Citizens for Clean Energy, Inc.

615 Third Avenue North

Great Falls, MT 59401

Website: http://www.cce-mt.org/

Email: cce-mt.bresnan.org

3/18/07

Mr. Richard Fristik

USDA Rural Development Program, Utilities Programs

1400 Independence Avenue, SW

Mail Stop 1571, Room 2237

Washington, D.C. 2025011571

Dear Mr. Fristik:

It is quite ironic that the city of Great Falls officials and SME have been saying that IGCC plants are neither feasible nor economical to build at this time. On March 6, 2007 Montgomery Energy Partners out of Texas announced its plans to build an IGCC facility just outside of the city of Great Falls. Click for story link Several other IGCC facilities are currently in construction or planning stages in the country. Our own governor advocates IGCC only for coal usage in the state of Montana. SME’s outdated CFB plant is not needed in this state. Montana is presently a net exporter of power and will be even more so when several planned wind farm projects come on line in the next two years.

When the first natural gas combined cycle phase of the plant referenced above comes on line in the next eighteen months or so they will be capable of satisfying all our power needs for many years to come. Also, they will be first on line in this area and therefore will use the capacity in Northwestern Energy’s local transmission facilities and lines leaving little or no room for the SME HGS station four or five years down the road.

The following are my considered discrepancies found in the FEIS concerning the sanitary wastewater systems, potable water systems, the ash monofill repositories, and our local water fisheries and habitat.

The FEIS states:

Low-volume wastes from coal combustion would be generally aqueous and include boiler blow down waste, cooler blow down waste, coal pile runoff waste, demineralizer regenerant, and boiler chemical cleaning wastes. Water would comprise a substantial portion of these wastes.

The characteristics of low-volume wastes are extremely variable and can contain various

hazardous materials such as strong acids or bases, cadmium, chromium, lead, mercury, and silver (EPA, 2000). Unless properly managed, these wastes have the potential to oxidize and generate acids that could contaminate nearby water resources. The boiler blow down wastes and cooling tower blow down waste (both liquid wastes) would be discharged into the waste water stream which would be pumped to the City of Great Falls wastewater treatment facility. As noted above, the demineralizer regenerate waste would be used to reduce dusting by utilizing the slurry material in the bed ash and fly ash pug mills when loading the ash haul trucks. Finally, the boiler chemical cleaning waste would be captured in special containers to be tested for metal content. The level of metal concentration would determine the disposal method. If allowable, the slurry would be admitted into the wastewater stream and discharged to the City of Great Falls wastewater treatment facility. A dedicated, zero outflow evaporation

The preferred option at present is to discharge wastewater back to the City of Great Falls for disposal at its existing wastewater treatment facility. The wastewater would be transported via a 12” newly constructed sanitary force main that would run from the project site to a point near Malmstrom Air Force Base where the line would intersect an existing waste water line owned by the City of Great Falls. The length of the pipeline and main improvements would be approximately 53,000 feet (16,160 m). SME would need to obtain a permit from the City and meet pre-treatment effluent standards. Up to 811 gal/minute of wastewater would be discharged and would consist of concentrated river water and trace amounts of cooling tower water and boiler water treatment chemicals (Pg 2-75)

My reply:

• This report assumes some level of discharge standards must be met by HGS? The discharge standards are not stated nor is the methodology to achieve these standards addressed in this environment impact report? What form(s) of pre-treatment will be used? There will be more than just domestic sewage to deal with from this facility. Nothing in this FEIS spells out how the industrial wastes will be treated and/or monitored prior to mixing and discharge with the sanitary domestic flows from the plant. Further, the city wastewater treatment plant is presently operating with, a two year old, out of date discharge permit from the Montana DEQ. How can the city issue a sewer discharge permit for HGS when they have no idea what future standards will be forth coming from the DEQ. It is quite likely, since no discharge parameters are spelled out here, that industrial discharges from the HGS facility could cause the city to be in violation of present and future discharges from its treatment plant.

• ‘The current Great Falls DEQ sewage discharge permit is two years delinquent and out of date. In the future Great Falls STP discharge permit will be modernized, by the DEQ, to protect downstream users. At that point only, will Great Falls be able to issue a responsible permit for the HGS that encompasses all the necessary protections for all concerned. If Great Falls intends to issue such a permit before DEQ upgrades the present permit, they will be remiss in their duties and put Great Falls at risk for major penalties and legal actions. How can one write a local discharge permit without knowing what regulations the DEQ may impose on the Great Falls STP’?

The FEIS states:

A pipeline would be constructed to supply potable water to the site from the City of Great

Falls. This pipeline, constructed of 6” ductile iron or HDPE, would follow the same routing as the discharge pipe, but would be located a minimum of 10 feet (3 m) to the side. This water supply pipeline would be buried at a depth of 7 feet (2.1 m). (Pg 4-20)

My reply:

• There is no stated provision for backflow protections on the potable water line interconnect in this report. For an industrial connection of this magnitude an approved and regularly certified and tested "Air Gap or similar mechanical device (reduced pressure principle device)"MUST be provided. There is no stated “in house” backflow protection for the potable water system separation from the industrial raw water systems.

