The Sierra Club said Feb. 17 that the U.S. Environmental Protection Agency has proposed designating large portions of Baltimore and Anne Arundel counties in Maryland as failing to meet the agency’s health-based air quality standards for SO2.
The H.A. Wagner coal-fired power plant just outside of Baltimore is one of the last remaining plants on the entire East Coast to still lack modern pollution controls for SO2 and is responsible for much of the pollution in the city and surrounding area, the club said. If the designation is finalized in July, the Clean Air Act will require Maryland to develop a plan to clean up the air and protect its citizens. The Maryland Department of the Environment (MDE) has already provided draft regulation that would keep the region’s air safe for the community which was shared for comment back in January 2014, said the club.
David Smedick, the club’s Maryland Beyond Coal Campaign and Policy Representative, said: “MDE already put months of work into a pollution reduction plan that would address the dangerous sulfur dioxide levels around Baltimore, much of which is attributable to the Wagner coal plant. Sadly, MDE has let these draft regulations languish for more than two years. We thank the EPA for its recognition of the region’s failing air quality and hope that it serves to galvanize action by the Department to finalize these needed air quality protections that have simply been gathering dust for too long.”
H.A. Wagner is a 976-MW plant owned by Talen Energy (NYSE: TLN) that is fired by coal, gas and oil.
Said a Feb. 16 technical document from EPA on its Maryland decision: “The Anne Arundel County and Baltimore County area contains one stationary source that according to EPA’s Air Markets Database emitted in 2012 either (a) more than 16,000 tons of SO2 or (b) 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, Herbert A. Wagner Generating Station (Wagner, or the Facility), had not met the specific requirements for being ‘announced for retirement.’
“Specifically, in 2012, Wagner emitted 7,514 tons of SO2, and had an emissions rate of 1.105 lbs SO2/mmBTU. Pursuant to the March 2, 2015 consent decree and court order, EPA must designate the area surrounding the facility by July 2, 2016.
“In its April 19, 2011 submission to EPA for the initial designations for the 2010 SO2 NAAQS, Maryland recommended that the area which includes Wagner, specifically the entirety of Anne Arundel County, be designated as unclassifiable. Likewise, Maryland’s 2011 submission recommended that Baltimore City be designated as unclassifiable. The 2011 submission, however, did not include any supporting analyses. Subsequently, in its November 20, 2015 updated designation recommendation submission to EPA, Maryland recommended that the area surrounding Wagner be designated as attainment. Maryland, however, did not recommend any particular boundary for the area in its November 20, 2015 submission. Maryland stated that no monitors in Maryland violated the 1-hour SO2 NAAQS, and EPA has confirmed this.
“On January 15, 2016, Maryland submitted a supplement to its 2015 recommendation which included a modeling analysis for the area around Wagner. Additionally, this supplement included comments on air dispersion modeling dated January 4, 2016, performed by Sierra Club and submitted to EPA, asserting that violations of the NAAQS are present in the area around Wagner. Maryland did not update its recommendation for Baltimore City in its 2015 updated recommendation. After careful review of the State’s 2015 recommendation and all submitted available data including air quality characterization, emissions data, meteorology, geography, topography, and modeling analyses for the area around Wagner, EPA disagrees with the State’s recommendations, and intends to designate the area surrounding Wagner (portions of Anne Arundel County and Baltimore County) as nonattainment, and Baltimore City as unclassifiable/attainment.”
EPA: recent SO2-reduction at Wagner not technically valid for rulemaking purposes
“Wagner is located in eastern Maryland in the northern portion of Anne Arundel County,” said the EPA report. “[T]he facility is located approximately two (2) kilometers south of the City of Baltimore along the Chesapeake Bay. … Specifically, the boundaries for our intended nonattainment area are comprised of the portions of Anne Arundel and Baltimore Counties that are within 35.5 kilometers of Herbert Wagner’s Unit 3 stack, which is located at 39.17765N latitude, 76.52752W longitude.
“EPA confirms that emissions had decreased significantly from 2007 to 2010; however, they have not decreased since then, and have in fact increased slightly in 2014 from the 2010 level. Additionally, Wagner had been identified in 2015 as meeting the emission criteria outlined in the court order, and Wagner’s emissions have not decreased further since 2010 with its SO2 emissions remaining between 9,000 and 10,000 tons per year, As a result, EPA believes that this emissions data alone does not support the attainment designation recommended by Maryland. Wagner’s emissions also have not decreased as significantly as Brandon Shore’s and Crane’s, which may reflect an absence or under-use of SO2 controls.”
At one point, as referenced in the EPA report, the Wagner, Brandon Shores and Crane coal units were owned by Raven Power, but were part of a 2015 merger that created Talen Energy. Talen recently sold Crane, but has retained Brandon Shores and Wagner.
Said the EPA report: “To evaluate what emission controls are installed for Wagner and neighboring sources, EPA reviewed its Air Markets Programs (AMP) database. According to the AMP database, Brandon Shores has wet lime flue gas desulfurization (FGD) on Unit 1 and wet limestone SO2 control for Unit 2. No SO2 controls are listed in the EPA database for Wagner or C.P. Crane. … With the lack of SO2 emissions controls at Wagner and the present level of emissions at the plant, EPA lacks sufficient supporting evidence to support an attainment designation for the area around Wagner as Maryland has recommended.
“Maryland’s updated 2015 designation recommendation mentions that in mid-April 2015, the owners of the Wagner facility, Raven Power, began to use a low sulfur coal at Wagner’s unit 2 as a method of compliance with the federal Mercury and Air Toxics Standard (MATS). However, EPA has insufficient information on the percent sulfur coal and whether any restrictions on fuel sulfur coal are in a permanent, federally enforceable document such as a permit or SIP approved requirement. Maryland also mentions that in early 2016, Raven Power will be adding a dry sorbent injection (DSI) system to Wagner’s unit 3 to comply with MATS to help reduce SO2 emissions. Again, EPA has no further information at this time regarding the specifications of the DSI system, its control efficiency, and operational requirements and no information on whether DSI controls are federally enforceable via permits or SIP requirements. In addition, review of Wagner’s unit-by-unit emissions reveals that emissions of SO2 from Wagner’s unit 3 are far greater than that of unit 2 and hence EPA believes controls and effectiveness of controls at unit 3 at reducing SO2 are more important to any analysis of impacts from the plant. At this time, there are no federally enforceable controls in place at the plant to reduce SO2, and Wagner’s obligations to comply with the federal MATs requirements is not sufficient to allow EPA to fully evaluate future likely impacts from Wagner on the NAAQS, and are not relevant for evaluating whether actual emissions from 2012-2014 caused violations of the NAAQS during that period.
“Maryland has not presented any analysis or information to support that MATS compliance plans will reduce SO2 emissions from Wagner to such an extent that the SO2 NAAQS are met. Present information from Maryland regarding potential control options at the plant and fuel switching options without federally enforceable controls and limits is insufficient to support Maryland’s recommendation of attainment for the area. Furthermore, based on EPA’s review of emissions control information in conjunction with available air dispersion modeling discussed later in this draft technical support document, EPA believes a designation of nonattainment is appropriate for the area around Wagner.”
U.S. Energy Information Administration data shows that Wagner in 2015 mostly took coal from the Brooks Run mining operations of Alpha Natural Resources, with other coal sources that included Alpha’s Hutchinson-Kanawha operations in West Virginia, MC Mining‘s Mine #4 in Kentucky, Patriot Coal’s Patriot Mining operation in West Virginia, and, for a time last summer, from Peabody Energy‘s Sage Creek/Twentymile mining operation in Colorado.