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HomeMy WebLinkAboutCC AG PKT 2002-06-10 Supplemental - Memoes re: DWP Property to Bay City Partners, LLC1 +fit 5[Af gEj� i f n `�. Memorandum To: Mayor Larson and Members of the City Council DWP Specific Plan Advisory Committee Planning Commission Environmental Quality Control Board Attention: John B. Bahorski, City Manager Q From: Lee Whittenberg, Director of Development Services7f7 0 Date: June 12, 2002 (/ //� SUBJECT: SALE OF DWP PROPERTY TO BAY CITY PARTNERS, LLC - DWP BOARD ACTION ON JUNE 18, 2002 The Board of Water and Power Commissioners will meet on June 18 to adopt a resolution approving the sale of the DWP property in Seal Beach to Bay City Partners, LLC for $4,501,000. Upon adoption of the resolution, the proposed sale must also be approved by the City Council of the City of Los Angeles. There is no time limit for the City Council to consider this matter. The Board Resolution is available for downloading on the Department of Water and Power website at: www. ladwp .convboard/061802/item21.pdf A copy is also available at the Department of Development Services for review. At this time, the City has had no contact by the purchaser of the property as to their intentions regarding the site. C.Wy Docwren%OWPTrpeny Ue Me .dwe W,0 JM2 IP �E SEA(` "gF Memorandum To' Mayor Larson and Members of the City Council Planning Commission Environmental Quality Control Board Attention: Jobn B. Bahorsld, City Manager ` , /` From: Lee Whittenberg, Director of Development Services; -�(//// Date: June 10, 2002 SUBJECT: DWP RESPONSES TO CITY OF SEAL BEACH COMMENT LETTER RE: HAYNES GENERATING STATION REPOWERING PROJECT DEIR The City has received a copy of the "Final Environmental Impact Report — Haynes Generating Station Repowering Project, Long Beach" prepared by the Department of Water and Power. The Final EIR includes revisions to the mitigation measures based on comments received on comments regarding Draft EIR, and the responses to all comments received. Comments were received by DWP from the following: • City of Seal Beach • California Department of Toxic Substances Control • California Coastal Commission • William Hurley, Seal Beach resident (Leisure World) • Mr. & Mrs. N. Brady, Seal Beach resident (Leisure World) • City of Long Beach • California Energy Commission The cover letter from DWP indicates that certification of the Final EIR and consideration of the proposed project is tentatively scheduled for Board consideration on June 18, 2002 at 1:30 PM, at the Los Angeles Department of Water and Power, Room 1555H — 15' Floor, I11 North Hope Street, Los Angeles. A preliminary review of the "Responses to Comments" indicates that DWP responded in a positive manner to several of the concerns of the City, particularly regarding: f WyDo mmMrEOAnWP Repw.ering Praje DEIRCC Me 2.dDc/LW/05-1"2 City Council Menor'andum re: Haines Generating Station Repowering Avject DEIR - Receipt ofDWPResponses to Ciry ofSeal Beach Corrvnent Lette+' June 10, 2002 Cultural Resources monitoring Noise mitigation programs regarding the ability of the Golden Rain Foundation to meet with DWP and to provide comments and suggestions regarding a "construction noise control program ", including • limitations on the types of construction activities occurring outside of standard construction hours ( "off - hours') • notification to Leisure World and Island Village when `off hours" construction activities will occur • limitation as to hours when pile driving and heavy construction equipment activities can occur near the property line adjacent to Leisure World— 8 AM to 6 PM, Monday through Friday, and 9 AM to 6 PM on Saturday • control program shall include "physical mitigation measures to the extent they are necessary, feasible, and effective, to reduce the impacts of noise caused by construction activity". These measures may include: • Noise barriers located adjacent to construction activity • Noise barriers located the Haynes property line, and/or • Noise reduction measures involving windows in affected residential units in Leisure World. At this fine, there is no specific commitment from DWP to provide upgraded window assemblies within identified living units impacted by construction noise within Leisure World. It is the intent of staff to attend the DWP Board meeting and press this issue further. A copy of the transmittal letter from DWP, the City comment letter of April 8, 2002 and the DWP Responses to Comments, dated May 2002 are provided for your information. The Final EIR is available at the Department of Development Services for review. Attachment: Response to Comments Received on the Draft Environmental Impact Report (EIR) for the Haynes Generating Station Repowering Project, City of Los Angeles Department of Water and Power, dated June 6, 2002 DWP Repo.9Pmj. DEROC Memo 2 G)��p�al�trumc =�ui1 oit ��'atc�t carnal I "n)��et� ]AMPS K. HAHN Commission w KENNETH T. JAMHARD, r...u.m DOMMCK W. RUEALCAVA. t P.nmu ANNA E. CHO MARY E. LESLIE SID C. STOLPER JOHN C. HURMAH1.N, S —a Mr. Lee Whittenberg Director of Development Services City of Seal Beach 211 Eighth Street Seal Beach, CA 90740 Dear Mr. Whittenberg: iiom® jlne City' ui) Lto� ,� \n�;rlc'ti r�. DAVID H. W1GGS, c.M.a NOps.. FRANK SALAS, ceidn, -, oBe. June 6, 2002 CITY OF SEAL BEACH JUN 2002 DEPARTMENT OF Response to Comments Received on the Draft Environmental Impact Report (EIR) for the Haynes Generating Station Repowering Proiect Thank you for commenting on the Draft EIR for the Haynes Generating Station Repowering Project. A copy of your comments and responses to those comments has been enclosed for your information. These comments and responses have also been