ROBINSON POWER PERMIT HISTORY SUMMARY
In 2017, the Pennsylvania Department of Environmental Protection (DEP) granted Robinson Power a plan approval for its proposed Beech Hollow Energy Center. In 2019, Robinson Power submitted an application to request a modification that would significantly increase emissions of many pollutants that can impact public health and exacerbate climate change.
Compared to the original 2017 proposal, the 2020 proposal would involve the construction of combustion units with a higher capacity, and it would allow a higher number of hours of startup/shutdown, which tends to increase emissions.
The information below, from Pennsylvania Department of Environmental Protection documents, provides a summary of the permitting history of the site.
PLAN APPROVALS (AIR PERMITS)
PA-63-00922A
April 1, 2005: The DEP issued an approval for a 272 MW waste coal-fired power plant
The DEP voided the permit after Robinson Power did not construct the facility by the time the permit expired
PA-63-00922B
June 30, 2011: The DEP issued an approval for a 147.8 MW gas-fired combined cycle power plant. At the time, Robinson Power still considered building an adjacent waste coal-fired power plant
December 1, 2014: Robinson Power never commenced construction under the approval, and informed DEP that the permit was no longer valid
PA-63-00922C
December 1, 2014: Robinson Power applied for a 668.7 MW gas-fired combined cycle power plant
July 7, 2015: Robinson Power withdrew its application
PA-63-00922D
October 27, 2017: The DEP issued an approval for a 1,000 MW gas-fired power plant
October 4, 2018: Robinson Power modified its application to remove certain equipment and modify how it would comply with fuel standards
February 8, 2019: Robinson Power requested to modify sources and conditions
March 8, 2019: The DEP determined that the application was administratively incomplete because Robinson Power did not notify the municipality
March 8, 2019: The DEP sent its Prevention of Significant Deterioration (PSD) requirements and the application to the United States Environmental Protection Agency, the National Parks Service and the Forest Service
March 28, 2019: These agencies determined that the application materials were administratively complete
April 2, 2019: National Parks Service notified DEP that it would not need more analysis
April 19, 2019: The DEP granted the first extension of the 18-month construction period, which made the new expiration date October 27, 2020
June 28, 2019: The DEP requested additional information from Robinson Power, including revised technology analyses, supporting vendor information, revised modeling information, additional justification for modifying certain plan approval conditions, and information on preparing the plant for operation
July 19, 2019: The Forest Service notified the DEP that it would not need more analysis for the Prevention of Significant Deterioration application
April 27, 2020: Robinson Power modified its permit application by adding new equipment, revising its design plans for the Beech Hollow Energy facility, which required a revision to the company’s air quality analyses of the facility. This resulted in the facility becoming a major source of pollution for multiple pollutants (particulate matter, nitrogen oxides, carbon monoxide, ammonia, and greenhouse gases
October 23, 2020: The DEP granted the second extension of the 18-month construction period, making the new expiration date March 28, 2022
NPDES (WATER DISCHARGE PERMITS)
PA0252808
May 22, 2018: The DEP issued this permit for the plant’s industrial wastewater discharge into Little Raccoon Run
PAD630045
September 4, 2019 RPC submitted application for a stormwater discharge permit associated with earth disturbance due to RPC’s construction of 500kV transmission line that will require covering 466 or more acres
PAD630034
August 11, 2020: The DEP issued this permit for stormwater discharge associated with Robinson Power’s construction at the facility site involving earth disturbance of 58.6 acres.
Clean Air Council and Environmental Integrity Project Comment Summary
In July 2020, Clean Air Council and Environmental Integrity Project submitted comments to the DEP on the proposed application, noting the ways in which it was insufficient. This was not a routine plan approval application. Because this would be a “major source,” it is subject to the more stringent requirements of the Prevention of Significant Deterioration (PSD) program. The following is a summary of their comments on July 17, 2020 and July 31, 2020:
1. The “additional impact analysis” was insufficient. It was required to provide an analysis of any air quality impacts projected for the area as a result of growth associated with the facility. There was no qualitative discussion of growth or treatment of the projected growth in emission quantities, or evidence or analysis to substantiate the conclusion that the growth associated with the facility was projected to be negligible.
2. The air modeling analysis was flawed in several ways.
The most significant flaw involved the determination of whether Significant Impact Levels (SIL) would be exceeded. (A new major source may not cause an increase in the concentration of certain air pollutants like fine particulates above certain levels). The applicant failed to provide a justification for basing its modeled impact on land use data from the airport, rather than on land use data from the project site. Under a guidance document from the Environmental Protection Agency, the applicant should have determined how representative the surface characteristics at the airport were compared with those at the project site, and it should have evaluated how that might affect predicted concentrations. The applicant did not do this.
The DEP should have exercised its authority to require additional air monitoring for background concentrations, the inclusion of emissions of ammonia in the air modeling, and the consideration of the impacts in the nonattainment area in Allegheny County. The facility would be a major source for ammonia, a precursor to fine particulates, and it would be located near the southwestern border of Allegheny County, which has long suffered from nonattainment with health-based standards for fine particulates.
3. Robinson Power’s control technology review was insufficient. It has not demonstrated that it meets the requirements of Best Available Control Technology (BACT) and Lowest Achievable Emissions Rate (LAER), categories of technologies required when proposed facilities are expected to lead to a large increase in air pollution.
4. When power plants start and stop operations, more air pollution is emitted. The dramatic increase in the number of proposed hours of startup and shutdown (147 hours instead of the original 33.8 hours in the previous application) highlights the need for clear and enforceable definitions, limits, and monitoring during such events.
The Department should reject Robinson Power’s proposal to define startup and shutdown (during which time the facility would generally be exempt from emissions limits) by whether the facility is not in compliance with emissions limits -- an example of circular reasoning. The applicant’s proposed definition would create an incentive against prompt compliance with emissions limits.
The Department should include specific emission limits for periods of startup and shutdown, based on data regarding anticipated emissions already provided by the applicant. In addition, the Department should propose a limit on the duration of a single shutdown event. This is important because the applicant is relying on specific hourly and concentration-based emission limitations during normal operations as a basis for avoiding legal requirements for major sources, but it is not doing the same for periods of startup and shutdown.
5. DEP should reassess the facility’s potential to emit and require supplemental information from Robinson Power due to its changes.