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HomeMy WebLinkAbout20060720IPC to MVP 10.pdfIDAHO POWER COMPANY O. BOX 70 BOISE, IDAHO 83707 RECEIVED 200& JUL I 9 PM~: 52An IDACORP Company IDAHO PUBLIC UTILITIES COMMISSION July 19 , 2006 Jean D. Jewell , Secretary Idaho Public Utilities Commission 472 West Washington Street P. O. Box 83720 Boise, Idaho 83720-0074 Re:Case No. IPC-06- Idaho Power Company s First Supplemental Response to the First Production Request of Mountain View Power, Inc. Dear Ms. Jewell: Please find enclosed for filing an original and two (2) copies of Idaho Power Company s First Supplemental Response to the First Production Request of Mountain View Power, Inc. regarding the above-described case. I would appreciate it if you would return a stamped copy of this transmittal letter to me in the enclosed self-addressed stamped envelope. Very truly yours 1f~~ (8. Monica B. Moen MBM:sh Enclosures Telephone (208) 388-2692, Fax (208) 388-6936, E-mail MMoenriYidahopower.com RECEIVED 200& JUL I 9 PH~: 52 BARTON L. KLINE ISB #1526 MONICA B. MOEN ISB #5734 Idaho Power Company P. O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-2682 FAX Telephone: (208) 388-6936 IDAHO PUBLIC UTILITiES COMMISSION Attorney for Idaho Power Company Street Address for Express Mail 1221 West Idaho Street Boise, Idaho 83702 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY FOR THE RATE BASING OF THE EV ANDER ANDREWS POWER PLANT. ) CASE NO. IPC-06- IDAHO POWER COMPANY' FIRST SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION REQUEST OF MOUNTAIN VIEW POWER, INC. COMES NOW, Idaho Power Company ("Idaho Power" or "the Company and, in response to the First Production Request of Mountain View Power, Inc. to Idaho Power Company dated June 19 , 2006, herewith submits the following supplemental information: IDAHO POWER COMPANY'S FIRST SUPPLEMENTAL RESPONSE TO FIRST PRODUCTION REQUEST OF MOUNTAIN VIEW POWER, INC. Page REQUEST NO.1 O. Please provide copies of all correspondence (written electronic or otherwise) from the Company to the Idaho Department of Environmental Quality (IDEQ) concerning MVP's minor source permit application filied January 31 2006 with respect to MVP's proposed Gateway power plant. RESPONSE TO REQUEST NO. 10: No correspondence (written electronic or otherwise) has been transmitted between the Company and IDEQ concerning MVP's proposed construction at the Gateway power plant. The response to this request was prepared by F. Gregory Hall, Principal Engineer, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney, Idaho Power Company. SUPPLEMENTAL RESPONSE TO REQUEST NO. 10: Please also refer to the November 2005 study conducted by Tetra Tech EM, Inc. on behalf of Idaho Power Company and attached hereto as "Response to Request No.1 0. DATED at Boise, Idaho , this 19th day of July, 2006. ~t. MONICA B. MOEN Attorney for Idaho Power Company IDAHO POWER COMPANY'S FIRST SUPPLEMENTAL RESPONSE TO FIRST PRODUCTION REQUEST OF MOUNTAIN VIEW POWER, INC. Page 2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 19th day of July, 2006 , I served a true and correct copy of the within and foregoing IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF MOUNTAIN VIEW POWER, INC. upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Hand Delivered Donovan Walker US. Mail Deputy Attorney General Overnight Mail Idaho Public Utilities Commission FAX 472 W. Washington (83702)Email: Donovan.walker(g)puc.idaho.gov O. Box 83720 Boise, Idaho 83720-0074 Industrial Customers of Idaho Power Hand Delivered Peter 1. Richardson, Esq.US. Mail Richardson & O'Leary Overnight Mail 515 N. 27th Street FAX O. Box 7218 Email: peter(g)richardsonandoleary.com Boise, Idaho 83702 Don Reading Ben Johnson Associates Hand Delivered 6070 Hill Road --.1L US. Mail Boise, Idaho 83702 Overnight Mail FAX Email: dreading(g)mindspring.com Mountain View Power, Inc.Hand Delivered Ronald L. Williams US. Mail Williams Bradbury, P.Overnight Mail O. Box 2128 FAX Boise, Idaho 83701 Email: ran (g) willi amsbradbury.com Robert D. Looper, President Hand Delivered Mountain View Power, Inc.US. Mail 1015 W. Hays Street Overnight Mail Boise, Idaho 83702 FAX Email: rlooper(g)spellc.com c8. Monica B. Moen CERTIFICATE OF SERVICE, Page IDAHO POWER COMPANY CASE NO. IPC-O6- FIRST PRODUCTION REQUEST OF MOUNTAIN VIEW POWER SUPPLEMENTAL RESPONSE TO REQUEST NO.1 0 \ '.."~, L~Et " . .~; .!~' !1rl ;;, REVIEW OF POTENTIALLY CRITICAL ENVIRONMENTAL ISSUES FOR PERMITTING ONE OF Two SIMPLE CYCLE COMBUSTION TURBINES AT ALTERNATIVE SITES ADA, CANYON, AND ELMORE COUNTIES I ) TETRA TECH EM INC. . . 