incorporated into the Final EIR for this project. Certification of the Final EIR and consideration of the proposed project is tentatively scheduled for the Board of Water and Power Commissioners' (Board) meeting to be held on June 18, 2002 at 1:30 p.m. The meeting location is: Los Angeles Department of Water and Power Room 1555 -H, 15th Floor 111 North Hope Street Los Angeles, CA 90012 Prior to the scheduled meeting, the Beard agenda may be viewed on the IADWP website at http�//www.ladwp.com/BoardAgenda/brdagenda, or the Commission Office may be contacted at (213) 367 -1350. Per your request, enclosed is a copy of the Risk Management Plan for the Ammonia Solution Storage and Supply System at the Haynes Generating Station. Water and Power Conservation ... a way of life 111 NorN Hope Semi Los Angeles CAUOnd8 OMailing address: Box 51111. Las Angeles 90051 -0100 Telephone: (213) 367 -4211 Cable address: DEWAPOLA FAX: (213) 367 -3287 Mr. Lee Whittenberg - 2 - June 6, 2002 Please note that Section 2: Offsite Consequence Analysis of the document has been removed from this copy. Pursuant to U.S. Environmental Protection Agency Guidelines, this section is not available for public review for security reasons. If you wish to view this section, please contact Mr. Dat Quach at (213) 367 -4697 in order that appropriate security measures may be made. Sincerely, MARK J.SEDLACEK Manager Corporate Environmental Services Enclosures c: Mr. Dat Quach r Letter 1 April 8, 2002 REP%: ;ave, Mt, Kelvin Lew APR 18 200Y Los Angeles Department of Water and Power CES Corporate Environmental Services I I l North Hope Street, Room 1044 Los Angel.. CA 90012 SUBJECT: CM OF SEAL BEACH COMMENTS RE: "DRAFT E.'VVIRONMENTAL IMPACT REPORT — ILIYNES GENERATING STATION REPOWERING PROJECT, LONG BEACH' Dear Mr. Lew: The City of Seal Bexh has reviewed the above,referenced Dra @'Environmental Impact Report (DEIR) prepared by the Department of Watei'and Power (DWP) and has several comments relative ta the document. The proposed project is close enough to the City of Seal Beach as w cause concern regarding environmental impacts upon our community, in particular the Leisure World retirement community located immediately east of the subject property. Support of Lone Tern, Air Quality Improvements: The City of Seal Beach supports the long -term an quality improvements that the proposed 1.1 project will create. The replaoemeot of out -moiled power generating equipment, and the resultant reductions in criteria ev pollutants is of great overall benefit to the Surrounding region, and oat particular to the midenls of Leisum World As indicated in Table 4.2 -24, the project will result in net overall peak daily operational am emission reductions as follows: ❑ 5,736 pounds per day of NO. ❑ 7,306 pounds per day of CO ❑ 301 pounds per day orVOC a 31 pounds per day of SO, ❑ 454 pounds per day of PM to G' ^ }I} OoomrcotPCEOAAx'p R�mq Pmryzt OE10.CC Camrr�rr l�r Jn[.LwL1ABLI Haynes Generating Starlen Repowering Project Peel EM 3 -2 May 2002 CfiY OF SEAL BEACH JUN ynrl7 DEPARTMENT OF DEVELOPMENT SERVICES Ciry ofScal Reach Comment Letter re.' DWP Repo —g Project Draft EfR Apr118. 700? However, those significant air quality improvements come at a significant impact to the residents of the Leisure World community within Seal Beach. The major concern of the City is to reduce the identified impacts to this residential community. Requested Modification of Mitigation Measures., Upon a thorough review of the DEIR, the City of Seal Beach requests the following modifications to the language of the proposed "Mitigation Measures", as set forth in Table 1.6- 1, and as appropriate within the body of the Final £1R document, and the inclusion of an additional "Noise" Mitigation Measure: 1.2 `Air Quality" Mitigation Measme, The City of Seal Beach requests that time language of this mitigation moaswc be revised to read n follows (Replaces DER language in its entirety): 1.3 "Cultural Resources" Mi[ ga['on Measure The City of Seal Beach requests that the language of this mitigation measure be revised to read as follows: 'Pdor to the issuance of a grading permit, a certified archaeologist shall be retained. The archaeologist shall establish a plan for site surveillance during initial ground disturbance for the proposed project. Said plan shall Provide for an on -site archaedioelst and Native American monitor during all Initial ground disturbance activldes. The archaeologist shall also develop procedures for temporarily halting or redirecting work to permit sampling, identification, and evaluation of any unexpected discovery. If any resources are found to be significant, the archaeologist shall determine the appropriate actions for exploration and/or salvage after consultation with the on -site Native American monitor. 1.4 "Noise" Mitigation Measures: The City of Sed Beach requests that the language of these mitigation measumus be revised to read as follows: omvmteoawerme Prvim utm.ee enma.., ., HaynesGmemang Smtim Repoamng Pmjec, Final Ers 3 -3 May 20x2 01y of Seal Beach Co...., Lever re: DWP Rem-errag PMJact Draft EIR AP4 $,2002 "Prior to construction occurring outside of the periods specified in the noise ordinance, LADWP shall obtain authorization from the City of Long Beach The noise ordinance limits the noise emanating from "operation of any tool m equipment" to specific houss set forth in Section 8.80202 of the Municipal Code. Prior to the City of Long Beach Itrantine such authorization, it shall meet and confer with the City of Seal Beach and Golden Rain Foundation (Leisure World) to consider anv concerns of these oreanizations prior to srantine such reuuested authorization. In order to minimize noise emanating