Comments and Request for Contested Case Hearing
on the Coleto Creek Unit 2 Application for State Air Quality
Permit No. 83778 and PSD Permit #PSD-TX-1118,
submitted by IPA Coleto Creek L.L.C.
Submitted by:
Texas Lone Star Sierra Club Chapter
Alamo San Antonio Regional Group
Austin Regional Group
Dallas Sierra Club Regional Group
Greater Fort Worth Sierra Club Regional Group
Sierra Club's Cross Timbers Regional Group (Denton County)
February 11, 2008
Ms. LaDonna Castanuela
Chief Clerk, MC-105
Texas Commission on Air Quality
PO Box 13087
Austin, Texas 78711-3087
Dear Ms. Castanuela,
Members of the Sierra Club's Lone Star Chapter including five regional groups are submitting
preliminary comments on IPA Coleto Creek LLC's proposed new pulverized coal-fired boiler in
Goliad County near Fannin, Texas. The Sierra Club in addition requests a contested case hearing
on the proposed IPA Coleto Creek's Coleto Creek Unit 2 facility and its emissions from burning
fossil fuels, including Western sub-bituminous coal and lower sulfur bituminous coal. The Coleto
Creek Electric Generating Station has one existing boiler originally fired with lignite and in recent
years apparently added sub-bituminous coal in Unit 1 through a permit amendment. The Sierra
Club is a membership organization with members who will be affected by the IPA Coleto Creek
proposed pulverized coal plant Coleto Creek Unit 2 in Goliad County, Texas, a 650 MW boiler
with a maximum heat input rate of 9,200 Btu/kW-hr.
The following preliminary comments are being filed over public health concerns with the IPA
Coleto Creek Unit 2 permit application to be sited at the existing Coleto Creek plant near Fannin,
Texas and the potential for impacts from the proposed supercritical, pulverized coal-fired boiler's
emissions. We also request a Public Meeting on the Coleto Creek proposed expansion in Goliad
County, Texas.
The Sierra Club's Lone Star Chapter has 25,000 members statewide and more than 10,000
members who are presently living in Goliad County, Karnes County, Bee County, Bexar County,
Atascosa County, Guadalupe County, Wilson County, Travis County, Hays County, Bastrop
County, Caldwell County, Comal County, and Williamson County; 200 members in the McLennan
County Regional Group; 3,929 members in the Dallas Regional Group; 1,839 in the Fort Worth
Regional Group; 6,000 members in the Austin regional group, and 505 members in the
Denton/Collin County Regional Group. The Sierra Club is deeply concerned about air quality and
environmental impacts from industrial sources such as power plants, especially coal-fired power
plants since they are the largest sources of industrial air pollution in Texas.
A number of Sierra Club members have requested that we seek a contested case hearing on
their behalf. In addition, we have members who suffer from asthma and respiratory illness that
would be directly affected by a new coal-burning power plant.
We request a contested case hearing on the permit application. On behalf of the group members
in Goliad County, Karnes County, Bee County, Bexar County, Atascosa County, Guadalupe
County, Wilson County, Travis County, Hays County, Bastrop County, Caldwell County, Comal
County, Williamson County, and the Waco and Dallas-Fort Worth areas, we oppose the proposed
IPA Coleto Creek Unit 2 application on the grounds that it is not protective of public health, quality
of life, or private property that will be impacted by the air emissions from this new coal plant.
We request a contested case hearing on the new IPA Coleto Creek Unit 2 permit application.
IPA Coleto Creek seeks a permit authorization to construct another new coal-fired power plant in
Texas at more than 8,000 tons per year released from an estimated 200-300 foot stack although
the draft permit may allow lower levels than IPA's request for emissions of approximately 8,000
tpy.
The Coleto Creek Unit 2 facility has significant air emissions indicated in the IPA permit
application by burning a mix of fossil fuels, including subbituminous coal.