1325AIRMOTIVE WAY, SUITE 200 RENO, NEVADA 89502 November 2005 CONFIDENTIA III~. SECTION IDAHO POWER COMPANY REVIEW OF POTENTIALLY CRITICAL ENVIRONMENTAL IsSUES ADA, CANYON, AND ELMORE COUNTIES, IDAHO CONTENTS PAGE EXECUTIVE SUMMARY ...........................,.....................,.......................".....,..........,.,...,...... INTRODUCTION ..............,..................,..........,.....,.....,........................,.............,.,...,.... IDAHO POWER SCREENING-LEVEL TURBINE DISPERSION MODELING RESULTS ......,............................................................,......................................,.........,, LAND DEVELOPMENT POLICIES FOR ADA, CANYON, AND ELMORE COUNTIES, IDAHO............................................,.........................................,............... ADA COUNTY......................,......,...........,.....................................,.......................... 9 CANYON COUNTY.................."........",................................................................, 3.2 ELMORE COUNTY".,.....,.,........,...........,..........,..................,..............".................. 16 REFERENCES......."..........."........................................,.............,....................,..............,........, TABLE FIGURE TABLES PAGE Idaho Power Screening Modeling Natural Gas Turbines................................................. 3 Idaho Power Screening Turbine Modeling Results, Class II Modeling Results NAAQS Impacts Using 7EA Turbine ............................................................................. 4 Idaho Power Screening Turbine Modeling Results, Class II Modeling Results NAAQS Impacts Using 501F Turbine.........,............... ........, .............. ........,.. ........ .......... 5 Canyon County 2003 Summary of Pollutant Concentrations .......................................... 1999 Emissions Summary of Criteria Air Pollutants..................................................... .. FIGURES PAGE NOx Spatial Representatives Canyon County Site........................................................... 6 NOx Spatial Representatives Ada County Site................................................................. 7 NOx Spatial Representatives Elmore County Site............................................................ 8 Ada County Site.............................,............,...........".,.............,...,............,........,............ Canyon County Site ....",................................................................................................ Elmore County Site.....",........,.............,............".........,.....,..................."...................... PAGE i IDAHO POWER COMPANY REVIEW 0 F POTENTIALLY CRITICAL ENVIRONMENTAL ISSUES ADA, CANYON, AND ELMORE COUNTIES, IDAHO EXECUTIVE SUMMARY Idaho Power Company is developing a plan for constructing a natural gas-fIred simple cycle combustion turbine to provide additional peaking power to the Idaho electric power grid. Three sites were chosen as alternatives for installing the gas-fired simple cycle combustion turbine. The purpose of this study is to review state and local requirements related to permitting issues for air quality, noise, and land use at three alternative sites in Ada, Canyon, and Elmore Counties in southern Idaho. The units selected as representing the range of options, included a Westinghouse 501 F and a General Electric 7EA. Manufacturer s specifications were obtained from similar projects. The scope of the project includes potential environmental impacts from the additional natural gas and electric transmission systems (if applicable). One of the tasks was to perform a screening level air quality impact analysis to ascertain the likelihood of complying with national and state ambient air quality standards. Tetra Tech EM Inc. (Tetra Tech) reviewed these sites using publicly available information. The Idaho Department of Environmental Quality was contacted about potential air quality permitting issues in each of the three counties. No environmental or special interest groups were contacted. Without specific lrnow ledge of any proposals, Tetra Tech prepared a review of potential constraints to permitting that could preclude or significantly delay the project at any of the proposed sites. Results of this investigation did not uncover any critical environmental issues that would significantly delay or prohibit the construction of a natural gas-fITed simple cycle combustion turbine at any of the three sites. Results of the air quality impact analysis shows that there should not be any exceedences of the ambient air quality standards PAGE 1 IDAHO POWER COMPANY REVIEW OF POTENTIALLY CRITICAL ENVIRONMENTAL IsSUES ADA, CANYON, AND