Loading...
HomeMy WebLinkAboutSP 144B; SDG&E Wastewater Facility; Specific Plan (SP) (6)AIR QUALITY IMPACT OF PROPOSED UNIT 5 ADDITION AND 400-FOOT STACK, ENCINA POWER PLANT, CARLSBAD, CALIFORNIA County of San Diego Air Pollution Control District June, 1975 Richard J„ Sommervi1le Acting Air Pollution Control Officer Executive Summary The San Diego County Air Pollution Control District's (APCD) air quality impact analysis of the proposed 292 MW steam turbine electric generating unit and single tall stack at the Encina Power Plant in Carlsbad, San Diego County, is outlined below. The analysis has two subdivisions: (1) Ground-level concentration of pollutants in the plant vicinity, and (2) Basinwide air quality Air quality with and without the proposed addition was considered,, Other considerations and technical assumptions are included as appendices to the report, Wi?<th or without the proposed addition at the Encina plant, basin- wide air quality with respect to sulfur dioxide and suspended particulate matter will degrade in the San Diego Air Basin; this degradation will accompany increased demand for electric energy generated in fossil fuel-fired power plants and increased use of oil fuel replacing natural gas fuel in these plants. Major degradation will occur with respect to sulfur dioxide; the de- gradation with respect to suspended particulate matter will be minor. However, the proposed Encina addition would slightly decrease basinwide degradation and would markedly decrease ground- level concentration of pollutants downwind in the plant vicinity, Data on fuel projections and energy demands supplied by the San Diego Gas and Electric Company (SDG&E) were used by the ,APCD to aid in calculating emissions to the atmosphere from SDGSE's power plants in this report* The APCD neither affirms nor denies *» SDGfrE's projections and estimates, K SDGSE's projections represent overestimates of actual need, the APCD-calculated emissions from power plants will be lafger than actually realized; the converse of course is also true. The degradation of air quality with respect to sulfur dioxide is of concern to the APCDo The ARCQ position is that any further SDG^E increase in oil-fired electric generating should be accompanied by measures to reduce the quantity of sulfur dioxide emitted from power plants so that the level of sulfur dioxide in the ambient air does not significantly increase. 1. Ground-Level Concentration of Pollutants in the Plant Vicinity *- > (a) Ktethod of A.na 1 ysis The existing Encina power plant and the proposed modifi- cation were analyzed using the User's Network for Applied Modeling of Air Pollution (UNAMAP)„ Ground-level concen- trations of sul"fur dioxide, nitrogen dioxide, particulates, carbon monoxide and reactive hydrocarbons were determined for a variety of meteorological conditions specific to the San Diego area, Both the existing and proposed facilities were examined under worst-case operating conditions, assuming maximum power generation with 100 percent usage of 005% sulfur-content oil« Conclusions UNAMAP analysis of the existing facility (Encina 1-4) indicates that maximum ground level concentrations in the vicinity of the plant by themselves may exceed state or federal 24-hour ambient air quality standards for sulfur dioxide0 Air quality impact for nitrogen dioxide, parti- culates, carbon monoxide and reactive hydrocarbons will be j- mini ma1„ A similar analysis of the Encina plant with the proposed modification (an additional boiler and combined 400-foot stack output) indicates that maximum local ground-level concentrations for all pollutants of interest which result from plant "emissions are slight, and localized effects of , th,e facility on air quality would be insignificant with the proposed modification. A tabulation of concentrations obtained with the UNAMAP analysis and a comparison with air quality standards follows. MAXIMUM GROUND LEVEL SULFUR DIOXIDE CONCENTRATIONS ATTAINABLE IN THE ENCINA PLANT VICINITY BY UNAMAP ANALYSIS CMICROGRAMS PER CUBIC METER) Plant Configuration Existing Plant. Proposed Plant, 5 units with tall stack Concentration 406 274 x Air Quality Standards 1 Hr, State - 1310 3 Hr, Federal - 1300 24 Hr, Federal - 365 24 Hr, State - 260 Annual, Federal 80 2 o Easimvide Air Quality (a) Discussion and Method of Analysis The Federal Environmental Protection Agency proportional model (Part 51, Environmental Protection Agency Regula- tions) was used to determine the effect of the Encina plant emissions on ambient air quality in the San Diego Air Basin0 The proportional model assumes that the level of air quality is directly proportional to the amount of pollutants emitted into the airc It gives a numerical value indicating the percentage of emission increase or decrease needed to reach a predetermined level of air quality, in this case a National Ambient Air Quality Standard (NAAQS)„ .It indicates whether or not an air quality standard may be exceeded or not exceeded, and the percentage of emission increase or decrease required to meet or exceed the standard,, The proportional model does not indicate to what degree or for how long an air quality standard will or will not be exceeded, (A diffusion model would give more information than a proportional model,, However, such a model has not been validated for basin- wide application at this time,) Only National Ambient Air Quality Standards (NAAQS) were considered for the pollutants emitted by the plant0 This was done because air pollution control require- ments for denying permits to new facilities are by federal law based on reference to NAAQS, (The San Diego County APCD did not apply these requirements when an authority (permit) to construct was issued for the Encina power plant addition because the requirements did not exist at that time,,) The only other air quality standards applicable to San Diego County are state standards; these are very close to NAAQS or when different are rarely exceeded, if at all. The pollutants covered in this analysis are oxides of nitrogen (as nitrogen dio- xide), sulfur dioxide and particulate matter,, Emissions of carbon monoxide and reactive hydrocarbons by the Encina plant were considered in. the overall analysis but were found to have no measurable effect on air quality. Emissions of all pollutants from all sources in the San Diego Air Basin (obtained from the latest Air Pollution Control District emission inventory), and current air quality data were used for input to the model for a base year (1974). For the years 1978, 1981 and 1983, estimates of emissions were made based on fuel usage and electrical energy sources available as reported by San Diego Gas and Electric Company (SDG§E), and on growth projections for other .emission sources. Emission factors (relating amount of pollutant emission to amount of fuel used) were .derived from emission tests of SDG$E boilers. It is assumed that SDG£E will continue to use fuel oils containing not more