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HomeMy WebLinkAboutItem PAGENDA REPORT DATE: April 8, 2002 TO: Honorable Mayor and City Council THRU: John B. Bahorski, City Manager FROM: Lee Whittenberg, Director of Development Services SUBJECT: APPROVAL OF COMMENT LETTER - HAYNES GENERATING STATION REPOWERING PROJECT DRAFT EIR SUMMARY OF REOUEST: Instruct Mayor to sign proposed Comment Letter, and instruct staff to forward to the Los Angeles Department of Water and Power. Forward staff report and approved comment letter to the Environmental Quality Control Board, Planning Commission, Archaeological Advisory Committee, and the Golden Rain Foundation for information purposes. Receive and File Staff Report. BACKGROUND: On December 19, 2001 the Environmental Quality Control Board (EQCB) received a staff report and approved a comment letter on the "Notice of Preparation of a Draft Environmental Impact Report — Haynes Generating Station Repowering Project, Long Beach ", prepared by the Los Angeles Department of Water and Power (DWP). The City comment letter focused on the following issues: • Air Quality • Hydrology & Water Quality • Noise The Draft EIR has now been prepared and is in the public comment stage of review. The comment period on the Draft EIR (DEIR) will close at 5:00 PM on April 19, 2002. The EQCB considered a Staff Report regarding the proposed comment letter on March 27, 2002, and instructed staff to froward the comment letter, with revisions, to the City Council for final review and approval. Recommended revisions by the EQCB are noted by daub underline and italics for text to be added and by doml; : #&@du for test to be deleted. A copy of the comment letter is also to be sent to the South Coast Air Quality Management Agenda Item C:Ny Document EQA \DWP Re wn g PmjaL Long Beach, DEULCC SMff ReWft.dm \LW,04 -02 -02 Comment Letter re: "Draft Environmental Impact Report — Haynes Generating Station Repowering Project" DEIR prepared by City of Los Angeles Department of Water and Power City Council Su f- Report April 8, 1002 District to receive the City comments regarding Alternative 3, "Extend the Project Construction Schedule ", due to the provisions of the Stipulated Abatement Order. _ Summary of Proposed Action and Environmental Impacts: Staff has provided as Attachment 2, a copy of the following sections of the DEIR for the City Council to review in considering approval of the provided comment letter: ❑ Table of Contents ❑ Chapter 1 — Executive Summary • Chapter 3 — Project Description • Chapter 4 — Environmental Analysis • Chapter 8 — Environmental Impact Summary • City comment letter re: Notice of Preparation (Provided as Attachment 3) These sections provide an overview of the proposed project, discussion of the various areas of environmental concern, a summary of areas of environmental concern and proposed mitigation measures, and a copy of the City comment letter on the NOP for information purposes. Project Summary. Provided below is a brief summary of the proposed project: DWP proposes to install a new gas -fired combined -cycle generating system (CCGS) at the existing Haynes Generating Station, taking two existing steam boilers out of service, and making other changes to accommodate the new units. The new CCGS would include two combustion gas turbines (Crs), two heat recovery steam generators (HRSGs), a new steam turbine generator, and associates selective catalytic reduction (SCR) and carbon monoxide (CO) catalyst air pollution control equipment. SCR would be used to reduce nitrogen oxide (NO.) emissions as part of DWP's plan to meet declining facility-wide NO, emission limits required by South Coast Air Quality Management District's ( SCAQMD) Regional Clean Air Incentives Market (RECLAIM) Program. To accomplish DWP's goal at the earliest possible time and prevent potential future exceedances of their RECLAIM annual Allocations, DWP has entered into a "stipulated order of abatement" with the SCAQMD. The agreement requires that DWP begin equipment installation and modifications at the Haynes facility to acquire additional RECLAIM trading credits to ensure compliance with SCAQMD Rule 2004, and for the proposed installation of the CCGS with SCR units to be in use by December 2004. Proposed Project Description: Existing Generating Station Configuration and Operation: DW P Re wer ng Projmt, L ng Bewl, DEIR.CC swfr Re on 2 Comment Letter re: 'Draft Environmental Impact Report - Haynes Generating Station Repowering Project" DEIR prepared by City of Los Angeles Deportment of Water and Power City Council Staff Report April 8, 2002 The Haynes Generating Station (HnGS) has six units actively generating power, with a net generating capacity of approximately 1,570 megawatts (MW). Over the years the facility has been expanded and reconfigured to its present condition. Natural gas is the primary fuel for the generator units, rather than fuel oil. SCR pollution equipment has been installed on Units 1, 2, 5, and 6. The proposed project will increase the generating capacity to approximately 1,620 MW. The proposed generating units to be installed at the HnGS include two new natural gas -fired combustion gas turbines (CTs), two new heat recovery steam generators (HRSGs), one steam turbine generator and associated pollution control systems. A SCR system is provided that uses a catalyst to facilitate a reaction between NOx and aqueous ammonia to reduce NOx emissions and produce nitrogen and water. A carbon monoxide (CO) catalyst will also be installed to comply with the SCAQMD's New Source Review (NSR) and Best Available Control Technology (BACT) requirements. Construction: Construction of the proposed project is scheduled to begin in the summer of 2002 and continue to the anticipated operational date of December 2004. Construction activities are anticipated to last approximately 26 months and take place six days per week, Monday through Saturday. Two 10 -hour shifts are possible at times during the construction period. Sunday shifts may be required at times to ensure that construction activities stay on schedule. Approximately 350 workers would be employed during project construction. Operation: The proposed project would require no additional workers for operations. The project could operate 24 hours per day for 365 days per year. DEIR Comment Period. The comment period on the DEIR will conclude at 5:00 PM on April 19, 2002. Written comments may be submitted to the DWP as noted below: Mr. Kelvin Lew Los Angeles Department of Water and Power Corporate Environmental Services 111 North Hope Street, Room 1044 Los Angeles, CA 90012 DWPRepowedng Pmiect,W.g Beach DEI2CCStafi Report 3 Comment Letter re: 'Draft Environmental Impact Report — Haynes Generating Station Repowering Project' DEIR prepared by City of Las Angeles Department of Water and Power City Council Staff Report April8, 2002 Public AvailabiUry WDEIR A copy of the DEIR is available at the Department of Development Services for review. In addition, the DEIR is available at: • DWP Headquarters 111 Hope Street Los Angeles • Leisure World Library 2300 Beverly Manor Road Seal Beach • by accessing http:// www .ladwp.wm/power/haynesdeir.htrn. FISCAL IMPACT: No direct impacts. If increased environmental degradation upon the City is experienced as a result of the proposed project, the costs of appropriate mitigation measures should be the responsibility of the project proponent. To the extent that those impact mitigation costs are not completely the responsibility of the project sponsor, the City of Seal Beach may ultimately have to incur significant expenses to adequately mitigate unfunded environmental mitigation programs. RECOMMENDATION: Instruct Mayor to sign proposed Comment Letter, and instruct staff to forward to the Los Angeles Department of Water and Power. Forward staff report and approved comment letter to the Environmental Quality Control Board, Planning Commission, Archaeological Advisory Committee, and the Golden Rain Foundation for information purposes. Receive and File Staff Report. NOTED /A.eb Whittenberg John Y1111ahorski !!!