HomeMy WebLinkAboutCC AG PKT 2004-08-09 #L AGENDA.. REPORT -
DATE: August 9; 2004
TO: Honorable Mayor and City Council
THRU: John B. Bahorski, City Manager
FROM: Lee Whittenberg, Director of Development Services
SUBJECT: Receive and File Comment Letter from Environmental
Quality Control Board to Los Angeles Department of Water
and Power re: "Notice of Preparation of Draft
Environmental Impact Report — Haynes Generating Station
Units 5 & 6 Repowering Project ",-Long Beach
SUMMARY OF REQUEST:
Receive and file comment letter from the Environmental Quality Control Board to Los
Angeles Department of Water and Power re: "Notice of Preparation of Draft
Environmental Impact Report — Haynes Generating Station Units 5 & 6 Repowering
Project ", Long Beach. -
BACKGROUND:
On July 28, 2004 the Environmental Quality Control Board (EQCB) received a staff report
and approved a comment letter on the " Notice of Preparation of a Draft Environmental
Impact Report — Haynes Generating Station Units 5 & 6 Repowering Project, Long Beach"
(NOP), prepared by the Los Angeles Department of Water and Power (DWP). The City
comment letter focused on the following issues:
❑ Air Quality
❑ Hydrology & Water Quality
❑ Noise
The EQCB requested additional emphasis be placed on the concerns regarding the following
issues:
❑ lighting impacts, both during construction and long term operations; and
❑ proposed construction activities on Sunday.
The comment letter was revised and signed by the Chairman on July 29, 2004.
Agenda Item L
Z: \My Documents \CEQA \DWP Repowering Project Units 5 & 6.NOP.CC Staff Report doe \LW\01 -2$ -04
Receive and File Comment Letter from om Environmental Quality Control Board re
°Notice of Preparation of Draft Environmental Impact Report —
Haynes Generating Station Units 5 & 6 Repowering Project"
prepared by City of Los Angeles Department of Water and Power
City Council Staff Report
August 9, 2004
Due to comment period deadline on the "NOP ", the City Council did not have an
opportunity to review the comment letter. A copy of the approved EQCB comment letter is
provided,as Attachment 1 for the information of the City Council.
The NOP document serves two purposes:
❑ to solicit information on the scope of the environmental analysis for the proposed
project, and
❑ to notify the public that DWP will prepare a Draft EIR to further assess potential
environmental impacts that may result from implementing the proposed project.
The comment period on the Notice of Preparation closed at 5:00 PM on July 26, 2004. City
staff requested an extension of the comment period until July 29, and that extension request
has been approved by DWP, to allow the EQCB to review the proposed continent at their
July 28 regular meeting. Due to the distance of the proposed project from the City of Seal
Beach, the proposed project may generate environmental impacts within the City of Seal
Beach.
Previous Project Reviews by City:
This project is very similar to the 2002 "Draft EIR - Haynes Generating Station •
Repowering Project" that both the EQCB and City Council devoted significant time to
review and provide comments on. The 2002 project evaluated the replacement of existing
Generator Units 3 and 4 with the same combined -cycle generating system (CCGS) as is
proposed for utilization in the current proposed project. The new COGS, consisting of
Generator Units 8, 9, and 10, is scheduled to be operational in winter of 2005. At that time,
Units 3 and 4 will be removed from service, and their generation capacity will by replaced
the 575 MW CCGS designated as Units 8, 9, and 10. After completion of this project, the
total generating capacity of the facility will be 1619 MW.
Summary of Proposed Action and Environmental Impacts:
Staff has provided as Attachment 2, a complete copy of the Notice of Preparation for the
information of the City Council, which provides an overview of the proposed project, and
the environmental setting, discussion of the various areas of environmental concern and
indication of those areas of envirommental concern to be further analyzed and mitigated in
the Draft EIR.
