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HomeMy WebLinkAboutCC AG PKT 2005-12-12 #F e AGENDA REPORT DATE: December 12, 2005 TO: Honorable Mayor and City Council TIIRU: John B. Bahorski, City Manager FROM: Lee Whittenberg, Director of Development Services SUBJECT: RECEIVE AND FILE - ENVIRONMENTAL QUALITY . CONTROL BOARD COMMENT LETTER RE: DRAFT EISIEIR - LONG BEACH LNG IMPORT PROJECT (SCH NO. 2003091130) SUMMARY OF-REQUEST: e Receive and File Staff Report. Authorize staff to continue to monitor this project and prepare additional Staff Reports as determined appropriate. BACKGROUND: e The City has received a copy of the Draft EIS/EIR for the above referenced project. The project site is located within the Port of Long Beach (POLB). Sound Energy .Solutions (SES) proposes to construct and operate a Liquefied Natural Gas ("LNG") import, storage, and vaporization terminal on a 25-acre site on a portion of .Pier T, designated Berth T-126, on Terminal Island within the POLB. The import terminal would deliver an average of 700 million standard cubic feet per day (MMscfd) of natural gas with a peak capacity of I Bscfd to the existing SoCal Gas pipeline system via a new 2.3-mile-long, 36-inch-diameter natural gas pipeline that would be constructed and operated by SES. In addition, a portion of the LNG would be distributed via trailer trucks to LNG vehicle fueling stations throughout southern California to fuel LNG-powered vehicles. Up to 10,000 MMBtu per day of C2 recovered from the LNG would be vaporized and distributed to the existing LARC via a new 4.6-mile-long, 10-inch-diameter pipeline that would be constructed and operated by ConocoPhillips. Power to the LNG terminal would be supplied via 0.8 mile of electric distribution lines and a new substation that would be constructed and operated by SCE. The proposed LNG terminal and associated facilities are described below. Please refer to Attachment 2 to review Figure 2.1-1, Long Beach Import Project, General Project Location to see graphically the project component locations discussed above and to Attachment 3, Figure' 2.1.1-1, Long Beach Import Project, General Site Layout to see graphically the proposed location of the facilities within the proposed LNG terminal itself. Agenda Item F Z:\My DocumontslCEQAILong Beach LNG Import Project CC StaffRcpmt docILW\12-01-oS Receive and File EQCB Comment Lettey ye: "DYCfft ElSlEIR -Long Beach LNG 1mpon PYoject" . City COIIllCil Staff Repayt December 12, 2005 e Proposed LNG Terminal Facilities: The LNG terminal facilities would include: [J a 1,100-foot-long LNG ship berth and unloading facility with unloading arms, mooring and breasting dolphins, and a fendering system that would be capable of unloading one ship at a time; [J two LNG storage tanks, each with a gross volume of 160,000 cubic meters (1,006,000 barrels) .surrounded by a security barrier wall; [J 20 electric-powered booster pumps; [J four shell and tube vaporizers using a primary, closed-loop water system; [J three boil-off gas compressors, a condensing system, an NGL recovery system, and an export C2 heater; [J an LNG trailer truck loading facility with a small LNG storage tank; [J a natural gas meter station and odorization system; [J utilities, buildings, and service facilities; and [J associated hazard detection, control, and prevention systems; site security facilities; cryogenic piping; and insulation, electrical, and instrumentation systems. The pipeline facilities would include: [J a 2.3-mile-long, 36-inch-diameter pipeline and associated aboveground facilities to transport natura1 gas from the LNG terminal to the existing SoCal Gas system; and [J a 4.6-mile-long, lO-inch-diameter pipeline and associated aboveground facilities to transport vaporized C2 from the LNG terminal to the existing ConocoPhillips LARC. e A complete description of the proposed project is provided in Section 2.0, Description of the proposed Action, previously provided to the City Council. Focus of City Staff Review of Document and approved Comment Letter by the Environmental Quality Control Board: Staff focused its review of the document on Section 3, the "Alternatives" section that discusses potential alternate locations along the California coast for such a facility; Section 4.9, Air Quality (in light of the information contained within the ARB report on "Diesel Particulate Matter Exposure Assessment Study for the Ports of Los Angeles and Long Beach"; a copy of which has previously been provided to the City Council), and on Section .4.11, which discusses the "Reliability and Safety" aspects of such a project. Section 4.11 also includes discussion