The Morro Bay Power Plant: Past, Present and Future - Part 2
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(Continued)
With city support in the form of the MOU, Duke then went ahead and filed a second CEC application on Oct. 23, 2000. It was radically different. The old plant and all its stacks would be torn down and, in their place, a completely new plant would be built with four 145-foot stacks on a different site a few hundred feet west of the existing plant, nearer the beach. Duke said it would generate 1200 MW and cost $600 million and would continue to use water from the Estuary for cooling purposes.
Duke claimed it would use less water, thereby killing less fish. Harmful chemicals in the emissions would be reduced. (Duke started out claiming the plant would be "clean" and later changed that to "cleaner" when CAPE pointed out that the smokestacks would continue to release unhealthy emissions, even if they were reduced and met regulatory standards.) It also would be smaller than the old plant and more efficient, the application said.
But during three years of investigations and hearings by the CEC on the project- and through discoveries contained in key filings by attorneys for CAPE - facts seeped out showing, contrary to Duke's claims, the proposed new plant would be built on a plot of land that would be larger than the existing plant site, its smokestacks emissions would be greater, it would generate more electricity by 20%, and it would divert more water from the Estuary, thereby killing more marine life. It would have, as Duke claimed, generated electricity more efficiently than the existing plant opened in 1955. But factoring in the risk to public health from the cancer-causing pollution released by the new smokestacks and the damage to the Estuary- the raison d'etre of Morro Bay - it would have been an atavistic step backward in time.
The CEC and the Regional Water Quality Control Board (RWQCB) are the primary agencies to review and sanction a proposed power plant, along with the U.S. Fish and Wildlife Service with respect to impacts on wildlife and habitat on land. As lead agency, the CEC grants a license to operate, and the board issues a federal permit to divert Estuary, bay or sea water and discharge it, after holding its own hearings and making a recommendation to the State Water Resources Control Board. Two other state agencies, the California Coastal Commission and the state Department of Fish and Game, make recommendations on the proposed new plant to the CEC during the review but they are important ones, especially the Coastal Commission's.
But even before the CEC started its review of the second application, two things happened that gave pause. New research findings on microscopic elements in industrial smokestack emissions, called particulate matter, began to document greater dangers of breathing it. An article in USA Today in April, 2000, reported that "even relatively low levels of the miniscule air pollutant known as particulates raise the risk of death and serious illness," based on a new study by the Health Effects Institute, a non-profit research organization supported by the U.S. Environmental Protection Agency. A scientist who reviewed the study was quoted in the article as saying it is "monumental." Another largescale study with the same conclusions soon followed.
The EPA later posted information on its web site showing particulate matter could cause a wide range of illnesses, ranging from asthma in children to premature death among those with lung or heart diseases.
Secondly, just as the CEC review was beginning in late 2001- on air quality, coincidentally- a Morro Bay resident, Pam Soderbeck, a retired attorney and Harvard law graduate, wrote two lengthy research reports with friend and fellow Harvard graduate and Morro Bay resident Bonnie Churney, who also was CAPE's attorney on air matters. (http://www.morrobaypowerplant.org/2006/10/effects-of-particulate-air-pollution-on-susceptible-populations-other-than-children/, http://www.morrobaypowerplant.org/2006/10/effects-of-particulate-air-pollution-on-children/) The reports, drawn from hundreds of studies worldwide, were on the effects of particulate matter. One of their reports stated: "The adverse health impacts resulting from even small increases in ambient concentrations of inhalable particulate matter...are quite significant and widely documented by public health professionals...These increased risks will occur at a significant level in Morro Bay as a result of the increased (particulate matter) emissions and resulting concentrations from the new (plant) as compared to the existing plant."
During the project review, a CEC staff report also stated: "...a series of studies have shown these pollutants (particulates) as capable of significant health impacts at levels significantly lower than existing standards considered adequately protective at the time they were set. Premature death is the most serious outcome in this regard as mediated through specific and non-specific cardio-pulmonary effects whose underlying biological mechanisms are inadequately understood." The report added that "major sources of fine particles are fossil fuel combustion by electric utilities."
The other study by Soderbeck and Churney said "the modeled maximum concentrations of every key pollutant increase in Morro Bay with the new (plant).
