The U.S. Environmental Protection Agency sent an Oct. 25 letter to the California Energy Commission expressing certain concerns over the Preliminary Staff Assessment/Draft Environmental Impact Statement for the coal-fueled Hydrogen Energy California Project.
The California Energy Commission is responsible for reviewing and ultimately approving or denying all applications needed to construct and operate the power plant. The federal action under the National Environmental Policy Act (NEPA) that requires an EIS is the U.S. Department of Energy’s decision whether to provide about $408m in financial assistance to the applicant. DOE is cooperating in the PSA/EIS process.
While the combined assessment and EIS approach presented challenges for the agencies due to the differences between the astate and federal timelines and procedures, it simplifies the review process for the public, said EPA. “We note that CEC’s process provides additional transparency and substantial public input opportunities, which are especially important considering the presence of a community with environmental justice concerns in the project vicinity, and we encourage DOE to continue to take into consideration the public input received through that process,” said the EPA.
The Hydrogen Energy California LLC (HECA) project is intended to demonstrate integrated gasification combined cycle (IGCC) and carbon capture technology on a commercial scale, turning a fuel blend – consisting of 75% coal and 25% petroleum coke – into a synthesis gas in a new power plant capable of generating 405 MW gross power and a nominal 300 MW to the grid. According to the PSA/DEIS, up to 90% of the carbon in the raw syngas would be captured, compressed and transported for use in enhanced oil recovery.
The EPA said its review has identified significant environmental impacts that should be avoided in order to provide adequate protection for the environment. Corrective measures may require substantial changes to the preferred alternative or consideration of some other project alternative (including the no action alternative or a new alternative). EPA said it intends to work with the lead agency to reduce these impacts.
For example, said EPA: “The PSA/DEIS has a limited alternatives analysis. In our scoping comments (May 2010), EPA suggested that the EIS evaluate the use of dry cooling or wet-dry hybrid cooling as a NEPA alternative to the proposed project. The PSA/DEIS states that a dry cooling or wet-dry hybrid cooling alternative remains under consideration and will be evaluated by CEC in the Final Staff Assessment/Final EIS (p. 6-2); also, that DOE believes that a dry cooling alternative is a project-level alternative that merits further analysis and consideration (p. 6-46). We appreciate this, but note that, for the Final EIS process, no formal public review period will be provided. Since the CEC process allows public comment up until the evidentiary hearings for the project, which will occur after the Final Staff Assessment/Final EIS is issued, we recommend that DOE consider any public comment that is received by CEC regarding a dry cooling alternative. We understand that DOE will wait until CEC makes it decision before signing the NEPA Record of Decision (ROD).”
In another example, EPA said it wants firm commitments about CO2 usage and eventual storage. “We agree with CEC staff’s suggestion that, at this stage of planning, HECA should enter into a binding contract with Occidental of Elk Hills, Inc. that identifies the responsibilities of each party to demonstrate and document permanent sequestration of the supplied CO2,” the agency said. “CEC is also proposing that this contract require OEHI to provide a CO2 Emissions Sequestration Plan that details the design and operation, monitoring, and recordkeeping requirements for ensuring CO2 emissions sequestration (condition of certification GHG-3). Equally important is proposed condition of certification GHG-2, which would require the project owner to shutdown gasifier operations if OEHI stops accepting the CO2 for sequestration or otherwise as necessary for compliance with the CO2 Emissions Performance Compliance Plan, SB 1368, or other regulatory requirements. EPA fully supports these conditions.”