of potential "worst-case" impacts from accidental or intentional (e.g., terrorist-induced) releases of LNG in or near the proposed LNG import terminal in Long Beach Harbor. e Long Boaob LNG Impmt Projoot.CC StaffRoport 2 e Receive and File EQCB Comment Leno ye: "Drqft ElS/EIR - Long Beach ING 1mpon hoject" City COU1Icil Staff Report December'12,2005 The public comment period on this DEIS/DEIR ended' on December 8 and therefore the Environmental Quality Control Board reviewed and approved a comment letter at its meeting of November 30, 2005 that addressed the issues discussed immediately above. Summary of Proposed Action, Environmental Impacts and Related Documents Regarding Liquefied Natural Gas (LNG): Staff has previously provided a copy of the following sections of the Draft EIS/EIR and other related documents for the City Council on November 17 for information purposes: e CJ Draft EIS/EIR Report: CJ Introduction by Federal Energy Commission(FERC) and the Port of Long Beach (POLB); CJ Table of Contents, Tables, Figures, Acronyms and Abbreviations; CJ Executive SnmmAry; CJ 1.0 - Introduction; CJ 2.0 - Description of the Proposed Action; CJ 3.0 - Alternatives; CJ 4.9 - Air Quality CJ 4.11 - Reliability and Safety CJ Figures from Chapters above CJ Appendix F - Hazards Analysis of a Proposed LNG Import Terminal in the Port of Long Beach, Califomia e CJ The following miscellaneous documents regarding Draft EIS/EIR and LNG in general were also provided on November 17 for the information of the City Council: CJ "Environmental Study on LNG Terminal Released", Port of LOllg Beach News Release, October 10,2005 CJ "Public Hearing Schedule, Proposed LNG Terminal Environmental Review Process", Port of Long Beach CJ "LNG Terminal Project, Environmental Impact Review Process", Port of Long Beach Q "Environmental Study on LNG Terminal Released", Port of Long Beach CJ "Liquefied Natural Gas in California: History, Risks, and Siting", California Energy Commission Staff White Paper, 1u1y 2003 CJ "Significant Events in the History of LNG" CJ "West Coast LNG Projects", California Energy Commission Staff, September 20, 2005 CJ "Liquefied Natural Gas (LNG)", California Energy Commission, November 8, 2005 CJ "Liquefied natural gas Safety", California Energy Commission, November 8, 2005 CJ "Documents Relating to Liquefied Natural Gas", California Energy Commission, November 8, 2005 Long Beach LNG Import ProJoel CC Sta1fRcport 3 I Receive and File EQCB Comment Lett.,. ye: "DYqft ElS/EIR - Long Beach LNG Impon hoject" City COllllCil Staff Repon Decembef' 12, 2005 e These sections and additional miscellaneous documents provided an overview of the proposed project, discussion of the various areas of environmental concern, a summary of areas of environmental concern, proposed mitigation measures and additional information regarding the consideration process by the various Federal and State reviewing and permitting agencies, and the Port of Long Beach. Project Objectives: Provided below is a brief summary of the three stated project objectives: [J provide up to 1 billion cubic feet per day (Bscfd) of natural gas to southern California; [J supp~y up to 150,000 gallons per day (gpd) of LNG vehicle fuel; and [J provide storage of up to 320,000 cubic meters of imported LNG to reduce fluctuations in the local supply. Additional discussion on these project objectives is set forth on pages 1-3 through 1-4 of the document. DEIR Comment Period: The comment period on the DEIR concluded on December 8, 2005, at which time all comments were to have been received in Washington D.C. e Again, the EQCB did approve a comment letter on November 30 on this DEISIDEIR. A copy of their comment letter is provided as Attachment I for the information of the City Council. Public A vailabilitv of Draft EIS/EIR: A copy of the Draft EISIEIR is available at the Department of Development Services for review. In addition, the OEIR is available at: a Port of Long Beach Planning Division 925 Harbor Plaza Long Beach, CA 90802 a Mary Wilson Library a RossmoorlLos Alamitos Library a Leisure World Library e Long Beach LNG Import Project.CC StaffRepmt 4 e e e Receive and File EQCB Comment Letter ye: "DYoft ElS/ElR - Long Beach LNG lmpon Project" City Council StaffRepoYI December 12, 2005 lJ by accessing http://www.polb.comlnews/dispIaynews.asp?NewsID=12. FISCAL IMPACT: No direct impacts. If increased environmental degradation upon the City is experienced as a result of the proposed project, the costs of appropriate mitigation measures should be the responsibility of the project proponent. To the extent that those impact mitigation costs are not