CRB - CITY OF REDONDO BEACH
CRB-0.
The Initial Study systematically analyzed potential impacts from the proposed divestiture of each power plant on the environment. The Initial Study used the environmental checklist provided in the CEQA Guidelines Appendix I. All reasonably foreseeable effects of the divestiture were analyzed and where environmental effects were found to be potentially significant, mitigation measures were incorporated. It is noted that the City does not request that the CPUC determine that an EIR be required for the project.
The Mitigated Negative Declaration/Initial Study was submitted to the State Clearinghouse on August 26, 1997 and received a schedule number of 97081067. The CPUC was notified on September 26, 1997 that this CEQA requirement has been met. With respect to notifying appropriate Councils of Government, as noted in the Mitigated Negative Declaration, the San Bernardino County Association of Governments, the South Bay Association of Governments, and the Los Angeles Regional County Planning Department were notified. Also, in addition to the parties listed on pages 6.4 through 6.13 of the Initial Study, every municipality within 10 miles of each power station was similarly notified, as were property owners and occupants within 300 feet of each power station. Through these contacts, the CEQA requirement mentioned by the commentor was satisfied.
As mentioned in response to CRB-0, the environmental checklist provided in the CEQA Guidelines, Appendix I, was used in the Initial Study. Some of the four items (a-d) listed in CRB-2 are described in detail in other subsequent comments provided by the City as follows:
a. Conflict with adopted environmental plans and goals. This comment is addressed in response to CRB-9.
b. Fuel and Water. Fuel usage was discussed on page 4.8.2 of the Initial Study: "Divestiture does not conflict with any adopted energy conservation plans. Therefore, this would be a less-than-significant impact." Also on page 4.8.3, the Initial Study concluded, "The increased use of energy resources that could result from divestiture is likely to be less wasteful or inefficient. This impact is less than significant."
Water usage was discussed on 4.4.46 of the Initial Study: "The project would not substantially affect surface water quantity at either the coastal or inland plants, or regionally. Therefore, the project impact would be less than significant." On page 4.4.47 the Initial Study states, "The project could result in additional groundwater extractions from the Upper Santa Ana River and Lower Mojave River basins. However, these extractions would be required by water rights judgments to be replaced by imported surface waters. Therefore, no significant impact would be expected." Also, on page 4.4.49 the Initial Study states, "The project could require additional groundwater extractions from the Upper Santa Ana River and Lower Mojave River basins. These extractions could affect groundwater quality and water levels in the basin but would be offset by imported water as stipulated in water rights judgments. No significant impacts are anticipated."
c. Noise levels. This comment is addressed in response to CRB-11 below.
d. Hazards. This comment is addressed in response to CRB-11 below.
The comment refers to mitigation measure 4.14.a.1, which applies only to the Cool Water power plant. Please see revisions to mitigation measure 4.14.a.1 in Section IV of this report, Text Changes.
Please see response to CCC-2. Note that the costs of remediation are not relevant to CEQA environmental analysis. Such costs are being considered by the CPUC in its Edison divestiture proceeding (A.96-11-046).
As indicated on page 4.9.13 of the Initial Study, the Phase I and Phase II reports were completed for the Redondo Power Plant. Information in these reports was used and factored into the Mitigated Negative Declaration/Initial Study. The commentor indicates that "elsewhere in the document" the document contradicts text on 4.9.13. We are unable to locate such text within the Initial Study.
To reflect the City's information, on page 2.8 (Section 2) of the Initial Study, the third sentence of the first full paragraph is revised as follows:
At Redondo, Edison will either sell the entire property, retaining easements and the transmission facilities, if the lot line adjustment is not approved prior to the auction, or if approved, divide the property as proposed in the lot line adjustment application.
To reflect the City's clarification, the last sentence of paragraph 2, page 4.1.7 is revised as follows:
Although the generation plant falls within the City's Coastal Zone, the Harbor/Civic Center Specific Plan serves as the area's local coastal plan.The project site is within the California Coastal Commission's Coastal Zone. The City does not have a fully certified Local Coastal Plan; therefore, the Coastal Commission retains permitting authority for land use changes at the plant.
Public Utilities Code Section 377 removes much of the CPUC’s regulatory authority over utility generation plants after these plants are market valued—an event mandated by AB 1890 even if divestiture does not occur. While it is true that local agencies would be the "lead agencies" for CEQA review of most future site improvements, most of the "permitting activities related to site planning, site improvements, building construction, and hazardous materials handling" are already handled by agencies other than the CPUC. Thus, divestiture would not have a significant impact on the economics of local permitting agencies. Rather than shifting regulatory authority, removing the CPUC from the regulatory regime over power plants merely gives way to the extensive existing regulatory authority of other federal, state and local agencies with permitting authority, such as the California Energy Commission, the California Department of Toxic Substances Control, and the Air Pollution Control Districts.
Edison intends to continue pursuing partitioning of the property. As noted on page 4.1.17, the sale of the property would not involve a substantial adverse change in physical conditions, either directly or indirectly, and no substantial land use or zoning conflicts would occur. While it is possible that the City of Redondo Beach Planning Commission and City Council could determine that the newly-created parcel would be inconsistent with the General Plan or zoning designation, it appears that the continued use of the land for fuel oil storage would be consistent with the P-GP use designation.
No new studies or analyses were performed after the issuance of the Draft Initial Study. As sought by the CPUC in offering the Draft Initial Study for review, the CPUC received many written comments about the electrical system operation after divestiture. Refinement and clarification of the CPUC's assessment (in part based on these comments) was presented in Section 3 of the completed Initial Study.
There is a great deal of uncertainty in the new energy market that makes it speculative to predict the specific increase in generation at any one divested plant (see pages 3.3 - 3.6 of Initial Study). Furthermore, the project analysis has indicated that divestiture would result in only a tendency for the new owners to operate more and not that the plants would operate at maximum capacity. The Initial Study and the evidence in the record, do not support the commentor's statement that "Any increase in operation will result in significant, quantifiable environmental effects" and that significant impacts would occur on noise, fish populations, air emissions, and hazardous materials as a result of implementation of the project. The EIR for the merger of Southern California Edison and San Diego Gas and Electric was reviewed and its analyses considered, during the preparation of the Initial Study for this project. However, an independent analysis was conducted for the proposed divestiture which made the following conclusions (summarized from the Initial Study):
Noise. Increased operations could result in relatively small noise level increases at some locations; these would not be significant. The frequency of automatic relief valves activating may increase with increased operation, but it would not be a constant occurrence and would not be anticipated to expose sensitive receptors to severe noise levels (see Section 4.10 of the Initial Study).
Fish Populations. No substantial changes are anticipated in cooling water intake and discharge levels and all plants would be required to continue to operate under permit conditions established by the Regional Water Quality Control Board. Minor changes in intake volumes and discharge quantity and quality may occur within permit conditions, which may have minor effects on fisheries but would not be considered significant (see Section 4.7 of the Initial Study).
Air Emissions. For the Redondo Plant, any increases in NOx emissions would be offset by the South Coast Air Quality Management District's RECLAIM policy (see Section 4.5 of the Initial Study).
Transportation and Storage of Hazardous Materials. Increases in plant operation could increase the use and generation of hazardous materials. However, new owners would be required to comply with all worker and public safety laws and regulations and hazardous materials regulatory requirements. The project would not substantially affect emergency response or evacuation plans. The impacts are not anticipated to be significant (see Section 4.9 of the Initial Study).
The Initial Study does address the effects of land division for each facility proposed to be divested that involves parcelization. Edison desires to retain portions of the Redondo Beach property and divest other portions, as shown in Figure 2.25 of the Initial Study. Edison has submitted a lot line adjustment application and apparently wishes to continue pursuing partitioning of the property. Should the lot line adjustment not be approved before the auction, Edison proposes to retain certain parcels that are currently legal lots and require no lot line adjustment (see response to E-9, which presents a new map submitted by Edison subsequent to publishing the Initial Study showing legal parcels to be retained in the event the lot line adjustment is not approved prior to the auction).
