HomeMy WebLinkAboutSP 144C; SDG&E Wastewater Facility; Specific Plan (SP) (5)CITY Of: CARLSBAD
ENVIRONMENTAL PROTECTION ORDINANCE OF 197
DECLARATION OF NEGATIVE (NONSIGNIFICANT) ENVIRONMENTAL EFFECT
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APPLICANT SAN DIEGO GAS AND ELECTRIC COMPANY
1J31_J\J^H__STREET. SAN DIEGO, CALIFORNIA 92101
TYPE OF APPLICATION GRADING PERMIT. SPECIFIC PLAN AMENDMENT
PERMIT AND/OR FILE NO. SP-144 (c) _ _____ _
THE ENVIRONMENTAL IMPACT ASSESSMENT HAS BEEN RECEIVED FOR: . . -
PROJECT DESCRIPTION: Modification, of water treatment facilities in accordance with EPA
regulations. A total of 28,380 cubic yards will be graded to allow construction of .six
water treatment ponds. The ponds and an adjacent treatment plant will remove copper, iron,
oil,- grease,- and suspended solids from fresh water used in the generation of-steam-electric
power. After treatment in accordance with State and Federal -standards, the water is to be
discharged into the ocean.
PROJECT LOCATION:Within the-Encina Power Plant Complex, east of Carlsbad Blvd., and south
of the Outer Agua.Hedionda Lagoon.
I declare that I have examined the information for the above project as submitted
by the applicant, and on the basis of the Environmental Impact Assessment
questionnaire on file in my office as a public document, it is my determination
that this project will not have any significant impact upon the environment
within the meaning of the California Environmental Quality Act of 1970 and the
Environmental Protection Ordinance of 1972 for the following reasons:
1.The construction of the treatment facilities is a necessary water pollution control
measure which 1s required by the.U.S. 'Environmental Protection Agency;—Discharged
water must be treated so that levels of copper, iron, oil-, grease, and suspended
solids will be, reduced1. : ; •
2.- The construction of the treatment'facilities will not increase the amount of fresh
' water discharged into the ocean, but wi11-simply improve tfte quality of that dis-
charged water, in accordance with all State and Federal requirements.
3.' The amount of grading associated with the project is not substantial, and does not
pose anv special geotechnical problems. ; : .
4. The treatment ponds will not be visible from offsite. Landscaped berms will -
surround the ponds.
5.
6.
An impervious liner will be installed to prevent seepage from the ponds. As an
auxilliary measure, a subdrain system will be constructed to accommodate seepage
.should the liner be punctured.
The applicant will construct overflow pipes to prevent discharge from rising too
. high in the ponds.
7. Boiler blow-down water, which accounts for.approximately 37% of ..the water which
the company could legally discharge into the ocean, wi 1.1 be re-used.
The Environmental Impact Assessment will be available for public review and comment -
for FIVE DAYS from date.
BUD PLENDEK, Acting Planning Directo'
DATED:3 1377t '
E.I.S. Log No. 337
*
MEMORANDUM
SEPTEMBER 1, 1976
TO: PLANNING DIRECTOR
FROM: DANA HIELD WHITSON
SUBJECT: ENVIRONMENTAL IMPACT REQUIREMENTS FOR WATER TREATMENT
FACILITIES AT ENCINA POWER PLANT
Per our discussions prior to your vacation, I have prepared a negative
declaration for the water treatment facilities at the San Diego Gas
and Electric Company Encina Power Plant.
Ed Gabrielson has provided a letter for our files describing the
project. In addition, I have asked him to submit an additional letter
answering the following:
1. What is the volume of fresh water to be discharged into the ocean?
2. How is this water used in the power generation process?
3. Why can't the treated water be recycled?
Gabrielson has been informed that the negative declaration won't be
published or posted until after your return. This should coincide
with their clearance from the Regional Coastal Commission.
Bud attended a meeting with myself, Ed Gabrielson and Mike Dudley,
so he is familiar with the project. Mike Zander said he can take
care of the posting and publishing.
Dana Hield Whitson
DHW:cs
cc: Bud Plender
Attachments: EIA
Grading Plan
Negative Declaration (for posting and for publication)
Letter from Ed Gabrielson, dated August 30, 1976
ENVIRONMENTAL IMPACT ASSESSMENT FORM
Receipt No. ' EIA NO.
Date:
Name of Applicant: san Dieg^ GAs & Electric Company
Address: 101 Ash Street, San Diego, CA 92101
Permit Applied For: Grading
Case Nos.:
Location of Proposed Activity: Encina Power Plant Site southwest
sector of the City of Carlsbad
BACKGROUND INFORMATION
1. Give a brief description of the proposed activity (attach
any preliminary development plans).
Modification of Water Treatment Facilities in accordance
with EPA regulations, Title.40, Part 423, Steam Electric
Power Generating Plants.
Describe the activity area, including distinguishing
natural and manmade characteristics; also provide precise
slope analysis when appropriate.
Project is located within the Encina Power Plant complex
which is located east of Carlsbad Blvd. and south of the
outer Agua Hedionda Lagoon.
3. Describe energy conservation measures incorporated into
the design and/or operation of the project.
The equipment to be installed is of contemporary design
and incorporates the latest developments of energy con-
servation
ENVIRONMENTAL IMPACT ASSESSMENT FORM
II. Environmental Impact Analysis
Answer the following questions by placing a check in the appropriate
space.
Yes No
1. Could the project significantly change present land uses
•' in the vicinity of the activity? x
2. Could the activity affect the use of a recreational
area, or area of important aesthetic value? x
3. Could the activity affect the functioning of an
established community or neighborhood? x
4. Could the activity result in the displacement of
community residents? x
5. Are any of the natural or man-made features in the activity x
. area unique, that is, not'found in other parts of the
County, State, or nation?
6. Could the activity significantly affect a historical or
archaelogical site or its setting? . x
Could the activity significantly affect the potential
use, extraction, or conservation of a scarce natural res- x
ource? . . . .
8. Does the activity area serve as a habitat, food source
nesting place, source of water, etc. for rare or endangered
wildlife on. fish species? x
9. Could the activity significantly affect fish, wildlife or
plant life? , , x_
10. Are there any rare or endangered plant species in the
activity .area? . '
11. Could the activity change existing features of any.of
the city's lagoons, bays, or tidelands?
