Paul Rolke OurLandOurLives

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1 Paul Rolke OurLandOurLives Texas A&M, AGEC 350 October 26, 2006 SO2 Health and Environmental Effects Power plants, especially those that burn coal, are by far the largest single contributor of SO2 pollution in the United States, accounting for approximately 67 percent of all SO2 emissions nationwide.4 Sulfates (from SO2) are major components of the fine particle pollution that plagues many parts of the country, especially communities nearby or directly downwind of coal-fired power plants. Sulfur dioxide also interacts with NOx to form nitric and sulfuric acids, commonly known as acid rain, which damages forests and acidifies soil and waterways. 8 Harvard School of Public Health studies have shown that SO2 emissions from power plants significantly harm the cardiovascular and respiratory health of people who live near the plants. According to EPA studies, fine particle pollution from power plants causes more than 20,000 premature deaths a year. In April 2005, EPA took final action to designate 177 counties and 31 partial counties home to more than 100 million Americans as nonattainment for health-based fine particle pollution standards.5 CO2 Texas has more plants (6) represented in the top 50 than any other state for CO2 emission rates. Large lignite-burning power plants in North Dakota and Texas rank among the worst CO2 polluters based on emission rate. Lignite is low grade fuel, abundant in places like Texas and North Dakota; its comparatively low BTU (heat) value means more CO2 for the electricity it generates. Carbon dioxide, one of several greenhouse gases that contributes to climate change, is released into the atmosphere when fossil fuels (oil, natural gas, and coal), wood, and solid waste are burned. Power plants are responsible for about 40 percent of all man-made CO2 emissions in the nation,12 and unlike emissions of SO2 and NOx, the electric power industry s CO2 emissions are steadily rising. Power plant CO2 emissions are directly linked to the efficiency with which fossil fuels are converted into electricity, and coal-fired power plants are inherently inefficient. According to EIA, in a typical power plant, only about a third of the energy contained in coal is converted into electricity, while the remainder is emitted as waste heat.13 In fact, coal-fired power plant efficiency has remained largely unchanged since the mid 1960 s. NOx Electric utilities account for 22 percent of all NOx emissions in the U.S.15 Ground-level ozone, which is especially harmful to children and people with respiratory problems such as asthma, is formed when NOx and volatile organic compounds (VOCs) react in sunlight. NOx also reacts with ammonia, moisture, and other compounds to form fine particle pollution, which damages lung tissue and is linked to premature death. Small particles penetrate deeply into sensitive parts of the lungs and can cause or worsen respiratory disease such as emphysema and bronchitis, and aggravate heart disease. NOx also increases nitrogen loading in water bodies, especially in sensitive coastal estuaries. Too much nitrogen accelerates eutrophication, which leads to oxygen depletion and kills fish. According to EPA, NOx emissions are one of the largest sources of nitrogen pollution in the Chesapeake Bay.16 Mercury Plants in Texas and Pennsylvania topped the list for the nation s highest power plant mercury emission rates. TXU s Martin Lake (Texas) plant ranked number one, with 1,744 pounds of mercury emissions. Two Texas power plants, TXU s Big Brown and American Electric Power s Pirkey, rank in the top 10 for both emission rate and total pounds. Coal-fired power plants are the single largest source of mercury air pollution, accounting for roughly 40 percent of all mercury emissions nationwide.20 Mercury is a highly toxic metal that, once released into the atmosphere, settles in lakes and rivers, where it moves up the food chain to humans. The Centers for Disease Control has found that roughly 10 percent of American women carry mercury concentrations at levels considered to put a fetus at risk of neurological damage.21 State Policies of the Texas Farm Bureau, 2006 The first paragraph of the Environmental Issues section reads as follows: (emphasis added) Environmental Issues 143 We recommend TCEQ (Texas Commission on Environmental Quality) not issue permits for new coal-fired power plants unless they meet environmental standards equal to or better than a gas fired plant with latest technology, meaning the most stringent controls, categorized as "lowest achievable emission rate." Should a coal-fired plant be permitted with the latest technology and meet clean air standards, pollutants extracted should not be buried in critical areas that could harm our environment. 1