As noted on page 4.6.4 of the Initial Study, current conditions for access and traffic circulation would not change because Edison would require as part of the conditions of the sale agreement that the new owner of divested properties allow access to Edison, and Edison would allow access through its retained properties to new owners of divested facilities. Similarly, public infrastructure needs would not change because of the reparcelization, since the uses on the properties would remain the same. Please see response to CRB-9 with respect to General Plan and zoning consistency.
No alternatives to the project were considered because the CPUC determined there are no significant impacts that cannot be mitigated to less-than-significant levels. In general, lead agencies must consider alternatives to the project only when an Environmental Impact Report is conducted. As noted in the Initial Study, the CPUC assumed in its CEQA review that: the divested plants will continue to operate, within the parameters of their existing permits (page 3.5); the incentives to retire or repower a given plant would be the same whether it is owned by Edison or a new owner (page C.16); and a decision by the new owner to repower the facility would trigger a "new source review" at the applicable air quality agencies, as well as a permitting process at the California Energy Commission if the repowering would increase capacity at the plant by more than 49 megawatts (MW) (page 3.2), and/or possibly approval by local permitting bodies. As discussed in Attachment C, Section 3.4 on page C.16 of the Initial Study, the decision to repower a generation facility is unlikely to be affected by divestiture over the next decade. Even though the existing owners and new owners may see different incentives and constraints on their actions in the restructured industry, these are not sufficient to create substantially different incentives for repowering these plants during that period.
To provide further clarification concerning the possible impacts of future repowering, the sixth sentence of the first paragraph of page 3.2 is revised as follows:
With that exception, however, expansion or repowering of facilities at the plants would require issuance of new permits and accompanying environmental review by the CEC. Regardless of CEC jurisdiction any plant expansion would require other permits and environmental reviews such as new construction permits or new source review by the affected air agencies.
In reference to noise, see response to CRB-11.
Please see response to CRB-13.
Comment noted.
Table 4.16-1 is amended to include the following additional local community projects near the Redondo Beach Generating Station. These projects were identified in the City’s comments and in a telephone conversation between Aaron Jones of the City and Richard Masters of ESA on October 7, 1997.
| 811-819 North Catalina Avenue | Catalina Technology Center, 293,000 sq. ft mixed use immediately east of the plant. Includes 20,000 sq. ft of Retail/Commercial, 40,000 Business Office, 40,000 Incubator, Industrial, and 100,000 mini storage, due to start construction November, 1997 |
| East of Edison plant, across Gertruda Street | Condorian Theater Project; 50,000 sq. ft, 13-16 screens, 2,500-3,000 seat cinema with 15,000 sq. ft of retail/restaurant |
| 260 Portofino Way | Portofino Hotel, addition of conference and banquette rooms |
| 300 N. Harbor Drive | Crown Plaza Hotel, 21 room expansion |
The analyses and conclusions of cumulative impacts with local community projects described on pages 4.16.12 through 4.16.15 remain unchanged.
The third sentence of the first paragraph on page 4.9.6 is revised as follows:
Redondo power plant has a hazardous waste storage area, six aboveground storage tanks, one underground aqueous ammonia storage tank, two underground storage tanks, (one containing unleaded gasoline, and the other containing diesel fuel), one resin tank, three retention basins, one transformer switch yards, and eight generating units that could be sources of contamination.
