Berkshire Hathaway Energy
Alert # 3
Overview
This BHE Alert is one of 6 which you are receiving
as part of the Berkshire Hathaway Energy
Supplier and Utility Connect Program. This Alert
focuses just on BHE activities. The Power Alert
and GTRE Updates cover the range of generation
subjects for coal and gas turbine/reciprocating
engine projects.
The Fabric Filter, FGD & DeNox,
Precipitator, and Monitoring newsletters cover
specific technologies.
This month the FGD & DeNox newsletter provides
updates on the Hunter and Huntingto NOx projects
and details on dry scrubber systems at Mid
American plants. the monitoring newsletter
identifies a large number of BHE people involved
in water quality monitoring for NV Muddy River,
Pacificorp Hydro, Neal ultrapure water
Berkshire
Hathaway Energy companies are taking early
action to protect the environment by:
·
Investing $16
billion in wind and solar generation
·
Pursuing
fossil-fueled generation efficiency improvement
projects including NOx reduction at Hunter and
Huntington and CCR compliance at all coal pants
·
Investing in
new electricity transmission and distribution
equipment to reduce the loss of kilowatts and
improve reliability
·
Offering
programs that empower our customers to conserve
and manage their energy use, including energy
efficiency incentives, energy assessments and
smart metering
·
Working to
avoid methane and sulfur hexafluoride releases
from our gas and electricity transmission and
distribution operations
System to determine sustainability
impacts of BHE operations
Which is
better for the environment? Growing tomatoes
with the CO2 emitted from the Currant Creek
plant, saving 100 eagles, saving 10000 trout, or
re-routing a transmission line through a less
populated area? 30 universities around the world
have combined efforts to conclude that the earth
is greener now than it was a decade ago. They
say the cause is the same fertilization effect
of CO2 which causes it to
be used in greenhouses such as at the
Currant Creek plant.They caution that increased
CO2 may be better for those facing starvation
over the next decade or two but that the long
run consequences will be negative enough to
offset the short term benefits.
Sustainability indices are not very helpful in
answering these questions.. The fact that a
cigarette company such as Phillip Morris has a
better Dow Jones sustainability rating than
Berkshire Hathaway Energy indicates the need for
a better metric
There are
very complex sustainability ratings which
include intricate analysis of economic, social,
and political impacts of any action. They do not
quickly inform you whether action A is better
than action B. Cardinal
Health came to Mcilvaine for help because they
were losing a billion dollar single use surgical
gown market . Hospitals were concerned about the
CO2 created by manufacturing and disposing of
single use gowns.
Mcilvaine was tasked in making an
unbiased determination of the environmental
impacts of single use vs reusable garments.
By developing a common metric to measure
the negative effects of
CO2
emitted to the atmosphere vs the water
contamination from washing virus laden gowns,
the hospitals could more fairly determine the
environmental consequences of the alternatives.
The study
also concluded that the environmental
consequences have to include
tribal
values and equate all consequences based on
present
value. A hospital in Canada must weigh the
tribal values of its clientele. They could be
impacted by the viruses in the water immediately
but may
because of their location not suffer from global
warming.
Also the harm from viruses in the water
is immediate whereas the impact of global
warming is decades away.
Mcilvaine
expanded this research to help power plants
decide whether it is better to increase NOx to
reduce CO2, or create more of any pollutant
while reducing another. The result was a
common metric that measures the harm of any
pollutant in terms
of equivalent tons of
CO2. For example 10 tons of water saved
in a drought area is worth 1 ton of CO2
generated. In an area of water surplus
it takes 1000 tons of water saved to
equal 1 ton of CO2 generated.
The equations are all based on EPA
background documents weighing the benefits of
various regulations
The problem
with this approach is that it relies on EPA
determinations and does not make clear
how you evaluate the harm of killing 100 eagles
or running a transmission line through a
populated area.
Mcilvaine
next addressed the approach used by insurance
companies and the medical industry . It is based
on Quality Adjusted Life Years.
This approach emphasizes length of life
and not quality. If we never ate desserts, mixed
in crowds, rode in an automobile or played
sports we could live longer.
But who would rather live in solitary
confinement to age 90 when they could
enjoy 85 years of a full life. How do you
justify asking a solider to risk his life for
the sake of his country?
The answer to these questions is a metric
to measure life quality rather than life
quantity
The
Quality Enhanced life Days ( QELD)
metric allows you to measure every
initiative. In the case of the 100 eagles lost
in a National park area in Washington, the
factors become the number of visitors per year
and the relative enjoyment from seeing these
eagles.
In the case of the transmission line it
is the negative QELD for the people impacted by
one route vs another and the positive QELD from
the benefits of the transmitted power
QELD also
addresses tribal values and net present value.
