P. U-N-T (UNOCAL/NEC/THERMAL) (as Represented by Latham & Watkins, Attorneys at Law)
P1 Comment noted.
P2 Please see response to Comment N11.
P3 As detailed in the response to Comment N5, the steam field operators refused to provide data on steam field capacity; therefore, the interpretation of available generation and capacity is based on PG&E’s representations to the CPUC and the ISO in relevant filings. The decline rate computation shown at page 3-15 in PG&E’s "Report on Reasonableness of Operations" provides no context for the calculations, including whether the "high 5" conditions noted by the commenter were a factor in such calculations. The computation appears to be based on actual generation after economic curtailment rather than available generation, which is the relevant measure used in the Attachment C forecast.
P4 Please see response to Comment N5 and N6.
P5 Please see response to Comment N9.
P6 The DEIR analysis assumes that the wastewater injection projects will only slow the rate of decline of the Geysers steam fields, and will not reverse that decline. For clarification, the last sentence of Page 5-9 of the DEIR is revised as follows:
Regardless of who owns the plants, the rate of decline of Geysers steamfield capacity will continue to can only be slowed if unless substantially more injection water becomes available.
P7 Please see response to Comments L45 and N3.
P8 Please see response to Comment N4.
P9 Please see response to Comment N6. The term "adjusted capacity factor" as used by PG&E in its filings to the CPUC is understood to be identical to the way "capacity factor" is employed in this EIR.
P10 Please see response to Comment N10.
P11 Please see response to Comment N10.
P12 The statement on page 4.8-5 of the DEIR that the Geysers steam fields "are being managed to prolong the steam resources to the extent possible" was related more to the efforts to extend the life of the fields using wastewater injection, rather than a judgment of day-to-day management practices concerning resource use decisions. Please see response to Comment N12 for further discussion on "wasteful or inefficient use of non-renewable resources."
P13 While a new owner may attempt to and succeed in negotiating new provisions in its contracts with the steam field operators, there is no way of predicting what types of contractual revisions might be made in the future. For purposes of the analysis presented in the DEIR, it is reasonable to assume that a new owner would pay comparable steam prices to those currently being paid by PG&E.
P14 Please see response to Comment N14.
P15 Please see response to Comment N16.
P16 Comment noted.
P17 Please see response to Comment N20.
P18 Comment noted.
P19 Comment noted.
P20 Please see response to Comment N23.
P21 Please see response to Comment N23.
P22 Please see response to Comment N24.
P23 Page 2-36, last sentence at the bottom of the page is hereby amended to read:
Other sources of recharge include (1) spent geothermal steam condensate…
P24 Please see response to Comment N26.
P25 Please see response to Comment N27.
P26 Please see response to Comment N29.
P27 Please see response to Comment N28.
P28 Please see response to Comment N30.
P29 Please see response to Comment N31.
P32 Please see response to Comment N32.
P31 Please see response to Comment H24.
P32 Please see response to Comment N35.
P33 Please see response to Comment N36.
P34 Please see response to Comment N37.
P35 Please see response to Comment N38.
P36 Please see response to Comment N39.
P37 Please see response to Comment N40.
P38 Please see response to Comment N10.
P39 Please see response to Comment N42.
P40 Please see responses to Comments N43 and N44.
P41 Page 4.9-13, the second sentence of the first full paragraph, is hereby amended to read:
Elemental sulfur (a nonhazardous waste) also is produced from abatement of hydrogen sulfide in the geothermal steam.
P42 Please see response to Comment N47.
P43 Please see response to Comment N48.
P44 Please see response to Comment N49.
P45 Please see response to Comment N50.
P46 Please see response to Comment N51.
P47 Please see response to Comment N53.
P48 Please see response to Comment N54.
P49 Please see response to Comment N55.
P50 Please see response to Comment N56.
P51 Please see response to Comment N57.
P52 Please see response to Comment N58.
P53 Please see response to Comment N8.
P54 Page 6-24 of the DEIR (last sentence of the first full paragraph) is hereby revised as follows:
Currently, some 6 8 million gpd are being piped up to the field from Lake County and injected in the Southeast Geysers.
In addition, the first paragraph, seventh sentence, on page 2-39 of the DEIR is amended to read:
…able to deliver up to 8 6 million gallons per day of effluent…
P55 Please see response to Comment N60.
P56 Please see response to Comment N61.
P57 Please see response to Comment N61.
P58 Please see response to Comment N62.
P59 Please see response to Comment N63.
P60 Please see response to Comment N64.
P61 Please see response to Comment N65.
P62 Please see response to Comment N66.
P63 Please see response to Comment N67.
P64 Please see response to Comment N68.
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