•
Project Summary:
. Provided below is a brief summary of-the proposed project:
•
DWP proposes to install a new natural gas -fired combined -cycle generating system (CCGS)
at the existing Haynes Generating Station, taking two existing steam boilers out of service,
DWP Repowering Project Units 5 & 6.N0P.CC Staff Report 2 - -
Receive and File Comment Letterf om Environmental Quality Control Board re
"Notice of Prepamtion of Draft Environmental Impact Report —
Haynes Generating Station Units 5 & 6 Repowering Project"
prepared by City of Los Angeles Department of Water and Power
City Council Staff Report
August 9, 2004
and making other changes to accommodate the new units. The new CCGS would include
two combustion gas turbines (CTs), two heat recovery steam generators (HRSGs), a new
steam turbine generator, and associated selective "catalytic reduction (SCR) and carbon
monoxide (CO) catalyst air pollution control equipment. The proposed project will require
the rerouting of the plant's existing once - through cooling water channel circulation system.
However, no modification to this system would occur within either the cooling water
channel (located east of the existing generating station) or the San Gabriel River. The
proposed project would also require the installation of ancillary equipment such as electrical
transformers and switching equipment.
•
SCR would be used to reduce nitrogen oxide (NO emissions as part of DWP's plan to
meet declining facility -wide NO emission limits required by South Coast Air Quality
Management District's (SCAQMD) Regional Clean Air Incentives Market (RECLAIM)
Program.
To accomplish DWP's goal at the earliest possible time and prevent potential, future
exceedances of their RECLAIM annual Allocations, DWP has entered into a "stipulated
order of abatement" with the SCAQMD. The agreement requires that DWP begin
equipment installation and modifications at the Haynes facility to acquire additional
RECLAIM trading credits to ensure compliance with SCAQMD Rule 2004, and for the •
proposed installation of the CCGS with SCR -units to be in use by December 2004.
Proposed Project Description:
The proposed generating units to be installed at the HnGS include two new natural gas -fired
combustion gas turbines (CTs), two new heat recovery steam generators (HRSGs), one
steam turbine generator and • associated pollution control systems. A SCR system is
provided that uses a catalyst to facilitate a reaction between NOx and aqueous ammonia to
• reduce NOx emissions and produce nitrogen and water. A carbon monoxide (CO) catalyst
will also be installed to comply with the SCAQMD's New Source Review (NSR) and Best .
Available Control Technology (BACT) requirements.
CONSTRUCTION
Construction of the proposed project is. scheduled to begin in mid -2005 and continue to the
anticipated operational date in late -2007. Construction activities are anticipated to last
approximately 30 months and take place five days per week, Monday through Friday. To
insure the construction activities stay on schedule, Saturday and Sunday shifts may be
required at times, and two shifts per day are possible at times during the construction period.
Sunday shifts may be required at times to ensure that construction activities stay on
schedule. Approximately 500 workers would be employed during project construction,
although not at the same time. Pile driving activities are anticipated at different phases
throughout the construction process.
3
DWP Repowcring Project Units 5 & 6.NOP.CC Staff Report
- ,
•
• Receive and File Comment Letter from Environmental Quality Control Board re
"Notice of Preparation of Draft Environmental Impact Report —
Haynes Generating Station Units 5 & 6 Repowering Project"
prepared by City of Los Angeles Department of Water and Power
City Council Staff Report
August 9, 2004
OPERATION
The proposed project would require no additional workers for operations. The project could
operate 24 hours per day for 365 days per•year.
Public Availability:
A copy of the Notice of Preparation is available at the Department of Development Services
for review. In addition, the NOP is available at:
❑ DWP Headquarters
111 Hope Street •
Los Angeles
•
❑ Or by calling the DWP's Public Information Center at (213) 367 -0202
•
As indicated above, the City has previously commented on a notice of preparation for
similar facility improvements at the subject property in early 2002. In 2000 the City also
commented on a similar project at the AES Alamitos facility across the San Gabriel River
from the DWP facility. Several of the concerns raised in the both of the previous comment
letters are expressed in the proposed comment letter on the subject NOP.
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 file comment letter from the Environmental Quality Control Board to Los
Angeles Department of Water and Power re: "Notice of Preparation of Draft
Environmental Impact Report — Haynes Generating Station Units 5 & 6 Repowering
Project", Long Beach.
