docket lip - south carolina
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In Re:
STATE OF SOUTH CAROLINA
BEFORE THE PUBLIC SERVICE COMMISSION
Docket No. 2001-507-E
Application of Palmetto Energy Center for )
a Certificate of Environmental Compatibility)
and Public Convenience and Necessity to )
Construct a Major Utility Facility )
)
L" I
DIRECT TESTIMONY
OF
DR. GEORGE C. HOWROYD, III ( Tab 1 )
and
JOHN E. NILAND ( Tab 2 )
FOR
PALMETTO ENERGY CENTER, LLC
( see separate bound document for Direct Testimony and Exhibits
of Art Holland for Palmetto Energy Center, LLC )
STATE OF SOUTH CAROLINA
BEFORE THE PUBLIC SERVICE COMMISSION
Docket No. 2001-507-Et
lip I o, op
In Re: Application of Palmetto Energy Center for )a Certificate of Environmental Compatibility)and Public Convenience and Necessity to )Construct a Major Utility Facility )
)
DIRECT TESTIMONY
OF
DR. GEORGE C. HOWROYD, III ( Tab I )
and
JOHN E. NILAND ( Tab 2 )
FOR
PALMETTO ENERGY CENTER, LLC
( see separate bound document for Direct Testimony and Exhibits
of Art Holland for Palmetto Energy Center, LLC )
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STATEOFSOUTHCAROLINA
BEFORETHE PUBLIC SERVICECOMMISSION
DocketNo. 2001-507-E
In Re: Applicationof PalmettoEnergy )Center,LLC for Certificateof )EnvironmentalCompatibilityand )PublicConvenienceandNecessity )to ConstructaMajor Utility Facility )
)
DIRECT TESTIMONY
OF
DR. GEORGE C. HOWROYD, III
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PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
My name is George Clarion Howroyd, III. My business address is 115 Perimeter
Center Place, N.E., Suite 700, Atlanta, Georgia, 30346.
BY WHOM ARE YOU EMPLOYED AND IN WHAT CAPACITY?
I am employed as a Principal Engineer by CH2M HILL, a Denver-based engineering
consulting firm. CH2M HILL is an international engineering and environmental
consulting company with approximately 12,000 employees in more than 120 offices
worldwide. Our annual business volume is more than $2 billion. CH2M HILL is
engaged in the business of providing environmental, engineering, and design services
for new and existing industrial facilities, including the power generating industry.
PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND AND
PROFESSIONAL EXPERIENCE.
I received a Ph.D. in Mechanical Engineering from the University of Waterloo in
Ontario, Canada in 1979. I also have a M.Sc. (1975) and a B.Sc. (1973) _or_ the ....
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STATE OF SOUTH CAROLINA
BEFORE THE PUBLIC SERVICE COMMISSION
Docket No. 2001-507-E
In Re: Application of Palmetto Energy )Center, LLC for Certificate of )Environmental Compatibility snd )Public Convenience and Necessity )to Construct a Major Utility Facility )
)
DIRECT TESTIMONYOF
DR. GEORGE C. HOWROYD, IH
I Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
2 A. My name is George Clarion Howroyd, III. My business address is 115 Perimeter
3 Center Place, N.E., Suite 700, Atlanta, Georgia, 30346.
4 Q. BY WHOM ARE YOU EMPLOYED AND IN WHAT CAPACITY?
5 A. I am employed as a Principal Engineer by CH2M HILL, a Denver-based engineering
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consulting firm. CH2M HILL is an international engineering and environmental
consulting company with approximately 12,000 employees in more than 120 offices
worldwide. Our annual business volume is more than $2 billion. CH2M HILL is
engaged in the business of providing environmental, engineering, and design services
for new and existing industrial facilities, including the power generating industry.
11 Q. PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND AND
12 PROFESSIONAL EXPERIENCE.
13 A. I received a Ph.D. in Mechanical Engineering from the University of Waterloo in
14 Ontario, Canada in 1979. I also have a M.Sc. (1975) and a B.Sc. (1973) afro the
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same university. I have more than 20 years of experience in environmental
engineering and consulting. Prior to my employment at CH2M HILL (in 1995), I was
employed by Dames & Moore, a Los Angeles based engineering consulting firm, from
1977 through 1995. When I left Dames & Moore, my position was Division Manager,
Air Quality Services. While working for both firms, I have been actively involved in
conducting environmental assessments, environmental permitting, domestic and
international environmental audits and compliance assessments, emission inventory
development, toxic air pollutant evaluations and assessments, dispersion modeling,
control technology assessments and evaluations, regulatory analysis and interpretation,
air quality and meteorological monitoring, and preparing and sponsoring expert
testimony in the same areas. I have assisted domestic and worldwide international
clients in the general manufacturing, energy and power, pulp and paper, automotive,
petrochemical, petroleum, steel, utility, and food products sectors.
ON WHOSE BEHALF ARE YOU APPEARING IN THIS PROCEEDING?
I am appearing on behalf of Palmetto Energy Center, LLC ("Palmetto Energy"), a
subsidiary of Calpine Corporation ("Calpine").
WHAT ARE YOUR RESPONSIBILITIES WITH REGARD TO THE
PALMETTO ENERGY PROJECT?
CH2M HILL is responsible for the environmental permitting of the proposed facility.
This area of responsibility includes the preparation of the permit applications and
supporting documentation for all environmental and related permits that will be
required for the construction and operation of the facility. As the Principal Engineer
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same university. I have more than 20 years of experience in environmental
engineering and consulting. Prior to my employment at CH2M HILL (in 1995), I was
employed by Dames &. Moore, a Los Angeles based engineering consulting firm, I'rom
1977 through 1995. When I left Dames & Moore, my position was Division Manager,
Air Quality Services. While working for both firms, I have been actively involved in
conducting environmental assessments, environmental permitting, domestic and
international environinental audits and compliance assessments, emission inventory
development, toxic air pollutant evaluations and assessments, dispersion modeling,
control technology assessments and evaluations, regulatory analysis and interpretation,
air quality and meteorological monitoring, and preparing and sponsoring expert
testimony in the same areas. I have assisted domestic and worldwide international
clients in the general manufacturing, energy and power, pulp and paper, automotive,
petrochemical, petroleum, steel, utility, and food products sectors.
14 Q. ON WHOSE BEHALF ARE YOU APPEARING IN THIS PROCEEDING?
15 A. I am appearing on behalf of Palmetto Energy Center, LLC ("Palmetto Energy"), a
16 subsidiary of Calpine Corporation ("Calpine").
17 Q. WHAT ARE YOUR RESPONSIBILITIES WITH REGARD TO THE
18 PALMETTO ENERGY PROJECT?
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CH2M HILL is responsible for the environmental permitting of the proposed facility.
This area of responsibility includes the preparation of the permit applications and
supporting documentation for all environmental and related permits that will be
required for the construction and operation of the facility. As the Principal Engineer
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on the project, I am responsible for directing and overseeing CH2M HILL's efforts in
this regard, and I am the primary interface between CH2M HILL and Calpine
Corporation. I also have responsibility for assisting Calpine with discussions and
negotiations with the appropriate State and Federal permitting agencies.
ARE YOU FAMILIAR WITH THE FACTS AND INFORMATION SET
FORTH IN PALMETTO ENERGY'S APPLICATION?
Yes. I was actively involved in the preparation of the Application. The Application
and the supporting documentation contained in the Application, accurately reflects the
work done by CH2M HILL, including our conclusions and recommendations.
WHAT IS THE PURPOSE OF YOUR TESTIMONY?
The purpose of my testimony is to support Palmetto Energy's Application for a
Certificate of Environmental Compatibility and Public Convenience and Necessity to
construct and operate a generating plant for the production of electric power and
energy in York County, near Fort Mill, South Carolina ("Palmetto Energy Facility")
and to answer any questions regarding environmental issues related to the facility. In
my testimony, I will present evidence regarding the potential impacts on water quality,
air quality and natural resources from the construction and operation of the Palmetto
Energy Facility, and demonstrate why these potential impacts will be minimal and not
adverse.
WHAT ARE YOUR CONCLUSIONS REGARDING THE PROPOSED
PALMETTO ENERGY FACILITY?
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on the project, 1 am responsible for directing and overseeing CH2M HILL's efforts in
this regard, and I am the primary interface between CH2M HILL and Calpine
Corporation. I also have responsibility for assisting Calpine with discussions and
negotiations with the appropriate State and Federal permitting agencies.
5 Q. ARE YOU FAMILIAR WITH THE FACTS AND INFORMATION SET
6 FORTH IN PALMETTO ENERGY'S APPLICATION?
7 A. Yes. I was actively involved in the preparation of the Application. The Application
and the supporting documentation contained in the Application, accurately reflects the
work done by CH2M HILL, including our conclusions and recommendations.
10 Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY?
11 A. The purpose of my testimony is to support Palmetto Energy's Application for a
12 Certificate of Environmental Compatibility and Public Convenience and Necessity to
13 construct and operate a generating plant for the production of electric power and
14 energy in York County, near Fort Mill, South Carolina ("Palmetto Energy Facility")
15 and to answer any questions regarding environmental issues related to the facility. In
16 my testimony, I will present evidence regarding the potential impacts on water quality,
17 air quality and natural resources from the construction and operation of the Palmetto
18 Energy Facility, and demonstrate why these potential impacts will be minimal and not
19 adverse.
20 Q. WHAT ARE YOUR CONCLUSIONS REGARDING THE PROPOSED
21 PALMETTO ENERGY FACILITY?
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1 A. I haveconcludedthat:
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From an environmentalstandpoint,the proposedPalmettoEnergyFacility will be
a state-of-the-artcombined-cyclecombustionturbinefacility;
Q the Palmetto Energy Facility will utilize clean-burning natural gas, which has
significantly lower emissions of carbon-based pollutants, as well as pollutants such
as sulfur dioxide, nitrogen oxides and other pollutants, than coal- or oil-fired
generation; the Palmetto Energy Facility also produces less pollutants per
megawatt-hour than other existing gas-fired facilities presently installed in South
Carolina due to the use of current technology and relative efficiencY of the
Palmetto Energy Facility - if the Palmetto Energy Facility displaces any existing
energy generation of a traditional nature (i.e., coal- or oil-fired generation), the
result will be less emissions;
the Palmetto Energy Facility's efficient use of river water in the plant cooling
system will not have any significant or adverse impact on the Catawba River -
Palmetto Energy will utilize advanced technology design practices to ensure that
aquatic species in the fiver will not be impacted by the water intake and discharge
systems;
the Palmetto Energy Facility's water withdrawal from the river will not have a
significant or adverse impact on the flow of water downstream of the Palmetto
Energy site;
1 A. I have concluded that:
~ From an environmental standpoint, the proposed Palmetto Energy Facility will be
a state-of-the-art combined-cycle combustion turbine facility;
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~ the Palmetto Energy Facility will utilize clean-burning natural gas, which has
significantly lower emissions of carbon-based pollutants, as well as pollutants such
as sulfur dioxide, nitrogen oxides and other pollutants, than coal- or oil-fired
generation; the Palmetto Energy Facility also produces less pollutants per
megawatt-hour than other existing gas-fired facilities presently installed in South
Carolina due to the use of current technology and relative efficiency of the
Palmetto Energy Facility — if the Palmetto Energy Facility displaces any existing
energy generation of a traditional nature (i.e., coal- or oil-fired generation), the
result will be less emissions;
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~ the Palmetto Energy Facility's efficient use of river water in the plant cooling
system will not have any significant or adverse impact on the Catawba River—
Palmetto Energy will utilize advanced technology design practices to ensure that
aquatic species in the river will not be impacted by the water intake and discharge
17 systems;
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~ the Palmetto Energy Facility's water withdrawal from the river will not have a
significant or adverse impact on the flow of water downstream of the Palmetto
Energy site;
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the designof the PalmettoEnergy Facility from an environmentalstandpointis
consistentwith the bestdesignpracticeandthe PalmettoEnergyFacility utilizes
what is acknowledgedby the South Carolina Department of Health and
EnvironmentalControl ("DHEC") andtheU.S. EnvironmentalProtectionAgency
("EPA") to bethebestachievablecontroltechnology("BACT") to ensureminimal
environmentalimpact;
anyenvironmentalimpactof thePalmettoEnergyFacility is justified considering
the availabletechnology,thenatureandeconomicsof otheralternativesandother
relevantissues- theproposedfacility is amongthe leastenvironmentally-intrusive
alternativesavailableto generatepower.;
the approval,constructionandoperationof the PalmettoEnergyFacility will not
significantly affect South Carolina's ability to site (from an environmental
standpoint)any additionalnew generatingfacilities that may be neededto meet
futurepowerneeds;
the Palmetto Energy Facility can be expected
environmentalpermitsto constructandoperate;
to receive the necessary
the PalmettoEnergyFacility will comply with all applicableenvironmentalrules
andregulations,andno environmentalstandardwill be compromised,threatened,
or exceededasaresultof its operation;
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~ the design of the Palmetto Energy Facility from an environmental standpoint is
consistent with the best design practice and the Palmetto Energy Facility utilizes
what is acknowledged by the South Carolina Department of Health and
Enviromnental Control ("DHEC") and the U.S. Environmental Protection Agency
("EPA") to be the best achievable control technology ("BACT**) to ensure minimal
environmental impact;
~ any environmental impact of the Palmetto Energy Facility is justified considering
the available technology, the nature and economics of other alternatives and other
relevant issues — the proposed facility is among the least environmentally-intrusive
alternatives available to generate power.;
~ the approval, construction and operation of the Palmetto Energy Facility will not
significantly affect South Carolina's ability to site (from an environmental
standpoint) any additional new generating facilities that may be needed to meet
future power needs;
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~ the Palmetto Energy Facility can be expected to receive the necessary
environmental permits to construct and operate;
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~ the Palmetto Energy Facility will comply with all applicable environmental rules
and regulations, and no environmental standard will be compromised, threatened,
or exceeded as a result of its operation;
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Palmetto Energy has, or is in the process of conducting the necessary
environmental studies to assess the impact of the Palmetto Energy Facility on the
environment; and
based on its operating track record, the environmental studies, and the design
efforts in this case, Calpine Corporation can be expected to design, construct and
operate the Palmetto Energy Facility while adequately protecting and minimizing
any effect on the environment.
Based on my knowledge of the project, review of the Application and testimony of
other witnesses, as well as my findings above, I have concluded that, in my opinion,
this Honorable Commission should grant Palmetto Energy's Application.
WHAT ARE YOUR RECOMMENDATIONS REGARDING THE PROPOSED
PALMETTO ENERGY FACILITY?
I recommend that this Honorable Commission grant Palmetto Energy a Certificate of
Environmental Compatibility and Public Convenience and Necessity to construct and
operate an electric generating plant in York County, South Carolina.
PLEASE DESCRIBE CALPINE'S ENVIRONMENTAL RECORD.
Calpine is committed to a long-term presence in York County for the entire period of
the facility's projected 30-year life. It is recognized that being a responsible corporate
citizen with a vision of protecting the environment is
welcomed into the community in which they will operate.
of developing and operating state-of-the-art power generating facilities that are among
absolutely vital to being
Calpine is in the business
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~ Palmetto Energy has, or is in the process of conducting the necessary
environmental studies to assess the impact of the Palmetto Energy Facility on the
environment; and
~ based on its operating track record, the environmental studies, and the design
efforts in this case, Calpine Corporation can be expected to design, construct and
operate the Palmetto Energy Facility while adequately protecting and minimizing
any effect on the environment.
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Based on my knowledge of the project, review of the Application and testimony of
other witnesses, as well as my findings above, I have concluded that, in my opinion,
this Honorable Commission should grant Palmetto Energy's Application.
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WHAT ARE YOUR RECOMMENDATIONS REGARDING THE PROPOSED
PALMETTO ENERGY FACILITY?
1 recommend that this Honorable Commission grant Palmetto Energy a Certificate of
Environmental Compatibility and Public Convenience and Necessity to construct and
operate an electric generating plant in York County, South Carolina.
16 Q. PLEASE DESCRIBE CALPINE'S ENVIRONMENTAL RECORD.
17 A. Calpine is committed to a long-term presence in York County for the entire period of
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the facility*s projected 30-year life. It is recognized that being a responsible corporate
citizen with a vision of protecting the environment is absolutely vital to being
welcomed into the community in which they will operate. Calpine is in the business
of developing and operating state-of-the-art power generating facilities that are among
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the cleanest in the nation. On a per kilowatt basis, the Palmetto Energy Facility will
emit less than 10 percent of what would be emitted fi'om a traditional coal- or oil-fired
generating facility. Calpine has and will continue to develop and operate its power
generating facilities in a manner that is environmentally sustainable on a long-term
basis.
PLEASE GENERALLY DESCRIBE THE PROPOSED PALMETTO ENERGY
FACILITY AND ITS LOCATION.
The proposed Palmetto Energy Facility is a combined-cycle, natural gas-fired
combustion turbine generating plant. The design of the Palmetto Energy Facility is
based on three natural gas-fired combustion turbine generators, a waste heat recovery
system, and a steam turbine generator that will generate up to 970 megawatts (MW) of
electric power. The Palmetto Energy Facility is to be located on an approximate 65-
acre tract of land in the Bradley Industrial Park, near Fort Mill, South Carolina in York
County.
ENVIRONMENTAL PROJECT DESIGN
PLEASE DESCRIBE WHAT STEPS HAVE BEEN TAKEN BY PALMETTO
ENERGY TO PROTECT THE ENVIRONMENT.
