HomeMy WebLinkAboutSP 144; SDG&E Wastewater Facility; Specific Plan (SP)m(\CALIFORNIA COASTAL ZONE CONSERVATION COMMISSION
1540 Market Street, San Francisco 94102 — (415) 557-lflOl
STAFF RECOMMENDATION
CJ -Vrt \
Appeal No. 7&-75
(SDG&E, Encina 5)
60th Day: Extended to
11/19/75DECISION OF
REGIONAL
pOMKISSION: Permit denied by the San.Diego Coast Regional Commission
PERMIT . . -
APPLICANT:
APPELLANT:
DEVELOPMENT
LOCATION:
DEVELOPMENT
DESCRIPTION:
San Diego Gas and Electric Company
San Diego Gas and Electric Company
Adjacent to the Pacific Ocean and Agua Hedionda Lagoon at the Ericina
Power Plant in Carlsbad, San Diego County (Exhibits 1 and 2)
Construction of a 292 mw fossil fuel steam turbine generating unit with
associated switching facilities and transmission lines, and replacement.,
of 4 existing 190-ft. stacks and one 400-ft. stack (see Appeal Summary,
Exhibits 2,3, 9, and 10)
PUBLIC HEARING; Held May 13, 1975, in Inglewood
SUBSTANTIVE FILE DOCUMENTS: ' .-
1. Regional Commission File
i 2. Notice of Appeal
• *J& 3- SDAPCD correspondence and reports ' . , • • '
'; 4« PUC decisions . • ' . . .
5- Applicant's supplementary material
6. Opponents' supplementary material . '
Energy Commission staff reports and decisions
8. Correspondence
TW3-THIRDS VOTE; The staff recommends the Commission find that a 2/3 vote is required
to issue a permit because the proposed development "...would substantially interfere
with or detract from the line of sight toward the sea from the state highway nearest
the coast" (Pub. Res. Code Section 27403 (d)) and "...would adversely affect water
quality...." (Pub. Hes. Code Section 27401 (e)). . •
STAFF NOTE; At the public hearing on this application, 4 major issues were identified:
(l) impact on the marine environment, particularly the 75-acre offshore kelp bed; (2)
impact on regional air quality; (3) impact on scenic resources of the 400-ft. stack
required to meet local air quality standards; and (4) the need for the plant in light of
ui'certain growth projections and energy conservation measures. Since the public hearing,.
the following events have occured related to these issues: (l) the State Dept. of Fish
and Game has withdrawn its objections to the'plant at this time subject to the conditions
recommended to protect the offshore kelp bed; (2) the San Diego Air Pollution Control
District has provided several reports on air quality impacts that have been sent to the
Commission or summarized in the proposed findings; (3) the City of Carlsbad approval of
the 400-ft. stack has expired and SDG&E is applying for a new City permit; and (4)
-2-
the State Energy Resources Conservation and Development Commission has decided to rely
on the State Public Utilities Commission's forecasts of electrical energy requirements
until its own forecasting models are developed. The PUC has determined that there is
a need for Encina 5 and has issued the applicants a certificate of public convenience
and necessity. • - ' .
Very recently, a new issue has arisen concerning air quality in the immediate
vicinity of the plant. Residents of a nearby subdivision have reported both property
damage; and health impacts from particles containing ferrous metals and some sulfates
(which reacts to form sulfuric or sulfurous acid). The San Diego Air Pollution Control
District is beginning studies of this damage and the issue is discussed more fully in
the proposed findings. . .
STAFF RECOMENDATIOK" ' ~~ -
The staff recommends that the Commission adopt the following resolution:
1. Approval. • ,ii
The Commission hereby approves, a permit for the proposed development subject
to the conditions below, on grounds that, as conditioned, the development will not have j
any substantial adverse environmental or ecological effects and will be consistent with ;
the findings, declarations, and objectives of the California Coastal Zone Conservation
Act of 1972.
II. Conditions _ ' «f
The permit is subject to the following conditions:
A- Permit Approvals. Applicant shall not commence on-site construction, of [
any portion of the proposed development until all necessary permits and approvals have {
been issued for the construction of the development as proposed, and evidence, satis- |
factory to the Executive Director of the Commission, has been submitted by the applicant j
shov/ing that such approvals have been issued. ;i
B. Air Quality Monitoring and Emission Controls. . - • >
I
• ' |
1. Applicant, prior to commencement of on-site construction, shall !
provide funds to the San Diego Air Pollution Control Dist. for the purchase of air .' !
quality monitoring instrumentation capable of monitoring ambient participates, NOX, ' |
and S02 concentrations for use at three new sites selected by the Air Pollution
Control Officer in the vicinity of the Encina Power Plant. Should the officer select
monitoring sites on applicant's property, applicant shall provide the sites and reason- t
able access at no expense to the District.. }
• • *
2. If the San Diego Air Pollution Control Officer determines (l) that the
Encina Power Plant is the source of the emissions causing the property damage and/or
health impact to residents of the Terramar subdivision described in Finding 3b, and (-2)
that operating practices and/or emission control devises are capable of eliminating such I
damage or impacts, the applicant shall submit to the Air Pollution Control Board, within j
60 days of the determinations specified above, a compliance schedule, including such \
operating practices and/or emission control devises to be used in the Encina Power Plant |
as are necessary to eliminate such damage or impacts and time schedules for their use, I
which is acceptable to the Air Pollution Control Officer. Upon acceptance of the com- J
pliance schedule, its terms shall become a condition of this permit and such emission I
-3-
control measures shall be incorporated into the proposed development. This condition
shall not be construed as exempting the applicant from any requirements imposed by law
and necessary to conform to the terms of this condition.
C. Kelp Resources,.
1. Applicant shall fund a comprehensive monitoring program to determine
the effects of the discharge from Unit 5 of the Encina Power Plant on the two nearby
Macrocystis sp. kelp stands indicated on Exhibit 5 and denoted as "north bed" and "south
bed." The details of the monitoring program will be mutually scoped by SDG&E and the
State Dept. of Fish and Game (henceforth Department). The monitoring program shall be
performed by a private firm retained by SDG&E and approved by the Department or by the
Department itself. SDG&E will participate in the field investigation and cooperate in
the exchange of data resulting from such investigation. The costs of the monitoring
program shall be funded by SDG&E, not to exceed $200,000 for a period of five years,
commencing one year prior to the scheduled commercial operation date.
2. If damage (as defined below) attributable to the discharge from Unit 5
of the Encina Power Plant occurs to either kelp stand, SDG&E shall fund a Macrocystis sp.
kelp transplanting program at a site selected by the Dept. of Fish and .Game on the follow-
ing basis:
(a) For each acre or portion of an acre of kelp damaged, a replacement
acre shall be transplanted.
(b) The transplanting shall be by Department or by a private firm
retained by SDG&E.
(c) SDG&E1s costs under this paragraph shall be limited to a total
sum not to exceed $250,000. Should $250,000 be expended for the
kelp transplanting program and the results of the program show
that the program may succeed, SDG&E and the Department, upon
mutual agreement, may continue the program in lieu of invoking
paragraph 5 of these conditions.
(d) "Transplant" means to develop a self-sustaining area of Macrocystis
kelp comparable in density and extent to the two nearby existing •
Macrocystis kelp beds in the absence of thermal discharge.
(e) Transplanting shall be considered complete when the replacement
Macrocystis kelp beds maintain such density and extend for three
consecutive years without human intervention.
3. "Damage" is defined as that damage attributable to the thermal dis-
charge from Unit 5 over the baseline conditions, and does not include damage from
natural causes. The term "baseline conditions" is defined as conditions in the absence
of a discharge from Unit 5- These conditions will be determined by monitoring the north
and south kelp beds prior to discharge and by monitoring control kelp beds. All compari-
sons shall, be on a yearly average basis.
4« The kelp transplanting program described in paragraph 2 shall be imple-
mented during or upon completion of a review of the monitoring studies and a finding that
damage has occured to kelp stands identified..on Exhibit 5- Either party may elect to
have that finding made by a majority vote of a three-member panel, one member each chosen
by the Dept. of Fish and Game and SDG&E, and the third member mutually agreed upon. All
expenses of such panel shall be paid by SDG&E and credited against the sum set forth in
paragraph 2 (c).
'-4-;
5. If kelp transplant is not deemed successful by the Select Review Panel
within five years, the Coastal Commission or its successor and/or the Dept. shall not
be limited by these conditions in any way from pursuing remedial measures to insure
the full protection of the Macrocystis kelp beds identified in Exhibit 5«
6. SDG&E shall proceed with the design and construction of Unit 5 of the
Encina Power Plant such that cooling water from the Unit may be directed to an ocean
outfall if an outfall later is required by any State or Federal agency.
7- Should any other Federal or State regulatory agency require SDG&E
to undertake the construction of an alternate discharge system, these conditions shall
then become null and void.
*
8. The conditions above are in addition to any requirements pursuant to
the Federal Water. Pollution Control Act Amendments of 1972 (PL 92-500). Acceptance of
any or all of the conditions above by SDG&E is not to be construed as exempting SDG&E
from any provisions of the Federal Water Pollution Control Act Amendments of 1972
(PL 92-500).
D. Beach Access. Prior to the commencement of construction, applicant shall
grant, and the State Dept. of Parks and Recreation shall have accepted, a public recrea-
tional easement to the State of California covering that portion of applicant's property
lying between Carlsbad Blvd. and the Pacific Ocean lying south of the discharge channel
and north of Terramsr Subdivision, commencing on June 1, 1979, when an existing lease
to the Employees' Association of San Diego Gas & Electric Co. is scheduled for renewal.
Indemnification of claims for personal injury or property damage arising from such public
use shall be provided on terms acceptable to both parties.
E. Berm and Landscaping. Within 2 years from the commencement of on-site
construction, .applicant shall extend the landscaped berm consistent with the quality
, of the existing landscaped berm adjacent to Interstate 5 to applicant's south property
line, then turn west and extend it to the railroad right-of-way, thereby improving
plant esthetics and screening much of the plant site as seen from Interstate 5«
III. Findings and Declarations.
The Commission finds and declares as follows:
.1. Summary. The proposed development is a 292 Mwt expansion of the existing
Encina Power Plant operated by San Diego Gas and Electric Co. Both the standards of the
Coastal Act and the policies of the Coastal Plan recognize that expansions of existing
generating facilities are generally preferable to the construction of major facilities
at entirely new sites. Where expansion will not overload an existing site, destroy
important coastal resources, interfere with the maintenance or attainment of air and
water quality standards, and where sufficient mitigation measures are available to
minimize the environmental impacts of the project, the expansion of an existing site
is ordinarily more consistent with the Coastal Act's objective of "orderly, balanced
utilization and preservation, consistent with sound conservation principles, of all
living and nonliving coastal zone resources" (Pub. Res. Code Section 27302 (c)) than .
wo'ld be the development of a new site. Thus, although there are undeniably adverse
environmental impacts from the proposed development and the magnitude of several impacts
is not well known, approval of the development, subject to the conditions above, is
warranted under the Coastal Act.- - .
