The Alliance For A Clean Environment

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Congratulations to Concerned Citizens For Limerick's
Future On Their Outstanding Victory

DEP Hearing for Proposed FPL Power Plant
From: Alliance For A Clean Environment
Presented by Donna Cuthbert - October 3, 2001

The Alliance For A Clean Environment asks DEP to deny FPL permit # PA-46-02-03. These air pollution emissions would add a dangerous and unacceptable burden on public health in the region. ACE believes this permit must be denied to comply with DEP’s mission statement, the PA Constitution, and National Ambient Air Quality Standards under the Clean Air Act.

DEP Mission Statement
DEP’s mission statement directs DEP to protect the air and provide for the health of PA citizens through a cleaner environment. FPL’s plant would further pollute severely contaminated air, in a heavily populated area, where public health is already jeopardized. The air in Montgomery County is among the top 10% of the most unhealthy and carcinogenic air in the nation. The results are painfully evident.

    a. Shocking increases in many kinds of cancers in Montgomery County are documented by the PA Cancer Registry statistics.

    b. Childhood cancer deaths, ages 1 to 14, are up 71% in Montgomery County according to the CDC, while they are down in surrounding counties, the state, and the nation.

    c. There is a rise in asthma deaths in Montgomery County, according to the CDC.

    d. The Pottstown Memorial Medical Center is a short distance from FPL’s proposed plant. Most physicians at PMMC say “we cannot risk any more pollution problems. Our doctors are very concerned as they see a significant increase in pollution-induced disease. Those most concerned are the pulmonologists, allergists, pediatricians and obstetricians.”
ACE asks that DEP relate these statistics and information to the regulatory evaluation of this project.

Is there a link between our severely polluted air and all our elevated, environmentally related illnesses, including cancer? Undoubtedly! It is time to face the facts and stop blaming the victims and their lifestyles. ACE’s has repeatedly documented massive evidence, of the harmful health effects of hazardous substances, which travel downwind into the county from the Pottstown Landfill and Occidental Chemical.

People would face even more of a health risk if another air pollution permit is issued. The air would be more contaminated, and the health risks for tens of thousands of people would be greatly intensified. If this permit is issued, we ask DEP to explain how it is consistent with DEP’s mission to protect our air and our health.

PA Constitution
There is no inherent right to pollute our air. In fact, the PA Constitution, Article 1, Section 27, states that PA citizens have a right to clean air. Breathing clean air is a basic right and a necessity. Citizens in this region have already been denied that right. Our air is severely contaminated and we are all forced to breathe it. Hazardous air emissions also contaminate our soil, our water, and even our homes. We can not protect ourselves or our children from these harmful emissions as they get into our lungs, and are even absorbed into our skin and eyes.

DEP has continually ignored mountains of evidence of harm. How will we be able to have livable communities and remain in them, if DEP continues to permit our air to get more contaminated? To further pollute our air is in direct conflict with our right to clean air as PA citizens. If DEP issues FPL’s air pollution permit, explain how this is consistent with our right to clean air under the PA Constitution.

Clean Air Act
National Ambient Air Quality Standards under the Clean Air Act were put in place to protect the HEALTH of the public from ‘criteria’ air pollutants. Government research documents that elevated levels of ‘criteria’ air pollutants injure human health and harm the environment.

If an area has not met Clean Air Act HEALTH standards it is said to be in “non-attainment.” Our area is classified a SEVERE non-attainment area, meaning it is among the most unhealthy in the nation. These federal standards require REDUCTIONS of ‘criteria’ air pollutants to protect public health.

It defies logic that DEP would even entertain this proposed air pollution permit in a severe non-attainment area, where FPL wants to further pollute our air with enormous amounts of ‘criteria’ air pollutants. If DEP chooses to disregard federal Clean Air Act health based standards, and issues this FPL permit, we ask DEP to clearly justify that disregard.

Please address this issue!