completely the responsibility of the project sponsor, the City of Seal Beach may ultimately have to incur significant expenses to adequately mitigate unfunded environmental mitigation programs. RECOMMENDATION: Receive and Fiie Staff Report. Authorize staff to continue to monitor this project and prepare additional Staff Reports as.determined appropriate. Whittenberg Director of Development S Attachments: (5) Attachment 1: EQCB Comment Letter Dated December 1,2005 re: "Draft EIS/ElR - Long Beach LNG Import Project (SCH No. 2003091130)" Attachment 2: Figure 2.1-1, Long Beach Import Project, General Project Location Attachment 3: Figure 2.1".1-1, Long Beach Import Project, General Site Layout Attachment 4: Excerpts of "Draft EIS/EIR - Long Beach LNG Import Project (SCH No. 2003091130)", prepared by the Federal Energy Regulatory Commission and the Port of Long Beach, dated October 2005 CJ Introduction by Federal Energy Commission (FERC) and the Port of Long Beach (POLB); Long Beach LNG Import Project CC StaffRcport 5 Attachment 5: Q Receive and File EQCB Comment Lettu ye: "Dyaft ElSlElR - Long Beach LNG Impon Project" City Council Staff Repol1 Decembu 12, 2005 e Q Table of Contents, Tables, Figures, Acronyms and Abbreviations; Q Executive Summary; Q 1.0 - Introduction; Q 2.0 - Description of the Proposed Action; Q 3.0 - Alternatives; Q 4.9 - Air Quality; Q 4.11 - Reliability and Safety; Q Figures from Chapters above; and Q Appendix F - Hazards Analysis of a Proposed LNG Import Terminal in the Port of Long Beach, California Note: Previously provided to City Council and not included with Staff Report due to length of the document. A copy of the complete Draft EIS/EIR will be available at the City Council Meeting for review Miscellaneous Documents regarding Draft EIS/EIR and LNG In General: Q Q "Environmental Study on LNG Terminal Released", Port of Long Beach News Release, October 10, 2005 "Public Hearing Schedule, Proposed LNG Terminal Environmental Review Process", Port of Long Beach "LNG Terminal Project, Environmental Impact Review Process", Port of Long Beach "Environmental Study on LNG Terminal Released", Port of Long Beach "Liquefied Natural Gas in California: History, Risks, and Siting", California Energy Commission Staff White Paper, July2003 "Significant-Events in the History of LNG" "West Coast LNG Projects", California Energy Commission Staff, September 20, 2005 "Liquefied Natural Gas (LNG)", California Energy Commission, November 8, 2005 "Liquefied natural gas Safety", California Energy Co=ission, November 8, 2005 "Documents Relating to Liquefied Natural Gas", California Energy Commission, November 8, 2005 e Q Q Q Q Q Q Q e Long Boach LNG Impmt Project CC Staff Report 6 e Receive and File EQCB Comment Len"" ye: "DYaft E1S1ElR - Long Beach LNG 1mpon Pyoject" City Council Staff Repol1 Decembt!f' 12, 2005 Note: Previously provided to City Council and not included with Staff Report due to length of the documents. Copies will be available at the City Council Meeting for review * * * * e e Long Beach LNG Impmt Project cc StaffRepmt 7 Receive and File EQCB Comment Lettey ye: "Dyqfl ElSlElR - Long Beach LNG ImpOl't Project" City Council Staff Repon Decembey 12, 2005 e ATTACHMENT 1 EQCB CO~ENT LETTER DATED DECEMBER 1, 2005 RE: "DRAFT EIS/EIR - LONG BEACH LNG IMPORT PROJECT (SCH NO. 2003091130)" e e Long Beach LNG Import Projccl.CC StaffRoport 8 December 1,2005 Magalie R. Salas, Secretary Federal Energy Regulatory Commission 888 First Street, NE, Room lA Washington, DC 20426 Robert Kanter, Ph.D. Port of Long Beach Planning Division 925 Harbor Plaza Port of Long Beach Long Beach, CA 90802 e SUBJECT: FERC DOCKET NO. CP04-58-000, ET AL. and POLB APPLICATION NO. BDP 03-079 CITY OF SEAL BEACH COMMENTS RE: "DRAFT EIS/ElR :.... LONG BEACH LNG IMPORT PROJECT (SCH NO. 2003091130)" Dear Mr. Salas and Mr. Kanter: The City of Seal Beach has reviewed the above referenced Draft Environmental Impact StatementlEnvironmental Impact Report (DEISlElR) prepared by the Federal Energy Regulatory Commission and the Port of Long Beach, dated October 2005, and has several comments relative to the document. This document was not able to be reviewed by the City Council due to the close of comments prior to the next available City Council meeting. Therefore, the following comments reflect the official position of the City of Seal Beach on this environmental document. The proposed project is close enough to the. City of Seal Beach as to cause concern regarding environmental impacts upon our community. Our comments are primarily directed at the information, conclusions, and proposed mitigation measures set forth in