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HomeMy WebLinkAbout1982-03-02; City Council; 6919; SDG&E TEST BURN OF MEDIUM SULFUR FUEL AT ENCINACITQ~~F CARLSBAD - AGENDQBILL Based on information from the Air Pollution Control District (APCQ), Staff is recommending that the City Council find SDG&E' medium sulfur fuel test burn consistent with condition 6 of Specific Plan SF-144. Item Explanation In approving :3DG&E's request (letter dated February 10, 1982 attached) the Council must determine whether the proposed eight week test burn of medium sulfur fuel conforms to Specific Plan 144 for the Encina Power Plant. If the Council finds that the test conform with SP-144 then na Environmental Review is necessary and the tests can begin immediately. SDG&E will only be burning the medium sulfur fuel in two of it: burners. Natural gas will be burned at the same time in the remaininq three burners. with this combination of fuels the existing pollution standards will not be exceeded. Pollution Control District (APCD) will be closely monitoring tf test and may shut down the operation if standards are exceeded (please see meno to City Manager dated February 19, 1982 for The Air further informat ion) * Environmental Review Staff feels no environmental review is necessary at this time. Please see rnerno to City Manager dated February 19, 1982 for no information. Fiscal Impact There will be no fiscal inpact to the City of Carlsbad from th project. If an EIR is required some staff time will be utili2 in process inq. n e 0 SAM DIEGO GAS €L ELECTRIC COMPANY P.0 BOX183i SAN DIEGO. CALIFORNIA 92112 (714) 232-4252 bj FILE NO. February 10, 1982 ,.*A i + $'Q< 13 4 3 & Honorable City Hall Mayor Packard cIga2d f& (B cpp 1200 Elm Avenue Carlsbad, CA 92008 RE: TEST BURN OF MEDIUM SULFUR FUEL, a c.!$!T C$fif-,, '9 .-,*e .. ENCINA POWER PLANT \x -- \ -. l&' Oc 6* The purpose of this letter is to request the City's Dear Mayor Packard: approval to conduct a test burn utilizing medium sulfur fuel at SDG&E's Encina Power Plant. As you know, one of SDG&E's major expenses.is cost of fuel. If we can reduce the price o of reducing' the increase in rates. For a year now, SDG&E has been evaluating the benefits of changing its fuel oil specifi cations. By going to a slightiy higher sulfur content in the fuel mixture, .we could potentially save miliions of dollars over the Iiext several years. oil, such benefits will. flow through to the ratepayer in term Ili October 1981, SDG&E filed a request with the APC to test burn sulfur fuel having >2 content higher tha-n 0.5 percent fuel. By letters of October- 21 and November 12, 1981 the APCD approved a test burr, not to exceed .75 percent sulfu under seven conditions. The APCD approval was pursuant to th equivalency provision of Rule 62 which is the same ruie that sets forth the standard of 0.5 percent sulfur by weight. The most important point concerning our test burn o 300,000 bbl-sf over a period six to eight weeks of testing, i that: SDG&E is required to keep the sulfur emissions exactly equal to what is permitted today, in other words, there will be no more sulfur einissions during the test than what SDG&E F into the air using 0-5 percent sulfur oil. This can be done by having some Encina units on natural gas while other units are on medium sulfur oi.1. SDG&E feeis confident tliat the sli increase in sulfur content of fuel oil will riot affect the ai quality. In adsition, SDG&E is required to terminate the tes burn at any time the APCD determines equivalent control is nc being achieved. Moreover, SDG&E believes that burning of medium sulfur- fuel urlder +he equivalei.icy provision of AFCD Rc 62 is consistent with the laiiqiiage ''upon being consumed" of Condition 6 cor,taincd in thz Specific Plan approving construc of Ericiria Unit 5, aiid/or satisfies the concerns which ConCiiti was intended to address. EXHIBIT A 4 0 Honorable Mayor Packard -2- - February 