14. Could the activity .serve to encourage development of
.presently undeveloped areas or intensify development
of already developed areas?
x
12. Could the activity change existing features of any of
the City's beaches? . _ _ x_
13. Could the activity result in the erosion or elimination
of .agricultural lands? '. _ _ L
. No
15. WilT the activity require a variance from established environmental
standards (air, water, noise, etc)? x_
16. Will the activity require certification, authorization or issuance
of a permit by any. local, State or Federal environmental control
agency? x
17. Will the activity require issuance of a variance or conditional
use permit by the City? __ . . y
18. Will the activity involve the application, use, or disposal of
potentially hazardous materials? x_
19. Will the activity involve construction of facilities in a flood
•plain?
20. Will the activity involve construction of facilities on a slope of
25 percent or greater? . x_
21. Will the activity involve construction of facilities in the
area of an active fault? Y
22. Could the activity result in the generation of significant
amounts of noise? x_
23. Could the activity result in the generation of significant
amounts of dust? x_
24. Will the activity 'involve the burning of brush, trees, or
other materials? • . • x_
25. Could the activity result in a significant change in the .
quality of any portion of the region's air or water resources?
(Should note surface, ground water, off-shore). v
26. Will there be a significant change to existing land form? . ' x .
(a) indicate estimated grading to be done in cubic yards. 92 .000j___-r-~~*
(b) percentage of alteration to the present land form. 2%
(c) maximum height of cut or fill slopes. 20 feet
.27. Will the activity result in substantial increases in the use of utilities,
sewers, drains or streets? . x
III. State of No Significant Environmental Effects
If you have answered yes to one or more of the questions in Section II but you
think the activity will have no significant environmental effects, indicate your
reasons below: Question 16: Project will require: ,
• '~ -1. Grading permit, City of Carlsbad
2. Building permit, City of Carlsbad
3. Development permi-t, .San Diego Coast
• Regional Commission
Question 25; . Project will improve quality of power plant fresh water .
discharge. Will have no change in the quality of other
resources. ' .
IV: Comments or Elaborations to Any of the Questions in Section II.
(If additional space is needed for answering any questions, attach additional
sheets as may be needed.)
Signature //C-r Ate*/ (Person/completing report.)
.Date Signed: /&<$
Conclusions (To be completed by the Planning Director). Place a check
in the appropriate box.
( } Further information is required.
( ) It has been determined that the project will not have significant
environmental effects. ( ) You. must submit a preliminary environmental
impact statement by the following date _ . ( ) You
• -should make an appointment with the Planning Director to discuss
further processing of your project, in accordance with Chapter 19.04
of the Municipal Code.
DATE RECEIVED:' ' _ •
. . BY:
Planning Director, or,
Revised 7/3/74
' ^
MEMORANDUM
July 26, 1977
TO: Paul Bussey, City Manager
FROM: J. C. Hagaman, Planning
SUBJECT: Encina Power Plant Fallout
The attached report from Mrs. Whitson of my staff indicates
that the Encina Power Plant abatement order No. 607 has been
extended to December 31, 1977 to all for further testing.
This action was based on information contained in the fallout
prepared for APCD by York Research Corporation. (A summary
is attached.) The York Research Corporation findings of
APCD are available in the department for City Council review.
It is recommended that the City Council not act on determining
if the Encina fallout problem is controlled until the current
abatement order of APCD is rescinded.
JCH: s
MEMORANDUM
DATE: July 6, 1977
TO: Jim Hagaman, Planning 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 building
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
source tests and paint panel tests. The abatement order has been
extended until December 31, 1977 in order to allow this new infor-
mation to be obtained. In the interim SDG&E has been instructed to
continue paying damage claims.
The State Health Department did express concerns about the health
effects of the fuel additives. Both magnesium and manganese additives
have been used for many years on the east coast. However, no specific
studies on the health effects of these additives have been conducted.
The Health Department's primary concern was with the presence of small
quantities of manganese in the fuel additive. Since the manganese
was found to have a limited effect on the fallout, it has been eliminated.
SDG&E, the APCD and the Health Department will continue to monitor the
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 York report is
attached. The report recommends use of a fuel oil additive, scheduling
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 fallout
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
ENCINA POWER PLANT
DAMAGING FALLOUT
ELIMINATION PROGRAM
Volume 1 •- Text-
York Research Corporation
One Research Drive
Stamford, Connecticut 06906
York Job Number 4-9126
Prepared for:
San Diego Gas and Electric Company
4600 Carlsbad Boulevard
Carlsbad, California 92008
March 16, 1977
York Research Corporation
One Research Drive. Stamford. Connecticut OB906• Telephone: (203) 325-1371 -TWX: 710-474-3947
2.0 SUMMARY
During the first phase of the program, base line conditions were
established prior to the implementation of operational changes.
The nature of the local damage caused by the Encina Power P,lant
... ' > ., v^ . ' -
was found to be related to" acidified particles generated by the
boilers and emitted from their smoke stacks. These particles
subsequently settle out of the plumes after being carried down-
wind from the plant. This acidic- fallout is dependent on the
formation of sulfur trioxide (303) and a carbonaceous carrier in
the combustion process.
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.
Simplistically then, the solution to the damaging fallout problem
is to minimize, if not totally eliminate the formation of SO^
and the carrier (or neutralize the SO^ without intruducing any
new, damaging material). To eliminate the 303 is to eliminate
either the sulfur or the oxygen. To eliminate the carrier is to
eliminate the unburned carbon or to trap the particles before
-2-
the gas stream enters the atmosphere.
2.1 Damaging Fallout
The characterization of damaging fallout is the key to the entire
program. At various locations in the environs of the plant in-
cluding mid-Terramar, (see Figure 1-1) sampling stations took data
every three hours for eight months. In excess of ten thousand
fallout sample collections will have been made at this writing.
In addition to the normal three hour interval collections, panels
of white paint have been placed to identify the extent of "Damage"
*• ;* • t- ~ -/- ,/>'
and/or the .lack of damage at the sampling locations. This panel
data is presently being gathered on an ongoing basis, (see Section
6.11).
The damaging fallout was acidic. The possibility that it was iron'
rust was eliminated when damage spots on the paint panels were
shown to be of an acidic origin and not iron (see Section 6.11).
2.2 Test Programs
Test Programs (see Section 4.0) were of an interdisciplinary
concept designed to include source testing, atmospheric monitoring,
and combustion engineering. The source and atmospheric monitoring
are continuing on a reduced scale.
2.2.1 Source Emission Tests
d the SO-, emissions.Of particular interest are the particulate pH a|
'!
