
Ammonia is a necessary and beneficial chemical at Eastshore that will enable Eastshore’s state-of-the-art air pollution control system to function properly. The ammonia will react with oxides of nitrogen (NOx) in the engine exhaust over a catalyst to convert the NOx into harmless nitrogen and water vapor, two common constituents in ambient air.Because the air pollution control system will not be 100% efficient (a physical impossibility), extra ammonia must be added to optimize the NOx control efficiency. The extra ammonia that does not react will be emitted from the exhaust stacks.
Eastshore recently committed to a substantially lower ammonia exhaust limit of 10 parts per million (ppm), exactly ½ of the 20 ppm level originally proposed.The lower ammonia slip commitment was made possible based on equipment vendor performance guarantees. As a result, the maximum annual ammonia emissions from the plant will be approximately 27.5 tons per year. This maximum emission rate is based on the facility operating at its rated capacity for 4000 hours per year, the maximum allowed operation under both the PG&E contract and the proposed Bay Area Air Quality Management District (BAAQMD) Preliminary Determination of Compliance.
There are several reasons to expect that the actual facility ammonia emissions will be substantially less than the maximum amount:
· Eastshore is not expected to operate 4000 hours per year.This is a contract and permit maximum. Modeling of historic grid performance suggests that actual operating hours would be in the range of 800 – 1000 hours per year.
· Eastshore expects that actual ammonia slip will be lower than the vendor guarantee as it is normal practice for equipment vendors to incorporate a compliance margin in their warranties
· It is in Eastshore’s financial interest to minimize ammonia emissions to the extent feasible because lower ammonia emissions will reduce Eastshore’s overall operating cost associated with ammonia consumption.
Based on the above, we expect that actual ammonia emissions will be less than 6 – 8 tons per year.
Ammonia
is one of the most common substances in the world and is a fundamental
molecule in many life processes. At the low levels expected at
Eastshore, ammonia emissions will pose no public health threat, even at
the maximum emission rate.For example, the
federal Occupational Safety and Health Administration has established
25 ppm of ammonia on an 8-hour average exposure as a safe level for
workers.The maximum Eastshore ammonia emission
level in the exhaust stack will be 2 ½ times lower than this acceptable
worker exposure level.Maximum public exposure at ground level will be over a 100 times lower than this already safe level.
From
an electrical grid distribution, reliability and cost-efficiency
standpoint, it is desirable to locate electrical generation as close to
the point of electrical interconnection and to locations of demand as
possible. Locating power plants at remote locations increases
transmission line costs and increases transmission lines losses, both
of which are directly related to the length of the transmission lines.
Higher transmission losses also mean that more fuel must be consumed to
deliver the same amount of electricity to remote consumers. Thus,
remote generation causes greater emissions and higher generation costs
per unit of electricity than localized generation.The
Adequate electricity supply is critical to the health and welfare of the residents of
Eastshore’s
contract with PG&E only specifies that the power be supplied to
PG&E when requested. Eastshore will not control the first use of
the power and cannot promise that
The
Yes.The exhaust stacks are necessary in order to allow the pressure created in the engines during the combustion process to be released.The release of pressure created during combustion is what transforms the fuel energy into the mechanical energy that drives the electric generators. If the stacks were closed off, the engines would not be capable of completing this energy transfer, pressure in the system would build up and the engines would not be able to operate.
The majority of noise-emitting equipment will be housed within a building to reduce noise emissions.Exterior
sources of noise will include the radiators, switchyard transformers,
natural gas metering and pressure reduction station, and exhaust stacks.Each will be designed and procured with low-noise specifications. In addition, the landscaped berm planned for the
During
the 18-month construction period, truck traffic will range from 8 to 23
trucks per day. Normal construction hours will be from
During normal operation, truck traffic will typically be less than 2 trucks per day. The majority of the truck traffic during operation will be associated with the delivery of 19% aqueous ammonia to the site. The plant will also require less frequent deliveries of lubricating oil, water treatment chemicals, and cleaning chemicals, and the removal of trash or, infrequently, any process wastewater that may need to be retained in the process wastewater tank because it does not meet the City’s sewer discharge restrictions. The plant will normally average approximately 3 aqueous ammonia deliveries per month. On many operating days, there may be no truck deliveries.On some ammonia delivery days, Eastshore may also receive one or at most two additional truck visits for either material delivery or waste removal. Deliveries of ammonia and other materials will be scheduled to occur during off-peak traffic hours.