2. Project Description. The proposed development is the construction of a
292 mw fossil fuel, steam turbine, base load, electric generating unit and associated
switching facilities and transmission lines. The construction would be at the southern
end of the existing 4 generating units at the applicant's Encina Power Plant in the City
of Carlsbad. To the east of the site is the 1-5 freeway; to the north, Agua Hedionda
Lagoon; and to the west, Carlsbad Blvd. and the ocean. The power plant is highly visible
from the lagoon, the 1-5 freeway, Carlsbad, Blvd. (old Highway l), and the beach west
-of Carlsbad Blvd. -
The existing Encina power plant building is about 500 ft. long, 216 ft. wideband
130 ft. high. The proposed expansion would extend the building by 2/j6 ft. in length,
and 18 ft. in height. The 4 existing stacks, which are 190 ft. above mean sea level
(MSL), would be replaced with a single stack 400 ft. above MSL.
The proposed cooling system is a once-through system with its intake at the existing
intake channel inside Agua Hedionda Lagoon and its discharge through the existing riprap
channel across the beach. The proposed cooling system is designed for a flow of 800,000
gallons per minute (gpm), a 418,000 gpm increase over the existing flow of 382»000 gpm.
Most of the increase in the.maximum flow (250,000 gpm) is the result of incorporating
a dilution system to reduce the temperature of the water discharged to 20 degrees F over
the temperature of the ocean.
3- Air Quality.• The applicant, the staff of the State Air Resources Board, and
the staff of the California Public Utilities Commission all make similar estimates of the
emissions from Encina 5« The figures calculated by the Air Resources Board (ARB) staff
and found in the Environmental Impact Report prepared by the California Public Utilities
Commission are as follows:
Plant operating at Plant operating at
73$ capacity 100$ capacity
Q,. 5$ sulfur fuel 0.5$ sulfur fuel
S02 12.9 tons/day 1?.? tons/day .
NOX 8.5 tons/day 11.6 tons/day
Particulates 2.4 tons/day 3-3 tons/day
The emissions of other pollutants are relatively unimportant compared to those listed.
As a significant source of air emissions, the air quality implications of Encina 5
roust be considered in relation to total emissions into the Sari Diego Air Basin and local
air quality. 'The Carlsbad area and the San Diego Air Basin of which it is a part is-
defined as an Air Quality Maintenance Area by the ARB. This air basin has the potential
for even greater air pollution problems than the South Coast Air Basin because of its
meteorological conditions. A study by the Environmental Protection Agency staff showed
that San Diego has twice as many days as Los Angeles in which weather conditions can
trap pollutants close to the ground, with resulting high concentrations. The extensive
agricultural lands in the north county area around Carlsbad are particularly subject to
damage from increases in air pollution.
The most significant impact of the SDG&E system on air quality in the San Diego Air
Basin is expected to be on SOo levels. The San Diego Air Pollution Control District
reports that SDG&E power plants are the predominant emitters of S02 in the basin and thus
air quality with respect to that pollutant is directly dependent on the SDG&E system.
For example, the ARB staff calculated that Encina Units 1 through 5 operating at 100$
load with 0.5$ sulfur fuel woulr. produce 56-1 tons of S02 per day whereas the total. SOo
emissions from all sources into the San Diego Air Basin in 1972 was only 36.1 tons per
day. Much of the increase in S02 emissions from the SDG&E system is undoubtedly caused
by the company's switching from natural gas to oil for fuel, but no data has been sub-
mitted indicating what proportion is due to increased demand.
a. SDG&E Emissions into.. San. Diego Air Basin. The impacts on the air quality
of the San Diego Air Basin from SDG&E emissions either with or without Encina 5 are_
difficult to predict because the effects will depend upon changes in demand, pollution
control technology, availability of different types of fuel, and the construction and
*operation of new generatiS^plants. All of these are uncerWIn, at least to some extent.
Moreover, the characteristics of the air basin are not well known, either as to the impact
of various emission sources or the ways in which pollutants are dispersed within the
basin. • • j ' •
Encina 5 would, however, be a more efficient generating unit than existing plants
in-the SDG&E system. Initially, it would be used instead of the company's older, dirtier
units. This would continue as long as there was an excess of generating capacity in the
existing system over demand. If demand increases, SDQ&E total emissions will also
increase, but the increase will be slightly less with the addition of Encina 5 than with-
out Encina 5 until demand exceeds the existing capacity of the syr.tem (plus 'a slight
margin representing the difference in generating efficiency between Encina 5 and other
units ). After that, there would be more emissions into the air basin than would be
possible with the existing system.
As noted by the staff of the Air Resources Board, the initial decrease in emissions
attributable to Encina 5 by the applicant would of course take place with the construc-
tion of any_ new generating capacity with the same efficiency,' and the reduction in emis-
•sions into the San Diego Air Basin would be even greater if the alternative capacity were
located outside the basin. The actual amount of emissions into the air basin will also
depend upon the ability of the utility to reduce emissions from existing plants, and to
bring other generating units into operation that will replace fossil fuel fired plants
in the basin such as San Onofre Units 2 and 3» the Kaiparowits coal-fired units, and
eventually SDG&E1s proposed Sun Desert nuclear units.
\
There are few estimates of the emissions from the SDG&E system under various demand
conditions because the computer program that SDG&E uses to model its system provides
only fuel use data on a monthly basis. The available estimates are also made only on
the basis of 0.5% sulfur oil. SDG&E estimates of emissions are limited .to forecasting
that between 19?8 and 1982 an average annual savings of 600,000 barrels of oil will be
possible with the addition of Encina 5. The ARE staff has calculated (using SDG&E
derrand figures) that "the total system emissions in 1976 of SOp with and. without Encina 5
would be 68.8 tons per day and 70.72 tons per day respectively or a difference of 2.7^-
(Such an estimate is no longer accurate because it was made in 1973; Encina 5 is" now
scheduled for operation in 1978, but this gives an estimate of the magnitude of the dif-
ference in system emissions.) The estimates of emissions submitted by the SDAPCD are
the most complete (see Air Quality_ Impact of Propps_e_d_jUnit_J:)..Addition and. _400-Ft. Stack,
•^n£in§^^lgr^lgn^j-^a^-sbAd^_J^al_ifornia, SDAPCD, June 1975jj but are limited to the
demand and fuel type use estimates used by SDG&E and the model used does not.indicate ..•
to what degree or for how long an air quality standard will or will not be exceeded.
The report concludes that with or without Encina 5 there will be a major increase in
air pollution from. SOp and some increase in particulate matter, but with Encina 5 the
degradation will be slightly less. The NOX figures given in the report, however, are
not internally consistent except for the estimates for 1978 and beyond, so comparisons
with the present situation are difficult to make.
b* Local Air Qua!j.ty. There are no long-term empirical data on the air
quality effects of the Encina power plant. Some very short term studies were conducted
by Stanford Research Institute for SDG&E in 1972, but that was prior to the construc-
tion of Encina Unit 4« No significant monitoring has been done since that time by either
SDG&E or the SDAPCD to determine the impact of Units 1 through 4 on local ambient air
quality. Thus, most of the local air quality estimates must come from computer models. •
No studies have been conducted to model the effects on local air quality if- the Macario
Refinery is built in addition to Encina 5, 'although the SDAPCD is in the process of
making such studies.
The applicant has submitted data compiled by the Bechtel Corp. showing that the
addition of Encina 5 would violate air quality standards if the existing stack design
(total height of 190 ft.) were utilized, but that the standards could be met if the
—7—
proposed 400 ft. stack were constructed. The purpose of the 400 ft. stack is to disperse
the pollutants and reduce the possibility that the plume from the plant will be trapped
under the inversion layer. No computer models were run by the applicant to determine
the impact of Unit 5 over the impact of Units 1 through 4» the only studies that were
run considered the impact of Units 4 and 5 together. The San Diego Air Pollution Con-
trol Dist. reports that the existing Units 1 through 4 may violate state or federal
24 hour ambient air quality standards for S02, but that with the 400 ft. stack, the
localized impacts of Encina 5 would be insignificant. •
Recent information has been submitted to the Commission and the SDAPCD 'by resi-
dents of the Terramar subdivision near the plant to the effect that a serious air pollu-
tion problem exists in the area (Exhibit 3). Residents of the subdivision have com-
plained of property damage to house and automobile paints; members of one household have
complained of continuous sore throats and members of another have complained of skin
irritation. Other apparently less serious complaints have been received from residents
east of the plant. Initial investigations by the SDAPCD have indicated that the problem
is caused by particles (cenospheres) composed in part of ferrous metals with some sulfates
present. The ferrous metals create an orange-brown spot and the sulfates react to form
sulfuric or sulfurous acid.
The SDAPCD is currently investigating the source and the causes of this problem
and expects to have results from various studies compiled and .in report form by Feb. 1,
1976. Although the source of the pollution has not been traced directly to the Encina
power plant, the only other major pollution source in the area is the 1-5 freeway; the
Commission is not aware of any similar problems along its route_. Similar pollution
problems have been identified in other power plant sites, however, such as Moss Landing,
and such particles have been reported in the literature as formed in power plant-sized
boilers.
Although property damage may result from the larger cenospheres, the smaller
particles (sub-micron in size) present the greatest potential health hazard in causing
or aggravating pulmonary diseases. At the present time, very little is known about the
source or composition of the pollution that has been reported although the SDAPCD is
scheduling tests. The APCD has reported, however, that "considerable testing would be
required to determine the over-all short-term and long-term effects of the sub-micron
particles." The APCD reports that without this testing it will be difficult to determine
the impact of the proposed development, but that currently, both the capital and operating
cost of such a project (requiring at least 3 stations measuring nitrogen oxides, sulfur
dioxides and particulates) is beyond the fiscal means of the District. Because of poten-
tial seriousness of the problem, the likelihood that the Encina power plant is the source,
and the difficulties expressed by the SDAPCD in being able to expeditiously eliminate
the problem, the conditions above are necessary for the Commission to find that the
applicant has met the burden of proof that there will not be a substantial adverse
environmental effect from the proposed development.