/ Director of Development Servi City Vpager Attachments: (3) DWP Repowtiag Pmjcq long Beach, DEIRCC Staff Repon 4 Comment Letter re: "Draft Environmentol Import Report - Haynes Generating Station Repowering Project" DEIR prepared by City of Los Angeles Department of Water and Power City Council Staff Report April 8, 2002 Attachment 1: Proposed Comment Letter re: "Draft Environmental Impact Report — Haynes Generating Station Repowering Project, Long Beach ", prepared by the Los Angeles City Department of Water and Power Attachment 2: Excerpts of "Draft Environmental Impact Report — Haynes Generating Station Repowering Project, Lang Beach ", prepared by the South Coast Air Quality Management District, dated March, 2002 ❑ Table of Contents • Chapter 1 — Executive Summary • Chapter 3 — Project Description • Chapter 4 — Environmental Analysis ❑ Chapter 8 — Environmental Impact Summary Attachment 3: City of Seal Beach Comment Letter re: "Notice of Preparation of a Draft Environmental impact Report — Haynes Generating Station Repowering Project, Long Beach ", letter dated December 19, 2001 DWPRep en "g Pmje.t,Long B.h,DMKCCSWff Report 5 Comment Letter re: 'Draft Environmental Impact Report — Haynes Generating Station Repowering Project" DEIR prepared by City of Los Angeles Department of Water and Power City Council Staff Report April 8, 1007 ATTACHMENT 1 PROPOSED COMMENT LETTER RE: "DRAFT ENVIRONMENTAL IMPACT REPORT - IIAYNES GENERATING STATION REPOWERING PROJECT, LONG BEACIP', PREPARED BY THE LOS ANGELES CITY DEPARTMENT OF WATER AND POWER DWP Re owe ng Roject, Long Beach, DEIRC Stab Re n 6 Comment Letter re: "Draft Environmental Impact Report — Haynes Generating Station Repowering Project" DEIR prepared by City of Los Angeles Department of Water and Power City Council Staff Report April 8, 2002 April 8, 2002 Mr. Kelvin Lew Los Angeles Department of Water and Power Corporate Environmental Services 1 I I North Hope Street, Room 1044 Los Angeles, CA 90012 SUBJECT: CITY OF SEAL BEACH COMMENTS RE: "DRAFT ENVIRONMENTAL IMPACT REPORT — I7AYNES GENERATING STATION REPOWERING PROJECT, LONG DRAFTDear Mr. Lew: BEACM' The City of Seal Beach has reviewed the above referenced Draft Environmental Impact Report (DEIR) prepared by the Department of Water and Power (DWP) and has several comments relative to the document. The proposed project is close enough to the City of Seal Beach as to cause concern regarding environmental impacts upon our community, in particular the Leisure World retirement community located immediate /v east of the subject property, @a the t , side Support of Long -Term Air Quality Improvements: The City of Seal Beach supports the long -term air quality improvements that the proposed project will create. The replacement of out -moded power generating equipment, and the resultant reductions in criteria air pollutants is of great overall benefit to the surrounding region, and in particular to the residents of Leisure World. As indicated in Table 4.2 -24, the project will result in net overall peak daily operational mass emission reductions as follows: ❑ 5,736 pounds per day of NO. ❑ 7,306 pounds per day of CO ❑ 301 pounds per day of VOC ❑ 31 pounds per day of SO, DW P Re ,o dng P-j-c L.^g Bach, DEM.CC Staff Report 7 Comment Letter re. 'Draft Environmental Impact Report — Haynes Generating Station Repowering Project" DEIR prepared by City of LOS Angeles Department of Water and Power City Council StatrReport April B, 2002 ❑ 454 pounds per day of PM10 Requested Modification of Mitigation Measures: Upon a thorough review of the DEIR, the City of Seal Beach requests the following modifications to the language of the proposed "Mitigation Measures ", as set forth in Table 1.6 -1, and as appropriate within the body of the Final EIR document, and the inclusion of an additional "Noise" Mitigation Measure: �go "Air Ouality" Mitigation Measure: DR The City of Seal Beach requests that the language of this mitigation measure be revised to read as follows (Replaces DEIR language in its entirety): "All applicable provisions of SCAOMD Rule 403 shall be complied with Prior to the issuance of demolition adinp or building permits the applicant shall obtain approval of an Air Quality Mitigation Plan by the City of Lone Beach. The Plan shall address each applicable control measure from the 1997 Air Ouality Management Plan in order to determine which control measures are feasible recommend implementation conditions and establish methods of aopMn conditions to project contractors/suppliers The project applicant shall reimburse City costs of an independent third Party review of this Plan." "Cultural Resources" Mitigation Measure: The City of Seal Beach requests that the language of this mitigation measure be revised to read as follows: "Prior to the issuance of a grading permit, a certified archaeologist shall be retained. The archaeologist shall establish a plan for site surveillance during initial ground disturbance for the proposed project. Said plan shall provide for an on -site archaeologist and Native American monitor durnn all initial ground disturbance activities The archaeologist shall also develop procedures for temporarily halting or redirecting work to permit sampling, identification, and evaluation of any unexpected discovery. If any resources are found to be significant, the archaeologist shall determine the appropriate actions for exploration and/or salvage, after consultation with the on -site Native American monitor. DWPRepowed Pmjmt,Lng Benh,DEIRCCSfffRepon 8 Comment Letter re: 'Draft Environmental Impact Report — Haynes Generating Station Repowering Project" DEIR prepared by City of Los Angeles Department of Water and Power City Council Staff Report April 8, 2002 "Noise" Mitigation Measures: The City of Seal Beach requests that the language of these mitigation measures be revised to read as follows: "Prior to construction occurring outside of the periods specified in the noise ordinance, LADWP shall obtain authorization from the City of Long Beach. The noise ordinance limits the noise emanating from "operation of any tool or equipment" to specific hours set forth in Section 8.80.202 of the Municipal Code. Prior to the City of Long Beach granting such authorization it shall meet and confer with the City of Seal Beach and Golden Rain Foundation (Leisure World) to consider any concerns of these organizations Prior to granting such requested authorization. In order to minimize noise emanating from construction operations, the contractor shall implement a construction noise control program acceptable to the City of Long Beach. The program shall limit hours of pile- driving and heavy equipment operations and shall otherwise control noise from construction operations. The program shall include notification of surrounding communities (i.e., Leisure World and Island Village residents) of the period when such operations would take place. The City of LonE Beach shall meet and confer with the City of Seal Beach, Golden Rain Foundation (Leisure World) and Island Village to receive comments and suggestions regarding the proposed construction noise control program Prior to approving said program The oroiect applicant shall reimburse City costs of an rode end t third party review of this rD QEram„ I) A The City of Seal Beach requests incorporation of the following additional "Noise" Mitigation Measure into the Mitigation and Monitoring Program for this project: 'The applicant shall design and implement a window replacement program within Leisure World to provide double -vane windows on the appropriate sides of all impacted residential units within Leisure World, as determined based on more detailed noise analysis at the following residential structures to reduce construction and operation noise levels: ❑ Mutual 8 — Buildings 199 and 201 ❑ Mutual 4 — Buildings 37, 48, 50, and 51 ❑ Mutual 3— Buildings 18- 20,32 -34. Said window replacement program shall be completed Prior to the issuance of demolition grading or construction Permits related to the oroiect If a Mutual within Leisure World will not Provide the necessary approvals for said window replacement program the DWPRepowcnng Pmjet,Ung Beech,DEIRCCStaa Report 9 Comment Letter re: 'Draft Environmental impact Report — Haynes Generating Station Repowering Project" DEIR prepared by City of Los Angeles Department of Water and Power City Council Staff Report April 8, 2002 applicant shall Provide proof of said denial of permission to the Director of Development Services of the City of Seal Beach The City shall have 30 days after said