Normal operating Sulfur Dioxide (SO2) emissions: 1,753 tpy
Normal operating Nitrogen Oxides (NOx) emissions: 1,471 tpy
Normal operating Carbon Monoxide (CO) emissions: 3,507 tpy
Normal operating PM10 emissions: 954 tpy
Normal operating VOC emissions:
100 tpy
Normal operating Lead emissions: 0.27 tpy (540 pounds)
Normal operating Hydrogen Fluoride (HF) emissions: 20 tpy
Normal operating Mercury emissions: 0.066 tpy (132 pounds)
Normal operating Sulfuric Acid (H2SO4) emissions: 117 tpy
Normal operating Hydrogen Chloride (HCl) emissions: 23 tpy
Normal operating Ammonia (NH3) emissions: to be estimated later in the draft permit
TOTAL Normal Projected Emissions: 7,990 tons per year
1. Nitrogen Oxides emissions from the Coleto Creek Unit #2 coal plant would impair the DFW
area to come into attainment with the 1-hour and 8-hour ozone standards. The Waco-McLennan
County area will undergo further deterioration moving closer toward ozone nonattainment. NOx
emissions from the Coleto Creek Unit 2 plant will be nearly 4 tons per day (8,060 pounds a day)
and would significantly eliminate the first round of emissions reductions paid for by the TERP
program.
The new power plant's emissions increase also wipe out the power plant reductions in response
to the SB7 grandfathered power plant cleanup passed in 1999 by the Legislature.
It would impair the Dallas SIP and make it more exceptionally difficult to come into compliance
with the federal health-based ozone standards. Coleto Creek Unit 2 joins CPS Spruce Unit 2 in
nearby Bexar County and three other proposed new coal-pet coke plants in Calhoun County with
a combined total of 7,576 tpy of NOx emissions. Five new coal units in McLennan, Limestone
and Robertson Counties will emit more than 11,893 tpy of new NOx.
New McLennan County NOx emissions:
Sandy Creek 1:
1,793 tpy NOx
New McLennan County coal boiler Total:
1,793 tpy NOx
New Robertson + Limestone Counties NOx emissions:
NRG Limestone 3:
1,752 tpy NOx
TXU Oak Grove 1 & 2:
6,286 tpy NOx
Twin Oaks 3:
2,037 tpy NOx
New coal boiler Total:
10,075 tpy NOx
New McLennan + Robertson + Limestone Counties NOx emissions:
McLennan Total:
1,793 tpy NOx
Robertson Total:
8,323 tpy NOx
Limestone Total:
1,752 tpy NOx
Total Waco airshed new NOx: 11,893 tpy
Calhoun County Navigation Dist. 3:
813 tpy NOx
Formosa Plastics 1 & 2:
920 tpy NOx
CPS Spruce 2:
1,752 tpy NOx
Coleto Creek 2:
1,471 tpy NOx
San Antonio upwind airshed new NOx: 4,956 tpy NOx
TOTAL NEW AIRSHED NOX EMISSIONS: 16,849 tpy NOx
2. The emission limits for oxides of nitrogen, particulate matter and sulfur pollution are not
protective of public health for Goliad County, Karnes County, Bee County, Bexar County,
Atascosa County, Wilson County residents and other downwind communities and citizens. IPA's
Coleto Creek Unit 2 seeks to spew a maximum stack emissions combined total during normal
operations of 4,178 tons per year, nearly 11.4 tons per day or 22,893 pounds per day of harmful
Sulfur Dioxide, Nitrogen Oxides and Particulate Matter from the Unit 2 stack. Startup emissions
will be significantly higher by twice or three times or even higher than normal operating
emissions.
3. The IPA permit application and the draft permit do not consider or require offsets of any
pollutant type at IPA's existing plant including Coleto Creek Unit 1. Nitrogen oxides, sulfur
dioxide, and carbon pollution are of special concern. The permit application does not adequately
examine the impact of the SO2 secondary particulate and NOx secondary particulate emissions
on Class I areas such as Big Bend National Park.
4. The BACT analysis submitted in the permit application is seriously flawed and illegal since it
does not fully explore the best available control technologies. Specifically, the Coleto Creek Unit 2
plant did not adequately consider Integrated Gasification Combined Cycle (IGCC) as part of their
BACT analysis for NOx, PM, Mercury or SO2.
5. The IPA Coleto Creek Unit 2 permit application does not utilize best available control
technologies for sulfur pollution, and does not appear to come close to the application filed prior
to this one for the City Public Service plant in San Antonio.
6. The IPA Coleto Creek Unit 2 permit application does not adequately examine the opportunities
for obtaining sulfur and mercury emissions reductions through coal washing.
7. The IPA Coleto Creek Unit 2 permit application does not adequately manage fugitive dust
emissions either from coal and bottom ash and fly ash handling or during start-up and shutdown.
8. The IPA Coleto Creek Unit 2 permit application does not address global warming gases [CO2
may be as high as 6.0 million tons per year] which clearly should be regulated by the TCEQ. The
TCEQ has the authority and the responsibility to regulate global warming gases and must do so.
The recent settlement in the CPS Spruce 2 application was reached in part due to the willingness
of City Public Service of San Antonio to partially offset its new global warming emissions through
additional renewable energy purchases and increased expenditures on energy efficiency. Almost
every major utility in Texas now acknowledges that global warming is occurring and they are
beginning to take steps in their planning to account for potential carbon regulation. Many of the
utilities are using proxy cost to estimate the cost of potential offsets, others are offsetting
emissions, and others are building IGCC plants.
9. The IPA Coleto Creek Unit 2 permit application does not appear to adequately discuss control
strategies for the emissions occurring during start-up, shutdown, maintenance, or malfunction.
By law, the permit must contain enforceable limits during normal operation, and start up, shutdown, and maintenance are all normal operational conditions.
10. The mercury emissions for the IPA Coleto Creek Unit 2 plant must meet the BACT
standards.
11. Nitrogen Oxides emissions from the Coleto Creek Unit #2 coal plant would impair the ability
of the San Antonio and Austin near-nonattainment areas to remain in ozone attainment with the
8-hour ozone standard. The San Antonio area is within 60-65 miles of the downwind air shed of
the Coleto Creek Unit #2 plant site and would be the most adversely impacted of any major urban
areas in Texas from the Coleto Creek Unit #2's NOx emissions. The Austn city area is within
120-135 miles of the downwind air shed of the Coleto Creek Unit #2 plant site and would be
adversely impacted by the plant's NOx emissions. NOx emissions from the Coleto Creek Unit 2
plant will be nearly 4 tons per day (8,060 pounds a day) and would significantly eliminate the first
round of emissions reductions paid for by the TERP program.
The Cities of San Antonio and Austin may become new ozone nonattainment areas under the
EPA's 8-hour ozone standard based on the high levels of power plant nitrogen oxides from ten
new proposed coal-fired power plants emitting 16,849 tpy NOx upwind of Waco in the following
areas: one in McLennan County, one in Limestone County, three in upwind Robertson County,
one in Bexar county, three in Calhoun County, and one in Goliad county. The TCEQ has failed to
evaluate the impact of high background NOx and Ozone upwind of Waco that will be transported
throughout the regional airshed.
12. The IPA Coleto Creek Unit 2 applicant must conduct Community Baseline Ambient Air
Monitoring by IPA for ozone, nitrogen oxides, sulfur dioxide, particulate matter and meteorological
conditions, at the Coleto Creej plant site in Goliad County as required by PSD regulations on preconstruction ambient air and meteorological monitoring for one-year prior to submission of permit
applications.
13. The IPA Coleto Creek Unit 2permit application does not include the diesel and particulate
pollution that will result from the new rail line that would bring coal to this plant and from the
additional trains, truck traffic and or mining operations that supply coal for this plant and the 9
other coal plants that would use powder river basin coal served by the trains plying the Trans
Texas corridor.
14. Air toxics that would come from this plant are not adequately addressed. Also, the toxicology
review also does not address short-term SO2 spikes.
