HomeMy WebLinkAboutItem FFebruary 12, 2001
STAFF REPORT
To: Mayor Campbell and Members of the City Council
Attention: Donald F. McIntyre, Acting City Manager
From: Lee Whittenberg, Director of Development Services
Subject: COMMENT LETTER RE: DRAFT EIR —
SELECTIVE CATALYTIC REDUCTION (SCR)
INSTALLATION PROJECT, AES LOS
ALAMITOS, LONG BEACH - SCAQMD
SUMMARY OF REQUEST
Instruct Mayor to sign proposed Comment Letter, and instruct staff to forward to Planning
Commission and Environmental Quality Control Board for information purposes. Receive and File
Staff Report.
DISCUSSION
Summary of Previous EQCB Actions:
On November 29, 2000 the Environmental Quality Control Board (EQCB) reviewed and approved a
comment letter regarding the "Notice of Preparation of a Draft Environmental Impact Report —
Proposed Selective Catalytic Reduction (SCR) Installation Project, AES Los Alamitos, Long Beach",
prepared by the South Coast Air Quality Management District (SCAQMD). This document served
two purposes: to solicit information on the scope of the environmental analysis for the proposed
project and to notify the public that SCAQMD will prepare a Draft EIR to further assess potential
environmental impacts that may result from implementing the proposed project.
The comment period on the NOP closed at 5:00 PM on December 7, 2000. Staff prepared a
response letter for the consideration of the EQCB, which was approved and forwarded to SCAQMD
and to the City Council for information purposes (Refer to Attachment 3 for a copy of the EQCB
Comment Letter). The City Council was not able to consider this matter, due to the shortness of the
comment period and the meeting schedule of the City Council.
AGENDA ITEM
QWy Docu UNCEQAISCR Psojxt DEM, AES Los Ala tos.CC Staff R post.d�1-25-01
City Council Comment Letter re: Draft EIR —
Selective Catalytic Reduction (SCR) Installation, AES Los Alamitos Generating Station
prepared by South Coast Air Quality Management District
City Council Staff Repon
February 12, 2001
Summary of Proposed Action and Envhonmentallmpacts:
Staff has provided as Attachment 2, a complete copy of the 'Table of Contents", "Chapter 1 -
Executive Summary", and "Chapter 2 - Project Description" of the Draft EIR, which provides an
overview of the project location, background, project objectives, and project description.
Project Summary:
Provided below is a brief summary of the proposed project:
AES Alamitos, L.L.C. proposes to demolish two urea tanks; install three 20,000 -gallon, above-
ground, double -walled, aqueous ammonia (29 percent concentration) storage tanks; construct a
containment wall around each ammonia tank; and install SCR catalysts in boiler exhaust units (Units
1, 2, 3 and 4). SCR would be used to reduce nitrogen oxide (NOO emissions as part of AES' plan to
meet declining facility -wide N% emission limits requited by South Coast Air Quality Management
District's (SCAQMD) Regional Clean Air Incentives Market (RECLAIM) Program.
To accomplish AES' goal at the earliest possible time and prevent potential future exceedances
of their RECLAIM annual Allocations, AES has entered into a compliance agreement with the
SCAQMD. The agreement requires that AES begin equipment installation and modifications at
the Alamitos facility starting early in 2001, such that affected power generating units will be in
use by summer 2001. For a complete description of the proposed project and the anticipated
activities, the reader is referred to "Proposed Project Description" below.
Proposed Project Description:
Existing Generating Station Configuration and Operation:
The Alamitos Generating Station has six units actively generating power. Utility boilers at the
Generating Station use natural gas as the primary combustion fuel and fuel oil as a backup fuel to
produce steam. The steam produced in the utility boiler is vented to steam turbine generators to
produce electricity. SCR technology, including a 20,000 -gallon underground aqueous ammonia
storage tank, was installed at the Generating Station in 1994 on Units 5 and 6. Noise suppression
equipment is installed on the forced draft fans for Units 5 and 6.
PROPOSED PROJECT DESCRIPTION
As part of the combustion process, NOs is produced and emitted to the atmosphere with the other
flue gas constituents (mostly nitrogen, carbon dioxide, and water vapor). SCR is an air pollution
SCR Pmjmt DEIR, AFS Las Ahnutw.CC Staff Repos 2
City Council Comment Letter re: Dmfr EIR —
Selectiw Catalytic Reduction (SCR) Installation, AES Cos Alamitos Generating Station
prepared by South Coast Air Quality Management District
City Council Swff Report
February 12, 2001
control technology that uses a reducing agent (ammonia) to reduce NO, to nitrogen and water in the
presence of a catalyst. In an SCR system, ammonia is injected into the boiler flue gas. The
ammonia/flue gas mixture flows through a catalyst that accelerates the reaction between the
ammonia and the N%. Ammonia used for SCR systems is typically stored in one or more storage
tanks. The ammonia is piped from the tank to the boiler where it is mixed with flue gas before
passing through the catalyst. The catalyst is composed of individually extruded homogenous
honeycomb ceramic elements of approximately 6" x 6" x 28" packed into steel support modules of
48" x 11" x 34". Its active elements are formulated from a proprietary mixture of Titanium Dioxide
and Vanadium Pentoxide.
The proposed SCR project consists of the installation of four SCR reactor units within the existing
boilers of Units 1, 2, 3 and 4; carbon steel assembly comprised of four reactors; three 20,000 -gallon
double -walled, above ground, and separately contained carbon steel ammonia storage tanks; and,
control equipment that would be incorporated into the existing plant distribution control system with
new interface hardware. Aqueous ammonia would be transported to the facility via tanker truck
along the existing approved route, established prior to the installation of SCR on Units 5 and 6. All
new equipment would be located within the existing fenceline of the Alamitos Generating Station.
The SCR reactor units would be encased in the boiler duct works and would not be visible from off-
site. All other new components would be installed close to the boiler structure and would not be
visible off-site. A temporary construction area would be located at the rear of the units.
CONSTRUCTION
Construction of the proposed project is scheduled to begin February 2001 and be completed by June
2001. Construction activities are anticipated to take place five days per week, Monday through
Friday, from 6:00 a.m. to 5:00 p.m. However, night and/or weekend shifts may be required to
maintain the construction schedule.
OPERATION
The proposed project would require no additional workers for operations. The project would operate
whenever Units 1, 2, 3, and 4 generate electric power, up to 24 hours per day for 365 days per year.
Dmft EIR Carnrnent Period:
The comment period on the Draft EIR will conclude at 5:00 PM on February 21, 2001. Written
comments may be submitted to the SCAQMD as noted below:
Steve Smith, Ph.D.
Program Supervisor
SCR F iw DM, AFS Los Al tos.CC Staff Repos 3
City Council Comment Letter re: Draft EIR—
Selective Catalytic Reduction (SCR) Installation, AES Los Alamitos Generating Station
prepared by South Coast Air Quality Management District
City Council SofReport
February 12, 2001
South Coast Air Quality Management District
21865 E. Copley Drive
Diamond Bar, CA 91765-4182
Public Availability:
A copy of the Draft EBR is available at the Department of Development Services, and at each library
within the City, for review. In addition, the Draft EBR is available at SCAQMD Headquarters, by
calling the SCAQMD's Public Information Center at (909) 396-2039, or by accessing the
SCAQMD's CEQA website at http://www.agmd.gov/cega/nonagmd.htm].
Summary of Previous Environmental Review Documents:
In 1993, the SCAQMD prepared a Final Supplemental Environmental Impact Report (EBR) for the
SCR system on Unit 5. The Final Supplemental EBR was prepared as a supplement to the Final
Subsequent EBR for the storage of aqueous ammonia and associated SCR system for Unit 6, which,
in tum, was prepared subsequent to and as a complement of the 1988 Program EIR for Proposed
Rule 1135, Emissions of Oxides of Nitrogen from Power Generating Steam Boilers. (SCAQMD,
1993b) These documents are available for review at the SCAQMD's Public Information Center, at
the Diamond Bar headquarters or by calling (909) 396-2039.
Initial Study for Alamitos Unit 5 (10/20/92): This Initial Study was prepared pursuant to the
state and SCAQMD CEQA Guidelines, and circulated as part of the Alamitos Unit 6 Subsequent
EBR. The Initial Study contained the Environmental Checklist and a preliminary identification
and discussion of the potential impacts of the proposed project.
Final Subsequent EIR (3122193) for Alamitos Unit 6. The Final Subsequent EBR for Unit 6
contained a detailed project description of the Underground Storage Tank (UST) and the SCR
system for Unit 6, environmental setting for each potential impact area, analysis of potential
environmental impacts (including cumulative impacts), analysis of project alternatives, and other
environmental topics as required by CEQA. The discussion of environmental impacts included a
detailed analysis of each of the following potential impact areas: air quality, water resources,
noise, risk of upset/human health, transportation/circulation, public services, energy/natural
resources, and utilities (solid waste). This document was certified by the SCAQMD on March
31, 1993. A mitigation monitoring plan was developed and implemented by Southern California
Edison (SCE), the owner of the Alamitos Generating Station at that time, for this project.
Final Supplemental EIR (8116193) for Alamitos Unit 5: The Supplemental EIR contained a
detailed project description, the environmental setting for each potential impact area, and
analysis of potential environmental impacts (including cumulative impacts), as required by
SCR Pmie DEIR. nes toe Mme .CC aren Report 4
City Council Comment Letter re: Draft EIR —
Selective Catalytic Reduction (SCR) Installation, AES Los Alamitos Generating Station
prepared by South Coast Air Quality Management District
City Council staff Report
February 12, 2001
CEQA. The discussion of environmental impacts included a detailed analysis of each of the
following potential impact areas: air quality, water resources, noise, risk of upset/human health,
transportation/circulation, public services, energy/natural resources, and utilities (solid waste).
Since 1993, AES has purchased the Alamitos Generating Station from SCE. However, the location,
operation and procedures have not significantly been altered since the change of ownership. The
installation of an aqueous ammonia storage tank, SCR units and ancillary features required detailed
CEQA analysis via the two EB3s completed in 1993 for SCR installation on Units 5 and 6 at this
location. The CEQA documents fisted above provide a general description of existing equipment
and operations at the Alamitos facility.
Previous City Actions:
On November 29, 2000, the City EQCB reviewed and commented on "Initial Study for Proposed
AES Alamitos LLC. — Selective Catalytic Reduction (SCR) Installation Project", prepared by
SCAQND, as discussed above. That comment letter dealt with comments on the initial study
document that led to the preparation of the subject DEIR. A copy of the November 29, 2000 City
comment letter is provided within Attachment 3, "Appendix B, Comment Letters and Response to
Comments", along with all other comment letters and responses received on the Notice of
Preparation for this Draft EBR for the information of the City Council. All of the comment letters
and responses are provided for the information of the City Council.
In February 1993 the City reviewed and commented on "Draft Subsequent Environmental Impact
Reportfor the Proposed Aqueous Ammonia Storage Tank Installation at SCE Alamitos Generating
Station", prepared by SCAQNID, as discussed above. That comment letter dealt with similar
activities proposed to be undertaken at the power plant and has not been provided.
Recommended City Action:
Staff has prepared a response letter for consideration of the City Council that continues to reflect
some of the concerns set forth in the EQCB comment letter (Refer to Attachment 1). The Draft EBR
adequately addressed the majority of the concerns of the EQCB set forth in the November 2000
comment letter. Due to the meeting schedule of the EQCB, they will not be able to review the Draft
EBR prior to the end of the comment period.
FBCAL IMPACT
No direct impacts.
SCR Project DEM. AES Los AUmut..CC Staff Report 5
City Counc l Comment Letter re. Draft EIR —
Selective Catalytic Redaction (SCR) Installation, AES Los Alamitos Generating Station
prepared by South Coast Air Quality Management District
City Council Staff Report
February 12, 2001
Instruct Mayor to sign proposed Comment Letter, and instruct staff to forward to Planning
Commission and Environmental Quality Control Board for information purposes. Receive and File
Staff Report.
NOTED AND APPRAE OD
Whittenberg, Director Donald F. McIntyre
Development Services Depart Acting City Manager
Attachments: (3)
Attachment 1: Draft Comment Letter re: "Draft EIR — AES Alamitos LLC. -
Selective Catalytic Reduction (SCR) Installation Project at Alamitos
Generating Station (Units 1, 2, 3 and 4)", prepared by the South
Coast Air Quality Management District
Attachment 2: "Draft EIR — AES Alamitos LLC. - Selective Catalytic Reduction
(SCR) Installation Project at Alamitos Generating Station (Units 1, 2,
3 and 4)", prepared by the South Coast Air Quality Management
District
Note: Provided are the "Table of Contents", "Chapter 1 — Executive
Summary", and "Chapter 2 — Project Description". Complete
document not provided due to length, 187 pages. Complete
document available at the Department of Development Services, City
Libraries, and at the South Coast Air Quality management District.
Attachment 3: Appendix B, "Comment Letters and Response to Comments" from
"Draft EIR — AES Alamitos I.I.C. - Selective Catalytic Reduction
(SCR) Installation Project at Alamitos Generating Station (Units 1, 2,
3 and 4)", Prepared by the South Coast Air Quality Management
District, including City Comment Letter dated November 29, 2000
re: "Notice of Preparation of a Draft Environmental Impact Report —
Proposed Selective Catalytic Reduction (SCR) Installation Project,
AES Los Alamitos, Long Beach"
SCR Pmjwt DEM AFS Los AIa W..CC Seen Repos
February 12, 2001
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 L.L.C. - SELECTIVE CATALYTIC
REDUCTION (SCR) INSTALLATION PROJECT AT
ALAMITOS GENERATING STATION (UNITS I, 2, 3 AND
4)„
Dear Dr. Smith:
The City of Seal 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 FIR document. The additional information provided within the
body of the Draft EIR and in Appendix B — "Comment 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
response that the project anticipates the reduction of NO, emissions from 6,132 tons/year to
478 tons/year. 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 EBR. It would seem most appropriate to provide this information with
Section 4.2.3.1, "Operation - NO, Emissions" of the Final EIR.
