reach effective control actions for SO2 against that facility.

    If you have modeling studies that show the ambient impacts to exceed the 1 hr SO2 standard or that the plant is otherwise jeopardizing compliance with a SO2 NAAQS, what strategy/litigation is SC pursuing against both of these plants that addresses the failure to comply with the SO2 NAAQS and which will lead to  State Implementation Plan limits to get the SO2 problems under control?

    Mercury emissions from that plant don't have anything to do with local respiratory health impacts or complaints in that North Omaha community as mercury emissions from power plants generally fail to cause ambient impacts exceeding mercury inhalation screening criteria published by U.S. EPA immediately around such facilities and mercury is not implicated at all in asthma and respiratory disease.

    If this facility is going to comply with the power plant MACT and continue operating as a base load coal fired plant, SC needs an effective  strategy to ensure that the plant becomes subject to SO2 NAAQS State Implementation Plan emission control rules.   It could also mean a higher, good engineering practice stack for the facility to address plume downwash if the facility has short discharge stacks.

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