T0 Comments on specific alleged deficiencies or errors are addressed individually as they are raised in the commenter’s subsequent comments. The CPUC disagrees with the commenter’s assessment of the DEIR as deficient. Therefore, there is no need to re-issue the document.

T1 Potential impacts to steelhead trout and coho salmon at the Pittsburg and Contra Costa Power Plants are discussed under Impact 4.7-2, and mitigation is provided under Mitigation Measure 4.7-2. These two species are not expected to be impacted by operations at the Potrero Power Plant, where occurrences of salmonids are rare. Big Sulphur Creek in the vicinity of the Geysers is an important steelhead spawning and rearing stream. However, there is nothing inherent in the normal operating processes of the Geysers Power Plant that would constitute a "take" of a listed species, and thus the change in listing status is not relevant to the CEQA analysis. Should a "take" occur as a result of equipment failure (e.g. geothermal condensate spill) or personnel negligence, the enforcement of the provisions of the Endangered Species Act would be no different whether PG&E or another entity owned the power plant.

T2 It is not clear why the commenter believes that the environmental baseline is nonexistent. The Baseline scenario for 1999 is defined on pages 3-2 and 3-9 through 3-12 of the DEIR and is used as a basis of comparison in evaluating all environmental impacts discussed in the DEIR. As noted in the DEIR, the baseline reflects the ongoing restructuring of the electric utility industry that will continue to occur with or without implementation of the proposed project.

T3 Proposition 9 was on the ballot in California on November 3, 1998 and was defeated. Regarding decommissioning, please see the response to Comment B5.

T4 As noted in the comment, the intention of the CEQA requirement to address both short-term and long-term significant effects of the project is to ensure consideration of the full range of environmental impacts associated with the project. The year 2005 was selected for analysis of long-term effects for the following reasons: (1) the restructuring of the electric industry will be complete by then; (2) for purposes of a cumulative analysis, it is difficult to anticipate future projects beyond that date; (3) a variety of anticipated changes in the regional electricity generation and transmission system will have been implemented by 2005; and (4) beyond that date, physical and operational differences between restructuring with divestiture as currently proposed and without divestiture could be effectively eliminated. In this context, evaluating potential effects through the year 2005 does encompass the potential long-term effects of the project. Please also note that the air quality analysis also considers longer-term cumulative air quality effects in 2015, based on populations projections supplied by the Association of Bay Area Governments and extrapolations of air quality projections developed by the BAAQMD.

T5A Please see response to Comment T1.

T5B The commenter implies that hydrogen sulfide will convert to sulfur dioxide, which is a phytotoxicant to plants, and will result in ambient air levels that are great enough to damage plants. Studies indicate that the conversion of hydrogen sulfide to sulfur dioxide in the atmosphere is a slow process (Seinfeld, 1986 and Baulch, et al., 1982), with typical conversion times being over 53 hours. Within that time period, pollutant emissions from the Geysers plants would be transported many miles downwind, and concentrations of these pollutants would be extremely small because of dilution by the air. Therefore, hydrogen sulfide conversion to sulfur dioxide at these larger distances from the plants would result in levels well below those that could affect plants.

In addition to the response, the following references are hereby added to the reference list for Section 4.5, Air Quality, on page 4.5-84 of the DEIR:

T5C It cannot be assumed that the proposed divestiture of the Geysers Power Plant will result in an increase in geothermal condensate spills because it is not projected that divestiture would lead to additional accidents. Therefore, the concern, while valid, does not constitute an impact of divestiture.

T5D PG&E has not received any National Marine Fisheries Service (NMFS) requirements for the Geysers. The Secretary of Commerce, through NMFS, has not yet issued a Protective Regulations ruling for steelhead trout under Section 4(d) of the Endangered Species Act of 1973. Until such a ruling is made, NMFS is acting in the role of advisory agency rather than regulatory agency with respect to threatened steelhead.

T5E The proposed divestiture project, i.e. the transfer of ownership of PG&E’s power plants, is not expected to have any impacts on special status species other than those discussed in Impacts 4.7-1 and 4.7-2. Mitigation Measure 4.7-1 addresses the need for future owners to be aware of all biological resources within the project area so as to not impact these resources through unforeseen, non-power-production activities such as equipment storage, maintenance practice changes, road access, facility repair, etc. To clarify that the materials provided by PG&E to the new owners must be readily accessible, Mitigation Measure 4.7-1 on page 4.7-34 of the DEIR is hereby amended as follows:

T6 Section 4.4.3, Significance Criteria, includes both CEQA Appendix G, Item (f): Substantially degrade water supply; and Item (g): Contaminate a water supply. As described in Impact 4.4-1, the project would have minimal, if any, effects on water quality.

