Citizens for Clean Energy, Inc.

www.cce.org  email: cce-mt@bresnan.net

615 Third Avenue North

Great Falls, MT 59401

 

3/18/2007

 

Mr. Richard Fristik

USDA Rural Development Program, Utilities Programs

1400 Independence Avenue, SW

Mail Stop 1571, Room 2237

Washington, D.C. 20250-1571

 

Dear Mr. Fristik:

 

My primary concern after reading the FEIS is that the justifications given and data provided are neither timely, complete nor accurate.  The shortcomings I will point out are more serious than a simple oversight as if the application had not been signed. Yet if the application were not signed the permit would be denied on that basis alone no matter how complete, accurate and justified the application is. Major concerns are as follows -

 

 

 

 

 

There is no shortage or crisis that compels a rush to judgment.  A rational decision is not easy because we are caught in changing times making any predication of future conditions more uncertain.  We can easily delay the construction of HGS until some of the current trends are more clearly defined.

 

1. Need misrepresented and are estimates.

 

There is no question of availability.  The only question SME raises is at what price can electricity be purchased and from whom?  Montana is a net exporter of electricity now and more projects of various types are in development.  Current studies and news stories show there is a skyrocketing inflation of new coal fired power plants due to the current rush to build new plants.  This boom in coal plant construction brings with it a risk of shortages, delays and cost overruns. These plants are being built where there are shortages and real need so the higher cost is justified.  Current studies show if HGS is built, the cost per KWH would be nearly the same as the full retail residential rate the customers of Northwest energy are paying now.  Since the load forecast has failed to materialize and in fact has decreased, it would seem the real purpose of HGS would be to sell the electricity on the open market i.e. a merchant plant.  Given the inflated price in a market with no shortage and more private projects in development, what is the true purpose of building HGS? The purpose is definitely not need of electricity by rural customers in Montana, the only issue addressed is cost and risk is ignored.

 

Although written in 2006 with references cited in DECEMBER 2006 and published in 2007, any empirical data of energy use ends in 2003.

 

Since there is now empirical data FROM 3 YEARS to test the theory of projected growth in the following categories from table 1-2 FEIS, THE EMPIRICAL DATA SHOULD BE EXAMINED TO DETERMINE THE ACCURACY OF THE PROJECTED.

 

   ACTUAL USE FROM TABLE 1-2 FEIS FOR 2003

 

   2003 - 486,526 MHh

 

   PROJECTED GROWTH BY CATAGORY 2004 - 2006 FROM TABLE 1-2.

 

   RESIDENTIAL                              8.25%     27,172 MWh    

   SMALL COMERCIAL                   5.09%      2,612 MWh    

   LARGE COMERCIAL          328.55%    102,103 MWh    

   IRRIGATION                               -(2.59%)      -515 MWh    

   OTHER SALES                               0.042%        42 MWh    

   OWN USE AND LOSSES            38.56%    17,251 MWh

    

   PROJECTED TOTAL GROWTH OF    148,665MWh

 

   ACTUAL USE REPORTED BY DOE 2004 - 2006

 

   2004 - 431,979MWh 

   2005 - 472,439MWh 

   2006 - Not posted    

 

   *Note 2005 actual use is LESS than 2003 actual use of 486526 MWh

  

   PROJECTED USE BY 2006 = 486,526 MWh + 148,665 MWh = 635,330 MWh

  

There are plans and projects in development to bring hundreds of megawatts of power on line by the time HGS gets built. No project of any kind was considered in predicting need.  There are groups in SME's area actively pursuing clean sources not owned or supplied by SME.

  

2. Failures in alternatives examined

 

   a. Power purchase agreements were eliminated because of higher contract prices, yet at the same time SME is preparing customers for higher prices because it is deemed inevitable no matter whom the supplier is.  SME claims power purchases will contribute the same amount to pollution when in fact the power may be purchased from hydroelectric sources.

 

   b. Wind sources were not seriously considered.  Although it is true there is a probability the wind will not be blowing during peak demand it is also an absolute given fact that the HGS will be shut down at times for maintenance and there is a probability that the plant will have an unexpected shutdown or at times be shut down rather than operate at a loss.  Having a single source of generation greatly exacerbates the element of risk.  The only remedy of shutdowns is purchasing power.  It is a forgone conclusion that shutdowns will happen some percentage of the time, yet SME's argument is that this is the reason for excluding wind as a source.  No amount of data analysis was ever shown.  Historic wind data needs to be correlated with base and peak electricity usage.  Since wind energy is less expensive to start with and has no element of risk of higher prices due to increased regulation or rising fuel prices, there is more room for purchasing power.  The amount of money saved and available for power purchases needs to be calculated. Furthermore there is a percentage of the population willing to pay a premium for truly clean energy.

