October 27,1995

Ms. Mary Riveland, Director
Washington Department of Ecology
Air Quality Program
P.O. Box 47600
Olympia, WA 98504-7600

RE: RACT Finding for the Centralia Coal Fired Power Plant

Dear Ms. Riveland,

The Mountaineers is the oldest and one of the largest conservation and outdoor recreation organizations in the state of Washington, with over 15,000 members. Mountaineers members have been instrumental in the protection of Mt. Rainier National Park and the creation of Alpine Lakes Wilderness. We have followed the proceedings of the SouthwestAir Pollution Control Agency (SWAPCA) and their efforts to improve air quality surrounding the Centralia coal fired power plant with some interest. The vast majority of our 15,000 members live, work, and recreate in the area affected by the plant's emissions, and we are concerned by the potential dangers to human health and the environment. We urge the Department of Ecology to support stricter pollution controls at the Centralia Power Plant, and to revise the comprehensive state visibility implementation plan.

Located in close proximity to millions Puget Sound residents, the Centralia Plant is the largest single source ofsulfur dioxide (802) in the West. Emitting 65,000 tons of 802 per year, the plant produces over 50 percent of all sulfur dioxide emissions in the State of Washington alone. The Centralia Plant is also a substantial generator of nitrogen oxide (NOx) and particulate matter pollution.

The Reasonably Available Control Technology (RACT) Order released by SWAPCA requires the Centralia Plant to limit its 802 emissions to 55,000 annual tons by the year 2002. We believe that both the timetable for installing pollution control equipment sliould be accelerated, and the limits on S02 emissions lowered. Specifically, we recommend the installation of scrubbers in both of the Centralia Plant's stacks, which would remove 90 percent ofS02 emissions, to be completed as soon as reasonably possible.

The Clean Air Act cites specific requirements for the protection of Class I national park and wilderness areas. Washington State has eight Class I areas including Mt. Rainier and the Alpine Lakes Wilderness. These area's outstanding aesthetic qualities are enjoyed by millions of local, national, and international visitors every year. Washington's residents and visitors expect clear vistas, pristine environments, and healthy ecosystems. Tourism, which is dependent on such qualities, is an ever- increasing segment of our state's economy and the Centralia Plant is causing long-term damage to the state's valuable, natural areas. In formal comments and testimony before SWAPCA, the National Park Service presented several studies demonstrating that the Centralia Plant's emissions contribute to visibility impairment and acid deposition at one or more Class I national park and wilderness area in Washington. We strongly urge that measures including stricter pollution control technology be installed at the Centralia Plant, in order to protect the economic and environmental health of our state. - . (206)284-6310

The Clean Air Act requires each state to prepare a visibility implementation plan. Plans must include a long term strategy, addressing emission limitations and schedules of compliance; an assessment of visibility impairment, along with a discussion of how to remedy existing impairment in Class I areas within the state; and emission limitations representing Best Available Retrofit Technology (BART) for each existing stationary facility identified through a BART proceeding. Washington state should take full advantage of its ability to instigate a BART proceeding for the Centralia Plant. In terms of achieving its national visibility goals set by the Clean Air Act, the state would be best served by addressing large, substantial polluters such as the Centralia Plant.

According to the American Lung Association of Washington, there has been a stunning 40 percent increase in the incidence of asthma over the past decade. Most research indicates that air pollution is one of the major contributors to this dramatic rise. Air pollution hits the young, the elderly, and those with lung disease the hardest. Over one million people in Washington suffer from some sort of lung disease, and are at risk from additional health problems due to air pollution. In order to protect the health of citizens in Washington State, we believe it is imperative that the RACT be reviewed at least every five years. We oppose the 20 year wavier granted to the Centralia Plant by SWAPCA that would exempt the plant from future air quality determinations.

While the Centralia Plant currently meets Clean Air Act requirements, the proximity of Class I national park and wilderness areas, along with the economic importance of a clean environment for tourism, recreation, and reduced human health problems, creates a strong argument for stepping beyond those requirements. The Mountaineers believes a proactive approach to maintain a high standard of air quality will best serve all Washington residents.

The Mountaineers is very sensitive to the issue of job loss. We understand the importance of the 730 plant jobs to the rural Centralia area. But clean air is a resource that belongs to all 5,334,000 Washington citizens, and it must not be squandered in the name of temporary cost savings. With proper investments in air pollution control technology, we believe the economy, the environment, and jobs can be sustained together for many years to come.

Thank you for the opportunity to make these comments.


Craig Rowley

cc: David Lucio, Seattle City Light
Robin Cross, PUD #l ofSnohomish County