4« Wate_r Quality. The impacts of Encina 5 on marine life are not well known,
but the potential for adverse impacts are significant, particularly with respect to the
offshore kelp bed to the south of the plant. The cooling system proposed is a once-
through system with the intake located in the westernmost of the 3 bodies of water that
make up Agua Hedionda Lagoon, and the discharge would be directly across the beach in
an existing riprap channel.
As proposed by the applicant, the cooling system would permit an expansion of the
volume of cooling water drawn through'the plant from the existing 3S2t°00 gpm for Units 1
through 4 to a maximum of 800,000 gpm. A majority of that increase in flow (250,000 gpm)
is the result of incorporating a dilution system needed to reduce the temperature of the
discharged cooling water to a maximum of 20 degrees F over ambient ocean temperature to
meet one of the specific objectives of the State Thermal Plan. The dilution system
is needed when the plant is operating at 100^ capacity and the temperature of the water
in the lagoon exceeds the temperature of the ocean by about 1 degree F. The flow is • •
A -8-
- increased in increments of about 60,000 gpm as plant load factors and lagoon tempera-
tures rise. The applicant estimates that the dilution system will be only operating
during limited periods of time, primarily during the summer months (see Exhibit 4)«
When the dilution system is not operating, the increase in flow with Units 1 through 5
operating will be from the existing 382,000 gpm to about 550,000 gpm.'
A significant proportion of the waters of the lagoon may thus be drawn through
the plant; Agua Hedionda Lagoon has a surface area of about 250 acres and if conserva-
tively assumed to be an average of 8"ft. deep would have a volume of 2,000 acre-feet.
The amount of water drawn through the plant on a daily basis at 800,000 gpm would be
about 3,54-0 acre-feet. Without the dilution system, Encina 5 would represent an increase
in daily flow from 1,635 acre-feet from Units 1 through 4 to about 2,400 acre-feet.
a* Cooling System Intake and Impacts to Agua Hedionda Lagoon. There is
very little information available on the impact, if any, of the increase in cooling
water volumes on the marine ecosystem of Agua Hedionda Lagoon. To use the Encina site
with its intakes in the lagoon, SDG&E had to dredge the lagoon. Maintenance dredging
of the inlet and outer lagoon continues every other year. There appears to be a general
consensus that opening the lagoon has had a beneficial effect on habitat in the lagoon
by improving flushing action. On the basis of the minimal studies that have been con-
ducted at the site, however, it is impossible to predict whether the increase in cooling
water volumes will have any substantial adverse impact from the entrainment of marine
organisms or altering circulation and salinity distribution and hence the marine eco-
system of the lagoon ac it now exists. There appear to be fewer problems with entrain-
ment of adult fish at Encina than many other power plants because of the lower concen-
tration of such fish in the lagoon and the low intake velocity. Loss of eggs, larvae,
and juvenile fishes entrained in the cooling water have not been studied to the extent
that any reliable estimates of loss could be made. •
The applicant contends that the impact on the lagoon should be minimal, because the
increase in cooling system flow is not great compared to the flushing action of the tides,
and that the water for the cooling system is likely to come directly from the inlet of
the lagoon rather than circulating throughout the entire lagoon before entering the
cooling system. If virtually all of the cooling water did come directly from the inlet
of the lagoon without circulating much, the adverse impact of the increase in entrained
organisms would probably not be substantial; however, there is little data to substan-
tiate such a circulation pattern and intake water temperatures indicate that much of the
cooling water has circulated through the lagoon. If it has circulated through the middle
and upper portions of the lagoon, the increase in flow could affect the ecosystem of the
lagoon.
The temperature differential between the water at the plant intake and ambient
ocean temperature (see Exhibit 4 showing the amount of time "the dilution system may be
operating) appears possible only if the intake water has been circulating throughout
the lagoon or discharge water is recirculating a large amount of the time through the
system under up coast current conditions. The applicant has stated that the warmer
temperatures in the lagoon may be from either source but has not made any of the studies
that would be required to determine current patterns, although the applicant reports that
such studies were conducted for its plants in San Diego Bay.
Given the little information available concerning current patterns in the lagoon,
it is impossible to determine whether the increase in intake flow from Encina 5 (44?°
to 109$ increase, depending upon the operation of the dilution system) will adversely
affect the marine ecosystem of the lagoon. As one of the few remaining Southern
'California lagoons, Agua Hedionda Lagoon is clearly an important coastal resource and
any significant disturbance of its ecosystem would be inconsistent with the Coastal Act.
Given the minimal impact of the existing generating units on the lagoon, however, it
does not appear that there is sufficient probability of significant adverse impacts to
warrant denial under the Coastal Act.
f :'
^__«____ on Kelp. The existing
cooling system for Units 1 through 4 and the proposed system for Unit 5 discharges
cooling water across the beach in » riprap lined channel. They do not comply with the
specific objectives of the State Thermal Plan which require an offshore discharge or a
closed cycle system such as cooling towers. A variance from those standards" was applied
for and received from the San Diego Regional Water Quality Control Board but the State
Water Resources Control Board has ruled that the applicant has not justified a variance
on the basis of existing information and has required more studies; construction was
permitted contingent upon further studies and retrofitting of the system with an off-
shore discharge depending upon the results of the studies.
The requirements of the State Thermal Plan have been largely superseded, however,
by the more stringent statutory requirements of the Federal Water Pollution Control Act,
which prohibit thermal discharges after 1981 for a plant such as Encina 5 and would
require a closed-cycle cooling system. An exception to the Federal Water Pollution
Control Act standard has been applied for by SDG&E under Section 3l6a of that Act, but
further studies must be conducted to determine if the exception standard ("assure the
protection and propogation of a balanced, indigenous population of shellfish, fish,
and wildlife in and on the body of water into which the discharge is to be made") can be
met. The San Diego Regional Water Quality Control Board has rejected the applicant's
first study proposal as inadequate to make the determination necessary under Federal law,
but no determinations, have been made of the adequacy of subsequent study proposals.
The State Dept. of Fish and Game initially questioned the discharge system pro-
posed by SDG&E because of the potential impacts of the thermal discharge on a 75-acre
kelp bed offshore and just south of the discharge. The applicant contends that the
impact of Units 1 through .5 will be essentially the same as the impact of Units 1
through 4» and that those units have not had any significant adverse effects on the
kelp habitat. The applicant contends that only 2-3 acres of the canopy of the kelp
bed comprising about 3-5$ of the stand has been destroyed, and that juvenile kelp con-
tinue to grow under the thermal plume. The applicant contends that the existence of the
juvenile kelp indicates that the wildlife habitat provided by the kelp bed will survive
the addition of Unit 5.
However, data compiled by the National Oceanographic and Atmospheric Administration
show that for 21 out of the 24 months prior to the public hearing, the average monthly
ocean temperature had been below the 20-year mean ocean temperature for those months,•
and therefore the thermal discharge from Encina 4 would likely have had less impact than
normal on the kelp bed. The Dept. of Fish and Game has also noted that "...evidence '
indicates that Macrocystis beds are damaged by persistent temperatures above 20° C • .
(68° F) for more than several weeks, and by persistent temperatures above 24° C (?5.2OF)
for more than one week. Information supplied by the applicant predicts that the dis-
charge plume from Encina Units 1 through 5 combined could increase the surface water
temperature in a nearby downcoast kelp bed. ..to at or above 66-70° F on a chronic basis
for possibly six to eight months per year.... Although these temperature increases are
predicted to be limited to the upper 10 feet of the water column, this provides little I
relief to the kelp bed; for the major photosynthetic surfaces and biomass of Macrocystis
plants are found in the regions of highest illumination, namely on the distal end of
the plant near the water surface.... Our information indicates that Macrocystis is more
desirable than .other species of algae. First, Macrocystis presently supports a substan~ j
tial commercial harvest, while other species of algae do not. Secondly, diver observa- j
tions have revealed that Macrocystis seems to provide a better habitat for marine fish
and invertebrates. Other attached algae cannot grow in water as deep as Macrocystis,
and provide less canopy and cover to sustain marine organisms."
Thus, there is testimony that the effect of Unit 5 will be detrimental to the
existing kelp bed. What is not clear ±s the extent of the degradation. The Environmental
Impact Report prepared by the California Public Utilities -Commission conclxided. that
there is "no accurate way to predict the effect of the increased discharge upon the
kelp beds due to the addition of Encina Unit No. 5* It appears that the only way to
determine the effects of the thermal discharge is from observing the effects on the kelp
beds after Unit No. 5 has been in operation...." Because of such uncertainties, the
applicants have agreed to the conditions above to restore the amount of habitat pro-
vided by the kelp bed even if it is damaged. On that basis, the Dept. of Fish and
Gar.ie has withdrawn its opposition to the proposed discharge -at this time.
The California Public Utilities Commission EIR also noted several other impacts
from the proposed across-the-beach discharge: .
"Impact on Ir-tertidal Sand Beach Community. The effect of the temperature rise
associated with Encina Unit 5 will adversely affect certain organisms as specified in
the Draft EIR. . . . Significant adverse effects to marine organisms will occur only in
an area near the point of discharge comprising about seven acres of intertidal beach
"Impact Upon Agua Hedionda Lagoon. ...The operation of... Encina 5 could have the
effect of slightly raising the temperature Of the lagoon. Compounding conservative
assumptions of high tide, high current speed, full plant load and a high lagoon heating
value, SDG&E estimates that the lagoon temperature may rise as much as 5 degrees F for
short periods of time. This predicted lagoon temperature increase will occur infre-
quently. ... This temperature rise would be reduced if offshore discharge of the cooling
waters... is implemented."
