The U.S. Environmental Protection Agency has agreed, at least on a preliminary basis, with the state of Kansas that the area around the coal-fired, 1,450-MW La Cygne plant of Kansas City Power & Light is in 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). 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.
Kansas submitted updated recommendations to EPA n September 2015, ahead of a July 2, 2016, deadline for the EPA to designate certain areas in various states established by the U.S. District Court for the Northern District of California in a lawsuit brought by environmental groupos. This deadline is the first of three deadlines established by the court for the EPA to complete area designations for the 2010 SO2 NAAQS.
Said EPA in a technical document supporting a Feb. 16 preliminary decision: “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 the La Cygne Generating Station as unclassifiable/attainment for the 2010 SO2 NAAQS. Specifically, the boundaries are comprised of the entirety of Linn County, Kansas. The unclassifiable/attainment designation is based on a modeling analysis that the State of Kansas provided to EPA.”
The La Cygne 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). As of March 2, 2015, this stationary source had not met the specific requirements for being “announced for retirement,” which would exclude it from this process.
Specifically, in 2012, the Kansas City Power & Light’s (KCP&L) La Cygne station emitted 16,235 tons of SO2 and had an emissions rate of 0.36 lbs SO2/mmBTU. Pursuant to the March 2, 2015 court-ordered schedule, the EPA must designate the area surrounding the facility by July 2, 2016.
In its submission, Kansas recommended that the area surrounding the La Cygne station 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. This assessment and characterization was performed using air dispersion modeling software, i.e., AERMOD, analyzing allowable emissions.
The La Cygne Generating Station is located in eastern Kansas in the eastern portion of Linn County near the Kansas-Missouri border. It includes two boiler units and no other significant emitters of SO2 are located nearby.
The emission limits used by the state for the La Cygne Generating Station were based on the installation and upgrades to emission control equipment to comply with the Best Available Retrofit Technology (BART) program of EPA. The new SO2 scrubber controls were operational at Unit 1 in 2015 and Unit 2 in 2014.