Palmetto Energy has gone to great lengths to design a highly efficient state-of-the-art
facility that will minimize its impact on the environment. As it has been designed, the
Palmetto Energy Facility will comply with all applicable state and federal
environmental regulations and statutes.
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the cleanest in the nation. On a per kilowatt basis, the Palmetto Energy Facility will
emit less than 10 percent of what would be emitted Irom a traditional coal- or oil-fired
generating facility. Calpine has and will continue to develop and operate its power
generating facilities in a manner that is environmentally sustainable on a long-term
basis.
6 Q. PLEASE GENERALLY DESCRIBE THE PROPOSED PALMETTO ENERGY
7 FACILITY AND ITS LOCATION.
8 A. The proposed Palmetto Energy Facility is a combined-cycle, natural gas-fired
9 combustion turbine generating plant. The design of the Palmetto Energy Facility is
10 based on three natural gas-fired combustion turbine generators, a waste heat recovery
11 system, and a steam turbine generator that will generate up to 970 megawatts (MW) of
12 electric power. The Palmetto Energy Facility is to be located on an approximate 65-
13 acre tract of land in the Bradley Industrial Park, near Fort Mill, South Carolina in York
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15 ENVIRONMENTAL PROJECT DESIGN
16 Q. PLEASE DESCRIBE WHAT STEPS HAVE BEEN TAKEN BY PALMETTO
17 ENERGY TO PROTECT THE ENVIRONMENT.
18 A. Palmetto Energy has gone to great lengths to design a highly efficient state-of-the-art
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facility that will minimize its impact on the environment. As it has been designed, the
Palmetto Energy Facility will comply with all applicable state and federal
environmental regulations and statutes.
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WILL THE PALMETTO ENERGY FACILITY COMPLY WITH ALL
APPLICABLE ENVIRONMENTAL RULES AND REGULATIONS?
The Palmetto Energy Center is being designed to comply with all applicable local,
State, and Federal environmental rules and regulations so that no environmental
standard will be compromised, threatened, or exceeded as a result of its operation.
Palmetto Energy has gone to great lengths to design a highly efficient state-of-the-art
facility that will minimize its impact on the environment through the use of advanced
technology and clean-burning natural gas. Palmetto Energy's Air Permit Application,
which was submitted in February of 2002, demonstrated through dispersion modeling
that the facility will have an insignificant impact on ambient air quality at all locations
and for all pollutants. Palmetto Energy's NPDES water and wastewater permit
application (submitted in February of 2002) demonstrates that the facility will not
have an adverse impact on the Catawba River as a result of water withdrawal or
wastewater discharge to the river during operation. Stormwater runoff during both
construction and operation will be controlled in accordance with all applicable
requirements. With respect to wetlands, threatened and endangered species, and
archaeological resources, Palmetto Energy has conducted extensive studies to identify
those areas or specific resources so that they can be avoided or otherwise mitigated in
accordance with the requirements of the appropriate agencies.
PLEASE DESCRIBE HOW PALMETTO ENERGY WILL CONTROL AIR
EMISSIONS FROM THE FACILITY.
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m. Palmetto Energy will use BACT to control emissions in accordance with state and
federal standards and requirements. Only clean burning pipeline natural gas will be
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1 Q. WILL THE PALMETTO ENERGY FACILITY COMPLY WITH ALL
2 APPLICABLE ENVIRONMENTAL RULES AND REGULATIONS?
3 A. The Palmetto Energy Center is being designed to comply with all applicable local,
4 State, and Federal environmental rules and regulations so that no environmental
5 standard will be compromised, threatened, or exceeded as a result of its operation.
6 Palmetto Energy has gone to great lengths to design a highly efficient state-of-the-art
7 facility that will minimize its impact on the environment through the use of advanced
8 technology and clean-burning natural gas. Palmetto Energy's Air Permit Application,
9 which was submitted in February of 2002, demonstrated through dispersion modeling
10 that the facility will have an insignificant impact on ambient air quality at all locations
11 and for all pollutants. Palmetto Energy's NPDES water and wastewater permit
12 application (submitted in February of 2002) demonstrates that the facility will not
13 have an adverse impact on the Catawba River as a result of water withdrawal or
14 wastewater discharge to the river during operation. Stormwater runoff during both
15 construction and operation will be controlled in accordance with all applicable
16 requirements. With respect to wetlands, threatened and endangered species, and
17 archaeological resources, Palmetto Energy has conducted extensive studies to identify
18 those areas or specific resources so that they can be avoided or otherwise mitigated in
19 accordance with the requirements of the appropriate agencies.
20 Q. PLEASE DESCRIBE HOW PALMETTO ENERGY WILL CONTROL AIR
21 EMISSIONS FROM THE FACILITY.
22 A. Palmetto Energy will use BACT to control emissions in accordance with state and
23 federal standards and requirements. Only clean burning pipeline natural gas will be
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burned in the combustion turbines. When compared to traditional oil- or coal-based
systems, the combustion turbines that will be used by Palmetto Energy are extremely
efficient in terms of their ability to generate large amounts of power with relatively
low emissions to the atmosphere. To reduce emissions even further, Palmetto Energy
will also install an advanced technology Selective Catalytic Reduction (SCR) emission
control system that will result in an additional 85 percent reduction in nitrogen oxide
(NOx) emissions from the facility. A continuous emission monitoring system will be
employed on the combustion turbines to continuously monitor NOx emissions and to
ensure compliance with the regulations. The primary source of emissions from this
facility will be three General Electric Model 7FB combustion turbines, each of which
will be equipped with a natural gas-fired heat recovery steam generator ("HRSG")
designed to efficiently recover waste heat for the purpose of generating additional
power. The emissions will be released from three 160-foot exhaust stacks, each of
which will serve an individual turbine and HRSG combination. Emissions from these
three stacks will include NOx (controlled by using state-of-the-art Dry Low-NOx
combustors in the turbines and an add-on SCR emission control device), SO2
(controlled by burning only natural gas, which is virtually free of sulfur), CO and
VOC (both will be minimized through the use of a highly efficient state-of-the-art
combustion turbine), and PM-10 (limited by using only clean-burning natural gas).
An additional source of emissions will be a small auxiliary boiler used to generate
steam during periods of startup and shutdown. This small boiler will generate less
than five percent of the emissions that will be generated by the combustion turbines
and HRSG's.
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burned in the combustion turbines. When compared to traditional oil- or coal-based
systems, the combustion turbines that will be used by Palmetto Energy are extremely
efficient in terms of their ability to generate large amounts of power with relatively
low emissions to the atmosphere. To reduce emissions even further, Palmetto Energy
will also install an advanced technology Selective Catalytic Reduction (SCR) emission
control system that will result in an additional 85 percent reduction in nitrogen oxide
(NOx) emissions from the facility. A continuous emission monitoring system will be
employed on the combustion turbines to continuously monitor NOx emissions and to
ensure compliance with the regulations. The primary source of emissions from this
facility will be three General Electric Model 7FB combustion turbines, each of which
will be equipped with a natural gas-fired heat recovery steam generator ("HRSG")
designed to efficiently recover waste heat for the purpose of generating additional
power. The emissions will be released from three 160-foot exhaust stacks, each of
which will serve an individual turbine and HRSG combination. Emissions from these
three stacks will include NOx (controlled by using state-of-the-art Dry Low-NOx
combustors in the turbines and an add-on SCR emission control device), SO&
(controlled by burning only natural gas, which is virtually free of sulfur), CO and
VOC (both will be minimized through the use of a highly efficient state-of-the-art
combustion turbine), and PM-10 (limited by using only clean-burning natural gas).
An additional source of emissions will be a small auxiliary boiler used to generate
steam during periods of startup and shutdown. This small boiler will generate less
than five percent of the emissions that will be generated by the combustion turbines
and HRSG's.
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HOW DOES THE AIR EMISSIONS CONTROL EQUIPMENT BEING
INSTALLED BY PALMETTO ENERGY COMPARE TO THE EQUIPMENT
BEING INSTALLED AT OTHER NEW GENERATING PLANTS IN THE
AREA?
The emission control equipment and methods of operation that will be utilized by
Palmetto Energy at the proposed facility will be consistent with or better than the
equipment and methods that are being used by other facilities throughout the country,
including several facilities that are presently being planned in South Carolina. The
emissions control equipment that will be used at the facility, as well as the inherent
design of the plant, will result in one of the lowest emitting power generating facilities
in the country.
WHAT IMPACT IS THE PALMETTO ENERGY FACILITY LIKELY TO
HAVE ON THE AIR QUALITY INTHE SURROUNDING AREA?
The proposed Palmetto Energy Facility is located in an area that is designated by
DHEC and EPA as being in attainment of all ambient air quality standards, including
ozone. The Palmetto Energy Facility has demonstrated in its Application for a Permit
to Construct and Operate Air Emissions Equipment that its predicted impacts on air
quality will be insignificant at all locations and for all pollutants. As such, there
should not be either a real or perceived threat to any ambient air quality standard, nor
should there be any adverse effects on health or welfare as a result of the operation of
the Palmetto Energy Facility. As a result of the insignificant nature of the projected
impacts, the permitting of this facility will not have any significant or adverse effect
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1 Q. HOW DOES THE AIR EMISSIONS CONTROL EQUIPMENT BEING
2 INSTALLED BY PALMETTO ENERGY COMPARE TO THE EQUIPMENT
3 BEING INSTALLED AT OTHER NEW GENERATING PLANTS IN THE
4 AREA?
5 A. The emission control equipment and methods of operation that will be utilized by
6 Palmetto Energy at the proposed facility will be consistent with or better than the
7 equipment and methods that are being used by other facilities throughout the country,
8 including several facilities that are presently being planned in South Carolina. The
9 emissions control equipment that will be used at the facility, as well as the inherent
10 design of the plant, will result in one of the lowest emitting power generating facilities
11 in the country.
12 Q. WHAT IMPACT IS THE PALMETTO ENERGY FACILITY LIKELY TO
13 HAVE ON THE AIR QUALITY IN THE SURROUNDING AREA?
14 A. The proposed Palmetto Energy Facility is located in an area that is designated by
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DHEC and EPA as being in attainment of all ambient air quality standards, including
ozone. The Palmetto Energy Facility has demonstrated in its Application for a Permit
to Construct and Operate Air Emissions Equipment that its predicted impacts on air
quality will be insignificant at all locations and for all pollutants. As such, there
should not be either a real or perceived threat to any ambient air quality standard, nor
should there be any adverse effects on health or welfare as a result of the operation of
the Palmetto Energy Facility. As a result of the insignificant nature of the projected
impacts, the permitting of this facility will not have any significant or adverse effect
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on the ability of others to construct industrial facilities in the region surrounding the
Palmetto Energy Facility.
WHAT STEPS HAS PALMETTO ENERGY TAKEN TO ENSURE THAT
WATER USE AND WASTEWATER DISCHARGES WILL COMPLY WITH
STATE AND FEDERAL REGULATIONS?
An integral part of Palmetto Energy Center's proposed facility is a mechanical draft
closed-cycle wet cooling system. Cooling water for the plant will be taken from the
Catawba River through a new intake structure, which will utilize a submerged wire
screen designed to comply with the cooling water intake standards under Section
316(b) of the Clean Water Act. The intake will use passive screen technology to
reduce both impingement and entrainment of aquatic species. The proposed intake
location is in a deep zone of the river to avoid shallow waters that could be potential
habitat for juvenile aquatic species. Prior to use in the cooling system, all incoming
river water will be passed through an onsite clarifier and filter to reduce the amount of
particulate matter present in the river water. Palmetto Energy Center's National
Pollutant Discharge Elimination System (NPDES) permit application provides
information on the water in the vicinity of the intake, a description of the selected
intake technology, data on the baseline biological condition of the source water, and
details on water treatment (i.e., clarification and filtration).. Variables that will
determine the amount of water use on a given day include ambient temperature,
relative humidity, plant load, and the number of times the cooling water can be
recycled before being discharged to the river. Based on the analysis of water samples
obtained from the Catawba River and the expected amount of recycling in the cooling
-11 -
on the ability of others to construct industrial facilities in the region surrounding the
Palmetto Energy Facility.
3 Q. WHAT STEPS HAS PALMETTO ENERGY TAKEN TO ENSURE THAT
WATER USE AND WASTEWATER DISCHARGES WILL COMPLY WITH
STATE AND FEDERAL REGULATIONS?
6 A. An integral part of Palmetto Energy Center's proposed facility is a mechanical draft
7 closed-cycle wet cooling system. Cooling water for the plant will be taken from the
8 Catawba River through a new intake structure, which will utilize a submerged wire
9 screen designed to comply with the cooling water intake standards under Section
10 316(b) of the Clean Water Act. The intake will use passive screen technology to
11 reduce both impingement and entrainment of aquatic species. The proposed intake
12 location is in a deep zone of the river to avoid shallow waters that could be potential
13 habitat for juvenile aquatic species. Prior to use in the cooling system, all incoming
14 river water will be passed through an onsite clarifier and filter to reduce the amount of
15 particulate matter present in the river water. Palmetto Energy Center's National
16 Pollutant Discharge Elimination System (NPDES) permit application provides
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information on the water in the vicinity of the intake, a description of the selected
intake technology, data on the baseline biological condition of the source water, and
details on water treatment (i.e., clarification and filtration).. Variables that will
determine the amount of water use on a given day include ambient temperature,
relative humidity, plant load, and the number of times the cooling water can be
recycled before being discharged to the river. Based on the analysis of water samples
obtained from the Catawba River and the expected amount of recycling in the cooling
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water system, the plant is expected to have a daily average water use requirement of
approximately 4.6 million gallons per day (MGD) during normal operation, and up to
9 MGD during conditions when maximum cooling is required and incoming water
conditions limit the amount of recycling in the system. Approximately 80 percent
of the cooling water will be evaporated to the atmosphere during the cooling process.
The remaining 20 percent (1 to 2 MGD) will be returned to the Catawba River.
Recycling of the water in the cooling system will result in an increase in the
concentration of naturally occurring metals and solids in Palmetto Energy Center's
wastewater discharge, This increase will be partially offset by Palmetto Energy's use
of clarification and filtration to remove particles from the incoming water prior to use
in the cooling system. This increase in concentration will be attributable to solely to
the evaporation of water during the cooling process and no additional treatment (other
than clarification and filtration of the incoming fiver water) will be performed before
being returned to the Catawba River. A submerged effluent diffuser will be used to
rapidly mix the discharge with the receiving stream.
WHAT HAS PALMETTO ENERGY DONE TO PROTECT WETLANDS AND
THREATENED & ENDANGERED SPECIES?
A comprehensive survey of the proposed Palmetto Energy Facility site has been
conducted by CH2M HILL biologists and endangered species specialists and they
have determined that there are no wetlands on the 65-acre project site where the plant
will be built. There are, however, some small wetland areas that may be traversed by
right of ways (ROWs) for water, wastewater, and electric transmission lines (electric
transmission line ROW to be provided by Duke Power). If any of these wetland areas
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water system, the plant is expected to have a daily average water use requirement of
approximately 4.6 million gallons per day (MGD) during normal operation, and up to
9 MGD during conditions when maximum cooling is required and incoming water
conditions limit the amount of recycling in the system. Approximately 80 percent
of the cooling water will be evaporated to the atmosphere during the cooling process.
The remaining 20 percent (I to 2 MGD) will be returned to the Catawba River.
Recycling of the water in the cooling system will result in an increase in the
concentration of naturally occurring metals and solids in Palmetto Energy Center's
wastewater discharge, This increase will be partially offset by Palmetto Energy's use
of clarification and filtration to remove particles from the incoming water prior to use
in the cooling system. This increase in concentration will be attributable to solely to
the evaporation of water during the cooling process and no additional treatment (other
than clarification and filtration of the incoming river water) will be performed before
being returned to the Catawba River. A submerged effluent diffuser will be used to
rapidly mix the discharge with the receiving stream.
16 Q. WHAT HAS PALMETTO ENERGY DONE TO PROTECT WETLANDS AND
17 THREATENED & ENDANGERED SPECIES?
18 A. A comprehensive survey of the proposed Palmetto Energy Facility site has been
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conducted by CH2M HILL biologists and endangered species specialists and they
have determined that there are no wetlands on the 65-acre project site where the plant
will be built. There are, however, some small wetland areas that may be traversed by
right of ways (ROWs) for water, wastewater, and electric transmission lines (electric
transmission line ROW to be provided by Duke Power). If any of these wetland areas
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will be impacted as a result of ROW construction, all such activity will be in
accordance with the requirements of the US Army Corps of Engineers and SC DHEC.
The threatened or endangered species evaluation of the area has indicated that there
are no threatened or endangered species within the project boundaries and that
construction of the facility is not likely to result in an adverse impact on areas of
potential habitat.
WHAT HAS PALMETTO ENERGY DONE TO PROTECT
ARCHAEOLOGICAL AND CULTURAL RESOURCES?
Palmetto Energy has completed a Phase I Archaeological and Cultural Resources
survey of the project site and the proposed ROWs and is currently in the process of
completing Phase II investigations of these areas. The purpose of these assessments is
to identify those resources that have the potential to be impacted by the development
or operation of the proposed facility. Once all resources are identified, appropriate
consideration can be given to all identified cultural and archaeological resources so
that they can be either avoided or their impact mitigated. Calpine is currently in
discussions with representatives of the Catawba Indian Nation and the South Carolina
State Historic Preservation Office (SHPO) to identify specific issues and resources of
concern.