C.-WyD umnmNCEQAISCR R ieo DER, AES[ Alamitoa.CCLetter.docVWX-12-01
City of Seal Beach Comment Letter re:
"Draft EIR — Selective Catalytic Reduction (SCR) Installation
Project, AES Los Alamitos, Long Beach"
February 12, 2001
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
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 L.L.C., and describe how the project activities
will result in the reduction of future impacts to less than a significant level. It is also
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 concern 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 "Cumulative
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
Final EIR should be revised to adequately describe the impacts of the loss of 1,000 MW to
the California power grid and the ability of California to 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 EIR. 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
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 4-61 "Ammonia Slip Health Risk
Assessment Results", indicates "Average Annual Concentration (uglms)" is 1.965. It is
unclear if this number is the "cumulative hazard index" number discussed within this section
SCR P jmt Da1R, AES Las Ale tos.CC Leuer
City of Seal Beach Comment Letter re:
"Draft EIR - Selective Catalytic Reduction (SCR) Installation
Project, AES Las Alamitos, Long Beach"
February 12, 2001
of the Draft EIR. Please review and revise the language of the Final EIR to indicate what is
the `cumulative hazard index" number.
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 4.3.1.3 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 a.m. 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
transportation route indicated to deliver the aqueous ammonia to the site, using the I-405
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
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 EBR for this project, please send 1 copy to Mr. Lee Whittenberg,
Director 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, re" c
Patricia E. Campbell
Mayor
City of Seal Beach
SCR ftlec, EM, AES Los Alam ..CC Lener
Distribution:
Seal Beach City Council
Environmental Quality Control Board
Acting City Manager
Golden Rain Foundation
SCR P ject DEIR, AFS Los Auautos.CC Lett,
City of Seal Beach Comment Letter re:
"Draft E1R — Selective Catalytic Reduction (SCR) installation
Project, AES Los Alamitos, Lang Beach"
February 12, 2001
Seal Beach Planning Commission
Director of Development Service
City of Long Beach
SOUTH COAST AIR QUALITY
MANAGEMENT DISTRICT
DRAFT ENVIRONMENTAL IMPACT REPORT FOR:
AES ALAMITOS, L.L.C. — SELECTIVE CATALYTIC REDUCTION
(SCR) INSTALLATION AT ALAMITOS GENERATING STATION
(UNITS 1, 2,3 AND 4)
CITY OF SEAL BEACH
January 19, 2001
SCH No. 2000111039 JM 2 3 2001
OEVE OPMENTDEPARTME�SE:.
Executive Officer
Barry R. Wallerstein, D. Env.
Deputy Executive Officer
Planning, Rule Development, and Area Sources
Jack Broadbent
Assistant Deputy Executive Officer
Planning, Rule Development, and Area Sources
Elaine Chang, Dr.Ph.
Planning and Rules Manager
CEQA, Socioeconomic Analysis, PM/AQMP Control Strategy
Alene Taber, A.I.C.P.
Authors: URS Corporation - Consultant
Contributors:
Reviewed by: Steve Smith, Ph.D. — Program Supervisor
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT
GOVERNING BOARD
Chairman: WILLIAM A. BURKE, Ed.D.
Speaker of the Assembly Appointee
Vice Chairman: NORMA J. GLOVER
Councilmember, City of Newport Beach
Cities Representative, Orange County
MEMBERS:
MICHAEL D. ANTONOVICH
Supervisor, Fifth District
Los Angeles County Representative
HALBERNSON
Councilmember, City of Los Angeles
Cities Representative, Los Angeles County, Western Region
JANE W.CARNEY
Senate Rules Committee Appointee
CYNTHIA P. COAD, Ed.D.
Supervisor, Fourth District
Orange County Representative
BEATRICE J.S. LAPISTO-KIRTLEY
Councilmember, City of Bradbury
Cities Representative, Los Angeles County, Eastern Region
RONALD O. LOVERIDGE
Mayor, City of Riverside
Cities Representative, Riverside County
JON D. MIKELS
Supervisor, Second District
San Bernardino County Representative
LEONARD PAULIIZ
Councilmember, City of Montclair
Cities Representative, San Bernardino County
CYNTHIA VERDUGO-PERALTA
Governor's Appointee
S. ROY WILSON, Ed.D.
Supervisor, Fourth District
Riverside County Representative
EXECUTIVE OFFICER:
BARRY R. WALLERSTEIN, D.Env
TABLE OF CONTENTS
Chapter 1 - Executive Summary ..............................................................................................................1.1
Project Location.......................................................................................
1.1
Introduction..............................................................................................1-1
Background..............................................................................................2-1
1.2
Legislative Authority................................................................................
1-1
1.3
California Environmental Quality Act.....................................................1-2
Project Features ........................................................................................2-4
3-7
1.3.1 Previous Relevant Projects and CEQA Documentation ...............
1-2
2-4
1.3.2 Notice of Preparation and Initial Study (NOPAS)........................1-3
2.4.2 Aqueous Ammonia Storage Tanks...............................................2-5
1.4
Intended Uses of this EIR................................. ..................................
...... 1-3
1.5
Scope of EIR............................................................................................1-3
Operations....................................................................................2-5
1.6
EIR Summary ...........................................................................................1-4
2.4.4 Aqueous Ammonia Flow Control................................................2-6
1.6.1 Summary of Chapter 1 - Executive Summary ............. .................
1-4
2-6
1.6.2 Summary of Chapter 2 - Project Description ...............................
1-4
1.6.3 Summary of Chapter 3 - Existing Setting.....................................1-4
2.4.7 Criteria Pollutant and Ammonia Monitoring...............................2-7
1.6.4 Summary of Chapter 4 - Environmental Impacts and
2.4.8 Compliance Monitoring...............................................................2-7
Mitigation.....................................................................................1-5
2.4.9 Safety Features.............................................................................2-8
1.6.5 Summary of Chapter 5 — Project Alternatives ..............................
1-7
Chapter2 - Project Description...............................................................................................................2.1
2.1
Project Location.......................................................................................
2-1
2.2
Background..............................................................................................2-1
2.3
Project Objectives.....................................................................................2-4
3.2.2 Meteorology in the Vicinity of the Project ...................................
2.4
Project Features ........................................................................................2-4
3-7
3.3 Hazards and Hazardous Materials..........................................................
2.4.1 Selective Catalytic Reduction (SCR) Units ..................................
2-4
2.4.2 Aqueous Ammonia Storage Tanks...............................................2-5
2.4.3 Vaporization and Injection of Ammonia for SCR
Operations....................................................................................2-5
2.4.4 Aqueous Ammonia Flow Control................................................2-6
2.4.5 Aqueous Ammonia Storage Tank Refilling Operations ...............
2-6
2.4.6 Aqueous Ammonia Transport ......................................................2-6
2.4.7 Criteria Pollutant and Ammonia Monitoring...............................2-7
2.4.8 Compliance Monitoring...............................................................2-7
2.4.9 Safety Features.............................................................................2-8
2.4.10 Construction.................................................................................2-8
2.4.11 Operation......................................................................................
2-8
2.4.12 Permits and Approvals.................................................................2-9
Chapter3 - Existing Setting.....................................................................................................................3-1
3.1 Introduction..............................................................................................
3-1
3.1.1 Existing Generating Station Configuration and Operation ..........
3-1
3.2 Air Quality................................................................................................3-1
3.2.1 Regional Climate..........................................................................3-1
3.2.2 Meteorology in the Vicinity of the Project ...................................
3-3
3.2.3 Setting .............................................. .............................................
3-7
3.3 Hazards and Hazardous Materials..........................................................
3 -IC
AES Alamitos SCR i January 2001
TABLE OF CONTENTS
Chapter 4- Environmental Impacts and Mitigation...............................................................................4.1
4.1
Introduction..............................................................................................4-1
5-1
4.2
Air Quality................................................................................................4-1
5-1
4.2.1 Construction and Operation Emissions
5-1
Thresholds/Significance Criteria..................................................4-1
4.2.2 Construction Emissions................................................................4-2
5-2
5.3
4.2.3 Operations ........................... .........................................................
4-8
4.3
Hazards and Hazardous Materials .............. ............................................
4-17
4.3.1 Significance Criteria...................................................................4-17
4.4
Environmental Impacts Found Not To Be Significant ...........................4-24
4.4.1 Aesthetics...................................................................................4-25
4.4.2 Agriculture Resources................................................................4-25
5-7
5.5
4.4.3 Biological Resources..................................................................4-25
4.4.4 Cultural Resources.....................................................................4-26
4.4.5 Energy.........................................................................................4-26
4.4.6 Geology and Soils.......................................................................4-27
4.4.7 Hydrology and Water Quality....................................................4-28
4.4.8 land Use and Planning...............................................................4-30
4.4.9 Mineral Resources......................................................................4-30
4.4.10 Noise...........................................................................................4-30
4.4.11 Population and Housing.............................................................4-31
4.4.12 Public Services...........................................................................4-31
4.4.13 Recreation...................................................................................4-33
4.4.14 Solid/Hazardous Waste..............................................................4-33
4.4.15 TransportationtTraffic................................................................4-33
4.5
Other CEQA Topics...............................................................................4-34
4.5.1 Irreversible Environmental Changes..........................................4-34
4.5.2 Growth -Inducing Impacts...........................................................4-34
Chapter 5 - Project Alternatives..............................................................................................................5-1
5.1
Introduction..............................................................................................
5-1
5.2
Alternatives Rejected as Infeasible..........................................................
5-1
5.2.1 Alternative Location.....................................................................
5-1
5.2.2 Alternative NO, Controls.............................................................5-1
5.2.3 Alternatives to Aqueous Ammonia Transport and Storage..........
5-2
5.3
Description of Alternatives......................................................................
5-3
5.3.1 Alternative A - No Project............................................................5-3
5.3.2 Alternative B - 19 Percent Aqueous Ammonia ............................5-4
5.4
Comparison of the Alternatives................................................................5-4
5.4.1 Air Quality....................................................................................5-4
5.4.2 Hazards and Hazardous Materials ............ .............. ......................
5-7
5.5
Conclusion..............................................................................................5-10
References
AES Alamitos SCR ii January 2001
List of Tables, Figures and Appendices
Tables
Table 1-1 Environmental Impacts from the Project
Table 1-2 Comparison of Adverse Environmental Impacts Associated with Project
Alternatives
Table 1-3 Ranking of Alternatives
Table 3-1 Average Monthly Temperatures and Precipitation for Los Angeles International
Airport, CA, 1961 — 1990.
Table 3-2 Exceedances of State Ambient Air Quality Standards at the North Long Beach
Monitoring Station, 1997 — 1999
Table 3-3 Ambient Air Quality Standards
Table 4-1 Air Quality Significance Thresholds
Table 4-2 Construction Emissions
Table 4-3 Construction Related Mitigation Measures and Control Efficiency
Table 44 Overall Peak Daily Emissions During Construction (Mitigated)
Table 4-5 Screening Meteorology Used in the ISCST3 Modeling Analysis
Table 4-6 Ammonia Slip Health Risk Assessment Results
Table 4-7 Mobile Source Emissions
Table 4-8 Total Daily Mobile Source Emissions Compared to Significance Thresholds
Table 5-1 Comparison of Emissions Between The Proposed Project And Alternative B
(Ib/day)
Table 5-2 Comparison of Adverse Environmental Impacts Associated with Project
Alternatives
Table 5-3 Ranking of Alternatives
Figures
Figure 2-1
Project Location, AES Alamitos, L.L.C.
Figure 2-2
Location of Units 1, 2, 3, and 4 and Proposed NH3 Tanks
Figure 3-1
Dominant Wind Patterns in the Basin
Figure 4-1
Onsite Ammonia Release, Maximum Distance to 200 ppm; 0.1 mile
Appendices
Appendix A Notice of Preparation/Initial Study
Appendix B Comment Letters and Response to Comments
Appendix C Calculation Methodology for Construction Emissions
Appendix D Ammonia Slip Modeling Analysis (SCREEN3 Model Input and Output Files)
Appendix E Calculation Methodology: Mobile Source Emissions
Appendix F RMP*COMPT Output Files
AES Alamitos SCR 111 January 2001
CHAPTERI
EXECUTIVE SUMMARY
Introduction
Legislative Authority
California Environmental Quality Act
Intended Uses of this EIR
EIR Summary
Chapter I - Executive Summary
1.1 INTRODUCTION
AES Southland L.L.C. (AES) is a supplier of electricity to Southern California. AES generates
electrical service at three existing facilities within the South Coast Air Basin (Basin). The
proposed project, which is designed to reduce AES' emissions of oxides of nitrogen (NO,) in the
Basin, would be constructed at AES' Alamitos Generating Station, located on the eastern side of
the City of Long Beach in the County of Los Angeles.
Utility boilers at the Alamitos Generating Station use natural gas as the primary combustion fuel
and fuel oil as a backup fuel to produce steam. The steam produced in the utility boiler is vented to
steam turbine generators to produce electricity. As part of the combustion process, NO, is
produced and emitted to the atmosphere with the other flue gas constituents (mostly nitrogen,
carbon dioxide, and water vapor). Control of NO, emissions is important for at least three reasons:
1) NO, contributes to atmospheric nitrogen dioxide (NOD; 2) NO, is a precursor to ozone
formation; and 3) NO, is a precursor to the formation of suspended particulate matter (PMia).
