Thursday, February 24, 2005

NRCERB Comments re: Title V Permit- from L. Ann Rocker

CB9M Distribution: FYI
Click here: Bureau of Stationary Sources : Draft Title V Permits
Forwarded Message:
Subj: NRCERB Title V Comments - from L. Ann Rocker
Date: 2/22/2005 9:56:45 P.M. Eastern Standard Time
From: Pstahly
BCC: Reysmont

NRCERB Comments re: Title V Permit- from L. Ann Rocker
NYSDEC and NYCDEP’s NRWCP Title V Permit
NYSDEC Special Conditions

Item 1-1.1
1. We find this statement satisfactory.
2. This statement must be totally removed from the North River Title V, Permit and the following must be inserted and adhered to as follows:
The NRAQM equipment must be upgraded, renewed, replaced, and the program implemented continuously by the NYCDEP in perpetuity. The Harlem Community and other patrons enjoy Riverbank State Park atop the NRWPCP, where thousands of children and adults are in daily attendance. West Harlem has the highest asthma rate in New York, and Columbia University School of Public Health just finished a study of asthma in pregnant women and found that all the fetuses are affected by air pollutants.

The safety of the health of the community must be the priority in this component of the system.

Item 1-6.1
Opacity monitors must be installed on all ten engines, both blower and pump, to monitor all emissions and especially to avoid any unmonitored engine emissions from both types of stacks. This is necessary to stop disparities of which stack emissions are venting.

Item 6-1
Termination of monitoring station #8 leaves a void in the 8 existing monitoring stations. The move of the #3 monitor inside of NR’s North Wall to the South East Wall must remain identified as #3, because the #9 monitor that was promised to West Harlem and went into DEP’s budget was never installed. Monies for the #9 monitor were promised by the NYCDEP to NRCERB and the community for recreational usage. Please take note of this important concern.

The probe height requirement for the VOC monitors at the community station #6 is good. However, that monitor has to remain on top of the existing city transportation building roof, and the height must be compatible with the stacks in the RBSP.

In references to monitoring PM 2.5, the word “particulate” should be added, and the location of the monitor should be approved by NRCERB and the RBSP.

If the NYCDEP only has only two years left on this Title V Permit, they are clearly in violation for the last three years of operation of the NRWPCP, the NRAQP, and the NRWPCP Consent Order. A very significant penalty is in order here!

Item E: (a) (4)
An addition must be included as follows: The DEP must report these emergencies in the monthly review, the monitoring and compliance certification report, and report to the West Harlem Community and Community Board 9 within 30 days.

Item 10-1 (a)
3. Records must be made available to the community for examination upon request.

Item 1-2.
Is the 6 minute per hour Federal threshold to be established because currently the air emission contaminates are emited from the stacks most of the time? Usually there are continuous emissions.

2) Yes, usually plumes are observed from the stacks in three different colors: white, brown, and orange.

Item 1-6.2 Record keeping
In addition to quality reports of monitoring to the NYSDEC, please require that the DEP send these reports to the Community Board 9 and NRCERB. Also, oil sulfur standard exceedences that occurred during the reporting quarter must be reported to the community and made available to the community immediately.

Stack testing that will be required once every 5 years in order to demonstrate compliance with the regulatory standards:
Copies of stack testing results must be given to the community, in addition to plume and particulate compliance certification activities.

Item 66. 1
This is good. The NYSDEC must hold the NYCDEP accountable to this standard, particularly in communities of color such as West Harlem, where a disproportionate number of city service facilities exists.

Item 1-24.2
This compliance must be carefully monitored by the NYSDEC and the community. Also, the Jerome monitors must be checked, housekeeping rules of cleanliness and maintenance procedures must be checked, and reports documented.

Item 1-27.2
Because of maintenance lapses this has been a source of odors in the past. These regulations must be carefully adhered to in order to stop the escape of odor.

Item 76.2
The handling of NRWPCP odor complaints is acceptable when followed. This procedure must be carefully monitored by the DEC and kept in place.

Item H
Items that may fall into categories pursuant to 6 NYCRR part 616 Public Access to records and section 114 (c) of the 503 (e) of the act. A list of such information entitled to “confidential treatment” should be made, explained for cause, and added to this permit before it gets out of hand.

All personnel, both NYSDEC and NYCDEP, must continue attending the NRCERB monthly forums, and make reports in order to maintain community oversight. The NYCDEP must continue to finance this level of personnel and this must be written into the Title V Permit with all aforesaid requirements.

CB9M Distribution: For those inerested on Title V and the Questions pertaining to NRCERB Comments, follow the link and directions below.

Dear George,
I just got the link from Rick Muller (see below).

After you go to the link, scroll down the page to:
NYC-DEP NORTH RIVER WPCP 2-6202-00007/00015 (466 KB PDF file).
Download the PDF. Ann's coments start on PDF page 7 of 109.
Skip Stahly

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