notification of denial by applicant to City to meet and attempt to resolve said denial of permission If said Mutual continues to deny said repuest, the City shall so inform aopticant, and applicant shall be relieved of Providine windows to units within that particular Mutual." (Proposed new Mitigation Measure by City of Seal Beach) Acceptance of these modifications to the "Mitigation Measures" will indicate the desire of LADWP to work in a cooperative manner with Seal Beach and the residents of Leisure World and Island Village to ensure that all reasonable concerns regarding the short-term construction impacts related to "Air Quality" and "Noise" are thoroughly addressed in the various monitoring programs that will be established during the demolition and construction phases of the proposed project. Comments on Draft ELR Document- Consideration ofProiect Alternative Number 3: D DWPRepowenng Pmjw t,Lng8wch,DEIRCCStaff Report 10 Comment Letter re: 'Draft Environmental Impact Report — Haynes Generating Station Repowering Project" DEIR prepared by City of Los Angeles Department of Water and Power City Council Staff Report Apri18, 2001 Comments on issues not Addressed in Response to City Comments on NOP: The City of Seal Beach previously commented on the Notice of Preparation ( "NOP ") for this Draft EIR, and will focus its comments on those issues and concerns raised in that NOP comment letter of December 19, 2001. Air Oua[iN: DR AF The overall air quality benefits of the proposed project have been quantified and discussed thoroughly within the Draft EIR, in accordance with the comment of the City of Seal Beach during the NOP comment period, with the exception of "ammonia slip" evaluation, discussed below. Ammonia Slip Air Emission Evaluation Lacking: The NOP indicated that the expected ammonia slip emission will be set at no more than 5 ppm in the flue gas from the HRSGs. The Leisure World retirement community is immediately east of the AES Los Alamitos facility, and comprises approximately 8,300 residents, with approximately 90% being over the age of 65. Our comment letter indicated a concern to the City as to how the levels of ammonia slip being discussed could impact this population group, particularly those individuals with respiratory or other related health concerns. Although As requested in the December 19, 2001 comment letter on the NOP, there is no indication as to what the annual one -hour maximum ground concentration for ammonia slip is anticipated to be for the proposed project. This information, along with an analysis as to where ground level concentrations are anticipated to occur at, needs to be presented and evaluated for adverse environmental impacts. Will significant ground level concentrations of ammonia exist on the Haynes facility or on the adjoining AES Alamitos facility? If on the subject or adjoining or nearby properties, those should be indicated by the use of a map. As indicated in our December 19, 2001 comment letter, this analysis needs to include a "cumulative" analysis section performed for the combined air emissions, including ammonia emissions from all proposed SCR units at both the Haynes and AES Alamitos facilities. The indicated "health risk assessment document_, along with a `risk management plan" should be provided as technical appendices to the Final EIR document, permitting the interested public to review and comment as to the adequacy of the health risk and risk management documents. The specific health risk assessment issues relating to an elderly, retirement community population of 8,300 persons, should be particularly discussed in this portion of the Draft EIR. The "Health Risk" portion of the DEIR document and its related Table 4.2- 28, do not discuss or present information on ammonia. It appears that the DEIR does not address this concern in any meaningful manner, and in particular the requested `cumulative" analysis of this facility and AES Alamitos. The Final EIR should respond to these issues DWP Repowering P"ect, lung Beach, DEIR.CC Staff Rryon 11 Comment Letter re: "Draft Environmental Impact Report — Haynes Generating Station Repowering Project" DEIR prepared by City of Los Angeles Department of Water and Power City Council Staff Report April B, 2002 and concerns and provide full disclosure regarding the cumulative impacts of "ammonia slip" upon the adjoining Leisure World retirement community. Page 4-22, Table 4.2 -11, Overall Peak Daily Emissions During Turbine Commissioning, presents information as to the peak daily emissions during turbine commissioning. It is not clear in the DEIR as to how many days a year this activity would be anticipated to occur. Please clarify this issue in the Final EIR, and explain how those occurrences are incorporated into the information provided in Table 4.2 -24, Net Overall Peak Daily Operational Mass Emissions. ^ Geolocv: DR 0 The discussion on page 14 of the NOP indicated the existence of a document titled "Los Angeles Department of Water and Power, Risk Management Plan, Ammonia Storage and Supply System, Haynes Generating Station ", dated June 1999, prepared by Corporate Environmental Services. The City of Seal Beach again requests a copy of the referenced 1999 report and any updates to that document [hat may be prepared in the future. It is important to our emergency response providers to be aware of the potential risks and the management actions and programs in place at the Haynes facility to respond to potential risk and upset situations. Hvdroloev and Water OualiN: The DEIR provides adequate discussion regarding conformity with the appropriate requirements of the Los Angeles Regional Water Quality Control Boards. Noise: The Draft EIR includes a noise and groundborne vibration impact section, and in particular discusses the additional operational noise generated by the new facilities, the ability of the "proposed noise reduction measures" to reduce that noise to a level of less than significant, and discussion as what noise level is deemed acceptable. The DEIR indicates that "Construction activities are anticipated to last approximately 26 months and take place six days per week Monday through Saturday. Two 10 -hour shifts are possible at times during the construction period. To ensure that construction activities stay on schedule, two ten -hour shifts may be necessary at times during the construction period, and Sunday shifts may also be required at times." (Page I-4). The City wishes to express extreme concern regarding all anticipated construction activities that would occur before 7:00 AM or after 8:00 PM, and anytime on Sunday. Analysis of impacts to the adjoining residential community of Leisure World of extended construction hours and Sunday construction activities indicate impacts that cannot be mitigated to a less than significant level. DWPRep dng Pmject, Lon Beach,DEIRCCSotr Re n 12 Comment Letterre: "Draft Environmental Impact Report — Haynes Generating Station Repowenng Project' DEIR prepared by City of Las Angeles Department of Water and Power City Council Staff Report April 8, 2002 As indicated above, the City of Seal Beach is requesting the oyportunity ability, along with Leisure World and Island Village, to review and provide comments on requests by LADWP to permit construction activities occurring outside of the periods specified in the noise ordinance of the City of Long Beach and to review and provide comments on the required "construction noise control program ", prior to the granting of those requests by the City of Long Beach. Specific concerns of Seal Beach relate to the following construction activities: • Construction activities occurring after 7:00 PM on a daily basis • Construction activities occurring on Saturdays and Sundays. It is recommended that any requests for extended construction operations and pile driving activities include provisions of the use of equipment noise barriers and enclosures, and possibly utilization of temporary fabric screens along the fenceline, to reduce construction- related noise impacts. In addition, the use of pour- i%pl�sC�aissons, rather than piledriver caissons should be carefully considered. DR IN Further, since the construction schedule indicates that construction activities will occur for an anticipated 26 months, the noise impacts to impacted areas of Leisure World will