WHAT HAS PALMETTO ENERGY DONE TO COMPLY WITH
REGULATIONS RELATED TO STORMWATER RUNOFF?
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A. The Palmetto Energy Center is being designed to control stormwater runoff in
accordance with all applicable State, Local, and Federal requirements. Stormwater
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will be impacted as a result of ROW construction, all such activity will be in
accordance with the requirements of the US Army Corps of Engineers and SC DHEC.
The threatened or endangered species evaluation of the area has indicated that there
are no threatened or endangered species within the project boundaries and that
construction of the facility is not likely to result in an adverse impact on areas of
potential habitat.
7 Q. WHAT HAS PALMETTO ENERGY DONE TO PROTECT
8 ARCHAEOLOGICAL AND CULTURAL RESOURCES?
9 A. Palmetto Energy has completed a Phase I Archaeological and Cultural Resources
10 survey of the project site and the proposed ROWs and is currently in the process of
11 completing Phase II investigations of these areas. The purpose of these assessments is
12 to identify those resources that have the potential to be impacted by the development
13 or operation of the proposed facility. Once all resources are identified, appropriate
14 consideration can be given to all identified cultural and archaeological resources so
15 that they can be either avoided or their impact mitigated. Calpine is currently in
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discussions with representatives of the Catawba Indian Nation and the South Carolina
State Historic Preservation Office (SHPO) to identify specific issues and resources of
18 concern.
19 Q.
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WHAT HAS PALMETTO ENERGY DONE TO COMPLY WITH
REGULATIONS RELATED TO STORMWATER RUNOFF?
21 A. The Palmetto Energy Center is being designed to control stormwater runoff in
22 accordance with all applicable State, Local, and Federal requirements. Stormwater
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permit applications and stormwater pollution prevention plans are currently being
prepared for both construction and operation of the facility. These plans demonstrate
that the facility is incorporating the appropriate stormwater detention basins and
oil/water separators to ensure that contaminated stormwater will not leave the site.
WHAT HAS PALMETTO ENERGY DONE TO REDUCE THE IMPACT ON
SOIL AND VEGETATION DURING CONSTRUCTION AND OPERATION
OF THE FACILITY?
The impact of the Palmetto Energy Facility during the construction phase will be
consistent with the impacts of similarly sized projects, and Palmetto Energy will
mitigate said impacts to the extent possible using all reasonable means available. This
will include the use of stormwater runoff controls and the minimization of fugitive
dust during dry conditions. During the construction phase, there will be areas where
vegetation and soil will be disturbed, including primary construction zones, material
laydown areas, and road access. The remainder of the site will remain in a reasonably
natural state. Best management practices will be implemented to control stormwater
runoff during construction. During operation, the impacts of the Palmetto Energy
Facility are not expected to be significant and, as such, there are not expected to be
any measurable impacts on soil or vegetation at any location surrounding the Palmetto
Energy Facility. All oil-containing equipment and tanks will have secondary
containment and facility personnel will be trained in accordance with the facility's
Spill Prevention Plan. It should be noted that, since the facility will utilize only
natural gas as its fuel, Palmetto Energy will not store or use a significant amount of
oil- or petroleum-based products on the site.
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permit applications and stormwater pollution prevention plans are currently being
prepared for both construction and operation of the facility. These plans demonstrate
that the facility is incorporating the appropriate stormwater detention basins and
oil/water separators to ensure that contaminated stormwater will not leave the site.
5 Q. WHAT HAS PALMETTO ENERGY DONE TO REDUCE THE IMPACT ON
SOIL AND VEGETATION DURING CONSTRUCTION AND OPERATION
OF THE FACILITY?
8 A. The impact of the Palmetto Energy Facility during the construction phase will be
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consistent with the impacts of similarly sized projects, and Palmetto Energy will
mitigate said impacts to the extent possible using all reasonable means available. This
will include the use of stormwater runoff controls and the minimization of fugitive
dust during dry conditions. During the construction phase, there will be areas where
vegetation and soil will be disturbed, including primary construction zones, material
laydown areas, and road access. The remainder of the site will remain in a reasonably
natural state. Best management practices will be implemented to control stormwater
runoff during construction. During operation, the impacts of the Palmetto Energy
Facility are not expected to be significant and, as such, there are not expected to be
any measurable impacts on soil or vegetation at any location surrounding the Palmetto
Energy Facility. All oil-containing equipment and tanks will have secondary
containment and facility personnel will be trained in accordance with the facility's
Spill Prevention Plan. It should be noted that, since the facility will utilize only
natural gas as its fuel, Palmetto Energy will not store or use a significant amount of
oil- or petroleum-based products on the site.
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WHAT WILL PALMETTO ENERGY DO TO PROTECT THE AESTHETICS
OF THE SURROUNDING AREA?
Palmetto Energy will comply with all pertinent Fort Mill and York County buffer and
landscape requirements. The Palmetto Energy Facility is being designed to preserve
the forested areas along the Catawba River (which borders the site to the south) so as
to limit line of site visibility of the fiver and from locations across the river.
ENVIRONMENTAL PERMITTING
WHAT TYPES OF ENVIRONMENTAL PERMITS ARE NORMALLY
REQUIRED FOR FACILITIES OF THIS TYPE?
Environmental permits for a generating facility of the type being proposed by
Palmetto Energy are normally required for air emissions, water use or withdrawal,
wastewater discharges, stormwater runoff, wetlands, and threatened and endangered
species, and several minor permits and approvals.
WHAT IS THE STATUS OF PALMETTO ENERGY'S AIR EMISSIONS
PERMIT?
Palmetto Energy has applied for a Permit to Construct and Operate Air Emissions
Equipment. This application was submitted in February of 2002 to DHEC. The
application will be undergoing internal agency review and DHEC is expected to issue
a final permit by the third quarter of 2002.
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1 Q. WHAT WILL PALMETTO ENERGY DO TO PROTECT THE AESTHETICS
2 OF THE SURROUNDING AREA?
3 A. Palmetto Energy will comply with all pertinent Fort Mill and York County buffer and
landscape requirements. The Palmetto Energy Facility is being designed to preserve
the forested areas along the Catawba River (which borders the site to the south) so as
to limit line of site visibility of the river and from locations across the river.
ENVIRONMENTAL PERMITTING
8 Q. WHAT TYPES OF ENVIRONMENTAL PERMITS ARE NORMALLY
9 REQUIRED FOR FACILITIES OF THIS TYPE?
10 A. Environmental permits for a generating facility of the type being proposed by
11 Palmetto Energy are normally required for air emissions, water use or withdrawal,
12 wastewater discharges, stormwater runoff, wetlands, and threatened and endangered
13 species, and several minor permits and approvals.
14 Q. WHAT IS THE STATUS OF PALMETTO ENERGY'S AIR EMISSIONS
15 PERMIT?
16 A. Palmetto Energy has applied for a Permit to Construct and Operate Air Emissions
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Equipment. This application was submitted in February of 2002 to DHEC. The
application will be undergoing internal agency review and DHEC is expected to issue
a final permit by the third quarter of 2002.
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IS PALMETTO ENERGY REQUIRED TO OBTAIN WATER SUPPLY
PERMITS?
Palmetto Energy will obtain authorization for the water intake structure as part of the
facility's NPDES permit, which was submitted in February of 2002 to DHEC.. The
cooling water intake system that will be used by Palmetto Energy will be considered a
cooling water intake structure and will be permitted under 40 CFR 125, Subpart I -
Requirements Applicable to Cooling Water Intake Structures for New Facilities under
Section 316(b) of the Clean Water Act. Certification that the proposed activities do
not violate the State water quality standards will be obtained during the permitting of
the water intake through the State's Section 401 Water Quality Certification process.
PLEASE DESCRIBE THE PROCESS UNDERTAKEN TO OBTAIN
APPROVAL FOR PALMETTO ENERGY'S WASTEWATER DISCHARGE
PLAN.
SC DHEC Bureau of Water staff were consulted to discuss the Palmetto Energy
Facility's discharge to the Catawba River. The principal wastewater stream will be
cooling tower blowdown. Other waste streams may be mixed with this discharge and
include demineralization regeneration wastes, steam cycle blowdown, and equipment
drains. HRSG discharge (boiler blowdown) will be routed to the cooling tower as a
source of make-up water. Process wastewater streams containing oil will be
segregated and routed to an on-site oil/water separator. Recycling of the cooling water
in the cooling system will result in an increase in the concentration of naturally
occurring metals and solids in Palmetto Energy Center's wastewater discharge. This
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I Q. IS PALMETTO ENERGY REQUIRED TO OBTAIN WATER SUPPLY
2 PERMITS?
3 A. Palmetto Energy will obtain authorization for the water intake structure as part of the
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facility's NPDES permit, which was submitted in February of 2002 to DHEC.. The
cooling water intake system that will be used by Palmetto Energy will be considered a
cooling water intake structure and will be permitted under 40 CFR 125, Subpart I—
Requirements Applicable to Cooling Water Intake Structures for New Facilities under
Section 316(b) of the Clean Water Act. Certification that the proposed activities do
not violate the State water quality standards will be obtained during the permitting of
the water intake through the State's Section 401 Water Quality Certification process.
11 Q. PLEASE DESCRIBE THE PROCESS UNDERTAKEN TO OBTAIN
12 APPROVAL FOR PALMETTO ENERGY'S WASTEWATER DISCHARGE
13 PLAN.
14 A. SC DHEC Bureau of Water staff were consulted to discuss the Palmetto Energy
15 Facility's discharge to the Catawba River. The principal wastewater stream will be
16 cooling tower blowdown. Other waste streams may be mixed with this discharge and
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include demineralization regeneration wastes, steam cycle blowdown, and equipment
drains. HRSG discharge (boiler blowdown) will be routed to the cooling tower as a
source of make-up water. Process wastewater streams containing oil will be
segregated and routed to an on-site oil/water separator. Recycling of the cooling water
in the cooling system will result in an increase in the concentration of naturally
occurring metals and solids in Palmetto Energy Center's wastewater discharge. This
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increase in concentration will be attributable solely to the evaporation of water during
the cooling process and no significant additional treatment of either the incoming river
water or the cooling water discharge will be required before being returned to the
Catawba River. A submerged effluent diffuser will be used to rapidly mix the
discharge with the receiving stream. A preliminary engineering report and NPDES
permit application have been prepared that includes an anti-degradation assessment,
mixing zone evaluation, and cooling water intake structure information. A
submerged, single port diffuser design was selected based on the use of EPA's
CORMIX model to provide effluent mixing in the river and to facilitate rapid mixing
of the discharge in the river. Modeling results show that the temperature difference
between the cooling water discharge and the fiver will be less than 2 ° F within 15 feet
of the diffuser for summer and winter conditions. The CORMIX model also predicts a
20- to 40-fold dilution of concentration for all constituents in the discharge within 100
feet of the diffuser.
PLEASE DESCRIBE THE STATUS OF THE STORMWATER
CONSTRUCTION AND OPERATING PERMITS.
Prior to the construction of the facility, Palmetto Energy will obtain an NPDES
Stormwater Construction Permit. This permit will be obtained at least 1 to 2 months
prior to commencement of construction. Prior to operation of the facility, Palmetto
Energy will also obtain an NPDES Stormwater Operating Permit. This permit will be
obtained at least 1 to 2 months prior to the commencement of "Commercial
Operation." Both of these permits will be issued by the DHEC.
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increase in concentration will be attributable solely to the evaporation of water during
the cooling process and no significant additional treatment of either the incoming river
water or the cooling water discharge will be required before being returned to the
Catawba River. A submerged effluent diffuser will be used to rapidly mix the
discharge with the receiving stream. A preliminary engineering report and NPDES
permit application have been prepared that includes an anti-degradation assessment,
mixing zone evaluation, and cooling water intake structure information. A
submerged, single port diffuser design was selected based on the use of EPA's
CORMIX model to provide effluent mixing in the river and to facilitate rapid mixing
of the discharge in the river. Modeling results show that the temperature difference
between the cooling water discharge and the river will be less than 2' within 15 feet
of the diffuser for summer and winter conditions. The CORMIX model also predicts a
20- to 40-fold dilution of concentration for all constituents in the discharge within 100
feet of the diffuser.
15 Q. PLEASE DESCRIBE THE STATUS OF THE STORMWATER
16 CONSTRUCTION AND OPERATING PERMITS.
17 A. Prior to the construction of the facility, Palmetto Energy will obtain an NPDES
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Stormwater Construction Permit. This permit will be obtained at least I to 2 months
prior to commencement of construction. Prior to operation of the facility, Palmetto
Energy will also obtain an NPDES Stormwater Operating Permit. This permit will be
obtained at least I to 2 months prior to the commencement of "Commercial
Operation.*'oth of these permits will be issued by the DHEC.
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WHAT OTHER PERMITS AND APPROVALS MAY BE REQUIRED OF
PALMETTO ENERGY?
Palmetto Energy may be required to obtain various additional minor permits and/or
approvals prior to the construction and/or operation of the plant. Some of these
permits and approvals are being deferred until such time as additional design
information is available. However, the application for and issuance of these permits or
approvals is routine and typical for facilities of the type being proposed by Palmetto
Energy. Examples of these minor permits include a Spill Prevention, Control, and
Countermeasure (SPCC) Plan (to be prepared prior to operation, approval not
required), Title V Operating Permit for air emissions (to be applied for within one year
following operation), Emergency Response and Risk Management Plan (to be
prepared prior to operation, approval not required), storage tank registration, water and
sewer connection approvals, FAA Stack Height Notification, and an erosion and
sedimentation control permit. Although not required by any permit or authorization,
Palmetto Energy will also obtain clearance letters from the U.S. Fish and Wildlife
Service and the South Carolina Heritage Trust regarding Endangered Species on or
near the site. A similar clearance letter from the South Carolina Historic Preservation
Office regarding the historic structures or artifacts on or near the site will also be
obtained.
ENVIRONMENTAL STUDIES
PLEASE DISCUSS THE ENVIRONMENTAL STUDIES THAT WERE
CONDUCTED.
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1 Q. WHAT OTHER PERMITS AND APPROVALS MAY BE REQUIRED OF
2 PALMETTO ENERGY?
3 A. Palmetto Energy may be required to obtain various additional minor permits and/or
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approvals prior to the construction and/or operation of the plant. Some of these
permits and approvals are being deferred until such time as additional design
information is available. However, the application for and issuance of these permits or
approvals is routine and typical for facilities of the type being proposed by Palmetto
Energy. Examples of these minor permits include a Spill Prevention, Control, and
Countermeasure (SPCC) Plan (to be prepared prior to operation, approval not
required), Title V Operating Permit for air emissions (to be applied for within one year
following operation), Emergency Response and Risk Management Plan (to be
prepared prior to operation, approval not required), storage tank registration, water and
sewer connection approvals, FAA Stack Height Notification, and an erosion and
sedimentation control permit. Although not required by any permit or authorization,
Palmetto Energy will also obtain clearance letters from the U.S. Fish and Wildlife
Service and the South Carolina Heritage Trust regarding Endangered Species on or
near the site. A similar clearance letter from the South Carolina Historic Preservation
Office regarding the historic structures or artifacts on or near the site will also be
obtained.
20 ENVIRONMENTAL STUDIES
21 Q. PLEASE DISCUSS THE ENVIRONMENTAL STUDIES THAT WERE
22 CONDUCTED.
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An integral component of the design and permitting of the Palmetto Energy Facility
has been extensive environmental studies and analyses that have focused on evaluating
the current environmental condition of the site, and assessing the impact of the facility
on the environment during construction and operation. The studies that have been
performed are described below.
PLEASE DESCRIBE THE PHASE I ENVIRONMENTAL SITE ASSESSMENT
THAT WAS CONDUCTED.
Calpine conducted a "Phase I Environmental Site Assessment" of the proposed facility
site in June of 2001 to determine if there were any pre-existing environmental
conditions that could adversely affect the development of the site for its intended
purpose. The results of this assessment indicate that the site itself is free of any known
environmental contamination or prior industrial usage that might have otherwise
impaired the property.
PLEASE DESCRIBE THE AMBIENT AIR QUALITY IMPACT ANALYSIS
THAT WAS PERFORMED.
A comprehensive air quality impact analysis was performed to support Palmetto
Energy's application for a permit to construct and operate air emissions equipment.
This impact analysis was based on the use of DHEC and EPA approved computer
models that simulate the dispersion of air pollutants in the atmosphere. The analysis
included an assessment of criteria pollutants (i.e., nitrogen oxides, sulfur dioxide,
particulate matter, carbon monoxide, and volatile organic compounds), as well as toxic
air pollutants such as ammonia, formaldehyde, and heavy metals. The dispersion
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1 A. An integral component of the design and permitting of the Palmetto Energy Facility
has been extensive environmental studies and analyses that have focused on evaluating
the current environmental condition of the site, and assessing the impact of the facility
on the environment during construction and operation. The studies that have been
performed are described below.
6 Q. PLEASE DESCRIBE THE PHASE I ENVIRONMENTAL SITE ASSESSMENT
7 THAT WAS CONDUCTED.
8 A. Calpine conducted a "Phase I Environmental Site Assessment" of the proposed facility
9 site in June of 2001 to determine if there were any pre-existing enviromnental
10 conditions that could adversely affect the development of the site for its intended
11 purpose. The results of this assessment indicate that the site itself is free of any known
12 environmental contamination or prior industrial usage that might have otherwise
13 impaired the property.
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Q. PLEASE DESCRIBE THE AMBIENT AIR QUALITY IMPACT ANALYSIS
THAT WAS PERFORMED.
