1. Greatly increased CO, NOx and particulates pollution due to a proposed 1000MW gas-fired power plant to be located 2 km from Gatton, a small Australian Town.

According to Naturalgas.org [1], the fossil fuel-derived pollutant emissions levels (in pounds per Btu of energy input) are as follows (noting that this is for average gas burning and not specifically for gas-turbine power stations):

for CO2: 117,000 (gas), 164,000 (oil) and 208,000 (coal);

for CO: 40 (gas), 33 (oil) and 208 (coal);

for NOx: 92 (gas), 448 (oil) and 457 (coal);

for sulphur dioxide (SO2): 1 (gas), 1,122 (oil), and 2,591 (coal);

for particulates (fine soot): 7 (gas), 84 (oil) and 2,744 (coal); and

for mercury (Hg): 0.000 (gas), 0.007 (oil) and 0.016 (coal).

Gatton has a population of 5,295 and Australia a population of 23.0 million. According to the US Energy Information Administration, in 2012 Australian petroleum consumption was 1,045.6 thousand barrels per day i.e. 1.046 million (M) barrels per day [2]. 1 barrel of oil combusts to yields 0.433 tonnes (t) CO2 [3]. Thus in 2012 Australia produced 1.046 Mt CO2 per day x 0.433 t CO2 per barrel x 365 days per year = 165.3 Mt CO2. Gatton’s notional share of this pollution was 5,295 x 165.3 Mt CO2/23.0 M = 38,055 t CO2/year.

These days in the US gas-fired power stations on average produce about 0.475 t CO2 /MWh (versus the current 1.4 t CO2/MWh for coal-fired power stations and the 0.6-0.7 t CO2/MWh for the GFPP). Accordingly a 300 MW gas-fired power station operating at a capacity factor of 0.2 (i.e. only operating at 20% of full annual capacity) would produce 0.475 tCO2 per MWh x 300 MW x 0.2 (capacity factor) x 365 days per year x 24 hours per day = 249,660 t CO2/year.

Using the data tabulated above, we can estimate that Gatton’s current oil-derived annual pollution would be 38,055 t CO2 x 33t CO/ 164,000 t CO2 = 7.65 t CO; 38,055 t CO2 x 448t NOx/ 164,000 t CO2 = 104.0 t NOx; 38,055 t CO2 x 1,122t SO2/ 164,000 t CO2 = 260.4 t SO2; and 38,055 t CO2 x 84 t particulates/ 164,000 t CO2 = 19.5 t particulates.

We can then estimate the pollutant production from (A) a proposed 300 MW gas-fired power plant operating at 20% capacity, from (B) a 1000 MW gas-fired power plant operating at a realistic 90% of capacity, and from (C) a 1,000 MW gas-fired pant operating at 100% capacity, as set out below.

This analysis ignores the specific Gatton GFPP characteristics, and partial removal and dispersion of specific pollutants by the proposed plant. Further, the translation of increases in pollutant production to increases in actual ground level pollutant concentration is complicated by multi-factorial environmental pollutant removal kinetics.

However, given that CO production from gas burning is 1.2 times that from oil-burning (see above data) and ignoring effects of the GFPP stack and other specifics, increases in CO production in Gatton due to the proposed gas-fired power plant can be reasonably equated with the same increase in CO production due to a corresponding increase in vehicular traffic.

(A) 300 MW & 20% capacity factor scenario.

The extra pollution from a 300MW gas-fired power station operating at only 20% of capacity would be 249,660 t CO2 x 40 t CO/117,000 tCO2 = 85.4 t CO; 249,660 t CO2 x 92 t NOx/117,000 tCO2 = 196.3 t NOx; 249,660 t CO2 x 1 t SO2/117,000 tCO2 = 2.13 t SO2; and 249,660 t CO2 x 7 t particulates /117,000 tCO2 = 14.9 t particulates.

Accordingly, with a 300 MW gas-fired power station operating at 20% capacity factor, Gatton’s pollution would increase from 7.7t CO to 93.1 t CO (i.e. 12.1 times for CO), from 104.0 t NOx to 300.3 t NOx ( i.e. 2.9 times for NOx) ; from 260.4t SO2 to 262.5tSO2 (i.e. very little for SO2); and from 19.5 t particulates to 34.4 t particulates (i.e. 1.8 times for particulates).