than 0.5 percent sulfur by weight. The increase or decrease in emissions from the base year (1974) to 1978, 1981 and 1983 was related directly to air quality increase or decrease for those years, and estimated levels of air quality were obtained. Using these levels, the model was used to determine a percentage that an emission level would be above or below the level required to exactly meet a NAAQS. The years 1978, 1981 and 1983 were used because (1) in 1978 the Encina plant addition will begin operation; (2) in 1981 the second San Onofre nuclear power plant unit will begin operation; and (3) in 1983 the third San Onofre nuclejar power plant, unit will begin full-time operation, and electrical energy for San Diego County will be available from the Kaiparowits power plant in Utah. While the San Onofre and Kaiparowits plants will not emit pollutants affecting NAAQS in the San Diego Air Basin, availability of their electricity affects the amount of fuel used by SDG$E0 Different plant combina- tions and modes of plant usage were used during 1978, 1981 and 1983 to determine effect on air quality. Cal- culation of emissions is based on SDG§E prediction of 100% usage of fuel oil in its plants after 1976. "Nominal" operating condition is defined as operating under SDG§E-determined normal conditions,, "Worst con- dition" is defined as operating with a boiler fired to achieve the maximum rated electric output of a power plant. (b) Conclusions Increased demand for electrical energy from fossil-fuel fired steam turbine electric generating plaints in San Diego County and the decreased use of natural gas in these plants will result in degradation of air quality with respect to sulfur dioxide and particulate matter, This will occur with or without the proposed addition to the Encina Power Plant, With the addition, the degradation will be slightly less. Since SDGSE power plants are the predominant emitters of sulfur dioxide in the San Diego Air Basin, the improvement or degra- dation of sulfur dioxide air quality in the Basin is directly dependent on electric power generation in fossil-fuel fired power plants. Since SDG§E power plants account for only about five percent of all particulate matter emissions, increased fuel oil use and more electric power generation will have minimal effect on suspended particulate matter air quality. Following is a tabulation of percentages by which air quality is different from standards for particular years, and combinations of power plant availability. Note: Negative values indicate that the air quality standard is not or will not be exceeded. The more negative the value, the cleaner the air» Positive values indicate that the air quality standard is or will be exceeded. The larger the value, the dirtier the air. A "0" value indicates that the air quality standard is or will be met; however, with any degradation, the air quality standard will be exceeded. 1974 (For Comparison) Nitrogen Dioxide Sulfur Dioxide -67 Suspended Particulate Matter + 44 1978 Nominal Conditions 1. Without the Encina plant addition -14 2. With the Encina plant addition -16 Worst Conditions (At Encina Plant) 1. Without the Encina plant addition -12 2. With the Encina plant addition -14 -7 •10 + 3 -7 + 52 + 52 + 54 + 52 1981 Nominal Conditions 1. Without the Encina plant addition and with San Onofre 2 -16 2 „ With the Encina plant addition and with San Onofre 2 -18 3. Without the Encina plant addition and without San Onofre 2 -12 4. With the Encina plant addition and without San Onofre 2 -12 Worst Conditions (At Encina Plant) 1„ Without the Encina plant addition and with San Onofre 2 -14 2. With the Encina plant addition and with San Onofre 2 -16 3. Without the Encina plant addition and without San Onofre 2 -10 4. With the 'Encina plant addition and without San Onofre 2 -12 -3 -7 + 17 + 14 + 9 + 21 + 17 + 54 + 54 + 57 + 57 + 55 + 54 + 58 + 57 Suspended Nitrogen Sulfur Particulate Dioxide Dioxide Matter 1985 Nominal Conditions V 1. Without the Encina plant addition and with San Onofre 2 and 3 and the Kaiparowits plant -22 -7 + 55 2. With the Encina plant addition and with San Onofre 2 and 3 and the Kaiparowits plant -24 rlO +55 3,, Without the Encina plant addition, and without San Onofre 2 and 3 and the Kaiparowits plant -4 +42 +63 4. With the Encina plant addition and . without San Onofre 2 and 3 and the . Kaiparowits plant -8 +41 +62 Worst Conditions (at Encina Plant) 1. Without the Encina plant addition and with San Onofre 2 and 3 and the Kaiparowits plant -20 . . +3 +57 2 „ With the Encina plant addition and with"San Onofre 2 and 3 and the Kaiparowits plant -24 -8 . +55 30 Without the Encina plant addition and without San Onofre 2 and 3 and the Kaiparowits plant -2 +46 +64 40 With the Encina plant addition and without San Onofre 2 and 3 and the Kaiparowits plant -4 " +42 • +63 10 Appendix 1 Local Air Quality Impact a Methodology, Considerations and Assumptions Introduction The localized effect of the existing and proposed Encina Power Plant facility was analyzed using the applicable programs of IMAMAP (User's Network for Applied Modeling of Air Pollution), and consisted of the following: 1) PTMAX: PTMAX produces an analysis of maximum ground-level concen- tration, and distance of maximum concentration for each condition of stability and wind speed. 2) PTDIS: PTDIS calculates downwind ground-level concentrations for a single source for various meteorological conditions specified by the user. Primary output of the program consists of the height of emission and ground-level concentration for each downwind distance. 3) PTMPT: PTMPT produces hourly concentrations at.up to 30 receptors whose locations are specified, from up to 25 point sources. PTMAX was used to evaluate the existing Encina stacks 1-k individually, and the proposed boilers 1-5 exhausting through a IjOO-foot stack, for maximum .ground-level concentrations. PTDIS was applied to the proposed facility to obtain additional information and the distribution of ground-level concen- trations in the vicinity of the power plant. PTMPT was used in the analysis of the existing facility to determine the distribution of concentrations for the combined stacks. ' . . • Model Application The meteorological conditions' input to the IMAMAP. programs to determine ground-level concentrations of pollutants were classified by stability and wind speed. Wind direction and mixing height, where applicable, were also used to define atmospheric conditions. Six stability classes were considered: ,1) extremely unstable 2) unstable 3) slightly unstable h) neutral 5) slightly stable • 6) stable These stability classes were evaluated at wind speed classes of 2, 3> ^-5? 7 and 10 meters per second which are equivalent to 35 5> 10? 