be significant for a significant period of time. The DEIR indicates that the pile driving noise level at the nearest residences would be about 70 dB(A), which would be perceptively intrusive. The DEIR indicates that limits on pile driving could be observed to minimize the impacts (DEIR, Page 4 -73). The DEIR also indicates that construction of the proposed wastewater ponds adjacent to the property line could temporarily increase noise levels to about 76 dB(A) at the nearest residences, assuming no attenuation (DEIR, Page 4 -75). This increase in noise levels is much greater than perceptible, and the City requests that a noise mitigation program be established to provide double -pane windows on the appropriate sides of all impacted residential units within Leisure World, as determined based on more detailed noise analysis. The City feels that the window replacement program should include the following structures within Leisure World, at a minimum: ❑ Mutual 8 — Buildings 199 and 201 ❑ Mutual 4 — Buildings 37, 48, 50, and 51 ❑ Mutual 3 —Buildings 18-20,32-34 Implementation of this mitigation program would be anticipated to reduce construction noise impacts to less than significant. Transportation and Trafi7c: The DEIR indicates that the intersection of Studebaker Road and Westminster Avenue will be significantly impacted in the PM peak hour as a result of the proposed project (Page 4 -92, Table 4.5 -7). An "Intersection Safety Analysis" is then presented on pages 4 -95 and 4-96. The "Intersection Safety Analysis" does not analyze the one intersection in the study area identified as being significantly impacted by the project, Studebaker Road and Westminster Avenue. It is requested that a "Intersection Safety Analysis" also be conducted for Studebaker Road and Westminster Avenue. DW P Repowenng Projmt, Long Beach, DEIRCC Staff Report 13 Comment Letter re: 'Draft Environmental Impact Report — Haynes Generating Station Repowering Project" DEIR prepared by City of Los Angeles Department of Water and Power City Council Staff Report April 8, 1001 Hazardous Materials: The Initial Study indicated there would be no impacts related to "Hazards and Hazardous Materials ". The City of Seal Beach expressed concerns regarding this environmental impact issue, and they have not been addressed in the DEIP- and are again set forth below: `Hazards and Hazardous Materials: ^ AFT The NOP discussion related to general risly upset/human health impacts of transportation of aqueous ammonia from various potential locations within the region to the subject site. It is recommended that the specific transportation routes be indicated within the Final EIR. This would allow easier review and comments from interested individuals or organizations regarding this specific area of concern. There should be discussion in the Final EIR as to the statistical likelihood of a liquid ammonia release, based on cumulative operating conditions of the AES Alamitos and Haynes facilities. In addition, there should be an indication of the storage capacity of the ammonia storage areas, the retention capacity of spill containment areas, assuming a release were to occur, and a determination as to the length of a release without overflowing the proposed spill containment system. As was indicated in the 1993 SEIR for the AES Alamitos facility, the worst - case population exposure to the 100 -ppm ammonia irritation level for a complete containment facility failure was 2,070 persons. It is assumed that an increased level of exposure would now be created, and that a portion of this exposed population is located in Seal Beach, and most probably within Leisure World. The new analysis should include a map presentation of the area impacted by the modeled dispersion at the 100 ppm level, to allow both the City of Long Beach and the City of Seal Beach to be more fully informed as to potential impacts upon their respective residents. In the case of Seal Beach, there is a heightened level of concern, since the Leisure World community comprises approximately 8,300 residents, with approximately 90% being over the age of 65. It is a concern to the City as to how the levels of ammonia being discussed could impact this population group, particularly those individuals with respiratory or other related health concerns. This discussion should also provide information as to the nearest responding emergency service unit locations, estimated response times, and potential impact upon the capabilities of emergency medical response to meet the demands placed upon the emergency medical response system by a large amount of emergency calls from impacted persons. DWPRepow gPmject,L ng Be h,DE1R.CCSten'Re n 14 Comment Letter re.- 'Draft Environmental Impact Report - Haynes Generating Station Repowermg Project" DEIR prepared by City of Los Angeles Department of Water and Power City Council StajjReport April 8, 2002 The 1993 SEIR for the AES Alamitos facility also indicated that the worst - case population exposure to the 100 -ppm ammonia irritation level is 5,020 resulting from a transportation spill and a complete contaimnent failure, based upon analysis prepared for the Redondo Station. The Final EIR should indicate the transportation routes that will be utilized to transport the aqueous ammonia from anticipated suppliers to the Haynes Generating Station. The 1993 SEIR indicated that most of the anticipated suppliers are located to the north or east. In order to eliminate potential impacts to the Leisure World community, it is recommended that all truck transport of aqueous ammonia utilize the Route 405 /605 /SR- 22/Studebaker Road access locations to serve the generating station, with no deliveries occurring along Pacific Coast Highway, Westminster Avenue or Seal Beach Boulevard. It is also requested that local fire and police departments, both Long Beach and Seal Beach, be informecL2Grs prior to shipment, including routing information. DR Ar , If truck transport will occur within Seal Beach, it is assumed that a portion of this exposed population is located in Seal Beach, and most probably within Leisure World. The DEIR analysis should include a presentation of the area impacted by the modeled dispersion at the 100 ppm level, to allow both the City of Long Beach and the City of Seal Beach to be more frilly informed as to potential impacts upon their respective residents. In the case of Seal Beach, there is a heightened level of concern, since the Leisure World community comprises approximately 8,300 residents, with approximately 90% being over the age of 65. It is a concern to the City as to how the levels of ammonia being utilized could impact this population group, particularly those individuals with respiratory or other related health concerns. This discussion should also provide information as to the nearest responding emergency service unit locations, estimated response times, and potential impact upon the capabilities of emergency medical response to meet the demands placed upon the emergency medical response system by a large amount of emergency calls from impacted persons. Discussion should also be provided as to the types of anticipated human health problems to be anticipated assuming exposure of a large elderly population. The Final EIR should include a thorough discussion and evaluation of potential impacts related to the above concems." The Environmental Quality Control Board (EQCB) considered and discussed the DEIR document on Much 27, 2002 and the City Council considered and discussed the DEIR document on April 8, 2002. The City Council and the EQCB authorized the Mayor and DWPRe wering Pmjmt, ng B=h,DE1R.CCgtaff Report 15 Comment Letter re: "Draft Environmental Impact Report — Haynes Generating Station Repowering Project" DEIR prepared by City of Los Angeles Department of Water and Power City Council Staff Report April B, 2002 Chairman, respectively, to sign this letter indicating the official comments of the City of Seal Beach. Upon the preparation of the Final EIR for this project, please send 4 hard copies and a digital copy, if available, to Mr. Lee Whittenberg Director of Development Services, City Hall, 211 Eighth Street, Seal Beach, 90740. Thank you for your consideration of the comments of the City of Seal Beach If you have questions concerning this matter, please do not hesitate