Although there is no significant impact requiring mitigation, Edison has agreed to incorporate the suggested measure into the project. Therefore, the next to last paragraph on page 4.9.7 of the Initial Study is revised as follows:
Edison has agreed to provide any new owners with all of Edison's informational materials and training documents related to worker health and safety and to hazardous materials handling and storage.Although the impact is not significant, the following mitigation measure will reduce any potential accidental risks to even lower levels:
Mitigation Measure
4.9.a.1 For the plants subject to this proceeding Edison shall provide the new owner, for each respective plant, with all of Edison's material, non-privileged informational materials and training documents (not including records relating to Edison personnel) regarding worker health and safety, emergency plans and hazardous materials handling and storage. Although the new owners will be responsible for ensuring that their operations are in compliance with applicable laws, this informational material may assist new owners in understanding worker health and safety issues and procedures and in meeting all safety and legal obligations regarding hazardous materials handling, emergency plans and storage.
Monitoring Action: Edison will provide the CPUC mitigation monitor with a disclosure form signed by the new owner listing documents to accomplish this condition
Responsibility: CPUC
Timing: At least 3 business days prior to transfer of title of the plant(s).
Mitigation measure 4.9.a.1 is also added to the Mitigated Negative Declaration.
The last paragraph on page 4.9.7 is revised as follows:
Under divestiture, any new owner would be required to comply with all worker and public safety laws and regulations, just as is the case for Edison now. Furthermore, Edison will provide each new owner with information about Edison's operating procedures and compliance plans. Because of these laws and circumstances, this potential impact of the project would be less than significant. Nonetheless, the above mitigation measure will assist new owners in complying with pertinent laws and regulations.
As noted on page 4.6.4 of the Initial Study, there would be no change from current conditions for access because Edison would require as part of the conditions of the sale agreement that the new owner of divested properties allow access to Edison, and Edison would allow access through its retained properties to new owners of divested facilities. As noted on page 4.9.8, the emergency response plan will need to be updated by the new owners and the update would logically note the access situation. These conditions are part of the project, so a mitigation measure is not needed.
The referenced sentence on page 4.10.3 was intended to be a general statement of the approximate impact area/distance for consistency with ordinance standards and community response. At specific locations, the plant generated sound level is dependent on various factors including the noise spectrum, the terrain and intervening buildings (if any) and the weather conditions. The community response is dependent on the noise level, noise character, background noise, type of receptor, community history and individual sensitivities.
Concerning the location of Pacific Coast Highway with respect to the Redondo Generating Station and receptors, reference to a city map and the site plan indicate that the highway is approximately 0.15 miles from the plant. Sensitive receptors in the area include residential buildings on North Elena (Robey, 1997); this roadway is approximately 0.025 to 0.2 miles from the Pacific Coast Highway. The highway is 0.35 miles from the sound measurement location at the residential facility on Herondo Street at Monterey Boulevard. Moreover, highway noise is generally audible over a fairly wide corridor. Please refer to the response to CRB-20.
It is true that noise complaints can occur to receptors farther than 0.5 miles from stationary noise sources, however the Redondo Beach power plant is not currently generating complaints from such distances and the divestiture of the plant would not reasonably be expected to change operations to the degree to generate noise complaints from such distances.
The wall referred to (discussed in the first paragraph on Page 4.10.9) is approximately 10 feet tall, based on inspection and on information provided by Paul S. Veneklasen & Associates, a consultant to Edison that conducted surveys of the Redondo plant and the surrounding community (Robey, 1997). This particular wall is along Herondo Street and is across the street from the multifamily complex where the sound measurement was made.
This measurement was taken along Herondo Street at Monterey Boulevard. The location was selected as being the nearest evident sensitive receptor, which was multifamily development, to the plant. As noted in the comment, the measurement location was in Hermosa Beach.
The City of Hermosa Beach noise ordinance specifies a maximum level for steady noise at multifamily land use of 55 dBA for daytime and 50 dBA for nighttime, with adjustments for noise character as judged by the enforcing officer and also adjustment for background noise. The measured sound level obtained from the sample taken along Herondo Street appeared to be in compliance with local noise standards.