Eastshore will be operated whenever PG&E determines that it has a need for power from the facility.Eastshore has no discretion under its contract with PG&E to refuse to operate on a “Spare the Air” day. If PG&E requests power on one of those days, Eastshore will be required to operate. “Spare the Air” days typically occur less than 10 to 12 days per year.
Eastshore will be required as a condition of its CEC license to maintain a hotline to receive community complaints.All complaints will be documented, investigated, resolved and reported to the CEC.In addition, the community will be able to file complaints directly with the CEC, the BAAQMD, and the City.
The residents and businesses in
The
two power plants being proposed for the City are designed to meet very
different PG&E needs. Eastshore is a peakload power plant that is
specifically intended to operate only when PG&E experiences peak
demand. For this reason, Eastshore will only be permitted to operate up
to 4000 hours per year and is anticipated to operate on average for
substantially fewer hours.The Eastshore power will be placed onto PG&E’s 115kV (local) transmission system. The other proposed power plant in
The principal hazardous material stored onsite will be 19% by weight aqueous ammonia.The aqueous ammonia will be stored in two 10,000 gallon storage tanks. The storage area will be surrounded by a berm to contain any spill in the unlikely event of a release.The ammonia solution to be stored is similar, but more concentrated than the ammonia solutions found in many household cleaning products. A worst-case offsite consequence analysis conducted for Eastshore demonstrated that offsite ammonia exposure levels would be safe even in the unlikely event of a spilling of the entire tank contents into the bermed area.
There are a variety of other chemicals that will be stored in small quantities onsite. A listing is provided below:
Chemical | Use | Storage Location | State |
Aqueous Ammonia | Control oxides of nitrogen (NOx) emissions through selective catalytic reduction | Two 10,000 gal storage tanks | Liquid |
Biocide | Biocide for diesel fuel | Hazmat Storage Locker | Liquid |
Citric Acid | Chemical cleaning of piping | Hazmat Storage Locker | Powder |
Cleaning Chemicals/Detergents | Periodic cleaning of engines | Hazmat Storage Locker | Liquid |
Corrosion Inhibitor | Cooling water corrosion inhibitor | Hazmat Storage Locker | Liquid |
Diesel Fuel | Emergency black start generator | Tank | Liquid |
Hydraulic Oil | Engine/Generators | Storage Room | Liquid |
Lubrication Oil | Engine lubricating oil | Main and used lube oil tank | Liquid |
Lubrication Oil | Coolant for electrical generator’s bearings | Tank | Liquid |
Mineral Insulating Oil | Transformers/switchyard | Extra Not stored on site | Liquid |
Oxidation Catalyst Panels | Catalyst panels for reduction of CO | In reactor vessels only | Solid |
SCR Panels | Catalyst panel for reduction of NOx | In reactor vessels only | Solid |
Sulfuric Acid (H2SO4)(in batteries) | Sealed batteries | In batteries only | Liquid |
Eastshore will be designed to meet the most rigorous Seismic Zone standards in the
Eastshore
would not cause unsafe conditions for school children. Eastshore
performed air quality modeling of the facility emissions that
demonstrates Eastshore will not cause a violation of any
No, Eastshore will not worsen anyone’s asthma. Please see the response to question 14, above. Eastshore will not cause a violation of any AAQS. The AAQSs are established with consideration for potential air quality impacts on individuals with asthma. These standards are set with a margin of safety to protect the most sensitive and susceptible individuals in the population.