to contact Mr. Whittenberg at telephone (562) 431 -2527, extension 313, or by e-mail at Whittenberg&i.seal-beach.m.us. Sincerely, _ OR pFI William J. Doane Mayor City of Seal Beach Distribution: Seal Beach City Council Seal Beach Environmental Quality Control Board City Manager Golden Rain Foundation Attn: William Narang South Coast Air Ouality Manaeement Dis6ict Attn: Norma J. Glover, Board Chairman 21865 E. Conley Drive Diamond Bar. CA 91765 -4182 South Coast Air Oualitv Mana¢ement District Attn: Edward Camarena, Hearin¢ Board Chairman 21865 E. Cooley Drive Diamond Bar. CA 91765 -4182 DWPRe wenng Project ,Long Beach,DE1R.CC5taff Rryn 16 Joseph E. Porter III Chairman Environmental Quality Control Board Seal Beach Planning Commission Seal Beach Archaeological Advisory Committee Director of Development Service City of Long Beach Attn: Gerhardt Felgemaker April 8, 2002 Mr. Kelvin Lew Los Angeles Department of Water and Power Corporate Environmental Services I 11 North Hope Street, Room 1044 Los Angeles, CA 90012 SUBJECT: CITY OF SEAL BEACH COMMENTS RE: "DRAFT ENVIRONMENTAL IMPACT REPORT - AMINES GENERATING STATION REPOWERING PROJECT, LONG BEACH" Dear Mr. Lew The City of Seal Beach has reviewed the above referenced Draft Environmental Impact Report (DEIR) prepared by the Department of Water and Power (DWP) and has several comments relative to the document. The proposed project is close enough to the City of Seal Beach as to cause concern regarding environmental impacts upon our community, in particular the Leisure World retirement community located immediately east of the subject property. Support of Long -Term Air Quality Improvements: The City of Seal Beach supports the long -term air quality improvements that the proposed project will create. The replacement of out -moded power generating equipment, and the resultant reductions in criteria air pollutants is of great overall benefit to the surrounding region, and in particular to the residents of Leisure World. As indicated in Table 4.2 -24, the project will result in net overall peak daily operational mass emission reductions as follows: ❑ 5,736 pounds per day of NOx ❑ 7,306 pounds per day of CO ❑ 301 pounds per day of VOC ❑ 31 pounds per day of SO,; ❑ 454 pounds per day of PM, C:W, Docum.UTEQA0WP Rep.wm., Project DEMCC Comment Unecd.c " -08 -02 City of Sea! Beach Comment Letter re: DWP Repowering Project Draft EIR April 8, 2002 However, those significant air quality improvements come at a significant impact to the residents of the Leisure World community within Seal Beach. The major concern of the City is to reduce the identified impacts to this residential community. Requested Modification of Mitigadon Measures: Upon a thorough review of the DEIR, the City of Seal Beach requests the following modifications to the language of the proposed "Mitigation Measures ", as set forth in Table 1.6 -1, and as appropriate within the body of the Final EIR document, and the inclusion of an additional "Noise" Mitigation Measure: "Air OualiN" Mitigation Measure: The City of Seal Beach requests that the language of this mitigation measure be revised to read as follows (Replaces DER language in its entirety): "All applicable provisions of SCAOMD Rule 403 shall be compiled with. "Cultural Resources" Mitigation Measure: The City of Seal Beach requests that the language of this mitigation measure be revised to read as follows: "Prior to the issuance of a grading permit, a certified archaeologist shall be retained. The archaeologist shall establish a plan for site surveillance during initial ground disturbance for the proposed project. Said plan shall provide for an on -site archaeologist and Native American monitor during all initial ground disturbance activities. The archaeologist shall also develop procedures for temporarily halting or redirecting work to permit sampling, identification, and evaluation of any unexpected discovery. If any resources are found to be significant, the archaeologist shall determine the appropriate actions for exploration and/or salvage after consultation with the on -site Native American monitor. "Noise" Mitigation Measures: The City of Seal Beach requests that the language of these mitigation measures be revised to read as follows: DWP Repowenng Projeot DEIR.CC Comment Letter City of Seal Beach Comment Letter re: DWP R coo wering Project Draft EIR April 8, 2002 "Prior to construction occurring outside of the periods specified in the noise ordinance, LADWP shall obtain authorization from the City of Long Beach. The noise ordinance limits the noise emanating from "operation of any tool or equipment" to specific hours set forth in Section 8.80.202 of the Municipal Code. Prior to the City of Lone Beach granting such authorization it shall meet and confer with the City of Seal Beach and Golden Rain Foundation (Leisure World) to consider any concerns of these omanizations prior to granting such requested authorization. In order to minimize noise emanating from construction operations, the contractor shall implement a construction noise control program acceptable to the City of Long Beach. The program shall limit hours of pile - driving and heavy equipment operations and shall otherwise control noise from construction operations. The program shall include notification of surrounding communities (i.e., Leisure World and Island Village residents) of the period when such operations would take place. The City of Lone Beach shall meet and confer with the City of Seal Beach, Golden Rain Foundation (Leisure World) and Island Village to receive comments and suggestions reearding the proposed construction noise control program prior to approving said program. The project applicant shall reimburse City costs of an independent third party review of this program" The City of Seal Beach requests incorporation of the following additional "Noise" Mitigation Measure into the Mitigation and Monitoring Program for this project: Said window replacement program shall be completed prior to the issuance of demolition grading or construction Permits related to the proiecf If a Mutual within Leisure World will not provide the necessary approvals for said window replacement program, the applicant shall provide proof of said denial of permission to the Director of Development Services of the City of Seal Beach. The City shall have 30 days after said notification of denial by applicant to City to meet and attempt to resolve said denial of permission. If said Mutual continues to deny said request the City shall so inform applicant, and applicant shall DWP Re owemg Project DEIR.CC Comment Letter City of Seal Beach Comment Letter re: DWP Repowering Project Draft EIR April 8, 2002 be relieved of providing windows to units within that particular Mutual." (Proposed new Mitigation Measure by City of Seal Beach) Acceptance of these modifications to the "Mitigation Measures" will indicate the desire of LADWP to work in a cooperative manner with Seal Beach and the residents of Leisure World and Island Village to ensure that all reasonable concerns regarding the short -term construction impacts related to "Air Quality" and "Noise" are thoroughly addressed in the various monitoring programs that will be established during the demolition and construction phases of the proposed project. If DWP determines to not incorporate the requested amendments to the mitigation measures set forth above, the City of Seal Beach would then formally request re- consideration by DWP of Alternative 3. For further information on the reasoning of this request please refer to "Comments on the Draft EIR Document", immediately following. Comments on Draft EIR Document: Consideration of Project Alternative Number 3: If DWP determines not to incorporate the requested amendments to the mitigation measures set forth above the City of Seal Beach requests the Department of Water and Power to reconsider its rejection of Project Alternative 3. The City is of the opinion that Alternative 3; "Extend the Project Construction Schedule" and summarized on page 1-4 of the DEIR would reduce impacts to the residents of Leisure World in a more acceptable manner. This alternative would extend the project construction schedule to avoid the potential for nighttime and weekend construction activity, and not meet the December 2004 deadline established in the Stipulated Order of Abatement. This deadline date appears to have been determined without consideration of the adverse noise impacts to the elderly residents of Leisure World. While extension of the construction schedule would lengthen the time of uncomfortable daytime noise levels by about 100 days, the absence of construction activities on weekends and during extended construction hours would provide a significant level of relief for our citizens. It is our belief that the relief afforded on weekends and evenings would be welcomed by the residents of Leisure World. The City of Seal Beach requests that DWP and the SCAQMD petition the hearing board to revise the timeframe for Haynes Units 3 and 4, as noted on page 8 of the Stipulated Amended Order for Abatement, Findings and Decision, dated September 12, 2001. Comments on Issues not Addressed in Response to City Comments on NOP: The City of Seal Beach previously commented on the Notice of Preparation ( "NOP ") for this Draft EIR, and will focus its comments on those issues and concerns raised in that NOP comment letter of December 19, 2001. DWP Repowering Project DEIR.CC Comment Letter City of Seal Beach Comment Letter re. DWP Repo"ring Project Draft EIR April 8. 