USDA Forest Service
Technical Review of the Cambria Coke Company
Prevention of Significant Deterioration Application and Draft Plan Approval
March 2005
The USDA Forest Service received an application, draft plan approval, and staff analysis for the proposed Cambria Coke Company (Cambria) project on February 14, 2005 from the Pennsylvania Department of Environmental Protection (PADEP). Cambria Coke Company is a subsidiary of Sun Coke, Inc. and seeks approval to construct and operate a heat recovery coke plant in Cambria Township, Cambria County. The plan will process 2.55 million tons of wet (4%) coal annually in 280 heat recovery coke ovens to produce 1.7 million tons of high quality metallurgical coke annually. Additionally, the facility will use waste heat from the coke batteries to produce 165 megawatts of electricity.
Sulfur dioxide (SO2) emissions will be controlled to 3661 tons per year, and H2SO4 to 32.27 tons per year using a lime injection/spray dryer/adsorber system with 90% control efficiency. Nitrogen oxides (NOx) will be controlled to 1365.5 tons per year using combustion staging. Particulate matter (PM10) emissions are limited to 390 tons per year and total suspended particulate (TSP) to 526 tons per year.
One of the purposes of the Prevention of Significant Deterioration (PSD) program is to “preserve, protect, and enhance” the air quality in national parks and wildernesses designated as Class I areas. The Clean Air Act (CAA) gives the Federal Land Manager (FLM) an affirmative responsibility to protect the air quality related values (AQRVs) of the Class I areas. Cambria has the potential to impact air quality and AQRVs at two Class I areas administered by the Monongahela National Forest (MNF), Dolly Sods and Otter Creek Wildernesses. Dolly Sods is located 170 kilometers, and Otter Creek 175 kilometers, south of the proposed facility.
In fulfilling our CAA responsibility we have reviewed the PSD application and draft plan approval to determine whether or not the emissions from Cambria will have an adverse impact on any of the AQRVs in the class I areas. The air quality related values at these areas include visibility, vegetation and water. The following comments are based on the class I modeling results and the draft plan approval received February 14, 2005.
Procedural Issues
We received a PSD application, draft plan approval and technical review document on February 14, 2005. We also received notice of a public comment period ending March 28, 2005. There are several procedures required by the Clean Air Act and its implementing regulations that are not being followed in the case of Cambria. These procedural issues include: providing insufficient time for the FLMs to review and comment on the application and draft plan approval, and providing inaccurate information to the public on the potential impacts to AQRVs in the class I areas and level of class I increment consumption by Cambria.
Under PADEP’s delegation agreement with EPA and its regulations in 25 PA Code 127 Subchapter D, EPA retains the authority as the "Administrator" for those portions of section 40 CFR 52.21(p) dealing with notification and consultation for sources impacting Federal class I areas in subparagraphs - (1) Notice to Federal Land Managers and (2) Federal Land Manager. Specifically, under 40 CFR 52.21 (p)(1), the FLM should be provided all information relevant to the permit application within 30 days of receipt and at least 60 days prior to the public hearing[1]. Accordingly, it is EPA's responsibility to provide notice and to consult with the Federal Land Managers; however EPA would need to receive the information in adequate time to do this. In this case, PADEP supplied the FLM with notice and class I impact information for Cambria, but not within the time frames outlined above. Although PADEP has not scheduled a public hearing, the intent of this regulation is to allow the FLM adequate time to review the materials and provide comments to the state permitting agency, so that information on potential adverse impacts can also be communicated to the public. The FLM was not provided 60 days to review and comment on the Cambria application or draft plan approval.
The regulations also indicate that information on increment consumption should be included in the public notice. 40 CFR 51.166(q) (iii) regarding public participation states that the reviewing authority shall:
Notify the public, by advertisement in a newspaper of general circulation in each region in which the proposed source would be constructed… the degree of increment consumption that is expected from the source or modification…
And, 25 PA Code 127.45(4), states that the public notice shall include:
For sources subject to Subchapter D (relating to prevention of significant deterioration of air quality), the degree of increment consumption expected to result from the operation of the plant or facility."