A. A comprehensive air quality impact analysis was performed to support Palmetto
Energy's application for a permit to construct and operate air emissions equipment.
This impact analysis was based on the use of DHEC and EPA approved computer
models that simulate the dispersion of air pollutants in the atmosphere. The analysis
included an assessment of criteria pollutants (i.e., nitrogen oxides, sulfur dioxide,
particulate matter, carbon monoxide, and volatile organic compounds), as well as toxic
air pollutants such as ammonia, formaldehyde, and heavy metals. The dispersion
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modeling analysis resulted in the conclusion that the emissions from the facility will
not cause or contribute to a significant impact on ambient air quality at any location.
The analysis also showed that no ambient air quality standard or health-based
guideline would be threatened or exceeded as a result of the operation of the Palmetto
Energy Facility.
PLEASE DESCRIBE THE WATER USE AND WASTEWATER DISCHARGE
STUDY THAT WAS CONDUCTED.
Hourly flow records from the Catawba River at Highway 21 (approximately 6,000 feet
upstream of the intake site) were reviewed for the period October 1991 through
September 2001 to evaluate river flow pattems in the vicinity of the Palmetto Energy
site. Palmetto Energy's proposed maximum daily withdrawal rate is less than 0.4
percent of the annual average river flow, and less than 3.5 percent of the FERC
mandated minimum flow from Lake Wylie.
A biological baseline study was completed as part of the NPDES permit application to
identify aquatic species and life stages in the vicinity of the cooling water intake that
may be susceptible to impingement or entrainment in the water intake. The baseline
study indicated that there are no known occurrences of protected species of fish or
aquatic invertebrates in York County. There have been some observations of some
state and federally protected species of mussels in the Catawba River Basin, but none
have been observed in the Catawba River between Wylie Dam and Fishing Creek
Reservoir. There are other aquatic species of concern in the general area, but none are
listed as threatened or endangered. These include a snail (Gravel Elimia) and a fish
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modeling analysis resulted in the conclusion that the emissions trom the facility will
not cause or contribute to a significant impact on ambient air quality at any location.
The analysis also showed that no ambient air quality standard or health-based
guideline would be threatened or exceeded as a result of the operation of the Palmetto
Energy Facility.
Q. PLEASE DESCRIBE THE WATER USE AND WASTEWATER DISCHARGE
STUDY THAT WAS CONDUCTED.
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Hourly flow records from the Catawba River at Highway 21 (approximately 6,000 feet
upstream of the intake site) were reviewed for the period October 1991 through
September 2001 to evaluate river flow patterns in the vicinity of the Palmetto Energy
site. Palmetto Energy's proposed maximum daily withdrawal rate is less than 0.4
percent of the annual average river flow, and less than 3.5 percent of the FERC
mandated minimum flow from Lake Wylie.
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A biological baseline study was completed as part of the NPDES permit application to
identify aquatic species and life stages in the vicinity of the cooling water intake that
may be susceptible to impingement or entrainment in the water intake. The baseline
study indicated that there are no known occurrences of protected species of fish or
aquatic invertebrates in York County. There have been some observations of some
state and federally protected species of mussels in the Catawba River Basin, but none
have been observed in the Catawba River between Wylie Dam and Fishing Creek
Reservoir. There are other aquatic species of concern in the general area, but none are
listed as threatened or endangered. These include a snail (Gravel Elimia) and a fish
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(CarolinaDarter), but neitherhavebeen found in the main channelof the Catawba
River and their habitats are not likely to be found in deep pools such as where
PalmettoEnergy's intake structurewill be located. There is also an aquaticplant
speciesof concern(i.e., it is not threatenedor endangered),namelythe ShoalsSpider
Lily. However, the lily primarily exists in shallow rocky shoals some10 miles
downstreamof the project site. The ShoalsSpiderLily doesnot occur in deeppool
habitats.
An anti-degradationassessmentthat includeda dischargealternativesanalysisand a
demonstrationthatthe dischargewill accommodateeconomicandsocialdevelopment
is included in the NPDES permit application for the Palmetto Energy Center.
Alternativesreviewed included an NPDES permitted discharge,reuseand recycle,
relocationof theproposeddischargelocation,connectionto areawastewatertreatment
plants,landapplication,andprocessdesignalternatives.A closed-cyclesystemwith a
high degreeof recycle dischargingthrough an engineereddiffuser in the Catawba
River wasdeterminedto be the most technicallyandeconomicallyviablealternative.
The EPA CORMIX model was used to design a submergeddischargediffuser to
provide rapid mixing of the dischargein the river. Modeling resultsshow that the
temperaturedifferencebetweenthe cooling waterdischargeandthefiver will be less
than 2° F within 15 feet of the diffuser for summer and winter conditions. The
CORMIX model also predicts a 20- to 40-fold dilution of concentration for all
constituents in the discharge within 100 feet of the diffuser.
Q. PLEASE DESCRIBE PALMETTO ENERGY'S WETLANDS SURVEY.
-21 -
(Carolina Darter), but neither have been found in the main channel of the Catawba
River and their habitats are not likely to be found in deep pools such as where
Palmetto Energy's intake structure will be located. There is also an aquatic plant
species of concern (i.e., it is not threatened or endangered), namely the Shoals Spider
Lily. However, the lily primarily exists in shallow rocky shoals some 10 miles
downstream of the project site. The Shoals Spider Lily does not occur in deep pool
habitats.
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An anti-degradation assessment that included a discharge alternatives analysis and a
demonstration that the discharge will accommodate economic and social development
is included in the NPDES permit application for the Palmetto Energy Center.
Alternatives reviewed included an NPDES permitted discharge, reuse and recycle,
relocation of the proposed discharge location, connection to area wastewater treatment
plants, land application, and process design alternatives. A closed-cycle system with a
high degree of recycle discharging through an engineered diffuser in the Catawba
River was determined to be the most technically and economically viable alternative.
The EPA CORMIX model was used to design a submerged discharge diffuser to
provide rapid mixing of the discharge in the river. Modeling results show that the
temperature difference between the cooling water discharge and the river will be less
than 2' within 15 feet of the diffuser for summer and winter conditions. The
CORMIX model also predicts a 20- to 40-fold dilution of concentration for all
constituents in the discharge within 100 feet of the diffuser.
22 Q. PLEASE DESCRIBE PALMETTO ENERGY'S WETLANDS SURVEY.
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A comprehensiveonsite wetlandsinvestigationof the property was conductedby
experiencedwetlandsbiologiststo determineif thereareanywetlandsor watersof the
Unites Stateson the project site, or on areasthat will be usedasROWs for water,
wastewater,or electrictransmissionlines. Theresultsof this investigationconcluded
that the main 65-acreplant sitehad noneof the threecharacteristicsof jurisdictional
wetlands:hydric soils, positive indicatorsof wetland hydrology, predominanceof
hydrophyticvegetation. Therefore,nojurisdictional wetlandsarepresenton themain
65-acresite. Two creeksmeetingthedefinition of"other watersof theUnited States"
wereidentified on the site. An intermittent streamwas identifiedon the easternedge
of the sitethat is approximately10-20feetin width with waterpresentonly within the
lowestportions of the drainage.An intermittentstreamwasobservedon the western
edgeof the site thatis approximately5-10feetin width, highly incised,with no water
presentattime of survey.
Somewetlandshavebeenidentified on proposedROWs that will be usedfor water
and wastewaterpipelines. The identified wetlandsare not extensiveand Palmetto
Energywill takethenecessarystepsto avoidor minimize impactsto wetlands. Any
wetland impactsassociatedwith the water and wastewaterpipeline ROWs will be
mitigatedin accordancewith therequirementsof theCOEandSCDHEC. Theelectric
transmissionline ROWs between the project site and the Duke Power 500 kV
transmissionlines to the north of the project site will be constructed,owned,and
operatedby Duke Power. However, wetland surveysconductedon the ROW
proposedby DukePowerindicatethatonly limited wetlandsarepresentandthesecan
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1 A. A comprehensive onsite wetlands investigation of the property was conducted by
2 experienced wetlands biologists to determine if there are any wetlands or waters of the
3 Unites States on the project site, or on areas that will be used as ROWs for water,
4 wastewater, or electric transmission lines. The results of this investigation concluded
5 that the main 65-acre plant site had none of the three characteristics of jurisdictional
6 wetlands: hydric soils, positive indicators of wetland hydrology, predominance of
7 hydrophytic vegetation. Therefore, no jurisdictional wetlands are present on the main
8 65-acre site. Two creeks meeting the definition of "other waters of the United States"
9 were identified on the site. An intermittent stream was identified on the eastern edge
10 of the site that is approximately 10-20 feet in width with water present only within the
11 lowest portions of the drainage. An intermittent stream was observed on the western
12 edge of the site that is approximately 5-10 feet in width, highly incised, with no water
13 present at time of survey.
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Some wetlands have been identified on proposed ROWs that will be used for water
and wastewater pipelines. The identified wetlands are not extensive and Palmetto
Energy will take the necessary steps to avoid or minimize impacts to wetlands, Any
wetland impacts associated with the water and wastewater pipeline ROWs will be
mitigated in accordance with the requirements of the COE and SC DHEC. The electric
transmission line ROWs between the project site and the Duke Power 500 kV
transmission lines to the north of the project site will be constructed, owned„and
operated by Duke Power. However, wetland surveys conducted on the ROW
proposed by Duke Power indicate that only limited wetlands are present and these can
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either be avoided
requirements.
or easily mitigated in accordance with COE and DHEC
PLEASE DESCRIBE THE THREATENED AND ENDANGERED SPECIES
SURVEY CONDUCTED ON THE SITE.
The threatened and endangered species evaluation of the project site included a
literature search and an onsite survey. The literature search included a review of the
U.S. Fish and Wildlife Service (USFWS) and the South Carolina Heritage Trust
(SCHT) databases for potential and known locations of protected species and their
habitats. The USFWS and SCHT databases reported occurrences of some rare,
threatened, and endangered (RTE) species in the general vicinity of the project site.
An on-site survey of the project site and associated ROWs was conducted in the fall of
2001 and the winter of 2002 by experienced biologists to determine if there was any
evidence of these RTE species or their habitat. The results of the onsite survey did not
indicate the presence of any protected species within the proposed site boundaries and
additional surveys will be conducted during the upcoming growing season. Although
potential habitat for some of the identified species could potentially exist within the
project boundaries, the onsite survey indicated that the project site is only marginally
to poorly suited as habitat for these species. Therefore, it is unlikely that there will be
any adverse impacts to any of these species as a result of the development of the
Palmetto Energy Center facility. If any rare, threatened, or endangered species are
observed to be present on the site, they will either be avoided or their impacts will be
mitigated in accordance with the requirements of the COE, USFWS, and SCHT.
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either be avoided or easily mitigated in accordance with COE and DHEC
requirements.
3 Q. PLEASE DESCRIBE THE THREATENED AND ENDANGERED SPECIES
4 SURVEY CONDUCTED ON THE SITE.
5 A. The threatened and endangered species evaluation of the project site included a
6 literature search and an onsite survey. The literature search included a review of the
7 U.S. Fish and Wildlife Service (USFWS) and the South Carolina Heritage Trust
8 (SCHT) databases for potential and known locations of protected species and their
9 habitats. The USFWS and SCHT databases reported occurrences of some rare,
10 threatened, and endangered (RTE) species in the general vicinity of the project site.
11 An on-site survey of the project site and associated ROWs was conducted in the fall of
12 2001 and the winter of 2002 by experienced biologists to determine if there was any
13 evidence of these RTE species or their habitat. The results of the onsite survey did not
14 indicate the presence of any protected species within the proposed site boundaries and
15 additional surveys will be conducted during the upcoming growing season. Although
16 potential habitat for some of the identified species could potentially exist within the
17 project boundaries, the onsite survey indicated that the project site is only marginally
18 to poorly suited as habitat for these species. Therefore, it is unlikely that there will be
19 any adverse impacts to any of these species as a result of the development of the
20 Palmetto Energy Center facility. If any rare, threatened, or endangered species are
21 observed to be present on the site, they will either be avoided or their impacts will be
22 mitigated in accordance with the requirements of the COE, USFWS, and SCHT.
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PLEASE DESCRIBE THE ARCHAEOLOGICAL AND CULTURAL
RESOURCES ASSESSMENT THAT WAS PERFORMED.
A Phase I archaeological and cultural resource database survey of the proposed 65-
acre Palmetto Energy project site and surrounding area was performed in December of
2001. The background research indicated that there were no previously recorded
archaeological sites on the 65-acre project site, although a number of previously
recorded sites, including several that are eligible for the National Historic Register, are
present within a 1-mile radius of the project site. Some of these sites are associated
with former settlements that were occupied or used by Catawba Nation Indians over
two centuries ago. Given that the project will require the use of additional land for
ROWs for the conveyance of water, wastewater, and electricity to and from the project
site, these additional sites are presently being evaluated (including Phase II
archaeological testing) to ascertain if they will be impacted. The results of the Phase II
archaeological testing has identified one new potential archaeological site on the
southern boundary of the 65-acre project site, and confirmed the presence of a former
Catawba Nation Indian village in the vicinity of proposed ROW for water and
wastewater pipelines. The development of the proposed Palmetto Energy Facility will
include appropriate consideration of all identified cultural and archaeological
resources so that they can either be avoided or their impact appropriately mitigated.
Calpine is currently in discussions with representatives of the Catawba Indian Nation
and SC SHPO to identify and confirm the locations of any resources of concern, and
to determine any specific issues, concerns, or requirements that those organizations
may have with regard to the mitigation of impacts in these areas.
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1 Q. PLEASE DESCRIBE THE ARCHAEOLOGICAL AND CULTURAL
2 RESOURCES ASSESSMENT THAT WAS PERFORMED.
3 A. A Phase I archaeological and cultural resource database survey of the proposed 65-
4 acre Palmetto Energy project site and surrounding area was performed in December of
5 2001. The background research indicated that there were no previously recorded
6 archaeological sites on the 65-acre project site, although a number of previously
7 recorded sites, including several that are eligible for the National Historic Register, are
8 present within a I-mile radius of the project site. Some of these sites are associated
9 with former settlements that were occupied or used by Catawba Nation Indians over
10 two centuries ago. Given that the project will require the use of additional land for
11 ROWs for the conveyance of water, wastewater, and electricity to and from the project
12 site, these additional sites are presently being evaluated (including Phase II
13 archaeological testing) to ascertain if they will be impacted. The results of the Phase II
14 archaeological testing has identified one new potential archaeological site on the
15 southern boundary of the 65-acre project site, and confirmed the presence of a former
16 Catawba Nation Indian village in the vicinity of proposed ROW for water and
17 wastewater pipelines. The development of the proposed Palmetto Energy Facility will
18 include appropriate consideration of all identified cultural and archaeological
19 resources so that they can either be avoided or their impact appropriately mitigated.
20 Calpine is currently in discussions with representatives of the Catawba Indian Nation
21 and SC SHPO to identify and confirm the locations of any resources of concern, and
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to determine any specific issues, concern, or requirements that those organizations
may have with regard to the mitigation of impacts in these areas.
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HAS PALMETTO ENERGY CONDUCTED AN ASSESSMENT OF THE
IMPACT OF PLANT OPERATION ON REGIONAL VISIBILITY?
Palmetto Energy has, in accordance with the requirements set forth by EPA and
DHEC, conducted an assessment of the impact on regional visibility, most notably in
the Class I areas in North Carolina. The purpose of this assessment was to
demonstrate that the operation of the Palmetto Energy Facility would not cause or
contribute to the degradation of visibility in these pristine protected areas. The
analyses conducted have demonstrated that no such degradation will occur. In the
area immediately surrounding the plant, local visibility is not expected to be an issue
since the facility will burn only clean natural gas, which will result in a virtually
invisible exhaust from the combustion turbines and the auxiliary boiler proposed by
Palmetto Energy. The cooling towers that will be used by Palmetto Energy can be
expected to generate, during certain times of the year, visible plumes of water vapor.
These water vapor plumes are most likely to occur during relatively cold, moist
conditions when the condensation of water vapor is most favorable.
ELECTRICAL TRANSMISSION LINES
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Q. PLEASE DESCRIBE THE ELECTRICAL INTERCONNECTION BETWEEN
THE PALMETTO ENERGY FACILITY AND THE DUKE POWER
19 TRANSMISSION SYSTEM.
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A° Duke Power will provide all electrical transmissions lines between Duke's 500 kV
transmission lines and a substation that will be located on Palmetto Energy's 65-acre
project site. Duke Power will construct, own, and operate the transmission lines and
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1 Q. HAS PALMETTO ENERGY CONDUCTED AN ASSESSMENT OF THE
2 IMPACT OF PLANT OPERATION ON REGIONAL VISIBILITY?
3 A. Palmetto Energy has, in accordance with the requirements set forth by EPA and
4 DHEC, conducted an assessment of the impact on regional visibility, most notably in
5 the Class I areas in North Carolina. The purpose of this assessment was to
6 demonstrate that the operation of the Palmetto Energy Facility would not cause or
7 contribute to the degradation of visibility in these pristine protected areas. The
8 analyses conducted have demonstrated that no such degradation will occur. In the
9 area immediately surrounding the plant, local visibility is not expected to be an issue
10 since the facility will burn only clean natural gas, which will result in a virtually
ll invisible exhaust from the combustion turbines and the auxiliary boiler proposed by
12 Palmetto Energy. The cooling towers that will be used by Palmetto Energy can be
13 expected to generate, during certain times of the year, visible plumes of water vapor.