10, 1982 SDGtiE hereby requests your approval to test burn medium sulfur oil (.75 percent sulr'urj under the conditions imposed by the APCD, and that the test burn is consistent with Conditioil 6 or' the Specific Plzn. As with APCD, your office would be notified 30 days prior to the actual schedule of the test burn. Sincerely, -fmAA---dL- E. N. Gabrielson Manager Licensing & Environmental EMGjcp cc GABishop PJCIberhaus Vince Biundo Frank Alashire L c 0 0 PlEMORANDUY DATE 2 February 19, 1982 TO : Frank Aleshire, City Manager FROM : James C. Hagaman, Planning Director 1' -J SUBJECT: San Diego Gas and Electric Co. Medium Sulfur Test Burn SDG&E is proposing a test burn of medium sulfur fuel (.75 sulfur at the Encina Power Plant for a period of six to eight weeks. The Council is being asked to decide whether this test is in con- condition 6 of the specific plan which will determine whether or not an amendment is needed. Condition 6 states: formance with Specific Plan (SP-144). The main issue involves All fuel storage tanks shall be recessed and used for those oils which, upon being consumed, shall not have a sulfur content exceeding -5 per cent; being that percentage com- monly associated with the term "low sulfur fuel oil." This condition was placed in the specific plan based on rule 62 of the Air Pollution Control District (APCD). APCD which is governed by rule 62 has already found that this test is consis- tent with its rules and regulations. Since condition 6 is based upon APCD regulations and APCD has approved the test, it would seem logical that the test conforms with section 6 of the speci- fic plan and no amendment is needed. If the Council finds that the test conform to condition 6 of thc specific plan then no environmental review is necessary because there is no project (no amendment to SP-144) as defined by the California Environmental Quality Act (CEQA). This interpretatioi is based on a similar decision by APCD which is much more equip- ped than the city of Carlsbad to decide air quality issues. CEQA does indicate that if significant public controversy exists on a project or if an action does have the ability to create sig. nificant impacts on the environment an EIR should be prepared. From our communications with APCD we do not feel this applies to the SDG&E proposal because technically no project exists, only a test. Pollution standards set by APCD will not be violated, and APCD has the authority to shut down the test at any time their stan- dards are exceeded. An EIR should be required if SDG&E is to us medium grade sullfur fuel oil on a long term basis. EXHIBIT B A 0 0 Recommendat ion Based on input from APCD, staff is recommending that the Council 144 and does not need an amendment to the Specific Plan. JCH:CDG:rh find that SDGGE's snedium sulfur test burn meets the intent of SP- -2- 0 0 CONDITIONS In a phone conversation with Dick Smith of the Air Pollution Control District (APCD) on February 23, were applied to the SDGEE test burn. follows~ staff was informed that several conditions The conditions, in effect, are as 1) That monitoring of the test burn will be required "at the stack," That the test burn must not exceed existing standards currently applied to the Encina Plant (equivalency). Sulfur content in the proposed test fuels shall not exceed .75 percent. If at any time equivalency standards are exceeded or acid fallout These comments were received orally. Actual conditions should be available in time for the March 2, meeting. 2) 3) 4) occurs, the project will be shut down, CG:m 0 79 I _- It. J. SO~!!I,,~: )'I t !lir Polliit~(;r~ < t rm-x rn~r~fli ruz-wS-z,rr& < Gcto'kr 21, 1981 Edwd M. Gabrielson Supervisor, Licensing & Envimmental San Diego Gas E Electric hpmy P.O. Box 1831 San Diego, CA 32112 * Eased on yow letter of October 13, 1981, 2 . 