Currently in a similar but larger Queensland town (Toowoomba) the mean ground level CO, NOx and particulates (PM2.5) concentrations are roughly 11.5%, 25.1% and 81.3% of the air quality maximum, respectively, and the estimated increases of 12.1, 2.9 and 1.8 times due to a 300 MW/20% capacity factor gas-fired power station would make ground level CO, NOx and particulates concentrations reach 139%, 73% and 146.3% of the health maxima, respectively (if one ignores plant-based pollutant reduction and huge non-linear environmental pollutant removal kinetics) – clearly worrisome from a human health perspective.

These calculations ignore the specifics of the GFPP proposal, its pollution amelioration systems and environmental pollutant removal kinetics. However one can reasonably say that since gas burning-derived CO production is 40/33 = 1.2 times greater than for oil burning–based CO production (see above) and ignoring the effects of the WPP stack, the above estimates indicate that the addition of the CO from a 300 MW power station operating at 20% capacity factor would be like increasing the CO impact equivalent to increasing the vehicular traffic in the small town of Gatton by a factor of 1.2 x 12.1 = 14.5-fold.

(B) 1000 MW & 90% capacity factor scenario.

It is envisaged that the gas-fired power station would increase to 1000 MW and with Queensland’s huge gas resources one could readily envisage the capacity factor increasing to the 90% obtaining for a baseload power station [29]. With this scenario, the extra CO2 pollution would be 0.475 t CO2 per MWh x 0.9 (capacity factor) x 1,000 MW x 365 days per year x 24 hours per day = 3,744,900 t CO2/year.

Accordingly, the extra pollution from a 1000 MW gas-fired power station operating at 90% of capacity would be 3,744,900 t CO2 x 40 t CO/117,000 tCO2 = 1,280.0 t CO; 3,744,900 t CO2 x 92 t NOx/117,000 tCO2 = 2,944.7 t NOx; 3,744,900 t CO2 x 1 t SO2/117,000 tCO2 = 32.0 t SO2; and 3,744,900 t CO2 x 7 t particulates /117,000 tCO2 = 224.1 t particulates.

Thus, for a 1000 MW gas-fired power station operating at 90% capacity factor, Gatton’s annual pollutant production would increase from 7.7t CO to 1,287.7t CO (i.e. 167.2 times for CO), from 104.0 t NOx to 3048.7t NOx ( i.e. 29.3 times for NOx) ; from 260.4t SO2 to 292.4 tSO2 (i.e. again very little increase for SO2); and from 19.5 t particulates to 243.6 t particulates (i.e. 12.5 times for particulates).

Thus, for example, given that gas burning-derived CO production is 40/33 = 1.2 times greater than for oil burning–based CO production (see above), the above estimates indicate that the effect of a 1000 MW power station operating at 90% capacity factor would be like increasing the CO impact equivalent to increasing the vehicular traffic in the small town of Gatton by a factor of 1.2 x 167.2 = 200.6-fold.

Again one observes that currently in a similar but larger Queensland town (Toowomba) the mean ground level CO, NOx and particulates (PM2.5) concentrations are roughly 11.5%, 25.1% and 81.3% of the air quality maxima, respectively, and the estimated increases in pollution output of 167.2, 29.3 and 12.5 times due to a 1000 MW/90% capacity factor gas-fired power station raise concerns that ground level CO, NOx and particulates concentrations might reach 1,922.8%, 735.4% and 1,016.3% of the health maxima, respectively (if one ignores plant-based pollutant reduction and non-linear environmental pollutant removal kinetics) - worrisome from a human health perspective.

(C) 1000 MW & 100% capacity factor scenario.

For a 1000 MW gas-fired power station operating at 100% capacity factor, the extra CO2 pollution would be 0.475 t CO2 per MWh x 1.0 (capacity factor) x 1,000 MW x 365 days per year x 24 hours per day = 4,161,000 t CO2/year.

Accordingly, the extra pollution from a 1000MW gas-fired power station operating at 100% capacity would be 4,161,000 t CO2 x 40 t CO/117,000 tCO2 = 1,422.6 t CO; 4,161,000 t CO2 x 92 t NOx/117,000 tCO2 = 3,271.9 t NOx ; 4,161,000 t CO2 x 1 t SO2/117,000 tCO2 = 35.6 t SO2; 4,161,000 t CO2 x 7 t particulates/117,000 tCO2 = 248.9 t particulates.;

Thus, for a 1000 MW gas-fired power station operating at 100% capacity factor, Gatton’s annual pollution would increase from 7.7t CO to 1,430.3 t CO (i.e. 185.8 times for CO), from 104.0 t NOx to 3,375.9 t NOx ( i.e. 32.5 times for NOx) ; from 260.4t SO2 to 296.0 t SO2 (i.e. again very little increase for SO2); and from 19.5 t particulates to 268.4 t particulates (i.e. 13.8 times for particulates).