from construction operations, the contractor shall implement a construction noise control program acceptable to the City of Long Beach. The program shall limit bours of pile-driving and heavy equipment operations and shall otherwise control noise from construction operations. The program shall include notification of surrounding communities (i.e., Leisure World and Island Village residents) of the period when such operations would take place. The City of Lone Beach shall meet and confer with the Citv of Seal Beach, Golden Rain Foundation (Leisure World), and Island Village to receive comments and suimestions reeardina the proposed construction noise control Pr pram prior to nr ine said promm. The roiect appl' t sh U reimburse City costs of an independent third natty review of this program " 1.5 The City of Seal Beach requests incorporation o£ the following additional "Noise' Mitigation Measure into the Mitigation and Monitoring Program for this project: pw ? nERL= a --ta- Haynes Generating Sntim aep anng Project Final Ent 3-4 May 2002 City ojSwI Beach Comment Leuer re.: DWP Repo"er gPiojecl DraJt EIR April 8. 2002 be relieved of providing windows to units within that oarticular Mutual." (Proposed new Mitigation Measure by City of Seal Beach) 1.6 Acceptance of these modifications to the "Mitigation Measures- will indicate the desire of LADWP to work in a cooperative manner with Seal Beach and the residents of Leisure World and Island Village to ensure that all reasonable concerns regarding the short -term construction impacts related to "Air Quality" and "Noise" are thoroughly addressed in the various monitoring programs that will be established during the demolition and construction phases ofthe proposed project If DWP determines to not incorporate the requested amendments to the mitigation measures set forth above, the City of Seal Beach would then formally request re- consideration by DWP of Alternative 3. For further information on the reasoning of this request please refer to "Comments on the Draft EIR Document ", immediately following. Comments on Draft EIR Document. Consideration of Project Alternative Number 3: HIf DWP determines not to incorporate the requested amendments to the mitigation measures set forth above the City of Seal Beach requests the Department of Water and Power to reconsider its rejection of Project Alternative 3. The City is of the opinion that Alterative 3; "Extend the Project Construction Schedule" and summarized on page I-4 of the DEIR would reduce impacts to the residents of Leisure World in a more acceptable manner. This alterative would extend the project constmcdon schedule to avoid the potential for nighttime and weekend construction activity, and not meet the December 2004 deadline established in the Stipulated Order of Abatement This deadline date appears to have been determined without consideration of the adverse noise impacts to the elderly residents of Leisure World. While extension of the construction schedule would langthen the time of uncomfortable daytime noise levels by about 100 days, the absence of construction activities on weekends and during extended construction hours would provide a significant level of relief for our citizens. It is our belief that the relief afforded on weekends and evenings would be welcomed by the residents of Leisure World. The City of Seal Beach requests that DWP and the SCAQMD petition the hearing board to revise the timefmme for Haynes Units 3 and 4, as noted on page 8 of the Stipulated Amended Order for Abatement, Findings and Decision, dated September 12, 2001. Comments on Issues not Addressed in Response to My Comments on NOP: The City of Seal Beach previously commented on the Notice of Preparation C'NOP ") for this Draft EIR, and will focus its comments on those issues and concerns raised in that NOP comment letter of December 19, 2001. DWP Rsyo Pg Pmjeet DEaLCC ee N I to r Baynes Gemmling Swim Re menng Project Pnal EIR 3 -5 May 2002 0,y ojSe l Beach Commem Lerrar re: DWP Repowenag Pmjee( Drat! EIR Ap it 8, 2001 Air Ouafiryr The overall air quality benefits of the proposed project have been quantified and discussed thoroughly within the Draft EIR, in accordance with the comment of the City of Seal Beach during the NOP comment period, with the exception of "ammonia slip" evaluation, discussed below. 1 S Ammonia Slip Air Emission Evaluation Lacking The NOP indicated that the expected ammonia slip emission will be set at no more than 5 ppm in the flue gas from the HRSGs. The Leisure World retirement community is immediately east of the AES Los Alamitos facility, and comprises approximately 8,300 residents, with approximately 90% being over the age of 65. Our comment letter indicated a concern to the City as to how the levels of ammonia slip being discussed could impact this population group, particularly those individuals with respiratory or other related health concems. Ahhough requested in the December 19, 2001 comment letter on the NOP, there is no indication as to what the annual one -hour maximum ground concentration for ammonia slip is anticipated to be for the proposed project. This information, along with an analysis as to where ground level conmrarations are anticipated to occur at, needs to be presented and evaluated for adverse environmental impacts. Wi11 significant ground level concentrations of ammonia exist on the Haynes facility or on the adjoining AES Alamitos facility? If on the subject or adjoining or nearby properties, those should be indicated by the use of a map. As indicated in our December 19, 2001 comment letter, this analysis needs to include a "cumulative' analysis section performed for the combined air emissions, including