HomeMy WebLinkAbout1977-11-22; City Council; 5258; SDG&E air monitoring progresse crw OF CAIiZSBAD e
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AGENDA BILL NO, ,q;75p Initial: Dept . Rd.
DATE : November 22, 1977 C. Atty.
C. Myr. DEPARTNENT :
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Subject: ' .
SAN DIEGO GAS AND ELECTRIC - PROGRESS ON AIR MONITORING
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Statement of the Matter --
San Piego Gas and Electric has requested time to give a
progress report on air monitoring at the Encina Generating
Plant.
Counci 1 action
11-22-77 Council directed staff to review the San Diego Gas & Electric Specific Plan Ordinance and report back to Council at its nex meeting as to the course of action to be taken.
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sD&E SAN DIEGO GAS & ELECTRIC COMPANY
P 0 BOX183i SAN DIEGO CALIFORNIA 92112 G (714) 232-4252
FILE NO
November 22, 1977 CNB 100
Carlsbad City Council Members 1200 Elm Avenue
Carlsbad, California 92008
Dear Council Members:
In accordance with Carlsbad City Council
Ordinance No. 9456, dated May 4, 1976, San Diego Gas & Electric agreed to a condition that would provide for an annual report regarding improvements in plant and operating procedures at Encina Power
Plant.
Attached herewith is SDG&E's first annual
report concerning emission reductions and operating
improvements. ++
/ ckz Attachment
cc: B.W. Colston
Manage
Generation En ineering
(V.P. Project Management)
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AV I&VESTO~ O/i/lED C39D3PAl13"1
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- MENORANDUM
DATE: July 6, 1977
TO: Jim Hagaman , P1 anning Director
FROM: Dana H. Whitson, Assistant Planner
SUBJECT: Encina Power Plant Fallout - Status Report
BACKGROUND
In approving Ordinance 9456 amending the Specific Plan for Encina Power Plant to allow construction of a single 400 foot stack, the City attached the following condition:
The applicant shall make a formal commitment to conduct the studies necessary-to determine what operating practices and/or emissions control devices are capable of eliminating the particulate "fallout" problem. A schedule for the completion of the studies shall be established which is
satisfactory to the San Diego County Air Pollution Control District Officer, the Air Pollution Control District Hearing Board or Court of Law. SDG&E shall fully comply with the abatement order entered in petition No. 607.
The applicant shall further agree to pay claims for property damage resulting from the "fallout" problem until compliance with the abatement order is achieved.
The particulate "fallout" problem shall be controlled to the satisfaction of the City Council of the City of Carlsbad and of the Air Pollution Control Officer prior to the final buildin$ permit clearance for Encina 5 and the single stack.
As a separate action, the Air Pollution Control District issued an abatement order (No. 607) which required SDG&E to:
1) Hire an independent consultant to determine the source of the
particulate fallout problem at the Encina Plant and recommend control technology to substantially eliminate the fallout;
2) Continue paying for property damage resulting from the fallout;
3) Submit a compliance schedule for abatement of the nuisance.
On July 17, 1977 the APCD Hearing Board reviewed the fallout report prepared by York Research Corporation and extended the abatement order so that the level of particulates with use of the fuel oil additive can be determined. Deadlines have set for conducting new
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source tests and paint panel tests. The abatement order has been
mation to be obtained. In the interim SDG&E has been instructed to
extended until December 31, 1977 in order to allow this new infor-
continue paying damage claims.
The State Health Department did express concerns about the health effects of the fuel additives. Both magnesium and manganese additive have been used for many years on the east coast. However, no specifi studies on the health effects of these additives have been conducted. The Health Department's primary concern was with the presence of smal quantities of manganese in the fuel additive. Since the manganese was found to have a limited effect on the fallout, it has been elimin SDG&E, the APCD and the Health Department will continue to monitor th health effects of the magnesium based additive for a period of one year.
YORK RESEARCH CORPORATION REPORT
A copy of the summary and recommendation from the Vork report is attached. The report recommends use of a fuel oil additive, scheduli of soot blowing during favorable meteorologic conditions, control of fuel oil viscosity, and continued use of low sulfur fuel oil. All of these measures except for fuel oil viscosity controls-- are now being implemented. They will continue indefinitely, except for a short period necessary to collect baseline data for the new source tests which have been required.
The report is available in the library for "reserve book" use by the public. We also have an office copy of the report.
RECOMMENDATION
SDG&E will have met the requirements of the APCD once the new source tests and paint panel tests are satisfactorily completed. The City Council at that time must also find that fallout problem has been controlled before final building permit clearance is issued for
Encina Unit #5 and the single stack.
I believe that we should inform the Council that the York Research Report is available for their review. The Council should wait until the abatement order has been rescinded before finding that the fallou has been controlled.
DHW: jp
Attachments Summary & Recommendations, York Research Corp. Memo to APCD from Air Pollution Control Officer, dated 6-17-77 Testimony of Jim Hinrichs, SDG&E, before APCD Hearing Board
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Environmental Consultants { j. y
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^. EHCIMA POG\VER PLANT
DAMAGING FALLOUT
c ELIMINATION PRQGRAM
Volume 1 - Text.
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._ York Research Corporation 1 ! One .Research Drive i Stamford, Connecticut 06906
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Yogk Job NWer 4-9126 i , 3 . i \ 1 .I I Prepared f~n: :
Sals Diego Gas and Electric Company 4600 Carlsbad Boulevard Carlsbad, California 92008 I ' *._
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2.0 SUMMARY
During the first phase of the program, base line conditions wert
established prior to the implementation of operational changes.
The nature of the local danage caused by the Encina Power ylant
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was found to be related to- gcidified parti'dfes generated by the
L boilers and emitted from their smoke stacks. These particles
!- subsequently settle out of the plumes after being carried down-
wind from the plant.
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This acidic fallout is dependent on the i;
I I I formation of sulfur trioxide (SO3)
the combustion process.
and a carbonaceous carrier iI
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Three elements constitute the major portion of the damaging
fallout where sulfur and carbon are contributed by the fuel oil
and the oxygen is supplied by the combustion air in excess of
that required to burn the oil.
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Simplistically then, the solution to the damaging fallout proble
is to minimize, if not totally eliminate the formation of SO3
and the carrier (or neutralize the SO3 without intruducing any
new, damaging material), To eliminate the SO, is to eliminate
either the sulfur or the oxygen.
eliminate the unburned carbon or to trap the particles before
To eliminate the carrier is tc
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,the gas stream 0 enters the atmosphere, *
2.1 Damaging Fallout f
The characterization of damaging fallout is the key to the entir
program. At various locations in the environs of the plant in-
cluding mid-Terramar, (see Figure 1-1) sampling stations took da
every three hours for eight months.
fallout sample collections will heve been made at this writing.
In addition to the normal three hour interval collections, panel
of white paint have been placed tc identify, the extent of "dalnag
and/or the lack of damzge at the szrnpling locations. This Fanel
data is presently being gathered on an ongoing basis, (sPe Secti
6.11).
In excess of ten thousand
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The damaging fallout was acidic.
rust was eliminated when damage spots on the paint panels were
shown to be of an acidic origin a_n,d not iron (see Section 6.11).
2.2 Test Programs
The possibility that i-L was Fr
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Test Program (see Section 4.0) wer2 of an interdisciplinary
concept designed to include source testing, atzospheric monitori
and combustion engineering. The source and atimspheric mcnitori
-_ are ccntinuing on a redlLced scale.
2.2.1 Source Einission Tests
Of particular interest are the particulate pH a
The obvious need to correlate stack emissions with combustioE
engineering ar,d ambient nor,itoring wzs frustrated by the unsulta
the so3 emissi
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.- of EPA methcds used to determine SO3 at the normal low concen-
trations found in the Encina boilers. A superior method was
devised and is being continued by Ongoing tests. The p~ measur
ment of the stack particulate has a low (4 - 0.5 pH units) precis
but is useful in showing trends and comparative levels,
2.2.2 Aknospheric Monitoring
The atmospheric monitorhg conskts of collecting rneteorologica
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data, air quality datz, and fzllout data (see Section 4-2) -<
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- computers which aided materially in reaching decisions (see
Section 6.10).