The obvious need to correlate stack emissions with combustion
engineering and ambient monitoring was frustrated by the unsuitability
-3-
ENCINA POWER PLANT AND VICINITY
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of EPA methods used to determine SO-j at the normal low concen-
trations found in the Encina boilers. A superior method was
devised and is being continued by ongoing tests. The pH measure-
ment of the stack particulate has a low (j- 0.5 pH units) precision;
but is useful in showing trends and comparative levels.
2.2.2 Atmospheric Monitoring
'The atmospheric monitoring consists of collecting meteorological
data, air quality data, and fallout data (see Section 4.2).,
...',.>.,
"The vast quantity of data"taken were mathematically analyzed by
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 combustion engineering
group (see Section 4.3).
2.2.4 Fallout Measurement
The focal point of the study was measuring and identifying the
damaging plant fallout. Plant emissions contain many of the
*
constituents normally found as background around the Encina plant
but in differing amounts. A method was developed to reliably
«i
Imeasure the effect of plant operations on damaging fallout.
1
(General measuring equipment and techniques are discussed in
detail in Sections 4.0, 6.0 and Appendix B). Atmospheric fallout
monitors daily measured the acidic fallout - more than .18,000 .,
. - -4-
acid fallout eventl^were recorded. The courratag of events was
frustrated by the question, "Which way and how fast was the
wind blowing?" Ground wind direction and speed were continuously
recorded; but the upper air layer above about 250 feet (see
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 the
two classes of fallouts it was possible to,utilize the ratio of• ••„.-» . i- ~ ./• .rx
strong acid to total events counted and observe the change in
ratio for any change in the plant conditions. This ratio change
enabled data analysis to become nearly independent of the meteor-
ological and other conditions (e.g.-a boiler out of service).c; • ..
A,corroborating indicator is stack particulate average pH. This
has also developed into a data, source which provides a means of
detecting in the stack whether the normal fallout is going to be
acidic in nature. See Section 5.1.2 for examples of the use of
the ratio and of pH. •
•* • r
\ ,
2.3 Operational Changes
Once the source of the acid fallout problem was identified,
operational changes were instituted which might best affect a
solution.
2.3.1 Additives
/ Since the acid is formed by sulfur dioxide being further oxidized
-5-
into sulfur trioxide with normal excess oxygen, then the addition
of magnesium oxide into the fuel would combine with the sulfur
trioxide to form magnesium sulfate. This action will neutralize
or prevent the sulfur trioxide from combining with the combustion
water to form sulfuric acid. The data show that the plant's
emitting of strong acid fallout fell to one-quarter the rate after
additives (18% of total fallout as opposed' to 80% before additives
(see Section 5.1)). The acidity of particulates emitted from
the stacks was substantially reduced, from a pH of 2.5 before
j
additive to 5.5 after additive-. Tests are 'continuing to ge'nerate
— -' ' : f pi
fallout data from the entire plant using additive rather than just
one unit.
- /
2.3.2 Soot Blowing
V Greatest fallout intensity was first found during plant soot
blowing. Normally scheduled for early evening (1700 to 2130),
soot blowing coincided with transitional wind conditions, where
ground level winds reverse direction and exhibit minimum speed.
Upper air v/inds also change direction and speed but in a less
predictable -manner and usually somewhat earlier than ground
level winds.
In order to verify that increased fallout was-directly related to
soot blowing activities, independent of wind transition effects,
the soot blowing period was rescheduled at 1100 to 1530 daily.
The fallout intensity maximum also moved to the 1100 to 1400
/ period. Thus, soot blowing was established as a direct influence
on fallout.
^•F- •A hypothesis developed that if soot blowing could 'be performed
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)
• - . . ' i !••• , .-•» . i .
- -• -x ' . /' #2.3.3 Viscosity
Fuel viscosity was explored to determine 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)
2.3.4 Fuel Sulfur Content
The effect of fuel sulfur content on damaging fallout was measured
.over a three week period burning 0..17% S Fuel. In spite of the
short time period, the ratio of damaging fallout to total fallout
V
was indeed reduced by this special fuel (80% strong acid fallout
count to 25% strong acid fallout count. If there were no sulfur
j
in the fuel there would be no sulfuric acid andjjithis small amount
f
of sulfur was approaching that condition. (See Section 5.4)
—7 —
2.4 Control Plan Recommendations
The program objective; mitigation of damaging fallout, is defined
in terras 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 completely in Section 7.0.
2.4.1 Fuel Oil Additive Use
A magnesium based fuel oil additive should' be used in all boilers
at a minimum amount for effective neutralization of acidic
emissions'. This rate must be maintained throughout the range
of fuel flows in each boiler'.
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 blowing in all boilers should be performed between
the hours of 1100 and 1600. This takes full advantage of
favorable winds of maximum speed and persistence to disperse
acidic particles in a narrow corridor further away from pop-
ulated areas.
2.4.3 Fuel Oil Viscosity Control
Fuel oil viscosity should be automatically controlled in each
boiler to minimize^fcimbustible particulate f^fc.ssions. This
serves to reduce the carbonaceous carriers of sulfuric acid and
( thus reinforces other abatement measures.
2.4.4 Low Sulfur Fuel Oil Use
Fuel oil should have as low a sulfur content as possible. This
will be governed by availability. ,
7.0 CONCLUSIONS AND RECOMMENDATIONS
From the data available, a program has been developed which can
substantially eliminate local fallout damage. This damage has been
isolated to the generation, dispersion and' settling of large
- >.> " '. ''acidified carbonaceous agglomerates. Evidence from painted panels,
source, emission and fallout monitoring confirms this at the Encina
Power Plant.
The following items constitute the basis of an effective control
>. ' plan which will mitigate the fallout problem:
7.1 Fuel Oil Additive
The proper use of a magnesium based fuel oil additive substantially
eliminates strong acid fallout from the plant. The evidence cited
%
.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 counts from
80% to 18%.
The use of additive is proper only when minimum effective amounts
are used. More than.this will simply be expellees from the boiler
as increased particulate matter without contributing to acid neutrali-
f
zation.
-236-
With these points in mind, it is recommended that a fuel oil addi-
tive be used in all boilers at the Encina Power Plant with control
of additive rates against sulfur content of fuels. Preferably,
this should be on a real-time basis through continuous monitoring
of fuel sulfur or S02 emissions. Consideration should also be given
to monitoring particulate pH as a final control function of additive
rate. The ratio of additive to oil must also be maintained at the
effective minimum throughout the fuel flow rates used by each boiler.
7.2 Soot Blowing Schedule ' ,
i f •*
The rescheduling of daily soot blowing from the present 1700 start
* time to 1100 PST is recommended in order to take advantage of favor-
able wind conditions existing from mid-day through early afternoon.
