The U.S. Environmental Protection Agency Administrator signed a Jan. 23 order denying in part three petitions asking the EPA to object to operating permits issued by the Texas Commission on Environmental Quality (TCEQ) to Luminant Generating Co. LLC relating to three coal-fired steam electric generating stations (SES) located in East and Northeast Texas.
EPA will publish a notice of this final action in the Feb. 23 Federal Register.
Title V operating permit number O53 was issued by the TCEQ for the Martin Lake SES located in Rusk County, Texas. Title V operating permit number O64 was issued for the Monticello SES located in Titus County, Texas, while title V operating permit number O65 was issued for the Big Brown SES located in Freestone County, Texas.
The EPA’s Jan. 23 order responds to the three petitions submitted in early 2014 by the Environmental Integrity Project (EIP) representing themselves and on behalf of Sierra Club. The Sierra Club withdrew all of its objections prior to the issuance of the order. The EIP requested that the Administrator object to the proposed operating permits issued by the TCEQ to Luminant on several bases. The three petitions did not raise identical claims; however, three common claims are addressed in the issued order. The remaining issues are to be withdrawn by the petitioner in accordance with a settlement agreement reached on Jan. 22 between the petitioner and the EPA.
The issues raised are that: the Compliance Assurance Monitoring (CAM) provisions in the Martin Lake, Monticello and Big Brown permits do not assure compliance with the applicable particulate matter (PM) emission limit during periods of startup, shutdown, maintenance and malfunction; the record supporting the CAM opacity indicator ranges for PM for Monticello Units 1, 2 and 3 is deficient and not based on reliable data; and the Big Brown permit must be revised to ensure that any credible evidence may be used to demonstrate noncompliance with applicable requirements.
On the CAM provisions, EPA Administrator Gina McCarthy ruled about the comment period leading up to the TCEQ’s permit decisions: “This issue was not raised with reasonable specificity during the public comment period, as required by [the Clean Air Act]. In addition, the Petitioner has not demonstrated that it was impracticable to raise such objections during the comment period, and there is no basis for finding that grounds for such objection did not arise until after the comment period.”
A similar reason about prior comment was offered in rejecting the Monticello-specific claims. McCarthy also said at one point: “Because the Petitioner has not demonstrated that information is missing from the record or that the omission of any infortnation may have resulted in a deficiency in the Proposed Monticello Permit, the EPA denies the Petitioner’s request that we object to the Permit on this basis.”
Martin Lake consists of three boiler units with 2,340 MW of total capacity. The flue gas from each unit is routed through an electrostatic precipitator (ESP) to remove fly ash which is routed to storage silos equipped with fabric filer baghouses. The flue gas from the ESP is routed to a flue gas desulfurization (FGD) system to remove sulfur dioxide from the flue gas.
Big Brown consists of two boiler units with 1,150 MW total capacity. Each unit utilizes an ESP and pulse jet baghouses for emission control.
Monticello consists of three boiler units with 1,900 MW total capacity. Two of the boilers are capable of generating approximately 575 MW (net), while the third boiler is capable of 750 MW (net). Units 1 and 2 use ESP and fabric filter baghouses to control emissions of fly ash, while Unit 3 has a FGD system to remove sulfur dioxide from the flue gas and an ESP for fly ash control.