11+ .w>li Jc termin-> ' : prcposed test program ma57 be undertaken ~JI>:,L< of Rule 62(c), provided ce?tzh conditioris <?y? v>t. as follows: 1. San Diego Gas E Electric shall cali!lr i ( c~11tii y the : i o eqiiivalenc., bz JdzLim ;?lese cor,!!' in the tall stack. The emissions frm Ib tall stack shall hi. monitored for SO:, continuously thm$m~i4 i li(> rxqx)sed tes" z~d L+.~> results recorded. Tnese remxls sFial1 lv rr dvajlahle to thc District upon request, 2. The hourly quatities of sulfur burwd CJI,~ I I '1 )' exceed 0.' / !')/-9f E heat input. Liquid fuel sulfur contt-n' c tu1 I not exceed @.'Ir)' hj wc: Fuel usage for each boiler shall k recwrcd daring the test w1d rrxlt availale to the District upon request. 3. 4. The District shall conduct such emissia1.; tc s a's it detc dp?ro;)riatz during ~iie iesr perid. reimburse the District for this testb,g. If at any the during the test propam the iI.:'Xi detemkes ec;liivcil.-ni contml is not being achieved, the test f) jm shall be term;. ..-ti 3 immed iat e ly . The test program you aze proposing will 1~- as described hi v-(x kttc of October 13, 1981. As noted i; thir ! I ;t I, ')an Diego i; 1 ic -3 will notify the District prior to ear>) ii '1 f ' tcl-,t Iucl. :)r~l ; i' ':a, t Elect- 5. 6. - AIR POLLUTION CONTROL t)ISTRiC?' (714) 565-5901 9150 Chesapeake Driie. San Diego, Cnlifornin 92123 W - I3wad . M . Gabrielson -L- c) Octc.h-::t: , r' 1 , .I 5 3 :i SD(.;GE b In addition, the following are proposed by 1.1~ iiis 1~r.c-t as new cor-i:i'i:ti 0: IS for present Encha Pennits to Operate (lkmibw!:~~ ?91., '792, 793, 1770, ax1 5238). Any modification cf fuels usrd w1-1.i ci.1 Ih:; 1-b:: potential to increase emissimns shall .ve:.!ui I '$:, j;: ., r:.!- -...vi.tten ap;.;i. from the APCD. Upon receipt of San Diego Gas E Electric's wr,.l.tt I1 acceptance cf' -?E above- conditions, the District will. modify the Thriiia ;ic;:ility ~rmits xcccrdIrig1y. * r ,_,___. - --'- '.' .-.?-A // i-:*7ddg\-.,,, \- VILLE Eiir Pollution Control Officer RJS: JML: vch ... 1 0 R J :> $1 *,,* pq]l,-[ , ( I ‘I <,* 1 :. 58 11 .. 8: a‘N~X~”l- I Novehr 12, 1.981 €‘ward Y. Cabrielson Supervisor, Licensing G Lr!vim:mn:a? S& Diego Gas E Electrlc &r,pr,y P.O. Box 1831 San Diego, C4 92112 IEDIW SULT R 11 This is in response to your leIter of OC~O?J<~ 3 Q, , 1 “8 1 . SXIE’s accepance of co:-dlt!or.s far the ~:lt f? 1 hply that ihis fuel can be ased on a reguI(~: eqlii-mlency is explicit tc SDXZ’s requec Yow request to expand the sco3e of this atteqxt to incrementally Sen TOE than rajac ;I You suggest that condition 2 b2 chinged t content of the fuel not to exceed 0.75 p-r’ to Urlit No. 5. sign;f;cant changes &I the sulfur content Encina plant. The supplier of Rolofite ad(:!:t ;\>ti irvI:c.a:cs that likely be tolerable but tllere -:s concern timl ti (3 irc’r7Ccxe I’ropc this tolerable limit. Of prticulm cmcer ic, 7 &y;uacjr of monitoring in the exhaust stach at Eicim. At f ‘’;I ? i ,t~ have bee:, cr\~idm;cd the plant while burning the 0.75% sulfur fuel oi 1 d: o if it can k :,kc:+.? th; there m2 T?C: zdve-se ALLY ;m7ar+c --- m acid falloi;t ~..~itf:c :t \7: cl&icr! ~i T?;? ST- the AP2D’s Rules and Regulations, then the 01 s rric t wi’ : consider allov;jn; sulfL contents greater than 0.75 pxent. It is premature at this tim for the District to consider changing pm~it tc operate conditions on a pernext basis. l”nert.lore, the last condttictn stal irl the October 21 response to you has been delt1:c-J. necessary to require that the ::<strict he ~KIPXM~~P!;, a:\:,rised of ci 1 , a-tion: assxiated with fuel use at Dicina. As a result of the abOve, the :allowing coi~~lir j, vi program: 1 ndst e kiy aetermi I,~IT ,E, a iin1te-c: teeJ? pi‘” €’rankly, there is reason Hcmever, it wi;i ’x- wi I! IF hp~sr ! (I. t!!e tr AIR POLLL‘TlO.’\, COK‘I’KOI, UiS f I(i( 7 9150 Chewpeahe Drive. San Ilicgo. (’.ti11 o~I;~<I 92 120 (714) 565-5901 E.'wul u d .I. w Gr&rieisoiL 1) -2 - e Nover;3j.;r' I?, 15 * r .-I, 1; t., 1. SZTI Diego &s & Electric sl;;i:: cdibr, the tail stad,. The erisSi:)i;s fro!:. Jci:, f~?