T7 The measured concentrations of radon are typical of safe background levels and well below levels causing health problems. As a precaution to prevent exposure levels from exceeding health levels, the Air District requires that radon levels be monitored near the Geysers project. There are typographical errors on page 4.5-47 that lead to the wrong conclusions. Thus the text regarding radon in the third sentence of the third full paragraph on page 4.5-47 of the DEIR has been changed to read:

T8 The steam field operator referenced in the comment did go bankrupt and abandon 24 leaking wells in the Geysers Known Geothermal Resource Area in 1997. U.S. Environmental Protection Agency Superfund monies were used to cap seven of the wells, and a grant from the CEC provided the funds to cap all but one of the remaining wells. The one uncapped well is not currently considered an environmental threat. Please note that potential buyers of the project power plants will be carefully screened for financial solvency and will be subject to CPUC approval. Regarding decommissioning, please see responses to Comments B5 and K1.

T9 The increase in cycling operations discussed in Attachment C is going on currently, and has been going on since 1994. Increased cycling would not be a consequence of divestiture, although restructuring may encourage cycling by altering the economic incentives faced by any owner, whether it be PG&E or a new buyer. For this reason, analyzing the impacts of cycling is beyond the scope of this DEIR.

The Lake County effluent pipeline currently is able to deliver at least 8 million gallons per day (mgd) to the Southeast Geysers area (see the response to Comment P54). Although smaller, this is still comparable to the proposed 11 mgd capacity for the Santa Rosa pipeline. The Lake County line has been in operation less than a year, but has already increased generation capacity at the affected PG&E units by about 40 MW, which is an average of 10 MW apiece for Units 13, 16, 18 and 20, the four units affected. Also please see the response to Comment L15. It appears that, if anything, the DEIR had underestimated the potential improvements from these projects.

The comment faults information presented in the Project Description (on page 2-36 of the DEIR) for failing to address constituents of the geothermal steam. Such constituents are described elsewhere in the DEIR where relevant. For example, chemical constituents found in geothermal steam are mentioned on page 4.9-12. (Also, as noted on page 4.4-12 of the DEIR, the Geysers plant has a zero water discharge program and therefore needs no NPDES permit nor wastewater discharge requirements.)

The commenter alleges that there are "corrosive solutes in the geothermal steam that have produced high levels of chloride at the wellhead with observed levels greater than 100 ppm." The commenter goes on to claim that "the chloride-bearing steam is acidic and highly corrosive..." However, the commenter provides no basis for these assertions. In fact, steam or water having chloride concentrations of "greater than 100 ppm" would be neither "acidic" nor "highly corrosive." The chloride ion by itself is a neutral ion (a constituent of table salt) that imparts no acidic quality to steam or water, and low concentrations of 100 ppm chloride are not corrosive. Given the fact that the drinking water standard for chloride is 500 ppm, a concentration of 100 ppm of chloride would not be considered a "high level" by any authority. It follows that the claim that it could be "highly corrosive" or "acidic" appears unreasonable.

The commenter’s assertion that the statement on page S-12 of the DEIR ["7. The two proposed wastewater injection projects...are being implemented..."] is "highly speculative and false" is mistaken. The DEIR text is correct as written. The DEIR is merely stating the cumulative assumptions for the year 2005, not claiming that the projects are happening now or are guaranteed to happen as the commenter seems to imply. The commenter is correct that the proposed projects may in fact not ultimately be approved or implemented, but CEQA requires that the cumulative analysis assume that proposed projects actually will occur.

T10 The comment focuses specifically on the Executive Summary of the DEIR and on Chapter 2, the Project Description. However, the concerns of the commenter regarding existing contamination and cleanup are discussed in the local setting and impact descriptions for the Geysers Power Plant in the Hazards section of the DEIR. The Hazards setting for the Geysers Power Plant begins on page 4.9-12. Impacts of remediation are discussed under Impact 4.9-1, which starts on page 4.9-14, and under Impact 4.9-2, which can be found on page 4.9-18.

The Phase II Environmental Site Assessment and the Risk Assessment have now been completed for the Geysers Power Plant. The findings and conclusions of the Phase II Environmental Site Assessment and the Risk Assessment do not modify the analysis nor conclusions of the DEIR. Page 4.9.13 of the DEIR (bottom of page) is hereby amended with the following new paragraphs:

In addition, page 4.9-25 of the DEIR is hereby amended with the following additional reference:

T11 No EIR mitigation measures refer to decommissioning of the units. Regarding decommissioning generally, please see response to Comment B5.

T12 Page 1-7, item No. 4 of the DEIR lists concerns raised by the public with respect to the project prior to publication of the DEIR; no analysis or conclusions of environmental effects are presented in this section. Although there currently are diversions of some creeks by steamfield owners (not owners of generating units) for reinjection, there is no evidence that new owners of the generating units would attempt additional creek diversions, and no diversions are proposed as part of the project. Also see response to Comment N19.

