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28 FIGURE 20 Beaver Valley Nuclear Power Station, Pennsylvania (courtesy: Nuclear Regulatory Commission). FIGURE 19 Bay Front Power Station, Wisconsin (courtesy: Seth Tisue, Wikipedia Commons). Power Plant proposed near Byron Municipal Airport (C83) (AOPA 2010). exhaust effluent on aviation safety by the Airport Obstruction Standards Committee. The purpose of the study is to: VAPOR PLUME VISUAL IMPACT 1. Determine the impact of plume-induced turbulence under a variety of atmospheric conditions; In addition to turbulence created by industrial plumes, visual 2. Evaluate potential plume impacts and risk resulting hazards created by the plumes, especially from cooling tow- from pollutant concentrations within the plume using ers, also present a potential problem to pilots (see Figure 20). EPA and Occupational Safety and Health Administra- Plumes from cooling towers have relatively low vertical tion allowed regulations and potential exposure to the velocities and typically do not cause turbulence within the aircraft and crew members through repeated exposure flight levels. The main hazard from a cooling tower vapor of flying through plumes; and plume therefore is visual impairment to a pilot primarily 3. Evaluate potential visible affects from plumes on avia- resulting from the plume length and height along with poten- tion (i.e., ash and soot). tial fogging and icing conditions. Modeling is used to evaluate impacts from cooling towers. The state of California has a significant number of existing The model has the capability of predicting frequency (includ- electric energy plants located near airports. There are several ing lengths and heights) of visible cooling tower moisture groups opposing these facilities based on the potential safety plumes along with the potential hours of fogging and icing hazards the new plumes could pose on nearby air traffic at conditions. the airports. In California, the procedures for the siting of a new power plant are complex and involve a variety of review organizations that evaluate among other criteria environ- MITIGATION OPTIONS mental impacts. Review agencies include the CEC, EPA, and FAA, along with local permit agencies. One of the problems The following mitigation options may be considered to min- in addressing the impact of exhaust plumes and aviation is the imize impacts from thermal plumes: lack of current information and studies on the effect plumes have on aircraft. The FAA is currently conducting an analysis Curtail in energy-generation operations during periods of the impact of plume-induced turbulence and the potential when it may be necessary for aircraft to pass over air- risk to aircraft and pilots. The only conclusive information cooled condensers because of to weather conditions or available from the FAA and U.S.DOT is after-the-fact inci- other specific circumstances. dents of aircraft crashes in the vicinity of exhaust plumes near Restrict in-flight procedures during certain periods of the day when thermal plumes may occur. airports (CEC 2010b). Expand pilot training and awareness programs. The Aircraft Owners and Pilots Association (AOPA) has been active in providing comment on proposed energy proj- TRADITIONAL POWER PLANT IMPACT EXAMPLES ects and their potential impacts on pilots (J. Collins, AOPA, personal communication, 2011). For example, AOPA has pro- The following are examples of traditional power plants, both vided comments on the potential impacts of thermal plumes baseload and peakers, identified as having a potential impact from the proposed 200 MW Mariposa Natural Gas-Fired on aviation.

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29 Towantic Energy, Connecticut Russell Energy Center, California The Towantic Energy Power Plant is a proposed 512 MW Calpine Corporation has proposed a 600 MW combined cycle combined-cycle natural gas-fired power plant proposed for natural gas electric plant in Hayward, California, known as Middlebury, Connecticut. Two 150-ft stacks are proposed for the Russell City Energy Center. The project would be located the project located approximately 280 ft east of the Oxford Air- approximately 1.5 miles from Hayward Executive Airport port runway. The location of the stacks lies directly under the (HWD) and consist of two 145-ft exhaust stacks. The project "left downwind leg" approach to the airport and the height received a No Hazard determination from the FAA. The and location of the stacks could present a potential hazard to California Pilots Association is appealing to the Bay Area Air aviation. In addition, potential fogging conditions could occur Quality District and the EPA to deny the air quality permit for with the increase in water vapor from the plant, along with the facility because of the potential hazards the electric plant potential inversion conditions that could obscure the runways. could pose to aviation activity in the area including, but not An analysis was completed to evaluate the vapor plumes emit- limited to, visual and thermal plume hazards the plant could ted by the project near the airport (Egan Environmental 2010). present to pilots flying in the area (Wilson 2010). The project Five aeronautical studies were conducted by the FAA, with the is still being reviewed by EPA/Bay Area Air Quality District, latest determination by the FAA of No Hazard from the stacks the CEC, and the California Public Utilities Commission. (FAA 2010c). The Connecticut Siting Council has approved the project; however, construction of the plant has not occurred The FAA completed an aeronautical study for the Russell owing to the current economic situation and the need to secure Energy Center and issued a determination of No Hazard, dated a long-term power purchase agreement. In February 2010, as a March 26, 2007. The FAA also reviewed comments from result of continuing concerns of the potential impact of the pro- the CEC and issued a determination on those comments on posed plant on Oxford Airport, the FAA announced the Airport July 18, 2007, regarding the potential hazardous impact of the Obstruction Standards Committee had begun a plume exhaust plumes from the facility (Rodriguez 2007). The FAA findings initiative to evaluate the potential impacts from plume-induced did not change the original determination of No Hazard for turbulence along with the potential impact to both aircraft and either Hayward Airport (HWD) or nearby Oakland Interna- aircrew from repeated exposure resulting from flying through tional Airport (OAK). plume effluent (R. Pietrorazio, FAA Air Traffic Control Tower Manager, personal communication, 2010). The findings of the initiative are expected to be released by the end of 2011. Eastshore Energy, California Eastshore Energy proposed a 116 MW natural gas-fired Blythe I and II, California peaking facility in the city of Hayward, California. The proj- The CEC authorized the construction of the Blythe I power ect would consist of fourteen 70-ft-tall exhaust stacks located plant on January 31, 2001. The Blythe I energy facility is a approximately 1 mile from the airport. The CEC denied the 520 MW baseload natural gas power plant located approxi- application to build based on deficiencies in five areas (CEC mately 1 mile east of the Blythe Airport (BLH). The plant has 2008). Areas specifically pertaining to aviation were: two large stacks and cooling towers. The project is currently operating and there have been numerous complaints filed to The facility would cause a significant cumulative public the CEC by pilots because of the visible and thermal plumes safety impact on the operations of the nearby Hayward emanating from the plant and the hazards presented to pilots Executive Airport by further reducing already constrained (Ford 2010). air space and increasing pilot cockpit workload. The thermal plumes from the facility would present a Blythe Energy Project Phase II is a proposed 520 MW significant public safety risk to low-flying aircraft dur- combined cycle power plant located to the west of the exist- ing landing and takeoff maneuvers because of the close ing Blythe I project. The project is similar in size to Blythe I, proximity of the Hayward Airport. with a bank of cooling towers and two 130-ft stacks. The The facility would be inconsistent with the city of CEC has approved the Blythe II project; however, the FAA Hayward's Airport Approach Zoning Regulations and has not granted a No Hazard determination and has rejected incompatible with the Alameda County Airport Land proposed mitigation from the developers. Use Policy Plan.