This is because of the dramatically lower stack heights (450 ft. vs. 145 ft.), lower exhaust velocity, and lower exhaust temperature, which more than offset the reduction of some emissions." And the new plant "as proposed will have significant adverse health impacts on infants and children in Morro Bay, a group making up 15.1% of the population."
The crucial point that those reports made- and the CEC staff studies would later make- was that, as one of Churney's briefs stated, "emissions are not dispersed as widely and result in increased local concentrations" of toxic pollutants falling on Morro Bay and people in it because, in large part, wind currents blow more away from Morro Bay with taller stacks than lower stacks.
But after considering those and other arguments from CAPE and its technical expert, the CEC staff ultimately sided with Duke and concluded that plant emissions would meet air quality standards, echoing the same findings of the county Air Pollution Control District (APCD). They found no significant cancer risk. This is because it was decided that Duke's planned emission controls and offsetting measures would reduce toxic pollutants to within acceptable levels. "Staff finds the combination of BACT (best available control technology) use and requirements for offsetting emission reductions as adequate to prevent the project's operations from increasing the levels of the air pollution of concern for the proposed" plant," a CEC staff report said.
Conceding in two of its briefs that "...the actual air quality impacts of the new facility (impacts are the estimated concentrations on the ground, where they would affect people) are expected to be greater than the existing facility in nearly all cases," the CEC staff said, "the applicant proposes to mitigate the emission increases from the proposed facility using a combination of clean fuel, emission control devices and emission reduction credits."
What are emission reduction credits? "Emission reduction credits (ERCs) can be created when existing permitted emission sources cease operation or reduce their operation below permitted levels," the staff report said. "The ERCs are reviewed and approved by the local air district and recorded in their 'bank' for future use." Then they are bought or traded and used by polluters such as power plants as paper credits to offset predicted actual emission increases.
The APCD District "requires MBPP to provide ERC for all net facility emission increases. To fully mitigate the facility's potential emission increases, MBPP plans to purchase ERCs from the District's ERC bank..." the CEC staff said.
"We believe that banked offsets in this case constitute real mitigation of potential impacts from the proposed project in the context of the District overall attainment strategy." In other words, they would serve to reduce calculations of overall emissions in the county's air pollution control district. But they would not actually reduce emissions themsleves in Morro Bay, and the staff reports did not claim they would.
And Duke, the staff report continued, would use some credits from its own bank- earned for the coming shut down of the old plant and for stopping the burning of oil in the 1990s, plus a few from Chevron, probably awarded for closing its oil loading yard at Torro Creek and Highway 1 some years ago. That is the method of using ERCs to offset not only increases in particulate matter but also nitrogen oxide, volatile organic compounds, sulfur dioxide and carbon monoxide, the report said.
So there would be more of these chemicals in the air and falling on Morro Bay, even though Duke would meet air quality standards- on paper. That's the way the EPA rules work- or did then during the Bush Administration.
In addition, there were disputes between CAPE on one side and the CEC staff, APCD and Duke on the other over the correct data to use it calculating the volume of emissions from the proposed plant. For example, Churney showed in a CAPE brief that the emissions rates from the plant were estimated by the vendor of the proposed new plant's gas turbines to be twice the rates that Duke stated in its application. "This data was not supplied to the APCD," she pointed out, and "would result in significantly greater adverse air quality health impacts than Duke's proposed rates, and there is no mitigation being offered for those increased emissions."
Churney went on to say, "Even assuming Duke's incorrect emission rates, the projected emissions of two criteria pollutants, PM,,,and SOx (sulfur dioxide)...go up with the new MBPP compared to the exising plant," and "all of these PM emissions from the MBPP are in fact fine, combustion particles... which have the most lethal health consequences of the particulates...."
In addition, "it is important to know that the scientific studies to date have found no indication of any safe threshold for the adverse impacts that result from increases in (particulate matter)," her brief said.
The bottom line, she emphasized, is that even if all parties could agree on measures to reduce projected real emissions- forget the ERCs- to meet state and federal standards, "this totally ignores the overwhelming evidence of very significant health effects that occur even at levels below existing standards" in California.