In addition to the above impacts, the use of biocides and heat treatments to keep
the cooling system free of marine growths will have an adverse effect on water quality,
although its -extent win not be great. ' '
c. :Ai.t ernat ive Pis c h arg e J3y st ems. Although there is little specific or
up-to-date information on alternative cooling systems, a review of the available informa
tion indicates that a well located and designed offshore diffuser may offer the most
reasonable alternative to the across-the-beach discharge proposed. The closed cycle
alternatives such as cooling towers or cooling ponds present other significant .environ-
mental problems such as additional degradation of the scenic values of the area and
impacts on prime agricultural lands. Available information is not sufficient to make.
findings as to specific impacts however. An offshore diffuser would have temporary con-
struct ion impacts to the marine environment and would increase the time entrained organ-
isms were subject to increased temperatures. However, the California Public Utilities,
Commission EIR noted: "A comparison of the environmental impacts on the "marine- environ-
ment of continuing the across-the-beach discharge system leads to the conclusion that
the risk of producing irreversible environmental harm with the offshore discharge
system is less than if the across-the-beach system is continued with Encina 5 in opera-
tion. The offshore discharge is the preferable system from the point of view of pro- •
viding protection to the existing environmental setting." In issuing the development
a certificate of public convenience and necessity, however, the Public Utilities Com-
mission found that the then estimated $18.5 million cost of the offshore diffuser was
not justified. It did require the cooling system be designed with sufficient flexi-
bility that retrofitting was possible just as the State Water Resources Control Board
had done.
5. Scenic. Resources. The Encina power plant is south of and adjacent to Agua-
Hedionda Lagoon between Carlsbad Blvd. and 1-5 (Exhibits 1 and 2). Viewed from the
beach or from cars on Carlsbad Blvd.,. the power plant is an imposing concrete structure
about 130 ft. tall and 500 ft. long (a wall extends about 100 ft. south of the building
proper giving the building the appearance of being about 600 ft. in length when viewed
from some angles). The power plant also dominates the view from 1-5 for drivers travel-
ling either north or south. The proposed development involves adding 18 ft. to the
-ii- W-
height of the building, 246 ft. to the length, and replacing the 4 existing stacks with
a height of 190 ft. above MSL with a single stack that is 400 ft. above MSL in height.
The expansion will increase the area from which the plant is visible from the existing
9 sq. mi. to 34 sq. mi. Consultants to the City of Carlsbad estimated that the popula-
tion visually affected by the existing plant in 1975 would be 11,938 while the number
affected by the proposed development would be 27i 998. The number of people affected
in 1985 by the proposed development was estimated to increase to $6, 691« The same con-
sultants estimated the proposed plant expansion to be about 2.3 times more viewable by
passing motorists on 1-5 than the existing plant because of the greater viewing time
resulting from the expansion.
The proposed expansion and 400 ft. stack would substantially interfere with and
detract from the line of sight toward the sea frorr. the 1-5 freeway, the State highway
nearest the coast. However, alternatives to the 400-ft. stack, euch as scrubber systems,
would also have significant visual impacts as well as using more land and energy to
operate.
6. Need for Encina 5« Given the uncertainties surrounding some of the environ-
mental impacts of Encina 5> the question of need for the development was argued exten-
sively at the public hearing, the applicants contending that a clear public need for the
project had been established, the opponents asserting that 'energy conservation measures
would eliminate any compelling reason for its construction. Since that time, the Public
Utilities Commission has held new hearings on the need for the plant and has issued
the applicants a certificate of public convenience and necessity for Unit 5- The
decision of the Public Utilities Commission can be summarized as follows: (l) Fore-
seeable energy conservation measures may not sufficiently reduce demand for electrical
energy in the period between 1978 and 1981 (when other baseload units are to come on -
line), and that during this period, Encina 5 was required to maintain a high degree of
system reliability; (2) there is sufficient generating capacity available to meet anti-
cipated demand, but the unscheduled outage of 2 or more major units would result in a
deficit during periods of peak demand; (3) no alternatives "to Encina 5 were considered
feasible given the time required to gain approvals and construct the units except gas
turbine peaking units; and (4) gas turbine peaking units were rejected because they
would be less efficient, burn more expensive fuel, and would not provide long-term
baseload generating capacity.
7- Mitigating Conditions. Although the expansion of the Encina power plant is
generally preferable to the construction of facilities at an entirely new site, there
are some known adverse environmental impacts of the proposed development and some environ-
mental impacts the significance of which have not been completely resolved. Thus, the
mitigating conditions above are necessary under Pub. Res. Code Section 27403 and in order
to make the findings required by Pub. Res. Code Section 27402. A summary of the condi-
tions is set forth below:
a* Permit Approvals. Because the applicant's permit from the City of
Carlsbad to construct the 400-ft. stack has expired and because the stack as proposed
is necessary to meet local ambient air quality standards, no construction would be
permitted until a new permit has been approved.
b. Air Quality_Moiiitorin^ and Emission_ Controls. Because of the absence
of comprehensive air quality data, the availability of monitoring equipment is neces-
sary to assure that the level of emissions -claimed for the project are met and can be
enforced. The condition requires that monitoring equipment and sites for that equip-
ment under certain circumstances are available to the San Diego Air Pollution Control
District. Although it does not appear thet the Dist. now has the funds to immediately
operate the monitoring system (i.e., it would require funds to pay for one year of a •
person's time), the provision of the equipment will permit use of the system upon the
budgeting of operating funds.
-12- '
Because of the extreme uncertainty surrounding the source and extent of the
property damage and health effects to local residents of the particulate matter des-
cribed in Finding 3b, and because of procedural difficulties encountered by the San
Diego Air Pollution Control Dist. in requiring abatement of such emissions should
their source be the Encina power plant, the condition requires the applicant to
install such emission control devices or use such operating procedures as are deter-
mined necessary by the San Diego APCD when its studies are complete.
Ct Kelp Resources. Because of the uncertainty over the extent of the
damage to the kelp beds offshore of the'proposed across-the-beach discharge' 'from the
cooling system for Encina 5» the condition requires the applicant to establish and fund
a monitoring program under the supervision of the Dept. of Fish and Game and to fund
a kelp planting program under the supervision of the Department should the existing kelp
bed be damaged. The condition also requires the applicant to provide flexibility in
the design of the project so that it can be retrofitted with an offshore diffuser
should one be required under the terms of the Federal Water Pollution Control Act
or other State laws. .
d. Beach Access. The applicant owns approximately 20 acres of beach •••
with about 2,100 ft. of ocean frontage between the Terramar subdivision and the Carlsbad
State Beach. No. public access is now permitted to the beach, which is leased to the
employees of SDG&E. When the existing lease to the employees terminates in 1979, the
condition requires the applicant to dedicate a recreational easement over the parcel to
the State Dept= of Parks and Recreation so that it can be used for public recreation
in conjunction ivith the adjacent State Beach.
e. Berm and Landscaping. To minimize the visual impact of the proposed
development, the condition would require the extension of the existing berm adjacent
to the 1-5 freeway to the applicant's southern property line where it would then be
extended west'to the railroad right-of-way. . .
A\\A»m»j&\ • "^.\ 1 \ \\'vV^V'vH ' ^ ' . SCALE 1:24000 si
\ \\\ VA:¥% \ '•- >\v -SAM LUIS REY, CALlF.ji
\ \. V\ \ \'-\ *>- V. ">>V, NFV* ocz*:iv.3£ i* r-'JAW^ts t
\ NvV\ \ \ ^ ^- V, "-W-, - Kmn7^_v;n7l5/7.5 J;—'.VI 1715/7.5 I?
()
*
WILLIAM SIMMONS
Air Pollution
Control Officer
Appeal No"78-75
AIR POLLUTION CONTROL ^STRICT
COUNTY Of: SAN DIEGO
9150 ChBsapc.ikc Onve
Sa<i Pica". Calif. 92123 •
(711) 50r>-r>901 (MS017G)
NO\fTO 1975 :'"
November 7. 1975
Frank Broadhead . •
Senior Permit Analyst
California Coastal Zone Conservation Commission
1540 Market Street, 2nd Floor
San Francisco, ,OA 94102
Dear Mr. Broadhead:
The purpose of this letter is to inform your staff of recent air pollution
problems which have occurred in the vicinity of San Diego Gas fi Electric
Company's Encina power plant. You may want to consider the contents of
this letter when you make your recommendation to the Commissioners on .
the proposed Encina 5 power plant.
The San Diego County Air Pollution Control District has, during the past •
several months, received complaints alleging air pollution damage in the
immediate vicinity of the plant. The District's initial investigation
determined that the damage to house and auto paint was due to the
disintegration of cenospheres. These cenosphcres are composed, in part of
ferrous metals with some sulfates present. A primary source of cenospheres
is the combustion of liquid and gaseous fuels in power plant size boilers.
The size and quantity of the cenospheres is related to the inorganics in
the fuel and the condition of the burner nozzle.
The disintegration of these cenospheres in the presence of moisture has
at least two known effects. These are: . '
a) The fei-rous metal creates an orange-brown spot.
b) The sulfates react to sulfuric or sulfurous acid. The
acid then deteriorates the paint on homes and cars.
- 2 -
California Coastal Zone
Conservation Commission November 7, 1975
In addition to the above problem these citizens hnvc complained of plant
damage. The District has not at this time performed a pathological study
of the plants to determine the cause of the damage.
The District is currently undertaking the following investigative program
in an effort to determine the source of the pollution and the extent of
damage throughout the area.
1. By November 17, 1975 initiate impactor ambient sampling in
the area of the power plant (one week) . ,.
2. By November 17, 1975 initiate in-stack sampling with a cascade
slide iinpactor, a minimum of two boilers will be tested during
normal conbustion and during soot blowing (one week).
•
3. By November 17, 1975 initiate Hi-Vol sampling (3 sites) in the
area of the power plant (2-4 weeks).
4. November 10, 1975 initiate preliminary plant pathology study
(2 days).
5. By November 17, 1975 initiate formal plant pathology study
(1-2 weeks)
6. November 6, 1975 extensive analysis of all fuel oil currently
in storage tanks. This analysis will be for sulfur content and
trace metals (2 weeks).
7. By November 26, 1975 submit all impactor slides to laboratory
for identification by x-ray flouresence.
8. By November 26, 1975 complete a photomicrographic study'
of the particles (by District).
9. By January 1, 1976 receive x-ray flouresence analysis
report from the lab.
10. By February 1, 1976 have all data assimilated in a report .
with conclusions.
The above investigative program will be initiated at SDGSE's South
Bay. power plant about two weeks after the Encina study has begun. One
of the more serious aspects of this case is determing if a health hazard
is present down wind from the plant during normal combustion. The
- 3 -
California Coastal Zone :
Conservation Commission November 7, 1975
available literature on this subject indicates that sub-micron
cenosphcres are generated in the combustion chamber. These particles
with their small mass then become airborne and may travel
a great distance from the source. Available literature also shows
that it is the sub-micron particles which pose the greatest potential
for causing or aggravating pulmonary diseases. Whether or not these
particular particles pose a health hazard is not known at this time.
