L. Pacific Gas and Electric Company
L1 As discussed in Section 3.1 of the DEIR, due to the uncertainty involved in predicting future behavior of either PG&E or new plant owners, a conservative approach to the analysis in this EIR was employed. Such assumptions, as the commenter points out, "would result in the greatest potential for environmental impacts." Given this, the DEIR may, in some instances, very well overestimate potential environmental impacts resulting from the project. This approach was necessary to ensure that, even if these environmental impacts were potentially overestimated, environmental effects identified would be evaluated and mitigated appropriately.
L2 As discussed generally in response to Comment L1, the commenter points out specifically one of many conservative assumptions utilized in the analysis. The commenter is correct that this assumption (greatly reduced natural gas supply costs) further strengthens the conservative nature of the impacts analysis.
L3 Comment noted.
L4 "Greater coordination" as used in the instances described by the commenter extends beyond mere notification of events that might lead to steam stacking. The assumption of "greater coordination" for the environmentally preferable alternative was made for several reasons. First among those is a simple "common sense" determination: decision-making among two parties is more difficult than decision-making by one party, especially if the two parties in the former case have different corporate strategies and motivations. Second, the business relationship between PG&E and the steam field owners by all accounts has occasionally been adversarial in the past, and disputes among the parties continue. Third, the steam field operators have insisted that PG&E’s operations at the Geysers "promotes wasteful and inefficient use of fuel," and that PG&E "has declined to make numerous investments and operating changes that would prolong resource life" at the Geysers (please see Comment P12). Thus, if the steam field owners were to purchase PG&E’s Geysers generating units, the fact that one entity would act to obtain maximum benefit from both the generating units and the steam fields would likely ensure greater coordination of steam field operations with generating unit operations, and would likely result in a greater overall benefit to the environment. For example, a single owner of both the steam field and the generating units may choose to bid into the Power Exchange (PX) at a price low enough to ensure some level of minimum generation at the Geysers, and thus avoid potential damage to the steam field resulting from shutting in the steam, even if the owner would lose money on the power sold during those times. By contrast, PG&E has operated its units based solely on benefits to its shareholders, and ceases operations the instant that continued generation becomes uneconomic, regardless of any potential damage to the steam field.
In addition, noted in Attachment C of the DEIR, the steam suppliers would face effective steam prices that are well below the off-peak PX prices because they would only have to recover steam production costs, rather than the administered prices in the steam supply contracts. Therefore, they would be likely to cycle the Geysers plants less than PG&E currently does in response to fluctuations in demand and in PX market price. This would result in a greater capacity utilization of the Geysers units, which could reduce stacking and the unabated air emissions associated with stacking. Therefore, the DEIR conclusion that Alternative 3 is environmentally preferable to the proposed project is well founded.
It is important to note, however, that the DEIR concludes only that Alternative 3 "would allow for greater coordination of generating unit operations with steam field characteristics and may reduce steam stacking" (page 6-29, emphasis added), and does not state with certainty that Alternative 3 would definitely result in greater coordination or in reduced incidences of steam stacking. As well, the DEIR does not conclude that the operations of the generating units and steam fields are currently " not coordinated" as implied by the commenter, merely that having a single entity controlling both operations "allows for greater coordination." Furthermore, the DEIR points out (on page 6-26) that the project itself "is not expected to have any adverse impacts with respect to steam stacking." Thus, while Alternative 3 may provide environmental benefits in comparison to the existing setting (with PG&E owning the Geysers units), it would not alter or alleviate any significant environmental impacts associated with the project.
L5 The determination that Alternative Three should represent the Geysers component of the environmentally superior alternative is not based solely on the level of operations of the Geysers units, but it is also based on the greater potential for coordination between the steam fields and the plants. Please see response to Comment L4 for the bases for conclusions with respect to Alternative 3.
L6 Please see responses to Comments L4 and L5 with respect to the selection of the environmentally superior alternative. The DEIR notes in several locations that the steam field operators have the right of first refusal to purchase the Geysers Power Plant. It is also noted in the discussion of Alternative 3, on page 6-24 in the fourth full paragraph, second sentence.