ammonia emissions from all proposed SCR units at both the Haynes and AES Alamitos facilities. The indicated "health risk assessment document_, along with a "risk management plan" should be provided as technical appendices to the Final EIR document, permitting the interested public to review and comment as to the adequacy of the health risk and risk management documents. The specific health risk assessment issues relating to an elderly, retirement community population of 8,300 persons, should be particularly discussed in this portion of the Draft EIIL The "Health Risk" portion of the DEIR document and its related Table 4.2- 28, do not discuss or present information on ammonia. It appears that the DEIR does not address this concern in any meaningful manner, and in particular the requested "cumulative' analysis of this facility and AES Alamitos. The Final OR should respond to these issues and concerns and provide full disclosure regarding the cumulative impacts of "ammonia slip" upon the adjoining Leisure World retirement community. Page 4 -22, Table 42 -11, Overall Peak Daily Emissions During Turbine Commissioning, 1.9 presents information as to the peak daily emissions during turbine commissioning. It is not clear in the DEIR as to how many days a year this activity would be anticipated to Occur . Please clarify this issue in the Final EIR, and explain how those occurrences are D" Repo�a P,uie, OEM= ewnmem Ua, Haynes Genenuag Suwon Re ,nag Pt,., R.al EIR 3 -6 May 2002 City arSeal Beach Comment Letter re: DWP Repownriag Project Draft EIR April 8, 2002 incorporated into the information provided in Table 4.2 -24, Net Overall Peak Daily Operational Mass Emissions. 1.10 Geoloev: The discussion on page 14 of the NOP indicated the existence of a document titled 'Los Angeles Department of Water and Power, Risk Management Plan, Ammonia Storage and Supply System, Haynes Generating Station ", dated Jane 1999, prepared by Corporate Environmental Services. The City of Seal Beach again requests a copy of the referenced 1999 report and any updates to that document that may be prepared in the future. It is important to our emergency response providers to be aware of the potential risks and the management actions and programs in place at the Haynes facility to respond to potential risk and upset situations. 1.11 Hvdroloev and Water Quality, The DEIR provides adequate discussion regarding conformity with the appropriate requirements of the Los Angeles Regional Water Quality Control Boards- Manse: 1.12 The Draft EIR includes a noise and groundbome vibration impact section, and in particular discusses the additional operational noise generated by the new facilities, the ability of the "proposed noise reduction measures" to reduce that noise to a level of less than significant, and discussion as what noise level is deemed acceptable. - The DEIR indicates that "Construction activities are anticipated to last approximately 26 months and take place six days per week, Monday through Saturday. Tivo f 0 -hour shifu are possible at times during the construction period. To ensure that construction activities stay on schedule, two ten -hour shifts may be necessary at timer during the construction period, and Sunday shifts may also be required at times." (page 1 -0). The City wishes to express extreme concern regarding all anticipated construction activities that would occur before 7:00 AM or after 8:00 PM, and anytime on Sunday. Analysis of impacts to the adjoining residential community of Leisure World of extended construction hours and Sunday construction activities indicate impacts that cannot be mitigated to a less than significant level. As indicated above, the City of Scal Beach is requesting the opportunity, along with Leisure World and Island Village, to review and provide comments an requests by LADWP to permit construction activities occurring outside of the periods specified in the noise ordinance of the City of Long Beach and to review and provide comments on the required "construction noise control program ", prior to the granting of those requests by the City of Long Beach. Specific concerns of Said Beach relate to the following construction activities: • Construction activities occurring after 7:00 PM on a daily basis • Construction activities occurring on Saturdays and Sundays. c,eiu oeR.= Ciun —I teav Haynaa Genenung Sudan Repoweang Noted Final Ent 3 -7 M, 2002 City of Seal Beach Cammmt Letter rr: DWP Pra /err fYaft E1R Aprir S. 2002 It is recommended that any requests for extended construction operations and pile driving activities include provisions of the use of equipment noise barriers and enclosures, and possibly utilization of temporary fabric screens along the fmcaline, to reduce construction - related noise impacts. In addition, the use of pour -in -place caissons, rather than piledriver caissons should be carefully considered. Further, since the construction schedule indicates that construction activities will occur for an anticipated 26 months, the noise impacts to impacted areas of Leisure World will be significant for a significant period of time. The DEIR indicates thin the pile driving noise level at the nearest residences would be about 70 dB(A), which would be perceptively intrusive. Tlae DEIR indicates that limits on Oita driving could be observed in minimize the impacts (DEIR, Page 4 -73). The DEIR also indicates that construction of the proposed wastewater ponds adjacent to the property line could temporarily increase noise levels to about 76 dB(A) at the nearest residences, assuming no attenuation (DEIR, Page 4-75). This increase in noise levels is much greater than perceptible, and the City requests that a noise mitigation