The 1640 MW coal-fired Chesterfield Power Plant is on the James River near Richmond, VA
From an Article by Sarah Vogelsong, Virginia Mercury, March 19, 2019
A proposed new natural gas-fired power plant in Charles City County, which, if built, would be among the largest power generators in the state, has sparked few objections, even as other new gas infrastructure has faced a contentious path to approval.
Only three people spoke at a hearing hosted by the Virginia Department of Environmental Quality March 5 on the granting of a “prevention of significant deterioration” permit for the planned Chickahominy Power Station.
The permits are required for the construction of any new air pollution source that emits more than 100 tons per year of any of a set of pollutants identified by DEQ, including sulfur dioxide, carbon monoxide and particulate matter, among others.
For Charles City Supervisor Bill Coada, who attended DEQ’s March 5 hearing, there was little to fear from the proposed natural gas power station. “Of course we have concerns about the air quality,” he said. But, he added, “if you compare it to a coal-fired unit, you’ll find these are much cleaner.”
The Chickahominy Power Station is being developed by Chickahominy Power, LLC, a subsidiary of Balico, LLC, that was formed for the purpose of developing and operating the facility. Plans submitted to the State Corporation Commission and DEQ describe it as a combined-cycle natural gas generation facility with three turbines that will be capable of producing 1,650 megawatts. By comparison, Dominion Energy’s recently finished Greensville combined cycle power station is 1,588 megawatts and the company’s coal-fired Chesterfield Power Station is the largest fossil-fuel plant in Virginia at 1,640 megawatts.
As an independent power producer, Chickahominy would sell its power directly to the PJM Interconnection wholesale market. Located just over half a mile east of the intersection of Chambers and Roxbury Roads, the project’s 185-acre site surrounds Dominion Energy’s existing Chickahominy Substation and is crossed by two of Dominion’s transmission lines and a Virginia Natural Gas pipeline.
Documents from DEQ show that of 10 proposed emission constituents, seven are above the threshold set by the department to classify a facility as a major stationary source of the pollutant. These include three types of particulate matter, nitrogen oxide, carbon monoxide, volatile organic compounds and carbon dioxide equivalents.
Mary Finley-Brook, an associate professor of geography and environmental science at the University of Richmond aired concerns about the level of emissions that the plant is expected to produce at the March 5 hearing and recommended that the project be sent to the State Air Pollution Control Board for review.
“The one actually that concerns me the most would be the greenhouse gas emissions, so the carbon dioxide equivalent,” she told DEQ. “One of the main reasons why I think this permit should be rejected is because we are looking to limit our greenhouse gas emissions from our fossil-fuel sector.”
Steve Fuhrmann of Providence Forge also cited worries about emissions. “We already have a higher incidence than normal of both [chronic obstructive pulmonary disease] and asthma in this county, and any additions to our polluting atmosphere … is of great concern,” he said. (VDH maps show that relative to other areas of Virginia, Charles City County and the surrounding region show higher incidences of asthma.)
An engineering report by DEQ has found that “approval of the proposed permit is not expected to cause injury to or interference with … health.” As a further safeguard, the department has also attached to its draft permit the requirement that the facility carry out continuous emissions monitoring, which will constantly track and record the pollutants the power station is producing.
A ‘sudden surge of interest’ in new power production
Still, for some residents, the proposed Chickahominy Power Station is only the tip of the iceberg.
The project is the third major energy generator proposed for the county in the span of four years. In 2015, the Board of Supervisors approved a special use permit for the C4GT power station, another natural gas facility that Michigan-based NOVI Energy says it plans to develop on 88 acres less than a mile from the Chickahominy facility.
The C4GT facility, which has not begun construction (earlier this month, the SCC granted its certificate of public convenience and necessity a two-year extension), has a planned capacity of 1,060 megawatts.
Finally, this spring, the board is considering ambitious plans by Utah-based sPower to construct a 340-megawatt solar farm on more than 2,000 acres of land previously used for timber. While that project has not yet received the special use permit it needs to move forward in the county, the Charles City Planning Commission showed little opposition to it, voting 5-1-1 to recommend its approval.