2.2-3 Combustion Engineering
( The monitoring of plant operations and entry of data into the
computers for correlation with fallout measurements and source
emission data was the responsibility of the com.Sustion engineel
group (see Section 4-3).
2.2-4 Fallout Measurement
The focal point of the study was measuring and identifying the
damaging plant fallout,
constituents nomally found as background around the Encica pLc
but in differing amounts.
measure the effect of plant operations on damagi
(General measuring equipment and techniques are discussed in
Plant emissions contain many of the
A method was 2evelopei to reliably
I detail in sections 4.0, 6.0 and Appendix B). Atmospheric fall( i
mopitcrs daily measured the acidic fallo1Jt - more than-18,000
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.- acid fallout ev a nts were recorded. The @ unting of events was
frustrated by the question, "Which way and how fast was the
wind blowing?"
recorded; but the upper air layer above about 250 feet
Section 6.3 thru 6.6) is unpredictable and confounded efforts
to adequately quantify the acidic fallout events. An alternate
means was devised which nearly eliminated the influence of wind
The acidic fallout events were of two classes, (see Section 6.9
strong acid, and weaker acids plus metal salts- By counting th
two classes of fallouts it was possible to,utilize the ratio of
strong acid to total events counted and observe the change in
ratio for any change in the plant conditions. This ratio chang
enabled data analysis to become nearly independent of the meteo
ological and other conditions (e.g.-a boiler out of service).
A-corroborating indicator is stack particulate average pH. Thi
has also developed into a data source which provides a means of
detecting in the stack whether the normal fallout is going to h
acidic in nature, See Section 5.1.2 for examples of the use of
the ratio and of pH,
2.3 Operational Changes
Once the source of the acid fallout problern was identified,
operational changes were instituted which might best affect a
solution.
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Ground wind direction and speed were continuous
(see
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2-3-1 Additives
Since the acid is forned by sulfur dioxide being further oxidiz I:
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<- into sulfur trioxide with no.rmal excess oxygen, then the additio
of magnesium oxide into the fuel would combine with th& Qulh < "
trioxide to form maqtesium sulfate, This action will neutralize
or prevent the sulfur trioxide from combining with the coxbustio
water to form sulfuric acid.
emitting of stroslg acid fallout fell to one-quarter the rate aft
additives (18% of total fallout as opposed'to 80% before additlv
(see Section 5.1}),
the stacks was substantidly rezuced, from a p9 of 2.5 before .
zdditive to 5.5 after addithe,
The data shaw that the plant's
The acidity of particulates emitted from
l Tests are 'continuing to ge'nerat ,f k' - -1
t fallout data from the entire plact using adsitive rather than ju
one unit.
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2.3.2 Soot Blowing
Greatest fallout intensity w;?s first found durhg plank soot
blowing, Normally scheduled for early evenhg (1700 to 2130),
soot blowing coincided with transitional wind conditions, where
ground level winds reverse direction and exhibit nini_?lum speed.
Upper air winds also change dFrection ar,d sFeed but in a less
predictable manner and usually somewhat earlier than ground
level winds.
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In order to verify that increased fallout was-directly relate3 t
soot blowing activities, independent of wind transition effects,
the soot blowing 2eriod was rescheduled at ll@O to 1530 daily.
The fallout intensity maximux also move2 to the 1100
TerFod. Thus, soot blowi3g was established as a direct influenc
on fallout.
to 1400
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. -1 A hypothesis developed that if soot blowing could be perforned
nearly continuously then fine particles of acidic nature would (
have less time to form into large particles by agglomerating on
the boiler tubes or airheater surfaces. If large particle ..
generation could be limited, then less material would be avai-
lable to settle locally and thus damage would be theoretically
reduced. Evaluation of a period of intensive soot blowing
showed that this did little to assist in the prevention of
damaging fallout, (See Section 5.2)
2.3.3 Viscosity
Fuel viscosity was explored to deternine if there were an
optimum viscosity that would ensure complete combustion carbon,
Reducing the unburned carbon minimizes carriers available
for absorbing sulfuric acid and falling as acidic fallout. An
optimum viscosity was found for the minimum production of un-
burned carbon. (See Section 5.3)
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2.3.4 Fuel Sulfur Content
The effect of fuel sulfur content on damaging fallout was measui
over a three week period burning 0.17% S Fuel.
short time period, the ratio of daqaging fallout to total faLloL
was indeed reduced by this special fuel (805 strong acid fallout
count to 25% strong acid fallout count. If there were no sulfui
in the fuel there would be no sulfuric acid an this small aqour
of sulfur was approaching that condition.
In spite of the
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(See’ Section 5-4)
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0 0 .- 2.4 Control Plan Recommendations
The program objective; mitigation of damaging fallout, is definc
in terns of four specific areas of plant operations where the
most substantial gains in abatement can be obtained. The basis
of an effective control plan is therefore centered on modifi-
cations within those areas, Recommendations are presented
briefly here and explained more ccinpletely in Section 7.0.
2.4-1 Fuel Oil Additive Use
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~ .. ;- ,i 7 A magnesium based fuel oil additive should he used in all boilex
at a minimum amount for effective neutralization of acidic
emissions.
of fuel flows in each boiler.
This rate must be maintained throughout the range
The minimum effective additive rate is determined empirically
as that ratio of additive to fuel which maintains the lowest
particulate acidity and minimum strong acid fallout events.
2-4.2 Soot Blowing Schedule Change
Daily soot biowing in all boilers should be pFrformed between
the hours of 1100 and 1600.
favorable winds of maximum speed and persistence to disperse
acidic particles in a narrow corridor further away from pop-
ulated areas.
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This takes full advantage of
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2.4.3 Fuel Oil Viscosity Control
Fuel oil viscosity should be automatically controlled in each i
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bailer to minime com5ustible particcrla t@emissions.
serves to reduce the carbonaceous carriers of sulfuric acid and
thus reinforces other abatement measures.
This
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2-4.4 Low Sulfur Fuel Oil Use
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Fuel oil should have as low a sulfur content as possible,
will be governed by availability, r
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7.0 CONCLUSIONS AND RECOWNDATIONS
From the data available, a program has been developed which can f --
I. substantially eliminate local fallout damage. This damage has be€
f" isolated to the generation, dispersion and' settling of large
acidified carbonaceous agglom&ates. Evidence from painted panel:
source emission and fallout monitoring confirms this at the Encin;
Power Plant,
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The following items corrstitute the basis of an effective control
plan which will mitigate the fallout problem: * k
i: 7.1 Fuel Oil Additive
I' The proper use of a magnesium based fuel oil additive substantial
eliminates strong acid fallout from the plant. The evidence citec
is from additive use in only Unit 4, with the rest of the plant
operated normally. This produced a significant reduction in the
ratio of strong acid counts (red) to total fallout colints from
80% to 18%.
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I t The use of additive is proper only when minimum effective mounts
are used. More than this will simply be expelle from the boiler
as increased particulate matter without contributing to acid neut
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d 0 With these points in mind, it is recomende that a fuel oil addi
give be used in all boilers at the Encina Power Plant with contro
of additive rates against sulfur content of fuels.
this should be on a real-time basis through continuous monitoring
of fuel sulfur or SO2 emissions. Consideration should also be gi
to monitoring particulate pH as a final control function of addit
rate. The ratio of additive to oil must also be maintained at thc
effective minimum throughout the fuel flow rates used by each bai
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I Preferably,
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i. 7.2 Soot Blowing Schedule I
The rescheduling of daily soot blowing from the present 1700 star
' time to 1100 PST is recornended in order to take advantage of fav(
able wind conditions existing from mid-day through early afternoo
Winds during this period are generally at or near their maximum
speed with high persistence, thus limiting dispersion to a narrow
corridor. Conversely, late afternoon and early evening winds are
relatively low in speed and persistence which tends to deposit
fallout of all sizes in nearby areas. The recommended earlier
period results in carrying away many of the smaller particles wit
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It was observed that intensive soot blowing yielded a measureabLe
reduction in damaging fallout but not significantly greater than
that obtained by simply shifting the time period- I_. This technique
; is not capable of substantial elimination of acidic fallout; ther
fore, it is not recommended considering the extra steam consumpti
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. .~- required and possible water shortages in the area.
