HomeMy WebLinkAboutVolume 2 of 4 - Study Session - Presentation by the Planning Roberts, Robin From: Albers, Patricia Sent: Wednesday, February 08, 2006 8:14 AM To: Ramos, Ricky Cc: Roberts, Robin Subject: RE: Economic and Fiscal Impacts Study by M. Cubed Hi Ricky, Thanks so much for obtaining that report ! We do not need a letter from Mr. Erskine. The report wasn't missing from our file, we just never received a copy of. it. In watching the video tape of the Council meeting, we can see that he turned it into the Sergeant at Arms, who passed it on to Council, but it never made it over to the City Clerk. It's existence was already entered into the record via the minutes from the meeting - now we will add the physical copy to the file. Thanks again for your assistance with this: Patricia Albers Acting Senior Deputy City Clerk X5210 -----Original Message----- From: Ramos, Ricky Sent: Tuesday, February 07, 2006 5:02 PM To: Albers, Patricia Cc: 'RTempleton@Nossaman.com' Subject: FW: Economic and Fiscal Impacts Study by M. Cubed Patricia - Here is the report. Does John Erskine need to send a letter to officially enter this into the record for the Sept. 6, 2005 hearing or is it already entered in the record but the report was just missing from the City Clerk's file? -----Original Message----- From: Templeton, Roxanne [mailto:RTempleton@Nossaman.com] Sent: Tuesday, February 07, 2006 4 :52 PM To: rramos@surfcity-hb.org Subject: Economic and Fiscal Impacts Study by M. Cubed I just spoke to John Erskine and he would appreciate your advising us if we need to send a transmittal letter to the City Clerk to rectify the fact that his request made at the September 6 hearing that the attached document be entered into the record was apparently not acted upon. If such a letter is not needed, we would appreciate your copying the attached document and transmitting it to the Clerk. Thank you! POLICY ANALYSIS F O R T€--i E CC PUBLIC AND PRIVATE SECTORS ![.CURED i tI f C Economic and Fiscal Impacts of the Proposed Huntington Beach Desalination Project Prepared for Poseidon Resources, Inc. by M.Cubed with assistance from Robert Mott i June 2003 r 5358 Miles Avenue Oakland, CA 94618 Ph. (510) 547-4369 Fx. (510) 547-3002 ii I Economic and F�cai Impacts of Proposed Huntngk»n Beach Desalination Project Final Report, June 2D03 Report Table of Contents 1. SUMMARY OF FINDINGS 1 1] Summary of Findings Plant Construction Phase 1 12 Summary of Findings Plant Operations Phase 2 2. LOCAL PROCUREMENT OF EQUIPMENT AND SERVICES 4 2.1 Local Procurement during Construction Phase ofProject 4 2.2 Local Procurement during Operations Phase ofProject 4 3. REGIONAL EC(}N[}Kq|C IMPACT ANALYSIS 7 11 Plant Construction Phase |K8PLAN Detail Tables 8 3.2 Plant Operations Phase |KXPL4N Detail Tables 11 4. FISCAL IMPACT ANALYSIS 15 4.1 Apportionment of Sales Tax Revenue Increment 15 42 Utility Tax Revenue Apportionment 16 4.3 Property Tax Revenue Apportionment 16 &yCubed Pokq/Analysis for the Public and Private Sectors ' Econornic and Fiscal Impacts of Proposed Huntington Beach Desalination Project" Final Report, jUne 2003 List of Tables TABLE 1, SUMMARY OF ECONOMIC IMPACTS FROM 2-YEAR CONSTRUCTION OF HUNTINGTON BEACH DESALINATIONPLANT........—................ ....... ............... ............ ............ .............---....... 2 TABLE 2. S U MNNARY OF ANNUAL IMPACTS FROM PLANT OPERATION...... ........ ....--................... ................... 3 TABLE 3. CONSTRUCTION COST BREAKDOWN FOR PROPOSED HUNTINGTON BEACH DESALINIA-11ON PROJECT.... 5 TABLE 4. ANNUAL OPERATING COSTS OF PROPOSED HUNTINGTON BEACH DESALINATION PLANT............. ..... 6 TABLE 5. PLANT CONSTRUCTION PHASE: ORANGE COUNTY EMPLOYMENT IMPACTS.... ........ ....... ....... ............ 9 TABLE 6- PLANT CONSTRUCTION PHASE: ORANGE COUNTY LABOR INCOME IMPACTS........................................ 9 TABLE 7. CONSTRUCTION PHASE: ORANGE COUNTY OTHER PROPERTY INCOME IMPACTS........ ....... .............. 10 TABLE 8. CONSTRUCTION PHASE: ORANGE COUNTY INDIRECT BUSINESS TAX REVENUE IMPACTS......—.......... 10 TABLE 9. PLANT OPERATIONS PHASE: ORANGE COUNTY EMPLOYMENT IMPACTS......... ....... ................ 12 TABLE 10, PLANT OPERATIONS PHASE: ORANGE COUNTY LABOR INCOME IMPACTS..................... ......... ...... 12 TABLE 11. PLANT OPERATIONS PHASE: ORANGE COUNTY OTHER PROPERTY INCOME IMPACTS....... ....... ...... 14 TABLE 12. PLANT OPERATIONS PHASE: ORANGE COUNTY INDIRECT BUSINESS TAX REVENUE Ir,1PACTS... ...-.. 14 TABLE 13. SALES TAX REVENUE APPORTIONMENT: PLAN f-CONSTRUCTION PHASE..................... ....... ........... 15 TABLE 14. SALES TAX REVENUE APPORTIONMENT: PI-ANT OPERATIONS PHASE ................... ................. ..... 16 TABLE 15. EXPECTED APPORTIONMENT OF ANNUAL PROPERTY TAX REVENUE ..... ....... ......... ......... 18 M.Cubed Policy Analysis for the Public arid Private Sectors Economic and Fiscal Impacts of Proposed Huntington Beach Desalination Project Final Report, June 2003 1. Summary of Findings The proposed Poseidon Seawater Desalination Project at Huntington Beach consists of the construction and operation of a 50-million gallons per day (MGD) reverse osmosis seawater desalination plant. The desalination plant would produce high-quality potable drinking water for use by residents and businesses in Orange County, providing enough water for approximately 100,000 existing households. The plant would be located on an 11-acre site adjacent to the AES Huntington Beach Power Plant. The desalination plant would utilize approximately 100 MGD of cooling water from the AES facility as source water for the reverse osmosis process. Brine water from the reverse osmosis process would be returned to the AES outfall facilities for discharge to the ocean. Construction of the facility would last approximately two years and cost about $228million. Preliminary construction estimates indicate that about 41% of the plant construction cost, approximately $93.5 million, would consist of goods and services procured within Orange County. Once constructed, the facility would operate 24-hours per day, seven days a week, and would employ up to 18 full-time workers. A regional economic and fiscal impact analysis using the IMPLAN input-output modeling system was conducted to evaluate income, employment, and fiscal impacts for Orange County associated with plant construction and operation. The impact analysis is divided into two phases: (1) the plant construction phase and (2) the plant operations phase. 1.1 Summary of Findings Plant Construction Phase The principal findings from the impact analysis during the construction phase of the proposed project are summarized in Table I and include the following-. • Plant construction would support 675 jobs per year in the construction sector. An additional 275 jobs per year would be indirectly supported through procurement of goods and services in aid of construction and spending of construction labor M.Cubed 1 Policy Analysis for the Public and Private Sectors � Economic and Fiscal impacts o/Proposed Huntington Beach Desalination Project Final Report, June 2003 earnings. |n total, approximately 1.9O0 job-years would be supported during the tw/0-ye@[ %0OstructiOD period. 0 Annual labor income iO Orange County would increase bV $50 million during the construction period. Approximately three-fourths Of this income would accrue tn construction sector labor. Construction 0f the desalination plant would support high-value jobs. Estimated average earnings per job are $54.000, about 29% higher than average earnings per job for the C0UDb/.' * In addition to labor earnings, construction spending would increase property and investment income within Orange County by approximately 39 million per year during the two-year construction period. 0 Indirect business tax (IBT) receipts, which consist primarily Ofsales and property tax revenue, would increase by $2.5 million per year during construction. Over the two-year period, |BT receipts vvOU|d increase bV $5 DliUiOO. Table 1' Summary of Economic Impacts from 2-YearConstruction of Huntington Beach Desalination Plant Labor income $100 million $70 million $170 million Other income $18 million $19 million $37 million Indirect business tax receipts $5 million $7 million $12 million 1'2 Summary of Findings Plant Operations Phase While the employment, income, and fiscal impacts from construction spending vvOU/d persist only during the period of construction, iO0p8CtS associated with plant _.............___ __ / Average earnings per job for Orange County are$42.00O. This estimate comes from US. Department of Commerce, Bureau of Economic Analysis 2001 data adjusted to 2003 dollars. ^ Impacts in Table 1 are shown for the entire two-year construction period. Annual impacts are half these values assuming construction spending is evenly divided over the two years. M.Cubed 2 Po6iqy Analysis for the Public and Private Sectors Economic and Fiscal Impacts of Proposed Huntington Beach Desalination Project Final Repod, June 2003 operation would be of a more permanent nature. These impacts are summarized in Table 2 and include the following: • Plant operation would directly support 18 full-time jobs. An additional 322 jobs per year would be indirectly supported through procurement of operation and maintenance goods and services and spending of labor earnings. In total, approximately 350 jobs would be supported directly and indirectly by plant operation. • Aggregate labor income in Orange County attributable to plant operation would be $18 million per year. Average earnings per job would be $53,000, about 26% higher than average earnings per job for the county.3 • In addition to labor earnings, plant operation would increase property and investment income within Orange County by approximately $7 million per year. • Indirect business tax receipts from plant operation would total approximately$3.0 million per year. Fiscal impacts of plant operation are discussed more fully in Section 4. Table 2. Summary of Annual Impacts from Plant Operation y 1 Regional l,mpacts , 0rari a count , Annual employment obs�------ 35_0 Labor income $18.0 million _...._. - -- - ---- ....._.._.._. .. Other income $7.0 million Indirect business tax receipts $3.0 million See footnote 1 for explanation of Orange County average earnings. M.Cubed 3 Policy Analysis for the Public and Private Sectors Economic and Fiscal Impacts of Proposed Huntington Beach Desalination Project Final Report, June 2003 2. Local Procurement of Equipment and Services Construction and operation of the proposed desalination facility would result in significant investment and spending in Orange County. To the extent the facility would offset demand for water imported from outside the region, it would incrementally add to regional economic output. Because of the depth and breadth of the Orange County economy, a sizeable proportion of materials, equipment, and services required for construction and operation should be procured within the region. Consequently, the project should provide significant support for regional employment and income. 2.1 Local Procurement during Construction Phase of Project Table 3 shows the estimated construction expenditures for the proposed desalination project. As shown in the table, approximately 41% of total construction spending would be expected to occur within Orange County. In round figures, this amounts to about $93.5 million in regional expenditure. Expenditure shares between engineering services, equipment & material, and construction are 23%, 9%, and 68%, respectively. The construction expenditures shown in Table 3 were used to calculate the employment, income, and fiscal impacts during the construction phase summarized in Table 1. 2.2 Local Procurement during Operations Phase of Project Table 4 shows a breakdown of annual operating costs for the proposed facility. Equipment, services, and labor for plant operation are expected to be drawn from within Orange County. Expected annual O&M costs would run about $31 million. Plant employment would be 18 full-time equivalent positions. These costs and employment estimates were used to calculate the employment, income, and fiscal impacts during the plant operations phase summarized in Table 2. M.Cubed 4 Policy Analysis for the Public and Private Sectors Economic and Fiscal Imparts of Proposed Huntington Beach Desalination Project Final Report, June 2003 Table 3. Construction Cost Breakdown for Proposed Huntington Beach Desalination Project ; Protect Element ,. 'Pro ect3Breakiown ' r f nP #rutty EsimatedC'ost ,. F4unt ngtori BeachElsevdhere grid C3utside OVChange CountyAarea 'California f ... °�, . a NPercertt Cellars. F'ercei Ltollars :Total Es#imated..C,on tructmon host. ,. .. a .xu ,;. ..:_ -% r $228 C100,Q00r . 41 /0 ..= 3,4$O,OUO_z w ;.. 59-/0 $1.3.4,520000•, PO System Engineering $3,900,000 70%1 $2,730,000 30 %! $1,170, 000 Materials and Equipment $35,400,000 Owl100%1 $35,400,000 Construction $25,900,000 73% $18,870 0001 27%I $7,030,000 _.... _ _00 Pretreatment System ;Engineering $1,100,000 75% $830,000 25°l0l $270,000 ` Materials and Equipment' $13,700,000 0% - 100%' $13,700,000 _ Construction ; $15,100,000 60% $9,060,000 40% 6,040,000 Intake and Discharge Facilities Engineering $980,000 75% $740,000 25% $240,000 Materials and Equipment' $5,720,000 60% $3,430,000 40% $2,290,000 i Construction $4,400,000 50%1 $2,200,000 50%f $2,200,000 Post-Treatment Facilities Engineering $480,000 i 80% $380,000 20% $100,000 Materials and Equipment $2,200,000 20%' $110,000 1 80% $2,090,000 ;Construction $2,820,000 75%'; $2,110,000 j 25% $710,000 Electrical, Instrumentation, and ,Engineering $1,800,000 70% $1;260,000 20% $540.000 Controls ,000 80%Materials and Equipment $15,000,000 20%I $3,000 $12,000,000 Construction $14,600,000 60%1 $8,760,000 4 0% S5,840,000 !General Construction and Auxiliary ;Engineering I $3,400,000 70% $2,380,000 i 30% 1,020,000 1Facilities 'Materials and Equipment{ $16,000,000 20% $3,200,000 80%1 $12,800,000 _ (Construction $16,600,000 60%1 $9,960,000 40%1 6,640,000 Solids Handling Facilities Engineering $500,000 100% $500,000 0%1 Materials and Equipment; $4,600.000 20% $900,000 80% $3,700,000 _ Construction $2,300,000 100% $2,300,000 0% - Product Water Tank, Pump Station, Engineering �$4,140,000 80% $3,310,000 1 20% 830,000 and Delivery Pipeline Materials and Equipment $20,720,000 I 20%i $4,140,000 I 80% $16,580,000 Construction $16,640,000 80%! S13,310,000 20% 3,330,000 Economic and Fiscal Impacts of Proposed Huntington Beach Desalination Project Final Report, Jane 2003 Table 4. Annual Operating Costs of Proposed Huntington Beach Desalination Plant flperat ng Categary. �r ;`Annual=Cost Type of Cost I s. E� _._. (Thous Power Cost -$16,800 iEVariable - — Chemicals $2,500 Variable Labor - _-_-_-_ __-- ---____ _ $.1 600 Fixed Membrane Replacement $1,700 Fixed Slue Cris osal $1,500 Variable Operations & Maintenance - _ $2,400 Fixed _ — - - - _ Operator Fee $1;800 ! Fixed Miscellaneous $2,700 Variable _........ -- Totl __ a ___ __._. . $31 000 __ _. —Number of Employees -- �- ---- 18 M.Cubed 6 Policy Analysis for the Public and Private Sectors Economic and Fiscal Impacts o;Proposed Huntington Beach Desalination Project Final Report; Jame 2003 3. Regional Economic Impact Analysis An IMPLAN regional input-output (1-0) model for Orange county was constructed to estimate employment, income, and tax impacts from construction and operation of the proposed desalination project. The 1-0 model was used to estimate how direct purchases of goods and services and payment of wages to construct and operate the plant would be spent within Orange County, thus supporting additional economic activity and employment. Economists typically organize these multiplier effects into three categories: (1) direct impacts, (2) indirect impacts, and (3) induced impacts. Direct impacts refer to the values of output and employment generated by the sectors (e.g., the construction and utility industries) to construct and operate the facility. Indirect impacts refer to income and employment associated with purchases of goods and services from support industries by the direct activity -- for example, building materials supplied by a local construction supply house. Induced impacts refer to economic activity caused by regional spending of wage income earned in the direct and indirect rounds of spending -- for example, the purchases of food and other household goods by employees of the desalination plant and its suppliers. The IMPLAN modeling system uses data from the national benchmark 1-0 tables and combines this with county level wage and employment estimates developed from ES202 and County Business Patterns 4-digit data. Bureau of Economic Analysis Regional Economic Information System (REIS) 2-digit employment and income data are used to distribute county level self-employment Eo industry sectors. Regional purchase coefficients and regional value-added/output ratios are used to localize the national absorption and by-product matrices from the benchmark 1-0 tables. All final demand and value added components in the IMPLAN model are region specific. 4 A regional input-output model traces the interactions of local industries with each other, with industries outside the region, and with fina►demand sectors. An 1-0 model accounts for flows of monies through the region, showing details regarding consumer behavior, the technology of production, incomes, and social transfers. M.Cubed 7 Policy Analysis for the Public and Private Sectors Economic and Fiscai Impacts of Proposed Huntington Beach Desalination Project Final Report, June 2003 Data in Tables 3 and 4 were used in conjunction with the IMPLAN software to calculate the results summarized in Tables 1 and 2. The tables that follow provide a more detailed view of the IMPLAN analysis results, showing the employment, income; and fiscal impacts for ten aggregate economic sectors. 3.1 Plant Construction Phase IMPLAN Detail Tables Table 5, 6, 7, and 3, show changes in Orange County employment, labor income, property income, and business tax revenues, respectively, by economic sector during the construction phase of the project. The values in these tables are totals over the assumed two-year construction period. Annual values can be derived by halving the values shown in the table, as was done in the summary bullets in Section 1. The employment and income changes shown in these tables are temporary and would phase out following completion of construction. In other words, the construction activity would provide a temporary increase in regional economic activity and tax receipts. s The IMPLAN model has a total of 528 industry sectors. Model results can be aggregated or disaggregated according to user needs. The ten basic industry sectors are (1) agriculture, (2) mining, (3) construction, (4) manufacturing, (5)transportation & utilities (TCPU), (6) trade (retail and wholesale), (7) finance, insurance, and real estate (FIRE), (8) services (professional and consumer), (9) government(local, state, and federal); and (10)domestic services. These sectors are organized according to Standard Industrial Classification (SIC) codes. M.Cubed g Policy Analysis for the Public and Private Sectors Econormic and Fiscal Impacts of Proposed Huntington Beach Desalination Project Final,Deport; Jane 2003 Table 5. Plant Construction Phase: Orange County Employment Impacts Industry Sector Direct* Indirect" Induced* Total' Agriculture 0 1 5 Mining 0 0 1 1 Construction 1,349 1 8 1,35 Manufacturing 0 4 22 2 TCPU 0 2 16 1 Trade 0 10 183 19 FIFE 0 3 41 4 Services 0 38 233 27 Government 0 1 6 7 Domestic service 0 0 12 12 Total Jobs 1,349 58 526 1,93 *Model: Orange Poseidon 2000.iapi values in part-and full-time jobs Table 6. Plant Construction Phase: Orange County Labor Income Impacts Industry Sector Direct'* Indirect* Induced* Total` Agriculture $0 S15,651 S89,430 $105,081 Mining $0 $3,783 $52,296 $56,07 Construction S77;284,861 $25,885 $428,561 $77,739.307 Manufacturing $o $189,020 S1;077,116 $13266,13, TCPU $o $109,095 $919,516 $1,028,611 Trade $0 $479,008 $5,636,617 $6;115,62 FIRE $0 $147,151 S2,449,549 $2,596,69 Services $0 $1,842,576 $9,120,792 $10,963,36 Government $0 $34187 $419,584 $453,77 Domestic service $0 $0 $154,251 $154,251 i Total Labor Income $77,284,861 $2,846.357 S20,347,711 00,478,929,1 `Model: Orange Poseidon 2000.iap: values in whole 2003 Dollars. Policy Analysis for the Public and Private Sectors Economic and Fiscal In7pacts of Proposed Huntington Beach Desalination Project Final Report, June 2003 Table 7. Construction Phase: Orange County Other Property Income Impacts .............. Industry ry Sector Direct* Indirect* Induced* Total* Agriculture $0 $8,394 S46,187 S54,58111 Mining $0 $5,519 376,513 S82,0311, Construction $7,527,076 $2,311 342,180 $7,571,567 Manufacturing $0 S81,690 $584,138 $665.828 TCPU $0 $65,089 $765,026 $830.115 Trade $0 $149,715 $1,669,188 $1,818,903 FIRE so $156,880 $5,836,789 $5.993.669 Services $0 $206,913 $1,196,119 $1,403.032� Government $0 -$1,635 $47,544 $45,908 Domestic service $0 so $o $0 Total Other Prop. Income $7,527,076 $674;875 $10,263,683 $18,465,634 *Model: Orange Poseidon 2000.iap; values in whole 2003 Dollars., Table 8. Construction Phase: Orange County Indirect Business Tax Revenue Impacts 6 ---------- Industry Sector Direct* Indirect* Induced* Total* Agriculture $0 $954 . $4,546 $5,50J Mining $0 $1,090 $15,153 $16,24 Construction $1,105,136 $212 S3,999 $1,109,347 Manufacturing $0 $7,188 $45,812 S53,000 TCPU $0 $17,910 $221,135 $239,045 Trade $0 $159,846 $1,665,814 $1,825,660 FIRE $0 $26,726 $1,170.018 $1,196,744 Services $0 $48,877 $325,568 $374,445 Government $0 $0 $0 $0 Domestic service $0 $0 $0 $0 Total Ind. Bus_ Taxes $1,105,136 S262,803 $3,452,044 S4,819,98' *Model: Orange Poseidon 2000.ia p-, values in whole 2003 Dollars', ............ 6 Indirect Business Taxes (IBT)are composed posed primarily of property and sales tax revenues, but also include excise taxes, license and registration fees. M.Cubed 10 Policy Analysis for the Public and Private Sectors Economic and Fiscal Impact's of Proposed Huntington Beach Desalination Project Final Report. June 2003 3.2 Plant Operations Phase IMPLAN Detail Tables Table 9, 10, 11, and 12, show changes in Orange County employment, labor income, property income, and business tax revenues, respectively, by economic sector during the plant operations phase of the project. The values in these tables are annual and would persist for as long as the plant remains in operation. Thus, these changes represent a more permanent increase in regional economic activity for Orange County. M-Cubed 11 Policy Analysis for the Public and Private Sectors Economic and Fiscal Impacts of Proposed Huntington Beach Desalination Project Final Report, June 2003 Table 9. Plant Operations Phase: Orange County Employment Impacts Industry Sector Direct* Indirect* Induced- Total*-.— Agriculture 0 0 1 1 Mining 0 0 0 0 Construction 119 1 120[ Manufacturing 01 6 4 10 TCPU 181 10 3 3 It Trade 13 32 46 FIRE T 0 9 8 17 Services 0 78 4*1 119 Government 0 31 1 4 Domestic service 0 oil 2 Total Jobs 181 2391 931 35011 *Model: Orange Posiedon 2000.iap- values in whole 2003 Dollars. Table 10. M.Cubed 12 Policy Analysis for the Public and Private Sectors Economic and Fiscal Impacts of Proposed Huntington Beach Desalination Project Final Report, June 2003 Plant Operations Phase: Orange County Labor Income Impacts Industry Sector Direct- IndirectInduced* Total* Agriculture $0 $9.297 S16,484 $25,781 Mining $0 $18,929 $9,639 $28,568 Construction i $0 $6,882,264 S78,989 $6,961,253 Manufacturing $0 $372,828 $198,537 $571,366 TCPU $1.474,431 $656,334 $169.483 $2,300,248 Trade $0 $676,534 $1,038;942 $1,715,476 FIRE $0 $542,750 $451,499 $994,248'Services $0 $4,119,677 $1,681:045 S5,800,723'! Government $o $213,547 $77,333 $2901880il Domestic service so so $28,420 $28,4201 Total Labor Income $17474,4311 513,492,160 $3,750,374 $18,716,9641 *Model: Orange Posiedon 2000.iap; values in whole 2003 Dollars. M.Cubed 13 Policy Analysis'for the Public and Private Sectors Economic and Fiscal Impacts of Proposed Huntington Beach Desalination Project Final Report, June 2003 Table 11. Plant Operations Phase: Orange County Other Property Income Impacts F ------- Industry Sector Direct* Indirect Induced* Total* Agriculture $0 $4,989 $8,513 $13,502 Mining $0 $27,642 S14,104 $41,746 Construction $0 $585,467 $7,775 $593,242 Manufacturing $0 $204,591 $107,677 $312,267 TCPU $2,556,860 $534,640 22 $123$141,0 2,522 Trade so: $208,646 $307,665 $516,811 FIRE $0 $673,282 $1,075,767 $1,749,050 Services -$0 $355,852 $220,446 $576,298, Government $0 -$10,356^ $8,7651 -$1,590 Domestic service $0 so Sol S11 Total Other Prop. Incomel $2,556,860 $2,584,753 $1,891,7351 $7,033,348 *Model, Orange Posiedon 2000-iap-, values in whole 2003 Dollars. Table 12. Plant Operations Phase: Orange County Indirect Business Tax Revenue Impacts' Industry Sector Direct* Indirect* Induced* Total* Agriculture so $457 $678 $1.135 Mining so S4,429 $2,259 $6.687 Construction $o $40,475 $596 $41,071 Manufacturing $0 S14,037 $6,830 $20,866 TCPU** $1,968,636 $136,144 $32,968 $27137,749 Trade $0 $180,938 $248,331 $429,269 FIRE $0 $85,800 $174,408 $260,209 Services- $0 $71,827 $48,529 $120,3561! Government $0 $0 $0 Sol Domestic service $o $0 $0 $ ............. Total Ind. Bus. �axes $1,968,6361 $534,107 $514,599 $3,017,342 *Model: Orange Poseidon 2000.iap.- values in whole 2003 Dollars- Direct property tax revenues were calculated outside the model based on an estimate of plant assessed value. Indirect Business Taxes(IBT) are comprised primarily of property and sales tax revenues, but also include excise taxes, license and registration fees. M.Cubed 14 Policy Analysis for the Public and Private Sectors Economic and Fiscal Impacts of Proposed Huntington Beach Desalination PrQiect Final Report, June 2003 4. Fiscal Impact Analysis The principal fiscal impacts of the proposed desalination facility relate to the generation of sales, utility and property tax revenues. The IMPLAN analysis produced estimates of sales tax generation during the plant construction and operation phases of the project. Utility tax revenues are based on the estimated purchases of electricity during plant operation- Construction of the facility will also add approximately $186.5 million to the local property tax base_' The apportionment of this incremental increase in sales, utility, and property tax revenues is presented in this section. 4.1. Apportionment of Sales Tax Revenue Increment The IMPLAN analysis estimated Orange County sales tax receipts of approximately $1.5 million during the two-year construction phase of the project. Table 13 shows how these revenues would be apportioned between state and local entities. Table 13. Sales Tax Revenue Apportionment: Plant Construction Phase Sales Tax Revenue Apportionment Sales Tax Rate Revenue Revenue Decomposition Share Allocation State General Fund 4.75% 61-3% $930,613 Local Revenue Fund 050% 6.5% $97,959 ............................ State General Fund 015% 12% $48,980 Local Public Safety Fund 0 50% &5% ................................. ................................ $97,959 Local (City&County) 1.00% 1 12�9% $195,918 ....................... .......... County Transportation Fund 0-25% 1 3.2% $48,980 ...................... al Measure M (transport tax) 0.50% 6_5% $97959. ............................. E LT 7.75% 100.0% $1,51 368: The basis for property tax calculations was taken to be the expected cost of plant construction less the cost of facilities that will be publicly owned and therefore not subject to property tax. The Product Water Tank, Pump Station, and Delivery Pipeline facilities shown in Table 3 are expected to be publicly owned. Therefore these costs were deducted from the total construction cost to estimate the property tax basis of the project, M,Cubed 15 Policy Analysis for the Public and Private Sectors Economic and Fiscal Impacts of Proposed Huntington Beach Desalination Project Final Repcit, June 2003 Likewise, the IMPLAN analysis estimated Orange County sales tax receipts would increase by approximately $0.5 million annually during the plant operations phase of the project. The apportionment of this annual increment in Orange County sales tax revenue is shown in Table 14. Table 14. Sales Tax Revenue Apportionment: Plant Operations Phase .......... ....................................---------- Sales Tax Revenue Apportionment Sales Tax Rate Revenue Revenue - Sales�e Decomposition I hare 1 Allocation __------ - I---J 61 a3_12,81 State General Fund 4.75% J ............................. ........... Local Revenue Fund 0.50% 6_5% 32,928 $ .............. ....................... State General Fund 0,25% 12% $16,464 Local Public Safety Fund 0.50% 6.5% $32,928 .................... Local (City&County) 1.00% 12.9% $65,855 County Transportation Fund 0.25% 12% $16,464 .................... Local Measure M (transport tax) O�50% 6�5% $32,928, ................................ .......... Total 7.75% 100,0% $510,380 4-2 Utility Tax Revenue Apportionment The City of Huntington Beach utility tax rate is 5%. This rate is charged against gross electricity purchases paid to the taxed entity's energy service provider. The tax is not assessed against electricity purchases related to water pumping. The analysis assumed that 94% of the plant's electricity purchases would be for water pumping and 6% would be for non-pumping purposes. Thus, of the $16.8 million in annual electricity purchases shown in Table 4, approximately $1.0 million would be taxed, resulting in annual utility tax revenues for City of Huntington Beach of$0.05 million. 4.3 Property Tax Revenue Apportionment The proposed facility would add approximately $186.5 million to the local property tax roles. Because the facility would be within the Southeast Coastal Redevelopment Area and because of changes in the tax increment for this Redevelopment Area expected to take place in 2004, the apportionment of property M.Cubed 16 Policy Analysis for the Public and Private Sectors Economic and Fiscal impacts of Proposed Huntington Beach Desalination Project Final Report, June 2003 tax revenues is somewhat complicated and subject to uncertainty. Discussions with Orange County's Auditor/Controller's Office resulted in the following conclusions.9 • The Southeast Coastal Redevelopment Area was established with a 2001 base year value of $103,941,351. The AES power plant parcel was assessed at $101,865,641 at that time. The plant was reassessed at $325,209,214 in 2002, which contributed an additional $223,343,573 in tax base to the RDA10 since taxes collected above the base year value (increment) are provided to the RDA, subject to deductions specified by current Community Redevelopment Law discussed below. • In 2004, the AES plant will be transferred from the local property tax rolls to the state rolls. Because of this transition, the RDA base year will be reduced by $101,865,641, making the new base year value $2,075,710." It is also our understanding that new properties, such as the proposed desalination plant, will add to the RDA increment only and will not impact the base year value. • As a result of the previous points, all of the assessed valuation of the proposed plant would contribute to the RDA tax increment, subject to deductions and reallocations imposed by current Community Redevelopment Law (California Health & Safety Code section 33607.5). These requirements state that 20% of'the tax increment be directed to a housing set-aside fund. Of the remaining 80% of the tax increment, 25% is to be passed through to all County and local tax entities and apportioned according to current law. The remainder goes to the RDA. Based on the above considerations, the expected apportionment of annual property tax revenue from the proposed facility is shown in Table 15 and Figure 1 9 Personal Communication with Neal Gruber, County of Orange, Auditor/Controller's Office, April 21,2003, G Redevelopment Agency of Huntington Beach. I Negotiations resulted in an agreement to reduce the RDA's tax increment by the original 2001 AES assessment rather than the 2002 reassessment, M.Cubed 17 Policy Analysls for the Public and Private Sectors Economic and Fiscal Impacts of Proposed Huntington Beach Desalination Project Finial Report. June 2003 Table 15. Expected Apportionment of Annual Property Tax Revenue _........... ._ � - Assessed Value of Property $186,500;000 Property Tax Rate 1.01% Annual Property Tax (2003 dollars) $1,883,650 Housing fund set-aside $376,730 Redevelopment Agency of Huntington Beach � $1,130,190 Apportioned to City& County Agencies $376,730 City&County Agency Apportionment Share Amount _ (2003 dollars) City of Huntington Beach 15.5% v $58,393 Schools 55.0% $207,202 County 6.0% $22,604 Special Districts 7.0% $26,371. Education Revenue Augmentation Fund (ERAF) 16.5%1 $621,160 Total 100.0%l $376,730 M,Cubed 18 Policy Analysis for the Public and Private Sectors Economic and Fiscal Impacts of Proposed Huntington Beach Desalination Project Final Report, June 2003 County Housing Fi,n 2'1 h r, s Cini of Huntington 6eertt Specirl Dist'irs v RDA,City Huntington Beach �s � Oa^i s»� 63 fo .�... ,� a�.:.,...,. ;y Figure 1. Expected Apportionment of Annual Property Tax Revenue M Cubed 19 Policy Analysis for the Public and Private Sectors _ � r Deficiencies in DREIR for Poseidon Desalination Facility relating to Biological Impacts including Entrainment, Impingement, and Salinity 2 m � ■ The DREIR inappropriately separates the operations M and impacts of the power plant from those of the z proposed desalination facility, creating a false dichotomy between the two. r ■ Co-located desalination facilities may, in fact, cause 00 adverse effects in addition to those caused by the power plant. ■ Another selectively excluded reference, discussed A immediately below, is the entrainment study recently completed pursuant to the Energy Commission requirements. Reference:Coastal Commission Letter May 26,2005,page 8 i Entrainment and Impingement ■ EPA defines entrainment as"the incorporation of all stages of fish and shellfish with intake flow entering and passing Ithrough a cooling water intake structure" (EPA 2002) a ■ Impingement refers to the entrapment of fishes and shellfishes on screening structures during cooling water f withdrawals. ■ At the AES HGBGS,juvenile and adult fishes that are entrained in the cooling water intake structure are drawn I downstream to the generating screening structure where they are susceptible to impingement on the traveling screens. Source:AES Huntington Beach L.L.C.Generating Station Entrainment and Impingement Study Final Report(April 2005) i I 1 t AES Huntington Beach L.L.C. Generating Station Entrainment and Impingement Study Final Report (April 2005) ■ Loss of hundreds of millions of individuals of various species each year due to entrainment and impingement caused by the power plant. ■ Organisms from just eleven target species lost due to entrainment are equivalent to those produced in up to almost two square miles of the near-shore waters off Huntington Beach. i } ■ This is a significanti greater.impact than the effects described in the DREIR. F ■ "We recommend further revisions of the DREIR incorporate the results of the Energy Commission study into its analyses." p� Reference:Coastal Canmision Lew May 26,2005,page 9 l Table 5-1 Entrainment Summary I Source:AES Huntington Beach LL.C.Generating Station Entrainment and Impingement Study Final Report(April 2005) Estimated Annual Entrainment ■ Goby Complex: 113,166,834 ■ Northern Anchovy: 54,349,017 ■ Spotfin Croaker: 69,701,589 ■ Queenfish: 17,809,864 ■ White Croaker: 17,625,263 ■ Black Croaker: 7,128,127 ■ California Halibut: 5,021,168 I I { 2 i Fish Species Entrained and Impinged at AES t 1 Table 7. 2003 fish impingement totals (top 10 species) from 11 coastal generating stations in the SCB(Southern California Bight) Source:AES Huntington Beach LLC.Generating Station Entrainment and Impingement Study Final Report(April 2005�__ Fish impingement abundance was highest at SONGS E and followed by the HBGS a i I HBGS Contribution ■ Queenfish: No: 10.8% Wt. 12.5% ■ Shiner Perch: No: 41.9% Wt. 53.9% y ■ White Croaker: No: 53.5% Wt. 34.4% ■ White Seaperch: No:16.8% Wt. 30.6% f ' 3 i i Table 8. 2003 macroinvertebrate impingement totals (top 10 species)from 11 coastal generating stations in I the SCS(Southern California Bight) Source:AES Huntington Beach LLC.Generating Station Entrainment and _Im iP ngement Study Final Report(April 2005) T �� Impingement abundance was highest at the HBGS (91% of the Bight-wide total) HBGS Contribution ■ Dendronotus frondosus: No: 100% Wt"100% ! ■ Yellow Rock Crab: No: 69.4%Wt: 63.5% ■ Pacific Rock Crab: No: 33.3%Wt: 7.1% j ■ Graceful Rock Crab: No: 84.4% Wt: 48.3% ■ Tuberculate Pear Crab: No: 95.1% Wt:94.6% ■ Red Rock Shrimp: No: 24.5%Wt: 22.5% ■ Striped Shore Crab: No: 35.3% Wt: 18.0% ■ Red Rock Crab: No: 92.5%Wt: 96.6% 1 ks i Marine Biological Resources: Effects of the Proposed Desalination Facility Discharge Reference:Coastal Commission Letter May 26,2005,page 11 ■ The areas affected by salinities of more than 10% above background range up to several dozen acres, while areas of between 1%and 10% above background can cover nearly { 2000 acres. ■ The area predicted to exceed U.S. EPA guideline of 4 ppt increased salinity could extend up to about 600 feet downcurrent ■ These areas of increased salinity, along with the area lost to biological production due to entrainment as described above, I represent a significant portion of the Huntington Beach j coastline, and do not appear to be the insignificant impact described in the DEIR E I 4 r jThe DEIR does not properly assess the short,-medium, and long-term operational changes likely to occur in the power plant operations and how these changes may affect the proposed desalination facility. ■ Poseidon's agreement with AES is much longer than the power 1 plants energy contracts. !f ■ Poseidon has a 38-year agreement with AES. i ■ AES has 10-year approval from the CEC,expires in 2011. ■ Power Plants NPDES permit is up for renewal every 5 years,with changes from EPA requiring reductions of between 60/o and 95%in mortality from entrainment and impingement ■ AES energy contracts have terms of less than a year, three years, or until 2018. ■ Future development plans submitted by AES to CEC in November 2004 did not mention on-site desalination facility i i SURF CITY OR SMOKESTACK CITY? S ' try gg t -�' isxrr"g,w—g 4 '.y4,1�p`""ie"ex �2^4X` ita Tv4ty,° v,F�l�aq�3'v�i y+H s,t�g a� q '4F �. &" ,� ,nit d d} s•e,,,�'` I I 5 �c BUC =IRDFOR-COUNCL i •J"' GTY CLEPo(OFFICE ,gANLRYtOl,GTYCLERIC POSEIDON PIPELINE OBSTACLES AND IMPACTS Poseidon Resources 48" Force Main Installation Obstacles along Reach 2 of Primary Route (Newland along Hamilton to Brookhurst): ✓ Proximity to ASCON Toxic Waste Site Berm ✓ Talbert Drainage Channel ✓ OCSD 108" Bushard Trunk Sewer Pipe POSEIDON PIPELINE 0 • AND-IMPACTS Poseidon Obstacles alongRoute (Newland along Hamilton . : .. Proximity• o ASCON TalbertDrainage •OCSID 108" . Trunk Sewer Pipe WE Miol lilt] a � y t5ft R ' YR n � x. 4w 1 g �� ` e NPIPELINE REA'JChH#2 HANIILTONAVENUE' x ' I) ING BUSHARD & HAMILTON' ._ OCSD SEWER PIPE " •' 1 1 POSEIDON PIPELINE OBSTACLES ON REACH #2 1.PROXIMITY TO THE ASCON TOXIC WASTE SITE 23RAVERSING TALBERT DRAINAGE CHANNEL 33RAVERSING 108" DIAMETER OCSD BUSHARD TRUNK SEWER PIPE POSEIDON PIPELINE OBSTACLES ON REACH#2 1 .PROXIMITY TO THE ASCON TOXIC WASTE SITE BERM �� f4•tr• h xry �S APOSEIDO wUSI G A qN�ON fY� 2 a3 V 3 POSEIDON PIPELINE OBSTACLES ON DRAINAGE TALBERT DRAINAGE CHANNEL BRIDGE Irv.. aY TMe,�v�ek� tits. � 1 y 4 a r;`! r, i POSEIDON PIPELINE OBSTACLES ON REACH #2 3.TRAVERSING 108" DIAMETER OGSD BUSHARD TRUNK. SEWER PIPE r BUSHARD STREET PAVEMENT BASE 10" COMPACTED SOIL COVER 47" 6'/a' BASIC SEPARATION STANDARD(t) 16' rrr::.;rrra.rr;psi:;r.;,rrrr:riiii:^«;ii>$i:•r:r;ru;r.}i.;hu w�is 5::r,;;r SEWER PIPE OCSD SEWER �g THICKNESS 10" PIPE 108" BASIC SEPARATION STANDARD(b) 16' _,�..�.46"PIPE TUNNELED UNDER SEWER LINE The installation of the Poseidon R�srources water transmnsston fine vJ;lJ cuse nuni negative impacts to the corntpunityalong its primary muelthat have no minqation strategies S There at c,no o�,ernding benefits to t no surrounding community fo.th�damage and disruption caused bv the installation of the Poseidon Resources water tran5nnission fir- 4 There isthe octentia!for long-term darnage to the surrounding comm.nity fine due to overcoming mr,significant and mavoidalbte obstacles faced by me project 5 Poseidon Resources ties not done an adequate job tri consuning�Nfth the Responsible Partiesand agencies involved in overcoming the significant and addressmg the negative impacts with collaborative TIftigation strategies This c u!d iead to unforesecn consequences and conditions unacceptable to the • 6 CONCLUSIONS : 1 . The Poseidon Resources R-EIR is incomplete and inadequate in addressing the significant environmental impacts of its water transmission line installation. 2. The installation of the Poseidon Resources water transmission line will cause numerous negative impacts to the community along its primary route that have no mitigation strategies. 3. There are no overriding benefits to the surrounding community for the damage and disruption caused by the installation of the Poseidon Resources water transmission line. 4. There is the potential for long-term damage to the surrounding community associated with the installation of the Poseidon Resources water transmission line due to overcoming the significant and unavoidable obstacles faced by the project. 5. Poseidon Resources has not done an adequate job in consulting with the Responsible Parties and agencies involved in overcoming the significant and unavoidable obstacles to the installation of its water transmission line, and in addressing the negative impacts with collaborative mitigation strategies. This could lead to unforeseen consequences and conditions unacceptable to the community. AS FROM 85 MEETIOF 7 R'�' 714E OFFICE SOUTHEAST HUNTINGTON BEACH NEIGHBORHOODjftYfMlq'TY CLERK OPPOSING THE POSEIDON RESOURCES CORP. DESALINATION PLANT Dear Huntington Beach City Council: Since 2001, the Executive Board of the Southeast Huntington Beach Neighborhood Association (SEHBNA) has opposed the establishment of a massive desalination plant by.. Poseidon Resources Corp. (Poseidon) near the AES power plant in Southeast Huntington Beach. SEHBNA has pressed for rejection of the initial Environment Impact Report (EIR) on the grounds that several general and specific concerns to our area were not adequately addressed by it, and that potentially unacceptable impacts to the quality of life of our area residents could result. These concerns included: l. The desal plant would increase pollution to our air and water that would degrade our coastal environment and harm our reputation as a resort destination. . The desal plant would add further growth to an over-industrialized part of the city, and it would "enshrine" the aging AES power plant and its visual blight. 3. Poseidon, based upon its poor performance with similar projects in other areas (most notably Tampa Bay, FLA), may.:not be capable of living up to its promises to build and run the largest desalination plant in the country. 4. Promised financial benefits to the city under an agreement with Poseidon may prove illusory and impossible to guarantee. S. Huntington Beach would lose its ability to protect its citizens and public interests from any adverse effects or conditions`if a municipal water district or other government agency achieved an ownership interest or controlling influence in the desal plant. 6. Poseidon's desal plant would NOT be producing water for Huntington Beach. It would allegedly be sold to new communities in South Orange County. Poseidon's desal water would be much more expensive than the current sources of water serving our city. Many other concerns affecting local citizens, and Southeast Huntington Beach residents in particular, were expressed previously. However, a devastating new concern addressed by neither the old nor the new EIR has arisen that demands the attention of everyone in our area. Section G of the EIR deals with the water transmission line routes from the desal plant to its terminus in Costa Mesa for carrying Poseidon's water to its customers in South Orange County. All of the proposed routes call for a 42 to 48 inch diameter force main to be installed along the length of Hamilton from Newland to Brookhurst (a distance of one and a half miles). There have been major negative impacts already with the similar installation of the O.C. Sanitation District sewer pipe, especially along Bushard. The pounding of heavy equipment combined with the extensive and destructive dewatering process has caused damage and destabilization to many residential properties in the construction area. Poseidon's water transmission pipe could be even more damaging and would pose a significant and continuing threat to our area. It is totally unacceptable for this concern to not be more completely addressed by the EIR and the responsible parties, especially since the city would be involved in litigation for damages allowed by this project. The only way to guarantee our safety and quality of life is to reject the desal plant and its current EIR. Because Southeast Huntington Beach residents will receive none of the benefits and all of the negative impacts of this project, we must oppose this project now and demand that our concerns be fully addressed. We, the undersigned, ask that our City Council reject the Poseidon EIR and act to protect the interests of the city in Southeast Huntington Beach. SOUTHEAST HUNTNGTON BEACH NEIGHBORHOOD PETITION f OPPOSING THE POSEIDON RESOURCES CORP. DESALINATION PLANT We, the undersigned, ask that our City Council reject the Poseidon EIR and act to protect the interests of the city in Southeast Huntington Beach. Sign Name Residence Address For Official Use 1 -------- - -- ---`- --- ---------------- d F Print Name Sip Naff— Res�n�GAdd Sass 2 Pn Name--------------- ---------- ' faCJ�,�LQif'r' / t j' Sign Name / c Residence Address 1 3 ---Print Name V �� �1 �� f 6 Sign Name -- Residence A9dress---------------------- Print Name Sign Name CwA --_-__- Residence Address 5 --------- ------------ =- -- -------- �--tom/ Print Nam _ Sign Name �— w n Residence Address `q e ^1 Print Name%1(IaA' I _,We_ L4.A ______-- ^ 4 1- 4� A� f Z` f Sign Name KK•/�cam• Residence Address -------- -- - - 7 Print Name--- - �3►l� 117 Sign Name -------------- Residence Address g ----- ---- - �------------ 9Q0#t AJ/6tf.454. �4 Print Name Sign Name ; Residence Address g --------- --------- ------------------------ "/662 IJ!C7 UEf. GI RCI� Print Name STSVe Iff- —W-Z-:�I l 4*twerp,4J Sign Name ° Residence Address 10 Print Name Sign Name Residence Address � L_ foes b 2�,� 87, p A- 11 p N �J Sign Ngme Residence Address 12xv. �.�6 yz Po�.� N�srFN ------ - ----- ----------------------- Print Name . Sign Name�/ / ___- --- Residence Address 13 ------- '//-d„/!/ - - --- - --------- cj Print Name 26 q--6 Sign Name Residence Address 14 Print Nam (24 Sign Name Residen�c(e Address ` � n 15 -------- -- ___ -a --- -- ------ (J l rr'// � Print Name Sign Name ----- Residence Address r 16 Pri))Name - ---------------- L Sign Name Residence Address 1 7 Print Nam--- -- -- - -- -------- ------------ l/1 V Vt(i� a 264 Sig ame Residence Address 2 1 1 Pi Names -- --- - ------ ----Q--------- �/& ✓ A" _ Sig m ----- Residence Address 19 P'nt a {V t] ��� Q-^ . Sign Name ----------------- Residence Address 20 Print ame �� i' SOUTHEAST HUNTINGTON BEACH NEIGHBORHOOD PETITION OPPOSING THE POSEIDON RESOURCES CORP. DESALINATION PLANT Dear Huntington Beach City Council: Since 2001, the Executive Board of the Southeast Huntington Beach Neighborhood- Association (SEHBNA) has opposed the establishment of a massive desalination plant by Poseidon Resources Corp. (Poseidon) near the AES power plant in Southeast Huntington Beach. SEHBNA has pressed for rejection of the initial Environment Impact Report (EIR),on the, grounds that several general and specific concerns to our area were not adequately addressed by it, and that potentially unacceptable impacts to the quality of life of our area residents could result. These concerns included: 1. The desal plant would increase pollution to our air and water that would degrade our coastal environment and harm our reputation as a resort destination. �. The desal plant would add further growth to an over-industrialized part of the city, and it would "enshrine" the aging AES power plant and its visual blight. 3. Poseidon, based upon its poor performance with similar projects in other areas (most.notably Tampa Bay, FLA), may not be capable of living up to its promises to build and run the largest desalination plant in the country. 4. Promised financial benefits to the city under an agreement with Poseidon may prove illusory and impossible to guarantee. 5. Huntington Beach would lose its ability to protect its citizens and public interests from any adverse effects or conditions if a municipal water district or other government agency achieved an ownership interest or controlling influence in the desal plant. 6. Poseidon's desal plant would NOT be producing water for Huntington Beach. It would allegedly be sold to new communities in South Orange County. Poseidon's desal water would be much more expensive than the current sources of water serving our city. • Many other concerns affecting local citizens, and Southeast Huntington Beach residents in particular, were expressed previously. However, a devastating new concern addressed by neither the old nor the new EIR has arisen that demands the attention of everyone in our area. Section G of the EIR deals with the water transmission line routes from the desal plant to its terminus in Costa Mesa for carrying Poseidon's water to its customers in South Orange County. All of the proposed routes call for a 42 to 48 inch diameter force main to be installed along the length of Hamilton from Newland to Brookhurst (a distance of one and a half miles). There have been major negative impacts already with the similar installation of the O.C. Sanitation District sewer pipq, especially along Bushard. The pounding of heavy equipment combined with the extensive and destructive dewatering process has caused damage and destabilization to many residential properties in the construction area. Poseidon's water transmission pipe could be even more damaging and would pose a significant and continuing threat to our area. It is totally unacceptable for this concern to not be more completely addressed by the EIR and the responsible parties, especially since the city would be involved in litigation for damages allowed by this project. The only way to guarantee our safety and quality of life is to reject the desal plant and its current EIR. Because Southeast Huntington Beach residents will receive none of the benefits and all of the negative impacts of this project, we must oppose this project now and demand that our concerns be fully addressed. We, the undersigned, ask that our City Council reject the Poseidon EIR and act to protect the interests of the city in Southeast Huntington Beach. SOUTHEAST HUNTNGTON BEACH NEIGHBORHOOD PETITION f ' OPPOSING THE POSEIDON RESOURCES CORP. DESALINATION PLANT We, the undersigned, ask that our City Council reject the Poseidon EIR and act to protect the interests of the city in Southeast Huntington Beach. AR Sign Name Residence Address For Official Use 1 go� Lil/� Print Name ^ G ('gun` Sign Name Residence Address 2 ----- -Z- Z Print Name Sign Name r Residence Address 3 -------- ----------W---L-4----- �l v 7- f�l fG � E C✓! Y' Print Name //I• �V O f r C '7 a C Sign Name Residence Address 'LT1 4 -------- ----- ------ -------- --------- q a Z 7, "tb U t: , �+2 Print Name ChXX"-o ei' Mwpte G4- 91Z4YL Sign N Residence Address 5 ---- -------f--- •G�•---`---J- ------------------ A t f3-a Sk4s !Gibe, kwe-i Print E�� v�J7'ir✓ 7o.cJ 6 Sign Name Residence Address 6 ov, 't11*u�L► � i�r Print Nam� �� — ' u /� Q I efA Sign Name Residence Address r �� 7 ------ -- -- - ---------------- Print Name 4-6 . Sign NameX Residence Address ------ ------- ---�--------=-------------- 90 yZ �s� � � 8 Print Name ON � - 966 e1 Sign Name Residence Address s -------------- ------ -------- ----------- Print Nam Sign Name Residence Address o -------------T------- ----------------------- r ?�y,� Print Name pl Ile Sign Name ----------- Residence Address 11 {�o Vf nGS�c►s� Print a ----------- Print Name Y1 042.2 CA Ct2,U +(0 Sign Name � Residence Address 12 ------- — (�—•'i—L - - -- arb .. Po or /y N-t lal) � Print N,�, ' h Sign Name Resi once Ad ss 13 -Print Name----- -- --- ------=� ��Y---- O A /��°vi� - �4( Sign Name Residence/Address 14 ---------1---- - --------------- �o't 1 T�C�ATT�A W- Print Name ,'«R4- -7:T k \ ` GA Sign Name Residence Address /�n /% v�GJ/U 15 -------- ------------- 96� G�9'Tf� Print N ame 2 Si n Name -- Residence dress 9 16 Prir)) -- ------- -- -- — -------------- Orr. 113 Sign Na Relance Address17 p --- Prin — — ------- Sign Na Residence Address 18 ---- ----------------------- ----------------- Print Siqn am ^ ,/, _ Re�idenc�ddress�� .^ 19 --'------�--`—,+-- —�—J—r—•=-----~---3r—+—/v—[—`T`--1^—\'-------- Cam]`(,J� Print Name Sign a Resident Addre 20 - -- -- -- ---------------------------- -13 � '9f�(I � Print Name SOUTHEAST HUNTINGTON BEACH NEIGHBORHOOD PETITION OPPOSING THE POSEIDON RESOURCES CORP. DESALINATION PLANT Dear Huntington Beach City Council: Since 2001, the Executive Board of the Southeast Huntington Beach Neighborhood Association (SEHBNA) has opposed the establishment of a massive desalination plant by Poseidon Resources Corp. (Poseidon) near the AES power plant in Southeast Huntington Beach. SEHBNA has pressed for rejection of the initial Environment Impact Report (EIR) on the grounds that several general and specific concerns to our area were not adequately addressed by it, and that potentially unacceptable impacts to the quality of life of our area residents could result. These concerns included: 1. The desal plant would increase pollution to our air and water that would degrade our coastal environment and harm our reputation as a resort destination. 2,. The desal plant would add further growth to an over-industrialized part of the city, and it would "enshrine" the aging AES power plant and its visual blight. 3. Poseidon, based upon its poor performance with similar projects in other,areas (most notably Tampa Bay, FLA), may not be capable of living up to its promises to build and run the largest desalination plant in the country. 4. Promised financial benefits to the city under an agreement with Poseidon may prove illusory and impossible to guarantee. 5. Huntington Beach would lose its ability to protect its citizens and public interests from any adverse effects or conditions if a municipal water district or other government agency achieved an ownership interest or controlling influence in the desal plant. 6. Poseidon's decal plant would NOT be producing water for Huntington Beach. It would allegedly be sold to,newcommunities in South Orange County. Poseidon's desal water would be much more expensive than the current sources of water serving our city. Many other concerns affecting local citizens,.and Southeast Huntington Beach residents in particular, were expressed previously. However, a devastating new concern addressed by neither the old nor the new EIR has arisen that demands the attention of everyone in our area. Section G of the EIR deals with the water transmission line routes from the desal plant to its terminus in Costa Mesa for carrying Poseidon's water to its customers in South Orange County. All of the proposed routes call-for a-42 to 48.inch diameter force main to be`installed along the length of Hamilton from Newland to Brookhurst (a distance of one and a half miles). There have been major negative impacts already with the similar installation of the O.C. Sanitation District sewer pipe, especially along Bushard. The pounding of heavy equipment combined with the extensive and destructive dewatering process has caused damage and"destabilization to many residential properties in the construction area. Poseidon's water transmission pipe could be even more damaging and would pose a significant and continuing threat to our area. It is totally unacceptable for this concern to not be more completely addressed by the EIR and the responsible parties, especially since the city would be involved in litigation for damages allowed by this project. The only way to guarantee our safety and quality of life is to reject the desal plant and its current EIR. Because Southeast Huntington Beach residents will receive none of the benefits and all of the negative impacts of this project, we must oppose this project now and demand that out concerns be fully addressed. We, the undersigned, ask that our City Council reject the Poseidon EIR and act to protect the interests of the city in Southeast Huntington Beach. SOUTHEAST HUNTNGTON BEACH NEIGHBORHOOD PETITION f OPPOSING THE POSEIDON RESOURCES CORP. DESALINATION PLANT We, the undersigned, ask that our City Council reject the Poseidon EIR and act to protect the interests of the city in Southeast Huntington Beach. 7 ,Sip ---------------- Residence Address For Official Use 1 Print Name ------ ---- - �f1a rt//�v�L Gf 2 > 6.4 (I Co TName Residence Address 2 =. ti._ �=-- --------- ..=----------- Sign N --------- Residence Address Print Name Sig a e Residence Addres 4 --- ------------ Print me w_ I Sign N Resid nce Address (�i1vl�J7 5 ----- - ----------- -- - - - -------- �o'lI Mud Circe Print IN �to - •� ��q/ Sign Name Residence Address /K�/ ---- - - ------- -- ------ --------- v 2L. C LAZ 6 -Print Name Vim-• Q� �• Z! 1 VR Sign �me Residence Address .��� /7•S 7 (- P - e---- ---- - - '�'='------ fof32L N�l� vNnN T V •�• Sign Name �4_lf Residence Address g ------------ - --- W I�-------- fv - Print Name 1 ; � G Sign Name Residence Address g ------- an 0 - - 909 2 N 'o�a e•/ C••• Print Name J 6P Sign Name -� Residence Ad ress l 10 r' iG�lrh -fir- Print Name Sign Name //�h� !/•`�/ ��----- Residence Address Print Name I Sign Name( Residence Address"�� � Q 12 ------ - --' -- ------- -1f�2 I�O�I`N,, �✓ Print Name Sign N e, 1•.. _ ------------------ Rdd Address �ssPw V 6 4 C t�- 1 s Prin — Sign Name Residence Address Print Name 14 ------ - - -- ----------------------- �W Z ° !te Cl-1 It bA07 ! z.6y9 Sign ame Residence Address 15 - - ---- ----- ----------- Print Name I� tAv ft k- CA , V Sign Residence Address ------ 16 - - - -- ---- g022 �0blo tee N, . Pri ame &A]b h Sig me -------- Residence Address -- - ---- ----- ------ ----- v/(� 1 Print Name ( a JM— 1 ` Sign Name ------------------ Q 6W1 ddress� 46, J �. 18 Print Namee-el— — ——— _(A`U Sign Name tddres ov`' C419 Y` Print Name f4x;� &�,,CA Sign Name ------------------------ Residence Address 20 0 '9 AA FA kw S W a oizA 2 Print Name--- ---- 14 SOUTHEAST HUNTINGTON BEACH NEIGHBORHOOD PETITION OPPOSING THE POSEIDON RESOURCES CORP. DESALINATION PLANT Dear Huntington Beach City Council: Since 2001, the Executive Board of the Southeast Huntington Beach Neighborhood Association (SEHBNA) has opposed the establishment of a massive desalination plant by Poseidon Resources Corp. (Poseidon) near the AES power plant in Southeast Huntington Beach. SEHBNA has pressed for rejection of the initial Environment Impact Report (EIR) on the grounds that several general and specific concerns to our area were not adequately addressed by it, and that potentially unacceptable impacts to the quality of life of our area residents could result. These concerns included: 1. The desal plant would increase pollution to our air and water that would degrade our coastal environment and harm our reputation as a resort destination. The desal plant would add further growth to an over-industrialized part of the city, and it would "enshrine" the aging AES power plant and its visual blight. 3. Poseidon, based upon its poor performance with similar projects in other areas(most notably Tampa Bay, FLA), may not be capable of living up to its promises to build and run the largest desalination plant in the country. 4. Promised financial benefits to the city under an agreement with Poseidon may prove illusory and impossible to guarantee. 5'. Huntington Beach would lose its ability to protect its citizens and public interests from any adverse effects or conditions if a municipal water district or other government agency achieved an ownership interest or.controlling influence in the desal plant. 6. Poseidon's desal plant would NOT be producing water for Huntington Beach. It would allegedly be sold to new communities in South Orange County. Poseidon's desal water would be much more expensive than the current sources of water serving our city. Many other concerns affecting local citizens, and Southeast Huntington Beach residents in particular, were expressed previously. However, a devastating new concern addressed by neither the old nor the new EIR has arisen that demands the attention of everyone in our area. Section G of the EIR deals with the water transmission line routes from the desal plant to its terminus in Costa Mesa for carrying Poseidon's water to its customers in South Orange County. All of the proposed routes call for a 42 to 48 inch diameter force main to be installed along the length of Hamilton from Newland to Brookhurst (a distance of one and a half miles). There have been major negative impacts already with the similar installation of the O.C. Sanitation District sewer pipe, especially along Bushard. The pounding of heavy equipment combined with the extensive and destructive dewatering process has caused damage and destabilization to many residential properties in the construction area. Poseidon's water transmission pipe could be even more damaging and would pose a significant and continuing threat to our area. It is totally unacceptable for this concern to not be more completely addressed by the EIR and the responsible parties, especially since the city would be involved in litigation for damages allowed by this project. The only way to guarantee our safety and quality of life is to reject the desal plant and its current EIR. Because Southeast Huntington Beach residents will receive none of the benefits and all of the negative impacts of this project, we must oppose this project now and demand that our concerns be fully addressed. We, the undersigned, ask that our City Council reject the Poseidon EIR and act to protect the interests of the city in Southeast Huntington Beach. SOUTHEAST'HUNTNGTON BEACH NEIGHBORHOOD PETITION OPPOSING THE POSEIDON RESOURCES CORP. DESALINATION PLANT We, the undersigned, ask that our City Council reject the Poseidon EIR and act to proteck the interests of the city in Southeast Huntington Beach. Sign Name ----------- Residence Address For Official Use 1 Print Name 'I , J��� C?tc La�j' �rS(c 7 0 Sign Name ~� Residence Address [-Print Name,./,- Yv� L/ ✓ / > Sign Name G Residence Address -----------------/ ---------- Print Name / � _,.c.l� �%f� 9.ZLY6 Sign Na—:� Residence Address Print Name Sign Name , Residence pppddress pil �q �y Print Name ------ -- ---------------Sign N Residence Address Print Name 0 , y r } i�l_.N—F'- /eyi l✓� t , er . ✓� ezC Calf r /f 1 dance AGtlress �}r'Si a Resi t_^ 7 --'-_---- =- -- -- � C®L6r� S Pri e Sign Name < Residence Address Print Name o /1/T c . ( A qc 12 P Sign �avC ,y ,►�/��}1`�`.._—. Reysidence Address Pr Name P6 V Sign Name _ Residence Address 10 Sign N _.. _. Resioenc�Addre¢ 11 Print Name Y _ n a�1 QA +? 11 Sign Name- f ---- __ Resi ce��s .�1�M—� Si n Name Residence Address 13 P n1JJame i Sign � -- Res�nce Address " A U rf-il� 14 -- - - - - ------, - ------ ,: r qZ. Prin me Sign a '� .�' ti fr Residence Address _ 15 - _ 4 - ------- ---------- q P F Prin N -_-� r 1061 Apr'ame - ----�' Resi ce Addr nN ---- - ---- ------------------- S��S"� 1� Pricy Name Sign Namaf Re idence Address ^ elcl ---- -- - �;' ; --------------- � C- z- Print Name! - Sign NamV ��-- _ Reside 7Address 18 '----- --- --- ---------------nt Nm / ,tG 4 Sign Name Residence Address le 19 ------------ ` - - ---------------- Print Name Sign Name�/ • �j � p�7A'VV ------- Residence Address VJ (Q`/'/`� L J 20 ------ - - =------ ---- ---------- t Print Name /WWI KtKaw 2' . SOUTHEAST HUNTINGTON BEACH NEIGHBORHOOD PETITION OPPOSING THE POSEIDON RESOURCES CORP. DESALINATION PLANT Dear Huntington Beach City Council: Since 2001, the Executive Board of the Southeast Huntington Beach Neighborhood Association (SEHBNA) has opposed the establishment of a massive desalination plant by Poseidon Resources Corp. (Poseidon) near the AES power plant in Southeast Huntington Beach. SEHBNA has pressed for rejection of the initial Environment Impact Report (EIR) on the grounds that several general and specific concerns to our area were not adequately addressed by it, and that potentially unacceptable impacts to the quality of life of our area residents could result. These concerns included: 1. The desal plant would increase pollution to our air and water that would degrade our coastal environment and harm our reputation as a resort destination. 2,. The desal plant would add further growth to an over-industrialized part of the city, and it would "enshrine" the aging AES power plant and its visual blight. .3. Poseidon, based upon its poor performance with similar projects in other areas (most notably Tampa Bay, FLA), may not be capable of living up to its promises to build and run the largest desalination plant in the country. 4. Promised financial benefits to the city under an agreement with Poseidon may prove illusory and impossible to guarantee. 5. Huntington Beach would lose its ability to protect its citizens and public interests from any adverse effects or conditions if a municipal water district or other government agency achieved an ownership interest or controlling influence in the desal plant. 6. Poseidon's desal plant would NOT be producing water for Huntington Beach. It would allegedly be sold to new communities.in South Orange County. Poseidon's desal water would be much more expensive than the current sources of water serving our city. Many other concerns affecting local citizens,.and Southeast Huntington Beach residents in particular, were expressed previously. However, a devastating new concern addressed by neither the old nor the new EIR has arisen that demands the attention of everyone in our area. Section G of the EIR deals with the water transmission line routes from the desal plant to its terminus in Costa Mesa for carrying Poseidon's water to its customers in South Orange County. All of the proposed routes call for'a 42 to 48 inch diameter force main to be installed along the length of Hamilton from Newland to Brookhurst (a distance of one and a half miles). There have been major negative impacts already with the similar installation of the O.C. Sanitation District sewer pipe, especially along Bushard. The pounding of heavy equipment combined with the extensive and destructive dewatering process has caused damage and destabilization to many residential properties in the construction area. Poseidon's water transmission.pipe could be even more damaging and would pose a significant and continuing threat to our area. It is totally unacceptable for this concern to not be more completely addressed by the EIR and the responsible parties, especially.since the city would be involved in litigation for damages allowed by this project. The only way to guarantee our safety and quality of life is to reject the desal plant and its current EIR. Because Southeast Huntington Beach residents will receive none of the benefits and all of the negative impacts of this project, we must oppose this project now and demand that our concerns be fully addressed. We, the undersigned, ask that our City Council reject the Poseidon EIR and act to protect the interests of the city in Southeast Huntington Beach. SOUTHEAST HUNTNGTON BEACH NEIGHBORHOOD PETITION ' OPPOSING THE POSEIDON RESOURCES CORP. DESALINATION PLANT We, the undersigned, ask that our City Council reject the Poseidon EIR and act to protect the interests of the city in Southeast Huntington Beach. Sign Name �- ^/� Residence Add ss/� -►�)O For ONicial Use ------- YS:. -=.5 _--------- ----------=- C/2,. 1 Print Name Sign Name / /� A Residence Address /L`tr-^y � + 9� �7 ----------� - `T'T- 'L-I'-!/- -P•^------------------ 2 J Print Name CCJJ C ('If lUf Sign Name ---- Residence Address Print Name uCvr>j A S U/V7-1NCsr&/- r3cAc(-( CA Sign Name Y -------------- Residence Address - Print Name • r 1��e- E fdxki / 9` -/� r � 1/ �jnb(f yl Sign Name V Residertcel�Irreess � L 5 ---------- --- - ----- -- ------- (/ Print Name Sign Name '1 a Residence Address ff rd 6 �7v _ E��'S -- j 7W Z a ------------------ ---- ---------- Print Name �^ A 1 u3 K' 9 1 yo Sign Name /� � �_p � ---- Residence Address Print Name r— Sipn Name 1212, 17 ----- Residence Address Print Name sin Name Residence Address - Vie_ 3 ., Print Name j - � �VA e _ 2 t'q ;Sign Name Residence Address 10 s------ y-- -------------------- ------ �c�/ a7 t/✓���i Print Name / ton N � / Residence Address Print N e c Residence Address p 12 ------- ----- J-G � -=------------- D / a9-�'� Pnt Name Sip ame - Residence Add r� /J/ �V 13 -------------------- 40° - - 6 (W Si a ---- Residence Address 14 � m `� % !L o1i2CE% --------- - - --------------------- ----- t Name Sign Name/7 -� Residence Address 1 C Print Name Sign _---t- - Res ce A�ress_ / ,p^/ (fi -- ------------------------- 9 16 e i e�� S Sign e ---------------------- Residence Address 6 �� 17 Print H Sign Name ` /f --------- Residence Address 18 Print Name t AL-'- c l/ C®�-2Lcxr)' � �&/Zr�it.J /;�^' • ��Ct,.Y-BicJ C."k Sign Name ! Residence Address - ------------- 19 Print Name IV Q� 1 J� .N V Sign Natne/� Residence Address 20 A S 4— /*-/ -----(,�ie _G-- ----------- l I ii� Print Name H y rL. 4- t ►'l yi 6eci c h C -` 0 C.J cl e n I < --N SOUTHEAST HUNTINGTON BEACH NEIGHBORHOOD PETITION OPPOSING THE POSEIDON RESOURCES CORP. DESALINATION PLANT Dear Huntington Beach City Council: Since 2001, the Executive Board of the-Southeast Huntington Beach Neighborhood i Association (SEHBNA),has opposed the establishment of a massive desalination,plant by Poseidon Resources Corp. (Poseidon) near the AES power plant in Southeast Huntington Beach. SEHBNA has pressed for rejection of the initial Environment Impact Report (EIR) on the grounds that several general and specific concerns to our area were not adequately addressed b it, and that potentially unacceptable impacts to the quality of life of our area residents could result. These concerns included: 1. The desal plant would increase pollution to our air and water that would degrade our coastal environment and harm our reputation as a resort destination. 2,. The desal plant would add further growth to an over-industrialized part of the city, and it would "enshrine" the aging AES power plant and its visual blight. 3. Poseidon, based upon its poor performance with similar projects in other areas (most notably Tampa Bay, FLA), may not be capable of living up to its promises to build and run the largest desalination plant in the country. 4. Promised financial benefits to the city under an agreement with Poseidon may prove illusory and impossible to guarantee. 5. Huntington Beach would lose its ability to protect its citizens and public interests from any adverse effects or conditions if a municipal water district or other government agency achieved an ownership interest or controlling influence in the desal plant. 6. Poseidon's desal plant would NOT be producing water for Huntington Beach. It would allegedly be sold to new communities in South Orange County. Poseidon's desal water would be much more expensive than the current_sources of water serving our city. Many other concerns affecting local citizens, and Southeast Huntington Beach residents in particular, were expressed previously. However, a devastating new concern addressed by neither the old nor the new EIR has arisen that demands the attention of everyone in our area. Section G of the EIR deals with the water transmission line routes from the desal plant to its terminus in Costa Mesa for carrying Poseidon's water to its customers in South Orange County. All of the proposed routes call for a 42 to 48 inch diameter force main to be installed along the length of Hamilton from Newland to Brookhurst (a distance of one and a half miles). There have been major negative impacts already with the similar installation of the O.C. Sanitation District sewer pipe, especially along Bushard. The pounding of heavy equipment combined with the extensive and destructive dewatering process has caused damage and destabilization to many residential properties in the construction area. Poseidon's water transmission pipe could be even more damaging and would pose a significant and continuing threat to our area. It is totally unacceptable for this concern to not be more completely addressed by the EIR and the responsible parties, especially since the city would be involved in litigation for damages allowed by this project. The only way to guarantee our safety and quality of life is to reject the desal plant and-its current EIR. Because Southeast Huntington Beach residents will receive none of the benefits and all of the negative impacts of this project, we must oppose this project.now and demand that our concerns be fully addressed. We, the undersigned, ask that our City Council reject the Poseidon EIR and act to protect the interests of the city in Southeast Huntington Beach. e . � EAST HUNTNGTON BEACH NEIGHBORHOOD PETITION ` 1'. GQ NG THE POSEIDON RESOURCES CORP. DESALINATION PLANT 01�c��� \ e undersigned, ask that our City Council reject the Poseidon EIR and act to protect interests of the city in Southeast Huntington Beach. Sign Name ;✓J ----------- Residence Address For Official Use Print Name �/' "/ ��KJ/✓C..� `��'�.rv1(i� ��lD��a���� � ��p� Sign Name ---------------- Residence Address Print Name ` Sign ----- Residence Address Print e C-L A 1"c(-Ll �p Sign Name Residence Address e 4 -- -W� ----- -- `C�---------- Z182`j �.J1rPlaht �2tc,� Printnt Name Name i r ` 13C 14 C A Z `tC Sign Name Residence Address 5 ----------------------------------------------- Print Name Sign Name Residence Address 6 --------------------------------------------- Print Name Sign Name Residence Address 7 --------------------------------------------- Print Name Sign Name Residence Address g --------------------------------------------- Print Name Sign Name Residence Address 9 ----------- --------------------------------- Print Name Sign Name Residence Address 10 ----- ----------------------------------------- Print Name Sign Name Residence Address 11 --------------------------------------------- Print Name Sign Nhme Residence Address 12 --------------------------------------------- Pr nt Name Sign Name Residence Address 13 --------------------------------------------- Print Name Sign Name Residence Address 14 --------------------------------------------- Print Name Sign Name Residence Address 15 nt Name--------------------------------------------- Pr Sign Name Residence Address 16 Prir))Name ----------------------------------------------- Sign Name Residence Address 17 --------------------------------------------- Print Name Sign Name Residence Address 18 Print Name Sign Name Residence Address 19 —Pri—nt----- Name—————————————————————————————————————— Sign Name Residence Address 20 Print Name CITY COUNCIL/ADMINISTRATION Citizen Inquiry 2005 DATE RECEIVED August 01, 2005 W Comment/Opinion INQUIRY # 1 610 ❑ Mayor's Response Mr./Mrs./Ms.: First Name: Last Name: various Title: Organization: Address: City: Huntington Beach State: CA Zip: Phone: Contact Type: Various Qty: 2,301 EMail: Subject: Comments regarding the Poseidon Project (C.1. 1525 - 3 comments in May; C.I. 1548 - 3 comments in June; Cl 1574 - 826 comments in July) Referred To: Department Date Referred #Days Rec/Ref Date Closed #Days Ref/Cls Total Days Planning 8/1/2005 0 8/1/2005 0 0 Topic: Desalination Plant Assignment: None- Comments Only Action: i I i I � j, 77 I Date Closed August 01, 2005 (blank field indicates open file) PLEASE FORWARD A COPY OF YOUR RESPONSE TO ADMINTISTRATION DENISE BALANT Poseidon Contacts - August 2005 Citizen Inquiry 1610 Poseidon Support Support Support Oppose Oppose E Oppose Project Letters E-mails Postcards Letters mails Postcards Total 8/1/05 1 40 41 8/2/05 1 86 87 8/3/05 55 55 8/4/05 1 65 66 8/5/05 19 19 8/8/05 1 3 75 79 8/9/05 6 6 8/10/05 1 1 119 121 8111/05 1 45 46 8/12/05 3 37 40 8/15/05 1 3 50 54 8/16/05 3 1 57 61 8/17/05 2 3 29 34 8/18/05 59 59 8/19/05 1 1 2 45 49 8/22/05 1 1 1 20 107 130 11 8/23/0511 6 2 1 8 140 157 8/24105 1 2 1 1 109 114 8/25/05 5 1 2 3 4 53 68 8/26/05 17 19 2 1 107 146 8/29/05 4 29 2 5 135 175 8/30/051 1 17 123 141 8/31/051 20 2 496 5 30 553 62 P1 568 171 63 1585 2301 Total Comments - Total Comments - Support of Project 636 Opposed Project 1665 Comments Support Oppose Total Comments May, 2005 0 3 3 Citizen Inquiry 1525 June, 2005 0 3 3 Citizen Inquiry 1548 July, 2005 3 823 826 Citizen Inquiry 1574 August, 2005 636 1665 2301 Citizen Inquiry 1610 Total 639 2494 3133 Dear Members of the Huntington Beach City Council: As a Huntington Beach resident, I want you to know that I support the proposed Huntington Beach Water Treatment Facility because: - RECEIVED •Local drought-proof supply-of water • $1.8 million per year in property tax for Huntington Beach AUG 3 1 2005 • $500,000 per year in sales tax for Huntington Beach CITY OF HUNTINGTON BEACF •Trees, paving and other Rnprovements around the current power,plant ADMINI$TQ{tTION OF ICE '� co�/t� Sincerely, ! D G� Lo Nzme: � (nl Address: City, State and Zip Code: / 5; �Z7 Dear Members of the Huntington Beach City Council: As a Huntington Beach resident,I want you to know that I support the proposed Huntington Beach Water Treatment Facility because: •Local drought-proof supply of water • $1.8 million per year in property tax for Huntington Beach ��— b • $500,000 per year in sales tax for Huntington Beach _&:: •Trees,paving and other improvements around the current power plant Sincerely, ` Name: 0 e t n*::t4 Address: 4 04 City, State and Zip Code: Dear Members of the Huntington Beach City Council: As a Huntington Beach resident, I want you to know that I support the proposed Huntington Beach Water Treatment Facility because: •Local drought-proof supply of water j lI 1 5 -rke • $1.8 million per year in property tax for Huntington Beach • $500,000 per year in sales tax for Huntington Beach I( P Y g �p 2 ,47E 5E.2T •Trees,paving and other improvements around the current power plant �O 1M rv%.LL ry I7� Sincerely, Name: - P Address: I "7 f City, State and Zip Code: (Lv.�C�-.�� �2�.a 2c;�to y7 Dear Members of the Huntington Beach City Council: As a Huntington Beach resident,I want you to know that I support the proposed Huntington Beach Water Treatment Facility because: •Local drought-proof supply of water • $1.8 million per year in property tax for Huntington Beach • $500,000 per year in sales tax for Huntington Beach •Trees,paving and other improvements around the current power plant off ILL- Sincerely, ` • .ti- -t, � � 'l ,�r—C.C.�I Name: �° fl I Address: 1 .3 =.5' ( U• t..1j, City, State and Zip Code: ( Dear Members of the Huntington Beach City Council: As a Huntington Beach resident, I want you to know that I support the proposed Huntington Beach Water Treatment Facility because: •Local drought-proof supply of water •$1.8 million per year in property tax for Huntington Beach •$500,000 per year in sales tax for Huntington Beaeh •Trees,paving and other improvements around the current power plant 0 Sincerely, Name:�o O,z-.3/,q N :l, ��, Address: / cc?. � City, State and Zip Coder�� 2 6`-f 7- 6 c,R o Dear Members of the Huntington Beach City Council: A!G 4L��- AsXHuntington Beach resideneXwant you to know that Ysupport the proposed Huntington Beach Water Treatment Facility because: 3�,_r K �, - F,�5�0 S GtvC�- t`(I 2.) •Local drought-proof supply of water • $1.8 million per year in property tax for Huntington Beach zr,vt(�_rieK+ j bs • $500,000 per year in sales tax for Huntington Beach •Trees, paving and other improvements around the current power plant Sincerely, M.&M—s.C.Michell 5761 Castle DR Hunlinglon Beach CA 92649 Name: Address: i—.— Q*.t- —A Tin CnrtP' Dear Members of the Huntington Beach City Council: As a Huntington Beach resident, I want you to know that I support the proposed Huntington Beach Water Treatment Facility because: , Local drought-proof supply of water C-Voy NiS • $1.8 million per year in property tax for Huntington Beach Or 1-"'�'V,j Tk • $500,000 per year in sales tax for Huntington Beach AI/O p/"Lv"�btF pAVA •Trees,paving and other improvements around the current power plant Sincerely, Name: D N OCOlvy✓A- Address: City, State and Zip Code: b`i�f^� Q� } C�} 'LIZb V Dear Members of the Huntington Beach City Council: As a Huntington Beach resident, I want you to know that I support the proposed Huntington Beach Water Treatment Facility because: •Local drought-proof supply of water • $1.8 million per year in property tax for Huntington Beach • $500,000 per year in sales tax for Huntington Beach •Trees, paving and other improvements around the current power plant / N Sincerely, y� , Name: � ��� .lam , �ltJ Address: / 76r 3 i/✓(Y �+ City, State and Zip Code: ,�1���T �� ��i�� C.. Dear Members of the Huntington Beach City Council: As a Huntington Beach resident, I want you to know that I support the proposed Huntington Beach Water Treatment Facility because: Goo� i7�6-4 - 6,AJ6 ,, II ,ur •Local drought-proof supply of water Hd k) Pd 7 �N �5 I d 12 5 • $1.8 million per year in property tax for Huntington Beach G t�T 06-c X • $500,000 per year in sales tax for Huntington Beach �e- •Trees,paving and other improvements around the current power plant �D1.) o 6 2 W)�-T&T_ 151 LLS �� Sincerely, Name: Address: City, State and Zip Code:�I7 Dear Members of the Huntington Beach City Council: As a Huntington Beach resident, l want you to know that I support the proposed Huntington Beach Water Treatment Facility because: •Local drought-proof supply of water • $1.8 million per year in property tax for Huntington Beach • $500,000 per year in sales tax for Huntington Beach •Trees, paving and other improvements around the current power plant Sincerely, h/ Name: / Y��•' C Address:/���> � � 11,�•¢i�i City, State and Zip Code: / T' • �2� � Dear Members of the Huntington Beach City Council: As a Huntington Beach resident, I want you to know that I support the proposed Huntington Beach Water Treatment Facility because: • Local drought-proof supply of water • $1.8 million per year in property tax for Huntington Beach • $500,000 per year in sales tax for Huntington Beach •Trees,paving and other improvements around the current pojr plant Sincerely, JQ Address: Zc'L,-C City, State and Zip Code: _ y�'� 1 of V}O'►� � 1 l J/ 2_4�2 � C� Dear Members of the Huntington Beach City Council: As a Huntington Beach resident, I want you to know that I support the proposed Huntington Beach Water Treatment Facility because: • Local drought-proof supply of water C � • $1.8 million per year in property tax for Huntington Beach • $500,000 per year in sales tax for Huntington Beach •Trees,paving and other improvements ar nd the power plant ,n r Sincerely, " !� ent Name: y� -rX,c\ti►� Address: GV �P c\ NC City, State and Zip Code: 1����\kS\ Q rc� c�j, �..� Q 6<'q7 " 23 �� Dear Members of the Huntington Beach City Council: As a Huntington Beach resident, l want you to know that I support the proposed Huntington Beach Water Treatment Facility because: • Local drought-proof supply of water • $1.8 million per year in property tax for Huntington Beach • $500,000 per year in sales tax for Huntington Beach •Trees, paving and other improvements around the current power plant nt Sincerely, Name: Address: �.3to�- /VC44rza49 City, State and Zip Code: t//✓Tr�.✓ �F.�k',, , �f� �� T Dear Members of the Huntington Beach City Council: As a Huntington Beach resident, l want you to know that I support the proposed Huntington Beach Water Treatment Facility because: • Local drought-proof supply of water • $1.8 million per year in property tax for Huntington Beach • $500,000 per year in sales tax for Huntington Beach •Trees,paving and other im rovements around the current powerplant', (ice L 1 �V �/�d, �y�lv Y'�/ • , N� �T Sincerely, l Name: L-A VytUneC t-t . S-)N-4 I's Address: 1 Z $ OL 2 City, State and Zip Code: 4,J"T «1 C40h Dear Members of the Huntington Beach City Council: As a Huntington Beach resident, l want you to know that I support the proposed Huntington Beach Water Treatment Facility because: • Local drought-proof supply of water - - vT U�)rs C—e 1 • $1.8 million per year in property tax for Huntington Beach • $500,000 per year in sales tax for Huntington Beach •Trees, paving and other improvements around the current power plant Sincerely. Address: ��732 1 r 1 t� 7Z.A L4 rJC l'ity. State and Zip Code: Dear Members of the Huntington Beach City Council: As a Huntington Beach resident,I want you to know that I support the proposed Huntington Beach Water Treatment Facility because: - �6c�itn,. -M •Local drought-proof supply of water • $1.8 million per year in property tax for Huntington Beach • $500,000 per year in sales tax for Huntington Beach -� •Trees, paving and other improvements around the current power plant Sincerely, Name:— -Ar& Address: 16 f P �1�'/ ' L'v arc& City, State and Zip Code: •ems Dear Members of the Huntington Beach City Council: As a Huntington Beach resident,I want you to know that I support the proposed Huntington Beach Water Treatment Facility bepcause: ` �� \ 1 -A � '9 k � ��t Oq� • l�G eK Ov►e\'�wi ro:J I'A � 0 WIC �G�ZOI � �lq Ihnr. f An S A�^ r%,^0 •Local drought-proof supply of water vJ AerwV�JS T'%ort resoUrce5 • $l.8 million per year in property tax for Huntington Beach Over 0A . • $500,000 per year in sales tax for Huntington Beach Ps. GteAyl% kp S WV7 •Trees, paving and other improvements around the current power plant 1 S\k M 5 Sincerely, Name: -I n r\'s Address: City, State and Zip Code: 1" dY1 3 2Cj LA I have lived here in Huntington since I was born -- much longer than about 80% of the residents. As a child, I remember the population sign reading 39,000. 1 have watched the City Council mess up over the years at the meetings personally and on Channel I wholeheartedly support the Poseidon project. It will bring Huntington income that is sorely needed. One concern of mine is the way that part of the coastline looks. Maybe some aesthetic landscaping? SCOTT WATSON Huntington Beach } (AT We are in support of the desalination plant in Huntington Beach. DON and MARILYN MACALLISTER Nobody wants anything near them. Everyone wants power, but not power plants. Everyone likes air travel, but they don't want airports. Nobody wants anything near them, especially if it might help someone else. We are hearing the same things being said about the proposed desalination plant, Poseidon. "Let them put it somewhere else, we don't want it here." 9Not in my back yard). Well to those people saying that, I say this: You're better than that. The people of Huntington Beach are better than that. NIMBYism is a petty reason for petty people. People not like us. Let's not be those people. Let's step up and say yes to the desalination plant. We have an excellent location, next to the AES power plant. And if it's true that most or all of the water produced by the Poseidon plant will go to South County then so be it. If South County wants to pay Poseidon, and Huntington beach through Poseidon's taxes for a renewable resource that's great. It's a win-win for Huntington Beach. We get to claim civic responsibility by providing water in what should be a desert and we get paid in the process. Miles McGraw I wish to voice my support of the Poseidon Water Treatment Facility in Huntington Beach, knowing very well the need for a clean and more dependable water source for Southern California. Desalination using the technique planned by Poseidon is environmentally sound, and locating it adjacent to the existing power plant will improve the appearance of that section of our coast. I am a native Southern Californian, and since 1968 have lived and volunteered in community environmental affairs in Huntington Beach. MARGARET CARLBERG Huntington Beach The desalination plant should absolutely be approved. The region needs the water. Putting saltwater back into the ocean isn't going to harm anything. And Huntington Beach could sure use the $2 million per year that Poseidon would provide in tax revenue. If the city denies the project, then a public water agency is going to come in and build it anyway. And then the city loses all control over the project and loses out on the $2 million per year in tax revenue. This is a no-brainer. Approve the project immediately. ERIC CARLISLE Huntington Beach I would like to register my vote in favor of the planned desalinization plant in Huntington Beach. It is a much-needed and highly practical step in the.solution to Southern California's current and future water problems. GEORGE CROSS As a longtime resident of California and a 30-plus-year resident of Huntington Beach, I believe it is time for us to unify behind a solid plan for water procurement and conservation. One exciting component of such a plan is seawater desalination, such as that proposed for Huntington Beach. As a former chairman of the Huntington Beach Chamber of Commerce and an active volunteer in the community, I support the proposed water desalination treatment facility as good business for our residents, city government, the environment and for the people of Southern California. We can sit and do nothing in the belief that either"Mother Nature" or some other jurisdiction will "take care of it"or we can step forward and admit that concerns over water shortages in California are real and need to be addressed immediately. When we turn on our kitchen faucet or the front yard garden hose, we take it for granted that the water will flow. But even record rainfall over the past year in Southern California did not solve our over six-year drought while people continue to migrate into the state. We don't have sufficient means, even in times of heavy rainfall, to properly catch, store or even temporarily hold water. Depending on water from the Colorado River to meet our present needs, not to mention our future requirements, is risky business. Between the demands of the population, agriculture and industry there is not enough water to go around. Even with strict rationing and conservation our traditional water sources are at or near record lows. Currently, nearly 40% of Huntington Beach's water supply is imported from northern California and the Colorado River. Do we have sufficient, multi-year guarantees in place related to that water supply? Guarantees such as that don't exist, of course. But we must work to protect our homes, businesses and families by securing alternative sources of.water. One taxpayer-friendly, proactive solution is.the proposed desalination facility in Huntington Beach, which will serve as a vital new source of safe drinking water and a major relief to our depleted traditional water sources. In addition to a reliable water supply, the desalination facility offers significant tax benefits to Huntington Beach residents, using private investment for public benefit at a time when cities are desperately reaching out for their fair share of tax dollars for parks, sewers and vital public safety services. With a public-private partnership on the planning table, the Huntington Beach desalination facility will be a tremendous economic asset to the city. Consider the following economic benefits --all at no cost to taxpayers: * Bringing the city of Huntington Beach nearly $2 million in annual tax revenue-- money that could help support schools, public safety, libraries and parks. * Generating $500,000 per year in sales tax revenue, a third of which will go the county and area cities for police, fire and other local services. * Contributing $50,000 per year to the city of Huntington Beach in utility tax dollars. Beyond the tax benefits directly attributed to the desalination facility, the stabilization it provides to the local water supply has a very important"big picture" economic impact. How? A stable, abundant water supply will protect property values and attract businesses to the area. We can't afford to let water shortages threaten our economic future. Future sources of fresh water will be critical. I support the Poseidon desalination project. DALE L. DUNN r Huntington Beach has always been a leader in maximizing its water resources through conservation and smart water management, but limitations to the region's water supplies means new solutions are needed. This proposed desalination facility represents one key building block to a more secure "water future"for our area, while helping to secure a healthier city economy by bringing millions of annual tax dollars to Huntington Beach. Charlie Bunten Costa Mesa Kudos to letter writer Frank Furian "Thank you Cindy Cross" Aug. 4. I too am a southeast Huntington Beach homeowner and am tired of the SEHBHA purporting to represent all of the southeast area. Actually their membership only consists of approximately 20 percent of residents, not necessarily homeowners. They would not have that number if membership was not free and their heirarchy pesters non members.to the point people sign up just to get rid of their harassment. Recently, I found under my front gate a paper full of scare talk not based on facts and two addressed postcards with a note to post them to the City Council to protest the construction of the desalination plant. The note was not signed. ( I guess the distributor does not care about the Fair Political Practice Act) Southern California needs desalination plant and should welcome entrepreneurs that come from the private sector to perfect this technology. I agree with the letter writer. Let us encourage our City Council to approve the EIR and get this negative filibustering out of the picture. Past history has shown that these minority naysayers do not represent the majority. It is about time the democratic process prevails. We want the Poseidon Resources project now. Bob Polkow In 1962, President John F. Kennedy proclaimed: "If we could produce fresh water from salt water at a low cost, that would indeed be a great service to humanity, and would dwarf any other scientific accomplishment."Who in their right mind could argue what that, yet here we are, more than four decades later, with no commitment to desalination in America? Only when a serious commitment is finally made to establish ocean water desalination on a large scale in America will we see the technology greatly improve and production costs dramatically decline. So, if the bellwether entrepreneur Poseidon Resources is willing to bear the task and risk of building an unobtrusive, yet state-of-the-art desalination plant here in Huntington Beach -- taking a portion of the existing cooling stream from the AES plant and converting it into potable water--while adding over$2 million to the city's coffer per year(in various taxes and fees), where is the downside? The resulting brine will be mixed with the portion of the cooling stream not used by the desal plant before being returned to the ocean, and no more "constituents" (salts, metals etc)will be returned to the ocean than were taken in. Not to mention that all studies I've seen have shown little, if any effect on marine life by adding a desal plant to AES. And for those concerned about bacteria in the AES effluent and our surf zone: It has been shown by studies that exposure to increased salinity can actually destroy fecal bacteria via "osmotic stress," so perhaps adding a desal plant to the AES plant's cooling loop may even help to cleanse the effluent, subjecting it to increased salinity along it's trip to the ocean outfall, where it will quickly dilute. Let's also not forget that we do live in a coastal desert region and, in my opinion, need to take much more responsibility for our own fresh water needs, while moving away from selfishly importing large portions of it from hundreds of miles away. Finally, regarding the issues encountered at the Poseidon Tampa Bay plant: It seems that the economic climate of 2000-01 (corporate/energy scandals, the technology bust and the attacks of Sept. 11) were the main players in the financial issues that hampered the project. Then the decision by the local Tampa Bay water district to take over completion of the plant midway through construction, instead of allowing Poseidon to resecure financing to finish the plant to their original specifications, only added insult to injury. Another(if not the) major issue, which arose in the warm-water estuary of the Tampa Bay plant, was the unforeseen mass infestation of nonnative, tiny, green Asian mussels (from the bilge water of international cargo ships), whose very fine attachment hairs broke off and passed through the desal plant's prefilters, then continually clogged the reverse osmosis membranes. This species of mussel cannot live and reproduce in the much cooler waters off Huntington Beach, and our own resident mussel species are not expected to present a similar hair-clogging issue. Therefore, I say yes to approving Poseidon's offer to take--at their own financial risk--this one large and long overdue step toward realizing another of President Kennedy's bold and progressive dreams, and toward affirming Huntington Beach as one of California's most cutting-edge and progressive coastal communities. TOM POLKOW Huntington Beach Now is the time for the desalination plant. PAT DAVIS Southeast Huntington Beach residents live here because we know a good thing when we see it and choose to live within walking or biking distance of the beach, the local schools, and downtown. We choose to live where the fresh ocean breezes cool our neighborhood, where we have a sense of community, and where we can envision a future in Orange County for the young people growing up now. We can solve our water shortage problems, and we can count on the proposed desalination project to help! Poseidon Resources will clean up the dilapidated oil tanks behind the power plant and clean up the area by repaving and landscaping Newland. Poseidon Resources will pay$1.8 million a year in property taxes. Poseidon Resources will continue their partnership with the community, as they have done, by providing sponsorships to the Duck-a-Thon and the Orangewood Pals Golf Tournament and providing free bottled water to the West OC Family YMCA, the Lions Club, the Huntington Valley Little League, the HB Chamber of Commerce, HB Girl Scout Council and the HB Interfaith Breakfast. Furthermore, Poseidon Resources will have a vested interest in helping to keep the ocean water quality high. The Clean Water Act states that source water must be tested regularly and meet certain quality standards before it can be used for drinking water. Poseidon Resources will be required to sample ocean water and make available all data to the regulating agencies in order to process the water at the Huntington Beach Water Treatment Facility. They will have a personal stake in protecting the water quality of the ocean they will be tapping into. As a Southeast Huntington Beach resident, I welcome the improvements that will be made to my neighborhood with the building of the Huntington Beach Water Treatment Facility, the property taxes that will be added to the city's treasury, and the protections to the ocean water quality and our water supply that we need so desperately. Michelle Nixon I think that we as Huntington Beach residents should consider an option like desalination. It would be another way to get water and would generate much-needed revenue for our city. LISA TRIPODO I just want to thank Cindy Cross in putting things into perspective in last week's column, "A lot of excitement about nothing." We, as Huntington Beach residents, should use our energy in making our city better, not wasting it like these naysayers who are against"anything innovative or unfamiliar"- which only puts a damper on our city. They are out there to attack anyone or anything they can to put a"good idea" down. One "good idea" is the seawater desalination plant that Poseidon Resources is proposing. I am not sure where these naysayers find the majority of Huntington Beach residents to be against this desperately needed project, because I am not one of them— nor are a lot of my neighbors. For those who support this proposed seawater desalination plant, please let your voices be heard. It's not fair that the small minority who are against it are the only ones making their voices heard. Frank Kurisu I am a resident of Huntington Beach and a native Southern Californian. I am responding in support of the efforts to establish a sea-water treatment plant that will provide much-needed additional water supplies to the region. An adequate water supply should be of critical concern to all of us'who live in Orange County as well as in other parts of thirsty California. Much of our water continues to be imported and, as the supply becomes tighter and more expensive, we must look to the future and implement new ways to provide for the sustained growth that will surely continue. The ocean offers an abundant supply.The location proposed for the desalination plant is in an existing industrial area adjacent to the AES power plant and would use sea water already being drawn for that plants'operation. I believe that concerns about the impact on the surrounding neighborhood as well as ocean environmental concerns can be mitigated with good planning, community input and application of sound science. Donna Gray In this time of state and municipal budget shortfalls, dwindling water supplies, and divisive politics,it's like drinking a long, tall glass of water on a hot day to see the plans of some very knowledgeable people taking shape. I recently had the opportunity to learn quite a bit about water in Southern California. What I was most surprised about is how low our water supply is and that it would take many years of more than average rain fall to catch up.We must find new sources of water for the future. I would like to personally congratulate the boards of directors and staffs of Orange County Water District and the Orange County Sanitation District on their foresight in developing the Groundwater Replenishment System (GWRS) to refill Orange County's groundwater basin. Using recycled water innovatively like this is one of keys to successfully managing our water supply. Another bright and shining example of ingenuity is the proposed Huntington Beach Water Treatment Facility,which will take the salt out of our very abundant supply of ocean water to make it drinkable. This water will be extremely high quality and the effects on the local beaches will be so miniscule as to be undetectable, as evidenced by the studies done by esteemed scientists at Scripps Oceanographic Institute. With all of us "regular guys" doing our part to conserve water, and our local water agencies/companies doing their part to increase and improve supplies,we will have plenty of water to support our way of life here in Orange County. Don MacAllister It's time to get on the bus, paddle out, drop in, dive in--whichever phrase works for you--on the desalination project.Water has been and will be a concern for us living in this converted desert we call Southern California. Our population continues to grow not only here but in the states that the Colorado River actually runs through. We will have our supply from the Colorado River cut--the only questions are when and by how much. There are very successful desalination plants being used around the globe and some that have had problems.We can't just bury our heads in the sand for fear that we may be hurt. This is much too pressing of an issue for our community as a whole and individually--for our families and our children's families. The naysayers point to problems of a plant in Florida, or point to the troubles with the city's sports complex. The point is that mistakes are made, and we can stop or learn from them to produce a better outcome. Stopping generally gets you nowhere! The environmental impact is negligible; the revenues for the county and city are promising. This would be a local project with local controls. This is a win-win for the city of Huntington Beach. So let's do the research and be prudent but definitely move on and do the responsible thing for the generations to come. CHRIS HAMMOND Desalination is the answer to the need for increased water supply. I strongly support the Poseidon project. CAROL SPEAKER The Independent has always, in my opinion, used its power as a media to publish both sides of controversial issues. Three writers had articles published on May 5: "Enough progress already;" "An invite to walk the wetlands;" and "Is cheaper water possible?" All objected to my stand on progress and prosperity for Huntington Beach. Two of the writers lowered the bar to a personal attack, which is their prerogative, but their attack did not explain how progress or filling in so-called wetlands was inferior to what they wa nt. One writer decried the condos built on the beach that were probably built before he moved to our city and asked, "Do we need more people and homes?" To that I say we have the people, what we need is affordable housing to eliminate their long commute from other cities to work in our community. He then talks of "beautification projects we have had to endure." Those projects have made it possible to provide adequate salaries for the people who give our city the services that benefit all of us. I think this writer is so livid in his war against progress that he states, "Are we not going to have any square footage where weeds and grass grow that are not paying taxes?" This question stopped me for a while but the writer unknowingly made a slip. That is correct weeds, grass, birds, insects and reptiles do not pay taxes. I may be able to convert this writer after all. The writer goes on to invite me to leave Huntington Beach and go to Victorville and Lancaster "They would appreciate [my] support". Sorry, but I worked at the Victorville Air Base upon discharge after serving in World War II because I was offered a lucrative position and salary to prepare B-29s that were stored there after returning from the South Pacific. My job was to see they were prepared for a safe "one-time flight" to Warner Robins Air Force Base for refurbishment or salvage. My later visits pleased and astonished me as Victorville is no longer a wide spot in the road with a cement processing plant but a thriving, well-developed city with all the amenities we have and more. And the developing is still going strong. Lancaster and Palmdale people have homes in those two cities and worked in the "skunk works" that built some of our latest state of the art Air Force bombers and are also developing their cities further. One other writer, also lowering the bar to a personal level, invited me to take a walk through the Bolsa Chica "and enjoy the beautiful things nature gave us." Sorry but I have been there and done that. There is not enough insect repellent, with DEET, available to entice me back to that swamp, or so called wetlands. I see more beauty walking my neighborhood enjoying the well-kept lawns, flowers of all colors and fragrances and well- chosen trees. My neighbors are supplying more oxygen with their plantings than the hundreds of pickle weed and whatever in Bolsa Chica's hundreds of acres that is going to cost the taxpayers hundreds upon hundreds of million dollars to "develop" and maintain. I suggest Bolsa Chica supporters enjoy wallowing in their victory in diverting money meant for clean water to purchase land that could have been used for its original purpose. The third writer urges us to use common sense instead of building a desalination plant to make us less dependent on Northern California and the Colorado river water. To me, taking advantage of a process to convert the infinite supply of sea water to potable water is common sense. During the late days of my career I spent considerable time on a remote coral atoll, Johnston Island, in the South Pacific. Our only source of water was from two huge diesel engines running 24 hours a day operating a desalination plant. I drank it, showered in it, washed my clothes in it and found it mixed good with bourbon. Ice was a precious commodity so my colleagues along with me had to forgo that luxury in our drink. I do not intend to demean our city-supplied water but the desalination water tasted better. Please don't invite me for a sociable drink. My long career was interesting, busy and diverse, but it left me with an ulcer and hypertension. In closing let me say the only advantage one can enjoy after getting old, is being to able to say "I have been there and done that" and to encourage those that follow not to be content with the status quo but take advantage of the benefits that intelligent and intense well thought-out progress will bring and benefit those that hopefully, continue to do so after we are all long gone and forgotten. BOB POLKOW Huntington Beach I „° .�- Z;)JA0 or °II=cEIVEt) Dear Members of the Huntington Beach City Council: 0 �)/' AUG 3 12005 As a Huntington Beach resident, I want you to know that I su ort the proposed Huntington Beac W# er HUNilNGT N BEgcH Treatment Facility because: � o•� ADMINIS7Rq � FF10E r°f w�jovT Local drought-proof supply of water-' • $1.8 million per year in property tax for Huntington Beacom5; , ��javT ► ' ` C�eG • $500,000 per year in sales tax for Huntington Beach •Trees, paving and other improvements around the current power plant HOLA/ (e_k,k f; � e Sincerely, Name: � t� � CD Address: 2, City, State and Zip Code: Dear Members of the Huntington Beach City Council: O //f� y As a Huntington Beach resident, I want you to know thatl: �t the proposed Huntington Beach Water Treatment Facility because: • Local drought-proof supply of water • $1.8 million per year in property tax for Huntington Beach • $500,000 per year in sales tax for Huntington Beach •Trees,paving and other improvements around the current power plant Sincerely, Name: v Address: City, State and Zip Code: Dear Members of the Huntington Beach City Council: As a Huntington Beach resident, I want you to know t t I support the roposed Huntington Beach Water Treatment Facility because: •Local drought-proof supply of water 41u,3-n.4 G,-rD,� 654C'JC R-F..,SiD tf4iS AND VP • $1.8 million per year in property tax for Huntington Beach • $500,000 per year in sales tax for Huntington Beach ����� •Trees, paving and other improvements around the current power plant Sincerely, Name: Address: City, State and Zip Code: JA-6> q76��-7� Dear Members of the Huntington Beach City Council: As a Huntington Beach resident, I want you.to know that Psupport the proposed Huntington Beach Water Treatment Facility because: • Local drought-proof supply of water • $1.8 million per year in property tax for Huntington Beach • $500,000 per year in sales tax for Huntington Beach •Trees,paving and other improvements around the current power plant Sincerely, why .1) C-O%AA Pa PUY') PovR- i^o - aeco" • z) CACK of PV&UCAVOAJ OF H6,12_E5100ITS Name: Tt r� TOa U S C/IvS Address: �PO. t�b X `-1 SL City, State and Zip Code: ' �� CA '7 -V 8 Dear Members of the Huntington Beach Cit l: DVS7T_(V As a Huntington Beach resi e ,I want you to know that I s�4 e pl�PsedVunringfon Beach Water Treatment Facility because: •Local drought-proof supply er � •$1.8 million per property tax for Huntington Beach •$500,000 ear in sales tax for Huntington Beach � /Q� •T ,paving and other improvements around the current power plant /�-�L7 Sincerely, =;t2 r P"V � u� k Name: . Address: City, State and Zip Code: t► I 11,ors a�! � • Dear Members of the Huntington Beach City Council: As a Huntington Beach resident, I want you to know th upport the pro Huntington Beach Water Treatment Facility because: •Local drought-proof s y of water . • $1.8 million pe ar in propert or Huntington Beach • $500,00 r year in sale for Huntington Beach �ddd.•••JJJJ •Tr,�, paving and r improvements around the current power.plant Sincerely, _ r- Name: Address: VJ 1 J !JfE'J I City, State and Zip Code: Ifj TA Dear Members of the Huntington Beach City Council: As a Huntington Beach resident,I want you to know that I sit the proposed Huntington Beach Water ,l Treatment Facility because: } C L e Vo t- roof su 1 water • Local r p pp ( • $1.8 million per ' property tax for Huntington Beach \ I (-{ _ l l.� ZI • $500, 00 ear in sales ox Huntington Beach C��C•G \� O v\� ` `� ` • !e_e-s-O,�aving and other iraprovernaftszLound the current power plant Sincerely, Name: Q (1 Address: City, State and Zip Code: Dear Members of the Huntington Beach City Council: As a Huntington Beach resident, I want you to know that Itpport the proposed Huntington Beach Water Treatment Facility because: •Local drought-proof supply of water • $1.8 million per year in property tax for Huntington Beach • $500'000 per year in sales tax for Huntington Beach •Trees, paving and other improvements around the current power plant Sincerely, Name: •_ a . . , ;y Address: 441 6. -E4— .77� f d F. x � � p ppy ..................................................... — Welcome to Huntington Beach Surf City, USA The dynamic coastal City of Huntington Beach,with ` r its sunny k editerranean climate and idyllic setting, is home to more than 19�ili iU residents. r Internationally kncrn:ro as Surf City,Huntington Beach boasts eight miles of scenic,accessible p heachfront,the largest stretch of uninterrupted heachfront on the.'"Jest Coast.Tourism remains a vital part of the economy,as over 11 million visitors - r flock to the city during the summer,on weekends and for special events. OX4 Ce�� �� � side Pave � � acifie City u L f" iten° �ayvp , Hi vo P�W, 6 s`r Olk j} P N� Y R� s:. �4 g 1; « Y Open 'ceorg.,.. ,Z", .. ..... ,,.,... Albers, Patricia From: Dapkus, Pat Sent: Wednesday, September 07, 2005 9:07 AM To: Flynn, Joan Cc: Albers, Patricia Subject: FW: Powerpoint Presentation from Last Night In hbcc-presentation- 20050906a.pp... FYI -----Original Message----- From: Edward DeMeulle [mailto:ed@demeulle.org] Sent: Wednesday, September 07, 2005 9:00 AM To: city.council@surfcity-hb.org Cc: Pat Dapkus; Cathy Fikes Subject: Powerpoint Presentation from Last Night Enclosed is my powerpoint presentation. Please add it to the record. Thanks! E DeMeulle < d@demeulle.org> 1 S�pURLIyFC SRC 0F 1C RECpR fa CITY OF HUNTINGTON BEAt:� 1i E of E L ME 4� f CLERK INTER-DEPARTMENT COMMUNICATION TO: .Planning Commission Members FROM: Howard Zelefsky,Planning Director SUBJECTi POSEIDON SEAWATER DESALINATION PROJECT DRAFT ENVIRONMENTAL IMPACT REPORT(EIR NO.00-02) DATE: September 19,2002 The City's consultant has recently completed the Draft Enviromnental Impact Report(EIR No. 00-02)for the proposed Poseidon Seawater Desalination Project The Draft EIR analyzes the potential environmental effects associated with a request to construct and operate seawater intake pretreatment facilities,a seawater desalination plant utilizing reverse osmosis technology, product water storage,pump stations,materials storage tanks,and 42 to 48 inch diameter product water transmission pipeline possibly up to 10 miles in length in Huntington Beach and Costa Mesa The facility would utilize existing AES seawater intake and outfalI pipelines for its operations. The project includes construction of an underground pump station in a portion of unincorporated Orange County,south ofBonita Canyon Drive,near the eastern border ofthe City of Newport Beach. The proposed desalination facility is located on a seven acre portion of the 22 acre AES Huntington Beach Generating Plant located at 21730 Newland Street,off Pacific Coast Highway_ The Draft EIR will begin its mandatory 45-day public comment period Thursday, September 19tk The comment period closes on November 0. Tentatively,we would expect the Planning Commission's review to occur in January 2003. Copies of the document were distributed to state and local agencies. Other copies are available for public review at the Planning Counter,Huntington Central Library and Banning Branch Library. A Notice of Availability was sent to 466 surrounding property owners and interested organizations. A. of the draft document has been attached for your review # clx , � te T calms�aemciices ylease contacfRicky-Ramos-at-exl:-5624� End. cc: Scott Hess,Planning Manager Mary Bean,Broenm,Principal Planner Ricky Ramos,Associate Planner 'aFEOERAppNo Los Angeles / Orange Counties 1626 Beverly Boulevard cgs Building and Construction Los Angeles, CA90026-5784 Phone(213)483-4222 Trades Council (714)827-6791 RICHARD N. SLAWSON Fax(213)483-4419 Executive Secretary Affiliated with the Building& Construction Trades Dept.,AFL-CIO September 6, 2005 rvt 1 �i✓�s RECEIVED FROM AS PUBLI r FOR COUNCIL MEETING OF tm CLERK OFFICE JOAN L.FLYNN.CITY CLERK To: Huntington Beach Mayor and City Council Members From: Jim Adams, Council Representative Re:Public Hearing for the proposed Poseidon Desalination Project Dear Honorable Mayor and City Council Members: I respectfully request that the attached testimony become part of the public record in its entirety. Thank You Jim Adams, Council Representative Good Evening, Honorable Mayor, Members of Huntington Beach City Council. My name is Jim Adams, I am a Council Representative for the Los Angeles/Orange Counties Building and Construction Trades Council. Our Council represents affiliated Construction Unions whose membership exceed 130,000 Skilled Craft men and women that live and work in Orange County as well as here in Huntington Beach. On behalf of those Craft Men and Women, we are here to support the proposed Desalination Project. There are many of us here this evening, although we will not all speak in consideration of your time as well as our own. But I would like to thank those that support the project for their attendance and ask them to stand and be recognized. Generally speaking the Building Trades support projects that will produce jobs for local contractors and local workers, especially when we believe the project is good for the community. And this project will certainly do that. However, this project goes well beyond creating jobs during construction. We have an opportunity to be the first in the County that actually has a desalination plant. We could be someone that is actually doing something to help ease the drought. The very first sentence from the California Coastal Commission website: Report on Seawater Desalination In California states... With population growth and the recent six year drought contributing to an increase in Californian's concerns about water scarcity, several communities and industries in California have proposed constructing desalination plants. Some 90% of California's water is piped more than 250 miles to its consumers, the majority from the Colorado River. But we all know that supply is in danger due to declining levels. There are some 18 desalination plants under consideration in California offering a way out of this situation. I certainly hope we are one of those 18. It seems that the opposition to this project is based mainly three reasons; (1)Water creates growth, (2) harms Marine Life and (3) we must dig up the streets for a pipeline. As for as growth, growth is here and we better hope it continues so we may survive. No city, can remain viable without growth. Marine Life: Few if any monitoring studies that I have found have been conducted on the impacts to Marine Life research. I am not sure where their information is coming from. Pipeline Construction: All of our pipelines are under ground regardless of the purpose. And yes, we must tear up the streets for installation and or repair. The City of Anaheim is currently well under way with a 50 year project to place all their electrical lines under ground. I hear others talk about privatization of our natural resources. I don't where they are going with that, we allows commercial fisherman to fish and sell their catch, with proper licenses and permits. We have a oil well in the parking lot. We sell the sun that activates our solar equipment. I wonder if there would be opposition if all of a sudden the valve at the Colorado River got shut down or the aqueduct all of a sudden developed a leak. I encourage the City Council to embrace this project, negotiate the best development agreement possible, one that will be good for the City. I am concerned that if we don't there will be another agency that will. And we lose. Thank you for your time and consideration. PAS Ot BUC H.CORI) 6MF MEETMG OF CITY CLEW OFFICE j0AN L FLYldtd.CITY CLERK The Poseidon Plant: Desalination In Huntington Beach By Shannon Pankratz Institution: UCLA, ESE Department Course: EHS 235 Instructor: Dr. Linwood Pendleton Date: 12/14/2004 Introduction The west coast of the United States has experienced over half a decade of drought, the longest period in 108 years'. California has additional water shortage complications. This state has used 600,000-800,000 acre-feet per year(afy) over its Colorado River water allotment2. California's dependence on this portion of Colorado River water will be phased out by 20163. On top of continued drought conditions and reduction of imported water, the population of California is expected to grow by 6 million by 20104. Desalination is an option for enhancing water supplies and significantly improving water supply reliability. In addition to need, desalination has become more viable as water costs have increased and as desalination costs have decreased through technological advances5. Along the coast of California there are approximately a dozen desalination plants5, which produce up to 3,300afy6. An additional 20 planned desalination projects5 could collectively produce 260,000afy6. One of California's planned desalination projects is located in Huntington Beach (HB). HB is a coastal city in Orange County, southern California. The Orange County Water District (OCWD) estimated water demands will surpass supply by 109,000afy in 20257. HB and OCWD considered a proposal by Poseidon Resources Corporation (PRC) to build a desalination plant connected with the HB AES power plant. This desalination plant would have been the largest in the nation2, supplying Orange County (OC) with 50 million gallons per day (MGD), or 50,000afy, of potable water'. Most local and regional stakeholders recognized the impending 1"Treasure From the Deep: Drinking Water",Jane Black,Business Week Online,5/1/2003 2"Along the Coast:Creating a Healthy Coast",Watersheds,nbc4.com 3"Squeezing Salt From the Sea",Laura Wides,CBS News.com,8/8/2003 4"New Technology Better at Removing Salt from Water",Laura Wides,Sea Sabres,4/8/2003 5"Desalination Issues Assessment Report:Draft",Center for Collaborative Policy,California State University,Sacramento, 5/21/2003 6"Seawater Desalination and the California Coastal Act",California Coastal Commission,March 2004 "Ocean Water Desalination Program Concept Development Paper",by Orange County Water District and the Municipal Water District of Orange County,October 2003 1 water shortages in southern California, and they were not opposed to desalination projects as a means of increasing water supplies. However, this specific PRC desalination project for HB was met with strong opposition. Concerns over the content of PRC's Environmental Impact Report (EIR) ultimately led the HB city council to reject PRC's EIR as inadequate 8. Nonetheless, there were many socio-economic issues that may have to be resolved before this desalination project may ever proceed. Currently, the EIR is being revised by Poseidon and is expected sometime early in 20059. Background Desalination and the Huntington Beach Project The HB desalination project is favored for increasing southern California water supply reliability10 and for potentially offsetting groundwater withdrawals and imported watery. Currently, OC water supplies consist of 180,000afy of imported water, 265,000afy of groundwater, 15,000afy of recycled water, and 72,000afy of a GWR System-Phase I'. Though the 50 MGD desalination plant will supply only a small percentage of the 650MGD OC demand", it will provide water for 100,000 OC homes3. The HB Planning Commission cites additional benefits, such as increased property tax revenue, improvement of visual aesthetics of the site, addition of a traffic lane on a nearby street, and clean-up of hazardous chemicals on the siters 8"Perspectives: Desalination in Huntington Beach",Surfrider Foundation,Huntington Beach/Seal Beach Chapter 9"Planning and Environmental Committee Agenda",San Diego County Water Authority,7/22/2004 10"District Boosts Water Reliability: Desalination,Conservation,Supply and Quality Programs Move Ahead",Metropolitan Water District of Southern California,Press Release,8/21/2001 11 "Conditional Use Permit No.02-04/Coastal Development Permit No.02-05(Poseidon Seawater Desalination Plant)",City of Huntington Beach Planning Department Staff Report,5/27/2003 2 The BB desalination plant will use the existing ocean intake and outfall pipes of the AES power plant'. The AES intake is 2,292 ft offshore at depth of 34 ft12, and the outfall is 1,500ft offshore". Utilizing reverse osmosis (RO) technology, the plant will produce one gallon of freshwater for every 2 gallons of seawater'. 50MGD of brine wastewater will be mixed and discharged with about 407MGD of AES cooling water". The plant will operate 24 hours per day, 7 days per week" The scope of the desalination project is to provide a base water supply for the OCWD service area . PRC will manage the project design, construction, and financing, while OCWD will handle the plant operations'. The Metropolitan Water District of Orange County (MWDOC) will handle the water sales for the plant'. General Benefits and Costs of the Huntington Beach Project The most important benefit of desalination is decreased dependence on imported water supplies and reduced pressure on surface water sources6.Considering only groundwater and desalination water, the OCWD estimates the desalination project water could provide 94% of the summer supply and 90% of the winter supply'. Another potential use of the project water could be a partial emergency water supply to southern OC1. Combining the desalination facility with the AES power plant would reduce costs on intake, outfall, and power source infrastructures'. As well, this combination could result in less cumulative impingement and entrainment effects than a desalination plant built alone. The BB desalination plant will cost $250 million 3. Even though the costs of desalination are decreasing, it will still cost twice as much as conventional southern California water supplies25. RO is sensitive to poor water quality6, and the filter membranes are sensitive to 12"Environmental Impact Report No.00-02(Poseidon Seawater Desalination Plant)",City of Huntington Beach Planning Department Staff Report,5/27/2003 3 fouling from bacterial contamination and other constituents6. Utilizing seawater, the RO method will require frequent maintenance and cleaning. These processes utilize chemical cleaning agents and will generate waste. The amount of generated waste could be considerable, depending on the degree and frequency of membrane filter clogging. Economics of the Huntington Beach Project The perceived long- and short-term benefits of a local and drought-proof water supply are accepted along with the higher desalination costs 6. These benefits are likely to increase with time, given the future predictions of water shortages. Water security is preferentially valued and a high priority, and this factor alone may dominate over other potential environmental and socio- economic shortcomings. Other short-term economic gains include the provision of construction jobs (see Table 1). Long-term gains for HB are the provision of full-time jobs for the desalination plant, provision of water for the projected growth of OC, and increased property tax revenues (see Table 1). The project operational costs are difficult to estimate and are associated with numerous conditional assumptions. Most of the operational costs depend on operating consistently at full capacity, obtaining limited subsidies from various state and federal agencies, and electricity costs (see Table 1). Particularly, desalination costs are sensitive to energy prices. One third to half of total desalination costs are due to energy costs 6.Also, it is estimated that a one-cent difference in the price per kilowatt-hour of electricity results in a $50 difference in the cost of producing an acre-foot of desalination water6. Altogether, it is likely the costs of this project are highly underestimated, as were PRC's development and production costs for its smaller Tampa Bay desalination project$. 4 Environmental impacts of the Huntington Beach Project The marine impacts of the desalination plant involve the intake and outfall pipes of the AES power plant and the current water quality of HB. The intake pipes cause impingement and entrainment of marine organisms. Impingement is the death or injury to marine organisms by being pulled into an intake system and trapped against a fish screen. Entrainment is the death or injury of relatively small marine organisms, such as larvae and fish eggs, that are pulled into the facility using the seawater6. It is estimated entrainment results in 100% mortality of marine organisms, from thermal effects and pressure changes. There is the potential for many different toxic contaminants to impact the outfall and nearshore marine environments. The desalination process will concentrate compounds or elements from the intake water, up to twice the initial concentrations, and discharge them through the outfal16. These water constituents may be naturally occurring or present as pollution. Specific concern was expressed over salinity and bacteria, whose environmental impacts have yet to be determined. While death of marine organisms and changes in marine communities are commonly referenced as impact endpoints, higher salinity concentrations could have sub-lethal effects on marine organisms. These negative effects include increasing the overall stress on the marine organisms, in turn increasing their vulnerability to other environmental stressorsb. HB has problems with bacterial contamination of nearshore waters, and there is a wide- ranging negative public perception of polluted HB beach waters25. A desalination plant has the potential to concentrate bacteria and to compound HB's bacterial problems. A California Energy Commission (CEC) study found AES wastewater contained high bacterial concentrations, one 5 bacterium per 36 water particles13. Alone, the AES power plant already contributes 16% of enterococci bacteria that ends up at HB13 Status of the Huntington Beach Project The HB Planning Dept staff recommended the project", having concluded the impacts on marine resources were less than significant12. However, the California Coastal Commission (CCC) staff, CEC staff, California Parks and Recreation Department$, and the California Department of Fish and Game determined the EIR to be inadequate 25. The HB City Council voted not to certify PRC's EIR on the basis of failure to adequately address environmental impacts, population growth inducement, and the relationship between the AES power plant and 14 the desalination plant9. Nonetheless, the HB City Council and the OCWD are still interested in partnering with private companies to build a desalination plant 15. Stakeholders of the Proposed Huntington Beach Desalination Project There are many different groups affected by the eventual outcome of a desalination project in HB (see Table 2). Considerations of future water supplies motivate most people to support desalination in general. However, HB and OCWD are currently meeting their water demands. PRC and developers within OC are the groups with the most economic incentive for a HB desalination plant$. California law requires proposed developments to provide adequate water supplies for its residents. Yet, most major proposals presently lack a dedicated water source$, which desalination could provide. State agencies and environmental groups have been able to supply greater pressure in attempts to halt or slow the movement toward building desalination plants. Thus far, local 13 "That's a Lotta Clams!",Nick Schou,OC Weekly,Nov. 14-20,2003 14"Desalination Plant rejected by Huntington Beach City Council", Water Reuse News, 1/12/2004 15"Desalination Plant Down but Not Out",S. Allison and D.Weikel,Los Angeles Times, 12/17/2003 6 environmental and socio-economic concerns have been successful in preventing the construction of a desalination plant in HB. Nevertheless, as water needs increase over time, this balance may shift in favor of developing desalination projects. Issues Alternatives to Desalination The pressures exerted by developers and the fears of future reliable water supplies may have led to OCWD's principal focus on desalination. Alternatives to a desalination project in HB were not actively proposed or supported. Though OCWD could rely upon MWDOC for extra water', there was a sentiment this option was unreasonable compared to desalination. Use of additional water from MWDOC could address local concerns over seawater intrusion from groundwater withdrawals and avoid negative impacts of a desalination plant'. Though figures from 1991 underestimate current costs, costs ranging $27/af-$194/af for importing water from different sources16 are still likely to be cheaper than desalination (see Table 1). Also, there are two outside pressures that may limit alternatives to desalination projects. The first is the ease of transferring water rights. Most of California runs on an old system of appropriative water rights (first in time), and farmers have rights to the vast majority of California's water". While farmers are not necessarily opposed to the voluntary sale of water to cities, there is opposition to these private water sales from groups who believe water is a public good 18. The second pressure is the inertia of public perception and personal behaviors. HB has the option of increasing its water supplies from reclamation, which is cheaper than desalination. However, there are limits to the extent of reclamation from strong negative public perceptions of 16"Seawater Desalination in California: Background",California Coastal Commission 17 Cadillac Desert:The American West and Its Disappearing Water,Marc Reisner,Penguin Books,1993 18 EHS 235 notes,Environmental Policy for Science and Engineering,University of California,Los Angeles,Fall 2004 7 "toilet to tap". Moreover, residential water conservation is limited by the degree of personal behavior changes most people are willing to accept. Often, people are not willing to significantly change their daily routine and water-usage18. Growth Inducement Desalination has the potential to encourage and exacerbate the growth of OC. Currently, OC is not reliant upon desalination as a water source, and the water demands of existing residents are met. Introducing a new water source now will create a gap between when extra water is available and when the water will be needed. In the meantime, this available water will be used by developers who require additional water sources to build their projects. This growth inducement from desalination may eventually push coastal population growth to a point beyond what can be supported by California's coastal resources6. The Public Trust The CCC is concerned with private companies using the Pacific Ocean, a public resource, for private profits6. Private companies may not have strong incentives to protect coastal resources3. It may be possible to try and avoid private ownership of desalination plants by heavily supporting public ownership. Public ownership may lead to more comprehensive approaches and better oversight to coastal development and to controlling population growth effects'. At present, the issues of publicly financing desalination ventures may only allow for an active role for private companies. Lack of Science There is relatively little information known on many of the potential environmental impacts of desalination. Information is lacking on the effects of outfall discharges on particular 19"W 10a: Briefing on the Applicability of Coastal Act Policies to Public and Private Desalination Facilities", California Coastal Commission,2/20/2003 8 marine species and habitats, whether monitoring requirements adequately characterize facility effects, and the potential cumulative impacts of water withdrawals and discharges from multiple desalination plants. Also unknown are: the impact levels of entrainment and impingement of desalination plants alone and coupled with power plants$, the impacts of addition runoff from new local development20, and the probabilities and the hazards of disposal problems and on-site build-up of chemical filter cleaners$. Though studies are needed to fill in these knowledge gaps, the costs and the potential results of scientific studies may impede their implementation. Scientific studies may be expensive, especially when determining project impacts on a recommended case-by-case basis. Proposition 50 has specifically provided $50 million for desalination, but the money was apportioned for both research and construction 4. There may also be few studies to date because both environmentalists and construction companies are equally unsure of the significance of environmental impacts. If study results show outfall and intake impacts are insignificant, or less than significant with mitigation measures, then environmental groups will no longer have grounds to oppose this type of coastal development. Yet, if environment impacts are proven as significant, then the development progress of desalination projects may be considerably slowed. Feasibility of Mitigating Environmental Impacts Additional studies are required to determine the feasibility of mitigation solutions 5. These solutions apply to outfall discharges, water intakes, and the cleaning up of potentially dated and dirty power plants coupled with new desalination plants6'20. Also, it is not just a question of an available technological fix, but also of mitigation techniques costs. For instance, while it is relatively easy to reduce or avoid impingement, entrainment mitigation requires substantial 20"Desalination:The Solution or a New Problem",Chris Dixon,surfermag.com 9 effort. The implementation of mitigation techniques will have to be considered in the total construction and operational costs of desalination. Compliance with Regulations The CCC is concerned over U.S. trade treaties with multinational companies. These companies can file claims under international trade treaties and challenge government decisions that hurt their business21. Such claims may enable some private companies to circumvent compliance with environmental regulations. In terms of HB, PRC could contract with international companies to help develop its desalination project21. This would potentially save PRC money it would have to otherwise spend on environmental considerations. Additionally, if the HB AES power plant is coupled with a desalination plant, it may have future problems complying with the Clean Water Act. The Clean Water Act 316b regulations will require 60-90% reduction of entrainment rates and 80-95% reduction of impingement rates$. Coupling the AES plant with a desalination plant is likely to increase the total annual volume of water pumped through the intake pipe, increasing ordinary entrainment and impingement rates. The increased water intake volumes will be due to the desalination plant's constant operation, as opposed to the intermittent intake needs of the AES power plant. Public Perception of Huntington Beach Water Quality Aside from impacts on marine organisms and habitat, the negative public perception of polluted HB waters25 may complicate future approvals of a HB desalination project. The CCC and the California Department of Parks and Recreation stated a desalination project could potentially double bacterial levels in HB waters22. Concentrating bacteria in HB's surf zone 21 "US:A Wave of Desalination Proposals",Bettina Boxall,Los Angeles Times,3/14/2004 22"The Poseidon Misadventure",Nick Schou,OC Weekly,Dec. 12-18,2003 10 raises concern over health and associated negative economic impacts$. If there are no technical or feasible mitigation techniques for outfall bacterial concentrations, it is debatable whether nearshore water quality will be sacrificed for gaining a supplemental water supply. Technological Feasibility of the Huntington Beach Desalination Plant Past performance of PRC's $110 million Tampa Bay desalination plant offers no indication that the proposed HB desalination plant is technologically viable22. The Tampa Bay Plant is the largest desalination facility in the country, yet half the size of the proposed HB plants. The fiscal and technical problems experienced with the Tampa Bay plant have seriously questioned the current reliability of large-scale desalination projects$. The operational problems with frequent filter clogging have also led to substantial cleaner chemical storage on the plant property20. Presently, the Tampa Bay desalination plant is still not operationa122,23. Water Users and Water Usages It is questionable who will benefit from a PRC HB desalination plant. PRC assured HB it could buy water if the city so desired 22. However, in its EIR, PRC only made a general statement that "the desalination water would be for the regional water distribution system for the southern California region and particularly Orange County"24. The economics suggest initial interested purchasers of water would be areas of dramatic development, that are only prohibited by the lack of an identifiable water source$. Hence, it is likely the desalination water will go to support new home construction 25. The Santa Margarita Water District is such an area with large development proposals, stalled from lack of water supplies$. While the desalination plant was being 23 http://www.tampabaywater.org/ 24"Poseidon Seawater Desalination Project",Draft Environmental Impact Report#2001051092,City of Huntington Beach, 9/19/2002 25"Turning Water into Whine",Nick Schou,OC Weekly,Nov. 14-20,2003 11 considered by HB, the Santa Margarita Water District had agreed with PRC to purchase 25MGD, half of the plant's water 25. It is also questionable how HB desalination water can and will be used. If PRC makes agreements with home developers, there may not be enough water available for the planned future uses for which the OCWD would approve such a desalination project. These planned OCWD water uses include reduction of imported water supplies, reduction of groundwater withdrawals, reduction of seawater intrusion, and increased local and reliable water supplies to meet normal project growth. Payment for Desalination Water and Desalination Impacts If a HB desalination plant is ever constructed, there are questions of who will bear the increased costs of the desalination water and the environmental impacts. It is most likely HB will inequitably bear the localized environmental burdens of desalination, while a significant portion of this water will be made available to inland communities26. There a few different ways for which the increased water costs (via desalination) could be accounted. The increased costs could be absorbed by the profits of planned housing development projects, passed on to the property purchasers, or passed to OCWD users as a group$. Yet, until a HB desalination project comes closer to actualization, it is uncertain who will end up paying for the increased costs of desalination water. Conclusions Desalination may be one of few viable options for southern California to meet its future water demands5. Poseidon's desalination project proposal for HB was not approved primarily 26"Seawater Desalination Plant in Huntington Beach:Cost-Benefit Prospectus",David Sumi,Public Policy and Administration 220B,3/6/2004 12 because of cited EIR inadequacies. Still, it is questionable if the desalination project proposal should have been seriously considered, based on numerous unresolved environmental and socio- economic issues. Permitting uncertainties, ecosystem impacts, growth inducement, assurance and maximization of public benefits, and the production of reliable and sustainable desalination water sources still need to be addressed5. Drought conditions, decreases in water supplies, and population growth are all factors weighing heavily in favor of desalination. Nonetheless, these are more future considerations of HB and the OCWD, rather than immediate conditions. Presently, HB and OCWD are meeting water demands and are primarily concerned with securing an additional reliable water source. Thus, at this point in time, local environmental and socio-economic concerns have footing versus local and regional water needs. However, future water needs may eventually prevail over legitimate concerns of environmental impacts and socio-economics, as the water shortage crisis peaks in southern California. 13 Table 1. The economic costs and benefits of the proposed Poseidon desalination plant in Huntington Beach, California. Factor Duration Costs (C) Benefits (B) Net (B-C) Water supply Long-term Undetermined Undetermined Perceived as securit 6 positive Construction jobs Short-term Likely none Undetermined Perceived as positive System integration Short-term Estimated$50 Undetermined Undetermined of desalintion7 million —20 fulltime plant Long-term Undetermined Perceived as Perceived as jobs7'11 positive positive Construction Short-term Undetermined Indirect: $100 Perceived as process'5 million positive Additional Property Long-term NA $2 million Positive Tax Revenue22 Growth Long and short- Perceived as NA Perceived as inducement term significant negative Reduced beach Long-term Perceived as NA Perceived as recreation/tourism negative negative (from increased pollutant concentrations)26 Energy use 'n77 Long-term —$14 million Undetermined Undetermined Complete cost Annual $31-57 million $12.5 million in $359-880/af, or MWD subsidies, —$12 million extra $23 million not costs, or an extra purchasing MWD $25/af water, $10 million in federal subsidies 27"Seawater Desalination in California: Key Desalination Facts", California Coastal Commission 14 Table 2. Stakeholders of the proposed Poseidon desalination plant in Huntington Beach, California. Supporter of Huntington Supporter of Stakeholder Group Beach Project General Desalination Issue(s) of Concern OCWD Yes Yes Meeting future water needs;Reliable and local water source CCC ' ' '19 No Neutral Protection and enhancement of Pacific Ocean as public resource for current and future generations,against private and international profits;Protection of ocean views;Control over all types of coast development;Sprawl prevention;Prevention of growth inducement Environmental groups No Yes (generally) Growth inducement;AES (Sierra Club, Southeast intake and outfall impacts; Huntington Beach cumulative coastal Neighborhood impacts;Coupling desalination facilities with Association, Surfrider old power plants;Offshore Foundation, OC and nearshore water Coastkeepers)2'''25'8 quality Customers of OCWD No Yes Benefits to the city;Who (residents of HB, other will receive project water; OC cities)7'25'14 Marine life impacts MWD, other southern Perceived as Yes Yes Local to national support California water of desalination; districts, U.S. Diversification of water Desalination supply sources;Enhancing Coalitions,)1,28,29 water supplies Poseidon Resources Yes Yes Catering to local and Corporation regional water needs; Construction of desalination plants Housing developers Yes Yes Adequate water sources for development proposals California executive and Unknown Yes Provide for the state's legislative branches, current and future water state agencies5'6 needs;Accountability to public welfare Fishing Industry Unknown Unknown Protection/enhancement of fishing stocks Academic institutions Unknown Unknown Research opportunities; Service to the public 28"Reliable Water Through 2025 Outlined Under Updated Integrated Plan Adopted By Metropolitan Board",Metropolitan Water District of Southern California,Press Release,7/13/2004 29"Metropolitan Moves Ahead with Seawater Desalination,Pipeline to Augment the Region's Reliable Water Supply", Metropolitan Water District of Southern California,Press Release, 10/8/2002 15 ' 9 Gail Hutton, City Attorney City Attorney, City of Huntington Beach `�- Scott F. Field,Assistant City Attorney /' 2000 Main Street �� P4 Huntington Beach, California 92648 Telephone: 714.536.5555 � � j 4�.i►2'�► Facsimile: 714.374.1590 Electronic Mail: fields@surfcity-hb.org JEFFER, MANGELS, BUTLER& MARMARO LLP Alvin S. Pak, Esq. 8EGEIVED FROM Malcolm C. Weiss, Esq. AS PUBLIC RECORDS MEETS David P. Waite, Esq. OF Dominic P. Hanket, Esq. CITY OLE OF E One Sansome Street, 12th Floor .BAN L.FLYNK CITY CLERK San Francisco, California 94104. Telephone: 415.398.8080 Facsimile: 415.398.5584 Electronic Mail: asp@jmbm.com ATTORNEYS FOR THE CITY OF HUNTINGTON BEACH BEFORE THE ENERGY COMMISSION OF THE STATE OF CALIFORNIA In the Matter of ) AES Huntington Beach Generating ) Docket No. 00-AFC-13 Station Retool Project ) (Filed December 1, 2000, accepted Application for Certificate. ) as complete February 7, 2001) COMMENTS OF THE CITY OF HUNTINGTON BEACH ON THE PRESIDING MEMBER'S PROPOSED DECISION A. Introduction The City of Huntington Beach, an intervenor in the above-captioned proceeding,files these additional comments in response to the Presiding Member's Proposed Decision (PMPD) issued on March 30, 2001. The City has previously filed its Brief with respect to the issues presented in this matter on March 21, 2001, and incorporates by reference its arguments and positions raised in that filing. These comments address the specific rulings posed by the PMPD. In filing these comments,the City takes the general position that the Commission has a large and generally unfettered jurisdiction to impose conditions on the construction and operation of any facility governed by the Warren-Alquist Act. The Commission holds a clear statutory mandate to specify"conditions under which approval and continuing operation of any facility shall be permitted. Public Resources Code Section 25216.5(a). That authority is plenary and exclusive with respect to other state agencies and,to the extent permitted by federal law, supercedes the authority of any federal agency. Public Resources Code Section 25500. Furthermore, the Legislature has vested additional implicit and explicit authority in the Commission related to resolving any"impending serious shortage of energy, or a clear threat to public health, safety or welfare." Public Resources Code Section 25216.5(b). Finally, recent gubernatorial orders and legislation directing the Commission to address the declared energy-market emergency demonstrates the State's expectation that this agency has not only the authority but the responsibility to assure that the emergency is resolved effectively and as quickly as possible. In performing its duties under conditions of emergency, the Commission is also required to protect the environment and the public health, safety and welfare. While the PMPD attempts to find a balance between effecting those protections and meeting the need for additional generating capacity in this State, the PMPD has omitted discussion of several key conditions that should be attached to any certificate granted in this proceeding. The City urges the Commission to consider these additional conditions as yet left unaddressed by the PMPD. B. Limitation on the Duration of the Certificate The PMPD limits the duration of the certificate granted for the operation of Huntington Beach Units 3 and 4 to a period of five years, ending September 30, 2006. See PMPD at 9, 10-11. At that time, AES will be required to decommission and dismantle the units, or to file for an extension of the certificate. Whether AES files for such an extension will depend on the significance of any adverse impacts the operation of the units has on the environment and/or the public health, safety and welfare, either independently or cumulatively with respect to other 2 projects, and whether significant impacts, if any, can be mitigated. In addition;the Commission can anticipate that the prevailing economics of the units, the cost of the ongoing mitigation measures adopted for the units and the performance of the units through that time will also affect any decision by AES or successor-owners to file for an extension of time. The City, as a proponent of the limitation adopted in the PMPD, submits that the Commission should adopt the condition limiting the duration of the certificate for Huntington Beach Units 3 and 4 to the five-year period. While AES is generally correct that certificates previously issued by the Commission have not carried such a limitation,AES is patently wrong in asserting that the State generally and the Commission specifically are precluded as a matter of law from imposing an expiration date upon which the certificate shall lapse. Not only do the unusual circumstances presented in this case warrant the limitation, but the limitation is amply supported by apposite law and precedent. 1. The Lapse of the Permit Is a Justifiable In-Lieu Condition and Substitution for Thorough Environmental Review. Although the City agrees with other parties that an admirable job has been done to review this project given the compressed schedule, the City is compelled to note for the record that the record is hardly complete and that the review that has been conducted would not, under ordinary circumstances, meet the requirements of the Warren-Alquist Act. The PMPD duly concedes various aspects of the environmental impacts the restart of these units may have on the environment or the public safety and health have not been fully ascertained. See PMPD at 11. The PMPD reserves certain of those matters for further studies. The Coastal Commission has filed comments noting its discomfort with that position, indicating the Coastal Act would require the completion of all studies and the mitigation of all discovered significant impacts prior to the issuance of a permit. The PMPD itself correctly concedes that, under ordinary circumstances, the proposed project would bear greater scrutiny and might not pass muster. As the PMPD finds, the project as proposed relies on dated technology with fuel efficiencies considerably below that of more modern designs, will have a greater adverse effect on the ocean habitat by returning more wasted heat to the ocean than more efficient plants, and conflicts with visual-impact regulations along the coastal zone. See PMPD at 11. i y, Rather than evaluating the project at face value under its traditional practice,this proceeding has taken full cognizance of the present declared emergency and moved along smartly. In doing so, the.Commission Staff and the Assigned Committee have observed that potential impacts identified in this record will continue to be studied, with appropriate mitigation imposed upon the completion of such studies. As a compromise to the urgency of the situation, the City agrees with the PMPD, the Commission Staff, the Coastal Commission and CURE that a limited-term certificate to operate the retooled units is appropriate under the emergency circumstances in which the State finds itself. The limitation will ensure that capacity will be available for the coming summer peak-demand months while preserving the State's ability to revisit issues related to environmental quality, adverse impacts on public health and safety, the plant's technological obsolescence and the efficient use of fuel supplies at the end of the five-year term. It is important to consider that AES has not argued that the five-year limitation of the certificate would constitute a taking of operating rights. As the City's uncontroverted testimony demonstrates,AES will suffer no economic harm from having to decommission the units since they will have provided handsome profits over the five years of their operation. While AES contested the assumptions underlying the City's estimates of the net revenues that would be generated by the restart of the units, AES bluntly refused to provide its own net revenue and return projections. Using commonly available information related to those assumptions, the Commission can make its own estimates and no doubt will conclude that AES will enjoy full recovery of its invested capital, plus more than a modest return on its investments, during the five-year period contemplated by the PMPD's terms. Finally, the five-year limitation on the certificate adopted by the PMPD is supported by AES' own averments in the original application and throughout its showing. AES itself indicated that the plant would be operated for a period of between five and eight years and was being proposed as a solution to the existing energy-market supply-demand imbalance. The City suspects that, had AES not posed this project as a short-term solution to the current emergency, a far different procedural course would have governed the review of this project. In fact, it was not until the final moments of this case that AES revealed its intention to operate the retooled units for a minimum of twenty years and for as long as "several decades." If this is in fact the case and the 4 Commission is inclined to consider issuing a certificate of indefinite duration,the City must insist that the Commission reopen this proceeding so as to create a record supporting such a certificate. No party, save AES, has argued that the instant record is sufficient to support findings that there are no significant impacts beyond the immediate future, and the Coastal Commission has indicated that even five years stretches the operating period too far into the future. The five-year limitation is reasonable, fully supported by the record, and should be adopted by the Commission. 2. The Commission Has Ample Authority Under Which It May Limit the Duration of the Certificate Issued in this Proceeding. As noted above, the Commission possesses a broad and exclusive authority related to the siting of generating facilities in this State. See especially Public Resources Code Sections 25216.5 and 25523, providing authority related to the imposition of conditions on certificates. The Legislature clearly empowered the Commission to include conditions in certifications that it issues. Durational limits and lapses due to time are simply one form of tool that the Commission may employ in accomplishing its certification responsibilities, chief among them the protection of the environment and the public health, safety and welfare. Administrative officers and agencies generally have such implied powers as are necessarily inferred or implied from or incident to the powers and duties expressly granted or imposed on them. 73 C.J.S. Section 51, at 501. The power vested in an agency to grant licenses, permits, or other authorizations carries with it the power to exercise reasonable discretion in granting or refusing them. 73 C.J.S., at 503. Where the statute grants authority to impose conditions, an agency may do so subject only to the limitation that the conditions are just and reasonable. 73 C.J.S., at 545. These general rules governing the adoption of conditions related to the operation of generating facilities have long been observed by the California Public Utilities Commission (CPUC) and the Federal Energy Regulatory Commission (FERC), both of which consider time limitations in the granting of authorities to operate generating facilities. Pursuant to its authorities under the Public Utilities Act, the CPUC requires applicants to file information related to the useful life and operation of a facility, including data related to the expected useful life of the plant. See Public Utilities Code Sections 1001, 1003(a)(c)(d), 1005. Similarly, in issuing licenses for hydroelectric facilities, the FERC is required to specify the duration of any license as a condition of approval, and 5 all licenses are required to expire not later than a period prescribed by the Federal Power Act. 16 U.S.C. Section 799. In the present case, the PMPD, in duly recognizing severe time constraints would have to be placed on the review period to assure the timely construction of the retooling project, balanced the needs posed by the declared emergency while considering the potential adverse impacts the project might have on the environment and the public health, safety and welfare. Indeed,the Commission, at its Business Meeting of February 7,2001, found that the application had failed the requirements of Public Resources Code Section 25550 and was not entitled to fast-track processing under the Commission's newly adopted six-month siting procedures precisely because the applicant had not demonstrated, inter alia, that it could comply with federal, state and local air emission requirements. Where the Commission could reject the application altogether, the Commission should possess, as a simple matter of logic and under the rules of administrative procedure cited above, the juridical discretion to adopt what is in essence a temporary certificate tailored to meet the principal circumstance justifying the issuance of the certificate in the first place, namely, the immediate need for additional in-state generating capacity during the next two to five years. The five-year limitation on the certificate granted to AES is an appropriate manner in which to address what the PMPD describes as resolving a situation in which the Commission finds itself "between a rock and a hard place." Apart from the implicit authorities held by the Commission to limit the life of a certificate to some fixed period of time,state law specifically empowers the Commission to adopt such limitations in other contexts. Public Resources Code Section 25552 provides that,for simple-cycle thermal powerplants that are not a major stationary source, are equipped with the best available control technology, and will not have a significant adverse effect on the environment as a result of construction or operation,the Commission shall require as a condition of any certificate a binding and enforceable agreement for the powerplant to either cease operation within three years or be replaced within three years with a combined-cycle thermal powerplant using best available control technology. Under such circumstances, the Legislature has struck the same balance that the P.MPD strikes in the present case, specifically, that the imposition of a limitation on the effective 6 duration of a certificate is a reasonable condition in light of the expedited review process that would be used. Additional similar procedures and precedent can also be found in the Governor's recent executive orders. Under Executive Order D-24-01, the Governor ordered that local air pollution control and air quality management districts modify emission restrictions limiting hours of operation for generating facilities providing power under contract to the Department of Water Resources. By Executive Order D-28-01, the Governor recognized the appropriateness of limitations on the duration of these modifications. Thus, such modifications are limited to a three-year time period. Clearly, the Governor's framework under which additional near-term generating capacity is to be captured contemplates the imposition of limitations on the waiver of otherwise applicable environmental protections and standards. The PMPD's adoption of similar limitations is sanctioned and supported by the Governor's instructions. As a final matter, the limitation on the duration of the certificate adopted by the PMPD is consistent with expiration and renewal requirements related to other permits specific to this facility. The Facility Air Permit to Operate relating to the allocation of credits for regulated pollutants reissues on an annual basis by the South Coast Air Quality Management District("SCAQMD"). Section K of the Permit to Operate provides that the facility's Title V permit shall expire not more than five years from the date of its issuance. Additionally, in its Order No. 00-5 addressing wastewater discharge requirements for the facility, the Santa Ana Regional Water Quality Control Board has limited the permit for the facility through the period ending June 1, 2005. All of these permits are necessary preconditions for the Retool Project to operate. The PMPD's similar adoption of a limitation on the duration of the instant certificate is, contrary to the arguments posed by AES in its Brief, hardly extraordinary under administrative law, the procedures adopted to deal with the present emergency declared by the Governor, or even for the instant facility. The PMPD also adopts another related proposed condition submitted by the City. See PMPD at 11. In order to promote land-use and energy-supply planning, the City proposed that AES be required to file, on or about June 30, 2004, some two years in advance of the certificate's proposed lapse, a "master plan"for the site with both the Commission and the City, specifying 7 whether AES intends to request an extension of the certificate or take some other course of action, including whether it might abandon the units or replace them with a more modern facility. Although AES originally agreed to make such a filing, it has since reversed its position, arguing in its Brief that the filing of a master plan would be a burdensome exercise. The City continues to believe that the Commission and local planning agencies should be provided with the filing and that AES' late reversal of position should be disregarded. The condition is in the public interest and the PMPD should be adopted in this regard. C. Conditions Vesting a Native Load Preference in California Consumers The PMPD declines to adopt any condition requiring AES to execute a contract with the State for the delivery of the power produced by the units for the benefit of California consumers or that the price of the power be reasonable. The City,joined by CURE and the Commission Staff, asked for these conditions to assure that the plants would in fact provide some measure of solution to the State's ongoing energy problems. The PMPD takes the position that AES has indicated that it will deliver power to the State and that AES should be taken at its word. See PMPD at 10. The City submits that this resolution is inadequate and urges the Commission to adopt the conditions proposed by the City implementing a native load preference in the power to be generated by the project to the retail consumers of the State of California. In proposing conditions related to the delivery of power to the State of California, the City first relies on the various references to the intentions of AES submitted as part of the application and throughout its filings and showings in this proceeding. Certainly the Commission has the authority to require an applicant to observe its own filings and testimony under simple rules of jurisprudence. Rather than assuming AES will own up to its word, however, the City strongly recommends that the Commission impose conditions requiring AES to convert its rhetoric into delivery of the goods. The City would hope, as apparently does the PMPD, that such a condition ultimately proves to be inconsequential. That is, if AES' true intentions are that it will execute a contract with the Department of Water Resources or otherwise commit the delivery of the power generated by the plant into the California market so as to alleviate the current emergency, the City's proposed conditions will be mooted as those intentions are fulfilled. But if no such contract is forthcoming or in the event AES operates the units in the style of other plant owners of which the 8 State has complained in other forums, this project will not be the solution it has been billed to be and the Commission will have relinquished its opportunity to address the current emergency effectively. So as to be better safe than song, the City submits the Commission must adopt what is tantamount to a native load preference with respect to the power generated by the retooled units. To do otherwise is to place the resolution of the emergency in the hands of AES rather than within the jurisdiction of the Commission. Furthermore, the recent spate of gubernatorial and legislative directives fully demonstrate the State's expectation that this agency has not only the authority but the responsibility to assure that the emergency is resolved effectively and immediately. To fail to do so would fly in the face of the market conditions that have dictated the conduct of this proceeding and result in a failed opportunity to address those market conditions in a meaningful way. The City urges the Commission to create a solution in this matter and protect the environment and the public health, safety and welfare by adopting the pertinent conditions at issue in this docket. 1. The Imposition of Conditions Related to Delivery of the Project's Power to the Consumers of the State of California Is Consistent with the Commission's Plenary Jurisdiction with Respect to this Application and Other State Procedures and Administrative Rules. As previously stated, the City finds ample legal authority has been vested in the Commission to adopt conditions as part of any certificate as may be necessary to protect the environment or the public health, safety and welfare. The Commission holds a clear statutory mandate to specify"conditions under which approval and continuing operation of any facility shall be permitted." Public Resources Code Section 25216.5(a). That authority is plenary and exclusive with respect to other state agencies and, to the extent permitted by federal law, supercedes the authority of any federal agency. Public Resources Code Section 25500. Providently, the Legislature has vested additional implicit and explicit authority in the Commission related to resolving any"impending serious shortage of energy, or a clear threat to public health, safety or welfare." Public Resources Code Section 25216.5(b). The City submits that the Commission's authority to adopt conditions related to the delivery of power to the State's consumers under a Commission-imposed preference is fully supported by these provisions. 9 The Commission's jurisdiction to adopt contract and delivery requirements under the state of emergency that has been declared is evidenced in other procedures and laws adopted by the State of California. The Legislature has enacted similar contractual preferences with respect to permits for clean power plants providing peaking capacity. See Health& Safety Code Section 42301.14, regarding "cleaner[peaking] generating units" limiting term of permit to three years (subpart(a)(6)(A)(B)) and requiring operation exclusively under contract with Independent System Operator(subpart(a)(2)). Similarly, the Governor has recognized that, in light of the current emergency, permitting processes should be modified so as to provide preferences to power plants that will provide solutions. Thus, the Governor has created expedited permitting processes for plants delivering power under contracts with the Department of Water Resources and the Independent System Operator. See Executive Order D-24-01, Ordering Paragraph 1 (February 8, 2001), and Executive Order D-28-01, Ordering Paragraph 3(March 7, 2001), respectively. Clearly, both the Legislature and the Governor have presumed that the State has the authority to impose conditions on operating permits identical to the City's proposed conditions related to the constraint to sale of the power to the Department of Water Resources or such other agency as the Commission may designate. The special circumstances presented by the ongoing supply-demand imbalance in the California energy markets provide ample support for adopting the conditions proposed by the City. 2. Native Load Preferences Are Fully Consistent with the History of the Regulation of the Domestic Power Industry and Fully Supported by the Record Adduced During the Course of this Proceeding. Under the traditional regulatory regime involving vertically integrated utilities, the concept of native load preferences was implicit in each and every project undertaken by the utility. In evaluating any proposal for a project by any jurisdictional entity, the state would determine, in considering the issuance of a certificate of public convenience and necessity, the benefits the state's citizens would receive from the project. Accord, Public Resources Code Sections 25500.5, 25525; also, Public Utilities Code Section 1005. That the project might also serve the citizens of other states presented ancillary issues, except in those cases where a multi-utility or multi-state utility project was proposed, in which case each state affected would consider its preferences in the context of the multi-state issues. See, e.g., Public Utilities Code Section 1001.5. In every 10 proceeding involving the construction of new generating facilities in this state, the abiding presumption is that the project will serve the utility's native customers first and in some cases exclusively. The notion that native load preferences are objectionable as a matter of law would ignore the century-old regulatory history of the domestic power industry. Nothing in the implementation of retail competition in the state's electricity market causes changes the permissibility of native load preferences under either the Federal Power Act or the Commerce Clause of the United States Constitution. The coordinated federal-state regulation of interstate commerce is generally governed by a balance struck between the provisions of the Commerce Clause and the Tenth Amendment of the United States Constitution. See U.S. Const., Art.l, Section 8, cl.3 and U.S. Const. Tenth Amendment. Although the Commerce Clause indicates that Congress holds preemptive authority to regulate interstate commerce, the states yet hold substantial authorities to regulate matters not regulated under federal law or where the interests of the states are vital. It is well settled that the states retain authority under their police powers to regulate matters of legitimate local concern even where interstate commerce may be affected. Parker v. Brown, 317 U.S. 341 (1943); Lewis v. BT Investment Managers, Inc.,447 U.S. 27, 36 (1980). This authority exists even as to matters where there is a substantial federal interest and an otherwise comprehensive federal regulatory scheme. Accord, Pacific Gas & Electric Company v. Energy Resource Conservation & Development Commission, 461 U.S. 190, 194 (1978), with respect to state interest in regulation of electric power relative to the Supremacy Clause and affirming jurisdiction of this Commission to impose conditions on site license for nuclear power plants related to nuclear waste reprocessing and disposal; see also, Public Resources Code Sections 25524.1 and 25524.2. In exercising the rights reserved to their police powers, the states may grant a preferential access to the products of the state notwithstanding any effects such preferences may have on interstate commerce. Reeves, Inc. v. Stake, 447 U.S. 429 (1980). With respect to electric power, the Federal Power Act specifically addresses and incorporates the above constitutional principles. Section 201 of the Act declares that,while the business of transmitting and selling electric power is affected with a public interest, federal regulation shall "extend only to those matters which are not subject to the regulation by the States." 11 16 U.S.C. Section 824(a). Section 201 further provides that the Federal Energy Regulatory Commission (FERC)only holds jurisdiction with respect to generating facilities to the extent specified by the Act, preserving the regulatory authority of the states with respect to such facilities. No provision of the Act affects the siting of thermal power plants nor does any provision of the Act imply that all electric power from thermal power plants shall be made available to the interstate wholesale markets regulated by FERC. Chemehuevi Tribe of Indians v. Federal Power Commission, 420 U.S. 395 (1975). The absence of any such provisions provides for the reasonable regulation of the services to be rendered to customers or consumers of power as may from time to time be prescribed by any duly constituted agency of the State. While economic protectionism is generally void, the mere appearance of a preference, particularly where attached to a traditional local interest and where the exercise of the state's police powers are tailored to the interest, does not constitute a violation of the Commerce Clause. The City has found only one instance in which a state agency was prevented from adopting an explicit native load preference. New England Power Co. v, New Hampshire, 455 U.S. 331 (1981). In that case, the Supreme Court held that that the state could not ban out-of-state sales of power generated by a federal hydroelectric licensee. The Court held that such a requirement ran afoul of the strict prohibition against conferring a preference in the natural resources of a state, a matter specifically addressed by the Federal Power Act's provisions related to the licensing of hydroelectric projects. Id., at 338, 340-341. The Court found New Hampshire's action particularly offensive since the state based the prohibition on its express intention to prevent other states from enjoying the cost advantages of the hydroelectric facilities subject to the prohibition. The Court in New England Power did not reach the question of whether native load preferences were altogether barred under the Federal Power Act or the Commerce Clause, declining to describe"the precise contours of the saving clause" of the Federal Power Act. Id., at 343,fn. 9. In the instant case, however, the siting procedures involved are not only derived purely from state processes related to a thermal power plant over which the FERC has no general jurisdiction, but were created out of the further necessity to address a declared emergency within the state. Nothing in New England Power indicates that state procedures designed to address a 12 local emergency, borne of supply shortages, cannot require that permits granted under those procedures shall in fact fulfill the state interest underlying those procedures. On the contrary, the Court in the same session sanctioned the exercise of state police powers to restrict the production of a cement producer to in-state sales where the state did so in response to a regional supply shortage. Reeves, supra,at 441. Where the state's creation of a preference did not affect a' natural resource and was not borne of protectionism,the Court held that the preference for in-state sales was nothing more than an "effective and creative program for solving local problems." Id., at 441-443. The interests of the state are significantly greater in the regulation of electric power, where the Court has recognized that federal enactments do not direct that states allow the construction of plants regulated by federal agencies, leaving the question of"whether a plant should be built to the states." Pacific Gas & Electric, supra, at 207. Furthermore, where electric power is concerned, Congress has reserved to the states the traditional responsibilities of regulating the construction and operation of generating facilities and the determination of need. Id., at 205. To deny the states a right to impose a native load preference in favor of its own consumers, particularly in circumstances of shortage and emergency,would preclude any requirement that a generating plant serve those aspects of public convenience and necessity justifying its construction in the first place, an absurd result. Under this scheme of shared federal-state regulatory authority, the concept of native load preferences remains a vital part of the state regulatory scheme and is reflected in siting statutes empowering local agencies to determine whether any proposed project will serve the public convenience and necessity. Clearly, the Commission has not been heretofore barred from considering the extent to which the interests of California consumers would be served by a proposed generating facility. In fact, the Commission is obligated under the terms of the Warren- Alquist Act to make findings as to whether the public convenience and necessity would be served by such a facility and make findings related to the public convenience and necessity. Public Resources Code Sections 25500.5, 25525. That consideration specifically includes the manner in which the operation of any proposed facility will benefit the State's consumers and local reliability. The only remaining issue before the Commission, then, is whether, in considering whether the public convenience and necessity will be served by the proposed project, the Commission may impose such conditions as necessary to assure that the public convenience and necessity will in 13 ' d fact be served. The City submits that the authority to impose such conditions is explicitly provided in the Warren-Alquist Act. Public Resources Code Section 25516.5. The record in this matter evidences that the public convenience and necessity might be served by the retooling of Huntington Beach Units 3 and 4. The delivery of any power produced by the units could alleviate the energy shortages anticipated for the summer. The procedures adopted for the prosecution of AES' application were constructed so as to assure that this anticipated public benefit would be captured. But as the Commission is well aware, the availability of generating capacity is not in and of itself the answer. Much of the state's generating capacity has been off-line at inopportune times, under circumstances other state agencies have found to be suspicious and contrary to the public interest. Other generators deliver power but only when prices reach levels failing standards governing just and reasonable rates. In light of these circumstances, the ability of the proposed project to serve the public convenience and necessity must be augmented by a coincident contractual obligation obligating the project to in fact provide that service. The City submits that, in the absence of any federal regulation to the contrary, the Commission may enforce the state's interests related to the siting of the retooling project. The FERC holds no jurisdiction with respect to the siting of thermal power plants and has expressed no intent, with the exception of authority related to its own hydroelectric licensees,to compel the delivery of electric power into interstate commerce from such plants. This fully confers upon the State of California a reserved jurisdiction to impose a native load preference on the power produced by the proposed project for the benefit of the citizens of the State. In the absence and exercise of such a jurisdiction, granting the certificate in this case makes little or no practical sense. Without meaningful conditions related to the delivery of power to the State's consumers at just and reasonable prices, the Commission will authorize AES to ignore its own showing that it intends its project to provide a solution to the current emergency and otherwise wholly betray the Commission's rationale for adopting the unique procedures applied to this application, rendering any resulting certificate defective. Rather than being precluded by the Commerce Clause or the Federal Power Act from adopting the City's proposed conditions relating to native load preferences, the Commission is compelled by state law and the record to impose such conditions. 14 D. Conditions Related to Local Laws, Ordinances, Regulations and Standards The Commission accepted the application as "substantially complete"on February 7, 2001, despite acknowledging that certain deficiencies remained in the AES application. The Commission noted the City's objections to the acceptance of the application, finding that since the application was not entitled to expedited procedures the remaining defects would be cured over the course of the coming year. On February 8, 2001, Governor Gray Davis issued several emergency orders providing for expedited permitting of power plants that could alleviate the State's anticipated energy supply shortages. On February 9th and in disregard of the Commission's rulings of February 7th, the Commission Staff implemented a sixty-day procedural schedule for the AES application and this matter has been off and running ever since. The Committee rejected the City's motion to overturn the Staffs procedural schedule and, on March 7, 2001, Governor Davis issued another emergency order essentially affirming the Committee's ruling. This case has been conducted under the fastest schedule for any power plant in the history of the State, with study and hearing schedules that normally take a year being compressed into forty-five days. The Committee and the Commission Staff, taking due notice of the practical effects of the schedule, have observed a general rule that mitigation measures related to anticipated or undetermined but foreseeable environmental impacts or impacts on the public health and safety would be considered. This rule took the place of the Commission's normal practice of carefully studying the potential impacts of any proposed project and requiring the mitigation of any significant adverse impacts exposed during the study period. The City submits that under the circumstances the rule was justifiable and reasonable. But the rule should be applied strictly and the Commission should err on the side of imposing, rather than relaxing, conditions on the certificate granted in this matter. A. Air Quality Issues The largest source of air pollutants at the Huntington Beach facility is Unit 5, a peaking unit comprised of eight gas-fired combustion turbines. The City, CURE and the Commission Staff support strict limitations on the operation of that unit so as to mitigate the added emissions from the operation of Units 3 and 4. The PMPD adopts the requirement that the operation of Unit 5 be 15 r , � limited to hours during which the California Independent System Operator declares a Stage 3 power alert and that otherwise Unit 5 not operate during hours when Units 3 and 4 are operating. Additionally, the PMPD requires that Unit 5 be removed from service on or before December 31, 2002 (as opposed to the City's request for shutdown on or before September 30, 2001), unless control technology approved by SCAQMD is installed on the unit. Consistent with the previous arguments submitted in these comments, the City submits that the Commission has the full authority to impose conditions related to the operation of Unit 5 under the terms of the Warren- Alquist Act. AES has submitted nothing in its Brief requiring a contrary result. Moreover, the record supports findings that AES has previously misstated both its ability to test the air emissions resulting from the operation of Unit 5 and the level of emissions generated by the operation of that unit. Both CURE and the City have provided to the Commission the records of the SCAQMD describing source tests for Unit 5. These source tests demonstrate not only the feasibility of the tests but that Unit 5 produces much higher levels of emissions than cited by AES. The adverse impacts on local air quality and health are likely to be much higher than admitted by AES. Restrictions on the operation of Unit 5 are fully justified to mitigate the adverse impacts on local air quality that will result from the restart of Units 3 and 4. The Proposed Decision either rejects or omits discussion of several other conditions raised by the City related to air quality. The City respectfully requests that the Commission consider the following additional conditions. The City has recommended that AES be required to perform source tests for Unit 5 for various regulated pollutants, such tests to be performed on a random basis. The PMPD's requirement that such tests be performed under observation does not reach either the City's or CURE's objections to staged and scheduled tests, namely, that the results can hardly be considered realistic with respect to actual operating conditions inasmuch as the tests can be "staged." The City requests that the Commission reconsider its position with respect to the test procedures and require such tests to be conducted on a random basis subject to order of the Commission or local regulatory agencies. As an additional condition protecting the public health and safety,the City urges the Commission to require continuous emission monitoring of ammonia slip during the operation of 16 Huntington Beach Units 3 and 4. The PMPD only requires that AES conduct and file a technology feasibility study. See PMPD at 29, AQ-5. At the very least,the Commission should specify the parameters apposite to any determination of whether monitoring is feasible. Finally, the City urges the Commission to require that AES make a good faith effort on an annual basis to obtain air-emission credits and offsets from within Orange County so as to mitigate emission impacts within the general vicinity. This will create the greatest potential for local mitigation of the adverse impacts associated with the restart of the units. To the extent AES cannot obtain sufficient credits and offsets within the county, a report to that effect, describing the efforts it has made, may be filed with the Commission with AES thereafter being relieved of further obligations. B. Noise Regulation As the City reads the PMPD, AES will not be required to obtain a variance from the local noise ordinance which would otherwise restrict construction hours. The PMPD adopts the City's recommendations with respect to the level of noise that might be permitted outside normal construction hours, namely, that no construction noise five dbA above ambient sound levels be permitted between the hours of 7:00 p.m. and 2:00 a.m. The PMPD, however, omits any discussion of providing alternative nighttime accommodations for nearby residents as requested by the City. The City asks that the Commission take notice that noise complaints from construction activities into the wee hours of the morning over three months can be expected and that nearby residents will suffer hardships from nighttime construction, regardless of whether AES manages to remain within the noise limits or strays above them occasionally or routinely. The City therefore recommends that the noise-complaint procedure provide for an onsite noise technician who can receive complaints during any hour in which construction is taking place and provide for lodging allowances for the facility's neighbors. C. Mitigation of Biological Impacts The City fully supports the PMPD's holding that AES should be required to participate in the local studies of the possible contribution power plant operations make to the presence of indicator bacteria in the surf zone. Although AES must provide $1 million to support the studies 17 and is held responsible for mitigation in the event the studies indicate the power plant is a contributor to the problem, the City joins the Coastal Commission in the concern that both the study and any mitigation measures may entail costs considerably above the$1 million figure. The City continues to support requirements that the Commission provide for adequate funding of any mitigation measures that might emerge from the studies. Leaving the issue of responsibility for Mitigation to be determined until after the studies are concluded places environmental protection and the protection of the public health and safety at risk. In light of the potential impacts contamination of the beaches might have on visitors, residents and the local economy,the requirements posed by the City pale by comparison. The PMPD omits discussion of several other conditions raised by the City related to impacts the project may have on local biological resources. With respect to two such conditions, the City submits that the record supports findings that AES can readily achieve the minimization of impacts on the environment and that conditions requiring the effort should be imposed. First,the Commission should ban heat treatments as the method by which the plant intake tunnels are cleared of mollusks so as to reduce fish kills in the tunnel. This can reduce the impacts operation of the Huntington Beach Generating Station will have on local marine resources until such time as ongoing biological impact studies can be completed. Similarly, the Commission should restrict plant wastewater outflows to a temperature no greater than twenty degrees higher than the ambient temperature of local seawater. This condition is generally achieved under normal operating conditions at the plant currently and is consistent with the limitations likely to be required by the Santa Ana Regional Water Quality Control Board if and when the plant's NPDES permit is up for renewal. D. Local Control Issues Among the major omissions in the PMPD is the lack of any discussion related to the conditions under which the City would act as the Chief Building Official for the purposes of overseeing construction activities and enforcing the local building code. The City had presented a series of conditions that were prerequisites to its assumption of CBO responsibilities. Since none of these conditions were adopted, the City's ability to perform effectively in this role was adjudged. to have been jeopardized and the City was forced to decline the Commission Staffs invitation to act as the CBO in this project. Notwithstanding that the City has withdrawn from acting as the CBO 18 s ti for this project, the City has submitted two conditions that should be adopted nevertheless. The first has to do with providing information to the public as to the appropriate point of contact for whomever serves as the CBO and the second provides for ongoing oversight by the City Fire Department irrespective of who performs the CBO role. These conditions should be added to the certificate. The PMPD also rejects the City's proposed conditions related to community betterment. This affects two proposals submitted by the City. First, the Proposed Decision does not require AES to make any contribution to the local parks and recreation fund;notwithstanding,the PMPD's finding that the plant detracts from the local area and poses certain adverse and significant environmental impacts. Second, the Proposed Decision does not require AES to provide impact mitigation funds in advance of those impacts becoming a nuisance or hazard. AES is,once again, trusted to fund any mitigation on a pay-as-you-go basis. The City submits that these conditions constituted the practice enforced by both this Commission and the Public Utilities Commission with respect to projects proposed by regulated utilities. See Public Utilities Code Section 1002(a)(1)(2). Furthermore, many of the projects reviewed by the Commission recently, despite the fact that their proponents are not regulated utilities but exempt wholesale generators, have continued the practice. For projects subject to permitting by the City, the City typically includes requirements for parkland set-asides or in-lieu park fees as a condition of construction. The City submits that these conditions are de minimis with respect to the impact they may have on AES and its returns and, consistent with state practice and local law, will enforce the Committee's admonitions to AES that it should assume the role of.good neighbor to the residents of Huntington Beach. Finally, the PMPD is unclear as to whether AES will be required to complete seismic studies and retrofits related to the existing foundation and structure. (Compare PMPD at 146-148 re GEN-1 with PMPD at 154-155 re STRUC-1.) As a pre-1960 facility, the plant was not built to withstand earthquakes of any magnitude. The PMPD cites to the 1998 California Building Code and requires observance of its requirements in GEN-1, but STRUC-1 only requires the filing of plans without making clear that observance of code requirements shall govern these. The ordinary case in any other construction project would require bringing the preexisting facilities up to code, including seismic standards. Failure to do so would pose hazards for workers and passersby. The PMPD could result in a curious distinction between new and old facilities. While new structures 19 and components must comply with modern seismic standards, major foundational and structural components that are integral to the new structures and components may not be brought to seismic standards, rendering the requirement related to the new structures and components in.large respects wasted effort and small comfort. The City requests that the Commission clarify the requirements being imposed on AES in favor of code compliance. E. Conclusion The City acknowledges the effort the PMPD makes at arriving at a timely and balanced result. With additional consideration of previously omitted issues,the PMPD can achieve its intended result of assuring that adverse impacts on the environment and the public health,safety and welfare can be achieved, while improving the outlook for the upcoming peak-demand season in the State of California. Except as specified herein or its prior Brief as submitted in this proceeding, the City supports the PMPD and urges its adoption. Respectfully submitted, [I'Original signed by Patricia Romero for Alvin S.PaM Alvin S. Pak Special Counsel for the City of Huntington Beach Jeffer, Mangels, Butler& Marmaro LLP One Sansome Street, 12th Floor San Francisco, California 94102 San Francisco, California April 9, 2001 20 ,EIVED FROM [&Z'tL&z-V ' I&do ")BLIC RECORD FOR-CQUNP ylEEM ITY CLERK OFFIIC /OS -AN L.FLYNN,CITY CLERK Water- Energy Santa Barbara 6600 MWDOC 5500 Carlsbad 540 Tampa 35157 Chino desalter 1 00 recycled water 1200 trmt groundwater 50 0 1000 2000 3000 4000 5000 6000 7000 Kilowatt Hours per acre-foot Figures from CEC 2005 Energy Report Committee 1 WaterosComparison t Saudi Arabia Desal M$1,356 Imported $507 Groundwater $285 $0 $200 $400 $600 $800 $1,000 $1,200 $1,400 $1,600 Dollars per acre-foot (325,1151 gallons) Fully encumbered costs 2 Natural Gas Prices U.S. futures $L 1.69 Saudi Arabia (2002) $0.75 $0.00 $2.00 $4.00 $6.00 $8.00 $10.00 $12.00 $14.00 Per thousand cubic feet 3 Energy Component of Desalinated Water Tampa pays Poseidon Edison Edison 4¢/KWh assumes commercial commercial 6¢/KWh rate (low end) rate (high end) 12.30/KWh 12.7¢/KWh 5476.80KW x 5476.80KW x 5476.80KW x 5476.80KW x .04 = .06 = .123 = .04 = $219.07 $328.61 $673-65 $711 -98 4 IV- _ . . - - .—l�.. ,S S�1P•T�� .wa,r' •�Z � L�7 `���.°�`���•:4--+-`�W"'+� T' -•T • • . •�tYi,���I.Matdde,..�^-f"�-,.M,i J��„z+ra..� '�}a �r�".7�' � �k t k,..,,�+--". �,r' �a 1} `` I. - dp yV '�1�- �'.��„r....-•-1--" �"��Li ..�- aasrrnx `�a. ... •wt+:.'"' ��` "^..,,� • �>t iJ -•r_s ,14 • off r 6 ,Yt}Jr ! .!'�Nf' n..a �+lt a�'hhlIp f'I i -tr >7 n4 ;,tr,�� .v-."v '•`� � u� l�h bl 'ry.!h• N I A A P I , �n i e"�ikwl ,i,; U Qiri�'v, q � 1 b 1 .,,,.-. AES 2001 Retool ENERGY"IA • 10 year certification expires HUNTINGTON B-A i9�H COMMISSION GENERATING STATION in 2011 RETOOL PROJECT Application For Certitication 00-AFC-13 Orange County CD • "in 2006 , the Energy W z Commission will determine 0 complied if AES has lied with p P � - a all Conditions of T Certification and : . MAY 19 implemented measures to ■ mitigate environmental impacts . " Grad Nab,GsrwW 6 Emergency C CALIFORNIA'S ELECTRICITY EMERGENCY The AES Huntington Beach Retool Project as recommended for cenification is a "Absent responding t o t h e creature of California's electricity supply emergency,both in its design and regulatory processing. AES proposes to rebuild and upgrade the internal components of two current electricity 1950's vintage boilers that were retired from use by SCE in 1995. AES testified that g purchased the its state-of-the-art Beach Generating Station with the emergency, the A E S intention of replacing the old boilers with stale-of•the-art combustion turbine combined cycle units. At some unspecified time and based upon factors to which we are not privy, AES began the process of preparing an Application for Certification to resurrect the sole project does not present units. AES's design included the use of air pollution control technology that will allow Units 3 and 4 to burn nearly as cleanly as modern combined cycle units. As a result, AES filed its Application for Certification in December 2000, contemplating a routine,nominal 12-month regulatory review. sufficient justification to In the intervening time,instead of remaining routine and nominal,California's electricity perpetuate the y i n taq e supply situation has become an emergency. By various Executive Orders, Governor Davis has declared an energy supply emergency and directed the Energy Commission marshal state resources t expedite its regulatory reviews bring new generation re Huntington Beach resources online,with a particular emphasis on generation which coulo be available for the summer of 2001. For its part,AES has responded to the electricity supply emergency by offering to retool power p I a n t o n a Huntington Beach Units 3 and 4 in 90 days from the date of licensing. Therefore,to enable AES to fulfill such a pledge and bring Unit 3 and 4 generation on line by mid-July 2001,the Energy Commission has instituted a highly expedited process that could lead coastline of world- Other to certification by mid-April 2001. energy developers are currentty proposing to replace their vintage coastal boiler• renowned scenic, type power plants,whether purchased from SCE or PG&E,with new combustion turbine combined cycle units,as AES had originally intended. Duke Energy's Morro Bay Project and Dynergy's El Segundo Redevelopment Project use state•of-the-art emission recreational, a n d controls. consume about one-third less natural gas than a boiler unit to produce an equivalent amount of electricity, and return less-heated cooling water to the ocean environment. All of this comes in a low profile,less visually intrusive package than the environmental value. " Huntington Beach proposal by AES. 1,^a facilities model California's future coastal oeM:er plant, Absent responding to the current electricity emergency,the AES project noes not present sufficient justification to perpetuate the vintage Huntington Beach power plant on a coastline of world-renowned scenic,recreational,and environmental value. Consequently,the Energy Commission will certify the retooled facility for 10 years to be available to fully address the electricty supply emergency,since the initial years of this period will likely coincide with the term of the electricity sales contract which AES 4 7 Water- Energy WATER-ENERGY • "Effective water RELATIONSHIP conservation and In support of the W efficiencprograms 2005 Integrarated Energy Policy Report G. VV y a Matt Trask U.Environmental Office U. can provide an entire Systems Assessment and Facilities Siting Division ■ ■ California Energy Commission string of benefits, including ener DISCLAIMER sa vin gs, reduced air This paper was prepared as the result of work by a member of the staff of the California Energy Commission.It does not necessarily represent the emissions, and lowered views of the Energy Commission,its employees,or the State of California. The Energy Commission,the State of California.its employees,contractors and subcontractors make no warrant,express or implied,and assume no legal liability for the information in this paper;nor does any party represent that the uses of this information will not infringe upon privately owned • " rights.This paper has not been approved or disapproved 6y the California na tura 1 ga s paces• Energy Commission nor has the California Energy Commission passed upon the accuracy or adequacy of the information in this paper. June 2005 CEC-700-2005-011 8 r f as Disconnect The • Water agencies are in the business of providing water r I I • Subsidies are actually lower for methods that consume less energy — $130/AF for OCWD groundwater replenishment project him — $250/AF for seawater desalination I 9 Congressional • "Subsidies for new coo desalination facilities USUMONY would most likely not Statement of improve the overall Douglas Holtz-Eakin Director YCBO's Comments on H.R. 1071 economic efficient of a Bill on Subsidizing New Desalination Facilities water s upp lY and use beforebecause such subsidies Subcommittee on Water and Power on Re Committee on Resources U.S.House of Representatives would compound the May 24,2005 , ..v ur embur,daOb.Y7.......10 ....u../F.OT1un distortion of price pnhGshrd.h'n2vm in.d.nr...,,.rods...ununuu firmed ..........I...rn.ri.,.,edi.r l,cfUre , YY r;.r.,ri..,.. signals. g CONGH el SSIONAL BUDGIKT OFFICE May, 2005 SF,COND.AND D STREETS,S.W. WASH I NCI'ON,D.C.20515 10 West Basin Municipal Water District El Segundo Desal Pilot Project 1 /5/05 Board Meeting Minutes • RWQCB has required the District to perform the following: x — West Basin shall evaluate impingement and entrainment _ impacts that may result from a full scale facility. The feasibility of - - alternate options, such as beach wells, infiltration galleries, eto., FLI must be fully explored before the operation of full scale desalination; and zr — An extensive energy consumption evaluation shall be conducted and results submitted in the Final Report. 11 — a , pigs == � EIR su osed to be a Full p Disclosure Document a. a m �•_"--.-^—.-_fu-;'`�.:-._._.-_� � — ._ __ - 'se � vet _ "f '- _ What is the relationship between AES & Poseidon? _ I — CUP application was filed jointly by AES & Poseidon _ .. z',sr'.ea-• — - - . Ate-.. .y43 �s-t - — AES entrainment/impingement == f study should have been included in EIR. ,oa i4 Foreseeable -� certification mitigation measures should have been analyzed Energy analysis cursory - - water exchange Pending t e g n e agreements should be analyzed 12 DWR Desal • Compare benefits, costs, and environmental impacts with Water Desalination other water supply alternatives. Findings and Recommendations • Complete a current assessment of entrainment October2003 and impingement impacts. • Analyze impacts of facility apart from the operations of the co-located facilities. Fully disclose same information as a publicly Gruy Davis,Governor,State of California owned facility. Mary D.Nichois,Secretary for Resources,The Resources Agency Michael J.Spear,Interim Director,Department of Water Resources • Growth related impacts should be properly evaluated. 13 These are the Significant Impacts not addressed in the EIR • Lost opportunity for state of the art power plant • Energy demands will burden region with higher costs and reduced reliability • Ocean environment will continue to decline • Subsidies of water and electricity will reduce conservation efforts • Water source encourages urban sprawl • Non-renewable resources will be squandered 14 a ,f STATE OF CALIFORNIA-THE RESOURCES AGENCY - - ARNOLD SCHWARZENEGGER,GOVERNOR CALIFORNIA COASTAL COMMISSION I � x 45 FREMONT, SUITE 2000 SAN FRANCISCO, CA 94105-2219 VOICE AND TDD (415) 904-5200 FAX (415) 904-5400 September 6;2005 City Council City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 VIA ELECTRONIC MAIL Re: Proposed Certification of FIR for Poseidon Desalination Facility Dear City Councilmembers and Interested Parties: Coastal Commission staff is providing the following comments for consideration at this evening's City Council meeting regarding the adequacy of the EIR done for the proposed Poseidon desalination facility. These comments are in part based on the Response to Comments (Response)the City issued on August 17, 2005 and the Notice of Public Hearing we received earlier today. While Commission staff won't be able to attend this evening's hearing, we hope these comments are useful in your deliberations. Please note that these comments and concerns are not about whether this desalination facility is a good idea or a bad idea; they are about how to determine what effects the proposed facility would have on the coastal resources of Huntington Beach. Our comments throughout this process have been based on what is required pursuant to CEQA and the Coastal Act, with additional consideration given to the Findings and Recommendations of the state's Desalination Task Force, established in 2003 to identify opportunities and constraints related to the use of desalination in California. To sum up our concerns, the EIR does not yet provide adequate information to determine the likely adverse effects of the proposed desalination facility and does not yet meet the standard of review necessary for CEQA or the Coastal Act. We therefore recommend the City not yet certify the EIR. We recognize the challenge of preparing an EIR that adequately addresses the issues associated with this proposed project; however, we find it remarkable that, in spite of the City's receipt of more than 50 comment letters, many of which were from agencies and organizations with expertise on desalination, marine resources, or CEQA, and that identified significant shortcomings in the DREIR, the City's Response resulted in no substantial changes to the EIR. The Response states, in fact, that of the hundreds of specific comments received;none "substantially affect the conclusions" of the DREIR. While our comments in this letter focus on just two key issues that were mischaracterized in the DREIR and the Response, there are many others for which the Response ignores clear direction in CEQA or the Coastal Act for addressing the impacts of proposed projects. �f Comment Letter on proposed EIR Certification—Poseidon Desalination Facility September 6, 2005 Page 2 of 7 The two key issues of focus in this letter are the proposed desalination facility's effects on marine biology and how it would interact with power plant operations, and we describe herein how the DREIR and the Response inadequately address those issues. These are discussed in more detail below, but briefly, our main points are: • The EIR needs to incorporate the data and analyses from the Energy Commission's recently completed study of entrainment caused by the intake system. • The EIR needs to identify and evaluate the reasonably foreseeable effects of the proposed desalination facility associated with its relationship to the power plant. By not adequately addressing these issues, the Response and the EIR are incomplete and inadequate for purposes of CEQA and for use in determining the proposed project's conformity to applicable elements of the Coastal Act, including those incorporated into the City's Local Coastal Program. I. Role of the Energy Commission entrainment study in this CEQA review: The main reason the desalination facility is proposed to be sited at the power plant is so it can use the power plant's seawater intake. The California Energy Commission recently completed a study of the effects on marine biology caused by that intake system (AES Huntington Beach L.L.C. Generating Station Entrainment and Impingement Study Final Report—April 2005, or Final Report).' Several DREIR commenters, including Coastal Commission staff, noted the relevance of this study to the desalination proposal and requested it be incorporated into the EIR analyses. The Response states that this study was not used for several reasons, including that the study was "not likely to provide new information of substantial importance regarding the potential significant impacts of the desalination facility"; and, that the study's final analysis has "not yet been finalized nor made available to the public". In support of these conclusions, the Response cites CEQA Guidelines Sections 15088.5 and 15162. These conclusions are inappropriate for several reasons: • First, the Response errs in concluding that the study is not likely to provide useful information. The study shows that the intake causes a loss of marine organisms equivalent to those produced in almost two square miles of ocean water off of Huntington Beach. This is a significantly greater adverse effect than is described in the DREIR. For example, Chapter 4 (Existing Conditions) of the DREIR makes no mention of the intake system's effects on marine resources, and Chapter 5 (Environmental Analysis) at page 5.10-11 describes HBGS operations as having"no detectable adverse effects on the marine biota or the beneficial uses of the receiving waters". It cites monitoring reports from 2001 in support of this conclusion. Therefore, the DREIR does not adequately or accurately describe existing environmental conditions caused by the intake system, and does not describe the increase in adverse effects likely to be caused by the desalination facility. Further, the Response incorrectly refuses to incorporate this more recent and more extensive study that evaluates the same type of impacts that would result from the desalination facility. We note that the City was an intervener in the Energy Commission's review and approval of the power plant upgrade that required this study be completed. I Comment Letter on proposed EIR Certification —Poseidon Desalination Facility September 6, 2005 Page 3 of 7 • Next, the Response states the study is not used because it has not been"finalized nor made available to the public". These are both misstatements. The study is has been publicly available since early May of this year. As the City staff confirmed two weeks ago, the Energy Commission considers the study to be a public document, and in fact, has made it available to any parties interested in reviewing it or commenting on it. We note that the Energy Commission sent a copy of the study to the City earlier this summer, several weeks before the City issued its August 17th Response document. Additionally, as is evident from its title, the study results are in a final report. This report represents the full set of data collected during a year-long sampling effort and includes analyses of those data showing that the intake system causes significant impacts to marine biology along the Huntington Beach shoreline. This is the kind of information used during CEQA review to determine project-related impacts and necessary mitigation measures (see the discussion of CEQA below). Leaving these analyses out of the EIR creates an incomplete and insufficient CEQA document. • The Response also miscites or misinterprets the provisions of CEQA that address how to evaluate new information, such as this study. The Response cites CEQA Sections 15088.4 and 15162 in support of its contention to not use the study; however, both of those provisions actually support inclusion of the study. CEQA Section 15088.5 describes "'significant new information `requiring recirculation" of an EIR (emphasis added) as including information that discloses a"substantial increase in the severity of an environmental impact"unless "mitigation measures are adopted that reduce the impact to a level of insignificance". Clearly,the entrainment study fits this description—it describes almost two square miles of lost production in the marine environment, which is a substantially different impact than the finding in the DREIR of"no detectable adverse effects" due to the intake system. Regarding CEQA Section 15162, it appears this section was cited in error, since it describes how to address information that becomes available after an EIR has been certified.2 Still, this section provides further support of the intent of CEQA to ensure decision-makers have the Z Section 15162,states,in part: "...new information of substantial importance,which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete or the Negative Declaration was adopted, shows any of the following: (A) The project will have one or more significant effects not discussed in the previous EIR or negative declaration; (B) Significant effects previously examined will be substantially more severe than shown in the previous EIR; (C) Mitigation measures or alternatives previously found not to be feasible would in fact be feasible,and would substantially reduce one or more significant effects of the project,but the project proponents decline to adopt the mitigation measure or alternative; or (D) Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment,but the project proponents decline to adopt the mitigation measure or alternative." Comment Letter on proposed EIR Certification—Poseidon Desalination Facility September 6, 2005 Page 4 of 7 best information available with which to make their decisions, and it is similar to Section 15088.5 in that it recognizes the importance of new information that identifies a proposal's increased adverse impacts. We additionally note that the study also meets CEQA's definition of substantial evidence found in Section 153843, and as such, should be incorporated into the EIR. The erroneous dismissals in the EIR of the adverse effects caused by the existing intake system and the likely additional adverse effects that would be caused by the desalination facility seem to stem from two misunderstandings about how the power plant and desalination facility would interact. The document states, essentially, that because the power plant causes 100%mortality to entrained organisms, the desalination facility would not cause any additional mortality.4 The EIR assumes that the desalination facility would not result in any additional water being drawn through the intake and that it would not cause any additional mortality above what is caused by the power plant. These assumptions appear to be incorrect: • First, the desalination facility is proposed to operate at all times except during the occasional heat treatments at the power plant. This means the desalination facility would operate even when the power plant is shut down for maintenance, is not operating due to market conditions, or is not generating electricity for any other reason. • Second, while both the power plant and the desalination facility cause essentially 100% mortality to marine organisms, this is true for the power plant only when it is generating electricity and drawing those organisms through the high heat and pressures of the power plant condensers. When the power plant is not generating electricity and is only drawing water through its intake as a"maintenance" flow, the rate of mortality is likely lower since the organisms are not exposed to the same high heat and pressure. The desalination facility, however, would be causing the same 100%mortality at all times regardless of whether the power plant is generating electricity. 3 CEQA Section 15384 states: (a) "Substantial evidence"as used in these guidelines means enough relevant information and reasonable inferences from this information that a fair argument can be made to support a conclusion,even though other conclusions might also be reached. Whether a fair argument can be made that the project may have a significant effect on the environment is to be determined by examining the whole record before the lead agency. Argument, speculation,unsubstantiated opinion or narrative,evidence which is clearly erroneous or inaccurate,or evidence of social or economic impacts which do not contribute to or are not caused by physical impacts on the environment does not constitute substantial evidence. (b)Substantial evidence shall include facts,reasonable assumptions predicated upon facts, and expert opinion supported by facts." 4 We note that the EIR's contention of power plant-caused mortality of roughly 95%is based on in-plant testing, which does not represent the effects on any surviving organisms when they are discharged from the power plant. Guidance from the various regulatory agencies is to assume 100%mortality, either due directly to the high heat and pressure in the system or due to the increased predation on organisms once they are discharged from the system. Comment Letter on proposed EIR Certification—Poseidon Desalination Facility September 6, 2005 Page 5 of 7 Therefore, the desalination facility would cause adverse effects above and beyond those caused by the power plant, even at the minimum intake flows identified in the DREIR that would occur when the power plant is not generating electricity. By not evaluating this issue, the EIR does not adequately address how big an additional impact this represents, and the EIR therefore incompletely and inadequately describes the proposed project's effects on marine life along Huntington Beach. II. Relationship between the power plant and the proposed desalination facility: Our comments identified several key regulatory or contractual issues that the DREIR should have addressed, but did not. These issues involve reasonably foreseeable changes at the power plant likely to affect operations of the proposed desalination facility and result in adverse environmental effects. They include: • Expiration in 2011 of the power plant's current approval by the Energy Commission to operate two of its units; • Upcoming NPDES permit review subject to new U.S. EPA requirements for once-through cooling systems; • Various energy supply contracts, including those with terms of less than a year or three years; • The power plant's development plan submitted to the Energy Commission, which does not identify a desalination facility on the site; and, • Conditions of the lease between the power plant and the desalination facility. In response to our request to evaluate the effects of these reasonably foreseeable events, the Response merely states that the desalination facility could not operate the seawater pumps independent of the power plant, that additional review would occur if the desalination facility took ownership of the intake and outfall, and that future operating scenarios of the power plant are speculative. This response is both non-responsive to our comment and mischaracterizes several reasonably foreseeable events as "speculative": • Regardingthe he upcoming expiration of the Energy Commission's approval: If the desalination facility were to be built during the next couple of years, it would operate for no more than about five years until the 2011 deadline. The EIR needs to describe how at least two likely scenarios—either expiration or renewal of the Energy Commission's approval—would affect operations of the desalination facility and its effects on marine biology. We note that the Energy Commission imposed this 10-year license condition in part due to support for the City's concerns about the effects of the cooling system's effects on marine biology(see Energy Commission Decision, Huntington Beach Generating Station Retool Project(00-AFC-13), May 2001, p. 8). The City should not now in this EIR ignore this 10- year condition and the concerns that resulted in that condition. Comment Letter on proposed EIR Certification —Poseidon Desalination Facility September 6, 2005 Page 6 of 7 • Regarding the NPDES review: Again, the EIR needs to describe likely scenarios arising from last year's changes to the regulations related to this type of intake system. Those regulations include a 'requirement that this type of intake system decrease entrainment effects by 60-90%. There is a limited range of options available to meet that requirement, including complete cessation of the use of seawater, and at the very least, the EIR needs to assess these reasonably foreseeable scenarios. • Regarding energy contracts: The DREIR does not describe the effects of the various short- and long-term energy contracts on operations of the two facilities. At the very least, these contracts illustrate the variable nature of the energy market and the resulting variations in power plant operations that would alter the effects of the proposed desalination facility. • Regarding the AES Master Development Plan: Our comments pointed out that the master plan submitted in November 2004 by AES to the Energy Commission makes no mention of a desalination facility on site. Clearly, adding such a facility at the site would affect future power plant development proposals and options. This issue took on even greater importance with the statement by the power plant operator at the City's August 22°a workshop that the desalination facility would be located at the most feasible site for dry cooling. Dry cooling is one of the preferred options to eliminate the impacts associated with the existing intake system; therefore, locating the desalination facility at this site would make it difficult, if not impossible, for the power plant to switch from using its harmful and outdated once-through cooling system to a dry cooling system. The Response does not address this issue at all. This is particularly surprising since the Energy Commission's condition requiring AES to submit this development plan was based on a direct request from the City to the Energy Commission (see Energy Commission Decision, Huntington Beach Generating Station Retool Project (00-AFC-13), May 2001, page 9). At the very least, the proposed desalination facility would represent an environmental opportunity lost due to use of this location,which must be evaluated as part of the EIR's cumulative impact analysis. This also represents the type of impact addressed in CEQA Sections 15126(b) & (c)—"significant environmental effects which cannot be avoided if the proposed project is implemented", and"significant irreversible environmental changes which would be involved in the proposed project should it be implemented". • Regarding conditions of the lease between Poseidon and AES: Many of the effects resulting from the issues identified above would be better known if the EIR described conditions of the lease between the power plant and the proposed desalination facility. The Response entirely dismisses our concerns about those lease conditions, yet without knowing those conditions, we cannot know the details of how the two facilities would operate, how the conditions could be modified, or other elements of the lease that would likely alter the environmental effects caused by one or both facilities. Ignoring the issues noted above results in the EIR being inadequate for both CEQA and Coastal Act review. It additionally results in the EIR not being consistent with the Findings and Recommendations (October 2003) of the State Desalination Task Force, a group formed to provide guidance on how such proposed facilities are best able to address California's needs and requirements for desalination. The Response states that it is incorporating the Findings and Comment Letter on proposed EIR Certification—Poseidon Desalination Facility September 6, 2005 Page 7 of 7 Recommendations of the Task Force into the EIR; however, there seems to be no basis for that statement, since it clearly leaves out one of the Task Force's key recommendations—that the effects of proposed co-located facilities such as this one be evaluated separately from those of the power plant.5 This recommendation is one of many agreed upon by the diverse membership of the Task Force, which included representatives from all the main agencies involved in regulating desalination facilities, and representatives from numerous groups interested in desalination issues. We note that the Task Force's representative from local government was a member of the Huntington Beach City Council. Closing: In conclusion, we again recommend the City not yet certify this EIR until our comments are properly incorporated into its analyses. Not only is the current EIR not adequate for purposes of CEQA or the Coastal Act, it provides inaccurate and inappropriate guidance for any subsequent coastal desalination proposals yet to go through the CEQA process. We therefore urge the City to not certify the EIR at this time, but to direct staff to revise it by fully incorporating our comments and the comments of other agencies and groups with expertise. Sincerely, Tom Luster Energy and Ocean Resources Unit s Task Force Recommendation#21: "For proposed desalination facilities co-locating with power plants,analyze the impacts of the desalination facility operations apart from the operations of the co-located facilities. This will identify the impacts of the desalination facility operations when there are reductions in cooling water quantities. This recommendation is not intended to dictate California Environmental Quality Act alternatives that must be evaluated." 'tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our, dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name:'—�aNr c�. v+` l i4 RECEIVED FR Ad4YYL5. _`` OAF PUBLIC� C oA FOR COUNCIL MEETING Address: 2q'7 � �l�.¢¢,.��...<<, yy/ 10.E�RK OFFICE "N L.FLYNN,CITY CLERK 'tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: jtred V. , Address: 0- Le- � � 'tizens for Clean Water affiliated with the LA1O Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California (213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main.Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: Tjn.v 7 i--.\ Address: Ca. A q \-7 1 Q3 'ti.zens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: (0 r"\ 0-C Address: ( o 'a►-•-� a r c C tea--- l 7(a 8 0 C ttizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council mernbers City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. s Name: Address: 'tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: Address:` '_o �.P,vtcr; / 62C #-l0 'tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California F_ (213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: Address: Z5 7,20 S dti pf �d Hord©t C' � C4 <?o ?l(7 'tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California (213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration.. —�P Name. 67 a � �� �� � T7)�S�-Z Address:3 D 'tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California (213) 483-4222 Ec� I Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: - Address: ,�� 'tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: re, R k CL t51 (� Address: 't'Ze"S for Clean Water affiliated with the LA/O Building & Construction Trades Council 1616 Beverly Blvd. C: Los Angeles, California E:: (213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: ► 4 CA /)U ne 7 Address: to 3 U E / y LJ 0 'tizens for Clean Water affiliated with the LAJO Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California ---F 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed.Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a.part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: (L- LpSP 3)nP12 Address: Phw-d- & c r�, Q-g�-=&Zp 0tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: `11�10SD% l;2Yy4v'1l-P Address: T' AVr- ;5 Tjxf)A LC C�-.g 9-?s sz 'tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 F--- -�- -- ,--I I Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: C—,, Address: � �— { .c ttizens for Clean Water affiliated with the LA/0 Building& Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: _ Address: �p 2 � A- fN A- C tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: fy)-ZA t Y-\&U-., Cr\,r L Q U-Q-� Address: t C_.® t y�O, C (+ o 0-A 'tize :Building or Clean Water ated with the LA/O & Construction Trades Council 1616 y Blvd. Los As, California E::: 213) 222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: Address: 0 'tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: Address: S. Gl,�r���'lSrf X)/Z . 'tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: C0A en Address: bo b ' Pn o- 0 C ttizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. 1 am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. �aa--P-�7 I �) 7 Name:nc- Address: AU �A ri VVI Cat 'tizens for Clean Water affiliated with the LA/O Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: :0 Address: iw f [' �� VQ ��- 'tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213)483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: UTAA P , V1 V� Address: �� .5A N Oc b&O �,A V131 'tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California (213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: -� J 1 1 f} S' ccv V, Address: D �j C .eW7 *C ttizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California (213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: a I!, n Ci Address:J C,+y)Cur it c *C ttizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California (213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: r Address: *c ttizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 E::: Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Address:{6��o�/� w- c/) /4 � � *C ttizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California (213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: )� / t Address: J/5-3 t' cj e -4-�- LOC)L� .C ttizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: -6' Address: i t , �C C 1 � 0 c ttizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California E:::: 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: i Address: _ �- -r--�-z 0 C ttizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. a y � Name: Address: jVigw j La-v 0 C ttizens for Clean Water affiliated with the LAJO Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: Address: 2 po AJ�A-S A 2. 'tizens for Clean Water affiliated with the LAJO Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California (213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: 2-4 Address: C 05 00o' 'tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: ' (�4 ( Inc► Address: -32?3 4"',0/03 0 C ttizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: • lC� Address: 9- !, A uti �� qo 7 q 0 C ttizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name:/ d / Address:Z2/2 ! Q �(/ 'tizen:ng r Clean Water ted with the LA/O & Construction Trades Council 1616 By Blvd. Los A , California 213) 222 E:::- Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. V --- Nam . I. j 66'-4 Address: ��� 0tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name:-f-(�' Address: I 'c ttizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California (213) 483-4222 E::: Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: /� �- E V � Address: tt *c ttizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California E::: 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: C,4--V Address: ft, PC 2� � `tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California (213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: ' Address: f r *c ttizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 E::: Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: / f 4?1 Address: c ize:Beverly or Clean Water ted with the LA/0ng & Construction Trades Council 1616 Blvd. LoS s, California 23222 E:::: Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: Address: q D-L ��% / A:L4 0- .r :(213) or Clean Water ated with the & Construction Trades Council y Blvd. s, California 222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: Address: 00 E::::(213) 483-4222 ens for Clean Water affiliated with the O Building & Construction Trades Council 6 Beverly Blvd. s Angeles, California Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: Address: CO.C-� L�-k= �J� l� �a 0 C ttizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Address:/Z''/ � ��� 'C ttizens for Clean Water affiliated with the LAJO Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: A—,rill Address: � z -0 2-Y 'tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name.. j"eliqW - Address: T115q O Ul .C ttizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. --7-TName: �S Address: 'tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California C213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: Address: .7�>'3 ' fr-L L t A 0 C ttizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4[:::::�222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: e�rM M"�Y aal<y S Address: 'tizens for Clean Water affiliated with the LA/O Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: �o— Nt Twme-, Address: ( =\ � Csw C � � r *c ttizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California (213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: Address: �-�- �� , C,(+ �'� *c ttizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: Address: 1 - , 02� 'tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: A �Address:��,?7 ` �-a->r.Sii.'�"� *c ttizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California E:::: 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: „ I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. 9 Name:--,& -^ 1 Address: ,33 Z ' A�y S�w 4 9 �' E::::(213) ns for Clean Water affiliated with the O Building & Construction Trades Council 6 Beverly Blvd. Angeles, California 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: r ✓i 7 J s° ✓/C /1 7 Address: 2.0 � �, • V11 'S I *C tti.zens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: / � C1�,�� - Address: 339 ',) � )VT� S—rp-- / I 'tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: l; Z4 dee- Address: C)-- C tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: ��J l �� (-1 e��. Address: C� L N rid 'tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California C213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: Address: *C ttizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: Address: 'tizens for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Los Angeles, California 213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity-to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. Name: ,1r Address: 0,`7 P 1 T 157- ,k/ 0izens.for Clean Water affiliated with the LA/0 Building & Construction Trades Council 1616 Beverly Blvd. Ct . Los Angeles, California (213) 483-4222 Mayor Jill Hardy and Council members City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 RE: Support for the Poseidon Resources Desalination Project Dear Mayor Hardy and Council members: I am a resident of Southern California and I am writing in support of the proposed Desalination Plant that will provide a new and secure WATER supply for the City of Huntington Beach and surrounding Communities. Southern California and individual Cities and Counties have been dependent on ever shrinking supplies of WATER from our region. The Colorado River or Northern California WATER Supplies have been overused and competition is increasing daily. The proposed Poseidon Resources Desalination Project is an opportunity to add to our WATER supplies before our dependance on natural supplies exhaust their ability to meet the needs of our citizens and businesses. I am asking that you fully review the environmental documents that are a part of the Environment Impact Report that is required for this project and for your support for the project when you vote on it. Thank you for your consideration. f-' Name: 'IYlrC,eL<,lko'(-6v dk Address: k2-7'� La \,fe Che hf!� '� , Page 1 of 1 Flynn, Joan From: Ramos, Ricky Sent: Friday, September 02, 2005 9:06 AM To: Broeren, Mary Beth; Alan Ashimine (E-mail); Kevin Thomas (E-mail); Josie McKinley(E-mail) Cc: Flynn, Joan Subject: FW: Poseidon Comment Letter -----Original Message----- From: Greg Herr [mailto:HERR@irwd.com] Sent: Friday, September 02, 2005 8:33 AM To: rramos@surfcity-hb.org Cc: Norris Brandt Subject: Poseidon Comment Letter Ricky, please see the attached comment letter. Hard copy is in regular mail to your attention. Thanks, Gregory K. Herr Planning and Resources Specialist Irvine Ranch Water District 3512 Michelson Dr. Irvine, CA 92612 (949) 453-5865 herr@irwd.com _ 9_8 J � 9/2/2005 ti ULMJ W14BS➢6fNCC SRi 111TE WCH %TER DBmR T 15600 Sand Canyon Ave.,P.O.Box 57000,Irvine,CA 92619-7000 (949)453-5300 September 1, 2005 Ricky Ramos Associate Planner City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 Subject: Responses to Comments for the Draft Recirculated Environmental Impact Report (DEIR) Seawater Desalination Project at Huntington Beach Dear Mr. Ramos: Irvine Ranch Water District(IRWD)has received and reviewed the subject document and ............................ ......offers the following comments. IRWD considers the response to our May 27,2005,comment letter(attached)to be inadequate. We note that the issues in our May 27 letter were consistent with those in our November 1,2002, comment letter(attached). The response essentially restates conclusions cited in the DREIR and acknowledges the regulatory limits and requirements, but does not address the overriding concerns raised by IRWD. IRWD still has serious reservations regarding accepting the desalinated ocean water from the proposed project into our potable water system. Those reservations center around water quality(primarily sodium,chloride,bromide, and boron levels),customer acceptance, corrosion and inadequate corrosion control measures. As stated in prior correspondence, IRWD has significant concerns regarding the compatibility of the proposed desalinated product water with IRWD potable and recycled water systems and uses. In particular,We are concerned that the use of the desalinated product water within our service area will lead to a degradation in the quality of our recycled water,which is primarily used for irrigation. While the desalinated product water may meet minimum state and federal standards for potable water use,its use could very well lead to recycled water that would not meet our customers' quality standards. Over the years, IRWD has devoted significant resources and funding to provide recycled water that meets or exceeds our customers' standards. We do not favor the use of potable water sources like the desalinated product water that would diminish our customers' confidence in the recycled water we provide. Customer satisfaction is among our highest goals. If our recycled water is rejected by our customers, IRWD would have no alternative but to in turn reject the desalinated product water. i Desalination Project at Huntington Beach DREIR Page 2 September 1, 2005 As a co-owner of the East Orange County Feeder No. 2 pipeline,we also have concerns regarding the long term corrosion impacts from the introduction of the desalinated product water into this major feeder. We believe other co-owners could have similar concerns. IRWD appreciates the opportunity to provide these additional comments, and requests that they be included into the proceedings of the hearing to be held on Tuesday, September 6, 2005 before the Huntington Beach City Council. Sincerely, 000 C� Norris Brandt,PE Environmental Quality Manager Attachments(2) cc: Mesa Consolidated Water District Metropolitan Water District of Southern California - - - - Moulton-Niguel Water District Municipal Water District of Orange County City of Newport Beach City of San Juan Capistrano Santa Margarita Water District 4[7tttb1 IY�b15[B1CP. ���T17 1Ui111�11� l uliUlO L1lJlll��� 156QO Sand C�nYon Ave.,PO Boic 5700d'lrnne CA 92619 70d0 (94.9}453-5300 May 27,2005 Ricky Ramos Associate Planner City of Huntington Beach 2000 Main Street Huntington Beach,CA 92648 Subject: Recirculated Draft Environmental Impact Report(DEIR) Seawater Desalination Project at Huntington Beach Dear Mr.Ramos: Irvine Ranch Water District(IRWD)has received and reviewed the subject DEIR and offers the comments that follow. IRWD is a multi-service agency located in central Orange County that provides potable and ronpotable(including recycled)water supply,wastewater collection,treatment,and disposal, and urban runoff treatment services to a population of approximately 316,000 covering an area of 132 square mites. The IRWD service area includes all of the City of Irvine and portions of unincorporated Orange County and the Cities of Lake Forest,Tustin, Santa Ana,Costa.Mesa, Orange,and Newport Beach(see attached map of the IRWD service area). IRWD has two primary sources of potable water:imported water supplied by the Metropolitan Water District of Southern California(MWD)and local groundwater. IRWD's primary sources , of nonpotable water are recycled water provided by the Michelson Water Reclamation Plant (MWRP)and the Los Alisos Water Reclamation Plant(LAWRP), and local and imported untreated water. The proposed Seawater Desalination Project(Project)would affect IRWD's potable and nonpotable water customers,as well as those customers in other cities and districts who will receive Project water. While IRWD supports development of additional water sources for southern California,maintenance of water quality and customer satisfaction are our highest priority. As proposed,elements of the Project have the potential to negatively impact both of these priorities. Introduction and Overview Pursuant to Exhibit 3-19 of the DEIR,IRWD is expected to be the largest user of Project water, which will be conveyed through the existing regional Orange County water distribution system primarily to customers in central and south Orange County. Consequently, IRWD is very concerned about the potential environmental impacts of this water on IRWD's facilities and Mr.Ricky Ramos City of Huntington Beach May 27,2005 Page 2 customers. As described more fully below,these impacts are focused on the potential effect of the quality and compatibility of Project water on IRWD's potable and nonpotable water systems and customers. Potable Water System Water Compatibility Issues The blending of Project water with existing supplies will alter water quality in both regional conveyance facilities(e.g.,East Orange County Feeder No.2—mixing of Project water and imported water) and in IRWD's local potable water distribution system(Project water,imported water,groundwater),and may cause problems related to disinfection and corrosion control. Disinfection Effective initial disinfection and maintenance of chlorine residuals in distribution systems is critical to ensure the safety of drinking water supplies from the standpoint of bacteriological/pathogen water quality. Maintenance of chlorine residuals is complicated by the proposal to introduce Project water into regional and local distribution systems. The EIR must - -- include development of a monitoring plan that includes specific methods to adjust and control the molar ratio of chlorine.to ammonia within a range acceptable to MWD,the Municipal Water District of Orange County(MWDOC),IRWD and other appropriate governmental entities. This will ensure that chlorine levels are maintained and that there will be no increased nitrification episodes or impacts on IRWD Total Coliform Rule compliance. In addition,the Project's proposed use of sodium hypochlorite for disinfection will add to sodium levels in the Project water(as described more fully below). The DEIR should evaluate the impact of sodium hypochlorite use on sodium levels and should also evaluate alternative disinfection methods that would reduce or eliminate the impact on sodium.levels. Disinfection By Products(DBP) The Project water will contribute an increased amount of bromide. Bromide is a DBP precursor, and its presence within IRWD's distribution system could result in the formation of additional amounts of brominated DBPs. Legislation is pending in the State of California mandating that the Office of Environmental Health and Hazard Assessment(OEHHA) establish Public Health Goals(PHGs) for each individual tri-halomethane(THM) and five halo-acetic acid(HAA5) DBPs by January 2007. OEHHA's position is that this action is on track to complete the THM PHGs by the January 2007 deadline and that establishing the HAA5 PHGs is achievable by the same date. A shift toward brominated DBPs could cause IRWD to exceed these new PHGs. The DEIR must address these impacts and provide appropriate mitigation measures. Mr. Ricky Ramos City of Huntington Beach May 27,2005 Page 3 Corrosion Control Based on the results of IlZWD's Lead and Copper Monitoring Program,IRWD is not currently required to implement corrosion control for the potable water system. Although the DEIR indicates that Project water will be moderately non-corrosive(target"corrosivity index"(SI)of 0.0 to 0.5),the substantially higher levels of proposed chloride may result in other corrosion problems. More specifically, a previous study by the American Water Works Association Research Foundation(AWWARF),in which IRWD participated,indicated that MWD water in IRWD's distribution system had the potential of causing"pitting"due to chloride levels. Although this potential was consider relatively low and did not warrant the use of corrosion inhibitors,the higher levels of chloride associated with the introduction of Project water will increase the corrosion potential and may require the use of costly phosphate based corrosion inhibitors by IRWD. The DEIR needs to analyze the specific impact of the proposed Project on corrosivity of iRWD's potable water system,including an analysis of corrosion control and operational methods as mitigation measures. Tests performed in other areas under different conditions would not provide adequate analysis of IRWD-specific conditions. In addition, if IRWD has to change operational methods due to these impacts and incur additional capital and O&M costs,the Project proponent must include mitigation measures as a part of the environmental impact report that clearly state IRWD will be reimbursed for these additional costs. Customer Acceptance and Confidence IRWD is committed to improving the appearance,taste and quality of potable water we serve to our customers. The proposed Project has the potential to negatively impact these factors,thereby altering customer perceptions about the quality of the water supply. These perceptions can negatively affect the community's view of IRWD and result in significant public relations issues. All new sources of potable water to-IRWD must be at least equal to or better than the quality of water we are currently serving our customers. IRWD is committed to maintaining consumer confidence. Degradation or perception of degradation by our customers of appearance,taste,and quality of water as a result of the Project is not acceptable. The DEIR does not adequately analyze the impacts of the proposed Project,and in particular,the Project's anticipated elevation of levels of sodium,chloride,bromide and boron on the taste, odor,safety and appearance of existing potable water supplies. Nor does it provide mitigation measures that address consumer concern and purveyor liability for product water quality. If future complaints received from customers by IRWD are determined to result from Project water,the Project proponent or owner must be responsible for corrective action. Mr. Ricky Ramos City of Huntington Beach May 27,2005 Page 4 Nonpotable Water Recycled Water Customer Concerns- Constraints on Water Reuse IRWD has an extensive recycled water program that provides water to meet nearly 20%-of the District's overall demands. IRWD aggressively promotes the use of recycled water and produces high quality water that meets our customers' water quality needs.We are concerned that the Project water will significantly increase the sodium and chloride levels in IRWD wastewater that provides the basis for the production of recycled water,and the potential adverse impacts these levels would have on water quality in our recycled water system. Approximately 90%of IRWD's recycled water is used for irrigation,and higher levels of sodium and chloride could result in plant toxicity and soil permeability issues with these customers. More specifically,higher levels of sodium in recycled water resulting from introductions of Project water into the IRWD potable water distribution system can cause issues with soil permeability,plant nutrient exchange, and plant damage(leaf burning)when this water is recycled. Permeability relates to the"sodium adsorption ratio"(SAR)of the water. The "Sodium Adsorption Ratio"section of a report prepared by McGuire Environmental in January - 2005 ("Water Recycling Using Desalinated Seawater in the Source Water Supply-Implications for the Irvine Ranch Water District Water Recycling Program") confirms that the higher sodium levels in Project water will increase SAR values in IRWD's recycled water(Figures 10 and 11). This is a concem since the predominately clay soils in the Irvine area are particularly sensitive to higher SAR's. Another result of increased SAR,which leads to lower soil permeability,is an increase of surface runoff from irrigation and rainfall. This increased runoff carries additional pollutants to receiving waters,in turn increasing pollution of surface waters and beaches. It is IRWD's goal to maintain or enhance the quality of all water it serves to its customers,not allow it to be degraded.We believe that the elevated levels of sodium,chloride and possibly boron in the Project water may reduce the quality of IRWD's recycled water.These impacts may result in decreased recycled water usage by our customers,putting a further burden upon potable water supplies. This is contrary to both IRWD's and the State of California's goals which call for recycled water to be maximized for all approved uses. Inasmuch as Orange County agencies have expended considerable time and money to develop extensive recycled water programs,the potential for Project water quality to impact regional water resources is significant. Reductions in recycled water use would necessitate the increased use of imported MWD water or development of additional local supplies at substantial cost. In addition, inorganic carbon(bicarbonate)levels in IRWD's drinking water are likely to change as a result of the Project, resulting in secondary impacts on the MWRP Biological Nitrogen Removal(BNR)process. More specifically, lower bicarbonate levels in IRWD wastewater will decrease pH and alkalinity, and require additional pH control measures to augment the BNR Mr.Ricky Ramos City of Huntington Beach May 27,2005 Page-5 process. The lower levels of bicarbonate will tend to lower the alkalinity prior to chlorination resulting in the need for additional chemical treatment to meet NPDES requirements at MWRP. To address the potential impacts described above, the DEIR must evaluate mitigation,including a monitoring component and an adjustment and control methodology,overseen by the appropriate water supply agency. Sodium and Chloride Reclamation Permit Limits The Regional Water Quality Control Board(RWQCB)recently adopted revised water quality objectives for mineral limits for the Irvine basin that replace the current sodium and chloride limits with an overall total dissolved solids(TDS)based limit. However, IRWD's current operating permit for MWRP includes specific sodium and chloride limits. This permit is expected to be renewed in 2006 and may include the revised basin mineral limits,however such inclusion is speculation. The permit renewal process will include a review of the appropriateness of applying the new water quality objectives to MWRP, and will involve public input. Consequently, IRWD has no assurance that its current permit sodium and chloride limits will be changed. If they are not changed, elevated sodium and chloride levels associated with the Project water would cause MWRP to exceed its permit limits, and necessitate that IRWD construct additional capital facilities to remove the sodium and chloride(reverse osmosis or ion exchange along with brine disposal facilities)and incur higher O&M costs. The DEIR must include a mitigation measure whereby the Project proponent or owner will reimburse IRWD for these additional costs.. Conclusion In conclusion, IRWD is very receptive to proposals to develop alternative water supplies, - including the proposed Project. However, conditions must be placed on the Project to required product water from the Project to undergo a treatment process that reduces the amount of sodium,chloride,bromide and boron. Conditions must also include appropriate increases in calcium,magnesium and alkalinity(buffering)to better match current IRWD potable water supplies thereby minimizing the impacts identified herein. In order to reduce risks associated with the Project,IRWD strongly recommends that the Project proponent add an additional level of treatment to the currently proposed treatment process. Diligent efforts by the City and Project proponent to address the concerns outlined in this letter will be greatly appreciated, and are in our view necessary for the completion of an adequate EIR. The Final EIR will require a Mitigation and Monitoring Plan for addressing potential impacts. It is expected that much of the monitoring will be conducted by public agencies,in addition to the Project proponent. Thus,multi-party operating agreements among the Project proponent,the j monitoring agencies, and retail agencies receiving the Project product water will need to be executed before any water is received by those retail agencies. It seems prudent to negotiate those agreements prior to any detailed planning or design of the Project. Mr. Ricky Ramos City of Huntington Beach May 27,2005 Page 6 Over the last several years,water quality requirements have become more stringent due to various technological,social, and environmental developments. It is likely that requirements will continue to change in the future. Thus,the Project and any attendant agreements must provide for adaptive management of those changes. IRWD is very willing to continue a dialogue with the Project proponent and City to discuss our concerns-about this Project.We understand the importance to our community of the success of appropriate ocean desalination and are supportive of using alternative water supplies to supplement our existing systems. However,IRWD has many concerns regarding the Project as outlined herein and requires satisfactory resolution before we can support the Project. If you have any questions regarding our comments or need additional information,please feel free to contact me at(949)453-5860. Sincerel sBr ,P Environmental Quality Manager Attachment—IRWD service area map cc: Richard.Bell,MWDOC - n i ifl41t�8ht�`,8 DMO IRTAT l I CK I F!_7 B DR1CT 15600 Send Canyon Ave.,P.O.Box 5700,Irvine,CA 92519-7000 (949)453-5300 November 1,2002 VIA FAX(original by mail) Mr.Ricky Ramos City Of Huntington Beach Planning Department 2000 Main Street _ Huntington Beach,CA 92648 Re: Draft Environmental Impact Report No.00-02 Proposed Poseidon Seawater Desalination Project Dear Mr.Ramos: i The Irvine Ranch Water District(IRWD)has reviewed the DEIR for the Poseidon Resources Seawater Desalination Project. IRWD is supportive of efforts to develop a cost-effective seawater desalination water supply to augment and bolster Orange County's water supply mix. However,IRWD will be significantly impacted by the proposed project and therefore is keenly interested in its development and offers the following comments. Our review of the subject DEIR has found it to be inadequate in several respects. Our comments pertain to the issues affecting public services and utilities. In particular,our comments fall into two main categories,project description/system reliability and water quality..Our comments follow. PROJECT DESCRIPTION AND SYSTEM RELIABILITY Overview. The DEIR notes.that the proposed project would deliver product water from the proposed seawater desalination plant into the East Orange County Feeder No.2 system in a reverse direction via a new connector pipeline and use of the existing OC-44 pipeline. A booster pumping station would also be constructed at the junction of Reach 4 of the EOCF#2,OC-44 and the Irvine Cross Feeder connection. We note that this location is.in a sensitive habitat area. Based upon our preliminary review and discussions with the MWDOC and MWD,the proposed project as now configured appears to be technically infeasible. Our comments on system reliability address technical issues. Our analysis suggests that an additional pipeline and new F point of interconnection will be necessary to accommodate project water in a reverse flow direction into the EOCF#2 Feeder. In addition,due to adverse water quality impacts that are } discussed below,the proposed treatment process appears to be inadequate. Additional treatment will be required if the product water supply is to be delivered into the EOCF#2 system from -which IRWD receives a significant quantity of imported water supply. i A-1 Mr.Ricky Ramos City of Huntington Beach November 4,2002 Page 2 Additional engineering work is necessary to properly develop the seawater desalination facility and conveyance system for integration into the imported water distribution system. As currently described in the project description,the project appears to be fatally flawed. Additional facilities will require further environmental review for impacts that have not been addressed in this DEIR. Hydraulic Design Constraints. Backfeeding the EOCF#2 system with anew booster pumping station will require a higher hydraulic gradient at the lower end of Reach 4 of the EOCF#2. It is our understanding that this pipeline was designed with a falling head HGL. The DEIR needs to address the structural integrity of the pipeline under the proposed reverse flow,higher pressure operation. We estimate that a discharge HGL of 558 feet would be required to move 50 mgd(78 efs).to the Coastal Junction PCS in order to meet the design HGL of 528 at that location. This will require analysis and verification by MWD. The higher head system will likely exceed the pipeline design for normal operation and surge pressure design allowance. If this is the case, the current configuration is unacceptable. To remedy this,an additional connecting pipeline may be required tie into the CM-10 turnout located just upstream of the Coastal Junction Pressure .._......__...Control Facility. Hydraulic surge control is inadequately addressed in the DEIR. This is a significant area of concern and it requires full analysis in the DEIR,with any hydraulic control structures and system control facilities described and assessed. Surge Control Constraints. With the conversion of the San Joaquin Reservoir to reclaimed water storage by IRWD,the reservoir is no longer hydraulically connected to the EOCF#2 pipeline. At this time,MWD is working with IRWD to develop a surge relief facility that would use an air gap for surge releases into the reservoir. The planned set point forthe relief system is 485 feet. The proposed booster pumping station to backfeed reach 4 of the EOCF#2 would result in pumping water into the reservoir. Consequently,under the planned surge control system,the as proposed integration of the desalinated supply into the EOCF#2 is unworkable. Operational Reliability. Operational reliability is an issue,should a power or other emergency shutdown of the desalination system and booster pumping stations occur. It is our understanding that the operation of the Santiago Creek and Coastal Junction Pressure Control Stations have limited automatic remote control flow capacity operation capability. The control valves apparently require manual adjustment for large changes in flow. The project flow rate of 78 cfs likely exceeds the remote operation capability. The DEIR should describe what additional modifications would be required in these facilities to accommodate a rapid shutdown from the desalination project and with the environmental impacts accordingly addressed for any necessary improvements. Since the proposed desalination project is located near the Newport Fault on generally poor soils, the risk of outages due to a rupture on this segment of the fault and mitigation measures needs to be more fully described in the DEIR. This introduces an additional level of risk to the regional A-2 Mr.Ricky Ramos City of Huntington Beach November 4,2002 Page 3 system reliability and this risk should be compared to the current level of risk in the existing system. WATER QUALPI'Y Sodium and Chloride Constraints on Water Reuse. Table 4-6-1 in the DEIR lists the expected concentration of several constituents in the product water quality. Product water quality shown appears to be the permeate quality,based on the low calcium and magnesium concentrations that are shown. Consequently,this table does not show the finished water quality post lime stabilization and caustic soda pH adjustment. The finish water quality needs to be shown for all constituents. Table 4.6-1 shows the product TDS to be 350 mg/l,sodium to be 150 mg/l and chloride to be 190 mg/l. The current sodium and chloride levels received by IRWD from MWD sources are in the 65-85 mg/l range. IRWD operates a major dual reclamation system. The reclamation system user profile and NPDES permit Iimits recycled water supply sodium to 125 mg/l and chloride to .150 mg/l. The DEIR does not describe the quantity or seasonal variation of desalinated seawater supply deliveries to each of the affected agencies over the course of a year. MWDOC has provided information that indicates IRWD will receive on average about one-half the proposed project flows. Consequently,IRWD will be significantly impacted by the proposed project. At these,flow rates,the proposed desalinated Water supply will cause sodium and chloride levels in IRWD's recycled supply to substantially violate our NPDES permit for both constituents. This would be an unacceptable condition. The proposed treatment process for the desalination project will need to be adjusted to match sodium and chloride levels to those levels currently received from MWD if this water is to be introduced into the EOCF#2 system at points of connection where IRWD receives MWD imported water. Customer Acceptance. We anticipate consumer taste complaints due to the significantly higher proposed sodium and chloride concentrations in the finished water. Furthermore,commercial and light industrial customers who would_ be impacted by the change in water quality will need to be identified in the DEIR,including any pre-treatment issues. The EIR needs to more fully address public acceptance for use of desalinated water within the affected public water supply agencies. Consumer surveys,focus group process,and other methods should be utilized to ascertain public acceptance. Reliance on assumed acceptance is inadequate. Membrane Performance. The DEIR notes that the TD5 to be produced from the proposed single pass RO system would be 350 mg/l. As membranes age,salt passage may increase as much as I0%annually. The cause and control of this potential deterioration rate should be described in the DEIR and.potential changes in permeate quality described. The type of membrane should be identified with a manufacturer's analysis in an appendix in order to justify the predicted permeate water quality. A-3 Mr.Ricky Ramos City of Huntington Beach November 4,2002 Page 4 Water Stabilization and Corrosion ConfroL A more in-depth discussion of potential corrosion, corrosion control and water stabilization chemistry issues on the each of the receiving water supply agencies needs to be addressed in the DEIR. The current discussion-lacks sufficient technical foundation.. IRWD needs to be consulted to review the stabilization formulation in order to be satisfied that lead and copper rule requirements will be met. Trace Contaminants. The DEIR discusses"Red Tides"and neurotoxins that originate from plankton blooms. The DEIR cites one reference as the authority on stating that the RO system will safely remove any neurotoxins in the source water. The DEIR needs to more fully discuss the issue,identify the types of neurotoxins and frequency of occurrence in coastal waters, address concentrations found in the water column during severe blooms,and provide more substantial documentation of their removal by the proposed treatment process. A second unit treatment process to destroy any trace neurotoxins or other problematic trace organic that may pass through membranes may need to be considered to provide adequate water quality .assurances. Finished Water Quality Monitoring. Since a private entity will be operating the project,the water quality control system and water_quality monitoring and control program need to be described. This control system needs to be fully protective of public water suppliers. The null zone,the point in the pipeline where imported water and desalinated water meet,will move throughout the pipeline with varying demand conditions. This may cause significant fluctuations in water quality over short periods at affected points. This impact needs to be addressed. SUMMARY r We appreciate the opportunity to provide comments on the DEIR for the Poseidon Resources Seawater Desalination Project. As stated above,it is our considered opinion that the proposed ` project is deficient in two major respects:(1)the proposed method of integration into the regional imported water distribution system is infeasible and(2)the.finished water quality is unacceptable since it will cause violation of water recycling permits. Additional work needs to be developed and completed on the proposed project to be deemed feasible, t IRWD is one of several participants who own capacity in the EOCF#2 system and approvals from each of the participants is required before any modifications to the system and its use can be made. i We note that IRWD was not on the original distribution for the DEIR. We would appreciate IRWD being added to your mailing list for all future notices of meetings and distribution of reports regarding the subject project. Other affected agencies may have also been excluded from the original distribution and thereby either not afforded an opportunity to comment on the DEIR or provided inadequate time for review and comment. Affected water supply,agencies are those who receive water supply from the Metropolitan Water District of Southern California (MWD)and Municipal Water District of Orange County(MWDOC),through the Orange s County Feeder and East Orange County Feeder No.2 Feeder pipelines. i E I A-4 Mr.Ricky Ramos City of Huntington Beach November 4,2002 Page 5 We are requesting that the current version of the proj ect description and the DEIR,which we consider to be inadequate,be substantially modified so as to present a fully developed and technically feasible project. We request that the City of Huntington Beach not certify the DEIR in its current form and require Poseidon Resources to further develop the project,conduct and provide sufficient technical analyses supporting key aspects of the project impacts as described above,revise the DEIR accordingly,and re-circulate for comments. If you should have any questions or need additional information,please contact the undersigned at(949)453-5582 or via e-mail at bellna,irwd.com. Very truly yours, Richard B.Bell,P.E. District Manager for Planning and Resources cc; K. Seckel,MWDOC F:/grWwrd/eng/rbb/poseidon.doc i ' t 1 1 I A-5 CITY CL.EIK � CITY OF 17422 Lido Lane HUNTINGTON BEACH, CA Huntington Beach, CA Sg2-6,47 1005 SEP - I A l i 3 3. August 31, 2005 _ Mayor and City Council Members Huntington Beach, CA 92648 Honorable Mayor and Council Members, I wish to voice my support.of the construction of the Poseido-n Water Treatment Facility in Huntington Beach, knowing very well the need for a clean and more dependable water source for our area. Desalination using the reverse osmosis technique is environmentally sound, and reusing the effluent water from the power plant will reduce the temperature of the water returned to the ocean thereby benefiting, not harming, the marine environment as well. The design and landscaping planned will certainly improve that industrial area and our special oceanfront, and the new water storage units will be a major asset to our community in an emergency. Since 1968 I have enjoyed living in Huntington Beach, and volunteering in community environmental affairs. As one of many quiet but dedicated environmentalists in the area, I urge you to approve the EIR and support the construction of this water treatment facility in Huntington Beach. Sincerely, Margaret Carlberg `- g � Page 1 of 1 Roberts, Robin From: Chris St. Hilaire [csthilaire@impactjuries.com] Sent: Thursday, September 01, 2005 1:50 PM To: rroberts@surfcity-hb.org; djones@surfcity-hb.org It is very frustrating to hear that a few residents are once again opposed to a business going into the city. This is certainly the case with Poseidon Resources who deserves a chance to build their project. Once in a while, I would like the city to consider the tax benefits and other needs of the city rather than a few angry residents. John Trommald Resident c cn m _ V > :�Dc n N W o r. ,L4 /1 Ce+1 (!A) 9/1/2005 ift_L;L'I VLb CITY CLERK C11-Y OF HtlV INGTON BEACH, CA 2005 SEP -2 P 4: 18 A respected expert on bottle-Nose dolphins, Dennis Kelly, says the following on the proposed Huntington Beach Water Treatment Facility: "I guess one question is whether it's wise to enshrine the power plant, not only from aesthetics, but from the perspective of water quality," he said. Dennis Kelly, an Orange Coast College professor of marine science who has read the environmental report, said the desalination plantwould not have serious direct effects on the ocean. «I don't see any consequences that are going to be detrimental to the marine environment," said Kelly, adding that the plant will "meet a need for water that is becoming increasingly tenuous." An excerpt from the following article: THE 50-MILLION-GALLON QUESTION By JEFF OVERLEY THE HUNTINGTON BEACH WAVE—September 1, 2005 f 4,.,r X0 s-- 2 cII- �d,tiJ C/Aj SEP-04-2005 04 :55 PM EOB. POLKOW 714 962 4810 P. 01 RLC.I`IVLD CITY CLERK CITY OF HUNTINGTON BEACH, CA Agenda Item No. D4.a&b Poseidon, 6 September 2005 (in fayogEqf-tie desal 0 2 plant) TO: City Council My name is Bob Polkow, I have an office in Huntington Beach but aside from paying for a business license I think the more pertinent fact that I have the privilege to address you is because I am a bona-fide southeast Huntington Beach resident, a long time taxpaying homeowner and therefore one of your constituents. Not an out of town rabble rouser that you must contend with that has no voting privilege in our great city but insists on telling you and me what we are doing wrong or what we should do. I continually hear the phrase that "we must protect our resources for the future generations" but just recently a letter was published in the Register written by one of these science wannabes that state "we do not need a desal plant as our acquifers have enough water to last through 2030". What about the period after 2030? Let us put a stop to this double talk. Stop the continual; filibusters by these CAVES and N1MBYs and give Poseidon the chance to further a technique that inevitably will be the Norm not only in our state but in the entire world. Let us not make the same mistake Tampa did and insist on transfer of control before Poseidon has completely finished the project. Poseidon, not Tampa, has borne the blame for problems of the Tampa Bay project and should not be interfered with again, or be continually blamed for the Tampa Bay problems. I was assigned to a project on. Johnston Island. A small pencil point speck of corral in the South. Pacific and was required to spend some time there more than once. Our only source of potable water was a small decal plant operated by a contractor. We drank it, showered in it and our food was cooked with it. The water could be competitively compared to distilled water. Countries in the and Eastern and Middle Eastern countries are successfully operating desal plants today. The Sanitation district is spending millions of our tax dollars purifying sewer water and injecting it into the ground to pose a barrier to salt water intrusion. Despite this costly effort other agencies are dredging channels through our beaches to allow salt water to move further inland, Let us stop this ridiculous madness. Poseidon Resources want to produce potable water not with our tax money but their own, The initial users will, of course, pay more for the water until �f / SEP-04-2005 04 :55 PM BOE. POLKOW 714 962 4810 P. 02 the capital investments and engineering costs are amortized. This is how capitalism works. If Huntington Beach is not the initial customer so be it. If we are indeed concerned with the well being of Future generations there is now one way to show it, approve agenda item, D 4a and b and let us be part of the future. Huntington Beach should not be continually compared to a pimple on the backside of progress. I believe I can safely say I speak for the silent majority, eo:e a-nview Lane, Huntington Beach, Ca 92646-8215 (714)862-4810 LI C17 Y OF September 1, 2005 HUB T INGTON BEACH, CA City Council 2005 SEP -2 P 1: 3 0 City of Huntington Beacb P.O. Box 190 Huntington Beach, CA 92648 RE: Poseidon To the Honorable Members of the City Council: In regards to the seawater desalinization plant, I am troubled and concerned. Currently, we are seeing the aftermath of Hurricane Katrina. Since this is `earthquake country', the pumping of millions of gallons of water and debris into an area with homes and schools nearby could be the making of a disaster. Question: is the city ready to handle the spillage and flooding and debris if such an event happens?Also, the OCSD has a sewer project that has many delays and problems. This project is near the proposed site for Poseidon; this needs to be factored into the equation of hazardous materials. I am concerned that the EIR is flawed. Do you really want to go on record as accepting this? Is this the standard of reporting that is acceptable? Has 'the bar' fallen? Are each of the members of the City Council doing a satisfactory job representing the interest of the residents of Huntington Beach? How you vote will be remembered. If this project is such a blessing, then be willing to accept the responsibility and liability for problems and possible disaster. What about setting up an `escrow account'for claims, etc. related to the Poseidon plant? Are those members of the City Council in favor of the plant also willing to be held personally responsible and liable for any injuries to people, especially children? Yours Ann Tweedy 9761 Melinda Circle Huntington Beach, CA 92646 Page 1 of 1 Pt CITY CLERK Albers, Patricia CITY OF HUNTINGTON BEAU, From: Fabian, Jill @ Anaheim [Jill.Fabian@cbre.com] 1005 SEP -b A 10: 3 I Sent: Tuesday, September 06, 2005 10:24 AM To: palbers@surfcity-hb.org Subject: city council meeting tonight I am a resident of Huntington Beach for 35 years and I am totally against the Seawater Sealination Project (Poseidon). There are a number of reasons but my main reason is that this company does not care about our city and I feel very strongly that they will probably sell to Foreign investors when the project is complete and they can see a good profit. My house is located right off Newland and I already suffer from allergies due to the cleaning of the Ascon Dump and I feel it is totally unfair to subject the residents of Southeast HB to more pollutants in the air. We have the Ascon Dump, Edison Company, the Sewer Plant and we have had our streets torn up for the last four years. If this would benefit the residents of HB, I might feel differently, this is not our responsibility. As a city we are known to be slow in issuing permits and allowing building (look at the project at 5th & PCH) but you seem to be really pushing this plant. I am not sure if I can attend the meeting this evening so I wanted to voice my opinion and I speak for all my neighbors, I sincerely hope that you will take this into consideration because a lot of the people in the city are not stepping up to the line to voice their objections but all the people I have talked to are against this project. We are currently suffering from bad press based on what some of the city council did in the past and hopefully this is not the case now because this project seems to be moving too fast. If this should come up for a vote this evening, I hope you will all vote against these permits. If you have any questions, please call me. Jillian Fabian 21292 Sand Dollar Lane Huntington Beach, CA (714) 536-0423 �C (dAOO�sl 7701J 9/6/2005 September 6, 2005 To: City Council Members # ,` Subject: Desalination Plant From: Mike Grumet C I I Y C L E R•s i`, CITY OF HUNTINGTON BEACH, CA. I am so tired of ridiculous arguments against the desalination plant. If one wants to see the environmental impact of "water shortages"just look at Mono Lake! Oh, I am sorry, we cajajskthat 6roi I V_ $alit must not be important. We are only concerned with OUR local environment! The argument that having an abundant supply of water is going to attract urban growth is flat out bombastic. Let me tell you how I really feel. Oops! I just did! I spoke with a couple from Boston two weeks ago. They thought about moving their careers to H.B. They mentioned great weather, a variety of cultural and sports activities, a tremendous economy, and an overall quality of life. Let's take a poll from all those considering to move to OC or HB and see if"ABUNDANT WATER SUPPLY appears in the top 1000 list of reasons to move here. I guess we have to stop all good weather days, end all sporting and cultural events and just destroy the quality of life in-order to save the micro-organisms in the ocean! Has anyone noticed that the water around the pier and in HB is brown? It isn't blue! The run-off from the Santa Ana River and maybe in the San Gabriel River seems to assist us in our attractive"Blue Hue"that brings visitors to HB. As long as our ocean water is free of illness causing bacteria,I don't think the study of micro-organisms is the big draw to HB for most tourists. Fixing our infrastructure and focusing on stopping untreated runoff from inland cities is our greatest environmental challenge to our ocean water. Let's stop the short sited,not in my back yard mock-environmentalists from destroying our capacity to adapt to the needs of the community. The last I heard,the population in OC and HB are still going to grow. Water is absolutely essential to ALL of our . communities here. Countries go to war over water resources because it is key to SURVIVAL. Our environmental do-gooders need to put money and effort into conservation education not WATER ELIMINATION! Over analysis and abusive use of the court systems already put California in a tail spin over electricity. Have we not learned anything yet? The sign of madness is when you keep doing the same thing, get the same results and somehow expect a different outcome. Stopping the construction of power plants didn't end the birth rate or stop people from the frozen tundra of the northeast from moving to California. Stop using scare tactics, abusive law suits and stalling techniques. Remember the big picture... water is key to survival. Has anyone considered how the ground water is impacted when you over-draw from our well water? The influx of salt water into our underground system is a reality if we overuse that resource. If you look at the survival of any species since the beginning of time,being able to adapt to change is key. Let's diversify our water resources so we are better to adapt to: loss of resources like the Colorado River, drought, potential terrorist attacks on our water system and natural disasters destroying our water delivery systems. Anyone been to New Orleans yet?You don't need to spend 20 years and millions of dollars on research to know,we need to diversify our water resources now! While I think a concern over efficiency in Tampa is valid, I have faith in.technology and the company's ability to overcome. Ultimately, the need for diversified water resources out-ways the minor ways the ocean water may be affected. Thank you for putting up with my sarcasm. Cj 9- d3S ,fQOl bQ 'flQtl3fl f'�Q1Q�'I.E�'lli� Sincerely, 40 1 Mike Grumet Cis %-A,' ) Page 1 of 1 Flynn, Joan From: THEHBLIFEGUY@aol.com Sent: Tuesday, September 06, 2005 10:10 AM To: bowens@poseidon 1.com Cc: jflynn@surfcity-hb.org; dbazante@surfcity-hb.org; citycouncil@surfcity-hb.org Subject: RE: Desalination Plant Opinion Dear Council and Poseidon, I have never expressed an opionion political in public. This issue touches me greatly because I raise money to expeand water resources in the middle-east. Water and Peace are inseperable there. Water and Quality of Life and Survival are critical here. o � o � O�-%_,: Wv�-.M. M F7 �0 m N C7 - y (IAJ 9/6/2005 0945/2005 22:36 7146397212 VAN. BLARCOM PAGE 01/02 VAN BLARCOM FAX COVER SHEET LEIBOLD 6 'ZOOS MCCLENDON Cit of Huntington Beath MANN shyAttorneyzs39 P2Mt��Cxr�KDKIv�,5UITE 105 LAOUNAH.ILL CAT, 'JgJA 92653 A PROFESSIONAL CORPORATION TEL 714.639.6700 FAX 714.639,7212 Date: September 6;2005 THE FOLLOWING DOCUMENT INCLUDING THIS COVER SHEET IS 3 PAGES. ,PLEASE DELIVER TO: A T FA.X N0. City A.ttorney 374-1590 FROM. Ronald A. Van Blarco,nz RE: Agenda Item D-4a / Seawater Desalination Project REIR MESSAGE: Please see attached.. If any of these pages are not legible, or you do not receive all of the pages, please call(714) 639-6700 CONFIDENTTAL.IT.Y)lVOTICE THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR FjNTTTY TO WHICH IT IS ADDRESSED,AND MAY CONTAN INFORMATION THAT IS PRIVILEGED,CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW, IF TT.TT; READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT,YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINA'riON,DISTRI6TITION ORCOPYING,OF THIS COMMI INTCATTON TS STRTCTT,Y PROHTRTTFT). TF Yni T HAVF RFC'FIVPID TFTTS t.OMMT NICATTQN iN L•;RRnR.; PLEASE NOTIFY US IMMEDIATELY BY TEI,T;PT-ION.E,.ANT).RETURN THE ORIGINAL MESSAGE TO U§_A.T-_-T.HL, ABOVE ADDRESS VIA THE UNITED STATES POSTAL SERVICE. a THANK YOU. W C:) ds September 6, 2005 Honorable Mayor Members of the City Council City of Huntington Beach, Cali.fonfia. Re: Certification of Recirculated Environmental Impact Report No. 00-02 (Seawater Desalination Project at I-Yuntington Beach); Agenda Item D-4a for the September b, 2005 Council Aketing Dear Mayor and Coun.cilm.em.bers_ Our firm represents Poseidon Resources Corporation with respect to the preparation and processing of Recirculated Envirorunental Impact Report No. 00-02 (Seawater Desalination Project at Huntington Beach)by the City of I Zurifinl ton Beach. in,tbi.s letter,we respectfully request on.behalf.of Poseidon,that the City Council certify the REIR. We maintain that the RE,IR should be certified by the City Council because the REIR has disclosed to the concerned citizens and decision-makers in Huntington Beach—and it has extensively discussed all of the environmental consequences of approving Conditional Use Permit No. 02-04 and Coastal Development Permit No. 02-05, and it has done so in strict accordance with. the .requirements of the California environmental Quality Act, the CEQA Guidelines and controlling case law. As was the case durnxtg the Ci:ty's consideration. of the original. FIR, oppo�aerrts of the Seawater Desalination Project have argued that the REIR has not provided a legal analysis of environmental impacts_ The question of what constitutes a legal analysis of environmental impacts in an environmental impact report is not new. The answer is provided to this City Council.and to other lead agencies by the CEQA statute(Public Resources Code sections 21000 et seq.),the CEQA Guidelines(California Code of .Regulations, Title 14. sections 15000 et seq.), and, perhaps most ft-nportantl.y, by the.cases decided by California Courts. The key is to understand that the purpose of an environmental impact report is to disclose and discuss the potential environmental impacts of a project. One court used a common analogy in answering the question of what constitutes a legal analysis: an environmental impact report"must contain.sufficient detail to help insure the integrity of the process of dccisionmaking by Precluding 3tubbom problems or serious criticism from being swept under the rug." (Kings County Farm Bureau v. City of Hanford(1990) 221 Cal.App.3d 692, 733.) As the Council has a 09/P/2005 22:36 7146397212 VAN BLARCOM PAGE 02/02 Poseidon Position Statement on REIR September 6, 2005 Page 2 witnessed,no criticism has been ignored, unheard or discounted, let alone "swept under the rug" during the exhaustive analysis of this project's potential environmental impacts. "Stubborn problems" and. "serious criticisms" have been. openly discussed and publicly dissected repeatedly, in meeting alter meeting. As everyone is well aware, criticism of the original ETR led to the additional analysis and info.nnation that has been included i:n the REIR: No potential impact analysis has been. ignored. Accordingly, we encourage the Council to bring the City's three year procosq of environmental impact disclosure and discussion. (that began with the release of the original Draft EIR in September 2002)to a close with the hearing on the REIR tonight. We suspect that there may be last minute commentary offered at your meeting tonight. Some may call for more time and further studies. But it is clear under CEQA tb.at the City does not need.to"conduct every test and perform all research,study, and experimentation recommended to it"by interested parties. (Society for California Archaeology v. County of Butte (1977) 65 Cal.App.3d 832, 838.) The key is whether the potential environmental impacts of the project have been disclosed and discussed in the REIR. The California Supreme Court has explained that in deciding whether a legal analysis has been providcd by an EIR, the test is not "whethcr the stu.d.ics are irrefutable i►r wlicilirr t uy could .have been better_" Obviously, experts may disagree on some points. (Berkeley Keep Nets Over the Bay Committee v. BoardqfPorf Commissioners(2001)91 Cal.App.4th 1344, 1.356,quoting Laurell'-leighiv4,47 Cal.3d.at 409.) The test is whether tb.e potential environmental impacts of the project have been disclosed and discussed in the REIR. We submit that all of the potentially significant environmental effects that may result from approval of the CUP and CDP have been disclosed and discussed in the REIR and., where applicable, mitigation measures to reduce such effects to a level of bisi.gni.f cance have been identified. The REIR therefore meets all of the legal requiremmits imposed under CEQA. Please recognize that your. City staff, the City's experts, the Poseidon team of scientist and consultants, and the interested citizenry have all invested significant time in examining the potential environmental impacts of this important project. Finally, please do not hesitate to call on me if I can assist in.your understanding of the evidence or the application of.CEQA your determinations. Very truly yours, Van Blarcom, Leibold, McClend. & Mann By: Ronald A. Van Blarcoin cc: B. Owens t_ P O S E I D O N R E S O U i�rERL.i�,G� E S CITY CLE;pit CITY OF HUNTINGTON BEACH, CA 1005 SEP -b p I: i L4 Via E-mail September 6, 2005 Honorable Mayor and City Council City of Huntington Beach 2000 Main St. P.O. Box 190 Huntington Beach, CA 92648 RE: Applicant Request for Time to Present:. Seawater Desalination Project — Huntington Beach September 6th Public Hearing Dear Mrs. Hardy: Poseidon Resources is requesting twenty (20) minutes at the September 6th Public Hearing on the seawater desalination project to present its view on the proposal for the city. Our presentation would be for the record of the hearing. Poseidon would follow the city staff presentation on the project and before the receipt of public comments. In addition to the normal Applicant presentation on the proposed project, Poseidon will present information on the proposed water delivery pipeline. The desalination delivery pipeline has recently surfaced as a public concern and it will be important for Poseidon to describe how its pipeline will differ from the OCSD pipeline and can be constructed without the same community impacts. Your agreement to this time will be greatly appreciated. Respectfully, Billy Owen Sr.Vice Presi nt CC: Penny Culbreth-Graft Scott Hess Paul Emery Mary Beth Broeren Poseidon Resources Corporation 3760 Kilroy Airport Way,Suite 260,Long Beach,CA 90806,USA 562-490-2003 Fax:562-490-2403 Executive Office:1055 Washington Boulevard,Stamford,CT 06901 v,-,, G epi�S VAN BLARCOM RONALD A.VAN BLARCOM LEIBOLD Direct Phone: 714-639-6700 Direct Fax: 714-639-7212 MCCLENDON ron@CEQA.com 23422 MILL CREEK DRIVE, SUITE 105 . LAGUNA HILLS, CALIFORNIA 92653 MANN TEL 949.457.6300 • FAx 949.457.6305 A PROFESSIONAL CORPORATION September 6, 2005 Honorable Mayor Members of the City Council City of Huntington Beach, California Re: Certification of Recirculated Environmental Impact Report No. 00-02 (Seawater Desalination Project at Huntington Beach); Agenda Item D-4a for the September 6, 2005 Council Meeting Dear Mayor and Councilmembers: Our firm represents Poseidon Resources Corporation with respect to the preparation and processing of Recirculated Environmental Impact Report No. 00-02 (Seawater Desalination Project at Huntington Beach)by the City of Huntington Beach. In this letter,we respectfully request on behalf of Poseidon that the City Council certify the REIR. We maintain that the REIR should be certified by the City Council because the REIR has disclosed to the concerned citizens and decision-makers in Huntington Beach—and it has extensively discussed— all of the environmental consequences of approving Conditional Use Permit No. 02-04 and Coastal Development Permit No. 02-05, and it has done so in strict accordance with the requirements of the California Environmental Quality Act, the CEQA Guidelines and controlling case law. As was the case during the City's consideration of the original EIR, opponents of the Seawater Desalination Project have argued that the REIR has not provided a legal analysis of environmental impacts. The question of what constitutes a legal analysis of environmental impacts in an environmental impact report is not new. The answer is provided to this City Council and to other lead agencies by the CEQA statute(Public Resources Code sections 21000 et seq.),the CEQA Guidelines(California Code of Regulations, Title 14, sections 15000 et seq.), and, perhaps most importantly, by the cases decided by California Courts. The key is to understand that the purpose of an environmental impact report is to disclose and discuss the potential environmental impacts of a project. One court used a common analogy in answering the question of what constitutes a legal analysis: an environmental impact report"must contain sufficient detail to help insure the integrity of the process of decisionmaking by precluding stubborn problems or serious criticism from being swept under the rug." (Kings County Farm Bureau v. City of Hanford(1990) 221 Cal.App.3d 692, 733.) As the Council has Poseidon Position Statement on REIR September 6, 2005 Page 2 witnessed, no criticism has been ignored, unheard or discounted, let alone "swept under the rug" during the exhaustive analysis of this project's potential environmental impacts. "Stubborn problems" and "serious criticisms" have been openly discussed and publicly dissected repeatedly, in meeting after meeting. As everyone is well aware, criticism of the original EIR led to the additional analysis and information that has been included in the REIR. No potential impact analysis has been ignored. Accordingly, we encourage the Council to bring the City's three-year process of environmental impact disclosure and discussion (that began with the release of the original Draft EIR in September 2002)to a close with the hearing on the REIR tonight. We suspect that there may be last minute commentary offered at your meeting tonight. Some may call for more time and further studies. But it is clear under CEQA that the City does not need to"conduct every test and perform all research, study,and experimentation recommended to it"by interested parties. (Society for California Archaeology v. County of Butte (1977) 65 Cal.App.3d 832, 838.) The key is whether the potential environmental impacts of the project have been disclosed and discussed in the REIR. The California Supreme Court has explained that in deciding whether a legal analysis has been provided by an EIR, the test is not "whether the studies are irrefutable or whether they could have been better." Obviously,experts may disagree on some points. (Berkeley Keep Jets Over the Bay Committee v. Board of Port Commissioners(2001)91 Cal.App.4th 1344, 1356,quoting Laurel Heights I,47 Cal.3d at 409.) The test is whether the potential environmental impacts of the project have been disclosed and discussed in the REIR. We submit that all of the potentially significant environmental effects that may result from approval of the CUP and CDP have been disclosed and discussed in the REIR and, where applicable, mitigation measures to reduce such effects to a level of insignificance have been identified. The REIR therefore meets all of the legal requirements imposed under CEQA. Please recognize that your City staff, the City's experts, the Poseidon team of scientist and consultants, and the interested citizenry have all invested significant time in examining the potential environmental impacts of this important project. Finally, please do not hesitate to call on me if I can assist in your understanding of the evidence or the application of CEQA your determinations. Very truly yours, Van Blarcom, Leibold, McClend & Mann C. By: Ronald A. Van Blarcom cc: B. Owens SEP-06-2005 14:55 P.01 a F t',HCITY�~OFRK ' a € i)?