HomeMy WebLinkAbout9C - Natural Gas Franchising
MEETING DATE:
AGENDA #:
PREPARED BY:
CITY COUNCIL AGENDA REPORT
May 1, 2000 ~
9C . ~,
Frank Boyles, City Manage)\
AGENDA ITEM: CONSIDER APPROVAL OF REPORT REGARDING NATURAL GAS
FRANCHISING.
DISCUSSION:
ISSUES:
History: The City Council at its April 17, 2000 meeting received a presentation
from the NSP gas utility representatives. NSP proposed that the City Council
schedule a hearing to consider whether a second gas franchise should be issued
in Prior Lake (one is already issued to Minnegasco). This does not mean that two
gas companies would serve the same household, but rather that two companies
could have residential customers within Prior Lake. The City Council directed that
the staff prepare a report identifying whether the customer is best served by
considering multiple gas suppliers in the community. Based upon the report, the'
Council would determine if it desires to schedule a public hearing.
Current Circumstances: The Council has indicated that if there is a tangible (i.e.
dollar) benefit to the customer in allowing multiple gas franchises, they would be
more inclined to consider conducting a public hearing. The paragraphs below
identify what I believe to be the issues the Council may wish to consider in
determining whether to schedule and give notice of a hearing
(1) Expanded Service Area: NSP indicates that authorization of a second franchise
will mean that larger areas of Prior Lake can be served by natural gas rather than
bottled gas to better facilitate development. Presumably this would be especially
timely in the orderly annexation area.
Minnegasco has supplied me with a map highlighting the streets in the
community which they serve. It appears that virtually every developed acre in
Prior Lake is presently served. The map also shows gas service along Spring
Lake Road, Vergus, South Shore, Panama, Mushtown, and Revere in Spring
Lake Township and the orderly annexation area, and virtually all streets in Credit
River Township up to the maps edge at about CSAH 27.
In short, there does not appear to be a problem with availability of gas service in
Prior Lake, the orderly annexation area or Credit River adjacent to our boundary.
Nor am I aware of complaints about the extension of gas lines to serve new
developments. A public hearing might confirm or deny this observation.
(2) Better Customer Service: NSP indicates that whether there is a choice in supplier
or not, the fact that more than one gas supplier serving the area provides the
customer leverage to gain better service.
16200 Eagle Creek Ave. S.E., Prior Lake, Minnesota 55372-1714 / Ph. (612) 447-4230 / Fax (612) 447-4245
AN EQUAL OPPORTUNITY EMPLOYER
City Council Agenda Item 9C
May 1, 2000
The argument assumes that current or expected future service levels need
improvement. We have observed this situation in other monopolies (i.e. cable
TV). I am not aware of significant problems with the service provided by
Minnegasco. This does not mean that Minnegasco's service will always be
acceptable however. A public hearing may help to determine whether there is a
problem to fix from the customer's perspective.
(3) Increased Offerings: NSP indicates that two suppliers in the service area
encourage additional customer services such as common utility trenching,
rebates on high efficiency heating equipment and home energy audits. To be
sure competition encourages the continuation and expansion of such customer-
services.
(4) New Camarate Citizens and Partners: Corporations such as NSP are civicly
responsible. As such, they often support civic projects financially or through in
kind contributions of their knowledge and expertise.
(5) Increased Tax Base: The real and personal property of the utilities is taxable
under present statute. Any additional investment made in Prior Lake by NSP
would benefit our tax base. A public hearing would help to reveal NSP's specific
plans for real and personal property investment in the community. The Council
should be aware that the public utility companies and their lobbying organizations
are working hard to sponsor state or federal legislation which would exempt their
personal property from taxation. If legislation of this type is passed, it may create
a reduction in tax base for any City containing such facilities.
(6) Better Gas Rates: While rates are regulated by the Public Utilities Commission
(PUC), the rate each company charges is based upon its production / distribution
costs. At present, the cost per therm for Minnegasco is 49.3i and for NSP 51.4i
(or 2.1 i more). Both utilities have a monthly service charge. The monthly service
charge is $5.00 for Minnegasco and $6.50 for NSP. Based upon these figures,
the customer pays more for NSP service at this point in time. I have also learned
that the developer likely receives a fee in the vicinity of $10,820 (541 units x
$20/unit) from NSP or Minnegasco, whoever gets the franchise. The developer
may use such funds to purchase ads for the development rebates for high
efficiency appliances and upgrades of insulation and high efficiency windows and
doors. In short, competition appears to be most beneficial to the developer.
There may someday be the option for customers to buy gas from NSP or any
other gas supplier even if the gas is delivered through Minnegasco lines.
However, both Minnegasco and NSP representatives agree that such a
brokerage system is some time off.
(7) Franchise Fees: The City is authorized to establish up to a 5% franchise fee as
we have done for cable television. Previous Councils have resisted this initiative
recognizing that the City will be identified as the benefactor on every utility bill
and the public is likely to perceive the charge as a hidden tax.
I :\COUNCI L \AGN RPTS\2000\050 1_ 9C. DOC
City Council Agenda Item 9C
May 1, 2000
Based upon the costs cited above, it appears that a residential customer today
would pay more for their gas service from NSP than from Minnegasco. If I were
that customer and knew that a franchise had been issued by the City which cost
me more than I would have otherwise had to pay, I might not feel well served. Of
course, rates can change over time.
CONCLUSION:
A public hearing could help to provide information useful in determining if a
second franchise would create any benefit to Prior Lake customers. If the
information received does not suggest that the consumer would benefit in any
appreciable way, then the Council has no obligation to pursue the matter further.
ALTERNATIVES: (1) Direct staff to schedule a Public Hearing to collect additional information
regarding the appropriateness of franchising a second gas company in the City.
(2) Take no action which would kill the request for an additional franchise.
RECOMMENDED
MOTION:
Alternative (2). If the information above is accurate, I do not believe that the
consumer significantly benefits from a second franchise in Prior Lake. If the .
Council would like to solicit additional input, then Alternate (1) would be
appropriate.
I :\COUNCIL\AGNRPTS\2000\0501_9C. DOC
1\51I
Northern States Power Company
414 Nicollet Mall
Minneapolis, Minnesota 55401-1993
Telephone (612) 330-5500
April 25, 2000
Wesley M. Mader, Mayor
City of Prior Lake
16200 Eagle Creek Avenue
Prior Lake, MN 55372
Dear Mayor Wesley M. Mader:
Northern States Power Company plans to make some significant improvements at its Black Dog
Power Plant. More specifically NSP plans to convert Units 1 and 2 at the plant from coal combustion
to natural gas-fired combined-cycle technology. The proposed project will result in a nominal
increase in generating capacity at the Plant of approximately 114 MW. The change will also result in
improved environmental performance by reducing air emissions associated with electric generation.
We have filed an application with the Environmental Quality Board ("EQB") asking that the project
be exempted from the EQB' s Power Plant Siting procedures. The purpose of the Power Plant Siting
Act is to locate new power plants. Since the project is the renovation of an existing power plant, we
do not believe there are any siting decisions to be made. As you can see in the copy of our
application we have enclosed, the project will improve the efficiency of power production and
improve the environmental performance of our plant. Air quality and water quality permits must be
granted by the Pollution Control Agency and the Department of Natural Resources before the project
can proceed.
As a local or regional unit of government within 10 miles of the plant you have an opportunity to
comment on our exemption request. If you have any comments you may address them to John
Hynes, Minnesota Environmental Quality Board, 658 Cedar Street, St. Paul, Minnesota 55101. You
have 60 days to file any comments you may have. If you have questions of the EQB, please direct
them to Mr. Hynes. His phone number is 651 296 2871.
We would be happy to discuss our project in more detail with you. If you have any questions please
feel free to contact me. My phone number is 612 330 6732. My e-mail address is
james.r.alders@nspco.com. Thank you.
Sincerely
~ /rlbvz--
James Alders
Manager Regulatory Projects
Enclosure
Application to Exempt
the
Black Dog Units 1 and 2 Repowering Project
from the
Siting Requirements of Minnesota Statutes ~116C.51 to 116C.69
Table of Contents
Introduction................................................................................................................................ 1
1.1 Summary.................................................................................................................................... 1
1.2 Background.......................................................................................................................... ...... 2
1.3 Project Overview........................................................................................................................ 4
2 Project Description ......... .... ..................... ...... .............. ....... ...... ............. .................. ...... ............. 5
2.1 Ownership.................................................................................................................................. 5
2.2 Size and Type............................................................. ................................................................ 5
2.3 Location.......................................................................................................................... ............ 6
2.4 Engineering Design.................................................................................................................... 6
2.5 Design Life................................................................................................................................. 7
2.6 Cost Estimate..................................................................................................................... ......... 7
2.7 Operation.................................................................................................................................... 7
2.7.1 Dispatch.......................................................................................................................... 7
2.7.2 Fuel................................................................................................................................. 8
2.7.3 Maintenance................................................................................................................... 9
3 Effects on Human Settlement................................................................................................... 10
3.1 Displacement............................................................................................................................ 10
3 .2 Noise......................................................................................................................................... 10
3.3 Aesthetics................................................................................................................................. 11
3.4 Community Benefits................................................................................................................. 11
3.5 Cultural Values......................................................................................................................... 11
3.6 Recreation................................................................................................................................. 12
3.7 Public Services ...................................................................................... .... .... ............. .............. 12
3.7.1 Highways and Railroads....................................................................................... ........12
3.7.2 Natural Gas Supply............................................................................................ ...... ....12
3.7.3 Fire Protection............................................................................................................. .13
4 Effects on Public Health and Safety......................................................................................... 14
5 Effects on Land-based Economies........................................................................................... 15
5.1 Agriculture................................................................................................................................ 15
5 .2 Forestry..................................................................................................................................... 15
5 .3 Tourism.................................................................................................................................... 15
5.4 Mining .............................................................................................................................. ........ 15
6 Archaeological and Historic Resources................................................... ....................... .......... 16
... ..~..........._---....._..~........----y--..--_...._-_._-_.
Table of Contents (continued)
7 Effects on the Natural Environment......................................................................................... 17
7 .1 Air................................................. ........ .................................................................................... 17
7.1.1 Prevention of Significant Deterioration........................................................................18
7.1.2 MACT Review............................................................................................................ .20
7.1.3 State Air T oxics Review............................................................................................... 22
Water.......................................................................................................................... .............. 22
7.2.1 Surface Water Runoff.................. ................................................................................ .22
7 .2.2 Wastewater.................................................................................................................. .23
Land............................................................................................................................ .............. 24
Wildlife........................................................................................................................... .......... 24
7.2
7.3
7.4
8
9
9.1
9.2
r-,,::;;;
Rare and Unique Natural Resources......................................................................................... 25
Cumulative Present and Future Demands on Air and Water Resources.................................. 27
Air Resources...................................................................................................................... ..... 27
Water Resources....................................................................................................................... 27
9.2.1 Groundwater Appropriations..... ........................................................ ......... ...... ....... .....27
9.2.2 Surface Water Appropriations...................................................................................... 28
10 Application of Design Options............................................................. ............................... ..... 29
10.1 Maximize Energy Efficiencies ........................................................................................ ........... 29
10.2 Mitigate Adverse Environmental Effects ........................................................................... ........ 29
10.3 Accommodate Expansion......................................................................................................... 30
11
ILl
11.2
11.3
12
12.1
12.2
13
14
Use of Existing LEPGP Sites and Infrastructure...................................................................... 31
Plant Components..................................................................................................................... 31
Transportation Infrastructure.................................................................................................... 3 1
Electrical Transmission ......................................... ...... .......... ............. ....... ..... ........... ...... ......... 31
Costs Dependent on Design and Site........................................................................................ 33
Construction....................................................................................................................... ...... 33
Operation.......................................................................................................................... ........ 33
Unavoidable Adverse Effects................................................................................................... 34
Permits........................................................................................................................ .............. 35
11
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List of Tables
Table 1
Table 2
Table 3
Table 4
Estimated Emission Rates Comparison
Estimated Ambient Air Impacts
Estimated HAP Emissions
List of Potential Permits, Approvals and Plans
List of Figures
Figure 1
Figure 2
Figure 3
Figure 4
Figure 5
Figure 6
Project Location Map
Black Dog Site Map
Existing Black Dog Plant Layout
Project Plant Layout
Vicinity Natural Resources
Potential Natural Gas Pipeline Routes
List of Appendices
Appendix A
Appendix B
Appendix C
Appendix D
Minnesota Session Laws 2000, Chapter 289
Response from State Historical Preservation Office
Responses from MDNR Natural Heritage Program and U.S. Fish and
Wildlife Service
Groundwater Appropriations Permit Amendment Application
Acknowledgement
This application was prepared by Northern States Power Company with assistance from Barr
Engineering Company. Portions of the information included in this document were collected and
compiled by Earth Tech, Inc.
