Coastal Alliance on Plant Expansion

To: Rep. Lois Capps
From: CAPE
Subject: Air quality permit for new power plant in Morro Bay

Dear Rep. Capps:

The U.S. Environmental Protection Agency last October conducted a hearing in Morro Bay on a federal air permit sought by the owner of the existing Morro Bay Power Plant, who has indicated an intent to seek approval for a proposed new power plant on the plant site. The permit is called a Prevention of Significant Deterioration (PSD) permit. No decision on the PSD has been rendered yet.

The Coastal Alliance on Plant Expansion (CAPE), a nonprofit citizens group which for eight years has been advocating effective environmental and air quality controls if a new plant is built, strongly opposes the permit sought by Dynegy, Inc., the new plant owner.

The central and uncontested fact is that ground-level concentrations of particulate matter (PM), which EPA considers a significant health risk, would rise 60% in Morro Bay primarily as a result of the proposed plant’s operating capacity being increased by 20% to 1200 megawatts.

PM are fine particles “that are easily inhaled into the lungs,” EPA says, and scientific studies have linked PM to “significant health problems,” including decreased lung function, aggravated asthma, chronic bronchitis, irregular heartbeat, heart attacks and premature death in people with heart or lung disease. There is no known safe level of PM. Information on PM is available at http://www.epa.gov/oar/particlepollution/fastfacts.html

An EPA air quality impact report shows PM “to be a pollutant for which the proposed emission change (from a new plant) exceeds the significance threshold” under EPA regulations.

The PM, produced by fuel sulfur, inert trace contaminants and incomplete combustion of hydrocarbons in smokestack emissions, would be controlled by a “combination of good combustion practices and low or zero ash fuel (i.e. natural gas),” the EPA report on the PSD says. It does not state to what levels the PM would be reduced, whether those levels are considered safe and who would be responsible for controlling it or what technology would be used as the control.

The report further states that carbon monoxide, nitrogen dioxide and sulfur dioxide would be reduced by a new plant while ozone, although it would increase, would be below standards. But a new plant would still release more than 1,500 tons of emissions per year, including PM. This is in comparison to the existing plant’s licensed capacity of 1002 megawatts, despite the fact that the plant is operating with only two of its four generating units and at very low levels.

Another reason PM levels would rise in Morro Bay is because the height of the plant smokestacks would be reduced from 450 feet to 145 feet, which would prevent winds from blowing as much of the PM away from the community surrounding the plant. This was established by a staff report of the California Energy Commission.

The EPA analysis assumes that a new plant would use water drawn from the Morro Bay National Estuary to cool the plant (called once-through cooling), even though that highly controversial process that destroys marine life has not been approved by state regulators, and a new state policy to sharply restrict or prohibit it is under review in the wake of a Jan. 25 decision by the federal Second Circuit Court of Appeals requiring best technology available for cooling purposes, which, in effect, prohibits once-through cooling. (An industry appeal of that decision was unanimously rejected by the full Second Court on July 5, 2007.) Alternative cooling technologies, such as dry cooling, “were not analyzed,” the EPA analysis says. This alone renders the EPA analysis completely out of date.

In comments on the proposed permit filed with EPA, CAPE argues that the predicted 200 tons per year of PM emissions are understated by at least 100%. The air quality permit issued by the local Air Pollution Control District in 2001 has long since expired and new stricter state standards may apply. The PM data used in the permit also are outdated by the “overwhelming bulk of scientific investigations of the lethal impacts of this pollutant,” CAPE commented at the EPA hearing. The levels of permissible emissions from the existing plant are overstated because an improper baseline was used.

A proper baseline “would prevent issuance of the PSD permit and as a practical matter would require the owner/operator to elect to pursue a smaller, less polluting plant or forego the modification of the existing (plant) altogether,” CAPE’s comments said.

CAPE cited numerous other flaws in the information submitted by the original applicant, Duke Energy, to EPA. For example, meteorological data were collected from Vandenburg Air Force Base to prepare air quality models for the Morro Bay area without showing how their upper air conditions are similar.

“This leaves the public susceptible to significantly higher than allowable emissions that may spread for miles beyond Morro Bay itself,” CAPE commented to EPA.

The air quality modeling submitted by previous owner Duke Energy to the EPA “assumes no distribution of particulates beyond a six-mile radius of the (plant), whereas all of the scientific literature indicates that particulate emissions are regional pollutants by nature.” The California Energy Commission staff has noted that PM may have long lifetimes in the atmosphere and travel hundreds to thousands of kilometers. In addition, the modeling assumed no severe meteorological conditions of any kind, which could make PM more severe than predicted at times.

Additional details about the flaws and deficiencies of the permit are available at http://www.morrobaypowerplant.org/.

For the reasons stated, we urge you to take the necessary steps to require EPA to address these flaws and deficiencies, which reflect, we believe, a rubberstamping of the plant owner’s request for the PSD without a conscientious review and adherence to federal air quality standards.