15 and 21 miles . per hours. Each combination of wind speed and stability was examined for frequency of occurrence. Meteorological conditions which did not exist for a minimum of two hours per year were eliminated from consideration. The remaining combinations of conditions were evaluated with emissions from the existing plant as determined by 1973-7^ stack tests and the emissions anti- cipated if a fifth unit is added to the facility as proposed. Tables I and II show the meteorological conditions for which the 24-hour or annual average air quality standards could be reached or exceeded. TABLE I Existing Facility - Stack Impact Only Stability Class 1 2 • 3 If . 6 Wind Speed 2 m/s 3 m/s U.5 m/s 7 m/s A,B,C A A A A A A A A - Exceeds 809 annual average standard. B - Exceeds S02 2^-hours standard C - Exceeds N02 annual average standard -3- TABLE II Existing Facility & Background (Annual Avg.) Stability Class 1 2 3 4 . 5 6 Wind Speed 2 m/s 3 m/s 4.5 m/s 7 m/s A,B,C A A,B,C A A A,C A A A A A A - exceeds S02 annual average standard B - exceeds BO 24-hour standard C - exceeds M"C>2 annual average standard Calculations for the existing facility indicate that one-hour average ground- level concentrations for all species are well below their respective one -hour and three-hour standards. An examination of the meteorological ' conditions which would permit the annual or 24-hour standard to be exceeded indicates that such conditions will not persist for sufficient periods to result in a violation of applicable standards . Calculations for stability classes 1, 2 & 3 are valid up to a few kilometers. Calculations for stability classes 4, 5 & 6 are valid to a few hundred meters. Building downwash was not considered in these calculations. Unless the stack is 2.5 times the building height, there is some downwash that will increase ground-level concentrations close to the power plant. However, due to the variation of the eddy effects, such downwash would only effect one-hour averages or standards for any given receptor and as such are not anticipated to affect the results of this study. The models also assume relatively flat 'terrain. Uneven terrain will increase -h- dilution of the stack plume through mechanical turbulence. In addition during daylight hours, ground heating along mountains or steep hills can create a chimney effect which lifts a plume over ridges without ground contact, even though a plume is headed directly toward an elevated site. At night, the predominant wind flew is off-shore. Results of .computer runs for the proposed "Encina 5." facility indicate that, due to the elevated stack height and plume buoyancy effect, the impact on local air quality is slight. Maximum ground level concentrations as a result of plant emissions for all species are much less than applicable air quality standards; under most meteorological conditions the plume is not expected to make ground contact within several kilometers. The ground-level concentrations due to Encina 5 with the tall stack are calculated (by com- puter runs) to be less than the ground-level concentrations of the existing Encina plant (four (k) units without the tall stack). Appendix 2 ASSUMPTION USED FOR BASINWIDE PROJECTIONS IN SUBDIVISION (g) 1. Emissions based on power plants operating 3^5 days per year. 2. All fuel oil is residual oil with'a sulfur content of 0.5$ "by weight. 3- Weight of fuel oil is 8.5 pounds per gallon. h. Savings of 600,000 barrels residual fuel oil per year over the SDG&E system stemming from Encina 5 is constant over the years (1978, 1981, 1983). 5. Total generating capacity for the projection years (19?8, 1981, 1983) is the sum of the 197 ^ generating capacity of 2100 MW plus the MW increments from Encina 5, San Onofre and Kaiparowits less that generating capacity equivalent .to 200,000 barrels per year fuel oil combusted in older, less efficient units, for example, Station B and Silvergate. Appendix 3 GENERATING CAPABILITY USED IK SUBDIVISION (2) - PKOJECTED BY SDG&E - MW 19714. « 2,100 m 1978 - Projected Encina 5 maximum rated capacity is 292 MW I98l - Projected power from San Onofre Unit 2 is 228 MW 1983 - Projected power from San Onofre. Units 2 and 3 is ^56 MW and from Kaiparowits is 351 MW. Appendix: h FUEL USAGE 'DATA USED IH SUBDIVISION (2) SUPPLIED BY'SDG&E (includes Encina 5, Sari Onofre.& Kaiparowits) 1978 Oil - 18.7 million barrels Gas - -0- 1981 Oil - 19.2 million barrels Gas - -0- 1283 Oil - 18.2 million barrels Gas - -0- Appendix PROPORTIONAL MODEL DESCRIPTION USED IN SUBDIVISION (2) The proportional model is expressed by the following equation: ...A."9 x 100 - percent reduction required to A-B meet a pollutant standard Where: A" = existing air quality at the location having the highest measured or estimated concentration in the region. . B = background concentration C = Applicable National Ambient Air Quality Standard This formula is also referred to as the rollback formula. If "A" is "below "C", that is, if the existing air quality is better than the national standard, the formula becomes a rollup formula, indicating the percent by which the. existing air quality is below 'the standard. The latest data, that for the year 197^-> was used to compute the rollbacks or rollups in this report. League of Women Voter I c opoi San P.O. Box 727 . . Cardiff, Ca. 92007 STATEMENT TO THE CARLSBAD CITY COUNCIL AT A PUBLIC HEARING ON THE PROPOSED 400 ' STACK AT THE ENCINA POWER PLANT .... APBIL 20- , 1976 My name is Ruth Honnold, lilive at 42?2 Sunnyhill Dr., 'Carlsbad. I am speaking for the League of Women Voters of San Dieguito. The League of Women Voters has expressed concern about the issuance of a permit to construct a 400 ' stack at the Encina Power Plant on several occasions. Vfe have testified at other public hearings regarding this permit. V»b reiterate, on the basis of our Air Quality positions, our opposition to this proposal. The League of Women Voters believes that the control of air pollution is a responsibility of all levels of government. Wa believe that the City of Carlsbad has the responsibility to prevent the further degradation of its air quality and of the air quality of its neighboring communities. V*s believe that total emissions at Encina should be reduced, not dispersed. San Diago County is all one air basin, and should be considered as a whole. The League of Women Voters supports regulation of stationary sources by controls and penalties, including inspection and monitoring, full disclosure of pollution data, and substantial fines. V.e feel that Encina Power Plant hss not been adequately monitored, that controls have not been mandated, and that pollution data is not avail- able to the public. The League considers it imperative that information on measured emissions from the present stacks be knov:n before a decision can be made on the advis- ability of a tall stack. The City Council of Carlsbad should have full knowledge of present stack emissions, present dispersion patterns, present weether conditions and how these will be changed by Encina j*/p, with or without the tall stack. The City Council should have full knowledge of alternative control measures, such as scrubbers, bag