~ SO contijluo!_ls15~ thl\3 )\'L]i t-hc 1 ,! >, , , , ' .. 2 ~lzordtd. 'l'h?se reco:+:; request. 1"ne holzly quantities of scifl;n b;une!i :<,jj:jj .I heat input. Licpld fuel c2nter.t shall If SKLE CZ, show by stack test, to tht Cmtml Gificer that eqilivcz,lency of Rx.1 c sulfur level of 0.75 perccr::: ? then tht: ailow the use of fuel exceeding this 3. 2., 3 md 4. The total dwation of fuel burning which exceeds the lhits of hie 6?(k shall not exceed eight (6) weeks as spciTied LT; SIGlE corresmr;::ence cia October 13, 1991. Fuel usage for each bcller shall be r.et'c:-)..l available to the Cistrict qmn req~est. 2. 3. ,, 1. 4. ,i l!x::,j-, .:]?e rest ;-if! i:cl ii: 5. ?:%e Djstrict shall cii et sxch efis:,j:~y ' . i ., 1 !, : i r]( 17 ,~.,+ Ti . :; f, qprop,niate during the tes; pericd. :;<:I: I ;I ':' , .! .. reimburse the District for this testir;!;. If at arly tim duriig the test pmgm detemiines equivalent control is not r? the limiting exhaust gas pE is occlmr- %mediately. 6. 7. The test progrm you me pmpsing wi.1 1 :I, ,i:: :i (ly.j!,:yj in y(;!l! #,,I : I' \, - 3ctober 13, 1981. will notify the District prior to each cst? of test fuel. As noted in this le? t PI', :;<ill j.cgo cas ari(j !.: j c 'c ' :. t !:E you have any questions, contact Can Spwr\ (1: ('i I ii) 565-3907. by$& R. J. semmv~m Air Pollution Control Off: 7 cer RJS : vch * (I T 3, J.. LL February 19, 1982 F LE NO Ms. Lee Rautenkranz City Clerk City of Carlsbad 1200 Elm Avenue Carlsbad, CA 92008 Dear Ms. Rautenkranz: As you requested, two copies of York Research Corp.' report: "The effect of a Magnesium Fuel Oil Additive on Particulate Emissions", dated December 9, 19'77, are enclosed. If you decide that additional copies are needed please give me a call at 235-7778. S inc er e 1 y , L. J. Brunton Supervisor, Eilv<. iiegulation Licensing & Environmental LJB/cp Enclosures (2) cc FWDeVore EMGabrielson GAB i shop POSTOFFICE BOX 1831 SAN DIEGO, CALI=091\ A 321 12 TELtDt-O\t 714/232 4252 I 0 r-y June 16, 1981 FILE NO Mr. Bill Baldwin Assistant City Manager City of Carlsbad City Hall 1208 Elm Avenue Carlsbad, California 92008 Dear Mr. Baldwin: Ordinance No. 9456, Section 3(j), dated May 4, 1976, requires SDG&E to file with the City Council an annual report regardinq improvement in plant and operating procedures during the preceding year which reduce the emission of air pollutants re- sulting from the operation of Encina 1-4. The fourth such annual report is attached herewith. Should either you or the Council desire any further infornation, please contact me at (714) 235- 7766, or L. J. Erunton on my staff. Sincerely, d P -4 L4 E. M. Gabrielson Supervisor Licensing & Environmental Department /z Attachment cc: R. Sommerville - APCD R. Beckman - Carlsbad City Public Works POSTOFFICE a3X 153i.SAh 3IEG3 CAL '08hA 32iiZ.TELE?-'Oh 7ir/232-!;32 e a FOURTH ANNUAL REPORT TO THE CARLSBAD CITY COUNCIL REGARDING EMISSION REDUCTION AND OPERATING IMPROVEMENTS AT THE ENCINA POWER PLANT SAN DIEGO GAS b ELECTRIC June, 1981 m e In compliance with the City of Carlsbad Ordinance No. 9456, Section 3, 14(j), San Diego Gas & Electric is submitting this fourth annual report to the Carlsbad City Council. The report was required to relate "improvements in plant and operating proce- dures during the preceding year which reduce the emission of air pollutants resulting from the operation of Encina Units 1, 2, 3, and 4." As a preface, subsequent to completion of Unit 5 and tall stack, the plant has returned to a routine operating mode that has been characteris- tically clean from an air quality viewpoint. operation approaches the optimum in terms of effi- ciency and few significant changes are still occurring in either the plant or operating procedures. At the same time, the contribution of the emissions from the Encina Power Plant to local air quality concentrations has been substantially reduced. Further, there