EPA mostly agrees with Michigan on SO2 NAAQS designations impacting coal plants

The U.S. Environmental Protection Agency on Feb. 16 sent to the state of Michigan its preliminary decisions on the SO2 NAAQS attainment status for several areas scattered around the state, with those decisions impacting coal-fired power plants of companies like Consumers Energy and DTE Electric located within those areas.

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.

Michigan submitted updated recommendations to EPA in September 2015, ahead of a July 2, 2016, deadline for EPA to designate certain areas established by the U.S. District Court for the Northern District of California. The court had ruled in a lawsuit brought by environmental groups over EPA failures to make these designations. This July 2 deadline is the first of three deadlines established by the court for EPA to complete area designations for the 2010 SO2 NAAQS. On Feb. 16, EPA sent to the state of Michigan a letter and a supporting technical document outlining its preliminary decisions for several areas within the state.

St. Clair County (DTE Electric plants)

St. Clair County, located in the Detroit area, contains two stationary sources that according to 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 lbs SO2/MMBTU. As of March 2, 2015, these stationary sources had not met the specific requirements for being “announced for retirement,” which would exclude them from the projess.

Specifically, in 2012: DTE Electric’s coal-fired Belle River Power Plant emitted 24,869 tons of SO2, and had an emissions rate of 0.621 lbs SO2/MMBTU; and DTE Electric’s coal-fired St. Clair Power Plant emitted 28,208.476 tons of SO2, and had an emissions rate of 0.935 lbs SO2/MMBTU. Pursuant to the March 2, 2015 court-ordered schedule, EPA must designate the area surrounding these facilities by July 2, 2016.

In its submission, Michigan recommended that the area surrounding the Belle River and St. Clair plants, specifically a defined portion of St. Clair County, be designated as nonattainment. “After careful review of the state’s assessment, supporting documentation, and all available data, EPA agrees with the state’s recommendation for the area, and intends to designate the area as nonattainment,” said EPA’s Feb. 16 technical report.

These two power plants are located next to each other, approximately 6 kilometers southeast of the center of St. Clair along the St. Clair River. 

Bay County (Consumers Energy) 

Bay County contains a stationary source that according to 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 lbs SO2/MMBTU. As of March 2, 2015, this stationary source had not met the specific requirements for being “announced for retirement.”

Specifically, the coal-fired D.E. Karn Generating Complex of Consumers Energy emitted 6,850 tons of SO2, and had an emissions rate of 0.546 lbs SO2/MMBTU. Pursuant to the March 2, 2015 court-ordered schedule, EPA must designate the area surrounding the facility by July 2, 2016.

In its submission, Michigan recommended that the area surrounding D.E. Karn, specifically the entirety of Bay County, be designated as attainment. In this analysis by the state, the JC Weadock Generating Complex (JCW) of Consumers Energy, a facility that is co-located with D.E. Karn, was not included in the modeling because, due to a federal consent decree, the units at JCW must be retired by April 15, 2016.

“After careful review of the state’s assessment, supporting documentation, and all available data, EPA agrees that the modeling, assuming the shutdown of JCW, shows attainment of the NAAQS,” said EPA. “However, since the assumption of the shutdown does not reflect the current state of the Bay County air quality, EPA intends to designate Bay County as unclassifiable. EPA anticipates finalizing the designation of the area as unclassifiable/attainment once the source is confirmed as shutdown.”

D.E. Karn is located in eastern Michigan in the southeastern portion of Bay County. It is located approximately 7 kilometers northeast of the center of Bay City, situated on the Saginaw Bay, which is off of Lake Huron.

The potential to emit limits used by the state for the D.E. Karn units were the result of an installation permit issued on April 30, 2015, to reflect new SO2 control technology.

Lansing (Lansing Board of Water & Light power plants)

The Lansing area contains two coal-fired stationary sources that according to 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 lbs SO2/MMBTU. As of March 2, 2015, these stationary sources had not met the specific requirements for being “announced for retirement.”

Specifically, in 2012, the city’s Eckert Generating Station emitted 3,677 tons of SO2, and had an emissions rate of 0.58 lbs SO2/MMBTU and the city’s Erickson Generating Station emitted 2,685 tons of SO2, and had an emissions rate of 0.64 lbs SO2/MMBTU. Pursuant to the March 2, 2015 court-ordered schedule, EPA must designate the area surrounding these facilities by July 2, 2016.

