State Line Power Station:The Harms Behind Inadequate Regulation of Coal Combustion

Brian Warensbwarens@gmail.com

What is Coal?

• It’s a fossil fuel!• It’s the largest source of energy for

electricity generation worldwide.

Where Does It Come From?

• Coal comes from beneath the ground.• We uncover it via underground mining (left) or

surface mining (right).

How Does Coal Generate Electricity?

What’s So Great About Coal?

• It provides energy security.

• It is domestically abundant.

• It provides jobs to people in a number of different fields.

What’s Not So Great?

• Coal is a pretty dirty fuel source.

• It can really only be used in way: combustion.

• Coal combustion generates numerous pollutant byproducts.

Byproducts: Particulate Matter

• Particulate matter (or fine dust) causes respiratory problems, heart and lung disease, and haze.

• It also contains mercury – a toxic metal.

Byproducts: Sulfur Dioxide (SO2)

• SO2 is created from burning the sulfur contained within coal.

• It combines with moisture in the air to form sulfuric acid, which falls as acid rain.

Byproducts: Nitrogen Oxide (NOx)

• NOx is a precursor to both acid rain and ground-level ozone (known as smog).

• Too much NOx too close to the ground harms vegetation.

• Coal produces ¼ of U.S. NOx emissions.

Byproducts: Carbon Dioxide (CO2)

• CO2 is Earth’s most plentiful greenhouse gas and a leading cause in global warming.

• Coal combustion is responsible for much of CO2 emission in the U.S.

Byproduct: Coal Ash

• Coal ash is a solid remnant of coal combustion.

• It is most commonly recycled as a cement additive.

• In the interim, it is stored in coal ash ponds, which poses containment issues.

Checks and Balances

• Federal and state regulation are aimed at keeping the above pollutants in check.

• The Clean Air Act of 1970 (CAA) was created to reduce smog and air pollution in general – one innovation was to require new plants to install pollution controls limiting emission of certain pollutants.

New Source Review: Half-Baked?

• The CAA was fraught with ambiguous definitions and inconsistent provisions.

• One problem with the CAA was the new source review process under Section 111.

The Folly of New Source Review

• Section 111’s stringent permitting provisions applied only to “new” sources of air pollution.

• Many existing coal power plants fell outside of its coverage.

• In theory, coping with increasing strict requirements would eventually cause older plants to be regulated out of existence.

• Things did not work out as planned…

Old Coal: The Ones That Got Away

• Congress did not anticipate that older coal plants would stick around and continue to pollute in an unrestricted fashion.

Clear Air Act: Take Two

• Congress amended the CAA in 1990.• The amendments were meant to address acid rain concerns

by drastically reducing sulfur dioxide emissions.

Closing a Door, Opening a Window

• Congress directed stricter SO2 regulation, but gave all power producers too much discretion as to measure to get there.

• Many older coal plants simply switched to low-sulfur coal.

State Line: One Resilient Relic

• One of the worst offenders of old coal: State Line Power Station.

• It has pollute while subject to little regulation for over 80 years.

State Line: Background

• Samuel Insull of Commonwealth Edison (ComEd) directed State Line’s construction in 1929

• It initially operated with with one coal-powered turbine.• However, Insull wanted State Line to be the world’s first

one-gigawatt power plant.• Up to four turbine units were in operation by 1963.• The original two units were eventually shut down.

State Line: Today

• State Line is currently owned by the Dominion Resources, Inc..

• Its net generating capacity is 515 megawatts using two turbine units powered entirely by coal combustion.

State Line: Problems

• It lacks modern pollution control equipment.

• It generates 5 million tons of CO2 a year.

• It is among the dirtiest of old coal plants still in operation.

State Line: Problems (cont.)

• Its continued operation is destroying Lake Michigan’s ecosystem.

• It has violated federal opacity limits dozens of times in the last decade.

State Line: Mitigation• Install scrubbers.• Install filtration

systems.• Install cooling towers

and discontinue once-through cooling.

• Implement carbon capture.

Hope on the Horizon

• New, more rigorous EPA SO2 standards may finally address at least one aspect of the problem.

• Plants not meeting these standards must show how they will comply by August 2017.

Will Dominion Clean Up State Line?

• Nope.• "Dominion does not believe it would make economic sense

to make the investment in the equipment we expect will likely be needed to meet the EPA's new sulfur dioxide standard...We will continue to run State Line safely and in compliance with all applicable rules, regulations, and laws as long as it makes economic sense to do so.” (Dominion spokesman Dan Genest)

?OR

What’s Dominion’s Endgame?

• Dominion will close State Line at some point between 2014 and 2017, rather than meet new SO2 standards.

• It meets current standards by burning low-sulfur Wyoming coal.

What can we do now?• Pass a city ordinance, forcing

Dominion to comply with stricter standards sooner?

• Bring suit against Dominion, causing it to comply sooner?

• Pass more antipollution rules, forcing Dominion to speed up its decision to close State Line?

• Bring a new campaign aimed at reducing the number of fish killed around Lake Michigan?

The End?

• Coal is not going anywhere.• But we should not use so much of it to generate electricity

until we can better control the resulting pollutants.