111
'''''r-oo, .,,_. ....---.-..-......-....... .
1 Introduction
Northern States Power Company (NSP) hereby makes application to the Minnesota Environmental
Quality Board for Exemption from the Power Plant Siting Act for the Repowering of Units 1&2 at
the Black Dog Power Plant in accordance with Section 116C.S7 subd. Sa of the Minnesota Power
Plant Siting Ad (the "Act") as amended2, and Minn. Rules 4400.39103.
Co-
NSP proposes to upgrade its Black Dog Generating Plant (Plant) in Burnsville, Minnesota (Figure 1),
by replacing two older coal-fired boilers with a combined-cycle natural gas-fired combustion system
(the "Project"). Several components of Units 1 and 2 will be reused in the new combined cycle. The
repowering project at Black Dog will not cause significant human or environmental effects. Instead,
it will increase generating capacity by a nominal 114 megawatts (MW) to meet the growing demand
for electricity while, at the same time, increasing the efficiency and improving environmental
performance ofNSP's facilities.
1.1 Summary
. Land Use - No changes to land use will occur
The project will be constructed within the existing Black Dog Power Plant Buildings with limited
modifications. No new transmission lines are necessary. No agricultural land is affected. No
residential areas are affected. The project will not have any significant affects on flora or fauna.
The Plant's relationship with the Minnesota Valley National Wildlife Refuge that surrounds the
facility will be unaffected. The modification will not affect archaeological and historic resources.
. Aesthetics - Changes in aesthetics will be minimal
Almost all of the project will be housed within the existing Plant Buildings. Part of the
generating building roof will be raised to the same elevation as the boiler building roof and a new
230 foot tall stack will replace one of three 292 foot tall existing stacks.
1 Minnesota Power Plant Siting Act as cited at Minn. Stat. Sees. 116C.51 through 116C.69
2 Minnesota Session Laws 2000, Chapter 289
3 Exemption of Certain Large Electrical Power Generating Plant Sites as cited at Minn. Rules pt. 4400.3910
. Noise - No discernable change in noise is expected
No new significant noise impacts are expected as a result of the project since it will be housed
within the existing buildings and the plant currently operates nearly all the time. New noise
levels will be low and masked by existing noise sources.
. Air Quality - Air emissions from NSP's facilities will be reduced
The Project's conversion of two units at Black Dog from coal to natural gas combustion using
state of the art, high efficiency, combined cycle technology will result in a reduction in air
emissions. The proposal includes state of the art pollution control technology to minimize
pollutant emissions including nitrogen oxides.
. Water Appropriations - Will not change significantly
Under normal operating conditions ground water and surface water use at the Black Dog Power
Plant will not change from that which is currently permitted by the Department of Natural
Resources. The Department has modeled potential worst case groundwater appropriations and
found no significant impact to surrounding sensitive resources.
. Wastewater Discharge - No changes to wastewater permits will be required
The plant will continue to use a series of settling ponds to ensure proper quality before
discharging to the cooling lake (Black Dog Lake) and then the Minnesota River. The plant will
continue to operate the cooling lake in order to maintain compliance with temperature
requirements of the lake discharges to the Minnesota River.
. Public Health and Safety - No new public services will be required
There will be no new public services required as the result of the modification and no impact on
public health or safety.
1.2 Background
The Black Dog Power Plant currently consists of four coal-fired steam generation units with a total
generating capability of 485 MW. Figure 2 shows the Plant site and Figure 3 shows the layout of
major existing Plant features. The Plant's four units were brought on line between 1952 and 1960.
Units 1,3, and 4 can burn natural gas alone or in conjunction with coal but were designed as coal
2
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fired boilers. Unit 2 can burn natural gas as a start-up ignition fuel only. Units 1 and 2 of the Plant
are currently used as peaking facilities, operating only for a few hours a year, when the demand for
electricity is at its highest. Units 3 and 4 are used as intermediate load facilities. They typically
operate 24 hours a day for about 250 days a year.
During the 1998 cycle of the PUC Resource Planning process, several participants expressed interest
in the feasibility of converting NSP's coal-fired power plants located in the metropolitan Minneapolis
and St. Paul area to natural gas as a way of reducing air emissions. NSP reached agreement with the
parties to examine the feasibility of converting Black Dog Units 1 &2 to natural gas and the
Minnesota Public Utilities Commission included Order Point 14 in Docket E-002/RP-98-3t, which
states, "NSP shall conduct a study of the feasibility of converting its Black Dog Units 1 and2 from
coal fired generation to natural gas..."
The Black Dog Generating Plant was chosen for further evaluation because Units 1 &2 are currently
the highest cost resources in the metro coal fired fleet and earlier NSP screening work indicated that
natural gas conversion was feasible. The evaluation, completed in late 1998 and early 1999,
concluded that natural gas combustion in the existing Unit 1 and Unit 2 boilers was extremely
inefficient, but that repowering Units I and 2 with natural gas using combined-cycle technology was
feasible and cost effective. NSP informed the Public Utilities Commission of the evaluation's results
and ofNSP's intentions to apply for a Certificate of Need (CON) for the repowering of Black Dog
Units 1 and 2 on September 13, 1999. NSP filed an Application for a Certificate of Need with the
Public Utilities Commission December 30, 1999.
Minnesota Statutes 116C.51-.69 requires that power plants larger than 50 MW must obtain a
Certificate of Site Compatibility from the Environmental Quality Board. The purpose of the Power
Plant Siting Act is to locate new power plants in an orderly manner. The Project consists of major
improvements to and refurbishment of an existing power plant. Because there is no location decision
to be made, NSP concluded that a Site Certificate was not required for the Project. However, the
staff of the Environmental Quality Board indicate that their reading of the Act leads them to believe
the Project falls within the definition of a "Large Electrical Generating Facility" and thus a Site
Certificate is required. NSP discussed with the EQB staff the possibility of pursuing legislative
amendments to the Act and on March 28, 2000 the Governor signed Minnesota Session Laws 2000,
4 MPUC Order, Docket E-002/RP-98-32' "Order Modifying [NSP's] Resource Plan, ReqUiring Additional Wind
Generation, Requiring Further Filings, and Setting Standards for Next Resource Plan Filing, 2/17/1999.
3
2 Project Description
2.1 Ownership
The Black Dog Generating Plant and the property on which the Plant is located are owned by NSP.
The project will also be owned by NSP.
2.2 Size and Type
The Project will consist of installing natural gas-fired combined-cycle electric generating technology
in place of the existing coal-fired generating technology in Black Dog Units 1 and 2. TheProject
will include the removal of the Black Dog Unit 1 coal-fired boiler, precipitators, steam turbine and
generator, and retiring in place of the Unit 2 coal-fired boiler. A new natural gas-fired combustion
turbine-generator set will be placed on the Unit 1 steam turbine and generator foundation and a new
heat recovery steam generator (HRSG) will be placed in the Unit 1 boiler cavity (see Figure 4). The
Unit 2 steam turbine and generator will be utilized in the combined cycle. The HRSG will have the
ability to be fired with supplemental natural gas to provide additional peaking capacity.
The Project will generate approximately 290 MW during summer peak operating conditions. The
current accredited capacity of Black Dog Units 1 and 2 is 176 MW' The Project will increase NSP's
system summer generation capability by approximately 114MW.
Most new Project components, including an ammonia storage tank, will be located within the
existing Plant structure. New components that will be located outside of the existing Plant structure
are the combustion turbine step-up transformer, the HRSG exhaust stack and air inlet filter. A gas
compressor building approximately 20 feet by 40 feet may be added outside of the existing Plant
structure, depending on the source of natural gas supply for the Project (see Section 3.7.2).
The exhaust stack will be approximately 230 feet tall and will be located in the footprint of the
existing 292 foot Unit 1 retired flue gas chimney. The existing building height will be modified in an
approximately 58-foot by 77- foot area. It is anticipated that the roof will be raised by about 58 feet
in this section, from a height of about 67 feet to a height of 125 feet. The new height is consistent
with the current elevation of the adjacent boiler area roof.
4 URGE (Uniform Rating of Generating Equipment) as accredited by Mid-Continent Area Power Pool (MAPP)
5
. -_..---~.,-"... .~..~-_....,._".._...~
2.3 Location
The Black Dog Generating Plant is located in located in Township 27N, Range 24W, Sections 23 and
24 in Dakota County. The Plant is in the northern portion of the City of Burnsville, just south of the
Hennepin County boundary (Figures 1 and 2). Highway 77 is located approximately one east of the
site, and Interstate 35W is located approximately two miles west of the site. The site is located on a
1,900-acre parcel of land in the Minnesota River Valley along a linear strip of land with a southwest-
northeast alignment, which is bounded by the Minnesota River to the north. The Minnesota Valley
National Wildife Refuge is adjacent to the site. NSP leases approximately 1,250 acres of the 1,900-
acre parcel to the U.S. Fish & Wildlife Service who maintains it as part ofthe refuge. The nearest
residential areas of Bloomington and Burnsville lie approximately 2500 feet northwest and south of
the site.
2.4 Engineering Design
The proposed facility design is based on combustion turbine technology combined with the HRSG
and steam turbine. The process of utilizing the power generated by the combustion turbine along with
that generated by the steam turbine is referred to as combined-cycle electric generation and offers
substantially increased efficiency over a simple-cycle combustion turbine or a coal-fired system. The
combustion turbine fires natural gas and converts the energy contained in the fuel into mechanical
energy. The combustion of natural gas and subsequent expansion of the exhaust gas rotates the
combustion turbine, which spins the generator shaft to produce electricity. The exhaust heat from the
combustion process (with or without being heated further through firing of natural gas in duct
burners) is then used to produce steam in the HRSG, which in turn drives the steam turbine. The
exhaust steam from the steam turbine is condensed to water via the steam turbine condenser using a
once-through circulating water system. After passing through the HRSG, combustion gases pass
through a selective catalytic reduction system which uses aqueous ammonia and a catalyst to reduce
the emissions of oxides of nitrogen. The treated flue gas then exits via the 230 foot tall exhaust
stack.
The actual output of the Project depends on ambient weather conditions (primarily temperature and
humidity) and the operating mode of the HRSG (with or without duct-firing). For purposes ofthis
application, nominal generating capacity is considered 290 MW, which is the net capacity during
summer conditions (90oF and 60 percent relative humidity) when the combustion turbine is operated
at full load and the HRSG is duct-fired with supplemental gas to obtain peak output. The maximum
6
Project output of 323 MW occurs when operating in the winter when the combustion turbine is
operated at full load and the HRSG is duct-fired with supplemental gas to obtain peak output.
NSP expects that the Project will operate using the combustion turbine without duct-firing between
80 and 90 percent of its operating hours. Operating in that mode at yearly average temperature
conditions (450p and 60 percent relative humidity); the Project will have a capacity of 260 MW. The
Project operates at maximum efficiency (over 47 percent) and most economically without duct firing.
The additional capacity of the Project provided by supplemental firing of the HRSG, while generated
at a lower incremental efficiency (about 34 percent), is still competitive when compared to other
sources of of electricity during peak demand periods.
The design capacity of the Project was selected to take greatest advantage of the existing Unit 2
steam turbine. The existing Unit 2 steam turbine-generator is rated for 130 MW net capacity. In a
typical combined cycle plant, the combustion turbine is sized to be about double the steam turbine
capacity. The 170 MW Siemens Westinghouse 501P CT will provide exhaust heat to utilize
approximately 90 MW of the Unit 2 steam turbine capacity. Supplemental firing of the HRSG to
increase its steaming rate will allow the Project to capture the full load capability of the Unit 2 steam
turbine during periods when peak output is desired.
2.5 Design Life
The design life of the Project is 30 years although the actual serviceable life of the Project may
exceed that.
2.6 Cost Estimate
The estimated Project capital cost is $156 million. The annual fixed operations and maintenance cost
is estimated to be $5.3 million. The annual non-fuel variable operation and maintenance cost is
estimated to be $717 thousand, and the annual fuel cost is estimated to be $18 million.
2.7 Operation
2.7.1 Dispatch
The Project will be integrated into NSP's dispatch control center. NSP expects to use the facility for
intermediate load service, dispatching it after all incrementally cheaper and "must run" units have
7
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been called to run. The additional capacity of the Project, available through supplemental firing of
the HRSG, will be utilized for peak demand periods.
The Project will change output as instantaneous power requirements change. The Project will be able
to start up after a 30 minute notice and will have the capability to ramp at approximately 5 to 10 MW
per minute depending on the pre-existing steam turbine condition (cold, warm, or hot restart). A hot
restart to full load is expected to be accomplished in less than two hours, a warm restart to full load
in less than four hours, and a cold start to full load within eight hours.