Many residents who attended the CEC hearings on the air quality phase of the review were worried about the pollution from the plant as well as the construction, the uncertainty over how often the emissions would be monitored by the APCD and what controls would be in effect if they exceeded limits in order to either stop plant operations or alert the town. Little was reported in the local media about what was revealed in the briefs and hearings, although CAPE circulated newsletters door to door, reporting the facts that were coming out on the potential health risks from a new plant.
At an informal meeting with a small group of residents, Gary Willey, the APCD technical expert in the review, was asked whether he would be willing to live in Morro Bay with his family if a new plant were built and operating. He said no.
There was no way of guessing how the CEC would rule on the air quality issue, but it appeared some serious questions would have to be addressed- and, at a minimum, some stricter standards would be called for.
The CEC then turned to what effects a new plant would have on the Estuary and its marine life, and Duke ran into a huge hurdle right off the bat.
At the first meeting on the biological impacts, the CEC staff shocked Duke officials and everyone else was stunned when staff members revealed they would recommended against licensing a new plant that used water from the Estuary in the once-through cooling (OTC) process for cooling plant generators. Instead, they advocated a redesign that would have the plant operate with "closed-cycle cooling," in which a finite amount (except for slight evaporation) of fresh water would be recirculated in the plant much like in a car radiator. Estuary water would not be used at all. Even then, in 2001, closed-cycle cooling was already being used and spreading elsewhere in the nation (including two of Duke's own plants in Nevada) and around the world- but not on the California coast yet. Morro Bay would have been the first.
Hearing staff's surprise recommendation, Duke officials at first were flustered, almost speechless, which then turned to thinly-veiled anger, fueled by disbelief. Except for the CEC commissioners who were presiding at the meeting, along with staff and Duke, those in the Vets Hall that night knew very little about closed-cycle cooling and certainly nothing about the roadblock that this new (to California) technology could pose to Duke's plans.
Only a few months before, the CEC had approved and its staff had supported use of OTC by two major new generating units at the Moss Landing Power Plant northwest of Salinas- another plant drawing water from an estuary. For the staff to do such a turnaround on OTC in such a short period was puzzling. Staff members were mixing with CAPE members at the Moro Bay Brewery that night after the meeting, and the biologist on the project was asked why OTC was supported by staff for Moss Landing but not for Morro Bay. "We're learning," he answered. It may never be known why the staff changed its view on OTC, but it was clear to the CEC, staff and Duke that the plant owner had its work cut out.
Certainly the driving force behind the staff's position was two percentages: 17% and 33%. The Regional Water Quality Control Board had required Duke to have its biological consultants conduct a year-long study of the marine life in the water diverted from the Estuary and into the existing plant for cooling purposes. From those water sampling data, the regional board staff and its consultants issued a report showing that between 17% and 33% of the crab and fish larvae in the Estuary would be killed in the water circulated in the plant and discharged as heated water into Estero Bay at Morro Rock. Those numbers for the first time in the plant's history put a face on what the plant had been doing to the Estuary for nearly half a century.
The CEC staff also concluded that in the absence of any Duke commitment on limits on water withdrawal, the plant would likely use its calculated maximum intake capacity of 475 million gallons of water per day from the Estuary, more than the maximum of the existing plant. Duke claimed it would voluntarily limit the plant's water use to about 370 million gallons a day on a national average, even though its own officials testified that Duke planned to run the plant as much as possible.
More importantly, the staff said, "unpredictable seasonal timing and duration of the maximum levels of water withdrawal can coincide with spawning events and therefore maximize impacts to bay/estuary life."
As a CEC staff report explained, 17%-33% "is simply the proportion of larvae taken from the Morro Bay estuary," also called "proportional mortality." "For example," the report continued, "a proportional loss of 20% for a certain estuarine species means that the power plant 'takes' 20% of the larvae produced in the estuary for that taxa. It is important to understand that hundreds of species are entrained, not just a few fish species, but it is impossible to identify and enumerate all these entrained species.Therefore, the study focuses on the most abundant fish taxa that can be identified and enumerated." (The losses would be greatest among gobies, jacksmelt and CombtoothBlennies, the study showed.)
However, the proportional mortality is unrelated to population levels of marine life in the Estuary because such levels are "nearly impossible to detect (typically, we can only detect major events like population crashes)," unless sampling were to be conducted over a long period of time.
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