The PSD application clearly shows that Cambria would have a significant impact on 3-hour and 24-hour sulfur dioxide increments at Otter Creek and Dolly Sods Wildernesses; however PADEP did not include this in the public notice. Since PADEP did not provide the degree of increment consumption by Cambria at Dolly Sods and Otter Creek Wildernesses, it failed to properly advise the public of the impacts in each of these sensitive areas.
Furthermore, PADEP stated in the public notice that refined CALPUFF modeling showed minimal impacts to visibility and deposition in the class I areas. From the FLM’s perspective, this is erroneous information, as documentation supporting this claim was never provided. If a refined analysis was conducted, the results were never provided to the FLMs. FLMs were sent Chapter 8.5 of the Plan Approval Application and this described CALPUFF run in the screening mode. In fact, the information in Chapter 8.5 did not include deposition results; the FLM had to make an additional request to obtain the information. As will be discussed later, the deposition impacts are considered to be adverse impacts. Based on the limited documentation provided to the FLMs, it is our conclusion that erroneous information regarding potential impacts to the class I areas was provided in the public notice.
Class I Air Quality Analysis
CALPUFF
According to the information provided in Chapter 8.5 of the Plan Approval Application, a class I modeling analysis using CALPUFF in the screening mode was used to assess potential incremental increases in pollution and impacts to air quality and AQRVs in Otter Creek and Dolly Sods Wildernesses. Our review of the modeling finds that the applicant did not follow all recommended options for CALPUFF-Lite screening modeling. They did not apply concentric receptor rings around the plant site, but instead modeled the standard receptors for each Class I area. This likely resulted in an underestimate of impacts at the class I areas. This could have been avoided had a modeling protocol been submitted for FLM review and comment prior to approval by PADEP. However, it is not clear from the material provided, whether PADEP approved the modeling protocols.
The applicant used peak short-term emission rates representing the periods when Heat Recovery Steam Generator (HRSG) maintenance is conducted and exhaust gases from 40 coke ovens bypass the SO2/PM control systems. These emission rates are equal to, or greater than, the 24-hour emission limits in the draft plan approval. These are appropriate rates for the 24-hour increment and visibility analyses, but not for the 3-hour and annual increment analyses or the deposition analysis. Again these issues could have been avoided, had a modeling protocol been provided for review.
These issues indicate the need for a revised modeling analysis, however to meet the comment deadline we have reviewed the class I impacts and made comments taking these issues into consideration.
Class I Increment
The Cambria PSD increment modeling results are summarized in Table 1. Concentrations above the class I significant impact levels (SIL) for PSD increment consumption were modeled at both Otter Creek and Dolly Sods. Cambria exceeds the class I increment SILs for short-term sulfur dioxide (SO2) concentrations (both 3-hour and 24-hour averages). For other pollutants, particulate matter (PM-10) and nitrogen oxides (NOx), and annual mean SO2 concentrations, the maximum impacts are less than their respective SILs. However, due to the issues discussed above these results may be underestimated or, in the case of annual impacts, overestimated.
Table 1. Class I PSD increment modeling results showing maximum impacts reported in micrograms per cubic meter.
Pollutant / Significant Impact Level / PSD Increment / Otter Creek Wilderness / Dolly Sods WildernessSulfur dioxide (SO2)
3-hour / 1.0 / 25 / 2.241 / 2.172
24-hour / 0.2 / 5 / 0.715 / 1.055
Annual / 0.1 / 2 / 0.013 / 0.015
Particulate matter (PM-10)
24-hour / 0.3 / 8 / 0.055 / 0.093
Annual / 0.2 / 4 / 0.0010 / 0.0011
Nitrogen dioxide (NO2)
Annual / 0.1 / 2.5 / 0.0011 / 0.001
Because the SO2 (and possibly other) class I increment SILs are exceeded, the need for a multi-source CALPUFF modeling analysis is triggered. The applicant has not provided a cumulative increment analysis. Other recent cumulative modeling analyses for this area have shown violation of short-term class I SO2 increments, making this analysis particularly important. Without a cumulative analysis we do not know if Cambria is a significant contributor to a violation of increment.