If all three facilities are built, Charles City County will become one of Virginia’s biggest power producers, according to data collected by DEQ. “Geography has dictated this sudden surge of interest in Charles City County,” Coada said.
Balico director of development Jef Freeman, Jr., said growth in Virginia’s data centers is a primary driver of Balico’s interest in the Chickahominy project. “It’s really driven by the economic activity that’s going on in the region,” he said. “Data centers themselves require significant amounts of energy to support what they do and very reliable power.”
However, many of the companies building data centers are increasingly pushing to power them with renewable energy.
Charles City County, for its part, has highlighted the desire to develop its industrial assets in its 2014 Comprehensive Plan, which calls for the creation of a second industrial park, industrial reserve areas and a new industrial corridor overlay district.
Still, the handful of residents at the March 5 hearing expressed qualms about how the combination of new power generators might affect air quality overall.
Stanley Faggert, the DEQ’s minor new source review coordinator, said the agency had included the projected emissions from the C4GT plant in its air quality modeling for the Chickahominy Power Station. “We do model the background and we take into account existing sources around the facility,” said Michael Dowd, DEQ’s Air and Renewable Energy Division director. “It’s something we look at carefully.”
Fuhrmann asked that if DEQ decides to grant the permit, it take steps to do additional monitoring, as the closest monitoring station, at Shirley Plantation, sits in the opposite direction from prevailing winds relative to the Chickahominy Power Station. Dowd, however, said that the Shirley monitoring station “is darn close as far as monitoring goes” and observed that “many of these air quality impacts are regional in nature and not local.”
For Coada, the question comes down to not only the need for Charles City County to expand economically, but Virginia’s broader attempts to embrace clean energy. “When you look at what it’s replacing,” he said, “it’s actually doing the commonwealth a favor.”
Not everyone agrees. Thomas Hadwin, a former electric and gas utility executive in New York and Michigan who lives in Waynesboro, said that approval of the project “may not be good energy policy in the long run.”
Besides emitting significant amounts of greenhouse gases, he said, the plant would consume a large amount of Virginia Natural Gas’ supply to the region, which VNG has indicated is constrained. Furthermore, Hadwin questioned whether the demand exists in Virginia for two new major natural gas plants.
PJM, the regional transmission organization that coordinates wholesale electricity in all or parts of 13 states and the District of Columbia, including Virginia, is expecting capacity to significantly outstrip demand in the near future, according to data from the organization. Dominion has said it has no plans to build new combined-cycle natural gas facilities.
And C4GT, which this March petitioned the SCC to extend its certificate of public convenience and necessity for an additional two years, justified the project’s delay on the basis of “unexpected change in market for additional electric generating capacity.”
“These people are trying to move into a marketplace that’s already flooded with capacity,” said Hadwin.
Freeman, however, said that Chickahominy Power would not be pursuing a project that it didn’t think was viable. “There’s a lot that goes on behind the scenes to determine this kind of project,” he said, adding that “even with the two projects that are proposed, neither are assured of proceeding.”
The comment period for the VA-DEQ’s draft permit for the Chickahominy Power Station ended on March 20, 2019.
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From: Blue Ridge Environmental Defense League
8260 Thomas Nelson Highway, Lovingston, Virginia 22949,
BREDL@skybest.com(434) 420-1874
http://www.BREDL.org
DATE: March 20, 2019
To: Alison Sinclair, VA-DEQ,
Virginia Dept. of Environmental Quality, P.O. Box 1105,
Richmond, VA 23218 alison.sinclair@deq.virginia.gov
RE: Balico LLC; Registration No. 52610
Balico LLC/Chickahominy Power, 1380 Coppermine Rd. Ste.115, Herndon, VA 20171
Dear Ms. Sinclair:
On behalf of the Blue Ridge Environmental Defense League and our members in the Commonwealth of Virginia, I write to provide comments on the permit for the proposed Chickahominy Power facility in Charles City County. For the reasons detailed below, we oppose the permitting of this facility.