2002 Air ual' The overall air quality benefits of the proposed project have been quantified and discussed thoroughly within the Draft EIR, in accordance with the comment of the City of Seal Beach during the NOP comment period, with the exception of "ammonia slip" evaluation, discussed below. Ammonia Slm Air Emission Evaluation Lackin The NOP indicated that the expected ammonia slip emission will be set at no more than 5 pion in the flue gas from the HRSGs. The Leisure World retirement community is immediately east of the AES Los Alamitos facility, and comprises approximately 8,300 residents, with approximately 90% being over the age of 65. Our comment letter indicated a concern to the City as to how the levels of ammonia slip being discussed could impact this population group, particularly those individuals with respiratory or other related health concerns. Although requested in the December 19, 2001 comment letter on the NOP, there is no indication as to what the annual one -hour maximum ground concentration for ammonia slip is anticipated to be for the proposed project. This information, along with an analysis as to where ground level concentrations are anticipated to occur et, needs to be presented and evaluated for adverse environmental impacts. Will significant ground level concentrations of ammonia exist on the Haynes facility or on the adjoining AES Alamitos facility? If on the subject or adjoining or nearby properties, those should be indicated by the use of a map. As indicated in our December 19, 2001 comment letter, this analysis needs to include a "cumulative" analysis section performed for the combined air emissions, including ammonia emissions from all proposed SCR units at both the Haynes and AES Alamitos facilities. The indicated "health risk assessment documents, along with a "risk management plan" should be provided as technical appendices to the Final EIR document, permitting the interested public to review and comment as to the adequacy of the health risk and risk management documents. The specific health risk assessment issues relating to an elderly, retirement community population of 8,300 persons, should be particularly discussed in this portion of the Draft EIR. The "Health Risk" portion of the DEIR document and its related Table 4.2- 28, do not discuss or present information on ammonia. It appears that the DEIR does not address this concern in any meaningful manner, and in particular the requested "cumulative" analysis of this facility and AES Alamitos. The Final EIR should respond to these issues and concerns and provide full disclosure regarding the cumulative impacts of "ammonia slip" upon the adjoining Leisure World retirement community. Page 4 -22, Table 4.2 -11, Overall Peak Daily Emissions During Turbine Commissioning, presents information as to the peak daily emissions during turbine commissioning. It is not clear in the DEIR as to how many days a year this activity would be anticipated to occur. Please clarify this issue in the Final EIR, and explain how those occurrences are DWP Repo nng Pmjea DEIR.CC Comment Leaer City of Seal Beach Comment Letter re: DWP Repowering Project Draft EIR April 8. 2002 incorporated into the information provided in Table 4.2 -24, Net Overall Peak Daily Operational Mass Emissions. Geology: The discussion on page 14 of the NOP indicated the existence of a document titled "Los Angeles Department of Water and Power, Risk Management Plan, Ammonia Storage and Supply System, Haynes Generating Station ", dated June 1999, prepared by Corporate Environmental Services. The City of Seal Beach again requests a copy of the referenced 1999 report and any updates to that document that may be prepared in the future. It is important to our emergency response providers to be aware of the potential risks and the management actions and programs in place at the Haynes facility to respond to potential risk and upset situations. Hydrology and Water Ouality: The DEIR provides adequate discussion regarding conformity with the appropriate requirements of the Los Angeles Regional Water Quality Control Boards. Noise: The Draft EIR includes a noise and groundbome vibration impact section, and in particular discusses the additional operational noise generated by the new facilities, the ability of the "proposed noise reduction measures" to reduce that noise to a level of less than significant, and discussion as what noise level is deemed acceptable. The DEIR indicates that "Construction activities are anticipated to last approximately 26 months and take place six days per week, Monday through Saturday. Two 10 -hour shifts are possible at times during the construction period. To ensure that construction activities stay on schedule, two ten -hour shifts may be necessary at times during the construction period, and Sunday shifts may also be required at times." (Page 1 -4). The City wishes to express extreme concern regarding all anticipated construction activities that would occur before 7:00 AM or after 8:00 PM, and anytime on Sunday. Analysis of impacts to the adjoining residential community of Leisure World of extended construction hours and Sunday construction activities indicate impacts that cannot be mitigated to a less than significant level. As indicated above, the City of Seal Beach is requesting the opportunity, along with Leisure World and Island Village, to review and provide comments on requests by LADWP to permit construction activities occurring outside of the periods specified in the noise ordinance of the City of Long Beach and to review and provide comments on the required "construction noise control program ", prior to the granting of those requests by the City of Long Beach. Specific concerns of Seal Beach relate to the following construction activities: ❑ Construction activities occurring after 7:00 PM on a daily basis ❑ Construction activities occurring on Saturdays and Sundays. DWP R,.o nng Project DEIR.CC Cummcnt LeW City of Seal Beach Comment Letter re: DWP Repowering Project Draft ELR April 8, 2002 It is recommended that any requests for extended construction operations and pile driving activities include provisions of the use of equipment noise barriers and enclosures, and possibly utilization of temporary fabric screens along the fenceline, to reduce construction- related noise impacts. In addition, the use of pour -in -place caissons, rather than pile - driven caissons should be carefully considered. Further, since the construction schedule indicates that construction activities will occur for an anticipated 26 months, the noise impacts to impacted areas of Leisure World will be significant for a significant period of time. The DEER indicates that the pile driving noise level at the nearest residences would be about 70 dB(A), which would be perceptively intrusive. The DEIR indicates that limits on pile driving could be observed to minimize the impacts (DEIP, Page 4 -73). The DEIR also indicates that construction of the proposed wastewater ponds adjacent to the property line could temporarily increase noise levels to about 76 dB(A) at the nearest