Tag Archives: Dominion

Anyone Remember the Coal Ash De-watering Controversy?

Bremo Power Station de-watering test results. Click for legible image.

Environmental controversies are flying so fast and furious in Virginia these days that it’s hard to keep track of them all. As for last year’s disputations, they are quickly forgotten. Remember, for instance, the wrangling over Dominion Energy’s plans for de-watering coal ash ponds at its Bremo and Possum Point power stations?

After intense negotiations, riverkeeper groups, the Southern Environmental Law Center, Dominion, and the Department of Environmental Quality settled upon a protocol for treating and monitoring the quality of effluent before it entered the James River and Quantico Creek. How has the arrangement worked out? The absence of headlines this year is one clue. The water-testing results posted on Dominion’s website provide another.

The tests, which cover pH, suspended solids, oil & grease, hardness and 15 heavy metals and other compounds, show that the water treatment process is cleaning the water to the point where the presence of most pollutants is impossible to detect.

At the Bremo station, only arsenic and chloride appeared in measurable quantities among the three samples taken in early May, and the concentration of both chemicals is less than one-tenth of the Environmental Protection Agency’s permit levels.

Possum Point power station de-watering test results. (Click for larger image.)

At Possum Point, five chemicals appear in large enough quantities to be detectable, but all are safely within prescribed bounds. One chemical, thallium, nudges up close to the permit limit but does not go over.

I don’t purport to have any expertise in these matters, but it looks as if the arrangement is working as it should. If you want to browse through a year’s worth of test results, click here.

This is far from the end of the story, of course. Dominion still must obtain permits for de-watering its Chesapeake and Chesterfield facilities. The results at Bremo and Possum Point suggest that Dominion has the de-watering process firmly under control.

However, the company has yet to receive solid-waste permits for disposing of the coal ash after it has been de-watered. Dominion wants to pursue a cap-in-place approach while environmental groups want the utility to bury the material in landfills. That issue will take longer to resolve. Among the uncertainties is determining the extent to which underground water picks up contaminants while migrating through the coal ash pits. Getting answers will require a different testing protocol than the one used for the de-watering process.

Dominion Urges Citizens to Report Suspicious Activity

PG&E’s Metcalf substation, where a sniper attack knocked out 17 transformers. Photo credit: Wall Street Journal

Dominion Energy issued an unusual press release a couple of days ago, urging customers to “report suspicious activity.”

“Suspicious activity includes anything from someone recording or monitoring Dominion Energy facilities to someone who doesn’t seem like they belong in a certain area or is behaving strangely,” said Marc Gaudette, Director of Corporate Security, Safety and Health. “What may seem like a small piece of information could be the missing piece of the puzzle that law enforcement needs to prevent an unexpected event.”

Bacon’s bottom line: Dominion, like other electric utilities, finds itself in a difficult situation. On the one hand, it is rightfully concerned about the threats to the integrity of the electric grid at the hands of terrorists or other saboteurs. The electric power industry has been on hyper alert ever since a 2014 sniper attack on Pacific Gas & Electric’s Metcalf Transmission Substation, which severely damaged 17 transformers and forced the utility to reroute electric power in order to avoid blackouts. The situation is all the more urgent for Dominion, which has shut down two of three of its Yorktown Power Stations, leaving the Virginia Peninsula more vulnerable than usual to blackouts should an accident knock out a transmission line on a hot-weather day with elevated electricity demand.

Dominion cannot survey every substation or every mile of transmission line 24/7, and it makes sense to call upon the public if someone sees something suspicious. As the press release states: “”Think security and safety… If you spot something suspicious, speak up. … Act as our eyes and ears and report any suspicious activity near a Dominion Energy facility by calling 1-800-684-8486. Of course, in an emergency you should always call 911.”

Dominion’s problem is that it can’t get too specific about what to look out for. For one, the utility doesn’t want to generate unnecessary public alarm by exaggerating the threat. Even more important, the company doesn’t want to tip the hand of any potential bad guys by getting too specific about what to look for, thus revealing potential vulnerabilities.

The result of these conflicting imperatives leaves people unclear about what exactly they should be looking for. But a half-informed citizenry is preferable to a totally uninformed citizenry. And, given the stakes involved, false alarms are preferable to no alarms. I live near an electric transmission line and substation, which I routinely ignore. Now, I’ll be keeping an eye out for… whatever…. I’m not quite sure. But better safe than sorry.

McAuliffe Moves to Cap Utility Carbon Emissions

Governor Terry McAuliffe. Photo credit: Associated Press

Big news yesterday: Governor Terry McAuliffe issued an executive order to cap greenhouse gas emissions from Virginia power plants. Unfortunately, I’m out of town on personal business today, so I don’t have time for anything more than a cursory analysis.