T13 Please see response to Comment B5.

T14 The statement on page 2-38 of the DEIR (third paragraph) that "geothermal steam is expanded through a steam turbine and cooled and condensed into water..." accurately describes the overall electricity-generating process at the Geysers Power Plant. Steam condensate is produced during normal turbine operation. There is no reason to believe that divestiture would result in increased amounts of steam condensate being generated at the plant. See the responses to Comments H4, H5, and H15 for discussions of market forces and related factors that might affect future utilization of the Geysers steam resources.

Trace chemical constituents of geothermal steam were discussed in the DEIR in Section 4.9, Hazards. Toxic properties of the trace constituents of steam reflect the natural properties of local geology. There is no information to support the commenter’s contention that steam contains a "vast number of toxic substances" that the "original permit granters were afraid to ship...over the highways of California."

Hazardous waste streams at the Geysers Power Plant generally are process wastes associated with abatement systems; these wastes are handled in proper fashion, as is described in detail in the DEIR on page 4.9-23 under Impact 4.9-5, and on page E-5 of Attachment E.

The most significant toxic component found in the naturally occurring geothermal steam is hydrogen sulfide gas, as is discussed in the DEIR on page 4.9-12. All of the generating units at the Geysers Power Plant have hydrogen sulfide abatement systems, as is mentioned on page 4.9-12 and described in more detail in Attachment E in the DEIR. Also see response to Comment H22.

Other naturally occurring trace contaminants of geothermal steam include mercury and arsenic, as is mentioned on page 4.9-13 in the DEIR. Mercury is removed from the geothermal steam by means of activated-carbon scrubbers, as is described in the DEIR on page 4.9-13 (second paragraph). Precautions taken to minimize exposure to other metals including arsenic are described in the response to Comment H47.

T15 Please see response to Comment B5 regarding increased risk of environmental impact under a new owner in relation to plant decommissioning. The potential impacts of future decommissioning (not a part of divestiture) of the sulfur scrubbing units would not be affected by plant ownership, nor by the type of sulfur scrubbing technology employed at various Geysers units. The commenter offers no rationale for why decommissioning of the various scrubber systems might pose any unusual environmental problems.

Refer to the response to Comment H31 for a discussion of best available control technology for hydrogen sulfide at the Geysers units. Refer to the response to Comment H22 for an expanded description of sulfur scrubbing systems.

T16 The commenter notes that a representative wind rose was not presented for the Geysers Power Plant similar to those provided for the three Bay Area power plants, and assumes that such data were unavailable to the DEIR preparation team. In fact, tabular wind speed and direction data from several locations within the Geysers area were available to the DEIR authors during report preparation. These data were reviewed and considered as part of the environmental review for air quality impacts. They were not presented in the DEIR because the Geysers units, unlike each of the fossil-fueled plants, are located in a mountainous region with units widely separated by distance, elevation, and terrain. The several available meteorological data sets examined for the Geysers each tended to show influences from local topography specific to the location of the Geyser unit closest to that monitoring station. Because of these local influences, none of the available meteorological data sets could be considered representative for the all of the Geyser units and, thus, were not presented in the DEIR. The local wind flow situation present in the Geysers area is further discussed on the final paragraph of page 4.5-2 and the first full paragraph of page 4.5-3 of the DEIR.

T17 The decline in the Geysers steam field production has been known since at least 1987. Both steam field and power plant operators have studied various means of extending the steam supply, including closing power plants. Based on the analysis presented in the DEIR, divestiture of the Geysers is unlikely to exacerbate the steam field decline. For this reason, analysis of "productivity and potential shutdown of certain plants" is inappropriate given the lack of any discernible causation.

Alternative 3 (sale of Geysers units to the steam field owners) is designated the "environmentally superior alternative" because it would "unify" the steam fields to a large extent by vertically integrating the operations (see page 6-23 of the DEIR). This would improve the incentives to effectively coordinate steam and electricity production to maximize the economic benefits from Geysers generation.

T18 The runoff from the plants at the Geysers is contained through on-site drainage facilities and injected to supplement the natural deep groundwater and increase steam production.

The DEIR page 4.3-6 has been revised in response to Comment H27 to list serpentine as part of the geologic structure of the Franciscan Formation that underlies the Geysers. As noted in response to Comment H27, in order for asbestos particles that are contained in the serpentine rock to become a hazard, it would have to be entrained into the air and transported by the wind to offsite receptors. For this to occur, the exposed rock would have to be crushed through construction activities and clearing and grading operations. The project will not require construction operations at the Geysers plant. Therefore there would be no exposure to asbestos particles under divestiture.

With respect to the area’s mercury mines, page 4.3-6, paragraph 2 is hereby revised to add the following language at the end of the paragraph: