41 



EPA Region III of Philadelphia recommended that the Clover 

 plant be required to clean up its N0 X emissions using technology, 

 selective catalytic reduction, that was available in 1991 and has 

 now been required in permits for a base load coal plant in 

 Florida and several cogeneration plants in Virginia and New 

 Jersey. EPA had the opportunity to reduce the N0 X emissions from 

 Clover by 8,000 tons per year, thus sending the message that new 

 plants would have to install best available control technology. 

 Instead, EPA bowed to political pressure and issued an opinion 

 that damaged, rather than enhanced, NPS's ability to protect the 

 parks . 



The ODEC opinion, issued January 29, 1992, let stand 

 Virginia's policy of not looking at the impact on the park of new 

 sources located more than 100 kilometers away. The decision then 

 requires that NPS quantify the impact of the proposed source on 

 the air quality-related values of the park. The opinion 

 undercuts Section 165 of the Act. The law requires that the 

 applicant demonstrate that the proposed new source will not 

 contribute to a violation of the Class I increment. If the 

 applicant makes such demonstration, then the burden is on NPS to 

 demonstrate that the plant would contribute to an adverse impact. 

 Under the ODEC decision, if a proposed plant is more than 100 

 kilometers from the park, the applicant does not have to 

 undertake increment modeling to demonstrate that it does not 

 contribute to a violation of the increment. NPS is left in the 

 untenable position of having the burden to quantify an adverse 

 impact on the Park, but not having any applicant-provided 

 modeling to indicate the level of emissions that will reach the 

 park. 



If NPS must quantify the amount of pollution adversely 

 impacting the resource from a particular new source, EPA must 

 either provide the tools to make this demonstration, or require 

 applicants to develop the tools to assess the impact of sources 

 beyond 100 kilometers. An interagency working group has now 

 developed a model that clearly allows assessment of the impact of 

 sources beyond 100 kilometers. EPA has issued guidance 

 indicating that states should look at large sources beyond 100 

 kilometers. However, EPA needs to issue stronger guidance that 

 will force states to require increment modeling from all PSD 

 sources within 200 kilometers of the Class I areas. 



A muzzle is placed on the Park Service PSD efforts in 1992 



In 1992, it became apparent that the Secretary of Interior's 

 office had placed a tight muzzle on the Park Service's efforts to 

 protect Shenandoah and the Great Smoky Mountains National Park. 



Until April 1992, the Park Service had either submitted 

 extensive comments or negotiated an offset agreement on each of 

 the power plant permits that had come up for public comment in 