14 These water vapor plumes are most likely to occur during relatively cold, moist
15 conditions when the condensation of water vapor is most favorable.
16 ELECTRICAL TRANSMISSION LINES
17 Q. PLEASE DESCRIBE THE ELECTRICAL INTERCONNECTION BETWEEN
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THE PALMETTO ENERGY FACILITY AND THE DUKE POWER
TRANSMISSION SYSTEM.
20 A. Duke Power will provide all electrical transmissions lines between Duke's 500 kV
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transmission lines and a substation that will be located on Palmetto Energy's 65-acre
project site. Duke Power will construct, own, and operate the transmission lines and
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will be responsible for the acquisition and management of the necessary ROW on
which these lines will be built. The lines are expected to traverse Banks Street at the
north end of the 65-acre project site, run parallel to the west side of Banks Street up to
the 500 kV lines, approximately 4000 ft to the north.
IS THE PROPOSED FACILITY'S PROBABLE IMPACT ON THE
ENVIRONMENT JUSTIFIED?
Yes. The proposed Palmetto Energy Facility will be constructed using the best
available technology to protect the environment, and will provide significant
environmental advantages over other generating resource options.
DOES THIS CONCLUDE YOUR TESTIMONY?
A. Yes.
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will be responsible for the acquisition and management of the necessary ROW on
which these lines will be built. The lines are expected to traverse Banks Street at the
north end of the 65-acre project site„run parallel to the west side of Banks Street up to
the 500 kV lines, approximately 4000 tt to the north.
5 Q. IS THE PROPOSED FACILITY'S PROBABLE IMPACT ON THE
6 ENVIRONMENT JUSTIFIED?
7 A. Yes. The proposed Palmetto Energy Facility will be constructed using the best
available technology to protect the environment, and will provide significant
environmental advantages over other generating resource options.
10 Q. DOES THIS CONCLUDE YOUR TESTIMONY?
11 A. Yes.
12
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STATEOF SOUTHCAROLhNA
BEFORETHE PUBLIC SERVICECOMMISSION
DocketNo. 2001-507-E
In Re: Applicationof Palmetto Energy )
Center, LLC for Certificate of )
Environmental Compatibility and )
Public Convenience and Necessity )
to Construct a Major Utility Facility )
)
DIRECT TESTIMONY
OF
JOHN E. NILAND
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PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
My name is John E. Niland. My business address is Calpine Corporation The Pilot
House 2 nd Floor, Boston, Massachusetts, 02011.
BY WHOM ARE YOU EMPLOYED AND IN WHAT CAPACITY?
I am employed by Calpine Corporation, as a Director of Project Development and I
am the Project Manager for Palmetto Energy Center, LLC ("Palmetto Energy").
PLEASE DESCRIBE YOUR
PROFESSIONAL EXPERIENCE.
EDUCATIONAL BACKGROUND AND
I earned a Bachelor of Science
University in 1981.
generation industry.
in Mechanical Engineering from Northeastern
I have over twenty-two years of experience in the power
I am a licensed Professional Engineer in the states of Rhode
Island and Maine. At Calpine, I am Director of Project Development and have
responsibility for engineering, permitting and project development activities
associated with the sitting, construction and operation of power generation facilities
STATE OF SOUTH CAROLINA
BEFORE THE PUBLIC SERVICE COMMISSION
Docket No. 2001-507-E
In Re: Application of Palmetto Energy )Center, LLC for Certificate of )Environmental Compatibility and )Public Convenience and Necessity )to Construct a Major Utility Facility )
)
DIRECT TESTIMONYOF
JOHN E. NILAND
1 Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
2 A. My name is John E. Niland. My business address is Calpine Corporation The Pilot
House 2" Floor, Boston, Massachusetts, 02011.
4 Q. BY WHOM ARE YOU EMPLOYED AND IN WHAT CAPACITY?
5 A. I am employed by Calpine Corporation, as a Director of Project Development and I
6 am the Project Manager for Palmetto Energy Center, LLC ("Palmetto Energy").
7 Q. PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND AND
8 PROFESSIONAL EXPERIENCE.
9 A. I earned a Bachelor of Science in Mechanical Engineering from Northeastern
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University in 1981. I have over twenty-two years of experience in the power
generation industry. I am a licensed Professional Engineer in the states of Rhode
Island and Maine. At Calpine, I am Director of Project Development and have
responsibility for engineering, permitting and project development activities
associated with the sitting, construction and operation of power generation facilities
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in the eastem United States. Prior to joining Calpine two and a half years ago, I
worked as a project engineer and as manager/director for a large engineering and
construction company responsible for the construction of a variety power generation
facilities. I also worked in business development and marketing for the power
industry.
ON WHOSE BEHALF ARE YOU APPEARING IN THIS PROCEEDING?
I am appearing on behalf of Calpine Corporation and Palmetto Energy.
PLEASE DESCRIBE CALPINE'S EXPIERENCE IN SOUTH CAROLINA?
Calpine Corporation currently owns two other power facilities in the State of South
Carolina, the Broad River Energy Center in Gaffney and the Columbia Energy Center
located in Calhoun County, South Carolina. The Broad River facility is a peaking
facility with electrical interconnect with Duke Power and its output under contract
with Carolina Power and Light Company. Columbia Energy (currently under
construction) is a combined cycle plant with cogeneration capabilities that will sell
steam to Carolina Eastman at its manufacturing plant in Calhoun County and have the
ability to sell electrical power on the wholesale market. Palmetto Energy represents
the third power plant proposed to be owned and operated by Calpine Corporation in
the State of South Carolina. The combination of these three plants represents a direct
investment of over $1.2 billion dollars in South Carolina.
WHAT ARE YOUR RESPONSIBILITIES WITH REGARD TO THE
PALMETTO ENERGY PROJECT?
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in the eastern United States. Prior to joining Calpine two and a half years ago, I
worked as a project engineer and as manager(director for a large engineering and
construction company responsible for the construction of a variety power generation
facilities. I also worked in business development and marketing for the power
industry.
6 Q. ON WHOSE BEHALF ARE YOU APPEARING IN THIS PROCEEDING?
7 A. I am appearing on behalf of Calpine Corporation and Palmetto Energy .
8 Q. PLEASE DESCRIBE CALPINE'S EXPIERENCE IN SOUTH CAROLINA?
9 A. Calpine Corporation currently owns two other power facilities in the State of South
10 Carolina, the Broad River Energy Center in Gaffney and the Columbia Energy Center
11 located in Calhoun County, South Carolina. The Broad River facility is a peaking
12 facility with electrical interconnect with Duke Power and its output under contract
l
13 with Carolina Power and Light Company. Columbia Energy (currently under
14 construction) is a combined cycle plant with cogeneration capabilities that will sell
(
steam to Carolina Eastman at its manufacturing plant in Calhoun County and have the
16 ability to sell electrical power on the wholesale market. Palmetto Energy represents
17 the third power plant proposed to be owned and operated by Calpine Corporation in
18 the State of South Carolina. The combination of these three plants represents a direct
19 investment of over $ 1.2 billion dollars in South Carolina.
20 Q. WHAT ARE YOUR RESPONSIBILITIES WITH REGARD TO THE
21 PALMETTO ENERGY PROJECT?
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As the Director of Project Development, I am responsible for managing all aspects
associated with the development of the Palmetto Energy project. My responsibilities
include, among others, overall project schedule for permitting, design and
construction, plant design and configuration, land acquisition, coordination of all
permitting activities, local tax agreements, electrical interconnection, natural gas
interconnection and transportation agreements, and project financing.
ARE YOU FAMILIAR WITH THE FACTS AND INFORMATION SET
FORTH IN PALMETTO ENERGY CENTER'S APPLICATION?
Yes. I was actively involved in the preparation of the Application.
WHAT IS THE PURPOSE OF YOUR TESTIMONY?
The purpose of my testimony is to support Palmetto Energy's Application for a
Certificate of Environmental Compatibility and Public Convenience and Necessity to
construct and operate a generating plant for the production of electric power and
energy in York County, South Carolina and to answer any questions regarding the
facility. In my testimony, I will summarize Palmetto Energy's Application, describe
the team of professionals involved in our project and generally describe the design,
construction and operation of the PEC generating facility (the "Facility").
WHAT ARE YOUR CONCLUSIONS REGARDING THE PROPOSED
PALMETTO ENERGY ?
Based upon my review of the Application and the direct testimony of our team of
experts, as well as my own knowledge of the project, I have concluded that:
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1 A. As the Director of Project Development, I am responsible for managing all aspects
associated with the development of the Palmetto Energy project. My responsibilities
include, among others, overall project schedule for permitting, design and
construction, plant design and configuration, land acquisition, coordination of all
permitting activities, local tax agreements, electrical interconnection, natural gas
interconnection and transportation agreements, and project financing.
7 Q. ARE YOU FAMILIAR WITH THE FACTS AND INFORMATION SET
8 FORTH IN PALMETTO ENERGY CENTER'S APPLICATION?
9 A. Yes. I was actively involved in the preparation of the Application.
10 Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY?
11 A. The purpose of my testimony is to support Palmetto Energy's Application for a
12 Certificate of Environmental Compatibility and Public Convenience and Necessity to
13 construct and operate a generating plant for the production of electric power and
14 energy in York County, South Carolina and to answer any questions regarding the
15 facility. In my testimony, I will summarize Palmetto Energy 's Application, describe
16 the team of professionals involved in our project and generally describe the design,
17 construction and operation of the PEC generating facility (the "Facility").
18 Q. WHAT ARE YOUR CONCLUSIONS REGARDING THE PROPOSED
19 PALMETTO ENERGY?
20 A. Based upon my review of the Application and the direct testimony of our team of
21 experts, as well as my own knowledge of the project, I have concluded that:
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Calpine and its team of professionals has the capability and expertise to
properly design, construct and operate the proposed PEC as a merchant plant
in York County, South Carolina;
Palmetto Energy is a state-of-the-art facility that has been designed to
generate electrical energy in a highly efficient manner, while maintaining the
reliability and integrity of the regional electrical transmission system and
enhancing and serving the interests of system economy and reliability.
Combined cycle technology is the most efficient means by which to generate
electricity using natural gas. The Facility will employ the Best Available
Control Technology (BACT) to reduce its air emission to the lowest feasible
levels;
environmental impacts created by Palmetto Energy (such as water, air quality
and natural resources) will be minimal and not adverse and comply with all
environmental rules and regulations; environmental impacts were fully
evaluated, considering the state of available technology and the nature and
economics of various alternatives.
the PEC site is located in an industrial park for which siting a power plant is a
permitted use. The local community has been informed of the plans for the
plant and community leaders have openly accepted and support the project;
there is a need for new combined-cycle merchant facilities to meet anticipated
electrical demands in South Carolina and the region, to increase regional
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+ Calpine and its team of professionals has the capability and expertise to
properly design, construct and operate the proposed PEC as a merchant plant
in York County, South Carolina;
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+ Palmetto Energy is a state-of-the-art facility that has been designed to
generate electrical energy in a highly efficient manner, while maintaining the
reliability and integrity of the regional electrical transmission system and
enhancing and serving the interests of system economy and reliability.
Combined cycle technology is the most efficient means by which to generate
electricity using natural gas. The Facility will employ the Best Available
Control Technology (BACT) to reduce its air emission to the lowest feasible
levels;
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environmental impacts created by Palmetto Energy (such as water, air quality
and natural resources) will be minimal and not adverse and comply with all
environmental rules and regulations; environmental impacts were fully
evaluated, considering the state of available technology and the nature and
economics ofvarious alternatives.
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+ the PEC site is located in an industrial park for which siting a power plant is a
permitted use. The local community has been informed of the plans for the
plant and community leaders have openly accepted and support the project;
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+ there is a need for new combined-cycle merchant facilities to meet anticipated
electrical demands in South Carolina and the region, to increase regional
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reserve margins, to provide for more power supply diversity, and to create a
more vigorous and competitive wholesale market for power and energy ;
all of the business risk and costs associated with Palmetto Energy will be
bome by Calpine's investors, and not by South Carolina or its residents;
Palmetto Energy will provide significant non-energy-related
benefits to the State of South Carolina and to York County;
economic
there will be no negative impacts to South Carolina residents arising from
Palmetto Energy's use of the electric transmission system or natural gas
pipeline system;
the site was carefully selected following consideration of other alternative
locations;
Calpine has received no adverse comments from any governmental agency
responsible for environmental protection, land use planning, or other
regulation of the proposed site or Palmetto Energy ;
There is reasonable assurance that Palmetto Energy will conform to all
applicable State and local laws and regulations issued thereunder, including
any allowable variance provisions; and
the State of South Carolina and its residents will benefit overall from the
existence of Palmetto Energy.
-5-
reserve margins, to provide for more power supply diversity, and to create a
more vigorous and competitive wholesale market for power and energy;
+ all of the business risk and costs associated with Palmetto Energy will be
home by Calpine's investors, and not by South Carolina or its residents;
+ Palmetto Energy will provide significant non-energy-related economic
benefits to the State of South Carolina and to York County;
+ there will be no negative impacts to South Carolina residents arising from
Palmetto Energy 's use of the electric transmission system or natural gas
pipeline system;
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+ the site was carefully selected following consideration of other alternative
locations;
+ Calpine has received no adverse comments from any governmental agency
responsible for environmental protection, land use planning, or other
regulation of the proposed site or Palmetto Energy;
+ There is reasonable assurance that Palmetto Energy will conform to all
applicable State and local laws and regulations issued thereunder, including
any allowable variance provisions; and
+ the State of South Carolina and its residents will benefit overall from the
existence of Palmetto Energy .
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I believe that the construction and operation of Palmetto Energy are in the public
interest and is justified by the public convenience and necessity.
WHAT ARE YOUR RECOMMENDATIONS REGARDING THE PROPOSED
CALPINE FACILITY?
I recommend that the Commission grant Palmetto Energy a Certificate of
Environmental Compatibility and Public Convenience and Necessity to construct and
operate an electric generating plant in York County, South Carolina.
CALPINE BACKGROUND AND COMMITMENTS
PLEASE DESCRIBE PALMETTO ENERGY CENTER, LLC.
Palmetto Energy Center, LLC is a limited liability company organized under the laws
of the State of Delaware. Palmetto Energy's principal place of business is in York
County, South Carolina. Palmetto Energy is an affiliate of Calpine Corporation.
PLEASE DESCRIBE CALPINE.
Calpine Corporation is a publicly traded company that develops, owns and operates
wholesale electrical generating facilities in the United States. Based in San Jose,
Califomia, Calpine Corporation is an independent power company that is dedicated to
providing customers with clean, efficient, natural gas-fired power generation. Calpine
has facilities in operation or under construction 27 states in the United States, three
provinces in Canada and in the United Kingdom. Calpine also is the world's largest
producer of renewable geothermal energy, and it owns and markets 1.3 trillion cubic
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I believe that the construction and operation of Palmetto Energy are in the public
interest and is justified by the public convenience and necessity.
3 Q. WHAT ARE YOUR RECOMMENDATIONS REGARDING THE PROPOSED
4 CALPINE FACILITY?
5 A. I recommend that the Commission grant Palmetto Energy a Certificate of
Environmental Compatibility and Public Convenience and Necessity to construct and
operate an electric generating plant in York County, South Carolina.
CALPINE BACKGROUND AND COMMITMENTS
9 Q. PLEASE DESCRIBE PALMETTO ENERGY CENTER, LLC.
10 A. Palmetto Energy Center, LLC is a limited liability company organized under the laws
11 of the State of Delaware. Palmetto Energy's principal place of business is in York
12 County, South Carolina. Palmetto Energy is an affiliate of Calpine Corporation.
13 Q. PLEASE DESCRIBE CALPINE.
14 A. Calpine Corporation is a publicly traded company that develops, owns and operates
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wholesale electrical generating facilities in the United States. Based in San Jose,
California, Calpine Corporation is an independent power company that is dedicated to
providing customers with clean, efficient, natural gas-fired power generation. Calpine
has facilities in operation or under construction 27 states in the United States, three
provinces in Canada and in the United Kingdom. Calpine also is the world's largest
producer of renewable geothermal energy, and it owns and markets 1.3 trillion cubic
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feet of proved natural gas reserves in Canada and the United States. The company
was founded in 1984 and is publicly traded on the New York Stock Exchange under
the symbol CPN.
WHAT IS THE RELATIONSHIP BETWEEN CALPINE AND PALMETTO
ENERGY ?
Palmetto Energy is a wholly-owned subsidiary of Calpine Corporation.
IS PALMETTO ENERGY CENTER, LLC AUTHORIZED TO TRANSACT
BUSINESS IN SOUTH CAROLINA?
Yes.
PLEASE GENERALLY DESCRIBE CALPINE'S POWER PLANT
DEVELOPMENT ACTIVITIES IN THE UNITED STATES AND IN SOUTH
CAROLINA.
As a leading national independent power producer, Calpine is committed to
developing state of the art gas fired efficient power generating facilities in areas
throughout the United States were there is sufficient need for such facilities. Calpine
presently has facilities under construction or in operation in all major National Energy
Reliability Council (NERC) regions in the United States. As detailed in Mr.
Holland's testimony, Calpine has carefully considered the need for power and the
substantial benefits to South Carolina (and the region) from the development of the
Palmetto Energy Facility. In addition to its proposed Palmetto Energy Facility,
Calpine presently operates the Broad River Energy Center, in Cherokee County
-7-
feet of proved natural gas reserves in Canada and the United States. The company
was founded in 1984 and is publicly traded on the New York Stock Exchange under
the symbol CPN.