residences, assuming no attenuation (DEER, Page 4-75). This increase in noise levels is much greater than perceptible, and the City requests that a noise mitigation program be established to provide double -pane windows on the appropriate sides of all impacted residential units within Leisure World, as determined based on more detailed noise analysis. The City feels that the window replacement program should include the following structures within Leisure World, at a minimum: ❑ Mutual 8 —Buildings 199 and 201 ❑ Mutual 4 —Buildings 37, 48, 50, and 51 ❑ Mutual 3 —Buildings 18-20,32-34 Implementation of this mitigation program would be anticipated to reduce construction noise impacts to less than significant. Transportation and Traffic: The DEIR indicates that the intersection of Studebaker Road and Westminster Avenue will be significantly impacted in the PM peak hour as a result of the proposed project (Page 4-92, Table 4.5 -7). An "Intersection Safety Analysis" is then presented on pages 4 -95 and 4-96. The "Intersection Safety Analysis" does not analyze the one intersection in the study area identified as being significantly impacted by the project, Studebaker Road and Westminster Avenue. It is requested that a `Intersection Safety Analysis" also be conducted for Studebaker Road and Westminster Avenue. Hazardous Materials: The Initial Study indicated there would be no impacts related to "Hazards and Hazardous Materials ". The City of Seal Beach expressed concerns regarding this environmental impact issue, and they have not been addressed in the DEIR, and are again set forth below: Hazards and Hazardous Materials: The NOP discussion related to general risk of upset/human health impacts of transportation of aqueous ammonia from various potential locations within DWP Re wenng Project DEIR.CC Commem Letter City of Seal Beach Comment Letter re: DWP Repawering Project Draft EIR April 8, 2002 the region to the subject site. It is recommended that the specific transportation routes be indicated within the Final EIR. This would allow easier review and comments from interested individuals or organizations regarding this specific area of concern. There should be discussion in the Final EIR as to the statistical likelihood of a liquid ammonia release, based on cumulative operating conditions of the AES Alamitos and Haynes facilities. In addition, there should be an indication of the storage capacity of the ammonia storage areas, the retention capacity of spill containment areas, assuming a release were to occur, and a determination as to the length of a release without overflowing the proposed spill containment system. As was indicated in the 1993 SEIR for the AES Alamitos facility, the worst - case population exposure to the 100 -ppm ammonia irritation level for a complete containment facility failure was 2,070 persons. It is assumed that an increased level of exposure would now be created, and that a portion of this exposed population is located in Seal Beach, and most probably within Leisure World. The new analysis should include a map presentation of the area impacted by the modeled dispersion at the 100 ppm level, to allow both the City of Lang Beach and the City of Seal Beach to be more fully informed as to potential impacts upon their respective residents. In the case of Seal Beach, there is a heightened level of concern, since the Leisure World community comprises approximately 8,300 residents, with approximately 90% being over the age of 65. It is a concern to the City as to how the levels of ammonia being discussed could impact this population group, particularly those individuals with respiratory or other related health concems. This discussion should also provide information as to the nearest responding emergency service unit locations, estimated response times, and potential impact upon the capabilities of emergency medical response to meet the demands placed upon the emergency medical response system by a large amount of emergency calls from impacted persons. The 1993 SEIR for the AES Alamitos facility also indicated that the worst - case population exposure to the 100 -ppm ammonia irritation level is 5,020 resulting from a transportation spill and a complete containment failure, based upon analysis prepared for the Redondo Station. The Final EIR should indicate the transportation routes that will be utilized to transport the aqueous ammonia from anticipated suppliers to the Haynes Generating Station. The 1993 SEIR indicated that most of the anticipated suppliers are located to the north or east. In order to eliminate potential impacts to the Leisure World community, it is recommended that all truck transport of aqueous ammonia utilize the Route 405 /6051SR- 22/Studebaker Road access locations to serve the generating station, with no deliveries occurring along Pacific Coast Highway, Westminster Avenue or Seal Beach DWP Rqp nng Project DEIR.CC Comment Letter Gi v of Seal Beach Comment Letter re: DWP Repowering Project Draft EIR April 8, 2002 Boulevard. It is also requested that local fire and police departments, both Long Beach and Seal Beach, be informed 24 -hours prior to shipment, including routing information If truck transport will occur within Seal Beach, it is assumed that a portion of this exposed population is located in Seal Beach, and most probably within Leisure World. The DEIR analysis should include a presentation of the area impacted by the modeled dispersion at the 100 ppm level, to allow both the City of Long Beach and the City of Seal Beach to be more fully informed as to potential impacts upon their respective residents. In the case of Seal Beach, there is a heightened level of concern, since the Leisure World community comprises approximately 8,300 residents, with approximately 90% being over the age of 65. It is a concern to the City as to how the levels of ammonia being utilized could impact this population group, particularly those individuals with respiratory or other related health concerns. This discussion should also provide information as to the nearest responding emergency service unit locations, estimated response times, and potential impact upon the capabilities of emergency medical response to meet the demands placed upon the emergency medical response system by a large amount of emergency calls from impacted persons. Discussion should also be provided as to the types of anticipated human health problems to be anticipated assuming exposure of a large elderly population. The Final EIR should include a thorough discussion and evaluation Qf potential impacts related to the above concerns." The Environmental Quality Control Board (EQCB) considered and discussed the DEBT document on March 27, 2002 and the City Council considered and discussed the DEIR document on April 8, 2002. The City Council and the EQCB authorized the Mayor and Chairman, respectively, to sign this letter indicating the official comments of the City of Seal Beach. Upon the preparation of the Final EIR for this project, please send 4 hard copies and a digital copy, if available, to Mr. Lee Whittenberg, Director of Development Services, City Hall, 211 Eighth Street, Seal Beach, 90740. Thank you for your consideration of the comments of the City of Seal Beach. If you have questions concerning this matter, please do not hesitate to contact Mr. Whittenberg at telephone (562) 4l1 -2527, extension 313, or by e-mail at Whittenberg @ci.seal- beach.ca.us. I / (Sincerely, Wi iam n� Mayor City of Seal Beach DWP Repo enngP jest DEIR.CC Comment Letter Joseph orter III airman nvironmental Quality Control Board Distribution: Seal Beach City Council Seal Beach Environmental Quality Control Board City Manager Golden Rain Foundation Attn: William Narang South Coast Air Quality Management District Attn: Norma J. Glover, Board Chairman 21865 E. Copley Drive Diamond Bar, CA 917654182 South Coast Air Quabty Management District Attn: Edward Camarena, Hearing Board Chairman 21865 E. Copley Drive Diamond Bar, CA 917654182 DWP Repowering Pmjmt DEIRAC Comment liarr 10 City of Seal Beach Comment Letter re: DWP Rep o wen ng Project Draft EIR April 8, 2002 Seal Beach Planning Commission Seal Beach Archaeological Advisory Committee Director of Development Service City of Long Beach Attn: Gerhardt Felgemaker OF SEAS B.. iw � S' ;At �_� Memorandum To: Mayor Doane