� I INGTON BEACH, CA 2005 SEP -h P 3: 52 City of Costa Mesa 77 Fair Drive Costa Mesa,CA 92628-1200 Fax: (714)754-5330 FACSIMILE MESSAGE A I Date: Time: 0�1 pages: /p (Includes Cover sheet) To- Attention, Fax Number: From: Subject: +� Comments: Y, ,x QkC1 Z) If you don't receive all pages c 2131-111 %10� C..i" 1 7;5- k;xj" Oe,fr1C>J 0-,-q- 1,4q-6 •, SEP-06-2005 14:55 P.02 CITY OF COSTA MESA °A P.O.BOX 1200,CALIFORNIA 92620.1200 FROM THE OFFICE of THE CITY MANAGER September 6, 2005 City Clerk City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 SUBJECT: ENVIRONMENTAL IMPACT REPORT 00-02; SEAWATER DESALINIZATION PROJECT IN HUNTINGTON BEACH Dear City Clerk- With the Huntington Beach City Council scheduled to consider action on the above, subject environmental impact report, we would appreciate the following and the attached be included as part of the Public Record. The City of Costa Mesa has reviewed the Draft Environmental Impact Deport 00-02 and provided comments and conditions dated May 26, 2005, Since the proposed project involves the installation of pipelines in the City's right of way, we have stated our requirements for construction and use of City right of way, as well as comments on other aspects of the project in Costa Mesa. please understand that the conditions and comments offered on the proposed project are based on current information and may change depending on new information or changes in the scope of the project. Any and all decisions subject to preview and approval by the City Council, Planning Commission and/or the Parks &. Recreation Commission will be determined following public review&comment. We appreciate the opportunity to provide this information to the Huntington Beach City Council as part of its deliberations. Sincerely, Allan L. Roeder -� City Manager 77 FAIR DRIVE 0Wn1uP- 171A%7r1-RV7 • Tnn• 171L1 7SLAVAA . FAIL: 17141 75W.RTM + www_ci.00eta-M0aa_La_Qa SEP-06-2005 14:55 P,03 Attaclunent c: City Council Public Services Director Deputy City Manager/Development Services Director City Engineer Transportation Services Manager Assistant Development Services Director Principal Planner Associate Engineer SEP-06-2005 14:55 P.04 COMMENT 9 . x CITY OF COST.ALMEM. CALIFORNta=787.8•i2DQ P.O.BOK 1200 PUBLIC SE1'...V1CU D@PART"Wr May 2-6;2005 Mr_Ricky Ramos_ City of$uniin. on Beach plmming Dcpartment__ 2000 Main Strcct Huratington Beach,CAS2649. SUBJECT: ' _D 2Ak EiYV1�t€��T19�IY']CA .IM�AC�, POD No QQ-U2. R-TLM__ SEAWATER DESAL INATEON PROJECT 1N HUNTINGTON BEACH D car Mr.Ramos: i1izr 'yau rar baectiiig with-City`or gist$ mt!sa styon May 74V"2M-- to &kusg tli�'subjcct� Draf3.�viznz�ra�ntaLJ�xgactRc�arc..(F�}.._Hased-am,Q�udisc,��;n���.a�.azeviaw.,of.thel�ta�t_ EIIR. the City of Costa Mcsa has developed the attached cornmcnts and conditions. t;.you have Eay..CiILCS&n5,.p1casG r-T,r2n 1'pnrtntinn_SeL�1C�S.Maag ,at 714-754.5182. Sincerciy, William J. mS ` l�irec#or t��'pubSi-c'Scrvrces Ri Att=hmcnt c PeterNagbav,-Trari-,nnrtarirt-n Setvi.ces.l!'U2z=. EMESto Munoz, City 1=.D.gineet MikeoEainson,_Assi�tant r?r1c �InpmenLSnLvi�2m - Kimbcrly Brandt,principal Ph nrocc Raja Scrhu=gi.,-Assacia{e En-P r�er . Doug 1_,ofstrom, Orange County Fairgrounds 14 PHokr@; (114)755a.g737 - Fkk- 0 - DRIVE l7 )75n.Sf129 TOO: (714)7;,A.sa=4 www.ci.�v5ta•meFa.ca.us SEP-06-2005 14:55 P.05 F C0TY1MF_r-ZTS ON TaLSEAWATEF.DESAEINATION PROJECT DRAFT; CIRCULATE D ENVIRONMENTAL IMPACT RETORT page 3-2: The DES states"p Iti~ougt�prev:se.r*�iPalin=-aligume�4 �ay.he.modi£Lad.dl�zi .FL engineering a-`ssl.ysis, the conceptual pipel•;ne aiignmbnts are shown in E31ibit 3-3...... The Ciry of'osta Ilcsa'carYstderstnc pipelint to be r teal p�:E cf Y F=-1 t. �+s Bach, tl o-€._ ali,pmcnts should trot significantly dc-jate from proposed pr-oject align r-cr.ts. The proposed modifcaticas suggestedio pi�6_hn&alignment-by the, Cost�'lvlesa 5'£rtoineezxztg l=ijvrsiotz shoe be_a .the-current DE>Tt. Exhibit 3-3'The plan shouUrJzarly.icl u ky.th.c locations where.the pipeline is within City.zight- of way and where the pipeline aligmcnts arc not within the City's right-of'way. The project C description depicts-thr,.z1�ent_.traversing.tbzau�thc... r e_C=tY_,Fair.grounds�.Paizview Developmental Center, and the Costa,.Mesa Couz►tzy Club. Page 3-38:Primary Alignment: TheMEIRdiscusses.ali��ment-along-Adarls-�venlle3nd_then .t�1_Flaeentia.Avenue.t►�.. t�s# Mesa Country Club. Adams Avenue is a Major Az':erial and carries significant amount of;traffic 'tbmugbout the day. In,addition,,there,are residential,areas adjacent to Adams Avenue.as-well as d Placentia Avenue in the proposed alignment area. Therefore, the construction impacts resulting from.the.pxoposcd Proaacf_are. si.g ai.fxcant.and .shou.ld .hc ..asL* CCU as.part. DEI$- Trenching in the mad,way may result ira closure of two lanes oftraffic during the day, which . would not be allowed.by the_City.of.Costa.Mcsa.. The.impacts of onsttttatio:t.at rigbt.such__;�.s noise should be evaluated and addressed in the DEIR. Pronto reaching Costa Mesa Counlzy_Club,_thkpipelina.=ssca-Fairvi�w Eark-Apcprovals.Rmt Costa Mesa City Cour oil axed Parks&Recreation Commission will be zequix:d prior to working � within-the-Fairview.-Park, as-wel .as-vuitbin-the.. - Apprcv-al- operators of Costa Mesa Country Club should be obtained prior to construction within Costa' Mesa Country Club:" The DEIFY states.tha1L"pipeUztc would"ihcipm=ad_al�the_easterb=daz-3.af.Fainrteuc-S.tatc Hc4iml." The area shown in. Exhibit 3-3 has been sold by Fairview State Hospitsl to private dev'elop=--ss fox a bC) s41z_P yrrx.•-City.r ,quires-the documenta'tiois-of- f. approval from Fairview Developmental Cemfr of the proposed pipehu.e within their pioperty. The impacts ofmoyiz thz­aii xcr to it�sri rt=a wap o arlsor SoiiIcvard-vuil1 rescalt,, 11151gDsaRt impacts tdiat.�ucr�natCYaluared u�ttic pFIR�- The DEIR then states that the pipeline Would be routed along Fair Dnve on the northem side. Flcase.refcr.ta.cornm s hela�.o -tl3is�aiigruae��t The-City. -thecenter� median of Fair Drive. ,The impacts of this construction should be apalyzed in detail. The exisriug artd propasecl t� tli�ie� -Yd fir I rivcshaaid be rlsTdezeck _ftuuclung;-i the road;,�-ay may result in closure of rwo lanes of traffic dunng tb-- day, which would not be allowed by the City of Costa"Mesa. Fair Drive' ha only -two hires in 'each "dfree6oil. The impacts of' l comtmction at night such as noise sbDuld be evaluated aDd addressed in the DBIR, as there are residential areas adj-acent to lair Dave]T the proposed alignment area_ I i P.06 SEP-06-2005 14:56 ;r The DEM f n-thr-r states that the pipeline may be routed tYxrotigh th,e O,ap_ge County F&ETounds. Howtvcr, based on disctesstor:s wi'�tr Qra�r4e•�O y FziTgrartrsd� Staff, -there.have bcesy nQ. approvals faT. tbC proicct. City will require approval from Orange County Fairgrounds of the project prior to the Fi*iarizzdOrr-of1he"alignmcm per. Tkre en acts of mavirrg t}r�apr�-t:�, ye will "- ' : ` t-mere.3t c: _Iuated a the DEER. rair Sri rc�ui� iu ai�.Ei�,..�,t-sTe}.oC�S t,.,a Proposed Modifica¢ions to pipeline Alignment II • P!jrnarY Route p_Z=gh 4 t 1. IA lieu of rL sii lAdazm$vrnuo and..Plac=Iia_Ave=„ sk hatiz�ontal.alijp=ent o f the proposed pipeline should utilize the Santa Ax+a River right-of-way from Ad==Aveuue.taihe.Gry-af.Costa sa p�opertysotul�ofSwanl?tive,and, proeced east 0=3 the northerly edge of the park. This allg mmt will result in minimum disruption of.tho.City roadways, .2. The pipeline shall be desiped with consid.eration of the.futurc improvemmits witI&_Eainai w_Parl,atthe.endiaLCanax_yD ive, 3. The parks and Recreation Commission and Costa Mesa City Council shall approve.all wQrk within F,airvkw Park, r - 4. Any work impacting the Golf Course parking lot shall requite that the parking lot be Tesurfaccdzzidbe-4ohtdivatad i operar rS of.Golfcnl) C, Primary Route, Reach 5 I. City conouts..u'itbL the tr=hlms.cz=izag�LHazlaat�Rou3evasd_.The roadway section for Fait Drxvc shall be Cement Treated Base, and the trench shall bC IQCat2d-i�3:t}�CCTIieF-0 f the sfi�3et_- 2. The City of Costa Mesa reserves the south side of Fair Noe for a future storm drain.-The proposed,pige]ine,alighm=i should occuLx+ii3ain tht Q run ge-CG= Fairgrounds between Fairview Road and Newport Boulevard. - • For all Routes r r s 1. The City of,Costs Mesa reserves She r;gbt to� rave hath_theatignme�t.sod location(vertical.and horizontal control)within the City of Costa Mesa bQusadati e2 tt►allow fa,Fe€t�tu£e sertstFtie o-E ,ity s#tnnrchasrxfaci}ities arn-t- uti.ixry systems_ i" 2- The.work for.this prt�je��ha 11-b ? cf3 wi#h �at�u€-p }eets-by•El,�­City--& Costa Mesa. The projects izelude, but arc not h-mitcd to the rehabilitation of Fair 17riva f�liar•l3ouleva�d•ta l~sir�+-ieva-R�ci- u-�vc^se l;e2tiv�"•�t" P.07 SEP-06-2005 14:56 Fairview Road and Newport Boulevard, and Harbor Boulevard between Wilson Street and ll�cvgort Bar}end: 3;- The pipe aIignrt�t��tl-belaca�edr�nl? nn az[�1_streeks,as.shay�n.on,Gikx's � Ivlaste:-P-..z-zn.af.Arterial +a ways- . Page 3-29:Alternative Alignment: City-is ;not able,to cv�.u~ c:t: z*pm uc ;gnmPpr.as.deta;ied.anak)rszs_is not pro xidcd..an-this option. If this becomes the preferred alipment the City requests a recirculation of thr, ;HEIR. Since,Victoria•Streit traroTr}y tv�-}aric-�irt each reet on;tl�e Gi�y e Ce 3L+Iesa•ig•vp es�w, any consideration of this alig±tmcnt as the impacts of the construction are anticipated to by SIP,ifidant, Page 5S-24,TRA.FFIC.•- There.is-na.discussion.ofim�narr?c.to-City.of.Cosr:Mess arterials_atrdmeigbhorltoads,-whtte-a majority of impacts would occur due to the project. The discussion is very general and brief with no.estimates for.tnulLtdps-aLdevilq 01Qo suv don-=tbads-or-q-uawificatimofimpacts.Ttittzk k trips, construction workers and equipment resulting from the pipeline construction would impact ' City.of Costa Mesa utmia.L�-significantly.atxd-should_}z�--.d=umtmttd.in_the DEIR. A Traffic Management Plan within City of Costa Mesa should be submitted for approval by City's Transportafiozc Servir- Manager. Page S_9-33,TRAITIC I" 13 llak: "Limit coas�t�tioa to.oz� side-oftl�-Faar�;,." cxsates-•��� i�past t��i� streets. The arterials considered for placement of pipeline in City of Costa Mesa are Adams Avenue,-P1 acmtia A-ver-uL-,-H2fborBorr}cvard=-&i=air-Dri Ve Thre$seT=dVa-YY=-Of sigr[ifrtzat-, irtiport&ace to the City and cannot be subject to closure, especially'during the day. 3"t BuDet: ldEntiff'locations ill Ck of Cds#a M6"a.wfidre'tfierc may be crosurc of bicycle fines or.sidewalks. 1 4'h Ba*et: Submit a truck routing plan, to City pf Costa Mesa;For approval for any construction 1 withba Costa Mesa, 5�'13u11eG Ap$rava e€ode pl r sk anki be oht�=net,i am- il'y of�nsta Mesa'T d ' Services Mana_#r for any partial or full closure of streets within the City limits. 60 Builer.-City re 0fTmffic'M4TagemeT.A Mead af-9'Tperceat design phase. 76 Bullet: The project shall coordinate with all other construction activities izt the City and not Just 'to the extent fdziible:- CON-32: F.or.all work.in..thy_GiLy.cfC~sts��IesaT tl,�p a a .sl ll.recerve from Cosca Mesa Public Services Aepamnerlt. COLT-33: Same-comment.as far 4004-R. SEP-06-2005 14:56 P.08 ,s CON-341ay aiahL'Iimc construction activities izt City of Costa Mesa shill receive approval ixom Public Services Dimmu.-- CON-36: The appliea+lt--51%a4-c�wr.-dig,;�ie- 41-wTst=tiou-.miff r,icdgtrd aoavities.with.Costa Mesa's Public Services Department. The cmstrucd=vehicle muting plan in the City of Costa rfiesa shall ,be*submitted-Tzr ap-FT;:,v hf t�-E:ty- o-f-Cost-a W. sa--T-r amp adatiai�••"8 l Manager. - EXECUTIVE SUMJ ,ARX: Executive to above commeAnts. 4 s' • 'a s t } t SEP-06-2005 14:57 P.09 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS x Response No. 9 City of Costa Mesa Public Services Department William J. Morris, Director of Public Services 9a. This text provides an introduction to the comment letter and does not require a response. 9b. The desalinated water pipeline alignments presented in the DREIR were developed as a result of extensive preliminary engineering and feasibility analysis- These pipeline alignments are technically and environmentally feasible and are not expected to deviate substantially during final design, unless such a change is made necessary by an agency with permit authority over the project. 9c. A revised conceptual pipeline alignment map (Exhibit 3-3 of the DREIR) has been provided within Section 3.0, ERRATA, of the Responses to Comments. 9d. Construction of a 48-inch diameter pipeline will require one to two lanes to be closed during construction. The extent of these lane closures could be minimized through the contract documents to prevent a significant stretch of the road from being reduced by two lanes (500-feet minimum). In addition, hours of construction may be limited to exclude rush hour periods. Finally, lanes may also be re-striped to balance the number of lanes in each direction, effectively resulting in the loss of one lane in each direction. All pipeline design and construction within the City of Costa Mesa will be reviewed and approved by the City of Costa Mesa. No night time construction is anticipated at this time. ge. Comment noted. No response is necessary. 9f. The project applicant would obtain approval from the Fairview Developmental Center prior to construction on their property. Any construction occurring along Harbor Boulevard would require approval from the City of Costa Mesa and would include such measures as the exclusion of construction during rush hour periods, preparation of a Traffic Management Plan (TMP), and roadway re-striping, among others, as determined through a TMP review by the City. 9g_ The construction of the product water pipeline in the median of Fair Drive may allow the closure of only one lane of traffic. This would ease the flow restrictions. Once the pipeline is laid, the median would be replaced to existing conditions. All pipeline design and construction within the City of Costa Mesa would be subject to the review and approval by the City of Costa Mesa. Also refer to Response 9d, above. 9h. Comment noted_ Refer to Responses 13c through 13m, below. 9i_ This change has been incorporated into Section 3.0 of the Responses to Comments, ERRATA. City of Huntington Beach August 17, 2005 125 SEP-06-2005 14:57 P. 1O Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS 9j. As stated above, implementation of any pipeline segment within the City of Costa Mesa would require approval prior to construction. The construction process would be subject to such measures as the exclusion of construction during rush hour periods, preparation of a Traffic Management Plan, and roadway re-striping, among others_ The project applicant would consult with the City of Costa Mesa during final design to ensure that adverse impacts are minimized to the maximum extent practicable. 9k. Extensive analysis of impacts to sensitive receptors is provided within the DRE1R in Section 5.9, CONSTRUCTION RELATED IMPACTS in regards to air quality, noise, and traffic. Mitigation to minimize impacts to less than significant levels (including the preparation of a Traffic Management Plan) is provided within the section. 91. The measures provided within the comment would all be required*as part of the permit approval process through the City of Costa Mesa (such as a truck routing plan, automobile/bicycle detour plan, Traffic Management Plan, coordination with other construction activities, and coordination withlapproval from the City Public Services Department). The project applicant would consult with the City of Costa Mesa during 90% plan stage to ensure that adverse impacts are minimized to the maximum extent practicable. This change has been incorporated into Section j 3.0 of the Responses to Comments, ERRATA. 7 City of Huntington Beach August 17, 2005 126 TOTAL P. 1O Message Page 1 of 1 (.ITY CLERK Flynn, Joan kY .x}, CITY 0 ir,TiGTG� BEACH, Ca From: Billy Owens [bowens@poseidon1.com] 0" SET P ?: 5 2 Sent: Tuesday, September 06, 2005 3:39 PM To: 'Jill Hardy(ACT!)'; 'Penny Culbreth-Graft (ACT!)'; 'Paul Emery (ACT!); 'Mary Beth Broeren (ACT!); 'Scott Hess (ACT!); 'Joan Flynn (ACT!); 'Ricky Ramos (ACT!); dbazante@surfcity-hb.org; city.counciI@surfcity-hb.org Cc: Pat Dapkus; Cathy Fikes Subject: Poseidon Letter for Public Hearing -Sept 6th For the record please. Billy Billy Owens Sr. Vice President Poseidon Resources Corporation Long Beach Office (562)490-2003 ext 13 (562)490-2403 fax (949)433-4049 mobile r v �Y1h� i�g L - 9/6/2005 p O S E I D O N R E S O U R C E S September 6,2005 VIA ELECTRONIC TRANSMITTAL AND HAND DELIVERY Mayor Hardy and Council Members City of Huntington Beach 2000 Main Street P.O.Box 190 Huntington Beach,CA 92648 Re: September 6. 2005 City Council Items D-4a and D-4b: Certify Recirculated Environmental Impact Report ("REIR") NO. 00-02 for Seawater Desalination Project (Poseidon) and Approval of Conditional Use Permit (CUP) No. 02-04 and Coastal Development Permit (CDP)02-05 forwarded by Planning Commission Dear Mayor Hardy and Council Members On behalf of Poseidon Resources, Inc. ("Poseidon") I am transmitting the following comments for the record and for your consideration with respect to Items D4a and D-4b on the Council's September 6, 2005 Agenda relative to certification of the Recirculated Environmental Impact Report ("REIR") No. 00-02 for our proposed Seawater Desalination Project and approval of Conditional Use Permit("CUP")NO. 02-04 and Coastal Development Permit ("CDP") 02-05 forwarded by the Planning Commission. Poseidon's management team and our consulting engineers, scientists, local counsel, planning consultants and community relations representatives have worked for over 3 years with City officials,City Staff and the community to address a myriad of issues related to our seawater desalination project applications and to provide a complete and adequate environmental document for the project. Recirculated EIR Should Be Certified. With respect to the REIR,three(3)predominant subject areas of concern were identified by the City Council in December 2003, and as a result, the Draft includes updated information and analysis of the following: 1) Im ip_ngement and entrainment impacts of the currently permitted once-through cooling water system of HBGS and the potential impingement and entrainment impacts that may be caused by the project; Poseidon Resources Corporation 3760 Kilroy Airport Way,Suite 260,Long Beach,CA 90806,USA 562-490-2003 Fax:562-490-2403 Executive Office:1055 Washington Boulevard,Stamford,CT 06901 Mayor Hardy and Council Members September 6,2005 Page 2 2) Potential Growth-inducingimpacts of the project; and 3) Compatibility of the desalination facility's product water with existing notable water supplies delivered through the regional water distribution system. The Draft also evaluated several water transmission pipeline alignment alternatives, and additional information addressing impacts of such pipeline is contained herein. Poseidon has provided all information requested by City Staff and its independent consultant,RBF,and MBC,the City's scientific consultant,over the last 1 1/2 years and believes,as does City Staff and the City's EIR consultant, that the should be certified as complete and adequate. The has adequately identified and completely analyzed all potential impacts in the 3 areas referenced above as required by the City Council and City Staff. Please see also a letter from CEQA counsel, Ron Van Blarcom of today's date with respect to the adequacy of the REIR. Administrative Approval of CUP/CDP for Conforming Land Use Appications Are Only Decisions Before City Council. While City Staff will present their report on the facts in support of their recommended findings for approval of Poseidon's project applications, we would respectfully point out that policy questions as to whether State, Regional or County Water agencies should be doing more recycling, conservation or water transfers; water quality issues to be addressed by Regional Water Quality Control Board and Department of Health Services, or any of the other issues which will be addressed during processing of the 17 separate permit applications before these other agencies are not before the City Council at this time. Poseidon is only seeking administrative approval from the city of a CUP/CDP for our land-side desalination facility and product water delivery pipes. A. Reasons for Support of Poseidon's CUP/CDP Applications. As stated above, the purpose of this to provide environmental clearance for two administrative land use entitlement requests. These should be granted because: • The desalination water treatment facility conforms to and is a conditionally permitted use under the General Plan, Zoning and Southeast Coastal Redevelopment Plan; • The finds, among other critical findings, that there is "no significant long term impact" to the environment, and therefore provides CEQA clearance for the requested permits; • Local, secure and sustainable water supply is a significant asset to the City since it will provide: Mayor Hardy and Council Members September 6, 2005 Page 3 • Local control of backup, emergency water and potential ability to recharge the groundwater basin without relying on imported water,upon exercising City right- to-purchase such water(see"Water Supply"below); • City incurs no risk; • Additional water system benefits outlined below. Benefits to City of Huntington Beach from Poseidon Project. Contrary to the assertions of project opponents,there are clear,identifiable benefits to the City from the project's water output and status as a private, taxable, Southeast Coastal Redevelopment Project Area improvement which will have a construction value of approximately$200 million in 2005 construction costs. Moreover, if the City does not allow Poseidon to move forward with its project applications,it is entirely foreseeable that a public water agency(MWDOC,MWD, etc.),will renew their pre-2004 interest in the HBGS Site for a public desalination facility (see OCWD October 2003 "Ocean Water Desalination Program"Concept Development Paper). Whether included as project conditions or incorporated into a subsequent City—Poseidon Development Agreement, or alternative Agreement, Poseidon states its unequivocal commitment to providing the following benefits to the City of Huntington Beach over and above the CUP/CDP Conditions of Approval already imposed by the City: A. Water Supply. • City shall have the option to take up to 4 million gallons per day(MGD) of product water on a permanent, firm basis, up to 4 MGD, at a net rate equal to MWDOC's treated, uninterruptible, retail rate then in effect, with 24 hour advance notice. • City would be provided first rights to product water in a City Council declared water emergency, up to 10 MGD, at MWDOC's treated, uninterruptible, retail rate then in effect, for up to seven(7) consecutive days with 24 hours advance notice. Additional water may be available if product water deliveries cannot be made to others customers located beyond OC44 interconnection. • City would be provided a 5 cfs pipeline connection from the desalination product water deliver pipeline near the Newland-Edison intersection into city facilities in the area. • Joint use of a 10 MGD Southeast water reservoir, dedicated to City's priority use,with shared O&M costs; Poseidon will construct or lease the reservoir, at the City's discretion. The agreement will have additional Mayor Hardy and Council Members September 6,2005 Page 4 operational benefits and revenue to the City. City will have priority on the use of the reservoir in times of an emergency. • A new, drought-proof, local source of potable water increasing the diversification of the City's supply sources. • Long term water rate mitigation (desalination costs are declining and traditional water supply costs are rising). • Reduction in the City's operating expenses through the Project's financial contributions which defray the expenses of the OC-44 pipeline; the City and Mesa-Consolidated Water District share, through a Joint Powers Authority,the responsibility and expense of operating the OC-44 pipeline. B. Street and Landscaping Improvements Along Huntington Beach Pipeline 4-mile Right-of-Way. • Repaving from curb to centerline of-the street disturbed for pipeline construction immediately after pipeline is completed, including striping, markings and reflective pavement markers(RPMs). • Public right-of-way enhancements along pipeline alignments for: ■ ADA Ramps ■ Sidewalk replacements ■ Parkway trees • Landscaping median construction where master planned ■ Landscaping renovation of existing frontage road medians • Poseidon will pay for an on-site city construction inspector for pipeline construction. • Poseidon will provide a performance, surety bond or other financial instrument to the City to ensure financial liabilities,if any, are addressed during pipeline construction. • City shall have the right to review qualified pipeline contractors' list prior to selection/execution of contracts or bids. C. 30-Year Guarantee of Tax Benefits: In-Lieu Fee in the event of sale to Public Aizenc . • City protection clause to ensure transfer of the obligation to provide the agreed benefits with any change in ownership, especially sale to a tax- exempt public entity. May be provided for in statutory development Mayor Hardy and Council Members September 6,2005 Page 5 agreement, conditions of approval or other binding mechanism upon mutual review of City Attorney and Poseidon legal counsel and review/approval by City Council and if necessary, City Planning Commission. 0 New, long term source of sales tax, property tax and other specific benefits to the City, as cited above, protection clause in event of any change in ownership to a public agency (e.g., MWDOC) to assure 30- year guarantee of benefits. • Location in Southeast Coastal Redevelopment Project Area provides higher tax retention. • Property tax revenue of$1.8 million annually verified in June 2003 M. Cubed Report (will be submitted with hard copy of report to City Clerk at public hearing). Annual property tax revenue based on 2003 construction valuation of approximately$186.5 million. 38-year lease is treated as fee simple property and fully assessable under State Revenue and Taxation Code, Section 61(c)(1). • RDA will realize estimated $1.2 million annually for Southeast Coastal improvements. D. Financial Instrument Posted to Assure Completion or Removal of Prot facilities. Poseidon will post appropriate financial instrument assuring completion of all project facilities and, subject to cure periods, removal of same in the event of any condition subsequent that prevents operation of the plant. Items Needing Clarification The Project as presented to the City, raised legitimate concerns that must be addressed; some are unique to the Project and others related to the environmental setting. The City Council,as stated above, determined in 2003 that potential effects upon marine life with the discharge of concentrated seawater and potential impact to marine life that may be caused by recycling the power plant discharged cooling water, potential for growth inducement and potential for life extension of the power plant or related operational changes needed to be further analyzed. The recently introduced concern about the potential effects of constructing a pipeline in the city streets is also a legitimate concern that deserves attention. The EIR has examined all of these points and addressed each one either in the study itself or in the Response to Comments prepared by city staff. The staff conclusion is there is no significant Mayor Hardy and Council Members September 6,2005 Page 6 long term impact and others can be further mitigated as noted in the reports. Poseidon has provided additional commitments(see pg.4,item B of this letter)beyond staff-required conditions of approval that mitigate any potential pipeline impacts and will address the pipeline issue in more detail in its presentation before the City Council. However, this project has served as a platform for other agendas and issues that are not directly related to the Project to be introduced and linked to the Project. There are core issues directly related to the proposed Project to which specific responses have been prepared, not a different project imagined and the subject of speculation. While Poseidon has addressed the issues relating to the Project with specific analysis and detailed responses in the EIR,we will elaborate on a selected few below. Need for the Project There is no question as to the need for desalinated water to meet the area needs over the next twenty years. This project and others have been identified in various state,regional and local water agency plans for years (see EIR, Section 3.4, Project Needs and Objectives). When possible, agencies plan and permit new infrastructure(including water facilities) in advance of the actual demand. It takes years for these facilities to be approved and constructed. More often than not, water supply and related infrastructure is in place before the customer requires it. It takes too much time to put water facilities in place; waiting until the need is immediate is too late and imprudent. As mentioned above, prior to the commencement of the two-year construction of the Project, the local land use approval process must be completed and subsequently approvals and permits must be obtained by numerous state and federal agencies, including the California Coastal Commission, all of which take considerable time and capital investment. Poseidon would offer some of these recent statements by Southern California's regional water suppliers (the same suppliers the city of Huntington Beach relies upon for 40% of its supply)on water needs and the utilization of desalination to address those needs for the record. Metropolitan Water District of Southern California(MWD) "Local resources, including groundwater recovery, water recycling, seawater desalination, and conservation are fundamental parts of the IRP. Financial incentives by Metropolitan will support local projects that are expected to develop 255,000 acre-feet of new supplies by 2012/13. These investments result in additional water supply, but just as importantly, defer the need for Metropolitan to construct new treatment and distribution capacity(emphasis added)." [MWD 2003 Integrated Water Resource Plan(IRP)Update,adopted July 13,2004,Appendix 1,page 99]. "Other changes since the 1996 IRP include the following: Mayor Hardy and Council Members September 6,2005 Page 7 ■ Decreases in the estimated cost of seawater desalination ■ Faster than expected development of groundwater recovery supplies ■ Decreased offset of potable supplies by recycled water due to higher than projected local recycling production dedicated to non-direct uses,such as groundwater replenishment and seawater barriers." JMWD 2003 Integrated Water Resource Plan(IRP)Update,adopted July 13,2004,Appendix 1,page 33]. MWD of Orange County(MWDOC) "The release of the IRP Update comes at a time when the Colorado River is experiencing a very significant drought(by some accounts the worst in 500 years)and much of the West has also been in drought. Meeting the reliability goals for the Metropolitan service area will require concerted effort and investment over many years and on many fronts. Continued effort in the Bay/Delta and Colorado River to firm up available supply, continued effort to pursue local projects such as water recycling and seawater desalination, and continued advancement of water use efficiency measures will all be required to maintain reliable water supplies to 2025 and beyond." "Although current resource targets do not need to be modified,the IRP Update identified two new areas of concern: (1) Increasingly stringent water quality regulation;and (2) Resource implementation risk surrounding the development of planned projects." (MWD of Orange County memorandum dated July 7, 2004, RE: Final 2003 Integrated Resources Plan Update Report,item 3 on MAID of Orange County Board agenda.) Efforts by Water Agencies to Move Desalination Projects Forward. It is also important to note the extensive effort Southern California water agencies are exerting to promote desalination consistent with formally adopted supply plans. Several public water agencies are members of the US Desalination Coalition, an organization created by these same organizations,to lobby Washington and Sacramento for support for seawater desalination projects. A list of actions by this organization is listed below: • Water Price Reduction Subsidy—MWD approved on July 12, 2005 (Items 8-7 and 8-11 Board Agenda), as a part of its desalination program, a $250 per acre foot per year subsidy(approximately 125,000 acre feet per year total for these projects) to its member agencies for desalination projects that successfully reach operation. Mayor Hardy and Council Members September 6,2005 Page 8 • Electricity Price Subsidy — S.1016 and H.R. 1071 — "The Water Supply Shortage Prevention Act of 2005." Requests an electricity price subsidy of$0.62 per thousand gallons (or $200 per acre foot) of water produced for the first ten years of operation. (http://www.usdesal.orWabout/home.htm). • Desalination Site Preservation— (a)Assembly Concurrent Resolution 84, sponsored by MWDOC; directs city and county governments to consider the potential for siting desalination facilities prior to taking zoning actions. (Please note MWDOC's letter on the REIR,dated May 27,2005,page 3, last two paragraphs, states ". . . gaining various permits and approvals for the project, including site acquisition would be beneficial to a future project. . . . MWDOC does support preservation of the site for a future desalination project." (b) San Onofre Nuclear Generation Station is closing Unit 3. The State Lands Commission has jurisdiction over the future use of the existing ocean intake-outfall cooling water structures connected to Unit 3. MWDOC has actively participated in the proceeding on the future disposition of the cooling structures arguing for their preservation as a feed water structure for a seawater desalination facility at the site. • California Electricity Price Subsidy—AB 2918—introduced as a special electricity tariff for desalination sponsored by several water agencies in Southern California, the bill required the same type of preferential treatment as the Federal legislation cited above. It has since evolved into a study by the Public Utility Commission. • The OCWD sponsored October 2003 "Ocean Water Desalination Program" concept paper: "envisions a 50 MGD ocean water desalination plant("OWDP")at the AES power plant in Huntington Beach . . . could be expected to produce 50,000 afy". This water agency report concluded that: "The reduced pumping (associated with operation of an OWDP at Huntington Beach) would raise groundwater basin water levels and would act to deter seawater intrusion. In addition, if the OWDP is quickly constructed and was utilized in conjunction with an in- lieu program,the groundwater basins' overdraft could be reduced." The report goes on to indicate similar benefits using additional MWD supplies; however, given the report's primary fording that"OCWD water demands in 2025 will exceed the current supplies by 109,000 acre-feet per year,and an OWDP could help meet this need,"and MWD's recent action to continue the desalination subsidy program, no credible argument can be advanced that water agencies are on record that the region doesn't need additional water supplies,or that desalination projects are an important component of that supply. • Desalination Water Sunyly— AB 314,Kehoe, Desalination. Mayor Hardy and Council Members September 6,2005 Page 9 AB 314 is a clear statement by the State of California that brackish or seawater desalination should be treated equally with traditional sources of water for meeting future supply needs: "...law declares that a substantial portion of the future water requirements of this state may be met economically by saline water conversion facilities and that the development and use of those facilities will contribute to the health and safety of the people of the state." [Approved by Governor August 9,2003.Filed with Secretary of State August 11,2003.] z The activities cited above are a further confirmation of the desire and need for desalination project is recognized now by the water community and policy-makers and that these projects and this site will be relied upon for meeting local and regional needs. 2005 California Energy Commission (CEC) Huntington Beach Generative Station Study: Dry Cooling Alternative Speculation Not Relevant for Recirculated EIR As stated above, the City Council directed an expanded entrainment study for Project impacts at the point of seawater withdrawal from the discharge pipe of the Huntington Beach Generating Station(HBGS). The objective was to determine the potential for additional "incremental" entrainment of marine organisms after discharge by HBGS. The study contained in the 2005 is completed and the findings were that there would be no significant impacts. The study was done to satisfy the council's information request, but the City, as lead agency continues to define the project as recycling HBGS discharged cooling water, not direct use of seawater. This is important,factually and legally,because: • The direct withdrawal of seawater is controlled by HBGS and HBGS is therefore legally responsible for compliance under the Clean Water Act,316(b)regulations. 0 The US Environmental Protection Agency (EPA) has always regulated industries under the assumption the withdrawal of water will result in 100% mortality of the organisms entering the cooling facilities. • Downstream users, after the power station has utilized the seawater, are not directly regulated because the marine organism impact has already occurred. 0 The new EPA 316 (b) regulations have not altered this rule; the new regulations have specified more significant mitigation requirements to reduce the loss of marine life and defined methodologies for choosing among approved mitigation technologies or off-site mitigation measures for "existing facilities". HBGS is therefore responsible to comply with the new 316(b)regulation. A recently released draft CEC study on entrainment and impingement is inapplicable to these proceedings for the fundamental reasons detailed below: Mayor Hardy and Council Members September 6,2005 Page 10 • the new draft CEC study is about the power plant,not the desalination facility; • the study is a "draft" report under limited release May 3, 2005 (to agencies involved in the 2001 AES HBGS certification for Units 3&4),almost one month after the Project EIR was released for public review • any mitigation measures under AES's responsibility will occur "up stream" of the desalination water intake point. It has also been asserted, at the recent City Council study session on August 22, 2005, that the Project would occupy the only land contiguous to, and large enough for the installation of"dry cooling"facilities which conceivably would be necessary for HBGS to comply with the new Clean Water Act,316(b)regulations. Neither the CEC study nor the EPA regulations lead one to the conclusion that dry cooling is an acceptable or appropriate technology to address the issue at the HBGS location. In any case, any decision is many years in the future as additional studies will be required by the South Coast Regional Water Quality Control Board to support a specific set of permit requirements for the HBGS. The future actions of a regulatory proceeding are multiple and therefore speculative and not relevant under CEQA. . Private versus Public Development and Operation of Seawater Desalination Projects;Adherence to Environmental Regulations by Multinational Corporations is Required,Contrary to Assertions by Coastal Commission Staff. • Private sector firms provide water and wastewater services of all kinds to over 50 California communities and provides domestic water service to approximately one-in-five Californians.* Nationwide, approximately 2,000 municipalities have entered into contracts with private firms for water or wastewater systems. Of the total number of existing desalination facilities cited in the California Coastal Commission's 2003 report, half are privately owned and account for 73%of annual production. • While Poseidon is a Connecticut-based and not a multinational corporation, it is important that the City Council be aware that there is no basis for the Coastal Commission Staff s continued insistence that private entities covered by provisions of[international trade]agreements (e.g., NAFTA, GATS, etc.) may attempt to use these agreements to challenge state or local regulations as barriers to free trade. • The Commission Staff s assertion ignores the fact that multilateral trade agreements such as the General Agreement on Trade in Services("GATS"),the General Agreement on Tariffs and Trade 1994 ("GATT") and the North American Free Trade Agreement ("NAFTA") do not *Water Partnership Council letter of Nov. 6,2003 to California Coastal Commission. Mayor Hardy and Council Members September 6,2005 Page 11 interfere with a legitimate exercise of environmental enforcement power by federal or state and local governments relating to desalination or other facilities. • GATS specifically exempts measures taken by a member state which are necessary to protect human, animal or plant life or health. (Article XIV(b)). GATT also has a similar exemption for enforcement of environmental regulations in Article XX(b) and g). Both GATS and GATT would therefore not prevent enforcement of environmental regulations applied equally to domestic companies. NAFTA, likewise, has numerous built-in safeguards for assuring environmental protection(see Article 712(1).) Finally, the Department of Water Resources ("DWR") recognizes that international ownership grants no special rights: No international trade treaty now in effect or being negotiated by the United States would prevent local, state or federal government agencies from reviewing and regulating water projects that involve private companies with multinational ties. Such projects include desalination plants, water transfers, water storage projects (both above and below ground) and waste water reclamation projects. So long as governmental regulations are applied in the same manner to water projects involving multinational corporations as they are to water projects owned and operated by domestic companies or public agencies, there would be no conflict with international trade treaties.(emphasis added)* Growth Inducement Addressed The provides extensive analysis and discussion in Section 6.2 and Appendix P. The most current General Plans for the County of Orange and for the individual cities within the County were analyzed by LSA and independently assessed by staff. Land uses, growth forecasts, major projects under review or anticipated were examined to determine the amount of additional growth and development anticipated within the County. These growth forecasts were analyzed in conjunction with most recent projections by SCAG, California State University at Fullerton and forecasts by water agencies serving these jurisdictions. Water Plan Assessments ("WPA's") for specific projects were analyzed to determine if water was already available for the projects and those without were assumed to potentially rely upon desalinated water,even though water supply is not considered available by law until a water facility is operating. The potential or growth inducement was found to be insignificant. Moreover, the 2003 Update to the California Water Plan(Bulletin 160)prepared by the Department of Water("DWR") estimates that by 2030, 17 million new residents will need to be served with an additional 2.4 million acre feet of water assuming aggressive water conservation measures are in place. *Draft California Water Update 2003,Bulletin 160,Volume 1, Chapter 2, at pagel 1. n Mayor Hardy and Council Members September 6,2005 Page 12 Product Water Pipeline Construction Poseidon treats the community's concern about potential disruption and potential damage related to the construction of the 48-inch water transmission pipe very seriously. The problems related to the 108-inch (9 ft.) diameter OCSD sewer pipeline are being linked to the future construction of the desalination product water pipeline. This is not a reasonable comparison. Not only are the two pipes dramatically different in size(9ft—vs.-4ft in diameter),but design, schedule to complete,the potential to contribute to disruption of the neighborhood, subsidence in adjacent areas and potential to disrupt traffic are all of a different magnitude. Poseidon will present a more a more detailed description of how the construction can proceed at the public hearing. Life Extension of Power Plant • the Project will obtain all of its own permits;no shared permits with HBGS • the CEC stated in the HBGS approval of"modernizing"Units 3&4 in 2001: "The possible development of a desalination plant would not have an effect on the land use considerations relevant to the proposed project. Any land use impacts generated by the desalination facility would be identified and evaluated in the City's environmental analysis." • Similar statements in 2004 CEC studies on aging power plants in the state acknowledge desalination projects are being proposed at coastal power plants and "Energy Commission staff is not aware of any land use issue that would likely contribute to decisions to retire aging generating units within the time frame of this study." • HBGS has contracts to sell its output for many years into the future and the plant location has benefits to the electrical grid system For the above reasons,one should conclude: • HBGS has a distinct economic and regulatory life of its own • the CEC significantly controls the regulatory life of HBGS and has determined that local zoning-land use decisions will not have a bearing on its ability to regulate HBGS • the absence of the desalination Project will not close or accelerate the closure of HBGS; 0 therefore,approving the desal project will not extend the life of the power plant; Mayor Hardy and Council Members September 6,2005 Page 13 In closing, the decisions before the City Council concerning the Project are narrowly defined under CEQA. Careful consideration is still required and appropriate conditions and follow-up actions are necessary to grant the requested land use approvals for the Project.We have appreciated the opportunity to work closely with the City Staff and the City's consultant's in processing the project applications over the past 3 1/2 years. If Poseidon can be of further assistance in your deliberations, please do not hesitate to contact us at your convenience Sincerely, Billy wens cc: Penny Culbreth-Graft Jennifer McGrath Planning Staff Dear Members of the Huntington Beach City Council: As a Huntington Beach resident,I want you to know that I support the proposed Huntington Beach Water Treatment Facility because: •Local drought-proof supply of water • $1.8 million per year in property tax for Huntington Beach • $500,000 per year in sales tax for Huntington Beach •Trees,paving and other improvements around the current power plant Sincerely, Name: e 3 Address: City, State and Zip Code: 4�1+ :yo u , �a 2 Z(Iq 9 Please... Your First Class stamp will save us the cost of postage. BUSINESS REPLY MAIL -_ FIRST-CLASS MAIL PERMIT NO 1617 HUNTINGTON BEACH CA POSTAGE WILL BE PAID BY ADDRESSEE HUNTINGTON BEACH WATER TREATMENT FACILITY PMB 305 419 MAIN ST STE A HUNTINGTON BEACH CA 92648-9942 all eni � ib 1y�� pwu� rr ke t�YJ ,aofisrr 1` ' �"@ .� " �. w� NHtA '�.,. ° ROE! �� �„m � $�. �s rw >. �. n n7 ,�fit� o��rd�zet� t� 4�' 3� s tc�ucisi indisry`��� imp �i?.l-ptt ` r fNt� ,y� rT'i i; s'e� x�'" ': pr ass, f ire Yyr x }tf tid�,ynr t.�Xkr �.' �, 1�9�''r�lY y� d lr+ '`r"1'�"ff BMX y>'ry�"f �NP Y s Ik r K 1 4 yt .�d 7 F, �sk 'Ik �^ �Z T �[ X S ly f '� h h1r C ✓i�� 4 k&�� Sep-06-2005 01:llpm From- T-348 P-001/005 F-040 Lid t_?i Ei i-v ri fY � GlOY McKenna Low HUPiTINGTOPI BEACH, CA. lVl .�i AiJanla 2005 SEP —b P I* &Aldridge,.,.,, San Diego [Denver Annrwysac Um San Francisco I-os Angoles 444 South Flower Street + Los Angeles, CA 90071 washingion,DC Philacselphia Tel; 2'13.688.1000 • Fax: 213.243,6330 Brussels www.mckennaiong.com FACSIMILE TRANSMITTAL Date: September 6, 2005 To: Name/Company { Fax No. Phone No. Ms, Joan Flynn (714) 374-1557 (714) 536-5227 City Clerk, City of Huntington Beach j From: James C. Hughes Phone: (213)243-6130 Re: Bella Terra Shopping Center Number of Pages (including cover): 5 COMMENTS Confidentiality Notice- The information contained in this facsimile is legally privileged and confidential information intended only for the use of the individual or entity named above, If the reader oi'this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this telecopy is strictly prohibited. If you have received this telecopy in error, please immediately notify us by telephone and return the original message to us at the address above via the United States Post Office. Thank you. User No.: 2901 ClientfMa uar No.: 28360.0013 If transmission is unclear or incomplete, please contact our facsimile operator immediately at(213)243-6061. Sep-06-2005 01:11pm From— T-348 P.002/005 F-040 Atlanta McKenna Long San Diego Denver &A1dxldger Attorneys at Law San Francisco Los Angeles 444 South Flower Street a Suite$00•Los Angeles,CA 90071-2901 Washington,❑C 213,689.1000•Fax: 213.243.6330 Philadelphia www.mckennalong_com Brussels JAMES C.HUGHES EMAIL ADDRESS (213)243-6130 jhughesemckennalong.com September 6, 2005 Via facsimile Honorable Mayor Pro Tom and Members of the City Council City of Huntington Beach City Hall 2000 Main Street Huntington Beach, CA Re. Bella Terra Shopping Center Specific Plan No. 13 H-Item, September 6rh City Council Meeting Proposed Zoning Amendment to Specific Plan No. 13 Ladies and Gentlemen: We submit this communication to you on behalf of Bella Terra Associates("BTA"), current owner of the Bella Terra Shopping Center("Bella Terra"), Huntington Center Associates, LLC ("I-iCA"), the farmer owner and party charged with the ongoing completion of Bella Terra, and Snyder Huntington Development, LLC ("Snyder"), HCA's construction manager for the ongoing completion work. Bella Terra is the product of as Owner Participation Agreement ("OPA") entered into between HCA and the Redevelopment Agency of the City of Huntington Beach ("Agency") in October, 2000 and implemented pursuant to Specific Plan No. 13 ("SP 13"). The development of Bella Terra is expected to be completed by the middle of 2006, although portions of the project Nvill be completed as early as next month. Bella Terra is the largest development project under construction in the City. It is also one of the most significant projects in the City due to its gateway location and ability to generate real property and sales taxes for the City. Before Bella Terra, City and Agency officials lamented the fact that the residents of Huntington Beach drove by the former Macerich Huntington Beach Mall on their way to other cities to spend discretionary income on retail purchases and entertainment. Bella Terra has remedied that problem, assuring that local retail and entertainment dollars will remain in the City to be recycled back via taxes into City operations and programs. Sep-06-2005 01:11pm From— T-346 P.003/005 F-040 Honorable Mayor and Council September 6, 2005 Page 2 BTA, HCA and Snyder have been advised of a proposal to direct City Staff to initiate a zoning amendment to revise SP 13 (which we understand may be expanded to include all specific plans)to require even minor modifications to SP 13 and new development projects within SP 13 implemented through the Site Plan Review process to include "... a report to the City Council ofthe Planning Director's decision, and to permit any person to appeal the Planning Director's decision to the Planning Commission within 10 calendar days .,." (See August 31, 2005 City Council Interoffice Communication of Jill Hardy, Mayor to Honorable Mayor Pro Tern and City Council Members.) BTA, HCA and Snyder oppose this proposal in its entirety and advise you that adoption of the proposal with respect to SP 13 is legally impermissible as well as inadvisable for the following reasons, among others: (1) Changes to SP 13 Require Mutual Agreement Under the OPA: OPA Section 402 specifically requires that Bella.Terra is to be redeveloped "_ as generally established in City-approved entitlements ..., including Specific Plans ..., except for such changes as may be mutually agreed upon between Participant and the: City." As co-Participants, BTA and HCA do not approve the proposal to revise SP 13 to grant additional approval and appeal rights. Just as BTA and I-1CA are barred from unilaterally changing SP 13 as may suit their needs in developing Bella Terra, the City is barred from requiring additional, substitute, and/or replacement approvals and from granting additional appeal rights under SP 13. (2) Vesting Rights Preclude"Mid-Stream" Changes: Even if the OPA had not included Section 402,applicable principles of law relating to vested rights and the prospective application of changes in law require that the City cannot change materially the approval and appeal processes pursuant to which development projects, including Bella Terra, are approved and completed under SP 13 after SP 13 has been approved and development has commenced in reliance thereon. HCA and BTA (and their investors and lenders) have made substantial investments and exerted substantial efforts to develop Bella Terra in reliance on SP 13, including the use of established approval and appeal processes and procedures. By proposing to make every change and every site plan review subject to City Council review and public appeal - essentially stripping the Planning Director of virtually all authority to make decisions efficiently and expeditiously regarding inevitable project evolutionary changes -the proposed zoning amendment"changes the rules of the game" for SP 13 in mid-stream significantly and detrimentally for the developer. This is neither legally permissible nor advisable. Sep-06-2005 01:11pm From- T-346 P-004/005 F-040 Honorable Mayor and Council September 6, 2005 Page 3 (3) Internal City Personnel Problems Should Not Be Remedied B Legislation That Increases the Already Considerable Costs and Risks of Development: Rending between the lines of the proposed zoning amendment, it appears that someone at the City has decided that the City Planning Department, including the Planning Director, are not to be trusted. Despite the expetlise, experience, and tireless efforts of these City planning professionals in ex,aNating and implementing development projects, someone has decided that they require unusually close City Council and public supervision. We believe the City's internal personnel problems should be solved internally by the City, not by significant increases in laws and regulation. The proposal before you adds a significant new level of project review by the City Council, adding to the Council's already overburdened calendar and extending overly lengthy development approval processing by the City. In addition, appeal rights are granted to "any person," including competitors,non-residents, those opposing development of any kind based outside of the City, and other non-stakeholders, who are afforded The further opportunity(by unjustified developer delay and increased expense) to frustrate legitimate commercial objectives, as well as the City's and Agency's exercise of its redevelopment powers. In short, if the City is dissatisfied with the performance of one or more of its own planning professionals, it should re-educate them, or hire new ones, or implement better internal communication among City Staff, the Planning Department and the City Council so that decisions of the Planning Director will be consistent with Council directives. But the City cannot solve this internal City problem by putting developer, in the middle between the Planning Director and City Council or by granting any member of the public a further opportunity to veto the project, even as to its most trivial aspects. These actions by the City will needlessly and detrimentally destabilize the development process City-wide. (4) Discriminatory Treatment of SP 13: As originally proposed,the zoning amendment would be limited to SP 13. We understand this may be expanded to include all specific plans. We believe tivs expansion is intended merely to mask the original intention to impose different rules and standards for SP 13 and Bella Terra than for other specific plans and projects in the City. Any proposal to treat SP 13 and Bella Terra differently from other specific plans and projects in the: City is patently illegal because no adequate justification exists for this discrimination. 1n point of fact, Bella Terra is one of the City's most successful and productive projects and the developers who have created Bella Terra have demonstrated uncommon perseverance and ability in bringing Bella Terra to market. Further, Sella Terra will generate tax income greatly in excess of original projections for the City's benefit, has attracted first-class retailer; and restaurants to th4 City, and has established a landmark destination for City residents for retail and entertainment. Sep-06-2005 01:12pm From- T-348 P.005/005 F-040 Honorable Mayor and Council September 6, 2005 Page 4 (5) The Future Is At Stake: Successful governance requires that municipalities balance divergent interests in connection with the consideration of approvals, but thereafter allow knowledgeable professionals to implement projects expediently and in a manner consistent with these approvals. Pure democracy paralyzes action because it impedes efficient decision-making. Overly centralized decision-making makes for efficient decision-making but sacrifices divergent points of view. The proposal before you suffers from both defects: too much centralized power over projects by the City Council (which should remain delegated to the Planning Director for efficiency) and too much pure democracy (in the public's ability to appeal every project decision). These will needlessly politicize even the most minor development decisions, effectively eliminating the ability of the project developer, investor and lender to predict the availability, cost and timing of necessary project approvals as the project evolves during the course of development. These effects must be carefully considered now before they create a lasting detrimental impact:on development and investment in the City. Based on the foregoing, among other arguments, we respectfully submit that the proposal before you to initiate a zoning amendment is not legally permissible under the OPA with respect to SP 13. Moreover, the proposal is impermissible and inadvisable for SP 13 and other specific plans for the other legal and business reasons given above, among others. Other reasonable alternatives exist for the City to correct its internal personnel deficiencies without imposing additional regulation on the development community, in particular Bella Terra. For these reasons and others which may be discussed with you at the City Council hearing this evening and on other occasions, BTA, IICA and Snyder urge you to reject the proposal. ry truly yours, games C. Hughes V cc: Mr. Lindsay Parton Mr, Bryan Ezralow Mr. Michael Wise 09/14/2005 12:39 FAX 714 960 7806 REP DANA ROHRABCHER 0 001 DANA ROHRABACHER WASHINGTON GFFICE: 451h Dislrm.cuhrprnia 23a8 Rayhurn House Ot(Ice dudtln� p (h 1 � Washington,DC 20515-0546 12021 225-2a15 FAX:1202)225 Olaf. CUrnndllrr.:. f�� !{i v SCIENCE < j1 DISTRICT OFFICE; Chairman,BuDrammillea on Sp6irr:anaAeruPautIGS (Y �[ L� 11 �(]/�1F*� t1LD LQ�� L�1L.J}{J4 101 Mwln Straet, !a2s 3a0 w,juhrIOMMME°an Research ocongrezz of Me rl it b "+.�Gft{.�`u Hut in-054H3on caFAch,CA1419 .'18 ll (71aI 9fit1-5463 FAX (714f 9G0�7&UE INTERNA FIONAL RELATIONS jpauge of RcprCBPEttatibe $n�ilh daV'(71U1 377 9a97 Subcommirlcc an Ir)lnmatmral Tarrnrlxm, http.lfwww hn NaripralllrraTlUn.and Human Rlphls uxc Oow7rnhratsacncr! SubcommiMcc un Aa'ia and IhE Pam11G CONGRESSMAN DANA ROHRABACHER FACSIMILE COVER SHEET To- From= a LLI Congressman Dana Rohrabacher 0 Bernard Stroppa — o--i COor^ F1 Kathleen Hollingsworth ❑ Mike Gureckas MT' r_ Dr. Fadi Essmaeel ID Matthew Hanson 0 -- ❑ Alberto Sandoval [j Julie Goldpaint Xr Kellee Barron ❑ Intern, Number of Pages, including cover page: _ Notes: ��� 09/14/2005 12:89 FAX 714 960 7806 REP DANA ROHRABCHER Q 002 DANA ROHRABACHER WASHINGTON OFFICE_ d0th 04 t kL CpIftrnlp ' t J d 2=IIeI House Mos 8AMng WnIoC20 *46" Ce 42021226-MG FAX OU1726--oms INTERNATIONAL RM ATldi9 pl$TAICT OFFICE. , Cfai HV%s3w nmff "ell 71111 O►wNd�W hvialadww SubowwrMss an �LL�Q 4 7JTJ 1t 1J ta Huntington Reek G 1200D A�AM Psi (7,.a 8m�+e3 FAX (714a ri 7eaa SCIENCE oulle of Repreoentatibeg so �•rro,nlx» s sutimneane an Spans ua ArMI&I nvavrron.eh.e Bsr_tr year sub" I a IMF September G,2005 The Honorable Jill Hardy,Mayor City of Huntington Beach 2000 Main Street Huntington Beach,CA 92648 Fax:714536-5233 Dear Mayor Hardy: As the Huntington Beach City Council considers the proposed desalination project in Huntington Beach,I would ask that you take into consideration the broad as well as the narrow view of what is being decided. It should never be minimised that Southern California is,essentially, a desert by the sea. Although Huntington Beach is not in a water crisis today,it is important to recognize that you are making a decision about the future availability of fresh water in Huntington Beach, Orange County and the greater Southern California area. Unfortunately,there are irrational forces at play that oppose any new infrastructure to serve our current and future population. No-growth NIMBY-ism is a destructive force in meeting the needs of our people and maintaining our way of life. That a private company is willing to make the major capital investment to build a project that will increase the arneiml of water available to our area is a godsend. If this offer is tuned down,along with the$l.8 million in new tax revenue it would bring in,the city should not expect the federal government to take seriously future requests for assistance. Huntington Beach has always been on the cutting edge of technology,whether in aerospace or in developing technologies that improve the quality of life. There is no reason we should not be in the forefront of using desalination to ensure a supply of clean and drinkable water. As a resident of Huntington Reach,I feel very strongly about this issue and urge you to certify the Environmental Impact Report for the desalination project. Sincerely, Dana I�ohtabacher Member of Congress CITY OF HUNTINGTON BEACH 13 Inter Office Communication Planning Department TO: Honorable Mayor and City Council Members VIA: Penny Culbreth-Graft, City Administrator FROM: Ross Cranmer, Acting Director of Planninl-,- DATE: August 18, 2005 SUBJECT: RESPONSE TO COMMENTS FOR DRAFT RECIRCULATED ENVIRONMENTAL IMPACT REPORT NO. 00-02 (POSEIDON SEAWATER DESALINATION PROJECT) The City's consultant has completed the Response to Comments for the Draft Recirculated Environmental Impact Report (REIR) for the proposed Poseidon Seawater Desalination Project. Attached is a copy for your review in preparation for the upcoming public hearing, scheduled for September 6a'. A study session has also been scheduled for this project on August 22na The Response to Comments, which includes the 52 comment letters received on the Draft REIR, has been sent to all agencies and private organizations that commented on the Draft REIR. In addition, copies of the Response to Comments are on file with the Planning Department, the Central Library, and Banning Branch Library. The Response to Comments may also be viewed on the City's website at: www.ci.huntington-beach.ca.us/govermnent/departments/ planning/majorprojects as of August 22"a RC:MBB:RR:rl xc: Jennifer McGrath,City Attorney Joan Flynn, City Clerk Paul Emery,Deputy City Administrator Bob Beardsley,Director of Public Works Duane Olson,Fire Chief Howard Johnson,Utilities Manager Scott Hess,Planning Manager(w/o attachment) Mary Beth Broeren,Principal Planner Ricky Ramos, Associate Planner GA\AdmLtr\2005\0805mbb 1.doc RESPONSES TO COMMENTS for the SEAWATER DESALINATION PROJECT AT H U NTI N GTO N BEACH AUGUST 17, 2005 Lead Agency: City of Huntington Beach Consultant: RBF Consulting RESPONSES TO COMMENTS for the SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH j #CH 2O01051092 S Lead Agency: CITY OF HUNTINGTON BEACH 2000 Main Street Huntington Beach, CA 92648 Contact. Mr. Ricky Ramos, Associate Planner (714) 536-5271 Consultant: RBF CONSULTING 3536 Concours, Suite 220 Ontario, CA 91764 Contact: Mr. Kevin Thomas, Environmental Services Manager (909) 941-5204 August 17, 2005 r JN 10-101409 1 - Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report TABLE OF CONTENTS TABLE OF CONTENTS PAGE 1.0 INTRODUCTION.......................................................................................................... 1 2.0 RESPONSES TO COMMENTS ................................................................................... 3 FEDERAL AGENCIES 1. United States Department of Commerce National Oceanic and Atmospheric Administration Valerie L. Chambers, Asst. Regional Administrator for Habitat Conservation ...... 3 STATE AGENCIES 2. California Coastal Commission Energy and Ocean Resources Unit TomLuster........................................................................................................ 16 3. California Department of Fish and Game Donald R. Chadwick, Habitat Conservation Supervisor ..................................... 81 4. California Department of Parks and Recreation Orange Coast District Michael M. Tope, District Superintendent .......................................................... 84 5. California Department of Transportation District 12 Robert F. Joseph, Chief, IGR/Community Planning Branch............................... 87 REGIONAL AGENCIES 6. County of Orange Resources and Development Management Department Ronald L. Tippets, Chief, Environmental Planning Division................................ 89 7. Metropolitan Water District of Southern California Laura J. Simonek, Manager, Environmental Planning Team.............................. 93 8. Southern California Association of Governments Brian Wallace, Associate Regional Planner, Intergovernmental Review.......... 115 LOCAL AGENCIES 9. City of Costa Mesa Public Services Department William J. Morris, Director of Public Services................................................... 120 10. City of Huntington Beach Environmental Board A.T. Hendricker, Chairman .............................................................................. 127 City of Huntington Beach August 17, 2005 i Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report TABLE OF CONTENTS 11. Irvine Ranch Water District Norris Brandt, P.E., Environmental Quality Manager....................................... 136 12. Municipal Water District of Orange County Richard B. Bell, P.E., Principal Engineer.......................................................... 147 13. Orange County Fair& Exposition Center Becky Bailey-Findley, CEO/General Manager................................................. 154 14. Orange County Water District Virginia Grebbien, P.E., General Manager....................................................... 159 PRIVATE ORGANIZATIONS 15. Group of Private Organizations California Coastal Protection Network California Earthcorps Elkhorn Slough Coalition Friends of the Sea Otter Friends Artists and Neighbors of Elkhorn Slough Public Citizen San Diego Baykeeper Save Our Shores Save Our Waterfront Committee Sierra Club Southern California Watershed Alliance Surfrider Foundation The Ocean Conservancy........................................................................... 162 16. Heal the Bay Craig Shuman, Staff Scientist, and Mark Gold, Executive Director .................. 186 17. Huntington Beach Tomorrow DavidGuido, President.................................................................................... 193 18. Orange County Coastkeeper Garry Brown, Executive Director...................................................................... 198 19. Pacific Institute Dr. Peter H. Gleick, President.......................................................................... 202 20. Planning and Conservation League Mindy McIntyre, Water Policy Specialist .......................................................... 208 21. Southeast Huntington Beach Neighborhood Association Steve Homer, Chairperson .............................................................................. 220 City of Huntington Beach August 17, 2005 ii Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report TABLE OF CONTENTS 22. Surfrider Foundation Huntington Beach/Seal Beach Chapter Don Schulz, Executive Committee Member..................................................... 225 23. Wader LLC WarrenFinley.................................................................................................. 234 INDIVIDUALS 24. Patricia Aurelius............................................................................................... 237 25. Frank Bradley............................................................................................... 239 26. Leslie Brian...................................................................................................... 241 27. Ric Button........................................................................................................ 244 28. Debbie DeMeulle & Edward DeMuelle............................................................. 246 29. Nancy M. Donaven.......................................................................................... 248 30. James & Cindy Douglas .................................................................................. 250 31. Patricia M. Goodman, CPA.............................................................................. 252 32. Lia A. Hernandez............................................................................................. 254 33. Lynda A. Hernandez........................................................................................ 257 34. Flossie Horgan ................................................................................................ 260 35. John D. Howell ................................................................................................ 262 36. Karen Jackle.................................................................................................... 264 ~ 37. Annie A. Jelnick............................................................................................... 267 38. Darlene Little ................................................................................................... 269 39. David Maricich................................................................................................. 271 40. Maureen Mills 273 .................................................................................................. 41. Eileen Murphy.................................................................................................. 276 42, Larry Porter..................................................................................................... 279 43. Joanne Rasmussen......................................................................................... 282 44. Rod Rasmussen.............................................................................................. 286 City of Huntington Beach August 17, 2005 iii Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report TABLE OF CONTENTS 45. John F. Scott ................................................................................................... 288 46. Robert J. Thomas............................................................................................ 291 47. Steve Tyler 294 48. Jan D. Vandersloot, MD.................................................................................... 296 49. Todd Van Etten................................................................................................ 334 50. Kris Westwell................................................................................................... 336 51. Norm Westwell ................................................................................................ 338 52. William Yarchin................................................................................................ 341 3.0 ERRATA.................................................................................................................. 343 City of Huntington Beach August 17, 2005 ii Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 1.0 INTRODUCTION 1.0 INTRODUCTION In accordance with the California Environmental Quality Act (CEQA) Guidelines and the City of Huntington Beach policies for implementing CEQA, the City of Huntington Beach has prepared the Final Recirculated Environmental Impact Report (FREIR) for the proposed Seawater Desalination Project at Huntington Beach. The Draft Recirculated EIR (DREIR) for the proposed desalination project was distributed to potential responsible and trustee agencies, interested groups, and organizations. The DREIR was made available for public review and comment for a period of 45 days. The public review period for the DREIR established by the State commenced on April 5, 2005 and ended May 19, 2005. Note that the public review period was extended to May 27, 2005 due to an electronic error on the City's website (where the document was available for electronic download). The previously circulated EIR process for the Seawater Desalination Project at Huntington Beach included public scoping in order to gather information on concerns and issues that the general public may have regarding the project and the EIR. Two public scoping meetings were held on June 6, 2001 (2:30pm and 7:15pm), at Edison Community Center in the City of Huntington Beach. In addition to the public scoping meeting process for the previously circulated EIR, numerous public hearings were conducted by the City of Huntington Beach Planning Commission (a total of five public hearings) and City Council (a total of two public hearings) to consider certification of the EIR. The City of Huntington Beach conducted a consultation meeting December 7, 2004 for the DREIR per Sections 15086 and 15088.5(d) of the CEQA Guidelines to receive agency input on potential impacts of the proposed project. The following is an excerpt from the CEQA Guidelines, Section 15132: "The Final EIR shall consist of: (a)The Draft EIR or a version of the draft. (b) Comments and recommendations received on the Draft EIR either verbatim or in summary. (c)A list of persons, organizations and public agencies commenting on the Draft EIR. (d) The responses of the Lead Agency to significant environmental points raised in the review and consultation process. (e)Any other information added by the Lead Agency." This Responses to Comments document, together with the original DREIR text (as amended by the minor corrections shown in Section 3, ERRATA), Findings of Facts, and Mitigation Monitoring and Reporting Program include all of the above required components to make up the Final EIR. Each comment letter is followed by the corresponding response(s). A response is provided for each comment raising significant environmental issues, as received by the City during the DREIR public review period. In addition, in response to several comments, the applicant has provided additional information, met with local agency staff, and proposed an additional pipeline alignment alternative to address environmental and operational concerns. It should be noted that responses to comments also resulted in various editorial clarifications and corrections to City of Huntington Beach August 17, 2005 1 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 1.0 INTRODUCTION the original DREIR text. Added or modified text is shown in Section 3, ERRATA, by underlining (example) while deleted text is shown by striking (exana&). The additional information, corrections, clarifications, and pipeline alignment alternative are not considered to substantively affect the conclusions within the DREIR. City of Huntington Beach August 17, 2005 2 FEDERAL COMMENT LETTERS i�fµT OF�Qy COMMENT 1 tJal41Tc0 Sf,'-DTI=S DSi✓Ai=cT'N8SNT OF: C7iV`1MSRDS National Oceanic and Atrnosaheric Administration NATIONAL MARINE FISHERIES SERVICE STArcs OF Southwest Region 501 West Ocean Boulevard, Suite 4200 4 png Beach, Caiifornia 90802-4213 MAY 16 2005 F/SWR4:MEM ` Mr. Ricky Ramos City of Huntington Beach Planning Department 2000 Main Street Huntington Beach, California 92648 Dear Mr. Ramos: Thank you for the opportunity to comment on the recirculated Draft Environmental Impact Report (DEIR) for the proposed"seawater desalination facility at the Huntington Beach Generating Station. The project proponent,Poseidon Resources Corporation, is proposing to construct a 50- million gallon per day(mgd) seawater desalination facility within the City of Huntington Beach. The facility will be collocated with the Huntington Beach Generating Station (HBGS). The power facility currently utilizes a seawater intake for once-through a cooling, and discharges warmed seawater to the ocean. The HGBS is currently permitted to withdraw up to 516 mgd of seawater, although the historical maximum has been 507 mgd, and average withdrawals have been much less (265 mgd from 2002 to 2003). The desalination facility will withdraw approximately 100 mgd from the cooling water discharge system as source water. Using a reverse osmosis process, the proposed facility will produce approximately 50 mgd of fresh drinking water, and 50 mgd.of concentrated brine waste water. This waste water would be returned to the HBGS cooling water discharge stream, diluted and discharged to the ocean. No modifications to the existing intake or discharge structures are proposed. Endangered Species Act The proposed project may affect species listed under the Endangered Species Act (ESA). Listed sea turtle species under the jurisdiction of NOAA's National Marine Fisheries Service (NMFS) that may be found in the vicinity of the project area include: green turtles (Chelonia inydas), loggerhead turtles (Caretta caretta), leatherback turtles (Dermochelys coriacea), and olive ridley turtles (Lepidochelys olivacea). The mechanism by which the project may affect these species is through possible entrainment at the intake structure. No sea turtles have been reported to be entrained at the Huntington Beach Generating Station; however, other coastal power plants in California have reported entrainments of green, loggerhead, and leatherback sea turtles. Under the ESA it is illegal to "take" a.listed species without a permit. The term "take" is defined as harassing,harming,hunting, pursuing, shooting, wounding, killing, trapping, t w ,r- capturing, or collecting a listed species. NTN4FS is currently processing an application submitted by the HGBS for the incidental taking of green, loggerhead, leatherback, and olive ridley turtles pursuant to section 10 of the ESA_ The Poseidon Resources Corporation may want to work with HGBS to apply for a combined section 10 pen-nit for b the incidental take of listed species entrained in the intake structure. In processing the permit, NMFS will analyze the adverse effects of entrainment on sea turtle populations. r Until this permit is processed,NNT S wiii continue to monitor the entrainment of listed species at the IHBGS through the NMFS stranding network. Marine Mammal Protection Act Many species of marine mammals may be found within the vicinity of the HBGS. However, the only species that are likely to be affected by the proposed action include the California sea lion (Zalophus californianus californianus) and the Pacific harbor seal (Phoca vitulina richardsi). Small numbers of California sea lions have been entrained in the HBGS intake structure. Although reports indicate that harbor seals have not been entrained at this location, entrainment of harbor seals has been reported at other California coastal power plants and may become entrained at this facility. Seals and sea lions are protected under the Marine Mammal Protection Act (MMPA). - Under the MMPA, it is illegal to "take" a marine mammal without prior authorization -from NMFS. "Take" is defined as harassing, huntin, capturing, or killing, or attempting to harass, hunt, capture, or kill any marine mammal. "Harassment" is defined as any act of pursuit, torment, or annoyance which has the potential to injure a marine mammal in r the wild, or has the potential to disturb a marine mammal in the wild by causing disruption of behavioral patterns, including,but not limited to, migration,breathing, nursing,breeding,feeding, or sheltering. The HBGS has submitted an application for an incidental small take permit under section I01(a)(5)(A) of the MMPA for the take of marine mammals during routine operations of the facility. NMFS.is currently processing the permit application. The Poseidon Resources Corporation may want to work with HGBS to apply for a combined small take permit for the incidental take of marine mammals entrained in the intake structure. Until the permit is issued, the number of marine mammals entrained at this location will be monitored through the NIMFS stranding network. In the event of a stranding or entrainment of a marine mammal or sea turtle on HBGS property, HGBS staff should contact Mr. Joe Cordaro, the NMFS stranding coordinator at (562) 980-4017. Magnuson-Stevens Fishery Conservation and Management Act r The proposed project is located within an area identified as Essential Fish Habitat (EFH) for various life stages of fish species managed under the Coastal Pelao-ics and the Pacific Groundfish Fishery Management Plans, as defined in Magnuson-Stevens Fishery Conservation and Management Act(MSFCMA). NMFS has evaluated the proposed project for potential adverse effects to EFH through impingement and entrainment at seawater intakes, and from discharges associated with power generating facilities and r desalination plants. NMFS expects impingement and entrainment of MSFCMA-managed r 3 species and EFH-prey species with total mortality of entrained eggs and larvae. Discharges of concentrated brine are expected to adversely impact benthic communities d in the vicinity of the outfall. Specific comments on the DEIR are provided in the attached Enclosure. Your consideration of our comments and recommendations is appreciated. Should you have any questions, or-wish to begin coordination on this project to address our concerns in a I timely manner, please contact Bob Hoffman at 562-980-4043 or via email at BobHoffman@noaa.gov. Sincerely, Valerie L. Chambers Assistant Regional Administrator for Habitat Conservation Enclosure cc: William Paznokas, California Department of Fish and Game David Woelfel, Santa Ana Regional Water Quality Control Board David Vilas,MBC Applied Environmental Sciences 1 r-- 4 ]Enclosure NNTS has reviewed the DEIR and provides the following comments and r recommendations. 1. NA/IFS supports the development of desalination facilities that will reduce impacts to trust resources from water development or ongoing diversions; and strongly recommends alternatives to large volume seawater intakes. Subsurface intakes avoid and reduce the impacts associated with impingement and entrainment. r These methods have also been recommended for desalination facilities by the f California Coastal Commission (CCC 2004). At least six currently proposed desalination facilities in California are considering using beach wells (CCC 2004). The DEIR states these alternative intake methods would be infeasible due to the volume required to meet the project purpose, and the significant cost and land requirements (Section 7.0). While it is clear that subsurface alternatives r capable of delivering 100 mgd would have substantial environmental and economic impacts, NMFS recommends that the project proponent conduct a cost- benefit analysis that would address the potential ecological benefits of other source water supply options, including decommissioning the existing intake, and account for adverse impacts to EFH. 2_ The DEIR does not adequately address the adverse effects of operating the existing intake structure. The proposal to utilize the existing power facility intake maintains the current unacceptable level of impingement and entrainment. The recent AES Huntington Beach L.L.C. Generating Station Entrainment and Impingement Study Draft Final Report indicates that entrainment at this facility is significant, and contributes to adverse cumulative effects in the Southern California Bight (MBC Applied Environmental Sciences and Tenera Environmental 2005). ' r The HBGS, like the.majority of the California power plants, is in the process of e renewing operating permits to meet new Clean Water Act section 316(b) regulations (EPA 2004). Section 316(b)requires these facilities to reduce fish and shellfish impingement mortality by 80 %to 90%, and to reduce their entrainment of fish and shellfish by 60.% to 90% from uncontrolled levels. As a collocated facility proposing to depend on the existing HBGS intake,the Poseidon Resources Corporation has taken steps to ensure the transfer of ownership of the intake structure should the power facility cease operations. The DEIR does not . present any contingency plan for the decommissioning of the intake structure, or r offer any minimi .ation measures or mitigation for impacts associated with its continued use. The project proponent should conduct analysis for scenarios where the utilization of once-through cooling systems is discontinued. The DEIR r does not address the contribution that the Poseidon Resources Corporation will make to avoid,miruirze, or mitigate for the adverse effects of impingement and entrainment at their intake. N IFS will work with Federal, State, and local r r 5 authorities, and project proponents to develop avoidance,minimization and mitigation measures. g 3. The DEIR(section 3.4) states that the project is expected to provide a new source to offset imported water supplies that are being diverted to environmental water needs in Northern California, the Mono Lake area, and the Colorado River. To the degree that the proposed facility production exceeds local demands, water dedicated to these environmental needs could become partial mitigation for the h adverse effects of the project. The DEIR does not describe how project proponents will ensure that these waters will be retained in their native waterbodies. 4. The DEIR does not adequately address impingement and entrainment at the proposed increased intake levels, or offer any minimization or mitigation measures for adverse impacts expected from increasing the intake volume. According to Appendix S of the DEIR, the 20-year operational history suggests that much lower intake flows of approximately 127 mgd or 254 mgd, each account for about 50% of the power facility's operational time. The average withdrawal from 2002 to 2003 was 265 mgd. If operation of the desalination facility increased the volume of seawater taken in to the maximum permitted level of 516 mgd, impingement and entrainment would also increase. The DEIR(page 5.10-40 and T-7) evaluated entrainment at intake flows of 127 mgd, not at the actual average or proposed intake levels. Furthermore,the DEIR evaluated entrainment using an observed mortality of less than 100%. Based on their review of available studies, the U.S. Environinental Protection Agency assumes that there is zero survival of organisms entrained in cooling water intake structures, though some industry stakeholders dispute their assumption (EPA 2004). Due to the mechanical,pressure,temperature, and ' chemical conditions likely to be experienced by entrained organisms during operations,NIVIFS makes the same assumption for other facilities using flow through systems (Thompson 2004). i5. Tlie DEIR"does not adequately address the potential effects of the discharge on benthic communities. The most concentrated discharge of 55.4 ppt (about 60% higher than the local mean salinity of 33.5 ppt)would occur at low intake volumes, as when only one power generation unit was operating. As noted above, these low intake flows account for about 50% of the power facility's operational k time. Models suggest that under these conditions, high salinities in the water column would occur near the discharge outfall, and dissipate to within approximately 10% of ambient levels within approximately 150 feet from the outfall. Salinities within 10% of ambient levels are expected to fall within normal variability, and are not expected to have long-term adverse effects. High salinity levels near the outfall are potentially fatal to fish and other species,however, rapid mixing in the water column is expected to minimize effects on the pelagic community. r- r= 6 r- Because concentrated brine discharges are more dense than seawater, persistent saline wedges may form along the bottom. Benthic organisms within the area of higher salinity are expected to be adversely affected. Modification or loss of this habitat by saline discharges may reduce diversity and abundance, and shi$the �( benthic community toward more saline tolerant species. Should this result, this is considered an adverse of act to E�17111, and the project proponent should develop a mitigation and monitoring plan, to compensate for the loss of this habitat. s- Literature Cited r CCC (California Coastal Commission). 2004. Seawater Desalination and the California Coastal Act. California Coastal Commission. 99 pages. Available at: http://www.coastal.ca.gov/energy/14a-3-2004-desal'mation.pdf. r MBC Applied Environmental Sciences and Tenera Environmental. 2005. AES Huntington Beach L.L.C. Generating Station Entrainment and Impingement r Study; Draft Final Report. Prepared for AES Huntington Beach L.L.C. February 2005. r EPA(Environmental Protection Agency). 2004. National Pollutant Discharge Elimination System—Final Regulations To Establish Requirements for Cooling Water Intake Structures at Phase II Existing Facilities;Final Rule. Federal r F Register Volume 69, Number 131,pages 41576-41693. July 9, 2004. Thompson,N.B. 2004. Potential impacts of liquid natural gas processing facilities on fishery organisms in the Gulf of Mexico. NOAA/NMFS Southeast Fisheries Science Center Memorandum. Available at: http://sero.nn-ifs.noaa.gov/ac/lnAlg_ws—memo.pdf r r r r r r r Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS 1 Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 1 United States Department of Commerce National Oceanic and Atmospheric Administration Valerie L. Chambers, Assistant Regional Administrator for Habitat Conservation 1 a. These introductory paragraphs provide a summary of the project description, and do not require a response. 1 b. Comment 1 j states that the National Marine Fisheries Service (NMFS) assumes 100 percent mortality of entrained organisms at HBGS due to the mechanical, temperature, pressure, and chemical conditions of the HBGS cooling water system. Since the proposed project would not alter the operations of the HBGS (see pages 3-20 and 3-21 of the DREIR) (i.e. no increase in the volume of HBGS cooling water intake would occur due to project implementation), the desalination project would not result in significant entrainment impacts. Thus, the project would not contribute to the incidental take of sensitive turtle species, and no Section 10 permit for the project is required. 1 c. Refer to Response 1 b, above. 1d. This comment addresses two NMFS concerns - 1) Entrainment (marine life drawn into the intake HBGS's cooling water intake) and impingement (marine life trapped on the HBGS's filter screens) by HBGS; and 2) potentially adverse effect of elevated salinity on benthic communities within the vicinity of the outfall, and the effect of this on Essential Fish Habitat (EFH). 1) Entrainment and impingement - The DREIR points out that entrainment and impingement are -currently permitted for the once-through cooling water system of the HBGS, that the proposed desalination facility does not directly take seawater from the ocean, and that withdrawal of feedwater for desalination is from the HBGS cooling-water discharge and not subject to intake regulation under the Federal Clean Water Act (316b). Further, operation of the desalination facility does not in any alter HBGS cooling water intake operations. Appendix T (Intake Effects Assessment) provides a comprehensive analysis of entrainment and impingement by the proposed seawater desalination facility. This study was undertaken to ensure that the DREIR would contain a careful, up-to-date analysis of intake impingement and entrainment at the proposed facility. The assumption of the NPDES 316b permit (which is required for operation of the HBGS cooling water intake system) is that 100% of the entrained organisms do not survive through the HBGS cooling system. However, in response to City of Huntington Beach City Council direction that a certain fraction of the entrained organisms may in fact survive the transit and that the desalination facility would in fact kill these survivors required that additional testing be done so that this issue could be clarified for purposes of the DREIR. City of Huntington Beach August 17, 2005 9 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Appendix T models the expected rate of larval loss due to entrainment from the source water attributable to HBGS's cooling water intake system.This was done by comparing the estimated density of larvae in the source water and the number taken in by the cooling water intake. In summary, HBGS cooling intake would reduce the number of larvae in the source water by 0.33% and the proposed desalination facility would, at 127 MGD, diminish source water larval density by an additional 0.02%, which is over 10-times less than the HBGS's effect. This is not a significant effect; particularly in view of the 316b permit assumption of 100% mortality of the organisms entrained by the cooling water intake. Regarding the species that are entrained, Appendix T shows that six fish r taxa and a grouping of unidentified larvae of other fish species comprise 97 percent of all the fish larvae present in the cooling water flows. These taxa include gobies, blennies, croakers, northern anchovy, garibaldi, r unidentified fish larvae and silversides. Larva of species having high commercial and recreational importance and having relevance therefore to maintenance of EFH (e.g., California halibut and rockfishes) are very uncommon in the HBGS cooling water flow. In addition, as stated in the DREIR, the desalination facility will not have a direct ocean intake system; thereby it will not cause any impingement losses above the quantity taken in by the HBGS cooling water inflow. Refer to responses 1j and 2u below. 2) Desalination Byproduct Discharge, Benthic Communities, and Essential Fish Habitat - Under the Magnuson-Stevens Act, EFH is defined as the waters and substrate necessary [i.e., to support a sustainable fishery and the managed species contribution to a healthy ecosystem] to fish for spawning, breeding, or growth to maturity. EFH refers to federally managed fish species for which a fishery management plan has been r developed. In the EFH definition "waters" refers to aquatic areas and j, their associated physical, chemical, and biological properties that are used by fish and may include aquatic areas historically used by fish where appropriate, while "substrate" includes sediment, hard bottom, and structures underlying the waters, and associated biological communities. Also, as used in the comment, this response to comment, and with r reference to EFH, the term "adverse effect" means any impact which reduces quality and/ or quantity of EFH, including alterations of the waters or substrate and loss of, or injury to benthic organisms, prey species and their habitat, and other ecosystem components.) r The DREIR and both Appendices C (Hydrodynamic Modeling Report) and S (Marine Biological Considerations) detail the results of models for the dispersal and mixing of the combined HBGS and desalination facility discharge. Analyses of the potential biological effects of a region of hypersalinity in the discharge flow plume are contained in both the DREIR and Appendix S. r City of Huntington Beach August 17, 2005 10 I Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS As it pertains to EFH, this comment expresses the concern that salinity levels within the discharge plume, in particular its benthic zone, will be sufficiently high to exclude all organisms, thereby adversely affecting prey abundances and feeding area within the EFH. Answering this comment requires a brief review of model results. Appendix C reports that the 20-year history of the HBGS cooling water flow rate is bimodal. One mode, termed low flow mode, is 127 MGD. The other flow mode average is 254 MGD. For the modeling of the discharge salinity and its dispersal, the two HBGS flow modes were coupled with two different combinations of receiving water conditions (i.e., combinations of variables that would either promote or lessen mixing of the combined discharge with the ocean water). The low flow, "worst-case scenario" combined a low plant flow (127 MGD, which would produce a much more saline discharge) with sub-optimal ocean mixing conditions, and assumed these would remain in place for 30 days. As stated in the DREIR and Appendices C and S, plant flow rate and ocean mixing conditions are independent factors and the probability of the simultaneous co-occurrence of both a low flow (low power demand) and low receiving water mixing potential (i.e., very calm water) is very low. Moreover, the probability that both states would persist for 30 days, the time used to run the model, is far less than 1%. Nevertheless, modeling of the "worst case, low flow scenario" and assuming these conditions remained in place for 30 days demonstrates the most extreme conditions for salinity that could possibly occur in the receiving water. Appendix C contrasts the rare and extreme worst case low flow scenario with the more common occurrences of average flow or low flow and "average" conditions for ocean mixing and these findings are summarized in the DREIR. The following table provides a summary of the modeled salinities, based on different historic flow rates, for midwater (M) and bottom (B) under different conditions: HBGS o. Discharge Tower Isom Salinity Area flow ' -Time Rate Occurrence (MGD) Salinities Salinities Midwater Bottom Midwater Bottom +10% >+10% (ppt) (ppt) (ppt) (Ppt) (acres) (acres) Midwater Bottom Historic 127 42-48 55 48 39 37 15 3.7 (1980- >254 52-58 42 39 35 35 0.13 0.13 2000) — Post- 127 6-9 55 48 38 37 Retooling — (2000- >254 91-94 43 39 35 35 2002) ppt=parts per thousand This shows that low flow and average ocean mixing conditions, which have a 42-48% occurrence, will result in higher midwater and bottom salinities at the discharge than will the higher flow rates. Also, City of Huntington Beach August 17, 2005 11 r Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS calculations (based on Jenkins and Wasyl, 2005 Table ES-2, Generalized Salinity Plume) indicate that at low flow (127 MGD) the approximate area of the discharge plume having a salinity greater than 10% above ambient (33.5 ppt) is 15 acres on the bottom and 3.7 acres in midwater. At average flow (254 MGD) the area having salinity greater than 10% of ambient is about 0.1 acres both on the bottom and in midwater. Appendix C also points out that, since the recent retro-fit of its generating system, the HBGS has recorded higher flow rates; low flow now occurs less than 10% of the time (see above table). Assuming this trend continues, the benthic area of the discharge field experiencing elevated salinity will be reduced. Thus, a multi-part answer is needed to address concerns about EFH expressed by this comment. First, the models show that low flow conditions that will cause the greatest salinity load on the habitat would occur 42-48% of the time based on the historic record of HBGS flow and much less under the recent history of HBGS cooling water flow rates. Second, the hypersaline conditions potentially inimical for benthic ,. organisms (i.e., 38-40 ppt) occur in a small area (15 acres) under low flow conditions and an even smaller area (2 acres) at average flow. The habitat into which this discharge flows has a sandy, soft bottom and an extended and contiguous area of no less than 6,000 acres and has no areas of special biological significance. Third, under average flow and receiving water conditions and for most of the combinations of low flow and ocean mixing conditions that can be expected to occur, benthic salinities beginning within a few meters of the base of the discharge tower will be within a range that will allow some of the organisms living there w presently to remain. f, V Another possibility, as stated in the DREIR, is that organisms currently N living in estuaries and bays (and which, for this reason, tolerate a greater range of habitat salinity) could potentially move into the small benthic area of elevated salinity adjacent to the discharge tower. These organisms would be the ecological equivalents of the native benthic r infauna, which means that although the species composition might be changed in this area of the discharge, it would not be devoid of life and would remain an effective feeding resource within the EFH. Fishes and other pelagic organisms that contact the elevated salinity area would r either swim or "drift" through it in a short enough period of time that they would not-be affected. Accordingly, under all possibilities discussed and analyzed in the DREIR, increased salinity loads of the combined project and HBGS discharge will not result in a significant impact or adverse effect on EFH where there is no potential impairment of EFH functions caused by increased salinity. 1 e. This text provides a conclusion to this portion of the comment letter, and does not r require a response. City of Huntington Beach August 17, 2005 12 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS if. As stated within the DREIR, alternative source water intake options were determined to be infeasible for a 50 MGD facility since the environmental impacts associated with these alternatives would be greater than the proposed project. Increased land use, aesthetic, recreational, and biological impacts would result from implementation of alternative intake technologies such as beach wells, infiltration galleries, and/or seabed filtration systems. A comparison between the proposed project and these alternative intake methods (including the benefits of decommissioning the HBGS intake) would not be applicable in this case, since implementation of an alternative intake does not necessarily mean that HBGS would decommission its intake. Refer to responses 2ai, 2ak, and 2al, below. ' 1g. In the event that the project applicant were to assume ownership of the existing HBGS intake and outfall for any reason, the ownership transfer would be treated as a separate project. The transfer would be subject to applicable CEQA and regulatory agency permit requirements. Avoidance, minimization, and mitigation measures for such a transfer would occur at that time. In addition, future potential operating scenarios of HBGS are speculative at this point. Refer to Response 2u, below for a discussion regarding the AES Huntington Beach LLC, Generating Station Entrainment and Impingement Study prepared by the California Energy Commission (CEC). 1 h. It is not anticipated that proposed desalinated water production would exceed the water supply demands of Orange County. All product water is expected to remain within the County. The DREIR states that increasing regulatory activity and environmental needs in Northern California, Colorado River and in the Mono Lake area have reduced the amount of water available to Southern California. Refer to Response 7r, below. In the event that Orange County water purveyors decide to use water produced by the proposed project to replace reliance on Colorado River or Northern California water supplies, ecosystem and biologic resource benefits may occur in those areas of origin. Moreover, it is important to note that this benefit is not included as a mitigation measure within the DREIR, and specific mechanism for implementation is not required. 1 i. The proposed project would not increase the volume of water flowing through the HBGS. The project would divert water from the HBGS cooling water system as part of HBGS' normal operations. Also refer to Response 1 b, above. 1j. Comment noted. The Intake Effects Assessment, which analyzed entrainment impacts, was prepared specifically to address concerns from commenters on the originally circulated EIR who disputed the assumption of 100 percent entrainment mortality recommended by the U.S. Environmental Protection Agency (USEPA). Under either assumption (100 percent mortality or assuming that a small _ percentage of organisms survive the once-through cooling process), impacts in ' regards to entrainment were found to be less than significant as a result of the proposed project. The California Coastal Commission staff comments on the originally circulated DEIR consistently requested information on the potential for entrainment/impingement impacts as a result of operation of the desalination project, distinct from the HBGS effects. The Huntington Beach City Council decision not to certify the originally circulated DEIR was influenced by these arguments in its request for more data on this issue. The California Coastal City of Huntington Beach August 17, 2005 13 - r Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Commission staff letter on the DREIR now agrees with the commenter position that states the HBGS is responsible for 100% of the entrainment/impingement r under the Clean Water Act. Refer to response 2w below. 1 k. The DREIR reports findings about the dispersal and dilution of the discharge based on computational models (Appendix C, HYDRODYNAMIC MODELING `— REPORT) and a study examining discharge salinity effects on the marine biota (Appendix S, MARINE BIOLOGICAL CONSIDERATIONS). The models demonstrate the occurrence of the salt wedge and detail how bottom mid-water plume salinities differ with distance from the discharge tower out to about 500 meters (m)where bottom and mid-depth salinities become nearly the same. r As reported in the DREIR, the models show that low flow conditions, which will cause the greatest salinity changes in the habitat, will occur 42-48% of the time, based on the historic record of plant flow, but much less frequently under the r recent history of HBGS cooling water flow rates. The habitat around the HBGS discharge tower has a sandy, soft bottom and is part of an extended and contiguous coastal area with an area no less than 6,000 acres. Only a very small area of this contiguous habitat will experience a small salinity increase. As reported in Appendix S and in the DREIR, salinity levels of 38 - 40 ppt approach the upper tolerance point of many marine organisms. Under the low flow (127 MGD) scenario, salinities this high or higher occur around the discharge pipe out to nearly 150 m (area about 15 acres). Under the average flow (254 MGD) conditions, salinities this high occur only in the core of the discharge pipe (<2 acres). Thus, under average flow and.receiving water mixing conditions and for some combinations of low flow and ocean mixing conditions that can be expected to occur, benthic salinities at all depths beginning very near the base of the discharge tower would be within a range where some of the organisms living there presently could in fact remain. Another possibility, as stated in the DREIR, is that organisms that currently live in estuaries and bays (and which, for this reason, tolerate a greater range of habitat salinity) could potentially move into the small benthic area of elevated salinity adjacent to the discharge tower. These organisms would be the ecological equivalents of the native benthic infauna, which means that although the species composition might be changed in the immediate vicinity of the discharge, it would not be devoid of life and would remain an effective feeding resource within the EFH. Fishes and other pelagic organisms that contact the elevated salinity area would either swim or "drift" through it in a short enough period of time that they would not be affected. Also, refer to response 1 d above. r Because increased salinity of the HBGS flow will not cause a potential impairment of EFH functions, the project will not result in a significant impact or adverse effect on EFH. As the commentator is aware, the federal government regulates ocean fishing from three miles to two hundred miles offshore whereas California has jurisdiction from the shoreline to three miles seaward. The project does not involve a federal action or federal waters and a response to EFH conservation recommendations is not mandated by the Magnuson-Stevens Act. The City of Huntington Beach 14 August 17, 2005 ` Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS comment, however, is noted with the hopes that the summarized response information and detailed information of the DREIR will assist NOAA/NMFS with their continued management of fisheries and EFH. 11. This text provides citations for literature utilized in preparing the comment letter. No response is necessary. City of Huntington Beach August 17, 2005 '' 15 r-- STATE COMMENT LETTERS r-- ;Teri:OF 0ALIPONNIA Yid K2501111CRS AGPIVCY i COMMENT 2 " CALIFORNIA COASTAL COMMISSION ...M I11 ANUI N t-11. r.\ •1+1.,1. ::1'1 � 1 f•111 m TN If— 14i51 L1AA ialil BUJ L.11111 May 26, 2005 Mr. Ricky Ramos, Planning Department City of Huntington Beach 2000 Main Street !-luntington Beach, CA 92648 RE: Draft Recirculated Environmental Impact Report (DREIR)No.00-02—Proposed Poseidon Resources Corporation Desalination Facility(SCH 42001051092) Dear Mr. Ramos: Thank you for the opportunity to comment on the above-referenced document. The proposed project would involve construction..and operation of a desalination.facility on the site of the AES Huntington Beach power plant. It would produce up to 50 million gallons of drinking water per day using seawater drawn from the power plant's cooling system. It would be the largest of its kind in the U.S. and several times larger than any other successfully operating seawater desalination facility in the country. Our comments in this letter focus primarily on the DREIR's use for CEQA purposes. We will a likely have additional and more detailed continents and questions about the proposed project during its coastal development permit review. The proposed project is within the coastal zone jurisdiction of both the City and the Coastal Commission,so it will require a coastal development permit from each. It is also within the Coastal Commission's appeal jurisdiction, so decisions by the City regarding its coastal development permit may be appealed to the Commission. Gencrai Comments 1) There are numerous significant shortcomings in the DRER that make it inadequate for purposes of CEQA review, Basic information about characteristics of several existing conditions seems to be in error,and as a result,many of the document's key analyses are likely inaccurate or misleading_ Much of the document either mischaracterszes the 1 relationship between the existing power plant and the proposed desalination facility or depicts the relationship inconsistently. The document includes several descriptions and analyses that are highly selective in their use of references and data so as to portray the proposed project as causing fewer adverse environmental effects than it is actually likely to cause. Substantial portions of the DREIR read as a justification for the proposed project rather than a reasoned, arms-length evaluation of its likely adverse effects and the measures 1 needed to address those effects. Additionally,the document does not provide adequate explanation or justification of the proposed project's purposes or why it must produce 50 million gallons per day of drinking water, especially when some,if not all, of that supply r Comments on DREIR for Proposed Desalination Facility-SCH#12 001 051 092 May 26, 2005 r Page 2 of 17 could be available from water sources that are likely Jess cost)y,have fewer adverse ,- envirDnnmenta) impacts, and represent a feasible and more appropriate part of the region's water supply portfolio. These and other concerns are discussed in more detail in the comments below. r- Due to the concerns expressed in this letter and in our previous comment letters,we recommend the DREM be thoroughly revised and then recirculated for additional review, We particularly recommend the document be revised so that the proposed project is r evaluated both as a facility that would operate at times independently of the power plant and as one that would operate at times in conjunction with the power plant, This would more accurately reflect the way it would likely operate during its expected useful life and would r better reflect CEQA's requirements to address likely project-specific impacts. This approach C would also be consistent with the approach suggested in the October 2003 Water Desalination Findings and Recommendations report by the state's Desalination Task Force. r- We note that this report is one of those ased in a highly selective manner by the DREIR, and we recommend that the next revision of the DREIR incorporate the complete set of findings and recommendations from that report that are applicable to this proposed project. r Consideration of Comments Provided Previously 2) Coastal Commission staff provided extensive comments during the proposed project's it previous CEQA review during 2001-2003. It appears that the DREIR addressed some,but not all, of the concerns expressed in those comment letters. The DREIR states that comments provided during that previous review were considered and that revisions were made,but it does not state how those previous comments were addressed. It is evident from reviewing those past comments and comparing them with those in ioday's letter that several significant issues have not yet been adequately addressed in the current DREIR. It is also r evident that we have identified consistent problems and concerns throughout both CEQA processes about the adequacy of the reviews. r Because it is unclear whether those previously-submitted comments will be flusher addressed during this current review,we are incorporating those earlier comments by reference. They are included in the following letters- r- • June 14,2001: comments on Notice of Preparation. November 4, 2002: comments on Draft EIR. • May 8. 2003: comments on City's Response to Comments. r • July 7, 2003: letter to City's Planning Commissioners regarding relationship between CEQA and the Coastal Act,and the adequacy of the EIR. • December 8. 2003: letter to City's Planning Director responding to several misstatements_ '- made about the CEQA baseline,the City's Local Coastal Plan, and the Coastal Act These letters will be provided as e-mail_attachments along with this letter. The comments r provided herein are to supplement those provided.previously and to address our main concerns about this most recent DREM. r r r Comments on DREIR far Proposed Desalination Facility—SCH#2001051092 May 26, 2005 Page 3 of 17 Jurisdiction 3)- As noted above, the proposed project is within the coastal zone and under the coastal development pemiit jurisdiction of both the City of Huntington Beach and the Coastal Commission;however,the DREIR does not accurately reflect the review required by each. Please revise relevant sections of the document(e.g., Section 3.6—Agreements,Permits, and e Approvals Needed; Section 5.1 —Land Use/Relevant Planning; Section 5.10—Ocean Water Quality and Marine Biologicah.Resources; etc.)to include the permit required frorn the Coastal Commission and to describe applicable Coastal Act requirements. Project Need and Objectives 4) In its description of the need for the project (Section 3A),the DREIR cites the Draft 2004 California Water Plan as recognizing the benefits of seawater desalination. We note that the DREIR uses a highly selective reading of that plan to create a sense of support for the proposed project. While recogair_ing that the Water Plan is still in draft:foam,we find that a more complete reading shows it includes a number of concerns about seawater desalination, f cites the full set of findings and recommendations of the state's Desalination Task Force, and expresses the need to prioritize implementation of those Task Force recommendations as part of desalination in California. We recommend therefore either that the DRE1R be revised to delete references to this still draft Water Plan or that it fully incorporate the other concerns and considerations included in the rest of the document. 5) The DREIR describes six primary project objectives(e.g.,on page 3-45). Of these,portions of at Ieast two of the objectives are of questionable validity since they appear to either inappropriately limit feasible and less damaging project alternatives or provide an g unsubstantiated boost to the proposed project's benefits. The first objective is to"provide a reliable local source of potable water to Orange County that is sustainable independent of climatic sources and the availability of imported water supplies or local groundwater supplies". The DR M errs in not considering"local groundwater supplies"a"reliable local source"of water. Most water agencies, including,for instance,the Metropolitan Water District,categorize groundwater as a local and reliable source. Even if groundwater supplies are contaminated or have high salinity levels,they can serve as reliable local water sources through the use of the same technology proposed for use by this proposed desalination project,and are often available at much less cost and with fewer adverse environmental effects than desalted seawater. This project objective should therefore be changed and a new alternatives analysis be developed that considers local groundwater supplies Lobe pan of the portfolio of reliable local water sources. The fifth of the objectives is to"create ecosystem and biologic resources benefits that may accrue due to decreased pressures on existing water resources and reduced contamination within receiving waters". It is inappropriate to apply this objective to this proposed project ; for at least two reasons. First,the proposed project itself does not necessarily meet this objective,since as shown in several comments below,it is likely to result in substantially greater adverse ecosystem and biologic impacts than are described in the DREIR. Second, i Comments on DREIR for Proposed Desalination Faciliry—SCH#2001051092 May 26, 20D5 Page 4 of 17 there is no way to measure whether the proposed project would actually achieve this r- objective. since the DREIR describes no mechanism to ensure whether the project,if built, would result in decreased pressures on existing water resources or reduced contamination. In actuality,the proposed project is more likely to increase pressures on existing water r resources and cause increased contamination in receiving waters due to it resulting in more growth and use of fewer conservation measures in the region. We believe the intent of this objective is to suggest that the proposed desalination facility would allow more water to stay ; in the Colorado River, the Central Vailev, or other water source used by the local area; however, unless the next revision of the DREIR can describe a particular mechanism to ensure this happens, we recommend this objective be dropped from the DREIR and its analyses. r Relationship between operating characteristics of the power plant and the proposed facility r 6) Several key analyses in the DREIR are based on an incomplete or inaccurate description of The relationship between the proposed"desalination facility and the power plant. The DREIR is based largely on the assumption that the proposed project will use only seawater that r passes through the power plant condensers and will not require any additional water beyond what is used by the power plant For several reasons discussed below,this assumption is likely incorrect, and the analyses in the DR M related to water use need to be revised. In r reality, water use by the co-located power plant and proposed desalination facility is likely to be substantially higher than water used just by the power plant. For CBQA purposes,the effects of the proposed project should include those caused by the proposed desalination facility operating on its own. We therefore recommend the DREIR be revised throughout to describe the characteristics and effects of the proposed project operating on its own along with analyses of how it would operate in association with the power plant. This letter includes a number of examples of the analyses that need to be revised,such as the following: r a) Incorrect data and assumptions: The analyses in the DREIR use several erroneous or incomplete characterizations of existing conditions at the proposed project site,including. r • Seawater temperatures: Several DREIR analyses and associated reports(e.g.,Marine Biological Considerations Related to.the Reverse Osmosis Desalination Project at the Applied Energy y Sources Huntington Beach Generation Station,August 2004)are apparently based on seawater temperatures at the power plant intake ranging from 12 to 190 C(approximately 54 to 660 F). However,the California Energy Commission's k _ analysis done in 2001 cited information provided by the power plant owner showing a somewhat higher range of ocean water temperatures at the intake. These higher r temperatures could create very different conditions and effects than those described in the DREIR. Some of these changes are described in more detail below. We therefore recommend the relevant analyses be revised to better substantiate the actual r- temperature range and base the expected effects on that range. " r r - r i Comments on DREIR for Proposed Desalination Facility-SCH#2001051092 May 26, 2005 Page 5 of 17 Power plant pump capacity and operations: The existing power plant has six ptunps with capacities of 63.4 million gallons per day and two pumps with capacities of 66.7 million gallons per day. The DREIR uses a puunping rate of 127 million gallons per day as its "reasonable worst-case scenario" based on a minimum of two piunps operating at any given time. This does not appropriately recognize the potential that the power plant may at times operate no pumps or perhaps only one pump. It is reasonaviy foresceable that the power plant could shut down or be in standby mode due to maintenance needs or lack of electricity demand, and during those times could use much less than the 127 - million gallons per day. These same conditions could result from implementing the recent U.S. EPA rule regarding entrainment and impingement at thermal power plants, since the power plant may ne-d to decrease its entrainment effects by pumping less water at times or may need to substantially change its existing cooling system_ We therefore recommend the analyses be revised to reflect the likelihood that the power plant's water use during some parts of the proposed desalination facility's operating life will be either zero or less than 127 million gallons per day. This change is additionally appropriate since the DREIR does not sufficiently address the proposed project's stated need to produce 50 million gallons per day of drinking water. The DREIR therefore needs to assess a feasible and smaller proposed desalination facility having available to it less than 127 million gallons per day of cooling water from power plant operations. 9 Cumulative im acts: The DREIR does not adequately address cumulative impacts 4 Y P associated with the proposed project and its environmental setting. For example,it ' does not address at all the effects associated with impairment of nearby affected ocean and estuarine waters pursuant to Clean Water Act Section 303(d);and only M partially addresses the numerous intakes,outfalls, and discharges of all types in the area affected by the proposed project. It also does not fully address the decline in the local and regional fishery caused in part by the multiple adverse effects occurring in the ocean waters. These aspects of the existing environmental setting need to be incorporated into a further revised DREIR, b) Operating scenarios:The DREM describes at leist two different and contradictory ' scenarios for how the proposed facility would operate_ It first states that the proposed facility would operate full-time(24 hours per day, 365 days per year),but then states, conversely,that it wotild try to take advantage of off-peak electrical pricing by not operating during peal..hours. ' These two scenarios would result\in very different characteristics for the facility and could have significantly different effects on coastal resources,project and produced water n ' costs, and facility operations. The first scenario,for example, does not adequately recognize the wide variations in power plant operations over the course of a given day or long term based on market demand,the need for regular cooling system heat treatments, changes in regulatory requiremcnis,or other factors that may result in fuIl or partial r Comments on DREIR for Proposed Desalinarion Facility-SCH 42001051092 May 26, 2005 F_ Page 6 of 17 shutdown or standby of the power plant. Additionally, desalination facilities using r- reverse osmosis membranes tend to operate more efficiently, require less maintenance, and last longer when they are operated continually rather than in an on/off fashion. It is not clear from the DREIR whether these characteristics are evaluated. We therefore recommend that the DREIR be revised to clarify the operating methods the proposed facility intends to use and revise the applicable analyses accordingly(e.g.,those related to costs, energy use, water use, maintenance requirements, etc.). The revised analyses n should cite specific operating characteristics of the power plant and condition of'Me r operating agreement between the power plant and the proposed desalination facility and should reflect the likely effects of those conditions. r- c) Cooling water use and energy demand:The DREIR states that the proposed 50 million gallon per day desalination facility would use about 30 to 35 megawatt-hours of electricity(or about 720 to 940 megawatt-hours per day). Combined-cycle power plants such as HBGS using a once-through cooling system require about 15,000 gallons of cooling water per megawatt-hour of electricity generated. Therefore,the desalination facility's electrical demand would require roughly 450,000 to 500,000 gallons per hour of f tooting water,or about I 0 to 12 million gallons per day. While some of this water would likely be the same as that withdrawn from the cooling system for desalination use,the 0 . DREIR should assess the effects associated with any additional water use. r Additionally, it is not clear from the DREIR whether the stated energy demand for the desalinatior► facility includes the energy needed to pump the produced water into the regional distribution system. Because the proposed desalination facility would be at sea r- level,it may require substantial energy to pump the water uphill into the distribution lines. The DREIR.should incorporate this energy demand and costs into its evaluations. d) Cooling water use and water temperature:Reverse osmosis membranes are designed to be used in up to a particular water temperature (e.g.,up.to 95'F),with their most efficient operating temperature generally somewhat lower. The power plant's cooling r water may at times exit the condensers at higher temperatures than optimal or usable for the membranes;therefore,the water used by the desalination facility may need to be cooled by using additional seawater that has been drawn into the power plant intake but has bypassed the condensers. As a result,the desalination facility may end up using r much more than the expected 100 million gallons per day of water, and more than would otherwise be used by the power plant. These same characteristics would also result in the proposed desalination facility causing entrainment that would not otherwise be caused by p + the power plant. Additionally,and as noted above,the DREIR7s analyses appear to be i based on lower ambient ocean water temperatures than may actually exist at the site. These analyses should therefore be revised to incorporate the design operating ,- temperatures of the membranes and the desalination process,their most efficient operating temperatures, and whether additional water would be needed to cool the desalination source water to usable temperatures. It should also describe any additional entrainment effects that would be associated with this additional water use. i r- ti r i, k' ro Sxb „w Cornments on DREIR for Proposed Desalination Facility—SCH#2001051092 ¢: May 26, 2005 Page 7 of 17 e) Operational characteristics and energy use: CEQA Section 15126.4 requires that EIRs consider the implications a proposed project may have on energy ttse. It further requires an energy conservation analysis that considers costs along with other measures of feasibility. Among the goals of such review is to decrease reliance on natural gas and oil, _ and increase reliance on renewable energy sources. Further, Coastal Act Section 30253(4)requires that new development minimize energy consumption. Several recent wadies—;ur example, the PaciSc L•tstitute's Wzrr--Not,Want_Not: The Potential for Urban Water Conservation in California(November 2003), and the Planning q -- and Conservation League's Investment Strategy for California Water(November 2003)— conclude that seawater desalination is relatively costly and energy-inefficient,particularly when compared with other available sources of water such as conservation and recycling, brackish water desalination,and even many of the state's water import infrastructure projects. The DREIR should be revised to evaluate whether the proposed project supports the requirements cited and how it fits into California's increasing emphasis on energy efficiency and conservation. f) Costs:The DREIR does not describe the cost of the water to be produced. Because cost is a consideration of determining the feasibility of proposed projects,mitigation measures,and alternatives,it is a necessary part of environmental review. Further r revisions of the document should include discussion of anticipated costs and the basis for those costs, and should then apply those costs to determine the feasibility of project alternatives and mitigation measures. g) Status of power plan� t a royals,permits,and contracts: The DREIR does not properly assess the short-,medium-,and long-term operational changes likely to occur in the power plant operations and how those changes may affect the proposed desalination facility. These changes include everything from daily variations in electrical demand, upcoming changes to existing energy contracts, and measures that may be required to minimize the cooling system's entrainment and impingement effects,including the potential to switch to alternative cooling methods that may not provide the same benefits for desalination (e.g.,dry cooling,closed loop cooling,recycled water cooling, etc.). These reasonably foreseeable changes could result from any of the following: • The power plant's Units 3 and 4 are operating under a I0=year approval from the S California Energy Commission(expires in 2011). • The power plant's NPDES permit is up for renewal every five years. The next renewal will-require review to ensure conformity to a recent rule change by the U.S. EPA(described in more detail below),and may result in substantial changes to the power plant's structures, operations,or mitigation requirements. • The DREIR describes several energy contracts with remaining terms of less than a year,three years,or until 201 S. • The power plant's report on its future development plans, submitted to the Energy Commission in November 2004, discusses various alternatives,none of which mentions an on-site desalination facility or the effects of such a facility. i Comments on DREIR for Proposed Desalination Facility-SCH#2001051092 May 26, 2005 Page 8 of 17 • The agreement between the project proponent and the power plant operator runs for r_ 38 years. The DREIR does not describe in sufficient detail the conditions of the agreement, allowable ways to modify the agreement, and other elements That could result in substantial changes to how either of the two facilities operates. r- All of these suggest that the DREIR analyses should incorporate several substantial and $ + - reasonably foreseeable changes and alternatives that would affect the proposed desalination facility. We recommend the DREIR be revised to fully describe these various permits and agreements and to assess the effects of likely changes. _ Maeane Biological Resources-Effects of the Proposed Desalination Facility Intake r - i 7) Incorrect assumptions and incomplete data:As noted above, the proposed desalination facility would likely be associated with direct, indirect,and cumulative impacts caused by �- withdrawing substantially more water Than needed by The power plant. The DREIR inappropriately separates the operations and impacts of the power plant from those of the proposed desalination facility,creating a false dichotomy between the two. Many of the r- revisions requested in other parts of this letter will require that analyses related to marine biological resources also be revised-for example, analyses showing the proposed desalination facility drawing in water that would not otherwise be drawn in by the.power planipperating on its own would result in different effects on marine organisms. Further,the r DREIR's marine biology analyses rely in some cases on highly selective references from various documents,or uses documents and studies based on data that are several years or decades old and not necessarily applicable to current envirorunental conditions offshore of -Huntington Beach or that use out-of-date sampling and study methods. t i One example of the highly selective references is the DREIR's citation of a draft paper on r feedwater intake issues issued during the California Desalination Task Force process. This draft paper includes a statement that co-located desalinarion facilities would result in no additional entrainment or impingement. The DREIR should be revised to instead use more appropriate references,including the Desalination Task Force's final report,Watzr Desalination Findings and Recommendations(October 2003) and the Coastal Commission's report,Seawater Desalination and the California Coastal Act(March 2004). Both these reports recognize the importance of case-by-case and site-by-site consideration of such `^ impacts and note that co-located desalination facilities may,in fact,cause adverse effects in addition to those caused by the power plant. Another selectively excluded reference, discussed immediately below,is the entrainment study recently completed pursuani to Energy Commission requirernenis. 8) Effects Associated with the Intake.The DREIR states essentially that the proposed desalination facility would cause no entranment beyond that caused by the power plant. As noted above,there are several reasons why this statement is erroneous. The DREIR further errs in not including the most recent documentation of the scale of entrainment and u impingement losses caused by the power plant. The DREIR includes an Intake Effects j Assessment(November 2004)intended to describe the entrainment and impingement effects associated with the proposed desalination facility, however, it inappropriately excludes the r i r Comments on DREIIt for Proposed Desalination Facility—SCH 42001051092 May 26, 2005 Page 9 of 17 recently published AES Huntington Beach L.L,C- Generating Station Entrainment and Impingement Study(April 2005),required as a condition of the 2001 California Energy Commission approval of the power plant upgrade. While we recognize that the study was in progress.during preparation of the DREIR,many of the data were available to provide an initial scope of the entrainment effects, and now that the final study is available during review oFthis draft CEQA document,it should be incorporated into the analyses. The rec--itly completed study describes, atrnong other things, the loss of hundreds of millions U of individuals of various species each year due:to entrainment and impingement caused by the power plant. The study further concludes that organisms from just eleven target species lost due to entrainment are equivalent to those produced in up to almost two square smiles of the nearshore waters off Huntington Beach. This is a significantly greater impact than the effects described in the DREIR. Same of the reasons for differences between the DREIR findings and the Energy Commission study's findings may be due to elements of the studies described.below. We recommend further revisions of the DREIR incorporate the results of the Energy Commission study into its analyses. a) Source water;The DREIR describes the source water for the intake as the entire Southern California Right. This is an inaccurate basis for entrainment and results in inaccurate representation of the ecological impacts caused by the cooling system. The Energy Commission study more properly based its source water volumes on the area of water that could be drawn into the intake that contained organisms of"entrainable"size—that is, for each species,the entrainment rate is based on when the affected organisms are at a particular size or life stage subject to entraimnent, and the source water represents the area close enough to the intake(due to currents and other factors)than the water containing those organisms could be drawn in. This approach results in�a substantially smaller area of source water than was used in the DREIR and a more valid assessment of intake-related adverse impacts. The analyses in the DREIR should therefore be revised to incorporate the approach used in the Energy Commission study. G) Efate of entrainment mortality:The DREIR states that testing at the power plant shows entrainment mortality to be abort 94-95% and that the proposed desalination facility would increase that rate only marginally. The standard approach for such studies is to ' assume an entrainment mortality of 1001/6. Even if some individual organisms are able to survive the temperatures and pressures experienced when going through the cooling system,they are generally considered to have a survival rate of essentially zero when they are discharged from the system back into the water column. Additionally, for the water withdrawn for the proposed desalination facility,any organisms that survive the power plant cooling system should be assumed to have 100% mortality, since desalination pretreatment, filtering,and other processes)are meant to remove all organic particles from the water,which would naturally include eggs. plankton, and larvae. The DREIR entrainment analyses should therefore be revised using a 100%mortality rate for both the power plant and the proposed desalination facility, Comments on DREIR for Proposed Desalination Paciliry—SCH#2001051092 May 26, 200S Page 10 of 17 c) Standard of ieview. The DREIR states that the power plant meets the federal Clean Water Act's Section 316(b) requirements for thermal power plant cooling water structures, r Flease note thai this does not equate to conformity to CEQA or the Coastal Act,both of which have more stringent standards for mitigating adverse effects. Please also note that the power plant's upcoming NPDES permit review will be subject to the recent changes X to that section of the Clean Water Act. The DREIR should therefore not use past 316(1>) conformity as the standard by which to determine conformity of the proposed desalination facility to applicable 'water quality and Ynarine protection requirem ents. +� The DREIR additionally argues in its discussion ofpotential alternative intake systems, that it is not necessary to consider a subsurface intake or beach well because they are not T-- considered"Best Technology Available"(BTA)under the Clean Water Act. Again,this contention is immaterial to the review of the proposed project, since other applicable requirements, including CEQA,do not use this standard to determine feasible mitigation f_ measures Further, it is odd to see this contention in the DREIR since the document in almost every other instance takes great pains to distinguish between the cffects of the proposed desalination facility and those of the power plant,yet here contends that a standard applicable to the power plant provides a reason to not consider measures that would likely reduce the adverse effects of the desalination facility. We additionally note, I that several recently published documents here in California strongly recommend the use y of subsurface intalces for desalination to prevent the direct or indirect entrainment effects caused.by open water intakes. We note as well that the power plant currently has a closed loop cooling water system for part of its operations that uses up to 56 million gallons per day. This suggests that additional implementation of closed loop cooling may be feasible at the power plant and would allow either complete avoidance or significant ? reduction in its entrainment and impingement impacts. This would also further support the need For the proposed desalination facility to be evaluated on its own for the proposed use of the powca plant intake. d) Impingement.The DREIR states that the HBGS intake brings in water at a velocity of two feet per second. Please note that this flow rate is four times the 0.5 feet per second established by the U.S. EPA as"Best Technology Available"in its recent rule revision, which is among the requirements applicable to this facility. Unlike the BTA standard referenced above,this Clean Water Act requirement may result in a more stringent limit Z r that,if required of the power plant during its next NPDES review,could substantially affect the operation of the proposed desalination facility. The DRM should be revised to evaluate how such a change would affect the proposed project,its environmental effects, and the mitigation that may be necessary. Marine Biological Resources—Effects of the Proposed Desalination Facility DischwZe 9) Ocean water off of Huntington Beach has an average salinity concentration of about 33.5 - parts per thousand (ppt),with variations over the course of the year of roughly 10%. The as DREIR describes an area of increased salinity near the existing power plant discharge that would be caused by combining that discharge with the proposed desalination discharge. The i document's analyses describe varying areas of increased salinity concentrations based largely r i r i _ r 1 Comments on DMR for Proposed Desalination Facility-SCH r20010S1092 May 26, 2005 Page 11 of 17 on either of two flow rates through the cooling system(i.e., either 253 or 127 million gallons per day). The areas affected by salinities of more than 10% above background range up to several dozen acres,while areas ofbetween 1%and 10%above background can cover nearly 2000 acres. The area predicted to exceed the U.S. EPA guideline of ppt increased salinity could extend up to about 600 feet downcurremt. These areas of increased salinity, along with the area lost to biological production due to entrainment as described above,represent a significant forlion of the.€.-ant.ngton Bleach coastline, and do not appear to be the insignificant impact described in the DREIR. Further, because additional reasonably expected scenarios would have the power plant operating at much less than 127 million gallons per day, the affected areas could be much different in size or have much higher salinity concentrations than those described in the DREIR. As mated a a previously,the cooling water flow scenarios described in the DREIR are likely less than the ' "reasonable worst-case scenario"due to the likelihood that the power plant may either shut down entirely for periods of time or may need to operate only a single pump during standby periods. The DREIR's salinity evaluations should therefore be revised to include these scenarios. The DREIR also concludes that the species within these areas that would be exposed to these higher salinity levels are either tolerant of the higher levels or would be able to move out of the affected areas. Its primary basis for this conclusion is that these species are exposed to these expected higher salinity concentrations elsewhere in their range_ This does not appear to be a valid comparison far at least two reasons. First,the analyses do not differentiate between the range of tolerance for a species and the tolerance of particular individuals of that species. For example,while individuals of a particular species may do well in higher salinity a b waters in other parts of the species' range, it does not mean individuals living in the range of r salinity found offshore of Huntington Beach would do well if those waters were to change to having salinity concentrations at 110%to 164%of those existing ambient conditions. Secondly,the analyses do not describe how quickly these organisms are able to adapt to these types of salinity differences. While the organisms may be able to adapt to the naturally occurring 10%change in salinity over the course of a year,they may not be able to respond to an immediate change of that range or greater. Additionally,some areas within the discharge plume will cycle back and forth through these salinity ranges relatively quickly based on the number of pumps that happen to be operating at the power plant at any given time,thus requiring exposed organisms to quickly adjust to salinity extremes far high m than ` normal conditions. It is Iikely that many organisms adapted to local conditions would actively avoid the higher salinity areas,thus creating a zone with lower biomass,less biodiversity,or with other substantial ecological changes_ The DREIR also includes a report(Marine Biolopcal Consideration Related to the Reverse Osmosis Desalination Protect at the Applied Energy Sources Huntingdon Beach Generation Station-August 2004), which provides for several species lethal salinity concentrations ae (LC,a,which estimates the:lethal concentration for 50%of the tested individual organisms). While a 48-hour LC5a is a useful measure for some purposes,it does not adequately characterize an organism's response in the natural environment and does not detect behavioral or reproductive changes,chronic effects,or other sublethal or long-term stresses_ i Comments on DR.EfR for Proposed Desalinarion Facility-SCH#2001051092 May 26, 2005 r Page 12 of 17 The report also cites a study done in Antigua of the effects of much smaller desalination r- discharge in a different marine ecosystem than is found off of Huntington,Beach. The DRF-IR should also provide monitoring and study results that apply more directly to the a C - conditions and organisms of Huntington Beach and Southern California. Effects on Nearby Habitat Areas I u)The DREIR does not describe the h—abit-?t v2lues as&ociated with the flood control channel and wetlands immediately adjacent to the proposed project site. 'It appears from site ad photographs that there arc several habitat elements that could be affected by project construction and operation. The document should be revised to include analyses of these elements and to evaluate feasible mitigation measures that would avoid or minimize adverse effects to these habitat features. r Drinking water quality and public welfare { 11)The presence of boron in drinking water is an emerging health concern. At elevated levels, , boron is believed to cause human reproductive effects and is harmful to plants_ Here in California,there is no drinking water standard for boron; however,the state has established an action level of 1.0 tng/L. Providers of drinking water that exceeds this action level must r notify the consumers and local governments,and the Department of Health Services may recommend removal of the water source from service if concentrations of the contaminant significantly exceed the action level. The World Health Organization has established a guideline for maximum boron concentrations in drinking water of 0.5 mg/L. Seawater contains boron at naturally occurring levels of about 4.5 nig/L. The DRMR sates a e that the water supply provided by the proposed desalination facility would contain boron at levels around 0.6-0.9 mg/L. However, single-pass reverse osmosis systems like the one proposed to be used at the facility are generally considered to have only a_50-75%removal efficiency for boron,which would bring the boron concentrations down to roughly 1-2'mg/L, rr or about two to four times the recommended concentrations for drinking water. The DREIR revisions should provide more detailed information about the basis of the statement regarding expected boron levels in the product water,including a description of the materials and r processes the facility would use to reach the stated levels. It should also identify any available measures that would further reduce the boron concentrations along with the costs and effects of those measures. Alternatives Analysis 12)Section 7 of the DREIR assesses several alternatives to the proposed project. These r assessments include several problematic assutmptious,and use some questionable or a f incomplete information to arrive at their conclusions. Several of these problems were described above, including the DRt=IR's definition of groundwater as something other than a local reliable water source,the use of the wrong"reasonable worst-case scenario"for cooling water pumping,rind others, The alternative analyses should be revised to incorporate those changes along with those described below. 't. Commenrs on DREIR for Proposed Desalination Faciliry—SCH#2001051092 �. May 26, 2005 Page 13 of 17 a) No Ptoiect Alternative: The DF�21R states that the"No Project" Alternative is not feasible,in part,because it would result in the proposed project site remaining contaminated and unsightly and would require the use of conservation measures to reduce regional water demand. Concerning the first contention, although the proposed project is one way to clean up and beautify part of the power plant site, it is not the only method for doing so and is not a valid reason to dismiss the`No Project"Altemative. With regard to the second contention"'font ut'Le region',vvuid havehavetv iIii`tSiwu.-ut Stg^itf,.-a!2 r_... efforts—the DREIR erronecnWy treats this as a negative, rather than a positive Feature, A "No Project"Alternative that resulted in stronger water conservation treasures would ibetter conform to the stated goals of many water planning efforts and those of CEQA. We note,too,that the DREIR states it would be difficult to conserve the equivalent of the ag ' 50 million gallons per day output of the proposed facility as early as 2008 when the facility is expected to be operating. It is inappropriate in this CBQA review to use that amount of water as a basis for comparison since that water currently is not available,is not being used,and is not tinder contract to be used. it is further inappropriate to use 2008 as the date by which this amount of water must be conserved since there is no certainty that the proposed project would be operating by that date. This is particularly the case since most of the DR&IR's other references to water demand and planning efforts have timelines stretching to 2025 or later. We therefore recommend that the"No Project Alternative"be revised based on the actual existing amount of available water, not the water that may eventually be available from the proposed facility, and that the full suite of available conservation measures be applied within the potential service areas for the same time period as is used in the cited water planning documents. b) Alternative urovosed production: As noted previously,the DREIR does not adequately establish the need for the proposed project to produce 50 million gallons per day of -drinking water. The alternatives analyses should be revised to recognize other amounts a that would be feasible and useful. Clearly,lesser amounts should be feasible,since this proposed project would be several times larger than any other fully operating seawater desalination facility in the country. cj Alternative water sour-cm: Given the concerns expressed throughout this letter and the additional impacts identified,the alternatives considered need to include other methods to .. provide source water for the proposed facility. These other methods should include: • Beach wells or subsurface intakes:The DREIR's alternatives analyses for these types a i Y YP of intakes include several flaws that require correction. As noted above,the analyses are basal on an unsupported expectation that beach wells must produce 100 million gallons per day of water. Much smaller beach wells may prove to be adequate for a smaller and feasible facility. Commenrs on DREIR for Proposed Desalination Facility—SCH 92001051092 May 26, 2005 F Page 14 of 17 The document also expresses concern about the love levels of dissolved oxygen often found in water from beach wells,and states that the desalination discharge would Have such low dissolved oxygen concentrations as to not meet requirements of the California Ocean Plan or the U.S.EPA. This concern seems to be based on leaving out a trey aspect of the proposed project that is included in all other parts of the DREIR— namely,that the discharge from the proposed desalination facility would be combined with the power plant discharge and its adverse effects diluted. For scsranos that include an operating power plant, such a combination would I-.acely a 1 allow any very low dissolved oxygen levels to be mitigated so that the overall discharge could meet the applicable water quality standards. Additionally,the DREIR briefly mentions that there are measures available to increase the oxygen r levels in the water before it is discharged, but does not provide the necessary description of those measures and an assessment of whether they are feasible. r Please also note that desalination facilities currently approved or operating on the California coast use beach wells—for instance,in the cities of Marina and Sand City. In both those cases,the beach wells look nothing like the illustrations provided in the DREIR showing relatively large and invasive structures on the beach. In sum,-most of the significant limiting factors the DREIR identifies for beach wells are misplaced and the alternatives analyses should be revised. r„ Recycled or reclaimed water:The proposed facility would be located a relatively short distance from the Grange County Wastewater Treatment Facility. Despite some concerns expressed in the DREIR described below,this appears to be a feasible option for both feedwater for,and discharge from,the proposed facility and is worthy a' Of additional analysis. In fact, use of water from the treatment plant may result in much lower desalination operating costs since the levels of total dissolved solids in r- treated wastewater are often lower than levels in seawater. We therefore recommend ? That the DREIR revise its alternative analyses to further evaluate this option. d) Alternative discharges:Numerous studies cite the advantage of blending the high salinity r- discharge from a desalination facility with an existing wastewater discharge,not only because they can share the same outfall but because the increased overall salinity helps the discharge blend more rapidly with the receiving water. The DREIR notes concerns `- about the capacities of the nearby wastewater outfall and concludes that the lack of am capacity makes this option infeasible. However, it does not consider the benefits of having the proposed desalination facility take more water from the treatment plant than it r would return—For example, if it used 100 million gallons to create drinking water,it would return muck less to the treatment facility to be discharged. We recommend this alternative be explored further. e) Alternative sites:The DREIR includes three analyses for alternative sites—at the power plant site,within two miles of The proposed project site,and more than two miles from the site. With regard to the first analysis,the DREIR should include in its discussion of an s alternative site at the power plant the effects the proposed location could have can the power plant's ability to change to an alternative cooling system. r Comments on DREIR for Proposed Desalination Facility—SCH#2001051092 May 26, 2005 Page 15 of 17 For the.second type of analysis,the DREIR considered open areas within two miles of The proposed site. This two-mile radius appears to be arbitrary, as it does not relate to the proposed project's objective to provide water throughout the region or any other aspect of feasibility. Additionally,using"open areas"as a criterion resulted largely in a selection of nearby parks,schools, and wetlands, all of which were dismissed as inappropriate. ' This is clearly an inappropriate criterion to use. since the preferred project site itself—an existing industrial-Zoned power plant—is not an "open arc8"and would not be considered feasible. We therefore recommend the DREIR change these two criteria to exclude the arbitrary two-mile radius and to-look at sites other than"open areas"that may include sites with existing compatible uses,sites that provide redevelopment opportunities,or other such situations similar to the primary proposed site. ' The third analysis,of sites further than two miles away, appears to be perfunctory and does not fully address the feasibility of sites that are located somewhere other than immediately adjacent to the beach or sensitive coastal resources and does not consider ao ' different approaches for handling the proposed water source other than a standard open water intake and outfall. The analyses should be revised to identify other feasible options, such as existing intakes or outfalls, locations inland from the immediate shoreline,and other characteristics fitting of a proposed regional water supply project. f) lone-tern viability: As noted previously,the DREIR does not adequately address likely changes to the power plant's existing permit tequircments,approvals,and contracts. The DREIR should therefore more fully incorporate the conditions of these various a p agreements and requirements into its analyses to better evaluate feasible alternatives that . may not be subject to the same limitations or potentially changing circumstances. g) Alternative ownership:The DREIR evaluates"alternative ownership"of the proposed facility to address a concern that operation of the facility by a private entity could result in more environmental impacts than those resulting from a publicly-operated facility. Section 7.3 of the DREIR states that alternative forms of ownership—i.e.,changing the facility from being privately operated to being operated by a public entity—would not 1 change how it would affect the environment. In support of that assertion,the document cites a passage from the 2004 California Water Plan,which states,in relevant part,"So long as government regulations are applied in the same manner to water projects involving multinational corporations as they are to water projects owned or operated by aq domestic companies or public utilities,there would be no conflict with irimmationah trade treaties.' The DRFIR goes on to state that the project proponent,Poseidon Resources Corporation,is a U.S.corporation,not a multi-national corporation. There are several problems and shortcomings with the analysis provided in the DREIR.. First,the analysis does not accurately portray the issue of concern—it is private ownership of the facility, not its operation,that is of concern,due to provisions of international treaties that suggest such facilities may escape certain locally-imposed health and environmental standards. Second,the cited passage from the Water Plan does not address the concern that provisions of international treaties may lessen or remove the r Comments on DREIR for Proposed Desalination Faciliry—SCH#2001051092 May 26,.2005 Page 16 of 17 ability of local and state government from regulating private multi-national entities or regulating a resource that is controlled, sold,or otherwise marketed by these entities. The passage merely states that there would be no conflict with these treaties if regulations were applied in the same manner to both private entities and public agencies. The concern about the international treaties is that they may create a"lowest common r denominator" system of regulation,in which the least restrictive standard imposed by a country subject to a treaty becomes the standard applicable to any entity here in California prov icing a service covered by the treaty. We recommend the DRE-M incorporate other sources of information about this issue—for example, instead of using the statement above from the Water Plan that doesn't apply to the issue of concern,we recommend the analysis incorporate the concerns of the California Office of the Attorney r General and the California Senate Select Committee on International Trade Policy and aq State Legislation, both of which have expressed significant concerns about potential loss of local and state authority over proposed projects such as this one. F' Lastly,we note that the DREIR states that the applicant,Poseidon Resources,is not a multi-national corporation because it is based in Connecticut. That is incorrect. Many r multi-national corporations are based in the US., as is Poseidon. What makes a corporation multi-national is not where it is based,but that it has operations in several countries. If Poseidon operates in a country subject to treaty provisions that provide lesser environmental or health standards than California, and those standards become r applicable to their operations here in California,the proposed project may have far t greater adverse effects than those described in the DREIR. Cwowth Inducement _ i 13)The DR IR's discussion an growth-inducement in Section 6.2 is based on-some questionable r analyses and includes some troubling statements. It mixes growth projections contained in 1 adopted plaits with projections from various growth assessments not adopted by any particular pl=ning or govenunental entity. It includes in its areas of potential water service ar F several that have already exceeded adopted General Plan build-out levels. It cites the nerd forate conservation as a art of water i but does o provide a ec water c nsery p atrnin b not ro de the n e P �. P ssarY descriptions of what water conservation measures are in place in each of its potential service areas and what feasible measures are still available'to be implemented. It also includes the troubling statement that any growth resulting from the proposed project would not be due to the project itself,but would be entirely dependent on how the water would be allocated by various local and regional water purveyors buying the water provided by the project. While this statement may correctly identify the immediate cause of a particular result,it clearly misses the CEQA mquirmnent to address reasonably foreseeable as consequences of a proposed project. It is akin to saying that a new water supply doesn't cause growth; it's all the people drinking;the water,or that a new road doesn't cause growth', it's all those cars driving on it. This is clearly not the analysis anticipated from CEQA review. The statement also ignores the CEQA Guideline(Section 15126.2(d))cited earlier in r that same discussion that the analysis of growth-inducement discuss the ways the proposed project"...could foster economic or population grovnh,or the construction of additional r- i r Commenis on DREIR for Proposed Desalination Facility—SCH#2 001 051 092 May 26, 2005 Page 17 of 17 ihousing, either directly or indirectly, in the surrounding environment." Further,absent some reasonable level of certainty about where the proposed new water supply would So,the DREIR does not meet the necessary standard for determining potential growth-inducing aspects. This lack of certainty is due in part to some shortcomings noted above and also because the DREIR does not adequately establish the need for the proposed 50 million as gallons per.day of water versus any other amount that may be feasible to produce. For purposes of CEQA review,the DREIR clearly does not provide an adequate evaluation of growt{i-inducement. The document should be revised in a number of ways to address these shortcomings. Its analyses should properly evaluate the proposed project's potential for growth inducement by using valid and consistent adopted growth projections. With regards to the needed level of certainty,the document should either base its growth- inducement analyses on known locations of where the water wiU go (i.e.,based on contractual obligations or other legal mechanisms)or should develop various scenarios that would allocate different amounts of water to different service areas and then identify the resulting growth. Closing ' Tbank you again for the opportunity to continent on this document. In closing,we wish to reiterate that much of the DREIR is based on inadequate or dated information,uses incorrect assumptions,or is otherwise flawed. The document,therefore,is not yetsufficient for CEQA review and does not yet provide adequate information upon which to begin review pursuant to at Coastal Act requirements. We recommend,therefore,that rather than publish a Final EIR that includes only responses to comments, you thoroughly revise the DREIR based on the comments above as well as others you may receive and then recirculate the newly-revised document for additional public comment before publishing a final version. zel Tom Luster Energy and Ocean Resources Unit Cc: Poseidon Resources—Peter MacLaggan California Energy Commission—Rick York,Donna Stone Regional Water Quality Control Board, Santa Ana Sur£Tider—Joe Geever Heal the Say—Craig Shuman STATF.OF CAI-IFORNIA-1"HE RESOURCES AGHNCY GRAY DAVIS,(WiTRYOR CALIFORNIA COASTAL COMMISSION jG 45 FREMONT, SUITE 2000 SAN FRANCISCO, CA 04)05.22)0 VOICE. AND TOD (415) 004-S200 A FAX (415) 904.1400 i. VIA FACSIMILE (714) 374-1648 November 4, 2002 Mr..Ricky Ramos City of Huntington Beach Planning Department 2000 Main Street P.O. Box 190 Huntington Beach,CA 92648 ' RE: Draft Environmental Impact Report: Poseidon Seawater Desalination Project, September 2002—City of Huntington Beach (State Clearinghouse 4200.1051092) ' Dear Mr.Ramos: ' Thank you for the opportunity to comment on the above-referenced Draft Environmental Impact Report(DEIR). The proposed project would be built adjacent to the AES Huntington Beach Generating Station(HBGS)and would use water drawn in from the Pacific Ocean through the ' HBGS once-through cooling system as its source water to produce approximately 50 million gallons per day(mgd) of desalinated potable water for local and regional use. ' The proposed project is located within the coastal zone and is primarily within the jurisdiction of the City of Huntington Beach's Local Coastal Plan(LCP). Additionally, the Coastal Commission has retained jurisdiction over portions of the proposed project that would affect ' coastal waters. The project,therefore,would require two Coastal Development Permits (CDPs) —one from the City for upland portions of the proposal and another from the Coastal Commission for portions affecting coastal waters. The entire proposal is also within the Coastal Commission's appeal jurisdiction;therefore, any appeal of the City's permit decision may be au ' heard by the Commission. The proposed.project would be the largest desalination facility in the U.S.,and would be the first to be built in California in over a decade. The proposal raises significant issues related to compliance with several local and state policies and regulations and therefore deserves a thorough review,first at the CEQA level and then during subsequent permit determinations. The .comments below are focused primarily on issues related to conformity to the Coastal Act and the proposal's possible effects on coastal resources. Please note that these comments reflect our concerns and questions at this time in the EIR review, and that we will likely request additional or more detailed information during the CDP review process related to the proposal's conformity to the Coastal Act. These comments also provide a follow-up to the June 14;2001 comments we provided regarding the"Notice of Preparation"for the EIR. Those comments requested that the DEIR address several significant areas of concern; however, in some cases,the information provided in the DEIR does not adequately respond to those comments. r- r • r Coastal Commission staff comments on Huntington Beach Desalination Facility DEIR November 4, 2002 Page 2 of 7 r General Comments: r I) Water Quality and.Marine Biological Impacts due to the Facility's Proposed Use of Ocean Water: r The proposed project is located adjacent to u.e HBGS and is dependent on the electrical generating facility's use of ocean water for once-through cooling. _The California Energy Commission recently approved an upgrade at HBGS through an expedited review process r that allowed the applicant to delay some studies of potential impacts to coastal resources and identification of feasible mitigation measures until after the project was approved and the facility was operating. One of these studies was to determine the entrainment, impingement, and thermal impacts related to the facility's once-through ocean water r cooling system. There is also an ongoing study to determine whether an interaction between the HBGS intake and the nearby Orange County Sanitation District discharge may be leading to local beach closures due to increased levels of bacterial contamination. a V I r Results of the HBGS cooling system study are needed to identify impacts to water quality and marine organisms,and the feasible measures that would allow these impacts to be r avoided,minimized,or otherwise mitigated. We will therefore likely need the results of this study as part of our review of the proposed facility's conformity to the Coastal Act. . Additionally, the DEIR cites the City's LCP Policy 6.1.19, which states: "Prior to approval of any new or expanded seawater pumping facilities,require the provision of maximum feasible mitigation measures to minimize damage to marine organisms due to entrainment in accordance with State and Federal law." Pursuant to this policy,the study r results should also be included in the EIR review. ` Results of the studies mentioned-above will likely answer several of the questions and r comments below. In the interim,please respond to the comments based on currently available information,where possible. J r la) At)plicable water quality standards: Section 4.3 of the DEIR describes the beneficial uses of the Pacific Ocean's nearshore waters as industrial service supply,navigation, contact and non-contact water recreation,commercial and sport fishing,wildlife habitat support,and others. The California Ocean Plan also describes a number of specific water quality objectives for marine water. The listed beneficial uses and objectives do not include drinking water or potable water supply. i Please.provide an evaluation of whether the proposed project's use of ocean water 'aw �I for drinking will conform to state water quality standards, including the Ocean Plan, and whether such a proposal requires a change in the listed beneficial uses of ocean water or a change in discharge limits to ocean waters to protect those waters as a source of drinking water. Please also discuss the beneficial or adverse r effects these types of changes these might have on those resources. r Coastal Commission.staff comments on Huntington Beach Desalination Facility DEAR November 4, 2002 Page 3 of 7 lb) Facility operations: Please describe the relationship between the HBGS facility and the desalination facility. For example,please describe whether the desalination facility will continue to operate during times HBG-S is shut down for short-term or long-term maintenance,planned outages, or other reasons. If it will, please describe the desalination operations that would occur during these shutdowns,including a description of the facility's entrainment effects.and the characteristics-of its discharge,including thermal characteristics and concentrations of salinity and constituents as they compare to allowable NPDES ax permit limitations. This should also address the area of increased salinity around the discharge and its effect on water quality and marine organisms. ' Also,please describe,if known,how adverse entrainment and discharge effects will be"partitioned"between the desalination facility and HBGS for purposes of ' NPDES permit compliance,determining mitigation requirements, etc.; during times both facilities are operating as well as when just one is operating. ' 1 c) Modeling and analyses used: The DEIR and its appendices include several analyses of the proposed project's effects on marine organisms and water quality. For example,the DEIR describes impacts to water quality and benthic areas due to salinity levels in the proposed project's discharges from the existing HBGS outfall. The"worst case"scenarios in these analyses are based on the desalination facility operating while only one of the four HGBS generating units is operating, and when there is no mixing of the discharge plume in the receiving water. The resulting analyses describe the salinity levels at various distances from the outfall as ranging from less than 10%to roughly 60%greater than the local mean a y seawater salinity(at 33.5 ppt). They also include maps showing the anticipated areas of higher salinity levels at various depths. These maps do not include a distance scale,but appear to show increased salinity in areas of the water column and benthic surface of from a few acres to several hundred acres during different conditions. We are concerned that the"worst case"scenario used in the DEIR may not be the actual"worst case", and in fact,may understate adverse conditions that would occur during the normal course of operations. The actual"worst case" scenario is likely one in which the desalination facility operates while none of the HBGS generating units are operating.:Therefore,the analyses of entrainment, impingement,thermal discharges, salinity changes, and others should be re- assessed based on the desalination facility operating when HBGS.is not. ld) Mitigation measures: The DEIR does not include identify mitigation measures f available to avoid or minimize the impacts associated with entrainment, impingement, or thermal discharges. Results of the cooling water study ' mentioned above will likely be needed to complete this portion of the .environmental review. There are a number of measures that could be considered, such as operational or structural changes to the intake to reduce water velocity a Z 1 and entrainment rates,changes to the outfall to either increase mixing and avoid salinity increases to the benthic community at the seafloor,and others_ r i Coastal Commission staff comments on Huntington Beach Desalination Facility DEIR 1. November 4, 2002 . Page 4 of 7 !— I e) Information from other desalination facilities: Our June 14, 2001 comments on the NOP*requested that the DEIR include a review of other similar desalination r facilities to assess whether monitoring requirements at those facilities were adequate to identify project impacts and establish necessary mitigation measures, and whether similar or improved requirements would be appropriate for this ba ,- proposed facility;however,the DEIR does not include this review. Please provide an evaluation of the known impacts associated with other existing desalination facilities, the measures taken to avoid,minimize or compensate for �— those impacts,the types of monitoring used to determine the impacts as well as the performance of the selected mitigation measures, and any contingency measures that are in place or have been required due to the identified impacts. r i 2) Energy Demand.- Our NOP comment letter requested that the DEIR address the energy requirements of the proposed facility, including the effects of its energy demand on local and regional energy t- supplies and measures available that would minimize energy use, and that these analyses be-done using a reasonable range of possible energy prices. The DEIR states that the r desalination facility would use approximately 30 to 35 megawatts (MW)per hour, or bb about 720 to 840 MW per day, and that it would attempt to use off-peak power when practicable, but does not include any additional analysis on energy use. i Please describe the effects of the desalination facility on local and regional energy supplies during times of typical electrical demand as well as during peak demand times. Please also describe the.effects of this significant base load demand (assuming the facility would operate continuously, or nearly so)on the local and regional energy capacity. This should include an analysis for the facility's energy demands when the HBGS units are shut down for short-term or long-term maintenance. 3) Site and Facility Hazards.- The DEIR states that the project objectives include providing a reliable source of potable water for the area. The proposed project site,however,,is located in a seismically active area with very high liquefaction potential,and is designated as being prone to flooding. Recognizing the benefit to the applicant of siting the proposed facility where it can use an existing intake and outfall system,we are still concerned that locating the facility in a site with these hazards may not meet the desired objective of providing a reliable source of water during emergencies. bC 3a) Seismic Activity and Liquefaction: The site is described as being subject to high r levels of seismic activity and ground shaking, and as having a very high potential for liquefaction. The DEIR states that a geotechnical report has not yet been prepared, but that one will be required as part of the building permit application. This report is likely to include recommended mitigation measures necessary to protect the facility from seismic activity. Recommended mitigation measure GEO-7(at page 4.2-13), for example, states that the project will comply with the Uniform Building Code standards on seismic safety,but also states that more j stringent measures may be required due to the site's location near two faults. _ Coastal Commission staff comments on Huntington Beach De ahnation Facility DEIR November 4, 2002 Page 5 of 7 Please describe what additional mitigation measures would be required to ensure the facility's safety during the anticipated level of earth shaking, based on measures that may have been required at other similar facilities that have been bC built nearby, and any adverse effects those measures are likely to have—for example,will facility construction require larger or deeper excavations, and therefore require treatment of higher volumes of contaminated groundwater, or will the facility require a larger amount of paved surface and therefore additional stormwater treatment? 3b) Flooding: The DEIR states that the site is subject to flooding and that additional hydrologic analysis will be needed to determine if the site drains adequately. This analysis would clearly influence the appropriateness of the site for the proposed development. Please provide currently available information about the types and bd frequency of flooding or high waref at and near the site and the types of,analysis r anticipated to be done. Please also describe the types of mitigation measures that would likely be necessary to prevent flood or high-water related impacts. ' Additionally,the DEIR states that the Orange County Flood Control District will be placing sheet-piles along the flood control channel adjacent to the proposed project site. Please describe the purpose of this project,their relationship to the be proposed development,the impacts they are meant to address, and the mitigation measures that may be needed as a result of these sheet-piles, especially as they relate to the proposed project and its site. 4) Alternatives Analysis: - The DEIR's discussion of alternatives presents several options for alternative sites, desalination methods;or different Iocations of various.elements of the proposed project; however,it does not evaluate possible alternative sources of water that might be available to meet all or most of the project objectives. The current proposed source of water may involve significant adverse impacts to.marine organisms and water quality, and there are b f . likely other water sources available that would result in no impacts to these coastal resources,and fewer impacts overall. Subsequent environmental documents should evaluate the availability of all water supplies in the region against demand to document the shortage and/or surplus in the ' various areas and how this proposed project would affect that balance. Section 3.5 of the DEIR discusses some of the local and regional water demands and supplies, but does not adequately discuss other sources of water, such as groundwater,reclaimed water, or conservation that may be available throughout the region to be served, and whose use could result in fewer adverse impacts to coastal resources. For example, it states that the "Southern California Integrated Water Resources Plan"has identified 80 projects -providing over 150,000 AF/year to the region and another set of projects with the potential to provide as much as 800,000 AF/year. The proposed desalination facility would produce about 150,000 AF/year, but would result in impacts to ocean water quality 1 and marine resources not likely to occur with the other projects identified above. The DEIR should compare the benefits and effects of projects such as those in the above- referenced plan with the benefits and effects of the proposed desalination facility. r r Coastal Commission staff comments on Huntington Beach Desalination Facility DEIR November 4, 2002 Page 6 of 7 S) Growth-inducing Impacts: Our comments on the NOP requested that the EIR include a thorough examination of growth-inducing impacts: The NOP stated that the proposed project was "intended to s•,zppler,:ent existing Orange County water supplies and is not intended to foster r additional growth or accelerate growth. However, depending on the ultimate destination of the project's water supply, provision of additional potable water may lead to growth- L` inducing impacts." The purpose or scope of the proposed project has apparently changed. The DEIR states that the desalination water made through the project will be available throughout the South Coast Hydrologic Region, which stretches from northern Ventura County to San � Diego. The DEIR also reiterates the statement in the NOP that the facility may or may not induce growth, depending in part on its final end-users. bg r For purposes of both CEQA.and conformity to the Coastal Act, subsequent environmental documents should provide additional specific information about the proposal's possible growth-inducing impacts. For purposes of determining conformity to the Coastal Act,we are particularly interested in those impacts in coastal areas. For example,please provide information about how water produced at the desalination facility will be allocated to various water purveyors, or if that has not yet been '— determined, how those decisions will be made. Also,please identify,if known, how the water supply provided to various purveyors will be tied to approved growth-related plans in the various service areas—for example,will allocations be limited in some way depending on the plans in place?;what degree of public review and oversight will be available for both the facility's operations and the allocation decisions?; etc. r 6) Cumulative Impacts: i_ The proposed prof ect would contribute to cumulative impacts at both a relatively r- localized level as well as a regional level. Regional cumulative impacts are likely to be associated primarily with issues related to growth-inducement, and proj ect alternatives, and may also be associated with water quality,marine biology, and energy impacts. Regarding cumulative impacts related to growth,the analysis provided in the DEIR is bh -- limited to possible impacts in the City and in south Orange County. All but two of the projects listed in the DEIR as possibly contributing to the cumulative impacts of the r proposed facility are within one mile of from the facility site. This is clearly inadequate (_ when the proposed facility is anticipated to affect water use throughout the South Coast - Hydrologic Region. While we do not believe the DEIR needs to evaluate the potential cumulative impacts of all anticipated projects in the entire region, it should at least assess L the cumulative impacts of those projects Imown to or anticipated to benefit from the increased supply of water,including those that may be some distance from the proposed facility. Additionally,and pursuant to the CEQA Guidelines related to cumulative impact analyses,it should base its analysis on the growth projections in the general plans of those jurisdictions that maybe affected by this water supply, and should evaluate feasible options for'mitigating these impacts in the affected region. The DEIR states (on page 5- -9) that potential cumulative impacts are not being quantified or evaluated because such r- r L. Coastal Commission staff comments on Huntington Beach Desalination Facility DEIR 1 November 4, 2002 Page 7 of 7 an exercise would be"speculative";however,it is reasonable and necessary to expect the ' environmental review for this proposed project to include an evaluation of these impacts and potential mitigation measures based on information in these locally adopted plans. bh These plans are perhaps as equally"speculative"as an evaluation of cumulative impacts, but they still provide use basis U—k other sUrdlar CEQA-level reviews and p---,t decisions. iRegarding cumulative impacts associated with project alternatives, please provide an evaluation of the cumulative impacts associated with any alternative sources of water that may be available (per our comments in the Alternatives Analysis section above). For example,if there are sources of water other than ocean water drawn from the HBGS b facility that may feasibly supply potable water for the region, the subsequent environmental document should assess the cumulative impacts of those sources compared with this proposed facility. Specific Comments: These comments address specific statements in the DEIR, 7) Section 3.5,p. 3-23, Table 3-2: This table shows a recent and an anticipated water budget for the South Coast region for both average and drought years. However,it shows that b i ' use during the drought years was generally higher than during average years. Please correct or explain. 8) Section 4.3, D.4.3-12: The DEIR states that salinity modeling is based on a local mean seawater salinity level of 33.5 ppt. Please identify how much this levels varies and how bk that variation affects the results of the various modeling efforts. ' 9) Section 4.3,p.4.3-18 and 19: This section describes some of the cleaning compounds that may be used at the desalination facility. Table 4.3-2 shows the total discharge of cleaning compounds to be approximately 91,000 gallons,while the text below states that bI a typical day's cleaning solution would be in the range of 200,000 to 300,000 gallons. Please correct or explain. Thank you again for this opportunity to comment. Please contact me at(415)904-5248 or bm tluster(56coastal.ca.gov if you have questions or would like additional information. ' Sinc rely, l 1 Tom Luster _. Environmental Analyst Cc: Poseidon Resources—Andy Shea State Clearinghouse Coastal Commission, Long Beach Office—Steve Rynas ' Santa Ana Regional Water Quality Control Board—Mark Adelson -• STATE OF CALIFOR NIA .SDtRCfS.AG-NCY GRAY DAVIS,OUP6RNOB CALIFORNIA COASTAL COMMISSION ' [5 FREMONT, SUITE 2000 � - SAX, FRANCISCO, CA 91105.22I9 VOICE nNU TOO (415) 904-5200 Fp\ (4I5) 906. 1400 ' May 9, 2003 tvir. Ricky Ramos City of Huntington Beach- Plazi ing T �! 4 t�eYalultEiit 2000 Maui Street ' Huntington Beach, CA 92649 VIA FACSDVI[LE (714)374-1648 ' RE: Coastal Commission staff review of City's Response to Comments for proposed Poseidon Seawater Desalination Project Draft Environmental Impact Report. ' Dear Mr.Ramos: ' Thank you for providing the Responses to Comments document of March 21, 2003 for the proposed Poseidon Seawater Desalination Project. The document provides responses to comments the City received on its Draft Environmental Impact Report(EIR) for the proposed project,including comments provided by Coastal Commission staff in a letter dated November 4, 2002. The proposal involves constructing and operating a desalination facility to be located at the Huntington Beach Generating Station(H:BGS) in Huntington Beach. A portion of the proposed project is within the City's Local Coastal Plan jurisdiction and will require a coastal ' development permit from the City. Additionally,part of the proposal is within the Coastal bn Commission's retained jurisdiction as well as within the Commission's appeal jurisdiction, so it will require additional review and approval by the Commission. ' We have several concerns about the responses that we would like you to incorporate into the CEQA review before the City considers adopting a Final EIR for the proposed project.- We understand the Planning Commission has scheduled a heating on the matter for May 27,2003. Our concerns are based on the level of information needed to review the proposed project's conformity to the Coastal Act as well as to provide adequate evaluation under CEQA. We are ' especially interested in ensuring this proposal undergoes proper review,since it represents what would be the largest coastal desalination facility in the U.S. and the first one to be reviewed in California for over a decade_ To better ensure this environmental review is done ' comprehensively and efficiently,we recommend the comments below be incorporated into the City's EIR review before the_City and the Coastal Commission start their reviews for coastal development permits. General Comments: The responses in several issue areas do not provide adequate information for reviewing the bO proposed project for conformity to the Coastal Act, and may not be adequate for review under CEQA. Our primary concerns relate to the EIR's evaluation of the proposed project's biological ' impacts,the alternatives analysis,growth-inducement, and cumulative impacts. r- Letter re.- to :'0n7n2enr, onOSC 2ct0in Seawcaer � esalinari072 Prr�jec`DZIR Nray 8, 00 Paac of 0 One additional area of concern that underlies several of the comrnents in our November letter regards the applicability of various ordinances,regulations; and laws to this proposed proiect. The proposal involves using a private entity to produce potable water morn a public resource G.e.;seawater),.and selling that product to one or more public water dis:ncts. providing a public r I' ` +1,e -- dor;c most commonl ybv public rntit1ey. Our concerns in this water. s uyp,y uas, in u a past, �. t matter take two forms: r • Whether laws. ordinances_ and regulations applicable to public entities rarovidinu a water L supply apply differently, if at all, to private water suppliers.-Public water districts are subject to a number of requirements that are based in part on their characteristics as public agencies. For example,rates are set for public water districts based largely an the operational and.maintenance costs of providing a public service,not on profitability. Additionally,the Coastal Act includes several polici es with provisions or requirements for public works facilities,but not for similar"private works facilities." Vi%e recommend. the EIR provide an analysis of this issue to ensure that anticipated reb latory by requirements and mitigation measures would indeed apply to this proposed project. Of course, a more fundamental question to be asked and answered outside the context of _ [ CEQA is whether privatizing water supplies is sound public policy. • Whether international trade law adversely affects the ability of state and Local [ jurisdictions to regulate proposals such as this. Recent decisions by international trade tribunals and other developments in international trade law raise concerns-that private companies operating internationally may not be subject to state or local environmental regulations if those regulatory actions interfere witb profitability. For example, a company may argue that producing and selling,water in California includes restrictions, r such as flow limits,mitigation requirements, or compliance with'Coastal Act resource protection policies,that are not required in other countries wbere the company produces and sells water, and that these restrictions adversely affect profitability. Such an argument could limit or eliminate state and local environmental protection requirements, and may abrogate many of the mitigation measures identified during env6ronmental review. We therefore recommend the City consider bow international trade agreements, treaties, and laws may apply to this proposal, and whether anticipated environmental mitigation measures could be compromised Attached is a copy of a presentation given to the Coastal Commission-in February of this year regarding Coastal Act policies that may apply differentlyto public and primate proposals. The bq City may wish to evaluate its own Local Coastal Plan policies and other applicable City ordinances in a similar manner-and include the evaluation as part of the EIR_ Please also note that at several places in our November comment letter,we requested additional information be' provided in"subsequent environmental documents". This was meant to refer to br subsequent CEQA-related documents to be developed as part of the City's CEQA review,such as a supplemental EIR, an addendum, or other similar documents. Letter re: "Responses to Comments" on Poseidon Seawater Desalination Project DEIR Iola)'S, 2003 Page 3 of 6 ' Specific Comments: Water Ouality and Marine Biological Resources: Our comment letter requested that the EIR include additional information about the proposed project's impacts on biological 1 resources. W`c note that several other federal and.state regulatory agencies (includi-ig the U.S. Fish and Wildlife Service, California Department of Fish and Game,the Regional Water Quality Board, and the State Lands Commission) also stated in their comment - ' letters that the DEIR did not adequately address various'a e-cts of the proposed project's bs impacts to biological resources. However,rather than make changes to the analyses based on.commcnts from these agencies,the"Responses To Comments" document largely re-iterates what was stated in the DEIR. A Therc are a number of assumptions used in the EIR analysis that do not appear to accurately reflect conditions at the project site or characteristics of the existing and proposed facilities;therefore,the EIR's determination that there are no significant impacts to marine resources may not be accurate. We have provided more detailed ' comments on this issue below. • Entrainment: Our comment letter stated that results of the HBGS entrainment study ' would be needed to identify.the existing level of impacts to marine biological resources and to help determine impacts of this proposed project. Our letter also cited the City's LCP Policy 6.1.19,which requires mitigation be identified before approving any new or ' expanded seawater pumping facilities. The City's response to our comments states that the project would not result in increased entrainment, entrapment, or impingement of marine organisms, and that results of the study would therefore not be necessary. We ' disagree, for several reasons: o First the DEIR appears to base its assumptions about entrainment impacts on the Permitted water use at H13GS rather than actual use. We note that several.recent CEQA-equivalent analyses by the California Energy Commission to review proposed changes to coastal powerplants have used as their baseline the actual amount of water used by a power plant,rather than the maximum permitted amount. This approach provides a more accurate assessment of existing versus proposed conditions and meets the CEQA requirement to establish baseline levels by determining the actual, existing environmental conditions at the time of review. The EIR analysis should bt ' therefore be based on the actual amount of water used at the power plant during a recent representative period of time, and the analysis should compare this rate and pattern of use with the water use anticipated for the desalination facility. o Next, the DEIR states that the desalination facility would not increase entrainment over that caused by the power plant because some of the power plant's pumps would t be used to circulate water for use by the desalination facility even when the power plant was not generating electricity. While this measure might reduce the difference between the rates of entrainment caused by either process, it does not provide the level of information needed to determine entrainment impacts for either facility. Without additional detailed information about each facility's pumping rates,the relationship between water use for power generation and for desalination (e.g_,the ))r L L Letter re: "ReS770nses to C onimenrs or?Poseidon Seawater Desalinxion IUrnject DEII; Mail 2003 'Page 4 of G L timing and rate of desalination operations during power plant shutdown, ions-term (� operation of the desalination facilitvwitnoutpowerproduction, etc.), and the dill rent L entrainment effects that may result from power generation and desalination, we are unable to determine vv ether entra�-•-ient rates would increase, decrease, or Term r the Came IL o Additionally;the entrainment study currently underway for the power plant is meant r� to not only determine entrainment impacts but to identify what mitigation measures L are available and necessary if the study results show significant impacts. The study could therefore result in mitiation measures that milt require structural.or operational changes to the once-through cooling system affecting both the power plant and the desalination facility. Since part of the purpose of CEQA review is to identify significant impacts and availabic mitigation,we believe it is necessary to include the results of the entrainment study as part of the review for the proposed desalination facility. o Finally,we note that the California Energy Commission (CEC) and the Regional [ Water Quality Control Board(RWQCB)will use the results of the entrainment study bt to help determine whether alternative cooling systems may be feasible and necessary at the power plant The CEC recently provided a I O-year certification for the power plant, and the power plant's NPDES (National Pollutant Discharge Elimination System)permit is subject to review and renewal by the RWQCB every Eve years, r Since alternatives to the existing cooling system such as dry cooling,wet-dry cooling, and others will lilcely be considered during these upcoming reviews and within the approximate 20-year planum-horizon of this CEQA analysis, the EIR should evaluate the effect that selecting a cooling system other than once-through cooling would have on the desalination facility, and should also evaluate the effect the presence of an existing desalination system migllt have on the choice of alternative cooling systems. The issues and concerns above regarding marine biological resources and entrainment should also be incorporated into the EIR's cumulative impacts analysis. 'Iltis issue is'of particular concern because the offshore waters that would serve as both source and receiving waters for the facility are subject to significant ongoing stresses that adversely - affect water quality and biological resources. Additional adverse effects related to entrainment or brine discharges maY exacerbate these existing adverse conditions. • Modeling water aualit,,and biological impacts: The EIR needs to include more detailed information about the modeling and assumptions used to develop and evaluate the `worst-case"scenario for impacts to water quality and marine biological resources. The modeling results provided show increased salinity extending over up to several hundred bu acres of water surface and benthic habitat While the EIR points out that part of this increase is within the natural range of variability in seawater, it does not describe how �- that variation correlates seasonally or with ambient ocean conditions iri the vicinity of the r discharge, and does not describe the:effect an ongoing increased salinity discharge would have on marine organisms that would otherwise experience seasonal or ambient conditions. -Additionally,the modeling identifies an impact that may be significant and All Leger re: `ResPonser to Comments ' on POSeid0n..Seawater Desalination Project DEIR May 8, 2003 Page S of 6 that would occur over a relatively large area,but does not evaluate mitigation measures to avoid or minimize that impact, such as structural or operational changes to the facility's bu outfall. We recommend these be included in the Ea. •, • Lack of site-speci;7c or goneral imbrrnation:V.e also requested than the EIUK inCiiidC information about the impacts of other similar desalination facilities and mitigation measures used at those facilities. We believe this would help determine whether there ' were issues or knowledge gained elsewhere that might be applicable to the proposed project. The City's response states that this information is not necessary, However,we by refer back to our concerns mentioned above about another of the City's responses,which .' stated that the findings of the current entrainment study are not needed, either. We are therefore left with no recent, applicable data about the effects of desalination facilities in general, or about this proposed facility in particular. The absence of one set of these data maybe acceptable,but the absence of both provides very little credible information on which to base the CEQA analysis. Inadequate Alternatives Analysis: There are likely several reasonable and feasible ' alternatives that have not yet been incorporated into review of the proposed project, and that will be needed both for completeness under CEQA and for conformity to Coastal Act policies. In our November comment letter, we requested additional alternatives analyses be done that identified other sources of water that might be used to provide drinking water. In its response,the City stated that alternatives were not needed because the use of ocean water would not cause significant impacts. However,based on our concerns about entrainment and water quality mentioned above, we believe the City should reconsider this position, since the proposal may indeed result in significant entrainment impacts. r� The City also stated that other water sources were not being considered because part of the project purpose is to provide a reliable local source of drinking water, and that sotnces such as reclaimed or recycled water were not considered local since they were bW derived from imported water or groundwater. We.note,however,that the recent Metropolitan Water District(MWD) document, "Report on Metropolitan's Water Supplies"(March 25,2003) considers recycled water as a local water source. Since the proposed facility is within the MWD service area, and is subject in part to MWD planning projections,we believe it would be reasonable to define the sources of supply consistent with the definitions used by MWD. This approach would allow for an ' - ' adequate alternatives analysis under CEQA and would also allow for consideration of recycled or reclaimed water sources that may have fewer adverse environmental impacts. Even if seawater were to be the only water source evaluated, there are several methods of using seawater, such as beach wells, covered intakes, etc.,that would avoid or reduce what maybe significant levels of entrainment caused by using a once-through ocean water cooling system. While these alternatives may require that new structures be built or existing structures be modified, the construction-related impacts may be relatively short-term and minimal compared to the ongoing adverse entrainment effects that may occur. We therefore recommend the EIR provide additional evaluation of these or other similar alternatives. L -errer 7�': ".FCesponses to Comnzenis' on Poseido»S'eawax: Le- aiinarion Project f�LI Mai; 2003 Pane 6 of F, • Inadequate Analysis of Growth-Inducement: The FIR does not provide adequate L information about the known or likely use of tnc waicr to be produced by the proposed l facility;therefore, it is not possible to adequatel- evaluate the growth-related or cumulative impacts of that use. Regarding growth-inducement, c RQA requires a. discussion of ho-AT the proposed project could foster grow Lh. 77ie analysis should, at the very least, include information about where the produced water is either lmown to be _ bx going(due to existing contracts to purchase the water) or is likely to go (based on the. economics of producing and transporting water from coastal, low-elevation Huntington L Beach to other locations in the water supply service area). The analysis should also evaluate effects of the potential growth on the resources of the surrounding area,pursuant to the CEQA guidelines, and should also address the impacts of that growth on coastal resources, as required by the Coastal Act. J In closing,we recommend that these concerns be incorporated into either a Final or 'L Supplemental Draft EIR before review be,-,ins,to determine the proposed project's conformity to the Coastal Act. Thank you for the opportunity to comment, and please feel free to contact me at by (415)904-5249 or tlusteria)eoastal.ca.aov if you have any questions. - Since ly, . l Tom Luster Energy and Ocean Resources Unit Cc: Poseidon Resources-Billy Owens U.S.Fish &Wildlife Service-Jonathan Snyder L CA Dept.of Fisb &Gatne-William Paznol as Regional-Vdater Quality Control Board, Santa Ana Region-Mark Adelson State Lands Commission-lane Smith L L r L ..��, STATE DF CALIFDRNIA-THE RESOURCES AGENCY GRAY DAVIS,GOMM-ION' CALIFORNIA COASTAL COMMISSION 4} FREMONT. SUITE 2000 SAN rRANCTSCO, CA 94IV5.2219 VOICE AND 7'DU (415) 904-5200 ' FAX (415) 904-5400 1 July 7,2003 rr AVIA r.Sri.arrT rj r^rY 4 32^r$-1544 Planning Commissioners City of Huntington Beach Planning Department 2000 Main Street ' Huntington Beach, CA 92648 RE: City of Huntington Beach Review of Proposed Poseidon Desalination Facility Dear Commissioners: �I I have been asked to respond to several questions about the City's review of the proposed P Poseidon_desalination facility as it relates to Coastal Act and related CEQA requirements. The main questions relate to the overall scope of the Environmental Impact Report(EIR) and its adequacy in addressing elements of the proposed project that would affect coastal resources. Our primary concern, as expressed below and in comment letters provided earlier during the CEQA review process,is that the EIR does not yet adequately describe the proposed project's impacts to coastal resources and the mitigation measures that may be necessary to address those impacts. We believe,therefore,that the EIR does not yet provide an adequate basis for making a decision about the proposal's conformity to the City's Local Coastal Program(LCP) or the Coastal Act. This letter discusses several,but not all, of our concerns about the currently inadequate EIR and recommends that the City significantly revise several sections of the EIR before adopting it as final. bZ Part of our interest in this proposed proj cot and in having the CEQA work done adequately is that the proposal would be the first coastal desalination plant in California in about a decade, and would be the largest coastal desalination facility in the U.S. Given its location in California's coastal zone and its potential to cause significant impacts to coastal resources,we believe the CEQA review should be thorough enough to adequately inform decision-makers about the-- proposal's confomsity with applicable policies of the City's LCP and the Coastal Act_ To reflect that interest, Coastal Commission staff previously provided comments during several stages of the City's CEQA review, including a June 14,2001 letter in response to the City's Notice of Preparation, a November 4,2002 letter on the Draft EIR, a May 8,2003 letter regarding the Response to Comments and a June 3, 2003 in response to requests from several Planning Commissioners. The comments focused on elements of the proposed project that will need to be evaluated during the coastal development permit review by both the City and the Coastal _. . . t n Comments to Kuntin o o Beach Planning Commission re: Poseidon Desalrnatzon EIR July 7, 2003 Page 2 of 6 Commission.1 This letter expands on a number of the comments we provided previously, including those related to growth-inducement, entrainment,project and mitigation altematives, - and the ability of state and local agencies to adequately regulate the proposal. We have also been Z asked to address the scope of the City's role as lead agency in review of the project. r,+_�__ r n h w Tl. ih b 1 t b tit the+ ' do+iron t cope � -GXLGIIt Vl l.]�arti review: .�u�:rL'cave been several CiueSuvnS avv,.. j;:r1S v�.v���� 9..vyv the City's CEQA review and about whether the City, as lead agency,needs to consider project impacts or mitigation measures outside of its jurisdiction. The CEQA statute and guidelines are F very clear in establishing that a lead agency is to review a proposed project in its entirety, L without limiting its review to the particular jurisdiction of that agency. For example,the CEQA definition of"lead agency"inakes no distinction about only reviewing aspects of the proposal within the agency's jurisdiction; in fact, the lead agency is required to consult with other agencies that have jurisdiction over parts of the proposal and incorporate their concerns and recommendations into its review.2 If lead agencies were required to address only those issues within their jurisdiction,many proposed projects would be reviewed under a number of separate EIRs produced by several different agencies, which is clearly not the case. One example with this proposed project of an element that may be outside the City's jurisdiction ea but within the City's responsibility as lead agency is"growth-inducement". In our previous i- comment letters, Coastal Commission-staff requested the EIR include a more thorough analysis of the growth-inducing effects of the proposed project. However,the discussion of growth- inducement in both the EIR and the Response to Comments is inadequate,in that it only VL describes the 50 million gallons per day of water to be provided by the facility as being used as part of the overall water supply for somewhere in Orange County or Southern California. Apparently, the City has been informed that the applicant has contracted to provide half of the L produced water to the Santa Margarita Water District "At the very least,the EIR should evaluate the growth-inducing effects of these 25 million gallons per day on the Water District's service {� area, and should also determine where the remainder of the water will be sent and its anticipated (_ growth-inducing impacts. Even if the contract includes conditions (which is a normal aspect of contracts),it is reasonable to assume that the water is meant to be provided to the Santa J� Margarita Water District and therefore.rises above the level of-being speculative. Additionally, this information about growth-inducement will be needed as part of the Coastal Commission's permit review. r _ 1 'Note:Part of the proposed project is within the retained jurisdiction of the Coastal Commission and will requac a coastal development permit from the Commission. Portions of the proposal are also within the Commision's appeal jurisdiction;therefore,the City's decision as to whether or not to issue a coastal development permit may be appealed to the Commission. Section 21067 of the CEQA Statute defines"lead agency"as meaning"the public agency which has the principal responsibility for carrying out or approving a project which may have a significant effect upon the environment". Other sections of the C1;QA Statute and Guidelines identify the lead agency's obligation to coordinate with other agencies with jurisdiction,to adequately incorporate the concerns and responsibilities of those agencies,and to produce an environmental document that adequately assesses the proposed project's environmental effects and necessary mitigation measures. f L Comments to Huntington Beach Planning Commission re: Poseidon Desalination EIR July 7, 2003 Page 3 of 6 Entrainment: The proposed project, in-and of itself,would result in entrainment and mortality �'. of marine organisms at what could be significant adverse levels of impact beyond what is caused by thepowcr plant;however,this is not addressed in the ELR. Information about entrainment caused by the desalination facility is needed as part of the EIR for several reasons—first,to - dctcrrnine the effects of the facility on ti'ie marine environment;next,to identify mitigation measures that may be necessary to.address those effects; and finally, for both the City and the Coastal Commission to determine whether the proposal conforms to policies of the City's Local Coastal Program and the Coastal Act. The analysis needed in the EIR to determine conformity to these policies is separate from any requirements under the federal Clean Water Act or state water quality standards. The City's LCP Policy 6.1.19 states: "Prior to approval of any new or expanded pumping facilities, require the provision of maximum feasible mitigation measures to minimize damage to marine organisms due to entrainment in accordance with State and Federal law.". Sections 30230 of the Coastal Act states: Marine resources shall be maintained, enhanced, and where feasible, restored. Special 4 protection shall be given to areas-and species of special biological or economic signfcance. Uses of the marine environment shall be carried out in a manner that will ,� surtain the biological productivity of coastal waters and that will maintain healthy Cb 1i populations of all species of marine organisms adequate for long-term commercial, recreational, scientific, and educational purposes. LSection 30231 of the Coastal Act states: The hiological productivity and the quality of coastal waters, streams, wetlands, estuaries, and lakes appropriate to maintain optimum populations of marine organisms and for the protection ofhuman health shall be maintained and, where feasible, restored through, among other means, minimizing adverse effects of waste water discharges and entrainment, controlling runoffpreventing depletion of ground water supplies and substantial interference with surface water flow, encouraging waste water reclamation, maintaining natural vegetation buffer areas that protect riparian habitats, and minimizing-alteration of natural streams. The proposed facility includes new seawater pumping facilities(see,for example,Exhibit 3 in the Draft EIR); therefore,the above LCP policy applies to the proposal. However,neither the EIR nor the CDP Staff Report identify the entrainment effects associated with new seawater pumping or the mitigation measures needed to minimize those effects. In fact,the EIR analysis erroneously assumes that any entrainment mortality that would be associated with the desalination facility is already occurring due to power plant operations. In the City's Response to Comments (issued March 21,2003,p. 8),the City stated:"No increase in entrainment or impingement of marine organisms would occur upon project implementation, as project operation would not result in an increased intake of ocean water through the AES intake Comments to Iluntington.Beach Planning Commission re:Poseidon Desalination EIR July 7, 2003 Page 4 of 6 structure. The desalination facility would divert ocean water for desalination subsequent to its use as cooling water by the AES Generating Station." However, in the Errata section of the same document,the City adds the following to the EIR: "It should be noted that the proposed project would utilize pumps circulating a total of 126 mgd. These pumps would operate constantly and would be independent of the AES Generating Siauon .Should the AES facility r t L. l:tc,rY,nylrl con, to nrnrinr .nnei dt riblit_p_, Cease`LO operate,the prvposCd desalu.u.i�^r a.iL') c....j �e �t :^ potable water." The proposed desalination facility would cause entrainment mortality when it operates while the power plant is not generating electricity. Although the desalination facility is tied closely to the power plant,there arc likely to be times when maintenance requirements or market conditions would cause the power plant to shut down, and entrainment mortality occurring during those periods would be due largely to desalination. During those periods when the power plant is not producing electricity but is only running its circulation pumps,the entrained organisms are not likely to experience the same mortality rates since they will not be subjected to the higher temperatures and pressures that occur during power generation. However,the desalination process itself will cause entrainment mortality and without the-results of an appropriate entrainment study, it is not possible to determine the type and scope of those impacts or the mitigation that may be needed,nor is it possible to ensure compliance with CEQA or applicable IL LCP or Coastal Act requirements. Therefore, the characterization in the EIR that there would be no change or increase in entrainment is in error, and the document does not include the analysis necessary to conform to CEQA or the LCP and Coastal Act sections cited above. �,- cbI To address this inadequacy, at the very Ieast,the City needs to include in the EIR the results of r an entrainment study describing the entrainment and water quality impacts associated with the proposed use of 126 mgd of ocean water, and describes the maximum feasible mitigation measures-to minimize these entrainment impacts. The entrainment study being implemented by AES, due to start later this month,wiII likely be adequate for purposes of the EIR. Although the study results will not be available for approximately 14-16 months, they are necessary as part of the EIR's environmental review. [Note:We first identified the need for this type of information in our comment letter on the City's NOP in June 20011. At any time,the City or the applicant could have initiated the entrainment study on its own rather than wait for the AES study to be concluded.] �°- Results of this study are of particular interest for this proposed project because entrainment data have never been collected at AES Huntington Beach. Information provided previously about entrainment at the facility is based on data collected in the late 1970s from other power plants along the coast. Therefore, absent the results of the study about to be initiated (or a similar study using the same protocols),there is no recent,local,and scientifically valid data about the likely entrainment impacts that-would result from the desalination facility, and therefore no way to 1 determine conformity to CEQA, the LCP, or the Coastal Act. 3 We note further that the EIR does not adequately describe the relationship between AES and Poseidon,either as it L relates to operation of the power plant and desalination facility or as it relates to any leases or contracts between the two parties. As part of the application for a coastal development permit from the Coastal Commission,the applicant (Poseidon)will need to provide documentation ofthe underlying landowner's approval,along with any conditions of,that approval that may affect operations. lr r� Comments fo Huntington Beach Planning Commission re:Poseidon Desalination EIR July 7, 2003 Page S of 6 Project and Mitigation Alternatives: The discussion above on entrainment impacts and .� mitigation measures that may be necessary to address those impacts leads to consideration of alternatives. Without the results of the entrainment study,the EIR cannot adequately address alternatives that may be necessary to mitigate entrainment impacts. The current EIR dismisses �. the necessary alternatives analysis because of its conclusions that there would be no Increase In c:. entrainment. As shown above, this conclusion is not yet timely and may be erroneous. Therefore, along with incorporating the results of the entrainment study and determining whether there are significant adverse entrainment impacts, a revised EIR would need to evaluate whether there are feasible alternatives that would avoid or reduce those significant impacts. Again, this cannot be done before the entrainment study is completed,but would likely require consideration of altemativcs that could significantly alter the proposal,including using recycled water, siting the facility or pipelines in different locations, and others. Applicability and enforceability of local and state requirements: One important part of ' CEQA review is to identify the regulations that would apply to a proposed project. In a previous comment letter,we identified two specific concerns about this issue: ` Whether laws,ordinances, and regulations applicable to public entities providing a water supply apply differently, if at all, to private water suppliers; and, • Whether international trade law adversely affects the ability of state and local jurisdictions to regulate proposals such as this. Even though these issues may not be entirely within the City's jurisdiction,they are within the Cd City's responsibility as CEQA lead agency, since the answers to the questions raised will affect how and whether the proposed project's environmental effects are regulated. Regarding the first issue,the Coastal Act includes several policies that differentiate between public and private entities. We therefore again request that the EIR provide an analysis of this J� issue to ensure that the regulatory requirements and mitigation measures described in the document would indeed apply to this private proposal. Concerning the second issue,because of recent trade agreements and decisions by international trade tribunals,there is some question as j to how and whether local and state regulations apply to private entities operating in the international arena_ We again request that the EIR include an evaluation of-how international trade agreements,treaties, and laws may apply to this proposal, and whether anticipated ` environmental mitigation measures could be compromised. Closing: In summary,the existing EIR and the Response to Comments are not adequate for CEQA, nor are they adequate to determine whether the proposal conforms to applicable LCP or Coastal Act policies. To address these shortcomings,we recommend the City revise the EIR to Ce include the assessments described above. We also request that the City re-open the comment period for the EIR so that we may provide further comments on these and other areas of concern. Finally, we refer the City to our previous comment letters for more details on the issues raised in this letter as well as other issues raised about the adequacy of the EIR. Comments to Huntington Beach Planning Commission re:Poseidon Desalination ELR July 7, 2003 r Page 6 of 6 Thank you for attention to these issues. 1 hope this is helpful in your deliberations. Please feel free to contact me at (415) 904-5248 or at tlusterCcDcoastal.ca.trov if you have questions_ ce jr Sincerely, �I Tom Luster Energy and Ocean Resources Unit Cc: Poseidon Resources—Billy Owens (' Department of Water Resources—Jonas Minton, Chuck Keene Coastal Commission,Long Beach Office—Steve Rynas r F r- + - STATE OF CALIFORNIA—THE RESOURCES AGENCY ARNOLD SCFWARZENEGGER,ODy£aNOR CALIFORNIA COASTAL COMMISSION ,� a.S FREMONT, SUITE 2000 SAN rRA NC-ISC-0. CA 94105-22 f 9 tee. YoICE ANU -full (415) 904-5200 ` 1"(415) 904-5400 - y� December 8., 2003 �\ Mr.Howard Zelefsky,Planning'Director City of Huntington Beach 200 Main Street. Huntington Beach, CA 92648 RE: Comments on the City of Huntington Beach Environmental Impact Report(EIR) for the Proposed Poseidon Desalination Facility Dear Mr. Zelefsky:- I am writing regarding the City's environmental review of the desalination facility being proposed by Poseidon Resources. I received a copy of your November 17,2003 memo, Interoffice Communication from the City's Planning Department to the Mayor and City Council_ Members,which was written in response to concerns expressed by California Energy Commission (CEC)staff about the analysis of the proposed project in the City's EIR. I wish to provide some comments regarding three of the issues raised by the Planning Department's memo. These comments are meant to help ensure the City's decision conforms to the California Environmental Quality Act(CEQA) and applicable provisions of the City's Local Coastal Program and the Coastal Act. I am also providing copies of this letter to members of the Huntington Beach City Council to use in their deliberations on this proposed project. This letter does not address each as-of-yet unresolved concerns we have with the EIR as expressed in our previous comment letters,but focuses on three points raised in your recent C f memo: • First, the EIR does not use an appropriate baseline to establish the existing marine biology and water quality conditions at the site; • . Second,the EIR's use of the maximum allowable water volume described in the NPDES permit for the associated power plant does not equate.to CEQA's requirement to base impacts on existing physical conditions at the site; and, • 'bird,regardless of the City's eventual position on the above two points,the current version of the EIR is not adequate to determine whether the proposed project will conform to applicable provisions of the City's Local Coastal Program and the California Coastal Act. Each of these three points-is discussed in more detail below."We raised similar concerns in several comment letters we sent earlier during the EIR process, many of which highlighted inadequacies in the EIR that create what is likely a substantial understatement of the proposed project's impacts to marine life and water quality and result in insufficient information for decision-makers. Comment letter to City of Huntington Beach re:EIR for proposed desalination facility December 8, 2M � Page 2 of S ,— 1) The EIR does not use an appropriate baseline to establish the existing marine biology and water quality conditions at the site. The EIR bases its analysis and its determination of no significant adverse impacts to marine biology and water quality on the review done by the RWQCB during renewal of the power plant's National Pollutant Discharge Elimination System�—IN rDES)permit in June 2000. The RWQCB used a 1983 entrainment study as the basis for its NPDES decision. CEQA allows EIRs in some circumstances to use for baseline conditions the levels of impact identified in previous CEQA reviews. Your memo cites Fairview Neighbors v. County of Ventura as supporting this approach. However, because NPDES permit review is exempt from CEQA, it is not appropriate in this case to use it to establish baseline conditions. The NPDES permit review,pursuant to federal and state water quality standards, is meant primarily to determine whether the existing once-through cooling system at the power plant provides the"Best Technology Available"for power plant cooling. Section 15263 of the CEQA Guidelines specifically exempts NPDES permits from undergoing CEQA review (except in the case of new Cg sources, which does not apply at the AES Huntington Beach facility). This determination that NPDES review is CEQA-exempt, and that it involves a different type of review than the review required under CEQA,is further supported by the recent decision in City of Burbank vs. State Water Board'. If the City wishes to use an acceptable previous review in the EIR,it would be more 1 appropriate to use the CEC's more recent review from May 2001,-which was done as part of the CEC's Application for Certification(AFC)process used to review proposed new power plants and power plant upgrades. Section 15251 of the CEQA Guidelines r designates the review that occurs during this AFC process as"CEQA-equivalent", and the CEC process incorporates elements of CEQA review not required during NPDES )� permit review. In its CEQA-equivalent review,the CEC determined that the entrainment data at the facility were out-of-date, and required the power plant owner to perform a new entrainment study,which is currently underway2. The CEC's reasons for requiring an updated entrainment study are the same as the r reasons these study results are needed for the City's current CEQA review—to' L incorporate relevant and necessary information about existing conditions at'the project location,to determine whether the proposed project will cause impacts, and to determine t Fromp.20-21 of the decision:"We conclude that Water Code section 13389 not only relieves Rem onal Board of _ the requirement to prepare an ETR or cause an EIR to be prepared(pub.Resources code,§21100,subd_(a)),but also r relieves Regional"Board of those CEQA obligations that ordinarily are satisfied through preparation and consideration of an FIR, including the obligation to consider potential environmental impacts,project alternatives, _ and mitigation measures." Ile usual CEC review process,as evidenced in the recent Moss Landing and Morro Bay power plant proceedings, is to require up-to-dale entrainment data be provided before a permit decision is made. The CEC's review ofthe AES power plant was done under a special emergency provision meant to expedite decision-malzng during the Governor's declaration of a state energy crisis,and is the only recent proceeding in which the CEC allowed a required entrainment study to be completed after its decision. � r Comment letter to City ofHuntino on Beach re:ETR for proposed desalinatlonlacility December 8, 2003 Page 3 of 5 what mitigation measures may be necessary to address those impacts. By not using the more recent and CEQA-equivalent CEC review,the EIR is likely providing inadequate Cg information for decision-makers and likely understating the impacts of the proposed project. -- -— — -- _ �) I 17 le t l d "mod t nt�fr_ The �itc S LL5e of the 3CIa3�itauiu SitGrrali5I rra�Bi Vf➢ivauc ueSCr:....+ .� }it'f Plant's NPDES permit does not equate to CEQA's requirement to base impacts on _ existing physical conditions at the site. Section 15125(a) of the CEQA Guidelines states: / "An EIR must include a description of the physical environmental conditions in the vicinity of the project, as they exist at the time the notice ofpreparation is published, or if no notice of preparation is published,.at the time environmental analysis is commenced from both a local and regional perspective. This environmental setting will normalcy constitute the baseline physical conditions by which a lead agency determines whether an impact is significant," In addition to the NPDES permit review not providing the necessary CEQA-equivalent basis for the EIR,the maximum allowable flow established in the NPDES permit does not represent actual site'conditions. The EIR uses for its baseline the maximum allowable flow permitted in the power plant's NPDES permit (517 million gallons per day). However,the power plant has rarely operated at that maximum level and has generally operated for the past several years at levels far below that maximum(averaging Ch around 250 mullion gallons per day). This period of lower flow operations coincides with the time of the City's environmental analysis for the proposed desalination facility. ' Therefore, for this EIR,it is not appropriate to use the NPDES permitted maximum as the baseline, since that does not represent actual conditions at the site. ' We recognize, as noted in your memo, that there are various court decisions regarding how baseline conditions are to be determined for analysis under an EIR, and we also recognize that countervailing decisions on this issue are based largely on how the CEQA Guidelines apply to the particular facts of a proposed project. Fairview is one, as is the more recent decision on Save Our Peninsula Committee v. Monterey County Board of Supervisors,which discusses several of the factors to consider when establishing baseline conditions,including the recency of data and the use, where available, of documents and records showing actual rates of use. For this proposed desalination facility,it is clear that the facts support a characterization of existing site conditions based on far lower power plant operations than are described in the EIR and more recent entrainment data than are provided in the 1983 study- Without a more accurate description of the power plant's operational characteristics, and without a clear understanding of how the desalination facility operations will affect or will be affected by power plant operations, it is not possible to determine from the EIR what adverse effects may result and what mitigation measures may be needed. Comvnent letter to Cityo Huntington Beach re; EIR or proposed desalination facility of Huntington I`� December 8, 2003 Page 4 of 5 . r" Additionally, the EIR assumes that the desalination facility will not change power plant operations, and will therefore cause no additional entrainment beyond what would be caused by the power plant operating alone. As a result of this assumption, the ETR does not evaluate, as it should, how the high daily and seasonal variability of power plant operation will interact�ith the proposed"steady-state"flow of 100 million gallons per r day proposed for desalination operations'. The contradictory statements in the City's 1 record regarding this operating relationship make it impossible to tell whether this assumption is correct. For example,the EIR describes the desalination facility as using eh heated water from the operating power plant after it passes through the plant's condensers;the EIR's Errata section states that the facility would operate constantly and be independent of the power plant operations; and most recently,your November 17 memo states that the Facility would shut down when the power plant pumps shut down. Each of these scenarios could result in a very different range of adverse entrainment effects,but the EIR does not include an adequate analysis of any of the scenarios. 3 The current version of the EIR is not ade uate to determine whether the proposed q. P project will conform to applicable provisions of the City's Local Coastal Program and the California Coastal Act, l Finally,regardless of the City's eventual decision regarding the two points above,the l EIR in its current form is inadequate for determining conformity to at least one provision of the City's Local Coastal Program(LCP) and two provisions of the Coastal Act,all of , which apply to the proposed project. Policy 6.1.19 of the City's LCP states"Prior to Ci approval of any new or expanded seawater pumping facilities,require the provision of maximum feasible mitigation measures to minimize damage to marine organisms due to ,1 entmaitnnent in accordance with State and Federal law." The EIR clearly shows that the proposed project, a seawater desalination project,will require new seawater pumps. ' Additionally, Sections 30230 and 30231 of the Coastal Act,require,m part,that proposed projects restore the marine environment where feasible, and minimize the adverse effects of entra.i.nmenO. We note,for-example,that the environmental analysis of the country's only other recent large-scale desalination facility co-located with a power plant(in Tampa Day,Florida)estimated there would be an entrainment increase of between two and seven percent. These facilities likely have a different operating relationship than the one proposed between the AES Huntington Beach plant and the desalination facility,so while the actual change in entrairim nt in lIuntington Bcach is likely to be different,the review done in Tampa shows,at the very least,that assuming no entrainment increase may not be accurate, Coastal Act Section 30230:"Marine resources shall be maintained,enhanced,and where feasible,restored. Special protection shall be given to areas and species of special biological or economic significance, Uses of the marine environment shall be carried out in a mariner that will sustain the biological productivity of coastal waters T- and that will maintain healthy populations of all species of marine organisms adequate for long-term commercial, recreational,scientific,and educational purposes." Coastal Act Section 30231:"The biological productivity and the quality of coastal waters,streams,wctlands, estuaries,and lakes appropriate to maintain optimum populations of marine organisms and for the protection of human health shall be maintained and,where feasible,restored through,among other means,minimizing adverse effects of waste water discharges and entrainmerit,controlling runoff,preventing depletion of ground water supplies and substantial interference with surface water flow,encouraging waste water reclamation,maintaining natural y vegetation buffer areas that protect riparian habitats,and minimizing alteration of natural streams." l . , : Comment letter to City of Huntington Beach re:EIR for proposed desalination facility December 8, 2003 Page S of 3 As noted above,the EIR's determination that the desalination facility will cause no additional impacts to water quality or marine biology beyond those caused by the power plant is based on inadequate data and analysis. Minimizing entrainment impacts, as required in the policies cited above, first requires knowledge of what those impacts are. For the CEQA evaluation of this project proposing to use a large a-nourt of water from the impaired ocean waters off of Huntington Beach,relying on data over twenty years old does not provide that knowledge-it is as i f one were depending on a twenty-year old termite inspection report to determine if a house has termites. As stated earlier in this letter and in previous EIR comment letters to the City from Coastal Commission staff,current entrainment data will be needed during review of the proposed project's coastal development permit applications.to the City and to the Coastal Commission. We also note that the state regulatory agencies participating in the recently completed Desalination Task Force convened by the Department of Water Resources CI agreed that the environmental review for proposed desalination facilities needed to include up-to-date entrainment datas. The ElR's current determination that updated entrainment data are not needed has at least two consequences—first,it does not provide adequate assurance that the project will conform to the City's LCP and to the Coastal Act; and second, it does not allow the results of the study to be used as they are intended to be used—to allow decision-makers to determine whether the project will result in adverse impacts and whether design changes or mitigation measures will be needed to address those impacts. There is no benefit,therefore, in certifying the EIR without this information,since it is part of the substantial evidence needed by decision-makers to make an adequately informed decision. In closing, we recommend the City not certify the EIR at this time. We instead recommend that '? tY fy , at the very least,the City incorporate updated entrainment data into a revised EIR. This would C, better allow the environmental review to conform to the applicable provisions of CEQA,the Coastal Act, and the Local Coastal Program, and perhaps more importantly, ensure that impacts of the proposed project arc adequately addressed. _ ` Sincerely, Tom Luster Cc: City of Huntington Beach City Council members Poseidon Resources—Mr.Billy Owens California Energy Commission—Mr. Terry O'Brien Santa Ana Regional Water Quality Control Board—NPDES Unit See the Task Force's Final Report at:http://www.owue.water.ca.gov/recycle/desaUdesal.cfrn I S,f-__E OF CSLIFORT- 'IA-THE RESOURCES ACF.NCY [;RAY DAVIS,GOVERNOR CALIFORNIA COASTAL COMMISSION �. 1� 45 FREMONT, SUITE 20DO C SAN FRANCISCO, CA 94105-ZZ19 k VOICE AND iDD (415) 904-5200 FAX (415) 904-5400 . June 14,2001 Ms.Mary Beth Broeren City of Huntington Beach Planning Department 2000 Main Street P.O. Box 190 Huntington Beach, CA 92648 RE: Comments on"Notice of Preparation" of Draft EIR for Proposed Poseidon Seawater Desalination Plant Dear Ms. Broeren: Thank you for the opportunity to comment on the above-referenced Notice of Preparation(NOP) as required by the California Environmental Quality Act(CEQA). The NOP is for a proposed 50 million gallon per day reverse osmosis(RO)seawater desalination plant and associated water transmission pipelines. The facility is to be located at the AES Huntington Beach Generating Station(EBGS) in the City of Huntington Beach.. Based on the information in the NOP,it appears that the facility is proposed to be located at one of two alternative sites,both within the jurisdiction of the City's Local Coastal Plan, and will therefore require a coastal development permit from the City. However,the proposed project also involves discharge of brine into the Pacific Ocean,which is within the retained jurisdiction - of the Coastal Commission. This proposed discharge constitutes development as defined in ck Section 30106 of the Coastal Act', and therefore,the discharge will require a permit from the Commission. The comments in this letter are focused on aspects of the proposed project that may affect coastal resources. Those comments having to do with the proposed discharge are meant to allow the information produced during the City's CEQA process to be used in the Commission's review of the proposed discharge and its conformity with the Coastal Act. We have also included recommendations on other parts of the proposal for the City to use in its permit.review process. In addition to our interest in this specific proposal,the Commission has an ongoing interest in desalination as a coastal-related issue. In 1993,the Commission published a report, Seawater Desalination in California"which compiled information about desalination facilities in the state, the likely impacts of those facilities on coastal resources, and the policies of the Coastal Act that apply to these types of facilities. We have-attached a copy for your review, and we recommend that applicable information in this report be used in your CEQA review. Development'means,on land,in or under water,the placement or erection of any solid material or structure; discharge or disposal of any dredged material or of any gaseous, liquid, solid, or thermal waste..." NOP Comment Letter:Poseidon desalination facilizy, City of Huntir_g5on Beach June 14, 200.1 Page 2 of 4 f General Comments: Development in the coastal zone must conform to the policies-and standards of the California L_ Coastal Act, and as applicable,the local jurisdiction's certified Local Coastal Plan. We concur C� ' With the'i7eed o evaluate the issues identified in u e ,. ;including the r uir er t e ral to t �d +h �TOD, e1 erri t _o � a_ `r imnart iTiovnort:n,elym ' -o+, cumulative, n, grogh-inu,�ing,., The nF tl�r.rr�mrr+ncal EIR should include a thorough evaluation of growth-inducing impacts. The NOP states that the proposed project"is intended to supplement existing Orange County water supplies and is not intended to foster additional growth or accelerate growth. However, depending on the ultimate destination of the project's water supply, provision of additional potable water may lead to growth-inducing impacts"(NOP,p. 9). The proposed project would provide 50 mullion gallons per day of additional potable water. This is apparently in the upper size range of desalination facilities around the world. It is unclear how CM this water would be used and how it will supplement existing supplies without fostering additional_growth. This issue should be evaluated thoroughly to determine the types and extent of potential growth-inducing impacts. The DEIR should also identify any long-term commitments made or proposed to provide water to specific entities. The assessment of growth- inducing impacts should also describe-current or feasible measures that would reduce or eliminate the need for this facility. This should include mitigation measures such as conservation and reclamation, growth,planning,and zoning policies of local governments in the proposed service area, and other similar measures. The CE A review should incorporate the findings of other studies being done at the facility site. L The project site was recently part of a review by the California Energy Commission to retool the Huntington Beach Generating Station(BEGS). The Energy Commission expedited its review to allow the increased electrical supply to be available during the summer of 2001. As part of the expedited review,the Energy Commission allowed several studies of potential impacts to coastal resources and necessary mitigation measures to be developed after project approval and after the cn facility was operating. These studies will evaluate water quality and biological impacts associated with the ocean intake and discharge system,proposed to be used by'the desalination facility. They also include a study meant to determine whether effluent from the nearby Orange County Sanitation District outfaD is being drawn into the area of the BBGS intake. The Coastal- L Commission will need results of these studies to determine whether the discharge from the proposed facility conforms to the policies of the Coastal Act. We recommend that the study results be incorporated into the EIR process as part of the necessary evaluation of the proposed facility's potential environmental impacts. Impacts identified at other desalination plants:the.DEIR should include review discharge-related impacts identified at other desalination facilities in California. The review should determine CO whether monitoring requirements at those facilities are adequate to identify impacts and establish necessary mitigation measures, and whether similar or improved requirements are appropriate for the proposed facility. N NOP Comment Letter.-Poseidgn desaZination faci,'zry, City of I-Iuntina on Beach June 14, 2001 Page 3 of 4 Enert*yUse: the Coastal Act requires that new development in the coastal zone minimise energy consumption. Reverse osmosis desalination facilities arc energy-intensive. The 1993 report cited above shows cncrgy requirements for reverse osmosis facilities in California ranged from about 6,500 to 12,000 kilowatt-hours per acre-foot of production. A facility operating within this _ range of energy demand and producing 30 million gallons (153 acre-fee!}per-day would require between approximately 900 and 1800 megawatt-hours oT cicctriciry. Cp The DEIR should provide an analysis of the energy use required by the proposed facility,the effects of this energy demand on local and regional energy supplies, and a discussion of feasible methods to minimii.e energy use at this facility. Also, given the current uncertainty of energy supplies and prices,these analyses should be done using a reasonable range of possible energy prices. Specific Comments on NOP: p. 4 Other Agencies Whose Approval is Required(and Permits Needed): please add"Coastal Cq Commission—Coastal Development Permit" p. 13 Hydrology and Water Quality: the DEIR should include a thorough discussion of the relationship between desalination plant operations and power plant operations. This should include an evaluation of discharge water quality when both facilities are operating Cr i and when only the desalination plant is operating, along with the effects of those discharges on receiving water and biological resources. Reverse osmosis desalination also requires maintenance with various alkaline and acid cleaning agents and anti-scaling chemicals. The DEIR should include a description of the types, amounts, and toxicity of materials to be used,the frequency of their use, and their fate and transport in the discharge system. C$ As mentioned above in the General Comments, the Commission will need-results of the studies being done for-the power plant discharges as part of its review for the proposed discharges from this desalination facility. p. 16 Transportation/Traffic:the DEIR should evaluate the transportation and traffic impacts _ associated with any growth-inducing elements of the proposed project. For example,if Ct the additional water supply is likely to result in increased growth rates in local cities,the DEIR should include an evaluation of the increased traffic impacts in those locales. p. 16 Biological Resources: similar to the comment in Hydrology and Water Quality above, the DEIR should evaluate the effect of the discharge water quality on marine biological resources in and near the outfall, and should also evaluate the indirect and cumulative CV impacts of the proposed discharge being added to the existing impaired conditions of the receiving waters. The Commission will need this information in its review of the proposed discharge. NO1' Comment.Letter: Poseidon desalination faciltyy, City) of Huntington Beach June 14, 200.1 Page 4 of 4 One of the studies being done as a condition of the 1-1130S re-tool is to determine the effects of impingement and entrainment on marine biological resources. The DEIR CU should incorporate the findings of this study into its review, and should further evaluate any difference in impingement, entrainment, and mortality rates for organisms that go through the inta;;e;discharge system during power plant operations only and during � 4dons of both fay lities simultancously. 4 p. 20 Noise: the DEIR should include a thorough evaluation of expected noise Ievels at the Facility, at nearby residences, and at public recreation areas at the adjacent beach. The C V evaluation should include an assessment of how anticipated noise levels will affect coastal resources,including public access and recreation_ = p 22 Utilities and Service Systems:the document states that the proposed facility will generate -- approximately 20 tons per day of non-hazardous dewatered solid waste. The DEIR 1= should describe the location(s)and methods of disposal for this waste and the effects of this additional waste load on the active life of the disposal sites. CW IFAdditionally,the DEIS should discuss the conceptual pipeline alignments and the purpose.for selecting these particular alignments. Specifically,the discussion should include the water supply systems available along these selected pipeline routes and the cumulative and growth-inducing impacts associated with connecting the proposed pipeline with these systems. p.24 Recreation:see comment in.Noise section, above. CX Again,thank you for the opportunity to comment. Please contact me at(415)904-6093 or Cy tluster@,coastal_ca.aov if you have questions or would like more information. We look forward to continuing our involvement with the environmental review of this proposal. Sincerely, - t Tom Luster _ Environmental Specialist Energy Unit 1, Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report,or .2.0 RESPONSES TO COMMENTS Response No. 2 California Coastal Commission Energy and Ocean Resources Unit Tom Luster 2a. This text provides an introduction to the comment letter, and does not require a response. 2b. This paragraph provides an overview of comments discussed throughout the comment letter. No response is necessary. 2c. The desalination facility, as proposed, cannot operate the cooling seawater intake pumps independently of the HBGS. As stated within the DREIR on page 4-7 and Appendix C, from 1980 through July 2003, HBGS pumps have been in operation 98.8 percent-of the time. Like all large power generation facilities, there are scheduled outages when maintenance is performed. During times when the HBGS cooling water system is not operating, the desalination facility would not produce desalinated water. Instead, the facility would pump previously desalinated water through the distribution system from its aboveground product water storage tank, which would have a capacity of 10 million gallons. Refer to Response 1 g, above. 2d. As indicated by the comment itself, the commentator has had no less than six separate occasions to comment on the project. The commentator_states that "several significant issues" from past comment letters "have not yet been adequately addressed in the current DREIR" Because this comment does not specify any specific"significant issues", a more detailed response is not possible. Instead, the commentator incorporates five previous comment letters by reference. - In accordance with CEQA Guidelines Section 15088.5, those who desired to comment on the DREIR were directed to submit new comments. Accordingly, comments received during the earlier circulation period do not require any response. "The lead agency need only respond to those comments submitted in response to the recirculated revised EIR." Although responses to the prior comment letters were previously made and are not required for the DREIR, each of the prior comments has again been responded to here. See Responses 2at through 2cy, below. 2e. Section 3.6, AGREEMENTS, PERMITS, AND APPROVALS REQUIRED, Section 5.1, LAND USE AND RELEVANT PLANNING and 5.10, OCEAN WATER QUALITY AND MARINE BIOLOGICAL RESOURCES includes reference to a Coastal Development Permit (CDP) from the California Coastal Commission (CCC) on pages 3.46, 5.1-9, and 5.10-17. 2f. As explained in footnote 2 on page 3-38, the DREIR presents information provided in both the existing 1998 California Water Plan and the draft 2004 California Water Plan. In April 2005, after the DREIR was made available to the City of Huntington Beach August 17, 2005 61 l Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS r public for the CEQA mandated 45-day review period, the Department of Water Resources released the public review draft of the latest California Water Plan — 1_ Update 2005. This Update 2005 report will not be adopted until Fall 2005. This DREIR presents information provided in both the 1998 Plan and the public review draft of Update 2005. On- page 2-10 the existing 1998 Plan is incorporated by reference. In response to this comment, the DREIR will now also incorporate by reference the public review draft of the California Water Plan - Update 2005. Refer to Section 3.0, ERRATA. i 2g. The statement of objectives on page 3-45 complies with the requirements in (_ CEQA Guidelines Section 15124(b). 2h. Local groundwater supplies are generally considered to be "reliable" by water industry professionals. However, as stated in the DREIR on page 3-44, the Orange County Groundwater Basin .does not provide an unlimited supply of ,= water. Over the years the Orange County Water District (OCWD) has engaged in significant and continuous artificial recharge operations in order to provide Orange County water purveyors with 200,000 to 350,000 acre-feet per year of f supply while managing the accumulated overdraft so that there is no irreparable damage to the resource. One objective of the proposed project is to provide a Y1 source of water that is sustainable even during times like 2003 when OCWD took action to reduce the rate of withdrawal of local groundwater supplies. r 2i. Refer to Response 1 h, above. In addition, certain contaminants (i.e. nitrates) currently accruing in the Orange County Groundwater Basin could be reduced if Orange County water purveyors decide to use water produced by the proposed _ project to recharge the Basin. j 2j. Refer to Response 2c, above. _ 2k. The assertion that the DREIR analysis of ocean impacts was based on a presumed temperature range at the intake of 120 to 190 C is incorrect. The hydrodynamic modeling of the project's ocean impacts is contained in Appendix- C of the DREIR. There the reader will find that 7,523 computer simulations of the project's ocean impacts were developed based on ocean conditions that occurred prior to re-tooling of the HBGS (see Section 5 of Jenkins and Wasyl, 2005). During these simulations, ocean temperatures were varied in the hydrodynamic model between 9.90 C and 25.10 C, according to the historic { observations found in Figure 3.23 of Jenkins and Wasyl (2005). An additional 578 computer simulations of project impacts were performed using ocean conditions occurring after re-tooling of the generating station. Ocean temperatures used during the post re-powering simulations varied between 11.90 C and 22.6° C, as reported in Figure 5.18 of Jenkins and Wasyl (2005). Therefore, the DREIR analysis was certainly not limited to a truncated range of ocean temperatures as presumed by this comment, but rather encompassed the entire range of variability contained in the full period of record. 21. Refer to Response 2c, above. r City of Huntington Beach August 17, 2005 62 a. u' 4p r it�ra� Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report,, 20_ RESPONSES TO COMMENTS 2m. Local ocean water quality concerns in the vicinity of the project site include the q Y tY P J Orange County Sanitation District (OCSD) discharge, Santa Ana River, Talbert Marsh, and miscellaneous urban dry weather runoff and storm water discharge points (see DREIR Appendix E). The proposed project would not result in cumulative impacts in association with these various discharges, since the area of impact would be relatively localized and most of the marine organisms living near the HBGS also occur in other areas of the Southern California Bight (SCB), where naturally occurring salinities can be higher than what is anticipated at the HBGS outfall. In addition, the combined impacts of the proposed project and local discharges are not anticipated to be significant. 2n. The desalination facility, which includes both the water treatment process and the storage water and delivery systems will operate continuously by delivering fresh potable water to the distribution system 24 hours per day and 365 days per year. The desalination treatment process will be shut down for a period of 6 to 8 hours once every 6 to 8 weeks when HBGS completes heat treatment. The downtime of the desalination treatment process during the hours when a heat treatment event occurs will be compensated for by operating the desalination treatment process at maximum capacity during the rest of the day (i.e. for 16 to 18 hours before or after heat treatment). A detailed description of the heat treatment process is described on page 4-7 of the DREIR. During HBGS heat treatment operations and when the desalination facility's treatment process is shut down, desalinated water will be served to the customers from the on-site product water -storage tank. To assist the power system in times of high demand, the desalination facility will conduct load management/shifting to reduce demands during high peak energy periods. The modular characteristics of the reverse osmosis system allow for cycling water production without shutting down all water production. During high peak energy periods, the treatment process may be turned down and water will be delivered to the system from the on-site storage tank. During off peak energy and higher water production periods the treatment process will produce water to deliver to the system and replenish the storage tank resulting in an average of 50 MGD. This shift of a portion of the desalination facility water treatment production from peak to off-peak period of municipal power demand will help in reducing the overall maximum load on the power grid and thereby be more energy efficient. Variations of HBGS energy production over the course of a given day will not affect the desalination facility's operation. The specific operating.conditions of the HBGS and their effect on the operation of the desalination facility are described on page 3-20 of the DREIR, "Project Site Lease" section, pages 3-20 & 3-21 "Proposed Physical Connection Between the Desalination Facility and the HBGS" and pages 4-6 and 4-7, "Alternative Modes of HBGS Operation". Even if HBGS is not producing power and is operating in standby mode (HBGS pumps a low flow rate of 127 MGD of seawater for operational readiness), the desalination facility will be able to operate and produce 50 MGD of fresh potable water. The only time when the HBGS operations will have an effect on desalination facility operations is during heat treatment events as discussed above. City of Huntington Beach August 17, 2005 63 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS 2o. The desalination facility operations will not require additional seawater use by HBGS. After installing the desalination facility, the HBGS will continue to pump between 127 MGD and 514 MGD of source seawater for cooling as is permitted today. The HBGS permit allows the generation station to take up to 514 MGD for 24 hours per day and 365 days per year without any constraints on the time of r the day, year or frequency. The minimum HBGS cooling water flow needed for t the operation of the desalination facility. is 127 MGD. This flow is the same as the minimum flow that HBGS takes out of the ocean under any operational mode ;� as described on pages 4-6 and 4-7 of the DREIR. L The potential increase of the HBGS intake cooling water flow of 10 to 12 MGD, is a speculative assessment assuming that all of the energy the desalination facility uses is generated at the HBGS. As described on page 5.6-12, DREIR, "the facility's electrical power source would be controlled by a power marketing company, which, in consultation with the California Independent System Operator (Cal ISO), would obtain power from the HBGS and/or the California power market at the lowest cost possible" and "...the project's electrical demand would be met by dozens of power plants connected to a regional power supply source, with many of these plants located outside of Southern California." It 1, should be further noted the operations of the desalination facility will not require any changes to the HBGS's State regulated operating conditions. r The stated desalination project power demand of 30 to 35 MW includes the energy needed to pump the produced water into the regional distribution system. r This energy demand is already incorporated in the evaluations of the DREIR. 2p. The commentator makes assumptions related to the high desalination facility intake water temperature and the alleged associated need for collection of more seawater to "cool" the power plant discharge and to therefore cause additional impingement and entrainment. These assumptions are incorrect and are not based on factual information pertinent to this project. As indicated in Appendix C C, page C-113 of the DREIR, the actual HBGS data show that the cooling water discharge temperature averages 820 F. This value is below the "efficiency" temperature threshold of 950 F, established by the writer. The actual maximum threshold for feed water temperature for seawater membranes specified by the membrane manufacturers is 1130 F (451 C), not 951 F as established by the author. As indicated in Appendix C, page C-113, of the DREIR, based on a 20.5 year record (1980 to 2002) of the ambient ocean water temperature in the HBGS intake area, the maximum daily mean temperature on record was 770 F. The actual temperature increase after HBGS use was 180 F. At a temperature increment of 180 F, the highest temperature of the feed water to the RO membranes was 771 F + 181 F = 95° F, which is at the writer's temperature limit and significantly below the actual membrane temperature specification ;- requirement of 1130 F. F City of Huntington Beach August 17, 2005 64 l.tf Seawater Desalination Project at Huntington Beach a. RESPONSES TO COMMENTS Recirculated Environmental Impact Report _ 2.0 RESPONSES TO COMMENTS 1 Even if HBGS was usingu to its maximum permitted temperature increment of P P P 300 F, defined in the plant's NPDES permit, during the warmest day of the last 20.5 years, the maximum possible temperature of HBGS discharge/desalination facility intake would have been 771 F + 300 F = 1070 F, which is lower than the actual membrane manufacturer specification threshold of 1130 F. Therefore, no additional seawater will need to be diverted to the desalination facility beyond approximately 100 MGD of HBGS cooling water discharge as indicated in the DREIR. ®r 2q. Refer to Section' 6.1 of the DREIR, SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES THAT WOULD BE INVOLVED IN THE j PROPOSED ACTION SHOULD IT BE IMPLEMENTED, which provides an analysis of the project's impacts in regards to non-renewable energy resources. 2r. "'Feasible' means capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors." (Public Resources Code Section 21061.1) "Cost," as referenced by the commentator, is but one of several interdisciplinary factors in determining feasibility. The analysis of cost (and other factors) within an EIR pertains to the identification of mitigation measures as opposed to the production costs and profitability expected by the project applicant. The cost of potable water is driven by market factors and is a fluctuating cost that is readily discernible by public and private water purveyors. 2s. Refer to Response 2c, above. 2t. As stated above, the proposed desalination facility would not operate independently of the HBGS, and would not result in significant marine biological impacts. Also refer to Response 2c, above. As stated by the commentator in 2f, all of the Desalination Task Force's findings -� and recommendations are included in the Draft 2004 California Water Plan. The Draft 2004 Plan has been incorporated by reference into this DREIR (see Response 2f, above). In response to this comment, the DREIR will now also incorporate by reference the Coastal Commission's report, "Seawater Desalination and the California Coastal Act (March 2004)." Refer to Section 3.0 of the Responses to Comments, ERRATA. 2u. Comments on the DREIR that make reference to methods or findings that may or may not be included in the Huntington Beach Retool Project Entrainment and Impingement Final Analysis being prepared by the CEC ("Final Analysis") are both inappropriate and potentially misleading since the Final Analysis has not been finalized nor made available to the public. The DREIR was prepared based on the impingement and entrainment data that was publicly available as of the date of the initiation of the 45-day public review period for the DREIR (see, Appendix T for a discussion of the methodologies and data analysis employed). Moreover, because the Final Analysis pertains to the potential impacts of the operation of the HBGS, it is not likely to provide new information of-substantial importance regarding the potential significant impacts of the desalination facility (see, CEQA Guidelines Sections 15088.5 and 15162). As stated on page 5.10- City of Huntington Beach August 17, 2005 65 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS 41 of the DREIR (and explained in detail in Appendix T), "Impacts due to operation of the proposed desalination facility in regards to impingement and entrainment are not anticipated to be significant. Also refer to Response 1 j, above. 2v. Refer to Response 2u, above. In addition, the volume of the entire Southern California Bight was not the source volume used in the report. The source water volume was estimated over the larval duration period as the product of the alongshore current movement and a cross section area determined by the cross shelf current. The alongshore current excursion was calculated by the sum of the maximum and minimum alongshore excursion. The cross shelf excursion was estimated by the maximum of the onshore or offshore movement. If the cross shelf excursion exceeded 7 km then the cross sectional area to 40 m depth was used. 2w. The EPA, in the Phase II 316(b). rule, specifically requires that 100 percent mortality be assumed to provide the most conservative assumption. Appendix T of the DREIR (INTAKE EFFECTS ASSESSMENT) did not assume 100 percent mortality in order to address a specific request by the City of Huntington Beach City Council to analyze the desalination facility's entrainment impacts. Entrainment by the desalination facility would result in 100 percent mortality and this value was used in assessing the effects of the proposed desalination facility. Refer to Response 1 j, above. 2x. The proposed desalination facility would be subject to all regulatory requirements, including National Pollutant Discharge Elimination System (NPDES) regulations. The project does not assume that any of HBGS' existing permits would eliminate the need for the desalination facility to comply with applicable Federal, State, and local standards. 2y. Regardless of whether an alternative intake system is considered the `Best r- Technology Available" (BTA), implementation of such a method was determined to be infeasible within the DREIR (refer to Response 1f, above). Alternative l_ cooling scenarios at HBGS are speculative at this point, and may require continued seawater intake. Refer to Response 1g, above. 2z. The proposed desalination facility would riot increase flows at HBGS, and thus would not result in impingement impacts. The impingement effects resulting from (� a potential reduction in HBGS flows in compliance with Clean Water Act (CWA) h requirements (which would presumably reduce impingement effects) would be unrelated to the proposed project. 2aa. During the low flow scenario (127 MGD), a maximum of 15.6 acres of ocean floor (benthic area) and 18.3 acres of the water (pelagic area) around the discharge r are expected to be exposed to water with a salinity 10 percent higher than the ambient seawater'. A variation of 10 percent higher salinity is within the normal variability of seawater and would be tolerated by most fish species. Moreover, �- the benthic area exposed to a-10 percent increase in salinity is relatively small and localized in relation to the amount of similar soft-bottom habitat offshore of ' DREIR p. 5.10-29. City of Huntington Beach August 17, 2005 66 Seawater Desalination Project at Huntington Beach ,,, ., RESPONSES TO COMMENTS Recirculated Environmental Impact Report '2.0 RESPONSES TO COMMENTS Huntington Beach. Also refer to Responses 2c and 2w, above, fora discussion of entrainment and variation in HBGS flows._ 2ab. This paragraph has been separated into segments to more clearly respond. Bold text denotes quotes from this paragraph. "The DREIR also concludes that the species within these areas would be exposed to these higher salinity levels are either tolerant of the higher levels or would be able to move out of the affected areas." The DREIR states that the increased salinity "footprint' resulting in the discharge plume would have the greatest effect on the benthic organisms living in close proximity to the discharge tower where salinities would be the largest. As detailed in Appendix C (HYDRODYNAMIC MODELING REPORT) this zone may extend 150 meters beyond the discharge tower depending upon the HBGS flow. The salinity level, particularly over the sea floor, will be sufficiently high to affect the benthic community living there. As discussed in Appendix S (MARINE BIOLOGICAL CONSIDERATIONS), this effect may result in changes in the benthic faunal composition, either abundances or total species number. It could potentially reduce the numbers of some species but increase the numbers of others presently living there. Another result could be the addition to this zone of species that can be ecologically successful (i.e., feed, grow, and reproduce) there because they are adapted to habitats having higher salinities (e.g., estuaries). However, away from this zone, at distances within 50 to 100 meters of the discharge, dilution of the plume of salinity by the receiving water will be sufficient to quickly lower salinities, both in the benthic and pelagic habitats, to less than 10% above ambient salinity (33.5 ppt). Benthic organisms presently living in areas that will experience this slight salinity increase could be reasonably expected to tolerate (i.e., adapt to) this slight salinity elevation. Fishes and other pelagic organisms that contact the elevated salinity plume would either swim or "drift"through it in a short enough period of time that they would not be affected. "Its primary basis for this conclusion is that are theses species exposed to P these expected higher salinity concentrations elsewhere in their range. This does not appear to be a valid comparison for at least two reasons. First, the analyses do not differentiate between the range of tolerances for a species and the tolerance of particular individuals of that species." Geographic salinity range of a species is a useful index of its salinity adaptation capacity that, in the absence of exhaustive laboratory testing of the salinity tolerances of each and every species occurring in the habitat near the HBGS discharge pipe, provides a valid first approximation of what the discharge salinities are needed to be to prevent adverse effects on the marine community. As detailed in Appendix S this general information was coupled with a literature review of salinity tolerances and with detailed salinity tolerance tests done on selected benthic species representative of the Southern California Bight. Benthic organisms are important because they have limited potential for moving out of City of Huntington Beach August 17, 2005 67 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS the permanent elevated salinity area. Mr. Steven Le Page, working at the Desalination Test Facility located in Carlsbad, CA conducted these tests. The 1_ results showed: 1) no effect of exposure to salinities higher than have been modeled for the discharge plume and 2) that salinity tolerances of species tested w far exceed the tolerances predicted by geographic range (e.g., sand dollars, sea urchins, and abalone live in 40 ppt). Tolerance tests involving gradual step increases in salinity (as might happen if plant flow rate changes) have been done and show no effect of incremental salinity increases on animal survival. These are entirely applicable to the question of benthic animal tolerances to changing conditions. Also, benthic species from the Southern California Bight have been t� maintained in aquaria at 36 ppt for extensive periods at the Carlsbad test facility (Appendix S). "For example, while individuals of a particular species may do well in higher salinity waters in other parts of the species' range, it does not mean that individuals living in the range of salinity offshore of Huntington Beach would do well if those waters were to change to having salinity concentrations at 110%to 164% of those existing ambient conditions." The broad geographic dispersal mechanism of most benthic marine invertebrates is by means of pelagic larvae. As these larvae have the potential to settle out in habitats having different physical characteristics, flexibility and the capacity to tolerate a range of conditions are intrinsic features of the genetic capacity of a species. r Appendix S provides information about salinity tolerance tests done with a few benthic species common in coastal waters of the Southern California Bight. These show no effect of exposure to salinities higher than those predicted by the combined HBGS and desalination facility discharge plume. Also, whether or not there are population-level differences in salinity tolerance or adaptation capacity is answered by tests, conducted at the desalination plant test facility in Carlsbad, CA, showing that locally occurring species (i.e., living in 33.5 ppt) can live, feed, grow, and have normal seasonal reproductive development in 36 ppt and tolerate higher salinities (tests done in 40 ppt)for long periods (Appendix S). With respect to the 164% salinity increase, Appendix C shows that low HBGS flow rates will result in higher midwater and bottom salinities at the discharge tower than will the higher flow rates. As reported in Appendix S and in the DREIR, salinity levels.of 38 - 40 ppt approach the upper tolerance point of many marine organisms. Under the low flow (127.MGD) scenario, salinities this high or higher occur around the discharge pipe out to nearly 150 m (an area of about 15 acres). Apart from the flow field in the immediate vicinity of the discharge tower, the area over which such an increase would occur is small and would not extend into the major flow field of the desalination plume. Salinities this high will not occur under average flow conditions. Low flow conditions will occur 42-48% of the time based on the 20 year historic data on HBGS flow rate. However, since the recent overhaul of some of the power plant's generators, the percentage time of low flow is less than 10%. If this trend is sustained, the occurrence rate of salinities as high as 55 ppt will be less. City of Huntington Beach August 17, 2005 68 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report. .: p. .2.0 RESPONSES TO COMMENTS Secondly, the analyses does not describe how quickly these organisms are able to adapt to these types of salinity differences. While the organisms may be able to adapt to the naturally occurring 10% change in salinity over ,the course of a year, they may not be able to respond to an immediate change of that range or greater. Additionally, some areas within the discharge plume will cycle back and forth through these salinity ranges relatively quickly based on the number of pumps that happen to be operating at the power plant at any given time, thus requiring exposed organisms to quickly adjust to salinity extremes far higher than normal conditions." The 10% annual range of ocean salinity reported in the DREIR and in Appendix C is not seasonal. Rather, it reflects short-term spikes in salinity change caused by excessive rain or periods of low vertical mixing in association with evaporation from the ocean surface. Organisms are thus tolerant of short-term and abrupt changes. The kinds of tolerance data that are routinely collected by the EPA and. by experimenters involve testing abrupt (short-term) changes in salinity. That is, placing a test group or organisms into a container of water having salinity other than that to which they are adapted, and testing survival, often for 48 hours or longer (Appendix S). Such tests, by showing no mortality in.groups experiencing only slight salinity changes, do in fact test the rapidity of the salinity adaptation response and provide statistically robust data for the threshold lethal effect (i.e., the concentration that is lethal for 50% of the test group, LC50). The modeling of the physical oceanography (Appendix C) reported in the DREIR indicates that changes in the ratio of HBGS cooling water to desalination byproduct volume, or other variations in flow rate will take many hours to be evident in the discharge field and because of dilution by the receiving water, they would not result in very different plume characteristics. "It is likely that many organisms adapted to local conditions would actively ' avoid the higher salinity areas, thus creating a zone with lower biomass, less biodiversity, or with other substantial ecological changes." The DREIR states that the permanent higher salinity "area" resulting in the discharge plume would have the greatest effect on the benthic organisms living in close proximity to the discharge tower where salinities would be the highest. It also states that the zone.of salinity elevation immediately around the discharge tower can be expected to undergo changes in the benthic faunal diversity, as some species living there now are adversely affected by the permanent higher salinity. As detailed in Appendix S, likely scenarios associated with this effect on the benthic fauna include changes in the numbers and relative abundances of the organisms living in this area, including the possible addition of species _ adapted to living in more saline habitats such as estuaries. Fishes and other pelagic organisms can be expected to move into and out of the higher salinity area over sufficiently short periods of time to not be affected. 