Questions and Comments

from

Public Open House

March 4, 2004

Copy of Modeling PowerPoint Presentation Available for Download (PDF Format 5 meg)

Q: What are the emissions during peak demand periods? How close to the standards are the emissions during peak demand periods? Do they exceed the standards? Does the dispersion model take into account the fact that the proposed project is located in a narrow valley?

A: The emissions in the permit application were based on the boiler operating at 100% load throughout the year. Peak demand will not change the load on the boiler; hence, the emissions in the permit application are the emissions that would be produced during periods of peak demands. The highest modeled concentrations from SPC Sources only are presented below. The last column shows the percent of National Ambient Air Quality Standards (NAAQS). The NAAQS are maximum concentration "ceilings" measured in terms of total concentration of a pollutant in the atmosphere. This percentage includes pollutant concentrations from existing sources in the area.

As seen from the above table the percentage of the NAAQS for SO₂, PM₁₀, NO₂, and CO are considerably below their respective standards.

Pollutant concentrations from SPC Sources only were also reviewed against the Prevention of Significant Deterioration (PSD) Class II increments. A PSD increment is the maximum allowable increase in concentration that is allowed to occur above a "baseline" concentration for a pollutant. The "baseline" concentration for a pollutant is the ambient concentration existing at the time that the first complete PSD permit application affecting the area is submitted (major source baseline dates). The major source baseline dates in Utah are:

January 6, 1975 for PM₁₀ and SO₂ and February 8, 1988 for NO₂. Significant deterioration is said to occur when the amount of new pollutant would exceed the applicable PSD increment. PSD increments that currently exist are for SO₂, PM₁₀, and NO₂. The highest modeled concentrations from SPC Sources only are presented below. The last column shows the percentage of the PSD Class II increment. The PSD Class II increments are for the area around the plant including Richfield and Sigurd.

As seen from the last column in the table above, the percentage of the PSD Class II increments for SO₂, PM₁₀, and NO₂ are considerably below their respective standards.

The dispersion modeling conducted using both the ISC3 and CALPUFF models includes the complex terrain around the facility as well as the narrow valley where the facility is proposed. Actual terrain elevations are input to the model. These elevations were obtained from the USGS database of digital elevation model data.

Q: Fly Ash - Where will it be stored? Will it be covered? What will be done to stop fugitive dust? Visual Impacts - Will the 460' smoke stack [be visible] from the entire valley? Will the valley have a brown haze layer? What will be the elevation of the haze? Mercury - What will be the cumulative effects on unborn fetuses?

A: The ash by-products generated by the facility will be stored in concrete or carbon steel silos. The ash by-product will be transported off-site daily in the empty coal trucks and trailers to an approved ash disposal site.  Both the trucks and the trailers will be covered.

The State of Utah has developed regulations that pertain to fugitive dust sources. Fugitive dust will be minimized through watering or vegetation as needed. As a permit requirement, visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas shall not exceed 20% opacity.

Emissions from the SPC facility will not cause a brown haze layer over the valley. If currently there is a brown haze layer over the valley from existing sources then that haze layer will still be present. The elevation of the haze layer will vary due to meteorology.

As for cumulative mercury effects on unborn fetuses, we are not qualified to answer that question.  We would refer you to Steve Packham, UDAQ toxicologist, to accurately answer this question.  However, it should be noted that the mercury emissions from the plant, as modeled, are significantly below the EPA Lifetime Threshold Limits established for mercury.

Q: If the pollution emitted from this coal-fired power plant is so minimal, why do they not permit any more such plants to be built in California? If these plants are so clean, why are the State of Utah air-quality Officials questioning the building of 3 such plants in Nevada? Utah is downwind from the NV plants!

This question should be addressed by UDAQ.

Q: My father works in these plants and he stated he couldn’t find accurate emissions information. How have you been able to be sure of your information?