Said McAuliffe in a press release: ““The threat of climate change is real, and we have a shared responsibility to confront it. Once approved, this regulation will reduce carbon dioxide emissions from the Commonwealth’s power plants and give rise to the next generation of energy jobs. As the federal government abdicates its role on this important issue, it is critical for states to fill the void. Beginning today, Virginia will lead the way to cut carbon and lean in on the clean energy future.”

McAuliffe’s press release cited the job-creation benefits that would come from a shift from fossil fuels to solar energy. Last year, as solar production took off in Virginia, the solar industry employed 3,236 workers — twice the number supported by coal. McAuliffe said also invoked sea level rise to justify his move:

Virginia is already experiencing the effects of climate change in its coastal regions due to rising sea levels. The threat from frequent storm surges and flooding could cost the Commonwealth close to $100 billion dollars for residential property alone. The impacts extend far beyond our coast, as half of Virginia’s counties face increased risk of water shortages by 2050 resulting from climate-related weather shifts.

The action now moves to the Department of Environmental Quality, which the governor ordered to write the regulations.

Bacon’s bottom line: McAuliffe’s move will generate headlines and plenty of political heat — Republicans have already announced their opposition to what they call the governor’s executive overreach — but it’s far from clear what practical impact the move will have. Acknowledging that the cost of solar energy has plummeted, Dominion Energy and Appalachian Power already have forecast that they will move heavily toward renewable energy sources over the next 25 years.

The press release spoke of a “cap” on greenhouse gases and new regulations that will “reduce” carbon emissions — not merely reduce carbon intensity (carbon dioxide emitted per kilowatt of energy produced). It is possible to reduce the carbon intensity of the electric generating fleet while allowing total carbon emissions to increase, albeit it at a much slower rate, as the economy grows. If Virginia caps carbon emissions, Dominion and Apco might be required to close additional coal-fired power stations, and it is unlikely that Dominion would build a planned gas-fired power plant in the early 2020s. Cancellation of that facility could undermine the economics of the proposed Atlantic Coast Pipeline, construction of which McAuliffe has said he supports.

Expect trench warfare between utilities, environmentalists and consumer advocates in the DEQ hearings discussing how to implement the carbon caps. Also expect General Assembly Republicans to challenge McAuliffe’s legal authority to implement a cap.

Update: Apco spokesman John Shepelwich submits the following correction: “Appalachian Power no longer operates any coal-fueled power generation in Virginia and has not since 2015. Two of the three units of our Clinch River Plant in Russell County were converted from coal to natural gas; that plant is scheduled to be retired in 2026.”

Shareholders Pressure Dominion on Climate Policy

At Dominion Energy’s annual meeting earlier this month, shareholders submitted numerous shareholder proposals requiring the energy giant to adopt more environmentally friendly measures. I took note of some of them in my story about the event but never bothered to inquire about the vote results. I’ve attended plenty of annual meetings in my time, and I’d never seen a shareholder proposal opposed by management approved, or even come close to being approved. I didn’t expect any differently this time.

My bad. As it turns out, 48% of participating shares voted in favor of a resolution that would require Dominion to publish an annual statement on the financial risks that climate change poses to the company, according to the Virginian-Pilot. That total was up from the 23.5% of the vote for a comparable resolution at the 2015 annual meeting.

It wasn’t just gadfly nuns and hippies owning a few shares who voted for the resolution. That many votes required heavy support from pension funds and other institutional shareholders. It’s entirely possible that a similar proposal could pass a year from now. The proposal must be taken seriously, for its sponsors surely will be back next year.

Backers of the proposal cast the issue in terms of what is best for Dominion, not environmentalists, the environment or Mother Gaia: Climate change caused by CO2 emissions is unleashing more frequent and more damaging storms, which can expose Dominion’s infrastructure to storm damage, and will engender tighter anti-carbon regulations that could endanger its multi-billion bet on natural gas electric plants and pipelines.

“The three costliest storms in Dominion’s 100-year operating history, Hurricane Isabel, Hurricane Irene and the June 2012 Derecho, have occurred in the last decade,” states the shareholder proposal in the 2016 proxy statement. “The consensus among climate scientists is that without significant reduction of greenhouse gas emissions, climate change will continue to result in more severe and frequent storms, among other effects.”

Dominion’s restoration costs were $128 million for Hurricane Isabel in 2003, $59 million after Hurricane Irene in 2011, and $42 million after the derecho. “Additionally, between 2011 and 2012, weather events, earthquakes, and environmental regulations imposed more than $450 million in costs on the company, adversely affecting its earnings.”