The Project will typically be dispatched 5 days per week, 16 hours per day, resulting in an annual
capacity factor of around 45 percent.
2.7.2 Fuel
The Project will be fueled entirely by natural gas with no back up fuel. In combustion turbine peak
firing mode and with HRSG duct firing during summer conditions (summer peak mode), the Project
will consume an estimated 2.2 million standard cubic feet (SCF) of natural gas per hour, with an
estimated peak demand of 2.4 million SCF per hour during winter peak operating mode. Under
normal operating conditions, dispatched five days per week, 16 hours per day, the Project could
consume up to 9,200 million SCF of natural gas each year.
NSP plans to purchase firm gas supply capacity for the project and is currently evaluating gas supply
proposals from three prospective suppliers. Any pipeline infrastructure needed by the gas supplier to
provide the contracted gas service will be the responsibility of the gas supplier. By law the gas
service provider must ensure that there will be no disruptions to other customers when providing firm
gas supply service.
Depending on the gas service proposal, new pipeline capacity mayor may not be necessary to serve
the Project. One of the proposals under consideration would likely require no new pipeline
infrastructure. Two of the proposals under consideration would require a new interconnection to the
plant from the Cedar Town Border Station. Although the proposals do not include routing
information Figure 6 identifies two concepts for pipeline routing. A third possibility not shown on
Figure 6 might be a more direct route crossing Black Dog Lake. Some of the proposals also indicate
that gas suppliers may need to make upstream system improvements as the result of the project. If a
new pipeline is required it would require a pipeline permit from the EQB or FERC. The
owner/operator would be responsible for that application. Both processes incorporate full
8
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environmental review if necessary. There are pipeline routing alternatives and mitigation techniques
available that would prevent significant environmental or human pipeline impacts if a new line is
required. Any construction impacts can be mitigated with appropriate permit conditions in the route
permitting process.
2.7.3 Maintenance
The scope and frequency of maintenance work on the Project's combustion turbine, steam turbine,
HRSG, and the balance of Plant equipment will be in accordance with power industry standards and
equipment manufacturer's recommendations. The frequency of maintenance for major combustion
turbine components is based on the number of unit start-ups and firing hours and falls into three
categories:
.
Combustor inspection-occurs every 400 starts or 8,000 firing hours and would require a 5-day
outage,
,-..-
.
Hot gas path inspection and component replacement-occurs every 800 starts or 16,000 firing
hours requiring an 11 to 13 day outage, and
.
Major overhaul-scheduled every 1,600 starts or 48,000 firing hours and requiring a 23 to 25 day
outage.
The HRSG should only require periodic inspection and minor maintenance that can be scheduled to
coincide with outages of the combustion turbine. Major overhaul of the steam turbine-generator,
condenser, and associated equipment will be necessary every six to eight years. The annual
availability of the Project is expected to average over 90 percent.
,...-
9
3.3 Aesthetics
The Black Dog plant aesthetics will not change significantly. The plant is located within the
Minnesota River Valley and is surrounded by the Minnesota Valley National Wildlife Refuge (see
Figure 5). There are scenic views in the area, particularly from the river bluffs. There is also an
wildlife observation area along Black Dog Road on the riverside of Black Dog Lake and west of the
plant used primarily to observe waterfowl that use the Lake during migration and as the result of
open water created by plant warm water discharges during winter. Since the proposed modifications
occur largely within the Plant, they will not affect scenic views. The new Project stack height will
actually be about 72 feet shorter than the retired stack it is replacing. There will be an additional
water vapor plume from the combined cycle unit.
3.4 Community Benefits
The local community will benefit from the Project. Project construction will require an estimated
250 to 300 construction workers over the 2-year Project demolition/construction period. These high-
skill, high paying positions, including pipefitters, iron workers, millwrights, boilermakers,
carpenters, electricians, and other trades, are estimated to add over $10 million of payroll into the
regional economy. Operation of the repowered unit after construction will require approximately 15
additional full-time positions.
The Project and the rest of the Plant will annually contribute an estimated $3.5 million in property
taxes for the City of Bloomington, Dakota County, and Burnsville School District. The state and
Dakota County will also benefit from income and sales taxes paid as a result of the construction of
the Project. The operating staff associated with the plant will continue to pay payroll taxes.
3.5 Cultural Values
Construction of the Project will not have any impact on the cultural values ofthe area nor will it alter
the use of the site or nearby lands. The existing Black Dog Generating Plant consists of a steam
plant, an electrical substation, coal yard, cooling ponds, ash storage areas, and associated drive and
parking areas, and has provided electricity to Twin Cities customers since 1952. Since there will be
no change in land use, no change in the cultural landscape will occur.
11
. ...~. . ......T- ............--.-...---.......
3.6 Recreation
The Project involves repowering of existing facilities and will not have an impact on recreation in the
area. The Project would not alter the use of the site or nearby lands and water bodies. None of the
nearby fish and wildlife resources would be altered by the Project. The information kiosk, trailhead
and recreational trail leading into the wildlife refuge on the south side of Black Dog Lake would be
unaffected by the Project.
3.7 Public Services
3.7.1 Highways and Railroads
The highways and railroads near the Plant are shown on Figures 2 and 3. The existing Black Dog
Road and Union Pacific Railroad line will meet the Project access needs during construction and
future operations. No railroad and only minor temporary road upgrades are necessary for the Project.
It is expected that the Cedar channel bridge located on Black Dog Road east of the plant will require
temporary shoring for transport of the HRSG. Restricting traffic to one lane on Black Dog Road may
be necessary to allow for the swing of the construction crane during certain construction activities.
3.7.2 Natural Gas Supply
Currently the Plant is served by Minnegasco via Portland Town Border Station (TBS). Thepipeline
consists of a 16-inch steel pipe operated at 145 pounds per square inch (psi) with annual consumption
ranging from 300,000 to 750,000 million British thermal units (MMbtu). Theoperating
specifications for the Project require an operational PSI of 500-525 psi with estimated annual
consumption of 12,000,000 MMbtu.
NSP is conducting a competitive bidding process for the gas delivery service necessary to serve the
Project. The existing natural gas pipeline will need to be operated at a higher pressure or a new
natural gas pipeline will need to be constructed to serve the Project. The existing Minnegasco
pipeline and two of several potential gas pipeline routing ~oncepts are shown in Figure6. Any
pipeline infrastructure will be owned and constructed by the gas provider and that provider would be
responsible for an regulatory approvals necessary to construct-and operate that infrastructure. Some
of the prospective suppliers have indicated that upstream improvemnts to the gas pipeline system
may also be needed to ensure continued reliable operation of the gas system.
12
Two prospective gas suppliers are Local Distribution Companies (LDCs). If a new pipeline is
constructed by an LDC, a pipeline routing permit from the EQB would be required and the pipeline
owner/operator would be responsible for that application. If an interstate pipeline company is
selected to supply gas for the Project, environmental review for pipeline infrastructure work would
fall under the jurisdiction of the Federal Energy Regulatory Commission (FERC). Minnesota EQB
staff have been active participants in the FERC review process on recent gas pipeline projects and
would be expected to be involved in this case. Any construction activities that have potential for
significant environmental or human impacts could be mitigated with appropriate permit conditions in
the route permitting process. For the new gas pipeline option, the successful bidder for the
installation and operation of the distribution system will be responsible for the identification of the
actual routing and acquisition of the required permits and approvals in order to construct the pipeline.
3.7.3 Fire Protection
The Plant is equipped with a complete fire protection system consisting of a diesel-driven fire pump
designed in accordance with National Fire Protection Association (NFP A) requirements, a backup
electric fire/cooling water pump, distribution headers and smoke detectors throughout the Plant, and
automatic sprinklers that provide coverage for much of the equipment. The source of water is the
Minnesota River. The Plant is equipped to handle first response to any fire. The City of Burnsville
Fire Department is available for emergency situations.
13
4 Effects on Public Health and Safety
No adverse impacts to public health or safety will result. The Project involves repowering of an
existing electric power generating plant with advanced technology processes and equipment. The
conversion from burning coal to burning natural gas will result in an overall reduction in potential
combustion emissions. Use of natural gas will reduce NSP's system-wide air emissions of sulfur
dioxide, nitrogen oxides, particulates, carbon monoxide, carbon dioxide, and mercury. Also,
reductions in fugitive particulate matter emissions will result from the elimination of ancillary
sources associated with operation of the existing Units 1 and 2.
14
'--T"'"---'
5 Effects on Land-based Economies
5.1 Agriculture
There will be no impacts to the agricultural economy from the Project. The site is currently used for
generation of electrical power and falls within a conservation district in an area of guided General
Industrial use. The site is not located on or near agricultural land.
5.2 Forestry
There will be no impacts to the forestry economy from the Project. The site is currently used for
generation of electrical power and falls within a conservation district in an area guided for General
Industrial use. The site is not located on or near commercial forestry land.
5.3 Tourism
The Project will not affect the adjacent Minnesota Valley National Wildlife Refuge and will not
affect any tourism to the area. The site is currently used for generation of electrical power.
5.4 Mining
There will be no impacts to the mining economy from the Project. The site is currently used for
generation of electrical power and falls within a conservation district in an area guided for General
Industrial use. The site is not located on or near any land used for mining.
15
6 Archaeological and Historic Resources
No impacts to archaeological and historic resources are expected as a result of the Project. The site
is currently used for generation of electrical power and has been since 1952. The Project involves
minimal disturbance of the site-less than five acres will be temporarily disturbed by construction.
The Minnesota State Historic Preservation Office was asked to review their records to determine
whether there are any reported historic or archaeological resources in the Project area and whether
there is a significant probability of any unreported resources. Their December 22, 1999 response
letter is included in Appendix B, and indicates that no historic properties or archaeological sites will
be affected by the Project.
16
7 Effects on the Natural Environment
7.1 Air
The conversion of Black Dog units I & 2 from burning coal to burning natural gas will result in an
overall reduction in potential combustion emissions both at the Plant and across NSP's system.
Table 1 shows a comparison of the potential criteria pollutant emissions from the Project and the
existing Units 1 and 2 refurbished to continue operating as coal-fired unit~.
TABLE 1
ESTIMATED EMISSION RATES COMPARISON)
Black Dog Units 1 and 2 Repowering Project
Estimated Emission Rates (lbs.lMWh) 2
Pollutant Black Dog Units 1 and 2 Black Dog Units 1 and 2 Refurbished for
Repowered Peaking Service
S02 0.0063 4.13
NOx 0.12 6.88
PM10 0.07 0.24
CO2 780 2500
CO 0.18 0.32
1 Based on best data available, at 100% load. May achieve additional megawatts from steam cycle optimization.
2 Project emission decreases do not include particulate matter emissions from ancillary sources.
Combustion of natural gas in the proposed combined-cycle combustion turbine will result in
emissions of oxides of nitrogen (NOx), carbon monoxide (CO), particulate matter (PM),
sulfur dioxide (S02), and volatile organic compounds (VOCs). A small portion of the PM and VOCs
include compounds that are classified as Hazardous Air Pollutants (HAPs) under the Clean Air Act.
The combustion turbine emissions will be discharged through a stack 230 feet in height. It is
expected that the facility will utilize the following emissions control technology:
5 Units 1 and 2 are currently being operated for peaking service. To continue operating the units in that mode, NSP
must invest in a variety of maintenance projects to enhance the performance and reliability of the units. The
continued operation of Units 1 and 2 as an alternative to the Project is discussed in the Certificate of Need
Application for the Black Dog Units 1 and 2 Repowering Project submitted to the Minnesota PUC by NSP on
December 30, 1999 (MPUC Docket No. E-002/CN-99-1815).
17
."T-...Oo.-.------..~-......... .
. Firing only natural gas to minimize sulfur dioxide emissions,
. Dry low-NOx burners to minimize the formation of oxides of nitrogen in the combustion
turbine,
. Selective catalytic reduction to reduce oxides of nitrogen emissions in the combustion turbine
exhaust gas, and
. Good combustion practices for control of fine particulate, carbon monoxide, and volatile
organic compound emissions.
An air emission permit application was submitted to the MPCA in January 2000.
7.1.1 Prevention of Significant Deterioration
The Project qualifies as a major modification to an existing major source under the federal
Prevention of Significant Deterioration (PSD) requirements. The purpose of the PSD program is to
minimize degradation to air quality in areas that currently enjoy clean air. As a major modification,
PSD requires the following:
. Best Available Control Technology (BACT) must be applied to control emissions from the
new combustion turbine.