6 miles upwind of the proposed new power plant is the Pottstown Landfill. At a public hearing in March, 2000 a Pottstown Landfill spokesperson said “Our facility sits in a severe non-attainment area. It’s near impossible to design a power plant today that would have low enough emissions and would meet the current criteria to get a permit from the DEP.” If the Pottstown Landfill could not get a permit to build a power plant for the gas it already generates, how then could FPL get a permit for a new power plant in the same severe non-attainment area?

Please Address This Issue!

Why DEP allows air pollution credits to be bought and used in a severe non-attainment area. Reductions are required to protect public health because the area is in compliance. We ask DEP to justify FPL’s purchase and use of air pollution credits in our severe non-attainment area.
  • Selling air pollution credits is playing a dangerous pea and shell game with the lives of tens of thousands of people. It provides polluting industries with loopholes that attempt to legitimize something which was never intended and which has great harmful health consequences to the public.

  • Polluting industries should not be permitted to sell the right to pollute anyone’s air, mush less air that is already severely over-polluted. Air pollution sales should be prohibited in severe non-attainment areas.
DEP needs to explain why one of the most dangerous air polluters in the state, Occidental Chemical, has been permitted to sell ‘ air pollution credits’ to FPL, less than 2 miles downwind from Occidental’s extremely hazardous air emissions, in this severe non-attainment area, where people are already sick.
    a. Enormous numbers of people including those downwind in Limerick, Spring City, Royersford, and beyond, are already facing the synergistic and cumulative harmful health effects of some of the most dangerous air emissions known to mankind.

    b. Criteria air emissions, in addition to extraordinarily dangerous air emissions from the Pottstown Landfill travel about 4 miles into Occidental’s extremely hazardous air emissions, which then are intensified as they travel less than ONE mile the Limerick nuclear low-level radiation emissions.

    c. DEP just permitted this threat to get much worse. If Occidental burns Pottstown Landfill gas there will be a frightening CONCENTRATION of dangerous air missions less than a mile from the nuclear plant – not only more HAZARDOUS air emissions – more radiation, more dioxin, and heavy metals. How will people thrive or survive? How could DEP even think of adding to this potential for disaster?
Interaction – Hazardous and Criteria Air Emissions with Radiation
  • Experts say every exposure to nuclear radiation, even low-level radiation, increases the risk of cancer. It is persistent and deadly.

  • Rachel Carson in Silent Spring made the connection between radiation, chemical contamination, cancer, and genetic damage. Many years age she recognized the harmful interaction between radiation and other industrial chemicals to cause cancer.

  • We believe the current reaction between the chemicals in our air with the low-level radiation, both from the Limerick nuclear plant and Pottstown Landfill gas, are a major factor in the significantly elevated cancers in this area.
ACE would like DEP to produce peer-reviewed science addressing the potential for synergistic harm to human health. In less than one mile interaction exists between the hazardous chemicals and criteria air emissions from Occidental and Limerick’s radiation emissions. FPL’s proposed emissions would interact with Limerick’s radiation in less than ½ mile.

We want specific answers about the interaction of VOC’s, NOx, and ground level ozone with radiation. We believe they work synergistically with radiation to enhance the cancer-causing effects of radiation.

Before DEP would issue an air pollution permit for FPL, less than ½ mile away from the Limerick nuclear radiation emissions, DEP needs to scientifically prove there would be no harmful interaction. If DEP does not have the expertise to provide this proof, we ask DEP to get the NRC involved in the FP&L air pollution permitting process, or use the Precautionary Principle to deny this permit.

Please value the lives of the people in this heavily populated region, especially those most at risk – our children, the elderly, and the many people who are already sick. ACE urges DEP to deny FPL permits to further pollute our air.

Together we can make our community safer for our children, our families, and ourselves. If you would like to participate in or donate towards campaigns, programs or projects, please contact ACE.

P.O. Box 3063
Stowe, PA 19464

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