California agency reviews issues with revamped Carlsbad project

California Energy Commission staff on Aug. 6 filed a report with the commission committee that is reviewing two recent proposed amendments to the commission’s prior approval of the Carlsbad Energy Center LLC project of NRG Energy (NYSE: NRG).

These are issues resulting from the review of the modifications sought by Carlsbad Energy Center on May 2 and April 29. One amendment would change the Carlsbad Energy Center Project (CECP) from a combined-cycle gas-fired facility, to a simple-cycle gas facility.

The amended CECP would be a simple-cycle generating facility using six, nominally rated 100-MW natural gas-fired combustion turbines with a capacity of 632 MW net output, compared to 540 MW for the licensed CECP. Similar to the licensed version of the CECP, the amended CECP’s units would interconnect to the electrical transmission system via138-kV and 230-kV lines that connect to neighboring San Diego Gas & Electric (SDG&E) switchyards. The amended CECP would be sited within a recessed location along the eastern boundary of the Encina Power Station (EPS) site.

The project revision is the result of a Jan. 14, 2014, multi-party agreement entered into by representative entities of NRG, the city of Carlsbad, and SDG&E. The licensed CECP consisted of two, combined-cycle units. By using six smaller, fast-start, peaking combustion turbine generators (CTGs), the amended CECP would have greater operational flexibility and a shorter start-up time. The peaking units would also be better suited to the continued integration of variable renewable generation by providing more readily dispatchable generation and increased local reliability, the staff report noted.

Also, electricity provided by the 632-MW amended CECP would displace the aging, inefficient EPS Units 1-5 that currently employ once-through cooling (OTC) using seawater. The state of California has mandated the phasing out of OTC plants.

NRG Energy is the parent company of both Carlsbad Energy Center LLC and Cabrillo Power I LLC, owner of the existing EPS facility.

The shutdown and decommissioning of the existing EPS Units 1 through 5 would provide emission offsets for use by the project and enable the cessation of OTC.

Revised project targeted for completion in late 2017

The amended CECP would be constructed over a 23-month period, with a projected online date in the fourth quarter of 2017, which would comply with the State Water Resources Control Board’s OTC Policy. Following the commissioning and operation of the new power plant would be a 12-month period of preparing the EPS generation equipment, structures, and all auxiliary equipment east of the railroad tracks for removal, auction, or destruction.

Demolition and remediation of the EPS generating units, buildings, and all other related equipment, tanks, and ancillary facilities, would occur in a nine-step process, beginning with the 12-story enclosure building and 400-foot stack, and concluding with the water separator tank system’s removal.

Issues identified by staff include:

  • Potential significant impacts of the proposed modification which may be difficult to mitigate;
  • Potential areas of modification noncompliance with applicable laws, ordinances, regulations or standards (LORS);
  • Areas of conflict, or potential conflict, between different parties regarding the proposed modifications; or
  • Areas where resolution may be difficult or may ultimately affect the schedule.

Emissions issue needs to clarified

For one thing, it is unclear that cessation of the historic boiler emissions, per San Diego Air Pollution Control District new source review and/or emission banking rule requirements, would reduce the net facility emissions of NOx and volatile organic compounds (VOC) below District offset thresholds. The San Diego Air Basin in the area of the project site is classified as nonattainment for the state ozone, particulate matter less than 10 microns (PM10) and PM2.5 standards, and federal ozone standard. Without proper offset mitigation for NOx, VOC, PM10, and sulfur oxides, this project could contribute to existing violations of the state and federal ambient air quality standards. Staff is addressing these issues through data requests to the applicant.

Staff has also reviewed the amendment applications but has not found a complete description of the transmission interconnection facilities for all six simple-cycle CTG units. Staff needs a complete description of the proposed transmission interconnection facilities, including the project switchyards, the generation tie lines, and the interconnections to the existing transmission grid. That question is also the subject of data requests to the company.

Staff believes the amendment requests did not include sufficient information for a proper California Environmental Quality Act (CEQA)-level analysis of the demolition of EPS, and the need for data requests and responses could potentially delay the petitioner’s proposed “aggressive” schedule, said the report.

The Aug. 6 report proposed a schedule for this case for information gathering through a Jan. 16, 2015, filing of a preliminary staff assessment. The dates after that, including those for evidentiary hearings and a final commission decision, are left blank.

The Carlsbad Chamber of Commerce on Aug. 11 filed with the commission a letter of support for the project, saying: “A reliable supply of power is a basic requirement of nearly every industry. Local businesses were reminded of this dependency during the blackout of September 2011. We are concerned about the reliability of our power supply given the closure of the San Onofre Nuclear Generating Station, the looming closure of the Encina Generation Station, and the vulnerability of our transmission system to wildfires like the one we experienced a few months ago in Carlsbad.”

The chamber added: “We applaud the City of Carlsbad for reaching an agreement with NRG and SDG&E that will result in a more environmentally friendly project. The agreement also will facilitate the demolition and redevelopment of the Encina site and adjacent service center for non-industrial purposes. It is our firm belief that this revised project will provide Carlsbad and the region with the most logical and reliable solution to our power needs.”

About Barry Cassell 20414 Articles
Barry Cassell is Chief Analyst for GenerationHub covering coal and emission controls issues, projects and policy. He has covered the coal and power generation industry for more than 24 years, beginning in November 2011 at GenerationHub and prior to that as editor of SNL Energy’s Coal Report. He was formerly with Coal Outlook for 15 years as the publication’s editor and contributing writer, and prior to that he was editor of Coal & Synfuels Technology and associate editor of The Energy Report. He has a bachelor’s degree from Central Michigan University.