program be established to provide double -pane windows on the appropriate sides of all impacted residential units within Leisure World, as determined based on mom detailed noise analysis. The City feels that the window replacement program should include the following structures within Leisure World, at a minimum; o Mutual 8 — Buildings 199 and 201 • Muma14 — Buildings 37, 48, 50, and 5l • Mutual 3 —Buildings 18-20,32-34 Implementation of this mitigation program would be anticipated to reduce construction noise impacts to less than significant 133 1 Transaorradon and Traffic: The DEIR indicates that the intersection of Studebaker Road and Westminster Avenue will be significantly impacted in the PM peak hour as a result of the proposed project (Page 4-92, Table 4.5 -7). An "Intersection Safety Analysis" is then presented on pages 4-95 and 4-96. The "Intersection Safety Analysis" does not analyze the we intersection in the study area identified as being significantly impacted by the project, Studebaker Road and Westminster Avenue. It is requested that a "Intersection Safety Analysis" also be conducted for Studebaker Road and Westminster Avenue, Hazardous Materials: The Initial Study indicated there would be no impacts related to "Hazards and Hazardous Marenals ". The City of Seal Beach expressed concerns regarding this environmental impact issue, and they have not been addressed in the DEIR, and are again act forth below: " Hazards and Hazardous Materials: 1.14 The NOP discussion related in general risk of upset/humam health impacts of transportation of aqueous ammonia from various potential locations within DwP aepowerin80mjet DaaI.CC rammrcre f.ean Haynes Geocnang Sufi.. Rl.a .ng Pr ject Fnal Ent 3-8 May 2002 City afSea! Beach Comment Letter ,r DWP Repamering Prajecr Dr /t EIR' Ayril 8. 200: the region to the subject site. It is recommended that the specific transportation routes be indicated! within the Final EIR 1Lis would allow easier review and comments from interested individuals or organizations regarding this specific area of concern. Then: should be discussion in the Final EIR as to the statistical likelihood of a liquid ammonia release, based on cumulative operating conditions of the AES Alamitos and Haynes facilities. In addition, there should be an indication of the storage capacity of the ammonia storage areas, the retention capacity of spill containment areas, assuming a release were to occur, and a determination as to the length of a release without overflowing the proposed spill containment system. As was indicated in the 1993 SEIR for the AES Alamitos facility, the worst - case population exposure to the 100 -ppm ammonia irritation level for a complete containment facility failure was 2,070 persons. It is assumed that an increased level of exposure would now be created, and that a portion of this exposed population is located in Seal Beach, and most probably within Leisure World. The new analysis should include a map presentation of the area impacted by the modeled dispersion at the 100 ppm level, to allow both the City of Long Beach and the City of Seal Beach to be more fully informed as to potential impacts upon their respective residents. In the case of Seal Beach, there is a heightened level of concern, since the Leisure World community comprises approximately 8,300 residents, with approximately 9001. 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 disetuslon should also provide information as to the nearest responding emergency service unit locations, estimated response times, and potential impact upon the capabilities of emergency medical response to meet the demands placed upon the emergency medical response system by a large amount of emergency calls from impacted persons. The 1993 SEIR for the AES Alamitos facility also indicated that the wont - case population exposure to the 100 -ppm ammonia irritation level is 5,020 resulting from a transportation spill and a complete containment failure, based upon analysis prepared for the Redondo Station. 1.15 The Final EIR should indicate the transportation routes that will be utilized m transport the aqueous ammonia from anticipated suppliers to the Haynes Generating Station. The 1993 SEIR indicated that most of the anticipated suppliers are located to the north or east. In order to eliminate potential impacts m the Leisure World community, it is recommended that all truck transport of aqueous ammonia utilize the Route 40516031SR- 22/Smdebaker Road access locations to serve the generating station, with ne, deliveries occurring along pacific Coast Highway, Westminster Avenue nr Seal Beach DwP R"wering Prvlm DEl0.Cr Ca—ea Leiar Haynes Generating Sauna RepuweringP jest Final EIR 3-9 May 2002 Ciry ofsmi Beoch Comment Gems re: DWP Po:pawerfng Prajact Dmfl EIR April 8. 2002 Boulevard. It is also requested that local fire and police departments, both Long Beach and Seal Beach, be informed 24 -hours prior to shipment, including routing information. If took transport will occur within Seal Beach, it is assumed that a portion of this exposed population is located in Seal Beach, and most probably within Leisure World. The DER analysis should include a presentation of the area impacted by the modeled dispersion at the IDO ppm level, to allow both the City of Long Beach and the City of Seal Beach to be more fully infomred as to potential impacts upon their respective residents. In the case of Seal Beach, there is a heightened level of concern, since the Leisure World community comprises approximately 8,300 residents, with approximately 90% being ova the age of 65. It is a concern to the City as to how the levels of ammonia being utilized could impact this population group, particularly