Tuesday, September 17, 2024
The Lake Granbury Conference Center was abuzz Monday evening, Sept. 9, as residents gathered for a public hearing regarding the proposed expansion of the Wolf Hollow II power plant.
Senator Brian Birdwell was represented by staff members Shelley Verlander and Clinton Harnon, who were present to address concerns and provide support.
Additionally, numerous Hood County elected officials attended the event. The conference center room was packed with concerned citizens, signaling a high level of community engagement, which was evident throughout the tense and charged discussion.
The panel on stage was comprised of five TCEQ employees, including the moderator, Lori Garris, and three Constellation employees.
TCEQ organized the meeting to gather public feedback on a permit application submitted to the TCEQ by Wolf Hollow II Power LLC.
THE APPLICATION
The applicant, Wolf Hollow II, is a 1,115-megawatt combined cycle gas and steam turbine power plant in Hood County. They are planning a significant expansion.
Constellation owns and operates the facility, which began operations in 2017. It has filed with the Texas Commission on Environmental Quality (TCEQ) to add 300 megawatts of new gas-fired generation capacity.
This expansion, referred to as Wolf Hollow III, will include the installation of eight new natural gas-fired generators, three emergency diesel generators, and additional equipment to meet Texas’ rising energy demands.
POTENTIAL IMPACT OF AIR QUALITY
Many complex pollutants were discussed at the meeting, and they can be further studied at the Environmental Protection Agency’s and the American Lung Association’s websites.
EPA.gov details the effects of nitrogen oxide and ozone formation, as well as sulfur dioxide and particulate matter, on the human body. The ALA site, www.lung.org, outlines the health hazards of volatile organic compounds and smog.
The new generators are expected to introduce potentially harmful pollutants into Hood County’s air, as outlined in the Notice of Application and Preliminary Decision for Air Quality Permits Proposed Air Quality Permit Numbers: 175173, PSDTX1636, and GHGPSDTX238 which can be viewed online at 2024-09-09-wolf-hollow-ii-power-llc-175173-psdtx1636-ghgpsdtx238-napd-pm.pdf (texas.gov) Some of the chemicals listed include nitrogen oxides (NOx), carbon monoxide (CO), particulate matter (PM), and greenhouse gases (GHGs) such as carbon dioxide (CO2).
These chemicals can have serious side effects. NOx contributes to ozone formation, triggering asthma attacks and respiratory issues. At the same time, particulate matter, especially the fine PM2.5 particles, poses long-term health risks by affecting lung and heart function.
Additionally, volatile organic compounds (VOCs) and sulfur dioxide (SO2), though emitted in smaller quantities, can aggravate air quality problems, increasing the likelihood of smog and acid rain.
Currently, Hood County is classified as an “attainment” area, meaning air pollution levels meet national standards. It is alledged the expansion could push some pollutants above safe thresholds, mainly if the plant operates at higher capacities in the future.
While the current application assumes the new generators will operate at 40% capacity, there are concerns about what might happen if Wolf Hollow III increases its output to 50% or beyond to meet growing energy needs. Higher operation levels could lead to significantly increased emissions, potentially harming air quality and posing health risks to residents.
RESIDENTS’ CONCERNS
Some Hood County residents strongly opposed the expansion, raising numerous environmental and health concerns. Alana Brown and her daughter Christiana articulated fears about the potential negative impacts on children’s health, including noise and air pollution issues. “We’re worried about long-term effects like learning disabilities and cognitive problems,” said Christiana Brown.
Daniel Lakey, a resident of Contrary Creek, criticized the expansion as excessive for the predominantly residential area, questioning the reliability of pollution monitoring and expressing frustration with local political representatives.
Dr. Andrew J. Wolford raised concerns about the adequacy of pollution dispersion modeling and environmental impact assessments, calling for a more thorough review and consideration of alternative sites.
Dave Eagle, Commissioner for Precinct 4, highlighted concerns about the plant’s business relationship with MARA, formerly Marathon, pointing out potential legal and added health risks.
Shanice Copenhager, a parent with asthma, voiced opposition to the permit due to worries about particulate matter and volatile organic compounds that Wolf Hollow III will emit.
REGULATORY REVIEW AND ENVIRONMENTAL ANALYSIS
Wolf Hollow II’s permit application has triggered a series of environmental reviews. The TCEQ is assessing whether the proposed expansion will comply with state and federal air quality regulations, including the National Ambient Air Quality Standards (NAAQS).
TCEQ’s notice of application and preliminary decision for air quality permits — Example A— can be viewed online at www. Tceq.texas.gov/downloads/agency/decisions/hearings/notices/2024.