Contact will be made with professionals who are knowledgeable in this
area to determine the health affects from these particles. Considerable
testing would be required to determine the over-all short term and long
term affects of the sub-micron particles. Currently the District
does not have budgeted funds for such a project, and if such funds
were to become available it would not occur until our next fiscal year. •
The Air Resources Board and the Federal Environmental Protection Agency
were queried by me as to the availability of special project funds for
this problem. I was given a negative response from both agencies.
Without this testing it will be difficult to prove or disprove the
total impact on the environment from this station.
Adequate ambient monitoring would require at least three stations
measuring nitrogen oxides, sulfur dioxide and particulates. Currently,
the capital and the operating cost of such a project are beyond the
fiscal means of the District.
Should you have any questions pertaining to this or any related matter
please feel free to 'contact me.
Sincerely,
RICHARD H. BALDWIN
Chief, Surveillance § Enforcement Division
RHB:kb
EtlCINfi. POV/SK. PLMT
PLANT C!R.CHL'i\TlSJG- UW£,?
WITH UNIT "5
TYP/CflL
ItoCKZteEb f-'LQW V
WITH DILUTION: OF
FLQ\ti TO
2P °F
\ MflXIM'AM A.~t~,~~~
(/O0'/0 Piflirr £0fib)\
(80% P£
K *
UJ>
O
§ 3
•^ y
O
800
£00
- \
200
AT
20 HO &o iso
(/,;j%; £0 '•'/••/ 5 87^0 /ytt
ENCiNfl
PLANT C/KCUf.flTM<r
-. '• WITH UNIT
TYP/CfiL '
L6\fl f/QO% PLMT LOK
'. .... . . -
S. FLVti ($0% PLRtttiofi$\
. : ' i . : i •
: !
IOOO\
900 -'en— •
600
i kl.- !
Y/)//T
PLANT C/%CUL/}riiVG- W/}7"£V? J>tSC r//l?G-
\ •' WITH U,\'IT
TYf/CP.L
lCVJ (I00ya PLfMT
&c. FJLOVf (80 % pLfiUTSb FLOW
WITH blLllTIOtf Of:. .
(SO%! Pifl.MT LOAti) ^^> -
LfiQOOfi A/
of £XC£££>£AA!£ C %)
. DISCHARGE CHANNEL
CNCINA POWCn f LANT
: .,
'''.:' • X'!*.«•'° ^^ W^t'P&'S'S&x&S^*
.-o—•3
o c-;o a DOO
• A-kO
0 0-10
fACIFIC OCEAN
OC.JO OO-H)
00-10
OO-20
'•'•'£ :
O 0-30
O(.50 c-t»
K£V, .
|/^j AREAOP KELFOCMIA/CnOX.)
j;>;\j AREA OC RCCKV BOTTOM (AfPROX.I
UAKINKET
f/7 Ant* Of COSSIOlt CCOlOCilCAL CMANSIJ
'.\] AntAOFy -yj AND fOiSIOVI [COlOUlCAl. CHANGS
E.\CI.NAPOVi-£P. (»LA.\
Un;;\a. S
tOICTiO U<7AC7 0? .U.L 3 VHITS,
5.1-15
July 1VJ3
f'; »
CALIFORNIA COASTAL ZONE CONSERVATION COMMISSION
1540 Market Street, San Francisco 94102-(415) 557-1001
.APPEAL SUMMARY'
Appeal No. 78-75
(SDG&E, Encina 5)
60th Day: 6/17/75
ISi^JOjlJl!!.
MQ^'^-^p.^'5^STff]; Permit denied by the San Diego Coast Regional. Commission
PERMIT
APPLICANT;, , San Diego Gas and Electric Company
LOCATION: Adjacent to the Pacific Ocean and Agua Hedionda Lagoon at the
'.,.. Encina Power Plant in Carlsbad, San Diego County (Exhibits lf 2)
IESCRLH;'ION: Construction of a 292 mw fossil fuel steam turbine generating
unit with associated switching facilities and transmission
lines, and replacement of 4 existing 190 ft. stacks and one
400 ft. stack (Exhibits 2t 3, 9, 10)
San Diego Gas and Electric Company
AjjPEIJ,ANT ^CONTENDS _THAT;
1. "...Any inconsistency with the Act cannot be supported, based on the record
belowa«.therefore, the permit was wrongfully denied after applicant had met the burden of
proof required.e."
2. The development has received construction permits from the APCD and meets appli-
cable Federal, State and local air quality standards. Total, air basin emissions will be
reduced by the development and 600,000 barrels of oil saved annually. The Regional
Commission staff judgment that "significant air quality problems could result from the
' construction of Encina 5" is not supported and is unreasonable.
3« The applicant has agreed to mitigate any adverse impacts to offshore kelp beds
as required by RWQCB if it is necessary. The adverse effects to th.e lagocn-sca ecosystem
claimed by the Regional Commission staff are not supported.
•"'^ 4* The development will not harm scenic resources. The elimination of the existing
stacks and replacing them with a 400 ft. stack will be an improvement. The facilities
to be constructed will be enclosed in the building so it will not harm scenic resources.
5. Public access would not be affected by the development.
6. The Regional Commission did not act to protect public health, safety, and welfare,
and private property as denial will result in a shortage of electric energy.
7« The Regional Commission's decision is contrary to the intent of Proposition 20
since it prohibits power plants in the coastal zone. The Regional Commission staff
wrongfully determined that there was not a need for this plant until 19SO and that it
could then be met by an alternative site. The evidence refutes this0
8. No findings were made by the Regional Commission as the project was denied for
lack of the necessary affirmative votes, . .
9, The Regional Commission should have reconsidered the development but .was wrong-
fully advised by the Attorney General. " ' "*• •'••-•-»"-
10. A 2/3 vote should not have been required.
.SUBSTANTIVE FILE DOCUMENTS;
1. Regional Commission file.
2t Notice of Appeal.
3. Photographs and renderings.
STAFF NOTES: .
1. Background. The proposed development is a 292 mw fossil fuel, steam turbine,
base load, electric generating unit. It would be built at the Encina Power Plant (includes
existing Units 1 through 4) in the City of Carlsbad, on the inland side of Carlsbad Blvd.
which runs along the beach and south of and adjacent to Agua Hedionda Lagoon. The power
plant is highly visible from along the beach as well as the 1-5 freeway which parallels the
beach in this area0 The cooling system would be a once-through system with the intake
inside Agua Hedionda Lagoon and the discharge directly across the beach in a rip-rap channel
A 2/3 vote requirement was adopted by the Regional Commission because of adverse
effects on water quality and interference with ocean views from 1-5. A permit was therefore
denied when the application received 7 affirmative votes with 8 votes needed for approval.
In the Regional Commission's discussion, the following issues were identified:
(l) air quality issues involved in a fossil-fuel power plant in the agriculturally-
productive north county area, which is part of a critical air area; (2) water quality
issues involved in bringing oil into the Encina terminal next to Agua Hedionda Lagoon
and a once-through cooling system that would increase the flow through the plant from
300,000 gallons per minutes (gpm) to 800,000 gpm, could affect an offshore kelp bed and
Agua Hedionda^ Lagoon, and does not meet the standards of the State Thermal Plan;
(3) aesthetic" issues involved in enlarging the power plant near the beach and replacing
4 stacks with a height of 190 ft. with one 400 ft. high stack; and (4) the need for the
additional generating capacity and alternatives to Encina 5» The relationship of the
project to adopted policies of the Energy Element was also considered. (See Regional
Commission staff recommendation and SEG&E response.)
2» Air Quality. On the assumption that Encina 5 will burn 2.8 million barrels of
0.5$ sulfur content oil per year (APCD Encina Status Report, 2/75), emissions will amount
to 12.6 tons/day of S02? 6.2 tons/day of NOj: and 1.7 tons/day of particulate matter.
NOX contributes to photochemical smog and S02 can be transformed into weak sulfuric acid
in foggy coastal areas.
An additional point source of this magnitude may present significant problems. The
San Diego Air Basin has been designated as a critical air area. It also has the potential
for more severe air pollution problems than the South Coast because of meteorological_
conditions. The productive north- county agricultural areas around Carlsbad are particu-
larly susceptible to increases in air pollution.
Monitoring of the air quality impacts of the existing units at Encina outside the
plant has been limited to some local ground level studies conducted by consultants for
SDG&E (SRI). The San Diego Air Pollution Control District (APCD) has not conducted any
local area studies, but is now modeling the impact of the plant with the 400 ft. stack.
Studies based on the SRI data showed that Encina Units 1-5 would exceed ambient ground
level standards near the plant if th.e. existing stack arrangement and height were used.
In response, SDG&E proposed to replace the existing 190 ft. stacks with a single 400 ft.
high stack, to disperse pollutants to avoid high ground level concentrations and thereby
meet State and EPA standards. Studies conducted by Bechtel for SDG&E concluded that with
the 400 ft. stack: "when 0«,5% sulfur oil is burned, the maximum 24-hour average 862
concentration is calculated to be 73 [micrograms]/nK, which is 70% of the California
standard. o. The maximum 1-hour average NO 2 concentration is calculated to be 374
[micrograms]/m , which is 80% of the California standard, based on* »« very conservative
assumumption. .." Thus, unless other emission controls are installed at Encina, such as
scrubbers and/or retrofitting the existing units, it appears that the 400 ft. stack
would be necessary to meet ground le.vel air quality standards. The visual impact of the
400 fto stack is discussed below and shown in Exhibit 3»
The Bechtel figures, however, are based only on the emissions from the Encina units
and do not take into account background levels because the SRI studies "concluded that
background levels would be small. This may not remain true in the future, however, as
the Macario Refinery is planned as part of an industrial park to the east of Encina near
the Palomar Airport « Although within the coastal zone, the site is outside the permit
area* And, even with the 400 ft. stack, it appears that the operation of Units 1-5 to-
gether will result at some times in an increase in the existing ground level concentra-
tions measured by SRI.