A: Major sources of air emissions, such as existing power plants, are required to conduct source testing; that is, samples of the air are tested as they leave the stack after the pollution control equipment. Accurate emissions information are available from the EPA or State of Utah for these existing plants. For the proposed SPC facility, NEVCO relied on emission estimates from the manufacturer who may build the facility. These emission estimates are based on similar plants that are currently operating and based on the coal to be used. For those pollutants where the manufacturer did not have emissions information, NEVCO relied on EPA information, which was developed based on actual source testing data.

Q: Based on EPA’s current data, (www.scorecard.org) 14,573 people in Sevier County face a cancer risk more than 100 times the goal set by the Clean Air Act. Living near a power plant increases cancer by 12%  How much more do you want to infect upon us?

A: While it is true that, according to Scorecard.org, the EPA predicts that 14,573 people in Sevier County face a cancer risk more than 100 times the goal set by the Clean Air Act, it is important to read further and see how Scorecard categorizes the sources of risk. According to Scorecard, 81% of the air cancer risk is from mobile sources. Scorecard defines mobile sources to include both on-road vehicles (cars, buses, trucks) and off-road equipment such as agricultural and construction equipment.

The second highest contributor to the cancer risk in Sevier County, according to Scorecard, at 19%, is area sources. Area sources include small pollution sources like dry cleaners, gas stations, and auto body paint shops. Area sources are defined as sources that emit less than 10 tons per year of a criteria or hazardous air pollutant or less than 25 tons per year of a combination of pollutants. The category also includes commercial buildings (heating and cooling units; surface coatings), residential buildings (fire places; surface coatings), fuel combustion in non-road machinery, boats, railroads, and even family lawnmowers and barbeque grills.

The third category that Scorecard lists with the lowest percentage (0.0091%) of the cancer risk is from point sources. According to Scorecard, point sources include major industrial facilities like chemical plants, steel mills, oil refineries, power plants, and hazardous waste incinerators. Point sources are defined as those that emit 10 tons per year of any criteria pollutants or hazardous air pollutants or 25 tons per year of a mixture of air toxics.

Q: Please explain how much mercury will be admitted into the air.  How will the residue be handled and removed through the years?  What effect will mercury have on residences’ lungs and health in general?  Mercury is a poison.

A: According to the Mercury Report to Congress, mercury emissions from coal combustion are through stack emissions, which are thought to include both gaseous and particulate forms of mercury. Gaseous mercury emissions are thought to include both elemental and oxidized chemical forms, while particulate mercury emissions are thought to be composed primarily of oxidized compounds due to the relatively high vapor pressure of elemental mercury. According to the EPA, the analytic methods for mercury speciation of exit gases and emission plumes are being refined, and there is still controversy in this field. The speciation of mercury emissions is thought to depend on the fuel used (e.g., coal), flue gas cleaning and operating temperature. The exit stream is thought to range from almost all divalent mercury to nearly all elemental mercury. Most of the mercury emitted at the stack outlet is found in the gas phase although exit streams containing soot can bind up some fraction of the mercury. The divalent fraction is split between gaseous and particle bound phases (Lindqvist et al, 1991). Much of this divalent mercury is thought to be HgCl (Michigan Environmental Science Board, 1993).

As for mercury health effects, we are not qualified to answer that question.  We would refer you to Steve Packham, UDAQ toxicologist, to accurately answer this question.  

Q: How will air quality monitor our air each day - what will happen when the plant exceeds air quality standards - will we be under restrictions like SLC is during inversion? It has been said no health risks.  How can you know this with the reports from other areas that have plants?

This question should be addressed by UDAQ.

Q: On page E1 of NOI what does state of the art mean? This CFB is 30 years old system. Check other countries. On page 2-18 they state natural gas. Where you going to get it? Why not natural gas all time? Page 2-20 will the limestone trucks cause PM2.5

A: The technology proposed will consist of the highest degree of development, which includes the use of the best available boilers and pollution control equipment. While CFB technology has been around for 30 years, like most technologies considerable advances have been made. The boilers will be started up with natural gas, which will be piped to the facility. Natural gas will not be used all the time because it is not an efficient use of this resource for the proposed technology. Most particulate emission sources will have a fraction of emissions which will be in the 2.5-micron range.