houses, electrostatic precipitators, — their costs end their effectiveness against the various kinds of pollutants, — before a decision onithis proposal can be made. It is the position of the League that pollution control should be considered a cost of doing business, but citizens as consumers and taxpayers must expect some costs to be passed on to them. Citizens are already paying all the costs cf the damage done by air pollution. Savings from reducing air pollution should be-balanced against the cost of installing cleaning systems on the stacks. League believes that all tne costs of this proposal/ be considered. The League, furthezore, believes that deterioration of present air quality must not be tolerated, the President's Council on Environmental Quality hss urged prompt action to protect health and the environment, declaring that "we should no longer be limited to repairing the damage after it has been done; nor should ive continue to allow the entire population or ths entire environment to be used as a laboratory". '^'he California Environmental Quality Act declares it to bs the State's pdlicy to ensure that long term as well as short term protection of the environment shall be the guiding criterion in public decision-making. The act further declares that decisions based on the protection of the environment shall carefullyyconsider all the alternatives and necessary mitigations, anticipate all the consequences of both a beneficidl and adverse nature and allow a choice of the beat possible options. Loaguo believes that City Council should choose emission controls, rather than u tall stuck. Following the passage of the Clean Air Act Amendments in 1970, the Sierra Club and other environmental groups, including the Clean Air Council of San Eiego County, sued the Environmental Protection Agency for approving state implementation plsns tr.at did not include nondej;radation provisions. The Sierra Club sour-ht a r,t.rir+ *„+.,>. --- *_.•.•-.- TESTIMONY OP R. G. LACY BEFORE THE CARLSBAD CITY PLANNING COMMISSION APRIL 20, 1976 My name is Robert G. Lacy. I am the Manager of Mechanical Engineering for San Diego Gas & Electric Company. The engineering for Encina Unit 5, and the proposed single stack, is being performed under my direction. I will make a brief presentation on the technical aspects of the project. I will be followed by Dr. Edward M. Listen of Stanford Research Institute. Dr. Listen has been with Stanford Research Institute since 1965. He is now working in the Atmospheric Sciences Laboratory. He received his PhD from the University of Southern California in!Chemical Engineering. He started working on air pollution research in 195^ as an employee of the Air Pollution Foundation. During his 11 years at SRI he has specialized in experimental research involving the designing and conducting of test programs and the analysis and interpretation of data from these programs. Dr. Listen will -be. followed by Mr. Jack Thomas, Vice President of San Diego Gas & Electric, who will make a concluding statement. On November 20/1973, the Carlsbad City Council approved a Specific Plan Amendment for a single 400 foot stack at the Encina Power Plant. During the ensuing and lengthy regulatory . proceedings before other agencies, that Stack Modification Amend- ment expired. Tonight, we again ask your approval to allow us to construct the single 400 foot stack at Encina for the purpose of improving air quality in Carlsbad. There have.been no changes in the project since your first approval. •'•During the public hearings before the Planning Commiss- ion on January 28, and March 24, I described in some detail how the 400'foot stack will improve the air quality in Carlsbad; and why an alternate solution, such as a scrubber, would be environ- mentally unacceptable. Tonight, I would like to summarize the central issue before us — the need for the stack. i Theiaddition of Unit 5 will decrease the total fuel oil consumption from all of our plants in San Diego County by 600,000 barrels each year.due to the high efficiency of the new unit. A commensurate reduction in system emissions will also occur. It is also true that the addition of Unit 5 will increase the total Encina plant fuel consumption by 30 to 45$ depending on system demands, and that is precisely why we wish to build the tall stack. The tall stack was designed to disperse these increased emissions effectively, even under the most severe meteorological conditions, and will result in a dramatic improvement in local air quality. -2- In no downwind area, either close to or distant from the plant, will emissions from the stack exceed any federal, state, or local standard. In fact, local ground level traces of emissions with five units and the tall stack will actually be less than those now produced by the existing four units with their shorter stacks. Further downwind, the air quality will be no worse because of the stack. This uncontradicted evidence has been reviewed many times in public hearings — before a number of regulatory agencies ., Within the past year, the San Diego County Air Pollution Control District conducted an independent study of the air quality impact of Encina 5 and the tall stack. The APCD study also concluded that air quality improvement in the Carlsbad area would be achieved by installing the tall stack. I The stack is clearly needed and deserves your approval. A second issue — that of the fallout damage, which affects a very small portion of the City of Carlsbad, — has almost overshadowed the major issue at hand. -3- Investigations havo shown that the Encina Plant is responsible .for the rust-like spots up to one-half inch in diameter which collect on some horizontal surfaces in Terramar. These investigations also showed that other types of corrosion damage in the area were characteristic of surfaces exposed to salt-laden sea air and were not caused by the power plant. As noted in the Planning Department- Staff Report, the proposed conditions to the Specific Plan Amendment will give the city ample control to ensure that the problem will he corrected. Mr. Baldwin has also .stated that the Air Pollution Control Officer has petitioned the County Air Pollution Hearing Board for an abatement order-to correct the fallout damage-problem. San Diego Gas & Electric Company has agreed with the abatement order application. We have already requested bid proposals from qualified consultants to conduct a comprehensive test program, which will start in the next two months, to determine the proper methods to correct the fallout problem. Corrective measures might include; changes in sootblowing procedures, fuel oil additives, burner modifications, particulate .collection devices, or combinations of tho.se measures. The need for Encina Unit 5 is not at issue here. However, very recent changes in the Company's resource plans deserve mention. Last week, the Company cancelled its partici- pation in the Kaiparowits Project. This cancellation