HomeMy WebLinkAboutItem OAGENDA REPORT
DATE: April 23, 2001
TO: Honorable Mayor and City Council
THRU: John B. Bahorski, City Manager
FROM: Lee Whittenberg, Director of Development Services
SUBJECT: RECEIPT OF "RESPONSES TO COMMENTS" RE:
DRAFT EIR - SELECTIVE CATALYTIC REDUCTION
(SCR) INSTALLATION PROJECT, AES ALAMITOS,
LONG BEACH - SCAQMD
SUMMARY OF REOUEST:
Receive and File the Responses to Comments to the City comment letter of February 12,
2001 regarding the Draft EIR - Selective Catalytic Reduction (SCR) Installation Project,
AES Alamitos, Long Beach. Instruct Staff to forward to the Planning Commission and
Environmental Quality Control Board for information.
BACKGROUND:
On February 12, 2001 the City Council reviewed a staff report regarding the subject Draft
EIR and authorized the Mayor to sign a comment letter expressing concerns regarding the
document. As required by CEQA, the South Coast Air Quality Management District has
prepared the necessary "Response to Comments" and has forwarded it to the City. It is
being provided to the City Council for information purposes.
FISCAL IMPACT:
None
RECOMMENDATION:
Receive and File. Instruct Staff to forward to the Planning Commission and
Environmental Quality Control Board for information.
e Whittenberg
Director of Development Servi es
Agenda Item
CA My Dorton M \CEQA \SCRPmjat DEIR, Responses to Co=mN.CCSR. o TW01 -0691
Receive andFile — Responses to Comments
Draft EIR, SCR Project, AES Alamitos
City Coaacil StajfReport
Aprd 23, 2001
NOTED AND APPROVED:
h-Ae--,
B. BahotsM, City Manager
Attachment Responses to City of Sea] Beach Comment Letter re: Draft EIR — Selective
Catalytic Reduction (SCR) Installation Project, AES Alamitos, Long Beach,
prepared by South Coast Air Quality Management District, dated March 6,
2001
SCR Pmimt DPIR, Responses b Commenis.CCSR
South Coast
Air Quality Management District
<21865 E. Copley Drive, Diamond Bar, CA 91765 -4182
(909) 396 -2000 • http: //v .agmd.gov
March 6, 2001
Lee Whittenberg
Director of Development Services
City of Seal Beach, City Hall
211 Eighth Street
Sea] Beach, California 90740
Dear Mr. Whittenberg:
CITY OF SEAL BEACH
MAR - 8 2001
DEPARTMENT pF
DEVELOPMENT
VIA FACSIMILE (562) 431 -4067
The South Coast Air Quality Management District (AQMD) received your comment
letter regarding the above referenced project. Thank you for reviewing and providing
comments on the Draft Environmental Impact Report (EIR) for the AES Alamitos
Generating Station Selective Catalytic Reduction (SCR) Installation Project. A copy of
your comment letter and a draft response we enclosed.
The Final EIR, which also will include the responses to your comments, will be sent to
you upon certification. The Final EIR is expected to be considered for certification early
March 2001. If you have any questions or need other information on the environmental
analysis for this project, please call me at (909) 396 -2706.
Sincerely, �/
Michael A. Krause
Air Quality Specialist
CEQA Section
Enclosure
U:tp.lwMOmm�az)
RESPONSES TO THE CITY OF SEAL BEACH COMMENT LETTER
(February 12,2001)
2 -1 Specific responses to each issue raised by the City of Seal Beach are provided in
response to comments #2 -2 through #2 -11.
2 -2 This comment indicates that the City supports one of the objectives of the project,
to improve air quality by reducing NOx emissions, which is ultimately beneficial
to the citizens of the Leisure World community.
2 -3 The text of the Final EIR (Section 4.2.3.1) will reflect the reduction of NOx
emissions, from 6,132 tons per year to 478 tons per year, as presented in the
Notice of Preparation response to comment number #4 -4.
2 -4 This comment indicates that the City had two concerns regarding the "cumulative
impacts" analysis. These concerns are addressed in the responses #2 -5 and #2 -6.
2 -5 The settlement agreement between SCAQMD and AES addressed the inability of
the Alamitos Generating Station to reconcile its annual NOx RECLAIM emission
with sufficient credits, thus exceeding the annual NOx allocation pursuant to
Regulation XX. The agreement also ensures the timely installation of equipment
to assure emissions are reduced in the future. The unusual energy demand in
2000, and a requirement to continue operation by the California Independent
Systems Operator (Cal -ISO), resulted in the Alamitos Generating Station
operating more than initially anticipated and, as a result, the facility exceeded its
annual NOx emissions allocations by an amount that could not be reconciled.
SCAQMD did not assert, nor did the settlement agreement address, any alleged
violations by AES of its RECLAIM Allocation contributing to exceedances of
any state or federal ambient air quality standards in the vicinity of the Alamitos
Generating Station.
It is because of these past violations of Regulation XX that the SCAQMD entered
into a settlement agreement with AES Alamitos to make sure that such
exceedances do not occur in the future. SCAQMD is committed to ensuring that
all power generators located in the district comply with all applicable laws and
regulations. To that end, SCAQMD intends to continue to vigorously monitor
and enforce implementation of SCAQMD requirements and the settlement
agreement with AES.
Installation of SCR systems at the Alamitos Generating Station will virtually
eliminate the likelihood of the annual NOx emissions exceedances in the future.
Furthermore, in conjunction with this project and pursuant to Regulation XX,
AES will be required to upgrade the existing continuous emissions monitoring
systems to incorporate the ranges of monitoring needed after SCR installation.
The continuous emissions monitoring system on each unit is directly connected to
the SCAQMD's emissions database. Therefore, SCAQMD has continuous
records of the levels of NOx and other pollutants emitted from each unit at the
Alamitos Generating Station. Also, per SCAQMD permit conditions, AES is
required to report levels of all criteria pollutants and ammonia slip emitted from
the facility on a regular basis. Thus, the permit conditions are specifically
designed to ensure compliance with and enforcement of SCAQMD rules and
regulations.
2 -6 The project applicant will work with Cal -ISO to ensure that any cumulative
impacts to the power grid are minimized while the units are off line during
installation of the proposed project, thus minimizing any future adverse energy
impacts. It is important to point out that, due to the power crisis in California, the
power generating units at the Alamitos Generating Station are currently being
allowed to operate, even though the facility has exceeded its annual NOx
emissions limits. However, such operations have been and are being allowed
based on AES' commitment to reduce NOx emissions, via installation of SCR on
an expedited basis. Therefore, the proposed project is necessary to ensure that
these units are allowed to continue operation in the long term.
2 -7 This comment indicates the City concurs with the conclusion in the DEIR that
ammonia slip from the proposed project will not generate significant adverse
human health impacts.
2 -8 The City requests clarification regarding the cumulative hazard index number
discussed in the DEIR, Table 4 -6 (shown below). The discussion below addresses
this comment.
Table 4-6
Ammonia Slip Health Risk Assessment Results
Maximum Hourly Concentrations (pgW)
19.65
Acute Reference Exposure Level (pgW)
3200
Acute Hazard Index
0.0061
Annual Average Concentrations()ig/m3)
1.965'
Chronic Reference Exposure Level (pg /ms)
200
Chronic Hazard Index
0.0098
"This is a concentration, used with the " REL to determine the —Hazard Index. If
the — Hazard Index is less than 1.0, then there is no risk to health.
The number 1.965 g/n? is the annual average concentration of ammonia
predicted by the model to occur at ground level at a certain distance away from
the source (in this case the stacks at the Alamitos facility). This concentration is
used together with the Chronic and Acute Reference Exposure Levels to
determine the Chronic and Acute Hazard Indices, respectively. If the Hazard
Index level is greater than 1.0, then there is considered to be a potentially
significant effect on human health from the release of that particular substance (in
this case ammonia). As explained in more detail in the DEK the Hazed Indices
for the proposed project are far less than 1.0. Therefore, there is no risk to human
health as a result of the proposed project.
When the model was used to predict the ground level concentrations (the
maximum hourly concentration and the annual average concentration as in the
above table), the emissions from all four of the boiler units (post -SCR system
installation) at the Alamitos Generating Station were included in the model input.
Therefore, the impact of the operation of all four boiler units (post -SCR system
installation) at the same time was assessed. The resultant Hazard Indices were
found to be less than 1.0. Thus, the impact of all four boilers operating at once
also does not pose a risk to human health.
The Cumulative Hazard Index is a facility -wide hazard index that takes into
account the operation of other equipment on the site, including the existing SCR
equipment on Units 5 and 6, as well as from the proposed equipment (i.e., the
operation of the four boilers /SCR units). The text of the Final EIR will include a
footnote stating that the acute and chronic hazard indices in Table 4 -6, "Ammonia
Slip Health Risk Assessment Results," serve as both the project- specific and the
cumulative impacts. The operation of the proposed project is well below the
Cumulative Hazard Index standard of 3.0.