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7.3 Low Sulfur Fuel Oil
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\- t Very low sulfur fuel oil use may be a helpful expedient as the dai
clearly indicates. However, not enough data is available to spec:
fically recommend the exclusive use of oil containing less than
.2% sulfur. If a definite change is to be made in this direction
a separate program should be instituted to evaluate the increment(
changes accompanying stepwise reductions in sulfur content. This
t-- would establish the most productive change in terms of acidic fal:
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abatement.
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Certainly, however, the use of higher sulfur content oils than arc
now available should not be undertaken.
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7.4 Fuel Oil Viscosity Control j':
Automatically controlled fuel oil viscosity should be implemented
!- for all boilers to reduce carbonaceous acid carriers. When visco
i values are obtained which result in minimum unburned combustibles
then those values should be used until there is a fuel oil change
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I or the burner tips are replaced. This will not solve the acidic <
fallout problem, but it will make any other solution easier to
maintain.
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Based on the trends exhibited by the data during limited test per
, these recommendations will provide the Encina Power Plant with su
stantial elimination of the damaging fallout, as ell as minimizi
the total fallout that occurs in the nearby corn
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rq GWJNTY OF SAN DIEGO
I NTER-DEPARTMENTAL CORRESPONDENCE
DATE June 17, I91
TO:
THROUGH:
FROM: Mil 1 iam Simmons ,I I
Air Pollution Control District Hearing Board
Clerk of the Hearing Board (A45)
Air Pollution Control Officer (0136) ‘
SUBJECT: ENCINA FALLOUT PROJECT: DISTRICT PETITION NO..:
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On June 9, 1977, the Hearing Board continued the hearing on Petition No. 60
to June 23, 1977. She District then advised your board that: it is prepared to make recommendations as to the modification of the abatement order issue
to San Diego Gas ti Electric Company in concection with the operation of
Encina power plant .
The District also advised your board in its memo of May 11, 1977 that the District has reviewed the test report and the control plan submitted by SDS&E, and that this report does not address the health effects, if any, of ernissicins that may result from the use of the fuel oil additive which is proposd sy SDGE as part of the overall control plan.
SDGeiE ZTL! :% Eistrict have consulted the State Department of Health to det
mine sa:? I-lsalth effects. The department has advised that certain tests ne to be ccn2ucted before an assessment can be made as to any adverse health effects. To be determined are (1) mass emission rates from the stacks, (2) partjcle 57’22 distribution, (3) composition (both elemental and compound specific) of the background, (4) areawide impact, and (5) other related ana
It also appears from the test report that with the use of a fuel oil additi
the total particulate emissions from the Encina power plant may increase (degree not known) even though the damaging acid-fa1 lout wi 11 decrease. According to SDG&E it is possible that there may be no increase in particuf
emissions once all boilers burn the additive. Assuming emissions increase, proposed control plan will have to be reviewed pursuant to District Rules 2
20.2, 53(b) and subpart A of District Regulation X. Source tests are to be conducted on Encina boilers to determine exactly the change in emissions, i any. Also, further evaluation is needed to determine possible damage on di paint surfaces by emissions resulti.ng,from the use of the additive.
As explained to the Hearing Board on June 9, 1977, the acid-fallout problen arises from the formation of acid from SO3 which is formed from SO2 in the presence of monatomic oxygen. SO2 is created by the combustion of fuel oil containing sulfur. Fuel oil additive inhibits the formation of S03. Anotk probable solution to the acid-fallout problem is the use of low sulfur fuel which will result in lower emission of SO2; this method should be tried if
fuel oil additive program cannot accomplish compliance with District Rules
Regul at i ons .
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Encina Fallout Project June 17, 1977
DISTRICT POSIT1 ON
The change in the level of particulate emissions with the use of fuel oil
additive must be determined by a three phase test program; (1) source test after a boiler wash to determine baseline particulate emissions without the use of fue? oil additive, (2) source test shortly after boiler wash, using fuel oil additive, and (3) source test using additive after the operation h stabilized.
tion and similar tests must be conducted after this unit is put into operat
Pursuant to the above, the District recommends that the Hearing Board modif the abatement order issued to SDG&E, as follows:
1. By August 1, 1977 - the use of fuel additive shall be fully irnplementec on all the boilers located at Encina Power plant, Carlsbad. Also, rescheduling of soot blowing as proposed in the control plan shall be i irn?'I enented.
2. By Sqtember 1, 1977 - SDG&E shall install all equipment and instrumenl neczsszry to gather information required by the State Department of He;
an$ suhit the infornation to said department and the District.
Fii'2 {5) days after boiler wash, SDG&E shall conduct a source test to
&--PT7 k, ,,;RS baseline emissions.
Irn~disisly after the baseline test, SDG&E shall conduct a source test
de:=,rn5r?e missions with the use of fuel oil additive.
Mithin 60 days of the test mentioned in '4' above, and after boiler operation with the use of fuel oil additive has stabilized, SDG&E shal
conduct a source test to determine emissions with the use of the fuel addi ti ve .
Tests required by condition nos. 3, 4, and 5 shall be conducted in
accordance with the procedures approved by the Air Pollution Control C Schedules for testing shall be provided the District in advance. Rest
of said tests shall be submitted to the District within two (2) weeks completion of each test..
SDGKE shall determine the impact.of emissions on different paint pane! as required by the District.
PresentJy there are four (4) boilers in operation, therefore
twiIve (12) tests will be required, A fifth unit (boiler) is under constru
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8. SDG&E shall continue to make restitution to all persons whose propert; been damaged by the emissions from the Encina Power Plant.
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4 Enci na Fa1 lout Project June 17, 1977
9. By December 31, 1977, SDG&E shall be in full compliance with all Rules
and Regulations of the District in respect to Encina Power Plant
including compliance with Section 41700 of the Health and Safety Code and District Rule 51,
Respectfully submitted, a&/> WILLIAM SI MONS
Air Pollution Control Officer
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cc: S%&E
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' @?STIPlONY OF J. M. HINRICH@
BEFORE THE HEARIIJG EOARD
OF THE
SAN DIEGO AIR POLLUTION CONTROL DISTRICT
Plr. Chairman and members of the Hearing Board, my name is Jim Hinrich
I am a Senior Engineer in the Generation Engineering Department of th
San Diego Gas and Electric Company.and am reqistered as a Professiona
ginecr in the State of California.
and South Bay Power Plant Fallout Test Programs. These programs have
set up to determine and correct the cause of damage resulting from ac
particulate emissions from these two power plants.
1 am the Project Manager for the
The purpose of my presentation is to again present the results of the
test: program zt the Encina Plant, and describe those measures which 'h
achieve compliace with the requirements contained in Abateinent Order
issued June 10, 1376.
The test proqzm had its beginnings in June, 1976, at which time we a
the allegations and provisions of the Abatement Petition sought by tk
Pollution Control District. At that time it was established by both
and the APCD that "SDG&E was responsible for at least some of the COI
spotting" around the Encina Power: Plant. We subsequently contracted
depenzent consultant, York Research Corporation, as specified in the
ment Order, to conduct a comprehensive study to determine the source
damaging particles, and a method to control. those particles. That te:
after approximately 11 months of in-depth study, is now essentially (
The results of the test program and the recommendations for acid-fal:
abatement at Encina are as follows:
1. Reaffirming our original findings, the four boilers situated at
Encina Power Plant do contribute to local corrosive spotting pro
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Acidified particles formed in the boilers are emitted, and have
sufficient weight to fall in the vicinity of the plant and cause
damage if they land on a susceptible surface such as a car, or a
patio awning.
emitted from the units are extremely small, dust-like, and non-
g corrosive in nature. The acidic fallout particles account for on
It must be remembered that the majority of particl
a very small fraction of the total particulates.
