Diesel Peaker Plant

Developer Plans to Choke
Bremerton WA Community of 3,000+
Under Huge Plume of Untreated Diesel Exhaust

Bad Location for a Bad Idea

Tenaska Corp pitches 218MW Biodiesel "Peaker" Plant to PSE

PSE has received {{100+ responses}}{(source: May 3, 2023 conversation w/Tenaska local representative)} to their recent {{2021 All-Sources RFP}}{(https://www.pse.com/en/pages/energy-supply/acquiring-energy/2021-All-Source-RFP)}1.1 for capacity, logistics and infrastructure improvements needed over the next 10 years as they deal with the clean energy transition, plus projected population growth.
PSE's concerns are legitimate:
- meeting peak demand in winter cold-snaps
- meeting peak demand in summer heatwaves
- making the Kitsap grid more resilient.

Breakdown of either of 2 incoming 230kV transmission lines, or the 2 main substations they feed, could cause power interruptions for many Peninsula customers, and take up to several weeks to fix.

There are many possible approaches to addressing these issues.

Tenaska's {{initial proposal}}{(Copyrighted material we cannot reproduce in whole; available by Public Records request from Puget Sound Clean Air Agency; ask for NOC #12284)} is backwards and dirty.
It's definitely the cheapest—it writes off the fortune, health and well-being of thousands of people living next to its proposed location as being completely worthless.

Mar 30, 2023: Soundview Estates HOA Board calls on local leaders & regulatory agencies to deny permission for Tenaska's proposed project.

It’s dirty and dangerous

Biodiesel exhaust lacks a few noxious elements of ordinary fossil-fuel diesel exhaust, but don't let anyone tell you it's "safe". Unless treated (which Tenaska does not intend to do), it includes higher proportions of very fine particulates2.1—so small, they can move directly from lungs into the bloodstream. And, it includes unregulated chemicals for which no safety limits have yet been established.

It’s inefficient

Instead of a cleaner, more efficient gas turbine design that saves ratepayer dollars over the long haul, Tenaska chose a dirtier, thirstier, cheaper-up-front unit.

It’s impractical

When we asked, Tenaska could cite only only one biodiesel-fueled power plant existing anywhere else in the world today: a biodiesel turbine generator in Kemi, Finland4.1. But it's designed to run continuously, not intermittently like a peaker plant; and it's a cleaner, more efficient design, using biodiesel produced at the wood pulp factory it's literally in the middle of.

It’s unfair and unwise

The WA Legislature carefully crafted its 2019 Clean Energy Transition Act5.1 to require utilities to share out the burdens and benefits of its changes fairly and equitably, instead of just dumping the dirtiest facilities onto the most hard-up communities. This project reverts right back to those old, engrained bad habits.

It’s backwards-looking

Experts reviewing PSE’s draft Clean Energy Implementation Plan called out its significant disregard for non-emitting alternatives, like {{EE/DR/DER}}{(EE=Energy Efficiency (rewarding customers by subsidizing investments in improved insulation, more-efficient appliances or heating & cooling, upgraded windows & doors, etc.);

DR=Demand Response (rewarding customers for reducing demand in peak periods on [automated] advance request by the utility);

DER=Distributed Energy Resources (Rooftop & ground-mount solar PV, battery systems, small wind turbines, etc., owned by individual customers; community solar arrays, owned by customer cooperatives; etc.)} programs. They cite documented positive results from other utilities in our region which made earlier, bigger commitments to building these programs. PSE could directly fill the capacity “hole” it wants to plug by boosting its investment in those programs, instead of noxious diesel-spewing peakers.

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Scale representation of fine beach sand particle, human hair, and PM10 and PM2.5 emissions particulates

Raw biodiesel exhaust lacks some of the noxious elements2.6 of ordinary diesel exhaust, but not all.

One major component both do have in common is thousands of tons of nitrogen oxides2.5—which have long-proven adverse health effects2.1,2.3, as well as accelerating climate change.

Biodiesel exhaust actually includes higher proportions of very fine particulates2.2—so small, they can enter your bloodstream via your lungs.

