Tuesday, July 23, 2013


(The City of Brownsville and the Brownsville Public Utility Board has been tight-lipped about the details surrounding the agreement between them and Tenaska in the construction of the 800 MegaWatt gas-fired electric plant they plan to build in the city. The information in this post was taken directly from their application to the Environmental Protection Agency. Of particular interest is the section dealing with the prevention of significant deterioration (PSD) of greenhouse gases.)  

By Juan Montoya
Texas Commission on Environmental Quality (TCEQ) Customer Reference Number (CN) 604252627
TCEQ Regulated Entity Number (RN) 106579600.

Taken as face value, the 800 MW electric plant planned by Tenaska and the City of Brownsville will not only provide city with 200 Megawatts (MW) of electric power and allow Tenaska to sell the remaining 600 MW to the grid. And, despite repeated attempts to get a fix on the total cost of the PUB ratepayers' financial commitment to build this $500 million plant, PUB and Tenaska have been successful in convincing the Texas Attorney General to keep those details from the public claiming the "competitive" nature of the project. This much we do know:
Tenaska lists two possible alternatives in its EPA application. It is proposing to permit a 1‐on‐1 or a 2‐on‐1 combined cycle combustion turbine (CCCT) configuration. The Brownsville Generating Station will be designed to have an estimated nominal power generation summer condition output capacity of approximately 400 megawatts (MW) for the 1‐on‐1 configuration or 800 MW for the 2‐on‐1 configuration.
Public announcements by the BPUB have focused on the latter design with the utility's ownership interest entitling it to the 200 MWs, enough its spokesmen say, to supply power to approximately 100,000 residences.
Under the agreement, BPUB is responsible for building a water pipeline from the Robindale Road wastewater plant to the power plant, a distance of roughly five miles, as well as a gas pipeline from Edinburg — about 50 miles — to supply the power plant with fuel. Tenaska expects that the EPA will approve its plans and permit construction of the power plant to begin in 2014.
Tanaska states in the EPA application that the plant will emit the following contaminants:
1. nitrogen oxides (NOX)
2. carbon monoxide (CO) and
3. and volatile organic compounds (VOC)
4. Other air contaminants not listed above: NH3, H2, SO4 Mist and (NH4)2, and SO4 will also be released. The proposed Brownsville Generating Station is within a major facility category and subject to a 100 tpy (Tons Per Year) threshold for classification as a PSD major source.
(What Does PSD Require?
The EPA requires any new power plant such as that proposed for Brownsville to file a Prevention of Significant Deterioration (PSD) that applies to new major sources or major modifications at existing sources for pollutants where the area the source is located is in attainment or unclassifiable with the National Ambient Air Quality Standards. It requires the following:
1. installation of the Best Available Cost Technology (BACT)
2. An air-quality analysis
3. an  additional impact analysis and
4. public involvement.
The Brownsville Generating Station is estimated to have potential emissions in excess of 100 tpy for NOx, CO, and VOC emissions.
In addition, the greenhouse gas (GHG) emissions exceed the tailored major source PSD threshold of 100,000 tpy.
Therefore, the Brownsville Generating Station will be considered a new major source with respect to the PSD program. According to EPA guidance, the "major for one, major for all" PSD policy, if a site is major for one or more criteria pollutants, then the other criteria pollutant emissions need to be
compared to the Significant Emission Rates (SERs) when determining PSD applicability for particulate matter (PM), particulate matter with an aerodynamic diameter of 10 microns or less (PM10), particulate matter with an aerodynamic diameter of 2.5 microns or less (PM2.5), sulfur dioxide (SO2) and sulfuric acid (H2SO4) mist.
Based on emissions estimates for the Brownsville Generating Station, the proposed project will be PSD major for
CO2: 3,169,143.4 Tons Per Year
CH4: 3,421.49 Tons Per Year
N2O: 80.254 Tons Per Year
SF6: 0.005 Tons Per Year
Total CO2e: 3,265,993 Tons Per Year