ELMORE COUNTIES, IDAHO INTRODUCTION Idaho Power Company is developing a plan for constructing a natural gas-fired simple cycle combustion turbine to provide additional peaking power to the Idaho electric power grid. Three sites were chosen as alternatives for installing the gas-fired simple cycle combustion turbine. The purpose of this study is to review state and local requirements related to permitting issues for air quality, noise, and land use at three alternative sites in Ada, Canyon, and Ehnore Counties in southern Idaho. The units selected as representing the range of options, included a Westinghouse 501 F and a General Electric 7EA. Manufacturer s specifications were obtained from similar projects. The scope of the projects included potential environmental impacts from the additional natural gas and electric transmission systems (as applicable). Without specific knowledge of any proposals, Tetra Tech EM Inc. (Tetra Tech) prepared a review of potential constraints to pennitting that could preclude or significantly delay the project at one of the proposed sites. Tetra Tech reviewed these sites using publicly available information. The Idaho Department of Environmental Quality was contacted about potential air quality permitting issues in each of the three counties (Idaho Department of Environmental Quality, 2005). IDAHO POWER SCREENING-LEVEL TURBINE DISPERSION MODELING RESUL TS Tetra Tech completed the screening-level dispersion modeling for Idaho Power to evaluate potential criteria pollutant impacts from two turbine models at three different sites in Idaho. The modeling was completed using the ISCST3 model and included one year of meteorological data collected at the Boise, Idaho National Weather Service station during 1991. The modeling included effects from building downwash. Since specific source parameter and emission information were not available, comparable values were taken from other projects that used the same turbine models. Table 1 shows the stack parameter information used for each turbine model. Table 2 shows the model results for the 7EA at the three potential sites evaluated in the modeling. Table 3 shows the model results for the 501F at the three potential sites. The values in green represent the lowest modeled value for each pollutant and averaging period at each of the three sites. The values shown in Tables 2 and 3 represent the highest modeled values ITom the model output and do not take into account whether the impacts would fall on or off the facility property. All modeled impacts from the 7EA and 501F are low and any ofthe three sites would be acceptable should it be selected. The impacts from the 501F are slightly higher than the 7EA. Nitrogen oxide (NOz) is the only pollutant that had a modeled impact that exceeded the significant impact level, and only for the PAGEl IDAHO POWER COMPANY REVIEW OF POTENTIALLY CRITICAL ENVIRONMENTAL ISSUES ADA, CANYON, AND ELMORE COUNTIES, IDAHO 50 IF at the Elmore County site where the value was slightly above the annual significant impact level. (The "significant impact" level, also known as a de minimus, is the level at which no review is required under Environmental Protection Agency s (EP A) New Source Review or the Idaho Department of Environmental Quality) In the case of the Elmore County site with the 501F, the air quality impact for nitrogen oxides is 2.3 micrograms per cubic meter and the national ambient air quality standard is 100 micrograms per cubic meter. A spatial representation of the nitrogen oxide impacts for the three sites with the larger Westinghouse 501 F are shown in Figures 1 through 3. TABLE 1 IDAHO POWER SCREENING MODELING NATURAL GAS TURBINES Hourly Emission Rate (!!Is) Stack Stack Stack Stack Source UTM UTM Hei~ht Temp Velocity Diameter Name X(m)Y(m)(m)(K)(mls)(m)PM1o S02 NOx VOC 7EA Site Suecific 18.810.49.907 069 284 12.220 378 501F Site Specific 18.722.75.1.88 690 193 135 032 378 Notes: 7EA 501F f!/s mfs NOx PMlO S02 VOC UTM Y(m) X(m) General Electric 7EA Westinghouse 501 F Carbon monoxide Gram per second Meter Meter per second Nitrous oxides Particulate matter w/aerodynamic diameter less than 10 microns Sulfur dioxide Volatile organic compound Universal Transverse Mercator Coordinates Coordinates PAGE 3 ID A H O P O W E R C O M P A N Y RE V I E W O F P O T E N T I A L L Y C R I T I C A L E N V I R O N M E N T A L I s S U E S AD b C A N Y O N , A N D EL M O R E C O UN T I E S , ID A H O TA B L E 2 ID A H O P O W E R S C R E E N I N G T U R B I N E M O D E L I N G R E S U L T S CL A S S I T M O D E L I N G R E S U L T S , N A A Q S IM P A C T S U S I N G 7 E A T U R B I N E 7E A M o d e l e d C o n c e n t r a t i o n (l) (u f l l m NA A Q S Av e r a g i n g Si g n i f i c a n t I m p a c t Co n c e n t r a t i o n Po l l u t a n t Pe r i o d AD A C o u n t y S i t e El m o r e C o u n t Y S i t e Ca n v o n C o u n t y S i t e Le v e l (u ! ! l m (u 2 l m NO z An n u a l 10 0 PM I O 24 H o u r s 15 0 An n u a l 1 H o u r 19 . 