And, it adds unregulated and under-researched chemicals that come from the novel feedstock2.9 oils—emissions for which no safety limits have been established yet. But there's published early evidence of inflammatory2.3 and cytotoxic effects2.8 in laboratory studies.

Overall long-term public health impacts? No-one can quantify them.

But this plant will cause more premature death—its raw, untreated pollutant emissions will kill people2.4 downwind, particularly the vulnerable: infants, children2.7, the elderly, and people with cardiac2.6 or respiratory issues.

Just like no car or light truck is sold in 2023 without sophisticated control systems that have radically cleaned up vehicle emissions from the early days of open pipes, today there are plenty of proven methods available to clean up raw exhaust emissions from a turbine-powered generator.

But Tenaska's proposal rejects all available smokestack abatements—instead, asking the Puget Sound Clean Air Agency to let them pump raw, untreated biodiesel exhaust directly into the air above our homes.

The only commitment in the initial application was that the plant would scrape barely under EPA's limits for federally-regulated pollutants, by limiting total operation time to under 470 hours a year.

After Clean Air Agency engineers responded with some pointed questions, they withdrew the application "for refinement". And in later discussions we've had with them, they acknowledged they “couldn’t make it pencil” without more than doubling that limit.

Soon we should see what the "refined" application "commits" to limiting its maximum annual hours of emissions to. You might want to make PSCAA's New Construction Applications listing your new browser home page—after their next application is posted there, we'll have just 15 days to demand public hearings.

And if the regulators approve the proposal anyway—despite popular pushback—it'll be just as vital to see how the Agency proposes to disincent the developers from blowing past the licensed limits, shrugging off possible penalties as a minor "cost of doing business".

Plenty of us aren't too keen on us, our kids, or our elders being Tenaska's involuntary guinea pigs.

The cheap, dirty & crude gas turbine design Tenaska proposes nearly doubles the fuel burned, and doubles the exhaust emitted every MW/hour of electricity produced, versus cleaner, more-efficient (and more expensive up-front) two-stage gas turbine generators.

That's because the more-sophisticated two-stage ("Combined Cycle") design adds a Heat Recovery subsystem that captures almost as much waste heat energy again from the exhaust stream as the cheaper, dirtier ("Single Cycle") turbine approach manages to deliver in its single mechanical stage—heat energy the cheap & dirty unit sends straight up its exhaust stack.

Although single-stage units cost less up front, long-term, the extra fuel they guzzle gives the cost advantage to two-stage systems—even more quickly, if reduced emissions impacts to the environment and public health are properly priced in.

Compare unit price ("LCOE") for "Gas peaker" with "Gas (combined cycle)" in this chart:

Single-stage units do spin up from a cold start about 15 minutes faster, too. But two-stage systems can easily meet and beat that small head-start by adding a relatively small on-site battery—ready in mere milliseconds to instantly meet demand until the two-stage unit reaches service speed.

Single-Cycle Gas Turbine schematic illustration

Single-stage turbo generator

Combined-Cycle Gas Turbine schematic illustration

Two-stage turbo generator

The reason the world has no other biodiesel peaker plants? Maybe because biodiesel is “contraindicated” for backup/standby generators—according to engineers at John Deere, Inc.

(Oh, and engineering studies by Portland General Electric reached the same adverse conclusion, too.)

Biodiesel can’t be stored for more than 45 days before it degrades too badly for reliable service. It also degrades even faster in conditions of extended heat or cold.

After every use, John Deere recommends emptying the tank, discarding all left-over biodiesel, and cleaning out the tank. A tall order, when your tank capacity is 1.8 million gallons

There are applications where biodiesel may make sense. But they're mostly in transportation, which is where our limited volumes of biodiesel production ought to be going instead.

The plant location is also the cheapest choice: right next to the incoming feed lines.

But it’s also right on top of some of Bremerton’s newest and most concentrated residential developments.

Besides recently-completed Soundview Estates, under-construction Soundview West, and the in-planning Buckingham Properties development, there are lots of other zoned-residential parcels nearby, owned by home developers, which the City of Bremerton expects to fill with new residents as its population grows by a third in the next 10 years.