2ac. This paragraph has been separated into segments to more clearly respond. Bold text denotes quotes from this paragraph. City of Huntington Beach August 17, 2005 69 ,11r d__. Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS "The DREIR also includes a report Marine Biological Considerations p ( g Related to the Reverse Osmosis Desalination Project at the Applied Energy Sources Huntington Beach Generating Station.- August 2004) which provides for several species lethal salinity concentrations (LC50, which estimates the lethal concentration for 50% of the tested individual organisms). While a 48 hour LC50 is a useful measure for some purposes, it does not adequately characterize an organism's response in the natural environment and does not detect behavior or reproductive changes, chronic effects, or other sublethal or long-term stresses." t . The kinds of tolerance data that are routinely collected by the EPA and by experimenters involve testing abrupt (short-term) changes in salinity. That is, placing a test group or organisms into a container of water having salinity other than that to which they are adapted, and testing survival, often for 48 hours or longer (Appendix S). Such tests, by showing no mortality in groups experiencing only slight salinity changes, do in fact test the rapidity of the salinity adaptation j response and provide statistically robust data for the threshold lethal effect (i.e., the concentration that is lethal for 50% of the test group, LC50). Long-term assessments of elevated salinity effects were done at the Desalination Test Facility in Carlsbad, California by Mr. S. Le Page. A tank set up to operate at 36 ppt salinity has been maintained for well over 18 months. It contains fishes 'r and benthic invertebrates(about 17 species are in the tank). There has been no �. mortality and organisms such as urchins feed, grow, and produce gonads (seasonally). The general health of these organisms and the stability of the tank indicate there are no chronic, sub lethal effects or long-term stresses associate _ with local species living in 36 ppt water. "The report also cites a study done in Antigua of the effects of a much smaller desalination discharge in a different marine ecosystem than is found off of Huntington Beach. The DREIR should also provide monitoring and study results that apply more directly to the conditions and organisms of Huntington Beach and Southern California." The commentator requested environmental analysis from other existing desalination facilities (refer to comment 2ba). Now the commentator finds fault t with the study because it does not have the same marine organisms as Southern California. The success of the 36 ppt demonstration tank in Carlsbad (operated (� for over 18 months) is providing the direct data this comment requests. The results show that continuous exposure to 36 ppt is not harmful to 17 species living in the tank (Appendix S). Regarding the Antigua study, Appendix S analyzes its applicability to environmental questions at Huntington Beach. The most useful feature of the r Antigua study is that it is a designed experiment done by manipulation of the discharge to direct it into the central area of a coral reef lagoon. Before and after data were compiled showing no effect of adding 2x seawater concentrate to the F lagoon. Because coral reefs are complex habitats with high species diversity and are generally regarded as fragile environments, the finding of no effect of the i release of a reverse osmosis concentrate (i.e., 2x salinity water) into the lagoon City of Huntington Beach August 17, 2005 70 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report„ 2.0 RESPONSES TO COMMENTS is noteworthy. While the Antigua desalination plant has a small capacity relative Y 9 P P Y to that proposed for Huntington Beach, its 2x salinity discharge is far more concentrated. 2ad. A description of adjacent sensitive habitat and potential project-related impacts is provided in Section 5.9 of the DREIR, CONSTRUCTION RELATED IMPACTS. In addition, operational impacts of the project on surrounding sensitive uses are provided in Sections 5.5, 5.7, and 5.8 of the DREIR. 2ae. Refer to Response 15ai, below. 2af. As required by CEQA, Section 7 of the DREIR describes a "reasonable range" of alternatives to the project which would "feasibly attain most of the basic objectives" of the project. Refer to Responses 2h and 2ag through 2aq. 2ag. It is correct for the DREIR to state that adoption of the "No Project" Alternative would not meet the project's objective of remediating the project site. Pursuant to CEQA Guidelines Section 15126.6(e)(3)(B) the discussion of the "No Project" Alternative should "compare the environmental effects of the property remaining in its existing state against the environmental effects which would occur if the project is approved." The commentator's opinion that the DREIR characterizes increased conservation efforts as "a negative" is not supported by the discussion in Section 7.1 (1) "Increased Conservation Efforts." That section does_not judge existing or future conservation efforts. Rather it reviews existing conservation planning in the County and concludes, based on the projections in the existing plans, that a doubling of the County's future conservation savings would be required each year to equal the 56,000 acre-feet of new water supply to be provided by the project. Finally, because the project description includes a construction schedule that would last approximately 24 months, it is reasonably foreseeable that the project could be in full production "commencing as early as 2008" as stated on page 7-3 of the DREIR. 2ah. The "Reduced Facility Size" Alternative in Section 7.5 of the DREIR discusses a- facility that would produce approximately 25 MGD of drinking water. The commentator also suggests that the DREIR must "establish the need for the proposed project to produce 50 million gallons per day of drinking water." While a comment questioning the "need" for the project may be relevant to exercise of "the agency's ultimate discretion on the project" (see CEQA Guidelines Section 15121(b)), it is not considered to be a "comment on environmental issues" (see Guidelines Section 15088[a]). No further response is necessary. 2ai. The use of smaller beach wells has been discussed in Section 7.4 of the DREIR as part of the "Alternative Project Design" Alternative (see pages 7-11 through 7- 16 and 7-19 through 7-20). As stated in the DREIR, a study prepared for a 25 MGD seawater desalination facility in Corpus Christi, Texas, concluded that vertical intake wells were not a feasible intake alternative because the "significant cost and land requirements make them impractical and economically infeasible." Also refer to Response 2ah, above. City of Huntington Beach August 17, 2005 71 r Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS l_ Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS 2a'. Combining the discharge from a desalination facility which takes its water from J 9 9 tY beach wells and the power plant discharge will not mitigate the dissolved oxygen (DO) problem as suggested by the commentator because of the significant difference between the DO levels of the two streams. Please note that Section II, Water Quality Objectives, Subsection D, Chemical Characteristics, page 5 of the 2001 California Ocean Plan has a requirement that "The dissolved oxygen r concentration shall not at any time be depressed more than 10 percent from that which occurs naturally, as the result of the discharge." As indicated on page 7-19 of the DREIR, the DO concentration of the beach well water is projected to be between 0.2 and 1.5 mg/L and to have a volume of approximately 50 MGD. According to HBGS' NPDES permit, the generation station is allowed to discharge between 127 MGD and 514 MGD of cooling water (see page 4-6 of the DREIR). At an average discharge temperature of 820 F (280 C) and ocean water salinity of 33,500 mg/I, the concentration of DO in the HBGS { discharge (under the best case scenario when the ocean water is fully saturated with oxygen) would be 6.5 mg/L.' Since the requirement of DO depression applies at any time, under the worst case scenario, when 127 MGD of HBGS s discharge at 6.5 mg/L of DO concentration is blended with 50 MGD of intake well II desalination facility discharge with DO concentration of 1.5 mg/L, the DO li- concentration of the blended HBGS/desalination facility discharge would be: 5.1 mg/L = (127 MGD x 6.5 mg/L + 50 MGD x 1.5 mg/L)/ (127 MGD + 50 MGD). As a result of this combined discharge, the oxygen level at the point of discharge will _ be depressed by 21% ((6.5 mg/L — 5.1 mg/L) /6.5 mg/L). This depression of the DO concentration is almost two times higher than the acceptable level of r depression of 10% allowed by the California Ocean Plan. In the case when the 1L r DO in the intake well desalination facility discharge is 0.2 mg/L, the DO level of the blended discharge would be depressed from 6.5 mg/L down to 4.7 mg/L = r- (127 MGD x 6.5 mg/L + 50 MGD x 0.2 mg/L)/(127 MGD + 50 MGD), and the DO concentration depression would be 28%. The DO level in the discharge will be out of compliance with the California Ocean'Plan requirements. In order to comply with the discharge requirements of the California Ocean Plan, the low DO level discharge from a seawater desalination facility using beach wells has to be aerated to a level within 10% of the ambient ocean water DO level. Increasing the DO concentration of 50 MGD of desalination facility �- discharge from 0.2 mg/L to 6.5 mg/L will require additional power use of approximately 0.1 MW for aeration. Capital expenditures for aeration equipment and facilities will be needed as well. As indicated in the DREIR (page 7-20), these additional expenditures will result in a measurable impact on potable water production costs and diminish the viability of this type of intake. As indicated on page 5.10-35 of the DREIR, "the RO operation will not significantly affect water turbidity, suspended solids, pH, and oxygen levels." Since the dissolved oxygen in the ocean water collected by HBGS is not affected by HBGS operations, the r dissolved oxygen concentration of the desalination facility discharge will be I approximately the same as that of the ocean water. 2ak. The referenced seawater desalination plant in Marina produces approximately 300,000 gallons per day, while the proposed Sand City desalination facility is proposed to produce approximately 270,000 gallons per day. In comparison"to City of Huntington Beach August 17, 2005 72 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report '2.0 RESPONSES TO COMMENTS the proposed project, these production rates account for approximately 0.6 P P p 1 � P PP Y percent and 0.54 percent of the output of the proposed project. Although it may be feasible to reduce the aesthetic impact of each proposed beach well, other factors (land use, aesthetics, noise, air quality, etc.) make this alternative infeasible due to the number of wells that would be required. In addition, photographs from the Marina Coast Water District website clearly show a facility that does not match the commentator's description. 2al.. As explained on page 7-21 of the DREIR, use of the OCSD outfall for concentrated seawater discharge is not feasible because capacity within the OCSD outfall is not available. Likewise, use of water from the OCSD treatment plant as feedwater for the proposed project is not feasible because that water is already committed to the Ground Water Replenishment System (GWRS) project. In addition, the scope of the proposed project is to desalinate seawater and produce potable water for direct human consumption, which is in compliance with the Safe Drinking Water Act and State regulations governing potable water production. The suggested scenario— i.e. taking 100 MGD of treated wastewater from the OCSD wastewater treatment plant discharge and producing potable water is not a feasible alternative to the proposed project because the purpose of the project is to produce drinking water for direct human consumption, not reclaimed water for reuse. The suggested alternative will not produce potable water suitable for direct human consumption nor would it provide an access to a new water source. This alternative will produce highly treated wastewater (reclaimed water). The direct reuse of reclaimed water for human consumption is prohibited by the Safe Drinking Water Act and the California Department of Health Services. As stated in the DREIR, water agencies recognize the need for diversification of water supplies including conservation, recycling and desalination to meet future water needs. 2am. Refer to Response 2al, above. ' 2an. The proposed project would not affect the HBGS' ability to `convert to an alternative cooling system and would not effect operation of the generating station. In the event that the HBGS once-through cooling water system is decommissioned, the project applicant may need to assume ownership of the intake and outfall. Refer to Response 1g, above. 2ao. It is noted that the range of alternatives required in an EIR is governed by a "rule of reason" and that an EIR need not consider every alternative to a project. In this comment, the commentator specifically questions the criterion used for the discussion of"Alternative Locations Within a Two-Mile Radius of the HBGS" and suggests that it is inappropriate. The commentator questions the limitation of a "two-mile" radius (which was the stated focus of this alternative discussion) while at the same time recognizing that an additional discussion of sites outside of the two-mile radius was also performed in the DREIR. The commentator then incorrectly suggests that the "two-mile" radius discussion was limited to "open City of Huntington Beach August 17, 2005 73 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS ,- areas." As explained on page 7-6 this discussion included an "investigation of available land (five acres or larger) within a two-mile radius of the HBGS." In addition to nearby "open areas" (i.e. parks and schools), the investigation identified OCSD•property, the Ascon/Nesi site, the former CENCO tank farm, the Pacific City development and the new Hyatt Regency property. The commentator does not identify any particular site within the two-mile radius, or outside of it, which should have been discussed. In addition, the commentator specifically questions the discussion of "Alternative ' Locations Outside of the City of Huntington Beach," suggesting that it is 1 . .perfunctory and should have discussed other sites. The commentator does not identify any particular site which should have been discussed. The range of alternatives required in an EIR is governed by a "rule of reason." An EIR need not consider every alternative to a project. 2ap. It would be speculative to predict what types of changes may occur to the HBGS' existing permit requirements, approvals, and contracts. However, any such changes affecting the operation of the proposed desalination facility would also r_ require a regulatory review of the project's existing permits and approvals. 7 Avoidance, minimization, and mitigation measures for such changes would occur at that time. 1 2aq. The commentator disagrees with the project applicant's confirmation_ that they . are a domestic corporation and not a multinational corporation. The commentator also disagrees with the 2004 California Water Plan provision that states: "So long as government regulations are applied in the same manner to water projects involving multinational corporations as they are to water projects owned or operated by domestic companies or public utilities, there would be no conflict with international trade treaties." The commentator's disagreement is noted. The commentator argues that the "issue of concern" is private ownership rather than operation and that other sources of information should be considered (e.g.- concerns of the Attorney General and legislative committees). As noted, the 2004 California Water Plan provision referenced applies equally to ownership and operation of the project. Moreover, the practice of integrating undisclosed executive and legislative policy materials would result in voluminous materials unrelated to the analysis of potential environmental impacts. An EIR is intended to be a concise informational document and therefore cannot include analysis of every hypothetical argument speculating about the possibility of a multinational corporation avoiding environmental law through the application of international treaty. "Argument, speculation, unsubstantiated opinion or narrative, evidence which is clearly erroneous or inaccurate, or evidence of social or economic impacts which do not contribute to or are not caused by physical impacts on the environment does not constitute substantial evidence." (CEQA Guidelines Section 15384(a).) 2ar. In this comment, the commentator specifically questions the discussion of "Growth-Inducing Impacts" in DREIR Section 6.2 suggesting that it is "based on some questionable analyses." The commentator does not specifically identify the City of Huntington Beach August 17, 2005 74 g s r Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report;, 2.0 RESPONSES TO COMMENTS portion of the analyses that is considered questionable, but comments on the mixing of growth projections and the inclusion of water conservation information. ' The analysis in Section 6.2 does include growth projections from the following two sources: growth projections based on adopted general plans as well as growth projections based on information provided by the Center for Demographic Research. These projections are not "mixed." Rather they,are separately set forth in Tables 6-1 and 6-2 of the DREIR. Descriptions of the water conservation measures "in place" in Orange County are provided by reference to the existing water plans of the Metropolitan Water District of Southern California and the Municipal Water District of Orange County (DREIR pages 6-10 through 6-12). 2as. The commentator is "troubled" by the statement in the DREIR that "the growth- inducing impact of the project would depend entirely upon how regional or local water purveyors will allocate the desalinated seawater produced by the project." (DREIR, page 6-13.) The commentator criticizes the DREIR for 'lack of certainty about where the water produced by the project will be used. CEQA Guidelines Section 15144 recognizes that "foreseeing the unforeseeable is not possible" and directs that "an agency use its best efforts to find out and disclose all that it reasonably can." At page 6-13 of the DREIR, it is clearly stated that the water produced by the project will be "delivered only to existing regional or local water purveyors in Orange County" and that because "no water supply agreements have been executed with water agencies in Orange County, the precise locations/uses where desalinated water would be allocated are not known." Accordingly, the DREIR concludes that "there is a potential for the project to induce growth in unidentified areas. All proposed projects and water sources would be subject to environmental analysis prior to approval." (page 6- 13) The commentator also suggests that the DREIR must"establish the need for the proposed project to produce 50 million gallons per day of drinking water." While a comment questioning the "need" for the project may be relevant to exercise of "the agency's ultimate discretion on the project" (see CEQA Guidelines Section 15121[b]) it is not considered to be a "comment on environmental issues" (see Guidelines Section 15088[a]). No further response is necessary. 2at. This text provides a conclusion to the comment letter and does not require a response. 2au. These paragraphs provide an introduction to the agency's comments and summarize the project description. No response is necessary. 2ay. In response to this comment on the originally circulated DEIR, the potential impingement and entrainment impacts of the project were- addressed in the DREIR in Section 5.10 and Appendix T and found to be less than significant. In addition, refer to Responses 1 d, 1 j, 2p, 2u, and 2z, above. 2aw. The DREIR addresses this comment in Section 5.10, OCEAN WATER QUALITY AND MARINE BIOLOGICAL RESOURCES. 2ax. The relationship between the HBGS facilityand the desalination facility is Y described in the DREIR at pages 3-20 and 3-21, and a detailed description of the City of Huntington Beach August 17, 2005 75 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS HBGS operations is provided in Section 4.1. In addition, refer to Responses 2c and 2u, above. 2ay. Operation of the desalination facility without power production from the HBGS is referred to as the "Standby Mode of HBGS Operations" (see, page 4-7 of the DREIR) and has occurred less than one percent of the time. As explained on page 5.10-28 of the DREIR, the standby mode was included in the modeling of . the worst-case, "low flow scenario." The DREIR concluded that the potential impacts to ocean water quality and marine biological resources are less than significant. I I I l_ 2az. Refer to Responses 1 d, 1 j, 2p, 2u, 2z, and 2av, above. 2ba. The requested information and evaluation is included in the DREIR at pages 6-18 through 6-24, and in Appendix X. �- 2bb. Refer to Responses 2o, above, and 1 Oh, below. 2bc. Site-specific preliminary seismic assessments were prepared for the proposed desalination facility site (Appendix H) and for the aboveground storage tank - site(Appendix 1). These assessments concluded that the risk for surface faulting at the site is a "relative minimum while seismic activity from numerous faults r within the vicinity, including the Newport Inglewood Fault Zone (the closest active fault), may result in liquefaction in soils at depths of seven to 16 feet below ground surface.(bgs). Soils below that depth were not found to be susceptible to liquefaction. Soil layers susceptible to liquefaction were not determined to be i continuous throughout the proposed desalination facility site and the tank site. Liquefied soils may experience post-liquefaction settlements _of four to five inches. As detailed design features of the project have not yet been determined, measures to mitigate potential geologic hazards as recommended within the preliminary seismic assessments will be developed as part of final design. A construction-level geotechnical report will be prepared as grading and design plans are developed. This report will include mitigation measures regarding grading, foundations, retaining walls, streets, utilities, remedial work, overexcavation/recompaction, dewatering, water quality, and chemical/fill properties of underground items including buried pipe and concrete and protection thereof. The report shall also specifically address lateral spreading, flood control channel bank stability, liquefaction potential and groundwater constraints. 2bd. As a result of improvements to the Huntington Beach Channel performed by the Orange County Flood Control District (located adjacent to the subject site), the site is no longer located within the 100-year floodplain as designated by the latest Federal Emergency Management Agency's (FEMA) Flood Insurance Rate Maps (FIRM). Flooding is not expected to be a hazard to the proposed project site. 2be. Refer to Response 2bd, above. 2bf. Refer to Section 7.0, ALTERNATIVES, of the DREIR, and Response 2af, above. City of Huntington Beach August 17, 2005 76 1 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS 2bg. Refer to Section 6.0, LONG-TERM IMPLICATIONS OF THE PROPOSED PROJECT, and Responses 2ar and 2as, above. 2bh. Refer to Section 6.0, LONG-TERM IMPLICATIONS OF THE PROPOSED PROJECT, and Responses 2ar and 2as, above. 2bi. Refer to Responses 2bf and 2bh, above. 2bj. The table referenced in this comment is not in the DREIR. No response is necessary. 2bk. During dry weather conditions the ocean salinity will vary less than one percent. During wet conditions, salinity is depressed from increased river flow due to rainfall which was evaluated in Section 5.10, OCEAN WATER QUALITY AND i. MARINE BIOLOGICAL RESOURCES and Appendix C of the DREIR. Also refer to Section 5.10, OCEAN WATER QUALITY AND MARINE BIOLOGICAL RESOURCES, of the DREIR. 2bl. The total volume of waste cleaning solution generated from the cleaning of one reverse osmosis (RO) membrane train is 91,000 gallons (cleaning solution plus ' first rinse). The desalination facility will have a total of 13 RO membrane trains. Each train must be cleaned twice during the year. On a typical cleaning day, two to three membrane trains could be cleaned at the same time resulting in a generation of up to 182,000 to 273,000 gallons of waste cleaning solution. This number was rounded to a range of 200,000 to 300,000 gallons. 2bm. This paragraph provides contact information for the Coastal Commission's representative, and does not require a response. 2bn. This text provides an introduction to the comment letter and does not require a response. 2bo. This paragraph summarizes immediately-following comments and is responded to below. 2bp. Refer to.Response 2aq, above, and Response 33f, below. 2bq. Comment noted. No response is necessary. 2br. This paragraph clarifies earlier comments that referred to "subsequent environmental documents", and no response is necessary. 2bs. This text provides a summary of immediately-following comments and is responded to below. O.C. Sees Cheap Water Era Ending", Orange County Register, September 29, 2002. 3 CEQA Guidelines Section 15124[b]. City of Huntington Beach August 17, 2005 _ 77 l _ Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS 2bt. Refer to Appendix T of the DREIR, INTAKE EFFECTS ASSESSMENT, which was prepared in response to concerns regarding the entrainment impacts of the proposed project. Also refer to Responses 1 b, 1 d, 1 j, 2p, 2u, and 15q. 2bu. Section 5.10, OCEAN WATER QUALITY AND MARINE BIOLOGICAL RESOURCES provides a description of potential salinity impacts under two scenarios ("low flow" and "average flow" scenarios). These scenarios take into account seasonal conditions and compare potential impacts to natural ambient seawater salinity. Additionally, Appendix C of the DREIR provides details f regarding the assumptions utilized in the modeling. 2bv. It is not feasible (nor required by CEQA) to analyze project-specific impacts of other desalination projects. However, the cumulative impacts of the proposed project and other desalination proposals within the Southern California Bight were provided within Section 7.0 of the DREIR. Moreover, a project-specific entrainment impact analysis (Appendix T, INTAKE EFFECTS ASSESSMENT) was prepared for the DREIR. lbw. The requested additional alternatives have been incorporated into Section 7 of the DREIR. �- 2bx. Refer to Responses 2ar and 2as, above. 2by. This text provides a conclusion to the comment letter and does not require a response. l t_ 2bz. This text provides an introduction to the comment letter and does not require a response. {{� 2ca. Note that no purchase agreements with local water purveyors currently exist for the proposed project. The growth inducing impacts discussion has been t- substantially revised since preparation of the originally circulated EIR — refer to l� Section 6.0 of the DREIR, LONG-TERM IMPLICATIONS OF THE PROPOSED PROJECT. Also refer to Responses 2ar and 2as, above. 2cb. Refer to Response 2bt, above. 2cc. Refer to Responses 2bt, above. 2cd. Refer to Response 2aq, above, and Response 33f, below. 2ce. This text provides a summary to the comment letter and does not require a response. 2cf. This comment provides a summary of comments immediately following and has been responded to below. 2cg. Refer to Responses 2bt and 2bu, above. City of Huntington Beach August 17, 2005 78 +'— Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report - 2.0 RESPONSES TO COMMENTS 2ch. The DREIR evaluates both a "low_flow" 127 m d flow, with two circulating ( 9 9 pumps operating and no heating of discharge water) and "average flow" scenario (253 mgd flow, with four circulating pumps running and two generating units operating). Also refer to Response 2c and 2bt, above. In addition, footnote 3 of the letter is factually incorrect. The reference to "an entrainment increase of between two and seven percent" is not for the Tampa Bay Desalination plant that was constructed at the Big Bend power station. The commentator's reference is from the environmental analysis of an alternative site in the Tampa Bay area - the Anclote River Power Plant site. As stated in the Fact Sheet for the NPDES permit issued for the Tampa Bay (Big Bend) Desalination Plant (NPDES permit number FL0186813), "the source water for the RO desalination facility will be taken from the discharge of the power plant's cooling water and as a result the intake flow to the power plant will not increase...This limitation insures the entrainment does not exceed the levels previously permitted for this site" (page 2, paragraph F). This change has been incorporated into Section 3.0 of the Responses to Comments, ERRATA 2ci. The proposed project's consistency with the City's Local Coastal Program has been analyzed in Section 5.1, LAND USE AND RELEVANT PLANNING. Note that pumps to draw seawater from the ocean are not included in the project; ' rather, pumps to divert seawater from the HBGS cooling water system are proposed. Also refer to Response 2bt and 2bu, above and 17d below. 2cj. This text provides a conclusion to the comment letter and does not require a response. '2ck. This text provides an introduction to the comment letter and does not require a response. 2cl. Refer to Section 5.1, LAND USE AND RELEVANT PLANNING, of the DREIR. 2cm. Refer to Response 2as above. 2cn. As the proposed project would not alter the operations of the HBGS, previous studies/mitigation relevant to the HBGS have not been incorporated into the DREIR. 2co. Refer to Response 2bv, above. 2cp. Energy consumption impacts are analyzed within Sections 5.6 and 7.0 of the DREIR. 2cq. This suggested change was included within the DREIR within Section 3.0, PROJECT DESCRIPTION. 2cr. Refer to Section 5.10, OCEAN WATER QUALITY AND MARINE BIOLOGICAL RESOURCES. Note that the desalination facility would not produce water while the HBGS is not running its circulating pumps. City of Huntington Beach August 17, 2005 79 r I Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS r 2cs. Refer to Section 5.10, OCEAN WATER QUALITY AND MARINE BIOLOGICAL RESOURCES. Also refer to Response 2cn, above. 2ct. Cumulative impacts of the proposed project are analyzed within Section 6.0 of the DREIR. The potential traffic impacts due to growth within Orange County would be analyzed within the site-specific EIR prepared for each relevant project. 2cu. Refer to DREIR Sections 5.10, OCEAN WATER QUALITY AND MARINE BIOLOGICAL RESOURCES and 6.0, LONG-TERM IMPLICATIONS OF THE r- PROPOSED PROJECT. Also refer to Response 2bt, above. 2cv. Refer to DREIR Sections 5.5, NOISE, and 5.9, CONSTRUCTION RELATED IMPACTS. 2cw. Refer to Section 5.6, PUBLIC SERVICES AND UTILITIES of the DREIR. 2cx. Refer to Response 2cv, above. 1, 2cy. This text provides a conclusion to the comment letter and does not require a response. 1 . L. r City of Huntington Beach August 17, 2005 80 COMMENT 3 State of California-The;Resources Agency' ARNOLD SCHWARZENEGGER, Governor DEPARTMENT OF FISH AND GAME http://www.dfg.ca.gov 4949 Viewridge Avenue City of Huntirgton Bea-_ San Diego, CA 92123 (858) 467-4201 MAY 3 12005 May 27, 2005 Mr. Ricky Ramos City of Huntington Beach Planning Department 2000 Main Street Huntington Beach, CA 92648 Comments on the Draft Recirculated Environmental Impact Report No. 00-02 for the Seawater Desalination Project at Huntington Beach, Orange County (SCH#2001051092) Dear Mr.Ramos: The Department of Fish and Game(Department)has reviewed the above-referenced recirculated Draft Environmental Impact Report(DEIR). The project,proposed by.Poseidon Resource Corporation, consists of the construction and-operation of a 50 million gallon per day seawater desalination facility within the City of Huntington Beach. The facility would consist of sedwater intake pretreatment facilities,a " seawater desalination plant utilizing reverse osmosis technology,product water storage,two pump stations, materials storage tanks, and 42 to 48-inch diameter product water transmission a pipeline possibly up to 10 miles in length in Huntington Beach and Costa Mesa. The facility would utilize existing AES Huntington Beach Generating Station(HBG_S) seawater intake and outfall pipelines for its operations. The proposed desalination facility is located on an 11-acre portion of the 22-acre HBGS facility located at 21730 Newland Street, off Pacific Coast Highway The Department provided comments to you previously on an earlier version of the DEIR in a letter dated November 4,2002. We offer the following additional comments and recommendations to assist the City in avoiding or minimizing potential project impacts on biological resources. 1. There seems to be some confusion regarding the location of the OC-44 underground booster pump station in relation to the boundary of the Natural Community Conservation Plan (NCCP) area. The location of the proposed-pump station was altered from the description in the DEIR of September 19,-2002 (approximately 0.25 mile north of the San Joaquin Reservoir)to the description in the DEIR of April 5, 2005 (approximately 0.5 mile north of the San Joaquin Reservoir) so that its proposed position is outside the NCCP,but within the County-designated Resource Preservation Easement. We believe that a biological constraints report for the OC-44 pump station is appropriate with this change in location. The final EIR should include a map showing the location of the station in relation to the bounds of the Mr. Ramos May 27, 2005 Page 3 - NCCP, and a vegetative map delineating the vegetation communities contained on the project b site and the surrounding area. - 2. Pre-construction surveys were included in the mitigation measures for the underground booster pump station; however, biological surveys for sensitive species should be conducted Prior to the release of the DET?Z. The results of--he surveys should have been included in the DEIR along with a comprehensive analysis based on the survey data so that the reviewing agencies, the public and decision makers accurately gage the project's potential effect on C sensitive biological resources, and to determine that any associated mitigation measures reduces the project's effects on biological resources to a level of less then significant. 3. Least Be11's vireo is a State-listed endangered species;therefore, a Cali-fornia Endangered d f Species Act (CESA)Permit(2081 or 2080.1)may be required for impacts to this species. 4. In regards to Mitigation Measure CON-39,we recommend that the Department be consulted regarding the preparation and implementation of a relocation plan for southwestern pond turtles. Thank pP �'you for the o ortuni -to comment on the recirculated DEIR The Department Y eP finds that the project would not be de minimis in its effects on fish and wildlife per section 711.4 f of the California Fish and Game Code. Questions regarding this letter and further coordination on these issues should be directed to Leslee Newton-Reed at (858) 467-4281. Sincerely, r Donald R Chadwick` Habitat Conservation Supervisor r cc: State Clearinghouse Bill Paznokas,Marine Division,Department of Fish and Game _ Jonathon Snyder,U.S.Fish and Wildlife Service (� LNR:lnr Seawater Desalination Project at Huntington Beach recirculated DEIR r Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 3 State of California Department of Fish and Game Donald R. Chadwick, Habitat Conservation Supervisor 3a. These introductory paragraphs provide a summary of the project description, and do not require a response. 3b. A map denoting the proposed OC-44 booster pump station location in relation to the NCCP boundary was provided in the Responses to Comments document (dated March 21, 2003)for the previously circulated EIR. A biological constraints, survey for the OC-44 site was included as Appendix L to the DREIR, which describes biological characteristics for the site. 3c. A biological constraints survey was conducted as part of the preparation of the DREIR, the results of which included analysis of sensitive species existing at the subject site. Any potential impacts on sensitive species at the OC-44 booster pump station would be reduced to less than significant levels as part of the regulatory permit acquisition process. 3d. As stated within the DREIR, the Applicant would be required to consult with the California Department of Fish and Game regarding the appropriate permits necessary for the project prior to any construction activities. 3e. Refer to Response 3d, above. 3f. Comment noted. No response is necessary. r City of Huntington Beach August 17, 2005 83 State of California.The Resources Agency Arnold Schwarzenegger, Govemor " ® DEPARTMENT OF PARKS AND RECREATION Ruth G.Coleman,Director Orange Coast District COMMENT 4 3030 Avenida Del Presidente. San_Clemente CA 92672. (949) 49270802 �,i��of Hunfiirafion Beach MAY 312005 rMay 26, 2005 Ricky Ramos City of Huntington Beach 2000 Main Street Huntington Beach CA 92648 Subject: Seawater Desalination Project at Huntington Beach Recirculated Draft Environmental Impact Report, SCH #2001051092 Dear Mr. Ramos: Thank you for the opportunity to comment on the recirculated Draft Environmental Impact Report for the Huntington Beach seawater desalination project. California State Parks owns and manages Huntington State Beach so that its exceptional natural and recreational resources are protected and available for the citizens of California. Huntington State Beach serves more than three million visitors j annually. A large percentage of these visitors use the Pacific Ocean for recreation. a AES power plant and the proposed seawater desalination plant is adjacent to ' Huntington State Beach. Ocean water intake and outlet pipelines for the AES power plant travel through Huntington State Beach near Newland Avenue. The ocean water intake and outlet structures are located approximately 1200 feet offshore. As presented, the proposed project will utilize these facilities for-obtaining seawater and discharging. We are concerned the this project may impact the natural and recreational resources the public enjoys within Huntington State Beach. Poor ocean water quality remains a significant issue along the Huntington Beach coastline. State Parks recognizes the considerable scientific data which has been compiled to analyze this project and its impacts on ocean water quality. However, the ocean is extremely dynamic,and unpredictable, and for many years scientists have failed to predict ocean conditions. State Parks is most sensitive to any change in water quality from a project that could affect postings on the beach. We feel that continuing questions about changes in water quality from bacterial entrainment of intake cooling waters or from changes in a body of hypersaline effluent water need to be more clearly evaluated. Mr. Ramos May 26, 2005 Page 2 r The AES pipeline easement through Huntington State Beach is for power plant cooling purposes only. Should this desalinization project move forward, the project C ' proponent will be required to acquire easement rights from CA State Parks. II� l_ Thank you for inviting us to comment on this project. If you have a.need to clarify any of our concerns, please call me at (949) 492-0802. d t� Sincerely, !ichael�. Tope l- District Superintendent I a_. 1, Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 4 State of California Department of Parks and Recreation Orange Coast District Michael M. Tope, Superintendent 4a. These introductory rovide a summary of the project description, and P rY P 1 P , do not require a response. 4b. The proposed project's analysis of impacts to ocean water quality and marine biological resources employed a computer model that analyzed potential impacts to the marine environment. The model and subsequent environmental analysis concluded that the proposed project's impacts would be less than significant. In regards to the proposed project's discharge and intake interacting with the OCSD ' outfall discharge, the modeling found that under worst-case conditions, effluent from the OCSD outfall would be diluted 30 million to one at the HBGS intake. Accordingly, the OCSD outfall is'not considered to be a potentially significant source of contamination for the proposed project. Refer to Section 5.10 (OCEAN WATER QUALITY AND MARINE BIOLOGICAL RESOURCES) for further discussion. In conclusion, the proposed project's marine environment impacts have been analyzed with the best available information and, in accordance with the statutory requirements of the CEQA, the findings have been disclosed to the decision makers and the general public. In addition, refer to Response 21f, below. 4c. If the project is approved, the Applicant will consult the Department of Parks and Recreation about acquiring easement rights. 4d. This concluding paragraph provides contact information and does not require a response. City of Huntington Beach August 17, 2005 86 COMMENT 5 STATE OF CALYFORNLA BUSYNESS TR4NSPORT4nON AND HOUSING AGFNCY DEPARTMENT OF TRANSPORTATION District 12 ' 3337 Michelson Drive,Suite 380 Irvine,CA 92612-8894 �� TeL(949)2724-2267 Flezyourpowerl Fax: (949) 724-2592 D.aV Be energy efficient) April 13, 2005 r Mr. Ricky Ramos File: IGR/CEQA City of Huntington Beach SCH#: 2001051092 200 Main Street Log#: 906C Huntington Beach, California 92673 SR#: SR-1, SR-39 Subject: Seawater Poseidon Desalination Project.at Huntington Beach Dear Mr. Ramos, Thank you for the opportunity to review and comment on the Draft Re-circulated Environmental Impact Report for the Seawater' Poseidon Desalination Project at Huntington Beach. The project consists of the construction and operation of a 50 million gallon per day seawater desalination facility within the City of Huntington Beach. The project site is located on Pacific Coast Highway and Newland Street in the City of Huntington Beach. The nearest state facilities to the project site are SR-1 and SR- 39. Caltrans District 12.status is a responsible agency on this project and our comments have been a addressed in the above report. Please continue to keep us informed of this project and any future developments, which could potentially impact the transportation facilities. If you have any questions or need to contact us, please do not hesitate to call Maryam Mola_vi at (949) 724-2267. Sincerely, ROB ERT F. JO SEPH, Chief ' IGR/Community Planning Branch C: Terry Roberts, Office of Planning and Research Terri Pencovic, Caltrans HQ IGR/Community Planning Gale McIntyre, Deputy District Director "Caltrans improves mobility across California" Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS r Response No. 5 L State of California Department of Transportation �— District 12 Robert F. Joseph, Chief IGR/Community Planning Branch r L- 5a. Caltrans District 12 will continue to be notified about future developments concerning the project. No further response is necessary. j r r I l ,1 r I r r r r L l I City of Huntington Beach August 17, 2005 gg +r i 0 FJ REGIONAL COMMENT LETTERS F �1 El P-i �i -jN,02-2005 15:29 FROM:ENVIRONMENTRLPLNG 17148346132 T0:714374164e r.002/004 COMMENT 6 ' �lryzn SpceEglc,Z}Ircctor / T j f �j ]��/ �* 300 N.1Trnv=-StrCa CL�1� l .0 OF O 111.t r Uri Sanin Ana,C�� v� F-()-tkFi ,z �i tR . _ CAnm Ann,CA 9�M2-A048 RESOURCES&DEB'E',LopAf� T3,I1NAGEM-NrDEPA TMFNT D 4t Tcicphonc (714)RJ4-2300 q�tx-o8�' Fax: (714)834-6188 NCL 05-01 S 31mc 2,2005 Ricky Ramos City of Huntington Beach Planning of Departraeut 2000 Main.Strcct Tim ington Beach,CA 92648 = - SUBJECT: Recirculated DEIR No.00-02 for the Poseidon Seawater Desalination,Project Dear Mr.Ramos: The County of Orange is submitting its comments after the close of the public review period ending on.Friday, May 26, 2005 following agreement with Ricky Ramos and Howard.Zolcfsky granting an extension for County r review of the subject Recirculated Draft Environmental Impact Report (DELR�. The project consists of the construction and operation of a 50 million gallon per day seawater desalination facility to be located'on a seven acre portion of the 22 aciir.AES Huafuigtait Beach Generating Plant at 21730 Newland Street,off Pacific Coast Higbway. - a ' The County of Orange bas reviewed the Recirculated DEIR and offers the fbUowi>ng comments: OPEN SPACE/RECREATION: s The County has no comments regarding the proposed desalinization plant site within the City of Huntington Beach,but is concerned regarding: I�LpMscd 01 44 Puma Statior+in Resource Preservation Easement: 1. The proposed pump station site is located in an eastern area of the City of Newport Beach within a County"Resource Presentation Easemcnf,in Lot C. Recorded Tract 15945. Terms and limitations for the casements are per that-separate instrument recorded.November 14, 1984,as Instrument No. 84- 468083,and cited on the recorded tract map. Specifically,removal of native vegetation is prohibited,no grading or land-filling petrnitted except to repair slope damage due to failure or to construct access ways to developed.'areas when no other access routes are available,and structures limited to open fencitn.g. b Activities regarding site placement,grading and construction of the proposed pump station are prohibited within the subject Resource Preservation Easement. Additionally, given the nature of JLIN-02-2005 15:29 FROM:ENUIRONMENTALPLNG 17146346132 T0:714374164e P.003Z004 Ricky Ramos Page Z existing habitat on the site and the acknowledgement of construction related impacts (Section 5.9), permits from the California Department of Fish&Game (CDFG) and perhaps the Army Corps of Etiginaers(ACOE) or U.S. Fish& Wildlife Service(USFWS)will likely be required in order to . implement the booster pump station at this proposed location. Should the applicant he successful in securing any required CDFG and/or ACOE,USFWS perrnits,the applicant will also need to file for a County Property Pen-nit(encroachment permit)with the County of Orange as well as a request.for b vacation of the Resource Frrtection Easement over t13E p:nj e:t s.*w. if tt:e re;*:eat for vacation and County Property Permit arc deemed appropriate,additional mitigation and/or compensation over and above any CDFG,ACOE or USFWS permit requirements will likely be required _ r I "Alternative Pipeline Alignment"along;Victoria Street: L 2. An alternative pipeline alignment is proposed along Victoria Street in the City of Costa Mesa. The DEIR acknowledges that the pipeline will be-focated within public easements,but does not evaluate any - proposed impacts to Talbert Nature Preserve located both on the nortb and south side of Victoria Street C near the Santa Ana River. Any short term construction impacts and/or long tern project impacts to the r Talbert Nature Preserve would also requite a County Property Permit fivm the County of Orange with 1_ appropriate mitigation for those impacts. r Trails and Bikeways; Project Site: - 3. Talbert Channel may become a future regional trail or bikeway. As such the County requests that the project:notprcclude tbepossible reuse of the levee service road for trail or bikeway purposes. Perimetct Wall: 4. Whene the perimeter wall is adjacent to the channel levee,the County requests that instead of a block wall,the City use a vertical metal-tubing fence. This type of fencing opens up the view from the trail and avoids the"tanner"effect created by a long.blank,block wall. Also,block walls are susceptiblc to graffiti. Interior Landsea pmS- 5. Where the project is adjacent to the channel,the County requests that landscaping be planted just inside the metal fencing to improve the quality of the view shed- Water'transmission Lines: 6. Several proposed water transmission line alignments cross numerous County trails and bikeways. These facilities are used by numerous commuter and recreational bicyclists and trail users. Based on Exhibit 3-9 (Approximate Desalination Water Distribution Area),the following trails and bikeways will be impacted: a. Aliso Creek Bikeway(several locations) JUN-02-2005 15=29 FROM:ENUIRONMENTPLPLNG 17149346132 TD_714374IG49 P.004/004 Rkfcy Ramos Page 3 b. Aliso Creek Trail (several locations) ' c. Santa Ana River Class I Bikeway(3 locations) d. Santa-Ana River. Trail (3 locations) C. Greenville-Banning Class I Bikeway(I locaioon) f Peters Canyon Class I Bikcway(2 locations) ' g. Peters Canyon Trail(2 locations) Q h. San Dick Creek Class I Bikeway(1 or more locations) J. Sand Canyon Class 1.Bikeway(1 location) j. Santa Ana Heights Trail(l location) k, Wood Canyon Trail(1 location) This is only an estimate. There may be other locations where additional regional or local trails and bikeways tray also be impacted by the project. Existing Bikeways and Trails to Remain Open: 7. Existing bikeways and trails should remain open at all times during project construction,either by protecting in place or by providing a detour. Detour plans should follow Caltrans standards. A detour e must remain in place until the affected trail or bikcwyy can be returned to its original alignment. Also, trails and bikeways trust be retumed to original condition upon completion of construction activities as a requirement of a County Property Permit for encroachment within any of its trails or bikeways(thc County will.provide additional details when an encroachment permit is requested). Coordination regarding Trails Arid Bikeways: 8_ we suggest that the applicant coordinate with Jeff Dickman, Chicf of the County's Trail Planning,who maybe reached at(714) 834-5372. II Thank you for the opportunity to respond to the Recirculated 1]EIR If you- have any questions,please contact Charlotte Harryman at.(714)834-2522. Sincerely, ' Ronald L.Ti. ef' Environmental Planning Division Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 6 County of Orange Resources and Development Management Department Ronald L. Tippets, Chief, Environmental Planning Division 6a. This text provides an introduction to the comment letter and does not require a response. 6b. Comment noted. Implementation of the OC-44 booster pump station would require acquisition of all necessary resource and encroachment permits, which could include permits from the California Department of Fish and Game (CDFG), r Army Corps of Engineers (ACOE), U.S. Fish and Wildlife Service (USFWS), and County of Orange. r 6c. Refer to Response 6b, above. 6d. The proposed project site is within close proximity to the Talbert Channel. The proposed conveyance pipeline would be either microtunneled or directionally bored beneath the Channel, and would not impact the levee service road. In addition, the project would not place a block wall adjacent to any public trails. Moreover, as shown in DREIR Exhibit 3-16, CONCEPTUAL LANDSCAPE MASTERPLAN, landscaping is proposed along the eastern side of the subject site, adjacent to the Huntington Beach Channel. To clarify, Exhibit 3-19, DESALINATED WATER DISTRIBUTION AREA of the DREIR depicts existing water conveyance pipelines in Orange County. The proposed project would not impact the listed trails/bikeways. Note that the proposed distribution pipeline would be microtunneled or directionally drilled beneath the Santa Ana River and Greenville-Banning Channel, and their associated bikeway and trail would not be disturbed. 6e. Refer to Response 6d, above. 6f. This paragraph provides contact information for the County, and does not require a response. - r r City of Huntington Beach August 17, 2005 92 r COMMENT 7 . 111 ..-MWD ' METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA ' EzecVive Office ' May 26, 2005 II Mr_.ricky Ramos City of Huntington Beach impartment-of Planning 2000 Main Street `I=lurnington Beach,Califbrnia�548 Dear Mr. Ramos: Recirculation of a Frei $nvirotunzntai itrtt7act R�prn-t forth seawater Desaiirtation-Proiect at'l i tington Beach -lheMetro elitan-Water Dstrict-of Souhern-Caiiarnia( a oli -hzs received a copy of the Recirculated Draft Environmental Impact Report(Draft EIR) for the Seawater Desalination ' -`Pralect at HuntingtoiiBeach(Project). The city of Huntington Beach(City)is acting a9 the Lead `Agenoy for this Project. The-Prc-*t consist of the-construction-and-operation of a 50 million gallon per day seawater desalination facility within the City. The facility would consist of -seawater intake pretreatment-faciiities1--",esaiination-plant utilizing reverse-osmosis technology, product water storage, two pump stations, materials storage tanks, and 42 to 48-inch diameter. —product water transmission pipeline possibly up t6-10 Miles ii lend iri Huntington Beach and ' Costa Mesas. The facility would utilize existing seawater intake and outfall pipelines for its operations. The proposed Project is located on an 1 I-acre portion of the 22-acre Huntington _Beach Generating Plant:Iocated at 2173DISIewland.Street,.off Pacific.Coast.Highway. The proposed Project includes construction of an underground purnp station in a portion of ed-Orange-County;south--of-Bonita,Canyon-Drive;neartha--castern border of the City of Newport Beach. A second pump station is proposed in a church parking lot located at a 494-Alton-Parkway within-the-City of Irvine. Bet -Metropolitan and-its-m.ember-agencies have a responsibility-to-provide adequate,reliable, high quality water supplies to meet current and projected water demands in Southern California Tz-d=end,-aiternative--water supplies must be exploredbeyond-the additional development of -,-current.i.' ported supplies—Over_the-past seYer$1-decades,.Mztropoliran.has explomd-the potential of seawater desalination as a water resource alternative for Southern California. More tl3r;Metropolitan's-Board of Directors adapted policy principles in-February 2001, which define a strategy for the development-of brackish and seawater desalination. These policy -prirrcipirs will-serve as-guidelines'in-definingthe future direction'of seawater desalination NV ' 704 td 4tamatfa Street,Los Angeles;Catifomia 9MI �-Mailing Address-Box 541753,Los Anples,Csttfornia 9305d-0153• Telephone(213)217-6000 r r- r— -THE METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA r— Mr.'RickyRamos Page 2 May 26;2005 ?development through-strategic p1mmingpmcesses: This-letter contains-Metropolitan's views, as a potentially affected public agency, on the scope and content of the Recirculated Draft EIR, a General Comments Metropolitan's July 2004 Integrated Water Resources Plan Update(IRP,Report 1236), --iasta'blishes that Metropolitan aiid its member agcncica arc pwinca in crnyuring adequatz, m1lable, high quality water supplies to meet southern California's current and future water demands. The guiding principles-of the IRP are reliability, affordability, water quality;-flexibility, b -enxironmenta.lTBnd_insdtufiozW-ranstraints.. Th-e.IRP-and M-etropolitan'-s-water rate structure - support the development of local water resources by member agencies,recognizing contributions `c,f a l projects to-wateersupply-reliability-f�Frsot-thernCalifarnia. -` 'he-iRF-also recognizes seawater desalination as a potential supply option for the region. r-- Metropolitan remains concerned about the ultimate fate of the additional bromide loading from he—desalinated-se is-expected-to be-0:�mg/L, greater than drought-level bromide concentrations in State Water Project(S`VVP). High bromide levels may C r I ncrease disinfection-by-products.'-Some discussion of the accumulation of bromide in the groundwater basins should be included in the EIR. r Additionally, Metropolitan provided a comment letter on the Draft EIR, dated October 28,2003, �($ttsched). Our review of-the-Recircuiated Draft EIR indicates-that-some bf our comments, restated below,were not adequately addressed. '£he-lrvirie-Cross Feeder and the East-Orange County Feeder No. 2 are within the proposed _lacxtion foi.the undergrannd booster.pump station.-According-to.the-Recirculated Draft EIR, the proposed site for the booster pump station is within an Orange County Resource Preservation . went, about 'A mile north-of the-San-Joaquin-Reservoir;where the-East Orange County Feeder No. 2 and the OC-44-transmission pipelines converge. These facilities are owned and operated-by Metropolitan. Metropolitan is concerned with potential impacts to the East.Orarge County Feeder No. 2, the Irvine Cross Feeder,and Service Connection OC-44 as a result'of the construction of the -4=p_csed.boostar.pump.station..Metropolitan.requests-that the-City.consi4er-our facilities in its project planning and identify potential impacts to these facilities that may result from Project -impk-mcritation. Service Connection OC-44 is awned and operated by Metropolitan and, therefore,coordination with Metropolitan should occur prior to project approval. Further,Metropolitan requests that the City-address operational impacts and mitigation e Tnrasures,-ifany,related-ta-the-introduction of desalinated seawater into Metropolitan's regional r ' THEVE—IRUPOLMAN'WATrR DISTRICT OF 50UTFIERN CAOFORNIA Mr.`Ricky"Ramos Page 3 May�,2005 �i' ,ib,ution-system. MomspecifteaHy;ivfetropolitan-recommercds-th-at-the City and Project Applicant coordinate with Metropolitan regarding operational and design issues presented in Appendix D-Pressure Surge Analysis. This technical document extends beyond the scope of ,.the raft EIR review andrequim.extensiye nnnrdinAt_inn,.analysis,.and review among all parties involved. Based on preliminary evaluation of the proposed introduction of desalinated seawater in-to-Metropolitan's-regional distributions-yst-en3;-hydraulic conditions and surge impacts would affcat current operating conditions_within the distribution system. Agreement on the operational 'feasibility of connecting-to Servicc�onnection-OC-4-4-,-the-i✓ast-O=ge County-Feeder No.2, and the Irvine Cross Feeder requires further review. `In-order to avoid potential conflicts with-Metropolitan's rights=oi-way arid'because the booster . lip-station-is-proposed to connect-to Service,Connection-OC-44i.we-require that design plans for any activity in the area of Metropolitan's pipelines or facilities be submitted for our review -andwritten approval. in-addition,-Metropolitan must-also be-allowed to maintain its rights-of- way and access to our facilities at all times in order to repair and maintain the current condition of those facilities. The City may obtain detailed prints of drawings of Metropolitan's pipelines and rights-of-way by f `calling Metro politan's.Subsuuctures tnfnrmarionl.int at j213)217-6564. To assist in preparing ' plans that are compatible with Metropolitan's facilities,easements, and properties,we have enclosed a copy of the Cruidelines-far-Developments in the-Area of Facilities, Fee Properties, and/or Easements of The Metropolitan Water District of Southern California." Please note that ' �li�ubrnitted designs orplans must-ciearly-identify Metropolitan's-facilities and rights-of-way. Metropolitan also requests that the effect of blending water sources with differing temperatures_ ' be discussed in the EIR. The EIR should also demonstrate that blending desalinated seawater nrhes sources produces-.an aesthetically ac:eptgbla end product. -Additionally,the EIR g should also demonstrate that the delivered water must be acceptable to all downstream users for 'itsaesthetic qualities,-temperature;zridail•regulated and unregulated--constituents. It appears that few of the downstream users have been consulted in this regard. "Speci-fic Comments o va Surer tears,-Page.11-2(Ifigt paragraph), Page 3-3v.(first par4graph); and Page 5.9- 10,Coastal Junction Pump: In addition to pumps,telemetry equipment, appurtenances and one ' des-el-powered electrical generator for-emergency-back-up purposes at the Coastal Junction pump station, the EIR should assess the need for surge protection as provided for the OC-44 puttup station. r-- 7HE 7b#TROPOLTAN WATER DISTRICT Or SOUTHERN CAUFORNIA Mr:�icky-Ramos Page 4 hay 26, 2005 age-3-32: -Table 34-sh-orm-onty selectedwater-quality parameters andthe'table overstates the r benefits of desalinated seawater. Some-parameters such as bromide and chloride significantly increase. Although a high Total Dissolved Solids(TDS) may be indicative of water with higher coTr❑Qivity,.it is actually - f-specifir.ions that-iriffuences-corrosion. While r sulfate is lower in desalinated water, chloride will increase.by about 100 mg/L. Furthermore, the '`Recirculated-Draft SI-R-inons6tentIy states-thcavc-age TDS-ofthe desalinated water. In Table 3-1, the TDS is shown tss 250—350 mg/L, a significant dccrcaw from Metropolitan's Diemer r "Fil±ration-Plant-water of 373 --4-9j-mg/L.Aqowevar;-Apptndix-b-(PagccO3 3)shows the TDS of desalinated seawater as 3 50—400 mg,/L. , age 3-34, (first paragraph;Tirst sentence):- ?he sentence stating-i`.::the seawater r '`desa-liaation-facility-would-use fewer-c�icals-of lower-dosages-then-existing conventional water treatment plants in Southern California,because its unique source of water ... is of r significantly better quality Itm,other available sources .:." is incorrect;--First,the seawater desalination facility will use f3r�,greater chemicwt dos es than ty-piceI ,urfz e water plants (e.g., 5-10 mg/L ferric sulfate, 30 mg/L of lime [App. 0-91,6 mg/L of carbon dioxide, 15-20 mg/L of j -sulfuric acid Jim the full intake-&w,-aat-the product-water-#lowj.;polyrner-tof0.5 to 1 mg/L, and membrane cleaning chemicals). Second,the Watershed Sanitary Survey [Appendix E] shows '—g ficant contaminatittr►-potentialszi t-arc--greaterthan-experienced in-surface waters (e.g.,an unidentified source of bacteria and ammonia,with ammonia concentrations as high as 1.7 mg/L, r `red-tks;and praeess-water-and drainage). --P-age336.(first paragrs-sh,-Zrt €e):-Please-change-this-sentence to read as follows: "It r- is well established that Southern California as we know it today could not exist without the k '-rn-'s historic-inv Me estrnent-in 11111LIeJUM varied,lor-al-and-imported-water projects." r .P�ge 3-36.(first paragraph,�e�aentence):..-Pleast rl+ange this sentence.to read as follows: "These well-known regional water projects include: the Los Angeles Aqueduct(operated by the Les-AngelesDepartrnent-of-Water and-Power);-the-Slate Water-Project(operated by the California Department of Water Resources [DWRI); and the Colorado River Aqueduct (operated �' y N%M);as well-as-award=winning-conservation, recycling wid other local water supply projects. �Page3-37,A.-Tbe-Project-Provides a Drotight=Proof Water-Supj5ly, (first paragraph): The statement.that."-California.has-noi.=perienced_the-hardships and environmental pressures of a prolonged drought since the early 1990s..:"could be misinterpreted to mean there has not been a `grelsnged-draught since-the-early-1990s. -The-years-2000-through 2004-were very dry for Southern California; 1999 through 2004 were record drought years for the Colorado River Basin; � tO1,1002,-and 2004-were-dryyears-foT-the-State Vater Project watershed. r ' THE METROPOLITAN WATER DISTRICT OF SOUTHERN CALIPORNIA Mr—. Ricky Ramos P�ge 5 P� ay 26;2005 ' The IRP for the region, which was first adopted in 1996,establishes a water resource mix that would meet the retail-level demands under all foreseeable hydrologic conditions. As a result, Metropolitan-and.its member agencies-embarkeddr.-de-v ment of.wateruse efficiency measures,local supplies including recycled water, and storage programs. Metropolitan's storage rapacity-hasiaercasedmwrc-thffirtcrr-fotd-from-1996 to-2-e05.-Metropolitan also adopted a Water Surplus and Drought Management Plan in 1999 to guide its management of water through wet arid-dry ycars.-The investments thatMetropolitan and-its member.agencies wave made and the prudent management of water have prevented hardships to end-users during the dry period of the early 2000s. m Additi-onally;these two-sentences-stale—..:hut-expeTmagrec�thatsimilar or worse conditions of unreliable water.supplies..."and"During-long-o£zx-tremedroughts,-water.supplies are less reliable; ..." The use of the word"unreliable" or"reliable" is confusing. In fact,water supplies ' '-are7elia y-Iess-during-drought. "Me4ropolitan-suggests.clarifying-these-two-sentenoes-with-the-fbkwing:-"It-is recognized that ' Southern California,being in a semi-arid region,periodically experiences droughts that could be Oro-langed. During-long-o7extreme-droughts;water-sapplies-are-reduced,-groundwater levels decline and conflicts increase among water users." ' "Page 3.37,A:-The Project-Provides a-Drought;;ProofWaterSuppfy;�`third paragraph, second sentence): This sentence implies that construction of Diamond Valley Lake is rot ' complete. It implies that improvements in infrastructure are needed at Diamond Valley Lake to '\-a&_f1exibility in operating.-C�ia'-s-water-.syst=- In.fact,-Diamond Valley Lake and the � other projects mentioned in this paragraph have been completed and are operating. Metropolitan- 'suggests.that the first-scntence-af thisparagraph is-changed-to-read-as follows, "Recent changes ' (primarily improvements in infrastructure)should make it easier to respond to future drought conditions." ' 1ge-3-37;-Ai-TIre-Project P-r-eyk es-a-Drought Proof-Water-Supply,(Last-paragraph): Please update this and all subsequent references to the Draft 2004 California Water Man to the 0 'Pubiirl-Review Draft of the�Californi a-Water Plan-Update, released-irf April 2005, Page 3-38, A.The Project Provides a Drought-Proof Water Supply, (first paragraph): Please-change this sentencu-to-read-as-foilows,"..:Seawater Desalination-Project at Huntington p ' Beach would add even more flexibility in operating California's water system, and would provide particular drought relief in Orange County." 4 ' Page 3-38,B.The Project Provides a Replacement Water Supply: Replace"through ongoing ro -tributions to MWD"with"through ongoing water purchases from MWD." q r 7AE METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA Mr Ricky Ramos Page--6 May 26, 2005 f Page"3-38,B.The Project Provides a Replacement dater Supply: The description under this section is misleading.-.Tb ssectionstates_that-envirenmental_coz rzints-.leave-reduced supplies from the SWP and Mono Lake area. Metropolitan's deliveries from the SWP have increased "sigiuftcantly-since the avai i�itq afstar$ge capacity. -Additions y-Metropolitan's-IRP has r accounted for the variability of supply availability and determined that resource targets are adequate:ta meet all retail demands under various hydrologies; -In other words, there is no additional need to replace water supplics from SWP or Mono Lake. f 'I'1;-s section also seems to imply thehistoric over-usage of up to 1 million acre-feet per year by 'the-State of Caiifomi:a-is-an-arnotmt"last to thermion-and needs-to-b-e-repiaced by Metropolitan or Orange County. According to Metropolitan's IRP,the.r_esource.target for Colorado River r supply is full aqueduct when needed. This goal is achievable with the Quantification Settlement Agseernent and Interim-Surplus Water-Guidellnes;and programs Metropolitan and its member . agencies have implemented, including the San Diego County Water Agency-Imperial Irrigation r '-District water transfers tire-Water-Supply-Managcmcm and-Crop-Rotation-Pmgram at Palos Verde Irrigation District, and storage programs such as the Hayfield Water Storage Project. Metropolitan suggests that this section be renamed "The Project Provides a Water Supply to '•Enmwe Reliability.fo_T4g ndle_Unrerraiaties."-Water--supply-planning-inherently fates a number of uncertainties.such as more extreme hydrology than experienced in recorded past, r -higher-than projected econefftic andpopulation-grawwth;more-stringent-water quality and environmental regulations,contaminations to water supplies, and delays in implementations of planned water supply projects. r .'a-ge-3-4$,-SouthernCxt forn!a*s-iritegrated-Wa'ter-Resources Plan:-Please replace the reference,-and-all.subsegt=t-refierences,-to the_2003 iR:Pd3pdatr to-the-IRP-Update,July 2004 or S simply the IRP Update. The dual dates of 2003 IRP adopted in July 2004 are confusing to readers. The No Project Alternative would not result in any"shifting" of resource targets in the IRP t `Update.-The-IRP-resource-targets are established based on-a number-of factors including the desire to have a diversified portfolio,affordability,water quality, and physical,environmental an3'institutional constraints. -Ps;e 74,2.Increased.Ilse-of-1mporked Water-Supplies As mentioned above,the No Project Alternative would not cause any increased use of imported V -aratcr-supplics-.:-Furthermore;thzstaten=T that"Waterpiazmzrs arc-continuing to project increased reliance on imported water supplies"is untrue. The IRP resource target for Colorado -River resources-is-full aqueduct when needed, as was the 1996-IRP target;both of which are r 1 ' THE*IWF7ROPOV7ANWATER U15TIR7CT OF SOUTHERN CALIFORNIA Mr. Ricky Ramos PageJ7 May 26, 2003 ' —cm3istent with­p=practices: Metropoiitan and its-nzrtttR-,r-agencies-have-implemented-and are in the process of implementing approved programs (see comment to Page 3-38, B. The Project u `Provides a Replacement Water-Supply;'for examples of programs)to manage-this supply. ' Likewise,the IRP resource target for the SWP reflects supplies from existing infrastructure and operations, and identified projects under various-stages of implementation. ' The assertion that water transfcrs"havc&=anomie egaloeatian and cnvi-onrncntal isaucs rclatcd to `the-Delta"and `would result in economic and environmental impacts" is nor true. Metropolitan's policy on water transfers (Metropolitan Administrative Code § 4203,provided — eiow�addresses-economic-and-environmental Imes. §4203. Water Transfer Policy. 'To meet its public water supply objectives in--the-future.-Metropolitan will vigorously pursue the development of water transfers, subject to the following considerations: (a) Water transfers, including water marketing, will be developed only on a voluntary basis with willing partners; ' 'b) -A-futi-range-ofwaterrtransfer-options will-be-pursued, including arrangements with appropriate state and federal agencies, public and private water entities,-and individual water-users; (c) Water transfers will be designed to protect and, where feasible, enhance environmental resources; -(d)--Water-iransfers will be designed-to-amid-cantributing to or creating a condition of long-term groundwater overdraft; e Irfforts.will-continue-tozdeveio -watertransfers in-cooperation with the ��� p p agricultural community,which seek to avoid unreasonable operational and financial impacts; and (f) Strategies will be developed to appropriately address community impacts of water transfers. M.I.-39412-January-14,1992. r- r- 7HEVETRaPOf/TAN WATER?Lr7STR1C,-, pF MU7h,ERN-CAL7FORNlA r— Mr-.Ricky-Rmnos Pa e $ My 25,-2M —rzp-T-3,-4:Cans-trnction-of AttinnatLoeal-Water Supply-Prcjests�last sentence) r It is our position that without the proposed Project, other local water supply projects may be --constructed;bat not additional projects. Furthermore,currendy planned projects by member W agencies and their retail water suppliers meet or surpass the IRP target. Please clarify this issue in this paragraph. Appendix N, Page N-9 (ehtrd paragraph): The rapid disappearance of combine chlorin; r- residual-in-the disinfects-i-reverse- peme ate must-be-considered-a-significant impact-an product water quality. Appendix N showed rapid decay of the chloraminated seawater or X -blmded water. The rapid decay-of dhtoraminawd water releases additional ammonia that increases the risk of nitrification. Further study must be conducted to assess the impact of the r- chlorine residual decay. `We--appreciate-the-opportunityto provide input-to-your planning process'and we look forward to receiving future environmental documentation on this Project. If we can be of further assistance, j please contact me ar(213)217=b242. y r- -V_cz:y,kuly yours, Manager,Environmental Planning Team r ZZ1JIlyd1 (Public Polders/EPU/Leners/2O-MAY-OSA.doC—Ricky Ramos) _ r, �ncfasure:Metropolitan-Ietter,datedOctober28,20.03 r-- r r r r— 1 1 ...COPIV 1 MW UFTRDPDLITAN WATER DISTRICT OFSDUTHFRN CALIFORNIA 4" ' October 28, 2002 Nfr Ricky Ramos ity of Huntington Beach— Main Street Huntington Beach,CA 92648 Dear-Mr:Ramos: ' --Dra�ft-F_-nvironmentalJm Pact-Rcwitfor--the?trseid-on-Szawarter-Desaiinatian Project The Metropolitan Water District of Southern California(Metropolitan)has received a copy of.the DraftEnvironmental Impact Report(Draft EIR) for the Poseidon Seawater Desalination Project. T-he-.proposed projeci gallons per day seawater desalination facility within the city of Huntington Beach(City). The facility would 'cvnsist of seawater intaik-e-pretreatnwmfaeitities,-a-seawater'desalination plant utilizing reverse osmosis technology, product water storage, two pump stations, materials storage tanks,and 42- Z to-4&inch diameter product water transmission pipelines up to ten miles in length in Huntington Beach and Costa Mesa. The facility would utilize existing seawaterintake and-outfail pipelines for operations. The proposed desalination facility would.be located on seven acres of the `existing 22-acre.AES-.Huntington-.loch.Conerating..Plant located-at 2-1.7M Newland-Street,-off Pacific Coast Highway. The proposed project includes construction of an underground pump ''station-in-aportion of-anincurporated-Orange{btmty;south of-Bonita-Canyon Drive,near the eastern border of the city of Newport Beach. toffi'Metropolitan and its member agencies have a responsibility to provide adequate,reliable, `-high-quality water supphes-to-mect-current-and projected water-demands in-SotAem California. To that end,altemative water supplies must be explored beyond the addidonaI detvlop:nent of current imported supplies. Over the past several decades,Metropolitan has explored the poteniial_of seaw2=dl--salinaiionss.s..water-resource-alternative for-Southern California. More recently, Metropolitan's Board of Directors adopted policy principles in February 2001,which de€ttte-a strategy-for-the development-ofbrackish-and-sca.%Ver desalination. These policy a a principles will serve as guidelines in defining the future direction of seawater desalination development through strategic planning processes. This letter contains Metropolitan's views, as `s-potentially.affected-public agency,-on-the-scope and cont-ent�of the Draft-£IR. General comments are contained within the fallowing paragraphs; specific comments to the Draft EIR are 'Z,antametl-within-a separate section-following-the general comments. r- -MT.-Ricky-Ramos Page 2 October-2S 12002 -tGur-revi.ewaf the Dr-aft-EIR-in6cate-s-that Aletitopolitan-has in the-vicinity of the proposed desalination plant, However,Metropolitan owns and operates facilities in the vicinity 'ofthe-off site proposed undergromdtaoster pump station location: The irvine Cross Feeder and r the East Orar_ge County Feeder No. 2 are within.the proposed location-for the,underground booster pump station, The underground booster pump.station is proposed to be located at the --r-= rgence of-the.East-OrzW r' ;E-eedc-r-No,.2.and-the-Irvine-Cross Feeder. -According-to a s the Draft EIR,this proposed location is within the Orange County Resource Preservation -E-asernent,-The booster-pumgstati-on is proposed-to connect Zo-Metropolitan's Service Connection OC-44 of the East Orange County Feeder No.2, which is owned and operated by 1-1Pietropolitan. 'Mctropolitan-isron=med-with-goteriu- -impacts-to-the-East-GrangeJCounty Feeder No. 2,the Irvine Cross Feeder,and Service Connection OC-44 as a result of the construction of the proposed-booster pump station.-Metrop67 itan requests that the City consider Metropolitan's `facilities in its-project planning-and-ideati#y-potential-impacts-to--these facilities as a result of ab project implementation. Service Connection OC-44 is owned and operated by Metropolitan and, `therefore;coordinative -shurdd oc=-prior-to project implementation, -?ut-ther,-Metropolitan-rcgncsts that tine-ity-address-aperationalimpacts`ontl-mitigation measures, if any,related to the introduction of desalinated seawater into Metropolitan's regional 'Bis-tribution system:-More spec-iid0y,-Metrop6litan recommends that the City conduct a hydraulic analysis that supports the operational feasibility of connecting to Service Connection OC-44,the East Orange County Feeder No. 2, and the Irvine Cross Feeder. Based on preliminary aC.I sValuation-ofthe.proposedlntmAlletio❑ of de-,auntsd-wgwaW.into,Metropolitan's regional distribution system, hydraulic conditions would exceed the design gradients of the Irvine Cross `fFme -&ad4 ereach-from-Bernice C-onnection -44-=r�o-C astai-Junzrtion Pressure Control Structurc at the East Orange County Feeder No.2. Im- crta Evoid potentiai vnifi -with-Metropolitan's rights-of-way acid-because the booster _putrip stati-anis-pronov�d to cnnn=-MScmice-Connection-OC--44,-we-requim-that.design plar3s for any activity in the area of Metropolitan's pipelines or facilities be submitted for our review -and--,.w4tten-approval.-4n-ad-dition,Metropolitan-must also be aliowed to maintain its right-of-way and access to our facilities at all times in order to repair and maintain the cument-condition of ft-see facilities. adi -Tie City may obtain-detailed?Hitts- '-&awings-of Metropolitan's-#peiincs and rights-of-way by calling Metropolitan's Substructures Information Line at(213)217-6564. To assist the City in '` preparing plans that are compauble with fmc-tropolitan,5 fac:.'':•`: .''s and ease:ne..ts,we have `�enclnsed a copy.of The"GuidelinesforD-evelopmetzts.4n-the-Area of Facilities,.Fee Properties, and/or Easements of The Metropolitan Water District of Southern California." Please note that �- all--submitt, cd-tiesignsor-pians-must-clesrly-identify Metropnlitan'yfacilities and-rights-of-way. Mr:-Ricky Ramos Page-3 October 28, 2002 'N tropolitan believes that tthe general discussion of seawater desalination in the Draft EIR ' shouW convey.the water supply reliability. In addition,Metropolitan requests that an expanded discussion of water quality impacts and ae 'benefits;as$resultof-ffie-seawater-desalination project;ba added to the Draft EIR. Metropolitan does not believe that the issue ofpotential water quality impacts of blending desalinated water supplies with imported water supplies has been addressed adequately. It is unclear how backwash soliQ9 will be treated np,_E0_di�e...1be-chemicals ferric chloride and polymer were described to treat the influent water,however, it is not clear how residual '-so=ids.would be removed, these vhnifi=are not described-in the project description or on schematics(note Exhibit No. 6). An expanded discussion is n6cessary. a� Metropolitan requests that the effect of blending water sources with differing temperatures be discussed in the Draft EIR. The report should also demonstrate that blending desalted water with other sources.produces-anaesihericaliy-acceptableznd product..-Additiow ly,the report should also demonstrate that the delivered water must be acceptable to all downstream users for its `sesthetie qualities;temperature—,and-all regulated mid unregulated=stit=rM. It appears that few of the downstream users have been consulted in this regard. Specific Comments: _Sectiori 3.Q ?reject Characteristics),page 3-20: In the Water Delivery subsection, no was providrd the 3tatensetrtthac eielivery reii-atiitity would be improved by the proposed project. Delivery reliability depends on numerous factors suchas storage,_multiple pipztines, and multiple power sources-(arid'backup power supplies), Though the project would add additional treatment capacity, the lack of significant storage may limit the improvement in reliability. Additionally, on page 3-16,the report states that the desalination facility output may _J2escdu=d.for.electriciLy ran seruation.-.-It.is_unknown how this.would-be implemented. That is,- ag would the power source be interruptible by the electricity provider? Would flow reductions for �eleetricit}F tonservatiom be-offset-by-other regional water-supplies?-Adequate storage for a new +� supply is integral to improving reliability. Section 3.5 (Froject Needs and Objectives),page 3-20, 2nd paragraph, Ist sentence: The phrase `kept in-times of extr-ene-droughtj"Wirth re were numerouszrccasions-where the imported water system did not meet all of the region's supplemental water supply needs. However, March 1991 to March 1992 was the only one-year period that all of the region's ,water supply-aeeds-were riot-met. This-was the-last-ye$r-of-a-s3x-year tkought. a Metropolitan requests that this statement be revised to more accurately reflect that there was only "aneyearwhere all of the zegiun-s-suppiemental-water-supply needs were not met. r-- -My'- Ricky Ramos Pase 4 October 28,2002 Section 3.5 (Project7Veeds and Objectives),page 3-21, ?nd paragraph, 1st sentence: Revise this sentence to read,"Solutions to potential water shortage and reliability problems include water r` �mana¢Pmen2.prnerasns-tan-imoo edw�ter-s ums as-ill--z-_art-incr°ased-reliance on marry different sources of water supply and a continued emphasis on water conservation through '-inplm=ntation--ofState-approved--BtstManagement-Practices(BMN)." 71 -,3eation.3.5. -page 3-24,.2nd partag-aph; last-sentence: No offset is needed according to Metropolitan's plan. Additional supplies are necessary to accommodate r erected increases-in poptAation-wxl-economic-activity. *7epoL -on Metropolitan's Water Supplies,dated February 11, 2002 is provided for your information. '-Sactron 3:5-(Projec7'Needs arid'Olijectives),page 3?7,-3rd paragraph;3th sentence: Revise the -fib-sentence-to-read, "Depending-upon-tcrtumlvgicaiadv=erttents--and-economic constraints, the IRP projected that as much as 800,000 acre feet of recycled water could be made available to , -die on by-year 202C." -lZec4an 3.5-(Pitoject-Nees ;-page Revise the sixth sentence to read, "Recycled water projects will certainly be relied upon to help meet p-mj-ected-growth in the region. ah motion 3.5{Project Ideedssd C3jeetives), pugs 3�21, thpuragrupta, d sentence: Revise the second sentence to read,"Consequently,seawater desalination was also one of several potential resource-aptians ideriti£ed irithe-19WIRP" -Sestien 3.5{Project Needs Ord Object s);par-3-21,-*hVw—ttgraph,-4th-se:n ence:-Revise the fourth sentence to read"The IRP stated that based on.feasibility studies on potential projects, `abuut 20a,=acre=feet-per yearjof desalinated ocean water)coiiTdbe-developed by 2010 (p.3- " 12)," _Sectioii-3:5(Project Needs and Objectives),page 3-21, 4th paragraph, Sth sentence: Revise the f&hsenteri to.read,_"-Tle-propoted-P-0se;don-seawater-Desalination-Project represents an opportunity to develop approximately 56,000 acre-feet per year, or approximately one-fourth of 'the-potential for-seawater-d-esaiiriation-development identified by the 19961RP." 'ect'ian 3.5-(Prajsct#eeds arcd flfrjertivesj;page-;22;lstparagraph,-Iasi sentence: Metropolitan disagrees with the statement, "In-genera.L t]ticipated statewide shortages.can be expected to translate to equivalent local and regional shortages,with similar economic and �euviranmerisal-effects."-�ertate ll{S$)231 d 5$610-require-de-monstrationof waterstg y reliability prior to development. Revise the text to include the statement referenced above and 'Include-the-information Provided-in-the-comment regarding SS 221 and 610. fi -Mr:Ricky I:amos Pale-5 October 21, 2002 Section 3:5'(ProjecfNeeds and Objectives), page 3-23, fable 3-2: Table 3-2 does not include �plafmed projects-and4ropc Etan-dornvs- t bci-reve-thatthistable-shami&be used as the basis for developing conclusions related to future water supply needs. Metropolitan requests that Table 3- ah `2 and the paragraph on page 3-22 that references the table be_deleted. `Seetlen-3,7(,4gree=nt;-Ptrmiis;-and,-fpprovals-fi`e-guired),-page-3=23: -Add-Metropolitan as a responsible agency for access to its rights-of-way. ' Section 4.6 (Public Services and Utilities),page 4.6-11: In the Water Compatibility subsection, the port states, ;MVVD water vanfd�nzst-tikudy-have aslightly higher-level of organic a; carbon content and disinfection by-products...",but offers no evidence for this statement, -7�tropolitm requests-supporting evidence. =5ertian 4.6(Putt r-Servizms and Uftier),-Table-4.6-7,pages A: -72=4.3?b:-Table 4.6-1 describes product water.-qualities from the-progosed4ir4ec2_snd-ota=sources.__Certain constituents such as chloride and sodium are substantially greater than from other sources. ak am ide-wt3uld-also,be-g4eater;-though-it4rrrtot-deseribe -inl ris-table): Though chloride, sodium,and bromide do not have direct public health significance, their impact on either reuse omsml; ide-r-hioride objectives)or[he"forrnation of disint'ectioiiby-products(bromide) should be explored. Section 4.6(Public Services and U111ities),page 4.6-17: In the Water Compatibility subsection, the report states,"Impacts in-regard,to water.compatibility_are maL miicipated.to be significant," No data or reports were described to support this statement. Proposed bench-and pilot-scale �-sugUes-completed feted durin -thee ' ak' p g ��;n-plrese phase-may-be be too late-tfl- concerns regarding water compatibility. The compatibility issue must be further investi"ated. `Section 4.6(Public Services any'Utiitc-es),page_4.3=77:­Iri the first sentence of the Water -Qml-ity subsection;the report-states;-"The•fmaj-pmmd=t water-will'be--disinfeCted at the proposed - desalination facility with free chlorine using sodium hypochlorite to meet the Department of '_Hegth-Services(DHS)treatment techriique requirements for potable water disinfection of a a' surface water source." More information is needed on this_process. For.example, what are.the expected disinfection by-products formed by this process? How will chlorine residual be ,,-measured,_particularly.in the-prescace-oftelatively high(--0,5- g/L)-brerntde concentrations? [Chlorination of water with high bromide results in the formation of bromine, which may complicate themeasuremernufand-disinfectionby-free chlorine]. -Mr:-Picky Ramos r October 28, 2002 We-appreciate the opportunity to provide input to yoar planning process and we look forward to ' ecLi'ving-fut=envirorarre=t do=n-erttation-an this project."If we can be of fu ther assistance, am I please contact me at(213)217-5364. -very truly yours, bye inai Signed By I". -Meister �- Marty Meisler Inttrim-Msnager, Environmental Planning Team JAITrdl (Puhlit FoldersfEPUlLettersl2&OGT-02.doc—Rioky Ramor.) r _EncioSUres: Planning ladidel"ines Copy-of'5Repert-en-Metx olitan s Water supplirs"(February 11, 2002) r- Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 7 Metropolitan Water District of Southern California Laura J. Simonek, Manager, Environmental Planning Team 7a. These paragraphs provide a summary of the project description and the background of the Metropolitan Water District of Southern California's (MWD). No response is necessary. 7b. This text provides an overview of MWD's Integrated Water Resources Plan Update (IRP). Noted with interest, MWD has formally promoted seawater desalination and as such expects its member agencies to address the issues raised in this letter. The July 12, 2005 MWD decision to financially support five reverse osmosis seawater desalination projects confirms MWD's willingness to work with desalination projects to ensure successful integration of desalinated water into Southern California's drinking water supply. No response is necessary. 7c. The Safe Drinking Water Act protects drinking water from unsafe disinfection byproduct (DBP) formation by regulating total trihalomethanes (TTHMs) and haloacetic acids (HAAs). Both TTHMs and HAAs consist of chlorine based and bromide based compounds. Currently, total TTHMs and HAAs are regulated while the individual compounds that make up the TTHMs and HAAS are not individually regulated. Individual compounds that make up TTHMs and HAAs are listed in Tablet of Appendix N of the DREIR. The project's potential to increase disinfection byproduct formation was analyzed in the Disinfection Byproduct Formation Study, included as Appendix N of the DREIR. The DBP Study analyzed various blends of desalinated water with water from other existing sources, including water from MWD's Diemer Water Treatment Plant. The DBP Study concluded that blending existing sources of supply with desalted water will have a very beneficial effect in terms of significantly reducing disinfection byproducts due to the low organic content of the desalinated water. For example, as presented in Table 2, page N-21 of Appendix N, the TTHM concentration of the desalinated seawater after 72 hours of disinfection contact time was only 2.4 ug/L, while TTHM level of Diemer's water after the same disinfection time was 74 ug/L. A 50%/50% blend of the two waters resulted in 27% reduction of the Diemer water's TTHM level to 54 ug/L. Similarly, the desalinated water HAA5 concentration was not detectible, while that of the Diemer water was 34 ug/L. The 50%/50% blend of the two waters reduced the Diemer water HAA5 level down to 18 ug/L. In addition, the use of desalinated water is not expected to result in a measurable increase in bromide levels in the groundwater for two reasons: (1) the volume of desalinated water produced by the proposed seawater desalination facility would contribute a relatively small portion (less than 8%) of the Orange County water supply, as compared to the other"low bromide" water sources. Only a portion of the desalinated seawater would be converted to wastewater, and only a portion of this wastewater would be treated and used for groundwater recharge, by the OCWD GWRS Project; (2) the groundwater recharged to the local aquifers via City of Huntington Beach August 17, 2005 107 r- Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS OCWD GWRS's facilities will be processed through GWRS's RO treatment system. Since RO membranes remove bromides as well as they do chlorides (i.e. would reject 90% or more of the bromides in the water), the bromide concentration of the desalinated water that would recharged through the OCWD will be at a level comparable to that in the other water sources. 7d. Section 5.11 of the DREIR, PRODUCT WATER QUALITY, includes extensive analysis of the proposed project's impacts on the potable water distribution system within Orange County. Various mitigation measures have been incorporated into the DREIR to minimize impacts in regards to corrosion, .taste/odor, water quality, and hydraulics. In addition, as stated in Mitigation Measure PW-9 (p. 5.11-24 of the DREIR), the use of existing distribution system pipelines owned by local water agencies for desalinated water distribution would require that the applicant coordinate with and obtain approval from those agencies. 7e. Refer to Response 7d, above. 7f. Refer to Response 7d, above. 7g. The desalinated water temperature will be in the same range as the temperature of the source water produced by the existing MWD Skinner and Diemer water treatment plants, and therefore, will not be a factor that would have a significant impact on the product water quality or would result in a measurable change in the temperature of the blended water. In 2004, MWD sponsored a Taste Test Study of desalinated seawater, which ` was completed by the San Diego County Water Authority (SDCWA). The results of this study have been made available to the MWD staff by the SDCWA. This study indicates that the desalinated water has comparable aesthetic quality to that of the tap water produced by MWD. Additional- discussions of the desalinated water quality are presented Section 5.11 of the DREIR. Desalinated water quality's regulated constituents are presented in Table 5.11-3 of the DREIR. Analysis of this table indicates that the desalinated water will be in compliance with the applicable drinking water quality regulations. Request for water quality analysis of"all unregulated constituents" is unreasonable and is not required under any applicable regulatory requirements and under CEQA. 7h. An analysis of pressure surges for the proposed Coastal Junction and OC-44 pump stations is provided on page 5.11-21 of the DREIR and Appendix D to the DREIR, PRESSURE SURGE ANALYSIS. 7i As stated in the title of Table 3-1 (DESALINATED WATER QUALITY — KEY PARAMETERS) on page 3-32 of the DREIR, the purpose of this table is to only show key water quality parameters regulated by the applicable federal and state regulations. A complete characterization of the water quality of the desalinated water and comparison to other water sources in the area is presented in Table 5.11-3 and discussed in detail in Section 5.11, PRODUCT WATER QUALITY, of the DREIR. City of Huntington Beach August 17, 2005 108 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS It is agreed that the desalinated water and the existing water sources have differences. These differences are clearly shown in Table 5.11-3 of the DREIR and are not unusual or exclusive to the desalinated water. For example, MWD's Diemer water has chloride level of 69 mg/L which is over 5 times higher than the 13 mg/L chloride level in the Seal Beach Potable groundwater (see Table 5.11-3, page 5.11-11). That does not necessarily make MWD's Diemer water inferior in comparison with the Seal Beach potable water because both of them are in compliance with the Safe Drinking Water maximum limit for chlorides of 250 mg/L. Similarly, the MWD's Diemer water is significantly higher than Seal Beach Potable water in terms of sulfates (149 mg/L vs. 26 mg/L — page 5.11-12), but both waters comply with the sulfate limit of 250 mg/L. We hope that the writer will agree that five times higher levels of chloride and sulfates in the MWD water do not necessarily make this water 5 to 6 times more corrosive than the Seal Beach potable water or in any way unsuitable for distribution for public consumption. Similarly, the desalinated seawater is in compliance with all applicable drinking water quality regulations and differences of individual constituents do not detract from its benefits and from the suitability of this water for distribution and public consumption. Chloride and sulfate in the potable water are only two of the many constituents that have effect on the drinking water corrosivity. The chloride and sulfate limits in the Safe Drinking Water act of 250 mg/L were established in recognition that water that contains these constituents in concentrations lower than the regulatory limits will be safe in terms of distribution system corrosion. The concentration of both chloride and sulfate in the desalinated water is significantly below the regulatory limits. The accurate representation of the typical desalination facility daily average TDS concentration will be from 250 to 350 mg/L (average of 300 mg/L) as shown in Table 3.1. and Table 5.11-3 of the DREIR. On an instantaneous basis the desalinated water may reach 350 to 400 mg/L at times. The more conservative upper range of instantaneous TDS concentration of 350 to 400 mg/L was used for the purposes of the corrosion control analysis presented in Appendix O of the DREIR. Using these instantaneous levels allows to account for the maximum dosages of lime that may need to be added to implement a conservative corrosion control strategy. - 7j. The open ocean seawater is a cleaner water source than some surface water sources such as the Colorado River, which serves as one of the main existing sources of water supply for Orange County. The Colorado has a turbidity and organic content an order of magnitude higher than that of the ocean water planned to be used by the desalination project. As a result, the MWD's Diemer and Skinner surface water treatment plants processing Colorado River water have to use chemical coagulants at dosages of 40 to 100 mg/L which is several times higher than those planned to be used by the seawater desalination facility (5 to 10 mg/L). The desalination facility's source water is the HBGS once through cooling water Y 9 9 discharge. The HBGS withdraws the seawater from the ocean from an intake City of Huntington Beach August 17, 2005 109 T- Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS r structure that is submersed under the ocean surface and is over 1,840 feet off shore. Based on the source water assessment and sanitary survey attached in the DREIR, the area of the HBGS source water intake has no industrial dischargers or potential from impact from agricultural runoff. In addition, due to the significant depth of the HBGS intake, red tides have no measurable effect on the source water quality. As indicated in the Watershed Sanitary Survey `- (Appendix E of the DREIR), except for salinity, turbidity and pathogens the source water for the desalination facility meets all other drinking water regulatory limits. 'T 7k. This change has been incorporated into Section 3.0 of the Responses to Comments, ERRATA. r` 71. This change has been incorporated into Section 3.0 of the Responses to Comments, ERRATA. 7m. This change has been incorporated into Section 3.0 of the Responses to Comments, ERRATA. 7n. This change has been incorporated into Section 3.0 of the Responses to Comments, ERRATA. 7o. This change has been incorporated into Section 3.0 of the Responses to _ Comments, ERRATA. r- 7p. This change has been incorporated into Section 3.0 of the Responses to Comments, ERRATA. 7q. This change has been incorporated into Section 3.0 of the Responses to Comments, ERRATA. 7r. This comment adds additional information to that provided in paragraph B on page 3-38 of the DREIR. The information provided in this comment is consistent with the information provided in the DREIR. The sentence in the DREIR regarding reduced imported supplies from the State Water Project (SWP) and Mono Lake area specifically clarifies that the reduction is "compared to system capacity and earlier projections" and not compared to recent deliveries. There is no argument that MWD's IRP (discussed in the DREIR at pages 3-40 and 3-41) has identified resource targets for the SWP and the Mono Lake area. The only point is that those targets are lower than the system capacity and the earlier projections for these resources. Likewise, there is no debate that California's Colorado River allocation has been reduced from the amount the commentator characterizes as an "over-usage" amount of 5.4 million acre-feet per year to 4.4 million acre-feet per year. There is no intent in Paragraph B at page 3-38 of the DREIR to be misleading or to imply anything more than a "concern regarding the amount of water that would continue to be available for delivery through the imported water system." For added clarity, Paragraph B will be re-titled "The r Project Provides a Water Supply to Ensure Reliability to Handle Uncertainties" as requested (refer to Section 3.0 of the Responses to Comments, ERRATA). City of Huntington Beach August 17, 2005 110 r Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS 7s. This change has been incorporated into Section 3.0 of the Responses to Comments, ERRATA. 7t. The No Project Alternative does not include the Seawater Desalination Project at Huntington Beach and assumes that the MWD IRP Update is in place and would be relied on by local water purveyors in Orange County. The adoption of the No Project Alternative would not result in any shifting of resource targets as set by MWD in its IRP Update. The proposed project offers a "new potable water supply" of up to 56,000 acre-feet per year to meet future water demands in Orange County. 7u. The No Project Alternative includes a "planned for" increased use of imported water supplies (when compared to the plans in the 1996 IRP). Table 7-2 in the DREIR (derived from MWD's IRP Update) compares the 2020 supply projections for the Colorado River Aqueduct (CRA) and the SWP in the 1996 IRP and the IRP Update and shows that the IRP Update includes an "increased reliance on imported water supplies" in the amount of 50,000 acre-feet per year for the CRA and 57,000 acre-feet per year for the SWP. 7v. The Metropolitan Water Transfer Policy provided in this comment recognizes that water transfers can result in economic and environmental impacts. The Policy includes measures to avoid "unreasonable" financial impacts as well as measures to "protect" environmental resources and to "appropriately address" community impacts. It may be that implementation of this Policy could avoid all economic and environmental impacts resulting from such water transfers. Of course, other agencies seeking such water transfers may not employ the same policies as MWD. 7w. The proposed project is not included as one of the "local projects" in the IRP Update. The point being made by comparison in Paragraph 4 (on page 7-5 of the DREIR) is that 10 to 12 additional local projects (projects that have not been included in the IRP Update) would be needed to match the proposed 56,000 acre-feet per year additional water supply offered by the project. 7x. The process of chloramination of desalinated water has been analyzed in the DISINFECTION BYPRODUCT FORMATION STUDY (DBP Study), included as Appendix N of the DREIR. The results in the DBP Study indicate that because of the relatively higher levels of bromides in the desalinated water, a portion of the ammonia introduced to the disinfected water reacts with the bromide and forms bromamines. Although bromamines are an order of magnitude stronger oxidant/disinfectant than chloramines, they are less stable. Therefore, a portion of the initially formed bromamines dissociates to ammonia and bromides. Introduction of additional chlorine to the desalinated water beyond the levels currently used for disinfection of the existing water sources provides the excess chlorine needed to re-engage the ammonia released as a result of the bromamine dissociation. This additional chlorine and the ammonia released from the bromamine dissociation form chloramines and ultimately yield chlorine residual levels similar to these observed in the existing water sources. The modified disinfection strategies proposed to be used for the desalination system City of Huntington Beach August 17, 2005 111 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS do not require the use of ammonia dosages higher than these used for the chloramination of the existing water sources. Since no additional ammonia would be introduced into the distribution system beyond its current level, the risk of nitrification in this system is not expected to be elevated. As indicated on pages N-29 through N-31 of Appendix N of the DREIR, the r successful chloramination of desalinated water requires a disinfection strategy slightly different than the disinfection strategies used for chloramination of the existing sources of water introduced into the distribution system. The use of a IT- different disinfection strategy for desalinated water in order to match the existing chloramine residual of the other water sources in the distribution system would not result in a significant impact on product water quality of the desalinated water or the blend of this water with MWD water from the Diemer plant, as shown on Table 5, page N-31 of Appendix N. r The super-chlorination approach for achieving stable chloramine residual is not new - it has been used successfully by Tampa Bay Water, which blends water from five different sources in the distribution system. The plant has been r- introducing chloraminated desalinated water in their water distribution system since March 2003 without any observed nitrification related problems. Marina County Water District has been blending chloraminated desalinated seawater with other chloraminated water sources in their distribution system since 1996 without any measurable nitrification problems or disinfection issues. During the operational implementation phase of the project, the proponent will complete a distribution system water quality and corrosion control study. The test facility will incorporate testing of piping and fittings similar to those used in r the existing distribution system and will have provisions to compare the potential nitrification effects of desalinated water and imported water and other existing water sources. The results of this operational study will be made available to ; MWD staff for review in the course of project implementation and preparation of contractual arrangements for introduction of desalinated water into the existing distribution system. r� 7y. This paragraph provides a conclusion to the comment letter and does not require , a response. The commentator encloses a comment letter dated October 28, 2002. In accordance with CEQA Guidelines Section 15088.5, those who desired to comment on the DREIR were directed to submit new comments. Accordingly, comments received during the earlier circulation period do not require any response. "The lead agency need only respond to those comments submitted in response to the recirculated revised EIR." Although responses to the prior comment letters were previously made and are not required for the DREIR, each of the prior comments has again been responded to here. See Responses 7z through lam, below City of Huntington Beach August 17, 2005 112 r Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS 7z. This paragraph provides a summary of the project description, and does not P 9 P P rY P 1 P , require a response. 7aa. This text provides a description of MWD and its responsibilities, and also provides information regarding MWD facilities within the vicinity of the underground booster pump station site. No response is necessary. 7ab. All of the facilities identified in this comment are addressed in the DREIR. Coordination with MWD will be a prerequisite to project implementation. lac. In response to this comment on the originally circulated Draft EIR, the requested information and analyses have been conducted and are included on page 3-29 and in the Appendix D and G to the DREIR. The applicant continues to meet with MWD, MWDOC and local water purveyors to discuss operational issues. 7ad. Design plans will be submitted to MWD as requested. MWD will maintain its right-of-way and access at all times. ' 7ae. In response to this comment on the originally circulated Draft EIR, an expanded discussion of water quality impacts and benefits has been included in Section 5.11 and Appendix N of the DREIR. 7af. Refer to Response 7ae, above, and Appendices D, N, and O of the DREIR. 7ag. The increase in delivery reliability for the regional system that results from the project is solely due to the fact that the project introduces a. new source of supplemental water supply located in Orange County and is drought proof. Variability in sources of supply is a factor in delivery reliability. In addition, the desalination project design will allow maximizing electricity conservation by the following three operational practices: 1. Energy Load Management: Refer to Response 2n, above. 2. Use of State-Of-The Art Energy Recovery Devices: The desalination facility will be equipped with energy recovery equipment which will allow for the reuse at least 30 percent of the energy introduced with the high- pressure pumps of the RO system. 3. Use of Heated HBGS Water: The desalination facility will use warm generating station cooling water to reduce the overall power demand by at least 10 percent. The beneficial reuse of the thermal energy in HBGS's ` discharge will result in significant conservation of power. The effect of the power conservation measures listed above is additive (i.e. the total amount of power conserved will be approximately 60 percent [20 percent from off-peak use + 30 percent from energy recovery + 10 percent from use of warm power plant water] as compared to conventional desalination facility designs. City of Huntington Beach August 17, 2005 113 T-- Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS 7ah. This comment requests specific clarifying changes to the text of the originally circulated Draft EIR which are no longer relevant to the DREIR. The text changes were addressed previously as an errata item in the Response to Comments for the originally circulated EIR dated March 21, 2003. 7ai. Refer to Response 7ae, above. 7aj. The assumption that Table 5.11-3 of the DREIR (previously Table 4.6-1 of the originally circulated Draft EIR) reflects desalination permeate water quality rather T than product water quality is incorrect. Table 5.11-3 shows the average desalination facility product water quality after post-treatment and shows the desalinated water concentrations for all Primary and Secondary constituents t regulated by the California Department of Health Services. Combination of lime and carbon dioxide will be used for permeate post-treatment. The effect of the addition of these two chemicals on the desalinated permeate is already reflected r in the product water quality, shown in Table 5.11-3. Caustic soda will not be used for intake seawater or permeate treatment/pH adjustment. The specifications for post-treatment chemical additions are determined based on analytical, bench-, and pilot-scale studies. In addition, refer to Response 7ae, above. 7ak. Refer to Response 7ae, above, and Appendices D, N, and O of the DREIR. 7al. Refer to Response 7ae, above, and Appendices D, N, and O of the DREIR. 7am. This paragraph provides contact information for the agency, and does not require a response. r r- i� t City of Huntington Beach August 17, 2005 114 COMMENT 8 C±Lv of Huntington 5ecch SOUTHERN CALIFORNIAf2 6�no[ 26 May 2005 {J Y Mr. Rickey Ramos _ City of Huntington Beach Planning Department 2000 Main Street Huntington Beach, CA 92648 ASSOCIATION of GOVERNMENTS RE: Comments on the Draft Environmental.Impact Report for the Seawater Desalination Project at Huntington Beach-SCAG No.1 20020200 Main Office 818 West Seventh Street Dear Mr. Ramos: -izth Floor Thank you for submitting the Draft Environmental Impact Report (DEIR) for the Los Angeles,California Seawater Desalination Project at Huntington Beach to the Southern California 90017-3435 Association of Governments (SCAG) for review and comment. As areawide clearinghouse for regionally significant projects, SCAG's responsibility as the region's t(213)236-i800 clearinghouse per Executive Order 12372 includes the implementation of the California Environmental Quality Act (CEQA) §15125 [d]. This legislation requires the f(zi3)z36-i8z5 review of local plans, projects and programs for consistency with regional plans. ...scag.ca.gov We have reviewed the aforementioned DEIR, and have determined that the proposed a xrs:President:Coundimember Toni Young. Project is regionally significant per California Environmental Quality Act (CEQA) - Hueneme-First Vice President:Supervisor me Burke,Los Angeles County•Second Vice Guidelines (Section 15206). idenC Supervisor Gary Ovitt,San Bernardino rty,• immediate Past President Mayor Pro Ron Roberts,Temecula Policies of SCAG's Regional Comprehensive Plan and Guide, Regional Transportation Geld.Brawley�arCarrillo,lmperialCounty• Plan, and Compass Growth Vision,which may be applicable to your project, are outlined Angeles ny: voa Braithwaite Burke. Cngeles Couuntyy•ZevYaroslayskK Los Angeles P in the attachment. We expect the final EIR to specifically cite the appropriate SCAG ro P rty•Jim Aldinger,Manhattan Beach•Harry policies and principles and address the manner in which the Project is consistent with twin,San Gabriel-Paul Bowlen,Cerritos Cardenas,Los Angeles•Stan Carroll. La applicable core policies or supportive of applicable ancillary policies. Please reference ra Heights • Margaret Clark, Rosemead e Daniels, Paramount - Mike oispenza, our policy numbers to provide a side-by-side comparison of SCAG policies and ndale • Judy Dunlap, Inglewood - Rae elith,Long Beach•David Galin,Downey• Compass Growth Vision Principles with a discussion describing in detail how the GarcettL Los Angeles•Wendy Greuet.Los eles-frank Gurule;Cudahy•James Hahn• proposed project is consistent with and supports that policy or principle. ' Angeles•lance Hahn,Los Angeles-Isadore -. Compton •Keith W.Hanks,Azusa•Tom ` mge,Los Angeles•Paula Lantz,Pomona ,in Ludlow,Los Angeles•Cindy Miscikowski. The intent of this process is to provide guidance to local agencies that will contribute to Angeles • Paul Nowatka,Torrance• Pam mnor,Santa Monica •Alex Padilla, Los the attainment of regional goals and policies. Please provide a minimum of 45 days for eles-Bernard Parks,Los Angeles•tan Perry, Angeles • Ed Reyes, Los Angeles •Greig SCAG to review the Final EIR when this document is available. If you have any questions ih,Les Angeles•-Sidney Sykes,P Walnut•Paul regarding the attached comments please contact me at(213) 236-1851.Thank you. ot,Alhambra•Sidn Tyler,Pasadena-Sonia r as Uranga,Long Beach-Antonio Villamigosa, Angeles•Dennis Washburn,Calabasas-lack ss,Los Angeles•Bob Yousefum,Glendale• Sincerely, nis Zine.Las Angeles nge County.Chris Norby,Orange County " Stine Barnes,La Palma•John Beauman.Brea ru Bone,Tustin-Art Brawn,Buena Park• �- rard Chavez• Anaheim • Debbie Cook dington Beach-Cathryn DeYoung,Laguna _ rel-Richard Di=,Lake Forest•Marilyn Poe, Brian Wallace Alamitos•Tod Ridgeway.Newport Beach aside County:leg Stone,Riverside County• Associate Regional Planner mas Buckley, Lake Elsinore • Bonnie - kinger, Moreno Valley • Ron Loveridge, intergovernmental Review arside • Greg Pettis,Cathedral City• Ron 'ern-Temecula i Bernardino County: Gary Ovttt, San nardino County•Lawrence Dale,Barstow J Eaton,Montclair•Lee Ann Garda,Grand ace•Tim Jasper,Town of Apple Valley•Larry allon,Highland-Deborah Robertson,Rialto- �dvQST- n Wapner,Ontario - aura County.Judy Mkets.Ventura County• L z •n: " o Becerra,Simi Valley•Carl Morehouse,San - :naventura•Toni Young,Port Hueneme mge County Transportation Authority. Lou rea,County of orange emide County Transportation Commission: tin Lowe,Hemet �' rtura County Transportation Commission r COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH f SCAG NO. 1 20050200 PROJECT DESCRIPTION The proposed Project considers the development and implementation of a 50 million gallon per day seawater {, desalination facility within the City of Huntington Beach. The proposed Project is located on an 11 acre site b at the AES Huntington Beach Generating Facility located at 21730 Newland Street_ CONSISTENCY WITH REGIONAL COMPREHENSIVE PLAN AND GUIDE POLICIES The Growth Management Chapter (GMC) of the Regional Comprehensive Plan and Guide contains a number of policies that are particularly applicable to the Poseidon Seawater Desalination Project. r Core Growth Management Policies 3.03 The timing, financing, and location of public facilities, utility systems, and transportation systems shall be used by SCA G to implement the region's growth policies. GMC POLICIES RELATED TO THE RCPG GOAL TO IMPROVE THE REGIONAL QUALITY OF LIFE 3.18 Encourage planned development in.locations least likely to cause adverse environmental impact. 3.20 Support the protection of vital resources such as wetlands, groundwater recharge areas, woodlands, production lands, and land containing unique and endangered plants and animals. 3.21 Encourage the implementation of measures aimed at the preservation and protection. of recorded and unrecorded cultural resources and archaeological sites. C 3.22 Discourage development, or encourage the use of special design requirements, in areas with steep slopes, high fire, flood, and seismic hazards. 3.23 Encourage mitigation measures that reduce noise in certain locations, measures aimed at preservation of biological and ecological resources, measures that would reduce exposure to seismic hazards, minimize earthquake damage, and to develop emergency response and recovery r plans AIR QUALITY CHAPTER CORE ACTIONS 5.11 Through the environmental document review process, ensure that plans at all levels of government (regional, air basin, county, subregional and local) consider air quality, land use, transportation and economic relationships to ensure consistency and minimize conflicts. OPEN SPACE CHAPTER ANCILLARY GOALS Resource Protection 9.08 Develop well-managed viable ecosystems or known habitats of rare, threatened and endangered species, including wetlands. WA►ER QUALITY CHAPTER RECOMA IENDA T IONS AND POLICY OPTIONS The Water Quality Chapter core recommendations and policy options relate to the two water quality goals: to restore and maintain the chemical, physical and biological integrity of the nation's water, and, to achieve C and maintain water quality objectives that are necessary to protect all beneficial uses of all waters. 11.07 Encourage water reclamation throughout the region where it is cost-effective, feasible, and appropriate to reduce reliance on imported water and wastewater discharges. Current administrative impediments to increased use of wastewater should be addressed. GROWTH VISIONING/COMPASS The fundamental goal of the Growth Visioning effort is to make the SCAG region a better place to live, work and play for all residents regardless of race, ethnicity or income class. Thus, decisions regarding growth, transportation, land use, and economic development should be made to promote and sustain for future generations the region's mobility, livability and prosperity. The following "Regional Growth Principles" are proposed to provide a framework for local and regional decision making that improves the quality of life for all SCAG residents. Each applicable principle below is followed by a specific set of strategies intended to achieve this goal. Principle 3: Enable prosperity for all people - Provide, in each community,a variety of housing types to meet the housing needs of all income levels. Support educational opportunities that promote balanced growth. Ensure environmental justice regardless of race, ethnicity or income class. Support local and state fiscal policies that encourage balanced growth Encourage civic engagement Principle 4: Promote sustainability for future generations . Preserve rural, agricultural, recreational and environmentally sensitive areas. i Focus development in urban centers and existing cities. Develop strategies to accommodate growth that uses resources efficiently, eliminate pollution and significantly reduce waste. utilize"green"development techniques. r r-' SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS Roles and Authorities THE SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS (SCAG) is a Joint Powers Agency established under California Government Code Section 6502 et seq. Under federal and state law, SCAG is designated as a Council of Governments (COG), a Regional Transportation Planning Agency (RTPA), and a Metropolitan Planning Organization (MPO). SCAG's mandated roles and responsibilities include the following: SCAG is designated by the federal government as the Region's Metropolitan Planning Organization and mandated to maintain a continuing, cooperative, and comprehensive transportation planning .process Y resulting in a Regional Transportation Plan and a Regional Transportation Improvement Program pursuant to 23 U.S.C. '134, 49 U.S.C. '5301 et seq., 23 C.F.R. '450, and 49 C.F.R. '613. SCAG is also the designated Regional Transportation Planning Agency, and as such is responsible for both preparation of the Regional Transportation Plan (RTP) and Regional Transportation Improvement Program (RTIP) under California Government Code Section 65080 and 65082 respectively. r SCAG is responsible for developing the demographic projections and the integrated land use, housing, employment, and transportation programs, measures, and strategies portions of the South Coast Air Quality Management-Plan, pursuant to California Health and Safety Code Section 40460(b)-(c). SCAG is r' also designated under 42 U.S.C. '7504(a)as a Co-Lead Agency for air quality planning for the Central Coast and Southeast Desert Air Basin District SCAG is responsible under the Federal Clean Air Act for determining Conformity of Projects, Plans and Programs to the State Implementation Plan, pursuant to 42 U.S.C. '7506. Pursuant to California Government Code Section 65089.2, SCAG is responsible for reviewing all Congestion Management,Plans(CMPs) for consistency with regional transportation plans required by Section 65080 of the Government Code. SCAG must also evaluate the consistency and compatibility of such programs within the region. SCAG is the authorized regional agency for Inter-Governmental Review of Programs proposed for federal financial assistance and direct development activities, pursuant to Presidential Executive Order 12,372 (replacing A-95 Review). SCAG reviews, pursuant to Public Resources C-ode Sections 21083 and 21087, Environmental impacts Reports of projects of regional significance for consistency with regional plans [California Environmental Quality Act Guidelines Sections 15206 and 15125(b)]. Pursuant to 33 U.S.C. '1288(a)(2) (Section 208-of the Federal Water Pollution Control Act), SCAG is the authorized Areawide Waste Treatment Management Planning Agency. SCAG is responsible for preparation of the Regional Housing Needs Assessment, pursuant to California Government Code Section 65584(a). SCAG is responsible (with the Association of Bay Area Governments, the Sacramento Area Council of Governments, and the Association of Monterey Bay Area Governments) for preparing the Southern f- California Hazardous Waste Management Plan pursuant to California Health and Safety Code Section 25135.3. Revised July 2001 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS 1 9 Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response nse No. 8 e Southern California Association of Governments Brian Wallace, Associate Regional Planner Intergovernmental Review 8a. Consistency with the applicable policies of the Regional Comprehensive Plan and Guide is analyzed in Section 5.1 (LAND USE AND RELEVANT PLANNING). Refer to that section for further discussion. 8b. This paragraph briefly summarizes the project description and does not require a response. 8c. Project consistency with these policies of the Regional Comprehensive Plan and Guide are analyzed in Section 5.1 (LAND USE AND RELEVANT PLANNING). Note that policies not already included within the DREIR have been incorporated as part of Section 3.0 of the Responses to Comments, ERRATA. 8d. These paragraphs summarize the statutory responsibilities of SCAG. No response is required. �1 City of Huntington Beach August 17, 2005 119 x r LOCAL COMMENT LETTERS COMMENT 9 CM OF COSTA ES CALIFORNIA 9267.8_1200 P.O.BOX 1200 PUBLIC SEP.VICES DEPARTMENT May 26;2005 Ms_Ri&,,y Ramos. City of Huntington Beach Planning Degariinent_ 2000 Main Strect HuMington Beach, CA.°264$. SUBJECT: DRAFT.E VTR®NMENI^AL.IMPACT.F EPOR7C NO.00-01FORTHE SEAWATER DESALINATION PROJECT IN HUNTINGTON BEACH Dear Mr.Ramos: i'Iiank'you fer meeting with of Costa Mesa staff on Kay 2s, 20$5; to discuss the subject Draft.EnvironmentalImpatitRegort.(EIg).__Based.on.oimdiscussion&.anda review-of.the_Ih:ft ER, the City of Costa Mesa has developed the attached comments and conditions. l a If.you have any-.question please_contact.P.eter..Naghavi,Transpoa*tafLan.Services_Mfz g=,at 1 714-754-5182.Sincere ly,y, William J.Jr-Lis Director of Nb.lire'Servicm Attachment c Peter.Naghavi,Transp ad SezvwcesManag _ Ernesto Munoz,City Engineer Mike Robinson,-Assistant i�t�ypmPnt �rNi� Kimbcrly Brandt,Principal Planner Raja Scthts:amart,AssociateEngjr.je c_ Doug Lofstrom, Orange County Fairgrounds 77 FAIR MvE PHONE; (714)754-5343 • FAX (714)75A-5028 • TOO: (714)7.54-524a - \WW, . ;.costa-mesa.ca.L's -- - r COMMENTS ON THE-SEAWATER DESALINATION PROJECT DR.,F'RECIRCULkTED ENVIRONMIENT_A-L IMPACT REPORT Page 3-2: The DEIR states"Although ple�ise.pipelizw.aligDmeuts-alay.he.modified.duriag.f�1. engineering analysis, the conceptual pipeline alignments are shown in Exhibit 3-3........ The Ciiy of Costa Mesaconside -the pipeline -to be rtegral-pa.-t cf the project. As-such, the f�a�, r alignrnents should not sign.cantly deviate from proposed project alig=cnts, The proposed ' b modifications suggested to pipeline alignment-by the Ca-sta-Ivleres-Engineering-DTvisron-skould, fho.current DEIiR. )exhibit 3-3:.The-plan-ahould-clearly.identify.theloca*sons wherc the pipeline is within City.right- of-way and where the pipeline aliments are .<ot within the City's right-of-way. The project C r description.depicts.the.alig=ent traversing-through-the-0-rang e_CountY.Fairgrounds,.Fairview Developmental.Center, and the Costa Mesa Country Club. r Page 3-38: Primary Alignment: The DEIR discusses.alid-unent_along.Adams..A-vmve_and_-then_xQ.Plaaentia..Avmue.to..Co= Mesa Country Club. Adams Avenue is,a Major Arterial and carries significant amount of traffic throughout the day. In addition,.there.are residential..areas adjacent to Adams Avenue.as.well as Placentia Avenue in the proposed alignment area. Therefore, the construction impacts resulting from.the.proposed project_.are..significant-and .should- .be ..ad.dreasrA_as_.part.of..the.DEIR, Trenching in the roadway may result in closure of two lanes of tra£tic during the day, which r would not be allowed.by the.City.of.Costa.Mesa.. Thc.impacts of_constzuction.at night.such--as noise should be evaluated and addressed in the DEIR. Prior.to reaching Costa Mesa Country.Club,_the.pipeline-crosses-Fairview Park...Approval&frcim Costa Mesa City Council and Parks &Recreation Commission will be required prior to working e within.the- Fairview Bark, as.-well as-witlin-the.Costa-Mesa-Country-C-10-.- Approval-€rem operators of Costa Mesa Country Club should be obtained prior to construction within Costa' Mesa Country Club:- The DEIR states.that"pipeline would.then.gracecd_along_the_easterubaundary of.F-airuiew-Stag r Hospital." The area shown in. Exhibit 3-3 has been sold by Fairvicw State Hospital to private developers for a housir prqject-City--requires-the project-appliE-ara-ter*ovide doeunientatimrcf- f. approval from Fairview Developmental Center of the proposed pipeline within their property. The impacts-of moving-the-alignment-to-Eity'sri&t of w sy atmg-ffarhor Soiilevard-wi tf result: in significant impacts-thaLwcr-nnt_evaluated in-thc-DF-IR- r- The DEIR then states that the pipeline would be routed along Fair Drive on the northern side. Plcase.refer_to,comments beluu�r. -iltis align t.: :The City-prefers-an-L4gnmerk-in-the-center� median of Fair Drive. The impacts of this construction should be analyzed in detail. The existing and proposed-utilities-umdeer-Fair Drive7s}touid be considere&h Treuching in the roadway may result in closure of two lanes of traffic during the day, which would not be all Jowedby the 1 9 City of-Costa-Mesa. Fair Drive has only two lsacs in 'eacli 'direetion. The impacts of 1 construction at night such as noise should be evaluated and addressed in the DEIR, as there are residential areas adjacent to Fair Drive'in the proposed alignment area. r iI r i i t The DEIR.further states that the pipeline may be routed through the Orange County Fairgrounds. However, based on discussions- with--Orange--County- Fai:F ounda staff, there--have-be=-n-Q- approvals for the project. City will require approval from Orange County Fairgrounds of the project prior to the .firialization-of-the-ahgnmcnt-piarr-- "Fite-hnpacts-of-MON-irtg-the-aY�� t� TT T -7 , . .� . . 4''at.,.s.e not —,--Iuatcd iri the DE?�. fair 1Jrivc will result in siv-kILI cAL--lA.&Cc$ ",. .•.-. Proposed Modifications to Pipeline!alignment • Primary Route,Reach 4 1. In lieu uf-using-AdamsA-venuuan ?-Iac=tia_A-venuc,-thcho-ontal.alignment of the proposed pipeline should utilize the Santa An.a River right-of-way from Adams Avenue-to the-City-of.Costa.esa-prnperty.sauthofSwanDri-ve,.and proceed east along the northerly edge of the park. This alignment will result in minimum disruption of.thc.City roadways.. 2. The pipeline shall be designed with consideration of the future improvements withnxt-Faizvit--w-Parkratthn_end_of ana,vDj:lve- 3. The Parks and Recreation Commission and Costa Mesa City Council shall approve all work within Tairview Park,_ 4. Any work impacting the Golf Course parking lot shall require that the parking lot be resurfaced and be-coordinated with-operators-of GQIf C.al)rse,, o Primary Route,Reach 5 1. City concurs.with the trtnchlcss-.crossing atHarhor-- Q—ulcv rd_-The replacement roadway section for Fair Drive shall be Cement Treated Base, and the trench shall. be located-in-the renter-of thr-street. _ 2. The City of Costa Mesa reserves the south side of Fair Drive for a future storm drain..The proposed_.pipeline-alignment should oecunwithintIm Orange-County- Fairgrounds between Fairview Road and Newport Boulevard. For all Routes 1. The City.of Costa Mesa reserves.the_ ±o.-appravehorhthealigranent-axed location(vertical, and horizontal control)within the City of Costa Mesa baundaries-taall-ow.for,9m ftrtu£e rc nstrLe-tierro-f C:itrston rdrairtfacilities -nd-. utility systems. 2. The work for.this prajec sha be cad -. g.-erects by-the-City-e, Costa Mesa. The projects include,but are not.limited to the rehabilitation of Faun I3rive fFarn-Harbor-l�ouleuard-t4Fstit�i�-l�e�},-fi�*rt�u:�e::ue he2vver:i' NV Fairview Road and Newport Boulevard, and Harbor Boulevard between Wilson Street and-Newport•-BDulevard:- 3: The pipeline-alignm=tsi. .T helocated only.onartcHaLstmets.as shown on city_'s � Master_P!,---of Attetial is ways. r Page 3-29:Alternative Alignment: City is riot able to-con a tt cL--2It-e—m-ative-2-1 ant-as.deaiied-analysis-is_not provided-on-this r option. If this becomes the preferred aligzzm.ent, the City requests a recirculation of the DEIR. Since;Victoria-Str -_t bas-orr1y-V"-lanes-m-each direetiim;tie-City-e-fCesm Mesa-is--opposed--to' J any consideration of this alignment as the impacts of the construction are anticipated to be sf�iilCant. Page 59-24,TR.AFF.IC_ There.is-na-discussion.ofimparts.to--City.of-Costa-Mess Artyand•zteighboThoods,.whsre_a majority of impacts would occur due to the project. The discussion is very general and brief with no.estimates-for-trucl_tapa oz•_dctails_of con=ctiom methods.or q-uantL&atiQn.of impacts-Truck trips, construction workers and equipment resulting from the pipeline construction would impact City.of Costa Mesa-arterials-significantly.and.shmdd-he_.dncnmentec .in._the_DEIR. A -Tmffw Management Plan within City of Costa Mesa should be submitted for approval. by City's Tr=sportation,Seezvicec Manager. -Page 5.9-33,TRAFFIC r EC1N-�31: I' Bullet; "Limit construction--to-one.side-af the--road.:." cF€ates$fit iz�zpa�t to Cix�. streets. The arterials considered for placement of pipeline in City of Costa Mesa are Adams Avcnzic, P}accntia Avemre,Harbor BvTrlevsrcl arldFairDrive TheseTv$dways ire of D��. importance to the City and cannot be subject to closure,especially'during the day_ 3"z BuI1et: Identify locations in City ofCosta Mesa.where there may be closure of bicycle Panes or sidewalks. ' 4`" Bullet: Submit a truck routing plan to City of Costa Mesa,for approval for any construction within Costa Mesa. T 5 h Bullet: a Services Manager for any partial or full closure of streets within the City limits. e Bullet--City requires-subznittat of Fraffzc,Marragement Plan at 9ffpercent design phase. 7'h Bullet: The project shall coordinate with all other construction activities in the City and not just"to the extent feasz`b1e" CON-32: For.all work.in ihe__C.ty-oLCosta_JAesa,,_dm proj=t_app ioa shall-receive appr-eva from Costa Mesa Public Services Department. r CON-33: Saline-comment as-fir-CON-.3-2.- - r 'CON-34: Any nighttime construction activities in City of Costa Mesa shall -receive approval from Public Services Directon- CON-36: The applicant--shall c-oor.-dinate- all-construction_.traffic_related activities-with.Costa Mesa's Public Services Department. The construction vehicle routing plan in the City of Costa _ Mesa shall lie-sub=z tted--fur-approval lsy-tl�City--of Cast-a-Mesa7-Transp art atian---S`e xii es Manages_ EXECUTIVE SUMMARY: Executive Su-rmaL3f.shaulcibe,reviied.tQ.reflectresponses to above comments. Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS 1 9 Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS r Response No. 9 City of Costa Mesa Public Services Department William J. Morris, Director of Public Services 9a. This text provides an introduction to the comment letter and does not require a P q response. 9b. The desalinated water pipeline alignments presented in the DREIR were -developed as a result of extensive preliminary engineering and feasibility analysis. These pipeline alignments are technically and environmentally feasible and are not expected to deviate substantially during final design, unless such a change is made necessary by an agency with permit authority over the project. 9c. A revised conceptual pipeline alignment map (Exhibit 3-3 of the DREIR) has been provided within Section 3.0, ERRATA, of the Responses to Comments. 9d. Construction of a 48-inch diameter pipeline will require one to two lanes to be closed during construction. The extent of these lane closures could be minimized through the contract documents to prevent a significant stretch of the road from being reduced by two lanes (500-feet minimum). In addition, hours of construction may be limited to exclude rush hour periods. Finally, lanes may also be re-striped to balance the number of lanes in each direction, effectively resulting in the loss of one lane in each direction. All pipeline design and construction within the City of Costa Mesa will be reviewed and approved by the City of Costa Mesa. No night time construction is anticipated at this time. 9e. Comment noted. No response is necessary. 9f. The project applicant would obtain approval from the Fairview Developmental- Center prior to construction on their property. Any construction occurring along Harbor Boulevard would require approval from the City of Costa Mesa and would include such measures as the exclusion of construction during rush hour periods, preparation of a Traffic Management Plan (TMP), and roadway re-striping, among others, as determined through a TMP review by the City. 9g. The construction of the product water pipeline in the median of Fair Drive may allow the closure of only one lane of traffic. This would ease the flow restrictions. Once the pipeline is laid, the median would be replaced to existing conditions. All pipeline design and construction within the City of Costa Mesa would be subject to the review and approval by the City of Costa Mesa. Also refer to Response 9d, above. 9h. Comment noted. Refer to Responses 13c through 13m, below. 9i. This change has been incorporated into Section 3.0 of the Responses to Comments, ERRATA. City of Huntington Beach August 17, 2005 125 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS r 9j. As stated above, implementation of any pipeline segment within the City of Costa Mesa would require approval prior to construction. The construction process r would be subject to such measures as the exclusion of construction during rush hour periods, preparation of a Traffic Management Plan, and roadway re-striping, among others. The project applicant would consult with the City of Costa Mesa during final design to ensure that adverse impacts are minimized to the maximum extent practicable. 9k. Extensive analysis of impacts to sensitive receptors is provided within the DREIR in Section 5.9, CONSTRUCTION RELATED IMPACTS in regards to air quality, noise, and traffic. Mitigation to minimize impacts to less than significant levels r (including the preparation of a Traffic Management Plan) is provided within the section. 91. The measures provided within the comment would all be required as part of the permit approval process through the City of Costa Mesa (such as a truck routing plan, automobile/bicycle detour plan, Traffic Management Plan, coordination with other construction activities, and coordination with/approval from the City Public Services Department). The project applicant would consult with the City of Costa Mesa during 90% plan stage to ensure that adverse impacts are minimized to the maximum extent practicable. This change has been incorporated into Section 3.0 of the Responses to Comments, ERRATA. r r City of Huntington Beach August 17, 2005 126 r COMMENT 10 J CITY OF HUNTINGTON !BEACH ENVIRONMENTAL BOARD May 12, 2005 Mr. Ricky Ramos Planning Department City of Huntington Beach P.O. Box 190 Huntington Beach, CA 92648 Subject: Poseidon Seawater Desalination Project at Huntington Beach—Draft Recirculated Environmental Impact Report No. 00-02 Dear Mr. Ramos: The Environmental Board of the City of Huntington Beach is pleased to submit comments and recommendations regarding the subject Draft Recirculated Environmental Impact Report ("DREIR"). After reviewing the DREIR and discussing it at our May 5, 2005 meeting, the Environmental Board elected to submit comments and recommendations reflecting the issues discussed below. I. Process Waste Water: The DREIR indicates the project will generate upwards of a 500,000 gallons of"second rinse"wastewater that will be discharged to the Orange County Sanitation District("OCSD")facilities for treatment. However,presently the OCSD is.accepting diverted dry weather surface runoff for treatment thereby avoiding direct discharge of this water into the ocean and adding to the bacteria problems that have been experienced at the beaches along Pacific Coast Highway in Huntington Beach. Although the OCSD has current capacity to accept and treat this water, they have indicated that current diversion quantities may be limited in the future due to treatment capacity limitations. We are concerned,that the large quantities of project wastewater may result in curtailment of present dry weather diversion quantities due to treatment limitations. We believe that the DREIR should address this issue and provide information describing how the discharge of Project wastewater could impact treatment of dry weather diversion quantities. Since the Project will provide limited direct benefit to the City of Huntington Beach, while adding to the intensity of industrial related consequences, we believe that the Page i of 5 0 r- 5/12/2005 City should negotiate some additional benefits. Of particular interest to Environmental Board members would be some guarantee that OCSD will continue to accept all dry weather diversions at their current levels. Since future costs may be a imposed to insure treatment capacity at OCSD, the Project could provide the financial resources thereby relieving the residents of Huntington Beach from that liability. - I Reeyclin�of Construction ehris: There is no mention of how construction debris f will be handled as a result of decommissioning of the existing tanks and other b materials that will be removed to allow construction of the new facilities. We believe r that it is appropriate to include a discussion of how construction debris will be recycled to avoid landfill disposal. 3. Public Perception: Although DREIR information suggests that there is a low public perception for the Project within the City of Huntington Beach, we believe that there is C a high degree of interest in this project particularly in regard to the potential for environmental damage. We recommend revising thus statement in the report. 4. Unavoidable Environmental Impacts: Although the Project includes measures to ,> minimize environmental damage, there is no discussion of what mitigation offsets would be included due to long term environmental impacts. The DREIR should include a discussion of how these potential long-term impacts will be monitored so d that they can be quantified and what mitigations offsets would be provided. We believe the Project should include long-term monitoring of marine impacts and that all adverse impacts should be mitigated. 5. Reozonal Water Supplies: Table 34 "Projected Orange County Water Demand Through 2020", includes a summary of projected water demands, thereby providing f justification for construction of the proposed facilities. Other sources of information . regarding future water demands seem to conflict with the information provided in this Table. We recommend that the following additional information be addressed in the r DREIR: • The Table excludes agricultural water demands that we believe should be included to allow a proper understanding of total water demands.:.Although projected population increases will cause as increase in water demand, reduction e of agricultural acreage that will be consumed for new housing, commercial, and industrial facilities will result in a decrease in water demand. Therefore, in order to understand the combined impacts, a total water demand summary should be provided. u 0 Based upon information from other sources, it would appear that the estimates for reduced water demand resulting from conservation may be understated. Please provide some basis for how conservation estimates were prepared. r • Please clarify whether or not past projections are actual quantities or prior year projections that have been carved over. - r- Provide clarification as to what degree the current OCSD Water Reclamation Project will affect the overall County water balance. r Page 2 of 5 5/12/2005 0 Finally, there was a substantial reduction in demand between 1990 and 1995 that should be explained to better understand what factors might reduce water demands. 6. First Rinse Dater: The report states that the first rinse water from the filter cleaning process will be discharged to the OCSD for treatment. Although the quantity of water would be small, this water will have a high salt content that has the potential for damage to the bacteria treatment stage at OCSD. We believe that the report should include a discussion of how this water could impact the OCSD treatment facilities. In f addition, the report continues to state that should the first rinse not be sent to OCSD for treatment,it can be flushed into the ocean where; with dilution, it would meet most water quality standards. Further clarification is necessary to explain what conditions ' would necessitate flushing directly to the ocean and also to describe which water quality standards might not be met, to what degree, and how often this might occur. 7. First Rinse Diluent Water: The report states that no City water will be used to dilute. the first rinse that will be subsequently sent to OCSD for treatment. We request some g clarification regarding the source of water that is to be used for dilution. S. Electrical Power Demands: The Project will require significant electrical power. Recently,there has been a significant discussion in the news regarding the limited 1 capacity of California's electrical system and likelihood that brownouts will become h regular occurrences. The report should include a discussion of how the electrical system will be able to provide the Project power requirements while not increasing the likelihood of brownouts. Further, we believe that the Project should be premised upon an interruptible power supply during high State,demand periods. 9. Plant Operation: The Report states that the plant will primarily run at night to take advantage of off peak electrical rates in one section,but in another it states that the plant will run twenty four hours per day. Please clarify. 10. Water Line Corrosion: We believe there should be some discussion of the corrosion j potential to the new pipeline proposed for transfer of water to OCSD as well as the - existing pipelines that will contact the water through the treatment process. 11. Water Discharze to Ocean: It was unclear whether or not the water being discharged to the ocean would meet all discharge requirements. Please clarify that water k discharged into the ocean will meet all applicable water quality requirements and if not, a discussion of proposed offset mitigations should be included. 12.Facilities Post AES Discontinued Operation: Although the report includes a discussion of how the ocean inlet and outlet piping would be made available, operated, and maintained,in the event that AES discontinues operation, we request that more ' information be included regarding how the existing AES pumps would be retained and be available-for this project during any period whereby the AES facilities may be demolished. Page 3 of 5 r r 5/12/2005 13.Proposed Water Pipeline: Although the Proj ect includes a proposed pipeline configuration as well as an alternative routing, there is no discussion as to why each routing is so long. Certainly the construction impacts of either pipeline routing would m be significant on the impacted communities. Please provide a discussion justifying the proposed connection points, instead of a connection point closer to the Plant. r'- 14. Elevated Iron Levels: The report states that the elevated level of iron in the discharge water will be beneficial to plankton. We believe there should also be.a discussion of the potential impacts of iron on the occurrence of red tides in the area that are n presently common. Also;in a different discussion it is mentioned that planl�fton will be affected by the higher salinity. We believe that if there are any negative impacts to the plankton, the discharge should not be considered a nutrient. 15.Recreational Fishing: The report states that pelagic species currently inhabiting the area (feeding at the outlet pipe discharge)will simply avoid the area due to the higher salinity thereby avoiding harm. While this is avoidance of harm to fish is good, the O fish will be displaced resulting in an areas along the beach with fewer fish. This will result in a significant reduction of shoreline recreational fishing in the area. Although commercial fishing may not be impacted, the report should discuss impacts to shoreline recreational fishing. 16.Replacement of State Water Project Water: The report indicates that proposed California desalination projects have the potential to replace water imported through the State Water Project. As indicated, this option would result in a small net increase in electrical power consumption when compared to the power requirements of the State Water Project. However, it is very unlikely that this option could be beneficial p I to the Municipal.Water District of Orange County due to the significantly higher water - costs for desalination water versus water from the State Water Project. We believe report language should be revised to include a discussion of what circumstances would - justify replacement of State Water Project water with desalination water and how likely those circumstances would arise.' f-- 17.Desalination Plant Size Scale-up: .It should be noted that although there are many proposed desalination plants, extended operation experience of large facilities, similar to the proposed Project,is very limited. If the Project proceeds, it would be q F appropriate to require quarterly status reports to the City of Huntington Beach regarding the latest operating experience.of the larger plant operations. 4 r- 18. Private Ownership: The Project as currently proposed would be privately owned. We are unfamiliar with the potential risks of private ownership of water supplies and whether or not this course of action would be best for the public. However,we also r recognize that should this project suffer technical problems that substantially increase financial liabilities,those liabilities would fall on private resources and not the general public. r Page 4 of 5 5/12/2005 The Environmental Board appreciates the opportunity to comment on this project and is available to discuss these comments if appropriate. Please contact me with any questions or $ comments you may have. Yours truly, wv k A.T. Hendricker, Chairman ENVIRONMENTAL BOARD cc: City Council Members and Liaisons to the Environmental Board Dave Sullivan Keith Bohr Paage 5 of 5 r Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 10 City of Huntington Beach Environmental Board - A.T. Hendricker, Chairman r•- 10a. Comment noted. Also refer to Response 17k below. 10b. As stated in Mitigation Measures PSU-6 and PSU-7, appropriate measures will be taken to ensure that the project is in compliance with the City's waste r reduction and recycling program. In addition, a waste reduction plan for construction and demolition waste will be required prior to the issuance of a grading permit to ensure that the requirements of AB 939 are met. r 10c. Table 7-3 of the DREIR, ALTERNATIVE SITE COMPARISON, does not show public perception for the project as low. Rather, it is listed as "moderate". This r conclusion is provided in comparison to the other alternatives listed in the tables with many factors taken into consideration, such as land use compatibility, aesthetics, and biological impacts, among others. 10d. The only unavoidable significant impact identified in the DREIR for the proposed project is for construction-related air emissions. Although mitigation is provided to substantially reduce this impact, there are no mitigation measures available that can reduce this impact to a less than significant level. In regards to marine biological resources, impacts were found to be less than significant. Therefore, mitigation in the form of long-term monitoring is not provided in the DREIR. r However, additional mitigation requirements may be applicable to the project as part of the regulatory permitting process (e.g. NPDES or CDP permits). 10e. The information provided within Table 3-4, PROJECTED ORANGE COUNTY WATER DEMAND THROUGH 2O20 of the DREIR was taken directly from the Municipal Water District of Orange County's (MWDOC) 2000 Urban Water Management Plan (UWMP). The 2000 UWMP provides local water planning information for Orange County, utilizing a 20-year planning horizon. The table i provides historical (based on actual quantities) data and projections through 2020 based on previous trends and Water Use Efficiency (WUE) measures. 1Of. As indicated in Table 5.10-8 of the DREIR the volume of the first rinse is 4,000 gallons per membrane unit and the concentration of this process water under worst-case scenario will have salinity equal to that of seawater, i.e. 33,500 mg/L. As shown on page C-37, Appendix C, of the DREIR the discharge of the OCSD wastewater flow is up to 480 MGD. The wastewater will be fresh — i.e. wastewater plant influent TDS will be 500 mg/L or less. When a 4,000 gallons of desalination plant discharge of 33,500 mg/I of salinity are blended with 480 million gallons a day of 500 mg/L salinity, the salinity of the blended wastewater will be = (0.004 MGD x 33,500 mg/L + 480 MGD x 500 mg/L) 1480.004 MGD = 500.28 mg/L. Increase of OCSD influent TDS from 500 mg/L to 500.28 mg/L will have no measurable effect on the wastewater treatment plant operations and will not damage bacteria treatment stage. r City of Huntington Beach August 17, 2005 132 Beach RESPONSES TO COMMENTS Seawater Desalination Project at Huntington eac RESPO S Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Experience at the 30 MGD City of Los Angeles Terminal Island Treatment plant, located in the industrial port area, which takes seawater from ship washing operations of fish canneries, indicates that the biological wastewater treatment process is not affected until the wastewater influent salinity concentration reaches 3,000 mg1L. The increment caused by the desalination facility operations is negligible as compared to that level. Discharge to the ocean after treatment in the washwater tank and blending with desalination concentrate and HBGS seawater discharge is proposed as an alternative to the discharge of the "first flush" to the sanitary sewer. This alternative was introduced because discharging this cleaning solution after blending with desalination concentrate is widely practiced worldwide and is the most common approach for disposal of this process water in existing seawater desalination plants. A detailed laboratory analysis of the membrane process water is provided in Attachment K of the DREIR. Review of summary Table 15B indicates that after blending with the other discharge streams and dilution of 260:1, all parameters of the blend will be in compliance with the applicable water quality standards (California Ocean Plan) at the time the discharge enters the ocean. 10g. The small amount of water that will be used to dilute the first rinse that will be subsequently sent to OCSD for treatment will be desalinated water produced by the Huntington Beach desalination facility. 1Oh. The cumulative effect of the proposed project's electricity consumption is addressed in Section 6.0 of the DREIR, LONG-TERM IMPLICATIONS. On a regional scale, the project would result in a nominal increase in electrical demand in Orange County by approximately 0.8 percent, while that percentage would drop to 0.1 for the Southern California region. Moreover, the facility would operate the reverse osmosis system during off-peak periods to the maximum extent practicable. During emergency interruptions of electrical power, the desalination facility would utilize electricity from the HBGS auxiliary reserve bank or the state power grid, while off-site pump stations would be equipped with underground diesel-powered emergency generators. 10i. Refer to Response 2n, above. 10j. As stated on page 5.6-9 of the DREIR (PUBLIC SERVICES AND UTILITIES), the OCSD has indicated that the pH and flowrate of the potential discharge of waste cleaning solution would be acceptable. In addition, the project would require a Sewer Connection Permit from OCSD, and would be _subject to their requirements for operation (including a review for potential .corrosion impacts). For product water, per Mitigation Measure PW-5, a corrosion monitoring system would be installed at points of interconnection with existing water pipelines to ensure that corrosion impacts do not occur. Also refer to Appendix O, DISTRIBUTION SYSTEM CORROSION CONTROL STUDY, of the DREIR. 10k. The discharge from the proposed project, upon dilution with the HBGS cooling water effluent, would meet all applicable water quality requirements. Moreover, City of Huntington Beach August 17, 2005 133 r Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS the proposed desalination facility would be subject to all regulatory requirements, including National Pollutant Discharge Elimination System (NPDES)_regulations. 101. Refer to Response 1 g, above. 10m. The proposed pipeline routing(s) of the product water pipeline takes the shortest path to the desired connection point of the OC-44 transmission line. This connection point was chosen as it is the nearest location where the regional distribution system is sufficiently large enough in diameter (42 inches) to convey water into the regional transmission line. 1On. Comments about plankton and salinity deal with basic features of their drift through the discharge plume (Appendix C of the DREIR) and general features of their adaptation to changes in salinity (Appendix S of the DREIR). The concentration of iron in seawater is very low. However, it is an essential nutrient for phytoplankton (it is a necessary structural element in some enzymes and in the chlorophyll molecule, which is needed for photosynthesis). Other nutrients for phytoplankton (and for dinoflagellates, which is what the red tide organisms are) are required for growth. Two of the most important nutrients are nitrogen and phosphorus. These two elements are present in great supply in fertilizers used on lawns and farms and they thus enter coastal waters through storm drains and sewage outfalls. High concentrations of these nutrients have been linked to the formation of red tides, which often occur after periods of ocean mixing, termed upwelling, that bring nitrogen and phosphorus containing waters to the surface. While iron is also in fertilizers and thus in runoff water, it is far less soluble in seawater than either nitrogen or phosphorus and the chemical actions of seawater on iron keep it from increasing greatly in concentration. Specifically, iron is oxidized by seawater and forms an insoluble flocculent, which means that r it is put into a chemical form that makes it unavailable to phytoplankton. For this reason iron cannot accumulate to concentrations that would be toxic. However, in small quantities (usually parts per billion) iron is an important trace nutrient. However, once iron concentration reaches the level where it is oxidized, it is unavailable to biological processes and thus neither a nutrient nor a toxin. Thus, small amounts of iron can have a nutrient function but iron would never reach toxic concentrations or trigger red tides. Nitrogen and phosphorus are more r available in seawater than is iron and these are key elements contributing to the occurrence of red tides and other plankton blooms. 10o. As stated within DREIR Section 5.10, OCEAN WATER QUALITY AND MARINE BIOLOGICAL RESOURCES, under the "low flow" scenario, the discharge salinity at mid-point in the water column would decrease to 20 percent above background salinity within 20 feet of the outfall tower, 15 percent over background salinity at 100 feet, and 10 percent over background salinity at 1,200 feet. Note that a variation of 10 percent salinity can be tolerated by most fish species. Given the localized area of the plume that would have a salinity over 10 percent of the background, it is not expected that shoreline sport fishing would be adversely effected by the project. r City of Huntington Beach August 17, 2005 134 r Seawater Desalination Projecta Huntington t H ton Beach RESPONSES TO COMMENTS g Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS 10p. This comment requests that the DREIR "include a discussion of what circumstances would justify replacement of State Water Project water with desalinated water and how likely those circumstances would arise." That discussion is included at page 3-38 of the DREIR. Also refer to Response 1 h, 2i and 7r, above. 10q. The requirement for quarterly status reports is not currently included as a mitigation measure within the EIR, as such a requirement does not reduce the effects of any of the potential environmental impacts of the project. 1Or. Comment noted. No response is necessary. 10s. This paragraphs provides a conclusion to the comment letter and does not require a response. 1 City of Huntington Beach August 17, 2005 135 _ _ COMMENT 11 Pcist- vie �egea� Par„ To Cc. sad 3 rhona k � _ Fax n �L II�FAIVGH_ 7 ..Dt5i81Ct` ::.' Fax#/y 2iY � �t�� � --- :t1�'t,1J-k1�L01111 Vl tiL.?.! 1. 1V1Al2RlY,,l iaovu=Sena c,anyorz-,yve,r tlpxiuuu 1Ntne e,fi.y� y-�vuy fyayl4os-asvu May 27,2005 Ricky Ramos Associate Planner City of Huntington Beach 2000 Main.Street Huntington Beach,CA 92648 _ Subject: Recirculated Draft Environmental Impact Report(DEIR) Seawater Desalination Project-at HuntingfonSeach- . Dear Mr.Ramos: Irvine Ranch Water District(IRWD)has received and reviewed the subject DEIR and offers the comments that follow. IRVJD is a multi-service agency located in central Orange County that provides potable and nonpotable(including recycled)water supply,wastewater eolleetionj treatment,and-disposal, and urban runoff treatment services to a population of approximately 316,000 covering an area -of 132 square miles. The IRWD-gervice area includes a1ofthe-City+of Irvine and*portions of unincorporated.Orange County.and the Cities.of Lake.E.orest_Tnstin,Santa Ana,Costa-Mesa, Orange,and Newport Beach(see attached map of the IRWD service area). IRWD has two primary sources of potable water imported water supplied by the Metropolitan- Water District of Southern California(MMWD)-and-local'groundwaten. IRWD's primary sources ' of nonpotable water are recycled water provided by the Michelson Water Reclamation Plant (MWRP)and the Los Alisos Water Reclamation-Plant-(LAWk1-);-and-local-and imported-- a . untreated water. The proposed Seawater Desalination Project(Project)would affect IRWD's potable and nonpotable water customers,as well as those customers in other cities and districts who will receive Project water. While IRWD supports develepment-of-addi al-water-sources for southern California,maintenance of water quality and customer satisfaction are our highest priority. As proposed;-elements-of the Project have the patentiahu-negatively impact both of these priorities. Introduction and Overview Pursuant to Exhibit 3-19 of the DEIR,IRWD is expected to be the largest user of Project water, which will be conveyed through the existing regional Orange County water distribution system primarily to customers in-central and south Orange County. Consequently,IRWI)is very concerned about the potential environmental impacts of this water on IRVVD's facilities and' r Mr. Ricky Ramos City of Huntington Beach May 27,2005 r Page 2 customers. As described more fully below,these impacts are focused on the potential effect of the quality and comp atsbility of Project yvater on?RW DI 's potable and onpotable water syst=s a and.customers. Potable Water System Water Compatibility Issues r The blending of Project water with existing supplies will alter water quality in both regional conveyance facilities(e_g-,East Orange_County Feeder.bla,--2—mixing of Project-water and imported water) and in IRWD's local potable water distribution system(Project water,imported water,groundwater), and may cause problems related-to disinf�.ion-and co-rosion control. � Disinfection r- Effective initial disinfection and-maintenance of chlorine residuals in distribution systems is critical to ensure the safety of drinking water supplies from the standpoint of bacteriologicalipathogen water-gcrality.- Maintenasxce�f '. is complicated by-the--- proposal to introduce Project water into regional and local distribution systems. The EIR must include development of a monitoring plan that inch2des specific methods to adjust and control-- the molar ratio of chloi:i:ne_to.ammonta.wilhin arange acceprable_tQhfaMrthe-Municipal Water... C r District of Orange County(MWDOC),IRW'D and other appropriate governmental entities. This will ensure that chlorine levels are maintained and chat increased nitrification.... episodes or impacts on IRWD Total Colifoim Rule compliance. - r In addition,the Project's proposed use of sodium hypochlorite for disinfection will add to sodium levels in the ProJect-v dter(as LLescrrbedm ore falybdaw).-The D-Ea should-evaluate the impact of sodium hypochlorite use on sodium levels and should also evaluate alter.»lave r disinfection methods that would reduce or eliminate the impact on sodium levels'. Disinfection By Products(DBP) r The Project water will contribute an increased amount of bromide. Bromide is a DBP precursor, and its presence within1RWa'-s_distnbutionsy&tem_couldresult inAheformation ofadditional. amounts of brominated DBPs. Legislation is pending in the State of California mandating,that r the Office ofEnvironmen a1 Hralth'and Els ni7d Angessmeut(OEHHA�.establishP-ublicHealth. Goals(PHGs)for each individual tri-halomethane(THM)and five halo-acetic acid(HAA5) d DBPs by January 2007._OEHHA's_positionis.that-tlusaction ixcm-track.to-completethaTHM.._. PHGs by the January 2007 deadline and that establishing the HAA5 PHGs is achievable by the same date.-A shift toward-bmmixated DBl'sold-cause1 3 t$exs€vd t so-aew PNGs:- The DEIR must address these impacts and provide approprate mitigation measures. = r r - r r r_ Mr.Ricky Ramos City of Huntington.Beach May 27,2005 P age 3 Corrosion Control Based on the results of LRWD's Lead and Copper Monitoring Program,IRWD is not currently required to irrrpl went corrosion ron*.rol for the potable water syst-.., Alt hough though the DEIR indicates that Project water will be moderately-non-corrosive(target"corrosivity index,"(Sl)of 0.0 to 0.5),the substantially higher levels of proposed chloride may result in other corrosion problems. More specifically,a-previous study by the American Water.Worlm Association Research Foundation(AWWARF),in which IRWD participated,indicated that MWD water in IRWD's distribution-s-yst -had-the polerttil"eausirg"pitting"due to chloride levels: Although this potential was consider relatively low and did not warrant the use of corrosion inhibitors,the higherlevehz of chloride assouiated-with the in-;oduction-of Project water will e increase the corrosion potential and may require-the use of costly phosphate based corrosion inhibitors by IRW-D: The DEIR needs to analyze the specific impact.of the proposed Project on eonrosivity of IRWD's' potable water system,including-an analysis of corrosion.controLandckpwa#ional methods as- mitigation measures. Tests performed in other areas under different conditions would not provide adeqnate analysis-a€-IRF�B-speeif a eonditierssr In addition;-i€$RWI3 has to change--- operational methods due to these impacts and incur additional capital and O&M costs,the Project proponent must includ'a mitigation measures as a part-of the environmental impactreport- that clearly state IRWD will be reimbursed for these additional costs. Customer Acceptance and.Confidence_. IRWD is committed to itrproWng the appearance;taste and-qualk3f of potable water we serve-to our customers. The proposed Project has the potential to negatively impact these factors,thereby : altering customer perceptions-abmrt-thu-quality of the water s¢pply.- m ons can negatively-affect the community's view of IRWD and-res-ult in significant public relations issues. All new sources of potable water to-IRWD must beat least equal to or better than the quality of water we are currently.sen dng-our.custonu=s .IRWD.is-committed ta maintaining consumer confidence. Degradation or perception of degradation by our customers of appearance,taste,and quality of water as a result of the Project is not acceptable. The DEIR does not adequately analyze the impacts of the proposed Project,and in particular,the Project's anticipated elevation of levels of sodium,chloride,bromide and boron on the taste; odor,safety and appeara=of-existing.potable wateLsupplies_Nor-dom it-provide mitigation... . measures that address consumer concern and purveyor liability for product water quality. If future complaints receifiea4 ctrst�Irrers byIRWf3aredtertrxit #o- f�om Project = ' water,the Project proponent or owner must be responsible for corrective action- - � - - - r— r- Mr.Ricky Ramos City of Huntington Beach May 27, 2005 Page 4 Nonpotable Water Recycled Water Customer Concerns-Constraints on Water Reuse IRWD has an extensive recycled water.program that provides water.to-meet nearly.20%-of the District's overall demands. IRWD aggressively promotes the use of recycled water and produces -high quality water_that_rneets our.customers'-water_quality-needs..We-are concerned that_the. r-- Project water will significantly increase the sodium and chloride levels in IRWD wastewater that g -provides the basis-for tie-praduction of-reeyeled water,and the-potential-adverse-inpaets these levels would have on water quality in our recycled water system. Approximately 90%of IRWD's recycled water- sodiamrarrd-chlordu-could result in plant toxicity and soil permeability issues with these customers. More specifically-higher.levelsof sodium in recycled water reattlt;ngEmm introductionsof.. Project water into the IRWD potable water distribution system can cause issues with soil .permeability,plant nuts exeha ;and plant claFnags(lea b ng)when his water is recycles Pear=eability relates to the"sodium adsorption ratio"(SAR)of the water. The 'Sodium Adsorption Ratio='section-of a Tep<,Ltprepar-dbyivfc€`th-c-Parviromirental in 3anumuy- 2005 C Water Recycling Using Desalinated Seawater in the Source Water Supply-Implications . for the Irvine Ranch Water I3'rstdct Water Recycling Frogram')confirms that the higher sodium r levels in Project water vsainum -P SARualzie--,.-in-ELWD's-recycled-waten(Figures 10 and-.11)-- This is a concern since the predominately clay soils in the Irvine area are particularly sensitive to 'higher SARs. - r Another result of increased-SAR;-which-leads to lower soiYpermeahility;is an increase of surface runoff from irrigation and rainfall. This increased runoff carries additional pollutants to receiving waters,in turn increasing pollution-of surface waters and beaches. r It is IRWD's goal to maintain or enhance the quality of all water it serves to its customers,not allow it to be degraded: and possibly. boron in the Proj ect water may reduce the quality of IRWD's recycled water.These impacts may result in decreased recycled-water usage by our customers,putting a further burden upon potable water-supplies. This and the State ofCalifaniia_s.goalszuhich call... r for recycled water to be maximized for all approved uses. Inasmuch as Orange County agencies i have expended considerable- and many to,-devclop-extensive eeyeled-water�program;tla potential for Project water quality to impact regional water resources is significant. Reductions , in recycled water use would-necessitate thLrincreased use-of-imported-MWDrWatarar development of additional local supplies at substantial cost. In addition,inorganic carbon(bicarbonate)levels in IRWD's drinking water are likely to change r as.a result-of the Project�resultn&msemadary.imgacts on_the-MYM-Emlogwal Nitrogen Removal(BNR)process. More specifically,-lower bicarbonate levels in IRWD wastewater will i decrease pH and alkalinity,-and require additional pH control measures to augment the 13NR i Mr.Ricky Ramos City of Huntington Beach May 27,2005 Page 5 process. The lower levels of bicarbonate will tend to lower the alkalinity prior to chlorination resulting in the need for additional chew isa+t treat-ent to meet NPDES requirements at MWRP. To address the potential impacts described above,the DEIR must evaluate mitigation,including . a monitoring component and an adjustment and control methodology,overseen by.the i appropriate water supply agency. Sodium and Chloride Reclamation Permit Limits The Regional Water Quality Control Board(RWQCB)recently adopted revised water quality objectives for mineral limits for the ILvine basin that replace the.current sodium-and chloride Emits with an overall total dissolved solids(TDS)based limit. However,IRWD's current operating permit far.MWRP includes specific sodium nnd.chloride limits_.This permitix... expected to be renewed in 2006 and may include the revised basin mineral limits,however such : inclusion is speculation. 'Flee-permit renewal pr*ces-s-wU inchge a_review-44he,appropriateness- : of applying the new water quality objectives to MWRP,and will involve public input. Consequently,IRWD has its carerzt-perrmtsodimr and monde limits will'oc-- k changed. If they.ar-t nQtchangedelevated sodium and chlsdde levdss-associaeed with the... Project water would cause MWRP to exceed its permit limits,and necessitate that IRWD construct additional Capital-faCilifiestaremave+n Sodium anri rhlnridi-(rr._=eOSMOSIS.or Ion exchange along with brine disposal facilities)and incur higher O&M costs. The DEIR must include a mitigation measure whereby the Project proponent or owner will _. reimburse IR�D fcr t'aes�e-ad�i-floral costs;- Conclusion _. In conclusion,IRWD is very reeeptive to proposals to deg+Muy Baff,211ftfive water supplies,�. -including the proposed Project. However, conditions. 'must be placed on the Project to required product water from the Project-to'undergo a treatment process that-reduces the amount-of- ' sodium,chloride,bromideandbamn C'=u fons must alminrlude appropdate_increases-m calcium,magnesium and alkalinity(buffering)to better match current IRWD potable water supplies thereby.minimizinuZ the.impacts ideutifiedherein...Ia.order'to.reduce.risks associated with the Project,IRWD strongly recommends that the Project proponent add an additional level _ of treatment to the.culrentty nr med freanment-pracess.. Diligent efforts by the City and Project proponent to address the concerns outlined in this letter will be greatly-appreciated,M&ar-e in tmF-iew-neoersary for-the cempletia -ef as adequate.The Final EIR-willrequire a Mitigation and Monitoring Plan for addressing potential impacts. It is expected that inucli of d rrrmutari D_-w h-be�aud�d' public age re�-in additiarrto e M Project proponent Thus,multi-party operating agreements among the Project proponent,the monitoring agencies,and retail agencies receiving the Project product water will need to be executed before ariy_water.is received_hy-those retail a=ncif--s_.Itseems nldent to.negotiate those agreements prior to any detailed planning or design of the Project r Mr.Ricky Ramos City of Huntington Beach May 27,2005 Page 6 Over the last several years,water quality.requirements have become more stringent due to various technological, social, and enviroranental developments.- Itis-likelythatrequirements r will continue to change in the future. Thus,the Project and any attendant agreements must provide for adaptive management of those changes: IRWD is very willing to continue a dialogue with the Project proponent and City to discuss our concerns about this Project.We understand the.importance to our community of the success of n appropriate ocean desalination and are supportive of using alternative water supplies to r supplement our mdsting systems_ Howev.er,I RWD.has rnany-.concet-n.zrev-arding the Project as_ outlined herein and requires satisfactory resolution before we can support the Project. If you have any questions regarding our comments or need additional information,please feel free to contact me at(949)453-S860.- - Sinceretv r S Br P Environmental Quality Manager- . - r- Attachment—IRWD service area map cc:_Richard.Bell,MWI?OC-- . r r r District Location District Location • Service Area of 133 Square Miles is 20% of County kwp Service • Serve All or Portions of: _ = Area -.City of Irvine - City of Lake Forest ORANGE -City of Tustin _ -City of Newport Beach -City of Costa Mesa -City of Orange Unincorporated County s t ll County of v ruu IP Orange SANTA � � ,. ram, ANA to!« `. rs'' iJNlNOORPDRNNW ATEO COSTA MESAMmw OISIRIC'r �K - �yc�°`✓m,ro! _ _ r�� _,y.� ,.V�.`t.�`^��„„"a"�axw� '�pr«'��m _� k. s� j CPY Th_ - p `H'4Y ' V�Y.;?jt4oYun�T A� _ - - NEwPbRT t tnxca( _ Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS J 9 Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 11 Irvine Ranch Water District - Norris Brandt, P.E., Environmental Quality Manager 11 a. This text provides an introduction to the comment letter and does not require a response. 11 b. Water compatibility issues are addressed in Section 5.11, under ORANGE COUNTY WATER DISTRIBUTION SYSTEM. As indicated on page 5.11-17 of this section, the desalinated water quality will be compatible with other existing sources of potable water delivered in the distribution system. 11 c. The project proponent has committed to the development and implementation of a product water quality monitoring program. As indicated on page 5.11-20 of the DREIR, this project will include monitoring of product water quality, including concentration of disinfectant at the entrance point of the distribution system: "A monitoring program would be implemented for this location incorporating the following parameters: coliform bacteria, heterotrophic bacteria, chlorine residual, disinfection byproducts, and aesthetic parameters such as turbidity, odor and color, as well as corrosion indices. The purpose of this sampling point is to verify on a regular basis that no degradation of water quality has occurred during any period of storage at the facility site or in the transportation pipeline and that mixing of desalinated water with water from other sources continues to be compatible". Sppcific operational methods to adjust and control the molar ratio of chlorine and ammonia within a range acceptable to MWD, MODOC, IRWD and other users of the desalinated water will be developed during the detailed design of the project in coordination with all pertinent water agencies. Sodium hypochlorite is widely used for disinfection of potable water by most Orange County water agencies. Sodium hypochlorite will be added in a very small concentration, only 2 to 4 mg/L. Therefore, the amount of sodium added because of the disinfection process will be 30 times lower than that in the product water - i.e., 4 mg/L vs. 120 mg/L. The maximum increment in sodium concentration of the product water due to use of sodium hypochlorite for disinfection will be only 3.3% (124 mg/L- 120 mg/L 1120 mg/L - 3.3%). 11 d. Under the current regulations there are no limits for the individual compounds that contribute to the drinking water TTHM and HHA5 concentrations. If the State of California Office of Health and Hazard Assessment (OEHHA) establishes actual Public Health Goals (PHGs) for each individual THM and HAA5 DPB, and if under these future regulations the project actually may cause the IRWD to exceed these PHGs, then the desalination facility treatment will be upgraded to ' meet these regulations. The DREIR is not required to provide a speculative assessment of future regulations. Also refer to Response 7c, above. 1le. As indicated on page 5.11-17 of the DREIR, "similar to all other potable water sources in the distribution system, product water from the Seawater Desalination Project at Huntington Beach will be chemically conditioned at the treatment facility prior to delivery to the distribution system to mitigate its corrosivity". City of Huntington Beach August 17, 2005 143 r Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS r-- The corrosion effect of chloride levels on the distribution system will be further investigated by completing operational studies during the implementation phase of this project. If those studies indicate the need to control chloride related corrosion then operation measures such as addition of corrosion inhibitors other than lime (i.e., phosphate based corrosion inhibitors), and/or reduction of chloride levels in the desalinated water will be implemented. The specific arrangements to address these operational issues will be addressed in accordance with Mitigation Measure PW-9. 11f. Appearance, taste and quality of the desalinated water are described in Section 5.11 of the DREIR. No specific evidence is offered by the commentator leading r to the conclusion that "the proposed Project has the potential to negatively impact these factors thereby altering customer perceptions about the quality of water supply". Marina Coast Water District has been blending desalinated seawater with its other potable water sources for over five years, and their consumer reports, which are available on the internet, indicate that the use of desalinated water does not have negative impact on consumer acceptance and confidence. Page 5.11-20 of the DREIR presents other examples indicating positive public acceptance of desalinated water. 11g. As indicated in Section 5.11 of the DREIR, PRODUCT WATER QUALITY, the r desalinated water quality will meet or exceed all applicable drinking water regulations. These regulations are developed with the consideration that the drinking water will also be used for irrigation. There are no regulations limiting the use of drinking water for irrigation. Therefore, no significant environmental impacts are anticipated when using desalinated seawater. r As shown in Table 5.11-3 of the DREIR, the desalinated water will have a chloride level of 180 mg/L, which is significantly lower than that of the California DHS/Safe Drinking Water Act limit of 250 mg/L. The applicable regulations do not limit the level of sodium in the drinking water. The latest edition of the US EPA Guidelines for Water Reuse (EPA/625/R- 04/108) of September 2004, does not pose specific chloride limits for short or long term use of water for irrigation. These guidelines however, establish a "recommended TDS limit" of 500 to 2,000 mg/L. The guidelines state that "Below 500 mg/L, no detrimental effects are usually observed" (Table 2-7). The desalinated seawater will have TDS concentration of 300 mg/L, which is significantly below the recommended limit for irrigation. As indicated in the Guidelines for Water Reuse (section 2.3.2.2 Sodium), "the potential influence sodium may have is indicated by the sodium-adsorption-ratio (SAR)". SAR expresses the concentration of sodium in water relative to calcium and magnesium. According to the Guidelines a measurable irrigation effect of sodium is observed "when sodium exceeds calcium by more than 3:1 ratio. As indicated in Table 5.11-3 of the DREIR, the sodium and calcium (alkalinity) in the water is 120 mg/L and 50 mg/L, respectively. Therefore, the sodium to calcium ratio is 120 mg/L: 50 mg/L = 2.4, which is less than the threshold of 3:1. Since r City of Huntington Beach August 17, 2005 144 Seawater Desalination � Huntington n Project at Huntin ton Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS the actual sodium-to-calcium is below the limit established by US EPA, the desalinated water is expected not to have measurable effect on irrigation. If water quality adjustments are needed to accommodate specific needs of a water user, the SAR can be adjusted by either addition of lime to the desalinated water to increase the calcium content of the water, or by reducing the level -of sodium in the water. Desalinated water of lower levels of chloride and boron may be produced to address actual concerns of the IRWD customers of reclaimed water containing excessive levels of sodium, chloride or boron attributed to the use of desalinated seawater. These operational issues would be addressed in accordance with Mitigation Measure PW -9. 11 h. Refer to Response 11 g, above. 11 i. As stated in the DREIR, the project's product water quality will meet all applicable water quality regulations, including IRWD's reclaimed water quality permit 1 requirements for sodium, chloride and boron applicable at the time the desalination facility begins to supply water. The proponent's commitment to comply with IRWD's and other users water quality requirements associated with water reuse will be addressed in accordance with Mitigation Measure PW-9. 11j. As indicated in Section 5.11 of the DREIR, the pH of the desalinated water will match that of the other water sources and therefore will not have a measurable effect on MWRP wastewater influent. Lime (calcium hydroxide) will be added at the desalination facility to adjust the desalinated water pH and alkalinity as needed to meet the target levels needed to mitigate any potential impacts on the MWRP BNR Process. The BNR process at the MWRP uses a combination of nitrification and dentrification technologies. This BNR process is designed with provisions that allow most of the alkalinity used during nitrification portion of the treatment process to be recovered during wastewater denitrification and therefore, no significant effect on the MWRP BNR treatment costs are anticipated. Refer to Response 11 i, above. 11 k. As indicated in Section 5.11 of the DREIR, the proponent has committed to meet all product water quality requirements applicable at the time the project is ready to deliver water into the Orange County distribution system, including compliance with the IRWD's reclamation permit limits for sodium and chloride. Refer to Response 11 i, above. 111. The proponent has committed to meet all applicable water quality regulations and provide mitigation measures as needed to accommodate the water quality requirements of the users of the project product water. The proponent's commitment and specific technological provisions (such as additional level of treatment) and commercial arrangements needed to be implemented to comply with the specific water quality requirements of IRWD, and City of Huntington Beach August 17, 2005 145 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS any such potential future requirements of other water users, will be addressed in accordance with Mitigation Measure PW-9. f 11 m. Mitigation measures to address the operational concerns indicated by IRWD are included on pages 5.11-22 through 5.11-24 of the DREIR. The certification of the DREIR does not oblige the retail water agencies in Orange County, such as IRWD, to purchase water produced by the project. ri 11 n. The proponent has developed a project that has the flexibility to accommodate future regulations and adapt to more stringent water quality goals. In other instances, water quality issues regarding the introduction of new water supplies- into the regional and local distribution system are addressed under normal operating adjustments. Refer to Response 11d, above. r r- r- r r- r City of Huntington Beach August 17, 2005 146 MUNICIPAL COMMENT 12 nrDI sTRIc OF CRa¢VuE COUNT y 10500 Ellis Avenue City of i uritington Beach P.O.Box 20895 Fountain Valley,California 92728 May 27. 2005 MAY 2 7 2005 (714)963-3058 Far.(714)964-9389 wWW.MWdoc.cam ' Mir. Ricky Ramos Ed Royce,Sr. City of Huntington Beach Planning Department President 2000 Main Street Susan Hinman Huntington Beach, CA 92648 Vice-President Ergun Bakall Director Dear Mr. Ramos. Brett R.Barbre Director Wayne&Clark Subject: Comments on Recirculated Draft Environmental Impact Director Report No. 00-02 for the Seawater Desalination Project in Larry D.Dick Director Huntington Beach Joan C.Finnegan Director We previously submitted comments on the original DEIR for the subject project. Kevin a"trot,P.E.Genera!Manager These comments are in addition to those earlier comments and are made in response to new issues raised,not clarified, or addressed in the Recirculated DEIR. Our comments primarily address issues relative to water supply and MEMBER AGENCIES system reliability. City of Brea As a matter of reference, NIWDOC is a member agency of the Metropolitan City of Buena Park East Orange County Water District Water District of Southern California, and provides wholesale deliveries of El Toro Water District imported water in Orange County. MWDOC also provides regional water . Emerald Bay Service District resource planning in Orange County, including planning for new water supplies. a City of Fountain Valley NIWDOC is currently conducting feasibility studies for an ocean desalination City of Garden Grove project in Dana Point and jointly with San Diego County Water Authority at San City of Huntington Beach Onofre. Irvine Ranch water District Laguna Beads County Water District City of La Habra The Poseidon Resource proposed Seawater Desalination-Proieet has not 1 City of La Palma received any interest in contracting for this proposed supply source from any of Mesa Consolidated Water District the retail or wholesale water agencies in Orange County. At this time, Moulton Niguel Water District MWDOOs Board of Directors has not taken any action to contract for water city of Newport Bead, from the Poseidon Resource project;however, our Board has expressed interest City of Orange Orange County Water District in preservation of the site for future consideration for an ocean desalination Orange Park Aires Mutual Water Co. prof ect. City of San Clemente City of San Juan Capistrano Following are specific comments on the Recirculated Draft Environmental Santa Margarita Water District Impact Report. SantiagoCountyWater District City of Seal Beach Serrano Water District South Coast Water District Southern California Water Co. Trabuco Canyon Water District City ofTustLq - City of Westminster Yorba Linda Water District r� Mr.Ricky Ramos Page 2 r May 27,2005 Executive Summary Under the Summary of Project Alternatives, "No Project"Alternative, page 1-21 paragraph 2 under 1.3 states that the"No Project" alternative"...fails to meet the basic project needs and objectives (as stated in Section 3.4 and 3.5)." This r statement is misleading. . The "No Project" alternative essentially consists of the policies, programs and plans of the Metropolitan Water District(MET), its member agencies, including MWDOC, and retail water agencies to meet their future water supply needs. A diversified water management and supply portfolio has been adopted by MET in b its Integrated Resource Plan, July 2004 Update. This IRP consists of a diversified mix of imported water supply programs, storage projects, water transfers, water use efficiency measures,recycling and desalination projects. We believe these collective plans adequately set forth a program to assure water supply reliability over the next 20 years. The Recirculated DEIR needs to present the "No Project" alternative in a more balanced light and to indicate that the proposed project is not at this time specifically included in those plans. See below for a more detailed discussion of the treatment of the"No Project" Alternative. Section 7.0 Alternatives to the Proposed Action r- In this section, alternatives to the proposed action are presented and rejected. It C is evident that this analysis was made to support the proposed project. We respond to each of the major alternatives that were rejected. Section 7.1 "No Project"Alternative. The first paragraph on page 7-3 states that the"No Project" alternative is not presently being considered because it fails to meet project objectives. The proj ect's needs and objectives are described beginning on page 3-36. These needs�and objectives are substantially the same water supply and resource management objectives that form the foundation of efforts of the California Bay-Delta Authority, California. Department of Water Resources,MET,MWDOC, and other water supply d agencies to meet the future water management and supply needs of California. These objectives are found in various water agency policies,programs and ' plans. - - r The statement that the"No Project" alternative does not meet these objectives is a misleading, incorrect and self-serving. Policies,programs,plans and projects of r these agencies are being carried out to assure an adequate water supply well into the future. It should also be noted that the proposed project is not at this time an adopted supply component of MET,MWDOC or other Orange County water supply agencies. Although ocean desalination is included as a buffer supply NV I! Mr.Ricky Ramos Page 3 May 27,2005 component in MET's IRP, the current target was set to meet the projected needs „1 of its member agencies. �1 Further,the second paragraph on page 7-3 states that adoption of the `No Project" alternative "...would result in shifting the obligation for meeting a portion(up to 56,000 afy) of fixture water demands from the project to...." other sources. This statement infers that water supply agencies would have to develop new supplies without the project. It should be recognized and made clear that the proposed project is an alternative supply source to the adopted water management and supply programs of MET and its member agencies. A more accurate characterization should be provided in this section of the report to ' reflect that the "No Project" alternative is in effect implementation of the MET IRP, including ocean desalination projects being undertaken by its member agencies. Comparison to Adopted Water Management and Supply Programs. Section. 7.1 continues with sections that reject 56,000 afy of conservation, imported water supplies, groundwater supplies and local resource project development as alternatives to the project. These are not alternatives to the proposed project. As stated above,the proposed project is an alternative to MET's IRP. The f discussions presented to reject these water resource management and supply options are merely the point of view of the author. It should also be noted that the proposed project's 56,000 afy yield,when added on top of the other ocean desalination proposals from five of MET's member agencies,would exceed the current adopted buffer supply in MET's IRP, as discussed below. Ocean Desalination Projects. MET's ocean desalination program has received five proposals from its member agencies totaling 126,000 afy out of a target of - 150,000 afy. Some member agencies have indicated that they may increase their requests in future years as their projects proceed forward and ocean water desalination becomes an integral part of the region's water supply. The g proposed project yield of 56,-000 afy would add to the local supply;but at this time it is likely to exceed member agencies projects and targets incorporated in the 2004 IRP. This suggests that the timing of the project appears to be too early. However, gaining various permits and approvals for the project, including site acquisition would be beneficial to a future project. In Orange County,MWDOC is pursuing an ocean desalination project in Dana Point, in South Orange County and with San Diego County Water Authority, in the San Onofre area. MWDOC is not considering participation in an ocean desalination project in Huntington Beach. Also, to our knowledge there are no h other current customers for the proposed project. However,MWDOC does support preservation of the Huntington Beach site for a future desalination project. This proposed action would provide the land use designation for the proposed project, which is part of the process for preservation of the site. r� Mr.Ricky Ramos Page 4 May 27,2005 r- The proposed Dana Point Ocean Desalination Project site is MWDOC's preferred initial ocean desalination proj ect site in Orange County. The reason for this preference is the location of the Dana Point project. South Orange County receives 95 percent of its potable supply from one distant treatment plant in Yorba Linda. System reliability improvements are a critical area of need for � r South Orange County. The Dana Point Ocean Desalination Project is one of several proposed projects to improve system reliability in South Orange County. The Huntington Beach site does not provide the same level of system reliability benefit as MWDOC's Dana Point Ocean Desalination Project. The Recirculated DEIR when referring to MWDOC's project should note the system and supply reliability features of the proposed Dana Point Ocean Desalination Project. Section 7.2 "Alternative Site"Alternative. The Recirculated DEIR looks at alternative sites, including the location planned for the MWDOC Dana Point r Ocean Desalination.Project. The Recirculated DEIR should be made clear that this site was not considered because of the 56,000 afy size of the proposed proj ect. On page 7-8,under the paragraph entitled"Ocean Water Quality and Marine Life"reference is made to MWDOC's consideration of the use of`Beach Wells". The next sentence states "Although a beach well intake system may result in decreased marine biological impacts compared to the proposed r project, the benefit is negated somewhat by the need to construct a new ocean outfall for concentrated seawater discharge". This statement is misleading. MWDOC is considering using available capacity in the SOCWA outfall,not constructing a new outfall. Furthermore,MWDOC is investigating the feasibility of constructing a subsurface intake system that would avoid marine biological impacts as well as eliminating aesthetic and minimi2iu public use impacts to below less than significant levels. M`JV 3i OC is also working with the South Orange County Wastewater Authority r on use of available wastewater outfall capacity for blending and disposal of the concentrated seawater from the reverse osmosis membrane treatment process. MWDOC is not at this time considering construction of a new ocean outfall, as k may be inferred from this Recirculated DEIR statement. For a 56,000 afy sized project at this location the Recirculated DEIR is correct, that a new feedwater intake and ocean disposal outfall would be necessary. This section needs to be r clarified regarding the distinctions between the two proposed projects. { Table 7-3 purports to provide a comparison of alternative sites. It needs to be made clear that this table addresses construction of a project yielding 56,000 afy. Otherwise, it is misleading,because many of the opinions on impact are incorrect for a smaller, differently configured project such as that being pursued by MWDOC. - r 1 ' Mr.Ricky Ramos Page 5 May 27,2005 Thank u or the opportunity to review the Recirculated Draft EIR and provide Th you f pp ty r vl comments. If you should have any questions or need additional information to complete m your response to these comments, please do not hesitate to contact the undersigned. Sincerely, rRichard B. Bell, P.E. Principal Engineer i r Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS r Response No. 12 Municipal Water District of Orange County Richard B. Bell, P.E., Principal Engineer _ r 12a. These paragraphs provide an introduction to the comment letter and do not require a response. 12b. This text provides an introduction to a more specific comment discussed below. r Refer to Response 12d, below. 12c. This paragraph provides an overview of forthcoming comments regarding alternatives, and no response is necessary. 12d. This comment maintains that the DREIR is "misleading, incorrect and self- serving" when it states that the "No Project" Alternative does not meet the project's objectives (the six project objectives are listed on Page 3-45). However, the DREIR is correct when it states (at page 7-3) that the "No Project" Alternative r fails to meet the basic project objectives. While the "No Project" Alternative may provide a reliable supply of water to Orange County, it does not provide a "local source" that is (1) sustainable independent of climactic conditions (in other words, "drought proof') or (2) sustainable independent of the availability of imported water supplies or local groundwater supplies. In addition, the "No Project" Alternative will not meet the project objectives of reducing the salt imbalance of current imported water supplies or of minimizing demands on the imported water system. Finally, the "No Project" Alternative will not remediate the project site. For these same reasons, the commentator's characterization of the project objectives as "substantially the same" as those of MWDOC and other water purveyors is incorrect. Also refer to Response 2h, above. - 12e. Refer to Response 7t, above. 12f. The proposed project is not "an alternative to MET's IRP" as suggested in this- comment. In fact, at page 3-41, the DREIR recognizes that the project is independent from the MWD's Seawater Desalination Program. The project is a proposal to develop 56,000 acre-feet of desalinated seawater as a new supply. For purposes of comparison with the proposed project, the "No Project" Alternative (based on existing water plans) projected reasonably foreseeable increases of 56,000 acre-feet per year in particular water resource management and supply options (that are identified in existing plans), including projected increases in conservation, imported water supplies, groundwater supplies and local resource project development (including recycling projects). 12g. Comment noted. No response is necessary. r 12h. Comment noted. The suggested change has been incorporated into Section 3.0 of the Responses to Comments, ERRATA. 12i. The suggested change has been incorporated into Section 3.0 of the Responses to Comments, ERRATA. City of Huntington Beach August 17, 2005 152 r Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS 1 9 Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS 12j. Reference to a new ocean outfall at MWDOC's proposed desalination project in Dana Point have been removed. Refer to Section 3.0 of the Responses to Comments, ERRATA. 12k. The suggested change has been incorporated into Section 3.0 of the Responses to Comments, ERRATA. 121. The suggested change has been incorporated into Section 3.0 of the Responses to Comments, ERRATA. 12m. This text provides a conclusion to the comment letter, and does not require a response. ■ City of Huntington Beach August 17, 2005 153 NC Orange County Fair & Exposition Center COMMENT 13 32nd District Agricultural'Association 88 Fair Drive Costa Mesa,California 92626-6598_ 0 (714)708-3247-Voice City of Huntington 800t I g 9 O (714)641-1783—Fax SAY 3 12005 ' May 27, 2005 Mr. Ricky Ramos City of Huntington Beach 2000 Main Street - Huntington Beach, CA 92648 Subject: Seawater Desalinization Plan at Huntington Beach Recirculated Draft Environmental. Impact Report(SCH No. 2001051092) ' Dear Mr. Ramos: Thank you for the opportunity to review and comment on the Recirculated Draft Environmental Impact ' Report (DEIR) for the Seawater Desalinization Plan at Huntington Beach(SCH No. 2001051092). The 32nd District Agricultural Association (32nd DAA) and staff of the Orange County Fair and a Exposition Center (OCFEC) focused their review of the EIR on those aspects of the project that relate ' to OCFEC operations and property. 1. The 32nd DAA and the OCFEC Corporate Officer has no record of receiving a copy of the Notice of Availability or a copy of the_DEIR_ The 32nd DAA and the OCFEC are State Agencies under the Department of Agriculture and should have been noticed during both the scoping process and the DEIR public review period pursuant to State California Environmental b ' Quality Act(CEQA) Guidelines Section 15086. As a State Agency that exercises authority over resources that may be affected by the proposed project, please add the 32nd DAA to your mailing list. 2. The Primary Conceptual Pipeline Alignment shows that a pipeline will be installed"off pavement" along the northern side of Fair Drive adjacent to the OCFEC. It is unclear from ' Exhibit 3-3 or Chapter 3.0 Project Description exactly where the pipeline will be installed (e.g., in the street right-of-way,under the sidewalk/bike trail, or closer to or on OCFEC property). C a. Please provide clarification regarding the location of the proposed pipeline in Fair Drive. b. Will OCFEC parking facilities be impacted by construction? d . c. Please provide a description of"off pavement" construction. 3. .If the pipeline or pipeline installation encroaches on OCFEC property in any way,the 32nd ' DAA will become a Responsible Agency under CEQA with authority to approve or deny f applications for easements on the property. 4. The OCFEC is a year-round exhibition, conference, and event center. The primary function of the OCFEC is to host the annual summer Orange County Fair. Approximately 964,000 people attended the 2004 summer Fair. As a year round community venue,the OCFEC is committed to the education, safety and enjoyment of its public constituency. For example, approximately 75,000 elementary school students visit the OCFEC's Centennial Farm every year. The Youth Expo draws over 25,000 children during a weekend each April. In addition the Orange County g r Market Place, representing over 1200 vendors, occupies a Signifirnnt portion of the OCFEC parking lot nearly every weekend. In total.over 4 million people attend events, the weekly Market Place and other.activities in addition to the annual Fair. Any disruption to the parking area and/or access points to the OCFEC could cause significant impacts to any of these events. Although a general phasing schedule is provided in Chapter 3.0 Project Description; however, it does not include anticipated months of construction. a. Is construction along Fair Drive anticipated during the months of June, July, or August? h , If so, please provide analysis of potential impacts to summer Fair operations including those impacts related to traffic and circulation, noise, and air quality. b. Will access to the OCFEC via the main entrance on Fair Drive or the Vanguard Gate b� i restricted?For how long? c. Mitigation Measure CON-31 stipulates that access to residential and commercial properties must be maintained during construction. As a Public Institutional use, access to the OCFEC should also be maintained. d. If construction along Fair Drive is anticipated during the months of June, July, or August, please assess the proposed project's impacts on Fair vendors and the revenue stream that will result from construction and access limitations. An abrupt drop in k revenue could have a physical impact on the Fair's daily operations, maintenance, and implementation of the Master Plan program. e. How will installation of a pipeline in or adjacent to Fair Drive impact non-Fair operations on the OCFEC?Will construction take place on weekends when the Orange County Marketplace is in operation? f. How long is construction expected to last along Fair Drive between Harbor Boulevard r and State Route 55? M r r r r ' If you have any questions regarding this letter or if you need additional information,please contact me n at (714) 708-3247. Sincerely, ORANGE COLNNTY FAIR&, EXPOSITION CENTER Becky Bailey-Findley ' CEO/General Manager ' Cc: Jim Barich, 32nd DAA President 1 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS ' Response No. 13 1 Orange County Fair& Exposition Center Becky Bailey-Findley, CEO/General Manager ' 13a. This paragraph provides an introduction to the comment letter and does not require a response. ' 13b. The California State Clearinghouse is the agency responsible for ensuring that applicable State agencies receive notice for relevant environmental documents. However, the Orange County Fair& Exposition Center(OCFEC) has been added 1 to the project's distribution list. 13c. Under this alignment alternative, pipeline construction would occur under the ' sidewalk and fence area between the OCFEC property and Fair Drive. 13d. Under this option, parking facilities may need to be used for construction, but 1 only a maximum of 30 feet at the southern edge of the parking pavement. 13e. "Off pavement" construction refers to the construction of the pipeline adjacent to Fair Drive, which would not affect Fair Drive directly. 13f. Comment noted. No response is necessary. 13g. Comment noted. No response is necessary. 13h. The exact timing of construction at this reach is not known at this time. Detailed construction schedules are customarily developed during the detailed design phase of the project. However, construction could be scheduled to prohibit construction during this period if so directed by the City. ' 13i. It is estimated that pipeline construction will proceed at a rate of about 150 linear feet per day. As a result, open trenching in this area will most likely be limited to only two or three days. However, total restoration of the gate area may require approximately two weeks of total construction (median replacement, curb replacement, etc.). ' 13j. Comment noted. Access to the OCFEC will be maintained during construction. 13k. The construction specification would be developed with strict requirements_ to limit the impact to fairgrounds operation. Construction would occur during weekdays only and would not significantly impact the Fairground's weekend activities. As stated in Response 13h, construction could be scheduled to prohibit disruption during the months of June, July, or August if directed by the City. Also refer to Response 13j, above. 131. Refer to Response 13k, above. 13m. The reach of pipeline between Harbor and the 55 Freeway would require a maximum of five months of construction time. City of Huntington Beach August 17, 2005 ' 157 r Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS 13n. This text provides a conclusion to the comment letter and does not require a r-- response. r- r- r r-' r r r r r- r- r City of Huntington Beach August 17, 2005 158 r- COMMENT 14 i 'II1rerlors QJti cars PHILIP L ANTHONY or P1-tILJP L.ANTHONY WES BANNISTER 'I Pr[Vvir)gnt KATHRYN L.BARR JAN OEBAY DEN1S R 61LODEAU- i rrrat VicePt"Ideld ' RICHARD CHAVEZ y C PAUL GOOK KAl'HRYN L.BANR --JAN. BAY rr17) Or IeiNL' IZF S&Gottd Vha9 Premidnnt 9HAWNNELSDN ORANGE COUNTY WATER DISTRICT y cam Warn �\ �J VInCINIAGNeaB1EN ROGGR Cr YOH Orange County'Groundwater Authority Goneral Adan&ger May 27, 2005 ' MP Ricky Ramos `-04-of Huntington--B-each-%nning-Departmerit 1 2000 Main Street ' un ington-Beach;-CA792548 ,�Ct:.-Draft Reciucs aEte [E-i if-onme9ttAiT0Vavt'-Rapar"o:-00;-02 for the Seawater Desalination Project at Huntington Beach ' Dear Mr. Ramos: The Orange County Water District (OCWD) has received the draft Recirculated -Emvimn mental 1mpact-Report-TETR) for the Seawater Desalination Project at Huntington Beach dated April 5, 2005 (State Clearinghouse N_o 2M105jD92)....00WD appreciates the opportunity to review the draft Elk and supports creating new water supplies that a are consistent with the.area:s water supply pfans-at3d-pok4es. ' OCWD's comments on the draft EIR are: 1. The Environmental Summary, Section 1.2, under `Long-Term Water Quality ' Impacts'.and..P-wduct-Water-Quatity'.-should-addtess'-the-potential water quality b impacts of high chloride and sodium concentrations on irrigation users. 2. -Sodium; 'chloride, and boron concentrations in the proposed projects product water -may teed 4heAevels--in,-existing -water-supplies, potentially causing negative impacts to water users and recycled water users. Table 3-1 should list `sodium-,-chloride;-and'bumn "concentrations. -Section 5-11 should also have a C more detailed evaluation of sodium, chloride, and boron issues for recycled water users."The evaluation of water quality issues should include an assessment of potential impacts on irrigation uses..-Other-sections of the-EIR should be revised accordingly based on this evaluation. '-3,-OCWD would need-to see additional details before it could agree with the EIR's statement in Section 3.4, page 3-37, 'The.project W_ auld.provide.a new source of supply, and thus allow operational flexibility in managing -the amount of .`groundwater.pumped ftom.inderground.aquifers_ --This-would-assist in protecting the Orange County Groundwater Basin from seawater intrusion and/or replace groundwater.-supplies -nest -to 'overdraft- -concems.n This statemen: is not ' P.O.Box 6300,Fountain Valley,CA 92728-B3D0 - 10500 Ellis Avenue,Fountain Valley,CA 92708 fielephtme-(71-4)-378'3200 Fax(714)378.3373 Web Page www.ocwd.com r- --Ric-ky Ramos May-27-,2005 Page 2 of 2 supported in the draft EIR and there is no analysis or descri^t6un i,n the craft EIR Td r In ve.�..' L_� .ate_ L. _ j Y - .+.. ,.PLain-„v,n-.ttc„yWhesiz�`b-enefit woutd be achieved. --1 4. In referring to Phase 1 of the Groundwater Replenishment-(GWR) System,.the .,In states 'The 72,000 acre-feet would essentially offset the 60,000 acre- feet of imported water.,pu.rchasedJrom.-MVV.D-�,, #hisa--by-OCWWD, and, when added to the normal year recharge of 200,000 acre-feet, could allow for a slight ..increase in_available.grsuadwater-supply." T-Hs-statement is incorrect. OCWD e intends to continue to buy as much replenishment water as possible from MWD after--the--Phase A -G"-System is operation 51"in 2007. The Phase 1 GWR System supply of 72,000 acre-feet per year is intended---to,increase.basin pumping,--not offset water purchased from MWD each year by OCWD. . The_quWtatiGns-fnam.-he-Grand-JMTeport-nri­pages�= 4 and'3-45 of the draft r- EIR are not provided sufficient context to explain to the reader the fact that with a -seawater-intwsion -barrier, a 'cogs-W pumping depression' can exist without f causing seawater intrusion. When sufficient water islnjented into the barrier, the barrier prevents seawater intrusion even when a coastal pumping depression exists. '-6.-1n-1he discussion 6T alternatives to the proposed project, the draft EIR states in Section 7.1, page 7-5 "Therefore..Ilia abiRy-of4he ndwater basin to increase output or increase inflows of recycledfreclaimed water is limited.' The draft EIR has not-.considered .fie- eppertuP ttes--that -am--avaitabte--through Mid-Basin Injection with GWR System water, future phases of the GWR System, future `i mases-in-8anta -Ana-Riverrflow'-due"to'increased development upstream of Prado Dam, and other opportunities to increase the_groundwater basin's yield. `l"he-ElR-should acknowledge on-going OCWD planning efforts for future GWR phases and injection of GWR water through.v►J, 10-ated-lathe middle portion of the basin (this option, referred to as "Mid-Basin Injection" is described in the Grand Jury repo-d).. .5?GWD._ia.{)reparing a Long-Termfacifities Plan to-identify potential projects to cost-effectively increase the groundwater basin's yield_ Mlid- '43asin 1p*tion -GW-R-System-product water-and other projects that would allow increased basin yield are being evaluated in the Long-Term Facilities Plan. r The-OR-shoufd-presenta more'balanced discussion of the alternatives to the proposed project. r-- Tf you would like to discuss these comments, please contact me at 714-378-3200. h � r Virgir Grebbien, -G-ssteraf-Manager ' Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS S s � g Recirculated Environmental impact Report 2.0 RESPONSES TO COMMENTS n Respo se No. 14 Orange County Water District Virginia Grebbien, P.E., General Manager ' 14a. This text provides an introduction to the comment letter and does not require a response. 14b. Refer to Response 11 g, above. 14c. The proposed project's product water quality meets all applicable regulations. ' The purpose of this project is to produce drinking water that is in compliance with all current regulations, not water that has exactly the same levels of boron, sodium and chloride as the existing water sources. The differences between the water quality of the existing water sources and the desalinated water in terms of sodium, chloride and boron are not expected to have measurable environmental effects associated with the use of this water for irrigation. For specifics associated with the sodium and chloride levels refer to Response 14b, above. For specifics associated with the boron levels, refer to Response 15ai, below. Table 3-1, page 3-32 of the DREIR shows only key desalinated water quality parameters. The water quality of the desalinated water in terms of boron, sodium and chloride are presented in Chapter 5.11, which specifically addresses product water quality issues. 14d. This comment asks for additional information to support the statement labeled as "D" at the top of page 3-37 of the DREIR. The additional information in support of that statement is included at pages 3-43 through 3-45 of the DREIR. 14e. This comment has been addressed in Section 3.0, ERRATA, of the Responses ' to Comments. 14f. Comment noted. No response is necessary. 14g. Comment noted. It was not feasible for the DREIR to include all of the on-going planning efforts that are being evaluated for inclusion in OCWD's upcoming Long-Term Facilities Plan. 14h. This paragraph provides a conclusion to the comment letter and does not require a response. City of Huntington Beach August 17, 2005 ' 161 i PRIVATE ORGANIZATION COMMENT LETTERS 05/2(/10 on 14:'L'L CIVV 1KUNMr_1Y I 1`IUW rwt]G ul COMMENT 15 California Coastal Pr-olection Netivork * C'al fornie Earlh.corps "Elkhorn Slough Coalition „` Friends of the-Sea Otter "Friends Artists and Neighbors of Elkhorn Slough Public Citizen 'F San Diego Berykeeper F,Save Our Shores *Save Our Waterfront C.omnlit tee,*Sierra Club, *Southern California tf'atersh.ed A?liamce * Surfrider Foundation " T%le Ocean Consen ancy Mr, Ricicy Ramos City of Huntington Beach'Depa"tiTient of Planz ing In 2000 Main Street Hun ing,ton Beach, CA May 27, 2005 RE: Seawater Desaiination,Project at Hum tington 'Reach Draft Recircu;ated ETR No. 00-02 Via e-mail: zTaniosrasur{city-hb.ort, Via• Facsimile: 714.374.1540 Dear Mr. Ramos: We' are writing as-a group of local,regional, and nation.-wide organizations in regards to the draft,Poseidon-Huntington Desalination Re-Circulated Environmental Itnpact'Report (REIR.). We appreciate your careful consideration,of the IZEIR.. Your cautious scrutiny is important for several reasons,not the least-of which is that this is the first such report in California to forecast the impacts of a massive desalination facility. In these Lmusual clrc urns;tances,the Huntington Beach City Council effectively bears the extra burden:of setting a standard under the California Enviromnetital Quality A.ct(CEQA) for the review of similar desalination facilities statewide. This,is of particular inferest to citizens in both the southern California region.and.the Monterey Bay—the fbous.of planning for vumerous,desalination facilities. a It is important to point out that the undersigned groups are not opposed to desalination as a source ofpotable water:Many of the gmupssigning-signing s.letter.have.b=a investigating and protnoting the implementation of sound desalination policy as members of the Coalition on Respo.itisilslc-Desalination-ari&the-5tatewide E-Lvimnme .tal Desal-Working- Group.Nonetheless, in the absence of any detailed statewide or regional policy on the implementation of desaf.inatian facilities, we Uclieve_proposals like-the Poseidon- lluntngton facility are.premarure and c-cu-rently.u.nnecessary. - The,_Stateof-California is currently_speading-tens-ofminions of Proposition 50 dollars to research the best practices for collecting "source water' fi.-=-the ocean,and.for.the.most-efficiciat mr-anc.of.. 1 YJJ/'Ll11C7YJJ 14:11 JlC1-ozD-OOLU ' LI Y V 11\VI YI'ILI\1 1\Uw r- processing that oceaal water into potable water, To race into massive production facilities that leave o sr precious natural resources at risk, before the researcli is complete, is simpl3'"putting'th.e cattbeforethe horse", r Similarly, since the iiutial.rcvlew of this project, the United States Environmental Protection Agency has promulgated regulations for the r Use of at large facilities like the Kuntizgton Beach Generating.Station These regulations mandate a-dramatic reduction-in-the cuircnt_mortality.of marine life from "impingement" and/or"entrainment."It is unclear at the current time how the F BGS'i:ntends to conalsly wTtlrthese xnev=regulations:But,. reliance on the current cooling water intake for desalination source water is;again, premature and unsound public policy, a r - The California Deparunent of%ter Resources-is•currentl.yassessing-th-. projected demands on our limited water supplies and the several alternatives available for meeting an ever-growing demand:The niche iir- our wat=...portfolio.that can be filled with environmentally sensitive desalination facilities is still undefined. r It is in the best interest-of-ratepayers-arid-the cnvironrnent_to-ma.ke.sure.that the answers to these'outstanding issues are resolved Before approval of such a permanent and massive Saciliiy as the Poseidon-cFitiitingtbn proposal: Finally, and possibly most importantly, as detailed-btlow;�the-drafi-REIR still ails-to. allow a fully informed consideration of the proposal by the public and.•heir elected • representatives.The:REIR, in several areas,is inadequate. 'In the most eaareme'cases;the REIR may also be rnisleadingthc public arid our representatives. • r it is critical that the ptilli-c ana-CLur.decision-makers.fully.understand the scope of public policy issues that are raised by this project-considerations that go well beyond the surface issue ofwater sappily:ThispmlJ ct;-and-the associated_RELR raise.sei-ious considerations about futum Clean Water. Act compliance, coastal zone management, land use planning, electricity generation,marine life managerrrent/protectto-r�;-etc.It-isa.major_ decision that demands..thoroueh.doeunnentation and public policy debate before approval. r Once again, thanlc.yau_fnLyour.thorou3h considerations of the comments below, Sincerely, Sierra Club San Diego Baykerper L. Bruce Monroe Allison Rolfe RJ Chair- Coast &. Ocean Committee .Policy Director r- 2 r 17MWZI ZUUZI 114:LL )lU-DL7-DOLL GYv1TCUIYI�IGIV1 iVl-rw ��` �� l Surfrider Foundatioi7 Soutllcrtl.Califorllia Watershed Alliance Joc Geever Conner Everts r Southern California Regional ManaSer Executive DirectoT- The Ocean Conservancy California Coastal'Fi-otection Networlc GTeg rlc ris Susan J'crdan Prodmui1 Mzmaaer E;xeeutive Director California Earihcorps I'ubli'"c Citizen Don May Juliette Becic.. . b Executive Director California Director Fri-ends of the Sea Otter Ellabom Slough Coalition Heather Allen Maclelitite-Claik- Policy Director Save Our Sbores Save Our Waterfront Committee Jane De;Lay Barbara Bass Evarzs Executive Director Frim ds Artists and Neighbors of E om Slough Klaus Kloeppel y r COMNI(ENTS 1) "Project Description." and."Alternatives Analysis" is Unnecessarilv Narrow and Consegu6tly Inadeauate for Full), Inform-ed Decisions As noted in public corotnents on the original EIR,this re-circulated EIR(REIR) fails to adequately mialyce"wastewater.reclamation" and."watcr-conservation"as alternative supplies of iTcshwater for. the affected area. The EIR instead attempts to describe the r potential for i acreased conservation under the"No-Praject"alto rnative:Most imnortantiv, the inadecivate consideration of these feasible alternatives does not include a comparison ofthe environmental impacts, both yositive-and-negative;-ofP=suim-thcsr-aiternatives over a massive desalination.facility-Further=Te,a•more acctuate assessment of alternatives available to meet projected future water.dernands would allow a mix of conservation,reclamation-and-a-9imiI16r dcsak=. ian-facility-with-environmc-Lally.- C preferable source water intake alter,,,atives to the AES cooling,water intake- As in the original EIR, the draft REIR narrowly defines the purpose of the project as "local"in nature. We can only predict that the Response to Oommcnts will again rely oir this.narrow pro)ectdcscript:ion.to argue.that roclarnation and conservation are contingent upon imported water supplies and consequently do not meet the purposes of the narrow proiect description, tin-general;the R€IR definesxllP s ect puiposein-such.a-disd•.reet.. . r Fund narrow description so as to effectively preclude any reasonable alternatives to balanced and r.eliablewatersupplypamfbho,-Fhis-ird ro-?v-=6-speezous apgroaclr. undermines the intent of CEQA to offer the public full disclosure of the impacts of the r Project compared with those of feasible alten:3atives. Project Descrintiotn, Needs and Objectives The REIR Section 3_4 (Praject_Needs.and Objectives) states the need for increased supply in reference to past and future droughts. However, while the 1977-1.978 drought provided a learning-session-or-a wiltdow.on.tale.future,.thf_—z=am.longrterrn drauahtin.. the Colorado River system.and.the previous driest four years locally have been met with (� minimal conservat;=-=dTcclamatiorr-effortF-=-alternativ&S-that t43e REIR-disco}u is There have been no cutbacks or restrictions during this tine, and when the drought turns i to flood, as it has this-past winter, and his hdppen.ecrl=i stollcally, these local programs r show their.gl eater.valuc..To.hasn xlus_project.nnly..on-a dtQught period would leave the area with an overpriced,underutilized facility, as happened in Santa Barbara, where their decal plant;built-in-drou-eht; no,w-sits-idle. Furthermore, the disorrssioi-�-of-the-Califor->Z_Wattr 1 LI4 the-State-DZD-w-.meant-of watcr Resources' long term.planning tool,originally called Bulletin 160-2003,.now version 2005, is now under a gubtic-bearing pTv=s-with-tIrF.F r- ass�npt:ions--th& -the seenar as, e r laid out in the REIR. In addition., Water for California and th.e Planning and Conservation ' Lcague are circulating "Thu Wliier Jnvestment Strategy"See: • r 4 ,r 05/271200b 14:zLz .31U_bz7_t)nztI CIYvl�CUrn9GVi IYUw i .rur_ u,� 11tt1� /��ww.;�cl_orr�/ncl/pcl wa.terforca_asU as-illesponsc.tothe.Water Plan. After careful. review of the California Water Plan and the State's Desalination Task Force rccorn-nendatiorls, the study concbades that ocean water des rnaticu.is the lowest level_ supply option. Ocean water desalination should be used only when,conservation zu1d ,r reclamation potential is exhausted and only wheri beach tivellsar�the 'r..ntahe-sourceta, mitigate inipact•s.on the m.arinc environment: The State Desa.l.ivation Task Force recommended that desalination should be included i.ii a water supply portfolio wbj tre ir'i,-. econornlca!1y anal =,v rcrmi nYt l)y.approoria.te ' and wizen rccychng and comzervatlon have been implemented to the"maxiiriiim extent practicable." rThe chart shown on Table 3-3 of the REIR lists assumptions from the MWD Integrated e Resources Plan that can be refuted-by the Waler hwesttrnent-Strategy-table-listed.below- - ,ii:;_ _ —+rr _ na,a� — :+CS':-- -— •i eS; oh, ""rF��`—_ V .dd�f�aital'i;6leeq.'st '~�' 'c:_ _ _ ,Population Increase ._ Environmental Restoration ;�— 1:0� - ..Y.(il:' rM ill:�_ - -- --il: .rrl r,i:_`�•...Iw,��rr•�:.�-y:;-.... ..4._-_-__.—r TOYaZ�^' �`d' iiatl,6'e ..�-...,:�'; .::el^ ::•�r..:�� •a:�;:':,`:`;•"^� _ ..;:.�.��.�=":3:U 314g' -_ - "IM1rir_. =-✓-'"t�i J��i'._TV 'unririuL:-=_ •uJ,�iW1R^- n'tt:vai aY.^:•v2,q . Firsc:P�h'. ty,(,gpt o�sy. _ :,..ar::la:?xika r....:......; uC. i'?„S.it°(n!1iI�kC[?D:cF 11f eL ruroan water..Coaseryaticn 1 2.0-2.31 Agricultural Water Conservation ( At least 0.3-0.6il Recyc;ed.water- Treatment r rou water and Desalination At least 0.29; I_. Tre. — - - ;I---- - - - - -- -- - _-_-__:.'Tr.— - r.R'•__+�-__ r,.�-_�.4".M w4'y�--___ ..._'rl:Vl'^-:-�...Y:Y:._�rY ....._._nlf,.,�..W The REIR Section.3.4 B (Replacement Water) cites reductions.in.Mono Lake water as rationale for this project. The fresllwater streams that feecrMbrlo Lake only supplies-•- water.to Los Angeles.I-fowever, of interest in this case, any losses dire to environrnental mitigation are covered by conservation offsets by order of the State Water Resources f Control Board,in 1.995. This is.an.excellent.exatnple of how conservation, in coordination with community-based organizations as the delivery mechanism, can provide real water for urban use and st:l l jet 3E}"/'return to stream-Maxus-for-enYimunental.benefits. The REIR Section (PmjDeseriptisl�}s}+- naFlzes rurtentcstimates.of.w�tter supp y from wastewater reclamation(recycling) and water conservation.in the Orange County disv i,bution area. It is important to note'that-the-Urb-drr W'atar-MaRagemerit.Pl-an is- - currently beilig revised and could provide additional proj ections on water availability from these sowces. 1'utrthennore, we are requestiizD that-the-Dort-af-m-integ-ated resource plan' -- that is, a plan that thorouehly considers reducin*-surface water pollution, ar while,simultaneously supplying fresh water -- be more rhoroughTy considered-in the Urban,Water Man-agementPJan,.A tborout h documentation of potential manal;eirient approaches should evaluate the avoided costs of Clean Water Act compliance when water purveyors extent. For example;the Santa Ana Watershed Project Authority, which is working on a long- tcrm plan to be imported-water free for a three year period,.without ocean.desal,.is r working upstream.to clean.and restore gound.watcr supplies on a watershed level. Sce: w,ww. awpa.or This-winter's.high raiiai levels.acid.ruaofr-ha—v.t nprovcd_- 'andwater.. storage bevond listed numbers reflecting recent local drought. Climate change estimates silo w that local r siai* .e_pz(oa:ains,such as S-AWPA, will.have_great=_Value.aslncal.. g areas may receive more water and areas with traditional water supplies receive less. With t- extensive studies for-current.and future stom-watt-x-prngmms;..tais�uater-is now-seen.as_ W ,-;Ii t 1? u nle lie e-fits of imnr n7 i cr r recharge �df;� asset.ii�« a ila• S.:y, �^. b. lti, n -cued water �_lal..ty, eate_ � potential, and water cats-hr-zent with-cisterns: l Furtherrnore;-Secti-on 4.-8-duesn't-fist or supply source, along with other traditional supplies',vwb1c.h does include reclaimed water facilities. Finally, the,assumptions and conclusions of future demand, and the short timelines to i meet that demand based-on the.proj.actedcamptletiondaie.ofPaseidon's desalination... j facility, are confusing at best. >- I In short, the combination of Sections 3 and 4 of the RLIR are confusing,.inadequate, and misl.eading..The-se seatious-do-not-mezt-the- accurately inform the public. Alternatives J The RE1R Section 7 (Alternatives) againrelics. on assumptions that there is a discreet dermand'for 56,000 acre feet of water, and'diat tliis water must be deliveraEIe by 2008- Thcsc-baseline.assvmp;nns arc.not.UahroughLy.sutnstazz» ed_Mora-importantLy these r arguably flawed assumptions undermine a reasonable review of potential alternatives for providing a sustainab-le-aaad--za-viFa�u��ent�illy-preferable per suppl3�p4rtfalie€ar the region. r Section 7 briefly discusses the potential for recycling and conservation. Brut,the EIR appears to treat each-alternative as mutually exeliisive nattier th.ai.i,considering a q combination of improvedconservation.and.greater rcclamation.outgut..Furthermoze,.th_e_ alternatives analysis seems to conclude that these sources would not be available before Z008.-thc:proposed-date for.Selling-th�I2esa.l.facility-ou-line-This-dateis.not corisistent, with planning documents for 2025 demand relied upon in the REIN and is.consequently irrelevant.. L Most inanortantly_ alternatives_ such as hciehtcned water conservation Prot-t•ams and increased wastewater reclamation. , For example, a recmat-study-byihe-Irvine-Ranch-Water-Di=._ct-docnrnenta-rhat-fairly- sumpl.e application of irrigation devices can.reduce overall.household water demand by ' r 50%, rcd-uce local urban runoff by 70%, and-'can reduce pollutant Ioadings irz receiving waters by 75%. See-.wwtiv.i.rwd.com atldseazchfor.`-`Residen.i.alRunof£Rcduction.(R3�.._ 6 L �" G7l Lf7 LGG� 1V.LL ,J1 U'ULJ uu.au `. i.�✓,..` .. .✓.. ..-- —. t Study." Also, expanded wastewater reclamation prog,ams can dramatically reduce treated seware.discharges to the ocean. As the REIR poin.1s out in Sections 4 and 5, fbere are numerous poternnal sources of contamination contributing to the intractable problem.of beach closures at Huntington t Beach; Arnon1-these are the sewage discharge frowL orange County Sanitation Distract's 1 treatinent facility and urbairrtmoff. These sources can be dramatically reduced.by an r�. aggressive pi-ograr, to cxpan.d wastewater reclamation and the Groundwater Replcnislimc:nt System, as well as a progressr-7e"prograin to i_tnpiemer,.'t-water conservation. . _ . Furthermore, the Municipat Water District of Oratlge County is experimenting with alternative"source water" collection systems that avoid any impacts to marine rife— either through dirmt:ogea.00ean intalccs,,or thsougli reliance and exacerbation of existi.rtg cooling water intakes for a coastal gelaerator. Once again, it is the findings of the State Desa hnatioii Task.Force that desalination should be included-irra-wat= srtpply pGYtf'oli(a nomically.and.. enviroumcnially appropriate"and when recycling and conservation have been imp leimenwd to the "maximum extentpracticable.' The R.EIR fails to give the public and our decision makers,an-adeVtate znalygis-of- alternatives for meeting.tbe projected demands for freshwater in the region. In, particular, the.-combination of water conservation,wastewater reclamation and a downsized-enviraumi=tally. preferable desalination facility are not considered a separate"alternative."More importantly,the scant consideration of these 1 alternatives in alteruative.does_uQtdiscuss the environmen"tal benefits to water quality of this course of action— not to mention the economic benefits of reduced'ClczarVesterAct cocra ligi;e� casts - Z) Definition of En*traiiiment/i>rr oinzemenr'Sio-mi nce' Es: Ilisleadintr antl.Scope of.Impacts Too barrow Once again, given that-this-is-the fist-GSA,rcvII w.afa.desalbation facility of this Z'. configuration and size, the:REIR is effectively setting a new GEQA"standard of review." With this in inind,-the assuznpdorrs-em toyed as-weEl-as-tlg sc_pe and-standard deserve heightened scrutiny. Q ' R..eREIR relics ou misreading stand�trdsfortfetct7xrmi "sig fxeance''' of.ig�pacts to- marine fife. Furthermore,the REIR narrowly defines the scope of potential impacts from the co-location of a massive desalination facility with the existing-Fiuntingtonaeaclx- Generating Station..(I,i GSA.. • i Defining"Significant" . t= The REM, in Sectian.5-1.0,page 41,concludes that, "Impacts due to operation of the Proposed desatination facility in regards to impingement and entrainment are not anvcipated to be sigttif cant."This conclusion.*&.based in part.on reliance:on the harvest p r courol rule adopted in the Nearshore l;is4ery M-wiagement Plan—the so-called "40-10 rule,"Id. ThIs harvest-control rules applied to fisheries-where tl trasess y data is ... available. For many species,this data is not available and harvest cont-,.- Is must resort to r "proxies-" ---� Additionally, the REi.R.acies not document historical inipingen3ent/cntraimi3ent of species r of major concern,.nor.does it compare.these rites with.dwindlingpopulations.For •example, populations of Shecphead, Vermillion Rockfish, Boccacio Rockfish, Cowcod Rockfish have declined frG}n.habitat losses,.cxvzrfisl'i'Aud-other_pressures over the past several decades that may lead to dramatic reductions in the nuinber of individuals (� recorded.1"D itnpinkmurit/entr iniment studies: l�tQFrefl2e}eVs;t{�ese pepula an dec-lines ly.. underscore the importance of reducing mannelife mortality from cooling water intake 4 structures. Furthermore, numerous species likely enirainect-arthe--farcifitp;such Tidewater Goby and-G.ar-ibaldir art natregulatedJonsustainable harvests —several having total prohibitions on any"take,"Therefore,the use of fishery management plans and harvestocintrol-tafess-2sindcaorf si- fnt ti1at-r u �nc_life i r REIR oversimplif es the complicated process of determining"total allowable catch" and. misleads the reader. I � Nonetheless, assuming the best case scenario(i.e., that the species' populations, survival strategies,'and life-cycles-are-fully.understood), the rule-would not necessarily_allow the t "taking" of up to 60%of the existing populations—as implied in the REIR.In fact,the har.vest cotitro}'ntle-relies-on-estimates-of."trnfrshecLbin,,,��s"-not ctirrent populations_ If the currant populations are below 40°/a of the estimated un-.fished biomass, ">;ebuilding. l- plans"are implemented-oTrzr-c c, ari:d--1-89{,7-af-th&s;e populations:ConsideW- r a species where the necessary data is available to employ the"40-7 0"rule, and current ` populatimis are below 1.0%of the estimatedr`anftshed-biomass—the "4G.;It'rtrle-may.... prolubit,the take of these species altogether. There are species within the Southern Cali forma Bight where this is the case(e-g., "Cow-Cod"rockfish)anal others that Have dramatically reduced harvest allowances because the mm-ent populations are estimated below-the 40% target(e.g., "Sheephead"). Therefore, any"take" of these species and others under-similar under.thzdeftniti.on relied on ui the r- REIR. In short, the REIR's use of the"40-10 rtr]e'for defining"significauit" --and the r inzxplicable application-of-therale to-the S--tend thc- additional mortality attributable to the proposed co-located desalination.facility— is �- ruisleading. Without fixity identifying the populadotrs--af cv rsiderzttiorr;and the S applicability of the harvest control rule,the'REIR falsely concludes that- The maximum. "harverr" cry--ect ar 12-7 MGD- s a33-• percent, sicn.�Czcvntly.below the uccepred(DFG) thresholds of 60%. .,The - t L. 05/27/2005 14: L'L ate—tste—aeste� C I V V 1 tCufYITICI`i 1 I Yu W maxirnurn ha.•rvest efrecr of the proposed projerr is O.02 pet cent; an order of ouzo?iftide less Than 0.3 3 percent, based cjn.HBGS e7nrainmenr mcz rrah v of 94.1 hercc,•it- , This not only directs the public into falsely relying can a misleading definition of "significant unpact", it raises scrious questions about the-adl gaacy-cf,the S i3rpingement/cntrairnneilt study itself. For exarDple, the baseline of 127 MGD is a ruiii2:,T�!^ vJltladl'1Wal rate arltl tl6c'S 710i uCCllritely re�Iect -average cooling water intakes, nor projectediiicn aces in,coobn.g wav:r intalce volume after the addition of the desalination facility. Furthermore, the REIR should identify species killed in the process that do not have harvest controls and"take"is-prohibited. For instance,.there.is no atlowable fishery for Garibaldi. or Black Sea Bass. "Take"of these species is prohibited altogether and any t impact on these species viould be "signrfinant." Therefore, the REIR should not Ede ce.rued'unti} st incttae�es :re�aorcr�#� amd- defensible definition of"significant impact" on all species collected in Historical and current impingernent/entrainment studies.The- REMshould-aisotarot glxky. explain the-current population assessments for the species recorded in these studies and reconcile why some with already diminished populations may be reeor&d'in relatively low-rrrmbers:-Finaiiy,-the-REIRshoulid identify species killed in the intake that are protected under the Endangered Species �ct,,fishery management plan "take" reductions and-pruh-ibWens; —d-otVter-reguiatory_and.Leg slative protections_ Scope of Impacts As noted in F revious carmnients, the addition of a dcsadination,facility of"this size will create a clranraticncw�d=iaFA-o}i-ih--,T.iB.G.S__In_a.misleading ponclusion,the Rt?IR states that: "The oper�vuon of the desalination facility would not result in any changes to the permitted operations or in tlse"maxi:rmnx ERGS-intak-e-how-rate_•__'_'This reliance on "permitted flow rates" versus actual historical cooling water, intakes sets a misleading - baseline [roan which to compare projected:mpii��en7enzfentrasxe irpczs.. V The REIR is confusing in that in one instance, at Section 3-1 page?$;tlxe REIR-states-that "The..desatinatioti.facility.would not include a back-up generator. Emergency power would come from the electric power grid and/or.-FiBGS"acixiiiary reserve-bank.."This statement implies chat-the-encegy necessary to run the desalination facility under normal operating circumstances (i.e., not during"emergencies")would come directly.froi-i thie IdBGS, Con.sequerstly;�Fieb�seline� d-aueraee operation.s of the generators will 5urely increase to supply the necessary energy to run the'desalinati.on plant.It-is important to repeat here thlt the baseline-far t afvdlatirkg-rnai•ine li-fe-.mor�ycis-not:the.`.`permitted" ' withdrawal of 514 MGD,but the:actual historical withdrawal of cooling water. According io the.RELR,the desalination facility will"require approximately 30 to 35 tslebawatts,-.. As such,the daily energy consutnpti.or).of the facility is estimated to be 72l9 �� 9 i i to S40 mtzawatl hours per day." See: RBIR§ 5.4, page 13. The current average daily out put of the HBGS is not presented in the Rr7R.However—if the average daily cooling water intake flow rates are any indication,HBGS, between 2002 a«d Rly 2003, was only operating ",eneraturs ] and 2 orratverage; See: REM-y-4, page.?(average flow rate � equaled 265-MGD, with low flow rates at 127 MGD). If so,'on average,the HBGS is generating approximately 4301VIW: See: REIR:5 4 page 3 Gr-Y n-these.extrapolati oils, -.. �� the addition of the energy demand from the desalination facibiy Willincrease average operatna orap t of the Huntington AES fio7n 4367�1W'to 4�.sI�-_ -TY-in crease-Qf.. approximately S%. Nowhere in the REIR is there an:.alysis of how much additional � rater will be withdrawn from the ocean to meet this increase in daily eiectrital'' output at HBGS. Assuining the energy demand for-the-desalinatien.facilit*will be supplied by:€HBGS V under normal circumstances; the REIR fails to identify the resulting increases in on- site cooling water intakes and-associated-:mrirref:fe-n--wrta,litu-to-supply.the-energy... • i Alternatively, the REM iruiynonclude-that-the eneT-Ey- c;rand_farthe-desalination facility will be met under normal operating conditions by power from.the electrical grid. � In this case, some estimate of wTiat perceniage-afpower-on-t-lie-mid cogs dam facilati.es.. J using`bike through cooling"would Help decision makers better understand regional j impacts. In short,without some clarity of how the fdcility will meet-the-energy-demands of the massive desalination facility, it is impossible to adequately assess the associated marine life mortality. Therefore,the RUR fails to adequately inform the public of the impacts of the roject on marine life-mortality-u-atil-it-is-dear-bow.the:.ene Ty demandill w be met, r P (u One potential solution would be an.unequivocal and irreversible commitment to the source of energy— condition given the importance of this factual background for fully documenting foreseeable impacts to marine life. l " 3) New Regulations for Coolin Water Intakes Not Analyzed The REIR fails to includ.e.all.the relevant information currently available on marine life impacts,including the recently proinul Mted rules on cooling water iiztake structures [i.e- L Clean Water Act 316(bb 3-arid_d.recently completed imping_e-icnt and entrainment study for HBGS. W. t.t is uncertain how HBGS inteiads to comply with the-i,"ecently pronii:d sated Clean Water Act 316(b)regulatiaPs f6i cooliii.g water-intalces-on existing-power-plants drawingm.ore IF" than 50mgd ("Phase 11 regal:ations"). These new TC,,Ulatiorts on cooling water intake structures require dramatic reductions in marine life impi.-,=ent-($0=9-5%') anc-- entraininent (60790%). • I >r ,r l-- :� Gam!L f J LGG� 14.LL .71 U-UL j UULU i ��� 11 LI lv 11\VI11.1LI1 I IIVW Rele�ant.issues raised by the proinulgation of these new rules include: the land used fo-the footprint of the desalination facility-would-pr cclu6c the option of adopting closed-cycle codling for HBGS by di.sallowm-g use of the same land for cooli.17111 towers; reducing cooling water flows for ERGS. or. instaMitiou of alternative- w I tecJanologi es,.vlay other a1tel�at.ves to meet the performaace standards it.the new regulations. However, such mandated chmaocs may render hie desalination facility-economically at.practically inoperablewitliout coptinued iltse of the ocean water intake structure. Licensing of the From Using EPA's Preferred Technolop_,v The Phase H regulations specify closed-cycle cooling as the best technology available for minimizing adverse environmental impact. While the rule aIldtvs compliance-in-other wags that meet closed-cycle..performance standards, the EPA.expresses the preference for closed-cycle cooling. Ili fact,for new power, plants, closed-cycle cooling is essentially ' regLiired. However-;closed-Gycic_c-= ing.deinands available land for construction of cooling towers.Therefore,licensing of the desalination plant would likely foreclose the ase of closed-cycle plant_ Furthermore,the desalination facility's reliance on.HBGS's once-thzough cooling water will effccti.vely preclude the transition to claz;ad-cycle-cooli car f�xrce tl�e cantiaued use.. of the intake structure for desalination"source water"-- undermining the intent of the new regulations. - X By precludinb 0GS from employing closed-cycle cooling, or prolonging the use of the ocean water intake-structure.for.other purposes,.the desalination facility is effectively undermining the intent of the new 3I6(b) regulations. This foreseeable impact sbould be thoroughly d red itrt�e Rl If the Desallhation Plant-AttmTrDts-tcrC—gMnll-v,4h-the 3-1-6bLit---�'ons.by.n-ieans other than EP.A's preferred mcbnoloiTy, the viability of the desalination-plant is susvect. The Phase H regulations-provide compli,ahce alternatives other-titan the use of closed, . - cycle cooling.. For insfwec,the plant can reduce cooling Dows throLig11 reduced operations, install new teclmology,or perform a combination of thesato-comply with-the performance standards- However,.each of th-tse alternatives has consequences on either the total water available to the desalination plant or the electricity available to tonsumem- the desalination plant,-or-bola,,.. One potential HBGS-comph;ase-e-resp"s.e.wouEcLbLe_tQ.r-ed_uce the volume of intake water from the historical baseline. Assiimnng this response,the REIR is incomplete until it provides an areal}lsis'of` for.the reduction in cooling water art HBGS. More tmportantly,.ti,e:REIP should ducitment the marine life-mortality nssociated with this response_ + X rutire 31 Gb Re ruiations.Mav E-11minate the Viability of The Desalination Plant l�lto�ether. r The REIR indicates that, should the HBGS discontinue the use of the "once through cooling"syste,-.n, Poseidon would take over operations of�fic cooling wate7 in..take structure to supply water to the desalination facility. It;. lus sce::ario,all of the marine life Ar mortality from the 100 MGD-plus-withdrawal would be directly attributable to the y desalination facility. The draft plisse;I;II regulations,which would likely apply to th.e desalimition plant, would likely rernu.rc the sarne reductions in impingement and el'iTyau-unent front uacontrollcd-levels as the HBGS-plant must-m,eet_.The.M, R does not indicate how the desalination plant might meet these requirements should it need to draw water directly,f..rom the ocean. Missing Relevant Information It is our understanding that the California Energy Commission figs recently.released— 1 cone prehensive studyofthe marine life mortality rates at the HBGS. This "316(b) study" is currently available for public.mview,but has nui t been uzcluded in this REIR. It is also our understanding that there are-si.gnificautdiarences in the scope of the analysis and the relevant information.contained in,that study as compared to the study provided in the R.EIR. This is pet-tiaent'and-srbfrrifteatty in orm;ition f4r.the pU zlicatnd dur elected representatives to snake fully informed decisions. Absence of this information Z renders the REIR inadequate. Furthermore,the REIR does not summarize nor append copies oftlie recently adopted r Clean Water Act 316{b}aegulatioits.cont3'ollutQ the use of"cooling water intake j structures'for existing facilities, including the HBGS..Again,this is essential �- information for fully informingtltepnl}lu-of.tltescage.of innpacts related to this project proposal. I Conclusion In summary,the Phase II rem nations were the focus of a great deal of discussion during p'ubl.ic com.nient o. the original DEIR, and'should be treated as "significant;niftcant new information"in this RREIlt_-.B.cfoxe the HBGS dminonstrates how it will couzply with the j Phase II regulations, it is prcmature for the City of Huntington:Beach to license the as I desalination plant:-Purrthermare;relevant_.documett.tatiQn.of current impingement/entrainment is now available from.the California Energy Commission, and lkit information is criti.cal'to,a thorottgh-ttnderstandingaf tl apezaticzns ofHSGS.as.i ,. as well as predicted impacts from the co-Location of a massive desalination facility. Again,the absence of this pertiiien# fully_ informed decision and renders the RFUR finadequate. j - 1� I 4) End Users Not Identified and Consequently "Growth .Inducement" Analysis is Inadequate The REYR does not adequately identify the"end user" of the product water in a way that i.rfornis the pttbl:i.c-of the potential environment.-d impacts or a4lews in_fomied decisions. r"+s nwLed in die . watc*pollutiou.. in the SItITOtilldInPr IOn'I5 The:result o-f 7ltti l2?v^2i point source and non-point source loadirls. As mentioned above improved water P r P o P . conscrvatioii and wastew-ater reclamation can provide anew source of freshwater while simuhan.eously reducingpollution loading—IQr-example,.see the.Irvine Ranch Water District's "Residential Runoff Reduction(R3)"study—see: http:/l,..v%-w_irwd.com/click on"Cau.servation", then":Landscape.&.Agn cultural Irrigation", and finally_ "Conservation Research." Alternatively, an-overnight introduction of 501AGD into the water supply may.exacerbate current difficulties meeting evef-stricter water-quality regulations:This would-be.. especially true in areas of the region where intractable non-point source pollution has yet to be abated, and/or sewage trdatment facilities-are w4cr-capacity-forthe7resentwater a{,U supplied to the service area. The REiR sdems'to imply that the product water will simply be absorbed into the ri;g-ional water supply and offset projected deficits in imported water. These conclusions ` arc rot substantiated with-any-discreet demand-f--a,n.specific-.watur:agenc'LP-andoo wa.y. of disseminating the local environtn.ental consequences. For instance, if the water were destined for delivery To-the-Romcho_Misslon Vie area;il�e supply wc>ttki Ea se serious concerns about the resultant laud development— as well as the impacts on available sewage treatirent capacity and-the impact of a new source of water on olluret±ruuoff p . y � n into local strearris and the ocean. Similarly, if the water is destined for areas within the ' Oranbc County Sanitation District service area, and in particular the Santa Ana River watershed, similar E�n�eA�s V�i�l�be:cllSed-c n�C'TLi�T rPcnitinu deyPlnn_ mind the impact on sewer treatment capacity and urban runoff.,However, should the water be destined for an. area that7sahcady`tTuilt=out"anflEras addressed--predic7ted-sewage-- treatment capacity d.ernands and urban runoff problems• the impacts would be dramatically di fferent. In short,avoiding the documentation of the "end user" of this potential new source of'.water precludes.an.-anal;sis-dithe.`.`growth.inducement" aspects of the project, its well as the consequential water quality impacts_The absence of this significant information renders-the RE-IR-inadegnate- -As-.v sidesg-ter-it x-easanab-le.to_request_. this information and analysis-prior to certifying the REIN because, absent any . Commitment to take de I ivery-of-the water,-posfpaui�-tfre�zsisrn 9hauld-not-create-- any hardships on the project proponent. f 5)-Discha-rge of Cleaning Solution is Not.F afly. Identified.and Impact Analysis Inadequate On page 3-26, the EIR indicates that chemicals used to clear,the RO membranes would possibly be discliarged directly to the ocean iLsough the AES discharge conduit. Given ae , that a tnaj or. problem with operations of the Tarnlza Bay desalination plant r,evolved around filter clogging and tt e aecimulation of excess cleaning chemicals, this EIR should fiu•ly explore-the discharge of chtmic.als under.a".!orst.case"..scenario.— similar to the experiences of the Tampa Bay facility. '~ Furthermore, the predicted chemical concentrations of the membrane cl.eani.no solutions are teat directly compared toth� discharge requirements-applicable to-either the O.rang�, County Sanitation District or to the ocean duough the AES discharge conduit. In the case of Orange County Sanitation District;the appli cab le-discharge-requir=eizts-arc thei-r- industi7al pretreatment requirements, and for ocean discharge the applicable limits are those .f-ound in the California Ocean Plan(COPj: A cursory comparison of the COP--- limi.ts with val.ues-presei3.ted-in-Table-I4B of a-pi Pnc1ix K ofthe EIR.iadicates that ad concentrations of lead,mercury ai7d arsenic in.some of the cleaning solutions may exceed � Water quality obj-cctivesin-"Cab-b&af=tl7e COP: In conclusion,the REIRU ihade�quatein that it-dtors-trot--fYrElrin€ormdhe-pablie-o€-- r the "worst case scenario" of the volume of cleaning solution, and the foreseeable ianpaets from.the discharge of the cleaning solution. 6) No Cumulative Impacts Analysis of Energy Demand, Marine Life MortatiCy or,Growth-1 ftcefirent-. The REIR does not adequately inform the public; of the numerous d.esalua.ation proposals � na some stabe of plalinin�statev�idc or it7 the so the Cal araaa r� on_Eor.example,.izi southern California alone,there are proposals to build desalination.facilities in San ae Diego, Carlsbad; San'0mft-c,Dais.-Point;-Long B tat*ab.4-2-fawlities-itt-El-Segundo.., ", Some of these facilities are researching energy-saving alternatives and/or`source water" intakes that avoid marine life mortality. r Consequently, without a thorough understanding of the several desalination,proposals .currently being plar ned:-itis-kV,essible to--filly rinderstand-thcrumulativeimpacts.oa regional.Energy demand and the associated marine life mortality and other environmental impacts. Similarly, as noted bi the section Above on."Grovnh lndueenzcnt,-'the=does not allow a thorough consideration of cumulative impacts on gr.owdj inducement from the introduction.of multiple desalination facilities region-wide. NOT does it provide any a window into imderstandmg the-cuizz��lati���-i.rnpactsaris�wra�.treaiment capacity and' discharges, energy demand and assor-Jared environmental impacts, land use,traffic,etc— all potentially resulting-from n�tiltiple dsaliFatio�r Iacilities.aud the associated-growth__ induced by the introduction of new water to the region. r • 14 ,. L II Z007 14.LL FirtaJ_ly, the apparent "-first come—first serve"result of individual desalination.permit applicadons.to local jurisdictions precludes a thorough alternatives analysis that identifies � a sound approaches to providing desalination.in the region lit. �k manner that would g minami.ze the cumulative impacts Noted above. Absenf s region-wide des.tlimition planning policy,this R)EIR must matte a reasonable attempt to document the cutnul:SiiVe i�.apacts from—this and several.otinei. desalination facilities currently proposed in southern California. Also, the REIR cah , should compare the cumuintive impacts-from etzmp)crying-fhe-technology--proposed at this facility with the alternatives proposed by facilities like that being considered - and currently researched in Long Beach and'Dana Point. 7) Drinking Water Quality and Human Health Standards (Boron) The RE1R does not adequately address all the implications of the product water for Vuman consumption and the applicable health st.aridar4-spw_1:E1ca1Ly as.it.concerns.boron. conta.rai.natioll. A recent article on the subject concludes. "Reverse osinosis desalination has tremendous potential for a supply of ncnv-'Water-forthe21sr-centuzy; especiaDy in areas of the world, where water-is scarce or the quality is inadequate. lts widespread application. however, is han-mered by the fact that reverse osmosis desalination does not retaove boroil' sufficiently(only 60 percent).. As a result. desalination of seawater does not reduce the boron level below the new standard for drinldn_g water in the EdTopean Ui ion (and will be also problematic for the non-European Mediterranean countries adopting a similar drinkins water standard for boron). Therefore;.additional removal techniques must be a i j introduced in order--tabFing boron levels.dawnta.dri ikingstandards_' See:_ http://vY,4�r.ge(3iimes.org/ni iy04/feature boron.htnil Seawater contains about 4.5 mg/L boron. The. California Department of Health Services (CD.H.S) has established-an action level-of 1 ing/L and-the World-HealtlrOrganizativn (WHO).has a guideline of 0.5 mg/L. Thus,you need about 78%removal to bet to the CDHS li.mir turd aboui 99%removal to get to the VVKO'Duid-eIine. There is apparently ongoingrescar hJnto boron'rernoval technology an.d practices. For . instance, the Long Beach-Watzr.D zpartnzent(1.BVJL�s,,y 43-786/ is grange for boron removal. They also say "Boron rejection substantially deteriorates with warm water temperatures." See-sh es43—?7aF httn=l/vs�uw,l bwater.or�,/udi7grese citations/AC:EBoron2004.-pdf LBVIW',D is experimenting witir-a-2-stage RE)process-and--alas-ttied-adding-fluor_kle (unsuccessful.) and a base(sodium hydroxide)to raise the pH to improve boron.removal. This appears to be successful, but ii-adds to the cost an...d-requires subsequent-acid-additiorr- to bring the pH bac)<.down to.Deutral- 15 -- - r In. Conclusion, the REIR is inadequate in th<,t it does not fully inform the public or our representatives of the present difficulti.(S addressing bor..ou contamination, nor ' � the potential eavironmetital impacts.Furthermore, the REIR does not include a a i discussion of the on-going-research an n d possible-mitigatie -af-baron-camamin.ation, to levels considered riot sig.n.ifi.caot. 8) Public vs. Private Ownership 73 Alternate Owncrslup Alternative: Assuming that the environmental in aparts would be the same under either public yr private ovmm-sl-rip-ignores the-fttndamental-motive•and-• fiduciary.respornsibility underlying private ownership: private profit .Poseidon's foremost goals are to return profit to their investors and protect investor interests, whereas the purpose of a public desalination.plant would.be.to.provide a s-ustainable,-environmentally sound water supply with direct accountability to the public. Given.that water is a public r trust resource, governnaont ent'it1eS-5LMh.iLiU1L'1I111261101-nn nr annh (';tv LQinlcll should, give public ownership of a desalination.plant greater-weight and not weaken its public trust zespon.sibility by parnritting-tln eozzinzereiali�atto-trcr€tl}ts vi�resQurce. 5 r The Tampa Bay erperlerice tusderscores how private ownersYupafa-dim ination plant can weakest public accountability. The project changed hands tl2ree times acid the most r recent owner, Coventa Energy, finally declared banhruptey in order to avoid its contractual obligations_. 'Posen-don's-involyemcntin the-.Tampa Bay.pra1e_ct.doesnot.set.a good precedence for responsible public trust stewardship. aJ r The RE.1R also dismisses the potential concerns pertaining to international trade - agt-eements as irrelevant beeause 1?o-suidon i,$-txat an.is rn i al in stir nor should international trade .lave be evoked if regulation is uniform and non-discriminatory against 'f ,,foreign.investors. Intenrstironatradt=.ra.te�5uclr ar IdF:�'selrgterl t, ii=written-so--- broadly that international.investors_can.challcuge.any gpoverninent.action.that they might ... deem tantamount to expropriation or alight indirecrly discriminate against a foreign r usvestor. The Methaimx- _= utive_.ard&rbanning_.. M..T{3E is a good example of, in this case, a Carsadian investor claiming indirect discr-iminati.00- udin.g.expected future r profits. Tlte ease is being heard in a secretive NAFTA tLibunal where environmental concerns-have becai-blocked(petitions fderUiy.Eaarthinslic-e Lerral laefensr_Eundhave been repeatedly rejected, for example). Poseidon describes itself as a private water company tbat invests in water supply projects ' around the world. It is:not d=:salinadon-plant-is-snot, m.eetuag public expectations and'the public moves to seize the facility-through eminent cloinain,Poseidon.cotttd-usa-a-foreigrpartnertn fife aclaitn irr arritztcrrratian.a} ulvest)Df-mc court. Bechtel,a San Francisco based company, is currently suine, for S50 million in compensatio» foi"a pul.)lic-private partnership in B"oI"ivia thaa was terminated r under significantpublic this.c1airp_Lnldcr.a_hi teraLinvestrnent - treaty between the Dutch and Bolivian govertvnents, claitnin.g a small Dutch.suhsicl ary 1 6- r r-' 05/27/2005 14:22 310-629-GB20 ENVIRONMENT NOW PAGE 17 gave th.enl legal standing, The czLse is.currently uncitrway in.-'I;jghly secretive tribunal in- a branch of the World Bmak called the International Court .for the Settlement of l.nvesiment Disputes Cloarly earporlt�or_s u ith a b}elral reach are frrrdin;cl eatzve vFrays a to cirotunvent d.orncstic environmental laws. This threat can not be underestimated. CONCLUSION 1n conclusion,we want to again emphasize the importance of setting a`standard for C.EQA review of t.Ws and fume desalination facili.tiestharful:ly informs the public of- foreseeable enviroameraal impacts. This REIR falls far short ofineetim,that standard. We also want to incorporate by reference the.c.omments.submi2tcd-tayou.by.Heal the.. Bay and the PIanning an.d Conservation League. The southern Gilifomi_a region, like so many other areas of the state and nation, is facing intractable problems-of water-pollution; land-use pl-a aai-ng e y derrrar7cl;declirrirtg` coastal and inwine living resources, loss of coastal and marine habitat- amongst myriad considerati.oris implicated-by•tbe-dcvelapmenrofcfiesalirmtion,.facili.ties. Properplaimirzg for desalination facilities and other alternatives for meeting the increasing demand for fresh water in the region can either exacerbate these problems,.or' be a tool in.resolving i them. The REIR will be the basis for several considerations in the future—well beyond.the.. a�( ' jurisdiction of the City of Huntington Beach.for example, the REIR will, inform California Coastal.Comm ission.ca stal_de_vr1o�Pnt_pm=i$_decisiozis,.eta-Aaia. Regional Water Quality Control Board"Clean.Water Act"decisions(including the ocean water intake and-disc—barge-permit&-far the HE+3S);-California-EueYgy-Co,_L='sMcrr.-- pemvts,the Cafi.fomia Department.of Water Resources"California Water Plan':-several. Urban Water ManagerrccnrPlans etc.-WMT-dais i.n-mint-,-certification of the REIR- demands a rigorous and thorough review. For all the reasons stated above,.thc REIR fails to.meet the.mandate&.of.the-Cali-fomiia.. -- Environmental Quality Act. The inadequate approach to documenting the environmental impacts of the proposed:Huntingtan-P faeilAy°fai-ls to-fully mform- the'public of the foreseeable impacts of this project on"stand alone"basis, within the context-of cbangi'ngregt4atzvzzs-forthc cis. catcd-HBGa,-arrd-within trie context ofihd foreseeable cumulative-impacts of multiple desalination proposals. We therefore request that the REIR be re-circulated once a;ain with a more.thoroush documentation,and analysis oftlie' issues raised above. We are concerned that a traditional "Response.to..Con=ents" in..Snal�zrng.theRl LF_w_i-llbe insu�fficieit, Oncc again, titanic you-far.yottr considerat-fort af-these oammerAa.- 17 Seawater t r Des Project at Huntington Beach RESPONSES TO COMMENTS Desalination n o Project Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 15 Group of Private Organizations California Coastal Protection Network California Earthcorps Elkhorn Slough Coalition Friends of the Sea Otter Friends Artists and Neighbors of Elkhorn Slough Public Citizen San Diego Baykeeper Save Our Shores Save Our Waterfront Committee �. Sierra Club Southern California Watershed Alliance Surfrider Foundation The Ocean Conservancy 15a. This text provides an introduction to the comment letter and does not require a response. 15b. This text lists the co-authors of the comment letter and does not require a response. 15c. The commentator suggests that the purposes or objectives of the project have been too narrowly stated. As required under CEQA Guidelines section 15124(b), however, the project's objectives have been clearly'stated. The City is not required to adopt new or different project objectives suggested by the authors of this comment letter or any other person or entity. Also refer to Response 2g, above. As to the discussion of alternatives, refer to Response 22i, below. 15d. The project is not based "on a drought period" as suggested by the commentator. Refer to Response 19d, below. 15e. Refer to Response 20f and 22f, below. 15f. Comment noted. No response is necessary. 15g. Comment noted. No response is necessary. 15h. Pages 4-21 and 4-22 in Section 4.8 of the DREIR reference Figure 3-1, "Orange County Water Supply Sources," located at page 3-43 of the DREIR. "Water Use - Efficiency" (i.e. conservation) is recognized on the immediately preceding page of - the DREIR (page 3-42) in Table 3-4 as a reduction to water demands instead of as a "supply source." 15i. Comment noted. No response is necessary. 15j. This text provides a summary of the comments provided above and has been responded to accordingly. City of Huntington Beach August 17, 2005 179 - r Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS _ 15k. Refer to Response 2ag, above, and Response 19d, below. r 151. Refer to Response 20e, below. 15m. Comment noted. No response is necessary. r 15n. Refer to Responses 2t and 2af, above. \ 15o. The commentator criticizes the significance criteria used in the DREIR for considering potential impacts to marine life and characterizes the standards as "misleading." As explained on page 5.10-17 of the DREIR, "significance r thresholds for biological resources that are identified in Appendix G of the CEQA Guidelines are applicable primarily to terrestrial biological resources. With respect to marine biological resources, guidance in developing appropriate (- significance thresholds has been taken from the California Coastal Commission." The standards used in the DREIR are taken directly from recent (March 2004 and September 2004) Coastal Commission reports and are clearly set forth at pages 5.10-17 and 5.10-18 of the DREIR. Refer to Responses 15p through 15u, below. 15p. Comment noted. Also refer to Response 16f, below. 15q. Tidewater goby larvae, the only potentially entrainable rare and endangered species potentially occurring in the area of the HBGS intake were not collected in the desalination project's intake entrainment studies. California State Government Code 425.6 making the Garibaldi the state fish included protection for the adults from sport fisherman, particularly spear- gunners who found the species easy prey and because the populations were declining. The DREIR looks to the State of California for guidance on the population level significance of early life stage losses of entrained fish species and to regulatory law such as the ESA for establishment of allowable take. Relying on both the science and practice of population management and protection, the DREIR estimated proportional entrainment losses due to the project's seawater intake represent a de minimus effect. These entrainment effects would never rise to significance in a population of unharvested species and are far below the State's recommendation for managing fisheries for harvested species. 15r. Refer to Response 15q, above. 15s. The assessment of desalination facility entrainment effects is based on a flow volume of 127 MGD, the minimum HBGS minimum cooling flow configuration, even though this volume, which is approximately 20 MGD more than will be used by the proposed desalination facility, over estimates the level of the desalination facility intake effects. 15t. Refer to Response 15% above. r 15u. This text provides a summary of comments 15o through 15t provided above and has been responded to accordingly. City of Huntington Beach August 17, 2005 180 r Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS 15v. The desalination facility would receive its electricity from the state power grid. Refer to Response 2o, above. 15w. Refer to Response 1 g above. 15x. Comments regarding the ability of the generating station to comply with the requirements of 316(b) because the desalination facility will occupy adjacent property is speculative under CEQA and not relevant. If the commentator is interested in more information on the options available to the power plant for future compliance of 316(b), the commentator can read a recent CEC study on aging power plants where this subject was discussed in some detail (see "RESOURCE, RELIABILITY AND ENVIRONMENTAL CONCERNS OF AGING POWER PLANT OPERATIONS AND RETIREMENTS"; AUGUST 2004 100-04- 005D, California Energy Commission, Staff White Paper, pages 80 — 88). In ' addition, refer to Response 1g, above. It is also important to note that the proposed desalination facility is not subject to CWA Section 316(b) requirements. 15y. Refer to Response to 1 g, above. 15z. Refer to Response 2u, above. It should also be noted that the proposed project's feedwater withdrawal is not subject to intake regulation under the CWA Section 316(b). 15aa. This text provides a summary to comments 15w through 15z and has been responded to accordingly. 15ab. Refer to Response 2as, above. 15ac. The DREIR indicates two scenarios for disposal of the process chemicals used . for membrane cleaning: 1) disposal of the first flush of the cleaning chemicals (4,000 gallons — see page 5.10-37) to the sanitary sewer and blending of the remaining volume of flush water (87,000 gallons) with HBGS cooling water discharge and the concentrate from the desalination facility; and 2) disposal of the entire volume (91,000 gallons — see page 5.10-37) of cleaning chemicals generated to the HBGS cooling water discharge and the concentrate from the desalination facility prior to their discharge to the ocean. The preferred scenario is the first disposal method. As indicated on page 3-9 of the DREIR, the proposed seawater desalination facility will be equipped with a Washwater Tank, which would have capacity (200,000 gallons) capable of retaining the volume of first flush chemicals generated during membrane cleanings. Since the total number of membrane cleanings of all membranes needed annually is 26 under normal operational conditions and 52 under worst case scenario (long periods of red tides, rain events, etc.), the storage volume for the first-flush chemicals will be adequate to retain approximately one year of membrane cleaning water. Refer to Response 17d below. 15ad. Analysis of the chemical concentrations of the membrane cleaning solutions for compounds regulated by the California Ocean Plan and other applicable regulations was provided in Appendix K of the DREIR. The OCSD staff has been City of Huntington Beach August 17, 2005 181 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS contacted and asked to evaluate the information presented in Appendix K of the DREIR in order to establish if the discharge of the cleaning solution chemicals to the wastewater collection system is viable. The OCSD staff confirmed that this discharge is in compliance with their sewer system discharge requirements. The OCSD already accepts the same membrane cleaning chemicals used by other reverse osmosis membrane plants and is well familiar with their water quality. r As indicated on Page K-2, Appendix K of the DREIR, "most of the regulated compounds in the cleaning solution will already be below their detection and/or regulatory limits even before the cleaning solution is diluted with the desalination facility and HBGS discharges." Table 15B of Appendix K indicates the compounds that were determined to be above the detection limit — a limit below r their concentration can not be measured. All other parameters regulated by the Ocean Plan and other applicable regulations are below their detection limit. Please note, that the parameters shown in Table 15B represent only the , concentration of the cleaning solution before blending with the HBGS cooling water discharge and desalination concentrate. As indicated on page K-3, Appendix K of the DREIR, these levels will be further reduced significantly, with one or more orders of magnitude, when the discharge is further diluted in a 260:1 ratio with desalination facility concentrate, treated filter backwash water and , HBGS discharge prior to their combined discharge to the ocean. An example is the level of lead referenced in the question. As shown on Table 15B, the cleaning solution with highest level of lead contains 6.7 ug/L of lead. Because the discharge is intermittent (i.e. only two discharges of cleaning solution are planned per month), the applicable Ocean Plan Limits for lead are the daily maximum COP limits of 8 ug/L and the instantaneous maximum limit of II'! 20 ug/L. Comparison of the lead level in the worst-case cleaning solution and COP limits indicates that the cleaning solution is in compliance with the lead r limits, even before any dilution with power plant cooling water and desalination plant concentrate. If 91,000 gallons of cleaning solution that contains lead of 6.7 ug/L is diluted with 50,000,000 gallons of desalination plant concentrate that contains lead of less than 0.005 ug/L (see Table 15, Appendix K), the blended- concentration will be (6.7 ug/L x 91,000 gal + 0.005 ug/L x 50,000,000 gal)/(91,000.gal + 50,000,000) = 0.017 ug/L. As a result, the total desalination facility discharge will have a lead concentration of 0.017 ug/L, which are several orders of magnitude lower than the Ocean Plan Limits of 8 ug/L and 20 ug/L. This dilution does not even account for the additional reduction which will be r achieved when the desalination facility discharge is blended with the HBGS cooling water discharge. Similar concern was expressed regarding mercury. The daily maximum and the instantaneous maximum COP limits for mercury are 0.16 ug/L and 0.4 ug/L, respectively. As shown on Table 15B, the worst-case mercury concentration of the cleaning solution is 1.57 ug/L, while the desalination facility mercury concentrate mercury level is less than 0.001 ug/L. When 91,000 gallons of cleaning solution that contains mercury of 1.57 ug/L is blended with 50,000,000 gallons of concentrate of mercury level of less than 0.001 ug/L, the maximum level of mercury in the total desalination facility discharge will be: (1.57 ug/L x 91,000 gal + 0.001 ug/L x 50,000,000 gal)/(91,000 gal + 50,000,000) = 0.0039 City of Huntington Beach August 17, 2005 182 r Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS ug/L. Therefore, the discharge of the desalination facility will contain a mercury level which is over 40 times lower than the daily maximum mercury limit established by the COP. This concentration will be reduced further by blending the desalination facility discharge and HBGS cooling water discharge. The same conclusion is valid for arsenic. The daily maximum and the instantaneous maximum COP limits for arsenic are 32 ug/L and 80 ug/L, respectively. As shown on Table 15B, the worst-case arsenic concentration of the cleaning solution is less than 4000 ug/L, while the desalination facility mercury concentrate mercury level is less than 10 ug/L. When 91,000 gallons of cleaning solution that contains arsenic of level lower than 4,000 ug/L is blended with 50,000,000 gallons of concentrate of arsenic level of less than 10 ug/L, the maximum level of arsenic in the total desalination facility discharge will be: (4,000 ug/L x 91,000 gal + 10 ug/L x 50,000,000 gal)/ (91,000 gal + 50,000,000) = 17 ug/L. Therefore, the discharge of the desalination facility will contain an arsenic level which is lower than the daily maximum mercury limit established by the COP. As in the previous examples, this concentration will be reduced further by blending the desalination facility discharge and HBGS cooling water discharge. 15ae. An analysis of potential cumulative impacts due to multiple desalination facilities proposed within the Southern California Bight is provided in Section 6.0 of the DREIR, LONG-TERM IMPLICATIONS (beginning on page 6-18). 15af. An EIR must provide both "a detailed statement of growth inducing impacts" and an analysis of cumulative impacts contributed to by the project. This is distinguishable from an analysis of "cumulative impacts on growth inducement" referenced by the commentator. No further response is necessary. 15ag. Refer to Responses 15ad and 15ae, above. 15ah. This text provides a summary to comments 15ad through 15ag and has been responded to accordingly. 15ai. The proposed seawater desalination facility will be designed to produce potable water which will be in compliance with all regulatory requirements applicable to this project at this time, including with the boron "action level" established by the California Department of Health Services of 1 mg/L. The World Health Organization Guidelines do not have direct relevance to this project nor are they accepted as the governing water quality regulations in the US, and in many other developed countries in the world. For example, the European Union's drinking water quality limit for boron is 1 mg/l, while in Canada the boron standard is 5 mg/L. The applicant will use the newest state-of-the art commercially available seawater reverse osmosis membranes which are designed to reject boron at levels significantly higher than the "60%" removal efficiency for boron indicated in the question. The writer refers to the older generation seawater desalination membranes, or the widely publicized dual-stage nanofiltration system proposed by the City of Long Beach, which performance is indeed limited to the referenced boron removal efficiency range of 43 to 78%. The experimental "Long Beach" City of Huntington Beach August 17, 2005 183 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS dual nanofiltration system relies on using nanofiltration membranes that have order of magnitude larger membrane openings than the proven state-of-the-art reverse osmosis membranes proposed to be used at the proposed desalination facility at Huntington Beach. While using nano-membranes with larger openings supposedly allows to reduce energy use (which has not been proven to date), the dual nanofiltration system has a disadvantage — i.e., the nano-membranes allow more salts, including boron, to pass through the membranes and contaminate the product water. In order to address this issue, Long Beach staff has tried to use chemicals to increase the size of the boron molecules and thereby to remove more boron from the seawater. We agree with the conclusion of the referenced internet site that the use of such chemicals would increase the overall cost of water treatment. Since the reverse osmosis membranes have an order of �- magnitude smaller membrane openings they are much more effective in removing boron and other contaminants. The newest generation seawater reverse osmosis membranes planned to be used at the Huntington Beach seawater desalination facility have boron removal efficiency of 85 to 88% and would produce fresh water that consistently meets the boron product water quality action level requirement of 1 mg/L using a single- stage membrane reverse osmosis system. As indicated in project's product water quality specifications (page 5.11-10 of the DREIR), the proposed seawater desalination facility is projected to produce potable water in which boron concentration would be in a range of 0.6 to 0.8 mg/I. At a typical seawater boron level of 4.5 mg/I and rejection efficiency of 85%, the boron concentration in the product water is projected to be 0.68 mg/L. The high boron removal efficiency of the proposed reverse osmosis membranes has been tested and proven at Poseidon Resources' seawater desalination demonstration plant located in Carlsbad, California. This plant uses the same single-stage seawater reverse osmosis membrane system configuration as that proposed for the Huntington Beach seawater desalination facility. The Poseidon demonstration plant has been in operation for over two years and has been producing high-quality desalinated water using warm power plant condenser seawater of similar quality as that of the Huntington Beach seawater desalination facility. This demonstration plant uses the newest generation of high boron- rejection seawater desalination membranes which allow it to consistently produce potable water of boron levels below 1 mg/L, and to comply with all applicable product water quality requirements. r If the applicable regulations change in the future and more stringent boron limit is introduced, than the reverse osmosis desalination system will be upgraded as necessary to accommodate these limits. Please note that the boron removal experience in the non-European Mediterranean countries referenced in the question is not directly applicable to the site specific conditions of the Huntington Beach project. The Mediterranean seawater has higher salinity than the Pacific Ocean along the California coast (40,000 mg/L vs. 33,500 mg/L). Similarly, boron concentration of the Mediterranean seawater is higher than that of the Pacific Ocean seawater as well — 6 to 8 mg/L vs. 4 to 4.5 mg/L. Therefore, additional removal techniques are City of Huntington Beach August 17, 2005 184 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS t water below 1 m /L when desalinating often required to obtain a er of boron levels be o g e g Mediterranean seawater as compared to treating Pacific Ocean water. 15aj. The profitability of the proposed project does not alter the environmental requirements that the project will be required to meet. Also refer to Response 2aq, above. 15ak. These paragraphs provide a conclusion to the comment letter and do not require a response. As comment letters from Heal the Bay and the Planning and Conservation League are incorporated by reference into this comment letter, refer to Responses 16 and 20, below. City of Huntington Beach August 17, 2005 185 -i{}�► 3220 Nebraska Avenue ph 310 453 0395 info@healthebay.org COMMENT 1 the Bay Santa Monica CA 90404 fax 310 453 7927 www.healthebay.org �ltv o1 Huntinglon Beach - MAY 312005 . May 27, 2005 Mr. Ricky Ramos City of Huntington Beach Planning Department 2000 Main St. Huntington Beach, CA 92648 - RE: Comments on April 2005 Draft Recirculated Environmental Impact Report No. 00-02 for the Seawater Desalination Project at Huntington Beach .� Dear Mr. Ramos, Heal the Bay is a nonprofit environmental organization with over 10,000 members dedicated to making the waters of Southern California clean and healthy for marine life and people. We have been actively coordinating with the environmental representatives of the State's Desalination Task Force and we currently participate in the 316(b) working group led by the Los Angeles Regional Water Quality.Control Board. We have reviewed the April 2005 Draft Recirculated Environmental Impact Report No. 00-02 for the Seawater Desalination Project at Huntington Beach (dRE1R) and have numerous concerns. Specifically, we find the dREIR fails to assess all potential environmental impacts of a the proposed facility nor does it thoroughly evaluate alternatives to the proposed project as required by the California Environmental Quality Act (CEQA). The project applicant has not completed the necessary analyses nor provided the information necessary to enable responsible agencies and the public to determine the full range of environmental impacts, especially those relating to the impingement and entrainment of marine species. Our specific comments are summarized below: 1. Huntington Beach Generating Station's (HBGS) compliance with 316(b) should be. determined prior to approval of a co-located desalination facility Cooling water intake structures operated by the electric utility industry are "[t]he single largest predators of our Nation's waters."1 Noting the tremendous negative environmental impact of once-through cooling systems, the U.S. Court of Appeals for the Second Circuit recently upheld b the United States Environmental Protection Agencies (USEPA)regulation mandating closed- cycle cooling as the national minimum technology for new power plants and factories, while striking down a provision that would have sanctioned inferior technology and attempts to replace damaged resources:? .When applied to existing facilities,the USEPA has.established stringent 'May,i-R.,and van Rossu i,M.K."The Quick and the Dead: Fish Entrainment Entrapment, and the Application of Section 316(b)of the Clean Water Act."20 Vermont Law Review 376(1995). z Riverkeeper vs.U.S.Environmental Protection Agency,No.02-4005 (2nd Cir.Feb.3,2004). 1 µj} ► 3220 Nebraska Avenue ph 310 453 0395 info@healthebay.org the Bay Santa Monica CA 90404 fax 310 453 7927 www.healthebay.org new regulations under section 316(b) of the Clean Water Act that are intended to dramatically decrease impacts to the marine environment by establishing performance standards that are projected to reduce impingement mortality by 80 to 95% and entrainment by 60 to 90%.3 Unfortunately, co-locating the proposed project with the HBGS would effectively preclude the implementation of the preferred compliance option, closed-cycle cooling. Not only would the proposed project result in a direct, permanent use for the cooling water, the structural footprint of the proposed project would occupy valuable space that could be utilized for the implementation of an alternative cooling technology. Rather then convert to closed-cycle cooling, the HBGS may opt to achieve compliance through one of the various other compliance options, the simplest of which would be a reduction of intake flow commensurate with required entrainment reductions. This option would serve to,both reduce the amount of cooling water flowing through the facility and the amount of electricity produced by the plant. There are no analyses in the dRE]R as to how either of these, or other, compliance options would b affect the operation of the proposed facility and what the subsequent impact might be on the marine environment. The dREIR makes the assumption that the HBGS will continue to use once-through cooling for the duration of the projected life of the proposed project. This assumption, however, is not binding to BBGS which is free to pursue any compliance option available, either immediately, or in the future, if new more efficient cost effective closed-cycle cooling technologies become available. Without having a detailed understanding of how the HBGS will comply with the new Phase H 316(b) regulations,the applicant cannot simply assume that they can dovetail the proposed project on the existing cooling system. Not only will the proposed project preclude the ability of the HBGS to pursue the preferred compliance option under Phase II 316(b) but would"[p]rovide a justification for the continued use of once-through cooling technology...a technology [that] has well documented environmental impacts, including impacts on marine organisms."4 In addition, the California Coastal Commission has recognized the possible environmental impact of linkin� a drinking water supply with an "out-of-date" and environmentally harmful cooling technique. Finally, we would like to make it very clear that the proposed project, or any other proposed co- located desalination facility, should in no way be used by a power generating facility as an excuse to get out of 316(b)requirements to reduce the marine impacts of impingement and C entrainment. 