Even though the two coal-fired plants involved are doomed anyway, making the decision something of a moot point, the U.S. Environmental Protection Agency told the state of New York that the area around the plants is in unclassifiable/attainment for the SO2 NAAQS.
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). A nonattainment area does not meet the NAAQS or contributes to a violation in a nearby area. An attainment area is 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.
The state of New York submitted updated recommendations to EPA in September 2015, ahead of a July 2, 2016, deadline for the EPA to designate certain areas established by the U.S. District Court for the Northern District of California. That court order came out of an environmenjtal group lawsuit. This deadline is the first of three deadlines established by the court for the EPA to complete area designations for the 2010 SO2 NAAQS.
On Feb. 16, EPA sent New York a letter and supporting technical document outlining its preliminary decision ahead of the July 2 deadline for a final one.
The Erie-Niagara area covered by the preliminary decisions contains two stationary sources 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). As of March 2, 2015, these stationary sources had not met the specific requirements for being “announced for retirement,” which would exempt them from consideration.
- The Huntley Generating Station emitted 2,716 tons of SO2 in 2012, and had an emissions rate of 0.70 lbs SO2/mmBTU.
- The Somerset Generating Station emitted 5,653 tons of SO2 in 2012, and had an emissions rate of 0.53 lbs SO2/mmBTU.
In its submission, New York recommended that the area surrounding the Huntley and Somerset stations, specifically the entirety of Erie, Niagara, and Cattaraugus counties, be designated as attainment. Said EPA: “After careful review of the State’s assessment, supporting documentation, and all available data, the EPA does not agree entirely with the State’s recommendation for the area, and intends to designate only Erie and Niagara Counties as unclassifiable/attainment.”
The Huntley Generating Station is located in the northwestern portion of Erie County. The plant is on the shore of the Niagara River in the Town of Tonawanda.
The Somerset Generating Station is located in Niagara County approximately 35 miles north-northeast of Buffalo and 50 miles west-northwest of Rochester. The plant is on the south shore of Lake Ontario.
EPA noted that the only other facility that might impact Erie County is the coal-fired Dunkirk Steam Generating Station in neighboring Chautauqua County. According to the EPA’s 2014 Clean Air Markets database, the facility’s SO2 emissions were 951 tons. Because an air monitor is located in an area that captures the general area where maximum SO2 impacts from Dunkirk Generating Station are expected, the EPA does not believe that emissions from Dunkirk are causing or contributing to a violation of the 2010 SO2 NAAQS in Erie County. The EPA would like to clarify that this assessment applies only to Dunkirk Steam Generating Station’s potential impacts on Erie County, and is not intended to inform air quality characterization within Chautauqua County. Evaluating all current information, the EPA does not believe that there are any stationary sources in any other neighboring county that cause or contribute to a violation of the 2010 SO2 NAAQS in Erie County or Niagara County.
The impacts from sources in Erie County and Niagara County are expected to attain the NAAQS with an adequate margin of safety, and furthermore, are not expected to cause or contribute to a violation of the NAAQS in any neighboring county in New York. As a result, the EPA believes that its intended unclassifiable/attainment area, consisting of Niagara County and Erie County, has clearly defined legal boundaries, and it finds these boundaries to be a suitably clear basis for defining its intended unclassifiable/attainment area. As previously noted, New York has not evaluated the impact to Cattaraugus County from nearby areas in its recommendation, and in conjunction with the fact that Cattaraugus County does not contain any areas meeting the conditions requiring designation by July 2, 2016, the EPA is not proposing to designate any portion of Cattaraugus County at this time.
EPA can’t consider prospective actions in its SO2 NAAQS findings, unless they’re under a federally enforceable program. But all three of the plants mentioned here are being or will be retired due to age and a New York state policy calling for the shutdown of all coal-fired power in the state by 2020.
For example, Huntley Power LLC, the operator of the Huntley coal-fired power plant, on Jan 11 notified the Federal Energy Regulatory Commission of its withdrawal of a proposed unexecuted reliability must-run (RMR) agreement. Huntley is a wholly-owned subsidiary of NRG Energy (NYSE: NRG).
In August 2015, Huntley submitted a 180-day notice to the New York Public Service Commission (NYPSC) that it intended to retire Units 67 and 68 on March 1, 2016. The NYPSC then requested the New York Independent System Operator (NYISO) and Niagara Mohawk Corp. d/b/a National Grid to assess the reliability impacts of the Huntley facility retiring. On Dec. 18, the NYISO and National Grid informed Huntley that the facility was not needed for reliability after March 1, 2016.
Huntley Units 67 and 68 are coal-fired units, with 218 MW of nameplate capacity apiece, that began operating in 1957 and 1958, respectively. The units are interconnected to the National Grid system in NYISO’s Zone A.
NRG has also lately been shutting down Dunkirk in phases, after a plan to convert it to natural gas fizzled. Conversion of the 668-MW Somerset plant to natural gas has also been talked about.