The document presents initial studies conducted by the company, which suggest that while emissions will increase, the project is not expected to violate NAAQS or significantly affect the surrounding environment.
However, certain pollutants, like PM2.5 and NOx, may require additional analysis due to their potential health impacts.
The facility’s modeling data shows that some pollutants, such as nitrogen oxides and carbon monoxide, will exceed regulatory thresholds, necessitating further review.
If the plant operates at higher than permitted levels in the future, emissions of these and other chemicals could rise, potentially triggering new regulatory hurdles.
RESPONSES FROM TCEQ AND WOLF HOLLOW II
Albert Hatton, Constellation’s Director of Environmental Operations, defended the permit application, emphasizing that Wolf Hollow III would operate only about 40% of the time.
He assured attendees that the facility is designed to meet TCEQ’s air quality standards, and that the expansion is intended to help stabilize the Texas power grid during peak demand periods.
Jason Law, an air permit specialist with TCEQ, outlined the federal and state review processes, assuring that the expansion complies with both Texas and Federal Clean Air Acts.
Catherine Talley from TCEQ’s Environmental Law Division explained the administrative process, noting that public comments would be considered before a final decision is made and that contested case hearings could be requested.
PUBLIC QUESTIONS AND TECHNICAL CLARIFICATIONS
Donna Adair, who lives on Contrary Creek Road about a mile from the Wolf Hollow Power Plant, expressed her concerns about the facility’s environmental impact.
She requested that the Texas Commission on Environmental Quality deny Permit 175-173, which Constellation Energy is seeking.
Adair noted that a significant plume of steam and air pollution is visible from her home with the current four turbines, and she fears that additional turbines would increase emissions of pollutants like carbon monoxide, nitrogen oxide, and sulfur dioxide.
She also mentioned that the MARA Bitcoin Mining Plant, which Constellation Energy supplies with power, could be contributing to the need for this permit. Adair believes that power plants should be located in more industrialized areas with substantial buffers, not in rural residential zones.
During the Q&A session, Tom Dykes, a resident living approximately four miles from the proposed power-generating plant on Mitchell Bend Court, asked a general question about the recommended distance between such plants and the nearest residences. He inquired whether there are statutory or best practice guidelines for this separation.
In response, a TCEQ representative explained that their jurisdiction does not cover plant location choices unless mandated explicitly by statute. In this case, there are no statutory requirements for plant placement.
However, zoning and land use regulations still apply. Despite this, the response did not fully address Dykes' question, leaving him without a clear answer on the recommended distance.
Dr. Shannon Wolf, precinct 211 chair, addressed several technical issues as she inquired about the inclusion of carbon capture technology, which is not required due to the plant’s proposed limited operating hours.
Robert M. Taber, Jr., president of the Board of Directors of Pecan Plantation, a community with 8,000 residents that is expected to grow to 11,000 by 2028, asked about the tools used to measure pollution.
TECQ explained that the pollution model used is software-based and does not have actual sensors.
Taber argued that while software models can provide estimates, real sensors are needed to measure pollutants like particulates and gases accurately. Drawing from his 30 years of experience in the semiconductor industry, he emphasized the importance of using real sensing devices to get precise data.
Other questions focused on the modeling of fine particulate matter emissions, compliance with future EPA regulations, and the distance between the plant and surrounding residential areas.
Community members expressed skepticism about the permit process, questioning the potential for increased emissions and the accuracy of air quality models since they are assumptive and theoretical.
The panel reassured attendees that the plant’s emissions would be monitored and must remain within permitted limits.
FINAL REMARKS
The meeting concluded with a reminder that no final decisions would be made at the event. Lori Garris from TCEQ emphasized that all public comments, both oral and written, would be considered before a final decision is rendered.
If approved, construction for Wolf Hollow III is expected to begin by the end of this year or early next year, with the project potentially operational by 2026.
AGENCY CONTACTS AND INFORMATION.
Public comments and requests must be submitted either electronically at www14.tceq.texas.gov/epic/eComment/, or in writing to the Texas Commission on Environmental Quality, Office of the Chief Clerk, MC-105, P.O. Box 13087, Austin, Texas 78711-3087. Please be aware that any contact information you provide, including your name, phone number, email address, and physical address, will become part of the agency’s public record.
For more information about this permit application or the permitting process, please call the Public Education Program toll-free at 1-800-687-4040. Si desea información en Español, puede llamar al 1-800-687-4040.
Further information may be obtained from Wolf Hollow II Power LLC at the above address or by calling Mr. Albert Hatton III, Director, Environmental Programs, at (844) 783-2885.