Q: P 3-1 why not run the generator and fire pump on natural gas? P 3-6 the limestone to be delivered in end dumps. What about the covered load. Same page it stated ‘negligible quantities of dust’ what does that mean? Page 3-7 a fraction of the empty coal trucks will transport the ash off site. Truck drivers tell us that can’t be done in the same truck.

A: Since the generator and fire pump are proposed to have limited operating hours (120 hours each) per year, it is appropriate to run this equipment on diesel. The comment regarding negligible quantities of dust is referring to the conveyors, which are covered.

Q: NOX is bad to breath - right or wrong?

A: We are not physicians and thus, we feel we are not qualified to answer this question. We would refer you to Steve Packham, UDAQ toxicologist, to accurately answer this question.

Q: Please see what you can do to keep the proposed power plant away from people. I live 1/4 mile away from the proposed power plant, and I believe there should be a good neighbor policy so the fallout will not cause problems for me and my family. I read in the Richfield Reaper where NEVCO has met the requirements of Federal Air Quality. My family also raises a garden, and sells hay for a living. Is this polluted air going to affect our produce? As well as our environment? What about our health? Why build on good agricultural ground instead of wasteland? We have both in our county. Don’t people matter anymore? Why rob us of the precious thing in life? Clean air!

A: See above response for information on health and environmental impacts.  

Q: I’ve made copies of my questions and will expect answers. Thank you. The modeling done by MSI does not include a cumulative impacts from wildfire (which will never go away), prescribed fire, proposals for added capacity at Delta and Hunter, and growth (residential and vehicle traffic). Maximum impacts will not truly be assessed until these factors are included in the modeling. The ambient concentrations for CO, SO2, NOX, mercury, etc. Are not from this valley so why are they applicable? What are the standard errors for the modeling results? Error bars and appropriate factors of safety should be included in the presentation of the results. The PM monitoring station should have been placed in Richfield and Salina since this is the actual ambient air that will have pollutants added to [it]. What validation monitoring has been done for the models used in the MSI analyses? A worst case scenario for pollutant concentrations would likely be from an inversion that is deeper in height above ground level than the smoke stack. Has this modeling been done and are those results reported in the MSI analyses?

The Fishlake National Forest has not been consulted with regards to the NEVCO proposal and it should be. There are several potential issues including:

The forest has acidic soils, what will be the cumulative impacts?

Wildfires contribute to PM10 emissions and are not included in the MSI modeling, but should be - - this plant will also limit the forests' ability to use prescribed fire.

The forests parks have sensitive, rare, and threatened endangered plants, some of which are sensitive to changes in soil, etc.

What will be the water quality impacts? It takes very little mercury to pollute a lot of water.

A: UDAQ does not require that temporary sources such as wild fires be modeled.  The PM10 monitoring data that was used for background should contain the contributions of wildfires if any existed during the monitoring periods.  The emission information for the full impact analysis was provided by UDAQ and did not contain emission information for the proposed new sources at IPP and Hunter.  Growth should be minimal from this project (of the projected 85 full-time employees approx 20-30 would be hired from out of the area).   Vehicular emissions were not required to be modeled (these were not discussed in the approved modeling protocol).  In the past vehicular emissions were accounted for in the mobile source emission inventory.  Questions regarding background concentrations and monitoring locations should be addressed to UDAQ.   

Error levels from the model are extremely difficult to quantify and can originate not only from the algorithms in the model but also the modeling input information for the meteorology and sources.  There is a strong consensus in the modeling community that dispersion models tend to give conservative (high) concentrations when compared against actual monitored data.  Model validation was not required by any regulatory agency.  

Vertical mixing potential was addressed in both near and far-field models through the use of hourly mixing heights and vertical temperature profiles in the MM5 dataset.  The dataset contained many instances where the inversion depth exceeded stack top.