Section 3, Altematives, Section 4.9, Air Quality, and Section 4.11, Reliability and Safety. The concerns of the City are heightened upon our review of a recent study released by the State of California Air Resources Board titled "2005 Draft Diesel Particulate Matter Exposure Assessment Study for the Ports of Los Angeles and Long Beach" (''the ARB Report"). e Due to significant health risks identified within the ARB Report from existing diesel particulate emission from both the Ports of Los Angeles and Long Beach, it is requested that a supplemental analysis of air quality impacts throughout the document be prepared and re- distributed to all interested parties for review and provision of commeIl.ts prior to closing the Z:\My DoCUll1lll1tslCEQAlLong Beach LNG Impmt Projoct DEIS-DEIR EQCB I..etter.docILWlII-30-0S City of Seal Beach EnviI"onmental Quality ContYol Board Comment Lette1' re: "D1-<rfi E1SIElR - Long Beach LNG lmpon l'7'oject (SCH No. 2003091130):' FERC Docket No. CP04-58-OOO, of 01. and POLB Application No. HDP 03-079 _ Novembe1' 30, 2005 _ public review and comment period Qn the DEIS/ElR and the preparation of the Final EIS/Effi. for this project. This analysis needs to also consider the cumulative impacts of this project and the "Draft Environmental Impact Report 37-03 - Long Beach Airport Terminal Improvement Project (SCH No. 200309112)", and the cumulative projects identified in both of these environmental documents. Comments and Concerns re: Section 3, Alternatives: In our review of this important section of the DEIS/EIR, it is apparent that the issue of proper locations for LNG facilities is of both national and statewide concern and we are disappointed that the regulatory agencies at the Federal and State levels have not been able to come to agreement on a comprehensive energy policy and facility siting program to address these national and statewide concerns. The leadership at the Federal, State and local levels. needs to be harnessed in a positive manner to achieve such an outcome. The discussion on pages 1-3 and 1-4 highlights both the current situation regarding LNG supplies in California and the necessity of a coorrl;n~tPd, comprehensive energy policy and facility siting program.. .; Until those actions are taken, projects of this nature will continue to result in strong positions being stated by parties that feel their personal safety, that of their families, and their entire community is being severely threatened without a clear understanding of the important Federal and State goals and policies that are related to the siting of a specific energy facility in California A reasoned and lengthy dialogue among all interested parties regarding a comprehensive energy policy and facility siting program would achieve great strides in bringing these issues and concerns to a closure position that would allow persons to make decisions regarding their personal lifestyle in full knowledge of the goals and facility siting plans of such a comprehensive program. e The analysis clearly indicates that the use of natural gas is a relatively clean and efficient fuel that can release emissions of regulated pollutants (e.g., NO", SQz, and PMIO) or unregulated greenhouse gases (e.g., COV. The City of Seal Beach supports any improvements to the regional air quality that can be achieved in a responsible and safe mAnner for the population not only of Seal Beach, but of the entire South Coast Air Basin. However, the ARB Report contains on page 2 and 3 the following key findings that should cause all parties involved with this project to re-evaluate the impacts of additional diesel particulate matter emissions upon the region: "The key findings from this study are: [J Diesel PM emissions from the ports are a major contributor to diesel PM in the South Coast Air Basin. The combined diesel PM emissions from the ports are estimated to be about 1,760 tons per year in 2002. This represents a significant component of the regional diesel PM emissions for the South Coast e Long Beach LNG Impmt Project DEIS-DElR.EQCB Lellor 2 e City of Seal Beach Envi1'onmental Quality Cont1'ol BOaYd Comment Letter re: "j)yqf/ ElSIEIR - Long Beach LNG ImpoYt Project (SCH No. 2003091130)" FERC Docket No. CP04-58-000, et al and POLE Application No. HDP 03-079 November 30, 2005 Air Basin (SCAB) at about 21 percent of the total SCAB diesel PM emissions in 2002. Focusing only on diesel PM emissions occurring on port property or within California Coastal Waters (CCW) , the emissions from ship activities (transiting, maneuvering, and hotelling) account for the largest percentage of emissions at about 73 percent, followed