was caused by spiraling costs resulting from regulatory delays. Encina Unit 5 was urgently needed before. The need is:now desperate. The operation of existing generating units is also not an'issue here. .However, noteworthy, progress which has been made to reduce oil consumption on these older units with a performance monitoring program which was instituted in the Fall of last year. This is a continuing program which is addressing waste heat rejection in our condensers, boiler controls, excess air and stack gas temperatures. Since the commencement of the program, we have improved our over-all system efficiency by 2.1%. During the course of the stack hearings, many irrelevant issues were raised and numerous requests for new information were made, including the exact quantity of emissions for nearly every source in Carlsbad, San Diego County, and the State of California. It would, indeed, be fun to learn the exact quantity of emissions from everything — fro'm sources including automobiles, small boats, power plants, small industries, household stoves, water heaters and furnaces. But, while the answers to these questions may be of •academic interest, they have nothing to do with the merits of the issue before you. The question which must be answered tonight is approval of the stack. The fact is, if Encina Unit 5 and the tall stack were in service today, the quality of the air in Carlsbad would be better right now. The Planning Commission has recommended approval of the stack. 'A total of twelve conditions were imposed. These conditions are tough, by anyone's standards. We will • • '. '••/•accept them. , . . , And now Dr. Listen will speak on the subject of the SRI studies. -6- AIR POLLUTION CONTROL DISTRICT COUNTY OF SAN DIEGO TESTIMONY BEFORE THE CARLSBAD CITY COUNCIL ON ENCINA 5 POWER PLANT 4/20/76 My name is Richard Baldwin. I am Division Chief of the Air Pollution Control District's Division of Surveillance and Enforcement. With me tonight is Michael Foley Division Chief of the District's Division of Monitoring and Technical Services, The APCD has previously issued an Authority to Construct for Encina 5* Our recent written analysis (June, 1975) of the impact of emissions from Encina one through five with the tall stack concludes that the "proposed Encina addition would slightly decrease basin degradation and would markedly decrease ground level concentration of pollutants downwind in the plant vicinity." The latter conclusion is based on use of the tall stack. Based on this study, Encina five as proposed would comply with the District's Rule 20.1. In March, 1976, the APCD completed an investigation of the property damage problem in the vicinity of the power plant. We .have concluded that the power plant is responsible'for some property damage due to staining and acid corrosion. SDG&E has concurred with the results of our study. If Encina 5 and the tall stack are built as proposed, the property damage problem should be reduced rather than worsened. *0n December 12, 1972 the APCD issued an Authority to Construct for Encina 5. On February 28, 1975 the APCD extended the time for the Authority to Construct to December 11, 1977. -2- SDG&E has agreed to conduct a comprehensive study of the formation of these pollutants. This study will lead to control of the emissions from all units at Encina including the proposed Unit 5. The proposed study will be conducted in a manner acceptable to the APCD and the APCD will be an active observer throughout the study. The APCD has petitioned the Air Pollution Control Hearing Board for an abatement order and a copy of this petition has been presented to you. We are requesting that the study be commenced as soon as possible, and that a solution be determined by no later than next April. At that time SDG&E will be required to submit a construction schedule to the Hearing Board to be incorporated into the abatement order. If SDG&E fails to comply with any condition of the abatement order it will be subject to a maximum of $6,000 per day penalty and could be forced to close down the Encina Power Plant. On April 13, 1976, the District received a copy of a letter to the Carlsbad City Council suggesting that information on 11 questions should be at your disposal. The District prepared a response to these questions and submitted it to you on Friday April 16. The information pertains to: Local and basin-wide air quality; past, current and projected emissions from the Encina Power Plant; the effects of smog in L.A.; and the ability of the plume from the 400 foot stack to penetrate the in- version layer. -3- If you have any questions pertaining to the air pollution aspects of the subject before you, please feel free to call on Mr. Foley or myself to answer these questions. . G round-Lev el Con cent ration o f Po 11 u t ant sin the Plant Vic in it y (a) , M.e-t h:o d - o f An a 1 y s is The existing Encina power plant and the proposed modifi- cation were analyzed using the Us-er's Network-for Applied ; Mpdeling of Air Pollution (UNAMAP). Ground-level concen- trations of stfT-ftfr -dioxide, nitrogen dioxide, particulates, carbon monoxide and reactive hydrocarbons were determined for a variety of meteorological conditions specific to the San Diego area. Both the existing and proposed facilities were examined under worst-case operating conditions, assuming maximum power generation with 100 percent usage of 0.5% sulfur-content oil. Conclusions UNAMAP analysis-of:-thci existing facility (Encina 1-4) indicates that maximum ground level concentrations in the ..vicinity of the plant by themselves may exceed state or federal 24-hour ambient air quality standards for sulfur dioxide. Air quality impact for nitrogen dioxide, parti- culates, carbon monoxide and reactive hydrocarbons will be .minimal. A similar an:aly:s~isTbf, the Encina plant with the proposed mG'd-if rcation • (an additional boiler and combined 400-foot stack output} 1-ndicates that maximum local ground-level concentrations for all pollutants of interest which result from plant Demissions are slight, and localized effects of J thte.