No Altamont Power Plant

In addition to the environmental impact report claiming that there are “few residences” in the vicinity of the site, there is the crucial issue of “sensitive receptors” which apparently have special consideration under the law.  A “sensitive receptor” is described in the report testimony as:

“A sensitive receptor, for purposes of a public health analysis, is an establishment that houses sensitive individuals (e.g., children, the elderly, and individuals with respiratory diseases), such as a school, hospital, a daycare facility, or a nursing home.”

The report claims:

“The applicant indicated, and staff verified, that there is one “sensitive receptor” within a 3-mile radius of the project site (EAEC 2001a, pages 8.4-8, 8.12-1)”

This may have been true in 2002.  However, today, there are at a minimum 12 “sensitive receptors” within a 3-mile radius.  They are:

1. Wicklund Elementary School
2. Bethany Elementary School
3. Brooke’s Busy Bees Day Care
4. Future Stars Daycare
5. Happy Home Day Care
6. Junior Art Studio and Day Care Center
7. Little Star Daycare
8. Love’s Family Preschool and Childcare
9. Mary’s Little Lambs
10. Mountain House Monkeys - Preschool & Daycare
11. Mountain House Preschool
12. Precious Babies Child Care

This is important primarily for the reason that all of these “sensitive receptors” are downwind from the site, whereas the only sensitive receptor used in the original analysis is not downwind.

This comes into play in the health risk assessment in, at a minimum, the following specific way. The report says:

“The applicant’s estimates of the EAEC’s potential contribution to the area’s carcinogenic and non-carcinogenic pollutants were obtained from a screening-level health risk assessment conducted according to procedures specified in the 1993 California Air Pollution Control Officer’s Association (CAPCOA) guidelines. The results from this assessment were provided to staff along with documentation of the assumptions used (EAEC 2001a, pages 8.1-42 through 8.1-44, and pages 8.6-4 through 8.6-8). This documentation included:
Pollutants considered;
Emission levels assumed for the pollutants involved;
Dispersion modeling used to estimate potential exposure levels;
…”

Bold emphasis mine. Dispersion modeling means more or less “where the wind blows the toxins.” Given the wind patterns with which we are all too familiar, we know from a common sense perspective that the upwind/downwind distinction is of critical importance in determining where the toxins will be most concentrated. By chance, I have done similar kinds of modeling professionally, and know that no matter how they modeled this before, that model is now irrelevant using the assumptions that they claimed to have used.

This entire analysis must be reconsidered from scratch. The language of the extension grant does not require this. I intend to work with the CEC to correct this serious mistake.  Preferably by simply voiding the permit and asking Calpine to start over if they want to pursue this in 2008 rather than in 2002.

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