August 10 1995
Board of Directors
Southwest Air Pollution Control Authority
1308 N.E. 134th St
Vancouver WA 98685-2747

Dear Sirs;
A special report entitled The Big Dirty, by Craig McLaughlin, appeared in the August issue of Cascadia Times. The article notes that the Centralia Steam Electricity Generating Plant is the leading point source air polluter in Washington State for three pollutants; emitting 10, 7, and 2 times as much Sulfur dioxide, nitrogen oxides, and PM 10 particulate as the nearest industrial competitor. The article states that the plant is suspected of contributing to acid rain in and around Mt. Rainier National Park. It also states that local studies have indicated significant human mortality possibly as far north as Seattle have resulted due to sulfur dioxide and PM10 particulate emissions. The spokesperson for a major stockholder in the facility, PacifiCorp, reportedly stated that because EPA air quality emission standards have not been exceeded, "I don't beleive the plant is causing deaths in the region." The article also indicated that your agency is working to determine what action to take with respect to this situation.

With respect to clean air legislation, the Clean Air Act of 1979 directed the EPA to regulate more than 300 known toxic air pollutants. As of 1990, the agency had set standards on only 7 of these substances; the ones quoted in the EPA Polution Standards Index.

The American Lung Association of Washington's Summer 93 newsletter reported the results of a study done by the University of Washington, which showed that the national clean air laws allow the 24 hour average concentration of particulates to be 5 times greater than the concentration found to be linked to asthema attacks requiring hospitalization in Seattle. Disturbingly, the Association's 92-93 annual report noted a substantial increase in the incidence of asthema in Washington over the last decade.

The "Six City Study", conducted by the Harvard School of Public Health., found a 26% higher risk of premature death in the city with the highest concentration of particulate, compared to the city with the lowest concentration of particulate, of the six citys studied. EPA limits require that the concentration of particulate matter less than 10 microns in diameter not exceed a specified target value (the PM10 standard). The Harvard study, controlled for risk fctors such as tobacco smoking, corelated its mortality statistics with the presence of particles one quarter this size (2.5 microns), and found that the concentration of particles did not on average exceed one third of the target value. This means that not only were particulate concentrations measured in the study well within EPA allowable limits, but the wrong particulate size was chosen as a criterion. This information has been documented in Scientific American, November 1993, pp 23f. The American Lung Association subsequently filed suit against the EPA to demand an immediate review of the particulate pollution limit criteria.

The Winter issue of Clear Views, a publication of the Puget Sound Air pollution Control Agency (PSAPCA) discussed the white haze which has progressively reduced visibility in the Puget Sound Area since 1986. The visibility criterion, is in fact, the number of days each year between April and October during which Mount Rainier is visible from Sea-Tac airport. Although it is not aesthetic, the real significance of this haze is the fact that it is composed of extremely fine particulate material, which, according to Harriet Ammann, Senior Toxicologist for the Washington State Department of Health, is more easily lodged in the lungs, and tends to absorb more toxic (carcinogenic) matrial. "we've suspected for some time the (federal air quality) standards (set for particulate mater) may not be protective of health. But now we're saying they may not even be protective of life". A 1992 report by Joel Schwarz of the EPA, and Douglas Dockery of Harvard, estimated that respired particulate material may cause as many as 60,000 premature deaths every year.

The undersigned have been informed that you intend to hold a public hearing on August 15, at 3:00 PM in Vancouver Washington. Seattle and Tacoma are in King County, while Mount Rainier is in Pierce County. All of these are in the jurisdiction of the Puget Sound Air Pollution Control Agency. Because this issue has the potential to effect the health of citizens in Seattle, Tacoma, and Olympia, the undersigned are inquiring as to weither PSAPCA has been contacted regarding this issue. We also support the request of the Northwest Environmental Advocates for a more convenient tiem and location , and extended period for public comment, so that those effected by any decisions will have the oppertunity for input.