• These are major health and environmental oversights particularly as concerns the domestic interconnection to the city municipal water supply.

The FEIS states:

SME has voluntarily agreed to construct recompacted clay liners in the waste management cells and to monitor the underlying aquifer as part of an ongoing demonstration.

My reply:

• There is no stated written procedure in this report that spells out the particulars for a monitoring program and to whom and how often documented reports would be delivered for any necessary action(s) taken or may need to be taken.

The FEIS states:

The Pendroy Clay soils found onsite are characterized by very slow water transmission rates and infiltration rates. This material would be recompacted at optimum moisture content to create an engineered clay liner for the cell.

My reply:

• How will continuous (three years of tracked machinery operation per monofill) processes affect crack formation in an engineered clay liner? How about resistance to severe Montana freeze/thaw conditions? What is the engineered clay barrier’s resistance to variations in pH of the ash leachate and to the various leachate salts that may affect the clay barrier? The report has not provided sufficient data indicating what percentages or contents of hazardous chemicals will be in the various ash wastes planned for disposal at the monfills, or what the pH ranges of the ash wastes and the leachates will be, These parameters can have a major affect on the behavior of a clay layer.

The FEIS states:

The monofill would be encircled by a raised perimeter containment berm constructed from onsite fat clays. This berm would ensure that surface waters do not drain into the monofill. Any storm water that fell within the berm would be contained within the monofill, where it would evaporate.

My reply:

• In the eventuality of containment overfill and failure, there are no stated provisions for this eventuality and what environmental affects would occur nor how they would be mitigated and handled.

• Another point is once the plant and site is useless and decommissioned:

There is no stated provision for long-term (forever) monitoring of the toxic site ash monofills.

• There is no long-term (forever) ground water monitoring and protection program provided.

• This must be considered a toxic site essentially forever.

• It will contain thousands of pounds of unknown quantities of radionuclides, heavy metals, and many undocumented toxic compounds.

• Financial and written provisions must be provided for, set aside in a special fund to provide for the above so that the taxpayer is not on the hook to clean up the mess thirty five years from now. We have a tragic legacy surrounding Great Falls from coal mining, silver mining and Anaconda Copper Smelter operations that has left the area with current toxic sites that may never be usable and gave us a not so notable high place on the EPA’s Superfund cleanup program. My generation DOES NOT intend to continue this legacy, by allowing again in our backyard an industrial toxic belching behemoth called a CBF coal-fired generation plant!

• This is a negligent and gross oversight and would probably have been addressed if the EPA had been more diligent and/or involved in drafting this document.

• The most efficient method to deal with these problems is DO NOT BUILD A COAL-FIRED PLANT ANYWHERE.

The FEIS states:

The monofill would operate continuously, as solid waste was produced by the plant. Ash and, if appropriate, filter slurry would be conveyed to the monofill by truck and would be dumped within the active storage cell. On a scheduled basis, tracked machinery would distribute and spread the solid waste. The material would have sufficient moisture to allow workability by tracked equipment. As the ash dries, it would form a hard lightweight cover similar to concrete. In this form, the ash would not be subject to wind erosion. If erosion should occur, an onsite water wagon would be used to moisten the ash and regenerate the hard cover.

My reply:

• The author is not familiar with weather conditions in this part of Montana or is just hoping for the best outcome over the 35 plus year of the plant. Wind erosion will occur and probably under conditions where a water wagon could not operate affectively if at all. This area is known as one of the windiest regions in the US. We can normally have surface winds that are at hurricane force. The monofill berms will not protect erosion from occurring under these conditions. There are no stated provisions for perimeter monitoring and emergency control of hazardous ash and coal dust migrations from the site.

• I would also like to note the absence of any radiological monitoring of stack fly ash, monofill repository ash and coal dust migrations from the site. It is well documented that these materials contain emissions of Uranium, Radon and Thorium. What is the public to think when there are no stated requirements for monitoring of the radionuclides that will be entering into our environment?

The FEIS states:

“Belt Creek is listed as not supporting the beneficial uses of aquatic life, coldwater fishery, and drinking water. Probable causes of the stream impairment include metals, siltation, bank erosion, fish habitat degradation, and other habitat alterations. Probable sources of the impairment are listed as being highway/road/bridge construction, resource extraction, acid mine drainage, channelization, construction, hydromodification, agriculture, and grazing-related sources." Volume 1, pg 3.11, paragraph 3.2.4

My reply:

• Again the author of this document is not familiar with, is just plain deceitful, and/or intends to document through this flawed FEIS that our local adjacent rivers and streams are already so polluted that whatever contaminants the SME –HGS adds to the ecology of the area are not of any consequence. They appear to be establishing a baseline record, through the FEIS, that they hope will stand in future court cases. Our government officials should recognize this and take appropriate action with a revised FEIS.