As noted in the first paragraph on page 4.10.10 of the Initial Study, there is no documentation that the facility is not in compliance with the noise ordinance and no evidence to suggest that any current background noise levels above noise ordinance standards are attributable to the power plant. In any event, given that a trial court has ruled that the noise ordinance is too difficult to interpret and enforce, a determination of compliance may not be an appropriate measure of the project's noise effects. Comprehensive acoustic analyses have been done for the Redondo Beach power plant. Study reports include in part: a Wyle Laboratories report of March, 1991; and a report by Paul S. Veneklasen & Associates of November 12, 1996. Neither a review of these reports nor the current noise study conducted as part of the Initial Study (second paragraph, page 4.10.10) indicate ongoing community noise effects from the power plant.
As reported by Khosrovani (1996), Edison has agreed to maintain the noise levels on the property line of the plant to a level of 64 dBA or below (see page 4.10.9 of the Initial Study). This level thus serves as a baseline and reference value to evaluate the effect of noise control methods applied. Edison has applied a number of methods to achieve this noise level on the property lines of the site. These methods include active noise suppression systems for inlets of Forced Draft fans of units 7 and 8 and noise control enclosures around the fan housings, equipment enclosures, barriers, valve change-out and pipe lagging systems. These noise reduction techniques have reduced the noise levels from 72 dBA to 63 dBA at the existing east fence lines of the site which is the most sensitive of all segments of the fence lines. This would generally be considered to represent a reduction in loudness of nearly 50 percent.
It appears from the information provided that appropriate and "best available" methods have been applied to control the Redondo Beach plant noise. Information received related to this issue indicates that the plant is currently in compliance with the "informal" standard of 64 dBA at the east property line (George, 1997).
As described on page 4.11.6, it is not known if the new owner would or would not provide security services. Also, as described in the Initial Study, it is anticipated that if no private security were provided, any demand for police services would be low and that no significant impact would occur. There is no basis to conclude otherwise. In any event, even if the facility has private security services, the services of police can still be required at times and the local police are still responsible for serving the site.
With or without divestiture, it is possible that the plant would generate more electricity and more employees could be added to the plant. Although identifying a specific number of new employees would be speculative, the growth in wastewater flows from the additional sewage generated by a few new employees, if any, would be unnoticeable to the wastewater collection system. Since the project itself would not generate incremental impacts to the system, it would not have cumulative effects when considered in light of the other projects mentioned by the commentor.
With the exception of adding fences to proposed parcel boundaries internal to the plant, the proposed project will add no new structures and will not change any views. The following information is added to the end of the last paragraph on page 4.13.6 of the Initial Study:
In views from the east, the site is visually compatible with surrounding industrial uses. The station facilities and transmission lines dominate the background of southwesterly views from uphill areas along Herondo Street. The City of Redondo Beach has noted that nearly all of the industrial uses to the east of the plant will be redeveloped. The City considers the view of the plant to be incompatible with the community and destructive to the scenic vista of the harbor. However, with the exception of fences to proposed parcel boundaries internal to the plant, the proposed project will add no new structures and will not change any views. Therefore, the project will generate no significant visual impacts.
As discussed in Section 3 of the Initial Study, the continued existence of the Redondo plant, as with all other Edison plants being offered for divestiture, is dependent on market forces that are independent of divestiture. Either Edison or the new owners would have similar incentives to continue operations, refurbish or repower these plants. (See also responses to CCC-1, CCC-2, and CRB-13.)
The past use of cooling water to heat the City's public swimming pool in noted on page 4.15.17. Such use was discontinued in 1994 because of damage caused by the Northridge earthquake. Accordingly, the document states that, "It is not known what the availability of this resource would be to the City with a new owner of the plant."
REFERENCES:
George, Ballard, Acoustic Engineer, phone interview, October, 13, 1997.
Khosrovani, Hooshang, Paul S. Veneklasen & Associates, "Noise Impact Report-Redondo Generating Station," 12 November 1996.
Robey, Bob, Paul S. Veneklasen & Associates, personal communication, August 13, 1997.