Again one observes that currently in a similar but larger Queensland town (Toowoomba) the mean ground level CO, NOx and particulates (PM2.5) concentrations are already roughly 11.5%, 25.1% and 81.3% of the air quality maxima, respectively, and the estimated increases of 185.8, 32.5 and 13.8 times due to a 1000 MW/100% capacity factor gas-fired power station could make ground level CO, NOx and particulates concentrations reach 2,136.7%, 815.8% and 1,121.9% of the health standard maxima, respectively (this ignoring the industrial containment and environmental dispersion specifics of the WPP) – clearly a worrisome risk from a human health perspective.

Given that gas burning-derived CO production is 1.2 times greater than for oil burning–based CO production (and ignoring the WPP stack and other specifics), the impact of a 1000 MW gas-fired power station would be like increasing the CO impact equivalent to increasing the vehicular traffic in the small town of Gatton by a factor of 1.2 x 185.8 = 223.0-fold.

It must be critically reiterated that the translation of these huge estimated annual increases in CO, nitrogen oxides (NOx), and particulates pollution in Gatton due to a gas-fired power station to ultimately increased average ground-level pollutant levels is a complex, multivariable matter. The above calculations are based on average data for gas burning rather than on the specific technical details of the WPP scheme and the estimated baseline Gatton pollutant data assume that oil-based burning by vehicles is the major pollutant source.

That said, proponent's theoretical projections involving dispersion modelling based on complex and unclear assumptions are grossly insufficient – the onus should be on the proponents to provide empirical data from existing gas-fired power plants as to CO, nitrogen oxides (NOx), and particulates pollution (in tonnes per year) and the ultimate rigorously predicted outcome in terms of ground-level pollution (in μg/m³) of CO, nitrogen oxides (NOx), and particulates (noting that explicit data on expected ground-level particulate pollution is notably lacking from the GFPP proposal and from world-wide data). Critically, the WHO states that “no threshold for PM has been identified below which no damage to health is observed” [4].

D. CO, NOx and particulates pollution from a GFPP.

Simple analysis of a notional gas-fired power plant proposal for the outskirts of a rural valley town in South East Queensland (ignoring GFPP specifics) reveals that the initial proposal of an up to 1000 MW plant operating as a “standby” or “peaking” power provider could significantly increase generated CO, NOx and particulates pollution with concerns (depending upon the industrial mitigation or environmental dispersion and dissipation of such pollution) that it might go above or near the health standard maxima and that the CO pollution impact could be equivalent to that from increasing vehicular traffic in Gatton by a factor of over 200-fold.

From the perspective of human impact it is important to consider the annual pollution in Gatton due to oil burning in comparison with that estimated by the Proponents to be produced by the GFPP (1000MW, 20% CF). My estimations of pollution just from oil burning in Gatton are as follows (Proponent -estimated GFPP emissions are given in parentheses; all data in tonnes per year): 7.7 CO (177.0), 104.0 NOx (904.1), 19.5 PM (145.2), 260.4 SO2 (43.5) and 38,0555 CO2 (874,202) i.e. the GFPP at 1000 MW and 20% CF would increase annual pollution emission (i.e. ignoring dispersion) in the town of Gatton by factor of 26.0 times for CO, 9.7 times for NOx, 8.4 times for PM, 1.2 times for SO2 and 24.0 times for CO2.

In a March 2013 report, Dr Stephanie Shaw of the Electric Power Research Institute (EPRI) commented on the limited amount of information available on pollution from gas extraction and utilization in power plants: “Although very limited data exist regarding exposure and toxicity issues related to natural gas extraction activities and combustion in power plants, some general conclusions can be drawn. Due to shorter stacks and lower-temperature flue gas than for coal-fired plants, as well as higher likelihood of being located in more densely populated areas, natural gas–fired power plant plumes may be more susceptible to downwash, less dispersion, and thus potentially higher population exposures near a facility. The review of emissions suggests ultrafine particles may be emitted in high particle number from natural gas power plants; some evidence does exist that certain types of ultrafine particles have an independent role in human health impacts and are perhaps more of a health concern than larger particles. However, this would have to be determined on a facility-by-facility basis, with measurements and modeling” [5].