•
•
DWP Repowering Project Units 5 & 6.NOP.CC Staff Report 4
Receive and File Comment Letter _from Environmental Quality Control Board re
"Notice of Preparation ofDraft Environmental Impact Report —
Haynes Generating Station Units 5 & 6 Repowering Project"
•
prepared by City of Los Angeles Department of Water and Power
• City Council Staff Report
August 9, 2004
NOTED AN I APPROVED
•
I 6i
ee Whi enberg John ://: a erski
Director of Development Se ices City / / a n ager
Attachments: (2)
Attachment 1: Environmental Quality Control Board Comment Letter dated
July 28, 2004 re: "Notice of Preparation of Draft
Environmental Impact Report - Haynes Generating Station
Units 5 & 6 Repowering Project ", Long Beach ", prepared
by the Los Angeles City Department of Water and Power
Attachment 2: "Notice of Preparation of Draft Environmental Impact
Report — Haynes Generating Station Units 5 & 6 Repowering
Project ", Long Beach, prepared by the Los Angeles City
Department of Water and Power, dated June 24, 2004
• * * * *
•
•
•
•
DWP Repowering Project Units 5 & 6.NOP.CC Starr Report 5
•
Receive and File Comment Letter from Environmental Quality Control Board re
• "Notice of Preparation of Draft Environmental Impact Report —
Haynes Generating Station Units 5 & 6 Repowering Project"
prepared by City of Los Angeles Department of Water and Power
City Council Staff Report
August 9, 2004
ATTACHMENT 1
ENVIRONMENTAL QUALITY CONTROL
BOARD COMMENT LETTER DATED JULY
28, 2004 RE: "NOTICE OF PREPARATION OF
DRAFT ENVIRONMENTAL IMPACT REPORT
- HAYNES GENERATING STATION UNITS 5
& 6 REPOWERING PROJECT', LONG
BEACH ", PREPARED BY THE LOS
ANGELES CITY DEPARTMENT OF WATER
AND POWER
5
6
DWP Repowering Project Units 5 & 6.NOP.CC Staff Report
Receive and File Comment Letter from Environmental Ouality Control Board re
"Notice of Preparation of Draft Environmental impact Report —
Haynes Generating Station Units 5 & 6 Repowering Project"
prepared by City of Los Angeles Department of Water and Power
City Council Staff Report
August 9, 2004
(ORIGINAL ON CITY LETTERHEAD)
BY FACSIMLE AND FIRST CLASS MAIL
July 28, 2004
Mr. Charles C. Holloway
•
Department of Water and Power
111 North Hope Street, Room 1044
Los Angeles, CA 90012
•
•
SUBJECT: CITY OF SEAL BEACH COMMENTS RE: "NOTICE OF
PREPARATION OF A DRAFT ENVIRONMENTAL
IMPACT REPORT - HAYNES GENERATING STATION
UNITS 5 & 6 REPOWERING PROJECT, LONG BEACH"
Dear Mr. Holloway:
The Environmental Quality Control Board of the City of Seal Beach has reviewed
the above referenced Notice of Preparation (NOP) prepared by the Department of Water
and Power (DWP) and has several comments relative to the document. The proposed
project is close enough to the City of Seal Beach as to cause concern regarding
environmental impacts upon our community, in particular the Leisure World retirement
Community located east of the subject property, on the easterly side of the San Gabriel
River.
The City has previously commented on your previous project involving the
replacement of Generator Units 3 and 4 with similar SCR treatment facilities as part of
modifications to the subject property. The following comments closely parallel the
comments from the City of Seal Beach on the replacement of the Generator Units 3 & 4
project.
DWP Rapowering Project Units 5 B 6.NOP.CC Staff Report
•
Receive and File Comment Letter from Environmental Duality Control Board re
"Notice of Preparation of Draft Environmental Impact Report —
Haynes Generating Station Units 5 & 6 Repowering Project"
prepared by City of Los Angeles Department of Water and Power
City Council Staff Report .
August 9, 2004
It is of extreme concem that the impacts of the proposed project, along with the
• cumulative impacts of the AES Alamitos project and the Haynes Units 3 & Repowering
Project, are fully discussed, evaluated, and mitigated in the areas of concern discussed
below, particularly in regards to the community of Leisure World. It is the opinion of our
Director of Development Services 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. -
Following are specific concerns of the City of Seal Beach that should be analyzed,
discussed, and appropriately mitigated in the Draft EIR:
Air Oualigr:
The discussion on pages 19 -20 indicates that NO emissions are to be
reduced to comply with the annual NOx Regional Clean Air Incentives •
Market (RECLAIM) allocation. This overall air quality benefit is supported
and should be quantified and discussed thoroughly within the Draft EIR,
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 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. 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
concems.