72 . 20 0 0 40 , 00 0 8 H o u r s 6. 4 20 . 50 0 00 0 80 z 3 H o u r s 30 0 24 H o u r s 00 4 36 5 An n u a l 00 2 00 1 Oz o n e 1 H o u r nl a 23 5 (I ) M o d e l e d v a l u e s d o n o t i n c l u d e b a c k g r o u n d co n c e n t r a t i o n s . GR E E N v a l u e s r e p r e s e n t t h e l o w e s t m o d e l e d v a l u e o f t h e t h r e e s i t e s e v a l u a t e d . No t e s : 7E A p, g / m N/ A NM Q S NO z PM , o SO z Ge n e r a l E l e c t r i c 7 E A Mi c r o g r a m p e r c u b i c m e t e r Ca r b o n m o n o x i d e No t a p p l i c a b l e Ne v a d a A m b i e n t A i r Q u a l i t y S t a n d a r d s Ni t r o u s d i o x i d e Pa r t i c u l a t e m a t t e r w / a e r o d y n a m i c d i a m e t e r l e s s t h a n 1 0 m i c r o n s Su l f u r d i o x i d e PA G E 4 -- - / ID A H O P O W E R C O M P A N Y RE V I E W O F P O T E N T I A L L Y C R I T I C A L E N V I R O N M E N T A L IS S U E S AD A , C A N Y O N , A N D E L M O R E C O U N T I E S , I D A H O r. ,. TA B L E 3 ID A H O P O W E R S C R E E N I N G T U R B I N E M O D E L I N G R E S U L T S CL A S S n M O D E L I N G R E S U L T S , N A A Q S I M P A C T S U S I N G 5 0 1 F TU R B I N E 50 1 F M o d e l e d C o n c e n t r a t i o n (l) (u ! ! l m NA A Q S Av e r a ~ n ~ Si ~ n i f i c a n t I m p a c t Co n c e n t r a t i o n Po l l u t a n t Pe r i o d AD A C o u n t Y S i t e El m o r e C o u n t y S i t e Ca n v o n C o u n t y S i t e Le v e l (u ! ! l m (u ! ! l m N0 2 An n u a l 10 0 PM l O 24 H o u r s 1. 7 15 0 An n u a l 1 H o u r 25 . 21 7 . 20 0 0 00 0 8 H o u r s 10 . 4 27 . 50 0 00 0 80 2 3 H o u r s 1. 0 30 0 24 H o u r s 36 5 An n u a l Oz o n e 1 H o u r 2. 4 20 . 4 n/ a 23 5 (1 ) M o d e l e d v a l u e s d o n o t i n c l u d e b a c k g r o u n d c o n c e n t r a t i o n s GR E E N v a l u e s r e p r e s e n t t h e l o w e s t m o d e l e d v a l u e o f t h e t h r e e s i t e s e v a l u a t e d No t e s : 50 1 F Jl g / m N/ A NA A Q S N0 2 PM \ o 80 2 We s t i n g h o u s e 5 0 1 F Mi c r o g r a m p e r c u b i c m e t e r Ca m o n m o n o x i d e No t a p p l i c a b l e Ne v a d a A m b i e n t A i r Q u a l i t y S t a n d a r d s Ni t r o u s d i o x i d e Pa r t i c u l a t e m a t t e r w / a e r o d y n a m i c d i a m e t e r l e s s t h a n 1 0 m i c r o n s Su l f u r d i o x i d e PA G E 5 IDAHO POWER COMPANY REVIEW OF POTENTIALLY CRITICAL ENVIRONMENTAL ISSUES ADA CANYON, AND ELMORE COUNTIES, IDAHO FIGURE 1 IDAHO POWER, CANYON COUNTY SITE SPATIAL REPRESENTATION PLOT ESTIMATED NIJROGEN DIOXIDE CONCENJRATION 4844000 4842000 0.3 uglm3 25 uglm3 2 uglm3 4840000 4838000 4836000 Canyon County tlrbine location PAGE 6 4834000 4832000 4830000 524000 526000 528000 530000 532000 534000 536000 VIM Basting (meters) ..d ' . 1818' 4826000 4824000 4822000 4820000 lJ- bl) 4818000 4816000 4814000 4812000 IDAHO POWER COMPANY REVIEW OF POTENTIALLY CRITICAL ENVIRONMENTAL ISSUES ADA, CANYON, AND ELMORE COUNTIES, IDAHO FIGURE 2 IDAHO POWER, ADA COUNTY SITE SPATIAL REPRESENTATION PLOT ESTIMATED NIJROGEN DIOXIDE CONCENTRATION Ada O:mnty turbine locallon .6. 562000 564000 566000 568000 570000 572000 574000 6 uglm3 0.5 uglm3 4 uglm3 0.3 uglm3 0.2 uglm3 UTM Basting (meters) PAGE 7 IDAHO POWER COMPANY REVIEW OF POTENTIALLY CRITICAL ENVIRONMENTAL ISSUES ADA, CANYON, AND ELMORE COUNTIES, IDAHO 4788000 4786000 4784D00 fi' ';; 4782000 4780000 4778000 4776000 4774D00 FIGURE 3 IDAHO POWER, ELMORE COUNTY SITE SPATIAL REPRESENTATION PLOT ESTIMATED NI1ROGENDIOXIDE CONCENTRATION Elmore GolIDly \,; ~bine location "s;~;,; 596000 598000 600000 602000 604000 606000 608000 610000 2 uglm3 2 ugfm3 1.8 uglm3 1.6 uglm3 1.4 uglm3 1.2 uglm3 1 uglm3 8 uglm3 6 uglm3 4 ugim3 2 uglm3 U1M Basting (meters) PAGE 8 . '. ",--... IDAHO Po WER COMPANY REVIEW OF POTENTIALLY CRITICAL ENVIRONMENTAL IsSUES ADA, CANYON, AND ELMORE COUNTIES, IDAHO LAND DEVELOPMENT POLICIES FOR ADA, CANYON, AND ELMORE COUNTIES, IDAHO The following information regarding land development issues was prepared for the development of future sites. This information is based on potential areas of concern that may be applicable to the construction of a new facility for Ada, Canyon, and Elmore Counties, Idaho. This section focuses on land use, noise, air quality, natural resources, cultural and historical resources , and utility issues as they may apply to the future