No, Eastshore will not cause any safety risk for local aviation.The
FAA recently completed (January 2006) a safety risk analysis titled
“Safety Risk Analysis of Aircraft Overflight of Industrial Exhaust
Plumes”. The study concludes that the aviation risk associated with
aircraft overflight is extremely low and essentially zero. Eastshore
has also completed (and reported to the CEC) the results of an analysis
of the potential atmospheric disturbance that may be caused by
Eastshore exhaust using the only known methodology and guideline, an
Australian civil aviation safety guideline. That analysis demonstrates
that the Eastshore plumes would not pose a safety risk under Australian
civil aviation guidelines. In the above mentioned FAA safety report,
the FAA acknowledged the existence of the Australian guideline, but
neither endorsed or rejected its use.In addition, Eastshore has submitted an FAA Notice of Construction (Form 7460-1) to both the FAA and the
No, based on comprehensive health risk calculations, the plant will not cause any additional cancer cases for either the community or workers in or near the plant.The plant will use state-of-the-art emission controls that are considered Best Available Control Technology for toxics (T-BACT) by the BAAQMD.
Cancer
risk is normally calculated and expressed as a probability of
incidence. For example, the probability of a coin toss resulting in a
“heads” is 1 chance in 2. The health-protective significance threshold
for cancer risk established by the
Worst-case cancer risk calculations were completed independently by Eastshore, BAAQMD and CEC.Even assuming worst-case conditions -maximum allowable emissions, maximum allowable hours of operation,, and continuous exposure at the point of maximum ground level impact for an entire lifetime (24 hours/day, 70 years),Eastshore’s calculated maximum cancer risk is 6.7 chances per million, well below the health-protective significance threshold referenced above.The actual cancer risk will be far less than this calculated worst case value.
The BAAQMD is responsible for attaining and maintaining ambient air quality standards by implementing an Air Quality Plan (AQP).The
AQP includes a program of rules and regulations that require emission
reductions from existing sources of ozone-forming emissions (precursor
organic compounds and oxides of nitrogen), and allows emission
increases from new or modified sources only if they provide mitigation
- offsetting emission reductions in the form of emission reduction
credits (ERCs). Bay Area facilities that voluntarily reduce their
emissions or shutdown certain operations are allowed to bank their
reductions with the BAAQMD in the form of ERCs, but only if the
reductions are quantifiable, verifiable, enforceable, permanent and
certified by the BAAQMD. When new or modified facilities are permitted
by the BAAQMD, they are required to purchase and/or surrender an amount
of ERCs equivalent to 15% more than their maximum permitted emissions.
In this way the BAAQMD is able to continue to reduce emissions and
improve air quality while allowing measured economic growth in the Bay
Area. The program is reviewed annually by the
Eastshore
will comply with the BAAQMD New Source Review rule by purchasing and
surrendering BAAQMD-certified ERCs that represent a 15% surplus of
emission reductions. The actual surplus is expected to be even greater
because:
· Eastshore will operate below its permitted emission limits
· Eastshore
is expected to operated for substantially fewer hours than the 4000
hours per year of operation required in its PG&E contract
As a result Eastshore will provide overall air quality benefits to the region.
19. What about particulate matter, I heard something about using wood stoves to mitigate particulate matter emissions?
Yes,
Eastshore’s particulate matter (PM) emissions will be below the
BAAQMD’s PM offset threshold and the BAAQMD will therefore not require
PM offsets.However, the BAAQMD has typically
measured ambient PM levels that are above the PM ambient air quality
standards on some days in the wintertime. In order to ensure that
Eastshore will not cause a significant contribution to these
occasionally high wintertime PM ambient levels, Eastshore will be
proposing a mitigation program that will include wintertime PM
reductions using a wood-burning stove and fireplace replacement /
retrofit program.A program like this currently exists in