3"National Pollutant Discharge Elimination System—Final Regulations to Establish Requirements for Cooling Water Intake Structure at Phase II Existing Facilities;Final Rule."Federal Register 40 CFR Parts 9, 122 et al.,July 9,2004. 4 Department of Water Resources: "Water Desalination:Findings and Recommendations."October 2003. Recommendation 30,p.5. 5 Seawater Desalination and the California Coastal Act.California Coastal Commission.March 2004.p.79. 2 r 3220 Nebraska Avenue ph 310 453 0395 info@healthebay.org the Bay Santa Monica CA 90404 fax 310 453 7927 www.healthebay.org 2. The dREIR does not use current impingement and entrainment data In May 2001,in the midst of the California energy crisis, the California Energy Commission approved the Application for Certification for the Huntington Beach Generating Station Retool Project. As a condition of the certification (BIO-3), the applicant of the permit was required to conduct a year long impingement and entrainment study to assess actual losses due to the cooling 6 water intake system of the power generating facility. The sampling for this study was conducted from September 2003 through August 2004 and the Final Entrainment and Impingement Study was released in April 2005.7 Although this study did not come out until after the dREIR was prepared,the data most certainly could have been made available during the d year long data collection process. For some reason, these data were not utilized for the analyses included in the dREIR. Consequently, there are several major discrepancies between the calculated impingement and entrainment (UE) estimates between the two documents. For example, the dREIR states that"Species with high commercial and recreational importance, such as California halibut and rockfishes, were shown to be very uncommon in the BBGS intake flows." (p. T-7) This is not supported by the results of the recent I/E study that estimated 5,021,168 California halibut larvae and 54,349,017 northern anchovy larvae were entrained annually by HGBS flows. These mortality levels were calculated to be equivalent to an area of production foregone of,0.386 and 4.472 km2 for each species,respectively.$ The source water calculations used in the dREIR were also flawed. The dREIR inaccurately characterizes the source water as the entire Southern California Bight. (T-23) The recent I/E study required by the Energy Commission more appropriately based its source water volumes on the area of water that could be drawn into the intake affecting target species. This was calculated e as function of average current speed and direction and larval duration. This approach resulted in a much smaller source water volume which provided a more accurate assessment of entrainment impacts. Even if the dREIR did use the new study to estimate I/E mortality, the methodology used to determine the"significance" of the impact would have to be adjusted. The dREIR relies on misleading standards for determining "significance"of impacts to marine life. The dREIR, concludes that, "Impacts due to operation of the proposed desalination facility in regards to impingement and entrainment are not anticipated to be significant." (p. 41) This conclusion is f based in part on reliance on the harvest control rule adopted in the Nearshore Fishery Management Plan, a rule designed to manage active fisheries, and is not a rule used to determine the significance of a seawater intake. The harvest control rule is designed to regulate the sustainable harvest of specific-species and is not intended to apply to non-harvested species of ecological concern or importance, which is at issue in this case. 6 California Energy Commission.Huntington Beach Generating Station Retool Project,Commission Decision. 00- AFC-13.May 2001. 7 MBC Applied Environmental Sciences and Tenera Environmental. AES Huntington Beach L.L.C. Generating Station Entrainment and Impingement Study,Final Report April 2005.AES Huntington Beach L.L.C.and California Energy Commission. s Id.at 157 3 gEl 3220 Nebraska Avenue ph 310 453 0395 info@healthebay.org Santa Monica CA 90404 f2x310 453 7927 www.healthebay.org _1 A more appropriate entrainment and impingement assessment approach would be to use the area of production foregone to determine the significance of the impact. The area of production foregone relates to the estimated area of marine habitat required to produce the number of larvae of a given species entrained in the cooling water flow. As stated above,the Energy Commission gr study calculated an area of production forgone as large as 4.5 km2 for the northern anchovy, an area that could most certainly be considered significant. - 3. The dREIR inappropriately dismisses the use of alternative intake technologies The dREIR is quick to point out, without any reference,that a co-located system is the most environmentafly sound option. The use of alternative intake designs, such as sub-Soaface intakes are dismissed because they are purportedly not recognized by the EPA as Best Technology _. Available (BTA) under 316(b).(p. T-12) This is yet another example of the numerous instances when the dREIR selectively cites portions of a document or a decision to advocate for the proposed project. As stated previously, the preferred option for compliance under 316(b) is the conversion of the facility to closed-cycle cooling, an option that would preclude the co-location of the proposed project. The new 316(b)regulations are structured around performance based standards with BTA only to be used in conjunction with a comprehensive demonstration study in one of the 5 compliance options. Sub-surface intakes, such as beach wells or infiltration galleries, could most certainly be employed by the HBGS to meet 316(b)requirements if found to be technologically feasible. The dREIR erroneously dismisses the use of alternative intakes for cooling water flow, yet fails to mention that they may be feasible for the proposed project, or a scaled down version of the proposed project. The application of alternative intake technologies are currently being explored by several grants administered under Proposition 50. Several small scale desalination facilities currently utilize subsurface intakes and elsewhere in the world they provide up to 25 MGD.9 In addition, the California Coastal Commission clearly states that, "jf]acilities proposing to co- locate should not presume that use of the cooling system is the best available alternative, but should conduct the necessary feasibility study to determine whether subsurface intakes would work in the area.s10 I The dREIR is wholly inadequate by its omission of a thorough analysis of the feasibility of alternative intakes as both a co-located facility as well as a stand alone facility. A. The dREIR fails to assess impacts of the proposed project as it would operate independently of the IBGS To meet CEQA requirements,the dREIR must thoroughly assess the impacts of the proposed project as it would operate independently of the B3GS as well as one that work in conjunction ! 9 CCC.Seawater Desal.p.71 r io Id. at 81 4 3220 Nebraska Avenue ph 310 453 0395 info@healtheba _or t Santa Monica CA 90404 fax 310 453 7927 www.healthebay.org th.98Bay with the plant. This would more accurately reflect the way the proposed project is likely to operate during its useful life and would better reflect CEQA requirements to address likely impacts. It is neither reasonable nor likely to expect the HBGS to operate at the stated "reasonable worst-case scenario"minimum capacity of 127 MGD, 24 hours a day 365 days a year. There is a high degree of likelihood that the HBGS would use far less than 127 MGD during periods of plant maintenance, licat treatments, times of low power demand, or due to compliance with 316(b) regulations. In addition, should the HBGS permanently discontinue its use of once through cooling, the proposed project would be responsible for all impacts associated with the 100 MGD plus withdrawal of seawater. In either scenario, the dREIR demonstrably fails to evaluate, yet alone acknowledge, these likely,direct impacts to the,.manne environment•due to.both I/E and j discharge of hypersaline brine that has not been diluted due to mixing with the power plant effluent. 5. The dREIR fails to state how energy demands of the proposed project will be met The dREIR clearly states that the proposed facility will require a tremendous amount of electricity to operate. Unfortunately, the dREIR fails to state where this energy will be obtained, leaving a tremendous hole in the impact analysis. It can reasonably be assumed that for cost and power efficiency the co-located HBGS would be the source of electricity for the proposed project. If this were to be the case, than a detailed analysis of historical and current operational output of the facility would be required to determine the increased electrical generation capacity �( required to meet the needs of the proposed project. The increased use of water associated with this increased production would be directly linked to the proposed project and thus must be - assessed as part of the CEQA process. The only way these analyses could be excluded from the CEQA process would be if the proposed project was prohibited from receiving power from the HBGS. Closing In conclusion, Heal the Bay strongly recommends that significantly.more analyses be completed and another draft EIR be released for public review and comment. We find the dREIR to be wholly inadequate in its assessment of the potential impacts to marine life and likely operating scenarios of the proposed project. We find that the dREIR is misleading in that it fails to provide references to support many assumptions, does not utilize current I/E data, and selectively cites specific sections of references to advocate for the proposed project. This document does not provide an unbiased assessment of potential project impacts and thus, falls far short of CEQA requirements. Given that this is the first of many future projects concerning desalination in the and climate of Southern California, we feel the this EIR is obligated to set a precedent to ensure all future desalination projects are held to the highest environmental standards. As currently written, this 5 � gth,-Et.y 3220 Nebraska Avenue ph 310 453 0395 info@healthebay.org Santa Monica CA 90404 fax 310 453 7927 www.healthebay.org EIR sets a poor precedent and allows for the continued degradation of our precious marine P � resources. Thank you for the opportunity to comment on the dREIR.-Please call us at 310-453-0395 if you have any questions about Heal the Bay's comments. 1 Sincerely, /g Shuman, D. Env. Mark Gold, D. E v. Staff Scientist Executive Director " S - I 6 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 16 Heal the Bay Craig Shuman, Staff Scientist, and Mark Gold, Executive Director 16a. These paragraphs provide an introduction to the comment letter and do not require a response. 16b. Refer to Response 1g, above. 16c. Comment noted. The proposed project would not alter the HBGS' permit requirements (including CWA Section 316[b]) in any way. 16d. Refer to Response 2u, above. 16e. Refer to Response 2u, above. 16f. The significance of impacts was analyzed in several ways including comparing the proportional mortality estimates with harvest control levels from the Nearshore Fishery Management Plan. The levels from the Nearshore Fishery Management Plan are relevant because they were established to provide protection to exploited species and would by nature be overprotective of non- exploited species. These levels would also be conservative when used with larval populations in order to account for any mechanisms that may act to compensate for the small levels of additional larval mortality resulting from operation of the desalination facility. In addition, refer to Response to 15o, above. 16g. Refer to Response 2u, above. 16h. Refer to Response 2y, above. 16i. Refer to Response 1 g, above. 16j. Refer to Response 1 g, above. 16k. Refer to Response 2o, above. In addition, refer to Appendix Q of the DREIR. 161. This text provides a conclusion to the comment letter and does not require a response. City of Huntington Beach August 17, 2005 192 COMMENT 17 HUNTINGTON BEACH TOMORROW "Making a difference today for Huntington Beach tomorrow" P.O. BOX 865, HUNT INGTON BEACH, CA 92648 _ PHONE: (714) 840-4015 E-MAIL: INFOgHBTOMORROW.ORG www.hbtoftiorrow.org May 27, 2005 "R� Huntington Beach City Council �. 2000 Main Street MAY 2 7 Z005 Huntington Beach, California 92648 Subject: EIR Comments, Poseidon Draft Environmental Impact Report Huntington Beach Tomorrow appreciates the opportunity to comment on the Poseidon Draft EIR. HBT has reviewed the document and finds information missing and a insufficiencies in the proposal. HBT believes this new draft of the Poseidon EIR, as before, does not meet the standard necessary for approval. • The DEIR does not discuss the viability of other methods of water generation as alternatives to the Poseidon facility. These alternatives include expanded b residential and commercial conservation efforts, agricultural conservation, water recycling, and groundwater and beach well desalination. • It does not include a comparison of the environmental impacts and efficiencies of� C production of Poseidon's proposed desalination plan to alternative methods. Desalination by reverse osmosis (RO) has not been proven practical at this scale anywhere in the country. Most existing RO plants, such as in Carlsbad, California, are a fraction of the size of the proposed Poseidon plant and therefore cannot be used as a true comparison of its. functionality and impacts. Since the only other plant near to the size of the proposed Poseidon plant is the recently completed d Tampa, Florida facility, its major operational difficulties and deficiencies and cost overruns should be evaluated to assess what environmental impacts they have caused. What environmental impacts has the Tampa project created? And how do they apply to this project? There are still no specifics in this DEIR stating who will be the actual recipient off e the water generated by Poseidon. J • The DEIR does not specify what measures Poseidon will take to ensure its claim that production will be used to meet existing needs rather than acting as a catalyst f of more growth in Orange County. • The DEIR states that since Poseidon uses AES' ocean water intake, there-should be no new restrictions on that intake, such as improvements to AES' high level of impingement. If this were approved: o How would limiting restrictions to improvements affect currently required impingement studies, i.e. as part of AES' retooling of Units 3 and 4? o What effect would limiting restrictions to improvements have on requiring g AES to modify the intake to meet current standards? o What effect would limiting restrictions to improvements have on requiring AES to update its facilities to comply with future standards? 1 The DEIR states that if h A• the 1=S plant were to cease to operate, Poseidon would reserve the right to keep AES' ocean water intake tines, discharge lines, and main ocean water pumps. The DEIR doesn't disclose where these pumps would be located. The DEIR doesn't delineate a process of conversion to a completely self- contained Poseidon. Where would the pumps be located? What would the process h be to convert to a Poseidon-only facility? What agency would have jurisdiction over the regulation of the facility under those circumstances? The DEIR should discuss these issues in detail. • The DEIR states that in some cases process water (water involved in cleaning of the system) would be allowed to go back into the ocean without treatment. Under what circumstances would untreated process water be allowed to go back into the ocean? flow often would this happen? Why should this be allowed? s • For safety of adjacent residents, the I,000-gallon ammonia tank located outside on the'plant grounds should be located in a structure so that if a catastrophic failure of the tank were to occur for whatever reason, the resulting ammonia leak could be J. contained. • The DEIR fails to address impacts on the OCSD systems. What effects will the additional load from this plant°have on OC-SD systems, especially in terms of-how it will affect OCSD's ability to handle dry-weather runoff treatment? What long-term k damaging -effects will-the chemicals in the discharge from the plant have on OCSD pipelines and/or plant? r• The DEIR gives conflicting information about the plant's operating hours. In some portions, it talks about it running primarily. at night to take advantage of cheaper energy, but in other portions, it talks about how the plant. will run 24/7. Why is there a-contradiction? What will the-hours of-operation be? While there are numerous other areas of concern, HBT submits that these issues and unanswered questions alone are sufficient to deny certification of this draft of the EIR l� and to require further development of the EIR to-satisfy the aforementioned _concerns. m fiBT 'recommends the EIR not 'be certified unless favorabie. answers to these r questions can be provided. Very truly yours, EEU Tl ON BEACH TOMORROW David Presi Cc: . Mr. Ricky Ramos, Planning Department, Huntington Beach r 7 a'R' 4Af I. Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 17 Huntington Beach Tomorrow David Guido, President 17a. This text provides an introduction to the comment letter and does not require:,a response. 17b. A discussion of alternative water supplies for Orange County is provided in Section 7.0, ALTERNATIVES, of the DREIR. 17c. Refer to Response 17b, above. 17d. A comparison of the Tampa Bay desalination facility's environmental impacts to the proposed project is not applicable due to substantially different environmental variables. However, as stated within Appendix X of the DREIR, DESALINATION FACILITIES THROUGHOUT THE WORLD, seawater desalination facilities operate in over 120 countries worldwide, primarily in the Middle East and Mediterranean. 10 large-scale production facilities (the smallest being 9.2 MGD and as high as 32 MGD) have been constructed within the past 10 years. Worldwide, seawater desalination facilities produce over 3.5 billion gallons of potable water per day. 17e. Comment noted. No response is necessary. 17f. Section 6.0, LONG-TERM IMPLICATIONS, of the DREIR provides information regarding population and housing projections for Orange County. ' Seawater desalination has been identified as a future water supply in both MWD's and MWDOC's UWMP's to accommodate growth in the County. No measures are necessary to ensure that the project would not result in adverse growth-inducing impacts. In addition, refer to Response to 2as, above. 17g. Refer to Response.1g, above. Note that the project would not result in any impingement impacts, since organisms would not be exposed to screening (beyond what already occurs at the HBGS intake) at the desalination facility. 17h: Refer to Response 1 g, above. 17i. Under no circumstances would untreated process water (referred to as "spent cleaning solution" at page 3-26 of the DREIR), be allowed to go back to the ocean. As indicated in the DREIR, page 3-26, under all discharge scenarios, this process water will -be "directed to a designated 300,000-gallon storage tank (wash water tank)for mixing and treatment". 17j. As indicated on page 5.8-8 of the DREIR, "Ammonia would be delivered and stored in liquid form and would be stored in a 1,000 gallon tank with 110-percent spill containment structure". The liquid ammonia storage system would be a double containment system. The liquid ammonia tank would be located inside a second containment tank that has a volume to retain 110% of the volume of the liquid ammonia storage tank. in the unlikely event of liquid ammonia tank rupture City of Huntington Beach August 17, 2005 195 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS or leak, the spilled ammonia solution will be contained in the secondary containment tank. This liquid ammonia containment system will allow for retention of the ammonia at the facility site under any circumstances, and thereby provide effective protection of the neighboring community from chemical spills. Similar double-containment systems are provided for all chemicals which are planned to be stored at the desalination facility site. The chemical storage protocol is currently used for most water treatment facilities. 17k. The impact of the desalination facility operations on the OCSD system will be minimal. The only two waste streams proposed to be directed to the sewer during dry-weather.conditions are the treated first rinse water from the membrane cleaning and the sanitary waste generated at the facility. The discharge of project wastewater will have no measurable impact on the ability of the OCSD treatment plant capacity to accept and treat dry weather diversion quantities because of the limited volume and frequency of the desalination facility discharge. As indicated on page 5.10-36 of the DREIR, only the "first rinse" of membrane cleaning solution is proposed to be discharged into the local sanitary sewer for further treatment at the OCSD regional wastewater treatment facility. Review of Table 5.10-8, page 5.10-37 of the DREIR indicates that the,volume of the first rinse (referred to as "concentrated waste cleaning solution" is only 4,000 gallons per membrane unit cleaning (i.e., 8,000 gallons per month, taking under consideration that an average of two membrane units are planned to be cleaned each month). Discharge of 8,000 gallons of wastewater per month to the OCSD treatment plant that is designed to treat over 14.4 billion gallons of wastewater per month (480 MGD) will have no measurable impact on plant capacity, operations or ability to receive any other flows. Because of the small volume of this discharge as compared to the capacity of the nearby sanitary sewer, the effect of this volume on the sewer's hydraulic capacity C will be negligible. Capacity availability was confirmed with the OCSD staff. The discharge of process water to the sanitary sewer is not going to have any short or long term damaging effects on the OCSD sewer system. As indicated on page 3-26, of the DREIR, the concentration of the chemicals in the discharge will be so low that they could meet the Regional Water Quality Control Board's Ocean Plan and could be safely discharged to the ocean. In addition, discussion t. with OCSD staff indicates that the discharge of similar process water generated during membrane cleaning is already practiced by other membrane treatment ` plants discharging to the OCSD collection system and these discharges have not resulted in any damages of the sewer system or the OCSD treatment facilities. I' The desalination facility will have only 18 employees. The sanitary sewer generated from the facility is insignificant. 171. Refer to Response 2n, above. City of Huntington Beach August 17, 2005 196 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS 17m. This text provides a conclusion to the comment letter and does not require a response. _ i 1 . 1 - i 1 - t - - City of Huntington Beach August 17, 2005 197 COMMENT 18 t COASTKIEEPHR EDUCATION/ADVOCACY/RESTORATION/ENFORCEMENT 441 Old Newport Blvd., Suire 103 Newport Beach, CA 92663 949.723.5424 Voice 949.675.7091 Fax www.coastkeeper.org May 26th, 2005 CR V'E N Ricky Ramos Planning Department City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 RE: Comments on the DREIR for the Seawater Desalination Project at Huntington Beach. Dear Mr. Ramos: Orange County Coastkeeper is a non-profit organization with a mission to protect and preserve the marine habitats and watersheds of Orange County through education, restoration, policy advocacy, and enforcement. In our previous comment letter regarding the Seawater Desalination Project Draft ER we discussed issues that,needed to be addressed to complete the DER. During our subsequent review of the Re-circulated EIR 8 and our own research on the potential impacts the proposed project; we would like to submit the following additional comments. 1. The report states that the first rinse water from the filter cleaning process will be discharged to the OCSD for treatment. This water will have a high salt content that has the potential for damage to the bacteria treatment stage (secondary treatment) at OCSD. The report should include a discussion of how this water could impact the OCSD secondary treatment process. If dilution is the solution to this high salinity byproduct,where will the dilution water come from and how much will be required?-In addition, the report states that if the first rinse cannot be sent to OCSD for treatment, it can be flushed into the ocean where, with -dilution,.it would meet MOST water quality.standards. It must be explained what conditions would require flushing directly to the ocean and also to describe which water quality standards might not be met, to what degree, and how often this might occur. 2. The R-EIR indicates the project will generate upwards of 500 000 gallons of P J 9 P "second rinse"wastewater that will be discharged to the Orange County C Sanitation District for treatment. Presently OCSD is accepting diverted dry r i weather surface runoff for treatment to reduce the effects of bacteria in the runoff on the water quality at the beaches in Huntington Beach and other cities. OCSD has indicated that current diversion quantities are limited due to treatment capacity limitations. We are concerned that large quantities of project wastewater may result in a reduced diversion capacity to continue present dry C weather diversions or limit additional future diversions to the sanitation district. We believe that the R-ER should address this issue and provide information describing how the discharge of project wastewater could impact treatment of dry weather diversion quantities. r- - r 3. Although the project includes measures to minimize environmental damage, L there is no discussion of what mitigation offsets would be included due to long- - term environmental impacts. The R-EIR should include a discussion of how these potential long-term impacts will be monitored so that they can be d quantified and what mitigation offsets would be provided. The project should ) include long-term monitoring of marine impacts and assurance that all adverse impacts will be mitigated. 1 4. The report states that fish species currently inhabiting the area (feeding at the outlet pipe discharge) will simply avoid the area due to the higher salinity thereby avoiding harm. The result is that fish will be displaced from the outfall site resulting in an area along the beach with fewer fish. This will result in a e significant reduction of shoreline recreational fishing in the area. The report should discuss impacts to shoreline recreational fishing. 5. The report states that the elevated level of iron in the discharge water will be lr beneficial to plankton. There should also be a discussion of the potential impacts of iron on the occurrence of red tides that are common in this area. Also, in a f different discussion it is mentioned that plankton will be affected by the higher salinity. If there are any negative impacts to the plankton, the discharge should J� not be considered a nutrient. 1 . 6. The plan states the project is necessary to meet expected regional water i demands for the future: Future water demand and supply in Orange County is Widely disputed. OCSD and the OCWD have recently started construction on the Ground Water Replenishment System (GWRS) and each water agency in the region is aggressively pushing conservation and recycling. There is the potential g for greater conservation utilizing new technology and greater public awareness. As the cost of water increases to the point where the water from this plant becomes economically viable, the demand for new water due to consumer r- conservation, utilization of new technologies, and reclamation will potentially reduce, especially given the real cost in producing desalination water. Though water costs will continually increase, considering the cost of imported water, the r cost of pumping water from wells and the aquifer, and even the cost of highly treated water from GWRS, it appears the real cost of desalination water from this project will be the most expensive water. There are many alternative models 1 and combinations of water sources in the near future. Granted we agree with the report that desalination water will be a necessary source of water in the future comprising-up to 10-15% of our water supply. However, we would like to have g the R-EIR address at what point in the future desalination will actually be a needed source of water and be economically viable. 7. In Southern California currently Poseidon is locating desalination.,plants for entitlement solely based on the existing location of a power plant's cooling system—not on criteria such as areas of most future need or existing pipeline '-i.-'L-.•i: -+-.. 1n/t,�i• t4, ..r•�.rr.,�I f+i.. imn of Inr=+-inn i-F1nc� Ui,U IUULlt�n syJ�Ci i i. VV 1 Ion are a ie a%.%.w 11utau V e u i lF,aCts v� desalination plants without considering distribution system storage capacity and h identifying specific areas of future need? As and example, If four equal capacity plants are built in Long Beach, Huntington Beach, South County and Oceanside in the next five years, is there storage/distribution capacity to handle a new source of water at 200 m.g.d? How much additional pipe must be installed to convey desalination water from the source to where it is needed? 8. We believe there is validity in addressing the question of"Should we develop--a new source of water rather than develop reclamation and reuse to the maximum extent'? We have been told we can not have greater reclamation due to the lack of a pipeline distribution system for reclaimed water. At what point is it 1 viable to construct a reclaimed water distribution system rather than paying 2-3 times the current price for water? 1 9. The industry of developing large volume desalination plants is in its infancy. There will be technological advances in treatment methods as well as advances in saltwater sourcing. The R-EIR provides in depth discussion on the issue of utilizing saltwater ground wells instead of intake pipes as a saltwater source. It concludes technology is not currently adequately developed for salt water ground ' wells to be a viable alternative to intake pipes. Ground wells would eliminate issues of impingement, entrainment, and would benefit the project in lower energy demand in treating water. The EIR should address what.,is the current status of research and development in the industry, particularly advances in sourcing technologies. Can the public anticipate any new technological advances in the near future? Sincerely, Garry Br wn Executive Director Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 18 Orange County Coastkeeper Garry Brown, Executive Director 18a. This text provides an introduction to the comment letter and does not require a response. 18b. Refer to Response 7af and 10j, above. 18c. -To clarify, only "first rinse" washwater would potentially be conveyed to the OCSD treatment plant. Refer to Responses 10j, above, and 17k, below. 18d. Refer to Response 10d, above. 18e. Refer to Response 10o, above. 18f. Refer to Response 1 On, above. 189. Refer to Response 2as above. P 18h. The proposed project includes new pipelines to convey desalinated water to regional distribution points operated by MWD. Adequate capacity is available for distribution of desalinated product water to end users. Each individual 1 desalination proposal would be required to evaluate pipeline capacities on a case-by-case basis,, and would require acquisition of permits/approvals in order to use existing distribution facilities. 18i. This comment does not pertain to the DREIR and does not require-a response. 18j. Refer to Response 1f, above. i 1 1 1 City of Huntington Beach August 17, 2005 201 ---------__ COMMENT 19 - PAC'-1r IC INSTITUTE May 27, 2005 Research for People and the Pliinef` Ricky Ramos ity of Huntington Beach.P.lan.ni.rg Department._ 'non Main St., l?urlti^.Cron Beach California, 92643 .Dear Mr. Ramos: I serve as President of tb.e Pacific Ins_titute,.anindTcndcnt.reseaTch.institute.in.Qakland, California. I am.writing with selective comments on the Poseidon-Huntington. Desalination Fri,i.ronm. =taI Impact Rep ort-(FIR).-We very.m:uch-appr-eci-atc your carefiLL. consideration of the EIR.. 'I'lie Institute ha:. 18 years.of experience.with California cuater.ro.anagement and.sup}aona-. a careful development and management of water in California. I serve on the Department of Water Resources P.uhlic.Advisory.Committee for.theCalifornia-Water Plan. I serve ait, the U.S.Nation2l Academy of Sciences Water Scim.ce and Technology Board and am. an. Academician of the International.Water.Academy.inDsla.-Narway - Our review leads us to conclude that the draft Recirculated EIR(REIR) is seriously inadequate and flawed in its.analysis.of-future-.water.demand.-a.criticaLp2rt af.the analysis is whetl}er there is need for the plant,compared.to the alternative of improved. efficiency of usc.. There-arc.scyrral components,to these flsws..which we-address-below. As a result,the IiIR as presented runs the risk of m.i.sleading decisi.onmakers and the public about cenain.issues-of_importancc_. The issues raised by our review indicate that there are critical questions that remain unresolved. Thec;e should.be.addresaed successfull_y-before.approvat.ofsuch.a-suhstmatial. and potentially costly investment for local ratepayers. 'Thank you for your eonsideratiaa of the cam ' ants-bOxLw— N ccrey*PctGlvT*cic D President Pacific lnsti�ute 654.133h•Strest:E'.reseru2tiaa.� �_Dal<{aR�:OaGifnrni;3 4G5>2:6L.S-A- 510-251-1600 -1 fax-510-251-22.0.3. 1 e-wait pistaff0pacinst.arg.-1 www.pacinst..org-. t^ COMMENTS-of-the Paci is Unst-itufie Uproject Objectives".are.inadewat; As stated .in the current revised ETR(REIR), "Project Objectives"include production of a droug%hi-proof Supply of local water,_salt-reduction of imparted water;site rcu ediafisn,. (r and ecosystem b-criefits. T..ite Project Objectives are inadequate. Specifically, the water L_ supply/inanager Dent objectives-should include a goal cficicntifying cost-effective ways Of- meeting water demands,not simply providing supply independent of costs. The REIR grossly misrepresents the ability of arange of alternatives to meet these _ i_iazrowly dcftnecl objectives- incomplete and inadequate analysis of"water conservation"and "efficiency"as alternatives to the construetionoffaciliti:es-te-supply-new iresh-watff for-the region: Section 7.1. ("No.Project" alternative) states: The"No Project" alternative is not presently being considered because if fails to �- C meet the basic proiect'6 jectives. (page 7-3)'- The conservation and efficiency discussion,is limited.and inaccurate. A separate, and _ thorough, discussion nfcost--effective-water.conservation.and efficiennyis warranted_In addition, this section misquotes future demand projections, misrepresents conservation pot=ti.al,and mi-sunderstandLcnncepts_of_ef6cieacic_. Summary: The REIR fails to provide an adequate nalysis of alternatives for meeting the projected.dlemands-.(whichare themsetves..inadegm te4-analyzed,2 rooted below) .for freshwater in the region. In particular,water conservation and efficien-cy are n-rA,-but dwul&berconsidereda--se -*'.ate Specific Problems_in.GQnsencationand.Efftcienr-y-Anat cZs i Throughout the 1,ETR,there is little to no consideration of conservation.as a means to reduce future demand.-:EIRs.aresequiredic-include i .es Whj1ea-"-Net- P.roj ect" alternative is put forth, efficiency improvements.are inappropriately dismissed without consideration because they.don't-most-the basis ol#c-*vc-af—the-project,whieh4s,. to provide a "`drought-proof,'high duality,Clew potable water supply."There are two errors to this conclusiotr: F.irst:there is insufficient-suppatt.foT_the--arg=r-utthat sucl, ;, .' rou t-proof,high-- quali.ty...water supply"is needed, given more realistic projections of future demand. 2 Sccon.d, no actual analysis.was done to see if conservation.and eaciency programs.are capable of mect_ng such an objective in.Ibis area. Some such,programs are capable of e providing high-c.(uality potable supplics,u.sually-at costs below the cost of rew supplies. We understand that previous responses to similar comments by project developers argued that conservado-a--and_cfficiency are contingetltnpD mgortedvvater.supplies.and consequently do not meet the purposes of the narrow project descripti.ou. This marrow and specious approa.,:h.u^deu incs the.intent of CEQ_Q_to offer the puGiic tali disclosure of the impacts of ttie project compared with those of feasible alternatives.Moreover, this f argument is fats;.. Conservation,and.ef lcaei1cy_irnpravementshave-a_direct effect-am- reducing the need for imports,exactly the same as new supply from d.esalina.ti.on,and. almost always at lower cost lncormct Description of Water Need/Demand The ,PF-T.R Secticin1.4 ad-for.iucreased supply in the co:rttext of droughts. The actual vulnerability of supplies in the affected. region to future droughts has not been demonstrated. Event if such vulnerability could be clearly shown, conservation and efficiency improvements are precisely the alternatives- inc)st successful st reduci„Timpacis e »nhts,as slowhy..thr-,-fact_that-dir._ri1 cnt, long-term drought in the Colorado River system bad been handled easily with,1-.n.' al g ' conservatiou and reclamation efforts— alternatives_rej-ectedhy the RE.IR..A.similar.. - in.con•ect assumption was made when the Santa Barbara desalination plant was built,with disastrous econcmucresult_to-local xatep -yers_A.sthe_price-oftbLaplantgr-w-.th> pricc.to, consumers grew, and efforts at efficiency and conservation substantially reduced total demand, elimin.;Axn.gtbe need for the plant. Thaviiery.expensive plant has remaified idle and mothballed, and ratepayers are still paying it off. Demand.Projealions-May&--Wrong_. Tlie REIR.Lays out a set of assumptions about future demand that ini.squote and misrepresent estimates.in.the.California WaterPlan._tbe State.DegarftneW of.Watu Resources' (DRR)long term planning tool("Bulletin. 160-2005"). Section 7 (Atiernatives)rclies_o -baseline acsurnpticins about bnth.incLeaaesinfuh=a-demand.a=d. the potential for zonservation improvements that are inadequately substantiated:The REIR takes as a fundamental-assumption-tit-there-will-be-dm-aaand-for-its-water upAG- 56,000 acre-feet per year.. Yet this assumption,is based on both old data,and.on inadequate cvalrratiarr of actual . s,-CTangcCota. per-capita water-use-.. h - high,ranging from a.low of 197 gped in very_wct years (]995) to 233 sped in drier years (1.990)(source: Metropolitan Water District. 2005, Integrated Resource Plan Update). This suggests that a significant amouttt of.conservation potential.still exists and.that, more complete %nd comprehensive demand analysis is needed before any estimate of future water demand.carrbe evaLuated_. More importantly.,dbrrr-.ise_vid=r-.to-SF,g gcst that theBPTR eciimatpc of ervatl9n potential are far. too .low_ The Pacii'zc Institute, for example,in a statewide review of urban conservation potcntiaL.idcntified the RcztentiaLfoL30%n xr-duction,cost-effeet+_veLy (i.e., at costs far lower than desalination costs)in current urban water demand, using r existing tcchaolagies.(P.acific.Institute,.2QD5_°`WastNniTWantL�Iot:.Ihe P_QtexztialSnL, Urban Water Cc;nservati.on"). The conclusion of this report was adopted by the DWR in its estimates.of-'_uturc.urbatLconservai oti poteRtiaLbuzlzas hedni,�arl,eze_ As a single example,recent work at the Irvine Ranch Watcr. District documents that use of a single cfFcicncy.technotogY --.readily available residantiaLi gatioa- ontrallers-- can.reduce total:-esidcntial.water demand by 10%,reduce local urban runoff by 70%iii. the dry (high dc:cnand) season; aiV can_ receiimg waters-.- (See: vvww-irwd.cori(R esideritial Runoff Reduction " j Study, Executive Summary .Fuly 20D4). Summary: 1Vlany.a(ternative indoor and outd ear.residential efficiency.options,are available,as a.r,:a wide range of commercial and industrial options_Proper and consistent implE,,nnentAti of these kas the potent a to;u H&a�y&V even••., completely elitninate the need for the water provided by a proposed desalination plant,-but this madegrate-REW failsty ppro�srisrte�yev nth :titer:: tine. The Proposed.Approaeh.Conflicts:.with Recommandatkms ofthe_$tata- Desalination Task Force. California's State Dcsatinkinn Task Eorcz-r===en&-d-that-desali=ion-shculd_Ise t included in a water supply portfolio where it is"economically and environmentally appropriate"and-when-re:yeling-an-d-conse beetr. "maximum extent practicable."This REIR fails to adequately address this or adopt_this recomiri.endati.on. L --end -- 4.. r Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 19 Pacific Institute Dr. Peter H. Gleick, President 19a. This text provides a description of the Pacific Institute and does not require a response. 19b. This text provides an introduction to the comment letter and does not require a response. 19c. The commentator opinion is noted. Objectives of the California Water Plan may be as general as that championed by the comment. However, the project requires project-level objectives and such specific objectives that include "a drought-proof supply of local water" are adequate and reasonable under CEQA. Refer to Responses 2f and 2ag, above. 19d. If the water supply is not needed, then the project will fail on economic grounds as dictated by the market. To the extent that the project results in impacts that cannot be mitigated, the lead agency is required to balance the benefits of the project with the resulting environmental impacts (see CEQA Guidelines Section 15093). Aside from this balancing requirement of the lead agency, CEQA does not require a "needs" analysis. While a comment questioning the "need" for the project may be relevant to the exercise of"the agency's ultimate discretion on the project" (see, CEQA Guidelines Section 15121[b]), it is not considered to be a "comment on environmental issues" (see Guidelines Section 15088[a]), and does not require a response. i19e. The commentator's belief that "some such [conservation] programs are capable of providing high quality potable water supplies usually at costs below the costs ' of new supplies" is appreciated. However, no specific conservation program has been identified that warrants a more detailed response. If the commentator's statement is valid, demand for imported water supplies would not be increasing 1 and the California Water Plan would not need to consider all feasible water supply opportunities including desalination of water. Also refer to Response 2ag, above. 19f. Conservation and efficiency improvements were considered as part of the "No Project"Alternative in the DREIR. Refer to Response 2ag, above. 19g. Refer to Response 19d, above. The commentator's suggestion that conservation and economics eliminated the need for the Santa Barbara's desalination facility is misleading. In fact, immediately upon completion of the Santa Barbara's desalination facility, water supply and political circumstances changed. Rainfall filled local reservoirs and connection to the State Water Project was approved. 19h. The commentator claims that the DREIR misquotes and misrepresents estimates in the California Water Plan. Citations to the California Water Plan are provided whenever the DREIR sets forth information from that document. In addition, the City of Huntington Beach August 17, 2005 206 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS J 9 Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS r entire California Water Plan has been incorporated by reference. Also,refer to - Responses 2f and 19f, above. 19i. Refer to Response 2t, above. l J l._ 1 1 r City of Huntington Beach August 17, 2005 207 COMMENT 20 cvio rm Edrohnson Qrnnyr �unf� s mor V,rr`PrVVJcn1 Phy1111 Fabcr Gary Pctton Bay Arca VictFrc.+.idcni 7 willil Ycnmr Lor Ai,gtJu $eei'u�rv.T„-usurer . PLANNING A�XD �E?N�ER lO T�1✓� E May 27, 2005 Mr. Ricky Ramos City of Huntington-Beach- Department of Planning 2000 Main Street Huntington Beach, CA 92648 iRe; Comments on the Draft Recirculated Environmental Impact Report(REIR)No. 00-02 forthe.Seawater.DesalinationProjectatIlimtingtaa-I3earh.. Dear.Mr. Ricky Ramos,. . . The Planning and Conservation League submits the-fallowing-corn Tents on the Draft ' Recirculated Environmental Impact Report REIR)No. 00-02 for the Seawater Desalination Project-atHm ngtan$earclr:We appreciate tl-is-oppartunity to-comment-oa-. this project and request careful consideration of these comments and those received by other individuals. Large scale desalination has not yet been-suecessfully achieved in California or in the United States. In the:_United.States.theLeis_only.ona.large.scale.scawatcrAcsalination - a facility.That facility,located in Tampa Bay Florida,has never functioned as intended. The proposed project under the REBt would be the first large scale reverse osmosis facility in Califom a;-wiih-a projected;capacityvftwicr-Tampa-Bay'-srmn-operational- facility. CarefiiLand.thsLughtful-considcmtion must br-giYen-la-the_.gropnsed project in-... Huntington Beach to ensure that all concern's and outstanding issues are addressed prior to moving fortvL-dLuwith-such,-&-large-scale.-fa�flity-that-wiRhave-ending impacts-on the— Huntington Beach community and on the coastal and marine resources of Southern California: As the comments below demonstrate, tlifi TEE &e's not P rovide'information essential to assessing the.long.term feasibility.andimpacts-of the.proposed-project. .the... REIR does not adequately demonstrate a need for the.projeci;it fails to adequately analyze growth inducing impacts;enviroa ntal},4s ce khpaet,-impacts-err marine life,. or cumulative impacts of the proposed project:In addition,the REIR does not provide information on-howprivate-o-WnErsI.Lipaftlredesalinatiozrfacilityimpactsthe�-operatiorr, the proposed facility and how the responsibilities of the private company will difiez from `b that of a public owner. This project will impact future Clean Water act compliance, coastal zone management, land use planning,P1eGtSiQty_geT2erA6n ri the mArinr rr n ysten ( rhr Southcm California Bight. Such a decision requires thorough information and careful consideration of the full impacts-and alter atives-evail -- '�-•'••' _ ' NATIONAL ; rL xr+me nxn 921 11 th Street Third Floor, Sacramento,CA 95814 Phone 916-444-8726 Fax 916-44R-T.789 �M�E s:r+xscNnnoN F F,1)fiR ATE O N' Lurve Websitt.: www.pel.org Lmail:pdniQ..@pcl.urg w.rw•pLI.0 YL• Unfortunately,this RE tR is inadequate, flawed,,and sets an unacceptably low precedent 2 for future reviews of desalination_in California.The RE1R does not provide essential information to the Huntington Beach City Council and to residents of the Huntington Beach either on the impacts of-the alternatives-available-to_ther==Unity.- - We strongly urge the-fl: ngtan-Bead-City-Cowl to Fej th€current REIR and . - b attain all the information essential to malting ar,inforrned decision before moving, fory ard.Yl th any Proposed seawaterdesafination pr,-F1�Gt�'t��';IIlrtilT�tolTBVBC�`i community. Th Ly cI nt yre Water Policy Specialist f COMMENTS The REIR does not adequately demonstrate a need for time proposed project. , The REIR states the ro'ect is 'currently being proposed,to meet,Orange Coun 's P .J Y S P P g t5' ongoing water needs."However,the recently released Draft California Water-Man . Update indicates that the Southern California region could feasibly use less water in 2030 than it does today.'The DcakWater Plan Update-scenaria-indicates that-Southern- - - C Califoinia will use about 100,000'acre-feet less water with minimal implementation of - conservation ineastu es,2 Accordingly,the REIR should provide i€ocumented information that explains,the need for-anadditional56,M-0-&cre-fe�inQrange-County.Without such information,there is no need for this project. T1ne REIR states that over all demand in California has increased since the last drought of 1992, T' 's statement-isunsubstantia ed'rd - , ct:InIkct;-thc-Drafr-CalifomiaWater Plan Update states,"As has been demonstrated in various regions of the state, an increase r in population does not necessarily�resulf in a proportionate increase in urp-&water use."! i For example,the Los Angeles,Department of Water and Power reports in their Urban. Water Management Plan Update 2002-2003 that"water conservation continues to play an important part.inkeeping thy.citx's.water.use,equivalent to-levels seen 20 years ago." The REIR does not fully Ymnlyze alternatives to the lrsvp®sect project. _ e 1 1 California Water Plan-Update-Pnhlir-geview.Draft,Hiahli hU,P-agc 4 2 California Water Plan Update Public Review Drag,Highlights,page 4. California Wa=Plan Update Public Review Draft Vohllite 2,Chaptei 22=pag_c 22-1. 2 i ,e REa fails to include an analysis of how other water supply reliability methods could meet the water needs suggested in.the REIR, In particular,the REIR fails.to analyze an_ alternative that includes conservation,recycling and groundw?ter.treatment. Water for California and-the'Planning& Conservation-L-eagtre-recently released an ' analysis of cost-,effective s}ateg;e.s to meet Csalifornia's fui:urir water needs.The document,the Investment Strategy jvr CuZij��Ffa I11 �lr��es&—Mera iicr ut2 r') demonstrated that California can more thaameet watcrnecda.with,implementation.of cost-effective water conservation,water recycling and groundwater clean up.The chart from the'Investment-S"tegybelow summarizes these-fmdings-:a Additional'.. .eeds- Population Increase Environmental Restoration 1.0 'Total additt natne6ds- 3.ft 3.a e' First Priori 00tEM& miliiortacre=feet Urban Water-Conservation 2.0-2.3 -Agricultural Water Conservation At least 0.3-0.6 Recycled Water .1.5 Graur aLatg� e�trx�ent: ►d Des3l�aiioa--. . Ai eastIl 99 iTotal First Prlorlty Potential At least 4.094.69 In addition to the Investment Strategy,State of California documents also indicate that water conservation;recyclineandl gratin ore-than meetwater� - needs in California.As stated above,the Draft California Water Plan Update'indicates that California and in particular,Southern California could feasibly use less water in 2030 than is used today;In-t ie ss�ario t iat_Cal krma-needs-mores•�ar�the I�ra$Ilpdate identifies several options that are i2iorc reliable and cost'effective than large scale nt Tke Dratseawater desalinadorr, California Water Plan Update also identifies'water management options that will help . augment existing water supplies and increase water reliaVilYty. According to the Update,'Urban W_ate'r Use Efficiency holds the greatest potential as a'*' watcr'managemcni.option.withrigotential.ta.provide.2.Q-Z3 million acre feet of water. ' The Update states that recycled water has a potential to provide another 1.4 million acre �Inve�tmcxct,Strategy for.��'^t�ll'at�gase2. '. hfp://www.pcl.brg/pcllpcl files/Iavesfinent%20Stratejzy 11 18 04.pdf s Cabf=ia Warcr Plan_Update-.Pub&ReYiew Draft,Highaphts,page 4. feetbf water. Crroundwatcr management and storage is also identified as lia-v ing a e significant potential at greater than 2.0 million acre feet.6 The REIR does not provide an alternative that includes the finding of the Investment Straregy for California Water-of the inforrnaiion from;the Dr2Lf.Ca1if6mi&Water Plan Update. Omitting such an alternative falsely indicates that Southern California and in particular Orange County.-have no-alternative 20 e:.pe:rsive se$�vate:clesalinatio Because the REIR fails to incline-an analysis of ah alternative including water conservation,water recycling and groundwater.treatrn.cnt,the A RTR.omite essential_. . . information on how such an alterative would compare to the proposed project. In fact,as outlined in the lnvestnient-SawfeVand.the�3raft Califo ria V6Late�Plaa�Jpdaee, �- alternative could more than meet the stated objectives in a more reliable, less energy intensive;more cost=effective and less environmentally damaging way than the proposed- project. Conservation, water.recyclingand_use.ofstomd- ro indwater.arrpro-venreliable.drought f responses. In the past these responses have been successful in offsetting drought impacts. Recent developments of these--water_managementstrategieshaticeincrPased-draught_-:. .. reliability in Southern California. In Orange County,recycled water is being stored iri natural-local aquifers-providinra s 3rought- periods.... For example,there have been no cutbacks or restrictions ur gbutfiPtn Cafi 6rnia even with the 1996-1997 draught vLith.fihe went c=cntleng=tezm_drmigb in thuCa1oradriRixet system, or over the past four years which were some of the driest years in Southern California.-Over-thBm.dZ "Paris lin. been met udth minimal nnns=atim, and reclamation efforts. Alternatively,large scale seawater desalination-has not proven to be a reliable drought supply. The REI R'mentions that during drought-the proposed-facihty could provide-a-- substitute supply for water imports.However,in times of drought hydroelectricity throughout California and the Pacific Northwest is also reduced-and prices of remaining g electricity increases.-The:proposed.desahnati6 facility-would-be a sigaificant strain on the'eztergy grid,requiring more energy than any other source'of water.The REIR fails to address how energyshoftWs-and increased-costwilI t-the�reliab—Gfthzproposed- project Therefore,the REIR does not provide sufficient support for conclusion that the proposed project woukHa-fact-m c tyarflrange eoM1ty: {� The REIR should be re-drafted to include an alternative based on the Investment Strategy f for California Water and.theDrafhCaliforniaWate Plan_ dar sathata,`ull_-.. - comparison of alternatives is considered by Huntington Beach's community and elected officials. C Cslifomia Water PlmUpdatc Public Review Draft,Highhghts,page IS 4 The REIR fails tb analyze the f'iM impacts-of-the operatioha tithe proposed large- scale desslinati€n facility. The REIR states that because the proposed desalination facility will be co-located with the Huntington Beach Generating Station and will make use of an existing once through cooling intake,the project has no mgnificant impacts on the marine life from impingement and entrainment.This finding is misleading,untrue and inconsistent with the recommendations-ofihil Stateof,Ealifornia The California Department-ofWater-Resources convened-a-Desalinat:ion Task-Force oaI i and published the Task Force Findings and Recommendations in October of 2003. According to the Desalination Task-Forcc_Findings,cQ>loeating a desalination facility... with a coastal power plant, as is proposed with the REIR, can provide.a justification for the continued use of once=through-cooling te ology Ehre�tleugl3 caelirtg teehno}og has well-documented environmental impacts,including impacts on marine organisms from impingement and entrainment, according to die DesaHnation Task Porce.7- In order to ensure all impacts from a desalination facility-are understood;the Desalination Task Force recommended that impacts from approgued project be assessed separately from the existing power plant.8 The REIR fails to follow this recommendation. Assessing impacts of the desalination facility apart from the power plant-is important because power plants maybe shut-down-or die-operatimrof h powerplant may r�hange-- in way that is incompatible with desalination operations.In those cases,the desalination facility would need to function separately from the existing facility, and'tllerefore the - impacts of the desalination operation would be different that the impacts from the existing facility. Older power plants such as the Huntington Beach Generating:Station(HBGS)use open - ocean-intakes.to gather-water-fir r once through caohng._This method of-cooling requires vast amounts of water and the unscreened intake results in very high marine life loss. Numerous species-af marine lifr-in-tl Sautheru-CalifomiaBiah �,,,rPntt�c_undeL . extreme pressure and several are estimated to have been depleted to less than ten percent of their historical populations: However,there are new*technologies for power prints that recirculation cooling water or use dry methods of cooling_ahich-significantly.reduce the water needed for power generation which in turn reduces the impacts on the marine environment Under the Federal Clean Water act, a power plant must have a current 316(b)permit for an intake to the ocean:The Federal-FP A-r-e,=tl-y-ad.opted-=w rules-fo=-p�*.?m ace=_ water intakes.The new nile requires all large existing power plants to reduce Water Desalination Task Bone,-October.2093..Dk_;:uncut of Water Resources,page.5_ B Water Desalination Task Farce,October 2003.Departrnent of Watt-r Resourcts,page 21. 1 impingement and entrainment of marine life by the cooling water intake structure by 80 � to 95 percent. In addition,the law requires cooling intakes to utilize the best available - technology for reducing entrai arnent and impingement. There is a process-und-erway to-update.the 316{b)pemiit--for HaG,3_The.current intake.. for the HBGS does not reflect the'best available technology for reducing impacts,as 1l required by the new rules.The California Energy Com:mssiars-r.:eently-completed a study- oa the i:npse+s of the Iu?aOS c0,fixg,water intake.It is uncertain how HBGS intends to comply with the recently promulgated Clean Water Act 376(b)regulations on cooling water intakes. One potential HBGS compliance response would be to reduee'the volume of intake water from the historical baseline. This course of action would make the proposed project infeasible because the desalination facility woigd require a-vast-mmaunt,of wat=to aduce potable warer.es., well as to dilute the brine wastewater produced by the desalination process.In this case, the operation of the desalination-facilitywouId bes*i&tmtl),625e ent t-tbe operation of the intake for the power plant.Failing to assess the impacts of the intake on marine life separate from the impacts ofthe.power plant is-a signif'icanf flaw in the REIR- In addition,the REIR does not indicate how the project will affect areas in the designated m as Area of Special-RiolQgirA1•C____ig;ficanceby+-theState-WatenResources Control Board. L Because the REIR-does-not--adequatel-Rc,;t s the en3,ronmP,tat impacts of the.proposed desalination facility,the REIR is fatally flawed and must be rejected. . C The REIR does not provide'clear information about the source of energy for the L proposed project _ The proposed project would require a significant.amount of energy to operate. The REIR states that theoperatioa-ofthi piepos4project-wouldFequire 724to--940 megawatts - hours per day,enough for 30,000 to 35,000 residential units_ However,the REIR is not clear as to the source ofthe large atnaunt afenergyieclnirecFforthisproJcct The energy source for this project is iinportant because it will affect tfie bi quality_ O impacts of this project-6c,cost ofthis�wjcctrtheimpact.of the project on the availability of energy in the Huntington Beach area,and the greater energy grid'. Regardless of source the REIR is required to identify and mitigate for the air quality g � q fy g q ty ' impacts of gcnMMtingthe•-eaergy-necessary-€ar thispre feet.If flie-energy source far the- REIR project will come from the HBGS,the air quality impacts to Huntington Beach r should beincludedin the REIR.If the energy for the project wilf come from the energy-- grid,a discussion of the-impactnil eaergy.msts.and availability needs to be included so that impacts on Huntington Beach and Orange County are fully understood. L The greatest expense in the operation of reverse osmosis facilities is energy,The cost of operation and the economicfeasibilityttftlrispmject w if!-be-based =-the cost crf energy If there is no secure source•of energy for this project, the cost of the project operation will increase according to the market rate for energy. Increased energy costs could result in inuch higher operations cost,which would then increase the.cost of water_The claimed benefits of this project would be greatly reduced if the price of water from the facility became prohibitively.experrsive:- 0 The RE?R does notprovide infoiiziation necessary to-adeq_uatelyassesslraw the energy- ' consumption of the proposed project will affect the grange County community, and therefore the REIR should be rejected. Growth inducing impacts have not been-adequately-smmalyzed.- ' The'REIR states th t-the-growffi-ihduci_ng impacts-of tbze-proposed project.would-depend` entirely on the how the local and regional water purveyors allocate the water produced by the project..Essentially,the REIR-fails to identify a use-oruser;for the-proicct water This- calls into-question the need for the project,but it does not excuse the REIR from p I addressing the growth inducing impacts of the"proposed project.The project would be connected to the Orange County_water distribution system,and therefore could be used in a limited area. Therefore, growth inducing impacts of an additional 56,000 acre-feet of water supply in Oranges.Cmmty_shouldbe.anrzllyzed. As indicated in theREIR;fro--leeal-waw-puy-veyor-&Dave-indacateda.needur.-a desire to purchase water from the project The REIR also notes that the proposed project is not included as part oftho-regionut rugratrr bY� sterl}isttict: ..- Neither was there a specific target or project for desalination like the proposed project in the Municipal Water District of Orange County's last Urban Water Management Plan. The City of Huntk%pn-B each- as4ndicated.d=-there-is-no.use-for_the_prnject water..... 4 within'the'City. This water has no specific intended use, which implies that it will be used ' for unidentified purposes,-includirrggi o wth.. The REIR has not adequately assessed-growth inducing impacts or identified a need for this project,and-therefore.the.REIRshould_be.rejected, The REM fails to.assmEn-virGum n a1 Justice_bnpacts-fr-effi.increased water costs and proliferation of the HGBS pourer plant operation. As discussed above, the proposed project'may provide justification for the extended operation of the H$GS-powef plant:In the-absence-af th-e d-propose Project-the HG1�_. r may close as newer,more'efficient and less environmentally damaging power generation is developed. Operation of the proposed project would-provide justifrcation'for the-' continued use of HGBS even if less environmentally damaging power becomes.available. The REIR therefore should analyze the impacts of continued power plant operation on the local community; and inrpaideular the justice impacts-that result from- the.continued use of the HGBS power plant. In addition, the water produced from seawater desalination is;ecogm'zed as the most expensive source of water. Even with technological advances,'seawater desalination still- requires'costly upkeep,including filter and membrane maintenance and replacement and energy consumption for reverse osmosis processes are greater requirements for other r water options.In fact; according to.the Department of.Water.Resources Desalination Task Force Findings, seawater desalination,requires 30 percent more energy than any other supply source, So-uthern California,including-impor'tei-water:- hi addition, cost savings Have 7never been realized as of yet-fvr�eawaterdesaliriati6n.:hT- California a seawater desalination plant constructed in Santa Barbara has never been used because operation of the plant is too costly. In'Tamps Bay,the seawater desalination plant-operation became sig_nincantly more expensive when it was realized filters and membranes would have to be replaced much more frequently than project proponents had indicated.The.Tamn plant .urrently operates far_keicii.capacity,-primarily because operations cost are so high. If the proposed project were to provide water to the residents.of Orange County, the r expensive water could increase the cost of Yvat County. This-- potential increase in price could be marginal,but even a marginal increase in cost could , severely impact residents on limited incomes.Therefore, the REM§Mould i ieru&e an analysis of how increased water costs will impact water rates in Orange County and how the increase will affect low income residents.This information is essential in order for the Huntington Beach Ciesil�be�s to this nr *v�illsflect their.. community. This is consistent ., tie 'Fask Free that_des: "Environmental justice considerations include the siting of desalination facilities, determining who accrues the costs and bdnefits of fiesalination and who has the--- opportunity to use higher'quality(desalinated)water, an mpacts o d the possible if replacing low-cost with high-cost water."g_... (� The REIR does not irndicite how the privately owned facility evi:Z operate as a r supplier of public water. The Desalination Task Force Findings&Recommendations states: "There are implications-associated with the range of public-private possibilities for $ ownership and'operation of desalination facilities. Local'government has the responsibility-to make the detail of these wangements a-vai at,te to the_public„1Q The proposed project-wifl notbe-pubbc}y ownlcd As•aprivate-o�—,aniiatioFr; the proposed-- project operators would not be subject to the same requirements as public agencies. The REIR does not address haw private'ownerslup of this demdination-facilhywill affect the`._ F L 4 Desalination Task Force Findings&.Recommendations October 2003.page 6 10 California Desalination Task Force,October 2003,page 5 t 05/27/2005 14:Z6 FAX 811E 446 1 6V r.C .L.r. I�jU1U/U1U facility Operator's responsibilities regarding the Coastal Act,the Clean Water Act and other important environmental and public health laws: $ Before this REM is approved,this information must be provided'to th'&public. The Cumulative Impacts of desalination an the Southern California Right are not a1e.quately aesPeced.. The REIR states that the total-production from proposed-desalination-on.the Southern .. California Coast is 260,000 acre-feet per year.The REIR then states that there will be no growth inducing impacts from the cumulative developmerit of desalination:-H$wever,­- 260,000 acre-feet is well above the targeted regional desalination production identified in t the Metropolitan Water District's Integrated Regional-Water Plan thdt sets a target'of 150,000 acre feet.In addition,240,000 acre-feet per year is well above the target set forth in the Draft California Water Plan Update of 187,000 acre feet of desalination production statewide. Therefore,-existing plans do.not account_for.the cumulative impacts,,includihS growth inducing impacts from the proposed-seawater desalination facilities.The REIR fails to asses the-dive-gg'aivth-inducing-impacts-64vSoutliem-C hforma-and is therefore inadequate. In addition,the REIR fails to address how the proposed desalination projects.in Southern u California will perpetuate the use of harmful open ocean intakes on the Southern Califomia Bight.. Because of the flaws-identified_al"e_the ffuntin m R�ac _Cauncil is.required V to reject this i.EIR. 9 ' Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS 1 9 ' Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 20 Planning and Conservation League Mindy McIntyre, Water Policy Specialist ' 20a. This comment provides an overview of seawater desalination in California, and does not require a response. ' 20b. This text provides an overview of the comment letter and does not require a response. 20c. The information provided by the Draft Water Plan Update is noted. Nevertheless, as disclosed and explained, the California Water Plan relies on both conservation measures and desalination of water to meet projected water use in California. If conservation measures are effectively implemented (as speculated by the commentator), then conservation and desalination water production will together provide a greater opportunity to reduce imported water demand in the region. ' Refer to Response 19d, above. 20d. Comment noted. The Municipal Water District of Orange County's 2000 Urban Water Management Plan reports that water demand in Orange County increased from 1990 to 2000, even with implementation of water use efficiency measures. See Table 3-4 at page 3-42 of the DREIR. 20e. Increased conservation efforts, increased use of groundwater supplies and construction of additional water recycling projects are all discussed as part of the "No Project" Alternative in Section 7.1 of the DREIR. Refer to Response 19d, above. 20f. The document prepared by the Planning and Conservation League (the commentator) entitled "Investment Strategy for California Water" includes interesting and insightful information pertaining to management of California's water supply. The summary information included in this comment is noted. There is no requirement that the "Investment Strategy for California Water" be considered as an alternative to the project. Refer to Responses 2af and 20e, above and 22f below. 20g. This comment suggests that energy shortages and increased costs will affect the reliability of the project. If the project is not operational, most— if not all — of the project's potential environmental impacts would not occur. Refer to Response 19d, above. 20h. Refer to Response 20f, above. ' 20i. Refer to Responses 1 g, above. ' 20j. Refer to Responses 1 g, above. City of Huntington Beach August 17, 2005 217 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS 20k. Comment noted. However, it should be noted that the HBGS intake structure is equipped with a mechanical screening system (described on p. 4-3 of the DREIR. 201. Refer to Responses 1g, above. 20m. The nearest Area of Special Biological Significance (ASBS) as designated by the State Water Resources Control Board (SWRCB) is located approximately seven miles southeast of the proposed desalination facility (Newport Beach Marine Life Refuge), and would not be impacted by the proposed project. 20n. This paragraph provides a summary for comments 20h through 20m and has been responded to accordingly. 20o. Air quality impacts due to the project's electrical consumption are addressed within Section 5.4, AIR QUALITY, of the DREIR. For a discussion of local and regional impacts on the electricity market in Southern California, refer to Response 1Oh, above. In addition, the effect of electricity on the costs of operation of the proposed project is not an environmental issue, and does not require a response. 20p. Refer to Response 2as, above. 20q. Refer to Response 2as, above. 20r. The proposed project would not "provide justification for the extended operation of the HBGS power plant." See DREIR, page 4-8 and Appendix Q. In the event that the HBGS were to cease operations, the project applicant would assume ownership of the existing HBGS intake and outfall. The ownership transfer would be treated as a separate project. The transfer would be subject to applicable CEQA and regulatory agency permit requirements. Avoidance, minimization, and mitigation measures for such a transfer would occur at that time. The proposed project would be privately funded, owned, and operated. Water would be sold to local water purveyors seeking a high quality, drought-proof water supply. Decisions regarding cost effects on customers would be made at the discretion of the local water provider, and it would be speculative to analyze a potential increase in water costs at this time. In addition, the cost of seawater desalination has steadily decreased over time due to technological advances in reverse osmosis processing. It is expected that the cost of desalinated seawater would continue to decrease as the cost of existing water supplies increases in the future. 20s. The commentator's recital of the Desalination Task Force's opinion about local government responsibility is noted. In addition, regarding the commentator's argument that the "project operator' would not be subject to the same requirements as public agencies, refer to Response 2aq. Substantial evidence in the DREIR indicates that the project (privately owned and operated) would fully comply with the Coastal Act, the Clean Water Act, and other environmental laws and regulations. One example of this obvious factor is the commentary by the City of Huntington Beach August 17, 2005 218 1 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS 1 9 Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS ' California Coastal Commission that the project applicant is required to obtain a Coastal Development Permit in accordance with the California Coastal Act. 20t. An analysis of potential cumulative impacts due to multiple desalination facilities proposed within the Southern California Bight is provided in Section 6.0 of the ' DREIR, LONG-TERM IMPLICATIONS (beginning on page 6-18). 20u. The proposed project would not perpetuate the operation of HBGS. It would not result in a cumulative impact (nor is it related to) the perpetuation of other open intakes within the Southern California Bight due to other desalination proposals. 1 20v. This text provides a conclusion to the comment letter and does not require a response. 1 i 1 1 1 City of Huntington Beach August 17, 2005 1 219 ' AY-27-2005 02 -07 PM UPR r. o t COMMENT 21 sE BNA Southeast Huntington Reach Neighborhood Arsociation P.O. Box 5696 Huntington Beach,CA 92646 sehbra�?sgl:b^a:org RE:OPPOSITION TO THE PROPOSED DESALINATION PLANT, SEHBNA,the Southeast Huntington Beach Neighborhood Association has spent a ' considerable time and.effottin examining the.facts.regarding.the.proposed desalination project in Huntington Beach. Additionally, several of our members have been in contact with other citizen groups-.within_the-.city.and_cmmty as_wcll.as.iasearch_of an objective ' evaluation by experts of a project that is bound,if implemented,to influence the quality of our life and the economic;-health-and environmental--future*f-generations to come:We- have also examined carefully the performance history of Poseidon trying to judge the ' credibility of its informationatcampaign and currentprornises-to-dwI4untington-Beach-% a community verses its actual performance in other parts of the country. ' All of our investigation has led us to the conclusion that we must express strong opposition to the propnscd I2esalination-Facility.in the.midst.of our community. ' in addition to strong opposition to Poseidon's plans,we are unequivocal in stating the need for.honest andeomplate_answcr -from_alLconcerned regazdingthe.short and long- term impacts of this project.In this regard, we ask that you accept your moral and ' professional responsibility_to.the_citizens.of.Huntington Reach.in.leading the.effort to make sure that this objective is realized in all aspects of the process including a truly critical evaluation ofwhatwe.belkve.to.be_an inadec;uate_EnviLotunental Impact Report, ' Our primary concerns include: l- Our air quality-,and the.quality.-of life.near the proposed desalination.plant(B.)L. ' 2- Pipeline Assessment—traffic,noise and the impact of air and noise pollution on neighbors.(C). 3- RO membrane_cleaningsolution_discharge_datarincluding c1e!aning_f1uids�water_, contamination,wastewater and the impact on ocean life and human health in a host of areas.rangingArom..gassibleallergic reactions_tagntentiaLimpact-on-the immune system and the overall health status of the population(K). ' 4- DisinfectionHyprnductsFonnation-.—Local-impacts mecca Tfish mammal and other marine life(N). 5- Local and regionaLgQwer_requirements--- itnpactand lre power available, including restraints and realistic costs(Q). ' 6- Failure of.other_desalination_facilhics_located.elsc_where-- including Florida__ C This should include detailed data on cost and environmental irn--pact as well as proof that this would not happen here (X). C Poseidon comportment at the Tampa Bay Installasion.haa risen.mare than a,few concerns at our meetings and in meetings with other concerned citizen groups. Given the vicissitudes of operating a facility.of.this kind,.it becomes clear that problems can and do _ arise. Yet, Poseidon has convincingly provided neither full disclosure any adequate mitigation *treasures. The potential of long tertt±,serious.enY?Ten-m-e-n+tal.da--age.is.t}?ere I and it far out weights any short-term effects that may or may not be corrected. Yet,the response to these concems.by.the.project.principals.is.woefully-inadequate. This leads.us, and many other reasonable people,to conclude that the information we have received from Poseidon proponents and from Poseidon representatives-are-either intentionally deficient of all the facts or are specious at best. We realize that some.individuals-in-the-Huntington_Beach_City Cmmci4the-Mayer'_a_ Oft-ice,the City Development Agency and others with heavy demands on their time may find it difficult to explore-all relevant-data,-and-thus-become dependeat.on-information provided by special interest groups or individuals who can benefit from the proposed desalination project.We-submit-that-such-art-approach is-not-in-the bestinteresrofthe- e citizens who placed their public trust in such individuals and organizations.We expect that all elected representatives and public servants insist on receiving aIrtnformation in . order to make decisions_based-onknowledge_and to avoid-any appearanrr that-other; factors such as insufficient data or false information have strongly affected them. Respect for their opinions-and-the integrity-eF-the-presess-derrrand-4tata4 facts be known. The proposed plant poses.a sedou&-myirnnmL-ntat and zn hc:aIt:h_=isk_taAhc. ,ro__ system of Huntington Beach and its citizens due to high concentrations of brine and litany-of toxic chemicals,-:Yet; lacking:How mold the matter be concluded without asking the proponents of the project to provide detailed analysis of possibl and-existing IeveN ofocean contaminants?This is particularly true in view of the insufficient data on the environmental and public"hearth impact of the recently expanded facilities of a polluting AES.Add to this that we do not have a clear picture of the pollution sources That his caused recent beach closures.These facts are among those that point to the failure of Poseidon to provide an environmental.bas-line_that-can be-usedasa_, benchmark to judge its true harmful impact on the environment and health or to judge the value of any.mitigating-;treasures:-More wok-is-needed-Wore--theirTeport-can-be--- seriously considered. We urge your refusal of a report that has not addressed all the facts. Some have asked thc-relevant question.- wit fair to ask-6ur community to live with the toxic effluent of a facility whose product will not be used by the community that carries the-environ-mental and-healf burden's The answer.to this eftw impact .- the proposed project. One important area that is not addressed adequately is the impact on g AES;which will supply in€r etr:e support;laird,and-ogtcasilsly;thffkitowatts'needed- iPY-27-2005 e2 :09 PM UPP 7149689545 P. 03 r ' to power the proposed project. What is the impact on the-environment,-on the power grid, on the consumer's energy cost,on the operating hours and conditions of AES? What is the magnitude of added noise-and air-pollution? What are-tlie-e€€eetive mitigating- measures of the burden on the environment and the human population? Can such a g project be considered without answering these and other long term adverse affects in-a� clear manner? The potential economic impact:.an be.seriom as well, is.proposed-praiect cim possibly erode tourism and harm the economic health and Huntington Beach's image as a clean resort destination. This iss-a definite by-product-as-opposed-to a-speculati-ve promise.of tax, revenue that is neither credible nor proven.Additionally,such a proposed project is likely to lengthen the life of an aging and polluting A-ES with,-a combined'effect-of increasing_. the blighted appearance of_the-arta_leading to.a_possible.decline.in thexity'.s.pr.Q.p_erty value.The-economic.health.of Huntington Beach is at risk. ' The previously noted facts point to a logical.conclusion. The proposed desalination project is ill conceived-and_it-domnot-ft-in-mbeTPfit ourour community-.Ti kf_ Environmental Impact Report is deficient in several major areas. It does not provide ' necessary information--to,judge its-true impact-on-the en vironment;-health anti economy-ef. Huntington Beach.It does not seriously address the short and long-term impacts on the environment. It does not adequately provide mitigation measures ofadverse effeem The-. ' cost of polluting our air and our ocean that represent our major natural resources,the cost of adversely affecting the health of our community that represents our human capital and.the.costof threatening-tourism thatisessential.to_.the_ec comic strength Qf.our city-- is simply too high. Huntington Beach cannot afford Poseidon. We urge.you to.jointisirn.opposing_the.proposed..desalinati.on plant,_to protect the ' environmental quality of Huntington Beach and to support our call for amassing the facts in.an honest and-comp lete.manner-as.anec-essaLy.ingredient-to making-decisions.based.on knowledge. Your thoughtful consideration of this matter and your prompt response'will be deeply appreciated. ' Steve Homier, Chairperson Southeast Huntington Reach Neighborhood ss ciation ' 714-968-9545 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS J 9 Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS . 21 Response No. ' Southeast Huntington Beach Neighborhood Association Steve Homer, Chairperson 21 a. These introductory paragraphs provide an introduction to the comment letter and do not require a response. ' 21 b. There are not specific comments in this text that have not previously been addressed within the DREIR. No response is necessary. 21 c. The statutory scope of the California Environment Quality Act (CEQA) requires that physical changes to the environment that would occur as part of a project be analyzed, disclosed, and mitigated where feasible. The CEQA statute requires ' that "substantial evidence" (i.e. facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts) be provided to support any conclusions made about potential physical changes to the environment that occur as a result of a project. The financial problems, construction delays, or other adverse issues that concern the Tampa Bay seawater desalination plant do not constitute any type of legitimate evidence for analyzing the environmental effects of the proposed project. 21 d. Refer to response 17d. 21 e This paragraph contains commentary on the City of Huntington Beach's public review process. No response is necessary. ' 21f. This paragraph states that proposed desalination plant poses a "serious environmental and public health risk" because of discharge of brine and "toxic chemicals." In addition, this paragraph states that the DREIR does not provide ' detailed analysis of the concentrated seawater discharge and existing ocean water quality issues. On the contrary, detailed analysis of potential impacts on ocean water quality and marine biology were conducted in Section 5.10 of the ' DREIR, (OCEAN WATER QUALITY AND MARINE BIOLOGICAL RESOURCES). Research found that discharges from the proposed project would have a less than significant impact on ocean water quality and marine biology, and that the OCSD wastewater plume does not reach the HBGS intake or outfall. Note that this conclusion is based upon the findings of technical reports prepared for the DREIR. These technical reports are available in Appendix C (HYDRODYNAMIC MODELING REPORT) and Appendix E (WATERSHED ' SANITARY SURVEY). In addition, refer to Response 22h, below. 21 g. Impacts in regards to energy consumption of the proposed project are included in ' Section 6.0, LONG-TERM IMPLICATIONS. Air and noise impacts are analyzed within Sections 5.4 and 5.5 of the DREIR, respectively. Mitigation measures are provided throughout the DREIR when applicable. In addition, refer to Responses ' 20 and 10h, above. 21 h. Economic impacts are outside the statutory scope of CEQA unless substantial evidence can demonstrate that an economic effect would result in a physical City of Huntington Beach August 17,2005 ' 223 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS change to the environment. In this instance, the author suggests that the proposed project would adversely impact tourism revenues, causing blight and ultimately resulting in adverse effects to the City's finances. No substantial evidence is presented to support this assertion that the proposed project would result in blight. Consequently, this statement is considered speculative and further analysis is not required. 21 i. This text provides a conclusion to the comment letter and does not require a response. City of Huntington Beach August 17, 2005 224 c COMMENT 22 1 Cify Of Hun ir:Gion4�l� fru• 2005 Er Su Fvunda.Wn Huntington Beach/Seal Beach Chapter ' To: City of Huntington Beach Planning Department May 27, 2005 2000 Main Street,Huntington Beach California 92684 Attn:Ricky Ramos From: Surfrider Foundation,Huntington Beach/Seal Beach Chapter. P.O. Box 3087, Long Beach, CA 90803 tDon Schulz PE Blue Water Task Force Re: Draft Recirculated Environmental Impact Report(E1R)No. 00-02 for the Seawater Desalination Project at Huntington Beach-Comments. Dear Mr. Ramos; Our Huntington Beach/Seal Beach Chapter of Surfrider Foundation appreciates the opportunity to provide the following comments to the above referenced Draft Recirculated Environmental Impact Report(dREIR).As you are aware, comments from our chapter were submitted to the originally circulated Draft EIR which continue to remain unresolved. After review of the contents to the new dREIR,there appears to be several additional issues of concern to our membership. The comments to those specific dREIR contents which are either(or both)misleading and incorrect, or not supported by the facts, are summarized in the a ' accompanying attachments to this letter. It is recommended that unless, (or until)these dREIR issues are resolved, certification to the ' above referenced document be denied Your attention to these dREIR comments is sincerely appreciated. Don Schulz Executive Committee Member Surfrider Foundation,Huntington Beach/Seal Beach Chapter P.O.Box 3087,Long Beach,CA 90803 City of Huntington Beac! MAY 3 12005 ATTACF v=-.. Seawater Desalination Project at Huntington Beach (dREIR) Comments: 1.2 ENVIRONMENTAL SUMMARY States: (PG.1-3) 8_1 LAND USEIRELEVANT PLANNING LAND USE The proposed dasalination facility is not anticipated to create any .impacts to surrounding uses with regards to air quality, noise, aasthatics, hazards and hazardous materials, and short-term construction_ Siarnifpcance: Less than! SlgFsiffcanr COMMENT: Applicant's definition of the term"significant"is unique to this EIR.(see comments to 5.0 below). The proposed desalination facility will have a short-term impact during construction on all of the above. states: (Pe.5-6 ELECTRFCFTY The desalination project may create impacts in regards to increased aiactricrty demand Sigri ficance: Lasts than sfgnif r-ant COMMENT: The Huntington Beach desalination project peak energy demand of 840 MWh may not be a significant load on the total state-wide power grid during periods of less than peak power service to the grid as a stand alone project.However, due to the fact that there are several similar desalination projects presently in various stages of planning along the California coast the cumulative impact of the total energy load to the power.grid may be quite significant, and should be carefully considered by the State Energy Commission prior to issuing even a single permit for a specific project. C During periods of peak service demand on the State power grid the margin between available power and energy demand is small(sometimes zero)and will likely result in an increase in the occurrence of blackouts or rolling brownouts. Purchasing energy at spot demand prices from out- of-state suppliers during these peak energy periods increases the electricity cost for all citizens. Coordinating the logistics of curtailing the energy usage from a number of privately owned desalination plants statewide during periods of peak energy demand, as the applicant has suggested, in order to reduce the likelihood of brownouts may be a great deal more complex than the dEIR has indicated. Issuing permits for co-locating desalination plants with existing power plants on a first-come, first serve basis could lead to a statewide unbalanced and chaotic power distribution system It is suggested that the State Energy Commission should be the lead Agency responsible for determining the location and adequacy of co-located power/desalination plants before even the C first large scale permit is issued. 3.0 Project Description States: (pg. 3-9) Aboveground Product Water Storage Tank(approximately 215'in diameter and 40'high 130'above grade and 10'below grade]):The aboveground prod;.:cI ater storaae tank would be circular in shape and would have an approximate capacity of 10 million gallons. COMMENT: The detention time in a 10 million gallon storage tank for a 50mgd desalinated water distribution d system is insufficient to provide an adequate margin of safety for potential users .For example, if pathogens were detected in the storage tank(24-48 hour laboratory test delay time)up to 40 million gallons of contaminated desalinated water would be in homes and in the distribution system before the tank could be purged- 3.0 Project Description: States: (pg. 3-27) Energy Consumption A 50 MGD desalination facility would require approximately 30 to 35 megawatt hours of power to operate. Based on 24 hour per day operation, the daily energy consumption of the proposed desalination facility is estimated to be between 720 and 840 megawatt hours per day. This amount ' of electricity could provide powerforthe average demand of between 30,000 and 35,000 residential units. The total amount of power required to produce desalinated water for one family per year is approximately the same as the amount of power used by the family's refrigerator in one year. ' COUNT: The applicant confuses the terms"power"and"energy."Units of power are kilowatts and megawatts.Units of energy are kilowatt-hours and megawatt-hours. The amount of energy required to produce desalinated water for one family per year is almost twice the amount of energy used by the family's refrigerator in one year. 3.0 Project Description States: (pg.3-36) C. The project would provide a new water supply source to accommodate Orange County's increasing water needs as shown in the water plans adopted by state, regional and local water agencies. CONYMNT: A report"Investment Strategy for California Water"dtd. Nov. 18,2004 coordinated by the f ' Planning&Conservation League provides the following data: Additional Needs(year 2030) million acre-feet Population Increase... ...... ...... ............................ ..........2.0-2.4 Environmental Restoration............ ............ .....................1.0 Total additional needs.............................. ..................3.0-3.4 First Priority Options (by year 2030) million acre-feet Urban Water Conservation... ...... ... ... ................ ... ... ........2.0-2.3 Agricultural Water Conservation...... ............ ... ... ....at least 0.3-0.6 Recycled Water......... ... ..................... ... ...... ...... ... .......1.5 Groundwater Treatment and Desalination........- least 0.29 Total first priority potential.........................................at least 4.09-4.69 . _ t In other words, by just employing moderate conservation and recycling options there will be no T need to even consider seawater desalination plants statewide until the year 2030. 'The report is supported by independent studies from the California Desalination Task Force,the Southern California Watershed Alliance, and the State Water Resources Control Board. The Orange County Water District has also determined that there is no present need to consider a seawater desalination project for our district residents. 5.0 Overview of EIR methodology and Significance Determination States: (pg.5.0-2) The following is an explanation of the different significance determinations made in this EIR: A. Not Significant This determination is made when any of the three following cases apply. 1) No Impact Due to the nature or location of the project, this impact will not occur. For example, underground facilities do not have the potential for long-term visual impacts. 2) Less Than Significant Although an impact may occur, it will not be at a significant level based on the above described standards. For example,construction-related air emissions that fall below the adopted air quality standards are less than significant. 3) Potentially Significant Impact"1 Ufrtigated"Through Existing Requirements(No FIR mitigafion required): In this case,there is an impact which,although it is potentially significant,will be g reduced to less than significant levels through adherence to and/or implementation of various existing requirements. These existing requirements include the City of Huntington Beach Ordinances, engineering and design requirements (through the Uniform Building Code and other regulations), and from other regional, state, and federal agencies. CO zU.- With regard to ocean water quality parameters such as oil, grease, suspended solids, salinity, turbidity, and loss of marine life by impingement and entrainment,the California Ocean Plan (COP) clearly defines significance as follows: KsiGNffiCANT difference is defined as a statistically significant difference in the means of two `: distributions of sampling results at the 95 percent confidence level." Since the desalination plant reduces the amount of cooling water discharged into the ocean by 50mgd all of the constituent concentrations referenced above will be increased by an equivalent amount, and will therefore meet the numerical definition of significant as stated above. pr Regardless of the fact that the constituent concentrations may still meet COP pollutant limits, b remediation for the degradation of the AES power plant discharge into the ocean due to the brine from the desalination plant should be determined and mitigated EXISTING CONDITIONS OCEAN WATER QUALITY States: (Sect 4.0) The Pacific Ocean in the vicinity of the intake is high quality and,in fact,has concentrations of some chemicals that are far below the drinking water MCLs prior to any treatment. An MUN designation would not provide any additional protection because the intake water quality is not influenced by storm water discharges,the Santa Ana River,the Talbert Marsh,or the Orange County Sanitation District(OCSD)wastewater discharge,as described.in the hydrologic modeling studies included in Appendix C,HYDRODYNAMIC MODELING REPORT. Requiring these discharges to meet MCLs in ambient waters would provide no improvement in water quality at the intake to the desalination facility. AND. Elevated Bacteria Levels in the Huntington Beach Surf Zone As stated above, extensive bacterial studies have shown that the Santa Ana River and Talbert Marsh appear to be the primary sources of fecal indicator bacteria to the near shore ocean. In h addition,bird droppings and a reservoir of bacteria stored in the sediment and on marine vegetation may continue to be the source of bacteria at the mouths of the river and marsh. Modeling studies and monitoring data indicate that there is likely another unidentified source of bacteria in the vicinity of Stations 6N and 9N. However,three separate studies conducted between 2001 and 2002 have demonstrated that HBGS is not the source of bacteria in the surf zone. coAMErrr: Neither of the conclusions stated above in this section of the dREIR is supported by the data and facts included in the most recent reports from Orange County Sanitation District"Marine Monitoring 2004 Report."and the Orange County Health Care Agency"Annual Beach Monitoring Report." The beach water quality in the near-shore and surf zone near-by and directly in front of the AES (HBGS)power station(OCSD sites at 6N-9N) continues to exhibit both wet and dry weather bacterial concentrations in excess of AB411 standards,and, in fact frequently above maximum detection limits for the methods uses by the monitoring agencies,OCHCA and OCSD (>400 cfu mpn for enterococci).Further studies of the water quality bacterial concentration in this area are currently being planned by Southern California Coastal Ocean Observing System Nearshore Observation and Prediction Study(HOPS)project. (www.sccoos.or1. The HBGS discharge pipe has not been dismissed as a possible source for these episodic occurrences of bacterial contamination. Ref: www.ocsd.org and www.ocbeachinfo.or�. 7.0 ALTERNATIVES States: 1, Increased Conservation Efforts Adding an extra 56,000 acre-feet-per year to the 84,000 acre-feet of annual conservation that is occurring in Orange County would be difficult because the MWD 2003 IRP Update already set Sign•r canah inCreaScd conservation aa__g eaa-1 or v_a nte County ai0 rc'C_ by 20 20, Ti iLts Ai na 6 II RP target of 882,000 acre-feet for the MWD service area was increased to 1,028,000 acre-feet in the 2003 IRP Update—a regional increase of 145,600 acre-feet per year(see Table 7-2). This equates to increased conservation expectations in Orange County of 64,000 acre-feet over and above the 84,000 acre-feet per year projection,for 2005. To realize an additional 56,000 acre-feet of conservation savings each year would essentially require doubling of the County's future conservation efforts. To double the future conservation efforts of the County in such a relatively short time period would require,at a minimum,the imposition of prescriptive conservation standards for activities,like outdoor residential irrigation,that are today considered discretionary consumptive water use. COAMENT: The comments included in the above statement regarding the MWD 2003 IRP are in conflict with the information received from the Planning and Conservation League referenced in the section 3.0 Project Description discussed above. Recommended alternatives to the proposed project include: 1) Urban water conservation. 2) Agricultural water conservation. 3) Wastewater replenishment(recycled water). 4) Groundwater treatment and desalination. 5) Moratorium on new water connections. It is suggested that the dREIR is both unresponsive and incomplete unless a hill description and comprehensive discussion of all of the possible alternatives are included. Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS 1 9 Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 22 Surfrider Foundation Huntington Beach/Seal Beach Chapter Don Schulz, Executive Committee Member 22a. This text provides an introduction to the comment letter and does not require a response. 22b. Refer to Section 3.0 of the Responses to Comments, ERRATA, for revisions to this conclusion. Note that mitigation measures for air quality, noise, aesthetics/light and glare, hazards and hazardous materials, and construction are also applicable to land use, as stated within the Environmental Summary table. 22c. As stated within Section 6.0, LONG-TERM IMPLICATIONS of the DREIR, the proposed project's electricity consumption would compose approximately 0.1 percent of all electricity loads in Southern California. Moreover, the facility would utilize off-peak electricity to the maximum extent practicable. As stated within the DREIR, this nominal increase on a cumulative, regional basis is not significant. In addition to the comments above, the State Desalination Task Force examined the future state-wide demand of desalination facilities and found energy requirements would not be significant (ENERGY OPTIONS WHITE PAPER, CALIFORNIA DESALINATION TASK FORCE, September 15, 2003, page 1). Also refer to Responses 20 and 1 Oh, above. 22d. Contamination issues apply to all water sources and water storage tanks — the DHS does not differentiate between desalinated seawater, groundwater or surface water. The proposed aboveground product water storage tank will be of comparable size to all other existing water storage tanks servicing the City of Huntington Beach and the Orange County distribution system and will follow the same safety protocol. In order to address the issue of concern, which is an issue for every water treatment plant and water storage facility in California, the California Department of Health Services has stringent requirements for maintaining disinfectant concentration in drinking water to ensure that any potential pathogens (bacteria, viruses, etc.) are killed. The desalination disinfection system and storage facilities have received conceptual approval and will be designed as per the requirements of the Department of Health Services and all other applicable regulations. The treated desalinated water will be chlorinated both prior to entering the 10 MGD product storage tank and after leaving the storage tank, in order to maintain the DHS required chlorine residual. In addition, the disinfection process of the desalinated water does not end at the 10 MGD product water storage tank located at the desalination facility site. The desalinated water does not enter into the existing distribution system immediately after it leaves the tank site. The disinfected desalinated water will travel through approximately 5-miles, of 42 to 48-inch diameter product water delivery pipeline before it enters the existing City of Huntington Beach August 17, 2005 231 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS distribution system. This pipeline provides additional disinfectant contact time of the water thereby further ensuring that the desalinated water will be safe for public consumption before it enters the distribution system. Furthermore, this project will also include continuous operational monitoring of product water quality, including concentration of disinfectant at the tank site (before entering and leaving the tank site) and at the entrance point of the existing distribution system. As indicated on page 5.11-20 of the DREIR, "A monitoring program would be implemented for this location incorporating the following parameters: coliform bacteria, heterotrophic bacteria, chlorine residual, disinfection byproducts, and aesthetic parameters such as turbidity, odor and color, as well as corrosion indices. The purpose of this sampling point is to verify on a regular basis that no degradation of water quality has occurred during any period of storage at the facility site or in the transportation pipeline and that mixing of desalinated water with water from other sources continues to be compatible". 22e. Comment noted. The amount of energy required to produce desalinated water for one family per year is approximately the same as the amount of energy used by the family's refrigerator in one year. One family of four consumes approximately 400 gallons per day (400 gpd x 365 days/yr = 146,000 gallons/yr). The energy used to produce 50 MGD of desalinated water is 30 MW/hr x 24 hrs = 720 MW/day. Therefore, the energy used to produce 1 gallon of water is 720,000 kilowatts/day/ 50,000,000 gallons/day = 0.0144 kilowatts/gallon. Therefore, the total amount energy needed to produce water for one family per year is 146,000 gallons/yr x 0.0114 kilowatts/gallon = 2,102.4 kilowatts/yr. (i.e. approximately 2.1 MW/yr). According to the US Department of Energy Internet Site (http://www.eere.energy.qov/consumerinfo/factsheets/ec7.htmi), a typical 16- cu ft refrigerator uses 725 watts of power. As indicated in this internet site, the annual amount of energy used by the refrigerator should be estimated assuming the refrigerator runs only one-third of the time. Therefore, the annual amount of energy used by one refrigerator is 725 watts x 24 hrs x 365 days /3 = 2,117,000 watts (i.e. 2,117 kilowatts/yr), which is slightly more than the amount of power needed to produce desalinated water for a family of four (2,102.4 kilowatts/yr). In addition, refer to Response to 20 and 1 Oh, above. 22f. The information from the report "Investment Strategy for California Water" is noted. As stated by the commentator (refer to Comment 22i), this information conflicts with information provided in the IRP Update recently adopted by MWD, the region's largest water provider. This DREIR has been prepared in accordance with CEQA Guidelines Section 15121(a) to "inform public agency decision makers and the public generally of the significant environmental effect of a project, identify possible ways to minimize the significant effects, and describe reasonable alternatives to the project." Although not required under CEQA Guidelines Section 15124, information about "Orange County's increasing water needs" and the "need" for the project has been provided in the DREIR at pages 3-36 through 3-45 to supplement the required "statement of objectives sought by the proposed project." As noted by the commentator, this information has been gleaned from "the water plans adopted by state, regional and local water agencies" and did not include information from the "Investment Strategy for City of Huntington Beach August 17, 2005 232 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS California Water" report. While a comment questioning the "need"for the project may be relevant to exercise of "the agency's ultimate discretion on the project" (see, CEQA Guidelines Section 15121[b]), it is not considered to be a "comment on environmental issues" (see Guidelines Section 15088[a]) and does not require further response here. 22g. The California Ocean Plan is discussed at pages 5.10-14 and 5.10-15. The "significant difference" definition in the California Ocean Plan is a specific definition to be used when comparing sampling results and is not the correct criteria under CEQA to be used to analyze this project's potential impacts. Instead, the project's impacts have been extensively studied and evaluated based on the significance criteria clearly stated at pages 5.10-17 and 5.10-18 of the DREIR. The study included in the DREIR (Appendix S) specifically addresses potential effects of the desalination facility discharge on local species passing through the area and surrounding the point of discharge as well as the potential effects on benthic organisms living in the area surrounding the discharge structure. The detailed analysis of the effect of the discharge from the proposed desalination facility on the marine biological resources provided in the DREIR states that this discharge will not cause a significant environmental impact on the marine habitat nor would it impact any endangered species (see page 5.10-36). Therefore, no mitigation measures to accommodate this discharge are required. 22h. As stated in the DREIR, there are various theories as to the cause of bacterial pollution at Huntington State Beach. The theory that HBGS may be a contributor is noted, but does not change any significance conclusions in the DREIR. No further response is necessary. 22i. As required by CEQA, Section 7 of the DREIR describes a "reasonable range" of alternatives to the project which would "feasibly attain most of the basic objectives" of the project. Increased conservation efforts, increased use of groundwater supplies and water recycling are described as part of the "No Project" alternative in Section 7.1. Also refer to Response 22f, above. City of Huntington Beach August 17, 2005 233 COMMENT 23 City of Huntington Beach MAY 2 4 2005 1076 Skyline Dr. Wadur Laguna Beach, CA 92651 (949) 494-8960 www.waderllc_com �4ay 20, 2005 W. Ricky Ramos Planning Department PO Box 190 Huntington Beach, CA. 92648 Dear Sirs: Re: Seawater Desalination Project at Huntington Beach We appreciate the opportunity to comment on the Draft Recirculated Environmental Impact Report for the above Project. As a small organization, Wader LLC was established to support the research and development of inventions in oceanographic technology. The company is dedicated to the creation of inventions that benefit ocean ecology. The company holds patents on methods of generating energy through a process involving the mixing of salt and fresh water. During April 2005, an additional patent application (described below) was filed on a method of mitigating water pollution, especially concentrated seawater from desalination treatment plants Obviously, a critical aspect of the project as pointed out in the EIR related to the selected site is "to utilize existing ocean intakeldischarge lines of sufficient seawater volume to avoid the impact of 8 constructing new intake/discharge facilities". However, based on the hydrodynamic modeling, we believe we can offer a solution to the brine issue. Currentiv under development we have demonstrated, with our device, dilution of 70 ppt brine into 35 ppt tanks to a level of 3% above ambient. The background salinity near the Huntington Beach project varies around 33.0 to 34.0 ppt. An average salinity value of 33.52 ppt was used in earlier calculation (see Jenkins and Wasyl, 2001). The desalination plant anticipates recovering 50% of the 100 mgd intake from the discharge cooling lines of 'the generating facility. The reject water from the membrane treatment would yield salinity about double the Salinity of fine c .avvat�r intake �r 67,04 pnt_ 'i'hig hioh caiinr>avatPr wn»lr� he r�icrharaPcl intn a nnnLl J r _s o-- r- prior to entering the outfall. At the terminus of the outfall, the concentrated seawater discharge salinity is a function of the number of power generator operating (more precisely, the number of pumps to service the generators). From the hydrodynamic model study, if only one generator is operating, the plant discharge could reach 5 5.3 7 ppt. (pg. C-114). The EIR states that during "low flow case", the salinity exiting the discharge outfall is anticipated to be 55.4 ppt while during "average flow cases", the salinity exiting the discharge outfall is estimated to be 41.7. The point of greatest salinity difference is where the reject water from the desalination treatment enters the pond. Our device should be able to maintain a 3-4% above ambient level of salinity_ To highlight our systems we enclose a diagram below of atypical setup with averaged salinities noted m,parts per thousand (ppt). 1 T Diameter"Skim' 72.4 reservoir •meter locations water level • 352 injector upper • tube 36.s lower tube 36.4 We have generated electricity from the kinetic energy available at the exit of the smaller tube (labeled `upper tube in drawing) in a substantially similar device. We are engaged in research and development of a prototype that will enable the desalination facility operator to recover through self-generation a portion of the expended energy, thus dramatically saving costs of energy. We would be happy to arrange a demonstration at our test facility, a 50,000-liter tank in Laguna u,:ttg at yn=.rr convenience f,r y n„ nr yn„r et�f P1eacP ca}i V�arren Finley at 949-494-8960 or email him at wfinlag,waderllc.com if you desire such a demonstration. For technical advice, please email Dr. Anthony T. Jones,Ph_ D. at-i��ocean@,dc.rr.com. Yours Duly. Narrate Fin1Pv a Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 23 Wader LLC Warren Finley 23a. This comment letter does not contain information pertinent to the DREIR, and does not require a response. City of Huntington Beach August 17, 2005 236 INDIVIDUAL COMMENT LETTERS ' imam .::... :.'�' �.. �UaOise:Sf:>{;3''?3'4.'h•4G`ik4.,4�;%"ur...,..idrvr.:iro,..�..,...1....<.,.c,....o..,.._..,...._�_,w..s.......................... f�q%✓'r,x6" 7 fit A� ry da e1p� v • �� �� � I � I I k I I lYit 'h`1 P �1/. fir, �• ' ' (� i I �i. � ;� X��. p 'n ,�€� 41 (� i,�4 Ij.f.. � I "� • � Tl�r � � 1i� I[fJJr F(/.li� M� !y �� �u /• •� i�C,.�.:. * �Wf��' f ) u,t'� k�."^ �y 'SCR "s� Fsr✓'"m'.'`�f Ve �' e 1 '� "�I l r.,""f'i- _. T�~'<I�, • Via:,',.1�.' w' .. O I.. r Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 24 Patricia Aurelius 24a. The commentator's belief that "we should be looking at conservation and recycling water instead (of seawater desalination)" is appreciated. However, recycling and conservation were analyzed as alternatives to the proposed project within the DREIR in Section 7.0. ALTERNATIVES. No specific conservation or recycling program has been identified that warrants a more detailed response. If the commentator's statement is valid, demand for imported water supplies would not be increasing and the California Water Plan would not need to consider all feasible water supply opportunities including desalination of water. Also refer to Response 2ag, above. City of Huntington Beach August 17, 2005 238 COMMENT 25 I; �r �•� ,�:' l 1; i�j�� ��.d �' ��!r o•�w Eo ��2 �6�� Le11 f>c�.���Y C s C/� /✓Gl� �J��''� 5�v+ �!Jt'1 C c,.� ��-lac I.Z l��' � PAP S 1F A f�Ucs� �Ja)v; a c�S G is �P25�5 i'O 15��i s /L7 it✓@U/c�lWf� 11 � ���SYf�vcv �a: GS '`2-WAY A !'�-po Cj l ti fc �sl/3 ,�Y (( Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 25 Frank Bradley 25a. The pipeline alignment is proposed to run for approximately 1,800 feet within Newland Street. As stated within the DREIR, construction of the pipeline would include measures to minimize impacts to adjacent sensitive receptors, including (but not limited to) the preparation of a Traffic Management Plan, acquisition of necessary permits from the City, and multiple measures to reduce air quality and noise impacts. City of Huntington Beach August 17, 2005 240 COMMENT 26 May 1'), 2005 Ricky Ramositi �'Ur�`r„ #� Associate Planner ` i b City of Huntington Beach Dept. of Planning 2000 Main St. P.O.Box 190 Huntington Beach, Ca. 92648 Subject: Proposed Poseidon Seawater Desalination Project Response to Draft Recirculated EIR 4/5/2005 Dear Mr.Ramos: Although I am not a resident living in the city of Huntington Beach,I am a resident of South Orange County,I am opposed to the desalination project in your city for the following reasons: 1. Growth Inducing Qualities of Proposed Desalination Plant—Aiding future Development(particularly South Orange County): The projected 50 mgd has never.been intended(nor needed)for Huntington Beach. Poseidon reported in the beginning that it had found a customer to purchase 50% of the a proposed 50 mdg. And•a tentative arrangement was made between the Santa Margarita Water District and Poseidon to purchase water at$800.00 an acre-foot. This agreement is apparently and hopefully off the table. As a resident of South Orange County,I do not want to have to pay a higher price for water from the desalination plant. It does not make-sense to me. Poseidon has denied that the proposed development in Rancho Mission Viejo has not been considered as a requirement to justify building a plant of this size, but I do not believe that. If the proposed desalination plant is not approved, it will become much more difficult for the proposed Rancho Mission Viejo development to go forward— WHICH IS FINE BY ME! 2. Water conservation and recycling water makes more sense.to me. This should always be our first line of defense. As long as we have urban runoff,we know we are not conserving enough water. There is a huge untapped potential to con- serve water that would eliminate the need to build this plant. The savings alone($250.00 vs. $800.00)justifies creating citywide conservation projects, i.e.: low-flush toilets,low-flow shower heads, changing outdoor watering habits, laundry habits,etc. The IRWD currently has a very successful tiered pricing schedule that SHOULD be implemented in other Orange County Cities. Our city government and municipal water districts should be investing in re-cycling technology and advertising the power of conservation rather than considering an EXPENSIVE,UNNECESSARY PRIVATIZED desalination plant. b Thank you for compiling these written comments. Sincerel �Iesli ri an 71 Giotto Aliso Viejo, CA 92656 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 26 Leslie Brian 26a. Comment noted. No purchase agreements between the project applicant and local water purveyors currently exist. 26b. Refer to Responses 2ag and 24a, above. City of Huntington Beach August 17, 2005 243 COMMENT 27 From: Kelley, Jason Sent: Monday, April 04, 2005 10:03 AM To: Ramos, Ricky Subject: FW: poseidon desalination plant -----Original Message----- Fiom: Ricbuliton@aol.com rmaiitO:Ricbu,ioi..@ay.comj Sent: Monday, April 04, 2005 9:58 AM To:jkelley@surfcity-hb.org Subject: poseidon desalination plant My name is Ric Button. I live adjacent to Edison Park. I am concerned with the plan to build a desalination plant next to the AES power plant. It is my understanding that the AES plant was given a conditional use permit to continue operation during the energy crisis and that will expire within the next few years. The intake and out take pipes are less than 112 mile offshore. The beach in front of AES is closed off and on for extended periods of time due to bacteria. There have been nigher than nog mal cases of brain•tumors and cancer in people in Hun ivngto,� Beach living near or under the AES transmission lines. Many studies have been done by SC Edison, but a even though AES has been retrofit it still is operating with 50 year old plus technology. If nothing else the intake out take pipes should be extended 5 miles offshore. I am sure this would not be considered if Huntington Beach owed the beach if front of AES and not the state. I am also concerned that our city would propose to add another environmentally sensitive project when others have not been taken care of. For example,AES power plant, the ASCON/NESI site or the methane gas in Edison Park. Please do not allow the desalination plant to be built. Please do not sacrifice our beautiful coast line in Huntington Beach where so many of us like to go to the beach with our families and friends. Sincerely, Ric Button 8642 Hatteras Dr, Huntington Beach, CA 92646 (714)969-9030 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 27 Ric Button 27a. Elevated bacteria levels off the coast of Huntington Beach in relation to the proposed project are analyzed within Section 5.10 of the DREIR, OCEAN WATER QUALITY AND MARINE BIOLOGICAL RESOURCES. Potential hazardous material impacts due to surrounding uses are analyzed within Section 5.8, HAZARDS AND HAZARDOUS MATERIALS. Impacts were found to be less than significant. City of Huntington Beach August 17, 2005 245 COMMENT 28 From: Debbie DeMeulle[debbie@demeu Ile-org] Sent: Friday, May 27, 2005 4:44 PM To: rramos@surfcity-hb.org Subject: Poseidon desalinization project and EIR Dear Council Members, We ask that you vote no on the proposed Poseidon desalinization project and a EIR for Huntington Beach. As citizens that border the surf, our responsibility to act carefully is even greater with regards to the public ocean waters. On our coast we already have so many issues affecting our ocean. We have the lingering unknown definitive source of beach closures, the aged AES plant, treated sewage from the Orange County Sanitation District, urban runoff and the wetlands impacting our local beach. b These issues combined with the fact that we have been trying to transform our city into a tourist destination, makes this a bad combination. Would this be the best use of coastal land in conjunction with your efforts for tourism so close to the proposed project? On top of all this is the fact that Poseidon is still an unproven partner. Their Tamba Bay project has been plagued with problems. Huntington Beach has had more than its' fair share of troubled dealings and projects recently. Furthermore, there are those that have questions about foreign corporations having some control of our local water supply_ C We have other less costly and less impacting avenues available to us in terms of increasing our water supply. Please vote no on the proposed Poseidon desalinization project and EIR. Thank you for your time and consideration, Debbie DeMeulle Edward DeMeulle HB Residents No virus found in this outgoing message. Checked by AVG Anti-Virus. Version: 7.0.322 / Virus Database: 267. 0.0 - Release Date: 5/27/2005 1 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 28 Debbie DeMeulle Edward DeMeulle 28a. This text provides an introduction to the comment letter and does not require a response. 28b. Comment noted. No response is necessary. 28c. The statutory scope of the California Environment Quality Act (CEQA) requires that physical changes to the environment that occur as a result of a project be analyzed, disclosed, and mitigated where feasible. The CEQA statute requires that "substantial evidence" (i.e. facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts) be provided to support any conclusions made about potential physical changes to the environment that occur as a result of a project. The financial problems, construction delays, or other adverse issues that concern the Tampa Bay seawater desalination plant do not constitute any type of legitimate evidence for analyzing the environmental effects of the proposed Seawater Desalination Project at Huntington Beach. In addition, refer to Response 17d, above. City of Huntington Beach August 17, 2005 247 COMMENT 29' City of Huntington i3eGy,h. MAY 2 6 2005 Nancy M Donaven 4831 Los Patos Avenue Huntington Beach, CA 92649 . 714/840 7496 ndonaven@fea.net May 25, 2005 City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 Attn: Ricky Ramos,Associate Planner Regarding: EIR#2001051092 First things first, why was this project ever planned? I know that there is data in the report indicating that there will be development and infill, etc. but nowhere does it say a who will be using the water produced The rationale for building this project is lacking. What will be the difference in the operation of the AES plant if this plant is built? That is, how many days and how many AES units operate now and how will that change b with the Poseidon plant in operation? The amount of water that this plant is projected to produce can support a large C community. What,in detail, are the growth inducing aspects of this production? How was the number$2,000,000 arrived at as the amount the City of Huntington Beach d would receive annually as a consequence of this plant's being built? What is the reason that, given an EIR is supposed to be neutral, more attention was not e given to conservation? Who owns Poseidon Resources? f What will be the impact on tourism of this facility,both as to looks and as to the effect on the beach and swimming? g What is the financial position of the company proposing this project? Are there some recent financial statements available as well as a few older ones? h Sincerely, Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 29 Nancy M. Donaven 29a. The needs and objectives for the proposed project are provided within Section 3.0, PROJECT DESCRIPTION of the DREIR. 29b. The proposed desalination facility would not alter operations at the HBGS. 29c. Growth inducing impacts of the proposed project are analyzed in Section 6.0, LONG-TERM IMPLICATIONS OF THE PROPOSED PROJECT. 29d. The financial relationship between the proposed project and the City of Huntington Beach is not relevant to the DREIR, and no response is necessary. 29e. Increased use of water conservation measures was analyzed in detail under the No Project Alternative in the alternatives analysis; refer to Section 7.0, (ALTERNATIVES TO THE PROPOSED ACTION). 29f. Ownership of Poseidon Resources Corporation is outside of the scope of CEQA and does not require a response. 29g. Aesthetic and ocean water quality impacts are analyzed within the DREIR in Sections 5.7 and 5.10, respectively. 29h. The fiscal status of the applicant is outside the scope of CEQA and does not require a response. City of Huntington Beach August 17, 2005 249 COMMENT 30 oily Of Hunting- Jamest & Cindy Douglason$`ach 17322 Whetmore Lane APR Z 62005 Huntington Beach, Ca 92647 (714) 596-1222 Ricky Ramos City of Huntington Beach Planning Dept. 2000 Main Street Huntington Beach, CA 92648 Dear.City of HB: We are strongly opposed to a Seawater Desalination Project in Huntington Beach. We feel that the unpact from construction-related air quality to our City is a significant threat to the children and adults who already suffer from a asthma and other airborne allergies. Again, we are opposed to a Seawater Desalination Project in Huntington Beach. Jim & Cindy Douglas Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 30 Jim and Cindy Douglas 30a. Construction related air quality impacts would be mitigated through preparation of a dust control plan and adherence to City and South Coast Air Quality Management District (SCAQMD) regulations. As detailed within Section 5.9 of the DREIR, and despite the implementation of standard conditions, project design features and mitigation measures, a significant and unavoidable short- term air quality impact would remain. The proposed project is anticipated to exceed SCAQMD thresholds in regards to short-term air emissions (remediation, demolition, construction). Mitigation measures will be implemented, but these measures are unable to reduce NOX emissions to a less than significant level according to SCAQMD thresholds. This impact is overridden by the benefits that could be provided by the proposed project. There are no feasible alternatives that could avoid this significant impact. Moreover, the South Coast Air Quality Management District and California Air Resources Board have jurisdiction over stationary and mobile emission sources, respectively. City of Huntington Beach August 17, 2005 251 COMMENT 31 1853 Bentley Lane Huntington Beach, CA 92648 May 26, 2005 c-tty,kot Huntington Beach Ricky Ramos MAY 2 7 2005 Associate Planner City of Huntington Beach Dept of Planning 2000 Main Street Huntington Beach, CA 92648 Dear Mr. Ramos, I am writing to express my opposition to the construction of seawater desalination plant at the AES plant here in Huntington Beach. The process pollutes the beach, kills ocean life, and is very energy-intensive. Huntington Beach won't be using the water Poseidon a takes from the ocean. I know that water is replacing oil as liquid gold but I do believe that we can do more in the way of conservation recycling before we implement desalination plants to meet our water needs. It is fiscally irresponsible to commit resources to such a risky endeavor that would impose huge costs on our citizens and impair our coast. I ur a the City Council to vote against the Poseidon plant. Sincerely, Patricia M. Goodman, CPA Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 31 Patricia A. Goodman 31a. The proposed project's potential ocean water quality, marine biology, and energy impacts are analyzed within the DREIR. For a response in regards to conservation as an alternative to the project, refer to Responses 2ag and 24a, above. City of Huntington Beach August 17, 2005 253 COMMENT 32 May 17, 2005 Mr.Ricky Ramos City of Huntington Beach Dept. of Planning ,,;� � P.O. Box 190 Vje I11:ntington Beach; CA 92648 RE: Comments against Proposed Poseidon Desalination project— Writing in opposition to this expensive plant Dear Mr.Ramos: Please enter my continents into the official public records in response to the Draft Recirculated EIR report dated April 5, 2005. I am against this project for the following reasons: Ocean destruction—Impingement and Entrainment It is my understanding that the proposed desalination plant will share a seawater intake system with the AES power plant. When the power plant is in full operation it sucks in 240 million a gallons daily. Normally, the AES plant is not ill operation 24 hours per day; it is usually in operation during the daytime hours when power usage is at its peak. Based upon the huge amount of water required to operate the proposedplant at viable economic levels, the Poseidon would force AES to operate at night when marine life is much more active. The intake system will suck in and destroy billions of fish eggs and plankton that is a vital part of the marine food chain. These smaller life forms will get caught in the screen(impingement)and larger marine lire may get sucked into the pipes (entrainment). 100 million gallons will be used by Poseidon to produce a projected 50 rmillon gallons of drinking water. Approximately half of this will be thrown back into the ocean,in the form of brine. The area in front of both plants has already been shut down numerous times because of high bacteria levels. Huntington B each is creating a dead zone. And,building another plant is not going to improve the polluted waters. As a resort destination, Huntington Beach cannot afford to shut down its beaches on a regular basis. Conservation and recycling water makes a lot of sense and costs much less Y g - After 4 years of drought,Huntington Beach never came close to running out of drinking water. Shouldn't the city seriously consider a conservation plan before building a very expensive desalinationpl t? Many other cities have successfully adverdsedprograms such as low-flush toilets and low-flow showerheads or provided incentives. Changing citizen habits to run only full b loads of laundry or to water in the early morning or less often could yield significant water. Our whole region could be part of a conservation program Desalinated water is very expensive and ranges in price from$800-2000 per acre foot as compared to drinking water obtained through conservation or recycling methods at approx. $250 per acre-foot. We have all the technology already in place. Future Development may be dependent upon Poseidon Since Huntington Beach doesn't need this water and can't afford it, who are the intended customers? I am deeply concerned that future development in south Orange County may be C dependent on approving this project. It was reported in the LA Times in Nov. 2003 that the Poseidon Corporation had tentatively signed an agreement with the Santa Margarita Water District. If it ca-n be shown that the Poseidon maybe encouraging future growth in Orange Country by providing developers such as Rancho Mission Viejo with a reliable water source then the City of Huntington B each must vote no to stop this misguided plant in its tracks. C Thank you! Please let me know when the public hearings are scheduled to take place. i Sin rc4y, fJ Lia A. Hernandez 8232 Munster Dr. Huntington Beach, CA 92646 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 32 Lia A. Hernandez 32a. Refer to Responses 1 b, 1 d, and 2c, above. 32b. Refer to Responses 2ag and 24a, above. 32c. No purchase agreements are currently in place for potable water produced by the proposed project and it would therefore be speculative to discuss potential end users. Growth-inducing impacts from the proposed project are analyzed programmatically in Section 6.0, LONG-TERM IMPLICATIONS OF THE PROPOSED PROJECT. In addition, refer to Response 2as, above. City of Huntington Beach August 17, 2005 256 COMMENT 33 May 13, 2005 Mr. Ricky Ramos ,T1 V t } Associate Planner City of Huntington Beach a IVJ Dept. of Planning 2000 Main St. P.O.Box 190 Huntington Beach, CA 92648 RE: WlZtten Comments—Proposed Poseidon seawater desalination project— In response to Draft Recirculated EIR dated 4-5-05 Dear Mr. Ramos: Please accept this letter as my official written comments in opposition to the proposed 50 mgd seawater desalination plant. I am opposed to this project_for the following reasons: 1. Entrainment and'Impingement—inherent to the reverse osmosis technoloanr & adverse environmental impacts Billions of fish eggs and plankton as well as larger marine life are sucked into a the shared once-through cooling intake system When AES is in full operation, it takes in approx. 240 million gallons of seawater daily; the proposed Poseidonproject would require 100 million gallons of that to produce 50 mgd of drinlang water. For every 100 gallons of water taken in,Poseidon would throw 50-85 gallons of brine (salt)back into the ocean. In addition, to make desal water taste more like potable water requires additives such as lime. The coastal waters between Newland and Ma-iolia already have high levels of pollution. Let's not add to this problem. 1 2. A 50 mgd reverse osmosis seawater desal plant is unproven in the United States The Tampa Bay plant, which is V2 the size of the proposed H.B. plant, is still b not running successfully 3 years after the scheduled operational date and may not be on until 2007. The construction costs went way over budget, three building contractors went bankrupt and Poseidon has beenbought out. Why would we bring such a questionable and disastrous project to Huntington.Beach? 3. Potential Problems associated with Antiquated AES Power PIant The AES plant was built in the 1950's and will require serious upgrades and maintenance to remain a viable power producer over the coming decades. The s - California Energy Commission(LA Times,Nov. 16, 2003)has reported that the AES plant operates at 25%power capacity. In order for Poseidon to produce 50 mgd, it C would need to run at full capacity, 24 hours a day over 90% of the time. And, the AES plant schedule runs primarily during daytime hours when power is most needed_ With Poseidon operating around the clock, environmental impacts would be higher since marine life is more active at night. And,if AES closed down in the next few years, how would that impact the operation of the proposed desalination plant? AES has to renew its 316(b)permit, which it might not be able to do because of the once- through cooling systein. These questions must be answered fully before proceeding C any further. 4_ Reverse Osmosis Desalination is expensive The price per acre-foot of desalination water could range as high as 580042000. When compared to pumping local water from underground aquifers -5292. or Q imp orting water from outlying areas-$460., we simply can't afford it. And, 33-50% of the costs associated with seawater desalination are connected to energy. As energy costs go up in the future, water obtained through this method becomes even less affordable. 5. The site of proposed desalination plant is over a seismic fault line(s) The proposed construction site-for!Poseidon is L25 miles.away from the Alquist= Priolo earthquake fault line. In addition,the Newport Beach fault line is close by And the South Branch fault is located beneath the subject site. This geological area e is prone to liquefaction potential. It requires special studies including site-specific seismic analysis and expensive engineering to eliminate the dangers of lateral spreading and geologic hazards. The bottom line is that the danger inherent to this site adds even more to the already high price tag associated with seawater desalination. And, even with the best engineering techniques,there are no guarantees as we saw with the recent mudslides due to unstable hillside conditions and inadequate compacting. I could list many more conunents but I just want to emphasize that this project is in conflict with the Public Trust Doctrine. Privatizing water and placing it in the hands of corporations opens the door to high profit margins and growth incentives. Water is a precious natural resource. Let's protect it for future generations. Thank you for compiling these public comments. Please let me know when the public hearings are scheduled Sincerely, i If= Lynda A Hernandez 8232 Munster Dr. Huntington Beach CA 2 "6-5040 714/803-9676 (cell) Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS J 9 Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS 1 Response No. 33 Lynda A. Hernandez 33a. Comment noted. No response is necessary. 33b. Refer to Response 28c, above. 33c. Refer to Responses 1 g, above. 33d. Economic impacts are outside the statutory scope of CEQA unless substantial evidence can demonstrate that an economic effect would result in a physical change to the environment. The cost of product water is not relevant to CEQA, and does not require further response. 33e. Potential geologic and seismic impacts are analyzed in Section 5.2, GEOLOGY, SOILS, AND SEISMICITY. All impacts in this regard were determined to be less than significant with mitigation. 33f. The proposed project would be subject to the same requirements and regulations that a similar publicly-owned facility would be subject to. Moreover, a publicly- owned facility would result in the same environmental impacts as the proposed project. In addition, refer to Response 2aq, above. City of Huntington Beach August 17, 2005 259 COMMENT 34 May 27, 2005 MAy 2 170,,r i Ricky Ramos 2000 Main Street Huntington Beach, CA 92648 Dear Mr.Ramos: Re:Inadequacies in EIR for Desalination Plant in Huntington Beach 1.The EIR has not adequately addressed the traffic problems caused by their alternative of the pipeline that will go into Costa Mesa and Newport Beach as well a as the compromising our streets in Huntington Beach. 2.There was no mention of the increased use of electricity needed by the desalination plant in this EIR. The desalination plant needs heated water 24/7 for b 365 days of the year. The AES plant only heats the water 260 days of the year. It runs the water but does not heat it for the 105 days of the year. 4.More effluent will be going back into the ocean. The EIR does not explain adequately the adverse impacts that the proposed desal-plant will have on the concentration of marine life in the ocean area. The coastal waters in Huntington C Beach are an economic engine for Huntington Beach. How will this desal plant discharge affect local fisheries and other marine life? Sincerely, Flossie Horgan 207 212t Street Huntington Beach CA 92648 1 ' r Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 34 Flossie Horgan 34a. To clarify, no pipelines are proposed to occur within the City of Newport Beach. Portions of the pipeline proposed within the Cities of Huntington Beach and Costa Mesa would be subject to the requirements of the relevant jurisdiction. Traffic impacts due to pipeline construction have been addressed properly according to CEQA in Section 5.9, CONSTRUCTION RELATED IMPACTS, of the DREIR. In addition, mitigation measures CON-31 through 36 would apply to the construction process. 34b. Impacts in regards to electricity consumption are analyzed within Sections 5.6, PUBLIC SERVICES AND UTILITIES and 7.0, ALTERNATIVES TO THE PROPOSED ACTION, of the DREIR. The desalination facility's reverse osmosis membranes do not need heated water to produce drinking water. The reverse osmosis membranes can produce drinking water with non heated seawater. Refer to Response 2p, above. 34c. Impacts to marine biological resources are analyzed within Section 5.10 of the DREIR. City of Huntington Beach August 17, 2005 261 =_ COMMENT 35 Bazant, Denise From: Dapkus, Pat Sent: Tuesday, April 05, 2005 4:41 PM To: Bazant, Denise Subiect: RV: Desalination plant ---Original Message---- From: John Howell.[mailto:jhowell@socal.rr.com] Sent: Tuesday, April 05, 2005 3:22 PM To: city.council@surfcity-HB.org Cc: Pat Dapkus; Cathy Fikes Subject: Desalination plant I am a home owner, resident of Huntington Beach. I am opposed to the building of the desalination plant next to AES. We have a beautiful coastline, and the last thing this generation should be doing is adding a factory to our coast's shoreline. The city does not need high priced water and we don't need to add a a symbiotic plant to help keep AES in operation(a great blot to our scenery.also.) Help keep the coast line beautiful and reduce,not add to the heavy industry on our shores. If the desalination plant is built,the 1 next thing we will hear is that the power plant needs to expand and produce more steam. We don't need it. . John D. Howell 20321 Bancroft Circle H.B. r - , r Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 35 John D. Howell 35a. The proposed project would be constructed within an industrial area and would be consistent with existing City land use and zoning designations. Also refer to Responses 1g and 20r, above. City of Huntington Beach August 17, 2005 263 COMMENT 36 FRDM FAX ND. :71494=21 May. 27 2005 05:53PM P1 Karen Jackle 6702 Lawn Haven Dr. Huntington Beach, CA 92648 714-848-4040 FAX 714-848-3321 karene?p jeckle,com ' 5/212005 Ricky Ramos City of Huntington Beach Planning Department 2000 Main St. Huntington Beach, California, 92648 iRE: EIR for Poseidon Desalinization Plant Huntington Beach, California, 92648, As a concerned resident who enjoys our beach, our air and safe drinking water of our community,I wanted to write to you about the EIR for the proposed desal plant ' which piggybacks on the water being used now by the existing power plant. Although it is cost efficient for Poseidon to use the ocean water from the power plant which is warmed by the processing it receives before it get to the reverse esmosis,what happens to the costs if the power plant is not heating the water? The projections appear to be for the Poseidon plant to be operating every day while a the power plant does not have to heat the water all year,just two-thirds of the time. The costs assume the water will come to the desalinization plant warmer than they are in the ocean.Who pays for the fuel to heat the water when it is riot warm enough to be directly utilized for reverse osmosis? If above is correct then the costs need to be adjusted upwards to allow for the increased fuel and of course,the benefit of the tax an the fuel used also needs to be factored into the economic benefit to the city.The air quality will be affected by the need to use fuel to heat the water.I do not'know if that would be enough to have a significant effect on the air quality in our community. Since there is not documentation available in the desal EIR posted on the Huntington Beach City Website showing the Environmental Impact Report for the existing AES plant which may require new documentation since an alteration is being trade to what is existing,there is also no analysis of mitigation efforts which may b be required since the water is not just going to exit AES as it did before but goes through another process before it then goes back into the ocean.It seems the information should be trade available on this change since it affects the overall 1 FROM FAX N0. :71484e3321 May. 27 2005 05:53PM P2 picture of the costs and impacts of adding a desolinization plant to an existing b process that consumes fuel and the products of its processes go into the air and the water. — Although our city u..! receive an emergency water storage facility,I also wander w who will covner the cost of the maintenance of it if in the future, The plant becorn �► part of a public utility and is no longer in private hands. Thank you in advance for addressing these concerns. Sincerely, Karen Jackie 2 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS J 9 Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 36 Karen Jackie 36a. Refer to Response 34b, above. 36b. The HBGS is not in the process of altering its cooling water system. It would be speculative to analyze the impacts of a change in the HBGS cooling water system at this time. Also refer to Response 2an, above. 36c. Maintenance of the desalination project would be privately funded under the proposed project. There are no plans for a public agency or utility to acquire the proposed desalination facility. Therefore, any analysis of potential maintenance costs by a public entity would be speculative. City of Huntington Beach August 17, 2005 266 COMMENT 37 City of Huntington i3O-cotry MAY 2 6 2005 To: City of Huntington Beach Planning Department/City Council Re: Poseidon Date: May 25, 2005 Regarding the EIR for the potential Poseidon facility.It appears to me that not all the possible environmental hazards to this city are clearly defined and understood. There are many issues that are unknown and unresolved. However,it is worthwhile to point out some glaring potential issues. Quoting the report about the long term implications, "the local marine environment surrounding the HBGS outfall may experience long-term changes in regards to increased salinity due to the a proposed plan's concentrated seawater discharge,but impacts to biological resources are not anticipated to be significant." The stated fact of the change and increased salinity should be a red flag in itself. Then the statement that the"impacts to biological resources are not anticipated to be significant" (italics mine)would seem to be of enough significance to not allow this project to go through. That the impact is not anticipated to be"significant" is a not only"best-guess", but also,what do we mean by significant?I would venture that to those of us who live here,pay taxes here and go to the beach here what is "significant"would be considerably different than Poseidon thinks is significant. We here at the California coast in general, and in Huntington Beach in particular have a unique beach/coastal/ocean environment. It is important to our economy, our well-being, and our health. Obviously we cannot know,until it happens,how wrong things can go. Of course by then it would be too late. Everyone would look at the Poseidon project in ' hindsight.and state that it should have been clear at the outset that it was an b environmental fiasco waiting to happen_ iWhat are needed at this time are city officials who can lead,not by hindsight,but with clear vision on this project that is so wrong on so many counts. To approve it would be t gamble and I,for one,think we cannot take that risk. I strongly urge a no vote on the Poseidon project. Sincerely Annie A. Jelnick 22031 Capistrano Lane Huntington Beach Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 37 Annie A. Jelnick 37a. Specific criteria for determining the significance of marine biological impacts are provided on pages 5.10-17 through 5.10-18 of the DREIR. Under these criteria, impacts to marine biological resources were determined to be less than significant. These criteria were taken from the CEQA Guidelines and the California Coastal Commission's Seawater Desalination and the California Coastal Act, September 2004. 37b. Comment noted. No response is necessary. City of Huntington Beach August 17, 2005 268 COMMENT 38 City �ut�r, dQ�Cf Mr.Ricky Ramos, City of Huntington Beach Planning Department, 2000 lyfa-in St, Huntington Beach,California, 92648, Sir, I am writing in regards to the Huntington Beach plan to create a desalination plant. . There are too many uncertainties with the cost of the project an?'-history in other attempts at using desalination to. facilitate additional drinking water have fallen well below the pfojections. a i 1 It is a bad precedent to allow any form of privatization into the water business. Water is too critical to all walks of life°to take it out ofpublic ownership I hope you will consider my opinions when making your decisions that will affect all Californians. Please feel free to contact me regarding this issue. cer 1 Sin e y, 4arlene Little ' 9882 Spruce Court Cypress,Calif.90630 714-827-0055 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 38 Darlene Little 38a. Refer to Response 33d and 33f, above. City of Huntington Beach August 17, 2005 270 COMMENT 39 City of Huntington Beach MAY 2 4 2005 Attn: Ricky Ramos Project Planner City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 Re: Public Comment-Seawater Desalination Facility Dear Planning Department& City Council Members: - A salesman has once again hit _up city hall with_a spotty track record-and lukewarm references.This salesman, Poseidon a Resources Corporation and their desalination plant, should be escorted to the door by the city council and asked not to return to the City of Huntington Beach. Poseidon is offering a technology that is unproven and not urgently needed. Sure there will be a need for additional water sources in the future, but why should Huntington Beach be the guinea pig when water still flows freely at a reasonable price? ■ This is especially true since the proposal site at Newland and PCH is quickly becoming incompatible with it's residential and b tourism based neighbors. And we must ask ourselves, what would happen to the tax dollars generated from tourists if our beaches become fouled as a result? Futhermore, Poseidon is a private entity who will not answer to the city but to their investors. We might as well have the Arrowhead or Sparkletts truck drop off extra bottles-for our sprinklers, showers and laundry. When a profit motive gets mixed C up with public utilities, the result is often a higher price. At an estimated $850 per acre-foot of desalinated water(2 to 3 times the current price),the writing is on the wail. If desalination becomes a proven technology in other nearby communities, then perhaps we should consider it. But as most smart businesses, organizations and municipalities do, Huntington Beach should avoid excessive risk and reject Poseidon's bid d to build a desalination plant on AES property. The promise of any real return for the city in this case is highly questionable. Sincerely, avi Maricich 21292 Banff Lane Huntington Beach,CA 92646 1 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 39 David Marich 39a. This text does not contain information relevant to the DREIR. No response is necessary. 39b. The reliability of seawater desalination technology is shown in Appendix X of the DREIR, DESALINATION FACILITIES THROUGHOUT THE WORLD. Seawater desalination facilities operate in over 120 countries worldwide, primarily in the Middle East and Mediterranean. 10 large-scale production facilities (the smallest being 9.2 MGD and as high as 45 MGD) have been constructed within the past 10 years. Worldwide, seawater desalination facilities produce over 3.5 billion gallons of potable water per day. In addition, the proposed project would be constructed within an industrial area and would be compatible with existing City land use and zoning for the site. Regarding "beaches becoming fouled" as a result of the proposed project, refer to Section 5.10 of the DREIR, OCEAN WATER QUALITY AND MARINE BIOLOGICAL RESOURCES. 39c. Refer to Response 20r, above. 39d. Comment noted. No response is necessary. City of Huntington Beach August 17, 2005 272 COMMENT 40 1 U , 1 - i - I i i 1 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS J 9 Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS ' No. 40 Response ' Maureen Mills 40a. This text does not contain information relevant to the DREIR, and does not require a response. 40b. All air quality impacts of the proposed project were determined to be less than significant with the exception of construction related NOX emissions (refer to DREIR Sections 5.4 and 5.9). However, this impact would be short-term in nature, ceasing after the completion of the construction process. ' 40c. This text does not contain information relevant to the DREIR, and does not require a response. City of Huntington Beach August 17, 2005 275 COMMENT 41 May 4, 2005 �► �p,`� p 5 Z��� Ricky Ramos Huntington Beach Planning Department 2000 N. Main Street HB CA 92648 RE: Draft Recirculated Environmental Impact Report 2005 iFiaCAreryj4 6eS lit tltE � f�si besaiii'iCit iu+il �slri�tt 25 1. The EIR the AES plant should have been included in this from e p a EIR. In my opinion the decal piggy backing on the AES plant makes their EIR relevant. ' 2. Did the AES plant have any significant impact on the air quality b since it only ran 2/3'd of the year? If so the Desal which is running another 1/3 of the year should have considered the existing impact by the AES plant. 3 .IMPACTS Significant Criteria EIR Air Quality 5.4-11" Violate any air quality standard or contribute substantially to an existing or projected air quality violation; Who knows what the EIR for the AES plant said about Air Quality? C EIR 5.4.11 "If the project causes an exceedance of either the state one-hour or eight hour CO concentrations, the project would be considered to have a significant local impact." This EIR does not take in account the AES.conditions combined with the DESAL. ' 4. The AES plant operates 255 days of the year and 110 days runs the water through the.plant BUT does not heat it. The besai plant d ' needs heated water 7 days a week 24 hours a day. The decal EIR does not mention this inadequacy 5. The pipeline running across HB and into Newport and Costa Mesa will have a significant affect on our traffic and compromise our e streets when the end product will not benefit any of these cities. 6. The ;uclity of the ocean water has::'t been studied sufficiently because they have a diffuser problem. EIR W1-2 "The diffuser Would provide an increased dilution factor at the shoreline. However, f a diffuser would increase the seabed salinity within 600 feet of the outfall because only Y of the water column would be engaged for dilution because the present discharge configuration ejects the concentrated seawater away from the seabed." 7. Since the product has no buyers and is not needed by any of the cities that will be affected by the polluting of the ocean, the air and g the quality of life this project should be rejected and the EIR should be denied because of inadequacies. Respectfully submitted. �l Eileen Murphy PY 201 21st Street HB CA 92648 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS 1 9 Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 41 ' Eileen Murphy 41 a. Since the proposed project would not alter operations at HBGS, only the impacts of the proposed project need to be considered within the DREIR. Also refer to Responses 1 g and 2z, above. ' 41 b. Refer to Response 1 g, above. 41 c. Refer to Response 41 a, above. Section 5.4-11 of the DREIR was intended to analyze project-specific air quality impacts only. The proposed project's cumulative impacts are analyzed within Section 6.3 of the DREIR. 41 d. Refer to Response 34b, above. 41 e. Refer to Response 34a, above. 41f. The HBGS outfall is not currently equipped with a diffuser. The quote incorporated by the commentator was taken from Appendix W of the DREIR, which models the potential effects of adding a diffuser to the outfall. 41g. This paragraph provides a conclusion to the comment letter and does not require a response. City of Huntington Beach August 17, 2005 278 COMMENT 42 Larry Porter ' 1501 Westcliff Dr#201 Newport Beach California 92660 ' Voice and Fax 949 722 9166 Email : Dubbietub4aol.corn CEBT_ MAY 2 7 2005 May 271'2005 ' To Whom it May Concern : Poseidon Respondent First ' I will discuss the "Ocean Water Quality"at the AES intake pipe. a Your EIR states that : because of a "Model of Your Chosing"that the water at the intake ' pipe is "Seawater" and would not be subjected to/contaminated by the discharges of 1) OCSD's 250 million gallons per day discharge 2)The San Gabriel River 3)The Los Angeles River 4)The Dominguez Channel 5),The Many ships that are increasingly ' anchored off shore. _ Secondly rThe EIR only mentions , and tries to just focus on BACTERIA.When in reality the discharges are ,but not limited to : 1) OIL and GREASE- minimally from OCSD alone ' 61.5 thousand pounds per day permitted.That's just OCSD. 2)PHARAMECUTICALS? No mention?Why? 3) Pesticides? 4)ENDOCRINE DISRUPTORS ? ' OCSD FACTS Discharge Quantity : 250 million gallons every day ..EVERY DAY , EVERY DAY. The b ' discharge is buoyant.Fresh water is lighter than salt water. Wind direction and "STUFF" goes down wind .Wind direction creates currents and the ' current and the wind takes "STUFF"with it. On shore which the EIR refuses to admit. The EIR refuses to ACKNOWLEDGE THE TRUTH. San Gabriel River—Los Angeles River—Dominguez Channel These now flood control channels flow 24 hours per day ,365 days a year even in the summer after prolonged periods of no rain.And when it does rain and when it doesn't rain.What color is the water?Is it the color of"SEA WATER"Is it the color of"SEA WATER"colored with a lot of"Stuff"from the Urban Runoff"and OCSD discharge? ' Describe the different constituents relating to the different colors please. What You See is Usually True? Please describe what one would see at the AES intake pipe ?What is the real chemistry being sucked in. How many times has the applicant or his people been close to the b CCSD discharge site?Why is it that I know I am near it 2 miles away down wind when the "Experts"say.that couldn't be?Why is it that the RWQCB changed the rules that only the top ten feet near the OCSD discharge would be designated OK for swimming? Could it be that 15 feet down it's contaminated ? And that's just considering "FECAL COLIFORM" Might the water be contaminated with other bad "STUFF"?Why don't you talk about the other 'BAD STUFF" ? Tampa Bay Why did Poseidon fail in Tampa Bay?Is it still down? Is not the treatment process described in the this EIR the same as used in Tampa Bay?If not,how is it different? C Where else is a like (so minimal process train employed—my words) .Its good to compare apples with apples and oranges with oranges.Yes?No? How much more chemicals did they want to use than what the indicated they would use?Did the Tampa plant have difficulties with permits because of the increased chemical usage? On the Beach I sugaest you stand on the beach in front of the AES power plant and contemplate truthfully ,with the utmost candor what you see and feel. The surf: are the waves breaking onshore?Why?Do the surfers surf toward the shore ? Do they surf towards Catalina?Towards the OCSD outfall?Towards the San Gabriel River,The LA River, The Growing Harbor Complex.? Soapy Water Bubbles Maybe this heads up will help.Go to the toy store. Get a bubble maker. I'll reimburse you. Go to the beach(or anywhere )—the beach is more fun? Clean air. Now ,after dipping your plastic dealibob in the soapy solution and blowing at the hole in the dealibob. Which way do the bubbles go? Downwind? Upwind? Which way? Trash the Model Don't use the silly model that has been used. It's a joke. Get real . Just describe what is f actually happening, what is-actually at the AES intake. It's better for the applicant to get this "Intake Pipe Situation" correct Does the applicant want more egg on its face like Tampa? Over , Larry Porter Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS J 9 Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response n No. 42 Larry Porter 42a. This paragraph does not contain a comment on the DREIR and does not require ' a response. 42b. Potential sources of contamination to the HBGS intake (including the OCSD ' discharge, Los Angeles River, San Gabriel River) are analyzed within Section 5.10, OCEAN WATER QUALITY AND MARINE BIOLOGICAL RESOURCES. 42c. Refer to Response 21 c, above. 42d. This paragraph does not contain a comment on the DREIR and does not require a response. 42e. This paragraph does not contain a comment on the DREIR and does not require ' a response. 42f. The commentator does not provide specifics regarding the "silly model that has been used" nor does the commentator provide information on an alternative to ' this model. No response is necessary. City of Huntington Beach August 17, 2005 281 COMMENT 43 May 16, 2005 Ricky Ramos ' City of Huntington Beach Planning Department ' 2000 Main Street Huntington Beach, CA. 92648 Dear Mr. Ramos, I believe we spoke about a month ago about the Poseidon Desalination Plant EIR. I had ' many questions about the report. These are my comments and questions: I am concerned about the noise levels both during the building of the plant and after it has a ' been finished. Noise levels have been compared to a Mack trucks' engine revving. Since walls must be built and screens would be put up,this is an acknowledgement it would be noisy. I envision walls built to keep freeway like noise out, yet you still being able to ' hear obnoxious noise. I wonder whether the racket would bother Hotel visitors. The report talks about digging very deep holes where we will be driving (Magnolia,' b Hamilton). Traffic dilemmas like what has happened with the Sanitation District don't sound inviting. Pipes will be built on Hamilton that are described as though will be visible during and after the plant is built. The wording wasn't clear. Will any pipes being built going to the Sanitation District be visible in our neighborhood?If so,what will that look like? C Another eyesore for our neighborhood to bear is a slap in the face to the many taxpayers who live here. ' I'm concerned about the closeness to a lot of earthquake faults to your deep holes being d dug. Could this trigger a quake? ' The report talks about toxic chemicals fioving into the ocean if the plant experiences an emergency. It doesn't explain what the plant considers an emergency. Could it be something as small as the electricity going out or as large as a 9.0 earthquake? This isn't clear. Neither is the amount of chemicals the plant.would allow to go into our ocean. These questions need to be answered in a clear and concise way for the citizens of our community and for anyone who would be swimming or wading here. This sounds like a lawsuit waiting to happen. _ Many questions have been asked about the promises Poseidon will be making to the city, f ' reimbursing the city for our"trouble". I'm concerned about the Iona term financial effects we will have to bear if this plant isn't profitable or if it's sold off. ' Our community will be affected by this plant, yet we will be getting no water from it. This is an outrageously unfair deal for South East Huntington Beach. g Our immediate beaches (Between Newland and Brookhurst) have been said to have "urban runoff', a catch all term vaguely describing "people" causing the contamination. This is not an acceptable explanation. Since we don't know why these waters are riddled with bacteria,we need to learn why before bringing in more potential contamination. The Sanitation District and the AES power plant are right at the door to these waters. Although both plants have been cleared of cawsm-the problems,{there. is still a question of where it's coming from. To.bring another plant in where there is existing contamination would be bad for residents and for tourism. The media has not been friendly to Huntington Beach over our water problems. Friends and family from the East coast have spoken to me about these problems. Do we want to risk adding to this question mark tourists have about the cleanliness of our beaches? The entire EIR has many unanswered questions and raises fear in my mind about chemicals, noise,traffic problems, loss of tourist income and other above mentioned problems. After the experts have done their work by writing about negative impacts,they i come back and essentially O.K. the building of Poseidon. The impact on Huntington Beach taxpayers can be avoided. My hope is that all of these questions will be taken into consideration when it's time to vote on whether to allow this company to be part of our coastline landscape. Joanne Rasmussen ' Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS J 9 Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 43 Joanne Rasmussen 43a. Construction of the proposed desalination facility would be limited to the hours of 7 AM to 8 PM, per the City of Huntington Beach Municipal Code. In addition, a truck and vehicle routing plan would further minimize noise levels due to construction. Impacts during construction would be short-term in nature, and are not anticipated to be significant. Moreover, the project would be required to meet the City's Industrial noise standard of 70.0 dBA at the HBGS property line. It is not expected that soundwalls (similar to those located along highways) would be necessary to mitigate noise levels. ' 43b. Construction of the proposed pipeline would utilize standard pipeline trenching techniques (except in places where micro-tunneling or directional boring would be utilized), and would not be located deeper than necessary. Portions of the pipeline proposed within the City of Huntington Beach would be subject to City review and permit process. Traffic impacts due to pipeline construction have been addressed properly according to CEQA in Section 5.9, CONSTRUCTION RELATED IMPACTS, of the DREIR. In addition, mitigation measures CON-31 through 36 would apply to the construction process. 43c. No pipes associated with the proposed project would be visible after construction. 43d. It is not anticipated that any construction activities associated with the project would trigger a seismic event. 43e. All chemicals stored on-site would be stored with 110-percent spill containment capability, utilizing appropriate storage techniques/materials. The desalination facility operator would develop a hazardous waste management and safety plan, and the project would comply with all Federal, State, local, and Occupational Health and Safety Association (OSHA) requirements. 43f. Economic impacts are outside the statutory scope of CEQA unless substantial evidence can demonstrate that an economic effect would result in a physical change to the environment. In this instance, the author expresses concerns about impacts to the City's finances if the proposed project has financial problems. No response is necessary. 43g. No purchase agreements exist for proposed desalinated product water. It has not been determined if the City of Huntington Beach will or will not purchase desalinated water from the project. 43h. Potential impacts of the OCSD discharge and urban storm water/dry weather runoff are analyzed in detail within Section 5.10, OCEAN WATER QUALITYAND MARINE BIOLOGICAL RESOURCES. City of Huntington Beach August 17, 2005 ' 284 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS 43i. This text provides a conclusion to the comment letter and does not require a response. City of Huntington Beach August 17, 2005 285 COMMENT 44 ROD ALAN RASMUSSEN May 16, 2005 4 m q l Mr. Ricky Ramos CA n zorj 7'� City of Huntington Beach �_r Planning Department 2000 Main St. Huntington Beach, CA. 92648 Re: Poseidon Desalination Plant EIR Dear'Mr. Ramos: As a resident of the southeastern portion of Huntington Beach I would like to add my two cents worth to the above referenced project. Despite what you have and are hearing from the good people who make up SEHBNA, not all of us in this area are against Poseidon. Those that are can only be described as your a typical NIMBY's. Most of these people haven't had anything good to say about our country since Vietnam and long for that era to return. Hence they will jump at any chance to protest and demonstrate and otherwise attempt to cause a ruckus. I for one would like to see this project get the green light if for no other reason than to show the rest of the area, state and nation that at least one community is willing to stand up to the liberals and luddites and all the other dis-affected hippielenvironmental types. The benefits of Poseidon to this community are just extra! Regards, Rod Rasmussen 9152 KAPAA DR.- HUNTINGTON BEACH, CA - 92646 PHONE/FAX: 714.593.170Q Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 44 Rod Rasmussen 44a. The author expresses his support for the proposed project. No response is necessary. City of Huntington Beach August 17, 2005 287 Matj 25 05 08: 43a x 0000000000 P. 1 COMMENT 45 Jolm a • Scott 22032 Capistrano Lane-Huntington Beach,CA 92646-8309 Phone:(714)962-1746-Fax:(714)962-1746-Email: 4iohnseoW( earthlink.net May 2.6, 2005 Ricky Ramos e City of Huntington Duead i Planning tg vepar tmei�t 2000 Main St. Huntington Beach, California, 92648 ... Dear Mr. Ramos: . ' My response to a portion of the Poseidon EIR is a enclosed. It has been very difficult for me and I would guess for others, to respond to this EIR because of the manner in which it.was made available to the public. I would. a urge the city, if indeed it wants citizen participation, to utilize current technology to give busy citizens easier and-cheaper access to such documents. It would be nice to-someday hear from-public officials-that S-EHB was-destined to get something besides more industrialization. One would think that with AES, OCSD, and NEST, planners would begin to understand that"residents here already bear more than their share of the city's dregs. Respe fully, John F. Scott Mau 26 05 08: 43a x 0000000000 p. 2 Poseidon's Desalination.Pipeline Alignment The Poseidon Ea has two rejected alternative routing proposals forthe pipeline that would-carry the produced water to its potential point of usage somewhere in South County_ Under the AIternate 2 scenario the 42-48'inch pipeIine ca wing the water to its users in South County would have utilized the Edison right-ol way north of Hamilton A venue to car their water to u e Santa Ana River. Their pipeline then would have proceeded in the Edison right-of--way in a northeasterly direction adjacent to the river and cross the river at a point coinciding with the northern border of the Fairview Park and the Costa Mesa Golf Course. Edison rejected this _ alternative. Alternative I would have had the pipeline constructed under Hamilton Avenue and then continue east across the river and.down Victoria Avenue.- Costi-llesa-rejected-this Alternati<rm. What remains is a convoluted route that-leaves Hunting on Beach-bearing the brunt of getting water to South County. The remaining route is down Hamilton to Brookhurst and up Brookhurst to Adarns and across the river_ The planned route will close two Lanes on Hamilton and - {, Brookhurst dilring construction, Since both Edison and Costa Mesa have rejected Poseidon's U alternate routes the EIR is limited to a route wandering through Southeast Huntington Beach. Unlike responses from Edison and Costa Mesa,Huntington Beach.city.officials apparently.have._ agreed to let Hamilton,Brookhurst and Adams to be torn up and for the area to again be subjected to the dewatering-pr=s,%the noise-and pounding-of-heavy- and darn—age to- homes. . Presently over 60 families have joined a lawsuit seeking to recover hundreds of thousands of dollars in damages to their-homes from the City,the constriction company and the Sanitation District resulting from sewer construction in Brookhurst,Banning and Bushard streets. Trenching, dewatering and heavy equipment have refft homes with cracked, empty pools, doors that will not close, slabs that are cracked, room additions that are moving away from the house and many people heartsick as they witness the destruction of the home in which they have spent a lifetime. Again residents of Southeast Huntington Beach will be subjected to the perils incumbent upon: dewatering, deep trenches,the-pounding-of heavy-equipnrent-and thetraffrc problems that- - months of torn up streets will bring. Despite the experience with the OCSD sewer line, this EIR totally ignores the problem-arrd-lists-no rnitrgation-measuTes-to-resolve-it: Residents of'Sautheast- Huntington Beach will have to again turn to legal measures to recover damages resulting from Poseidon's pipeline construction. . John Scott 22032 Capistrano Lane Huntington Beach, CA 92646-8309 Phone: (714) 962-1746. Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 45 John F. Scott 45a. The DREIR was distributed to the public according to the CEQA Guidelines. In addition, the proposed project would be compatible with the existing City land use and zoning designations for the site. 45b. Refer to Responses 25a, 43b, and 49c. r r r r r r 1 r City of Huntington Beach August 17, 2005 290 COMMENT 46 Cite of Huntington Beach May 26, 2005 MAY 2 5 2005 Robert Thomas 9152 Playa Dr. Huntington Beach 92646 City of Huntington Beach Planning Department Mr. Ricky Ramos Dear Mr. Ramos, This letter is to request that you deny the Poseidon desalination plant proposed for Newland Street. I am concerned about a the potential increase in air and water pollution. I am also concerned for the damage to our neighborhood that would be caused by the construction of the transmission pipeline. Finally I ask that the_City of Huntington Beach recognizes the value of protecting our coast for the current and future generations. The OC Register reported on April 28, 2005 that The American Lung Association rated Orange County air quality as An "F"in three pollution categories. These pollutants include ozone, and fine particle pollution. The AES generation plant needed to b support the Poseidon project is a major source_of air pollution. The South Coast Air Quality Management District agreed that the ALA's method of assigning grades is fair. These older, polluting power generators are slated to be shut down.and no further heavy industry should be added. The quality of ocean water is often poor at Newland Street. When the tide is low the intake and outflow pipes for the AES plant are almost in the surf zone. It is obvious that the changes in C water temperature and salinity are not helpful to the marine life and water quality. If we want to call our city "SURF CITY' shouldn't we make the protection of the ocean our prune goal? 1 2. The Orange County Sanitation District has hied for the past two years to construct a pipeline on Bushard Street. This project has been a complete failure and has resulted in numerous lawsuits. My family has had to deal with the noise and dust of heavy trucks idling practically right outside our bedroom at 6:30am and d waking us up. The constant vibrations have felt like mini- earthquakes. The 10 minute round trip to drop the kids off at Sowers School was doubled due to closed streets. The pipeline to South County would do nothing to add to the quality life for residents of Southwest Huntington Beach and would potentially be another _ boondoggle. I reserve the right to bring legal action, if needed, in response to these or any undiscovered environmental or health @ r problems resulting from the Poseidon plant. Huntington Beach has more than its fair share of heavy industry. It is time for other county cities to share in the burden of power, sewer and water utilities. Just last year the Army Corp of Engineers had to abandon plans to add sand to west Newport Beach due to public outcry. Surely the citizens of Huntington Beach deserve the same consideration from our representatives. Is the ocean in front f of the city of Huntington Beach any less valuable than that of Newport or Laguna? The city of Irvine was able to take control of El Toro and close runways that have been in use for 50 years. As a result the citizens of Huntington Beach now deal with ever increasing traffic routed right over us. Please think of what is best for the ocean the air_ and the families who live in this SURF CITY and reject the Poseidon plant. Sine Robert J. Thomas Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 46 Robert Thomas 46a. This paragraph provides an introduction to the comment letter and does not require a response. 46b. The HBGS is a permitted power plant that has undergone a separate environmental clearance process. The proposed desalination project would not alter the operations of the HBGS. Therefore, the air quality impacts of the HBGS need not be considered as part of the EIR. 46c. This paragraph does not contain a specific comment on the DREIR. Ocean water quality impacts have been analyzed within Section 5.10, OCEAN WATER QUALITYAND MARINE BIOLOGICAL RESOURCES of the DREIR. 46d. No pipelines associated with the proposed project would occur within south Orange County. Rather, the desalinated water pipeline is proposed within the Cities of Huntington Beach and Costa Mesa. Potential impacts due to pipeline construction are addressed within Section 5.9, CONSTRUCTION RELATED IMPACTS of the DREIR. 46e. Comment noted. No response is necessary. 46f. This text does not contain information relevant to the DREIR and does not require a response. City of Huntington Beach August 17, 2005 293 COMMENT 47 APR ?ao City Oi ?"each Ricky Ramos April 9, 2005 City of Huntington Beach Planning Department 2000 Main Street Huntington Beach, CA 92648 Subject: Desalination Plant Dear I& Ramos: I am 54 years of age and although my wife and I currently live in the city of Orange I have been visiting BB nearly every weekend since I was a teenager. At that time it was a safe to hitchhike which is what I did. Now my wife and I visit regularly eating and shopping. I would like to briefly express my views opposing the desalination plant. Much of the waxer that would be produced is slated for proposed development in Rancho Santa Margarita which I am totally opposed to as it would destroy critical wild areas. b Huntington Beach has an excellent groundwater reclamation plan. Stick with that and upgrade as needed Lastly, and no matter what the fibs Poseidon puts forth, it is unquestionably environmentally unfriendly. C Thank you for sending me the letter and allowing my input. Respectfully, S� Steve Tyler 2564 Fraaki St Orange,CA 92965 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 47 Steve Tyler 47a. This paragraph provides an introduction to the comment letter and does not require a response. 47b. No purchase agreements with local water purveyors (including Santa Margarita Water District) exist. In addition, refer to Response 20c, above. 47c. Comment noted. No response is necessary. City of Huntington Beach August 17, 2005 295 COMMENT 48 JAN D. VANDERSLOOT, NM Certified,American Board of Dermatology 8101 Newman Ave, Suite C Phone: (714) 848-0770 Huntington Beach, CA 92647 Email:JonV3@aol.com FAX: (714) 848-6643 May 27, 2005 MAY 2 7 2005 Rick Ramos City of Huntington Beach Planning Department 2000 Main Street Huntington Beach, CA 92648 Re: Draft Recirculated Environmental Impact report No. 00-02 for the Seawater Desalination Project at Huntington Beach Dear Mr.Ramos: Thank you for the opportunity to comment on the above referenced Draft EIR. I am taking the liberty of resubmitting the comments I made in my letter to Mayor Connie Boardman and Huntington Beach City Councilmembers of November 16,2003 which includes a number of attachments. I ask that this letter and attachments serve as comments to be addressed in the current Recirculated Draft EIR, as I find that the Recirculated Draft EIR does not address the particular comments I made in that letter. In particular,the Draft Recirculated EIR does not make an in-depth analysis of the Komex study for the California Energy Commission of August 4,2003.In fact,the current Draft EIR states that: "Based on the water quality sampling and the modeling studies,Komex concluded that the HBGS was not contributing to the beach contamination problem"(page 2-9 and 4-19)". Also on a page 4-20,it is stated"Three separate studies conducted between 2001 and 2002 have demonstrated that HBGS is not the source of bacteria in the surf zone". This is not true.This erroneous language is also used on page 5.1072,first sentence,page 5.10-5, second paragraph from the bottom, and page 5.10-27,three paragraphs from the top. The actual language in the Komex study states: "Land-based sources of bacteria(particularly BD and BFW) do enter the discharge vault and are discharged to the ocean,but not at concentrations high enough to contribute significantly to bacterial contamination of the surf zone of Huntington State Beach..."(my emphasis to point out the word sign candy,which means that the bacteria reach the beach and do contribute to the bacterial contamination of the beach). See page iv of the Komex Report, attached. Also see figure 4-4,page 4-19 of the Draft Recirculated EIR showing "Surf Zone=47"referring to the number of total coliforms at HBGS reaching the Surf Zone, Summer 2002. Moreover,page 42 of the Komex report showed total coliform elevations in the HBGS discharge vault exceeding 24,192 MPN/100cc,the limit of the measuring device, with e.coli ranging to 1,296 MPN/100cc and enterococcus ranging to 1,694 MPN in the discharge vault Divide these numbers by a 36 dilution gives 672 MPN/100 total coliforms, 36 e.coli, and 47 enterococci reaching the surf zone. The point is that bacteria from the HBGS do reach the surf zone and therefore may contribute to the beach contamination problem. The bacteria may also multiply by reconstituting in the beach. i JAN A VANDERSLOOT, MI) Certified,American Board of Dermatology 8101 Newman Ave, Suite C Phone: (714) 848-0770 Huntington Beach, CA 92647 Email: 7onV3@aol_com FAX.- (714) 848-6643 sand(see below reference to the Peer Review Summary of the HB Shoreline Contamination a Study). In addition,because the desalination process excludes bacteria from passing through the membranes,the brine concentrate will contain these bacteria and double the concentration as it also twice concentrates the other constituents of the source water. This double-concentrated discharge then has the possibility of reaching the surf zone and further contributing to the beach contamination problem. - Moreover,the Komex report also states that: "Sub-thermocline water is occasionally entrained into the AES HBGS intake.During this study there were no specific indications that the intake water contained part of the OCSD plume. However one event in August and three brief events in September demonstrated(brief)entrainment of sub-thermochne water into the intake vault. The C mechanism to support the Grant Hypothesis has been demonstrated on four brief occasions in this study" (page iv of the Komex report). This shows the possibility of the OCSD plume entering the HBGS plant intake and affecting the desalination facilities, as well as the possibility of the OCSD plume also contributing to the beach contamination problem. This possibility should be stated as such in the Draft Recirculated EIR. The Draft EIR fails to mention the"Peer Review Panel Summary Report,Huntington Beach Shoreline Contamination Investigation,Phase III", prepared by the USC Sea Grant Program and the University of California, Santa Barbara Marine Science Institute,March 21, 2003". The importance of this review is that mechanisms exist that can transport the OCSD sewage plume to the beach,where low levels of bacteria can reconstitute in the beach sand.Moreover the report states"categorical dismissal of the OCSD plume as a major cause of beach contamination is not scientifically justifiable at this point" (see page 4 of the attached Executive Summary of the report). The Executive Summary also suggests that fixture study is needed to further characterize the fate and transport of the OCSD plume, stating: "Such a model,including the AES Power Plant plume and other sources,will likely be the only way to reach definitive conclusions about what proportion of beach contamination is due to the OCSD effluent."(see page 6 attached Executive Summary). This is important because no single source of the beach contamination problem has been e identified.The Draft EIR states: "...the Santa Ana River and Talbert Marsh appear to be the primary sources of fecal bacteria to the near shore ocean"However,the Komex study showed a spatial gap between the Santa Ana River, Talbert Marsh, and the contaminated beach area adjacent to the AES plant, 6N and 9N. See attached Plate 46 from the Komex report.This spatial gap shows that the Santa Ana River and Talbert Marsh are not the cause of the beach contamination problem.Recall that the Santa Ana River is 8,300 feet south of the AES plant,over a mile,while the OCSD discharge has been shown to come as close as'/z mile to the shore, closer than the Santa Ana River_ The Draft EIR does not explicitly state how many actual RO membranes are proposed.The EIR mentions 13 treatment trains.How many membranes are there in 13 treatment trains?This is f important in trying to determine quantities of RO membrane cleaning solutions. Table 5.10-8 shows quantities per RO membrane. How many membranes are there? 2 JAN D. 'VAINTDERSLOOT, MD Certified,American Board of Dermatology 8101 Newman Ave, Suite C _ Phone: (714) 848-0770 Huntington Beach, CA 92647 Email_JonV3@a aol.com FAX_ (714)848-6643 The EIR does not address the increase in marine mortality by increased AES plant pumping gr operations at night-time when marine organisms are most active. How will the desalination operations change the nighttime operations of the AES plant? Thank you for the opportunity to comment. Please see attachments and respona to me comments in the November 16,2003 letter to Mayor Connie Boardman, and the May 29, 2003 and July 22, 2003 letters to Planning Commission Chairman Randy Kokal. Sincerely, Jan D.Vandersloot, MD Attachments_ 1 F. JAN D. VANIDERSLOOT, MD Certified, American Board of Dermatology 8101 Newman Ave, Suite C Phone: (714) 8=�8-0770 Huntington Beach CA 92647 FAX: (714) 848-6643 November 16, 2003 Mayor Connie Boardman, and u"'-tington Beach Cite Councilmembers City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 Re. Huntington Beach City Council Meeting November 17, 2003 Agenda items D-2a and D-2b Poseidon EIR, CUP, and CDP Dear Mayor Boardman, and Huntington Beach City Councilmembers: I am writing to request that you oppose certification of the EIR for the Poseidon Desalination ; Project and that you vote to deny the Conditional Use Permit (CUP) and Coastal Development Permit for this project. Regarding.the Poseidon EIR, I believe there is a major deficiency in the EIR not considering the study written by Komex H2O,Inc. for the California Energy Commission (CEC)titled: "AES Huntington Beach Generating Station Surf Zone Water Quality Study, Final Draft, dated August 4, 2003". In the meantime,the CEC has written you a letter dated November 7, 2003,giving you many reasons why the Poseidon EIR is deficient because of its association with the operations of the AES plant. Although I had written an email dated September 8, 2003 to the Planning Commission recommending consideration of AES CEC study report, and sent it to you by email (see attached), this report-was not considered nor referenced in the EIR certified by the Planning Commission. Neither the staff nor Planning Commission made an analysis of the data within this report. j However, the attached email details my own analysis of the Komex AES CEC study, which should give you reason to request further analysis of the Poseidon EIR.. The AES CEC report shows how bacteria from the AES plant is found within the plant and within the intake and discharge vaults of the AES plant, where it is then discharged into the ocean some 1500 feet offshore. The report shows how bacteria are then diluted at only a 36 to 1 ratio when the bacteria hit the shoreline. Concentrations of bacteria within the discharge vault sometimes exceeded 24,192 M2N/100cc, which was the limit of the ability of the instrument to measure the bacteria. The actual numbers of bacteria could have been much higher. The dye study in the AES CEC study showed that the AES discharge plume reaches the shoreline -within an hour of injection into .the discharge vault. Since the Poseidon desalination operations will concentrate and add other constituents to the AES discharge plume, consideration must be made to what impact the Poseidon operations will have on beach bacteria and marine water quality. Given the persistently high bacteria readings on the beach adjacent to the AES plant in the vicinity of Magnolia Street, it is critical to further examine the role of the AES plant and the proposed desalination plant's impact on the AES discharge. JAN D. VANDERSLOOT, MD - Certified,American Board of Dermatology III I Newman Ave, Suite C Phone: (714) 848-0770 Huntington Beach; CA 92647 FAX: (714) 848-6643 I am submitting another report for your consideration titled: 'TIuntington Beach Shoreline Contamination Investigation, Phase III, Peer Review Panel Summary Report", dated March 21, 2003. Page 4 of this report, bottom of the page, states.- "If the beach is considered to be the end of th.e transport pathway, and the bacteria transported to shore remain on shore or trapped in the surfzone, possibly adsorbed to sediment particles,then low concentrations of bacteria just offshore can be reconcentrated at the beach. The potential for resuspension of fecal indicator bacteria within the surfzone was not addressed in the Phase III study and therefore cannot be . ruled out as a possible source of beach contamination." Although this report referred to the OCSD outfall,the same principles apply to the AES outfall, which also discharges bacteria,.although in lower amounts than the OCSD outfall. However, unlike OCSD,the AES outfall discharge has been definitively shown to reach the beach. I am k enclosing the color photographs of the dye study in the AES CEC report to show how the AES discharge is shown to reach the beach,Figure 4-19b and Plate 5-1. This could be the explanation for the high bacteria readings on the beach. Bacteria from the AES discharge vault reaching the beach, resuspending in the surfzone and reconstituting on the beach adsorbed to sand particles, The Poseidon operations, through concentration and addition,will alter the bacterial levels within the AES discharge vault, and therefore the bacterial levels that reach the beach,where they may become resuspended and reconcentrated,perhaps worsening the bacteria problems on the each at 9 North.This impact should be analyzed in the EIR. I am also attaching my letter to the Planning Commission of May 29,2003,along with Exhibits 13, 14,and 16 from the Poseidon EIR, showing how the salinities from the AES discharge follow the shoreline, outlining the plume: Again, if bacteria are also entrained in this plume, you can see how the beach can receive these bacteria, and you have an explanation for the beach pollution problems we continue to have along this stretch of beach. In this letter,I requested further analysis of this potential impact in the EIS which was never done. I am also attaching my letter to the.Planning Commission of July 22,2003, detailing my concerns about the privatization of public water supplies, and the potential for security problems and difficulties with international trade laws if Poseidon should sell out to a foreign company. Poseidon is already partly owned by US Filter, a French company despite its name. Our public water supply should remain in public hands, subject to public oversight, and not be manipulated by for-profit and foreign corporations. . I am also attaching the recent news article from the St. Petersburg Times, published October 30, 2003,titled: "Desal builder files for bankruptcy". I think this article should give you pause as to the financial stability,of the company who is making application for this project and the financial promises being made. I would also ask if it is smart to locate a water reservoir over an area subject to earthquake and liquefaction potential. All in all,the Poseidon desalination project raises many questions that need to be answered before you approve this project or its EIR_ I think this project is the wrong project in the wrong place. M Desalination of ocean water is a potential source of water,but locating a plant at the AES site is 1 just asking for trouble. 2 JAN D. VANDERSLOOT, MD Certified Ainerican Board of Dermatology 8101 Newman Ave, Suite C Phone: (714) 848-0770 Huntington Beach. CA 92647 FAX: (714)848-6643 The Planning Commission developed"Suggested Findings For Denial, Conditional.Use Permit No. 02-04/Coastal Development Pellr-t No. 02-05", a-LL ached. I recommend that you adopt these m Endings for den;at, in adri;t;on to finding the EIRto be inadequate as submitted. _ Thank you. Sincerely, Jan D. Vandersloot, MD Attachments: 1. September 8, 2003 Email to Planning Commission and City Councilmembers 2. March 21, 2003 Huntington Beach Shoreline Contamination Investigation, Phase III, Peer.Review Panel Summary Report 3. May 29,2003 Letter to the HB Planning Commission 4. Exhibits 13, 14, and 16 from the Poseidon EIR 5. July 22, 2003 Letter to HB Planning Commission 6. October 30, 2003 Newspaper Article from the St.Petersburg Times 7. Suggested Findings For Denial, Conditional Use Permit No. 02-04/Coasatal Development Permit No.02-05 sehb OOG t al:AES C C Study, Commission Tuesday, 7 PM `Subj: j na] e E t y, HB Planning C y, :Date: 1/812003 1:01:16 AM Pacific Dayfight Time From: .:c n 2 L clo M Reply to: .To: ,.Cr! '.'3a� ri i . `_ai�, vit.i CSr"v-v��'...iG-• ...JT '_'_1;� -- 'S!i�- _'r - - =.�1:��'--,in iC, - ��,-�vi -'�-"'1 -- - ,,,.re amasLff b.oro, :�.,c�.�,e �.U-ci. I �: L:;;�L _ � L, i C- • :.j1� hu-ur:: C: .:�:,Yc!:�.i-,-.��:_ ii�. ��v, =CQr- _ - 0Ili^�i-.�tvr+. _ 'i'; ra- -^,rt^��l'i - 'l=S- •c.•- �i�ti ,T�i�iE`?c .. '�^ . ' _�. i_�i. ^:, j__gra SI'^_-rl"teiF•'�ric^r;r.ri�_ sGS�di-i -;aiJ��'i�"1i�t - _ :Sent from the Intemet-D si September 8,2003 Re: Poseidon CUP, HB Planning Commission, September 9, 2003 Dear Huntington Beach City Council and Planning Commissioners: This is part of my ongoing analysis of the AES Huntington Beach Generating Station Surf Zone Water Quality Study, Final Draft, prepared for the California Energy Commission, prepared by Komex H2O Science Inc, dated August 4, 2003. After spending some 20 hours reading and rereading this report, these are my recommendations and findings for the Poseidon EIR, CUP, and further AES proceedings: Recommendations: 1. Because the AES GEC report shows that bacteria from the AES.operations are discharged into the ocean and comeback to shore via the AES plume,this whole report should be included in the Poseidon Desaiination EIR, as a Supplemental EIR, because the findings in this reportwere not considered in the Poseidon Desalination EiR; and Poseidon will alter the AES discharge by virtue of concentration and addition. 2.The Conditional Use Permit for the Poseidon Desaiination Project should contain requirements that: 1.All freshwater discharges from AES into the Discharge Vault of AES should be diverted to the OCSD for further treatment and not be allowed to enter either the Poseidon intake pipes or the AES discharge pipe. 2.The brine n concentrate from Poseidon should be diverted to OCSD for further treatment,similarto the treatment of the brine concentrate from the GWRS system. 3. Blackford's Ditch has characteristics,of a wetland and should be considered as such in terms of enclosing it in a box culvert as part of the widening of Newland. 4. Internal practices by AES that resulted in lower bacterial counts in 2002 than in 2001 should be identified and required for future practices to prevent backsliding. These recommendations are based on the following findings, with page numbers referring to the AES CEC Report: 1.The AES discharge plume into the ocean 1200 feet from the shoreline comes back through the surf zone and affects the beach, as proven by the August 2002 dye study. The plume reached the beach first at Station 12 North, and then appeared on the beach to the south (p.116-118) (plates 4-18, 4-19b). 2.The discharge plume goes straight up to the surface of the ocean, without dilution, from the AES discharge . port, which is 19 feet wide and only 11 feet below the surface of the ocean, at a distance of 1200 feet from the shoreline. At the surface of the ocean,the plume is diluted by 6 to 1, reaches the surf zone at 24 to 1,then the beach at a minimum of 36 to 1 dilution (p. 123). 3.The discharge plume,as evidenced by the dye study, can reach the intake port some 700 feet away from the discharge port, at a dilution of 24 to 1 at 600 feet(p. 117), and the plume fills the entire water column (p_126)- Komex did no measurements of dye inside of the intake pipe, however. 4.The bacteria from the discharge pipe get on the beach, contributing total mliforms, fecal cohforms, and enterococci to the beach bacteria. Komex estimates that up to 16% of the Enterococci bacteria on the beach come from the AES discharge (p- 134). Sunday, November 16, 2003 America Online: Jon V3 r t'acre 2 of -5 _ r- 5. Komex fails to consider the influence of beach sand acting as a reservoir and sink for continuous bacterial buildup and propagation from the AES discharge, although it does give an analysis of how bacteria survive and enhance in a saline environment (p.178-183). The independent peer review panel evaluating the OCSD Phase 2 investigation first proposed the role of beach sand acting as a reservoir. However, OCSD consistently denies that bacteria from its outfall ever reach the beach. On the other hand, Komex has shown in this report that bacteria ? from the AES outfall consistently reach the beach. 6. The intake vault contains-high bacteria levels that Komex blames on a contaminated ocean (p. 107). However, h the discharge port I the � Komex did not do any studies of the ocean bacteria at the intake poi L or�{�� r f_h� ocean is contaminated at the intake port, this would be the first evidence that the ocean is contaminated with measurable levels of indicator bacteria at 1500 feet out from the shoreline,where the intake port is located 23 feet below the surface of the ocean. (p.17). r~ 7. Intake Forebay bacterial concentrations between May 30 and September 28,2001, ranged up to 12,997 MPN/100 cc Enterococci (AB 411 standard is 104 CFU/100cc for a single water sample) (p.42). 8. Intake Vault bacterial concentrations in the summer of 2002 between July 12 and October 5, 2002,would have caused 4 exceedances of AB 411 if collected in the surf zone (p.80). 9. Discharge Vault bacterial concentrations ranged up to total coliforms >24,192 MPN/100cc,fecal coliforms up to 1,296 MPN/100cc, and Enterococci to 1,694 MPN/100cc between May 30 and September 28, 2001 (p.42) (AB 411 standards are a maximum of 10,000"Total Coliforms,400 Fecal Col'rforms MPN/100cc, or 104 Enterococcus CFU/100cc in a single water sample). Note that values >24, 192 exceeded the instrument's capacity;therefore r— the actual numbers are higher, maybe much"higher. 10. Discharge Vault concentrations in the summer of 2002 would have caused a total of 6 exceedances of AB 411 standards if the samples were collected in the surf zone. n 11. Bacterial concentrations at the intake and discharge vaults-exceeded AB 411 21 times if the samples had been collected in the surf zone (Table 5.1). Of these exceedances nine were observed in the intake value and s therefore represent an import of contamination.from the ocean. (p. 107) 12. A considerable amount of bacteria comes into the discharge vault of the AES plant from on-site fresh water sources. 'The source of the bacterial contamination within the discharge vault is most likely a freshwater source" (p. 107).These on-site sources include the General Purpose Retention Basin, receiving water-from yard and in-plant drains (p. 20),the Boiler Fireside Wash,the Boiler Sump Wash,the Storm Water Sump, and Blackford's Ditch on Newland. The discharge from the General Purpose Retention Basin goes into the discharge ;vault at.a rate of up to 230,000 gallons a day. (p. 121). Indicator bacteria concentrations from these sources added up to 644 exceedances of AB 411 standards if the samples had been collected from the surf zone (p. 82 to 84). 13. Ammonia levels are very high within the system at both intake and discharge vaults,without adequate explanation. Only surmises are offered to explain high ammonia levels, including the highly questionable contention that bivalve biofouling occurs at an arbitrary density of 500,000 bivalves (mussels, clarris) per square meter lining the intake-pipe surface (p.112), despite procedures to prevent biofouling such as reverse flow heat r treatments (p.19) and removal by divers.This would equate to a diameter of a bivalve being .003 of an inch, or 323 bivalves per square inch.The other explanation questions the accuracy and sensitivity of the EPA methodology, as Komex could not explain consistently high ammonia levels above 1.0 mg/I in both intake and discharge vaults(p.112), r 14. Data is thrown out if Komex could not explain it, such as low salinities on CTD Cast#'i. These salinities were thought to be not possible, so the salinity values were not included in the subsequent analyses (p. 97). 15, Data had to be"rectified" or altered to match the data from other studies,including adjusted temperature data that was used to calculate adjusted salinities. (p. 95) 16-The Grant hypothesis of entrainment of OCSD discharge could not be dismissed, and evidence of cold subthermocline water in the intake vault was found (P.138). 17. An alternate hypothesis of entrainment of water and bacteria from the San Gabriel, Los Angeles, or Santa An ' •, �T-----_t-- iL ^)!"012 /t++"+arira (lnTinP.' Tnn V3 River, by the AES plume is suggested. (P.141). 18.The computer model of the plume discharge did not match the actual observations of the dye study until far field distance.The near field and intermediate field were not accurately depicted by the UM computer model (p.127). 19.Blackford's Ditch along Newland qualifies as a wetland. it is called a creek (p.S8). "Approximately 100 feet of the creek has water present to a depth of two feet_ The presence of adapted plants and small fish observed in the creek suggests that the creek is a standing body of water for long periods" ..."The creek is hydraulically connected to the discharge vault and, at high tides; ocean water from the discharge vault may be forced up into the creek." (p.58). Also,salinity concentrations were approximately 2/3 of ocean water and decreased along the length of the ditch from the pump house to the dry inlet (p. 93).Also,tolytriazole, a corrosion inhibitor used in the AES plant, was found in the ditch (p. 93). Blackford's Ditch is also called a creek,with poor water quality and high concentrations ofindicator bacteria (p.108). 20. Internal practices in the AES plant improved high bacterial counts in the discharge vaults and other locations in 2002 compared to 2001 (p. 136). No mention of what these "intemaf practices" actually were. If verified, these practices should be codified. 21. In-Plant Water Quality.Measurements included the fallowing high values'. n intake Vault:Enterococcus to 590 cfu/100 cc (AB 411 is maximum 104) (p.80) Discharge Vault. Enterococcus to 610 cfu/100cc (p.81) Blackford's Ditch:Total Coliforms up to.370,000 dfu/100cc (AB 411 is 10,000) - Fecal Coliforms to 31,000 cfu/100cc (AB 411 is 400), Enterococcus to 62,000 cfu/100cc (AB 411 is 194) (p. 82) Boiler Fireside Wash:Total Coliforms to 68,000, Fecal Coliforms to 4,300, Enterococcus to 160,000 cfu/100cc (0.82) Boiler Sump Wash:Total Coliforms 21,000, Fecal Coliforms 3,800, Enterococcus to 11,000 (p.83) Storm Water Sump:Total Coliforms to 11,000, Fecal Coliforms to 1,400, Enterococcus to 2,200 (p:83) General Purpose Retention Basin: Total Coliforms to 32,000, Fecal Coliforms to 9,400, Enterococcus to 700(p.84) These all show high numbers of indicator bacteria that get discharged into the Discharge Vault and ultimately out into the ocean,where they come back to shore. . The Poseidon desalination operations may act to concentrate these bacteria and other freshwater toxics such as corrosion inhibitor, and therefore.all freshwater inputs to the discharge vault should be diverted to OCSD,where the toxics can be regulated under OCSD's source control program. In addition,whatever toxics and bacteria that are concentrated after Poseidon's operations should be sent to OCSD for further treatment similar to the GWRS program. . Respectfully submitted, Jan D. Vandersloot, MD 2221 East 1 6th Street Newport Beach, CA 92663 (949) 548-6326 To unsubscribe from this group, send an email to: sehbna-unsubscribe@yahoogroups.com Your use of Yahoo! Groups is subject to the - - - - - .... 1 Sunday, November 16, 2003 America Online: Jon V3 i1�y-27-©3 13 =44 FRC)M=OCSu AD'MIhl 1D= 714!9S203SS FACE 2/10 "„niin+crton e icb Shore ne Conr�? ?n�rinn 11ii v r Iuv Gs 1--a�Un, Phase III Veer Review Panel Summary Report Prepared by O University of Soutbern California Sea Grant PrOg= and r University of California, Santa Barbara Marine Science-Instatuie - r^ r r March 21.2003 ? -L KGi1= OCS= ADH�* Executive Snrfunary of Review Panel Comments on the Huntington Beach Phase III Wirral Draft Report 1 1=h 21,2003 Background _ High bacteria counts at Huntington State Beach forced a taro-month b.ach closure in the summer of 1999,at significant cost to the community- This-occurred immediately upon implementation of the AB411 beach closure standards.The O=ge County Sanitation District(OCSD) conducted a series of studies to detemnine the source of the bacteria Initial studies suggested that contamination from the sewage ouffa117 km off the east end of the beach was tmliely,but not impossible. Sewage leakage from b-�ach festrooris,and animal waste from nearby Talbert Marsh have been implicated in tracer studies,but the source of the contamination had not been clearly identiried as of spring,2001, scientioc Objectives Phase III of the Huntington Beach Shoreline Contamination Investigation re-focused = attention on the sewage ourfall,with specific hypotheses concerning onshore transport of the sewage plume.The study objectives, as origivaliy stated in The Rautington Beach Shoreline Contamination Investigation,Phase III Workplan are: "I) characterize the 0 physical ocean6g aphic processes involved in possible cross-shelf transport of the wastewater plume in the vicinity of the AES thermal discharge outfall;2)determine if there is a cau t tweed o shore ands zone acteria and related plume constituents;and 3) determine if the conditions during The summer of 2001 are similar to those of 1999 and other years with unusual surf zone bacteria levels'- The Principal Investigators (PIs)in the study, after careful consideration,re-defined the objectives in October,200?thus: "The principal object e for this multifaceted measurement program-was to determine if there is a causal link between offshore wastewater discharge and significant bacterial contarninarion at or above state beach sanitation standards(i.e.,AB411) along the Hunting on Beach shoreline.This objective inclLides the aim of identifying caasfal ocean processes that could explain any observed links-A secondary- objective was to determine the principal coastal-ocean circulation pat tems in this region,allowing the evaluation of any new ideas that may arise or gain recognition during or follov%incl this study.Thirdly, conditions during the summer of 2001 would be compared to those of 1999 and other years with a high incidence of surf zone bacteria contamination." By this statement,the PIs defined the important issue as bacterial contamination causing bi..ach closures, not a more general question about bacterial transport_ 1 - - 1 ay-27-03 13=4S FROM= OCSD ADMIN I1D= 71nSS203SS PAGE 4/10 Study Result As stated in the Phase III Draft Report: There were no direct_ observations of either thee hula bacteria concentrations r seen in the OCSD piume at the shelf break reaching the shorelile in signif cant leve-Is or of an association between the existence of a coastal ocean process and Mach contamination at or above AB4I 1 levels_It is concluded that the OCSD plume is not a major cause of beach contamination;no causal Iinks could be demonstrated. This conclusion is based on thee absence of direct observation of links between bacteria in the outfall plume and beach contamination,on analysis '- of spatial and temporal patterns of shoreline contamination and coastal processes, and on the observation of higher levels of contamination at the beach than in the plume." Rerievv Process The-University of Southern California Sea Grant Program convened an independent panel of experts to conduct a peer review of the Huntington Beach Phase III Study_ The - Q purpose of this review was to"evaluate the scientific process.data, and interpretation of - - scientific results,and provide ongoing feedback to help guide the investigators in their analysis of these studies." The Review Panel met with the Principal Investigators in person in April 2002 for preliminary presentations of the Phase III Study results and analyses. Subsequent to this first meeting,the Panel submitted a Preliminary Report to OCSD on their initial findings of the Phase III Study on May 15,2002. In August 2002, the Panel and PIs met again to further discuss the analyses of The Phase III data Followin4 the August meeting,the Panel submitted a second response to the Pls with recommendations for further improvement of the Phase III analyses. The Panel and-PIs have also corresponded via phone and email throughoutzhe review process_ A written Final Draft report was made available by the Ns in January 2003 for review by the Panel. This Executive Summate is the result of a concerted peer review,effort by the Review r Panel over the Iast two months and represents a.synopsis of their collective comments on the Phase III Final Draft Report. The Review Panel consisted of: John Allen,Ph.D. r- Oregon State University Theoretical geophysical fl-uid dynamics; Coastal ocean dynamics Jack Barth,Ph_D. Oregon State University Coastal ocean dynamics;Flow-topography interactions AY-27-03 13 : 45 FROM =DCSD ADMIN ID= 714SB2035S ai ivy Walter E-Trick,Ph.D. USEPA Ecosystems Research Division. Plume models for outfall design and assessment; Lou--velociy compressible flow tbeory -n.ij-- Roger r uoxa, A-)). w ater Resources Researen Center, TJni;-ersiry of Ha-wall EnYironmental water quality; Public health microbiology Trish Holden,Ph_D_ Unh trsiry of California, Santa Barbara N{icrobiology; Bacterial community fingerprinuno Jesus Pined a,Ph-D. Woods Hole Oceanographic Institution Cross-shore transport of planktonic larvae; Benthic population.ecology Cynthia Codaback,Ph_D.(Co-chair) University of California, Santa Barbara. Inner shelf transport and effect on biological cor=1111iues 0.1 Judy Lemur,Ph-D.(Co-chair) Sea Grant Program,University,of Southern California Marine Advisory Program Leader _ Review Panel Objecti-ves OCSD initiated Phase III of the HE studies to determine whether sewage discharged offshore from Huntingrton Beach can be transported to the beach and under-what ' conditions it may do so_ Therefore,the Panel has focused on three main questions- 1. Do the studies adequately answer.the specific investigatory objectives that were addressed` 2. Were the data properly interpreted and presented in the preliminary reports` 3.Are there other studies that could be conducted to determine the risk of plume insurgency onto the shoreline? General Comments The Panel ackno,,Oedges that the Phase III field studies conducted durinb the summer of 2001 were of high quahry and represent a cornnlendable undem-ddng. The size and completeness of the data that This study has generated set is also impressive- Given the amount of time available to the Principal Lnvesugators. the analyses are progressil?Q tiveIl. 3 F-- Ay-?7-03 13 : 46 FROM:OCSD ADMIN_ ID: 71456203SG PACE 6/10 The Panel considers the Firial Draft Report to be a good start at analvzinc,the full complement of data and expect that several new contributions io the field of ocean coastal circulation will be i onlacoming from this work. The main conclusion of the Final Draft Report, "It is concluded that the OCSD plume is nDi a major cause of beach containina ion;no causal links could be deiuonsuated,,,is complex,with two separate statements. The second statement, "no causal links could be demonstrated;"is.based on temporal and spatial disconnects between the outfall, transport processes,and beach contamination_Although events that might drive onshore transport of bacteria were observed (such as cold water entering the surf zone),These events did not coincide with or precede beach contamination events in exceedence of the A134I I standards. High bacterial concentrations were observed near the outfall and at the beach,but measurements also indicated that there was a zone of lower concentration between the two regions_ Given the current status of analyses on the Phase I11 studies and based on the available measurements,this conclusion seems to be reasonable and accurate. However,with respect to the first half of the conclusion, "the OCSD plume is not a major cause of beach contamination,"the Panel finds that this smtement is not supportable because of the incomplete nature of the analyses and to limitations.in the spatial and temporal resolution of the Phase III sampling. While a connection between the OCSD outfall and beach contamination has not been found,a lack- of understanding ` Of some key parameters warrants caution;categorical dismissal of-the OCSD plume as a O ` major cause of beach contamination is not scientifically justifiable at this point. Several variables that remain in question are discussed below. 1)Bacterial sari 1p in` The Panel recognizes the difficulty of collecting and analyzing bacterial data,bui-notcs` r that the spatial and temporal resolution of sampling in this study was heavily weighted towards hydrographic data While these field experiments far exceeded previous studies in sampling intensity,.and the number of bacterial samples processed by OCSD was extraordinary,the bacterial monitoring data remain a limitation_ Accordingly,the transport and behavior of bacteria in the coastal ocean is not adequately understood. Anothe>-IiTllitation of the swfzone bacterial analyses is that a large percentage of the data are not graphically represented because samples with less than 20 MPN total or fecal colif'orm or less that 10 MPN entz_rococci,are not included (HB-III.Final Draft Report, Figs.2a,2b,2c)_ T7 2)Spatial disconnection? The argument that the OCSD outfall plume is not a major source of beach.contamination relies on the spatial gap between high bacterial concentrations in the core of the plume and the high bacterial concentrations measured at the beach. Given that the transport properties of bacteria in the coastal ocean are not well understood, it seems prudent to allow for the possibility of a range of plausible behaviors. A possible.mechanism for bridbn-the observed spatial disconnect could be in the reconcentration of bacteria either k'ithin the surfzone or during transpc:!':, 117flie beach is considered io be the end o the transport pathway,an ace ransporze io s ore remain on ore or trap in the surzone,possibly adsorbed t t3c es,o sediment par en ou7 concentrations ofbacteria�ust 4 -27-03 13 :46 FROM=OCSD ADMIN ID= 714S620356 a offshore can be reconcentrated at The beach. The poten-dal for resuspeRSlQa_offcal indicator bacteria within the surfzone was not addressed in the Phase III study and therefore cannot be ruled out as a possible source of beach con-Lamination_ Another explanation involves the gravitational collapse of the plume, which tends to lunit its ver�icaI extent As a velucaily collapsed Lens,the pluu,e could penetrate coarse vertical i sampling lids, dl d Llleripb� 1Cd(1 LV sLLUJ llllcil tJCfl Le11Q ti1Q illLla VeLli=iltlss�ll. • 3) Patchiness The spatial discontinuity between high concentrations of bacteria in the outfall plume and hi;h concentrations of bacteria at the beach may be due to a patchy distribution of bacteria and other plume tracers.The Phase III data clearly demonstrate chat the plume field can be patchy(Fig_5-12,Volume II),and that patches of the plume can sometimes come close to shore (Figs. 3-11 and E1--12,Volume II). Although the region between the plume signature and the beach contains low bacter_ai concentrators, the distance between the two is si friciently close to warrant careful consideration of sampling adequacy._Additiona.Ily,these high values at shallo-,v depths are coincident in time IIN-ith high bacterial concentrations near the beach_- 4) Surface transport O The wind-driven surface transport of buoyant particles shoulcl.be examined as a possible pathway for the transport of plume bacteria onto shore. The possibility of this mechanism was acknowledged in the.Final Draft Report,but not included in the design of the Phase III studies for several reasons involv-ing the unlikely association of bacteria with grease and oil particles,both offshore and at the beach_ Indeed,the Phase III data indicate that the plume is almost al-,vays submerged beneath the therrnocline. Independent modeling by one member of the Panel (W. Frick) supports these results. However, low concentrations of bacteria have been measured at the surface by OCSD personnel, and features of the plume were occasionally observed at the surface during the Phase II investigations (Figs. 3-14 and 4-13 of HB-III Final Draft Report)- Finally,the accumulation of buoyant particles at onshore propagating fronts associated with an internal tide has been observed in Southern California (Pineda, 1999)_ 5) Cross-shelf transpo4 t mechanisms A thorough consideration of cross-shelf transport of'physical waterproperties and plume material is not yet complete. For exainple,additional analyses shoWd be directed at quantifying the nature of the across-shelf transport of the ternperature field as a function of spatial location on the shelf and as a function of frequency_ In addition,internal solitary waves, which are often associated xgth the internal tide and capable of transporting particles onshore, are not adequately addressed in the Final Draft Report Likewise, the association of at least one cold water intrusion into the nearshore indicates the plausibility,if not probability, of this mechanism and deserves further analysis. A third mechanism that could also be investigated is transport in the bottom boundary layer by breaking internal waves near a sloping boundary. 5 spy-27-P3 13 :46 FROM:DCSD ADMIN iD: 72456203S6 FACE FatuTe Stadies There are t vo main areas of concern that could benefit from further research: cross-shelf traiispori and circulation mechanisms, and accurate-L-makinu of plume bacterna_ r Cross-shelf transport and circulation mechanisms t) The spatial and temporal variability of the intemal tide must be investigated in r order to better_understand the role of internal tidal motions in across-shelf transport Field observations are needed to conclusively discard internal solitary r waves as a mechanism for onshore transport of plume effluent bacteria. 2) Further dye tracking experiments, with a release outside the surfzone,may be useful to determine whether eater-borne particles can be transported from the 15m isobath to the surfzone. If possible, adding dye to the effluent after the 200:1 dilution near the outfall may also yield profitable results. This latter experiment would need to be timed with The occurrence of spring tides, 01 3) The nature of the across-shelf circulation could be further explored by examining: in more detail the coupled behavior of the.-temperature and velocity field. This analysis should include calculations of the mean across-shelf and along-shelf fluxes of temperature(uT and vT) as afunction of depth and spatial Iocation on the shelf,includin.'a breakdown into contributions from different frequency bands_ 4) A comprehensive model of plume rise,ocean circulation, and very possibly bottom and sea-surface atmospheric interaction is necessary to help synthesize the complex processes and interactions involved in the transport and fate of the OCSD effluent. Such a model, including the AES Power Plant plume and other sources, will likely be the only way to reach definitive conclusions about what proportion of beach contamination is due to the OCSD effluent Tracking of plume bacteria 1) One imponant issue that remains unanswered,and should be addressed in future studies,is the question of which chemical and physical oceanographic measurements are suitable Tracers for fecal indicator bacteria and for pathogens directly_ 2) Good high-resolution time series data of some plume indicator other than temperature and salinity would-be beneficial. This will not be possible for . bacteria,but could be done for tracers,such as nutrients, as one (J. LarD er)has r used in other.areas. Commercially available moored nutrient sensors could be deploys along the potential pathway to provide hi h-temporal resolution measurements of a chemical signature of the plume_ MAY -27-03 13 :47 FRDM=D.CSD ADMIM I0= 71496203SE PAGE 9/10 i 3) A.Ithough the objective of the current study was to demonstrate whether the ocean ouffall was responsible for high bacterial counts in the surfzone,the probability that measurable but law levels (1-50 MPN/100 ml) of fecal bacteria in ocean effluent do reach the surfzone remains an important question to answer for all ocean outfalls. 4) The possibility of beach contamination due to local sources on the beach should be furrher addressed. Land based sources of bacteria are not restricted to restrooms, Talbert Marsh or the Santa Ana River_ Bird feces,dog,feces, seaweed, and soil on the beach,and marine mammals are other known sources of fecal indicator bacteria. While bird counts and marine mammal observations have been ' performed in previous Huntington Beach contamination studies,this contingency could be more thoroughly explored. ' 5) A good model of bacterial transport and die-off would be useful_However, bacterial die-off is a difficult issue and quantitative die-off models are rare. One such model is the Mancini model (1978)that expresses a decay coefficient as a function of light intensity,salinity, and temperature.A review ofMancini's data reveal considerable scatter,testifying to the uncertainty implicit in the decay rates derived from the model. However, the Mancini model does at least allow one to O determine the sensitivity of coliform bacteria to sunlight intensity_ A more complete model of bacterial die-off would necessarily be considerably more. complex than the Mancini model. Editorial Comments 1 The final report by the PIs should be written for an audience that is potentially unfamiliar with the issues at Huntington Beach.This requires greater clarity and more careful . explanations. In many chapters, shorter paragraphs would be helpful.The report requires a number of edits-,the most general of which are discussed in this section:Detailed editorial comments are contained within the appendices. The rule to follow is that a short explanation should be stated for each statement or conclusion_The authors should pay � close attention to s rnmar for all chapters.The executive summary, especially, should be carefully edited for clarity, since this is the only section that most people will read. Each chapter should be understandable and.complete unto itself,or at least have clear references to chapters where certain issues are explained. Some chapters are long with 1 many subheading and some are very short with few subheadings: Also,some important information is contained only in the figures and tables,making the reader's task more difn-cult In general,readers should be informed of the experimental design of the study before the results are discussed:The docurnent would be easier to read if each chapter had this structure: I.Introduc ion I Goals or Objectives 3.Experimental Design and Methods 1 1 r— 1Ak-27-03 13 :47 FROM=OCSD ADMAN ID: 71456203SG PAGE 10/10 � r 4. Results 5. Conclusions In Chapter 1,the objectives of the study must be clearly stated in a separate sub-section (objectives are not hypotheses),and those objectives must rnatch the chanter as unnderstood by the S.The objectives listed here resemble those in the original work order, which caused so much confusion at the Iast meeting between the Panel and s_Is the objective of this study to determine where the plume goes,whether it affects the beach at all,or whether it causes AB41I beach closures? This chapter should more effectively introduce the complex nature of the study, particularly the bacterial sampling,to readers, explaining the rationale for creating the type 1,type 2 and type 3 violations and discuss r how the authors would use these categories of violation to interpret results. Without an explanation,these chosen types appear to be arbitrary. - r- Chapter 2 needs a better introduction to the bacterial sampling methods,and should be organized along the lines described above-The three bacterial violation categories are used in the discussion of this chapter,however,since the basis for these three types of violations were not clearly established,the reader cannot determine the significance of 0 these violation-events_In addition, Chapter 9,the methods section, could precede Chapter 2- Also in Chapter 2,combine the plots for total coliform on a sin-le page,one above-the other,to show the consistent.M2 pattern and along-shore propagation.Do the same for each species.This will allow a clearer discussion of patterns and make Life easier for the reader. Compare the timing of observed poleward motions of total coliform with timing Of flood currents measured at the ADCP closest to the shore. _ The PIs should also plot the bacteria data from lines I and 2 in Figure 3=I6 of Volume 2. . This would allow them to examine the question of sampling aliasing.The analysis in Figure 3-16 should be iepeated for ail the intensive sampling periods. It is also important to plot vertical sections (not 3D renditions) of the ammonium data like was done for the bacteria data so that they can be examined for coherent cross-shelf stricture. References r-- Mancini,3_I...-(1978)_.Numerical estimates of coliform mortality rates under various conditions.Journal of the Wawa-PoZhigon Control Feder=on Nov-2477-2484. Pineda,J_ (1999): Circulation and larval distribution in internal tidal bore warm flouts. Lunwlogy and Oceanography 44-.1400-1414 r- r • i� J4N D. VAN-DERSLOOT,M.D- Diplomate, American Academy of Dermatology 8101 Newman, Suite C Huntington Beach, CA 92647 Phone (714) 848-0770 Email one = "c;Y ;l-cc.m Fax (714) 848-6643 May 29, 2003 Mr_ Randy Kokal, Chairman, and Huntington Beach Planning Commission City of Huntington Beach 2000 Main Street Huntington Beach, CA 92647 c/o shess@surfcity-hb.org' Dear Chairman Kokal, and Huntington Beach Planning Commissioners, At the Planning Commission meeting on May 27, 2003, Commissioner Dingwall asked that I refine and reinforce the comments I made to the Planning Commission on that date. As you may recall, I passed out a four-page handout at the Study Session and.I . incorporated that handout by reference at the Planning Commission.Public Hearing, as well as incorporating the comments made by the Coastal Commission staff in its May 8; 2003 letter to.the Planning Commission- I asked that you consider those comments and choose to take discretionary action in voting for the Alternative Action of " . "Continue certification of EIR No. 00-02-and direct staff accordingly". I would like to discuss the handout and the Coastal Commission letter more thoroughly. The first page of the handout was figure 13 of the Poseidon EIR. This figure showed "Projected Mid-Depth Salinity Over the AES Outfall- "Worst Case" Scenario"_ The figure showed how the salinity discharged from the Poseidon operations will-cause a plume emanating from the AES outfall pipe, and how this plume hugs the beach south of the AES plant, including Station 9N. 1 Since salinity is one way to measure the extent of a lume from an outfall, m purpose _ P Y was to show how constituents emanate from the AES discharge outfall, including, but not limited to, salinity, including bacteria_ The salinity is one marker for the plume caused by the AES discharge pipe, but the plume will include other things, including bacteria and chemicals used by the desalination plant, cleaning solutions, concentrated metals, etc. Figure 13 shows what the AES plume looks like. The second page of the handout was "Figure 2_ Huntington Beach Aerial Location Map". This came from the Huntington Beach.Closure Investigation, Phase I. It shows the location of bacterial testing stations 9N, 6N, and 3N, these numbers referring to 1 ' r r J4N D_ VANDERSLOOT,M.D. Dip]omate, American Academy'of Dermatology - 8101 Newman, Suite C - Huntington Beach, CA 92647 Phone (714) 848-0770 Email Fax (714) 848-6643 r thousands of feet north from the Santa Ana River. 9N is the station immediately south of the AES plant, r These bacterial testing stations, particularly station 9N, have been the source of persistently high bacterial readings on the beach, often causing posting of the beach at the end of Magnolia. The source of these elevated bacterial readings has been mysterious, not having been solved even after a $5.1 million dollar Huntington Beach Shoreline Contamination Investigation, Phase HL r If.you then compare the two pages, you will note the apparent coincidence of the discharge plume from the AES plant with the bacterial testing stations, especially 9N, the end of Magnolia, where the worst beach bacteria problems occur. This would indicate to me, and I hope to you, that discharge from the AES plant may be contributing to the beach bacteria problems. The possible role of the AES plant in causing beach bacteria problems is corroborated by additional comments by scientists, including the Peer Review Panel Summary'Report-for-. the Huntington Beach Shoreline Contamination Investigation,Phase III, prepared by.the University of Southem California Sea Grant Program and the University of California, p Santa Barbara, Marine Science Institute. The third page of the handout is the face page of this Peer Review Panel Summary Report, and the fourth page of the handout is page 6 of the report I put a star next to Paragraph 4, and underlined the phrase "AES Power Plant plume". My purpose in doing this is to show the concern that these scientists have in studying the role of the AES power plant discharge plume, as well as other sources, in determining the proportion of beach contamination due to the OCSD effluent_ In addition, I will fax the entire Executive Summary of this report on Friday, May 30, 2003, to be included in the EIR.-This summary is important, as it outlines further studies which should be done to define the important issue of bacterial contamination causing each closures as well as stating that one of the original objectives was to: "1 b � g � 3 ) characterize.the physical.oceanographic processes involved in possible cross-shelf transport of the wastewater plume in the vicinity of the AES thermal discharge outfall" (see page 1 of this report)_ - -- r In addition, UCI scientist Stanley Grant, in his presentation to the OCSD Technical Advisory Committee meeting of April 3, 2003, stated that the bacterial problems at 9N were different from those at Station 0, the Santa Ana River, and 3N, the Talbert Marsh, �- showing a different Total Coliform/Fecal Coliform ratio. He'also stated that there appears to be an as-yet unidentified offshore cause of the bacterial problems at 9N. - r JAN D. VA-N-DER.SLOOT, M.D_ Diplomate, American Academy of Dermatology 8101 Newman, Suite C Huntington Beach, CA 92647 Phone (714).848-0770 Email ' == :ao .con Fax (714) 848-6643 Therefore, could the plume caused by the AES plant discharge pipe be a factor in the bacterial problems at 9N? If so, could an additional influence of the Poseidon operations affe i the AES plume and thus impact the bacterial problems at 9N? The answer should be discovered before the EIR for Poseidon is approved as complete.- iWe know that Poseidon will influence the salinity and temperature of the AES discharge plume. What about bacteria generated by the AES operations, including decomposition of marine life entrained and impinged by the once through cooling system and killed by the 3 0 degree temperature change within the pipes?Larvae, plankton,-and small fish trapped and killed within the pipe may cause a level of bacteria. ' What are the bacterial levels within the AES pipeline? What are the bacterial levels at the discharge pipe? Any bacteria levels over the ambient ocean conditions (<10 MPN/100 cc)that are found within the cooling system pipe or at the discharge outfaU may come to the beach.only 1500 feet away, as shown by the shape of the AES discharge plume, ocean currents, and wind driving the bacteria to the beach. p Even low levels of bacteria can be reconcentrated at the surfzone or at the beach, or be adsorbed to sediment particles, as suggested by Phase III Peer Review Panel, pages 4 and 5. Without knowing baseline conditions of the AES discharge plume with regard to . ' pollution at station 9N, it would be impossible to know how Poseidon operations may affect these.impacts, or what mitigation measures should be required. That is one reason why I suggest you require additional environmental documentation such as a Subsequent EIR or Supplemental EIR. This Supplemental EIR should examine the AES power plant operations as a baseline, since an EIR has never been completed for the AES plant. Once the AES baseline conditions are known, including actual, existing conditions, rather than permitted conditions, then the Poseidon effects on the AES plant can be determined, and mitigation requirements imposed_ For example, one of the baseline conditions not currently known, is the HBGS entrainment and impingement study currently being done, but not yet finished, and therefore the results are unknown. This study is investigating the marine life, including larvae and plankton present in the vicinity of the intake and outfall pipes. 3 JA.N D. VA.NDERSLOOT, M.D_ Diplomate, American Academy of Dermatology - 8101 Newman, Suite C r Huntington Beach, CA 92647 Phone(714) 848-0770 Email sor 'Gol.cOM, - Fax (714) 848-6643 r The Poseidon operations may impact the entrainment and impingement of these q organisms if AES power plant operations are curtailed or suspended for maintenance or- other reasons_ What responsibility should Poseidon have for effects on this marine life if the AES power r plant goes oflline for whatever reason? What mitigations should be the responsibility of Poseidon? With regard to mitigations that are required,what will happen if Poseidon sells its operations to an international or multinational company subject to international trade t '' laws as mentioned in the May 8, 2003 Coastal Commission letter? r �Will any local mitigations remain in effect?Now is the time to lock in the mitigations. u Will there be any element of public oversight of this private company? Is it proper for a private company to utilize a public resource such as ocean water for V r` private gain without public oversight? Has the EIR considered and analyzed alternative locations for the Poseidon Operations such--as Plant 2 at the Orange County Sanitation Di strict? W Has the EIR considered mitigations such as requiring the RO reject brine to be routed X r through the OCSD sewage.treatment system, thus avoiding adverse ocean water quality impacts from its direct discharge to the ocean? Has the EIR considered the human impacts from increased salinity in the area proximate y to the discharge pipe, including station 9N. Will the increased salinity cause mucous membrane irritation, such as eye irritation to surfers and swimmers in the vicinity of the increased salinity? For all these reasons, and the reasons brought up by the Coastal Commission staff; I respectfully request the Planning Commission either request further environmental documentation or reject the draft EIR outright- Z Since this,is the first and largest of the coastal desalination plants to be considered along the California coast in the past 10 years, it is important to get it right the first time. I personally do not see the need to rush this project through without waiting for the studies to be done and to analyze the results. r- r JA.N D. VAI DERSLOOT, M_D- _ Diploniate, American Academy of Dermatology 8101 Newman, Suite C I Huntington Beach, CA 92647 Phone (714) 848-0770 Email ;. ;;t-:G.o i.corn Fax (714) 848-6643 And lastly, what good is this project doing for the citizens of Huntington Beach? I have yet to see a good reason for how this project will bene:t the people of Huntington Beach- The vast-majority of the speakers from the community seem to be opposed to this project. Thank you for the opportunity to comment. Sincerely, r ' Jan D.Vandersloot, NvID I I I5 14 I is f tt TUESDAY,AUGUST 20,2002-DYE INJECTION N4(16:30 to 16;66)-TIME-SERIES DYE IMAGES FROM 16;41 to 1 fi:Afi II 1J — r1,tpp 11.1,�i,•:,k.JY:).:p,•L'.:>,1.� {�y(�v,I(t,!{��:i::;i�;tviei,if:' y,�+vW,,Y:.::.5•:1:,f(•::ILIIYIf``p6 • Jiy� �:1 rp,{ i! IMLH� 1 � A�Ii I�Y'd'Y 9'S?311t-!?' Lb1il�7 '�.et�"'t3p."5��� i'71517'c Jxa1Y'`41� Sk 1.1.1��?'itb�Fi fG r�IZf`f"l lxd e !r a 4r+ r Ealti'^ i f t .0 ill r �� ' ¢;' ' l<•I. rl c c I 1 II 'I •L:Irll+)� • 1 4 INI t!i 1('-I f � r^c�•,'L>�";�;�i"{j;:�? �r,I�(�c. R r��'t?��n��� pg�y{}1.1'�Y�Sj e"YtK' rt�•(��3.�& d% dw"� ryp? in (`, . f '� P ur ?rl��;�•w6 �,�_ r 9. 1 n• ] 1. •y. I f i t 1 tlR JU Pl u 1 .I I'�! ID Y1L ! l l • rt'I R < I s r I I f rr rt+! 1 ,t t �y'fp) tcg�i��aEp�' #d}�"•4a,y�J�';�,'�1t�".. F.�5Ills.11X 1 t C 1 4�'c�` J �'4 VP��" 2 /s ��"" �Y'ln� �a»/3s r �F'�i683Y1�h 3.1'.a U t :r• i f )a t�q��7r���d�� � ,-,•�'k<,.a F.FI G�r'�1 � ..�: t1.lf�:;Fwa •:7�.. ,' ,�tc�d�,.;71CI7�' .�' Y�s� lsAt'>x. !,'�{�EYN�tgP�i • as „., �,w.. ».�..,,. ,. .„w ,.. ..,. a, „,..,.,.,..,,.,,.„ ...• .......... ...........� .. .... .._..•. .• •..,. F rn 1 x LLY {� I ? r'li'141a } Ip' n t r 7 I '�'Ir '��0 6�i f �� - sf�n.' 'ta ��; :'t��2 i t r I r�IrR'°f AJ.',i x,:• . ' ss'r 1x 1 =� / A v .;a i � L, ^��r y�r 1`• wl — California Energy Commission b,Pdry,n Oq.: nhi tlRn NBGS-AESPowerplanl we: ]25011 ' ' 1"Time Series Dye Releases: Y �1-19b 1(OMEX Dy e Release No.4 Part 1 1 ] 7 r r r r r irr rr r r r >ws rr rr rr r rr rr �r ., rr Current Patterns Inferred From Dye Dispersion Image 211 - 8/20/2002,16.10 PDT 12 NA r i Erdave r�rNan Apo; _ e'�rl'�1.,'�; Fluky ` Goo � ? t, TjV IN � fig, �800j001 T IF. kuryrd FFF jtlg- 5"5�.4 7 � r 'r'�S.J s4 ry1 >U Ai i f: 1l�gJrf� r<pq 1f• ,� 'S.3r .x5"� rJ,�'7,� Ijr!fit d 4 1000 r.• ,�r+ F� rja � r a S t dh tf 7 �+ r ,, 1200 2 1400 0 200 400' 600 800 1000 1200 WO 1000 '1800 2000 Ambient Currents 410- Outlal(II Currents —1 Client: California Energy Commission Dale: Aprli 2003 Pmfecl No: 225-001 FroJecusile; HBGS-AES Powerplant Plate No: SOMEX T1tle Inferred Current Patterns From Dye Dispersion � fMFMfObq IITERl ilf 115E ROM 41f III N�IIp ' OEI'if'2NI.1IIgIquNlnlp ISMMESOOIIINFMOf6 Yn IH m�C111td.E1INS[Illtru011110�OUIIMcI iA, r Ut►��a y ff16At'dtAtl S,Irr'iylltbyl"!i 9r�11 r.J. ' 4yh �} {1 f1t;ft•�lyl��q 1!i,�'4�I I'rr rr r I) frk! t if f F 11, _3 "ylrr'tr F i FF7`ti"if�lt�llr��..IA lull f s/ 1! i FJ !.•I! £r c jl .'r I'':• 1 1 r( yE4' h�t�f �1 II 13 I it 1 1 1 I-i Y Y 11 1 5"14 S��A����•I��la rial l}'`{1>�yJ JI J I I' t «`ti.ci{{: .-^��Y�'�' '� rr �` r 1 1 r S �33,,'r�yV Nf��3r'i`'iy��•LirSi{3!r(r{� 1 tl i , 1 £�r 1 (l 1 1 I ! 6.F i 4 1.;I , � 1 1 ! -r , ITNI`tA nl rr�(•1*�� (Y'�� 'ts �k Jt'r. l ,N,r Jx F T1 r P ( - iQKi 1 II 't+i S.�i tl J�,41 (£4 £ 1 fl l'!is { !air, fA— F1 ;l��al,IIt { (l dq ,rfrr {^�rl�yl+3ill yy3rt,rjl'tf 1�tfi7lYR�l illlli�p. 31i azi. 4 '1 77(,J(.'� �ifypr i#yr� (,{I3'£dr ! H'"¢'fisa. II�T�141r I1 }t11tl :�ilt� ai- .h xYtcair r 1: Yr I rl� i -1 itr .Ifs 777 r.�,R����7 ;EJ, {}1�1ri f�lij fail it ,4 rt 31 ifi7lf,IrlJ,'}JF1�fr,it�fJ'LI/17I£ pf N. r^I t r l s t 11 �ty� rl ✓ tr a t,1 � i 3{3{frM J ' 11R`Itrr U £ (fi I` Ir Ittn t 11 t4 �tiJl � J Y Ir� rl C VY f J 7 rft£4t �g, 4L{ y,G:jltl ytt}qdt �11�}I rltS lr'r rl pry. -' IC � rrl Tl ,11i Li 7NRt r' f 'Injil��I�yrItNS,l.tl�1/;rf 41'd� Ir 14tJCr�lli 3Ft� ti r ` r ttl a. t tAS i I:x. k f rMO.', 111.1�1144 + 1 Sl R s !'�rJJJ• J 11 .l�l 1� 4 t !Sa£ IJ if ri I .1 y t'.J i i + y 1. 1 1 #� 4}i, lit I r t l ' h{ 1 4lf/ �1�•x ._IL 4lru l ItI,T XS-,xrj tll J 1 � 1 3 N IS! 1f r1. r I y� +!`i "2£t a 1. J �Jarlr js..4 r fal! off., ' tl d"'A a Asi ItI-.4rj.t - 1 2 J t t_1 ht -Irr. i , 1�•'f r i r r �r rr s �r r rr �s r rr ar r� rr r r r i Ilil .I;! Boat l 1 ! h, .I • ._Y,,1 I I �r ,y f. r� _,,li';r;l'F'� •'ly"'T�7, I•I'�I. /(fh I '•'a'Y�I 1 �`�. I,e clad' li1'C'.ffl i`ial' Llllll1 011 VU Iy011.011r1*.1 c:iat'KTIiLLtiLCi soil iPa4ce 04;ild��7 Irtidi;; EU); 'n 50 knit.di I'liuli How, Ploc. 120,1 ;tl.gd, k�ulkilcr't+�ruli;ir�atn; ;, �i I, sll ,.;L� :; !..13)e;���'•t'ct FKI.1o1'r!Bf�r-.u'ir.!!In!:;nr�•rai1,611i.�d1,>al.f��.l"i)�:D.1.1'�•! I!{l�li ll!(..��.��t t aS +'i l'I'ii I':II'.'�I•'al..^,,.�.I 1i:7�, I'I:�if I r...i Prayt t;�cl..�eafloor Salinity lit' .Ire �C� C)utfal� "'�'V��rs� �;��;�' ��'c :,,< �.ta�i r�I r7 ..—r�r........._+-...�..�._�.--�,.n_._r.—u...:inn,yin..n..�i�,.�r.i�.....r,r,r.r�:,••.nnwl..•�....e�t..•. ..........n�..n.•....�.w..••.�i......._...•.....�.....i.....�... _ - .. I��:IA�{JI ti4' '� ail ii:Ilk tq A {„IjYllit4u;'li i'yi�• � " • r I � • r • r I I • I • • r • I • • r 1 • I • • I n • • • I r r • r. • I • I I • I . • I • • • • • • • • • • • I • I . , r. • • • • • • • • � • • • • L t I'. • , . • I I I • r • r r • • • r . • .� r • � . � • i r i • .� °` ..:�� S Huntington �' "' :��'• � ..� .' . ��. ..... A' Beach: Talbert: .... POar&h tr.eenville BAlInInC Marsh, } Figure . .1n 6,, .oN errii c +,f kilinh ,it scab al rnr co cenfrtted keo eater r irrI R_ ). 511 nfVr..11.faiil 1'1 ow lZm — :'53.4 mad.a}crau vow ILI it,fs;. S^arcs: F'v9�i<:ICm. �,:°ot.rcesGor ir�lli>n ,;M 202 �. R� POSEIDON ,EA',';--`,TER DESr1LIN.-1,710'N'ITC0.(] Projected Seafloor Salinity At the AES Qutfall - "Average" Scenario JAN D. VANDERSLOOT, MD Certified,American Board of Dermatology 8101 Newman Ave; Suite C Phone: (714) 848-0770 Huntington Beach, CA 92647 FAX: (714) 848-6643 July 22.2003 Randy; Kokal, Chairman And Planning Commissioners Huntington Beach PIanning Commission City of Huntington Beach 2000 Main Street Huntington Beach, CA 92647 Re: Poseidon EIR Request analysis public versus private ownership of public water Dear Chairman Kokal, and Huntington Beach Planning Commissioners: Regarding the Poseidon FIR, 1 would like to request that further analysis be done concerning the 1 implications of private versus public ownership and dealership of ocean water,and oversight and ab responsibilities-concerning the public trust of a resource owned by the public, that is, our ocean water. My concerns are as follows: ' 1. Public service sector responsibilities, such as community water systems and services , should not be turned over to for-profit corporations as a matter of sound public policy and for some very practical reasons. ' 2. Water and access to clean eater to meet human needs must be treated as a right and should NOT be treated as a commodity that can be traded for profit. 3. Corporations exist to maximize profits for their shareholders and not to do what is in the best interest of the community or the environment. This is simple fact because that is the nature of legal entities known as corporations. The responsibility of the directors and officers of the ' corporation is to maximize return on investment_That is their mission and affects the way ac business Isconducted, expenditure decisions are made,and how they address, in the water service area, doing what is or is not in the best interest of the consumer,the community and the environment- 4. If corporations are allowed to own and operate and profit from water services they will invariably bring pressure to bear to expand service area, rates and consumption to the detriment of sound environmental stewardship. Examples include the lack of incentives to promote water conservation, enhance water quality, nunimize growth-inducing effects, and to maximize protection of public safety_ Environmental protections and other safeguards will most likely b.e limited to the minimum that government regulations require or what marketing and tax write downs offer as benefits_ 5. Water is a public trust resource, especially ocean waters, and should not be expropriated by private business for profit. r JAN D. VANDERSLOOT, MD Certified__ American Board of Dermatology 8101 Nmmian Ave. Suite C Phone_ (714) 848-0770 Huntington Beach, CA 92647 FAX: (714) 848-6643 6. Public water systems are possible targets of terrorism and it is necessary and appropriate to expect the ovmer-operator to take the initiative to ensure public safety by guarding against attack r or contamination. Public agencies do so as a matter of responsibility and duty notwithstanding the costs involved. Private corporations are not driven by similar considerations. It is unreasonable and naive to expect private entities that are in the business ofproviding public water services for profit to do ar.;u'r.ng above and beyond the minimum necessary to protect the systems. Doing otherwise would reduce profits. 7.The consumer is not protected against unreasonable rate increases if it were solely up to corporations. Experience shows that where corporations operate water systems for public use they invariably push for higher rates. �- 8. It is not clear-whether water services will be encompassed in new international trade agreements currently being negotiated. If such services are included, state and local regulations r .would be Subject to challenge and could be trumped by such trade agmt menis. Complaints filed by multinational corporations challenging state and local regulations intended to protect public safety,health and welfare, including environmental protections (e.g_,water conservation measures, limits to service area to guard against adverse environmental impacts stemming from r the growth=inducing effects of the system)would be resolved through secret trade dispute resolution tribunals established by the WTO or other international trade organization. Public a C water agencies would NOT be subject to international trade agreements while the investment and r operational activities of multi-national corporations to maximize return on investment would be. Experience around the world shows a growing number of examples where multi-national corporations that were given approvals to operate water services for public consumption are s taking the country in which their investment is made before international trade tribunals to seek compensation for lost profits as a result of some state or Iocal government action protective of local community values. Why would a public governing body,like a city or county or even a state,knowingly put its residents in harm's way even where such harm is merely potential at this time?Longer range thinking is essential and the question must be asked whether privatization of public water services r is in the long-term best interest of the public. Why shoul d investment ventures for private profit benefit at public expense?Are we as a society " so poor or so desperate that we need to turn over the keys of control over what the United Nations has recognized as a fundamental human right, access to drinking water,to amoral,.self-serving corporations that do not and cannot place community best interests above those of the bottom r line? Please address these comments in the revised.EIR and in your deliberation concerning the ,- wisdom of granting the permits to the Poseidon desalination firm. Thank you- r Sincerelv Jan D. Vandersloot_MD r Tampabay: Desal builder files for bankruptcy Page 1 of 3 V�Teather Sports I Foa ams Comics Classifieds Calendar ?-4ov1'es Desai b;iflrfimr fiioc fnr hnnVn inf-t �u t :.e Covanta Tampa Construction becomes the third contractor to do so. Tampa Bay Water views the move as a way to prevent being fired from the 5110-million job. By CRAIG PITTMAN, Times Staff Writer ' Published October 30, 2003 ' The builder of the area's huge desalination plant filed for bankruptcy Wednesday, preventing Tampa Bay Water from firing the company and hiring someone else to finish the $110-million job. rConstruction of the.Apollo Beach plant was completed last spring, but sporadic water production has required further woik. ' Tampa Bay Water is counting on the plant to produce a sixth of the utility's needs - or, about 25-mi1lion V ad gallons out of 150-million gallons a day. rBut for the past five days the plant has not cranked out a sin-ale drop, utility officials say_ This marks the third bankruptcy associated with the construction of the desal plant,which ultimately is ' expected to be the largest in the United States. Two previous contractors, including the parent company of the one that filed Wednesday, also declared bankruptcy. ' Covanta Tampa Construction filed for Chapter 11 bankruptcy in New York City, even as company officials were negotiating with Tampa Bay Water officials to avoid being fired in two weeks. "To us this amounts to a betrayal of the public trust," said Tampa Bay Water general counsel Don Conn. That's not the way Covanta officials see it. They say by filing for bankruptcy,they have guaranteed that ' they will finish the plant with no increase in cost, rather than some other contractor stepping in and doing the job for more money. iCovanta has two dozen employees worlang on the plant every day; trying to get it running; and this way they aren't distracted by the prospect of losing their jobs, said Covanta vice president Scott Whitney_ "We're the only ones doing anything productive," Whitney said. "Tampa Bay Water seems to be focused on public relations and finding a way to terminate our contract." ' Begun two years ago, the plant is supposed to take 40-million gallons of seawater each day from Tampa Electiic Co.'s Big Bend power plant next door and force it through 10,000 tightly woven membranes to produce 25-million gallons of potable water and 15-milli on gallons of brine_ Y http://www.sptimes.comJ2003/10/30/ne-v�Ts_pf/Tampabay/Desal builder files f.shtoal 11/12/2003 r Tampabay- Desal builder Tiles Tor banicuptcy ragc Ul , r The water goes to TarnpaBay Waters 2-m1111On customers, while the brine is mixed with the electric company's regular discharge into Tampa Bay. r The plan-Cs original contractor, Stone&Webster, went bankrupt in 2000. Ayear later its replacement, Covanta Energy, filed for Chapter 11 too. Tampa Bay Water stuck with the company, which the utility's general manager, Jerry Maxwell, defended as the only way to keep construction moving forward. At T.npa Bay W ater's insistence, Covanta created a subsidiary that would continue building the plant. That subsidiary, Covanta Tampa Construction,has one asset: the contract to build the desal plant. r- "It has no other existence on Earth," Maxwell said earlier this week "If they bankrupt it,they will prevent us from going in and effecting a repair." . r- Although construction is done, the key to completing the plant is a 14-day test to show that everything is running smoothly. Covanta ran the test in May but failed to satisfy Tampa Bay Water,which was concerned about problems that could drive the operating cost above the budgeted $10-million a year. r It noted 17 problems, not the least of which was the filters clogging more frequently than expected, 8CI I ; which required cleaning more often and with a stronger solution_ _ r- Covanta officials have blamed the clogging on Asian green mussels that stick to the intake grates.- The need to chance and increase the cleaning solution for the membranes caused a bigger problem_ r Hillsborough County balked at allowing large quantities of the cleaning solution to be disposed of in its sewer system, so Covanta was forced to store 2-million gallons in tankers parked around the site - a glitch Covanta blamed on Tampa Bay Water. r In June,the utility gave Covanta until Sept. 30 to successfully complete the 14-day test. When Covanta failed to meet that deadline, Tampa Bay Water's board voted to find the company in default of its r contract. ; A default meant the company would face$465,000 in fines, as well as a requirement that it hand over 306-million gallons of free water. But it would still have until Nov. 17 to fix the problems. If Covanta still had not completed the test successfully by Nov_ 17, though, the board said it would fire r Covanta and use a.$23-million perfornnance bond- guaranteeing the completion of the plant -to hire a replacement to finish the work_ Conn, general counsel for Tampa Bay eater, said that during negotiations on Tuesday Covanta official said they could not start the two-week test on Nov. 3, the Iast possible date on which to start and still finish the test by Nov. 17. r Conn said the bankruptcy filing appeared to be a defensive action "to protect them from inevitable termination_" Because the company's sole asset is its Tampa Bay Water contract, any attempt to fire Covanta requires approval of the bankruptcy court judge, Conn said. h,Tilder files f.shtml 11/12/2003 I-ampabay.- Resat DulIaer Mes ror oanKzupLcy ' The same goes for the $23-million performance bond: Tampa Bay Water cannot claim that money tivithout getting a judge's approval. The company filed for bankruptcy in New York because that's where its parent company filed too, Whitney said. ' The New York City bankruptcy court "is a very popular destination for bankruptcy filings," Whitney said, so getting a hearing could take a while. ad Since all the company's assets are in Florida, though, Tarripa Bay Water may file an emergency motion to move the case here, as well as challenging whether the company can really call itself bankrupt at this point, Conn said. - Times staff writer John I-Ell and researcher Caryn Baird contributed to this report. 0 Coovria-ht 2003 St. Petersburc Times. All rights reserved h ://www.s times-com/2003/10/30/news f/Tam aba /Desal builder files f.sh-(ml II/I2/2Q03 ttP P P y _ _ _ r - r SUGGESTED FINDINGS FOR DENIAL, CONDITIONAL USE PERMIT NO. 02-041 COASTAL DEVELOPMENT PERMIT NO.02-05 - r GGESTED FINDINGS FOR-DENTA7,-CONDITIONAL USE PERMIT NO. 02-04: conditional Use Permit No.02-04 for the establishment, maintenance and operation of a seawater desalination plant producing r million gallons per day(MGD) and up to four miles of water transmission lines will be detrimental to the general welfare of sons working or residing in the vicinity or detrimental to the value of the.property and improvements in the area because: r �e proposed desalination plant will take 100 MGD of raw seawater from the Pacific Ocean through the existing AES aerating station intake line and discharge 50 MGD of brine thereby increasing the ocean-water salinity which will have a r ,ative effect on local beaches. ,he proposed desalination plant will utilize the existing AES intake and outfall,which are outdated. the conditional use permit will be incompatible with surrounding uses because the proposed project is an industrial use within �t 3e proximity to sensitive residential uses. It will also discharge brine into the ocean in close proximity to a wetlands area. r GGESTED FINDINGS FOR DENIAL COASTAL DEVELOPMENT PERMIT NO.02-05: ;oastal Development Permit No.02-05 for the development of the desalination plant and approximately one mile of water r ismission lines within the Coastal Zone, does not conform to the goals and policies of the General Plan, including the Local istal Program and Coastal Element as follows: r 6.1.1 -Require that new development include mitigation measures to enhance-eater quality, if feasible; and, at minimum, t vent degradation of water quality of groundwater basins,wetlands, and surface water . proposed desalination plant further degrades the ocean water quality and may have an impact on the adjoining wetlands. 6.1.2-Marine resources shall be maintained, enhanced, and where feasible, restored- proposed desalination plant further degrades marine resources. r r i r r I r FINAL DRAFT three cold-water events occurred at the intake mooring (water temperature less than 13.5'q, indicative of sub-thermocline water. Corresponding temperatures in the intake vault were lowered, suggesting partial entrainment of sub-thermocline water by the AES HBGS. As part of this investigation, ammonia sensors were to be deployed on moorings and in the intake vault, however technical limitations of the equipment prevented the successful deployment of the ammonia sensors,conseauentiv ammonia samples were collected from four locations within the AES HBGS facility (discharge vault at zero-feet, ten-feet, and 30-feet depths, and the intake vault). Based on the results collected in this study*he following conclusions have been made: • Sub-thermocline water is occasionally entrained into the AES HBGS intake. During this study there were no specific indications that the intake water contained part of the OCSD plume. However one event in August and three brief events in September demonstrated r (brief) entrainment of sub-thermocline water into the intake vault. The mechanism required to support the Grant Hypothesis has been demonstrated;.v y four brief occasions in this Study; - `= OR. of • Concentrations of bacteria introduced to the AE!jt—'6? rorr`-fie ocean do riot increase l �, significantly in numbers during passageirczugh �the'�cooling water system prior to discharge;' , . Al • Land based sources of culaFl bacteria,�pti ;BED`and BFV1)do enter the discharge vault and Y n +<F are discharged to the e ��� n©# at concentrations high enough to contribute significantly to bacterial conitanaftlatia, of the surf zone of Huntington State Beach;and • The sanitary sewers, tr�,the HBGS are not connected to, or leaking into the discharge vault Because of the microbial and oceanographic results presented in this study further investigation of the role of the AES HBGS.facility in surf zone water quality of Huntington State.and. City: Beaches is not recommended at this time. As a general principle, discharges of fresh-water through the AES HBGS discharge vault and outfall should be minimized. Any revisions to the discharge limits for the AES HBGS should be determined as a result'of a complete review of all available studies including this report during the NPDES permit renewal process(2004-2005). Additional recommendations include diverting the storm drains to an adjacent sanitary sewer line,and treating runoff within the AES HBGS to remove contaminants Cmduding heavy metals and bacteria). r 24632_1.Doc Iv KOM EX USA,CANADA.UK AND WORLDWIDE ny I fit �4 jj WJ • 1,tZ, A. 14'q ggl ry S. n— t 4-1 v.7,Y -P IF m ...... g.- if) Or ,,;l ---q-A; It I P, a v 5-It to Wt. f 117 0 2 1141 h, a Wirt er 14�44 A, j WO -As J-1 0'. a ,41 I'It.f q IPA 1.r .1 w t j! Ww"'?'" ta fv .47i 147i�J k IMF" TF A NIP W ;jT w�J —T.t- "k, 4v fit 1,.,j 1. IT -7. t, Amn A Ali; i'T;,1F.�Vq �Jr -10 4 am I-A S-W� of, ki cfx ri`4� P.A.A.. '!r.0 it at is Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 48 Jan D. Vandersloot 48a. The commenter encloses comment letter dated November 16, 2003 with attachments. In accordance with CEQA Guidelines Section 15088.5, those who desired to comment on the DREIR were directed to submit new comments. Accordingly, comments received during the earlier circulation period do not require any response. "The lead agency need only respond to those comments submitted in response to the recirculated revised EIR." ' Although responses to the prior comment letters were previously made and are not required for the DREIR, each of the prior comments has again been responded to here. Refer to Responses 48i through 48af, below ' It is important to note that the AES Huntington Beach Generating Station Surf Zone Water Quality Study(Final Draft), 2003 prepared by Komex H2O Science, ' Inc. was incorporated by reference into the DREIR. The commentator makes specific comments with regards to pages 2-9, 4-19, 4-20, 5.10-2, 5.10-5, and 5.10-27. The commentator is correct in stating that the Komex study states: "Land-based sources of bacteria (particularly BD and BFW)do enter the discharge vault and are discharged to the ocean, but not at concentrations high enough to contribute significantly to bacterial contamination of the surf zone of Huntington State Beach...... However, it would be misleading to state that bacteria ' from HBGS reaches the surf zone and contributes to the beach contamination problem as suggested by the commentator. As pointed out by the Komex study and shown in Figure 4-3 of the DREIR, the primary source of bacteria that comes ' out of HBGS' discharge is not from the generating station but rather from off-site urban runoff. ' 48b. Two scenarios are proposed for the washwater disposal process, as a result of cleaning the RO membranes. The "first flush" cleaning solution discharge would either be neutralized and conveyed to the OCSD wastewater treatment facility for ' disposal or neutralized, blended with the desalination concentrate and discharged through the HBGS outfall. Subsequent rinses under either scenario would be neutralized and blended with desalination concentrate for discharge ' through the HBGS outfall. In addition, refer to Response to 17k, above. Note that the membrane cleaning process would utilize chemicals such as citric acid, hydrochloric acid, low-concentration caustic soda, and mild detergents _(all ' of which are similar to household cleaning products). Any bacteria that survive the RO filtration process would be killed during membrane cleaning activities, and would not lead to bacterial contamination of the ocean. 48c. The DREIR acknowledges that, under extreme conditions, there is a possibility that the OCSD wastewater discharge could reach the HBGS intake. However, even under such an extreme scenario, the OCSD discharge would be diluted 30 million to one and would not be a significant source of contamination at the HBGS intake. Any bacteria associated with the OCSD discharge would be City of Huntington Beach August 17, 2005 ' 331 - Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS removed through the RO filtration process. In addition, refer to Response 21f, above. 48d. Regardless of whether the OCSD discharge is the cause for bacterial contamination problems at Huntington Beach, the proposed project has the ability to filter bacteria and produce potable water meeting all regulatory drinking water standards. 48e. Comment noted. The intent of the DREIR was not to determine the cause of r high bacterial levels near the shore of Huntington Beach, but evaluate potential contamination sources to the source water for the desalination facility. Refer to Responses 48c and 48d, above. 48f. The number of reverse osmosis membranes per RO train are 1,328. The total number of installed RO membranes is 13 RO trains x 1,328 = 17,264. 48g. The proposed project would not alter HBGS operations, including nighttime operations. Refer to Response 1g, above. 48h. This paragraph provides a conclusion to the comment letter and does not require a response. 48i. This text provides an introduction to the comment letter and does not require a response. 48j. Refer to Response 48a, above. 48k. Refer to Response 48c, above. 481. Refer to Responses 2aq, 33f and 48c, above. 48m. This text provides a conclusion to the comment letter and does not require a response. r 48n. The numerous issues raised regarding bacteria levels off-shore of Huntington Beach are noted. However, it is important to restate that the intent of the DREIR was not to determine the cause of high bacterial levels near the shore of Huntington Beach, but evaluate potential contamination sources to the source water for the desalination facility. Refer to Responses 48c and 48d, above. 480. The Executive Summary for the Review Panel Comments on the Huntington r Beach Phase ill Final Draft Report is noted. No response is necessary. 48p. See DREIR page 4-19 and refer to Response 48n, above. r 48q. Refer to Response 1g, above. 48r. Refer to Response 1 g, above. r- City of Huntington Beach August 17, 2005 332 � Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS ' Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS 48s. Mitigation measures that the project applicant would be responsible for implementing are stated within the DREIR. Additional mitigation requirements may apply at the discretion of regulatory agencies during the permit acquisition process. 48t. The proposed project would be subject to the same requirements and regulations that a similar publicly-owned facility would be subject to, regardless of international or multinational ownership. In addition, refer to Response 2aq, ' above. 48u. Refer to Response 48s, above. ' 48v. Refer to Response 48s, above. ' 48w. Alternative locations are analyzed within the DREIR within Section 7.0, ALTERNATIVES TO THE PROPOSED PROJECT. The OCSD facility is not analyzed, since adequate land is not available (refer to page 7-6 of the DREIR). ' 48x. As noted on Page 7-21 of Section 7.0 of the DREIR, the OCSD discharge alternative was rejected by the OCSD staff because of capacity constraints at the OCSD facility. _ 48y. Salinity impacts are analyzed within Section 5.10 of the DREIR, OCEAN WATER QUALITY AND MARINE BIOLOGICAL RESOURCES. Under a "low flow" ' scenario, mid-depth salinity would drop to 10 percent above background salinity within 1,200 feet of the HBGS outfall. Under an "average flow" scenario, mid- depth salinity would drop to 10 percent above background at only 430 feet. Such an increase is not expected to affect recreational users. 48z. This text provides a conclusion to the comment letter and does not require a ' response. 48aa. The graphics attached to the commentator's letter have been noted. ' 48ab. This paragraph provides an introduction to the comment letter and does not require a response. ' 48ac. Refer to Responses 2aq and 20s, above. 48ad. The commentator's attachment to the comment letter is noted. Refer to ' Response 17d, above. 48ae. The information provided in this comment is not relevant to the DREIR, and does ' not require a response. 48af. The commentator's attachment is noted. No response is necessary. City of Huntington Beach August 17, 2005 ' 333 i COMMENT 49,- CIty of Huntington Beach MAY 2 7 2005 LAST �17 - i �,�-�-.�' �r2�;-oy=�?.��f�11/�.ar i�orY�.��� ,Vr'v' ,�!.Gi�.T I - • rlC L ;�N!s �r i��5 / 1N%Lrx ri�/�( I S ;n'R � /� i a✓i i�1 IN �r �Yi�-T �✓rcT r��3� �'v��,� �'vc�✓,�e� ,cn� ��.`7G c�s7-t>t/�SSf-llr�� - '�� ���.s�=r'>��ii ',v��:✓� �c�sc ir�'�-.4�5 t�vL�.�r�'�r�-;-� �.�tV - - A-2�FL 45- �l�Lli i,.Ab zz — ��=,Q,�7� ire S=�_v�7d !�-ra�"�.=N��c��f'%'��5 Co���lv !� S��• 6.�C���F�Nr-�t . • � i?�v1r�`��lA:,�V'.�i�cy �Nj II�1�U?-z� tilc;AN lyv �i- �'j'/L�-S �;_ �/.- �S 11�1 C IU r ID/� %E74-111 //IV IU 7iV7 'OY-S . C/7/Z--lYS IWJZZ f� r S'c S 1Z� 4N� � GY'�leV{• Tf, 'L' HPL,&Z 1,1A !`� Sl/r��; j-✓ fi!L T/G in/ �Clt /zV.l 7:�--47-1S Z&-,/A7 G�.�; ��0��� tv�r�,:4,� :?�� ��—�- CL,9/i�i��-,`j,�.�r����� �,c��2 /.S /�-115:�;��� • :A�R�i�;�� J��J C�'�r��iv�� Sti$ 9jPrnv7-/'�r /c7gs Tt3 � 5 r4'Z Sat i i' / 41Ca�iC� �i%>-GI�G�;/ �,%��r�%6 ?,`,��._-•�;'����-1';cS /tj� Co�vs�L�4'�7�1�1 - — i f Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 49 Todd Van Etten 49a. Refer to Response 17d, above. The author's comment regarding impacts to tourism does not contain a specific comment relevant to the DREIR, and cannot be responded to. 49b. Refer to Response 1 g, above. r 49c. Refer to Responses 2ar and 2as, above. In regards to pipeline construction L impacts, implementation of product water pipeline would require approval prior to construction. The construction process would be subject to such measures as the exclusion of construction during rush hour periods, preparation of a Traffic Management Plan, and roadway re-striping, among others. The project applicant would consult with the City during final design to ensure that adverse impacts are minimized to the maximum extent practicable. Additional mitigation measures to minimize impacts to sensitive receptors are included in Section 5.9, CONSTRUCTION.RELATED IMPACTS of the DREIR. 49d. Refer to Response 24a, above. City of Huntington Beach August 17, 2005 335 r COMMENT 50 Pale I of I From: Kris Westwell [krisw@truwest.com] Sent: Wednesday, May 25, 2005 5:42 PM To: rramos@surfc4-hb.org Cc: jflynn@su (city-hb.org; lehringksuI1city-hLJ ' Subject: Desal EiR Comments . I feel the Poseidon Desalination project EIR fully identifies all of the impacts of the project and 8 find it to be adequate and complete and encourage you to support staffs. recommendation to accept the recirculated EIR as adequate and complete. I urge you to vote yes and approve the Poseidon Desal EIR. Thank you. Kris Westwell 17171 Englewood Cr. t. I BCA 92647 kHsw@tuwest.com 714.842.4075 1 - Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Response No. 50 Kris Westwell 50a. The author expresses support for the proposed project. No response is necessary. it City of Huntington Beach August 17, 2005 337 COMMENT 51 Page 1 of 2 From: Norm Firecracker Westwell [nor mw@modernpublic.com] Sent: Wednesday, May 25, 2005 t35 PM To: . rramos@surfcity-hb.org r Cc: jfiynn@surfcity-hb.org; lehring@surfcity-hb.org ' Subject: Poseidon Desal EIR 00-02 Comments Support for approval of EiR 00-02 Saltwater Desalination Facility. - have read and understand the recirculated EiR 00-02 for the saltwater desafination project and find the document to be both adequate and complete. a While it is acknowledged that any project will have some impact on our community, the negative impacts_ identified in the EIR are negligible. The benefits our city and its residents will receive will greatly exceed the insignificant impacts identified. This is a positive-project for HB because it will: . Not cost taxpayers or the city one penny. The project is privately funded. There.is no cost to taxpayers and no financial risk for the city. . Clean up and improve the existing site. b . Provide street improvements to Newland St. . Enhance public safety. The HB Water Master Plan identifies our water storage capacity as inadequate. This project will create an additional 10 million gallon water storage tank valued at $14 million at no cost to taxpayers and will provide emergency water to S.E: HB. ' . Foster increasing prosperity by directly and indirectly creating new employment opportunities in HB. 1 Will create a new city government revenue stream of$1.8 million annually which we desperately need to maintain services. L Page 2 of 2 • Save residents money. The copper pipes used throughout HB will last longer due to the less aggressive water produced by the desal plant. All HB residents will directly benefit from reduced plumbing maintenance expenditures resulting from deteriorating copper pipes. b . Government studies confirm that conservation alone will not be adequate to provide for our future water requirements here in our desert community of HB. In addition, conservation reduces water and sewer tax revenues the city receives. Utilizing our local natural resource to enhance the lives of our citizens is responsible, practical and - economical and will benefit our residents. In summary, I fully support the HB staff recommendation to accept the recirculated EIR as adequate and complete and strongly urge the approval of this EIR to move the C project forward so our citizens will soon enjoy the benefits of utilizing the one natural resource available to us, the ocean. Norm "Firecracker" Westwell 17171 Englewood Cr. HBCA 92647 714.842.4075 JL ---------------- Norm Firecracker Westwell normw@modernpublic.com www.modernpublic.com . L r- Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS J 9 Recirculated Environmental Impact Report 2.0 RESPONSES TO COMMENTS Respo nse No. 51 Norm "Firecracker"Westwell 51 a. This text provides an introduction to the comment letter and does not require a response. 51 b. The author expresses his support for the proposed project. No response is necessary. 51c. This text provides a conclusion to the comment letter and does not require a ' response. City of Huntington Beach August 17, 2005 340 ' ay 27 05 10: 15a William Yarchin, Ph. D. 714-962-9187 p. 2 COMMENT 52 Mav 27, 2005 Ricky Ramos CAl3' v1 i.ut.tuigrvu 17Ga1lti P[Q[rnLfii`,' ilCp[it tt[tejlt 2000 Main St Huntington Beach, Calisomia 92�48 I=Ak 714-374_I;40 RE: EIR `as praaos%ed.desatinizatioa R! nt_ Dear.Planning Department: Please listen to the.vou�s-of FMxesidents-aswwe plead-vylth yotu tere;=t the .at...st Eu%. u vr[.Pt'3seiut3il Lowai uS d-ie building of a desalinization plant. The overaii negative impact on the rocal'quaIity ofliie and'natural resources is still,.even in this revised.JEIR, tog great-tc-re r►onsibly Q< Yro ect to proceed. The track record of Ptsuei,clo if histo7-Y teaches .. a us anything ii is t:at 'ILM Iwxpayers and water districts will ultimately be - buruened with the F[aancidFhLnd'engineeriag wreckage that Poseidon wif leave behind_.Whatever-lona-.term.cif this project'r`J3li CGtue to I3aii h.,.as wr fli.Tampa-Bay... 1 In particular, the southeast corner of1� will be relegated toh�r indusuializat:ion-contrary-to-the-wishm-of-thc-msidents-ag they have been consistently expressed_for_over 3-0--yeaSs. In sun-.there.is nothia good-for HR ab -GLlt-the prE} 4 de 17 g fpG sal:u- zatiE3n. project. Please tarn.it down. Respectfully, William Yare 9291 Hudson riva, Huntington eaC114 CA Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS 1 9 Recirculated Environmental Impact'Report 2.0 RESPONSES TO COMMENTS Response No. 52 William Yarchin 52a. Refer to Responses 17d and 35a, above. r r 1 l- f L r L L City of Huntington Beach 342 August 17, 2005 � C_ ' Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 3.0 ERRATA 3.0 ERRATA TO DREIR TEXT Changes to the EIR are noted below. Additions to the text are indicated with underlining (example). Deletions to the text are indicated with stricken text (example). Changes have been analyzed and responded to in Section 2.0, Responses to Comments. The changes to the EIR do not affect the overall conclusions of the environmental document. Changes are listed by page and where appropriate by paragraph. ' NOTE TO REVIEWER: This Errata has been prepared in response to comments received on the DREIR, which was ' available for public review from April 5, 2005 to May 27, 2005. Additional editorial corrections have been initiated by City staff. These clarifications and modifications are not considered to result in any new or greater impacts than identified in the DREIR. To avoid redundancy, it should be assumed that additions, modifications, or deletions of text within Sections 5.1 through 1 5.11 of the DREIR, when applicable, are reflected in Section 1.0, EXECUTIVE SUMMARY. Page 1-3, ENVIRONMENTAL SUMMARY ' LAND USE "The proposed desalination facility is not anticipated to create any impacts to surrounding uses with regards to air quality, noise, aesthetics, hazards and hazardous materials, and short-term construction. Significance: Less than significant with mitigation." Page 1-14, ENVIRONMENTAL SUMMARY TRAFFIC "CON-31 A Traffic Management Plan (TMP) shall be prepared and implemented to the satisfaction of the affected jurisdiction within which the facilities are to be constructed ' when the facilities are to be located where construction would affect roadways. The TMP shall include, but not be limited to, the following measures: ❖ Limit construction to one side of the road or out of the roadbed where possible; ❖ Provision of continued access to commercial and residential properties adjacent to construction sites; ❖ Provide alternate bicycle routes and pedestrian paths where existing paths/ routes are disrupted by construction activities, if any, and prior to initiating construction, the public shall be notified as to which bicycle routes will be disrupted and when construction will commence; ❖ Submit a truck routing plan, for approval by the City of Huntington Beach, County, and other responsible public agencies in order to minimize impacts from truck traffic during material delivery and disposal; ❖ Prior to any partial or full closure on a street.within the city of Costa Mesa's limits, a detour plan shall be submitted to the city for approval by the City Transportation ' Services Manager. Where construction .is proposed for two-lane roadways, confine construction to one-half of the pavement width. Establish one lane of traffic on the other half of the roadway using appropriate construction signage and flagmenz;or submit a detour plaR feF approval by the city TFaffiG F.Rg;Reel:� City of Huntington Beach August 17, 2005 343 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 3.0 ERRATA ❖ The TMP shall be approved by affected agencies at least two weeks prior to construction. oor Galtranc ro.. iromo As +The applicant shall submit the TMP to Caltrans and the city of Costa Mesa at the 90-percent design phase; ❖ Construction activities shall; to the extent feasible, be coordinated with other construction activity taking place in the affected area(s); and ❖ Provide for temporary parking, where necessary, during installation of pipelines within the AES site. CON-32 Prior to initiating the removal of structures and contaminated materials, the contractor must provide evidence that the removal of materials would be subject to a traffic (� control plan, for review and approval by the by the City of Huntington Beach Department of Public Works. The intent of this measure is to minimize the time period and disruption of heavy duty trucks. For all work done in the City of Costa (� Mesa, the project applicant shall receive approval from the Costa Mesa Public L Services Department. (� CON-33 Construction related activities would be subject to, and comply with, standard street use requirements imposed by the City of Huntington Beach, County and other public agencies, including the use of flagmen to assist with haul truck ingress and egress of construction areas and limiting the large size vehicles to off-peak commute traffic periods. For all work done in the City of Costa Mesa, the project applicant shall receive approval from the Costa Mesa Public Services Department r I CON-34 The Contractor shall obtain the necessary right-of-way encroachment permits and satisfy all permit requirements. Nighttime construction may be performed in congested areas. Also, any nighttime construction activities shall have prior approval by the City of Huntington Beach Department of Public Works. Any nighttime L construction activities in the City of Costa Mesa shall receive approval from the _. Public Services Director. (^ CON-35 During periods of heavy equipment access or truck hauling, the Contractor would provide construction traffic signage and a construction traffic flagman to control construction and general project traffic at points of ingress and egress and along roadways that require a lane closure. CON-36 The proposed truck haul routes. It shall specify the hours in which transport activities can occur and methods to mitigate construction related impacts to adjacent residents and the surrounding area. The plan shall take into consideration any.street improvement construction occurring in the vicinity. These plans must be submitted for approval to the Department of Public Works. The applicant shall coordinate all construction traffic related activities with Costa Mesa's Public Services Department. The construction vehicle routing plan in the City of Costa Mesa shall be submitted for approval by the City of Costa Mesa Transportation Services Manager." Page 2-10, INCORPORATION BY REFERENCE r "... Much of Bulletin 160-98 (the update of the Water Plan performed in 1998) is devoted to L identifying and analyzing options for improving water supply reliability. It should be noted that an update to Bulletin 160-98 ("Update 200541') has commenced and a Final Water Plan Update L City of Huntington Beach August 17, 2005 r 344 t- Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 3.0 ERRATA is anticipated to be complete in April 2005. ' Public Review Draft California Water Plan Update 2005 State of California Department of Water Resources, 2005. The Draft California Water Plan, Update 2005, assesses California's agricultural, environmental, and urban water needs and evaluates water supplies, in order to quantify the gap between future water demands and the corresponding water supplies in 2030. The series, consisting of three volumes, presents a statewide overview of current water management activities and provides water managers with a framework for making water resources decisions. Seawater Desalination and the California Coastal Act March 2004. This report provides information about many of the issues related to desalination along the California coast, focused on how they relate to the Coastal Act. It summarizes the status of desalination along the coast and lists the known anticipated facilities now being planned. This document also updates the Coastal Commission's 1993 report, Seawater Desalination in California, to reflect changes in technology, improved understanding of coastal resources, and additional policy considerations of the Coastal Act. " Page 3-5 Revised Exhibit 3-3 Conceptual Pipeline Alignments (Provided on following page) Page 3-29, New Water Transmission Pipeline "...the pipeline would pass under the SR-55 freeway utilizing trenchless construction until it 1 ultimately terminates at OC-44, located at the intersection of Del Mar Avenue and Elden Avenue. Refer to Table 5.9-3, PIPELINE ALIGNMENT DETAILS. ' Primary Alternative The primary alternative route has a length equal to that of the primary alignment (7.5 miles). ' However, under this alignment, the routing of the pipeline varies from the primary alignment between the intersection of the Santa Ana River channel and Adams Avenue to Placentia Blvd. Instead of further traversing Adams after the Santa Ana River, this alignment has the pipe routed south along the river to just south of Swan Lane and then east along the northern r boundary of the city park until it meets the original primary alignment at Placentia Blvd. This alignment reduces congestion along Adams Avenue and utilizes some of the Santa Ana River right-of-way and the city park space. Finally, the reach (Reach 5) of pipeline on Fair Drive will be ' located in the center of the street between Harbor and Fairview Road and within the Orange County Fairgrounds (just north of Fair Drive) between Fairview Road and Newport Blvd. This primary alternative alignment is expected to minimize construction impacts in regards to ' roadway traffic and sensitive receptors." Page 3-36, Need for the Project ' ..It is well established that Southern California as we know it today could not exist without the region's historic investment in numerous ap4-varied local and imported water projects. These ' well-known regional water projects include: the Los Angeles Aqueduct (operated by the Los Angeles Department of Water and Power); the State Water Project (operated by California Department of Water Resources [DWR]); and the Colorado River Aqueduct (operated by MIND), ' as well as award-winning conservation, recycling and other local water supply projects. MWD continues to encourage the development of local water projects..." City of Huntington Beach August 17, 2005 345 rr r r� r■r r� rr r r r rr rr r rr a■i rr rr rr rr rr -� .t-, } t•� ,�f .4) .}'erlryye ( 'j 5 - .......... 6 { t .,t �r 'haltrino- 9ch1� j I I hllw - i - J / 7V 1 •I — I7 1 1 t •�� w {,S,J,,� t... -. '� u� ;S: � � '. � ± h;:� �✓ `�„�,t �«less to � �� �' _ It•{1- , :S i �til; z; ,. �� � �1■,.� t 1 M �`e a `�,�"•1� it �i I R L�_q T __ _ _q (t�l! unt ( f` •, - i S J ^Ihni41: ■ e' J,k t. Lt • b ' y;Ct,a� Jlll�� d a'■ .I1 ■ t I■ r 1 ,� ■I tr't p1� Co Right • k pp 41 A N Yy ° � .Ai,S �. _ c(/ t° - •Ad�� �9 L,�"lam. 1 1�,,. ��J•—� S Y so� Zot .�•�_ — 4248" ,_:t . e Me DIAMETERS I ��- x�°°gpn°' Cw \..., ..,� n ' J g yyt ice• fY � � ICE I II_f t TE. Sl.i v rzi ��� Ra PRIMARY �TY\ A tbfn PRIMARY ALTERNATIVE�w ALTERNATIVE JAIRGROUNDS �� slmB An � � okl /1' / •'J,_ f•,l� - �, �""� lf/{ t`i •COuntry_CI � s r � III � � " _. � ! � f/f� (f �0 �{��� .•��rrr%r�� rrrrrrrr ar3 .a • ��-. ' � PRIMARY ram r Se ♦i ' I II �:•rs_' � l�rf z m+.� _ __�_57 �-•'Right-of-Way 42-48" �S_ 1 • 1^;� hYY�s 1p 1� T yam' t I I R"_'tY.l f:m cch n —wn ,DIAMETER •. i m � , oom u • I f r ♦• d.. '.1nr.,... _ n-�_n_.a_1�.ti. _ _ J•♦ l' �'iLind ra •f■•.:.- ;`=__a::c_co. i- i ..�:;�„',.' 'f L / .�f ��IS' Yca mesa was 0 man h n u.rart ' ,� �!`+.�• `+o �� d , � ALTERNATIVE i^---!-----•�� �-r-i rf�1•t••r•r•iY r r r r r r r r r r r It!•■�■■ � �e+ ♦ � p�,���',.�•'T"..,.ti. } IE ! <°�i ! /��� .3 � i' 1� !� Iwr =i' °'o Jrt�w,�`li Tam.... �� i1 N � � ��� ��.w,•__6,� e I .thflc7 •.�" � )-T � _P��C"�"� �s'. T�-S,. 'E y r� BIB POSEIDON RESOURCES CORP. �'! `! ;Rp� N, SEA WATER DESALINATION PLANT y �'�,i ✓; iticww a t.oks \ "' sn ! _ `� �\4kw 7t i/"^ '.G•.. w� ~Caij. •ji h ♦ 1 OC• `\ `w'�'dt' a s `.. y 2'�1 � I t Y r w..-"' �' •``,, *rr�`i '• 7, x , AES HUNTINGTON BEACH '`°fi ��� `c + ` y w ►c a - Ind 7 I.� {9 r ]( 1 va � ''al� ,.e�o s `JP f� •litI : I gaj `� _ GENERATION FACILITY I° 1 A jI C'bH �,... �l.•,- - .mom f.. ,P_ .yA�, !; II�� 'P�•I�� ■, ue r 4N`Sri: I + Source:Carollo Engineers,August 2005. NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH e e . Conceptual Pipeline Alignments r-ONSULTING 08105•JN 10-101409.002 Exhibit 3-3 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 3.0 ERRATA ' Page 3-37, The Project Provides a Drought-Proof Water Supply "California has not experienced the hardships and environmental pressures of a prolonged drought since the early 1990s.but experts agree that Similar er worse Ge RditiGRS of YRFeliahlo water supplies Gan and would . However, it is recognized that Southern California, being in a semi-arid region, periodically experiences droughts that could be prolonged. During long or extreme droughts, water supplies are less reliable reduced, groundwater levels decline and conflicts increase among water users. Business is also adversely affected, jeopardizing the economy and ecosystems are strained..." Page 3-37, The Project Provides a Drought-Proof Water Supply "Other Recent changes (primarily improvements in infrastructure) would should make it easier to ' respond to future drought conditions. Completion of the Coastal Aqueduct (DWR), the Morongo basin pipelines (Mojave Water Agency), Diamond Valley Lake (MWD), Los ' Vaqueros Reservoir (Contra Costa Water District), and five large-scale groundwater recharge/storage projects should add flexibility in operating California's water system. "The Draft 2004 California Water Plan Update 2005 recognizes that one of the potential benefits 1 that seawater desalination can provide is "increased water supply reliability during drought periods." (DFaft California Water PI Public Review Draft of the California Water Plan Update 2005, Volume 2, Resources Management Strategies, Desalination, page 3.) "The primary benefit of desalting is to increase California's water supply. Seawater desalting creates a new water supply by tapping the significant supply of feedwater from the Pacific Ocean" (page 3). Because the supply available from the Pacific Ocean is not affected by drought conditions, the Seawater Desalination Project at Huntington Beach would add even more flexibility in operating California's water system, and would provide particular drought pretec-t+et--relief in Orange County." ' Page 3-38, NEED FOR THE PROJECT "...Huntington Beach would add even more flexibility in operating California's water system, and would provide particular drought protection in Orange County. B. The Proiect Provides -a Water Supply to Ensure Reliability to Handle ' UncertaintiesWateF Supply Although Orange County has made a significant financial investment in the regional imported ' water system (through ongoing sentr+bUt+eaS-water purchases tefrom MWD), and the system has historically met all of Orange County's water supply needs..." Page 3-38, The California Water Plan, Footnote 2 "In 1957, the Department of Water Resources published Bulletin 3, the California Water Plan. ' Bulletin 3 was followed by the Bulletin 160 series. The Bulletin 160 series was published six times between 1966 and 1993, updating the California Water Plan. A 1991 amendment to the California Water Code directed the Department to update the plan every five years. Bulletin 160- 98 (the 1998 Plan) is the latest adopted plan in the series. In April 2005, after this Draft EIR ' went to print, DWR released the public review draft of the latest California Water Plan - Update 2005. However, the 2004 WateF PlaR Update has beeR available iR draft fGFM feF severa-I Menths:The 28�^�I�Update 2005 will not be adopted until Fall 2005. This EIR presents information provided in both the 1998 Plan and the public review draft of Update 2005." City of Huntington Beach August 17, 2005 347 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 3.0 ERRATA Page 3-38 The California Water Plan "...Senate Bills (SB) 221 and 610, which became effective January 1, 2003, require demonstration of water supply reliability prior to development. In the 2004--P anUpdate 2005, DWR and water industry stakeholders wanted a more comprehensive analysis that included economics, water quality, and environmental and social considerations rather than focusing on the water budgets presented in Bulletin 160-98. As explained by DWR, this goal was not realized. "The analytical work could not be completed for use iR this [ 20045] water plan update. Without this analysis, aUpdate 20045 lacks the information to make the types of regional-specific water budget comparisons afforded by Bulletin 160-98. However, eUpdate 20045 provides qualitative discussions and presents the analytical approach for use in aUpdate 200810 and beyond. If the past is any indication, we expect the analytical approach to continue to evolve long after Update 200810 is completed." (Draft-Update 20045 'lall, Volume 1, Chapter 34, Box 3 xx4=3, "Evolving Analytical Approach" page 4-33).3 Page 3-38, The California Water Plan, Footnote 3 - "The California Water Plan, Update 2005, Volume I —The Strategic Plan, Chapter 34, Planning for an Uncertain Future, tntemal Public Review Draft, dune-24April, 20054." Page 3-39,The California Water Plan "The dFaftrUUpdate 20045 Plan-extended the planning period to 2030, and includes an estimated population increase of 14 million people, from about 34 million to 48 million. (Volume 1, Chapter 23, page 23-3, fn 2.) The draft- Update 20045 Plan also employs "a new analytical approach to be Fefilled ovei: the ne..'