by cargo handling equipment (10 %), commercial harbor craft vessels (14%), in-port heavy duty trucks (2%), and in-port locomotives (1%). CJ Diesel PM emissions from the ports impact a large area and the associated potential health risks are of significant concern. Diesel PM emissions from the ports result in elevated cancer risk levels over the entire 20-mile by 20-mile study area. In areas near the port boundaries, potential cancer risk levels exceed 500 in a million. As you move away from the ports, the potential cancer risk levels decrease but continue to exceed 50 in a million for more than 15 miles. e Primary diesel PM emissions from the ports also result in potential non-cancer health impacts within the modeling receptor domain. The non-cancer health effects evaluated include premature death, asthma attacks, work loss days, and minor restricted activity days. Based on this study, average numbers of cases per year that would be expected in the modeling area have been estimated as follows: CJ 29 premature deaths (for ages 30 and older), 14 to 43 deaths as 95% confidence interval (CI); CJ 750 asthma attacks, 180 to 1300 as 95% CI; CJ 6,600 days of work loss (for ages 18-65), 5,600 to 7,600 as 95%CI; CJ 35,000 minor restricted activity days (for ages 18-65), 28,000 to 41,000 as 95% CI. CJ "Hotelling" emissions from ocean-going vessel auxiliary engines and emissions from cargo handling equipment are the primary contributors to the higher pollution related health risks near the ports. e Hotelling emissions from ocean-going vessels account for about 20 percent of the total diesel PM emissions from the ports. These emissions are responsible for about 34 percent of the port emissions related risk in the modeling receptor domain based on the population- weighted average risk. These emissions resulted in the largest area (2,036 acres) where the potential cancer risk levels were greater than 200 in a million in the nearby communities. The second highest category contributing to cancer risk levels above 200 in a million was cargo handling equipment, which impacted a residential area of 410 acres and is responsible for about 20 percent of the total risk in the modeling receptor domain based on the population-weighted average Long Beach UlG lmpmt Project DEIS-DElR.EQCB Lotter 3 City of Seal Beach EnviJo01l11lental Quality Cont1'ol BoOYd Comment Letter- ye: "Draft E/S/EIR - Long Beach LNG Impon Project (SCH No. 2003091130)" . FERC Docket No. CP04-58-000, et al. and POLB ApplicationNo. HDP 03-079 _ November- 30, 2005 _ risk. Reducing emissions from these two categories will have the most dramatic effect on reducing the port emissions related risks in nearby communities. [J Emissions from commercial harbor craft, in-port trucks, in-port rail, and ocean-going vessels (transit and maneuvering. activities) account for a much smaller percentage of the near source risk, but are an important contributor to elevated cancer risk levels over a very large area. Emissions from commercial harbor craft, on-port trucks, on-port rail, and ocean going vessels (maneuvering and transit activities) account for about 70 percent of the total diesel PM emissions for the ports. While emissions from these source categories do not have a major role in the near port risk levels, they are significant contributors to the overall elevated risk levels in the study area. Addressing the emissions from these sources is critical if we are to significantly reduce the exposure of a large population (over 2 million people) to cancer risk levels in the 50 in a million range." 1 In reviewing the other "offshore" proposed projects in Southern Ca1ifomia, it is the opinion of the Environmental Quality Control Board that the Cabrillo Port LNG Deepwater Port _ project is the ''Environmentally Superior" site alternative given the infqrmation provided in _ Section 3 of the subject document. Table 3.2.2-2, Environmental Comparison of the Long Beach LNG Import Project and the Cabrillo Port LNG Deepwater Port clearly indicates that: [J "The consequences of an. incident at the proposed fadlity are potentially less than at an onshore terminal due to the site's more remote location.", and [J "Given the location of the FSRU 21 miles offihore of Port Hueneme and Oxnard, air pollutants resulting from operation of the project would disperse and would nat likely contribute to cumulative air quality impacts at onshore areas." It is the opinion of the Environmental Quality Board that the Cabrillo Port LNG Deepwater Port project substantially achieves the stated project objectives while resulting in greatly reduced impacts to the entire southern California area by eliminating the cumulatively significant adverse impacts for the proposed project regarding "Air Quality" and "Reliability and Safety" issues set forth within the subject Draft EIS/EIR. 1 "2005 DYafI Diesel Paniculate Matter Exposure Assessment Study foy the Pons of Los Angeles and Long Beach", State of California Air Resources Board, Page 2 and 3. e Long Beach LNG Import ProJect DE1S-DEIR.EQCB r.eu.r 4 e e e City of Seal Beach Environmental Quality COnl1"ol BOaYd Comment Lette1' ye: "Dyqft ElSIEIR-Long Beach LNG ImponProject (SCHNo. 