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Common sense isn't.

TVA's Buffalo Mountain Wind Power Plant

Dangers of RegenesysTM Energy Storage for TVA's Buffalo Mountain Wind Power Plant

Do We Want the "Green Giant" Batteries?

Is TVA Building New Terror Targets?

Originally Posted: October 6, 2002

News from 2004-08-18. Added 2006-05-07: Tennessee Valley Authority loses millions on Mississippi (Regenesys) power

Update 12/22/2003: Cancellation of RegenesysTM Energy Storage for Columbus Air Force Base

Update 12/21/2002: Cancellation of RegenesysTM Energy Storage for TVA's Buffalo Mountain Wind Power Plant

A popular Government without popular information or the means of acquiring it, is but a Prologue to a Farce or a Tragedy or perhaps both. Knowledge will forever govern ignorance, and a people who mean to be their own Governors, must arm themselves with the power knowledge gives.
-- James Madison (1751–1836), U.S. president. Madison to W.T. Barry, August 4, 1822 ( Reference Bartleby.com, archive, 2004).

Learned institutions ought to be favorite objects with every free people. They throw light over the public mind which is the best security against crafty and dangerous encroachments on the public liberty.
-- James Madison (1751–1836), U.S. president. Madison to W.T. Barry, August 4, 1822 ( Reference Bartleby.com, archive, 2003).

What would you call a facility with a worst case distance to toxic endpoint* of greater than 25 miles, and alternative scenario distances of 3.5 miles and 5.5 miles? Would you call that facility "green" or "with relatively low environmental impacts?" Would you volunteer to pay extra to subsidize such a facility as part of a "green choice" program? Would you want it in your town? Would you think it was right to hold public hearings and publish environmental assessments without publicizing those possible consequences?
* The toxic endpoint concentration is the maximum airborne concentration below which it is believed individuals could be exposed for one hour without irreversible or serious health effects that could impair the individual's ability to take productive action.
The RegenesysTM energy storage system being built in Mississippi (Reference Platts.com at Archive.org, 2003), and being proposed as part of TVA's wind power plant expansion is such a facility ( Reference, TVA.gov, archive, 2002). TVA's unpublicized offsite consequences analysis contains those estimates. If you make arrangements to meet with the project manager, Anita Rose, and jump through some hoops of 40 CFR 1400 (archive, 2003), you too may view the analysis.

TVA published environmental assessments, held public meetings, listened to public comments, and appeared to respond to public comments on their proposals to build wind power plants and associated RegenesysTM energy storage systems.

There was an appearance of public involvement in decision making, but accident consequence information was withheld from consideration, and some misleading or false information was spread ( Ref. 1 (archive 2005), and Ref. 2 (pdf, local) written and previously distributed by Nigel Cornwall of Cornwall Consulting) regarding the safety of the chemicals being used; however, some articles did point out the risks in a general way, and highlighted the plans to operate the facility remotely (Reference Elizabethton Star at Archive.org, 2004).

TVA publicized only selected portions of the offsite consequence analysis; in particular, only the portions that indicated a low probability of accidents occuring. They did not publicize estimates of consequences (Ref. Appendix D of the Environmental Assessment at TVA.gov archive, 2002).

Technically, the RegenesysTM energy storage system does not store toxic substances above threshold quantities listed in 40 CFR 68.130. Therefore, TVA is apparently not required to prepare a Risk Management Program, and is exempted from other requirements. This is apparently due to the storage tanks only containing about 300 pounds of bromine gas during normal operation, which is below the 500 pound threshhold quantity. The CFR fails to recognize that charged sodium bromide solution (bromine complexed as tribromide, NaBr3) will quickly release additional bromine gas when the solution is exposed to the atmosphere. For TVA's worst case scenario, they estimated that approximately 690,000 pounds of bromine gas could be released to the atmosphere in about 14 minutes, if the 500,000 gallon, double-walled tank were to somehow catastrophically fail.

TVA felt that the General Duty Clause of the 1990 Clean Air Act amendments required them to perform the offsite consequence analysis, but TVA apparently also felt it was not necessary to fully inform the public of the results of the offsite consequence analysis.

Interesting questions remain:

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