. ears and te be used OR prepaFatiGR of Galifernia Water Plan Update 2008. The majOF Ghange in this aRalytiGal appmaGh fFem past water plan updates is th for multiple plau&ible-future base conditions (scenarios) rather than, a SiRgle p Feje •ted f ,t,,ro." (Volume 1, chapter 34, Box 4-3, page 4-4-33.) DWR considered numerous factors that could vary in the future and developed three future scenarios (that would be used to begin the analysis for water plan eUpdate 200910). • Scenario 1—Current Trends: GGRtinwe based on recent ^��rcv„e;t—trends continue for population growth, agricultural and industrial production and water conservationwith-ne bin s uprises vr�-�vrPr'"��' . • Scenario 2—Less Resource S ' y Intensive: recent trends continue for population growth, agricultural and industrial production, with more environmental water dedication and more naturally occurring water conservation. • Scenario 3—More Resource Intensive: Galifemia is highly predLlGtive, FespeGtful of the virrnmont vet loss effi Gie Rt in 2030 water use than t.,da- higher population growth, agricultural and industrial production, with no additional environmental water dedication and less naturally occurring water conservation. The three scenarios are listed in the-dr-a#f-U date 20045 P4aa Volume 1 Chapter 34 Pages City of Huntington Beach - August 17, 2005 348 ' Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 3.0 ERRATA ' 444-9 and 10.) While the analysis is not yet completed, numerous "Resource Management Strategies" have been identified in the draft-Update 20045 Rae-to address the three scenarios. One of those strategies is seawater desalination. The 1998 Plan recognized that "seawater desalting is sometimes described as the ultimate solution to Southern California's water supply shortfall" (Bulletin 160-98, page 7-70), but failed to provide any projections regarding the estimated future water supply to be provided by seawater desalination projects. The draft- Update 20045 Plan-surveyed "the number and capacity of seawater desalting plants in operation and in design and construction as of 2002 and plants that ' are currently planned or projected for construction" (Vol. 2, Resource Management Strategies, Chapter 6, Desalination, page 6-3). According to Update the d-afr20054 Plan, the following table (Table 3-2, DESALTING IN CALIFORNIA FOR NEW WATER SUPPLY) includes "the ' plants proposed in response to the MWD solicitation (see below) and plants in Huntington Beach, the Monterey Bay area and Marin County. ' As referenced in the above table, DWR projects that a combination of six new seawater desalination facilities would provide up to 187,100 acre-feet of California's urban water supply by 2030. The same number (FOURded te 200,000 aGre feet) is listed as the target ameuRt tG be ' predUGed by seawateF _dDesalination; is one of the "Resource Management Strategies" � featured in the draft-Update 20045 Water � c Strategy Summary Table." (Draft Update 20045-Plan, Volume 42, Chapter 1, Table 1-1, page 1-4 _) ' Page 3-40, Table 3-2, change to table title ' Table 3-2 (from DFaft 2804California Water Plan, Update 2005, Volume 2, Ch. 6, p. 6-3) DESALTING IN CALIFORNIA FOR NEW WATER SUPPLY" ' Page 3-40, Southern California's Integrated Water Resources Plan - "The 2003 IRP Update (approved by MWD in July 2004) refined the resource development ' targets based on changed conditions and updated the resource targets through 2025 (see Table 3-3, UPDATED RESOURCE TARGETS [WITH SUPPLY BUFFER]). The 2003 IRP Update continued to confirm..."' ' Page 3-44, The Project Provides a New Source to Protect Against Seawater Intrusion "The 72,000 aGFe feet weuld esseRtially effset the 60,000 aGFe feet ef irnpGi4ed water PUFGhased aGre feet, GOUld a11GW fGF a Slight ORGrease iR available gFOURdwateF supply. The 72,000 acre- feet together with up to 60,000 acre-feet or more that could be purchased from MWD each year ' by OCWD and the normal year recharge of 290,000 acre-feet could allow for an increase in available groundwater supply._ However, the coastal pumping depression problem..." ' Page 5.1-10, RELEVANT PLANNING "...As such, the proposed desalination facility's ocean discharge will require separate review ' and approval by the California Coastal Commission of a Coastal Development Permit. ' Due to the redundancy of this term (2003 IRP Update), the reader should assume that all changes have been made throughout the EIR. City of Huntington Beach August 17, 2005 349 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 3.0 ERRATA SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS (SCAG) REGIONAL COMPREHENSIVE PLAN AND GUIDE "Growth Management Chapter ❖ _ 3.03: The timing, financing, and location of public facilities, utility systems, and transportation systems shall be used by SCAG to implement the region's growth policies. ❖ 3.18: Encourage planned development in locations least likely to cause adverse environmental impacts. 3.20: Support the protection of vital resources such as wetlands, groundwater recharge areas, woodlands, production lands, and land containing unique and L endangered plants and animals. ❖ 3.21: Encourage the implementation of measures aimed at the preservation and protection of recorded and unrecorded cultural resources and archaeological sites. ❖ 3.22: Discourage development, or encourage the use of special design requirements, in areas with steep slopes, high fire, flood, and seismic hazards. 3.23: Encourage mitigation measures that reduce noise in certain locations, measures aimed at preservation of biological and ecological resources, measures that would reduce exposure to seismic hazards, minimize earthquake damage, and to develop emergency response and recovery plans. Air Quality Chapter L ❖ 5.11: Through the environmental document review process, ensure that plans at all levels of government (regional, air basin, county, subregional, and local) consider air quality, land use, transportation, and economic relationships to ensure consistency and minimize conflicts. Open Space Chapter ❖ 9.08: Develop well-managed viable ecosystems or known habitats of rare, threatened and endangered species, including wetlands. Water Quality Chapter ❖ 11.07: Encourage water reclamation throughout the region where it is cost- (" effective feasible, and appropriate to reduce reliance on imported water and L wastewater discharges. Current administrative impediments to increased use of wastewater should be addressed. (' Growth Visioning/Compass L • Principle 3: Enable prosperity for all people o Provide, in each community, a variety of housing types to meet the housing needs of all income levels. o Support the educational opportunities that promote balanced growth. o Ensure environmental justice regardless of race, ethnicity or income class. City of Huntington Beach August 17, 2005 350 i ' Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 3.0 ERRATA o Support local and state fiscal policies that encourage balanced growth o Encourage civic engagement. ' ❖ Principle 4: Promote sustainability for future generations o Preserve rural, agricultural, recreational and environmentally sensitive areas. o Focus development in urban centers and existing cities. ' o Develop strategies to accommodate growth that sues resources efficiently, eliminate pollution and significantly reduce waste. o Utilize "green" development techniques" ' Page 5.3-6, Flooding ' The proposed project is currently designated with a Federal Emergency Management Agency (FEMA) flood zone designation of "X". However, the City's.Local Coastal Program designates the project site as being situated wit located adiacent to an area prone to "Flooding with Wave Action". in additien-Although the open/space wetland area to the southeast of the subject site routinely stores runoff, resulting in high water levels during storm events, recent improvements to the Huntington Beach Channel (performed by the Orange County Flood ' Control District) have minimized the which-eeY1d potentially for impacts to the site." Page 5.6-4, Water ' "Facilities within the City of Huntington Beach consist of 480 miles of water lines (ranging from 2-inch to 42-inch in diameter), water booster pumps, and fivefour reservoirs with a combined capacity of 55 million gallons." Page 5.8-8, Product Water Treatment Materials "In the event of an accidental liquid chemical spill, the chemical would be contained within the concrete containment structure and evacuated through an individual drainage system. The spilled chemical would then be pumped into hazardous waste containment trucks and ' transported off-site for disposal at an appropriate facility accepting such waste. This operation would be completed by a specialized contractor licensed in hazardous waste handling and disposal. Spill notification thresholds would be established and published and appropriate ' agencies, such as the City of Huntington Beach Fire and Police Departments, would also be contacted if necessary. It should also be noted that the existing containment berms along the northern and eastern boundaries of the proposed desalination site would further minimize the potential release of hazardous materials into the adjacent Huntington Beach Channel and ' wetlands." Page 5.8-9, Product Water Treatment Materials r .'Hazardous waste management transportation use storage and disposal information and procedures would be processed and approved through the Huntington Beach Fire Department ' Hazardous Materials Division and other applicable regulatory agencies The desalination facility operator would develop hazardous waste management and safety plans in accordance with City, Occupational Health and Safety Association (OSHA), and United States Environmental ' Protection Agency (EPA) requirements. In accordance with OSHA regulation 29 CFR 1910.119, operation of the proposed facility would require..." Page 5.8-10, OC-44 Pump Station ' "...electrical generators would be required for underground g q g pump station implementation. City of Huntington Beach August 17, 2005 351 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 3.0 ERRATA Diesel fuel would be stored within an 8,700-gallon double walled tank with a diameter of eight feet and a height of 26 feet. The city of Irvi a Ciro rlep@FtmeRt Orange County Fire Authority (which provides service to the OC-44 pump station site) has no preference for either an aboveground or underground storage tank." Page 5.9-23, HAZARDS AND HAZARDOUS MATERIALS "...adverse impacts with regards to hazardous materials. Remediation activities could expose on-site workers, future project employees, and the adjacent community to a variety of potentially hazardous materials. However, site remediation activities are strictly controlled by local, state, (� and federal requirements (such as the Orange County Health Care Agency, Regional Water I L Quality Control Board, and City of Huntington Beach, among others), and the majority of contamination in the vicinity of the proposed desalination project site is petroleum-based (which is not considered "toxic" or acutely hazardous). In addition, contaminated soils may be encountered along the proposed pipeline alignment (especially in the vicinity of the proposed desalination facility) as well as on the proposed pump station site. Therefore, compliance with the required mitigation measures (including a Remedial Action Plan subject to regulatory agency approval prior to project implementation for contaminated areas) is expected to reduce potential impacts to less than significant levels. Note that the project (both desalination facility construction and pipeline construction) would also require adherence to the City of Huntington Beach's Soils Clean-Up Standard (City Specification 431-92)." Page 5.9-32, CON-21 and CON-25 "CON-21 If any hazardous materials not previously addressed in the mitigation measures contained herein are identified and/or released to the environment at any point during the site cleanup process, operations in that area shall cease immediately. At the earliest possible time, the contractor shall notify the City of Huntington Beach Fire Department of any such findings. Upon notification of the appropriate agencies, a course of action would be determined subject to the approval of the by the City of Huntington Beach Department of Public Works and Fire Department. CON-25 Any unrecorded or unknown wells uncovered during the excavation or grading process shall be immediately reported to and coordinated with the City of Huntington Beach Fire Department and State Division of Oil, Gas, and Geothermal Resources (DOGGR), and shall meet City Specification 422 — Oil Well Abandonment Permit Process." Page 5.9-33, CON-29 "CON-29 Methane migration features would be consistent with the requirements of the City of Huntington Beach Specification Number 429 and other applicable state and federal regulations. The methane migration features shall be submitted for review and approval to the Orange County Health Care Agency (OCHCA), Environmental Health Division and the City of Huntington Beach Fire Department." Page 7-7 Alternative Locations Outside of the City of Huntington Beach "Several other locations outside of the City of Huntington Beach have also been considered for F this project, including the mouth of San Juan Creek (within the City of Dana Point), San Onofre IL (within San Diego County),and along the coast of the City of San Clemente (refer to Exhibit 7-1, City of Huntington Beach --August 17, 2005 352 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 3.0 ERRATA ' ALTERNATIVE SITE LOCATION MAP, and Table 7-3, ALTERNATIVE SITE COMPARISON). These alternatives are not being considered for a variety of reasons, such as the 56,000 afy ' size of the proposed project-(San Juan Creek), environmental concerns of a new ocean intake/discharge system (San Clemente) and/or engineering/acquisition issues (San Onofre)." ' Page 7-8, Ocean Water Quality and Marine Life "...impacts are anticipated to be similar to those of the proposed project site within the City of Huntington Beach. MT .Depending on the alternative site selected, impacts in regards to ocean water quality and marine life may be greater than those of the_proposed project site. If implementation of the proposed project on an alternative site ' requires the construction of new or modified intake and outfall facilities for plant operation (as is the case with the San Clemente or San Juan Creek alternative site), substantial impacts to marine biological resources would occur, as construction and operation of plant facilities may disrupt sensitive marine habitats. If the desalination facility were to utilize existing intake and ' outfall facilities (as is the case with the San Onofre alternative site), impacts to be similar to those of the proposed project site within the City of Huntington Beach." ' Page 7-10,Table 7-3, change to table title Table 7-3 ' ALTERNATIVE SITE COMPARISON Project yield: 56,000 acre-feet per year ' Page 7-10, Alternative Locations Outside of the City of Huntington Beach "While source water (i.e. ocean water) quality may vary by site, the reverse osmosis treatment ' process would most likely be capable of producing water meeting all Department of Health Services (DHS) requirements. Impacts due to product water compatibility are anticipated to be similar to the proposed project. It should be noted that at San Juan Creek, system and supply reliability would improve in South Orange County." ' Page 7-11, "ALTERNATIVE OWNERSHIP" ALTERNATIVE ' "... the California Department of Water Resources has come to the opposite conclusion. "No international trade treaty now in effect or being negotiated by the United States wetld-prevents local, state, or federal government agencies from ' reviewing and regulating water projects that involve private companies with multinational ties. Such projects include desalination plants, water transfers, water storage projects (het -above and below ground), and wastewater ' reclamation projects. There is no conflict with international trade treaties Sso long as government regulations are applied On the sarne maRRer to water projects involving multinational corporations in the same manneras they are applied to water projects owned or operated by domestic-companies or public utilities, theFe weyid be Re GE)Rfl4Gt With inteMatleRcll trade " (2004-California Water Plan, Update 2005, Volume 1, Chapter 23, page 263-37.) ' - City of Huntington Beach August 17, 2005 353 Seawater Desalination Project at Huntington Beach RESPONSES TO COMMENTS Recirculated Environmental Impact Report 3.0 ERRATA It should be noted that the project proponent, Poseidon Resources Corporation, is a U.S. corporation based in Connecticut, and is not a multi-national corporation." Page 8-3, HYDROLOGY AND WATER QUALITY "...recharge since the project does not involve the extraction of groundwater from the site. Groundwater wells supply 7 0 66% of the City of Huntington Beach's water. The proposed project would consume a nominal amount of water..." City of Huntington Beach August 17, 2005 354 CITY OF HUNTINGTON BEACH 2000 MAIN STREET CALIFORNIA 92648 OFFICE OF THE CITY CLERK JOAN L. FLYNN CITY CLERK September 19, 2005 Poseidon Resources Corporation 3760 Kilroy Airport Way, #260 Long Beach, CA 90806 ATTN: Josie McKinley Re: NOTICE OF ACTION — Recirculated Environmental Impact Report (REIR) No. 00-02 for Seawater Desalination Project. Dear Ms. McKinley: The City Council of the City of Huntington Beach at its regular meeting held Tuesday, September 6, 2005 took action on the following Public Hearing: Certify Recirculated Environmental Impact Report(REIR) No. 00-02 for Seawater Desalination Project (Poseidon) Council certified Recirculated Environmental Impact Report (REIR) No. 00-02. Enclosed are the action agenda pages 9 through 16 and a fully executed copy of Resolution Number 2005-62 for your records. If you have any questions regarding this matter, please contact my office at (714) 536-5227. Sincerely, Joan L.Ff �n Y ji"). City Clerk Enclosure: Action Agenda Pages 9-16 cc: Howard Zelefsky, Planning Director M. Broeren, Planning R. Ramos, Planning (Telephone:714-536-5227) PROOF OF SERVICE OF PAPERS STATE OF CALIFORNIA ) ) ss. COUNTY OF ORANGE ) I am employed in the County of Orange, State of California. I am over the age of 18 and not a party to the within action; my business address is 2000 Main Street, Huntington Beach, CA 92648. Pursuant to Code of Civil Procedure § 1094.6, on September 19, 2005, 1 served the foregoing documents(s) described as: NOTICE OF FINAL ACTION on the interested parties in this action by placing a true copy thereof in a sealed envelope addressed as follows: Poseidon Resources Corporation 3760 Kilroy Airport Way#260 Long Beach, CA 90806-2455 Attn: Josie McKinley a. [X] BY MAIL --.1 caused such envelope to be deposited in the mail at Huntington Beach, California. I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. It is deposited with U.S. Postal Service on that same day 'in the ordinary course of business, with postage thereon fully prepaid. I am aware that, on motion of a party served, service is presumed invalid if postal cancellation date or postage meter date is more than 1 day after date of deposit for mailing in the affidavit. b. [ ] BY MAIL -- By depositing a true copy thereof in a sealed envelope with postage thereon fully prepaid in the United States mail at Huntington Beach, California, addressed to the address shown above. c. [ ] BY DELIVERY BY HAND to the office of the addressee. d. [ ] BY PERSONAL DELIVERY to the person(s) named above. e. [ ] BY FAX TRANSMISSION to No. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on September 19, 2005, at Huntington Beach, California. [Nep City C rk g1followup/appeal/!!proof of service letter!!.doc PUBLIC NOTICE CITY OF HUNTINGTON BEACH DEPARTMENT OF PLANNING NOTICE OF RECIRCULATION FOR DRAFT ENVIRONMENTAL IMPACT REPORT NO. 00-02 FOR THE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH Draft Recirculated Environmental Impact Report No. 00-02 for the Seawater Desalination Project at Huntington Beach The City of Huntington Beach has prepared a Draft Recirculated Environmental Impact Report(EIR) No. 00-02 (State Clearinghouse # 2001051092) for the proposed Seawater Desalination Project at Huntington Beach. The EIR includes an analysis of potential environmental impacts associated with construction and implementation of the project. An unavoidable significant impact has been identified in regards to construction-related air quality. In accordance with California Environmental Quality Act (CEQA) Section 15088.5 (Recirculation of an EIR Prior to Certification),the EIR for the Seawater Desalination Project at Huntington Beach is being recirculated for public review due to the addition of significant new information intended to address concerns expressed during review of the originally circulated EIR. No impact conclusions have changed as part of the Recirculated EIR, although a substantial amount of information has been added throughout the document to clarify and further support the conclusions provided. The EIR will be available for public review and comment for 45 days, commencing Tuesday April 5, 2005 and ending Thursday May 19, 2005. Although already part of the administrative record, previous comments on the originally circulated draft EIR do not require a written response in the final EIR. As such, if you wish to comment on the Recirculated EIR, a new comment letter must be provided. Written comments on the EIR must be submitted to Ricky Ramos, City of Huntington Beach Planning Department, 2000 Main Street, Huntington Beach, California 92648 and must be received no later than 5:00 p.m., Thursday May 19, 2005, in order to be considered prior to the City's final determination on the project. The Recirculated EIR is on file at the following locations: City of Huntington Beach Department of Planning,2000 Main Street, Huntington Beach; Central Library,7111 Talbert Avenue, Huntington Beach; and Banning Branch Library, 9281 Banning Avenue, Huntington Beach. In addition, the Recirculated EIR may be reviewed electronically on the City's website at: www.ci.huntington- beach.ca.us/_government/departments/plannin_q/malor protects Project Description: The project, proposed by Poseidon Resources Corporation, consists of the construction and operation of a 50 million gallon per day seawater desalination facility within the City of Huntington Beach. The facility would consist of seawater intake pretreatment facilities, a seawater desalination plant utilizing reverse osmosis technology, product water storage, two pump stations, materials storage tanks, and 42 to 48-inch diameter product water transmission pipeline possibly up to 10 miles in length in Huntington Beach and Costa Mesa. The facility would utilize existing AES Huntington Beach Generating Station (HBGS) seawater intake and outfall pipelines for its operations. The proposed desalination facility is located on an 11-acre portion of the 22-acre HBGS facility located at 21730 Newland Street, off Pacific Coast Highway. The project includes construction of an underground pump station in a portion of unincorporated Orange County, south of Bonita Canyon Drive, near the eastern border of the City of Newport Beach. A second pump station is proposed in a church parking lot located at 4949 Alton Parkway within the City of Irvine. At this time, no date has been set for a public hearing on the project. For further information, please contact Ricky Ramos at 714-536-5624. N IR O�N"MEN A I�I\/I �C� �R E� RTARNfr ' £a „�n'M r ,✓ SP ° ., .fir .','"v +. ary �„ytn, t'ry ,..a: ' a:, ,-:'x t r"-9D .. a w '`"tea 1 x r � k Ha il",Ig { ` " ' ' .?"'^., z'" r vz- Leac�!Agency T C�tyoHuntin¢¢ton'Beach � ' COI�SU�tallf s _� rt � � v �z 't,'�.f4.•x,t.- n DRAFT RECIRCULATED ENVIRONMENTAL IMPACT REPORT # 2001051092 SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH Lead Agency: CITY OF HUNTINGTON BEACH *; 2000 Main Street Huntington Beach, CA 92648 Contact. Mr. Ricky Ramos, Associate Planner (714) 536-5271 Consultant: RBF CONSULTING 3536 Concours, Suite 220 Ontario, CA 91764 Contact: Mr. Kevin Thomas, Environmental Services Manager `�. (909) 941-5204 April 5, 2005 �' JN 10-101409.002 Seawater Desalination Project at Huntington Beach TABLE OF CONTENTS Draft Recirculated Environmental Impact Report TABLE OF CONTENTS page 1.0 EXECUTIVE SUMMARY................................................................................................. 1-1 2.0 INTRODUCTION AND PURPOSE 2.1 Purpose of EIR............................................................... ......2-1 ................................ 2.2 Compliance with CEQA.......................................................................................2-1 2.3 Scope of EIR........................................................................................................2-3 2.4 Public Scoping Process.......................................................................................2-3 2.5 EIR Organization..................................................................................................2-7 2.6 Use of the EIR......................................................................................................2-7 2.7 Incorporation By Reference.................................................................................2-8 �( 2.8 Technical References........................................................................................2-10 3.0 PROJECT DESCRIPTION 3.1 Project Location ...................................................................................................3-1 3.2 Environmental Setting..........................................................................................3-1 3.3 Project Characteristics.........................................................................................3-2 3.4 Project Need and Objectives.............................................................................3-36 3.5 Project Phasing..................................................................................................3-45 3.6 Agreements, Permits and Approvals Required .................................................3-46 4.0 EXISTING CONDITIONS/ENVIRONMENTAL SETTING �j 4.1 Project Site......................... ................................4-1 .................................................. 4.2 Pipeline Route......................................................................................................4-9 4.3 Underground Booster Pump Stations................................................................4-10 ' 4.4 Local Marine Species and Communities Occurring in the Waters at Huntington Beach .........4-10 ................................................................................. 4.5 Huntington Beach Surf Zone Studies................................................................4-12 4.6 Ocean Water Quality at the HBGS Intake 4.7 Ocean Water Quality at the Desalination Facility Intake...................................4-21 4.8 Orange County Water Supply and Distribution System ....................................4-21 5.0 ENVIRONMENTAL ANALYSIS 5.0 Overview of EIR Methodology and Significance Determination.......................5.0-1 5.1 Land Use/Relevant Planning ............................................................................5.1-1 5.2 Geology, Soils, and Seismicity..........................................................................5.2-1 5.3 Hydrology, Drainage, and Storm Water Runoff................................................5.3-1 5.4 Air Quality..........................................................................................................5.4-1 5.5 Noise.................................................................................................................5.5-1 5.6 Public Services and Utilities..............................................................................5.6-1 5.7 Aesthetics/Light & Glare ...................................................................................5.7-1 5.8 Hazards and Hazardous Materials ...................................................................5.8-1 5.9 Construction Related Impacts...........................................................................5.9-1 5.10 Ocean Water Quality and Marine Biological Resources................................5.10-1 5.11 Product Water Quality.....................................................................................5.11-1 r1 City of Huntington Beach April 5, 2005 i Seawater Desalination Project at Huntington Beach TABLE OF CONTENTS �r Draft Recirculated Environmental Impact Report 1 6.0 LONG-TERM IMPLICATIONS OF THE PROPOSED PROJECT n 6.1 Significant Irreversible Environmental Changes 6.2 Growth-Inducing Impacts of the Proposed Action...............................................6-2 6.3 Cumulative Impacts ...........................................................................................6-13 7.0 ALTERNATIVES TO THE PROPOSED ACTION........................................................... 7-1 8.0 EFFECTS FOUND NOT TO BE SIGNIFICANT..............................................................8-1 9.0 ORGANIZATIONS AND PERSONS CONSULTED........................................................9-1 10.0 BIBLIOGRAPHY............................................................................................................ 10-1 11.0 APPENDICES (provided under separate cover) A. Noise Data l B. Air Quality Data �r , C. Hydrodynamic Modeling Report D. Pressure Surge Analysis E. Watershed Sanitary Survey , F. Marine Biological Analysis ! G. Preliminary Pipeline Assessment H. Geological Report- Desalination Site I. Geological Report-Aboveground Product Water Storage Tank J. Correspondence K. RO Membrane Cleaning Solution Discharge Test Stream Data L. Underground Booster Pump Station Biological Constraints Survey M. Underground Booster Pump Station Cultural Resources Assessment Reports r N. Disinfection Byproduct Formation Study O. Distribution System Corrosion Control Study P. Growth Assessment and General Plan Evaluation Q. Report on Local and Regional Power Requirements and Generation Resources R. Local Alternative Site Investigation S. Marine Biological Considerations T. Intake Effects Assessment U. Receiving Water Chemistry and Quality Report V. Preliminary Seismic Assessment r W. Supplemental Report on the Effects of a Retrofitted Diffuser on the Discharge Outfall for the Proposed Seawater Desalination Project at Huntington Beach X. Desalination Facilities Located Throughout the World 1 -r n i , 1 City of Huntington Beach April 5,2005 n, ii Seawater Desalination Project at Huntington Beach TABLE OF CONTENTS Draft Recirculated Environmental Impact Report LIST OF EXHIBITS 3-1 Regional Vicinity Map.......................................................................................................3-3 3-2 Site Vicinity Map...............................................................................................................3-4 3-3 Conceptual Pipeline Alignments......................................................................................3-5 3-4 OC-44 Booster Pump Station Location Map .........................3-6 3-5 Coastal Junction Booster Pump Station Location Map...................................................3-7 3-6 Conceptual Site Plan .....................................................................................................3-10 3-7 Administration Building Plan/Exterior Elevations...........................................................3-11 3-8 Reverse Osmosis Building Plan/Exterior Elevations.....................................................3-12 3-9 Pretreatment Filter Structure Plan/Exterior Elevations..................................................3-13 1� 3-10 Solids Handling Building Plan/Exterior Elevations ........................................................3-14 3-11 Chemical Storage Structure Plan/Exterior Elevations...................................................3-15 r 3-12 Electrical Room/Substation Building Plan/Exterior Elevations......................................3-16 3-13 Storage Tank Plan/Exterior Elevations..........................................................................3-17 3-14 Carbon Dioxide Tank Plan/Exterior Elevations ...................... 3-18 ....................................... 3-15 Product Water Storage Tank Plan/Exterior Elevations .................................................3-19 3-16 Conceptual Landscape Masterplan...............................................................................3-22 3-17 Desalination Facility/HBGS Cooling Water Connection................................................3-23 3-18 Desalination Treatment Process Flow Schematic.........................................................3-24 3-19 Approximate Desalinated Water Distribution Area........................................................3-33 4-1 HBGS Intake and Outfall Location Map...........................................................................4-5 4-2 Imported Water Transmission System in Orange County.............................................4-24 5.1-1 Zoning ...........................................................................................................................5.1-5 5.1-2 Land Use Designations.................................................................................................5.1-6 5.2-1 Regional Geology and Seismicity.................................................................................5.2-5 5.5-1 Sound Levels and Human Response...........................................................................5.5-3 5.7-1 Desalination Facility Site Photographs 5.7-3 5.7-2 Pipeline Alignment Photographs...................................................................................5.7-4 5.7-3 Booster Pump Station Site Photographs......................................................................5.7-5 City of Huntington Beach April 5, 2005 iii Seawater Desalination Project at Huntington Beach TABLE OF CONTENTS 1 7 Draft Recirculated Environmental Impact Report = n 5.7-4 Desalination Facility Visual Simulation — Magnolia Street.........................................5.7-8 5.7-5 Desalination Facility Visual Simulation —Newland Street.........................................5.7-9 �1 5.10-1 Location Map of Local Surface and Wastewater Discharges.................................5.10-3 5.10-2 Projected Mid-Depth Salinity Over the HBGS Outfall - "Low Flow" Scenario .......5.10-30 7� 5.10-3 Projected Seafloor Salinity at the HBGS Outfall -"Low Flow Scenario ...............5.10-31 i 5.10-4 Projected Mid-Depth Salinity Over the HBGS Outfall -"Average Flow" Scenario 5.10-32 j 5.10-5 Projected Seafloor Salinity at the HBGS Outfall -"Average Flow" Scenario ........5.10-33 5.10-6 HBGS Intake Screening Process ..........................................................................5.10-38 6-1 Infill Percentages by Regional Statistical Areas.........................................................6-11 7-1 Alternative Site Location Map f-i i � ,S i r, �l r-, r, City of Huntington Beach April 5, 2005 iv Seawater Desalination Project at Huntington Beach TABLE OF CONTENTS Draft Recirculated Environmental Impact Report LIST OF FIGURES 3-1 Orange County Water Supply Sources.....................................................................3-43 4-1 Southern California Bight..........................................................................................4-11 4-2 Geometric Means for Fecal Indicator Bacteria at Huntington State Beach..............4-14 4-3 Total Coliforms at HBGS, Summer 2001 ..................................................................4-18 4-4 Total Coliforms at HBGS, Summer 2002..................................................................4-19 5.10-1 Interannual Variation in Huntington Beach Infaunal Abundance and Species Richness, 1975-1993 .............................................................................................5.10-9 r 5.10-2 Interannual Variation in Huntington Beach Macrofauna Abundance and Species Richness, 1975-2001 .............................................................................5.10-11 7-1 Horizontal (Ranney) Beach Well...............................................................................7-13 �( 7-2 Horizontal (Ranney) Beach Well Photo ....................................................................7-14 7-3 Horizontal (Ranney) Beach Well System Illustration ................................................7-15 7-4 Conceptual Horizontal (Ranney)Well Intake Configuration at Huntington Beach...7-15 7-5 Infiltration Gallery.......................................................................................................7-16 7-6 Seabed Infiltration System ........................................................................................7-18 7-7 Seabed Infiltration System Cross-Section.................................................................7-18 7-8 Seabed Infiltration System Approximate Impact Area ..............................................7-19 City of Huntington Beach April 5, 2005 v 117 Seawater Desalination Project at Huntington Beach TABLE OF CONTENTS Draft Recirculated Environmental Impact Report V_J LIST OF TABLES �l 3-1 Desalinated Water Quality- Key Parameters............................................................3-32 3-2 Desalting in California for New Water Supply ............................................................3-40 n i 3-3 Updated Resource Targets (with Supply Buffer)........................................................3-41 3-4 Projected Orange County Water Demand Through 2020..........................................3-42 4-1 Rated Capacity Flow Rate at HBGS.............................................................................4-6 4-2 State Standards for Beach Postings...........................................................................4-13 4-3 Beach Postings in Huntington Beach from April to October.......................................4-13 4-4 OCSD Treatment Facility Operational Goals..............................................................4-17 5.4-1 National and California Ambient Air Quality Standards.............................................5.4-4 5.4-2 SCAQMD Rules and Regulations..............................................................................5.4-6 5.4-3 South Coast Air Basin Ambient Air Quality Classifications .......................................5.4-7 5.4-4 Local Air Quality Levels..............................................................................................5.4-8 5.4-5 SCAQMD Emissions Thresholds.............................................................................5.4-12 5.4-6 Mobile Source Emissions.........................................................................................5.4-13 5.5-1 California Land Use Compatibility Noise Guidelines.................................................5.5-4 f 5.5-2 City of Huntington Beach Noise Ordinance Exterior Noise Standards .....................5.5-6 5.5-3 City of Huntington Beach Noise Ordinance Interior Noise Standards.......................5.5-6 5.5-4 Existing On-Site and Surrounding Ambient Noise Levels.........................................5.5-8 5.5-5 Existing Off-Site Pipeline/Pump Station Ambient Noise Levels................................5.5-8 5.5-6 Significance of Changes in Cumulative Noise Exposure........................................5.5-10 r 5.5-7 Predicted Pump Station Noise Levels at Three Feet 5.5-11 5.8-1 Product Water Treatment Chemical Usage Summary..............................................5.8-6 F` 5.9-1 Demolition Process Details .............................5.9-4 -........................................................... 5.9-2 Site Grading Details 5.9-5 5.9-3 Pipeline Alignment Details.........................................................................................5.9-5 '5.9-4 Pipeline Construction Details.....................................................................................5.9-6 5.9-5 OC-44 Booster Pump Station Construction Details...................................................5.9-7 r- 5.9-6 Coastal Junction Booster Pump Station Construction Details................................5.9-10 1� r City of Huntington Beach April 5, 2005 V vi Seawater Desalination Project at Huntington Beach TABLE OF CONTENTS Draft Recirculated Environmental Impact Report 5.9-7 SCAQMD Emissions Thresholds.............................................................................5.9-12 5.9-8 Construction Emissions ...........................................................................................5.9-17 5.9-9 Predicted Project Emission Rates ...........................................................................5.9-19 ` 5.9-10 Screen3 Predicted Emission Concentrations..........................................................5.9-20 5.9-11 Seawater Desalination Facility Construction Equipment Noise Levels...................5.9-21 5.9-12 Construction Noise Exemption Periods...................................................................5.9-22 5.10-1 Major Groups of Infaunal Animals at Huntington Beach, 1975-1993......................5.10-7 5.10-2 Order of Abundance of Infaunal Animals at Huntington Beach, 1975-1993...........5.10-8 5.10-3 Macrofaunal Invertebrates at Huntington Beach, 1976-2001 ...............................5.10-10 5.10-4 Yearly Abundance of Demersal Fish Species Collected By Otter Trawl at Huntington Beach, 1976-2001 ...........................................................................5.10-12 5.10-5a Comparison of HBGS Intake Well Monitoring Data to Primary Maximum ContaminantLevels...............................................................................................5.10-23 5.10-5b Comparison of HBGS Intake Well Monitoring Data to Primary Maximum ContaminantLevels...............................................................................................5.10-24 5.10-6a Comparison of HBGS Intake Well Monitoring Data to Secondary Maximum Contaminant Levels ..............................................................................5.10-25 5.10-6b Comparison of HBGS Intake Well Monitoring Data to Secondary Maximum Contaminant Levels ..............................................................................5.10-25 5.10-7 Cycle Water Discharges to the HBGS Cooling Water System .............................5.10-26 5.10-8 Reverse Osmosis Membrane Solution Discharge Volumes .................................5.10-37 5.11-1 DHS Drinking Water Notification Levels................................................................5.11-10 5.11-2 Response Levels ...................................................................................................5.11-10 5.11-3 Product Water Quality Comparison.......................................................................5.11-11 6-1 Orange County Projections: 2000-2030 .......................................................................6-6 6-2 General Plan Housing Element Summary....................................................................6-7 6-3 Proposed New Residential Development Projects in Orange County (over 500 D.U.)............................................................................................................6-10 6-4 Proposed Desalination Facilities along the Southern California Coast......................6-19 6-5 SCE 230 KV Substations Serving Load in Orange County........................................6-23 6-6 Summary of Estimated Loads (MW)...........................................................................6-23 6-7 Changes in Estimated Loads due to Addition of the Project (%)...............................6-24 7-1 Comparison of Alternatives...........................................................................................7-2 ' City of Huntington Beach April 5, 2005 vii Seawater Desalination Project at Huntington Beach TABLE OF CONTENTS Draft Recirculated Environmental Impact Report n 7-2 MWD Updated Resource Targets (With Supply Buffer)...............................................7-3 7-3 Alternative Site Comparison .......................................................................................7-10 �1 ,J r-~ r-7 i-i n i t.1 r-, City of Huntington Beach April 5, 2005 viii 1 1 1 1 1 1 1 .0 EXECUTIVE SUMMARY r t a 1 .0 EXECUTIVE SUMMARY 1.1 PROJECT SUMMARY EXISTING CONDITIONS The proposed Seawater Desalination Project at Huntington Beach site is approximately 11 acres in size and would be located adjacent to the Applied Energy Services Corporation (AES) LLC Huntington Beach Generating Station (HBGS), within the southeastern portion of the City of Huntington Beach (City)at 21730 Newland Street. In 2001,AES Huntington Beach, LLC acquired the property from Southern California Edison (SCE). The existing HBGS uses a once through cooling system with an offshore intake and outfall. The site for the proposed desalination facility is situated on an unused fuel oil storage tank area. The storage tank area contains a total of six tanks, ranging incapacity from 924,000 gallons to 8.64 million gallons. Each of these storage tanks is 40 feet high, cylindrical in shape and surrounded by 10 to 15-foot high earthen containment berms, pipelines,pumps,and associated structures. On-site vegetation consists mainly of non-native low- lying shrubs and bushes along the eastern border of the project site. The topography of the site is relatively flat, gently sloping to the southwest, with an elevation of approximately five feet above mean sea level (msl) (refer to Exhibit 5.7-1, DESALINATION FACILITY SITE PHOTOGRAPHS). Section 4.0,EXISTING CONDITIONS, provides additional information regarding existing conditions and environmental setting. In addition to the desalination facility site (refer to Exhibit 3-6, CONCEPTUAL SITE PLAN), the proposed project will include several related off-site improvements, including pipelines between the existing HBGS ocean intake/outfall lines and the proposed desalination project,up to approximately 10 miles of water delivery pipeline and two underground pump stations. The intake/discharge pipelines would be located entirely within the existing HBGS site and would not require modifications to the coastal/marine portions of the existing HBGS ocean intake/discharge facilities. The water delivery pipeline would be up to approximately 10 miles in length, extending from the proposed desalination facility to the OC-44 water transmission line within the City of Costa Mesa,east of State Route 55 (SR-55) at the intersection of Del Mar Avenue and Elden Avenue. The majority of the pipeline alignment will occur within existing public streets,easements,or other rights-of-way(ROW) in urbanized areas.Although precise pipeline alignments may be modified during final engineering analyses, the conceptual pipeline alignments are shown in Exhibit 3-3, CONCEPTUAL PIPELINE ALIGNMENTS. One of the two new off-site underground booster pump stations is proposed to be located within an unincorporated area of the County of Orange, within an existing easement. The other off-site pump station is proposed within the City of Irvine, within a church parking lot in an urbanized area (refer to Exhibit 3-4, OC-44 BOOSTER PUMP STATION LOCATION MAP and Exhibit 3-5, COASTAL JUNCTION BOOSTER PUMP STATION LOCATION MAP). PROPOSED PROJECT The proposed Seawater Desalination Project at Huntington Beach consists of the construction and operation of a 50 million gallon per day (MGD) or 56,000 acre-feet per year (afy) seawater desalination facility by Poseidon Resources Corporation that would provide a supplemental and alternative source of potable water to Orange County. The desalination facility would withdraw source water from the existing HBGS cooling system discharge pipe, purify it utilizing reverse osmosis(RO)technology,discharge concentrated seawaterwater back to the existing HBGS outfall, to blend with remaining HBGS discharge and deliver potable product water to the distribution system. City of Huntington Beach April 5, 2005 1-1 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report r-� Improvements associated with the proposed project would include seawater intake system, pretreatment facilities, the desalination facility utilizing reverse osmosis (RO) technology, post- treatment facilities, product water storage, landscaping, chemical storage, and a booster pump r station. Also, the project would require the demolition of three fuel storage tanks and the remediation of any soil/groundwater impacted by contamination associated with previous site usage as a fuel storage facility. In addition, the existing interior berms would be demolished while the existing exterior berms would remain as is. Structures on the desalination facility site would consist of an administration building, a reverse osmosis facility building, pretreatment filter structure, chemical storage/solids handling building,bulk chemical storage building,product water and influent pump stations (situated underground) and surge tank, rinse tank, lime silos, wash water tank, r, carbon dioxide tanks, ammonia tank, an electrical substation building, an aboveground product water tank, and appurtenant facilities (refer to Exhibit 3-6, CONCEPTUAL SITE PLAN). Off-site improvements include the construction of up to 10 miles of water transmission lines to connect to existing regional transmission and local water distribution systems as described above. The majority of the two pipeline alignments currently being considered are planned for existing public streets, easements,or other rights-of-way,and the alignments are not anticipated to require disturbance of native vegetation or otherwise impact sensitive resources. The proposed alignments consist of a 42- to 48-inch pressure main, and construction would utilize trenchless installation of pipeline in order to traverse waterways and/or roadways with a high sensitivity to traffic disturbance. This topic is further addressed in Section 5.9, CONSTRUCTION RELATED IMPACTS.The project would also be conditioned to complete street improvements along the southern side of Edison Avenue (situated north of the subject site). r- The off-site underground booster pump stations are needed as part of the distribution system. The first off-site underground booster pump station(the"OC-44"pump station)is proposed to be located r- within an unincorporated area of the County of Orange along the eastern border of the City of Newport Beach, approximately 1.5 miles south of the University of California, Irvine, within an Orange County Reserve Preservation Easement. The site is located adjacent to, but outside of, a r Natural Community Conservation Plan/Habitat Conservation Plan(NCCP/HCP)area,approximately '/4 mile north of the San Joaquin Reservoir,where the East Orange County Feeder Number Two and the OC-44 transmission pipelines converge(refer to Exhibit 3-4, OC-44 BOOSTER PUMP STATION LOCATION MAP). The OC-44 underground booster pump station would include pumps, a surge tank to protect the distribution system from sudden pressure changes, telemetry equipment, appurtenances, and three diesel powered electrical generators for emergency back-up purposes. This pump station would be placed entirely underground to maintain the natural character of the surrounding resource preservation easement. The second underground booster pump station (the "Coastal Junction" pump station) would be located in the parking lot at St. Paul's Greek Orthodox Church,at 4949 Alton Parkwaywithin the City of Irvine(refer to Exhibit 3-5, COASTAL JUNCTION BOOSTER PUMP STATION LOCATION MAP). The underground pump station would be constructed within the north/northwestern portion of the church parking lot, in an area used for both parking and volleyball activities. The pump station would be entirely underground except fora small pipe vent and a ground-level steel access doorfor maintenance(the access door would not impede parking after construction). This location is near the connection points of the existing regional water distribution system,Aufdenkamp Transmission Main and the Tri-Cities Transmission Main to the East Orange County Feeder Number Two. The Coastal Junction off-site underground booster pump station would include pumps, telemetry equipment, appurtenances, and one diesel powered electrical generator for emergency back-up purposes. This pump station would be placed entirely underground to maintain the appearance and functionality of the existing parking lot. City of Huntington Beach April 5, 2005 1-2 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report 1.2 ENVIRONMENTAL SUMMARY Refer to the following summary of project impacts, mitigation measures,and unavoidable significant impacts. IMPACT MITIGATION MEASURE 5.1 LAND USEIRELEVANT PLANNING LAND USE The proposed desalination facility is not anticipated to create any None required. However,refer to mitigation measures contained in impacts to surrounding uses with regards to air quality, noise, Section 5.4 (Air Quality), Section 5.5 (Noise), Section 5.7 aesthetics, hazards and hazardous materials, and short-term (Aesthetics/Light & Glare), Section 5.8 (Hazards and Hazardous construction. Significance: Less than Sign cant. Materials),and Section 5.9(Construction Related Impacts). 1 RELEVANT PLANNING The proposed Seawater Desalination Project at Huntington Beach will None required. be consistent with the City of Huntington Beach General Plan,Zoning and Subdivision Ordinance,SCAG Regional Comprehensive Plan and Guide,and Local Coastal Program,and does not propose to change any General Plan or Zoning designations. Significance:Less than Significant. 5.2 GEOLOGY,SOILS,&SEISMICITY WINDIWATER EROSION Implementation of the proposed desalination project would create Refer to Mitigation Measure HWQ-1,below. adverse impacts in regards to wind and water erosion. Significance: Less than sign cant with mitigation. TOPOGRAPHY No significant landform impacts are anticipated,as the existing project None required. area is relatively flat and contains no unique geological or physical features. Signifficance:Less than sign cant GEOLOGY/SOILS The project site's high liquefaction potential and shallow groundwater GEO-1 A detailed geotechnical report shall be prepared and conditions may create geologic hazards for the proposed desalination submitted with the building permit application for the facility. Signiricance:Less than sign cant with mitigation. proposed desalination facility. This analysis shall include on-site soil sampling and laboratory testing of materials to provide detailed recommendations regarding grading, foundations,retaining walls,streets,utilities,remedial work, overexcavation/recompaction, dewatering, water quality, and chemicallfiill properties of underground items including buried pipe and concrete and protection thereof. The reports shall specifically address lateral spreading,flood control channel bank stability, liquefaction potential and groundwater constraints. Appropriate recommendations shall be provided to mitigate potentially adverse conditions. The geotechnical report shall also be submitted to the Department of Public Works for review and approval in conjunction with the grading plan. City of Huntington Beach April 5, 2005 1-3 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report IMPACT MITIGATION MEASURE GEO-2 In conjunction with the submittal of application for a precise grading permit, the Applicant shall demonstrate to the satisfaction of the City Engineer that the preliminary geotechnical report recommendations have been incorporated into the grading plan unless otherwise r, specified in the final geotechnical report and/or by the City Engineer. GEO-3 Excavation for the proposed project shall implement r dewatering activities in compliance with NPDES regulations. Pumped groundwater shall be sampled, tested, and (if deemed necessary) treated prior to discharge. , GE04 As native on-site soils are compressible upon placement of structural loads, project implementation shall implement complete removal and recompaction of compressible soils r, or use of piles and grade beams to support on-site structures. GEO-5 Type V cement shall be used for concrete and buried metal pipes shall utilize special measures (coatings, etc.) to protect against the effects of corrosive soils, r SEISMICITY/FAULTING The project area is subject to seismic activity, as it is situated within GEO-6 Due to the potential for ground shaking in a seismic event, 1.25 miles of anAlquist-Priolo Earthquake Fault Zone. Significance: the project shall comply with the standards set forth in the (ci Less than sign>ficant with mitigation. UBC(most recent edition)to assure seismic safety to the satisfaction of the Department of Building and Safety prior to issuance of a building permit,including compliance with California Division of Mines and Geology Special r Publication 117(Guidelines for Evaluating and Mitigating Seismic Hazards in California, adopted March 13, 1997). However,given the proximity of the site to the Newport- Inglewood and Compton Blind Thrust Faults,more stringent measures may be warranted. GEO-7 As the South Branch Fault(situated beneath the subject site)is classified as Category C by the City of Huntington Beach General Plan, special studies and subsurface investigation (including a site specific seismic analysis) shall be performed prior to issuance of a grading permit,to the approval of the City Engineer. The subsurface investigation shall include CPT and exploratory borings to determine the fault rupture potential of the South Branch Fault,which underlies the subject site. r— LIQUEFACTION POTENTIAL The proposed project will be subject to liquefaction hazards, post- GEO-8 Due to the potential for liquefaction within the project r liquefaction distress, seismically-induced settlement, and lateral vicinity,the Applicant shall comply with the standards set spread, as the project area has a potential for liquefaction. forth in the UBC(most recent edition)for structures on-site Significance:Less than significant with mitigation. to assure safety of the occupants to the satisfaction of the Department of Building and Safety prior to issuance of a building permit. These standards include compliance with the California Geological Survey Special Publication 117 (Guidelines for Evaluating and Mitigating Seismic Hazards in California,adopted March 13,1997)and Recommended r Procedures for implementation of California Geological r- City of Huntington Beach April 5, 2005 14 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report IMPACT MITIGATION MEASURE Survey Special Publication 117-Guidelines for Analyzing and Mitigating Liquefaction in California(Dr. Geoffrey R. Martin et al,May 1999). GEO-9 The proposed project shall incorporate adequate measures to stabilize structures from on-site soils known to be prone to liquefaction. Typical methods include,but are not limited to: Over excavation and recompaction of soils; in-situ soil densification (such as vibro-flotation or • vibro-replacement); injection grouting;and ❖ deep soil mixing. GEO-10 The site specific geotechnical investigation forthe proposed project shall analyze the potential for lateral spread on-site. If deemed a possibility,adequate subsurface stabilization practices(similar to those utilized for liquefaction)shall be incorporated prior to the construction of on-site structures. 5.3 HYDROLOGY,DRAINAGE AND STORM WATER RUNOFF LONG-TERM WATER QUALITY IMPACTS The proposed desalination facility may have hydrology and water HWQ-1 Prior to issuance of a precise grading permit,the applicant quality impacts in regards to flooding and storm water runoff. shall submit and obtain approval from the City of Huntington Signiricance:Less than signiricant with mitigation. Beach of a Water Quality Management Plan (WQMP) specifically identifying Best Management Practices(BMPs) that would be used on-site to control predictable pollutant runoff. This WQMP shall identify, at a minimum, the routine,structural and non-structural measures specified in the Countywide NPDES Drainage Area Management Plan (DAMP) Appendix which details implementation of the BMPs whenever they are applicable to a project, the assignment of long-term maintenance responsibilities tothe applicant,and shall reference the location(s)of structural BMPs. The applicable BMPs include: ❖ Plant materials that require fertilization and pest control shall be maintained in accordance with Orange County Management Guidelines for Use of Fertilizers and Pesticides. ❖ BMP structures and facilities shall be cleaned and maintained on a scheduled basis by a Facility Operator appointed person; HWQ-2 Appropriate site specific hydrology and hydraulic analysis will be performed for the project prior to the issuance of grading or building permits,which ever comes first. The analysis shall include mitigation measures,if necessary,in regards to storm water drainage and flooding. HWQ-3 Prior to the issuance of building permits (not including demolition permits)an appropriate on-site drainage system shall be installed for the project that integrates permanent stormwater quality features. �I City of Huntington Beach April 5, 2005 1-5 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report IMPACT MITIGATION MEASURE 5.4 AIR QUALITY LONG-TERM EMISSIONS r The proposed Seawater Desalination Project at Huntington Beach None required. would create long-term air quality emissions impacts through on-site station, off-site mobile, and off-site energy-related emissions. Significance:Less than sign cant. CONSISTENCY WITH REGIONAL PLANS Airquality emissions and relatedimpacts for the proposed project have None required. been accounted for both regionally and locally. Significance:Less than significant SENSITIVE RECEPTORS The proposed project may impact sensitive receptors surrounding the None required. Refer to Section 5.9, CONSTRUCTION RELATED project site in regards to air quality. Significance: Less than IMPACTS,fora discussion of short-term construction related air quality significant impacts. 5.5 NOISE LONG-TERM STATIONARY NOISE SOURCES r-- The proposed project may have long-term stationary noise impacts on NOM Prior to the issuance of any building or grading permits,the surrounding sensitive receptors.Significance.Less than significant Applicant shall prepare an acoustical analysis report and appropriate plans,prepared under the supervision of a City- approved acoustical consultant,describing the stationary noise generation potential and noise mitigation measures (such as the installation of double walls,sound absorbing materials, acoustic barriers, sound control curtains, and sound baffles), if needed,which shall be included in the r plans and specifications of the project. All stationary equipment shall be designed to insure that noise levels at the HBGS property line do not exceed the City's Industrial noise standard of 70.0 dBA and will be subject to the approval of the City of Huntington Beach. 5.6 PUBLIC SERVICES AND UTILITIES FIRE SERVICE ~ The proposed project could increase demand for fire and emergency None required. services within the City. Significance:Less than significant. SCHOOLS The proposed project is not expected to generate the need for PSU-1 Prior to the issuance of building permits,the applicant will additional school facilities, but it may place additional demand on be required to pay applicable school mitigation fees school facilities located within the vicinity of the project area. pursuant to State law. Significance:Less than significant impacts. City of Huntington Beach April 5,2005 1-6 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report IMPACT MITIGATION MEASURE LIBRARIES The Seawater Desalination Project may increase demand on the City's None required. library system. Significance:Less than significant. ROADWAY MAINTENANCE PSU-2 The Applicant will be required to pay appropriate traffic Additional traffic generated by the proposed project may increase impact fees as determined by the City of Huntington Beach demand on streets nearby the project site. Significance:Less than Department of Public Works. signFicant with mitigation PARKS AND RECREATION The desalination project may increase demand on park facilities within None required. the vicinity of the project area. Significance:Less than significant WASTEWATER Implementation of the proposed desalination facility could increase PSU-3 The Applicant will be required to pay five percent of the demand on the local wastewater system. Significance:Less than OCSD connection fee to the City of Huntington Beach. significant with mitigation. STORM WATER DRAINAGE The proposed project may increase demand on the local storm water None required. drainage system. Significance: Less than significant impact with mitigation. WATER l The proposed project's product water may create impacts in regards to PSU-4 The Applicant will be required to pay appropriate fees for water supply. Significance:Less than significant with mitigation. water service connections, installation, and meters. In addition, the City requires payment of a service fee for industrial customers. RECLAIMED WATER The project site does not currently utilize reclaimed water,and is not None required. anticipated to utilize reclaimed water in the future. Significance:Less than significant impact. SOLID WASTE Project implementation may increase the generation of solid waste, PSU-5 The Applicant will coordinate with the City's recycling thereby increasing demand on solid waste disposal facilities within the representative to ensure that the proposed project is in vicinity. Significance:Less than significant with mitigation. compliance with the City's waste reduction and recycling program. PSU-6 Prior to the issuance of a grading permit,the Applicant will prepare a waste reduction plan for the generation of construction and operational waste from the proposed project. This plan will be submitted to the recycling coordinator from the City of Huntington Beach who will ensure that AB 939 requirements are properly addressed. City of Huntington Beach April 5, 2005 1-7 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report IMPACT MITIGATION MEASURE ELECTRICITY The desalination project may create impacts in regards to increased None required. electricity demand. Significance:Less than significant. GAS Existing gas facilities in and surrounding the project area are capable None required. of accommodating additional demand resulting from the proposed project. Signiricance:Less than significant. TELEPHONE AND CABLE Existing telephone and cable facilities in and surrounding the project None required, r area are capable of accommodating additional demand resulting from the proposed project.Significance:Less than significant 5.7 AESTHETICSILIGHT&GLARE Y-' SITE CHARACTER The Seawater Desalination Project at Huntington Beach may alter the ALG-1 For areas visible by adjacent existing or proposed site character of the project area,including undeveloped portions of residential areas,exterior mechanical equipment shall be the project area,which would be considered a positive impact to the screened from view on all sides,and rooftop mechanical project area. Significance:Less than significant with mitigation. equipment shall be set back 15 feet from the exterior edges of the building. Equipment to be screened includes,but is not limited to, heating, air conditioning, refrigeration equipment, plumbing lines, duct-work and transformers. Said screening shall be architecturally compatible with the building in terms of materials and colors. If screening is not designed specifically into the building,a rooftop mechanical equipment plan showing screening must be submitted for review and approval with the application for building permit(s). LIGHT AND GLARE The proposed project may generate light and glare through on-site ALG-2 If outdoor lighting is included,light intensity shall be limited — lighting. Significance:Less than significant with mitigation. to that necessary for adequate security and safety. All outside lighting shall be directed to prevent"spillage"onto The proposed project may create additional light and glare through adjacent properties and shall be shown on the site plan and reflective sources. Significance: Less than significant. elevations. 5.8 HAZARDS&HAZARDOUS MATERIALS r LONG-TERM OPERATIONAL IMPACTS The proposed project may create hazards due to the storage, None required,other than project design implementation of existing transportation,and/or handling of hazardous materials,thereby posing regulations and requirements. a threat to on-site occupants and surrounding uses. Significance: Less than significant. r City of Huntington Beach April 5, 2005 1-8 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report IMPACT MITIGATION MEASURE 5.9 CONSTRUCTION RELATED IMPACTS HYDROLOGY AND WATER QUALITY CON-1 Concurrent with the submittal of the Grading Plan,the Applicant shall submit an Erosion Control Plan to the Proposed project construction may generate erosive conditions City of Huntington Beach Department of Public Works including sediment laden storm runoff or dust, which could have which would include the following measures: adverse impacts in regards to hydrology and water quality. a) Where necessary,temporary and/or permanent Significance:Less than significant with mitigation. erosion control devices, as approved by the Department of Public Works,shall be employed to control erosion and provide safety during the rainy season from October 15th to April 15"h. b) Equipment and workers for emergency work shall be made available at all times during the rainy season. Necessary materials shall be available on-site and stockpiled at convenient locations to facilitate the rapid construction of temporary devices when rain is imminent. c) Erosion control devices shall not be moved or modified without the approval of the Department of Public Works. d) All removable erosion protective devices shall be in place at the end of each working day when the 5-day rain probability forecast exceeds 40%. e) After a rainstorm, all silt and debris shall be removed from streets,check berms and basins. f) Graded areas on the permitted area perimeter must drain away from the face of the slopes at the conclusion of each working day. Drainage is to be directed toward desilting facilities. g) The permittee and contractor shall be responsible and shall take necessary precautions to prevent public trespass onto areas where impounded water creates a hazardous condition. h) The permittee and contractor shall inspect the erosion control work and ensure that the work is in accordance with the approved plans. ` i) Water shall be applied to the site twice daily during grading operations or as otherwise directed by the County of Orange Inspector in compliance with South Coast AQMD rule 403 (Fugitive Dust Emissions). A grading operations plan may be required including watering procedures to minimize dust, and equipment procedures to minimize vehicle emissions from grading equipment. CON-2 Construction of the project shall include Best Management Practices (BMPs) as stated in the Drainage Area Management Plan (DAMP) by the Orange County Stormwater Management Program. BMPs applicable to the project include the following: Potential pollutants include but are not limited to: solid or liquid chemical spills;wastes from paints, stains, sealants, glues, limes, pesticides, herbicides, wood preservatives and solvents; asbestos fibers,paint flakes,or stucco fragments; fuels,oils,lubricants,and hydraulic,radiator,or City of Huntington Beach April 5, 2005 1-9 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report r�l IMPACT MITIGATION MEASURE batteryfluids;fertilizers,vehicle/equipment wash r water and concrete wash water; concrete, detergent,or floatable wastes;wastes from any engine/equipment steam cleanings or chemical degreasing;and superchlorinated potable water line rinsings. ❖ During construction, disposal of such materials should occur in a specified and controlled temporary area on-site,physically separated from potential stormwater run-off, with ultimate disposal in accordance with local, state, and federal requirements. CON-3 As part of its compliance with the NPDES requirements, the Applicant shall prepare a Notice of Intent(N01)to be submitted to the Santa Ana Regional Water Qualityt Control Board providing notification and intent to comply with the State of California general permit. Prior to construction, completion of a Storm Water Pollution Prevention Plan (SWPPP) would be required for construction activities on-site. A copy of the SWPPP shall be available and implemented at the construction site at all times. CONA Prior to any dewatering activities, the Applicant shall obtain and comply with a general dewatering NPDES permit from the Santa Ana Regional Water Quality Control Board. CON-5 The Applicant shall submit a dewatering plan for review and approval by the Santa Ana Regional Water Quality Control Board and the City of Huntington Beach Department of Public Works. The Applicant would comply with the approved dewatering plan. CON-6 The Applicant shall inform the Orange County Water , District(OCWD)of its plans for on-site dewatering,and, if necessary, would acquire necessary permits and approvals from the OCWD to ensure that no adverse r impacts on the groundwater basin or seawater intrusion barrier occur as a result of the proposed project. The Applicant would comply with any approved dewatering permits or plans. CON-7 During dewatering operations,a survey program shall be conducted on surrounding properties and structures to ensure that movement or settlement from on-site r- dewatering operations does not occur. This survey program would be subject to approval by the City Engineer. r" CON-8 Should on-site dewatering operations require discharge into the sanitary sewer system,the Applicant shall obtain applicable permits and approvals from the Orange County Sanitation District (OCSD) and City of Huntington Beach Department of Public Works. Should the dewatering discharge be directed to existing AES stormdrain facilities, the Applicant shall ensure that dewatering is addressed in the Applicant's SARWQCB NPDES permit. City of Huntington Beach April 5, 2005 1-10 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report IMPACT MITIGATION MEASURE AIR QUALITY Short-term construction processes for the proposed project would CON 9 The project shall comply with SCAQMD Rule 402 which have short-term air quality impacts. Significance: Unavoidable prohibits the discharge from a facility of air pollutants significant impact. that cause injury,detriment,nuisance,or annoyance to the public or that damage business or property. CON-10 During clearing, grading, earth moving, or excavation operations, excessive fugitive dust emissions shall be controlled by regular water or other dust preventive measures using the following procedures,as specified in the SCAQMD Rule 403. ❖ On-site vehicle speed shall be limited to 25 miles per hour, ❖ All material excavated or graded would be sufficiently watered to prevent excessive amounts of dust.Watering would occur at least twice daily with complete coverage, preferable in the late morning and after work is done for the day. All material transported on-site or off-site would be either sufficiently watered or securely covered to prevent excessive amounts of dust. i The area disturbed by clearing, grading, earth moving, or excavation operations would be minimized so as to prevent excessive amounts of dust. These control techniques would be indicated in project specifications. Compliance with the measure would be subject to periodic site inspections by the City. ❖ Visible dust beyond the property line emanating from the project would be prevented to the maximum extent feasible. .NOISE Construction processes for the proposed desalination project may CON-11 Prior to the issuance of any grading permits, the generate significant amounts of noise and vibration, impacting Applicant shall ensure evidence acceptable to the City of adjacent sensitive receptors. Significance: Less than significant Huntington Beach Department of Planning and Public with mitigation. Works that: ❖ All construction vehicles or equipment, fixed or mobile, operated within 1,000 feet of a dwelling shall be equipped with properly operating and maintained mufflers; All operations shall comply with the City of Huntington Beach Municipal Code Chapter 8.40 (Noise Control); Stockpiling and/or vehicle staging areas shall be located as far as practicable from residential areas; • and Notations in the above format, appropriately numbered and included with other notations on the front sheet of grading plans,would be considered as adequate evidence of compliance with this condition. �- City of Huntington Beach April 5, 2005 1-11 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report r IMPACT MITIGATION MEASURE CON-12 Should the project require off-site importlexport of fill material during demolition, remediation, and construction,trucks shall utilize a route that is least disruptive to sensitive receptors,preferably Newland Street to Pacific Coast Highway to Beach Boulevard r, to 1-405. Construction trucks shall be prohibited from operating on Saturdays, Sundays and federal holidays. r—� CON-13 To reduce project-related construction noise impacts generated by the proposed project, the following conditions shall be implemented: Construction activities shall be limited to hours specified by the City Noise Ordinance;and :• Unnecessary idling of internal combustion r- engines shall be prohibited. PUBLIC SERVICES AND UTILITIES r7 Project implementation may create an increase demand for public CON-14 Unless underground utility locations are well services and utilities. Signiricance: Less than sign cant. documented,as determined by the City of Huntington Beach Public Works Department,the project engineer Project implementation may conflict with underground utilities along shall perform geophysical surveys to identify the proposed pipeline alignment.Significance:Less than sign cant subsurface utilities and structures, the findings of with mitigation. which shall be incorporated into site design. Pipelines or conduits which may be encountered within the excavation and graded areas shall either be relocated or be cut and plugged according to the applicable code requirements. AESTHETICS/LIGHT&GLARE Project-related construction may adversely impact views of and across CON-15 During construction, a security fence,the height of the proposed project site through debris,equipment,and truck traffic. which shall be determined by the City of Huntington Signiricance: Less than sign cant with mitigation. Beach Department of Building and Safety,shall be installed around the perimeter of the site. The construction site shall be kept clear of all trash, weeds,etc. CON-16 Construction activities,to the extent feasible,shall be concentrated away from adjacent residential areas. Equipment storage and soil stockpiling shall be at least 100 feet away from adjacent residential property lines. r-- HAZARDS AND HAZARDOUS MATERIALS Project implementation may pose a risk to on-site workers and CON-17 Prior to excavation of the contaminated and other adjacent land uses with regards to short-term construction related areas for rough grading, the project site shall be hazards and hazardous materials. Significance: Less than cleared of all excess vegetation, surface trash, sign cant with mitigation. piping,debris and other deleterious materials.These materials shall be removed and disposed of properly (recycled if possible). CON-18 Proper excavation procedures shall be followed to comply with OSHA's Safety and Health Standards. If applicable,the South Coast Air Quality Management District (SCAQMD) Rule 1166 permit shall be r City of Huntington Beach April 5, 2005 1-12 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report IMPACT MITIGATION MEASURE obtained prior to the commencement of excavation and remedial activities. CON-19 The contractor shall follow all recommendations contained within the adopted Remedial Action Plan for the project site. CON-20 If asbestos or lead-based paints are identified in any on-site structures, the contractor shall obtain a qualified contractor to survey the project site and assess the potential hazard. The contractor shall contact the SCAQMD and the City of Huntington Beach Departments of Planning,Building and Safety, and Fire prior to asbestos/lead paint removal. CON-21 If any hazardous materials not previously addressed in the mitigation measures contained herein are identified and/or released to the environment at any point during the site cleanup process,operations in that area shall cease immediately. At the earliest possible time,the contractor shall notify the City of Huntington Beach Fire Department of any such findings. Upon notification of the appropriate agencies, a course of action would be determined subject to the approval of the by the City of Huntington Beach Department of Public Works. CON-22 All structures must be cleaned of hazardous materials prior to off-site transportation,or hauled off-site as a waste in accordance with applicable regulations. CON-23 Structure removal operations shall comply with all regulations and standards of the SCAQMD. CON-24 The contractor shall post signs prior to commencing remediation, alerting the public to the site cleanup operations in progress. The size, wording and placement of these signs shall be reviewed and approved by the City of Huntington Beach Departments of Planning and Public Works, CON-25 Any unrecorded or unknown wells uncovered during the excavation or grading process shall be immediately reported to and coordinated with the City of Huntington Beach Fire Department and State Division of Oil, Gas, and Geothermal Resources (DOGGR). CON-26 During remediation, if any soil were found to be hazardous due to contamination other than petroleum hydrocarbons, it would be segregated, stockpiled, and handled separately. CON-27 Dust and volatile organic emissions from excavation activities shall be controlled through water spray or by employing other approved vapor suppressants including hydromulch spray in accordance with Regional Water Quality Control Board (RWQCB) Waste Discharge Requirements and the South Coast Air Quality Management District(SCAQMD)permit conditions. City of Huntington Beach April 5, 2005 1-13 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report IMPACT MITIGATION MEASURE CON-28 Prior to the excavation process for pipeline construction,the contractor shall coordinate with the County of Orange's Integrated Waste Management Department in order to ensure that proposed pipeline construction does not impact drainage of the former Cannery Street Landfill. CON-29 Methane mitigation features would be consistent with the requirements of the City of Huntington Beach Specification Number 429 and other applicable state and federal regulations. The methane mitigation features shall be submitted for review and approval to the Orange County Health Care Agency(OCHCA), Environmental Health Division. CON-30 Studies to evaluate the potential for landfill gas(LFG) r generation and migration would be completed prior to implementation of the proposed water delivery component of the project. Appropriate mitigation measures would be coordinated with the South Coast Air Quality Management District,Solid Waste Local Enforcement Agency,Regional Water Quality Control Board, and the City of Huntington Beach Fire Department. Mitigation measures could entail active or passive extraction of LFG to control surface and off-site migration and passive barriers with vent layers and alarm systems below trenches and within f 1,000 feet of the former Cannery Street Landfill boundary. A comprehensive monitoring network would be established along the pipeline alignment adjacent to the landfill. Periodic monitoring of the monitoring network would be performed. TRAFFIC Short-term project construction(of both on-site and off-site elements) CON-31 A Traffic Management Plan(TMP)shall be prepared could potentially create impacts in regards to traffic. Significance: and implemented to the satisfaction of the affected Less than significant with mitigation. jurisdiction within which the facilities are to be constructed when the facilities are to be located r where construction would affect roadways. The TMP shall include, but not be limited to, the following measures: ❖ Limit construction to one side of the road or out of the roadbed where possible; Provision of continued access to commercial and residential properties adjacent to construction sites; s• Provide alternate bicycle routes and pedestrian paths where existing paths/routes are disrupted by construction activities,if any; Submit a truck routing plan,for approval by the City of Huntington Beach, County, and other responsible public agencies in order to minimize impacts from truck traffic during material delivery and disposal; r- .• Where construction is proposed for two-lane roadways, confine construction to one-half of City of Huntington Beach April 5, 2005 1-14 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report IMPACT MITIGATION MEASURE the pavement width. Establish one lane of traffic on the other half of the roadway using appropriate construction signage and flagmen, or submit a detour plan for approval by the City Traffic Engineer; :• The Traffic Management Plan shall be approved by affected agencies at least two weeks prior to construction. Per Caltrans requirements, the applicant shall submit the Traffic Management Plan to Caltrans at the 90-percent design phase; Construction activities shall, to the extent feasible,be coordinated with other construction activity taking place in the affected area(s);and �o Provide for temporary parking, where necessary,during installation of pipelines within the AES site. CON-32 Prior to initiating the removal of structures and contaminated materials,the contractor must provide evidence that the removal of materials would be subject to a traffic control plan, for review and approval by the by the City of Huntington Beach Department of Public Works. The intent of this measure is to minimize the time period and disruption of heavy duty trucks. CON-33 Construction related activities would be subject to, and comply with, standard street use requirements imposed by the City of Huntington Beach,County and other public agencies,including the use of flagmen to assist with haul truck ingress and egress of construction areas and limiting the large size vehicles to off-peak commute traffic periods. CON-34 The Contractor shall obtain the necessary right-of- way encroachment permits and satisfy all permit 1 requirements. Nighttime construction may be performed in congested areas. Also,any nighttime construction activities shall have prior approval by the City of Huntington Beach Department of Public Works. CON-35 During periods of heavy equipment access or truck hauling, the Contractor would provide construction traffic signage and a construction traffic flagman to control construction and general project traffic at points of ingress and egress and along roadways that require a lane closure. CON-36 The Applicant shall coordinate with the Department of Public Works, Traffic Engineering Division in developing a truck and construction vehicle routing plan. This plan shall include the approximate number of truck trips and the proposed truck haul routes. It shall specify the hours in which transport activities can occur and methods to mitigate construction related impacts to adjacent residents and the surrounding area. The plan shall take into City of Huntington Beach April 5, 2005 1-15 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report r IMPACT MITIGATION MEASURE consideration any street improvement construction occurring in the vicinity. These plans must be submitted for approval to the Department of Public Works. BIOLOGICAL RESOURCES Construction of the proposed project may result in impacts to sensitive CON-37 Prior to construction on the proposed OC-44 booster biological resources. Signifficance: Less than significant with pump station site, three focused coastal California mitigation. gnatcatcher surveys shall be performed for the site in accordance with USFWS protocols,preferably during the gnatcatcher breeding season. Should the species be observed on or adjacent to the site, consultation and permitting through the USFWS would be required. CON-38 Prior to construction on the proposed OC-44 booster pump station site, eight focused least Bell's vireo surveys shall be performed for the off-site underground booster pump station(at least 10 days apart during the vireo nesting season of April and July)in accordance with USFWS protocols. Should the species be observed on or adjacent to the site, consultation and permitting through the USFWS would be required. This measure may not be necessary if construction phasing can avoid the vireo nesting season. CON-39 Prior to construction on the proposed OC-44 booster pump station, a qualified biologist shall perform a habitat assessment for the southwestern pond turtle at the pump station site. If habitat for this species is observed,a trapping program would be implemented to determine the presence or absence of these species.If present,pond turtles must be trapped and relocated prior to the start of construction. CON-40 A survey for active raptor nests shall be performed by a qualified biologist 30 days prior to the commencement of construction activities on the OC- '— 44 proposed booster pump station site.Any occupied nests discovered during survey efforts shall be mapped on construction plans for the site. If recommended by the biologist, restrictions on construction activities may be required in the vicinity of the nest until the nest is no longer active. CON-41 Prior to the commencement of any directional boring r for water conveyance pipeline implementation, the applicant shall prepare a Frac-Out Contingency Plan. The plan shall establish criteria under which a bore would be shut down(e.g.,loss of pressure,loss of a certain amount of returns)and the number of times a single bore should be allowed to frac-out before the bore is shut down and reevaluated. It would also clearly state what measures would be taken to seal previous frac-outs that have occurred on a given bore to ensure that it does not become the path of least resistance for subsequent frac-outs.Additionally,the r site-specific Frac-Out Contingency Plan would be prepared and reviewed by the City Engineer and City of Huntington Beach April 5, 2005 1-16 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report IMPACT MITIGATION MEASURE appropriate resource agencies prior to each major bore. CON-42 In order to minimize potential construction impacts to nesting savannah sparrows adjacent to the proposed desalination facility,a pre-construction nesting survey would be performed by a qualified biologist in consultation with applicable regulatory agencies. Should nesting savannah sparrows be found, adequate mitigation(such as relocation,construction noise abatement measures, etc.) would be implemented as appropriate based on the findings of the pre-construction survey. CON-43 All focused surveys for sensitive biological resources performed prior to proposed project implementation shall include a review of data within the California Natural Diversity Data Base (CNDDB) to obtain current information on any previously reported sensitive species/habitat,including Significant Natural Areas identified under Chapter 12 of the Fish and Game Code. CON-44 Prior to implementation of the proposed off-site OC- 44 booster pump station adjacent to the NCCP/HCP boundary,a jurisdictional delineation of the proposed pump station site shall be performed to determine the extent of jurisdictional area, if any, as part of the regulatory permitting process. CULTURAL RESOURCES Construction of the proposed project may result in impacts to cultural resources. Signiricance: Less than sign cant with mitigation. CON-45 Should buried historical/archaeological resources be discovered during excavation on the proposed OC 44 booster pump station site,all construction work in that area shall be halted or diverted until a qualified archaeologist can evaluate the nature and significance of the finds. CON-46 During excavation of five feet below ground surface or lower on the OC-44 proposed booster pump station site,a paleontological resource recovery program for Miocene invertebrate fossils shall be implemented. This program shall include,but would not be limited to,the following: Monitoring of excavation in areas identified as likely to contain paleontologic resources by a qualified paleontologic monitor. The monitor shall be equipped to salvage fossils as they are unearthed to avoid construction delays and to remove samples of sediments,which are likely to contain the remains of small fossil invertebrates and vertebrates. The monitor must me empowered to temporarily halt or divert equipment to allow removal of abundant or large specimens. Monitoring may be reduced if the potentially fossiliferous units described herein are not encountered, or upon exposure are City of Huntington Beach April 5, 2005 1-17 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report IMPACT MITIGATION MEASURE determined following examination by qualified paleontologic personnel to have low potential to contain fossil resources; ❖ Preparation of recovered specimens to a point of identification and permanent preservation, including washing of sediments to recover small invertebrates and vertebrates; S• Identification and curation of specimens into a museum repository with permanent retrievable storage. The paleontologist should have a written respository agreement in hand prior to the initiation of mitigation activities;and Preparation of a report of findings with appended itemized inventory of specimens. The report and inventory,when submitted to the appropriate Lead Agency, would signify completion of the program to mitigate impacts to paleontologic resources. CON-47 A qualified paleontologist shall be retained to monitor grading operations at the proposed desalination facility site,and,if necessary,to salvage scientifically significant fossil remains. The paleontologist shall have the authority to temporarily divert or direct grading efforts to allow evaluation and any salvage of exposed fossils. 5.10 OCEAN WATER QUALITY AND MARINE BIOLOGICAL RESOURCES OCEAN WATER QUALITY The proposed project may adversely impact ocean water quality in the vicinity of the HBGS outfall.Signiricance:Less than sign cant n None required. MARINE BIOLOGICAL RESOURCES The proposed project may have adverse impacts upon marine None required. biological resources in the vicinity of the HBGS outfall.Signiricance: Less than si niricant. r- 5.11 PRODUCT WATER QUALITY PRODUCT WATER QUALITY r--� The proposed project may create impacts due to the quality of potable PW-1 Prior to project operations, the applicant shall obtain all water produced by the desalination process. Significance:Less than required drinking water permits from the California sign cant with mitigation. Department of Health Services. These permits are r anticipated to consist of: ❖ A Wholesale Drinking Water Permit;and ❖ An Administrative Change to Retail Agencies' Drinking Water Permit(to include desalinated water from the proposed project as an approved source of supply for their agency). r- City of Huntington Beach April 5, 2005 1-18 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report IMPACT MITIGATION MEASURE PW-2 During final design of the proposed project,the applicant shall incorporate the following six provisions to protect water quality in the event of"non-routine"operations at the HBGS(defined as operations such as seawater emergency intake pump shut downs and failures,electricity equipment malfunctions,excessively high temperature of the cooling water,etc.): Automatic control interlock between HBGS pumps and desalination facility intake pumps:The shutdown controls of the desalination facility intake pumps shall be interlocked with the HBGS pumps,so when HBGS pump operation is discontinued to prepare for heat treatment, non-routine or even routine pump shutdown,this would automatically trigger an alarm at the desalination facility along with shutdown of the desalination intake pumps. After this emergency shutdown, the intake pumps shall be started up manually,and the operations staff would be required to check the reason of shutdown with the HBGS staff before restarting the treatment facility intake pumps. Continuous Intake Pump Flow Measurement Devices: Seawater intake pumps shall be equipped with flowmeters, which would record the pumped flow continuously. If the intake flow is discontinued for any reason, including non-routine HBGS operations, automatic intake pump shutdown shall occur. Continuous Intake Water Temperature Measurement Devices: The desalination facility intake pump station shall be equipped with instrumentation for continuous measurement of the intake temperature. Any fluctuations of the intake temperature outside preset normal limits shall trigger alarm and intake pump shutdown. This monitoring equipment shall provide additional protection against heat treatment or other unusual intake water quality conditions. Continuous Intake Water Salinity/Conductivity Measurement Devices:The desalination facility intake pump station shall be equipped with instrumentation for continuous measurement of the intake seawater salinity. Any fluctuations of the intake salinity outside preset normal operational limits shall trigger an alarm and initiate intake pump shutdown. This monitoring equipment shall provide additional protection against discharge of unusual fresh water/surface water streams in the facility outfall. Continuous Intake Water Oil Spill/Leak Detection Monitoring Devices: The desalination facility intake pump station shall be equipped with instrumentation for oil spill/leak detection. Detection of oil in the intake water even in concentrations lower than 0.5 mg/L shall automatically trigger an alarm and initiate intake pump shutdown. This monitoring equipment shall provide additional protection against unusual intake water quality conditions. City of Huntington Beach April 5, 2005 1-19 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report r-� IMPACT MITIGATION MEASURE •: Routine Communication with HBGS Staff: The desalination facility staff of each shift shall be required to contact HBGS personnel at least once per shift and enquire about unusual planned or unplanned events at the HBGS. If non-routine operations are planned at the HBGS,the desalination facility shall modify desalination facility operations accordingly. PW-3 During project operations,the RO membrane system shall be continuously monitored for feed seawater and permeate conductivity and the differential pressure through the membranes. If permeate salinity(i.e.total dissolved solids) concentration exceeds the design level,membranes shall be cleaned to recover their original performance capabilities. PRODUCT WATER RELIABILITY r The reliability of product water at the Seawater Desalination Project at PW4 Prior to project operations, the desalination facility Huntington Beach may be adversely impacted by emergency operations staff shall develop an earthquake mitigation and r conditions such as seismic events. Significance: Less than preparedness plan,which shall be coordinated with the City significant with mitigation. of Huntington Beach. This plan shall define coordination measures to assure continuous plant operations and water delivery under earthquake emergency conditions. ORANGE COUNTY WATER DISTRIBUTION SYSTEM The proposed desalinated product water may have adverse impacts PW-5 Prior to project operations,a corrosion monitoring system upon the existing Orange County water distribution system. shall be installed in the proposed transmission pipeline at Significance:Less than sign cant with mitigation. points of interconnection with the existing water distribution system to ensure that the proposed corrosion control measures are effective and adequate. PW-6 To protect against potential taste and odor problems , associated with the startup of facility operations, a sequential rinsing program shall be initiated just prior to project startup that shall be coordinated with the involved water agencies to minimize any sediment disturbance that might occur due to flow reversal in a portion of the existing distribution system. PW-7 Prior to project operations, a sampling location shall be established near the physical connection of the transmission pipeline to the OC-44 feeder. A monitoring program shall be implemented for this location r-� incorporating the following parameters:coliform bacteria, heterotrophic bacteria, chlorine residual, disinfection byproducts, and aesthetic parameters such as turbidity, odor,and color,as well as corrosion indices. F— PW-8 Prior to project operations, additional modeling shall be performed to confirm that the proposed project shall not have pressure surge impacts upon the existing regional r- water distribution system. The model shall recommend appropriate facilities to prevent pressure surges,such as Incorporation of pressurized surge tanks at booster pump station locations; City of Huntington Beach April 5, 2005 1-20 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report IMPACT MITIGATION MEASURE ❖ Vacuum relief and air release valve improvements; Hydraulically operated isolation valves; ❖ Elimination of existing valves;and/or Pressure control valve improvements. PW-9 Prior to project operations,the applicant shall coordinate with and obtain approval as required from applicable local water agencies that own and operate the distribution system in which the desalinated water would come in contact with. Various operating approvals and corresponding agreements shall be signed before the desalinated water is introduced into the local distribution s stem. UNAVOIDABLE SIGNIFICANT IMPACTS ' AIR QUALITY Even after implementation of mitigation measures, the proposed desalination project may have unavoidable significant impacts in regards to temporary, short-term emissions for NO,. However, impacts in this regard have been adequately analyzed within the City's General Plan EIR, as the project will be consistent with all General Plan and zoning designations. No other unavoidable significant impacts have been identified for the Seawater Desalination Project at Huntington Beach. 1.3 SUMMARY OF PROJECT ALTERNATIVES "NO PROJECT"ALTERNATIVE None of the impacts associated with the proposed development and construction activities would occur if the "No Project" alternative were selected. Implementation of this alternative would leave the existing portion of the fuel oil storage facility, proposed pipeline alignment, and proposed underground booster pump station sites in place, and would avoid any adverse physical or environmental impacts associated with the proposed project. Existing geologic,soils,and aesthetic conditions in the area would remain the same. Air quality, noise, and traffic impacts due to construction of the desalination facility, pipeline, and pump stations would not occur with the "No Project"alternative. The "No Project" alternative is not presently being considered because it fails to meet the basic ' project objectives. In addition, the existing project site degrades the aesthetic character of the vicinity and, if not remediated as proposed, may pose a significant health risk due to petroleum hydrocarbon contamination. Furthermore,the"No Project"alternative would not realize the project benefit of providing a "drought proof," high quality, new potable water supply. "ALTERNATIVE SITE" ALTERNATIVE An alternative site(formerly the proposed project site within Initial Study prepared for the previously circulated EIR, dated May 17, 2001)for the desalination facility is located southwest of the current project site,within the HBGS,with HBGS office buildings to the west, an electrical switchyard to the north,and fuel oil storage tanks to the east. The alternative site is located within approximately 300 feet of the proposed project site, closer to the residential uses to the west. Project operation and equipment would be similar as with the project. However,the primary constraint for this site that led City of Huntington Beach April 5, 2005 1-21 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report to its rejection is potentially significant temporary and permanent disruption to HBGS parking, access and operational activities,as the site is located immediately adjacent to the generating units and would displace existing parking, access areas and buildings. In addition, due to the site constraints that would be placed on HBGS from this alternative, it may preclude the power plant from converting to gas turbine combined cycle operation in the future. As such,this alternative site is not considered feasible. Several other locations outside of the City of Huntington Beach have also been considered for this project, including the mouth of San Juan Creek(within the City of Dana Point), San Onofre (within San Diego County), and along the coast of the City of San Clemente (refer to Exhibit 7-1, , ALTERNATIVE SITE LOCATION MAP, and Table 7-3, ALTERNATIVE SITE COMPARISON). These alternatives are not being considered for a variety of reasons, such as environmental concerns of a new ocean intake/discharge system (San Clemente)and/or engineering/acquisition , issues (San Onofre). "ALTERNATIVE OWNERSHIP"ALTERNATIVE The"Alternative Ownership"alternative would not change any of the design or operational features of the project. Rather,this alternative consists of the exact same project owned and operated by a public entity. The project proponent, a private entity, has already obtained lease rights to the site through negotiations with the current land owner(AES Huntington Beach, LLC). For this alternative to be feasible, a public entity would first need to negotiate with the applicant or otherwise obtain lease rights to the site. Assuming that lease rights of the site were acquired by a public entity, this alternative would result in the same environmental impacts as the proposed project(under private ownership). Consequently, the "Alternative Ownership" alternative and the project as proposed would result in the same potential impacts on the environment. "ALTERNATIVE PROJECT DESIGN"ALTERNATIVE The "Alternative Project Design" Alternative would incorporate a different method of desalination (such as multi-effect distillation, or MED)or an alternative seawater intake collection system (such as vertical wells, Ranney wells, infiltration galleries, and seabed infiltration systems). The MED alternative is infeasible due to the extreme height required for operation of the vertical tubes (300 feet) and the dependency on an electrical power plant for generation of steam. Alternative intake methods are infeasible primarily due to the number of vertical/Ranney wells necessary for a 50 mgd project(at least 24 individual wells),and the area of disruption necessary for an infiltration gallery or 117 seabed infiltration system. An alternative discharge location (the Orange County Sanitation District [OCSD] outfall)was also analyzed as an alternative. This alternative is also rejected,since OCSD has indicated that they do not have the capacity to accommodate the waste stream from the proposed desalination project. r "REDUCED FACILITY SIZE" ALTERNATIVE The proposed desalination project is currently designed to incorporate reverse osmosis (RO) technology to remove impurities from seawater to produce approximately 50 mgd (56,000 AFY)of potable water for distribution to local water agencies. One alternative to the proposed project would be to reduce the output of project water to approximately 25 mgd. The design and operation of the proposed desalination facility would generally remain the same. However, this alternative would reduce the size of the facility,the amount of seawater required to produce water,and the amount of concentrated seawater discharged back into the HBGS outfall. r- The 25 mgd alternative would not significantly reduce potential environmental impacts when compared to the proposed project. In addition,this alternative would result in a substantial decrease City of Huntington Beach April 5,2005 1-22 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report in the amount of desalinated water that could be produced, and thus a substantial increase in the cost of the desalinated water. Consequently, the 25 mgd alternative would not achieve the project objectives to provide a sufficient amount of water that would meet the future water needs projected by Orange County water purveyors, and would reduce overall water supply reliability that is sustainable and independent of climatic conditions. While the Reduced Facility Size alternative may result in slightly reduced impacts in comparison to the proposed project,the 25 mgd alternative would result in providing water at a cost that would not be acceptable to Orange County water purveyors, and would not produce a sufficient amount of desalinated water to meet projected future demand. Implementation of the 25 mgd alternative would not avoid the project's identified unavoidable construction related air quality impact, and would reduce the water quality benefits of the project as proposed. As such, this alternative is not presently under consideration. "ENVIRONMENTALLY SUPERIOR"ALTERNATIVE None of the above alternatives are considered "environmentally superior"to the proposed project, except for the "No Project" Alternative. In this case, CEQA requires identification of an "environmentally superior" alternative from among the other alternatives. Implementation of the project on an alternative site, while dependent on site-specific variables, is not anticipated to significantly reduce impacts,as alternative site implementation is expected to result in overall similar or greater environmental impacts. The"Alternative Ownership"alternative would result in the same environmental impacts as the proposed project. A hypothetical reduction in facility size can be argued to be "environmentally superior", based on the reduction in facility size and corresponding reduction in traffic, air and noise impacts. However, reducing facility size and output would not substantially reduce any significant impacts. The other alternative project design alternatives (alternative desalination methods and alternative intake facilities),while offering some environmental benefits, result in greater environmental impacts overall. Consequently, and in accordance with the mandate of CEQA,the"Alternative Project Design—Reduced Facility Size"alternative is identified as the environmentally superior alternative in comparison to the proposed project. 1.4 AREAS OF CONTROVERSY AND ISSUES TO BE RESOLVED Section 5.0 includes a detailed discussion of environmental impacts associated with the proposed project. Section 6.0 includes a discussion of the long-term implications of the proposed project. These issues have been the subject of extensive public hearings, study sessions, and public testimony before both the Planning Commission and City Council of the City of Huntington Beach. Several areas of controversy were identified and addressed through the public hearings and responsive informational disclosure. Three predominant subject areas of public controversy were identified by the City Council, and as a result, this Draft Recirculated EIR includes updated information and analysis of the following: 1) Impingement and entrainment impacts of the currently permitted once through cooling water system of HBGS and the potential impingement and entrainment impacts that may be caused by the proposed project; 2) Potential growth-inducing impacts of the proposed project; and 3) Compatibility of the desalination facility's product water with existing potable water supplies delivered through the regional water distribution system. The selection of a specific pipeline alignment can be characterized as an issue to be resolved. This Draft EIR has evaluated several pipeline alignment alternatives, in sufficient detail to allow implementation of any of the identified alternatives. As part of typical refined analyses that occur in final design, variations to these alternatives may be developed. City staff has the discretion to City of Huntington Beach April 5, 2005 1-23 Seawater Desalination Project at Huntington Beach 1.0 EXECUTIVE SUMMARY Draft Recirculated Environmental Impact Report determine whether or not this EIR adequately addresses future project plans, pursuant to CEQA Guidelines Section 15162. r-, r-, r-, n F- City of Huntington Beach April 5, 2005 1-24 i 1 1 1 1 1 ' 2.0 INTRODUCTION AND PURPOSE 1 1 1 1 f i 1 2.0 INTRODUCTION AND PURPOSE 2.1 PURPOSE OF THE EIR The previously circulated Draft Environmental Impact Report (EIR) for the Poseidon Seawater Desalination Project(now entitled the "Seawater Desalination Project at Huntington Beach")was made available for public review on September 19, 2002 for a period of 45-days. The purpose of the previously circulated Draft EIR was to review existing conditions,analyze potential environmental impacts and suggest feasible mitigation measures to reduce significant adverse environmental effects of the proposed "Seawater Desalination Project at Huntington Beach" (unless otherwise noted, "project" refers to all aspects of the proposed Seawater Desalination Project at Huntington Beach, including temporary construction-related effects and long-term effects associated with project buildout and implementation). A total of 21 comment letters were received from federal, state, and local regulatory/trustee agencies. In addition,several interested parties testified and provided written comments during the public review period. A Responses to Comments document (dated March 21, 2003), provided responses to each of the 21 formal comment letters received on the Draft EIR, and was utilized as part of the Final EIR considered by the City of Huntington Beach Planning Commission and City Council. After several public hearings, the Planning Commission certified the EIR on August 12, 2003. On appeal, the City Council voted to deny certification of the EIR on December 15, 2003, citing a lack of sufficient information in regards to marine biology(entrainment and impingement), growth inducement, and product water compatibility (the Planning Commission and City Council public hearing process are described in further detail below, in Section 2.4, PUBLIC SCOPING PROCESS). As such, the previously circulated Draft EIR has been revised as part of this Recirculated EIR in order to address the concerns expressed during review of the previous EIR. No impact conclusions have changed as part of the Recirculated EIR, although a substantial amount of information has been added throughout the document to clarify and further support the conclusions provided. It is the intent of this Recirculated EIR to provide construction-level environmental documentation for the project by utilizing the most current and detailed plans, technical studies and related information available. For more detailed information regarding the proposed development, refer to Section 3.0, PROJECT DESCRIPTION. This Recirculated EIR will be used by the City of Huntington Beach and other responsible agencies and interested parties to evaluate the environmental impacts of the proposed project (refer to Section 3.6,AGREEMENTS, PERMITS AND APPROVALS, for a list of responsible agencies and project approvals). 2.2 COMPLIANCE WITH CEQA This Recirculated EIR has been prepared in conformance with the California Environmental Quality 1 Act (CEQA) Statutes (as amended through January 2005)and the CEQA Guidelines, particularly California Code of Regulations, Article 7, Section 15088.5 (recirculation of an EIR) and Article 9, Section 15120 through 15132 (content of an EIR).As a Recircuated EIR, this document will serve as the comprehensive compliance with the California Environmental Quality Act pursuant to CEQA Guidelines. CEQA Guidelines Section 15088.5(g)provides: "When recirculating a revised EIR,either in whole or in part, the lead agency shall, in the revised EIR or by an attachment to the revised EIR, summarize the revisions made to the previously circulated draft EIR." The following language is City of Huntington Beach April 5, 2005 2-1 Seawater Desalination Project at Huntington Beach 2.0 INTRODUCTION AND PURPOSE Draft Recirculated Environmental Impact Report provided in compliance with Section 15088.5(g). The previously circulated Draft EIR has been revised as summarized below: ❖ This EIR includes a summary description of the areas of controversy and issues raised during the hearings held before the City of Huntington Beach Planning Commission and City Council (see Section 2.4, PUBLIC SCOPING PROCESS). ❖ This EIR includes technical references with new and updated information (see Section 2.7, INCORPORATION BY REFERENCE, Section 10.0, BIBLIOGRAPHY, and Section 11.0, APPENDICES). ❖ Section 3.0, PROJECT DESCRIPTION has been revised to include: 1) more detail concerning the interaction between the project and the Huntington Beach Generating Station (HBGS)operated by Applied Energy Services Corporation (AES); 2) more detail about the project's off-site improvements; and 3)to eliminate discussion of the aboveground product water storage tank as an option to the underground product water storage tank. The project now includes an aboveground product water storage tank. ❖ As in the previously circulated EIR, this Recirculated EIR provides a description of existing conditions/environmental setting as a precursorto the discussion of potential environmental impacts (see Section 5.0, ENVIRONMENTAL ANALYSIS). However, a new Section (Section 4.0, EXISTING CONDITIONS)has been included to provide additional information regarding the existing conditions and environmental setting of the project. This new section provides additional background and baseline information in order to assist decision makers and the public in their analysis of the potential environmental impacts of the project. ❖ This EIR includes an updated analysis of all of the impact areas that were analyzed in the previous EIR (the analysis that was in Section 4.0, ENVIRONMENTAL ANALYSIS of the previous EIR is now found in Section 5.0 of this Recirculated EIR). A separate and more detailed analysis of two impact areas(with additional background and baseline information) is included in this EIR: • Section 5.10 — OCEAN WATER QUALITY AND MARINE BIOLOGICAL RESOURCES; and • Section 5.11 —PRODUCT WATER QUALITY. ❖ The discussion of Growth Inducing Impacts of the Proposed Action has been updated and revised (see Section 6.2). ❖ The discussion of Cumulative Impacts has been updated and revised (see Section 6.3). ❖ The discussion of Alternatives to the Proposed Action has been updated and revised (see Section 7.0). As part of the review process,the Draft Recirculated EIR is subject to a 45-day public review period by responsible and concerned agencies and interested parties. Following this period,responses to comments received from these agencies will be prepared. The Final Recirculated EIR will consist of the Draft Recirculated EIR or a revision of the draft, as well as comments received on the Draft Recirculated EIR and the responses to these comments. The Recirculated EIR will be considered by decision makers prior to action on the project. City of Huntington Beach April 5, 2005 2-2 Seawater Desalination Project at Huntington Beach 2.0 INTRODUCTION AND PURPOSE Draft Recirculated Environmental Impact Report 2.3 SCOPE OF THE EIR As stated above, this Recirculated EIR has been prepared in order to address the concerns expressed during the previous EIR process. No impact conclusions have changed as part of the Recirculated EIR, although a substantial amount of information has been added throughout the document to clarify and further support the conclusions provided. Much of the information and analysis within the original Draft EIR has been rearranged to better assist agencies/interested parties in reviewing the document. Issues discussed within this EIR are as follows: • Land Use/Relevant Planning • Geology, Soils, and Seismicity • Hydrology, Drainage, and Storm Water Runoff • Air Quality • Noise • Public Services and Utilities • Aesthetics/Light& Glare • Hazards and Hazardous Materials • Construction Related Impacts • Ocean Water Quality and Marine Biological Resources Product Water Quality • Additional CEQA-mandated discussion (alternatives, growth, cumulative impacts). 2.4 PUBLIC SCOPING PROCESS The original Draft EIR process for the Seawater Desalination Project at Huntington Beach included public scoping in order to gather information on concerns and issues that the general public may have regarding the project and the EIR. Two public scoping meetings were held on June 6, 2001 (2:30pm and 7:15pm),at Edison Community Center in the City of Huntington Beach. Participants at both meetings consisted primarily of local residents, City staff, and representatives from the Southeast Huntington Beach Neighborhood Association (SEHBNA) and the Southeast Homeowner's Association (SEHOA). A summary of issues and concerns raised at each scoping meeting are described below: ❖ Land Use/Relevant Planning • Local homeowners will be directly impacted by another industrial use nearby their residences. • Implementation of the project should not cost the City or taxpayers any money. • If the desalination plant is built, local residents should receive some sort of direct benefit. • The potential implementation of a City water storage facility nearby the proposed Poseidon Desalination Project should be planned carefully to avoid impacting local residents. ❖ Air Quality • The proposed desalination project should not contribute to the HBGS's pollutant emissions. • The desalination project should not create fugitive dust or odors. City of Huntington Beach April 5, 2005 2-3 Seawater Desalination Project at Huntington Beach 2.0 INTRODUCTION AND PURPOSE Draft Recirculated Environmental Impact Report ❖ Noise • All stationary noise sources should be properly attenuated. ❖ Public Services and Utilities • The proposed plant's electrical demand should be regulated,as electricity is in short supply statewide. ❖ Ocean Water Quality and Marine Biological Resources • The brine discharge from the proposed desalination plant should not change the temperature of discharge from the AES outfall into the ocean. ❖ Product Water Quality • Poseidon should be cautious to ensure that their product water is compatible with water already being distributed within the County. In addition to the public scoping meeting process for the previously circulated Draft EIR, numerous public hearings were conducted by the City of Huntington Beach Planning Commission (a total of five public hearings)and City Council (a total of two public hearings)to consider certification of the EIR. A description of the primary areas of controversy and issues raised during the public hearing process is provided below: Plannina Commission/City Council Public Hearings ❖ Land Use/Relevant Planning • Local homeowners will be directly impacted by another industrial use nearby their residences. • Implementation of the project should not cost the City or taxpayers any money. • If the desalination plant is built, local residents should receive some sort of direct benefit. • Desalination plant may impact wetland area adjacent to the project site. • The proposed project may have lighting, noise, and drainage impacts. • Proposed pipeline construction may impact residential areas. • The proposed desalination facility would extend the life of the HBGS, given that the desalination plant would utilize the existing HBGS cooling water system for operation. ❖ Hydrology, Drainage, and Storm Water Runoff • Storm water runoff from the proposed project site may impact adjacent uses. ❖ Air Quality • The proposed project would result in air emissions impacting adjacent land uses. City of Huntington Beach April 5, 2005 2-4 Seawater Desalination Project at Huntington Beach 2.0 INTRODUCTION AND PURPOSE Draft Recirculated Environmental Impact Report • The proposed desalination project should not contribute to the HBGS's pollutant emissions. • The desalination project should not create fugitive dust or odors. Noise • The proposed project would result in noise impacting adjacent land uses. • All stationary noise sources should be properly attenuated. ❖ Public Services and Utilities • The brine discharge from the proposed desalination facility should be sent to the Orange County Sanitation District(OCSD)wastewater treatment facility instead of being returned to the HBGS cooling water outfall. • The proposed plant's electrical demand should be regulated,as electricity is in short supply statewide. ❖ Aesthetics/Light and Glare ' • The proposed desalination plant would result in further aesthetic impacts to surrounding receptors in an existing industrial area. • The project may result in aesthetic/land use impacts due to nighttime lighting. •'• Construction Related Impacts • The project should ensure that significant biological impacts do not occur as a result of underground booster pump station construction near the pump station proposed in unincorporated Orange County (at the existing OC-44 distribution system connection). This location is situated adjacent to a Natural Community Conservation Plan/Habitat Conservation Plan (NCCP/HCP) reserve. ❖ Ocean Water Quality and Marine Biological Resources • The brine discharge from the proposed desalination plant should not change the 9 P P P 9 temperature of discharge from the AES outfall into the ocean. • The proposed project must not intake or contribute to the ocean bacterial plume known to periodically exist off-shore in the vicinity of HBGS and the OCSD wastewater treatment facility. • The proposed project should not result in impingement(when marine organisms are trapped against screening devices at the HBGS cooling water intake)or entrainment (when marine organisms are circulated through the HBGS cooling water system) beyond existing levels. • Implementation of the proposed project would result in elevated salinity levels surrounding the HBGS outfall,thus adversely affecting marine biological resources. City of Huntington Beach April 5, 2005 2-5 Seawater Desalination Project at Huntington Beach 2.0 INTRODUCTION AND PURPOSE Draft Recirculated Environmental Impact Report ❖ Product Water Quality • Desalinated product water may affect the existing potable water distribution system through adverse mixing conditions, resulting in possible lead leaching or corrosion impacts. • Distribution of desalinated seawater may impact the Irvine Ranch Water District's (IRWD) ability to comply with current National Pollution Discharge Elimination System (NPDES) permit requirements for recycled water. ❖ Long-Term Implications of the Proposed Project • Growth inducement impacts of the project cannot be determined since water purchase agreements with local water agencies have not yet been executed. Growth effects would be most evident in South Orange County. ❖ Alternatives to the Proposed Action • Alternative site locations have not been adequately analyzed. The EIR should include additional analysis of alternative locations at San Onofre and San Juan Capistrano. • The EIR needs to examine alternative seawater intake methods to minimize impingement and entrainment impacts. Agency Consultation Meeting—December 7, 2004 The City of Huntington Beach conducted a consultation meeting for the Recirculated EIR per Sections 15086 and 15088.5(d) of the CEQA Guidelines to receive agency input on potential impacts of the proposed project. Agencies attending the consultation meeting consisted of the California Division of Oil, Gas, and Geothermal Resources (DOGGR), Orange County Sanitation District (OCSD), Mesa Cosolidated Water District (MCWD), and the Municipal Water District of _ Orange County(MWDOC). Issues discussed at the meeting included: ❖ Hazards and Hazardous Materials • As the project area is known to have been utilized for historical oil production use, the project must comply with applicable DOGGR specifications in regards to development over plugged/abandoned wells. ❖ Ocean Water Quality and Marine Biological Resources • The proposed project does not include the installation of a diffuser mechanism (or any other modification)at the HBGS outfall structure. ❖ Product Water Quality • Desalinated product water may affect the existing potable water distribution system through adverse mixing conditions, resulting in possible lead leaching or corrosion impacts. - City of Huntington Beach April 5, 2005 2-6 Seawater Desalination Project at Huntington Beach 2.0 INTRODUCTION AND PURPOSE Draft Recirculated Environmental Impact Report 2.5 EIR ORGANIZATION ' The Draft Recirculated EIR is organized into 11 sections: • Section 1.0, EXECUTIVE SUMMARY, provides a brief project description and summary of the environmental impacts,and the mitigation measures for each impact. • Section 2.0, INTRODUCTION AND PURPOSE, provides CEQA compliance information. • Section 3.0, PROJECT DESCRIPTION,provides a project location,background and history, project characteristics, project objectives, phasing, agreements and approvals which are required for the project. • Section 4.0, EXISTING CONDITIONS/ENVIRONMENTAL SETTING, provides information regarding the existing environment at and surrounding the proposed project site and pipeline alignments. • Section 5.0, ENVIRONMENTAL ANALYSIS, discusses the existing conditions for each environmental issue area. This section will describe the methodology for significance determination and identifies short-term and long-term environmental impacts associated with the project and their level of significance before mitigation, recommends feasible mitigation measures to reduce the significance of impacts, and identifies areas of unavoidable significant impacts after mitigation. • Section 6.0, LONG-TERM IMPLICATIONS OF THE PROPOSED PROJECT,discusses the significant environmental changes that would be involved in the proposed action, should it be implemented;growth-inducing impacts;and cumulative impacts associated with General Plan buildout and concurrent surrounding projects. • Section 7.0,ALTERNATIVES TO THE PROPOSED ACTION,describes alternatives to the project, some of which may be considered during project deliberations. • Section 8.0, EFFECTS FOUND NOT TO BE SIGNIFICANT, provides an explanation of potential impacts which have been determined not to be significant in the Initial Study checklist. • Section 9.0,ORGANIZATIONS AND PERSONS CONSULTED, identifies the lead agency, preparers of the EIR, all federal, state and local agencies and other organizations and individuals consulted during the preparation of the EIR. • Section 10.0, BIBLIOGRAPHY, identifies reference sources utilized for the EIR. • Section 11.0, APPENDICES. 2.6 USE OF THE EIR ' This Recirculated EIR is part of the environmental review process for the Seawater Desalination Project at Huntington Beach. It is the intent of this Recirculated EIR to enable the City of Huntington Beach and other responsible agencies and interested parties to evaluate the environmental impacts of the proposed project. (Please refer to Section 3.6, AGREEMENTS, PERMITS AND APPROVALS, for a list of responsible agencies having approval authority over the project.) This City of Huntington Beach April 5, 2005 2-7 Seawater Desalination Project at Huntington Beach 2.0 INTRODUCTION AND PURPOSE Draft Recirculated Environmental Impact Report Recirculated EIR suggests measures to mitigate potentially significant impacts of the proposed project. 2.7 INCORPORATION BY REFERENCE Pertinent documents relating to this Recirculated EIR have been cited and incorporated by reference, in accordance with Section 15148 and 15150 of the CEQA Guidelines, to eliminate the need for inclusion of voluminous engineering and technical reports within this environmental document. This EIR incorporates the following documents by references, which are available for review at the City of Huntington Beach Planning Department (located at 2000 Main Street, Huntington Beach, California): City of Huntington Beach General Plan EIR, 1995 This document addresses the environmental impacts of General Plan buildout, including development of the proposed project site, as well as analysis of cumulative and growth-inducing impacts. Huntington Beach Generating Station Phase II Environmental Site Assessment,November27, 1996 The purpose of the Phase II Environmental Site Assessment (ESA) performed at the Huntington Beach Generating Station (HBGS) was to evaluate the environmental condition of the facility by investigating site features that have potential recognized environmental conditions. A secondary objective was to obtain initial information pertaining to the nature and extent of air quality compounds of potential concern and to identify areas that may require future investigation or remediation. The project site is located within the study area limits of this assessment. City of Huntington Beach General Plan, 1996 The General Plan for the City of Huntington Beach is a policy planning document which provides the framework for management and utilization of the City's physical, economic and human resources. This document guides civic decisions regarding land use,the design and/or character of buildings and open spaces,the conservation of existing housing and the provision of new dwelling units,the provisions of supporting infrastructure and public services, the protection of environmental resources, the allocation of fiscal resources, and the protection of residents from natural and human-caused hazards. City of Huntington Beach Local Coastal Program, 2001 In accordance with the California Coastal Act, this document consists of a land use plan, zoning ordinances, district maps,and other actions which,when taken together, implement the policies of the Coastal Act at the local level. The Local Coastal Program allows the City of Huntington Beach to have jurisdiction over Coastal Development Permits within the coastal zone portion of the City, as would be applicable to the Seawater Desalination Project at Huntington Beach. Southern California Edison Huntington Beach Fuel Oil Storage Tank Removal Project Environmental Assessment, April 20, 2000 The Southern California Edison Huntington Beach Fuel Oil Storage Tank Removal Project Environmental Assessment assesses the significance of any environmental impacts associated with the removal of numerous high capacity aboveground storage tanks used to store fuel oils. City of Huntington Beach April 5, 2005 2-8 ' Seawater Desalination Project at Huntington Beach 2.0 INTRODUCTION AND PURPOSE Draft Recirculated Environmental Impact Report Information regarding existing environmental conditions,site status,and tank capacities exists within the document. ' Phase I Environmental Site Assessment for Edison Pipeline and Terminal Company Huntington Beach, May 2000 The Phase I ESA for Edison Pipeline and Terminal Company(EPTC)Huntington Beach identifies recognized environmental conditions as defined bythe American Society for Testing and Materials (ASTM), with regards to hazardous materials. In addition to recognized environmental conditions, the document identifies"areas of potential concern"to address those environmental issues that do not specifically meet the definition of a recognized environmental condition, but may warrant further investigation. The project site is located within the study area limits of this assessment. ' 2000 Regional Urban Water Management Plan, Municipal Water District of Orange County, December 2000. This document analyzes water supply and water use efficiency measures unique to the Municipal Water District of Orange County's (MWDOC) service area. It also summarizes the current and proposed water management activities of MWDOC. AES Huntington Beach Generating Station Surf Zone Water Quality Study(Final Draft), 2003. ' Komex H2O Science Inc. prepared this document for the California Energy Commission(CEC). The CEC required this study as part of the HBGS's retooling project. This study included an intensive water quality monitoring/dye study program that was conducted during the summer of 2002. This study was performed to determine if the HBGS was a source of chronic fecal indicator bacteria problem in the surf zone near Huntington Beach. Samples were collected daily from a number of locations at the HBGS from mid-July to mid-October. In addition, samples were collected every three hours from four locations during a two-week intensive study. Data were also collected in the ocean near the intake and outfall of the generating station. The study found that urban runoff from an area adjacent to the HBGS that is discharged to the discharge vault of the HBGS contained high levels of fecal indicator bacteria. Because the urban runoff is blended with cooling water from the HBGS, the HBGS discharge contained much lower concentrations of fecal indicator bacteria. A dye study was also conducted to determine if the HBGS discharge has the potential to reach the surfzone. Dye was injected into the discharge vault at HBGS five times in one day in August 2002. The dye surfaced over the outfall and then spread radially in all directions. The average dilution between the discharge and the beach was 277 to one,while the lowest calculated dilution was 36 to one. Based on the water quality sampling and the modeling studies, Komex concluded that the HBGS was not contributing to the beach contamination problem. Integrated Water Resources Plan (IRP), 2003 Update, Metropolitan Water District of Southern California, May 2004. The original 1996 IRP provided a 20-year resource plan that brought a balance between locally developed resources and imported supplies. It called for investments in water conservation, recycling, groundwater treatment storage and water transfers, and in return brought diversity and stability. The 2003 Update builds upon the original 1996 IRP in an effort to ensure that the original vision of reliability, diversity, and flexibility continues to be successful. The 2003 Update had three objectives: 1) to review the goals and achievements of the 1996 IRP; 2) to identify changed conditions for water resource development; and 3)to update the resource targets for 2006. City of Huntington Beach April 5, 2005 2-9 Seawater Desalination Project at Huntington Beach 2.0 INTRODUCTION AND PURPOSE Draft Recirculated Environmental Impact Report Water Quality Control Plan, Ocean Waters of California (California Ocean Plan), State Water Resources Control Board, 2001. This document serves to protect the quality of ocean waters for the public's use and enjoyment through the regulation of waste discharges into the ocean. The Plan establishes water quality objectives in regards to bacteria,physical characteristics,chemicals, biological characteristics,and radioactivity. It also provides methods/programs for the implementation of these water quality objectives. It should be noted that an amendment to the 2001 California Ocean Plan(in regards to "indicator organisms"and"quality-based effluent limitations")is proposed and has been circulated in draft form.' California Water Plan, Bulletin 160-98,State Department of Water Resources, Division of Planning and Local Assistance, 1998. The Bulletin 160 (California Water Plan) series assesses California's agricultural, environmental, and urban water needs and evaluates water supplies, in order to quantify the gap between future water demands and the corresponding water supplies. The series presents a statewide overview of current water management activities and provides water managers with a framework for making water resources decisions. Much of Bulletin 160-98 (the update of the Water Plan performed in 1998)is devoted to identifying and analyzing options for improving water supply reliability. It should be noted that an update to Bulletin 160-98("Update 2004")has commenced and a Final Water Plan Update is anticipated to be complete in April 2005.2 2.8 TECHNICAL REFERENCES In accordance with CEQA Guidelines Section 15148, the Seawater Desalination Project at Huntington Beach Recirculated EIR cites appropriate technical studies and other reference documents, as indicated throughout the EIR and listed in Section 10, BIBLIOGRAPHY. These technical studies are available for review at the City of Huntington Beach Planning Department located at 2000 Main Street, Huntington Beach, California. http://www.swrcb.ca.gov/pinspols/oplans/ 2 hftp://www.waterplan.water.ca.gov/bl60/workgroups/chapterreviewgroup.htm City of Huntington Beach April 5, 2005 2-10 � 3.0 PROJECT DESCRIPTION i 1 1 1 1 1 1 1 i 3.0 PROJECT DESCRIPTION ' The proposed Seawater Desalination Project at Huntington Beach consists of the construction and operation of a 50 million gallon per day(MGD)seawater desalination facility by Poseidon Resources ' Corporation. The proposed facility would be located adjacent to the Applied Energy Services Corporation (AES) LLC Huntington Beach Generating Station (HBGS), within the southeastern portion of the City of Huntington Beach (City). The proposed facility would convert a fraction of the HBGS' condenser cooling seawater discharge into fresh drinking water using a reverse osmosis desalination process. Source water for this facility would be taken from the existing HBGS condenser cooling-seawater discharge pipeline system, which is permitted to circulate up to 514 MGD of seawater. The historical maximum flow rate at HBGS has been 507 MGD. After the ' seawater passes through the HBGS' condensers, the desalination facility would intake approximately 100 MGD of HBGS' cooling water discharge and produce 50 MGD of high-quality potable drinking water for use by residents and businesses in Orange County. The remaining 50 ' MGD becomes concentrated seawater, which would re-enter the HBGS condenser cooling water discharge system downstream of the desalination facility's intake point and blend with up to 407 MGD (507 MGD of historical maximum flow minus 100 MGD of water diverted towards the ' desalination facility) of HBGS condenser cooling circulation system flow for dilution prior to discharge back into the Pacific Ocean. 3.1 PROJECT LOCATION The proposed seawater desalination project site is approximately 11 acres in size and is located at P p P 1 PP Y 21730 Newland Street. The City of Huntington Beach is a coastal city along the Pacific Ocean in ' northwestern Orange County. It is surrounded by the City of Westminster to the north, City of Fountain Valley to the northeast, Cities of Costa Mesa and Newport Beach to the east,and the City of Seal Beach to the northwest. Los Angeles is located approximately 35 miles to the northwest while San Diego is 95 miles to the southeast(refer to Exhibit 3-1, REGIONAL VICINITY MAP). The site is bordered by a fuel oil storage tank to the north,the Huntington Beach Channel (a facility ' operated by the Orange County Flood Control District[OCFCD])to the east, HBGS facilities to the southwest,a wetland area to the southeast,and an electrical switchyard to the west(refer to Exhibit 3-2, SITE VICINITY MAP). ' 3.2 ENVIRONMENTAL SETTING ' The subject site is situated on an unused fuel oil storage tank area formerly owned and operated by Southern California Edison (SCE). In 2001, AES Huntington Beach, LLC acquired the property, and, upon project implementation, would lease a portion of the property to the project proponent, Poseidon Resources Corporation (refer to Section 3.3b,SITE LEASE A GREEMENT). The storage tank area contains a total of six tanks, ranging in capacity from 924,000 gallons to 8.64 million gallons. Implementation of the proposed project would require the demolition of three of the six tanks(three fuel oil tanks). The three fuel oil storage tanks to be demolished have historically been ' referred to as the South, East, and West fuel oil storage tanks (refer to Exhibit 3-2, SITE VICINITY MAP for the precise location). Each of these storage tanks is 40 feet high, cylindrical in shape and surrounded by 10 to 15-foot high earthen containment berms, pipelines, pumps, and associated ' structures. On-site vegetation consists mainly of non-native low-lying shrubs and bushes along the eastern border of the project site. The topography of the site is relatively flat, gently sloping to the southwest,with an elevation of approximately five feet above mean sea level (msl)(refer to Section 5.7,AESTHETICS/LIGHT AND GLARE for information on views of the existing site). Section 4.0, ' City of Huntington Beach 3-1 April 5, 2005 Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report EXISTING CONDITIONS, provides additional information regarding existing conditions and environmental setting. In addition to the desalination facility site, the proposed project would also include several related off-site improvements, including tie in pipelines between the existing HBGS condenser cooling water discharge system and the proposed desalination project, up to approximately 10 miles of product water delivery pipeline and two new underground booster pump stations. The intake/discharge pipelines would be located entirely within the existing HBGS site, and would not require modifications to the coastal/marine portions of the existing HBGS ocean intake/discharge facilities. However, it should be noted that the existing HBGS intake/discharge facilities traverse land owned by the California State Lands Commission (CSLC), and the land is leased to AES. A lease agreement between the CSLC, AES, and the project applicant may be required prior to project implementation. The product water delivery pipeline would be up to approximately 10 miles in length,extending from the proposed desalination facility to the OC-44 water transmission line within the City of Costa Mesa, east of State Route 55 (SR-55)at the intersection of Del Mar Avenue and Elden Avenue. The majority of the pipeline alignment would occur within existing public streets, easements,or other rights-of-way(ROW)in urbanized areas. Although precise pipeline alignments may be modified during final engineering analyses,the conceptual pipeline alignments are shown in Exhibit 3-3, CONCEPTUAL PIPELINE ALIGNMENTS. Two off-site underground booster pump stations are needed as part of the distribution system. The first off-site underground booster pump station (the OC-44 booster pump station)is proposed to be located within an unincorporated area of the County of Orange along the eastern border of the City of Newport Beach, within an Orange County Resource Preservation Easement but outside of the Natural Community Conservation Plan/Habitat Conservation Plan (NCCP/HCP) delineation zone (refer to Exhibit 3-4, OC-44 BOOSTER PUMP STATION LOCATION MAP). The second underground booster pump station (the Coastal Junction booster pump station)would be located in the parking lot of St. Paul's Greek Orthodox Church,at 4949 Alton Parkway within the City of Irvine (refer to Exhibit 3-5, COASTAL JUNCTION BOOSTER PUMP STATION LOCATION MAP). 3.3 PROJECT CHARACTERISTICS The proposed project consists of construction of a seawater desalination facility to meet the needs of Orange County. The proposed desalination project would consist of seawater intake system, pretreatment facilities, a seawater desalination facility utilizing reverse osmosis (RO)technology, post-treatment facilities, product water storage,on-and off-site landscaping, chemical storage,on- and off-site booster pump stations,and 42-to 48-inch diameter product water transmission pipelines up to 10 miles in length. This section presents an overall description of the proposed project by summarizing six basic project characteristics associated with the desalination facility: on-site improvements, the proposed desalination facility's association with HBGS, off-site improvements, desalinated water distribution facilities,quality of potable water produced by the desalination facility, and facility operations. A. ON-SITE IMPROVEMENTS The proposed project involves the implementation of a desalination facility producing approximately 50 MGD, or 56,000 acre-feet per year (afy) of potable water. The project would require the demolition of three fuel storage tanks and the remediation of any soil/groundwater impacted by contamination associated with previous site usage as a fuel storage facility. In addition,the existing interior berms would be demolished while the existing exterior berms would remain as is. On-site structures would consist of an administration building, a reverse osmosis facility building, City of Huntington Beach April 5, 2005 3-2 S i I L O S AN G E L E S i ' COUNTY ' an © Burbank ' .�. B Azusa Glendora © Pasadena / Rancho Fontana 101 Cucamonga Rialto West Porno a Ontario Covina -- --�_ Chino Los �, � �,i Riverside Angeles ® Whittier -- ® Chino Yorba Hills �—' Linda Norco �+► rr� r © Fullerton Corona Torrance 0 Garden Grove® O R A N G E i Santa COUNTY Ana Irvine ���1�� � x =.. ' Costa ' - Mesa Lak 60,1iun�il ib ���a m $ � ". Elsin m � hk h W � San Juan p - ` Capistrano i �f -y v' A,S Y aw IIMI � �' a 1 USMC lE.r 'lP h7�'ANN 1101 0L Camp Pendleton Subject Site ' NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH Q Regional Vicinity Map CONSULTING 02/05•JN 1 0-1 0140 9.002 Exhibit 3-1 5 ' 4 ' i 8,1213 . . 6 , a 4p.f Mf y Iw S El . 1-Huntington Beach Generating Station 6-Mobile Home Parks 11-East Fuel Oil Storage Tank 2-Pacific Holdings Storage Tank Facility 7-Open Space/Wetlands 12-West Fuel oil Storage Tank 3-Ascon/Nesi Landfill 8-Project Site 13-North Fuel Oil Storage Tank 4-Edison High School 9-Distillate Fuel Storage Tank 5-Edison Community Center/Cannery Street Landfill(closed) 10-South Fuel Oil Storage Tank NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH Q Site Vicinity Map CONSULTING 02/05•JN 1 0-1 01 40 9.002 Exhibit 3-2 1� !I 1=1 man M momMill M m 4w " i t1 ?tl €P •"« #; et« a �wr » ''T � � '.'� ,n,*� ��� AV ma«a a'€a ,€f♦ '. � 4�w^c a , fy € c r4. " :a '','a� J..,,. .,,� ,° _ +} • °' tr 0MMARy rd� a�ita<s: , *Y nwr 4tr�� ' plr We 3 DIAMETERAl Mw a _ _ araxx 'wa` wawta + ' p } ,? & . TMIMAItY 3! I "y� '. � i'. C s► - y 3'� #4 to it � r 1 N H i€ € •R €'3k t t `41 42 4$ Ic <w DIAMETER ..,. : �tx v } :� $, t l iF f l ALT, E YIirE OSTA � .. .', Az a *Samoa /1� 41.a�atr r`rie■ r ■ia " MMMk rs•w.��r t 3i FCrG17a1 tint '' 1 tt _ Hamilton enye" t . , t• t• ' wwwm=w Ww owww wlww' sawlFw i M�#€>•s '�`3r` ,�..." r< 8a a I.: "'` r ., � 'Sra `' ,^�, a � .,.� �r 3 € .'N€ t' @ r x 1I�., + 44&tut'ua,a r e .� 3 a € a t. r.= V3' + { } R 4#; POSEIDON RESOURCES CORP. Aw A ' SEAWATER DESALINATION PLANTS f� 41, naafi =a AX AES HUNTINGTON BEACH ' � � � 't � . GENERATION FACILITY ?, �• �. vx 14 Source:Carollo Engineers,August 2002. NOT TO SCALE PSEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH "' Q Conceptual Pipeline Alignments CONSULTING 12/05•JN 10-101409.002 Exhibit 3-3 x t �'! ,�`� '��;.;3"-x '. "'�' r �' _ K'v �• eta .«,«^� € .3�ry�.-�, � •�i,u�4-' �"`! ,yi .-'-z-.:`} �' „h' � A�`. :�i(: ��`F+,•t �r � �.#- � 6 R °f:5'B'.,p,^<S�,a i 1 i 1 • 1 � �; R3 a « IT- a '+lc(�i°,`Sy{iw i i'�+v. .�7� _ -4 § " +�,• ,.fir t '�`-ae Aw «< n. �:»,,,, .kaF. , ,�,.. .„ J>,,;°•'L'y r•...;-,�i ;'-�'..,.,.,,•, :x � 4`5, a:,...,�4.x (L Via*- � ":', v '' .t ;� �•" z,::s •�r P `;..'1, L �- �y`E`OY B. '��'• ,j� L .��" !m. � ti 'q^.. '"•'.� . - .,` €�sty '�.�� ', '� § \, .`.-. r....,.;}'y� � k;`,�,s'��. � -_.. (hc�a �.:> �'•M.4G �_ Y�i#�r3�Fg. '� ;+. A 4g�: x��a',P�u:. /Mi ``.:'*. i> ..`..'atr> > 'its,-,.,. _..q��P`'�fa2 ,.�. ^r �y �-r�• � ��i#�� tsI6F'tAbY4 .,*a.x r� � �e� '� �s:_ 1, -. Y �' � �„fy�,",�r.°A�"aKAFyF'b:i' } .p• x � al �',. , Npw - I ii �``a ;it4 �1'`r�.�k, ,f ,: ,..,",.,, +:t 't�.w�.�i�'� �j c..�.,. •:••.�.!�yJ-,IwS+`'a. �,� a `>�"�, ��'�g� � �� � tip:., a•; � ., ,.,��,. ._�.�'&„•J,;;,, `x :- - .^y-» ....- • _ .�.:, ,g.� �:.:,.+ ,� � t< . \may , ,,, �..s.., f(t�` .- �, .•..{ .. r y 1-53..!r l A R •fir x. a r}r y J/ y'1r�.. � -. n x 1Y •... � � _p ;, Ira r`•.�w <Lt „.�;<, �,, �s; y. x`.� , ='drat""r .;�� i � � �'� �-Y; 'o'� "`.s F�§-� �;� 4 {` ,-.yr'�� ,. d '�� :'�{•�Y.ir��;it, :d"„ 1 i5k +"',. -�i'y `ir. atp;r£.�'� .SJ+��3 r ,r S 3 �:g� 6` ,.«� �,.«:_ ,�•+v.: ��d "'.r'a,:'`� `'�"a'�,�.. `�:. "+�; �}• •"+��r'r1ti :� ea.? x � f- � kb ,�.a a�',��.a ` :. ,y ."�„'f"�' "'"- '.•rpr. �3.rey` b«.,... Y. N /J '.r�.�«' '`^� a„. " r,.FA,. � a:�.,-` < �; �t ,�r�ff xs-"" �-�., t'� ' �..• '?�.,'T i�`+{-,�fcr{h,a?�.ajd#'i��t`' ..:F � 'yg.��.���x4 �`X- «.�.. •a'` d, / "�..::,a �.* " sM `` - � �q*�;i�a'':'.a �<•r�.-`'`}���.?�• ."Q�l'�L •r# r '�.�.•� ;T wt�: �, �`',�` .�s: �``1v�•.i.s r'����Ct...�. - ;�� �;,s�:�'� r,. �,',,�'i>�+5. < } Y�� 4''., y+ti�5� ....4��t .;�'�'� ��.yir.._}tV.� '.V; K, .. �� ii �a;S=(��.� �{� s�. .. q•.#� .v �� > 1' t4'� v,'�. '. .... >F'4 e '��y.�y +,a`„r d.,i ' ' � �, s•a,`-„3 a` , .'. ^` :ye r.,yf.. � e}.., �.F:,j 4+'.``s�!y I,`. -�:'���x`s�`.x.,°''�..Sy"` '-/ '!•,J :,p ."�.* � �.i..� �a Fix .� i"� •. � �•a .,. ��+,"'v..�. �,, - q •t f j....� ,r��' �h�:: � 4 ; ,tea- �m }�d - '� � t�'�. 1. �,, °'�?}y'^ ,s't �"��4.1r '� # �1` t,�. ,fir'��;! ��ti � �.. f ,� " � -�.�<" •* *!tom _.- � v n' y<�'-.:;•� ,.q „y'§:a,,,i�• A4�� $�: -,�� .:� -'�i�!w -�' r a.,+' g �.'�r .a=*,» �k � v.>m-r =. x� ��'�`'`i+! .>:. ��:...�� 9.t_..y.. ;�. r� �' t a r� • >`TM} ?.:�� �:.�'x t� jJ .eY �Jf "'rm %.,"+ a'"`*'°` `'} �St ',ti.�.�k` 5�.. n`- t"•-T'..+i •�"'�- ay`��e; '�. Y'J,v„ •,# 9i � icy, e;-�� ''� �' .�„,».. ��4 .•�}!' ,L� ..+',:�,, 1'ri::� :s`,a f r w '•c�,�' ��',��" .•a� r'.ai ��`�?d�' ?� + .� ¢ice - r. �. �' 5,..�. .;�Yix �:.t>i. - .�.n`•F,'. ' �1" •.y }�t" 3 a ��. .�,,�- �� -.''q. _.L �� �'L¢�r g- :. .::,•. A�ic. - 1 stir,, �' •'. �.,�r., - ., j�c � ";."yt .� �'' {:` '� � .e ".�'�' �_ � 1` �:: _�_4.. ��,�e,,'�"�'�,.:J:N.�J�' PS r.. a' :,`.Y..�qy�.'>t�;°�k i,. .. t&. �:�..:; > •� A,.Y,,v t :.,. i' .��.,,,,. �� tP�'�-�ti.2.;.. �.c:'v�i.v..!s3._..,•.',x,��', -:�:�-�.%��rn'..`.,,`.�"II �s;r;.�i *►��: - as,.�:�'`� � � .�,`s�..�^+ ... -*,�^.: rs�•4. � ' 1 1 �q :4 i I 1 11 it I I 1 r �' s b �y, }*a t•' ¢. =ar. _ t ` . I"x ° « Y . it ,nyWf,�g,a��7 'e��`` ?` ,�'w�"ayr,, � �1`, h't �. .,�- ��+ �C s^z,, aim. a4 s `e T �•,a{c# r , 'rt}`��'`v , r � `. � °`�"?.; � �: �.�•,. - -J u'§, :+' a» S Awe�• :°,:: �";� _'�`"°!4`°.� - t al�'��°S , :� gc v»',��� ,.:�;,: >t� 1'<. '� ..a- �+w,. , � ,£�_.. ��,t����, <.t'+�zk' .ram•' >r;.,�,a �?}.:r,1-tip/ �1.. eu a` � °.,q ay��4. .�..,•y ,fde'' :r �'c. �::.� � � ,#..?. ' J!`... "'="R°',. t r.s,:--.s,fib - ��at •�+ " 'x"",,.,{ �;,s •�,r�' :,:�.;,,�. .�.. �,... °. p�«,,a:. ;,«„<.. �1; 'h ..r.*' "u,� r^ ''� o-..'� r :�,« .5��„^ °?l,. �. "'"+§.<�".`"�'�"/ '$x4 ! I K ,: �N.a .�: 'x <:x tl.. ,..r�RP!`_�, .. -✓., < ,°«r_..'✓ ,x ,. T�" a .��'t,'n r��, i 4� �1� b1d� `'''fig{ i t + .?<,.1 m"'. ��T ��`.,A , (`" �5 �' .zrH�. "�': s.- �, �.:" �,+•a"i.",+. r`w�. „7<>:., k t � :: ,., .. ��''4 '�w q+'� � '�� m er*,°�i�, r. t y, a x emu,•;' ;�.;a=,-:+ _. ty�",s � `4 � ,= , .' "i k.�S.q �L;q � '� �d, � ,t�' m...<:� � '�»="a•..'' s;' ',�.'.., V �*.�`• t3��, "'�, f�a;` ' '9 -.�r•'+«��' '�.JI�t�° �Ai z � '�" C � e ,'++ � �,,� �s � t. •,� •'�` , c. � Cam:_ � ..>; e F� :. �° � „e<<R " .� -a,<.<< ''.��'/1^ �!�~~, , �s»"� 1� _ 1.. tc�. h ►T�- b'�.��`�-r,:'�'�'.°p �q, n"w �rrk�- $' � 3 mac. �,`• ,x�p ,� d d s., ( �'"'.„;.. "Y-a.. 7"} r. .• � .k �<���'»^:°:7 a a�, x�� �`{E .'�' �:"w �a �11 ';. ���»ff� a,•e�a �„s' h• >2 �4 'yl ti. s4F�- - s w s ! � � ''Rgu s,i �,�!. �'•' � �+, ww � � £�^ x��� ", ,-� wed ""^•a ':9r`.�' ''r`K,.,, ° v ,4 _Y_.f� * x ,.s..«• r-:'4 i<;1` .•�'�'. ,sl,'.!: '�K i<'r ,.+. yJ: !'�x+£��":�•'�'",�$,.. „�..,.y4 c.�, ,� t. `5 r � .:_ .5 � ��'I .t'"' Yr- ..rs� �. i � �_ �.� t"•.q.. "�v�., <� '�`"fix �. F r,.'}• ,::�� ;,� �'`F�3,f�4.+.." .-.r�o-'Tj 'sue„ �' ,riy�i<.r�".. �y.,+U %t.'�.�`� '"'i• �:�'� �re'�'�+y L a "`� s�1�,? s �Y:' C{" 4 d..w�'�- ax`e.;��_. .;: �h'�.7.,.�,,, ...' # i, �a:�; .5.;. '�tw:;!1'!3`� e!�«.,�� �.t '�S ,^, '•I� ,•i� x '` L�'•Lv. �S 8ya{ 't. s r j.,, +,�,.�, 4� ,�" ..:.� �«g�� •�i"'`= �-,�:�` (1 �*>�, �'`Via`' `s� '',Qr� y, ,Y€�,,-� ales-'s ...;t. .,.:.t, .Y s,' ,^« �.# -s t �sr;a gly. �..,t: ^<r'- � i,i- �•��,� � «I•.:x��.«• ��,* trT 'v� �i� *t�:ap�•py,{���"./`� -r+,.e� 1•*. {tk���f��. �`'+�` ..W.� eel'• F � :' •y�"•$• '¢ b.„.ky°}4' gna...» •�. 'SM'.., � *� -,_.. " �v � f� #,�•.,.,� sr.:F, < '��fl„��a:�' t��a, }� a�i'xd` '�,t �p, r;t6' .�. '�*+ Y;. � .a� ,• ,; ""i?a�; .�. �� r :"+sat,}.. -'m"�l-�Y+ �„ ,'�3I"' `'".aa".K�„ �r� n, } `"�' '*"� d•�' fiT? �r� yu��y. ;� �y�$'�: :• ._ x� � w..�,.»< �' yf' i f c AO 5 4 ,xy rt A AK i I+r r* t Jwo ; , �.+ ♦ x3=- r'a:`�;�'.�; �``�' .-- �_.`"' �� .srla .�."���".x�.�tt:::.":.f-;1:1`���� r°•.` lr r� +',k +. t I� _. 'r r«>r�.#,.>• • a. s3# i.Vc 5t :`1, M1'+<5.,+ v _ "7 iv "�'... 1 11 1 1 1' 11• ' w � Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report pretreatment filter structure, chemical storage/solids handling building, bulk chemical storage building, product water pump station (situated underground)and surge tank, rinse tank, lime silos, wash water tank, ammonia tank, influent pump station (situated underground), an electrical substation building, an aboveground product water tank, and appurtenant facilities (refer to Exhibit 3-6, CONCEPTUAL SITE PLAN). Proposed Buildings and Structures All proposed buildings and structures would comply with state and local standards in regards to fire and structural safety. The proposed desalination project would consist of the following buildings and structures: v Administration Building (approximately 158'L x 64'W x 18'H, 10,120 s.f.): This building is proposed to be Type-II, non-rated (generally defined by the California Building Code as structures incorporating non-combustible materials (steel, iron, concrete,or masonry]for structural elements,floors,walls,and roofs)and would be constructed of steel. The exterior would feature flat metal wall panels running vertically along the face of the structure. A metal panel roof system would be screened with a metal fascia using deep-ribbed metal panels running horizontally. All glazing would be tinted and would include clear anodized window frames(refer to Exhibit 3-7,ADMINISTRATION BUILDING PLAN/EXTERIOR ELEVATIONS). ❖ Reverse Osmosis Building (approximately 293'L x 130'W x 25'H, 38,090 s.f.): This building would be a Type-II, non-rated, steel-constructed building housing the reverse osmosis components of the desalination facility and associated indoor pumps. The exterior would feature flat metal wall panels running vertically along the face of the structure. A continuous metal reveal band would be placed mid-height to break up the 25-foot structure vertically. A metal panel roof system would be screened with a metal fascia using deep-ribbed metal panels running horizontally. Full height louvers would match the wall panel color and would be recessed slightly from the face of the structure to allow for shadowing. Panel coloring would match the Administration Building (refer to Exhibit 3-8, REVERSE OSMOSIS BUILDING PLAN/EXTERIOR ELEVATIONS). ❖ Pretreatment Filter Structure(approximately 196'L x 195'W x 16'H,38,270 s.f.): This open-air structure would house the pretreatment filter components of the facility. It would feature concrete walls matching the color of the Reverse Osmosis Building. The concrete walls would stair-step in elevation to a peak that would be finished with the deep-ribbed metal panels running horizontally. These panels would match the fascia of the Administration and Reverse Osmosis Buildings. A painted band would be included to match the reveal band of the Reverse Osmosis Building (refer to Exhibit 3-9, PRETREATMENT FILTER STRUCTURE PLAN/EXTERIOR ELEVATIONS). The influent pump station (to be located in an underground vault) would be situated adjacent to the Pretreatment Filter Structure. ❖ Solids Handling Building (approximately 170'L x 50'W x 21'H, 7,590 s.f.): This Type-II,non-rated,steel-constructed building would house solids handling equipment associated with facility operation. The building would architecturally match the Administration Building, featuring flat metal wall panels running vertically along the face of the structure. The metal panel roof system would be screened with a metal fascia using deep-ribbed metal panels running horizontally (refer to Exhibit 3-10, SOLIDS HANDLING BUILDING PLAN/EXTERIOR ELEVATIONS). City of Huntington Beach April 5,2005 3-8 Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report ❖ Chemical Storage Structure(approximately 112'L x 39'W x 23'H,4,368 s.f.):This structure would also feature Type-II, non-rated, canopy steel construction and would house various chemicals stored in bulk. The metal panel roof system would be screened with a metal fascia using deep-ribbed panels running horizontally(refer to Exhibit 3-11, CHEMICAL STORAGE STRUCTURE PLAN/EXTERIOR ELEVATIONS). ❖ Electrical Room/Substation Building (approximately 60'L x 30'W x 12'H, 1,800 s.f.): This Type-Il, non-rated, steel-constructed building would match the Administration Building architecturally. The exterior design utilizes flat metal wall panels running vertically along the face of the structure. The metal panel roof system would be screened with a metal fascia using deep-ribbed metal panels running horizontally (refer to Exhibit 3-12, ELECTRICAL ROOM/SUBSTATION BUILDING PLAN/EXTERIOR ELEVATIONS). ❖ Lime Silos (six tanks approximately 20' in diameter and 25'high,314 s.f.): The lime silo tanks would be arranged in two rows of three tanks each within the northern portion of the subject site in an area approximately 80 feet long by 57 feet wide. These tanks would be placed within an open air,welded steel structure incorporating aesthetic treatments to enhance the character of the site. (refer to Exhibit 3-13, STORAGE TANK PLAN/EXTERIOR ELEVATIONS). ❖ Washwater Tank (approximately 45' in diameter by 19' high, 1,590 s.f.): This single tank would store washwater and would be constructed of steel, painted to match the surrounding buildings and structures. The approximate capacity of this tank would be 200,000 gallons (refer to Exhibit 3-13, STORAGE TANK PLAN/EXTERIOR ELEVATIONS ). ❖ Rinse Tank(approximately 25'in diameter by 29'high,491 s.f.):This single tank would store the desalination facility's rinse water and would have an approximate capacity of 100,000 gallons. This tank would be constructed of steel and would be painted to match the surrounding buildings and structures (refer to Exhibit 3-13, STORAGE TANK PLAN/EXTERIOR ELEVATIONS). ❖ Ammonia Tank(approximately 6'in diameter by 6'high,28.35 s.f.): This single tank would store ammonia and would be constructed of high density polyethylene or fiberglass reinforced polyester, and would have an approximate capacity of 1,000 gallons (refer to Exhibit 3-13, STORAGE TANK PLAN/EXTERIOR ELEVATIONS). 4. Carbon Dioxide Tanks (approximately 7'8" in diameter by 57' long, 1,482 s.f): Two tanks would store carbon dioxide. These tanks would be constructed of welded steel and would be painted to match the surrounding buildings and structures. The storage tanks would be double-wall vessels.The inner vessel wall would be made of high-strength carbon steel,while the outer vessel wall material would be aluminum or structural grade carbon steel (refer to Exhibit 3-14, CARBON DIOXIDE TANK PLAN/EXTERIOR ELEVATIONS). ❖ Aboveground Product Water Storage Tank(approximately 215'in diameter and 40'high[30'above grade and 10'below grade]):The aboveground product water storage tank would be circular in shape and would have an approximate capacity of 10 million gallons. The tank would be a steel structure (refer to Exhibit 3-15, PRODUCT WATER STORAGE TANK PLAN/EXTERIOR ELEVATIONS). The City of Huntington Beach April 5, 2005 3-9 �C - _ ST�..R�ATIaO N.�.- -� r LIDS, HD L1`NAQMININ `SO BUILDING `°-%CIO TRE . 0/S U —PARCEL `� wCH I L7 TRIGL STORAGE, as 6ts "... NED} - (CONTAI _. W. NN I { _ mm I RO BUILDING 47, 130y OSCAPING ...., '-� 1 ,,• _ I § iANWALLy _. INFLWE fT, PUMP STATION Y q ff ,� -�i 41.1 '9 ftf �� 1 °�� ! t���� /� z 4,�{� •»mallE�. ��+�^.} 17 LV I�G A 7t FEED LINEZ i v -tu - s.. q I(V1Jf7, • _..,_. „ : is ... <� `� r ^`o° ,T� � �t�i ENC RED f ,1 tM^..<,,,y,a... ;': � 0: w".`...;.,-• a,__ _.s - •'" f', "] .r„S �"Y"F .,'`.... �...''z » p "✓ ',, <." „: `` `'_: r't; r f ' TANI ,rJ.SdY r1 + ""'+. tQa�.^` syiv-, ,y . - >x k: RI • E,}» S , , _..__ _._ ;• t / ' lH`,TAfVK' ' f B `,`. �� t i r r' ..•w ! a -�. q ... t r- s? /rr. - ,r rF- /F". .f,' .w`,Y +.,.^Y'' \, A, p ELECT„ RICAL a r LI1E,' r�-,:..i ��a_ jt§i� � .,��"i. �' � ^1.:. ,✓ / ✓ F' Ae� �� ,`.,��,, / r �°""F'. '-,/ a j{ "�`1\ ? I PI}NW......._.W,.._g Ihr STOf2AG TANKELECTRICAL aM Y p / (6 F0 T D,IA} ¢ [ ('• :' " ✓fa, �: �,>, r:r; J,, j t ' "' ', l`' r: f ft`/ C AINEQ 7i r ti ~` ,� , �/ IC? ` } _ .... z, PRODUCT WATER � ` r � �b � PRODUCT WATER STORAGE TANK i PUM STATION } 115' _ � o �§ �. `007 ' „ vrr Sa' „€ t . r T SURGEE. `' i� ,Jk,Q� „,._i' _ "'r'.C-1. r, .Mr 3 t+j `iV'•. ..� `Q'",.� :� �z�d 1�7r' .-'E "�1(� (�..'3 r It »A ��.. > V I ',...a y 48"-PRODUCT g t�f�e�yy �r{ �i\`, ., z- +�r•: �."� ' :`;- r'` ..�'b ... ::::"4'-7. E i ,�. 'u1�7ESILC�J, TER LINEr 4 SS' c�° Iw' ::. r`W„k 2a '! ,P;W a..i: �:e _ (1WN,jj _ TA _ f1s, . o,- ° ., .^ "-'-ULTIIAATE�-�✓� - e�`!)� „. "y'�r";�„ - l .0 ..,^,�r' ",f! °.✓y>:" _.n ,.�-.:.. t,i®-, - w_. ��,� ------__ — _— - ... CARBON DIOXIDE TANKS Source:Poseidon Resources Corporation. J I NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH Conceptual Site Plan i s a r 4 C 13NB u LTI NI3 02J05•JN 10-101409,002 Exhibit 3-6 r^,AT ' �Yt RRFfit t 1 T�Ts`F<1`i CEIi Y Y„ }'y ' "alETAI,F LIA".`,!vR 1� - ,• a - 01 METAL MAN DC)OR fl EEL( NIO t 77 �- �c F`, r ;�d , � A:1 f ✓ f { k _. =�_. IN FOR CRC)U\D{SHOWNREVEAL I f f f a s �r a: ti IR H ELEVATIOI\ ti t>ttlti 4'C E. rwl T.j $( n i P y SOUTI•I ELEVATION T T1 IN -1 ffi� t ��+.��. .:v� p h� � rt". pg .. �'a=� ..e•.\ �k _.,.�..,-, �F�J €3�.ia,•q I._.�, WEST ELE4'ATION _-, , EAST ELEVATIM - Source:Carollo Engineers,November 2004. NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH BF Administration Building Plan/Exterior Elevations CON9umt4a 02/05•JN 10-1 01 4 0 9,002 Exhibit 3-7 KEYNC17ES rFr 1. €i jI}.' r s s rre.>.i i Q w $ tI .Is rr ww a zLEMVLPXu04 )f � r r. NORTH ELEVATION `]FIMK IE,S &iiiv:+:.'",FtC?L:.;+?.G_+ctz;ut`.x'n�5'u•Sc. g .dAt VCR (.!C1'�1T p hi E'YdrtFi1 § 9 ' 1. �. .� ( 1 7 I SOUTH ELEVATION w, ME '° � � �' a t �$ i1 a�� bra• e EAST ELEVATION ._f 3 ra ...' AYE, ELEVATION Source:Carollo Engineers,November 2004. NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH Reverse Osmosis Building Plan/Exterior Elevations CONSULTING 02/05•JN 1 0-1 01 4 09,002 Exhibit 3-8 dn r; No is t. ca3acR4rxuix 2 Ptft'ETER CCr CRET°WM.t a. REVE E(p1 Gk:.R477+14 Pk`'t 3.tia.. _ .,ems �» =-i— M r ra NORTH ELEVATION M- 1 .41 as s fiNiSlIES _ L . . „tit f aa_ i k GEW E?�t.�%i'C41Na E<Si.'4b'Ca5'SSrvS5iffE' N+_ v, i' t i t I 1 ' '1J-�' '5P8ai 1 i OFF i.TYP, p I 'L5 t.-[ 4 �Gj2 SO(.ITH ELEVATION �CEA`;G'�L",.ii.ftllHN EGW:v'�5'.A4CE9' .xa9 R UZ10 f m Kl- a A , 7 i a , a:na. '--.JDa z EAST ELEVATION �n� o- zg G I, T-727-77-77 1-7 �``� .fit e." v'•a a E.'�'= r /^— '— t'r MM — eat y ° 2 FF:-- =r 2 WEST ELEVATION Source:Carollo Engineers,November 2004. NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH Pretreatment Filter Structure Plan/Exterior Elevations CON5ULTINO 02/05-A 10-101409.002 Exhibit 3-9 �: � ��r � � � it rr �1 �: ar� ire rt•: ar � rr: �� � �. IMF Y.N'O ES 2 h1I L I CAL a EI S REEV W?ALT. • t a 3 META I FRAME WINDOW -L M FfA L MAIN DOOR 1L M I gg 1 �1E3.4:LRC?l.l.l;l'[7C>Oft t• � - �`� � �s me 'A � I �.�_. 6 REVEAL •�._.""... 4' 1 '� � � or .... 1 M1C'.M t 77 3 att2 _r I,T FINISHES �tY xi r =L.-` [Est Elevation _./ ,T '' I„r` West 1; ati( — :a.s�r ri..aac�n,ter..<t.:r..•a'+w; 77,'.........._.. �„F ' aR--- r I(} ! lol-�' 4I<i--'t Ir;,_" , ...:' , _� t ...' .I«: ' So1ith Elovatilin i Ilan Source:Carollo Engineers,November 2004. NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH Solids Handling Building Plan/Exterior Elevations CONSULTING 02/05•JN 10-101409,002 ' Exhibit 3-10 j a ,it if 3 N, `i 3 1• :S �a e�$ i 6,Tt0: '.3.3 ",3 I . .. ? 1. . . .7fY'#GNLN b $ 1 .�.._.,. ',.e A " '3# FNIM , ./ ....,.. .,_�4.. rzv. � : . \OR'Fl l ELEVATION EA51'ELEVATION I�- -'C- -, a+! a, a 4MMIM rF oscx��r A, s j a! IF,? U" - _ 1 x b .. i �r _ .a J '&a` [ r 4 r s MIA Ml SOL)UH ELEVATION WF-1;T ELEVATIC)N KFYtiC7fSS [I FIAlsI IF,<1' - .vs�rer +.xm rvs_. �r.+eT.0 -vc-rz+n>z rvn�.rz,w j a c�•.•,. !'.1 aaxv •sw' c '-s s» - a. ar,ene sz xe aaur=,xnr;n€sarsr�;e r -• . a KCE (LXU"YJ�zV FC.xr,k� ..:..... ......•,...... FN vzv i F;BhltlH t �! --.. a. .t s u s rKu x,., i..�swaxiKwear..sa '�L ........... ................. SjSjSj x:.« k�a U 4 .._:. PLAN Source:Carollo Engineers,November 2004. NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH Chemical Storage Building Plan/Exterior Elevations CONSULTING 02/05•JN 1 0-1 01 4 09.002 Exhibit 3-11 KEYNOTES r o -------- f u,,x cri a-z a.aa_.«c sRVT V` 7= — _,' [t C` 'VEST ELEVATION 7 �I t '3A7 i ' rt 3 Sx A A` i '[_; EAST ELEVATION L €�� l PLAN L7 I\O TI-1 ELEVATION y r ' SOUTH ELEVA`rio Source:Carollo Engineers,November2004. NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH Electrical Room/Substation Building Plan/Exterior Elevations ■ ■ r C 13 N SU LTI NG 02/05-A 10-101409.002 Exhibit 3-12 r r No M M rr its rr r o, ari r rr rr r rr +�r re r. FENISHES �.S16"£t.IYS.l.R9i a. t.'a'CA tNY ac cress aoE c. J t ,.cc,:I.w,i vC+�ok��rs:cu=vaucs •. :ro5 wu -.:erc cu-.r vccrnurra 3;fC bf 5sJ< `,. SQL 'sU+trGA'iRtM1'Ni , 1 21_ - PLAN PLAN PLAN PLAN �4 . xsun r _ 1 14 A mil ml: FUltm ft:R > .: IP Gj v � t IAGE el � A ONIASIORA � � � •r TANK i [[ A . 1 f 0 w. , FLUSH TANK LIME SILOS WASH 4hYATECt TANK Source:Carollo Engineers,November 2004. NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH fw Storage Tank Plan/Exterior Elevations CONSULTING 02105-A 10-101409,002 Exhibit 3-13 KE:1 N011 S '_YC Yht(rNv:,i� {JEtT3Wk]tJ:l$el � S .e_Yxt +� 4E_k*2a1 At � n�R CM1§tftL.;lY4i CFAI,Wrt,g?A � II TANKEl � d Do 0i1 St iC,=' .k E9-N - 5L„ TANK j 11 ,: f� PLAN Xrl y'"§ $ t[3""i -m<~' 17 , T ME ' 1 ■ r• �4 � t 1 � t 1 a� EAST ELEVATION NORTI I ELEVATION Source:Carollo Engineers,January 2005. NOT TO SCALE MF SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH Carbon Dioxide Tank Plan/Exterior Elevations C 4N SU tSI N4 02/05-A10-1 C1409.002 Exhibit 3-14 r` a' B / t r e n ays ENLARGED ELEVATION G f u ff �r+' KEYNtJl'ES IIVISHE$ � : ? Cta vl.'�'i $'A•,#A" bi:�i_ � Ah'%]Jc68 tW4t['&+F`SII `x`f£OCE„!LS �� � - �P4NVYL^0G{H SzxPCRtIS r r[tatY:,�^tra•.e>t E S r.G1Z5Mk.S'fz'i..LN"iTPtiE'E'A `^-.. '" PLATY fi SR£L i'R4M�tiG k'4%+EkFi4 I- STEEL s rxy.(x Wlf El.n'AMN----\ 4 EC.fin�6E.4.n Sl ��.iIGF.T tT'itiiY S = m _ ii. e f _ Now �tl +XiY 3 i _ --1—._------ —.—.--.__— _._..— —___1. EDISON AVENUE ec.xArx fi" "- —. ----v OVERALL ELEVATIONI Source:Carollo Engineers,November 2004. NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH MF Product Water Storage Tank Plan/Exterior Elevations CONSULTING 02/05-A 10-101409.002 Exhibit 3-15 Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report product water pump station (to be located in an underground vault)would be situated adjacent to the Product Water Storage Tank. Landscaping and Street Improvements Based upon 2003 Design Review Board approval, landscaping and street improvements would be focused on the northern, western, and eastern portions of the subject site (refer to Exhibit 3-16, CONCEPTUAL LANDSCAPE MASTER PLAN). Along the northern portion of the project site, Edison Avenue would be improved. These improvements would consist of the dedication of 12 feet along the frontage of the existing Edison Avenue (for curb, gutter, paving, and street lighting improvements)for a total of approximately 600 linear feet. It should be noted that AES Huntington Beach, LLC would be responsible for dedication of property to the City for these improvements, as AES owns the entire southern frontage of Edison Avenue and would lease property to the applicant for the proposed project. However, the project applicant would be responsible for completing the roadway and landscaping improvements as a condition of approval for the project subsequent to property dedication. It should also be noted that street widening along Newland Street(west of the ' proposed project site)would be performed by the City,with separate entitlements and environmental evaluation. AES Huntington Beach, LLC would dedicate 10 feet of right-of-way(to 50 feet east of centerline)along Newland Street. In addition,AES and the project applicant would be required to ' pay their fair share of the cost to widen and improve Newland Street. A ten-foot wide landscaping planter(including street trees,accent palms,shrubs,and groundcover) would be planted around the northern perimeter and a portion of the western side of the project site. In addition,an eight-foot high masonry block wall would be placed between the landscaping and the earthen berms. Adjacent to the eastern portion of the project site is a wetland area. Therefore, landscaping within the eastern portion of the site would consist of compatible native wetland vegetation,which would be coordinated with the Huntington Beach Wetlands Conservancy and the City of Huntington Beach. B. INTERACTION BETWEEN THE PROPOSED DESALINATION FACILITY AND THE HBGS Project Site Lease The project applicant, Poseidon Resources Corporation, has entered into agreements with AES for the lease of an approximately 11-acre site and for the use of various easements on the adjacent properties for the construction and operation of the proposed Seawater Desalination Facility at Huntington Beach. The lease agreement is with AES Huntington Beach Development, LLC; the easement agreement is with AES Huntington Beach Generation, LLC. The easement agreement provides for interconnection of pipes and associated pumps with the existing HBGS condenser cooling water infrastructure. The easement agreement also provides for site access and other underground piping among the water treatment facilities and the water storage tank. The term of ' both agreements is for 38 years, plus options to extend for two 10-year periods. However,since the desalination facility would withdraw HBGS cooling waste water rather than pump seawater directly from the ocean; should the HBGS cease operation permanently, the applicant has the option to purchase the intake/discharge infrastructure to ensure continued operation of the water facility and would be required to seek new permits for operations due to the change in the project description. Proposed Physical Connection between the Desalination Facility and the HBGS Source water for the desalination facility would be taken from the existing condenser cooling seawater discharge pipe system of the HBGS (Exhibit 3-17, DESALINATION FACILITY/HBGS COOLING WATER CONNECTION). The seawater desalination facility intake would only be connected to the HBGS 108-inch cooling water discharge lines and would only collect seawater that City of Huntington Beach April 5, 2005 3-20 Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report has already been screened and pumped through the generating station cooling water system facilities. The desalination facility would not have a separate intake that can collect seawater directly tJ from the ocean nor would it require modifications to the exiting HBGS intake system(refer to Section 4.1, PROJECT SITE). At all times and under any mode of HBGS operation, the desalination facility would collect approximately 100 MGD of seawater from the HBGS cooling water discharge pipelines. The desalination facility would have only one (normal) mode of operation and would be operated at 50 MGD of potable water production capacity 24 hours per day and 365 days per year. This mode is expected to change only during unpredictable emergencies. It should be noted that the proposed project would utilize new feedwater pumps. These pumps would operate constantly and would be independent of the HBGS. Should the HBGS cease to operate, the applicant would purchase the HBGS pumps and intake/discharge facilities and continue to produce and distribute potable water, subject to approvals as noted above. t_ Currently, HBGS is permitted to operate at full capacity and to use and discharge up to 514 MGD of seawater 24 hours per day, and 365 days per year. The operation of the desalination facility would not result in any changes to the permitted operations or in the maximum HBGS intake flow rate (refer to Section 4.1, PROJECT SITE, for a description of HBGS operations). C. DESALINATION TREATMENT PROCESS 1.J The desalination facility treatment process is presented in Exhibit 3-18, DESALINATION TREATMENT PROCESS FLOW SCHEMATIC, and includes the following key treatment facilities, 0 processes, and characteristics: ❖ Intake system, which consists of: • intake pipeline connection to HBGS discharge lines, • intake pump station, ❖ Pretreatment filtration system, ❖ Reverse osmosis membrane system, which includes: r • reverse osmosis membrane maintenance process facilities, ❖ Product water post treatment facilities, •3 Chemical storage/handling facilities, +r- ❖ Reverse osmosis concentrated discharge and filter backwash discharge facilities; and ❖ Energy consumption. Intake System The desalination facility intake system would consist of a connection to the HBGS discharge pipes,a 72-inch desalination facility intake pipeline and approximately a 100 MGD pump station.The point of the desalination facility connection would be downstream from the HBGS condensers(refer to item r 1 on Exhibit 3-18). Approximately 100 MGD of source seawater for the desalination facility would be drawn from the existing HBGS condenser cooling water discharge system through this connection - and conveyed to the desalination facility intake pump station via the 72-inch pipeline. This intake pipeline would be located entirely within the existing HBGS site. The desalination facility pump r station would consist of five vertical turbine pumps of approximate capacity of 25 MGD each. Four of the five pumps would be operational while one would be a standby unit. It should be noted that these pumps would operate constantly and would be independent of the HBGS. The desalination r facility's pumps would not be able to withdraw seawater from the ocean;only the HBGS pumps are i City of Huntington Beach April 5, 2005 r 3-21 �w r rs r r arr r rnr r r� rr rr r r r rr r i r r FI AM I t1.F171,G � _••_: -•.•.,., :;` _.�.» ;..��._: ..�_�R� ~.. t�t'eFz.P.L't:`45iYL275&l:t' P❑ A [ �� t ff !! ESHT[ 476GIL.S:',`SRk6l TRk'fi a w P f+,'R' Geium N�4, u=.0atirrcc'rx 7sttc=.rt-�.- a Fir � 1 f f$ LyM;Rrt0 E'1",tllfl.T.T Ei .nthnaa�4rn;re;�sr_>a+a�e�,MfF��a 3 i ED .--sr --. 1 Y` 4'aN'E.l itEl[+�1n F4.¢IAIlIS A- t 3 4. 20 F'+'1 W-Yl'r"T�-.a DI fi { ✓'"� J".,ti_ �� i xwaa \ V� p"�. —` E �1 >t 556h lYde Lb�k f ' Sf 13a 1 t F 1RO 0,441% C9.) pm--' t;a�aa ra art,A�ptu11 .n caa„a ee,,,. P Leg Fxvp to unx M. ' 1 f — m 1pl t3 Y d Wwrn xd 1"A 4'hie Panel 4 han.. 1 `- ',;;,...�( q+,.' tp-•.•. '1f)_h P."I.,PIm Ae m6 WrJr Rlbn4—WY 1!c Slk-1 KIN lA "F'DS0N Sf IdTf s Il f � ' tx Pro4uq e�,uar nr rTana � �� � 33 �� ,�.-- A..ic,Etz��:emu: ly--••r^'- �`t i �� �� .2}} hml.Grbave t Air, �u� t`t6 riuNSeM tSme'mie 5«Cewdk. 1 . .:. F o ( -FSF t d »A¢u pe[1'x°Blxuat rAF,-11- IT Ww&SW p.R A—i Pink-dA Ad*-lu ttarCvg'Ai.Sa. SEt..I'lUh(3!3 3Llt°L'Yp.i)51R11ii" L;AND5CARE.AIREASUNVMARY: AttG1l tt,J4t YP ARh42-Z-4SF. Aft�13-1S,a`76 S t. AfiEA A-S.iNi S.F. ((ST:i-55,2W 5F Source:Poseidon Resources Corporation,February 2005. NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH .wo . Q Conceptual Landscape Masterplan CONSULTING 02l05•JN10-101409.002 Exhibit 3-16 UNIT (D 168" POWER PLANT INTAKE PIPE NoA 168" POWER PLANT OUTFALL (1) POWER PLANT INTAKE/DISCHARGE STRUCTURE DESALINATION PLANT INTAKE WATER QUALITY SAMPLING POINT. 7Z'RCPP--" 54'RCPP (Typ) 18—INCH SO UNIT No.3 ------- I POWER PLAN 36—INCH SID PUMP 4 PUMP 3 72'qCP PUMP 2 105'RCPP PUMP I 3 ---------------- io RCPP 14'xl 1' I 72"RGPP 1 O—INCH BOX POND DRAIN J 4 CULVERT ------------- 46' DESALINATION PLANT DISCHARGE -—- - -—- 54"RCPP UNIT 1 72' DESALINATION No.2 I (TYP) PLANT INTAKE ia—INCH SD-/tI DESALINATION POINT OF DESALINATION PUMP STATION PLANT DISCHARGE/SAMPLING N 33* 38.634' W 117 58.729' 72'RCPP �! UNIT 72' DESALINATION ND,l PLANT FEED LINE Source:Carollo Engineers,November 2004, NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH fWF Desalination Facility/HBGS Cooling Water Connection CONSULTING 02/05-JN 10-10140H02 Exhibit 3-17 �Jesalinatior Facility _ IN wS `' ,. +i'�' `�-' - � - �- ` :k-`i-{" rya In m: Ma lo law NNW MR ` '. Coagulant ..P4 mer s v _ > e� _ 4 Carbon Dioxide f. - 3otlium F3rsuifite lime Chlorine ANtntonia fbw T Stream DescrlptwnCartndge Fliteis t Seawater intake - ` ® 2 RO Feedwrater a ; r" { Potable 3Froduet Ylla 4 Cd"htraied'lwwater ' Pret€eatment Red Product,Water �� 5 �FiterBackwashwater; ,Filtration ` Pumps Stdiage'Tank' 3 . B Desalination Faofy Discharge Pipeline. C] Conhriuous deed of Chemicals' Sulfuric Acid Interrriittent i eed ot;C hemicals; Energy Recovery_ - m — Intake O° Omtfailr Pumps Pumps {r{A4'Ic 1 PoWer=Cenerattn8fettcn a, 0 nw 'Chlorine--�► Generating Station Condenser Coopng Coaling Water D&harga Generating Siallon Qutfail 'Intake Water Circulation St(4m. ,. ScEeens Co } miensers a' . Puritps� - ocean- Generating Station- .- - � Cooling Seawater"tntake Source:Poseidon Resources Corporation,November 2004. NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH . e Desalination Treatment Process Flow Schematic CONSULTING 02/05•JN 10-101409,002 Exhibit 3-18 ' Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report ' capable of this. To prevent growth of marine organisms in the intake system, chlorination and de- chlorination of the supply water would be on an as-needed basis. Aside from the connection point within the HBGS site, no modifications to the HBGS would be required. ' Pretreatment Filtration System ' The proposed desalination facility would utilize either a single-stage or two-stage gravity media filtration pretreatment system. The addition of coagulants, such as ferric chloride and polymers, would be provided as appropriate to enhance the operation of the media filters and to prepare the ' water for RO treatment. There are a variety of pretreatment filtration systems and technologies available that can meet the requirements for RO treatment. The actual pretreatment process to be used would be determined during the final design phases of the project. The final phase of pretreatment would be cartridge filtration. The filter cartridges would be standard five-micron polypropylene wound filters enclosed in a pressure vessel. The pressure vessels would be located on the RO feed water piping between the pretreatment and RO processes. The RO intake water would be chlorinated intermittently to prevent microbiological growth on the filter media. Since any chlorine remaining in the filter effluent water can damage the RO membranes, the filter effluent would be dechlorinated using sodium bisulfate.. In addition, the RO ' feed water would be treated with sulfuric acid as needed to reduce the potential for scale formation in the RO system. The amount of sulfuric acid added to the water would be determined by the bicarbonate concentration of the seawater and the Stiff Davis Index (SDI) needed in the RO ' concentrate. The acid also provides carbon dioxide in the RO permeate (product water), which is needed to react with the lime for product water stabilization in the post-treatment step. Reverse Osmosis Membrane System The RO process would be a single-pass design using high-rejection seawater membranes. The system would be made up of 13 process trains (12 duty and one standby), each train with a design ' capacity of about four MGD. This arrangement provides approximately eight percent standby capacity, which is needed to ensure continuous water delivery with normal membrane wear and maintenance requirements. High-pressure,electrically-driven feed pumps would convey waterfrom the intake filters through the RO membranes. The pumps would provide feed pressures ranging from 800 to 1,000 pounds per ' square inch (psi), and would be located within the RO building. The actual feed water pressure depends on several factors including temperature of the intake water, salinity of the intake water, and the age of the membranes. The pumps would be equipped with variable frequency drives to ' improve energy efficiency and to provide pressure control over a wide range of feed water quality and membrane conditions. To further improve energy efficiency, the high-pressure feed pumps would be equipped with energy recovery devices. A large amount of residual pressure remains in the concentrated seawater leaving the RO process. The energy recovery devices recover this ' energy, reducing the net energy demand for the system by approximately 30 percent. Additional energy savings may result from the use of warmer water provided to the RO process by the HBGS' cooling process. The desalination system would be designed to operate at both ambient and ' elevated seawater temperature. However, using warmer water increases the efficiency of the RO membranes. Reverse Osmosis Membrane Maintenance Facilities The accumulation of silts or scale on the RO membranes causes fouling, which reduces membrane performance. The membranes would be periodically cleaned to remove these foulants and extend membrane life. Normally cleaning frequency is twice per year per train and City of Huntington Beach April 5, 2005 3-25 Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report there are thirteen trains. To clean the membranes, a chemical cleaning solution is circulated through the membranes. The RO system trains would be cleaned using a combination of cleaning chemicals such as industrial soaps (e.g. sodium dodecylbenzene,which is frequently used in commercially available soaps and toothpaste)and weak solutions of acids and sodium hydroxide. The cleaning process includes two steps:first, circulating a number of cleaning chemicals in a predetermined sequence through the membranes;and second,rinsing the cleaned membranes with clean water (permeate) to remove the waste cleaning solutions and prepare the membranes for normal operation. It should be noted that the actual cleaning chemicals used n would be based on the observed operation and performance of the system once it is placed in J operation. For a detailed discussion of chemicals and materials to be utilized for reverse osmosis membrane maintenance,including a description of volumes/ratios,refer to Section 5.8, HAZARDS AND HAZARDOUS MATERIALS. As noted above, subsequent to the circulation of the cleaning chemicals through the RO membranes, membrane rinsing would be performed using membrane permeate fresh water, j 1 which would be free of chlorine. The membrane rinsing process would include a first rinse 1� (removing most-of the waste chemicals),and subsequent rinses(containing only trace amounts of cleaning chemicals). It should be noted that besides permeate and residual cleaning solution, a the waste rinse water would also contain a small amount of concentrated waste cleaning solution. All chemicals used in the membrane cleaning process and the membrane's first rinse would generate approximately 91,000 gallons of spent cleaning solution and would be directed to a designated 300,000-gallon storage tank (wash water tank)for mixing and treatment. The wash water tank would be equipped with a mixing system and chemical feed system. The content of the tank would be continuously mixed and the pH of the waste cleaning mix would be n monitored. The waste cleaning solution would be treated using.sulfuric acid or sodium hydroxide as needed to neutralize the solution. 4_ The first rinse water would go to the washwater tank to be neutralized and then discharged into r the local sanitary sewer for further treatment at the Orange County Sanitation District(OCSD) t_ regional wastewater treatment facility. OCSD has indicated that its facilities are of adequate capacity to accommodate this waste cleaning solution.' The rinse water following the first rinse r- water would be diluted with the RO process discharge, treated filter backwash, and HBGS cooling water discharge,and then sent to the Pacific Ocean via the HBGS outfall. An alternative to discharging the RO membrane cleaning solution into the OCSD system is to discharge the r— solution into the Pacific Ocean via the HBGS outfall. The majority of the chemicals within the membrane cleaning solution would be either below detection levels or regulatory limits, even �- before dilution with other desalination facility and HBGS discharges. Dilution with the HBGS discharge would ensure National Pollution Discharge Elimination System(NPDES)compliance. I It should be noted that potable water coming from off-site City facilities would not be utilized for l- operation of the rinse tank or wash water tank. Ir For a discussion of potential impacts in regards to RO membrane cleaning solution, refer to l_ Section 5.3,HYDROLOGY,DRAINAGE,AND STORM WATER RUNOFF,Section 5.6,PUBLIC SERVICES AND UTILITIES, and Section 5.8, HAZARDS AND HAZARDOUS MATERIALS. F- ' Email between Nikolay Voutchkov, Poseidon Resources Corporation,and OCSD, May 29,2002. r City.of Huntington Beach April 5, 2005 3-26 L ' Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report ' Product Water Post Treatment Facilities Product water from the RO process requires chemical conditioning prior to delivery to the distribution system to increase hardness and protect the new and existing distribution system against corrosion. Lime and carbon dioxide would be used for post-treatment stabilization of the RO water as a source for pH and alkalinity adjustment. In addition, the final product water would be disinfected prior to delivery to the distribution system. Chlorine, in the form of sodium hypochlorite and ammonia,would be added to disinfect the product water by chloramination in order to meet the State Department of Health Services(DHS)water quality standards for potable water disinfection and to control biological ' growth in the transmission pipeline (refer to Section 5.11 PRODUCT WATER QUALITY AND EXISTING POTABLE WATER QUALITY IMPACTS). Chemical Storage/Handling Facilities ' Various chemicals typically associated with desalination facility operation would be stored on-site. These chemicals include sodium hypochlorite, ammonia, lime, carbon dioxide, ferric sulfate, polymer,sulfuric acid,sodium bi-sulfite,and the RO membrane-cleaning solution described above. All such chemicals would be stored, handled, and used in accordance with all applicable Federal, State, and local standards. This topic is further addressed in Section 5.8, HAZARDS AND HAZARDOUS MATERIALS. These chemicals are food-grade purity compounds typically used in most conventional water treatment facilities. ' Reverse Osmosis Concentrated Seawater Discharge and Filter Backwash Discharge Facilities ' The byproduct of the RO process would be concentrated seawater. Approximately one gallon of concentrated seawater would be created for every gallon of potable drinking water produced. Therefore, for the proposed 50 MGD desalination facility, approximately 50 MGD of concentrated seawater would be generated. The salinity of the concentrate would be about 68,000 parts per ' million (ppm), twice the concentration of the incoming seawater prior to blending with the HBGS condenser cooling water discharge(refer to section 5.10, OCEAN WATER QUALITYAND MARINE BIOLOGICAL RESOURCES,for additional information). The concentrated seawaterwould re-enter ' and blend with up to 407 MGD of the HBGS's condenser cooling water circulation system for discharge back into the ocean. The blending point would be downstream of the intake point for the desalination facility to prevent re-circulation of the concentrated seawater back into the desalination ' facility intake (refer to Exhibit 3-17, DESALINATION FACILITY/HBGS COOLING WATER CONNECTION). In addition, the filters would be cleaned (backwashed) to remove the seawater solids that accumulate in the media beds. The amount of backwash water necessary would be about four percent of the total intake water flow. For a 50 MGD facility, with an intake of approximately 100 MGD of raw seawater,approximately four million gallons of filter backwash water would be produced per day. The filter backwash water would be combined with the concentrated seawater for return back into the ocean. The constituent concentrations of the combined ' desalination facility concentrated seawater discharge and the HBGS'cooling water discharge would meet the requirements of the California Ocean Plan as administered by the State Regional Water Quality Control Board (also refer to 5.10, OCEAN WATER QUALITYAND MARINE BIOLOGICAL ' RESOURCES). Aside from a connection point to the cooling water discharge system within the adjacent HBGS site, no modification of HBGS facilities would be required.- Energy Consumption A 50 MGD desalination facility would require approximately 30 to 35 megawatt hours of power to operate. Based on 24 hour per day operation, the daily energy consumption of the proposed desalination facility is estimated to be between 720 and 840 megawatt hours per day. This amount City of Huntington Beach April 5, 2005 3-27 Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report of electricity could provide power for the average demand of between 30,000 and 35,000 residential U units. The total amount of power required to produce desalinated water for one family per year is U approximately the same as the amount of power used by the family's refrigerator in one year. The desalination facility would utilize off-peak power to the maximum extent practicable. In order to maximize the desalination facility's power efficiency, potable water production may be halted for short periods of time,at which point the facility would distribute water from its product water storage (� tank. The desalination facility would not include a backup generator. Emergency backup power U would come from the electrical power grid and/or HBGS auxiliary reserve bank. For further discussion see Section 5.4,AIR QUALITY. D. OFF-SITE IMPROVEMENTS L New Water Transmission Pipeline In order to convey the project's potable drinking water off-site, the project requires construction of water transmission lines to connect to existing regional transmission and local water distribution o systems. Although precise pipeline alignments may be modified during final engineering analyses, the conceptual pipeline alignments are shown in Exhibit 3-3, CONCEPTUAL PIPELINE ALIGNMENTS. A total of two pipeline alignments are currently being considered to convey water eastward from the desalination facility to its destination within the City of Costa Mesa,east of SR-55 at the intersection of Del Mar Avenue and Elden Avenue. The majority of each pipeline alignment is planned for existing public streets, easements, or other rights-of-way, and the alignments are not r� anticipated to require disturbance of native vegetation or otherwise impact sensitive resources. The U proposed alignments consist of a 42-to 48-inch pressure main, up to 10 miles in length along the two different conceptual alignments. The proposed routes would utilize trenchless installation of pipeline in order to traverse waterways and/or roadways with a high sensitivity to traffic disturbance. This topic is further addressed in Section 5.9, CONSTRUCTION RELATED IMPACTS. Primary Alignment The primary, or northern, alignment has a total length of approximately 40,050 feet(7.5 miles). This pipeline alignment would extend in a northerly direction from the AES facility within r Newland Street. The pipeline would utililize micro-tunneling or directional boring technology to cross the Orange County Flood Control District's (OCFCD) Huntington Beach Channel,as the bridge crossing the channel lacks the capacity to support the proposed pipeline. The pipeline would then proceed in an easterly direction within Hamilton Avenue from the Newland Street/Hamilton Avenue intersection to the Hamilton Avenue/Brookhurst Street intersection. Along Hamilton Avenue, the pipeline would be either micro-tunneled or directionally bored to cross the Talbert Channel. The pipeline would continue northerly within Brookhurst Street and would proceed in an easterly direction within Adams Avenue. The pipeline would again utilize trenchless methods to cross the Santa Ana River and Greenville-Banning Channel, as the r— Adams Avenue Bridge is not capable of supporting a 42-to 48-inch pipe. The alignment would then proceed in a southerly direction within Placentia Avenue to the Costa Mesa Country Club, at which point the route would proceed east along the northern boundary(utilizing off-pavement, open trenching methods)of the property to Harbor Boulevard. The pipeline would then proceed along the eastern boundary of the Fairview State Hospital to the Harbor Boulevard/Fair Drive intersection, again using off-pavement, open trenching methods. The alignment would then cross Harbor Boulevard (most likely utilizing trenchless methods) and proceed easterly within r Fair Drive. Routing the pipeline on the northern side of Fair Drive would permit the construction of the line off-pavement once the Orange County Fairgrounds is reached. East of the fairgrounds, the pipeline would pass under the SR-55 freeway utilizing trenchless construction L City of Huntington Beach April 5, 2005 r 3-28 ' Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report ' until it ultimately terminates at OC-44, located at the intersection of Del Mar Avenue and Elden Avenue. Refer to Table 5.9-3, PIPELINE ALIGNMENT DETAILS. ' Alternative Alignment The alternative alignment would follow a path located south of the primary alignment. This route ' would rely entirely on the implementation of the pipeline within public easements, through the Cities of Huntington Beach and Costa Mesa. The total distance for this route would be approximately 30,000 feet(5.7 miles). This pipeline would follow the same route as the primary alignment until the intersection of Hamilton Avenue and Brookhurst Street. At this point, the pipeline would continue eastward within Victoria Street and would utilize trenchless methods to cross under the Santa Ana River and Greenville-Banning Channel. Trenchless construction would also be necessary to cross Harbor Boulevard and the SR-55 along Victoria Street. After crossing SR-55, the pipeline would continue for a short distance along 22"d Street and would proceed northeast to its termination point at OC-44, located at the intersection of Del Mar Avenue and Elden Avenue. Refer to Table 5.9-3, PIPELINE ALIGNMENT DETAILS. Underground Booster Pump Stations The off-site construction of two underground booster pumping stations would be required as part of the seawater desalination facility project in order to convey potable water from the subject site to the regional distribution system. The OC-44 underground pumping station is proposed to be located underground within an unincorporated area of the County of Orange,along the eastern border of the City of Newport Beach,approximately 1.5 miles south.of the University of California, Irvine. The site is within an Orange County Resource Preservation Easement, but outside of the NCCP/HCP ' delineation zone,approximately%mile north of the San Joaquin Reservoir,where the East Orange County Feeder Number Two and the OC-44 transmission pipelines converge (refer to Exhibit 3-4, OC-44 BOOSTER PUMP STATION LOCATION MAP). The OC-44 underground booster pump station would include pumps, a surge tank to protect the distribution system from sudden pressure changes,telemetry equipment,appurtenances,and three diesel powered electrical generators for emergency back-up purposes. These generators would be Caterpillar Model 3516 units or similar equipment and would supply approximately seven megawatts of emergency power for adequate operation of the pump station (in regards to flow and pressure). These diesel-powered generators would require an 8,700-gallon diesel fuel storage tank(assuming ' a 24-hour emergency period), with a diameter of eight feet and a depth of 26 feet. The booster pump station, including the surge tank, the three generators and diesel fuel storage tank, would require a total footprint area of approximately 110 feet by 110 feet, and would be placed entirely ' underground to maintain the natural character of the surrounding resource preservation easement. Any displaced vegetation would be replaced upon completion of construction. A second underground booster pump station (the "Coastal Junction" pump station) is proposed ' within the parking lot of St. Paul's Greek Orthodox Church within the City of Irvine, located at 4949 Alton Parkway. The underground pump station would be constructed within the north/northwestem portion of the church parking lot, in an area used for both parking and volleyball activities. The site ' is surrounded by the St. Paul's Church to the south,the Woodbridge Village Association to the west, an apartment complex to the east, and open space to the north. The footprint of the proposed underground pump station would be approximately 100 feet by 100 feet, and would require a ' construction easement of 125 feet by 125 feet. The pump station would be entirely underground except for a small pipe vent and a ground-level steel access door for maintenance(the access door would not impede parking after construction). It should be noted that St. Paul's Greek Orthodox Church has been contacted by the applicant and has issued a statement of interest for the underground pump station site. This location is near the connection points of the existing regional City of Huntington Beach April 5, 2005 3-29 Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION a Draft Recirculated Environmental Impact Report water distribution system,Aufdenkamp Transmission Main and the Tri-Cities Transmission Main to the East Orange County Feeder Number Two (refer to Exhibit 3-5, COASTAL JUNCTION UU BOOSTER PUMP STATION LOCATION MAP). The Coastal Junction off-site underground booster pump station would include pumps, telemetry equipment, appurtenances, and one diesel powered electrical generator for emergency back-up purposes. This generator would be a Caterpillar Model 3516 unit or similar equipment and would r� supply approximately seven megawatts of emergency power for adequate operation of the pump J station (in regards to flow and pressure). This diesel-powered generator would require a 1,300- gallon diesel fuel storage tank(assuming a 24-hour emergency period),with a diameter of six feet and a depth of 15 feet. The booster pump station, including the generator and diesel fuel storage tank,would require a total footprint area of approximately 100 feet by 100 feet and would be placed entirely underground to maintain the appearance and functionality of the existing parking lot. Additional information regarding the proposed off-site pump stations is included in Section 5.9, CONSTRUCTION RELATED IMPACTS. Edison Avenue Improvements n As a condition of approval by the City of Huntington Beach for the proposed project, the applicant �J would be required to complete improvements along the southern side of Edison Avenue (situated north of the subject site as shown in Exhibit 3-2, SITE VICINITYMAP). These improvements would consist of the dedication of 12 feet along the frontage of the existing Edison Avenue(for curb,gutter, paving, and street lighting improvements)for a total of approximately 600 linear feet. It should be a noted that AES Huntington Beach, LLC would be responsible for dedication of property to the City for these improvements, as AES owns the entire southern frontage of Edison Avenue and would lease property to the applicant for the proposed project. However, the project applicant would be responsible for completing these roadway and landscaping improvements as a condition of approval for the project subsequent to property dedication. It should also be noted that street widening along Newland Street (west of the proposed project site)would be performed by the City, with separate entitlements and environmental evaluation. AES Huntington Beach, LLC would dedicate 10 feet of right-of-way (to 50 feet east of centerline) along Newland Street and both AES and the project applicant would be required to pay their fair share of the cost. E. DESALINATED WATER DISTRIBUTION As described below in Section 3.4,PROJECT NEED AND OBJECTIVES,the project would provide a supplemental and alternative source of potable water to Orange County. Water produced at the L Seawater Desalination Facility at Huntington Beach would be delivered via the off-site project pipeline into a large water transmission pipeline operated by Mesa Consolidated Water District(the (- OC-44 pipeline). From there the product water would travel into the existing regional water distribution system that is operated and maintained by the Metropolitan Water District (MWD) of �- Southern California. It would be necessary for the applicant to negotiate and enter into institutional agreements with Mesa Consolidated Water District, MWD, the Municipal Water District of Orange County and other local water agencies that own or operate those portions of the regional water L distribution system that would be utilized for delivery of the water produced by the project. The water agencies that would either receive the desalinated water or a blend of desalinated water [ and imported supply include: r- • City of Huntington Beach • El Toro Water District • Irvine Ranch Water District r • Laguna Beach County Water District City of Huntington Beach April 5, 2005 r 3-30 Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report • Mesa Consolidated Water District • Moulton Niguel Water District • City of Newport Beach • City of San Clemente • City of San Juan Capistrano • Santa Margarita Water District • South Coast Water District Exhibit 3-19, APPROXIMATE DESALINATED WATER DISTRIBUTION AREA, depicts the approximate distribution of the desalinated water throughout Orange County in the year 2010.The amount that is received by an agency may vary depending on a number of factors, but the main factor would be the water demands from the water agencies connected to the transmission pipelines that are conveying the desalinated water. For example, if the amount of water taken from the transmission pipelines in central Orange County increases, then the amount of desalinated water that actually makes its way to south Orange County decreases. Conversely, a decrease in central 1 Orange County usage results in an increase of desalinated water going to south Orange County. F. DESALINATED WATER QUALITY The desalination facility would produce drinking water of very high and consistent quality, which meets or exceeds all applicable regulatory requirements established by the US Environmental Protection Agency(EPA)and the California Department of Health Services(DHS). The desalinated water would be produced applying state-of-the-art seawater reverse osmosis membranes which are capable of removing practically all contaminants in the source water: turbidity, taste, odor, color, bacteria, viruses, salts, proteins, asbestos, organics, etc. With-pores ranging from 0.00005 to 0.0000002 microns (for comparison - human hair size is 200 microns) the reverse osmosis membranes would retain and remove over 99.5 percent of the seawater salinity;over 99 percent of the metals and organics; 99.999 percent of the bacteria and other pathogens (Giardia and Crypfosporidium) and 99.9 percent of the viruses in the source water. Current) EPA recognizes reverse osmosis membrane treatment as a best available technology for Y. 9 9Y water treatment and for meeting future more challenging water quality regulations. This technology has proven its viability and performance in a number of facilities worldwide over the last 20 years.An example of a seawater desalination facility in California is the Marina Coast Water District's(MCWD) facility, which has been in operation since 1996 in the City of Marina, at Marina State Beach. This facility has been delivering high quality desalinated waterto the MCWD's distribution system for over eight years — with no customer complaints or measurable corrosivity effects on the distribution system or household plumbing. To provide an additional level of safety after RO membrane filtration, the desalinated water produced by the proposed facility would be disinfected applying the same chemicals that are currently used for disinfection of all other water sources in the Orange County's water distribution system(chloramines). In addition,the desalinated waterwould be conditioned with a combination of lime and carbon dioxide to make it non-corrosive to the water distribution system and to household plumbing. The desalinated water quality would be compatible with the water quality of all other sources of potable water with which it would be blended in the distribution system. The viability and performance of seawater desalination treatment using Pacific Ocean water have been proven at Poseidon's demonstration desalination facility in Carlsbad, California (situated on- site at the Encina Power Station). This facility has been in operation for over two years and has produced over 20 million gallons of high-quality fresh water to date. City of Huntington Beach April 5, 2005 3-31 Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report Table 3-1, DESALINATED WATER QUALITY— KEY PARAMETERS presents key desalinated water quality parameters and provides a comparison with the existing drinking water produced at the u Diemer Water Treatment Plant, operated by the MWD, and federal/state limits. Currently, the Diemer Water Treatment Plant is one of the main plants supplying Orange County with drinking water. Table 3-1 DESALINATED WATER QUALITY KEY PARAMETERS MWD Diemer Plant �. Parameter Desalinated.Water w EPA/CDHS Limas Water... t; Total Dissolved Solids (TDS), 250-350 373-491 500/1,000 m /L Hardness (as CaCO3), mg/L 40— 100 200— u Moderate) Hard (Hard) No Limit Sulfate, mg/L 5-20 111 - 173 250 a Total Trihalomethanes 5- 10 27-51 80 (TTHMs), µg/L Haloacetic Acids (HAAs), 1 -5 10-24 60 µg/L MWD=Metropolitan Water District of Southern California I EPA= Environmental Protection Agency CDHS=California Department of Health Services mg/L= milligrams per liter /L=micrograms per liter A review of Table 3-1 indicates that the desalinated waterwould have approximately 100 mg/L lower L salinity(listed in the table as TDS)than the existing drinking water. The lower drinking water salinity F- should result in better taste and lower water distribution system corrosivity. The desalinated i seawater would be softer than the existing water sources. Softer water has a number of benefits L such as: better taste;formation of less calcium deposits on household appliances and cutlery;and lower detergent use. Commercial and industrial establishments which currently use softening devices to treat the potable water would also benefit from introduction of the softer desalinated water �— in the distribution system—their softening costs would be reduced and some of these users may not need to soften their water anymore (most industrial users typically require water with a hardness below 80 mg/L — as desalinated water would reduce hardness by at least 50 percent, softening L costs would also be reduced commensurately). Similar to TDS, drinking water of lower sulfate concentration would have a better taste. The desalinated water would have order-of-magnitude lower concentrations of disinfection byproducts (TTHM and HAA)than the existing drinking water. t_ Disinfection byproducts are well known carcinogens and their reduction in the drinking waterwould be an added benefit. r Section 5.11, PRODUCT WATER QUALITY, provides a more detailed analysis of the desalinated L water quality and the potential water compatibility impacts that may result from introduction of desalinated seawater into the regional water distribution system. I L G. SEAWATER DESALINATION FACILITY OPERATIONS r Parking Automobile parking for facility employees and visitors would be provided in an area surrounding the administration building, located within the northern portion of the subject site. Approximately 30 L City of Huntington Beach April 5, 2005 1 3-32 L SANTA ANA., FOUNTAIN VALLEY 1 1. `SS' I atxsaa roar �— iV MEI fa M• I I PflGMM ttii C,�ICR�LAfif - r; f :::�• . : ;` ::::VIN .......... .:?.s..,..?...ii...i.................................... ' :.:::.::.?:.:�::'•.:..'�:..:.::...:':'.::.:.'i.'::.:.:.�.::.':i.:.'.::::.,:.`.:.:.?...':.:.:.IR1-405 i2 : 5 .......... ESA C 7 D� i ...... , '.. .:. .:. .:p� I r ci tir . a.•::: :hi:i:•s:i:iii:•: ' u ..::::::::: .: . :•:::::::. .:::::.::::.::.:::.:•':::•::: :::::::::::: ..........::::c - HUfJT NGT.. a .:.�. ...............::::•::: W TE D STRICT ��. wM1tiwv. ... ................................... i/ %e. .. ....... - ...r........ ....... ................ .....". ...................... ....._.........s .........� .. • :..........:::•. ,1 sir„ ..4........ ............... +. 7: ..... ............. ...... .. r ...... ...... rrrwur t.............. .. ...........L. ......-.. .. .. .. - ..__...._... LEGEND �::. :.:::::::.� :•:.: ' .. •::• , LOS LISOS PIPELINES (% DESALINATED WATER) r'r DISTRI ...... .. ..........{ip'.c:mwb :::. .... .. ER NONE MM ItII .^rw I •s [RT'd".p¢'1':::.: ... ................... ..................:. .... .. >0 AND < 25 .B NE ...................... >25 AND <=50 .. _._..................._..._.... >50 AND <=75 _..........."......... �6 .... ...r:.v�....:..::' ..:.: '::.-- •-.. .:::::r::::::::::::::.r::::::•:.�:.-::.:. �r..:::::. .:a�.>•,.,.,. c..' : >75 AND <100 ::-'. ............ ,m; :.Ndt1:DER::D.xS7Ri :T;t':;'::a:..,:.;.,.. ...................................... 100 .� � �-- � ,. .... ::.tea..�:..::...... ................. ... .................. SERVICE AREAS % DESALINATED WATER ........................ �' - ':c:;::.�: ...-.. .. .:::::.v:.v::::.::r...:.:... .:::::._:.�.�.::�r:: ." ._............................::i(�ii:is ........i.. ........ :::::.' '7::ii•:•:^:ii, c}ii:{i•:is ai:r.'•': �-- ... ......... ...... ..�.................................... ::.>�:�;:::;::::::;;.::� `:;:'::- :� :;:�:�:.::' ::.: ;:�:�:�:�:�:�:�`�:�::€`.�.`;� �:�:�:�;:_: >0 AND <=25 ........................ Y :. �;';':;' ::•:'::':::�::'::':;�::::'::':::�: � � >25 AND <-50 ........ . ...................::::::.....................:. .:.: '::::::.:�:._::::::.::�:::::." . >50 AND <=75 _._ .................... ........—_...:::::::: ......................... J.:.'\:'::::::::::..:::.:::::: :'...'....�:::. . .......... :.. ::.•............................>.-.."....:::::.::::::::.�:::: _...,.............:...•. gra!axeuw�.' ':::.;.::. ':.;.:::•:.'.;':::'::':::'::':::':;:;';:'::� :::;;:::•>::>75 AND <=100 1 .... .. .v .� � ..................... . .� �. . :.... ::::::::;:;:::::::;' .. .. ,:..... ... ................ .:::.:.:........ . MOU TON 'NIC) L'::..:::::. ::.:::.:: ?:::. ... ....................................................... ���._...,.. ..,. ., SANTA MARGARITA WATER DIST -- .-- - ..: I �'::.`..:.:. : Loin , Lf3CWD"' �M a J .w�u�w✓wv.n.•wn a .yr..-_ ............. ................ ................ ................... i ----------------- �` • :: : .: `.' APTS0 VALLEY I . ...._::..... t..,:• WA T ,< DISTRICT --------- � 1 \ `--LEM EN TE Source:Carollo Engineers,February 2005. I NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH Q Approximate Desalinated Water Distribution Area CONSULTING 02/05•A 10-101409.002 1 Exhibit 3-19 Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report parking stalls would be provided,which would include several stalls designated for disabled persons in accordance with Americans with Disabilities Act (ADA) requirements. The parking lot would feature appropriate landscaping along its perimeter, per City standards. 1 Site Access Access to the proposed desalination site for employees, delivery trucks, and construction vehicles would be provided via the existing HBGS access point (main gate) along the eastern side of Newland Street. From this point vehicles would travel in a southeasterly direction, along the northern side of the HBGS generating units. At a point just east of HBGS generating unit number one and north of the service water tank, the access route would turn to the northeast and would proceed to the southwestern corner of the project site. Vehicles would then utilize internal access roads to their destination within the proposed project site. All access roads would comply with Huntington Beach fire code and City specifications. Staffing The proposed desalination facility would employ an approximate total of 18 people and would operate 24 hours a day, 365 days a year. Staff positions would include management, operators, maintenance, and administration/staff support. In addition, outside contracting of part-time staff is anticipated for specialized services such as electrical and mechanical maintenance. The estimated number of staff on duty during regular working hours Monday through Friday would be five to seven, with a minimum of two people on duty during swing shifts, graveyard shifts, and weekends. Chemicals The seawater desalination facility would use the same type and grade of chemicals as any other conventional surface water treatment plant. However, the seawater desalination facility would use fewer chemicals of lower dosages than existing conventional water treatment plants in Southern California, because its unique source of water (the Pacific Ocean) is of significantly better quality than other available water sources (i.e. Colorado River, the San Joaquin and Sacramento River Deltas, local surface water,and most groundwater sources in the area). The seawater desalination facility would also use significantly(order of magnitude) less chemicals than water reclamation/re- purification facilities in Southern California. Since the desalination facility would use fewer chemicals, this would reduce the potential of chemical exposure to the surrounding environment, compared to producing water using the existing watertreatment plants or reclaiming wastewaterfor reuse. Also with fewer chemicals, there are fewer deliverables to the plant and less disruption of surrounding neighbors, lower traffic impacts and reduced labor costs. The normal operation of the desalination treatment facility would require the continuous use of the following chemicals: ❖ Coagulant(Ferric Sulfate)for Removal of Naturally Occurring Solids from Seawater The purpose of coagulant addition is to remove solids,which occur naturally in the seawater. 4 Ferric sulfate would be added in typical dosage of 5 to 10 mg/L. Occasionally,mostly during rainy events,the ferric sulfate dosage may be increased to up to 20 mg/L for the duration of the event. The addition of ferric sulfate to the seawater would enhance removal of seawater solids and would generate a small amount of sulfates(3 to 5 mg/L vs.seawater sulfate concentration of 2,300 mg/L). The two products of the coagulation process (solids and sulfates)would be returned to the ocean via the power plant outfall after blending with the concentrate from the City of Huntington Beach April 5, 2005 3-34 Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report desalination process and the power plant cooling water. Because both iron and sulfates are environmentally safe,their discharge is currently not regulated by the California Ocean Plan. ❖ Sulfuric Acid for Seawater Alkalinity Adjustment 1 The seawater is slightly alkaline (has pH of 7.8 to 8.3)and sulfuric acid would be added as needed to make the natural seawater more neutral (less aggressive and corrosive to the equipment)before membrane treatment. The maximum dosage of sulfuric acid that may be (f used for seawater alkalinity neutralization is 30 mg/L. Typically, this dosage would be between 15 and 20 mg/L. Because the seawater has high alkalinity, the amount of hydroxide ions in the seawater is more than 10 times higher than the amount of hydrogen ions. Sulfuric acid,which contains an excess of hydrogen ions, is added in dosage to bring a balance between the hydroxide and hydrogen ions in the seawater, i.e. to reduce the pH from alkaline (pH of 7.8 to 8.3)to neutral (pH of 7). The added sulfuric acid reacts with the seawater creating two environmentally safe products:water(from the reaction of the excess hydroxide ions of the }' seawater and excess hydrogen ions of the acid) and sulfates. 1J ❖ Lime and Carbon Dioxide for Product Water Alkalinity and Softness Adjustment The water produced by the reverse osmosis desalination system(permeate)is very soft and cannot be used directly for potable purposes. Lime and carbon dioxide would be added to the permeate to increase product water alkalinity to a desirable range specified in the drinking water regulations. Lime and carbon dioxide addition for alkalinity adjustment and water distribution system corrosion control is verywidely practiced at many conventional and desalination water treatment plants today. Added lime and carbon dioxide would not be discharged to the ocean. ❖ Sodium Hypochlorite and Ammonia for Product Water Disinfection Sodium hypochlorite and ammonia would be added continuously for product water disinfection by chloramination. Chloramination is the current disinfection practice used at most of the other product water sources in the plant service area, which the product water from the desalination facility would be blended with. The applied dosages of sodium hypochlorite and ammonia are in a similar range of that used at the other water treatment plants in the area. 1L In addition, the desalination facility would intermittently use the following chemicals: ❖ Sodium Hvpochlorite and Bisulfite for Bacterial and Algal Control Chlorine in the form of sodium hypochlorite may need to be added to the seawater occasionally (for several hours per day and several days, two to three times per year) to protect the pretreatment facilities and the membrane equipment from excessive growth of algae and bacteria naturally conveyed in the seawater. Most of the sodium hypochlorite would be consumed in the disinfection process.The residual chlorine would be neutralized using sodium bisulfite. The chlorine would react with the seawater and the sodium bisulfite producing chlorides,sulfates,and sodium of amounts of less than 5 mg/L. For comparison, the concentration of chlorides in the seawater is usually in a range of 16,000 mg/L to 19,000 mg/L. The total increase in chloride, sodium and sulfate concentrations would be less than 0.05 % and would have no harmful effect on the marine environment. - . L City of Huntington Beach April 5, 2005 3-35 — }•c,: ti;of Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report ❖ Polymer for Enhanced Solids Removal form Seawater Occasionally, typically during rainy events as needed, polymer would be added in small dosages (0.5 to 1 mg/L) to enhance the removal of solids from the intake seawater. Polymer addition would be intermittent for the duration of the event. The used polymers would be of high quality food grade approved for potable water production and would be of type customary for water treatment plants. The added polymer would react with the solids in 0' the seawater and would be removed along with them and returned to the ocean. The amount of polymer in the discharge water would be negligible - below detection limits. ❖ Membrane Cleaning Chemicals Two times per year reverse osmosis membranes would be cleaned with chemicals similar to those used for household cleaning.The cleaning chemicals are citric acid (used for cooking in everyday life); hydrochloric acid (widely used for swimming pool conditioning); mild detergents(which can be found in products such as toothpaste and baby shampoo)and low- concentration caustic soda. The use of these chemicals for membrane cleaning is not unique for the proposed desalination facility.These membrane cleaning chemicals are used in all existing desalination installations in California (i.e.West Basin Desalter, Marina Coast Water District Plant, Irvine Ranch Desalter,etc.),Florida and worldwide. All chemicals listed i above would be of a high grade and are approved for potable water use by the National Safety Foundation. After membrane cleaning, the chemicals from the first rinse would be neutralized and sent to OCSD. Subsequent rinses would be mixed with the desalination facility concentrate and power plant seawater and discharged through the power plant outfall. Because of the small amount of chemicals used,the concentration of the cleaning chemicals would be below their detection limits and would be in compliance with all local, �l state and Federal discharge regulations. A more detailed description of the individual chemicals and their storage, delivery and handling at the proposed desalination facility is presented in Section 5.8, HAZARDS AND HAZARDOUS MATERIALS. 3.4 PROJECT NEED AND OBJECTIVES NEED FOR THE PROJECT It is well established that Southern California as we know it todaycould not exist without the re ion's 9 historic investment in numerous and varied local water projects. These well-known regional water projects include: the Los Angeles Aqueduct(operated by the Los Angeles Department of Water and Power); the State Water Project(operated by California Department of Water Resources [DWR]); and the Colorado River Aqueduct(operated by MWD),as well as award-winning recycling and other local water supply projects. MW D continues to encourage the development of local water projects to reduce reliance on the regional water projects and help meet the water needs of the region. The Seawater Desalination Project at Huntington Beach is one of several local water projects currently being proposed to meet Orange County's ongoing water needs. The project meets Orange County's water needs in four different ways. A. The project would provide Orange County with increased water supply reliability during times of drought or during shortages in other water supplies. City of Huntington Beach April 5, 2005 3-36 Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION { Draft Recirculated Environmental Impact Report B. The project would replace imported water supplies lost by Orange County to statewide and environmental needs. C. The project would provide a new water supply source to accommodate Orange County's increasing water needs as shown in the water plans adopted by state, regional and local water agencies. D. The project would provide a new source of supply, thus allowing operational flexibility in managing the amount of groundwater pumped from underground aquifers. This would assist in protecting the Orange County Groundwater Basin from seawater intrusion and/or replace groundwater supplies lost to overdraft concerns. A. The Project Provides a Drought-Proof Water Supply California has not experienced the hardships and environmental pressures of a prolonged drought since the early 1990s,but experts agree that similar or worse conditions of unreliable water supplies can and would reoccur. During long or extreme droughts, water supplies are less reliable, groundwater levels decline and conflicts increase among water users. Business is also adversely affected,jeopardizing the economy and ecosystems are strained,risking sensitive and endangered plants, animals, and habitats. w California's most severe recorded drought occurred in 1976-1977.Two consecutive years with little precipitation (fourth driest and the driest year in the recorded history)left California with record low storage in its surface reservoirs and dangerously low groundwater levels. Socioeconomic and environmental impacts were very severe during these extreme drought conditions. According to the Department of Water Resources,the total loss due to the drought during these two years exceeded $ 2.5 billion ($6.5 billion at today's cost). The most recent prolonged drought in California's recent history lasted 6 years from 1987 to 1992. Department of Water Resources studies indicate that in 1990-1992 the drought resulted in reduced gross revenues of about $670 million to California r agriculture. Energy utilities were forced to substitute hydroelectric powerwith more costly fossil-fuel generation at an estimated statewide cost of $500 million in 1991. The drought also adversely - affected snow-related recreation businesses. Some studies suggest as much as an$85 million loss for snow-related recreation businesses during the winter of 1990-91. Since the last drought (1987-1992), many notable changes have occurred and would alter the impacts of future droughts. Some changes would result in making it more difficult to respond to future drought conditions. For example, California's population has increased to about 36 million people as of January 1, 2004, meaning that over-all demand has increased. In addition,the State tL Water Resources Control Board adopted Decision 1630 in 1995, which requires higher flows to protect the San Joaquin and Sacramento River Deltas, meaning that less waterwould be available to those areas that rely on the imported water supplies of.the State Water Project. Other changes (primarily improvements in infrastructure)would make it easier to respond to future drought conditions. Completion of construction of the Coastal Aqueduct(DWR),the Morongo basin l pipelines (Mojave Water Agency), Diamond Valley Lake (MWD), Los Vaqueros Reservoir(Contra t Costa Water District), and five large-scale groundwater recharge/storage projects should add flexibility in operating California's water system. The Draft 2004 California Water Plan recognizes that one of the potential benefits that seawater desalination can provide is "increased water supply reliability during drought periods." (Draft �f} California Water Plan,Volume 2, Resources Management Strategies, Desalination, page 3.) "The primary benefit of desalting is to increase California's water supply. Seawater desalting creates a new water supply by tapping the significant supply of feedwater from the Pacific Ocean" (page 3). r Because the supply available from the Pacific Ocean is not affected by drought conditions, the City of Huntington Beach April 5, 2005 3-37 �. Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report Seawater Desalination Project at Huntington Beach would add even more flexibility in operating California's water system, and would provide particular drought protection in Orange County. B. The Project Provides a Replacement Water Supply Although Orange County has made a significant financial investment in the regional imported water system (through ongoing contributions to MWD), and the system has historically met all of Orange t, County's water supply needs,there is concern regarding the amount of waterthatwould continue to be available for delivery through the imported water system. Increasing regulatory activity and environmental water needs in Northern California and in the Mono Lake area have reduced the amount of imported water supply (compared to system capacity and earlier projections) that is Y available to Southern California. Likewise, there is a fundamental change occurring in the availability and use of Colorado River water because California,for the first time,would be required to reduce the amount of Colorado River water it uses. Implementation of the Colorado River Water Use Plan would, among other things, result in a reduction of up to 1 million acre-feet per year as compared to the highest amount diverted in the past 25 years (from a high of 5.4 million acre-feet per year to the California allotment of 4.4 million acre-feet per year). The project provides a new source of supply to offset any imported water supply losses experienced by Orange County. C. The Project Provides a Planned-For Supply to Meet Increasing Water Needs Water planning documents are legally required to provide projections of future water needs(based on population projections and other factors)and to identify,to the extent feasible,where the water supplies to meet those needs would be found. As is discussed below, state, regional and local planning documents have identified seawater desalination as one of the future supplies required to meet Orange County's water needs. The California Water Plan The DWR provides an assessment of anticipated statewide population growth and related water -� consumption statistics in their"Bulletin 160 series"California Water Plan.2 The DWR employs these projections in developing and implementing long-range strategies addressing California's water demands. The 1998 Plan provided readers with estimates of the magnitude of dry-period water shortages in different areas of the state and also presented some options for reducing those shortages. DWR projected 2020 statewide water shortages at approximately 2.4 million acre-feet in an average water year, and 6.2 million acre-feet in drought years. In response, Senate Bills (SB) 221 and 610, which became effective January 1, 2003, require demonstration of water supply reliability prior to development. In the 2004 Plan, DWR and water industry stakeholders wanted a more comprehensive analysis that included economics,water quality,and environmental and social considerations rather than focusing on the water budgets presented in Bulletin 160-98. As explained by DWR, this goal was not ` - realized. "The analytical work could not be completed for use in [the 2004]water plan update. Without this analysis, update 2004 lacks the information to make the types of } 2 In 1957,the Department of Water Resources published Bulletin 3,the California Water Plan. Bulletin 3 was followed by the Bulletin 160 series. The Bulletin 160 series was published six times between 1966 and 1993,updating the California Water Plan. A 1991 amendment to the California Water Code directed the Department to update the plan every five years. Bulletin 160-98(the 1998 Plan)is the latest adopted plan in the series.However,•the 2004 Water Plan Update has been available in draft form for several months. The 2004 Plan will not be adopted until Fall 2005. This EIR presents information provided in both the 1998 Plan and the draft 2004 Plan. City of Huntington Beach April 5, 2005 3-38 Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report regional-specific water budget comparisons afforded by Bulletin 160-98. However, update 2004 provides qualitative discussions and presents the analytical approach for use in update 2008 and beyond. If the past is any indication, we expect the analytical approach to continue to evolve long after 2008 is completed." (Draft 2004 Plan, Volume 1, Chapter 3, Box 3-xx, "Evolving Analytical Approach").3 The draft 2004 Plan extended the planning period to 2030, and includes an estimated population increase of 14 million people, from about 34 million to 48 million. (Volume 1, Chapter 2, page 2) The draft 2004 Plan also employs "a new analytical approach to be refined over the next several years and to be used in preparation of California Water Plan Update 2008.The major change in this analytical approach from past water plan updates is the evaluation of multiple plausible future scenarios rather than a single projected future." (Volume 1, chapter 3, page 1.) DWR considered numerous factors that could vary in the future and developed three future scenarios (that would be used to begin the analysis for water plan update 2008). • Scenario 1—Current Trends: Continue based on current trends with no big surprises. I • Scenario 2—Resource Sustainability:California is more efficient in 2030 water use than today while growing its economy and restoring its environment. • Scenario 3—Resource Intensive: California is highly productive, respectful of the environment, yet less efficient in 2030 water use than today. (The three scenarios are listed in the draft 2004 Plan, Volume 1, Chapter 3, Page 14.) While the analysis is not yet completed, numerous"Resource Management Strategies"have been identified in the draft 2004 Plan to address the three scenarios. One of those strategies is seawater desalination. The 1998 Plan recognized that"seawater desalting is sometimes described as the ultimate solution to Southern California's water supply shortfall"(Bulletin 160-98,page 7-70),but failed to provide any projections regarding the estimated future water supply to be provided by seawater desalination projects. The draft 2004 Plan surveyed "the number and capacity of seawater desalting plants in operation and in design and construction as of 2002 and plants that are currently planned or projected for construction" (Vol. 2, Resource Management Strategies, Desalination, page 3). According to the draft 2004 Plan,the following table (Table 3-2,DESALTING IN CALIFORNIA FOR NEW WATER SUPPLY) includes "the plants proposed in response to the MWD solicitation (see below)and plants in Huntington Beach, the Monterey Bay area and Marin County." As referenced in the above table, DWR projects that a combination of six new seawater desalination facilities would provide up to 187,100 acre-feet of California's urban water supply by 2030. The same number (rounded to 200,000 acre-feet) is listed as the target amount to be produced by seawater desalination,one of the 25"Resource Management Strategies"featured in the draft 2004 Water Plan Update's "Strategy Investment Options Table." (Draft 2004 Plan,Volume 1, Findings and Recommended Actions.) 3 The California Water Plan Volume 1 —The Strategic Plan, Chapter 3, Planning for an Uncertain Future, Internal t� Review Draft,June 21,2004. L City of Huntington Beach April 5,2005 3-39 ~ ' N� Seawater Desalination Project ot Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Y� Table 3-2 (from Draft 2004California Water Plan, Volume 2) DESALTING IN CALIFORNIA FOR NEW WATER SUPPLY ion Feedwater Number of Annual Number of Annual Number of Annual Source Plants Capacity Plants Capacity Plants Capacity 1. Capacity in Acre-feet per year. No.of plants is number of new plants. 2. Design and Construction-Construction underway or preparation of plans and specifications has begun. -� 3. Planned-Planning studies underway for new or expanded capacity 4. Projected-Assumed new or expanded capacity of plants in operation or design and construction. Sources: "Water Desalination Report"and Worldwide Desalting Plants Inventory series by International Desalination �N Southern California's Integrated Water Resources Plan N� In 1986 the major imported water supplier in the region. MVVC).first adopted "Southern California's - Integrated Water Resources Plan" (the"IRP") representing a dramatic shift in water management and resource planning for the region. The |RP recommended that groundwater recovery projects, �N storage p �eo1a.xv�terreoy�Ungp �e�t�.xvaber�one#srp ��obaandvv�0er�one�rvobonprojects be ^ -^ �-' considered in addition to available imported supplies to determine the"resource mix"available to the region. The IRP set resource development targets(in acre-feet per year)for water conservation and for each of the various water supply sources needed bz meet projected vvatardennondo. Although m� no target was set for desalinated ocean water as a future supply,the 1996 IRP stated that,based on feasibility studies on potential projects, about 200.000 acre-feet per year (of desalinated ocean water) could be developed by201O (p. 3-12). The 2003 IRP Update (approved by MWD in July 2004) refined the resource development targets booed on changed conditions and updated the resource targets through 2025 (see Table 3-3' UPDATED RESOURCE TARGETS[WITH 8UfPL\/B . The2003 IF(P Update continued to confirm that "[t]here is no single cornerstone for regional supply reliability. Because of this, the region has developed an integrated resource plan that depends on many sources of supply' (p. 11). �N |n the 2003 /RPUpdate.seawater deoo|inoUonbecanne a targeted reoounze.included with recycling and groundwater recovery in the mix of necessary local resources (pp. 31-33). According to the 2003 IRP Update: "Recent improvements in membrane technology and new plant ��. siting strategies have reduced costs,and may make seawater desalination a potential supply option for1heregion. |n20O1. YWVVD issued a competitive RFP for seawater desalination projects vvith1he goal of developing up to 50,000 acne-feet per year. In light of the enthusiastic response to the proposals submitted under the RFP, this report [the 2003 |R|F, Update] includes o revised |000| resources target that can accommodate o seawater deea|inobon goal of15O,OOOaona-feet.^ .�� yWVV[}'a 2008 Report on Water Supplies explains NYVV[}'e Seawater Desalination Program. "Launched in the summer of 2001,the program would provide financial and technical support forthe development of local cost-effective seawater deoa|ination projects. Aua|| forpnopooa|apnoduced fi*ep �ac�. /r�f�rtmm�otion0.3. (�U8�L8~�T7\��/�V��(�T�\ proposed-^ ` -'. , were evaluated by MVVC>'s review committee of staff and conmu|tante. Collectively,the projects �N City of Huntington Beach April 5, 2005 - m� 3-4O Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report Table 3-3 (from 2003 IRP Update) UPDATED RESOURCE TARGETS (WITH SUPPLY BUFFER) 1996 IRP IRP Update Chan'e IRP.Update 202b-$ 2020 2025. 9 Conservation 882,000 1,028,000 +145,600 1,107,000 • Recycling +250 000 • Groundwater Recovery 500,000 750,000 750,000 • Desalination (buffer) Colorado River Aqueduct * 1,200,000 1,250,000 +50,000 1,250,000 State Water Project 593,000 650,000 +57,000 650,000 Groundwater Conjunctive Use 300,000 300,000 0 300,000 CVP/SWP Storage and Transfer 300,000 550,000 +250,000 550,000 buffer MWD Surface Storage " 620,000 1 620,000 1 0 1 620,000 * The 1,250,000 acre-feet supply from the Colorado River Aqueduct is a target for specific year types when needed. ] Metropolitan is not depending upon a full aqueduct in every year. **Target for Surface Storage represents the total amount of water that can be extracted from storage. could produce about 132,000 acre-feet of drinking water per year.,4 The 56,000 acre-foot per year Seawater Desalination Project at Huntington Beach is independent from MWD's Seawater Desalination Program,but would still be considered an Orange County local project for purposes of the 2003 IRP Update. Orange County Water Plans The County of Orange and the service area of the Municipal Water District of Orange County (MWDOC) are located at the center of the MWD service area. In addition to the water planning information available in the California Water Plan and the IRP, local water planning information isi also readily available for Orange County water supplies. The Urban Water Management Planning Act of 1983 requires all urban water suppliers to prepare and adopt an Urban Water Management Plan, and to update that plan every five years using a 20-year planning horizon. As a member agency of MWD, MWDOC supplies imported water to 32 local water purveyors throughout the County of Orange(all of Orange County except the cities of Anaheim, Fullerton and Santa Ana). The most recent MWDOC Regional Urban Water Management Plan (UWMP), dated L, December 20, 2000, provides an excellent basis for discussing Orange County water planning efforts because the 2000 UWMP includes countywide information to supplement the information specific to MWDOC's service area. According to the 2000 UWMP, Orange County 2020 water needs are projected to be as high as 856,000 acre-feet in an average year. If conservation, also known as water use efficiency(W UE), efforts are successful, the County's water needs can be reduced by 99,000 acre-feet per year to �l= 757,000 acre-feet. Refer to Table 3-4, PROJECTED ORANGE COUNTY WATER DEMAND THROUGH 2O20 (from the 2000 UWMP, page 2-10). Figure 3-1, ORANGE COUNTY WATER SUPPLY SOURCES (from the 2000 UWMP, page 3-2) identifies expected sources of supply to meet a hypothetical water need of 700,000 acre-feet. 1 4 The five desalination projects are proposed by the City of Los Angeles,City of Long Beach,Municipal Water District of Orange County,San Diego County Water Authority,and West Basin Municipal Water District. City of Huntington Beach April 5,2005 3-41 L Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report The information in the 2000 UWMP is in the process of being updated by MWDOC to reflect MWD's 2003 IRP Update assumptions (a revised UWMP must be adopted by MWDOC in 2005). In completing the IRP Update, MWD included two specific assumptions for Orange County: 1) an increase in conservation from 84,000 acre-feet in 2005 to 148,000 acre-feet in 2025 and 2) an �. increase in "local supplies"from 350,000 acre-feet in 2005 to 512,000 acre-feet in 2025 (April 22, 2004 presentation by MWDOC: "Orange County's Part in the IRP"). The conservation assumptions in the 2003 IRP Update are more aggressive than those projected in MWDOC's 2000 UWMP. Table 3-4 indicates total conservation(WUE)of 32,000 acre-feet in 2000 and projects only 57,000 acre-feet for 2005. The 2020 projection of 99,000 acre-feet in the 2000 UWMP is 49,000 acre-feet short of the 2003 IRP Update assumption. In addition,the assumption that Orange County can increase local supplies to 512,000 acre-feet is dependent on continued significant groundwater production. According to MWDOC, a "lower groundwater production" scenario could leave Orange County up to 52,000 acre-feet short of the 512,000 acre-foot local project goal in 2025 even assuming that all existing and planned recycling projects(including Phase I of the Orange County Water District's Groundwater Replenishment System)were fully operational (April 22, 2004 presentation by MWDOC: "Orange County's Part in the IRP"). The 2000 UWMP specifically stated that "seawater desalination is undoubtedly in the future of Orange County's water supplies" and describes a seawater desalination facility within the City of Huntington Beach (situated adjacent to the HBGS) as a "future water supply for Orange County" . (2000 UWMP, page 3-13). In 2002, MWDOC submitted a proposal for the South Orange County Seawater Desalination Project to MWD in response to MW D's call for proposals(refer to Table 6-4, PLANNED DESALINATION FACILITIES ALONG THE SOUTHERN CALIFORNIA COAST). That Table 3-4 PROJECTED ORANGE COUNTY WATER DEMAND THROUGH 2O20 Orange County Urban Water Demand Notes Year Population;" acre-feet (millions) Without WUE Net With `o'v'UE Amount VVUE 1990 2.40 617,000 - 617,000 HEstora,al 1995 2.59 563,000 13,000 570,000 Yr2000-2^' 3�t year of dry, 2000 2.86 706,000 32,000 674,000 warm weather 2005 3.00 707.000 57,000 650,000 Praiecfions assume a`normar weather year.Actual ' a 2010 3.09 755 000 72,000 683,000 demands may vary on he 2015 3.15 798.000 86,000 712,000 order of+1-10%from`norma' due to weather and economic 2020 33.23 856,000 49,000 757,000 condi5orts. i6 Increase 1 QW to 2020 35% 39% n!a 23% Increase 23GD to 2�0 13a/o 27°la 2 % 12% l°l populstion estimates by the Center for Demogrspluc Reseuch,CKT Fullerton- f!1l umbers represex cccrosu= tive taban hater demand.Includes recyclednarer;does not in.-hide agaculttnal use-does not taartde reale3is ent of ztaraee.. Projections per tM`D-ALA1N modal_ "' atu-onsened due to both—actire"water ef5ciency effo-ts and U3 the=`pa.SIre"efform of plumbing Lades. Estimate; per 3.f�L D 4i s Tl�=o el. City of Huntington Beach April 5, 2005 ' 3-42 Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report Figure 3-1 ORANGE COUNTY WATER SUPPLY SOURCES Orange County Water Supp►iy Sources FY 99-00 State Project Colorado River 113,000 AF � �Y�� - 227,000 AF Metropolitan Water district 309,000 AF - Import Replen. 31,000 k San Gabriel Basin Santa Ana River �- 12,000 AF ° a 200,000 AF into Basin � h S Santiago Creek � f � 000 AF Consumpt1e ater[}�emand OCW D 17Gfi Groundwater Basin Pumping ' b Small Local 338,000 AF aBasins 3,000 AF Recycling Plants 30,000 AF Direct, 6,000 AF into Basin project has been included in the MWD Seawater Desalination Program. MWDOC continues to list ocean desalination as a one of the"next steps for Orange County"togetherwith additional recycling, additional groundwater recharge and additional conservation (April 22, 2004 presentation by MWDOC: "Orange County's Part in the IRP"). D. The Project Provides a New Source to Protect Against Seawater Intrusion The Orange County Water District (OCWD) oversees management of Orange County's most important local water supply—the Santa Ana River Groundwater Basin (the "Basin"). The 2003- 2004 Orange County Grand Jury studied groundwater conditions in the Basin and provided certain operational recommendations to OCWD. This study is entitled,"The Groundwater Replenishment System: Providing Water for the Future". All of the facts set forth in this section were identified during the Grand Jury study. OCWD does not manage the Basin by trying to keep it full. Rather it has established a goal of maintaining an accumulated overdraft of about 200,000 acre-feet to allow storage space for replenishment when excess water is available during wet years(page 8). In fact,the Grand Jury commended OCWD for its"efforts to capture and recharge floodwater"stating that the"average of 70,000 acre-feet of storm flows captured each flood season saves Orange Countywater users more than$17 million peryear' j (page 23). In 1965,OCWD installed injection wells along the coast near the mouth of the Santa Ana River(at a place called the "Talbert Gap") to pump water into the shallow aquifers. Injecting water into the shallow aquifers produced a groundwater mound that stood higher than sea level. With a barrier in place to retard seawater intrusion, it became feasible to draw water levels down during dry periods City of Huntington Beach April 5, 2005 3-43 Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report when local surface water and imported water sources were in short supply, instead of simply keeping the basin as full as possible to prevent seawater intrusion. During wet periods,the depleted aquifer could be replenished with storm runoff and excess imported water. Utilizing this method of groundwater management, OCWD allowed the amount of depleted groundwater supply (basin overdraft) to fluctuate between "full" in 1969 to an overdraft of nearly 500,000 acre-feet in 1977 without causing irreparable damage to the resource (page 7). Groundwater withdrawals from the Basin have increased from less than 200,000 acre-feet per year in the early 1960s to more than 350,000 acre-feet per year in 2002 (page 7). In comparison to the 350,000 acre-feet of annual withdrawals from the Basin during the period 1998-2002, the natural recharge is small (estimated by the OCWD to be about 70,000 acre-feet per year) (page 9). The majority of replenishment water is from"artificial recharge"operations whereby OCWD captures the flow of the Santa Ana River(which currently averages about 150,000 acre-feet per year)in recharge facilities located in the river bed and through deep recharge basins (abandoned sand and gravel pits)near the river. OCWD also captures an average of about 70,000 acre-feet of storm flows each year. To make up for the imbalance between this 290,000 acre-feet of recharge and the 350,000 acre-feet of withdrawals, OCWD has purchased an average of 60,000 acre-feet of imported water ' from MWD each year for supplementary recharge. If the accumulated overdraft becomes excessive, OCWD uses complex financial disincentives to discourage groundwater withdrawals. Since the 1997-98 water year(a wet year), the County has experienced dry conditions, resulting in overdrafts in excess of 30,000 acre-feet per year. Groundwater levels have declined more than 20 feet throughout the basin since 1998, and water levels near the coast are currently as much as 80 feet below sea level. In November 2002, the accumulated overdraft was estimated to be more than 400,000 acre-feet,which prompted OCWD to take actions to limit groundwater production rates and reduce the rate of withdrawal to about 324,000 acre-feet per year in 2003 (page 8). One key finding made by the Grand Jury was that"depressed groundwater levels near the coast have exacerbated the inland advance of saline water[into the Basin]" (finding No.4, page 21). To remedy this condition, the Grand Jury recommended that "Orange County Water District curtail groundwater withdrawals from deep wells and obtain blending water for the Talbert Gap seawater- intrusion barrier from other sources"(recommendation No. 3, page 22). The Grand Jury also found that"changes in groundwater management strategies would be required to increase the current rate of groundwater withdrawals to satisfy future needs" (finding No. 8, page 21). One such strategy known as the Groundwater Replenishment System (GWRS) is currently being pursued by OCWD. According to the Grand Jury study, OCWD: "would convert 100 million gallons per day of wastewater from the Sanitation District's sewer collection system into 72,000 acre-feet per year of desalted and purified wastewater. Treated wastewater from the Sanitation District wastewater treatment facilities would be filtered through a state-of-the-art micro-filtration system y to remove particulate matter, passed through reverse-osmosis membranes to remove dissolved salts, and purified with ultraviolet and hydrogen-peroxide disinfection to produce `ultra pure'water that exceeds all drinking water standards. The purified water would be used to protect and replenish Orange County's underground water supplies" (page 3).' The 72,000 acre-feet would essentially offset the 60,000 acre-feet of imported water purchased from MWD each year by OCWD, and, when added to the normal year recharge of 290,000 acre-feet, could allow for a slight increase in available groundwater supply. However, the coastal pumping depression problem would likely remain. According to the Grand Jury, OCWD's modeling efforts City of Huntington Beach April 5, 2005 3-44 Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report "clearly illustrate that simply increasing recharge in the Water District recharge facilities and extending the seawater-intrusion barrier[as proposed by the GW RS project]would stabilize,but not alleviate, the coastal pumping depression" (page 16). The Seawater Desalination Project at Huntington Beach could provide an alternative supply of water to coastal communities that would } allow operational flexibility in managing the groundwater basin. PROJECT OBJECTIVES The overall objective of the project is to provide Orange County with a long-term, reliable, high quality local source of potable water. Project implementation would create a local drought-proof supply of domestic water and would reduce Orange County's dependence on imported water, consistent with the goal of integrated water resource management. A key advantage of the selected site is to utilize existing ocean intake/discharge lines of sufficient seawater volume to avoid the impact of constructing new ocean intake/discharge facilities. The project is intended to realize the following objectives: ❖ Provide a reliable local source of potable water to Orange County that is sustainable independent of climatic conditions and the availability of imported water supplies or local groundwater supplies; ❖ Provide product water that meets the drinking water requirements of the Safe Drinking Water Act (SDWA) and the Department of Health Services (DHS); ❖ Reduce salt imbalance of current imported water supplies by providing a potable water source with lower salt loads for blending with existing supplies; ❖ Remediate the subject site of on-site contaminants resulting from approximately 35 years of use as a fuel oil storage facility in order to protect the health and safety of those in the surrounding community; ❖ Create ecosystem and biologic resource benefits that may accrue due to decreased 1� pressures on existing water resources and reduced contamination within receiving waters; and ❖ Minimize demands on the existing imported water system. 3.5 PROJECT PHASING The demolition, remediation, and construction process of the proposed project would last approximately 24 months,including time necessaryto acquire all required agreements,permits,and approvals. Project phasing would be divided into three separate categories, composed of the following: ❖ On-Site Desalination Facility Construction: This portion of the proposed project would last approximately 24 months, and would include such activities as on-site demolition, J grading/excavation, construction of desalination facilities, landscaping, and facility startup/testing. Import and export of earthen materials would occur primarily during the first six months and last four months of this phase of the project. ❖ Off-Site Product Water Transmission Pipeline Construction: This portion of the project would last approximately 21 months,and would start about three months after the beginning ` of on-site desalination facility construction. This phase would include such activities as pipeline installation, implementation of pipeline under waterways/major roadways, soil remediation, removal of pipeline, and facility startup/testing. Import and export of earthen materials would occur primarily during the middle 12 months of this phase. City of Huntington Beach April 5, 2005 3-45 4� Seawater Desalination Project at Huntington Beach 3.0 PROJECT DESCRIPTION Draft Recirculated Environmental Impact Report ❖ Off-Site Product Water Underground Booster Pump Stations Construction: This phase of the proposed project would last approximately 18 months,and would begin approximately six months subsequent to the commencement of on-site desalination facility construction. This portion of the project would include such activities as grading/excavation/paving,pump station construction, emergency power generator construction, landscaping, and facility startup/testing. Import and export of materials would occur mainly within the first six months and final six months of the phase. l It should be noted that it is anticipated that all three phases would be implemented concurrently for the final 18 months of the proposed project. 3.6 AGREEMENTS, PERMITS, AND APPROVALS REQUIRED The following agreements, permits, and approvals are anticipated to be necessary: Approval/Permit, Permits to Operate Agency Final EIR Certification City of Huntington Beach Conditional Use Permit City of Huntington Beach Coastal Development Permit 5 City of Huntington Beach Franchise Agreement City of Huntington Beach Owner Participation City of Huntington Beach Agreement and/or Development I Agreement Domestic Water Supply Permit State of California Department of Health Services Coastal Development Permit (CD P)s California Coastal Commission (CCC) NPDES Permit Santa Ana Regional Water Quality Control Board Permit to Operate South Coast Air Quality Management District Encroachment Permits U.S. Army Corps of Engineers (Santa Ana River Crossing) Caltrans, District 12 (SR-55 undercrossing) County of Orange (channel crossings, pump station) City of Huntington Beach (product water pipeline) City of Costa Mesa (product water pipeline) Mesa Consolidated Water District (product water pipeline) Institutional Agreements Various cities, agencies, and regional water purveyors(including the Metropolitan Water District of Southern California [product water pipeline]) Lease Agreement California State Lands Commission Industrial Source Control Permit Orange County Sanitation District The City's Coastal Development Permit approval may be appealed to the California Coastal Commission. 6 A CDP is required directly from the CCC for the ocean discharge. City of Huntington Beach April 5, 2005 3-46 r 4.0 EXISTING CONDITIONS/ � ENVIRONMENTAL SETTING � I 4.0 EXISTING CONDITIONS/ ENVIRONMENTAL SETTING 4.1 PROJECT SITE PREVIOUS USE OF THE SITE The proposed project site exists within a fuel oil storage tank facility constructed in 1961. This tank facility provided a fuel source for the Southern California Edison (SCE) Huntington Beach Generating Station (now owned by AES Huntington Beach, LLC), which began operating in 1958. By the late 1980s, the SCE Generating Station was utilizing primarily natural gas as a fuel source for electric energy generation. Although fuel oils were no longer necessary for operation of the generating facility, SCE was required to maintain a back-up fuel source, and the storage of fuel oils at the tank facility continued. SCE then received notice from the California Independent Systems Operator (ISO) that back-up fuel supplies were no longer necessary, thus eliminating the need for the storage tanks associated with the generating facility. In May 2001, AES Huntington Beach, LLC, owner of the Huntington Beach Generating Station (HBGS), acquired ownership of the fuel oil storage tank area from SCE, and has entered into an agreement with Poseidon Resources Corporation for the lease of a portion of the property(refer to Section 3.413, PROJECT SITE LEASE). The storage tank area contains a total of six tanks, ranging in capacity from 924,000 gallons to 8.64 million gallons. Implementation of the proposed project would require the demolition of three of the six tanks (three fuel oil tanks). The three fuel oil storage tanks to be demolished have historically been referred to as the South, East, and West fuel oil storage tanks (refer to Exhibit 3-2, SITE VICINITY MAP for their precise location). These storage tanks are 40 feet high, cylindrical in shape and are surrounded by 10 to 15-foot high earthen containment berms, pipelines, pumps, and associated structures. On- site vegetation consists mainly of non-native low-lying shrubs and bushes along the eastern border of the project site. The topography of the site is relatively flat, gently sloping to the southwest, with an elevation of approximately five feet above mean sea level (msl) (refer to Exhibit 5.7-1, DESALINATION FACILITY SITE PHOTOGRAPHS). SURROUNDING ADJACENT LAND USES Surrounding adjacent land uses to the proposed desalination facility include HBGS to the southwest, a wetland area to the southeast, the Huntington Beach channel operated by OCFCD flood channel to the east, a fuel oil storage tank to the north, and an electrical switchyard to the west. Additional surrounding land uses include Pacific Coast Highway to the south; the Pacific Holdings storage tank facility to the east; Ascon/Nesi Landfill to the northeast; commercial, industrial, recreational, and residential uses to the north; and Newland Street, Huntington-By- The-Sea Mobile Home Park, and Cabrillo Mobile Home Park to the west. Uses surrounding the HBGS intake/discharge pipeline connections consist of various generating station uses and parking areas. LAND USE/PLANNING The City of Huntington Beach General Plan designates the proposed project site as Public (P). Typical permitted uses within areas of this designation include governmental administrative and related facilities, such as utilities, schools, public parking lots, infrastructure, religious, and similar uses. The project site is zoned as Public-Semipublic with Oil and Coastal Zone Overlays w (PS-0-CZ). This zoning district provides for similar uses to those allowed by the City of City of Huntington Beach April 5, 2005 4-1 Seawater Desalination Project at Huntington Beach 4.0' EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING Huntington Beach General Plan. The Seawater Desalination Project at Huntington Beach is a permitted use. Refer to Exhibit 3-2, SITE VICINITY MAP for additional information. HUNTINGTON BEACH GENERATING STATION Background and History As stated above, the HBGS began operation in 1958 under the ownership of SCE. The power I� plant utilized fuel oil for production of electricity through its five generating units until the late 1980s, when the generating units were converted for natural gas operation. In 1995, SCE retired two existing generating units (Units 3 and 4) due to limited use. AES Huntington Beach, LLC, acquired the HBGS from SCE in 1998, and later acquired the fuel oil storage tank property in 2001. In 2001, AES filed an Application for Certification (AFC) with the California Energy Commission (CEC) to rebuild and upgrade ("retool") Units 3 and 4 to meet increasing electrical demand in California. The AFC (which was ultimately approved by the CEC in May 2001) and subsequent retool brought the total electrical generation capacity of HBGS to 1,103 megawatts (MW). Until October 2002, Units 1 through 5 were available for operation at the HBGS. However, as part of a South Coast Air Quality Management District (SCAQMD) order, Unit 5 (a combustion turbine unit) was permanently removed from operation, and all permits for this unit were surrendered. As such, current operation at the HBGS consists of four steam turbine generating units with a total capacity of 880 MW. Conditions applicable to AES by the CEC as part of the AFC include: {� ❖ EMERGENCY-1: In consideration of this expedited certification to the Governor's �J Executive Order and before commencing commercial operation of the project, AES shall enter into an electricity sales contract with DWR to sell the generation from Huntington Beach Units 3 and 4 to address the electricity supply emergency. ❖ EMERGENCY-2: This certification is granted by the Energy Commission for a period of ten (10) years. An interim review shall be conducted as follows. No sooner than January 1, 2006 and no later than April 1, 2006, the project owner shall present evidence to the Commission supporting the following Commission findings: l., • the project owner has substantially complied with the conditions of certification; • the project owner has implemented or is implementing to the extent feasible the mitigation measures it is responsible for implementing as a result of studies required by the conditions of certification; and • all currently required permits (i.e. NPDES) are in force and the project owner is in substantial compliance with each permit. If the Commission determines that it cannot make all the above findings, and if the project owner fails, within a period of 60 days from such determination or such other period as the Commission shall determine to be reasonable under the circumstances, to bring the project into compliance, the Commission may terminate certification or take any other action permitted by law. r- ❖ EMERGENCY-3: On or before June 30, 2004, AES shall submit to the Commission and the City of Huntington Beach a Master Development Plan setting forth its plans for the .� long-term use of the Huntington Beach Generating Station site beyond September 30, 2006, including but not limited to its plans for the operation, repowering, reconfiguration, City of Huntington Beach April 5, 2005 4-2 Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING closure, decommissioning, moth-balling, demolition, or dismantling of any operating unit then in place.' Regulatory Framework/Compliance The energy sector of California is regulated by a number of agencies. The CEC is the principal point of oversight as it relates to major power generating facilities. The CEC has the exclusive authority to certify the construction and operation of thermal electric power plants 50 megawatts or larger and all related facilities in California. The CEC's site certification process provides a timely review and analysis of all aspects of a proposed project, including need, public health and environmental impacts, safety, efficiency, and reliability. Once operating permits are issued for an electric generating facility, the operating permits are managed by responsible agencies, including: the Regional Water Quality Control Board (storm water and wastewater discharges/NPDES) and the regional air quality management district (air emissions). The power plant applicant is responsible for the periodic renewal of these permits with the applicable responsible agency. The California Public Utility Commission (CPUC) regulates market behavior and pricing for the power sector in California. The Federal Power Commission (FPC) performs a similar function at the federal level. The ISO regulates the operation of the electric transmission grid and directs the dispatch of generating units to serve the system. HBGS Operations The existing HBGS consists of four generating units (Units 1-4). Each unit is equipped with two condensers. Units 1 and 2 are rated at 215 net MW and Units 3 and 4 are rated at 225 net MW. HBGS has a total nominal generating capacity of 880MW. The station uses a once-through cooling system with an offshore intake and outfall. The existing HBGS intake/discharge facilities traverse land owned by the California State Lands Commission (CSLC), and the land is leased to AES. Cooling water is supplied to the generating station from the ocean through an intake structure located 1,840 feet offshore (see Exhibit 4-1, HBGS INTAKE AND OUTFALL LOCATION MAP). The generating station's offshore seawater intake structure consists of a vertical riser with a horizontal velocity cap supported five feet above the opening to the cooling water conduit. The entire structure rises about 15.8 feet above the ocean floor where the total water depth is approximately 34 feet. Cooling water flow varies between 127 MGD and 507 1 MGD depending on the number of pumps that are in operation. The intake collects seawater at a mean velocity of 2.0 feet per second and conveys the flow through a 14-foot diameter conduit, with screening, to the HBGS intake structure located on the HBGS property. The HBGS intake structure consists of an open forebay from which the seawater flows through two trash racks, each constructed of vertical steel bars with three-inch openings between the bars. Downstream of the trash racks, the water flows through four vertical traveling screens with 3/8-inch mesh screening. The screened seawater is then conveyed through a 14-foot x 11-foot rectangular conduit into the generating station cooling water pump well structure. The condensers are supplied with cold seawater by eight cooling water pumps (two for each generating unit). Six of the cooling water pumps (Units 1, 2 and 4) are rated at 63.4 MGD (44,000 gallons per minute [gpm]), while the remaining two pumps (Unit 3) are rated at 66.7 MGD (46,300 gpm). The cooling water pumps convey the screened seawater through thousands of 7/8-inch diameter tubes that make u the generating station's condensers. Steam exiting the facility's P g 9 9 Y ' Application for Certification 00-AFC-1 California Energy Commission Decision May 2001. PP � 9Y � Y City of Huntington Beach April 5, 2005 4-3 Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING turbines, passes over the outer surfaces of the condenser tubes and is condensed back to a liquid state to be pumped back to the boilers. During this process heat is transferred to the seawater and its temperature is raised, on average, by 18°F (10°C). The maximum temperature increase specified in the facility's NPDES permit is 30OF (16.50C). After passing through the condensers, the warmed seawater (cooling water) is returned to the 1 discharge well located at the HBGS intake structure via two 108-inch (nine-foot) diameter discharge pipelines. From the discharge well the cooling water flow is conveyed back to the ocean via a single 1,500-foot long, 14-foot diameter conduit, then through a discharge structure identical to the intake structure except for the absence of a velocity cap. Instead, the discharge vertical riser structure is capped with a 12-inch by 18-inch mesh screen constructed from one- inch by three-inch flat bars. Design and Operation Criteria of Condenser Cooling Water Systems Most industrial production processes need cooling water to operate efficiently and safely. Refineries, steel mills, petrochemical manufacturing facilities, electric utilities and paper mills all rely on equipment or processes that require efficient temperature control. Cooling water systems control these temperatures by transferring heat from the hot process fluids into cool water. At generating stations, such as the HBGS, the process fluid to be cooled is steam after it has passed through the steam turbine and generated power. As the cooling occurs, the cooling water itself gets warmer and must be cooled or discharged and replaced by a fresh supply of cooling water. Where the cooling water is used once and then discharged, the system is known as once-through cooling. Once-through cooling systems characteristically involve large volumes of water and small increases in water temperature. These systems are usually employed when water is readily available,in large volume at low cost. Once-through cooling systems for generating stations are typically operated at a high load factor. They are started several hours prior to startup of the balance of the facility, and are operated several hours after facility shutdown in order to fully cool the steam condensing equipment. Although simple in design and operation, once-through cooling systems are subject to corrosion, scaling and microbial growth and fouling. Microbial growth and fouling result in energy losses due to increased.frictional resistance and increased heat transfer resistance, ` increased capital costs for excess equipment capacity to account for fouling, increased maintenance costs for replacement of equipment with severe under-deposit corrosion, and shutdowns to clean equipment with loss of production. With .respect to the HBGS, the most significant problems are debris plugging the condenser tubes, algae growth, and mussel growth and the requirement that all three of these are controlled without removing the units from service. The cleaning methods for bio-fouled (bio-fouling is the attachment of biological materials such as protozoa, amoeba, fungi, and other organisms to surfaces, forming a "bio-film") systems consist of physical and chemical methods (biocides sanitization). Physical methods are simple but show limited efficacy (flushing) or are effective only for loosely adherent films (backwashing) or for thinner deposits (non abrasive sponge balls). These cleaning methods also require the power generation units to shutdown. The most common approach to bio-fouling problems in cooling water systems is the use of biocides, substances able to drastically reduce the total number of cells in the feedwater and to attack and weaken the stability of the bio-film. City of Huntington Beach 4-4 April 5, 2005 YYYJJJ Mae M M SO � � � ar M �M rr. mom M ■r M M M JL. Desalination Facility Huntington Beach Generating ,. , Station ,°.' :> •�''�' '® bil Tanks 4 ,gyp, 3# '^ '•� '§ [• §.,tea 3 _ "?F c �. a. g tEa `� # S-z -•i 9'w:. -33_ 41V I# 44P e ', 4 3 5 S 00 tt c fi s� Source:Poseidon Resources Corporation,December 2004. NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH PF Q HBGS Intake and Outfall Location Map CONSULTING 02/05•JN10-101409.002 Exhibit 4-1 Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING The efficacy of biocides depends on several factors like the kind of biocide and its mechanism of action, its concentration, its kinetics, and the way it is dosed. Research has shown that a continuous bio-fouling monitoring system (on-line and side-stream monitors, visual inspections etc.) and a chlorine dioxide (CI02) dosage provides the best results.2 The HBGS utilizes chlorination, heat treating, and mechanical cleaning to control condenser fouling problems. There are benefits to continuous operation (as opposed to pumping water only when units are generating electricity) of once-through cooling water systems at facilities such as the HBGS. These include: ❖ Continuous monitoring and control of steam condenser fouling (bio-film formation); ❖ Reduction of potential leaching of steam condenser metals (copper) typically caused by shutdowns; and ❖ Reduction of potential cold shock (loss of thermal plume)to affected aquatic life. The HBGS is allowed to operate its pumps 24 hours per day, every day under its NPDES discharge permit, issued and monitored by the Santa Ana Regional Water Control Board (SARWQCB). Alternative Modes of HBGS Operation + Currently, HBGS has three distinctive modes of operation: normal (typical) mode, standby mode, and heat treatment mode. ' Normal Mode of HBGS Operation During normal operation mode the generating station produces electricity. The amount of electricity being generated dictates how many units are running. This in turn dictates the condenser cooling water flow rate. The table below shows the cumulative effect on rated capacity flow rate based on the number of units running and therefore the number of pumps running. The historical maximum cooling water system flow rate at HBGS is 507 MGD. Table 4-1 RATED CAPACITY FLOW RATE AT HBGS Generating Units On-Line 1 1,2 1,2,4 1,2,3,4 Number of Pumps On-Line 2 4 6 8 Condenser Cooling Water Pump Rated Capacity 127 254 380 514 (MGD) In normal mode, the generating station's discharge is, on average, about 18°F (10°C) above ambient seawater temperature. As mentioned in HBGS regulatory framework, during the normal mode of operation the maximum discharge temperature specified in the facility's NPDES permit is 30OF (16.50C). 2 Once-through cooling systems antifouling treatment by CI02 M.Belluati 1, L.Bartole 2, G.Bressan 2, ( 1: Caffaro, Laboratorio Ricerche, via F.Nullo 8, 25126 Brescia [Italy] 2: Dipartimento di Biologia, University degli Stud di Trieste,via L.Gorgieri 10,34127 Trieste[Italy]. City of Huntington Beach April 5, 2005 4-6 Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING Standby Mode of HBGS Operations During the HBGS standby mode of operation, a generating unit does not generate electricity. However, the station's equipment is operated at a level of readiness that allows the unit to begin generating electricity on short notice. While in standby mode, the generating station may discharge only 127 MGD of seawater (the equivalent of one unit/two pumps on-line). If the HBGS is not generating electricity and is in standby mode, the temperature of the discharge is approximately the same as the ambient seawater temperature entering through the intake. The frequency and duration of standby mode operation is driven by the grid's demand for electricity. Historically, this scenario has occurred less than one percent of the time. Heat Treatment Mode of HBGS Operations HBGS periodically conducts a heat treatment procedure to further control the growth of bio- fouling organisms that attach to the walls of the generating station intake structure and cooling water conduits. The larger bio-fouling organisms or macro-fouling organisms (primarily r barnacles and mussels in the case of HBGS) attach themselves to surfaces within the cooling water system and can restrict water flow and interfere with the operation of facility equipment (pumps, valves, etc.). If the shells of these organisms are detached from the substrate, they can be carried by the cooling water flow to the condensers where they can clog tubes and r degrade the performance of the condensers. Heat treatments are typically completed once every six to eight weeks. The entire procedure takes about six to eight hours to complete. Heat treatment is a routine operation at many of California's coastal generating stations and is permitted and regulated under the HBGS' NPDES permit conditions. The main goal of heat treatment is to remove the marine organisms that have settled within the r generating station's cooling water system while they are still small enough to detach and pass through the condenser tubes without clogging the tubes. During heat treatment, flow is reversed within the cooling water system and seawater is drawn into the system via the discharge conduit and discharged out of the intake conduit. Only a very small amount of seawater flow is actually taken from the ocean during this process, and most of the cooling water flow is circulated within the generating station system rather than discharged from the generating station. By recirculating the seawater flow through the condensers, rather than discharging it to the ocean, the seawater temperature in the recirculation loop is raised from ambient ocean water temperature to approximately 110-1150F (43-460C). The elevated water temperature removes the marine organisms within the system, which are then discharged through the intake structure. HBGS Historical Operations As stated above, the HBGS has been in operation since 1958. All four generating units were on-line until 1995. At that time Units 3 and 4 were taken off-line due to limited use. Units 3 and 4 were retooled and brought back on-line in 2002 and 2003, respectively. The HBGS facility flow rate from the period 1979 through 2002 (prior to retooling) averaged 234 MGD, with a low flow of 127 MGD. From 2002 to July 2003 (during and subsequent to retooling) the average flow rate has increased to 265 MGD, with a low flow of 127 MGD. From 1980 through July 2003, HBGS pumps have been in operation approximately 98.8% of the time. Like all large facilities, there are scheduled outages so that maintenance needs can be performed on the system (refer Appendix C, HYDRODYNAMIC MODELING REPORT). City of Huntington Beach April 5, 2005 4-7 Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING HBGS Future Operations As discussed in Section 2 of the REPORT ON LOCAL AND REGIONAL ELECTRIC POWER REQUIREMENTS AND GENERATION RESOURCES (refer to Appendix Q), there are a number of factors that would likely result in continued operation of the HBGS units for the next several years and the foreseeable future. These are summarized as follows: Reliability: ❖ Two of the four units at the HBGS have received Reliability Must-Run (RMR)3 contracts from the California ISO for each of the last four years; ❖ In addition to the above, an existing ISO Operating Procedure requires that two units at the HBGS or one HBGS unit plus a 320 MW unit at the Alamitos Generating Station be on-line during peak load conditions on the SCE system. ❖ On a going forward basis it would appear as though at least two HBGS units would be considered RMR and at least one unit would be required to meet the requirements of the ISO Operating Procedure unless other generation were added in the same geographic area or if SCE were to make additions and/or modifications to the transmission system into and within the area. At present there are no announced plans for either to occur. Existing Power Contracts: •'• At the present time there is a power supply contract between the State of California and • Williams Energy Marketing and Trading5 that extends through 2018 and for which HBGS ' provides a portion of the capacity; ❖ At the present time the output of HBGS Units 3 and 4 is being sold to SCE under the terms of a five-year tolling agreement which expires in 2008.E Serving Long-Term Load Requirements: ❖ There would be a significant need for generation resources located within Southern California to serve the projected area loads. Because of the nature of the SCE transmission system these generation resources would have to include either existing or new generation in the Orange County area to avoid significant transmission system investments and to provide the same reliability benefits as HBGS Units 1 and 2. Regulatory Status of the HBGS Units: ❖ HBGS Units 3 and 4, which had been shut down by SCE in 1995, have been refurbished by AES and were placed in operation in July of 2002 and August of 2003, respectively.7 In 2001 these units received a certificate from the California Energy Commission (CEC) that allows them to operate for an initial period of 10 years with conditions. 3 RMR units are those that have been identified by the ISO as required to be on-line to maintain local area reliability in the event a forced outage should occur on a transmission element or a generator in the local area. a ISO Management Recommendations for 2004 RMR Designations from the LARS Process(September 19,2003); Page 35. 5 Williams Energy Marketing and Trading is an entity in the business of buying and selling natural gas and electricity. e A tolling agreement is one in which the entity receiving the output from a generating facility owned by another parry supplies the fuel which is burned in the generating facility. Energy Facility Status summary, California Energy Commission,June 30,2004. City of Huntington Beach April 5, 2005 4-8 Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING ❖ Because HGBS Units 1 and 2 were not removed from service prior to their acquisition by AES it was not necessary for them to go through a CEC certification process in order to continue to operate. Therefore, the regulatory life of these units is indefinite, as long as they comply with the pertinent air and water permits. Siting Issues for New Generation: ❖ A developer/electric utility would likely face significant difficulties in siting a new generating facility in Orange County that would provide the same system support benefits, as does the HBGS facility. , 4.2 PIPELINE ROUTE In addition to the desalination facility site, the proposed project would include up to approximately 10 miles of water delivery pipeline. The water delivery pipeline would extend V from the proposed desalination facility to the OC-44 water transmission line within the City of Costa Mesa, east of State Route 55 (SR-55) at the intersection of Del Mar Avenue and Elden Avenue. The proposed pipeline alternatives (refer to Exhibit 3-3, CONCEPTUAL PIPELINE ALIGNMENTS) are proposed to be routed primarily within existing street right-of-way and easements. However, portions of the pipeline alignments are proposed to be installed within areas of the Costa Mesa Country Club (Costa Mesa) and Fairview State Hospital (Costa Mesa). As described in Section 3.0, Project Description, the following streets are proposed to be included in either the primary or alternate pipeline route: Primary Route Newland Street Hamilton Avenue Brookhurst Street Adams Avenue Placentia Avenue Harbor Boulevard Fair Drive Del Mar Avenue and Elden Avenue Alternate Route Hamilton Avenue Victoria Street Harbor Boulevard 22"d Street F- Del Mar Avenue Elden Avenue r- SURROUNDING ADJACENT LAND USES Uses surrounding the proposed pipeline route are dependent upon the pipeline alignment r` selected, although these include primarily residential areas, with some commercial/industrial uses, schools, parks, and flood control facilities. City of Huntington Beach April 5, 2005 4-9 Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING 4.3 UNDERGROUND BOOSTER PUMP STATIONS Two off-site underground booster pump stations are needed as part of the distribution system. The first off-site underground booster pump station (the "OC-44" pump station) is proposed to be located within an unincorporated area of the County of Orange along the eastern border of the City of Newport Beach, within an Orange County Reserve Preservation Easement. The site is located adjacent to, but outside of, a Natural Community Conservation Plan/Habitat Conservation Plan (NCCP/HCP) area (refer to Exhibit 3-4, OC-44 BOOSTER PUMP STATION LOCATION MAP). An inventory of existing biological and cultural resources within the vicinity of the OC-44 pump station is included in Section 5.9, CONSTRUCTION RELATED IMPACTS. The second underground booster pump station (the "Coastal Junction" pump station) would be located in the parking lot at St. Paul's Greek Orthodox Church, at 4949 Alton Parkway within the City of Irvine (refer to Exhibit 3-5, COASTAL JUNCTION BOOSTER PUMP STATION LOCATION MAP). SURROUNDING ADJACENT LAND USES Land uses adjacent to the OC-44 booster pump station include open space to the north, south, and east, and residential to the west. The Coastal Junction pump station site is surrounded by the St. Paul's Church to the south, the Woodbridge Village Association to the west, an apartment complex to the east, and open space to the north. Refer to Exhibit 3-4, OC-44 BOOSTER PUMP STATION LOCATION MAP, and Exhibit 3-5, COASTAL JUNCTION BOOSTER PUMP STATION LOCATION MAP, for additional information. 