2003091130)" FERC Docket No. CP04-58-000, et al. and POLE Application No. HDP 03-079 November 30. 2005 Comments and Concerns re: Section 4.9, Air Quality: Sl{poort ofLonfl-Term Air Oualitv Improvements: The analysis clearly indicates that the use of natural gas is a relatively clean and efficient fuel that can release emissions of regulated pollutants (e.g., NO., S~, and PMIO) or unregulated greenhouse gases (e.g., C<h). The City of Seal Beach supports any improvements to the regional air quality that can be achieved in a responsible and safe ",AnnP.l' for the population not only of Seal Beach, but of the entire South Coast Air Basin. However, the ARB Report contains on page 2 and 3 significant findings regarding the air quality impacts of existing Port operations that are not presented, evaluated, and proposed for mitigation under the current Draft EISIEIR document. Revised Analvsis is Required in Liflht of New and SiImificant Air Oualitv Information Not Available at time of PreDaration of Draft EISIEIR: As stated above ip. our comments on Section 3, Alternatives, it is the position of Seal B~ that a revised "Air Quality" analysis must be prepared and re-circulated for public review and comments due to the release by the Air Resources Board of the referenced "2005 Draft Diesel Particulate Matter Exposure Assessment Study for the Ports of Los Angeles and Long Beach". This document sets forth significant new information regarding impacts upon "Air Quality" and "Hazards" that are not discussed, evaluated, and proposed for mitigation under the current Draft EISIEIR document. Section 4.9.6. Gerreral Conformitv Determination ImDroDerlv Defers Necessarv and ADDrouriate Federal Air Oualitv Conformitv Analvsis: This section, on page 4-119 indicates that: "To allow the FERC staff to complete its analysis and issue a Final General Confonnity Determination, the FERC staffrecommends that: [J SES shall complete a full air quality analysis and identify any mitigation requirements necessary for a finding of conformity with the applicable SIP and AQMP. SES shall file documentation supporting conformity with the Secretary of the Commission (Secretary) before the end of the draft EIS/EJR comment period for review and analysis in the final EISIEIR." This proposed provision of additional air quality analysis and identification of necessary mitigation requirements is improperly deferred and should be included within the Draft EISIEIR to allow all interested parties the opportunity to review and comment on the required conformity analysis and any proposed mitigation requirements. Significant information is being deferred, and to do so is to disenfranchise all interested parties from LOlli Beach LNG Import Project DEIS-DElR.EQCB Lcu.r 5 City of Seal Beach Environmental Quality Contl'ol BOaYd Comment Lefttn' ye: "Draft ElSIElR-Long BeachING Imparl pyoject (SCHNo. 2003091130)" FERC Docket No. CP04-58-000, et 01. and POLB Application No. HDP 03-079 A Novembu 30, 2005 _ effective and timely review of and providing comments on this important portion of the Air Quality analysis in 1he Draft EISIEIR. Section 4.9. 7. Health RiskAssessment: This complete section must be revised and updated to include the newly available analysis and conclusions presented in the "2005 Draft Diesel Particulate Matter Exposure Assessment Studyfor the Ports of Los Angeles and Long Beach", as is discussed above. Comments and Concerns re: Section 4.11, Reliability and Safety: A review of the analysis in this section indicates no potential direct impacts to Seal Beach by any of the evaluated "incidents", Although the City is relieved that identified impacts do not directly impact our community, the identified impacts to areas adjacent to the Port facilities, and within the Port facilities are significant and should not be easily brushed aside in the decision-making process. Again, consideration needs to be given to the designation of the Cabrillo Port LNG Deepwater Port project as the "Environmentally Superior" site alternative given the information provided in Section 3 of the subject document. Table 