Selective Catalytic Reduction (SCR) is a proven air pollution control technology that uses a
reducing agent (typically ammonia) to reduce NO, to nitrogen (N,) and water in the presence of a
catalyst. In an SCR system, ammonia is injected into the boiler flue gas. The ammonia/flue gas
mixture flows through a catalyst that accelerates the reaction between the ammonia and the NO,.
Ammonia used for SCR systems typically is stored in one or more storage tanks. The ammonia
is piped from the tank to the boiler where it is mixed with flue gas before passing through the
catalyst. AES is proposing to use aqueous (dilute) ammonia (approximately 29 percent by
weight) for this project.
AES proposes to install SCR at the Alamitos Generating Station's Units 1, 2, 3 and 4. SCR will
be used to reduce NO, emissions to comply with the declining facility -wide NO, emission limits
imposed under South Coast Air Quality Management District's (SCAQMD) Regulation XX —
Regional Clean Air Incentives Market (RECLAIM) Program.
To accomplish AES' goal at the earliest possible time, meet the needs of California energy
customers during the peak summer demand, and allow for continuing operation within their
RECLAIM annual allocations, AES hopes to begin equipment installation and modifications at
the Alamitos facility starting early in 2001, such that affected power generating units can be put
into use by summer 2001.
1.2 LEGISLATIVE AUTHORITY
The California Legislature created the SCAQMD in 1977 (The Lewis -Presley Air Quality
Management Act, Health and Safety Code Sections 40400-40540) as the agency responsible for
developing and enforcing air pollution control rules and regulations in the Basin. By statute, the
SCAQMD is required to adopt an Air Quality Management Plan (AQMP), which ensures
compliance with all state and national Ambient Air Quality Standards (AAQS) within the area of its
jurisdiction (Health and Safety Code Section 40460(a)). Furthermore, the SCAQMD must adopt
rules and regulations that carry out the AQMP (Health and Safety Code Section 40440(a)).
The California Environmental Quality Act (CEQA), Public Resources Code §21000 et seq., requires
that potential environmental impacts of proposed projects be evaluated and that methods to reduce,
AES Alamitos SCR 1-1 January 2001
Chapter 1 - Executive Summary
avoid or eliminate significant adverse impacts of these projects be identified and implemented where
feasible. To fulfill the purpose and intent of CEQA, SCAQMD is the lead agency for this project.
The lead agency is the public agency that has the principal responsibility for carrying out or
approving a project that may have a significant effect upon the environment (Public Resources
Code §21067). It was determined that the SCAQMD has the primary responsibility for
supervising or approving the project and is the most appropriate public agency to act as lead
agency (CEQA Guidelines §15051(b)). The proposed project requires discretionary approval
from the SCAQMD. SCAQMD has prepared this Draft Environmental Impact Report (DEIR) to
assess the potential environmental impacts associated with the AES Alamitos SCR Project for
Units 1, 2, 3 and 4.
1.3 CALIFORNIA ENVIRONMENTAL QUALITY ACT
The Final Environmental Assessment (FEA) for the RECLAIM program (October 1993)
analyzed, in a level of detail commensurate with the detail of the proposed project, the impacts
associated with the use of various add-on pollution controls to comply with RECLAIM. In
particular, the FEA for the RECLAIM program incorporated by reference environmental analyses
conducted for specific add-on pollution controls, including SCR, that could be used by power
generating facilities to comply with RECLAIM. To the extent that these analyses adequately
address the potential environmental impacts associated with this project, no further analysis is
required for such impacts (CEQA Guidelines § 15152(d)).
1.3.1 Previous Relevant Projects and CEQA Documentation
In 1993, the SCAQMD prepared a Final Supplemental Environmental Impact Report (EIR) for
the SCR system on Unit 5. The Final Supplemental EIR was prepared as a supplement to the
Final Subsequent E02 for the storage of aqueous ammonia and associated SCR system for Unit 6,
which, in tum, was 4repared subsequent to and as a complement of the 1988 Program EIR for
Proposed Rule 1135?— Emissions of Oxides of Nitrogen from Power Generating Steam Boilers
(SCAQMD, 1993b). These documents, summarized in the following paragraphs, are available
for review at the SCAQMD's Public Information Center or at its Diamond Bar headquarters, or
by calling (909) 396-2039.
Final Subsequent EIR (3122/93) for Alamitos Unit 6., The Final Subsequent EIR for Unit 6
contained a detailed project description of the underground storage tank (UST) and the SCR
system for Unit 6, environmental setting for each potential impact area, analysis of potential
environmental impacts (including cumulative impacts), analysis of project alternatives, and other
environmental topics as required by CEQA. The discussion of environmental impacts included a
detailed analysis of each of the following potential impact areas: air quality, water resources,
noise, risk of upset/human health, transportation/circulation, public services, energy/natural
resources, and utilities (solid waste). This document was certified by the SCAQMD on March
31, 1993. A mitigation monitoring plan was developed and implemented by Southern California
Edison (SCE), the owner of the Alamitos Generating Station at that time, for this project.
Since that time Rule 1135 has been superceded by the RECLAIM program, Regulation XX.
AES Alamitos SCR 1-2 January 2001
Chapter l - Executive Summary
Final Supplemental EIR (8116/93) for Alamitos Unit 5: The Supplemental EIR contained a
detailed project description, the environmental setting for each potential impact area, and analysis
of potential environmental impacts (including cumulative impacts), as required by CEQA. The
discussion of environmental impacts included a detailed analysis of each of the following
potential impact areas: air quality, water resources, noise, risk of upsetthuman health,
transportation/circulation, public services, energy/natural resources, and utilities (solid waste).
1.3.2 Notice of Preparation and Initial Study (NOPAS)
A NOPAS for this DEIR (Appendix A) were distributed to responsible agencies and interested
parties for a 30 -day review and comment period ending December 7, 2000. The NOP/IS identified
potential adverse impacts for the following two environmental topic areas: air quality and hazards
and hazardous materials. During the public comment period for the NOP/IS, the SCAQMD
received 7 comment letters, as well as 1 map that was followed up with a phone call to the
submitter. The SCAQMD's responses to comments submitted on the NOPAS are presented in
Appendix B of this DEIR.
1.4 INTENDED USES OF THIS EIR
Information regarding some of the potential environmental impacts associated with potential
construction -related impacts was difficult to ascertain or not available for inclusion in this DEIR.
As a result, the analyses of such impacts, though "worst-case," nonetheless are general or
qualitative in nature. In the instances where specific information is available, the environmental
impacts are quantified to the level of detail warranted by the information available.
Additionally, CEQA Guidelines §15124(d)(1) require a public agency to identify the following
specific types of intended uses:
• A list of the agencies that are expected to use the EIR in their decision-making;
• A list of permits and other approvals required to implement the project; and
• A list of related environmental review and consultation requirements required by federal,
state, or local laws, regulations, or policies.
See Section 2.4.12 for a discussion of public agencies' approvals and permits that may be
required.
1.5 SCOPE OF EIR
CEQA requires that the environmental impacts of a proposed project be evaluated and feasible
methods to reduce, avoid or eliminate identified potentially significant adverse impacts of the
project be considered. To fulfill the purpose and intent of CEQA, the SCAQMD, as the lead
agency, directed the preparation of this DEAR, which addresses the potential environmental
impacts associated with modifications at the AES generating station.
It should be noted that the Final Environmental Assessment for the RECLAIM program (October
1993) analyzed potential adverse environmental impacts associated with various add-on pollution
controls expected to be used to comply with RECLAIM. In particular, the Final Environmental
AES Alamitos SCR 1-3 January 2001
Chapter 1 - Executive Summary
Assessment for the RECLAIM program incorporated by reference previously prepared
environmental analyses conducted for specific add-on pollution controls (e.g., selective catalytic
reduction) that could be used by power generating facilities to comply with NO,, control
requirements. To the extent that these analyses adequately address the potential environmental
impacts associated with this project, no further analysis will be required (CEQA Guidelines
§15152(d)).
1.6 EIR SUMMARY
CEQA Guidelines, Section 15123 requires an EIR to include a brief summary of the proposed
actions and their consequences. In addition, areas of controversy including issues raised by the
public must also be included in the executive summary. This DEIR consists of the following
chapters: Chapter I - Executive Summary; Chapter 2 - Project Description; Chapter 3 - Existing
Setting, Chapter 4 - Environmental Impacts and Mitigation; Chapter 5 - Project Alternatives; and
two appendices. The following subsections briefly summarize the contents of each chapter.
1.6.1 Summary of Chapter 1 -Executive Summary
Chapter 1 includes a discussion of the legislative authority that requires or provides for the
SCAQMD to act as Lead Agency for this project and also identifies general CEQA requirements.
Chapter 1 presents summaries of the remaining chapters that comprise this DEIR.
1.6.2 Summary of Chapter 2 - Project Description
Chapter 2 describes the SCR units to be installed and it provides details regarding the operation
and monitoring of these units. Chapter 2 also describes the construction activities that would
occur and discusses the project's objectives, which include:
• To comply with RECLAIM Program or requirements imposed on the Alamitos Generating Station;
• To reduce NO, emissions from Units 1, 2, 3, and 4;
• To minimize operational impacts by limiting changes to existing systems or technologies at
the facility; and
• Provides 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 early in
2001, such that affected power generating units can be put into use by summer 2001.
1.6.3 Summary of Chapter 3 -Existing Setting
Pursuant to the CEQA Guidelines §15125, Chapter 3 - Existing Setting, includes descriptions of
those environmental areas that could be adversely affected as a result of the implementation of the
proposed SCR project as they existed at the time the NOPAS was released for public review. The
Initial Study identified two areas where adverse impacts potentially could occur as a result of the
proposed project: Hazards and Hazardous Materials and Air Quality. The following subsections
briefly highlight the existing settings for these two environmental areas. Other environmental topic
areas where no adverse impacts are anticipated are presented in Section 1.6.4.4.
AES Alamitos SCR 14 January 2001
Chapter I - Executive Summary
1.6.3.1 Air Quality
Over the last decade and a half, there has been significant improvement in air quality in the
SCAQMD's jurisdiction. Nevertheless, several air quality standards are still exceeded frequently
and by a wide margin. Of the national Ambient Air Quality Standards (AAQS) established for six
criteria pollutants (ozone, lead, sulfur dioxide, nitrogen dioxide, carbon monoxide, and PMio), the
area within the SCAQMD's jurisdiction is in attainment for the lead, nitrogen dioxide, and sulfur
dioxide standards. Chapter 3 provides a brief description of the existing air quality setting for each
criteria pollutant, as well as the human health effects resulting from each pollutant.
As stated previously, stationary source equipment, including combustion equipment, is regulated
by the SCAQMD. Accordingly, the proposed project is being developed by AES to reduce
emissions of NO, from its operations for the purpose of achieving regulatory compliance with the
RECLAIM Program. NO, emissions are produced as part of the combustion process and, absent
appropriate controls, would be vented into the atmosphere with other flue gas constituents. NO,
is formed by the oxidation of atmospheric nitrogen during combustion and from the oxidation of
bound nitrogen in organic fuels. The amount of NO, formed depends, in part, upon the available
oxygen supply and combustion temperature.
1.6.3.2 Hazards and Hazardous Materials
The Alamitos facility currently has two units (Units 5 and 6) with SCR and associated aqueous
ammonia storage. The proposed project would add SCR to the remaining four units and increase
the onsite storage of 29 percent aqueous ammonia by adding three aboveground storage tanks
and ancillary piping, pumps and secondary containment.
The transportation of aqueous ammonia would occur along major interstates on a currently -
approved route, and would be regulated by the U.S. Department of Transportation (DOT) and the
California I-fighway Patrol (CHP).
1.6.4 Summary of Chapter 4 - Environmental Impacts and Mitigation
CEQA Guidelines Section 15126.2(a) requires the following: "An EIR shall identify and focus
on the significant environmental effects of the proposed project... Direct and indirect significant
effects of the project on the environment shall be clearly identified and described, giving due
consideration to both the short-term and long-term effects."
The following subsections briefly summarize the analysis of potential adverse environmental
impacts from the adoption and implementation of the proposed project.
1.6.4.1 Air Quality
Implementation of the proposed SCR project would reduce NO, emissions from Units 1, 2, 3,
and 4 by at least 90 percent. Construction emissions would occur from demolition of existing
equipment, preparation of the site for the installation of the ammonia tanks, and installation of
the SCR systems and related equipment. None of the criteria pollutant would exceed
significance thresholds during construction. It is anticipated that the construction activities for
the project would occur for approximately three months.
AES Alamitos SCR 1-5 January 2001
Chapter I - Executive Summary
The environmental review also revealed that there would be no significant adverse direct or
cumulative air quality impacts associated with operational activities once the proposed project has
been implemented. The proposed SCR project is expected to achieve direct and cumulative air quality
benefits from a significant reduction (at least 90 percent) of NO, emissions from Units 1, 2, 3, and 4.
1.6.4.2 Hazards and Hazardous Materials
The hazards impacts analysis in Chapter 4 examines the construction and operational hazards of
implementing the SCR project. Hazard impacts associated with the construction of the SCR
project would be insignificant. The analysis of hazards associated with the transportation and
storage of aqueous ammonia for operation of the SCR project concluded that the potential hazard
impacts, though low, would remain significant after mitigation.