There is no indication as to what the annual one -hour maximum ground
concentration for ammonia slip is anticipated to be for the proposed project. -
' This information, along with an analysis as to where ground level
concentrations are anticipated to occur at, needs to be presented and
evaluated for adverse enviromnental impacts. Will significant ground level
concentrations of ammonia exist on the Haynes facility or on the adjoining
AES Alamitos facility? If on the subject or adjoining or nearby properties,
those should be indicated by the use of a map.
It is indicated on page 20 that a health risk assessment will be performed to •
• determine the human health impacts of the proposed project. This analysis
needs to include a "cumulative" analysis section performed for the combined
air emissions, including ammonia emissions from all proposed SCR units at
DWP Repowering Project Units 5 8 6 NOP.CC Staff Report 8
Receive and File Comment Letterfiom Environmental Quality Control Board re
"Notice of Preparation of Draft Environmental Impact Report —
Haynes .Generating Station Units 5 & 6Repowering Project"
prepared by City of Los Angeles Department of Water and Power
City Council Staff Report
August 9, 2004
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 Draft EIR document, permitting the
interested public to review and comment as to the adequacy of the health risk
and risk management documents. The specific health risk assessment issues
relating to an elderly, retirement community population of 8,300 persons,
should be particularly discussed in this portion of the Draft EIR.
Geology:
The discussion on page 14 of the NOP indicates the existence of a document
titled "Los Angeles Department of Water and Power, Risk Management
Plan, Ammonia Storage .and Supply System, Haynes Generating Station ",
dated June 1999. Does this document include risk management programs
for the proposed project facilities? IF not, the document should be updated
and the information within the updated document should be evaluated within
the context of the subject DEIR. In addition, the City of Seal Beach would
request a copy of the referenced 1999 report and any updates to that
document that may be prepared in the future. It is important to our
emergency response providers to be aware of the potential risks and the
management actions and programs in place at the Haynes facility to respond
to potential risk and upset situations.
Hydrology and Water Quality:
The discussion on pages 30 -32 indicates "The HnGS operates under a
National Pollution Discharge Elimination System ( NPDES) permit issued
by the RWQCB for the discharge of water, including generator unit once-
- through cooling water and various in plant waste streams. The current
NPDES permit contains effluent objectives for discharged water at IInGS
under the Water Quality Control Plan for the Ocean Waters of California
(Ocean Plan) and temperature objectives for discharged water under the
Water Quality Control Plan for Control of Temperature in the Coastal and
Interstate Waters and Enclosed Bay and Estuaries of California (Thermal
Plan).
The discussion in the NOP indicates that `further evaluation of potentially
significant impacts to marine water quality related to the intake and
discharge of cooling waters will be conducted in the EIR."
This discussion and evaluation should provide a particular focus to those
pollutants and stressors identified for the "San Gabriel River Estuary" and
"San Gabriel- River Reach 1 (Estuary to Firestone)" as identified on the
9
DWP Repowenng Project Units 5 & 6.NOP.CC Staff Report
Receive and File Comment Letterrom Environmental Quality Control Board re
"Notice of Preparation of Draft Environmental Impact Report —
Haynes Generating Station Units 5 & 6 Repowering Project"
prepared by City of Los Angeles Department of Water and Power
City Council Staff Report
August 9, 2004
"2002 CWA Section 303(d) List of Water Quality Limited Segment, Los
Angeles Regional Water Quality Control Board" and as approved by the
United States Environmental Protection Agency in July 2003. A copy of
page 44 of that listing is provided for your information as Exhibit A of this
letter. Those identified pollutants and stressors for the identified areas of the
San Gabriel River, as indicated on page 44 of the listing, are:
❑ Abnormal Fish Histology — Estuary and Reach 1
❑ Algae — Reach 1
❑ High Coliform Count — Reach 1 •
❑ Toxicity — Reach 1
The City looks forward to reviewing this analysis and requests that this
analysis also include conformity discussion with the appropriate -
requirements of the Los Angeles and Santa Ana Regional Water Quality
Control Boards. It is our understanding that the jurisdictions of both of these
regional boards is impacted by the intake and discharge portions of the
power plant operation. The analysis should include conformity with the
recent rules and regional permits approved and proposed by each of these
•
boards.