3.2.2-2, Environmental Comparison of the Long Beach LNG Import Project and the Cabril10 Port LNG Deepwater Port clearly indicates that: [J "The consequences of an incid~nt at the proposed facility are potentially less than at an onshore terminal due to the site's more remote location." e For this reason alone it is again recommended by the City of Seal Beach that the subject project be rejected and the "Environmentally Superior" alternative of the Cabrillo Port LNG Deepwater Port project be seriously considered. Section 4.11.5, Siting Requirements - Thermal and Vapor Dispersion Exclusion Zones, subsection Thermal Exclusion Zone. page 4-140 indicates that FERC staff recommends that: "SES sball provide in its comments on tbe draft EISIEIR, or in a separate document submitted at the same time, evidence of its ability to exercise legal control over tbe activities tbat occur within tbe portions of the tbermal radiation exclusion zones that fall outside the site property line that can be built upon." This proposed deferral of necessary property control over adjoining properties that is explicitly required for such a project to proceed is improperly deferred and should be included within the Draft EISIEIR to allow all interested parties the opportunity review and comment on the proposed method of insuring said "legal control over activities that occur within the poytions of the thermal radiation exclusion zones thatfall outside the site pyopeyty line that can be built upon." Significant information is being deferred, and to do so is to e Long Boatb rno Import Prqject DEIS-DEIR EQCB LolIcr 6 e City of Seal Beach Environmental Quality Control BOaYd Comment Letter Ye: "DYaft E1SIE1R - Long BeachLNG Import Project (SCH No. 2003091130)" FERC IJockst No. CP04-58~OO, et aL and POLB Application No. HDP 03-079 Novembu 30, 2005 disenfranchise all interested parties from effectively and timely reviewing and commenting on this important portion of the Reliability and Safety analysis in the Draft EISIEIR Additional Comments on Draft EIS/EIR Document: The City of Seal Beach will now focus its comments on those issues and concerns regarding other environmenta1 issues and concerns not discussed in the previous portions of our comment letter. Section 4.1. GeoloflV: Section 4.1.4.1, Seismic Hazards, on page 4-9, first complete paragraph, indicates that: e "The POLE asked SES to estimate how large an earthquake would be needed to cause the LNG storage tanks to fail. Analyses by ARUP (2005) and Mitsubishi Heavy Industries (2005) estimated that an.earthquake of M9.0 on the Palos Verde fault or M7.5 on the THUMB-HB fault would be necessary to generate ground motions strong enough to rupture the tanks and release their contents. These events have estimated return intervals of approximately 15,000 years and. therefore, are extremely unlikely to occur during the 50-year life of the project The potential impact of an earthquake-induced release from the LNG storage tanks is discussed in Appendix F." On page 4-S, the last sentence of the first paragraph indicates that the "Palos Verdes fault/fault zone and the Newport-Inglewood fault/fault zone were found to be the main contributors to the potential ground motion hazard at the LNG terminal site because of their proximity and relatively high recurrence rates." The "Fault Location Map", Figure 4.1.4-1, indicates the "Palos Verdes Hills fault" and the "Newport-Inglewood" fault. It does indicate the location of~e "THUMS-HBfaulf'. Please clarify the location of the "THUMB-HB fault" on Figure 4.1.4-1 and clarify the language quoted above regarding the potential impacts of what magnitude earthquake on the Newport-Inglewood fault was estimated to be necessary to "generate ground motions strong enough to rupture the tanks and release their contents." We are also requesting information on the estimated last known occurrences of earthquakes on the Palos Verde and the lHUMS-HB fault systems. Section 4.9. Air Oualitv: In addition to the comments above regarding this section, we have the following comments regarding this section of the Draft EISIEIR: e Long Boooh LNG Import Project DEIS-DElR.EQCB Lettor 7 City of Seal Beach Envil"onmental Quality Conti-oJ Boayd Comment Letter re: "D7'aft ElSIElR-Long BeachLNG Impon hoject (SeHNo. 