L7 The commenter is correct that CEQA does not require that the environmentally superior alternative be selected. As acknowledged on page 6-24 of the DEIR (fourth paragraph), it is not certain that the CPUC could order PG&E to sell its facilities to a particular buyer.
L8 Comment noted.
L9 Figure S.2 on page S-4 of the DEIR and Figure 2.1 on page 2-3 of the DEIR show only the status of the PG&E fossil-fueled power plants and the Geysers Power Plant. These figures do not show the location or status of other PG&E power plants, including 112 hydroelectric units, and the Diablo Canyon Nuclear Power Plant in San Luis Obispo County. The status of these other power plants is discussed in the DEIR in the last paragraph on page S-5.
L10 Page S-5 (third paragraph, second sentence) is hereby amended as follows:
PG&E will retain facilities and equipment at each site that pertain to transmission or distribution operations with the exception of a small portion of the transmission lines at the Geysers Power Plant.
Please note that the DEIR already states (on page 2-7, first paragraph) that PG&E will divest its 21-kV distribution and 4-kV service lines at the Geysers plant.
L11 The commenter is correct. Although the effect of both types of agreements is to prevent future residential use (or other sensitive uses) of the property, the legal mechanisms would vary, as noted by the commenter. Page S-5 of the DEIR (third paragraph, fifth sentence) is hereby amended as follows:
The Purchase and Sale agreement for each of the fossil-fueled plants requires a deed restriction that prevents the new owner from using the site for residential or other sensitive uses. The same restriction will be created on the Geysers Power Plant transfers by means of a land use covenant whereby the purchaser (and its subsequent transferees, if any) agrees not to use the property for residential or other sensitive land uses.
Similarly, page 4.1-13 of the DEIR (first paragraph under Impact 4.1-1, second and third sentences) is hereby amended as follows:
As a result, the new power plant owners would be subject to local environmental permits (e.g., water and air quality), and local land use agreements (e.g., easements, and deed restrictions, and covenants). Furthermore, PG&E’s Purchase and Sale Agreement for each of the fossil-fueled plants will require a deed restriction that prevents development of residential and other sensitive uses on the site, while the buyers of the Geysers plants will be required to sign a land use covenant, which would transfer to any future owners, prohibiting residential and other sensitive uses of the property.
L12 Page S-21 (Impact 4.5-4, significance level for proposed project) is hereby amended as follows:
NS(M)
Page S-21 (Impact 4.5-5, significance level for proposed project) is hereby amended as follows:
S/UN(M)
In addition, the following definition is added to footnote "a" of Table S.6 (all pages), following the definition for S/UN:
S/UN(M) = Impact is significant and unavoidable; mitigation is identified to reduce the impact, but not to less-than-significant levels.
Page S-23 (Impact 4.9-3, significance level for proposed project) is hereby amended as follows:
NS(M)
L13 Page 2-5 of the DEIR (first complete paragraph, last sentence) is hereby amended as follows:
PG&E is currently considering the divestiture various options for market valuation of its hydroelectric assets.
L14 Page 2-20 of the DEIR (second paragraph, third sentence) is hereby amended as follows:
Two All three of the three boilers associated with Units 5, 6 and 7 are also capable of burning residual fuel oil.
L15 Page 2-42 of the DEIR (second paragraph, second sentence) is hereby revised to reflect PG&E’s updated estimate of improved capacity from the Southeast Geysers effluent pipeline:
There has been a 7 5 percent (60 40 MW) increase in capacity in the Southeast Geysers field as reported by staff at the Geysers Power Plant PG&E (PG&E Comments to DEIR, September 21, 1998, page 4).
L16 In order to reflect PG&E’s clarification, Table 2.3 is revised to indicate that the Contra Costa plant does require an SLC Marine Terminal/Public Lands Lease. See response to Comment BX1. Note (b) in Table 2.3 is amended as follows:
Applies only to Administration Center and Operations Center at the Geysers Power Plant. The Aboveground Petroleum Storage Tank requirement applicable to the Geysers plant is not a permit per se. The requirement includes a biannual statement, registration fee, and SPCC plan.