and Members of the City Council Attention: John B. Bahorsid, City Manage' From: Lee Whittenberg, Director of Development Services �5 v Date: April 8, 2002 (/ /// SUBJECT: AGENDA ITEM "P" - COMMENT LETTER RE: HAYNES GENERATING STATION REPOWERING PROJECT DEIR — WATER QUALITY CONCERN Overview of Councilman Yost's Concern: Councilman Yost has contacted staff regarding concems regarding the water quality impacts of the proposed project: specifically the water temperature and quality issues of the discharge of the cooling waters into the San Gabriel River. Staff has reviewed again the discussion in the Draft EIR regarding this issue, provided to the City Council in Attachment 2 of the Staff Report at pages 4-45 through 463. Staff Recommendation: After further review of the DEIR regarding the issues raised by Councilman Yost, staff is recommending there be no changes to the comment letter. In reviewing the "Hydrology and Water Quality" section of the Draft EIR, the document indicates the facility will still be subject to all requirements of the current NPDES peanut, which is valid between June 29, 2000 and May 10, 2005. The permit governs the quantity, quality and temperature of waste discharges from HnGS and requires monitoring of numerous constituents. No modifications of the current NPDES permit conditions are requested as part of the repowering project. Unless the project were to violate the existing NPDES permit requirements, there is a presumption of no adverse impacts, since the project is in compliance with the existing NPDES permit requirements. C:My Dxvmcns\CEQAOWP aeWwe^^ Jan DERCC M. &d ,LNN M2 City Council memorandum re: Haynes Generating Station Repo"nng Project DEIR - H7drologP and Water Quality Contents by Councilman Yost April 8, 2002 Summary of DEIR discussion re Water Quality Issues: The information in the DEIR indicates the following regarding temperature and water quality issues of the discharge waters back into the San Gabriel River: Environmental Setting: ❑ Page 4-47: "Once treated, the water form the wastewater basins is either recycled or is discharged to the River with the cooling water, as authorized by the existing NPDES permit" • Page 448: "The handling of all wastewater generated during operations at HnGS is governed by the facility's existing industrial NPDES permit ( NPDES permit CA0000353, CI -2769) issues by the RWQCB for the period June 29, 2000 through May 10, 2005. Table 4.3 -1 fists the wastewater discharge characteristics of the site's industrial, sanitary, and cooling water discharges. A copy of the NPDES permit is provided in Appendix C of this report. Also included in the NPDES permit are the monthly average and daily maximum discharge limits for temperature, pH and other constituents." (A copy of Table 4.3 -1 is provided as an attachment to this memorandum) • Page 4-48: "Also, monitoring data show that the quality and beneficial uses of the receiving waters (San Gabriel River and San Pedro Bay) were being protected over the three -year period (MBC, 19976 -1999) " Marine Water Quality — San Gabriel River ❑ Page4 -51: "As mentioned previously, a NPDES permit govems the quantity, quality and temperature of waste discharges from HnGS and requires monitoring of numerous constituents. As was previously shown in Table 4.3 -1, the cooling water discharge, which includes other waste streams is limited to 1,014.6 million gallons per day at or less than 38 °C (100 017). Despite the elevated temperature, monitoring data show that the quality and beneficial uses for the receiving water (San Gabriel River and San Pedro Bay) were being protected over the three -year monitoring period (MBC 1997b- 1999). Environmental Impacts — Marine Water Oualiri ❑ Operatio n— Page4 -61: The volume of cooling water used for the CCGS is expected to be at or below that currently utilized by Units 3 and 4. Likewise, the volume, temperature, and chemical characteristics of cooling water discharge associated with the CCGS operating would be generally the same as under the current operation. ....By complying with the existing NPDES permit requirements, the proposed project would have no significant operation - related water quality impacts since the temperature, chemical characteristics, and flows would stay within the limits currently prescribed." Environmental Impacts — Marine Biological Resources ❑ tion —Page 4- 61 -62: "Various studies have shown that the operation of the existing HnGS plant has no significant effects on the marine biota within Alamitos Bay or the River. The operation of the proposed CCGS is expected to be similar to the DWP Repowaing ROjat D1MCCM. City Council memarandam re: Ham Generating Station Rep~ringProjectDElR- Hydrology and Water Quality Concerns by Councilman Yost April8, 2001 existing Units 3 and 4 that it would replace, and it would operate within the existing permit discharge parameters (chemical, temperature, and volume). The proposed project could actually reduce impacts to marine biological resources. With only one steam boiler, only half as many heat treatment episodes would be required with the CCGS compared to Units 3 and 4 that would be removed from service. Also, one pump and screen chamber would be provided for the CCGS compared to two pump and screen chambers on Units 3 and 4 that would be removed from service. This could reduce the number of fish impinged on these facilities. The impingement impacts recorded in the 2001study were insignificant particularly when compared to the standing crop population. Since the project would not result in an increased volume or approach velocity, there should be no impact on marine biological resources. Similarly, receiving water monitoring reports from 1978 -2001 indicate that the operation of HnGS has not adversely affected water quality or beneficial uses. Since the volume, temperature and chemical characteristics of the discharge would be at or below the current facility, there should be no adverse impacts on the receiving water biological resources." Attachment: "Table 4.3 -1, NPDES Discharge Characteristics, Haynes Generating Station", Haynes Generating Station Repowering Project Draft EIR, page 4-49 DWP R,owningA jw DE[RCC Mom Table 4.3 -1 NPDES Discharge Characteristics, Haynes Generating Station Source: RWQCB, 2000. 4See Appendix C for volumes of listed miscellaneous discharges. During the preliminary project evaluation, groundwater was sampled in three on -site locations. This sampling indicates that groundwater below the site exceeds the California and federal standards for drinking water for some metals and sulfate. Though three VOC compounds and three SVOC compounds were at non - detect levels in the sampling, their respective quality limits for drinking water were exceeded. The near- surface groundwater . beneath the site is not suitable for potable uses. Haynes Generating Station Repowering Project EIR Paste 449 O.P.10' M.rch 2002 Maximum Value Maximum Daily Constituent -(b'outfall) Flow 001, 002 003 Units I & 2 Units 3 & 4- Unirs S & 6 Arsenic (_) <3 <3 <3 Cadmium ( oJlj <0.5 <0.5 <0.5 Copper (pg/l) 7 14 12 Chromium (total) ( o p Q 1 <2 <2 Zinc all) 10 10 15 Mercury A) <0.2 1 <0.2 <0.2 Nickel (c/) <3 <3 <3 9 Phenols ( S) <50 <50 <50 Residual Chlorine ( e/1) <I00 <100 <100 PH 7.8 -8.3 7.8 -8.3 7.7 -8.3 Maximum Temperature (F) Winter (October-April) 83 80 73 Summer (May-October) 96 93 91 Maximum Flow (mad) 276.58 276.58 460.90 1,014.06 Miscellaneous Wastewater (mad)- - -- - -- - -- 0.565 Includes: Boiler blowdown Storm water runoff Deminerliur re_generat..on Floor drains Filter polish water Laboratory drains Boiler washwater Boiler acid cleaning rinses Sanitary wastes - Reverse osmosis reject Source: RWQCB, 2000. 4See Appendix C for volumes of listed miscellaneous discharges. During the preliminary project evaluation, groundwater was sampled in three on -site locations. This sampling indicates that groundwater below the site exceeds the California and federal standards for drinking water for some metals and sulfate. Though three VOC compounds and three SVOC compounds were at non - detect levels in the sampling, their respective quality limits for drinking water were exceeded. The near- surface groundwater . beneath the site is not suitable for potable uses. Haynes Generating Station Repowering Project EIR Paste 449 O.P.10' M.rch 2002