Sunday, March 1, 2009

Comment letter to SD DENR

here is a copy of a letter i sent to the state of SD DENR contesting the Big Stone II power plant. the only problem i have with submitting letters of objection like this is that the people you are objecting to are the same people that approved it, and they don't like to be criticized that they are totally inept in their job. it is too bad this can't be submitted to a higher authority (God) for his approval..

Mr. Brian Gustafson, Administrator
Air Quality Program, South Dakota DENR
Division of Environment
520 East Capitol, Joe Foss Building
Pierre, SD., 57501

Dear Mr. Gustafson
Since the process of the Air Quality Permit for Big Stone II closely parallels the process that must be done with the Hyperion Oil Refinery, I read with great interest the objections raised by the EPA on the Big Stone Facility and feel an obligation to file an objection with the DENR on the permit request by Otter Tail Public Power for a 600 Megawatt power facility in Big Stone, South Dakota.
Under the Clean Air Act revision in 1990 the Congress of the United States revised and expanded the role of the EPA in enforcing regulations to reduce air pollution. In order to apply the standards of the Clean Air Act nationwide, the EPA delegated some of this responsibility to the states. When the EPA delegated authority to South Dakota DENR to act in its behalf, it also delegated responsibility. It is my understanding that it is the responsibility of DENR to uphold those standards when it comes to permitting companies to build facilities that will pollute the environment. I do not see that the DENR is acting in the best interests of the citizens of South Dakota. In fact, if you read the papers and applications submitted by Otter Tail, the DENR is acting in the best interests of Big Stone II, not the citizens of South Dakota.
One of the requirements of the EPA that is directed by the Clean Air Act as amended in 1990 to set National Ambient Air Quality Standards (NAAQS) (40 CFR part 50) for pollutants harmful to public health and the environment. The Clean Air Act established two types of national air quality standards. Primary standards set limits to protect public health, including the health of “sensitive” populations such as asthmatics, children, and the elderly. Secondary standards set limits to protect public welfare, including protection against decreased visibility, damage to animals, crops, vegetation, and buildings.
The EPA Office of Air Quality Planning and Standards (QAQPS) has set National Ambient Air Quality Standards for six principal pollutants, which are called “criteria” pollutants. I have listed them below.

National Ambient Air Quality Standards
Carbon Monoxide (CO)
8-hour Average
9 ppm
10 mg/m3
1-hour Average
35 ppm
40 mg/m3
Lead (Pb)
Quarterly Average

1.5 µg/m3
Primary & Secondary
Nitrogen Dioxide (NO2)
Annual Arithmetic Mean
0.053 ppm
100 µg/m3
Primary & Secondary
Ozone (O3)
1-hour Average*
0.12 ppm
235 µg/m3
Primary & Secondary
8-hour Average
0.08 ppm
157 µg/m3
Primary & Secondary
Particulate < 10 micrometers (PM-10)
Annual Arithmetic Mean

50 µg/m3
Primary & Secondary
24-hour Average

150 µg/m3
Primary & Secondary
Particulate < 2.5 micrometers (PM-2.5)
Annual Arithmetic Mean

15 µg/m3
Primary & Secondary
24-hour Average

65 µg/m3
Primary & Secondary
Sulfur Dioxide (SO2)
Annual Arithmetic Mean
0.03 ppm
80 µg/m3
24-hour Average
0.14 ppm
365 µg/m3
3-hour Average
0.50 ppm
1300 µg/m3

Big Stone II (BSII) threatens the quality of air and water not only South Dakota, but Minnesota and North Dakota. I am very concerned about BSII. I believe it is imperative that to prevent serious pollution of the surrounding area the facility must abide by MACT standards as directed by the EPA in their objections to this facility. In light of the words spoken by recently elected President Barak Obama and his desire to reduce carbon emissions throughout the United States, BSII is doing just the opposite. This is not the time to be releasing more carbon – the main cause of global warming - into the atmosphere. Nitrogen Oxide is one of the primary components of ozone, or smog. Sulfur dioxide is the primary component of soot. Some soot particles are so small they can become embedded in the lungs and this is dangerous for the elderly, the young children, and people with lung diseases.
I believe there is general consensus that the pollutants from BSII will create havoc with the plant and animal life in this area. Big Stone National Wildlife Refuge is a major waterfowl and migration area. If I’m not mistaken, there is a mapped bald eagle’s nest about 0.3 miles from the site. The bald eagle still remains a federally threatened species gentlemen.
I believe the EPA made it very clear in its letter of January 22nd 2009 that they object to the proposed Title V operating permit renewal for the BSII power Plant. Under the guidance of the Clean Air Act as amended in 1990 the state of South Dakota may enact stricter standards than the EPA but not less strict.
I urge you gentlemen to deny the clean air permit under the grounds that it does not meet the standards required to build a power facility in Big Stone, South Dakota

Sincerely yours


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