Please see question below with regard to contacts that were made. 

A soils and vegetation section was included as Section 7.12 in the Notice of Intent. 

Water quality impacts were not required for the air permit.

Q: How many jobs in the County will be lost because of plant production? 

NEVCO A.   The reason jobs in other counties have been lost… or given up… is because they decided to sell their water that was used to cool the power plants.  The technology utilized in the other power plants requires significantly more water than the “air-cooled” technology featured in the design of the SPC facility.  Once the other farmers had sold their water, they could not farm anymore. We anticipate a net increase of jobs from trucking, plant operations and support services. 

Q: Do we really need a power plant? I don’t think we do! Moving is my only option if one does come in here. Please don’t put one here.

A: Unable to respond - either an opinion was expressed without an actual question or question was not applicable to this forum

Q: What about the NOISE they make? Is there any odor emanated? Will these big 40' trees grow there?

NEVCO A.  The individuals who visited the Mirant plant near Las Vegas, NV and the Warrior Run Plant near Cumberland, MD indicated no discernable noise or odors from these plants. There are mature 40’ popular trees of the variety we propose to plant growing in Jody Gale’s yard which you can inspect first hand.

Q: Please explain better the water being used. Where it will come from, etc. Do we have enough water to support this project when we are in such a shortage? Also, is it necessary to put the plant so close to Sigurd? Is there a second or third choice that would work?

NEVCO A. The water is used, purified, and recycled several times over. Ask the individuals who went to the Warrior Run & Mirant plants and saw the water purification system. Water for the facility has been acquired with the property purchased for the facility. No new allocation of water will be sought to provide water for the facility. Existing land currently under irrigation will be removed from irrigation and change applications filed on the existing water rights. Water will be supplied by a well on the property. An existing well, which has been acquired, will be capped and the water transferred to plant site following the appropriate state process, and will be subject to the current reduction in the amount of the water right based on the change of the water from irrigation to industrial purposes. The choice of the Sigurd Site was an iterative process. Several other sites were considered and eliminated for a variety of reasons.

Q: I am 14. Why don’t our County officials care enough about my future to keep our air clean to breath. Are you so greedy that all you can care about is money in your pockets right now? What about their own children? How can they not care for their health and well being? Pollution is a fact of life, it’s getting worse, not better, making my future scary. Why don’t adults care enough to fix the problem instead of making it worse?!

A: Unable to respond - either an opinion was expressed without an actual question or question was not applicable to this forum

Q: Who gets to benefit - in other words where does all the money go to? The city, the counties, or individuals? And what amounts go to our communities?

NEVCO.  A.  The plant will shoulder approximately one half of the tax base for the county. The coal mine and its employees will benefit… the trucking industry and their employees will benefit… the plant employees will benefit… the schools will benefit… the local business owners and their employees will benefit…  and the owners of the plant will benefit.  

Q: It has been said that Utah coal is high grade coal. But you have said no contracts have been made with any Utah companies. So if coal comes from outside of Utah what grade of coal will be used?

NEVCO. A.  The emission data used in the modeling and incorporated into the air permit for the facility are all based on high-quality Utah coal.  The permit conditions cannot be met if high quality coal is not used.  Therefore the permit conditions dictate and require the use of high-quality coal. 

Q: Nice display but you’re not fooling thinking folks - forget it - go to a venue where there aren’t any people, animals, or plants for coal is a DINOSAUR

A: Unable to respond - either an opinion was expressed without an actual question or question was not applicable to this forum

Q: I live ½ mile from this new plant and I want to know what you are going to do when my well dries up and I don’t have any water to live off of.  Are you going to buy my land too?  And everyone else with the same problem.  I would really like to know!!! 

NEVCO A. Nevco will have a well at the plant site.  It is expected that the well that will be transferred there will be limited to a withdrawal of approximately “one third” less water than it is now being supplied from the existing well because of the reduction in the allocation of water under a change of the water from agricultural, “irrigation” use to industrial use. The well for the facility will have to go through an approval process with the State Water Resource Department before a permit will be issued.  Also, the well will be much deeper than your well and draw from a different aquifer.

