Our main issue with the Russell City Energy Center

Of the many valid issues surrounding RCEC, there is one of particular concern to me.

I do not believe that the potential emissions of TACs  (Toxic Air Contaminants- hazardous emissions of chemicals such as Formaldehyde, Acrolein, and many others) have been sufficiently quantified as required by California law (AB2588 “Hot Spots” program).

According to permitting documents, Calpine intends to operate the RCEC as a spot load facility which may start up and shut down an estimated 614 times per year (there is no limit to the frequency of startups and shutdowns in the permit). During startup and shutdown, when engines are not running efficiently and pollution controls are off, TAC emission rates are potentially many times higher than when the engines are running at maximum efficiency and pollution controls are activated. As a cold start can take 6 hours, and a warm start can take 3, it is reasonable to conclude that startups and shutdowns could potentially account for a large proportion of this plant’s TAC emissions.

Calpine, the BAAQMD, and the CEC have failed to quantify the TAC emissions during startup and shutdown conditions. They have only quantified TAC emissions for periods when the plant is operating at maximum efficiency. This contradicts the text of AB2588, which states that the “maximum actual emissions or maximum potential to emit” must  be quantified, and requires that worst case scenarios be taken into account.

To be more specific, I believe that there are serious shortcomings with the following assertions from Calpine re. (TAC) Toxic Air Contaminant emissions from RCEC:

While all of Western Alameda County has been identified as one of six “priority communities” within the Bay Area under proposed revisions to the Air District’s program for permitting sources of toxic air contaminants (along with (1) Concord, (2) Richmond/San Pablo, (3) San Jose, (4) Redwood City/East Palo Alto, and (5) Eastern San Francisco), the Air District _specifically found that RCEC would meet even the more stringent thresholds imposed for such “priority communities”:_

“The Air District has recently issued a proposal to establish more stringent air permitting requirements for toxic air contaminants as a measure to address cumulative air pollution in more highly impacted communities. This proposal, if adopted, would represent the most stringent air permitting requirements for TACs in the country, as far as District staff are aware. The approach involves reducing the allowable project risk thresholds by a factor of two for projects located within more highly impacted communities. The maximum project risks for Russell City Energy Center are much less than these proposed more stringent project health risk standards.”

(BAAQMD, August 3, 2009, Additional Statement of Basis, p. 97; available at: _http://www.baaqmd.gov/~/media/Files/Engineering/Public Notices/2009/15487/B3161_nsr_15487_fsb_080309.ashx_ <http://www.baaqmd.gov/%7E/media/Files/Engineering/Public%20Notices/2009/15487/B3161_nsr_15487_fsb_080309.ashx>.)

….

In light of the series of detailed technical analyses of the project’s emissions and potential impacts on health, there simply is no basis in science or fact for alleging that RCEC’s emissions will harm the students, faculty or staff of CLPCCD or anyone else in the community.

The Air District’s initial Statement of Basis reported that, the Air District has undertaken a detailed review of the public health impacts of the emissions authorized under the proposed permitting action, and has found that they will involve no significant public health risks.

The health hazards posed by the highest possible concentrations of air contaminants caused by the project are below what the Air District, EPA, or any other public health agency considers to be significant

To put these hazards in context, the increased cancer risk was found to be than one in a million (0.7 x 10-6). As a point of comparison, the California Air Resources Board recently found that the increased cancer risk to residents of West Oakland from truck traffic alone is 951 in a million (951 x 10-6), or more than a thousand times greater than the risk from the highest modeled exposure to RCEC’s emissions.

Fortunately for the public, it is not the responsibility of local community members (though it sure feels like it sometimes) to find a “basis in science or fact that the RCEC’s emissions will harm” the surrounding community. On the contrary, the burden rests with the RCEC and permitting agencies to find a basis in science and fact that the RCEC will operate in a manner that will not harm the community.

