Health and Environmental Issues
White Stallion does not have to provide an EIS, because federal funds are not being used to construct the energy center, nor is the development relying on federal loan guarantees. The only federal jurisdiction in the permitting process is any impact to the wetlands and the barge unloading facility, both of which are governed by the U.S. Army Corps of Engineers. The Corps is in the process of reviewing the application submitted by White Stallion and will determine if an EIS is required. An EIS is not expected because the impacts under its jurisdiction are minimal. All other permits are governed by the Texas Commission on Environmental Quality (TCEQ).
However, with that said, it doesn’t mean that White Stallion is not addressing potential environmental impacts from this project. White Stallion has invested millions of dollars and has spent three years evaluating and minimizing the environmental impacts of our project.
The environmental considerations for the development are addressed in a way that meets or exceeds regulatory and permit requirements. The permit process itself provides a checks and balance to determine that environmental issues have been adequately addressed. There have been several public comments and even a hearing on the environmental permits for this project. White Stallion has responded to each and every comment and in many cases has adjusted to better accommodate these concerns. The adjustments continue to be refined as White Stallion applies for the multiple permits and as concerns are identified. Some examples include:
- White Stallion met with farmers and listened to their concerns about water usage from the Colorado River. From those discussions White Stallion has committed to either funding the construction of an $8 million, 9-mile closed pipe from LCRA’s Bay City Pumping Station on Route 35 to the White Stallion Energy Center or to install a concrete and synthetic liner for this length of canal. Either alternative will reduce the facility’s operational water requirement by over 8,000 acre-ft/yr, from 36,000 acre-feet per year to between 28,000 and 25,000 acre-feet per year.
- White Stallion has evaluated potential groundwater resources for conjunctive use during drought conditions.
- The original footprint of the plant impacted on-site wetlands. Our engineers are evaluating optional arrangements that could further reduce or eliminate these impacts. Bridges will span creeks, avoid removal of trees where possible, and so on.
- The circulating fluidized bed (CFB) technology chosen for this plant operates at lower temperatures to minimize the formation of nitrogen oxide and nitrogen dioxide (NOx); thereby reducing these emissions significantly from plants using other technologies. Multiple technologies were evaluated before choosing a CFB and are described in the air permit application. Integrated gasification combined cycle (IGCC) technology is one that is commonly mentioned as a lower emitting technology; however, IGCC technology has reliability problems and is required to be shutdown too often for commercial purposes. The CFB technology is the better choice because of its versatility to use multiple fuels. It is also more efficient and has lower emissions than other traditional technologies.
The White Stallion team has invested millions of dollars and has spent several years evaluating and minimizing the environmental impacts of the development.
- Much of the electricity currently generated in America uses technology that was built in the 1960s and 1970s. It is like driving a Model T in 2010. White Stallion will be approximately 70% to 80% cleaner by law than the average coal plant during that time in the United States. Opposition to ALL coal plants is killing the process to replace these polluting Model T’s with cleaner Ford F-150s.
- First, the circulating fluidized bed (CFB) technology proposed for White Stallion does not slurry the ash as is done in other power plants, so the stories you’ve heard about what happened at the Tennessee Valley Authority (TVA) will not happen at White Stallion. At the White Stallion Energy Center, ash will be generated in a dry state, slightly moistened to eliminate dust formation during travel and then placed in a landfill. The ash will be composed of a high portion of limestone, which will cause it to set up like concrete in a short period of time after placement in an on-site landfill. Some ash from other plants has had beneficial re-use in various operations such as wall boards and road construction. White Stallion will continue to evaluate potential re-use options as an alternative to disposal.
Comparing the new White Stallion ash disposal facility to the old Tennessee Valley Authority (TVA) facility is an apples and oranges comparison. The ash produced by old pulverized coal (PC) technology electric generation units, such as used by TVA, was disposed of by transporting wet ash in a slurry form (50% water) via pipeline to a pond. This pond was usually formed by installing an earthen dam across a creek. The slurry was pumped into the pond where the water was decanted from the ash.