4.4 LOCAL MARINE SPECIES AND COMMUNITIES OCCURRING IN THE WATERS AT HUNTINGTON BEACH THE SOUTHERN CALIFORNIA BIGHT All of the marine species living near the HBGS commonly occur over geographic ranges extending well beyond the coastal waters of Southern California. They are part of a biologically and climatologically unique region called the Southern California Bight (SCB). Geographically, the SCB is an open embayment extending from Point Conception, CA into Baja California, Mexico and 125 miles offshore (refer to Figure 4-1, SOUTHERN CALIFORNIA BIGHT(Carlucci et al., 1986; Jackson, 1986). Biologically, the SCB is a transition-zone species assemblage positioned between two larger and diverse assemblages; one in the cooler waters to the north and the other in the warmer waters to the south. SCB organisms comprise a mix of species: some from the cooler, northern region and some from the warmer, southern region. Physical, biological, and oceanographic factors affect the total SCB biomass and cause year-to- year variation in the number of species occurring within the SCB and in areas such as Huntington Beach. While ocean temperature, current patterns, and upwelling affect nutrient and food supplies, biological variables such as the arrival of planktonic animals to coastal areas, the recruitment of new organisms (addition of young-of-the-year to the population) and habitat availability and quality all influence ecosystem-species composition, diversity, and biomass (Jackson, 1986). The young stages of most marine invertebrates and fishes living at and near Huntington Beach and throughout the SCB begin life as drifting plankton. Their survival into the next life stage requires that the appropriate and vacant habitat be found. Thus, evaluation of either local or regional habitats with respect to their biodiversity, the abundances of different species, and the age, body size, and growth rates of specific organisms must always be made in the context of the large-scale influences, whether in the area around Huntington Beach or across the entire SCB. City of Huntington Beach April 5, 2005 4-10 Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING Figure 4-1 SOUTHERN CALIFORNIA BIGHT aavidson \ PL Conception i Santa Monica -, R �• Newport Beach quo �'4 r � ��� `► San Diego Mexico Q 100 200 i000'�s 70001� � Kiiwrrete� �'V Depth in MWOM MARINE ORGANISMS AND THE HABITAT OCCURRING IN THE OCEAN WATERS NEAR THE HBGS OUTFALL Since 1975 National Pollutant Discharge Elimination System (NPDES) requirements for HBGS receiving water monitoring have been carried out by Marine Biological Consultants (MBC) r Applied Environmental Sciences (Costa Mesa, CA). Annual reports by MBC (a complete list of these annual reports is contained the bibliography of Appendix C, HYDRODYNAMIC MODELING REPORT) have monitored the abundance, diversity, and health status of marine organisms inhabiting the waters and substrata surrounding the HBGS. In addition to recording environmental conditions and censusing the organisms living near the HBGS heated discharge, MBC sampling has been done at locations 3,000 feet north and south of the discharge. The r sampling methods have included diver surveys along bottom transects, trawling for the census of fishes and macroinvertebrates, and bottom-core samples to assess the number and diversity of animals living within the substrate. Over the years, as monitoring results consistently indicated the absence of discharge effects, the number of surveys required by NPDES was reduced. The MBC report for 1993 contains the most recent analysis of the benthic infauna (i.e., organisms living in the substrate). The 2001 report has the most recent findings of the trawling and diving- surveys of benthic macroinvertebrates. The sea floor (benthic habitat) surrounding the HBGS discharge is relatively smooth and gently sloping, and contains medium to fine-grain sands. It extends for a considerable distance, both up and down the coast from the discharge site. Littoral currents sweep the waters overlying the coastal sea floor in a generally downcoast direction, although net movement is affected by tides, City of Huntington Beach April 5, 2005 `r 4-11 Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING winds, and storms. These factors and sand grain size play a major role in determining the distribution, abundance, and diversity of benthic animals. The marine organisms living in the vicinity of the HBGS discharge occur in one of three habitat classifications: 1) substrate (termed infauna); 2) on the seafloor (termed macroinverteb rates, including worms, crabs, sand dollars, starfish and some fishes); or 3) in the water column itself 1 (consisting of squid, fish, plankton, etc.). General descriptions of these three habitat classifications are provided below. However, more detailed information is provided in Section 5.10, OCEAN WATER QUALITYAND MARINE BIOLOGICAL RESOURCES. 1. Infauna Huntington Beach infauna surveys were carried out from 1975 to 1993 (MBC, 1993). This habitat is dynamic and there are many species that can potentially occur in the infauna, however, many of these are rare or appear episodically. Most of these animals have very short lives and it is reasonable to assume that many of them arrive each year in the plankton. Thus, the infaunal species diversity of the extended habitat varies from year to year as does organism age, size, and abundance. In terms of both numbers and species, the most dominant animals each year were polychaete worms and crustaceans. Mollusks were the third most abundant group and showed marked variation from year to year. 2. Benthic macrofauna Macrofaunal surveys, conducted from 1975 to 2000, show the repeated occurrence of the same core group of species in the area (MBC, 2001). The macrofaunal species occurring at Huntington Beach are typical of those expected to occur at other comparable open, sandy bottom habitats throughout the SCB. Average abundances of these and other organisms and total species number varied from year to year. From 1975 to 2001, five animal groups (three annelid [polychaete] worms [Diopatra, Owenia, Maldanidae], hermit crabs [Paguridae] and Pacific sand dollars [Dendraster excentricus]) account for about 90% of the marcrofaunal abundance. 3. Fishes Since the fish surveys began, 65 species have been collected, all of which can be considered as typical residents of open, sandy bottom coastal habitats in southern California (Horn and Allen, 1978; Mearns, 1979; Allen and DeMartini, 1983). The fifteen most abundant fish species living in the area between 1976 and 2000 are: white croaker, queenfish, northern anchovy, California halibut, Pacific sardine, speckled sanddab, curflin turbot, kelp pipefish, white seaperch, walleye surfperch, C-O turbot, Pacific butterfish, California lizard fish, salema, and barred surfperch 4.5 HUNTINGTON BEACH SURF ZONE STUDIES HUNTINGTON BEACH SURF ZONE— ELEVATED BACTERIA LEVELS Huntington State Beach was closed from July 1, 1999 until September 3, 1999 due to elevated levels of fecal indicator bacteria in the surf zone. Fecal indicator bacteria (total coliformn, fecal coliform, and Enterococcus) live in the digestive tracts of warm-blooded animals, including humans. The Orange County Health Care Agency (OCHCA) suspected that there was a source of human wastewater that was contributing the high bacterial levels. City of Huntington Beach April 5, 2005 4-12 Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING Elevated bacteria levels have resulted in chronic beach postings advising visitors against f swimming for the last four years. Huntington State Beach is heavily used with over five million visitors per year. Surf zone pollution severely affects the economy of the City of Huntington Beach when the beach is closed or advisories have been posted. It is estimated that as many , as 50,000 people per year may suffer from gastroenteritis as a result of ingesting bacteria while swimming and surfing in this water(Kim et. al., 2003). Monitoring for fecal indicator bacteria is conducted three to five times per week in ankle deep , water approximately every 3,000 feet along the shoreline of Huntington State Beach by the OCSD. OCHCA decides whether to notify the public (via beach postings) that the water may , not be safe for swimming based on a comparison of the bacteria data to state standards, as shown in Table 4-2, STATE STANDARDS FOR BEACH POSTINGS. If OCHCA knows or suspects that human wastewater may be responsible for the high levels of bacteria, the beach is closed for body contact recreation. Table 4-2 , STATE STANDARDS FOR BEACH POSTINGS Single Sample Monthly Fecal Indicator Bacteria Maximum Geometric Mean Total Coliform, MPN/100 ml 10,000 1,000 Fecal Coliform, MPN/100 ml 400 200 Enterococcus, CFU/100 ml 104 35 MPN= Most Probable Number. The MPN technique provides a"statistical picture"of the number of coliforms present and is not an exact measurement. CFU = Colony Forming Units. The CFU technique counts colonies of a bacteria within a sample. It is not an exact measurement of bacteria. OCHCA summarized the beach monitoring data for 2000 through 2003 in their 2003 Annual Report (OCHCA, 2004). The data collected between Beach Boulevard (located approximately one-half mile northwest of HBGS) and the mouth of the Santa Ana River (located approximately two miles southeast of the HBGS) were combined and are presented in Table 4-3, BEACH , POSTINGS FROM APRIL TO OCTOBER IN 2000 TO 2003. Table 4-3 BEACH POSTINGS IN HUNTINGTON BEACH FROM APRIL TO OCTOBER Year Postings Days Beach Mile Days 2000 28 223 67.6 2001 29 70 14.8 2002 31 89 23.8 2003 21 72 41.9 The number of"beach mile" days is an indicator of the extent of the problem. It is calculated by multiplying the number of days the beach is posted by the number of miles that are posted. As shown in Table 5.10-2, there was a large decrease in both the number of days and the number of beach mile days between 2000 and 2001. This was the period when dry weather urban runoff was first diverted to OCSD for treatment rather than discharged to the ocean via the Santa Ana River or Talbert Marsh. For the last three years there has been an increasing trend in the number of beach mile days. Figure 4-2, GEOMETRIC MEANS FOR FECAL INDICATOR BACTERIA AT HUNTINGTON STATE BEACH (STATION 6N) presents data from the OCHCA Annual Report on the mean City of Huntington Beach April 5, 2005 4-13 Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING concentrations of each of the three fecal indicator bacteria for 2000 to 2003 at Station 6N which is 3000 feet downcoast from the HBGS. This figure shows that total coliform and fecal coliform bacteria levels have decreased substantially. There was a decrease in Enterococcus between ' 2000 and 2001 but for the last three years the levels have remained fairly constant. Most of the postings during the last four years were due to exceedences of the Enterococcus standard. Figure 4-2 GEOMETRIC MEANS FOR FECAL INDICATOR BACTERIA AT HUNTINGTON STATE BEACH (STATION 6N) 2 50 200 1 ■Total Coliform ■Fecal Coliform 100 13 Enterococcus 50 2000 2001 2002 2003 * AB 411 Periods(4/1 through 10/31),2000-2003 An analysis of the large amount of bacterial data that have been collected has shown that bacteria levels are highest in the surf zone during spring tides and lowest during neap tides. In addition, fecal indicator bacteria are significantly higher at night and lower during the day, presumably because of sunlight-induced mortality. A number of potential sources of the fecal indicator bacteria have been investigated in studies funded by OCSD and others over the last four years. Each of these sources and the most recent information on their potential to contribute fecal indicator bacteria at Huntington State Beach are described below. Urban Dry Weather and Storm Water Runoff The Santa Ana River drains a highly urbanized watershed of 1,700 square miles and discharges to the ocean approximately 9,000 feet from the intake to the HBGS. The Greenville Banning Marsh is located east of the Santa Ana River and drainage from the marsh flows into the Santa Ana River through a diversion channel. The Huntington Beach and Talbert flood control channels discharge into the Talbert Marsh, which discharges to the ocean approximately 1,300 feet upcoast from the Santa Ana River. Flows from the Santa Ana River and Talbert Marsh are tidally influenced in both dry and wet weather conditions. Ocean water flows inland up the river during flood tides and City of Huntington Beach April 5, 2005 4-14 Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft_Recirculated Environmental Impact Report ENVIRONMENTAL SETTING mixes with water from the river, which is heavily dominated by urban runoff. The mixture of ocean water and river water flows back through the river outlet during ebb tides and contaminants from the watershed enter the surf zone. Contaminants in the surf zone are transported parallel to the shore by wind and wave-driven currents in a direction controlled by the angle at which waves approach the shore. Other mechanisms such as rip and undertow currents carry contaminants offshore. A fraction of the contaminants carried offshore is returned to the surf zone (Kim, et. al., 2004). Contaminants from the Santa Ana River and Talbert watersheds that flow into the nearshore ocean during ebb tides can be transported upcoast toward Huntington State f , Beach during the following flood tide. Peak longshore tidal velocities are in the range of 0.2 to 0.3 meters per second during spring tides (Kim et. al., 2004). This means that during one tidal cycle, contaminants can be transported four to six kilometers upcoast. r=, Monitoring station 9-North (9N) is adjacent to the HBGS and is located 1.5 miles upcoast from the Santa Ana River outlet. rs--, Four separate field studies were conducted by U.C. Irvine during the summer of 2001. Over 2000 samples were collected and analyzed for total coliforms, E.coli (a subset of fecal coliforms) and Enterococci bacteria. These studies determined that fecal indicator bacteria in the surf zone are highly variable and governed by a complex set of environmental conditions, including the input of bacteria to the surf zone during ebb tides, the magnitude of coastal currents, and the prevailing wave direction (Kim, et.al. 2004). The concentration of total coliforms is highest during the transition from the nighttime falling to rising tide and mostly confined to the region of the surf zone upcoast of the Santa Ana River and Talbert Marsh outlets. Results indicate that total coliforms enter the nearshore ocean from the Santa Ana River and Talbert Marsh during ebb flows and are carried upcoast by wave driven surf zone currents and/or tidally driven coastal currents. The patterns for E.coli and Enterococcus are different than the total coliform pattern. The concentrations of E.coli and Enterococcus are highest in the region between 6N (near Magnolia Street) and 9N. Based on a detailed analysis of the data collected in 2001 and on modeling studies, it appears that there are potentially other sources of E.coli and Enterococcus in the vicinity of stations 6N and 9N. A microbial source tracking study concluded that human wastewater was the source of a portion of the bacteria in the vicinity of 9N (Kim et. al., 2004). During storm events, significant amounts of bacteria are delivered to the surf zone. One study estimated that on an annual basis over 99 percent of the fecal bacteria are delivered in storm events with less than one percent delivered during dry weather conditions (Reeves, et. al., 2004). Although bacteria standards are exceeded after ' storm events, fewer people are impacted because most usage of the ocean occurs during the dry spring and summer months. However, the contaminated sediments and particles that enter the nearshore ocean during storms could be deposited and lead to chronic contamination of beach areas located near the Santa Ana River and Talbert marsh outlets. Beginning in 1999, the City of Huntington Beach and County of Orange began diverting dry weather runoff to OCSD for treatment and offshore disposal. Thirteen diversion facilities, including ten pump stations and three in-channel diversion facilities were constructed at a cost of approximately $7.5 million (County of Orange, et. al., 2004). These facilities collect urban runoff from approximately 90 percent of the watershed area and divert up to 2.4 MGD of dry weather runoff to the OCSD system. All diversions are terminated during storms, which generally occur from November to March. A study of the effectiveness of the diversions in the Talbert Marsh watershed, conducted by U.C. City of Huntington Beach April 5, 2005 4-15 iSeawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING Irvine, showed that the diversions reduced the flow of fecal indicator bacteria from urban runoff to the outlet of Talbert Marsh. During the three years of the study, the concentrations of the three indicator bacteria increased in urban runoff stored in the forebays of the channels that drain the Talbert watershed. However, in general, the average concentrations of fecal indicator bacteria did not change significantly at the coastal outlet of Talbert Marsh. This indicates that the diversions were effective in controlling the flow of fecal indicator bacteria from urban runoff in the Talbert watershed but there may be other sources of fecal indicator bacteria, such as bird droppings or regrowth of bacteria in sediments. The County of Orange and the Cities of Costa Mesa and Newport Beach recently submitted a workplan to the Santa Ana Regional Water Quality Control Board (SARWQCB) to address dry weather runoff from the areas where runoff is currently not diverted, which equates to approximately 10 percent of the watershed (County of Orange, et. al., 2004). These areas are adjacent to the Greenville-Banning Channel and lower Santa Ana River downstream of the existing in-channel diversion dams. OCSD Discharge At the time of the beach closure in 1999, OCSD was discharging 245 mgd of wastewater at an outfall that is located 4.5 miles offshore at a depth of 195 feet. At that time, all wastewater received primary treatment and 50 percent of the wastewater also underwent secondary treatment. OCSD also has an emergency outfall that is closer to shore but it has not been used since construction of the deep outfall. During early investigations of high levels of bacteria in the surf zone, OCSD maintained that the OCSD discharge could not be the cause because: 1) the discharge plume was contained below the thermocline and could not mix with surface waters; 2) intensive monitoring offshore and nearshore showed no indication of bacteria traveling from offshore to the nearshore zone; and 3) other water quality monitoring efforts conducted by OCSD had never detected the plume near the shore. Stanley Grant, a professor at U.C. Irvine, advanced a theory that a submerged edge of the OCSD wastewater plume may be transported shoreward by subsurface currents and then entrained in the discharge from HBGS and transported into the surf zone (Grant et. al., 2000). Intensive, monitoring conducted by the U.S. Geological Survey (USGS) in 2001 did not identify a connection between ocean processes and bacterial contamination of the beach (USGS, 2003). The OCSD plume rises toward the thermocline when it first enters the ocean because it is less saline and warmer than ocean water. The plume mixes with ocean water that is about 12 to 14 degrees Celsius and is generally carried out of the area by alongshore currents. Although internal tides were shown to intermittently transport cold water toward the shore in July and August 2001 and the OCSD plume is occasionally detected in shallow water (20 meters), there is no connection between the cold water intrusions and exceedences of beach standards. Intensive bacteria monitoring conducted during the summer of 2001 showed that when the beaches have high bacteria levels, water about 0.4 kilometers from the beach also has measurable bacteria, although well below the beach standards. There was a gap between the nearshore contamination and the bacteria measured 3.3 kilometers offshore below the thermocline in the OCSD plume. The lowest levels of bacteria were consistently found about 0.8 kilometers from the beach. This gap indicates that the bacteria from the OCSD outfall do not reach the beaches (OCSD, 2002). City of Huntington Beach April 5, 2005 4-16 Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING In August 2002 OCSD began disinfecting its effluent with chlorine to determine if there was any undetected mechanism by which the effluent plume was reaching the surfzone in an effort to ensure that OCSD was not a contributor to the exceedence of bacteria standards. OCSD has set a goal of meeting the shoreline standards in the zone of initial dilution around the outfall (OCSD website). The daily operational goals for the final effluent are shown in Table 4-4, OCSD TREATMENT FACILITY OPERATIONAL GOALS. The total coliform, fecal coliform, and enterococcus levels in the final effluent are generally far below the goals. Bacteria levels at nearshore monitoring stations have continued to exceed beach standards since OCSD began disinfecting its wastewater. This supports the previous studies that concluded that the OCSD plume was not the , source of the nearshore bacteria. OCSD is also taking steps to treat 100 percent of the wastewater to secondary standards. At the end of 2003, 64 percent of the wastewater received secondary treatment and 36 percent received primary treatment. Table 4-4 OCSD TREATMENT FACILITY OPERATIONAL GOALS ,— Beach Sanitation Standards Daily Operations Indicator Bacteria (30 day geometric mean (Target at the final effluent after initial dilution of sampler using 100:1 dilution) 180:1 Total Coliform, MPN/100 ml 180,000 <100,000 r Fecal Coliform, MPN/100 ml 36,000 <20,000 Enterococci, MPN/100 ml 6,300 <3,500 Wastewater Collection System During the Phase I bacterial investigation in 1999, closed circuit television inspection of OCSD's coast trunk line that runs along Pacific Coast Highway revealed no leaks. No leaks were detected in OCSD's outfall. A small leak was found in the Huntington State Beach restroom system and was fixed. During the summer of 2001 the Huntington State Beach restrooms and sewers along the Pacific Coast Highway near the HBGS were tested for leaks using hydrostatic, air pressure, and dye testing methods. Sewer lines between several restrooms were leaking with the most severe leak in 800 to 900 feet of sewer line connecting two restrooms that are near HBGS and adjacent to Station 9N. r' The dye testing revealed that wastewater flowed from the restrooms to the shoreline via the tidally influenced groundwater near the beach. Dye was detected in groundwater monitoring wells near the restrooms and in the surf zone within 48 hours of injection at the restrooms (OCSD, 2002). These studies indicated that the restroom sewers could potentially be a source of bacteria to the shoreline, and may be the additional source of E.coli and Enterococcus between Stations 6N and 9N discussed above. OCSD recommended that the California Department of Parks and Recreation (California State Parks) take corrective measures to eliminate the leaks and to routinely test their sewers in the future. California State Parks closed the restrooms with the leaking sewers and submitted plans to abandon the leaking sewer near the HBGS and replace it with a direct connection to OCSD's coast trunkline. HBGS There has been considerable speculation that the HBGS in someway contributes to the bacterial contamination of the nearshore ocean around monitoring station 9N, either as a source of bacteria or by "sucking" in the OCSD plume and then discharging it in City of Huntington Beach April 5, 2005 4-17 Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING nearshore waters. USGS conducted an intensive ocean monitoring program in the summer of 2001 to determine if the OCSD plume could potentially reach the shore. USGS concluded that the interaction of the HBGS and the OCSD plume could not be responsible for the beach contamination (USGS, 2003). MBC conducted a water quality monitoring program during the summer of 2001 to identify potential sources of bacteria at the HBGS. MBC found high concentrations of fecal indicator bacteria in the HBGS discharge vault and determined that the sources of the bacteria were the HBGS retention basins and the off-site Pacific Coast Highway (PCH)/Newland Street storm drain that flows into the HBGS discharge vault. The PCH/Newland Street storm drain collects urban runoff from an area west and north of HBGS, including the adjacent RV/trailer park. Although high levels of fecal indicator bacteria were found in the discharge vault, intensive sampling of the ocean near the HBGS discharge revealed much lower concentrations. The total coliform data from the summer of 2001 are summarized on Figure 4-3, TOTAL COLIFORMS AT HBGS, 1 SUMMER 2001. MBC concluded that the HBGS was not responsible for the bacteria contamination of the beach at Station 9N due to the dilution of the discharge with cooling water and with ocean water in the immediate vicinity of the outfall (MBC, 2002). Figure 4-3 TOTAL COLIFORMS AT HBGS, SUMMER 2001 (in MPN/100mi) Generating Station Off-Site .Urbane: :Runoff Avg = 21,904 Intake Max Avg = 587 Dlscharge` Avg = 1,763 = >24,192 Well.:,__ Vault Max = >24,192 Max = >24,192 Beach Standard = 10,000 I Minimum Dilution a' Outfall = 32:1 Avg = 17 Avg = 150 Max = 355 Intake Max = 3,654 The California Energy Commission (CEC) required a study of the impact of the HBGS on Huntington Beach bacterial contamination as part of the retooling of the generating station in 2001 (Komex, 2003). An intensive water quality monitoring program was conducted during the summer of 2002 and dye studies were performed to determine if the HBGS was a source of fecal indicator bacteria to the surf zone. Samples were collected daily from a number of locations at the HBGS from mid-July to mid-October. In addition, samples were collected every three hours from four locations during a two- week intensive study. Data were also collected in the ocean near the intake and outfall of the HBGS. The total coliform data for 2002 are summarized on Figure 4-4, TOTAL City of Huntington Beach April 5, 2005 4-18 Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING COL/FORMS AT HBGS, SUMMER 2002. The study found that urban runoff from an r, area adjacent to the HBGS that is discharged to the discharge vault of the HBGS contained high levels of fecal indicator bacteria. Because the urban runoff is blended with cooling water from the generating station, the generating station discharge ' contained much lower concentrations of fecal indicator bacteria. These findings are consistent with the findings from the MBC study conducted the previous year. Figure 4-4 TOTAL COLIFORMS AT HBGS, SUMMER 2002 (in MPN/100ml) Generating:Station _.Off-Site Urban"" Rlunoff Avg = 18,311 Av 11 Intake -blschakie Av 93 Max = 370,000 g :Well Vault g Max = 310 `:` Max = 1,700 Beach Standard r = 10,000 Surf Zone = 47 Minimum Dilution Outfall = 36:1 r-, Intake Komex (2003) conducted a dye study on the HBGS discharge to determine if the discharge has the potential to reach the surfzone. Dye was injected into the discharge vault at HBGS five times on one day in August 2002. The dye surfaced over the outfall and then spread radially in all directions. The average dilution between the discharge and the beach was 277 to one. The lowest calculated dilution was 36 to one. These results are consistent with the modeling conducted in Appendix C of the EIR, HYDRODYNAMIC MODELING REPORT. Based on the water quality sampling and the modeling studies, Komex concluded that the HBGS was not contributing to the beach contamination problem. r-, Bird Droppings A two-week study in May 2000 showed that the Talbert Marsh is a source of total coliform, Enterococcus and E. coli (Komex, 2003). The study showed that the marsh produces about 100 billion of all three indicator bacteria each day: These organisms are transported to the ocean with each ebb tide. The source of the bacteria appears to be seagull feces, which are deposited in the marsh. Marine vegetation and marsh sediment become potential reservoirs of the bacteria. OCSD conducted bacteria monitoring upstream and downstream of the PCH bridge over the Santa Ana River in the summer of 2001. Bacteria levels downstream of the bridge were consistently and substantially City of Huntington Beach April 5, 2005 4-19 i Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING higher than upstream levels. Birds roosting under the PCH bridge were thought to be a possible cause of the high levels downstream (OCSD, 2002). There has also been speculation that bird droppings on the beach could be partially responsible for the high bacteria levels in the surfzone. During the summer of 2001, OCSD conducted visual observations of birds in the area between Stations 6N and 12N. Groups of up to 400 birds were observed on the beach and groups of 200 to 300 birds were observed floating in the water beyond the surfzone (OCSD, 2002). Bacterial monitoring studies were not conducted to determine the impact of bird droppings. Pet Waste There have been no studies in Huntington Beach on the potential contribution of pet wastes to bacteria in the nearshore ocean. A study conducted at the Dog Beach in San Diego found that areas with large accumulations of dog feces did not produce higher concentrations of bacteria than areas with low accumulations of dog feces. However, the study concluded that the combination of decaying marine vegetation, dog feces, and bird droppings in the kelp line was likely the source of bacteria at that beach (MBC, 2003). Groundwater Discharge During the summer of 2003, researchers from Stanford University conducted a study to determine if groundwater near Station 9N could transport fecal indicator bacteria to the surf zone (Boehm, et.al. 2003). Radium isotope studies were conducted to confirm that groundwater enters the surfzone during ebb tides. Groundwater samples were analyzed for fecal indicator bacteria. Most of the samples contained less than 60 MPN/100 mL (60 most probable number/100 milliliters) but one sample contained total coliform of greater than 24,192, fecal coliform of 17,329, and enterococcus of 776 MPN/100 mL. An experiment was conducted to determine if the sand at Huntington Beach would filter out Enterococcus as the groundwater moved through the sand. The experiment showed that Enterococcus are not filtered out and readily move through the sand with the groundwater. This study and the dye study conducted by OCSD in 2002 show that groundwater enters the surf zone near Station 9N. Groundwater entering the surf zone could transport bacteria from a variety of sources such as leaks in the wastewater collection system, bird droppings, and/or pet waste, Conclusions Based on the extensive studies conducted on bacterial pollution of Huntington State Beach, the Santa Ana River and Talbert Marsh appear to be the primary sources of fecal indicator bacteria to the near shore ocean. During the summer months, most of the dry weather runoff is currently diverted to OCSD although approximately 10 percent of the watershed near the mouth of the Santa Ana River still discharges to the river. Bird droppings and a reservoir of bacteria stored in the sediment and on marine vegetation may continue to be the source of bacteria at the mouths of the river and marsh. Modeling studies and monitoring data indicate that there is likely another unidentified source of bacteria in the vicinity of Stations 6N and 9N. Three separate studies conducted between 2001 and 2002 have demonstrated that HBGS is not the source of bacteria in the surf zone. City of Huntington Beach April 5, 2005 4-20 Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING 4.6 OCEAN WATER QUALITY AT THE HBGS INTAKE There have been several efforts to characterize the intake and discharge water quality of the Huntington Beach seawater desalination facility. These efforts include: completion of sanitary survey (Appendix E), collection of desalination facility intake water quality information for two years, and operation of a seawater desalination pilot facility for the last two years. There are a number of discharges and potential sources of contaminants in the vicinity of the HBGS intake (which would be the source of water for the desalination facility). Potential contaminant sources have been identified as: ❖ OCSD discharge; ❖ Urban dry weather and storm water runoff; ❖ Recirculation of HBGS discharge; ❖ Los Angeles/Long Beach Harbors; ❖ Cruise ships and/or fishing boats; ❖ Recreation; and ❖ Oil and gas activities. These potential contaminant sources are evaluated in Section 5.10, OCEAN WATER QUALITY AND MARINE BIOLOGICAL RESOURCES. 4.7 OCEAN WATER QUALITY AT THE DESALINATION FACILITY INTAKE The water quality at the desalination facility intake would potentially be affected by HBGS activities that occur between the ocean intake and the point at which water will be diverted from the HBGS cooling water system to the desalination facility. The intake water to the desalination q� facility would be cooling water taken after the water has flowed through the condensers of the generating station. Potential contaminant sources have been identified as: ❖ HBGS cycle water discharges; ❖ Urban runoff discharges from within the HBGS site; ❖ HBGS wastewater discharges; ❖ Hazardous materials spills at the HBGS site; and ❖ HBGS heat treatments. Poseidon collected data on all of the water quality constituents that are regulated in drinking water supplies. Samples were collected from the HBGS intake vault and from the outlet to the condensers (where the desalination facility intake will be located). Analysis of impacts in this regard and the results of sampling are included within Section 5.10, OCEAN WATER QUALITY AND MARINE BIOLOGICAL RESOURCES. 4.8 ORANGE COUNTY WATER SUPPLY AND DISTRIBUTION SYSTEM Through the collective efforts of more than 30 different water purveyors, four sources of water (imported water from the Metropolitan Water District of Southern California [MWD], surface water, groundwater and recycled water) are managed, treated and distributed to customers throughout Orange County. A list of water purveyors that manage the water supply and operate water distribution facilities in Orange County is provided below, while Figure 3-1, ORANGE City of Huntington Beach April 5, 2005 r-7 4-21 Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING ' COUNTY WATER SUPPLY SOURCES, identifies the sources of water supply available to the County: Imported Supply: ❖ MWD ❖ Municipal Water District of Orange County (MWDOC) Groundwater Management: ❖ Orange County Water District ❖ San Juan Basin Authority Retail Delivery: ❖ Anaheim, City of ❖ Brea, City of ❖ Buena Park, City of ❖ Capistrano Valley Water District ❖ East Orange County Water District ❖ El Toro Water District ❖ Fountain Valley, City of Fullerton, City of ❖ Garden Grove, City of ❖ Huntington Beach, City of ❖ Irvine Ranch Water District ❖ La Habra, City of ❖ La Palma, City of ❖ Laguna Beach County Water District ❖ Mesa Consolidated Water District ❖ Moulton Niguel Water District ❖ Newport Beach, City of ❖ Orange, City of ❖ San Clemente, City of ❖ Santa Ana, City of ❖ Santa Margarita Water District ❖ Santiago County Water District Seal Beach, City of ❖ Serrano Water District ❖ Southern California Water Company ❖ South Coast Water District ❖ Trabuco Canyon Water District ❖ Tustin, City of ❖ Westminster, City of ❖ Yorba Linda Water District Imported Water Imported water in Orange County is supplied by the Metropolitan Water District of Southern California (MWD). MWD only provides water to its member agencies. There are four MWD member agencies in Orange County: the Cities of Anaheim, Fullerton, and Santa Ana, and the MWDOC. MWD provides imported water directly to the three cities, and the three cities City of Huntington Beach April 5, 2005 4-22 Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING distribute that water to their retail customers. The rest of Orange County receives its MWD imported water through MWDOC. MWDOC is a wholesale water agency charged with providing imported water to 27 different retail water purveyors in Orange County (refer to the list of member agencies above). As the second largest MWD member agency, MWDOC coordinates and plans water management programs throughout Orange County and represents all of Orange County's retail water purveyors (except Anaheim, Fullerton and Santa Ana and the Orange County Water District [OCWD]) to MWD. MWDOC does not directly operate any imported water delivery facilities. Instead, Orange County's imported water supply is transferred directly to the retail water purveyors via MWD's facilities. Imported MWD water consists of surface water from Northern California and Colorado River water. This water is transported over many miles, blended together, and then delivered throughout Orange County via two major water transmission pipelines: the Orange County Feeder and the East Orange County Feeder No. 2. Imported water that is treated at MWD's Jensen Plant in Granada Hills and Weymouth Plant in La Verne supplies the Orange County Feeder. Imported water that is treated at MWD's Diemer Filtration Plant in Yorba Linda supplies the East Orange County Feeder No. 2. From these two major transmission pipelines, several important regional water pipelines are served through connections (or turnouts). The South County Pipeline (serving inland South Orange County), the Aufdenkamp Transmission Main (serving Laguna Beach) and the Tri-Cities Transmission Main (serving Laguna Niguel, Dana Point and San Clemente) are all supplied through connections to the East Orange County Feeder No. 2. In addition, the OC-44 Pipeline (serving Costa Mesa and Huntington Beach) is supplied through a connection (the connection is called "OC-44") near the end of the East Orange County Feeder No. 2. The Coast Supply Line (serving the coast from Newport Beach to Laguna Beach) is supplied through a connection near the end of the Orange County Feeder. The Irvine Cross Feeder allows for flexibility in distributing imported water through this regional system because it connects the East Orange County Feeder No. 2 and the Orange County Feeder. Exhibit 4-2, IMPORTED WATER TRANSMISSION IN ORANGE COUNTY, is a map depicting the imported MWD water distribution system in Orange County. Surface Water Orange County's main natural source of surface water is the Santa Ana River. The Santa Ana River is supplied by rainfall and snowmelt from the San Bernardino Mountains.$ However, the Santa Ana River base flow is mainly comprised of treated wastewater discharged from treatment plants in Riverside County and San Bernardino County. r- Santa Ana River water is not directly supplied to water customers in Orange County. Instead, as River water percolates in spreading basins operated by the OCWD, the River water becomes groundwater (the groundwater is then pumped through wells, treated and distributed to water customers as discussed below). An average of 200,000 acre-feet of River water percolates into the Santa Ana River Groundwater Basin each year. Another source of surface water is the Santiago Creek, which is captured in the Santiago Reservoir (Irvine Lake) and provides approximately 8,000 acre-feet per year of supply. 8 Metropolitan Water District of Southern California,Regional Urban Water Management Plan, December 2000. City of Huntington Beach April 5, 2005 4-23 FBPp Fl/.V1 - AFN]pM - .. 1 PANT i .5 YOMunru r SANTI 0 caurrn ! f �•• WATOR DIiTRCT 7 .�'+--•..Al Surface whler - DIENCflc -- f�EILTRATION_ � t fi:�•'� 3 L;, pF�� � N:Ik f>IUPte[tnl Sbpe), PIAIIT YORBA ISTR U.V,KTYfP. _ f WATER DISTFICT Stream or Rivrr Chantnl s �o LIP�, ,',+� %%wr Ap-ymC—ly Qwndary � � �. ti � PV \ -, 1 \♦ E `�F / p MwvOC Bp mdarY \I 4NAHEIM �• � ♦�♦ �� IRVINE RANCH !oral PipPlinl OmalPd N3Te0 \\/ 1\\♦ ! `` /,r/� f .�� ° `v�r N AktrofnQten Pgxline(T—Ted) ^V/ ♦\ SOUTHE�C! F WATER DISiflICT if �,t'O /�/ focal PipHline(U.1-1l dNMtt) BREA.1 _ �. rt d y �� ♦/ W E OMPANY• SOUTHERRCAUF. J�♦\ /- MNmpoGUn Piwl-(Umrcmd) WATER COMPAnY ,.�07•\ r ` y� 54' J .�p 11f+A E �^♦\,,l SANTIAGO COUNTY fy !. ; Pfwtf.+Tu �'! �` - /♦ \ WATER DISTRICT , P e`p � .``sJ ,,�♦ ./ .,���+fit-Qotu"1♦ ;..rw sw.l:se000 LAN A �tr .•�'p .'Y,F_ 1. a• - y !"\. A�i+ j - WATER l �A-�ONWATER OIS oEm -TIC. A. 1Lm am Si. 61w ]im S*T CT WATER i `f, J g FVLLERTON pTvi ( ��1 ; � 3\\ SRC ♦r ' I _ - 0 GE �" {--I♦ f • t� /^ { ♦♦\d�1 1j' e ;w m �� F EL .�.�.+-ay� l� %'l .- ,e*/ • / /AN\AHEIe �Y�, EAST OR�rraECWnrr ` ? „ ~ tom---�-�' �•f �. �t f ♦ ,f �q, / / \ ` / \ r•J./ ♦h• TVATER 0151i1,'CF 5 LL 1 I(�` , '� \ I �+`• rI / T'o �y' y! / ` v q ♦ ```��� fff I ♦ SAUso3 • +.W \ ''`JJ � o _„F f t• �J\ ( __ �M��- (� = WATER CI STRICT fff JJJ��� •� � \^�E♦,\`a 7vsnv , �\ IIR<^Y wePea�iN�`- OVINE RANCH 0I" f • `��♦ I WATER DISTRICT I4S N`� f ] /'\ r' a•'_ Syr .BUEN ARIL ' f ,♦I `. Ai%♦ J 1,.vw.lFj0 1 -•-` �' i�,, �L a � T 1 ¢( 1 1 • \♦ ,ty ,t' V -',>^1'a � SA L-"- NTAMAR GARITA, WATERDISTRICT._� --". LAKIFFOR SANTA ANA —j rr•+� / = ` Q 1 ur \ 1♦\-. .! 1 4 T� a A,NtT;�♦♦•§� / �/ FPOPq � '---rtlGii.`r-- LLtIT,�iyVyN�1RyV�yii� ... tr-...- , EC)�N"�/'• �' � �i,�♦ y� \ ♦ J f 1REl.YE '1•T:y �s���.,of♦ ¢Towj F ��r� I G-i_♦ cTrpe� Qtc� ��� �' ♦�,4 \ ! '/ ��� hNi` -�i wA�rnmsmler�\\g1 �- '\ � � g1 ' ♦♦\ p��.W�.�'� L n4 5 SOUTHERN CALIF �'�� \ 1/ 1 ♦ TA L91A4 111115 ♦ T �,� � WATER OMPANY 4♦\@J \\' _i� g E \\ 1 S y�ry�'��i'♦. .f� ♦ � `�' �\a " Los faros u WESTMINSTER\\♦ '� g 41' #It �\ �r,��. _ 1. �+ f f•! �: ♦\ �, FOU tft AIN \ ` T to •a....,.•_ a \_ q9�,, °j�'4,,,;,;4 o .•tt \ VALLEY F 1 w•.d"`• {♦ •AtOEll Y NIGUEL l a ♦I / .� i i ;,,\ r �•r gD; ♦ .Ar'H DISTRICT MESA CONSOLIDAT - .\= f"i+'�r:♦ �` '�y,\ �♦ i \ . / WATER DISTRICT+/„F. ` 8 $(y,, SAnwA0t:1� \+' ♦ \ CAPISL OVALLEV / \ a � f,1 �I�� i y� "LLCD '{Ef0 ♦ \�. Rc16A+•olR J�a\t �ci'.,; } \;3 WATER 01 RICT COCA S'-'.7 � •'t i, \ dJ fP 1 a s' '! CCCj \`,� _3`/ T + s',: •� \ ,� 1 1 P 1 LAGUNA ,+' CDS rA X1 Si 1 ` S • BEACH \ GPIS ha e 1 t i 1 SEAL BEACH / 1 �:. { s1 O COUNTY �"+, { IArath'A A7ra/FJ. SAN CLEMENTE 1 - 1^ o MESA CON50610ATE0 / _ tt'1 WATER -♦ E �, WATER D`STRICT NEWPORT BEACH 1 IRVINE O7S7AIC7 ♦ _ l / \ UNTTNGTON BEACH - - ► RANCH "WATER DISTRICT \ .t, .+` ` _ rTCi:::ro----- - l----- - '.-- a•�•�+,.� `!/' ♦�•% ♦♦ i,•t\♦�� 4_LnASTnlrlYuuc �`SOUTy, $r ~ � -a `1WAT ``. I WAI{'i 1Ml�T1RDp 81>4UNE F.tt,D1sT��cr � I '�S�_`_ �•./'�"'• _�..`ti� �,� R1h'1 hT IOYN CNnR _ � �' Ippt�V LEVIMISS CAPISTRANO BEACH WATER DISTRICT I SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH ( Q Imported Water Transmission System in Orange County CONS IJ LTING 02105•JN 10-101409,002 Exhibit 4-2 ' Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING ' However, this amount greatly varies dependent upon rainfall. About 3,000 acre-feet per year of this water is treated for and delivered to water customers by Serrano Water District while the remainder is sold for agricultural irrigation by the Irvine Ranch Water District (IRWD).9 Groundwater10 The Santa Ana River Groundwater Basin underlies the majority of the northern half of Orange County and provides almost half of all the total amount of water used in Orange County. Several smaller Orange County groundwater basins, such as those located in the San Juan Creek and Aliso Creek watersheds, are currently being studied to maximize their use and storage potential. The San Juan Basin is managed by the San Juan Basin Authority and its member agencies, while Aliso Creek has yet to establish a managing entity. Additionally, a portion of northern Orange County (the cities of La Habra and Brea and surrounding areas) overlies the San Gabriel Basin. The OCWD was formed to protect Orange County's rights to water in the Santa Ana River and to manage the Santa Ana River Groundwater Basin ("Basin") underlying north and central Orange County." Basin groundwater reserves are maintained by OCWD through a recharge system that replaces water pumped from wells. The groundwater recharge system consists of approximately 1,100 acres of recharge spreading facilities located in and adjacent to the Santa Ana River and Santiago Creek.12 Each spreading system consists of a series of spreading basins, either shallow or deep, whose side-walls and bottoms allow for percolation into the underlying aquifer. Water enters the facilities from the Santa Ana River downstream of Prado Dam, and then flows by gravity through pipeline or overflow weir to the various recharge basins. In 1965, OCWD installed injection wells along the coast near the mouth of the Santa Ana River (at a place called the "Talbert Gap") to pump water into the shallow aquifers. Injecting water into the shallow aquifers produced a groundwater mound that stood higher than sea level. With a barrier in place to retard seawater intrusion, it became feasible to draw water levels down during dry periods when local surface water and imported water sources were in short supply, instead of simply keeping the Basin as full as possible to prevent seawater intrusion. During wet periods, the depleted aquifer could be replenished with storm runoff and excess imported water. Utilizing this method of groundwater management, OCWD allowed the amount of depleted groundwater supply (basin overdraft) to fluctuate between "full" in 1969 to an overdraft of nearly 500,000 acre-feet in 1977 without causing irreparable damage to the resource.13 Groundwater withdrawals from the Basin have increased from less than 200,000 acre-feet per year in the early 1960s to more than 350,000 acre-feet per year in 2002. In comparison to the 350,000 acre-feet of annual withdrawals from the Basin during the period 1998-2002, the natural recharge is small (estimated by the OCWD to be about 70,000 acre-feet per year). The majority of replenishment water is from "artificial recharge" operations whereby OCWD captures the flow of the Santa Ana River (which currently averages about 150,000 acre-feet per year) in recharge facilities located in the river bed and through deep recharge basins (abandoned sand and gravel pits) near the river. OCWD also captures an average of about 50,000 acre-feet of storm flows each year. To make up for the imbalance between this 270,000 acre-feet of recharge and the 350,000 acre-feet of withdrawals, OCWD has purchased an average of 60,000 acre-feet of imported replenishment water from MWD each year for supplementary 9 Municipal Water District of Orange County, 2000 Regional Urban Water Management Plan Update 10 The information in this section was reviewed and facts confirmed by John Kennedy of OCWD in September 2004. 1, 2020 Master Plan Report, Orange County Water District, November 1998. ,z 2020 Master Plan Report,Orange County Water District, November 1998. 13 The Groundwater Replenishment System:Providing Water for the Future, Orange County Grand Jury,2003. City of Huntington Beach April 5, 2005 4-25 Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING recharge primarily at its City of Anaheim and Orange recharge facilities. In addition the OCWD makes (via the first phase of the Groundwater Replenishment System [GWRS) and purchases approximately 20,000 acre-feet per year for injection in its seawater barriers. If the accumulated overdraft becomes excessive, OCWD uses complex financial disincentives to discourage groundwater withdrawals. Since the 1997-98 water year (a wet year), the County has experienced dry conditions, resulting in overdrafts in excess of 30,000 acre-feet per year. (� Groundwater levels have declined more than 20 feet throughout the basin since 1998, and f water levels near the coast are currently as much as 80 feet below sea level. In November 2002, the accumulated overdraft was estimated to be more than 400,000 acre-feet, which prompted OCWD to take actions to limit groundwater production rates and reduce the rate of withdrawal to about 324,000 acre-feet per year in 2003-04. Pumping for the current 2004-05 year has been limited to 316,000 acre-feet and is expected to fall to 311,000 acre-feet in 2005- 06. In comparison, the smaller groundwater basins in South Orange County, including Aliso Creek Basin and San Juan Basin, have been found to yield a total of 3,000 to 4,500 acre feet per year, dependent upon annual hydrology. Additionally, Orange County (the cities of La Habra and Brea and surrounding areas) receives approximately 12,000 acre-feet per year from the San Gabriel Basin, dependent upon annual hydrology. It should be noted that minor portions of the Santa Ana River Groundwater Basin are contaminated and, therefore, not available to Orange County water customers. OCWD and the (� IRWD are currently implementing the Irvine Desalter Project (IDP) to clean up one such �J contamination problem. IDP is a joint groundwater quality restoration project funded with the participation of the U.S. Navy and MWD.14 The IDP consists of two water purification plants with separate collection and transmission systems located near IRWD's headquarters on Sand Canyon Avenue in Irvine. One plant would remove the volatile organic compounds (VOCs)from the portion of the Basin that was contaminated by aircraft cleaning solvents used at the former El Toro Marine Base. IRWD would use that water only for irrigation and other non-drinking water uses. The other plant would treat water from outside the plume of contamination to remove salts and nitrates caused by the natural geology and past agricultural uses of the land. The water from outside the plume would be treated to drinking water standards and would be delivered to IRWD customers. Recycled Water Water recycling is a proven, effective drought-proof supply of water for Orange County. The foremost example of water recycling in Orange County is the GWRS, located in Fountain Valley. The GWRS is a water supply project that may ultimately reuse approximately 120,000 to 140,000 AFY of advanced treated wastewater from the Orange County Sanitation District (OCSD). Currently under construction, the first phase of the GWRS would supply approximately 72,000 AFY of recycled water to supplement existing water supplies. This recycled water would recharge the Orange County Groundwater Basin and protect the groundwater basin from further degradation due to seawater intrusion. The project is under construction and would be completed by May 2007. Approximately half of the water would be injected into the Talbert Seawater Barrier. The other half would be pumped to the OCWD's basin recharge facilities in the City of Anaheim. A small portion of the project has already been completed and is currently producing five MGD of water supply for the seawater barrier. 14 The Irvine Desalter Project, Irvine Water District,Online: hftp://www.irwd.com/ City of Huntington Beach April 5, 2005 4-26 Seawater Desalination Project at Huntington Beach 4.0 EXISTING CONDITIONS/ Draft Recirculated Environmental Impact Report ENVIRONMENTAL SETTING OCWD's seawater intrusion barrier consists of a series of 28 injection wells running along Ellis Avenue from Euclid Street to Newland Street in Fountain Valley. A mixture of recycled GWRS supply, imported water, and pumped groundwater from deep aquifers totaling about 20 MGD (22,400 acre-feet per year) is pumped to the wells and injected into the ground. This injected water creates an underground dam, blocking seawater from entering the groundwater basin when the basin's supply is drawn below sea level. Most of the injected water migrates inland, adding to the supply of groundwater in other portions of the Basin. OCWD also provides recycled water for irrigation. The Green Acres Project (GAP), located adjacent to GWRS, produces 7.5 MGD (8,400 acre-feet per year) of recycled water for irrigation of parks, schoolyards, golf courses and greenbelts within five miles of the treatment plant. The GAP stores the treated water in a two-million-gallon reservoir and then distributes it through 25 miles of pipeline to the cities of Costa Mesa, Fountain Valley, and Santa Ana.15 The IRWD conducts its own water recycling program. Through the treatment of wastewater, IRWD produces recycled water used to irrigate crops or landscaping. Recycled water now makes up 20 percent of IRWD's total water supply (23,383 acre-feet in fiscal year 2002-2003), reducing the need for imported MWD water and/or groundwater in IRWD's service area. 80 percent of all business and community (parks, school grounds, etc.) landscaping in the IRWD service area is irrigated with reclaimed water.16 Retail water purveyors in South Orange County have also pioneered water recycling within the County for many years. The South Coast Water District treats wastewater and uses the recycled water for landscape irrigation on parks, golf courses, playgrounds and greenbelt areas. Currently, the South Coast Water District provides recycled water to about 50 customers, ' including the Links at Monarch Beach, Niguel Shores, City of Dana Point, City of Laguna Beach, County of Orange, Monarch Beach, Aliso Creek Golf Course and Capistrano Unified School District." The Santa Margarita Water District operates two water reclamation systems, also located in South Orange County. The Oso Creek Wastewater Reclamation System produces recycled water used for centralized irrigation requirements, which include a golf course, greenbelts, parks and school grounds. The Chiquita Water Reclamation Plant is currently providing recycled water to the communities of Rancho Santa Margarita, Coto de Caza, Talega, Ladera Ranch, and portions of the Trabuco Canyon and Irvine Ranch Water Districts. Upon completion of the second phase, the plant could ultimately reach a capacity of 15 MGD (16,800 acre feet per year). Additionally, the Santa Margarita Water District and the Moulton Niguel Water District own and operate a reclamation facility, which produces a total of 3.2 billion gallons of recycled water a year (9,850 acre feet per year) to neighboring cities. 15 Recycling Brochure, OCWD,Online: http://www.ocwd.com/_assets/_pdfs/recycling.pdf 16 Irvine Ranch Water District. Online: hftp://www.irWd.com/ 17 South County Water District. Online:http://www.scwd.org/aboutlabout.htm#water City of Huntington Beach April 5, 2005 4-27 5.0 ENVIRONMENTAL ANALYSIS 1 1 1 1 1 1 5.0 OVERVIEW OF EIR METHODOLOGY AND SIGNIFICANCE DETERMINATION ' The EIR includes as much detail as possible to maximize information available for public review and thus avoid and/or minimize the need for future environmental documentation (see Section 2.0 of this EIR for further explanation of the EIR process). The EIR includes information gathered from ' correspondence from utility/service providers(Appendix J),available literature/reference documents, and consultation with potentially affected agencies (see Section 2.7, INCORPORATION BY REFERENCE). In addition, several technical studies were prepared for review and incorporation into this EIR. Technical studies completed for the Seawater Desalination Project at Huntington ' Beach include: • Noise Data ' • Air Quality Data • Growth Assessment and General Plan Evaluation • Underground Booster Pump Station Cultural Resources Assessment Reports ' • Geological Report- Desalination Site • Geological Report-Aboveground Product Water Storage Tank • Preliminary Seismic Assessment • Report on Local and Regional Power Requirements and Generation Resources • Local Alternative Site Investigation Underground Booster Pump Station Biological Constraints Survey ' • Marine Biological Analysis • Supplemental Report on the Effects of a Retrofitted Diffuser on the Discharge Outfall for the Proposed Seawater Desalination Project at Huntington Beach • Marine Biological Considerations Intake Effects Assessment Watershed Sanitary Survey • Hydrodynamic Modeling Report • Receiving Water Chemistry and Quality Report • Distribution System Corrosion Control Study • Disinfection Byproduct Formation Study • RO Membrane Cleaning Solution Discharge Test Stream Data • Pressure Surge Analysis ' • Preliminary Pipeline Assessment Desalination Facilities Located Throughout the World ' The analysis of the project's impacts, as contained in this EIR, is presented to clearly indicate the significance determination for each of the impacts by numbering each impact, with a correspondingly numbered impact discussion, and, if necessary, mitigation measure(s). The significance determinations are based on a number of factors as explained in each impact section. These primarily include Appendix G of the CEQA Guidelines, General Plan policies, ordinances, generally accepted professional standards, and established quantified thresholds by the City of Huntington Beach or other agencies. ' City of Huntington Beach April 5,2005 5.0-1 Seawater Desalination Project at Huntington Beach 5.0 OVERVIEW OF EIR METHODOLOGY Draft Recirculated Environmental Impact Report AND SIGNIFICANCE DETERMINATION The following is an explanation of the different significance determinations made in this EIR: A. Not Significant This determination is made when any of the three following cases apply: 1) No Impact: Due to the nature or location of the project, this impact will not occur. For example, underground facilities do not have the potential for long-term visual impacts. 2) Less Than Significant: Although an impact may occur, it will not be at a significant level based on the above described standards. For example, construction-related air emissions that fall below the adopted air quality standards are less than significant. 3) Potentially Significant Impact"Mitigated"Through Existing Requirements(No EIR mitigation required): In this case,there is an impact which, although it is potentially significant,will be reduced to less than significant levels through adherence to and/or implementation of various existing requirements. These existing requirements include the City of Huntington Beach Ordinances, engineering and design requirements (through the Uniform Building Code and other regulations), and from other regional, state, and federal agencies. B. Less Than Significant With Mitigation This determination is made when a potentially significant impact can be reduced,avoided or offset to less than significant levels by incorporating EIR mitigation measures. C. Significant With Mitigation This determination is made for a potentially significant impact where there is either no mitigation available, or the recommended mitigation measures are not sufficient to reduce the impact to less than significant levels. This determination requires a Statement of Overriding Considerations, pursuant to CEQA Guidelines Section 15093 (this would be adopted by the City of Huntington Beach prior to approving the project). City of Huntington Beach April 5, 2005 5.0-2 5.1 LAND USE/RELEVANT PLANNING The purpose of this section is to discuss the impacts of project implementation upon land uses on the project site and adjacent areas. This section includes a discussion of existing conditions including on-site and off-site land uses. Potential impacts of the proposed project are examined ' including compatibility with surrounding land uses, the City of Huntington Beach General Plan, the City of Huntington Beach Local Coastal Program, and the City of Huntington Beach Zoninq and Subdivision Ordinance. ' EXISTING CONDITIONS PROPOSED DESALINATION FACILITY SITE ' On-Site Land Uses ' The approximately eleven-acre desalination facility site is located within the City of Huntington Beach,south of Hamilton Avenue, north of Pacific Coast Highway,east of Newland Street,and west of Magnolia Street. The proposed project site consists of three fuel storage tanks formerly used in conjunction with the Huntington Beach Generating Station. The "west" tank site (location for the aboveground product water storage tank)is also developed with a fuel storage tank. For additional information regarding existing conditions, refer to Section 3.0,PROJECT DESCRIPTION,Exhibit 3- 2, SITE VICINITY MAP, and Exhibit 5.7-1, DESALINATION FACILITY SITE PHOTOGRAPHS. Adjacent Land Uses ' Surrounding adjacent land uses to the desalination site include the AES Huntington Beach Generating Station (HBGS)to the southwest,a wetland area to the southeast,the Huntington Beach Channel (a facility operated by the Orange County Flood Control District [OCFCD]) to the east, a fuel oil storage tank to the north, and an electrical switchyard to the west. Additional surrounding land uses include Pacific Coast Highway to the south;the Pacific Holdings storage tank facility to the east;Ascon/Nesi Landfill to the northeast;commercial, industrial,recreational,and residential uses to the north; and Newland Street, Huntington-By-The-Sea Mobile Home Park, and Cabrillo Mobile Home Park to the west. OFF-SITE PIPELINE ALIGNMENT AND UNDERGROUND PUMP STATIONS On-Site Land Uses ' Proposed Pipeline Alignment The proposed pipeline alternatives(refer to Exhibit 3-3, CONCEPTUAL PIPELINEALIGNMENTS) ' are proposed to be routed primarily within existing street right-of-way and easements. However, portions of the pipeline alignments are proposed to be installed within areas of the Costa Mesa Country Club (Costa Mesa) and Fairview State Hospital (Costa Mesa). ' OC-44 Booster Pump Station ' The proposed OC-44 underground pump station site is located within an Orange County Resource Preservation Easement, and is currently occupied by open space and vegetation (refer to Exhibit 5.7-3, BOOSTER PUMP STATION LOCATION PHOTOGRAPHS). Although the Resource ' Preservation Easement is subject to various development restrictions, the pump station would be situated in an area of the easement where limited development is allowed and two underground pump stations already exist. The footprint of the proposed underground pump station would be City of Huntington Beach April 5, 2005 5.1-1 Seawater Desalination Project at Huntington Beach 5.1 LAND USE/RELEVANT PLANNING Draft Recirculated Environmental Impact Report approximately 100 feet by 100 feet, and would require a construction easement of 125 feet by 125 feet. It should be noted that the proposed pump station site is located adjacent to(but not within)a Natural Community Conservation Plan/Habitat Conservation Plan (NCCP/HCP) area. Coastal Junction Booster Pump Station The Coastal Junction underground booster pump station is proposed within the parking lot of St. Paul's Greek Orthodox Church within the City of Irvine, located at 4949 Alton Parkway. The underground pump station would be constructed within the north/northwestern portion of the church parking lot, in an area used for both parking and volleyball activities. The footprint of the proposed underground pump station would be approximately 100 feet by 100 feet, and would require a construction easement of 125 feet by 125 feet. Also refer to Exhibit 5.7-3, BOOSTER PUMP STATION LOCATION PHOTOGRAPHS. Adjacent Land Uses Proposed Pipeline Alignment The proposed alternative pipeline alignments are situated adjacent to a variety of land uses, including residential, commercial, educational, medical, and recreational. OC-44 Booster Pump Station The proposed OC-44 booster pump station site is surrounded by open space to the north, open space and residential to the east, two existing underground pump stations, open space, and residential to the west, and open space to the south. It should be noted that the proposed pump station site is located adjacent to (but not within) a Natural Community Conservation Plan/Habitat Conservation Plan (NCCP/HCP) area. Coastal Junction Booster Pump Station The Coastal Junction pump station site is surrounded by the St. Paul's Church to the south, the Woodbridge Village Association to the west, an apartment complex to the east and open space to the north. RELEVANT PLANNING Zoning and Subdivision Ordinance The purpose of the City's Zoning and Subdivision Ordinance is to implement the policies of the City of Huntington Beach General Plan. The goal of this document is to promote and protect the public health, safety, and general welfare of Huntington Beach residents and provide the physical, economic, and social advantages, which result from a comprehensive and orderly planned use of land resources. The City of Huntington Beach General Plan designates the proposed project site as Public (P). Typical permitted uses within areas of this designation include governmental administrative and related facilities, such as utilities, schools, public parking lots, infrastructure, religious, and similar uses. The project site is zoned as Public-Semipublic with Oil and Coastal Zone Overlays (PS-O-CZ). This district provides for similar uses to those allowed by the City of Huntington Beach General Plan. The Seawater Desalination Project at Huntington Beach is a permitted use(refer to Exhibit 5.1-1,ZONING). The proposed desalination facility does not propose to change any existing zoning designations. As the subject site is located within the coastal zone, the City's Local Coastal Program is inclusive of the Zoning and Subdivision Ordinance and its policies. City of Huntington Beach April 5, 2005 5.1-2 Seawater Desalination Project at Huntington Beach 5.1 LAND USE/RELEVANT PLANNING Draft Recirculated Environmental Impact Report ' City of Huntington Beach General Plan The City of Huntington Beach General Plan is used by the City of Huntington Beach as the document to set baseline land use criteria within the City (refer to Exhibit 5.1-2 LAND USE DESIGNATIONS). The project site is designated as"Public(P)"by the City's General Plan. Typical permitted uses within areas of this designation include governmental administrative and related ' facilities, such as utilities, schools, public parking lots, infrastructure, religious, and similar uses. The policies and portions of the following General Plan Elements are relevant to the proposed project: Local Coastal Program (Coastal Element) ' The California Coastal Act of 1976 requires that local governments lying whole or in part within the coastal zone prepare a Local Coastal Program for its portion of the coastal zone. The Coastal Zone within the City of Huntington Beach runs from the northern City limit at Seal Beach,south nine miles ' to the Santa Ana River at the Huntington Beach/Newport Beach boundary, totaling approximately five square miles. The following policies of the Local Coastal Program are relevant to the proposed desalination facility, as it lies within the Coastal Zone: ❖ Policy 1.1.1 (page Coastal Element IV-C-100): With the exception of hazardous industrial development,new development shall be encouraged to be located within, contiguous or in close proximity to,existing developed areas able to accommodate it ' or,where such areas are not able to accommodate it, in other areas with adequate public services, and where it will not have significant adverse effects, either individually or cumulatively, on coastal resources. ' ❖ Policy 4.2.1 (page Coastal Element IV-C-111): Ensure that the following minimum standards are met by new development in the Coastal Zone as feasible and ' appropriate: 1. Preservation of public views to and from the bluffs, to the shoreline and ocean and to the wetlands. 2. Adequate landscaping and vegetation. 3. Evaluation of project design regarding visual impact and compatibility. 4. Incorporate landscaping to mask oil operations and major utilities, such as the electrical power plant on Pacific Coast Highway. ❖ Policy 4.2.3 (page Coastal Element IV-C-111): Promote the preservation of significant public view corridors to the coastal corridor,including views of the sea and the wetlands through strict application of local ordinances, design guidelines, and related planning efforts, including defined view corridors. ' ❖ Policy 4.7.1 (page Coastal Element IV-C-114): Promote the use of landscaping material to screen uses that detract from the scenic quality of the coast along public right-of-way and within public view. ' ❖ Policy 4.7.5 (page Coastal Element IV-C-114): Require the review of new and/or expansions of existing industrial and utility facilities to ensure that such facilities will ' not visually impair the City's coastal corridors and entry nodes. d• Policy 4.7.8(page Coastal Element IV-C-114): Require landscape and architectural buffers and screens around oil production facilities and other utilities visible from public rights-of-way. ' City of Huntington Beach April 5, 2005 5.1-3 Seawater Desalination Project at Huntington Beach 5.1 LAND USE/RELEVANT PLANNING Draft Recirculated Environmental Impact Report ❖ Policy 4.7.9 (page Coastal Element IV-C-114): Require the removal of non- productive oil production facilities and the restoration of the vacated site. ❖ Policy 6.1.1 (page Coastal Element IV-C-116): Require that new development include mitigation measures to prevent the degradation of water quality of groundwater basins, wetlands, and surface water. ❖ Policy 6.1.13 (page Coastal Element IV-C-119): Encourage research and feasibility studies regarding ocean water desalinization as an alternative source of potable water. Participate in regional studies and efforts where appropriate. ❖ Policy 6.1.19 (page Coastal Element IV-C-119): Prior to approval of any new or expanded seawater pumping facilities, require the provision of maximum feasible mitigation measures to minimize damage to marine organisms due to entrainment in accordance with State and Federal law. ❖ Policy 7.1.3 (page Coastal Element IV-C-121): Development in areas adjacent to environmentally sensitive habitat areas and parks and recreation areas shall be sited and designed to prevent impacts which would significantly degrade those areas,and shall be compatible with the continuance of those habitat and recreation areas. ❖ Policy 7.1.4 (page Coastal Element IV-C-121): Require that new development contiguous to wetlands or environmentally sensitive habitat areas include buffer zones. Buffer zones shall be a minimum of one hundred feet setback from the landward edge of the wetland, with the exception of the following: A lesser buffer may be permitted if existing development or site configuration precludes a 100-foot buffer, or conversely, a greater buffer zone may be required if substantial development or significantly increased human impacts are anticipated. In either case, the following factors shall be considered when determining whether a lesser or wider buffer zone is warranted. Reduced buffer zone areas shall be reviewed by the Department of Fish and Game prior to implementation. 1. Biological significance of adjacent lands: The buffer should be sufficiently wide to protect the functional relationship between wetland and adjacent upland. 2. Sensitivity of species to disturbance:The buffer should be sufficiently wide to ensure that the most sensitive species will not be disturbed significantly by permitted development, based on habitat requirements of both resident and migratory species and the short and long term adaptability of various species to human disturbance. 3. Susceptibility of parcel to erosion: The buffer should be sufficiently wide to allow for interception of any additional material eroded as a result of the proposed development based on soil and vegetative characteristics, slope and runoff characteristics, and impervious surface coverage. 4. Use of existing cultural features to located buffer zones: Where feasible, development and buffer zones should be located on the sides of roads, dikes, irrigation canals, flood control channels, etc., away from the environmentally sensitive habitat area. ❖ Policy 7.1.5 (page Coastal Element IV-C-122): Notify State and Federal agencies having regulatory authority in wetlands and other environmentally sensitive habitats when development projects in and adjacent to such areas are submitted to the City. The implementation of any Habitat Conservation Plan shall require an amendment to City of Huntington Beach April 5, 2005 5.1-4 IN IN 0 r � a ...........- psi ��w11►� ♦ �11111 • ♦ 111 111 111 111 i� i� ��. ii ♦ IN .a �■ ■■ ■■ ■a MIN F0 ON *� ♦e�111f11 IN ii ■ai�i ii ii ii ON ii :: ��1111�, ■ ■■ ■. ■■. ■■ w7WE miss Nos ■■ a■ ■■ ■ Mg 3 ■0 W.m M• IIIIIIIE�111 - ♦ ♦ 1E�111 • �1 . .. n■ ■■ am MR ®� �Y1111 .. a■ No ■■ ■. �IIIIIIY1111 a ■■ as ■■ ■■ ■■ E1111\� : ■■ r■ a■ ■■ No /IIIIE�1111 ■■ i. .■ ■■ ■■ ♦� lyM�11111 ■■ ro ■■ ■a ■■ IIIIIYIIa11 11� r MEMIN 111 �IIIIIIIIIIII1111111111111111111l - . toll'.� t�'�11111111111® ,.�i1,1 �■ ■■ :C71! o : :: IIa IIIIIIa General Plan �- Uj w Seawater ` 40 ; : 3 `- Desalination 1 Plant City of Huntington Beach RM-15 TT v1:1! 'ri.. •: r'i:••. ':'tp is '.=1.v,:"•'a•Ls x' �^ • :�v.�..�'i •.r..i:�i:'• pytOr. ^i�n1••L.;e. •;i.t L•p•i•s• a` � z ,QS'S y Open Space(Shore) P Public t:./:.•tt::3:•...r•:•r . L .•�r-.�^ •OS-C P P ;;:::.,ji;V� <t••• •jrj•• , &_ e.�.• Open Space Parcels :••tp•:•;.:•.i y (Conservation) {•: ��`f°�',r s CV Commercial Visitor SE Coastal Area r•2:"::� ii�p~ L~ o Industrial Mfg•'•'• j ` '�,;::-•; '.;i••L Max.floor area ration of 0.5,design overlay) •,s• ?:�:y: „r(d, Residential Medium Densitycw,mo� �'`:� •i: •' RM-15 (Max.of 15 dwelling units per acre) N'111:NUS1Y[:TIIISMAI` :�Y'!�:r.,. •. ,:�:j:1•' '� ,•7; Information Services t�epnnment IfMWrW Ma Y.esstw :,i ':,�fl t•". 'l:•� »f �v Residential Medium Density a ,s«s-w<t.•o►,.:-.o _ RM-15-sp Max.of 15 dwelling units per acre :K°r 'uw:r::.�`a�`rYe' •°'°••• �••��; RL-7 Residential Low Density ,,..,,.,„.,.,,.,,:o,e., �w1'••Y+�: ^="�:`,•' o.<.~.c°sxs (Max.of 7.0 dwelling units per net acre) •:z. Source:City of Huntington Beach,December 2004. NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH Q - Land Use Designations CONSULTING 02105•JN 10-101409.002 Exhibit 5.1-2 Seawater Desalination Project at Huntington Beach 5.1 LAND USE/RELEVANT PLANNING Draft Recirculated Environmental Impact Report the Local Coastal Program. Incidental take of sensitive habitat and/or species that occurs in the context of development must be consistent with this LCP. ❖ Policy 10.1.4 (page Coastal Element IV-C-128): Require appropriate engineering and building practices for all new structures to withstand ground shaking and liquefaction such as those stated in the Uniform Building Code. Land Use Element 4• Policy LU 4.1.1 (page II-LU-20): Require adherence to or consideration of the policies prescribed for Design and Development in this Plan, as appropriate. ❖ Policy LU 4.1.2 (page II-LU-20): Require that an appropriate landscape plan be submitted and implemented for development projects subject to discretionary review. ❖ Policy LU 4.1.6(page II-LU-20): Require that commercial and industrial development incorporate adequate drought-conscious irrigation systems and maintain the health of the landscape. ❖ Policy LU 4.2.1 (page II-LU-20): Require that all structures be constructed in accordance with the requirements of the City's building and other pertinent codes and regulations; including new, adaptively re-used, and renovated buildings. ❖ Policy LU 4.2.4 (page II-LU-20): Require that all development be designed to provide adequate space for access, parking, supporting functions, open space, and other pertinent elements. Policy LU 4.2.5 (page II-LU-20): Require that all commercial, industrial, and public development incorporate appropriate design elements to facilitate access and use as required by State and Federal laws such as the American's with Disabilities Act. 44. Policy LU 5.1.1 (page II-1-U-21): Require that development protect environmental resources by consideration of the policies and standards contained in the Environmental Resources/Conservation Element of the General Plan and Federal (NEPA)and State (CEQA) regulations. During the development review process: 1. Review any development proposal for the Bolsa Chica area to ensure that no development is permitted in Federally delineated wetlands; and 2. Review any development proposed for non-wetland areas to ensure that appropriate setbacks and buffers are maintained between development and environmentally sensitive areas to protect habitat quality. ❖ Policy LU 7.1.2 (page II-LU-22): Require that development be designed to account for the unique characteristics of project sites and objectives for community character and in accordance with the Development A Overlay Schedule as appropriate. ❖ Policy LU 7.1.5(page I I-LU-22):Accommodate the development of a balance of land uses that maintain the City's fiscal viability and integrity of environmental resource. City of Huntington Beach April 5, 2005 5.1-7 Seawater Desalination Project at Huntington Beach 5.1 LAND USE/RELEVANT PLANNING Draft Recirculated Environmental Impact Report ❖ Policy LU 12.1.4 (page II-LU-41): Require that new and recycled industrial projects be designed and developed to achieve a high level of quality, distinctive character, and compatible with existing uses. ❖ Policy LU 12.1.5(page II-1-U-41): Require that new and recycled industrial structures and sites be designed to convey visual interest and character and to be compatible with adjacent uses, considering the: 1. Use of multiple building masses and volumes to provide visual interest and minimize the visual sense of bulk and mass; 2. Architectural design treatment of all building elevations; 3. Use of landscaping in open spaces and parking lots, including broad landscaped setbacks from principal peripheral streets; 4. Enclosure of storage areas with decorative screening or walls; 5. Location of site entries to minimize conflicts with adjacent residential neighborhoods; and 6. Mitigation of noise, odor, lighting, and other impacts. 4. Policy LU 12.1.7 (page II-LU-42): Control the development of industrial uses that use,store, produce,or transport toxins,generate unacceptable levels of noise or air pollution, or result in other impacts that may adversely impact Huntington Beach. Urban Design Element ❖ Policy UD 2.1.1 (Page II-UD-27): Require that new development be designed to consider coastal views in its massing, height, and site orientation. Economic Development Element ❖ Policy ED 2.5.2(Page II-ED-24): Seek to capture new growth industries such as,but not limited to: 1. Knowledge based industries, such as research and development firms (higher technology communications and information industries); 2. Communication industry service providers and equipment manufacturers which are creating the next series of consumer and utility company equipment and services; 3. Biotechnical industries; 4. Environmental technology; and 5. Point of sale industries. Environmental Resources/Conservation Element ❖ Policy ERC 4.1.5 (Page IV-ERC-25): Promote the preservation of public view corridors to the ocean and the waterfront through strict application of local ordinances, design guidelines and related planning efforts, including defined view corridors. Air Quality Element ❖ Policy AQ 1.8.2 (Page IV-AQ-15): Require installation of temporary construction facilities(such as wheel washers)and implementation of construction practices that minimize dirt and soil transfer onto public roadways. City of Huntington Beach April 5, 2005 5.1-8 Seawater Desalination Project at Huntington Beach 5.1 LAND USE/RELEVANT PLANNING Draft Recirculated Environmental Impact Report Environmental Hazards Element ❖ Policy EH 1.2.1 (Page V-EH-24): Require appropriate engineering and building practices for all new structures to withstand groundshaking and liquefaction such as stated in the Uniform Building Code (UBC). Noise Element d• Policy N 1.2.2 (Page V-N-6): Require new industrial and new commercial land uses or the major expansion of existing land uses to demonstrate that the new or expanded use would not be directly responsible for causing ambient noise levels to exceed an exterior Ldn of 65 dB(A)on areas containing noise sensitive land uses. Hazardous Materials Element ❖ Policy HM 1.1.4 (Page V-HM-7): Implement federal, state, and local regulations for the handling, storage, and disposal of hazardous materials. ❖ Policy HM 1.2.2 (Page V-HM-7): Ensure that hazardous waste transportation activities are conducted in a manner that will minimize risks to sensitive uses. ❖ Policy HM 1.4.4(Page V-HM-8): Require that owners of contaminated sites develop a remediation plan with the assistance of the Orange County Environmental Management Agency(EMA). Southeast Coastal Redevelopment Plan The proposed project site is located within the Southeast Coastal Redevelopment Plan area. This redevelopment plan became effective in August of 2002,with the associated Program EIR certified in June of 2002. As adoption of the Southeast Coastal Redevelopment Plan did not change any General Plan or zoning designations within the redevelopment area (including the proposed desalination facility site), the proposed Seawater Desalination Project at Huntington Beach will be consistent with the Southeast Coastal Redevelopment Plan, General Plan, and zoning. California Coastal Act As the proposed project is situated within the Coastal Zone in the City of Huntington Beach,and the City has an approved Local Coastal Plan,the desalination facility will require a Coastal Development Permit from the City. However, various types of development within the Coastal Zone are also required to obtain a Coastal Development Permit from the California Coastal Commission. These developments are defined in the California Coastal Act (January 1, 2004), Section 30106 as, "on land, in or under water, the placement or erection of any solid material or structure; discharge or disposal of any dredged material or of any gaseous,liquid,solid,or thermal waste...or construction, reconstruction, demolition, or alteration of the size of any structure, including any facility of any private, public, or municipal utility..." As such,the proposed desalination facility's ocean discharge will require separate review and approval by the California Coastal Commission of a Coastal Development Permit. City of Huntington Beach April 5, 2005 5.1-9 Seawater Desalination Project at Huntington Beach 5.1 LAND USE/RELEVANT PLANNING Draft Recirculated Environmental Impact Report SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS (SCAG) REGIONAL COMPREHENSIVE PLAN AND GUIDE Growth Management Chapter ❖ 3.03: The timing, financing, and location of public facilities, utility systems, and transportation systems shall be used by SCAG to implement the region's growth policies. ❖ 3.18: Encourage planned development in locations least likely to cause adverse environmental impacts. ❖ 3.21: Encourage the implementation of measures aimed at the preservation and protection of recorded and unrecorded cultural resources and archaeological sites. ❖ 3.22: Discourage development,or encourage the use of special design requirements, in areas with steep slopes, high fire, flood, and seismic hazards. �:- 3.23: Encourage mitigation measures that reduce noise in certain locations,measures aimed at preservation of biological and ecological resources, measures that would reduce exposure to seismic hazards, minimize earthquake damage, and to develop emergency response and recovery plans. Air Quality Chapter ❖ 5.11: Through the environmental document review process, ensure that plans at all levels of government (regional, air basin, county, subregional, and local) consider air quality, land use,transportation,and economic relationships to ensure consistency and minimize conflicts. IMPACTS Significance Criteria A project will normally have a significant adverse environmental impact on land use if it results in any of the following: ❖ Physically divide an established community; ❖ Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect; and/or d• Conflict with any applicable habitat conservation plan or natural community conservation plan. Potential impacts related to land use and relevant planning have been identified and are categorized below according to topic. LAND USE The project proposes to implement a seawater desalination facility on a site surrounded by industrial uses. Residential uses are situated in the site vicinity,the nearest of which is located approximately City of Huntington Beach April 5, 2005 5.1-10 Seawater Desalination Project at Huntington Beach 5.1 LAND USE/RELEVANT PLANNING Draft Recirculated Environmental Impact Report 500 feet west of the subject site. The project has the potential to create impacts with regards to air quality, noise, aesthetics, hazards and hazardous materials, and short-term construction impacts (addressed in the corresponding EIR section). However,the proposed desalination facilitywould be consistent with the City of Huntington Beach General Plan, Local Coastal Program,and Zoning and Subdivision Ordinance,and will be subject to discretionary review and conditions of approval as part of the City's Conditional Use Permit and Coastal Development Permit process. In addition, the proposed project would replace dilapidated fuel oil storage tanks with a desalination facility and aboveground product water storage tank, which would improve the site's aesthetic character. The existing site does not provide coastal access and the proposed desalination facility does not interfere or limit access to the coast by the public. The project does not affect the visual elements of the coastal environment. All the proposed facilities are shorter than the existing structures that will be removed. The City's Design Review Board has approved the design of the project, including all landscaping. The treatment facilities are located inside an existing industrial site and will be buffered by the approved landscaping. HBGS is permitted to withdraw seawater from the ocean 24 hours per day to meet its cooling water needs. The project will not pump or withdraw seawater directly from the ocean. The project is designed to withdraw water from the discharge pipeline of the HBGS cooling water system. Concern was raised through comments on the previously circulated EIR that approval of the desalination facility would extend the life of the HBGS. This is not the case. As evidenced by the following statement,the California Energy Commission (CEC)is aware of the proposed project and its relationship to the HBGS. "AES (as the land owner) and Poseidon Company have filed for a Conditional Use Permit with the City of Huntington Beach to construct and operate a water desalination facility on a portion of the 53-acre site. The possible development of a desalination facility would not have an effect on the land use considerations relevant to the proposed project (AES retooling). Any land use impacts generated by the desalination facility would be identified and evaluated in the City's environmental analysis."' With implementation of standard construction measures and recommended mitigation measures throughout the EIR,there are no anticipated significant land use impacts associated with short-term construction/remediation activities or long-term facility operation. The proposed pipeline alternatives and underground pump station are adjacent to a variety of land uses, including residential, open space,commercial,educational,medical and recreational. However,the pipelines and underground pump stations would be subsurface and are not anticipated to result in any long-term land use impacts. In addition,it should be noted that the St. Paul's Greek Orthodox Church has been notified of the proposed pump station and has provided a letter of interest in response. These issues are discussed within other EIR sections, including 5.4 (Air Quality), 5.5(Noise), 5.7 (Aesthetics/Light& Glare), 5.8 (Hazards and Hazardous Materials), and 5.9 (Construction Related Impacts). RELEVANT PLANNING The project evaluated within this EIR proposes to implement a 50 mgd desalination facility within an industrial area. Project implementation would be consistent with the City of Huntington Beach General Plan, Local Coastal Program,and Zoning and Subdivision Ordinance,and SCAG Regional Comprehensive Plan and Guide(RCPG)because it would be consistent with the goals and policies of each plan, program and ordinance. During the design development stage,the Applicant will be submitting more detailed plans reflecting code and policy compliance with specific issues. No significant relevant planning issues have been identified. May 2001 Certification of Units 3 and 4 for the HBGS, page 14. City of Huntington Beach April 5, 2005 5.1-11 Seawater Desalination Project at Huntington Beach 5.1 LAND USE/RELEVANT PLANNING Draft Recirculated Environmental Impact Report MITIGATION MEASURES LAND USE None required. RELEVANT PLANNING None required. UNAVOIDABLE SIGNIFICANT IMPACTS None have been identified. City of Huntington Beach April 5, 2005 5.1-12 5.2 GEOLOGY, SOILS, & SEISMICITY The following section is based on information supplied by the City of Huntington Beach General Plan (May 1996), United States Department of Agriculture Soil Conservation Service and Forest Service Soil Survey (September 1978), the United States Geologic Survey Newport Beach Quadrangle(1981), the Fault-Rupture Hazard Zones in California,Alquist-Priolo Earthquake Fault Zoning Act (Revised 1997), the Geologic Map of Orange County California, Showing Mines and Mineral Deposits, California Geological Survey (formerly the California Division of Mines and Geology) (1981), the Preliminary Review of Geotechnical Constraints and Geologic Hazards, Poseidon Resources Orange County Desalination Proiect, Huntington Beach, California (July 11, 2002), the Preliminary Review of Geotechnical Constraints and Geologic Hazards, Poseidon Resources Orange County Desalination Proiect,Huntington Beach, California, North and West Tank Options(July 12, 2002), the Preliminary Seismic Assessment, Orange County Desalination Project (November 2002), and the Federal Emergency Management A_gency Flood Insurance Rate Map (revised February 18, 2004). In addition, Robert H. Sydnor of the California Geological Survey provided a comprehensive bibliography and several relevant maps that have been reviewed and incorporated into this section (see Section 10, BIBLIOGRAPHY). It should be noted that no site-specific geotechnical investigation has been performed for the proposed project. However, there have been several subsurface geotechnical/environmental studies performed in the site vicinity to provide a basis for the Geotechnical Reports prepared for this EIR (refer to Appendix H, GEOLOGICAL REPORT- DESALINATION SITE, and Appendix I, GEOLOGICAL REPORT-ABOVEGROUND PRODUCT WATER STORAGE TANK SITE). These studies include: ❖ Geotechnical Investigation for Future Huntington Beach Maintenance Facility, East End of Edison Road, East of Newland Street, Huntington Beach, California. Prepared by G.A. Nicoll, Inc., 2000. ❖ Geotechnical Investigation, Huntington Beach Channel(Flood Control Facility No. D01, City of Huntington Beach, County of Orange, California. Prepared for the Orange County Environmental Management Agency, February 21, 1991. ❖ Huntington Beach Generating Station Phase 11 Environmental Site Assessment. Prepared by CH2M Hill, November 27, 1996. ❖ Preliminary Geotechnical Assessment, Southeast Reservoir Site Acquisition, Huntington Beach, California. Prepared by GeoLogic Associates, May 24, 2002. EXISTING CONDITIONS PROPOSED DESALINATION FACILITY SITE Site Topography The proposed project site is unpaved and is currently developed with three large fuel oil storage tanks (South, East, and West tanks), containment berms, pipelines, pumps, and associated structures. The subject site lies at an elevation of approximately five feet above mean sea level. The three storage tanks on-site are surrounded on all sides by a 10-to 15-foot high soil containment berm (the berm to the north of the South fuel oil tank is situated outside of the project site boundaries, however). Each tank is elevated by approximately two to three feet above the floor of the site, which slopes gently to the southeast. City of Huntington Beach April 5, 2005 5.2-1 Seawater Desalination Project at Huntington Beach 5.2 GEOLOGY, SOILS,AND SEISMICITY Draft Recirculated Environmental Impact Report Surrounding Topography Areas within the project vicinity are similar in topography to the subject site. Surrounding areas to the west, north, and east are generally flat and have an approximate elevation of five feet above mean sea level. Elevations to the south gradually slope in a southwest orientation along Huntington State Beach and Huntington City Beach towards the Pacific Ocean. The Santa Ana River, located to the east of the project vicinity, lies in a depression with an approximate elevation of sea level at the mouth to six inches above mean sea level a quarter mile upstream. In addition,the Ascon/Nesi Landfill (located approximately 300 feet northeast of the project site)is elevated several feet above grade as a result of the accumulation of oil drilling byproducts and solid waste during its operation from approximately 1938 to 1984. The most noticeable topographic feature in the area is the Huntington Beach Channel, which is operated and maintained by the Orange County Flood Control District (OCFCD). This channel borders the eastern margin of the project site. This 60-foot wide channel is bounded on each side by a five-to seven-foot high levee,while the bottom of the channel lies at one foot below mean sea level. The interior sides of the portion of the levee nearby the subject site have recently been improved with driven sheet-piles in order to increase the capacity of the channel. Each of the 33-to 36-foot long interconnecting sheet-piles have been driven to the point where only 10 to 12 feet of each pile are exposed above the bottom of the channel. The southern limit of the new sheet-pile wall terminates near the southeast corner of the project site.'2 SITE GEOLOGY Surficial Geology The native soils beneath the project site consist of an upper 60-foot thick layer of interbedded coastal estuarine/littoral sediments consisting of fine sand, silt, clay, and mixtures thereof. According to Geologic Associates(2002),these sediments range in age from approximately 8,600 - years old to the present. Between depths of about 60 to 90 feet, the native sediments are represented by middle to late Holocene (8,600 to 11,000 years old) fluvial deposits. These sediments are composed largely of sand and clayey sand with layers and lenses of silt and highly plastic clay that contains varying amounts of organic detritus. Below a depth of 90 feet below ground surface are Pleistocene (11,000 to 1.8 million years old) marine and non-marine strata. These native soils are overlain by varying thicknesses of artificial fill soil that was placed during construction of the Huntington Beach Generating Station and associated fuel storage tanks. According to building foundation studies by G. A. Nicoll, Inc. (2000) for the newly constructed Huntington Beach Maintenance Facility(situated approximately 500 feet north of the site),without mitigation these alluvial deposits are considered unsuitable for foundation support due to their compressible nature when placed under structural (i.e. building) loads. Below this upper layer of highly compressible soils are deposits of sandy coastal alluvial soils that make up the Talbert aquifer. Limited standard penetration test (SPT) data indicate that the uppermost 10 to 16 feet of these sediments are highly susceptible to liquefaction during strong ground motion from nearby seismic sources. Below a depth of approximately 17 to 25 feet below existing ground surface, these alluvial sediments have"N-values"(as derived from SPT data)that are suggestive of soils that are not prone to liquefaction, nor are they considered compressible or subject to collapse under normal structural loads. ' Telephone conversation with Albric Ghokasian, Orange County Flood Control District, November 23,2004. 2 Geotechnical Investigation, Huntington Beach Channel, City of Huntington Beach, County of Orange, California: Consultants Report for Orange County Environmental Management Agency. Prepared by Geosoils, Inc., 1991. City of Huntington Beach April 5, 2005 5.2-2 Seawater Desalination Project at Huntington Beach 5.2 GEOLOGY,SOILS,AND SEISMICITY Draft Recirculated Environmental Impact Report There is no current evidence that would suggest the occurrence of soils containing collapsible, organic peat deposits in the vicinity of the project site. Seismicity/Faulting The primary seismic hazard to the subject site vicinity is the possibility of ground shaking due to the proximity of major active faults in the Southern California region. A number of concealed faults exist approximately 1.25 miles north of the proposed project site, while the South Branch Fault (a concealed fault which branches from the Newport Inglewood Fault)traverses the northern portion of the subject site (refer to Exhibit 5.2-1, REGIONAL GEOLOGY& SEISMICITY). Although the project area is not located within an Alquist-Priolo Earthquake Fault Zone (formerly referred to as Special Study Zones)as designated by the California Geological Survey3,the site is within approximately 1.25 miles of the Newport-Inglewood Fault Zone,an Alquist-Priolo Earthquake Fault Zone. Additional active or potentially active faults in the vicinity include: • Elsinore Fault-Located 28 miles from the City center and is capable of a magnitude 7.5 earthquake. • Palos Verdes-Coronado Bank Fault - Located 10 miles from the City center and is capable of a magnitude 7.5 earthquake. Raymond Fault- Located 30 miles from the City center and is capable of a magnitude 7.5 earthquake. • San Andreas Fault - Located 51 miles from the City center and is capable of a magnitude 8.3 earthquake. • Sierra Madre-San Fernando Fault-Located 32 miles from the City center and is capable of a 7.5 magnitude earthquake. Whittier-North Elsinore Fault-Located 19 miles from the City center and is capable of a magnitude 7.5 earthquake. • Elysian Park Fault-Located 25 miles from City center and is capable of a 7.0 magnitude earthquake. Compton Blind Thrust Fault-Located approximately 10 miles from the City center and is capable of a 7.0 magnitude earthquake. Torrance-Wilmington Fault-Located approximately 10 miles from the City Center and is capable of a magnitude 7.0 earthquake. Newport-Inglewood Fault Zone. The subject site is shown as being approximately 1.25 miles south of the Newport-Inglewood Fault Zone,which is an Alquist-Priolo Earthquake Fault Zone.4 Alquist- Priolo Earthquake Fault Zones are intended to prohibit the location of developments for human occupancy across the trace of active faults in order to minimize the loss of life and property in the event of an earthquake. The Newport-Inglewood Fault Zone is an active right-lateral fault system consisting of a series of en echelons fault segments and anticlinal folds that are believed to be the expression of a deep-seated fault within the basement rock.e,7,8 The fault zone is visible on the 3 Alquist-Priolo Earthquake Fault Zone Map, issued by the State Geologist, 1986; California Division of Mines and Geology Special Publication 42(1997). 4 Active Fault Near-Source Zones, California Division of Mines and Geology, map atlas page N-34, February 1998. 5 Faults that are in an overlapping or staggered arrangement. 6 Convex upward folds with cores containing the stratigraphically older rocks. 7 Bryant, 1988; Barrows, 1974. 8 City of Huntington Beach General Plan EIR, 1995. City of Huntington Beach April 5, 2005 5.2-3 Seawater Desalination Project at Huntington Beach 5.2 GEOLOGY, SOILS,AND SEISMICITY Draft Recirculated Environmental Impact Report surface as a series of northwest-trending elongated hills, including Signal Hill and the Dominguez Hills, extending from Newport Beach to Beverly Hills. The total fault length is approximately 44 miles. The estimated maximum earthquake magnitude assigned to the fault zone is 6.9Mw (momentum magnitude), based on its estimated rupture length versus magnitude relationship by Slemmons (1982) and its slip rate at 1 2 millimeter/year(a Type B seismic source). The South Branch Fault, a component of the Newport Inglewood Fault, traverses the northern portion of the project site under the existing South fuel oil storage tank. A seismic study performed for the Bolsa Chica Project(located approximately five miles northwest of the proposed desalination facility) indicates that the South Branch Fault is classified as neither active nor potentially active under the Bolsa Chica site.9 The City of Huntington Beach utilizes their 1996 General Plan and the CDMG's Alquist-Priolo Earthquake Fault Zones to develop four categories for faults within the City. The City's General Plan indicates that this fault is a Category C fault, requiring special studies and subsurface investigation for critical and important land uses. In addition, Geologic Associates' Preliminary Seismic Assessment, Orange County Desalination Project(2002) analyzes the potential for fault rupture beneath the proposed project site, currently occupied by the existing fuel oil tanks. A subsurface stratigraphic correlation/fault investigation was performed to assess the potential for surface fault rupture within Holocene-age deposits below the potential water tank sites. According to the criteria established by the California Division of Mines and Geology, a fault is considered "active" if it can be demonstrated that the fault has produced surface displacement within Holocene time(about the last 11,000 years). Due to the presence of a relatively thick layer of fill soils and shallow groundwater, conventional fault trenching and soil- stratigraphic techniques could not be employed by GeoLogic Associates to assess the presence of surface fault rupture potential. Instead, their investigation involved the use of cone penetrometer test (CPT) and exploratory borings for stratigraphic correlation purposes, as well as the use of radiocarbon dating of organic sediments and shells obtained from the exploratory borings. According to data collected, no evidence of faulting within Holocene sediments was found beneath the site. The report concludes that the risk of surface fault rupture is minimal over the lifetime of the proposed project. Liquefaction/Subsidence Potential Liquefaction is a seismic phenomenon in which loose, saturated, granular soils behave similar to liquid when subject to intense ground shaking. Liquefaction occurs when three general conditions exist: 1) shallow groundwater; 2) low density silty or fine sandy soils; and 3) high-intensity ground motion. Liquefaction occurs when the dynamic loading of a saturated sand or silt causes pore water pressures to increase to the point where grain-to-grain contact is lost and the material temporarily behaves as a viscous fluid. Liquefaction can cause settlement of the ground surface, settlement and tilting of engineered structures,flotation of buoyant buried structures and fissuring of the ground surface. A common trait of liquefaction is formation of sand boils-short lived fountains of soil and water that emerge from fissures or vents and leave freshly deposited conical mounds of sand or silt on the ground surface. The City of Huntington Beach General Plan designates the project area as having a Very High potential for liquefaction. In addition,the Seismic Hazards Zones Map prepared by the State Geologist(April 7,1997)shows the site as an Official Liquefaction Zone.10 In addition, due to the relatively loose, unconsolidated nature of near surface soils on-site,there is a moderate to high potential for earthquake-induced ground settlement and subsidence. 9 City of Huntington Beach General Plan EIR, 1995. 10 Seismic Hazard Zones Map,April 7, 1997,prepared by the State Geologist. City of Huntington Beach April 5, 2005 5.2-4 i TALBERT • � t� 6 e'�. .� �s�� ♦way rs .i+.• rY� • $ .. yy+fir. t Qac` QtM • • P +l w .« . 1 ` ' V 1 r '�� `+ y w ...N,' : ...,,'.: a a ri t r am"`*,. ` 'yes° f t 5. /F'11 f'.o � � 3 f c ..k � " • " ' ..«�....�.« t +t' WEST NEWPOR Q in • , 00 F. BORROW 00, f % `fit»..- : ..... ..v............ ��«• «i�. ^",rt a ixN may. ` / T / • a L + Qt i ' '` i; r 1' Aw"Lh;, y wy v�v� 'ty y' rila ...yu+t,qiG , �y i1r1 y,„yi` + a.. iy y;eii Sr yt"7"YN MIi'pi u�l, it 7 z "s i� " u4. �s. 1�i yy `.y`_ "tt i1 �4 , :6i11x,n�1 'a. asm` Ili�k' yi �� �I^ffi'� .+i a '�€ } r 1,10 € i"��"yy g�!uI�N�C :. aJ t'-,i,'"« �i a(U .it !,� Y"'i ,. ^„ i�.� n e r a, �" j y��� nik�L 'I _ ;;g d II a 7P �-d k ,p A,� -�' 4 I L 1 r �'ra,yA"` 41 t .g- AM Fi., ,fit � .'mar;i�'"�1° ;�'yi � tiW4�C, 'sue,�' `, ! �a� a ni �ti a s� s „�ia �"t yt ` Lw iir 1 �3r, �� I�� � ��9��1y��r�� a 4�^ Source:Geologic Map of Orange County California,Showing Mines and Mineral Deposits,California Division of Mines and Geology, 1981. * -Project Site • • •• concealed Fault Lines San Pedro Formation Terrace deposits Qt=Nonmarine terrace deposits Qtm=Marine terrace deposits t` 401 Limits of oil and gas Belch(califomio Division of Oil and Gas,1972). • Qac=Alluvium and coliuvium Qb=Beach sediments NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH Q Regional Geology and Seismicity CON9UkT1N0 02/05-A10-101409.002 Exhibit 5.2-1 Seawater Desalination Project at Huntington Beach 5.2 GEOLOGY, SOILS,AND SEISMICITY Draft Recirculated Environmental Impact Report ' According to building foundation studies by G. A. Nicoll, Inc. (2000) for the newly constructed Huntington Beach Maintenance Facility(situated approximately 500 feet north of the desalination facility site), the uppermost 13 feet of the native Holocene deposits are considered unsuitable for foundation support due to their compressible nature when placed under structural (i.e. building) loads. Limited standard penetration test (SPT) and cone penetrometer test (CPT)data (by G. A. Nicoll, Inc., 2000; and Geologic Associates, 2002 for the Beach Maintenance Facility and the proposed project site, respectively)indicate that the uppermost 10 to 16 feet of the native sediments are highly susceptible to liquefaction during strong ground motion from nearby seismic sources. According to the study performed by Geologic Associates (2002), the soil layers susceptible to liquefaction were not continuous beneath the proposed project site. Below a depth of about 17 to 25 feet, the native sediments have "N-values" (as derived from SPT and CPT data) that are suggestive of soils that are not prone to liquefaction. Soils below 17 to 25 feet are not considered compressible or subject to collapse under normal structural loads although some deeper sand lenses may be subject to liquefaction. Lateral Spread Lateral spreading involves the dislocation of the near surface soils generally along a near-surface liquefiable layer. In many cases,this phenomenon of shallow landsliding occurs on relatively flat or gently sloping ground adjacent to a"free face",such as an unsupported channel wall along a stream or flood control channel. Given the "weak" nature of near surface soils, fine-grained sediments, shallow groundwater, liquefaction-prone soils,and the nearby flood control channel,there is a high potential for lateral spread beneath the site during a major earthquake in the area. In addition, the sheet-piles that have recently been installed along the sides of the Huntington Beach Channel by the OCFCD are not designed to resist liquefaction or lateral loads that could occur as the result of a lateral spread." Landslides Potential landslide areas within the City of Huntington Beach are limited primarily to the mesa bluffs region. However,the potential for seismically induced landsliding along the levee of the neighboring Huntington Beach Channel is considered moderate to high. As stated above, the new sheet-pile walls that are to be constructed along the interior walls of the levee are not designed to withstand potentially large lateral forces associated with strong ground motion from a nearby earthquake. Tsunamis and/or Seiche Waves Tsunamis are long period sea waves that are seismically generated by seafloor displacements. Previous evaluations put the tsunami potential for the City of Huntington Beach at very low. Of more concern are seiche waves caused by tsunamis captured and reflected within the enclosed area of an inner harbor,such as Huntington Harbor. Seiche area damage is most severe in the same area as tsunami hazards. However,the project site is not in the immediate vicinity of a harbor. There is a potential for seiches to impact the subject site, as it is situated adjacent to the Huntington Beach Channel. The magnitude of seiche waves impacting the project site are anticipated to be lower than that of a tsunami,given the frictional energy dissipation of water running along the bottom and walls of the Channel. In addition, given that the existing 10 to 15-foot high containment berm along the eastern boundary of the project site would remain (running along the Huntington Beach Channel), the likelihood of seiches or tsunamis impacting the site is considered low. Impacts in this regard are anticipated to be less than significant. Mr.Phil Jones,Orange County Flood Control District, May 21,2001. City of Huntington Beach April 5,2005 5.2-6 Seawater Desalination Project at Huntington Beach 5.2 GEOLOGY, SOILS,AND SEISMICITY Draft Recirculated Environmental Impact Report Groundwater/Percolation and Drainage The subject site rests over the Talbert Aquifer,and is in a designated tidal flats region,characterized by poor drainage. Groundwater beneath the site fluctuates with the tidal cycles and the water level within the neighboring Huntington Beach Channel. Due to this interconnection,groundwater quality beneath the site is considered brackish. The site is underlain by shallow near surface water with depths ranging from five to seven feet under the surface within the project site vicinity.12 This condition contributes to the vicinity's very high liquefaction potential. OFF-SITE PIPELINE ALIGNMENT AND UNDERGROUND PUMP STATIONS Proposed Pipeline Alignment The proposed off-site product water delivery pipelines would be located primarily within existing roads or easements, generally flat. The pipeline alignment would traverse a wide range of surficial soils with varying characteristics and qualities, as the pipeline's length would be between approximately 30,000 and 40,000 linear feet. As with the desalination facility site, the off-site facilities are subject to typical seismic hazards of southern California. Shallow groundwater may be encountered along the pipeline alignment nearby the proposed desalination facility, depending on the depth of trenching for pipeline implementation. OC-44 Booster Pump Station The proposed underground booster pump station site would occur within an unincorporated portion of the County of Orange,within a Resource Preservation Easement. The pump station site rests at an approximate elevation of 200 feet above mean sea level. The surrounding terrain can be characterized as hilly, although much of the surrounding vicinity has been graded for residential development. Bedrock beneath the subject site belongs to the diabase intrusive volcanic formation, overlain by Calleguas clay loam soil.13 This soil is characterized as being well drained and moderately permeable. It should be noted that the site is within a designated Zone of Required Investigation for liquefaction hazards, and has demonstrated either a historic occurrence of liquefaction or local geological, geotechnical, and groundwater conditions indicate a potential for liquefaction.14 The subject site is not situated within an Alquist-Priolo Earthquake Fault Zone or earthquake-induced landslide Zone of Required Investigation as designated by the California Geological Survey.15 As the pump station site is situated approximately 3.5 miles from the Pacific Ocean, inundation by tsunamis and/or seiche waves is not expected to occur. Coastal Junction Booster Pump Station The Coastal Junction pump station location is situated at an approximate elevation of 80 feet above mean sea level. The site is located in the parking lot of a church within a developed area. The topography of the site is flat. The subject site is not located within an Alquist-Priolo Earthquake Fault Zone or earthquake induced Zone of Required Investigation as designated by the California Geological Survey.16 It is underlain by soils from the Sorrento-Mocho association, which is described as nearly level to moderate sloping, well drained sand loams, loams, or clay loams on 12 Huntington Beach Generating Station Phase II Environmental Site Assessment,CH2M Hill, November 27, 1996. 13 United States Department of Agriculture Soil Conservation Service and Forest Service Soil Survey,September 1978. 14 Seismic Hazard Zones,Tustin Quadrangle,Official Revised Map. California Geological Survey,January 17,2001. 15 Alquist-Priolo Earthquake Fault Zone Map,issued by the State Geologist,1986;California Geological Survey Special Publication 42(1997). 16 Alquist-Priolo Earthquake Fault Zone Map,issued by the State Geologist,1986;California Geological Survey Special Publication 42 (1997). City of Huntington Beach April 5, 2005 5.2-7 Seawater Desalination Project at Huntington Beach 5.2 GEOLOGY,SOILS,AND SEISMICITY Draft Recirculated Environmental Impact Report alluvial fans and flood plains." It should be noted that the site is within a designated Zone of Required Investigation for liquefaction hazards,and has demonstrated either a historic occurrence of liquefaction or local geological,geotechnical,and groundwater conditions indicate a potential for liquefaction.18 As the site is located over three miles from the ocean, inundation by tsunamis and/or seiche waves is not expected to occur. IMPACTS Significance Criteria Based on the criteria set forth by CEQA,a project may create a significant geological environmental impact if one or more of the following occurs: ❖ Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: • Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault; • Strong seismic ground shaking; • Seismic-related ground failure, including liquefaction; • Landslides; ❖ Result in substantial soil erosion or the loss of topsoil; ❖ Be located on a geologic unit or soil that is unstable or that would become unstable as a result of the project, and potentially result in on or off-site landslide, lateral spreading, subsidence, liquefaction or collapse; ❖ Be located on expansive soils, as defined in Table 18-1 B of the Uniform Building Code (1994), creating substantial risks to life or property; and/or ❖ Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater. PROPOSED DESALINATION FACILITY SITE Wind/Water Erosion It is anticipated that the entire subject would be either landscaped or paved, thereby reducing the likelihood for long-term operational wind/water erosion impacts to less than significant levels. However,the project would involve construction processes possibly causing wind and watererosion to occur during grading activities. The project would be subject to standard erosion control practices as typically required by the City of Huntington Beach. Any potential temporary increase in wind/water erosion would be reduced to less than significant levels with implementation of standard grading practices such as use of sandbags along the site perimeter (also refer to Section 5.3, HYDROLOGY AND WATER QUALITY, and Exhibit 3-16, CONCEPTUAL LANDSCAPE MASTERPLAN). 17 United States Department of Agriculture Soil Conservation Service and Forest Service Soil Survey,September 1978. 18 Seismic Hazard Zones,Tustin Quadrangle,Official Revised Map. California Geological Survey,January 17,2001. City of Huntington Beach April 5, 2005 5.2-8 Seawater Desalination Project at Huntington Beach 5.2 GEOLOGY,SOILS,AND SEISMICITY Draft Recirculated Environmental Impact Report Topography The proposed desalination facility site consists of three fuel storage tanks on a flat surface, surrounded by soil containment berms of 10 to 15 feet in height. The western and southern interior berms would be removed prior to construction of the desalination facility,while the eastern berm(the northern berm exists outside of the project boundaries)would not be removed. The site does not contain any other unique physical or topographical features. No significant landform impacts are anticipated. Geology/Soils As shallow groundwater exists on-site (at a depth of approximately five to seven feet below ground surface), saturated soils and caving conditions would be encountered during removal and excavation for grading/excavation below the groundwater table level. This would necessitate dewatering operations as well as lateral support for the sides of any excavation pits, if necessary. All dewatering activities would comply with National Pollution Discharge Elimination System (NPDES)regulations,and pumped groundwater would be sampled,tested,and treated,if necessary (refer to Section 5.9, CONSTRUCTION RELATED IMPACTS for more information regarding dewatering). As the uppermost 17 feet of native soils within project site boundaries are considered compressible upon placement of structural loads (aboveground storage tank, buildings, etc.), project implementation would require either the complete removal and recompaction of compressible soils or the use of piles and grade beams to support the structure. In addition, Type V cement would be used for concrete and special coatings or other measures for metal pipes to protect against the effects of corrosion. It is anticipated that the proposed product water storage tank could be supported by a conventional concrete mat type foundation,with provision to accommodate anticipated settlements due to existing saturated,soft soils and liquefaction. Soil conditions would not preclude the use of otherfoundation systems, however,which would be evaluated when design concepts are available. Dewatering may be necessary during construction, as shallow groundwater exists beneath the West tank site. A detailed geotechnical survey would be performed during the design phase of the proposed project. This survey would further characterize on-site soil and groundwater conditions and would determine the site's soil bearing capacity. This information would be used to develop a detailed foundation design for on-site structures. With implementation of recommended mitigation measures, and adherence to the Uniform Building Code (UBC), impacts in this regard are anticipated to be less than significant (also refer to Section 5.9, CONSTRUCTION RELATED IMPACTS). Seismicity/Faulting GeoLogic Associates completed a Preliminary Seismic Assessment for this project (refer to Appendix V, PRELIMINARY SEISMIC ASSESSMENT). The results of this preliminary study indicate an absence of evidence that faulting has ever occurred at the facility site and that the risk of future surface faulting at the desalination facility site is minimal. The Preliminary Seismic Assessment has determined that the maximum ground acceleration for the Maximum Credible Earthquake (MCE)for this site is 0.535 g. An earthquake of magnitude 6.9 on the Newport Inglewood fault was considered to be the MCE for the site. The Preliminary Seismic Assessment also indicates that the return period of an earthquake with the design MCE acceleration City of Huntington Beach April 5, 2005 5.2-9 tSeawater Desalination Project at Huntington Beach 5.2 GEOLOGY, SOILS,AND SEISMICITY Draft Recirculated Environmental Impact Report of 0.535 g is more than 200 years and its probability of occurrence during the next 50 years is below 10 percent. As a part of desalination operations, the operations staff would develop an earthquake mitigation and preparedness plan, which would be coordinated with the local jurisdiction's preparedness activities. This plan would define coordination measures to assure continuous facility operations and water delivery under earthquake emergency conditions. The desalination facility would be designed with one standby reverse osmosis train to provide additional reliability of water production and supply. Typically, desalination facilities, including the existing desalination facilities in California, are designed to operate with all available reverse osmosis trains in operation at all times. During the times of potential outages caused by scheduled or unscheduled maintenance or emergency events,such as an earthquake,these facilities operate at reduced capacity or are down for a certain period of time. The proposed desalination facility would be designed to produce 50 mgd of product water with 12 RO trains,and would be constructed with an additional 13th RO standby train, which can produce up to 4.2 mgd of water at any time. This additional train would provide increased reliability and redundancy that exceeds current reliability standards and common practices for desalination facility design. The proposed desalination facility would be the first facility in California with such additional production standby capacity and reliability provisions. Although the northern portion of the project site overlays the South Branch Fault, the site is not situated within an Alquist-Priolo Earthquake Fault Zone. The proposed project would be constructed in compliance with the seismic safety requirements of the Uniform Building Code (UBC) and applicable CDMG publications. Given the site's close proximity to the Newport-Inglewood and Compton Blind Thrust Faults, more stringent design measures may be warranted or required, as determined by the site-specific geotechnical survey for the project. All structures would be designed in accordance with the seismic design requirements of the most recent edition of the Uniform Building Code. The specific design provisions (wall and slab thickness, lateral bracing, structural configuration, etc.) for seismic enforcement would be developed during the design phase of this project. In addition, a detailed construction-level geotechnical study would be prepared during the design phase of the project. This report would include mitigation measures regarding grading, foundations, retaining walls, streets, utilities, remedial work, overexcavation/recompaction, dewatering, water quality, and chemical/fill properties of underground items including buried pipe and concrete and protection thereof. Impacts in this regard are expected to be less than significant with implementation of recommended mitigation measures. Liquefaction Potential The Preliminary Seismic Assessment prepared for the proposed project concluded that seismic activity from numerous faults within the vicinity, including the Newport Inglewood Fault Zone (the I closest active fault), may result in liquefaction in soils at depths of seven to 16 feet below ground surface (bgs). Soils below that depth were not found to be susceptible to liquefaction. Soil layers susceptible to liquefaction were not determined to be continuous throughout the proposed desalination facility site and the"North"and"West"tank sites. Liquefied soils may experience post- liquefaction settlements of four to five inches. Proposed on-site aboveground structures have the potential to experience post-liquefaction distress. In addition, the presence of liquefaction-prone soils and the location of the subject site relative to the Huntington Beach Channel pose a risk of seismically induced lateral spread. Substantial distress to both above and underground structures would occur in the form of seismically-induced landsliding. However, as stated above, a construction-level geotechnical study would be prepared for the proposed project site during the design phase of the project,which would recommend design measures to mitigate liquefaction and lateral spread impacts such as: 1)over excavation and recompaction of liquefaction/lateral spread- City of Huntington Beach April 5, 2005 5.2-10 Seawater Desalination Project at Huntington Beach 5.2 GEOLOGY,SOILS,AND SEISMICITY Draft Recirculated Environmental Impact Report prone soils;2)in-situ soil densification;3)injection grouting;or4)deep soil mixing. The desalination facility project would be subject to the Uniform Building Code (UBC) and applicable CDMG publications in regards to liquefaction. Upon adherence to applicable regulations and the incorporation of mitigation measures,impacts in this regard are expected to be less than significant. OFF-SITE PIPELINES AND UNDERGROUND PUMP STATION Proposed Pipeline Alignment The proposed product water delivery pipeline is not anticipated to result in significant impacts in regards to geology and soils,as the majority of the alignment would occurwithin existing street right- of-way and various utility lines that currently exist along the alignment. Pipeline construction would be subject to standard erosion control measures similar to those implemented for the desalination facility site to contain any potential wind and water erosion on-site. As the pipeline alignment is relatively flat and has been graded, impacts to natural topography are not anticipated. A design- level geotechnical investigation would be performed for the selected pipeline alignment to examine the potential for earthquake shaking hazards, surface rupture, shallow groundwater,and unstable soils (liquefaction, subsidence, lateral spread). Should the potential for such geological hazards exist,adequate mitigation for both pipeline construction and pipeline design would be incorporated to mitigate impacts in this regard to less than significant levels. Also refer to Section 5.9, CONSTRUCTION RELATED IMPACTS for a more detailed evaluation of pipeline construction. OC-44 Booster Pump Station Construction of the proposed off-site underground booster pump station would also be subject to standard erosion control measures as required by local,state,and federal regulations to contain any potential wind and water erosion on-site. As the site is relatively flat and is only approximately 0.5 acres in size, impacts to the natural topography of the site and surrounding vicinity are not anticipated. A design-level,site specific geotechnical study would be prepared for the underground pump station and would incorporate adequate mitigation measures (if deemed necessary) for geological hazards such as seismic shaking, surface rupture, shallow groundwater, liquefaction, subsidence, lateral spread, and landslides. As the underground pump station would require excavation to a depth of approximately 40 feet, lateral bracing for the sides of the chamber may be necessary as the site is in a designated liquefaction hazard zone.19 Upon the implementation of both standard and recommended mitigation measures, impacts in regards to geology and soils are not anticipated to be significant. Coastal Junction Booster Pump Station As both the geologic/seismic conditions of the site and design characteristics of the pump station are similar to that of the OC-44 pump station, refer to the impact analysis above. MITIGATION MEASURES WIND/WATER EROSION Refer to Section 5.3, HYDROLOGY DRAINAGE, AND STORM WATER RUNOFF, mitigation measure HWQ-1. 19 Seismic Hazard Zones,Tustin Quadrangle,Official Revised Map. California Department of Conservation,Division of Mines and Geology,January 17,2001. City of Huntington Beach April 5, 2005 5.2-11 Seawater Desalination Project at Huntington Beach 5.2 GEOLOGY,SOILS,AND SEISMICITY Draft Recirculated Environmental Impact Report TOPOGRAPHY None required. GEOLOGY/SOILS GEO-1 A detailed geotechnical report shall be prepared and submitted with the building permit application for the proposed desalination facility. This analysis shall include on-site soil sampling and laboratory testing of materials to provide detailed recommendations regarding grading, foundations, retaining walls, streets, utilities, remedial work, over excavation/recompaction, dewatering, water quality, and chemical/fill properties of underground items including buried pipe and concrete and protection thereof. The reports shall specifically address lateral spreading, flood control channel bank stability, liquefaction potential and groundwater constraints. Appropriate recommendations shall be provided to mitigate potentially adverse conditions. The geotechnical report shall also be submitted to the Department of Public Works for review and approval in conjunction with the grading plan. GEO-2 In conjunction with the submittal of application for a precise grading permit, the Applicant shall demonstrate to the satisfaction of the City Engineer that the preliminary geotechnical report recommendations have been incorporated into the grading plan unless otherwise specified in the final geotechnical report and/or by the City Engineer. GEO-3 Excavation for the proposed project shall implement dewatering activities in compliance with NPDES regulations. Pumped groundwater shall be sampled, tested, and (if deemed necessary)treated prior to discharge. GEO-4 As native on-site soils are compressible upon placement of structural loads, project implementation shall implement complete removal and recompaction of compressible soils or use of piles and grade beams to support on-site structures. GEO-5 Type V cement shall be used for concrete and buried metal pipes shall utilize special measures (coatings, etc.)to protect against the effects of corrosive soils. ' SEISMICITY/FAULTING GEO-6 Due to the potential for ground shaking in a seismic event, the project shall comply with the standards set forth in the UBC(most recent edition)to assure seismic safety to the satisfaction of the Department of Building and Safety prior to issuance of a building permit, including compliance with California Division of Mines and Geology Special Publication 117(Guidelines for Evaluating and Mitigating Seismic Hazards in California, adopted March 13, 1997). However,given the proximity of the site to the Newport-Inglewood and Compton Blind Thrust Faults,more stringent measures may be warranted. GEO-7 As the South Branch Fault (situated beneath the subject site) is classified as Category C by the City of Huntington Beach General Plan, special studies and subsurface investigation (including a site specific seismic analysis) shall be performed prior to issuance of a grading permit,to the approval of the City Engineer. The subsurface investigation shall include CPT and exploratory borings to determine the fault rupture potential of the South Branch Fault,which underlies the subject site. City of Huntington Beach April 5, 2005 5.2-12 Seawater Desalination Project at Huntington Beach 5.2 GEOLOGY, SOILS,AND SEISMICITY Draft Recirculated Environmental Impact Report LIQUEFACTION POTENTIAL GEO-8 Due to the potential for liquefaction within the project vicinity, the Applicant shall comply with the standards set forth in the UBC (most recent edition)for structures on-site to assure safety of the occupants to the satisfaction of the Department of Building and Safety prior to issuance of a building permit. These standards include compliance with the , California Geological Survey Special Publication 117 (Guidelines for Evaluating and Mitigating Seismic Hazards in California, adopted March 13, 1997) and Recommended Procedures for implementation of California Geological Survey Special Publication 117-Guidelines for Analyzing and Mitigating Liquefaction in California (Dr. Geoffrey R. Martin et al, May 1999). GEO-9 The proposed project shall incorporate adequate measures to stabilize structures from on-site soils known to be prone to liquefaction. Typical methods include, but are not limited to: + Over excavation and recompaction of soils; ❖ in-situ soil densification(such as vibro-flotation orvibro-replacement); ❖ injection grouting; and ❖ deep soil mixing. GEO-10 The site specific geotechnical investigation for the proposed project shall analyze the potential for lateral spread on-site. If deemed a possibility, adequate subsurface stabilization practices(similar to those utilized for liquefaction)shall be incorporated prior to the construction of on-site structures. OFF-SITE PIPELINES AND UNDERGROUND PUMP STATIONS Refer to Section 5.9, CONSTRUCTION RELATED IMPACTS. UNAVOIDABLE SIGNIFICANT IMPACTS None have been identified. City of Huntington Beach April 5, 2005 5.2-13 5.3 HYDROLOGY, DRAINAGE AND STORM WATER RUNOFF Information in this section was compiled from a site survey conducted by RBF Consulting on June 22, 2001;the Water Quality Control Plan for the Santa Ana River Basin(8)and amendments(1995) by the Santa Ana Regional Water Qbality Control Board, the Federal Emergency Management Agency Flood Insurance Rate Map(revised February 18,2004);the County of Orange General Plan (July 2, 2003); City of Irvine General Plan (1999); the United States Geological Survey (USGS) National Map Viewer (httpJ/nmviewogc.cr.usgs.gov/viewer.htm); and the Drainage Area Management Plan (2003) prepared by the County of Orange, Cities of Orange County, and the Orange County Flood Control District. EXISTING CONDITIONS REGIONAL DRAINAGE CONDITIONS The proposed project site is situated within the Santa Ana River Basin,which has a total drainage area of approximately 1,700 square miles. In general terms,the Santa Ana River Basin is a group of connected inland basins and open coastal basins drained by surface streams flowing generally southwestward to the Pacific Ocean.' The Santa Ana River empties into the Pacific Ocean approximately 1.5 miles downcoast(southeast)of the subject site. The flow of the Santa Ana River is intermittent and only substantial during storms. Long-term annual precipitation near the coast averages about 18.1 inches,of which 90%occurs between November and April. The Pacific Ocean lies approximately 2,000 feet south of the project site. The coast near the proposed project site is fronted by a broad, sandy beach and is backed by lowlands. The sea floor directly offshore is relatively smooth, with isobaths following the coastline. Offshore sediments range from fine to medium sand near-shore to sandy silt at a distance of about one mile from shore. The beach sands are normally transported southeastward by littoral currents,which are generated by incoming waves and modified by seafloor topography. PROPOSED DESALINATION FACILITY SITE On-Site Drainage The proposed desalination facility and associated product water storage tank are completely surrounded by containment berms of approximately 10 to 15 feet in height as a precaution against accidental fuel oil spillage. These berms prevent on-site stormwater from leaving project site boundaries. Stormwater collects within the storage tank area and either evaporates or percolates into the ground. In times of heavy rainfall,stormwater is either released through the manual valve of a drain line or is first tested for pollutants, and, if found to satisfactorily meet regulatory criteria, is pumped into the adjacent Huntington Beach Channel operated by the Orange County Flood Control District (OCFCD), ultimately emptying into the Pacific Ocean.2 Surrounding Drainage Conditions The general topography of the project site vicinity slopes gently to the southwest,towards the Pacific Ocean. Runoff upstream and downstream of the subject site generally follows this slope,emptying ' Water Control Management Plan,Santa Ana River Basin(8),Santa Ana Regional Water Quality Control Board,1995. 2 Han Tan,AES Huntington Beach,June 22,2001. City of Huntington Beach April 5, 2005 5.3-1 Seawater Desalination Project at Huntington Beach 5.3 HYDROLOGY, DRAINAGE, Draft Recirculated Environmental Impact Report AND STORM WATER RUNOFF into one of the three primary drainage facilities in the region,which consist of the Huntington Beach Channel,the Talbert Channel,and the Santa Ana River. All three drainage facilities are owned and operated by the OCFCD. All surface runoff within the vicinity of the project site eventually flows into the Pacific Ocean. A segment of the Huntington Beach Channel has recently been improved by the OCFCD to effectively double flow capacity(the Channel previously lacked 100-year flood protection capabilities). Metal sheet pile walls were placed on either side to expand the Channel's basewidth from approximately 30 to 85 feet. The project site obtained 100-year regional flood protection upon completion of these channel improvements.3 An approximately 131-acre wetland area is located southeast of the proposed project site,along a 1.5 mile stretch of Pacific Coast Highway. The wetlands are divided into two major components. To the southeast, the 17-acre Talbert Marsh opens to the ocean through a 100-foot wide entrance adjacent to the mouth of the Santa Ana River,approximately 1.3 miles downcoast(southeast)of the subject site. The Talbert Marsh is a recovering wetland area reintroduced to tidal influence in 1989. The second component of the wetland area is separated from the Talbert Marsh by Brookhurst Street, and includes 89 privately-owned acres directly southeast of the project site. This wetland area does not have tidal access, and water sources are limited to rainfall, urban runoff, and groundwater seepage. Due to extremely high salinities in the soils and seasonal ponds and poor quality of the brackish water marsh, restoration of the wetland area is proposed to occur in the planning stage. Water Quality (Groundwater) The lower part of the Holocene age sediments beneath the proposed project site consists of layered lenses of coarse sand and gravel known as the Talbert aquifer. A relatively impermeable cap of interbedded silts and clay up to about 15 feet thick overlies the Talbert aquifer. Given the proximity of the site to the Pacific Ocean,and its interconnection with the nearby Huntington Beach Channel, depth to groundwater within the site vicinity is between five to seven feet. The actual elevation of the groundwater table fluctuates with the ocean tides and water level in the adjacent neighboring flood control channel. Due to this interconnection, groundwater quality is considered brackish. Water Quality(Surface Water) As mentioned above,stormwater at the site is allowed to either evaporate,percolate into the ground, drained via a manual valve,or is pumped in to the OCFCD flood channel adjacent to the project site. No beneficial uses for surface water exist on site. Existing site runoff for the project vicinity contains moderate amounts of pollutants typical of urban areas, including oil and grease from automobiles, as well as incidental fertilizer and pesticides from routine maintenance of existing vegetation. OFF-SITE PIPELINE ALIGNMENT AND UNDERGROUND PUMP STATIONS Proposed Pipeline Alignment The proposed off-site product water delivery pipelines would be between approximately 30,000 and 40,000 linear feet,adjacent to a wide variety of land uses. The proposed pipelines would be located primarily within existing roads or easements that are generally flat and would be located entirely underground. The areas are generally drained by curb/gutter storm drain systems (for portions of the alignment within streets), on-site stormwater drainage systems (for portions within easements and other areas) and infiltration. 3 Telephone conversation with Albric Ghokasian, Orange County Flood Control District, November 23,2004. City of Huntington Beach April 5, 2005 5.3-2 Seawater Desalination Project at Huntington Beach 5.3 HYDROLOGY, DRAINAGE, Draft Recirculated Environmental Impact Report AND STORM WATER RUNOFF OC-44 Booster Pump Station The proposed OC-44 pump station site is located in an area where two existing pump stations occur. The existing site is unpaved and slopes gently to the northeast(although in general,the area slopes to the north). The site is situated at an approximate elevation of 250 feet above mean sea level and is located approximately 0.5-mile north of the San Joaquin Reservoir . No storm drain system exists on-site, and the site is drained via surface flow to the northeast. Coastal Junction Booster Pump Station ' The Coastal Junction pump station site is proposed for location in a church parking lot within the City of Irvine. The site exists as a flat, paved area, at an approximate elevation of 50 feet above mean sea level. The site vicinity generally slopes gently to the west. The site vicinity can be characterized as developed/urbanized. The San Diego Creek,a major drainage facility for the region, is situated adjacent to the church parking lot to the north. The existing site is served by an on-site storm water drainage system. LAWS, ORDINANCES, REGULATIONS AND STANDARDS iThe proposed project must satisfy the requirements of several federal and state regulatory agencies, most notably, the following: ❖ The Orange County Third Term NPDES Municipal Storm Water Permit(administered by the Santa Ana Regional Water Quality Control Board [SARWQCB]); ❖ California's Nonpoint Source (NPS) Pollution Control Program (administered by the State Water Resources Control Board [SWRCB]); and ❖ The National Pollutant Discharge Elimination System (NPDES) General Permit for Storm Water Discharges Associated with Construction Activity(administered by the SWRCB,and discussed further in Section 5.9, CONSTRUCTION RELATED IMPACTS). FEDERAL PROGRAMS The Environmental Protection Agency (EPA) is the primary federal agency responsible for management of water quality in the United States. The Clean Water Act(CWA)is the federal law that governs water quality control activities initiated by the EPA and others. Section 303 of the CWA requires the adoption of water quality standards for all surface water in the United States. Under Section 303(d), states are required to develop lists of water bodies that do not meet water quality objectives after required levels of treatment by point source dischargers. Total Maximum Daily Loads(TMDLs)for all pollutants for which these water bodies are listed must be developed in order to bring them into compliance with water quality objectives. In 1972, provisions of the CWA, were amended so that discharge of pollutants to waters of the United States from any point source is effectively prohibited, unless the discharge is in compliance with a NPDES permit. The 1987 amendments to the CWA added Section 402(p),which established a framework for regulating municipal, industrial,and construction stormwater discharges under the NPDES program. On November 16, 1990, USEPA published final regulations that established 1 application requirements for stormwater permits for municipal separate storm sewer systems(MS4s) serving a population of over 100,000 (Phase 1 communities) and certain industrial facilities, including construction sites greater than five acres. On December 8, 1999, USEPA published the final regulations for communities under 100,000(Phase II MS4s)and operators of construction sites between one and five acres. City of Huntington Beach April 5, 2005 5.3-3 Seawater Desalination Project at Huntington Beach 5.3 HYDROLOGY,DRAINAGE, Draft Recirculated Environmental Impact Report AND STORM WATER RUNOFF STATE PROGRAMS The State Porter-Cologne Act(Water Code 13000,et seq.)is the principal legislation for controlling stormwater pollutants in California. The act requires development of Basin Plans for drainage basins within California. Each plan serves as a blueprint for protecting water quality within the various watersheds. These basin plans are used in turn to identify more specific controls for discharges(e.g.,wastewater treatment plant effluent,urban runoff,and agriculture drainage). Under Porter-Cologne, specific controls are implemented through permits called Waste Discharge Requirements issued by the nine Regional Water Quality Control Boards. For discharges to surface waters, the Waste Discharge Requirements also serve as NPDES permits. NPS pollution, also known as polluted runoff, is the leading cause of water quality impairments in California. Section 319 of the CWA requires that each state prepare and submit a report that "identifies those navigable waters within the State which, without additional action to control nonpoint sources of pollution,cannot reasonably be expected to attain or maintain applicable water quality standards." In orderto complywith this directive,the California State Water Resources Control Board(SWRCB) adopted California's NPS Control Program (NPS Program) in 1988. The NPS Program was updated in January of 2000 to the Plan for California's Nonpoint Source Pollution Control Program , (Program Plan). The chief way in which the Plan fulfills the requirement of CWA Section 319 is through the implementation of management measures(MMs). MMs serve as general goals for the control and prevention of nonpoint source pollution. The project site is included within the Water Quality Control Plan for the Santa Ana River Basin(also known as the Santa Ana River Basin Plan). This Basin Plan identifies specific controls for discharges as well as implementation standards to achieve such controls. The proposed project would be subject to all applicable rules and regulations contained within the Water Quality Control Plan for the Santa Ana River Basin. LOCAL PROGRAMS Since 1990, the City of Huntington Beach has cooperated with other Orange County cities (the "permittees") in complying with the NPDES permits issued by the SARWQCB. The result of this cooperation has been the development of numerous common stormwater programs that have been integrated in the area-wide Drainage Area Management Plan (DAMP). As a result of the NPDES permits issued in early 2002 (Third Term Permits),the DAMP underwent significant changes and restructuring as part of the formation of the 2003 DAMP. The 2003 DAMP contains model program guidance that was developed through a collaborative effort among all permittees,as well as interested agencies,organizations,and the public. The 2003 DAMP requires that each permittee,including the City,prepare a Local Implementation Plan(LIP)as an Appendix to the 2003 DAMP. The City's LIP describes the activities that the City has previously undertaken and is currently undertaking to meet the requirements of the Third Term Permits and to make meaningful improvements in urban water quality. The LIP is intended to serve as the basis for City compliance during the five-year period of the Third Term Permit. The 2003 DAMP requires the implementation of site design, source control and treatment control BMPs. The enforcement mechanism for the DAMP are the Waste Discharge Requirements for Discharges of Urban Runoff from the Municipal Separate Storm Sewer Systems(MS4)Draining the Watersheds of Orange County, the Incorporated Cities of Orange County,and the Orange County Flood Control District within the Santa Ana Region. The permit is also generally known as the SARWQCB Municipal NPDES Permit No. CAS618030. City of Huntington Beach April 5, 2005 5.3-4 ' Seawater Desalination Project at Huntington Beach 5.3 HYDROLOGY, DRAINAGE, Draft Recirculated Environmental Impact Report AND STORM WATER RUNOFF i IMPACTS Significance Criteria Under the CEQA Guidelines a project may be considered to have a significant environmental effect if it will: ❖ Violate any water quality standards or waste discharge requirements. ❖ Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level(e.g.,the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted). •S Substantially alter the existing drainage pattern of the site or area,including through the alteration of the course of a stream or river, in a manner, which would result in substantial erosion or siltation on-or off-site. ❖ Substantially alter the existing drainage pattern of the site or area,including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner,which would result in flooding on-or off-site. ❖ Create or contribute runoff water which would exceed the capacity of existing or planned storm water drainage systems or provide substantial additional sources of polluted runoff. ❖ Otherwise substantially degrade water quality. ❖ Place within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map. ❖ Place within a 100-year flood hazard area structures,which would impede or redirect flood flows. ❖ Expose people or structures to a significant risk of loss, injury or death involving flooding, including flooding as a result of the failure of a levee or dam. ❖ Inundation by seiche, tsunami, or mudflow. Impacts in regards to long-term hydrology,drainage,and storm water quality are discussed below. As the proposed off-site pipeline alignment and underground pump station would be subsurface, there are no anticipated long-term impacts in regards to hydrology,drainage,and/or water quality.A discussion of short-term construction-related impacts in regards to hydrology and water quality is included in Section 5.9, CONSTRUCTION RELATED IMPACTS. LONG-TERM WATER QUALITY IMPACTS Proposed Desalination Facility Site 1 Fertilizers and Pesticides It is anticipated that the proposed desalination project would incorporate both native and non-native landscaping on-site. Non-native vegetation may require periodic fertilization and pest control. The use of fertilizers and pesticides would comply with City standards as well as the guidelines set forth in the Orange County Management Guidelines for such activities. Based on the size of the landscaped areas,the small amounts of fertilizers and pesticides needed,and the fact that the site landscape would be maintained per local and County standards, it is unlikely that use of these chemicals would be of environmental concern to the groundwater, adjacent ocean waters, or City of Huntington Beach April 5, 2005 5.3-5 Seawater Desalination Project at Huntington Beach 5.3 HYDROLOGY, DRAINAGE, Draft Recirculated Environmental Impact Report AND STORM WATER RUNOFF surrounding uses. Therefore,this is not considered a significant impact. However,a Water Quality Management Plan (WQMP) would be prepared for the proposed project, which would identify applicable Best Management Practices (BMPs) and control measures as identified within the Countywide National Pollution Discharge Elimination System(NPDES)Drainage Area Management Plan (DAMP). Flooding The proposed project is currently designated with a Federal Emergency Management Agency (FEMA)flood zone designation of'X." However, the City's Local Coastal Program designates the project site as being situated within an area prone to"Flooding with Wave Action". In addition, the open space/wetland area to the southeast of the subject site routinely stores runoff,resulting in high water levels during storm events,which could potentially impact the site. Appropriate hydrology and hydraulic analysis would be performed to determine if the site has adequate drainage. Storm Water Drainage The proposed grading activities and development of the proposed project site are anticipated to increase the amount of impervious area, thereby increasing surface runoff. In addition, existing containment berms(which contain storm water on-site)along the western and southern boundaries of the subject site would be removed (berms to the north of the subject site and along the eastern border of the site would remain in place). An on-site local storm water drainage system would be implemented as part of the desalination facility site and product water storage tank. The desalination site would be divided into two areas (north and south),with catch basins and a storm water pump station located in each area. Storm water flows would first be directed to catch basins by gravity,and would then be directed to a storm water pump via gravity lines. The water would then be pumped to the 48-inch by-product concentrated seawater discharge line that ultimately connects to the AES Huntington Beach Generating Station (HBGS)outfall line. Aboveground product water tank implementation would include an on-site storm water system,which would direct storm waterto the desalination facility's storm water system. In addition, containment berms surrounding the western and northern side of the West tank site would be left in place,further containing storm water on-site. As alternative options,the desalination facility's on-site storm water system could discharge storm water to the HBGS on-site storm water system or the City of Huntington Beach local storm water system, both of which ultimately convey storm water to the Pacific Ocean via the HBGS outfall. No storm water would be discharged into the adjacent Huntington Beach Channel. A Water Quality Management Plan (WQMP)would be completed for the proposed project as required by the Regional Water Quality Control Board (RWQCB). If necessary, storm water would be treated prior to off-site discharge in order to minimize impacts from urban pollutants. One of two sedimentation methods would be utilized for treatment,including: ❖ Waste Filter Backwash Clarifiers: The proposed desalination project facility would utilize clarifiers for the purpose of settling the waste stream generated during the backwash of the pretreatment filters. During rainy events, storm water would be combined with the waste filter backwash water and settled in the filter backwash clarifiers. This clarified water would then be combined with the desalination facility's concentrated seawater discharge and sent to the Pacific Ocean via the HBGS outfall. The waste filter backwash clarifiers would be oversized to accommodate the treatment of storm water. ❖ Sedimentation in Separate Clarifiers: As an alternative to combining on-site storm water with the waste filter backwash,storm water directed to on-site storm drains could be treated in separate sedimentation clarifiers for storm water treatment only. City of Huntington Beach April 5, 2005 5.3-6 Seawater Desalination Project at Huntington Beach 5.3 HYDROLOGY, DRAINAGE, Draft Recirculated Environmental Impact Report AND STORM WATER RUNOFF Subsequent to clarification, this water would be discharged via the HBGS outfall with the desalination facility's concentrated seawater discharge and HBGS cooling water. The most viable storm water treatment alternative would be selected during the design phase of the project, in close coordination with the City of Huntington Beach, RWQCB, and HBGS staff. The storm water facilities would be designed to comply with all applicable requirements of the City of Huntington Beach and the RWQCB. In addition, stormwater runoff would not affect adjacent sensitive land uses. Although the project site is situated directly adjacent to a wetland area (southeast of the site), the subject site would be graded so that all on-site stormwater would flow away from the wetland area towards an on-site local stormwater drainage system. The on-site local stormwater drainage system that would be implemented as part of the proposed project would not have surface runoff discharge onto Pacific Coast Highway. The existing containment berms along the western and southern boundaries of the subject site would remain, providing additional containment of any stormwater to the project site. The proposed project would also incorporate applicable Best Management Practices (BMPs) in order to contain stormwater runoff, which may contain urban pollutants such as petroleum by- products, trash/grease, pathogens, and pollutants that may occur in association with proposed desalination project operation. The project would be in compliance with all standards as administered by the State Water Resources Control Board and County of Orange. Water Quality Impacts to Nearby Coastal Wetlands from On-Site Spillage The existing containment berm along the eastern border of the subject site(to be left in place)would prevent direct spillage of product or by-product water onto the portion of wetlands situated to the east. In the event of an accidental spill associated with proposed project operation of either product or by-product water, no significant effects would occur on the adjacent wetland/open space area or the Huntington Beach Channel because water would not pass the physical separation. Soils of wetlands are already flooded by freshwater during the rainy season, forming standing pools. Product water spills would do the same. Soils are already hypersaline,so spills of by-product water would contribute little to the salinity of soils. Spills into the local Huntington Beach Channel are also likely to have minimal impact. The channel already has multiple year-round fresh water inputs, so product water spills would have no impact. By-product water spills would be diluted by these fresh water inputs. However, if the channel is mostly oceanic at the time of a spill,salinities may be overly elevated. Species likely to be found in the channel,such as topsmelt,can tolerate wide variations in salinity. In addition, the desalination facility would incorporate appropriate leak/spill containment measures to minimize the likelihood for hazardous materials being stored,used,and transported on- site from impacting adjacent uses (refer to Section 5.8, HAZARDS AND HAZARDOUS MATERIALS, for a detailed discussion). Impacts in this regard are anticipated to be less than significant. It should be noted that the Huntington Beach Wetlands Conservancy has proposed a Restoration Plan for several wetland areas both adjacent to and downstream of the proposed subject site. As stated above, significant impacts to these wetlands are not anticipated to occur as a result of an accidental spill of product or by-product water from the proposed desalination project. MITIGATION MEASURES LONG-TERM WATER QUALITY IMPACTS HWQ-1 Prior to issuance of a precise grading permit, the applicant shall submit and obtain approval from the City of Huntington Beach of a Water Quality Management Plan(WQMP) specifically identifying Best Management Practices (BMPs)that would be used on-site to ' City of Huntington Beach April 5, 2005 5.3-7 Seawater Desalination Project at Huntington Beach 5.3 HYDROLOGY,DRAINAGE, Draft Recirculated Environmental Impact Report AND STORM WATER RUNOFF control predictable pollutant runoff. This WQMP shall identify, at a minimum,the routine, structural and non-structural measures specified in the Countywide NPDES Drainage Area Management Plan (DAMP)Appendix which details implementation of the BMPs whenever r they are applicable to a project,the assignment of long-term maintenance responsibilities to the applicant, and shall reference the location(s) of structural BMPs. The applicable BMPs include: ❖ Facility materials that require fertilization and pest control shall be maintained in accordance with Orange County Management Guidelines for Use of Fertilizers and Pesticides. ❖ BMP structures and facilities shall be cleaned and maintained on a scheduled basis by a Facility Operator appointed person. HWQ-2 Appropriate site specific hydrology and hydraulic analysis would be performed for the project prior to the issuance of grading or building permits, which ever comes first. The analysis shall include mitigation measures, if necessary, in regards to storm water drainage and flooding. HWQ-3 Prior to the issuance of building permits(not including demolition permits)an appropriate on-site drainage system shall be installed for the project that integrates permanent stormwater quality features. UNAVOIDABLE SIGNIFICANT IMPACTS None have been identified. City of Huntington Beach April 5, 2005 5.3-8 5.4 AIR QUALITY Information in this section is based primarily upon the CEQA Air QualityHandbook, (South CoastAir Quality Management District[SCAQMD]),Air Quality Data(California Air Resources Board(CARB], 2000 through 2004), the City of Huntington Beach General Plan (1996) and General Plan Environmental Impact Report(1995)and the SCAQMD Final Air Quality Management Plan(August 2003). This section focuses on potential long-term local and regional air quality impacts associated with the proposed desalination project. Section 5.9, CONSTRUCTION RELATED IMPACTS, analyzes potential short-term air quality impacts associated with construction activity for the proposed project. Note: Potential air quality impacts of the proposed project have remained consistent with those described in the previously circulated EIR(2002). However,due to changes in regulatory standards since 2002, information has been added to this section to better describe the regulatory framework in the State and air basin, as well as additional impact analysis to demonstrate compliance with existing requirements. EXISTING CONDITIONS The proposed project is located within the South Coast Air Basin (SCAB). The SCAB is characterized as having a"Mediterranean"climate(a semi-arid environment with mild winters,warm summers and moderate rainfall). The SCAB is a 6,600-square mile area bounded by the Pacific Ocean to the west and the San Gabriel, San Bernardino and San Jacinto Mountains to the north and east. The SCAB includes all of Orange County and the non-desert portions of Los Angeles, Riverside and San Bernardino Counties. Additionally, the SCAQMD jurisdiction includes the San Gorgonio Pass area of Riverside County. The general region lies in the semi-permanent, high-pressure zone of the eastern Pacific. As a result,the climate is mild and tempered by cool sea breezes. The usually mild climatological pattern is interrupted infrequently by periods of extremely hot weather,winter storms, or Santa Ana winds. The extent and severity of the air pollution problem in the SCAB is a function of the area's natural ' physical characteristics(weather and topography),as well as man-made influences (development patterns and lifestyle). Factors such as wind, sunlight, temperature, humidity, rainfall and topography all affect the accumulation and/or dispersion of pollutants throughout the SCAB. CLIMATE Moderate temperatures, comfortable humidity and limited precipitation characterize the climate in the SCAB. The average annual temperature varies little throughout the SCAB, averaging 75 degrees Fahrenheit. However, with a less pronounced oceanic influence, the eastern inland portions of the SCAB show greater variability in annual minimum and maximum temperatures. All portions of the SCAB have had recorded temperatures over 100 degrees in recent years. January is usually the coldest month at all locations while July and August are usually the hottest months of the year. Although the SCAB has a semi-arid climate,the air near the surface is moist because of the presence of a shallow marine layer. Except for infrequent periods when dry air is brought into the SCAB by offshore winds,the ocean effect is dominant. Periods with heavy fog are frequent;and low stratus clouds, occasionally referred to as "high fog" are a characteristic climate feature. Annual average relative humidity is 70 percent at the coast and 57 percent in the eastern part of the SCAB. Precipitation in the SCAB is typically 9 to 14 inches annually and is rarely in the form of snow or hail due to typically warm weather. The frequency and amount of rainfall is greater in the coastal areas of the SCAB. More specifically, the City of Huntington Beach enjoys a mild climate. The greatest precipitation in the City occurs in January with a rainfall of 3.0 inches. The coolest month of the year ' City of Huntington Beach April 5, 2005 5.4-1 Seawater Desalination Project at Huntington Beach 5.4 AIR QUALITY Draft Recirculated Environmental Impact Report is December with an average low of 40°F. The warmest month is August with an average high of 85°F.' SUNLIGHT The presence and intensity of sunlight are necessary prerequisites for the formation of photochemical smog. Under the influence of the ultraviolet radiation of sunlight, certain original,or "primary'pollutants(mainly reactive hydrocarbons and oxides of nitrogen)react to form"secondary" pollutants (primarily oxidants). Since this process is time dependent, secondary pollutants can be formed many miles downwind from the emission sources. Due to the prevailing daytime winds and time-delayed nature of photochemical smog,oxidant concentrations are highest in the inland areas of Southern California. TEMPERATURE INVERSIONS Under ideal meteorological conditions and irrespective of topography, pollutants emitted into the air would be mixed and dispersed into the upper atmosphere. However,the Southern California region frequently experiences temperature inversions in which pollutants are trapped and accumulate close to the ground. The inversion, a layer of warm, dry air overlaying cool, moist marine air, is a normal condition in the southland. The cool, damp and hazy sea air capped by coastal clouds is heavier than the warm, clear air that acts as a lid through which the marine layer cannot rise. The height of the inversion is important in determining pollutant concentration. When the inversion is approximately 2,500 feet above sea level,the sea breezes carry the pollutants inland to escape over the mountain slopes or through the passes. At a height of 1,200 feet, the terrain prevents the pollutants from entering the upper atmosphere, resulting in a settlement in the foothill communities. Below 1,200 feet, the inversion puts a tight lid on pollutants, concentrating them in a shallow layer over the entire coastal basin. Usually, inversions are lower before sunrise than during the daylight hours. Mixing heights for inversions are lower in the summer and more persistent, being partly responsible for the high levels of ozone observed during summer months in the SCAB. Smog in Southern California is generally the result of these temperature inversions combining with coastal day winds and local mountains to contain the pollutants for long periods of time, allowing them to form secondary pollutants by reacting with sunlight. The SCAB has a limited ability to disperse these pollutants due to typically low wind speeds. The area in which the City of Huntington Beach is located offers clear skies and sunshine,however, it is still susceptible to air inversions. This traps a layer of stagnant air near the ground where it is further loaded with pollutants. These inversions cause haziness, which is caused by moisture, suspended dust, and a variety of chemical aerosols emitted by trucks, automobiles, furnaces and other sources. GLOBAL CLIMATE CHANGE California is a substantial contributor of global greenhouse gasses emitting over 400 million tons of CO2 a year. Climate studies indicate that California is likely to see an increase of three to four degrees Fahrenheit over the next century.2 Methane is also an important greenhouse gas that potentially contributes to global climate change. Greenhouse gases are global in their effect,which is to increase the earth's ability to absorb heat in the atmosphere. Because primary greenhouse gases have a long lifetime in the atmosphere,accumulate over time, and are generally well mixed; their impact on the atmosphere is mostly independent of the point of emission. ' Weather Channel,www.weather.com, November 11,2004. 2 Union of Concerned Scientists and the Ecological Society of America, Confronting Climate Change in California, 1999. City of Huntington Beach April 5, 2005 5.4-2 Seawater Desalination Project at Huntington Beach 5.4 AIR QUALITY Draft Recirculated Environmental Impact Report In 1988,the United Nations established the Intergovernmental Panel on Climate Change to evaluate the impacts of global warming and to develop strategies that nations could implement to curtail global climate change. In 1992,the United States joined other countries around the world in signing the United Nations' Framework Convention on Climate Change agreement with the goal of controlling greenhouse gas emissions, including methane. As a result,the Climate Change Action Plan was developed to address the reduction of greenhouse gases in the United States. The plan ' consists of more than 50 voluntary programs. Additionally, the Montreal Protocol was originally signed in 1987 and substantially amended in 1990 and 1992.The Montreal Protocol stipulates that the production and consumption of compounds that deplete ozone in the stratosphere (i.e. ' chlorofluorocarbons[CFCs],halons,carbon tetrachloride,and methyl chloroform)were to be phased out by 2000.3 SENSITIVE RECEPTORS Sensitive populations (sensitive receptors)are more susceptible to the effects of air pollution than the general population. Sensitive populations who are in proximity to localized sources of toxins and CO are of particular concern. Land uses considered sensitive receptors include residences, schools, playgrounds, childcare centers, athletic facilities, long-term health care facilities, rehabilitation centers,convalescent centers,and retirement homes. Existing sensitive receptors are ' not located within the proposed desalination facility site; however, residential, recreational, and educational uses exist within the vicinity of the project site, and adjacent to the proposed pipeline routes and underground pump stations. It should be noted that an animal shelter and the Wildlife Care Center of Orange County are situated near the project site (along the northern side of Edison Avenue and the northern side of Pacific Coast Highway, respectively), but are not considered sensitive receptors.4 LAWS, ORDINANCES, REGULATIONS AND STANDARDS Regulatory oversight for air quality in the SCAB rests at the regional level with the South Coast Air Quality Management District(SCAQMD), the California Air Resources Board (CARB)at the State level, and the U.S. Environmental Protection Agency (EPA) Region IX office at the Federal level. Laws, ordinances, regulations, and standards applicable to these three agencies are described below. U.S. ENVIRONMENTAL PROTECTION AGENCY The principal air quality regulatory mechanism on the federal level is the Federal Clean Air Act (FCAA) and in particular the 1990 amendments to the Federal Clean Air Act (FCAAA) and the National Ambient Air Quality Standards(NAAQS)that it establishes. These standards identify levels of air quality for"criteria"pollutants that are considered the maximum levels of ambient(background) air pollutants considered safe, with an adequate margin of safety, to protect the public health and welfare. The criteria pollutants include ozone(03), carbon monoxide(CO), nitrogen dioxide(NO2 is a form of NOX),sulfur oxides(S02 is a form of SOX),particulate matter less than 10 and 2.5 microns in diameter (PM10 and PM2.5, respectively) and lead (Pb) (refer to Table 5.4-1, NATIONAL AND 1 CALIFORNIA AMBIENT AIR QUALITY STANDARDS). The EPA also has regulatory and enforcement jurisdiction over emission sources beyond state waters (outer continental shelf), and those that are under the exclusive authority of the Federal government, such as aircraft, locomotives, and interstate trucking. 3 Methyl chloroform is not slated to be phased out until 2005. 4 Mike Krause,South Coast Air Quality Management District, May 8,2002. ' City of Huntington Beach April 5, 2005 5.4-3 Seawater Desalination Project at Huntington Beach 5.4 AIR QUALITY Draft Recirculated Environmental Impact Report Table 5.4-1 NATIONAL AND CALIFORNIA AMBIENT AIR QUALITY STANDARDS Pollutant Averaging Time California Standards i Federal Standards2 Concentration 3 Primary 3.4 Secondag 3,5 Ozone(03) 1 Hour 0.09 ppm 180 /m 0.12 m 235 /m3 0.12 m 235 /m3 8 Hour N/A 0.08 ppm 157 /m3 0.08 ppm 157 /m3 Particulate Matter 24 Hour 50 /m3 150 /m3 150 /m3 PMio Annual Arithmetic Mean 20 µg/m3 50 µg/m3 50 µg/m3 Fine Particulate Matter 24 Hour No Separate State Standard 65 /m3 65 /m3 PM2.a Annual Arithmetic Mean 12 µg/m3 15 µg/m3 15 µg/m3 Carbon Monoxide 8 Hour 9.0 ppM 10 m /m3 9 ppM 10 m /m3 9 ppM 10 m /m3 CO 1 Hour 20 ppm(23 mg/m3) 35 ppm(40 mg/m3) 35 ppm(40 mg/m3) Nitrogen Dioxide Annual Arithmetic Mean N/A 0.053 ppm(100 µg/m3) 0.053 ppm(100 (NO2) /m3 1 Hour 0.25 ppm 470 /m3 N/A N/A Lead 30 days average 1.5 /m3 N/A N/A Calendar Quarter N/A 1.5 /m3 1.5 /m3 Annual Arithmetic Mean N/A 0.030 ppm 80 /m3 N/A Sulfur Dioxide(S02) 24 Hour 0.04 ppm 105 /m3 0.14 ppm 365 /m3 N/A _. 3 Hour N/A N/A 0.5 ppm 1300 /m3 1 Hour 0,25 ppm 655 /m3 N/A N/A Visibility Reducing 8 Hour(10 am to 6 pm, Extinction Coeff.=0.23 No Particles PST) km@<70%RH Sulfates 24 Hour 25 µg/m3 Federal Hydrogen Sulfide 1 Hour 0.03 ppm(42 µg/m3) Standards Notes: 1. California standards for ozone,carbon monoxide(except Lake Tahoe),sulfur dioxide(1 and 24 hour),nitrogen dioxide,suspended particulate matter-PMio,and visibility reducing particles,are values that are not to be exceeded. All others are not to be equaled or exceeded. California ambient air quality standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations, In 1990,the CARB identified vinyl chloride as a Toxic Air Contaminant and determined that there was not sufficient available scientific evidence to support the identification of a threshold exposure level.This action allows the implementation of health-protective control measures at levels below the 0.010 ppm ambient concentration specified in the 1978 standard. 2. National standards(other than ozone,particulate matter,and those based on annual averages or annual arithmetic mean)are not to be exceeded more than once a year. EPA also may designate an area as attainment/unclassifiable,if it has:1)monitored air quality data that show that an area has not violated the ozone standard over a three-year period;or if 2)there is not enough information to determine the air quality in the area.For PM1o,the 24-hour standard is attained when 99 percent of the daily concentrations,averaged over the three years, are equal to or less than the standard. For PM2,5, the 24-hour standard is attained when 98 percent of the daily concentrations,averaged over three years,are equal to or less than the standard. Contact the EPA for further clarification and current federal policies. 3. Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based upon a reference temperature of 250C and a reference pressure of 760 mm of mercury. Most measurements of air quality are to be corrected to a reference temperature of 250C and a reference pressure of 760 mm of mercury(1,013.2 millibar);ppm in this table refers to ppm by volume,or micromoles of pollutant per mole of gas, 4. National Primary Standards:The levels of air quality necessary,with an adequate margin of safety to protect the public health. 5. National Secondary Standards:The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant. 6. N/A=Not Applicable Source: California Air Resources Board,November 2004. CALIFORNIA AIR RESOURCES BOARD The California Air Resources Board, (CARB), a department of the California Environmental Protection Agency (CalEPA), oversees air quality planning and control throughout California. Its responsibility lies with ensuring implementation of the 1989 amendments to the California Clean Air Act (CCAA), responding to the FCAA requirements and regulating emissions from motor vehicles sold in California. It also sets fuel specifications to further reduce vehicular emissions. City of Huntington Beach April 5, 2005 5.4-4 ' Seawater Desalination Project at Huntington Beach 5.4 AIR QUALITY Draft Recirculated Environmental Impact Report h amendments AA The ame ments to the CC establish California Ambient Air Quality Standards(CAAQS),and a legal mandate to achieve these standards by the earliest practicable date. These standards apply to the same criteria pollutants as the Federal CAA,and also include sulfate,visibility,hydrogen sulfide, and vinyl chloride (refer to Table 5.4-1). SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT(SCAQMD) The SCAQMD is one out of 35 air quality management districts that have prepared Air Quality Management Plans(AQMPs)to accomplish a five percent annual reduction in emissions. The most recent AQMP was adopted in 2003. The 2003 AQMP relies on a multi-level partnership of governmental agencies at the federal, state, regional and local level. The 2003 AQMP proposes policies and measures to achieve federal and state standards for improved air quality in the SCAB and those portions of the Salton Sea Air Basin(formerly named the Southeast Desert Air Basin)that are under SCAQMD jurisdiction. The 2003 AQMP also addresses several state and federal planning requirements and incorporates significant new scientific data, primarily in the form of updated emissions inventories, ambient measurements, new meteorological episodes and new air quality modeling tools. The 2003 AQMP is consistent with and builds upon the approaches taken in the 1997 AQMP and the 1999 . Amendments to the Ozone State Implementation Plan (SIP)for the SCAB for the attainment of the federal ozone air quality standard. However, the 2003 AQMP points to the urgent need for ' additional emission reductions(beyond those incorporated in the 1997199 Plan)to offset increased emission estimates from mobile sources and meet all federal criteria pollutant standards within the time frames allowed under the FCAA. SCAG is responsible under the FCAA for determining conformity of projects, plans and programs with the SCAQMD AQMP. As indicated in the SCAQMD CEQA Air Quality Handbook,there are two main indicators of consistency: ❖ Whether the project would not result in an increase in the frequency or severity of existing air quality violations or cause or contribute to new violations, or delay timely attainment of air quality standards or the interim emission reductions specified in the AQMP; and ❖ Whether the project would exceed the AQMP's assumptions for 2020 or increments based on the year of project build-out and phase. Applicable Rules and Regulations The following rules and regulations listed in Table 5.4-2, SCAQMD RULES AND REGULATIONS, would be applicable to the proposed project:5 ' 5 Telephone Conversation with Charles Blankson,South Coast Air Quality Management District, November 23, 2004. ' City of Huntington Beach April 5, 2005 5.4-5 Seawater Desalination Project at Huntington Beach 5.4 AIR QUALITY Draft Recirculated Environmental Impact Report Table 5.4-2 SCAQMD RULES AND REGULATIONS Rules/Regulations Description Regulation IX-Standards for Regulation IX incorporates, by reference, the provisions of Part 60, Performance for New Chapter 1, Title 40 of the Code of Federal Regulations. It requires Stationary Sources(NSPS) compliance with federal Standards of Performance for Industrial- Commercial-Institutional Steam Generating Units. This regulation sets pre-construction review requirements for new, modified, or relocated facilities, to ensure that the operation of such facilities does not interfere with progress in attainment of the national ambient air quality standards,and that future economic growth within Regulation All-New Source the SCAQMD is not unnecessarily restricted. The specific air quality Review goal of this regulation is to achieve no net increases from new or modified permitted sources of nonattainment air contaminants or their precursors. In addition to nonattainment air contaminants, this regulation will also limit emission increases of ammonia, and Ozone Depleting Compounds(ODCs)from new,modified or relocated facilities by requiring the use of Best Available Control Technology BACT. Regulation XIV includes rules that regulate Toxics and other Non- Regulation XIV,Rule -Toxics Criteria Pollutants. It provides specifications for maximum individual and Other Non-Criteria cancer risk(MICR),cancer burden,and non-cancer acute and chronic Pollutants hazard index(HI)from new permit units,relocations,or modifications to existing permit units, which emit toxic air contaminants. The rules establish allowable risks for permit units requiring new permits pursuant to Rules 201 or 203. RECLAIM is a market incentive program designed to allow facilities flexibility in achieving emission reduction requirements for Oxides of Regulation XX-Regional Clean Nitrogen (NOx), and Oxides of Sulfur (SOx) under the Air Quality Air Incentive Market(RECLAIM) Management Plan using methods which include,but are not limited to: add-on controls, equipment modifications, reformulated products, operational changes,shutdowns,and the purchase of excess emission reductions. Rule 201 establishes an orderly procedure for the review of new and Rule 201 -Permit to modified sources of air pollution through the issuance of permits.Rule Construction 201 specifies that any facility installing nonexempt equipment that causes or controls the emissions of air pollutant must first obtain a permit to construct from the SCAQMD. Establishes limit for visible emissions from stationary sources.This rule Rule 401 -Visible Emissions prohibits visible emissions as dark or darker than Ringlemann No.1 for eriods reater than three minutes in any hour. Prohibits the discharge from a facility of air pollutants that cause injury, Rule 402-Nuisance detriment, nuisance, or annoyance to the public or that damage business or pro pert . Source:South Coast Air Quality Management District,www.aamd.g_ov,November 30,2004. Note that Regulation XIV,Rule 201,Rule 401 and Rule 402 also apply to construction emissions. ATTAINMENT STATUS The SCAB has been designated as attainment for nitrogen dioxide(NOX)and sulfur oxides(SOX)for - both State and Federal Standards. The SCAB is designated non-attainment for ozone (03) and City of Huntington Beach April 5, 2005 5.4-6 ' Seawater Desalination Project at Huntington Beach 5.4 AIR QUALITY Draft Recirculated Environmental Impact Report particulate matter (PM10) under both Federal and State standards (refer to Table 5.4-3, SOUTH COAST AIR BASIN AMBIENT AIR QUALITY CLASSIFICATIONS). ' Table 5.4-3 SOUTH COAST AIR BASIN AMBIENT AIR QUALITY CLASSIFICATIONS Pollutant State _' federal Carbon Monoxide Non-Attainment Attainment Ozone 1 hour standard Non-Attainment/Severe Non-Attainment/Severe Ozone 8 hour standard Unclassified Unclassified Nitrogen Oxides Attainment Attainment Sulfur Dioxide Attainment Attainment ' Particulate Matter<10 microns Serious Non-Attainment Serious Non-Attainment Source:Telephone conversation with Charles Blankson,South Coast Air Quality Management District,November 2004. LOCAL AMBIENT AIR QUALITY The project area's local ambient air quality is monitored by the SCAQMD and CARB. CARB monitors ambient air quality at approximately 250 air monitoring stations across the state. Air quality monitoring stations usually measure pollutant concentrations ten feet above ground level;therefore, air quality is often referred to in terms of ground-level concentrations. The Costa Mesa Monitoring Station, located along Mesa Verde Drive, is the nearest air monitoring station to the project area. The data collected at this Station are considered to be representative of the air quality experienced in the project vicinity. Air quality data from 2000 to 2004 for the Costa Mesa Monitoring Station are provided in Table 5.4-4, LOCAL AIR QUALITY LEVELS. As PM10 and PM2.5 levels were not ' monitored at the Costa Mesa station, measurements were taken from the Anaheim — Harbor Boulevard and the Anaheim — Pampas Lane monitoring stations. The following air quality information briefly describes the various types of pollutants. ' Ozone Ozone occurs in two layers of the atmosphere. The layer surrounding the earth's surface is the 1 troposphere.The troposphere extends approximately 10 miles above ground level,where it meets the second layer, the stratosphere. The stratospheric or"good" ozone layer extends upward from about 10 to 30 miles and protects life on earth from the sun's harmful ultraviolet rays (UV-B). i "Bad" ozone is what is known as a photochemical pollutant, and needs VOC, NO,, and sunlight to form. VOC and NO, are emitted from various sources throughout the county. In order to reduce ozone concentrations, it is necessary to control the emissions of these ozone precursors.Significant ozone formation generally requires an adequate amount of precursors in the atmosphere and several hours in a stable atmosphere with strong sunlight. High ozone concentrations can form over large regions when emissions from motor vehicles and stationary sources are carried hundreds of miles from their origins. While ozone in the upper atmosphere protects the earth from harmful ultraviolet radiation, high concentrations of ground level ozone can adversely affect the human respiratory system and other tissues. Many respiratory ailments, as well as cardiovascular disease,are aggravated by exposure to high ozone levels. Ozone also damages natural ecosystems such as forests and foothill communities,and damages agricultural crops and some man-made materials,such as rubber,paint, and plastics. Societal costs from ozone damage include increased medical costs,the loss of human and animal life, accelerated replacement of industrial equipment, and reduced crop yields. ' City of Huntington Beach April 5, 2005 5.4-7 Seawater Desalination Project at Huntington Beach 5.4 AIR QUALITY Draft Recirculated Environmental Impact Report The 03 State standard is 0.09 ppm,averaged over one hour. The eight-hour 03 levels at the Costa Mesa monitoring station range between 0.086 ppm in 2000 and 0.087 ppm in 2004. The one-hour State standard was exceeded eight days from 2000 to 2004. The Federal standard for 03 is 0.12 ppm, averaged over one hour. The Federal standard was not exceeded between 2000 and 2004. The SCAB is designated as a nonattainment area for State and Federal 03 standards. Table 5.4-4 LOCAL AIR QUALITY LEVELS California Federal Primary Maximum Days(Samples) Pollutant Year State/Federal Standard Standard Concentrations Standard Exceeded 20M 6.3 0/0 20014 4.7 0/0 foorr 8 hour for Carbon Monoxide ppm or9. ppm 8 hour 20024 4.3 010 20034 6.0 0/0 20044 3.1 0/0 20004 0.086 NA1 Ozone for 0.09 ppm 0.12 ppm 20014 0.073 NAO 8 hours (1 hour) (1 hour) 2002 0.070 NA/0 20034 0.088 NAM 20044 0.087 NAM 20004 0.1 1/0 NA 0.08 20014 0.1 1/0 Ozone for 1 hour (8 hour) (8 hour)m 20024 0.1 0/0 20034 0.1 4/0 20044 0.1 2/0 20004 0.1 0/0 0.25 ppm 0.053 ppm 20014 0.1 0/0 Nitrogen Dioxide 2002 0.1 0/0 for 1 hour annual average 20034 0.1 0/0 20044 0.1 0/0 20005 126.0 3/0 PM102,3 50 µg/m3 150 µ 20015 93.0 8/0g/m3 20026 69.0 510 for 24 hours for 24 hours 20036 96.0 6/0 20046 62.0 310 20005 113.9 NA/6 No Separate State 65 /m3 20015 55.0 NA/0 PMz.s3 Standard for 24 hours 20025 68.6 NAM 20035 115.5 NA/3 20045 52.9 NA/0 0.14 ppm for 24 20004 0.0 0/0 -. hours or 20014 0.0 010 Sulfur Dioxide 0.25 ppm for 1 hour 20024 0.0 0/0 0.03 ppm annual 20034 0.0 0/0 arithmetic mean 20044 0.0 0/0 PPM=Parts Per Million PM,o=particulate matter 10 microns in diameter or less µglm3=Micrograms Per Cubic Meter PM25=particulate matter 2.5 microns in diameter or less NM=Not Measured NA=Not applicable Notes: 1. Maximum concentration is measured over the same period as the California Standards. 2. PM,o exceedances are based on state thresholds established prior to amendments adopted on June 20,2002. 3. PM,o and PM2.5 exceedances are derived from the number of samples exceeded,not days. 4. The Costa Mesa monitoring station is located on 2850 Mesa Verde Dr East,Costa Mesa,California 92626. w 5. The Anaheim-Harbor Boulevard monitoring station is located on 1610 S Harbor Blvd,Anaheim,California 92802 6. The Anaheim-Pampas Lane monitoring station is located in Anaheim,California. Source:California Air Resources Board,ADAM Air Quality Data Summaries from 2000 to 2004 as found at http://www.arb.ca.aov/adam/ City of Huntington Beach April 5, 2005 5.4-8 ' Seawater Desalination Project at Huntington Beach 5.4 AIR QUALITY Draft Recirculated Environmental Impact Report Carbon Monoxide ' Carbon monoxide (CO) is emitted by mobile and stationary sources as a result of incomplete combustion of hydrocarbons or other carbon-based fuels.CO is an odorless,colorless toxic gas that is formed by the incomplete combustion of fuels. In cities, automobile exhaust can cause as much as 95% of all CO emissions. At high concentrations, CO can reduce the oxygen-carrying capacity ' of the blood and cause headaches, dizziness, unconsciousness, and even death. It is generally associated with areas of high traffic density. State and Federal standards were not exceeded between 2000 and 2004. The SCAB is designated as an attainment area for Federal CO standards and non-attainment for State standards. Nitrogen Dioxide Nitrogen oxides (NOJ are a family of highly reactive gases that are a primary precursor to the formation of ground-level ozone, and react in the atmosphere to form acid rain. NO2, often used ' interchangeably with NOx,is a reddish-brown gas that can cause breathing difficulties at high levels. Peak readings of NO2 occur in areas that have a high concentration of combustion sources (e.g., motor vehicle engines, power plants, refineries, and other industrial operations) in the vicinity. NOx can irritate the lungs, cause lung damage, and lower resistance to respiratory infections such as influenza. The effects of short-term exposure are still unclear, but continued or frequent exposure to concentrations that are typically much higher than those normally found in the ambient ' air may cause increased incidence of acute respiratory illness in children. Health effects associated with NOx are an increase in the incidence of chronic bronchitis and lung irritation.Chronic exposure to NO2 may lead to eye and mucus membrane aggravation, along with pulmonary dysfunction. State and Federal standards were not exceeded between 2000 and 2004. The SCAB is designated as an attainment area for State and Federal NO2 standards. ' Particulate Matter Particulate matter pollution consists of very small liquid and solid particles floating in the air. Some particles are large or dark enough to be seen as soot or smoke. Others are so small they can be detected only with an electron microscope. Particulate matter is a mixture of materials that can include smoke, soot, dust, salt, acids, and metals. Particulate matter also forms when gases emitted from motor vehicles and industrial sources undergo chemical reactions in the atmosphere. PM,o refers to particles less than or equal to 10 microns in aerodynamic diameter. PM2.5 refers to particles less than or equal to 2.5 microns in aerodynamic diameter and are a subset, or portion of ' PM110 PM,o and PM2.5 particles are small enough to be inhaled into,and lodge in,the deepest parts of the lung. Health problems begin as the body reacts to these foreign particles.Acute and chronic health effects associated with high particulate levels include the aggravation of chronic respiratory diseases, heart and lung disease,coughing, bronchitis and respiratory illnesses in children.Recent mortality studies have shown a statistically significant direct association between mortality and daily concentrations of particulate matter in the air. Non health-related effects include reduced visibility and soiling of buildings. The State standard for PM,o is 50 micrograms per cubic meter (µg/m3) averaged over 24 hours. The State standard was exceeded 25 days between 2000 and 2004. The Federal standard for PM,o is 150 µg/m3 averaged over 24 hours. The Federal standard for PM,o was not exceeded between 2000 and 2004. The SCAB is designated as a nonattainment area for State PM,o standards. Based upon a desire to set clean air goals throughout the State,the CARB created a new annual average ' City of Huntington Beach April 5, 2005 5.4-9 Seawater Desalination Project at Huntington Beach 5.4 AIR QUALITY Draft Recirculated Environmental Impact Report standard for PM2.5 at 12 µg/m3. Currently, the CARB has issued a staff report,which recommends that the SCAB be designated as nonattainment for State and Federal PM2.5 standards Sulfur Dioxide Sulfur dioxide is a colorless, pungent gas belonging to the family of sulfur oxide gases(SOx),formed primarily by combustion of sulfur-containing fossil fuels (primarily coal and oil), and during metal smelting and other industrial processes. Sulfur dioxide(S02)often used interchangeably with sulfur oxides (SOx) did not exceed Federal or State standards between 2000 and 2004. The SCAB is designated as an attainment area for both State and Federal S02 standards. The major health concerns associated with exposure to high concentrations of SOx include effects on breathing, respiratory illness, alterations in pulmonary defenses, and aggravation of existing cardiovascular disease. Major subgroups of the population that are most sensitive to SOX include individuals with cardiovascular disease or chronic lung disease(such as bronchitis or emphysema) as well as children and the elderly. Emissions of SOX also can damage the foliage of trees and agricultural crops. Together,SOX and NOx are the major precursors to acid rain,which is associated with the acidification of lakes and streams,and accelerated corrosion of buildings and monuments. Sulfur oxides can react to form sulfates, which significantly reduce visibility. Reactive Organic Gases and Volatile Organic Compounds Hydrocarbons are organic gases that are formed solely of hydrogen and carbon. There are several subsets of organic gases including Volatile Organic Compounds (VOCs) and Reactive Organic Gases (ROGs). ROGs include all hydrocarbons except those exempted by the California Air Resources Board (CARB). Therefore, ROGs are a set of organic gases based on state rules and regulations. VOCs are similar to ROGs in that they include all organic gases except those exempted by federal law. VOCs are therefore a set of organic gases based on federal rules and regulations. Both VOCs and ROGs are emitted from the incomplete combustion of hydrocarbons or other carbon-based fuels. Combustion engine exhaust,oil refineries,and oil-fueled power plants are the primary sources of hydrocarbons. Another source of hydrocarbons is evaporation from petroleum fuels, solvents, dry cleaning solutions and paint. The primary health effects of hydrocarbons result from the formation of ozone and its related health effects. High levels of hydrocarbons in the atmosphere can interfere with oxygen intake by reducing the amount of available oxygen through displacement. Carcinogenic forms of hydrocarbons are considered Toxic Air Contaminants,or air toxics.There are no health standards for ROG separately. Toxic Air Contaminants According to section 39655 of the California Health and Safety Code,a toxic air contaminant is"an air pollutant which may cause or contribute to an increase in mortality or an increase in serious illness, or which may pose a present or potential hazard to human health". In addition, 189 substances that have been listed as federal hazardous air pollutants (HAPs) pursuant to section 7412 of Title 42 of the United States Code are TACs under the state's air toxics program pursuant to section 39657 (b) of the California Health and Safety Code. The TACs can cause various cancers depending on the particular chemicals, type and duration of exposure. Additionally, some of the TACs may cause short-term and/or long-term health effects. The ten TACs posing the greatest health risk in California are acetaldehyde, benzene, 1-3 6 http://www.epa.gov/pmdesignations/documents/120/table.htm, November 10,2004. City of Huntington Beach April 5, 2005 5.4-10 Seawater Desalination Project at Huntington Beach 5.4 AIR QUALITY Draft Recirculated Environmental Impact Report butadiene, carbon tetrachloride, hexavalent chromium, para-dichlorobenzene, formaldehyde, methylene chloride, perch lorethylene, and diesel particulate matter. t IMPACTS Significance Criteria In accordance with CEQA,the effects of a project are evaluated to determine if they would result in a significant impact on the environment. An Environmental Impact Report(EIR)is required to focus on these effects and offer mitigation measures to avoid or lesson any significant impacts that are identified. The criteria, or standards, used to determine the significance of impacts may vary depending on the nature of the project. Air quality impacts resulting from implementation of the ' proposed Project could be considered significant if they cause any of the following to occur: ❖ Conflict with or obstruct implementation of the applicable air quality plan; ❖ Violate any air quality standard or contribute substantially to an existing or projected air quality violation; ❖ Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable Federal or State ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors); ❖ Expose sensitive receptors to substantial pollutant concentrations; and/or ❖ Create objectionable odors affecting a substantial number of people. SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT THRESHOLDS Under CEQA, the SCAQMD is an expert commenting agency on air quality and related matters within its jurisdiction or impacting its jurisdiction. Under the FCAA the SCAQMD has adopted federal attainment plans for ozone and PM10. The SCAQMD reviews projects to ensure that they ' would not: 1) cause or contribute to any new violation of any air quality standard; 2) increase the frequency or severity of any existing violation of any air quality standard; or 3) delay timely attainment of any air quality standard or any required interim emission reductions or other milestones of any federal attainment plan. The SCAQMD CEQA Air Quality Handbook provides significance thresholds for both construction and operation of projects within the SCAQMD jurisdictional boundaries. Exceedance of the SCAQMD thresholds could result in a potentially significant impact. However, ultimately the lead agency determines the thresholds of significance for impacts.' If the project proposes development in excess of the established thresholds, as illustrated in Table 5.4-5, SCAQMD EMISSION ' THRESHOLDS, a significant air quality impact may occur and additional analysis is warranted to fully assess the significance of impacts. In addition,the significance of localized project impacts depends on whether ambient CO levels in the vicinity of the project are above or below State and Federal CO standards. If the project causes an exceedance of either the state one-hour or eight-hour CO concentrations, the project would be considered to have a significant local impact. If ambient levels already exceed a state or federal standard, then project emissions would be considered significant if they increase one-hour CO concentrations by 1.0 ppm or more, or eight-hour CO concentrations by 0.45 ppm or more. ' ' South Coast Air Quality Management District, CEQA Air Quality Handbook, page 6-1,April 1993. ' City of Huntington Beach April 5, 2005 5.4-11 Seawater Desalination Project at Huntington Beach 5.4 AIR QUALITY Draft Recirculated Environmental Impact Report Table 5.4-5 SCAQMD EMISSIONS THRESHOLDS Phase Pollutant Ibslda ROG P c0 Sox PM10 Operational 55 55 550 150 150 Source: SCAQMD,CEQA Air Qua2E Handbook,pa2e 6:1,ARM 1993. ODOR-BASED THRESHOLDS Projects emanating objectionable odors near existing sensitive receptors or other land uses where people may congregate could constitute a significant air quality impact to existing uses. Also, residential or other sensitive receptor projects built for the intent of attracting people near existing odor sources could also cause a significant air quality impact. The SCAQMD suggests a threshold based on the distance of the odor source from people and complaint records for a facility or similar facility. SHORT-TERM EMISSIONS For a discussion of short-term air quality impacts associated with remediation, demolition, grading and construction, refer to Section 5.9, CONSTRUCTION RELATED IMPACTS. LONG-TERM EMISSIONS The operation of the proposed project involves three primary activities that would generate air emissions. These activities are: ❖ Electricity generation by others for consumption to operate the project facilities and equipment; ❖ Electricity generation by others for consumption related to pump station operations; and ❖ Mobile source emissions from employee and truck delivery operations. Mobile sources refer to emissions from motor vehicles,including tailpipe and evaporative emissions. Depending upon the pollutant being discussed, the potential air quality impact may be of either regional or local concern. For example, ROG, NOx,and PM10 are all pollutants of regional concern (NOx and ROG react with sunlight to form 03 or photochemical smog, and PM10 is readily transported by wind currents). However, CO tends to be a localized pollutant, dispersing rapidly at the source. As previously discussed, the SCAB is a non-attainment area for 03 and PM10 (Federal and State). Nitrogen oxides and ROG are regulated 03 precursors(a precursor is defined as a directly emitted air contaminant that, when released into the atmosphere, forms or causes to be formed or contributes to the formation of a secondary air contaminant forwhich an ambient air quality standard has been adopted). Sources of long-term air emissions include machinery, equipment and vehicles within the project site, as well as indirect emissions from electricity and natural gas consumption. All water pumps associated with the proposed project (including the proposed off-site underground booster pump station) would be electrically powered, and would not directly generate air emissions. However, indirect impacts due to electrical consumption factors of the proposed desalination project are analyzed below. City of Huntington Beach April 5, 2005 5.4-12 ' Seawater Desalination Project at Huntington Beach 5.4 AIR QUALITY Draft Recirculated Environmental Impact Report ' PROPOSED DESALINATION FACILITY SITE ' Mobile Source Emissions Motor vehicles including potential employee and truck delivery trips associated with the project would constitute the primary source of pollutant emissions. It is anticipated that the project would ' result in an estimated worst-case of,28 worker trips per day, traveling an estimated maximum distance of 50 miles each way. In addition, truck deliveries have been anticipated to generate approximately four trips per day. Project generated vehicle emissions have been estimated with the ' EMFAC2002 (version 2.2) emissions model. URBEMIS2002 was not utilized for operational emissions due to the minimal amount of area source and vehicular related activities associated with the project. Thus,the estimated long-term emissions from mobile sources would be well below the SCAQMD thresholds for CO, ROG, NOX and PM10. Table 5.4-6, MOBILE SOURCE EMISSIONS, illustrates the minimal impacts associated with the project. Mobile source emissions from operation of the proposed desalination facility are anticipated to result in less than significant impacts. Carbon Monoxide The project is not anticipated to result in air quality impacts from CO hotspots.The project does not generate enough vehicular trips to result in a degradation of the level of service(LOS)of roadways in the site vicinity. Therefore, CO hotspots are not anticipated to result from project operations. Table 5.4-6 MOBILE SOURCE EMISSIONS Pollutant Mobile Source SCAQMD Thresholds Threshold Exceedance Emissions Ibslda Ibslda Yes/No Carbon Monoxide CO 43.0 550 NO ' Reactive Organic Gases ROG 4.74 55 NO Nitrogen Oxides(NOx) 9.6 55 NO Sulfur Oxides SOx 0.4 150 NO ' Particulate Matter PM10 0.08 150 NO Notes: 1.Emissions calculated utilizing the EMFAC2002(Q.2)model. 2.Oe2rational emissions calculations can be found in A2pendix B,Air Qualit . ' Electricity Consumption ' Based upon power consumption of 15 kilowatt hours per thousand gallons(4,887 kilowatt hours per acre-foot), the proposed 50 mgd (56,000 AF per year) desalination facility would require approximately 30 to 35 megawatts per hour to produce and distribute potable water. As such,the ' daily energy consumption of the facility is estimated to be between 720 to 840 megawatt hours per day. In order to take advantage of lower cost power pricing,the facility may utilize off-peak power to the maximum extent practicable by temporarily halting the production of potable water and only pumping product water from the product water storage tank. No back-up electrical generators would be incorporated into the proposed project site, as back-up power would be drawn from the electrical ' power grid and/or AES Huntington Beach Generating Station's (HBGS) auxiliary reserve bank. The proposed desalination facility's electrical power source would be controlled by a power ' marketing company, which, in consultation with the California Independent System Operator(Cal ISO), would obtain power from the HBGS, and/or the California power market at the lowest cost ' City of Huntington Beach April 5, 2005 5.4-13 Seawater Desalination Project at Huntington Beach 5.4 AIR QUALITY Draft Recirculated Environmental Impact Report possible. As such, a variety of base-, intermediate-and peak-load power generating facilities may produce power for the desalination facility. Typically,base-loaded power plants(such as California's two nuclear power plants and out-of-state coal-fired power plants) as well as several large hydroelectric power dams are the primary source of off-peak power serving Southern California. Intermediate and peak load plants are typically fossil fuel generating facilities(predominantly natural gas fired). The project would not change any General Plan or Zoning designations,and,as such,air impacts in this regard have been previously accounted for within local and regional planning documents. In addition, emissions resulting from the proposed project's electricity consumption would not be concentrated in the project site vicinity, as such emissions would be distributed throughout the region (with a portion possibly occurring outside of California),and have been previously accounted for through previous environmental documentation prepared for the SCAQMD's Regional Clean Air Incentives Market(RECLAIM)and New Source Review programs (refer to CONSISTENCY WITH REGIONAL PLANS, below).8 Electric power generating plants are distributed throughout the SCAB and beyond, and their emissions contribute to the total regional pollution burden. As the project is proposed to consume between 720 to 840 megawatt hours per day of electricity,the project may create regional impacts in regards to air quality(especially NO, which is typically produced by high temperature combustion processes utilizing fossil fuels, including electricity generating plants).9 However, it would be speculative to quantify such emissions caused by the proposed project's electricity consumption,as many power sources are located outside of the SCAB or the state, and the time of use by the desalination facility would dictate whether or not off-peak non-fossil fuel electrical power is being consumed. It should be noted that,although a power plant is located adjacent to the subject site(HBGS),actual project-related emissions are not possible to attribute to any one plant,since the project's electrical demand is met by dozens of power plants connected to a regional power supply grid,with many of those plants located outside of Southern California. It should further be noted that if the HBGS facility were to cease operating, electricity would still be available to the proposed desalination facility, as the proposed project would utilize electricity from the power grid and not directly from HBGS. Chemical Storage Facilities Various chemicals typically associated with desalination facilities would be stored on-site. These chemicals include sodium hypochlorite, ammonia, lime, carbon dioxide, ferric sulfate, polymer, sulfuric acid, sodium bi-sulfite and the RO membrane-cleaning solution. All chemicals would be stored, handled, and used in accordance with all applicable Federal, State, and local standards. These chemicals are food-grade purity compounds typically used in most conventional water treatment facilities. The seawater desalination facility would use the same type and grade of chemicals as any other conventional surface water treatment plant. However, the seawater 8 Jonathan Nadler, South Coast Air Quality Management District, February 22,2002. 9 In the event that the proposed desalinated water entirely replaces a given water provider's water curtailed from the State Water Project along the West Branch, then the power requirements to move imported water through the Central Valley, over the Tehachapi Mountains, and into the Los Angeles Basin could result in substantial power reductions,thus resulting in air quality offsets. Whereas the proposed facility has an"all in"power rate of 4,887 kilowatt hours per acre-foot for producing water and conveyance into the Orange County system,according to the Department of Water Resources Bulletin 132 (1998),the State Water Project has a power rate of 3,200 kilowatt hours per acre-foot(net of hydroelectric power production in the LA Basin). As such,there is only a 1,687 kilowatt- hour per acre foot difference(or an additional 258 megawatts per day)increase in energy consumption over current supplies into the Metropolitan Water District's(MW D)Diemer water treatment facility. City of Huntington Beach April 5, 2005 5.4-14 Seawater Desalination Project at Huntington Beach 5.4 AIR QUALITY Draft Recirculated Environmental Impact Report ' desalination facility would use fewer chemicals of lower dosages than existing conventional water treatment plants in Southern California. Chemical storage and the use of chemicals during the desalination process are not anticipated to have significant impacts to air quality in the region. In addition, based on the types of chemicals stored on site and their containment methods,odors are unlikely to emanate from the project site. Visibility A visibility analysis of the project's gaseous emissions is required under the Federal Prevention of Significant Deterioration (PSD) permitting program. The analysis addresses the contributions of gaseous emissions (primarily NOx and PM10) to visibility impairment on the nearest Class 1 PSD areas,which are national parks and national wildlife refuges.There are no national parks or refuges in close proximity to the project.The nearest Class 1 areas to the proposed project are the Channel Islands National Park,Joshua Tree National Park,Cabrillo National Park,Santa Monica Mountains National Recreation Area,Seal Beach National Wildlife Refuge and the Salton Sea National Wildlife Refuge.10•11 Considering the minimal amount of emissions generated by the operation of the proposed project, modeling was not conducted and impacts in this regard would be less than significant. 1 OFF-SITE PIPELINES AND UNDERGROUND PUMP STATIONS Off-site project components would include water transmission pipelines and underground booster pump stations. The underground pump stations would convey potable water from the desalination site to the regional distribution system. Two off-site booster pump stations are proposed, which would include surge tanks to protect the distribution system from sudden pressure changes, telemetry equipment, appurtenances and diesel powered electrical generators for emergency backup equipment.The diesel-powered back-up generators would be Caterpillar model 3516 units or similar equipment and would supply approximately seven megawatts of emergency power for adequate operation of the pump station (in regards to flow and pressure). The largest diesel- powered generator, located on the OC-44 booster station would require an 8,700-gallon diesel fuel storage tank (assuming a 24-hour emergency period). All internal combustion engines (ICEs) greater than 50 brake horsepower (bhp) are required to obtain a permit to construct from the SCAQMD prior to installation of the engines at the project site. NOX emissions from diesel-fired emergency engines are 200 to 600 times greater, per unit of electricity produced,than new or controlled existing central power plants fired on natural gas. Diesel- fired engines also produce significantly greater amounts of fine particulates and toxics emissions compared to natural gas fired equipment. In order for generators to be considered an emergency ' backup generator by the SCAQMD,generators cannot operate more than 200 hours a year and can only operate in the event of an emergency power failure or for routine testing and maintenance. Furthermore,the SCAQMD has provided a list of models of equipment as meeting all applicable air quality requirements and have issued permits to the dealer/distributor of these engines.The diesel- powered generator anticipated for the project, Caterpillar model 3516, is included within the approved list provided by the SCAQMD.12 In addition to applying for a permit to construct from the SCAQMD(Rule 201, refer to table 5.4-2), it would be necessary to apply for a Special Application for Temporary Emergency Authorization To 10 National Park Service, http://data2.itc.nps.gov/parksearch/state.cfm?st=ca, November 30,2004. 11 http://gorp.away.com/gorp/location/ca/wrfsc ca.htm, November 30,2004. 12 South Coast Air Quality Management District, htti)://www.agmd.gov/permit/docs/Emergency%2OGenerator% 20Fact%2OSheet.doc, November 29,2004. City of Huntington Beach April 5, 2005 5.4-15 Seawater Desalination Project at Huntington Beach 5.4 AIR QUALITY Draft Recirculated Environmental Impact Report Operate Electric Backup Generator(s)During Involuntary Power Service Interruptions Permit.13 The project would obtain all required air quality permits. Therefore, impacts associated with the operation of diesel- powered generators are anticipated to be less than significant. Pump stations as well as water transmissions lines would occasionally require maintenance,which would generate worker trips. Maintenance activities would occur at sporadic instances, and therefore modeling was not conducted since trip generation from such activities would not result in any significant air quality impacts. Water transmission lines would not result in criteria pollutant emissions and therefore would not have any significant impacts to air quality. CONSISTENCY WITH REGIONAL PLANS The purpose of the consistency finding is to determine if a project is inconsistent with the assumptions and objectives of the regional air quality plans, and thus if it would interfere with the region's ability to comply with Federal and State air quality standards. If a project is inconsistent, local governments need to consider project modifications or inclusion of mitigation to eliminate the inconsistency. It is important to note that even if a project has significant operational or cumulative air quality impacts, it can still be found consistent with the regional air quality conformity under the SCAQMD's planning handbook. Therefore,it is necessary to assess the project's consistency with the AQMP and the City of Huntington Beach General Plan. The subject site has a land use and zoning designation of Public(P). Project implementation would not conflict with the General Plan or Zoning Ordinance, nor would it propose to change any designations. As such, projects consistent with local General Plans are considered consistent with air quality related regional plans,such as the AQMP.14 Accordingly,air quality emissions and related impacts for the proposed desalination project have been locally and regionally accounted for.15 As indicated in SCAQMD's CEQA Air Quality Handbook, there are two main indicators of consistency: ❖ Whether the project would not result in an increase in the frequency or severity of existing air quality violations or cause or contribute to new violations, or delay timely attainment of air Ty quality standards or the interim emission reductions specified in the AQMP; and ❖ Whether the project would exceed the AQMP's assumptions for 2010 or increments based on the year of project build-out and phase. As previously stated,since the AQMP is based on the City and County's General Plan assumptions, the proposed desalination project is consistent with these General Plan assumptions. Thus, the project would be considered consistent with the AQMP land use assumptions and goals. In addition, the region (Los Angeles County, Orange County, and half of Riverside County) is regulated by the SCAQMD's Regional Clean Air Incentives Market (RECLAIM). The RECLAIM program, implemented on January 1, 1994,controls the amount of NOx and SOX emissions through financial incentives and involves the trading of emissions credits. The RECLAIM program is µ designed to guarantee annual reductions in air pollution by requiring industrial and business uses (including power plants)emitting four tons or more per year of NOx and SOX to cut their emissions by specific amount each year,resulting in an almost 80 percent reduction of NOx and SOX by 2003. As 13 South Coast Air Quality Management District,http://www.aomd.gov/permit/em back up gen.html,November 29, 2004. 14 CEQA Air Quality Handbook,Chapter 12, page 12-2. 15 Jonathan Nadler, South Coast Air Quality Management District, February 22,2002. City of Huntington Beach April 5, 2005 5.4-16 Seawater Desalination Project at Huntington Beach 5.4 AIR QUALITY Draft Recirculated Environmental Impact Report such, future NO, and SO,, emissions for the region, including those resulting from project implementation, would be offset through the RECLAIM program, and no significant regional air quality planning impacts are anticipated.'s The proposed project would also require review by the SCAQMD under Regulation XI I I (New Source Review), which establishes pre-construction requirements for new or modified facilities to ensure that operation of such facilities does not interfere with progress toward the attainment of ambient air quality standards (AAQS)without necessarily restricting economic growth. The specific air quality goal of this regulation is to achieve a no net increase from new or modified permitted sources of non-attainment air contaminants or their precursors." This standard review process administered by the SCAQMD would further ensure that the proposed project is consistent with regional air quality plans. In addition,according to SCAG,the project is consistent with the Regional Comprehensive Plan and Guide (RCPG). The following policies taken from the RCPG apply to the project: Core Growth Management Policies 3.03 The timing, financing, and location of public facilities, utility systems, and transportation systems shall be used by SCAG to implement the region's growth policies. 3.18 Encourage planned development in location least likely to cause adverse environmental impact. 1.11 Through the environmental document review process, ensure that plans at all levels of government (regional, air basin, county, sub-regional and local) consider air quality, land use, transportation and economic relationships to ensure consistency and minimize conflict. Analysis has shown that the project is consistent with regional plans and therefore would result in less than significant impacts. ' MITIGATION MEASURES ' LONG-TERM EMISSIONS None required. CONSISTENCY WITH REGIONAL PLANS None required. UNAVOIDABLE SIGNIFICANT IMPACTS None have been identified. 16 http://www.agmd.gov/reclaim/reclaim.htmi t7 http://www.agmd.gov/rules/html/rl301.html City of Huntington Beach April 5, 2005 5.4-17 5.5 NOISE The purpose of this section is to analyze project-related noise source impacts on-site and to surrounding land uses. Mitigation measures are also recommended to avoid or reduce the project's impacts. This section evaluates short-term construction-related impacts as well as long-term buildout conditions. Information in this section is based on the City of Huntington Beach General Plan (1996), and the City of Huntington Beach General Plan EIR (1995). Refer to Appendix A, NOISE DATA, for the assumptions used in this analysis. ACOUSTICAL TERMINOLOGY NOISE SCALES AND DEFINITIONS Sound is technically described in terms of the loudness (amplitude) of the sound and frequency (pitch) of the sound. The standard unit of measurement of the loudness of sound is the Decibel (dB). Since the human ear is not equally sensitive to sound at all frequencies,a special frequency- dependent rating scale has been revised to relate noise to human sensitivity. The A-weighted decibel scale(dBA)performs this compensation by discriminating against frequencies in a manner approximating the sensitivity of the human ear. Decibels are based on the logarithmic scale. The logarithmic scale compresses the wide range in sound pressure levels to a more usable range of numbers in a manner similar to the Richter scale used to measure earthquakes. In terms of human response to noise, a sound 10 dBA higher than another is judged to be twice as loud,and 20 dBA higher four times as loud,and so forth. Everyday sounds normally range from 30 dBA (very quiet) to 100 dBA (very loud). Examples, of various sound levels in different environments are shown in Exhibit 5.5-1, SOUND LEVELS AND HUMAN RESPONSE. In general, a three dBA change in sound pressure level is considered a"just detectable"difference in most situations. A five dBA change is readily noticeable and a 10 dBA change is considered a doubling (or halving) of the subjective loudness. It should be noted that a three dBA increase or decrease in the average traffic noise level is realized by a doubling or halving of the traffic volume, or by about a seven mile per hour(mph) increase or decrease in speed. For each doubling of distance from a point noise source, the sound level would decrease by six dBA. In other words, if a person is 100 feet from a machine, and moves to 200 feet from that source,sound levels would drop approximately 6 dBA. For each doubling of distance from a source, like a roadway, noise levels are reduced by 3 to 5 decibels,depending on the ground cover between the source and the receiver. Numerous methods have been developed to measure sound over a period of time. These methods include: 1)the Community Noise Equivalent Level(CNEL);2)the Equivalent Sound Level(Leq);and 3) Day/Night Average Sound Level (Ldn). These methods are described below. COMMUNITY NOISE EQUIVALENT LEVEL (CNEL) The predominant community noise rating scale used in California for land use compatibility assessments is the Community Noise Equivalent Level (CNEL). The CNEL reading represents the average of 24 hourly readings of equivalent levels,known as Leq's,based on an A-weighted decibel with upward adjustments added to account for increased noise sensitivity in the evening and night periods. These adjustments are+5 dBA for the evening,7:00 PM to 10:00 PM,and+10 dBA forthe night, 10:00 PM to 7:00 AM. CNEL may be indicated by"dBA CNEL" or just"CNEL". City of Huntington Beach April 5, 2005 5.5-1 Seawater Desalination Project at Huntington Beach 5.5 NOISE Draft Recirculated Environmental Impact Report Leq The Leq is the sound level containing the same total energy over a given sample time period. The Leq can be thought of as the steady sound level which, in a stated period of time,would contain the same acoustic energy as the time-varying sound level during the same period. Leq is typically computed over one, eight and 24-hour sample periods. DAY NIGHT AVERAGE (LDN) Another commonly used method is the day/night average level or Ldn. The Ldn is a measure of the 24-hour average noise level at a given location. It was adopted by the U.S. Environmental Protection Agency(EPA)for developing criteria for the evaluation of community noise exposure. It is based on a measure of the average noise level over a given time period called the Leq. The Ldn is calculated by averaging the Leq's for each hour of the day at a given location after penalizing the "sleeping hours" (defined as 10:00 PM to 7:00 AM) by 10 dBA to account for the increased sensitivity of people to noises that occur at night. The maximum noise level recorded during a noise event is typically expressed as Lmax. The sound level exceeded over a specified time frame can be expressed as Ln (i.e., L90, L50, L10, etc.). L50 equals the level exceeded 50 percent of the time, L10 10 percent of the time, etc. NOISE ATTENUATION Noise barriers provide approximately a five dBA noise reduction (additional reduction may be provided with a barrier of appropriate height, material, location and length). A row of buildings provides up to five dBA noise reduction with a 1.5 dBA reduction for each additional row up to a maximum reduction of approximately 10 dBA. The exact degree of noise attenuation depends on the nature and orientation of the structure and intervening barriers. LAWS, ORDINANCES, REGULATIONS AND STANDARDS It is difficult to specify noise levels that are generally acceptable to everyone. What is annoying to one person may be unnoticed by another. Standards may be based on documented complaint activity in response to documented noise levels, or based on studies on the ability of people to sleep, talk, or work under various noise conditions. All such studies, however, recognize that individual responses vary considerably. Standards usually address the needs of most of the general population. STATE OF CALIFORNIA GUIDELINES The California Environmental Quality Act(CEQA)was enacted in 1970 and requires that all known environmental effects of a project be analyzed, including environmental noise impacts. Under CEQA, a project has a potentially significant impact if the project exposes people to noise levels in excess of standards established in the local general plan or noise ordinance. Additionally, under CEQA, a project has a potentially significant impact if the project creates a substantial increase in the ambient noise levels in the project vicinity above levels existing without the project. If a project has a potentially significant impact, mitigation measures must be considered. If mitigation measures to reduce the impact to less than significant are not feasible due to economic,social,environmental, legal, or other conditions, the most feasible mitigation measures must be considered. City of Huntington Beach April 5, 2005 5.5-2 qN&q 4 N9R,'+$f tlq kL�,) �N�'J�DI' "� „��Ihti '� 'fs' �n k LIetE■#i �yl s �� SD �Na s wu>k�u Ha.SmliR.iI �Laud�il 1��.� 61 `W F" niN, , 4 Ii k •iyts iilii r' { � 's +, S Q I N� w�tli iii hhon Fang _ `s s ,� s' h `0 i� r � ait Ii �: r " Jinr~ P'ain�Thr�shald - NON , �i n 1' "Ill i �•_; S�"I'�tn+ = J3ua � u e w i _ VMa iae �I� h�s° II IeI��N� ��� �' IA1M 2- `tii� 'T`" '"MPI�Nys.��, N n Fk °�:�� � � ���N ■■ �' �Re ajar e€ asu � ve =1,minute �u RVC!► l1uslC 7, 7 ,zp,, �� ��� � � x risks permanent hearing[ass Fi(�S� �, „.i nLlii FGnS � ,, � k, L''�,I�' aW+S ii .,, i �"' a� n I ILN� � 7Wn`1ftiL) a.i �i +yQj /� Na,ma a than ]5 m�ilute Garbi�geii ruirk 1'�''S� a't VIOSUretreCamnich t: � 154,; s h r 8 V , La o wn nnoyW ng �``Rss i Wi i i s v "� WSN ii 4p nL WW n w r z4 k FY L ��� i � �� ape Average Gty Tra#fic Noise„i y F' Anna►ying=i interferes k with' conversation ,4" a Vacuuttt,Cleaner 7p Telephone use Difficulty r �r - IN N ); w�,i �Ii�h phtcy liq� s� s Norman Conriersatian ' 60F' Comfortable 1I,f. r 4 M C i � �5p e Li�t 'SF " Si ai Re r,geratO Humming °40 "" F r k 2 h,r r g r 9P W p 3 s r SI it;* i rf u. �. sai n sJ ry'nY s {'y ��jq�'♦■�^ '�� �k, e� 1,,�• d y�/+��,. � �(, M x ru r swL f q W.■■i.7 et" �� ��„ ,- Y t Vo Very Quit' ( 4 t prn+ WF 1 Si as "w S+J a s ,� I s ( i.: C .pp.¢ t „n ` L `kd I E j ems's,awi�FWr S k nriii, 'f" .W � d � ig� tti PF dl "rirf Fv.7w I';I &, h P7 ( s r§ Rustlrng Leaves .Zp �N, w � 9 V, a?f ail a �NmN is^'fir � �`' sin "i,li illl i i 7, dlK:li"1�u7�kAaadi/1je1 t� rw r,Si 1d+i Ni) � 4.Sa�i iiVlUBq.0 Iil� a i 4 `"'' s1t Jan .h'�.nT I, tS bik'Lr ,li iWi h�Ni H ryi iil4 FNh : �"'"Jih d 't�i In Pa @ Maur ,1 OFF o rc„ R r illi ,; �- •o °, Ili a'Fs I{N iF••i i i � ri {�, i „ pry F (Crs„k,Iiliki4h�a & -an,.t� - a: 1 s r r� INrM �k2 S ca nln�hiiNl r r � W i�NorrnalL Breathin '. t 6 lip a�p`rvt ;Fi�. �i n'$.ih %h« 7�pi ��'�IW �Hyri g@ s7 � .iS�� y�5so W � .i $; fe Nir 1. k-M �ZA610 } IRThresholdi, Hearing i�,Im,P. ,a �, N) Sources: Melville C.Branch and R.Dale Beland, Outdoor Noise in the Metropolitan Environment, 1970. Environmental Protection Agency, Information on Levels of Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety(EPA/ONAC 55019-74-004), March 1974. SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH WF Sound Levels and Human Response CONSULTING 02/05•JN 10-101409.002 Exhibit 5.5-1 Seawater Desalination Project at Huntington Beach 5.5 NOISE Draft Recirculated Environmental Impact Report California Government Code California Government Code Section 65302 (f) mandates that the legislative body of each county and city adopt a noise element as part of their comprehensive General Plan. The local noise element must recognize the land use compatibility guidelines established by the State Department of Health Services as shown in Table 5.5-1, LAND USE COMPATIBILITY FOR COMMUNITY NOISE ENVIRONMENTS. Table 5.5-1 CALIFORNIA LAND USE COMPATIBILITY NOISE GUIDELINES Communi <Noise Ez osure InTerms60fCNEL , Land Use Categoryx °NormallyConditionallyNormally z t ,; Clearly Acce"fable:: _:U1iac"ce 'table N°iUnacce table. Residential-Low Density,Single Family,Duplex, 50—60 55-70 70-75 75-85 Mobile Homes Residential-Multiple Family 50—65 60-70 70-75 70—85 Transient Lodging-Motel,Hotels 50—65 60-70 70-80 80—85 Schools,Libraries,Churches,Hospitals,Nursing 50—70 60-70 70-80 80—85 Homes Auditoriums,Concert Halls,Amphitheaters NA 50-70 NA 65—85 Sports Arenas,Outdoor Spectator Sports NA 50-75 NA 70—85 Playgrounds,Neighborhood Parks 50—70 NA 67.5-75 72.5-85 Golf Courses,Riding Stables,Water Recreation, 50—70 NA 70-80 80—85 Cemeteries Office Buildings,Business Commercial and 50—70 67.5-77.5 75-85 NA Professional Industrial,Manufacturing,Utilities,Agriculture 1 50—75 70-80 75-85 1 NA Source:General Plan Guidelines,Office of Planning and Research,California,October 2003.. Notes: NORMALLY ACCEPTABLE Specified land use is satisfactory,based upon the assumption that any buildings involved are of normal conventional construction,without any special noise insulation requirements. CONDITIONALLY ACCEPTABLE New construction or development should be undertaken only after a detailed analysis of the noise reduction requirements is made and needed noise insulation features included in the design. Conventional construction,but,but with closed windows and fresh air supply systems or air conditioning will normally suffice. NORMALLY UNACCEPTABLE New Construction or development should be discouraged. If new construction or development does proceed,a detailed analysis of the noise reduction requirements must be made and needed noise insulation features included in the design. CLEARLY UNACCEPTABLE New construction or development should generally not be undertaken. NA:Not Applicable The guidelines rank noise-land use compatibility in terms of"normally acceptable", "conditionally acceptable"and"clearly unacceptable"noise levels for various land use types. Single-family homes are "normally acceptable" in exterior noise environments up to 60 CNEL and "conditionally acceptable" up to 70 CNEL. Multiple-family residential uses are "normally acceptable" up to 65 CNEL and"conditionally acceptable"up to 70 CNEL. Schools,libraries,and churches are"normally acceptable" up to 70 CNEL, as are office buildings and business, commercial and professional uses. In addition,the California Noise Insulation Standard (California Administrative Code,Title 25, Chapter 1, Subchapter 1,Article 4)requires that indoor noise levels in multi-family residences do not exceed a CNEL of 45 dBA. 1 City of Huntington Beach April 5,2005 5.5-4 Seawater Desalination Project at Huntington Beach 5.5 NOISE Draft Recirculated Environmental Impact Report LOCAL JURISDICTIONS Local agencies may regulate noise levels of most sources not regulated by the Federal or State government. They may provide standards for insulation of noise receivers eitherwithin the structure or by placement of noise barriers such as walls;and,through land use decisions, may reduce noise impacts by separating noise generators from noise sensitive uses. To provide a satisfactory noise environment and to minimize complaints about community noise, the local jurisdictions have adopted standards for evaluating the compatibility of land uses with respect to outdoor and certain ((�� indoor noise levels. The purpose of the land use compatibility analysis is to screen projects that may require specific design considerations to mitigate noise impacts. City of Huntington Beach The City of Huntington Beach has adopted noise objectives and policies in its General Plan. These noise objectives and policies pertain to land use impacts,mobile noise sources,and stationary noise sources. The City of Huntington Beach has also,adopted a Noise Ordinance (Chapter 8.40 of the Huntington Beach Municipal Code), which identifies exterior and interior noise standards, specific noise restrictions, exemptions, and variances for sources of noise within the city. The Noise Ordinance applies to all noise sources with.the exception of any vehicle that is operated upon any public highway, street or right-of-way, or to the operation of any off-highway vehicle, to the extent that it is regulated in the State Vehicle Code, and all other sources of noise that are specifically exempted.The City's exterior noise standards are identified in Table 5.5-2,CITY OF HUNTINGTON BEACH NOISE ORDINANCE EXTERIOR NOISE STANDARDS. Table 5.5-3, CITY OF HUNTINGTON BEACH NOISE ORDINANCE INTERIOR NOISE STANDARDS,identifies the City's interior noise standards and prohibited interior noise levels. In both cases, if the ambient noise level is greater than the identified noise standards, the noise standard becomes the ambient noise level without the offending noise. The Noise Ordinance exempts noise sources associated with construction activities from the City's exterior and interior noise standards provided that a permit has been obtained from the City and that the construction activities do not occur between the hours of 8:00 PM and 7:00 AM on weekdays and Saturdays, or at any time on Sundays or federal holidays. City of Costa Mesa The City of Costa Mesa maintains a comprehensive Noise Ordinance which sets standards for noise levels citywide and provides the means to enforce the reduction of obnoxious or offensive noises. �J The basic noise standards outlines the typical land use compatibility standards of 65 CNEL for exterior areas and 45 CNEL for interior areas. The City of Costa Mesa limits the hours of construction activities from 7:00 AM to 8:00 PM, Monday through Friday and from 8:OOAM to 6:00 PM on Saturday. City of Irvine The City of Irvine treats construction noise separately in the City's noise ordinance because it does not represent a chronic, permanent noise source. To limit the potential nuisance from construction �I noise,especially for adjacent noise-sensitive receptors,the City of Irvine Noise Ordinance(Section 6-8-205 of the Municipal Code) limits the hours of construction activities from 7:00 AM to 7:OOPM, Monday through Friday and from 9:00 AM to 6:00 PM on Saturday. Compliance with the City's noise ordinance of limiting construction activities to those hours indicated in the Municipal Code would 1 reduce construction noise impacts a less than significant level. Additional "standard" conditions such as maintaining mufflers in good condition and placing construction staging areas as far from sensitive receptors would further reduce any construction related noise impact. City of Huntington Beach April 5, 2005 5.5-5 a }, Seawater Desalination Project at Huntington Beach 5.5 NOISE Draft Recirculated Environmental Impact Report ,>k-, Table 5 5-2 CITY OF HUNTINGTON BEACH NOISE ORDINANCE EXTERIOR NOISE STANDARDS Noise Land Uses r Noise Level Ttme Period 1 All Residential Properties 55 dBA Leq 7 AM to 10 PM 50 dBA Leg 10 PM to 7 AM 2 All Professional Office and Public Institutional Properties 55 dBA Leg Anytime 3 All Commercial Properties Except Professional Office 60 dBA Leg An time 4 All Industrial Pro erties 70 dBA Leg Anytime Exterior Noise Levels Prohibited: It shall be unlawful for any person at any location within the incorporated area of the City to create any noise,or to allow the creation of any noise on property owned, leased,occupied,or otherwise controlled by such person,which causes the noise level when measured on any residential,public institutional,professional, commercial or industrial property,either within or without the City,to exceed the applicable noise standards: (a)For a cumulative period or more than thirty(30)minutes in any hour; (b)Plus 5 dBA for a cumulative period of more than fifteen(15)minutes in any hour; (c)Plus 10 dBA for a cumulative period of more than five(5)minutes in any hour; (d)Plus 15 dBA for a cumulative period of more than one(1)minute in any hour;or (e)Plus 20 dBA for any period of time. In the event the ambient noise level exceeds any of the first four noise limit categories above,the cumulative period applicable to said category shall be increased to reflect said ambient noise level.In the event the ambient noise level exceeds the fifth noise limit category,the maximum allowable noise level under said category shall be increased to reflect the maximum ambient noise level. Source:Ci of Huntington Beach. I Table 5.5-3 CITY OF HUNTINGTON BEACH NOISE ORDINANCE INTERIOR NOISE STANDARDS Noise .s :.. Larid Uses Norse Level Time Period 20 a -; „ 1 All Residential Properties 55 dBA Leq 7 AM to 10 PM 45 dBA Leg 10PMto7AM 2,3,4 All Professional Office,Public Institutional,Commercial,and Industrial Properties 55 dBA Le Anytime Interior Noise Levels Prohibited: It shall be unlawful for any person at any location within the incorporated area of the City to create any noise,or to allow the creation of any noise on property owned, leased,occupied,or otherwise controlled by such person,which causes the noise level when measured within any other structure on any residential,public institutional,professional,commercial or industrial property to exceed: (a)The noise standard for a cumulative period or more than five(5)minutes in any hour; (b)The noise standard plus 5 dBA for a cumulative period of more than one(1)minutes in any hour;or i (c)The noise standard plus 10 dBA for any period of time. In the event the ambient noise level exceeds any of the first two noise limit categories above,the cumulative period applicable to said category shall be increased to reflect said ambient noise level.In the event the ambient noise level exceeds the third noise limit category,the maximum allowable noise level under said category shall be increased to reflect the maximum ambient noise level. Source:City of Huntington Beach. County of Orange As mandated by the California Government Code, the County of Orange has adopted a noise element as a component of the County of Orange General Plan. The County of Orange Noise Element is administered by the Orange County Planning Division of the Resources and Development Management Department (RDMD)and applies to all unincorporated portions of the County. The Noise Element establishes noise criteria to ensure that each county resident's quality of life is not adversely affected by high noise levels. In general, all outdoor living areas are compatible with noise levels less than CNEL 65 dBA. Similarly, indoor living spaces are compatible with interior noise levels less than CNEL 45 dBA. The County of Orange has also adopted a noise ordinance. The intent of the County of Orange Noise Ordinance is to control unnecessary, excessive, and annoying sound emanating from unincorporated areas of the County. Section 4-6-7 of the County's Noise Ordinance provides exemptions to the County's noise standards. It specifies that noise sources associated with City of Huntington Beach April 5, 2005 5.5-6 Seawater Desalination Project at Huntington Beach 5.5 NOISE Draft Recirculated Environmental Impact Report construction activity are prohibited between the hours of 8:00 PM and 7:00 AM on weekdays, including Saturday or at any time on Sunday or a Federal holiday. EXISTING CONDITIONS PROPOSED DESALINATION FACILITY SITE Noise Environment The primary noise sources in the project vicinity include commercial and industrial uses, as well as noise from adjacent local roadways. Both mobile and stationary noise sources contribute to the existing noise levels at the project site. Mobile noise sources consist mainly of car and truck traffic, with high volumes of traffic along Pacific Coast Highway, Magnolia Street, and Beach Boulevard (located west of the subject site). Stationary noise sources within the site vicinity include the AES : Huntington Beach Generating Station (HBGS)and commercial/industrial uses located to the north along Edison Avenue and Hamilton Avenue. Noise Sensitive Receptors Land uses considered sensitive receptors to noise include residential areas, schools, hospitals, churches, recreational areas, office buildings and transient lodging. The site is located adjacent to primarily commercial/industrial uses. Although no residential uses exist on the proposed project site, the Ascon/Nesi Landfill (located northeast of the site) is designated for residential uses, and two contiguous mobile home parks are situated west of the subject site along the inland side of Pacific Coast Highway. Additional residential uses surround the site to the north and east. Edison Community Center exists north of the project site along the northern side of Hamilton Avenue,while Edison High School is situated northeast of the site at the intersection of Hamilton Avenue and Li Magnolia Street. An open space area, Huntington State Beach, and Huntington City Beach are situated south and southwest of the subject site along Pacific Coast Highway. Existing Noise Levels Existing ambient noise levels were measured on-site,at nearby surrounding sensitive receptors and along the proposed water delivery pipeline alignments including the underground pump stations. Noise monitoring equipment used for the ambient noise survey consisted of a Larson Davis Laboratories Model LDL 820 sound level analyzer equipped with a Larson Davis Type 2561 microphone. The instrumentation was calibrated prior to use with a Larson Davis CAL 250 acoustical calibrator to ensure the accuracy of the measurements, and complies with applicable requirements of the American National Standards Institute(ANSI)for Type I (precision)sound level meters. The accuracy of the calibrator is maintained through a program established by the �- manufacturer, and is traceable to the National Bureau of Standards.All instrumentation meets the requirements of ANSI S1.4-1971. The Leq, Lmax, and source of peak noise for each reading is shown below in Table 5.5-4,EXISTING ON-SITEAND SURROUNDING AMBIENT NOISE LEVELS and Table 5.5-5, EXISTING OFF-SITE PIPELIN&PUMP STATION AMBIENT NOISE LEVELS. OFF-SITE PIPELINE ALIGNMENT AND UNDERGROUND PUMP STATIONS Proposed Pipeline Alignment The proposed water delivery pipeline would be up to approximately ten miles in length, extending from the proposed desalination facility to the OC-44 water transmission line within the City of Costa — Mesa,east of State Route 55(SR-55)at the intersection of Del Mar Avenue and Elden Avenue.The majority of the pipeline alignment will occur within existing public streets,easements,or other rights- City of Huntington Beach April 5, 2005 5.5-7 Seawater Desalination Project at Huntington Beach 5.5 NOISE Draft Recirculated Environmental Impact Report Table 5.5-41 EXISTING ON-SITE AND SURROUNDING AMBIENT NOISE LEVELS .LOCATION OF NOISE READINGLeq Lmax PEAKNOISE,.` ` 014=SITEN0ISE'L"EVELS' Northwest Portion of Site 54.8 64.5 Airplane-95.2 i Northeast Portion of Site 56.2 70.8 Truck-98.6 Southwest Portion of Site 60.1 69.4 Helicopter-94.1 Southeast Portion of Site 57.8 63.7 Airplane 91.4 -SURROUNDING NOISE LEVELS2 >. Huntington State Beach,adjacent to project site. 51.8 59.9 NA Corner of Kiowa Lane and Aloha Drive 52.6 52.9 NA Linear park adjacent to Seaforth Lane and Hamilton Avenue 55.7 64.7 Truck Cabrillo Mobile Home Park 64.7 75.9 Airplane 1 Measurements recorded on 4/24/02. 2 Measurements recorded on 11/11/2004 Table 5.5-5 EXISTING OFF-SITE PIPELINE/PUMP STATION AMBIENT NOISE LEVELS a Leq Lmax PEAK NOISE LOCATION,OF NOISE READING.,# , ,, db A s ' db"A .,, ...„ Source, Brookhurst Street/Adams Avenue Intersection(Primary Alignment) 73.9 86.6 Automobile Horn Harbor Boulevard/Fair Drive Intersection(Primary Alignment) 73.2 85.1 Bus Hamilton Avenue/Bushard Street Intersection Alternative Alignment) 71.0 86.3 Truck Victoria Street/Placentia Avenue Intersection Alternative Alignment) 72.6 84.3 Automobile Del Mar Avenue/Elden Avenue Intersection terminus of both pipeline alignments) 67.7 78.5 Automobile OC-44 Booster Pump Station 1 43.9 63.7 1 Wildlife Coastal Junction Booster Pump Station 1 58.4 71.2 1 Automobile Measurements recorded on 4/12/02(with the exception of the Coastal Junction Pump Station,which was recorded on 2/22/05).As surrounding conditions(land uses and traffic)of each noise reading location have remained consistent since 2002,ambient noise conditions would remain relatively unchan ed to present date. of-way (ROW) in urbanized areas. Although precise pipeline alignments may be modified during final engineering analyses, the conceptual pipeline alignments are shown in Exhibit 3-3, CONCEPTUAL PIPELINE ALIGNMENTS. Portions of the pipeline alignments are proposed to be installed within areas of the Costa Mesa Country Club (Costa Mesa) and Fairview State Hospital (Costa Mesa). OC-44 Booster Pump Station The OC-44 underground booster pump station is proposed to be located within an area of unincorporated Orange County,approximately 1.5 miles south of the University of California, Irvine., and 0.5 mile north of the San Joaquin Reservoir. The proposed OC-44 booster pump station site is surrounded by open space to the north, open space and residential to the east, two existing underground pump stations, open space,and residential to the west,and open space to the south. It should be noted that the proposed pump station site is located adjacent to (but not within) a Natural Community Conservation Plan/Habitat Conservation Plan (NCCP/HCP) area. The pump would be electrically powered and would be placed underground within an Orange County Resource Preservation Easement, in an area adjacent to open space and residential uses. 1 City of Huntington Beach April 5, 2005 5.5-8 Seawater Desalination Project at Huntington Beach 5.5 NOISE Draft Recirculated Environmental Impact Report Coastal Junction Booster Pump Station The Coastal Junction underground booster pump station is proposed within the parking lot of St. Paul's Greek Orthodox Church within the City of Irvine, located at 4949 Alton Parkway. The underground pump station would be constructed within the north/northwestem portion of the church parking lot, in an area used for both parking and volleyball activities. The footprint of the proposed underground pump station would be approximately 100 feet by 100 feet, and would require a construction easement of 125 feet by 125 feet. The Coastal Junction pump station site is surrounded by the St. Paul's Church to the south, the Woodbridge Village Association to the west, an apartment complex to the east, and open space to the north. Refer to Table 5.5-5, EXISTING OFF-SITE PIPELINE/PUMP STATION AMBIENT NOISE LEVELS. In general, ambient noise levels were lowest at the desalination facility site, nearby surrounding sensitive receptors,and the OC-44 off-site underground pump station facility. Ambient noise levels were higher along the two off-site water transmission pipeline alignments, with an average Leq of 71.7, due to automobile traffic along the proposed pipeline alignments. IMPACTS OA Significance Criteria Appendix G of the CEQA Guidelines contains analysis guidelines related to the assessment of noise impacts. These guidelines have been utilized as thresholds of significance for this analysis. As stated in Appendix G, a project may create a significant environmental impact if one or more of the following occurs: ❖ Exposure of persons to, or generation of, noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies; ❖ Exposure of persons to or generation of excessive ground borne vibration or ground borne ` noise levels; 1� ❖ A substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project; ❖ A substantial temporary or periodic increase in ambient noise levels in the project vicinity above levels existing without the project; ❖ Fora project located within an airport land use plan or, where such a plan has not been P J P p � adopted, within two miles of a public airport or public use airport,would the project expose people residing or working in the project area to excessive noise levels; and I ❖ For a project within the vicinity of a private airstrip,would the project expose people residing or working in the project area to excessive noise levels. SIGNIFICANCE OF CHANGES IN AMBIENT NOISE LEVELS al A project is considered to have a significant noise impact where it causes an adopted noise standard to be exceeded for the project site or for adjacent sensitive receptors. In addition to �N concerns regarding the absolute noise level that might occur when a new source is introduced into an area, it is also important to consider the existing noise environment. If the existing noise environment is quiet and the new noise source greatly increases the noise exposure,even though a criterion level might not be exceeded, an impact may occur. Lacking adopted standards for evaluating such impacts, general considerations for community noise environments are that a change of over 5 dBA is readily noticeable and,therefore,is considered a significant impact(refer to Table 5.5-6,SIGNIFICANCE OF CHANGES/N CUMULATIVE NOISE EXPOSURE). In areas where City of Huntington Beach April 5, 2005 5.5-9 Seawater Desalination Project at Huntington Beach 5.5 NOISE Draft Recirculated Environmental Impact Report the ambient noise level without project is between 60 — 6`5 dBA, some individuals may notice an increase to the ambient noise level of greater than three dBA. Changes in community noise levels by one dBA or more in areas where the ambient noise level is greater than 65 dBA is considered a significant impact because the increase would contribute to an existing noise deficiency. Table 5.5-6 SIGNIFICANCE OF CHANGES IN CUMULATIVE NOISE EXPOSURE Ambient Noise LevehWithout Project: Significant Impact+Assumed to Occur if the v Ldn orCNEL Pro`'ect Increases"rnbienf=Noise:f evels"ti <60 dBA +5.0 dBA or more 60-65 dBA +3.0 dBA or more >65 dBA +1.0 dBA or more Sources: FICON,FHWA,and Caltrans as applied by Brown-Buntin Associates,Inc.,1997. For a discussion of short-term, construction-related noise impacts, refer to Section 5.9, CONSTRUCTION RELATED IMPACTS. LONG-TERM STATIONARY SOURCES Proposed Desalination Facility Site The proposed project involves the implementation of a 50 mgd desalination facility on a site currently occupied by an existing fuel oil storage tank facility. The project site exists within an industrial area, with the HBGS and Pacific Holdings tank farm located in the project vicinity. The primary noise sources would be the feedwater pump area, water supply pumps, workshop and storage buildings, control room,transformers and power control centers.The pump systems would be the most significant noise source at the subject site. High flow, high-head pumps are typically driven by an electric motor and produce broadband noise without strong tonal components. This noise source is omnidirectional and continuous during facility operation. A total of 36 large electric water pumps are proposed on-site (33 operating continuously and three standby pumps), the largest of which would be utilized indoors. A.total of 12 400-horsepower pumps and 12 3,500 horsepower pumps would be operated indoors(reverse osmosis feed pumps and pretreatment transfer pumps), while four 250-horsepower pumps and five 500-horsepower pumps would be operated outdoors (seawater intake pumps,and product water transfer pumps). All indoor pumps would be fully enclosed within the proposed reverse osmosis building. The amount of noise radiated from the wall surfaces and ventilation system of any given pump housing is controllable over a reasonably wide range. The predicted noise levels of the combined indoor and combined outdoor pump systems is illustrated in Table 5.5-7,PREDICTED PUMP SYSTEM NOISE LEVELS AT THREE FEET. These assumed noise levels are for steady-state,base load operations, and exclude startups, shutdowns, and off-normal or emergency conditions. By accounting for standard attenuation from the pump housing components and the reverse osmosis building, the combined sound levels of the pretreatment transfer and reverse osmosis pumps would be reduced by 20 dBA.' Additionally, the outdoor intake and product water pumps would be enclosed in underground vaults. Thus, noise emanating from these devices would be negligible. Thus, the major source of noise from the project site would be random incident noise (i.e., maintenance activities, worker activities) and noise from the reverse osmosis building. Assuming a worst case scenario of all of the pumps operating at full capacity within the reverse ANSI S1.31, Precision Methods for the Determination of Sound Power Levels of Broadband Noise Sources in Reverberation Rooms. I City of Huntington Beach April 5, 2005 5.5-10 Seawater Desalination Project at Huntington Beach 5.8NOISE Draft Recirculated Environmental Impact Report osmosis building with standard attenuation, the combined sound level would be1OO.3dBAat the U edge of the building; ~^ Tab1e5'5-T ( / J ( PREDICTED PUMP SYSTEM NOISE LEVELS AT THREE FEET `~ Indoor Pumps(Pretreatment and Reverse Osmosis Pumps) Outdoor Pumps(Feedwater and Product Water Pumps) r# f Pums in Operation 4 F 0 5 0 105.3 dBA Notes- -Assumes overall sound Power(0)of 88 dBA at 3 feet. ssum 2-tAssumess overall sound Power(dB)of 98 dBA at 3 feet. 3-Assumes overall sound Power(0)of 98 dBA at 3 feet. - ssumes overall sound Power(dB)of 109 dBA at 3 feet. -Combined sound Level based on the following formula:dl3c 10 10910(10 A(dBA1/10)........+J0A(dBhV10)) Source:L.N.Miller,et.al.,Electric Power Plant Environmental Noise Guide.1984. The reverse osmosis building is the on-site facility that could potentiallyganara1e the most noise. The noise level at the nearest sensitive nemaotorbz the reverse o�nnoaio building xv�o oa|ou|o�ed \ / .' from each source using the Inverse Square Law of Noise Propagation. Bhofly, this formulation states that noise decreases by approximately six dBA with every doubling of the distance from the source. This methodology is an accurate assessment of noise propagation and is represented as: / Lu = L, -2O log (R. Rl) where: Le = Noise level at selected distance R2 from the source. L, = Noise level measured ata distance R, from the source. / \ Reverse Osmosis Building Noise � L, = 100.3dBA � R .� = thnaefeet R2= 1,000feet to nearest residential uses west of the subject site U �1 The nearest residential uses &o the reverse osmosis building are approximately 1.00O feet west. Based on the Inverse Square Law of Propagation, the noise levels at this distance would be 49.8 dBA. When accounting for existing intervening structures (power plant facilities, tanks, etc.) and L� features (bemna), the anticipated noise level of49.8dBA would be further reduced. The noise emissions mf all major faoi|ib/cmmponentaduringnonna|baae|oodopengbonoratvoioaUy /] limited by specifying equipment parameters to the vendors of the allowable sound power levels developed in the noise mode. The method for achieving the level required for each element and its physical details would be developed in pana||o|with the overall detailed design of the desalination / facility. In|ngenena|. all prepackaged components would be purchased under the condition that the noise limit stated in the technical specification would be met and guaranteed by the manufacturers. Special attention would be given to sources that tend bzbe tonal in nature to ensure that any tones are sufficiently attenuated. As shown above, noise levels from the desalination facility would not �- exceed 5O.OdBAat the nearest residential uses. |n addition, prior to construction of the reverse osmosis building, a detailed acoustical analysis would be performed for the projectboineunathat noise levels at the HE}GS property line do not exceed the Qb/'m Industrial noise standard of7O.O �~ City of Huntington Beach April 5. 2OO5 \ ( 5.�11 � Seawater Desalination Project at Huntington Beach 5.5 NOISE Draft Recirculated Environmental Impact Report dBA. Methods to further reduce noise levels from the reverse osmosis building include double walls, sound absorbing materials,acoustic barriers,sound control curtains,and sound baffles. Therefore, operational noise from the desalination facility would not have a significant impact in this regard. Mobile Sources 1 The proposed project would generate a nominal amount of noise resulting from mobile sources as a result of employee trips and truck-generated traffic. As stated previously,the proposed desalination facility would employ a total of approximately 18 people,with an average of five to seven people on- site per shift on weekdays. In addition,facility operation would require a maximum of four truck trips per day for solid waste disposal and chemical delivery. Noise generated by mobile sources as a result of the proposed desalination facility is anticipated to be less than significant. Off-Site Pipelines and Underground Pump Stations Proposed Pipeline Alignment The proposed product water pipelines would occur entirely underground. Upon completion of construction, these pipelines would not generate noise. As such, noise impacts due to long-term pipeline operations would not be significant. OC-44 Booster Pump Station The OC-44 pumping station is proposed to be located underground within an unincorporated area of the County of Orange, along the eastern border of the City of Newport Beach, approximately 1.5 miles south of the University of California, Irvine. The site is within an Orange County Resource Preservation Easement, but outside of the NCCP/HCP area,approximately 0.5-mile north of the San Joaquin Reservoir, where the East Orange County Feeder Number Two and the OC-44 transmission pipelines converge. The OC-44 underground booster pump station would include pumps, a surge tank to protect the distribution system from sudden pressure changes, telemetry equipment,appurtenances,and three diesel powered electrical generators for emergency back-up purposes. These generators would be Caterpillar Model 3516 units or similar equipment and would supply approximately seven megawatts of emergency power for adequate operation of the pump station (in regards to flow and pressure). These diesel-powered generators would require an 8,700- gallon diesel fuel storage tank(assuming a 24-hour emergency period),with a diameter of eight feet and a depth of 26 feet. The booster pump station would be placed entirely underground to maintain the natural character of the surrounding resource preservation easement. The pump that would be used is a vertical turbine pump. The pump would be less than 500 hp and produce noise levels of approximately 88 dBA at three feet from the source. As the booster pump would both be located underground and contain an adequate amount of acoustical shielding, it is unlikely to emit noise levels in excess of County of Orange codes.Additionally,as the pumps would be placed underground, the off-site underground booster pump station is not anticipated to adversely affect the NCCP/HCP area along the eastern border of the City of Newport Beach. Impacts in this regard are not anticipated to be significant. Coastal Junction Booster Pump Station A second underground booster pump station is proposed within the parking lot of St. Paul's Greek Orthodox Church within the City of Irvine, located at 4949 Alton Parkway. The underground pump station would be constructed within the north/northwestern portion of the church parking lot, in an area used for both parking and volleyball activities. The booster pumping station would be placed entirely underground to maintain the appearance and functionality of the existing parking lot. City of Huntington Beach April 5, 2005 5.5-12 Seawater Desalination Project at Huntington Beach 5.5 NOISE Draft Recirculated Environmental Impact Report The underground booster pump station would include pumps,telemetry equipment,appurtenances, and one diesel powered electrical generator for emergency back-up purposes. This generator would be a Caterpillar Model 3516 unit or similar equipment and would supply approximately seven megawatts of emergency power for adequate operation of the pump station (in regards to flow and pressure). This diesel-powered generator would require a 1,300 gallon diesel fuel storage tank (assuming a 24-hour emergency period), with a diameter of six feet and a depth of 15 feet. Similar to the OC-44 booster pump station,the pump that would be used is a vertical turbine pump. The pump would be less than 500 hp and produce noise levels of approximately 88 dBA at three feet from the source. As the booster pump would both be located underground and contain an adequate amount of acoustical shielding, it is unlikely to emit noise levels in excess of City of Irvine codes. Impacts in this regard are not anticipated to be significant. MITIGATION MEASURES LONG TERM STATIONARY NOISE SOURCES Proposed Desalination Facility Site N0I-1 Prior to the issuance of .any building or grading permits, the Applicant shall prepare an acoustical analysis report and appropriate plans, prepared under the supervision of a City- approved acoustical consultant, describing the stationary noise generation potential and noise mitigation measures (such as the installation of double walls, sound absorbing materials, acoustic barriers, sound control curtains, and sound baffles), if needed, which shall be included in the plans and specifications of the project. All stationary equipment shall be designed to insure that noise levels at the HBGS property line do not exceed the City's } Industrial noise standard of 70.0 dBA and will be subject to the approval of the City of C Huntington Beach. Off-Site Pipelines and Booster Pump Stations None required upon compliance with local noise standards. MOBILE SOURCES None required. UNAVOIDABLE SIGNIFICANT IMPACTS None have been identified. City of Huntington Beach April 5, 2005 5.5-13 L 5.6 PUBLIC SERVICES AND UTILITIES Public services include services such as fire protection, police protection, schools, libraries and parks. Utilities include wastewater, water, solid waste, electricity, gas, telephone, and cable. The purpose of this section is to establish existing conditions for each provider, identify potentially significant impacts and recommend mitigation measures to reduce the significance of such impacts. The primary question regarding utilities and services, relative to the CEQA process, is whether or not the project has any direct effect on the physical environment through impacts to existing facilities or the requirement to construct new facilities, particularly where such impacts would have an adverse impact on the environment. Information in this section is based on the City of Huntington Beach General Plan,City of Huntington Beach General Plan EIR, and correspondence from public service and utilities agencies (refer to Appendix J, CORRESPONDENCE). EXISTING CONDITIONS Fire Service The City of Huntington Beach Fire Department operates a total of eight fire stations within the City, including: Station 1 (Gothard Station), located at 18311 Gothard Street; Station 2 (Murdy Station), located at 16221 Gothard Street; ❖ Station 3 (Bushard Station), located at 19711 Bushard Street; ❖ Station 4 (Magnolia Station), located at 21441 Magnolia Avenue; ❖ Station 5 (Lake Station), located at 530 Lake Street; 44- Station 6 (Edwards Station), located at 18590 Edwards Street; ❖ Station 7 (Warner Station), located at 3831 Warner Avenue; and ❖ Station 8 (Heil Station), located at 5890 Heil Avenue. The fire stations serving the project vicinity are Stations 3, 4, and 5. The fire station nearest the project site is Station 4 (Paramedic Engine Company, staff of four), located at 21441 Magnolia Street approximately 0.5 miles from the subject site. Fire Station 3 (Paramedic Engine Company, staff of four) is located at 19711 Bushard Street approximately three miles from the site. Station 5, situated approximately 2.5 miles from the project site, is composed of a Paramedic Engine Company (staff of four), 95-foot aerial ladder (staff of four), and one ambulance (staff of two Emergency Medical Technicians). The average response times to the project site are four minutes from Station 4 and six to seven minutes from Stations 3 and 5. The current Insurance Services Office (ISO) rating of the site is ISO Class I.' Police Service ' The proposed project site is served by the City of Huntington Beach Police Department, which operates through one central police station and two smaller substations. Facilities and their locations are as follows: ❖ Police Headquarters, located at 2000 Main Street; ❖ Oakview Center Substation, located at 17483 Beach Boulevard, Suite B; and ❖ Downtown Substation, located at 204 Fifth Street; The Police Headquarters facility, located at 2000 Main Street, serves the entire City population of approximately 200,000 residents spread over 28 square miles. Average emergency response times ' Letter, Fire Marshall Eric Engberg,City of Huntington Beach Fire Department, December 6,2004. City of Huntington Beach April 5, 2005 5.6-1 Seawater Desalination Project at Huntington Beach 5.6 PUBLIC SERVICES AND UTILITIES Draft Recirculated Environmental Impact Report are approximately four minutes. Approximately two to four officers per shift serve the project site vicinity at any one time.2 The nearest police facility to the project is the Downtown Substation, situated approximately two miles northwest of the subject site. Schools The proposed project site is within the jurisdiction of the Huntington Beach Union High School District and the Huntington Beach City School District. The Huntington Beach Union High School District currently has a total of nine facilities within the Cities of Huntington Beach,Westminster,and Fountain Valley. The high school nearest the subject site is Edison High School, located approximately 0.8 miles to the northeast at 21400 Magnolia Avenue. Edison High School had an actual enrollment of 2,344 students for the fall of 2004.3 The Huntington Beach City School District has a total of 12 facilities within the City of Huntington Beach. Ten facilities are active schools,while two are currently inactive. The elementary schools nearest the proposed desalination project site are William E. Kettler Elementary School, located at 8750 Dorsett Drive,and John H. Eader Elementary School, located at 9291 Banning Avenue. Both schools are situated approximately 1.5 miles from the desalination facility site. Also in the project vicinity is Isaac Sowers Middle School, located approximately two miles from the desalination facility site at 9300 Indianapolis Avenue. William E. Kettler Elementary has an enrollment of 434 students, John H. Eader Elementary has an enrollment of 563 students, and Isaac Sowers Middle has an enrollment of 1,257 students.4 Libraries n- The Huntington Beach Library System consists of five facilities, including: Huntington Central Library and Cultural Center, located at 7111 Talbert Avenue; ❖ Graham Branch Library, located at 15882 Graham Street; ❖ Oakview Branch Library, located at 17251 Oak Lane; ❖ Banning Branch Library, located at 9281 Banning Avenue; and ❖ Main Street Branch Library, located at 525 Main Street. The Banning Branch Library serves the project vicinity and is located approximately two miles northwest of the subject site. The Banning Branch Library is a small facility and is approximately 2,400 square feet in size. This facility has on average 214 visitors per day and holds 24,197 volumes.5 Roadway Maintenance The City of Huntington Beach Public Works Department provides roadway maintenance to the City of Huntington Beach. The Department performs regular maintenance on City-owned roadways in the form of re-paving, pothole/curb repairs,and striping,as well as roadway widenings,expansions, and improvements. The City of Huntington Beach Public Works Department recently conditioned the widening of both Newland Street(located west of the subject site)and Edison Avenue(situated north of the subject site). The applicant would be required to complete improvements along the 1 southern side of Edison Avenue as a condition of approval for the project, while the City would be 2 Letter, Lieutenant Tom Donnelly,City of Huntington Beach Police Department, November 18,2004. 3 Letter, Ms. Patricia Koch, Huntington Beach Union High School District, November 28,2004. ° Letter, Mr. Richard Masters, Huntington Beach City School District, December4,2004. 5 City of Huntington Beach General Plan, Public Facilities and Public Services Element, May 13, 1996. 1L 11 City of Huntington Beach 5.6-2 April 5, 2005 l.-� ' Seawater Desalination Project at Huntington Beach 5.6 PUBLIC SERVICES AND UTILITIES Draft Recirculated Environmental Impact Report. .? responsible for street improvements along Newland Street with the applicant responsible for paying their fair share and completing the landscaping improvements adjacent to their site. For more information refer to the "IMPACTS"section below.6 Parks and Recreation The City of Huntington Beach contains 71 parks with a total area of 577.28 acres. The City's park system includes six mini-parks totaling 2.7 acres, 58 neighborhood parks totaling 157.39 acres, seven community parks totaling 143.28 acres,and two regional parks(Huntington Central Park and Blufftop Park)encompassing 376 acres. Other recreational opportunities within the City include two publicly owned golf courses, Huntington Beach City Gym and Pool, Oak View Center, various bikeways,and approximately two miles of equestrian trails. The City's coastal recreational facilities include the Huntington Beach Municipal Pier, various beach parks, recreational vehicle (RV) camping, and Huntington Harbor(a popular boating area).' The recreational facilities nearest the project site are Edison Community Center, Huntington State Beach,and Huntington City Beach,all of which are located within a radius of approximately 0.5 miles. It should also be noted that the City of Huntington Beach is planning to coordinate with the County of Orange to examine the feasibility of a landscaped riding/hiking trail along the Huntington Beach Channel, adjacent to the subject site. The proposed location and points of connection for the trail would be refined during the planning process for the trail. Wastewater �I The Orange County Sanitation District (OCSD) and the City of Huntington Beach Public Works Department, Utilities Division provides sanitation treatment and sewerage services for the City of Huntington Beach. Presently, 98 percent of the City is connected to the sewer system while the remainder uses septic tanks. The two wastewater treatment plants serving the City of Huntington Beach, Plant 1 and Plant 2, perform primary and secondary treatment procedures and are operated by the OCSD. OCSD Plant 2 would likely serve the proposed project. Within the City, the wastewater system is comprised of major trunk lines, smaller feeder lines, and lift stations. The OCSD has developed engineering plans for plant improvements anticipated to meet the needs of the City to the year 2050. The nearest City sewer line is an eight-inch line located north of the project site running along the southern side of the Huntington Beach Channel operated by OCFCD in an east-west direction? A 48-inch Orange County Sanitation District(OCSD)trunk line exists along Newland Street,an 84-inch line exists within Pacific Coast Highway, and a 78-inch line is situated within Magnolia Street. OCSD lines also traverse and exist adjacent to the various proposed pipeline alignment alternatives associated with the seawater desalination project.10 An additional private sewage system is located on the HBGS property,which flows by gravity to an on-site sewage ejector station and is conveyed to OCSD for treatment. s Letter,Terri Elliot/Duncan Lee, City of Huntington Beach Public Works Department, December 1,2004. City of Huntington Beach General Plan, Recreation and Community Services Element, May 13, 1996. e City of Huntington Beach General Plan, Utilities Element, May 13, 1996. s Letter, Duncan Lee, Principal Civil Engineer, City of Huntington Beach Public Works Department, December 1, 2004. 10 Map provided by Angie Anderson,Orange County Sanitation District,September 6,2001. City of Huntington Beach April 5, 2005 5.6-3 Seawater Desalination Project at Huntington Beach 5.6 PUBLIC SERVICES AND UTILITIES Draft Recirculated Environmental Impact Report Storm Water Drainage The OCFCD and the City of Huntington Beach Public Works Department operate the storm water drainage system within the City of Huntington Beach. The storm drainage system removes water runoff from streets and transports the runoff to the ocean. The OCFCD owns,operates,maintains, 1 and improves regional flood control facilities. The City of Huntington Beach owns and operates 15 storm drainage channel pumping stations,which pump the runoff water into the channels and to the ocean. No runoff from the project site is currently conveyed to the Pacific Ocean via City storm i. drainage facilities, as only OCFCD facilities provide service to the subject site. The closest storm channel near the project site is the OCFCD Huntington Beach storm channel (DO1)located to the north and east of the site, which confluences with the Talbert Channel (D02) downstream and eventually flows into the Pacific Ocean." Presently, the County and City are in the process of improving flood control facilities to accommodate higher levels of storm water.12 The OCFCD has recently improved the Huntington Beach Channel (adjacent to the subject site)in the vicinity of the project site to obtain 100-year regional flood protection.13 Water The Huntington Beach Utilities Division currently produces approximately 35,000 acre feet of potable water per year(afy), an average daily production of 48 cubic feet per second (cfs),and a maximum daily peak of 50 million gallons per day (mgd).14, 15 Currently, 66 percent of the City's water is supplied by groundwater wells located within the City, while 34 percent is imported from the Metropolitan Water District (MWD). Facilities within the City of Huntington Beach consist of 480 miles of water lines (ranging from 2-inch to 42-inch in diameter), water booster pumps, and five reservoirs with a combined capacity of 55 million gallons.16 Distribution piping in the area consists of looped 12-inch diameter asbestos cement(AC)pipe within Hamilton Avenue, Magnolia Street, and Newland Street. Pipelines within Pacific Coast Highway consist of 10-inch and 12-inch AC pipe. As part of a service agreement, the HBGS recently completed a major modification,which includes distributing 10-and 12-inch piping around the entire H BGS property and the proposed project as well as relocating their meter service from Pacific Coast Highway to Newland Street.17 The City is also in the process of siting a new water storage tank within a portion of the AES site(north of the subject site),to improve water service to the local water pressure zone. Reclaimed Water The City of Huntington Beach participated in the Green Acres project(GAP)in association with the OCSD and the Orange County Water District (OCWD). However, the City has only one Green 11 Letter,R.S.Bavan,Manager,County of Orange Resources and Department Management Department,December 30,2004. ' 12 City of Huntington Beach General Plan, Utilities Element, May 13, 1996. 13 Telephone conversation with Albric Ghokasian,OCFCD, November 23,2004. 14 Letter,Todd Broussard/Duncan Lee,Principal Civil Engineer,City of Huntington Beach Public Works Department, December 1,2004. 15 Note: Maximum daily peak demand was calculated as a worst-case scenario assuming peak water use plus two major fire events within the City. 16 City of Huntington Beach General Plan, Utilities Element, May 13, 1996. 17 Letter,Todd Broussard/Duncan Lee,Principal Civil Engineer,City of Huntington Beach Public Works Department, i December 1,2004. City of Huntington Beach April 5, 2005 5.6-4 Seawater Desalination Project at Huntington Beach 5.6 PUBLIC SERVICES AND UTILITIES Draft Recirculated Environmental Impact Report Acres project connection, which has not taken water for years. The OCSD produces secondary treated water for the OCW D, where the water is further treated and is distributed for industrial use and landscape irrigation for the Cities of Fountain Valley, Santa Ana, Costa Mesa, and Newport Beach. In addition,the Ground Water Replenishment System(GWRS)is a major new reclamation project currently being developed by the OCSD and OCWD. At the present time, no reclaimed water conveyance facilities are available at or near the subject site, and it is not anticipated that the proposed desalination project would require the use of reclaimed water.18 Solid Waste ' The County of Orange owns and operates three active landfills. Of the three active landfills, the Frank R. Bowerman Landfill in Irvine and the Alpha Olinda landfill in Brea are currently used in ' disposal of solid waste from the project site vicinity. The closest facility to the project is the Frank R. Bowerman landfill,which would I likely be the solid waste facility receiving waste from the proposed project site. Rainbow Disposal has been contracted by the City of Huntington Beach to provide solid waste collection services under a long-term contract. The City generates approximately 348,219 tons of solid waste per year, resulting from 52,220 tons of commercial waste, 155,625 tons of residential waste, and 140,374 tons of demolition/industrial waste.19 The City is responsible for meeting the Assembly Bill 939 (AB 939) mandate of 50% disposal reduction by the start of 2000, and for preparing AB 939 solid waste planning documents. Rainbow Disposal currently transports City solid waste to a transfer station located within the City and then to either Frank R. Bowerman Landfill or Alpha Olinda Landfill.20 The California Integrated Waste Management Board requires that all counties have an approved Countywide Integrated Waste Management Plan (CIWMP), which requires sufficient solid waste disposal capacity for at least 15 years. The Orange County landfill system has capacity in excess of 15 years. Consequently, it maybe assumed that adequate capacity for the project area is available for the foreseeable future. With regards to daily disposal limitations, the Frank R. Bowerman and Brea Olinda Landfills have been receiving refuse at rates near the maximum limit. As Orange County continues to develop, additional daily disposal demands upon County landfills may necessitate modifications to landfill permits, which would require separate discretionary review undertaken by the County of Orange. Electricity The Southern California Edison Company(SCE)currently provides electrical service to the City of Huntington Beach. Major facilities owned by SCE within the City include six substations, various transmission lines and switchyards(AES currently owns and operates a power plant within the City, located along Pacific Coast Highway west of Magnolia Street, adjacent to the project site). Currently, SCE service meets the City's demands for electricity.21 Gas The City of Huntington Beach receives natural gas service from the Southern California Gas Company. The Gas Company receives natural gas from Southern California, Northern California, and out of state suppliers. The Gas Company has no immediate plans to update the existing 1B Letter, Duncan Lee, Principal Civil Engineer, City of Huntington Beach Public Works Department, December 1, 2004. 19 City of Huntington Beach General Plan, Utilities Element, May 13, 1996. 20 Letter, Ms. Sandra Jacobs, Rainbow Disposal Company, Inc., November 24,2004. r 21 City of Huntington Beach General Plan, Utilities Element, May 13, 1996. City of Huntington Beach April 5, 2005 5.6-5 Seawater Desalination Project at Huntington Beach 5.6 PUBLIC SERVICES AND UTILITIES Draft Recirculated Environmental Impact Report equipment or to implement new technologies aside from the routine maintenance checks and replacements of deteriorating supply lines. The Gas Company is currently meeting present demands and can supply additional natural gas to the City, if required.22 Southern California Gas Company facilities within the project vicinity include pipelines along Newland Street(located west of the project site)and Edison Avenue and Hamilton Avenue(located north of the project site).Zs L Telephone and Cable Service Verizon provides telephone service to the project vicinity. According to data provided by Verizon, telephone facilities in the project vicinity include lines located along Newland Street(located west of the project site), Edison Avenue located north of the project site), and within HBGS property (located south of the project site). a Cable television service to the City of Huntington Beach is provided by Time Warner Communications. Existing facilities within the project vicinity are located along Newland Street,and are attached to existing SCE utility poles. There are no existing facilities within the proposed project boundaries.25 IMPACTS Significance Criteria Appendix G of the California Environmental Quality Act(CEQA)Guidelines contains the Initial Study j Environmental Checklist form used during preparation of the project Initial Study. The issues ) presented in the Initial Study Checklist have been utilized as thresholds of significance in this Section. Accordingly, a significant impact to public services would occur if the project would result in: ❖ Substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities,need for new or physically altered governmental facilities,the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: LJ • Fire protection; • Police protection; • Schools; • Parks; �I • Other public facilities. r-° ❖ An increase in the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the park would occur or be accelerated; 22 City of Huntington Beach General Plan, Utilities Element, May 13, 1996. 23 Letters, Mr. Robert Warth, Southern California Gas Company,July 2,2001 and November 19,2004. 24 Letter, Mr.Tom Solano,Verizon, December 2,2004. P- 25 Telephone conversation, Mr. Bill Jankowski,Time Warner Communications, December 2,2004. City of Huntington Beach April 5, 2005 5.6-6 Seawater Desalination Project at Huntington Beach 5.6 PUBLIC SERVICES AND UTILITIES Draft Recirculated Environmental Impact Report ❖ The inclusion of recreational facilities or require the construction or expansion of recreational. facilities which might have an adverse physical effect on the environment; ❖ An exceedance of wastewater treatment requirements of the applicable Regional Water Quality Control Board; ❖ The construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects; ❖ The construction of new storm water drainage facilities or expansion of existing facilities,the construction of which could cause significant environmental effects; ❖ Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed; 1 ❖ A determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project's projected demand in addition to the provider's existing commitments; ❖ Be served by a landfill with sufficient permitted capacity to accommodate the project's solid waste disposal needs; and/or ❖ Comply with federal, state, and local statues and regulations related to solid waste. Fire Service The project would comply with City of Huntington Beach Fire Department requirements, including the installation of fire sprinklers and fire hydrants. It is not anticipated that project implementation would result in the need for additional Fire Department facilities. The proposed project is not of the scope or nature to create a significant increase in demand for services requiring physical additions to the City of Huntington Beach Fire Department.2B In addition, the City of Huntington Beach Fire Department,through mutual aid and automatic aid agreements with Orange County and the cities of Westminster, Santa Ana, Newport Beach, Fountain Valley,and Costa Mesa can provide additional staff as needed. Adequate emergency access would be provided in accordance with City and County requirements. Impacts are not anticipated to be significant. Police Service The proposed project is not anticipated to create a significant increase in service calls to the project vicinity nor is it expected to create a need for additional police facilities within the City of Huntington Beach. No impacts are anticipated in this regard.27 1 Schools The proposed project involves the implementation of a seawater desalination facility within the ' southeastern portion of the City of Huntington Beach. The project does not propose housing or other student-generating uses. According to the Huntington Beach Union High School District,the project is anticipated to have negligible impacts on school facilities within the City of Huntington Beach, and is anticipated to have a student generation rate of .0000340242 per square foot. However, in consideration of A.B.2926,the Applicant would be required to pay a commercial fee of $0.36 per square foot for non-residential development within the Huntington Beach Union High School District, of which the High School District would receive 39 percent or$0.1404 per square 26 Telephone conversation,Fire Marshall Eric Engberg,City of Huntington Beach Fire Department,December 6,2004. 