1.6.4.3 Mitigation
Although there are no significant construction emission impacts, AES anticipates the application
of the mitigation measures listed in Table 1-1 to further reduce emissions during construction.
The implementation of the proposed project would result in certain unmitigable hazards impacts
during operation. Table I -I summarizes the impacts and mitigation measures associated with the
environmental impact areas analyzed for the proposed project.
1.6.4.4 Environmental Impacts Found Not To Be Significant
The Initial Study for the proposed project includes an environmental checklist of approximately
15 categories of potential environmental impacts. As discussed above, review of the current
proposed project identified two categories for further review in the DEIR. The Initial Study
concluded that the project would have no significant direct or indirect adverse effects on the
remaining environmental categories. Therefore, the SCAQMD has determined that there will be
no significant impacts to the following environmental areas as a result of implementing the
proposed project:
• Aesthetics
• Agriculture Resources
• Biological Resources
• Cultural Resources
• Energy
• Geology/Soils
• Hydrology/WaterQuality
• Land Use and Planning
• Mineral Resources
• Noise
• Population and Housing
• Public Services
• Recreation
• Solid/Hazardous Waste
• Transportation/Traffic.
AES Alamitos SCR 1-6 January 2001
Chapter I - Executive Summary
Table 1-1
Environmental Impacts from the Project
Environmental
Impact Area
Significance
Determination
Mitigation
Measures
Significance
After Mitigation
Air Quality
Construction:
Direct/Indirect
Not Significant
AO -1 Utilize existing power poles rather than temporary
Not Significant
internal combustion engine power generators.
AQ -2 Use low sulfur fuel for stationary construction
equipment.
AW Maintain construction equipment engines by keeping
them properly tuned.
AQ -4 Minimize vehicle idling time, where applicable.
Operational:
Direct
Not Significant
None Required
Not Significant
Indirect
Not Significant
None Required
Nut Significant
Hazards
Construction:ona
Not Significant
None Required
Not Significant
Operatil:
Direcbindiract
Significant
H-1 No transport of aqueous ammonia during school hours
Significant
or between 7 a.m. -9 a.m. and 4 p.m. - fi p.m.
Air Quality benefits associated with the implementation of the proposed fleet vehicle rules and related amendments are
discussed in Chapter 4 of this DEIR.
1.6.5 Summary of Chapter 5— Project Alternatives
Chapter 5 provides a discussion of alternatives to the proposed project as required by the CEQA
Guidelines. The alternatives analyzed include measures for attaining the objectives of the
proposed project and provide a means for evaluating the comparative merits of each alternative.
Table 1-2 lists the alternatives considered by the SCAQMD and how they compare to the
proposed project.
Alternative A - No Project
Section 15126.6(e)(1) of the CEQA Guidelines requires that "(t)he specific alternative of 'no
project' shall be also be evaluated..." The No Project Alternative would consist of continued
operation of Units 1, 2, 3, and 4 under existing conditions. In other words, the proposed aqueous
ammonia storage tanks would not be constructed and associated SCR systems would not be
retrofitted onto Alamitos Generating Station Units 1, 2, 3, and 4.
AES Alamitos SCR 1-7 January 2001
Environmental
Topic
Air Quality Pot lut rdw
Construction
Operational
Hazards
Chapter 1 - Executive Summary
Table 1-2
Comparison of Adverse Environmental Impacts
Associated with Project Alternatives
Alternative A Alternative B Proposed Project
(No Project)(19 Percent Aqueous Ammonia) (29 Percent Aqueous Ammonia)
Not Significant;
However, NO,
emission reduction
would be foregone
Not Significant
Not Significant Not Significant
Not Significant Not Significant
Significant, due to additional 50% Significant
increase in tanker truck deliveries;
impacts would be greater than
a Emission benefits and increases associated with the proposed project.
Installation of the SCR systems on the existing Units 1, 2, 3, and 4 are required in order for the
facility to comply with future RECLAIM Program requirements and, in tum, to continue
supplying reliable in -Basin power. More specifically, the No Project alternative would likely
result in exceedances of the Alamitos facility's Annual Allocation of N% emissions, which
could subject AES to substantial fines, penalties and closures, and reduce its ability to meet peak
energy demands in the Basin and in California.
Altemative B -19 Percent Aqueous Ammonia
This alternative would be similar to the proposed project, i.e., aqueous ammonia would be
utilized with SCR units to reduce NO, emissions. The lower percentage of aqueous ammonia
would require a redesign of piping from the storage tanks to the stacks. The storage tanks would
be located in approximately the same location and would be aboveground, double -walled, carbon
steel, individually -berried storage tanks.
Ammonia truck deliveries to the facility would increase by approximately 50 percent over the
number that would occur with the proposed project. Also, two types of aqueous ammonia (19
and 29 percent) would be delivered to the facility because Units 5 and 6 currently operate with 29
percent aqueous ammonia.
Additionally, due to larger flow volumes going into the gas path, the possibility of a visible
Plume occurring at the stack exit would increase by using 19 percent aqueous ammonia.
Table 1-3 presents a matrix that again lists potential impacts associated with the proposed project
and the project alternatives for the specific environmental topics analyzed in this DEER. The
table also provides a ranking of the proposed project and the project alternatives based on the
level of potential impacts and the ability to meet project objectives.
AES Alamitos SCR 1-8
January 2001
Chapter I - Executive Summary
Table 1-3
Ranking of Alternatives'
a Air Quality and Hazards are the only topics analyzed because, as discussed in the EIR, the proposed project and
two alternatives would not resuh in significant impacts in other environmental topic areas. Refer to Section 4.4
for a detailed discussion of environmental impacts found not to be significant.
b The number of project objectives met by the proposed project or alternative. (Refer to Section 2.3 of EIR)
c The ranking is based on which action will meet the most project objectives with the least significant impacts. "1"
is the highest ranking and "3" is the lowest ranking.
AES Alamitos SCR 1-9 January 2001
Project
Air Quality
Hazards
Objectives Metb
Ranking=
Proposed Project
. No construction impacts.
. No construction impacts.
4 out of 4
1
(29 Percent
Aqueous Ammonia)
"Net beneficial effect on
• Unmitigable, significant
long-term operational
impact related to
emissions as a result of
aqueous ammonia.
NO. emission reduction.
, No cumulative impacts.
• No cumulative impacts.
(Refer to Section 4.2)
(Refer to Section 4.3)
Altemafive A
. No construction impacts.
• No new impacts.
1 out of 4
3
(No Project)
. Continuation of existing
operation would not
realize the NO. reduction
benefits of SCR.
(Refer to Section 5.4.1.1)
(refer to Section 5.4.1.1)
Alternative R
. Same air quality impacts
• Same hazard impacts as
3 out of 4
2
(19 Percent
as Proposed Project
Proposed Project (see
Aqueous Ammonia)
(see description above).
description above).
50% increase in tanker
• W/b increase in tanker
truck deliveries (greater,
truck deliveries
but not significant,
increases probability of
operational impacts)
tanker truck failure.
(Refer to Section 5.4.1.2)
(Refer to Section 5.4.2.2)
a Air Quality and Hazards are the only topics analyzed because, as discussed in the EIR, the proposed project and
two alternatives would not resuh in significant impacts in other environmental topic areas. Refer to Section 4.4
for a detailed discussion of environmental impacts found not to be significant.
b The number of project objectives met by the proposed project or alternative. (Refer to Section 2.3 of EIR)
c The ranking is based on which action will meet the most project objectives with the least significant impacts. "1"
is the highest ranking and "3" is the lowest ranking.
AES Alamitos SCR 1-9 January 2001
CHAPTER 2
PROJECT DESCRIPTION
Project Location
Background
Project Objectives
Project Description
Chapter 2 — Project Description
2.1 PROJECT LOCATION
The City of Long Beach is situated along the Pacific Ocean, to the southeast of the Palos Verdes
peninsula in Los Angeles County. Within the city limits are residential areas, a power generating
station (AES Alamitos Generating Station), oil production facilities, light industry, and the Long
Beach Harbor. Several commercial corridors serve the needs of the community.
As of 1990, the population of Long Beach was approximately 440,000, which is distributed
throughout 49.7 square miles. The terrain generally slopes toward the ocean. The Long Beach
Harbor extends for approximately five miles to the south and west of the city, and the Long
Beach Marina is situated on the east side of the city, just south of the proposed project location.
The City of Seal Beach, which is adjacent to the proposed project location on the eastern side,
has a population of approximately 25,000 (10.7 square miles) and Los Alamitos to the northeast
has a population of approximately 12,000 (2.25 square miles).
The project is proposed to be constructed at the Alamitos Generating Station, which is located at
690 North Studebaker Road in the City of Long Beach, California. Figure 2-1 shows the vicinity
and the project site location. The Alamitos Generating Station is located on the eastern side of
the City of Long Beach, and is bounded by 7th Street to the north, the San Gabriel River to the
east, Westminster Avenue to the south, and North Studebaker Road to the west. The City of Seal
Beach is adjacent to the eastern edge of the facility across the San Gabriel River. The Alamitos
Generating Station occupies about 165 acres and is surrounded by industrial and some residential
properties. Figure 2-2 shows the location of all three proposed aqueous ammonia storage tanks,
which would be located approximately 500 feet from Units 1 through 4, in the central portion of
the 165 -acre site.
2.2 BACKGROUND
Regulation XX - Regional Clean Air Incentives Market (RECLAIM) is a regulatory program
designed and adopted by the SCAQMD to reduce oxides of nitrogen (NO,) and sulfur dioxides
(SO2) emissions from stationary sources in the areas within the jurisdiction of the SCAQMD,
while lowering the cost of attaining clean air through the use of market incentives. The goals of
RECLAIM are to assist SCAQMD in its efforts to attain and maintain state and national ambient
air quality standards, and to give affected facilities added flexibility in meeting their emission
reduction requirements, to lower the cost of compliance. The emission reduction goals are
established in the form of declining Annual Allocations. Facilities comply with RECLAIM by
installing control equipment that limits their annual NO, and/or SO, emissions to below or equal
to their Annual Allocations or by purchasing additional RECLAIM Trading Credits (RTCs) to
account for any exceedances above their Annual Allocations. AES Southland, L.L.C. is
proposing to install SCR on the Alamitos Units 1, 2, 3, and 4 as part of their plan to meet the
declining facility -wide NO, emission limits required by the RECLAIM Program.
AES Alamitos SCR 2-1 January 2001
Chapter 2 — Project Description
AES Alamitos SCR 2 - 2 Jarman 2001
Chapter 2 — Project Description
AES Alamitos SCR 2 - 3 /anuary 200
Chapter 2 — Project Description
2.3 PROJECT OBJECTIVES
CEQA Guidelines § 15124(b) requires a CEQA document to include a statement of objectives,
which describes the underlying purpose of a proposed project. The purpose of the statement of
objectives is to aid the decision -makers in evaluating the benefits of the project, in preparing
findings regarding the project and, if necessary, issuing a statement of overriding considerations,
concerning the need for the project. The objectives of the proposed project are:
• To comply with Regulation XX, specifically the declining annual RECLAIM Allocations for
the Alamitos Generating Station;
• To reduce NO, emissions from Units 1, 2, 3, and 4;
• To minimize operational impacts by limiting changes to existing systems or technologies at
the facility; and
• Provides 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 early in
2001, such that affected power generating units can be put into use by summer 2001.
2.4 PROJECT FEATURES
The proposed SCR project consists of the installation of: 1) four SCR reactor units within the
existing boilers of Units 1, 2, 3 and 4; 2) carbon steel assembly comprised of four reactors; 3)
three 20,000 -gallon double -walled, aboveground, and separately contained carbon steel ammonia
storage tanks; and 4) control equipment that would be incorporated into the existing generating
station distribution control system with new interface hardware. Aqueous ammonia would be
transported to the facility via tanker truck along the existing approved route, which was
established prior to and in conjunction with the installation of SCR on Units 5 and 6.
All new equipment would be located within the existing fenceline of the Alamitos Generating
Station. The SCR reactor units would be encased in the existing boiler duct works and would not
be visible off-site. All other new components would be installed close to the existing boiler
structure and would not be visible off-site. A temporary construction area would be located at
the rear of the units.
2.4.1 Selective Catalytic Reduction (SCR) Units
As part of the combustion process, NO, is produced and, if not controlled properly, is emitted to
the atmosphere along with the other flue gas constituents (mostly nitrogen, carbon dioxide, and
water vapor). SCR is a proven air pollution control technology that uses a reducing agent
(ammonia) to reduce NO, to nitrogen and water in the presence of a catalyst. In an SCR system,
ammonia is injected into the boiler flue gas. The ammonia/flue gas mixture flows through a
catalyst that accelerates the reaction between the ammonia and the NO,. Ammonia used for SCR
systems typically is stored in one or more storage tanks. The ammonia is piped from the tank to
the boiler where it is mixed with flue gas before passing through the catalyst. The catalyst is
composed of individually extruded homogenous honeycomb ceramic elements of approximately
six inches by six inches to 38 inches in diameter packed into steel support modules of 105 inches
AES Alamitos SCR 2-4 January 2001
Chapter 2 — Project Description
by 75 inches by 49 inches. The catalyst's active elements are formulated from a proprietary
mixture of titanium dioxide z.id vanadium pentoxide. At the end of the catalyst's useful life
(three years or more), the catalyst modules would be recycled by the catalyst manufacturer,
MHIA, or disposed according to federal, state and local regulations, offsite and in an appropriate
disposal facility.