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 with
the plume,
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. This technique
is not capable of substantial elimination of acidic fallout; there-
fore, it is not recommended considering the extra steam consumption
required and possible water shortages in the area.
-237-
7.3 Low Sulfur Fuel Oil •
Very low sulfur fuel oil use may be a helpful expedient as the data
clearly indicates. However, not enough data is available to speci-
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 incremental
changes accompanying stepwise reductions in sulfur content. This
would establish the most productive change. in terms of acidic fallout
abatement . . . • ', ' . • >
*• . -' • * * *•~ -/• • ./>•
Certainly/ however/ the use of higher sulfur content oils than are
now available should not be undertaken.
7.4 Fuel Oil Viscosity Control
Automatically controlled fuel oil viscosity should be implemented
for all boilers to reduce carbonaceous acid carriers. When viscosity
values are obtained which result in minimum unburned combustibles ,
then those values should be used until there is a fuel oil change
or the burner tips are replaced. This will not solve the acidic
fallout problem, but it will make any other solution easier to
maintain.
Based on the trends exhibited by the data during limited test periods,
these recommendations will provide the Encina Power Plant with sub-
stantial elimination of the damaging fallout, as Veil as minimizing
the total fallout that occurs in the nearby community.
-238-
;oi roCOUNTY OF SAN DIET5O
INTER-DEPARTMENTAL CORRESPONDENCE
DATF June 17, 1977
TO: Air Pollution Control District Hearing Board
THROUGH: Clerk of the Hearing Board (A45)
FROM: William Simmons JUN 2 8 1977
Air Pollution Control Officer (0176) -
SUBJECT: ENCINA FALLOUT PROJECT: DISTRICT PETITION NO.,'-6Q7n/n'7 rC^,.,."^
On June B, 1977, the Hearing Board continued the hearing on Petition No. 607
to June 23, 1977. The District then advised your board that it is prepared
to make recommendations as to the modification of the abatement order issued
to San Diego Gas & Electric Company in connection 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
SDG&E, and that this report does not address the health effects, if any, of
emissions that may result from the use of the fuel oil additive which is
proposed by SDGSE as part of the overall control plan.
SDGSE end the District have consulted the State Department of Health to deter-
mine said health effects. The department has advised that certain tests need
to be conducted before an assessment can be made as to any adverse health
effects. To be determined are (1) mass emission rates from the stacks, (2)
particle size distribution, (3) composition (both elemental and compound
specific) of the background, (4) areawide impact, and (5) other related analyses.
It also appears from the test report that with the use of a fuel oil additive
the total particulate emissions from the Encina power plant may increase
(degree not known) even though the damaging acid-fallout will decrease.
According to SDG&E it is possible that there may be no increase in particulate
emissions once all boilers burn the additive. Assuming emissions increase, the
proposed control plan will have to be reviewed pursuant to District Rules 20.1,
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, if
any. -Also, further evaluation is needed to determine possible damage on different
paint surfaces by emissions resulting from the use of the additive.
As explained to the Hearing Board on June 9, 1977, the acid-fallout problem
arises from the formation of acid from S03 which is formed from S02 in the
presence of monatomic oxygen. S02 is created by the combustion of fuel oil
containing sulfur. Fuel oil additive inhibits the formation of S03. Another
probable solution to the acid-fallout problem is the use of low sulfur fuel,
which will result in lower emission of S02; this method should be tried if the
fuel oil additive program cannot accomplish compliance with District Rules and
Regulations.
_ 2 -
Encina Fallout Project June 17, 1977
DISTRICT POSITION
The change in the level of participate 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 fuel oil additive, (2) source test shortly after boiler wash, using
fuel oil additive, and (3) source test using additive after the operation has
stabilized. Presently there are four (4) boilers in operation, therefore
twelve (12) tests will be required. A fifth unit (boiler) is under construc-
tion and similar tests must be conducted after this unit is put into operation.
Pursuant to the above, the District recommends that the Hearing Board modify
the abatement order issued to SDG&E, as follows:
1. By August 1, 1977 - the use of fuel additive shall be fully implemented
on all the boilers located at Encina Power plant, Carlsbad. Also,
rescheduling of soot blowing as proposed in the control plan shall be fully
implemented.
2. By September 1, 1977 - SDG&E shall install all equipment and instrumentation
necessary to gather information required by the State Department of Health,
and submit the information to said department and the District.
3. Five {5} days after boiler wash, SDG&E shall conduct a source test to
'determine baseline emissions.
4. Immediately after the baseline test, SDG&E shall conduct a source test to
determine emissions with the use of fuel oil additive.
5. Within 60 days of the test mentioned in '4* above, and after boiler
operation with the use of fuel oil additive has stabilized, SDG&E shall
conduct a source test to determine emissions with the use of the fuel oil
additive.
6. Tests required by condition nos. 3, 4, and 5 shall be conducted in
accordance with the procedures approved by the Air Pollution Control Officer.
Schedules for testing shall be provided the District in advance. Results
of said tests shall be submitted to the District within two (2) weeks after
completion of each test..
7. SDG&E shall determine the impact-of emissions on different paint panels
as required by the District.
8. SDG&E shall continue to make restitution to all persons whose property has
been damaged by the emissions from the Encina Power Plant.
- 3 -
Encina Fallout Project June 17, 1977
9. By December 31, 1977, SDG&E shallbe 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.
Res pectfully s ubmi tted,
WILLIAM SI1WONS
Air Pollution Control Officer
WS:PS:kb
cc: SDG&E
TEMCMONY OF J. M.. HINRICHS
BEFORE THE HEARING BOARD
OF THE
SAN DIEGO AIR POLLUTION CONTROL DISTRICT
Mr. Chairman and members of the Hearing Board, my name is Jim Hinrichs.
I am a Senior Engineer in the Generation Engineering Department of the
San Diego Gas and Electric Company.and am registered as a Professional En-
gineer in the State of California. I am the Project Manager for the Encina
and' South Bay Power Plant Fallout Test Programs. These programs have been
set up to determine and correct the cause of damage resulting from acidic
particulate emissions from these two power plants.
The purpose of my presentation is to again present the results of the
test program at the Encina Plant, and describe those measures which will
achieve compliance with the requirements contained in Abatement Order 697,
issued June 10, 1976.