In addition, the Initial Study. Checklist does not discuss a number of issues •
that are now required to be considered and evaluated in conformance with
the applicable Regional Water Quality Control Board permit requirements,
in particular the Santa Ana Region requirements. The additional items for
consideration in the Draft Environmental impact Report that have not been
•
presented are:
❑ Potentially impact stormwater runoff from construction activities? •
❑ Potentially impact stormwater runoff from post - construction
activities?
❑ Result in a potential for discharge of stormwater pollutants from
• areas of material storage, vehicle or equipment fueling, vehicle or
equipment maintenance (including washing), waste handling,
• hazardous materials handling or storage, delivery areas, loading
docks or other outdoor work areas?
❑ Result in the potential for discharge of stormwater to affect the
beneficial uses of receiving waters?
❑ Create the potential for significant changes in the flow velocity or
volume of stonmwater runoff to cause enviromnental harm?
❑ Create significant increases in erosion of the project site or
surrounding areas?
The City of Seal Beach requests that the DEIR discuss and evaluate each of •
these areas of concern.
DWP Repowering Project Units 5 & 6.NOP.CC Staff Report 10
Receive and File Comment Letterfrom Environmental Quality Control Board re
• "Notice of Preparation of Draft Environmental Impact Report—
_ Haynes Generating Station Units 5 & 6 Repowering Project"
prepared by City of Los Angeles Department of Water and Power
City Council Staff Report
August 9, 2004
The City would also like to go on record as supporting the conducting of
an updated "entrainment study" when the NPDES permit for the Haynes
Generating Station is under renewal consideration by the Los Angeles
Regional Water Quality Control Board and /or the Coastal Commission.
•
•
Noise:
The NOP at pages 34 and 35 indicates that noise and groundborne vibration
issues will be discussed within the Draft EIR. The City of Seal Beach is
concemed that the public have an opportunity to review and comment as to
the potential noise and vibration impacts and the ability of any proposed
mitigation measures to reduce any additional noise and vibration generating
sources to a less than significant level. The City of Seal Beach concurs that
the Draft EIR should include a noise and groundborne vibration 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. •
The project description indicates that:
❑ Construction activities are anticipated to last approximately 30
months and take place five days per week, Monday through Friday.
❑ To insure the construction activities stay on schedule, Saturday and
Sunday shifts may be required at times, and two shifts per day are
possible at times during the construction period to ensure that
construction activities stay on schedule.
❑ Approximately 500 workers would be employed during project
construction, although not at the same time.
❑ Pile driving activities are anticipated at different phases throughout
the construction process.
•
This type of construction schedule and the resultant noise, groundbome
vibration and night - lighting impacts needs to be thoroughly analyzed and
mitigated within the Draft EIR. 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 Sundays. Analysis of
impacts to the. adjoining residential communities of Leisure World and
Island Village of extended construction hours and Sunday construction
activities need to be specifically presented within the Draft EIR.
• - The City clearly recognizes the actions taken by DWP to alleviate
construction noise impacts within Leisure World as part of the replacement
DWP Repoweting Project Units 5 8: 6.NOP.CC Staff Report 11 _
•
Receive and File Comment Letter from Environmental Quality Control Board re
"Notice of Preparation of Draft Environmental Impact Report —
Haynes Generating Station Units 5 & 6 Repowering Project"
• prepared by City of Los Angeles Department of Water and Power
City Council Staff Report
August 9, 2009
•
of Generator Units 3 and 4 and anticipates the implementation of the same
mitigation measures, if determined appropriate based on the environmental
analysis, as part of this project.
The Initial Study indicates there would be "Less Than Significant Impact" or "No
Impact" to `Aesthetics ", "Hazards and Hazardous Materials" and "Public Services ". The
City is concerned that the public will have no opportunity to review and comment as to
potential impacts upon certain aesthetic, emergency service, and health - related concerns that
may be created by the proposed project. The City of Seal Beach concerns regarding these
environmental impact issues are set forth below:
Aesthetics:
The Draft EIR should discuss the potential light and glare related issues
regarding additional light sources, both temporary and permanent, upon
landing activities related to Long Beach Airport. It appears that the subject
facility is located In close proximity to the general landing corridor for ,
flights into Long Beach Airport. This issue needs to be evaluated and
mitigated, if necessary, within the Draft EIR document. In addition, the
impacts of lighting, both during construction and long -term operations, need
to be evaluated for impacts upon the Leisure World residential community.