Also, argued a memorandum in support of the proposal, the company does not seem to be taking into account federal or state legislation that could “either mandate greater deployment of renewable energy or assess financial penalties for the continued use of fossil fuels.” Dominion could be “betting the company” that changing laws, regulation and consumer tastes won’t leave the company with billions in stranded, uneconomic assets.

“Dominion faces serious financial challenges with regard to climate change risks that are not being addressed,” says the memorandum. “Dominion should be required to provide adequate climate risk assessments, including clearly defined actions the Board intends to take to address these risks.”

Dominion responds. Dominion management advised shareholders to vote against the proposal. Committed to being a good environmental steward, Dominion is pursuing an integrated strategy to reduce greenhouse emissions based on a diverse fuel mix, including gas, nuclear, hydro, wind and solar, the company stated. Between 2000 and 2015, the company has reduced the carbon intensity of its generating fleet by 43%, and it has forecast that carbon intensity will fall another 25% as it expands solar production to 5,200 megawatts over the next 25 years.

Dominion says it is one of the lowest carbon-intensity electricity producers in the U.S. Producers at the lowest end of the scale are pure-play renewable companies.

Also, the company responded in the proxy statement, it already reports on financial risks relating to climate change in its 10-Q forms and in its Citizenship & Sustainability Report. Three years ago, it published the “2014 Dominion Greenhouse Gas Report.”

As for the charge that Dominion isn’t taking into account the potential for tighter carbon emissions, in remarks made during the shareholders meeting, CEO Tom Farrell said that carbon regulation is coming. While some politicians have suggested that the Trump administration will roll back the Obama administration’s Clean Power Plan, Farrell said that the EPA is legally required to regulate CO2 emissions, and that a McAuliffe administration study group will come out with state-level recommendations in June.

Bacon’s bottom line: One can argue with the premises of the shareholder proposal, but it really doesn’t matter if the authors are right or wrong in their particulars. What matters is whether shareholders owning a majority of shares believe they are right. If a few more shareholders agree, joining those in the 48%, they could push through their proposal a year from now.

Farrell Defends Dominion’s Environmental Record

Dominion CEO Tom Farrell

Under continual pressure from politicians, protesters and even shareholders to develop more renewable energy, Dominion Energy (which has changed its name from Dominion Resources) offered a vigorous defense of its environmental policies at its 108th annual meeting in downtown Richmond today.

Since 2000 the company has cut nitrogen-oxide emissions 81%, sulfur dioxide emissions 95% and mercury emissions by 96% — a performance exceeded by only one other electric utility in the country, CEO Thomas F. Farrell II told shareholders.

Dominion also has reduced the carbon intensity of its electricity by 43% between 2000 and 2015, Farrell said. Carbon intensity measures the pounds of carbon-dioxide (CO2) emissions per megawatt hour of electricity produced. Dominion’s performance compares to a 23% reduction for the electric utility industry as a whole.

Carbon intensity will fall another 25% as Dominion expands solar power generation to a projected total of 5,200 megawatts within 25 years. “Solar is growing very rapidly,” Farrell said. I know that a lot of folks would like all of our power to come from renewables. That’s not realistic. That’s not affordable.”

Of greater interest to most of the shareholders in attendance, Dominion reported an 11.8% increase in earnings in 2016 and an 8.1% increase in dividends. But numerous shareholders, some owning as few as one or two shares, lined up to take the microphone during a Q&A session. They pressed for changes to Dominion’s governance practices, urged more aggressive adoption of solar power, and chastised the company for construction of the Atlantic Coast Pipeline (ACP).

Several shareholders argued that Dominion should reduce its corporate exposure to environmental risks, especially those resulting from severe weather or drastic regulatory changes implemented in response to climate change. One formal shareholder proposal recommended the company nominate a director with environmental expertise; another asked Dominion to evaluate alternate technologies as a way to comply with Paris Agreement accords to cut CO2 emissions. All shareholder proposals were voted down.

Farrell unapologetically defended the company’s environmental record, citing its achievements to date and its plans for the future.

Dominion was one of only four electric utilities to file a brief in favor of the Obama administration’s controversial Clean Power Plan, Farrell said. The plan, the status of which is now up in the air under the Trump administration, mandates major cuts to electric-utilities’ CO2 emissions, although the amount would vary depending upon how each state implements the plan.

While some have suggested that the Trump administration will scuttle the Clean Power Plan, Farrell insisted that carbon regulation is here to stay. An EPA endangerment finding, upheld by the U.S. Supreme Court, declared that the EPA is required to regulate CO2. “I have no idea what that’s going to look like. Neither does anyone else,” Farrell said. But some form of regulation is unavoidable.

In the meantime, a McAuliffe administration task force has been looking at the CO2 issue and is expected to announce its recommendations for the General Assembly next month. “There’s going to be carbon regulation, and to suggest otherwise just isn’t true,” Farrell said.

The carbon-regulation issue is particularly sensitive to Dominion because critics have argued for a rollback of a rate freeze put into effect two years ago in response to the Clean Power Plan. Now that the plan is likely to be overturned, they contend, the justification for the rate freeze — to provide rate stability amidst regulatory uncertainty — no longer exists.

Farrell also defended the “urgent need” for the Atlantic Coast Pipeline, a 600-mile pipeline that would bolster natural gas supplies to “grossly under-served” communities in Virginia and North Carolina. The pipeline has inspired fierce resistance from property owners along the route, especially in the steep mountains of western Virginia where environmentalists have raised concerns that construction on steep slopes and narrow ridges will lead to erosion and disruption to water fragile water supplies.

Large chunks of eastern Virginia and North Carolina have reached the limits of existing natural gas pipeline capacity, Farrell said. Furthermore, much of North Carolina is served by only one natural gas pipeline, Transco, making the region vulnerable to supply disruptions. He cited a recent outage on Transco that interrupted the gas supply to the company’s Brunswick Power Station near the North Carolina border, forcing it to halt generation temporarily. The ACP would provide an alternate pipeline to serve Brunswick and the nearby Greensville Power Station, which will be the world’s largest combined-cycle natural gas plant when construction is complete, as well as to Duke Energy power plants in North Carolina. Continue reading

The Failed Mountain “Decapitation” Narrative

Schematic filed with West Virginia regulators of a two-mile stretch of the proposed Atlantic Coast Pipeline near the Virginia state line.

Schematic filed with West Virginia regulators of a two-mile stretch of the proposed Atlantic Coast Pipeline near the Virginia state line. (Click for larger image.)

Environmentalists say the Atlantic Coast Pipeline will “decapitate” pristine mountaintops in western Virginia. They have no evidence to back the claim.

Last week foes of the Atlantic Coast Pipeline (ACP) leveled their most rhetorically heated charges against the 600-mile pipeline project yet. Construction teams would have to excavate some 247,000 dump-truck loads of rock and soil as they blasted a path across steep mountains and ridge lines. Describing the “decapitation” of pristine mountains, opponents likened the process to highly destructive mountaintop removal by the coal industry.

There was just one problem. The environmentalists’ calculations were based on the assumption that the ACP would flatten a 125-foot-wide construction corridor through the mountains. That assumption was inaccurate, Aaron Ruby, a spokesman for Dominion Transmission, managing partner of the pipeline project, responded at the time. On ridge lines, the company would carve out just enough space to excavate the trench, which will be “significantly narrower” than 125 feet. Without the 125-foot assumption, the rest of the “decapitation” analysis falls apart.

Ruby’s comment seemingly constituted a devastating rebuke. But pipeline foes are sticking to their guns. Building on the “decapitation” theme, the Chesapeake Climate Action Network (CCAN) is planning a rally today in front of Governor Terry McAuliffe’s office to demand that the governor use his regulatory power to “halt Dominion’s proposed mountaintop removal plans.”

A CCAN briefing paper asserts that “the choice to build along ridgelines is part of Dominion’s preferred and deliberate design. Working on these ridgelines will require creating a wide and flat surface to allow Dominion’s earth-moving vehicles and deep-trenching machines to operate and maneuver. The federal government’s report on the environmental impacts of the pipeline declares that ‘narrow ridgetops’ [will] require widening and flattening in order to provide workspace in the temporary right-of-way.”

What proof does CCAN have to back up such claims? None at all.


ANALYSIS


In a follow-up email distributed to members of the media late last week, Rick Webb with the Dominion Pipeline Monitoring Coalition (DPMC), a CCAN ally, attached a document that included the schematic above, which Dominion had submitted in a West Virginia regulatory filing. The schematic shows an elevation profile and a top-down view of the pipeline route on a two-mile section of the proposed pipeline near the Virginia border. A report by RESPEC, a geoscience engineering consulting firm hired by Appalachian Mountain Advocates, another anti-pipeline ally, estimated that construction would remove 130,000 cubic yards of material in that one segment alone.

That report, “Atlantic Coast Pipeline and Supply Header Project Volumetric Analysis,” made several assumptions. Among them, the firm created “typical cross-sections” to facilitate the computation of the volume of excavated material. One of the four cross-sections — “Ridgeline – Steep” category (shown below) — was applied to topography located on a ridgeline with an overall slope of greater than 20%.

