MMC Talking Points Fact
Sheet
Poor Location
· The new power plant, like
the one it is replacing, remains in a very poor location. Roughly 1300 ft. from
an elementary school and only 350 ft. from the nearest residential neighborhood.
· Chula Vista General plan
policy E 6.4 expressly directs the city to “avoid siting new or re-powered
energy facilities and other major toxic emitters within 1,000 ft. of a
sensitive receptor
· The creation of a new
facility on a previously empty portion of a lot with a 122% increase in capacity
is basically a new power plant that is using a “limited amount” of recycled
equipment.
· Another general plan policy
violated by the siting of this proposed plant is E 6.15 “site industries in a
way that minimizes the potential impacts of poor air quality on homes, schools,
hospitals, and other land uses where people congregate.”
- The immediate area (within 1 mile of the proposed power plant) is made up of an environmental justice community (81% of residents are people of color and 16% are below the federal poverty level).
Inappropriate Land Use
·
The
site and adjacent parcels are both considered “limited industrial.” Power plants are not included on the list of permitted or conditional uses
for this designation.
- CEC
staff refers to the proposed power plant as an example of heavy industrial
use which is not permitted under the current limited industrial
designation.
· According to the AFC, the
potential of PM emissions
is higher and the source is closer to sensitive uses. Again, it is the location of the project that is a significant
obstacle.
· There is insufficient
information about the cumulative impacts to the surrounding community. The proposed new power plant, with the
increase in the hours that it will run, will likely add more pollutants to the
area.
· MMC has not given the public
a good idea of how many hours we are likely to see from the new power plant. The
proposed plant will have a technical capacity of 4500 hours.
· The AFC compared the
emissions of the old plant with emissions of the proposed plant but for only 500
hours of operation. This is not an accurate comparison, since the old plant
never ran 500 hours in a year and the new plant will run more than 500 hours a
year.
· In a comparison of emissions
at both 500 and 4500, the proposed plant releases more emissions for each
contaminant listed except for CO under the 500 hour analysis and for all
contaminants under the 4500 hour analysis.
· The hourly emission rates
are higher for SOx, VOC,
and PM10/PM2.5
for the proposed plant, as compared to the existing plant.
- The 24-hour particulate levels in Chula Vista are already over the federal standard and the proposed peaker will make it worse.
Renewable Energy
· The MMC peaker expansion does
nothing to create a more sustainable energy future and curb greenhouse gas
emissions in that is does not include any commitments to implement renewable
energy or finance energy efficiency to offset future need of this gas-fired
plant.
· EHC’s position is that all
new gas-fired projects must, as part of their proposal, incorporate other
energy sources in compliance with the Preferred
Loading order.
· It is incumbent on new power
projects to reflect what the region needs
with respect to energy generation in the region- clean, sustainable, and
renewable. The proposed MMC plant
contains none of these.
- There is no evidence that this new power plant will remove or contribute to removal of the Reliability Must Run designation from the South Bay Power Plant.
Cooling/Water Use
· In a region suffering from
drought conditions and the need to tightly conserve our water resources, it not
reasonable for MMC to propose a power plant that could use up to 28 million
gallons per year of water.
- MMC’s own estimate is that the plant would use a minimum 4.2 million gallons per year on process and cooling water. This is a tremendous amount of water to use on a peaker plant.
Use of Ammonia
· Any air quality information
must also include the likely emissions from the ammonia trucks that will be
coming down a highly congested Main St. to fill up the 12,000 gallon ammonia
tank once every two or three weeks, according to the AFC.
· Based on the worst-case
scenario done for the Larkspur peaker plant in Otay Mesa (the release of the
entire contents of a 10,000 gallon above-ground storage tank of aqueous ammonia),
the radius of an area that would be exposed to ammonia beyond what is
considered extremely toxic under federal law is over 1,000 feet.
· Based on the more probable
accident of a hose leaking while re-filling the tank, according to models run
for Larkspur, the hazard zone would still be over 1,000 ft.
- AFC states “Although a potentially promising technology, SCONOx has not been commercially demonstrated on a large power plant.” Either the new power plant is a large plant that should be viewed as such in regard to land use and siting, or it is a small plant and thus a more detailed evaluation of the SCONOx alternative be presented.
CLICK
HERE TO SEE PICTURE OF AMMONIA RISK ZONE
Possibility of Expansion
· The old portion of the plant
will be removed, leaving the southern portion of the lot with what MMC
described as, “a shed for storage.
Easily this structure could be removed (or not built in the first
place), leaving room for another possible expansion.
- A dangerous new precedent could be created if the proposed plant is certified. If the City and CEC allow a 100 MW power plant in an area set aside for limited industrial, it would be difficult to limit future expansions.
Alternatives
· The Alternatives section of
the AFC is incomplete and must include a more detailed analysis of why some of
the alternatives were ruled out.
o First, in regard to the
alternative locations, none of the assessments of the alternative locations
discussed proximity to communities and schools.
o Closed sections of the
landfill and site in the eastern areas should have been, but were not,
analyzed.
o There should be an analysis of alternative methods of cooling, which was not presented in the AFC.