PUBLIC SERVICE COMMISSION OF WEST VIRGINIA
CHARLESTON
Longview Power, LLC And Longview Power, LLC Case No. 03-1860-E-CS-CN Case No. 05-1467-E-CN
RESPONSE AND OBJECTIONS OF BARBARA BORN, ET AL. TO THE PETITION OF LONGVIEW POWER, LLC FOR WAIVER OF MODIFICATION OR AMENDMENT REQUIREMENT FOR SITING CERTIFICATE TO INCREASE THE AMOUNT OF POWER PRODUCED
I. INTRODUCTION
On June 26, 2006, the Public Service Commission (PSC) granted certificates to Longview Power to construct at 600 MW coal-fired electric generation station and associated transmission line in the Cass District of Monongalia County, WV. On November 8, 2006, Longview Power submitted a Petition to the PSC to increase the power output of this plant to 695 MW with an increase in water usage but no increase in coal input. Barbara Born, et al. (Concerned Citizens) now responds and raises significant objections to the proposed plant. The resolution of these issues is of importance to the State and its citizens, particularly those residing in Monongalia County. Now, herewith, Concerned Citizens submits this Response and Objections to the Petition of Longview of November 8th, and requests a full hearing so that said objections can be considered, and related issues as stated herein can receive proper resolution. II. ARGUMENT The power output is to increase from 600 to 695 MW at constant maximum design heat input of 6,114 MM Btu per hour. And, the cooling water usage is to increase by about 12% to approximately 5,000 gallons per minute. This raises a number of issues and concerns for the Concerned Citizens and for the PSC, as follow: 1. The increased power generation level means an increase in the overall thermal efficiency of the plant, yet the increase in the cooling water rate means a decrease in the overall thermal efficiency of the plant. These conditions are at odds with each other, and a full explanation is necessary. A variety of impacts to the local environment will be precipitated by these changes, as indicated below. 2. An increased cooling water usage will require more or larger cooling towers, which will result in additional environmental impacts. The steam plume quantities in the local environment will be greater with attendant increased local rainout of pollutants and other impacts. The noise from cooling fans will be greater and, the view shed profiles will be increased. These problems are examined further below. 3. It is stated by Longview that “No modification of the National Pollution Discharge Elimination System (“NPDES”) permit issued by DEP to Longview is necessary due to the increased water usage by the facility.” This is a premature statement since no evidence of such a determination by WV-DEP is given, and because the existing permit is under appeal before the WV-Environmental Quality Board. 4. It is stated by Longview that the boiler building will increase from 257 feet high to 270 feet high, and the steam turbine building will increase from 100 feet high to 120 feet high. It is these heights that determine the plant primary stack height, currently at 557 feet. Good engineering practice will necessitate that the stack height be recalculated, to become a larger number, i.e. a higher stack will be required. Further, the air pollution modeling for the plant was based upon the previous values for the building and stack heights as well as previous values for the boiler exit temperature and the temperature profile in the stack. The air modeling needs now to be repeated to determine the impacts of pollutant dispersion on the local environment. Further, the stack height currently exceeds federal guidelines for obstacles in the vicinity of public airports; so the changes will require a re-examination of the stack height. 5. The issues raised in Argument 4 above will necessitate that the Air Quality Permit granted to Longview by the WV-DEP Division of Air Quality be reconsidered. Among the issues in need of consideration are (a) the new stack height determined from best engineering practice, (b) the number and quantity of cooling towers and the quantity and quality of the evaporated cooling water, (c) atmospheric dispersion modeling for the new stack and cooling towers given the new boiler building and steam turbine building, and other possible considerations some of which are mentioned below. 