2 EXISTING TNP I PLANT COMPARED TO PROPOSED PLANTS by Megawatt of Electric Production EXISTING TWIN OAKS III TXU Bioler 1 TXU Boiler 2 TOTAL Emissions / Nominal Output TXU's Oak Grove Plant Compared to the 13 Most Recently Proposed Coal Fired Power Plants in Texas By Rate of Emissions (Total Annual Emissions/Nominal Output) TXU's Oak Grove Plant vs. 13 Other Proposed Plants in Texas by RATE TXU's Oak Grove Plant Average Emission Rate of 13 Other Plants TXU's Oak Grove Plant Compared to the 13 Most Recently Proposed Coal Fired Power Plants in Texas By Rate of Emissions (Total Annual Emissions/Nominal Output) NOx is Nitrogen Oxides, the chemical that causes smog and Ozone problems, damages lung tissue and is linked to premature death. CO is Carbon monoxide, the poisonous gas cars emit. SO2 is Sulfur Dioxide which causes acid rain, SO2 emissions from power plants significantly harm the cardiovascular and respiratory health of people who live near the plants. VOC is Volatile Organic Compounds which combine with NOx to form smog. PM/PM10 is particulate matter, tiny particles of soot that can be inhaled deep into the lungs and cause numerous problems; according to EPA studies, fine particle pollution from power plants causes more than 20,000 premature deaths a year. Hg is Mercury which is a brain toxin and can cause slow development and IQ loss in newborns. Source: Dirty Kilowatts America s Most Polluting Power Plants; a report by The Environmental Integrity Project. July NOx CO SO2 VOC (x10) PM/PM10 Hg (x10,000) Pollutants Data for this chart taken from an internal TCEQ document Power Plant Projects Updated 08/02/06 TXU's Oak Grove Plant Compared to the 13 Most Recently Proposed Coal Fired Power Plants in Texas By Total Annual Emissions TXU's FOUR LIGNITE PLANTS RESPONSABLE FOR 24% OF TEXAS INDUSTRIAL POLLUTION 2,500,000 TXU's Oak Grove Plant vs. 13 Other Plants Proposed in Texas 100% 30,000 2,000,000 Tons of Emissions Annually 25,000 20,000 15,000 10,000 TXU's Oak Grove Plant Average of 13 Other Proposed Plants TONS OF POLLUTION 1,500,000 1,000, ,000 2,100,000 52% 1,083,015 24% 493,886 5,000 0 TOTAL TEXAS INDUSTRIAL POLLUTION ELECTRIC UTILITIES TXU's 4 LIGNITE PLANTS 0 NOx CO SO2 VOC (x10) PM/PM10 Hg (x10,000) Pollutants Data for this chart taken from an internal TCEQ document Power Plant Projects Updated 08/02/06 2

3 EXISTING TXU COAL PLANTS TXU had the top 3 plants in Texas for industrial air pollution in 2003 and its four coal/lignite plants accounted for 493,886 tons or nearly 24% of the State's total. TXU's Sandow Station ranked #8 in Texas. 2,100,000 tons Texas Total Industrial Emissions (2003) 1,083,015 tons From Industrial Sources other than Power Plants (48%) 1,083,015 tons From Electric Power plants (52%) 1,002,227 tons From 17 Coal Fired Plants ( 93% of power plant pollution) 80,957 tons From 134 Gas Fired Plants ( 7% of power plant pollution) TXU EMISSIONS: 512,319 tons From 19 TXU Power Plants 18,433 tons From 15 TXU Gas Fired power plants ( 4% of TXU s Pollution) 493,886 tons From 4 TXU Lignite Fired power plants equals: 96% of TXU s Pollution 46% of Texas Power Plant Pollution 24% of Texas Industrial Pollution TXU's proposed Oak Grove lignite-fired power plant that seeks to emit 41,600 tons per year would rank #11 for all power plants. Dirty Kilowatts America s Most Polluting Power Plants [Exerpts] The Environmental Integrity Project July ts.pdf#search=%22dirty%20kilowatts%20america%e2%8 0%99s%20Most%20Polluting%20Power%20Plants%22 The Environmental Integrity Project (EIP) is a nonpartisan, nonprofit organization dedicated to more effective enforcement of environmental laws and to the prevention of political interference with those laws. EIP was founded by Eric Schaeffer, who directed the U.S. Environmental Protection Agency's Office of Regulatory Enforcement until EIP s research and reports shed light on how environmental laws affect public health. SO2 Health and Environmental Effects Power plants, especially those that burn coal, are by far the largest single contributor of SO2 pollution in the United States, accounting for approximately 67 percent of all SO2 emissions nationwide.4 Sulfates (from SO2) are major components of the fine particle pollution that plagues many parts of the country, especially communities nearby or directly downwind of coal-fired power plants. Sulfur dioxide also interacts with NOx to form nitric and sulfuric acids, commonly known as acid rain, which damages forests and acidifies soil and waterways. 