And that's just the new homes: hundreds of other households already sit vulnerable to the toxic plume of exhaust gases and particulates fallout that will stream raw and untreated from the plant's smokestack, if built.

Being next to these current and proposed homes for around 3,000 Bremertonians mean they'll be forced to breathe its untreated emissions, while at the same time their homes suffer massive losses of real-estate value.

Realtors estimate that homeowners near the plant are likely to see a more than $100 million loss on the overall net worth of their homes.

The raw exhaust, with its damaging fine particulate fallout, will fill the air of a census tract that already suffers very high vulnerability indexes, per the WA Department of Health—compounding the unhealthy effects of heavy truck traffic and other industrial airborne pollutant sources, along with proximity to 3 national-scale SuperFund sites.

Those suffering most from the plant’s additional air pollution will be children, the elderly, and anyone already coping with respiratory or cardiac illnesses. WA Dept of Health maps show that this census tract is already among the most disadvantaged areas of Kitsap County.

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For very little extra cost, the plant could be set back a mile or so further back onto the Ueland Tree Farm property.

Prevailing winds would then bypass the main residential developments—and extra distance would help dilute contaminant concentrations on the way.

Doing so—and most importantly: adding pollution abatement controls to treat the exhaust stream—would substantially reduce human health risks.

We asked Tenaska to consider adapting their proposal in these small ways.
They acknowledged the benefits for public health, but said "it's too late to change our proposal now".

So, persuading PSE, the UTC, the Clean Air Agency, and the City Council to either rethink this approach, or kill the project outright, is our only hope.

We need your help to make a big impression on these groups.

Right now, today, combustion-fueled peaker plants—which tend overwhelmingly to get dumped on the doorsteps of vulnerable and marginalized communities6.1,6.2—across the country, and internationally, are being decommissioned and replaced6.3 left and right by renewable solar and wind sourced-power, backed up by a new class of battery storage systems.

The cost trends of solar photovoltaic and wind power have plummeted exponentially year over year, boosting their cost effectiveness far past nuclear and fossil-fuel sources.

No less an authority than the US Government's Energy Industry Administration acknowledged this May that—with all subsidies removed—solar and wind now costs 25% less than any combustion-based power—even when the cost of storage systems is included to offset the intermittency of renewables.

Grid-stabilizing "hybrid" renewable-plus-storage deployments have been growing exponentially over the last 5 years.

And according to NERC (North American Electric Reliability Corporation) forecasts, essentially zero other utilities on this continent are betting on liquid biofuels (like biodiesel) as a strategically-significant fraction of their future resource plans for the decades ahead. It's under 1% of projected supply; the only possible reason to touch it is to slurp up some sweet Congressional largesse aimed at placating Iowa soy producers.

The future of electrical power is here—enabled by instant, ubiquitous digital communications and control—and it revolves around decentralized networks, micro-grids, and non-emitting sources: energy efficiency programs, demand response programs, and especially distributed energy resources.

It exploits the staggering scalability of solar photovoltaic systems and new battery technologies, plus the unbeatable clean, free fuel advantages of both solar and wind6.4.

Which, when reasonably accessible global reserves are plotted to scale, lead to one inescapable conclusion: fossil fuel and nuclear generation are so inefficient, damaging, and limited, they simply have no place in the future.

What's still new news in utility thinking is the mold-shattering paradigm of Firm Renewable Power6.6: reliable committed supply, available 7/24/365, sourced 100% from renewables, through a combination of whole-system design, in place of the usual facility-scale piecemeal approach, and coordination of multiple key elements:

• perfect load forecasting6.7
overbuilt-for-curtailment-by-design solar6.8
• a sprinkling of wind
• limited storage
• geographically-dispersed installations

The ability to deliver rock-steady supply to match real-world load curves has been robustly modeled against extensive high-resolution national and regional datasets, drawn from regions as disparate as Italy; Switzerland; Minnesota; California; & New York State6.7.