The SCR reactor would be installed in the existing boiler footprint. There would be no
modifications to the boilers or burners except for the addition of ductwork to the gas path. The
reactor housing is a steel fabricated assembly with structural supports, ladders and platforms,
catalyst removal doors, and catalyst removal hardware. The reactor would be provided in
multiple sections for erection at the site. The reactor includes an internal framework to support
the catalyst. There is no NO, limit established in the draft Tide X permit, however, an allowable
ammonia slip limit is 10 parts per million (ppm).
2.4.2 Aqueous Ammonia Storage Tanks
AES proposes to use a 29.4 percent aqueous ammonia solution for the SCR systems serving
Units 1 — 4 at the Alamitos Generating Station. The proposed project consists of storing aqueous
ammonia in three new, 20,000 -gallon, double -walled, aboveground, and separately contained
carbon steel ammonia storage tanks. The storage tanks are ASME-registered U -stamped pressure
vessels designed for ammonia service. To minimize potential ammonia leakage, the tanks would
utilize a double-wall design. The inter -wall space is isolated from the main storage space and is
independently drainable. The ammonia supply of the boiler SCR units would be taken from
these storage tanks.
Units 1 and 2 would utilize one tank (located south of Unit 1) and Units 3 and 4 would utilize
two tanks (located south of Unit 3). Please refer to Figure 2-2 for tank locations. The proposed
tanks are horizontal, and have a nominal capacity of 20,000 U.S. gallons. The tanks will be
capable of withstanding pressures of 25 pounds per square inch gage (psig), which is designed
for the worst-case ambient temperature condition of 125 degrees Fahrenheit.
Each storage tank would be placed within a concrete berm that would be 595.5 square feet. The
berms have design capacities of 110 percent and account for the 6.4 inches (over 24 hours) of
cumulative rainfall for a 25 -year frequency storm.
There are no NO, limits on the units, per the draft Title X permit, and the allowable ammonia
slip limit is 10 parts per million (ppm).
2.4.3 Vaporization and Injection of Ammonia for SCR Operations
Two 100 -percent capacity hot air fans, one operating and one spare, will provide preheated
dilution air to convey the ammonia to the injection grids upstream of the SCR catalyst,
downstream of the boiler economizer. The dilution air is taken from the air pre -heater air outlet
to provide the flow and pressure requirements to ensure that the ammonia vaporizer outlet
temperature remains above 300°F, assuring complete vaporization of ammonia and preventing
localized condensation.
AES Alamitos SCR 2-5 January 2001
Chapter 2 — Project Description
Hot air from the fans flows through a common plenum into a vaporizer at a constant flow. Flow
of NH3 solution into the vaporizer is regulated primarily by NO, concentration in the flue gas
upstream of the SCR. The vaporized NH3 solution is injected into the vaporizer using a
supersonic atomizing nozzle. The small droplet size of the ammonia allows the ammonia to
quickly vaporize and thoroughly mix with hot air before the gas stream exits the vaporizer.
The injection grid is divided into multiple regions. Valves for each region permit the NH3 flow
rate to be individually adjusted during initial commissioning to optimize NO, reduction and to
account for duct NO, stratification.
2.4.4 Aqueous Ammonia Flow Control
The flow control of the NH3 solution into the vaporizers is established by an algorithm that uses
several parameters, including SCR inlet NO, concen,ration, to determine the amount of NH3
needed to maintain compliance with a specific emission limit. The measured SCR outlet NO,
concentration is used to modify the NH3 flow rate and optimize performance. Standard control
valves are provided to control NH3 flow.
The existing emissions monitoring system on the boiler will be used to assess of SCR outlet NO,
concentration. No physical modification to the emission reporting system will be necessary.
However, the SCAQMD will require that the existing Continuous Emissions Monitoring
Systems (CEMS) be re -certified for lower level reading accuracy.
2.4.5 Aqueous Ammonia Storage Tank Refilling Operations
The ammonia storage tanks are filled via vendor tanker trucks deliveries scheduled at regular
intervals based upon ammonia consumption. Track supply hoses are connected to a loading
bulkhead. Transfer pumps, hose purge equipment, and loading controls are provided on the
tanker truck itself. To retain a closed system and minimize potential leakage, the loading system
design incorporates both liquid fill hoses and vapor return hoses. Upon completion of filling
operations, all lines are purged with compressed air prior to being disconnected.
2.4.6 Aqueous Ammonia Transport
The aqueous ammonia for this project would be trucked in 6,000 -gallon tanker trucks to the
Alamitos Generating Station by a local distributor within the Basin. The distributor receives the
ammonia as anhydrous ammonia, delivered by rail from manufacturing facilities outside the
Basin, before converting it to aqueous ammonia.
AES anticipates purchasing its aqueous ammonia from Pacific Diazo Products. This primary
supplier will ship the aqueous ammonia from Fontana on Interstates 1- 15, 1- 10, and I-605 to the
Alamitos Generating Station in Long Beach, a distance of approxima.ely 63 miles. Currently,
AES receives about 170 aqueous ammonia deliveries per year. The proposed project will add
approximately 240 new trips per year.
As stated in the EIR for Unit 6 (1993) the only practical mitigation to an ammonia spill during
transport is the application of emergency response procedures as currently utilized by hazardous
AESAIan itos SCR 2-6 January 2001
Chapter 2 — Project Description
materials units, police, and other appropriate personnel. Emergency response to a hazardous
materials release typically includes stopping, containing, and diluting or covering the spill and/or
collecting and removing the material from the environment. The transport of aqueous ammonia
for the proposed project will adhere to these existing mitigation measures.
2.4.7 Criteria Pollutant and Ammonia Monitoring
Monitoring would be performed as required by the current Tide V application. Additional monitoring
for ammonia would be implemented as a result of the proposed modification. Continued adherence to
the current Title V monitoring requirements and the proposed ammonia monitoring would result in
on-going compliance with applicable air quality rules and regulations. The application for
Compliance Certification held for the facility verifies current compliance with such regulations. On-
going monitoring is performed in accordance with Regulation XX — RECLAIM.
2.4.8 Compliance Monitoring
Ammonia flow would be monitored on a continuous basis. The proposed monitoring is based on
the monitoring requirements previously established for the SCR systems on Unit 5 and 6 at the
Alamitos Generating Station. AES proposes to install and maintain a flow meter to accurately
indicate the flowrate of the total hourly throughput of the injected ammonia. The meter would be
equipped with a device to continuously record the ammonia flow rate. The measuring device or
gauge would be accurate to within plus or minus five percent. It would be calibrated once every
twelve months.
Further, AES would conduct a source test on each boiler every year to determine the ammonia
emissions at the outlet. AES would test each boiler every other year provided both boilers are in
operation. The test would be conducted using District Method 207.1 (or other SCAQMD
approved method) over a 60 -minute averaging time, in order to demonstrate compliance with the
BACT ammonia limit established under SCAQMD Rule 1303.
Any compliance monitoring required by the facility Risk Management Plan (RMP) also would be
implemented. Consistent with recent California Energy Commission and EPA Prevention of
Significant Deterioration (PSD) permit monitoring requirements, standard industry practice for
calculating the concentration of ammonia slip would be utilized by AES. More specifically, slip
concentrations will be calculated using ammonia flow and source test data and based on concentration
of NO, removed versus measured ammonia flow. Compliance with the ammonia slip limit would be
demonstrated using the following calculation:
Ammonia slip ppmv @ x % 02 = ((a - (b*c/1,000,000)) * 1,000,000 / b) * d
Where:
a= ammonia injection rate (lb/hr)/17(lb/lb. mol)
b = dry exhaust gas flow rate (1b/hr)/29(lbflb. mop
c = change in measured NO, concentration ppmv at x % O, across catalyst
d = correction factor (derived by comparing the measured and calculated ammonia slip during
annual [or other agreed upon frequency] compliance testing).
AESAlamiros SCR 2-7 January 2001
Chapter 2 — Project Description
2.4.9 Safety Features
A number of safety features would be incorporated into the design of the system to minimize the
likelihood of an accidental ammonia release. Because of the comprehensive regulations in place
regarding the use and transportation of ammonia, the design of systems utilizing ammonia in
conjunction with strict ammonia handling procedures have significantly reduced the potential for
accidental releases. Regarding the safety systems incorporated into the proposed project, the
system design will adhere to all appropriate codes and standards including Occupational Safety
and Health Association (OSHA), American Society of Mechanical Engineers (ASME), and
American National Standards Institute (ANSI). AES Alamitos Generating Station's Hazardous
Material Release Contingency Plan would be updated to reflect the proposed additional storage
of aqueous ammonia at the facility.
To further reduce potential safety risks, ammonia leakage detectors would be installed at the storage
tank -loading bulkhead and in the immediate vicinity of the storage tank, pump skid, and flow
controllvaporizer skid is a leak is detected. The leakage detector triggers an alarm in the control room
and sets off a local flashing light and horn. In response to an ammonia vapor alarm, the generating
station operators would shut down the ammonia feed supply to prevent excessive ammonia from
being spilled.
2.4.10 Construction
Construction activities are anticipated to take place five days per week, Monday through Friday,
from 6:00 a.m. to 5:00 p.m. for approximately four months. However, night and/or weekend
shifts may be required to maintain the proposed construction schedule. The construction shift
size is expected to be approximately 50 people of a variety of trades, including mechanics and
boiler makers. Construction equipment will include a fork lift, backhoe or bobcat, wackers,
welding machines, and cranes.
To minimize potential construction noise impacts, AES will require contractors to use electric
tools and welding machines (approximately 70 to 75 decibels) versus air or diesel tools (90 to
100 decibels). The use of electric equipment will keep construction noise below the City's noise
limit of 75 decibels.
2.4.11 Operation
The proposed project would not require any additional workers for operations. The project
would operate whenever Units 1, 2, 3, and 4 generate electric power, up to 24 hours per day for
365 days per year.
Noise generated by AES' current operations has been minimized by the use of sound enclosures on
existing equipment. For example, Units 5 and 6 have blower equipment that is enclosed in custom
designed insulation shields. AES would incorporate similar effective noise control methods for the
proposed project. For example, the hot gas blowers (four 100 hp/3,600 rpm) used to move the
dilution media would be externally insulated for thermal and audible protection. Also, SCR
equipment for Units l and 2 would be housed within a building, acting as a noise suppression
measure. SCR equipment on Units 3 and 4 would be installed on the exterior.
AES Alamitos SCR 2-8 January 2001
Chapter 2 — Project Description
2.4.12 Permits and Approvals
The proposed project will not require any local discretionary actions (e.g., Conditional Use Permit
or Coastal Development Permit). Building Permits will be required by the City of Long Beach,
Building Department. The Long Beach Fire Department must approve the project prior to final
approval for the Building Permits. The generating station will be required to update the California
Accidental Release Prevention (CalARP) Program and Emergency Response Business Plan to
reflect the addition of the new SCR units. Also, an Authority to Construct and a Permit to Operate
must be obtained from the SCAQMD. Lastly, the Continuous Emissions Monitoring System must
be recertified by SCAQMD and USEPA.
AES Alamitos SCR 2-9 January 2001
I I t
City Council Comment Letter re: Draft EIR—
Selective Catalytic Reduction (SCR) Installatiom AES Los Alamitos Generating Station
prepared by South Coost Air Quality Management DtsMct
Cory Council SMfj'Report
February 12, 2001
ATTACHMENT 3
APPENDIX B, "COMMENT LETTERS AND
RESPONSE TO COMMENTS" FROM "DRAFT EIR
- AES ALAMITOS I.I.C. - SELECTIVE CATALYTIC
REDUCTION (SCR) INSTALLATION PROJECT AT
ALAMITOS GENERATING STATION (UNITS 1, 2, 3
AND 4)", PREPARED BY THE SOUTH COAST AIR
QUALITY MANAGEMENT DISTRICT,
INCLUDING CITY COMMENT LETTER DATED
NOVEMBER 29, 2000 RE: "NOTICE OF
PREPARATION OF A DRAFT ENVIRONMENTAL
IMPACT REPORT - PROPOSED SELECTIVE
CATALYTIC REDUCTION (SCR) INSTALLATION
PROJECT, AES LOS ALAMITOS, LONG BEACH"
SCR Rojwt DM, AES Loa Alamiwa.CC Staff Report 13
APPENDIX B
COMMENT LETTERS AND RESPCNSE TO COMMENTS
(NOP/IS)
LETTER #1
Extract of official document: Seismic Hazard Zones Map
Los Alan-�itos 71/2-m-*Lnute Quadrangle
Scale: 1:24,000 or 1 inch = 2,000 feet
with application to the Alamitos Generating Station
Issued as an Oficial Map by State Geologist on March 25, 1999
Delineated in compliance with Chapter 7.8, Division 1, California Public Resources Code
Seismic Hazards Mapping Act of 1990 -
The coarse stippled patterns indicate official zones for liquefaction investigations.
For explanation, refer to California Division of Mines & Geology Special Publication 117,
Guidelines for Evaluating and Mitigating Seismic H=ards in California, 1997, 74 pages.
SP -117 and the complete zone map may be downloaded free from the CDMG homepage at
www.consrv.ca.gov/dmg
1-1
COMMENT LETTER #2
CITY OFANAHEIM, CALIFORNIA
Planning Department
J
November 14, 2000
Dr. Steve Smith
South Coast Air Quality Management District
CEQA Section
21865 E. Copley Drive
Diamond Bar, CA 91765-4182
RE: Notice of Preparation of a Draft Environmental Impact Report for the Proposed
AES Alamitos, L.L.C. — Selective Catalytic Reduction (SCR) Installation Project
Dear Dr. Smith:
Thank you for providing the City of Anaheim notice and the opportunity to comment
regarding the above -referenced project. We have no information or comment to provide.