The impacts of spill -over lighting and glare impacts are of particular
concern.
Public Services:
The Draft EIR should discuss and evaluate the ability of emergency service
providers to adequately respond to an emergency situation at the revised
facility. 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 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 analysis should also include a cumulative impact discussion of the
potential impacts to emergency responders from both the AES Alamitos and
Haynes facilities.
12
DW P Repowering Project Units 5 & 6.NOP.CC Staff Report
•
Receive and File Comment Letter from Environmental Quality Control Board re
"'Notice of Preparation of Draft Environmental Impact Report-
- Haynes Generating Station Units 5 & 6 Repowering Project"
prepared by City of Los Angeles Department of Water and Power
City Council Staff Report
August 9, 2004
Hazards and Hazardous Materials:
The discussion relates to general risk of upset/human health impacts of
.. transportation of aqueous ammonia from various potential locations within
the region to the subject site. It is recommended that the specific
transportation routes be indicated within the Draft EIR. This would allow
easier review and comments from interested individuals or organizations
regarding this specific area of concern.
There should be discussion 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 contaimment system.
As was indicated in the 1993 SEIR for the AES Alamitos facility, the worst-
case population exposure to the 100 ppm ammonia irritation level for a
complete containment facility failure was 2,070 persons. It is assumed that
an increased level of exposure would now be created, and that a portion of
this exposed population is located in Seal Beach, and most probably within
Leisure World. The new analysis should include a map presentation of the
area impacted by the modeled dispersion at the 100 ppm level, to allow both
the City of Long Beach and the City of Seal Beach to be more fully informed
as to potential impacts upon their_ respective residents. In the case of Seal
Beach, there is a heightened level of concern, since the Leisure World
community. - comprises approximately 8,300 residents, with approximately
90% being over the age of 65. It is a concern to the City as to how the levels
of ammonia being discussed could impact this population group, particularly
those individuals with respiratory or other related health concerns. This
•
discussion should also provide information as to the nearest responding
emergency service unit locations, estimated response times, and potential
impact upon the capabilities of emergency medical response to meet the
demands placed upon the emergency medical response system by a large
amount of emergency calls from impacted persons.
The 1993 SEIR for the AES Alamitos facility also indicated that the worst -
case population exposure to the 100 ppm ammonia irritation level is 5,020
resulting from a transportation spill and a complete containment. failure,
based upon analysis prepared for the Redondo Station. .
•
_
DWP Repowering Project Units 5 & 6.NOP.CC Staff Report 13 -
Receive and File Comment Letter from Environmental Quality Control Board re
"Notice of Preparation of Draft Environmental Impact Report —
Havnes Generating Station Units 5 & 6 Repowering Project"
prepared by City of Los Angeles Department of Water and Power
City Council Staff Report
August 9, 2004
The DEIR should indicate the transportation routes that will be utilized to
transport the aqueous ammonia from anticipated suppliers to the Haynes
Generating Station. The 1993 SEIR indicated that most of the anticipated
suppliers are located to the north or east. In order to eliminate potential
impacts to the Leisure World community, it is recommended that all truck
transport of aqueous ammonia utilize the Route 405 /605 /Studebaker Road
access locations to serve the generating station, with no deliveries occurring -
along Pacific Coast Highway, Westminster Avenue or Seal Beach
Boulevard. It is also requested that local fire and police departments, both
Long Beach and Seal Beach, be informed 24 -hours prior to shipment,
including routing information.
If truck transport will occur within Seal Beach, it is assumed that a portion of
this exposed population is located in Seal Beach, and most probably within
Leisure World. The DEIR analysis should include a presentation of the area
impacted by the modeled dispersion at the 100 ppm level, to allow both the
City of Long Beach and the City of Seal Beach to be more fully informed as
to potential impacts upon their respective residents. In the case of Seal
Beach, there is a heightened level of concern, since the Leisure World
community comprises approximately 8,300 residents, with approximately
90% being over the age of 65. It is a concern to the City as to how the levels
of ammonia being utilized could impact this population group, particularly
those individuals with respiratory or other related health concerns. This .
discussion should also provide information as to the nearest responding
emergency service unit locations, estimated response times, and potential
impact upon the capabilities of emergency medical response to meet the
demands placed upon the emergency medical response system by a large
amount of emergency calls from impacted persons. Discussion should also
be provided as to the types of anticipated human health problems to be
anticipated assuming exposure of a large elderly population.