4 Q. WHAT IS THE RELATIONSHIP BETWEEN CALPINE AND PALMETTO
5 ENERGY?
6 A. Palmetto Energy is a wholly-owned subsidiary of Calpine Corporation.
7 Q. IS PALMETTO ENERGY CENTER, LLC AUTHORIZED TO TRANSACT
8 BUSINESS IN SOUTH CAROLINA?
9 A. Yes.
10 Q. PLEASE GENERALLY DESCRIBE CALPINE'S POWER PLANT(.
11 DEVELOPMENT ACTIVITIES IN THE UNITED STATES AND IN SOUTH
12 CAROLINA.
13 A. As a leading national independent power producer, Calpine is committed to[
14 developing state of the art gas fired efficient power generating facilities in areas
15 throughout the United States were there is sufficient need for such facilities. Calpine
16 presently has facilities under construction or in operation in all major National Energy
17 Reliability Council (NERC) regions in the United States. As detailed in Mr.
18 Holland's testimony, Calpine has carefully considered the need for power and the
19 substantial benefits to South Carolina (and the region) f'rom the development of the
20 Palmetto Energy Facility. In addition to its proposed Palmetto Energy Facility,
21 Calpine presently operates the Broad River Energy Center, in Cherokee County
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which supplies peaking power to CP&L, and is constructing the Columbia Energy
Center, in Calhoun County. The Columbia facility will produce steam for use by
Carolina Eastman and as well as electrical power for sale in the electrical wholesale
power market.
PLEASE DESCRIBE CALPINE'S COMMITMENT TO THE COMMUNITY,
ITS EMPLOYEES, SAFETY, AND THE ENVIRONMENT.
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Calpine is committed to being a good corporate citizen. As I said, Calpine has a
significant presence in and commitment to South Carolina. We have a proven track
record of working closely with community officials, residents, and environmental
agencies to ensure that our facilities fully comply with all environmental
requirements and are constructed and operated safely. Since the commencement of
this project, Calpine has worked closely with residents, environmental activists, local
"businesses and elected officials in Fort Mill, South Carolina, and York County to
develop the best facility for the area, and to protect the natural resources of the area.
This commitment will not end with the commencement of construction or the
commercial operation of the Palmetto Energy Facility, but will continue over the
many years this facility will be in operation.
CAN CALPINE OFFER REASONABLE ASSURANCES THAT THE
FACILITY WILL CONFORM TO ALL APPLICABLE STATE AND LOCAL
LAWS AND REGULATIONS, INCLUDING ANY ALLOWABLE VARIANCE
PROVISIONS?
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which supplies peaking power to CP&L, and is constructing the Columbia Energy
Center, in Calhoun County. The Columbia facility will produce steam for use by
Carolina Eastman and as well as electrical power for sale in the electrical wholesale
power market.
5 Q. PLEASE DESCRIBE CALPINE'S COMMITMENT TO THE COMMUNITY,
6 ITS EMPLOYEES, SAFETY, AND THE ENVIRONMENT.
7 A. Calpine is committed to being a good corporate citizen. As I said, Calpine has a
8 significant presence in and commitment to South Carolina. We have a proven track
9 record of working closely with community officials, residents, and environmental
10 agencies to ensure that our facilities fully comply with all environmental
11 requirements and are constructed and operated safely. Since the commencement of
12 this project, Calpine has worked closely with residents, environmental activists, local
13 'businesses and elected officials in Fort Mill, South Carolina, and York County to
14 develop the best facility for the area, and to protect the natural resources of the area.
15 This commitment will not end with the commencement of construction or the
16 commercial operation of the Palmetto Energy Facility, but will continue over the
17 many years this facility will be in operation.
18 Q. CAN CALPINE OFFER REASONABLE ASSURANCES THAT THE
19 FACILITY WILL CONFORM TO ALL APPLICABLE STATE AND LOCAL
20 LAWS AND REGULATIONS, INCLUDING ANY ALLOWABLE VARIANCE
21 PROVISIONS?
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Yes. As noted above, Calpine is committed to being a good corporate citizen. As Mr.
Howroyd's testimony indicates, the Palmetto Energy Facility, as a state-of-the-art gas
fired combined cycle facility, is designed to conform to all applicable state and local
laws and regulations. Calpine will do what it takes to satisfy all applicable laws and
regulations.
PLEASE DESCRIBE CALPINE'S ENVIRONMENTAL GOALS.
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Calpine is committed to protecting the environment and ensuring that it is a valued
and trusted member of the communities in which its facilities are located. This
commitment stems from our background as the nation's largest geothermal power
producer and our desire to build, own and operate the nation's largest, most advanced
fleet of modern clean burning natural gas fired combined cycle power plants in the
nation. Calpine utilizes BACT to control plant emissions. We work closely with
federal, state and local authorities to ensure that we comply with all applicable
environmental statutes, standards and regulations. Ultimately, we recognize that the
long-term success of our company and our projects will depend in large part on our
ability to protect the environment and be good neighbors. This is evidenced by the
fact that one of our projects in California has been endorsed by the local Chapter of
the Sierra Club, and the local chapter of the American Lung Association.
THE CALPINE TEAM
PLEASE DESCRIBE THE CALPINE TEAM APPROACH.
Calpine has retained a group of highly qualified firms and individual professionals to
assist it in designing and developing the Palmetto Energy Facility. These firms and
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1 A. Yes. As noted above, Calpine is committed to being a good corporate citizen. As Mr.
Howroyd's testimony indicates, the Palmetto Energy Facility, as a state-of-the-art gas
fired combined cycle facility, is designed to conform to all applicable state and local
laws and regulations. Calpine will do what it takes to satisfy all applicable laws and
regulations.
6 Q. PLEASE DESCRIBE CALPINE'S ENVIRONMENTAL GOALS.
7 A. Calpine is committed to protecting the environment and ensuring that it is a valued
8 and trusted member of the communities in which its facilities are located. This
9 commitment stems from our background as the nation's largest geothermal power
10 producer and our desire to build, own and operate the nation's largest, most advanced
11 fleet of modem clean burning natural gas fired combined cycle power plants in the
12 nation. Calpine utilizes BACT to control plant emissions. We work closely with
13 federal, state and local authorities to ensure that we comply with all applicable
14 environmental statutes, standards and regulations. Ultimately, we recognize that the
15 long-term success of our company and our projects will depend in large part on our
16 ability to protect the environment and be good neighbors. This is evidenced by the
17 fact that one of our projects in California has been endorsed by the local Chapter of
18 the Sierra Club, and the local chapter of the American Lung Association.
19 THE CALPINE TEAM
20 Q. PLEASE DESCRIBE THE CALPINE TEAM APPROACH.
21 A. Calpine has retained a group of highly qualified firms and individual professionals to
22 assist it in designing and developing the Palmetto Energy Facility. These firms and
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individuals utilize proven Calpine standard plant designs and specifications to prepare
the required initial design documents needed to support our permit applications. This
approach insures the final plant design will conform to our permit applications and
result in a highly efficient, combined cycle power plant that has the some of the
lowest emissions of any power plant in South Carolina. Once we have achieved all of
the necessary permits needed for construction of the PEC and obtained the project
financing, Calpine will retain the necessary employees, professionals and firms to
safely construct and operate the Palmetto Energy Facility.
PLEASE IDENTIFY THE MEMBERS OF CALPINE'S TEAM THAT WILL
BE TESTIFYING IN THIS CASE IN SUPPORT OF CALPINE'S
APPLICATION.
In addition to my testimony, Calpine will present testimony by the following
professionals:
Dr. George C. Howroyd - Dr. Howroyd is a Principal Engineer with CH2M
HILL, and will testify as to the potential environmental impacts of Palmetto
Energy and the manner in which those impacts are being mitigated;
Mr. Art Holland - Mr. Holland is an Account Manager with Pace Global
Energy Services, and will testify to the need for Palmetto Energy and the
impact Palmetto Energy will have on system economy and reliability.
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individuals utilize proven Calpine standard plant designs and specifications to prepare
the required initial design documents needed to support our permit applications. This
approach insures the final plant design will conform to our permit applications and
result in a highly efficient, combined cycle power plant that has the some of the
lowest emissions of any power plant in South Carolina. Once we have achieved all of
the necessary permits needed for construction of the PEC and obtained the project
financing, Calpine will retain the necessary employees, professionals and firms to
safely construct and operate the Palmetto Energy Facility.
9 Q. PLEASE IDENTIFY THE MEMBERS OF CALPINE'S TEAM THAT WILL
10 BE TESTIFYING IN THIS CASE IN SUPPORT OF CALPINE'S
APPLICATION.
12 A. In addition to my testimony, Calpine will present testimony by the following
13 professionals:
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~ Dr. George C. Howroyd — Dr. Howroyd is a Principal Engineer with CH2M
HILL, and will testify as to the potential environmental impacts of Palmetto
Energy and the manner in which those impacts are being mitigated;
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~ Mr. Art Holland — Mr. Holland is an Account Manager with Pace Global
Energy Services, and will testify to the need for Palmetto Energy and the
impact Palmetto Energy will have on system economy and reliability.
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THE PALMETTO ENERGY CENTER FACILITY
PLEASE GENERALLY DESCRIBE THE PROPOSED PALMETTO ENERGY
CENTER FACILITY AND ITS LOCATION.
The proposed Palmetto Energy is a combined-cycle, natural gas-fired combustion
turbine generating plant. The design of the PEC incorporates three General Electric
model 7FB natural gas-fired combustion turbine generators. Each turbine will exhaust
to a Heat Recovery Steam generator (HRSG) that provides steam to be used in a
condensing steam turbine generator (STG). The HRSGs will also include provisions
for supplemental firing utilizing natural gas fired duct burners. Natural gas will serve
as the sole fuel source for the turbines and duct burners with no backup fuel proposed.
Palmetto Energy is to be located on an approximately 86-acre tract of land located in
the Bradley Industrial Park in Fort Mill, York County, South Carolina.
PLEASE DESCRIBE THE MAJOR COMPONENTS AND SYSTEMS OF THE
PROPOSED PALMETTO ENERGY.
Palmetto Energy will be capable of generating approximately 970 MW of electricity
using three General Electric Model 7FB combustion turbines. The combustion
turbines will be manufactured in General Electric's manufacturing plant in Greenville
South Carolina. Each combustion turbine will exhaust to a HRSG that will provide
steam to a single STG operating in combined cycle mode. The equipment will be
arranged in a "3 x 1" configuration for operational flexibility. The hourly electrical
production rate is dependent on operating and ambient conditions such as CTG
operating load (percent of maximum load) and ambient temperature.
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THE PALMETTO ENERGY CENTER FACILITY
2 Q. PLEASE GENERALLY DESCRIBE THE PROPOSED PALMETTO ENERGY
3 CENTER FACILITY AND ITS LOCATION.
4 A. The proposed Palmetto Energy is a combined-cycle, natural gas-fired combustion
5 turbine generating plant. The design of the PEC incorporates three General Electric
6 model 7FB natural gas-fired combustion turbine generators. Each turbine will exhaust
7 to a Heat Recovery Steam generator (HRSG) that provides steam to be used in a
S condensing steam turbine generator (STG). The HRSGs will also include provisions
9 for supplemental firing utilizing natural gas fired duct burners. Natural gas will serve
10 as the sole fuel source for the turbines and duct burners with no backup I'uel proposed.
11 Palmetto Energy is to be located on an approximately 86-acre tract of land located in
12 the Bradley Industrial Park in Fort Mill, York County, South Carolina.
13 Q. PLEASE DESCRIBE THE MAJOR COMPONENTS AND SYSTEMS OF THE
14 PROPOSED PALMETTO ENERGY .
15 A. Palmetto Energy will be capable of generating approximately 970 MW of electricity
16 using three General Electric Model 7FB combustion turbines. The combustion
17 turbines will be manufactured in General Electric's manufacturing plant in Greenville
18 South Carolina. Each combustion turbine will exhaust to a HRSG that will provide
19 steam to a single STG operating in combined cycle mode. The equipment will be
20 arranged in a "3 x I" configuration for operational flexibility. The hourly electrical
21 production rate is dependent on operating and ambient conditions such as CTG
22 operating load (percent of maximum load) and ambient temperature.
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The HRSG's will also include provisions for supplemental duct firing using natural
gas fired duct burners. Supplemental firing of the HRSG's will generate additional
steam over that produced by the gas turbine exhaust alone. This additional steam will
be used for increased electrical output. In addition, the combustion turbine output
will be increased during periods of peak electricity demand through steam injection
for power augmented generation (PAG). When operating in PAG mode, steam from
the HRSG is injected into the combustion turbine to increase mass flow and
accordingly power output.
The Facility will be designed to incorporate the following major components:
• All-weather enclosures that will contain the proposed new combustion turbine
generators;
HRSG structures that will be approximately 80 feet in height and will be equipped
with natural gas-fired duct burners;
Three 160-foot exhaust stacks, one for each combustion turbine generator set,
which will exhaust the products of combustion from each CTG/HRSG train;
Condensing steam turbine generator structure that will house the steam turbine;
Multi-cell, mechanical draft, wet closed-cycle cooling tower, fitted with drift
eliminators to reduce drift to 0.005% of circulating water flow;
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The HRSG's will also include provisions for supplemental duct firing using natural
gas fired duct burners. Supplemental firing of the HRSG's will generate additional
steam over that produced by the gas turbine exhaust alone. This additional steam will
be used for increased electrical output. In addition, the combustion turbine output
will be increased during periods of peak electricity demand through steam injection
for power augmented generation (PAG). When operating in PAG mode, steam from
the HRSG is injected into the combustion turbine to increase mass flow and
accordingly power output.
The Facility will be designed to incorporate the following major components:
10 ~ All-weather enclosures that will contain the proposed new combustion turbine
generators;
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~ HRSG structures that will be approximately 80 feet in height and will be equipped
with natural gas-fired duct burners;
~ Three 160-foot exhaust stacks, one for each combustion turbine generator set,
which will exhaust the products of combustion from each CTG /HRSG train;
16 ~ Condensing steam turbine generator structure that will house the steam turbine;
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~ Multi-cell, mechanical drafl, wet closed-cycle cooling tower, fitted with drift
eliminators to reduce drift to 0.005% of circulating water flow;
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One gas-fired auxiliary boiler rated at 99 mmBtu/hr that will be used to provide
steam to the steam turbine during periods of startup (emissions will be routed to a
dedicated 100 ft. exhaust stack);
A single story building to house the Facility control room, administrative offices,
laboratory, machine shop, and other miscellaneous service buildings;
Outdoor electrical switchyard, including station step-up transformers, switches,
and power metering equipment;
• Water supply and wastewater service;
• Tanks for raw water and demineralized water storage, etc;
• Paved/gravel/crushed stone roads and parking areas; and
• Diesel-fired emergency generator and diesel fire pump (emergency use only).
Palmetto Energy will be operated as a fully dispatchable generating facility, and can
therefore be expected to operate up to a maximum of 24 hours per day, 365 days per
year. As fully described in Mr. Howroyd's testimony, the state-of-the-art BACT
design will limit nitrogen oxide (NOX) emissions from the proposed CTG/HRSG
exhaust to a level of 3.5 parts per million.
The combustion turbine operates by using combustion air that is filtered and
compressed in a multiple-stage axial flow compressor. Compressed air and natural
gas are mixed and combusted in the turbine combustion chamber. Lean pre-mix dry-
lowNOx (DLN) combustors are used to minimize NOx formation during combustion.
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~ One gas-fired auxiliary boiler rated at 99 mmBtu/hr that will be used to provide
steam to the steam turbine during periods of startup (emissions will be routed to a
dedicated 100 ft. exhaust stack);
~ A single story building to house the Facility control room, administrative offices,
laboratory, machine shop, and other miscellaneous service buildings;
~ Outdoor electrical switchyard, including station step-up transformers, switches,
and power metering equipment;
~ Water supply and wastewater service;
~ Tanks for raw water and demineralized water storage, etc;
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~ Paved/gravel/crushed stone roads and parking areas; and
~ Diesel-fired emergency generator and diesel fire pump (emergency use only).
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Palmetto Energy will be operated as a fully dispatchable generating facility, and can
therefore be expected to operate up to a maximum of 24 hours per day, 365 days per
year. As fully described in Mr. Howroyd's testimony, the state-of —the-art BACT
design will limit nitrogen oxide (NOX) emissions from the proposed CTG/HRSG
exhaust to a level of 3.5 parts per million.
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The combustion turbine operates by using combustion air that is filtered and
compressed in a multiple-stage axial flow compressor. Compressed air and natural
gas are mixed and combusted in the turbine combustion chamber. Lean pre-mix dry-
lowNOx (DLN) combustors are used to minimize NOx formation during combustion.
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Exhaustgas from the combustionchamberis expandedthrougha multi-stagepower
turbinethat drivesboththeair compressorandelectricpowergeneratorprior to being
exhaustedto theHRSG.
EachGE 7FB combustionturbinegeneratorsetwill includeacompressorsection,gas
combustionsystem(utilizing advancedDLN combustors),power turbine,anda 60-
hertz(Hz), 18kilovolt (kV) generator.TheGE 7FB combustionturbinesaredesigned
to operatein the DLN modeat operatingloadsfrom 50 percentup to baseloadrating
and will be taken out of service for scheduledmaintenance,or as dictated by
economicor electricaldemandconditions.