2. Acid fallout particles are composed of two key parts, a carrier
called a "cenosphere," and an acid. The cenosphere is a carbon
particle fom'el! during the combustion of oil, which looks and ac
like a spcnge. It has an affinity for liquids, so the many holes
structure becons filled with water and acid formed during combust
The acid, sulfuric acid in this case, is formed when a small frac
sulfur in the fuel cornbines with oxygen during combustion and thc
water formed from combustion or available in the atmosphere. Whc
particle lands on a cloth, painted, or metal surface, the acid ir
enough to corrode or stain the surface. Fortunately, the acid-fz
particles are small and few in number so that the damage caused :
extensive.
Fallout damage was determined to be primarily caused by acidic pi
and not by iron rust, as was originally speculated.
The. majority of acid-fallout emitted occurs during and immediate
each unit's soot blow, an operation to clean the heat transfer s'
of the boiler. However, fallout is emitted from each boiler at.
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levels throughout the day.
5. The local meteorological conditions surrounding the Encina Power
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are such that the impact of fallout cannot be accurately forecast
based on surface wind speed and direction information. This is b
an unpredictable upper-air layer above approximately 250 feet alt
has no relationship with the surface wind conditions, and since t
stack plumes enter this layer, efforts to determine fallout impac
intensity are confounded.
Based on these findings and York's recommendations, SDG&E plans t
implemezt the following control measures to substantially elimina
damaging acizic fallout from the Encina Power Plant:
1. Magnesim based fuel oil additive will be injected into the f
system of each boiler at Encina on a continuous basis. All E
boilers have been using an additive since May 6, 1977. Test
basec5 sn aiibient fallout monitoring devices inc?icates at leas
80'4 r&!uctior! in the number of acidic particles emitted from
powr glant. The additive reduces acid-fallout by both inhik.
the fo;rxlation of SO and thus sulfuric acid, and by neutrali
any acid that is formed.
The rate of additive injection will be maintained at a level
sufficient to substantially reduce acid-fallout, which will t
minimize any increase in particulates from the boilers. Wit1
additive, we are currently in' compliance with Rule 52 which E
maximum source particulate levels at 0.1 grains/SCF.
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2. Soot blowing on each boiler will be rescheduled fron the pres
1700 hrs. start time to 1100 hrs. in order to take advantage
favorable wind conditions existing from mid-day through earl)
afternoon. Surface winds during this period are generally at
their maximurrl speed with high persistence and apparently, frc
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emission data, the upper winds tend to follow the surface wind
during this time period.
dispersion of fallout to a narrow corridor, East to South-East
the plant, which is essentially unpopulated.
This has the effect of limiting the
Implementation of this change in our soot-blowing schedule has
already begun and will continue as a standard operating practi
on all boilers.
3. Autorratic fuel oil viscosity controls will be installed on eac
boiler to assure that oil combustion is optimized so as to red
the carbonaceous acid carriers, "cenospheres" . Combustion equ
ment is Zesigned to operate at certain fuel oil viscosities in
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order t2 poduce the best flame possible and minimize the amoL
of ~nb:lmed carbon. This project is currently in the engineei
phase, with two consultants handling the engineering. The CUI
rent schedule calls for completion of the project by April, 1:
with hi1 operation to begin by August, 1979.
Based on the trends exhibited by the data during limited test periods,
first two control methods, additives and soot blow changes will provic
Encina Power Plant with substantial elimination of damaging fallout wl
installation of viscosity controls will just enhance the effectivenes!
the other control methods, The cost of these control methods will amc
to $30,000 to $50,000 per month, mainly to purchase the additive.
To verify the effectiveness of our proposed solution without producin
adverse side effects, we concur with the Districts position to contin
test program until December 31, 1977.
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We agree to perform the following functions:
1. By August 1, 1977, additive use and new soot blow procedures will
implemented on each boiler. Currently all boilers are using addi
2. By September 1, 1977, provided sampling sites and equipment are a
able, we will set up and begin a health effects study to meastlre
ambient concentrations of magnesium and magnesium compounds in ac
with approved APCD and State Health Department methods. This stu
will initially be set up to run one year from September 1, 1977 t
September I, 1978 with the data to be supplied to the State Healt
DepariJnent via th2 APCD. It should be noted that the primary con
of the Health Department regarding the additive was the presence
quantities of nanganese in the product. The manganese has now be
eliirtinatei since its contribution to elimination of the fallout i
3. We will. set up and ruT! particulate tests on each Encina boiler ac
to the procedarc outlined in the Districts position. We request
the language, however, to read:
3. Within two (2) to five (5) days ...,
4. Within two (2) to five (5) days ....
4. We have already instituted a study of fallout using different pai
panels and this information will be supplied to the District on a
regular basis.
5. We will continue t.0 pay claixs to all pcrscns whose property has
daxayed by our fallout emissions.
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TO date we have had a total of 67 claims made to the company,
14 have been denied because damage was -not caused by us, 53 have been
settled. Ascan be seen on this chart, the number of claims has
dramatically decreased since the start of the test progran.
for claims have totaled about $24,000 as opposed to $1,230,000 spent
for the test program to date.
Expendit
Approximately one year ago, SDG&E embarked on a program to solve
problem which others had not solved, and to find a solution which 0th
had not yet foEnd. Through an extensive test program utilizing York
Research Corporation, and an expenditure of approximately $1.25 milli
dollars, cr’? have developed a Final Control Plan which will substantia
elininate the fall~ut problem. We will continue this test program un
DeceFber 31, 1577 to satisfy the requirements of the District and thi
aoard.
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1 F T ANNUAL REPORT
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Presented by
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San Diego Gas &. Electric
NOVEMBER 22, I977
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In compliance with City of Carlsbad Ordinance 9456,
Section 314(k), San Diego Gas & Electric is submitting this
first annual report to the Carlsbad City Council. This
report will describe improvements in plant and operating
procedures during the preceding year which reduce the emission
of air pollutants resulting from the operation of Encina
Units 1, 2, 3 and 4.
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The following are areas of improvement that were
accomplished in the last year. These improvements result
in increased efficiency, reduced fuel consumption, and a
corresponding decrease in emissions.
I. Major Turbine Overhaul
Encina Units 1 and 3 underwent major turbine over-
hauls in September 1976 and January 1977, respectively (see
Attachments 1 and 2). During a major overhaul, the entire
turbine is dismantled, useable parts are cleaned and worn
parts replaced or repaired. The turbine is then reassembled
and put back in operation. The goal of a major overhaul is
to return the turbine efficiency to as close to design level
as possible and to insure reliable operation for the next
four years.
four years.
11. Boiler Overhaul
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'r Major turbine overhauls are normally done every
The boilers for Units 1, 2, 3 and 4 were overhauled
during the past year. By cleaning and repairing burners, air
registers, heat transfer surfaces and structural components,
air leakage is minimized. In this way, boiler efficiency is
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returned to design conditions.
111. Condenser Tube Scraping
The tubes in the condenser of all four units were 1 scraped to remove marine growth and other deposits.
this process, spring loaded metal scrapers are inserted into
the l-inch tubes (each condenser has 6,000 to 10,000 tubes)
and a high pressure water stream pushes the scrapers through
the individual tubes.
improved, reducing each unit's turbine back pressure. This
results in improved unit efficiency.
IV.
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Condenser heat transfer is thus
Electric Production Performance Monitoring Program
Since mid-1975, a special SDG&E team has been
working to find new ways of improving plant efficiency and
to cut fuel oil consumption.
Program is one of several developments that resulted from
The Performance Monitoring
1 those efforts.
The aim of this program is to provide a method of
monitoring performance of each unit so that it can be
operated at its most efficient level under various loading
conditions. This increased efficiency leads to reduced oil
consumption and corresponding emission reduction.
make hourly comparisons of actual unit performance to the
best attainable standards and then take corrective action
when appropriate.
control setting of the unit or request that maintenance be I performed (see Attachment 3).
II Operators
The operator can either adjust the
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V. Encina Fallout Test Program
Since mid-1976, SDGGrE has been conducting this
program to determine and correct the cause of damage resulting
from acidic particulate emissions from Encina Power Plant. 1
The test program had its beginnings in June 1976,
at which time SDG&E accepted the allegations and provisions
of the Abatement Petition sought by the Air Pollution Control
District. At that time it was established by both SDG&E
and the APCD that "SDG&E was responsible for at least some
of the corrosive spotting" around the Encina Power Plant.
