Name: Ronald E. Suess
Address: 1275 4th Street, No. 165
Santa Rosa, CA 95404
Telephone: (707) 541-0976

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Comment: This EIR should include a statement that acknowledges California will establish a hydrogen sulfide (H2S) noncancer chronic reference exposure level (REL). The State believes H2S poses a health risk to the public. The State has proposed 0.7 ppb (0.9 mg/m3) as the H2S inhalation REL. This directly effects PG&Eís Geysers Power Plant.

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The effects can impact in two key ways. One, the establishment of the REL follows Air Toxics "Hot Spots" Assessment Guidelines. Such a low REL, 0.7 ppb, can trigger very detailed and costly health risk assessments for the Power Plant as per "Hot Spots" requirements. The cost of such assessments could adversely effect the Plantís ability to compete in the deregulated electric generating industry.

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Two, the proposed REL could substantially increase H2S abatement costs. Californiaís ambient air quality standard is 0.03 ppm. It is based on threshold odor detection by humans. This standard plays a critical role on the mass emissions limits of H2S from the Power Plant. The relationship between the mass emissions limits and the REL could necessitate changes in those limits. Hence, modifications to equipment and operations coupled with increases in abatement chemical consumption costs imperil the Power Plantís competitive position.

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I believe it is imperative to address the REL issueís impact on the Geyser Power Plantís portion of the EIR.

Ronald E. Suess, J.D.


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