We informed the PADEP modeler and permit writer assigned to Cambria of our concerns regarding the lack of cumulative increment analysis in an email dated February 16, 2005. The applicant responded that the modeling likely overstated impacts and furthermore, emission reduction credits were owned by the company that could be used to mitigate these impacts. It is our understanding that exceedence of SILs cannot be mitigated away with emission reduction credits; the appropriate modeling demonstration must be made. If the applicant believes the impacts are overstated, it would be appropriate to conduct a refined analysis to evaluate whether the significant impact levels (SIL) are exceeded. If the refined analysis shows that impacts are below the SILs, no further increment analysis is needed. If the SILs are still exceeded, then a cumulative analysis is required. Based on the modeling results received, we believe that a complete application should include a cumulative class I increment analysis.
Impact to Air Quality Related Values
Of the many AQRVs FLMs are charged with protecting, visibility is the one AQRV that was specifically mandated by Congress. The assessment of visibility impacts to the Class I areas is therefore a very important one. The applicant’s assessment predicts the maximum daily change in visibility.
Emissions from Cambria are predicted to result in a maximum increase in light extinction at Dolly Sods of 12.21%, with 8 days in 5 modeled years showing greater than 5% change, and 1 day in 5 modeled years showing greater than 10% change. At Otter Creek, the maximum increase in light extinction was predicted to be 10.53%, with 7 days over 5 years showing over 5% change, and 1 day in 5 modeled years showing over 10% change. A change of 10% and greater is considered to be perceptible by the general public. These results are presented in Table 2. However these results may be underestimates due to the modeling errors mentioned previously, therefore we cannot make a conclusive statement on visibility impairment.
Table 2. Class I visibility modeling results showing percent change in light extinction from Cambria over five modeled years.
Otter Creek Wilderness / Dolly Sods WildernessMaximum Visibility Change / 10.53% / 12.21%
Days over 5% / 7 / 8
Days over 10% / 1 / 1
Two additional AQRVs, water and vegetation, could be affected by Cambria’s emissions. It is well known that stream water in many parts of West Virginia, particularly Dolly Sods and Otter Creek, is acidic. The current situation is the result of a combination of underlying geology that lacks buffering capacity and historically high sulfur deposition patterns. These same factors are also affecting soils. As soils acidify several changes take place, among these is the potential loss of nutrients needed by vegetation and the mobilization of aluminum that is toxic to roots and soil biota. Leachates from the soil then move into stream water and affect the aquatic ecosystem. Obviously the effects of acid deposition on streams, soil and vegetation within a watershed are linked and affect one another.
Annual emission rates were modeled to predict the impact of Cambria’s emission on sulfur and nitrogen deposition at the class I areas (Table 3.). Maximum annual sulfur deposition is 0.122 kg/ha for Otter Creek and 0.132 kg/ha at Dolly Sods. Nitrogen impacts are considerably less in both Class I areas.
Table 3. Maximum and average annual deposition of sulfur and nitrogen from Cambria’s emission at the class I areas in West Virginia.
Otter Creek Wilderness / Dolly Sods WildernessMaximum Annual Deposition
Sulfur in kg/ha / 0.122 / 0.132
Nitrogen in kg/ha / 0.022 / 0.024
Average Annual Deposition
Sulfur in kg/ha / 0.0882 / 0.0748
Nitrogen in kg/ha / 0.015 / 0.0156
We found that annual sulfur deposition from Cambria would cause measurable decreases in the acid neutralizing capacity of the most sensitive streams in both Otter Creek and Dolly Sods Wildernesses, even when all five years of modeling results were averaged (thus lowering the effective deposition rate). Sulfur deposition from Cambria’s emissions are predicted to produce reductions in acid neutralizing capacity (ANC) of 0.255 microequivalents/liter in the most sensitive streams at Otter Creek, and 0.216 microequivalents/liter in Dolly Sods. These measurable reductions in ANC values would further degrade streams that have already been adversely affected by acid deposition and are unable to support aquatic life. We consider measurable sulfur deposition impacts in these ecosystems already negatively affected by acid deposition to be unacceptable and therefore adverse. Appendix A provides more details on the current status of aquatic and terrestrial resources and our rationale for finding it an adverse impact.