We subsequently hired an independent consultant, York
Research Corporation, as specified in the Abatement Order,
to conduct a comprehensive study to determine the source of
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the damaging particles, and develop a method to control
these particles.
Results of the test program and recommendations
for acid-fallout abatement at Encina are as follows:
1. Reaffirming our original findings, the four
boilers situated at Encina Power Plant do
contribute to local corrosive spotting problems. t Acidified particles formed in the boilers
are emitted, and some have sufficient weight
to fall within close proximity of the plant
and cause damage if they land on a susceptible
surface such as a car, or a patio awning. The
majority of particles emitted from the unit are
extremely small, dust-like, and non-corrosive
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1 in nature. The acidic fallout particles are 1 very few in number and small in size,
I 2. Acid fallout particles are composed of two key
parts, a carrier called a "cenosphere," and an
acid. The cenosphere is a carbon particle
formed during the combustion of oil, which
looks and acts like a sponge.
for liquids, so the many holes in its structure
become filled with water and acid formed during
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It has an affinity I
cornbustion. As combustion efficiency increases,
production of cenospheres decreases. Therefore,
efforts to improve combustion efficiency are
extremely worthwhile. Sulfuric acid is formed
when a small fraction of sulfur in the fuel
combines with oxygen during combustion and
then with water formed from combustion or
available in the atmosphere. When a particle
lands on a cloth, painted, or metal surface,
the acid is strong enough to corrode or stain
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the surface. Fortunately, the acid-fallout
particles are small and few in number so that
the damage caused is not extensive.
3. Fallout damage was determined to be primarily 1 caused by acidic particles and not by iron
rust, as was originally speculated.
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4. The majority of acid-fallout emitted occurs
during and immediately after each unit's soot
blow, an operation to clean the heat transfer
surfaces of the boiler. However, fallout is
emitted from each boiler at varying levels
throughout the day.
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5. Local meteorological conditions surrounding
Encina Power Plant are such that the impact of
fallout cannot be accurately forecasted based
on surface wind speed and direction information.
This is because an unpredictable upper-air
layer exists above approxima.tely 250 feet
altitude that has no relationship with the
surface wind conditions.
enter this layer, the problem of determining
fallout impact and intensity are complicated.
1.
When the stack plumes
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1 Based on these findings and York's recormendations,
SDG&E implemented the following contrcll measures 110 sub-
stantially eliminate the damaging acidlic fallout from the
Encina Power Plant:
1. Magnesium based fuel oil addlitive is being I injected into the fuel system of each boiler
at Encina on a continuous basis. All Encina
boilers have been using an additive since
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May 6, 1977. Test data based on ambient fallout
monitoring devices indicates a typical monthly
average reduction exceeds 95% in the number of
acidic particles emitted from the power plant.
The additive reduces acid-fallout by both
inhibiting the formation of SO3, and thus sulfuric
acid, and by neutralizing any acid that is formed.
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The rate of additive injection will be
maintained at a level just sufficient to
substantially reduce acid-fallout, which will
then minimize any increase in particulates
from the boilers.
currently in compliance with Rule 52 which
sets the maximum source particulate levels at
0.1 grains/SCF.
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With the additive, we are
2. Soot blowing on each boiler has been rescheduled
from present 5:OO p.m. start time to 11:OO a.m.
in order to take advantage of favorable wind
conditions existing from mid-day through early
afternoon. Surface winds during this period
are generally at or near their maximum speed
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with high persistence and apparently, from
ambient emission data, the upper winds tend to
follow the surface winds during this time period.
This has the effect of limiting the dispersion
of fallout to a narrow corridor, east to south-east
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of the plant, which is essentially unpopulated.
3. Automatic fuel oil viscosity controls will be
installed on each boiler to assure that oil
combustion is optimized so as to reduce the
carbonaceous acid carriers, "cenospheres . ''
Combustion equipment is designed to operate
at certain fuel oil viscosities in order to
produce the best flame possible and minimize
the amount of unburned carbon. This project
is currently in the engineering phase, with
two consultants handling the engineering. The
current schedule calls for completion of the
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I project in 1979.
Based on the trends exhibited by the data during
limited test periods, the first two controlmethods, addi-
tives and soot blow changes will provide the Encina Power
Plant with substantial elimination of damaging fallout
while installation of viscosity controls will just enhance
the effectiveness of the other control methods. The cost
of these control methods will amount to about $30,000 per
month for the purchase of the fuel oil additive.
At the recommendation of the San Diego Air
Pollution Control Officer, a new test program was initiated
to study the proposed solution to the fallout program.
test program will continue until December 31, 1977.
This
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The following activities are underway as part of
this new test program:
1. At the request of the State Department of Health,
tests are being conducted to assess if any adverse
side effects may result from use of the additive.
SDG&E has initiated a program to determine
emission and dispersive characteristics of
respirable-sized particles, with qualitative and
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i quantitative identification. Information will
be submitted to APCD and the Department of Health.
2. SDG&E and APCD are jointly conducting a series
of source tests on each boiler to determine any
net increase or decrease in particulate emissions.
APCD Rules 20.1, 20.2, 53 (b) and Subpart A of
Regulation X limit an increase of total particu-
late emissions to 10 lb/hr 011 100 lb/hr, as
compared to emission levels prior to any modifi-
cation of operations or equipment.
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In conclusion, SDG&E has an aggressive and efficient
overhaul and maintenance program to maintain the most
efficient power plants possible. Additionally, we have
been successful in finding new ways to improve plant effici-
ency in many areas.
Regarding the Fallout Abatement Program, SDGGrE
began over a year ago to solve a problem others had not
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solved, and sought to find a solution others had not yet
found. All valid claims made by residents affected by
this problem have been acknowledged and settled.
an extensive test program utilizing York Research Corp.,
and an expenditure to date of $1,620,000, we have developed
a Control Plan
problem.
Carlsbad residents have dropped dramatically.
tinuing our testing through December 1977 to verify that in
fact this Control Plan will meet all a.pplicable regulatory
standards.
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Evidence of this is the fact: that demand claims by
We are con- a
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1976 OVER
JANUARY FEBRUARY MARCH APRlL MAY JUNE
~~~~ ~~~ ~~~ .5 tO 3s 20 25 s IO 1s 20 25 5 10 13 20 2s 5 10~~1520 25 5 10 IS 20 25 5 IO IS 2
JANUARY FE8RUARY miftcn APRIL MAY JUNE
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EFFICXENCY IMPROVEMENT PROGRAM AT SAN DIEGO GAS & ELECTRIC
Presented at: EEI Prime Movers Committee Meeting October 4, 1976
by: Jon P. Hardway General Superintendent, Electric Production San Diego Gas & Elecitric Company 1
1 INTRODUCTION
Over the last year and a half, San Diego Gas & Electric
Company has been concentrating on reducing its single largest
operating expense--the cost of power plant fuel and purchased energy. A special team was set up to increase plant efficiency and to cut fuel oil consumption.
system heat rate of 10945 Btu/k hr ranked 70th in the survey of the Top 100 electric utilities.Y of 10481 Btu/kwhr which elevated us to 41.st among the Top 100. That improvement of 29 steps is significant. It was exceeded only by one other company--Middle South Utilities, which ranked 56th in 1974 and 23rd in 1975.
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According to 1974 data, SDGSLE's
In 1975) we achieved a heat rate
SDG&E's improvement in heat rate reduced operating
expense in 1975 by approximately $7 milli.on which, undoubtedly, had a significant effect in the Company's improved financial 1 outlook.
Just what did we do to achieve this savings? factors contributed, including a unit performance monitoring pro- gram, improvedmaintenance, cleaner condensers, and operational
dispatch changes.
Many
PERFORMANCE MONITORING
Our first approach to improve unit efficiencies was to develop a unit performance monitoring prolgram, similar to Florida
Power and Light ' s Energy Management Program. 2 Special thanks go
to Charlie Branning of FP&L and Joe Davis of Duke Power Company for their helpful assistance.