8 Harvard School of Public Health studies have shown that SO2 emissions from power plants significantly harm the cardiovascular and respiratory health of people who live near the plants. According to EPA studies, fine particle pollution from power plants causes more than 20,000 premature deaths a year. In April 2005, EPA took final action to designate 177 counties and 31 partial counties home to more than 100 million Americans as nonattainment for health-based fine particle pollution standards.5 CO2 Texas has more plants (6) represented in the top 50 than any other state for CO2 emission rates. Large lignite-burning power plants in North Dakota and Texas rank among the worst CO2 polluters based on emission rate. Lignite is low grade fuel, abundant in places like Texas and North Dakota; its comparatively low BTU (heat) value means more CO2 for the electricity it generates. Carbon dioxide, one of several greenhouse gases that contributes to climate change, is released into the atmosphere when fossil fuels (oil, natural gas, and coal), wood, and solid waste are burned. Power plants are responsible for about 40 percent of all man-made CO2 emissions in the nation,12 and unlike emissions of SO2 and NOx, the electric power industry s CO2 emissions are steadily rising. Power plant CO2 emissions are directly linked to the efficiency with which fossil fuels are converted into electricity, and coal-fired power plants are inherently inefficient. According to EIA, in a typical power plant, only about a third of the energy contained in coal is converted into electricity, while the remainder is emitted as waste heat.13 In fact, coal-fired power plant efficiency has remained largely unchanged since the mid 1960 s. 3

4 NOx Electric utilities account for 22 percent of all NOx emissions in the U.S.15 Ground-level ozone, which is especially harmful to children and people with respiratory problems such as asthma, is formed when NOx and volatile organic compounds (VOCs) react in sunlight. NOx also reacts with ammonia, moisture, and other compounds to form fine particle pollution, which damages lung tissue and is linked to premature death. Small particles penetrate deeply into sensitive parts of the lungs and can cause or worsen respiratory disease such as emphysema and bronchitis, and aggravate heart disease. NOx also increases nitrogen loading in water bodies, especially in sensitive coastal estuaries. Too much nitrogen accelerates eutrophication, which leads to oxygen depletion and kills fish. According to EPA, NOx emissions are one of the largest sources of nitrogen pollution in the Chesapeake Bay.16 Mercury Plants in Texas and Pennsylvania topped the list for the nation s highest power plant mercury emission rates. TXU s Martin Lake (Texas) plant ranked number one, with 1,744 pounds of mercury emissions. Two Texas power plants, TXU s Big Brown and American Electric Power s Pirkey, rank in the top 10 for both emission rate and total pounds. Coal-fired power plants are the single largest source of mercury air pollution, accounting for roughly 40 percent of all mercury emissions nationwide.20 Mercury is a highly toxic metal that, once released into the atmosphere, settles in lakes and rivers, where it moves up the food chain to humans. The Centers for Disease Control has found that roughly 10 percent of American women carry mercury concentrations at levels considered to put a fetus at risk of neurological damage.21 Texas Medical Association adopt the Consensus Statement on Methylmercury and Public Health. APPROVED Therefore, policy makers at all levels should: Treat mercury emissions from all anthropogenic sources as "hazardous," and rapidly implement regulations aimed at attaining the maximum achievable emissions reductions; The American public is not adequately protected from mercury pollution. Available data suggest that human activities have increased levels of mercury in the atmosphere by roughly a factor of 3, average deposition rates by a factor of 1.5 to 3 and deposition near industrial areas by a factor of 2 to 10. Major identified sources of mercury pollution in the United States include coal-fired power plants, industrial boilers, municipal and medical waste incinerators, and chlorine manufacturing (chlor-alkali) facilities. While mercury emissions from various sources may be transported long distances in the atmosphere, local mercury sources play an important role in local pollution. Draft EPA modeling indicates that at mercury "hotspots" within the United States (locations where mercury deposition is highest), local emission sources within a state can be the dominant source of deposition. In addition, a recent 10-year study by the State of Florida points to the importance of local mercury pollution sources and the feasibility of measures to protect public health. In that study, strict emission limits applied to incinerators in south Florida were found to produce emissions reductions of 99 percent and corresponding reductions in mercury levels in Everglades fish and wildlife of 60 percent. Mercury threatens human health and child development. Scientific findings indicate that mercury is a significant threat to the fetus, infants, and young children. Exposure to methylmercury, the highly toxic form of organic mercury found in our environment and food, may adversely affect reproduction and a variety of organ systems, including the cardiovascular system and, in particular, the brain and