Zero Air Pollution? TVA Wind Power Plant

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Common sense isn't.

How does TVA's Wind Power Plant produce no air pollution?

Don't they cut down and burn trees to build it?

Don't they use electricity for plant loads, even while producing none?

Don't they burn fuel to travel to the remote site?

TVA ignores all that?

January 8, 2003

The following information was requested under the Freedom of Information Act on April 7, 2002.

Analysis, data and calculations that TVA used as a basis to state, "The production of wind energy creates no air pollution"
(Reference: http://www.tva.gov/greenpowerswitch/wind_faq.htm (archive 2002), under heading, " What is the role of wind energy (archive 2002) in Green Power Switch?")

The following response was released by TVA on December 2, 2002.

"Enclosed is information from the TVA Environmental Assessments that is responsive to this item of your request."

The document is not responsive to the request. All except maybe one paragraph was written after the claim referenced above, and it, in essence, states the conclusions without justification (or analysis, data and calculations). Perhaps TVA did not have any?

Beginning of TVA Document

From the 1st EA:

March 2000 pg. 5
"Heavy equipment used for site grading and construction would generate small amounts of air pollution via exhaust and fugitive dust for the duration of the site preparation and construction. This is expected to take 3 to 4 months. Likewise, some minor amounts of fugitive dust would also be generated during road upgrading and construction. Because of the short time required for construction, the potential direct, indirect and cumulative effects to air quality during construction would be insignificant. Operation of the wind turbines would not generate any pollutants. Use of the turbines to generate electricity would offset that air pollution that would be produced had conventional fossil fuels (i.e., coal) been used. Thus, direct effects to air quality would be insignificant. Indirect effects from using wind power to generate electricity would result in a minor improvement in regional air quality." [Comment 1]

From the 2nd EA:
April 2002 pg. 4-1
The short version: "The operation of the Buffalo Mountain windfarm expansion would have a positive impact on air quality in the TVA region because wind turbines have no air emissions and can offset the use of other electrical generating plants that emit air pollutants."

The whole section:
April 2002 pg. 4-1 and 4-2
Alternative 1 - Buffalo Mountain Windfarm Expansion

Impacts During Construction

Windfarm Expansion
Impacts to air quality during windfarm construction would primarily result from the exhaust emissions from internal combustion engines in stationary equipment and in motor vehicles used to transport materials to the site and to construct the windfarm, from site clearing activities, and from fugitive dust raised during construction activities. Exhaust emissions are primarily PM, NOx, carbon monoxide (CO), volatile organic compounds (VOCs), and sulfur dioxide (SO2). These are an unavoidable consequence of windfarm construction, and would have negligible effects on local air quality. [Comment 1]

Trees and brush cleared from the windfarm site could be disposed of by open burning. This would have a minor effect on local air quality, and the necessary permits would be acquired in advance of any open burning. Site clearing, excavation, and vehicle movement, both on the windfarm site and on gravel access roads, would raise fugitive dust. The largest size fraction (greater than 95 percent by weight) of fugitive dust emissions would be re-deposited within the construction site boundaries or adjacent to roads. Smaller fugitive dust particulate matter would be subject to transport over a longer distance. Construction areas and access roads will be sprinkled with water as necessary

to reduce fugitive dust emissions. Because of the remoteness of the site, fugitive dust would not impact nearby residents.

Regenesys^TM Facility
The construction of the Regenesys^TM facility at any of the four sites would result in similar air quality impacts. The air quality impacts would be similar to those resulting from windfarm construction, except that there would be little to no open burning of cleared trees and brush, and fugitive dust emissions would be much more localized at the construction site. Open construction areas and unpaved roads will be sprinkled with water as necessary to control fugitive dust. Impacts to off-site air quality would be minimal and would be well below the level of any ambient air quality standard.

Impacts During Operation and Maintenance

Windfarm Expansion
The operation of the Buffalo Mountain windfarm expansion would have a positive impact on air quality in the TVA region because wind turbines have no air emissions and can offset the use of other electrical generating plants that emit air pollutants. In fiscal year 2000, about 63 percent of the electrical power produced by TVA came from the burning of fossil fuels coal, diesel fuel, used oil, and natural gas. A small quantity of renewable fuels, wood and landfill gas, were also burned. Based on TVA's system average air emissions for the year 2000, the Buffalo Mountain windfarm expansion would offset the annual release of about 107 tons of NO_x, 270 tons Of S0₂, and 40,300 tons Of CO₂. [Comment 2]

Regenesys^TM Facility
Operation of the Regenesys^TM facility at any of the four sites would result in similar, negligible impacts on air quality. There would be three emission sources: a cooling tower, a primary stack for bromine releases, and a secondary stack to discharge hydrogen. A notification letter will be submitted to the State of Tennessee Department of Environment and Conservation (TDEC) which will detail the project scope for both construction and operation of this facility. Should TDEC require TVA to apply for a construction permit, the application will be submitted and a permit obtained, prior to commencement of construction. For an identical facility in Mississippi, a permit was not required as the State found that emissions were below the de minimus level that warrants a permit. [Comment 3]

The cooling tower would remove heat from the process and power conversion equipment. It would be rated at 3,000 kW (10,000,000 BTU) per hour. Potable water would be used for makeup water, and suspended solids in the makeup water would be a source of particulate emission in the cooling tower drift. Drift eliminators would be installed in the cooling tower to reduce drift to 0.005 percent of circulation water. The estimated emission rate for PM₁₀ would be 0.125 lb per hour, or 0.55 tons per year.

Bromine would be generated within the storage tank and elsewhere in the facility from the charged sodium bromide electrolyte. Air vented from the tank due to thermal breathing and air vented from the process building would thus contain trace quantities of

bromine. An air extraction system would operate continuously, with two carbon-bed adsorbers mounted in series to remove bromine from the air before venting the gases through 67-foot-high stack. Under normal operation, the annual bromine emission would be less than 10 lb per year.

The sodium bromide would need to be conditioned to maintain efficiency of the energy storage facility. On its return trip from the modules to the storage tank, a small quantity of the sodium bromide passes through an Electrolyte Management System (EMS, see Appendix A for a more detailed description) where the bromine level is reduced, the pH adjusted, and by-product sodium sulfate is removed. In the process, hydrogen would be emitted at a rate of 5.5 lb per hour, or 24 tons per year. Hydrogen is very light and disperses rapidly in the air. Although not an air pollutant, hydrogen can be explosive at concentrations between 4 and 75 percent in air. Consequently, discharged gas would be maintained at a concentration well above its explosive limit prior to being released. This gas would then pass through a water trap. The stack and piping would be purged with nitrogen prior to and following operation of the EMS system to remove any air that could dilute hydrogen to its explosive limit.

TVA has determined that these slight emissions of the operating Regenesys^TM facility would have an insignificant impact on air quality. [Comment 3]

End of TVA Document

Comments

Although TVA was particularly interested in the "benefits" of reducing carbon dioxide (CO2) emissions, when claiming that buying Green Power Switch is equivalent to planting trees, they seemed to overlook CO2 emissions from cutting down and burning trees and running engines for wind power plant construction, when claiming that production of wind energy creates no air pollution. Suddenly the effects are said to be insignificant, but they present no basis.
The indirect emissions reductions are probably based on predicted annual production of 6 million kilowatt-hours per year. The plant has actually produced only about 3-4 million kilowatt-hours per year.
Emissions estimates from Regenesys energy storage were based on normal operations. Worst-case emissions could be considerably worse. It is not clear whether state authorities were fully informed of all details of the operations.

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