 

   c. IGCC facts outdated and grossly misrepresented.  Major venders now offer wrap projects with guaranteed performance. The new IGCC plants have proven performance better than the guaranteed performance.  Attached is a spreadsheet from the DOE available in 2004 showing IGCC technology around the world. www.netl.doe.gov/technologies/coalpower/gasification/database/GASIF2004.xls  I have also included a 2007 PDF document.  www.nykomb.se/pdf/IGCC_summary.pdf  IGCC is now considered to be reliable and proven. NGCC plants now have plans to convert to IGCC for economic reasons virtually insuring the demand on coal to increase and prices to increase. Tim Gregory shot down IGCC in a public presentation stating it was not economic because the gas was worth more than the electricity.  Failing to take into consideration the economics of selling the gas when the electric power of such an oversized plant is not needed shows a serious lack of consideration.  FEIS states "no advantage in pollution control other than the potential to sequester carbon dioxide", when the reason for the current rush to build IGCC plants is primarily the greater efficiency producing less pollution of all types regulated or not and the greatly improved ability to control pollution of all types regulated or not, greater ability to modulate output to meet demand, flexibility of fuel types and the economics of having a petrochemical plant for value added products or selling the gas directly.  The government is pursuing rapid deployment of IGCC through tax breaks and cost sharing, something HGS does not qualify for, making the percentage of higher cost irrelevant and the advantages a freebie.

 

   d. Combination wind with NGCC or IGCC peaking or firming not seriously considered.  No data analysis was performed. To evaluate the economics of wind and any combined cycle, historic wind data needs to be correlated with base and peak electricity usage for a cost analysis. 

 

   e. Risk from technological advancements ignored. Advances in large-scale stationary solid oxide fuel cell used in public distributed generation or owned by industrial customers or small scale owned by residential customers for private power by 2018 (year predicted for actual base load generation from HGS) is an economic risk to HGS. Prices of power from fuel cells are rapidly dropping while cost of traditional electricity as pointed out by Tim Gregori is increasing. Thousands of home combined heat and power fuel cells have been operating as demonstrations in Japan and Europe for years.  Large-scale demonstrations have been operating in the U.S. for years. The DOE NETL SECA project 2006 report <http://www.netl.doe.gov/technologies/coalpower/fuelcells/pdf/FY06-FuelCellProgramReport.pdf> announced the target price of less than $300/KW has been surpassed and there is a current design that has operated for thousands of hours with none of the degradation expected making fuel cells competitive with fossil fuel generation at todayÕs prices.  The DOE figures refer to stack cost only and do not take into consideration the majority will operate as combined heat and power or in a combined cycle to bring the efficiencies up to the 60-80% range. Siemens is constructing a multi-megawatt demonstration plant in Germany to show this technology. Since industrial and residential customers will own their own units, the cost must reflect what the customer pays for power plus transmission and not the cost of generation by a power plant owner for sale. Furthermore the government is actively pursuing rapid deployment through tax breaks, something HGS does not qualify for. The NETL SECA project is on track and scheduled to end in 2010, making these units commercially available before HGS can complete construction. The future of electricity is clean distributed generation.

 

4. Environmental

 

      Referring to the causes-effect Questions Page 4-3 FEIS, the vast majority of particulate emissions modeled at the plant sight comes from sources other than the stack. The plant is on a high point with downward sloping terrain into drainages in 3 directions. At night, when calm, "downwash winds" will carry particulates down the drainages to belt creek and the Missouri river to be concentrated in the Missouri river drainage ecosystem. Very strong Chinook winds will blow coal dust and ash at times across the Lewis and Clark Portage Landmark. The decompressive forces of the wind over the bluffs will have a tendency for drifting action concentrating heavy elements into the same ecosystem. A serious oversight of environmental effects not considered.

