20061006WVE.pdf

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Women's Voices for the "Earth
MiSSOula OfficeP.O. Box 8743
MisSoula, Montana 59807
PhoAe: (406) 543~3747 .
Fax: [phone]
wve~womeriandenlli ronmentorg
www.womel'landenvironmefT!,org
Bozeman Office 'P.O;Box1067
Bozeman, Montana 59771
Phone: [phone] .
Fax: (406) 5B5~5P49
a Imee~wom enandenvi ran m ant. or!)
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IDAHO PUbLIC
UTILITIES COMMISSION
Octeber 5th , 2006
Commission .5ecretary
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Idahe Pll~lic Utilities Cemmission
O. Bcx 83720
. Boise 10 83720-0074
, Fax: [phone]
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Comments Re: Thampscn River .ccgen and A vista Utilities POwer PurchaseAg1"eement
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Case #: .AVU-O5-
. Tc the Idahe PUC:
, These cemments are submitted onoehalf ofWomen s Voices fbrthe Earth
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an environmental health' advocacy organization, based in Mis~cula, MT withstaff in Bczeman , MT and Baise, ID. We work to reduce and, where
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possible, eliminate persistent toxic pc II uti on -which disproportionately 'affeqs wemen. and children s health. We are very concerned abcut the impacts
the Thempson RiverCogen on the environmental and .public health .of thearea. On behalf .of cur hundreds .of members in Montana aqd Idaho , we askyou:notto approve the piJrcpase agreemef!t b~tween Avista Utilities andThomps~n River Cogen
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. 1.)The operation of Thompson River Cogen wiH ha.ve serious and significantenvironmental and publichealth impacts tc the co~munjty ofTbompsorJ
Falls. .
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. The pla~t will burn predaminantly ceai )Vhich will addto Iccal and regicnalmercury contamination. Mercury is a potent neurot(')~in; which especially.affects the brain 'ofa develcping child. The main-rcute of ~xPosure .tc .mercury is though eating contaminated fish. The Npxon reservoir
, a localrecreation ,area and fishing spct j.s unfortunately already heavily ccnta":'linatedwitt! m~rcury. Testing offif?h ccnductedin 2005. led the MontanaDepartment .of Public Health and Human Services ta issue a special fish
cansumption warning fcr fish caught from the locaJ Nc~on Reservoir. TheThompson River Cogen will only add to this already s~rious problem.
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100% pC!&1-Gan.~lime~ cIIIOlin"!:frs6rP.~yr.IM MOOI
09/25/2006 03: 02 4055494100 NCAT NHT PAGE 02
Particulate pollutian from Thampson River Cogen is alsa a serious concern. Modeling conducted
for this plant's air permit indicates that ambient particulate pollutien will likely increase by
350% in the area, frcm 30 ugl.m3 tc 136 ug/m3. The naticnal ambient air quality limit for
particulate pall uti on (PM- to) is 150 ug/m3 meaning that the ccgen alone is bringing the area
from a status of having quite clean air, to an area that .only just meets the federally allowed limit.
It should be acknowledged that while the NAAQS were intended to protect health, an encrmcus
body of scientific kncwledge generated since the promulgatian .of the NAAQS shows .otherwise
particularly with respect to particulate matter. Perhaps the best summary .of this cames from the
testimony .of Dr. Neal MacIntyre speaking on behalf of the American Thoracic Society, the
preeminent professianal association of pulmonolcgists and respiratory technicians.
Neil Mac Intrye M.D., Chief Prafessar of Critical Care Medicine and Directcr of the Pulmonary
Rehabilitatien program at Duke University presented the fallowing testimony on behalf .of the
American Thoracic Seciety (A TS) .on the EP A draft Staff Paper on Particulate Matter at the
November 12 2003 meeting of the Clean Air Scientific Adviscry Committee (CASAC).
I would like tc make two over-arching cemments that I think shculd guide CASAC and the
EPA staff as it ccntinucs its wcrk detennining whether the current particulate standards shculd
be changed. First, the science is scund and ccrnpelling. Both in its quality and its quantity, the
vast preponderance .of studies show that fine particle air pellutien is dangerous fcr public health
at current levels. Secondly, it is time to meve fcrward with decisian~making. We certainly dcn
know all we want to knew abollt scme specific issues, but we do know enough to be confident in
moving forward to resolve this review .of the science to pretect public health " stated Dr. Mac
Intyre.
The American Thoracic Seciety reccmmends a Icwering .of bcth the upper threshald and the
lower tl11'esheld fcr the annual average Fine PM standard, the 24-hcur Fine PM standard; the
Annual Average Coarse PM and the 24-hour Coarse PM standard. A growing body of evidence
is dccumenttlh.~adverse health effects .of both fine and coarse PM pollution at levels sienificant
below the current standards: The standards should be revised ta reflect this growing bcdy of
evidence " (emphasis added)
Full testimeny available at: http://www .cleanairstandards.org/article/articleview/29 111/38/
In fact. scientific studies en the health effects of particulate pollution show that an increase .of
100 ug/m3 in the ambient air is likely to increase the death rate in Thompson Falls. The
fallowing study from the New England Journal .of Medicine found that overall rate of death from
all causes increases by .51 percent with every increase in the ambient PM 10 level of 10 ug/m3.