Please forward any subsequent public notices and/or environmental documents regarding 2_1
this project to my attention at the address listed below.
If you have any questions regarding this response, please do not hesitate to contact me at
(714) 765-5139, extension 5440.
Sincerely,
L-Gcy N. Yeager
Senior Planner
8cagmdl (resp
200 S°uth Anaheim Boulevard
P.O. Box 3222, Anaheim, California 92803 • (714) 765-5139 • w .anaheim.net
so
COMMENT LETTER #3
CITY OF LONG BEACH
DEPARTMENT OF PLANNING AND BUILDING
— �•� ••_+ -4 CwLCVNnp, a i n mopµ . LONG BEACH. CA 90802 • (582) 570-6a94 FAX (582) 57O 088
COMMUNITY AND ENVIRONMENTAL PLANNING
November 7, 2000
Steve Smith, Ph.D.
Program Supervisor
South Coast Air Quality Management District
21865 East Copley Drive
Diamond Bar, CA 91765-4182
Subject: Notice of Preparation of a Draft Environmental Impact Report
Project Title: Proposed AES Alamitos, L.L.C. — Selective Catalytic Reduction (SCR)
Installation Project.
Dear Mr. Smith:
Thank you for the opportunity to review the Notice of Preparation
We concur that a cumulative health risk assessment and a risk management plan 3-1should be included in the Draft EIR.
Recently, the power plant was re-parcelized. If the project is located on a parcel which
is not required, the Draft EIR should indicate the precise project location relative to the�3-2
Coastal Zone.
Nearby land to the south and west is likely to be restored wetlands. The DEIR should
address impacts if any to the biological resources including avifauna as well a marine3-3
biology and water quality.
Finally, the DEIR should address compliance with the National Pollution Discharge 3-4
Elimination System,
Sincerel
Gerhardt (Gerry) H. gemaker
Environmental Planning Officer
1P
cc: Gene Zeller, Director of Planning and Building
Bob Berard, Zoning Officer, Planning and Building Department
_co Frank Colonna, Councilmember. 3rtl Dist^Ct, City Council
November 29, 2000
Steve Smith, Ph.D.
Program Supervisor
South Coast Air Quality Management District
21865 E. Copley Drive
Diamond Bar, CA 91765-4182
COMMENT LETTER #4
RECEIVED
scaonnD
PUINNING DIVISION
SUBJECT: CITY OF SEAL BEACH COMMENTS RE: "NOTICE OF
PREPARATION OF A DRAFT ENVIRONMENTAL
IMPACT REPORT — PROPOSED SELECTIVE CATALYTIC
REDUCTION (SCR) INSTALLATION PROJECT, AES LOS
ALAMITOS, LONG BEACH"
Dear Dr. Smith:
The City of Seal Beach has reviewed the above referenced Notice of Preparation
(NOP) 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 4-1
our community, in particular the Leisure World retirement community located east of the
subject property, on the easterly side of the San Gabriel River.
In reviewing the NOP, SCAQMD is proposing to evaluate the areas of "Air
Quality", "Hazards and Hazardous Materials", and "Mandatory Findings of Significance"
in the Draft EIR. In reviewing the discussion within the "Environmental Checklist and 4-2
Discussion" of the NOP, SCAQMD sets forth the reasons for those determinations. As
indicated below, it is the position of the City of Seal Beach that the area of "Noise" and
"Public Services" also need to be discussed in the Draft EIR, for the reasons set forth
below.
It is of extreme concern that the impacts of the proposed project are fully discussed,
evaluated, and mitigated in the above mentioned areas of concern, particularly in regards to
the community of Leisure World. It is the opinion of our Director of Development Services 4-3
that a substantial amount of discussion is necessary to allow full and complete evaluation of
potential impacts upon the residents of Seal Beach, which could have substantial adverse
impacts if not adequately described, evaluated, and mitigated.
Cody Datum ors CEQAl CR Proicn NOP, AES Los Alamiros.EQCa Leoendoc4.W\I 1-29-W
City of Seal Beach Environmental Quality Control Board Comment Letter
To South Coast Air Quality Management District re:
"Notice of Preparation - SCR Installation Project, AES Los Alamitos" {�
November29, 2000 l
Following are specific concerns of the City of Seal Beach that should be analyzed,
discussed, and appropriately mitigated in the Draft EIR:
Air Ouality:
The discussion on page 2-6 indicates that NO, emissions are anticipated to
be reduced approximately 90%. This overall air quality benefit is supported
and should be quantified and discussed thoroughly within the Draft EIR,4-4
including discussion regarding the possible health benefits of that reduction
in NO,.
It is indicated that the expected ammonia slip emission will be set at 10 ppm
over the whole load range. 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 4-5
of 65. It is 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.
It is indicated that the annual one-hour maximum ground concentration is
anticipated to be reduced to less than 1 ppm. Where is this level anticipated
to occur at, on the AES Los Alamitos facility or on adjoining properties? If 4-s
on adjoining or nearby properties, those should be indicated by the use of a
map.
It is indicated on page 2-6 that a cumulative health risk assessment
performed for the combined ammonia emissions from all four proposed Swas CR 4-7
units. In reviewing the reference documents for the NOP, it is not apparent
that the indicated "cumulative health risk assessment" document is available.
The "health risk assessment" document, along with the indicated "risk
management plan" on page 2-8, should be provided as technical appendices]
ppendices 4-8
to the Draft EIR document, permitting the interested public to review and
comment as to the adequacy of these documents. The specific health risk
assessment issues relating to an elderly, retirement community population of 4-9
8,300 persons, should be particularly discussed in this portion of the Draft
EIR.
Hazards and Hazardous Materials:
The discussion relates to general risk of upsetfhuman health impacts of
transportation of aqueous ammonia from various potential locations within
the District to the subject site.
SCR Ptuicn NOP. AES Los Alamims.EQCa Leser
City of Seal Beach Environmental Quality Control Board Comment Letter
To South Coast Air Qualite Management Distno re:
"Notice of Preparation - SCR Installation Project, AES Los Alamitos"
November 29, 2000
There should be discussion as to the statistical likelihood of a liquid
ammonia release, based on operating conditions of other similar facilities. In
addition, there should be an indication of the storage capacity of the diked 4-10
area, assuming a release were to occur, and a determination as to the length
of a release without overflowing the proposed low curb retention system.
As was indicated in the 1993 Subsequent EIR for the same 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 4-11
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 4-12
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 4-13
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 Subsequent EIR for this facility also indicated that the worst-case
population exposure to the 100 -ppm ammonia irritation level is 5,0204_14
resulting from a transportation spill and a complete containment failure,
based upon analysis prepared for the Redondo Station.
The DEIR should indicate the transportation routes that will be utilized to 4-15
transport the aqueous ammonia from anticipated suppliers to the AES Los
Alamitos Generating Station. The 1993 DSEIR 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/Studebaker 4-1f)
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 4-17
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� 4-18
this exposed population is located in Seal Beach, and most probably within
SCR Project NOP, AES Los Alamiws.EQCB Leacr
City of Seal Beach Environmental Quality Control Board Comment Letter
To South Coast Air Qualim Management District re:
"Notice of Preparation - SCR Installation Project, AES Los Alamitos"
November29, 2700
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 4-19
City of Long Beach and the City of Seal Beach to be more fully informed as
to potential impacts upon their respective residents. Discussion should aTso
be provided as to the types of anticipated human health problems to be 420
anticipated assuming exposure of a large elderly population. Please refer to
the discussion regarding Leisure World above.
Noise:
The NOP indicates that noise issues will not be discussed within the Draft
EIR. The City of Seal Beach is concerned that the public has no opportunity
to review and comment as to the ability of the measures indicated on page 2-
24 of the NOP (existing noise reduction measures within the generating
station, proposed noise reduction measures) to reduce any additional noise
generating sources to a less than significant level. The Draft EIR should 4-21
include a noise impact section, and in particular discuss 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.
Public Services:
As discussed in "Noise" above, the City is concerned that the public has no
opportunity to review and comment as to the ability of emergency service
providers to adequately respond to an emergency situation at the revised
facility. Again, the City of Seal Beach requests the Draft EIR to provide
discussion and specific information as to the nearest responding emergency
service unit locations (map exhibit), and 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 4-22
large amount of emergency calls from impacted persons. It should be
indicated that Orange County Fire Authority units, located in Seal Beach,
and the Seal Beach Police Department may also be impacted by additional
emergency response training, assuming that mutual aid agreements are
required to be effectuated. Costs of additional emergency response training
should be the responsibility of the project proponent.
The Environmental Quality Control Board (EQCB) considered and discussed the
NOP document on November 29, 2000. The EQCB authorized the Chairman to sign this
letter indicating the official comments of the City of Seal Beach.
Upon the preparation of the Draft EIR for this project, please send 4 copies 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
SCR Proimt NOP, AES Los Alaa iu, .EQCB Le.,
I r
City of Seal Beach Environmental Quality Control Board Comment Letter
TO South Coast Air Quality Managemem District re. -
"Notice of Preparation - SCR Installation Project, AES Los Alamitos"
November29, 2000
Beach. If you have questions concerning this matter, please do not hesitate to contact Mr.
Whinea�{s6?Z431-2527, extension 313.
)h E. Porter, III
rman, Environmental Quality Control Board
of Seal Beach
Seal Beach City Council
Acting City Manager
Police Chief
Golden Rain Foundation
Orange County Fire Authority
SCR Pmjea NOP, AES Las Alami,w.EQCB Utt.,
Seal Beach Planning Commission
Director of Development Services
City of Long Beach
COMMENT LETTER #5
STATE OF CAL OWA—BUSINESS AND TRANSPORTATION AGENCY GRAY DAVIS, G.va.,
DEPARTMENT OF TRANSPORTATION
DISTRICT7, ADVANCE PLANNING
IGR OFFICE 1-I0C
120 SO. SPRING ST.
LOS ANGELES, CA 90012
TEL: (213) 897-0486 ATSS: 8.647-0486
FAX: (213) 897-8906
E-mai1::NonPinjm CAGOI"n DOT
November 30, 2000
MR. STEVE SMITH
South Coast Air Quality Management District
21865 East Copley Drive
Diamond Bar, CA 91765
Re: IGR/CEQA #001129/NP
NOP, AES Alamitos, L.L.C. Selective
Catalytic Reduction
City of Long Beach
Vic. LA-001-1.97/SCH No. 2000111039
Dear Mr. Smith
Caltrans acknowledges receipt of the above-named document. The proposed project involves
installation of three (3) above ground, 20,000 gallon aqueous ammonia storage tanks and 5-1
installation of selective catalytic reduction control equipment on units, 1,2,3, & 4.
We have no comment, except to recommend, truck trips, especially heavily laden trucktraffic, be 5-2
limited to off-peak commute hours.
Thank you for including Caltrans in the environmental review of the project. If you have any
questions, please feel free to contact the undersigned at 213-897-4429 and refer to our
IGR/CEQA #001129/NP.
Sincerely,
STEPHEN J.BUSWELL
Program Manager
IGR/CEQA
cc: Scott Morgan
State Clearinghouse
Winston H. Hickox
1,gency Secretary
:alifomia Environmental
Protection Agency
Department of Toxic Substances Control
December 6, 2000
Edwin F. Lowry, Director
1011 N. Grandview Avenue
Glendale, California 91201
COMMENT LETTER #6
Mr. Steve Smith
South Coast Air Quality Management District
21865 East Copley Drive
Diamond Bar, California 91765
Gray Davis
Governor
NOTICE OF PREPARATION of AN ENVIRONMENTAL IMPACT REPORT FOR THE
AES ALAMITOS, L.L.C-SELECTIVE CATALYTIC REDUCTION (PROJECT),
SCH 2000111039
Dear Mr. Smith
The Department of Toxic Substances Control (DTSC) has received your Notice of
Preparation (NOP) of a draft Environmental Impact Report (EIR) for the above
mentioned Project.
Based on the review of the document, the DTSC comments are as follows:
1) The draft EIR needs to identify and determine whether current or historic uses at the I6-1
Project site have resulted in any release of hazardous wastes/substances at the Project)
area.
2) The draft EIR needs to identify any known or potentially contaminated site within the
proposed Project area. For all identified sites, the draft EIR needs to evaluate whether 6-2
conditions at the site pose a threat to human health or the environment.
3) The draft EIR should identify the mechanism to initiate any required investigation —1 6-3
and/or remediation for any site that may require remediation, and which government
agency will provide appropriate regulatory oversight.
4) If during construction of the project, soil contamination is suspected, construction in
the area should stop and appropriate Health and Safety procedures should be
implemented. If it is determined that contaminated soil exists, the draft EIR should 6-4
identify how any required investigation and/or remediation will be conducted, and which
government agency will provide appropriate regulatory oversight.
0 Printed on Recycled Paper
Mr. Steve Smith
December 6, 2000
Page 2
DTSC provides guidance for Preliminary Endangerment Assessment (PEA)
preparation and cleanup oversight through the Voluntary Cleanup Program (VCP). For 6-5
additional information on the VCP or to meet/discuss this matter further, please contact
Bob Krug, Project Manager, at (818) 551-2866 or me at (818) 551-2877.