L17 The following text is added to the end of the first paragraph on page 4.4-5 of the DEIR.
The sodium hypochlorite is neutralized with sodium bisulfate before discharge, in accordance with the NPDES permits.
L18 Page 4.5-14 of the DEIR (third paragraph, third sentence) is hereby amended and a fourth sentence is added as follows:
Since the beginning end of 1994, use of fuel oil at these plants has ended and, in response to BAAQMD Regulation 9, Rule 11, only natural gas is burned in these plants. However, fuel oil may still be used in limited circumstances such as force majeure natural gas curtailment and very limited testing, per BAAQMD Regulation 9, Rule 11.
L19 Page 4.5-24 of the DEIR (second paragraph, third sentence) is hereby amended as follows:
Unit 3 is coupled to a single boiler, which is capable of burning natural gas or fuel oil; however, since 1995 1994, PG&E has only burned natural gas. As previously discussed, burning fuel oil is now prohibited by has been burned because of Regulation 9, Rule 11 (promulgated by BAAQMD in 1997), except under force majeure natural gas curtailment and during limited testing.
L20 Page 4.5-34 of the DEIR (fifth paragraph, second sentence) is hereby amended as follows:
…include lube oil and distillate storage tanks, a gasoline dispensing facility, boiler standby equipment (distillate fire engine and mobile combustion turbine), solvent cleaning operations, maintenance coating operations, a wastewater treatment facility, sandblasting, and miscellaneous sources.
L21 Page 4.5-39 of the DEIR (last paragraph, last sentence) is hereby amended to read:
While two of the seven boilers are permitted to burn either natural gas or fuel oil, all of them currently burn only natural gas (because of restrictions in BAAQMD Regulation 9, Rule 11).
L22 Please see response to Comment T7.
L23 The EPA recognizes that there is uncertainty in emissions measurements of particulate matter, and it is still unclear how much of the fraction should actually be considered. The older emission factors, which usually did not include the condensable fraction, may have underestimated the actual emission factor. Since the condensable fraction may eventually become particulate matter in the atmosphere, EPA policy has been to include the condensable fraction. However, there is no indication on what fraction of the condensable portion would actually become particulate matter in the atmosphere. Thus, including all of the condensable fraction may be a conservative over-estimate of particulate matter emissions from these boilers.
L24 Page 4.7-30, paragraph 3, of the DEIR is hereby amended as follows:
In order to obtain take authorization under FESA, PG&E has submitted an application to USFWS and NMFS for Section 10 Permits. The HCP and draft Implementing Agreements between PG&E and the federal agencies were included in this application. In response to comments from the USFWS and NMFS, PG&E has slightly revised the HCP incorporated in the CESA MOU. The revised draft HCP (dated April 22, 1998) and associated permit application documents have been submitted to reviewed and deemed completed by USFWS and NMFS staff in June 1998. Based on PG&E’s discussion with USFWS and NMFS, the federal agencies intend to adhere to concur with a timeline under which the availability of the draft HCP and draft Environmental Assessment for the Section 10 Permits were will be noticed in the Federal Register in July September 1998. This will initiate a A formal 30-day public review and comment period was held. Comments received during the formal review period will be addressed in a final HCP. According to the staff proposed timeline, the Section 10 Permits will be issued by October the end of 1998.
L25 Please see response to Comment L24.