6. Longview reports that the view shed problems due to the boiler building and steam turbine building will increase from 2.08 square miles to 2.176 square miles. “The increase in building height causes a 0.6 percent increase in the area that can see the buildings.” However, the view shed problems are not well represented by these numbers or by this analysis technique. The residents of Ft. Martin, Bakers Ridge and Stewartstown will see a substantial increase in the size of the plant profile on the horizon as well as the extremely large steam plume that will dominate the day and night sky continuously. The views of the plant and its plumes from important observation sites at Coopers Rock, Dorsey’s Knob, and from the Evansdale and Medical Center campuses of West Virginia University will be significantly increased. 7. The cost of the proposed 600 MW power plant has gone from $940 million to $1.8 billion. Whether these are realistic estimates is not known to the Concerned Citizens; but clearly, it is important that the PSC know and understand the estimates for the capital and operating cost for the proposed plant. [Estimates for two coal-fired power plants proposed by Duke Energy to the North Carolina Utilities Commission (NCUC) were brought into question this past September; and, in late October Duke Energy notified the NCUC that the cost of these plants had gone up by 50% to $3.0 billion. The NCUC has now reopened the record and additional hearings will be held in January.] The cost issue is relevant to the financial viability of the proposed Longview power plant as well as to whether the public interest is served by the “payment in lieu of taxes” (PILOT) and other agreements pertaining to the proposed plant. 8. The decision of whether to build a conventional power plant such as a pulverized coal boiler unit or an advanced power plant such as an integrated gasification combined cycle system (IGCC) should involve environmental impacts and costs. Clearly, “best available control technology” (BACT) takes some account of the costs to achieve low environmental impacts. Given the high costs for a conventional power plant, as recently presented by Longview, it is now time to understand why the State of West Virginia cannot or should not benefit from advanced technology as represented by the IGCC option. Other BACT options may also be feasible given the new cost domain associated with the proposed plant. If Longview is to benefit from advances in boiler design, in achieving an increase from 600 to 695 MW with the same coal input, then the public should benefit from advances in environmental control at the same coal input level. III. RELIEF For these reasons, including other possible questions of financial viability, cooling tower performance and noise control that are still under study, it is appropriate that a full hearing on the various proposed changes be held. Only after the complete extent of the proposed changes have been determined and examined can a proper judgment be made as to the appropriate course for the future. It is the Public Service Commission that has the responsibility to gather the relevant information, hold hearings as appropriate to gain a complete understanding of the issues and information involved, and to render decisions in the public interest. The Public Service Commission must place the burden of proof upon Longview to establish that the public is protected. The primary purpose of the Commission is to serve the interests of the public. WHEREFORE, the Concerned Citizens respectfully request that the Petition of Longview Power of November 8, 2006, be denied subject to a full hearing for examination of all the details of anticipated impacts from the proposed changes. Barbara Born et al. (Concerned Citizens) By Counsel ________________________ Phillip D. Gaujot, Esquire (WVSB # 1355) 445 Lakeview Drive Morgantown, WV 216505
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PUBLIC SERVICE COMMISSION OF WEST VIRGINIA CHARLESTON
Longview Power, LLC And Longview Power, LLC Case No. 03-1860-E-CS-CN Case No. 05-1467-E-CN As counsel for Barbara Born, et al. (Concerned Citizens), I do hereby certify that on this 7th day of December 2006, copies of the foregoing “Response and Objections of Barbara Born, et al., to the Petition of Longview Power, LLC for Waiver of Modification or Amendment Requirement for Siting Certificate to Increase the Amount of Power Produced” were served upon the parties and/or counsel of record in this proceeding, and addressed as follows: Leslie J. Anderson, Staff Attorney Vincent Trivelli, Esquire Public Service Commission The Calwell Practice 201 Brooks Street 178 Chancery Row Charleston, WV 25301 Morgantown, WV 26505 Leonard Knee, Esquire Kathryn L. Patton, Esquire Bowles Rice McDavid Graff & Love LLP Allegheny Power 600 Quarrier Street 800 Cabin Hill Drive Charleston, WV 25301 Greensburg, PA 15601-1689 ______________________ Phillip D. Gaujot, Esquire WV Bar # 1355 445 Lakeview Drive Morgantown, WV 216505