Source: “Atlantic Coast Pipeline and Supply Header Project
Volumetric Analysis.” (Click for larger image.)

The graphic clearly shows the assumption that the top of the ridge-line will be removed in its entirety.

But the assumption is invalid. As ACP spokesman Ruby elaborated in an email: “We will not need to grade the entire 125-foot-wide construction right of way on every ridgeline. We may need to clear the entire ROW so we have room for our equipment, but we will only grade enough space so we can safely excavate the trench and install the pipe.”

There is nothing in the Dominion schematic to contradict Ruby.

In an interview with Bacon’s Rebellion, Webb acknowledged that pipeline foes were making assumptions for the purposes of their analysis, and he shifted the burden of proof to Dominion to prove their analysis wrong.

“We’re taking the information we have and saying, ‘It can be this bad,'” said Webb. “If Dominion says this is an exaggeration, show us the details to prove otherwise. Informed decisions can’t be made,” he added, until more information is made available.

Dominion has yet to file detailed construction plans for the route, Webb said. “The only detailed plans in Virginia we’ve seen is a one-tenth of a mile section in Highland County using high-tensile steel mesh nailed into the ground with six-foot nails. We want to see what they’re planning to do with the rest of the pipeline. Dominion has presented a concept. … We want to see solutions now.”

It’s one thing for pipeline foes to demand Dominion to make more information available to the public. It’s a very different thing to claim that the company intends to engage in mountaintop decapitation with devastating environmental consequences. Dominion insists that it won’t, and pipeline opponents have offered no tangible evidence to indicate otherwise. Perhaps proof will turn up in future filings to support their view. But it hasn’t yet, and pipeline foes undermine their credibility by trumpeting claims with no basis in demonstrated fact.

Dominion Sings New Tune, Embraces Solar

Dominion’s White House Solar farm in Louisa County

Dominion expects to install up to 5,200 megawatts of solar generating capacity by 2042 — about thirteen times its current commitment and enough to power 1.3 million homes — according to forecasts contained in its 2017 Integrated Resource Plan (IRP). That represents a dramatic shift from forecasts in previous versions of the long-range planning document, which is filed annually with the State Corporation Commission.

Natural gas emits half the carbon dioxide per unit of electricity than oil and coal, and solar produces no carbon emissions at all. Increasing reliance upon those two energy sources will shrink a typical Dominion Virginia Power customer’s carbon footprint (carbon dioxide emitted per customer) by 25% over the next eight years, the company stated in a press release.

“The ‘installed cost’ of large-scale solar facilities … has dropped 50 percent over the past four years,” said Paul D. Koonce, CEO of the Dominion Generation Group. “Our customers want more renewable energy, and changing economics make the transition to renewable resources easier.”

Dominion has been slow, compared to many other utilities, to embrace solar power. In past years, the company stressed that solar produced electricity only when the sun was shining, which made necessary extensive backup capacity, and that solar peak production in the mid-day did not match up well with peak demand for electricity on late summer afternoons or early winter mornings. Until now, the company had committed to building only 400 megawatts by 2020.

Environmental groups have been highly critical of the utility’s approach to renewable energy for years, and Dominion’s latest announcement changes little. The Sierra Club Virginia Chapter today attacked the utility’s continued reliance upon “dirty” “fracked” natural gas and criticized the proposed Atlantic Coast Pipeline.

“Dominion’s actions don’t match its words when it comes to promoting renewable energy,” said Kate Addleson, director of the Virginia Sierra Club, said. “Despite the fanfare, this does not appear to be a sharp change from what we have seen in the past.”

“Rather than deliver a clear energy plan, this document only serves to raise more questions about what Dominion really wants to do over the long-term and who really stands to benefit,” said Will Cleveland, Southern Environmental Law Center (SELC) attorney. “While Dominion is taking a good step toward expanding solar, they are simultaneously taking two steps back by doubling down on dirty fossil fuels.”

In related news, Appalachian Power Company also filed its IRP, forecasting the addition of 500 megawatts of universal solar by 2031, 1,350 megawatts of wind energy by 2031, and 10 megawatts of battery storage resources by 2025. “Universal” solar is the term for generating capacity that feeds into the broader system, not reserved for the use of a single customer or set of customers.

Dominion executives attributed the company’s rhetorical about-face to continued improvement in the economics of solar energy and a conviction that, despite the Trump administration’s antipathy toward the Clean Power Plan, some form of CO2 regulation will remain in place.

“We believe this balance … of solar, natural gas, and nuclear hits the sweet spot in terms of cost, environmental performance, and reliability for our customers,” Koonce said.