2 -9 The City of Seal Beach concurs with the SCAQMD's conclusion, as demonstrated
in Figure 4 -1, that the proposed project would not generate significant adverse
health risk impacts in general, or health risks to residents of Leisure World.
Furthermore, the City supports mitigation measure H -1 regarding the hours
ammonia can be transported. The City also concurs with the ammonia transport
route identified in the DEIR.
Finally, the City concurs with the conclusion in the DEIR that noise and public
services impacts from the proposed project will not be significant.
2 -10 This comment indicates that the City Council considered the comment letter and
authorized the letter's approval.
2 -11 Thank you for your comments. A copy of the Final EIR will be provided as soon
as it is completed.
February 12, 2001 Comment Letter # 2
Steve Smith, Ph.D.
Program Supervisor
South Coast Air Quality Management District
21865 E. Copley Drive
Diamond Bar, CA 91765 -4182
SUBJECT: CITY OF SEAL BEACH COMMENTS RE: "DRAFT EIR -
AES ALAMITOS LLG SELECTIVE CATALYTIC
REDUCTION (SCR) INSTALLATION PROJECT AT
ALAMITOS GENERATING STATION (UNITS 1, 2,3 AND
4)"
Dear Dr. Smith:
The City of Seat Beach has reviewed the above referenced Draft EIR and has several
comments relative to the document. Initially, the City would thank the SCAQMD for the
thorough responses to our comments of November 29, 2000 regarding the "Notice of
Preparation" for this Draft EIR document. The additional information provided within the
2.1
body of the Draft EIR and in Appendix B - "Cornmem Letters and Response to Comment"
are extremely helpful in addressing the concerns of our community as to the potential health
and safety factors of this project that might have a potential impact upon the Leisure World
community within Seal Beach. _
The City of Seal Beach supports the objective of the project - reduction by up to
90% of NO, emissions from Units 1, 2, 3 and 4. In "Appendix B - Comment Letters and
Response to Comments', SCAQMD indicates the historical annual emissions post -SCR
emissions in response to City of Seal Beach comment number 4.5. It is indicated within that
2.2
response that the project anticipates the reduction of NO, emissions from 6,132 tons/year to
478 tonslyear. This reduction of approximately 5,654 tons/year of NO, emissions is a
substantial air quality benefit to the surrounding region, and is seen as a particularly
beneficial aspect to the citizens of the Leisure World community within Seal Beach.
However, the information in this response to comment should also be set forth within the
body of the Draft EIR. It would seem most appropriate to provide this information with
2 -3
Section 4.2.3.1, "Operation - NO„ Emissions" of the Final EIR.
C.W, oaC,L .,ACEQA\SCR Pmj «I DEIR, AM Ins Alumims.CC Utwnd.c 02 -12 -01
City ofSeal Beach Comment Letter re:
"Dmft EIR — Selective Catalytic Reduction (SCR) Installation
Project, AES Las Alamitos, long Beach"
February 12,1001
The Draft EIR document indicates at page 1-4 that one of the project's objectives is
to "Provide for the terms of a settlement agreement with the SCAQMD, which provides for
AES to begin installation of pollution control equipment at the Alamitos facility starting in 2 -4.
2001, such that affected power generating units can be put to into use by summer 2001."
The City has two concerns that it wishes to express, particularly relevant to the Draft EIR
analysis of "cumulative impacts ".
The first concern is regarding the actions of AES Alamitos L.L.C. that resulted in a
settlement agreement. It is our understanding the settlement agreement was to resolve an
issue of the Alamitos facility substantially exceeding the allowable NO, emissions of its
current operations. If this is the case, the "Cumulative Impacts" analysis of the Final EIR
should 'indicate the level of exceedence of Federal and State NO, emissions as a result of the
non - compliance actions of AES Alamitos LL.C., and describe how the project activities
will result in the reduction of future impacts to less than a significant level. It is also 2 -5
requested that the "Cumulative Impacts" analysis also indicate how future monitoring
activities of SCAQMD will be implemented to not result in future violations of the rules and
regulations of the SCAQMD. It appears that the past violations were substantial, resulting
in a $17 million fine to AES Alamitos L.L.C. It is a concerts to the City of Seal Beach that
this type of egregious violation not occur in the future, and that timely monitoring and
adequate responses to violations of SCAQMD rules and regulations be implemented
Secondly, given the current power situation within California, the "Clumulative
Impacts" analysis is not adequate in addressing the impacts of taking Units 1, 2, 3 and 4 off-
line to accomplish the SCR retrofit at this time. The "Cumulative Impacts" analysis of the 2 -6
Final EIR should be revised to adequately describe the impacts of the loss of 1,000 MW m
the California power grid and the ability of California m continue to obtain adequate power
supplies to not require "rolling black- outs' or significant power interruptions. Phasing of
the proposed project to reduce impacts should be evaluated within the "Cumulative
Impacts" analysis.
