Testimony for ACHD Permit # 0679-I001
March 4, 2004
Kate St. John, GASP Board
Impact on Allegheny County air quality:
Allegheny County is not in attainment for PM2.5. Though this project is lasts a limited time, it will generate lots of particulate and add to the county’s non-attainment problem. To move toward attainment, the County will have to cut PM2.5 by other sites and industries. I suggest that tighter controls be placed on this project, including more monitoring and monthly reporting, so our region can move toward attainment.
High volume of heavy-duty diesel vehicles:
According to the draft permit, the Coal Processing Plant (P001) may process up to 177 tons/hr of coal to a maximum of 800,000 tons of coal/yr. The coal will have to be moved offsite, so assuming a 12-hour workday, this translates to about 8 truckloads/hour, or 96 round trips per day.
The Stone Crushing Process (P002) may process up to 110 tons/hr of rock to a maximum of 500,000 tons of crushed rock/yr. These maximums mean 5 truckloads of crushed stone per hour, or a maximum of 60 truck trips per day.
If these two processes run simultaneously, there may be as many as 156 heavy-duty diesel round-trips per day.
Part B of the Miscellaneous Emissions section describes vehicular traffic fugitive dust emissions. It states that the heavy-duty diesel vehicles will travel on 0.5 mile of unpaved roads and that annual vehicle miles will be 1495 miles per year. Is this a stipulation of 1495 miles “per vehicle” or the “annual total for the project”? As written, it seems to refer to the project’s annual maximum (the draft permit indicates the applicant must record total vehicle miles traveled on a daily basis and report a monthly summary).
Now with 156 HDDV round-trips/day on a 0.5 mile dirt road, they’ll travel 156 total miles each day. If I understand the text correctly, this leaves the applicant 9.5 days to do the entire project. Either I have misunderstood the text and the problem has to be clarified or the number is too low and the restrictions need to be reviewed in light of the real potential vehicle miles.
Ultra-low-sulphur fuel stipulation for HDDV:
The draft permit requires Processes P001 and P002 (Coal Processing Plant generator and Stone Crushing Process generator) to burn low sulphur fuel (not to exceed 0.2% by weight). I propose that ultra-low-sulphur fuel be required of the heavy-duty construction vehicles.
And finally, we have all seen black opaque smoke spewing from heavy-duty diesel construction trucks. The draft permit should make it clear that 60% opacity from any vehicle is prohibited. This concept is partly addressed in the Site Level Terms and Conditions (points 8a and 9a) but it is not clear enough concerning vehicle exhaust.