those individuals with respiratory or other related health concerns. -This discussion should also provide information as to the nearest responding emergency service unit locations, estimated response times, and potential impact upon the capabilities of emergency medical response to meet the demands placed upon the emergency medical response system by a large amount of emergency calls from impacted persons. Discussion should also be provided as to the types of anticipated human health problem to be anticipated assuming exposure of a large elderly population. The Final EEL should include a thorough discussion and evaluation pf potential impacts related to the above corroans" The Enviamtental Quality Control Board (EQCB) considered and discussed the DM document on March 27, 2002 and the City Council considered and discussed the DEIR document on April 8, 2002. The City Council and the EQCB authorized the Mayor and Chairman, respectively, to sign this letter indicating the official comments of the City of Seal Beach. Upon the preparation of the Front FIR for this project, please said 4 hard copies and a digital copy, if available, to Mr. Lee Whiuenberg, Director of Development Services, City Ball, 211 Eighth Street, Seal Beach, 90740. Thank you for your consideration of the comments of the City of Seal Beach. if you have questions concerning this matter., please do not hesitate to contact Mr. Whittenberg at telephone (562) 431 -2527, extension 313, or by a -mail at Iwhittenberg&iseal- beaeh.mus, y Sincerely, Wlliam Dane 7oscph otter lR Mayor an City of Seat Beach ntal Quality Control Board P-1 aaPV..a.,na P.O. omcc Comma., 4— Haynes Genmeting Station ftep ering Rajen Final EM 3 -10 May 2002 Distribution: Seal Beach City Council Seal Beach Envirortmental Quality Control Board City Manager Golden Rain Foundation Atm: William Namng South Coast Air Quality Management District Atta: Nornta 1. Glover, Board Chairman 21865 E. Copley Drive Diamond Bar, CA 917654182 South Coast Air Quality Management District Attn: Edward Camarena, Hearing Board Chairman 21865 E. Copley Drive Diamond Bar, CA 91765 -4182 Dw Rmw,nna Pnlm Da CC C—a -, tmv Hayves Generetiog S.Ii. Repo mg Projen Fnel EIX 3 -11 May 2002 Ory afSwl Beach Comment Loner re: DWP Repowering Project Dv/ ELR Aprit 8. 2002 Scal Beach Planning Commission Seal Beach Archaeological Advisory Committee Director of Development Service City of tong Beach Ann: Gefiardt Felgemaker Response to Letter 1 City of Seal Beach, April S, 2002 1.1 The LADWP is appreciative of the City of Seal Beach's support for long -term air quality improvements that result from the implementation of the proposed project. LADWP notes that only relatively short-term impacts associated with project construction were identified as significant in the Draft EIR. There are no long -term significant adverse impacts associated with the proposed project. 1.2 As stated on page 4 -13 of the Draft EIR, the SCAQMD has regulatory jurisdiction over the air quality issues related to the proposed project. The proposed project must comply with relevant SCAQMD rules and regulations in order to be issued permits to construct and operate. These rules and regulations are listed in Table 3.7 -1 (Applicable SCAQMD Air Quality Rules and Regulations) on page 3 -20 of the Draft EIR, and they include Rule 403 (Fugitive Dust). Hence, the LADWP has already committed to comply with Rule 403. In addition to compliance with Rule 403, mitigation measures for the proposed project include increased watering of active construction sites by one additional time per day beyond that specified in Rule 403. 1.3 The Cultural Resources mitigation measure has been revised in the Final EIR per the City's comment. 1.4 Upon further review of the City of Long Beach noise ordinance, it has been determined that because LADWP does not require permits for the proposed project from the City of Long Beach, the construction of the project is not subject to the provisions of the noise ordinance. Therefore, the noise ordinance does not provide the City of Long Beach a mechanism to formally authorize or limit construction activities in relation to noise issues. However, as indicated in the Draft EIR, the proposed project may result in short-term environmental impacts from noise created during project construction in relation to City of Long Beach and City of Seal Beach noise standards and existing ambient noise levels at and surrounding HnGS. Therefore, the mitigation measures related to construction noise have been revised in the Final EIR to require LADWP to coordinate with the City of Long Beach in the development of a construction noise control program for the proposed project and meet with the Golden Rain Foundation (Leisure World) to receive comments and suggestions regarding the development of this program. Island Village has not been included in this requirement because, based on the existing noise ordinance standards for Island Village and the existing ambient noise levels along Westminster Avenue, the noise generated by the proposed project construction would not create a significant impact. The revised noise mitigation measure is as follows. Prior to construction activities that would occur outside of allowable periods as specified in the City of Long Beach noise ordinance (the noise ordinance permits construction activities from 7 AM to 7 PM on weekdays and from 9 AM to 6 PM on Saturday) or that would exceed the noise ordinance standards specified for the allowable periods of construction, LADWP shall develop a construction noise control program. This program shall be developed in coordination with the City of Long Beach. LADWP shall also meet with the Golden Rain