. Dispersion modeling must be performed to demonstrate that the emissions from the Project
will not cause or contribute to a violation of an ambient air quality standard or PSD
increment.
. Additional impacts to air quality, visibility, soils, and vegetation due to Project emissions,
secondary emissions, and associated growth must be evaluated.
NSP will satisfy BACT requirements by applying the most effective of all the available options to
control NOx emissions. The combustion turbine will be equipped with dry low-NO. burners.
Emissions from the proposed combustion turbine and the duct burner will be further reduced using a
selective catalytic reduction (SCR) system. Burning only pipeline-quality natural gas will minimize
sulfur dioxide emissions. Good combustion practices will be applied to control CO and VOC
emissIOns.
Air dispersion modeling shows that worst case emissions from the facility will not have significant
impact on ambient air quality. The modeling, using EPA approved modeling protocols, of the
maximum predicted contribution to ambient air concentrations of contaminants due to emissions
from the proposed project are less than the PSD ambient air impact modeling significance levels for
18
.' ,~",'_'-'",.~.~,.-........_,_.,_., -,--~-'''''''''-'''''''.''''''''';-;''~'''--''''''.'-'-'''' ._~~...,,".,..-.~..~.-,~,-,..._._-_.,.. .~
.-.-T-...--.-.-----.-OO. ,
all pollutants. The ambient impact significance levels serve as screening criteria to determine if
further analyses are required to verify that the emissions will not cause or contribute to an
exceedance of an ambient air quality standard or PSD increment. PSD increments have been
established for N02, S02, and PMIO to prevent degradation to air quality by limiting the collective
change in ambient concentrations that can occur due to construction or modification of stationary
sources in the region after a specific baseline date. The PSD increments are more limiting than the
ambient air quality standards.
Table 2 presents ambient air quality standards and estimates oftotal plant impacts on ambient air
quality. These modeling results illustrate actual expected impacts from the Plant (both the
repowered part and units 3 and 4) under anticipated actual operating conditions. These results are
not potential to emit calculations that are required as part of an air permit application.
Estimated Black Dog Plant Contribution to
Ground-level Concentrations
Pollutant Ambient Air Quality Black Dog Units 1 and 2 Black Dog Units 1 and 2
Standard Repowered1 Refurbished for Peaking
Service2
(~g/m3) (lJg/m3) (lJg/m3)
S02 (Annual) 80 0.99 0.80
S02 (24-hour) 365 18 21
S02 (3-hour) 1300 63 81
S02 (1-hour) 1300 130 180
NOx (Annual) 100 2.4 1.6
NOx (24-hour) None 38 40
PM10 (Annual) 50 0.14 0.05
PM1Q (24-hour) 150 2.9 1.5
CO (24-hour) None 9.2 19
CO (1-hour) 40,000 42 170
CO (8-hour) 10,000 14 41
TABLE 2
ESTIMATED AMBIENT AIR IMPACTS
Black Dog Units 1 and 2 Repowering Project
1project, Units 3 and 4.
2Units 1 and 2 peaking, Units 3 and 4 intermediate service.
19
T"
7.1.2 MACT Review
The Hazardous Air Pollutant (HAP) emissions from the Project are below the thresholds that would
require a case-by-case determination of Maximum Achievable Control Technology (MACT) to
control HAP emissions.
The estimated HAP emissions from the Project are summarized in Table 3.
Black Dog Units 1 & 2 Black Dog Units 1 & 2 Refurbished
Pollutant Repowered for Peaking Service
(tons/year)
1 ,3-Butadiene 1 0.002 0.000
Acetaldehyde 0.296 0.043
Acetophenone NO 0.001
Acrolein 0.027 0.022
Antimony NO 0.001
Arsenic 0.000 0.001
Benzene 0.520 0.067
Benzyl chloride NO 0.053
Beryllium 0.000 0.000
Biphenyl NO 0.000
B is(2 -ethyl hexyl)phthalate NO 0.006
Bromoform NO 0.003
Carbon disulfide ND 0.008
Carbon tetrachloride NO 0.004
Cadmium 0.006 1.12
Chloroform ND 0.005
Chromium 0.006 1.12
Chlorobenzene NO 0.002
Cobalt 0.000 0.008
m,p-Cresol NO 0.001
Cumene NO 0.000
Cyanide NO 0.191
Dibutyl phthalate ND 0.003
Dichlorobenzene 0.001 NO
Dimethyl sulfate ND 0.004
TABLE 3
ESTIMATED HAP EMISSIONS
Black Dog Units 1 and 2 Repowering Project
20
._-.-_. .....-..
Black Oog Units 1 & 2 Black Oog Units 1 & 2 Refurbished
Pollutant Repowered for Peaking Service
(tons/year)
Ethyl benzene 0.090 0.035
Ethyl chloride NO 0.003
Ethylene dichloride NO 0.003
Formaldehyde 3.76 0.022
Hexachlorobenzene NO 0.000
Hexane 1.77 0.102
Hydrogen chloride NO 4.60
Hydrogen fluoride NO 4.12
Isophorone NO 0.044
Lead 0.059 0.069
Manganese 0.005 0.007
Mercury 0.002 0.004
Methyl bromide NO 0.012
Methyl chloride NO 0.040
Methyl ethyl ketone NO 0.030
Methyl hydrazine NO 0.013
Methyl iodine NO 0.006
Methyl isobutyl ketone NO 0.006
Methyl methacrylate NO 0.002
Methyl tertiary butyl ether NO 0.003
Methylene chloride NO 0.022
Naphthalene (POM)3 0.518 0.001
Nickel 0.002 0.027
N-nitrosodimethylamine 1 0.001 0.001
N-nitrosomorpholine 1 0.001 NO
PAHs2 (also POM) 0.667 0.000
Pentachlorophenol NO 0.000
Phenol NO 0.001
Phthalic anhydride NO 0.006
Propionaldehyde NO 0.029
Propylene Oxide 1 0.108 NO
Selenium 0.000 0.001
TABLE 3
ESTIMATED HAP EMISSIONS
Black Dog Units 1 and 2 Repowering Project
21
....~~..~.....,--_.._- ~
Black Dog Units 1 & 2 Black Dog Units 1 & 2 Refurbished
Pollutant Repowered for Peaking Service
(tons/year)
Styrene NO 0.002
Tetrachloroethylene NO 0.003
Toluene 0.485 0.039
Trans-1,3-0ichloropropene NO 0.006
Trichloroethylene NO 0.004
Trimethylamine 0.001 NO
Vinyl acetate NO 0.001
Vinylidene chloride NO 0.009
m,p-Xylenes NO 0.002
Xylene 0.099 0.034
Totals 7.92 12.0
TABLE 3
ESTIMATED HAP EMISSIONS
Black Dog Units 1 and 2 Repowering Project
NO - Either emissions are zero or data is not available.
1 Emission factor is based on one-half the detection limits and not on measured values. Expected
emissions are lower than the presented values.
2 PAH is polycyclic aromatic hydrocarbon (also called polycyclic organic matter, POM).
3 Naphthalene meets the definition of POM. Naphthalene also is regulated as an individual HAP,
therefore it is listed separately. However, it is subtracted from the total HAPs to prevent double counting.
7.1.3 State Air Taxies Review
The Project is exempt from the requirement to conduct an air toxics review because the proposed
turbine will burn only natural gas as fuel. Natural gas is the cleanest of all fossil fuels. The
exemption for natural gas-fired combustion sources is specified in a MPCA memorandum dated July
7, 1999, from the Risk Managers Lateral Team to the Toxics Evaluation Staff, Environmental
Review Staff, and Leadership Team.
7.2 Water
7.2.1 Surface Water Runoff
No adverse impacts to water resources will result from the Project. The Project will not alter the
plant's existing surface water runoff conditions because nearly all of the Project features will be
constructed inside the Plant building. After construction, the Project and the rest of the plant will
22
, ,_ ~..".-.~_..........~""._,.w..^_...~....______"_,,_,,.".,., ~ "--"-"'~-'~-~---'~"""'~'-"~' ....'^-,._,~-_.~--_....~---.....~...-.,_.."..,.. "-
--_.__._--_._-~--..----_._-_..-_...._....-
continue to be covered under the Minnesota General Storm water Permit for Industrial Activity
(MNG 11000).
The Plant has one city storm water drain located near the northeastern comer of the plant. This drain
receives runoff from an asphalt area and vegetation, however no substantial material storage occurs
in this area. One other city stormwater drain exists on Black Dog Road near the screenhouse. Other
than street runoff and the city drains there is no direct storm water discharge not already covered by
an National Pollutant Discharge Elimination System (NPDES) permit.
Transformers are located within concrete brick containment. All storm water that accumulates within
the transformer containment area is released to the plant bottom ash pumps and transported to the ash
basins. Substation runoff infiltrates or occurs as sheet runoff. The east side of the Plant has a yard
drainage system directing runoff to the ash settling ponds. Runoff from the coal yard, transfer areas
(fuel oil, caustic, sulfuric acid, dust suppression, and gasoline tank), dumpsters, fly ash loading, and
access road is directed to the ash settling ponds. Most of the closed/capped temporary ash storage
area runoff goes to ash settling Pond No.4. Pond water is discharged approximately monthly under
the plant's NPDES permit to Black Dog Lake, which serves as the plant cooling lake, and then into
the Minnesota River.
The site will remain as it is now, relatively flat after construction. Due to the limited area of
temporary impacts and temporary construction storm water control methods, changes in the quantity
and quality of the runoff after the Project are not expected to be significant. Runoff patterns at the
site will not change. No significant impact on the quality of the receiving waters is expected.
A new gas pipeline to the powerhouse may be necessary for the Project. NSP will work with the
natural gas supplier on any storm water issues associated with pipeline installation, including
reestablishment of present grade and vegetation.
Tanks and other storage containers at the Plant meet requirements of Minnesota aboveground and
underground storage tank rules, and federal Spill Prevention, Control, and Countermeasure (SPCC)
Plan regulations.
7.2.2 Wastewater
Process wastewater generated by the Project will be managed on-site at the NPDES permitted system
as is currently done. Household-type sanitary wastewater will continue to be discharged to the local
sanitary sewer system. The Reverse Osmosis system reject (liquid wastes generated by the treatment
23
"'-~"-"."'I--'~~-'-""-"""'"
of the Project raw water supply), other pretreatment wastes, evaporative cooler blowdown, and
miscellaneous wastewater (e.g. washdown, river water leaks, etc) will be routed to the plant's
existing permitted settling pond system.
7.3 Land
The Project will have no significant adverse effects to land resources. Existing site development
consists of a steam electrical generating plant, an electrical substation, coal yard, cooling ponds, ash
storage areas, and associated drive and parking areas. The Project would not significantly alter usage
of the site or adjacent/nearby lands. No permanent conversion of land cover will occur. Part of the
berm by the guardhouse will be knocked down and fill will be placed in the corner of the parking lot
to provide access for large equipment. The berm will be reseeded and gravel will be replaced on
disturbed portions of the parking lot. Less than 5 acres will be disturbed by the temporary site
modifications for the Project.
Solid wastes such as lubricants, hydraulic fluids, cleaning materials, packaging and office materials,
domestic-type wastes, demolition wastes, and asbestos generated from the Project
demolition/construction will be removed from the site for recycling or disposal at permitted facilities.
Several wastes currently generated by Units land 2 will be eliminated, including coal ash and
corrosive chemicals from the periodic cleaning of boiler tubes. This will reduce the amount of these
wastes generated at the Plant.
7.4 Wildlife
None of the site or nearby fish and wildlife resources will be altered by the Project. Wildlife
resources at the site itself include waterfowl and fish that utilize the cooling lake (Black Dog Lake)
and peregrine falcons that nest on a site exhaust stack (see Section 8). This stack will not be affected
by the Project. Waterbodies adjacent to or near the site (Black Dog Lake, the Minnesota River, and
Long Meadow Lake) and their associated wetlands and adjacent uplands represent significant fish
and wildlife resources.
24
....._-_......--.._--~--_..--......._..... ..
8 Rare and Unique Natural Resources
The Natural Heritage Program of the MDNR was contacted and asked to review their database to
determine if any rare plant or animal species or other significant natural features are known to occur
within the vicinity of the Project and along the conceptual natural pipeline corridors that mayor may
not be necessary to serve the Project (see Section3.7.2). The U.S. Fish and Wildlife Service was also
asked to comment on potential impacts to federally endangered or threatened species. Copies of the
two agencies' responses are included in Appendix C.