--facil.ityTrpn._ai.r quality would be insignificant with the,proposed modification. A tabulation of concentrations obtained with the UNAMAP analysis and a comparison with air quality standards follows. MAXIMUM GROUND LEVEL SULFUR DIOXIDE CONCENTRATIONS ATTAINABLE IN THE ENCINA PLANT VICINITY BY UNAMAP ANALYSIS (MICROGRAMS PER CUBIC METER) Plant Configuration •Existing Plant. Proposed Plant, 5 units with tall stack Concentration 406 274 x 10'13 Air Qual ity Standards^ 1 Hr, State - 1310 3 Hr, Federal - 1300 24 Hr, Federal - 365 24 Hr, State - 260 Annual, Federal 80 2. Basitiwide Air Quality (a) Discussion and Method of Analysis The Federal Environmental Protection Agency proportional model (Part 51, Environmental Protection Agency Regula- tions) was used to determine the effect of the Encina plant emissions on ambient air quality in the San Diego Air Basin. The proportional model assumes that the level of air quality is directly proportional to the amount of pollutants emitted into the air. It gives a numerical value indicating the percentage of emission increase or decrease needed to reach a predetermined level of air quality, in this case a National Ambient Air Quality Standard (NAAQS)„ .It indicates whether or J not an air quality standard may be exceeded or not exceeded, and the percentage of emission increase or decrease required to meet or exceed the standard. The" proportional model does not indicate to what degree or for how long an air quality standard will or will not be exceeded. (A diffusion model would give more information than a proportional model. However, such a model has not been validated for basin- wide application at this time.) Only National Ambient Air Quality Standards (NAAQS) were considered for the pollutants emitted by th'e plant. This was done because air pollution control require- ments for denying permits to new facilities are by federal law based on reference to NAAQS. (The San Diego County APCD did not apply these requirements when an authority (permit) to construct was issued .for the Encina power plant addition because the requirements did not exist at that time.) The only other air quality standards applicable to San Diego County are state standards; these are very close to NAAQS or when different are rarely exceeded, if at all. The pollutants covered in this analysis are oxides of nitrogen (as nitrogen dio- xide), sulfur dioxide and particulate matter. Emissions of carbon monoxide and reactive hydrocarbons by the Encina plant were considered in the overall analysis but J were found to have no measurable effect on air quality. Emissions of all pollutants from all sources in the San Diego Air Basin (obtained from the latest Air Pollution Control District emission inventory), and current air quality data were used for input to the model for a base year (1974). For the years 1978, 1981 and 1983, estimates of emissions were made based on fuel usage and electrical energy sources available as reported by San Diego Gas and Electric Company (SDG§E), and on growth projections for other .emission sources. Emission factors (relating amount of pollutant emission to amount of fuel used) were derived from emission tests of SDG5E boilers. It is assumed that SDG§E will continue to use fuel oils containing not more than 0.5 percent sulfur by weight. The increase or decrease in emissions from the base year (1974) to 1978, 1981 and 1983 was related directly -to air- quality increase or decrease for those years, and estimated levels of air quality were obtained. Using these levels, the model was used to determine a percentage that an emission level would be above or below the level required to exactly meet a NAAQS . -THe, yeaTs 1978, 1981 and 1983 were, used because (IJ^i&B? L1978 the Encina plant addition wil 1- «b/egdn ,ap,e^rati^>rf ;-" C,2 ) in 1981 the sec pij.df ^S a*m. On 6 fr e . et- .'.^\ unit will fregin wp &*&&&$& ; and (3) in 1983 the third San Onofre nucle_ar power plant, unit will begin full-time operation, and electrical energy for San Diego County will be available from the Kaiparowits power plant in Utah. While the San Onofre and Kaiparowits plants • will not emit pollutants 'affecting NAAQS in the San Diego Air Basin, availability of their electricity affects the amount of fuel used by SDG§E. Different plant combina- tions and modes of plant usage were used during 1978, 1981 and 1983 to determine effect on air quality. Cal- culation of emissions is based on SDG§E prediction of 100% usage of fuel oil in its plants after 1976. "Nominal" operating condition is defined as operating under SDG§E-determined normal conditions. "Worst con- dition" is defined as operating with a boiler fired to achieve the maximum rated electric output of a. power plant. (b) Conclusions Increased demand for electrical energy from fossil-fuel fired steam turbine electric generating plajits in San Diego County and the decreased use of natural gas in these plants will result in degradation of air quality with respect to sulfur dioxide and particulate matter. This will occur with or without the proposed addition to the Encina Power Plant. Wi£h the addition, the i degradation \9il be slightly less. Sin^JSOGSE power plants are the predominant emitters of sulfur dioxide in the San Diego Air Basin, the improvement or degra- dation of sulfur dioxide air quality in the Basin is directly dependent on electric power generation in fossil-fuel fired power plants. Since SDG§E power plants account for only about five percent of all particulate matter emissions, increased fuel oil use and more electric power generation will have luinimal effect on suspended particulate matter air quality. Following is a tabulation of percentages by which air quality is different from standards for particular years, and combinations of power plant availability. Note: Negative values indicate that the air quality standard is not or will not be exceeded. Tne more negative the value, the cleaner the air. Positive values indicate that the air quality standard is.or will be exceeded. The larger the value, the dirtier the air. A "0" value indicates that the air quality standard is or will be m-et; however, with any degradation, the air quality standard will be exceeded. (For Comparison) J 1974 Nitrogen Dioxide Sulfur Dioxide -67 Suspended Particulate Matter + 44 . 1978 Nominal Conditions • • - •' 1. Without the Encina plant addition -14 2. With the Encina plant addition -16 Worst Cond itions (At Encina Plant) 1. Without the Encina plant addition -12 2. With the Encina plant addition -14 + 3 -7 + 52 + 52 + 54 + 52 1981 Nominal Conditions 1. Without the Encina plant addition and with San Onofre 2 -16 2. With the Encina plant addition and with-San "Onofre 2 -18 3. Without the Encina plant addition and without San Onofre 2 -12 4. With the Encina plant addition and without San Onofre 2 -12 Worst Conditions (At Encina Plant) t ' - • 1. Without the Encina plant addition and with San Onofre 2 -14 2. With the Encina plant addition and with San Onofre 2 • -16 3. Without the Encina plant addition and without San Onofre 2 -10 4. With the 'Encina plant addition and without San Onofre 2 -12 -3 -7 + 17 + 14 + 9 0 + 21 + 17 + 54 + 54 + 57 + 57 + 55 + 54 + SS + 57 Nitrogen Dioxide Suspended Sulfur Pa-rticulate Dioxide Matter 1983 Nominal Conditions 1. Without the Encina plant addition and with San Onofre 2 and 3 and the Kaiparowits plant -22 2. With the Encina plant addition and with San Onofre 2 and 3 and the Kaiparowits plant -24 3. Without the Encina plant addition, and without San Onofre 2 and 3 • and the Kaiparowits plant -4 '4. With the Encina plant addition and . without San Onofre 2 and 3 and the Kaiparowits plant -8 -7 = 10 42 41 + 55 + 55 + 63 + 62 Worst Conditions (at Encina Plant) 1. Without the Encina plant addition and with San Onofre 2 and 3 and the Kaiparowits plant -20 2. With the Encina plant addition and with"San Onofre 2 and 3 and the Kaiparowits plant -24 3. Without the Encina plant addition and without San Onofre 2 and 3 and the Kaiparowits plant -2 4. With the Encina plant addition and without San Onofre 2 and 3 and the Kaiparowits plant -4 + 3 -8 + 46 + 42 + 57 + 55 + 64 + 63 10 . (...) Local Air .Quality Impact%• Methodology, Considerations and Assumptions Introduction The localized effect of the existing and proposed Encina Power Plant facility was analyzed using the applicable programs of UNAMAP (User's Network for Applied Modeling of Air Pollution), and consisted of the following: l) PTMAX: PTMAX produces an analysis of-maximum ground-level concen- tration, and distance of maximum concentration for each condition of stability and wind speed, '•*"' 2) PTDIS: PTDIS calculates downwind ground-level concentrations for a single source for various meteorological conditions specified "by the user. Primary output of the program consists of the height of emission and ground-level concentration for each downwind distance. 3) PTMPT: PTMPT produces hourly concentrations at up to 30 receptors whose locations are specified, from up to 25 point sources. PjEMAX was used to evaluate the existing Encina stacks 1-U individually, and the proposed boilers 1-5 exhausting through a ^00-foot stack, for maximum .ground-level concentrations. PTDIS was applied to the proposed facility to obtain additional information and the distribution of ground-level concen- trations in the vicinity of the power plant. PTMPT was used in the analysis of the existing facility to determine the distribution of concentrations for the combined stacks. . Model Application The meteorological conditions' input to the UNAMAP programs to determine ground-level concentrations of pollutants were classified by stability and -2- wind speed. Wind direction and mixing height, where applicable, were also •used to define atmospheric conditions. Six stability classes were considered: .1) extremely unstable 2) vinstable t ' 3) slightly unstable Jf) neutral ^ . 5) slightly stable • 6) stable These stability classes were evaluated at wind speed classes of 2, 3> ^-5, 7 and 10 meters per second which are equivalent to 3, 5, 10, 15 and 21 miles per hours. Each combination of wind speed and stability was examined for frequency of occurrence. Meteorological conditions which did not exist for a minimum of two hours per year were eliminated from consideration. The remaining combinations of conditions were evaluated with emissions from the existing plant as determined by 1973-7^- stack tests and the emissions anti- cipated if a fifth unit is added to the facility as proposed. Tables I and II show the meteorological conditions for which the 2^--hour or annual average air quality standards could be reached or exceeded. .TABLE I • Existing Facility - Stack Impact Only Stability Class 1 2 • 3 U . 6 Wind Speed 2 m/s 3 m/s k.5 m/s A,B,C A A ' A A A f-7 / A A A - Exceeds S02 annual average standard B - Exceeds S02 2^-hours standard C - Exceeds NOg annual average standard -3- TABLE II Existing Facility & Background (Annual Avg.) Stability Class 1 2 3 k . 56 Wind Speed 2 m/s 3 m/s ^.5 m/s A,B,C A AjB,C A A A A A 7 m/s A,C A A A - exceeds SOg annual average standard -. • B - exceeds SOg 2^-hour standard C - exceeds NOg annual average standard - Calculations for the existing facility indicate• that one-hour average ground- level concentrations for all species are well below their respective one-hour and threeThour standards. An examination of the meteorological conditions which would permit the annual or 2U-hour standard to be exceeded indicates that such conditions will not persist for sufficient periods to'result in a violation of applicable standards. Calculations for stability classes 1, 2 & 3 are valid up to a few kilometers. Calculations for stability classes h, 5 & 6 are valid to a few hundred meters, i Bi^lij^rgrdoj^nwash was not considered in these calculations J Unless the stack I \\:-7'M'-'^»*~^'&W*&^2*£*^-'t--':''*•'•''•' ''-^'•-•'•'•''l''. .' -.•.•--'-•"'- :.'•;•."' ' * ~—' - is 2.5 times the building height, there is some downwash that will increase ground-level concentrations close to the power plant. However, due to the variation of the eddy effects, such downwash would only effect one-hour averages or standards for any given receptor and as such are not anticipated to affect the results of this study. The -models also assume relatively^fiL.ESffi^ Uneven terrain will increase dilution of the stack plume through mechanical turbulence. In addition during daylight hours, ground heating along mountains or steep hills can create a chimney effect which lifts a plume over ridges without ground contact, even though a plume is headed directly toward an elevated site. At night, the predominant wind flow is off-shore. Results of .computer runs for the proposed "Encina 5" facility indicate that, due to the elevated stack height and plume buoyancy effect, 'the impact on local air quality is slight. Maximum ground level concentrations as a result of plant emissions^fpr all species are much less than applicable air quality standards; under mostLmet^ir61ogieal~cenditions~the pi expected to make ground contact within several kilometers;.. The ground-level concentrations due to Encina 5 with the tall stack are calculated (by com- puter runs) to be less than the ground-level concentrations of the existing Encina plant (four (k) units without the tall stack). ASSUMPTION USED FOR BA8INWIDE PROJECTIONS IN SUBDIVISION (2) 1. Emissions based on power plants operating 3^5 days per year. 2. All fuel oil is residual oil with'a sulfur content of 0.5$ by weight. 3. Weight of fuel oil is 8.5 pounds per gallon. k. Savings of 600,000 barrels residual fuel oil per year over the SDG&E system stemming from Encina 5 is constant over the years (1978, 1981, 1983). • ' 5. Total generating capacity for the projection years (19?8, 1981? 1983) is the sum of the 19?^ generating capacity of 2100 NW plus the MW increments from Encina 5s San Onofre and Kaiparowits less that generating capacity equivalent to 200,000 barrels per year fuel oil combusted in older, less efficient units, for example, Station B and Silvergate. ^^ Appendix 3 J ~ ~ GENERATING CAPABILITY USED IN SUBDIVISION (2) - PROJECTED BY SDS&E - MW • - 2,100 MW 1978 - Projected Encina 5 maximum rated capacity is 292 MW 1981 - Projected power from San Onofre Unit 2 is 228 MW 1983 - Projected power from San Ouofre Units 2 and 3 is k$6 MW and from Kaiparowits is 351 MW. Gas - -u~ 1§§1 Oil - 19-.' Gas - -0 UBDIVISION (2) &. n - 18.2 million Barrels Oil Gas - o ' ' PROPORTIONAL MODEL DESCRIPTION USED IN SUBDIVISION (2) The proportional model is expressed by the following equation: A-B x 100 = percent reduction required to meet a pollutant standard Where: A' = existing air quality at the location having the highest measured or estimated concentration in the region. B = background concentration C = Applicable National Ambient Air Quality Standard This formula is also referred to as the rollback formula. If "A" is beloi-r "C", that is, if the existing air quality is better than the national standard, the formula becomes a rollup formula, indicating the percent by which the. existing air quality is below 'the standard. The latest data, that for the year 197^, was used to compute the .