The Draft EIR is required to evaluate other projects that may have cumulative
impacts upon the environment, in conjunction with the proposed project. The City of Long
Beach has recently released a "Notice of Preparation - Draft Environmental Impact Report
— Long' Beach Home Depot ". This document indicates the City of Long Beach will prepare
a draft Environmental Impact Report (DEIR), evaluating the potential environmental
impacts of a proposed mixed -use project that will consist of the following major project
components:
❑ 191,529 square feet of mixed -use retail - commercial uses on approximately 16.5
acres; the development will comprise 4 different building pads ranging from
approximately 9,050 to 139,500 square feet as follows:
❑ A 104,886 square foot Horne .Depot store with a 34,643 square foot garden
center;
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14
DWP Repowering Project Units 5 & 6.NOP.CC Staff Report
•
Receive and File Comment Letterfram Environmental Quality Control Board re
`Notice of Preparation of Draft Environmental Impact Report
Haynes Generating Station Units 5 & 6 Repowering Project` •
prepared by City of Los Angeles Department of Water and Power
City Council Staff Report
August 9, 2004
❑ A 7,000 square foot sit down restaurant with 2,050 square foot outdoor eating
area;
❑ A 30,000 square foot major retail building; and
❑ A 15,000 square foot retail building.
The cumulative environmental impacts of this project, along with other projects that
may be identified need to thoroughly identified, evaluated, and mitigated in the Draft EIR on
the Haynes Units 5 & 6 Repowering Project.
The Environmental Quality Control Board (EQCB) considered and discussed the
NOP document on July 28, 2004. The EQCB authorized the Vice - 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 hard copies and
a digital copy, if available, to Mr. Lee Whittenberg, Director of Development Services, City
Hall, 211 Eighth Street, Seal Beach, 90740. Thank you for your consideration of the
comments of the City of Seal Beach. If you have questions concerning this matter, please
do not hesitate to contact Mr. Whittenberg at telephone (562) 431 -2527, extension 313, or
by e -mail at lhittenberg@ci.seal-beach.ca.us.
•
Sincerely,
/J
Mario Voce
Chairman, Environmental Quality Control Board
City of Seal Beach
Exhibit A: "2002 CWA Section 303(d) List of Water Quality Limited Segment, Los
Angeles Regional Water Quality Control Board", page 44 of 53
• Distribution:
• Seal Beach City Council Seal Beach Planning Commission
City Manager Director of Development Service
Golden Rain Foundation City of Long Beach
•
- • -r ° <
DW P Repowering Project Units 5 & 6.NOP.CC Staff Report 1 5
Receive and File Comment Letter from Environmental Quality Control Board re
"Notice of Preparation of Draft Environmental Impact Report —
Haynes Generating Station Units 5 & 6 Repdwering Project"
prepared by City of Los Angeles Department of Water and Power
City Council Staff Report
August 9, 2004
EXHIBIT A
"2002 CWA SECTION 303(D) LIST OF WATER
QUALITY LIMITED SEGMENT, LOS
ANGELES REGIONAL WATER QUALITY
• CONTROL BOARD ", PAGE 44 OF 53
•
•
16
DWP Repowering Project Units 5 & 6.NOP.CC Staff Report
, •
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. •
Receive and File Comment Letter from Environmental Quality Control Board re
"Notice of Preparation of Draft Environmental Impact Report —
Haynes Generating Station Units 5 & 6 Repowering Project"
prepared by City of Los Angeles Department of Water and Power
City Council Staff Report
August9, 2004
•
ATTACHMENT 2
"NOTICE OF PREPARATION OF DRAFT
ENVIRONMENTAL IMPACT REPORT —
HAYNES GENERATING STATION UNITS 5 &
6 REPOWERING PROJECT', LONG BEACH,
•
• PREPARED BY THE LOS ANGELES CITY
DEPARTMENT OF WATER AND POWER,
DATED JUNE 24, 2004
•
Note: Document not available in a digital •
format. A copy is available at the Department
of Development Services, City Hall, 211 Eighth
Street, Seal Beach
•
•
•
•
•
DWP Repowering Project Units 5 & 6.NOP.CC Staff Report 17