project(s) for each specific county. ADA COUNTY The ADA County site (Figure 4) is located at the base of a hill and adjacent to commercial and industrial development. There is a single residence within 1 mile of the facility that did not appear to be occupied. There is 240 kilovolt electric transmission line adjacent to the site that will significantly reduce additional environmental impacts from construction if there is sufficient capacity on that line to accommodate the new unit. FIGURE 4 ADA COUNTY SITE PAGE 9 IDAHO POWERCOMWANY REVIEW OF POTENTIALLY CRITICAL ENVIRONMENTAL IsSUES ADA, CANYON, AND ELMORE COUNTIES, IDAHO Land Use The Ada County Comprehensive Plan (or Comprehensive Plan) addresses a number of land use issues (Ada County Comprehensive Plan Update, 2005. http://www.adaweb.netidepartmentsl developmentservices/AdaCountyComPfehensive). The applicable policies and goals that may affect potential development are summarized below. Support public facilities, utilities, and transmission lines to serve all areas of Ada County. Require that new development be designed for compatibility with the natural environment taking into consideration the topography, drainage, and other natural systems. Applications for industrial development must conform to the adopted local, state and federal standards for air emissions; drainage systems; effects on neighboring land uses; employment characteristics; environmental impacts; fire and public safety; nature and volume of industrial activity; noise pollution; odor emissions; sewage collection and treatment; solid waste disposal; streets/roads/transportation; visual impacts; water quality; and utility services Lands designated for industrial use may be rezoned when a significant need for the land use change can be shown that will advance other goals of the Comprehensive Plan. Encourage commercial facilities at locations where they complement the existing transportation facilities and adjacent land uses. Noise The noise ordnance is principally aimed at air traffic and does not target any other specific projects. However, this noise limitation may set policy for other industrial activities including power generation facilities. The limits for airport noise range from 65 to 75 day-night weighted average noise level. Air Quality According to Mr. Bill Rogers at the Idaho Department of Environmental Quality, Ada County is maintenance area for particulate matter w/aerodynamic diameter less than 10 microns (PMlO) and carbon monoxide (CO). A maintenance plan indicates the air quality ambient monitoring data shows a trend toward non-attainment. However, there are cUITently no additional control requirements or emission offsets that would preclude development of power generations at the Ada County site. Idaho air quality is in attainment for CO, Ozone (1 hour), Ozone (8 hours), particulate matter w/aerodynamic diameter less than 2.5 microns (PMz.s), PMlO, sulfur dioxide (SOz), and lead (Pb) levels. Although the US. Environmental Protection Agency (EPA) Region 10 web site shows some non-attainment areas in the eastern Idaho area for CO and PMlO dated 2002, EP A did review and assessment for attainment and just published the results this year. Apparently the PAGE 10 IDAHO POWER COMPANY REVIEW OF POTENTIALLY CRITICAL ENVIRONMENTAL ISSUES ADA, CANYON, AND ELMORE COUNTIES, IDAHO , j Region 10 web site is not fully updated to reflect this change. No air quality summary table was available in electronic fonnat for ADA County. Ada County had the second highest number of reported releases of toxic pollutants. The EP A data show chemicals and electrical equipment had the highest number of releases in Ada County. Due to the size of the units in this investigation and the limitation of only natural gas as a fuel these units should not be subject to EP A Toxics Release Index (TRI) reporting. Natural Resources The following summarizes the goal statement and policies related to natural resources from the Ada County Comprehensive Plan: Retain the existing living, working, and natural environment by ensuring that land, air water, and wildlife resources are properly managed. Support infill development with a variety ofland uses and appropriate zoning designations to minimize development encroaching into natural resource areas. Buffer designated natural resource areas from more intensive urban uses with compatible transitional land uses. Establish density and development standards designed to protect existing terrain, steep slopes, benches, floodways, habitat areas, and ridge lines. Protect and preserve the natural beauty and habitat of the Snake River and land abutting the river and canyon. Protect