Although the 400 ft. stack will reduce ground level concentrations near the plant,
it has no impact on the amount of emissions into the air basin. However, Encina 5 is
more efficient and has better emission characteristics than older, dirtier units within
SDG&E1 s system.. Therefore, the applicant contends that emissions into the San Diego
Mr Basin will decrease with the operation of Encina 5 because Encina 5 will be run
most of the time while older units will only be used to meet system peaks. The appli-
cant's computer simulations of its system show that with existing demand, the operation
of Encina 5 will reduce fuel consumption by 600,000 barrels of oil per year (about the
amount the existing Encina units burn. in a month). However, because of the characteristics
of the applicant's models, it is not known whether emissions will increase during system
peaks. Long term forecasts of emissions are also not available at this time although
the applicant's submissions on 'other permits indicate that oil usage (and presumably
emissions) in their system will increase. Becatise of the lack of information, however,
the staff cannot determine what proportion of the increase is projected because of cur-
gas supplies and what is expected from increased demand.
Marine Environment. The Encina Power Plant uses a once-through cooling system
intake located within Agua Hedionda Lagoon and the discharge in a channel that
runs. across the beach (Exhibit 5)» With the construction of Encina 5, the amount of
cooling water drawn through the plant will increase from 300,000 gallons per minute (gpm )
to 800,000 (gpm). A significant portion of the increase is to dilute the cooling water
to reduce its temperature upon discharge so that it meets the standard of the State
Thermal Plan prohibiting discharges with a temperature greater than 2QOF above ambient.
The cooling system does not meet other standards of the Thermal Plan, however, because
it. discharges directly across the beach and not through an offshore diffuser. The
cooling system also does not comply with the general standards of the Federal Water
Pollution Control Act which requires closed cycle cooling systems. An exception under.
Section 316 of that Act has been applied for and a variance from the State Thermal Plan
is being pursued (the San Diego Regional Water Quality Control Board has approved the
variance but it has not cleared the State Water Resources Control Board or EPA).
There are several potential impacts of this project on the marine environment. Infor-
mation in this area is limited, however, because of the minimal studies conducted at the
plant. To utilize the Encina site with its intakes within Agua Hedionda Lagoon, SDG&E
had to dredge the lagoon. Maintenance dredging continues every other year. There appears
to be a general concensus that the opening of the lagoon has had a beneficial effect on
habitat in the lagoon by improving flushing action. Increasing the flow through the
cooling system from 300?000 gpm to 800,000 gpm, however, may have adverse impacts in terms
of entrainment of marine organisms in the lagoon, scouring of eel grass in the lagoon
that provides important habitat, and altering circulation and salinity distribution
within the lagoon. There appear to be fewer problems with entrainment of fish because
of the lower concentration of fish in the lagoon and the low intake velocity.
The discharge system also has associated impacts that are not subject to definitive
answers because of the limited studies that have been done in the past. The discharge of
the heated effluent is through a conduit under Carlsbad Blvd. and then through a rip-
rap channel across the beach (Exhibit 5)» The State Department of Fish and Game has
opposed the proposed discharge because of the potential effects on a 75~acre kelp bed
offshore and south of the plant. The expansion of the thermal plume with the construction
of Encina 5 under the generally downcoast currents will adversely impact the kelp bed, •
(Exhibit 6). The applicant contends that the adverse effects will not be significant
(Exhibit 7); but, if the kelp bed is substantially affected after the plant begins oper-
ation, the applicant has agreed it will mitigate the impact by. changing the plant.
The impact on the kelp bed could be eliminated by the construction of an offshore
diffuser system that was properly designed. Such a system would also comply with the
State Thermal Plan although it would still require a Section 31° exception from the
standards of the Federal Water Pollution Control Act, It has been noted that plankton
mortality from entrainment will be higher with a diffuser because the organisms are
exposed to elevated temperatures for a longer period of time. However, the increase in
mortality may not be very high if, as some marine biologists believe, most mortality
is from mechanical stresses and sudden increases in temperature,, But as with many such
issues, past research does not provJ.de definitive answers. An offshore diffuser would
also reduce the possibility of recirculating heated discharge water into Agua Hedionda
Lagoon under the limited times when there is an upcoast current. Information in the
file on cooling tower alternatives, such as those using salt water, is very limited
although it is clear that some agricultural land would be effected if such an alternative
was proposed.
.-'SP*"'
It was also brought out at the Regional Commission hearings that sting rays are
found in high concentrations around the existing discharge. If the concentration is
related to the discharge, the increase in the thermal plume from Encina 5 could bring
more sting rays to the beaches in Carlsbad, thus reducing their recreational value*
4» Scenic Resources, The Encina Power Plant is located next to Agua Hedionda
.Lagoon between Carlsbad Blvd. and 1-5 (Exhibit l). From on the beach or driving on
Carlsbad Blvd., the Encina Power Plant is an imposing structure about 150 ft. tall and
200 yds. long. The power plant is also highly visible from 1-5 (Exhibit 3), With
the addition of Encina 5, the structure housing the Encina Units will be enlarged by
about 150 ft. in length and an additional 18 ft. will be added to the height to hide
duct work and piping. The 4 existing 190 ft. stacks will be replaced by a single stack
-5-' '
with a height of 400 ft. above mean sea level. (See Exhibit 3 for various views of
existing and proposed structures.) The 400 ft. stack will be visible within a 34 sq.
mile area from as far away as 5 miles. (See Exhibit 4 for area within which the stack
will be visible.) The purpose of the 400 ft. stack is to disperse air pollutants as
mentioned above in the section on air quality.
^ The applicant hired a consultant to produce a public opinion study of the reaction
to the 400 ft. stack. Using colored reproductions of the 6th and 7th pages of Exhibit 3
for comparison, the consultants found that most respondants favored the expanded power
plant design. The State Commission staff has not yet evaluated the survey methods employed
but there does appear to be a question of whether the renderings chosen were the most
favorable to the expanded plant (i.e. see other pages of Exhibit 3 for other comparisons
of existing and proposed structures).
The San Diego Coast Regional Commission determined that a 2/3 vote was required
because of the additional blockage of ocean views from 1-5 from the expanded building.
5* .Determination oft Heed for Encina 5. The Regional Commission staff recommended
that because construction and operation of Encina 5 would have potential adverse impacts
on coastal zone resourceS| an assessment of the public need for the facility should be
made. Such an assessment involves a comparison of peak load fore-casts for the SDG&E
service area against planned generating capacity, with and without the proposed power
plant unit, to determine whether Encina 5 is essential to maintenance of an adequate
system reliability index and reserve margin.
Presumably a finding as to public need will be part of the California Public Utility
Commissions*s (CPUC) decision on SDG&E's application for a certificate of public conveni-
ence and necessity. Although the CPUC staff has issued the final Environmental Impact
Report on Encina 5» and has supported the applicant's assertions that the plant is
needed, the case has not yet been placed before the Public Utilities Commission, and
there is no possibility of CPUC action on the matter prior to Coastal Commission consider-
ation.
The Regional Commission staff strongly questioned the accuracy of the applicant's
peak load forecasts (see Appendix to Regional Commission staff recommendation). While
crediting SDG&E with an improved forecasting model,' the Regional staff concluded that the
forecasts do not reflect the full- potential for long term energy conservation* The staff
identified increased electricity prices, the increasing shift from single family dwellings
to more energy-efficient multiple housing units, an anticipated decline in the growth
rate of home appliance use, energy conservation standards for new buildings requiring
improved building technologies, and the possible use of thermal solar equipment for space
hearing and cooling, as factors suggesting a continuing increase in the impact of energy
conservation efforts on load forecasts. SDG&E, on the other hand, asserts that energy
conservation potentials are fully included in their forecasting models* Neither the
Regional staff nor the applicant has addressed the additional possibility that use of an
alternative rate structure might help to shave the sharp peaks characteristic of the
SDG&E system load, thereby lessening the need for the Encina plant.
The Regional staff further challenged the projections made for other independent
variables on which the forecasting models are based in part, such as Gross National
Product and Personal Disposable Income.
After concluding that applicant's long range peak load forecasts are possibly too
high, the Regional staff proceeded to consider the applicant's planned generating capacity.
Encina 5 represents 292 mw of a total of 1,518 mw additional capacity scheduled to come
on line by 1984, including 3 gas turbine peaking units in San Diego (June, 1979; already
approved by the Coastal Commission), 4 coal-fired units atKaiparowits in southern Utah
(first.unit, June, 1981; last unit, December, 1983), and San Onofre Units 2 and 3
(October, 1982; approved by Coastal Commission), The applicant's proposed 404 mw combined
cycle fossil fuel plant project at Sycamore Canyon, originally scheduled for operation
in mid-1979, was recently abandoned -by the company.
The Regional staff found that the most critical need for Encina 5 would occur in
early-middle 1981, prior to operation of the first Kaiparowits unit. Assuming the
accuracy of the SDG&E peak load forecasts, estimated system reserve margins over firm
load without Encinca 5 would drop to 4»3$ at that time. With Encina 5, the margin would
be 13.8%;revival of the Sycamore Canyon project as a substitute for Encina 5 would
clearly increase the reserve margin to well beyond 13•8$. Utilities typically like to
maintain a reserve margin of at least 15$ although SDG&E prefers to maintain a reserve
margin of at least 20$ to cover the possibility of a forced outage on its largest operating
unit.
The Regional staff concluded that need for additional generating capacity is demon-
strated only for the critical period—1980 to 1981—unless strong energy conservation
measures can substantially reduce peak loads below SDG&E projections, or unless the
Sycamore Canyon project were substituted for the Encina 5»
6. Alternatives to Encina 5» The primary thrust of the Regional Commission staff
recommendation for denial was that there were adverse effects from the project and that
there was- not a sufficient need demonstrated to justify approval; that the main alter-
native to the project was to rely on improved energy conservation measures to reduce the
growth in demand until other baseload units such as San Onofre come on line. (See pre-
vious section on demand above). A second alternative, considered was the reactivation of the
Sycamore Canyon 404 mw combined cycle plant. The Sycamore Canyon site is located inland
and was planned to come on line in 1979. It is exempt from the permit requirements of
the State Energy Commission. According to the applicant, cooling water was to be supplied
primarily from reclaimed municipal waste water with only minor amounts of fresh water
and the plant would have been about 10$ more efficient than Encina 5. The cost of the
404 mw Sycamore Canyon plant has been estimated at about $304 million where Encina 5
is estimated to cost about $94 million for 292 mw (the increase in dollars/mw is largely
attributed to the fact that all of the Sycamore Canyon site development costs would be
allocated to the first 404 mw even though another 400 mw could be placed at the site,
whereas the site development costs at Encina have already been paid). The engineering
contracts on the Sycamore Canyon site have been cancelled because of decreases in demand,
but the SDG&E annual report states that it can be "revived quickly", and the applicant's
representatives have stated that it could be on line by 1980-81.