L26 The following sentence is hereby added to page 4.7-31 of the DEIR at the end of the second bullet point:
The funding will be maintained in a special deposit account;
L27 Page 4.7-35, third paragraph, of the DEIR is hereby amended as follows:
PG&E has taken steps to ensure that the new owner will be the holder of the CESA MOU and the Section 10 Permits at the closing of the sale of the Pittsburg and Contra Costa Power Plants. The CESA MOU includes provision for transfer of the CESA MOU to the new owner. NMFS and USFWS have agreed to work with PG&E and the new owner to reissue the Section 10 Permits to the new owner on an expedited basis. In addition, the draft Implementing Agreement outlines the process proposed by NMFS legal counsel for the reissuance of the Section 10 Permits and transfer of the draft , including the related Implementing agreement Agreement and HCP to the new owner. Section 13 currently provides that upon the new owner satisfying specified conditions, the federal agencies will use their best efforts to issue new permits within 60 days of receipt of a complete application for permit reissuance. USFWS has proposed revisions to the language drafted by NMFS, and therefore the language of Section 13 is still subject to change. Nevertheless, USFWS legal counsel has indicated to PG&E that a reissuance of the Section 10 Permits to the new owner can be accomplished within a 60-day periodThe USFWS has concurred with this expedited timeline. Accordingly, if the Section 10 Permits are issued to PG&E and the new owner applies for permit reissuance at least 60 days prior to or at closing, the permits should be reissued to the new owner at closing, and the new owner will be subject to the restrictions of such permits and the CESA MOU upon the closing of the sale to the same extent PG&E would have been.
L28 Please see response to Comment L27.
L29 Please see response to Comment L27.
L30 Page 4.7-36, third paragraph, of the DEIR is hereby amended as follows:
As a condition of closing the saleIf the Section 10 Permits have been reissued to PG&E prior to closing, the new owner will be required to obtain seek the reissuance of the Section 10 Permits issued to PG&E, and accept the permittee’s obligations under the CESA MOU, the HCP and the Implementing Agreements. If the permits have not been issued to PG&E, the new owner will be required to resubmit and accept any obligations under, PG&E’s pending applications for the Section 10 Permits, including the resubmittal of the then-current draft Implementing Agreement and HCP, and will seek to obtain such permits on substantially the same terms and conditions as were contained in PG&E’s permit applications.
L31 As the timing requirement associated with Mitigation Measure 4.7-2 is currently written, documentation verifying that plant managers have received copies of the commitments to the pertinent obligations must be submitted to the CPUC at least 40 days before the transfer of title. No change is deemed necessary.
L32 Page 4.7-37, under the heading "Level of Significance after Mitigation," of the DEIR is hereby amended as follows:
If the Section 10 Permits are not issued to the new owner prior to or at closing, the project may result in an unauthorized taking of listed species. The new owner’s commitment to obtain the permits and to comply with the Operational operational Constraints constraints in PG&E’s Section 10 Permits and the HCP during the interim period before they are issued will reduce this impact to less than significant.
L33 Page 4.9-4 of the DEIR (last sentence at bottom) is hereby revised as follows:
With the exception of the sulfuric acid contained in lead-acid batteries, no acutely hazardous materials are used or stored at the Potrero Power Plant.
L34 Page 4.9-5 of the DEIR (last sentence at bottom running to top of next page) is hereby revised as follows:
According to information provided in the study, operations during the site’s use as an MPG have adversely impacted the groundwater and soil in areas of the plant. throughout the entire plant area.
L35 Pertinent information presented in the Phase II Environmental Site Assessments is summarized in the responses to Comment F33 and Comment T10, and in the staff-initiated text changes in Chapter 4 of this document.
L36 PG&E states that while the appropriate lead agency for cleanup at each plant would be selected by means of the "Site Designation Process Under the Unified Agency Review of Hazardous Material Release Sites" (as is described on page 4.9-17 of the DEIR), other selection processes might be used to honor arrangements with local agencies that might already be in place.
Page 4.9-17 of the DEIR (paragraph 1, second complete sentence) is hereby revised as follows:
The appropriate lead agency at each plant will likely be selected by means of the Site Designation Process Under the Unified Agency Review of Hazardous Material Release Sites (California Environmental Protection Agency, 1997).
L37 Page 4.9-19 of the DEIR (second bulleted paragraph, first sentence) is hereby revised as follows:
Ammonia (typically dissolved in water as NH4OH) has been is used in the past in emissions abatement equipment, but is no longer used.