and preserve the natural beauty and habitat of the Boise River and the black cottonwood forest and land abutting the river. Locate development away from designated wildlife habitat areas. Connect wildlife habitat areas by migration/movement corridors. Encourage preservation of existing healthy trees and rare plants throughout the County. Require all development to comply with applicable air quality standards. Cultural and Historic Resources The following summarizes the goal statement and policies related to cultural and historic resources from the Ada County Comprehensive Plan (Ada County Comprehensive Plan Update, 2005). To identify, protect, enhance, and perpetuate sites and structures that are significant components ofthe County's cultural, archeological, historical, agricultural, and architectural resources. Encourage the rehabilitation and retention of existing historic structures in Ada County. PAGE 11 IDAHO PO~R COMPANY REVIEW OF POTENTIALLY CRITICAL ENVIRONMENTAL IsSUES ADA, CANYON, AND ELMORE COUNTIES, IDAHO Establish a historic overlay zoning district with flexible development standards to allow convenient rehabilitation and multiple use of historic buildings and special sites within the County. Participate in the Idaho State Historical Society s Certified Local Government Program for historic preservation and improve interagency communication with all cities in the County and other community organizations regarding historic preservation. Support the Ada County Historic Preservation Council's role in identifying and inventorying all areas and sites that should be recognized and preserved. Require review of the exterior modifications to designated historic structures by the Historic Preservation Council to retain the historic character of such structures. Review proposed developments to determine if they would destroy or impact any unique geological or historical site and what steps may be needed to avoid or reduce negative impacts to the site. Consider incentives such as clustering and density bonuses for development that preserves historically or culturally significant sites or buildings. Encourage, enhance, and celebrate Ada County s ethnic and cultural diversity and heritage. Encourage activities and events that will celebrate the cultural heritage of Ada County. Encourage international cultural exchanges among individuals, organizations, and communities. Encourage cultural awareness through the creation and public exhibition of visual and performing arts. Assist community organizations in developing a sufficient variety of cultural facilities that meet the needs of all age groups and interests. Energy Services and Public Utility Facilities The following summarizes the goal statement and policies for energy services from the Ada County Comprehensive Plan. Coordinate with providers to develop plans for energy services and public utility facilities for the long-term energy and utility needs of Ada County. Promote the development of energy services and public utility facilities to meet public needs. Encourage the enhancement of the capacity and reliability of regional energy resources. Encourage the multiple-use of utility con-idors by utility providers. Develop a future acquisitions map for inclusion into the Comprehensive Plan that identifies existing and future utility facilities and corridors. PAGE 12 181 IDAHO POWER COMPANY REVIEW OF POTENTIALLY CRITICAL ENVIRONMENTAL ISSUES ADA, CANYON, AND ELMORE COUNTIES, IDAHO CANYON COUNTY The Canyon County site (Figure 5) is located at an existing site approximately 20 miles west of Boise adjacent to a sand and gravel operation and the Boise River. There is a new housing development (approximately 20 homes) within 1 mile of the site. This site has a good buffer ITom trees and there were not any obvious land use issues. The adjacent gravel operation may have an adverse affect on the modeling result when combined with the impact ITom a future generating unit. However, the site was previously permitted for a larger combined cycle unit and presumably would have included the gravel operation at that time. The emissions for the adjacent gravel operation were not included in the modeling contained in this report. There is an existing electric transmission line, and therefore visual impacts and potential natural resource impacts will be significantly less. FIGURE 5 CANYON COUNTY SITE Land Use Upon reviewing the Canyon County Comprehensive Plan (Canyon County 2010 Comprehensive Plan. October 20, 2005. http://www.canyoncounty.org/dsdlCompPlan.htm) and zoning ordinances there does not appear to be any specific prohibition against power generation. While we did not review