.->>>•'' " ' •In addition to the above considerations, the Regional Commission staff recommendation
included proposed conditions in the event the Regional Commission voted to approve the
permit. The text of the proposed conditions is shown in Exhibit 8 and the applicant's
response is contained in its rebuttal to the Regional Commission staff recommendation.
7. Plan Policies. The full text of the Preliminary Coastal Plan policies adopted
by the Commission in the Energy Element and related Marine Environment policies are
attached in Exhibit 11. The policies1 include:
a. Marine Environment
(b)"...closed or evaporating systems should be required unless an applicant
can demonstrate that overall environmental advantages justify...the use of once-through
cooling systems."
'
(d)"...the best available technology should be utilized and best potential
site chosen to minimize the intake and mortality of all forms of marine life."
(e)"...best mitigation measures have been incorporated as necessary to
minimize effects on marine life."
(f)"...New discharges...in the vicinity of kelp beds should be prohibited
unless it can be conclusively demonstrated that there will be no significant adverse
impacts."
b. Energy Element
(l5a)"Energy conservation...cannot reasonably reduce base load and peaking
requirements sufficiently to eliminate the need for the proposed facility." See the
discussion of need in the Appendix to the Regional Commission staff recommendation which
concludes that there is only a one year period where excess reserve margins drop to a
significantly low level.
(l5b)"Greater presently identifiable adverse environmental impacts would
occur from utilizing alternative inland or coastal sites or alternative technologies..."
As the Sycamore Canyon site would use reclaimed municipal waste water and would be
more efficient than Encina 5» it may prove to have fewer or less significant adverse
impacts, even though it is a new site.
' (I5g)".«.ln no case shall expansion take place in a critical air area, or
in an area where coastal resources would be adversely affected, unless there would be
a net decrease in generating system emission of pollutants for which national or State
ambient air quality standards have been established. Normally the- requirement will
apply to each individual plant for which expansion is proposed... Reduction in emissions
may be accomplished by modernization or retirement of existing facilities."
'-^
\ EM GIN A PLANT V
\
\ \, \ V^ \ \
~A A• ••->•, °\ \*• 1 x
x \ >\ \ i\
\,"A\
N\Vxv
\\
\\
• n^i^mirnr.,.
SCALE "1:24000
\ '• N\v 'SAM LUIS REY, CALIF.
VVi- NE/'V OC^AriilDE 15' OUACHAr.'CLE
N3.307/J— VVH715/7.fj
Vicinity maji SDG&E Enema Plant.
KxirnriT 1
SAN DIKGO GAS tt tXtCTRIC COMPANY
SA.N [lii Crl I;.VL !f-',-;^.<(A
ENCINA POwE.IV PLANT
PROPriiTY F'l.AN
EXHTIVfT
il
o
B {Rcsuaaca if. I
3?
PLANT
G
SOURCE: Prepared by State Commission
staff by tracing photographs
submitted by applicant.
\
\
c
•"". , /*>
G,
-„•"?.
1.-A
-5
^^^^i^^- r&^^^ ^^ll^ii^^ ..««„. e, „. ^fi^,... ~ -.\ •_.'•'• ••'^•>:-rt. ..••-••-.•Jf'i'. ,'..',>'.•.••..'•.'<'••.; -... <i -'-t-'1/-'•*•••'••<?/ '.^ ".'••'•'--^ '•• !V; •'•*!' I-"1- r .'\ V -*"•-'•} '';- -•'••/ Nl '' -•','' '^-~'-' ----- . • £NC:NTAS. ANO Rii,C!ni i*.-.r* ft c-.»:--4-.i.£
r^'^t'^-ift^ —^^ - .
V^O:-^;?VC|\;5€S4"0^^ KSi{?^::-
sflitii^^
•'•. ~i\-v-'----:"-.'" -*;•'/•''';' C'-~~~''^^;~~'^^'<>^-'-:''''^ ""•" ••. " x' ''.'--''• ?' •'•'" ', ' '"" '- '• ' ';. , •: --^ . -.-• -..,-'/.••• .',-•• <•• -_L^_J->r-> .•-.-'% ' \f.-;-r -Vc--, ,i-i-V -->i\': >i.-./ ---.--v-,.- --^^ti-' .•^..^•>^ty!<--v'^i r<. ? >^ •-••x. A--., >^-, '•-. / •-•-'•- vo, .•:•-^: ,:-... \ •'• .--• ..-..• • . - *
'x/
yxj^,7-"-i _--;^ •- ''-.-'; /
/ \/. /
T ' . J ^^^^^'^f^il^• -^.. // .// ^ ^->.>-.;
/i'
-V " :
V, • \/•:>•" "^ V1^ 7\ ><-^-\ "-^ /-v^^/S-//^'!'^-^;-:-. -i.':>\ '-'• •-• -; -• 7. --- r.- A= "-• •-••'>'••^ ^^rr^^ -•*"• -/^>t v>'. •^•^-^--•^f.^.'?sS-^i«^i^=^;-'^^.-O;C ';•-.-•'V- <-'•-/'' ••'••C~'-'•'•'' '•' "- . ^ ''}••
I .'''-'L- '
.:.^^-'.
-'"'" ?i
';"ir"-'>"•*//.
\^-, .-\' r ' c \
<*,'
EXHIBIT
; \ T A '•'- - • C' 5 C H A
vGvc-^ norr*-£'iy c'.c'^c1! *.
/
Via-' L/VT.C! •; ; W.vV
•':H,m;:;v,
PACIFIC CCEAtl
(4
EXC!\A PO'.VER PLANT
L'n::,Vc. 5
O c;
rn in
LAG OON
DISCHARGE CHANNEL
'•~J/ I -
t' [ | ENC1NA POWER PLAN
I -
o c
'-"' i
O
C>
^ ""C
" 9
o rn
en -a
H
0 !CCO
SCALE i.N FEET
LEGEND
['_ ;: " | 4° ISOTHERM AREA
F^-v-vi KELP BED AREA
TOTAL TEMPERATURE RISE
CURRENT SPEED (FPS)
CURRENT DIRECTION
TIDE STAGE ;FT ABOVE lYiLLVV!
AMBIENT OCEAN TEMPERATURE
INTAKE TEMPERATURE
00 GPM
18.G°
0.3
DQ'/'.'NCGAST
5.0
70°
770
\."3
DISCHARGE CHAN'^SL
^ /^'^^^^^^
^ <•* . ." • /''•'' '•>'''/
\<A, tyJ-^^^^x^^^m^
Vv ..v^/.-. ••'.- -^ ^^;,.J L^-r^.:•'•-•• 0 I';'.;....
^-~r-.-:-:--:':7r^r^ '•^•''VV-<'v;'fe^>7.^,;v:/-:^>..•••; ...... •..-...-.->.-:•": >;-^:vo;-/^-x;>^'.<;^.. 0-=
"^* 'v'^^'°'' V;;'^^:'^v;:';-:;^'^:^^:/"
00.30 /•'>-x ' ''•'•'•'•.;.'/'.;'•'•'V- O
e c.;s * D.JO
& o-so
PAIIFICOCcAN
O 0-60
V £.iD
ARE< C.« FiOCKV iOTTCM -^
AT.ZA C.= KELP OCCiC (A^JOX,!
i V, j AKS/'OCSICLE CCGLGwICrtieHA
SCALE IIJfEET
CO-10
OC-IO
£ \CI\A ?C','.'£?. f1
Uri: No. 5
•
f) - KNC1NA UNIT 5 - APRl, 1971>
(l) To promote public access to the beach, 'that that portion of applicant's property
lying botv.'f.'on Carlsbad Boulevard and tin.; Pacific Ocean bo fully dedicated to the
State of California, for public park purposes, excepting easements thereof In
favor of.' the Utility for tlie_useJlQd_j:!£:'mtonanee of fuel trjnvsmij/islon lii'li-L.and
;oo.!.i:V': .wa.<er J 'ij-;i':_'j__ and dj.sch or .".•..:..ch-'ijir_./:'!._;_;, cui \• n;i !:.s arid ',"•[ J'.'jictu r.:_s d~th:~iv->Y-
(?.) To promote public access to the south side of /\gua Iledi.onda Lagoon east of
Interstate Highway !;, that prior to construction of Enc.i.na Unit 5, the applicant
submit and have approved by the Commission a public access plan, showing the
method and physical improvements necessary to promote public access to said
section of /the Lagoon. Such physical improvements as required shall be Installed
prior to the cormnercia.! operations of Unit 5- Full costs shall be borne by the
applicant.
(3) To "improve plant aesthetics, that all distribution and. transmission facilities,
excepting the switchyard, be placed underground, from the plant site.-to a point
Ij800 feet easterly of Interstate Highway 'j. Oil cooled pumping faciJ i ties
and/or other underground, transmission appurtenances shall be placed below ground.
.k^?<>w--pir-.w^^^
eeftpr:dH/;^'e.v!-ave^y'-^^
«e£*HH:iM^;-—ah->-:o3;p~o^
(.5) -T&H^pArfB:fi&-~^^o^G:;-~^
"^a«4~e^--4/Kr>4fel-u^^
ettt-£fri9~-4^-i!e-eetiea-;'v--:c-6~^4^^
to t ho •c
.s_iK}_ces:;sor ,_a/rvency._'
(6) To minimiy,o adverse impacts on off-shore resources, should publicly required
environmental monitoring sti.id.ies i-txT-^rf-wi^w indicate that the discharge waters
are not or w:i.].l not comply with the regu.lato.i-y requirements of State or Federal
water quality agencies, that iiy£>lLJ^i!llIlT2^.^
successor agency, the applicant shall imn.edJ ately undertake such modifications as
may be reasonably required to reduce such effects and comply with such regulatory
requirements.
('/) That no construction shall take place until' the applicant has acknowledged in
writing that they understand, all conditions imposed, herein and »gi:c\: to abi.de by
each and all.
EXHIBIT ->
'" r Mills >, U,..-.,on
::•'../"' i'.Vi»!o
, ....-.-.,•/- /."I. •'•''•'•'•.V.; I ,
•/' //| '•:'*>',./ I-1•
,* -
LJ'-':1-'^^'' •''^ f'-'J: '-'1. f!
