EPA declares area around Ameren’s Labadie coal plant in nonattainment

The U.S. Environmental Protection Agency told the state of Missouri in a Feb. 16 letter that the area around the coal-fired Labadie plant of Ameren Missouri is in nonattainment for the SO2 NAAQS, but that the area for the Sikeston coal plant is in attainment.

Under section 107(d) of the Clean Air Act (CAA), EPA must designate areas as either “unclassifiable,” “attainment,” or “nonattainment” for the 2010 one-hour sulfur dioxide (SO2) primary national ambient air quality standard (NAAQS). The CAA defines a nonattainment area as one that does not meet the NAAQS or that contributes to a violation in a nearby area. An attainment area is defined as any area other than a nonattainment area that meets the NAAQS. Unclassifiable areas are defined as those that cannot be classified on the basis of available information as meeting or not meeting the NAAQS.

July 2 of this year is the deadline for the EPA to designate certain areas established by the U.S. District Court for the Northern District of California in a lawsuit brought by environmental groups. This deadline is the first of three deadlines established by the court for the EPA to complete area designations for the 2010 SO2 NAAQS. EPA on Feb. 16 sent letters to various states with affected areas, including Missouri, about its preliminary decisions ahead of this deadline.

This deadline applies to certain areas in Missouri because three emission sources, all coal-fired, meet the conditions of the court’s order. Missouri submitted updated recommendations in September 2015.

EPA said that after careful evaluation of the state’s recommendation and supporting information, as well as all available relevant information, it intends to designate the area around Ameren’s Labadie Energy Center as nonattainment for the 2010 SO2 NAAQS. This nonattainment designation is based on an analysis of modeling provided by the state of Missouri, an analysis of the Sierra Club’s modeling, and an analysis of Ameren’s modeling using regulatory defaults.

The Franklin County area contains a stationary source that according to the EPA’s Air Markets Database emitted in 2012 either more than 16,000 tons of SO2 or more than 2,600 tons of SO2 and had an annual average emission rate of at least 0.45 pounds of SO2 per one million British thermal units (lbs SO2/mmBTU). Specifically, in 2012, the Ameren Labadie Energy Center emitted 42,236 tons of SO2 and had a facility-wide emissions rate of 0.571 lbs SO2/mmBTU. As of March 2, 2015, this stationary source had not met the specific requirements for being “announced for retirement,” which would exempt it from this process.

In its submission, Missouri recommended that the area surrounding the Ameren Labadie Energy Center (Labadie) be designated as unclassifiable based on varying modeling results from its own modeling, Ameren’s modeling, and Sierra Club’s modeling. The Missouri Department of Natural Resources assessment included characterization of air quality from the facility and other nearby sources which may have a potential impact in the area of analysis where maximum concentrations of SO2 are expected along with an evaluation of historic and recent monitoring around the facility.

The Ameren Labadie Energy Center is located in the eastern portion of Missouri in the northern portion of Franklin County. EPA intends to designate the area around Labadie Energy Center as nonattainment with the nonattainment area based on an initial proposed boundary by the MDNR.

Two other areas of the state with coal plants in them were also covered by EPA:

Jackson County, Missouri (Sibley) Area

Said EPA: “After careful evaluation of the state’s recommendation and supporting information, as well as all available relevant information, the EPA intends to designate the area around Sibley Generating Station as unclassifiable for the 2010 SO2 NAAQS. … This designation is based on an evaluation of the MDNR modeling submitted in support of an attainment recommendation with additional consideration of Sierra Club’s modeling that also supported the MDNR conclusion around the Sibley Generating Station but not elsewhere.

In 2012, the Sibley Generating Station emitted 6,095 tons of SO2 and had a facility wide emissions rate of 0.550 lbs SO2/mmBTU. As of March 2, 2015, this stationary source had not met the specific requirements for being “announced for retirement.” The plant is controlled by KCP&L Greater Missouri Operations Co.

In its submission, Missouri recommended that the area surrounding the Sibley Generating Station, specifically a portion of Jackson County, be designated as attainment based on an assessment and characterization of air quality from the facility and other nearby sources which may have a potential impact in the area of analysis where maximum concentrations of SO2 are expected. Said EPA: “After careful review of the state’s assessment, supporting documentation, and all available data, the EPA does not agree with the state’s recommendation for the area and intends to designate the area as unclassifiable.”

The Sibley Generating Station is located in western Missouri in the eastern portion of Jackson County. Some other power plants are in the region, were considered, but are not part of the EPA finding. For Sibley, BPU Nearman, BPU Quindaro, and KCPL Hawthorn, the state used actual hourly emissions from the most recent three-year data set, i.e., 2012–2014.

EPA noted that the Blue Valley Station has three coal-fired boilers and is required, in Missouri Rule 10 CSR 10-6.261, to switch to natural gas by Jan. 1, 2017. In addition, Blue Valley is subject to the boiler MACT and has indicated to Missouri it will switch to natural gas by Jan. 21, 2016, well ahead of the July 2, 2016 designation date, therefore emissions reflecting natural gas were modeled. Blue Valley has stated it intends to complete the fuel switch before July 2, 2016, but this requirement is not contained in a federally enforceable document, thus EPA is not accepting the MDNR attainment modeling that relies upon this fuel switch assumption.

EPA also pointed out that the Missouri City Station ceased burning coal in 2013 and intends to shut down in 2016 and was not included in the state’s modeling although it did emit SO2 in 2012 and 2013 and does not have a federally enforceable requirement to shut down.

Both the Blue Valley and Missouri City plants are under Independence Power and Light.

Scott County, Missouri (Sikeston) Area

Said EPA: “After careful evaluation of the state’s recommendation and supporting information, as well as all available relevant information, the EPA intends to designate the area around Sikeston Power Station as unclassifiable/attainment for the 2010 SO2 NAAQS.”

In 2012, the Sikeston Power Station emitted 5,242 tons of SO2 and had a facility wide emissions rate of 0.620 lbs SO2/mmBTU. As of March 2, 2015, this stationary source had not met the specific requirements for being “announced for retirement.”

In its submission, Missouri recommended that the area surrounding the Sikeston Power Station, specifically the entirety of Scott County, be designated as attainment. EPA agrees that the area is attaining the standard, and intends to designate Scott County as unclassifiable/attainment.

The 235-MW Sikeston Power Station is located in eastern Missouri in the southern portion of Scott County and is controlled by the Sikeston Board of Municipal Utilities.

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.