The following sentence is added to the end of second bulleted paragraph on page 4.9-19 of the DEIR:
Ammonia is not currently used in emissions abatement equipment at the power plants to be divested.
L38 Please see response to Comment N51.
L39 Page 4.12-3, sixth paragraph, first sentence, is hereby amended as follows:
The transmission corridor serves San Francisco and the former Skyline District (in both San Francisco and San Mateo County Counties) loads (i.e., the aggregate demand for electricity from inhabitants of these areas) and is rated about 730 750 MW.
L40 Page 4.12-5, last paragraph, first sentence, is hereby amended to read:
…San Mateo Substation are automatically opened at the Martin Substation to ensure service to the network load.to protect the in-city on-line generation from potential crippling damage."
L41 Page 4.12-7, first full paragraph, first sentence, is hereby amended to read:
The network load includes City Hall, PG&E headquarters, the CPUC, BART and Municipal transit loads, and many of the skyscrapers of the financial district. Many of these loads cannot be interrupted, even momentarily, without possible significant health and safety impacts (e.g., trapping people in elevators and in BART trains under the bay), and too, it may prove a difficult and lengthy task to re-energize this older non-radial network.
L42 The commenter is correct that the percentage of the downtown load required to be served by San Francisco Peninsula generation varies with load. Also, the smaller amount of Peninsula generation required to be on line during the off-peak period will support some of the downtown load.
The second sentence in the third full paragraph on page 4.12-7 of the DEIR is hereby amended as follows:
The SFOC require the System Dispatcher to load the San Francisco generation at the Potrero and Hunters Point Power Plants to supply a significant share (the exact percentage varies with demand) 40 percent (PG&E, 1994) of the San Francisco load during all peak and partial peak hours.
The fifth sentence in the third full paragraph on page 4.12-7 of the DEIR is hereby amended as follows:
During off-peak periods, the SFOC is not intended to sustain even the much-reduced downtown loads dictates that about 80 MW of Peninsula generation must be online and dispatched. In case of a disturbance, this dispatched generation would serve to instantaneously support a portion of the downtown load.
L43 The commenter seeks to clarify the point that in fact there are multiple lines between San Francisco and the outside power grid versus a single line. The commenter is correct that there are multiple transmissions lines providing power to San Francisco. While the DEIR text mentioned a single interconnection which, in actuality, contains multiple lines, it is also true that this single interconnection is San Francisco’s only electric link to the outside grid. However, in the interest of clarity, page 4.12-9 of the DEIR, first full sentence, is hereby amended to read:
Additionally, without in-city generation, given the transmission configuration, there would be a citywide blackout if and when the single interconnection between San Francisco and the outside power transmission grid were lost.
L44 Page 4.12-9, last paragraph, first sentence, is hereby amended to read:
PG&E has just completed installation of shunt capacitors at the Metcalf Substation near south San Jose and during June 1998, and began replacement of two, approximately 100 120 MVA (MegaVolt-Amperes) 230 to 115 kV transformers with two 420 MVA transformers at the San Mateo Substation and replacement of 430 MVA transformers.
L45 The commenter is correct that the text on Page 5-11, paragraph 2 overstates PG&E involvement in the Santa Rosa Wastewater Modified Geysers Recharge Project. Page 5-11, the first full paragraph is hereby amended to delete the first two sentences as follows:
PG&E is one of the key players in the Santa Rosa Wastewater Modified Geysers Recharge Project. However, it is assumed that if PG&E were to sell its units, the new owners would simply assume PG&E’s role in the process. The potential increase in steam production…
L46 Please see responses to Comments L4 through L7.
L47 The commenter is correct that the conclusions of Attachment C "further the conservative nature of the analyses" in the EIR. All statements in Attachment C have been checked to the extent possible for accuracy and to minimize any speculation. As with other portions of the EIR, where judgements needed to be made concerning the future behavior of PG&E and of new owners of the plants proposed for sale, the EIR preparers chose assumptions that would avoid any potential for underestimating the changes effected by divestiture and their corollary environmental impacts.
L48 Please see response to Comment L16.
L49 Comment noted.
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