Dominion graphic shows the declining carbon footprint as the company’s four gas-fired power plants came online, replacing coal units and displacing out-of-state energy purchases.

Modernizing the grid. Aside from boosting the efficiency of solar panels, new technology enables utilities to better handle fluctuations of frequency and voltage on the electric grid caused by variable solar output.

“For the first time, our long-range plan discusses the need to modernize the energy grid in order to accommodate the changes in how power will be produced as well as to meet the needs and desires of our customers,” said Bob Blue, CEO of Dominion Virginia Power.

The existing transmission and distribution grids were built to facilitate a one-way flow of electricity from a handful of large power plants to millions of distributed customers. “The energy company produces a large amount of electricity at a relatively small number of locations,” Blue explained. “It then sends that power across big wires, then medium-sized wires, then small wires.”

Solar output will be more distributed. “When solar is connected, the distribution grid must become a two-way network so we can deliver energy seamlessly to everyone, including people with solar panels on their rooftops,” Blue said.

Continue reading

Avoiding Blackouts with a Remedial Action Scheme

Under its "Remedial Action Scheme" Dominion may not have to implement rolling blackouts in the Peninsula on high-risk days.

Under its Remedial Action Scheme Dominion may not have to implement rolling blackouts in the Peninsula on high-risk days.

Two years ago Dominion Virginia Power warned of dire consequences to the Virginia Peninsula if the company could not build a 500 kV transmission line across the James River. An analysis prepared by engineering consulting firm Stantec and submitted to the U.S. Corps of Engineers left little to the imagination:

Dominion will be required to implement pre-contingency load shedding (i.e. rolling blackouts) in the [North Hampton Roads Load Area] to prevent the possibility of cascading outages impacting the reliability of the interconnected transmission system. … It is estimated that rolling blackouts would initially occur 80 days a year and would continue to increase in number as load continues to grow in the area. …

The potential exists that up to 50% of the customers in this load area could be without electricity for days or even weeks until the event which caused the failure could be fixed.

Yesterday I posted an article based on an interview with Steve Chafin, Dominion director of transmission planning and strategic initiatives, that seemed to tell a different story. While the utility still said the Peninsula will be at risk for 50 to 80 days a year after shutting down the Yorktown Power Station’s No. 1 and No. 2 generators April 15, the ability to continue running the No. 3 generator up to 29 days a year will reduce that threat to about 50 days. Only if an unplanned event knocked out a transmission line — something that has happened only six times the past ten years — on one of those days would Dominion have to shed load. While there are no guarantees, Chafin told me, “We think we can get through the summer without any rotating blackouts.”

After publishing the article, I got to thinking about the marked difference in tone. Two years ago, when Dominion was trying to push the Surry-Skiffes project through regulatory approval in the face of intense opposition by preservationists, the company was stressing how disastrous things would be if the project wasn’t built. Now that the permit review by the Army Corps of Engineers is reaching its final stages and a mitigation settlement seems imminent, Dominion is downplaying the risk.

Yesterday I asked Chafin and Le-Ha Anderson, a Dominion spokesperson, to explain the change in rhetoric. They stand by what Dominion said then, and they stand by what Dominion says now, and they say there’s a legitimate explanation.

The difference between then and now is that Dominion has set up a Remedial Action Scheme (RAS).

Dominion worries about an uncontrolled, cascading blackout emanating from the Peninsula, the most vulnerable zone in the Dominion electric system and one of the most fragile in the 13-state PJM Interconnection territory. If blackouts erupted there, Dominion’s grid models can’t predict where they would stop. The United States conceivably could experience an outage as widespread as the infamous 2003 Northeastern blackout that knocked out power to millions.

With approval from the Southeastern Electric Reliability Council and PJM Interconnection, Dominion has set up an RAS to isolate the Peninsula if an unplanned outage occurs. “We put in an automatic, specialized relay scheme,” says Chafin. “If it senses certain conditions, it will immediately drop load to 150,000 customers.” The draconian action will prevent a cascading shut-down of transmission lines emanating from the Peninsula to points beyond.

Before the Remedial Action Scheme, Dominion would have had to implement rotating blackouts on high-load days before a component failure or other disruption occurred. Because the RAS responds immediately when needed, it allows Dominion to implement blackouts after the disruption.

While implementation of the RAS under a worst-case scenario would cause a massive outage on the Peninsula, it would nip in the bud an uncontrolled blackout that could rip through the nation’s electric grid. The chances of it occurring are remote, however, and it reduces the necessity of initiating precautionary, controlled blackouts when the Peninsula region reaches peak electric load some 50 or so times a year.

“We have a responsibility to provide reliability to our customers. We have an equally important responsibility to protect the safety and integrity of the grid,” Chafin says. “The automation will help to reduce the risk on a short-term and temporary basis.”