The agencies' reviews identified the potential presence of bald eagles (Haliaeetus leucocephalus) and
peregrine falcons (Falco peregrinus). It is unlikely that the Project would adversely affect these
listed species because all site impacts, including traffic in and out of the site, will occur on existing
developed land. Peregrine falcons nest on the tallest Plant stack, which will not be affected by the
Project. As requested in the MDNR response letter, NSP contacted Joan Galli, the MDNR Regional
Non-game Specialist, who in turn referred NSP to Dr. Harrison Tordoff at the University of
Minnesota, who has been observing the peregrine falcons at the Plant site. Dr. Tordoff stated: "with
all the activity far below them, my guess is that there would be no visible effect. I would recommend
that planning proceed independently of concern about the falcons.'''' With regard to the potential
natural gas pipeline corridors, if an existing pipeline corridor or other disturbed corridor (e.g., road or
railroad) is used to transport natural gas for the repowering Project, no adverse effects on threatened
or endangered species would be anticipated. Potential issues related to the natural gas pipeline route
will be addressed by the gas supplier as part of the permitting process for pipeline route designation
that will be completed in accordance with Minnesota Rules 4415 or similar FERC requirements.
The Minnesota County Biological Survey has identified several calcareous fens in the vicinity of the
site. The MDNR response letter also identified listed species and native plant communities that are
associated with the area calcareous fens. The mapped boundaries of the closest fens are
approximately 2,500 feet east-southeast and 3,200 feet southwest of the Black Dog plant and are
within the Minnesota Valley National Wildlife Refuge (Figure 5). Fens are described as open
wetlands, often on gentle slopes, located in areas with organic soil saturated by upwelling calcareous
groundwater. Fens are regulated under Minnesota Statutes I 03G.223as.promulgated by Minnesota
Rules 8420.1010. In the vicinity of the Minnesota River, fens are recharged by calcareous
groundwater associated with the Prairie du Chien aquifer. The hydraulic head of the Prairie du Chien
25
.. .--....oO.._.._........._~-_..._....r-"..._._...__.._--_._..._-_..
aquifer has been identified as approximately 20 feet higher than the ground surface within the
Minnesota River Valley. If the head of the Prairie du Chien aquifer were substantially reduced,
potential impacts to the fens could occur. The MDNR has modeled the potential impacts to the fens
based on the maximum withdrawal rates proposed in NSP groundwater appropriations permit
amendment request (see Section 9.2). The MDR has concluded that the potential impacts to the fens
resulting from the maximum groundwater appropriations for the Plant after the completion of the
Project will not be significant. The Black Dog Scientific and Natural Area (SNA) is located
approximately I1f4 miles southwest of the site, south of Black Dog Lake and east ofInterstate 35W.
This SNA is owned by the MNDNR and The Nature Conservancy and managed by the MNDNR.
According to MNDNR records, three fens are located in this area. The proposed project will not
have impacts on these resources.
6 February 25,2000 email from Harrison Tordoff [tordoff@bioscLcbs.umn.edu] to Daniel J. Orr.
26
9 Cumulative Present and Future Demands on Air
and Water Resources
9.1 Air Resources
The Project will have a net positive effect on the region's air resources by repowering two of the
Plant's four units from coal-fired steam generation units to a more efficient natural gas-fired
combined cycle combustion turbine unit. The Plant operates in accordance with an MPCA Air
Emissions Permit, which will be modified as a result of the Project. See Section 7.1 of this
exemption application for additional details regarding impact to air resources from the Project.
9.2 Water Resources
The Plant currently appropriates groundwater for makeup water and surface water for cooling under
Minnesota DNR permits No. 61-0271 and No. 61-0270, respectively.
9.2.1 Groundwater Appropriations
It is currently anticipated that dewatering will not be required at the site for the Project, or if required
would be significantly less than the 10,000 gpd or one million gallons per year threshold that would
require a MNDNR Water Appropriation permit.
An amendment to Permit No. 61-0271 has been submitted to the MDNR by NSP to add an additional
well to provide a backup to the existing groundwater well. A copy of the amendment application and
accompanying explanatory letter from NSP is included in Appendix D. The new well would obtain
water from the Prairie du Chien aquifer-the same aquifer the existing well is constructed in. The
amendment application proposes that either well be pumped at a maximum rate of 125 gpm, with the
provision that both wells may be pumped at a combined rates up to 250 gpm for up to 400 hours
annually. Groundwater modeling completed by the MDNR has indicated that those proposed
pumping rates would not adversely impact adjacent water resources. The groundwater appropriation
permit currently limits annual groundwater appropriations to 50 million gallons. Recent annual
groundwater appropriations for Plant operations have been in the range of 33-34 million gallons.
The Project is expected to increase the annual groundwater appropriation about 11 million gallons, so
the entire Plant appropriation will be approximately 45 million gallons annually. This annual
appropriation is less than the current permit limit, so no amendment to that permit provision is being
requested.
27
'''--~''-'--''-.-----'''----'-'------ .....- .
9.2.2 Surface Water Appropriations
No amendment to Permit No. 61-0270, which allows the Plant to appropriate surface water for
cooling purposes, is necessary for the Project. The surface water is withdrawn from the Minnesota
River and passes through the Plant condenser units and associated equipment for cooling purposes.
The water is discharged to the Plant cooling lake where the temperature is reduced to allow the water
to be discharged back into the Minnesota River under the Plant's NPDES Permit No. MN0000876.
(No major modification to the NPDES permit will be required as a result of the Project). The surface
water appropriation permit allows the Plant to appropriate up to 458,200 acre-feet (149,300 million
gallons) in any calendar year. Recent annual surface water appropriations have been in the range of
45,000 million gallons to 65,000 million gallons. While the Project is expected to reduce the
maximum or daily rate at which surface water will be appropriated, the annual appropriation is
expected to increase about 18,000 million gallons because of the higher capacity factor (i.e. more
operating hours) that the Project will realize compared to the recent capacity factors for Units 1
and 2.
28
10 Application of Design Options
The purpose of the Project is to enhance NSP's ability to provide economical, efficient and
environmentally acceptable electric generating capacity and energy to meet the needs ofNSP's retail
and wholesale customers. The Project's intermediate load and supplemental peaking service
generating capacity will assist NSP in meeting its demand forecast. Alternative technologies and
approaches were considered in the Project's Certificate of Need (CON) Application7. The CON
application demonstrated that the Project as proposed is preferable to the alternatives for meeting the
Project purpose and objectives. Key among the factors that make the Project preferable are the
Project's high efficiency and minimal environmental impacts.
10.1 Maximize Energy Efficiencies
The Project will replace approximately 176 MW of existing coal-fired generating capacity with new
gas fired capacity of290 MW, an incremental addition of approximately 114 MW of low-cost
summer capacity without expanding the existing Plant site. The Project is an example of increasing
the efficiency of existing generation units. The Project will not only increase the capacity of the
Plant, but will also increase the operating efficiency from 31 and 35 percent for the existing Units 1
and 2, respectively, to over 47 percent for the Project's repowered unit-an increase in efficiency of
over 45 percent.
10.2 Mitigate Adverse Environmental Effects
Utilization of an existing power generation site and, to the maximum extent possible, existing
infrastructure are the primary means by which potential adverse environmental effects will be
mitigated. No significant adverse environmental impacts are anticipated from the Project as
described throughout this document. Typical issues of concern for projects of this type include:
noise, air quality, aesthetics, groundwater, and surface water.
Potential noise concerns are mitigated by having most of the Project features constructed inside the
plant building. NSP will minimize noise during construction by requiring construction contractors to
use properly muffled equipment and restricting activities during nighttime hours (see Section 3.2).
7 Northern States Power Company, December 30, 1999. "Certificate of Need Application for the Black Dog Units 1
and 2 Repowering Project" PUC Docket No. E-002/CN-99-1815.
29
The Project is expected to have a positive impact on air quality because conversion of the coal-fired
units to natural gas combustion technology will measurably reduce air emissions (see Section 7.1).
Aesthetic impacts will not be significant because very little visible change will occur to the Plant as a
result of the Project. The most visible change will be the reduction height of one of the Plant stacks
(see Section 3.3).
Groundwater use is expected to have no adverse effect on surrounding resources. Increased Plant
pumping rates will be limited in accordance with the amended DNR groundwater appropriations
permit.
More surface water from the Minnesota River is expected to pass through the Plant cooling systems
because of the increased operation of the Plant expected after Project implementation, but surface
water usage will continue to comply with current Plant's surface water appropriation permit
provIsIOns.
10.3 Accommodate Expansion
No specific design features are included to accommodate expansion of the Plant.
30
.............._. "d_'_'__"'_'~"_''''__'~'''__'___''''
11 Use of Existing LEPGP Sites and Infrastructure
The Project will take advantage of an existing LEPGP. The Project will use existing Plant
components, existing transportation infrastructure and the existing electric transmission system.
11.1 Plant Components
The Project involves the repowering of two existing generating units allowing NSP to take advantage
of existing infrastructure. The combustion turbine portion of the Project will be placed inside the
existing building where Unit 1 is currently located. The steam turbine, generator and condenser
components of the existing Unit 2 will be re-utilized for the steam generation portion of the Project.
The combined cycle Project will result in a net increase in capacity of about two-thirds from the
current Units 1 and 2 capacity and increase the efficiency by about 45 percent.
The Project will be able to use the Plant switchyard with some modification and the electric
transmission line that currently serves the facility with no modifications.
11.2Transportation Infrastructure
The Project leverages use of the existing road system. No new roads are necessary. Some work will
be needed to shore up the Cedar channel bridge for delivery of the HRSG and combustion turbine.
The Project will not cause any significant long-term impact to traffic levels.
11.3Electrical Transmission
The Project will use the existing electric transmission system to move the energy generated by the
Project to NSP's customers. No new transmission lines are required to accommodate the increase in
generating capacity at the plant. However, reconductoring8 of two existing 115kV lines between the
Black Dog Substation and Wilson Substation, located 4 Y2 miles north of the Plant, will be necessary.
..:..
8 Reconductoring consists of replacing the conducting cables currently on the line with new cables capable of higher
current.
31
r......
Up to seven structures, where the transmission line changes direction, may be replaced with single
pole steel structures.
32
.0__.____....''0__- ._.----.---_._00
12 Costs Dependent on Design and Site
12.1 Construction
The estimated total plant capital cost for the Project at Black Dog Generating Plant is $156,000,000.
The major cost element is the combustion turbine generator set. Cost items that are unique to this
site are the cost of removal and modification of existing Plant components. These costs are partially
offset by the reduced site development costs at the existing site as compared to a greenfield site.
12.20peration
The major cost of operation is associated with the Project fuel, natural gas. Fuel costs are estimated
to be about $18 million per year. While the cost of natural gas is typically greater than coal (on a
$/million Btu basis), the increased efficiency of a combined cycle combustion turbine unit results in
lower generation cost. Fixed operations and maintenance costs are estimated to be $5.3 million per
year. Non-fuel variable operation and maintenance costs are estimated to be $717 thousand per year.
33
........ .~,.~.--.." ''''''~'~''-''''"'T''"~..~.~_._---,--_..~.~,~_.,_.,---,.. .
13 Unavoidable Adverse Effects
Unavoidable adverse impacts from the Project will be minimal. The Project is a repowering of an
existing electric generation plant and most of the Project will occur inside the Plant building.
Additional water appropriation may be necessary, but an assessment by the MDNR of the additional
withdrawal from the Prairie du Chien aquifer finds insignificant effect.
"\
During the demolition/construction period there will be an increase in traffic on Black Dog Road.
Currently an estimated 1,000 vehicles per day use Black Dog Road. An estimated 200 to 300
workers will work at the site over the estimated 2-year demolition/construction period.
The construction or upgrade of a natural gas pipeline to serve the facility may result in off-site
impacts. Potential impacts will be addressed under the environmental review process prescribed by
Minn. Rules 4410 and 4415 or similar FERC requirements. There are routing options available that
would not result in significant adverse effects. MEQB and FERC have routinely included mitigation
requirements in pipeline routing permits to ensure impacts are minimized.
-"
34
___....__.,__...._~__.u .....--___
14 Permits
Table 4 provides a list of potential permits, approvals and plans required for the Project.
TABLE 4
LIST OF POTENTIAL PERMITS, APPROVALS, AND PLANS
Black Dog Units 1 and 2 Repowering Project
~
Unit of Government Type of Application Status
U.S. Environmental Protection Spill Prevention, Control, and Will modify existing plan
Agency (USEPA) Countermeasure (SPCC) Plan
U.S. Department of Energy Exemption to burn natural gas for Will obtain
(USDOE) power production (10 CFR 503)
U.S. Army Corps of Engineers Waters of the U.S./Wetlands Permit If required, will obtain prior to
(USACE) initiating construction
Minnesota Public Utility Certificate of Need In process, submitted
Commission (Commission) December 30, 1999
Minnesota Pollution Control Air Emissions Permit Application submitted
Agency (MPCA)
MPCA National Pollution Discharge Will modify existing permit (No.
