Coastal Alliance on Plant Expansion

Comments on Proposed PSD, to LSP Morro Bay LLC
Morro Bay Power Plant Modernization Project
Permit NO. SCC 2005-01

On behalf of the many members of the San Luis Bay Chapter of the Surfrider Foundation (SLB Surfrider), thank you for the opportunity to submit comments regarding the U.S. Environmental Protection Agency’s (EPA) proposed Prevention of Significant Deterioration (PSD) permit to Dynegy for the Morro Bay Power Plant Modernization Project. The Surfrider Foundation is a non-profit environmental organization dedicated to the protection and enjoyment of the world’s oceans, waves and beaches for all people, through conservation, activism, research and education.

San Luis Obispo (SLO) County has 100 miles of coastline to offer the public for recreational uses. The coastline’s importance to our tourism-based economy is displayed by the variety of ocean enthusiasts from around the world that are attracted to our shores. Furthermore, we have entered an era recognizing the potentially catastrophic impacts of global climate change upon our economy, environment and society. Hence, SLO County, the State of California, and the EPA cannot afford to take a lax approach to developmental decisions that directly impact our environment. The health of the ocean and those who recreate and live near it depend on the highest standards of water and air quality.

Upon review, SLB Surfrider agrees with the Coastal Alliance on Plant Expansion (CAPE) and strongly opposes the proposed PSD permit for the following reasons:

1. As stated in the U.S. Clean Air Act, our industrial decisions, especially those impacting the nationally protected Morro Bay Estuary, require the EPA to, “protect public health and welfare from any actual or potential adverse effect” from air pollution or from exposure to pollutants, even in the event of “attainment and maintenance of all national ambient air quality standards” by the facility in question. The Clean Air Act also requires the EPA to “preserve, protect, and enhance the air quality” in national areas of special natural, recreational or scenic value. Again, Morro Bay is a nationally protected estuary and deserves higher standards than a PSD that will allow toxic emissions from the proposed new plant to remain at the levels of the existing 50-year-old power plant.
2. The central and uncontested fact is that ground-level concentrations of particulate matter (PM, both 2.5 and 10 micrometers in diameter), a potentially lethal toxic emission that the EPA considers a significant health risk, would rise 60% in Morro Bay, partly as a result of an increase in the proposed plants operating capacity by 20% to 1200 megawatts and stated plans to operate it more than the existing plant has been operated.
3. We agree that the proposed height reduction of the plant smokestacks from 450 feet to 145 feet, makes it less feasible for prevailing winds to blow the PM away from the community closest to the plant and the Morro Bay Estuary. Indeed, the California Energy Commission Final Staff Assessment, Part 1, Part 3, page 4-12, dated April 2002, concluded: “…the actual air quality impacts of the new facility are expected to be greater than the existing facility in nearly all cases. This is primarily due to the much greater stack height of the existing plant…”
4. We also agree that the local air quality permit, on which the proposed PSD is partly based, has expired, and newer state and federal emissions control standards may invalidate the PSD.
5. Emission rates for a new plant are contradictory and inconsistent, levels are understated by the applicant, air modeling for PM was inappropriate under EPA standards, the levels of emissions from the existing plant have been overstated to make those of the new plant appear to be lower, the baseline used to determine emissions levels for the existing plant has been inflated and the baseline years are the opposite of what the PSD requires for normal source emissions. We agree that the PM10 emissions levels for the new turbines proposed by the applicant are grossly understated.
6. The current Best Available Control Technology (BACT) may not allow use of duct burning, which contributes disproportionately to higher emissions, and more advanced and less-polluting turbines are commercially available, which EPA should review and consider as a requirement for the PSD permit.
7. We are disappointed that closed-cycle cooling and related PM emissions were not reviewed by EPA, even though it has not been ruled as for use by the proposed new plant.
8. We agree that an appropriate baseline of emissions from the existing plant may show that emissions from a new plant would violate PSD requirements, preventing issuance of the permit–leading to the applicant having to build a smaller, less polluting plant or no plant at all.
9. The meteorological data used to calculate ground-level emissions are not from Morro Bay, and no evidence has been presented to show that it is relevant to Morro Bay meteorological conditions.

   We agree with CAPE comments that the upper air meteorological data collected for the MBPP site was collected from Vandenburg Air Force Base, which is 45 miles southeast of the plant site. The owner/operator has never provided adequate evidence that this remote site has similar upper air conditions as the MBPP site, nor has it established any upper air meteorological data for the MBPP site itself since the original application was filed in 2000. The remote site data is inadequate for air modeling purposes to predict ground-level emission levels.

10. It is obvious that out-of-date national standards were used in determining permit compliance, and under newer ones, the proposed plant would not comply, if emissions were calculated correctly.
11. We agree that the Data analysis for PM 10 was inadequate to determine actual PM10 levels, exposing the public to significantly higher than allowable emissions and at farther distances from the plant.
12. We deem that Duke’s analysis assumed no distribution of PM beyond a six-mile radius of the plant, even though scientific literature indicates particulates are regional by nature, and the analysis failed to consider extreme meteorological conditions.
13. Furthermore we agree the PSD permit fails to consider Emission Reduction Credits, which are “offsets” that were used to find the new plant in compliance with local and state air quality standards, despite the fact emissions would still increase and the fact that the PSD is based in part on this compliance finding, serving to hide the real amount of emissions that the public would be exposed to.
14. Finally, the EPA Ambient Air Quality Impact Report (AAQIR) says the existing plant has operated since the 1950s “without incident” involving agricultural uses, even though many complaints have been made over the years by residents about emissions fallout from the plant, which damaged personal property and local vegetation.

CONCLUSION:

For all of the reasons discussed above, SLB Surfrider strongly supports CAPE’s recommendations to the EPA to conclude that the PSD analysis must be provided for all pollutants based on an appropriate baseline emissions period and that PM10 emissions will clearly cause an exceedance of PM10 PSD increments. We agree that such conclusions would not allow issuance of a permit for the Morro Bay Power Plant Modernization Project as currently proposed.

The San Luis Bay Chapter of the Surfrider Foundation finds the consideration of extending the life of the Morro Bay Power Plant to be damaging to SLO County’s tourism-based economy, human health and the environmental, particularly the Morro Bay National Estuary. In this day of serious global warming concerns our industrial decisions must appropriately reflect the planet’s current environmental condition. In conclusion, the SLB Surfrider Foundation is committed to and supports the development of green technologies and energy conservation techniques that do not pose negative impacts on human health, the economy and the environment. The time is now to drastically reduce our society’s toxic output and proceed into an ecologically abundant future.

Your consideration of our comments is greatly appreciated.

San Luis Bay Chapter
Surfrider Foundation

San Luis Bay Chapter
U.S. EPA Region 9
75 Hawthorne Street
San Francisco, CA 94105-3901
(415) 972-3965
r9airpermits@epa.gov

San Luis Bay Chapter of the Surfrider Foundation
PO Box 13222
San Luis Obispo, CA 93406
slbsurfrider@gmail.com