The Remedial Action Scheme will be available until the Surry-Skiffes transmission line receives regulatory approval and construction is complete, a process that will take at least another 18 months.

“We’ve been working on a Peninsula solution for a long time,” says Anderson. “We filed in 2013, and have worked with the Corps for almost four years. This is a serious situation. … We’ve had to look at what other things we can do in the meantime. This is a temporary, short-term tool that will help get us through the most critical period.”

Time to Panic Over the Closing of Yorktown Units? In a Word… No

Yorktown Power Station.

Yorktown Power Station. Photo credit: Daily Press

The day, April 15, is fast approaching when Dominion Virginia Power will be compelled by federal regulations to shut down two coal-fired generating units at the Yorktown Power Station, exposing the Virginia Peninsula to the risk of blackouts.

When the Yorktown units are shuttered, the utility will have enough electric power to supply the half million-person region from the outside most of the time. But during periods of peak demand, usually during the summer, an accident knocking one of those lines out of commission will put the region only one more incident away from uncontrolled, cascading blackouts that could spread to Norfolk, Richmond and beyond. Rather than incur any chance of disaster, PJM Interconnection, the organization that controls the transmission grid for a 12-state region that includes Virginia, would “shed load” — in other words, cut off electric power to some residents and businesses on the Peninsula.

Dominion’s proposed backup, the Surry-Skiffes transmission line, remains in a state of regulatory limbo while the U.S. Army Corps of Engineers negotiates ways to mitigate the line’s impact on a near-pristine stretch of the James River near Jamestown. Even if the Corps gave Dominion a permit tomorrow, it will take 18 months — and two summers — before the line can be built.

If I were a Peninsula business or resident, I’d be wondering, is it time to panic yet? I put the questions to Dominion: How frequent will the blackouts be and how bad will they be?

The answer: The threat is real but small in any given year, and a blackout, if it occurs, is likely to be limited in scope and duration. However, while the Peninsula might skate through the next year or two without a blackout, the situation is intolerable over the long run, Dominion warns. The Peninsula is the region most exposed to blackouts in the Dominion system and possibly the most vulnerable in the entire PJM transmission grid.

“This is a serious situation,” says Steve Chafin, Dominion director of transmission planning and strategic initiatives. When three things come together — (1) temperatures are running high, (2) the Yorktown 3 unit isn’t running, and (3) an accident knocks out a transmission line or sub-station — PJM likely will have to shed load.

Assuming normal weather conditions, the Peninsula will experience between 50 and 80 “high risk” days, Chafin says. Peak consumption is likely to occur in the summer, when temperatures are highest, although a few days may occur in the winter when temperatures are extremely low.

Although the company is closing two coal-fired units, the Environmental Protection Agency will allow it to run Yorktown 3, a oil-fired unit, 8% of the time, or up to 29 days. Using Yorktown 3 as a backup will reduce the number of vulnerable days to between 20 to 50.

Transmission lines to the Peninsula have been knocked out by accidents, component malfunctions or other causes six times in the past 10 years — an average of once every 20 months. (There have been two incidents in the past 10 years in which two simultaneous outages occurred.)

To reduce the odds of such mishaps shutting down a transmission line, the utility has been increasing its patrols of electric lines, boosting sub-station inspections and running infrared scanner. “This is not a normal mode of operation,” says Chafin. “We don’t patrol our transmission lines this frequently.”

If a once-every-twenty-months line outage occurs during one of the 20 to 50 at-risk days of heavy consumption when Yorktown 3 isn’t running, the electric grid will be at risk of an uncontrolled, cascading blackout. PJM, working in coordination with Dominion, will decide whether or not to shed load.

Should it become necessary to cut electricity consumption, the goal will be to disrupt as few people as possible and spare critical infrastructure such as hospitals and water treatment plants. PJM and Dominion would continuously run contingency models to determine the best course of action.

“Our goal is to avoid the need for temporary service interruptions, but should it become necessary, we will do all we can to limit the number of customers and duration,” Chafin says. “In the end, these are temporary measures to protect the larger grid from widespread, uncontrolled outages.”

Should blackouts occur, they likely would not last all day or affect the entire Peninsula. The company would close no more circuits than needed to drop electricity consumption to within a safe range. Giving a hypothetical example, Chafin says, “We might do two or three blocks of circuits of a few thousand customers for an hour or two.”

Dominion also would ask Peninsula customers to voluntarily conserve electricity.  “The more the conservation, the shorter the duration and the fewer people affected,” he says.