Foundation (Leisure World) to receive comments and suggestions lbynes Geoem ing Swim Repmmng Fgixt Foal EM 3 -12 May 2002 regarding this program. The program shall address noise created by construction activities occurring outside of allowable periods specified in the City of Long Beach noise ordinance. The program shall establish the types of construction activities that are unacceptable during these "off hours" The program shall include notification of surrounding communities (i.e., Leisure World and Island Village residents) when "off- hours" construction activities will take place. The program shall include a limitation on pile driving and the operation of heavy equipment near the HnGS eastern property line to between the hours of 8 AM and 6 PM, Monday through Friday, and 9 AM and 6 PM on Saturday. The program shall also include physical mitigation measures, to the extent that they are necessary, feasible, and effective, to reduce the impacts from noise caused by construction activity. These measures may include noise barriers located adjacent to construction activity, noise barriers located along the HnGS property boundary, and/or noise reduction measures involving windows in affected residential units in Leisure World. 1.5 While the revised mitigation measures related to noise control (see Response 1.4, above) do not specifically call for the implementation of a window replacement program at Leisure World, such a program has not been excluded. The revised noise mitigation measure requires that the construction noise control program considers physical measures to reduce the impacts from noise caused by pile driving and the operation of heavy equipment new the eastern property line. These measures could include window replacement or other noise control treatments for windows, to the extent that they are necessary, feasible, and effective. 1.6 Noise mitigation measures have been revised (see Response 1.4, above) in an effort to work cooperatively to reduce impacts. Please also see Response 1.7 regarding Alternative 3. 1.7 By restricting the hours during which pile driving and the operation of heavy equipment near the eastern property line shall occur and by requiring that other types of construction activities that might occur during `off hours" be defined in the construction noise control program, the revised noise mitigation measure (see Response 1.4, above) effectively achieves the objective of Alternative 3 to avoid "off- hour" construction noise impacts. 1.8 Ammonia slip from the HnGS will be no more than 5 ppm. Ammonia is considered both a chronic and acute non - cancer agent. The Office of Environmental Health Hazard Assessment (OEHHA) has established Reference Exposure Levels (RELs) for both chronic (i.e., long -term) and acute (i.e., short-term) exposure to ammonia. These RELs are designed to be protective of sensitive populations, including the elderly, children, and persons with respiratory or other related health concerns. Ammonia slip emissions were evaluated in the risk assessment that was conducted for the facility, as indicated in Table 4.2 -16 of the Draft EIR, which shows the emissions of toxic air contaminants. All emissions in the table were included in the risk assessment. The highest acute impacts for all toxic air contaminants included in the risk assessment were predicted to occur west northwest of HnGS (i.e., away from Leisure World). The maximum cumulative acute hazard index was 0.125 at the point of highest impact. The short-term maximum concentration of ammonia at the point of highest impact was predicted to be 8.76 pg/ms, which is significantly Haynes Generating SMUM Rnp enng P ,xt nual EM 3 -13 May 2002 below the acute REL of 3,200 µg/m3. The contribution to the acute hazard index at the point of maximum impact is 0.00274. Likewise, the highest chronic impacts for all toxic air contaminants included in the risk assessment were predicted to occur west and northwest of the HnGS site. The maximum cumulative chronic hazard index was 0.038 at the point of highest impact. The long -term maximum concentration of ammonia at the point of highest impact was predicted to be 0.222 µg/m3, which is also significantly below the chronic REL of 200 µg/m3. The contribution to the acute hazard index at the point of maximum impact is 0.00111. For the purpose of preparing the health risk assessment, health risks associated with facility operations are generally evaluated on the basis of incremental risk, or the facility's incremental contribution to total risk. However, to respond to the concerns raised by the City of Seal Beach, an evaluation of the potential cumulative impacts associated with ammonia slip emissions from the AES Los Alamitos facility in combination with the ammonia slip emissions from the new CTs at the HnGS facility was conducted. The Final EIR for the AES Alamitos LLC SCR installation (SCAQMD 2001) address the potential for impacts associated with ammonia slip through a screening evaluation. The maximum concentrations were predicted to occur 6,300 feet from the stack at Los Alamitos. Based on the results of the screening evaluation, the maximum predicted one -hour concentration of ammonia was 19.65 pg/m3, and the maximum predicted long -term concentration of ammonia was 1.965 µg/m3. Although the maximum impacts were predicted to occur more than a mile from the facility, to provide a conservative evaluation of the maximum possible impacts, it was assumed that the point of maximum impact could occur at the same location for the HnGS CTs and the AES facility. If the maximum predicted one -hour concentrations from both facilities occurred at the same location, the maximum one -hour concentration of