As 2014 draws to a close, the Tennessee Valley Authority (TVA) has been busy working on making an important decision at its Shawnee coal plant in Paducah, KY. December 9th marked the end of the public comment period for TVA’s draft Environmental Assessment (EA) to determine whether or not it should retire or retrofit two coal units at the plant. TVA must make a decision concerning the two Shawnee units by December 31, 2014, under a court ordered deadline per a 2011 Consent Decree with EPA and other environmental groups. In this blog, we highlight some of the key points made in comments submitted by SACE, Sierra Club, Environmental Integrity Project and Earthjustice.
The 2011 Consent Decree focused on only Units 1 and 4 at Shawnee, as these were the units that TVA made major modifications to without properly notifying EPA and obtaining relevant Clean Air Act permits. Shawnee has a total of 10 coal-fired units. Unit 10 was already retired due to an inefficient boiler design. The remaining 7 coal units, excluding Units 1 and 4, are being retrofitted with Dry Sorbent Injection (DSI) to reduce hazardous air pollutants. While DSI is a cheaper pollution control than the scrubbers proposed for Units 1 and 4, DSI controls pose unique environmental dangers, including creating more toxic coal ash. (For more information on DSI and our concerns about its application at Shawnee, you can read a SACE commissioned study on the issue or our blog).
In its draft EA, TVA states a preference for investing significant resources into retrofitting Units 1 and 4 with scrubbers to reduce these units’ sulfur dioxide emissions rather than retiring the two units. For the reasons laid out below, we disagree with TVA’s preferred alternative and instead support retiring the two units – saving TVA ratepayers money and reducing the negative environmental impacts to Paducah’s natural resources.
Shawnee Environmental Assessment Comment Highlights
- TVA failed to adequately justify the purpose and need for the project and its preferred alternative, which is retrofitting Units 1 and 4 with a scrubber that would cost hundreds of millions of dollars (anywhere from $175-225 million). Throughout the EA, TVA acknowledges that they do not need replacement generation in the area to maintain reliability if they retired the two units. Despite this assertion, TVA still claims it needs to invest significant resources to retrofit and continue to operate these units to meet “other system needs.”
- The EA contains insufficient analysis of other alternate replacement generation options, outside of retrofitting the units, including investment in clean energy resources like solar and wind generation. Failure to include these alternatives results in an inadequate EA.
- Analysis of the environmental impacts of the project fails to consider significant impacts to groundwater, surface water and air quality caused by continued operation of these units. Currently, the Shawnee site has significant groundwater contamination caused by coal ash impoundments and the EA fails to address current and future impacts to groundwater, and surface water, in the event that TVA continues operation of these units. Additionally, TVA fails to consider the impact of continued greenhouse gas (GHG) emissions from Shawnee – an oversight that is especially hard to understand given the recently proposed rules to control GHG emission from coal-fired power plants.
- Finally, TVA fails to consider the economic benefits of retirement rather than the more costly retrofit of the units. In order to recover the hundreds of millions of dollars it would cost to retrofit these two aged units, TVA would likely have to maintain them for several more decades—an assumption that is manifestly unreasonable in light of their age. Older plants are susceptible to catastrophic events, and TVA must account for the strong risk that the units become inoperable long before the costs of the scrubbers are fully recovered.
Stay tuned to see what TVA decides on December 31!