The Delaware Department of Natural Resources and Environmental Control said Aug. 9 that it has again taken action to reduce improve air quality through a petition asking the U.S. Environmental Protection Agency to find that FirstEnergy‘s (NYSE: FE) coal-fired Harrison plant near Haywood, W. Va., is emitting air pollutants in violation of the federal Clean Air Act (CAA) and National Ambient Air Quality Standard (NAAQS) for harmful ozone.
As with a Clean Air Act 126 petition filed the previous month by DNREC against Talen Energy‘s (NYSE: TLN) Brunner Island power plant in York County, Pa., the department argues that Delaware’s air quality is often adversely affected every summer by unhealthy ozone, with a number of NAAQS ozone exceedances having already occurred this year, and a likelihood of more to come so long as sources such as Harrison and Brunner Island continue emitting pollutants without proper controls, particularly for NOx.
The Delaware agency said that computer modeling, using EPA-approved methods, has confirmed that both the Brunner Island and Harrison power plants produce air pollution that carries into Delaware, resulting in exceedances of the health-based ozone air quality standard. Exceedances of the ozone NAAQS contribute to increasing incidents of asthma, respiratory disease and other health problems for Delawareans.
DNREC Secretary David Small said: “We are again petitioning the EPA to act on the fact that our ability to achieve and maintain health-based air quality standards is severely impacted by sources outside of the state of Delaware. Our position has been corroborated by EPA’s own modeling technology – that West Virginia’s emissions significantly impact Delaware – and we are petitioning EPA to reduce that impact and the encompassing health threats foisted on Delawareans through harmful ozone that comes from outside our borders.”
Small also said that Delaware is continuing to assess the impact of other electric generating facilities in the upwind states and that additional Clean Air Act 126 petitions may be developed in the near future. Some of the states where these power plants exist do not have regulatory requirements for installing highly-effective NOx emissions controls, while still other states do not require the power plants to consistently operate existing NOx controls at high levels of efficiency, the agency said.
Before DNREC’s Clean Air Act 126 petition to EPA, West Virginia had proposed more stringent NOx emissions limitations for the Harrison plant. However, DNREC’s Division of Air Quality reviewed the proposed NOx emission rate limitations and determined that, even if implemented, the new rate limits will not mitigate the Harrison plant’s significant impact on Delaware’s air quality.
Delaware’s 126 petition to EPA also notes that Harrison is outfitted with very effective post-combustion NOx emissions controls, but that the facility does not consistently operate those controls. Coal-burning Units 1-3 at the plant – installed in 1972, 1973, and 1974, respectively – all are equipped with low NOx burners (LNBs) and selective catalytic reduction (SCR) NOx controls as installed between 13 and 15 years ago, but these controls are used sparingly, thus contributing to Delaware’s cross-state air transport problems, said the state agency. When the plant’s SCRs are not deployed, emissions are several times higher and more detrimental to ozone levels than when they are operating at high levels of NOx control.
Section 126(b) of the Clean Air Act requires that within 60 days after the EPA’s receipt of any petition (and after a public hearing), the EPA administrator will make such a finding as requested, requiring the Harrison station to limit short-term NOx emissions to levels that are protective of the 8-hour ozone NAAQS in downwind areas such as Delaware, or deny the petition.
Harrison has three coal-fired units that produce a total of 1,984 MW. Unit 1 went online in 1972. Unit 2 went online in 1973. Unit 3 went online in 1974. The plant uses more than 5 million tons of coal annually, mostly from mines nearby.