It's a far more resilient and adaptable architecture—and the best part: it can be implemented and delivering bulk power for unit prices ("LCOEs") that are the same or less6.8 as today's systems—but it's a difficult paradigm shift for old-school command-and-control-fixated cultures like the utility industry, rooted in the late-19th-Century analog worldview of its origin.

Here's a dead giveaway to tell if you're talking to an engineering type who's still mired in the obsolete paradigms of your great-grandfather's power grid: if they talk about the necessity of fossil or nuclear "baseline" sources to offset/backup "the intermittency of renewables", or if they stare blankly at the term "implicit storage"6.7, they haven't got the memo yet.

Oh, yeah:
The Peninsula grid's resilience could also be enhanced in another non-emitting way: by repairing old and adding new underwater feeder lines, increasing our interconnections to the larger regional grid. PSE is already planning to do this, rushing it through at break-neck pace: In. 7. Years. (So Tenaska told us, privately.)
We think PSE should, um, enlarge and accelerate those efforts.

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Join Our Campaign!

Let our elected officials & regulators know how you feel about dropping a massive new emissions source right into your back yard…

Citations & Reference Info

1.12021 All-Sources RFPPSE's 2021 Request For Proposals 
2.1EPA 2019 Integrated Science Assessment for Particulate Matter (supplemented)U.S. EPA. Supplement to the 2019 Integrated Science Assessment for Particulate Matter (Final Report, 2022). U.S. Environmental Protection Agency, Washington, DC, EPA/635/R-22/028, 2022 
2.2CARB: Summary: Diesel Particulate Matter Health ImpactsDiesel Particulate Matter Health ImpactsARB estimates that diesel PM contributes to approximately 1,400 (95% confidence interval: 1,100-1,800) premature deaths from cardiovascular disease annually in California.
Additionally, exposure to diesel exhaust may contribute to the onset of new allergies; a clinical study of human subjects has shown that diesel exhaust particles, in combination with potential allergens, may actually be able to produce new allergies that did not exist previously.
2.3Particulate Matter Is a Surprisingly Common Contributor to DiseaseIntegr Med (Encinitas). 2017 Aug; 16(4): 8–12."Particulate matter is a huge contributor to indoor and outdoor air pollution and a significant factor in many major diseases. Those living in cities, and especially those working in traffic or living near roads, have substantially increased risk of several diseases, especially autoimmune, cardiovascular, respiratory, and neoplastic. Intervention is primarily based on reducing exposure and using appropriately sophisticated air cleaning systems."

"Unfortunately, although the total mass of PM from the biodiesel fuels is lower than for regular diesel, they produce much more of the ultrafine particles that penetrate the lungs more deeply, resulting in greater toxicity. Also, although biodiesel exhaust has lower sulfates, they also produce higher levels of nitrogen oxides than regular diesel exhaust."

"Researchers who studied animals exposed to each type of exhaust surprisingly found that biodiesel resulted in greater adverse cardiovascular, hematological, and proinflammatory changes than regular diesel."
2.4Particulate matter is not ‘junk science.’ Decades of research show it affects human healthPolitifact article debunking deceptive misstatement on “The Ingraham Angle”, June 7, 2023"The health effects linked to particulate pollution exposure have been studied and documented for decades. These effects include respiratory and cardiovascular health problems and premature death."

"The Environmental Protection Agency’s assessment of particulate matter shows clear evidence that exposure to particulate matter affects health."
2.5The Harmful Effects of Nitrogen OxidesSVI Industrial, manufacturers of Selective Catalytic Reduction Systems"NOx does significant damage to the respiratory system over time. In areas affected by smog, symptoms including coughing and throat and chest irritation commonly develop. People begin to find it hard to breathe due to permanent damage to their lungs caused by chronically inflamed tissue. People who suffer from asthma also find that smoggy environments exacerbate their asthma symptoms because their bronchial passages become inflamed and hyperactive."