15. Texas Effects Screening Levels (ESL's) have not been appropriately defined by the TCEQ.
16. The IPA Coleto Creek Unit 2 permit should regulate radon and its carcinogenic byproducts
that the public will be exposed to as a result of stack and fugitive radionuclide emissions from
coal-fired power plants, especially considering the millions of tons of coal being burned. No
radionuclides are listed in the permit application.
17. The IPA Coleto Creek Unit 2 permit application must state what specific equipment makes
and models will be used for the boiler and control equipment as well as the manufacturer
guaranteed emissions levels from this equipment.
18. The TCEQ must implement baseline ambient air monitoring in the downwind Counties area
for ozone, nitrogen oxides, sulfur dioxide and particulate matter from Coleto Creek Unit 2, but
especially considering four proposed coal-fired power plant units in McLennan County and three
more lignite-fired units proposed in Robertson County. Coleto Creek Unit 2 will also contribute to
downwind impacts in the Waco regional airshed adding to the cumulative burden on the area.
This represents the largest concentration of coal-fired and lignite-fired power plants in Texas with
more than 140,700 tons per year of new coal plant air pollution. New power plant air pollution
flying into the Waco regional airshed will be projected at about 385.5 tons per day or 770,959
pounds per day.
19. IPA needs to install and operate a mercury stack continuous emissions monitoring system
when the Coleto Creek Unit 2 plant is constructed by 2009-2010 or later.
20. The IPA permit application does not include adequate annual stack testing and stack PM10
continuous emissions monitoring provisions for particulate matter.
21. The IPA permit application does not consider the critical need to include adequate annual
radionuclide stack testing requirements and stack radon continuous emissions monitoring
provisions for radionuclide gaseous emissions such as radon to assure a demonstration of
continuous compliance through real-time stack monitoring.
22. The IPA Coleto Creek Unit 2 applicant must conduct Plant Site Baseline Ambient Air
Monitoring by IPA for ozone, nitrogen oxides, sulfur dioxide, particulate matter and meteorological
conditions, at the Coleto Creek plant site in Goliad County as required by PSD regulations on preconstruction ambient air and meteorological monitoring for one-year prior to submission of permit
applications.
24. NOx emissions from the IPA Coleto Creek Unit 2 plant will increase the contributions to high
regional ozone levels and would adversely impact on the ability of the San Antonio four-county
regional area and the Austin five-county regional area to remain in attainment with the 8-hour
ozone standards.
25. The applicant IPA must conduct Plant Site Baseline Radionuclide Ambient Air Monitoring for
Radon, Polonium 210 and Lead 210, at the Coleto Creek Unit 2 plant site in Goliad County as
needed to demonstrate the public assurances that the plant's stack emissions are safe.
26. The TCEQ must implement community baseline radionuclide ambient air monitoring in the
downwind Goliad County area for Radon, Polonium 210 and Lead 210 from IPA Coleto Creek
Unit 2, especially considering four proposed coal-fired power plant units in McLennan County and
three more new lignite-fired units permitted or proposed in Robertson County. New units will also
contribute to the radionuclide impacts in the Limestone County, North Texas, East Texas and
Waco-Central Texas regional airshed adding to the cumulative burden on the area. This
represents the largest regional concentration of radionuclide-emitting coal-fired and lignite-fired
power plants in Texas.
27. Transported Nitrogen Oxides emissions from the Goliad Unit 2 plant would impair the ability
of the East Texas and Austin near nonattainment areas to remain in complete attainment with the
8-hour ozone standard.
The citizens in Goliad County, Karnes County, Bee County, Bexar County, Atascosa County,
Guadalupe County, Wilson County, Travis County, Hays County, Bastrop County, Caldwell
County, Comal County, Williamson County and other down wind communities of San Antonio,
Austin, Waco and Dallas-Fort Worth have serious concerns about the impacts that this plant will
have on air quality, public health, quality of life, and economic growth in their communities. As is
described in the following pages, the application for the proposed IPA Coleto Creek Unit 2 plant is
severely flawed in several areas.