• rollbacks or rollups in this report. CARLSBAD COMMUNITY CAUSE 3831 MARGARET WAY CARLSBAt)', CA 92008 (714) 729-8065 April 11, 1976 To: Carlsbad City Council From: Carlsbad Community Cause Re: Sncina 5/400' stack effects on air quality Dear City Council Person: Jack Thomas, SDC&S, at the. Planning Commission meeting 3/24/76 (we have printed copies of the minutes) stated in response to a question by Gomm. Jose that Sncina units 1-3 are not obsolete and have a life expectancy of approximately 20 more years. Mr. Thomas stated also that SDG&E would be using these units as needed and not only for back- up or emergency. THIS IS THS FIRST TIME SDG&.S HAS ADMITTSD WHAT WE HAV? BSEN SAVING ALL TH3 TIMS. What we are talking about is not the generating capacity and pollution of 5+4 as compared to 1-4, but a grand total of units 1-5 operating at full, capacity. This admission totally invalidates the argument that local or regional air quality would be improved with, the addition of E5. If this project were seek- ing original approval, it could not meet the requirements of APGD Rule 20.1, which prohibits construction of new sources if they will cause significant deterioration of existing air quality. There will always be a market for energy. Excessive production leads to or creates excessive demand. As an astute young high school stud- ent pointed out at the Planning Commission hearing 1/28/76, how do we know that we will not some time in the future be asked to accept units 6, 7, & 8--each with their own 400' stack. THIS H<\S HAPPENED IN OTHER AREAS. APCD informs us that there are in existence stacks 2100' in height, which are, of course, much more efficient in DISPERSING the INCREASED amounts of pollutants. Let's not forget that SDG&S already has tentative plans for another power generating facility East of 15. Let's remember also that SDG&S is presently barging oil down to their So. Bay plant from the Encina mooring. If there is a change in gener- ating plans, it would most likely be (more economically feasibible) for SDG&5 to cut back at So. Bay and increase at Sncina. We have deep- er waters which provide a more suitable port for bringing in the oil via tankers, which will be either increasing in size or number or both. Our decision makers should also be fully informed as to the adverse environmental effects of these oil tankers--such as vapor emissions, normal oil spillage, risk of accident and results. page. 2 'Die actual emission firures for units 1-4 for 1974 (based on fuel oil consumption1) plus projected em.iKsions for unit 5 are; Sulphur Dioxide (S02): 10,349.1 tons/yr (causes lung disease "and has bad od~orl Nitrogen dioxide (M02); 5,066.7 tons/yr (component part of photo- chemical SMOG) Particulates: 1,091.6 tons/yr (fallout problem at Terremar-- causes property damare & in combination with S02 respiratory disorders) Hydrocarbons (HG); 151.4 tons/yr (also a componatt part of photo- chemical SMOG --emissions report for O'side show we already exceeded standards 189 days in 1975--APCD has not computed amounts for unit 5) Carbon Monoxide (GO); 227.4 tons/yr (adverse effect on circula- tory system—APCD has not computed for unit 5) IT IS OF CRUCIAL IMPORTANCE THAT WE KNOW THE AMOUNTS OF THESE CON- TAMINANTS THAT ARE ALREADY IN OUR LOCAL AND REGIONAL AIR AND HOW THEY COMBINE AND THE EFFECTS OF THESE COMBINATIONS. For example, we are ALREADY exceeding Hydrocarbon emissions at O'side over half the year--CarIsbad fugures would be higher. The existing Encina power plant is ALREADY one of the greatest single sources of oxides of nitrogen in the county. The formula for PHOTOCHEMICAL SMOG is : Hydrocarbons + Oxides of Nitrogen + Sunlight = PHOTOCHEMICAL SMOG The annual average oxidant (smog) reading for O'side in 1975 was higher than downtown San Diego. Carlsbad Community Cause formally requested the APCD mobile monitor- ing unit for Carlsbad. APGD's response was that this unit (their only one) was stationed at San Ysidro aid would not be available for some time.• The 5ncina_power plant is the largest single stationery source of air pollution in San Diego County and we are faced with an impending 5C% expansion. Carlsbad area should have top priority for monitoring equipment. _We are forced to use data collected from the O'side sta- tion which is upwind from us--prevailing winds being from the NW. It is ESSENTIAL that our city council members have complete, up-dated, accurate information on our present local and basin ambient air quality together with the emissions from the existing SDG&E power plant and what the projected emissions would be from unit 5. This information should then be C9nsidered against a background of expected increases in County pollution from other sources. page 3 Such information as the following should be at your disposal : — 1975 ambient emission figures for SD basin and no. of days exceed- ing standards —1975 emission figures for O'side, daily and annual averages, and no. of days exceeding standards — No. of days, local and basin, when emissions were approaching (close to) standards 1974/1975 --What are the state and federal standards, and would it be possible for city government to legislate more stringent standards for the protection of Cocal air quality — Source test data for units 1-4 --actual emissions for units 1-4 (based on fuel oil consumption) for 1974 and 1975 — Compare emissions and air quality information from 1970 (earliest reliable APCD figures) to present --How does our air quality compare to LA --What have been health, property, agricultural, aesthetic effects of air pollution in LA or other heavy smog areas — projected emission figures for unit 5 — Will the plume from the 400' stack penetrate the inversion layers The Research Team of Carlsbad Community Cause has been working very hard to obtain this information from our APCD so that it can be anal- ysed and we can have a complete picture of the present situation and the outlook for the future. THSRS IS NO CURS FOR SMOG. THERE IS ONLY PREVENTION. THIS IS YOUR RESPONSIBILITY AS THE SLECTBD REPRESENTATIVES OF THE PEOPLE. If the people demand clean energy-- the producers will supply it. This will only be accomplished if this requirement is made prior_ to the construction of pollution generating facilities. Very sincerely, Donna Flanders Research Committee Carlsbad Community Cause page cc: William Simmonsr APGD Don Agatep, Carlsbad Planning. Dept, Carlsbad City Library League of Women Voters Sierra Club Gil Davis, 31ada Tribune Ride Monroef Carlsbad Journal Tim ShtaDard, San Diei?o Union.