Despite the fact that Tenaska has said it plans to shelve the coal gasification part of its Taylorville Energy Center power project in Illinois, the Natural Resources Defense Council and the Sierra Club on May 30 appealed the project’s recently-issued air permit.
The Illinois Environmental Protection Agency had issued the permit on April 30 just before project developer Tenaska said it would shelve the coal gasification part of the project in favor of just firing the plant with regular natural gas, at least in the plant’s early years. The NRDC and Sierra Club filed their petition for review of the Prevention of Significant Deterioration (PSD) permit at the Environmental Appeals Board of the U.S. Environmental Protection Agency.
The state-issued permit authorizes Tenaska affiliate Christian County Generation to construct the Taylorville Energy Center, a coal-derived synthetic natural gas (SNG) facility and an associated power block in Taylorville, Ill. “Petitioners contend that IEPA’s best available control technology (‘BACT’) determination for the facility was clearly erroneous as a matter of law in violation of the Clean Air Act (‘CAA’), and additionally raises important policy considerations that the Board should review, in four major respects,” said the appeal.
- First, IEPA dismissed out of hand the feasibility of carbon capture and sequestration (CCS) technology in Step 2 of its BACT determination based on “general and unsubstantiated assertions of uncertainty,” without any genuine attempt at site specific feasibility analysis, and without regard to extensive site-specific analysis previously performed by the applicant concluding that CCS is feasible, the environmental groups said. In so doing, IEPA failed to follow BACT’s case-by-case statutory requirements, as well as U.S. EPA guidance requiring a full site specific inquiry into the feasibility of CCS for large-scale projects like TEC.
- Second, IEPA dismissed cleaner low-sulfur western coal as a basis for BACT based on an Illinois statute effectively granting a subsidy for facilities using high-sulfur Illinois coal, thereby unlawfully circumventing federal BACT requirements concerning consideration of clean fuels based on state law, in contravention of the Supremacy Clause, the appeal said.
- Third, IEPA rejected available and feasible controls for leaking components currently in widespread use – leakless component technology and leak detection and repair programs – based on arbitrary and deficient cost effectiveness analysis, the appeal added.
- Fourth, IEPA’s modeling analysis was “fundamentally arbitrary and capricious” because IEPA failed to conduct ozone modeling and, instead, relied on the Scheffe Tables to estimate ozone emissions even though EPA has denounced that method, the groups said.
On June 4, the board sent a letter to the parties offering them the option of taking this into the board’s pilot alternative dispute resolution process, with a June 18 deadline to accept or reject that option.
Tenaska still has coal gasification in long-term plan
Under its revised “Power Block First” proposal for the Taylorville Energy Center, Tenaska said May 16 that Illinois electricity customers could save an estimated $437.7m over a 20-year period, including more than $250.6m in the plant’s first five years of operation. Opponents of the project, including Commonwealth Edison parent Exelon (NYSE: EXC), have claimed that power from the plant would be too expensive over time.
The revised proposal would authorize construction of the initial stage of the project, an efficient 611-MW, natural gas-fueled combined-cycle plant that would be equipped to accept SNG in the future. This first phase of the project provides additional generating capacity at a time when the market is most in need because of coal plant closures, said Tenaska.
“The ‘Power Block First’ plan allows Illinois to take advantage of today’s low natural gas prices to build a necessary new source of electric power resulting in lower overall rates,” said Tenaska Vice President Bart Ford in the May 16 statement. “In the future, when economics favor the use of Illinois coal, equipment can be added to convert coal to clean SNG, capture carbon dioxide and provide for geologic storage.”