'The test program had its beginnings in.June, 1976, at which time we 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 contracted an in-
dependent consultant, York Research Corporation, as specified in the Abate-
ment Order, to conduct a comprehensive study to determine the source of the*
damaging particles, and a method to control those particles. That test progr
after approximately 11 months of in-depth study, is now essentially complete
The results of the test program and the recommendations for acid-fallout
abatement at Encina are as follows:
1. Reaffirming our original findings, the four boilers situated at the
Encina Power Plant do contribute to local corrosive spotting problems.
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. It must be remembered that the majority of particles
emitted from the units are extremely small, dust-like, and non-
.' corrosive in nature. The acidic fallout particles account for onjy
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 formed during the combustion of oil, which looks and acts
like a sponge. It has an affinity for liquids, so the many holes in its
structure become filled with water and acid formed during combustion.
The acid, sulfuric acid in this case, 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 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 caused by acidic particles
and not by iron rust, as was originally speculated.
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.
5. The local meteorological conditions surrounding the 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 above approximately 250 feet altitute
has no relationship with the surface wind conditions, and since the
stack plumes enter this layer, efforts to determine fallout impact and
intensity are confounded.
Based on these findings and York's recommendations, SDG&E plans to
implement the following control measures to substantially eliminate the
damaging acidic fallout from the Encina Power Plant:
1. Magnesium based fuel oil additive will be injected into the fuel
system of each boiler at Encina on a continuous basis. All Encina
boilers have been using an additive since May 6, 1977. Test data
based on ambient fallout monitoring devices indicates at least an
80% reduction in the number of acidic particles emitted from the
power plant. The additive reduces acid-fallout by both inhibiting
the formation of S03/ and thus sulfuric acid, and by neutralizing
any acid that is formed.
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. With the
additive, we are currently in compliance with Rule 52 which sets the
maximum source particulate levels at 0.1 grains/SCF.
2. Soot blowing on each boiler will be rescheduled from the present
1700 hrs. start time to 1100 hrs. 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 nea
their maximum speed with high persistence and apparently, from arabie
-4-
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 of
the plant, which is essentially unpopulated.
Implementation of this change in our soot-blowing schedule has
already begun and will continue as a standard operating practice
on all boilers.
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 equip-
ment 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 cur-
rent schedule calls for completion of the project by April, 1979,
with full operation to begin by August, 1979.
Based on the trends exhibited by the data during limited test periods, the
first two control methods, additives 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 $30,000 to $50,000 per month, mainly to purchase the additive.
To verify the effectiveness.of our proposed solution without producing
adverse side effects, we concur with the Districts position to continue the
test program until December 31, 1977.
-5-
We agree to perform the following functions: ,
1. By August 1, 1977, additive use and new soot blow procedures will be
implemented on each boiler. Currently all boilers are using additive.
2. By September 1, 1977, provided sampling sites and equipment are avail-
- able, we will set up and begin a health effects study to measure the
ambient concentrations of magnesium and magnesium compounds in accordance
with approved APCD and State Health Department methods. This study
will initially be set up to run one year from September 1, 1977 to
September 1, 1978 with the data to be supplied to the State Health
Department via the APCD. It should be noted that the primary concern
of the Health Department regarding the additive was the presence of smai:
quantities of manganese in the product. The manganese has now been
eliminated since its contribution to elimination of the fallout is minor.
3. We will set up and run particulate tests on each Encina boiler according
to the procedure outlined in the Districts position. We request to cham
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 paint
*
panels and this information will be supplied to the District on a
regular basis.
5. We will continue to pay claims to all persons whose property has been
damaged by our fallout emissions.
-6-
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 program. Expenditures
for claims have totaled about $24,000 as opposed to $1,230,000 spent
for the test program to date.
Approximately one year ago, SDG&E embarked on a program to solve a
problem which others had not solved, and to find, a solution which others
had not yet found. Through an extensive test program utilizing York
Research Corporation, and an expenditure of approximately $1.25 million
dollars, we have developed a Final Control Plan which will substantially /'
eliminate the fallout problem. Vie will continue this test program until
December 31, 1977 to satisfy the requirements of the District and this
Board.
SDG&E E!\JC!i\SA FALLOUT ABATEMENT PROGRAM
ENCINA TEST
PROGRAM
CLAIMS
0 100 200 300 400 500 BOO 700 800
EXPENDITURES TO DATE
(1,000's of Dollars)
900 1000 1100 1200 1200
35-
30-
NUMBER 25~
OF
CLAiiVIS 20.
15-
10-
5-
TOTAL CLAIMS TO DATE - 67
CLAIMS SETTLED-53
CLAIMS DENIED-14
MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC ! JAN FEB MAR APR MAY JUN JUL
1976 . .1377
MEMORANDUM
July 26, 1977
TO: Paul Bussey, City Manager
FROM: J. C. Hagaman, Planning Director)*^**"
SUBJECT:Encina Power Plant Fallout
The attached report from Mrs. Whitson of my staff indicates
that the Encina Power Plant abatement order No. 607 has been
extended to December 31, 1977 to all for further testing.
This action was based on information contained in the fallout
prepared for APCD by York Research Corporation. (A summary
is attached.) The York Research Corporation findings of
APCD are available in the department for City Council review.
It is recommended that the City Council not act on determining
if the Encina fallout problem is controlled until the current
abatement order of APCD is rescinded.
JCH: s
MEMORANDUM
.DATE: July 6, 1977
TO: Jim Hagaman, Planning 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 building
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 oi1
additive can be determined. Deadlines have set for conducting new
source tests and paint panel tests. The abatement order has been
extended until December 31, 1977 in order to allow this new infor-
mation to be obtained. In the interim SDG&E has been instructed to
continue pay ing damage claims.
The State Health Department did express concerns about the health
effects of the fuel additives. Both magnesium and manganese additives
have been used for many years on the east coast. However, no specific
studies on the health effects of these additives have been conducted.
The Health Department's primary concern was with the presence of small
quantities of manganese in the fuel additive. Since the manganese
was found to have a limited effect on the fallout, it has been eliminated
SDG&E, the APCD and the Health Department will continue to monitor the
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 York report is
attached. The report recommends use of a fuel oil additive, scheduling
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 fallout
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
-2-
Environmental Consultants
ENCINA POWER PLANT
DAMAGING FALLOUT
ELIMINATION PROGRAM
Volume 1 •- Text-
•-*.••* . i
by
York Research Corporation
One Research Drive
Stamford, Connecticut 06906
York Job Number 4-9126
Prepared for:
San Diego Gas and Electric Company
4600 Carlsbad Boulevard
Carlsbad, California 92008
r
i..
. I
A.