To succinctly summarize this issue:

1. RCEC has insisted that startups and shutdowns not be limited. The CEC and BAAQMD have sought to accommodate the RCEC in this regard, creatively applying existing regulations to meet RCEC’s objective. There are no permit restrictions that directly limit the frequency and quantity of startups and shutdowns, though there are limitations on annual criteria pollutant output.

2. Startups (which can take 3-6 hours using the less efficient RCEC technology) and shutdowns occur with emission control systems disabled, until operational conditions at the plant are suitable for their use (ie. until the plant is “warmed up”). During this period, TAC emissions may be hundreds of times higher than during normal full load operation due to incomplete combustion of fuel.

3. The CEC and BAAQMD air quality experts have expressed concerns re. unlimited startups and shutdowns, both formally and informally, due to the difficulty of determining cumulative project emissions. The parties have agreed to estimate the number of startups and shutdowns at approx 614 per year for the purposes of obtaining emissions credits.

4. When the BAAQMD/CEC performed the TAC quantification and the Health Risk Analysis, the emissions were estimated under assumptions that the plant would be operating at full load (maximum efficiency) with all emission control systems operational (ie. when TAC controls are most efficient). There is sworn testimony re. this assertion from multiple parties in both the RCEC and the Eastshore Energy Center cases. No quantification of TAC emissions, and thus no Health Risk Analysis has been performed for startup and shutdown conditions.

5. It appears that RCEC has a reason to seek an unlimited number of startups and shutdowns. It has been acknowleged by the CEC and the BAAQMD in official documentation, though curiously downplayed if not objected to outright by Calpine, that the RCEC is to be used as a spot-load facility, which will start up and shut down due to demand peaks. Demand peaks tend to occur twice per day during the hotter months. Calpine has strenuously denied that RCEC is a “peaker”, ostensibly because a plant classified as a “peaker” would be subject to limitations on startup and shutdown frequency as well as annual operating hours.

6. Despite repeated inquiries, Calpine, the BAAQMD and the CEC have completely avoided the issue of TAC emissions during startup and shutdowns. They have neither quantified these emissions, nor provided any evidence that such emissions are not significant. Given the expected high frequency of startups and shutdowns, and their potential for excessive TAC emissions relative to the baseline, the omission of this important emission source is alarming.

7. The non-regulation and non-quantification of TAC emissions during startups and shutdowns raises serious questions. The insistence of the RCEC on unlimited startups and shutdowns, and the resulting accommodation by BAAQMD and the CEC has apparently nullified the part of California environmental law which requires that the “maximum potential TAC emissions” from a facility be quantified. The appearance here is that a regulatory loophole is being exploited to allow for existing facilities, originally permitted to operate under “normal conditions”, to convert to a potentially inefficient and hazardous, though lucrative, mode of operation supplying peak load power without having to account for increased TAC releases.

8. RCEC and/or the BAAQMD could address this issue by either quantifying startup and shutdown TAC emissions and conducting a health risk analysis, or demonstrating why startup and shutdown emissions are exempt from environmental regulations. Their refusal to do either, while making affirmative statements about how their facility meets stringent TAC emissions limits, is damaging to the credibility of both organizations and is a significant source of suspicion and concern in the community. It is difficult to avoid the conclusion that if RCEC and the BAAQMD quantified TAC emissions during startup and shutdowns, additional permit conditions may be required that would not be aligned with RCEC’s goals in operating the facility.

I would ask that the parties involved desist from claims that the health risk of the RCEC facility has been fully analyzed and found to be safe. Given that the analysis to-date omits this potentially significant mode of operation, such claims may be misleading, and certainly do not further the interests of the public, which will only be served by a full quantification of TAC emissions from this facility.

Please demand that the BAAQMD adhere to state law and, as a mandatory condition of issuing a permit, quantify and regulate the RCEC’s emissions of Toxic Air Contaminants during the long and potentially frequent startups and shutdowns.