the floodplain limits for the Boise River, a preliminary survey may be required to confinn that site is not within the floodplain. PAGE 13 IDAHO POWER COMPANY REVIEW OF POTENTIALLY CRITICAL ENVIRONMENTAL IsSUES ADA, CANYON, AND ELMORE COUNTIES, IDAHO Noise The Canyon County Zoning ordinance states that "unreasonable dust, smoke, gas, fumes, noise vibration, or odor beyond the boundaries" of the facility are not acceptable. The only other requirement for noise control would appear to be in Idaho Code 52-101 where an evaluation of the existing and projected noise pollution in the immediate and sUlTounding area is required. Air Quality Canyon County air quality is in attainment for all criteria pollutants. Canyon County has substantial residential growth as well as growth in the small to large industrial sector in the county. According to Mr. Bill Rogers at the Idaho Department of Environmental Quality,Canyon County might have to be considered for an air quality maintenance plan as a result of industrial growth. An air quality maintenance plan is required by the US EP A when an area that was previously designated as non-attainment for a particular criteria air pollutant and has been re-designated as attainment. The state can also develop a maintenance plan for an area to prevent it from becoming non-attainment as a result of growth. There are no CUlTent requirements that would preclude power generation at the Canyon County site. Table 4 summarizes the highest concentration of criteria pollutants and the number of exceedences for 2003. Table 5 summarizes emissions in Canyon County taken in 1999. Idaho air quality is in attainment for CO, Ozone (1 hour), Ozone (8 hours), PMZ.5, PMlO, SOz, and Pb levels (EP A 2005L Although the EP A Region 10 web site shows some non attainment areas in the eastern Idaho area for CO and PMlO dated 2002, EP A did a review and assessment for attainment and just published the results this year. Apparently the Region 10 site is not fully updated. TABLE 4 CANYON COUNTY 2003 SUMMARY OF POLLUTANT CONCENTRATIONS Second Highest Highest Number Stations NAAQS Recorded Recorded of NAAQS Monitoring Pollutant Standard Concentration Concentration Exceedances Pollutant Carbon monoxide hour average 35ppm 8ppm 6ppm hour average 9ppm 7 ppm 5 ppm Ozone hour average 12 ppm 08ppm 08 ppm hour average 08 ppm 07ppm 07ppm PM- 24-hour average 65 uglm 33 uglm 27 uglm Annual arithmetic mean 15 uglm 9 uglm 5 uglm PM- 24-hour average 150 uglm 176 uglm 87 uglm Annual arithmetic mean 50uglm 27 uglm 0 uglm Source: Canyon County. ZOOS. http://www.canyoncounty.org/dsdlCompPlan/ZOlO%ZOComp%ZOPlan%ZO-%ZOOct%ZOZO05.pdf. PAGE 14 IDAHO PO~R COMW ANY REVIEW OF POTENTIALLY CRITICAL ENVIRONMENTAL ISSUES ADA, CANYON, AND ELMORE COUNTIES, IDAHO TABLE 4 (Continued) CANYON COUNTY 2003 SUMMARY OF POLLUTANT CONCENTRATIONS Notes: ug/m NAAQS PM1O PM2.5 ppm microgram per cubic meter Nevada Ambient Air Quality Standards Particulate matter w/aerodynamic diameter less than 10 microns Particulate matter w/aerodynamic diameter less than 25 microns Part per million TABLE 5 1999 EMISSIONS SUMMARY OF CRITERIA AIR POLLUTANTS (Expressed in tons of pollutant emitted) Carbon monoxide Nitrol!: oxides PM-PM- Sulfur dioxide Volatile l!:anic com ounds obileSources 36.365 6.820 4.862 29.618 513 ea Sources 6.304 1.434 2.274 8.361 619 oint Sources 32 1.133 1.037 3.575 9461 sources 42 702 9 388 8 173 41 554 2 078 Source: Canyon County. 2005. http://www.canyoncounty.org/dsd/CompPlan/2010%20Comp%20Plan%20-%20Oct%202005.pdf 623 264 889 Notes: PM2.5 PMlO Particulate matter w/aerodynamic diameter less than 2.5 microns Particulate matter w/aerodynamic diameter less than 10 microns Canyon County had the nighest number of reported releases of toxic pollutants, followed by Ada County. The EP A data show food ( agriculture) had the highest releases in Canyon County. The dominant chemicals were ammonia and nitrates. Mr. Rogers indicated that housing and commercial development are replacing agriculture. This change would reduce the levels of ammonia and nitrates. Due to the size of the units in this investigation and the limitation of only natural gas as a fuel, these units should not be subject to TRI reporting. Natural Resources Specific infonnation on natural resources was not available. However, due to the proximity of the Boise River and riparian habitat there may be issues related to nesting for the birds in the area that will need to be addressed prior to and during construction. Cultural and Historic Resources Goal Statement and Policies No specific infonnation available on cultural or historic issues were available on the Canyon County web site Energy