March 16, 1977
York Researoh Corporation
One Research Drive. Stamford, Connecticut 08906 • Telephone: (203) 325-1371 -TWX: 710-474-3947
2.0 SUMMARY
During the first phase of the program, base line conditions were
established prior to the implementation of operational changes.
The nature of the local damage caused by the Encina Power Plant
"' >.'*"•' ,Lwas found to be related to" acidified particles generated by the
bpilers and emitted from their smoke stacks. These particles
subsequently settle out of the plumes after being carried down-
wind from the plant. This acidic- fallout is dependent on the
formation of sulfur trioxide (303) and a carbonaceous carrier in
the combustion process.
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. .
Simplistically then, the solution to the damaging fallout problem
is to minimize, if not totally eliminate the formation of SO7• o
and the carrier (or neutralize the SO3 without intruducing any
new, damaging material). To eliminate the 863 is to eliminate
either the sulfur or the oxygen. To eliminate the carrier is to
eliminate the unburned carbon or to trap the particles before
-2-
the gas stream ents the atmosphere.
£' 2.1 Damaging Fallout
The characterization of damaging fallout is the key to the entire
program. At various locations in the environs of the plant in-
cluding mid-Terramar, (see Figure 1-1) sampling stations took data
every three hours for eight months. In excess of ten thousand
fallout sample collections will have been made at this writing.
In addition to the normal three hour interval collections, panels
of white paint have been placed to identify the extent of "Damage" ..* . -* • *- ~ -/• ,/",v
and/or the .lack of damage at the sampling.locations. This panel
data is presently being gathered on an ongoing basis, (see Section
6.11).
;... The damaging fallout was acidic. The possibility that it was iron
( ' .
rust was eliminated when damage spots on the paint panels were
shown to be of an acidic origin and not iron (see Section 6.11).
2.2 Test Programs
Test Programs (see Section 4.0) were of an interdisciplinary
concept designed to include source testing, atmospheric monitoring,
and combustion engineering. The source and atmospheric monitoring
are continuing on a reduced scale.
\
2.2.1 Source Emission Tests
i
Of particular interest are the particulate pH awd the SO^ emissions.
'i
The obvious need to correlate stack emissions with combustion
V engineering and ambient monitoring was frustrated by the unsuitability
-3-
ENCINA POWER PLANT AND VICINITY SHOWING LOCATION OF FALLOUT STATIONS
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of EPA methods used to determine SO-j at the normal low concen-
trations found in the Encina boilers. A superior method was
_
devised and is being continued by ongoing tests. The pH measure-
ment of the stack particulate has a low (+ 0.5 pH units) precision;
but is useful in showing trends and comparative levels.
2.2.2 Atmospheric Monitoring
The atmospheric monitoring consists of collecting meteorological
data, air quality data, and fallout data (see Section 4.2).,
•'- "', .;> " i-v'The vast quantity of data"taken were mathematically analyzed by
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 combustion engineering
group (see Section 4.3).
2.2.4 Fallout Measurement
The focal point of the study was measuring and identifying the
damaging plant fallout. Plant emissions contain many of the
constituents normally found as background around the Encina plant
but in differing amounts. A method was developed to reliably
measure the effect of plant operations on damaging fallout.
t
(General measuring equipment and techniques are discussed in .
detail in Sections 4.0, 6.0 and Appendix B). Atmospheric fallout
monitors daily measured the acidic fallout - more than.18,000 „
-4-
acid fallout evenR were recorded. The coupling of events was
frustrated by the question, "Which way and how fast was the
wind blowing?" Ground wind direction and speed were continuously
recorded; but the upper air layer above about-250 feet (see
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 the
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 change
enabled data analysis to become nearly independent of the meteor-
ological and other conditions (e.g.-a boiler out of service).
A.corroborating indicator is stack particulate average pH. This
has also developed into a data source which provides a means of
detecting in the stack whether the normal fallout is going to be
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 problem was identified,
operational changes were instituted which might best affect a
solution.
2.3.1 Additives
Since the acid is formed by sulfur dioxide being further oxidized
-5-
ftideinto sulfur trioxide with normal excess oxygen, then the addition
of magnesium oxide into the fuel would combine with the sulfur
trioxide to form magnesium sulfate. This action will neutralize
or prevent the sulfur trioxide from combining with the combustion
water to form sulfuric acid. The data show that the plant's
emitting of strong acid fallout fell to one-quarter the rate after
additives (18% of total fallout as opposed'to 80% before additives
.(see Section 5.1)). The acidity of particulates emitted from
the stacks was substantially reduced, from a pH of 2.5 before.
i
additive to 5.5. after additive-. Tests are 'continuing to ge'nerate
fallout data from the entire plant using additive rather than just
one unit.
2.3.2 Soot Blowing
v Greatest fallout intensity was first found during plant soot
blowing. Normally scheduled for early evening (1700 to 2130),
soot blowing coincided with transitional wind conditions, where
ground level winds reverse direction and exhibit minimum speed.
Upper air winds also change direction and speed but in a less
predictable -manner and usually somewhat earlier than ground
level winds.
In order to verify that increased fallout was-directly related to
soot blowing activities, independent of wind transition effects,
the soot blowing period was rescheduled at 1100 to 1530 daily.
The fallout intensity maximum also moved to the 1100 to 1400
/ period. Thus, soot blowing was established as a direct influence
on fallout.
A hypothesis developed that if soot blowing could be performed
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 determine 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)
2.3.4 Fuel Sulfur Content
The effect of fuel sulfur content on damaging fallout was measured
over a three week period burning 0.17% S Fuel. In spite of the
short time period, the ratio of damaging fallout to total fallout
was indeed reduced by this special fuel (80% strong acid fallout
count to 25% strong acid fallout count. If there were no sulfur
I
in the fuel there would be no sulfuric acid andj this small amount
of sulfur was approaching that condition. (See1Section 5.4)
-7-
2.4 Control Plan Recommendations
The program objective; mitigation of damaging fallout, is defined
in terms 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 completely in Section 7.0.
2.4.1 Fuel Oil Additive Use - . .
;:_,> .,. • .;';... '•
A magnesium based fuel oil additive should be used in all boilers
at a minimum amount for effective neutralization of acidic
emissions. This rate must be maintained throughout the range
of fuel flows in each boiler.
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 blowing in all boilers should be performed between
the hours of 1100 and 1600. This takes full advantage of
favorable winds of maximum speed and persistence to disperse
acidic particles in a narrow corridor further away from pop-
ulated areas.