The City appreciates the detailed analysis of the "Ammonia Slip Health Risk
Analysis" presented in Section 4.2.3.3 of the Draft MR. The health risk analysis concluded
that the "Acute Hazard Index" is 0.0061 and the "Chronic Hazard Index" is 0.0098. These
values are substantially less than the project- specific significance threshold of 1.0. This 2 -•%
detailed analysis indicates a substantially less than significant health risk as a result of the
project, taking into account the conservative parameters utilized to conduct the health risk
analysis. This information is helpful to the Leisure World residents in further understanding
the potential impacts of this project upon the health of themselves and other residents within
Leisure World.
Section 4.2.3.3 also indicates that if the cumulative hazard index is less than 3.0, the
cumulative impacts are less than significant. Table 4-6, "Ammonia Shp Health Risk 2 -8
Assessment Results ", indicates "Average Annual Concentration (ug1m3)" is 1.965. It is
unclear if this number is the "cumulative hazard index" number discussed within this section
SCR Hole. cars, AES loa Alemi..CC liner
City of Seal Beach Comment Letter re:
"Dmft EIR - Selective Catalytic Redaction (SCR) lmrallation
Project, AES Los Alamitos, Long Beach"
February 12, 20011
of the Draft EIR. Please review and revise the language of the Final EIR to indicate what is
2_8
the "cumulative hazard index" number. J
The City had requested a graphic representation as to the area of impact form an on-
site ammonia release, and the information provided within Section 4.3.13 and Figure 4-1
adequately responds to that request of the City. The map provided as Figure 4-1 clearly
shows that an on -site ammonia release at a level greater than 200 parts per million (ppm)
would have no anticipated impacts upon Leisure World, and would not be anticipated to
extend easterly of the San Gabriel River.
The City of Seal Beach supports Mitigation Measure H -1, requiring the transfer of
aqueous ammonia to not occur during school hours or between 6 am. to 9 a.m. and 4 p.m. to
6 p.m. This mitigation measure substantially reduces any potential impacts of an off -site
release to the general population and to school age children attending classes close to the
travel route to be utilized by the truck transport vehicles. The City also concurs with the
2-9
transportation route indicated to deliver the aqueous ammonia to the site, using the 1405
Freeway and Studebaker Road.
The discussion within the document adequately addresses the earlier concerns of the
Environmental Quality Control Board (EQCB) and our staff regarding the issues of "Noise"
and 'Public Services ". It is clear from the environmental analysis presented that noise
impacts from the construction and operation phases of the project would not have a
significant impact upon the leisure World community due to the distance from the project
site. It is also clear from the information presented that any `Public Service" impacts of the
project will be the primary responsibility of the City of Long Beach, and if an incident
exceeds the scope of the City of Long Beach response capabilities, that Los Angeles County
Hazardous Materials unit would be the next available backup.
The City Council considered this matter on February 12, 2001, and authorized the
2 -10
Mayor to sign this letter indicating the official comments of the City of Seal Beach.
Thank you for your consideration of the comments of the City of Seal Beach. Upon
the preparation of the Final EIR for this project, please send 1 copy to Mr. Lee Whittenberg,
Director
2 -1 1
of Development Services, City Hall, 211 Eighth Street, Seal Beach, 90740. If you
have questions concerning this matter, please do not hesitate to contact Mr. Whittenberg at
telephone (562) 431 -2527, extension 313.
Sincerely,
Patricia E. Campbell.
Mayor
City of Seal Beach
SCR *t DEIRA W Ahmitw.CC toter
City of Seal Beach Comment Letter re:
"Draft EIR— Selective Catalytic Reduction (SCR) Installation
Project, AES Los Alamitos, Um Beach"
February 12, 2001
Distribution
Seat Beach City Council Seal Beach Planning Commission
Environmental Quality Control Board
Acting City Manager Director of Development Service
Golden Rain Foundation City of Long Beach
SCR "= DER, Ass W Ale ws CC Utter