The benefits of CO2 fertilization in the
short term are more important to starving people
in developing countries than to wealthy people
in developed countries.
QELD is a unique and powerful metric
which will aid Berkshire Hathaway in its
decisions and can be used by investors to view
the company in a more favorable light than with
the Dow Jones approach. More details on this are
shown at
Sustainability Universal Rating System
CCR activities of Berkshire Hathaway
All the BHE coal fired plants are moving forward
to meet the coal combustion redisiduals
requirements.
Details afe shown at
http://www.berkshirehathawayenergyco.com/ccr/ppw.html
Neal North
CCR Plan
On April 17, 2015, the Environmental Protection
Agency (EPA) issued the final version of the
federal coal combustion residuals rule (CCR
Rule) to regulate the disposal of CCR materials
generated at coalfired units. The rule is being
administered as part of the Resource
Conservation and Recovery Act (RCRA, 42 U.S.C.
§6901 et seq.), using the Subtitle D approach.
MidAmerican Energy Company (MEC) is subject to
the CCR Rule and as such has developed a
Fugitive Dust Control Plan for all sites
handling and disposing of CCR per 40 CFR 257.80.
This report provides the Fugitive Dust Control
Plan for the George Neal Station North (Neal
North) located near Sergeant Bluff, Iowa. This
Fugitive Dust Control Plan is in addition to,
not in place of, any other applicable site
permits, environmental standards, or work safety
practices.
Bottom ash and economizer ash is handled wet and
sluiced to CCR impoundments onsite. Since the
CCR is sluiced in a wet condition via pipeline
to site impoundments, there are no potential
fugitive dust sources in the handling of
bottom/economizer ash both at the source of the
CCR and at the discharge point in the
impoundments. MEC is currently evaluating
converting the system to dry handling; should
dry handling be implemented for any of the units
at Neal North, there will be an amendment to
this plan to address dust controls for drying
handling
North Valmy pond closure
The North Valmy Generating Station’s landfill is
subject to the closure requirements in the CCR
Rule because the landfill is classified as an
existing CCR landfill. The landfill is
considered as an existing CCR landfill because
it is an “area of land or excavation that
receives CCR” and it received CCR both before
and after October 19, 2015, the effective date
of the CCR Rule
The CCR unit will be closed in a manner that will
• “Control, minimize or eliminate to the maximum
extent feasible, post-closure infiltration of
liquids into the waste and releases of CCR,
leachate, or contaminated run-off to the ground
or surface waters or to the atmosphere;”
(§257.102(d)(1)(i)) – The final cover system
will control infiltration of liquid into waste
by meeting the permeability requirements listed
in the CCR Rule and by providing a final cover
surface that is graded to promote positive
drainage. Meeting the permeability requirements
in the CCR rule will limit the potential for
water to infiltrate through the cover and into
the underlying waste. Creating a final cover
surface that promotes the flow of water will
reduce the time available for water to
infiltrate through the cover and into the
underlying waste. – The final cover system will
control the release of CCR by covering exposed
CCR to limit contact with wind, water, and other
agents of erosion. Armoring, compaction, and/or
other erosion control measures may be provided
in areas more susceptible to water or wind
erosion. Drainage and sediment control
structures may be installed to collect and/or
detain eroded CCR. – By limiting the amount of
water coming into contact with CCR, the measures
for controlling infiltration of liquid into
waste will also serve to limit the amount of
water available to create leachate and the
amount of leachate generated. Controlling and
reducing the amount of leachate generation will
in turn control the release of leachate. – By
limiting the amount of water coming into contact
with CCR
Jim Bridger will require new pond
liner
The PacifiCorp Jim Bridger Power Plant is a
coal-fueled steam-electric operation with four
operating units having a total generating
capacity of 2.12 GW, and is located
approximately nine miles northeast of Point of
Rocks, Wyoming. . FGD Pond 2 is a zero discharge
facility and generally evaporates water at the
same rate it is disposed of in this pond. It
does not have a spillway, or outlet structure.
The inlet structure consists of two, 10-inch
diameter HDPE pipelines which can discharge at
various points along the southern side of the
pond. Seepage from the current FGD Pond 2 has
created a groundwater plume beneath the general
area of the disposal ponds (FGD Ponds 1 and 2).
This plume is presently controlled by a series
of groundwater pump back wells which discharge
the pumped water back into FGD Pond 2.
The FGD Pond 2 does not meet the requirements of
§257.71 – Liner design criteria for existing CCR
surface impoundments, due to absence of an
installed geomembrane liner and compacted clay
soil liner. The Rule states that existing CCR
surface impoundments are considered unlined if
“the owner or operator of the CCR unit fails to
document whether the CCR unit was constructed
with a liner that meets the requirements of
paragraphs (a)(1)(i), (ii), or (iii).”