2.4.3 Fuel Oil Viscosity Control
Fuel oil viscosity should be automatically controlled in each
-8-
' • -boiler to minimizq^orubustible particulate fissions. This
serves to reduce the carbonaceous carriers of sulfuric acid and
V thus reinforces other abatement measures.
2.4.4 Low Sulfur Fuel Oil Use
Fuel oil should have as low a sulfur content as possible. This
will be governed by availability. t
-.9-
7.0 CONCLUSIONS AND RECOMMENDATIONS
From the data available, a program has been developed which can
substantially eliminate local fallout damage. This damage has been
isolated to the generation, dispersion and' settling of large
-••',_.>.*..' ' . ' •
acidified carbonaceous agglomerates. Evidence from painted panels,
source emission and fallout monitoring confirms this at the Er.cina
•- Power Plant.
The following items constitute the basis of an effective control
->. ' plan which will mitigate the fallout problem:
• 7.1 Fuel Oil Additive
• The proper use of a magnesium based fuel oil additive substantially
eliminates strong acid fallout from the plant. The evidence cited
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 counts from
80% to 18%.
The use of additive is proper only when minimum effective amounts
are used. More than this will simply be expellee! from the boiler
as increased particulate matter without contributing to acid neutrali-
zation.
-236- . . -
maWith these points in mind, it is recommended mat a fuel oil addi-
tive be used in all boilers at the Encina Power Plant with control
of additive rates against sulfur content of fuels. Preferably,
this should be on a real-time basis through continuous monitoring
of fuel sulfur or S02 emissions. Consideration should also be given
to monitoring particulate pH as a final control function of additive
rate. The ratio of additive to oil must also be maintained at the
effective minimum throughout the fuel flow rates used by each boiler.
7.2 Soot Blowing Schedule " ' ,
.'..',.>.,,• ' ' '-/• .rn
The rescheduling of daily soot blowing from the present 1700 start
time to 1100 PST is recommended in order to take advantage of favor-
able wind conditions existing from mid-day through early afternoon.
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 with
the plume.
V
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. This technique
is not capable of substantial elimination of acidic fallout; there-
fore, it is not recommended considering the extra steam consumption
required and possible water shortages in the area.
-237-
7.3 Low Sulfur Fuel Oil t
Very low sulfur fuel oil use may be a helpful expedient as the data
clearly indicates. However, not enough data is available to speci-
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 incremental
changes accompanying stepwise reductions in sulfur content. This
• would establish the most productive change in terms of acidic fallout
abatement.
Certainly, however/ the use of higher sulfur content oils than are
now available should not be undertaken.
7.4 Fuel Oil Viscosity Control
Automatically controlled fuel oil viscosity should be implemented
for all boilers to reduce carbonaceous acid carriers. When viscosity
values are obtained which result in minimum unburned combustibles,
then those values should be used until there is a fuel oil change
or the burner tips are replaced. This will not solve the acidic
fallout problem, but it will make any other solution easier to
maintain.
Based on the trends exhibited by the data during limited test periods,
these recommendations will provide the Encina Power Plant with sub-
stantial elimination of the damaging fallout, as/well as minimizing
fthe total fallout that occurs in the nearby community.
-238-
ft1OUNTY OF SAN DIEGO
INTER-DEPARTMENTAL CORRESPONDENCE
DATF June 17, 1977
TO: Air Pollution Control District Hearing Board ^3 7771 .p, —_ _
THROUGH: Clerk of the Hearing Board (A45) ~~"' '
FROM: William Simmons JUN 2 8 1977
Air Pollution Control Officer (0176) -
CITY Of u-SUBJECT: ENCINA FALLOUT PROJECT: DISTRICT PETITION N0.;:-6i>7njna no^.. ~ :"'
On June 9, 1977, the Hearing Board continued the hearing on Petition No. 607
to June 23, 1977. The District then advised your board that it is prepared
to make recommendations as to the modification of the abatement order issued
to San Diego Gas & Electric Company in connection 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
SDG&E, ar.d that this report does not address the health effects, if any, of
emissions that may result from the use of the fuel oil additive which is
proposed by SDG&E as part of the overall control plan.
SDGSE end the District have consulted the State Department of Health to deter-
mine said health effects. The department has advised that certain tests need
to be conducted before an assessment can be made as to any adverse health
effects. To be determined are (1) mass, emission rates from the stacks, (2)
particle size distribution, (3) composition (both elemental and compound
specific) of the background, (4) areawide impact, and (5) other related analyses.
It also appears from the test report that with the use of a fuel oil additive
the total particulate emissions from the Encina. power plant may increase
(degree not known) even though the damaging acid-fallout will decrease.
According to SDG&E it is possible that there may be no increase in particulate
emissions once all boilers burn the additive. Assuming emissions increase, the
proposed control plan will have to be reviewed pursuant to District Rules 20.1,
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, if
any. Also, further evaluation is needed to determine possible damage on different
paint surfaces by emissions resulting from the "use of the additive.
As explained to the Hearing Board on June 9, 1977, the acid-fallout problem
arises from the formation of acid from SOs which is formed from S02 in the
presence of monatomic oxygen. S02 is created by the combustion of fuel oil
containing sulfur. Fuel oil additive inhibits the formation of S03. Another
probable solution to the acid-fallout problem is the use of low sulfur fuel,
which will result in lower emission of S02; this method should be tried if the
fuel oil additive program cannot accomplish compliance with District Rules and
Regulations. , .
- 2 -
Encina Fallout Project - June 17, 1977
DISTRICT POSITION
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 fuel oil additive, (2) source test shortly after boiler wash, using
fuel oil additive, and (3) source test using additive after the operation has
stabilized. Presently there are four (4) boilers in operation, therefore
twelve (12) tests will be required. A fifth unit.(boiler) is under construc-
tion and similar tests must be conducted after this unit is put into operation.
Pursuant to the above, the District recommends that the Hearing Board modify
the abatement order issued to SDG&E, as follows:
1. By August 1, 1977 - the use of fuel additive shall be fully implemented
on all the boilers located at Encina Power plant, Carlsbad. Also,
rescheduling of soot blowing as proposed in the control plan shall be fully
implemented.
2.
3.. Five (5) days after boiler wash, SDG&E shall conduct a source test to
determine baseline emissions.
4. Immediately after the baseline test, SDG&E shall conduct a source test to
determine emissions with the use of fuel oil additive.
5. Within 60 days of the test mentioned in '4' above, and after boiler
operation with the use of fuel oil additive has stabilized, SDG&E shall
conduct a source test to determine emissions with the use of the fuel oil
additive.
