Don't Waste Arizona, Inc.

A non-profit environmental organization created for the protection, conservation, and preservation of the human and natural environment in and around Phoenix, and the state of Arizona.



Chemical Spill Emergency Plan

nukes wont halt climate change











All of these power plants will be major sources of air pollution per federal definition and statutes, also known as Title V sources. They will all, at a minimum, be required to utilize the Best Available Control technology. Power plants in non-attainment areas will also have to meet the Lowest Achievable Emissions Rate (LAER) standard. They will still be allowed to emit millions of pounds of air pollution each year.

All of the combined cycle power plants will be using a newly-developed technology to control the emissions of NOx, which power plants really crank out as their power is derived from combusting fuels. Selective Catalytic Reduction (SCR) has emerged as the technology all of these combined cycle power plants plan to use. SCR entails injecting ammonia into the exhaust across a catalyst bed, causing a reduction reaction that greatly eliminates (controls) NOx. With SCR, NOx can be reduced tenfold from previously achievable levels, to about 2.5 ppm per unit fuel. The agencies that issue air permits are myopic about reducing "criteria pollutants" (CO, VOCs, NOx, SOx, PM10) and ignore other impacts in their considerations. The "risk" from NOx emissions may be traded for the risks from ammonium sulfate, and the public may be getting more risk from the ammonium sulfate.

The SCR technology requires excess ammonia be injected into the exhaust stream so that there will be enough to react, but the excess ammonia combines with sulfates in the air above these power plants to form tiny particles (PM10) of ammonium sulfate. In fact, 20-30% of all of the PM10 that these combined cycle power plants are projected to emit will be these ammonium salts. Ammonium sulfate specifically causes shortness of breath, coughing, and respiratory irritation/inflammation. PM10 (particulate matter 10 microns or less in size) is so small that your lungs are not able to filter them out. PM10 already is the air pollutant that shortens lives (respiratory and cardiac problems) and creates asthma and other respiratory ailments. Now with the effect of the ammonium sulfate, the PM10 will be even more of a problem, perhaps exponentially worse. Each power plant will put out 20-35 tons per years of the ammonium sulfate PM10, and another 80-100 tons per year of "regular PM10," so it is easy to see there will be a cumulative and adverse effect.

Because under the Clean Air Act, all PM10 is assumed to be created equal and assumed to be as harmful as mere dust, the regulatory agencies that issue air permits ignore the known extra and specific chemical hazards associated with some of this particulate matter. This unscientific approach will have especially dangerous and lethal consequences in areas where power plants using SCR technology operate and proliferate. There is actually reason to believe that it will sicken many and even kill some people. Power plants putting as much as 100 tons of a respiratory irritant into the air, along with hundreds of tons of other particulate matter, will obviously have an adverse impact on people's health.

There are already studies showing that of all the criteria pollutants, PM10 is the pollutant that causes the illnesses and deaths. A December 14, 2000, study titled, "Fine Particulate Air Pollution and Mortality in 20 U.S. Cities, 1987-1994," published in the New England Journal of Medicine, concluded, "There is consistent evidence that the levels of fine particulate matter in the air are associated with the risk of death from all causes and from cardiovascular and respiratory illnesses. These findings strengthen the rationale for controlling the levels of respirable particles in outdoor air."

And there are other studies that finger sulfates specifically as causing increased mortality. A study titled, "Particulate air pollution as a predictor of mortality in a prospective study of U.S. adults, published in March 1995 in the American Journal of of Respiratory and Critical Care Medicine, states, "Increased mortality is associated with sulfate and fine particulate air pollution levels commonly found in U.S. cities." A German study, "Environmental air pollution and lung disease in children, states, "Sulphates will increase the use of medication and decrease lung function in asthmatic children."

Automobile exhaust is another source of ammonium sulfate particulate matter. Isn't it curious how the nation had cars switch to  catalytic converters to eliminate lead emissions from autos because of the health hazards they presented, and replaced the lead with a health hazard that causes asthma. And now the nation has an epidemic of asthma among its children. The power plants will make it worse.