• Belt Creek is a noted fishery and contains endangered native cutthroat trout. Check out this link from Montana Fish, wildlife & Parks, which states:

• All Species Present:

Brook Trout, Brown Trout, Common Carp, Goldeye, Longnose Dace, Longnose Sucker, Mottled Sculpin, Mountain Sucker, Mountain Whitefish, Rainbow Trout, Sand Shiner, Sauger, Shorthead Redhorse, Stonecat, Westslope Cutthroat Trout, White Sucker, Lake Chub

The FEIS states:

“The Missouri River is listed as not supporting the beneficial uses of aquatic life, coldwater fishery, warm water fishery, and drinking water. Probable causes of the river impairment include PCBs, metals, siltation, turbidity, and thermal modifications. Probable sources of the impairment are listed as being industrial point sources, dam construction, hydromodification, and agriculture.” Volume 1, pg 3.11, paragraph 3.2.4

My reply:

• Again the author of this document is not familiar with, is just plain deceitful, and/or intends to document through this flawed FEIS that our local adjacent rivers and streams are already so polluted that whatever contaminants the SME –HGS adds to the ecology of the area are not of any consequence. They appear to be establishing a baseline record, through the FEIS, that they hope will stand in future court cases. Our government officials should recognize this and take appropriate action with a revised FEIS.

• The Missouri River and in particular the upper Missouri is a nationally noted “blue ribbon” fishery as noted by this quote from Montana Fly Fishers. “As fly fishermen, we tend to think of the Missouri in terms of a phenomenal rainbow trout fishery from where the river leaves Holter Lake and downstream to the town of Cascade.  In this 40-mile stretch of river, anglers are treated to a multitude of fishing possibilities.  The MO supports a staggering 4000 trout per mile population with a majority of the fish being rainbows.  The average size of these fish pushes 16 inches with fish of 20 inches not uncommon.  The river has excellent aquatic bug life making for consistent hatch activity throughout the summer and fall months.  This in turn translates to excellent dry fly fishing opportunities for both the rainbow and brown trout”.

• This area of the Missouri (regardless of what the flawed EIS says) provides for the local drinking water supplies to the cities and towns of Great Falls and Fort Benton. ‘Lets keep it unpolluted please!’ Please revise this severely flawed and misleading FEIS.

• We Montanan’s would be pleased to keep our creeks, rivers, and lakes uncontaminated from the mercury and radionuclides emissions of coal-fired plants such as proposed by SME, for all the public’s healthful usage and enjoyment.

• These local resources draw considerable tourism dollars and jobs to this area. Much more of a long-term benefit than the polluting coal plant could ever be. ‘Let’s preserve what we have here please!’

• I also feel that the DEIS and the current FEIS did not adequately look into alternative energy systems. We have ample wind in this area that is currently being developed by others but was thrown out by SME as not providing base load. They did not attempt to do much study in this area because of the coal mindset. I would like you to look at these websites for starters:

http://www.wapa.gov/es/pubs/esb/2003/03Aug/esb084.htm & http://www.isepa.com/ these kinds of wind storage options were never studied although we have all the natural resources here to accomplish what Iowa is promulgating. Also, hydro pumped storage was never investigated although we again have those resources available in this area. The five local dams on the Missouri river have not been modernized nor upgraded for many years. Did SME and Great Falls ever talk with PPL, the dam owners and operators, to try and work out a deal? The city has leverage in this area as our water rights on the Missouri flows through PPL’s generating facilities and also one of the dams lies within the city limits. At any rate these clean energy alternatives were not fully explored.

• The 160 MGW Judith Gap Wind farm which came on-line early spring of 2006 supplies 8% of Northwest Energy’s peaking load and they sell their power for$ 0.03 per kw. They were producing at capacity 38% of time during 2006. Enough wind farms scattered around the state and you will have base electricity as the wind is blowing somewhere here all the time.

• By the time SME/HGS would come on line, five years down the line, more clean energy alternatives will be on line here in our area and throughout Montana. With the probable CO2 taxation in the near future, coal-fired plants will be forced to put in very expensive capture equipment making their power not competitive with the green energy producers as the tax will not effect them. Can HGS sell their power profitably at $0.03 kw as does Judith Gap as noted above? Can the RUS stray from their mandates and legitimately take this risk with our tax dollars? This plant (HGS) will be a merchant plant!

• The public expects that the government will help to protect our health, and environment(s). We currently have an excess of power in Montana that could be available to SME if they had fully investigated and acted upon this option. This coal-burning plant is not wanted here by the majority of the citizens of our community nor needed here.

• The RUS needs to look closely at their charter, set SME significant pressures aside, and do the right thing.

Thank you for your attention to these important details and I hope you will immediately initiate an FEIS supplemental to address important issues such as strategic missing pages, misleading assumptions, and many other issues that I and others have addressed in this currently incomplete FEIS that appears to have little EPA or proper peer review and oversight other than that of the applicant and its biased consultants.

Sincerely,

Neil J. Taylor