1. "The Top 100 Electric Utilities 1974--A Year of Zero Growth", Electric Light & Power, July 21, 1975 (1974 Data); August 16,
"An Energy Management Program Helps This Utility Reduce Its Fuel Bill", 1975 Generation Planbook, Power Magazine, p. 41-45
4 1916('1975 Data).
2.
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The aim of our program is to provide a method of monitoring performance of each unit, so that it can be operated
at its best efficiency under various loading conditions.
Five key variables were selected as potentially having
the greatest effect on heat rate. They are:
1) Turbine back pressure, as a function of circulating
water inlet temperatures. I
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2) Excess oxygen at the economizer outlet.
3) Air heatser gas out temperature, as a function of air heater air in temperature.
4) Main steam temperature, and
5) Reheat stearn temperature.
A display chart containing these five variables, (as a
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function of Mw), for each generating unit has been placed in each
plant control room. The charts graphically depict the "best
attainable" performance standards so that the operator can evaluate the unit's performance. selected over design paramerers to encourage operators to meet
present realistic goals.
takes corrective action when appropriate. The operator can either
adjust the control setting of the unit or request that maintenance
be performed.
on control room logs which are processed and compared by a digital
computer to the best attainable standards. The difference between the actual measurement and the best attainable value is then used to calculate the influence on heat rate and a prediction of the theoretical fuel savings (loss) that is created by variance from optimum. Knowing the econoinic impact of the increased fuel costs, our engineers can then use the data to determine the best correc- tive action, such as optimum frequency and method of condenser cleaning, boiler wash, soot blowing and ocher maintenance item scheduling.
The best attainable approach was
Each operator makes hourly comparisons
of actual performance to the best attainable standards and then
The operator then records actual operating performance
The computer program surmnarizes daily and monthly values for the performance monitoring report. See Figure 1 for sample monthly printout, and Figure 2 for trend analysis.
management withinformation on efficient plant operation. But just- ab iniportant - it requires the plant operators to participate
directly in monitoring each unit's efficiency.
The performance monitoring report provides Company
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OPERATIONAL CHANGES
Operational changes have had a significant effect on our system heat rate improvement. Our first step was to set up
an accurate set of current incremental heat rate characteristics
for all steam generating units. In some cases, we had previously been dispatching units on the basis of 10-year-old data. Since
absolute heat rate changes can change the incremental heat rates
significantly, accurate input-output tests are essential. A
special team of SDG&E engineers was formed to make periodic tests
of all steam generating units. Within 15 months, tests of every
steam unit on the system had been completed. The results were twofold: First, accurate incremental heat rate curves were define and second, each unit's performance was compared to original or manufacture specifications.
The incremental heat rate curves were then utilized by a new computer program, "Unit Comitment/Production Cost". This program provides load dispatchers with an hour-by-hour
nodel of our electric generating system. Now, the Load Supervisor
can efficiently dispatch our generating units by considering
incremental heat rates plus important plant operating conditions
such as boiler/turbine startup, shutdown, and ocher operation data
Operations Department to more effectively schedule limited use of less efficient, quick-starting gas turbines.
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This newcomputer program also enables our Electric
1 MAINTENANCE
Our input-output testing program pointed out that some units no longer met the original manufacturer's guarantee. Thus,
it became our goal on each unit's yearly overhaul to return our boiler/turbines to an "as new" condition. This goal, of course,
could not 3e achieved on every unit without significant modifi-
cations and expense.
During 1975, several major unit overhauls corrected
ljroblems such as severe deposits on turbine blades, circGlating pump impeller wear, turbine seal "rubout", and a condenser fouling.
Another key maintenance development was a new computeriz overhaul schcdulingprogram. This program determines the optimum
yearly schedule for overhauling each generating unit, thereby minimizing the system fuel cost and maximizing the system heat rate improvement.
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CONDENSERS
Both the Performance Monitoring Program and our main-
tenance programs concentrate on turbine back pressure as the
most important variable influencing heat rates. Efforts in 1975 have significantly reduced each unit's back pressure. Our goal, in this case, is to reduce all units back pressure to the
original manufacturer design specification.
In the past, we cleaned our condensers each month with
an air and water method, and each year with rubber plugs.
these techniques cleaned primarily tube-sheet debris and did not
remove mineral deposits. As indicated on Figure 3, the back
pressure on our South Bay Unit 1 had been increasing since 1960.
different methods of condenser tube cleaning. We evaluated hydroblast (10,000 psi waterjet), acid cleaning, a "flocculent"
material, plus the metal scraper technique. The metal scraper
approach, provided by the Condenser Cleaners Manufacturing Co., Pittsburgh, Pennsylvania, was judged to be the superior method.
The condenser tube wear was empirically determined to be less than 0.06 thousandths of an inch (.00006 inch) for each scraping.
The results were dramatic!
We flushed out more than one ton of "crud" frotn the
Howeve
Stemming from our heat rate improvement program, we looked into
condenser cleaning operation at South Bay Unit 1. The deposits were analyzed to be iron oxide, manganese oxide, silica, and organic growth. Figure 3 shows a 1.10" Hg improvement in back pressure--a return to original design back pressure.
Our experience with the scrapers in 1976 indicated that
a frequency of twice a year is optimum for our South Bay units an
once per year for our Encina units.
seven units, we have lowered our system heat rate by 0.66%, gaini a fuel saving of more than $1.2 million per year.
SUMMARY
considering our specific fouling conditions and heat rate economi
By cleaning condensers on 4
I have described some of the major parts of OUT program to reduce the net system heat rate. Many other factors contribut to improvement, but perhaps the most significant is the sincere
interest our management has shown in heat rate improvement.
We're still learning about efficiency projects, but we were encouraged by the first year results. Our goal for 1976 is improve efficiency by an additional 1 to 3%. For this second sta
efficiency effort we have retained the NUS Corporation of Rockvil
Maryland as consulting engineers. This will put additional empha
on specific programs that should further improve our position in
the Top 100 electric utilities.
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San Diego Gas %t Electric
NOVEMBER 22,1977
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MENORANDUM
DATE : * November 25, 197.7
TO : Mayor and City Council
FROM : City Attorney
SUBJECT: Report.Re Ordinance No. 9456 .
At the adjourned City Council meeting of Novernber 22, 1977,. San Diego Gas and Electric Company (hereinafter SDG&E) requested permission to use the new 400-foot stack to receive the exhzust gases from Encina Units 1 through 4. The Council referred the
request to the City Attorney for a report.
The request by SDGstE is controlled by Ordinance Eo. 9456 which
amended SpecificlPlan 144 to pemit the construction of the
stack subject to twelve conditions. (A copy of Ordinance No.9456
is attached for your ready reference). Condition (H) of the
ordinance is the only one directly involved- with the rzqlie,ck and,
in particular, the third paragray;h, which provides:
"The particulate "fallout" problem shall be controlled
to the satisfaction of the City Council of the City of Carlsbad and the Air Pollution Control Officer
Encina 5 and the single stack."
* prior to the final buildixg permit clearance for
The meaning of the term "final building permit clearancen has been reviewed in detail with the Building Director. He reports
that Encina 5 and the stack are being constructed pursuant to a single building permit. (A copy is attached). The stack is
considered to be a part of the Encina 5 structure. The project was assigned to Occupancy Group G which expressly includes power plants. Section 306(a) of the Uniform Building Code (1573
Edition), adopted for use in the City of Carlsbad by Municipal
Code Section 18.04.005, provides in part that:
"NO building or structure in Groups A to H inclusive,
shall be used or occupied, ... until the Buildfag
Official has issued a Certificate of Occupancy therefor.. . " (emphasis added).
Section 306(c) provides that a Certificate of Occupancy shall not be issued.unti1 after final inspection when it is found that
the building. or structure complies with all the provisions of the code. Issuance of a Certificate of Occupancy is the final
building permit clearance in the City of Carlsbad.
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In my opinion the terms of Condition (H) are clear and unambiguous.
The City Council and the Air Pollution Control Officer (hereinafter APCO) must be independently satisfied that the fallout problem
final buildinq permit clearance and under the Uniform Building Code the stack cannot be used until after such cleararlce.
