by Wallace McMullen
The Ozark Chapter filed a lawsuit in November, 1998, asking that the Environmental Protection Agency (EPA) classify St. Louis as a serious non_attainment area because its air quality is below the legal standard. One result of this suit has been considerable activity by the Missouri Department of Natural Resources (DNR) pertaining to air pollution. DNR requested an extension of the date by which attainment of air quality standards will be required for St. Louis. (Our lawyer has filed a brief which vigorously states that the law prohibits EPA from granting such extensions. This doesn't seem to bother either the EPA or DNR).
EPA's guidance for granting an extension requires, among other things, an "approvable attainment plan." The DNR Air Pollution Control Program has prepared a massive document titled the "SUPPLEMENTAL 1_HOUR OZONE ATTAINMENT DEMONSTRATION PLAN," which was submitted to EPA last November (1999).
This "Attainment Plan" strategy includes reduced emissions of nitrogen oxides (NOx) from Missouri electric utilities, especially those which burn coal as an energy source. Therefore, DNR is now busy promulgating a new regulation which will curtail NOx emissions from electric generating facilities.
Nitrogen oxides (NOx) are nasty air pollutants which contribute to smog, acid rain, and are precursor chemicals to the formation of ozone. So the planned limitation of NOx emissions is arguably one of the beneficial consequences of our air quality suit, particularly for the St. Louis metropolitan area.
Regular readers of the Sierran will recall previous articles on proposed NOx regulations ("Reducing Nitrogen Oxide Pollution", Ozark Sierran, May/June 1999, p. 4). The regulations which EPA proposed, known as the NOx SIP Call, were more stringent than the rules DNR is now proposing. Those regulations are currently stalled by litigation (brought by big industry).
The proposed DNR regulation will establish a limit of 0.25 lb. NOx emitted per million BTUs of heat input in the eastern third of Missouri, and a limit of 0.35 lb. NOx emitted per million BTUs for the western two thirds of the state. This differential is proposed because the current ozone air quality problems are occurring in the eastern part of the state. (Memphis area emissions are also threatening problems in the bootheel area).
In the proposed statewide rule the major coal fired Missouri electric generating facilities would be permitted to emit approximately 43.8 thousand tons of NOx during the ozone season, assuming that fuel input remains constant at 1997 level. If fuel input increased, the upper emissions limit would also increase since the rule does not include an emissions cap. By comparison, the NOx SIP Call rule would have imposed a NOx emissions cap on Missouri electric generating units (EGUs) of approximately 24 thousand tons of NOx during the ozone season. In 1997 these EGUs actually emitted about 82.4 thousand tons of NOx.
The proposed regulation also includes tradable allowances for EGUs which emit less NOx than the limit during operation. Low emission plants like UEs Rush Island will have some ÒsurplusÓ allowances to sell or trade. Even after the allowances are applied, Missouri's major coal burning EGUs would still emit about 39 thousand tons of NOx more than the NOx emissions allowable under the standards in the proposed rule. (Using numbers from 1997, which seemed like a more or less typical year). The remainder of the excess Ñ at least 34 thousand tons - couldn't be offset by allowances and electric generation utilities will presumably have to install emissions controls to reduce NOx emissions by this amount.
We hope that the requirement to reduce emissions will have two positive effects: 1) The air in Missouri will become cleaner, 2) the day when dirty, polluting coal fired electric generating plants are mothballed, and cleaner power sources (solar, wind, etc.) are employed will come closer to reality. That day can not come too soon. Even a clean coal fired facility like Rush Island puts out a lot of pollution, reporting annual emissions of 27,409 tons of sulfur oxides, 7105 tons of NOx, 143 tons of volatile organic compounds, 804 tons of fine particulates (PM10), and 1196 tons of carbon monoxide for 1998. We need clean, renewable sources of electricity.
Information sources for this article included the EPA website, DNR files, and the DNR Energy Center.