central nervous system. The developing brain is more susceptible to methylmercury exposure than are adult brains, and is most sensitive while in utero. Methylmercury crosses the placenta easily and readily penetrates the fetal brain. It also is secreted in breast milk, although the contribution of methylmercury exposure through lactation is not yet fully understood. ROBERTSON COUNTY RANK IN MERCURY EMISSIONS AS A STATE, IF COAL PLANTS APPROVED High dose exposures to methylmercury during fetal development can result in low birth weight, small head circumference, severe mental retardation, cerebral palsy, deafness, blindness, and seizures. Recent epidemiological studies have shown that children exposed to moderate or low levels of mercury before birth also may experience neurological and development impairment. Outcomes may include delayed walking, delayed speech, and decreased performance on tests of attention, fine motor function, language, visual-spatial abilities, and memory. Coal is cheap if you don t look at total costs According to a report prepared by independent consultants for the Government of Ontario, the province s coal plants kill 668 people per year in Ontario and cause 928 hospital admissions, 1,100 emergency room visits and 333,660 minor illnesses. According to the same report, when the health and environmental costs of burning coal are properly factored in, switching from coal to natural gas for electricity generation would reduce the province s total cost of power generation by $1.7 billon per year. The net savings from replacing coal with energy conservation and renewables would be even greater. As Figure 1 reveals, the total cost per kwh of coal-fired electricity generation is 67% greater than for natural gas-fired generation. DSS Management Consultants Inc. and RWDI Air Inc, Cost Benefit Analysis: Replacing Ontario s Coal-Fired Electricity Generation, Prepared for Ontario Ministry of Energy, (April 2005), p. ii. DSS Management Consultants Inc. and RWDI Air Inc, Cost Benefit Analysis: Replacing Ontario s Coal-Fired Electricity Generation, Prepared for Ontario Ministry of Energy, (April 2005), p. ii. 4

5 H:\HARC_H60\new_EGUs\report\final\Final_H60_EGUand Offset_ Report.doc H:\HARC_H60\new_EGUs\report\final\Final_H60_EGUand Offset_ Report.doc Ozone Impacts of Proposed Power Plants and Offsets by ENVIRON (DRAFT) August 11, 2006 Results from TERC Project H60 Phase 1 Summary Points (3 of 4) Robertson County in Central Texas consistently had the largest ozone impacts from proposed new Electric Generation Units Increases of ~5 to ~7 ppb in episode average maximum ozone from all 17 proposed EGUs and only about half a ppb lower with TXU s offsets. Monitoring data are lacking to place these modeled ozone changes in context. Four Highest Eight-Hour Ozone Concentrations in 2006 as of September 7 The table below lists the four highest daily maximum eight-hour ozone concentrations measured in 2006 in each community where the TCEQ measures ozone. Concentrations that are rated Moderate or higher are color-highlighted based on the EPA-defined Air Quality Index colors. All ozone measurements are in parts per billion. EPA BROCHURE How can ground-level ozone affect your health? Ozone can irritate your respiratory system, causing you to start coughing, feel an irritation in your throat and/or experience an uncomfortable sensation in your chest. Ozone can reduce lung function and make it more difficult for you to breathe as deeply and vigorously as you normally would. When this happens, you may notice that breathing starts to feel uncomfortable. If you are exercising or working outdoors, you may notice that you are taking more rapid and shallow breaths than normal. Ozone can aggravate asthma. When ozone levels are high, more people with asthma have attacks that require a doctor's attention or the use of additional medication. One reason this happens is that ozone makes people more sensitive to allergens, which are the most common triggers for asthma attacks. Also, asthmatics are more severely affected by the reduced lung function and irritation that ozone causes in the respiratory system. Ozone can inflame and damage cells that line your lungs. Within a few days, the damaged cells are replaced and the old cells are shed-much in the way your skin peels after a sunburn. Ozone may aggravate chronic lung diseases such as emphysema and bronchitis and reduce the immune system's ability to fight off bacterial infections in the respiratory system. Ozone may cause permanent lung damage. Repeated short-term ozone damage to children's developing lungs may lead to reduced lung function in adulthood. In adults, ozone exposure may accelerate the natural decline in lung function that occurs as part of the normal aging process. This report, the full Abt Associates report, Power Plant Emissions: Particulate Matter-Related Health Damages and the Benefits of Alternative Emission Reduction Scenarios (June 2004), and the interactive site Your Air on the Web are available at: 5

