• The mill has the potential to release 636,000 pounds of particulate matter a year.  Of this, Pope and Talbot releases 242,000 pounds of particulate matter less than 10 microns in size, or 1/7 the width of a human hair.  Such particulate matter is small enough to get into human lungs and is closely linked to respiratory ailments and incidences of asthma (see, www.epa.gov/airtrends/pm.html);
• The mill has the potential to release 558,000 pounds of carbon monoxide, which at high levels can kill people (see, www.epa.gov/iaq/pubs/coftsht.html);
• The mill also has the potential to emit 46,000 pounds per year of hazardous air pollutants, including methanol and formaldehyde.  Methanol can cause neurological damage (see, http://www.epa.gov/ttn/atw/hlthef/methanol.html) and formaldehyde is a known carcinogen (see, http://www.epa.gov/ttn/atw/hlthef/formalde.html).

Under the Clean Air Act, DENR issues permits for the operation of pollution sources, like Pope and Talbot’s lumber mill.  The Clean Air Act requires that these permits be written to ensure polluters comply with air pollution limits and standards in order to protect human health and welfare.  The law also requires that permits contain monitoring requirements to verify that polluters are in fact complying with pollution limits and standards and protecting clean air.  Permits are essentially safety nets for clean air and as such, must allow no leeway for violations.

At issue with Pope and Talbot’s pollution permit is that the permit fails to require best available control technology for carbon monoxide and particulate matter emissions, which come primarily from wood burning.   According to the permit, emissions of carbon monoxide and particulate matter have the potential to exceed major thresholds that are meant to prevent significant deterioration of air quality.  Under the Clean Air Act, if pollution has the potential to exceed these thresholds, polluters must use best available control technology to reduce emissions.  Particulate filters, or baghouses, and an oxidation catalyst, could more effectively control particulate and carbon monoxide emissions.

Although the DENR believes that limits in the permit keep emissions below major thresholds, the EPA requires that permits contain monitoring that ensures compliance with such limits.  In the case of Pope and Talbot’s permit, there are no monitoring requirements that ensure compliance.

“An emission limit is like a budget, it’s not supposed to be exceeded,” said Nichols.  “And just as businesses do careful accounting so they don’t exceed their budget, so too must polluters diligently monitor their emissions so they don’t exceed their limits.  Monitoring is essentially accounting of air pollution.”

While the permit requires that a “performance test” be conducted once every five years to measure carbon monoxide and particulate matter emissions, performance testing is not a substitute for monitoring according to the EPA.  Due to the lack of adequate monitoring, Pope and Talbot must use best available control technology for particulate matter and carbon monoxide emissions.

“Pope and Talbot has a responsibility to protect clean air all the time, not once every five years,” said Nichols.  “This permit is essentially a blank check for unfettered air pollution.”

If a permit fails to protect air quality, the Clean Air Act gives citizens the right to petition the U.S. Environmental Protection Agency to object to the issuance of the permit.  In this case, citizens have petitioned the U.S. EPA to object to Pope and Talbot’s permit and require DENR to write a stronger permit.

Besides inadequate monitoring, the coalition has asked the EPA to object to Pope and Talbot’s pollution permit for other reasons, specifically that:         

• The permit fails to require control of hazardous air pollutants, including methanol and formaldehyde.  In particular, the DENR relied on estimates of hazardous air pollutant emissions that have been deemed inaccurate and unreliable by the EPA;
• The permit fails to require adequate monitoring of opacity, or the density of pollution, coming from the wood-fired boiler.  Opacity is used an indicator of whether Pope and Talbot may be compliance with other pollution limits;
• The permit fails to ensure that the DENR and the public are promptly informed when the lumber mill deviates from pollution limits and standards; and
• The permit fails to ensure that equipment and machinery are properly operated and maintained to ensure protection of clean air.

Under the Clean Air Act, the U.S. Environmental Protection Agency has 60 days to grant or deny the petition.  If the petition is granted, the DENR will be required to write a stronger permit and Pope and Talbot will be held to standards that actually ensure protection of clean air.