Several environmental groups filed comments Nov. 30 with the Tennessee Valley Authority that said plans to install new emissions control equipment on the 53-year-old Gallatin coal plant are a bad idea, and that other avenues, like energy efficiency, would be more productive.
Rather than retire and replace Gallatin, a significant source of air and water pollution, TVA is planning to spend $1.2bn on pollution controls in order to continue operating it, said the Southern Environmental Law Center in a Dec. 3 public statement. In comments filed on Nov. 30 in response to a draft environmental assessment for the Gallatin retrofit project, five groups, including the center, said TVA has failed to appropriately consider other options and to disclose information about the proposed upgrades to the public.
“As a federal agency, TVA is legally required to analyze the environmental consequences of its proposed actions and consider reasonable alternatives,” said Nathan Moore, attorney with the Southern Environmental Law Center. “In this case, it’s clear that retiring Gallatin would be a more cost effective alternative and it would be better for the environment.”
Energy efficiency and renewable options, as well as natural gas generation, could more than offset the electricity provided by Gallatin, at a lower price than the proposed retrofit project, the groups claimed. These alternatives would also produce far less environmental and health impacts than continuing to operate the plant. Even with the proposed upgrades, Gallatin would continue to emit significant amounts of CO2, SO2 and mercury, the groups said.
“If TVA has its way, ratepayers will foot the bill for an outrageously expensive plan that locks Tennessee into an outdated and destructive energy system for decades to come,” said Louise Gorenflo, lead volunteer with Sierra Club’s Beyond Coal campaign in Tennessee.“At a time when other major electricity providers are moving into the future with cleaner, more efficient options, TVA is taking a major step backwards by doubling down on a plant over 50 years old.”
While the upgrades would reduce Gallatin’s air pollution enough to meet federal requirements, it would do so by producing new and larger coal combustion waste streams, the groups said. New landfills spanning 90 acres would be built to contain up to 6 million cubic tons of coal ash waste.
The five groups—Earthjustice, Environmental Integrity Project, Sierra Club, Southern Alliance for Clean Energy, and Southern Environmental Law Center— detail numerous concerns about the project in their comments:
- Continued operation of Gallatin would produce millions of tons of air pollutants and water pollutants that flow into the Cumberland River, as well as two to four times more coal combustion waste than it currently produces.
- In order to satisfy legal requirements under the National Environmental Protection Act, TVA must consider alternative approaches including retiring Gallatin—or a subset of its four coal units—and replacing it with energy efficiency resources, power from renewable energy sources, or natural gas generation.
- Given the controversial nature of the proposal and its significant impacts, TVA is legally required to follow a public process that discloses relevant information to the public. Yet TVA has failed to provide its evaluation of an energy efficiency study it commissioned, comparisons of the cost of this proposal with other options, and projections of impacts to ratepayers’ bills, the groups claimed.
Groups say a project this big and controversial needs an EIS
The Nov. 30 comments filed with TVA argue that a full-fledged environmental impact statement (EIS), not just an environmental assessment (EA), should cover a project this large. “Proposed actions will be considered ‘significant’ – and thus require an EIS – if they are ‘highly controversial’ or jeopardize threatened and endangered species,” the comments added. “Although either is sufficient, the proposed Gallatin retrofits are significant in both of these respects. Alternatively, TVA must prepare an EIS for the proposed action because Gallatin is a ‘major power generating facility’ and the decision to be made is whether to retire or continue operating this major power generating facility with retrofits. For all of these reasons, TVA cannot issue a record of decision (ROD) without first completing the EIS process.”
The draft EA itself is flawed in three important respects, and cannot be offered as a substitute for an EIS, the groups said.
- First, the draft EA impermissibly segments the project by failing to consider the environmental consequences of wet-to-dry ash conversion, closing the Cumberland River Aquatic Center (CRAC) and switching to a more polluting fuel source, they claimed.
- Second, the draft EA relies on an unlawful “no action” alternative. Under NEPA, “no action” means either the continuation of an agency’s established plans or taking no action, the groups said. In the draft EA for Gallatin, TVA framed its “no action” alternative in terms of operating all units at Gallatin with no additional controls. “But this would be illegal and inconsistent with TVA’s own established management decisions,” they said. “In 2011, TVA voluntarily entered into a legally binding agreement to cease operating Gallatin unless it installed retrofits or repowered the facility with biomass. Because TVA made a conscious management decision not to—and cannot legally—operate Gallatin as an uncontrolled coal plant after 2017, it cannot now choose continuing to operate the plant without additional controls as the baseline against which other alternatives are assessed.”
- Third, the draft EA considers an unreasonably narrow range of alternatives, the groups added. “In fact, the two purported alternatives that the Draft EA analyzes (other than TVA’s purported no action alternative – which is illegal and therefore unreasonable) really consist of one alternative (installing the same pollution controls) in two different locations,” they added. “As a result, TVA proposes to select a highly expensive and highly polluting option without even acknowledging that other, less expensive and less polluting alternatives exist, or weighing the impacts of retrofitting against less harmful alternatives. TVA cannot summarily dismiss from further consideration reasonable alternatives such as retiring the plant; replacement with energy efficiency or demand side management; replacement with natural gas; retirement of only some Gallatin units; replacement with power purchases; and alternative pollution control technology.”
TVA has also lately been battling the Sierra Club in federal court about the club’s Freedom of Information Act requests for documents related to the Gallatin projects.
Planned Gallatin retrofits include FGD and SCR
TVA, which is shutting a number of coal units due to clean air needs, is looking at installing new flue gas desulfurization (FGD), selective catalytic reduction (SCR) and activated carbon injection (ACI) systems at Gallatin, located in Sumner County, Tenn. These projects are needed in order to meet the new Mercury and Air Toxics Standards (MATS) and to comply with the April 2011 Federal Facilities Compliance Agreement (FFCA) between the U. S. Environmental Protection Agency and TVA.
Gallatin would get a dry FGD system to control SO2, SCR for NOX emissions and ACI integrated with the dry FGD to reduce mercury emissions. It would also get a pulse jet fabric filter (baghouses or PJFF) to control particulate matter (PM) emissions.
Additional facilities required to support TVA’s proposed action include a new on-site dry coal combustion product (CCP) landfill; electrical transmission lines, transformer yard, and switchyard upgrades; and ancillary facilities such as on-site haul roads. TVA’s plans for closure of surface impoundments to support wet-to-dry conversion plans specific to GAF are not included in the scope of the draft EA. TVA has been forced to phase out wet coal ash storage after the notorious failure in December 2008 of a dam at a wet storage facility at its coal-fired Kingston power plant in Tennesee.
Gallatin has four coal-fired units and combusts an average of 12,350 tons of coal per day. Units 1 and 2 each have nameplate ratings of 300 MW, and Units 3 and 4 each have nameplate ratings of 327.6 MW.
TVA has installed electrostatic precipitators (ESPs) at Gallatin to reduce PM emissions and low-NOX burners to reduce NOX. TVA also burns a low-sulfur blend coal, primarily from the Powder River Basin, to reduce SO2.