have been no fallout claims filed in over a year. The 0 c INCREASED COMBUSTION EFFICIENCY A primary ongoing goal of the SDG&E operations divi- sion is to squeeze more electricity generation from each unit of fuel combusted. late directly into fewer barrels of fuel required and lower emissions to meet customer electricity demand-s.Due to its more design, Unit 5 is the most efficient unit on the SDG&E system; and it's addition to the Encina Plant resulted in a considerable improvement in overall Plant efficiency. Durinq 1980, the several periodic maintenance activitic at the plant were scheduled to optimize the increased efficiency that is often aprimary purpose of those activities. The most important of these was the major overhaul of Unit 1. In addi- tion, the boilers in Units 1, 3 and 5 were chemically cleaned and a combustion instability in Unit 4 was eliminated. The high-intermediate pressure heater in Unit 2 was also renlaced. Improvements in combustion efficiency trans- The combined improvements in efficiency resulted in a savings of 329,532 barrels of fuel in 1980, over that which woulc have been required to generate the same electric power in 1975. This represents a considerable savings, especially when the present cost of a barrel of fuel oil is well over $30.00 per barrel. As described in the previous annual reports, the Elec- tric Production Performance Monitoring Program is still continuir In review, the method by which the Performance Program is accomplished is the monitoring of performance for each unit sc 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. Operators make hourly comparisons of actual unit performance to the best attainable standards then take corrective action when appropriatt The operator can either adjust the control setting of the unit 01 request that maintenance be performed. INCREASED CONSUMPTION OF NATURAL GAS Due to a further increase in availability of natural gas €or industrial use, the Xncina Power Plant aqain consuned more gas in 1980 for its operations than it did in 1979. By the increased use of natural gas, less fuel oil is required, and therefore, emissions of nitrogen dioxide, sulfur dioxide, and smoke are reduced. The 12,542,490 million cubic feet of gas burned at Encina represents a savings to the ratepayers of $22.7 million over the cost of oil, had. that gas not been utilized. . e e The gas availability for 1981 is projected tobe 15% to higher than the 1980 volume. CONTROL OF ACIDIC FALLOUT As mentioned earlier, no fallout claims have been filec with SDG&E in over a year. A single claim filed in early 1980 was questionable, and if even partially the result of power plant emissions, the causes were not recent at the time, and probably attributable to some past event. This success in controlling the acid falloutis due to the three procedures as identified in the last annual report: 1. Introduction of a fuel oil additive to neutralize acidic fallout that is created duriny boiler Soot blowing in the boiler is done on a regular basis to reduce build up of material on walls of the boiler. combustion. 2. 3. Use of viscosity controllers increase the breakup of fuel into very fine particles for more complete combustion of the fuel. The costs of these procedures were about $302,000 in 1980, with the major component being the additive itself at $288,000. CONTINUOUS EMISSION MONITORS Although recent emission testingby the California Air Resources Board confirmed Encina to be operating in compliance with the emission limits, SDG&E will be spending about $1 millior in 1981-2 to install and operate continuous emission monitoring instrumentation at the Encina Plant. These instruments are re- quired by the Air Pollution Control District to continuously monitor nitrogen dioxide emission from each unit to prove com- pliance with the applicable regulations. These monitors will provide data for quarterly reports for the APCD.