Exhaustgasexiting thecombustionturbine at approximately1,100°Fwill beducted
directly to an HRSG wherehigh-pressuresteamis producedto generateadditional
electricity in the STG. OneHRSGwill beprovidedfor eachcombustionturbineto
recoverthewasteheatin theexhaustfor thepurposeof generatingsteamto drive the
STG. Exhaustgasenteringthe HRSG will be cooled to approximately170°Fto
200°Fby the time it leavestheHRSG. Steamproductionin theHRSGscanalsobe
increasedusing natural gas fired duct burnerslocatedin eachHRSG, resulting in
additional peak power production.The high-pressureportion of the STG receives
high-pressuresuperheatedsteamfrom oneor moreof theHRSGs,andexhauststo the
reheatsection of the HRSGs.The steamfrom the reheatsectionof the HRSGsis
suppliedto the intermediatepressuresectionof theturbine,which expandsto thelow-
pressuresection. The low-pressureportion of the STG also receiveslow-pressure
steamfrom theHRSGsandexhauststo thesurfacecondenser.
-14-
Exhaust gas from the combustion chamber is expanded through a multi-stage power
turbine that drives both the air compressor and electric power generator prior to being
exhausted to the HRSG.
Each GE 7FB combustion turbine generator set will include a compressor section, gas
combustion system (utilizing advanced DLN combustors), power turbine, and a 60-
hertz (Hz), 18 kilovolt (kV) generator. The GE 7FB combustion turbines are designed
to operate in the DLN mode at operating loads from 50 percent up to baseload rating
and will be taken out of service for scheduled maintenance, or as dictated by
economic or electrical demand conditions.
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Exhaust gas exiting the combustion turbine at approximately 1,100'F will be ducted
directly to an HRSG where high-pressure steam is produced to generate additional
electricity in the STG. One HRSG will be provided for each combustion turbine to
recover the waste heat in the exhaust for the purpose of generating steam to drive the
STG. Exhaust gas entering the HRSG will be cooled to approximately 170'F to
200'F by the time it leaves the HRSG. Steam production in the HRSGs can also be
increased using natural gas fired duct burners located in each HRSG, resulting in
additional peak power production. The high-pressure portion of the STG receives
high-pressure superheated steam from one or more of the HRSGs, and exhausts to the
reheat section of the HRSGs. The steam from the reheat section of the HRSGs is
supplied to the intermediate pressure section of the turbine, which expands to the low-
pressure section. The low-pressure portion of the STG also receives low-pressure
steam from the HRSGs and exhausts to the surface condenser.
-14-
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An advanced technology Selective Catalytic Reduction (SCR) emission control
device will be installed in each HRSG to reduce emissions of NOx from both the
combustion turbines and the duct burners. Each HRSG will be exhausted through its
own stack.
A multi-cell mechanical draft closed-cycle wet cooling tower will be integral to
operation of the Facility. The majority of the cooling water will be used in the
surface condenser to absorb the heat rejected from the STG. Water from the cooling
tower is commonly referred to as circulating water. The circulating water system will
conserve water by increasing the number of times the water can cycle through the
cooling tower, thereby reducing the requirements for water make-up. A dedicated set
of circulating water pumps will be provided for this service. Circulating water will
also be used for direct cooling of plant auxiliaries. The cooling tower itself is a device
designed to reject heat from the STG by evaporating clean water. The cooling tower
will be fitted with drift eliminators to reduce the amount of drift to 0.005 percent of
the circulating water flow rate.
A 99 million British thermal units per hour (MMBtu/hr) natural gas-fired auxiliary
steam boiler will be used for heating steam to accommodate plant start-up and to
optimize keep-warm conditions. The auxiliary steam boiler will use low-NOx
combustors and fire natural gas exclusively. The operation of the auxiliary boiler will
be limited to a maximum of 2,500 hours/year.
Natural gas will be delivered to the plant boundary at a pressure sufficient for use in
the combustion turbines without additional fuel compression. Once on-site, the
-15-
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An advanced technology Selective Catalytic Reduction (SCR) emission control
device will be installed in each HRSG to reduce emissions of NOx from both the
combustion turbines and the duct burners. Each HRSG will be exhausted through its
own stack.
A multi-cell mechanical draft closed-cycle wet cooling tower will be integral to
operation of the Facility. The majority of the cooling water will be used in the
surface condenser to absorb the heat rejected from the STG. Water from the cooling
tower is commonly referred to as circulating water. The circulating water system will
conserve water by increasing the number of times the water can cycle through the
cooling tower, thereby reducing the requirements for water make-up. A dedicated set
of circulating water pumps will be provided for this service. Circulating water will
also be used for direct cooling of plant auxiliaries. The cooling tower itself is a device
designed to reject heat from the STG by evaporating clean water. The cooling tower
will be fitted with driit eliminators to reduce the amount of drill to 0.005 percent of
the circulating water flow rate.
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A 99 million British thermal units per hour (MMBtu/hr) natural gas-fired auxiliary
steam boiler will be used for heating steam to accommodate plant start-up and to
optimize keep-warm conditions. The auxiliary steam boiler will use low-NOx
combustors and fire natural gas exclusively. The operation of the auxiliary boiler will
be limited to a maximum of 2,500 hours/year.
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Natural gas will be delivered to the plant boundary at a pressure sufficient for use in
the combustion turbines without additional fuel compression. Once on-site, the
- 15
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natural gas will first be sent through a knockout drum and filtered for removal of any
liquid that may have been carried through the pipeline and delivered to the CTGs,
duct burners, auxiliary boilers and space heaters. The natural gas to the CTGs will
then be heated using a small natural gas-fired dew point heater during start-up and a
performance heater during operation. Due to the critical nature of supplying heated
fuel to the CTGs, one dew point heater and one performance heater will be installed
in each CTG gas line. After heating, the natural gas will be sent through a
filter/separator to remove particulate matter and entrained liquid. Finally, the treated
natural gas is delivered to the combustion turbines.
An emergency generator engine (1,200 kW) will be located on-site. The generator
will provide power to essential services necessary to protect the equipment during an
emergency shutdown resulting from a loss of power. The emergency generator engine
will only be used in the event of a disruption Of power delivery and during routine
readiness testing. A small diesel engine (350 BHP) will be installed to power a fire
pump located on-site. The fire pump engine will be operated in the event of a plant
fire and during routine readiness testing.
The multi-cell mechanical draft closed-cycle wet cooling tower was selected for use
at the PEC as the most effective economic cooling option from a water conservation
standpoint. The adjacent Catawba River represents the most practicable supply of raw
water. In addition to having adequate water volume to meet project needs, the
Catawba River also has sufficient capacity to accept treated process wastewater from
PEC.
-16-
natural gas will first be sent through a knockout drum and filtered for removal of any
liquid that may have been carried through the pipeline and delivered to the CTGs,
duct burners, auxiliary boilers and space heaters. The natural gas to the CTGs will
then be heated using a small natural gas-fired dew point heater during start-up and a
performance heater during operation. Due to the critical nature of supplying heated
fuel to the CTGs, one dew point heater and one performance heater will be installed
in each CTG gas line. After heating, the natural gas will be sent through a
filter/separator to remove particulate matter and entrained liquid. Finally, the treated
natural gas is delivered to the combustion turbines.
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An emergency generator engine (1,200 kW) will be located on-site. The generator
will provide power to essential services necessary to protect the equipment during an
emergency shutdown resulting from a loss of power. The emergency generator engine
will only be used in the event of a disruption of power delivery and during routine
readiness testing. A small diesel engine (350 BHP) will be installed to power a fire
pump located on-site. The fire pump engine will be operated in the event of a plant
fire and during routine readiness testing.
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The multi-cell mechanical draft closed-cycle wet cooling tower was selected for use
at the PEC as the most effective economic cooling option from a water conservation
standpoint. The adjacent Catawba River represents the most practicable supply of raw
water. In addition to having adequate water volume to meet project needs, the
Catawba River also has sufficient capacity to accept treated process wastewater from
PEC.
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Discharge of treated cooling water will occur via a new discharge line to the Catawba
River, downstream of the water intake structure. The majority of discharged water
will be derived from cooling tower blowdown. Other waste streams may be mixed
with this discharge and include demineralization regeneration wastes, steam cycle
blowdown, and floor and equipment drains.
Palmetto Energy will include all civil works required to support a complete and
operable generating facility. These will include, but not be limited to, the following:
• Drainage facilities for controlling and capturing storm water runoff;
• Fencing and security systems for safety protection; and
• Plant roadways and access lighting.
11 Q. WHAT BUILDINGS WILL BE LOCATED ON THE SITE?
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A° There will be several buildings for the Facility. The administrative building will be
single story and will house the administration offices, operating personnel offices,
control room, locker room, sanitary facilities, maintenance and storage areas, and
training areas.
A separate auxiliary building will house the plant water treatment system. A third
building will be in the electrical switchyard area and contain electrical protective
relays. Each gas turbine and the steam turbine will be housed in a sound-attenuating,
all-weather enclosure (which gives the appearance of a building).
-17-
Discharge of treated cooling water will occur via a new discharge line to the Catawba
River, downstream of the water intake structure. The majority of discharged water
will be derived from cooling tower blowdown. Other waste streams may be mixed
with this discharge and include demineralization regeneration wastes, steam cycle
blowdown, and floor and equipment drains.
Palmetto Energy will include all civil works required to support a complete and
operable generating facility. These will include, but not be limited to, the following:
~ Drainage facilities for controlling and capturing storm water runoff;
~ Fencing and security systems for safety protection; and
10 ~ Plant roadways and access lighting.
11 Q. WHAT BUILDINGS WILL BE LOCATED ON THE SITEY
12 A. There will be several buildings for the Facility. The administrative building will be
13 single story and will house the administration offices, operating personnel offices,
14 control room, locker room, sanitary facilities, maintenance and storage areas, and
15 training areas.
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A separate auxiliary building will house the plant water treatment system. A third
building will be in the electrical switchyard area and contain electrical protective
relays. Each gas turbine and the steam turbine will be housed in a sound-attenuating,
all-weather enclosure (which gives the appearance of a building).
20
- 17
1 Q. HOW WILL THE FACILITY BE CONSTRUCTED?
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The construction period will last approximately 24 months from "Notice to Proceed"
to "Commercial Operation." Initial construction activity will involve the leveling of
the site to a grade elevation, followed by the pouring of equipment foundations and
the construction of the main building. The major pieces of equipment will be shipped
via rail to the closest rail siding (which is within the industrial park) capable of
handling the weight of the equipment. Special heavy-haul equipment will be used to
convey the equipment from the rail siding to the site. At the site, the equipment will
be set on the foundations with heavy lift cranes. As soon as all equipment is set in
place, piping and electrical installation will commence. Once erection is complete,
comprehensive testing will take place and adjustments will be made before
Commercial Operation commences to ensure that the plant is in compliance with the
performance and environmental requirements.
WHAT IS THE ESTIMATED COST OF PALMETTO ENERGY ?
Palmetto Energy will cost in excess of $400 million.
WHAT SOURCE OF FINANCING DOES CALPINE PLAN TO USE TO
CONSTRUCT PALMETTO ENERGY?
Calpine currently has two non-recourse credit facilities, Calpine Construction Finance
Company and Calpine Construction Finance Company II (CCFC and CCFCII), which
provide Calpine with a total borrowing capacity of $3.5 billion. These non-recourse
credit facilities are one of the principal vehicles utilized to finance the construction of
-18-
1 Q. HOW WILL THE FACILITY BE CONSTRUCTED?
2 A. The construction period will last approximately 24 months from "Notice to Proceed"
3 to "Commercial Operation." Initial construction activity will involve the leveling of
4 the site to a grade elevation, followed by the pouring of equipment foundations and
5 the construction of the main building. The major pieces of equipment will be shipped
6 via rail to the closest rail siding (which is within the industrial park) capable of
7 handling the weight of the equipment. Special heavy-haul equipment will be used to
8 convey the equipment from the rail siding to the site. At the site, the equipment will
9 be set on the foundations with heavy lift cranes. As soon as all equipment is set in
10 place, piping and electrical installation will commence. Once erection is complete,
11 comprehensive testing will take place and adjustments will be made before
12 Commercial Operation commences to ensure that the plant is in compliance with the
13 performance and environmental requirements.
14 Q. WHAT IS THE ESTIMATED COST OF PALMETTO ENERGY?
15 A. Palmetto Energy will cost in excess of $400 million.
16 Q. WHAT SOURCE OF FINANCING DOES CALPINE PLAN TO USE TO
17 CONSTRUCT PALMETTO ENERGY?
18 A. Calpine currently has two non-recourse credit facilities, Calpine Construction Finance
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Company and Calpine Construction Finance Company II (CCFC and CCFCII), which
provide Calpine with a total borrowing capacity of $3.5 billion. These non-recourse
credit facilities are one of the principal vehicles utilized to finance the construction of
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Calpine's diversified portfolio of gas-fired power plants. Calpine has not finalized its
specific plans for the funding of Palmetto Energy. As construction of the facility
nears, Calpine expects that Palmetto Energy would be funded through credit capacity
then available under one of the CCFC facilities, most likely CCFCII given its larger
size, $2.5 billion, and its longer maturity date. However, Calpine may elect to fund
the construction of Palmetto Energy from the proceeds of corporate capital market
transactions or from the arranging of a stand-alone project finance transaction. While
Calpine currently expects to fund the construction of Palmetto Energy through one of
the CCFC facilities, Calpine has demonstrated the ability to raise substantial capital
from various sources to fund the construction of its new facilities. Recently
completed financing transactions clearly demonstrate that Calpine has competitive
and timely access to the capital markets, providing sufficient liquidity to meet current
and future capital requirements.
WHEN DOES CALPINE EXPECT PALMETTO ENERGY TO BE IN
COMMERCIAL OPERATION?
Calpine expects Palmetto Energy to be in commercial operation by the summer of
2005.
WHO BEARS THE RISK IF PALMETTO ENERGY IS NOT SUCCESSFUL?
Calpine's equity and debt investors will bear all of the risk of the success of Palmetto
Energy, and neither the State of South Carolina nor any of the residents of the State
will be responsible for any of the costs of the project.
-19-
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Calpine's diversified portfolio of gas-fired power plants. Calpine has not finalized its
specific plans for the funding of Palmetto Energy. As construction of the facility
nears, Calpine expects that Palmetto Energy would be funded through credit capacity
then available under one of the CCFC facilities, most likely CCFCII given its larger
size, $2.5 billion, and its longer maturity date. However, Calpine may elect to fund
the construction of Palmetto Energy trom the proceeds of corporate capital market
transactions or from the arranging of a stand-alone project finance transaction. While
Calpine currently expects to fund the construction of Palmetto Energy through one of
the CCFC facilities, Calpine has demonstrated the ability to raise substantial capital
from various sources to fund the construction of its new facilities. Recently
completed financing transactions clearly demonstrate that Calpine has competitive
and timely access to the capital markets, providing sufficient liquidity to meet current
and future capital requirements.
1415 Q. WHEN DOES CALPINE EXPECT PALMETTO ENERGY TO BE IN
16 COMMERCIAL OPERATION?
17 A. Calpine expects Palmetto Energy to be in commercial operation by the summer of
18 2005.
19 Q. WHO BEARS THE RISK IF PALMETTO ENERGY IS NOT SUCCESSFUL?
20 A. Calpine*s equity and debt investors will bear all of the risk of the success of Palmetto
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Energy, and neither the State of South Carolina nor any of the residents of the State
will be responsible for any of the costs of the project.
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PLEASE GENERALLY DESCRIBE CALPINE'S PLAN FOR DEVELOPING
AND OPERATING THE FACILITY.
Construction of Palmetto Energy will commence in the second quarter of 2003 and is
expected to last approximately 24 months. Calpine will follow our "Calpine
Construct" approach which has been successfully employed on facilities across the
country. This approach entails the use of an experienced Calpine project management
team who will oversee a qualified Architect/Engineer to prepare design information,
following Calpine standard designs and specifications, and an experienced contractor
to construct the project. Testing will be performed by a Calpine team experienced in
the design and start up requirements of the facility and will commence approximately
six months prior to commercial operation. Approximately 27 full-time employees
will be hired to operate the facility.
SITE SELECTION
PLEASE DESCRIBE HOW YOU DECIDED TO PLACE A NEW FACILITY
IN SOUTH CAROLINA AND HOW CALPINE SELECTED THE SITE FOR
PALMETTO ENERGY?
As discussed earlier, Calpine operates the Broad River facility and is constructing the
Columbia Energy Center. Accordingly, Calpine is very familiar with South Carolina,
its growth, associated power needs, electrical infrastructure and natural gas
infrastructure. In addition, as set forth in Mr. Holland's testimony, Calpine has
evaluated the impact of adding a third plant to the regional market. This evaluation
led us to the conclusion that a new plant was economically justified.
- 20 -
1 Q. PLEASE GENERALLY DESCRIBE CALPINE'S PLAN FOR DEVELOPING
2 AND OPERATING THE FACILITY.
3 A. Construction of Palmetto Energy will commence in the second quarter of 2003 and is
4 expected to last approximately 24 months. Calpine will follow our "Calpine
5 Construct" approach which has been successfully employed on facilities across the
6 country. This approach entails the use of an experienced Calpine project management
team who will oversee a qualified Architect/Engineer to prepare design information,
following Calpine standard designs and specifications, and an experienced contractor
9 to construct the project. Testing will be performed by a Calpine team experienced in
10 the design and start up requirements of the facility and will commence approximately
11 six months prior to commercial operation. Approximately 27 full-time employees
12 will be hired to operate the facility.