Background —-
According to Balico LLC’s application, the Chickahominy Power plant (“CPLLC”), if permitted, would be constructed as a 1650 Megawatt combined-cycle electric generation facility utilizing three combustion turbines fueled with natural gas. The plant would use supplementally-fired heat recovery steam generators and steam turbines. Air pollution control would include dry low nitrogen oxides burner technology, oxidation catalysts, and evaporative-inlet air cooling.1
Comments — Air Pollution
Combustion turbines are remarkable for their lack of efficiency in converting chemical energy to mechanical energy. Part of the output is lost the in compressor where intake air is compressed up to 30 atmospheres of pressure, before the fuel is burned. Accordingly, “More than 50 percent of the shaft horsepower is needed to drive the internal compressor and the balance of recovered shaft horsepower is available to drive an external load.”2
Combined cycle units that utilize heat recovery steam generators have an efficiency of 38 to 60 percent. This means that from 40 to 62 percent of the fuel burned produces no electric power. But air pollution and global warming gases are created by combustion whether power is produced or not.
1 CPLLC’s August 24, 2017 Application amends CPLLC’s April 5, 2017 Application, which replaced CPLLC’s initial March 13, 2017 Application. The August 24, 2017 filing also amends Exhibit I, Responses to 20 VAC 5-302- 20. On April 13, 2017, CPLLC filed supplemental Exhibit 4 to its Application, a map identifying the location of the proposed facility for notice purposes. On August 16, 2017, CPLLC filed supplemental Exhibit 5, a July 2017 Environmental Assessment of the Project Site. CPLLC identifies 1,650 MW as the net nominal generating capacity of the proposed Facility at 95 degrees Fahrenheit ambient temperature.
2 US EPA Air Pollution Emission Factors, AP-42, Stationary Gas Turbines, Section 3.1.2 Process Description
Moreover, how the turbines are operated affects air pollution emissions and efficiency. This may result in underestimated levels of toxic air pollution. According to the US Environmental Protection Agency:
Available emissions data indicate that the turbine’s operating load has a considerable effect on the resulting emission levels.
Gas turbines are typically operated at high loads (greater than or equal to 80 percent of rated capacity) to achieve maximum thermal efficiency and peak combustor zone flame temperatures. With reduced loads (lower than 80 percent), or during periods of frequent load changes, the combustor zone flame temperatures are expected to be lower than the high load temperatures, yielding lower thermal efficiencies and more incomplete combustion.3
The products of incomplete production—carbon monoxide and PM-10—increase with reduced operating loads. Before issuing this permit, the DEQ must assess the impacts of operating factors. Best available control technology for criteria pollutants and maximum achievable control technology for hazardous air pollutants are the standards which must be required for the Chickahominy Power plant.
Climate Change —-
The use of natural gas as a fuel is not an acceptable alternative to coal-fired power. The gas at the proposed Chickahominy plant would largely be supplied by hydrofracking. According to the Union of Concerned Scientists:
The drilling and extraction of natural gas from wells and its transportation in pipelines results in the leakage of methane, primary component of natural gas that is 34 times stronger than CO2 at trapping heat over a 100-year period and 86 times stronger over 20 years. Preliminary studies and field measurements show that these so-called “fugitive” methane emissions range from 1 to 9 percent of total life cycle emissions. Whether natural gas has lower life cycle greenhouse gas emissions than coal and oil depends on the assumed leakage rate, the global warming potential of methane over different time frames, the energy conversion efficiency, and other factors. One recent study found that methane losses must be kept below 3.2 percent for natural gas power plants to have lower life cycle emissions than new coal plants over short time frames of 20 years or fewer. And if burning natural gas in vehicles is to deliver even marginal benefits, methane losses must be kept below 1 percent and 1.6 percent compared with diesel fuel and gasoline, respectively. Technologies are available to reduce much of the leaking methane.4
Natural gas is not a “bridge fuel” because it does not reduce the emissions of greenhouse gases.
