The Sierra Club said July 1 that the U.S. Environmental Protection Agency failed to take steps toward protecting air quality, instead designating parts of St. Charles and Franklin counties, Missouri, as having an “unclassifiable” SO2 pollution status.
The main source of SO2 pollution is coal-fired power plants. Ameren operates three coal-fired plants without modern pollution controls in the St. Louis metro area, including the Labadie plant in Franklin County, the club said.
The club said that the Missouri Department of Natural Resources (DNR) had previously tried to give Ameren a “free pass” by recommending to the EPA that the area around the Labadie plant be designated as “unclassifiable.” In February, EPA notified Missouri that it intended to designate the area as failing to meet the health standard for SO2. However, with this just-announced designation, the EPA has failed to correct DNR’s mistake, and the process of reducing the dangerous levels of pollution in the area will be stalled as the DNR submits more data to the EPA, the club said.
“By following the DNR’s proposal, EPA rejected the science and is endangering the health of the people that live in and visit the area,” said Andy Knott, Senior Campaign Representative with the Sierra Club’s Beyond Coal campaign in Missouri. “It is disturbing to see that the very agency tasked with protecting our communities from dangerous levels of pollution has failed to do just that.”
EPA on June 30 issued a series of final decisions on SO2 limits under the National Ambient Air Quality Standards (NAAQS) for areas around the country, including in Missouri.
It found that the Franklin County, Missouri, 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. In addition, as of March 2, 2015, this stationary source had not met the criteria for being “announced for retirement.” Therefore, pursuant to a March 2015 court-ordered schedule, the EPA must designate the area surrounding this facility by July 2, 2016.
Missouri argued that the area was “unclassifiable”
In its Sept. 25, 2015, designation recommendation submission, Missouri recommended that the area surrounding Ameren Labadie Energy Center be designated as unclassifiable based on varying modeling results performed by Missouri, Ameren Missouri, and the Washington University Environmental Law Clinic on behalf of the Sierra Club, and an analysis of historic and recent monitoring. Missouri did not include a boundary with their unclassifiable designation recommendation. On Feb. 16, 2016, the EPA notified Missouri that it intended to designate portions of Franklin County and St. Charles County, Missouri, area as nonattainment, based on its view that the area was not meeting the NAAQS.
On March 29, 2016, and May 2, 2016, Ameren submitted several model runs supporting its position that an attainment or unclassifiable designation would be appropriate for the Labadie Energy Center.
Said EPA’s final June 30 finding: “After careful evaluation of all the information provided including the comments and information received from the state and public, and additional relevant information as discussed in this document, the EPA finds that it is unable based on available information to determine whether the area around Labadie Energy Center is meeting the NAAQS, and therefore is designating the area as unclassifiable for the 2010 SO2 NAAQS.
“This unclassifiable designation is based on an analysis of all modeling received from the state of Missouri, Ameren, and the Sierra Club. As outlined in the EPA’s SO2 NAAQS Designations Modeling Technical Assistance Document, the EPA supports the use of modeling as a surrogate to ambient monitoring to characterize air quality for the designations process, and the EPA recommends modeling the most recent 3 years of actual emissions. These data will generally best represent the emissions that would cause the impacts monitored in a 3-year monitoring data set under most circumstances. Consistent with this approach, the EPA has determined that it is appropriate to consider 2013-2015 modeling analyses, and that we should no longer rely upon modeled violations from the 2012-2014 period as the basis for issuing a final nonattainment designation for the area.
“Based on this new, 2013-2015 modeling, the EPA’s view is that the modeling results widely vary and greatly depend upon how the modeling was conducted, as discussed in this Technical Support Document. Because of the issues present in the modeling methodologies, the EPA does not have a clear basis to determine whether the area currently meets or does not meet the 2010 SO2 NAAQS based on all currently available information. At this time, our final designations for the state only apply to this area and the others contained in this final technical support document. Consistent with the court-ordered schedule, the EPA will designate all remaining undesignated areas in Missouri by either December 31, 2017, or December 31, 2020.”