Even if pollution mitigation and dispersion modeling for the specific WPP scheme asserts low CO, NOx and particulate pollution near the plant, much of the pollution has to end up somewhere, variously with deleterious consequences. Further, the precautionary principle indicates that such a power station not be located right next to an urban area, and that hard empirical data is required for such pollution for turbine-based gas-fired power stations at 200-1000 MW, operating at capacity factors from 20% to 100% and in different modes e.g. new and old, start-up or continuous operation (noting that pollution can be much greater in the start-up mode of such plants which are indeed intended for rapid, needs-based start-up and shut-down) [6].

E. CO, NOx and particulates pollution with a 1000 MW gas-fired plant at 90% capacity factor.

The adumbrated expansion to 1000 MW generating capacity and the possibility of full-on operation at 90% of maximum capacity (in view of Queensland’s huge exploitation of coal seam gas resources and misplaced bipartisan enthusiasm for a mistaken coal-to-gas conversion route) would be associated with estimated increases of CO, NOx and particulates pollution outputs over existing pollution by factors of 167.2, 29.3 and 12.5 times, respectively, increases that would be translated into unacceptably huge ground-level pollution increases if one ignores specific GFPP-based pollutant mitigation and non-linear environmental pollution removal kinetics - a worrisome scenario. Noting these GFPP-specific industrial and environmental pollutant removal qualifications, the CO pollution impact alone could be equivalent to that from increasing vehicular traffic in Gatton by a factor of over 200-fold.

F. Concerns over fine particulates pollution.

World-famous environmentalist Professor David Suzuki has drawn attention to fine particulates produced by gas-fired power plants: “Possibly more troubling are the emissions of fine particulates from gas-fired power plants. Though particulate emissions are about ten per cent of those produced by coal power, the U.S. Environmental Protection Agency estimates that 77 per cent of particulates from natural gas plants are dangerously small. These fine particulates have the greatest impact on human health because they by-pass our bodies' natural respiratory filters and end up deep in the lungs. In fact, many studies have found no safe limit for exposure to these substances” [7]. It is readily determined for a notional 1000 MW gas-fired power station operating at 90% capacity (and ignoring GFPP specifics) that particulates output could increase by a factor of about 12.5 (section E). Fine particulates have been measured in GFPP working areas [8], a worry in view of the absence of a threshold for toxicity of fine PMs [4, 9].

The key concern in addition to landscape, the environment (including global warming) , cost (including health, asset revaluation and climate change action costs), and human amenity, is human health. The WHO has set out Air Quality and Health Guidelines [4] and in the absence of relevant, documented, hard, empirical data I am not satisfied that the GFPP scheme operating at 1000 MW and 90% capacity will not violate these guidelines to the detriment of the people of Gatton, Lockyer Shire and Queensland.

In particular, the WHO Guidelines [4] specify the following pollution limits:

(a) for particulate matter (PM):

“PM_2.5

10 μg/m³ annual mean

25 μg/m³ 24-hour mean

PM₁₀

20 μg/m³ annual mean

50 μg/m³ 24-hour mean

The 2005 AQG set for the first time a guideline value for particulate matter (PM). The aim is to achieve the lowest concentrations possible… no threshold for PM has been identified below which no damage to health is observed.”

(b) for NO2 (that post-emission can generate dangerous particulates):

“40 μg/m³ annual mean

200 μg/m³ 1-hour mean”.