Sincerely,
Harlan R. Jeche
Unit Chief
Southern California Cleanup Operations - Glendale Office
cc: Governors Office of Planning and Research
State Clearinghouse
P.O. Box 3044
Sacramento, California 95812-3044
Mr. Guenther W. Moskat, Chief
Planning and Environmental Analysis Section
CEOA Tracking Center
Department of Toxic Substances Control
P.O. Box 806
Sacramento, California 95812-0806
1�,
CObWENT LETTER #7
�g�r�AyE4HNIA Grav ❑ours. Govvemu[
NATIVE AMERICAN HERITAGE COMMISSION
915 CAPITOL MALL, ROOM 364 -
SAC RAMENTO,CA95914
1919165&6092
(916)65] -5390 -Fax y'- RECEI V GD
November 16, 2000 Nov 2 200�
Steve Smith SCAOMD
South Coast Air Quality Management District PLANNING DIVISION
21865 E. Copley Dnve
Diamond Bar, CA 91765
RE: SCH# 2000111039, AES Alamitos, -.1-C.-Selective Catalytic Reduction
Dear Mr. Smith:
The Native American Heritage Commission has reviewed the above mentioned NOP. To adequately asses
the project -related impact on archaeological resources, the Commission reccomends the following action be
required:
1. Contact the appropriate Information Center for a records search. The record search will determine:
• Whether a part or all of the project area has been previously surveyed for cultural resources.
• Whether any known cultural resources have already been recorded on or adjacent to the project area.
• Whether the probability is low, moderate, or high that cultural resources are located within the project7-1
area.
• Whether a survey is required to determine whether previously unrecorded cultural resources are present.
2. If a archaeological inventory survey is required, the final stage of the is the preparation of a professional
report detailing the findings and recommendations of the records search and field survey.
• Required the report containing site significance and mitigation be submitted immediately to the planning
7_2
department.
• Required site forms and final written report be submitted within 3 months after work has been
completed to the Information Center.
3. Contact the Native American Heritage Commission for:
• A Sacred Lands File Check.
7-3
• A list of appropriate Native American Contacts for consultation concerning the project site and assistin
the mitigation measures.
Lac.: c` -tr°ace evidence of archeological resources does not predude the FSlctenc" a: ^•ah�abyica!
resources. Lead agencies should include provisions for accidentally discovered archeological resources during
construction per California Environmental Quality Act (CEQA) §15064.5 (f). Health and Safety Code §7050.5 and
7-4
Public Resources Code §5097.98 mandates the process to be followed in the event of an accidental discovery of
any human remains in a location other than a dedicated cemetery and should be included in all environmental
documents. If you have any questions, please contact me at (916) 653-4040.
1
CC: State Clearinghouse
Sincerely,
Rob Wood
Associate Governmental Program Analyst
SOUTHERN CALIFORNIA
ASSOCIATION of
GOVERNMENTS
Main Office
BIIl West Seventh Street
uth Floor
Los Angeles, California
9oou-3435
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November 16, 2000
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COMMENT LETTER #8
Mr. Steve Smith, Ph.D.
South Coast Air Quality Management District
21865 E. Copley Drive
Diamond Bar, CA 91765
RE: SCAG Clearinghouse 120000551 Proposed AES Alamitos, L.L.C—
Selective Catalytic Reduction (SCR) Installation at Alamitos Generating
Station
Dear Mr. Smith
We have reviewed the above referenced document and determined that it is
not regionally significant per Areawide Clearinghouse criteria. Therefore, the
project does not warrant clearinghouse comments at this time. Should there
be a change in the scope of the project, we would appreciate the opportunity to
review and comment at that time.
A description of the project was published in the November 15, 2000 8-1
Intergovernmental Review Report for public review and comment.
The project title and SCAG Clearinghouse number should be used in all
correspondence with SCAG conceming this project. Correspondence should
be sem to the attention of the Clearinghouse Coordinator. If you have any
questions, please contact me at (213) 236-1867.
Sincerely,
1''IEFF VM. SMITH, AICP
Senior Planner
Intergovernmental Review
AES ALAMITOS SCR PROJECT
NOP/IS RESPONSE TO COMMENTS
Comment Letter #1
CALIFORNIA DIVISION OF MINES AND GEOLOGY
1-1 The Los Alamitos 7V2 -minute Quadrangle map was submitted to the SCAQMD
without an accompanying cover letter. As a result, Steve Smith, Program
Supervisor of the SCAQMD's CEQA section, contacted Mr. Robert Sydnor
(whose business card was attached to the map), California Division of Mines
and Geology, on December 14, 2000, to obtain additional information relative
to the map. Mr. Sydnor requested that the Draft EIR indicate that the project
site is located in the "Official Liquefaction Zone" as shown on the attached
Seismic Hazard Zones Map (dated March 25, 1999).
The SCAQMD agrees with Mr. Sydnor that, as shown on the attached Seismic
Hazard Zones Map, the facility generally is located within a liquefaction zone.
However, based on existing data, the liquefaction potential at the actual project
site is low to moderate. The project design for the aqueous ammonia tanks
takes into account and addresses this potential risk. Specifically, the ammonia
tanks are founded on cast -in -drilled hole piles and mat foundations underlain
by engineered fill. The proposed project has been designed sufficiently to
withstand the potential for liquefaction. Therefore, the potential for
liquefaction -related impacts is less than significant.
Comment Letter #2
CITY OF ANAHEIM
2-1 The City of Anaheim indicated that it has no information or comments to
provide on the NOP/IS. Further, the City requests future notices and
documents related to the proposed project, which the SCAQMD will provide.
Comment Letter #3
CITY OF LONG BEACH
3-1 Page 2-8 of the NOP/LS incorrectly stated that a risk management plan (RMP)
would be provided as part of the Draft EIR. That reference was supposed to
refer to a health risk assessment. The health risk assessment is incorporated
into the Air Quality discussion (Chapter 4) of the Draft EIR.
The existing facility RMP will be updated and approved prior to ammonia
delivery for the new SCR units. The City of Long Beach Department of Health
and Human Services is the lead agency for implementation of the California
Accidental Release Program (Ca1ARP) RMP requirements. The existing
facility RMP is publicly available and the revised RMP would be open for
public comment prior to approval.
AES Alamitos SCR
January 2001
r
AES ALAMITOS SCR PROJECT
NOP/IS RESPONSE TO COMMENTS
3-2 Although the proposed project site has been re-parcelized, this action did rot
alter the existing Coastal Zone boundary. Based on California Coastal
Commission's Memorandum regarding Boundary Determination No. 36-2000
(June 14, 2000), it is clear that the proposed project is located to the north and
outside of the Coastal Zone. Therefore, no further action by the California
Coastal Commission is necessary.
3-3 As discussed in the NOP/IS, the proposed project will not adversely affect either
biology or water quality. As indicated in the NOP/IS (see also Chapter 4 of this
Draft EIR for more information) the proposed project will be carried out solely
within the confines of the existing facility so there is very little likelihood that any
impacts to nearby land, including the area proposed as a future restored wetlands
area, will occur. With regard to water resources impacts, except for water used
temporarily as a dust suppressant (a standard construction practice), the proposed
project does not increase demand for additional potable water or generate
substantial amounts of additional waste water. See also response 3-4 and Chapter
4 of the EIR for more information on this topic. Instead, this project will provide
a beneficial impact to biological resources via the 90 percent reduction of N%
from Units I though 4 at the facility.
3-4 As discussed in the NOPAS (Section IX, Hydrology and Water Quality), the
proposed SCR system is highly efficient and will not result in the generation of
wastewater. Also, any accidental spills or discharges of ammonia into a storm
drain that potentially could occur onsite have been addressed as par of the
actual project design.
Specifically, as par of the proposed project, AES will install ammonia vapor
detectors with audible and visual (light) notification in the vicinity of the SCR
systems and the storage tanks. Any leak onsite will be detected quickly and
signaled to the plant operators in the control room. In response to an ammonia
vapor alarm, the operators will shut down the ammonia feed supply to prevent
excessive ammonia from being spilled. Also, the aqueous ammonia storage
tanks will be double walled and bermed.
Further, AES Alamitos Generating Station's Hazardous Materials Release
Contingency Plan will be updated to reflect the proposed additional storage of
aqueous ammonia at the facility. The purpose of the plan is to specify how
station personnel would respond to any unplanned release of hazardous
materials in to the air, soil or surface water. This response includes notifying
the proper authorities of the release, controlling and cleaning up the release and
restoring the environment as required. The plan identifies sources of
hazardous material, responsibilities of employees during a response, a step-by-
step plan of how to respond to a release, who to contact, how to contain and
remove hazardous material released, restoration of the environment, and
creation of an operating record of the incident. The plan also includes maps of
the locations of all hazardous materials at the facility.
AFS Alamitos SCR 2 January 2001
AES ALAMITOS SCR PROJECT
NOPAS RESPONSE TO COMMENTS
In light of all the above safety precautions, no changes to the facility's existing
National Pollution Discharge Elimination System permits are necessary.
Comment Letter #4
CITY OF SEAL BEACH
4-1 Specific responses to each issue raised by the City of Seal Beach are provided
below. It should be noted that the proposed project is less than I mile from
Seal Beach and Leisure World.
4-2 Comment noted. Please refer to responses 4-21 and 4-22 for detailed responses
to the issues of "Noise" and "Public Services".
4-3 SCAQMD agrees that for those areas of the environment that may be
significantly impacted by the proposed project a full discussion, evaluation
and, if appropriate, mitigation of such impacts must be included as part of the
Draft EIR and subject to public review and comment. As discussed in the
NOPAS, areas of potential impacts created by this project include "Air
Quality" and "Hazards and Hazardous Materials." The Draft EIR contains a
detailed environmental evaluation of these potential impacts, along with a
compilation of appropriate mitigation measures.
44 Nitrogen dioxide (NO2) is the main component of NO, emissions and, in tum,
is the principal constituent responsible for NO, related health effects. NO2
also contributes to ozone and PMto formation. A reduction in emission levels
from Units 1 through 4 at the Alamitos Generating Station will result in lower
NO, and NO2 levels in the atmosphere, resulting in improved air quality and
significant health benefits, as discussed below.
Nitrogen dioxide can irritate lungs and lower resistance to respiratory
infections such as influenza. Continued or frequent exposure to nitrogen
dioxide to concentrations that are typically much higher than those normally
found in the ambient air may cause increased incidence of acute respiratory
illness in children. Nitrogen oxides are important contributors to ozone
formation and may affect both land-based and water-based ecosystems.
Nitrogen oxides in the air are a potentially significant contributor to a number
of other environmental effects as well, such as acid rain and nutrient
enrichment in coastal waters. In addition, nitrogen oxide emissions can form
aerosols in the atmosphere that significantly reduce visibility. Therefore, by
substantially reducing NO, emissions from Units 1 through 4 at the Alamitos
Generating Station, there will be significant health benefits and environmental
benefits, especially in the long term. For additional information on health
effects of criteria pollutants, please refer to Chapter 3 of the Draft EIR.
AES Alamitos SCR 3 January 2001
AES ALAMITOS SCR PROJECT
NOP/IS RESPONSE TO COMMENTS
The post SCR reduction of NOx emissions for each unit (Units 1 through 4) is
approximately 92 percent, compared to historical NO, emissions. The
reduction from each unit and the total reduction can be quantified as follows:
Unit
Number
Historical Annual PTE NOx
Emissions (tons per ear)
Post SCR Emissions
(tons per ear)
Unit 1
1513
51
Unit 2
1641
51
Unit 3
1489
188
Unit 4
1489
188
TOTAL
6132
478
Note: PTE — Potential to Emit — this is the maximum level of NO. emissions for each baiter, based on
historical continuous monitoring dam from each plant.
Please refer to Sections 1.1 and 4.2.3.1 of the Draft EIR for a complete
discussion of NO, emissions reduction associated with this project
4-5 A screening health risk assessment (HRA) was performed to estimate the
potential impacts associated with cumulative airborne emissions of ammonia
due to the proposed project. The HRA utilized a U.S. Environmental
Protection Agency (US EPA) accepted model that predicts the maximum
ground level concentration of ammonia resulting from operation of the SCR
systems on Units 1 through 4. The inputs used in the model were very
conservative, in order to predict a "worst case' scenario. Since ammonia is not
considered a carcinogen, an inhalation human HRA was performed.
In order to quantitatively assess the health effects of ammonia, the output from
the model, i.e., the maximum ground level ammonia concentrations, were
divided by the reference exposure level for ammonia (developed by the
California EPA and the Office of Environmental Health Hazard Assessment
(OEHHA)). This gave a chronic hazard index and an acute hazard index. A
hazard index of one or greater indicates that health risk exists; a hazard index
of less than one indicates that a health risk does not exist. The hazard indices
for the proposed project were a factor of one hundred less than one (0.0061 and
0.0098 for acute and chronic health effects, respectively).
It is important to note that the potential health risks to sensitive populations
have been taken into account in the HRA. The HRA utilizes reference
exposure levels developed by the OEHHA that are designed with a "safety
factor" to account for exposure to sensitive populations. By using these
reference exposure levels in the HRA, the risk to sensitive populations has
been taken into account. Moreover, the fact that the hazard indices were so far
below the risk level of 1.0 means that there will be no risk to even a sensitive
population.
AES Alamitos SCR 4 January 2001
4
AES ALAMITOS SCR PROJECT
NOP/IS RESPONSE TO COMMENTS
Reference exposure levels (RELs) are based on the most sensitive, relevant,
adverse health effect reported in the medical and toxicological literature. RELs
are designed to protect the individuals who live and work in the vicinity
emissions, as well as the most sensitive individuals in the population, through
the inclusion of margins of safety. They are intended to protect both
individuals at low risk for chemical injury as well as identifiable sensitive
subpopulations (highly susceptible or sensitive individuals such as the elderly,
the very young, pregnant women, and those with chronic or acute illnesses)
from adverse health effects in the event of exposure. Please refer to Chapter 4
of the Draft EIR for a complete discussion of ammonia slip associated with this
project.