Q: Please allow clean alternative energy such as solar, wind technology. Please do not allow this coal-fired plant to come into our valley. Please visit this web site www.cleartheair.org Will the citizen’s always have to pay for the ash waste dumping site?

NEVCO A.  The alternatives that you suggest are not practical for the generation of large amounts of power.  They are competitive sources for the supply of power in limited uses when you have back-up power sources, or have a limited application and can rely on battery powered back-up for periods of time when the sun is not shining and the wind is not blowing.  The overall costs per megawatt of power produced are significantly higher for solar and wind technology than for coal.   The citizens will not pay for the ash waste-dumping site.

Q: I do not want a power plant to be in my home county. I am only 17 I have my whole life ahead of me. Please take my comments seriously!

A: Unable to respond - either an opinion was expressed without an actual question or question was not applicable to this forum

Q: We do not need this plant. It does not benefit us at all - California gets the power.  Big interest gets the money we get the pollution no jobs will be made for local people no one here know how to build a power plant or run one, who will build it. Not our contractors. Who will run it not our people from here. How many trucks will it take to bring in the coal and take out the fly ash.

NEVCO A.  Approximately 62 trucks per day for coal and 5 trucks per day for ash. 

Q: What guarantees do you give our community that in 20 years.

We won’t suffer lung disease, cancers, birth defects, mercury in our fish and lakes, acid on our land and cars.

That you won’t leave a ‘rusted stack’ when you leave

Our farmers will have enough water to farm

A: Unable to respond - either an opinion was expressed without an actual question or question was not applicable to this forum

Q: How is this plant going to help tourism (our 1^st industry?)  Why is this plant coming to our populated valley when there is so much land elsewhere that is EMPTY? Are the jobs that come with this plant worth the look, smell, feel, and possible health problems that come with it? Comment - we just plain don’t want to see it in our valley - it is not a pleasant [sight] anywhere.

NEVCO A.    Unable to respond - either an opinion was expressed without an actual question or question was not applicable to this forum

Q: Why are you not listening to the public - take a vote. These comment cards do not allow you to hear from the public - you can pick and chose your questions - it seems to me you don’t want to know what the public thinks.

A: Unable to respond - either an opinion was expressed without an actual question or question was not applicable to this forum

Q: Why are they going to put a power plant here if they aren’t going to use the power for us.  I don’t want it here. Age 9

A: Unable to respond - either an opinion was expressed without an actual question or question was not applicable to this forum

Q: The plant will emit mercury - this will get into our drinking water and our lakes and into the fish - not to mention the human body - how can you expose a community to this?

A: Unable to respond - either an opinion was expressed without an actual question or question was not applicable to this forum

Q: Why did you choose a site for the power plant in the middle of a valley?

NEVCO A. Because of the proximity to the Sigurd sub-station.  It is an area that is already an existing industrial area.  The area surrounding the proposed facility consists of a wrecking yard and is traversed by several large, overhead power lines. and poles.  

Q: We live in a high desert area. What would the plant do to our water supply, which is from wells? When the farmer above Venice pumps his large (6 inch) watering well the wells in town drop - how much water would the plant require - how will it be obtained and how controlled or regulated?

NEVCO A.  Experience in the desert area of Arizona has shown that some wells are 16” and are drilled to 2,000 feet.  Sevier County wells are some 50 to 200 feet.  We plan to drill a deep well.   The plant requires 87 gallons of water per minute, the amount of water it takes to irrigate approximately 50 acres. The plant site will take up more than the 50  acres that will be taken out of existing irrigation. All water utilized will be water that is owned by the owners of the facility and will be regulated by the Utah State Water Resource Department.  

Q: Why don’t you put the issue to a vote?