To reiterate, US analyst Jennifer Seinfeld [5] states that “Various environmental approvals and permits (or changes to current permits) for electric utilities are needed for construction and operation of gas-fired generation and for a new (or larger) gas pipeline. A particularly challenging environmental issue for permitting new gas-fired generation is demonstrating compliance with the new short-term one-hour National Ambient Air Quality Standard for nitrogen dioxide (NO2). Because it is a short-term standard, worst-case hourly emission rates from the operation of the plant (e.g., start-up conditions of the gas-fired generation equipment, emergency equipment) must be used in assessing compliance [my emphasis]. The National Ambient Air Quality Standard for PM2.5 (particulate matter less than 2.5 microns in diameter) 24-hour and annual National Ambient Air Quality Standard also can be problematic, depending on the background concentrations of PM2.5 in the area. Conducting analyses to assess compliance with these standards should be part of the due diligence”. Seinfeld’s data indicate that for normal operation of a 195 MW natural gas-fired combustion turbine/combined-cycle (CT/CC) plant.(stack height 125 feet; NOx emission rate 14 lb/hr; annual emissions 55.6 t) the modeled 1-hour impact is 5 μg/m³ that added to a background of 88 μg/m³ has an impact of 93 μg/m³ as compared to a National Ambient Air Quality Standard (NAQS) of 188 μg/m³. (One supposes that a 1000 MW plant would yield a 1-hour impact of 25.6 μg/m³ and hence an overall impact of 113.6 μg/m³ ). However start-up conditions of the 195 MW plant would yield a modeled impact of 256 μg/m³ which with the background of 88 μg/m³ yields a total of 353 μg/m³, nearly twice the NAQS limit of 188 μg/m³. [6].

G. Ultimate destination of NOx and other pollutants.

Of course, the net CO, NOx, and particulate emissions from a gas-fired power station stack end up somewhere, and even if technically minimized in the immediate vicinity of the plant, they simply end up adding to pollution elsewhere (for further discussion see [9].

H. The World Health Organization (WHO) safety limits and empirical testing.for ground level CO, NOx and PM.

The World Health Organization (WHO) safety limits for ground level CO, NOx and PM.(e.g. PM10 are less than 10 micrometer in diameter) in micrograms per cubic meter are 10,000 for CO (8 hour mean), 40 for NOx (annual mean), 10 for PM2.5 (annual mean) and 20 for PM10 (annual mean) [4]. However observed levels of CO, NOx and PM10 in a typical urban area can be 20%, 35% and 75%, respectively, of these safety limits in the absence of a 1,000 MW GFPP. Given the enormously increased additional output pollution produced by such a GFPP (see above) there is a real fear than these safety limits will be exceeded, this reinforcing the crucial demand that ground level pollution in the vicinity of similar GFPPs should be determined. These standards are routinely exceeded in Beijing [10]. Further to the above concerns about safety limits being exceeded, one notes that human beings are different and some people (e.g. asthmatics and those suffering from chronic obstructive pulmonary disorder (COPD)) may be particularly susceptible to pollutants produced by a GFPP [11]. For further discussion see [12].

References.

[1]. Natural gas.org, “Natural gas and the environment”: http://www.naturalgas.org/environment/naturalgas.asp .

[2]. Australia, US Energy Information Administration: http://www.eia.gov/countries/country-data.cfm?fips=as .

[3]. “How much CO2 produced from burning 1 barrel of oil”, Wikianswers: http://wiki.answers.com/Q/How_much_CO2_produced_by_burning_one_barrel_of_oil .

[4]. WHO, “Air Quality and Health”:http://www.who.int/mediacentre/factsheets/fs313/en/ .

[5]. Dr Stephanie Shaw, Electric Power Research Institute (EPRI), “Air quality impacts from natural gas extraction and combustion”, Power, 13 March 2013: http://www.powermag.com/environmental/Air-Quality-Impacts-from-Natural-Gas-Extraction-and-Combustion_5417.html .

[6]. Jennifer Seinfeld, “Switching to gas… getting that air permit may not be so easy”, Public Power, January-February 2011: http://www.publicpower.org/Media/magazine/ArticleDetail.cfm?ItemNumber=30465 .

[7]. David Suzuki, “Natural gas”, David Suzuki Foundation: http://www.davidsuzuki.org/issues/climate-change/science/energy/natural-gas/ .

[8]. Hicks JB, McCarthy SA, Mezei G, Sayes CM, “PM1 particles at coal- and gas-fired power plant work areas”, Ann Occup Hyg. Mar;56(2):182-93 (2012).

[9]. US Centres for Disease Control and Prevention, “Health impacts of fine particles in air”, 17 April 2012: http://ephtracking.cdc.gov/showAirHIA.action .

[10]. Greening Beijing: http://www.unep.org/sport_env/documents/beijingreport07/chapter5.pdf .

[11]. The Lung Association, “Pollution & air quality”: http://www.lung.ca/protect-protegez/pollution-pollution/outdoor-exterior/index_e.php .

[12]. Gideon Polya, ““Expert Witness Testimony to stop gas-fired power plant installation”, Countercurrents, 14 June 2013: http://www.countercurrents.org/polya140613.htm .