The question of whether or not to condition the use of the stack
on solving the fallout problem is solely one of policy. In fact, the original. conditions recommended by the Planning Staff had no
such requirement. A review of the record indicates that the
condition grew out of concerns'expressed.at the public hearing and was added at the express direction of the City Council. The Planning Commission recommended adding a condition requiring the APCO to be satisfied that the problem was solved before the stack
could be used. The City Council concurred and further modified
the condition by adding the requirement that the City Council also be satisfied.
The record of the hearing seems clear in regard to the Council's
intent in adopting Condition (HI. One member of the Council was
of the view that the problem should be solved before the stack was
even approved. One other member of the Council expressed the view that the condition of approval would prevent the company from using the single stack before it solved the particulate problem. The
best indication of the Council's intent can be found in che finding of Ordiriance No. 9456. Section 8(C) of the findings in part
provides :
. has been "contrOlled" before Encina 5 and the stack can receive4
e
"Unless this ordinance is amended, the fallout
problem will be solved prior to the use of . Encina 5 and the stack".
I find no ambiguity in Condition (H) but to the degree some might
be deemed to exist, it should be resolved by reference to the
Council's intent expressed in the findings. The quoted portion
of which seems to me to speak €or itself.
While it was the Council's policy choice to impose the requirement in Condition (H), it was done by ordinance after public hearings.
If the Council wishes to materially change that requirement, it
should be done by the same process. -
SDGSIE has suggested to me in writing that it is unnecessary to proceed by way of amendment, in that Condition (H), of Ordinance No. 9456, can be changed by resolution. I find the authorities cited in support of that.position to be without merit as a
matter of law.
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SDG&E has also suggested that a resolution is appropriate because
the ordinance is ambiguous. They offer that ambiguity may be
found because Condition (HI does not mention Units 1 through 4
and does not distinguish between commercial use and use for
testing purposes. These suggestions are also without merit. The record indicates that Condition (H) related directly to Vnits 1 through 4 since they were what was causing the problem the conditic was intend.ed to resolve. In addition, while Condition (H) may not mention Units I through 4, Ordinance No. 9456 certainly does. Condition (I) expressly provides that the four stacks on the exist-
ing plant be remgved, "...not later than.eight months after the
Building Inspector signs the final inspection for the 400-fOOt
contemplated that the four existing stacks would not be removed until after the 400-foot stack and Encina were complete. If that
was in error, or if construction plans have changed, the problem
can be corrected by an amendment.
SDG&E is correct in their observation that the ordinance does
not differentiate between testing and. commercial use. The
ordinance simply prohibits the "use" of the stack, I find no
ambiguity in the word ''use;. In.any case, SDG&E is not request-
ing permission to test the 400-foot stack but-to place it into
full commercial use for Units 1 through 4. While there may be some doubt whether or not the prohibition against ''we" of the
stack proscribes testing, that qxestion is nct presented here
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' stack.. ." This condition and the record indicate that it was
. where the request is for use.
If the City Council is not satisfied the fallout problem has been
motion to deny SDG&E's request.
If the City Council is not satisfied the fallout problem has been
controlled, but finds merit in SDG&E's position that they should
be allowed to use the stack for Encina Units 1 through 4, the proper way to proceed is to initiate public hearings to consider
an amendment to the Specific Plan (SP-144) and Condition (3) to
so provide.
The Council also has the option of finding that the fallout probler! has been controlled. The determination as to what constitutes
"control" of the fallout problem is, of course, one for the Council
discretion. Although SDG&E has not requested such a finding, and
the APCO is apparently not prepared to make it at this time, there
is, in my opinion, sufficient evidence in the record to support SUC
a finding, if it is recognized that "controlled'' is somethinq less
than "solved" or "eliminated". To make the finding the Council
intent in Ordinance No. 9456.
controlled and wishes to enforce Condition (H) I your action is a
should satisfy itself that "controlled" is consistent with their
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3.
*I . 0 .. In reviewing the Uniform Building Code with the Building Director
it appeared that one additional option may be available. Section
306 (d) provides that:
"A temporary Certificate of Occupancy may be issued by the Building Official for the use of a ?ortion or portions of a building or structure prior to
the completion of the entire building or structure".
As previously noted, the stack is considered by the Building
Director to be a part of Encina 5 for building inspection purposes. The Building Director has indicated if it could be found that the
stack was complete, safe for use an2 in full compliance with the code and if the Council concurred, a temporary certificate night be issued.. Such a certificate could be limited to use for Units 1
through 4. 0
There are several problems with this option. The primary problem
is whether or not the use proposed by SDG&E can be considered
temporary. The evidence presented to the Councii indicates that the conversion from the four existing stacks to the 400-foot stack may be permanent and irreversible since the small stacks will be removed. It is doubtful, in my opinion, that we could-
successfully revoke a temporary cccupsr_cy should that become necessary. Further, the Building Director indicares that in most cases where temporary occupancy is used the City alims
occupancy pending clearance of minor technical problems where
the City has the ability to pull utility meters and terminate the use if the building is not completed in full compliance
with the code. SLich would not be the case with the stack. Finally, although issuance of a temporary certificate may be
legally possible under the Building Code, the Council would have
to be satisfied that such action was consistent with the intent
of Ordinance No. 9456.
CONCLUSIOTJ
Condition (8) of Ordinance No. 9456 which precludes the use of the stack until the fallout problem is controlled to the satisfaction
of the APCO and the City Council seems to me to be clear and unambiguous.
contention, that the condition is ambiguous and can therefore be "clarified" without the public hearingsnecessary to amend the
ordinance is not well taken. If the Council determines to either
The condition should either be enforced or changed and the proper way to change it is to amend the ordinance. SDG&E's
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b 0 .. deny the request or initiate public hearings to amend the ordinance,
that action can be taken by motion at your Noven5er 29, 1977
meeting. If the Council wishes to elect one of the other cptions
discussed herein, I recommend referring the matter to the City
Manager for a further report since they involve either the operatior of one of his departments or that of another governnental agency
and those aspects of the problen contain certain policy elements
beyond the province of your attorney which nay require additional
consideration.
VINCENT F. BIONDO, JR. City Attorney
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Attachments
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. ORDINANCE NO. 9456 .
AN ORDINANCE OF TfIE CITY COUNCIL OF THE.CITY
OF CARLSBAD, CALIFORHIA, ANENDING ORDINANCE -
NO. 9279 BY THE ANENDPENT OF THE SPECIFIC PLAl4
ADOPTED THEPZBY TO PERL'IIT THE CONSTRUCTION,
SUBJECT TO CERTAIN CONDITIONS, OF A 400 ,FOOT
SINGLE STACK TO REPLACE FOUR EXISTING STACKS
AT THE ENCINA POWEEZ PLANT ON PROPERTY GEHERALLY
LOCATED PEST' OF INTERSTATE 5 MGi) SOUTH OF THE
* AGUA HEDIONDA LAGOOX (SP-2-44 (B) ). APPLICaNTs
S-kN DIEGO GAS & ELECTRIC COP€P2WY,
Id
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The City Council of the City of Carlsbad, California, do
.- ordain as follows:
SECTION I: That it does find. and- declare as- fullsws :
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the matter was rererred to the Planning Cominission for public
hearing-
3. A duly noticed public hearing was held before the
Planning Cotmission at the time and in the place specified in
said notice on January 28, 1976 and'conti$;ued to ?.larch 24, 13
zit which tine all interested persons were heard- f
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4, The applicant has conplied with the PuSlic Facilit
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El,cinexl.t: of the General Plan and has.provided the necessary
. information which ensures ,Public Facilities ~ill be availah
concurrent with need. . .. -5 -. :
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.. . 5, The subject application.has complied wit'n the reqr:
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I ments of the City of Carlsbad "Environmental Protection Ordir
of 1972" in tha-t an Envirormental Impact Report on the projec
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was certified in 1973 and has been fully supglenenked with
additional current information which constitutes prior conpli
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In acidition, an EIR for the entireirclated Encind %project i
certified by the Pcblic Utilities Conmission actinq as lead
agency on the' project has been consT'dered,
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' approval of the applicant's request..