SITE SELECTION
14 Q. PLEASE DESCRIBE HOW YOU DECIDED TO PLACE A NEW FACILITY
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IN SOUTH CAROLINA AND HOW CALPINE SELECTED THE SITE FOR
PALMETTO ENERGY?
17 A. As discussed earlier, Calpine operates the Broad River facility and is constructing the
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Columbia Energy Center. Accordingly, Calpine is very familiar with South Carolina,
its growth, associated power needs, electrical intrasttucture and natural gas
inlrastructure. In addition, as set forth in Mr. Holland's testimony, Calpine has
evaluated the impact of adding a third plant to the regional market. This evaluation
led us to the conclusion that a new plant was economically justified.
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Oncethedecisionhadbeenmadeto develop anew plant, Calpineevaluated
list of potential sites using the following criteria: (1) the proximity of adequate
electric transmission, (2) the availability of adequateand economic natural gas
transportationfacilities, (3) the availability of a sufficient water supply and water
dischargefacilities, (4) the existenceof sites locatedin areasthat are zonedin a
mannerthat a power plant would be a permitteduse,(5) the absenceof significant
environmentalissues and (6) willingness of the community to support a power
generatingfacility.
Calpine utilized thesecriteria to selectand evaluatespecific sites. Calpine first
evaluatedelectrictransmission,industriallyzonedpropertiesandwateravailability in
the region. In addition,Calpinecontactedlocal economicdevelopmentofficials in
theregion to assessspecificproperties We consideredall of the factorsidentified
above,andidentified anumberof suitablesitesfor ageneratingfacility.
Thesesiteswere thenvisited by a teamof Calpineprofessionalssothat a first hand
evaluation of their suitability could be performed. This review also included
consultation with local officials in order to determine community receptiveness. The
Fort Mill site was selected above the other sites under consideration because it was
accessible to electric and gas interconnection points, had sufficient water and
wastewater facilities, was appropriately zoned with limited potential environmental
impacts and it was supported by community officials In addition, Calpine shared the
philosophy of the owner of the Bradley Industrial Park (The Springs Company) and
recognized the importance of environmental stewardship and community
commitment. Calpine had several meetings with the Springs Company and the Close
-21 -
Once the decision had been made to develop a new plant, Calpine evaluated
list of potential sites using the following criteria: (I) the proximity of adequate
electric transmission, (2) the availability of adequate and economic natural gas
transportation facilities, (3) the availability of a sufficient water supply and water
discharge facilities, (4) the existence of sites located in areas that are zoned in a
manner that a power plant would be a permitted use, (5) the absence of significant
environmental issues and (6) willingness of the community to support a power
generating facility.
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Calpine utilized these criteria to select and evaluate specific sites. Calpine first
evaluated electric transmission, industrially zoned properties and water availability in
the region. In addition, Calpine contacted local economic development officials in
the region to assess specific properties We considered all of the factors identified
above, and identified a number of suitable sites for a generating facility.
These sites were then visited by a team of Calpine professionals so that a first hand
evaluation of their suitability could be performed. This review also included
consultation with local officials in order to determine community receptiveness. The
Fort Mill site was selected above the other sites under consideration because it was
accessible to electric and gas interconnection points, had sufficient water and
wastewater facilities, was appropriately zoned with limited potential environmental
impacts and it was supported by community officials In addition, Calpine shared the
philosophy of the owner of the Bradley Industrial Park (The Springs Company) and
recognized the importance of environmental stewardship and community
commitment. Calpine had several meetings with the Springs Company and the Close
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family members, (owners of the Springs Company) that included two tours of a
Calpine facility with similar features to the Palmetto Energy Facility.
ELECTRIC TRANSMISSION ARRANGEMENTS
PLEASE DESCRIBE HOW PALMETTO ENERGY WILL
INTERCONNECTED WITH THE ELECTRIC TRANSMISSION GRID.
BE
Palmetto Energy will be connected to the existing Duke 525 kV Richmond Line
(Newport Tie to CP&L's Richmond station). The transmission voltage will be 525
kV, and power will be delivered to the transmission line by looping the transmission
line through the plant substation which will be owned and operated by Duke. The
switchyard will be designed to ensure adequate transmission capability and protection
to ensure no negative impacts on Duke Power's system and its customers.
HAS DUKE POWER CONDUCTED A STUDY OF TRANSMISSION
INTERCONNECTION WITH PALMETTO ENERGY ?
Yes. Duke Power has performed a thermal impact study of the proposed addition of
Palmetto Energy. Duke is also in the process of completing a Facilities Study which
identifies all of the upgrades that may be required and their associated costs. Duke's
study will also include the stability and short circuit analyses.
WILL THE PALMETTO ENERGY FACILITY NEGATIVELY IMPACT TO
THE DUKE POWER TRANSMISSION SYSTEM?
- 22 -
family members, (owners of the Springs Company) that included two tours of a
Calpine facility with similar features to the Palmetto Energy Facility.
ELECTRIC TRANSMISSION ARRANGEMENTS
4 Q. PLEASE DESCRIBE HOW PALMETTO ENERGY WILL BE
5 INTERCONNECTED WITH THE ELECTRIC TRANSMISSION GRID.
6 A. Palmetto Energy will be connected to the existing Duke 525 kV Richmond Line
7 (Newport Tie to CP&L's Richmond station). The transmission voltage will be 525
8 kV, and power will be delivered to the transmission line by looping the transmission
9 line through the plant substation which will be owned and operated by Duke. The
10 switchyard will be designed to ensure adequate transmission capability and protection
11 to ensure no negative impacts on Duke Power's system and its customers.
12 Q. HAS DUKE POWER CONDUCTED A STUDY OF T1VdVSMISSION
13 INTERCONNECTION WITH PALMETTO ENERGY?
14 A. Yes. Duke Power has performed a thermal impact study of the proposed addition of
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Palmetto Energy. Duke is also in the process of completing a Facilities Study which
identifies all of the upgrades that may be required and their associated costs. Duke'
study will also include the stability and short circuit analyses.
18 Q. WILL THK PALMETTO ENERGY FACILITY NEGATIVELY IMPACT TO
19 THE DUKE POWER TRANSMISSION SYSTEM?
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No. Duke Power has both the obligation and the capability to evaluate the impacts of
Palmetto Energy on its transmission system and protect against any negative impact.
Any required upgrades will be paid for by Palmetto Energy and will result in a more
robust transmission system. Significantly, as a general proposition, all else being
equal, the addition of new generation serves to strengthen the local transmission grid
and enhances local reliability.
WHAT IMPROVEMENTS TO DUKE POWER'S SYSTEM WILL BE
NECESSARY TO INTERCONNECT WITH THE PALMETTO ENERGY
FACILITY?
Other improvements on the transmission system notwithstanding, Palmetto Energy
will interconnect to the 525 kV transmission line by creating a new loop in the
existing line to bring it to through a substation at the Facility. The interconnect, short
i-un (approximately 4000 feet) of double circuit 525 kV transmission lines and the
new substation at the plant site will be constructed by Duke and paid for by Calpine.
All of the proposed improvements, rights-of-way and new substation are contained
within the confines of the Bradley Industrial Park.
WHAT WILL THE IMPROVEMENTS AND ADDITIONAL FACILITIES
COST, AND WILL PALMETTO ENERGY BE RESPONSIBLE FOR THOSE
COSTS?
Calpine will be responsible for all interconnection costs. Duke Power has yet to
estimate the electrical interconnection cost. For planning purposes, Calpine has
prepared an internal estimate of the interconnection costs, that assumes all potential
- 23 -
1 A. No. Duke Power has both the obligation and the capability to evaluate the impacts of
Palmetto Energy on its transmission system and protect against any negative impact.
Any required upgrades will be paid for by Palmetto Energy and will result in a more
robust transmission system. Significantly, as a general proposition, all else being
equal, the addition of new generation serves to strengthen the local transmission grid
and enhances local reliability.
7 Q. WHAT IMPROVEMENTS TO DUKE POWER'S SYSTEM WILL BE
NECESSARY TO INTERCONNECT WITH THE PALMETTO ENERGY
FACILITY?
10 A. Other improvements on the transmission system notwithstanding, Palmetto Energy
11 will interconnect to the 525 kV transmission line by creating a new loop in the
12 existing line to bring it to through a substation at the Facility. The interconnect, short
13 run (approximately 4000 feet) of double circuit 525 kV transmission lines and the
14 new substation at the plant site will be constructed by Duke and paid for by Calpine.
15 All of the proposed improvements, rights-of-way and new substation are contained
16 within the confines of the Bradley Industrial Park.
17 Q. WHAT WILL THE IMPROVEMENTS AND ADDITIONAL FACILITIES
18 COST, AND WILL PALMETTO ENERGY BE RESPONSIBLE FOR THOSE
COSTS?
20 A. Calpine will be responsible for all interconnection costs. Duke Power has yet to
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estimate the electrical interconnection cost. For planning purposes, Calpine has
prepared an internal estimate of the interconnection costs, that assumes all potential
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upgrades are required to be performed and has set aside sufficient funds to cover
these costs.
NATURAL GAS SUPPLY
PLEASE DESCRIBE HOW PALMETTO ENERGY WILL BE SUPPLIED
WITH NATURAL GAS.
Palmetto Energy will receive its natural gas requirements by means of an
interconnection with the Transcontinental Gas Pipeline Company ("Transco") natural
gas pipeline through the development and construction of new gas transportation
infrastructure to the area surrounding York County, South Carolina. The new
infrastructure is expected to consist of a wide-diameter pipeline (in the neighborhood
of 24 inches) that will span approximately 37 miles from an intercounection with
Transcontinental Pipe Line (Transco) to the Fort Mill area near Rock Hill, South
Carolina. The pipeline would be constructed by one of three suppliers competing for
the option to build the pipeline lateral required to supply gas to the PEC, Palmetto
Energy will continue to pursue these negotiations and work to procure the most
economical and reliable gas supply.
HOW WILL PALMETTO ENERGY ACQUIRE SUFFICIENT GAS SUPPLY
TO MEET ITS EXPECTED REQUIREMENTS?
The new pipeline will accommodate 100% of the gas requirements of the facility
from the Transco interconnect. The gas supply will comprised of a Calpine portfolio
of gas supply and transportation agreements, including long-term and short term gas
- 24 -
upgrades are required to be performed and has set aside sufficient funds to cover
these costs.
NATURAL GAS SUPPLY
4 Q. PLEASE DESCRIBE HOW PALMETTO ENERGY WILL BE SUPPLIED
5 WITH NATURAL GAS.
6 A. Palmetto Energy will receive its natural gas requirements by means of an
7 interconnection with the Transcontinental Gas Pipeline Company ("Transco") natural
8 gas pipeline through the development and construction of new gas transportation
9 infrastructure to the area surrounding York County, South Carolina. The new
10 inf'rastructure is expected to consist of a wide-diameter pipeline (in the neighborhood
11 of 24 inches) that will span approximately 37 miles from an interconnection with
12 Transcontinental Pipe Line (Transco) to the Fort Mill area near Rock Hill, South
13 Carolina. The pipeline would be constructed by one of three suppliers competing for
14 the option to build the pipeline lateral required to supply gas to the PEC, Palmetto
15 Energy will continue to pursue these negotiations and work to procure the most
16 economical and reliable gas supply.
17 Q. HOW WILL PALMETTO ENERGY ACQUIRE SUFFICIENT GAS SUPPLY
18 TO MEET ITS EXPECTED REQUIREMENTS2
19 A. The new pipeline will accommodate 100% of the gas requirements of the facility
20 from the Transco interconnect. The gas supply will comprised of a Calpine portfolio
21 of gas supply and transportation agreements, including long-term and short term gas
- 24-
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supply contracts. Transportation arrangements will include firm transportation and
capacity purchased from secondary markets, including released firm, and interruptible
contracts. This structure is intended to provide the flexibility to transport gas from
multiple sources including U.S. Gulf Coast, the Appalachian Basin, and gas derived
from expanded LNG facilities on the East Coast.
WHAT WILL BE THE EFFECT OF THE INTERCONNECTION OF
PALMETTO ENERGY WITH TRANSCO'S SYSTEM?
Palmetto's utilization of the Transco system will increase throughput and efficient
utilization of the system. We are aware of no negative effects of our interconnection.
WHAT IMPROVEMENTS, IF ANY, TO TRANSCO'S SYSTEM WILL BE
NECESSARY TO INTERCONNECT WITH PALMETTO ENERGY ?
A tap and metering station will need to be installed on the Transco mainline to
provide for delivery of natural gas.
WILL PALMETTO ENERGY BE RESPONSIBLE FOR THE COST OF
THOSE IMPROVEMENTS?
Yes. Palmetto Energy will be responsible
interconnection with the Transco pipeline.
for the costs associated with the
WILL THERE BE AN ADEQUATE SUPPLY OF GAS FOR THE FACILITY?
Yes. Gas is readily available in the market from numerous suppliers. As stated
- 25 -
supply contracts. Transportation arrangements will include firm transportation and
capacity purchased from secondary markets, including released firm, and interruptible
contracts. This structure is intended to provide the flexibility to transport gas from
multiple sources including U.S. Gulf Coast, the Appalachian Basin, and gas derived
from expanded LNG facilities on the East Coast.
6 Q. WHAT WILL BE THE EFFECT OF THE INTERCONNECTION OF
7 PALMETTO ENERGY WITH TRANSCO'S SYSTEM?
8 A. Palmetto's utilization of the Transco system will increase throughput and efficient
9 utilization of the system. We are aware ofno negative effects of our interconnection.
10 Q. WHAT IMPROVEMENTS, IF ANY, TO TRANSCO'S SYSTEM WILL BE
11 NECESSARY TO INTERCONNECT WITH PALMETTO ENERGY?
12 A. A tap and metering station will need to be installed on the Transco mainline to
13 provide for delivery of natural gas.
14 Q. WILL PALMETTO ENERGY BE RESPONSIBLE FOR THE COST OF
15 THOSE IMPROVEMENTS?
16 A. Yes. Palmetto Energy will be responsible for the costs associated with the
17 interconnection with the Transco pipeline.
18 Q. WILL THERE BE AN ADEQUATE SUPPLY OF GAS FOR THE FACILITY?
19 A. Yes. Gas is readily available in the market from numerous suppliers. As stated20
-25
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above, the contemplated gas infrastructure will have the capability of transporting gas
from numerous Gulf Coast and Appalachian gas producing Basins, as well as from
the newly expanded LNG facilities at Cove Point MD.
NON-ENERGY-RELATED STATE AND LOCAL BENEFITS
WHAT NON-ENERGY-RELATED
PALMETTO ENERGY CREATE?
ECONOMIC BENEFITS WILL
Palmetto Energy will create substantial non-energy related economic benefits for
York County and South Carolina. These benefits include:
Substantial contributions to the tax base while requiring only minimal
expenditures on infrastructure by the local government. State tax revenue, in
terms of both higher income and sales taxes, is expected to rise due to
increased economic activity as a result of the construction and operation of the
Facility. This increase in revenue, along with the sales and property taxes
directly paid by Calpine, will increase state and county tax revenue during the
construction period and during the first twenty years of operation;
Enhanced employment opportunities in the area: highly skilled employees to
operate the plant, approximately 400 construction workers during the two-year
construction period will result in substantial direct and indirect impacts of
Calpine's investment in the facility for the state. ; and
Besides the plant being located in Fort Mill, a major component of the plant,
the gas turbines, will be produced in Greenville, South Carolina;
- 26 -
above, the contemplated gas infrastructure will have the capability of transporting gas
from numerous Gulf Coast and Appalachian gas producing Basins, as well as from
the newly expanded LNG facilities at Cove Point MD.
NON-ENERGY-RELATED STATE AND LOCAL BENEFITS
5 Q. WHAT NON-ENERGY-RELATED ECONOMIC BENEFITS WILL
6 PALMETTO ENERGY CREATE?
7 A. Palmetto Energy will create substantial non-energy related economic benefits for
8 York County and South Carolina. These benefits include:
10
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Substantial contributions to the tax base while requiring only minimal
expenditures on infrastructure by the local government. State tax revenue, in
terms of both higher income and sales taxes, is expected to rise due to
increased economic activity as a result of the construction and operation of the
Facility. This increase in revenue, along with the sales and property taxes
directly paid by Calpine, will increase state and county tax revenue during the
construction period and during the first twenty years of operation;
16
17
18
19
Enhanced employment opportunities in the area: highly skilled employees to
operate the plant, approximately 400 construction workers during the two-year
construction period will result in substantial direct and indirect impacts of
Calpine's investment in the facility for the state.; and
20
21
Besides the plant being located in Fort Mill, a major component of the plant,
the gas turbines, will be produced in Greenville, South Carolina;
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HAS YORK COUNTY INDICATED ITS SUPPORT FOR THE
CONSTRUCTION OF PALMETTO ENERGY ?
Yes. Local civic and governmental leaders have actively supported the project.
Recently, Calpine is aware that business, community and local governmental leaders
have offered letters of support for the project to the PSC.
DOES THIS CONCLUDE YOUR TESTIMONY?
Yes.
- 27 -
I Q. HAS YORK COUNTY INDICATED ITS SUPPORT FOR THE
2 CONSTRUCTION OF PALMETTO ENERGY?
3 A. Yes. Local civic and governmental leaders have actively supported the project.
Recently, Calpine is aware that business, community and local governmental leaders
have offered letters of support for the project to the PSC.
6 Q. DOES THIS CONCLUDE YOUR TESTIMONY?
7 A. Yes.
27-