"Also, it was found that more children experience allergy problems—both pollen and food related—and studies indicate that fuel-burning pollution containing NOx has a strong correlation."
2.6Acute cardiovascular effects of controlled exposure to dilute Petrodiesel and biodiesel exhaust in healthy volunteers: a crossover studyDOI: 10.1186; Particle and Fibre Toxicology, 14 June 2021"Despite differences in PM composition and particle reactivity, controlled exposure to biodiesel exhaust was associated with similar cardiovascular effects to PDE. We suggest that the potential adverse health effects of biodiesel fuel emissions should be taken into account when evaluating future fuel policies."
2.7Soy Biodiesel Exhaust is More Toxic than Mineral Diesel Exhaust in Primary Human Airway Epithelial CellsDOI: 10.1021"The exhaust output of biodiesel was found to contain significantly more respiratory irritants, including NOx, CO, and CO2, and a larger overall particle mass. Exposure to biodiesel exhaust resulted in significantly greater cell death and a greater release of immune mediators compared to both air controls and ULSD exhaust. These results have concerning implications for potential global health impacts, particularly for the pediatric population."
2.8Biodiesel exhaust-induced cytotoxicity and proinflammatory mediator production in human airway epithelial cellsDOI: 10.1002/tox.22020"Different fuel types produced significantly different amounts of exhaust gases and different particle characteristics. All exposures resulted in significant apoptosis and loss of viability when compared with control, with an increasing proportion of biodiesel being correlated with a decrease in viability. In most cases, exposure to exhaust resulted in an increase in mediator production, with the greatest increases most often in response to B100."
2.9Toxicity of different biodiesel exhausts in primary human airway epithelial cells grown at air-liquid interfaceDOI: 10.1016/j.scitotenv.2022.155016"Despite the concentrations of all exhausts used in this study meeting industry safety regulations, we found significant toxic effects. Tallow biodiesel was found to be the most toxic of the tested fuels and Canola the least, both for blended and pure biodiesel fuels. This suggests that the feedstock biodiesel is made from is crucial for the resulting health effects of exhaust exposure, even when not comprising the majority of fuel composition."
2.10Potential hazards associated with combustion of bio-derived versus petroleum-derived diesel fuelDOI: 10.3109/10408444.2012.710194"Nitrogen oxides are regularly increased. Among the non-regulated emissions aldehydes are increased, while polycyclic aromatic hydrocarbons are lowered. Most biological in vitro assays show a stronger cytotoxicity of biodiesel exhaust and the animal experiments reveal stronger irritant effects. "
2.11Biodiesel fuels: A greener diesel? A review from a health perspectiveDOI: 10.1016/j.scitotenv.2019.06.002"The limited human testing further suggests short-term exposure to biodiesel engine exhaust is associated with cardiopulmonary outcomes that are comparable to diesel. Additional information about the health effects of biodiesel engine exhaust exposure is required for effective public health policy."
4.1Doosan Škoda Power to deliver 270MW turbine generator for new bioproduct mill in FinlandNS Energy, 17 Dec 2020"The turbine will have a condensing turbine section and will be equipped with two steam bleed connections of different pressure levels." — a combined-cycle turbine, in other words.
5.1Clean Energy Transformation Acthttps://app.leg.wa.gov/RCW/default.aspx?cite=19.405&full=true 
6.1Replacing peaker power plants with clean energy solutions represents one of the most important environmental justice opportunities in the country"Clean Energy Group collaborates with local community-based organizations, regional advocates, and environmental justice groups in support of their battles to close fossil-fuel peaker power plants and efforts to replace them with zero-emission, non-combustion alternatives.""Peaker power plants are disproportionately sited in and near low-income communities and communities of color, impacting the health of tens of millions of households across the country"
6.2The Peaker Problem: An Overview of Peaker Power Plant Facts and Impacts in Boston, Philadelphia, and DetroitJuly 27, 2022, Clean Energy Group"Peakers are some of the dirtiest, least efficient, and most expensive energy sources, and most of them are located in low-income communities, environmental justice communities, and communities of color. Long-term exposure to peaker emissions, such as sulfur dioxide, nitrogen oxides, and fine particulate matter (PM2.5), can cause asthma, Alzheimer’s, heart disease, chronic kidney disease, diminished fertility, miscarriages, and other adverse health conditions."
6.3Nearly 1/3 of planned gas peakers at risk from energy storage, GTM findsMarch 20, 2018, Utility Dive"As much as 32% of new gas peaker capacity will be at risk from four-hour energy storage by 2027, according to a new GTM Research report.