Services and Public Utility Facilities Goal Statement and Policies No specific infonnation available on the Canyon County web site PAGE 15 IDAHO POWER COMPANY REVIEW OF POTENTIALLY CRITICAL ENVIRONMENTAL ISSUES ADA, CANYON, AND ELMORE COUNTIES, IDAHO ELMORE COUNTY The Elmore County site (Figure 6) is located at the existing Evander Andrews Complex that contains two smaller Westinghouse simple cycle units. The area has a good buffer and does not appear to have any current conflicting land use. Surrounding land use includes a gravel operation, a highway maintenance facility, and agriculture. If the existing natural gas and electric transmission are adequate then the issues related to environmental clearances will be dramatically less. Under existing Idaho Administrative Procedures Act (IDAP A) and the federal New Source Review programs, an additional simple cycle unit can be added as a "synthetic minor" source if the emission of any criteria pollutant is less than 250 tons per year. FIGURE 6 ELMORE COUNTY SITE Land Use The proposed site in Elmore County is outside the city limits of Mountain Home and therefore would only be subject to Elmore County requirements. A variance for structures over 75 feet will be required. PAGE 16 IDAHO POWER COMPANY REVIEW OF POTENTIALLY CRITICAL ENVIRONMENTAL ISSUES ADA, CANYON, AND ELMORE COUNTIES, IDAHO Noise The only requirement for noise control is found in Idaho, Code 52-101. An evaluation of the existing and projected noise pollution in the immediate and surrounding area is required. Air Quality Elmore County air quality is in attainment for all criteria pollutants and there are no significant permitting issues according to Mr. Bill Rogers at the Idaho Department of Environmental Quality. Idaho air quality is in attainment for CO, Ozone (1 hour), Ozone (8 hours), PMz.s, PMlO, SOl, and Pb levels (EP A 2005). Although the EP A Region 10 web site shows some non-attainment areas in the eastern Idaho area for CO and PMlO dated 2002, EP A did a review and assessment for attainment and just published the results this year. Apparently the Region 10 site is not fully updated. Elmore County did not have any reported data for pollutants reported under TRI reporting requirements. Natural Resources No specific is information available Cultural and Historic Resources Goal Statement and Policies No specific information available Energy Services and Public Utility Facilities Goal Statement and Policies No specific information is available. Information was obtained from public conunents on construction of a coal-fIred energy plant in the Glenns Ferry Area (September 2004). A number of questions were raised about the project at that time. 1. What is the number of acre-feet of water that will be required to run the plant was asked during the legislative session. 2. A question was asked regarding the discussions with citizens and businesses that will be down wind from the coal burning power plant. 3. A doctor in Jerome was consulted by the legislature regarding clean coal technologies and down wind emissions. 4. A couple of questions were asked about the location of the plant in proximity to the coal load stations and if the coal that was going to be used would be local or brought in from other surrounding areas. PAGE 17 IDAHO POWER COMPANY REVIEW OF POTENTIALLY CRITICAL ENVIRONMENTAL ISSUES ADA, CANYON, AND ELMORE COUNTffiS, IDAHO REFERENCES Ada County Comprehensive Plan. 2005. Ada County Comprehensive Plan Update. On-Line Address: http://www.adaweb.net/departments/ developmentservices/ AdaCountyComprehensi ve Canyon County Comprehensive Plan. 2005. "2010 Comprehensive Plan." October 20 2005. On-Line Address: http://www.canyoncounty.org/dsd/CompPlanl201 0%20Comp%20Plan%20- %200ct%202005. pdf Idaho Department of Environmental Quality (IDEQ). 2005. On-Line Address: http://www.deq.state.id.us/air/prog issues.cfm IDEQ. 2005. Personal communication with Mr. Bill Rogers at the IDEQ regarding Ada County policy on particulate matter data collection. October 17 2005. US Environmental Protection Agency. 2005. Tetra Tech checked the Toxic Release Inventory releases for the three counties. On-line Address: http://www.epa.gov/triexplorer or http://www.epa.gov/cgi- binibroker?view=USST&trilib=TRIQl&S011= VIEW &s011 fmt=l&state=All+states&county= All+counties&chemical= ALL &industry=ALL&yeat=2003&tab rpt=l&f1d=RE TOLBY &ma pit=l& service=oiaa& Pfogram=xp tri.sasmacr.tristart.rnacro s. Environmental Protection Agency Region 10. 2005. "Air Quality Attainment." On-Line Address: http://yosernite.epa.gov/RIO/ AIRP AGE.NSF/webpage/Boise+PMl 0+ Attainment (http://www.epa.gov/ebtpages/airairqualityattainment.html PAGE 18