1 27 Letter, Lieutenant Tom Donnelly, City of Huntington Beach Police Department, November 18,2004. City of Huntington Beach April 5, 2005 5.6-7 Seawater Desalination Project at Huntington Beach 5.6 PUBLIC SERVICES AND UTILITIES Draft Recirculated Environmental Impact Report foot of the total fee.28 The Huntington Beach City School District would receive the remaining 61 percent($0.2196 per square foot)of the commercial fee,and does not anticipate that the proposed project would have significant student-generating impacts or require other assessment fees or mitigation measures. The project is not expected to generate the need for additional school facilities.29 { 1 It should be noted that the Huntington,Beach City School District is concerned that the proposed project may impact the health of its students that participate on the Dwyer and Sowers Middle School surf teams.30 These concerns are addressed in Section 5.10, OCEAN WATER QUALITY AND MARINE BIOLOGICAL RESOURCES. No significant impacts are anticipated in this regard. Libraries The proposed desalination project is not anticipated to have significant impacts on the City of Huntington Beach library system. Although the nearest libraryfacility to the project site(the Banning Branch Library)is small in size(approximately 1,200 square feet)the project is anticipated to have a negligible impact on the branch. The applicant would be required to pay standard library enrichment fees concurrent with building permit issuance. The Library Department has two development fees associated with commercial construction,which include: 1)the Library Development Fee,which is $0.04 per square foot; and 2) the Community Enrichment Library Fee, which is $0.15 per square Roadway Maintenance u As previously stated, both Newland Street and Edison Avenue have been conditioned to be improved. As a condition of approval by the City of Huntington Beach for the proposed project,the applicant would be required to complete improvements along the southern side of Edison Avenue (situated north of the subject site as shown in Exhibit 3-2, SITE VICINITY MAP). These improvements would consist of the dedication of 12 feet along the frontage of the existing Edison Avenue (for curb, gutter, paving, and street lighting improvements)for a total of approximately 600 linear feet. It should be noted that AES Huntington Beach, LLC would be responsible for dedication of property to the City for these improvements,as AES owns the entire southern frontage of Edison Avenue and would lease property to the applicant for the proposed project. However,the project applicant would be responsible for completing these roadway and landscaping improvements as a L) condition of approval for the project subsequent to property dedication. It should also be noted that street widening along Newland Street(west of the proposed project site)would be performed by the City,with separate entitlements and environmental evaluation. AES Huntington Beach, LLC would J dedicate 10 feet of right-of-way(to 50 feet east of centerline)along Newland Street and both AES and the project applicant would be required to pay their fair share of the cost. In addition, traffic impact fees as determined by the City of Huntington Beach would be collected upon project implementation in orderto offset any costs incurred for roadway widenings and intersection capacity 32 I t f improvements. Impacts in this regard are anticipated o be less than significant. L 28 Letter, Ms. Patricia Koch, Huntington Beach Union High School District, December 2004. 29 Letter, Mr.Richard Masters, Huntington Beach City School District, December 4,2004. 30 Letter, Mr. Richard Masters, Huntington Beach City School District, December 4,2004. 31 Letter, Mr. Ron Hayden, City of Huntington Beach Library Services Department, December 1,2004. 32 Letter,Todd Broussard/Duncan Lee,Principal Civil Engineer,City of Huntington Beach Public Works Department, L December 1,2004. City of Huntington Beach April 5, 2005 L5.6-8 Seawater Desalination Project at Huntington Beach 5.6 PUBLIC SERVICES AND UTILITIES Draft Recirculated Environmental Impact Report Parks and Recreation The recreational facilities nearest the project site are Edison Community Center, Huntington State Beach, and Huntington City Beach, all of which are located within a radius of approximately 0.5 miles. The proposed desalination project would be situated in an industrial area and would employ approximately 18 people, with five to seven people on duty during regular working hours Monday I through Friday, and a minimum of two people on duty during swing shifts, graveyard shifts, and weekends. The project is anticipated to have a negligible impact on parks and recreation facilities within the City of Huntington Beach. Impacts in this regard are not expected to be significant. ' Wastewater It is anticipated that either a new sewer line would need to be constructed to reach the existing 48- inch OCSD trunk line located along Newland Street,or the project would utilize the existing private sewer system on AES property. The proposed project would produce nominal amounts of domestic wastewater, as the facility would employ approximately 18 people,with five to seven on-site during weekdays and a minimum of two employees on-site during swing shifts, graveyard shifts, and weekends. However,desalination facility operation would require that used RO membrane cleaning first rinse solution is discharged into the local sanitary sewer for treatment at the OCSD regional wastewater treatment plant or the existing private sewer system on AES property. Approximately 500,000 gallons of used cleaning solution would be generated per month (90 percent rinse water and 10 percent cleaning solution). The OCSD would impose a commercial/industrial capital facility fee that is collected by the City of Huntington Beach and which the City retains five percent for collection purposes. This capital facility fee would offset any impact to the City and OCSD, and would be used to provide system improvements as necessary. As stated previously in Section 3.0,PROJECT DESCRIPTION,the accumulation of silts or scale on the RO membranes would require periodic cleaning to remove these foulants and extend membrane life. Normally cleaning frequency is twice per year. To clean the membranes, a chemical cleaning solution is circulated through the membranes. The reverse osmosis system trains would be cleaned using a combination of cleaning chemicals such as industrial soaps(e.g. sodium dodecylbenzene, which is frequently used in commercially available soaps and toothpaste) and weak solutions of acids and sodium hydroxide(refer to Table 5.10-11,REVERSE OSMOSIS MEMBRANE SOLUTION DISCHARGE VOLUMES). A portion of the waste cleaning solution from the washwater tank is proposed to be discharged into the local sanitary sewer for further treatment at the Orange County Sanitation District (OCSD) regional wastewater treatment facility. OCSD has indicated that its facilities are of adequate capacity to accommodate this waste cleaning solution.33 This solution would be transported using a dedicated on-site pump station with a capacity of 150 to 200 gallons per minute (gpm) and a new eight-inch sewer conveyance pipeline leading off-site to the existing 48-inch OCSD sewer pipeline located within Newland Avenue or a 54-inch OCSD line within Pacific Coast Highway. OCSD has 1 also indicated that the pH and flowrate of the washwater tank discharge would be acceptable, contingent upon the acquisition of a Sewer Connection Permit from the City of Huntington Beach and an Industrial Source Control Permit from the OCSD. It should be noted that the OCWD's Water Factory 21 used to discharge cleaning solution into the OCSD system,similar to the process the proposed desalination facility would utilize. Monitoring of waste cleaning solution water quality would be performed per the requirements of the OCSD for wastewater discharges to the sanitary sewer. The cleaning rinse water following the "first rinse" would be mixed with the RO facility concentrated seawater,treated waste filter backwash, and the HBGS facility discharge and sent to 33 Email between Nikolay Voutchkov,Poseidon Resources Corporation,and OCSD, May 29,2002. City of Huntington Beach April 5, 2005 5.6-9 Seawater Desalination Project at Huntington Beach 5.6 PUBLIC SERVICES AND UTILITIES Draft Recirculated Environmental Impact Report the ocean. This"second rinse"water stream would contain trace amounts of cleaning compounds and would be below detection limits for hazardous waste. Cleaning of the RO system would be staggered so that on average,two RO trains would be cleaned per month after the first year or so of operation, resulting in approximately 500,000 gallons of used cleaning solution generated per month. Impacts on local wastewater facilities are not anticipated to be significant. J An alternative to discharging the RO,membrane cleaning solution into the OCSD system is to discharge the solution into the Pacific Ocean via the HBGS outfall. Should this alternative be approved by the Santa Ana Regional Water Quality Control Board (SARWQCB), impacts to local wastewater facilities would be further minimized. Storm Water Drainage No City of Huntington Beach storm drainage facilities exist within the project vicinity. It is anticipated that the majority of the subject site would be composed of impervious surfaces,thereby increasing the potential amount of surface runoff. However, an on-site local storm water drainage system would be implemented as part of the desalination facility site. The desalination facility area and aboveground product water storage tank area would feature catch basins and storm water pump stations to provide adequate drainage. Storm water flows would first be directed to catch basins by gravity, and would then be directed to a storm water pump via gravity lines. The water would then be pumped to the 48-inch by-product concentrated seawater discharge line that ultimately connects to the HBGS outfall line. As alternative options,the desalination facility's on-site storm water system could discharge storm water to the HBGS on-site storm water system or the City of Huntington Beach local storm water system. The HBGS on-site storm water system conveys storm water to the Pacific Ocean via the HBGS outfall. The City of Huntington Beach's storm water system conveys storm water to the Pacific Ocean via existing facilities operated by the City and OCFCD. No storm water would be discharged into the adjacent Huntington Beach Channel. A Water Quality Management Plan (WQMP) would be prepared for the proposed project as required by the SARW QCB. Storm water would be treated prior to off-site discharge in order to minimize impacts from urban pollutants. One of two sedimentation methods would be utilized for treatment, including: Waste Filter Backwash Clarifiers: The proposed desalination facilitywould utilize clarifiers for the purpose of settling the waste stream generated during the backwash of the pretreatment filters. During rainy events,storm water would be combined with the waste filter backwash water and settled in the filter backwash clarifiers. This clarified water would then be combined with the desalination facility's concentrated seawater discharge and sent to the Pacific Ocean via the AES outfall. The waste filter backwash clarifiers would be oversized to accommodate the treatment of storm water. •♦• Sedimentation in Separate Clarifiers:As an alternative to combining on-site storm water with the waste filter backwash, storm water directed to on-site storm drains could be treated in separate sedimentation clarifiers for storm water treatment only. Subsequent to clarification,this water would be discharged via the AES outfall withi the desalination facility concentrated seawater discharge and AES cooling water. The most viable storm water treatment alternative would be selected during the design phase of the project, in close coordination with the City of Huntington Beach, RWQCB, and HBGS staff. The storm water facilities would be designed to comply with all applicable requirements of the City of Huntington Beach and the RWQCB. As a result of the proposed project,impacts are not anticipated � to be significant. City of Huntington Beach April 5, 2005 5.6-10 Seawater Desalination Project at Huntington Beach 5.6 PUBLIC SERVICES AND UTILITIES Draft Recirculated Environmental Impact Report Water Implementation of the proposed project would require new facilities to support operational uses (such as pipeline extensions,drinking fountains and restrooms),although these are not anticipated to create significant impacts. It is anticipated that normal domestic demand created by the proposed project can be provided with desalinated water generated on-site. However, should the project require potable water from the City, adequate backflow protection devices would be installed and maintained to ensure that no mixing of potable and subpotable waterwould occur. The Huntington Beach Utilities Division expects that impacts associated with the proposed project can be sufficiently 1 mitigated.34 With project implementation and appropriate mitigation,any potential impacts to water would be reduced to less than significant levels. It should also be noted that the proposed project would enhance drought resistance and provide emergency water supply to service areas on the coastal side.to the Newport Inglewood Fault. Refer to Section 5.11,PRODUCT WATER QUALITYfor a discussion of impacts in regards to water product quality. Reclaimed Water As stated above, the City of Huntington Beach is not currently participating in the GAP. The proposed project is not anticipated to require the use of reclaimed water or installation of reclaimed water facilities,as the project itself would be anew reclamation source. Asa result, impacts in this regard are not anticipated to be significant.35 Solid Waste rThe Frank R. Bowerman and Alpha Olinda Landfills are the two landfills that are presently used in the disposal of municipal solid waste from the project area. The landfills have sufficient permitted capacity to accommodate the proposed project's solid waste disposal needs. Rainbow Disposal Company is available to provide solid waste pick-up for the proposed project.36 In addition, the applicant would prepare a waste reduction plan for the construction and demolition (C&D) waste generated from this project. Impacts in this regard are anticipated to be less than significant. Electricity Based upon power consumption of 15 kilowatt hours per thousand gallons(4,887 kilowatt hours per acre-foot), the proposed 50 mgd (56,000 AF per year) desalination facility would require approximately 30 to 35 megawatts per hour to produce and distribute potable water. As such, the daily energy consumption of the facility is estimated to be between 720 to 840 megawatt hours per day. In order to take advantage of lower cost power pricing, the facility may utilize off-peak power to the maximum extent practicable by temporarily halting the production of potable water from the facility and instead pumping product water from the product water storage tank. No back-up electrical generators would be incorporated into the proposed project site, as emergency power/back-up power would be drawn from the HBGS auxiliary reserve bank. Back-up power for the off-site underground booster pump stations would be provided by underground generator sets using diesel fuel Maximum emissions from the back-up off-site generators are limited to 500 hours of operation. I34 35 Letter, Mr.Todd Broussard,City of Huntington Beach Public Works Department, P April 5, 2001. Letter,Duncan Lee, Principal Civil Engineer,City of Huntington Beach Public Works Department,December 1, 2004. 36 Letter, Ms.Sandra Jacobs, Rainbow Disposal Company, Inc., November 24,2004. 1 City of Huntington Beach April 5, 2005 5.6 11 Seawater Desalination Project at Huntington Beach 5.6 PUBLIC SERVICES AND UTILITIES Draft Recirculated Environmental Impact Report The proposed desalination facility's electrical power source would be controlled by a power marketing company, which, in consultation with the California Independent System Operator(Cal ISO), would obtain power from the HBGS and/or the California power market at the lowest cost possible. As such, a variety of base-, intermediate-and peak-load power generating facilities may produce power for the desalination facility. Typically, base-loaded power plant's (such as ��JJ California's two nuclear power plants and out-of-state coal-fired power plant's) as well as several large hydroelectric power dams are ,the primary source of off-peak power serving Southern California. Intermediate and peak load facilities are typically fossil fuel generating facilities (predominantly natural gas fired). Electric power generating plant's are distributed throughout the state, and the project's electrical demand would be met by dozens of power plant's connected to a regional power supply source,with many of those plants located outside of Southern California. SCE is prepared to install electrical distribution facilities to the subject site.37 As stated in Appendix Q, REPORT ON LOCAL AND REGIONAL POWER REQUIREMENTS AND GENERATION RESOURCES, the 35 megawatt project load would approximately equate to less than one percent of demand within Orange County or Southern California.38 Thus, impacts in this regard are anticipated to be less than significant(also refer to Section 5.4, AIR QUALITY) Gas The Southern California Gas Company can provide gas service to the proposed project via numerous gas mains surrounding the subject site.39 Project implementation would not result in any construction related impacts to the service area. No impacts are anticipated in this regard. Telephone and Cable Current) Verizon has telephone facilities located along Newland Street located west of the project Y� p 9 ( p 1 site), Edison Avenue (located north of the project site),and within HBGS property(located south of the project site). Verizon would be available to provide telephone service to the subject site from existing facilities.40 Cable television access to the City of Huntington Beach is provided by Time Warner Communications. Time Warner does not anticipate any impacts to its facilities as a result of project implementation. However, short-term impacts to Time Warner facilities may occur if utility poles along Newland Street are relocated.a1 Impacts are anticipated to be less than significant. It should also be noted that the installation of the 42-to 48-inch product water delivery pipeline within existing street right-of-way(ROW)would consume underground space for utilities along the streets the pipeline is proposed to occupy. However, it is anticipated that the project's water delivery pipeline would be buried deep enough to allow for the installation of smaller utilities (telephone, cable television, electricity,small diameter pipes)crossing above. In addition, preliminary analysis indicates that there is adequate space in Hamilton Avenue for the proposed pipeline and its utilities. Future projects requiring space for underground utilities along the proposed project's pipeline alignment may be required to use an alternative route where adequate space is available. 37 Telephone conversation, Ms. Spring Bowles, Southern California Edison, December 2,2004. 39 Local and Regional Electric Power Requirements and Generation Resources, Navigant,July 20,2004. (- 39 Letter, Mr. Robert Warth,The Gas Company, November 19,2004. 1 ao Letter, Mr.Tom Solano,Verizon, December 2,2004. 41 Telephone conversation, Mr. Bill Jankowski,Time Warner Communications, December 2,2004. �J... City of Huntington Beach April 5, 2005 5.6-12 Seawater Desalination Project at Huntington Beach 5.6 PUBLIC SERVICES AND UTILITIES Draft Recirculated Environmental Impact Report MITIGATION MEASURES Fire Service None required. Police Service None required. Schools PSU-1 Prior to the issuance of building permits, the applicant will be required to pay applicable school mitigation fees pursuant to State law. Libraries None required. iRoadway Maintenance PSU-2 The Applicant will be required to pay appropriate traffic impact fees as determined by the City of Huntington Beach Department of Public Works. Parks and Recreation None required. Wastewater PSU-3 The Applicant will be required to pay five percent of the OCSD connection fee to the City of Huntington Beach. PSU-4 All work within,over and under the OCFCD and County of Orange right-of-way should not commence until encroachment permits for the proposed work have been obtained from ' the County. Drainage Refer to Section 5.3, HYDROLOGYAND WATER QUALITY. 1 Water PSU-5 The Applicant will be required to pay appropriate fees for water service connections, installation, and meters. In addition, the City requires payment of a service fee for industrial customers. Reclaimed Water None required. ' City of Huntington Beach April 5, 2005 5.6-13 Seawater Desalination Project at Huntington Beach 5.6 PUBLIC SERVICES AND UTILITIES Draft Recirculated Environmental Impact Report Solid Waste PSU-6 The Applicant will coordinate with the City's recycling representative to ensure that the proposed project is in compliance with the City's waste reduction and recycling program. ?� PSU-7 Prior to the issuance of a grading permit, the Applicant will prepare a waste reduction �J plan for the generation of construction and operational waste from the proposed project. This plan will be submitted to the recycling coordinator from the City of Huntington Beach who will ensure that AB 939 requirements are properly addressed. Electricity None required. Gas None required. Telephone and Cable Service None required. UNAVOIDABLE SIGNIFICANT IMPACTS None have been identified. �I C City of Huntington Beach April 5, 2005 5.6-14 5.7 AESTHETICS/LIGHT & GLARE 1 Visual resources information in this section was compiled from site photographs and site surveys conducted by RBF Consulting on June 22, 2001 and December 1, 2004. Project impacts on the aesthetic character of the site from grading activities and building construction are analyzed and evaluated in relation to existing and surrounding site conditions. Consideration of public scenic views, introduction of new sources of light and glare, and compatibility of the proposed project with adjacent local aesthetic resources are included in this section. Construction-related impacts are addressed in Section 5.9, CONSTRUCTION RELATED IMPACTS. As the proposed off-site ' pipelines and underground pump station would be subsurface, there are no anticipated long-term aesthetic impacts. EXISTING CONDITIONS AESTHETICS On-Site The existing site's aesthetic quality can be characterized as low to non-existent,considering that the site is located within an industrial fuel oil storage tank area formerly used in conjunction with the AES Huntington Beach Generating Station (HBGS). The approximately eleven-acre site (seven acres for the desalination facility and four acres for the product water storage tank area)is currently developed with three fuel storage tanks. These fuel oil storage tanks exist on-site and are 205 feet in diameter and 40 feet in height. The exterior shell of all three tanks is composed of a non- reflective metal surface. Containment berms of approximately 10 tol5 feet in height surround the perimeter of each tank. The site is fully developed, with no unique vegetation or other visual resources (refer to Exhibit 3-2, SITE VICINITY MAP and Exhibit 5.7-1, DESALINATION FACILITY SITE PHOTOGRAPHS). Off-Site Views of the HBGS are available from numerous areas surrounding the project site, including: Huntington-By-The-Sea Mobile Home Park (located to the west); Beach Boulevard (located to the west); limited locations along Hamilton Avenue (located to the north); limited locations along Huntington State and Huntington City Beaches;and from the vicinity of the intersection of Magnolia Street and Pacific Coast Highway. However,since the proposed project is located behind the main HBGS structures and surrounded by 10-foot by 15-foot high earthen berms, views of the project from the surrounding area are limited. Surrounding adjacent land uses include the HBGS to the southwest, a wetland area to the southeast, the Orange County Flood Control District (OCFCD) flood channel to the east, a fuel oil storage tank to the north, and an electrical switchyard to the west. Additional surrounding land uses include Pacific Coast Highway to the south, the Pacific ' Holdings storage tank facility to the east, Ascon/Nesi Landfill to the northeast, commercial, industrial, recreational, and residential uses to the north, and Newland Street, Huntington-By-The- Sea Mobile Home Park, and Cabrillo Mobile Home Park to the west (refer to Exhibit 5.7-1, DESALINATION FACILITY SITE PHOTOGRAPHS). The Pacific Ocean, Huntington State Beach, and Huntington City Beach are located south of the subject site and can be characterized as high in aesthetic value. Uses surrounding the proposed pipeline route and underground pump stations vary depending upon the location, although uses generally consist of residential with some open space, commercial, school, recreational and medical (Fairview State Hospital in the City of Costa Mesa) uses(refer to Exhibit 5.7-2 PIPELINE ALIGNMENT PHOTOGRAPHS,and Exhibit 5.7-3 BOOSTER PUMP STATION SITE PHOTOGRAPHS). City of Huntington Beach April 5, 2005 5.7-1 Seawater Desalination Project at Huntington Beach 5.7 AESTHETICS/LIGHT &GLARE Draft Recirculated Environmental Impact Report - LIGHT AND GLARE On-Site The current uses on-site produce minimal light and glare due to the lack of high intensity lighting and absence of reflective surfaces on existing facilities. A minimal amount of nighttime security lighting currently exists on-site. Lighting fixtures are located sporadically throughout the project site, on a poles and mounted on the existing storage tanks. Off-Site Existing off-site sources of light and glare surrounding the project site, proposed pipeline alignments, and proposed underground pump station sites include street lighting, automobile headlights,and nighttime security lighting. Facility lighting and nighttime security lighting are utilized at the Edison Community Center and Edison High School situated northeast of the project site,while Beach Boulevard (a major arterial located west of the project site) produces light and glare as a result of heavy automobile traffic and street lighting. IMPACTS Significance thresholds in this Section are based on the CEQA Appendix G Environmental Checklist Form as indicated below. Significance Criteria A potentially significant impact to aesthetics would occur if the project caused one or more of the following to occur: ❖ Have a substantial adverse affect on a scenic vista; ❖ Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway; ❖ Substantially degrade the existing visual character or quality of the site and its surroundings; and/or ` ❖ Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area. The significance of an aesthetic impact, in terms of this project, can be determined by examining anticipated project effects from a number of different vantage points, including construction-related visual disruption, observer position, and changes to the existing visual character of the area. For a discussion of short-term, construction-related aesthetic impacts, refer to Section 5.9, CONSTRUCTION RELATED IMPACTS. LJ SITE CHARACTER The project site exists as part of a fuel oil storage tank facility within an industrial area. Prominent industrial facilities within the vicinity include the HBGS and the Pacific Holdings storage tankfacility. The existing project site can be described as low to non-existent in aesthetic value, as the existing fuel storage tanks are as large as 40 feet in height and 205 feet in diameter, and lack aesthetic or architectural enhancements. Currently, no aesthetic screening exists around the proposed project site. The proposed project would improve the aesthetic character of the site vicinity by replacing the existing dilapidated storage tanks with multiple buildings/structures featuring contemporary City of Huntington Beach April 5, 2005 j 5.7-2 J a� 5 f, 4 h M � i 4 n H ti, a 4 m if �bq�,� I & �» u F st yG> 4rl;� G , e w View of the desalination facility site in a northeasterly direction _ A southerly view of the desalination facility site from the from the HBGS. northwestern corner of the site. r � rr f 3 s a 1m, m _, �. •„ r .�.. _. � ^ - ;a- ^.-. �,_. ism: = '' #.'; >�.'r�. ��� a ;�a �.:' dw rt F � 8_ r' r.�w4 a,. v. View of the HBGS (situated southwest of the subject site) in an A westerly view of the desalination facility site across the A westerly view of the above ground product water storage easterly direction from Newland Street. Huntington Beach Channel. ©tank portion of the project site. f 1 NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH Desalination Facility Site Photographs CONSULTING 02/05•JN 10-101409.002 1 Exhibit 5.7-1 i AP i =✓"` A0 pv '21d l ME „.,I Will - R J q� r _ I � { j ' F I i I An easterly view of Hamilton Avenue, near the intersection A southerly view of Magnolia Street, between Hamilton Avenue of Hamilton Avenue and Magnolia Street (Primary and 13and Adams Avenue. Alternative Alignment). I I : lil I,t 11: F � I51eas I � I I I -;- _ r �- - An easterly view of the Primary Alignment at the Costa Mesa View of Victoria Street in a westerly direction, near the A® northeasterly.view of the Elden Avenue/Del Mar Avenue Country Club. intersection of Victoria Street and Monrovia Avenue (Alternative ©intersection, the point at which both alignment alternatives will t Alignment). connect to the 6C-44 line in the City of Costa Mesa. SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH Off-site Pipeline Alignment Photographs CONSU LTINO 02/05•A 10-101409.002 Exhibit 5.7-2 A northwesterly view of the proposed -41 e s booster pump station within an unincorporated area of the County of ' Orange (OC-44 pump station). t r 1 k G ' 3 A northerly view of an access road and existing purr station facilities located adjacent to the OC-44 pump station site. ' - View of the Coastal Junction pump station site, located within the parking , lot of St. Paul's Greek Orthodox Church. ur s" SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH Off-Site Underground Pump Station Photographs CONSULTING 02/05•JN10-101409,002 Exhibit 5.7-3 Seawater Desalination Project at Huntington Beach 5.7 AESTHETICS/LIGHT&GLARE Draft Recirculated Environmental Impact Report architectural design features and significant amounts of landscaping and aesthetic screening techniques in order to minimize any potential impacts of the project on the surrounding community. A visual simulation of the proposed project is provided in Exhibit 5.7-4, DESALINATION FACILITY ' VISUAL SIMULATION — MAGNOLIA STREET and Exhibit 5.7-5, DESALINATION FACILITY VISUAL SIMULATION—NEWLAND STREET. Although the proposed aboveground productwater storage tank(which would be approximately 250 feet in diameterwith a maximum height of 30 feet) ' would add to the aesthetic impact of the proposed project in regards to surrounding uses and local roadways,the tank would be constructed of non-glare producing materials. When considering that the tank (30 feet high above grade)would replace a dilapidated fuel oil storage tank(40 feet high) ' with a product water tank featuring contemporary design features, aesthetic screening, and landscaping, impacts in this regard would be considered less than significant. In addition, as the proposed off-site pipelines and underground pump station would be subsurface, there are no anticipated long-term aesthetic impacts associated with these improvements. ' Landscaping improvements would be focused primarily on the eastern, western, and northern portions of the subject site (refer to Exhibit 3-16, CONCEPTUAL LANDSCAPE MASTERPLAN). Landscaping selection would match that of the HBGS perimeter. Landscaping within the northern portion of the subject site would consist of Melaleuca quinquenervia (Cajeput Tree), Eucalyptus lehmannii (Lehmans Mallee), Callistemon viminalis (Weeping Bottle Brush Tree), turf, and ' ornamental drought/salt tolerant shrub and ground cover. Additional landscaping within the eastern portion of the project site would consist of a native wetlands planting area, situated east of the administrative building. Landscaping is also proposed along the western boundary of the product water tank site,along Newland Street,and would include evergreen street trees,accent palm trees, and shrub/groundcover plantings. The project would adhere to all City requirements with regard to building heights, landscaping, lighting, setbacks and lot coverage. Therefore, the project is considered to represent a positive impact relative to change in the existing on-site character. tLIGHT AND GLARE Existing on-site lighting is limited to sporadic light fixtures mounted on poles and on the existing fuel storage tanks. In addition, the site is void of reflective surfaces capable of producing significant amounts of glare. Additional light fixtures may be necessary for long-term operational use for both the desalination facility and product water storage tank,although any new lighting would be subject to City design standards and would utilize directional lighting techniques and low wattage bulbs (without compromising site safety or security) in order to direct light downwards and minimize light ' spillover. Project implementation may also result in a minimal amount of additional reflective surfaces on proposed structures,and from vehicles utilizing the facility. However,the resulting glare effects would be relatively minor when compared to existing levels of glare in the site vicinity. Additional lighting or glare-inducing surfaces would not occur as a result of water transmission pipeline or underground booster pump station implementation, as both the pipeline alignment and underground pump station would occur underground. This impact is considered less than significant with implementation of standard design practices and required mitigation. MITIGATION MEASURES ' SITE CHARACTER ALG-1 For areas visible by adjacent existing or proposed residential areas,exterior mechanical equipment shall be screened from view on all sides,and rooftop mechanical equipment shall be set back 15 feet from the exterior edges of the building. Equipment to be screened includes, but is not limited to, heating, air conditioning, refrigeration equipment, plumbing lines, duct-work and transformers. Said screening shall be architecturally compatible with the building in terms of materials and colors. If screening City of Huntington Beach April 5, 2005 5.7-6 Seawater Desalination Project at Huntington Beach 5.7 AESTHETICS/LIGHT&GLARE Draft Recirculated Environmental Impact Report is not designed specifically into the building, a rooftop mechanical equipment plan showing screening must be submitted for review and approval with the application for building permit(s). LIGHT AND GLARE ALG-2 If outdoor lighting is included, light intensity shall be limited to that necessary for adequate security and safety. All outside lighting shall be directed to prevent"spillage" onto adjacent properties and shall be shown on the site plan and elevations. UNAVOIDABLE SIGNIFICANT IMPACTS None have been identified. r-. r-- i City of Huntington Beach April 5, 2005 5.7-7 3 s rs 6^ Q ss A yw, § r Existing View Note:This visual s^uafwatil s computer techrakyfCAflMdVhd photo sintestionitotras#atette2dvnmsional engmee6nq plans an landscape ccxepts into a composite 3-0bnervotwl image.so as to depict tie conceptual � K oven?1 aP ea?ce of the prvrr.t�rcvn c+fs'^.ek:ations.The:Madsdepictednthis simulation are based on tuateal arcldleclural and landscape atchitactaalplxrs,77:apvrposeottMssimWationistotvalrMeg;adinpco;<ceptsasd aturaclaa,larrarrftg,lustapositeon at budding heights,and saflaa;lg of biding massr+p xi10 landscape.11 is agmad that design doles,materials, sldlp%t topoepatation of final ec'neaair.9 and constnchan dacvmecta., _ e I Proposed View 1- From Magnolia Street looping !North toward the Proposed Site Source:Poseidon Resources Corporation,November 2004. SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH Desalination Facility Visual Simulation - Magnolia Street CONSULTING 02A)5•JN10-101409.002 Exhibit 5.7-4 I a, d k: au,.,,x -::-=xi.>'_ ,±, ._:: -i#.-a. __..✓e:. ,.5,c ...-.. :,, xg„ _.,d u: k x d.".L..:ca ,.... ,.d. ._....- .S, ,.: t- :_ ir,rl'�«.,� u „ _.,m.:.,,a .. �,«..:.. ._,.x-..->,..- .,.._�,-•- - -: -,.. ... .,,. .... _.<, 'k;.,; - i.'4 '8 x, .___: ,... ...,,,... 1 1WPM yy i 6 S+. 1' 4 7 �a x � J i Fy. :,^.. I v 4�'�--•.,..,,,E-g z , w« : d a x« P^: r� P 4� .z x - m� y �6 .�� - � �. � „gin- ..�.�.� - ya .me.'._.�.. �•l- f,: t x r ' ti"" rr - 7 r' F1r Y'+ y.: Existing View T u r � r ..m Note:This visualsimulationutilzascom utcrtochnola CARD di tal hotosimulatior,to translate«c a P technology f 8 P 1 engineering plans and landscape concepts into a composite 3-dimansi3nal image,so as to depict the conceptual _x - m, -_- - =_ -' ':.-�= ,.. ., :,.- •x<m_ ,,,; ,-' Px., „, „„°, ; ,. overall appearance ofthe raectfromaff-s[telocations.The details depicted inthissimulationarebasedoncurrent r,ll k 4, archtecturalandlardscapearchitectufalplans.The pu,pose of his simulation is to evatuategrading concepts and harac r terracing,juxtaposition of building heights,and softening of building massing with landscape. It is c te. ux , P 9 P g 9 g 9 g recog nizathatdesrgndeias,mattrals,andcolarsshowrin thesesxhi its areconceptual andsAjecito prep aration of final engineering and construction documents. � I x x i 1 , k i Y • "View 2 - From Newland Overpass looking South toward the Proposed Site P 9 P , Source:Poseidon Resources Corporation,November 2004. I +I I SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH • Desalination FacilitylVisual Simulation - Newland Street CONSULTING 02/05•A 10-101409,002 Exhibit 5.7-5 < I t 5.8 HAZARDS & HAZARDOUS MATERIALS This section addresses potential impacts associated with the physical effects of the site due to the historic storage fuel oil within the boundaries of the subject site. Any potential site contamination, including soil and groundwater,is discussed within this section. Information contained in this section is based on the Huntington Beach Generating Station Phase 11 Environmental Site Assessment (prepared by CH2M HILL, November 27, 1996), the Site Investigation Report for Soil and Groundwater, Huntington Beach Generating Station, Huntington Beach, California (prepared by Woodward-Clyde, May, 1998), the Preliminary Hazardous Materials Assessment for the Southeast Coastal Redevelopment Plan (prepared by RBF Consulting, January 11, 2001), and the Environmental Assessment for the Southern California Edison Huntington Beach Fuel Oil Storage Tank Removal Project (prepared by Arthur D. Little, Inc., April 20, 2000). EXISTING CONDITIONS PROPOSED DESALINATION FACILITY SITE On-Site ' The subject site, formerly owned and operated by Southern California Edison (SCE), is currently developed with three fuel storage tanks(two at the desalination facility area and one at the product water storage tank area). These three fuel oil storage tanks (designated the"South", "West", and "East"tanks) are 205 feet in diameter and 40 feet in height. It is believed that the South and East tanks contain approximately 200,000 to 350,000 gallons of fuel oil, while the amount of fuel oil remaining in the West tank is unknown. The exact amounts of remaining fuel within all the storage tanks would not be known until the tanks are opened and inspected. Containment berms of 10-15 feet in height surround the perimeter of each tank. The fuel oil tanks are constructed of a thin,metal external shell and an internal insulated layer approximately two inches thick. This insulation material may contain asbestos, although the existence of asbestos would not be determined until the tanks are opened and inspected. In October and November, 1996, CH2M HILL advanced a total of 19 borings within the boundaries of the former fuel oil storage facility in which the subject site is located (four borings per fuel oil tank and three borings at the distillate fuel tank, located adjacent to the South tank). From the 19 borings, 35 soil samples and five groundwater samples were collected. Soil samples were collected from depths near the ground surface(0.5 feet below ground surface)and also at five-foot intervals to depths of approximately 10 feet below ground surface (bgs). Groundwater was encountered at depths of approximately seven to eight feet bgs within the subject site vicinity. 11 of the 35 soil samples and three of the five groundwater samples were taken surrounding the South, West, and East fuel oil storage tanks. All soil samples were analyzed for total petroleum hydrocarbons-diesel (TPH-D). TPH-D levels exceeded the Los Angeles Regional Water Quality Control Board (LARWQCB)' maximum soil screening level of 1,000 mg/kg,with samples as high as 65,000 mg/kg in the vicinity of the West tank and 5,200 mg/kg in the vicinity of the East tank, both at a depth of 0.5 feet bgs TPH-D was detected at concentrations of 0.51 mg/L in groundwater collected from the product water storage tank area. It is unknown whether this value exceeded LARWQCB thresholds for groundwater, as thresholds are established on a site-by-site basis.2 ' The Phase It Assessment,prepared by CH2M Hill(dated 11/27196),uses the LARWQCB Interim Site Assessment and Cleanup Guidebook(5/96), as a conservative screening criterion for evaluation of analytical results. z Yue Rong, Los Angeles Regional Water Quality Control Board,April 11,2002. City of Huntington Beach April 5, 2005 5.8-1 Seawater Desalination Project at Huntington Beach 5.8 HAZARDS AND HAZARDOUS MATERIALS Draft Recirculated Environmental Impact Report Surrounding Uses Additional soil and groundwater samples collected by CH2M HILL within the fuel oil storage facility but outside of project site boundaries were also analyzed for TPH-D and VOCs. TPH-D was detected above screening criteria near tanks located to the west and south of the subject site,with levels as high as 5,000 mg/kg. In addition, TPH-Diesel was detected at levels of 2.6 mg/L in groundwater samples taken from south of the project site, respectively. A soil and groundwater investigation was performed for the AES Huntington Beach Generating Station (HBGS)(Woodward-Clyde, May, 1998), located immediately southwest of the project site. It 1 was concluded that the screening criteria for petroleum impacted soils was not exceeded, while several metals, including antimony, arsenic, cadmium, cobalt, lead, mercury, selenium, silver, aluminum, iron, nickel, vanadium, copper, and molybdenum, exceeded average metal concentrations in soil for California. Numerous VOCs exceeded state and federal maximum contaminant levels (MCLs) in groundwater, while no SVOCs were detected above potential "threshold"concentrations in groundwater sampled at the HBGS. Various metals, including arsenic, thallium, beryllium, cadmium, chromium, copper, lead, mercury, nickel, silver, and selenium were also found to exceed existing MCLs. Other groundwater contaminants exceeding state and federal MCLs include fluoride, chloride, sulfate, and total dissolved solids (TDS). Two other petroleum-related storage tank facilities are situated within the project vicinity, including the Pacific Holdings and CENCO Marine Terminal facilities. The Pacific Holdings tank farm is located immediately east of the subject site, consisting of three fuel oil storage tanks, each with a capacity of 21 million gallons. A baseline tank study completed by SCE indicates that TPH levels of up to 7,500 mg/kg exist on-site, resulting from occasional spraying of oil on the soil for corrosion protection. The CENCO Marine Terminal,a former crude oil storage site,is located northwest of the project site. Prior to its demolition, the facility consisted of eight crude oil storage tanks. On-site hydrocarbon contamination was detected and remediation has been completed. The Ascon/Nesi Landfill, situated immediately east of the subject site, was utilized primarily as a Jn dumping ground for oil drilling wastes until its closure in 1984. Evidence of petroleum and hydrocarbon related contamination exists throughout the site primarily in the form of lagoons filled with oil drilling waste liquids. CH2M HILL performed groundwater sampling near the northern border of the proposed project site and the Ascon/Nesi Landfill. TPH-D and VOCs were not detected in the groundwater samples collected, downgradient of the Ascon/Nesi Landfill site. OFF-SITE PIPELINES AND UNDERGROUND PUMP STATIONS Proposed Pipeline Alignments n The proposed water delivery pipeline would be up to approximately ten miles in length, extending from the proposed desalination facility to the OC-44 water transmission line within the City of Costa Mesa,east of State Route 55(SR-55)at the intersection of Del Mar Avenue and Elden Avenue.The majority of the pipeline alignment would occur within existing public streets, easements, or other Y rights-of-way (ROW) in urbanized areas. Although precise pipeline alignments may be modified during final engineering analyses, the conceptual pipeline alignments are shown in Exhibit 3-3, CONCEPTUAL PIPELINE ALIGNMENTS. Portions of the pipeline alignments are proposed to be installed within areas of Edison Community Center(Huntington Beach), Costa Mesa Country Club (Costa Mesa), and Fairview State Hospital (Costa Mesa). No known areas of existing hazardous materials contamination are known to exist along the proposed pipeline alignments. City of Huntington Beach April 5, 2005 5.8-2 Seawater Desalination Project at Huntington Beach 5.8 HAZARDS AND HAZARDOUS MATERIALS Draft Recirculated Environmental Impact Report OC-44 Pump Station The OC-44 underground booster pump station is proposed to be located within an area of unincorporated Orange County,approximately 1.5 miles south of the University of California, Irvine., and 0.5 miles north of the San Joaquin Reservoir. The proposed OC-44 booster pump station site is surrounded by open space to the north, open space and residential to the east, two existing underground pump stations, open space, and residential to the west, and open space to the south. As this site is undeveloped, it is not expected to contain hazardous materials. Coastal Junction Pump Station The Coastal Junction underground booster pump station is proposed within the parking lot of St. Paul's Greek Orthodox Church within the City of Irvine, located at 4949 Alton Parkway. The underground pump station would be constructed within the north/northwestem portion of the church parking lot, in an area used for both parking and volleyball activities. The footprint of the proposed underground pump station would be approximately 100 feet by 100 feet, and would require a construction easement of 125 feet by 125 feet. The Coastal Junction pump station site is surrounded by the St. Paul's Church to the south,the Woodbridge Village Association to the west, an apartment complex to the east, and open space to the north. As this pump station site is developed as a parking lot adjacent to a church, hazardous materials are not anticipated to exist on- site. IMPACTS Significance thresholds in this section are based on the CEQA Appendix G Environmental Checklist r Form as indicated below: Significance Criteria Under the CEQA Guidelines, a potentially significant impact in regards to hazards and hazardous materials would occur if the project caused one or more of the following to occur: 1 ❖ Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials; ❖ Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment; ❖ Emit hazardous emissions or handle hazardous or acutely hazardous materials, s substances, or waste within one-quarter mile of an existing or proposed school; ❖ Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would create a significant hazard to the public or the environment; ❖ For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, the project would result in a safety hazard for people residing or working in the project area; ❖ For a project within the vicinity of a private airstrip,the project would result in a safety J hazard for people residing or working in the project area; ❖ Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan; and/or City of Huntington Beach April 5, 2005 5.8-3 Seawater Desalination Project at Huntington Beach 5.8 HAZARDS AND HAZARDOUS MATERIALS Draft Recirculated Environmental Impact Report ❖ Expose people or structures to a significant risk of loss, injury, or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands. For a discussion of short-term, hazards/hazardous materials impacts in regards to remediation, construction, and demolition, refer to Section 5.9, CONSTRUCTION-RELATED IMPACTS. LONG-TERM OPERATIONAL IMPACTS Proposed Desalination Facility Site Existing On-Site and Off-Site Contamination The proposed desalination project is not anticipated to result in long-term impacts in regards to Un existing on- and off-site soil and groundwater contamination. The project would facilitate the remediation of fuel contamination surrounding the fuel oil storage tanks within the boundaries of the proposed subject site consistent with RWQCB and Huntington Beach City standards. In addition, demolition of the fuel storage tanks would also involve the abatement of asbestos and lead-based paint, if detected. The majority of contaminants both on- and off-site (including the Ascon/Nesi Landfill) are petroleum-based, and are not considered toxic or acutely hazardous. The proposed project is expected to have a beneficial impact in regards to long-term hazards and hazardous materials. Proiect Operation The proposed project involves the implementation of a 50 mgd seawater desalination facility, and would involve the storage, handling,and use of hazardous materials. Hazardous materials would be utilized for three components of desalination facility operation: 1) periodic cleaning of the RO membranes which filter impurities from seawater; 2) treatment of potable product water; and 3) storage of diesel fuel for emergency backup electricity generators at the off-site underground pump stations. RO Membrane Cleaning Solution As stated previously within Section 3.0,PROJECT DESCRIPTION,the accumulation of silts or scale on the RO membranes causes fouling which reduces membrane performance. The membranes would be periodically cleaned to remove these foulants and extend membrane life. Normally cleaning frequency is twice per year. To clean the membranes, a chemical cleaning solution is circulated through the membranes. The reverse osmosis system trains r would be cleaned using a combination of cleaning chemicals such as industrial soaps (e.g. l sodium dodecylbenzene, which is frequently used in commercially available soaps and L toothpaste)and weak solutions of acids and sodium hydroxide.The cleaning process includes two steps: first, circulating a number of cleaning chemicals in a predetermined sequence through the membranes; and second, rinsing the cleaned membranes with clean water (permeate) to remove the waste cleaning solutions and prepare the membranes for normal operation. It should be noted that the actual cleaning chemicals used would be based on the observed operation and performance of the system once it is placed in operation. The cleaning solution is composed of the following chemicals: Citric acid,two percent solution:The Material Safety and Data Sheet(MSDS)for citric acid states that acute overexposure would cause eye/skin irritation, irritation of the respiratory tract if inhaled, and nausea, vomiting, cramps, and acidic irritation of mouth and throat if ingested. City of Huntington Beach April 5, 2005 5.8-4 Seawater Desalination Project at Huntington Beach 5.8 HAZARDS AND HAZARDOUS MATERIALS Draft Recirculated Environmental Impact Report Sodium hydroxide B, 0.1 percent solution: According to the MSDS for this material, acute exposure to sodium hydroxide may cause severe burns to exposed tissues (including the eyes), injury to the entire respiratory tract if inhaled, and severe injury to �( the digestive system if ingested. Sodium tripolyphosphate B, two percent solution: The MSDS for sodium �) tripolyphosphate indicates that acute overexposure to this material would cause minimal to moderate irritation to the eyes. Human industrial experience has not shown this chemical to be an inhalation hazard. Sodium dodecylbenzene B, 0.25 percent solution: According to the MSDS for this material, sodium dodecylbenzene would cause irritation to exposed tissues (including t the skin/eyes),and irritation to the respiratory or digestive systems, if inhaled or ingested, respectively. Sulfuric acid B,0.1 percent solution: The MSDS for sulfuric acid indicates that acute overexposure would result in burns to any exposed area such as the eyes, skin, and respiratory tract. �( The citric acid, sodium hydroxide, sodium tripolyphosphate, and sodium dodecylbenzene would be delivered to the subject site in 400-gallon plastic containers, and would be stored in the RO building within concrete enclosures. A drainage system would be provided for chemical evacuation in the event of an accidental spill. As these chemicals would not be used frequently, they would be delivered to the site on an as-needed basis, and no more than one container per chemical would typically be stored or used at one time. Storage for sulfuric acid is described below, under PRODUCT WATER TREATMENT MATERIALS. r Product Water Treatment Materials In addition to the RO membrane cleaning solution,a number of additional chemicals forwater treatment would be used, stored, and handled on-site (refer to Table 5.8-1, PRODUCT WATER TREATMENT CHEMICAL USAGE SUMMARY). A description of each chemical product water treatment is provided below: Sodium hypochlorite (chlorine): Chlorine would be delivered in liquid form as a 12% f� sodium hypochlorite solution. The liquid sodium hypochlorite would be stored in suitable tanks within an enclosed concrete containment structure with a 110-percent spill containment capability. The inner housing of the concrete containment structure would be coated for resistance to chemicals, and would be separated or divided from other chemicals to prevent mixing in the event of accidental spillage. Storage tanks would be high-density polyethylene (HDPE) or fiberglass-reinforced polyester(FRP). All piping, pumps, valves, and other ancillary equipment would be manufactured of materials compatible with this chemical. Generally, polyvinyl chloride (PVC) would be used for low-pressure piping,and lined Teflon piping would be used for high-pressure service. All metals, with the exception of titanium, silver, gold, and platinum would be avoided in pumps and pumping elements, as well as any other piece of equipment that can be expected to come in direct contact with the chlorine solution. No chlorine gas would be present on-site. According to the Material Safety Data Sheet (MSDS) for sodium hypochlorite, acute overexposure would result in strong irritation to the eyes, skin, and respiratory tract. Inhalation of fumes may cause pulmonary edema, while ingestion would cause burns to the mouth, digestive tract, and abdominal distress. City of Huntington Beach April 5, 2005 5.8-5 Seawater Desalination Project at Huntington Beach 5.8 HAZARDS AND HAZARDOUS MATERIALS Draft Recirculated Environmental Impact Report Table 5.8-1 PRODUCT WATER TREATMENT CHEMICAL USAGE SUMMARY $ d, Bulk ". Day Tank Storage Normal Chemical Solution Capacity Capacity"* .Chemical PurposeY: Concentratiori: s,,.(Ib/day) (gal/day)., (gallons) .(galIons)i I Sodium Prevent 12% 1,542 1,541 2,000 10,000 Hypochlorite Biological ]� Growth Ferric Sulfate Enhance Filter 70% 15,420 2,641 N/A 40,000 �I Performance Enhance Filter 0.5% 385 9,244 10,000 5,000 lbs. Polymer Performance Positive LSI to 92% 24,672 3,215 4,000 60,000 Sulfuric Acid Membranes Sodium Remove 20% 4,626 2,773 3,000 30,000 Bisulfate Chlorine II Carbon Dioxide Stabilize 100% 12,540 NA NA 38,000 4� (If required) Product Water Lime Stabilize 15% 11,676 9,333 10,000 200,000 (If required) Product Water Sodium Disinfection 12% 667 667 1,000 10,000 Hypochlorite Ammonia Disinfection 29% 206 95 100 1,000 Source:Poseidon Resources Corporation,October,2004. Bulk storage capacities are based on the amount of storage capacity necessary for two weeks of operation at proper design dosage rates. 'J� C^ Lime: Lime would be delivered in dry quicklime form and would be stored on-site in 50- ton silos. The silos would have a bag house to minimize the emission of fugitive dust particles during the loading process. The dry lime would be conveyed to a slaking L chamber where it would be mixed with water to produce lime slurry. The lime slurry would then be transported to a separate mixing/dilution tank. The lime slaking system would produce a 10-18 percent lime slurry. The materials of construction for storage tanks, conveyance systems, piping systems, and all ancillary equipment would be , compatible with the recommendation of the lime supplier and in compliance with all applicable City and state regulations. According to the MSDS for lime, this chemical poses an acute threat for skin and respiratory tract irritation and damage to mucous 1_ membranes of the upper respiratory tract. Carbon Dioxide: Carbon dioxide would be delivered to the facility in liquid pressurized form by truck and stored in two 50-ton pressurized bulk liquid storage tanks which would consist of a welded steel pressure vessel designed, constructed, and tested in accordance with the requirements of the American Society of Mechanical Engineers it (ASME)Boiler and Pressure Vessel Code.Although stored as a liquid,carbon dioxide is City of Huntington Beach April 5, 2005 r- 5.8-6 Seawater Desalination Project at Huntington Beach 5.8 HAZARDS AND HAZARDOUS MATERIALS Draft Recirculated Environmental Impact Report injected into the water stream as a vapor. No special alloy or plastic distribution piping is required for the carbon dioxide delivery system. The storage tanks would be double- walled vessels in which the outer walls would provide a secondary containment. The inner vessel wall would be made of high-strength carbon steel, while the outer vessel wall material would be aluminum or structural grade carbon steel. The tanks would be equipped with stainless steel piping, nozzles, valves and other fittings and would be designed for unconfined outdoor installation. According to the MSDS, carbon dioxide initially stimulates respiration and than causes respiratory depression. Inhalation of low concentrations (three to five percent)that may occur during accidental gas release has no known permanent harmful effects. Contact with the cold gas can cause freezing of exposed tissue. All forms of carbon dioxide are noncombustible. Ferric sulfate: Ferric sulfate or ferric chloride would be used as intake water coagulant. Ferric salts would be delivered and stored in liquid form. The coagulant would be a 70 percent concentration of ferric sulfate or ferric chloride solution. Storage a tanks shall be 9 fiberglass-reinforced polyester (FRP) or high-density cross-linked polyethylene (HDXLPE). All piping, pumps, valves, and other handling equipment would be �l manufactured, lined, and/or coated with Kynar7 vinylidene plastic, polyvinyl chloride, rubber, glass, ceramic materials, or other materials specifically manufactured for the intended service. All floors,walls and ancillary equipment subject to splashing would be \10 protected with corrosion-resistant coatings. On-site storage tanks would be placed within an enclosed concrete containment structure with a 110-percent spill containment capability. The inner housing of the concrete containment structure would be coated for ' resistance to chemicals, and would be separated or divided from other chemicals to prevent mixing in the event of accidental spillage. According to the MSDS for ferric sulfate,acute overexposure would result in irritation to the respiratory system if inhaled, burns,somnolence,diarrhea,tachycardia,shock,acidosis,and hematemesis if ingested, and irritation/corrosion to the eyes. Polymer: Polymer would be delivered and stored in the form of a dry powder. On average, 100 50-pound bags would be stored. To prepare the polymer for water treatment use, it would be mixed and aged in a batch tank. The polymer system would produce an output concentration of a maximum of 0.5 percent. The materials of construction for storage tanks,pumps,piping systems,and all ancillary equipment would be compatible with the recommendation of the polymer supplier. According to the MSDS for polymer, acute exposure would result in mild eye and skin irritation,while inhalation would cause irritation to the nose, eyes, and throat. Sulfuric Acid: Sulfuric acid would be delivered and stored in liquid form with a 20 percent concentration. The sulfuric acid would be stored in suitable tanks within an enclosed concrete containment structure with a 110-percent spill containment capability. The inner housing of the concrete containment structure would be coated for resistance to chemicals,and would be separated or divided from other chemicals to prevent mixing in the event of accidental spillage. Storage tanks would be manufactured of high-density polyethylene(HDPE). The materials of construction for pumps, piping systems, and all ancillary equipment would be iron, steel, polyvinyl chloride, or Viton for concentrated sulfuric acid, and glass, lead, or rubber for dilute sulfuric acid. According to the MSDS for sulfuric acid,acute overexposure would result in burns to any exposed area such as the eyes, skin, and respiratory tract. Sodium Bisulfite: Sodium bisulfite would be delivered and stored in liquid form, and contained in suitable tanks within an enclosed concrete containment structure with a is, 110-percent spill containment capability. The inner housing of the concrete containment City of Huntington Beach April 5, 2005 5.8-7 Seawater Desalination Project at Huntington Beach 5.8 HAZARDS AND HAZARDOUS MATERIALS Draft Recirculated Environmental Impact Report structure would be coated for resistance to chemicals, and would be separated or divided from other chemicals to prevent mixing in the event of accidental spillage. The 1 sodium bisulfate would be a 20 percent concentration solution. The materials of construction for storage tanks, pumps,piping systems,and all ancillary equipment would be in accordance with the recommendation of the chemical supplier. According to the MSDS for sodium bisulfite, acute overexposure would result in severe burns and irritation to the skin, eyes, and mucous membranes. Inhalation may cause respiratory discomfort, and ingestion would result in burns to the gastrointestinal system and possibly death. n Ammonia: Ammonia would be delivered and stored in liquid form,and would be stored J f in a 1,000 gallon tank with a 110-percent spill containment structure. The storage tank would be constructed of high-density polyethylene (HDPE) or fiberglass-reinforced r polyester (FRP). All piping, pumps, valves, and other ancillary equipment would be manufactured of materials compatible with the intended service. Generally, polyvinyl chloride (PVC)would be used for low-pressure conveyance piping, and lined Teflon for high-pressure conveyance piping. According to the MSDS for ammonia, acute overexposure would result in burns to the gastrointestinal tract, skin, eyes, mucous membranes, and respiratory tract. It should also be noted that feed pumps for sodium hypochlorite, ferric, sulfuric acid, and sodium ( bisulfite would be hydraulically actuated diaphragm-type or peristaltic type chemical metering pumps equipped with a variable frequency drive. The polymer pumps would be single stage, progressive cavity displacement pumps. Lime slurry would be conveyed to the application points with hose type positive displacement pumps. The project would incorporate numerous leak and spill containment measures to minimize the risk of upset to both on-site employees and surrounding uses, consistent with all Federal, State, County and City regulations. As stated previously, hazardous materials would be utilized for three components of desalination facility operation: 1)periodic cleaning of the RO membranes which filter impurities from seawater; 2) treatment of potable product water; and 3) storage of diesel fuel for emergency backup electricity generators at the off-site underground pump stations. All hazardous materials would be stored in concrete containment structures with a 110-percent spill containment capability. If necessary,the inner housing of the concrete containment structure would be coated for resistance to chemicals,and each structure would be separated or divided from other chemicals to prevent mixing in the case of accidental spillage. All storage tanks would be constructed of appropriate, non-reactive materials, compatible with the recommendations of the supplier of the hazardous material. In the event of an accidental liquid chemical spill, the chemical would be contained within the concrete containment structure and evacuated through an individual drainage system. The spilled ' chemical would then be pumped into hazardous waste containment trucks and transported off-site for disposal at an appropriate facility accepting such waste. This operation would be completed by a specialized contractor licensed in hazardous waste handling and disposal. Appropriate agencies, such as the City of Huntington Beach Fire and Police Departments, would also be contacted if necessary. It should also be noted that the existing containment berms along the northern and eastern boundaries of the proposed desalination site would further minimize the potential release of hazardous materials into the adjacent Huntington Beach Channel and wetlands. The chemical conveyance piping system connecting chemicals from their storage areas to their points of application would be protected from leaks utilizing one of the following leak protection measures: City of Huntington Beach April 5, 2005 5.8-8 Seawater Desalination Project at Huntington Beach 5.8 HAZARDS AND HAZARDOUS MATERIALS Draft Recirculated Environmental Impact,Report ❖ Use of piping with double containment walls to prevent potential chemical leaks from reaching the soil or groundwater; and ❖ Installation of chemical conveyance and feed pipelines in designated plastic or concrete trenches that would contain potential leaks and drain the leaking chemical(s)to a designated containment sump or tank,from where the chemical(s) would be evacuated and disposed of in compliance with all applicable federal,state, and local codes. On average, seven trucks per week can be expected to deliver chemicals to the proposed desalination project site (during business days, Monday through Friday), which is considered consistent and compatible with the site's designation as an industrial area. The transportation of hazardous materials to the desalination facility would comply with all Caltrans regulations. The facility would utilize registered haulers to further reduce the potential for accidental release or S� exposure of these hazardous materials to the environment and individuals during transport. The desalination facility operator would develop hazardous waste management and safety plans in accordance with City, Occupational Health and Safety Association (OSHA), and United States Environmental Protection Agency (EPA) requirements. In accordance with OSHA regulation 29 CFR 1910.119,operation of the proposed facility would require the preparation of a Process Safety Management Program (PSM), which is designed to prevent or minimize the consequences of catastrophic releases of toxic,reactive,flammable,or explosive chemicals. This PSM would provide the following preventative components: r - ❖ Employee participation plan; ❖ Process safety information; ❖ Process hazard analysis; ❖ Written operating procedures; ❖ Employee training requirements and written training programs; ❖ Inspection and maintenance program to document mechanical integrity; ❖ Preventative maintenance program; ❖ Contractor training requirements; ❖ Hot work cutting and welding permit procedures; ❖ Pre-startup safety review and management of change procedures; ❖ Compliance audit procedures; ❖ External emergency/non-emergency notification; ❖ Facilities training requirements; and ❖ Reportable quantities of on-site chemicals. > � The project would also be in compliance with EPA Risk Management Planning(RMP)Rule 40 CFR 68, which would require the facility operator to register the facility with the EPA prior to on-site storage of hazardous chemicals. For security purposes, the desalination facility would allow site access to authorized personnel only via a secured entry point with a 24-hour guard. Impacts in regards to the long-term operational use, storage, and transport of hazardous materials involved in desalination facility operation are not anticipated to be significant. Off-Site Pipeline Alignments and Underground Pump Stations Proposed Pipeline Alignments As stated above the proposed off-site pipeline alignments would occur adjacent to a variety of land p P P p 9 1 tY uses, primarily within existing street right-of-way and easements. No known areas of hazardous r materials exist along the proposed alignments. In addition, hazardous materials impacts due to City of Huntington Beach April 5, 2005 5.8-9 Seawater Desalination Project at Huntington Beach 5.8 HAZARDS AND HAZARDOUS MATERIALS Draft Recirculated Environmental Impact Report long-term operation of the pipelines are not anticipated to occur, as the only liquid proposed for conveyance is potable water. OC-44 Pump Station As stated previously in Section 3.0, PROJECT DESCRIPTION, two diesel-powered emergency backup electrical generators would be required for underground pump station implementation. Diesel fuel would be stored within an 8,700-gallon double walled tank with a diameter of eight feet and a height of 26 feet. The City of Irvine Fire Department (which provides service to the OC-44 pump station site) has no preference for either an aboveground or underground storage tank. However,an underground storage tank would be provided since the entire pump station vaultwould be located below grade, including the diesel generators. The storage tank would be located nearby but separate from the pump station vault and would feature a double-walled containment system with monitoring equipment to prevent and detect leakage. The tank would be contained within the surrounding soil and would supply diesel fuel to the generators (housed within the pump station vault)during power emergencies. Refilling of the tank would occur from the surface via filling ports, similar to the refilling process at a commercial gas station. The proposed 8,700-gallon diesel fuel storage tank would be placed entirely underground and would be double walled as a preventative measure for leaks and spills. The tank would be buried separate from the underground vault containing the pump station and diesel-fueled emergency back-up electrical generators. In addition, monitoring equipment would be provided to prevent and detect leakage. Because the diesel storage tank would be placed underground and adequate safety measures would be implemented, impacts in regards to the off-site use, storage, and transport of hazardous materials are not anticipated to be significant. Coastal Junction Pump Station The Coastal Junction pump station would also require the storage of diesel fuel for the operation of one emergency backup electrical generator. As only one backup electrical generator would be needed, diesel storage capacity would be 1,300 gallons. This diesel fuel would be stored in a �. similar manner as the OC-44 pump station, and the same safety precautions (double-walled containment system, leakage monitoring equipment) would be incorporated into pump station j design. Impacts in this regard are not anticipated to be significant. 11JJ MITIGATION MEASURES None required,other than project design implementation of existing regulations and requirements. UNAVOIDABLE SIGNIFICANT IMPACTS None have been identified. City of Huntington Beach April 5, 2005 5.8-10 5.9 CONSTRUCTION RELATED IMPACTS The purpose of this section is to discuss the short-term demolition, remediation, and construction related impacts of project implementation upon land uses adjacent to the proposed project site. This section examines possible short-term impacts with regards to hydrology and water quality,air,noise, ti aesthetics/light & glare, hazards and hazardous materials, and traffic. Information used in this section was obtained from the City of Huntington Beach General Plan (1996), City of Huntington Beach General Plan EIR (1995), the City's "Transportation System Needs Analysis 2000-2010" (September 12, 2000, approved by City Council October2, 2000), the Biological Constraints Survey for the Poseidon Seawater Desalination Plant Pump Station, Orange County, California (May 16, 2002), Historical/Archaeological Resources Survey Report, Poseidon Seawater Desalination Plant Pump Station Site (June 10, 2002), the Southeast Coastal Redevelopment Plan Program Environmental Impact Report(January 23, 2002), and the Paleontological Resources Assessment Report, Poseidon Seawater Desalination Plant Pump Station Site (June 10, 2002). EXISTING CONDITIONS PROPOSED DESALINATION FACILITY SITE On-Site Land Uses The approximately 11-acre (seven acres for the desalination facility and four acres for the product water tank) site is located within the City of Huntington Beach, south of Hamilton Avenue, north of Pacific Coast Highway,east of Newland Street,and west of Magnolia Street. The proposed project site consists of three fuel storage tanks formerly used in conjunction with the Huntington Beach Generating Station (HBGS). For additional information regarding existing on-site features, refer to Section 4.0, EXISTING CONDITIONS/ENVIRONMENTAL SETTING, Section 5.1, LAND USE/RELEVANT PLANNING, Exhibit 3-2,S/TE VICINITY MAP, Exhibit 3-3, CONCEPTUAL P/PELINEALIGNMENTS,Exhibit 3-4, OC-44 BOOSTER PUMP STATION LOCATION MAP, Exhibit 3-5, COASTAL JUNCTION BOOSTER PUMP STATION LOCATION MAP, and Exhibit 5.7-1, DESALINATION FACILITY SITE PHOTOGRAPHS. Adjacent Land Uses Surrounding adjacent land uses include the HBGS to the southwest, a wetland area to the southeast, the Orange County Flood Control District(OCFCD)flood channel to the east, a fuel oil storage tank to the north,and an electrical switchyard to the west. Additional surrounding land uses include Pacific Coast Highway to the south, the Pacific Holdings storage tank facility to the east, Ascon/Nesi Landfill to the northeast,commercial, industrial, recreational,and residential uses to the north, and Newland Street Huntington-By-The-Sea Mobile Home Park,and Cabrillo Mobile Home r Park to the west. The Huntington Beach Wetlands are situated southeast of the desalination site and occupy a 131- acre, 1.5 mile long area along the coast, bordered by Pacific Coast Highway to the southwest, and the Talbert and Santa Ana River Flood Control Channels to the north and southeast.' The wetlands are divided into two major components. To the southeast, the 17-acre Talbert Marsh opens to the ocean through a 100 foot-wide entrance adjacent to the mouth of the Santa Ana River.The Talbert Marsh is a recovering wetland area reintroduced to tidal influence on February 17, 1989.2 MEC, 1991. 2 Reish and Massey, 1990. City of Huntington Beach April 5, 2005 5.9-1 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS } Draft Recirculated Environmental Impact Report The second component of the Huntington Beach wetlands, separated from the Talbert Marsh by Brookhurst Street, includes 89 privately-owned acres abutting the edge of the southeast corner of the proposed project site. This acreage has limited tidal access, and water sources are primarily limited to rainfall, urban runoff,and groundwater seepage.3 Salinities are extremely high in the soils }� and seasonal ponds, water quality of the brackish water marsh is poor, and the area in general is �1 considered degraded.4 The remaining area of the Huntington Beach Wetlands includes almost 20 acres of open water channel of the Talbert Flood Control System. The privately-owned area of the Huntington Beach wetlands (abutting the edge of the southeast corner of the desalination facility site) is primarily a seasonally flooded estuarine intertidal habitat dominated by pickleweed, along with other plant species that can tolerate high soil salinities and seasonal saturation and drought, such as saltgrass and alkali heath.5 Many areas of the wetland are heavily disturbed and unvegetated. The back dune habitat along the Pacific Coast Highway supports a moderate number of species including introduced plant species.The dunes have been replanted with native plant species.The site functions as a seasonal wetland for some wildlife,while seasonal ponding in former tidal sloughs supports limited fish and invertebrate use. The wetland area to the southeast of the desalination facility site is characterized primarily as southern coastal salt marsh. Southern coastal salt marsh is known to occur in bays, lagoons, and estuaries along the coast. Vegetation within this area is high quality with a few disturbed patches due to human encroachment. Vegetation types known to existwithin southern coastal salt marsh in the vicinity of the project include:6 ❖ common woody pickleweed (Salicornia virginica); 1 ❖ alkali mallow (Malvella leprosa); ❖ alkali heath (Frankenia salina); ❖ curly dock (Rumex crispus); ❖ wild heliotrope (Heliotropum curassavicum); \ ❖ coastal saltgrass (Distichlis spicata); ❖ cocklebur(Xanthium strumarium); ❖ California encelia (Encelia californica); ❖ Alkali weed (Cressa truxillensis); and ❖ California marsh rosemary(Limonium californicum). Wildlife species known to exist within the project area include: ❖ Monarch butterfly(Danaus plexippus); !L ❖ Cooper's hawk (Accipiter cooperil); ❖ Sharp-shinned hawk (Accipiter striatus); ❖ Northern harrier(Circus cyaneus); ❖ White-tailed kite (Elanus leucurus); ❖ Merlin (Falco columbarius); ❖ American peregrine falcon (Falco peregrinus); ❖ Western snowy plover(Charadrius alexandrinus nivosus); ❖ Long-billed curlew (Numenius americanus); ❖ California gull (Lanus californicus); lr ❖ California least tern (Sterna antillarum browns); t ❖ Elegant tern (Sterna elegans); ❖ Loggerhead shrike (Lanius ludovicianus); and ❖ Belding's savannah sparrow (Passerculus sandwichensis beldingi). 3 MEC, 1991. 4 Coats and Josselyn 1990,CDFG 1982, cited in MEC, 1991. s MEC, 1991. s Southeast Coastal Redevelopment Plan Program EIR,January 23,2002. City of Huntington Beach April 5, 2005 5.9-2 Seawater Desalination Project at Huntington.Beach 5 9 _,CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report Desalination Facility Demolition, Remediation, and Construction Tank/Berm Demolition Implementation of the Seawater Desalination Project at Huntington Beach would begin with the demolition of on-site fuel oil storage tanks and the removal of the interior portions of the containment berms surrounding the tanks. A total of three storage tanks exist on-site,with a diameter of 205 feet and a height of 40 feet (the "South", "West', and "East" fuel oil storage tanks). The fuel oil tanks consist of a thin, corrugated metal external shell and an internal layer of insulation. The external metal shells would be collected and sold as scrap. All tanks are seated on either concrete footings or piles, which would also need to be removed as part of the tank demolition process. It is estimated that the South and East fuel oil tanks contain a total of 200,000 to 350,000 gallons of residual fuel oil remaining from former uses associated with the HBGS, while it is unknown how much fuel oil remains in the West tank. Precise amounts of remaining fuel oils would not be known until the tanks have been dismantled and inspected (however, for analysis within this section, a conservative assumption of 175,000 gallons per tank has been utilized). The contents of these tanks would either be transported to an appropriate industrial facility for reuse or disposed of at a suitable disposal site. Each fuel storage tank is completely surrounded by a 10-to 15-foot high berm utilized to contain any accidental spillage of fuel from the tanks. Implementation of the proposed desalination facility would require the removal of the berms along the southern and western boundaries of the site,as well as the berm separating the South tank from the East tank(it should be noted that the existing northern berm is outside of project boundaries). The berm along the eastern boundary of the site (adjacent to the Huntington Beach Channel) would be left in place, as would the berms surrounding the proposed product water storage tank, except for a small access area. It is estimated that approximately 2,000 cubic yards of soil contained within the berms would be hauled off-site. It should be noted that a City-approved grading plan,grading permit,and haul route would be required prior to any excavation, remediation, or construction activities. It is estimated that a total of 140 truck trips for 2,000 cubic yards of soil(14 cubic yard trucks)would be required. Refer to Table 5.9- 1, DEMOLITION PROCESS DETAILS, for more information. ` Tank demolition would most likely proceed in the following sequence: Removal of residual product in the fuel oil tanks; ' ❖ Clean the interior of the tanks; ❖ Removal of interior layer of insulation; v Dismantling and removal of external metal tank shell; ❖ Removal of concrete footings or piles; and ❖ Demolition and removal of containment berms. The tank demolition phase of the project would result in an approximate total of 510 truck trips, which include the following: ❖ 60 trips for the removal of 380,000 gallons of fuel oil (6,500 gallon trucks loaded at 6,333 gallons per load); ❖ 30 trips for 30 tons of storage tank insulation (one-ton trucks); ❖ 110 trips for 110 tons of external storage tank shell material (one-ton trucks); ❖ 170 trips for 2,000 cubic yards of concrete footings or piles (14 cubic yard trucks); and ❖ 140 trips for 2,000 cubic yards of containment berm soil (14 cubic yard trucks). Refer to Table 5.9-1, DEMOLITION PROCESS DETAILS, below. City of Huntington Beach April 5, 2005 5.9-3 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report Table 5.9-1 DEMOLITION PROCESS DETAILS otal Number�of Maximum Total Activity Truck.Loads/, ; --Number-of Activity I(Estimated Earth Export/Import Or Other: Length Construction Worker °. One-way: Material Quantity) (months).'-, Trips Truck,Tnps per Day, , Removal of Residual Fuel Remaining in the Tanks 1 60 30 (up to 380,000 gallons) Removal of Tank Insulation (20 tons of metal) 1 30 12 Removal of External Metal Tank Shell(100 tons of 1.5 110 28 � metal) Removal of Concrete Footings or Piles(2,000 CY) 1 170 20 Berms Demolition 1 140 40 (2,000 CY) Site Remediation Areas surrounding the fuel storage tanks on the existing project site have been found to contain contaminants in exceedance of Regional Water Quality Control Board (RWQCB) thresholds.7 It would not be known until after storage tank demolition if hydrocarbon contamination exists beneath the storage tanks. Prior to site grading, a Phase II hazardous materials evaluation and Remedial Action Plan (RAP)would be prepared to facilitate on-site remediation. However, such studies can only be prepared subsequent to storage tank demolition. Regardless, it is estimated that site remediation would require a total of 170 truck trips for 3,000 cubic yards of soil (14 cubic yard trucks). Desalination Facility Construction Construction of desalination facility components within project site boundaries would consist of a pretreatment filter structure, intake pump and pump station installations,reverse osmosis building, numerous pipelines, chemical storage/solids handling building, bulk chemical storage building, electrical substation building, various storage tanks, and an administration building. All buildings and structures on-site would be typical of water or wastewater plants, consisting of cast-in-place concrete and steel construction. All buildings on-site would be Type-II, non-rated. In addition, approximately 1,000 linear feet of pipeline would be installed to connect the desalination facility to r the HBGS intake and outfall facilities. An intake and discharge pipeline would be installed from theJ southern portion of the subject site in a southerly direction, turning west near the HBGS acid retention basin, and connecting to the outfall facilities at HBGS. Refer to Exhibit 3-17, DESALINATION FACILITY/HBGS COOLING WATER CONNECTION. Facility construction is anticipated to result in approximately 1,300 trips for 18,800 cubic yards of soil for initial/final site grading (assuming 14 cubic yard trucks). Refer to Table 5.9-2, SITE GRADING DETAILS,for more information. 7 Huntington Beach Generating Station Phase II Environmental Site Assessment. CH2M Hill, November 29, 1996. City of Huntington Beach April 5, 2005 5.9-4 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS 4 Draft Recirculated Environmental Impact:Report Table 5.9-2 SITE GRADING DETAILS Total Number of Maximum Total Activity Truck'Loads,/ Number of Activity I(Estimated Earth Export/import or Other Length-, Construction Worker One-way Material Quantity) (months) Trips Truck Trips per'Day Initial Site Grading (18,800 cubic yards) 2 1,300 30 Final Site Grading, Paving, and Landscaping (400 5 30 8 cubic yards) OFF-SITE PIPELINES AND UNDERGROUND PUMP STATIONS Proposed Pipeline Alignments As stated previously, implementation of the proposed project would require the installation of up to 10 miles of 42- to 48-inch force main to convey water in an easterly direction to its ultimate destination within the City of Costa Mesa, east of State Route 55 (SR-55)at the intersection of Del Mar Avenue and Elden Avenue. The majority of the pipeline alignment would occur within existing J public streets, easements, or other rights-of-way (ROW). Table 5.9-3, PIPELINE ALIGNMENT DETAILS, provides information regarding the lengths and characteristics of each pipeline alignment. Although precise pipeline alignments may be modified during final engineering analyses, the conceptual pipeline alignments are shown in Exhibit 3-3, CONCEPTUAL P/PELINEALIGNMENTS and described in Section 3.0, PROJECT DESCRIPTION. Additional information regarding the pipeline alignment alternatives is included in Appendix G, PRELIMINARY PIPELINE ASSESSMENT. Table 5.9-3 PIPELINE ALIGNMENT DETAILS Route Off Pavement`(ft`) Under Pav`ement;(ft)" Constructwns Primary Alignment 10,700 29,350 6 Alternative Alignment 0 30,000 6 As stated above, the pipeline alignment would require trenchless construction to cross waterways and roadways with a high sensitivity to traffic disturbance. The two methods under consideration are micro-tunneling or directional boring. Generally, micro-tunneling involves the excavation of two jacking and receiving pits,which are vertical excavations with shoring and bracing systems(one on each side of the waterway or roadway to be crossed). A micro-tunneling machine, equipped with either an auger or slurry material removing device, is lowered into the jacking pit and creates a tunnel connecting the jacking and receiving pits. The pipeline can then be installed within the underground tunnel. Horizontal directional drilling involves the drilling of a pilot hole at a prescribed angle from one end of the waterway/roadway to be crossed to the other utilizing a pilot drill string. Once the pilot hole is complete,the hole must be enlarged to a suitable diameter for the pipeline. This is accomplished by City of Huntington Beach 5.9-5 April 5, 2005 �, Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report "pre-reaming" the hole to an appropriate diameter. A reamer is attached to the drill string and is pulled through the pilot hole by a drilling rig. Large quantities of slurry are pumped into the hole to maintain the integrity of the hole and to flush out cuttings. Once the drilled hole is enlarged and the pipeline is prefabricated, a reamer is once again attached to the drill string, and the pipeline is connected behind the reamer via a swivel. The drilling rig then pulls the reamer and pipeline through the tunnel until surfacing at the opposite end,once again circulating high volumes of drilling slurry. 1_ For lengths of the pipeline not utilizing trenchless construction (the majority of the pipeline), open trench construction techniques would be utilized. For open trenching,the minimum coverage for a 42- to 48-inch pipe would be at least five to six feet with two feet of available workspace on both sides of the pipe. This would require deep trenches(approximately nine to 10 feet)with appropriate shoring. The required size of any access construction pit would be a minimum of 20 feet by 30 feet and 15 feet by 15 feet for receiving pits. Dewatering operations may be necessary, especially in areas close to the Pacific Ocean within the City of Huntington Beach. Including required lay-down area for supplies and equipment, a 30-foot easement may be required for trenching operations. Refer to Table 5.9-4, PIPELINE CONSTRUCTION DETAILS, for more information. Table 5.9-4 PIPELINE CONSTRUCTION DETAILS s Total Nu mberof .. :< ximum . Total Activity Truck Loads/ Number of . Activity I(Estimated Earth Exportllmport or Other Material length(months) Construction One-way , Quantity)' WorkerTrips Truck'Trips' perDay Crossing of Flood Control Channel at Newland(1,200 CY) 4 90 12 Crossing of Talbert Drainage Channel 3 90 12 (1,200 CY) Removal of 30-inch OCWD Pipe 1.5 10 8 (10 tons of pipe) Soil Remediation (1,600 CY) 2 115 16 Crossing Santa Ana River and Greenville-Banning (2,400 CY) 2 180 20 17 Crossing Harbor Boulevard at Fair 3 90 12 (1,200 CY) Crossing 55 Freeway (1,200 CY) 3 90 12 OC-44 Pump Station The off-site construction of an underground booster pump station would be required as part of the seawater desalination facility project in order to convey potable water from the subject site to southern Orange County. The pump station is proposed to be located entirely underground within an unincorporated area of the County of Orange, along the eastern border of the City of Newport Beach, approximately 1.5 miles south of the University of California, Irvine. The site is within the Orange County Resource Preservation Easement,approximately 0.5 miles north of the San Joaquin Reservoir, where the East Orange County Feeder Number Two and the OC-44 transmission a City of Huntington Beach April 5, 2005 5.9-6 IL Seawater Desalination Project at Huntington Beach' 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact:Report pipelines converge (the'proposed underground pump station would connect to the OC-44 pipeline). - The pump would be electrically powered and would be placed within an underground vault so as to avoid noise and aesthetic impacts to surrounding uses, which include residential and open space uses. The footprint of the proposed underground pump station would be approximately 110 feet wide by 110 feet long by 40 feet deep, and would include space for the pump station with wet well below.to separate rooms for the electrical generator and diesel-powered emergency backup generator. Also included as part of the underground booster pump station are telemetry equipment,appurtenances, and a surge tank. It is anticipated that the underground pump station would require the import or export of approximately 17,400 cubic yards of earthen material, requiring approximately 1,240 truck trips (14 cubic yard trucks). Refer to Table 5.9-5, OC —44 BOOSTER PUMP STATION CONSTRUCTION DETAILS, for more information. The construction process for the proposed underground booster pump station is expected to last approximately 18 months. Table 5.9-5 OC-44 BOOSTER PUMP STATION CONSTRUCTION DETAILS TotahNumberof Maximum Activi 1 Estimated Earth Ex ortllm ort Total Activity Length(months) Truck LoadsF Number of. ty ( P P or Other Material Quantity) .. Construction:Worker One-way Tnps Truck Trips -per Day Initial Site Grading (400 CY) 1 30 8 Site Excavation (16,000 CY) 3 1,240 40 Site Final Grading and paving and 3 70 20 ` Landscaping (1,000 CY) Construction of the proposed off-site underground booster pump station within an unincorporated area of the County of Orange may have impacts in regards to biological and cultural resources. The proposed pump station site is approximately 0.5 acres in size and is undeveloped and currently overgrown with dense native vegetation. The site is situated within a County-designated Resource Preservation Easement designated as a Natural Community Conservation Plan (N CCP) area. While development restrictions exist for the Easement, the underground pump station would be sited in an area where underground facilities are allowed (two underground pump stations exist adjacent to the proposed pump station site). Existing conditions for biological and cultural resources are described below. Biological Resources Vegetation The booster pump station site exists with dense riparian and upland vegetation types on-site. Riparian vegetation types on-site include mule fat scrub, wouldow scrub, freshwater marsh, and open water. Riparian species on-site include the following: ❖ mule fat (Baccharis salicifolia); ❖ arroyo wouldow (Sa/ix lasiolepis); ❖ Fremont cottonwood (Populus fremontil); City of Huntington Beach April 5, 2005 5.9-7 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report ❖ cattail (Typha sp.); ❖ reeds (Scirpus spp.); ❖ wild celery (Apiastrum angusifolium); ❖ western ragweed (Ambrosia psilotachya); ❖ prickly sow thistle (Sonchus aspen); and ❖ pampas grass (Cortaderia selloana). Upland vegetation types on-site include coastal sage scrub, California annual grassland, ruderal,ornamental,and developed. Upland species on-site include the following: ? ❖ California sunflower(Encelia californica); " v California sagebrush (Artemisia californica); ❖ coyote brush (Baccharis pilularis); 6• black sage (Salvia mellifera); ❖ white sage (Salvia apiana); ❖ monkey flower(Mimulus aurantiacus); ❖ poison oak (Toxicodendron diversilobum); ❖ deer weed (Lotus scoparius); ❖ Mexican elderberry(Sambucus mexicana); ❖ lemonadeberry(Rhus integrifolia); I ❖ coast prickly pear (Opuntia littoralis); ❖ California buckwheat(Eriogonum fasciculatum); ❖ California everlasting (Gnaphalium californicum); ❖ golden yarrow(Eriophyllum confertiflorum); ❖ black mustard (Brassica nigra); r ❖ telegraph weed (Heterotheca grandiflora); ❖ tocalote (Centaurea melitensis); ` ❖ non-native grasses (Avena and Bromus spp.); ❖ gum trees (Eucalyptus spp.); and ❖ fan palm (Washingtonia frlifera). Wildlifei Vegetation types within the boundaries of the proposed booster pump station site provide moderate to high quality habitat for native wildlife species, including birds, amphibians, reptiles, mammals, and fish. Species either observed or expected to T occur on-site include the following: ❖ red-tailed hawk (Buteo jamaicensis); ❖ Cooper's hawk (Accipiter coopen); ❖ red-shouldered hawk (Buteo lineatus); f- ❖ mourning dove (Zenaida macroura); California quail (Callipepla californica); ❖ American crow (Corvus brachyrhynchos); ❖ house finch (Carpodacus mexicanus); ❖ northern mockingbird (Mimus polyglottos); ❖ California thrasher(Toxostoma redivivum); ❖ common yellowthroat (Geothlypis trichas); coastal California gnatchatcher(Polioptila california californica); ❖ least Bell's vireo (Vireo bellii bellii); ❖ tree frog (Hyla regilla); ❖ African clawed frog (Xenopus laevis); ❖ western rattlesnake (Crotalus viridis); City of Huntington Beach April 5, 2005 5.9-8 Seawater Desalination Project at Huntington Beach .5.9 .CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report ❖ gopher snake (Pituophis melanoleucus); ❖ western fence lizard (Sceloporus occidentalis); side-blotched lizard (Uta stansburiana); ❖ alligator lizard (Elgaria multicarinata); ❖ San Diego horned lizard (Phyrnosoma coronatum blainvillei); ❖ northern red-diamond rattlesnake (Crota/us ruber Tuber); ❖ southwestern pond turtle (Clemmys marmorata pallida); ❖ opossum (Didelphis virginianus); ❖ house mouse (Mus musculus); v coyote (Canis latrans); d• raccoon (Procyon lotor); and ❖ mosquito fish (Gambusia sp.). Special Status Habitat Special status habitats are considered to be"depleted"by the California Department of Fish and Game (CDFG)and the County of Orange. Two special status habitats occur on or in the immediate vicinity of the subject site: riparian habitat (including mule fat scrub,wouldow scrub,freshwater marsh,and open water)and coastal sage scrub. In addition, riparian habitats may include wetlands,drainages,and"waters of the United States"which are protected under the jurisdiction of the U.S.Army Corps of Engineers and/or CDFG. It should also be noted that the pump station site is situated adjacent to, but outside of,a Natural Community Conservation Plan/Habitat Conservation Plan (NCCP/HCP) delineation zone, and the underground pump station would be subject to regulations as administered by the CDFG. Special Status Plant and Wildlife Species No federal-or state-listed threatened or endangered plant species are expected to occur within the boundaries of the proposed pump station site. However, several federal-and/or state-listed threatened or endangered wildlife species are known to occur in the subject site region, some of which are expected to occur on or in the immediate vicinity of the subject site. These include the coastal California gnatcatcher (federally-listed Threatened and state-listed Species of Special Concern), least Bell's vireo (federally- and state-listed Endangered), and southwestern pond turtle (federally-listed Species of Concern and state-listed Species of Special Concern). It should also be noted that the area has the potential to support raptor nesting habitat. A well-established red-tailed hawk nest was observed approximately 450 feet south of the subject site in a large gum tree. For a detailed discussion of existing biological resources within and surrounding the proposed booster pump station site, refer to Appendix L, UNDERGROUND BOOSTER PUMP STATION BIOLOGICAL CONSTRAINTS SURVEY. Cultural Resources Historical/Archaeological Resources No historical or archaeological resources are known to exist within the boundaries of the proposed booster pump station site. A total of 22 prehistoric archaeological sites are known to exist within a 0.5-mile radius of the subject site(none within or adjacent to the subject site),with eight having eligibility for listing in the National Register of Historic Places. In addition, historic maps indicate that the subject site vicinity appears to be City of Huntington Beach April 5, 2005 5.9-9 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report low in sensitivity for historic resources. No buildings,structures,objects,sites,features, or artifacts over 50 years of age exist on-site. Paleontological Resources No paleontological localities have been discovered within the boundaries of the proposed booster pump station site or within a one-mile radius. However, some localities have been found elsewhere in the same sedimentary units as those found on the subject site. Because the site is part of the Topanga Formation (containing sediments deposited during the middle Miocene period, highly sensitive for marine invertebrate and vertebrate fossils),there is potential for disturbance of fossil remains during earth-moving operations. No fossil remains are known to exist on the ground surface on or surrounding the subject site. For a detailed discussion of existing cultural resources within and surrounding the proposed booster pump station site,refer to Appendix M, UNDERGROUND BOOSTER PUMP STATION CULTURAL RESOURCES ASSESSMENT REPORTS. Coastal Junction Pump Station The Coastal Junction off-site underground booster pumping station would include pumps,telemetry equipment, appurtenances, and one diesel powered electrical generator for emergency back-up purposes. This generator would be a Caterpillar Model 3516 units or similar equipment and would supply approximately seven megawatts of emergency power for adequate operation of the pump station (in regards to flow and pressure). This diesel-powered generator would require a 1,300 gallon diesel fuel storage tank (assuming a 24-hour emergency period),with a diameter of six feet r and a depth of 15 feet. The booster pumping station, including the generator and diesel fuel storage 1 tank,would require a total footprint area of approximately 100'by 1 00'and would be placed entirely underground to maintain the appearance and functionality of the existing parking lot. Also refer to Table 5.9-6, COASTAL JUNCTION BOOSTER PUMP STATION CONSTRUCTION DETAILS. As the site is situated within a parking lot in an disturbed/urbanized area, no biological or cultural resources are anticipated to exist on-site. Table 5.9-6 � COASTAL JUNCTION BOOSTER PUMP STATION CONSTRUCTION DETAILS Activity!(Estimated E Total otal-Number o Maximum T f arth Activity Length(months) Truck Loads/ Number of - .Export/Import or Other Material o One=way Constructi n Quantity) Worker.Trips . �TruckTnps, T perDay Initial Site Grading (400 CY) 1 30 8 Site Excavation (16,000 CY) 3 1,240 40 Site Final Grading and paving and 3 70 20 Landscaping (1,000 CY) )� City of Huntington Beach April 5, 2005 5.9-10 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report PROJECT PHASING The demolition, remediation, and construction process of the proposed project would last approximately 24 months, including time necessary to acquire all required agreements,permits,and approvals. Project phasing would be divided into three categories described below: ' 1. On-Site Desalination Facility,Construction: This portion of the proposed project would last approximately 24 months, and would include such activities as on-site demolition, grading/excavation, construction of desalination facilities, landscaping, and facility startup/testing. Import and export of earthen materials would occur primarily during the first six months and last four months of this phase of the project. 2. Off-Site Product Water Transmission Pipeline Construction: This portion of the project would last approximately 21 months,and would start about three months after the beginning of on-site desalination facility construction. This phase would include such activities as pipeline installation, implementation of pipeline under waterways/major roadways, soil remediation, removal of pipeline, and facility startup/testing. Import and export of earthen materials would occur primarily during the middle 12 months of this phase. 3. Off-Site Product Water Underground Booster Pump Station Construction: This phase of the proposed project would last approximately 18 months,and would begin approximately six months subsequent to the commencement of on-site desalination facility construction. This portion of the project would include such activities as grading/excavation/paving,pump station construction, emergency power generator construction, landscaping, and facility startup/testing. Import and export of materials would occur mainly within the first six months and final six months of the phase. It should be noted that it is anticipated that all three phases would be implemented concurrently for the final 18 months of the proposed project. IMPACTS Significance Criteria Significance criteria for construction related impacts are provided within each impact category below. HYDROLOGY AND WATER QUALITY Excavation, grading, and backfillin associated with project implementation are anticipated to 9 9 p J p p generate erosive conditions that may include sediment laden storm run-off or dust. Pursuant to Appendix G of the Drainage Area Management Plan (DAMP) by the Orange County Stormwater Management Program,a National Pollution Discharge Elimination System(NPDES)Permit must be _ obtained from the Santa Ana Regional Water Quality Control Board(SARWQCB)for the demolition, remediation, and construction process. As part of the NPDES process, the project would also comply with the State of California general permit(including the submittal of a Notice of Intent to the SARWQCB) and would include the preparation of a Storm Water Pollution Prevention Plan (SWPPP). The SW PPP would outline the source control and/or treatment control BMPs that would avoid or mitigate runoff pollutants at the construction site to the "maximum extent practicable". Implementation of BMPs as found in the Orange County NPDES Stormwater ProgramDAMP, and the Standard Specifications for Public Works Construction "Greenbook" which include such measures as use of sand bags and temporary dam building may be applied to sufficiently reduce sediment laden storm run-off. Additionally, area watering and limiting excavation, backfilling and City of Huntington Beach April 5, 2005 5.9-11 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report grading activities to non-windy days would sufficiently control the amount of particulate matter that may migrate off-site. Therefore, this is not considered a significant impact with mitigation. In addition,any dewatering activities due to excavation at the proposed desalination facility site are not anticipated to have significant impacts in regards to hydrology and water quality. As stated previously, dewatering discharge would be directed to a desilting system, and would be sampled and tested periodically to ensure compliance with all NPDES regulations. Should contaminated groundwater be encountered, a remediation contractor would remediate the groundwater prior to 1 discharge into the sanitary sewer system or HBGS storm water system. The dewatering process would be a temporary procedure and would have no long-term impacts on groundwater quality in the project site vicinity. As no potable water supply or extraction wells exist within the vicinity of the subject site, no impacts to the potable groundwater supply would occur. Groundwater conditions would return to existing levels subsequent to the dewatering process, and no adverse impacts on the groundwater basin or seawater intrusion barrier are expected. J AIR QUALITY Note: Potential construction related air quality impacts of the proposed project have remained consistent with those described in the previously circulated EIR(2001). However,due to changes in regulatory standards since 2001, information has been added to this section to better describe the regulatory framework in the State and air basin, as well as additional impact analysis to demonstrate compliance with existing requirements. South Coast Air Quality Management District Thresholds Under CEQA,the South Coast Air Quality Management District(SCAQMD)is an expert commenting r agency on air quality and related matters within its jurisdiction or impacting its jurisdiction. Under the 1 Federal Clean Air Act (FCAA)the SCAQMD has adopted federal attainment plans for ozone and PM10. The SCAQMD reviews projects to ensure that they would not: 1) cause or contribute to any new violation of any air quality standard; 2) increase the frequency or severity of any existing violation of any air quality standard; or 3)delay timely attainment of any air quality standard or any required interim emission reductions or other milestones of any federal attainment plan. The SCAQMD CEQA Air Quality Analysis Guidance Handbook provides significance thresholds for construction activities of projects within the SCAQMD jurisdictional boundaries. Exceedance of the SCAQMD thresholds could result in a potentially significant impact. However, the lead agency , ultimately determines the thresholds of significance for impacts.8 If the project proposes development in excess of the established thresholds, as illustrated in Table 5.9-7, SCAQMD EMISSIONS THRESHOLDS, a significant air quality impact may occur and additional analysis is warranted to fully assess the significance of impacts. Table 5.9-7 SCAQMD EMISSIONS THRESHOLDS �r , PHASE ROG. �.eq �o.,`° Pollutant his day �- Construction 1 75 100 550 1 150 150 Source: SCAQMD, CEQA AQMD Air Quality Analysis Guidance Handbook, page 6-1,April 1993. 8 South Coast Air Quality Management District, CEQA Air Quality Handbook,April 1993. City of Huntington Beach April 5, 2005 5.9-12 Seawater Desalination Project at Huntington Beach' 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report Diesel Toxics Risk Factors Estimates of potencies and RELs are derived from experimental animal studies or from epidemiological studies of exposed workers or other populations. Uncertainty arises from the application of potency or REL values derived from this data to the general human population.There is debate as to the appropriate levels of risk assigned to diesel particulates since the U.S. Environmental Protection Agency(EPA)has not yet declared diesel particulate matter(DPM)s as a toxic air contaminant.The SCAQMD typically applies a risk level of one in a million as the de minimis risk level. However, this type of reporting is only applicable to large populations (such as entire air basins)where the sample group is large and the exposure time is long (which is not the case for typical project-level construction projects). Odor-based Thresholds Projects emanating objectionable odors near existing sensitive receptors or other land uses where people may congregate could constitute a significant air quality impact to existing uses. Also, residential or other sensitive receptor projects built for the intent of attracting people near existing odor sources could also cause a significant air quality impact. The SCAQMD suggests a threshold based on the distance of the odor source from people and complaint records for a facility or similar facility.The threshold would be more than one confirmed complaint per year averaged over three- year period, or three unconfirmed complaints per year averaged over a three-year period. Many of the air contaminants,which may be emitted at the proposed project,have odor thresholds based on empirical data.9These thresholds would be utilized to determine the potential to create objectionable odors (i.e. these pollutants would be treated as odor surrogates for comparison against modeled emission concentrations at the maximum point of impact). Methodologies The following models and guidelines are used as tools to create the analytical basis for the construction related impact analysis. The tools are discussed below. Note that Section 5.4, AIR QUALITY utilized the EMFAC2002 air quality model for long-term operational impacts, due to the project's minimal area source and vehicular related emissions. The construction process, which would generate substantially more mobile emissions, is modeled utilizing the Urbemis2002 model, which more accurately calculates mobile source impacts. Urbemis200210," Construction emissions are considered short-term impacts and are temporary in nature. URBEMIS2002 estimates construction related emission as if all construction were ongoing at the same time with all paving and architectural coatings applied in the last year. This analysis utilized the emission factors from URBEMIS2002 for the construction analysis. URBEMIS2002 operational emissions are comprised of two separate sources,area sources(i.e.emissions from space heating, landscape maintenance) and mobile sources. These emissions are calculated for the build out period and take into account future fleet mixes and emission controls. URBEMIS2002 was developed to provide meaningful analysis of both short and long term impacts, and to encourage mitigation measures during project planning. Discrete URBEMIS2002 analysis is limited to annual periods. URBEMIS2002 uses a simplified set of emission factors to estimate 9 Nagata,Measurement of Odor Threshold by Triangle Odor Bag Method,2002. 10 Jones and Stokes, Software User's Guide: URBEMIS2002 for Windows with Enhanced Construction Module, 2003. 11 Note: Unlike Section 5.4,AIR QUALITY(WhICh utilizes the EMFAC model),this section utilizes URBEMIS2002 to calculate construction related air emissions. EMFAC does not have the capability to calculate construction equipment emissions. Thus, URBEMIS2002 is the appropriate model for this analysis. City of Huntington Beach April 5, 2005 5.9-13 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report impacts separately for predetermined construction periods and for operational periods as independent events and does not factor in: small discrete periods of project overlap, incremental periods smaller than one year, individual build out rates for each particular element of construction, schedule utilization of individual pieces of equipment, pro-ration for occupancy rate, retrofit technology over the life of equipment, pollutant reactivity or pollutant transport. Where site specific or project specific data were available, URBEMIS2002 factors were modified to fit with the information (e.g. construction worker trips, demolition details, grading details, etc.). L_ Where little or no information was available for a project,default values were selected(in the case of this project, only the distance that construction workers would be commuting was set to the URBEMIS2002 default). For the cumulative analysis,air emissions that occur in the South Coast Air Basin (SCAB)were utilized. Screen3 For the purposes of diesel toxics analysis,construction vehicle pollutant emission generators would consist entirely of construction activities associated with rough-grading operations (which is the worst-case pollution emission scenario). The analysis methodology utilized in this report is based upon the SCAQMD CEQA Air Quality Handbook CEQA Handbook Guidelines for construction operations. Construction emissions were based upon the EPA AP-42 Report generation rates identified by the SCAQMD for the various classes of diesel construction equipment. A screening risk assessment of diesel-fired toxics from construction haul trucks was performed using the SCREEN3 dispersion model developed by the EPA's Office of Air Quality Planning and Standards. The SCREEN3 model uses a Gaussian plume dispersion algorithm that incorporates source-related and meteorological factors to estimate pollutant concentration from continuous sources. It is assumed that the pollutant does not undergo any chemical reactions,and that no other removal processes, such as wet or dry deposition, act on the plume during its transport from the source. Usingthe aforementioned concentrations obtained from the screening model, the diesel toxic risk 9 can be defined as the following: F . XEMFACxURF wind 70yearexposure Risk= Dilution where: Risk = is the excess cancer risk (probability in one-million); Fµ,;,,d= is the frequency of the wind blowing from the exhaust source to the receptor(the default value is 1.0); EMFAC = the exhaust particulate emission factor(the level from the screening model); URF70 year exposure is = the CARB unit risk probability factor (300 x 10-6, or 300 in a million cancer risk per µg/m3 of diesel combustion generated PM,o inhaled in a 70-year lifetime based upon the California Air Resources Board (CARB)CARB 1999 Staff Report from the Scientific Review Panel((SRP)]on Diesel Toxics); and, Dilution is=the atmospheric dilution ratio during source-to-receptor transport(the default value of 1.0 assumes no dilution) Given the above assumptions for wind frequency and atmospheric dilution ratio,and substituting the CARB recommended value for the unit risk probability factor gives the following expression: City of Huntington Beach April 5, 2005 5.9-14 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report 1 x EMFAC x 300x10-6 Risk= =300xl0-6 x EMFAC per person 1 Thus, the percentage of risk of cancer to any given person being exposed to a concentration of pollution equal to EMFAC (in µg/m) over a continuous period of 70-years would be: Risk(%)=(300x10-6 x EMFAC)x 100=300x10-4 x EMFAC per person Where it can be directly stated that a risk percentage of,say, 25%would indicate a 25% probability of inhaled cancer risk for the given level of exposure(EMFAC)if consumed continuously for a period of 70-years. A 50% probability would correspond to a 50:50 chance of inhaled cancer risk if consumed continuously for a period of 70 years, and so on. For the construction-related diesel-fired toxics analysis, an area-source consistent in dimensions with the proposed grading area is assumed.A simplified terrain model (which is consistent with the area surrounding the project site) with no building downwash corrections and a worst-case wind direction is utilized. Impacts Future construction of the project site would generate short-term air quality impacts during demolition, grading and construction operations. The short-term air quality analysis considers temporary impacts from the project. Construction activities would include: ❖ Clearing,grading,excavating and using heavy equipment or trucks creating large quantities of fugitive dust, and thus PM10; ❖ Heavy equipment required for grading and construction generates and emits diesel exhaust emissions; and ❖ The vehicles of commuting construction workers and trucks hauling equipment generate and emit exhaust emissions. Construction of the project has been divided into three distinct phases:proposed desalination facility site construction, proposed off-site pipeline alignment construction,and off-site underground pump station construction. Although the project has been divided in three different phases, all phases would occur concurrently,and therefore must be analyzed and compared to SCAQMD thresholds as a whole.12 As previously mentioned,the construction of the entire project is anticipated to take place within a period of 24 months (two years). The entire project would include site grading for an estimated total of eleven acres. Construction _ equipment used for grading includes graders,off-highway trucks,off-highway tractors and scrapers. Building and paving equipment includes cranes, construction trucks, tractors, pavers, paving equipment,excavators and tractors/loaders/backhoes. Exhaust emission factors for typical diesel- powered heavy equipment are based on the URBEMIS2002 program defaults. Exhaust emissions 1 would vary substantially from day to day. Numerous variables factored into estimating total construction emissions include: level of activity, length of construction period, number of pieces/types of equipment in use, site characteristics,weather conditions, number of construction personnel and the amount of materials to be transported on-site or off-site. Refer to Appendix B,AIR 12 Telephone conversation with Steve Smith, South Coast Air Quality Management District, November 17,2004. City of Huntington Beach April 5, 2005 5.9-15 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report QUALITY DATA, for a listing of mobile and stationary construction equipment included in these calculations. Computer model results are also included in Appendix B. Fugitive Dust Emissions Construction activities are a source of fugitive dust(PM10)emissions that may have a substantial, j temporary impact on local air quality. ,in addition, fugitive dust may be a nuisance to those living and working in the project vicinity. Fugitive dust emissions are associated with land clearing,ground L.: excavation, cut and fill operations, and truck travel on unpaved roadways (includes demolition activities). Dust emissions also vary substantially from day today,depending on the level of activity, the specific operations, and weather conditions. Fugitive dust from grading and construction is expected to be short-term and would cease following project completion. Additionally, most of this material is inert silicates, rather than the complex organic particulates released from combustion sources, which are more harmful to health. Dust (larger than 10 microns)generated by such activities usually becomes more of a local nuisance than a serious health problem. Of particular health concern is the amount of PM10 (particulate matter smaller than 10 microns)generated as a part of fugitive dust emissions. As previously discussed, PM10 poses a serious health hazard;alone or in combination with other pollutants. The SCAQMD regulates fugitive dust emissions through Rule 403,which aims to reduce the amount of particulate matter entrained in ambient air by requiring actions to prevent, reduce,or mitigate emissions. Such actions include watering during site grading, limiting the speed of construction vehicles, and minimizing the area of disturbance, among others. The URBEMIS2002 computer model calculates PM10 fugitive dust as part of the site grading emissions (refer to Table 5.9-8, CONSTRUCTION EMISSIONS).With implementation of standard construction practices and recommended mitigation measures regarding dust control techniques (i.e., daily watering), limitations on construction hours, and adherence to standard construction practices (requires watering for inactive and perimeter areas, track out requirements, etc.)fugitive dust impacts would be substantially reduced. In addition, the project would comply with the SCAQMD Rule 403 to reduce PM10 impacts. Impacts from PM10 fugitive dust would be less than significant. Construction Equipment and Worker Vehicle Exhaust 1 Exhaust emissions from construction activities include emissions associated with the transport of machinery and supplies to and from the on-site desalination facility, off-site product water pipeline locations and the underground booster pump stations. Emitted pollutants would include CO, ROG, NOX, SOX, and PM,o. As indicated within Table 5.9-8, CONSTRUCTION EMISSIONS construction activities would exceed the SCAQMD threshold for NOX.The project would result in approximately ^� 221,051 cubic yards of soil hauling attributed to grading and excavation from all three separate phases of the project. The export of excess soil would result in additional truck hauling trips,which increases NOXemissions. Construction equipment and worker vehicle exhaust emissions would be considered significant and unavoidable despite the implementation of standard construction practices and recommended mitigation measures requiring all construction equipment being maintained in proper tune, shutting down equipment when not in use for extended periods of time and utilizing electric equipment for construction whenever possible in lieu of fossil fuel-fired equipment. City of Huntington Beach April 5, 2005 5.9-16 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report Table 5.9-8 CONSTRUCTION EMISSIONS Emissions Source Pollutant ounds/da 4. ROG 'NO CO PM „SO . .. . <. �, z. �o. . x.. Year 1 On-site Desalination Facility 17.5 119.91 143.65 14.59 0.01 Off-Site Product Water Pipeline 17.4 117.67 140.12 5.35 0.01 Site Product Water Underground 17.6 116.84 146.02 5.57 0.01 Booster Pump Stations Construction Total Un-mitigated Emissions 52.5 353.26 429.79 25.51 0.03 SCAQMD Thresholds 75 100 550 150 150 Is Threshold Exceeded After NO YES NO NO NO Mitigation? Mitigated Emissions On-site Desalination Facilit 17.5 119.91 143.65 6.66 0.01 Off-Site Product Water Pipeline 17.4 117.67 142.11 4.35 0.00 Site Product Water Underground 17.6 116.84 146.02 4.78 0.01 Booster Pump Stations Construction SCAQMD Thresholds 75 100 550 150 150 Total Mitigated Emissions 52.5 353.26 429.79 15.79 0.03 Is Threshold Exceeded After NO YES NO NO NO Mitigation? Year 2 On-site Desalination Facility 22.64 149.24 181.90 5.73 0.00 Off-Site Product Water Pipeline 17.4 113.81 142.11 4.35 0.00 Site Product Water Underground 17.58 113.66 147.16 5.21 0.01 Booster Pump Stations Construction Total Un-mitigated Emissions 57.62 376.71 471.17 15.29 0.01 SCAQMD Thresholds 75 100 550 150 150 Is Threshold Exceeded After NO YES NO NO NO Mitigation? Mitigated Emissions On-site Desalination Facility 22.64 149.24 181.90 5.73 0.0 Off-Site Product Water Pipeline 17.44 113.81 142.11 4.35 0.0 Site Product Water Underground 17.58 113.66 147.16 4.42 0.01 Booster Pump Stations Construction Total Mitigated Emissions 57.62 376.71 471.17 14.5 0.01 SCAQMD Thresholds 75 100 550 150 150 Is Threshold Exceeded After NO YES I NO NO t NO Mitigation? CO=Carbon Monoxide ROG= Reactive Organic Gases PM10= Particulate Matter NOx= Nitrogen Oxides SOx=Oxides of Sulfur NOTES: 1. Emissions calculated using the URBEMIS2002 Computer Model as recommended by the SCAQMD. 2. The reduction/credits for construction emission mitigations are based on mitigations included in the UREBMIS 2002 computer model and as typically required by the SCAQMD. Mitigations include the following: proper maintenance of mobile and other construction equipment, replace ground cover in disturbed areas quickly, water exposed surfaces twice daily, cover stock piles with tarps, water all haul roads twice daily and reduce speed limitation on unpaved roads to 15 miles per hour. Refer to Appendix B, Air Quality Data, for assumptions used in this analysis, including quantified emissions reduction by mitigation measures. 1� City of Huntington Beach April 5, 2005 5.9-17 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report ROG Emissions In addition to gaseous and particulate emissions, the application of asphalt and surface { coatings creates ROG emissions, which are 03 precursors. In accordance with the methodology prescribed by the SCAQMD,the ROG emissions associated with paving have been quantified with the URBEMIS2002 model. All architectural coatings for proposed project structures would need to be in compliance with Regulation XI, Rule 1113 — Architectural Coating, listed in the SCAQMD Rules and Regulations.13 Rule 1113 provides specifications on painting practices as well as the ROG contents within paints used for within the District. It is anticipated that ROG emissions would be well below SCAQMD thresholds. Toxic Air Contaminants Diesel particulate matter is part of a complex mixture that makes up diesel exhaust. Diesel exhaust is commonly found throughout the environment and is estimated by the EPA's National Scale Assessment to contribute to human health risk. Diesel exhaust is composed of two phases,either gas or particle and both phases contribute to the risk.The gas phase is composed of many of the urban hazardous air pollutants, such as acetaldehyde, acrolein, benzene, 1,3-butadiene,formaldehyde and polycyclic aromatic hydrocarbons.The particle phase also has many different types of particles that can be classified by size or composition. The size of diesel particulates that are of greatest health concern are those in ,. the categories of fine, and ultra fine particles. The composition of these fine and ultra fine particles may be composed of elemental carbon with adsorbed compounds such as organic compounds,sulfate, nitrate, metals and other trace elements. Diesel exhaust is emitted from a broad range of diesel engines; the on road diesel engines of trucks, buses and cars and the off road diesel engines that include locomotives, marine vessels and heavy duty equipment. Health Risk Assessments(HRA)for Diesel Particulate Matter(DPM)are typically conducted for areas that would expose sensitive receptors to high concentrations of DPM over a long j period of time. Typically, per the California Office of Environmental Health Hazard -� Assessment(OEHHA)and California Air Pollution Control Officers Association (CAPCOA) guidelines, estimating cancer risk for DPM is not required for construction activities as theyI occur for a short period of time and therefore would not measurably increase cancer risk. l However, in order to provide a conservative analysis for construction impacts, a health risk screening analysis was performed using the EPA approved SCREEN3 model. J To be consistent with the approaches used for other toxic pollutants, a functional comparison of the risk probability per individual person exposed to construction contaminants would be examined. This approach has the advantage of not needing to quantify the population of the statistical group adjacent to the construction site as well as allowing the per-person risk to be expressed as a final percentage. Of course, for a large enough population sample (i.e., a million people) the results are the same as CARB's predictions. Construction vehicle pollutant emission generators would consist primarily of haul truck activities such as earthwork haulage, concrete delivery and other suppliers, graders and pavers, contractor vehicles, and ancillary operating equipment such as diesel-electric generators and lifts. Construction emissions utilized within the SCREEN3 model were taken from the URBMIS2002 construction outputs for the proposed project(refer to Table 5.9-8, CONSTRUCTION EMISSIONS). According to the construction schedule for the project,a majority of the demolition and grading would take place within the first year of construction, 13 South Coast Air Quality Management District,htti)://www.agmd.gov/ruies/reg/regl 1 tofc.htmi,November 10,2004. City of Huntington Beach April 5, 2005 5.9-18 �r Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report which would result in greater particulate matter emissions. Although all stable criteria pollutants are provided, it should be noted that for cancer-risk potential, only PM10 is the single contributing factor. Therefore, emissions during the first year of construction were utilized in the SCREEN3 analysis as a worst case scenario. In addition to PM,o, SCREEN3 also calculates predicted emissions for non-carcinogenic contaminants, including CO, NO,,, and SOX. As illustrated in Table 5.9-8, CONSTRUCTION EMISSIONS construction operations were found to generate daily pollutant levels of 429.79 pounds/day of CO, 353.26 pounds/day of NO,, 0.03 pounds/day of SOX, and 15.79 pounds/day of PM10. These emissions are assumed to occur over any given 24-hour day (thereby providing an upper bound on expected emission concentrations) and direct comparison with the California Ambient Air Quality Standards (CAAQS). The proposed project development has a working area of roughly 11 acres or 44,516 square-meters (36,422 m2). Based upon the on-site emission levels identified above, the aggregate emission rates for the various criteria pollutants in grams per second and grams per square-meter (m) per second (required as the input parameters for the SCREEN3 model) are given below in Table 5.9-9, PREDICTED PROJECT EMISSION RATES. This methodology essentially applies all of the diesel emissions over this working area and provides a worst-case assessment of the impacts to sensitive receptors. Table 5.9-9 PREDICTED PROJECT EMISSION RATES Criteria Datly Site Emission Rats f . Average Area`Emission R e ates '«s.P.ollutant'a.a,E,,n rams/second rams/m?/second ." CO 2.25 4.31 x 10 NO), 1.57 6.17 x 10 SOX 0.000157 4.31 x 10- PM,0 0.83 2.28 x 10- Notes: 1.Total averaging time is 24 hours x 60 minutes/hour x 60 seconds/minute=86,400 seconds per CAAQS standards. 2. Onepound-mass=453.592 grams The expected diesel-fired construction emission concentrations from the SCREEN3 model are shown in Table 5.9-10, SCREEN3 PREDICTED EMISSION CONCENTRATIONS. Based upon the model results,all criteria pollutants were below the recommended risk level with a PM10 risk probability of 0.34% per 70-year exposure duration. A less than significant impact is expected due to proposed construction operations. NOISE The proposed project would involve the remediation and demolition of existing fuel oil storage tanks, the construction of the proposed seawater desalination project,the installation of up to ten miles of pipeline within primarily within existing public streets,easements,or other rights-of-way(ROW),and the implementation of two off-site underground booster pump stations. The noise level for the construction of the seawater desalination facility would vary during the construction period, depending upon the construction phase. City of Huntington Beach April 5, 2005 5.9-19 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS U U Draft Recirculated Envi ental Impact Report i TABLE 5.9-10 | > SCREEN3 Predicted Emission ConcentrationsStaff Report from the Scientific Review Panel (SRP)on Diesel Toxics inhaled in a 70-year lifetime. c � NO 1. Diesel risk calculated using: Ris*(01.)=(300x10'x EWAQ x 100 300x10-4x EwAc, based upon CARB 1999 | 1 2. Conversion Factors (approximate): The demolition, remediation. and construction process of the proposed desalination facility would last approximately 24 months. Project phasing would be divided into three separate categories, composed of: 1)on-site desalination facility construction (lasting approximately 24 months);2)off- sitepnJduxtvvotertmonamiaaionpipe|ineoonstruobonUoabngeppuJximate|y21nnontha. beginning about three months after the commencement of on-site desalination faci|ib/��n������ion)'�nd3\off- site product water underground booster pump station construction(lasting approximately 18 months, beginning about 0months after the start mf construction for the on-site desalination faci|itv\. During ( | the project imp|ementsbonpnoneae'adiacentaenoitivereoeptorowou|dbmexpooedbooponadich' h noise levels and groundborne vibration associated with remediation, demolition and construction activities /oa o n��u|t�fpovvorkJo|a' a��-h�nmnnera. truck trips, pile-drivers, etc.). F ` ^ ' As stated above, sensitive receptors exist in the subject site vicinity, the nearest being residential uses approximately 5OO feet west of the desalination faci|itvaito. Theeeeeneibv� nam�p�mreany ' )j located within a primarily industrial area,and are typically exposed to noise generated bythe HBGS, industrial uses along Edison Avenue, and high levels ofautomobile traffic along Beach Boulevard, Pacific Coast Highway, and Magnolia Street. Various sensitive receptors exist along the two | alternative pipeline alignments, including residential areas,open space/recreational uses, medical ( � facilities and schools. Open space and residential uses are located adjacent to the proposed off- site underground pump stations located within unincorporated County ofOrange and the City of Irvine. The more intense remediation, demolition, and construction noise (including the driving of sheet pi|es\would occur for brief periods of typically two 10 four weeks. |n addition, the proposed project would require off-site import/export of soils oa part of the site grading process. Any off-site truck traffic associated with desalination project innp|emnentobonxvmu|duti|izatheexistingacoeaa | road located off of Newland Street. The loudest equipment tvpaeg�nmna||yo�onaUn� ataeiteduringe�ohphooeofconotructi�nane } ' � presented in Table 5 11 8EAN/�7��� [)E8�L8�477C)N �4(�/L/T� <���N8T7�U<�77��/V � 8� - . - EQUIPMENTNOISE LEVELS. The composite average or equivalent site noise level, representing noise from all equipment' is also presented in the table for each major activity. City of Huntington Beach April 5, 2005 - { � —' -' - / ~ � Seawater Desalination Project at Huntington Beach 8.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report '. 1� Table 5.9-11 ~~ SEAWATER DESALINATION FACILITY CONSTRUCTION EQUIPMENT NOISE LEVELS Facility Construction Track Mount Crane (1) 75 91.4 Pompo ud -- Wheel Mount Crane (1) 75 Flatbed Truck(2) 88 Derrick Crane (1) 88 Flatbed Truck(1) 88 Source:J.D. Barnes,et. al., Power Plant Construction Noise Guide, 1977. To calculate the noise level at a given distance from a noise eouroe. the noise levels are mathematically propagated using the Inverse Square Law ofNoise Propagation. Briefly, this formulation states that noise decreases by approximately 6 dBA with every doubling of the distance from the source. This methodology is represented as: Le = L, ' 20 log (R, Rl) Where: Le = Noise level at a selected distance R2 from the source. L, = Noise level measured at distance F{, from the source. Given the following values: Desalination Facility Construction mu,L, = 81.4 dBA (per Table 5.9711). R, = 50 ft. (distance from aquipmen1. Table 5.9-11). F{u= 1.00O ft. to nearest residential uses west of the subject site Pipeline Construction muxL, = 82.2 dBA (per Table 5.9-11\. R, = 50 ft. (distance from equipment, Table ��9-11). ` ' R2= 150ft. to nearest residential uses along pipeline alignment (approximate average) Applying the above Inverse Gquons Law formula, the construction noise |ave|a at residential uaoa adjacent to the Desalination Facility and pipeline alignment would be 85.4 dBA and 02.7 dBA respectively. Since this level of noise is higher than typical ambient environmental noise levels,the construction noise would likely be audible during traffic lull period |ava|o. Table 5.9-12. CONSTRUCTION NOISE EXEMPTION PERIODS outlines the hours that City mf Huntington Beach, City of Irvine, City ofCosta Mesa and the County ofOrange exempt construction noise. �� City of Huntington Beach April 5. 2OO5 Seawater Desalination Project et Huntington Beach 5.8 CONSTRUCTION RELATED IMPACTS Draft Recirculated E i ntal Impact Report -- Table 5'9-12 | ! U CONSTRUCTION NOISE EXEMPTION PERIODS City of Huntington Beach' 7 AM to 8 PM 7 AM to 8 PM City of Costa Mesa" 7 AM to 8 PM 8 AM to 6 PM City of Irvine' 7 AM to 7 PM 9 AM to 6 PM County of Orange 4 8 AM to 7 PM 8 AM to 7 PM 1—Per Section 8.40.090 of the City of Huntington Beach Municipal Code. Additionally,construction noise is prohibited on Sundays and Federal Holidays. 2—Per Section 13-279 of the City of Costa Mesa Municipal Code. Additionally,construction noise is prohibited on Sundays and Federal 3—Per Section 6-8-205 of the City of Irvine Municipal Code. Additionally,construction noise is prohibited on Sundays and Federal 4— er Section 4-6-7 of the County of Orange Code of Ordinances. Additionally,construction noise is prohibited on Sundays and Fede ral The xv�u|d �dh�r��o�h�abmv�Unl�restrictions reduce noise ! / '�-'---- '-^— � | impact to adjacent sensitive uses. With the incorporation of the time restriction,aa well asstandard -` control measures, construction noise impacts are considered less than significant.AJ|bodvtnaffio. including traffic associated with pipeline innp|ennentotion, would be subject to a buck and construction vehicle routing plan and would comply with all City/County noise regulations. |tmhou|d LJ also be noted that no significant noise na|o0ed innpao10 would occur at the {]C-44 underground booster pump station that would be located along the eastern border of the City of Newport Beach, ositia outside of the y���(�PYH��Parea. F`ne-oonatructionfocused bird aun/eyevvou|dbepa�onned. \ | and any potential construction noise impacts would be mitigated as required by applicable regulatory agencies. Construction impacts to biological resources are further discussed below in this section under BIOLOGICAL RESOURCE8.CSiven this infonnobon, o temporary inonaoae in noise and | | u gnoundborne vibration from remediabon' demolition, and construction is expected to be less than significant with inn9|ernontobon of standard-oonm1ruction practices. PUBLIC SERVICES AND UTILITIES The demolition, rennediatimn, and construction process for implementation ofbothon-ond off-site components of the proposed project is not anticipated to paau|t in impacts to public services. | J However, the proposed project (especially the installation of product water pipeline) may impact utilities in regards to damage or disruption of underground facilities such as water/sewer pipelines, electrical oonduitm, underground cable television or telephone vvihng, and natural gas mains. On- and off-site grading and excavation would occur only after the p 'act engineer has identified the locations ofunderground utilities. Should implementation of the product water pipeline conflict with existing subsurface utilities such as sewer or storm water gravity systems, either the proposed pipeline or existing utility would be rerouted. It should be noted that although the new Effingham sewer lift station is located along the > Alternative Pipeline Alignment, pipeline construction would ovoid this facility and disruption of service would not occur. |n the event that a gravity line mr other utility cannot be rerouted,the 42-to 48-inoh transmission line would be installed either above or below the existing utility > ' `' / flowing through the proposed pipeline vvmu|d be under pressure, routing the line under the utility would not affect its openstion). |n cases where a gravity line or other existing utility can be rerouted, the utility would be routed underneath the proposed pipe|ine, if possible. Gravity lines would be fitted with a siphon section to a||ovv flow to continue uninterrupted during proposed pipeline implementation. The proposed water transmission pipeline would have adequate sanitary separation from sewer faoi|ibee, and, if necessary, the Applicant would obtain necessary permits/approvals from the Department of Health 8en/|oem /[]H8\ for portions of the pipeline in | restricted zones. Impacts in this regard are not anticipated bzbesignificant. -- Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report In addition, the project would require trenchless construction beneath the Huntington Beach Channel as part of the product water pipeline portion of the project. The County of Orange has improved this channel by driving sheet piles 24 feet below ground to achieve a greater level of flood protection.14 Impacts in this regard are anticipated to be less significant. AESTHETICS/LIGHT& GLARE Demolition, remediation,and construction debris,associated mechanical equipment and high levels of truck traffic may adversely impact views of and across the project site, including the pipeline alignment and underground pump station locations. Construction and remediation activities on the proposed desalination project site would be visible from Huntington-By-The-Sea Mobile Home Park (located to the west), Beach Boulevard (located to the west), limited locations along Hamilton Avenue(located to the north), limited locations along Huntington State and Huntington City Beaches (located to the south), and from the vicinity of the intersection of Magnolia Street and Pacific Coast Highway(located to the southeast). However,these impacts would not be considered significant,as they would be short-term in nature. Standard construction measures such as chain link fencing and nylon mesh would be utilized to screen the staging and construction areas from site visitors and the general public at the proposed desalination project site and underground pump station sites. In addition,a staging area for equipment associated with the demolition,remediation,and construction process would be situated within HBGS property boundaries. HAZARDS AND HAZARDOUS MATERIALS The short-term demolition, remediation,and construction process of the proposed project may have adverse impacts with regards to hazardous materials. Remediation activities could expose on-site workers,future project employees,and the adjacent community to a variety of potentially hazardous materials. However, site remediation activities are strictly controlled by local, state, and federal requirements, and the majority of contamination in the vicinity of the proposed desalination project site is petroleum-based (which is not considered "toxic" or acutely hazardous). In addition, contaminated soils may be encountered along the proposed pipeline alignment (especially in the vicinity of the proposed desalination facility) as well as on the proposed pump station site. Therefore, compliance with the required mitigation measures (including a Remedial Action Plan subject to regulatory agency approval prior to project implementation for contaminated areas) is expected to reduce potential impacts to less than significant levels. No known plugged and abandoned oil wells exist within the project boundaries. However, several plugged and abandoned oil wells are located within proximity to the project site.. If possible, development over these wells would be avoided. Should development over a plugged/abandoned well be necessary, the well would be plugged or re-plugged in accordance with current Division of Oil, Gas and Geothermal Resources(DOGGR)specifications. Should any unrecorded or unknown wells be encountered during the excavation or grading process, the construction contractor would immediately report and coordinate with the City of Huntington Beach Fire Department and DOGGR to ensure adequate actions are taken. Implementation of the water transmission pipeline portion of the project may create potential impacts due to landfill gas generation (particularly methane)from the former Cannery Street Landfill,located at the northwestern corner of Hamilton Avenue and Magnolia Street(currently developed as Edison Community Center/SCE easement). Both pipeline alignment alternatives would pass directly south of the former landfill within Hamilton Avenue. However, pipeline construction in the vicinity of the former Cannery Street landfill would comply with all local,state,and federal regulations in regards to landfill gas. Standard construction practices would be implemented to determine the potential for 14 Telephone conversation with Albric Ghokasian, OCFCD, November 23,2004. iCity of Huntington Beach April 5, 2005 5.9-23 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report landfill gas and, if deemed necessary, appropriate gas detection, venting, and/or barrier system would be implemented to reduce impacts to less than significant levels. In addition, potential groundwater contamination beneath the subject site may pose a short-term health threat to on-site workers and adjacent land uses during dewatering operations. Groundwater pumped from the project site would be continually monitored for pollutants,and if detected,would be treated prior to discharge to the sanitary sewer system or stormwater facilities. As dewatering operations would meet all federal,State and local criteria for groundwater contaminants, impacts in this regard would be less than significant. In addition, demolition of existing on-site fuel oil storage tanks may expose persons to asbestos containing materials (ACMs)and/or lead based paint. Existing tanks on-site are constructed with a layer of insulation potentially containing asbestos. The proposed project is not expected to present significant health hazards, as carefully controlled removal operations would comply with all applicable Federal, State, and County regulations, in addition to measures imposed by the City of Huntington Beach and local agencies. Should asbestos or lead based paint be discovered on-site, a licensed asbestos/lead abatement contractor would be retained to remove the hazardous ) materials prior to the demolition of any structures. All ACMs would be removed in accordance with 1 SCAQMD Rule 1403. No structures would be demolished along the pipeline alignment, as the pipeline alignment would occur within existing public streets, easements, or other rights-of-way j (ROW). In addition, the two proposed booster pump location sites are void of structures, thereby j ! eliminating the possibility of asbestos insulation or lead based paint on-site. Impacts are not anticipated to be significant. )7 1 , TRAFFIC 7 Implementation of the proposed project may cause short-term,construction-related traffic impacts. The demolition, remediation and construction process would generate traffic in the site vicinity through on-site construction worker vehicle trips and truck trips. However, the City of Huntington r Beach's adopted "Transportation System Needs Analysis 2000-2010" (September 12, 2000, I approved by City Council October 2,2000)indicates that no existing deficient street segments(LOS D or worse)surround the subject site. The nearest deficient segment is located along Pacific Coast Highway (PCH), between Beach Boulevard and Huntington Street, to the west of the proposed desalination project site. The truck trips to and from the project site would utilize Beach Boulevard t _ to PCH to Newland Street,thereby minimizing impacts to the deficient segment of PCH located west of the project site. As the truck route would utilize Beach Boulevard from PCH north to the 1-405 freeway,the portion of Beach Boulevard from Garfield Avenue to Ellis Avenue (also designated as deficient by the City's "Transportation System Needs Analysis 2000-2010") may be temporarily impacted by short-term demolition, remediation,and construction. However,a Traffic Management Plan would be prepared for the demolition, remediation and construction phases of the proposed project in order to mitigate these short-term impacts to less than significant levels. Pipeline construction for product water delivery would require temporary disruption along public streets, as the majority of the pipeline is proposed to be installed within existing street right-of-way (ROW) utilizing open trench construction methods. Trenchless construction methods would be utilized to cross roadways sensitive to traffic disruption, such as Brookhurst Street and SR-55. Adequate staging areas would be provided for both open trench and trenchless construction in order l.- to minimize the amount of traffic disruption. In addition, a Traffic Management Plan would be prepared for the pipeline implementation phase of the proposed project in order to mitigate impacts to less than significant levels. The Traffic Management Plan would include measures to minimize traffic impacts due to pipeline implementation, such as the use of plating to reopen travel lanes during peak traffic hours as well as maintaining access to businesses and residences. City of Huntington Beach April 5, 2005 5.9-24 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact.Report In addition,a new pipeline would be necessary to connect existing HBGS intake and outfall facilities to the proposed desalination project. It is not anticipated that the pipeline would require the relocation of structures, utilities, or other AES facilities. The pipeline connecting HBGS facilities to the proposed desalination project would exist entirely within HBGS property boundaries,and would not affect public roadways. Pipeline construction would be short-term in nature, and appropriate mitigation measures would be implemented to reduce impacts on the HBGS to less than significant levels, including provision of temporary parking areas. Traffic impacts are not anticipated to occur upon implementation of the underground booster pump stations, as the pump station sites are proposed to occur within an Orange County Resource Preservation Easement and a church parking lot and would not require the closure or impede access to any roadways. BIOLOGICAL RESOURCES Proposed Desalination Facility Site Construction of the proposed desalination facility would not directly impact the existing wetland area situated to the southeast of the proposed site, as the facility is proposed entirely within the existing fuel oil storage tank area. Rather,construction-related impacts have the potential to occur indirectly in regards to air quality, noise, light/glare, and storm water runoff. However, as stated above, any such impacts would be short-term in nature and would cease following completion of the project. Construction at the desalination facility would only occur during the hours allowed by the City of Huntington Beach Noise Ordinance (7:00 AM to 8:00 PM). Western snowy plover (Charadrius nivosus, federally-listed as threatened and a state species of concern) forage primarily on sand at the beach-surf interface where they feed on small invertebrates. Snowy plovers nest most commonly on sandspits, dune-backed beaches, beach ' strands and open areas near river mouths and estuaries.15 Western snowy plover is a winter migrant in southern California and a localized breeding resident April through September.16 Reduced tidal influence in the marsh adjacent to the proposed project make it unlikely that western snowy plover would forage in this area. Plovers would also be unlikely to nest in this, or other adjacent marsh areas due to human activity.Western snowy plover nesting was last observed in the area in 1993, when one nesting pair was observed at the protected California least tern breeding area located on the Huntington State Beach." Belding's savannah sparrow(Passerculus sandwichensis beldingii,state-listed as endangered)may use the pickleweed of the Huntington Beach wetlands for breeding, nesting and feeding habitat.18 Construction impacts, including short-term,temporary noise disturbance,could lead to disruption in Belding's savannah sparrow nesting activities in the marsh adjacent to the project site.Adult birds are likely to avoid areas of construction and operational impacts, minimizing potential effects on ' adults. In order to minimize potential construction impacts to nesting savannah sparrows, a pre- construction nesting survey would be performed by a qualified biologist in consultation with applicable regulatory agencies. Adequate mitigation (such as relocation, construction noise abatement measures,etc.)would be implemented as appropriate based on the findings of the pre- construction survey. All focused surveys for sensitive biological resources performed prior to proposed project implementation would include a review of data within the California Natural Diversity Data Base (CNDDB) to obtain current information on any previously reported sensitive 15 Thelander and Crabtree, 1994. 1 6 AES and URS,2000. 17 Personal communication,Jonathan Snyder, United States Fish and Wildlife Service,2003. t8 MEC, 1991. City of Huntington Beach April 5, 2005 5.9-25 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report species/habitat, including Significant Natural Areas identified under Chapter 12 of the Fish and Game Code. California least tern (Sterna antillarum brownii,state-and federally-listed as endangered)are known �( to fly over the Huntington Beach wetlands, and to feed in the open water of the Talbert Channel.19 ! Least terns forage on small shallow-water fish such as anchovies and topsmelt.20 In order to provide abundant food for their chicks, California least terns breed in loose colonies along the coast near areas of seasonally abundant small fish, such as estuaries, river mouths and shallows. Nests are shallow depressions in sandy open areas with little vegetation. Nests and chicks are highly vulnerable to predation from native and introduced predators.A protected 7.9-acre California least tern breeding area is located on the Huntington State Beach between the Talbert Marsh opening and the mouth of the Santa Ana River, approximately 5,000 ft south east of the proposed project area.Typically 200 to 300 nesting pairs of California least terns utilize this breeding site each year.21 This area is likely to be unaffected by construction impacts. Upon adherence to construction standards administered by the City of Huntington Beach,and upon implementation of recommended mitigation measures,impacts to the adjacent wetland area are not I anticipated to be significant. 1 ! Off-Site Pipelines and Underground Pump Stations �} Proposed Pipeline Alignments I Implementation of the proposed project may result in impacts to waterways due to "frac-outs" potentially occurring during pipeline construction. "Frac-outs" occur when drilling fluids (usually bentonite)seep to the surface via cracks in the ground. Prior to the performance of any directional boring,the applicant would prepare a Frac-Out Contingency Plan.The plan would establish criteria under which a bore would be shut down (e.g., loss of pressure, loss of a certain amount of returns) and the number of times a single bore should be allowed to frac-out before the bore is shut down and reevaluated. It would also clearly state what measures would be taken to seal previous frac-outs that have occurred on a given bore to ensure that it does not become the path of least resistance for subsequent frac-outs. Additionally,the site-specific Frac-Out Contingency Plan would be prepared and reviewed by the City Engineer and appropriate resource agencies prior to each major bore. OC-44 Booster Pump Station r Construction of the proposed OC-44 underground booster pump station may have impacts on biological resources, as the 0.5-acre site is overgrown with dense native vegetation known to support numerous species of wildlife. Pump station construction may impact two special status habitats(riparian and coastal sage scrub)on-site and may adversely affect several federal-or state- listed species(coastal California gnatcatcher,least Bell's vireo,and western pond turtle)expected to occur within the immediate vicinity of the subject site. The applicant would consult with applicable regulatory agencies during the permit application process to determine the precise location of the underground pump station that would minimize impacts to surrounding biological resources. �- During project design and after the exact location has been determined, the following focused surveys would be performed, if necessary: ❖ Prior to construction, three coastal California gnatcatcher surveys would be performed for the subject site(preferably during the gnatcatcher breeding season)in accordance with the United States Fish and Wildlife Service (USFWS)and CDFG regulations for development 19 MEC, 1991. 20 Thelander and Crabtree, 1994. 21 Personal communication, Keane,2001. f City of Huntington Beach April 5, 2005 ) 5.9-26 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report within a NCCP region. If the gnatcatcher were detected on or adjacent to the site, consultation and permitting through the USFWS would be required. ❖ In addition, a focused survey utilizing USFWS protocols for the least Bell's vireo would be performed prior to pump station construction. This protocol requires that eight surveys be conducted at least 10 days apart during the vireo nesting season of April through July. If this species is found to occur on or adjacent to the subject site, consultation and permitting through the USFWS would be necessary. If construction can avoid the nesting season,this survey may not be required. ❖ As pump station construction may also impact the southwestern pond turtle, a habitat assessment conducted by a qualified biologist experienced with the species would be performed. If adequate habitat is observed, a trapping program may be required to determine the presence or absence of this species. If present, the pond turtles would be trapped and relocated prior to construction to mitigate impacts to this species to less than significant levels. ❖ A survey for active raptor nests would be conducted 30 days prior to commencement of any construction activities during the raptor breeding season between February 1 and June 30. Any occupied nests found during survey efforts would be mapped on construction plans. Restrictions on construction activities may be required in the vicinity of the nest until the nest is no longer active as determined by a qualified biologist. According to the 1995 County of Orange Central & Coastal Subregion Natural Community Conservation Plan&Habitat Conservation Plan (NCCP/HCP),the OC-44 pump station to be placed adjacent to the NCCP/HCP area would not be situated within or near a designated"special linkage" area. The purpose of"special linkage"areas is to"maintain connectivity between core coastal sage scrub habitat areas within the subregion, to improve biological linkages between the subregional reserve system and adjacent NCCP subregions, and to provide for other target species habitat located outside the reserve system." The nearest "special linkage" area to the proposed underground booster pump station site is the Coyote Landfill Special Linkage area, situated approximately 2,000 feet to the east. The El Capitan Special Linkage Area is located approximately one mile to the south. Implementation of the proposed off-site underground pump station is not anticipated to impact either of these "special linkage" areas. In addition, the underground pump station site would be situated outside the NCCP/HCP boundary, adjacent to an urbanized area. In addition, according to Appendix L of the Draft EIR, UNDERGROUND BOOSTER PUMP STATION BIOLOGICAL CONSTRAINTS SURVEY, the proposed OC-44 site may include areas within the jurisdiction of the Army Corps of Engineers (ACOE)or California Department of Fish and Game (CDFG). Should the potential for such areas continue to exist after the site is specifically located (outside of NCCP/HCP boundaries), a jurisdictional delineation in accordance with the Corps'Wetland Delineation Manual would be performed to determine the existence and/or extent of jurisdictional area. Adequate mitigation measures shall be implemented in consultation with the ACOE and CDFG during the permit application process, if necessary. As the proposed underground pump station would include all necessary biological surveys and comply with standard regulations as required by the USFWS, ACOE, and CDFG, impacts to biological resources are not anticipated to be significant (refer to Appendix L, UNDERGROUND BOOSTER PUMP STATION BIOLOGICAL CONSTRAINTS SURVEY,for additional information). It should also be noted that any displaced vegetation would be replaced. All focused surveys for sensitive biological resources performed prior to proposed project implementation would include a review of data within the California Natural Diversity Data Base (CNDDB) to obtain current information on any previously reported sensitive species/habitat,including Significant Natural Areas identified under Chapter 12 of the Fish and Game Code. City of Huntington Beach April 5, 2005 5.9-27 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report Coastal Junction Booster Pump Station As the Coastal Junction pump station is proposed within a church parking lot in a disturbed area,no impacts to biological resources are anticipated. CULTURAL RESOURCES Four archaeological studies have been conducted within a half-mile radius of the proposed desalination facility site. Of these studies,one encompasses the project site. This study found two archaeological sites, although none were found at the HBGS facility.22 In addition, no historic properties have currently been recorded at or nearby the subject site by the State Historic Resources Inventory list. However, due to the sedimentary deposits known to exist in the project area and due to the site's proximity to the coastal resources and fossil production from similar nearby sites, the project area is considered to have a high potential for producing paleontological resources. As such,a qualified paleontologist would be retained to monitorgrading operations,and, if necessary,to salvage scientifically significant fossil remains. The paleontologist would have the authority to temporarily divert or direct grading efforts to allow evaluation and any salvage of exposed fossils. Upon implementation of recommended mitigation, significant cultural resources impacts at the proposed desalination facility site are not anticipated to occur. As no historical or archaeological resources are known to exist within or surrounding the proposed booster pump station sites, impacts are not anticipated to be significant in this regard. However, should buried historical/archaeological resources be discovered during construction,all work in that area would be halted or diverted until a qualified archaeologist can evaluate the nature and significance of the finds. However, as the OC-44 pump station site is underlain by sediments deposited during the middle Miocene period,there is a high potential for the existence of middle Miocene invertebrate fossils and lower potential for middle Miocene vertebrate and Pleistocene vertebrate/invertebrate fossils. As such, a paleontological resource recovery program for Miocene invertebrate fossils would be j performed for proposed underground pump station implementation. Earth-moving activities IJ excavating lower than five feet would be monitored for paleontological resources,and a program to mitigate potential impacts to paleontological resources if exposed or unearthed during excavations would also apply (in accordance with the proposed guidelines of the Society of Vertebrate Paleontology). With the implementation of recommended mitigation measures, impacts to paleontological resources are not expected to be significant(refer to Appendix M, UNDERGROUND r BOOSTER PUMP STATION CULTURAL RESOURCES ASSESSMENT REPORTS, for more information). MITIGATION MEASURES HYDROLOGY AND WATER QUALITY CON-1 Concurrent with the submittal of the Grading Plan,the Applicant shall submit an Erosion Control Plan to the City of Huntington Beach Department of Public Works which would include the following measures: t a) Where necessary, temporary and/or permanent erosion control devices, as approved by the Department of Public Works,shall be employed to control erosion and provide safety during the rainy season from October 15th to April 151n 22 Southeast Coastal Redevelopment Plan Program EIR,January 23,2002. City of Huntington Beach April 5, 2005 5.9-28 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report b) Equipment and workers for emergency work shall be made available at all times during the rainy season. Necessary materials shall be available on-site and stockpiled at convenient locations to facilitate the rapid construction of temporary devices when rain is imminent. c) Erosion control devices shall not be moved or modified without the approval of the Department of Public Works. d) All removable erosion protective devices shall be in place at the end of each working day when the 5-day rain probability forecast exceeds 40%. e) After a rainstorm,all silt and debris shall be removed from streets,check berms and basins. f) Graded areas on the permitted area perimeter must drain away from the face of the slopes at the conclusion of each working day. Drainage is to be directed toward desilting facilities. g) The permittee and contractor shall be responsible and shall take necessary precautions to prevent public trespass onto areas where impounded water creates a hazardous condition. h) The permittee and contractor shall inspect the erosion control work and ensure that the work is in accordance with the approved plans. i) Water shall be applied to the site twice daily during grading operations or as otherwise directed by the County of Orange Inspector in compliance with South Coast AQMD rule 403(Fugitive Dust Emissions). A grading operations plan may be required including watering procedures to minimize dust, and equipment procedures to minimize vehicle emissions from grading equipment. CON-2 Construction of the project shall include Best Management Practices BMPs as stated p 1 9 ( ) in the Drainage Area Management Plan (DAMP) by the Orange County Stormwater Management Program. BMPs applicable to the project include the following: ❖ Potential pollutants include but are not limited to: solid or liquid chemical spills; wastes from paints, stains, sealants, glues, limes, pesticides, herbicides, wood preservatives and solvents;asbestos fibers,paint flakes,or stucco fragments;fuels, oils, lubricants, and hydraulic, radiator, or battery fluids; fertilizers, vehicle/equipment wash water and concrete wash water; concrete, detergent, or floatable wastes;wastes from any engine/equipment steam cleanings or chemical degreasing; and superchlorinated potable water line flushings. v During construction, disposal of such materials should occur in a specified and controlled temporary area on-site, physically separated from potential stormwater run-off, with ultimate disposal in accordance with local, state, and federal requirements. CON-3 As part of its compliance with the NPDES requirements,the Applicant shall prepare a Notice of Intent (NOI) to be submitted to the Santa Ana Regional Water Quality Control Board providing notification and intent to comply with the State of California general permit. Prior to construction, completion of a Storm Water Pollution Prevention Plan (SWPPP)would be required for construction activities on-site. A copy of the SWPPP shall be available and implemented at the construction site at all times. City of Huntington Beach April 5, 2005 5.9-29 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report CON-4 Prior to any dewatering activities, the Applicant shall obtain and comply with a general dewatering NPDES permit from the Santa Ana Regional Water Quality Control Board. CON-5 The Applicant shall submit a dewatering plan for review and approval by the Santa Ana Regional Water Quality Control Board and the City of Huntington Beach Department of Public ,Works. The Applicant would comply with the approved dewatering plan. CON-6 The Applicant shall inform the Orange County Water District (OCWD)of its plans for on-site dewatering, and, if necessary, would acquire necessary permits and approvals from the OCWD to ensure that no adverse impacts on the groundwater basin or seawater intrusion barrier occur as a result of the proposed project. The Applicant would comply with any approved dewatering permits or plans. CON-7 During dewatering operations,a survey program shall be conducted on surrounding properties and structures to ensure that movement or settlement from on-site dewatering operations does not occur. This survey program would be subject to approval by the City Engineer. CON-8 Should on-site dewatering operations require discharge into the sanitary sewer system, the Applicant shall obtain applicable permits and approvals from the Orange County Sanitation District (OCSD) and City of Huntington Beach Department of Public Works. Should the dewatering discharge be directed to existing AES stormdrain facilities, the Applicant shall ensure that dewatering is addressed in the Applicant's SARWQCB NPDES permit. AIR QUALITY CON -9 The project shall comply with SCAQMD Rule 402, which prohibits the discharge F j from a facility of air pollutants that cause injury,detriment, nuisance,or annoyance 1 J to the public or that damage business or property. CON-10 Duringclearing,grading,earth moving,or excavation operations,excessive fugitive 9�9 9� 9, P 9� dust emissions shall be controlled by regular water or other dust preventive measures using the following procedures, as specified in the SCAQMD Rule 403. ❖ On-site vehicle speed shall be limited to 25 miles per hour. ❖ All material excavated or graded would be sufficiently watered to prevent '— excessive amounts of dust. Watering would occur at least twice daily with complete coverage, preferable in the late morning and after work is done for the day. ❖ All material transported on-site or off-site would be either sufficiently watered �- or securely covered to prevent excessive amounts of dust. f- ❖ The area disturbed by clearing, grading, earth moving, or excavation 1 operations would be minimized so as to prevent excessive amounts of dust. I ❖ These control techniques would be indicated in project specifications. j Compliance with the measure would be subject to periodic site inspections by the City. ❖ Visible dust beyond the property line emanating from the project would be prevented to the maximum extent feasible. City of Huntington Beach April 5, 2005 5.9-30 - Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report NOISE CON-11 Prior to the issuance of any grading permits, the Applicant shall ensure evidence acceptable to the City of Huntington Beach Department of Planning and Public Works that: ❖ All construction vehicles or equipment,fixed or mobile,operated within 1,000 feet of a dwelling shall be equipped with properly operating and maintained mufflers; ❖ All operations shall comply with the City of Huntington Beach Municipal Code Chapter 8.40 (Noise Control); ' ❖ Stockpiling and/or vehicle staging areas shall be located as far as practicable from residential areas; and ❖ Notations in the above format, appropriately numbered and included with other notations on the front sheet of grading plans, would be considered as adequate evidence of compliance with this condition. CON-12 Should the project require off-site import/export of fill material during demolition, remediation, and construction, trucks shall utilize a route that is least disruptive to sensitive receptors, preferably Newland Street to Pacific Coast Highway to Beach Boulevard to 1-405. Construction trucks shall be prohibited from operating on Saturdays, Sundays and federal holidays. CON-13 To reduce project-related construction noise impacts generated by the proposed project, the following conditions shall be implemented: ❖ Construction activities shall be limited to hours specified by the City Noise Ordinance; and ❖ Unnecessary idling of internal combustion engines shall be prohibited. PUBLIC SERVICES AND UTILITIES CON-14 Unless underground utility locations are well documented,as determined bythe City of Huntington Beach Public Works Department, the project engineer shall perform geophysical surveys to identify subsurface utilities and structures, the findings of which shall be incorporated into site design. Pipelines or conduits which may be �. encountered within the excavation and graded areas shall either be relocated or be cut and plugged according to the applicable code requirements. AESTHETICS/LIGHT & GLARE CON-15 During construction,a security fence,the height of which shall be determined by the City of Huntington Beach Department of Building and Safety, shall be installed around the perimeter of the site. The construction site shall be kept clear of all trash, weeds, etc. CON-16 Construction activities, to the extent feasible, shall be concentrated away from adjacent residential areas. Equipment storage and soil stockpiling shall be at least 100 feet away from adjacent residential property lines. City of Huntington Beach April 5, 2005 5.9-31 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report HAZARDS AND HAZARDOUS MATERIALS (� CON-17 Prior to excavation of the contaminated and other areas for rough grading, the r, project site shall be cleared of all excess vegetation, surface trash, piping, debris I and other deleterious materials. These materials shall be removed and disposed of I J properly(recycled if possible). CON-18 Proper excavation procedures shall be followed to comply with OSHA's Safety and i Health Standards. If applicable, the South Coast Air Quality Management District (SCAQMD) Rule 1166 permit shall be obtained prior to the commencement of excavation and remedial activities. CON-19 The contractor shall follow all recommendations contained within the adopted n Remedial Action Plan for the project site. CON-20 If asbestos or lead-based paints are identified in any on-site structures, the contractor shall obtain a qualified contractor to survey the project site and assess the potential hazard. The contractor shall contact the SCAQMD and the City of Huntington Beach Departments of Planning, Building and Safety, and Fire prior to asbestos/lead paint removal. CON-21 If any hazardous materials not previously addressed in the mitigation measures contained herein are identified and/or released to the environment at any point during the site cleanup process,operations in that area shall cease immediately. At the earliest possible time, the contractor shall notify the City of Huntington Beach Fire Department of any such findings. Upon notification of the appropriate agencies, a course of action would be determined subject to the approval of the by the City of Huntington Beach Department of Public Works. CON-22 All structures must be cleaned of hazardous materials prior to off-site transportation, , or hauled off-site as a waste in accordance with applicable regulations. �J CON-23 Structure removal operations shall comply with all regulations and standards of the `^ SCAQMD. CON-24 The contractor shall post signs prior to commencing remediation,alerting the public to the site cleanup operations in progress. The size, wording and placement of these signs shall be reviewed and approved by the City of Huntington Beach Departments of Planning and Public Works. CON-25 Any unrecorded or unknown wells uncovered during the excavation or grading _ process shall be immediately reported to and coordinated with the City of Huntington Beach Fire Department and State Division of Oil, Gas, and Geothermal Resources (DOGGR). CON-26 During remediation, if any soil were found to be hazardous due to contamination other than petroleum hydrocarbons,it would be segregated,stockpiled,and handled separately. CON-27 Dust and volatile organic emissions from excavation activities shall be controlled through water spray or by employing other approved vapor suppressants including hydromulch spray in accordance with Regional Water Quality Control Board r (RWQCB) Waste Discharge Requirements and the South Coast Air Quality Management District (SCAQMD) permit conditions. City of Huntington Beach April 5, 2005 5.9-32 t. I Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report ' CON-28 Prior to the excavation process for pipeline construction, the contractor shall coordinate with the County of Orange's Integrated Waste Management Department in order to ensure that proposed pipeline construction does not impact drainage of ' the former Cannery Street Landfill. CON-29 Methane migration features would be consistent with the requirements of the City of Huntington Beach Specification Number 429 and other applicable state and federal regulations. The methane migration features shall be submitted for review and approval to the Orange County Health Care Agency(OCHCA), Environmental Health Division. CON-30 Studies to evaluate the potential for landfill gas (LFG) generation and migration would be completed prior to implementation of the proposed water delivery component of the project. Appropriate mitigation measures would be coordinated with the South Coast Air Quality Management District, Solid Waste Local Enforcement Agency, Regional Water Quality Control Board, and the City of Huntington Beach Fire Department. Mitigation measures could entail active or passive extraction of LFG to control surface and off-site migration and passive barriers with vent layers and alarm systems below trenches and within 1,000 feet of the former Cannery Street Landfill boundary. A comprehensive monitoring network would be established along the pipeline alignment adjacent to the landfill. Periodic monitoring of the monitoring network would be performed. TRAFFIC ' CON-31 A Traffic Management Plan (TMP) shall be prepared and implemented to the satisfaction of the affected jurisdiction within which the facilities are to be constructed when the facilities are to be located where construction would affect roadways. The TMP shall include, but not be limited to, the following measures: 4. Limit construction to one side of the road or out of the roadbed where possible; ❖ Provision of continued access to commercial and residential properties adjacent to construction sites; ❖ Provide alternate bicycle routes and pedestrian paths where existing paths/ routes are disrupted by construction activities, if any; ❖ Submit a truck routing plan,for approval by the City of Huntington Beach, County, and other responsible public agencies in order to minimize impacts from truck traffic during material delivery and disposal; ❖ Where construction is proposed for two-lane roadways, confine ' construction to one-half of the pavement width. Establish one lane of traffic on the other half of the roadway using appropriate construction signage and flagmen, or submit a detour plan for approval by the City Traffic Engineer; ❖ The Traffic Management Plan shall be approved by affected agencies at least two weeks prior to construction. Per Caltrans requirements, the . applicant shall submit the Traffic Management Plan to Caltrans at the 90- percent design phase; ❖ Construction activities shall, to the extent feasible, be coordinated with other construction activity taking place in the affected area(s); and City of Huntington Beach April 5, 2005 5.9-33 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report ❖ Provide for temporary parking, where necessary, during installation of pipelines within the AES site. CON-32 Prior to initiating the removal of structures and contaminated materials, the contractor must provide evidence that the removal of materials would be subject to a traffic control plan, for review and approval by the by the City of Huntington Beach Department of Public Works. The intent of this measure is to minimize the time period and disruption of heavy duty trucks. CON-33 Construction related activities would be subject to,and comply with,standard street { use requirements imposed by the City of Huntington Beach, County and other public C agencies,including the use of flagmen to assist with haul truck ingress and egress of construction areas and limiting the large size vehicles to off-peak commute traffic periods. CON-34 The Contractor shall obtain the necessary right-of-way encroachment permits and satisfy all permit requirements. Nighttime construction may be performed in congested areas. Also, any nighttime construction activities shall have prior approval by the City of Huntington Beach Department of Public Works. CON-35 During periods of heavy equipment access or truck hauling, the Contractor would provide construction traffic signage and a construction traffic flagman to control construction and general project traffic at points of ingress and egress and along roadways that require a lane closure. CON-36 The Applicant shall coordinate with the Department of Public Works, Traffic Engineering Division in developing a truck and construction vehicle routing plan. J This plan shall include the approximate number of truck trips and the proposed truck haul routes. It shall specify the hours in which transport activities can occur and methods to mitigate construction related impacts to adjacent residents and the surrounding area. The plan shall take into consideration any street improvement construction occurring in the vicinity. These plans must be submitted for approval to the Department of Public Works. ri BIOLOGICAL RESOURCES l CON-37 Prior to construction on the proposed booster pump station site, three focused coastal California gnatcatcher surveys shall be performed in accordance with USFWS protocols, preferably during the gnatcatcher breeding season. Should the species be observed on or adjacent to the site, consultation and permitting through t the USFWS would be required. CON-38 Prior to construction on the proposed booster pump station site,eight focused least Bell's vireo surveys shall be performed for the off-site underground booster pump station (at least 10 days apart during the vireo nesting season of April and July) in accordance with USFWS protocols. Should the species be observed on or adjacent to the site,consultation and permitting through the USFWS would be required. This measure may not be necessary if construction phasing can avoid the vireo nesting season. (^ t_ CON-39 Prior to construction on the proposed booster pump station site,a qualified biologist shall perform a habitat assessment for the southwestern pond turtle. If habitat for this species is observed,a trapping program would be implemented to determine the City of Huntington Beach April 5, 2005 5.9-34 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report presence or absence of these species. If present, pond turtles must be trapped and relocated prior to the start of construction. CON-40 A survey for active raptor nests shall be performed by a qualified biologist 30 days prior to the commencement of construction activities on the proposed booster pump station site. Any occupied nests discovered during survey efforts shall be mapped on construction plans for the site. If recommended by the biologist, restrictions on construction activities may be required in the vicinity of the nest until the nest is no longer active. CON-41 Prior to the commencement of any directional boring for water conveyance pipeline implementation,the applicant shall prepare a Frac-Out Contingency Plan. The plan ' shall establish criteria under which a bore would be shut down (e.g., loss of pressure, loss of a certain amount of returns)and the number of times a single bore should be allowed to frac-out before the bore is shut down and reevaluated. It would also clearly state what measures would be taken to seal previous frac-outs that have occurred on a given bore to ensure that it does not become the path of least resistance for subsequent frac-outs. Additionally, the site-specific Frac-Out Contingency Plan would be prepared and reviewed by the City Engineer and appropriate resource agencies prior to each major bore. CON-42 In order to minimize potential construction impacts to nesting savannah sparrows 1 adjacent to the proposed desalination facility, a pre-construction nesting survey would be performed by a qualified biologist in consultation with applicable regulatory agencies. Should nesting savannah sparrows be found, adequate mitigation (such as relocation,construction noise abatement measures,etc.)would be implemented as appropriate based on the findings of the pre-construction survey. CON-43 All focused surveys for sensitive biological resources performed prior to proposed project implementation shall include a review of data within the California Natural Diversity Data Base (CNDDB) to obtain current information on any previously reported sensitive species/habitat, including Significant Natural Areas identified under Chapter 12 of the Fish and Game Code. CON-44 Prior to implementation of the proposed off-site booster pump station adjacent to the NCCP/HCP boundary,a jurisdictional delineation of the proposed pump station site shall be performed to determine the extent of jurisdictional area, if any,as part of the regulatory permitting process. CULTURAL RESOURCES ' CON-45 Should buried historical/archaeological resources be discovered during excavation on the proposed booster pump station site,all construction work in that area shall be halted or diverted until a qualified archaeologist can evaluate the nature and significance of the finds. CON-46 During excavation of five feet below ground surface or lower on the proposed booster pump station site,a paleontological resource recovery program for Miocene invertebrate fossils shall be implemented. This program shall include, but would not be limited to, the following: ❖ Monitoring of excavation in areas identified as likely to contain paleontologic resources by a qualified paleontologic monitor. The monitor shall be equipped to salvage fossils as they are unearthed to ' City of Huntington Beach April 5, 2005 5.9-35 Seawater Desalination Project at Huntington Beach 5.9 CONSTRUCTION RELATED IMPACTS Draft Recirculated Environmental Impact Report avoid construction delays and to remove samples of sediments, which are likely to contain the remains of small fossil invertebrates and vertebrates. The monitor must me empowered to temporarily halt or divert equipment to allow removal of abundant or large specimens. Monitoring may be reduced if the potentially fossiliferous units described herein are not encountered, or upon exposure are determined following examination.by qualified paleontologic personnel to have low potential to contain fossil resources; {. ❖ Preparation of recovered specimens to a point of identification and permanent preservation,including washing of sediments to recover small invertebrates and vertebrates; ❖ Identification and curation of specimens into a museum repository with permanent retrievable storage. The paleontologist should have a written respository agreement in hand prior to the initiation of mitigation activities; and 4. Preparation of a report of findings with appended itemized inventory of specimens. The report and inventory,when submitted to the appropriate Lead Agency, would signify completion of the program to mitigate impacts to paleontologic resources. CON-47 A qualified paleontologist shall be retained to monitor grading operations at the proposed desalination facility site, and, if necessary, to salvage scientifically significant fossil remains. The paleontologist shall have the authority to temporarily El divert or direct grading efforts to allow evaluation and any salvage of exposed fossils. r� UNAVOIDABLE SIGNIFICANT IMPACTS L The proposed desalination project may have unavoidable significant impacts in regards to F temporary,short-term emissions for NO, This unavoidable significant impact is anticipated to occur for the duration of the demolition, remediation, and construction process (expected to last approximately 18-24 months). NOX emissions during construction of the proposed project would (� exceed the SCAQMD emission standards, despite the implementation of applicable mitigation l measures. F Ir- L_ L City of Huntington Beach April 5, 2005 5.9-36 5. 10 OCEAN WATER QUALITY AND MARINE BIOLOGICAL RESOURCES Information in this section was compiled from the Hydrodynamic Modeling of Source Water Make- Up and Concentrated Seawater Dilution for the Ocean Desalination Proiect at the AES Huntington Beach Generating Station(2004),prepared by Dr. Scott A.Jenkins Consulting,Watershed Sanitary Survey Report(2002),prepared by Archibald and Wahlberg Consultants,the California Ocean Plan (2001) prepared by the State Water Resources Control Board, Huntington Beach Desalination Facility Intake Effects Assessment (2004), prepared by Tenera Environmental, Evaluation of a Report on Receiving Water Chemistry and Quality Issues Related to the Operation of a Reverse osmosis Desalination Facility at the Huntington Beach Power Generating Station(2004),prepared by Jeffrey B. Graham, Ph.D.; Marine Biological Considerations Related to the Reverse Osmosis Desalination Proiect at the Applied Energy Sources Huntington Beach Generating Station (2004), Prepared by Jeffrey B. Graham, Ph.D.;Existing Conditions for the Proposed Poseidon Desalination Proiect at Huntington Beach, California;and the Effects of a Concentrated Seawater Discharge on the Marine Environment of Huntington Beach, California prepared by MBC Applied Environmental Services. EXISTING CONDITIONS OCEAN WATER QUALITY The Pacific Ocean is located approximately 2,000 feet south of the proposed project site, along Huntington State and Huntington City Beaches. Source waterforthe proposed desalination facility will be taken from the existing condenser cooling water circulation system from the Huntington ' Beach Generating Station facility (HBGS). Up to 507 million gallons per day (mgd) of cooling seawater presently flows to the HBGS through an existing ocean water intake structure located approximately 1,840 feet offshore. The Santa Ana River flows into the Pacific Ocean approximately 8,300 feet from the HBGS intake, while the Talbert Channel discharges into the ocean approximately 1,300 feet upcoast(northwest)from the mouth of the Santa Ana River. The Orange County Sanitation District (OCSD) deep ocean sewage outfall is located five miles offshore of the Santa Ana River at a depth of 195 feet (refer to Exhibit 5.10-1, LOCATION MAP OF LOCAL ' SURFACE AND WASTEWATER DISCHARGES). Bacteria levels are the primary Pacific Ocean water quality concern in the project vicinity. Natural water temperatures in the Pacific Ocean fluctuate throughout the year in response to seasonal and diurnal variations in currents as well as meteorological factors such as wind, air temperature, relative humidity, cloud cover,ocean waves,and turbulence. Diurnally,natural surface ' water temperatures generally vary one to two degrees celsius in the summer and 0.3 to one degree celsius in the winter. Reasonably sharp thermoclines (differences between surface and bottom water temperatures)are known to occur in the nearshore waters of Huntington Beach at a depth of 12 to 15 meters during the summer,and are typically absent during the winter. Salinities in the area are fairly uniform and normally range from 33.0 to 34.0 parts per thousand (ppt), while levels of dissolved oxygen range from approximately five to 13 milligrams per liter(mg/L). Recently, Huntington Beach has experienced several closures of the water area adjacent to the beach. The closures have been due to levels of bacteria in the surf zone that have exceeded the State standard. These closures have prompted a series of studies in order to find the source of contamination that is causing bacteria levels in the surf zone to exceed State standards. A review of ' City of Huntington Beach April 5, 2005 5.10-1 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES multiple studies conducted finds HBGS is not the source of bacteria in the surf zone. A discussion of bacteria in the ocean surrounding the subject site is discussed in Section 4.0, EXISTING CONDITIONS. i r f Contamination in Proximity to the HBGS Intake Potential Sources o C y There are a number of discharges and potential sources of contaminants in the vicinity of the HBGS intake (which will be the source of water for the proposed desalination facility). These potential contaminant sources were investigated to determine the quality of water that will enter the desalination facility. A hydrodynamic modeling study was conducted by oceanographers at the Scripps Institution of Oceanography to determine if several of the potential sources of contaminants �. in the vicinity of the HBGS intake could affect the quality of water at the generating station intake. Appendix E, WATERSHED SANITARY SURVEY contains a more thorough discussion of each of the potential contaminant sources, and Appendix C, HYDRODYNAMIC MODELING REPORT contains a detailed discussion of the modeling results. OCSD Wastewater Discharge Although disinfection of the OCSD effluent reduces bacteria in the discharge to the level of beach standards in the zone of initial dilution,the potential for the OCSD discharge to impact water quality at the intake of the HBGS was investigated. OCSD discharges a mix of primary and secondary treated wastewater at an outfall that is located 4.5 miles offshore at a depth of 195 feet. The OCSD outfall is located southeast of the HBGS intake(refer to Exhibit 5.10-1,LOCATION MAP OF LOCAL SURFACE AND WASTEWATER DISCHARGES). �- Under normal oceanographic conditions,the HBGS intake and OCSD discharge are segregated in two different water masses by ocean thermal stratification,with no appreciable exchange between those water masses. Currents generally flow downcoast (i.e. southeast) from the OCSD outfall. The OCSD wastewater discharge would have the greatest potential to impact water quality at the HBGS intake with summer El Nino conditions when net transport by waves and currents is upcoast !� toward the HBGS intake. A modeling study was conducted to determine if OCSD discharge could potentially affect water quality at the intake of the generating station (the results of the modeling study are discussed below, under IMPACTS). Urban Storm Water Runoff j The Santa Ana River and Talbert Marsh (located southeast of the HBGS intake)are known sources LJ of fecal indicator bacteria to the surf zone during storm events. A modeling study was conducted to determine if these two sources could potentially affect water quality at the intake of the generating station (the results of the modeling study are discussed below, under IMPACTS). E Storm water discharges from the Santa Ana River and Talbert Marsh would have the greatest potential to impact water quality at the HBGS intake if an extreme storm event coincided with an El Nino winter and maximum pumping of cooling water into the generating station. Although it is unlikely that all of these events would coincide with one another, this was considered to be the r-. "worst-case" scenario for determining if the Santa Ana River and Talbert Marsh contribute contaminants to the HBGS intake. L i r- L r City of Huntington Beach April 5, 2005 ) 5.10-2 -- 33:7�135— 317000 336875— 33:6750— '�• � —� � , L 336625 �. ,j - un�tingtOn.+� ( � r 33.6500 Lv �ti F l ?' fc Wbe ' �f HBGSInfall ���,��� 0 33.6375— .a 33:6250 33.6125_-- 5e--� � QCS Sh w 33.6060. ( ... x 335875- o I 33.5750 v l ,- 33,5625—• / ,�/ �, 11'8.100 `1 u.050 118.00i; 1,17.950 117:900 117.850 117:800. Longib*, Source Poseidon Resources Corporation,August 2002. NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH fMFQ Location Map of Local Surface and Wastewater Discharges CON SU LTI N[i 02/05-JN 10-101409,002 Exhibit 5.10-1 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES Dry Weather Runoff Several studies have shown that the Talbert Marsh is a significant source of fecal indicator bacteria in the surf zone. A modeling study was conducted to determine if dry weather runoff from the Talbert Marsh could affect water quality at the intake of the generating station (the results of the modeling study are discussed below, under IMPACTS). Most of the dry weather runoff is now diverted to OCSD for treatment and discharge at the deep water outfall. However,fecal indicator bacteria levels at the outlet of the marsh remain high and these bacteria are flushed out of the marsh, particularly during spring tides. Recirculation of HBGS Discharge ' The HBGS outfall is located 340 feet from the intake. The National Pollution Discharge Elimination System (NPDES) permit for the HBGS allows the facility to discharge up to 516 million gallons per day(mgd). The discharge consists largely of cooling water but up to 1.66 MGD of generating station process wastewater and storm water can be mixed with the cooling water and discharged at the outfall. In addition, upon project implementation, there is a potential for the desalination facility's reverse osmosis (RO) to be recirculated, as the concentrated seawater would be discharged through the HBGS outfall. Recirculation of the HBGS discharge would have the greatest potential to impact water quality at the intake during wet weather conditions when the maximum amount of storm water is being discharged through the outfall. Los Angeles and San Gabriel Rivers The Los Angeles River discharges to the ocean approximately 16 miles upcoast (i.e. northwest) from HBGS, while the San Gabriel River discharges approximately 11 miles upcoast. The United States Geological Survey(USGS)conducted an intensive ocean water quality monitoring program in the summer of 2001 and found a mass of lower-salinity water near the shore in Huntington Beach. The source of the nearshore low-salinity water was not identified in their study but the authors of the report speculated that it may be coming from the San Gabriel and Los Angeles rivers(USGS,2003). There have been no further studies on the potential impact of these two rivers. Cruise Ships and Fishing Boats Cruise ship and fishing boat operations in the vicinity of the HBGS intake have the potential to impact water quality in regards to sewage discharge and leaks or spills of oil/fuel. The nearest major port for cruise ships to the HBGS intake is the Long Beach Harbor,situated approximately 16 miles upcoast. Another major port for cruise ship operations is the Los Angeles Harbor, located approximately 18 miles upcoast of the HBGS intake. ISportfishing in Orange County is done mostly from piers and boats. A commercial passenger and private fishing vessel fleet, based in Newport Bay,operates in the vicinity of Newport and Huntington ' Beach. Charter boats operating off Newport and Huntington Beach fish the artificial reefs and sandy bottom, or the rocky areas and kelp beds to the south offshore of Corona Del Mar and Laguna Beach, typically in water depths of 14 to 18 meters deep (OCSD, 2002a). City of Huntington Beach April 5, 2005 5.10-4 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES Recreation It is estimated that over five million people visit Huntington State Beach each year for recreational purposes. Such users have the potential to affect water quality at the HBGS intake due to sewage and spills of contaminants such as lighter fluid used for bonfires. Oil and Gas Production Facilities a There are two offshore oil platforms approximately 1.5 miles west of the HBGS intake and four platforms approximately 10 miles west of the intake. Oil and gas pipelines connect the platforms to (� coastal oil/gas facilities upcoast from the intake. There are no oil tanker shipping lanes in the vicinity of the intake. The closest shipping lanes are six to seven miles offshore. There have not been any reportable spills or leaks from the offshore oil platforms or the pipelines.' A catastrophic event at one of the offshore platforms that is near the coast could affect water quality at the HBGS intake. Red Tides and Algal Toxins o Refer to Section 5.11, PRODUCT WATER QUALITY for a discussion of existing conditions in regards to red tides and algal toxins. Operations at HBGS Source water quality for the proposed desalination facility has the potential to be affected by HBGS operations. Activities or conditions occurring along the HBGS cooling water system between the HBGS intake and the point at which water is diverted toward the desalination facility could impact water quality(particularly in regards to metals). The diversion point would occur after cooling water has traveled through the HBGS condensers. Other potential sources of contamination at HBGS .include cycle water discharges (the discharge of HBGS process byproduct water at various points into the cooling water system), urban runoff discharges, wastewater discharges, hazardous materials,and heat treatments(the periodic diversion of water from the discharge vault back into the Q cooling water system to be reheated to prevent biological growth). These potential contaminant sources are further analyzed below, under IMPACTS. Elevated Bacteria Levels in the Huntington Beach Surf Zone Extensive bacterial studies have shown that the Santa Ana River and Talbert Marsh appear to be the primary sources of fecal indicator bacteria to the near shore ocean. In addition, bird droppings and a reservoir of bacteria stored in the sediment and on marine vegetation may continue to be the source of bacteria at the mouths of the river and marsh. Modeling studies and monitoring data r 7 indicate that there is likely another unidentified source of bacteria in the vicinity of Stations 6N and 9N. However, three separate studies conducted between 2001 and 2002 have demonstrated that HBGS is not the source of bacteria in the surf zone. Additional information in regards to existing n conditions for the elevated bacteria levels in the Huntington Beach surf zone is provided in Section i 4.0, EXISTING CONDITIONS. uu MARINE BIOLOGY The marine environment offshore of the proposed project site exists within a biologically and climatologically unique region called the Southern California Bight(SCB). Geographically,the SCB a is an open embayment extending from Point Conception, California into Baja California,Mexico and ' Personal communication, Dave Sanchez,California Division of Oil,Gas, and Geothermal Resources. City of Huntington Beach April 5, 2005 5.10-5 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES ' 125 miles offshore(refer to Figure 4-1, SOUTHERN CALIFORNIA BIGHT). Biologically,the SCB is a transition-zone species assemblage positioned between two larger and diverse assemblages:one in the cooler waters to the north, and the other in the warmer waters to the south. SCB organisms comprise a mix of species (some from the cooler northern waters and some from the warmer southern waters).z ' Physical, biological,and oceanographic factors affect the total SCB biomass and cause year-to-year variation in the number of species occurring within the SCB and in areas such as Huntington Beach. While ocean temperature, current patterns, and upwelling affect nutrient and food supplies, ' biological variables such as the arrival of planktonic animals to coastal areas,the recruitment of new organisms (addition of young-of-the-year to the population) and habitat availability and quality all influence ecosystem-species composition, diversity, and biomass (Jackson, 1986). The young stages of most marine invertebrates and fishes living at and near Huntington Beach and throughout the SCB begin life as drifting plankton. Their survival into the next life stage requires that the appropriate and vacant habitat be found. Thus, evaluation of either local or regional habitats with ' respect to their biodiversity,the abundance of different species,and the ages,body size,and growth rates of specific organisms must always be made in the context of the large-scale factors influencing these, whether in the area around Huntington Beach or across the entire SCB. As stated in Section 4.0, EXISTING CONDITIONS/ENVIRONMENTAL SETTING, the marine organisms living in the vicinity of the HBGS discharge occur in one of three habitat classifications: 1) substrate(termed infauna);2)on the bottom seafloor(termed macroinvertebrates,including worms, ' crabs, sand dollars, starfish and some fishes);or 3) in the water column itself(consisting of squid, fish, plankton, etc.). ❖ Infauna: Huntington Beach infauna surveys were carried out from 1975 to 1993 by MBC Applied Environmental Sciences(MBC, 1993). The habitat surrounding the HBGS outfall is dynamic and there are many species that can potentially occur in the infauna. However, many of these are rare or appear episodically. Most of these animals have very short lives and it is reasonable to assume that many of them arrive each year in the plankton. Thus, the infaunal species diversity of the extended habitat varies from year to year as does organism age, size, and abundance. ' Table 5.10-1, MAJOR GROUPS OF INFAUNAL ANIMALS AT HUNTINGTON BEACH, 1975-1993, summarizes the total diversity of infaunal organisms found over 18 years of study. Table 5.10-2, ORDER OF ABUNDANCE OF INFAUNAL ANIMALS AT HUNTINGTON BEACH, 1975-1993, lists the infaunal species in order of their mean abundance from 1975 to 1993. Figure 5.10-1, INTERANNUAL VARIATION IN HUNTINGTON BEACH INFAUNAL ABUNDANCE AND SPECS RICHNESS, shows the numbers of species and numbers of individuals found in samples overtime. Average animal density was about 43 per unit volume, but this varied from year to year and by a factor of five over 18 years. In terms of both numbers and species,the most dominant animals each year were polychaete worms and crustaceans. Mollusks were the third most abundant group and showed marked variation from year to year. ' ❖ Benthic macrofauna: Macrofaunal surveys, conducted from 1975 to 2000, show the repeated occurrence of the same core group of species in the area (MBC, 2001). The macrofaunal species occurring at Huntington Beach are typical of those expected to occur at other comparable open, sandy bottom habitats throughout the SCB. Table 5.10-3, 2 Marine Biological Considerations Related to the Reverse Osmosis Desalination Project at the AES Huntington Beach Generating Station, J.B. Graham, Ph.D., August 3, 2004 (refer to Appendix S, MARINE BIOLOGICAL CONSIDERATIONS). City of Huntington Beach April 5, 2005 5.10-6 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES Table 5.10-1 MAJOR GROUPS OF INFAUNAL ANIMALS AT HUNTINGTON BEACH, 1975-1993 Taxon Species Taxon Species CNIDARIA CRUSTACEA(cons). Anthozoe loopoda nonlife kollikerf t Edote&sublittoralis Uromunna ubiquity e NEMERTEA Amphipoda Cariname mutebilis Ampelisce brachycledus Lineidae,unid. Aora op.e Nemertea,unid. Aoridae,unid. Paransmertes californica 2 Argisse hamatfpes Tubulanue oinp ulatus Cerspus'tubularis' Tubulanua rxrthus Ericthonius brasiliansis Tubulanus peNuoidus/polynrorphus a Gibberosus myersi to Monoculodes hartmanae SI PU NCU LA Pachynus barnardi Siphonosome fngens Photis californica Thysanocardia nigra Phods macinerneyi Rhepoxynius menziesf'r ANNELIDA Rhepoxynius sp.A of SCAMIT i2 Polychaeta Stenothoe op. Ancisrrosyflis groenlandica Synchelidium*hoemakeri Aomirs astherinae Dscapoda Am*sans ocoidentalis Neatrypaoa califarniensis 13 Ampharete lebrops Ogyrides sp..A of Roney Apopnonospfo pygmsea Pinnixe forficulimanus Asychis disparidentata Pyromais tuberculate Chaetozone cf.swoop Chaetozone corona MOLLUSCA Chone a/boainuta Gastropod& Chone mollfs Armin*californica Diopatrs ornate 8alcis rubles Diopetra sp/endidissima Crepidula norrisierum Glyaer*conwluta Crepidula op. Gonisda littorea Cylfchnella harps Harmothoe ap.B of SCAMIT' Kurtzie/le plumbea Lumbrineris califormonsis Nassarius op. a Lumbrineristetraura Odostomia sp. Lumbrineris app. Olivells baetica Mage/ona pite/kai Ophiodermel/a cancell*ta Mod iomastus*pp. Philine bakeri Microphthalmus hystrix Rictaxis punctocaelatus Nephtys caecoidos Sulcorstuss xystrum Onuphid&e unid. Turbonf/la pedroana Onuphls eremfta Onuphis eremfta parve Peiecypoda Owenia collaris Cooperella subdiaphana a Paraprionospio pinnate M&coma up. Pe*finarie asliforniensis Mysella sm A ofSCAM1T Pf*ta nr,disjunota Nucula tenuis Piodarkeopsis glabrus 6 Poriploma p/eniusculum Prionoepiolightf a Siliqua lucid& Scoloplos armiger Solon sicarius Stg.shon spines Teltina modesta JI Spfoph*nes bomb^ Yoidia cooperi Spiophanes missionenme Sthenelafs verruculose PHORONIDA Tharyx op.A ofSSAMIT'T Phoronida,unid. Tharyxtesso/ata Typosyflis aciculate BRACHIOPODA Glouidis albida CRUSTACEA Copepoda ECHINODERMATA Paralteutha simile Ophiuroidea Ostracods Amphlodle pears EuphMomodow caraharodonte Amphiura arcystata ra Euphilomedes longfsets Amphiuridse op.A of M8C rb Pairsworopor bernesf Ophiuroidea,unid. Rutiderms rostrats Cumaaea HEMiCHORDATA Campyfaspis sp.Cot Mac Enteropneuata,unid.76 Cumells op.A of M8C Diastyfopsfs tenuis Leptocumo hxsmenf Source: MBC, 1993 u City of Huntington Beach April 5, 2005 5.10-7 = s = = = = M = M = = M = = = = = = M Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES Table 5.10-2 ORDER OF ABUNDANCE OF INFAUNAL ANIMALS AT HUNTINGTON BEACH, 1975-1993 Species 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 Mean SD Apopdonospio pygmaea 680 430 360 360 44 100 300 50 720 440 21 167 42 133 96 88 1513 29 79 297.4 376.5 Rhepoxynius menziesi - - 28 150 290 280 150 180 160 340 675 194 212 975 229 413 496 142 73 262.4 250.0 Diastylopsis tenuis 380 120 270 180 540 530 330 160 160 50 25 794 183 438 83 125 54 96 94 242.8 213.7 Goniada littorea 450 370 380 350 290 240 380 220 210 90 192 389 175 171 213 204 13 233 25 241.8 117.8 Olivella baetica 130 90 44 140 110 25 110 110 4 60 1995 11 29 33 21 33 25 8 1 154.4 460.3 Owenia collads - - - 180 240 180 800 - 150 40 88 - - 8 750 54 400 - 4 152.3 253.5 Polydora nuchalis - - - 340 - 30 1470 167 72 109.4 358.5 Crepidula naticarum 20 - 20 70 50 - 1670 104 28 - 25 - - - - - 104.6 401.3 Chaetozone cf.Setosa 60 120 210 20 17 60 10 250 40 20 292 11 200 13 183 121 42 92 14 93.4 94.4 Tharp sp. 690 280 170 30 17 30 70 80 40 40 - 161 38 - - - - - 36 88.5 171.0 Mediomastus spp. - - - 100 250 230 80 80 10 30 13 122 233 38 42 100 4 250 48 85.8 85.7 Leitoscoloplos pugettensi 40 210 180 50 39 150 80 300 80 40 92 122 71 - 13 - 4 83 - 81.8 83.0 Tellina modesta 10 - 10 50 90 680 110 50 10 120 8 28 79 17 29 8 - - 10 68.9- 160.3 Dendraster excentdcus - 120 - - 6 - 130 150 20 310 21 6 12 46 117 21 63 142 - 61.2 82.8 Eohaustodus washingtonianus - - - 190 90 4 10 13 - 90 50 56 100 108 200 83 50 50 - 60.8 63.7 Prionospio lighti' 70 50 40 50 17 200 4 70 30 30 21 6 - 271 58 79 8 63 5 56.5 71.9 Amaeana occidentalis 5 50 50 40 56 10 60 20 10 180 104 - 33 13 4 4 - 258 96 52.3 46.4 Pectinaiiacalifomiensis" 40 20 20 70 17 20 10 40 20 320 88 - 8 179 21 8 13 - 4 47.2 81.4 Spiophanes bombyx 50 20 20 30 22 50 20 - 90 170 100 17 21 71 63 33 33 58 24 47.0 41.7 Magelona sacculata - - - 30 33 190 30 80 10 10 150 - 12 46 67 63 75 33 - 43.6 54.3 Photis spp. 60 - 20 - - 10 17 30 - 410 46 44 4 25 4 4 25 - - 36.8 96.8 Parapdonospio pinnata - 40 10 - 6 20 140 100 20 180 17 61 33 8 4 - - 46 8 36.5 53.4 Ampharete labrops 10 10 16 30 4 10 10 440 42 22 - 4 38 8 25 8 4 35.8 104.1 Amastigos acutus - - 250 260 80 4 50 - 4 - - - - - - - - 34.1 84.5 Typosyllis spp. 120 170 - 80 - - 30 30 40 - - - 42 33 29 38 13 - - 32.9 47.1 Leptocuma forsmanni 20 10 20 20 60 30 20 - 4 11 8 33 29 88 121 42 33 63 10 32.7 31.4 Isocheles pilosus - 4 10 - - 330 - 20 10 - - 6 - 100 96 - 8 - - 30.7 82.4 Leptopecten latiauratus 5 - 40 - - 30 40 20 10 290 29 6 - - - - - 24.7 69.2 Thalenessa spinosa- 20 50 30 4 17 20 21 20 20 110 59 - 17 8 17 - 21.7 27.3 Rhepoxynius spp. 5 10 10 120 - 20 10 - - - 50 17 29 55 4 17 8 18.7 30.6 Nevedta recluziana - - - - 6 4 10 20 10 130 42 6 8 13 8 - - - 13.5 31.4 previously Prionospio cirrifera previously Cistena califomiensis previously Eusigalion spinosum urce:MBC 1975-1992 City of Huntington Beach April 5, 2005 5.10-8 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES Figure 5.10-1 D INTERANNUAL VARIATION IN HUNTINGTON BEACH INFAUNAL ABUNDANCE AND SPECIS RICHNESS, 1975-1993 LJ 2s a �. L / \ J 20 i5 ._.; .... .........l.________._____ -------- ------- ____........,/._._ a W / a N ,o . a W 100 ~ W 8o cc 1-1 60 * I� -J 40 _�_'� -Moon. ._. ._. . ........._. ;�/ ♦-+R 20 z 0 a75 77 79 .81 83 85 87 89 91 93 YEAR a MACROFAUNAL INVERTEBRATES AT HUNTINGTON BEACH, 1976-2001 lists key macrofaunal invertebrate species surveyed at Huntington Beach. Graphs showing animal abundance and species number for the area reflect the range of annual differences that commonly occur in shallow water habitats (refer to Figure 5.10-2, INTERANNUAL VARIATION IN HUNTINGTON BEACH MACROFAUNA ABUNDANCES AND SPECIES a RICHNESS, 1975-2001). Average abundances of these and other organisms and total species number varied from year to year. In 1975 and 1980 only 21 species were recorded. In 1994 just after the 1992-1993 El Nino, there were 54 species (Figure 5.10-2). Animal densities also vary considerably, from less than 20 per square meter in 1975 and 1976 to over 160 per square meter in 1990. From 1975 to 2001,five animal groups(three annelid[polychaete]worms[Diopatra,Owenia, Maldanidae], hermit crabs [Paguridae] and Pacific sand dollars [Dendraster excentricus]) account for about 90% of the marcrofaunal abundance. The relative numbers of these organisms vary from year to year and in different localities and they could be especially a abundant, with as many as 3,600-9,000 individuals of various species (sand dollars, polychaete worms, hermit crabs) being taken in one otter trawl net at one sampling site. Pacific sand dollars,for example,were found in great abundance near the discharge and at the upcoast sampling area in 1997, but had not been found in these areas in the preceding four years and have appeared variably at all stations over the survey and are not consistently found in the waters around the HBGS. ❖ Fishes: Since the fish surveys began,65 species have been collected, all of which can be considered as typical residents of open,sandy bottom coastal habitats in southern California (Horn and Allen, 1978; Mearns, 1979; Allen and DeMartini, 1983). The numbers of fish species taken in Huntington Beach trawl surveys ranged from 13 in 1999 to 29 in 1986 and p 9 Y 9 averages 22 species/year. The fifteen most abundant fish species living in the area between 1976 and 2000 are: white croaker, queenfish, northern anchovy, California halibut, Pacific I City of Huntington Beach April 5, 2005 5.10-9 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES Table 5.10-3 MACROFAUNAL INVERTEBRATES AT HUNTINGTON BEACH, 1976-2001 Year Percent 1975 1976 1977 1978 1979 i980 19a1 1982 1963 1964 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 Mean Total Total Number of Specks 21 36 23 27 48 21 39 24 25 54 43 36 43 32 46 29 37 32 40 29 26 29 26 31 24 27 25 32.4 Mean Number of Individuals(per m') 13.6 11.8 11.8 19.3 93.3 107,3 502 u9 4 78.0 73,7 61.8 49.9 1391 63A 150.7 22.0 56,1 405 58.1 53.6 362 51-0 664 539 49.4 54.5 51.3 61.0 Mean tlSiliCS 01 Key_Species_{pe�m?) ninpatra spp 10.2 51 7,7 10.2 109 17.6 19.1 232 28.6 281 439 39.1 26.2 102 7.9 11.1 40,0 19.6 42.A 43.8 29.0 40.0 23.3 45.5 421 44.7 38.2 26.2 45.1 Pagundea,unid.(includes lsocheles sp) 0.0 1.8 1.1 0.2 2.0 0.2 1-6 904 0.7 05 37 0 7 101 9 13.6 128.3 0.5 0.3 10.7 0.3 0.4 0.1 0.5 0.4 01 02 01 07 13.4 23,0 owenia spp 21 67.5 859 16.2 - 6.6 18 OA 0.0 1,8 1,1 0.6 7.4 0.0 O.0 0.1 0.0 0.0 0.2 7.1 12.2 Rendraster excerltricus ISO 70.2 0,0 25 11.8 1.1 0.4 - - 36.9 - 4.0 6.9 Maidanidae,unid 0 1 0.2 1,3 1:2 2.7 0.0 10 03 03 0,6 23 0,2 1 1 10 10 2.8 31 71 3.6 0.2 08 1.2 1.7 0.6 0.5 08 1.6 1.5 2.5 Othiuroidea,unid. 0.t 0.0 0.0 0.1 0.2 00 0.3 1.2 2 1 07 1.9 04 06 2.9 1.5 04 3.7 1.2 1.5 1.4 1.4 26 1.6 3.3 1.0 1.1 1.9 teplopecten latiatrratus 0.1 0.1 0.3 1.5 0.0 14.0 0.0 - 0.0 01 0.0 0.9 0 1 01 0.0 0.0 0.0 0.2 0.2 0.7. 1A 8atanus spp 0.0 0.3 0.3 OA 2.6 2 1 00 01 02 0.3 2.3 01 0.1 0.3 1.7 0,9 OA 2-1 01 01 1,8 1.5 0.7 1.1 Crepiduta spp 01 0.1 1 7 0:1 0.6 0,7 0.7 0.5 0.9 0.9 0.9 0.3 0.3 0.5 1.9 O.0 05 0.1 0.1 1.8 0.5 O.6 Maµdae,unit 01 0-1 0.0 01 OO 0.1 0.7 1,5 OA 2.5 0,5 05 0-7 08 4.5 0.5 0.3 Zaolutus actius 0.0 0.0 - OA 0,0 1,0 00 0.6 06 0.0 0.2 01 - 0.0 0,1 0.9 0.2 0.7 0.5 02 08 22 05 02 0.3 0:6 ouveita spp 1.9 0.2 0.0 0.2 - OA 0.0 - 07 0.4 0.0 01 22 0,3 0.1 0.0 0.0 0.3 0.0 0,1 0.2 01 0.1 0.3 0.4 Spicchaetopierus costanrm 01 0.1 0.0 0.1 0.2 0-1 02 O.1 0 1 01 07 01 06 0,5 1-0 0.7 0.1 0.0 01 OD 0.9 05 0.2 0.4 Asiropectenannatus 00 0.1 0.1 OA 0,0 0.0 0.1 01 0.1 01 Ot 0.1 0.1 00 01 0.3 09 03 0.4 0,5 0.4 0.6 0.1 01 0,2 02 0.4 0.2 0:3 Oendrorlotus/rondosus 4.0 0,0 - - D 1 0.3 1 Nassanus app 0.0 0.0 0.1 0.0 01 0.8 0.1 0.1 0.3 1,6 0.1 0,1 0.1 0,0 01 OD 0.2 00 02 01 0.1 OA o3. Asia spp - 0 1 0 1 Mo 0.1 0.1 0.2 0.2 0.6 0.1 1,2 - 0.2 0.3 0.2 0.1 OA 00 - 0.0 0.0 0.1 0:2 Hiatelta arctica 3 3 02 00 0 0 0'0 0.1 0:2 PhyWhaetopterus spp 0 4 0.0 113 0.8 0.6 0.1 0.2 Slytalula e"aita 0.0 0.0 0.0 0.0 0.2 0-2 0.0 - 0,1 0.6 0.4 0.3 0 1 0.4 0.3 0.1 0.2 0.2 0.1 0.2 Randle kolliken 0,0 0,0 00 - 0.0 0.1 OA 0.3 0.2 0.2 0.2 01 OA 0.2 0.2 0.2 0 t 0 1 0 1 Or 0.2 0.1 OA 0.2 Soren spp 1 1 0.0 1.2 0.3 0.2 MG - 0.1 02 ' Pyromais fubercutats 0 0 0 0 0.2 0.7 00 0.0 04 0.2 0.0 00 0.0 0.0 00 0.0 - 0-1 0.3 0 2 0.4 0.0 0.1 0.2 Chaetopterus varfopedatus Cmplx 0.6 0,1 0.0 0,1 0.1 0.3 0.2 01 0.2 0.2 D.4 0.1 0.1 0,1 0.2 Hanlnactis affenuala 0.1 OA 0 0 0 1 0.3 0 2 0,4 0.35 0.8 OA 0.1 Potygireofrma rutila(Batts ruf4a) 0.0 0'0 0.0 0.1 00 0.0 0 3 0.5 04 0 5 0.1 01 0.02 0.t 0.1 Thalamotporeth spp 0.1 0.1 0.2 0.2 0 4 01 0 1 0.1 0.0 01 0.0 0.2 - 0.1 0.1 Neverira rectusiana 0 0 00 0 0 00 0.0 00 0 1 0 1 0 1 0 2 0 1 0 1 0 1 OA 0 1 0.1 0.0 0.1 0.2 0.1 OA 0.0 00 0 0 00 0.0 0.1 0.1 Ophiodermetla spp 0 0 on - 0 1 0.3 0 0 - 0 1 00 0.0 0.0 0.0 01 OA - - 0.0 0.0 0.1 0.2 0.2 0.1 0.1 0.1 Anthozoa,unit 0/ 0 4 0 4 0 3 0.1 0.0 0.1 Argopeclen circtdaris 0 3 0.0 01 0.01 01 0.0 0.1 For 1975 and 1978 data was taken from the same 5 stations sampled since 1977 we, 0.0=<0 05 Source: MBC,2001 City of Huntington Beach April 5, 2005 5.10-10 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES Figure 5.10-2 INTERANNUAL VARIATION IN HUNTINGTON BEACH MACROFAUNA ABUNDANCES AND SPECIES RICHNESS, 1975-2001 30 z o n a 20 overall Mean W ........... .... ...... ................. .......................................... ....... ....... ... ....... ......... ...... 15 w �,1 t0 N V 5 U( W a 0 180 Leo 140 r E 120 o 100 � tso N80 _.Meaty..................................................... ..... ........... Z p 40 20 o VCAD sardine, speckled sanddab, curflin turbot, kelp pipefish,white seaperch,walleye surfperch, C-O turbot, Pacific butterfish, California lizard fish, salema, and barred surfperch (refer to Table 5.10-4, YEARLY ABUNDANCE OF DEMERSAL FISH SPECIES COLLECTED BY OTTER TRAWL AT HUNTINGTON BEACH, 1976-2001). The persistent representation of the same species indicates that the fish fauna is relatively stable. Conclusions of the MBC Monitoring The overall findings of MBC in its NPDES monitoring program are as follows (MBC, 2001): `J Operation of the HBGS had no detectable adverse effects on the marine biota or the beneficial uses of the receiving waters: ❖ There are strong indications that a relatively stable assemblage of organisms occur in the marine habitats near the discharge and, although the numbers and relative abundance rankings of species shift from year to year, no species has either been recruited to or eliminated from the area; ❖ All of the organisms occurring in waters adjacent to the HBGS have much broader geographic distributions, extending in most instances to beyond the range of the Southern California Bight; •'• Both the sea floor and littoral water habitats occurring near the HBGS discharge site are not • home to any endangered marine species; r L City of Huntington Beach 5.10-11 April 5, 2005 j L Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES Table 5.10-4 YEARLY ABUNDANCE OF DEMERSAL FISH SPECIES COLLECTED BY OTTER TRAWL AT HUNTINGTON BEACH, 1976-2001 Yew .. Percent 1976 1977 1974 1979 1980 1961 1982 1963 1984 1965 1986 1987 1985 1909 1990 .1991 1992 1923 1994 1995 19" 1997 199a 1999 2000 2001 Total Tote! Erignufts monw 355 3126 2460 6253 166 3138 1 8401 1145 5 61 40 386 11 Aaptr 301 3916 XM 507 221 626 35 1409 - 52a 9 12a23 $0.205 Gottyonanwsrinsahn 1773 3743 7503 2405 3407 1324 3C9 1177 1021 890 1200 1017 663 28 239 75 3878 4555 913 780 24 473 103 1 lie 390 385D9 26.615 Serip1wspoh!w 1822 134 1119 297 1712 25N 529 39% 3058 677 695 303 116 1 602 64 3883 2595 S72 6S4 91 430 169 495 125 26728 18,427 prw lw000rt AN;wus 59 275 14e 406 22 378 13 63 4 18 10 4 1 1 2 9 6 5 1 1 1426 0.90 HYPwPrn�P 5mtsar US 254 148 75 76 33 - - - - 11 - 1 3 - - 12 1 2 20 781 0,538 Pana kNhys caWbtnt 7 80 51 12 25 35 72 22 24 40 31 39 52 28 19 25 41 t 7 1 t a 4 13 5 7 1 11 678 0.467 Anlp�&gSrkatts 18 208 34 157 26 32 2 1 _ 1 1 8 2 4 1 6 6 517 0 356 Offi-ahthyt stgmeeu3 14 85 5 2 6 17 51 6 67 43 25 40 14 5 8 20 5 21 3 9 18 22 11 497 0.343 PepaAa srniJCms 66 1 41 4 13 2 2 i 31 105 4 15 - 2 23 2 12 - 5 1 38 475 0.327 Cymah0gRsrrvag0rw2ara 7 62 4t 160 13 76 7 45 1 1 3 1 4 5 1 2 16 4 13 465 0321 srwAskrcixVs 5 27 7 10 223 1 3 - 3 3 3 39 11 2 31 - 1 9 29 21 428 0.295 pteuro�hys drreri 2 2 1 1 12 1 7 11 7 32 21 25 4 20 6 5 2 1 1 161 OA i t Xysiratny3 hokT"S .3 1 2 3 4 32 8 4 18 3 14 9 6 5 12 5 5 1 4 1 8 1 3 150 0.103 Saroirtops sage( 2 67 - 7 12 0 45 - - 142 0.098 Leptwwtttm armahn 8 / 1 2 - 38 4 6 49 4 2 5 6 2 1 3 6 2 140 0.097 Merry-+ftis wo'Alus 5 3 9 21 2 2 8 8 3 16 6 2 2 - 2 1 3 4 1 1 10 14 1 4 130 0.090 ArWioa cumpmm - 1 1 1 1 4 t 1 10 30 6B 118 0.081 SrVV"txvs atrauda 10 11 1. 2 1 ! 5 3 6 11 a 13 9 4 - - 6 - - - - 105 0.072 Syrvmthvs ttpp. 5 39 5 2 1 2 4 1 - - 6 4 14 1 4 5 1 1 1 2 -2 100 0,059 Pk-iran ehthys V06caus 5 6 le 2 4 5 11 1 1 19 2 9 - 3 9 1 AS 0 065 A(y#0bari3 caffro'rrlea 1 t 9 t 4 1 t0 1 t 1 1 1 4 8 5 2 16 04 0.05a OphLat scrfpp— 1 1 43 - 1 - t 22 - 1 1 71 0.049 l'};,"k)ok§s Inww6ta 9 3 t 2 1 13 3 13 4 e 2 1 1 t 2 53 0.041 HypsopsgWe"Wala 1 3 2 3 1 6 6 2 2 2 2 1 1 - 1 2 35 0.024 paqarabral nebover 1 3 3 3 +. 4 1 2 2 2 1 1 2 1 1 - 25 0,019 CheHotroma saAkyli l . . . 2 .. 13 1 2 2 1 - _ 1 3 1 28 0.018 EmNro(=/ackso6 6 1 - 10 1 _ 4 22 0 015 PhNdWtG!PAVLXfut 2 3 2 1 - • - - t - 1 6 1 1 18 0,012 btusrokrs har*o 1 3 1 1 1 t t 1 5 1 16 0.011 Hefaras"[nus mstrarus . , . 1 • 2 1 2 1 1 2 1 - 12 0,003 porrctohysmvmster 4 1 - 2 1 2 1 12 0.008 Sphyriem agWtea 4 4 1 9 0.005 Arftori, si3 oaftorrrensi.3 1 1 - _ 2 1 1 1 1 8 0.005 Squaws acarw1 33 3 2 ? 1 8 0,005 AUneoscion rsc6Y3 - 3 2 1 6 0.004 Crmrrds t:tmcti'dmis t 2 2 1 6 0.004 D-J,7 irrr,mys Vacca 1 1 t 1 2 6 0,004 Gko"rxvd arts 1 j t 5 0.003 Paraabra,6latrvahn 1 t 1 1 1 5 0,003 Wrosiomas pa Jan 4 4 0 003 Syngnatlurs cavomiensis 4 4 0,003 C.-"rtr ttiyson 3 _ 3 0,002 Soapaem guttata 1 1 1 3 0.002 7nfchsenrs symrneh>ats 1 ! 1 3 0.002 Xerdshus cakrck nsis 3 3 0.002 crU -Nhys jr&w-tq.,+a 2 2 0 001 Leraesthas tenors Ptwxorrsdes returtn , t 2 0.001 Po&IhMrsrtotptus 1 1 2 O'Dol so asws pavof pot s 1 t 2 0.001 City of Huntington Beach April 5, 2005 5.10-12 Seawater Desalination Project at Huntington Beach 5.1000EAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES Table 5.10-4 (CONT'D) EPIBENTHIS INVERTEBRATES AND FISHES COLLECTED BY TRAWL AT HUNTINGTON BEACH, 1976-2001 Year . Percent 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1995 1997 1998 1999 2000 2001 Total Total Triakis semitasciata - 1 - 1 2 0.001 Anchoa delicatissima 1 1 0.001 Dorosoma petenense 1 1 0.001 Galeorhinus zygopleros 1 1 0.001 Gibbonsia elegans 1 1 0.001 Halichoeres semicinctus 1 1 0.001 Heterodontus francisci 1 - 1 0.001 Hypsoblennius gilberti 1 1 0.001 Pleuronichthys coenosus 1 1 6.001 Pleuronichthys decurrens 1 1 0.001 Raja inomata 1 - - - - - - - 1 abol Scomber japonicus 1 - 1 0.001 Sebastes serranoides 1 1 0.001 Semicossyphus pulcher 1 1 0.001 Torpedo califomica 1 1 _ 0.00_1 Number ofindMduals 4309 8068 11693 9834 5508 7613 1256 14513 5392 1836 2102 1572 1402 194 20638 606 11808 26963 2078 1696 986 1031 1933 82 1314 621 145050 Number of species 21 28 28 22 24 23 19 28 20 25 29 21 26 19 20 18 21 25 23 17 14 21 23 13 17 17 65 Number of stations sampled 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 12 6 6 6 6 6 6 6 6 Source: MBC,2001 City of Huntington Beach April 5,2005 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES ❖ The area does not have any "environmentally sensitive" habitats such as eel grass beds, surf grass, rocky shores, or kelp beds; and ❖ The movement, abundance, and diversity of invertebrate and fish populations along the Huntington Beach coast appear all to be in response to natural ecological factors and not in any way influenced or affected by the HBGS discharge. REGULATORY FRAMEWORK California Ocean Plan State Water Resources Control Board SWRCB and its nine Regional Since 1973, the CaliforniaSae ( ) g Water Quality Control Boards (RWQCB) have been delegated the responsibility for administering permitted discharge into the coastal marine waters in California. The SWRCB prepares and adopts the Quality Control Plan for Waters of California(Ocean Plan),which incorporates the water quality control standards that apply to all NPDES permits. The SWRCB adopted the Ocean Plan on July 6, 1972. Since 1972, the Ocean Plan has been amended a number of times, most recently in 2001. The Ocean Plan establishes beneficial uses to be protected, water quality objectives and a program for implementation needed for achieving the water quality objectives. The beneficial uses of the ocean protected by the Ocean Plan include: preservation and enhancement of designated Areas of Special Biological Significance(ASBS);rare and endangered species; marine habitat; fish migration; fish spawning; shellfish harvesting; recreation; commercial and sport fishing; mariculture; industrial water supply;aesthetic enjoyment; and navigation. The Ocean Plan's water quality objectives for California's ocean waters and provide basis for regulation of wastes discharged into the State's coastal waters. When a discharge permit is written, the water quality objectives defined in the Ocean Plan are converted into effluent limitations that apply to discharges into State ocean waters. These effluent limitations are established on a discharge-specific basis depending on the initial dilution calculated for the facility discharge outfall. The regulatory agency with jurisdiction over the discharge from the Huntington Beach seawater desalination facility would be the SARWQCB. The Ocean Plan's narrative and numerical water quality objectives are based on bacterial, physical, chemical, and biological characteristics as well as radioactivity. The water quality objectives in the Ocean Plan are established for protection of human health from both carcinogens and non-carcinogens. Within the Ocean Plan there are 21 objectives for protecting aquatic life, 20 for protecting human health from non-carcinogens, and 42 for protecting human health from exposure to carcinogens. The numeric objectives of the 2001 California Ocean Plan Table B would apply to discharges from J � � PPY 9 the proposed desalination facility (objectives currently apply to discharges from the AES power plant),and would be evaluated by the Regional Water Quality Control Board as part of the NPDES permit for the project. The NPDES permit(No. CA0001163)issued to AES Huntington Beach, LLC by the SARWQCB includes specific monitoring requirements for monitoring the discharges through the outfall. Those requirements would continue to apply. In addition,the project would be required to obtain a separate NPDES permit from the SARWQCB that would also include monitoring requirements. The RWQCB's Ocean Plan human health standards are designed to protect the beneficial use of body-contact recreation. The discharge from the desalination facility would be required to meet all Ocean Plan standards regulated by the SARWQCB. Based on the Water Quality Management Plan (WQMP)for the Santa Ana River Basin,the Pacific Ocean's nearshore waters in the project site vicinity serve multiple beneficial uses. Existing beneficial uses within the coastal vicinity include: industrial service supply,navigation,contact water 1 recreation (swimming, diving), non-contact water recreation (sailing, tide pool studies, aesthetic ` enjoyment,etc.),commercial and sport fishing,wildlife habitat support, rare/threatened/endangered City of Huntington Beach April 5, 2005 5.10-14 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES species habitat support, spawning/reproduction/development habitat support, marine habitat, and shellfish harvesting. No "potential uses" for the project vicinity(as categorized within the WQMP) have been recorded. This project does not require that the Pacific Ocean in the vicinity of the intake be designated as supporting the beneficial use of drinking water (MUN). The Sources of Drinking Water Policy, adopted by the State Water Resources Control Board in 1988, requires that all waters of the state, with certain exceptions, be protected as existing or potential sources of municipal and domestic l supply. One of the exceptions is water with a total dissolved solids(TDS)concentration exceeding 3,000 mg/L,which is applicable to the Pacific Ocean. The MUN designation affords some additional chemical protection of a waterway because maximum contaminant levels(MCLs)are to be achieved v' formicrobial contaminants because in ambient waters. There is no additional protection provided o MCLs have not been established for pathogens or coliforms. The Pacific Ocean in the vicinity of the intake is high quality and,in fact, has concentrations of some chemicals that are far below the drinking water MCLs prior to any treatment. An MUN designation would not provide any additional protection because the intake water quality is not influenced by storm water discharges, 9 the Santa Ana River,the Talbert Marsh, or the Orange County Sanitation III District(OCSD)wastewater discharge,as described in the hydrologic modeling studies included in Appendix C, HYDRODYNAMIC MODELING REPORT. Requiring these discharges to meet MCLs in ambient waters would provide no improvement in water quality at the intake to the desalination facility. Water Quality Control Plan for Control of Temperature in the Coastal and Interstate Waters u and Enclosed Bays and Estuaries of California (Thermal Plan) The State Water Resources Control Board's Thermal Plan regulates the discharges of elevated temperature wastes(thermal discharges)into coastal waters of California. The main purpose of this plan is to assure protection of the beneficial uses and areas of special biological significances from excessive thermal discharges. A key plan objective is to reduce the overall amount of thermal load �J discharged in State waters, including coastal waters. The Thermal Plan limits the maximum temperature of thermal discharge to Coastal Waters to 20 degrees Fahrenheit over the ambient ocean water temperature. This plan also requires the discharge of elevated wastes to the ocean not to cause a temperature increase in the natural water by more than 4 degrees Fahrenheit at: (a)the shoreline, (b)the surface of any ocean substrate,or (c) the ocean surface beyond 1,000 feet from the discharge system. The surface temperature limitation is to be maintained at least 50 percent of the duration of any tidal cycle. SARWQCB Water Quality Control Plan (Basin Plan) JL The California Ocean Plan,the Thermal Plan and other plans and policies adopted by the SW RCB are incorporated into the Basin Plan. A revised Basin Plan for the Santa Ana region became effective on January 24, 1995. In 2004,the Basin Plan was amended. This plan specifies beneficial uses and water quality objectives for waters in the "Nearshore Zone" and "Offshore Zone" of the , Pacific Ocean in the Santa Ana region. The "Nearshore Zone" is defined by the Ocean Plan, Chapter ll, A.1 as "a zone bounded by the shoreline and a distance of 1,000 feet from the shoreline or the 30-foot depth contour,whichever is f further from the shoreline". The "Offshore Zone" is the area bounded between by the "Nearshore Zone" and the limit of the State waters. L City of Huntington Beach April 5, 2005 5.10-15 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES NPDES Permit To comply with regulatory requirements the applicant applied to the SARWQCB for a NPDES permit on May 15, 2003. The NPDES permit application included: ❖ Submission of an application; ❖ Submission of an Engineering Report including; • Facility Description; • Facility Waste Streams; • Waste Streams Characterizations; • California Ocean Plan Requirements; and _ Antidegradation policy Applicability. It is expected that the SARWQCB may include provisions in the NPDES permit pertaining to the following: �` ❖ Discharge Water Quality Limits; and ❖ Water Quality Monitoring and Reporting. In summary,through issuance of a NPDES permit for the proposed project,the SARWQCB would require that the objectives for marine water quality as defined in the California Ocean Plan, Water Quality Control Plan for Control of Temperature in the Coastal and Interstate Waters and Enclosed Bays and Estuaries of California, and SARWQCB Basin Plan that would apply to the proposed project include: ❖ Bacterial Characteristics: Samples of water from each sampling station shall have a density of total coliform less than 1,000 per 100 mi (10 per mi), provided that not more than 20 percent of the samples at any sampling station, in any 30-day period, may t exceed 1,000 per 100 mi (10 per mi), and provided further that no single sample when verified by a repeat sample taken within 48 hours shall exceed 10,000 per 100 mi (100 per mi). In addition,the fecal coliform density based on a minimum of not less than five samples for any 30-day period,shall not exceed a geometric mean of 200 per 100 mi nor shall more than 10 percent of the total samples during any 60-day period exceed 400 per 100 mi. For all areas where shellfish may be harvested for human consumption, as determined by the Regional Board,the median total coliform density shall not exceed 70 per 100 mi, and not more than 10 percent of the samples shall exceed 230 per 100 mi. Physical characteristics: Ocean waters shall be free of visible floating particulates, j grease,oil,and discoloration. Natural light shall not be significantly reduced at any point outside the initial dilution zone as the result of the discharge of waste. In addition, the rate of deposition of inert solids and the characteristics of inert solids in ocean sediments shall not be changed such that benthic communities are degraded. ❖ Chemical Characteristics: The dissolved oxygen concentration shall not at any time be depressed more than 10 percent from that which occurs naturally as a result of the discharge of oxygen demanding waste materials, while the pH shall not be changed at any time more than 0.2 units from that which occurs naturally. In addition,the amounts of dissolved sulfide, nutrient materials, and harmful substances in marine sediments shall be limited so as not to negatively impact marine life. ❖ Biological Characteristics: Marine communities, including vertebrate, invertebrate, and plant species shall not be degraded. In addition,the natural taste,odor,and color of City of Huntington Beach April 5, 2005 5.10-16 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES marine resources used for human consumption shall not be altered, nor shall the concentration of organic materials bioaccumulate to levels that are harmful to human health. ❖ Radioactivity: Discharge of radioactive waste shall not degrade marine life. IMPACTS Significance Criteria Based on the CEQA Guidelines, Appendix G, the project would have a significant effect related to water quality if it would: •'• Violate any water quality standard or waste discharge requirements; it :• Otherwise substantially degrade water quality. The significance thresholds for biological resources that are identified in Appendix G of the CEQA Guidelines are applicable primarily to terrestrial biological resources. With respect to marine biological resources, guidance in developing appropriate significance thresholds has been taken from the California Coastal Commission(CCC)because the CCC must consider potential impacts of the proposed project before issuing the necessary Coastal Development Permit. In a recent report, dated March 2004, and updated September 2004, the CCC indicated concerns about potential l� impacts on the marine environment resulting from seawater desalination. The stated concerns in 1 this report are: ❖ Increased salinity of the effluent; ❖ Potential detrimental effects from chemicals added to the seawater during the desalination process; and ❖ Potential for impingement and entrainment in the intake system to degrade the quality of assemblages in the local or regional marine environment. n These generalized concerns encompass the range of potential effects of the desalination facility on ocean water quality and marine organisms,and therefore are the primary focus of this Recirculated EIR for determination of significant effects of the project. Elevated Salinity C7 EPA (1986) policy on discharge effects related to salinity acknowledges that fishes and other aquatic organisms are naturally tolerant of a range of dissolved solids concentrations(in this case salinity) and must be able to do this in order to survive under natural conditions. Also, marine species do exhibit variation in their ability to tolerate salinity changes. EPA(1986)recommendations state that, to protect wildlife habitats, salinity variation from natural levels should not exceed 4 ppt when natural salinity is between 13.5 and 35 ppt. The average ocean salinity at Huntington Beach and over a vast expanse of ocean area around it is 33.5 ppt. As applied to the proposed project, I discharge scenarios that do not permanently elevate salinities to 37.5 ppt(a 12 percent increase)or greater outside of a reasonable distance from the discharge core would appear effective in not adversely affecting marine organisms. The study prepared by Dr. Graham (Appendix S) specifically addressed potential effects on local species passing through the area surrounding the discharge core,as well as the potential effects on i� City of Huntington Beach April 5, 2005 5.10-17 #1 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES bethnic organisms living in the area surrounding the discharge core. The study incorporates numerous references and examples where no substantial ecological losses to source populations of marine organisms were observed from short-term exposure to elevated salinity levels. Based on the results of the referenced studies the following threshold for significant impacts on marine organisms from elevated salinity was defined for the site-specific conditions of the Huntington Beach project: ❖ Significant impacts related to elevated salinity would occur if the project would discharge salinity levels that result in substantial ecological losses to source populations of marine organisms; and/or ❖ Permanent elevation of salinity levels to 37.5 ppt or greater outside of a reasonable distance from the discharge core would be significant. Chemical Discharge Significant impacts related to chemical discharge would occur if the project would discharge any chemical wastes that would result in substantial ecological losses to source populations of marine organisms. Impingement and Entrainment Effects related to impingement and entrainment would be considered significant if: ❖ The impingement effects (trapping of larger organisms on intake screens) of desalination , s facility operations result in substantial ecological losses to source populations of the impinged species; and/or ❖ The entrainment effects (loss of small planktonic organisms passing through cooling water system) of desalination facility operations result in substantial ecological losses to source populations of the entrained species. OCEAN WATER QUALITY Oceanographers from the Scripps Institution of Oceanography conducted modeling studies using a computer model that simulates ocean conditions near the HBGS intake and outfall (refer to Appendix C,HYDRODYNAMIC MODELING REPORT).The model calculates the degree of mixing of various potential contaminant sources with the Pacific Ocean. The Santa Ana River, Talbert Marsh, OCSD wastewater discharge outfall, HBGS discharge and proposed desalination facility discharge were all investigated. Seawater contamination resulting from any of the above sources could potentially impact the quality of desalinated product water and,to some degree,the quality of byproduct concentrated seawaterwaterto be discharged from the HBGS outfall. The model results show the amount of dilution of each of these sources of pollutants under different oceanographic conditions. The modelers from Scripps used their many years of experience working along the Southern California coast to determine the"worst case"conditions that would be modeled. The"worst case" conditions were chosen to determine if any adverse water quality or environmental impacts occurred under extreme ocean and weather conditions that were most likely to show an effect. For example, the effect of the Santa Ana River and Talbert Marsh storm water on water quality at the HBGS intake was modeled assuming a very large, prolonged storm event and ocean currents flowing from the i City of Huntington Beach 5.10-18 April 5, 2005 ' Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES mouth of the river towards the HBGS facility. Normally, ocean currents flow in the opposite direction, down the coast (southeast) away from the HBGS. Potential Sources of Contamination in Proximity to the HBGS Intake OCSD Wastewater Discharge As stated above, the OCSD sewage treatment facility discharges a mix of primary and secondary g P rY treated wastewater at an outfall located 4.5 miles offshore at a depth of 195 feet. However,it should be noted that OCSD has committed to provide secondary treatment for 100 percent of all effluent it receives. The development of facilities to provide this additional secondary treatment could take up to 11 years to plan, design, construct, and commission. A more detailed implementation plan is being developed by the District. In addition, on August 12, 2002, the OCSD began disinfecting its wastewater per RWQCB requirements. The OCSD is presently adding bleach as a disinfectant followed by sodium bisulfite to remove residual prior to ocean discharge, and will continue to do so for the next three to five years. Testing and studies are underway to evaluate other disinfection technologies, including ultraviolet light, ozone, and peracetic acid for long-term application. The OCSD wastewater discharge would have the greatest potential to impact water quality at the HBGS intake with summer El Nino conditions when currents are flowing northwest towards the HBGS. In addition, for worst case conditions, the model assumed that: ❖ OCSD was discharging at its maximum allowable rate of 480 mgd; ❖ The temperature conditions in the ocean would allow the wastewater plume to be near the depth of the HBGS intake; ❖ A current-would travel upcoast (northwest); F7 ❖ End of pipe total coliform counts would be at the mid-to high end of operational ranges prior L to OCSD disinfection resolution; and ❖ HBGS would operate at a maxium flow rate and intake velocity(507 mgd and two feet per second, respectively). It should be noted that these conditions are atypical and the likelihood of them occurring simultaneously is extremely low. L The worst case model results show that the OCSD discharge is diluted 30 million to one at the HBGS intake. Any contaminants discharged at the OCSD outfall would be diluted far below background levels at the intake to the HBGS. Therefore,the OCSD discharge was not found to be a significant source of contamination at the HBGS intake. Furthermore, the proposed desalination project discharge is not expected to have a measurable impact on the OCSD's wastewater treatment plant effluent water quality, and therefore will not F require changes to OCSD's monitoring program or additional monitoring in the currently monitored ) area. According to hydrodynamic modeling prepared for the project,the"low flow"scenario ocean water salinity increases as a result of the desalination facility discharge, and discharge salinity concentration will diminish to levels close to the background ocean water salinity of 33.6 ppt before it reaches the OCSD outfall and monitoring area. The accuracy of the currently available instrumentation for seawater salinity measurement is+/-0.1 ppt. Under the"low flow"scenario the discharge salinity concentration of the desalination facility discharge decreases to 33.6 ppt(within+ City of Huntington Beach April 5, 2005 5.10-19 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact,Report MARINE BIOLOGICAL RESOURCES 0.1 ppt of the background seawater concentration of 33.5 ppt in less than 2,000 feet from the desalination facility point of discharge. The OCSD discharge outfall is more than five miles(26,400 feet) away from the power plant outfall. By the time the desalination facility discharge reaches the OCSD monitoring area,the salinity change contributed to the desalination facility discharge will be within the range of natural variability, and therefore, will be non-detectible. Refer to Appendix C, HYDRODYNAMIC MODELING REPORT for additional information. As far as other constituents of concern for the OCSD discharge, the desalination facility discharge water quality would be well within the limits established in the Ocean Plan. Therefore, the desalination facility discharge is not expected to have any measurable effect on the results of the OCSD's monitoring program. Urban Storm Water Runoff The Santa Ana River drains a highly urbanized watershed of 1,700 square miles and flows into the ocean approximately 8,300 feet southeast from the intake to the AES facility. The Talbert Marsh, which receives urban runoff from the City of Huntington Beach and several other communities, discharges to the ocean about 7,000 feet southeast from the AES intake. Under typical conditions, the discharges from the Santa Ana River and Talbert Marsh flow away(southeast)from the AES intake. However,there are times when the currents flow northwest and carry river and marsh water towards the AES facility. Since freshwater is less dense than seawater, the river and marsh discharges normally float on the surface of the sea and are slowly mixed into deeper waters. During �r storms, winds and waves can mix the river and marsh plumes into deeper water more rapidly. Storm water discharges from the Santa Ana River and Talbert Marsh would have the greatest potential to impact water quality at the HBGS intake if an extreme storm event coincided with an El Nino winter and maximum pumping of cooling water into the generating station. Although it is unlikely that all of these events would coincide with one another, this was considered to be the "worst-case" scenario for determining if the Santa Ana River and Talbert Marsh contribute contaminants to the HBGS intake. The model results show that during a 24-hour extreme runoff period only 0.0003 percent of the ' water at the HBGS intake would come from the Santa Ana River and Talbert Marsh and the remaining 99.9997 percent would be seawater. These results show that contaminants are not transported to the HBGS intake from the Santa Ana River and Talbert Marsh during extreme storm ^ conditions. More detailed modeling results are presented in Appendix C, HYDRODYNAMIC MODELING REPORT. Impacts are not anticipated to be significant in this regard. Dry Weather Runoff The mouth of the Talbert Marsh Ma is closed by sand spits for short periods of time during the dry season. This can trap up to 200 million gallons of urban runoff and seawater in the Marsh and lower channel system. When very high tides rise over the sand spit,the mouth of the Talbert Marsh opens and 80 to 100 million gallons of water can be released into near shore ocean waters in a single tidal _ flush. Because Talbert Marsh waters are similar to seawater salinity in the dry season, the ' discharge does not float on the sea surface and may quickly mix into deeper ocean waters where the HBGS intake is located. Tidal flushing of the Talbert Marsh would have the greatest potential to impact water quality at the HBGS intake during high spring tides combined with summer El Nino conditions when currents are flowing northwest from the marsh towards the intake. The model showed that under these worst case conditions,the marsh water is diluted 20,000 to one and essentially does not reach the intake. This is due to the fact that the marsh water is released into the surf zone and the onshore waves City of Huntington Beach April 5, 2005 5.10-20 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES keep the marsh water in the shallow nearshore waters,whereas the HBGS intake is located 1,840 feet offshore at a depth of approximately 33 feet. Impacts are not anticipated to be significant in this regard. Recirculation of HBGS Discharge The HBGS outfall is located approximately 1,500 feet offshore and 340 feet from the HBGS intake. �f The potential for recirculation of the discharge into the intake was examined. The discharge p 9 9 consists primarily of cooling water,but a small amount of power plant process wastewater and storm water can be mixed with the cooling water. The concentrated seawater from the proposed desalination facility will also be mixed with the power plant cooling water. Recirculation of the HBGS discharge would have the greatest potential to impact water quality at the intake during El Nino storm conditions when the maximum amount of storm water is being a discharged through the outfall. The hydrodynamic model for recirculation of the HBGS discharge was run using the El Nino conditions of February 1998 and the maximum allowable discharge of 1.66 MGD of generating station process wastewater and storm water. In addition, the proposed desalination facility was assumed to be running at full capacity so that 50 MGD of concentrated seawater discharge was mixed with the cooling water discharge. Furthermore, recirculation potential was examined under two generating scenarios: 1)one generating unit on-line with a total discharge of 78.4 MGD of cooling water, storm water, and wastewater, and the concentrated seawater discharge and 2)four generating units on-line producing a total discharge of 458.6 MGD of cooling water,storm water,and wastewater,and the concentrated seawater discharge. The model results under worst case conditions for a 7-day extreme runoff period show that only 0.3 percent of the HBGS discharge would be recirculated to the intake. The results for four generating units show a greater dilution with only 0.1 percent of the HBGS discharge recirculated to the intake. Based on these results, the recirculation of the HBGS discharge during storm events has been shown to not affect the source water quality at the HBGS intake. Impacts are not anticipated to be significant in this regard. Los Angeles and San Gabriel Rivers ` As stated above, the Los Angeles River discharges to the ocean approximately 16 miles upcoast (i.e. northwest)from HBGS,while the San Gabriel Riverdischarges approximately 11 miles upcoast. r The amount of dilution that occurs and the fact that the generating station intake is at a depth of approximately 33 feet indicates that contaminants entering the ocean from these two rivers would not likely affect the water quality at the HBGS intake. Impacts in this regard are not anticipated to be significant. Cruise Ships and Fishing Boats F The nearest major port for cruise ships is located approximately 16 miles northwest of the HBGS intake. Ingress/egress routes for cruise ships for Long Beach and Los Angeles Harbors do not come inclose proximity to the HBGS. In addition,given the limited nature of sportfishing that occurs in the project site vicinity, impacts in this regard are not anticipated to be significant. f Recreation Any contaminants released into the ocean due to recreational use are likely to be small in quantity greatly diluted due to tidal action. It would be difficult for such contaminants to reach the HBGS intake due to its depth of approximately 33 feet below the ocean surface. Impacts in regards to Y recreational uses are not anticipated to be significant. City of Huntington Beach April 5, 2005 5.10-21 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES Oil and Gas Production Facilities As stated above, there are two offshore oil platforms approximately 1.5 miles west of the HBGS intake and four platforms approximately 10 miles west of the intake. There have not been any reportable spills or leaks from the offshore oil platforms or the pipelines. A catastrophic event at one of the offshore platforms that is near the coast could affect water quality at the HBGS intake. However,given the relatively low probability based on operational history,impacts in this regard are not anticipated to be significant. Red Tides and Algal Toxins Refer to Section 5.11, PRODUCT WATER QUALITYfor a discussion of potential impacts in regards to red tides and algal toxins. Operations at HBGS Activities or conditions occurring along the HBGS cooling water system between the HBGS intake and the point at which water is diverted toward the desalination facility could impact water quality (particularly in regards to metals). The diversion point would occur after cooling water has traveled through the HBGS condensers. There are numerous water quality constituents regulated in drinking water supplies. Samples were collected from the HBGS intake vault and from the outlet of the condensers(where the desalination facility intake will be located). Table 5.10-5a/b, COMPARISON OF HBGS INTAKE WELL MONITORING TO PRIMARY MAXIMUM CONTAMINANTLEVELS compares the intake data to the California Department of Health Services (DHS) primary MCLs. Table 5.10-6a/b, COMPARISON OF INTAKE WELL MONITORING TO SECONDARY MAXIMUM CONTAMINANT LEVELS compares the data to the secondary MCLs. Although MCLs apply to treated drinking water, raw water concentrations that exceed MCLs provide an indication of potential contaminants of concern. None of the primary MCLs are exceeded in the intake water and the only secondary MCLs that are exceeded are salts(TDS,chloride,sulfate)that would be removed by the reverse osmosis process. Impacts are not anticipated to be significant in this regard. Potential sources of contaminants at the HBGS site also include cycle water, storm water, and wastewater that are mixed with the cooling water, and on-site spills of hazardous materials of sufficient magnitude to enter the floor drainage system or yard storm drainage system. These potential contaminants are discussed in more detail in Appendix E, WATERSHED SANITARY SURVEY. ' Cycle Water Discharges Cycle water is discharged to the cooling water system at various locations as the cooling water flows through the generating station. The cycle water is under vacuum so the cooling water leaks into the cycle water but the cycle water does not leak into the cooling water. There are several locations where cycle water is discharged into the cooling water system. Table 5.10-7, CYCLE WATER DISCHARGES TO THE HBGS COOLING WATER SYSTEM presents a summary of the discharges to the cooling water system that will be upstream of the intake to the desalination facility. The contaminants in these discharges will be greatly diluted by the large volume of cooling water compared to the small volume of the discharges. The only chemical of concern in a drinking water source is nitrite. The other chemicals in the discharges are not toxic to humans and drinking water standards have not been established. Because the volume of cooling water represents a maximum of 0.002 percent of the cooling water flowing through one unit at the HBGS, the nitrite concentration City of Huntington Beach April 5, 2005 5.10-22 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES Table 5.10-5a COMPARISON OF HBGS INTAKE WELL MONITORING DATA TO PRIMARY MAXIMUM CONTAMINANT LEVELS Primary . Monitoring Data Maximum Constituent Number of Mean Maximum Contaminant Level Samples Concentration Concentration Inorganic Chemicals Aluminum, m /L 1 3 0.063 0.073 Antimony,m /L 0.006 3 0.00009 0.00013 Arsenic,m /L 0.05 3 0.002 0.003 Asbestos, MFL 7 Barium, m /L 1 14 <0.000001 <0.000001 Beryllium, m /L 0.004 3 <0.000005 <0.000005 Cadmium, m /L 0.005 4 0.00003 0.0001 Chromium, m /L 0.05 4 0.002 0.003 .► Copper, m /L 1.3 4 0.0005 0.0008 Cyanide, m /L 0.2 2 <0.001 <0.001 Fluoride,m /L 2 14 0.724 0.9 Lead, m /L 0.015 4 0.0001 0.0002 Mercury, m /L 0.002 4 <0.0001 <0.0001 Nickel, m /L 0.1 5 0.001 0.002 Nitrate, m /L as N 10 14 <0.1 <0.1 Nitrate+ Nitrite, m /L as N 10 Nitrite, m /L as N 1 Selenium, m /L 0.05 3 0.005 0.008 Thallium, m /L 0.002 3 0.00004 0.00006 Radioactivity Gross alpha particle, Ci/L 15 3 3.62 6.62 Gross beta particle, Ci/L 50 2 14.15 23.4 Radium 226&228, Ci/L 5 1 0.226 Radium 226, Ci/L Radium 228, pCi1L Strontium-90, Ci/L 8 Tritium, Ci/L 20,000 Uranium, Ci/L 20 Organic Chemicals Atrazine, m /L 0.003 1 <0.010 Benzo a rene,m /L 0.0002 1 <0.001 Carbofuran, m /L 0.018 1 <0.050 Di 2-eth the I thlate, m /L 0.004 1 <0.030 Endothall,m /L 0.100 1 <0.400 L Simazine,m /L 0.004 1 <0.010 2,3,7,8-TCDD, /L 0.003 1 <1.69 Note:August 2001 -November 2001 data as per sanitary survey approved by DHS August 2002. r-- City of Huntington Beach April 5, 2005 5.10-23 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES Table 5.10-5b COMPARISON OF HBGS INTAKE WELL MONITORING DATA TO PRIMARY MAXIMUM CONTAMINANT LEVELS Primary Monitoring Data Maximum 1 Constituent Number of Mean Maximum Contaminant Level Samples Concentration Concentration Inorganic Chemicals Aluminum, m /L 1 8 0.204 0.496 Antimony, m /L 0.006 8 0.00011 0.00014 Arsenic, m /L 0.05 8 0.0016 0.0025 Barium, m /L 1 14 <0.000001 <0.000001 Beryllium, m /L 0.004 8 <0.000004 <0.00002 Cadmium, m /L 0.005 8 0.00004 0.0003 Chromium, m /L 0.05 8 0.0013 0.0048 Copper, m /L 1.3 8 0.0011 0.002 Cyanide, m /L 0.2 4 <0.001 <0.001 Fluoride,m /L 2 4 1.6 1.9 Lead, m /L 0.015 8 0.0002 0.0004 Mercury, m /L 0.002 8 0.00002 0.00005 Nickel, m /L 0.1 8 0.0029 0.0085 Nitrate, m /L as N 10 14 <0.1 <0.1 Nitrite, m /L as N 1 1 <0.6 <0.6 Nitrite+ Nitrate, m /L as N 10 1 <0.6 <0.6 Selenium, m /L 0.05 8 0.00003 0.00005 Thallium, m /L 0.002 8 0.000011 0,000025 Radioactivity Gross alpha particle, Ci/L 15 3 3.62 6.62 Gross beta particle, Ci/L 50 2 14.15 23.4 Radium 226&228, Ci/L 5 1 0.226 0.226 Strontium-90, Ci/L 8 1 <2 <2 Tritium, Ci/L 20,000 1 24.6 24.6 Uranium, Ci/L 20 1 1.64 1.64 Organic Chemicals Atrazine, m /L 0.003 1 <0.010 <0.010 Benzo a rene, m /L 0.0002 4 <0.000001 <0.000001 Carbofuran, m /L 0.018 1 <0.050 <0.050 " Di 2-eth the I thlate, m /L 0.004 1 <0.030 <0.030 Endothall, m /L 1 0.100 1 1 <0.400 <0.400 Simazine,m /L 0.004 1 <0.010 <0.010 2,3,7,8-TCDD, /L 0.003 1 <1.69 <1.69 Note: Nov.2001-Dec 2002 water quality data collected for the desalination facility design and operation criteria. of 800 mg/L will be diluted to about 0.02 mg/L in the cooling water that would reach the desalination facility. This level of nitrite is well below the drinking water MCL of one mg/L. Nitrite and the other chemicals present in the cycle water discharges will easily be removed by the reverse osmosis membranes. As a result, impacts in this regard are not anticipated to be significant. Urban Runoff Discharges Storm runoff from the HBGS site and a limited amount of off-site urban runoff is currently discharged to the cooling water system upstream of the intake to the desalination facility. The applicant would coordinate with HBGS to reroute these discharges during construction of the desalination facility so they would be downstream of the desalination intake and not 1 City of Huntington Beach April 5, 2005 5.10-24 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES Table 5.10-6a COMPARISON OF HBGS INTAKE WELL MONITORING DATA TO SECONDARY MAXIMUM CONTAMINANT LEVELS Secondary Monitoring Data Constituent Maximum Number of Mean Maximum Contaminant Samples Concentration Concentration Level Aluminum, m /L 0.2 3 0.063 0.073 Color, units 15 Copper, m /L 1.0 4 0.0005 0.0008 !! Corrosivity Non corrosive MBAS, m /L 0.5 Iron, m /L 0.3 3 0.051 0.081 Manganese, m /L 0.05 3 0.006 0.009 MTBE, m /L 0.005 2 <0.002 <0.003 Threshold Odor Number, units 3 Silver, m /L 0.1 4 0.0003 0.0006 Thiobencarb, m /L 0.001 1 <0.010 Turbidity, units 5 27 3.9 16 Zinc, m /L 5.0 3 0.006 0.008 Total dissolved solids, m /L 500 26 33,100 39,100 Conductance, umhos/cm 900 24 48,400 49,200 Chloride, m /L 250 14 19,600 20,200 Sulfate, m /L 1 250 1 14 2,300 2,700 � Note:August 2001 -November 2001 data as per sanitary survey approved by DHS August 2002. Table 5.10-6b COMPARISON OF HBGS INTAKE WELL MONITORING DATA TO SECONDARY MAXIMUM CONTAMINANT LEVELS Constituent Secondary Poseidon Monitoring Data Maximum Contaminant Number of Mean Maximum Level Samples Concentration Concentration Aluminum, m /L 0.2 3 0.063 0.073 Color, units 15 1 3 3 Copper, m /L 1.0 4 0.0005 0.0008 Corrosivity Non corrosive NA NA NA MBAS, m /L 0.5 1 0.065 0.065 Iron, m /L 0.3 3 0.051 0.081 t� Manganese, m /L 0.05 3 0.006 0.009 1L MTBE, m /L 0.005 2 <0.002 <0.003 Threshold Odor Number, 3 4 1 1 units (J Silver, m /L 0.1 4 0.0003 0.0006 1� Thiobencarb, m /L 0.001 1 <0.010 Turbidity, units 5 27 3.9 16 Zinc, m /L 5.0 8 0.0029 0.0058 Total dissolved solids, 500 26 33,500 34,340 t. m /L Conductance, umhos/cm 900 24 48,400 49,200 Chloride, m /L 250 14 19,600 20,200 Sulfate, m /L 250 14 2,300 2,700 NA-Not Applicable Note:Nov 2001-Dec 2002 water quality data collected for desalination facility design and operation criteria. City of Huntington Beach April 5, 2005 r 5.10-25 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES Table 5.10-7 CYCLE WATER DISCHARGES TO THE HBGS COOLING WATER SYSTEM Discharge Volume Contaminants 25,000 gallons per Chloride- 1-5 mg/L unit at start-up, Ammonia-0.15-0.5 mg/L Condensate Overboard generally once per Silica—1 mg/L month. Iron—1-5 mg/L Copper—1 mg/L H—7.0-8.5 25,000 gallons per Chloride—1-9 mg/L day from each unit. Phosphate—0.5-10 mg/L Silica—0.135-0.25 mg/L �• Boiler Blowdown Iron—1 mg/L Copper—1 mg/L pH—9.15-11 EC—10-300 umhos/cm Sodium hydroxide—1-40 m /L Several 1,000 gallons Nitrite—600-800 mg/L per day from each EC—6,000 umhos/cm unit. pH—8.5 Hardness—10 mg/L as CaCO3 Bearing Cooling Water Sodium fluorescein dye—1-10 mg/L Exchanges Polyoxyethylene-polyoxypropylene copolymer Ethoxylated nonylphenol Polydimethysiloxane Isothiazolin Uranine dye—2-10 m /L affect water quality at the desalination intake. The off-site urban runoff is from approximately 70 acres of land near the HBGS. The off-site drainage comes from a road and mobile home/recreational vehicle park to the west, the Wildlife Care Center parking lot located to the south, and a small commercial area north of the site. Dry weather runoff collects in a ditch alongside Newland Street and is currently pumped into the HBGS outfall pipeline. The City of Huntington Beach plans to modify the system so that it flows into the HBGS site by gravity when improvements are made to Newland Street as part of the conditions placed upon the project by the City of Huntington Beach. Impacts are not anticipated to be significant in this regard. Wastewater Discharges Low volume wastes, metal cleaningwastes,and pipeline hydrostatic test water are diverted PP Y to the HBGS retention basin and then to the outfall, where the wastewater is mixed with cooling water. Currently this waste is discharged downstream of the intake to the desalination facility and would not be included in the source water for the proposed desalination facility. Asa result, impacts in this regard are not anticipated to be significant. Hazardous Materials Spills A number of petroleum products and other hazardous materials are stored and used at the generating station. Although unlikely due to spill prevention measures and clean-up procedures in place at the HBGS, there is the potential for a spill to reach the floor drain or the storm drainage system and enter the cooling water system. The floor and yard drainage system currently enters the outfall line downstream of the point where the desalination facility City of Huntington Beach April 5, 2005 5.10-26 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES will be located and would not be included in the desalination facility's source water. As a result, impacts in this regard are not anticipated to be significant. Heat Treatments 1 Periodically water from the discharge vault is diverted back into the facility and reheated. This reheated water is then used to clean the discharge line of biological growths("bio-film"). This recirculated water contains wastes that have been discharged to the discharge vault prior to the flow being reversed in the facility. The proposed desalination facility would not intake water from the HBGS cooling water system during heat treatments. As a result, impacts in this regard are not anticipated to be significant. Elevated Bacteria Levels in the Huntington Beach Sun`Zone As stated above, extensive bacterial studies have shown that the Santa Ana River and Talbert Marsh appear to be the primary sources of fecal indicator bacteria to the near shore ocean. In addition, bird droppings and a reservoir of bacteria stored in the sediment and on marine vegetation may continue to be the source of bacteria at the mouths of the river and marsh. Modeling studies t and monitoring data indicate that there is likely another unidentified source of bacteria in the vicinity of Stations 6N and 9N. However, three separate studies conducted between 2001 and 2002 have demonstrated that HBGS is not the source of bacteria in the surf zone. As discussed previously, the results of hydrodynamic modeling performed for the EIR show that 'rl contaminants are not transported to the HBGS intake from the Santa Ana River and Talbert Marsh during extreme storm event conditions. In addition,dryweather urban runoff at Talbert Marsh during tidal flushing essentially does not reach the HBGS intake. Although the cause of the elevated bacteria levels in the Huntington Beach surf zone has not been determined, the seawater desalination process would have the ability to remove bacteria and produce potable water meeting all State Title 22 standards. The treatment process and product water quality impacts are further discussed in Section 5.11,PRODUCT WATER QUALITY. Impacts in this regard are not anticipated to be significant. MARINE BIOLOGY Concentrated Seawater Discharge Implementation of the proposed desalination project would mix the facility's concentrated seawater discharge with the HBGS cooling water discharge. It should be noted that, in addition to a Coastal Development Permit (CDP) required by the City for the proposed desalination project, a separate C D P will be required by the California Coastal Commission for the changes in HBGS outfalI salinity. In-pipe salinity of the combined concentrated seawater/cooling water discharge water will depend upon the level of operation of the HBGS facility. Following ocean discharge, the combined effluent will mix rapidly with oceanic water. The orientation of the outfall structure produces a vertical discharge stream, which broaches the sea surface as an observable "boil", and promotes mixing. The denser, high-salinity water will subsequently sink to the bottom,and then spread outward from the base of the outfall tower,further mixing with the surrounding water. Hydrodynamic modeling of water mass dilution and dispersion (included as Appendix C, HYDRODYNAMIC MODELING REPORT) utilized the SEDXPORT model, developed at Scripps Institution of Oceanography for the U.S. Navy's Coastal Water Clarity Program. It has been City of Huntington Beach April 5,2005 5.10-27 �� .! Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES thoroughly peer reviewed (including peer review by Dr. Stanley Grant, Professor at University of California, Irvine), and has been extensively calibrated and validated in numerous applications throughout the Southern California Bight. The model studied the ocean response to the proposed ' 50 mgd desalination facility using two separate modeling approaches: 1) event analyses of theoretical extreme cases, and 2) continuous long term simulations using the historical sequence ocean and HBGS operating variables. The latter approach was applied to two distinct historical periods: 1)resulting in 7,523 modeled solutions between 1980 and mid 2000;and 2)involving 578 + modeled solutions that characterized the post re-powering period using data collected between January 1, 2002 and July 30, 2003. ` The event analysis involved some potential situations for operating the desalination facilitywhen the generating station is operating at very low pumping levels. It refers to these as `low flow cases"and they produce the highest in-the-pipe concentrations of sea salts from the desalination process. The most common low flow case occurs when two circulating pumps are running and one of the four generating units is in operation. The most extreme of these low flow cases occurs when the generating station is in standby mode,when two circulating pumps are running and no generating units are in operation,producing no power and providing no heating of the discharge water. The low flow cases are evaluated in combination with extreme conditions in the ocean environment involving tranquil, dry weather, La Nina type summer climate. By superimposing two conditions that seldom occur together (low HBGS flow cases and a calm ocean) the maximum potential impact of the desalination facility on the local ocean environment can be assessed because the dose level of sea salts is highest when the dilution of those salts by mixing and ventilation is lowest. The event analysis also evaluated an: "average flow case"based on seasonal mean ocean conditions and average HBGS flow rates (four circulating pumps running and two generating units operating) to determine the most likely degree of dilution of desalination discharge in nearshore waters. t. Discussed below are the results of the event analysis of the theoretical extreme cases (the results from the long term simulated modeling using historical data are discussed in detail in Appendix C, HYDRODYNAMIC MODELING REPORT). Distribution of mid-depth seawater salinity in the vicinity of the HBGS outfall under worst-case scenario conditions is depicted on Exhibit 5.10-2,PROJECTED MID-DEPTH SALINITY OVER THE HBGS OUTFALL —"LOW FLOW"SCENARIO. The low flow month scenario assumes that the HBGS facility has onlytwo circulating pumps operating (one generating unit)and that no additional mixing from natural causes such as wind or wave action would occur and is extended for 30 days. This low flow scenario has less than a one percent chance of occurring. With a maximum discharge salinity of 55.4 ppt and no additional mixing from natural causes such as wind or wave action (low flow scenario),the highest salinity in the core of the discharge jet is predicted to be 55.0 ppt at mid- depth and 50.1 ppt at the surface.3 Following the long axis of the teardrop-shaped plume, the concentration of the discharge salinity at mid-point of column depth is projected to decrease to 40 ppt (20 percent above background salinity) within only 20 feet from the HBGS discharge outfall tower. Approximately 100 feet away from the outfall tower, the discharge salinity will decrease to 38.5 ppt,which is only 15 percent above the background seawater salinity. Within 1,200 feet from the outfall tower the discharge salinity will be only 10 percent higher than the background seawater salinity. Hence the size of the plume in terms of average dimensions of its teardrop shape is 500 feet from the outfall. Under the low flow scenario,the highest salinity on the ocean floor will be 48.3 ppt at the base of the outfall tower, decreasing with distance from the tower, as shown on Exhibit 5.10-3, PROJECTED SEAFLOOR SALINITY AT THE HBGS OUTFALL — "LOW FLOW" SCENARIO. The discharge salinity drops to less than 15 percent(38.5 ppt)above the background 3 Hydrodynamic Modeling of Source Water Make-Up and Concentrated Seawater Dilution for the Ocean Desalination Proiect at the AES Huntington Beach Generating Station. Dr. Scott A.Jenkins Consulting, December 1,2004. City of Huntington Beach April 5, 2005 5.10-28 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES salinity 100 feet away from the discharge. The bottom discharge salinity is reduced to 10 percent of the background salinity within 1,000 feet from the discharge outfall tower. Stated as an average teardrop shape,the size of the plume is within a distance of 465 feet from the outfall. A maximum of 15.6 acres of ocean floor (benthic area) and 18.3 acres of the water (pelagic area) around the }y�f discharge are expected to be exposed to water with a salinity 10 percent higher than the ambient seawater during the low flow scenario. These effects are acute and not expected to last for an extended period of time. Composited for one month, the low flow scenario of maximum discharge salinity and no mixing from natural causes (such as wind or wave action) has less than a one percent chance of occurring. For normal HBGS operation (four circulating pumps associated with two HBGS generating units), typical environmental conditions extended for 30 days and reverse osmosis facility production of 50 mgd ("average flow"scenario),the salinity at mid-depth in the discharge jet is predicted to be about 41.7 ppt, which is 25 percent higher than background salinity, dropping to 38.3 ppt on the sea 15 surface, as shown in Exhibit 5.10-4, PROJECTED MID-DEPTH SALINITY OVER THE HBGS OUTFALL— AVERAGE FLOW"SCENARIO. The concentration of the discharge salinity at mid- point of column depth is projected to decrease to 38.5 ppt(15 percent above background salinity) within 20 feet from the HBGS discharge outfall tower. Within 500 feet(long axis of tear-drop shape) from the outfall tower the discharge salinity will be 10 percent higher than the background seawater salinity. Hence the size of plume in terms of the average dimensions of its teardrop shape is 330 feet from the outfall. Assuming the average flow month scenario,the highest salinity on the ocean floor will be 37.6 ppt at the base of the outfall tower, (only 12 percent above background salinity),decreasing with distance j from the tower as shown on Exhibit 5.10-5, PROJECTED SEAFLOOR SALINITY AT THE HBGS OUTFALL— AVERAGE FLOW"SCENARIO. The discharge salinity drops to less than 10 percent above the background salinity approximately 430 feet away from the HBGS outfall along the long axis of the tear-drop shaped plume or an average distance of 300 feet. During average monthly case conditions a maximum of 6.8 acres of benthic area and 8.3 acres of pelagic area are expected to be exposed to water with a salinity 10 percent higher than ambient seawater. Average case F conditions are expected to occur 50% of the time the desalination facility is operating. As more generating units are operated, salinity of the combined discharge will continue to decrease and a smaller area of the surrounding environment will be exposed to elevated salinities. iit The pelagic area potentially exposed to a 10 percent increase in salinity as a result of the desalination facility discharge is relatively small,even in the low flow model. A 10 percent anomaly is within the normal variability of seawater salinity and would be tolerated by most fish species. Salinities predicted for the limited area of the discharge jet vicinity during the low flow scenario are potentially fatal to fish species. Mobile species have the ability to avoid areas that they cannot I tolerate and,since sharp salinity gradients may act as barriers to the movements of fish,would likely avoid higher salinity areas.4 Due to the mobility of the fish, commercial fishing would not be impacted. In addition, fish have been observed feeding in the discharge streams of southern California generating stations including the HBGS discharge. This opportunistic behavior is likely to be reduced or completely discontinued following the addition of the concentrated seawater discharge. However, given that the HBGS discharge stream is not the sole food source for fish in the region, impacts in this regard would not be significant. No significant impact to local fish populations as a result of the addition of the concentrated seawater discharge is expected. _ �F 4 "Salinity: Fishes." Marine Ecology. F. Holliday, 1971. City of Huntington Beach April 5, 2005 5.10-29 rr � r �r � � � r r � � •rr � siiir � � {awl a� .,^ .free T.er.r';� `c.• I' a? � Z oN I .�,E u h r ton -Be,ach� lr.: 'alb.ert ._t N , �� . .i^s ri 1)IlT k `w- 311 G`S I nktl {J� rl I T y: `S'rl al'I uv fi I. Pt 4e 4 30-day average of salinity at mid water column depth for concentrated sea `. water from: R.O. = 50 mgd, Plant Flow Rate = 126.7 mgd, low flow conditions. ��— �! I 35 40 45" 50 �55 ppt Source:Poseidon Resources Corporation,December 2004. NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH RAF Q Projected Mid-Depth Salinity Over the HBGS Outfall - "Low Flow" Scenario c ONGuLTING 02/05•JN 10-101409.002 Exhibit 5.10-2 lI� rnr a.i ,r ,� � � � r +� �� � �� � GIs •�I�I �aar � >i� untin6ton1 i.. . , Beach -rm \'. _v �0 q � L__^''=__.._, ��.—� 'ui� • it j�l � � - - -- ��I' r�"r-_-u '�,�« I _ ....� ' Lam.,�'a�'-1'..ly'• ",<F��.II1�-�Yi•7"y%'-- /•���4`� 1 ...Talbert "I 1 i{`/C✓ y t l/ �!`` gab.li.nta, 3• /J - ( sib_. -_,�-•' 1-�� I o , a • ��'I'V'I�r�'. .J, ,�.....`.-: u!.x4i'.• % � L- `Z���� ���- �G..+• A3.a...�J. �t}f�-�'• i �1'• ��I};�..- cam...� / r �%�I \ `[F� 1\ rerwytwilk HBGS Outfa 'I ...,�- �r �.� :�� �•� -� �x - harsh_, . :_ �11 . . HBGS Inf III -i'•�4. .Y. ��` ...F> Y:,�.. / C_ ,yam OCS Shallow ,. O u tfa l l =�^ >� `• bN'�p 30-day average of salinity on sea bottom for concentrated sea water from: R.O. = 50 mgd, Plant Flow Rate = 126.7 mgd, summer conditions. —r i1 40 =45 50 » >>t Source:Poseidon Resources Corporation,December 2004. NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH WF Q Projected Seafloor Salinity at the HBGS Outfall - "Low Flow" Scenario CONSULTING 02105•JN 10-101409.002 Exhibit 5.10-3 •t4'jt ( p:O• M.•lrPnGteTFv: /.{(> 'I• ' � �• :t�..a a • ( I�1�+`��`•� l _ �I ` ___�._ NEB Huntington Elm --Ta l b�ertr �=� r�� 'T;s„ � �,��, -• ��=-•lulu-�•h a - s ,-e H B G S O u tf l l :Bay_ ril g,Q H B G S I n f a I I r h ,\ '�=.'; `' ".�- j.1_ 6':.9:. ^C 1:,5. t•^fi'+}o tcx.I '�A—J" � 'l -c 4-1 .:7.i �. �•w�� :ri-�lV. '.Ohl t — I OCS Shallow Out fall N 1 y I HM N 5 30-day average of salinity at mid water column depth for concentrated sea water from: R.O. = 50 mgd, Plant Flow Rate = 253.4 mgd, average conditions. 3; ao 45 u 551,nt Source:Poseidon Resources Corporation,December 2004, NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH IMFQ Projected Mid-Depth Salinity Over the HBGS Outfall - "Average Flow" Scenario CONSULTING 02/05-JN 10-101409.002 Exhibit 5.10-4 � IE H u nti ni-9ton C 1--Beaches V� ���"^_c anti'--- -{'P F_-�, — - -"'Seam. ('J��;y�,' _ ••,..� '3 V ne .7 9 `� 1�` 1 -•_•.-. � _r_' f• _ u..Y i Ili t,Y�L`ti -'r'�-•��• ':�, '-I. alberti o,i iJ'' -'`` '' :^i•�•+`'RCd`n.urr•OH� 4..-•�` HBGS Outfal - = _ . - - `,�'` `�� y a• `;• zsy • " HBGS Infa - !L; r a•, �° I,rsh, " "_'.:. _ g r✓•!L ^Eta' , �- — 4ipn•rl .5,�3.y... S Rf' 1... ,:i.•�• ems:�-�•:��,'�' •,� i::.•:-:�.- OCS Shallow Outfall I• s a.: M 30-day average of salinity at seabed for concentrated sea water from: R.O. = 50 mgd, Plant Flow Rate = 253.4 mgd, average conditions_ 35 40 45 .50 »ppt Source:Poseidon Resources Corporation,December 2004. NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH Q Projected Seafloor Salinity at the HBGS Outfall - "Average Flow" Scenario CONSULTING 02/05-A 10-101409.002 Exhibit 5.10-5 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES Planktonic species have limited mobility and these species tend to occur in great numbers within the subject site vicinity. Marine planktonic organisms have similar salinity tolerances as local fish species (a 10 percent anomaly can be tolerated by most fish species/planktonic organisms). However, plankton entrained in the discharge stream are likely to be killed, as much by the turbulence and temperature of the discharge (which would occur even without proposed project implementation)as by the salinity increase. No significant increase in plankton loss is expected from the addition of the by-product water to the discharge stream. The benthic area potentially exposed to a 10 percent increase in salinity as a result of the proposed desalination facility discharge is relatively small in relation to the soft-bottom habitat offshore of Huntington Beach.The benthic community near the discharge structure is dominated by soft-bottom infaunal invertebrate species with limited mobility. Macrofaunal species are the larger members of the benthic community more easily identified in the field and are commonly used to assess the benthic community. Infaunal and other benthic species common offshore of Huntington Beach will have salinity tolerances similar to those of other marine species in the area and should be able to endure salinity increases of up to 10 percent. For most marine organisms, lower salinities are more detrimental than higher salinities,as long as the upper limit does not exceed 40 ppt.5 During low flow conditions, however, salinities at the base of the discharge tower are expected to exceed 48 ppt, and even during average conditions the salinity of the water at ocean floor immediately around the discharge will be about 38 ppt, higher than local normal oceanic variation. In times of stress infaunal species can withdraw into the sediments, where the interstitial water is only gradually exchanged with overlaying water. Still,the benthic species at the base of the intake tower will probably be replaced by species which are more tolerant of high salinities. There is also likely to be a general trend of replacement of infaunal species in the area of the 10 percent salinity anomaly footprint with species which are common to areas of fluctuating salinity such as bays, estuaries and river mouths. While species common to the open coast can tolerate salinity fluctuations to some degree, in the open coast these fluctuations are gradual, while operations of either the proposed desalination facility or HBGS may cause rapid changes in local salinity which estuarine species are better adapted to tolerate. Local benthic community diversity is likely to be depressed as a result of desalination facility operations. However, these estuarine species will be functionally similar to the existing community. Still,temporal fluctuations in abundance and diversity of benthic species are the norm for the shallow water communities on the mainland shelf of southern California.s Replacement species are most likely to be infaunal species common to local estuaries i and bays. The area of this replacement will be relatively small and localized. ■ In summary, a suite of biological facts indicates that the combined thermal and reverse osmosis discharge would not be large enough to have a significant biological impact on the marine species or communities living near the HBGS (as the reverse osmosis process would not involve the heating or cooling of circulated ocean water, thermal impacts would not occur). Most of the marine organisms living near the HBGS also occur in areas of the SCB and beyond it where salinities can be greater than those that would occur in the combined reverse osmosis and HBGS discharge field. For example,the natural geographic distributions of most of the species living at Huntington Beach extend south to near the tip of Baja California where both coastal temperatures and salinities are as high or higher than those predicted for most areas in the combined discharge field. In addition, some of these species or ones very closely related to them live in the upper part of the Gulf of California where salinities are 36 38 ppt and can be as high as 40 ppt. Thus, many of the species present in water around Huntington Beach naturally experience a salinity range comparable to or greater than what is predicted of the combined discharge area. 5 Benthic Impact of the Discharge from Desalination Plant. C. Pomory,2000. 