 

      Using fugitive emission methodology - Control of Open Fugitive Dust Sources (9/88) - in lieu of the updated AP 42 13.2.5 Industrial Wind Erosion, is inappropriate in this case. No amount of detailed Meteorology was used, only Òdays over 12 mphÓ to come up with a steady state emission of .05 grams/second per square meter. Local wind conditions are some of the most extreme in the nation. Daily peak wind gusts recorded between 1942-2002 averages out to 28.8 mph.  Monthly averaged peak wind gusts top out at 31.6 mph in December and are at a minimum of 27.6 mph in August.  The peak wind gust recorded at the Great Falls International Airport was 92 mph.  Higher gusts may have happened but power failures during these events prevent any record.  Given that the force of the wind is a square law, Kinetic Energy =(1/2)Mass(Velocity(squared)), the amount of particulate matter from wind blown sources was grossly underestimated and inaccurately modeled as a steady state emission of air with no gravitational effects. Besides the ash and coal piles, any partially or fully enclosed industrial processing that is not sealed cannot maintain a negative pressure in these nationally extreme but locally regular conditions.  Although a majority of strong winds come from the southwest, Great Falls has a history of strong winds in all directions making the city subject to particulate emissions not considered.

 

5. Technical Points

 

The PSD application contains spreadsheets showing the outputs of the updated AERMOD modeling program submitted Dec 15, 2006.  As of Dec 7 the newer AERMOD version 06341 was available.  The spreadsheets are dated NOV 28.  Examining the output files referenced in the spreadsheets show dates of  DEC 7 Ð 9.  It is recommended to use the most recent readily available data.  All met data ends in 2003.

 

The PSD application shows emission calculations used the maximum expected emission rates for short term averaging periods using the heat rate input of 2771 MMBtu/hr and long term using the annual average heat input rate of  2,626MMBtu/hr.  I do not have access to the commercially available emission factor sources used.  Examining the AERMOD emission rates for 1-hr and annual for SOx  shows 19.8975855 grams/second for hourly and 12.5733286 for annual, annual being 63.2% of hourly.  Similarly NOx shows 34.9089731 for hourly and 23.1621906 for annual, annual being 66.3% of hourly.  Does this imply that on an annual average HGS will operate at 63% or 66% of  capacity?

 

According to APPENDIX W sec 8.3 met input data should be latterly representative.  This is debatable for the sight considering the proximity to the drainages and primary plume travel down the Missouri River.

 

AERMOD can be used to treat dry and wet deposition for both gases and particles.  No effort was made to use these options. 

 

Fugitive emissions from wind erosion are not continuous.

 

From APPENDIX A to APPENDIX W - A.1 a. (1) AERMOD is appropriate for continuous toxic air emissions. 

 

From APPENDIX W 5.2.2.2

 

d. Under certain conditions, recommended dispersion models may not be reliable. In such circumstances, the modeling approach should be approved by the Regional Office on a case-by-case basis.

e.  ... Fugitive emissions include the emissions resulting from the industrial process that are not captured and vented through a stack but may be released from various locations within the complex. In some unique cases a model developed specifically for the situation may be needed. Due to the difficult nature of characterizing and modeling fugitive dust and fugitive emissions, it is recommended that the proposed procedure be cleared by the Regional Office for each specific situation

 

APPENDIX W 7.2.7 Gravitational Settling and Deposition

 

b. Gravitational settling and deposition may be directly included in a model if either is a significant factor. When particulate matter sources can be quantified and settling and dry deposition are problems, professional judgment should be used, and there should be coordination with the appropriate reviewing authority (paragraph 3.0(b)).

 

FEIS Table 2-6 shows a capitol cost 69.8% higher for IGCC than CFB when all other claims are 20% higher on the high end and Variable/Fuel 54.7% higher when IGCC plants are more efficient and use less fuel.

 

FEIS table 2-7 shows SO2 emissions 284.2% higher for IGCC than CFB(HGS) when sulfur is removed prior to combustion in IGCC.

 

FEIS Table 2-8 shows a total cost of HGS $469,555,000.

 

FEIS Table 2-9 repeats 69.8% higher figure for capitol cost 54.7% higher fuel/variable cost and then claims less than 80% Capacity factor when new IGCC plants have demonstrated above 90%.

 

FEIS Table 4-4 lists potential to emit 376tpy for PM and 366tpy for PM10.  The PSD application Table 3.1-1 lists 422tpy for PM and 409tpy for PM10

 

     In conclusion:  What I have read in the FEIS reeks of the spin of a salesman.  Given the problem of trying to make a decision now considering the enormity of a project that will affect hundreds of thousands of people for fifty years, during a time that the national psyche is changing and we are overwhelmed with an exponentially increasing rate of technological change, it is vitally important to make an attempt to base that decision on timely, accurate and complete facts.  Something SME has failed to provide.

 

Sincerely,

 

 

Ed Mcknight

Citizens for Clean Energy Member