In order to capture and transport the captured CO2 to a sequestration site, Tenaska suggests the following:
"Prior to sending the CO2 stream to the appropriate sequestration site, it is necessary to compress the CO2
from near atmospheric pressure to pipeline pressure (around 2,000 psia). The compression of the CO2 would require a large auxiliary power load, resulting in additional fuel (and CO2 emissions) to generate the same amount of power."
However, "While carbon capture technology may be technologically available on a small‐scale, it has not been demonstrated in practice for full‐scale natural gas combined cycle power plants, such as the proposed Brownsville Generating Station."
Tenaska would need to either transport the captured CO2 to an existing CO2 pipeline located at the Hastings Oil Field, operated by Denbury Resources (258 miles from the proposed Brownsville Generating Station), or transport the CO2 to a site with recognized potential for storage (e.g., enhanced oil recovery [EOR] sites). The closest potential EOR site is an existing oil well, located in Jim Hogg County, operated by Wynn ‐ Crosby Operating, Ltd. (Jim Hogg Well, API No. 24732057). This well is located approximately 106 miles from the proposed Brownsville Generating Station." 
"...Even though transporting and sequestering CO2 is feasible, CCS is not a viable, technically feasible
option for this project due to the fact that CO2 capture has not been achieved in practice for a large scale, 800 MW natural gas combined cycle plant, which was determined by Tenaska not to be feasible in Section Nevertheless, Tenaska has chosen to carry it forward in the Best Available Cost Technology (BACT) analysis to evaluate and present the associated environmental, energy and economic impacts."
"The capital cost for the proposed Brownsville Generating Station is approximately $500 million. Using the same cost factors as Carbon Capture and Storage (CCS) cost, the amortized capital cost for the proposed project is approximately $52 million/yr (including annual operation and maintenance costs). Based on these cost estimations, implementation of CCS will cost Tenaska almost 10 times the project capital cost on an annual basis, which is economically infeasible."

"Economic Feasibility: The low purity and concentration of CO2 in the combustion turbines’ exhaust means that the per ton cost of removal and storage will be much higher than the public data estimates for much larger carbon rich fossil fuel power facilities due to the loss of economies of scale. Even using low‐side published estimates for CO2 capture and storage of $256 per ton for a new natural gas combined cycle facility, assuming a conservative $6/MMBtu gas price means added cost to the project over $200,000,000 per year."
So instead of transporting the carbon monoxide contaminants that will be created by the Brownsville Generating Plant, Tenaska is proposing that it be allowed to periodically check its emissions and monitor its operations but that it be allowed to release the 90 percent of the 3,265,993 Tons Per Year its BACT cannot capture into the Brownsville environment anyway.
It is noteworthy to point out that on Page 8 of its EPA statement, Tenaska states:
"The Brownsville Generating Station will be located in Cameron County, Texas. An area map is included in this section to graphically depict the location of the facility and the power block with respect to the surrounding topography.
In an area area map tendered to the EPA by Tenaska that is centered on the Brownsville Generating Station and  extends out at least 3,000 feet from the property line in all directions, it depicts the depicts the property line with respect to predominant geographic features (such as highways, roads, streams, and railroads). The image shows there is one elementary school (Rancho Verde Elementary School) within 3,000 feet of the facility boundary.
Given the fact that state state officials estimate that the Rio Grande Valley will need 2,800 MW of power in the next 10 years, and that the plants online – including the Brownsville-Tenaska generating plant – will provide 2,861 MWs, it is obvious that it within 10 years we will be forced to seek power elsewhere despite the multimillion expenditures required from PUB ratepayers for this plant now.
Wouldn't it be more sensible to buy our power off the grid than to encumber our future generations with this costly – and environmentally risky – undertaking?


Anonymous said...

Your summary and reasoning make sense to me.

Anonymous said...

COPY & PASTE, Juan? Some "investigative" reporter. More like a copycat. jmho

Anonymous said...

I hope this makes my bill cheaper! So I can buy more beer. JMHO

Anonymous said...

I am wondering if any of the bloggers is going to write about the BISD board meeting on July 23? No wonder the school district has problems with principals, teachers and clerks. When you sweep, stairs and steps should be cleaned from the top to the bottom. How sad to see a public meeting that looked more like a circus.

Anonymous said...

Excellent piece, Juan! Imagine the environmental impacts these pollutant-generating, water-consuming plants will have on our quality of life up and down the RGV. The communities of Brownsville, San Benito, Harlingen and Edinburg are currently proposing power generating plants that will distribute the pollutants you listed into our air and soil.

The question we all should be asking is, why, all of a sudden, is there such a push to build power plants in our cities bordering Mexico?

Recently read that a kilowatt (kW) is selling for 19-22 cents in Matamoros, compared to an average of 9.5 cents here in the RGV. If, for example, B'ville is going to receive 200 Mw of the 800 generated, with the rest going to "the grid," is the true reason why all these plants are suddenly popping up in our border cities is to take advantage of the higher rates in Mexico?

Generally, it costs 6.5 cents to produce a kW. In the RGV, that's about 3 cents profit per kw for power companies. Selling in Mexico, on the other hand, these power companies will realize 13-16 cents profit per kW. At those kinds of returns, how long do you think it will take the power companies to raise our kW rates to be more in-line with the returns they realize in Mexico?

Think there are many questions that need to be answered by our elected officials on the environmental impacts these new power plants will have on the quality of our air, soil and waterways before all these plants are approved. Think we need assurances that our kW rates will not increase for a fixed period to cover the costs and miscalculations of our elected officials and these new power plant operators. The quality of life in the RGV is bigger and more important than each of these communities individually.

Anonymous said...



Dante said...

the missionhere is to SCREW the citizens of brownsville with more fees thats all the mayor wants with this new plant and also let his compadre Marin make a huge consulting fee. es todo