2003091130)" FERC Dockst No. CP04-58-OOO, et al and POLE Application No. HDP 03-079 _ NovembeY 30, 2005 ,., Section 4.9.5. Marine Vessels: The last sentence of the last paragraph indicates that "Except for the Coast Guard escort boats, the diesel engines used in the tugs and pilot boats would be re-powered to EPA Tier 2 Standards through California's Carl Moyer Program." Please indicate which agency will be responsible for this re-powering program and if the necessary funds have already been committed for this re-powering program. The Environmental Quality Control Board (EQCB) considered and discussed the Draft EIS/EIR document on November 30, 2005 and ~uthorized the Chairman to sign this letter indicating the official comments of the City of Seal Beach. Upon the preparation of the Final EISIEIR for this project, please send 4 hard copies and a digital copy, if available, to Mr. Lee Whittenberg, Director of Development Services, City Hall, 211 Eighth Street, Seal Beach, 90740. Thank you for your consideration of the comments of the City of Seal Beach. If you have questions concerning this matter, please do not hesitate to contact Mr. Whittenberg at telephone (562) 431-2527, extension 313, or bye-mail at Iwhittenberg@ci.seal-beach.caus. ~;C- Mario Voce, Chairman Environmenta1 Quality Control Board City of Seal Beach e Distribution: Seal Beach City Council Seal Beach Environmental Quality Control Board City Manager Director of Development Services e Loug Boach LNG Import Projoct DEIS-DEIR EQCB Letter 8 e FIGURE 2.1-1, PROJECT, LOCATION e . Receive and File EQCB Comment utley ye: "Draft ElS/ElR - Long Beach LNG 1mpOYI boject" City Council StaffRepon Decembey 12, 2005 ATTACHMENT 2 LONG BEACH ~PORT GENERAL PROJECT Long Beach LNO Import Project cc Staff Report 9 -- .j - LEGEND NATURAL GAS SENDOUT PIPELINE - - - - C2 PIPELINE ______n ELECTRIC DISTRIBUTION LINES o , 4000 , 8000 FEET I SCALE o DELIVERY POINT AT SOUTHERN CALIFORNIA GAS COMPANY PIPELINE SYSTEM METER STATIONS, ODORIZATJON SYSTEM, PIG LAUNCHERS, AND ELECTRIC SUBSTATION PIG RECEIVER Figure 2.1-1 Long Beach LNG Import Project General Project Location * 1:::.. REFERENCE: USGS 7.5 MINUTE TOPOGRAPHIC QUADRANGLE MAP OF LONG BEACH, CALIFORNIA, DATED 1981, ANO TORRANCE, CALIFORNIA, DATED 1981. 2-2 e Receive and File EQCB Comment Letter re: "Dyaft ElS/ElR - Long Beach LNG Impon hoject" City Council Staff Repon Decembey 12, 2005 ATTACHMENT 3 FIGURE 2.1.1-1, LONG BEACH IMPORT PROJECT, GENERAL SITE LAYOUT e e Long Beach LNG Import PTDJecl CC Staff Report .10 1 l' Q. ~"t'% IOi:<' ~ i;J . c-lC)~ e3~ 'atJ;;G) i!.l~ ~ .;J \ ~ ~ . . i 1:- . i - '. .... &> l- t - z..3 '8 II- ~ ~~ (j) o e Receille and File EQCB Comment Lett.,. ye: "D'aft ElS/EIR - Long Beach LNG 1mpoYI hoject" City Council Staff RepoYt Decemw 12,2005 ATTACHMENT 4 e EXCERPTS OF "DRAFT EIS/EIR - LONG BEACH LNG IMPORT PROJECT (SCH NO. 2003091130)", PREPARED BY THE FEDERAL ENERGY REGULATORY COMMISSION AND THE PORT OF LONG BEACH, DATED OCTOBER 2005 Cl INTRODUCTION BY FEDERAL ENERGY COMMISSION(FERC) AND THE PORT OF LONG BEACH (POLB); Cl TABLE OF CONTENTS, TABLES, FIGURES, ACRONYMS AND ABBREVIATIONS; Cl EXECUTIVE SUMMARY; Cl 1.0-INTRODUCTION; Cl 2.0 - DESCRIPTION OF THE PROPOSED ACTION; Cl 3.0-ALTERNATIVES; Cl 4.9-AIR QUALITY; Cl 4.11- RELIABILITY AND SAFETY; Cl FIGURES FROM CHAPTERS ABOVE; AND Cl APPENDIX F - HAZARDS ANALYSIS OF A PROPOSED LNG IMPORT TERMINAL. IN THE PORT OF LONG BEACH, CALIFORNIA NOTE: PREVIOUSLY PROVIDED TO CITY COUNCIL AND NOT INCLUDED WITH STAFF REPORT DUE TO LENGm OF THE DOCUMENT. A COPY OF THE COMPLETE DRAFT EISIEIR WILL BE AVAILABLE AT THE CITY COUNCn... MEETING FOR REVIEW e Long Beach LNG Import Project.CC StaffRcport II e Receive and File EQCB Comment Lener re: "Dr~ EISlEIR - Long Beach LNG 1m port Project" City Council Staff Report December 12. 2005 ATTACHMENT 5 MISCELLANEOUS DOCUMENTS REGARDING DRAFT EISIEIR AND LNG IN GENERAL: e e [J "ENVIRONMENTAL STUDY ON LNG TERMINAL RELEASED", PORT OF LONG BEACH NEWS RELEASE, OCTOBER 10, 2005 "PUBLIC HEARING SCHEDULE, PROPOSED LNG TERMINAL ENVIRONMENTAL REVIEW PROCESS", PORT OF LONG BEACH "LNG TERMINAL' PROJECT, ENVIRONMENTAL IMPACT REVIEW PROCESS", PORT OF LONG BEACH "ENVIRONMENTAL STUDY ON LNG TERMINAL RELEASED", PORT OF LONG BEACH "LIQUEFIED NATURAL GAS IN CALIFORNIA: mSTORY, RISKS, AND SITING", CALIFORNIA ENERGY COMMISSION STAFF WHITE PAPER, JULY 2003 "SIGNIFICANT EVENTS IN THE mSTORY OF LNG" "WEST COAST LNG PROJECTS", CALIFORNIA ENERGY COMMISSION STAFF, SEPTEMBER 20,2005 "LIQUEFIED NATURAL GAS (LNG)", CALIFORNIA ENERGY COMMISSION, NOVEMBER 8, 2005 "LIQUEFIED NATURAL GAS SAFETY", CALIFORNIA ENERGY COMMISSION, NOVEMBER 8,2005 "DOCUMENTS RELATING TO LIQUEFIED NATURAL GAS", CALIFORNIA ENERGY COMMISSION, NOVEMBER 8,2005 [J [J [J [J [J [J [J [J [J NOTE: PREVIOUSLY PROVIDED TO CITY COUNCIL AND NOT INCLUDED WITH STAFF REPORT DUE TO LENGTH OF THE DOCUMENTS. COPIES WILL BE AVAILABLE AT THE CITY COUNCIL MEETING FOR REVIEW Long Beach LNG Import ProJect CC Staff Report 12