7. That a duly noticed public hearing was held befari
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c ., City Council oh April 20, 1976. .. .
the testimony and. arguments,
. 8-. At said public hearing, 'upon hearing and consi6:er
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if any, of all persons who desi
.-to be heard, the City Council considered ail r'actors -relatin
the Specific Plan iben&xtent and! made the. following findings
factr
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(A) All conditions of City Council Ordinance 9279 hav been coinpl.icd with 2nd this amendment is consistc
. wli-tfi said orciinance and .the provisions of the P.-U
The 400-foot stack is necessary to provide an eff
i-ne-thocl of dispersing the emissions of the Enciria
.Po;.!cr p3:ant as required by -the State Air Resource
Eoard ancl becalise of its relationship with Encinz
vii.1I improve the overall cpality 05 air in this 2
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(C) SDG&E has indicated that some of the corrosion darn
"fallout", in the vicinity of the San Diego Gas &
Electric Company Encina- Power Plant (more. specific
the Terraktar Area) is probably started or caused- b
particles from the Encina'Plant. SDG&E has accept:
responsibility for such damage and further stated
they will meet with individual Terramar residents
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resolve the damage claims and that they are-also
develop a work program that will assure the City a
County that necessary corrective action will be ta
- working with the Sari Diego County APCD staff to
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by the Company.. Unless this ordinance is amended,
the "fallout" problem will be solved prior. to the
use of Encina 5 and the stack,
(D) The approval of this amendment, with conditions, w
improve air quality in the immediate vicinity of t
plant.
. (E) To the extent there are adverse environmental effe to the project, they will be mitigated by the con-
ditions of approval.
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(Fj The identical project was approved in 1973and the
conditions surrounding that approval have not mate
approval. -
ally changed and the applicant has relied on such
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(G) The construction of the' stack wLl.2 be accomganied
by the removal of the four existiiq stacicsand a
- screening of all duct work-so that the aesthetic e of the plant with the 400-foot stack wi
than the existing-.four s'tacks,
The project is a logical extension of an .-
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, use located in an area already committed to heavy
This amendiaent is consistent with the Carlsbad Gen
Plan and all applicable specific plans.
public utility operations, _<
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(I)
SECTION 2. That Ordinance No- 3279 is amended by -the
amendment of Section 2 of said ordinance to replace the Spec2 -_
Plan Map attached thereto w'ith a revised plan labeled SP-1443
Exhibit A, cthted October 10, 1375, on file in the'Planning
Qepartment and incorporated by reference herein, which is her
.- 1 ..- t ; ' adopted,
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SKCTIOM 3: That Ordinance Eo, 9279 is amerrdeci by the am:
ment of Section 2 of said ordinsnce to add Condition No- 14 to
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.. 1 read as 5OllOWS: I "14- In add-ition to the above condikions, the revised pl
tions of the specific plan which permit theconstru
of the 400-foot stack and the rmovai of the four
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the revised spncific plan SP-1443 and shall be sub
to the following conditions:
(A) All applicable requirements of amy law-, -ordi
or regulation of the'state of California, Ci
of:.Carlsbad; and any other governmental enti
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It (B3) Hilt groun2 lighking siiali be ari-angsLt~ ref
away from adjoining properties and streets,
(C) Any. mechanical and/or electrical equipent t
located on the roof of the structure shall b
screened in a manner' acceptable to the Plann
Director. Detailed plans for said- screening
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$+ 161 $c>p /?-< +>GO
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shall be subnitted, in triplicate, to th2
Planning Director for approval.
Air pollution equipment capable of rnonikorin
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placed in service not later. than si:: months
number of stations, type of equipment and IC
tion oE stations shall he to the satisfactic
the APCD Control Officer and the City osr' Car
Should the Air Pollution Control O€Eicer of
San Diego County Air Pollution Control Distr
' require addit_ional air quality or emissions
monitoring equipment and funds for air cluali
' lowing the etfective date of this ordinance.
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the applicant shall supply said equipment ar
funds as deemed necessary by the Air Pollutj / Control Officer, The cost oE said equipment
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shall not exceeci $150,ODO1 The requested fur
€or air quality analysis shall not exceed
$50,000 per year- .
Any future measure requiked by the San Diego
County Air Pollution Control District to lesz
-or otherwise control emissions from %he Encir
Power Plant are hereby incorporatedkas a barf
of this Specific Plan- Anendrnent and SDG&E shz
corn~Iy fully therewith. The costs 0-f such
(E)
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measures shall be borne by SDG&E.
(F) SDG&;E krill obtain a report 04 compliance fro?
City staff regarding the conditions of this
ordinance and fron the San Diego County Air
Pollution Control Officer regarding conplianc
and with air- quality standards, and forward 1
the City Council five years from the date of
with the applicable conditions or' the ordinal
.', . . -- - . this ordinance or as otherwise required by *-SL
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'motion of the City Council, or the Planning I Comrrtission. The Planning Commission and Citl
Council. shall review the report tsith reqard I
conformance to the con-citions of this ordinal
and to regulations required by other-%pplical
regulatory agencies, including, Sut not lini
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* a method of air emission dispersion, the 400 stack shall be removed at the applicant's ex
The applicant may request-an amendment' to th
specific plan to provide a reasonable extens
the period for such removal-
(€1) The applicant shall make a formal commitment conduct the studies necessary to determine t.7
operating practices and/or emissions control devices are capable of eliminating the parrki
"fallout': problem.' .A schedule for the conpl
. of the stuclies shall be ostablished which is
sakisEactory to the Sanbiego County Air Pol
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Control nis tr'ic t Officer, the Air Pollution
Control District Hearing Board or Court of La
SDG&E shall fully 'conply with the abatement
order entered in petition Eo - 607 -
The applicant shall further agree to p~y clai
for property damage resulting fxom the "zallo
problem until compliance wikh the abktQment o
is achieved.
The particulate "fallout" problem shall be cc
trolled to' the satrs2action 02 th e Cricy Cour,c
-of thG City of Car-Lsbad and 02 the Air P-ollut
Control Officer prior to the final building r:
Not later than eight months after th2 Builhin
Inspector signs the final- inspection for the
400-foot stack, the four stacks on the existi
Encina Power Plant shall be coxpletely renove
(J) SDG&E shall file an annual report with the Ci
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I . *clearance +or Lnc'ina 5 'and the single stack, *
(I)
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Council regarding improvements in plant and
opxa5Rg grccedxres during the preceding ye?
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resulting from the operation of Encina Units
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' (X;) SDGEtE shall operate the plant in full compli;
with all air quality standards as-are or mzy -- established by the APCD--> If the nonitcring st;
indicate. the stand3rds are being exceeded at
. time, SDG&E -shall campLy -with.-aLI dbectidns
APCD to reduce, through any reasonable means,
pollutants from the plant'-
(L) In the event SDG&.E files for-a variance or 01
fom or' administrative or legal relief from i
' requirements of APCD, they shall concurrentlj
forward a copy of any such filing, or any SUI
sequent communications in connection therewil
to the CiLy of Carlsbad, j
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SECTIO>T 4. That the thirty-five €oot height limit estat
ed by Condition No. 5 of Section 2, of Ordhance No- 9279, slil
not apply to the 400-foot stack or the duct work and. screeninc
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be constructed on top of the main generation building in conjt
tion wj-th the construction of the stack and the removal DE the
four existing stacks,,’’ b
EFFECTIVE DATE: This ordinance shall be effective thir-
-e days after its adoption, and the Ciky Clerk shall certify to
the adoption of this or2inance and cause it to be published
at least once in the Carlsbad Journal Githin fifteen days a€ti
its adoption- an adjourned INTRODUCED AND FIRST EAD at / regular meting of the -
Carlsbad City Council held on the23thday of April . r 19 ,-
and thereafter
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PASSED AND ADOPTED at a regular meeting of said Council
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>A;!4;&&d Y flb/A - - ILAR~ART E- A~AI~S, Citty Clerk
(SEAL)
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ASSESSOR'S PmcEL NUMBE
DoOK PAGE
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