GTM data show that 20 GW of new peakers — a mix of announced and expected projects — are forecast to come online by 2027."
6.4Overbuild solar: it’s getting so cheap curtailment won’t matterJune 11, 2019, energypost.eu"Oversized solar will deliver more energy in low light and reduce the need for expensive storage. It can be so cheap that daytime curtailment won’t matter."

"Our team has modelled a high-solar and overbuilt solution for the not particularly sunny state of Minnesota. The goal was to determine the least costly combination of grid-connected solar, wind and storage necessary to provide round-the-clock, year-round energy services.

The study demonstrates that overcoming the natural variability of solar and wind can be accomplished at costs below current grid costs (so-called “grid parity”) by overbuilding solar and wind resources and adopting a grid operating strategy of allowing about 20% to 40% curtailment of excess energy generation. Energy storage is also used in our model, but the superior economics directly result from substituting excess curtailable generation for more expensive storage."
6.5Why Oversizing Solar Generation is the Future of Renewable Energy and BeyondFeb 12, 2023, Khalifa Saber—a very readable presentation"It's time to challenge conventional thinking when it comes to renewable energy. The traditional approach of maximising production at all times and selling all output is hindering the progress of making solar and wind a reliable, on-demand source of energy. This mindset keeps renewables at the margin and is not cost-effective in the long run."
6.6From Firm Solar Power Forecasts to Firm Solar Power Generation: An Effective Path to Ultra-High Renewable Penetration - A New York Case StudyPublished 31 August 2020"We introduce firm solar forecasts as a strategy to operate optimally overbuilt solar power plants in conjunction with optimally sized storage systems so as to make up for any power prediction errors, and hence entirely remove load balancing uncertainty emanating from grid-connected solar fleets. A central part of this strategy is the plant overbuilding that we term implicit storage. We show that strategy, while economically justifiable on its own account, is an effective entry step to achieving least-cost ultra-high solar penetration where firm power generation will be a prerequisite."

"Using the New York Independent System Operator (NYISO) as a case study, we determine current and future costs of firm forecasts for a comprehensive set of scenarios in each ISO electrical region, comparing centralized vs. decentralized production and assessing load flexibility’s impact. We simulate the growth of the strategy from firm forecast to firm power generation. We conclude that ultra-high solar penetration enabled by the present strategy, whereby solar would firmly supply the entire NYISO load, could be achieved locally at electricity production costs comparable to current NYISO wholesale market prices."
6.7Implicit storage continues to gain support to enable renewables to deliver firm power, cost effectivelyAug 17, 2022, SolarAnywhere.com—a readable and extensively-footnoted exploration"The centerpiece of firm power-enabling strategies is implicit storage: overbuilding and curtailment of wind and solar. Implicit storage reduces real (long-term) storage requirements to the point where firm 24/7/365 renewable generation becomes economically reasonable. While the principle of curtailment (i.e., throwing away) renewable power has been known to designers and operators of remote stand-alone systems for decades, it’s still new and counterintuitive to the grid-connected PV and wind world, where curtailment is still perceived as a negative."
6.8Overbuilding & curtailment: The cost-effective enablers of firm PV generationSolar Energy, Vol. 180, March 1, 2019 — DOI 10.1016/j.solener.2018.12.074"We investigate the premium to transform a low-cost, but intermittent solar kWh into a firm, effectively dispatchable kWh. We show that a fundamental ingredient of minimizing this premium is to optimally overbuild and, as necessary and appropriate, curtail PV generation. Drawing on a case study in the State of Minnesota, we show that firm, high-penetration-ready PV generation could be achieved at a production cost at or below current conventional generation, especially when optimally coupled with wind generation."
[]version 1.1Last updated: 28 June 2023Many more references to come...


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