TRC's permit estimates an increase in PM 10 level .of 100 ug/m3 in Thempson Falls - which
calculates tc a 5% increase in deaths in Thompson Falls due tc TRc.
Citation
N Bngl J Med. 2000 Dec 14;343(24):1742-
Fine particulate air pellution and mortality in 20 U.S. cities, 1987- t 994.
Samet JM , Dcrninici F, Curriero FC, Coursac I, Zeger SL.
Department of Epidemiolcgy, School of Hygiene and Public Health, Jahns Hopkins University,
09/26/2005 03: 02 4065494100 NCAT NHT PAGE 03
Baltimore , MD 21205 , USA.jsamet(gJjhsph.edu
2) The TRC facility is no Icnger being weicemed by the local ccmmunity. The project was
initially proposed to the ccmmunity as a true cogeneraticn facility. The project was supposed tc
be a win-win which would provide local cperaticnsjobs as well as spurring on forestry jebs
associated with cutting slash which would provide bicmass far the generatcr. These promises
fell flat when TRC announced that it would be burning predominantly coal in the boiler, with
the exception of a small amcunt .of woad waste from Thompsen River Lumber. This facility is
barely a ccgen at all , and could tertainly never qualify as "green pcwer . We have attended
many .of the hearings and public meetings en the Thompscn Falls Cogen: They have all been
~cked with unhappy neighbcrs expressing their frustration with the process and the pollution
from the facility. The premises .of econcmic development and gccd jcbs for the ccmmunity have
not been fulfilled - as mest .of the jebs asscciated with the eperaticns .of the plant went to trained
operatars brcught in from out of state. The community has lost any faith in the upper
management .of TRc. Barry Bates, a partner in TRC , has recently been indicted for federal tax
fraud. TRC has also been unwilling to pay lecal property taxes .owed to the county.
3) Thompson River Ccgen has repeatedly demonstrated itself as a Bad Actor facility. The boiler
was purchased secandhand from RJ Reynclds Tcbaccc (whc as it turns cut has received air
quality awards fcr replacing their .old coal fired bailers with cleaner natural gas fired turbines.
The original plan for the plant (as .outlined in their initial preconstruction permit) was nat
fallowed. They built a significantly larger plant than they had permitted far. The original design
was meant ta have a 156 MMBtli/hr capacity. The facility that was built now has a 215
MMBtu/hr capacity, a difference that led tc significant fines frcm DEQ.
The original pclluticn ccntrol equipment installed on the boiler simply never operated coITectiy.
TRC failed its first and only campliance source tests for S02 and NOx - emitting in same cases
nearly triple the allcwable emissicns. In respcnse the MT DEQ issued .over $1 millicn in fines ta
TRC fer vialating environmental laws. The ambient air quality mcnitor required for the permit
was never located in an apprcpriate approved space so as to accurately ccllect data. TRC built a
discharge pipe for prccess water which led te an unlined pond , and did sc while claiming they
dud not need a water discharge permit. (Upcn inspection , the DEQ disagreed with this claim,
and TRC has since lined its pand, and has applied fcr a discharge permit.)
4) TRC has "at fully secured all the permits it needs tc operate. In fact, TRC lost the backing to
a significant loan issued by the Montana Board of Investment (801) when it was discovered that
the Cogen had not secured all the necessary permits it was required to have te receive the loan.
Specifically Thcmpsen River Cogen still has net secured its water right for the facility, it is
currently in the process .of acquiring Thempscll River Lumber s water right .of water from the
Clark Fork River. Altheugh , even if the water right transfer is granted, the amount of water
associated with this water right will only supply abeut six months ofTRC's estimated needs.Water tram wells drilled by TRC .on the preperty may nct be .of appropriate quality for its needs
09/26/2005 03: 02 4055494100 NCAT NHT PAGE 04
either. As mentianed abeve TRC is alsa in the process .of acquiring a water discharge permit.
is unclear whether the pracess water fwJ:T1 the plant will need tc be processed befcre being
released back inot the river .or into groundwater.
5) Lastly, this year, Governor Kempthorne passed a twe-year moratarium on thebuilding or
permitting of any ccal-fired power plants in the state .of Idahe. This made the statement that
Idaho was rejecting coal-fired power. Avista Utilities shculd not be sidestepping this
moratorium by purchasing coal-fired power fer use in ldahe that is generated just beyond the
state s border.
We appreciate the Idahe PUC's role in reviewing purchase agreements in Idaho and understand
the gravity with which ycu consider these matters, We hope these comments have been useful in
adding tc the overall context .of this facility. Thank yall for your seriolls consideration .of thesecomments.
Sincerely,
Alexandra Gorman
Director .of Science and Research
Wcmen s Voices fcr the Earth
O. Box 8743
Missoula, MT 59807
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