ammonia would be 28.41 µg/m3. This concentration is still significantly below the acute REL for ammonia of 3,200 µg/m3. The contribution to the acute hazard index would be 0.00888. Likewise, if the maximum predicted long -term concentrations from both facilities occurred at the same location, the maximum long- term concentration of ammonia would be 2.19 11 , which also significantly below the chronic REL of 200 pg/m3. The contribution to the chronic hazard index would be 0.011. In reality, the maximum impact points would not be expected to occur at the same location. Furthermore, the analysis presented in the Final EIR for the AES Alamitos facility is a screening analysis and is likely to overestimate predicted impacts compared to using a more refined evaluation using actual meteorological data. The cumulative impacts associated with ammonia slip emissions from both facilities are therefore likely to be much lower than presented in the discussion and would not pose a significant impact to the Leisure World retirement community. 1.9 As noted on page 4 -16 of the Draft EIR, emissions from turbine commissioning are associated with the project construction phase. During turbine commissioning, the CCGS would be operated under several different scenarios (as described on pages 4 -20 to 4 -22 of the Draft EIR) to fine -tune and calibrate the equipment. The commissioning process is a one -time process Haynes Geneiiiing Station Repowsriag Project Final aac 3-14 May 20x2 that would take place over about a one -month period. While the commissioning process could take one month, the associated emissions would occur for much shorter periods of time since the CCGS would not be operated continuously during this period. As noted in Table 4.2 -11 of the Draft EIR, emissions of CO and NO, during commissioning would exceed daily significance thresholds and have been characterized as significant and unavoidable (relative to project construction). The turbine commissioning emissions are not reflected in Table 4.2 -24 in as much as that table provides the peak daily emissions of the CCGS associated with the operation phase. 1.10 LADWP will provide a copy of this document to the City of Seal Beach as requested. 1.11 The City of Seal Beach's comment that the discussion relative to conformity with requirements of Los Angeles Regional Water Quality Control Board is noted. 1.12 Please refer to Responses 1.4 and 1.5 for a response to the noise issues addressed in this comment. 1.13 The intersections evaluated for safety were specifically identified by the City of Long Beach, based in part on safety history and/or known or suspected safety issues. The emphasis of the safety analysis is to evaluate conditions relative to the movement of truck traffic, including the need for oversize loads. The Draft EIR identified construction worker traffic impact as significant at the Westminster Avenue and Studebaker Road intersection during the PM peak hour; however, project- related heavy truck traffic during these hours would be minimal. For purposes of the Draft EIR safety analysis, the level of service impacts due to employee construction traffic during the PM peak hour do not correlate with the need to conduct safety analysis for truck transportation impacts. These issues are separate and distinct. 1.14 As discussed on page 17 of the Initial Study (included in Appendix A of the Draft EIR) and on page 8 -10 of the Draft EIR, aqueous ammonia is currently stored at HnGS for use in the SCR systems associated with existing Generator Units 1, 2, 5, and 6, and the proposed project would not result in any increase in the existing storage capacity or maximum inventory of ammonia currently stored on site. Therefore, the proposed project would result in no change from current conditions at HnGS relative to the storage and use of aqueous ammonia. 1.15 As discussed on pages 17 and 18 of the Initial Study (included in Appendix A of the Draft EIR) and on pages 8 -10 and 8 -11 of the Draft EIR, the proposed project may result in an increase of up to 50 percent in tanker truck deliveries of aqueous ammonia to HnGS (from a current average of two times per week to up to an average of three times per week). The actual increase in the number of deliveries would probably be less because each of the proposed CT units would provide a peak operating capacity that is considerably lower than existing Generator Units 1, 2, 5, or 6 and, therefore, would require the consumption of relatively less ammonia. In addition, after the construction of the proposed project, existing Units 1, 2, 5, and 6 would be run at lower loads, which would decrease the consumption of ammonia in the SCR systems associated with those units. However, the estimated 50 percent increase in deliveries was a conservative estimate used for the purposes of environmental impact analysis. Based on one additional weekly delivery, the statistical likelihood of any accidental release of ammonia from Haynes Genanung SMOM Repowering Project Final Eat 3 -15 May 2002 transport related to the proposed project is approximately one per 104,500 years and of a major release, approximately one per 418,000 years. The likelihood of such a release is considered very remote, and, therefore, no significant hazard from the proposed project is anticipated. Tanker trucks providing any additional deliveries of ammonia associated with the proposed project would follow the same routes as tanker trucks providing current deliveries of ammonia to HnGS, and deliveries would continue to comply with relevant federal, state, and local laws and regulations regarding the handling and transport of ammonia. llaynes Genemung S b. Repowering R jcct Rwl Eat 3 -16 May 2002