A: Unable to respond - either an opinion was expressed without an actual question or question was not applicable to this forum

Q:  I will move out of the area if the plant is built. I left Southern California for the same reason - smog! It will happen. I feel there are cleaner industries, such as tourism, that could be expanded. e.g. have ATV and jeep tours all summer, spring, and fall. Not just one week in Sept. The power plant will employ people but all qualified people will be brought in. Locals will be janitors and low paying jobs. The winter inversion issue in Sigurd has not been adequately addressed. What about wind power? We need alternative energy sources. How will the hazardous waste from the plant he handled?

NEVCO A.  Wind power occurs when the wind blows.  It is undependable.  Solar power would cost you, the rate payer, 10 to 15 cents per kwh.  (Rocky Mt. News.. Gargi Chakrabarty)   Hazardous Waste will be handled in accordance with State and Federal hazardous waste guidelines. 

Q: Why are you afraid to answer questions from the public directly? Why hide behind this?

Q: What moral justification do you use for rationalizing your exploitation of Sevier Valley people for your own personal profit. I do want to know this - there is a spate of moral depravity in the leadership of the USA - from Keyy Boy Lay [Ken Boule , Tom DeLay?] to Dennis Kowalski from Tyco Corp - why is American corporation leadership so devoid of morality?

A: Unable to respond - either an opinion was expressed without an actual question or question was not applicable to this forum

Q: Will NEVCO be using our local coal? How many local people will be permanently full time employed at the plant - be specific.

NEVCO A. We are having on-going discussions with the local mines and it is our intention to use Utah coal. We will not need employees for at least 4 years. Anyone who wants to prepare for a job has adequate time to prepare. Contact the College and ask if they can help! If you want a job there is time for you to get qualified!

Q: We live where we would have to look at the plant every day - will it be as ugly as the pictures of the existing plant?

NEVCO A.  The plant will have a row of trees planted soon after the ATC and County approval is awarded.  This Hybrid Popular grows approximately 10 feet per year.  By the time the plant comes on line…  you may not even notice the stack when it is camouflaged to match the surrounding colors and areas. The plant will compliment the area… blend in and be an asset.

A: Unable to respond - either an opinion was expressed without an actual question or question was not applicable to this forum

NEVCO A.  Nevco has had conversations will the local mines.  Nevco intends to use Utah coal…helping extend the life of the mines… supporting local jobs.   

A: Mark Hennefant, NEVCO’s boiler expert, says that visible emissions from the stack will be minimal. As per red and green burn days, these restrictions are due to Salt Lake County being in non-attainment for PM₁₀.  Since the Sigurd area is currently in attainment, and emissions from the proposed SPC Project will not put the Sigurd area into non-attainment, it is unlikely that red and green burn restrictions will be imposed on the area.

NEVCO A.  1. According to the studies made and published by the DAQ there should be no significant impact to those folks.  2. There should be health reports available through the DAQ.

NEVCO A.  No.   The facility will be required to adhere to the governmentally established emission levels.  The standards are designed to protect the most “sensitive groups,” (small children, older individuals, and those with health problems).  According to a comparison of the health statistics from Sevier, Millard and Carbon counties, the latter two of which have coal-fired power plants, there is no appreciable difference in the incidence of death or respiratory related illnesses.

NEVCO A. The coal pile will be covered.  The ash will be deposited in a protected area away from the plant.  Ash is being used today in cement… pumice blocks… road base…  etc..     Dust will be controlled with application of water and/or dust suppressant materials.

NEVCO A.  The area adjacent to the Sigurd Sub-Station was chosen after consideration of 5 other sites.

NEVCO A: This question should be addressed to the UDAQ

NEVCO A.  No.  NEVCO will assist the growth of industry in Sevier County.    

A: There is plenty of "clean air" available for potential industries. The percentage of PM10 in regards to the NAAQS is the highest due to the existing amount of PM10 in the region already, as indicated by the high background values used in the NAAQS demonstration.

A: Unable to respond - either an opinion was expressed without an actual question or question was not applicable to this forum

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