White Stallion is using the new circulating fluidized bed (CFB) technology to generate electricity. This technology requires limestone to be inserted into the combustion process to reduce emissions. As a result, the ash produced from this process is a dry substance with high lime content similar to low grade cement. The baghouse air filtration system captures over 99% of this ash. The ash is loaded into trucks at the plant site and sprinkled with a small amount of recycled water for dust control and then transported to an on-site landfill for disposal. When the ash is deposited in the onsite landfill, it sets up like low-grade concrete within a few hours and by the nature of its physical state cannot flood out of the area as what happened at the TVA facility.
- No. The ash will be slightly moistened prior to transporting to the landfill to prevent dusting. The moisture and limestone content will cause the ash to set up like concrete in the landfill and prevent any dusting problems.
- No. The ash/limestone will be contained in above-ground silos until it is transported to the on-site landfill. The ash/limestone will set up like concrete shortly after being placed in the landfill so that by it’s own physical state would not spread to other areas if flooded. The landfill will be managed in such a way as to collect storm water run-off that contacts any exposed ash material. In regards to flood control, the plant proper will be located above the 100-year floodplain elevation and a levee will be constructed around the landfill area to control both run-on and run-off from a 250-year flood event.
- No. The landfill is being designed with multiple applications to prevent leaching. First the landfill will have two separate liners to prevent any liquids from migrating out. And as a security measure, a leachate collection system will be placed in the landfill so that any liquid accumulation can be monitored and removed. The ash sets up like a block of concrete and rainwater will not carry constituents out of concrete.
- No. The ash from the White Stallion Energy Center is solid in nature. The ash is collected in aboveground silos when generated and then transported to an on-site landfill for disposal. The landfill will be surrounded by a levee to prevent run-off. The landfill will also be managed to limit the amount of material that will be exposed during rainfall events.
It is our stated intent that the White Stallion Energy Center will not impact the health of Matagorda County residents. We will use the most advanced technology available to prevent air and water pollution. In addition, continuous emissions monitors (CEMs) will be installed to ensure that White Stallion’s emissions and discharge water continue to comply with all state and federal environmental regulations. The data collected from these monitors will be available to the Matagorda County Commissioners Court and third-party engineering firms of the Court’s choosing. We will also evaluate new pollution control technologies as they become commercially-available.
The TCEQ evaluates all air and wastewater discharges for impacts to human health prior to issuing a permit. These evaluations are based on independent scientific studies that calculate values that will not adversely affect human health. The air permit models predict ground-level emission concentrations in an approximately 12-mile radius away from the plant. The model estimates the emissions that may result from operating the plant and these are most often greater than the actual emissions. The modeled estimates are compared to overly conservative risk-based values called an “effects screening level” or ESL.
The TCEQ has a separate Department of Toxicology that coordinates all TCEQ activities that assess risks to human health and develops these ESLs. These toxicologists are also the staff that review information presented in the individual permit applications to determine if the plant will have any negative impacts on human health. ESLs are determined through reviewing scientific studies performed on individual contaminants to estimate the value where no adverse effects are noted. The TCEQ Toxicology Division has been involved with numerous studies investigating human exposure to airborne toxic chemicals and the potential of these exposures to cause adverse health effects. These studies have been critically important: they have not only led to a greater understanding of air pollution and more knowledgeable decision-making by the TCEQ, but they have also become an invaluable way to address community concerns, since many of these studies were originally requested by citizens. In addition to the ESLs, the National Ambient Air Quality Standards and the state property line standards are used in the evaluation.
You’ve heard claims about expected incidents of respiratory problems if this plant is built; however, the TCEQ performs the risk analysis described above prior to setting limits for the power plant that are based on numerous certified scientific studies performed for individual chemicals.
It is also of interest that Matagorda County hired Herbert S. Smith, P.E., an independent engineer, to review the White Stallion Energy Center air permit. His findings concluded that White Stallion would not “create a violation of the 8-hour ozone limit”; nor would there be an “incremental increase of any pollutant greater than the maximum allowed under the PSD standard…”. Smith’s March 30, 2009 report included this Summary Statement.
The wastewater permit uses information about the specific receiving water body (Colorado River) and the anticipated effluent characteristics to establish effluent limits that will ensure that the river continues to meet all state water quality standards. In addition, we will continue to look for ways to reduce the plant’s water usage requirement by evaluating emerging technologies.
No. White Stallion will have equipment to control emissions. Emission allowables from the plant have been determined based on levels that ensure protection of human health and the environment.