With a little luck the Peninsula might escape unscathed, Chafin says. “We’re running drills to make sure we’re ready. We think we can get through the summer without any rotating blackouts.”

Chesapeake Coal Ash Ruling — Advantage Dominion

Judge John A. Gibney Jr.

My initial reaction to Judge John A. Gibney Jr.’s ruling in Virginia’s first coal ash-related federal court case was to call it a draw. As I blogged yesterday, both the Sierra Club and Dominion Virginia Power found aspects of the judge’s order that supported their positions. But as I sort through the implications for the ongoing debate over coal ash in Virginia, I’m thinking that Dominion was the real winner in the long run.

True enough, the Sierra Club and its attorneys with the Southern Environmental Law Center (SELC) did win one important tactical victory: Gibney found that arsenic-tainted groundwater passing through the coal ash ponds at Dominion’s former Chesapeake Energy Center (CEC), did, in fact, reach the Elizabeth River in violation of the Clean Water Act.

Here’s how Seth Heald, chair of the Sierra Club’s Virginia chapter, framed that finding in a press release:

A federal court has found Dominion responsible for breaking the law and polluting the Elizabeth River. That is important for all Virginians who seek to hold the utility responsible for its mishandling of toxic coal ash. Now we must push Dominion to do the right thing and get this toxic ash out of the groundwater and away from the river, which is highly susceptible to disastrous flooding from sea-level rise and other climate-change effects.

But the judge also found that Dominion had been a “good corporate citizen,” had cooperated with Virginia’s Department of Environmental Quality (DEQ) “every step of the way,” and “should not suffer penalties for doing things that it, and the Commonwealth, thought complied with state and federal law.”

More importantly, Gibney applied what is, in effect, a cost-benefit test to any proposed remedy. While it is true that a tiny volume of leachate reaches the Elizabeth River, arsenic concentrations have been rendered harmless by dilution in the massive volume of river water. No threat to aquatic life and human health has been detectable so far. Unless evidence emerges that arsenic levels are reaching dangerous levels, he saw no justification to spend upwards of $600 million to excavate and remove the coal ash.

Gibney also found Dominion’s remedy of “monitored natural attenuation” — in effect, letting nature run its course — to be inadequate as well. He ordered Dominion to conduct more extensive monitoring of sediment, water and wildlife in and around the Chesapeake cite, and to report the results to the Sierra Club’s counsel and the DEQ. “In the event of a significant change in the amount of arsenic in the water or sediments,” Gibney wrote, “either party may move the Court for further relief.”

But Gibney’s cost-benefit test favors Dominion as the coal-ash controversy unfolds. Riverkeeper groups have opposed Dominion’s requests for solid-waste permits at its Bremo and Possum Point power stations. They argued, as the Sierra Club did in the CEC case, that evidence of contaminated groundwater migrating into nearby water bodies is grounds for removing the coal ash to lined landfills away from the water regardless of expense. But the application of Gibney’s logic to future cases would mean that demonstrating the leakage of small volumes of contamination into surface waters is not sufficient to seek a massively expensive remedy. The leakage must be on a scale to affect aquatic health and human safety.

Over a half century of burning coal at the Chesapeake power plant, Dominion accumulated 3.4 million tons of combustion residue and disposed of it in coal ponds. The ash contained high levels of arsenic — an estimated 150 tons. In 2014, samples of groundwater from ten wells around the ash landfill showed arsenic concentrations higher than 10 micrograms per liter, the groundwater protection standard set by DEQ. At one location, the judge noted, the arsenic concentration reached 1,287 micrograms per liter.

Gibney accepted the Sierra Club’s arguments that groundwater migrates from the coal ash to the surface waters of the Elizabeth River and its tributaries. In so doing, he rejected Dominion’s contentions that the groundwater was unconnected to the surrounding water bodies, and that arsenic traces found in the Elizabeth River originated from other industrial sources. Wrote the judge:

Dominion argues that because sediments move upstream and downstream with the tides, it is impossible to tell where the sediments used for the poor water samples originally came from. Although some tidal action may move sediments around, it defies logic to argue that an enormous amount of arsenic does not contribute to the arsenic in soil and water right next to it, especially given the evidence of groundwater movement from the mound outward.

While the evidence shows that Dominion does discharge some arsenic into nearby surface waters, Gibney reasoned, “it does not show how much.”

The Court cannot determine how much groundwater reaches the surface waters, or how much arsenic goes from the CEC to the surrounding waters. .. What the Court does know, however, is that the discharge poses no threat to health or the environment. All tests of the surface waters surrounding the CEC have been well below the water quality criteria for arsenic….. The CEC is surrounded by an enormous body of water, and even a large arsenic discharge would amount to a drop in the bucket.

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