Read "Death, Disease & Dirty Power"

Natural gas-fired power plants are a potent source of extremely hazardous tiny particles 2.5 microns or less in diameter (PM2.5). All of the particulate matter produced by the gas-fired turbines of power plants will be less than 2.5 microns in diameter. In fact, all of it will be less than 1 micron in diameter, and consist largely of organic compounds referred to as products of incomplete combustion (PICs). Some hazardous trace metals will also be released along with the PICs.

EPA has been studying PM2.5 for some time, which lead the agency to propose new standards for exposure and emissions. See Particulate Matter Research Program Stategy: External Review Draft, which describes the EPA's research strategy in the areas of health, exposure, risk assessment, and risk management research.

An introductory EPA discussion of PM2.5 is at

In the eastern states, the study shows PM2.5 was mostly comprised of ammonium sulfate (40%-60% of the total mass), with another 5% to 15% as ammonium nitrate, and carbon from incomplete combustion accounting for another 30%-40% of the mass. Many of the medical studies that link PM2.5 or particulate matter to heart attacks and deaths were based on data from the New England states.

In the western states, only 5% to 15% of the PM2.5 was ammonium sulfate, and ammonium nitrate accounted for 1% to 35% of the total mass. The percentage of carbon from incomplete combustion ranged from 35% to 65% of the western samples. The soil content of the samples from both the east and western portions of the country were about the same, 5% to 10% in the east, 5% to 15% in the western states.

There will be severe health implications for the West as natural gas-fired power plants commence spewing hundreds of tons of PM2.5 and ammonium sulfate annually. The West is arid to semi-arid, and the hundreds of tons of PM2.5 and ammonium sulfate spewed by these power plants will linger in the air far longer than in the East, where there is significant rainfall to wash it out of the air.


As if that wasn't enough, there is the issue of the ammonia stored on-site at the power plant and the additional risks the ammonia presents. It will common to see 15,000 to 20,000 gallon tanks of ammonia stored at these facilities. Anhydrous ammonia is particularly dangerous, but even aqueous ammonia is risky. A catastrophic release of ammonia from a 15,000 to 20,000 gallon tank could be enough to kill and injure people a few miles away, depending on weather conditions. Facilities with this much ammonia on-site have to report and participate in a new federal program required by 112r of the Clean Air Act called the Risk Management Program. (In fact, Maricopa County's air permits for these power plants are even mentioning these Risk Management Program requirements, even though the agency itself doesn't have jurisdiction over that particular program.)  Note: If the facility uses aqueous ammonia in a concentration less than 20%, it is not subject to this special planning and preparedness requirement, but will still have to prepare an emergency plan under the Emergency Planning and Community Right-To-Know Act [EPCRA]

More about the RMP Program and its issues is available CLICK HERE..

More about EPCRA and ammonia at

In the rural areas, there will not be sufficient resources to respond quickly enough to prevent deaths and injuries. The responders simply do not have the equipment and infrastructure. People can shelter from the ammonia, but it will infiltrate their homes within a given amount of time and reach harmful or even lethal concentrations before the responders can arrive. When the release occurs, unless a rescuer arrives in a timely manner with his/her own SCBA (self-contained breathing apparatus) and one for each person to be rescued, there will be fatalities and injuries. The may also be issues of evacuation routes sufficient to allow a timely evacuation. And there will be issues of notification and preparation.

In urban areas, there might be a quicker response, but with the population densities, there are similar problems of resources. A large population will be at substantial risk.

Both rural and urban areas will see a heightened risk along the transportation route of the ammonia. A tanker of ammonia could harm people 2-3 miles on either side of the transportation corridor, in the event of an accident that ruptures the tanker. Only one out of four chemical spills are transportation incidents. Far more occur during the off-loading of a chemical at the industrial site.