In its submission, Michigan recommended that the area surrounding these two plants, specifically the entirety of Ingham and Eaton counties, be designated as attainment. “After careful review of the state’s assessment, supporting documentation, and all available data, EPA agrees that the area is attaining the standard, and intends to designate Ingham and Eaton Counties as unclassifiable/attainment,” said EPA.

The Eckert and Erickson stations are located in Lansing in the central Lower Peninsula of Michigan, and are 9 kilometers apart.

Marquette County, Upper Peninsula (Presque Isle coal plant)

Marquette County contains a stationary source that according to 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 lbs SO2/MMBTU. As of March 2, 2015, this stationary source had not met the specific requirements for being “announced for retirement.”

Specifically, in 2012, the Presque Isle Power Plant of We Energies emitted 6,028 tons of SO2, and had an emissions rate of 0.513 lbs SO2/MMBTU. Pursuant to the March 2, 2015 court-ordered schedule, EPA must designate the area surrounding the facility by July 2, 2016.

In its submission, Michigan recommended that the area surrounding Presque Isle, specifically the entirety of Marquette County, be designated as attainment. Said EPA: “After careful review of the state’s assessment, supporting documentation, and all available data, EPA agrees that the area is attaining the standard, and intends to designate Marquette County as unclassifiable/attainment.”

The Presque Isle plant is located in Marquette County in the Upper Peninsula of Michigan. The facility is located approximately 4 kilomters north of the center of Marquette along the Dead River adjacent to Lake Superior.

Monroe County (DTE Electric’s Monroe coal plant)

Back in the Detroit area, Monroe County contains a stationary source that according to 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 lbs SO2/MMBTU. As of March 2, 2015, this stationary source had not met the specific requirements for being “announced for retirement.”

Specifically, in 2012, DTE Electric’s coal-fired Monroe Power Plant emitted 49,151 tons of SO2, and had an emissions rate of 0.62 SO2/MMBTU. Pursuant to the March 2, 2015 court-ordered schedule, EPA must designate the area surrounding the facility by July 2, 2016.

Michigan recommended that the area surrounding Monroe, specifically the entirety of Monroe 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 where maximum concentrations of SO2 are expected. In this analysis, the coal-fired J.R. Whiting Generating Complex of Consumers Energy was not included in the modeling because, due to a federal consent decree, Whiting must be retired by April 15, 2016.

“After careful review of the state’s assessment, supporting documentation, and all available data, EPA agrees that the modeling, assuming the shutdown of Whiting, shows attainment of the NAAQS,” said EPA. “However, since the assumption of the shutdown does not reflect the current state of the Monroe County air quality, EPA intends to designate Monroe County as unclassifiable. EPA anticipates finalizing the designation of the area as unclassifiable/attainment once the source is confirmed as shutdown.”

The Sierra Club also submitted modeling to EPA In September 2015. This modeling showed a violation of the standard for the Monroe Power Plant. The main difference between modeling from the state and modeling from Sierra Club is the emission levels modeled. Sierra Club modeled actual emissions from 2012 to 2014. “However, the actual emissions do not account for the recent controls and emission limits that were effective for the plant in 2014,” said EPA. “EPA believes that the federally enforceable emissions limits relied by the state are an appropriate basis for the designation of Monroe County, notwithstanding the evidence from the Sierra Club that actual emissions from 2012 to 2014 may have caused violations of the SO2 NAAQS.”

In the last couple of years, DTE Electric has finished the final SO2 scrubber installation on Monroe, which means the plant is now fully scrubbed for SO2 emissions.

Ottawa County (Consumers Energy) 

Ottawa County contains a stationary source that according to 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 lbs SO2/MMBTU. As of March 2, 2015, this stationary source had not met the specific requirements for being “announced for retirement.”

In 2012, the coal-fired J.H. Campbell Generating Station of Consumers Energy emitted 21,501 tons of SO2, and had an emissions rate of 0.52 lbs SO2/MMBTU. Pursuant to the March 2, 2015 court-ordered schedule, EPA must designate the area surrounding the facility by July 2, 2016.

Michigan recommended that the area surrounding J.H. Campbell, specifically the entirety of Ottawa County, be designated as attainment. Said EPA: “After careful review of the state’s assessment, supporting documentation, and all available data, EPA agrees that the area is attaining the standard, and intends to designate Ottawa County as unclassifiable/attainment.”

J.H. Campbell is located in Western Michigan in the central western end of Ottawa County adjacent to Lake Michigan approximately 16 kilometers north of Holland, Michigan.

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.