Environmental Justice —
The most recent available census data reveals that Charles City County with a total population of just over 7,000. The county’s population is 43.3% white, 45.9% African American and 6.9% Native American.5
Many studies have shown that hazardous and solid waste facilities, industrial plants, and power stations of many types have traditionally been sited disproportionately in communities of color and low-income neighborhoods. In addition to being aesthetically unappealing, power plants emit toxic air pollution which has a negative effect on the health and well-being of plant neighbors. Low-income communities often lack the economic or political clout to fight these facilities. A review of environmental justice and equity law by the American Bar Association and the Hastings College of Law revealed the following:
Poor communities of color breathe some of the least healthy air in the nation. For example, the nation’s worst air quality is in the South Coast Air Basin in Southern California, where studies have shown that Latinos are twice as likely as Whites to live within one mile of an EPA Toxic Release Inventory listed facility, and Latinos, African Americans, and Asian populations in the region face 50% higher cancer risks than Anglo-Americans in the region. Advocates nationwide argue that because poor people of color bear a disproportionate burden of air pollution, their communities should receive a disproportionate share of money and technology to reduce toxic emissions, and that laws like the Clean Air Act should close loopholes that allow older, polluting facilities to escape pollution control upgrades.6
Walter Fauntroy, District of Columbia Congressional Delegate to Congress, prompted the General Accounting Office to investigate environmental justice issues. The GAO released its findings that three-quarters of the hazardous waste landfill sites in eight southeastern states were located in primarily poor, African American and Latino communities. United Church of Christ’s Commission for Racial Justice published Toxic Wastes and Race in the United States, which revealed that race was the single most important factor in determining where toxic facilities were located, and that it was the intentional result of local, state and federal land-use policies.
4 Environmental Impacts of Natural Gas, http://www.ucsusa.org/clean-energy/coal-and-other-fossil- fuels/environmental-impacts-of-natural-gas#bf-toc-1
5 https://www.census.gov/quickfacts/fact/table/charlescitycountyvirginia/PST045217
6 Environmental Justice for All: A Fifty State Survey of Legislation, Policies and Cases (fourth ed.), Steven Bonorris, Editor , Copyright © 2010 American Bar Association and Hastings College of the Law. With citation, any portion of this document may be copied and distributed for non-commercial purposes without prior permission. All other rights are reserved. http://www.abanet.org/environ/resources.html or http://www.uchastings.edu/cslgl
Dr. Robert Bullard published Dumping in Dixie: Race, Class, and Environmental Quality, in which he showed the importance of race as a factor in the siting of polluting industrial facilities.7
Virginia Law Requires Equitable Development —
The Hastings study also focused on individual state law and found that Virginia statutes governing energy development articulate support for environmental justice. One of the stated objectives is “developing energy resources and facilities in a manner that does not impose a disproportionate adverse impact on economically disadvantaged or minority communities.”8
The Virginia statutes direct various state agencies to work together to create a comprehensive 10- year energy plan that reinforces the EJ and other objectives.9
The state’s 10-Year Plan, among other things, must include the following information: an analysis of siting of energy facilities to identify any disproportionate adverse impact of such activities on economically disadvantaged or minority communities. In considering which parcels of land are suitable for energy facility development, the agencies must consider, in addition to technical matters, “potential impacts to natural and historic resources and to economically disadvantaged or minority communities and compatibility with the local land use plan.”10
State law is clear in this matter. Todate, the county the Planning Commission and the State Corporation Commission have failed with respect to its statutory obligation to ensure that the Chickahominy Power plant does not have a disproportionate impact on Charles City County’s African American community. Unless and until state law in complied with, DEQ cannot approve this permit.
7 Natural Resources Defense Council, https://www.nrdc.org/stories/environmental-justice-movement
8 VA. CODE ANN. § 67-101 (2009); see also Id. at § 67-102, stating that to achieve the objectives of § 67-101, it shall be the policy of the Commonwealth to “ensure that development of new, or expansion of existing, energy resources or facilities does not have a disproportionate adverse impact on economically disadvantaged or minority communities.”
9 Id. at § 67-201
10 Id. at § 67-201(d)
Conclusion —
The Virginia Department of Environmental Quality lacks adequate regulatory basis for this facility and cannot issue a permit for the Chickahominy Power plant until the applicant demonstrates it has met all statutory requirements.
Respectfully submitted,
Louis A. Zeller, Executive Director,
Blue Ridge Environmental Defense League