The Natural Resources Defense Council, Prairie Rivers Network and the Sierra Club have appealed a new water permit for Dynegy Midwest Generation’s coal-fired Havana power plant, claiming that the Illinois Environmental Protection Agency (IEPA) failed to take into account waste from new air emissions controls on the plant.
The appeal, filed Oct. 18 at the Illinois Pollution Control Board, contests a National Pollutant Discharge Elimination System (NPDES) permit issued Sept. 14 for the discharge of pollutants from one of the plant’s coal ash ponds into the Illinois River. The Illinois River is currently listed as impaired for fish consumption uses due to high levels of mercury on the Illinois Integrated Water Quality Report and Illinois Section 303(d) List, the appeal noted.
“Outfall 005 at the Facility discharges to the Illinois River from the East Ash Pond,” the appeal said. “Subsequent to its submittal of a NPDES permit renewal application in October 2006, Dynegy supplemented its application in 2007 with requests, inter alia, to increase the discharge of waste to the East Ash Pond in connection with new air pollution control equipment it planned to install. This new equipment included, inter alia, a spray dryer absorber (‘SDA’) scrubber system, which would generate an estimated stream of 25,000 tons of residue annually; and an activated carbon injection (‘ACI’) system, which would generate an estimated stream of up to 2.6 tons of activated carbon per day, including up to .6 pounds of mercury per day.”
In July 2010, Dynegy submitted antidegradation analysis to IEPA for increased discharges associated with the SDA and ACI, the appeal said. “With respect to mercury from the ACI waste, the antidegradation analysis relied solely on a study by the Electric Power Research Institute (‘EPRI’), an organization representing industry, which had concluded that such was ‘unlikely’ to be discharged at ‘levels of environmental concern.’ Dynegy did not submit, and IEPA did not perform, analysis to determine the best available technology (‘BAT’) for control of either SDA or ACI waste streams.”
Comments the environmental groups made to IEPA during the NPDES permitting process cited U.S. EPA analysis concluding that coal combustion waste impoundments (such as the East Ash Pond) are not the most effective alternative for addressing pollution control equipment residue, and are not likely to represent BAT for scrubber wastewater. Among these was a 2010 memorandum from James Hanlon of the U.S. EPA Office of Water, which described alternative control technologies assessed to be more effective at removing metals from air pollution control wastewater, the appeal noted.
Dynegy Midwest Generation is a unit of Dynegy (NYSE: DYN). Havana has one operating coal unit, Unit 6, with 441 MW of capacity.
Dynegy Midwest installs air controls on more than Havana
Dynegy Midwest Generation (DMG) applied June 8 at the Illinois board for a variance from the Illinois Multi-Pollutant Standard that would last from the time of any final board approval order, whenever that is, until April 1, 2015. This variance would be applicable to vintage 2013 and 2014 SO2 allowances allocated by the U.S. Environmental Protection Agency or the IEPA under the Cross-State Air Pollution Rule (CSAPR).
Dynegy Midwest wants a variance from the MPS requirement that prohibits owners or operators of electricity generating units (EGUs) in an MPS Group from selling or trading to or otherwise exchanging with any person SO2 allowances allocated to EGUs starting with vintage year 2013 that would otherwise be available for sale or trade as a result of actions taken to comply with the SO2 standards under the MPS. The MPS requires that, in 2013 and 2014, EGUs in an MPS Group comply with an overall SO2 annual emission rate of 0.33 lbs/mmBtu or a rate equivalent to 44% of the base rate of SO2 emissions, whichever is more stringent. Also, Dynegy Midwest is requesting a variance from the companion requirement that it surrender such excess SO2 allowances to the Illinois EPA.
Dynegy Midwest currently owns and operates four coal plants in Illinois: Baldwin in Randolph County, Havana in Mason County, Hennepin in Putnam County, and Wood River in Madison County. In November 2011, DMG permanently retired a fifth coal plant, Vermilion in Vermilion County.
The principal emissions at these coal-fired power plants are SO2. DMG generally controls SO2 emissions through the use of low-sulfur coal from the Powder River Basin with a sulfur content less than 0.3%. DMG said it did not expect to use any different type of coal during the proposed variance period, nor will the variance change the hourly rate of PRB coal use. In addition, to control SO2 emissions further, DMG has installed and is operating spray dryer absorbers (i.e., dry scrubbers) with fabric filter (i.e., baghouse) systems on two Baldwin units. DMG also is constructing a dry scrubber and fabric filter system on the third Baldwin unit (Unit 2), which will be operational by Dec. 31, 2012, and has installed a dry scrubber on Havana Unit 6, which also will be operational by Dec. 31, 2012.