4-6 The maximum ground level concentration is predicted to occur at a distance of
6,300 meters (20,700 feet) from the stacks at the Alamitos Facility. The
Leisure World community is located approximately 800 meters (2,600 feet) to
the east of the Alamitos Facility. Therefore the maximum predicted
concentration would not affect the Leisure World community.
To explain further, when a `puff' of gas is released from a stack, it travels high
into the air and is then dispersed and diluted by the air into which it is released.
The puff, or plume of gas, then travels at height for a distance (in this case
some 6,000 meters) before it is deposited at ground level. During the time the
plume is airborne, it is significantly diluted and dispersed, so that the
concentration of the gas deposited at ground level is orders of magnitude lower
than the concentration released. The concentration of ammonia gas released in
the plume from the stacks at the Alamitos Facility is very low, and will travel
some 6,000 meters before reaching ground level, where the concentration will
be far below levels at which human health effects occur.
4-7 The sentence referred to in the NOPAS is incorrect. - At the time the NOP/IS
was circulated for public review, the cumulative health risk assessment was
being prepared to be included in the Draft EBR, not in the NOPAS as implied.
A cumulative health risk assessment is provided in Chapter 4, "Air Quality'
section, of the Draft EBR.
4-8 Page 2-8 of the NOPAS incorrectly stated that a risk management plan (RMP)
would be provided as part of the Draft EIR. That reference was supposed to
refer to a health risk assessment. The health risk assessment is incorporated
into the Air Quality discussion (Chapter 4) of the Draft EIR. See also response
to comment 4-7.
The existing facility RMP will be updated and approved prior to ammonia
delivery for the new SCR units. The City of Long Beach Department of Health
and Human Services is the lead agency for implementation of the California
Accidental Release Program (CalARP) RMP requirements. The existing
facility RMP is publicly available and the revised RMP would be open for
public comment prior to approval.
AES Alamitos SCR 5
AES ALAMITOS SCR PROJECT
NOPAS RESPONSE TO COMMENTS
4-9 Please refer to the response to comment 4-5.
4-10 Please refer to Chapter 4, "Hazards" section, for a detailed "worst-case"
analysis of the probability and consequences of an accidental release of
ammonia, both at the facility and during transport by truck to the facility.
4-11 Please refer to Chapter 4, "Hazards" section, for a detailed analysis of the
probability of an accidental ammonia release and the consequences of such a
release under two scenarios. Please note that the SCAQMD has modified its
ammonia exposure significance threshold from 100 -ppm to 200 -ppm to be
consistent with the Emergency Response Planning Guideline Level 2 (ERPG-
2), which is used in Risk Management Plans under the California Accidental
Release Prevention (CalARP) Program and the U.S. EPA Risk Management
Program requirements.
4-12 Please refer to the responses to comments 4-10 and 4-11. Also, Figure 4-1 of
the Draft EM provides a map of the area that potentially would be impacted in
the event of a complete loss of containment of ammonia based on dispersion
modeling using the current 200 -ppm ammonia exposure threshold level.
Please note that the modeling was done for Units 1 and 2, versus Units 3 and 4,
because these units would have the greatest potential to impact sensitive
receptors and are closest to the generating station property boundary.
4-13 As indicated in Chapter 4 of the Draft EIR the City of Long Beach provides
fire and emergency services within its boundaries as a municipal service. Fire
and emergency services are coordinated by the Long Beach Fire Department
(Fire Department). The Fire Department has 24 stations within the city limits,
with the closest one located at 6340 Atherton Street, which is within one mile
of the Alamitos Generating Station. Response time for an emergency at the
facility therefore is anticipated to be very short.
The Fire Department is well equipped and trained for responding to and
dealing with fires, paramedic rescues, and certain limited types of hazardous
materials incidents. The Fire Department has been trained for aqueous
ammonia incidents at the Alamitos Generating Station since 1993, when SCRs
using aqueous ammonia were installed on Units 5 and 6. In the event that an
incident exceeds the scope of the Fire Department's capabilities, Long Beach
typically contacts the Los Angeles County Hazardous Materials unit for
emergency assistance. Backup is also provided by surrounding municipalities
on the basis of reciprocal agreements.
The Fire Department also serves as the conduit for information transfer from
one emergency response unit to others (e.g., fire, police, California Highway
Patrol (CHP), private emergency service or equipment providers, etc.), both
prior to and after an accidental release. Emergency response plans and
evacuation routes are coordinated by the Fire Department, with development
and review of such plans and routes supported by all of the public services
AES Alamitos SCR 6 January 2001
+ v s
AES ALAMITOS SCR PROJECT
NOP/IS RESPONSE TO COMMENTS
involved. AES currently is working closely with the Fire Department
regarding the update to the facility risk management plan and details of the
proposed project.
The Long Beach Police Department (Police Department) is responsible for
perimeter and entry control at the scene of a hazardous materials accident. The
Police Department also shares responsibility with the Fire Department for
security within the perimeter. In the event of a major hazardous materials
incident (or any other major emergency), it is primarily the responsibility of the
Police Department to implement evacuation procedures, should they be
necessary.
The Police Department has a designated person that works closely with the
Fire Department, especially on hazardous materials incidents. Backup support,
if it should prove necessary, would be supplied by the police departments of
surrounding municipalities and the Los Angeles County Sheriffs Department.
As concluded in the NOPAS, a worst-case scenario event (one storage tank or
tanker truck leaking all aqueous ammonia at one time) would require the same
level of emergency response as the current spill response plan created during
the installation of SCR on Units 5 and 6 (SCAQMD, 19936). Therefore, the
proposed project would not result in significant impacts to police and fire
services.
A large amount of emergency calls are not anticipated for the proposed project
because, based on the analysis in Chapter 4, the probability of an accidental
release is extremely low, i.e., a catastrophic tank failure rate has been estimated
at approximately one per 2,500 years.
4-14 As indicated in previous responses, a detailed risk analysis for the proposed
project has been prepared and is included in Chapter 4 of the Draft EBR.
4-15 A description of the aqueous ammonia transport route is included in Chapter 4,
"Hazards" section, of the Draft EBR.
4-16 A description of the aqueous ammonia transport route is included in Chapter 4,
"Hazards" section, of the Draft EBR. As noted in Chapter 4, the anticipated
ammonia transport route does not include using Pacific Coast Highway,
Westminster Avenue, or Seal Beach Boulevard.
4-17 AES will contact emergency response agencies, including those of the
Department of Transportation (Caltrans) and the City of Long Beach Fire
Department, in accordance with applicable federal, state and local regulations.
4-18 Truck transport will not occur on local city streets within Seal Beach. Less
than one mile of the existing and proposed 63 -mile transport route occurs on
Interstate highways that pass through the City of Seal Beach. The probability
of a truck accident to the Alamitos Generating Station is one per 200 years. A
AESA/amitor SCR 7 January 2001
• N �
AES ALAMITOS SCR PROJECT
NOPIIS RESPONSE TO COMMENTS
detailed description of the aqueous ammonia transport route and potential
associated risks are included in Chapter 4, "Hazards" section, of the Draft EIR.
4-19 Please refer to the response to comment 4-12 above.
4-20 Please refer to response to comment 4-5, and to Chapter 4, "Air Quality"
section, of the Draft EBR. As indicated in Chapter 4, exposure to ammonia can
cause eye and skin irritation, as well as respiratory difficulties.
4-21 It should be noted that the NOPAS is a public document that provides the
public an opportunity to review and comment on potential impacts of the
proposed project, including possible noise impacts.
As stated in the NOP/IS 'Noise" discussion, AES is committed to using
electric tools and welding machines (approximately 70-75 decibels) versus air
or diesel tools (90-100 decibels) during installation of the SCR on Units 1
through 4. Temporary construction noise impacts will not exceed the 75
decibel significance threshold established by the City of Long Beach. The
SCRs will be installed on existing equipment at an existing facility.
Consequently, with the noise reduction features of the project ambient noise
levels are expected to be unaffected by the project.
Similarly, the proposed design of this project incorporates the use of sound
enclosures for the SCR equipment. Moreover, the SCR equipment for Units 1
and 2, which are closest to sensitive receptors and the generating station
property line will be housed within a building, thus further suppressing noise
levels. Beyond this, the project design incorporates noise control methods,
such as external insulation for hot gas dilution blowers (four 11-hp/3,600 rpm).
Thus, as noted in the NOP/LS, SCAQMD concludes. that the potential noise
impacts related to SCR operation will be less than significant.
4-22 Please refer to the response to comment 4-13. Further, it should be noted that
costs are not a topic required for analysis under CEQA unless they result in
indirect physical impacts. No such physical impacts were identified for the
proposed project.
Comment Letter #5
STATE OF CALIFORNIA- BUSINESS AND TRANSPORTATION AGENCY,
DEPARTMENT OF TRANSPORTATION
5-1 This comment is a statement of the description of the proposed project. No
response is necessary.
5-2 The Draft EBR states that transfer of aqueous ammonia would not occur during
school hours or between 6 a.m. to 9 a.m. and 4 p.m. to 6 p.m. Please refer to
AES Alamitos SCR S January 2001
AES ALAMITOS SCR PROJECT
NOPRS RESPONSE TO COMMENTS
Section 4.3.1.4 of the Draft EIR for information regarding aqueous ammonia
truck transport.
Comment Letter #6
DEPARTMENT OF TOXIC SUBSTANCES CONTROL
6-1 The major components of the proposed project include installation of:
• Selective Catalytic Reduction (SCR) reactor units
• Control equipment
• Aqueous ammonia storage tanks.
The SCR reactor units would be incorporated in to the existing boiler footprint.
The control equipment would be installed within the existing plant distribution
control system. The three aqueous ammonia storage tanks and berms (595.5
square feet each) would be located on an impermeable surface. The ranks
would be located immediately west of Units 1 through 4.
CH2M HILL prepared a Phase II Environmental Site Investigation of the
Alamitos Generating Station for Souther California Edison Company, the
former owner, in 1997. The Phase II investigation was performed in
accordance with the Sampling and Analysis Plan and Quality Assurance
Project Plan, Phase 11 Environmental Site Assessments, SCE Generating
Stations, dated October 18, 1996, prepared by Hydro -Search, Inc., CH2M
HILL, and Geraghty & Miller, Inc.
The Phase II investigation included the area around Units 1, 2, 3 and 4 (Power
Block). More specifically, the Phase II investigation performed soil and
groundwater sampling in the area around Units I and 2 and soil sampling around
Units 3 and 4. Groundwater sampling was infeasible around Units 3 and 4, and
due to saltwater intrusion, was not considered necessary. The samples collected
were analyzed for total petroleum hydrocarbons (TPH), volatile organic
compounds (VOCs), and California Assessment Manual (CAM) metals.
No TPH and VOCs were detected at levels above the screening criteria set
forth in the CAM. Similarly, with the possible exception of arsenic, no heavy
metals were detected above the applicable screening criteria. Given the
historical use of the facility as a generating station, the presence of arsenic in
soil is most likely attributable to naturally occurring background soil
concentrations. Finally, there is no evidence that groundwater has been
impacted by TPH-diesel (D). Groundwater beneath the Alamitos Generating
Station has been impacted by saltwater intrusion and is not considered to have
a beneficial use. Based on this investigation it was concluded that little, if any
hazardous wastes/substances were released historically at the site, and it was
determined that no further investigation was necessary.
AES Alamitos SCR
January 2001
AES ALAMITOS SCR PROJECT
NOP/IS RESPONSE TO COMMENTS
Finally, it should be noted that the proposed project will not result in a -.y
significant disturbance of soils. Therefore, human health and the environment
will not be threatened by the proposed installation of surface features (i.e.,
ammonia tank pads) at the project site.
6-2 Please refer to the response to comment 6-1.
6-3 As discussed in response to comment 6-1, no investigation or remediation is
anticipated to be required as part of this project. However, if such
investigation and remediation were required, then the government agency to
provide oversight would either be the Regional Water Quality Control Board or
the Los Angeles County Department of Public Works, Environmental
Programs Division. In any event, the appropriate oversight agency would be
contacted if remediation becomes necessary.
64 As already noted in response to comment 6-1, a site investigation already has
been conducted and no contaminated soil was encountered. If contaminated
soil were found during construction of the proposed project, the site would be
further investigated and, if necessary, the contaminated soil would most likely
be removed and disposed of in an appropriate landfill. The government agency
to provide oversight would either be the Regional Water Quality Control Board
or the Los Angeles County Department of Public Works, Environmental
Programs Division depending on the location, source and/or extent of
contamination. See also response to comment 6-3.
6-5 As noted in response to comment 6-1, neither a PEA nor a VCP is anticipated
to be necessary.
Comment Letter 87
NATIVE AMERICAN HERITAGE COMMISSION
7-1 Rob Wood (Native American Heritage Commission) was contacted on
December 8, 2001 by 7eremy Rowland (consultant). Mr. Wood concluded that
because of the lack of ground disturbance a record search was not necessary for
the proposed project.
7-2 Please refer to response to comment 7-1.
7-3 Please refer to response to comment 7-1.
74 The project does not involve excavation, nonetheless, if the existence of
archeological resources is found during work on the proposed project, then all
applicable laws and procedures concerning such resources will be followed.
AES Alamitos SCR 10 January 2001
AES ALAMITOS SCR PROJECT
NOP/IS RESPONSE TO COMMENTS
Comment Letter N8
SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
8-I This comment indicates that SCAG has determined that the proposed project is
not regionally significant. The SCAQMD agrees with this conclusion.
ACJ AWM,10S JCR I1 January 2001