The permit limits are maximum values allowed and White Stallion intends to stay well below those limits.
The environmental permits that White Stallion is issued will ensure that limits are set for the plant that will not allow for harmful or detrimental effects to the surrounding area and people. The permit applications available in the Public Library provide detailed information on estimated emissions and discharges from the plant.
For example, the predominant water to be discharged from the plant is blowdown of recycled water from the cooling towers. Cooling water will contain the same constituents found in the river water upstream from where it is taken, but it will be concentrated since the water vapors have been evaporated in the cooling tower process. There will also be a smaller stream from a package domestic sewage plant. Run-off water from fuel storage piles (e.g. coal, pet-coke and limestone) will be collected in a lined surface impoundment. Any particles will be allowed to settle out of the water prior to any discharges. Discharges from this impoundment will only occur if the impoundment is reaching capacity, otherwise the water will be reused for dust control on the fuel pile in the plant.
White Stallion Energy Center would be subject to massive financial penalties. If it were determined that the violations were intentional, White Stallion would be subject to criminal prosecution. That said, White Stallion does not intend to violate permit conditions. Too much planning has gone into this development for that to occur. Furthermore, in order to receive financial backing for construction, White Stallion had to ensure that this plant would operate effectively and efficiently.
Prior to submitting the permit applications, the emissions and discharges were evaluated for capability to meet permit conditions. Discussions were held with vendors of process equipment and with pollution control equipment to determine what was needed for compliance. Many tests will be performed during start-up of the plant to verify that the plant is meeting or exceeding what was represented in the permit applications.
- Yes. However, Texas already uses more natural gas to generate electricity than any other state. This has pushed electric rates in Texas to among the highest levels in the nation. Power generated from using solid fuels will balance this trend and lower natural gas prices and lower electricity costs to preserve the economic viability of the entire economy of South Texas.
- The desalination of sea water so that it can be used in boilers and cooling towers increases the cost of water eight times. We will monitor this technology and consider using it if the costs come down.
- A recent water study by the Lower Colorado River Authority (LCRA) found that there is enough water available in the basin to serve White Stallion and the agricultural interests with water left over. There has never been a curtailment of water supply in the history of LCRA. In addition, White Stallion has prepared a drought contingency plan as part of the contract with LCRA to purchase water. Groundwater is currently being evaluated for conjunctive use during drought conditions.
- The White Stallion Energy Center will have two 30-foot diameter chimneys, which will be approximately 490 feet above ground level. For comparison, there are 27 lighted radio towers in Matagorda County and a couple of these are taller at 500 feet above ground level.
- White Stallion initially presumed that it would have use of the POBC facility, which was a factor in choosing the site for the project. POBC has issued letters in opposition to the project with permit regulators, thus White Stallion had no choice but to apply for construction of its own docking facilities. However, construction has not begun yet and this is still up for negotiation.
- White Stallion will utilize multiple modes of transportation to deliver materials to the plant, including rail and barge. There will be an average of two river deliveries a day, consisting of either two 1,700-ton barges on a tug or one 3,000-ton barge on a tug.
- Due to the size of locks along the transportation route from the source material to the plant, smaller barges will be needed. The larger barges are 3,000 tons and 53 feet wide by 300 feet long. The smaller barges are 1,700 tons and 35 feet wide by 195 feet long. If the smaller barges are used, two or three barges per day will be needed. If larger barges can be used, then one or two barges per day will suffice. The river is about 250 feet wide at the site location.
- The main line railroads have estimated that 12 to 16 trains per day pass through Bay City. White Stallion will require an average of one train per day to pass through Bay City.
Yes. White Stallion Energy Center estimates to pay approximately $20 million dollars in property taxes annually and no ownership structure will eliminate these funds.
WHITE STALLION ADDITION TO LOCAL TAXES
TAXING ENTITY ESTIMATED ANNUAL OBLIGATION Bay City ISD $13,000,000 Matagorda Fiscal Court $3,000,000 Matagorda County Hospital $2,000,000 Port of Bay City $500,000 Reclamation and Conservation District #1 $500,000
- No, that has never been our intention.
- No. The White Stallion developers have never considered such an action. This is a rumor generated by the energy center’s opposition.