Groups push for tighter SO2 limits at Crystal River, Lansing Smith

The Sierra Club and Earthjustice said June 13 that they have asked the state of Florida to significantly strengthen its NAAQS plan to address SO2 coming from the Lansing Smith coal units of Gulf Power and two Crystal River coal units owned by Duke Energy (NYSE: DUK).

Gulf Power is a subsidiary of Southern Co. (NYSE: SO). Lansing Smith has two coal units, while Crystal River has two older coal units (Units 1 and 2) with lesser air controls, and two newer coal units (Units 4 and 5) with relatively new air controls, including SO2 scrubbers. Gulf Power filed a June 10 request with the Florida Department of Environmental Protection (FDEP) to test various sorbents at Lansing Smith as part of a plan under the regional haze and Mercury and Air Toxics Standards (MATS) to control SO2 and other emissions from the plant’s coal units.

Currently, the Florida Department of Environmental Protection’s (FDEP) plan does not meet requirements to limit SO2 pollution and protect Floridians’ health, the groups said. Failing to design a plan that meets the standards of the Clean Air Act could trigger costly lawsuits or the need for the U.S. Environmental Protection Agency to step in and ensure Florida residents are being protected from harmful pollution, they added.

Said Rudy Scheffer, vice chairman of Sierra Club Florida: “It’s unacceptable for the state to finalize a plan that ignores the facts and takes no real steps to reduce the toxic pollution that is so harmful to Floridians. We’re stepping in now to tell the state of Florida: don’t pass the buck on clean air.”

More than 1,700 Sierra Club members and supporters signed an online action alert asking the FDEP to significantly strengthen its proposed SO2 plan before putting it into effect. The state has recently finalized a separate but related set of air pollution standards that will result in some reductions of SO2, but these improvements will not take effect for several years, and do not guarantee safe air quality, leaving tourists and Florida’s most vulnerable residents at risk of serious illness, the groups said.

Groups claim existing regional haze limits for these units not enough

The comments were submitted under Florida’s proposed Infrastructure State Implementation Plan (SIP) addressing the requirements for the 2010 Sulfur Dioxide National Ambient Air Quality Standards (NAAQS). “We are very concerned that Florida’s SIP submission does not include concrete measures to control SO2 pollution from two massive coal power plants which can and have caused unsafe air quality over the Crystal River and the Panama City Beach regions,” said the filing with the FDEP.

“Now, it is true that both plants have taken new SO2 permit limits last year in response to Florida’s regional haze compliance obligations,” the filing added. “But there remains a significant question as to whether they will be fully implemented, and in what form. Moreover, the 30-day rolling averaging time prevents them from ensuring compliance with the NAAQS, even if they are fully implemented.”

Duke for its Crystal River plant has agreed that it will either discontinue the use of its uncontrolled Units 1 and 2 as coal-fired units by 2020, or install a dry flue gas desulfurization (DFGD) system that achieves 95% S02 removal efficiency or an emission rate of 0.15 lb/mmBtu either by Jan. 1, 2018, or within five years of EPA’s approval of Florida’s haze plan, whichever is later, the environmental groups said. “However, option 1 would not do so until 2020,” they added. “And option 2 would not do so until five years after EPA’s approval of Florida’s haze plan, which has not yet occurred (so at least not until June 2018). Until that time, illegal and unhealthful air quality will continue to be allowed by Crystal River Plant’s permit. Moreover, because even the 0.15 lb/mmBtu limit is to be achieved on a ‘30-day rolling average,’ new limit cannot guarantee compliance with the one-hour NAAQS. FDEP should require a one-hour averaging time to ensure compliance with the NAAQS. EPA has agreed that a one-hour averaging period should be implemented to protect the 2010 S02 NAAQS from emissions from a particular source.”

The groups added in the June 12 comments: “Lansing Plant, meanwhile, has received an emissions limit of 0.74 lb/mmBtu in a haze-related permit, again on a rolling 30-day average. This limit is not effective until EPA approves it as part of Florida’s haze plan, and compliance is not required until March 2016. Once again, the permit countenances illegal air quality violations for at least three more years, and the 30-day averaging time in the permit cannot assure compliance with the one-hour NAAQS.”

In short, the groups added, FDEP has made some progress, prompted by the regional haze rule, but neither existing permit limits nor those which may be imposed by the final regional haze SIP assure NAAQS compliance.

Duke may shut Crystal River Units 1 and 2 in the near term

Notable is that Duke is leaning toward the shutdown option for Crystal River Units 1 and 2. In April 1 testimony filed at the Florida Public Service Commission, Benjamin Borsch, employed by the Integrated Resource Planning and Analytics Department of Progress Energy Florida as Director of Integrated Resource Planning and Analytics for Florida, said the company has decided to retire, not retrofit, these units. The coal-fired Units 4-5 at Crystal River are newer, bigger and have gotten emissions retrofits in recent years that will keep them running for the long term. The nuclear Unit 3 is shut and about to be permanently retired.

“PEF cannot continue to operate the Crystal River Units 1 and 2 without implementation of additional measures to bring the units into compliance with MATS,” Borsch noted. “Accordingly, the two main options that PEF considered were: (1) installing new emission control systems to reduce NOx, SO2 and mercury emissions; and (2) retiring the units and replacing the generation.”

To determine the most cost-effective compliance option for CR 1 and 2, PEF conducted a lifecycle cost analysis of all costs associated with both options. PEF focused on the comparative economics of a scenario in which Crystal River Units 1 and 2 continue to operate through 2041, equipped with significant life extension upgrades, state of the art emission control systems and a long term supply of low cost coal, versus a scenario where the units are retired in 2016.

PEF has decided that installing emission controls at Crystal River Units 1 and 2 is not the most cost-effective option to achieve MATS compliance. PEF is evaluating alternative fuel options that would allow Crystal River Units 1 and 2 to continue operating in compliance with MATS for a limited period of time. PEF plans to schedule and obtain permits for operational tests in 2013 to determine how the units perform with unnamed, alternative coals. If these tests are successful, it may be possible for PEF to extend Crystal River Units 1 and 2 operations to the 2018-2020 timeframe while still being in compliance with MATS.

MATS first takes effect in April 2015, with two one-year extensions of that deadline possible under certain circumstances.

About Barry Cassell 20414 Articles
Barry Cassell is Chief Analyst for GenerationHub covering coal and emission controls issues, projects and policy. He has covered the coal and power generation industry for more than 24 years, beginning in November 2011 at GenerationHub and prior to that as editor of SNL Energy’s Coal Report. He was formerly with Coal Outlook for 15 years as the publication’s editor and contributing writer, and prior to that he was editor of Coal & Synfuels Technology and associate editor of The Energy Report. He has a bachelor’s degree from Central Michigan University.