6 AECT Members American Electric Power Centerpoint Energy El Paso Electric Company Entergy Texas Reliant Energy Texas-New Mexico Power Company TXU Xcel Energy The Association of Electric Companies of Texas, Inc. (AECT) is a trade organization representing electric companies in Texas. Organized in 1978, AECT provides a forum for member company representatives to exchange information on their industry, and to communicate with state and federal government officials. According to a January 2006 publication by AECT titled Questions and Answers on Texas s Competitive Electric Market power is sold and procured based on the prices that buyers pay for electricity produced by natural gas. As a result, natural gas-fueled generation sets the price for all other electricity produced even electricity produced from coal-fired or nuclear-fired generating facilities. April 20, 2006 TXU Media Information Sheet Commitment to Voluntary Air Quality Improvement Setting a New Environmental Standard: TXU s plan will double its solid-fuel fleet while voluntarily improving air quality with large reductions in key emissions. TXU will set a new environmental standard by voluntarily offsetting all sulfur dioxide (SO 2), nitrogen oxide (NOx), and mercury emissions from all 11 new proposed units by making reductions at existing plants. In addition, the company will actually reduce these same key emissions by 20%. To achieve this reduction, TXU will voluntarily remove at least 1.5 pounds of key emissions from existing plants for every one pound from the new units. These actions will more than offset the SO2, NOx, and mercury emissions from the new coal plants and will reduce these key emissions by 20% from current levels. TXU plans to invest about $500 million in this voluntary program it will be in place as the new units become operational. This will be the largest program of its type in the nation and will make way for the next wave of needed electric generation. Benefits: TXU s voluntary new environmental standard will actually improve air quality for key regulated emissions at the same time that generation capacity is significantly increased. This reduction is the equivalent of taking 1.5 million cars off Texas roads or converting 1.6 million drivers to hybrid cars. These reductions are being achieved while adding enough capacity to power 6.5 million homes. Voluntary Verification: TXU will voluntarily enter into a legally-binding commitment with the Texas Commission on Environmental Quality (TCEQ). EPA Reporting: TXU has continuous emission monitors that measure SO2 and NOx emissions 24 hours a day, 7 days a week. These monitors are certified by the Environmental Protection Agency (EPA) and data is transmitted electronically to the EPA. Results are posted in EPA s publiclyavailable Acid Rain Database. Mercury emissions will be measured in accordance with the approved EPA method. LIGNITE ISSUES - Double Dipping TCEQ doesn t involve itself in economic decisions of applicant. Meaning, in part, they don t say what kind of stuff you can or can t burn to make electricity. But BACT is determined as the best available control applied to that particular fuel. Because Lignite is the lowest BTU coal, you must burn significantly more of it to generate heat equivalent to a higher rank coal. It has more ash. These and other faults make it far dirtier to burn and harder to successfully clean up. Thus the lignite burner is having it both ways. TCEQ isn t telling them what they can burn but if they choose to burn the dirtier coal, the standards are more lax. A compelling argument can be made that if the applicant gets to choose the fuel, the State should set a fixed standard for everyone. I understand that this cuts against the grain of the whole regulatory scheme. The fact remains that the rules as they exist allow those that choose to use dirtier methods to generate electricity are externalizing enormous costs to the public, primarily in the form of health related costs. And the current scheme ensures that the market will never accurately value generation methods that are cleaner while continuing to provide de facto subsidies to those who choose the dirtiest methods. The NOX allowances under CAIR will be distributed based on the average of the three highest amounts of heat input from calendar years 2000 through 2004, adjusted for the type of fuel burned: 0.90 for coal, 0.50 for gas, and 0.30 for all other fossil fuels 6

7 50 yr societal choice To generate more electricity than we need, by the Dirtiest Available Technology (DAT), in a plant that will be the dirtiest in Texas for most of its life, and will pollute for the next half century. Theoretical arguments about free (unregulated) markets and government action on behalf of the public interest will become painfully real in some child s lungs or brain 7