6. Tests required by condition nos. 3, 4, and 5 shall be conducted in
accordance with the procedures approved by the Air Pollution Control Officer.
Schedules for testing shall be provided the District in advance. Results
of said tests shall be submitted to the District within two (2) weeks after
completion of each test..
/" #
7. SDG&E shall determine the impact-of emissions on different paint panels
as required by the District.
8. SDG&E shall continue to make restitution to all persons whose property has
been damaged by the emissions from the Encina Power Plant.
- 3 -
Encina Fallout 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,
WILLIAM SIMMONS
Air Pollution Control Officer
WS:PS:kb
cc: SDQSE
TESTIMONY OF J. M. HINRICHS
BEFORE THE HEARING BOARD
OF THE
SAN DIEGO AIR POLLUTION CONTROL DISTRICT
Mr. Chairman and members of the Hearing Board, my name is Jim Hinrichs.
I am a Senior Engineer in the Generation Engineering Department of the
San Diego Gas and Electric Company.and am registered as a Professional En-
gineer in the State of California. I am the Project Manager for the Encina
and South Bay Power Plant Fallout Test Programs. These programs have been
set up to determine and correct the cause of damage resulting from acidic
particulate emissions from these two power plants.
The purpose of my presentation is to again present the results of the
test program at the Encina Plant, and describe those measures which will
achieve compliance with the requirements contained in Abatement Order 697,
issued June 10, 1976.
The test program had its beginnings in June, 1976, at which time we 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 contracted an in-
dependent consultant, York Research Corporation, as specified in the Abate-
ment Order, to conduct a comprehensive study to determine the source of the
damaging particles, and a method to control those particles. That test progr
i
after approximately 11 months of in-depth study, is now essentially complete
The results of the test program and the recommendations for acid-fallout
abatement at Encina are as follows:
1. Reaffirming our original findings, the four boilers situated at the
Encina Power Plant do contribute to local corrosive spotting problems.
•2-
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. It must be remembered that the majority of particles
emitted from the units are extremely small, dust-like, and non-
.1 corrosive in nature. The acidic fallout particles account for onj.y
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 formed during the combustion of oil, which looks and acts
like a sponge. It has an affinity for liquids, so the many holes in its
structure become filled with water and acid formed during combustion.
The acid, sulfuric acid in this case, 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 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 caused by acidic particles
and not by iron rust, as was originally speculated.
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.
5. The local meteorological conditions surrounding the 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 above approximately 250 feet altitute
has no relationship with the surface wind conditions, and since the
stack plumes enter this layer, efforts to determine fallout impact and
intensity are confounded.
Based on these findings and York's recommendations, SDG&E plans to
implement the following control measures to substantially eliminate the
damaging acidic fallout from the Encina Power Plant:
1. Magnesium based fuel oil additive will be injected into the fuel
system of each boiler at Encina on a continuous basis. All Encina
boilers have been using an additive since May 6, 1977. Test data
based on ambient fallout monitoring devices indicates at least an
80% reduction in the number of acidic particles emitted from the
power plant. The additive reduces acid-fallout by both inhibiting
the formation of SO.,, and thus sulfuric acid, and by neutralizing
any acid that is formed.
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. With the
*
additive, we are currently in compliance with Rule 52 which sets the
maximum source particulate levels at 0.1 grains/SCF.
2. Soot blowing on each boiler will be rescheduled from the present
1700 hrs. start time to 1100 hrs.. 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 nea
their maximum speed with high persistence and apparently, from arnbie
-4-
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 -of
the plant, which is essentially unpopulated.
Implementation of this change in our soot-blowing schedule has
already begun and will continue as a standard operating practice
on all boilers.
3. Automatic fuel oil viscosity controls will be installed on each
boiler to assure that oil combustion is optimized so as to reduce
t
the carbonaceous acid carriers, "cenospheres". Combustion equip-
ment 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 cur-
rent schedule calls for completion of the project by April, 1979,
with full operation to begin by August, 1979.
Based on the trends exhibited by the data during limited test periods, the
first two control methods, additives and soot blow chaages 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 $30,000 to $50,000 per month, mainly to purchase the additive.
To verify the effectiveness of our proposed solution without producing
adverse side effects, we concur with the Districts position to continue the
test program until December 3i, 1977.
— 5—•
We agree to perform the following functions:
1. By August 1, 1977, additive use and new soot blow procedures will be
implemented on each boiler. Currently all boilers are using additive.
2. By September 1, 1977, provided sampling sites and equipment are avail-
able, we will set up and begin a health effects study to measure the
ambient concentrations of magnesium and magnesium compounds in accordance
with approved APCD and State Health Department methods. This study
will initially be set up to run one year from September 1, 1977 to
September 1, 1978 with the data to be supplied to the State Health
Department via the APCD. It should be noted that the primary concern
of the Health Department regarding the additive was the presence of small
quantities of manganese in the product. The manganese has now been
eliminated since its contribution to elimination of the fallout is minor,
3. We will set up and run particulate tests on each Encina boiler according
to the procedure outlined in the Districts position. We request to cham
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 paint
panels and this information will be supplied to the District on a
regular basis.
5. Vie will continue to pay claims to all persons whose property has been
damaged by our fallout emissions.
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 program. Expenditures
for claims have totaled about $24,000 as opposed to $1,230,000 spent
for the test program to date.
Approximately one year ago, SDG&E embarked on a•program to solve a
problem which others had not solved, and to find a solution which others
had not yet found. Through an extensive test program utilizing York
Research Corporation, and an expenditure of approximately $1.25 million
dollars, we have developed a Final Control Plan which will substantially /
eliminate the fallout problem. We will continue this test program until
December 31, 1S77 to satisfy the requirements of the District and this
Board.
SDG&E EWCINA FALLOUT ABATEMENT PROGRAM
ENCIWA TEST
PROGRAM
CLAIMS
100 200 300
1 I I I r i
400 500 600 700 800
EXPENDITURES TO DATE
(1.000's of Dollars)
900 1000 1100 1200 1300
40 -i
35-
30-
NUMBER
OF
CLAIMS 20
15-
10-
5-
TOTAL CLAIMS TO DATE - 67
CLAIMS SETTLED-53
CLAIMS DENIED-14
___ . __ .... ..,.,.. !*.,.. M. »* ^__
MAR ^APR T MAY ' JUN r JUL ' AUG 1 SEPT ' DCT ' MOV ' DEC I JAN ' FEB ' MAR ^APR ' MAY "^JUN ' JUL
1976 . 1977