6 The Benthic Macrofauna of the Mainland Shelf of Southern California. G.F.Jones, 1969. City of Huntington Beach April 5, 2005 5.10-34 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES Hydrodynamic modeling for the proposed project also finds that an elevated salinity zone would occur around the discharge core and that all organisms living within these areas would encounter it. For the animals swimming in the water (some macroinvertebrates, fishes, turtles, mammals), the duration of their elevated salinity exposure would depend on their location and their residence time in the zone. Such a brief exposure time would have no effect on marine mammals,turtles, or most fishes which are good osmoregulators and while most fishes are unlikely to prefer salinities this high, comparative data showing fish easily tolerate high salinities for short periods suggest these salinities 1� could be tolerated for a short time. Also, fishes would have the ability to "sense" such a marked salinity change in the water and could thus alter their swimming direction to avoid it. SJ In the case of organisms that drift across the elevated salinity area, models developed for the discharge flow field show that planktonic animals drifting though the discharge area would r1 experience elevated salinity for variable times.These times would depend upon both the area of the zone and the organism's rate of drift and its position relative to the discharge core. Exposure to the inner discharge core would be less than one hour and exposure to the core's periphery would be two to three hours. Short-term exposures to higher salinity levels can be tolerated with no impact to marine organisms. While plankton, fishes and other water-column residents would have relatively brief exposures to the highest salinities within the elevated salinity zone,this would not be the case for the benthic organisms occurring in the discharge area. Bottom- dwelling organisms living near the core would experience an increased salinity. One likely biological result of this permanently elevated benthic salinity zone would be some reduction in the total J- diversity of species living within the zone and the likely increase in the concentration of species 1 having a greater tolerance to the elevated salinity. Such species may already exist in the Huntington Beach bottom community or species from other nearby coastal habitats (tide pool, bays) where salinity is more variable may be recruited to this zone. In addition, RO treatment requires the pumping of seawater through membrane filters that remove its salts. For each volume of freshwater produced by RO systems an approximately equal volume of doubly concentrated (2x salinity) seawater is also formed. The mass balance analysis of the proposed RO operation at the HBGS requires integration of daily flow volumes through it[e.g., 50 million gallons per day (mgd) each of potable freshwater produced along with 50 mgd of 2x concentrate]and the mixing ratio of the latter with the HBGS cooling water flow(approximately 127 mgd). Because seawater that will undergo RO filtration is pre-treated with iron sulfate (or iron chloride, a chelating agent that coagulates organic solutes and other dissolved materials,and also r precipitates a fraction of the trace elements), evaluation of seawater chemistry and physical properties is done before and after pre-treatment and following pretreatment filtration. Another factor affecting mass balance and water chemistry is the volume of RO filter backwash water produced by the intermittent reverse-flow of seawater over the pre-treatment sand filters to rinse away debris. r- Chemical comparisons show that all of the trace elements considered in the discharge analysis ) already occur in the source water and they have the same concentration off Huntington Beach coast 1 as they do in coastal oceans throughout the world. Chemical and physical factor comparisons f` between the source water and the RO facility discharge stream demonstrate the "concentrating effect"of RO on the source seawater but also show that the RO operation will not significantly affect water turbidity, suspended solids, pH, and oxygen levels. Mass balance results were based on the assumption of a low HBGS flow rate (127 mgd)and thus C conservatively overestimate the concentration that would be expected under normal operation conditions. Nevertheless, the results show that while these trace elements will become slightly concentrated by RO, their discharge concentrations remain far below the numerical water quality City of Huntington Beach 5.10-35 April 5, 2005 r �� Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES standards established to protect aquatic marine life by the Environmental Protection Agency and by the State of California. The only change in discharge water chemistry resulting from the RO facility will be an elevation in dissolved iron. However, this concentration is low and, like the salinity difference between the discharge and receiving waters,the iron concentration will be rapidly diluted to ambient levels. There are no numerical water quality standards governing the discharge of iron, which is usually present in low concentrations in seawater. Moreover, iron is an important ocean nutrient (essential for the growth of phytoplankton) and is likely to be biologically assimilated by primary produce organisms(mainly phytoplankton)in the discharge plume.Additional information is provided in Appendix S, MARINE BIOLOGICAL CONSIDERATIONS. In conclusion, the proposed project's discharge would not have a significant effect on organisms living around the discharge or organisms that would pass through the area. As stated above, most of the marine organisms living near the HBGS also occur in other areas of the SCB where naturally occurring salinities can be higher than what is anticipated at the HBGS outfall. Plankton,fishes,and other water-column species would have brief exposure to the concentrated seawater discharge field, and the area of benthic impacts would be relatively small and localized. In addition, no endangered species or kelp beds exist within the vicinity of the HBGS outfall. As water quality impacts and impacts to marine biological resources are not anticipated to be significant, a separate routine monitoring process is not proposed as part of the project. However, if applicable, biological monitoring during long-term project operation will be conducted as directed by the RWQCB, Reverse Osmosis Membrane Cleaning Solution Impacts to the local marine environment due to the discharge of reverse osmosis membrane cleaning solution through the HBGS outfall are anticipated to be less than significant. As stated previously in Section 3.0, PROJECT DESCRIPTION, the reverse osmosis system trains will be cleaned using a combination of cleaning chemicals such as industrial soaps (e.g. sodium dodecylbenzene, which is frequently used in commercially available soaps and toothpaste) and weak solutions of acids and sodium hydroxide. Approximate total discharge volumes per reverse osmosis membrane cleaning are shown below in Table 5.10-8,REVERSE OSMOSIS MEMBRANE SOLUTION DISCHARGE VOLUMES. Chemicals typically used for cleaning include (it should be noted that,the actual cleaning chemicals used will be based on the observed operation and performance of the system once it is placed in operation): ❖ Citric Acid — (two percent solution) ❖ Sodium Hydroxide B - (0.1 percent solution) ❖ Sodium Tripolyphosphate B - (two percent solution) 4$1 Sodium Dodecylbenzene B- (0.25 percent solution) d• Sulfuric Acid B - (0.1 percent solution) The"first rinse"treated waste cleaning solution from the washwater tank will be discharged into the local sanitary sewer for further treatment at the OCSD regional wastewater treatment facility. The cleaning rinse water following the "first rinse" will be mixed with the RO facility concentrated seawater, treated waste filter backwash, and the AES plant discharge and sent to the ocean. This "second rinse"water stream will contain trace amounts of cleaning compounds and would be below detection limits for hazardous waste. An Industrial Source Control Permit from the OCSD for discharge of waste cleaning solution into the sanitary sewer system will be required for the project. In addition, the discharge must comply with the limits and requirements contained in the OCSD's Wastewater Discharge Regulations. Impacts to the local marine environment in this regard would be less than significant. City of Huntington Beach April 5, 2005 5.10-36 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES Table 5.10-8 9 REVERSE OSMOSIS MEMBRANE SOLUTION DISCHARGE VOLUMES ., .."TYPE OF DISCHARGE .:GALLONS PERCENTAGE Concentrated Waste Cleaning Solution 4,000 4.4 1, I Rinse Water- Residual Cleaning Solution 11,000 12.0 Rinse Water-Permeate 45,600 50.2 Rinse Water-Concentrate Removed During 30,400 33.4 Rinsing TOTAL DISCHARGE (gallons) 91,000 100 An alternative to discharging the"first rinse"of the RO membrane cleaning solution into the OCSD system is to discharge the solution("first rinse"and all subsequent rinses)into the Pacific Ocean via the HBGS outfall. On a typical day, this alternative would blend 200,000 to 300,000 gallons of cleaning solution at a rate of 150 to 200 gpm(0.2 to 0.3 mgd)with 50 mgd of concentrated seawater by-product discharge, 10-15 mgd of treated filter backwash, and 400 mgd of HBGS cooling water , discharge. Under a low flow scenario (high membrane cleaning solution concentration and low J concentrations of concentrated seawater discharge, filter backwash, and HBGS cooling water discharge),the membrane cleaning solution would be diluted at a ratio of 260 to one. The majority of the chemicals within the membrane cleaning solution would be either below detection levels or regulatory limits,even before dilution with other desalination facility and HBGS discharges. Dilution at a 260 to one ratio would further minimize impacts to the marine environment and would assure NPDES compliance. Modeling for this discharge under various concentrations was performed,and is included in Appendix K,RO MEMBRANE CLEANING SOLUTION DISCHARGE TEST STREAM DATA. Impingement and Entrainment E Potential impacts to marine biological resources in regards to impingement and entrainment effects of the proposed source water withdrawal of the desalination facility,from the cooling water system discharge of the HBGS are analyzed within Appendix T, INTAKE EFFECTS ASSESSMENT (Tenera,2004). Impingement occurs when larger fishes and invertebrates'are trapped against the generating station's cooling water intake screens,while entrainment occurs when small planktonic organisms are drawn through the intake screens and through the generating station's cooling water system. Exhibit 5.10-6,HBGS INTAKE SCREENING PROCESS,depicts the HBGS facility's intake screening process. i Two separate and unrelated entrainment studies are being conducted at th'e'HBGS site. A long- r term study, in connection with a re-powering project certified by the CEC, is underway to study entrainment effects of the HBGS's cooling water intake system. The CEC required AES to perform a study of the power plant's cooling water intake system as a condition of re-powering certification. The CEC entrainment study is not a 316(b) study, but was designed using the same sampling methodologies and data analyses employed in several recently completed 316(b)studies (Tenera 2000 a, b, 2001). City of Huntington Beach April 5, 2005 1 5.10-37 Existing t$pi1 WpfEtr } JIM 3" Ratk (76W 3I8"Screen (9.Smm) An Pkmicn al ' Isfit � t� eo�r� E } " Fyn � �`� E� 118'roShs•13tosaal a t+( } E " b Z Z F&h Eggs �. . t/r(.bpi aroe 1!8'oS116`13N&eml 4 - }p +Viruses o:.y,C►ptl�s�rurs ry - 77 g, 3 5(reei WQ�r { C) � _ w . ' L . A- _ = Plarkron f�Vdd a (I to 1000Miaons) (.5 to 100 Noom) 0 091 'AM rI L _ Bach o Yitustt (. to S 100Nuons � ) t.02 to.25 Miuonsl s CAaueF Ot Q x; _ i 0 02 io.25 Now) Source:Poseidon Resources Corporation,December 2004. NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH MF HBGS Intake Screening Process CONSULTING 02/05-A 10-101409,002 Exhibit 5.10-6 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES The second, but unrelated entrainment study at the site is the desalination feedwater intake study included herein. It should be noted that the proposed project's feedwater withdrawal is not subject to intake regulation under the Federal Clean Water Act(CWA)Section 316(b). The project does not include a cooling water intake structure(CWIS). The CWIS is part of the HBGS existing operations and is presently regulated under Section 316(b). The desalination facility's feedwater would be withdrawn from the HBGS discharge and not directly from the open ocean,and its withdrawal does not affect HBGS intake requirements.. The project does not require the HBGS to increase the quantity of water withdrawn nor does it increase the velocity of the water withdrawn. However, taking under consideration that the project will withdraw intake seawater from the generating station discharge flow,the study conducted was consistent with the intent of Section 316(b)which requires "...the location,design,construction,and capacity of cooling water intake structures...are based on the best technology available to minimize the adverse environmental impact associated with the use of cooling water intake structures"(USEPA 2004). The desalination intake study,which is also not a 316(b)study(as none is required for the desalination facility intake), is designed to investigate the potential for desalination facility feedwater intake withdrawn from the HBGS cooling water system to increase HBGS entrainment mortality and assess the significance of this potential entrainment effect on the source water. The proposed project source water intake would not increase the volume, or the velocity of the HBGS cooling water intake nor would it increase the number of organisms entrained or impinged by the HBGS cooling water intake system. Therefore, the impingement effects of the HBGS are not included in assessing the proposed project's effects. This assessment focuses on the effects of the proposed project's entrainment of organisms already entrained by the generating station before they would be returned to the ocean in the cooling water discharge flow. Impingement The proposed desalination facility would not cause any additional impingement losses to the marine organisms impinged by the HBGS, as these organisms would not be exposed to further screening prior to entering the desalination facility's pretreatment system. The proposed desalination facility would not have a separate direct ocean water intake and screening facilities,and would only use cooling water that is already screened by HBGS's intake. As stated in Section 3.0,PROJECT DESCRIPTION,should the HBGS cease to operate,the applicant would purchase the HBGS pumps and intake/discharge facilities and continue to produce and distribute potable water, subject to new permits and approvals required due to a change in the project description. Entrainment Entrainment sampling for the desalination feedwater was conducted at an onshore point in the ' HBGS discharge line just before it is returned in conduits to an offshore discharge location. Bi- weekly samples were collected since the beginning of March 2004 by pumping measured volumes of cooling water discharges through small-mesh nets. The preserved samples were sorted in the laboratory and the fishes and target invertebrates were identified to the lowest taxon practicable. In general, entrainment effects are assessed using the Empirical Transport Model (ETM), as recommended and approved by the California Energy Commission (CEC), California Coastal Commission (CCC) and other regulatory and resources agencies. This model, used for HBGS intake studies and many other California intake effects studies, compares entrainment larval concentrations to source water larval concentrations to calculate the effects of larval removal on the standing stock of larvae in the defined source water. Tidal exchange ratios,source water volumes, City of Huntington Beach April 5, 2005 5.10-39 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES cooling water volumes, larval concentrations, and larval durations were variables used in the ETM calculations. Conservative assumptions of HBGS volumes of 127 MGD were used for developing the estimates of potential losses due to desalination facility operations. The ETM model estimates the proportion of the available larval supply in the source water that is eliminated by entrainment, but makes no assumptions as to the ultimate effects of such losses on the next generation of adult fishes. The study for the desalination project was also compared with the preliminary results from the 2004 six-month report submitted to the CEC(which is part of the ongoing HBGS intake entrainment and impingement study). Six taxa (gobies, blennies, croakers, northern anchovy, garibaldi, and silversides) and a group of larvae that could not be identified were found to comprise 97 percent of all the fish larvae present in the HBGS cooling water system from which the proposed project would withdraw its source water supply. Species with high commercial and recreational importance,such as California halibut and rockfishes, were shown to be very uncommon in the HBGS intake flows. Under HBGS minimum intake cooling water flow of 127 mgd, and assuming 100 percent through- HBGS larval mortality (based on USEPA 2004), the estimated larval fish entrainment loss is 0.33 percent of the total population of larvae in the local area surrounding the HBGS intake. Based on in-plant testing, the observed mortality of HBGS is 94.1 percent and the combined estimated mortality(utilizing the ETM)of the proposed project and HBGS at flows of 507 mgd would be 95.3 percent(an increase in mortality of 1.2 percent due to the proposed desalination facility)and 98.7 percent at HBGS flows of 127 mgd (an increase in mortality of 4.6 percent due to the proposed desalination facility). This assessment assumes 100 percent mortality of all organisms upon withdrawal into the desalination facility. Estimated larval fish loss attributed to the proposed desalination facility would be 0.02 percent (based on HBGS entrainment mortality of 94.1 percent)of the total population of larvae in the local area surrounding the HBGS intake. This would be an order of magnitude less than the HBGS larval population entrainment loss of 0.33 percent. The 0.02 percent figure accounts for the incremental amount of larval fish loss resulting from the proposed desalination facility, aside from that of the HBGS. From a regional perspective, model results for larval gobies, northern anchovy, and white croaker showed that approximately 0.33 percent of the larvae in the HBGS source water could be affected by HBGS operations at 127 MGD;this represents a de minimis fraction of the total numbers of larval fishes in the Southern California Bight. Results were modeled on encounter rates for the most abundant species entrained from the source water. The loss of marine organisms due to the potential entrainment of the proposed project has no effect on the species' ability to sustain their populations. The loss will not have a measurable effect on the source populations of the species in the Southern California Bight and is an order of magnitude lower than the entrainment loss typically caused by HBGS operations. Calculations have shown that approximately 25,000-37,000 adult gobies and 6,000-71,000 adult northern anchovy may be lost in a four-month period due to full HBGS operation (507 MGD)(MBC and Tenera 2004). Losses attributed to low flow (127 mgd) operations alone would be approximately 25 percent of these amounts. In addition: City of Huntington Beach April 5, 2005 5.10-40 Seawater Desalination Project at Huntington Beach 5.10 OCEAN WATER QUALITY AND Draft Recirculated Environmental Impact Report MARINE BIOLOGICAL RESOURCES ❖ The most frequently entrained species are very abundant in the area of HBGS intake and the Southern California Bight, and therefore, the actual ecological effects due to any additional entrainment from the desalination facility are insignificant. ❖ Species of direct recreational and commercial value constitute a very small fraction of the entrained organisms in the HBGS offshore intake and therefore, the operation of the desalination facility does not result in significant ecological impact in NEPA/CEQA context. ❖ The California Department of Fish and Game (DFG) (2001), in their Nearshore Fishery Management Plan, provides for sustainable populations with harvests of up to 60 percent of unfished adult stocks. The maximum "harvest' effect of HBGS operations at 127 MGD is 0.33 percent, significantly below the accepted (DFG) thresholds of 60 percent. The maximum "harvest' effect of the proposed project is 0.02 percent, an order of magnitude less than 0.33 percent, based on HBGS entrainment mortality of 94.1 percent. Impacts due to operation of the proposed desalination facility in regards to impingement and entrainment are not anticipated to be significant. MITIGATION MEASURES None required. UNAVOIDABLE SIGNIFICANT IMPACTS None have been identified. ! 1 City of Huntington Beach April 5, 2005 5.10-41 5. 11 PRODUCT WATER QUALITY The following section is based on the Municipal Water District of Orange County 2000 Urban Water Management Plan (December 20, 2000), the Huntington Beach Seawater Desalination Plant Pressure Surge Analysis (January 16, 2003), the Distribution System Corrosion Control for Desalination Seawater (September 27, 2002), and the Disinfection Byproduct Formation Report (March 2004). EXISTING CONDITIONS Four water sources (imported water from the Metropolitan Water District of Southern California [MWD], surface water, groundwater, and recycled water) are currently managed, treated and distributed through the Orange County distribution system to customers throughout Orange County. The potable water quality within the Orange County distribution system is in compliance with all regulatory drinking water standards. A description of the regulations currently applicable to the existing potable water supply within Orange County (and which would also be applicable to the proposed project) is provided below. 1 REGULATORY FRAMEWORK— DRINKING WATER Department of Health Services —Title 22 The California Department of Health Services (DHS) administers all provisions relating to the regulation of drinking water to protect public health. California's Safe Drinking Water Act requires DHS to administer laws relating to drinking water regulation, including setting and enforcing both federal and State drinking water standards, administering water quality testing programs, and administering permits for public water system operations. The standards established by DHS are found in Title 22 of the California Code of Regulations (CCR). The DHS is responsible for ensuring that all public and private water systems are operated in compliance with drinking water regulations. Current drinking water regulations include both primary and secondary standards. Compliance with primary standards is mandatory, because these standards are based on potential health effects on water users. The primary standards define 1 maximum concentration levels (MCLs) that cannot be exceeded by any public and private water system. All standards except turbidity are applicable at the water user's tap. Secondary standards are those parameters that may adversely affect the aesthetic quality of drinking water,such as taste and odor. These standards are not federally enforceable, although DHS reserves the right to enforce secondary standards if warranted. Under Title 22 of the California Code of Regulations, DHS would regulate the operation of the Seawater Desalination Facility at Huntington Beach and would oversee the quality of the product water produced. In addition, DHS would be responsible for ensuring that the product water blended with existing water supplies would meet the minimum recommended standards for contaminants in drinking water that has been established by the United States Environmental Protection Agency (EPA). To comply with the DHS regulatory requirements, the applicant would apply for a domestic water supply permit as a water supply wholesaler pursuant to the Regulations Relating to Domestic Water Systems. This includes the submission of: i City of Huntington Beach April 5, 2005 5.11-1 Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report ❖ A Water Quality Emergency Notification Plan (ENP); ❖ An Engineering Report describing how the proposed new facilities would comply with the treatment, design, performance and reliability provisions of the Surface Water Treatment Rule (SWTR); and ❖ A Facility Operations Plan. Permit provisions for similar municipal water supply projects typically include: ❖ Submittal of plans and specifications for Department approval prior to construction; ❖ Compliance with the Surface Water Treatment Rule (SWTR)—including the treated water turbidity, disinfection residuals and CT levels; ❖ All water must be treated —no bypassing; ❖ Complete water quality analyses conducted by an approved laboratory; ❖ Adequate corrosion control; ❖ Updated watershed sanitary survey every five years; ❖ Mandatory use of American National Standards Institute (ANSI) and National Safety Foundation (NSF)approved chemicals; ❖ Raw water bacteriological monitoring; ❖ Certified treatment facility operators; and ❖ Submission of monthly operation reports and a report after the first year of operation detailing the effectiveness of the facility's performance, a list of any violations and a list of any needed additions or operational changes. Santa Ana Regional Water Quality Control Board (SARWQCB)—Basin Plan As part of its Triennial Review of the Water Quality Control Plan for the Santa Ana River Basin (Basin Plan), the SARWQCB reviewed the recommendations of a Task Force report of the 1995 total dissolved solids (TDS)/Nitrogen Management Plan for the basin. This review resulted in the 2004 adoption of an amendment to the Basin Plan that could impact water quality discharge limitations in water reclamation permits leading to increased permit limits of several key water quality constituents: ❖ Revision of numerical water quality objectives for TDS in the Irvine Groundwater Management Zone. The new water quality objective is 910 mg/L. ❖ Deletion of numerical groundwater quality objectives for individual mineral constituents,such as sodium and chloride. These have been replaced with narrative water quality objectives: chloride concentrations shall not exceed 500 mg/L in groundwaters of the region designated MUN and sodium concentrations shall not exceed 180 mg/L in groundwaters designated MUN. IMPACTS As the proposed project would introduce an entirely new source of potable water into the Orange County water supply system, the following information analyzes the quality of potable water produced by the desalination facility and its potential impacts on existing potable water quality and the distribution system within Orange County. An analysis of the desalinated product water's compliance with regulatory drinking water standards is provided, in addition to a description of City of Huntington Beach April 5, 2005 5.11-2 Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report potential impacts to existing water supplies in regards to corrosion, chlorine residual, disinfection bypdroducts, taste/odor, and hydraulics. Significance Criteria Under the CEQA Guidelines a project may be considered to have a significant environmental effect if it would: ❖ Violate any water quality standards or waste discharge requirements; ❖ Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g.,the production rate of pre-existing nearbywells would drop to a level which would not support existing land uses or planned uses for which permits have been granted); ❖ Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects; ❖ Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed; and/or ❖ Otherwise substantially degrade water quality. PROPOSED PRODUCT WATER QUALITY The product water quality from the Seawater Desalination Project at Huntington Beach can be potentially impacted by the following factors: ❖ Ocean Water Quality Fluctuations 1 ❖ Ocean Water Red Tide Algal Bloom Event ❖ HBGS Non-Routine Operations ❖ Reverse Osmosis (RO) Membrane Performance These potential impacts on product water quality are discussed below. Ocean Water Quality Fluctuations The product water of the proposed seawater desalination facility may be impacted by natural changes in ocean water salinity, temperature, turbidity and pathogen concentration. Typically, ocean water salinity and temperature changes are triggered by natural seasonal events. As discussed in Section 5.10, OCEAN WATER QUALITY and the Watershed Sanitary Survey (Appendix E), the intake ocean water turbidity and pathogen concentration changes are mainly driven by rain events. In order to maintain a consistent quality of desalinated product water, the applicant would be required to obtain a drinking water permit from the California Department of Health Services(DHS) that would address monitoring of source water quality and its effects on product water quality. The applicant has been working with DHS for the last four years to obtain such a permit. On August 10, 2002, DHS issued a conceptual approval letter for the Seawater Desalination Project at Huntington Beach. The desalination facility intake water quality in terms of turbidity(which is a surrogate indicator for potential elevated pathogen content)and salinity would be measured automatically and monitored continuously at the desalination facility intake. Instrumentation for continuous monitoring and City of Huntington Beach April 5, 2005 5.11-3 Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report recording of these parameters would be installed at the desalination facility intake pump station. In event of excessive increase in intake seawater turbidity and/or salinity, this instrumentation would trigger alarms that would notify desalination facility staff. If the intake pathogen count reaches a preset maximum level, this instrumentation would automatically trigger chlorination of the source water, thereby reducing the source water pathogens to acceptable levels even before the water reaches the RO treatment facilities. In addition to the automation provisions, turbidity and salinity would also be measured manually by the desalination staff at least once a day and the intake seawater would be analyzed for pathogen content at least once per week. In the event of elevated intake seawater turbidity, laboratory pathogen content analysis would be performed more frequently. In addition to the intake water quality monitoring instrumentation, the desalination facility pretreatment filtration facilities would be equipped with filter effluent turbidimeters and particle counters. This equipment would allow facility operators to continuously monitor pretreatment filter performance and to trigger adjustments of desalination facility operations to accommodate intake water quality changes. Desalinated product water quality would also be monitored continuously for salinity and chlorine residuals and would be tested frequently for pathogen content. In summary,desalinated product water quality would be tested in accordance with the requirements of the California Code of Regulations (Title 22)and the DHS. Product water quality impacts due to ocean water quality fluctuations are not anticipated to occur upon implementation of the design features described above. Red Tide Algal Bloom Events Occasionally, in late summer and fall, the surf zone along the Pacific Ocean may experience excessive growth of red-pigmented algae(phytoplankton),which"bloom"and accumulate into dense visible patches near the ocean surface such that the water appears to be colored red. This phenomenon is commonly known as"red tide". During a red tide event,some of the algae produce elevated concentrations of specific organic compounds(such as the biotoxins saxitoxin and domoic acid)and store these compounds in their cells. Typically,the concentrations of organic compounds produced during red tide events are not harmful for humans if the ocean water is ingested directly. Oysters and other shellfish such as clams, mussels and scallops can accumulate and concentrate these organic compounds in their tissues in excess of 1,000 times. Therefore,directly ingested red- tide ocean water typically does not cause harm to humans,while consumption of shellfish that has high concentrations of organic compounds generated during red tides may result in harm. Red tides are natural phenomenon usually occurring when temperature,salinity and nutrients in the ocean reach suitable levels to trigger a red tide bloom. The exact combination of factors that trigger red tide blooms is presently unknown, but some experts believe that high temperatures combined with lack of rainfall are at the root of red tide events. There are no known ways to control red tides. Therefore, the desalination facility would be designed to maintain high quality potable water (consistent with regulatory standards) in the event of a red tide event. The Seawater Desalination Project at Huntington Beach would have a number of provisions/barriers to protect against the passage of red tide-related algal organic compounds through the treatment processes. These provisions/barriers are described below: ❖ Deep Intake Configuration to Minimize Algae Entrainment: Most of the algal biomass during red tide events floats on the surface. The HBGS intake (the source from which the desalination facility would divert seawater from)is located at depth of approximately 33 feet City of Huntington Beach April 5, 2005 5.11-4 Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report ' below the water surface. Algal presence,accumulation and growth at this depth are minimal because of the limited access of sunlight, which is vital for algal growth. HBGS intake water is collected through a velocity cap atop a rectangular intake tower. The maximum mean water velocity at the inlet to the intake conduit is only two feet per second (fps), which minimizes collection of red tide algae from the ocean surface, where they are ' most abundant. Because of the low intake velocity and significant depth of the outfall, the amount of the algae that would be entrained along with the intake water and would be conveyed to the desalination facility would be minimized,thereby protecting the desalination facility from exposure to significant amounts of red tide-related algal organic compounds. ❖ Chlorination of Intake Seawater: The desalination facility intake pump station would be equipped with a sodium hypochiorite feed system which would be used for intake seawater chlorination on as needed basis. During episodes of red tide/algae blooms, chlorine would be applied at dosages of three to five mg/L. Chlorine is a strong oxidant,which, applied at the high dosages indicated above,would reduce the concentration of red tide-related algal organic compounds in the seawater, thereby further minimizing their content in the facility product water. In addition, intake seawater chlorination upstream of the pretreatment sand filters would significantly decrease algae growth in the filter cells. Chlorination of intake source water is a method commonly used for controlling algal blooms in conventional water treatment facilities applying direct filtration. At present, a significant portion of the intake water sources in the US are surface water sources occasionally exposed to algae blooms (reservoirs, lakes, slow-flowing portions of rivers). Typically, conventional treatment facilities applying granular media filtration and chlorination as key treatment methods are effective in treating surface water at times of algae blooms. ❖ Enhanced Coagulation of Intake Seawater: The desalination facility pretreatment filters would be equipped with a coagulant (ferric sulfate or ferric chloride) feed system, which would be applied continuously at the seawater intake at dosages of five to 10 mg/L. During episodes of red tide/algae blooms coagulation dosage would be increased to up to 20 to 30 mg/L to achieve enhanced coagulation and removal of algae from the intake water. ❖ Microfiltration or Dual Media Sand Filtration Algae Barrier: Algae conveyed with the intake seawater would be retained in the filter media and removed from the filters during filter cell backwashing. Because algae cells are the carrier of the red tide elevated concentration of algal organic compounds,their physical removal in the dual media filters would significantly reduce the potential for release from the algal biomass into the seawater that would be ' processed in the downstream treatment facilities (cartridge filters and RO membranes). Filter effluent water turbidity is expected to be maintained in a range of 0.05 to 0.3 nephelometric turbidity units(NTU). ❖ Microfiltration or Dual Media Sand Filter Covers: The surface of all pretreatment filters and filter channels would be covered to minimize sunlight exposure. Filter cell covers have proven to be an effective measure for minimizing algae growth in the filter cells. In combination with chlorination and enhanced coagulation,this measure would assure that the intake water algae are effectively retained and their growth in the filter media suppressed. ❖ Cartridge Filter Algae Barrier: The pretreatment filter effluent would be processed through five-micron cartridge filters located downstream of the granular media filters and ahead of the RO membranes. The size of the openings of these filters is an order of magnitude smaller than the size of the red tide algae cells. Therefore,the cartridge filters would provide City of Huntington Beach April 5, 2005 5.11-5 Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report an additional protection barrier in terms of algae cell propagation. The cartridge filter effluent would be practically devoid of all red tide algae and algal particles. ❖ RO Membranes: Reverse osmosis membranes are very effective in removing soluble compounds of molecular size smaller than the size of the red tide algal organic compounds. The proposed membrane elements at the seawater desalination facility would be capable of removing more than 99.6 % of the chloride ions contained in the seawater. Because the membrane elements work as physical barriers,they would also be very effective in removing organic molecules several times larger than chloride ions,such as these of the red tide algal organic compounds. The reverse osmosis membrane system is projected to remove more than 99 % of the red tide algal organic compounds remaining in the seawater,which would assure safe and reliable product water quality.' In addition, a study completed by the US Army Biochemical Research and Development Laboratory in 1993 also clearly indicates that reverse osmosis treatment is an effective method for removal of algal organic compounds, including saxotoxin. ❖ Final Disinfection:The permeate from the reverse osmosis system would be disinfected with chlorine followed by ammonia addition for chloramination. This final barrier of algal organic compound inactivation would provide additional assurance in terms of product water quality and safety. ❖ Emergency Facility Shutdown: Desalination facility operation can be discontinued within 10 minutes after notification in the event of red tide/algal blooms of catastrophic proportions or advisory by pertinent local and state heath safety agencies. Red tide genesis and development are usually closely followed by local agencies. Red tide growth to a level of a major calamity usually happens in a matter of days rather than minutes. Continuous communication with pertinent regulatory agencies in the times of red tide conditions would allow ample time for emergency shutdown in extreme cases of red tide occurrence. Seawater desalination facilities using RO membranes similar to those proposed for the Seawater Desalination Project at Huntington Beach have operated successfully for more than 15 years in other parts of the world with scarce alternative water resources (Spain, Cyprus, Israel, the Middle East and the Caribbean). In all of these locations red tide/algal blooms have occurred occasionally in the past. The fact that there are no documented cases of red tide health or safety problems associated with the operation of RO seawater desalination facilities worldwide is indicative of the capability of these systems to perform reliably and effectively under red tide conditions. Thus, less than significant impacts are anticipated in this regard. HBGS Non-Routine Operations Unusual activities at the HBGS,such as seawater emergency intake pump shut downs and failures, electricity equipment malfunctions, excessively high temperature of the cooling water, etc., may impact product water quality and desalination facility performance. The Seawater Desalination Project at Huntington Beach would have six different provisions incorporating several protection/notification devices to account for non-routine operations at the HBGS: ❖ _Automatic control interlock between HBGS pumps and desalination facility intake pumps: The shutdown controls of the desalination facility intake pumps would be interlocked with the HBGS pumps,so when HBGS pump operation is discontinued to prepare for heat treatment, ' Letter from Hydranautics to Poseidon Resources Corporation,June 18,2002. City of Huntington Beach April 5, 2005 5.11-6 Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report non-routine or even routine pump shutdown,this would automatically trigger an alarm at the desalination facility along with shutdown of the desalination intake pumps. After this emergency shutdown, the intake pumps would have to be started up manually, and the operations staff would be required to check the reason of shutdown with the HBGS staff before restarting the treatment facility intake pumps. ' ❖ Continuous Intake Pump Flow Measurement Devices: Seawater intake pumps would be equipped with flow meters,which would record the pumped flow continuously. If the intake flow is discontinued for any reason, including non-routine HBGS operations, this would trigger automatic intake pump shutdown. ❖ Continuous Intake Water Temperature Measurement Devices: The desalination facility ' intake pump station would be equipped with instrumentation for continuous measurement of the intake temperature. Any fluctuations of the intake temperature outside preset normal limits would trigger alarm and intake pump shutdown. This monitoring equipment would provide additional protection against heat treatment or other unusual intake water quality conditions. ❖ Continuous Intake Water Salinity/Conductivity Measurement Devices: The desalination facility intake pump station would be equipped with instrumentation for continuous measurement of the intake seawater salinity. Any fluctuations of the intake salinity outside preset normal operational limits would trigger an alarm and initiate intake pump shutdown. This monitoring equipment would provide additional protection against discharge of unusual fresh water/surface water streams in the facility outfall. ❖ Continuous Intake Water Oil Spill/Leak Detection Monitoring Devices: The desalination facility intake pump station would be equipped with instrumentation for oil spill/leak detection. Detection of oil in the intake water even in concentrations lower than 0.5 mg/L would 1 automatically trigger an alarm and initiate intake pump shutdown. This monitoring equipment would provide additional protection against unusual intake water quality conditions. ' ❖ Routine Communication with HBGS Staff: The desalination facility staff of each shift would be required to contact HBGS personnel at least once per shift and enquire about unusual planned or unplanned events at the HBGS. If non-routine operations are planned at the HBGS, the desalination facility would be informed and would modify desalination facility operations accordingly. Implementation of the six provisions described above would minimize impacts in this regard to less than significant levels. Reverse Osmosis Membrane Performance As the RO membrane elements age,their rejection capabilities decrease.This may trigger a change in product water quality from the Seawater Desalination Project at Huntington Beach. The RO system membrane performance would continuously monitor feed seawater and permeate conductivity and the differential pressure through the membranes. If permeate salinity (i.e. total dissolved solids [TDS]) concentration exceeds the design level, membranes would be cleaned to recover their original performance capabilities. In addition, an average of 10 to 15 percent of the membrane elements would be replaced every year,thereby maintaining the product water quality at ' a steady level. City of Huntington Beach April 5, 2005 5.11-7 Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report The Seawater Desalination Project at Huntington Beach would produce product water with lower TDS levels than that currently delivered to Orange County water purveyors by MWD. The TDS product water quality estimate of 350 mg/L is based on the use of high-rejection seawater desalination membranes at the second year of desalination facility operations. Typically,during the first two years of facility operations,the average product water quality TDS concentration would be lower than 350 mg/L. After the second year of operations, a portion (typically 10 to 15 percent per year) of the desalination facility membrane elements would be replaced to maintain the product water quality close to the target TDS concentration of 350 mg/L. Membrane replacement is a standard approach commonly used in seawater desalination facilities to maintain product water quality at a long-term steady target level. In addition,chloride and sodium are estimated to average 180 mg/L and 120 mg/L, respectively. These estimated water quality levels for TDS, chloride, and sodium are well below the newly adopted narrative water quality objectives in the amended Basin Plan and when the desalinated water is integrated into the water supply system it is unlikely that recycled water would exceed the amended Basin Plan narrative water quality objectives. The desalination facility would use industry standard eight-inch desalination membrane elements, which are available from a number of specialized membrane manufacturers. The membrane element manufacturers and their products pre-qualified for this project are: - Hydranautics (SWC3 or better) - Filmtec/Dow (SW30HR-380 or better) - Koch/Fluid Systems (TFC2822SS or better) - Toray (SU820L or better). Key design membrane element parameters common for the products of these suppliers are: - Membrane Type: Spiral-wound, thin film composite; - Applied Flux: eight to 12 gpd/sf at recovery rate of 45 to 50 percent; - Nominal Salt Rejection: 99.6 percent or higher; - Applied Pressure: 800 to 1,100 pounds per square inch (psi); - Maximum Pressure Drop per Element: 10 psi; - Maximum Feed Water SDI (15 min): 5.0; - Free Chlorine Resistance: less than 0.1 mg/L; - Operating pH Range: two to 11; and - QA/QC Membrane Production and Testing Procedures. The actual membrane element that would be used for the proposed desalination facility would be selected during the detailed engineering design phase of this project. The product water projections are performed for two conditions: new membranes at facility start up and membranes at the second year of facility operations.All projections are completed for low flow scenario conditions in terms of intake water salinity and temperature and membrane performance characteristics. At the beginning of the desalination facility operation the TDS concentration of the RO system permeate is projected to be between 226 and 308 mg/L, and at the end of the second year of desalination facility operations is projected to be between 257 and 349 mg/L(based on projections of product water quality and membrane performance in accordance with modeling specifications provided by two of the four membrane suppliers,Toray and Hydranautics). As previously indicated, the permeate water quality would be maintained at a second-year operations level over the entire 30-year period of facility operations by replacement of a portion of the membrane elements every year. It should be noted that the projections above are for the water quality of the RO system permeate as it exits the desalination system. Prior to distribution,the desalination facility permeate City of Huntington Beach April 5, 2005 5.11-8 Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report iwould be conditioned by lime and carbon dioxide for stabilization and corrosion control, and with chlorine forfinal disinfection. The addition of these conditioning chemicals would increase the final product water TDS concentration by 30 to 50 mg/L. Therefore, at facility start-up the TDS of the product water delivered to the distribution system is expected to be in a range of 260 to 340 mg/L, while for the entire 30-year period of facility operations the TDS concentration would be in a range of 300 to 400 mg/L and would average 350 mg/L. The projections presented above are developed using conservative assumptions for the type and performance of the membrane elements, intake water salinity and temperature. The applicant's previous pilot testing experience in Tampa and Carlsbad and the actual performance of the same Toray membranes in Trinidad indicate that the membrane manufacturer projections carry a safety factor of 10 to 15 percent and the actual product water quality is always better than that projected by the software. Advances in membrane technology over the next 30 years are expected to yield membrane ' elements capable of producing water of TDS concentration below 300 mg/L for most of the useful life of the desalination facility. Therefore, the projected product water TDS concentration of 350 mg/L is a reliable and conservative estimate of the potable water quality that would be delivered to the distribution system by the Seawater Desalination Project at Huntington Beach. As described in Section 3.0,PROJECT DESCRIPTION,the facility would be capable of meeting all drinking water standards through multiple treatment processes,which include: pretreatment filters; cartridge filters; reverse osmosis membranes; and product water conditioning and disinfection facilities. A comparison between the product water quality of the Seawater Desalination Project at Huntington Beach and the DHS primary and secondary water quality standards is presented in Table 5.11-3,PRODUCT WATER QUALITY COMPARISON. Review of this table indicates that the desalination facility product water quality meets all current DHS water quality MCL standards. The project would also be consistent with all requirements of the SARWQCB Basin Plan. Thus,impacts in this regard would not be significant. DHS Action Levels ' In addition to the Safe Drinking Water Act, which sets the primary and secondary MCLs for water quality constituents, the California DHS has established health-based advisory levels, known as "action levels", for specific chemicals which may be found in drinking water. The levels in Table 5.11-1, DHS DRINKING WATER NOTIFICATION LEVELS, provide information to public water agencies and others about certain non-regulated chemicals in drinking water that lack MCLs. Furthermore, Table 5.11-2, RESPONSE LEVELS, provides response level information at which DHS recommends removal of a source from service. Unlike MCLs,which are enforceable regulatory standards, action levels are advisory in nature and not enforceable standards. However, if a chemical is present over its action level, the following apply: ❖ Local Government Notification; ' ❖ Consumer Notification; and ❖ Removal of a Drinking Water Source from Service — DHS recommends that the drinking water system take the source out of a service if a chemical is present at levels considerably higher than the action levels. Response levels for these recommendations are presented in Table 5.11-2. City of Huntington Beach April 5, 2005 5.11-9 Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report Of all the chemicals listed in Table 5.11-1, boron is the only compound that is detectable in the product drinking water from the seawater desalination facility. After the reverse osmosis treatment process the desalted water boron level is approximately 0.6-0.8 mg/I,which is below the DHS action level. Table 5.11-1 DHS DRINKING WATER NOTIFICATION LEVELS Chemical Notification Level (milligrams per liter Boron 1 n-But (benzene 0.26 sec- But (benzene 0.26 Tert- But Ibenze 0.26 Carbon disulfide 0.16 Chlorate 0.8 2-Chlorotoluene 0.14 4-Chlorotoluene 0.14 Dichlorodifluoromethane Freon 12 1 1,4-Dioxane 0.003 Ethylene glycol 14 Formaldehyde 0.1 lsopropylbenzene 0.77 Manganese 0.5 Methyl isobut I MIBK 0.12 Naphthalene 0.017 N-Nitrosodieth lamine NDEA 0.00001 N-Nitrosodieth lamine(NDMA) 0.00001 Perchlorate 0.006 n-Propylbenzene 0.26 Teritiary butyl alcohol (TBA) 0.012 1,2,3-Trichloro ro ane 1,2,3-TCP 0.000005 1,2,4-Trimeth (benzene 0.33 1,3,5-Trimeth (benzene 0.33 Vanadium 0.05 Source: California Department of Health Services,"Drinking Water Action Levels:An Overview". Chemical was detected two or more times in at least one drinking water source 2002-2004. Table 5.11-2 RESPONSE LEVELS (at which DHS recommends removal of a source from service) Chemical Toxicological Endpoint Response Level Multi les of Notification Level 1,4-Dioxane TBA 1,2,3-TCP Cancer Risk 100 times the NL NDMA Cancer Risk 20 times the NL NDEA Cancer Risk 10 times the NL All Others Cancer Risk 10 times the NL Source: California Department of Health Services,"Drinking Water Action Levels:An OvervieW. City of Huntington Beach April 5, 2005 5.11-10 IM = = = i = w i = M = Ml Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report Table 5.11-3 PRODUCT WATER QUALITY COMPARISON Projected Water Seal Beach Fountain Valley Newport Beach Irvine Ranch MWDSC Primary MCL Quality Huntington Potable Potable Potable Water District Diemer or(Secondary Beach Desalination Groundwater Groundwater Groundwater (Groundwater) Filtration Plant MCL) Facility (2001 CCR) (2001 CCR) (2001 CCR) (2001 CCR) (2001 CCR) (Average) (Average) (Average) (Average) (Average) INORGANICS Antimony ) 6 <DLR <DLR <DLR <DLR <DLR <DLR Arsenic(µ L) 10 0.01 <DLR <DLR <DLR 2.7 2.3 Barium(µ ) 1,000 <DLR <DLR <DLR <DLR <DLR <DLR Be Ilium(µ ) 4 <DLR <DLR <DLR <DLR <DLR <DLR Cadmium(µ L) 5 <DLR <DLR <DLR <DLR <DLR <DLR Chloride m L) (250) 180 13 36 57 14 69 Chromium,total(µ L 50 <DLR <DLR <DLR <DLR <DLR <DLR Color(Units) (15) 1 <DLR DS 1.8 DS <DLR DS <DLR DS 1 Co er(µ L)90`hpercentile- * 10(at plant) 180 R 160 R 270 R 190 R <DLR Cyanide(µ L) 150 <DLR <DLR <DLR <DLR <DLR <DLR ...... . .. . �F��u ride ,_. � , , � " � • Ironµ L (300) 2 <DLR <DLR <DLR <DLR <DLR Leadµ 90'h percentile * 0.5 (at plant) 3.1 R <DLR <DLR 1.2 <DLR Man anese µ (50) <DLR <DLR <DLR <DLR 39 <DLR MBAS(m L) 0.5 <DLR <DLR <DLR <DLR <DLR <DLR Mercury(µ L) 2 <DLR <DLR <DLR <DLR <DLR <DLR Nickel(µ L) 100 <DLR <DLR <DLR <DLR <DLR <DLR i. t4'" 'n;, n,�' ✓ ': 9 ,3tli: r .Y6#'iCya1... f �..4 Nitrate; . =as N©3. ,,�.n. , : „ ' $;fi ro, , ..` v: �, �' LR . � . �3 � � � _7 �•�,ci�LRtk 22 I. - R Nitrite(m L as N) 1 <DLR <DLR <DLR <DLR <DLR <DLR Odor(TON) (3) 1 <DLR DS 1 DS 1.7 DS <DLR DS No data Selenium(µ ) 50 <DLR <DLR <DLR <DLR <DLR <DLR Silver(µ L 100 <DLR <DLR <DLR <DLR <DLR <DLR "<DLR"(less than the Detection Limit for Reporting purposes)means the contaminant would not be detected at or above the analytical reporting level established for each contaminant by the California Department of Health Services. "DS"means samples are collected for compliance purposes from the distribution system,not at the well/treatment plant. "R"means samples for lead and copper compliance are collected from residential taps,not at the well/treatment plant. City of Huntington Beach April 5,2005 5.11-11 Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report Table 5.11-3 PRODUCT WATER QUALITY COMPARISON cont'd Projected Water Seal Beach Fountain Valley Newport Beach Irvine Ranch MWDSC Primary MCL Quality Huntington Potable Potable Potable Water District Diemer or(Secondary Beach Desalination Groundwater Groundwater Groundwater (Groundwater) Filtration Plant MCL) Facility (2001 CCR) (2001 CCR) (2001 CCR) (2001 CCR) (2001 CCR) (Average) (Average) (Average) (Average) (Average) w os/ctn _ Thallium(µ L) 2 <DLR <DLR <DLR <DLR <DLR <DLR DSI m, 32 z �.7. l Tdt ld' ", Tl7 3 .S 016' � 2 1✓R S : 6 Zinc /1- (5,000) <DLR <DLR <DLR <DLR <DLR <DLR RADIOACTIVITY ( Ci/L) Radium 226 and 228 5 <DLR No data No data No data No data <DLR Strontium 90 8 <DLR No data No data No data No data No data Tritium 20,000 <DLR No data No data No data No data No data Uranium 20 <DLR No data 4.9 5.2 No data 2.6 VOLATILE ORGANICS g/L Benzene 1 <DLR <DLR <DLR <DLR <DLR <DLR Bromoform THM <DLR <DLR <DLR <DLR <DLR <DLR Carbon tetrachloride 0.5 <DLR <DLR <DLR <DLR <DLR <DLR Chlorodibromomethane THM <DLR <DLR <DLR <DLR <DLR <DLR Chloroform THM <DLR <DLR <DLR <DLR <DLR <DLR 1,2—Dichlorobenzene 600 <DLR <DLR <DLR <DLR <DLR <DLR 1,4—Dichlorobenzene 5 <DLR <DLR <DLR <DLR <DLR <DLR Dichlorobromomethane THM <DLR <DLR <DLR <DLR <DLR <DLR 1,1—Dichloroethane 5 <DLR <DLR <DLR <DLR <DLR <DLR 1,2—Dichloroethane 0.5 <DLR <DLR <DLR <DLR <DLRJ <DLR 1,1—Dichloroethylene 6 <DLR <DLR <DLR <DLR <DLR <DLR "<DLR"(less than the Detection Limit for Reporting purposes)means the contaminant would not be detected at or above the analytical reporting level established for each contaminant by the California Department of Health Services. °DS"means samples are collected for compliance purposes from the distribution system,not at the well/treatment plant. W means samples for lead and copper compliance are collected from residential taps,not at the well/treatment plant. City of Huntington Beach April 5,2005 s s r Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report Table 5.11-3 PRODUCT WATER QUALITY COMPARISON cont'd Projected Water Seal Beach Fountain Valley Newport Beach Irvine Ranch MWDSC Primary MCL Quality Huntington Potable Potable Potable Water District Diemer or(Secondary Beach Desalination Groundwater Groundwater Groundwater (Groundwater) Filtration Plant MCL) Facility (2001 CCR) (2001 CCR) (2001 CCR) (2001 CCR) (2001 CCR) (Average) (Average) (Average) (Average) (Average) t-1,2-Dichloroethylene 10 <DLR <DLR <DLR <DLR <DLR <DLR Dichloromethane 5 <DLR <DLR <DLR <DLR <DLR <DLR 1,2—Dichloropro ane 5 <DLR <DLR <DLR <DLR <DLR <DLR 1,3—Dichloro ro ene 0.5 <DLR <DLR <DLR <DLR <DLR <DLR Ethylbenzene 300 <DLR <DLR <DLR <DLR <DLR <DLR Monochlorobenzene 70 <DLR <DLR <DLR <DLR <DLR <DLR MTBE 13 <DLR <DLR <DLR <DLR <DLR <DLR Styrene 100 <DLR <DLR <DLR <DLR <DLR <DLR 1,1,2,2—Tetrachloroethane 1 <DLR <DLR <DLR <DLR <DLR <DLR Tetrachloroethylene 5 <DLR <DLR <DLR <DLR <DLR <DLR Toluene 150 <DLR <DLR <DLR <DLR <DLR <DLR 1,2,4—Trichlorobenzene 5 <DLR <DLR <DLR <DLR <DLR <DLR 1,1,1—Trichloroethane 200 <DLR <DLR <DLR <DLR <DLR <DLR 1,1,2—Trichloroethane 5 <DLR <DLR <DLR <DLR <DLR <DLR Trichloroeth lene 5 <DLR <DLR <DLR <DLR <DLR <DLR Trichlorofluoromethane 150 <DLR <DLR <DLR <DLR <DLR <DLR 1,1,2-Trichlorotrifluoroethane 1,200 <DLR <DLR <DLR <DLR <DLR <DLR Vinyl Chloride 0.5 <DLR <DLR <DLR <DLR <DLR <DLR Xylenes 1,750 <DLR <DLR <DLR <DLR <DLR <DLR SYNTHETIC ORGANICS /L Alachlor 2 <DLR <DLR <DLR <DLR <DLR <DLR Atrazine 1 <DLR <DLR <DLR <DLR <DLR <DLR arnna-BHC(Lindane) 0.2 <DLR <DLR <DLR <DLR <DLR <DLR Bentazon 18 <DLR <DLR <DLR <DLR <DLR <DLR Carbofuran 18 <DLR <DLR <DLR <DLR <DLR <DLR "<DLR"(less than the Detection Limit for Reporting purposes)means the contaminant would not be detected at or above the analytical reporting level established for each contaminant by the California Department of Health Services. "DS"means samples are collected for compliance purposes from the distribution system,not at the well/treatment plant. "R"means samples for lead and copper compliance are collected from residential taps,not at the well/treatment plant. City of Huntington Beach April 5,2005 5.11-13 Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report Table 5.11-3 PRODUCT WATER QUALITY COMPARISON cont'd Projected Water Seal Beach Fountain Valley Newport Beach Irvine Ranch MWDSC Primary MCL Quality Huntington Potable Potable Potable Water District Diemer or(Secondary Beach Desalination Groundwater Groundwater Groundwater (Groundwater) Filtration Plant MCL) Facility (2001 CCR) (2001 CCR) (2001 CCR) (2001 CCR) (2001 CCR) (Average) (Average) (Average) (Average Average) Chlordane 0.1 <DLR <DLR <DLR <DLR <DLR <DLR 2,4-D 70 <DLR <DLR <DLR <DLR <DLR <DLR Dala on 200 <DLR <DLR <DLR <DLR <DLR <DLR 1,2—Dibromo-3— 0.2 <DLR <DLR <DLR <DLR <DLR <DLR chloro ro ane Di(2-ethy1hexyl)adi ate 400 <DLR <DLR <DLR <DLR <DLR <DLR Di 2-ethy1hexyl) hthalate 4 <DLR <DLR <DLR <DLR <DLR <DLR Dinoseb( ) 7 <DLR <DLR <DLR <DLR <DLR <DLR Diquat 20 <DLR <DLR <DLR <DLR <DLR <DLR Endothall 100 <DLR <DLR <DLR <DLR <DLR <DLR Endrin 2 <DLR <DLR <DLR <DLR <DLR <DLR Ethylene dibronude 0.05 <DLR <DLR <DLR <DLR <DLR <DLR Gl hosate 700 <DLR <DLR <DLR <DLR <DLR <DLR Heptachlor 0.01 <DLR <DLR <DLR <DLR <DLR <DLR Heptachlor epoxide 0.01 <DLR <DLR <DLR <DLR <DLR <DLR Hexachlorobenzene 1 <DLR <DLR <DLR <DLR <DLR <DLR Hexachlorocyclo entadiene 50 <DLR <DLR <DLR <DLR <DLR <DLR Methox chlor 30 <DLR <DLR <DLR <DLR <DLR <DLR Molinate 20 <DLR <DLR <DLR <DLR <DLR <DLR Oxam l 50 <DLR <DLR <DLR <DLR <DLR <DLR Pentachloro henol 1 <DLR <DLR <DLR <DLR <DLR <DLR Picloram 500 <DLR <DLR <DLR <DLR <DLR <DLR Polychlorinated bi hen is 0.5 <DLR <DLR <DLR <DLR <DLR <DLR Simazine 4 <DLR <DLR <DLR <DLR <DLR <DLR 2,4,5—TP(Silvex) 50 <DLR <DLR <DLR <DLR <DLR <DLR Thiobencarb 70 <DLR <DLR <DLR <DLR <DLR <DLR "<DLR"(less than the Detection Limit for Reporting purposes)means the contaminant would not be detected at or above the analytical reporting level established for each contaminant by the California Department of Health Services. "DS"means samples are collected for compliance purposes from the distribution system,not at the well/treatment plant. W means samples for lead and copper compliance are collected from residential taps,not at the well/treatment plant. City of Huntington Beach April 5,2005 k 5.1 1-4 A, m m m m ■11 = = M M M m m a" = IM m m Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report Table 5.11-3 PRODUCT WATER QUALITY COMPARISON (cont'd) Projected Water Seal Beach Fountain Valley Newport Beach Irvine Ranch MWDSC Primary MCL Quality Huntington Potable Potable Potable Water District Diemer or(Secondary Beach Desalination Groundwater Groundwater Groundwater (Groundwater) Filtration Plant MCL) Facility (2001 CCR) (2001 CCR) (2001 CCR) (2001 CCR) (2001 CCR) (Average) (Average) (Average) (Average) (Average) Toxa hene 3 <DLR <DLR <DLR <DLR <DLR <DLR MICROBIALS (MPNI100m1) Fecal Coliform -%positives ** 0 0 0 0 0 0 OTHER ANALYSES m 1L Alkalinity 50 No data 169 179 No data 104 Total Hardness 50 No data 63 79 No data 49 Ma esium 15 No data 11 13 No data 21 H(Units) 8.0 No data 8.0 8.0 No data 8.0 Potassium 5.0 No data 2.5 3.5 No data 3.5 Sodium 120 60 43 55 52 65 "<DLR"(less than the Detection Limit for Reporting purposes)means the contaminant would not be detected at or above the analytical reporting level established for each contaminant by the California Department of Health Services. "DS"means samples are collected for compliance purposes from the distribution system,not at the well/treatment plant. W means samples for lead and copper compliance are collected from residential taps,not at the well/treatment plant. City of Huntington Beach April 5,2005 5.11-15 Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report PRODUCT WATER RELIABILITY The desalination facility operations would be fully automated and key systems would be provided with redundant equipment and controls per the requirements of Title 22 of the California Code of Regulations. In the event of an underground booster pump station power outage,the booster pump station would be equipped with on-site power generators that would allow their operation to continue even if the main source of power supply has been interrupted. The desalination facility would be provided with two independent sources of power supply, which includes an electrical power grid and/or the HBGS auxiliary reserve bank to assure uninterrupted operations during emergencies. The desalination facility would be manned 24 hours per day, 365 days per year by skilled and certified operators,which would coordinate facility and pump station operations with that of all other water purveyors delivering water to or operating the water distribution system facilities. As a part of desalination and pumping station operations, the operations staff would develop an earthquake mitigation and preparedness plan, which would be coordinated with the City of Huntington Beach. This plan would define coordination measures to assure continuous facility operations and water delivery under earthquake emergency conditions. The desalination facility would be designed with one standby reverse osmosis train to provide additional reliability of water production and supply. Typically, desalination facilities, including the existing desalination facilities in California, are designed to operate with all available reverse osmosis trains in operation at all times. During the times of potential outages caused by scheduled or unscheduled maintenance or emergency events, such as an earthquake,these facilities operate at reduced capacity or are down for a certain period of time. The proposed desalination facility would be designed to produce 50 mgd of product water with 12 RO trains,and would be constructed with an additional 13th RO standby train, which can produce up to 4.2 mgd of water at any time. This additional train would provide increased reliability and redundancy that exceeds current reliability standards and common practices for desalination facility design. The proposed desalination facility would be the first facility in California with such additional production standby capacity and reliability provisions. The issues of reliability of the supply and emergency service provisions would be dictated by the terms of the institutional agreements negotiated with the regional water purveyors (including MWDOC and Metropolitan Water District) and by the terms of the water supply agreements negotiated with potential customers that would purchase the product water produced at the desalination facility. Thus, impacts are anticipated to be less than significant in this regard with mitigation. ORANGE COUNTY WATER DISTRIBUTION SYSTEM The introduction of desalinated product water into the existing Orange County distribution system may result in impacts in regards to the following: ➢ Blended Water Quality ➢ Blended Water Corrosivity ➢ Blended Water Chlorine Residual ➢ Blended Water Disinfection Byproduct Concentration ➢ Blended Water Taste and Odor ➢ Hydraulics City of Huntington Beach April 5, 2005 5.11-16 Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report Blended Water Quality Due to distribution system operations at certain points in the system, desalinated water may blend with other source waters,such as local groundwater or imported water from the Metropolitan Water District of Southern California. This blending could have water quality improvement benefits, especially if the receiving agencies are predominantly using imported water,which has higher levels 1 of TDS, sulfate, hardness and disinfection byproducts than desalinated water. The desalination facility would produce drinking water of very high and consistent quality, which meets or exceeds all applicable regulatory requirements established by the EPA and the DHS. The desalinated water would be produced applying state-of-the-art seawater RO membranes which are capable of removing practically all contaminants in the source water: turbidity; taste, odor, color, bacteria, viruses, salts, proteins, asbestos, organics, etc. Currently, EPA recognizes RO membrane treatment as a best available technology for water treatment and for meeting future water quality regulations. The desalinated water would have approximately 100 mg/L lower salinity(i.e.TDS)than the existing drinking water. The lower drinking water salinity would result in better taste and lower overall water distribution system corrosivity. The desalinated seawater would be softer than the existing water sources. Softer water has a number of benefits such as: better taste; formation of less calcium deposits on household appliances and cutlery;and lower detergent use. Commercial and industrial 1 establishments which currently use softening devices to treat the potable water would also benefit from introduction of the softer desalinated water in the distribution system, as their softening costs may be reduced and some of these users may not need to soften their water anymore (most industrial users typically require water with a hardness below 80 mg/L—as desalinated waterwould reduce hardness by at least 50 percent, softening costs would also be reduced commensurately). Similar to TDS, drinking water of lower sulfate consternation would have a better taste. The ' desalinated water would have order-of-magnitude lower disinfection byproducts, such as total trihalomethanes and halocetic acids, or TTHM and HAA, respectively) concentrations than the existing drinking water(refer to Appendix N,DISINFECTION BYPRODUCT FORMATION STUDY). Disinfection byproducts are well known carcinogens and their reduction in the drinking water as a result of the blending of the desalinated water with other water sources would be an added benefit. As such, the blending of desalinated product water with existing imported MWD water is not anticipated to result in significant impacts. Blended Water Corrosivity Blending the desalinated product water with existing water from other sources may change the water quality of the blend in terms of its corrosion effect on the existing water distribution system. When evaluating potential short-term and long-term impacts of blending treated waters from different sources, one of the most important considerations is the potential for corrosion of pipes and residential fixtures. Excessive corrosion over time might lead to colored water in homes, stained fixtures, pipe failures, and non-compliance with the Lead and Copper Rule. In 1992, the EPA promulgated the Lead and Copper Rule to protect drinking water consumers from excessively high concentrations of lead and copper in the drinking water caused by corrosion of household and public building plumbing systems. The rule sets limits for lead and copper in samples collected from faucets with risk for elevated lead and copper concentrations. The limits for lead and copper are 15 µg/L (micrograms per liter), and 1.3 mg/L, respectively. Similar to all other potable water sources in the distribution system,product waterfrom the Seawater Desalination Project at Huntington Beach would be chemically conditioned at the treatment facility prior to delivery to the distribution system to mitigate its corrosivity. Lime,in combination with carbon City of Huntington Beach April 5, 2005 5.11-17 Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report dioxide, would be added for post-treatment stabilization of the RO water as a source for pH and alkalinity adjustment and hardness addition. A corrosion control study describing in detail the type and amount of corrosion control chemicals planned to be used for this project are presented in Appendix O, DISTRIBUTION SYSTEM CORROSION CONTROL STUDY. The product water from the seawater desalination facility would be suitable for delivery through the existing water distribution system and would be comparable and compatible to the other water sources currently delivering water to the same system. Prior to delivery to the water distribution system the desalinated water would be conditioned using lime and carbon dioxide to achieve the following corrosion control driven water quality parameters,which are known to be consistent with water currently distributed throughout Orange County: • pHof8to8.5; • Langelier Saturation Index (LSI)of 0.0 to 0.5; and • Alkalinity of 40 mg/L or higher. These water goals are established based on current practices of the MWD, MWDOC, and most water agencies and municipalities in Orange County. The water goals are rooted in the Safe Drinking Water Act's water quality standards. These water quality goals would be achieved by the addition of the following chemicals: • Lime at dosage of 25 to 50 mg/L (average of 30 mg/L) • Carbon dioxide at dosage of zero to 30 mg/L (average of six mg/L) Adopting this proven corrosion control strategy would result in a non-corrosive product that can be seamlessly integrated into the system. In addition, a corrosion monitoring system would be installed in the proposed transmission pipeline at points of interconnection with the existing water distribution system to ensure that the proposed corrosion control measures are effective and adequate. As such, impacts in regards to corrosion are not anticipated to be significant upon implementation of the design features described above. Chlorine Residual The disinfected desalinated water may impact the disinfection of the existing water sources. The potential impacts include a change in the concentration of disinfection byproducts and a reduction of chloramine residual in the other water sources with which desalinated water is blended. The potential impacts and their assessment are described in detail in a separate study provided in Appendix N, DISINFECTION BYPRODUCT FORMATION STUDY. The desalinated product water would be disinfected prior to delivery to the distribution system. Chlorine, in the form of sodium hypochlorite, would be added as a disinfectant to meet DHS water quality standards for potable water disinfection. The desalted water would meet current imported water disinfection methods so as to not change any disinfection protocol currently being used by water agencies. Controlling biological growth in the transmission pipelines and in the receiving reservoirs in the distribution system would be accomplished by adding ammonia to the chlorinated water to form chloramines. Potable water from MWD as well as that from some local groundwater sources also contains chloramines as the final residual disinfectant. All of these treated water sources would have compatible chlorine residuals. City of Huntington Beach April 5, 2005 5.11-18 Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report The desalinated water would be chloraminated by sequential application of sodium hypochlorite and ammonia to achieve a chloramine residual concentration at the point of delivery to the distribution system is in a range of two to 2.5 mg/L. A detailed description of the proposed chloramination process is provided in Appendix N,DISINFECTION BYPRODUCT FORMATION STUDY.This study confirms that after blending of the chloraminated product water from the desalination facility with disinfected product water from other sources,the chloramine residual of the blend meets the target level in the distribution system of two to 2.5 mg/L. As such, impacts in this regard are not anticipated to be significant. Disinfection Byproduct Concentration The desalinated product water may impact the content of disinfection byproducts (known to be carcinogenic) of existing water sources within the distribution system. The two key groups of regulated disinfection byproducts that can be impacted are TTHMs and HHAs. The desalinated water typically has higher concentration of bromides than the other water sources. Bromides may create additional disinfection byproducts. Therefore, when blended with other source waters, the desalinated water may increase the concentration of disinfection byproducts in the other sources. On the other hand,the existing water sources in Orange County typically contain much higher level of organics than the desalinated water, which is practically void of organics. Organics are also a potential source of disinfection byproducts. Therefore, blending of desalinated water with other water sources may have a positive impact on water sources with high organic concentrations. Blending desalinated water with existing sources of supply would result in a product that is comparable to existing supplies and meets all disinfection byproduct limits. Desalinated seawater contains lower levels of organics than existing Orange County sources,such as the MWD's Diemer filtration facility and all other local groundwater water sources. Therefore, blending of desalinated water with other source waters in the distribution system would have a beneficial effect,and would lower the overall disinfection byproduct concentration of the blend. The results of Appendix N, DISINFECTION BYPRODUCT FORMATION STUDYconfirm the beneficial effect of the desalinated water on the blended water quality in terms of disinfection byproducts. As such, impacts in this regard are not anticipated to be significant. Blended Water Taste and Odor No measurable impact on odor is expected as a result of the integration of the desalinated water with water from other sources in the distribution system.The desalinated water would be softer and would have lower salinity than the other water sources. Therefore, blending of these sources would result in an overall reduction of the salinity and hardness of the water delivered to the customers. Lower salinity and hardness of the blended product water would be beneficial and would have a positive effect on the taste of the water delivered to the customers. ' As shown in Table 5.11-3, PRODUCT WATER QUALITY COMPARISON, the projected quality of the project water after RO treatment is closely comparable with the finished water it would blend with in the distribution system. In terms of odor, the desalination facility product water would meet the DHS MCL. In terms of regulated volatile organics, and other compounds that may impact product water taste and odor, product water from the Seawater Desalination Project at Huntington Beach would comply with all drinking water standards and does not differ substantially from the water quality of the other sources of product water in the distribution system. Therefore,the desalinated water would be better than or equal to existing water sources in the distribution system in terms of taste and odor. With pores ranging from 0.00005 to 0.0000002 microns(for comparison,a human hair is 200 microns in diameter)the RO membranes would retain and remove over 99.5 % of the seawater salinity;and over 99%of the metals and organics which may cause undesirable taste and odor of the product water. City of Huntington Beach April 5, 2005 5.11-19 Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report As indicated in Appendix X, DESALINATION FACILITIES LOCATED THROUGHOUT THE WORLD, desalinated seawater has been used for over 15 years worldwide without any problems encountered in terms of taste or odor quality. In 1999, Marin County completed a taste and odor survey of desalinated seawater and over 99 percent of the participants in the test indicated that desalinated seawater tasted better than alternative water sources. At a recent water taste testing event in Florida, the product water of the Marco Island seawater desalination facility(which is the second largest seawater desalination facility in the U.S.)was found to be the best tasting water in Southern Florida. To protect against potential taste and odor problems associated with the startup of facility operations, just prior to startup, a sequential flushing program would be coordinated with the involved water agencies to minimize any sediment disturbance that might occur due to flow reversal in a portion of the existing distribution system. A flushing program would minimize any aesthetic issues that might be created through flow reversal. In addition, a sampling location would be established near the physical connection of the transmission pipeline to the OC-44 feeder. A monitoring program would be implemented for this location incorporating the following parameters: coliform bacteria, heterotrophic bacteria, chlorine residual,disinfection byproducts,and aesthetic parameters such as turbidity,odor,and color,as well as corrosion indices. The purpose of this sampling point is to verify on a regular basis that no degradation of water quality has occurred during any period of storage at the facility site or in the transmission pipeline and that mixing of desalinated water with water from other sources continues to be compatible. In summary, because of the close chemical compatibility between the desalinated water produced at the Seawater Desalination Project at Huntington Beach and that of existing water sources in Orange County, no impacts in regards to taste and odor are expected. If such problems occur, the desalination facility water quality can be adjusted by controlling the RO membrane system removal efficiency in terms of particular compounds that may cause taste and/or odor issues,or the product water conditioning chemicals can be changed.2 Hydraulics Implementation of the proposed project may have hydraulic impacts on the regional water distribution system. A total of three pump stations would be necessary for operation of the project: 1)a product water pump station at the desalination facility site; 2)the OC-44 underground booster pump station in unincorporated Orange County; and 3)the Coastal Junction underground booster pump station in Irvine. Project implementation could potentially alter the flow rate and pressure of multiple transmission lines serving the vicinity. Based on hydraulic modeling performed for the proposed project,the following water transmission mains in the project vicinity are not anticipated to be impacted by the proposed project(it is assumed that all facilities discussed below have design features to prevent hydraulic surges): ❖ East Orange County Feeder#2 ❖ Irvine Cross Feeder ❖ Coast Supply Line ❖ Aufdenkamp Transmission Main Z The RO membrane system efficiency, in terms of particular compounds, would be controlled by measuring the turbidity of the desalinated water produced by the membrane system.Turbidity monitoring is achieved by installation of turbidimeters on the individual RO membrane trains and a turbidimeter that measures the turbidity of the desalinated water at the point of which the water leaves the facility site. If the turbidity is above a preset level determined by the DHS regulatory requirements,the individual RO membrane trains would be checked for leaks and the defective or failed membrane elements would be replaced. City of Huntington Beach April 5, 2005 5.11-20 Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report ' ❖ Tri-Cities Transmission Main ❖ Newport Beach Wells Supply Line However, the hydraulic characteristics of the OC-44 pipeline may be affected in one of two ways, depending on whether the pipeline segment in question is east or west of the proposed OC-44 connection point: 1)west of the proposed OC-44 connection point, the flow rate and flow direction would remain unchanged, while a change in water pressure would be negligible (a change of less than five psi);and 2)east of the proposed connection point,the direction of flow would be reversed, the flow rate would increase, and water pressure would decrease. It is anticipated that maximum flow velocity through this portion of the pipeline would be 7.5 fps. All flow rate, pressure, and velocity changes,which may occur in the existing pipelines,are within pipeline design specifications. In addition,the hydraulic characteristics of the East Orange County Feeder No.2(EOCF#2)may be affected in one of two ways, depending on whether the pipeline segment in question is north or south of the Coastal Junction (the point at which the Tri-Cities and Aufdenkamp Transmission Mains connect to the EOCF#2): 1)north(upstream)of the Coastal Junction,the flow rate within EOCF#2 would decrease (this decrease may allow water pressure to rise, but the resulting change in water pressure would be well within allowable design pressure for the existing pipeline); and 2) south (downstream)of the Coastal Junction, the direction of flow would be reversed, the water pressure would rise, and the flow rate would increase to a maximum velocity of 3.6 fps. Based on the hydrodynamic model, the pressure class of the existing pipeline is of sufficient strength to accommodate changes incurred by the proposed project. Thus, impacts in this regard would not be significant. Pressure Surges Appendix D, PRESSURE SURGE ANALYSIS, provides a discussion of potential impacts of the three pump stations associated with the project. The report includes the effect of pressure surges on: ❖ The proposed desalinated water 42- to 48-inch pipeline (between the desalination facility and the OC-44 transmission main) ❖ East Orange County Feeder#2 ❖ Irvine Cross Feeder ❖ Coast Supply Line ❖ Aufdenkamp Transmission Main ❖ Tri-Cities Transmission Main Analysis concludes that in the event of a loss of power to the booster pump stations,a low-pressure wave is predicted to propogate out from the discharge site of each booster pump station and into the associated pipelines. As the water travels toward its applicable destination (reservoirs, demand locations, and booster pump stations), the low-pressure waves cause the pipeline pressure to fall. ' Simultaneously,a pressure upsurge wave is predicted to propagate out from the suction side of the OC-44 and Coastal Junction pump stations. Following the loss of power to the pump station located at the desalination site,a vapor condition is I created in the desalinated water conveyance pipeline. When the product water conveyance pipeline is re-pressurized by a reflected waterhammer wave, any vapor cavities that are formed would collapse, and may create extremely high local pressure spikes that may damage the pipeline, resulting in premature corrosion and the development of leaks. When subjected to negative pressure,a leak could become a source of pathogen intrusion. If the piping does not have sufficient strength to withstand a full vacuum, the pipeline could collapse under such low pressures. City of Huntington Beach April 5, 2005 5.11-21 Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report To eliminate large negative pressures and the possibility of vapor cavity formation in the delivery pipeline system above,surge protection measures for proposed project facilities are recommended as follows: ❖ Incorporation of pressurized surge tanks at booster pump station locations; and ❖ Vacuum relief and air release valve improvements. Hydraulic modifications recommended for the existing water distribution system include the following: ❖ Hydraulically operated isolation valves; ❖ Elimination of existing valves; and ❖ Pressure control valve improvements. Refer to Appendix D, PRESSURE SURGE ANALYSIS, for additional information. Additional modeling would be performed during the design phase of the project to confirm that the proposed project would not have significant impacts on regional water transmission facilities. MITIGATION MEASURES PRODUCT WATER QUALITY PW-1 Prior to project operations, the applicant shall obtain all required drinking water permits from the California Department of Health Services. These permits are anticipated to consist of: ❖ a Wholesale Drinking Water Permit; and ❖ an Administrative Change to Retail Agencies' Drinking Water Permit(to include desalinated water from the proposed project as an approved source of supply for their agency). PW-2 During final design of the proposed project, the applicant shall incorporate the following six provisions to protect water quality in the event of"non-routine"operations at the HBGS (defined as operations such as seawater emergency intake pump shut downs and failures, electricity equipment malfunctions, excessively high temperature of the cooling water, etc.): ❖ Automatic control interlock between HBGS pumps and desalination facility intake pumps:The shutdown controls of the desalination facility intake pumps shall be interlocked with the HBGS pumps, so when HBGS pump operation is discontinued to prepare for heat treatment, non-routine or even routine pump shutdown, this would automatically trigger an alarm at the desalination facility along with shutdown of the desalination intake pumps. After this emergency shutdown, the intake pumps shall be started up manually, and the operations staff would be required to check the reason of shutdown with the HBGS staff before restarting the treatment facility intake pumps. ❖ Continuous Intake Pump Flow Measurement Devices: Seawater intake pumps shall be equipped with flow meters, which would record the pumped flow continuously. If the intake flow is discontinued for any reason, including non- routine HBGS operations, automatic intake pump shutdown shall occur. City of Huntington Beach April 5, 2005 5.11-22 Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report ❖ Continuous Intake Water Temperature Measurement Devices: The desalination facility intake pump station shall be equipped with instrumentation for continuous measurement of the intake temperature. Any fluctuations of the intake temperature outside preset normal limits shall trigger alarm and intake pump shutdown. This monitoring equipment shall provide additional protection against heat treatment or other unusual intake water quality conditions. ❖ Continuous Intake Water Salinity/Conductivity Measurement Devices: The desalination facility intake pump station shall be equipped with instrumentation for continuous measurement of the intake seawater salinity. Any fluctuations of the intake salinity outside preset normal operational limits shall trigger an alarm and initiate intake pump shutdown. This monitoring equipment shall provide additional protection against discharge of unusual fresh water/surface water streams in the facility outfall. ❖ Continuous Intake Water Oil Spill/Leak Detection Monitoring Devices: The desalination facility intake pump station shall be equipped with instrumentation for oil spill/leak detection. Detection of oil in the intake water even in concentrations lower than 0.5 mg/L shall automatically trigger an alarm and initiate intake pump shutdown. This monitoring equipment shall provide additional protection against unusual intake water quality conditions. ❖ Routine Communication with HBGS Staff: The desalination facility staff of each shift shall be required to contact HBGS personnel at least once per shift and enquire about unusual planned or unplanned events at the HBGS. If non-routine ' operations are planned at the HBGS, the desalination facility shall modify desalination facility operations accordingly. PW-3 During project operations,the RO membrane system shall be continuously monitored for feed seawater and permeate conductivity and the differential pressure through the membranes. If permeate salinity (i.e. total dissolved solids) concentration exceeds the design level, membranes shall be cleaned to recover their original performance capabilities. PRODUCT WATER RELIABILITY PW-4 Prior to project operations, the desalination facility operations staff shall develop an earthquake mitigation and preparedness plan,which shall be coordinated with the City of Huntington Beach. This plan shall define coordination measures to assure continuous facility operations and water delivery under earthquake emergency conditions. ORANGE COUNTY WATER DISTRIBUTION SYSTEM PW-5 Prior to project operations, a corrosion monitoring system shall be installed in the proposed transmission pipeline at points of interconnection with the existing water distribution system to ensure that the proposed corrosion control measures are effective and adequate. PW-6 To protect against potential taste and odor problems associated with the startup of facility operations,a sequential flushing program shall be initiated just prior to project startup that shall be coordinated with the involved water agencies to minimize any sediment disturbance that might occur due to flow reversal in a portion of the existing distribution system. City of Huntington Beach April 5, 2005 5.11-23 Seawater Desalination Project at Huntington Beach 5.11 PRODUCT WATER QUALITY Draft Recirculated Environmental Impact Report PW-7 Prior to project operations, a sampling location shall be established near the physical connection of the transmission pipeline to the OC-44 feeder. A monitoring program shall be implemented for this location incorporating the following parameters:coliform bacteria, heterotrophic bacteria,chlorine residual,disinfection byproducts,and aesthetic parameters such as turbidity, odor, and color, as well as corrosion indices. PW-8 Prior to project operations, additional modeling shall be performed to confirm that the proposed project shall not have pressure surge impacts upon the existing regional water distribution system. The model shall recommend appropriate facilities to prevent pressure surges, such as ❖ Incorporation of pressurized surge tanks at booster pump station locations; ❖ Vacuum relief and air release valve improvements; ❖ Hydraulically operated isolation valves; ❖ Elimination of existing valves; and/or ❖ Pressure control valve improvements. PW-9 Prior to project operations, the applicant shall coordinate with and obtain approval as required from applicable local water agencies that own and operate the distribution system in which the desalinated water would come in contact with. Various operating approvals and corresponding agreements shall be signed before the desalinated water is introduced into the local distribution system. UNAVOIDABLE SIGNIFICANT IMPACTS None have been identified. City of Huntington Beach April 5, 2005 5.11-24 � 6.0 LONG-TERM IMPLICATIONS OF � THE PROPOSED PROJECT i 1 6.0 LONG-TERM IMPLICATIONS OF THE PROPOSED PROJECT 6.1 SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL CHANGES THAT WOULD BE INVOLVED IN THE PROPOSED ACTION SHOULD IT BE IMPLEMENTED The CEQA Guidelines mandate that the EIR must address any significant irreversible environmental changes which would be involved in the proposed action should it be implemented (CEQA Guidelines Section 15126.2[c]). An impact would fall into this category if: ❖ The project would involve a large commitment of non-renewable resources; ❖ The primary and secondary impacts of the project would generally commit future generations to similar uses; ❖ The project involves uses in which irreversible damage could result from any potential environmental incidents associated with the project; or ❖ The proposed consumption of resources is not justified (e.g., the project results in wasteful use of energy). Construction of the proposed Seawater Desalination Project at Huntington Beach would commit the project site and associated off-site components to the uses identified in the project description for the foreseeable future, and thereby limit the range of other uses that could, in the future, be implemented on the subject properties. As the desalination site, surrounding properties, Coastal Junction Pump Station and off-site water transmission pipeline routes are developed within urbanized areas, they are not viable for agricultural uses and do not contain any significant natural features which should be preserved for public recreation or open space purposes. Nor do they contain any important natural resources which should either be conserved or reserved for other productive purposes or contain any features of significant cultural or historical value. The off-site OC-44 underground pump station, however,would be situated within an Orange County Resource Preservation Easement. The site is currently undeveloped and is inhabited by dense native vegetation. However,the pump station would be placed entirely underground and would be subject to development restrictions protecting the integrity of on-site biological resources. Any displaced vegetation would be replaced following the completion of construction. Determining whether the proposed project may result in significant irreversible environmental changes requires a determination of whether key resources would be degraded or destroyed such that there would be little possibility of restoring them. No such degradation or destruction of resources is anticipated as a result of the proposed project. While the project would represent a long-term commitment of the desalination project site and associated off-site components to the proposed desalination uses,such uses are consistent with applicable goals and policies of the City's General Plan, and would enhance City and regional water resources while facilitating their management. There are no identified important or sensitive natural resources that exist at the site. Further, no important natural resources would be lost as a result of project implementation. The local marine environment surrounding the Huntington Beach Generating Station(HBGS)outfall may experience long-term changes in regards to increased salinity due to the proposed plant's concentrated seawater discharge, but impacts to biological resources as a result of these changes are not anticipated to be significant. Various natural resources,in the form of construction materials and energy resources,would be used in the construction of the project, but their use is not expected to result in significant long-term shortfalls in the availability of these resources. Energy consumed by City of Huntington Beach April 5, 2005 6-1 Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report the project is not likely to contribute to intermittent statewide energy shortfalls because operations of the facility can be curtailed during incidents of peak electric grid overload. Proposed consumption of energy is not considered wasteful. Based on the foregoing, the project presents no possibility of significant irreversible environmental changes. 6.2 GROWTH-INDUCING IMPACTS OF THE PROPOSED ACTION This section discusses the ways in which the Seawater Desalination Project at Huntington Beach could foster economic or population growth,or the construction of additional housing,either directly or indirectly, in Orange County. CEQA REQUIREMENTS FOR GROWTH INDUCEMENT ANALYSIS The California Environmental Quality Act(CEQA)requires that an environmental impact report shall include a detailed statement setting forth "the growth-inducing impact of the proposed project." [Public Resources Code Section 21100 (b)(5).] The CEQA Guidelines provide the following direction for the required discussion. "Discuss the ways in which the proposed project could foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment."[CEQA Guidelines Section 15126.2(d).] Identification of the"surrounding environment'in which this project may foster growth is obviously a key factor in the analysis. The"surrounding environment'or"service area"for the proposed project has been identified as Orange County. Development of raw, natural land for new homes, industry or a commercial center is a clear example of directly converting the natural environment for use by man, and such projects are considered to be directly "growth inducing." Projects that are directly growth inducing convert the natural environment and develop structures and other physical features forthe purposes of providing places to live,work,shop, recreate and grow food for an expanding population within an area. Examples of projects that are directly growth inducing include projects that convert agricultural land to rural or urban development, and projects that replace existing rural, suburban, or urban development with uses that significantly increase the level of human activity in a given area. The CEQA Guidelines and controlling CEQA case law indicate that infrastructure projects (like the proposed project) are different. Infrastructure projects may have characteristics "which would remove obstacles to population growth"or"which may encourage and facilitate other activities that could significantly affect the environment, either individually or cumulatively." [CEQA Guidelines Section 15126.2(d).] In the specific example cited by the CEQA Guidelines,"a major expansion of a waste water treatment plant might ... allow for more construction in service areas." Infrastructure projects (like the proposed project) may be found to be indirectly"growth inducing." California courts have recognized that there is a different potential for indirect growth-inducement when the"sole reason to construct'an infrastructure improvement project"is to provide a catalyst for further development in the immediate area" (City of Antioch v. City Council of the City of Pittsburg [1986]) as compared to the analysis required for a project "designed to accommodate a development whose growth-inducing impact had already been addressed" (Merz v. Monterey County Board of Supervisors [1983]). Accordingly, this section examines the extent to which the proposed project would provide a catalyst for further development in Orange County as compared to the extent to which the proposed project has been designed to accommodate existing demand and planned development. City of Huntington Beach April 5, 2005 6-2 Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report Finally, the CEQA Guidelines admonish that "it must not be assumed that growth in any area is necessarily beneficial, detrimental, or of little significance to the environment." (CEQA Guidelines Section 15126.2[d]). Therefore,the analysis in this section endeavors to present factual information without engaging in such assumptions. DEFINITION OF GROWTH "Growth" is measured in terms of increases in the numbers of houses, residents, employees, businesses, and other quantifiable units within a particular area. Resulting growth statistics are 1 readily available from various sources, such as the U.S Census Bureau, State Department of Finance, and regional and local governments. Population growth has two basic causes: 1)the net difference between birth and death rates in a given area(natural increase);and 2)the net effect of in-and out-migration within an area. Birth and death rates are relatively uniform across the U.S., although there is the potential for aberrations in the local birth and death rate based on the specific environmental and social characteristics of a given area. Migration is directly related to growth catalysts or constraints,which are the result of the natural environmental conditions of a given area (e.g., its beauty and climate), as well as the man- made and social features of the community(e.g.,strength of the local employment base,desirability of living conditions,quality of schools,community amenities,and other quality of life issues). In this case, CEQA requires a discussion of the ways in which a proposed project could be a catalyst for migration into the environment surrounding that project. Growth Catalysts and Constraints Catalysts and constraints to growth can effect: 1)whether or not growth occurs in a given area:and 2)the rate at which growth occurs. Even if there is latent growth potential in a given area,the area may not experience any growth, other than natural population increase, because of specific constraints. Such constraints could be temporary and easily removed,such as a short-term lack of sewage treatment capacity,or long-term in nature and difficult to address,such as high air pollution levels in an air basin that discourage in-migration. Generally, naturally occurring growth catalysts/constraints(such as natural topography, location of rivers, lakes, steep slopes, fault zones, sensitive habitats) are fairly straightforward and easy to define. Man-made catalysts and constraints typically are a consequence of a combination of economic forces (job availability, pay scales, housing costs, development incentives) and infrastructure provision (roadways,public utilities,public services)that combine in a way that makes an area appear more, or less, attractive than another area. In some cases, manmade factors may interact with the natural environment to create growth catalysts(e.g.,the design of new development within a desirable natural setting) or constraints (e.g., air pollution combined with a poor climate) affecting decisions to migrate to an area. This relative attractiveness of the combined natural and man-made environment on the local, regional, state, or national level influences population growth. Areas that have healthy environmental factors, strong growth catalysts, and minimal or resolvable constraints would experience growth in the form of net-in-migration. GOVERNMENT'S ROLE REGARDING GROWTH Government is the vehicle through which many growth catalysts and constraints are created, increased, decreased, or removed. Local cities and counties primarily play this role, although service and utility agencies are also involved. The relationship between an area's growth catalysts, constraints, and government policy actions also facilitates or hinders growth. City of Huntington Beach April 5, 2005 6-3 Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report Cities and Counties In California, all cities and counties are required to prepare and maintain, "a comprehensive, long- term general plan for the physical development of the county or city, and of any land outside its boundaries which in the planning agency's judgment bears relation to its planning" (California Government Code Section 65300). Under State law, it is the responsibility of cities and counties to define the availability of land for future development in terms of the permitted location and intensity of residential, commercial, industrial, institutional, recreational, and other types of development. State requirements for the preparation and content of General Plans,as well as CEQA requirements for their review, are intended to ensure that a city's or county's land use plans are consistent with their circulation plans;are consistent with the agencies'plans for environmental management,public safety,and provision of housing for all economic segments of the community;and are supported by adequate public services and facilities. Overall, city and county General Plans establish the governmental policies as to how growth catalysts and constraints are managed within each community. A city or county, therefore, manages growth by affecting, influencing, and controlling growth catalysts and growth constraints. Through implementation of general plan policies and related implementation strategies, growth catalysts are either expanded or contracted. This affect can result in many outcomes,such as high rates of growth resulting from implementation of aggressive development plans, or conversely, low to no growth resulting from implementation of slow-growth development plans. Similarly, growth can be managed by either removing or leaving in place constraints to growth. For example,a completely built-out city that includes mountainous terrain can remove a growth constraint by enacting policies that allow development of hillsides previously prohibited from development,or it can choose to keep the existing hillside development prohibition in place, thereby maintaining the growth constraint. Service and Utility Agencies In California, public service and utility agencies function on a"would serve"basis,meaning that they are responsible for providing services and utilities to accommodate growth that is planned to occur in their service area. In providing these services and utilities, these agencies are responding to growth pressures that are ultimately managed, or controlled, by the cities and counties in their service area. Water purveyors in urban areas, for example, are required by law to prepare and adopt Urban Water Management Plans (UWMPs), with 20-year planning horizons, in order to demonstrate how they would accommodate the water service demands in their service area. These UW MPs must be updated every five years and are required to estimate water supply needs for their service area in normal, dry and drought years. Some see service and utility agencies as playing a dual role, by both accommodating growth as well as removing constraints to growth that results in the creation of a growth catalyst. Using the example of a capacity increase at a wastewater treatment plant, service agencies can create a growth catalyst that meets demand for growth coming from a particular city. Without the wastewater treatment plant capacity increase,a constraint to growth would remain. While the provision of these services and utilities can function as a catalyst to growth or the lack of providing them can function as a constraint to growth, the demand for growth is generally dictated by the planning activities of cities and counties in their service area. Special Legislative Requirements for New Developments The California State Legislature recognized the correlation between development and water supply when it passed new water supply laws, SB 610 and SB 221 in the 2001 legislative session.The bills require that cities and counties consult with the water agency serving a new development project of City of Huntington Beach April 5, 2005 6-4 Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report over 500 dwelling units(or similar large projects)to determine whether water supplies are sufficient to serve the project prior to approval. In addressing water supply availability for new development projects, SB 610 augments the CEQA process to definitively establish water availability. SB 610 requires that the public water supplier must prepare a "water supply assessment"that contains the following: ❖ Identification of existing and anticipated water supply entitlements, water rights, and water service contracts and a historical description of the quantities of water received by the public water supplier in prior years. ❖ Identification of the source of supply for the new development project and, if it is a new source,other competing purveyors that may receive water from the new source must also be identified. ❖ If the identified water supply includes groundwater, additional factors such as groundwater characteristics and sufficiency of the supply must be disclosed to establish proper use of the resource. The public water supplier's UWMP is the main planning tool used in preparing a water supply assessment for new development projects. If the demands expected from the new development are already accounted for in the UWMP, the UWMP may be used - in whole or in part - to establish supply availability under normal and drought conditions. If the water demands for a new project are not already accounted for in the Plan, SB 221 requires the public water supplier to provide"written verification" of"sufficient water supplies" for the new project as well as proof of the availability of water supply. In most cases,the water supply assessment prepared under SB 610 would meet the additional requirements of SB 221. Desalination Task Force Recommendations Assembly Bill 2717 (Hertzberg, Chapter 957, Statutes of 2002)called for the Department of Water Resources (DWR)to establish a Desalination Task Force("Task Force")to look into, among other things, potential opportunities for desalination of seawater in California. The Task Force completed its mission in October 2003, after six months of deliberations. DWR prepared recommendations with significant input from Task Force members. Direction on the evaluation of growth related impacts were included among those recommendations. DWR recommends that seawater 1 desalination projects be evaluated: "based upon adopted community General Plans, Urban Water Management Plans, Local Coastal Plans, and other approved plans that integrate regional planning, growth and water supply/demand projections. Environmental reviews should ensure that growth related impacts of desalination projects are properly evaluated." ORANGE COUNTY GROWTH PROJECTIONS The Center for Demographic Research (CDR)at the California State University,Fullerton,prepares biennial socioeconomic growth projections for Orange County. The Orange County Projections 2002 (OCP-2002) were adopted by the Orange County Council of Governments (OCCOG) in December 2002 and are the most recent projections. OCP-2002, as prepared by CDR, provides information on growth in population, employment, and housing between the years 2000 and 2030. According to the OCP-2002,from 2000 to 2030 Orange ' County is expected to experience a 26 percent increase in population (735,764 additional people) and a 37 percent increase in the number of jobs (564,390 additional jobs), but only a 15 percent City of Huntington Beach April 5, 2005 6-5 Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report increase in the number of dwelling units(145,090 additional dwelling units). Based on the projected increase in population compared to the flatter growth in the number of housing units projected, densities in Orange County are anticipated to intensify. The projections are shown in Table 6-1, ORANGE COUNTY PROJECTIONS: 2000-2030. Table 6-1 ORANGE COUNTY PROJECTIONS: 2000-2030 2000 2010 2020 2030 Population 2,866,312 3,289,360 3,523,736 3,602,076 Employment 1,514,611 1,820,814 1,984,051 2,079,001 Housing 973,339 1,066,476 1,100,848 1,118,429 Source: http://www.octa.net/programs/directions/2.1%20Growth%2OProjections.pdf Population According to the CDR,the population of Orange County was 2,866,312 as of January 1,2000. The CDR estimates an increase in Orange County's population to 3,289,360,360 in the year 2010,and to 3,523,736 in the year 2020. The projected population in 2030 is 3,602,076. Employment The proposed project site is currently occupied with several fuel storage tanks. The existing facility does not require the employment of any personnel.. Implementation of the Seawater Desalination Project at Huntington Beach would generate minor short-term and nominal long-term employment within the City of Huntington Beach. The proposed plant would employ a total of 18 people,with five to seven people working on-site Monday through Friday and a minimum of two people on duty during swing shifts,graveyard shifts,and weekends. Project implementation would not appreciably affect the CDR projected employment figure of 1,820,814 jobs in the year 2010 for Orange County. Housing The Seawater Desalination Project at Huntington Beach would occur within an industrial area and would not directly involve the construction of any new housing or the relocation of any existing housing in the City. However, as an infrastructure improvement project that would provide a new source of potable water supply(desalinated seawater)for Orange County,the Project's potential to indirectly foster the construction of new housing must be analyzed County-wide. The "Growth Assessment and General Plan Evaluation for Anticipated Infill and New Residential Development in Orange County, California,"prepared by LSA Associates, Inc.,in October 2004(the "Growth Assessment and General Plan Evaluation")has been attached to this EIR as Appendix P, GROWTH ASSESSMENT AND GENERAL PLAN EVALUATION. The Growth Assessment and General Plan Evaluation utilizes several complimentary approaches to determine the planned build- out of dwelling units in Orange County, analyzing the housing elements and related elements from the general plans of all jurisdictions in the County as well as analyzing CDR projections for each of the ten regional statistical areas(RSAs)for the County. The Growth Assessment and General Plan Evaluation also specifically reviews twelve proposed new residential development projects of over 500 dwelling units in the County. The Growth Assessment and General Plan Evaluation analyzed the housing elements and related elements from the general plans of all jurisdictions in the County. After compiling information from 34 cities and the unincorporated territory in the County,the Growth Assessment and General Plan City of Huntington Beach April 5, 2005 6-6 Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report Evaluation identified that a total of 970,296 dwelling units are projected for final build-out of Orange County(refer to Table 6-2, GENERAL PLAN HOUSING ELEMENT SUMMARY). Without relying on 1 additional updated information, the general plan review would provide an out-of-date projection of the total dwelling units to be built in Orange County. In fact,when the total number of dwelling units estimated for build-out in the general plan for each jurisdiction is added together (970,296), the resulting number is less than the total number of existing dwelling units in the County in 2000 ' (973,339 - refer to Table 6-1). One reason for the lower overall build-out estimates is that the general plans were written as independent governing documents for each jurisdiction. In addition, as shown on Table 6-2, the general plans were written in different years. Table 6-2 GENERAL PLAN HOUSING ELEMENT SUMMARY -M s Total RemaII Housing Total2004 CaII forma Units to Be Built pnorto 1 Housings Department of Build out of Jurisdiction ;Year of Estimates Financo per;Genera[Plan :n , .Generale at,Build-out Existing Estimates and Cahforni ':: General �:. Plan` ` , per General �.Housmg Department of,Finance ` .� .Jurisdiction � �`�"=Plan Element ' ;Element �� � ��"�Plan � _ � ���stimates �'' '� "-`Estimates Community Aliso Viejo Profile 2004 20,112 17,968 2,144 Land Use 129,159(per Anaheim Element 2004 City Planner) 101,527 27,632 Brea Housing Element 2002 15,802 14,292 1,510 Buena Park Housing Element 2001 24,285 23,848 437 Costa Mesa Housing Element 2000 43,122 40,947 2,175 Cypress Housing Element 2001 17,022 16,381 641 Dana Point Housing Element 2000 16,564 15,880 684 Fountain Valley Housing Element 2000 19,290 18,482 808 Fullerton Housing Element 2001 55,831 46,296 9,535 Garden Grove Housing Element 2000 48,299 47,069 1,230 Huntington Beach Housing Element 2000 79,514 77,221 2,293 Irvine Housing Element 2003 61,255 63,014 -1,759 Laguna Beach Housing Element 2001 13,083 13,174 -91 General Plan La una Hills Appendix A 2001 11,425 11,108 317 Laguna Niguel Housing Element 2000 24,947 24,664 283 Laguna Woods Housing Element 1 2003 13,395 13,629 -234 City of Huntington Beach April 5, 2005 6-7 Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report Total 004 Calif Remaining Housing `: Total;. 2ornia.,?r Units to Be Built priorto,,- Hod sing . Department of Build=out,ofJurisdicton, Yearof 'Estim finance Plan General at Build•out � Existing `"Estimates and California' General Plan' per General, Housing, Department of Finance Jurisdiction Plan Element Element Plan m Estimates - Estimates Lake Forest Housing Element 2000 21,428 26,385 -4,957 La Habra Housing Element 2003 19,271 19,719 448 La Palma Housing Element 2002 5,037 5,131 -94 Los Alamitos Housing Element 2001 4,578 4,362 216 Mission Viejo Housing Element 2000 34,465 33,714 751 Newport Beach Housing Element 2003 39,249 41,851 -2,602 Orange Housing Element 2001 45,846 43,372 2,474 Placentia Housing Element 2002 16,162 16,010 152 Rancho Santa Margarita Housing Element 2002 17,170 16,684 486 San Clemente Housing Element 2000 25,481 25,414 67 San Juan Capistrano Housing Element 1997 Unknown 11,676 Unknown Santa Ana Housing Element 2000 76,891 75,006 1,885 - Seal Beach Housing Element 1990 14,334 14,347 13 Stanton Housing Element 2001 11,726 11,065 661 Tustin Housing Element 2001 24,121 25,850 -1,729 Villa Park Housing Element 2001 4,081 2,020 4,068 Westminster Housing Element 2001 28,202 27,185 1,017 Yorba Linda Housing Element 2002 23,526 20,681 2,845 Unincorporated Orange County Housing Element 2001 94,782 37,957 Unknown Subtotal 970,296 1,003,929 64,324 Note:All housing estimates include proposed infill development.All negative totals(noted in parentheses)are counted as zero and not subtracted from the total. Source: Growth Assessment and General Plan Evaluation for Anticipated Infill and Planned Development in Orange County, California,August 2004. City of Huntington Beach April 5, 2005 6-8 ' Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report To provide updated information, the Growth Assessment and General Plan Evaluation compared the 2004 California Department of Finance (DOF) existing housing estimates to the general plan estimates on a jurisdiction-by-jurisdiction basis. As shown in Table 6-2, the build-out estimate for most jurisdictions continues to be up to date. However, in the Cities of Irvine, Laguna Beach, Laguna Woods, Lake Forest, La Habra, La Palma, Newport Beach, and Tustin, the general plan build-out estimates are out of date and have already been surpassed,when compared with the 2004 DOF existing housing estimates. When the 2004 DOF existing housing estimates are subtracted from the build-out estimates in the general plans on a jurisdiction-by-jurisdiction basis (ignoring the jurisdictions where the estimates have already been surpassed), the result is that an estimated 64,324 dwelling units remain to be built in Orange County. This number still seems low because, as indicated in Table 6-1, CDR projects that the total dwelling unit growth from 2000-2030 for Orange County is anticipated to be 145,090 dwelling units. In addition, the general plan total does not include any potential units that may be built in Irvine, Laguna Beach, Laguna Woods, Lake Forest, La Habra, La Palma, Newport ' Beach, Tustin, or unincorporated County. The CDR projection is likely a more accurate estimate of the future number of dwelling units to be built in Orange County. Under direction from the County Board of Supervisors, ten regional statistical areas (RSAs)for the County were established in 1977. CDR currently manages growth forecasting and projections for the ten RSAs. In its most recent analysis, OCP-2002, CDR found that 65,438 dwelling units(approximately 45 percent)are anticipated to be built in infill areas of the County and that seven of the ten RSAs are projected to have more infill development than new development. The percentage of infill development by RSA is shown in Exhibit 6-1, INFILL PERCENTAGES BY REGIONAL STATISTICAL AREAS. iIn contrast, almost all of the anticipated new development in Orange County would occur in three RSAs: B-41 (11,219 DU), C 43 (33,398 DU)and E-44 (24,836 DU). Of the 79,652 projected new units to be built from 2000 to 2030,69,453—87 %of the total-would be built in those three RSAs. RSA B-41 includes the Anaheim Hills and East Orange areas,while RSAs C-43 and E-44 include most of the inland (non-coastal)portions of Irvine and South Orange County. Several large tracts of vacant land remain in those areas. It is not surprising,therefore,that those are the areas where the majority of the County's proposed new residential development projects with over 500 dwelling units are located (refer to Table 6-3,PROPOSED NEW RESIDENTIAL DEVELOPMENT PROJECTS/N ORANGE COUNTY(OVER 500 DWELLING UNITS). ORANGE COUNTY WATER CONSUMPTION PROJECTIONS To determine whether the Seawater Desalination Project at Huntington Beach may be growth- inducing, projections regarding water consumption habits in Orange County must be understood in addition to the projections for growth in population, employment and housing. The Desalination Task Force recommends a review of applicable Urban Water Management Plans and "other approved plans that integrate regional planning, growth and water supply/demand projections." Three plans provide relevant information: the California Water Plan prepared by the Department of Water Resources (DWR), the 2003 Integrated Resource Plan (IRP) Update prepared by the Metropolitan Water District(MWD)and the 2000 Urban Water Management Plan prepared by the Municipal Water District of Orange County(MWDOC). Each plan includes seawater desalination as a projected future supply. City of Huntington Beach April 5, 2005 6-9 Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report Table 6-3 PROPOSED NEW RESIDENTIAL DEVELOPMENT PROJECTS IN ORANGE COUNTY (OVER 500 DWELLING UNITS) Project Proposed New Residential Land Use Water RSA Water Supplier; Supply # Development Projects VDUs_ Jurisdiction �� �sldentified Unincorporated Southern 1 Tonner Hills 810 B-41 County California Water Yes Company 2 West Coyote Hills 760 A-36 Fullerton City of Fullerton Yes B-41, Irvine Ranch 3 Del Rio 716 G 42 Orange Water District Unknown IRWD 4 Mountain Park 2,500 B-41 Anaheim City of Anaheim Unknown 5 East Orange-Santiago Hills II 4,096 E-44 Orange IRWD Yes 6 Planning Areas 1 and 2 4,310 E-44 Irvine IRWD Unknown 7 North Irvine Sphere 12,350 E-44 Irvine IRWD Yes 8 Great Park 8,550 E-44 Irvine IRWD Yes 9 Tustin Base 4,601 E-44 Tustin City of Tustin/ Unknown IRWD 10 UCI 850 F-39 UC Regents IRWD Unknown Northeast Future Planned Rancho Santa Trabuco 11 Community Area 618 C-43 Margarita Canyon Water Yes District 12 Rancho Mission Viejo 14,000 C-43 Unincorporated Santa Margarita Yes Ranch Plan County Water District - None - D-40 - - - - None - H-37 - - - - None - 1-38 - - - - None - J-35 - - - Total 54,161 DUs Note: The recently approved Pacific City project that include over 500 dwelling units in the City of Huntington Beach is considered an infill project in the LSA Study and therefore,is not included in the above table. Source: Growth Assessment and General Plan Evaluation for Anticipated Infill and Planned Development in Orange County, California,August 2004. The latest draft of the California Water Plan (the Draft 2004 Plan),projects that a combination of six new seawater desalination facilities would provide up to 187,100 acre feet of California's urban water supply by 2030. The same number (rounded to 200,000 acre feet) is listed as the target amount to be produced by seawater desalination,one of the 25"Resource Management Strategies" featured in the 2004 Water Plan Update's"Strategy Investment Options Table"to address state and local water supply concerns.' In Southern California, the 2003 IRP Update includes a revised local resources target that can accommodate a seawater desalination goal of 150,000 acre-feet. To that end, MWD's current Seawater Desalination Program includes five proposed projects that collectively could produce about 132,000 acre-feet per year. The 56,000 acre-foot per year Seawater Desalination Project at ' Draft 2004 California Water Plan,Volume 1,Findings and Recommended Actions. City of Huntington Beach April 5, 2005 6-10 P �t�ira •. San:Bernardino" A-36 r 6�1 County EMS. • .•:. Los Angeles -Countyi G ''r 100P/o " A Riverside. • G-42 E..44 - County: Legend Infill Percentage* Highways �. ° e' �� • C- Q O% - 9% D40 Regional Statistical ® I C418°f. Areas(RSA) 0 IO% - t9% 20% - 29% U�0 0 30% - 39% .l' qo% - 49% RM 50% - 59% l' ® 60%- 69% 70% - 79% Sari,Diego, FMM 80%- 89% County g0%— I00% Source:LSA,November 2004. Infill is cels that contain existing development,which is removed in favor of new development of a higher intensity or density. NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH . . . Infill Percentages by Regional Statistical Areas CONSULTING 02/05•JN 10-101409.002 Exhibit 6-1 ' Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report Huntington Beach is independent from MWD's Seawater Desalination Program, but would still be considered an Orange County local project for purposes of the 2003 IRP Update. The information in the 2000 UWMP is in the process of being updated by MWDOC to reflect MWD's 2003 IRP Update assumptions (a revised UWMP must be adopted by MWDOC in 2005.) In completing the IRP Update, MWD included two specific assumptions for Orange County: 1) an increase in conservation from 84,000 acre-feet in 2005 to 148,000 acre-feet in 2025; and 2) an increase in local project supplies from 350,000 acre-feet in 2005 to 512,000 acre-feet in 2025.2 The conservation assumptions in the 2003 IRP Update are more aggressive than those projected in MWDOC's 2000 UWMP. The 2000 UWMP indicates total conservation of 32,000 acre-feet in 2000 and projects only 57,000 acre-feet for 2005. The 2020 projection of 99,000 acre-feet in the 2000 UWMP is 49,000 acre-feet short of the 2003 IRP Update assumption. In addition,the assumption that Orange County can increase local supplies to 512,000 acre-feet is dependent on continued significant groundwater production. According to MWDOC, a "lower groundwater production" ' scenario could leave Orange County up to 52,000 acre-feet short of the 512,000 acre-foot local project goal in 2025 even assuming that all existing and planned recycling projects(including Phase I of the Orange County Water District's Groundwater Replenishment System)were fully operational (April 22,2004 presentation by MWDOC:"Orange County's Partin the IRP"). Seawater desalination ' is identified in the MW DOC's 2000 UWMP as a planned for future water supply,and it continues to be one of several methods recommended by MWDOC to close the potential gap between future supply and demand. All planned new development projects of 500 dwelling units or more that are approved or anticipated for Orange County are required by law to identify(and verify)the water sources available to serve ' those projects. None of the twelve planned new residential development projects of 500 dwelling units or more that were identified in the Growth Assessment and General Plan Evaluation have identified the Seawater Desalination Project at Huntington Beach as a source of water supply. Seven of the listed projects have identified water sources that are independent of the Seawater Desalination Project at Huntington Beach and the other five projects are not far enough along in the planning process to have identified a source of water supply (refer to Table 6-3). Three specific south Orange County projects (which are below the 500 dwelling unit threshold requiring a water supply assessment)are of note due to comments and references made during public review of the previously circulated EIR. These three projects are the Saddleback Meadows, Saddle Creek and Saddle Crest developments, with 299, 127 and 35 single-family residential lots proposed, respectively. All of these projects are within the water service area of the Trabuco Canyon Water District(TCWD). The EIR prepared for the Saddleback Meadows development stated that TCWD would be able to accommodate the required water supply demand of the proposed project with existing District water resources. TCWD also indicated that existing district water resources are adequate to serve projected water demands of the Saddle Creek and Saddle Crest developments. Because irrigation demands represent over one-half of these developments'total water demand,the developers, with assistance from TCWD, are investigating the availability and feasibility of developing a groundwater source for separate irrigation systems. POTENTIAL PROJECT-RELATED GROWTH-INDUCING IMPACTS The Seawater Desalination Project at Huntington Beach would provide a new source of potable water supply(desalinated seawater) producing 50 million gallons per day ("mgd")or 56,000 acre- feet per year of potable water for ultimate use within Orange County. However, as described in Section 3.0, PROJECT DESCRIPTION, the desalinated seawater would not be made directly available to end users. Instead,the project requires that the desalinated seawater produced by the 2 Source:April 22,2004 presentation by MWDOC:"Orange County's Part in the IRP." City of Huntington Beach April 5, 2005 6-12 Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report n Seawater Desalination Project at Huntington Beach be delivered only to existing regional or local water purveyors in Orange County. Consequently,the growth-inducing impact of the project would depend entirely upon how those regional or local water purveyors allocate the desalinated seawater produced by the project. i Neither CEQA, nor the CEQA Guidelines provide a specific methodology for determining whether or not a project like the proposed project would have growth-inducing impacts. One methodology would be to assume a scenario in which all water produced by the Seawater Desalination Project at J Huntington Beach was directed by regional and local water purveyors entirely toward fostering unplanned growth in Orange County. If a 200-gallon per day per capita water use is assumed,the project could supply water to 250,000 additional people, or approximately eight percent more than Orange County's 3,000,000 current residents. When the County's population reaches approximately 3,500,000 residents in 2020 (refer to Table 6-1), the project would be able to serve approximately seven percent of that projected population. Allocating the project's water supply entirely toward fostering unplanned growth in Orange County is not realistic because existing water supply plans identify desalinated seawater as one of the additional water sources already counted upon to meet the future supply needs for projected population increases. The Growth Assessment and General Plan Evaluation documents that the potential water supply from the Seawater Desalination Project at Huntington Beach is not currently being relied upon to serve seven of the planned new development projects of 500 dwelling units or more that are proposed in Orange County,although it cannot be ruled out that the proposed project might not be a supply for one or more of the five residential projects that have not yet identified rl water sources. It is more likely that all or most of the water supply produced by the project would be allocated by Orange County water purveyors to meet the increased demand of infill development planned to occur throughout the County. I Under CEQA, growth inducement is not considered necessarily detrimental, beneficial, or of little significance to the environment. Typically, the growth-inducing potential of a project would be considered significant if it fosters growth or a concentration of population in excess of what is assumed in pertinent general plans,or in projections made by regional planning agencies. Even if the project were relied upon to serve a new development of 500 dwelling units or more, it would not foster growth in excess of that already assumed and projected in pertinent planning documents. As stated above, the proposed project may be identified in the future as a water supplier for a project listed in Table 6-3 whose water supplier is not currently known. In addition, as no water supply agreements have been executed with water agencies within Orange County, the precise locations/uses where desalinated water would be allocated are not known. As such, there is a potential for the project to induce growth in unidentified areas. All proposed projects and water sources would be subject to environmental analysis prior to approval. However,in consideration of population/housing projections within the County and the recognized need for seawater desalination as a supply source (within the California Water Plan, MWD 2000 IRP,and MWDOC 2000 UWMP), any impacts in regards to growth inducement would be less than significant. 6.3 CUMULATIVE IMPACTS r This section has been included in the EIR to address the cumulative impacts associated with the proposed desalination project. In accordance with CEQA Guidelines §15130,an EIR shall address cumulative impacts of a project when the project's incremental cumulative effect is considerable,as defined in Section 15065(c). The discussion of cumulative impacts shall reflect the severity of the impacts and their likelihood of occurrence, but the discussion need not provide as much detail as is provided for the effects attributable to the project alone. The EIR need not address cumulative impacts for which the project does not contribute. The discussion should be guided by the City of Huntington Beach April 5, 2005 6-13 Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report standards of practicality and reasonableness. The following elements are necessary for an adequate discussion of cumulative impacts. 1. Either: ❖ A list of relevant past, present and probable future projects producing related or ' cumulative impacts including, if necessary, those projects outside the control of the agency, or ❖ A summary of projections contained in an adopted general plan or related planning document, or in a prior environmental document which has been adopted or certified, which described or evaluated regional or area-wide conditions contributing to the cumulative impact. 2. A summary of the expected environmental effects to be produced by those projects with specific reference to additional information stating where that information is available, and 3. A reasonable analysis of the cumulative impacts of the relevant projects. An EIR shall examine reasonable, feasible options for mitigating or avoiding the project's contribution to any significant cumulative effects. Additionally, the Coastal Act includes several policies requiring the evaluation of a proposed development's cumulative effects, including Section 30250(a), which states in part: ' "New residential, commercial, orindustrial development,except as otherwise provided in this division, shall be located...where it would not have significant adverse effects, either individually or cumulatively, on coastal resources." The Coastal Act defines "cumulative effects" in Section 30105.5 as: ' "Cumulatively"or"cumulative effects"means the incremental effects of an individual project shall be reviewed in conjunction with the effects of past projects, the effects of other current projects, and the effects of probable future projects." GEOGRAPHIC SCOPE OF CUMULATIVE IMPACT ASSESSMENT The geographic area for each impact varies, depending on the nature of the impact, whether it is regional, such as growth-inducement, or local such as noise. Thus,this EIR evaluates cumulative impacts on both a local and regional level. First,the"local"analysis focuses primarily on cumulative impacts that may result with implementation of the proposed desalination facility along with other proposed projects within the City of Huntington Beach. Second,the"regional"analysis focuses on cumulative impacts as a result of implementation of the proposed desalination facility along with other proposed desalination facilities, as well as other existing and proposed developments,along the Southern California coast. The"regional"cumulative impact analysis includes an evaluation of impacts to marine biology/water quality within the Southern California Bight, growth-inducement potential and power production. ' CUMULATIVE IMPACT METHODOLOGY Local Cumulative Impact Analysis The local cumulative impact discussion is based primarily on build-out of the City's General Plan, Zoning and Subdivision Ordinance, and General Plan EIR. These documents are contained in ' Section 2.7, INCORPORATION BY REFERENCE. The cumulative projects identified represent the currently known probable projects at the time of Draft EIR publication. 1 City of Huntington Beach April 5, 2005 6-14 Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report Cumulative impacts may be discussed in terms of project impacts, in combination with impacts anticipated for future development(including approved and planned development within the project area and surrounding affected area). Quantification is difficult for cumulative impacts,as it would require speculative estimates of impacts including, but not limited to, the following: the geographic diversity of impacts (impacts of future r development may affect different areas);variations in time of impacts (many project impacts would occur at different times,and would be reduced or removed before other impacts occurred);complete data are not available for all future development; and data for future development may change following subsequent approvals. However,every attempt has been made here to make a qualitative judgment of the combined effect of, and relationship between, cumulative projects. j CEQA notes that the discussion of cumulative impacts should be guided by standards of practicality and reasonableness (Guidelines, Section 15130 (b)). Only those impacts that might compound or interrelate with those of the project at hand require evaluation. Potential cumulative impacts of the proposed project, in combination with cumulative development projects, are discussed below. , Precise impacts of future development have been or would be discussed in appropriate environmental documentation (depending on what state of approval the project is in). Local Cumulative Proiects In addition to incorporating by reference the cumulative impact discussion from the City of Huntington Beach General Plan EIR, this EIR has provided the following list of specific cumulative projects to ensure an adequate assessment: The following proposed projects are located within one mile of the subject site: ❖ Southeast Water Reservoir (five-acre site north of the AES plant for a water reservoir to serve the southeast portion of the City, and would include a 10 million gallon tank, approximately 30 to 35 feet high and 225 feet in diameter, along with associated booster pump station). ❖ Waterfront Residential Development (184-unit residential development located at Beach Boulevard and Pacific Coast Highway,adjacent to the Ocean Grand Resort project). Project currently under construction as of February 2005. r" ❖ Magnolia Pacific Specific Plan,a.k.a.Ascon/Nesi Landfill(specific plan allowing 502 dwelling units on 40 acres located on southwest corner of Hamilton Avenue and Magnolia Street). ❖ Orange Coast River Park(passive park in the planning stages which extends east from the HBGS through Costa Mesa and Newport Beach) ❖ CENCO Residential(approximately 204 unit residential development on 25 acres located at 21471 Newland Street). ❖ Huntington Beach Wetlands Conservancy Restoration Plan (restoration of degraded wetlands situated southeast of the project site along the inland side of Pacific Coast Highway, from the HBGS east to Brookhurst Street). ❖ South Beach Phase II (renovation of existing beach parking facilities, restrooms, and lifeguard quarters). Project currently under construction as of February 2005. The following proposed projects are located more than one mile from the project area: ❖ Pacific City (31 acre mixed use project located along PCH between Huntington and 1st Street). City of Huntington Beach April 5, 2005 6-15 Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report The Strand (149 room hotel plus 135,000 s.f.of retail, restaurant,and entertainment located at Main Street and Pacific Coast Highway). ❖ Target Reconstruction (Demolition of existing 131,900 s.f. Target and garden center and construction of a 129,356 s.f. Target and garden center at southwest corner of Brookhurst Street and Adams Avenue). ' ❖ Home Depot (demolition of former 126,000 s.f. K-Mart and miscellaneous retail and construction of 139,000 s.f. Home Depot located at 19101 Magnolia Street). Land Use/Relevant Planning The proposed project is not considered to represent a significant cumulative land use or relevant planning impact, as the project is consistent with the City of Huntington Beach General Plan. Mitigation of cumulative land use impacts is best accomplished by area-wide mitigation programs, conforming to the adopted zoning,General Plan designations and zoning,and implementing project- specific mitigation measures where appropriate. Geology and Soils Cumulative effects related to earth resources resulting from the proposed project and development in the vicinity of the proposed project include short-term increases in erosion due to excavation, backfilling and grading activities. These impacts are anticipated to be mitigated by enforcing proper 1 erosion protection measures during remediation and construction of the proposed project, and would be mitigated on a project-by-project basis. In addition, sites with unsuitable development conditions such as liquefaction and seismic hazards are best mitigated on an individual basis. The proposed project would comply with the Uniform Building Code (UBC) and all erosion control measures established by the City. The proposed project is not anticipated to negatively add to the cumulative impacts of the area with regards to geology and soils. Hydrology and Water Quality Cumulative impacts with regards to hydrology and water quality would primarily result from off-site ' runoff containing urban pollutants, as the majority of the project site would be composed of impervious surfaces. However, as previously stated, the proposed project would incorporate protection measures to avoid hydrology and water quality impacts during operation of the ' desalination facility. All site runoff would be directed to appropriate storm drains via an on-site local drainage system, ultimately being discharged into the Pacific Ocean via the HBGS outfall. In addition, impacts would be further minimized as the existing berm along the eastern perimeter of the project site (adjacent to the Huntington Beach Channel) would prevent runoff impacts to the adjacent wetlands to the southeast. The desalination facility's discharge into the Pacific Ocean is not considered a significant cumulative impact, as discussed in Section 5.3, HYDROLOGYAND ' WATER QUALITY. Air Quality As stated in Section 5.4,AIR QUALITY,the proposed project may result in increased off-site energy emissions due to the facility's proposed electrical consumption rate of between 720 to 840 megawatt hours per day. These emissions have been previously accounted for within environmental ' documentation prepared for the SCAQMD's New Source Review and Regional Clean Air Incentives Market (RECLAIM) programs. In addition, the proposed project would, in combination with other developments in the area, have cumulative indirect air quality impacts due to electricity and natural gas consumption. Cumulative air quality impacts are best mitigated by compliance with the City's General Plan to ensure jobs/housing balance consistencyto reduce total vehicle miles traveled,and ' City of Huntington Beach April 5, 2005 6-16 Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report 17 through compliance with applicable local, state, and federal emissions reduction measures for i mobile and stationary sources. Noise J Potential long-term noise associated with the proposed project would be generated by both mobile and stationary sources. Although long-term operational traffic noise generated by the proposed project is anticipated to be nominal, cumulative development of the project vicinity is anticipated to result in increases in noise levels within the City. The project's contribution to this increase, however, is considered negligible (see Section 5.5, NOISE), and has been previously analyzed within the City's General Plan and General Plan EIR. In addition, on-site stationary noise sources would be properly attenuated and are not expected to generate significant amounts of noise and would be consistent with City standards. Cumulative impacts in this regard are anticipated to be n less than significant. Public Services and Utilities , The proposed desalination facility may have impacts on wastewater facilities due to the potential discharge of byproduct wastes associated with plant operation utilizing Orange County Sanitation District facilities. However, the OCSD would require a commercial/industrial connection fee, of which five percent would go to the City of Huntington Beach. Impacts in this regard have been !i adequately analyzed in previous documentation, as the proposed project would be in compliance with all General Plan and Zoning designations. Cumulative impacts are not anticipated to be significant in this regard. Cumulative impacts are best addressed through implementation of citywide programs such as service connection and impact fees,energy conservation,and recycling programs. s n Aesthetics/Light and Glare Temporary construction impacts and facility operation would change the aesthetic character of the project site vicinity. The project site exists as a portion of former fuel storage facility,with storage tanks 40 feet in height. The proposed project is expected to improve the overall aesthetic character r-- of the site vicinity by replacing the storage tanks with multiple tilt-up buildings/structures. These structures would incorporate aesthetic enhancements (landscaping, screening, and aesthetically sensitive architecture) and are expected to enhance the overall aesthetic character of the site vicinity. In addition,the proposed desalination project may introduce new sources of lighting to the area. However,appropriate mitigation measures to prevent the occurrence of significant amounts of light spillover would be incorporated into site design. All structures associated with the proposed project would comply with City standards with regards to building height,densities,and landscaping. Therefore, the proposed project is not anticipated to be cumulatively significant with other projects within the City in this regard. Hazards and Hazardous Materials The proposed project has positive public health and safety effects due to remediation of the former fuel storage tank facility. On a cumulative basis, other project sites that are constrained due to site contamination would require remediation on a case-by-case basis, in accordance with applicable health and safety regulations. The proposed project may have local impacts in regards to hazards and hazardous materials through various chemicals associated with plant operation. However, all hazardous materials would be used, stored, and transported according to all Occupational Safety and Health Administration (OSHA) and Environmental Protection Agency (EPA) regulations. Impacts in this regard are not anticipated to be significant. City of Huntington Beach April 5, 2005 6-17 Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report ' Construction Related Impacts Potential construction-related impacts resulting from cumulative development in the project vicinity include those related to air, noise,geology and soils, hydrology and water quality,aesthetics/light& glare, hazards and hazardous materials, traffic and terrestrial biological resources (discussed in detail below) as a result of the cumulative projects listed above. A substantial amount of ' development is anticipated to occur within the vicinity of the subject site. It would be speculative to estimate or quantify anticipated impacts in this regard for cumulative development in the vicinity of the project site because approvals have not been granted for many of the projects and timing is ' unknown. However, it is expected that compliance with the City's standard construction requirements(such as air/noise control measures,aesthetic construction-screening requirements, hazardous materials safety measures/contingency plans,and traffic control plans)would minimize cumulative impacts to less than significant levels. In addition,all cumulative projects would undergo separate environmental review. ' Biological Resources (Terrestrial Only) Implementation of the proposed off-site OC-44 underground booster pump station may have impacts on biological resources, as the 0.5-acre site is overgrown with dense native vegetation known to support numerous species of wildlife. Pump station implementation may impact two special status habitats (riparian and coastal sage scrub)on-site and may adversely affect several federal-or state-listed species (coastal California gnatcatcher, least Bell's vireo,and western pond turtle) expected to occur within the immediate vicinity of the subject site. As the proposed underground pump station would include all necessary biological surveys and complywith standard regulations as required by the United States Fish and Wildlife Service (USFWS), United States Army Corps of Engineers(ACOE),and California Department of Fish and Game(CDFG),impacts to biological resources are not anticipated to be significant. It should also be noted that any displaced vegetation would be replaced following completion of construction. Regulatory compliance during ' project construction would ensure that project-related construction activities would minimize cumulative impacts to less than significant levels. In addition,all cumulative projects would undergo separate environmental review. Product Water Quality The product water from the seawater desalination facility would be suitable for delivery through the existing water distribution system and would be comparable and compatible to the other water sources currently delivering water to the same system (refer to Section 5.11, PRODUCT WATER QUALITY). Thus, cumulative impacts in this regard are anticipated to be less than significant. In addition, all cumulative projects would undergo separate environmental review. Regional Cumulative Impact Analysis As stated above, the "regional" analysis focuses on cumulative impacts as a result of implementation of the proposed desalination facility along with other proposed desalination facilities, as well as other existing and proposed developments, along the Southern California coast. Other developments along the coast include ports, industrial uses,wastewater treatment plants,etc,all of which could result in regional cumulative impacts (i.e., marine biology, growth-inducement and air quality from power production), including impacts to the Southern California Bight. For purposes of this analysis, a qualitative discussion of regional cumulative impacts is provided for existing and proposed developments along the coastline. Accordingly,it is not practical or reasonable to analyze all existing and proposed development along the coastline. Although a comprehensive list of ' regional projects that could result in cumulative impacts,especially to the Southern California Bight, is not provided, this analysis assumes that planned desalination facilities along the coastline ' City of Huntington Beach April 5, 2005 6-18 �1 Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report comprise a portion of the cumulative projects that would contribute to regional cumulative impacts. Thus, a listing of the planned desalination facilities is provided below. The "regional" cumulative impact analysis includes an evaluation of impacts regarding marine biology/water quality within the Southern California Bight, growth-inducement potential and power production. Regional Cumulative Projects ' I Projects that may result in regional cumulative impacts include existing and/or planned 1 developments along the California coast that could exceed planned growth estimates,contribute to impacts to the Southern California Bight, and/or result in substantial demands on local power sources, resulting in additional water or air pollution. The analysis of cumulative projects refers to the inclusion of all existing and planned developments along the coast, including ports,wastewater treatment plants, industrial uses, etc., as well as planned desalination facilities. Table 6-4, n PROPOSED DESALINATION FACILITIES ALONG THE SOUTHERN CALIFORNIA COAST, provides a list of planned desalination facilities along the Southern California coast. J i Table 6-4 PROPOSED DESALINATION FACILITIES ALONG THE SOUTHERN CALIFORNIA COAST Purpose,:,and Public or Maximum Operator/Locatiow" Status: Private: Capacity: City of San Buenaventura - Municipal/domestic Not known Not known Public G Long Beach - Research 300,000 gpd/ Design phase Public 335 AF/ r. Municipal/domestic 10 million gpd/ `- h Long Beach Planning - Public 11,000 AF/ r. Los Angeles Department of Water and - Municipal/domestic 10 million gpd/ Planning Power - Public 11,000 AF/ r Municipal Water District of Orange - Municipal/domestic 27 million gpd/ Planning County/Dana Point - Public 30,000 AF/ r. Poseidon Resources/Huntington - Various 50 million gpd/ Draft EIR under Beach - Private 55,000 AF/ r. review San Diego County Water Authority/San - Municipal/domestic TBD Planning Onofre Nuclear Generating Station - Public r- San Diego County Water - Municipal/domestic 50 million gpd/ Planning Authority/South County - Public 55,000 AF/ r. San Diego County Water Authority& - Municipal/domestic 50 million gpd/ Planning Poseidon Resources/Carlsbad - Public/private 55,000 AF/ r. U.S. Navy/San Diego - Municipal/domestic 20 million gpd/ Planning - Public 22,000 AF/ r. West Basin Municipal Water District - Municipal/domestic 20 million gpd/ Planning Public 22,000 AF/ r. Total Proposed Production: 240 million gallons per da /260,000 AF/ r. Growth-Inducing Impacts As discussed in Section 6.2, GROWTH INDUCING IMPACTS,the proposed projectwould notfoster r growth in excess of that already assumed and projected in pertinent planning documents. Moreover, existing water supply plans already project that seawater desalination would play a necessary role in meeting projected future demands. Accordingly,the growth-inducing impacts of the project are not significant. Each incremental development would be required to comply with the City of Huntington Beach April 5, 2005 6-19 ' Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report ' goals and policies of the applicable General Plan or other planning documents for the proposed project area. Thus, potential growth-inducing cumulative impacts are considered less than significant. Refer to Section 6.2 for further detail regarding growth-inducing impacts as a result of project implementation. Ocean Water Quality and Marine Biological Resources The Southern California Bight is a region that includes coastal southern California, the Channel Islands and the local portion of the Pacific Ocean. The small portion of the Pacific Ocean that occupies this region, from point Conception in the north to just past San Diego in the south, and extending offshore of San Nicolas Island, is the temporary or permanent home to a wide variety of marine organisms. Impacting this coastal marine ecosystem are the millions of people who reside in the Los Angeles and San Diego metropolitan areas, as well as the Mexican residents who inhabit the Tijuana/San ' Diego border region of the Bight. The tremendous population of southern California, coupled with the activities necessary to sustain and/or enhance their existence, results in a significant quantity and variety of pollutants that enter coastal waters. The Pacific Ocean within the Southern California Bight area receives pollutants from a wide variety of sources. Most pollution within the Bight is ' derived from land,either from water runoff after a rainfall event,from the outfall pipes of wastewater treatment plants or from the water discharges of electrical power plants. Such runoff can introduce a mix of industrial and organic pollutants to coastal waters. Additionally, substantial amounts of ' refuse also make its way into rivers or bays via roadway gutters. Harbor/port activities also contribute pollution to the Southern California Bight. Combined, the ports of Long Beach and Los Angeles compose one of the busiest port systems in the nation. Though stringent guidelines are in ' place to protect the coastal environment,pollution from ships,from the ports'terminals and from the Los Angeles River is an ongoing problem. Discharge from the ballast tanks of ships,though illegal, does occur. Such vessels, arriving from distant ports of call, can introduce exotic species of plants and animals,causing disruption of the local food web. Discharges rich in nitrogen can generate the rapid growth of plankton, eventually leading to a condition known as red tide that is lethal to some coastal organisms.3 ' Implementation of the proposed project may contribute to long-term impacts to water quality and marine biological sources. However, as stated in Section 5.10, OCEAN WATER QUALITYAND MARINE BIOLOGICAL RESOURCES,all potentially significant impacts to long-term water quality and marine biological sources would be reduced to less than significant levels through regulatory compliance, and project design features and implementation of the recommended mitigation measures pertaining to hydrology and water quality. The following discussion describes the potential for cumulative impacts to the Southern California Bight. As discussed in Section 5.10, oceanographers from the Scripps Institution of Oceanography conducted modeling simulating ocean conditions near the HBGS intake and outfall. The model calculates the degree of mixing of various potential contaminant sources with the Pacific Ocean. The Santa Ana River, Talbert Marsh, OCSD wastewater discharge outfall, and proposed ' desalination facility discharge were all investigated. Seawater contamination resulting from any of the above sources could potentially impact the quality of product water and, to some degree, the quality of byproduct concentrated seawater to be discharged from the HBGS outfall. The model results show the amount of dilution of each of these sources of pollutants under different ' oceanographic conditions. The results of the model concluded that long-term water quality impacts to the Pacific Ocean would be less than significant. Additionally, the analysis concluded that the 3 Oceanography of the Southern California Bight, http://seis.natsci.csulb.edu/bperry/scbweb/homepage.htm City of Huntington Beach April 5, 2005 6-20 r-, Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report mixture of the proposed facility's concentrated seawater discharge with the HBGS cooling water discharge would not result in salinity increases that would significantly impact marine biological resources. The analysis to marine biological resources also concludes that plankton entrained in the discharge stream are likely to be killed, as much by the turbulence and temperature of the discharge (which would occur even without proposed project implementation) as by the salinity increase. Thus, no significant increase in plankton loss is expected from the addition of the by- product water to the discharge stream: Since implementation of the proposed project would result in less than significant impacts to ocean water quality and marine life, the analysis of cumulative impacts must include an analysis of the expected environmental effects to be produced by other cumulative projects. As shown in Table 6- Ji 4, 11 desalination facilities are currently being proposed along the Southern California coast,which would contribute to cumulative impacts associated with the proposed project. Seawater desalination projects outside of Southern California (approximately 11 are proposed)have no potential to interact with the proposed project. Additionally,existing and proposed ports,wastewater treatment facilities, industrial uses, etc. along the coast would contribute to cumulative impacts. The proposed r7 desalination facilities and other anthropogenic uses would be required to ensure that the objectives and goals defined in the California Ocean Plan and the Water Quality Control Plan for Control of Temperature in the Coastal and Interstate Waters and Enclosed Bays and Estuaries of California are met on a project-by project basis. These plans identify water quality goals and objectives that pertain to: ❖ Thermal characteristics (control of temperature in the coastal and interstate waters and enclosed bays and estuaries of California [Thermal Plan]); `r ❖ Bacterial characteristics,physical characteristics(i.e.,visible floating particulates,grease,oil,and discoloration); ❖ Chemical characteristics (i.e., dissolved oxygen concentration, pH, amounts of dissolved sulfide, nutrient materials, and other harmful substances); ❖ Biological characteristics (i.e., effects to marine communities, including vertebrate, invertebrate, and plant species); and ❖ Radioactivity (radioactive waste discharge). In regards to the proposed desalination facilities,because each proposed desalination facility would have unique design and siting characteristics,each is likely to be subject to a different set of Coastal Act policies and would likely conform to those policies in different ways. Some desalination proposals may be environmentally benign or may even provide environmental benefits,while others may cause significant impacts(e.g.,entrainment and impingement impacts). Determining whether a proposed desalination project would conform to the Coastal Act would therefore be done on a case- by-case basis. Furthermore, based upon the siting of a desalination facility,it would be necessary to conduct an evaluation of the Best Available Control Technology (BACT) (i.e., immersion filters, bafflers, screens to minimize larvae intake, etc.) to minimize impacts to water quality and marine biological resources. The physical effect of desalting seawater by reverse osmosis is in principle no different than the effects of evaporation. Ocean surveys of the Southern California Bight have measured evaporative losses at 93.4 centimeters per year. The surface area of the coastal waters inside the continental margin of the Southern California Bight is approximately 160,000 square kilometers. Factoring in evaporation over the surface area, it is concluded that the coastal area of the Southern California Bight loses 1.49 by 10" cubic meters of pure water constituent from the coastal ocean each year. In contrast, a desalination facility producing product water at a rate of 50 mgd will extract 6.9 x 107 cubic meters of pure water constituent of water from the coastal ocean in one year's time. City of Huntington Beach April 5, 2005 6-21 ' Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report ' Consequently, it would take 2,163 50 mgd desalination facilities to match the natural evaporative losses from the ocean in the Southern California Bight.4 When viewed in conjunction with other proposed desalination facilities and anthropogenic uses planned for the Southern California coast,the potential degradation of marine biological resources and long-term water quality could be considered a negative cumulative impact. However,given the dispersion and physical distance from the proposed desalination facility to other Southern California desalination facilities, there would not be any overlapping. Furthermore, the proposed project includes mitigation measures relevant to the preparation of a Water Quality Management Plan (WQMP),specifically identifying Best Management Practices(BMPs),a site-specific hydrology and hydraulic analysis, and installation of an on-site storm drainage system to ensure that long-term water quality impacts are less than significant. Additionally, potential impacts of cumulative projects would be-site specific and an evaluation of potential impacts would be conducted on a project-by- project basis. This would be especially true of those developments located in areas that contain sensitive species and habitat. Each incremental development would be required to comply with all ' applicable local, State, and Federal regulations concerning the protection of biological resources and degradation of water quality. In consideration of these regulations,potential cumulative impacts upon ocean water quality and marine biological resources are considered less than significant. ' Power Production Information regarding power production is based upon the Huntington Beach Desalination Project ' Report on Local and Regional Power Requirements and Generation Resources, prepared by Navigant Consulting, Inc. (NCI) (July 2004) (refer to Appendix Q, REPORT ON LOCAL AND REGIONAL POWER REQUIREMENTS AND GENERATION RESOURCES). According to this report, the estimated load for the proposed Project is 30-35 MW, and it is anticipated that it would be operating at this level unless the HBGS is conducting its heat treatment process. ' Southern California Edison (SCE)and other utilities routinely develop forecasts of electrical loads on their systems. Most times the publicly available information resulting from these forecasts is aggregated such that the only data available are that for the load served from the major substations or on a system wide basis. The assessment of impacts to power production as a result of project ' implementation have been based upon the following: ❖ Extracted information on the estimated amounts of power delivered through each of SCE's major 230-kV and 115-kV substations from SCE's CAISO Controlled SCE Transmission— 2004-2008 and 2013 Expansion Plan (March 2004). ❖ Information regarding the total peak loads on the systems of the Los Angeles Department of ' Water and Power(LADWP), the other municipal utilities in the Los Angeles Basin, and the Imperial Irrigation District from a load forecast prepared by NCI in 2002. ❖ Information regarding the total peak load on the San Diego Gas&Electric(SDG&E)system from information in the 2003 and 2004 RMR studies for the SDG&E area.5 The SCE system in the Los Angeles Basin consists of: ❖ A 230 kV transmission network which delivers power to a number of 230/66-kV substations, and _Hydrodynamic Modeling of Source Water Make-Up and Concentrated Seawater Dilution for the Ocean Desalination Project at the AES Huntington Beach Generating Station. Dr. Scott A. Jenkins Consulting, December 1, 2004 (Revised August 14,2004)(Appendix C of the EIR). a RMR units are those that have been identified by the ISO as required to be on-line to maintain local area reliability in the event a forced outage should occur on a transmission element or a generator in the local area. City of Huntington Beach April 5, 2005 6-22 Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report ❖ 66-kV lines which interconnect the 230-kV substations with numerous 66-kV substations from which the power is delivered to lower voltage facilities that ultimately serve the load. r7 Table 6-5, SCE 230-KV SUBSTATIONS SERVING LOAD /N ORANGE COUNTY, contains information relative to the location of the 230-kV substations,as well as estimates of the amount of the total SCE load in Orange County, that is served from each substation. In addition to SCE 7 substations listed in Table 6-5, the Lewis 230/66-kV Substation, located in Anaheim, serves the electrical load in the City of Anaheim. Table 6-5 ^' SCE 230KV SUBSTATIONS SERVING LOAD IN ORANGE COUNTY Substation Location %of County r (City) Load Served Alamitos Long Beach <1 Barre Stanton 20 Del Amo Cerritos 1 ' I' Ellis Huntington Beach 18 Johanna Santa Ana 12 Olinda La Habra 7 J Santiago East Irvine 23 7 Villa Park Orange 19 The information discussed above was also used to develop the information in Table 6-6,SUMMARY OF ESTIMATED LOADS (MW), relative to estimated loads for the years 2008 - 2013 in the Huntington Beach area, Orange County, the Los Angeles Basin, and southern California. Table 6-6 SUMMARY OF ESTIMATED LOADS (MW) Year 2008 2009 2010 2011 2012 2013 Huntington Beach Area Load 390 393 397 402 408 413 Orange County Load SCE 3,870 3,920 3,980 4,030 4,100 4,140 --------------------------------- -------------- -------------- --------------------------------------------- -------------- City of Anaheim 575 .585 600 610 620 635 Total Orange County 4,445 4,505 4,580 4,640 4,720 4,775 Los Angeles Basin Load SCE 14,470 14,640 14,720 14,820 15,060 15,230 -------------- -------------- --------------------------------------------- -------------- LADWP ___ 6,240 6,310 ___ 6,370_______ 6,420 6,470 6,520 Other Municipal Utilities6 2,170 2,200 2,240 2,290 2,330 2,380 Total Los Angeles Basin 22,880 23,150 23,330 23,530 23,860 24,130 Southern California Load SCE System Load 21,150 21,460 21,800 22,130 22,520 22,840 r -------------- -------------- -------------- ------------------------------ -------------- SDG&E Load 4,460 4,570 4,680 4,800 4,920 5,040 -------------- -------------- --------------------------------------------- -------------- LADWP Load 6,240 6,310 6,370 6---- 6---- 6---- -------------- -------------- ------------------------------------------------------------ Other Municipal Utilities 2,170 2,200 2,240 2,290 2,330 2,380 -------------- -------------- --------------------------------------------- -------------- Im ----- Imperial irrigation District 850 870 890 900 k-0 940 Total Southern California 34,870 35,410 35,980 36,540 37,160 37,720 6 Anaheim,Azuza, Banning, Burbank,Colton,Glendale, Pasadena,and Riverside. City of Huntington Beach April 5, 2005 6-23 ' Seawater Desalination Project at Huntington Beach 6.0 LONG-TERM IMPLICATIONS Draft Recirculated Environmental Impact Report ' As noted above, the project load is anticipated to be as much as 35 MW starting in the first quarter of 2008. Table 6-7, CHANGE IN ESTIMATED LOADS DUE TO ADDITION OF THE PROJECT(%), presents information on the amounts by which the estimated loads summarized in Table 6-6 would increase when a 35 MW project load is added to them. Table 6-7 shows that the addition of the 35 MW Project load would increase the demand for electric energy in the Huntington Beach area by ' approximately nine percent. However, the impact of the addition of this load on the demand for electric energy in Orange County or Southern California is insignificant (less than one percent). Thus, it is concluded that cumulative impacts to power production are less than significant. Table 6-7 CHANGE IN ESTIMATED LOADS DUE TO ADDITION OF THE PROJECT (%) ' Year 2008 1 2009 2010 2011 2012 2013 Huntington Beach Area 9.0 8.9 8.8 8.7 8.6 8.5 ' Load Orange County Load 0.8 0.8 0.8 0.8 0.7 0.7 Los Angeles Basin Load 0.2 0.2 1 0.2 0.2 0.2 0.2 Southern California Load 0.1 0.1 1 0.1 0.1 1 0.1 0.1 In addition, a recent report published by the National Resources Defense Council (NRDC) and Pacific Institute states that the California State Water Project is the single largest user of energy in ' California, utilizing two to three percent of all electricity consumed in the state. ' This electricity consumption is necessary to lift water 2,000 feet over the Tehachapi Mountains (the highest lift of any water system in the world). Operation of the Colorado River Aqueduct adds to the electricity consumed in pumping water to Southern California. As stated in Section 5.4,AIR QUALITY, the proposed desalinated water has the potential to replace a portion or all of a given water provider's water curtailed from the State Water Project along the West Branch,then the power requirements to move imported water through the Central Valley,over the Tehachapi Mountains, and into the Los Angeles Basin could result in substantial power reductions, thus resulting in air quality offsets. Whereas the proposed facility has an "all in"power ' rate of 4,887 kilowatt hours per acre-foot for producing water and conveyance into the Orange County system, according to the Department of Water Resources Bulletin 132 (1998), the State Water Project has a power rate of 3,200 kilowatt hours per acre-foot (net of hydroelectric power ' production in the LA Basin). As such,there is only a 1,687 kilowatt-hour per acre foot difference(or an additional 258 megawatts per day)increase in energy consumption over current supplies into the Metropolitan.Water District's (MWD) Diemer water treatment facility. 7 "Energy Down the Drain-The Hidden Costs of California's Water Supply", NRDC/Pacific Institute,August 2004. ' City of Huntington Beach April 5, 2005 6-24 i � 7.0 ALTERNATIVES TO THE PROPOSED ACTION 1 1 i 1 1 i 1 7.0 ALTERNATIVES TO THE 1 PROPOSED ACTION In conformance with CEQA Guidelines §15126.6, the EIR has included a comparative impact assessment of "alternatives to the proposed project". The primary purpose for this section is to provide decision-makers and the public with a"reasonable range"of project alternatives which could feasibly attain most of the basic project objectives, while avoiding or substantially lessening any of the project's significant adverse environmental effects. Important considerations forthis alternatives analysis include (as noted in §15126.6): 4. "...An EIR need not consider every conceivable alternative to a project." . An EIR should identify alternatives that were considered by the lead agency but were rejected as infeasible during the scoping process..." l ❖ Reasons for rejecting an alternative include: "...failure to meet most of the basic project objectives"; "...infeasibility'; and "...inability to avoid significant environmental effects". Other than temporary, short-term air quality emissions associated with construction activities, the EIR has not identified any "unavoidable" significant impacts of the project, as all potentially significant impacts can be mitigated to less than significant levels. However, certain cumulative impacts,to which the project would contribute,may be slightly reduced with some of the alternatives. Project-related cumulative impacts include air quality and noise,although the project's contribution is not"cumulatively considerable" as defined in CEQA Guidelines §15126.6. As noted in Section 3.4, PROJECT NEED AND OBJECTIVES, the proposed project's "basic objectives" consist of: ❖ Provide a reliable local source of potable water to Orange County that is sustainable independent of climatic conditions and the availability of imported water supplies or local groundwater supplies; ❖ Provide product water that meets or the potable ("drinking water") requirements of the Safe Drinking Water Act(SDWA)and the Department of Health Services(DHS); ❖ Reduce salt imbalance of current imported water supplies by providing a potable water source with lower salt loads for blending with existing supplies; ❖ Remediate the subject site of on-site contaminants resulting from approximately 35 years of use as a fuel oil storage facility in order to protect the health and safety of those in the surrounding community; ❖ Create ecosystem and biologic resources benefits that may accrue due to decreased pressures on existing water resources and reduced contamination within receiving waters; and ❖ Minimize demands on the existing imported water system. The following alternatives to the proposed project are discussed: "No Project" alternative; "Alternative Site"alternative;"Alternative Ownership and Operation"alternative;"Alternative Project Design" alternative; and "Environmentally Superior' alternative. A comparison of issues with implementation of identified alternatives is provided within Table 7-1, COMPARISON OF ALTERNATIVES. City of Huntington Beach April 5, 2005 7-1 7 Seawater Desalination Project at Huntington Beach 7.0 ALTERNATIVES Draft Recirculated Environmental Impact Report Table 7-1 COMPARISON OF ALTERNATIVES Alternative Issue No Project Alternative Ownership Alternative .Reduced Site Project Design Facility Size and Operation Land Use/ < N/A = > = j Relevant Planning =/> r-� Geology,Soils,and < Seismicity Hydrology, Drainage < and Storm Water Runoff Air Quality < — </ Noise < t—� Public Services and > Utilities (water supply) Aesthetics/Light& < _/> _ > _ Glare n Hazards/Hazardous < Materials Construction < </_ _ > Related Impacts Ocean Water < > _ < Quality and Marine Life Product Water < Quality and System Integration LEGEND Impact is equivalent to impact of proposed project(neither environmentally superior or inferior). r < Impact is less than impact of proposed project(environmentally superior). > Impact is greater than impact of proposed project(environmentally inferior). * Some alternatives may have greater impacts to marine life than the proposed project r 7.1 "NO PROJECT " ALTERNATIVE None of the impacts associated with the proposed development and construction activities would occur if the "No Project' alternative were selected. Implementation of this alternative would leave the existing portion of the fuel oil storage facility, proposed pipeline alignment, and proposed underground booster pump station sites in place, and would avoid any adverse physical or i environmental impacts associated with the proposed project. Existing geologic,soils,and aesthetic _ r City of Huntington Beach April 5, 2005 7-2 I Seawater Desalination Project at Huntington Beach 7.0 ALTERNATIVES Draft Recirculated Environmental Impact Report conditions in the area would remain the same. Air quality, noise, and traffic impacts due to construction of the desalination facility, pipeline, and pump stations would not occur with the "No Project' alternative. The "No Project" alternative is not presently being considered because it fails to meet the basic project objectives. In addition, the existing project site degrades the aesthetic character of the vicinity and, if not remediated as proposed, may pose a significant health risk due to petroleum hydrocarbon contamination. Furthermore,the"No Project"alternative would not realize the project benefit of providing a "drought proof," high quality, new potable water supply. Water planning professionals have forecasted that water demands would increase in the Southern California area, and have specifically identified resource targets to help meet projected demands, including local seawater desalination facilities. (See Table 7-2 MWD UPDATED RESOURCE TARGETS.) Consequently, adoption of the "No Project" alternative would result in shifting the obligation for meeting a portion (up to 56,000 acre-feet per year)of future water demands from the project to: 1)increased conservation efforts(efficiency improvements and reduced consumption);2) increased use of imported water supplies;3)increased use of groundwater supplies;4)construction of additional local water supply projects; and/or 5) construction of seawater desalination projects elsewhere in Orange County. In some instances,therefore,the environmental impacts associated with the "No Project' alternative may be greater than those associated with the project. Table 7-2 (From MWD's 2003 IRP Update) MWD UPDATED RESOURCE TARGETS (WITH SUPPLY BUFFER) 1996`�IRP IRP Update IRP Update 2020; '2020. Change .2025 Conservation 882,000 1,028,000 +145,600 1,107,000 • Recycling +250,000 • Groundwater Recovery 500,000 750,000 (buffer) 750,000 • Desalination Colorado River Aqueduct * 1,200,000 1,250,000 +50,000 1,250,000 State Water Project 593,000 650,000 +57,000 650,000 Groundwater Conjunctive Use 300,000 300,000 0 300,000 CVP/SWP Storage and Transfer 300,000 550,000 +250,000 550,000 buffer MWD Surface Storage"* 620,000 1 620,000 0 1 620,000 * The 1,250,000 acre-feet supply from the Colorado River Aqueduct is a target for specific year types when needed. Metropolitan is not depending upon a full aqueduct in every year. *"Target for Surface Storage represents the total amount of water that can be extracted from storage. 1. Increased Conservation Efforts As explained in the Metropolitan Water District of Southern California (MWD) 2003 IRP Update, "conservation reduces water demand in ways that are not easily measured or metered. Demand is reduced through changed consumer behaviors and savings from water-efficient fixtures"(page 26). Calculating against a base year of 1980,the Municipal Water District of Orange County(MWDOC) has projected that Orange County water users would conserve 84,000 acre-feet in 2005. One result of selecting the "No Project'alternative could be an increased obligation for Orange County water users to conserve an additional 56,000 acre-feet per year,commencing as early as 2008(when the project is expected to be in full production). City of Huntington Beach April 5, 2005 7-3 r-� Seawater Desalination Project at Huntington Beach 7.0 ALTERNATIVES l Draft Recirculated Environmental Impact Report Adding an extra 56,000 acre-feet per year to the 84,000 acre-feet of annual conservation that is occurring in Orange County would be difficult because the MWD 2003 IRP Update already set significantly increased conservation targets for Orange County to reach by 2020. The 1996 IRP target of 882,000 acre-feet for the MWD service area was increased to 1,028,000 acre-feet in the \ 2003 IRP Update—a regional increase of 145,600 acre-feet per year(see Table 7-2). This equates - to increased conservation expectations in Orange County of 64,000 acre-feet over and above the 84,000 acre-feet per year projection,for 2005. To realize an additional 56,000 acre-feet of n conservation savings each year would essentially require doubling of the County's future > conservation efforts. To double the future conservation efforts of the County in such a relatively short time period would require,at a minimum,the imposition of prescriptive conservation standards !- for activities, like outdoor residential irrigation,that are today considered discretionary consumptive water use. 2. Increased Use of Imported Water Supplies The western USA is in the sixth year of a drought. Southern California is in its fifth year of drought (2003/04 water year). If the region is in a 20-year drought cycle, as Scripps Climate Research ` Division scientists have strongly suggested,then imported water would be difficult to obtain from the primary sources of the State Water Project(Sacramento Delta)and Colorado River. Still,Table 7-2, UPDATED RESOURCE TARGETS, shows that water planners are continuing to project increased reliance on imported water supplies. Surplus water from the Colorado River is not likely to be available because of the drought. MW D's �l plan for dealing with imported water shortages (beyond recent storage increases) has been to purchase agricultural water from Northern California (through the Sacramento Delta). "in January 2003, Metropolitan's Board authorized one year transfer option agreements with 11 Sacramento Valley Water Districts to ensure water supply reliability. Metropolitan secured 146,230 acre-feet of options from these districts, of which 126,230 acre-feet were exercised" (MWD web page, September 2004). These water transfers are allowed and encouraged by state policy, but have economic dislocation and environmental issues related to the Delta that would be increased if additional supplies are required using these measures. As a matter of policy, water transfers are typically short-term arrangements, and, as such, are not sufficient to offset reliable long-term sources of supply. i J To realize an additional 56,000 acre-feet of imported water supplies each year would result in economic and environmental impacts resulting from such transfers. An increase in imported water supply would exacerbate environmental degradation occurring along such areas as the Colorado j River and Sacramento-San Joaquin Delta due to the existing diversion of supply to Southern California. 3. Increased Use of Groundwater Supplies' r-, Groundwater withdrawals from the Santa Ana River Groundwater Basin have averaged approximately 350,000 acre-feet per year during the period 1998-2002(OCWD Grand Jury Report, page 7). In comparison, natural and artificial recharge efforts average approximately 270,000 acre- feet per year (OCWD Grand Jury Report, page 9). To make up for the imbalance, OCWD has + purchased an average of 60,000 acre-feetof imported replenishment water from MWD each yearfor supplementary recharge and 20,000 acre-feet of water each year (via the first phase of the Groundwater Replenishment System[GWRS]and purchases from MWD)for injection into seawater barriers. Since the 1997-98 water year (a wet year), the County has experienced dry conditions, 1 The information in this section was reviewed and confirmed by John Kennedy of the Orange County Water District (OCWD)in September,2004. -1 City of Huntington Beach April 5, 2005 7-4 Seawater Desalination Project at Huntington Beach 7.0 ALTERNATIVES Draft Recirculated Environmental Impact Report resulting in overdrafts in excess of 30,000 acre-feet per year. In November 2002,the accumulated overdraft was estimated to be more than 400,000 acre-feet,which prompted OCWD to take actions to limit groundwater production rates and reduce the rate of withdrawal to about 324,000 acre-feet per year in 2003-04. Pumping for the current 2004-05 year has been limited to 316,000 acre-feet and is expected to be reduced to 311,000 acre-feet in 2005-06 (Grand Jury Page 8). To realize an additional 56,000 acre-feet from groundwater supplies each yearwould risk damaging the capacity, reliability and performance of the groundwater basin, particularly in regards to an increased susceptibility of coastal groundwater aquifers to seawater intrusion. The ability to increase the volume of water taken into the basin is limited by the geology of the area. Current recharging capacity is approximately 300,000 acre-feet per year(Groundwater Recharge Brochure, OCWD). The groundwater basin is sustained by natural and man-made recharging 1 (introduction of water)of the basin aquifers. OCWD manages a very sophisticated system of lakes (i.e. percolation ponds)in Orange and Anaheim that seep water through the lake bottoms. Each of the lakes acts like purification funnels delivering water into the groundwater basin. It is interesting to note,that only in that area of the county is the soil composition of the sand and gravel conductive to water traveling to deep aquifers. Underlying the rest of the ground water basin is a fairly consistent clay layer that prevents significant percolation into the groundwater basin outside the Anaheim and Orange areas. Over the years,constantly improving this recharge system has tripled the yield of the groundwater basin. It is estimated that by 2020, additional improvements would be required to increase percolation capacity by 70,000 acre-feet per year to meet future groundwater demands. It should also be noted that the Groundwater Replenishment System, or GWRS, (GWRS, 2008 operation) would produce 70,000 acre-feet per year and half of its water would be piped to the percolation ponds described above and half would be injected into the seawater barriers (O.C. Water 101 -Where Do We Get Our Groundwater? - OCWD web site). Therefore, the ability of the groundwater basin to increase output or increase inflows of recycled/reclaimed water is limited. 4. Construction of Additional Local Water Supply Projects As shown in Table 7-2, MWD is projecting that local projects(recycling, groundwater recovery and 1 desalination) would shoulder a greater portion of the burden in meeting future water demands. Clearly, it is expected that several additional water supply projects would be constructed in coming years as the target set by the 1996 IRP for 2000—300,000 acre-feet of supply from local projects- was missed. As of 2002, local projects produced 251,000 acre-feet peryear. As summarized in the MWD 2003 IRP Update,"meeting the targets would require the region to produce 159,000 acre-feet of additional local project and/or seawater desalination supply by 2010 and 249,000 acre-feet by 2020." The GWRS project and potential phased expansions are currently included in the MWD 2003 IRP Update. Through implementation of those projects and others, MWDOC is planning to increase the contributions of local projects by 162,000 acre-feet per year, and has plans to add another 50,000 acre-feet per year of"buffer projects"to match the MWD 2003 IRP Update plans for supply. To realize an additional 56,000 acre-feet from additional local water supply projects each year (over and above the significant increases that are already planned) would require implementation of 10 to 12 new projects: a 30 percent increase over current plans. 5. Construction of Seawater Desalination Projects Elsewhere in Orange County This alternative is discussed in Section 7.2 "ALTERNATIVE SITE"ALTERNATIVE. City of Huntington Beach April 5, 2005 7-5 Seawater Desalination Project at Huntington Beach 7.0 ALTERNATIVES Draft Recirculated Environmental Impact Report 7.2 "ALTERNATIVE SITE" ALTERNATIVE Huntington Beach Generating Station (HBGS) Alternative Site An alternative site(formerly the proposed project site within Initial Study prepared for the previously circulated EIR, dated May 17, 2001)for the desalination facility is located southwest of the current n project site,within the HBGS,with HBGS office buildings to the west,an electrical switchyard to the north,and fuel oil storage tanks to the east. The alternative site is located within approximately 300 feet of the proposed project site, closer to the residential uses to the west. Project operation and equipment would be similar as with the project. However,the primary constraint for this site that led to its rejection is potentially significant temporary and permanent disruption to HBGS parking, access and operational activities,as the site is located immediately adjacent to the generating units and would displace existing parking, access areas and buildings. In addition, due to the site constraints that would be placed on HBGS from this alternative, it may preclude the power plant from converting to gas turbine combined cycle operation in the future. As such,this alternative site is not considered feasible. i Alternative Locations Within a Two-Mile Radius of the HBGS J A preliminary investigation of available land (five acres or larger) within a two-mile radius of the . HBGS was performed for the proposed project. Open areas were identified within the two-mile radius using aerial photographs and information obtained from the City of Huntington Beach website. As shown in Appendix R, LOCAL ALTERNATIVE SITE INVESTIGATION, most of the open areas are parks and schools within the local community. There are total of eight parks identified in the two-mile radius,and most are less than five acres in size. In addition,there are five schools located in close proximity to the identified parks. Other open areas include: wetlands, Orange County Sanitation District(OCSD)property(reserved forfuture plant expansion)and the Ascon/Nesi site(a former landfill approximately 40 acres in size). The Ascon/Nesi site is a highly contaminated piece of property and is currently under DTSC review for clean-up, and therefore this is not a viable ) alternative for the desalination project. There are three open areas to the northwest of the HBGS. However,all three sites are proposed for development. One of the sites is the former CENCO tank farm (25 acres), for which an entitlement application is in process for construction of 204 homes. The remaining two sites include the new Pacific City development located west of Huntington Street, and the new Hyatt Regency Huntington Beach Resort and Spa located west of Beach Boulevard, which has since been developed. According to the City of Huntington web page, only three of the parks analyzed within the site investigation are at least five acres. These parks consist of: ❖ Gisler Park, 11 acres; ❖ LeBard Park, five acres; and ❖ Talbert Regional Park(the north part of the park is 99.1 acres while the south part of the r park is 88.5 acres). As these park facilities are actively utilized for recreation by the local community and no proposals to convert these facilities to alternative uses exist, no sites within a two-mile radius are feasible for implementation of the proposed desalination facility. r r City of Huntington Beach April 5, 2005 7-6 Seawater Desalination Project at Huntington Beach 7.0 ALTERNATIVES Draft Recirculated Environmental Impact Report Alternative Locations Outside of the City of Huntington Beach Several other locations outside of the City of Huntington Beach have also been considered for this project, including the mouth of San Juan Creek (within the City of Dana Point), San Onofre (within San Diego County), and along the coast of the City of San Clemente (refer to Exhibit 7-1, ALTERNATIVE SITE LOCATION MAP, and Table 7-3, ALTERNATIVE SITE COMPARISON). These alternatives are not being considered for a variety of reasons, such as environmental 5 concerns of a new ocean intake/discharge system (San Clemente)and/or engineering/acquisition issues (San Onofre). A discussion of potential impacts is discussed below. Land Use/Relevant Planning Impacts in regards to land use/relevant planning vary primarily on uses surrounding the project site and general plan/zoning designations for the site. Sensitive uses(residences,schools,recreational areas,etc.)exist in the vicinity of the San Juan Creek and San Clemente locations,thereby creating a greater potential for land use impacts to occur for these two alternative sites. In addition, the proposed industrial use may conflict with existing General Plan,and zoning designations within the City of Dana Point, City of San Clemente, and County of San Diego. The HBGS alternative site would have potentially significant operational impacts upon HBGS. Geology and Soils Geology and soils impacts are dependent on the unique geological/soil characteristics of each alternative site considered. However, project implementation on an alternative site would comply with the Uniform Building Code (UBC) and all other State and local regulations in regards to geologic and seismic safety. Impacts are anticipated to be similarto those of the proposed project site, although the HBGS alternative site avoids issues associated with the OCFCD channel. Hydrology, Drainage and Storm Water Runoff Implementation of the proposed project at an alternative site outside of the City of Huntington Beach P P P P J tY 9 would likely have similar impacts in regards to hydrology, drainage, and storm water runoff. As the design, area, and operation of the proposed desalination facility would generally remain the same (i.e. incorporation of an adequate on-site storm water drainage system),both construction and long- term operational impacts are anticipated to be similar to those of the proposed project. Air Quali r Implementing the proposed desalination project on an alternative site would have similar air impacts to those of the proposed project site. As stated above, the design, area, and operation of the proposed desalination facility would generally remain the same. Therefore, air impacts resulting from short-term project construction and long-term facility operation would be similar to those of the proposed project site within the City of Huntington Beach. Noise Impacts in regards to noise are anticipated to be similar to those of the proposed project site. As stated above, the design, area, and operation of the proposed desalination facility would generally remain the same. It is anticipated that the same noise-generating equipment(pumps,compressors, etc.)and noise attenuation measures would be incorporated upon implementation on an alternative site. In addition, the level of noise generated by mobile sources (automobiles driven by on-site employees,delivery trucks)would not change,as facility operations would not significantly change. However, alternative sites with nearby sensitive receptors may create greater noise impacts. City of Huntington Beach April 5, 2005 7-7 r-, Seawater Desalination Project at Huntington Beach 7.0 ALTERNATIVES Draft Recirculated Environmental Impact Report Public Services and Utilities Implementing the proposed desalination facility on an alternative site is anticipated to have similar 4 impacts in regards to public services and utilities as the proposed project site. As stated above,the design, area, and operation of the proposed desalination facility would generally remain the same. In addition, impacts to public services and utilities such as police/fire service, solid waste, sewer, drainage,and electricity would not vary-significantly from proposed project site implementation within the City of Huntington Beach. Aesthetics/Light& Glare As stated above, the design, area, and operation of the proposed desalination facility would generally remain the same. Although building height and lighting standards vary by city/county, it is expected that impacts in regards to aesthetics,light,and glare on an alternative site would be similar in nature to proposed project site implementation. However, construction of a new facility in a sensitive coastal environment absent of industrial uses (San Clemente) may have significant aesthetic impacts. Hazards and Hazardous Materials Impacts in regards to hazards and hazardous materials are anticipated to be similar to those of the proposed project site. The nature in which hazardous materials would be stored,handled,and used for project operation is not expected to change upon alternative site implementation. However,one J' or more alternative sites may have less existing site contamination. Construction Related Impacts As stated above, the design, area, and operation of the proposed desalination facility would generally remain the same. Although many short-term construction impacts(primarily noise and air) would vary by the amount of grading necessary, it is anticipated that the phasing and construction process would not vary significantly from proposed project site implementation. However, construction-related impacts due to pipeline implementation are anticipated to be lower for the alternative sites in comparison to the proposed.project site, as shorter lengths of pipeline would be necessary to convey product water to the distribution system (refer to Table 7-3, ALTERNATIVE SITE COMPARISON). Ocean Water Quality and Marine Life Depending on the alternative site selected, impacts in regards to ocean water quality and marine life r may be greater than those of the proposed project site. If implementation of the proposed project on an alternative site requires the construction of new intake and outfall facilities for plant operation(as is the case with the San Clemente alternative site), substantial impacts to marine biological resources would occur,as construction and operation of plant facilities may disrupt sensitive marine habitats. If the desalination facility were to utilize existing intake and outfall facilities(as is the case - with the San Onofre alternative site), impacts are anticipated to be similar to those of the proposed project site within the City of Huntington Beach. MWDOC,which is considering the implementation of a desalination facility at the San Juan Creek location, is exploring the use of beach wells as a seawater intake. Although a beach well intake system may result in decreased marine biological impacts compared to the proposed project, this benefit is negated somewhat by the need to r construct a new ocean outfall for concentrated seawater discharge. r-- City of Huntington Beach April 5, 2005 7-8 Tv- tin Jinn 1 � r" �''�yy ap i st ran±a�. ,Y, , �irna oint i -40 J� �r / ',1 *,'^c.�``'e.`� ^.•-,:s.�.• .- "„,�., t` j ,,..�i'V mil.r�= ` -%' -°., ♦.y tt "T-�L-' {Y"t�'t _ - t� p 4 3 -% iv } Ca istranto, ( Site A �... Beach ��,� s,�- �t�i � f � ��t,�+ Near Mouth of rP. ° ...�..._... �. �-� San Juan Creek Site �t �c DIY ✓{ 1 l t T17 7 / s Coast in San Clemente Ole Hanson Beach clb� , '/ ' r _J P G ! f o f a �� t a ' San-,J e C a ! a ! i n a San Clemetc{'° ��ram,.. � ��,'•./'S��t{ f � Site ,S If Rdm San Onofre Source:Poseidon Resources Corporation,August 2004. NOT TO SCALE SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH PFQ Alternative Site Location Map CONSULTING 02/05•JN 10-101409.002 Exhibit 7-1 Seawater Desalination Project at Huntington Beach 7.0 ALTERNATIVES Draft Recirculated Environmental Impact Report Table 7-3 ALTERNATIVE SITE COMPARISON Near Mouth of Coast in San Onofre Huntington San Juan Creek San Clemente Beach Environmental Issues Many Many Many Temporary Land Use Many Issues Many Issues Few Issues None Land Cost Very High Very High Moderate Moderate Seawater Supply Beach Well Intake Requires New Intake Could use Existing Existing Intake Effluent Requires New Outfall Requires New Outfall Could use Existing Existing Outfall Required Piping <2 miles 2-5 miles 5-7 miles 10 miles ` Public Perception High High Very High Moderate Issues Product Water Quality As the reverse osmosis treatment process utilized at an alternative site would be similar to that of the proposed project, the quality of product water is anticipated to be similar. While source water (i.e.ocean water)quality may vary by site,the reverse osmosis treatment process would most likely be capable of producing water meeting all Department of Health Services (DHS) requirements. ' Impacts due to product water compatibility are anticipated to be similar to the proposed project. Conclusion While the alternative site locations offer advantages over the proposed project site by reducing the length of the product water pipeline, the San Juan Creek and San Clemente sites would have greater impacts due to sensitive surrounding uses and the need to create a new ocean intake/outfall. Implementation of the "Alternative Site" alternative would not avoid the project's identified unavoidable air quality impact, and may result in significant aesthetic and/or marine biological impacts. This alternative is not presently under consideration. 7.3 ALTERNATIVE OWNERSHIP ALTERNATIVE The"Alternative Ownership"alternative would not change any of the design or operational features of the project. Rather,this alternative consists of the exact same project owned and operated by a public entity. The project proponent, a private entity, has already obtained lease rights to the site ' through negotiations with the current land owner(AES Huntington Beach, LLC). Forthis alternative to be feasible, a public entity would first need to negotiate with the applicant or otherwise obtain lease rights to the site. Assuming that rights to the site were acquired by a public entity,this alternative would result in all of the same potential environmental impacts that would result from implementation of the project as proposed (under private ownership). It has been asserted that operation of seawater desalination projects by private entities may result in potential environmental impacts over and above those that City of Huntington Beach April 5, 2005 7-10 r� Seawater Desalination Project at Huntington Beach 7.0 ALTERNATIVES Draft Recirculated Environmental Impact Report would result if public entities operated such plants because private entities with multinational ties i could seek to avoid state and local environmental regulations by relying on treaties now in effect or being negotiated by the United States. Upon reviewing this assertion,the California Department of r Water Resources has come to the opposite conclusion. "No international trade treaty now in effect or being negotiated by the United States would prevent local, state, or,federal government agencies from reviewing and regulating water projects that involve private companies with multinational ties.Such projects include desalination plant, water transfers, water storage projects (both above and below ground), and wastewater reclamation projects. So long as government regulations are applied in the same manner to water projects involving multinational corporations as they are to water projects owned or operated by domestic companies or public utilities, there would be no conflict with international trade treaties." (2004 California Water Plan, Volume 1, Chapter 2, page 26.) It should be noted that the project proponent, Poseidon Resources Corporation, is a U.S. corporation based in Connecticut, and is not a multi-national corporation. Consequently,the"Alternative Ownership" alternative and the project as proposed would result in the same potential impacts on the environment. �. 7.4 "ALTERNATIVE PROJECT DESIGN" ALTERNATIVE r� Alternative Methods of Desalination Alternative methods of desalination,such as thermal distillation,have been previously considered in coastal desalination development using a variety of technologies. The MWD,in combination with a consortium of architects, engineers, and a desalination process vendor, proposed a 12.6 mgd multiple-effect-distillation (MED) desalination project under the MWD Desalination Research and Innovative Partnership (DRIP) program in 1996 to be located within the immediate vicinity of the HBGS. Used initially for industrial desalination, the MED process is an alternative process to reverse osmosis. While there are certain advantages to the MED process when compared to the RO process (power consumption not dependent on seawater salinity, higher product water quality, does not require sophisticated pretreatment; and no high-cost membrane replacement elements), the extreme height required for the vertical tubes (300 feet) and the dependency on power plant r operation for steam supply precluded MWD from further considering the MED process at the HBGS site. For the same reasons, the MED process is rejected as a feasible alternative to the existing project. r Alternative Project Intake Source Water Collection Systems The three most common subsurface type intake systems: 1)beach wells;2)infiltration galleries;and 3) seabed filtration systems could be considered as alternative intake systems for the Seawater Desalination Project at Huntington Beach. These three subsurface intake facilities all have one key advantage over the project:the source water they collect is pretreated via slow filtration through the subsurface sand/seabed formations in the area of source water extraction. Beach Wells There are two types of beach wells typically utilized for the intake of seawater: 1) vertical intake wells;and 2)horizontal collector wells(commonly referred to as Ranneywells). Vertical intake wells consist of a non-metallic casting(typically,fiberglass reinforced pipe),well screens,and a stainless �Y City of Huntington Beach April 5, 2005 7-11 Seawater Desalination Project at Huntington Beach 7.0 ALTERNATIVES Draft Recirculated Environmental Impact Report steel submersible or vertical turbine pump. The well casting diameter is between six inches and 18 inches, and well depth does not usually exceed 250 feet. The vertical intake wells are usually less costly than the horizontal wells but their yield is relatively small (typically, 0.1 to 1.0 MGD). Horizontal (Ranney) intake wells consist of a caisson that extends below the ground surface with water well collector screens (laterals) projected out horizontally from inside the caisson into the surrounding aquifer (see Figure 7-1, HORIZONTAL(RANNEY]BEACH WELL). �i Since the laterals in the Ranney wells are placed horizontally, a higher rate of source water collection is possible than with vertical wells. This allows the same intake water quantity to be collected with fewer wells. Individual Ranney wells are typically designed to collect between 0.5 to 5.0 MGD of source water. The caisson is constructed of reinforced concrete that may be between 10 and 30 feet inside diameter with a wall thickness from approximately 1.5 to three feet. These larger capacity intake wells require vertical pumps,which cannot be submersed in water,therefore these vertical pumps must be housed above the high tide line. In addition,the size and servicing of the well pumps, piping, electrical, instrumentation and other auxiliary equipment of large-capacity wells require that the location of the pump house be a minimum of 10 feet above beach grade. The caisson depth varies according to site-specific geologic conditions, ranging from approximately 30 feet to over 150 feet. The number, length and location of the horizontal laterals are determined based on a detailed hydrogeological investigation. Typically the diameter of the laterals ranges from eight to 12 inches and their length extends up to 200 feet. The size of the lateral screens is selected to accommodate the grain-size of the underground soil formation. If necessary,an artificial gravel- pack filter is installed around the screen to suit finer-grained deposits. In large intake applications, such as that shown on Figure 7-2, HORIZONTAL (RANNEY) BEACH WELL PHOTO, the horizontal beach wells are typically coupled with the intake pump station installed above the well caisson. Figure 7-2 shows one of the three 3.8 MGD horizontal (Ranney) intake beach wells (two active intake pumps and one standby pump) for the largest existing seawater desalination facility located on the Pacific Ocean coast in North America—the 3.8 MGD water supply facility for the Pemex Salina Cruz refinery in Mexico. As stated, vertical intake wells typically have relatively low yields (0.1 to 1.0 MGD) compared to horizontal Ranney wells. The proposed Seawater Desalination Project at Huntington Beach would require approximately 100 MGD of seawater in order to produce the projected 50 MGD of freshwater. Consequently, 100 to 1,000 vertical intake wells (100 MGD/1 MGD = 100 wells to 100 MGD/O.1 MGD= 1000 wells),with an estimated depth of 250 feet each,would be required to supply the necessary source water required for full operation of the facility. The vertical intake wells would have to be located on the beach, in close vicinity(usually within several hundred feet) of the ocean. For 100 vertical beach wells with an individual capacity of 1 MGD each, and a minimum distance between the individual wells of 200 feet, the footprint of the beach well shoreline area would be 20,000 feet long (200 feet x 100 wells = 20,000 feet) or approximately four miles. The minimum area of shoreline needed for construction of the vertical intake wells would be (100 feet(construction zone)x 20,000 feet= 2,000,000 square feet (46 acres)). The network of wells would also need n)) a extensive piping system In order to link the individual wells with the desalination facility. A feasibility study prepared for a 25 mgd seawater desalination facility in Corpus Christi, Texas, also concluded that vertical intake wells were not a feasible intake alternative because the "significant cost and land requirements make them impractical and economically infeasible."2 2 Large Scale Demonstration Desalination Feasibility Study. City of Corpus Christi,August 2004. This document is available at hftp://www.cctexas.com/files/gl7/LSD%20Report%20Aug%2004%2Epdf. City of Huntington Beach April 5, 2005 7-12 Seawater Desalination Project at Huntington Beach 7.0 ALTERNATIVES t Draft Recirculated Environmental Impact Report r Figure 7-1 HORIZONTAL (RANNEY) BEACH WELL to Pump house Plant°}ment t.T+ i Al2; � 1 'a i t J f e I ���y 0 3 a�s� s ' • v"F'vt�s,� � ' fit#:��''. I City of Huntington Beach April 5, 2005 7-13 Seawater Desalination Project at Huntington Beach 7.0 ALTERNATIVES Draft Recirculated Environmental Impact Report Figure 7-2 HORIZONTAL (RANNEY) BEACH WELL PHOTO ME r x Q f ; ESTRICTAMENiE,PRONIB100 { EL PASOATODA PERSONA AJENA A IAfMPRESA pp��R3!SESORPRfID� C ENELRITMSERA OAA CONSM,NA a ♦ 'T w t 3"P`R2\'iSY4 ai � 2 2` a "<. a'x ,}x'xi4+k^ .� ., 4 a;Pik hc.� a t*. -t•"n„ .' � wca a. _.:x're,-,.s, :.,,x .-i.+ fi,< "'.v5a.'".a�',+. " On the other hand,the minimum number of individual horizontal Ranney intake wells required for the site-specific conditions of the project is 24. This number was determined considering: the total intake capacity of the desalination facility is approximately 100 MGD;the hydrogeological conditions are very favorable and therefore an individual well could yield five MGD of intake water;and that an additional 20 percent well standby capacity would be incorporated in the intake system design to account for well capacity decrease over the 30-year period of the useful life of the project and for well downtime due to routine maintenance (100 MGD/5 MGD per well)x 1.2 = 24). For 24 Ranney wells with an individual capacity of five MGD each,and a minimum distance between the individual wells of 400 feet, the footprint would be 9,600 feet long (400 feet x 24 wells = 9,600 feet (approx. 1.8 miles). The minimum area needed for construction of the horizontal beach wells would be (100 feet[construction zone]x 9,600 feet= 960,000 square feet[22 acres]). Figure 7-3, HORIZONTAL (RANNEY)BEACH WELL SYSTEM ILLUSTRATION,shows the approximate size and configuration of a horizontal intake well system for a 10 MGD seawater desalination facility with five intake wells. Figure 7-4, CONCEPTUAL HORIZONTAL (RANNEY) WELL INTAKE CONFIGURA TIONA THUNTINGTON BEACH, gives a general representation of the shoreline area in front of HBGS that would be impacted by the construction of a Ranney well intake system. The portion of the seashore shown in the figure is approximately 3,000 feet long; as discussed previously, total length of shoreline that would be required would be approximately 1.8 miles. The network of wells would also need an extensive piping system in order to link the individual wells with the desalination facility. City of Huntington Beach April 5, 2005 7-14 n I Seawater Desalination Project at Huntington Beach 7.0 ALTERNATIVES Draft Recirculated Environmental Impact Report n Figure 7-3 HORIZONTAL (RANNEY) BEACH WELL SYSTEM ILLUSTRATION r-i k.. ' i a ,s4✓t- �' +Sy - 3-A " a `:�# 0', c nty..atxS' `' k i"' f"nz x & a"on-S i fines e 11 e s A minimum secuhiy fence _ . ,� h 4 s 4,nk d m HCCBSS��, '`"�' ' a' f`I service vehicle 3, Figure 7-4 CONCEPTUAL HORIZONTAL (RANNEY)WELL INTAKE CONFIGURATION AT HUNTINGTON BEACH Desalination Facility n W high berm divider Oil ran" sr Huntington Beath er � WRIZZ"'N" Pacl>ic Coast Highway, 406 ft ;� n t �.>�i`� 'sm{ „,x c,"e' '" �''", �'_ .,'� _ a •24 Beach intake we115:.=...:." •8 wells visible in this view m �� � r t• City of Huntington Beach April 5, 2005 7-15 - Seawater Desalination Project at Huntington Beach 7.0 ALTERNATIVES Draft Recirculated Environmental Impact Report Ranney beach well drilling techniques do allow for the placement of wells further inland (e.g. away from the beach in a developed area), thus moving aesthetic and recreational impacts from the beach to inland uses. Regardless,the number of wells necessary fora 50 mgd desalination facility limit the feasibility of utilizing wells for a large-scale project. Infiltration Galleries Infiltration galleries are typically implemented when conventional horizontal or vertical intake wells cannot be used due to unfavorable hydrogeological conditions. For example, they are suitable for intakes where the permeability of the underground soil formation is relatively low, or in the case of river or seashore bank filtration, where the thickness of the beach or the onshore sediments is insufficient to develop conventional intake wells. Infiltration galleries consist of an excavated trench that is filled with filtration media of size and depth similar to that of the granular media filters used for conventional water treatment plants. Vertical or horizontal collector wells are installed in equidistance(usually 100-200 feet)inside the filter media. Typically the capacity of a single collection well is 0.2-2.5 MGD. The most common type of infiltration gallery is a horizontal well collection system with a single trench (refer to Figure 7-5, INFILTRATION GALLERY). The media in the infiltration gallery is configured in three distinctive layers: a bottom layer of sand media of approximately three to six feet,followed by a four to six foot layer of graded gravel pack surrounding the horizontal well collector screens;topped by a 20-to 30- foot layer of sand. The horizontal well collector screens are typically designed for inflow velocity of 0.1 feet per second or less. Figure 7-5 INFILTRATION GALLERY Intoke PUMP Intake N,ells to TreotMent PUMP house plont 5 f ° �i7 , - Water level Water-, - o Y q �IaE $ v Sod be gd j^ ;F 4 fr e a Grad rove I bed De pth of t 'gallery trench rizantoI gallery o Collector Hollection Sys screens City of Huntington Beach April 5, 2005 7-16 Seawater Desalination Project at Huntington Beach 7.0 ALTERNATIVES Draft Recirculated Environmental Impact Report The infiltration galleries could be designed either similar to conventional rapid sand filters (if the natural ocean water wave motion can provide adequate backflushing of the infiltration gallery media) or could be constructed as slow sand filtration systems,which have at least a 30-feet layer of sand overlying the collection well screens. For the site-specific conditions of the proposed Seawater Desalination Project at Huntington Beach, the minimum number of individual collection wells required for the gallery is 48. This number was determined considering: the total intake capacity of the desalination facility is p ty ty � approximately 100 MGD;the hydrogeological conditions allow the individual well to yield 2.5 MGD of intake water;and that an additional 20 percent well standby capacity is incorporated in the intake system design to account for well capacity decrease over the 30-year period of the useful life of the project and for well downtime due to routine maintenance ([100 MGD/2.5 MGD per well] x 1.2 = 48 individual collection wells). , The infiltration gallery wells have to be located on the seashore, in close vicinity (usually within several hundred feet)of the ocean. For 48 collection wells of individual capacity of 2.5 MGD,and a minimum distance between the individual wells of 200 feet,the footprint of the beach well shoreline area would be 9,600 feet long (200 feet x 48 wells = 9,600 feet), or approximately 1.8 miles. The minimum area of shoreline needed for construction of the horizontal beach would be (100 feet [construction zone] x 9,600 feet = 960,000 square feet, or 22 acres). The network of wells would also need an extensive piping system in order to link the individual wells with the desalination facility. A feasibility study prepared for a 25 mgd seawater desalination facility in Corpus Christi,Texas,also concluded that horizontal infiltration galleries were not a feasible intake alternative because the ?" "significant cost and land requirements make them impractical and economically infeasible.'3 Seabed Filtration System r Seabed filtration intake systems consist of a submerged slow sand media filtration system located at the bottom of the ocean in the near-shore surf zone, which is connected to a series of intake wells (see discussion on vertical and horizontal intake wells above)located on the shore(see Figure 7-6, SEABED INFILTRATION SYSTEM). n Seabed filter beds are sized and configured using the same design criteria as slow sand filters. The i design surface loading rate of the filter media is typically between 0.05 - 0.10 gpm/square foot. Approximately one inch of sand is removed form the surface of the filter bed every six to 12 months for a period of three years, after which the removed sand is replaced with new sand to its original depth. As seen in Figure 7-6, the ocean floor has to be excavated to install the intake piping of the c wells. These pipes are buried at the bottom of the ocean floor excavation pit (see Figure 7-7, SEABED INFILTRATION SYSTEM CROSS-SECTION). + Currently, there are no existing large seawater desalination facilities (with capacity over five MGD) using seabed filtration intake systems. The largest seawater desalination facility with a seabed r , filtration intake system currently under construction is the 13.2 MGD Fukuoka District RO facility in Japan. This plant is planned to be operational in late 2005. The Fukuoka seawater desalination facility seabed intake area is 312,000 square feet. 3 � Large Scale Demonstration Desalination Feasibility Study. City of Corpus Christi,August 2004. This document is available at http://www.cctexas.com/files/g17/LSD%20Report%20Aug%2004%2Epdf. City of Huntington Beach April 5, 2005 7-17 Seawater Desalination Project at Huntington Beach 7.0 ALTERNATIVES Draft Recirculated Environmental Impact Report Figure 7-6 SEABED INFILTRATION SYSTEM to Pump hoes, Plant Ment • �r Pump',,t r Intake well ahw nd r Filtro lion bed 3 a COIIeCtOf screens Figure 7-7 SEABED INFILTRATION SYSTEM CROSS-SECTION _�. Flow Meter tS l�s tq • •�1 f i� f` �9 y Or real Sa�1-Lay}r pump Reaced S d La 1 1 Gradeig;"Crush Stone L er: I *?t Pore ater Gonnecttrtg Pipe TMt evei Gauge YNLt Press Jre r �_ •c•� ,Intake 1Ne11 �a+. Veloc Gauge olfecti City of Huntington Beach April 5, 2005 7-18 Seawater Desalination Project at Huntington Beach 7.0 ALTERNATIVES Draft Recirculated Environmental Impact Report For the source water intake feed rate of 100 MGD (70,000 gpm) needed for the Seawater Desalination Project at Huntington Beach,and a typical seabed design surface loading rate of 0.07 gpm/square foot, the total area of the ocean floor needed to be excavated to build a seabed intake system of adequate size is 23 acres(70,000 gpm/0.07 gpm per square foot= 1,000,000 square feet =23 acres). Assuming that the seabed is 200 feet wide(a typical length for a collector screen),this translates to an impact on the ocean floor of approximately one linear mile (1,000,000 square feet /200 feet = 5,000 feet) (see Figure 7-8, SEABED INFILTRATION SYSTEM APPROXIMATE IMPACT AREA). The network of wells would also need an extensive piping system in order to link the individual wells with the desalination facility. Figure 7-8 SEABED INFILRATION SYSTEM APPROXIMATE IMPACT AREA A� e .. P"N roc. vrd"� i °w N 4 �w1 r. s y. 3,,zca tip t r 41 k� nl ah.• > " ' art,* s IV d a., 4.+. "J. e Alternative Intake System Environmental Analysis All intake system alternatives reviewed above would extract the seawater supply by slowly withdrawing the water from the surrounding sand. Water velocity at the seawater/sand interface would be negligible. Since the seawater is filtered through the sand,there would be no entrainment of marine organisms. Beach well water typically has a very low dissolved oxygen (DO) concentration. The DO concentration of this water is usually less than two mg/l, and it often varies between 0.2 and 1.5 mg/L. The RO treatment process does not add an appreciable amount of DO to the intake water. r Therefore, the RO system product water and concentrated seawater to be discharged have the same DO concentration as the source water. The low DO concentration in the product water would require either product water re-aeration or would result in significant use of chlorine. In addition,the r low DO concentration in the discharge would not be in compliance with the EPA's daily average and minimum DO concentration discharge requirements of four mg/L and five mg/L, respectively. In comparison, the project discharge would have a DO concentration of five to eight mg/L,and would be in compliance with the California State Water Resources Control. Board Ocean Plan regulations and in turn would comply with all EPA requirements. City of Huntington Beach April 5, 2005 7-19 Seawater Desalination Project at Huntington Beach 7.0 ALTERNATIVES Draft Recirculated Environmental Impact Report The discharge water resulting from a beach well intake alternative could cause oxygen depletion and significant stress to aquatic life. The discharge water would have to be re-aerated before it was released into the ocean. For a desalination facility of the size of the proposed project,the amount of air and energy to increase the DO concentration of the discharge from one mg/L to four mg/L would be significant and would have a measurable effect on potable water production costs. Discharge of this low DO concentrate to a wastewater treatment facility would also result in significant additional power use to aerate this concentrate prior to discharge. Construction of any of the alternative intake well facilities necessary to support the project would require the disruption of coastal areas within Huntington Beach and would temporarily impact coastal and marine biological resources in the site vicinity. The beach excavation required for any alternative intake system has the potential to negatively impact shore birds, marine mammals,and intertidal organisms in the area of the construction. Although opportunities may exist to construct Ranney wells away from the beach (further inland), the construction of approximately 24 well sites within coastal communities would create substantial construction and long-term(land use,aesthetic, energy)operational impacts. Obtaining construction permits and easements would be a formidable task due to the sensitive nature of this location. In addition, in the case of the seabed filtration intake system,excavation of a 23 acre/one-mile long by 200-foot wide strip of the ocean floor in the surf zone to install a seabed filter system of adequate size to supply the desalination facility would result in a significant impact on the benthic marine organisms in this location (Figure 7-8). The entire benthic ecosystem in the area covered by the seabed filter would be removed as part of the excavation process. The material removed would require disposal elsewhere, thus creating additional environmental impacts. The dredging of the sea floor and establishment of a layer filter bed would disrupt normal public use of the beach and surf zone in this area during construction and the periodic replacement of the layered filter media. Furthermore, construction activities for the alternative subsurface intake systems would cause temporary disruption to local tourist and public use of the beach. The movements of materials and equipment needed for the project would restrict road traffic. The aesthetic and noise impacts of construction activities,as well as a probable reduction in public access to the area,would negatively impact businesses in the vicinity of the construction. The pipeline network necessary to link the intake well system with the desalination facility would be extensive and would require beach shoreline excavation, trenching and subsequent burial of the system. After the completion of construction, the presence of the structures necessary to house the pumps and other equipment needed for the operation of an alternative beach well intake system would cause additional impacts (primarily aesthetic). The wells and appurtenances would permanently and negatively alter the aesthetic characteristics of the beach shoreline (access roads, fences, electrical supply equipment, etc.). Although the above-grade pump house could be designed in virtually any architectural style,these facilities and the necessary service roads would change the visual landscape of the seashore(see Figure 7-3). Taking into consideration that the desalination facility intake equipment and source water must be protected from acts of vandalism and terrorism,the individual beach wells would have to be fenced-off or otherwise protected from unauthorized access. The large and tall fenced-off beach well concrete structures would have a limited aesthetic appeal. Since the City of Huntington Beach public beaches are visually sensitive areas,the installation of large beach wells would affect recreation and tourism,and would negatively alter beach appearance and character(see Figure 7- 3). None of these potential environmental impacts are associated with the use of the cooling water system from the existing HBGS as source water for the project. The proposed intake system would not alter the operations of the HBGS intake or discharge system, and it would provide a more than City of Huntington Beach April 5, 2005 7-20 r_1 Seawater Desalination Project at Huntington Beach 7.0 ALTERNATIVES Draft Recirculated Environmental Impact Report n adequate supply of source water. None of the proposed alternative intake systems would be an acceptable substitute to the proposed use of the existing HBGS cooling water system as the supplier of source water for the Seawater Desalination Project at Huntington Beach. Alternative Project Discharge Alternative Protect Discharge Location The only existing ocean discharge facility(besides the HBGS outfall)in the project site vicinity is the 120-inch,4.5-mile ocean outfall utilized at the OCSD regional wastewater treatment facility(located approximately 1.5 miles southeast of the proposed project site). The City inquired with OCSD regarding the feasibility of discharging the proposed desalination project's concentrated seawater discharge (50 mgd)through the OCSD's outfall. In a response letter dated June 24, 2004, OCSD indicated that, based on hydraulic discharge capacity performed for the OCSD's 1999 Strategic Plan, capacity within the OCSD outfall is not available for the proposed desalination project. \ Analysis of future wastewater projections shows that the capacity of the 120-inch outfall is anticipated to be exceeded once every three years by the year 2020, requiring the use of the District's emergency one-mile ocean outfall.4 As such,the use of the OCSD outfall for concentrated seawater discharge is not considered a feasible alternative to the proposed project. n Alternative Project Discharge Design - Diffuser All hydrodynamic analysis performed for the EIR is based on the proposed project utilizing the r7 existing HBGS outfall infrastructure. The analysis determines the dilution and dispersion of the concentrated sea salts that would be added to the discharge stream by the proposed desalination facility,which is discussed throughout this document as the proposed project. Yet, another outfall alternative would be to install a diffuser on the existing discharge tower. The most practical diffuser concept is a velocity cap retrofitted to the discharge tower, identical to the one that already exists on the infall tower. A velocity cap would provide four lateral diffuser ports with rectangular cross section, producing four horizontal discharge jets (assuming the jets are oriented in the cross-shore and along shore directions, parallel to the walls of the discharge tower). f As a worst case scenario,the velocity cap diffuser would cause faster dilution of the sea salts in the water column beyond 600 feet from the outfall, but would result in higher salinities on the seafloor within 600 feet from the outfall. As further described in Appendix W, SUPPLEMENTAL REPORT ON THE EFFECTS OF RETROFITTED DIFFUSER ON THE DISCHARGE OUTFALL FOR THE PROPOSED SEAWATER DESALINATION PROJECT AT HUNTINGTON BEACH, the diffuser would increase maximum seabed salinity at the base of the outfall from 48.3 ppt to 50.0 ppt for the Low-Flow event scenario, and the benthic area experiencing a 10 percent increase in salinity or r more would increase from 15.6 acres to 24.5 acres. Higher bottom salinities with the diffuser is caused by the horizontal diffuser jets permitting only the lower half of the water column to engage in the dilution volume of the heavy discharge. A diffuser would provide an increased dilution factor at the shoreline, but a diffuser would also increase the seabed salinity within 600 feet of the outfall because only half of the water column would be engaged for dilution and because discharge configuration ejects the concentrated seawater away from the seabed. Thus, the proposed project's current outfall configuration allows for a more rapid dilution of the concentrated sea salts than the diffuser. r 4 Letter, Jim Herberg, P.E.,Orange County Sanitation District,June 24,2004. City of Huntington Beach April 5, 2005 7-21 Seawater Desalination Project at Huntington Beach 7.0 ALTERNATIVES Draft Recirculated Environmental Impact Report i 7.5 "REDUCED FACILITY SIZE" ALTERNATIVE The proposed desalination project is currently designed to incorporate reverse osmosis (RO) technology to remove impurities from seawater to produce approximately 50 mgd (56,000 AFY)of potable water for distribution to local water agencies.One alternative to the proposed project would be to reduce the output of project water to approximately 25 mgd. The design and operation of the proposed desalination facility would generally remain the same. However, this alternative would reduce the size of the facility,the amount of seawater required to produce water,and the amount of concentrated seawater discharged back into the HBGS outfall. The 25 mgd alternative would not significantly reduce potential environmental impacts when compared to the proposed project. In addition,this alternative would result in a substantial decrease in the amount of desalinated water that could be produced, and thus a substantial increase in the cost of the desalinated water. Consequently, the 25 mgd alternative would not achieve the project objectives to provide a sufficient amount of water that would meet the future water needs projected by Orange County water purveyors, and would reduce overall water supply reliability that is sustainable and independent of climatic conditions. A discussion of potential impacts is discussed below. Land Use/Relevant Planning Potential impacts in regards to land use/relevant planning would be similar to the proposed project, because the desalination facility location and general layout would not change substantially. The zoning requirements would not change. A 25 mgd facility would use three to four acres less area than a 50 mgd facility. The height and architectural profile of all key buildings and other structures (storage tanks, pump stations,etc.)would remain the same. Facility capacity reduction would only impact the footprint of the buildings, and would not affect their appearance. Geology and Soils Geology and soils impacts would be very similar to those of a 50 mgd facility because the depth of the facilities and associated excavation activities would not change with facility capacity reduction. Grading would be similar in both cases because of the need to remove the existing unused fuel oil storage tanks. However, because of overall reduction of the facility footprint,the construction of a 25 mgd facility as compared to a 50 mgd facility would require approximately 30 percent less earthwork and soil transportation, which in turn would result in reduction of the number of construction truck trips and traffic. Construction traffic is temporary in nature, and the difference between this alternative and the proposed project is not anticipated to be significant. Hydrology, Drainage and Storm Water Runoff The proposed project and the Reduced Facility Size alternative would have similar impacts in regards to hydrology,drainage, and storm water runoff. Both projects would incorporate an on-site drainage system to properly dispose of runoff. Although the Reduced Facility Size alternative would have a footprint approximately 30 percent smaller than the proposed project, impacts in this regard are not anticipated to substantially differ from the proposed project. Air Quality Long-term air quality impacts resulting from the Reduced Facility Size alternative would be slightly lower than the proposed project. As the project would produce a smaller amount of product water, less electrical energy would be necessary to operate on-site desalination facilities and off-site product water pump stations. In addition,employee and truck delivery operations may be reduced, City of Huntington Beach April 5, 2005 7-22 7 Seawater Desaiination Project at Huntington Beach 7.0 ALTERNATIVES i Draft Recirculated Environmental Impact Report thus resulting in slightly lower mobile air emissions. However,as the number of employee/truck trips would be negligible under either scenario,and both the proposed project and Reduced Facility Size alternative would be subject to the Regional Clean Air Incentives Market(RECLAIM),no substantial difference in impacts is anticipated. Noise I Impacts in regards to noise are anticipated to be slightly reduced in comparison to those of the proposed project. As stated above,the design and operation of the proposed desalination facility would generally remain the same, but with a reduced amount of noise-generating equipment. It is anticipated that the same noise-generating equipment (pumps, compressors, etc.) and noise s attenuation measures would be incorporated for the 25 mgd alternative. In addition, the level of noise generated by mobile sources(automobiles driven by on-site employees,delivery trucks)would ; not substantially change, as the facility operations would generally remain the same. ? Public Services and Utilities Implementing a 25 mgd desalination facility is anticipated to have similar impacts in regards to public services and utilities as the proposed project site. As stated above,the design and operation of the proposed desalination facility would generally remain the same. In addition, impacts to public services and utilities such as police/fire service, solid waste, sewer, drainage,and electricity would not vary significantly from the proposed 50 mgd project. Aesthetics/Light & Glare As stated above, the design and operation of the proposed desalination facility would generally e7 remain the same. It is expected that potential impacts in regards to aesthetics, light,and glare on a 25 mgd alternative would be similar in nature to the proposed 50 mgd project implementation. Hazards and Hazardous Materials Impacts in regards to hazards and hazardous materials are anticipated to be similar to those of the , proposed project. The same types of hazardous materials would be required for operation of a Reduced Facility Size alternative. The nature in which hazardous materials would be stored, handled, and used for project operation is not expected to change for the 25 mgd alternative implementation. `) Construction Related Impacts i Implementation of the Reduced Facility Size alternative would result in slightly reduced construction- related impacts in comparison to the proposed project(primarily at the proposed desalination facility site). At the desalination facility site(which would be reduced in size by approximately 30 percent), n impacts in regards to hydrology/drainage/storm water runoff,air quality, noise,and traffic would be incrementally reduced due to lower amounts of on-site grading, import/export haul trips and employee worker trips. As construction for the off-site booster pump stations and pipelines would not vary considerably for smaller product water pipelines and pump stations,impacts are anticipated to be similar to the proposed project. It is not anticipated that implementation of the Reduced Facility Size alternative would reduce the unavoidable significant impact in regards to construction- related NOX to a less than significant level. : I r-, F City of Huntington Beach April 5, 2005 7-23 Seawater Desalination Project at Huntington Beach 7.0 ALTERNATIVES Draft Recirculated Environmental Impact Report Ocean Water Quality and Marine Biological Resources Like the proposed project,the 25 mgd alternative would not change the required flows or operation of the HBGS cooling water system. The impact of the proposed project(50 mgd facility)on ocean water quality and marine life has been found to be less than significant (refer to Section 5.10, OCEAN WATER QUALITYAND MARINE BIOLOGICAL RESOURCES). Construction of a 25 mgd facility as an alternative to a 50 mgd facility is not anticipated to result in a measurable difference in impacts to the ocean environment surrounding the HBGS outfall. The radius of the zone of initial dilution is likely to be incrementally reduced. Asa result, impacts in regards to ocean water quality and marine biological resources are anticipated to be slightly reduced in comparison to the proposed project. Product Water Quality The product water quality of the 25 mgd desalination facility would be the same as that of a 50 mgd facility. Identical chemical conditioning and corrosion control and monitoring would be implemented. Therefore, a reduction in the size of the proposed project would have no adverse effect on the product water quality. System integration of desalinated water with the existing potable water distribution system of Orange County would be the same for both 25 and 50 mgd projects. However, one of the benefits of the proposed project (a reduction in the overall salt content of existing potable water in Orange County through the introduction of desalinated water)would be reduced if the product water output of the project were reduced to 25 mgd. Conclusion While the Reduced Facility Size alternative may result in slightly reduced impacts in comparison to the proposed project,the 25 mgd alternative would result in providing water at a cost that would not be acceptable to Orange County water purveyors, and would not produce a sufficient amount of desalinated water to meet projected future demand. Implementation of the 25 mgd alternative would not avoid the project's identified unavoidable construction related air quality impact, and would reduce the water quality benefits of the project as proposed. As such, this alternative is not presently under consideration. 7.6 "ENVIRONMENTALLY SUPERIOR" ALTERNATIVE None of the above alternatives are considered "environmentally superior"to the proposed project, except for the "No Project" Alternative. In this case, CEQA requires identification of an "environmentally superior' alternative from among the other alternatives. Implementation of the project on an alternative site, while dependent on site-specific variables, is not anticipated to significantly reduce impacts,as alternative site implementation is expected to result in overall similar or greater environmental impacts. The"Alternative Ownership" alternative would result in exactly the same environmental impacts as the proposed project. A hypothetical reduction in facility size can be argued to be"environmentally superior', based superficially on the reduction in facility size and corresponding reduction in traffic, air and noise impacts. However, reducing facility size and output would not substantially reduce any significant impacts. The other alternative project design alternatives(alternative desalination methods and alternative intake facilities),while offering some environmental benefits, result in greater environmental impacts overall. Consequently, and in accordance with the mandate of CEQA, the "Alternative Project Design — Reduced Facility Size" alternative is selected as the environmentally superior alternative in comparison to the proposed project. City of Huntington Beach April 5, 2005 7-24 i i � 8.0 EFFECTS FOUND NOT � TO BE SIGNIFICANT 1 r 8.0 EFFECTS FOUND NOT TO BE SIGNIFICANT Through preparation of the previously circulated Draft EIR, certain impacts of the project were found to be less than significant due to the inability of a project of this scope to create such impacts or the absence of project characteristics producing effects of this type. The following section provides a brief description of effects found not to be significant or less than significant, based on the previously circulated EIR preparation process. 8.1 EFFECTS FOUND NOT TO BE SIGNIFICANT 1. LAND USE AND PLANNING. Would the project. a) Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? No Impact. The City of Huntington Beach General Plan land use designation for the proposed desalination project site is "Public (P)" and is zoned AIG-O-CZ-FP2 (General Industrial with Oil, Coastal Zone, and Flood Plain Overlays). Off-site improvements are permitted within the public rights-of-way and easements. Proposed uses for the project site will be consistent with the General Plan and Zoning Ordinance. However, the EIR addresses relevant planning programs in Section 5.1, LAND USE/RELEVANT PLANNING and throughout the EIR. b) Physically divide an established community? 1 No Impact. The project site has been previously developed, and is surrounded by industrial uses. The project site is proposed to become a desalination facility producing 50 mgd of potable water. Off-site infrastructure would be subsurface and would not otherwise divide a community. Project implementation is not of a scope or nature such that it would physically divide an established community or disrupt the physical arrangement of the City. There are no anticipated significant long-term land use or planning impacts. However, the EIR addresses potential land use impacts associated with short-term remediation/construction operations, including lighting, noise, dust, hazards and hazardous materials, and traffic (Section 5.9, CONSTRUCTION RELATED IMPACTS). c) Conflict with any applicable habitat conservation plan or natural community conservation plan? No Impact. The proposed off-site OC-44 booster pump station would be situated adjacent to, but not within, a County of Orange Resource Preservation Easement (a designated Natural Community Conservation Plan/Habitat Conservation Plan [NCCP/HCP] area). The pump station would be constructed completely underground. As such, the project would not conflict with any local policies or ordinances protecting biological resources. No impacts are anticipated in this regard. City of Huntington Beach April 5, 2005 8-1 n Seawater Desalination Project at Huntington Beach 8.0 EFFECTS FOUND Draft Recirculated Environmental Impact Report NOT TO BE SIGNIFICANT 2. POPULATION AND HOUSING. Would the project. a) Displace substantial numbers of existing housing, necessitating the construction of replacement housing elsewhere? No Impact. The proposed project will not displace people or homes, as the project area does not contain residential units. The proposed project site is within a primarily industrial area. The Huntington-By-The-Sea and Cabrillo Mobile Home Parks are located approximately 2,000 feet to the west. No housing in this mobile home park will be displaced by the proposed project. The proposed project will not alter proposed land uses and complies with the City's General Plan. No impacts related to the displacement of the population are anticipated. b) Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere? r, No Impact. Refer to Response 2b, above. 3. GEOLOGY AND SOILS. Would the project. a) Result in substantial soil erosion, loss of topsoil, or changes in topography or unstable soil conditions from excavation, grading, or fill? r Less Than Significant Impact. Potential significant soil erosion in the City of Huntington Beach is limited to the seaward facing bluffs along the coast. These areas r, are subject to erosion during periods of extremely high tides. The proposed project site is not in this region. However, grading and trenching during the construction phase of the project would slightly increase the potential for erosion. In addition, the interior 10 to ri 15-foot soil containment berms surrounding the fuel storage tanks will be removed to create a suitable building pad for the proposed desalination facility, and substantial excavation will be required for the proposed underground water storage tank. In accordance with the City's Standard Conditions of Approval, a detailed soils analysis will be prepared for the subject site, the recommendations of which will mitigate any impacts to less than significant levels. In addition, an erosion control plan shall be prepared for the proposed project. These issues are also analyzed in Section 5.2, GEOLOGY, SOILS, AND SEISMICITY. b) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water? r No Impact. No septic tanks or alternative wastewater disposal systems are proposed. Therefore, no impacts in this regard are expected. r 4. HYDROLOGY AND WATER QUALITY. Would the project. a) Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level(e.g., the production rate of pre-existing nearby wells would drop to a level which would not support existing land uses or planned uses for which permits have been granted)? City of Huntington Beach April 5, 2005 8-2 fSeawater Desalination Project at Huntington Beach 8.0 EFFECTS FOUND Draft Recirculated Environmental Impact Report NOT TO BE SIGNIFICANT Less Than Significant Impact. Project implementation would not result in the depletion of groundwater supplies or interference with groundwater recharge since the project does not involve the extraction of groundwater from the site. Groundwater wells supply 76% of the City of Huntington Beach's water. The proposed project would consume a nominal amount of water for short-term construction and long-term employee use. However, the project is proposed to produce 50 mgd of potable water to be distributed within the region, providing a beneficial impact to the local water supply. Less than significant impacts are anticipated in this regard. b) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of stream or river, in a manner which would result in substantial erosion or siltation on-or off-site? Less Than Significant Impact. The site has been previously developed and is void of existing drainage courses such as rivers or streams. The project will be in compliance with all Santa Ana Regional Water Quality Control Board (RWQCB) requirements and will obtain a National Pollution Discharge Elimination System (NPDES) Permit. Use of Best Management Practices (BMP's) will ensure that all on-site surface water will be directed to appropriate storm drain facilities, in accordance with standard drainage facility design requirements. The proposed project site is in the vicinity of an Orange County Flood Control District (OCFCD) flood control channel, the Santa Ana River, and Pacific Ocean, in an area designated as a 100-year flood hazard area by the Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map. These issues are further examined in Section 5.3, HYDROLOGY, DRAINAGE, AND STORM WATER RUNOFF. c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on-or off-site? Less Than Significant Impact. Refer to Response 4b, above. d) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? Less Than Significant Impact. Refer to Response 4b, above. e) Otherwise substantially degrade water quality? Less Than Significant Impact. The project will be in compliance with all Santa Ana RWQCB requirements and will obtain a NPDES Municipal Permit. Typical urban water quality pollutants usually result from motor vehicle operations, oil and grease residues, fertilizer/pesticide uses, and careless material storage and handling. Use of Best Management Practices (BMP's) will ensure that all on-site surface water will be directed to appropriate storm drain facilities. In addition, a Water Quality Management Plan in accordance with NPDES standards will be prepared for the proposed project. With the incorporation of standard design measures, impacts are expected to be reduced to less than significant levels. City of Huntington Beach April 5, 2005 8-3 Seawater Desalination Project at Huntington Beach 8.0 EFFECTS FOUND j Draft Recirculated Environmental Impact Report NOT TO BE SIGNIFICANT Place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map? r No Impact. Although the subject site is located within a FEMA-designated 100-year flood hazard area, no housing is proposed to be incorporated into the project. No impacts are anticipated in this regard. g) Inundation by seiche, tsunami, or mudflow? Less Than Significant Impact. Previous evaluations put the tsunami potential for the City of Huntington Beach at very low. Of more concern are seiche waves caused by tsunamis captured and reflected within the enclosed area of an inner harbor, such as Huntington Harbour. The project site is not in the vicinity of a harbor. In addition, the site vicinity is void of land features capable of producing mudflow. Therefore, inundation by seiche, tsunami, or mudflow is not anticipated to occur. However, depending on the ultimate grade of the proposed site, there is a potential for seiches within the adjacent Huntington Beach Channel. The magnitude of seiche waves impacting the project site are anticipated to be lower than that of a tsunami, given the frictional energy dissipation of water running along the bottom and walls of the channel. This issue is further discussed in Section 5.3, HYDROLOGY, DRAINAGE, AND STORM WATER RUNOFF. 5. AIR QUALITY. Would the project. r a) Violate any air quality standard or contribute substantially to an existing or projected air quality violation? Less Than Significant Impact. The proposed project may result in temporary construction-related emissions and long-term air quality effects. However, the project t will be consistent with the City's General Plan and impacts in this regard have been adequately analyzed in the General Plan EIR. These impacts are addressed in the EIR within the air analysis section (Section 5.4, AIR QUALITY). n b) Conflict with or obstruct implementation of the applicable air quality plan? Less Than Significant Impact. Refer to Response 5a, above. c) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality , standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)? n Less Than Significant Impact. Refer to Response 5a, above. 6. TRANSPORTATION/TRAFFIC. Would the project: , a) Cause an increase in traffic which is substantial in relation to the existing traffic load and capacity of the street system (i.e., result in a substantial increase in either the number of { vehicle trips, the volume to capacity ratio on roads, or congestion at intersections)? Less Than Significant Impact n i City of Huntington Beach April 5, 2005 8-4 Seawater Desalination Project at Huntington Beach 8.0 EFFECTS FOUND Draft Recirculated Environmental Impact Report NOT TO BE SIGNIFICANT Short-term Traffic Impacts: The proposed project's traffic impacts can be separated into short-term impacts due to remedial and construction activities and long-term impacts from project operations. Short-term traffic impacts will result from increased trips of vehicles involved in the remediation and construction phases. However, in accordance with the City's Standard Conditions of Approval, a truck and construction vehicle routing plan will be prepared for the project to reduce any short-term traffic impacts to less than significant levels. These impacts are further analyzed in Section 5.9, CONSTRUCTION RELATED IMPACTS. Long-term Traffic Impacts: The City's recently adopted "Transportation System Needs Analysis 2000-2010" (September 12, 2000, approved by City Council October 2, 2000) indicates that segments of Newland Street and Hamilton Avenue, which surround the project site, will be deficient (LOS D or F) in 2010, assuming estimated growth in the area and non improvements to the streets. However, the proposed seawater desalination facility is expected to employ approximately 18 people, with a staff of five to seven on-site Monday through Friday, and a minimum of two people on-site during swing shifts, graveyard shifts, and weekends. In addition, project operation would require approximately three truck trips per day. The number of trips generated by the project on a long-term basis is considered negligible, and impacts in this regard are not anticipated to be significant. b) Exceed, either individually or cumulatively, a level of service standard established by the county congestion management agency for designated roads or highways? Less Than Significant Impact. Refer to Response 6a, above. c) Result in a change in air traffic patterns, including either an increase in traffic levels or a change in location that results in substantial safety risks? No Impact. Although the City of Huntington Beach is included within the Airport P 9 Y 9 P Environs Land Use Plan (AELUP) of Orange County, the proposed project site is located more than 20,000 feet from the Armed Forces Reserve Center in the City of Los Alamitos. In addition, the height of future structures would not penetrate navigable airspace or otherwise impact air traffic patterns. No impacts are anticipated in this regard. d) Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? No Impact. Implementation of the proposed project plan may result in a nominal increase in vehicle trips. Access to the subject site, currently provided via Newland Street, is not proposed to change. No impacts are anticipated in this regard. e) Result in inadequate emergency access? Less Than Significant Impact. The proposed project shall be in compliance with all City of Huntington Beach emergency response and/or emergency evacuation plans. The project site is proposed to utilize the existing AES Huntington Beach Generating Station (HBGS) entrance located along Newland Street. Incorporation of required evacuation plans and procedures shall be incorporated into site design and the project will comply with applicable design standards. Temporary construction activities for City of Huntington Beach April 5, 2005 8-5 7 Seawater Desalination Project at Huntington Beach 8.0 EFFECTS FOUND Draft Recirculated Environmental Impact Report NOT TO BE SIGNIFICANT pipeline installation will ensure adequate emergency access at all times. Impacts in this regard are anticipated to be less than significant. Result in inadequate parking capacity? Less Than Significant Impact. Implementation of the proposed project would create a ' nominal demand for parking during long-term facility operations, as approximately five to seven employees will be on-site per shift on weekdays, with fewer on-site during swing shifts, graveyard shifts, and weekends. The short-term construction process may create r, a temporary substantial demand for parking. However, the City's Standard Conditions of Approval require that on-site parking be provided for all construction workers and equipment, thereby eliminating short-term construction impacts (refer to Section 5.9, CONSTRUCTION RELATED IMPACTS). No significant impacts are anticipated in this regard. g) Conflict with adopted policies, plans, or programs supporting alternative transportation (e.g., bus turnouts, bicycle racks)? No Impact. The proposed project would incorporate the goals and policies of the City of r' Huntington Beach General Plan and would not conflict with any other known policies. No impacts are expected in this regard. 7. BIOLOGICAL RESOURCES. Would the project: a) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? n Less Than Significant Impact. Project implementation is not anticipated to interfere with the movement or corridors of any native resident or migratory fish or wildlife species, nor impede the use of native wildlife nursery sites. However, potential impacts _ of the desalination facility's discharge into the Pacific Ocean via the HBGS outfall pipe are further analyzed within Section 5.10, OCEAN WATER QUALITY AND MARINE BIOLOGICAL RESOURCES. b) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? No Impact. The proposed off-site OC-44 booster pump station would be situated adjacent to, but not within, a County of Orange Resource Preservation Easement (a designated Natural Community Conservation Plan/Habitat Conservation Plan r- [NCCP/HCP] area). The pump station would be constructed completely underground. As such, the project would not conflict with any local policies or ordinances protecting biological resources. No impacts are anticipated in this regard. c) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? f- No Impact. Refer to Response 7b, above. City of Huntington Beach April 5, 2005 8-6 Seawater Desalination Project at Huntington Beach 8.0 EFFECTS FOUND Draft Recirculated Environmental Impact Report NOT TO BE SIGNIFICANT 8. MINERAL RESOURCES. Would the project. a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state? No Impact The project site is located within a fully developed urban setting. No classified or designated mineral deposits of statewide or regional significance are known to occur within the project area. No impacts are anticipated in this regard. b) Result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? No Impact. The project site is located within a fully developed urban setting. The project site has not been delineated as an important mineral resource recovery site within the City's General Plan. No impacts are anticipated in this regard. 9. HAZARDS AND HAZARDOUS MATERIALS. Would the project. a) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? No Impact. No existing or proposed school facilities are located within a one-quarter mile radius of the desalination project site. Pipeline and pump station construction, which may occur in proximity to a school, is not expected to involve emission or handling of hazardous materials other than that typical of public works construction. Therefore, no impacts in this regard are anticipated to occur. b) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? No Impact. Although hydrocarbon contamination is known to exist on-site, the subject site is not included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. Therefore, no impacts are anticipated in this regard. Impacts in this regard are further analyzed in Section 5.8, HAZARDS AND HAZARDOUS MATERIALS. c) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? No Impact. Although the City of Huntington Beach is included within the Airport Environs Land Use Plan (AELUP) of Orange County, the proposed project site is located more than 20,000 feet from the Armed Forces Reserve Center in the City of Los Alamitos. The height of future structures would not penetrate navigable airspace or otherwise impact air traffic patterns. No impacts are anticipated in this regard. d) For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people residing or working in the project area? No Impact. Refer to Response 9c, above. City of Huntington Beach April 5, 2005 8-7 Seawater Desalination Project at Huntington Beach 8.0 EFFECTS FOUND Draft Recirculated Environmental Impact Report NOT TO BE SIGNIFICANT e) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? Less Than Significant Impact. The proposed project shall be in compliance with all City of Huntington Beach emergency response and/or emergency evacuation plans. The project site is proposed to,utilize the existing HBGS entrance located along Newland Street. Incorporation of required evacuation plans and procedures shall be incorporated into site design and the project will comply with applicable design standards. Temporary impacts from pipeline installation will be reduced through incorporation of standard construction measures. Impacts in this regard are not anticipated to occur. t) Expose people or structures to a significant risk of loss, injury or death involving wildland r, fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands? r-, No Impact. The project site is developed and located within a fully developed urban setting. Therefore, project implementation would not expose people or structures to a - significant risk of loss, injury or death involving wildland fires. 10. NOISE. Would the project result in: a) For a project located within an airport land use plan or, where such a plan has not been r; adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? r-, No Impact. Although the City of Huntington Beach is included within the Airport Environs Land Use Plan (AELUP) of Orange County, the proposed project site is located more than 20,000 feet from the Armed Forces Reserve Center in the City of Los n Alamitos. No impacts are anticipated in this regard. b) For a project within the vicinity of a private airstrip, would the project expose people residing or working in the project area to excessive noise levels? No Impact Although the City of Huntington Beach is included within the Airport Environs Land Use Plan (AELUP) of Orange County, the proposed project site is not located in the vicinity of a private airstrip. No impacts are anticipated in this regard. 11. PUBLIC SERVICES. a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services: r 1) Fire protection? rr Less Than Significant Impact. The proposed project site is currently developed and has previously been served by the Huntington Beach Fire Department. The proposed project will comply with all City of Huntington Beach safety codes, emergency response and/or emergency evacuation plans, and the City's General Plan. The facility will have r City of Huntington Beach April 5, 2005 8-8 Seawater Desalination Project at Huntington Beach 8.0 EFFECTS FOUND Draft Recirculated Environmental Impact Report NOT TO BE SIGNIFICANT independent fire protection. However, fire access to the subject site will be provided via the existing access point to the HBGS located along Newland Street. Impacts in this regard have been adequately analyzed within the City's General Plan EIR. However, the EIR addresses impacts in this regard within Section 5.6, PUBLIC SERVICES AND UTILITIES. 2) Police protection? Less Than Significant Impact. Implementation of the proposed project is not expected to result in the need for increased police protection services. The project will implement a seawater desalination facility in an industrial area and will not include uses requiring significant additional police patrols or service calls, such as housing or retail uses. Impacts in this regard have been previously analyzed in the City of Huntington Beach General Plan EIR. However, the EIR addresses impacts in this regard within Section 5.6, PUBLIC SERVICES AND UTILITIES. 3) Schools? No Impact. The project vicinity is served by the Huntington Beach City Elementary School District and the Huntington Beach Union High School District. The project is not expected to create a need for new or increased school services or to directly impact enrollment figures. However, these issues are included in the EIR (Section 5.6, PUBLIC SERVICES AND UTILITIES). 4) Parks? No Impact. The project proposes a 50 mgd seawater desalination facility within an industrial area. No impacts are anticipated in this regard. 5) Other public facilities? No Impact No other adverse impacts have been identified for public services, therefore, no impacts are anticipated in this regard. 12. UTILITIES AND SERVICE SYSTEMS. Would the project. a) Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board? No Impact. The facility is anticipated to produce wastewater in the forms of concentrated seawater, filter backwash water, filter backwash solids, domestic wastewater, and used membrane cleaning solution. All such wastewater will be properly collected, monitored, and discharged per Regional Water Quality Control Board requirements. These impacts are analyzed in Section 5.6, PUBLIC SERVICES AND UTILITIES. b) Require or result in the construction of new storm water drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? City of Huntington Beach April 5, 2005 8-9 r Seawater Desalination Project at Huntington Beach 8.0 EFFECTS FOUND Draft Recirculated Environmental Impact Report NOT TO BE SIGNIFICANT Less Than Significant Impact. Project implementation would incorporate an appropriate local on-site drainage system integrating permanent stormwater facilities and BMP's to ensure that surface runoff is directed to the Huntington Beach Channel. The on-site drainage system will require the construction of a stormwater pump station and/or detention basin, as the Channel surface water level elevation is higher than the project site elevation. Impacts in this regard are anticipated to be less than significant. r However these impacts are addressed within Section 5.6, PUBLIC SERVICES AND UTILITIES. T, c) Have sufficient water supplies available to serve the project from existing entitlements and resources, or are new or expanded entitlements needed? No Impact. The project is proposed to produce 50 mgd of potable water through the filtration of seawater. The facility will not consume significant amounts of fresh water and will not require new or expanded water entitlements. The project will provide the surrounding region with an additional source of potable water. No impacts are anticipated in this regard. d) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project=s projected demand in addition to the provider's commitments? Less Than Significant Impact. The facility is anticipated to produce wastewater in the forms of concentrated seawater, filter backwash water, filter backwash solids, domestic wastewater, and used membrane cleaning solution. All such wastewater will be properly collected, monitored, and discharged per Regional Water Quality Control Board requirements. Certain types of wastewater will be discharged via the AES Huntington Beach Generating Station outfall pipeline, while others will be discharged for wastewater treatment at the Orange County Sanitation District facility within the City of Huntington Beach. Impacts in this regard are anticipated to be less than significant. However, this issue is addressed within Section 5.6, PUBLIC SERVICES AND UTILITIES. - 1 e) Comply with federal, state, and local statutes and regulations related to solid waste? No Impact. The facility is anticipated to produce solid waste in the forms of domestic/municipal solid waste. Project operation may require the disposal of dewatered filter backwash solids as a solid waste as an alternative to utilizing OCSD facilities for disposal. All such waste will be stored, transported, and disposed of in accordance with federal, state, and local statutes. This issue is further addressed in Section 5.6, PUBLIC SERVICES AND UTILITIES. 17 13. AESTHETICS. Would the project: a) Have a substantial adverse effect on a scenic vista? Less Than Significant Impact. Project implementation would require the replacement of three large, visually prominent fuel storage tanks with a total of 150,000 square feet of buildings associated with desalination operations within an industrial area. Project implementation would improve the overall aesthetic character of the alternative site, as facility structures would feature contemporary architectural design and substantial landscaping/aesthetic screening. New lighting facilities may be necessary for nighttime City of Huntington Beach April 5, 2005 8-10 Seawater Desalination Project at Huntington Beach 8.0 EFFECTS FOUND Draft Recirculated Environmental Impact Report NOT TO BE SIGNIFICANT illumination. Potential opportunities to reduce impacts would be utilized in order to Pp p reduce light spillover effects in accordance with the City's Standard Conditions of Approval. All off-site infrastructure is proposed to be subsurface. Implementation of the off-site OC-44 underground booster pump station implementation may require the removal of native vegetation during construction, however, all such vegetation would be replaced subsequent to the completion of construction. Impacts are anticipated to be less than significant. b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? No Impact. Refer to Response 13a, above. c) Substantially degrade the existing visual character or quality of the site and its surroundings? Less Than Significant Impact. Refer to Response 13a, above. d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area? Less Than Significant Impact. Implementation of the proposed project may include nighttime lighting for certain areas of the site. Potential opportunities to reduce impacts would be implemented in order to reduce light spillover effects in accordance with the City's Standard Conditions of Approval. This issue is examined in the EIR (Section 5.7, AESTHETICS/LIGHT& GLARE). 14. CULTURAL RESOURCES. Would the project: a) Cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5? No Impact. No historical or archaeological resources are known to exist within the boundaries of any component of the project (both on- and off-site components). No impacts are anticipated in this regard. b) Disturb any human remains, including those interred outside of formal cemeteries? No Impact. Refer to Response 14a, above. 15. RECREATION. Would the project: a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? No Impact. The proposed project site does not involve recreational facilities, nor does it involve project components that would increase demand for existing recreational facilities. Impacts are not anticipated in this regard. However, this issue is further analyzed within Section 5.6, PUBLIC SERVICES AND UTILITIES. City of Huntington Beach April 5, 2005 8-11 Seawater Desalination Project at Huntington Beach 8.0 EFFECTS FOUND j Draft Recirculated Environmental Impact Report NOT TO BE SIGNIFICANT b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? No Impact. Refer to Response 15a, above. c) Affect existing recreational opportunities? 'J Less Than Significant Impact. Refer to Response 15a, above. 16. AGRICULTURAL RESOURCES. In determining whether impacts to agricultural j resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. 17 Would the project: a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? No Impact. The proposed project site is currently developed and exists within an '7 urbanized area. Designated land uses within the project area do not include agricultural uses. Based upon the Farmland Mapping and Monitoring Program for the California Resource Agency, project components do not affect any agricultural resource area. Therefore, impacts to agricultural land or zoning for agricultural use will not occur. b) Conflict with existing zoning for agricultural use, or a Williamson act contract? r, No Impact. Refer to Response 16a, above. c) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use? No Impact. Refer to Response 16a, above. i f-- City of Huntington Beach April 5, 2005 8-12 � 9.0 ORGANIZATIONS AND � PERSONS CONSULTED 1 1 1 1 t 1 9.0 ORGANIZATIONS AND PERSONS CONSULTED ' Lead Agency: City of Huntington Beach ' Department of Planning 2000 Main Street P.O. Box 190 Huntington Beach, CA 92648 Mary Beth Broeren, Principal Planner Ricky Ramos, Associate Planner Applicant: Poseidon Resources Corporation 3760 Kilroy Airport Way, Suite 260 Long Beach, CA 90806 Billy Owens, Vice President, Project Development Josie McKinley, Project Development Manager Environmental Consulting Team RBF Consulting (EIR Consultant) 3536 Concours, Suite 220 Ontario, CA 91764 Kevin Thomas, CEP, Environmental Services Manager(Project Manager) Alan Ashimine, Environmental Analyst(Project Coordinator) Bill McInerney, Project Engineer(Pipeline Review) Eddie Torres, Air/Noise Specialist Michael Harden, Environmental Analyst Maria Cadiz, Environmental Analyst Stacey Brenner, Environmental Analyst BonTerra Consulting (Booster Pump Station Biological Constraints Survey) 151 Kalmus Drive, Suite E-200 Costa Mesa, CA 92626 Ann Johnston, Principal Michael Couffer, Consulting Biologist CRM TECH (Cultural Resources Assessment Reports) 2411 Sunset Drive Riverside, CA 92506 Bruce Love, Principal Bai "Tom" Tang, Historian Harry Quinn, Archaeologist Mariam Dandul, Archaeologist City of Huntington Beach April 5, 2005 9-1 Seawater Desalination Project at Huntington Beach 9.0 ORGANIZATIONS AND Draft Recirculated Environmental Impact Report PERSONS CONSULTED D. Scott Magorien, CEG (Geotechnical Reports) 330 W. Bay Street, Suite 140 Costa Mesa, CA 92627 MBC Applied Environmental Sciences (Marine Biological Analysis) 3000 Redhill Avenue Costa Mesa, CA 92626 Charles Mitchell, President David Vilas, Project Scientist Shane Beck, Project Scientist Public Agencies City of Huntington Beach Fire Department Huntington Beach Union High School 2000 Main Street District Huntington Beach, CA 92648 10251 Yorktown Avenue Mr. Eric Engberg Huntington Beach, CA 92646-2999 Ms. Patricia Koch City of Huntington Beach Library Services Department County of Orange Public Facilities & 7111 Talbert Ave. Resources Department Huntington Beach, CA 92648 300 N. Flower Street Mr. Ron Hayden Santa Ana, CA 92703-5000 Mr. Sara Bavan City of Huntington Beach Police Department 2000 Main Street Orange County Sanitation District Huntington Beach, CA 92648 10844 Ellis Avenue Tom Donnelly, Captain Fountain Valley, CA 92708-7018 Mr. Adam Nazaroff City of Huntington Beach Public Works Department Rainbow Disposal Company 2000 Main Street P.O. Box 1026 Huntington Beach, CA 92648 Huntington Beach, CA 92647 Mr. Todd Broussard Ms. Sandra Jacobs Mr. Duncan Lee Southern California Edison Huntington Beach City School District 7333 Bolsa Ave. 20451 Craimer Lane Westminster, CA 92683 Huntington Beach, CA 92646 Ms. Spring Bowles Mr. Richard Masters Southern California Gas Company Time Warner Communications 12631 Monarch St. 7441 Chapman Ave. Garden Grove, CA 92841 Garden Grove, CA 92840 Mr. Greg Heintz Mr. Bill Jankowski Verizon 7352 Slater Ave. Huntington Beach, CA 92647 Mr. Tom Solano City of Huntington Beach April 5, 2005 9-2 ' Seawater Desalination Project at Huntington Beach 9.0 ORGANIZATIONS AND Draft Recirculated Environmental Impact Report PERSONS CONSULTED Interested Parties ' Harbor Ridge Estates Maintenance Association Harbor View Knoll Community Association Newport Ridge North Community Association Seawind Newport Homeowner's Association Southeast Homeowner's Association ' Southeast Huntington Beach Neighborhood Association Surfrider Foundation, Huntington/Seal Beach Chapter Orange County Coastkeeper i 1 1 t City of Huntington Beach April 5, 2005 9-3 IL 9 J m m O . O 10.0 BIBLIOGRAPHY Documents: 2000 Regional Urban Water Management Plan. Municipal Water District of Orange County, ' December 20, 2000. 2020 Master Plan Report. Orange County Water District, November 1998. Active Fault Near-Source Zones. California Division of Mines and Geology, map atlas Pape N- 34, February 1998. AES Draft Mitigated Negative Declaration No. 00-09. City of Huntington Beach, November 2, 2000. ' AES Huntington Beach Generating Station Surf Zone Water Quality Study (Final Draft). Komex H2O Science Inc., 2003. AES Huntington Beach Master Site Plan, AES Huntington Beach, LLC, September 28, 2004. Air Quality Management Plan. South Coast Air Quality Management District, 1997. Alquist-Priolo Earthquake Fault Zoning Act. City of Huntington Beach, July 1995. Alquist-Priolo Earthquake Fault Zone Map, issued by the State geologist, 1986. California ' Division of Mines and Geology Special Publication 42, 1997. Annual Progress Report to the California State Legislature. Metropolitan Water District of Southern California, February 2002. "AQMD Sees Progress in Attaining Federal Clean Air Standards", AQMD Advisor, Volume 3, ' Number 7, September 1996. Assessment of Noise with Respect to Community Reponse. International Standardization, ' Switzerland, 1996. Benthic Impact of the Discharge from Desalination Plant. Prepared by C. Pomory, 2000. ' Biological Constraints Survey for the Poseidon Seawater Desalination Plant Pump Station, Orange County, California. BonTerra Consulting, May 16, 2002. California Energy Commission Energy Facility Status summary. California Energy Commission, June 30, 2004. California Water Plan Update, Bulletin 160-98. State of California Department of Water Resources, November 1998. CEQA Air Quality Handbook. South Coast Air Quality Management District, revised November 1993. City/County Population Estimates, with Annual Percent Change, January 1, 1999 and 2000. California Department of Finance, May 2000. ' City of Huntington Beach April 5,2005 10-1 Seawater Desalination Project at Huntington Beach 10.0 BIBLIOGRAPHY Draft Recirculated Environmental Impact Report City of Huntington Beach General Plan. City of Huntington Beach, May 1996. City of Huntington Beach General Plan EIR. City of Huntington Beach, July 1995. City of Huntington Beach Local Coastal Program. City of Huntington Beach, November 2001. City of Huntington Beach Water Master Plan. City of Huntington Beach, December 2000. City of Huntington Beach Zoning and Subdivision Ordinance. City of Huntington Beach. City of Irvine General Plan. City of Irvine, March 1999. County of Orange General Plan. County of Orange, July 2, 2003. County Population Projections from 1997 through 2040. California Department of Finance, December 1998. Desalination Facilities Located Throughout the World. Poseidon Resources Corporation, November 2004. Desalination Task Force Report (Draft and Final, dated September 19, 2003 and October 2003, respectively). California Desalination Task Force. Disinfection Byproduct Formation Report. McGuire Environmental Consultants, March 2004. Distribution System Corrosion Control for Desalination Seawater. McGuire Environmental Consultants, September 27, 2002. Ecological Descriptions and Evaluation of Proposed Enhancement/Restoration for Eight Southern California Wetlands. Prepared by MEC Analytical Systems, 1991. Electric Power Plant Environmental Noise Guide. Prepared by L.N. Miller, et. al., 1984. Energy Down the Drain — The Hidden Costs of California's Water Supply. National Resources Defense Council/Pacific Institute, August 2004. Environmental Assessment Southern California Edison Huntington Beach Fuel Oil Storage Tank Removal Project. Prepared by Arthur D. Little, Inc., April 20, 2000. Evaluation of a Report on Receiving Water Chemistry and Quality Issues Related to the Operation of a Reverse Osmosis Desalination Facility at the Huntington Beach Power Generating Station. Prepared by Jeffrey Graham, Scripps Institution of Oceanography, August 25, 2004. Final 1997 Air Quality Management Plan. South Coast Air Quality Management District, January 1997. Flood Insurance Rate Map, Huntington Beach. Federal Emergency Management Agency, June 2000. Flood Insurance Rate Map. Federal Emergency Management Agency (revised), February 18, 2004. City of Huntington Beach April 5,2005 10-2 rSeawater Desalination Project at Huntington Beach 10.0 BIBLIOGRAPHY Draft Recirculated Environmental Impact Report Fundamentals of Abatement of Highway Traffic Noise. Bolt, Beranek, and Newman, 1973. ' Geologic Map of Orange County California, Showing Mines and Mineral Deposits. State of California Division of Mines and Geology, 1981. Geotechnical Investigation for Future Huntington Beach Maintenance Facility, East End of Edison Road, East of Newland Street, Huntington Beach, California. Prepared by G.A. Nicoll, Inc., 2000. Geotechnical Investigation, Huntington Beach Channel (Flood Control Facility No.D01), City of Huntington Beach, County of Orange California for the Orange County Environmental ' Management Agency. Geosoils Inc., February 21, 1991. Growth Assessment and Evaluation for Anticipated Infill and New Development in Orange County, California. LSA Associates, Inc., October 2004. Guidelines for Evaluation and Mitigating Seismic Hazards in California. California Division of Mines and Geology Special Publication 117, Prepared by Dr. Geoffrey R. Martin et al, May 1999. Historical/Archaeological Resources Survey Report, Poseidon Seawater Desalination Plant ' Pump Station Site. CRM TECH, June 10, 2002. Huntington Beach Desalination Facility Intake Effects Assessment. Poseidon Resources ' Corporation, November 17, 2004. Huntington Beach Generating Station Phase II Environmental Site Assessment. CH2M Hill, November 27, 1996. Huntin ton Beach Seawater Desalination Plant g a Pressure Surge Analysis. Flow Science ' Incorporated, January 16, 2003. Huntington Beach Generating Station Retool Proiect Application for Certification (00-AFC-13) Commission Decision. California Energy Commission, May 2001. Huntington Beach Seawater Desalination Plant Pressure Surge Analysis Poseidon Resources Corporation. Flow Science Incorporated, February 2, 2005. ' Hydrodynamic Modeling of Source Water Make-Up and Concentrated Seawater Dilution for the Ocean Desalination Project at the AES Huntington Beach Generating Station. Dr. Scott A. Jenkins Consulting, January 6, 2005. Integrated Water Resources Plan (IRP) 2003 Update. Metropolitan Water District of Southern California, May 2004. Large Scale Demonstration Desalination Feasibility Study. City of Corpus Christi, August 2004 ' (http://www.cctexas.com/files/gl7/LSD%2OReport%2OAug%2004%2Epdf). Local and Regional Electric Power Requirements and Generation Resources. Navigant Consulting, December 10, 2004. ' City of Huntington Beach April 5,2005 10-3 Seawater Desalination Project at Huntington Beach 10.0 BIBLIOGRAPHY Draft Recirculated Environmental Impact Report Marine Biological Considerations Related to the Reverse Osmosis Desalination Proiect at the Applied Energy Sources Huntington Beach Generation Station. J.B. Graham, August 3, 2004. Metropolitan Water District of Southern California Integrated Resources Plan. Metropolitan Water District of Southern California, 1996. Municipal Water District of Orange County Regional Urban Water Management Plan. Municipal Water District of Orange County, December 20, 2000. Paleontological Resources Assessment Report, Poseidon Seawater Desalination Plant Pump Station Site. CRM TECH, June 10, 2002. Phase 1 Environmental Site Assessment for Edison Pipeline and Terminal Company. Huntington Beach, May 2000. Power Plant Construction Noise Guide. J.D. Barnes, et. al., 1977. Preliminary Assessment of Potential Water Transmission Line Routes for the Orange County Desalination Plant to the OC-44 in Costa Mesa. Carollo Engineers, August 2001. Preliminary Geotechnical Assessment, Southwest Reservoir Site Acquisition Huntington Beach, California. Prepared by Geologic Associates, May 24,2002. Preliminary Hazardous Materials Assessment for the Southeast Coastal Redevelopment Plan. Prepared by RBF Consulting, January 11, 2001. Preliminary Review of Geotechnical Constraints and Geologic Hazards, Poseidon Resources Orange County Desalination Project. Huntington Beach, California. Scott Magorien, CEG, July 11, 2002. Preliminary Review of Geotechnical Constraints and Geologic Hazards, Poseidon Resources Orange County Desalination Project. Huntington Beach California North and West Tank Options. Scott Magorien, CEG, July 12, 2002. Preliminary Seismic Assessment Orange County Desalination Proiect, Huntington Beach, CA Response. Geologic Associates, January 15, 2005. Regional Comprehensive Plan and Guide. Southern California Association of Governments (SCAG), May 1995. Regional Urban Water Management Plan. Metropolitan Water District of Southern California, December 2000. Rules and Regulations. South Coast Air Quality Management District, 2001. "Salinity: Fishes" Marine Ecology. Prepared by F. Holliday, 1971. Seawater Desalination and the California Coastal Act. California Coastal Commission, March 2004. Seismic Hazard Zones Map. Prepared by the State Geologist, April 7, 1997. City of Huntington Beach April 5,2005 10-4 rSeawater Desalination Project at Huntington Beach 10.0 BIBLIOGRAPHY Draft Recirculated Environmental Impact Report Seismic Hazard Zones, Tustin Quadrangle, Official Revised Map. California Geological Survey, January 17, 2001. Site Investigation Report for Soil and Groundwater. Huntington Beach Generating Station Huntington Beach, California. Prepared by Woodward Clyde, May 1998. ' Soil Survey of Orange County and the Western Portion of Riverside County California. United States Department of Agriculture Soil Conservation Service and Forest Service, September 1978. Southeast Coastal Redevelopment Plan Program Environmental Impact Report RBF Consulting, January 23, 2002. Supplemental Report on the Effects of a Retrofitted Diffuser on the Discharge Outfall for the Proposed Seawater Desalination Project at Huntington Beach CA Scott A. Jenkins Consulting, January 7, 2005. The Benthic Macrofauna of the Mainland Shelf of Southern California. Prepared by G.F. Jones, ' 1969. The Drainage Area Management Plan. Prepared by the County of Orange, Cities of Orange ' County, and the Orange County Flood Control District, 2003. The Groundwater Replenishment System: Providing Water for the Future. Orange County Water District, 2003-2004. The Thomas Guide. 2004, page 857. Thomas Brothers Maps and Books, 2004. Transportation System Needs Analysis, 2000-2010. Prepared by JR Consulting Engineers, September 2000. ' USGS 7.5-Minute Maps of Newport Beach California United States Geological Survey, photorevised 1981. ' Water Quality Control Plan for the Santa Ana River Basin (8) and amendments. The Santa Ana Regional Water Quality Control Board, 1995. ' Water Quality Control Plan, Ocean Water of California (California Ocean Plan). State Water Resources Control Board, 2001. ' Watershed Sanitary Survey Report. Archibald and Wallberg Consultants, January 2002. Web Sites: www.agmd.gov/cega/hdbk.html (South Coast Air Quality Management District - updated guidance documents) ' www.arb.ca.gov/adam.welcome.htmi (California Air Resources Board) www.calmis.cahwnet.gov (State of California Employment Development Department) ' www.coastal.ca.gov/web/desalrpt/dtitle.htmi (California Coastal Commission) ' City of Huntington Beach April 5,2005 10-5 Seawater Desalination Project at Huntington Beach 10.0 BIBLIOGRAPHY Draft Recirculated Environmental Impact Report www.irwd.com/ (Irvine Ranch Water District) http://www.mwdh2o.com/ (Metropolitan Water District) www.nmviewogc.cr.usga.gov/viewer.htm (National Map Viewer of the United States Geological Survey [USGS]) www.ocwd.com/ assets/ pdfs/recycling_pdf(Recycling Brochure, OCWD) http://www.ci.huntington-beach.ca.us/ (City of Huntington Beach) http://www.scwd.org/about/about.htm#water (South County Water District) City of Huntington Beach April 5,2005 10-6 �41e�enme fn ` THE CITY OF HUNTINGTON BEACH The document you are viewing contains additional information that is not possible to produce electronically. For information on how to locate this document for viewing , please contact or visit the City Clerk's Office for assistance . 2000 Main Street 2nd Floor — City Hall Huntington Beach CA 92648 (714) 536-5227