Elimination System/State Disposal MN0000836 to address change
Permit due to the Project
MPCA Above ground storage tank Will register new tank
registration for tanks over 110
gallons
MPCA Construction Storm Water Permit Estimate of disturbed area
does not trigger permitting
requirement; if estimate
changes to above 5 acres, will
obtain. Requirements for any
new pipeline are a supplier
obligation.
MPCA Storm Water Pollution Prevention Will modify plan, if needed
Plan
MPCA Hazardous Waste Will modify plan, if needed
Contingency/SPCC /Minnesota Spill
Bill Plan
Minnesota Emergency SARA Title III chemical notification, Will comply with requirements
Response Commission and planning and reporting for aqueous ammonia or if
Local Fire Dept. change boiler chemicals
Minnesota Dept. of Natural Water Appropriation Permit for Will modify existing permit (No.
Resources (MNDNR) supply wells 61-0271) to meet additional
water needs
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LEGEND
D Black Dog Power Plant
Property Boundary
i~ J Municipal Boundary
+
Figure 2
1000 0
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4000 5000 Feet
---'
SITE MAP
BLACK DOG UNITS 1 AND 2
REPOWERING PROJECT
Burnsville, Minnesota
250 0
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MINNESOTA
RIVER
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Figure 3
EXISTING PLANT LAYOUT
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REPOWERING PROJECT
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PROJECT PLANT LAYOUT
BLACK DOG UNITS 1 & 2
REPOWERING PROJECT
LEGEND
,^..l ApprOXimate Fence Line
I' / Approximate Property Boundary
@ Town Border Stallon
A Approximate Fen Locetlon
0: MNDNR Minor Watershed Boundary (Dakota Co.)
o Scientific and Natural Area (SNA)
FEMA Floodplain Areas:
[SJ 100-yr. FlOOdplain
500-yr. Floodplain
Netural Gas Pipeline Anematlve Corridors:
',-North Corridor
.~.south Corridor
-nExlstlng Corridor
Netlonal Wellands Inventory (NWI):
_ Lacustrine
_ Palustrine Emergent
_ Palustrine Forested
_ Palustrine Scrub-Shrub
o Palustrine Unconsolldeted Bottom/Shoreline
o Palustrine Aquallc Bed
B Riverine
N
t
o 1000 2000 3000 Feet
, ,
1 Inch = 3,000 Feet
EARTH@T
E
c
H
FIGU RE 5
VICINITY NATURAL RESOURCES
NSP BLACK DOG UNITS 1 AND 2
REPOWERI NG PROJECT
BURNSVILLE. MINNESOTA
DEC. 1999
37454
LEGEND
-+
Figure 6
Potential Gas Pipeline Routes
- - - 'North Corridor
.......... South Corridor
Existing Corridor
o Municipal Boundary
1000 0 1000 2000 3000 4000 5000 Feet
~ -----'
POTENTIAL NATURAL GAS
PIPELINE ROUTES
BLACK DOG UNITS 1 AND 2
REPOWERlNG PROJECT
Burnsville, Minnesota
2SO 0 250 500 750 1000 1250 1500 MeIms
1""""""1 ---,
S.F No. 2652, 1st Engrossment
Page 1 of 2
s.a.t.
.'~.'.' .. .. .;I
KEY: strieJJ(el"l = old language to be removed
underscored = new language to be added
NOTE: If you cannot see any difference in the key above, you need to ~h~Dg~the..1l_u;.plfl.Y of stricken
and/or underscored language.
Aulh.9.I~ anJLS_t!1.lJ.~ · List ~I~j9n~
S.F No. 2652, 1st Engrossment: 81st Legislative Session (1999-2000) Posted on Feb 21, 2000
1.1
1.2
1.3
1.4
1.5
1.6
1.7
1.8
1.9
1.10
1.11
1.12
1.13
1.14
1.15
1.16
1.17
1.18
1.19
1. 20
1. 21
1. 22
1.23
1.24
1.25
2.1
2.2
2.3
2.4
2.5
2.6
2.7
2.8
2.9
2.10
2.11
2.12
2.13
2.14
2.15
2.16
2.17
2.18
2.19
2.20
A bill for an act
relating to utilities; modifying electric power
generating plant exemption from the Minnesota Power
Plant Siting Act; amending Minnesota Statutes 1998,
section 116C.57, subdivision Sa.
BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF MINNESOTA:
Section 1. Minnesota Statutes 1998, section 116C.57,
subdivision Sa, is amended to read:
Subd. Sa. [EXEMPTION OF CERTAIN SITES.] (a) A utility or
person may apply to the board in a form and manner prescribed by
the board to exempt from the requirements of sections 116C.51 to
116C.69 the construction at a proposed site~
III of a proposed electric power generating plant with a
capacity between 50 and 80 megawatts frem tHC rc~ircmcl"lts of
Gcctiol"ls 11aC.S1 to 11aC.a9~
(2) involvinq the retrofittinq or repowerinq of an existinq
nuclear or primarily coal-fired power plant to primarily a
qas-powered power plant or similar clean fuel. Within 15 days
of the board's receipt of an exemption application, the utility
or person shall:
(1) publish a notice and description of the exemption
application in a legal newspaper of general circulation in the
county of the proposed site;
(2) send a copy of the exemption application by certified
mail to the chief executive of counties, home rule charter and
statutory cities, and organized towns within ten miles of the
proposed site; and
(3) mail to each owner whose property is part of or
contiguous to the proposed site a notice and description of the
exemption application, together with an understandable
description of the procedures the owner must follow should the
owner desire to object.
(b) For the purpose of giving mailed notice under this
subdivision, owners are the persons or entities shown on the tax
records of ~he county auditor ~r, in a county where tax
statements are mailed by the county treasurer, on the records of
the county treasurer, but other appropriate records may be used
to identify owners. Except for owners of tax-exempt property or
property taxed on a gross earnings basis, a property owner whose
name does not appear on the records of the county auditor or the
county treasurer is deemed to have waived the mailed notice
unless the owner has requested in writing that the county
auditor or county treasurer, as the case may be, include the
owner's name on the records for that purpose. The failure to
give mailed notice to a property owner or defects in the notice
http://www.revisor.leg.state.mn.us/cgi-binlbldbill.pl ?bill=S2652.1 &session=ls81
3/30/2000
'--y--'"
S.F No. 2652, 1st Engrossment
2.21
2.22
2.23
2.24
2.25
2.26
2.27
2.28
2.29
2.30
2.31
2.32
2.33
2.34
2.35
2.36
3.1
3.2
3.3
3.4
3.5
3.6
3.7
3.8
3.9
3.10
3.11
3.12
3.13
3.14
3.15
3.16
3.17
3.18
3.19
3.20
3.21
3.22
3.23
3.24
3.25
3.26
does not invalidate the proceedings, if a good faith effort is
made to comply with this subdivision.
(c) If a person who owns real property that is part of or
contiguous to the proposed site or an affected political
subdivision files an objection with the board within 60 days
after the board receives an exemption application, the board
must either deny the exemption application or conduct a public
hearing to determine if the proposed electric power generating
plant at the proposed site will cause any significant human or
environmental impact.
(d) The board shall require environmental review under
chapter 116D to assist in making its determination regarding
potential significant human and environmental impact.
(e) If the board determines that the proposed plant has an
electric power production capacity less than 80 megawatts or is
beinq retrofitted or repowered as described in paraqraph (a),
and the proposed site will not have a significant human and
environmental impact, the board may exempt the construction of
the proposed plant at the proposed site from the requirements of
sections 116C.51 to 116C.69 with any appropriate conditions.
(f) If an exemption is granted, the utility or person must
comply with applicable state rules, local zoning, building, and
land use rules, regulations, and ordinances of any regional,
county, local, and special purpose governments in which the
facility is to be located.
(g) The board may, by rule, require a fee to pay costs
incurred in processing exemptions. An estimated cost for
processing the exemption application must be discussed with the
applicant and be approved by the board when an application is
received. The applicant must remit 50 percent of the approved
cost within 14 days of acceptance of the application. The
balance is due within 30 days after receipt of an invoice from
the board. Costs in excess of those approved must be certified
by the board and charged to the applicant. Certification is
prima facie evidence that the costs are reasonable and
necessary. All money received pursuant to this subdivision must
be deposited in a special account. Money in the account is
appropriated to the board to pay expenses incurred in processing
the application and in the event the expenses are less than the
fee paid, to refund the excess to the applicant.
Sec. 2. [EFFECTIVE DATE.]
Section 1 is effective the day followinq final enactment.
Page 2 of 2
http://www.revisor.leg.state.mn.us/cgi-binlbldbill.pl ?bill=S2652.l &session=ls8l
3/30/2000
-"'T'OO'
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II
\11 \'\ I.:'()T \ 1I1~T()IU ( \ I. :-illC I liT)
ST ATE HISTORIC PRFSERV A TION OFFICE
December 22, 1999
Mr. Douglas Mensing
Earth Tech
3033 Campus Drive North, Suite 175
Minneapolis MN 55441
, RE: Resource Inquiry: NSP Black Dog Generating Plant Repowering Project
Dakota County
SHPO Number: 2000-0825
Dear Mr. Mensing:
As requested by your letter of December 13th, a list of inventoried historic properties and
archaeological sites is enclosed. This list includes sites within the location(s):
Township 27 North, Range 23 West, Sections 18 and 19
Township 27 North, Range 24 West, Sections 13, 23-25
Additional historic properties and archaeological sites may be present, but not yet included in the
SHPO inventory. Submittal of your project to our office for review, including photographs of any
affected buildings/structures built before 1950, will insure that potential historic sites and the
probability of archaeological sites are evaluated.
Please also note that this comment letter does not address the requirements of Section 106 of the
National Historic Preservation Act of 1966 and 36CFR800, Procedures of the Advisory Council on
Historic Preservation for the protection of historic properties. If this project is considered for federal
assistance, or requires a federal permit or license, it should be submitted to our office by the federal
agency as outlined in 36CFR800.3.
If any further information is needed, please feel free to contact me at (651 )296-5462, or by email at
sarah.jordan-beimers@mnhs.org.
Sincerely,
L';(L'Ul tl;) (l C(rq,~ I~.( (I! 1 ( , lOci ._-
.- .
Sarah Jordan Beimers
Review & Compliance Associate
Enclosure(s)
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Minnesota Department of Natural Resources
Natural Heritage and Nongame Research Program, Box 25
5()() Lafaycllc Road
SI. Palll. 1\1innc'ola 55 I :;:;.-lO_u
Phone: (651) 296-8279 Fax: (651) 296-1811 E-mail: karcn.cieminski@dnr.state.mn.us
January 7, 2000
Douglas M. Mensing
Earth Tech., Inc.
3033 Campus Drive N, # 175
Minneapolis, MN 55441
Re: Request for Natural Heritage information for vicinity of proposed NSP Black Dog Generating Plant
Repowering Project, T27N R24W S. 13,23,24,25 and T27N R23W S. 18 & 19, Dakota County.
NHNRP Contact #: ERDB 20000474
Dear Mr. Mensing,
The Minnesota Natural Heritage database has been reviewed to determine if any rare plant or
animal species or other significant natural features are known to occur within an approximate one-mile
radius of the area indicated on the map enclosed with your information request. Based on this review,
there are 53 known occurrences of rare species or natural communities in the area searched (for details,
see enclosed database printout and explanation of selected fields). Following are specific comments for
only those elements that may be impacted by the proposed project.
. Peregrine falcons have been reported from the site. Please coordinate this project with your
Regional Nongame Specialist, Joan Galli (651-297-2277) to avoid disturbance of this nesting
pair,
. Several listed species and native plant communities (calcareous seepage fens) are reported from
Section 18 near the pipeline's North Alternative. If this Alternative is chosen, we may
recommend a survey prior to disturbing any previously-undisturbed areas, which may contain
rare species. Because any change in hydrology or groundwater quality may affect the nearby
calcareous seepage fen plant communities (a protected type of wetland), we recommend this be
addressed in project development. A calcareous seepage fen is an extremely rare type of
wetland that is critically endangered in Minnesota. This type offen is designated as an
"outstanding resource value water" in water quality regulations administered by the MPCA. As
such, it is given statutory protection through Minnesota Rules pI. 7050.0180. The Wetlands
Conservation Act, authorized by Minnesota Statutes 103G.223, states that "[c]alcareous fens may
not be drained or filled or otherwise degraded except as provided for in a management plan
approved by the commissioner" of the Department of Natural Resources.
. Rare fish and mussel resources have been reported from the Minnesota River in the vicinity of
the project. The mussel occurrences are historic occurrences of rare freshwater mussels. These
species do not appear to be still extant in the river in this area, due to the poor water quality of the
river. However, although no live individuals ofrare species were found in the area, the currently
improving water quality of the river leads us to hope that they may some day be able to exist in
this area again. We recommend this project not be allowed to detrimentally affect the water
quality of the river.
The Natural Heritage database is maintained by the Natural Heritage and Nongame Research
Program, a unit within the Section of Ecological Services, Department of Natural Resources. It is
DNR Information: 651-296-6157 · 1-888-646-6367 · 1TY: 651-296-5484 · 1-800-657-3929
An Equal Opportunity Employer
Who Values Diversity
o
Printed on Recycled Paper Containing a
Minimum 0110% Post-Consumer Waste
. ......'T""-......---..---.......-.-.-... .
continually updated as new information becomes available, and is the most complete source of data on
Minnesota's rare or otherwise significant species, natural communities, and other natural features. Its
purpose is to foster better understanding and protection of these features.
Because our information is not based on a comprehensive inventory. there may be rare or
otherwise significant natural features in the state that are not represented in the database. A county-by-
county survey of rare natural features is now underway. and has been completed for Dakota County.
Our information about natural communities is. therefore. quite thorough for that county. However.
because survey work for rare plants and animals is less exhaustive, and because there has not been an
on-site survey of all areas of the county. ecologically significant features for which we have no records
may exist on the project area.
The enclosed results of the database search are provided in two formats: index and full record.
To control the release of locational information which might result in the damage or destruction of a
rare element. both printout formats are copyrighted.
The index provides rare feature locations only to the nearest section. and may be reprinted.
unaltered. in an Environmental Assessment Worksheet. municipal natural resource plan. or internal
report compiled by your company for the project listed above. If you wish to reproduce the index for
any other purpose. please contact me to request written permission. Copyright notice for the index
should include the following disclaimer:
"Copyright(year) State of Minnesota, Department of Natural Resources. This index may be
reprinted. unaltered, in Environmental Assessment Worksheets. municipal natural resource
plans. and internal reports. For any other use, wriuen permission is required. .
The full-record printout includes more detailed locational information, and is for your personal
use only, If you wish to reprint the full-record printouts for any purpose. please contact me to request
written permission.
Please be aware that review by the Natural Heritage and Nongame Research Program focuses
only on rare natural features. It does not constitute review or approval by the Department of Natural
Resources as a whole.
An invoice for the work completed is enclosed. You are being billed for map and database
search and staff scientist review. Please forward this invoice to your Accounts Payable Department.
Thank you for consulting us on this matter. and for your interest in preserving Minnesota's rare natural
resources.
Z.n erelY'j .~
~ /" .
. ~/ ~t . (L I / l.i/GvJC{
Karen Cieminski
Data Manager/Ecologist
encl: Database search results
Rare Feature Database Print-Outs: An Explanation of Fields
Invoice
.._~.- ,
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Twin Cities Field Office
4101 East 80th Street
Bloomington, Minnesota 55425-1665
JAN 1 3 2000
Mr. Douglas M. Mensing
Ecologist
Earth Tech, Inc.
3033 Campus Drive North, Suite 175
Minneapolis, Minnesota 55441
Dear Mr. M~nsing:
This replies to your December 13, 1999, letter requesting U.S. Fish and Wildlife
Service comments on potential impacts to federally endangered or threatened
species from two proposed natural gas pipeline alternatives for the Northern
States Power Black Dog Generating Plant on the Minnesota River in Dakota
County, Minnesota.
The following federally-listed threatened (T) and endangered (E) species are listed
for this portion of Dakota County:
Species
Scientific Name Habitat
Bald eagle (T)
Haliaeetus leucocephalus Breeding/Wintering
There is no designated critical habitat for the above species. There are also no
Candidate Species listed for the project area at this time.
In accordance with Section 7(c) of the Endangered Species Act of 1973, as
amended, it is the responsibility of the Federal agency to determine ifits actions
"may affect" listed species or critical habitat. We recommend that your
assessment of project effects on federally-listed species be included in any
environmental documentation required for the proposed project.
We also recommend that you contact the Minnesota Department of Natural
Resources concerning any state-listed species which may occur within Dakota
County.
"._ ....-m._~...,.,__.-_'___'M..____~...__._"_."..._ _._ _' '.
These comments have been prepared under the authority of the Endangered
Species Act of 1973, (16 V.S.C. 1531-1543), as amended. We appreciate the
opportunity to offer our comments on this project. Please contact Mr. Gary Wege
at 612/725-3548, extension 207, if you have any questions or require additional
information.
;;:::~{I W
Russell D. Peterson
Field Supervisor
cc: Minnesota Department of Natural Resources, St. Paul, Minnesota
~
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I\SP
"
Northern States Power Company
"-
414 Nicollet Mall
Minneapolis. MN 55401
Telephone (612) 330-6625
February 25, 2000
Mr. Pat Lynch, Area Hydrologist
Region 6 (Metro) Division of Water
Minnesota Department of Natural Resources
1200 Warner Road
St. Paul, Minnesota 55106
Black Dog Generating Plant
Water Appropriations Permit #61-0271'
Repowering Project
Dear Mr. Lynch,
Thank you for your review and modeling of an increase in well water withdrawal at
the Black Dog Generating Plant under Permit #61-0271 to accommodate the plant's'
repowering project as presented at meetings last year. For the repowered unit, well
water will be purified to supply the heat recovery steam generator year round and to
supply the combustion turbine inlet fogging system during warmer weather to
improve generating efficiency. As discussed and modeled, the project entails the
need for a second well water pump at the power plant with resultant potential total
power plant usage of up to 250 gpm for five weeks of five 16-hour workdays (totaling
400 hours) of operation during the summer and up to 125 gpm for the rest of the
workdays during the remainder of the year. The resultant increase in annual
appropriations is anticipated to be about 11 million gallons, which when combined
with present usage is expected to be within the existing permit limit of 50 million
gallons per year. The conclusion of your department's review and modeling is that
the impact of the additional appropriations on nearby fens will be minimal. A second
well may be installed to provide the additional appropriations and serve as a backup
to the existing well. Given your conclusions, NSP will work with the well driller to
ensure installation of any new well to the recommended aquifer.
Filp Cr.f:!Y
E:; 1\0
d C ,,"Or
o ~"cr e,.,
1.1:''-' J
.... ....-r--..----......----.
With the higher withdrawal capacity, Northern States Power Company (NSP) is filing
the attached request fo'r an amendment to Water Appropriations Permit #61-0271 to
increase the withdrawal rate to 250 gpm as well as to accommodate the installation
of a second well. Based on the analysis to date, NSP is not requesting an increase
in the annual appropriations limit of 50 million gallons at this .time but will trend
appropriations for any future needs.
'....
Enclosed with the application are a check for $75.00 to cover the application fee, an
area map, and an existing well log. Please review the enclosed materials to draft a
permit amendment. For your information, NSP is in the process of securing the
certificate of need as well as alternatives/exemption to the siting process for the
repowering project, and we anticipate that these processes will be completed early
summer.
Thanks for your review of this information. If there are any questions or concerns,
please call me at 612-330-6625.
r
1-
Ji Bodensteiner
. Environmental Scientist
encl:
c: ERAD Records Center
Jim Paris
Mark Danberg
Steve Hjermstad
Carl Sannes
Jim Alders
Terry Coss
... _."'~"""---"-'T"--~'-~~' ...
Permit Application for Appropriation of Waters of the State
NON-IRRIGATION
PA.NO.
~~ Oote(s) SeN9d
B~ "
<~
DCrrv
NA-<r2623-03
(r8V.11 /Q3)
IlEPWMENT OF
1IATUlW. RESOURCES
NonCE OF WARNING: All Information on this form Is considered to be public Information In accordance wtfh the
Mlmesota Data Prtvades Act (M.S. 15.1611 to 15.1698).
. SEE INSTRUCTIONS... 1YPE OR PRINT ClEARlY.
2. AutncItZIId Agent (If opplcctlle)
I. Aj:::pIlcant Ncrrle
Northern States Power Com
4. MalInQ AddreII So Clly. srm.. ~ Code
RSQ-8, 414 Nicol1et Mall Minneapolis, MN 55401
7. PIR'OSE (&pIo1n what !he wc:rlwr wtII be ~ tQr) DPubIIc Water ~ jiJ CorTITle/'daIt1ndurh1c1
o PoIlu1lon Conl\ lefT'Iel.t 0 Tempaay 0 0Itw
a. Sou'C8 at Water (j(" one and ccmpIete) AdciIlclna Ww.......~. MUSl' be 9. PoInt at Toldng/PuTIpIng SIte S E
~'OI'eocIl_1Wef a. 1/401 1/4ct 1/4
Go 0 One wet 10 IrwIruc:llI:n (I a 9) tot lWQLfto - 2 3
b. D mcnIoIded well mer& b. SedIon No.
c. 0 stream. dItt:h or riII'8r(r.crne) c. TownIhIp No. 27N
c1 0 Wetland.lalce Of ~t (name) c1 ~ No. 24 W
.. IXIOthet Additional well and. ex; !'=;tinq p~rm; t-t-~ e.Cou1ty Dakota
11. Meftlod of 12. Mecn 13.1.eQc1 ~1Icn-land Owned~'
10. Means of Tatdng end Rate ~t T~ RarQe Sect f1octloncI Sect.
Go ~ 1 statlOIIQ/Y~) at~ Go ~ Flow Me_ a. ~pIpe """"'_Iength No. No. . Govt. lots
1i'iOj ea.
b. 0_ jXlr1able pIJl'Tl)(a) at _g:m b. D11mi'lg o.w:. b. iltonk
(nQ.) ea.
c. D GrcMIy Flow at: gpm/cfI c. DEIectric PO\NW c. Dc:::I'larY'*
CorIl.rnptlcn
gpm/cfl c1 Dobt
(c:ide one) c1 DObt
~ Heme Phone No.
(612) 330-5500
6. Wale Phone No.
(612) 330-6625
o Watw LewI Mall ,,-ICl~
gel. oapcx;Ily 2 7 N
'-lgth
24W
23&24
c1 0 0Itw
14. MalIh1 ct
Appccpc1at\Ol,
Xl.IAN tJ.AJL
Xl FEB )0 AUG
MAR 15 SCP
Xf APR ~ OCT
~ MAY )r:! NOV
JUN ~oec
11. Sc:tleduIe ct ~ I ("X. one and ~te)
30 gp~
Go~Ccn1lnuou .1l. tn./dIaf 30 ~mo. 12 mo./yr.
b.~~m Beglmlngdate !,=;llmm~r: 4.00
c. OTempolrzy End date
"Rental Agrecnent MJST Be Sl..tmItted
.~TOa-dQ:f!.fttVBlack Dog Cooling
a. f]SlNam. Cltd'l Of ~ M;,.,,., ~ c:: n of- .:l( 'W' , ) MGY
(name)
b. OWettcnd. La. Of
~
La]
16. Total NYu:II UIe (MGY) II MGY
additional. Present permit
allows 50 MGY.
c
}MGY
(name)
c. C1s.w. S>;Itern
C )MGY
('ft'S ) MGY
'I. Ollc:harge Pclnt
Go _1I4ot_1I4of~1I4
b. Section No. 2 4 .
C. Township No. 2 7 N
d. RanQe No. 2 4 W
'c11CJOthet Eva oration
20. AddItloncI ~ts:
a. IX] Map Of 1<< Photo which IhoIoII:
1) PoInt of TaIdng Of P\.n'plng SIht
2) T8It Hole loc:atIcn 3) 8ou'1doI1eI of Property
Ccnlroled and Nea at UIe 4) o~ PoInt
b. i!FLH; Fepao,tClble to: . $.~U~I"
.000AI1MENr Of NA1UIAL RESOURCES" l' J..-lfe..r
c1 ~ Other g 2 4 ~cfI c. ~ 31...1... .,t ct JuItIfIcatIcl ,,~ sduR::8i
ontributes to existi~-) c1 ~Ooa.menll~
..c~ly Dakota Lan~ pro~ess wa~er Syste . x~st~ng well log
n se ~ng pon s.
~ I hereby make appUcatton pursuant to Mlmesota Statutes Chapter 103G.261 and al supporttng rUes tor a permit
to appropr1ate water In accordance wtfh all supporting maps. plans. ~d other Informatton submitted with this
application. 'The Information submitted and statements made concerning ttis application are true ood correct to
the best of my knawfedge.
19. Mecra ct 0IIcnarge a-d RaM
a. O_statIoIay ~s) at_SPn ea.
(nQ.)
b. 0 v;;:r- portot:IIe ~s) at gpm eo.
c. 0 GravIIy Flow at SPn/ds
. IMPORTANT: SJbmlt this application and all s..pportlng data to the DNR RegIonal O1ftC8
APPliCANT: KEEP A COPY FOR YOUR RECORDS.
(Q 1993 State OT Minnesota. Department 01 Natural Resources
22. Date
..
.. .
"I Printed on Recycled.Paper
_...._'''~~-~._.~~-----------~....
ADDENDUM
NOTICE TO APPLICANTS FOR DNR PERMITS TO APPROPRIATE AND USE
SURFACE AND GROUND WATERS OF THE STATE
The Oepa1m.e.1t ot Na1\Jrc/ Rescue. (DNR) and !he PoIkJtton Control agency (?CA) are WOI1cIng IoQeIher 1'0 CVQld dupllcat10n In s1at8 ClgllnC'f
r8IIIew of proposed oetMt1eI ctfecl1ng water r8SOlJrces ot !he $tate. THs tOlTTl WCl$ ptepOred by It\e DNR and me PCA to mnmize yC4.1 wone In
contacllng state agencies tot project approval.
Please complete this tOlTTl by plac:Jng an ox. In the approprtate box 01' boxes. It YOJr project 01' proposed oetMty does not lrlvdIie CI't'/ of the oetlon1
listed on Ih8 foIm. place an OX" n Ihe box after Item o.
If yolZ proposed project 01' ac1Mty will nwlve an( of the actlora listed tor box. 3 1t1~ 5. a COprf of yo.Jt DNR pemit appllcatton will be tOl'-
warded 1'0 the PeA tOl' their rEMew. It a separal8 PCA pel1'1"it 01' ape:llOllCl is 18Q\J/r8d. you wil be nottfted by the PeA.
In oddltton. please be acMsed that projec:ts wHch wIIlnvolve d1d1IOge. exc:ava1lcn. ftft 01' ~t of wel1ands 01' wat8lS of the Unlted Stat..
ewn ttlcM _11andI OJtsIde of the JUllsdlctton of the DNR. mo( r1IClUie an IndMduClI perrrit from the U.S. Atrrr( C~ ot Engi'leen. P8ISOI'lI propalng
such plOjec1s JtlouId conh:x:t the Regulatay FunctIons Brcnc::I'I. Oepattrnent of the Aim(. CcrJ:>> of ~. St. PaU 0Isll1c:t. 180 Kellogg Blvd. E..
Room 1421. St. PaU. M\I 55101-1479 (teiephol ~. (612) 220-0375) tor fI.lrther In(ojn oallon. klr maelnfofmotloo on the fclIowtng ac1Ic:lrw. pIeae calIlhe
PCA at (612) '297-1832.
Place a'l OX" In the opplIcoble box(.).
1. Pupcseoflhepn:ljec:t natural gas-fired cOmbined-cycle system (combustion turbine
heat recovery
steam generator)
2. FoIowng Ita use. the ~ted water wII be dkcharged dIIwctIv. I81aned tor Iat8t
dlsd'large. 01' colect8d and 18tumed via a dn::1Inoge system to uface walen of the stat.. . ex )
It the retun ftow is o.n&nllV ~ U'lder a'l NPDeS dIsc:hatge pem'l/t IIIued by the
PCA. then enter pem;t nunber: MN 0 0 0 0 8 7 6
It not. a1toctl a map 01' drawIng with suttIclent detalll'o shaw Iocatton{s) of relun /low
disd'large(J) end I8C8Mng wat8lI.
3. The project wi ...ut In dIWnIon of sufcce watwt frcm one 'wC1.t.....t; to another or
ground waterfll::m one aqUfw to another oquIfw. . . (
4. The P<<lIect wllr'NcNe grou-d watwt punpout tor rwmecIcI ocflcn at a .,. with
conta I ill .oted gcund watwt. (
5. The projec:t w111nYo/ve water cppIcpriatIcn for ITliN'1Q cpetatlonl. (
6. The project or ac1Mty wi not Involve arrv of !he ~.
ApplIcant Name (type or print)
Applicant SIgnature
ApplIcant Addr_
ERAD - RSQ-8 - 414
ThIs irtfotmatfon If available In an
altemottve fcxmat ufX'I1 request.
Mall M Is MN 55401
For 8ddIdonaJ lmonnallon and asalstanc:e.
cantad the appoprf.w Regional OffIce or the
OMIion 01 w...1n St. P.uI.
Reglan 1 2115 Blrdlmont Beach Road N.E.
BemIdJ. UN 56801
(218) 755-3973
RegIon 2 1201 East HIghway 2
Grand RapldI. UN 557...
(218) 327.w18
~n31~1Mn~.om.
BrU1etd, UN 5&401
(218)828-2805
. ~n" Box 758. Highway 15 South
New um. MN 56073
(507) 359-aOS3
RegIon 5 P.O. Box 8247
Rochester. UN 55903
(507) 285-7430
RegIon 8 1200 Werner RoIId
SL Paul. UN 55108
(812)772-7910
Central 500 Lafayette Ro.d
OffIce St.Plul,MN 551~
(812) 29fS..48OO
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Northern States Power Co. - Bla.ck Dog Date started Z/lO/50
Date completed 3/1S/50
No. of days 22
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. '"Date 3/15/50
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Time to clear
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BENEFITS OF NATURAL GAS UTILITY COMPETITION
TO THE PEOPLE OF PRIOR LAKE, MN
While the benefits of free enterprise have been apparent and envied throughout the
world, as the city staff and council, it is your duty to show the permanent, tangible
benefits of utility competition to the constituents you serve.
The following are reasons for allowing customer choice in Prior Lake:
o EXPANDED SERVICE AREA
Prior Lake is a growing city with land areas to develop or preserve, according to
your comprehensive community plan. Those areas being developed will see
a quicker response from two competing utilities than they would from a single utility.
I Specific To Your Community I
As the city expands through development or annexation into the surrounding townships,
the fact that two utilities are competing for customers means a quicker, more
comprehensive approach to getting natural gas into those areas. Business and
homeowners won't have to convert to propane and then back to natural gas when loads
are sufficient to bring the utilities in.
Key Thought: Competition encourages more complete utility service areas.
a BETTER CUSTOMER SERVICE
For years the people of Minnesota and virtually every other state in the nation have had
to accept the existing telephone, cable television, electric and natural gas utilities in a
given area as the only option. These monopolies had a lot to learn about customer
service. Customer satisfaction is a primary reason people shop where they do for
products and services.
I Specific To Your Community I
Northern States Power's Gas Utility participates annually in a peer panel review
with other leading natural gas utilities. The most current results, dated July, 1999, rank
NSP as the number one gas utility among those participating. The ranking is derived
from customer satisfaction, system reliability and operational efficiency measures.
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Whether you have a choice at your residence or not, the fact that there are businesses
and government entities in town that have choice in gas suppliers allows the consumer
leverage to gain better service through these other channels.
Key Thought: Customer service improves when competition exists.
o INCREASED OFFERINGS
Competition forces a wider spectrum of service offerings to the customer.
Specific To Your Community I
In 1992 I NSP started offering 'joint' or 'common' utility trenching as an option. This
was the result of a utility trying to compete for business by offering a customer-
friendly service. As the free market would provide, our competitors at Reliant Energy
now offer joint trench as a service. The installation and overall ascetics of most new
developments is a direct result of competition. Many customer services which were
previously considered "non-standard" have become more attainable as competition
escalates.
When Wal-Mart came to the upper Midwest a few short years ago, they immediately
took market shares from K Mart and Target. One of their biggest advertising
campaign issues was friendly customer service. Despite our smaller size in natural
gas customers compared to Reliant Energy, NSP offers a wide range of customer
services including rebates for high efficiency furnaces, water heaters, in-floor systems
and boilers, as well as home energy audits and many other programs .
Key Thought: Competition gives customers new benefits and choices.
(J A NEW CORPORATE CITIZEN AND PARTNER
-
Traditionally, utilities have been high quality contributors to the local
business and education base of the communities they serve. NSP and Reliant Energy
are good examples of this type of social stewardship.
I Specific To The Commun.ities NSP Serves I
In the communities NSP serves, we have been active corporate citizens in many areas,
including the following:
· Chamber of Commerce membership
· Rotary Membership
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.U.S. Summary
.'
mstatewide unbundling. active programs
.StatMde.unbundling. implementation phase
.Pilot. pro gramslp artial'unbundlin g
IINo unbundling. Considering action
DNo unbundling
Retail Unbundling - United States Summary
Overview: State programs to allow residential natural gas users to select their gas
suppliers are spreading throughout the country. However, the availability,
characteristics, and participation rates of these "customer choice" programs vary widely
across states. Three states (New Mexico, New York, and West Virginia) allow all
residential consumers to choose their own natural gas suppliers, while eight states have
begun to implement statewide programs. Another nine states and the District of
Columbia have pilot or partial unbundling programs in place, and one state will start its
pilot in November 1999. An additional 11 states are considering action on customer
choice, while 18 states have thus far taken no action.
Consumer reaction to these choice programs has been mixed. In some states, such as
Nebraska, 97 percent of the eligible residential and commercial customers are electing
to choose their own suppliers. In other states, such as Indiana and New York,
participation is 2 percent or less of those eligible. Large commercial and industrial
consumers have had the option of purchasing the natural gas commodity separately
from transportation and other services for many years. State regulators and lawmakers,
who are responsible for designing and implementing retail restructuring programs, have
moved more slowly in implementing choice programs for residential and small-volume
commercial customers, traditionally known as "core" consumers, until they could ensure
reliable service. In several cases, a local distribution company has initiated the
development of a choice program for its customers.
EJA Data: In 1997, the United States had 56,186,958 residential and 5,004,384
commercial customers. They consumed 4,984 and 3,219 billion cubic feet of natural
gas, respectively. The average prices paid for natural gas purchased from local
distribution companies by residential and commercial customers were $6.94 and $5.79
per thousand cubic feet, respectively. The average city gate price in the United States
was $3.66 per thousand cubic feet..
Eligibility/Participation in Retail Choice Programs:
Status as of June 1999: Number of Residential Customers
Eligible Participating
Category/State
Total 1997
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1 ~ota~~rcent of 1997 ~~t Percent of ~~rcent of 1997
I otal I Eligible otal
!Statewide Unbundling: Active Programs
New Mexico 443,167 443, 100 00 0
167
14,07 58,4
Nft York 4,077,385 17,38 100 1.4 1.4
5 88
West Virginia 362,432 362, 100 58 0.02 0.02
432
4,88 58,5
~ubtotal 4,882,984 2,98 100 1.2 1.2
4 46
Statewide Unbundling: Implementation Phase
1,26 839,
Georgia 1,553,948 ~,50 81.2 66.5 54.0
5 000
Maryland 890,195 ~84, 43.2 83,7 121.8 9.4
362 75
Massachusetts 1,204,494 183,0 5.9 18,7 22.6 1.6
00 67
New Jersey 2,193,629 p4,1 2.5 54,1 100 2.5
00 00
1,71 456,
Ohio 3,041,948 6,87 56.4 ~6.6 15.0
3 058
~,50 1,45
Subtotal 8,884,214 10,84 39.4 1,70 141.5 16.3
0 0
Pilot Programs/Partial Unbundling
D.C. 135,000 135, 100 17~ 50 5.6 1s.6
000 0
Illinois 3,521,707 ?7,O 0.8 8,10 30.0 J.2
00 0
Indiana 1,509,142 510, 140.4 6,00 1.0 J.4
000 4
Michigan 2,859,483 NA I- 192, - 5.7
660
Nebraska 444,970 76,7 17.2 4,0 96.5 16.6
16 00
Virginia 812,866 53,0 6.5 16,0 30.2 2.0
00 00
Wisconsin 470,045 ~O,O 4.3 1,52 17.6 P.3
00 6
Subtotal 9,753,213 '*921 "'13.4 ~05, '*12.3 ~.1
,716 790
9,3 1,81
Total Programs 23,520,411 05,5 *45.0 6,03 '-17.5 7.7
40 6
U.S. 1997 Total 56,186,958 - I- - l- i-
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*Excludes Michigan.
NA= Not available. - = Not applicable.
Note: Three other states (California, Colorado, and Pennsylvania) are in the implementation phase of
statewide unbundling, but eligibility and participation data are not available. Also, four other states
(Delaware (pilot begins in November 1999), Montana, South Dakota, and Wyoming) have pilot programs
or partial unbundling, but residential data are not available.
Sources: Total 1997: Energy Information Administration, Natural Gas Annual 1997 (October 1998).
Eligibility and Participation: State public utility commissions (June 1999).
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