~>- 1 '
ENC.NA POWER
NCI N A. POWER PL AW
Unit No. 5
SITE OF y'Rorosr
230-kV LINi.: ADDITXONS
TO CL3 T'-".'.:. r> TO CLLTDv-.1-;
P'r^Oiin V33KV
FI-.CM t.:::i:;A
f- V3 OLD fCi'.'J
'
i R/'.VL'^'E
FRCV. V.:i5:OK
TO DLL' TG.'.'\
I
I
iy.Vi.SKE I / ,1 M>
/
P *:, C D 2 S i - ;"'"<*.•' ."' 3 0." C* - - 7 3 - K V
F " C '•' V ; 3'" L '. f ?• 0'.' '.'' S C C 'i
T r. r • -i T r . . *. -* .-. "; • -, 1 '..- ..
Ca
-:s FT
?./;VC~.C£:S£=:T!ON u-u
'_• n:r. A c. 5
Adopted Statewide Policy Concerning Thermal Discharge
7. AVOID ADVERSE IMPACTS OE THERMAL DISCHARGES AM) ENTRA I.NMlv'IT
To avoid adverse effects of using seav/ater for cooling or heating In. power
and industrial plants:
a) A State agency should be adequately empowered and funded to direct and
coordinate research on the effects of thermal (heated or cooled) dis-
charges and entratnment of organisms on the marine environment.
[See (c) below.] '
b) Until more is known about the effects and. methods for miti-gatlng impacts
of once—through coo.ling systems, closed or evaporating systems should
be required unless an applicant can demonstrate that overall environmental
advantages justify both a coastal location and the use of once-through
coo.ling systems. [liefer also to the Energy element polltvi.es on pov/er
plant siting,J , • . •
c) Independent "baseline" studies of the existing marine .system should be
conducted, and. evaluated for all potential sites at, the applicant's
expense, several years in advance of the construe.!",ion of a major
fieawater-using power or industrial plant.
d) Where cooling or industrial processing waters ore drawn from marine
waters, the best available technology should bu utilised and best
potential site chosen to minimise the intake and mortality of all forms
of marine life (e.g., offshore intake points, velocity caps,, and fish
return systems).
e) Warmed or cooled water discharges should bo permitted only where rapid
.return of water to normal ambient temperature can bo assured and where
best available mitigation measures have been incorporated as necessary
to minimize effects on ma.rine life.
f) New discharges into coastal wetlands, mar.inc reserves, wildlife refuges,
education and research reserves, or in the vicinity of kelp beds should
^fs-r"-"-* be prohibited unless it can be conclusively demonstrated, that there '
will be no significant adverse impacts.
g) Existing and. new thermal discharges should be periodically monitored
(by independent researchers or a 55tatc agency), and appropriate
mitigation measures or alternative systems should be required v;here
significant adverse impacts are discovered.
ENi'.'.RGT KTJMEMT
Adopted Statewide Policy Concerning Power Plant Siting
MINIMIZE ADVERSE EiWlROm-iENTAL IMPACTS ON COASTAL }?!j,SO:J.aCES
I5ycau.se 'the coastal 7,0 nc represents a valuable, fragile, and finite resource,
.because pov.v/r plants have major potential impacts on land, use, air quality,
and the marine environment, because virtu.al.ly all of the State's major
power1 plants are. located on the ocean coast or the shores of Sari Francisco
Bay and the .Helta, and because studies .have estimated, that there may be
'need by 1990 for as many as 20 major new sites, which, if located primarily
on the coast, could have significant adverse effects on coastal resources,
new power plants should be approved, in the coastal KOJIC only when it can
be demonstrated that:
a..
, cannot reasonably reduce base load, and p
requirements suf liciently to eliminate the need for the proposed facility.
b. Greater presently identifiable adverse environmental impacts would
occur from utilising obtainable alternative Inland or coastal sites or
alternative technologies. In evaluating alternative sites and
technologies, in addition, to the factors included in. the hFarren~A.lqul.st
Energy Act, v consideration shall be given to evaporative, dry and dry/
spray, and salt water evaporative cooling towers, and the following
potential water sources' should, be considered in evaluat:' •".g the impact
of providing cooling water an inland sites: (l) surplus freshwater
supplies already allocated to power generation but not present!; being
used; (2) agricultural or municipal waste water,' (3) freshwater supplies
that can eventually be replaced by waste water,' and (/|.) other fresh-
water supplies, if it is determined that there is sufficient water
available after the reasonable needs, of other users are met so as not
to deprive inland or coastal areas of freshwater needed for agricultural
production. To assist i_n evaluating alternative sites -the utility or
utilities proposing the coastal site shall submit a comprehensive
evaluatioi:, of reasonable alternative coastal and inland si.tes and
,,:«- generating technologies, including the environmental reasons for
rejecting thorn in favor of the proposed site, sufficiently in advance
of a desired decision that an adequate and independent analysis can be
made;. The primary ' responsibility for the identification of such
alternative inland si.tes should, re st with the State Energy Commission,
arid the identification, or certification of such a site by -: :it Commission
dcmoi'istrates that such suitable alternative inland si.tes are available.
c. In tin; case of a proposal for a new coastal site, the need for new
capacity cannot or should not be met by plant expansion at an existing.
:i n't and or coastal site which has been :i.('!ontii'.'iod as suitable for
expansion.- The primary respons.ibili ty for the identification of such
(continued)
sites suitable for expansion should rest with tho State Energy
Commission, and the identification or certification of such a site
by that Commission demonstrates that such suitable sites for
expansion are available.-
d. The proposed power plant arid bhe-- land use restrictions required by
the State Energy Commission on the surrounding; area as required by
the Warren-Alquist Energy Act to protect public health and safety
will not conflict with other existing or planned coastal-
dependent land uses at or near the site.
e. In the case of a nuclear power plant the proposed site is in an area
of minimum seismic hazard in comparison to alternative sites
reasonably capable of serving the utility's or utilities' service
area or areas; the proposed plant is designed to safely withstand the
effects of the most severe seismic activity thought possible in the
site area; and the number of people and. their distribution within the
potential radiation hazard area meets AEG and State Energy Commission
criteria, and the people can be readily evacuated in the event of an
emergency.
f.. The generation and cooling systems proposed are the least environment ally
damaging technologies projected to be available at the time of scheduled
construction. The cooling system technology employed- shall'satisfy
the environmental protection requirements of the Marine Environment
element; and where a once-through cooling system is proposed, the
. project shall meet the standards set by the Marine Environment State-
wide Policies ?(b), 7(c), ?(d), ?(f) and ?(g)« Improvements in the
cooling systems of existing facilities at the site may be weighed by
the agency designated to carry out the Coastal Plan in determining
compliance with this subsection. -
g. In the case of a proposed new coal- or oil-fired electric generating
plant at a new site, or a proposed plant expansion at an existing site,
the project will cause no significant degradation of air quality. The
facilities shall be sited and designed to minimir/.e the effects of
pollutants for which there are designated Federal or State ambient air
quality standards, and shall employ the least polluting technology to be
available at the time the facilities are designed to go into operation.
Such facilities shall not be built in areas of the coastal zone designated
by the Air Resources Board as "critical air areas", or in areas where
coastal resources such as health resorts or agricultural lends would be
adversely affected, unJ.ess the agency designated to carry out the Coastal
Plan determines that there is no alternative inland or coastal location
where siting would result in less adverse environmental degradation.
In no case shall expansion take place in a critical air area, or in an
area where coastal resources would be adversely affected, unless there
would be a net decrease in generating system emission of pollutants for
which national or state ambient air quality standards have been established.
Normally this requirement will apply to each individual plant for which
expansion is proposed, unless it can be demonstrated that the emissions
from two or more near-by plants affect'the some geographic area. If such
EXHIBT
a determination can be made, then the plants involved can be treated as
one unit for the purposes of this policy. Reduction in emissions may
be accomplished by modernization or retirement of existing facilities.
The plant will l.\e set back from the" shoreline to avoid adverse visual
impact on the shoreline, cirid is designed and located to minimi/,e
adverse environmental effects, including bat not limited to effects on
fish and wildlife and their habitats, and. on scenic, agricultural, and
other resources of the coastal none. The plant should not be located
in a highly scenic area as defined in the Appearance arid Design
Element.
A substantial area will be established for permanent public use and
enjoyment of the coast and may include a substantial dedication of land
to the public.
As alternative, less environmentally damaging generating technologies
become widely available so that some of the existing fossil fuel or
.nuclear generating facilities can be phased out arid removed, priority
shall be given to removal of these facilities which are in prime
beach recreation areas.
EXHIBIT 'I (continued)
f STATL OF CALIFORNIA-CALIFORNIA COASTAL ZONE CONSERVATION COMMISSION RONALD REAGAN, Governor
SAN DIEGO COAST REGIONAL COMMISSION
6154 MISSION GORGE ROAD, SUITE 220
SAN DIEGO,CALIFORNIA 92120-TEL. (714) 280-6992
CONTROL MO:
APPLICANT:
LAST DAY FOR ACTION:
VOTE REQUIRED:
COMMISSIONERS'ABSENT
AT PUBLIC HEARING:
PROJECT LOCATION:
PROJECT DESCRIPTION:
STAFF RECOMMENDATION
F0451
San Diego' Gas and Electric Company
P. 0. Box 1831
San Diego, CA 92112
MALCOLM A. LOVE
Chairman
ROBERT C. FRAZEE
Vice Chairman
JEFFERY D. FRAUTSCHY
Representative to the
California Coastal Zone
Conservation Commission
THOMAS A. CRANDALL
Executive Director
April 8, 1975 DATE OF PUBLIC HEARING: February 7, 1975
Two-thirds of authorized membership (8 affirmative votes
required for approval) according to Section 27401 (d): "Any
development which would substantially interfere with or detract
from the line of sight toward the sea from the state highway
nearest the coast; and Section 27401 (e): "Any development
which would adversely affect water quality, existing areas of
open water free of visible structures, existing and potential
commercial and sport fisheries, or agricultural uses of land
which are existing on the effective date of this division."
Dutcher, McNeely, Pearson
Immediately adjacent to and south of the existing four unit Encina
Power Plant, which is located adjacent to Agua Hedionda Lagoon and
the Pacific Ocean in the southwest sector of the City of Carlsbad.
Encina Unit 5: Construction of a 292 Megawatt fossil fuel steam
turbine generating unit; replacement of four existing 190 foot
high stacks with a single stack, the top of which will stand 400 /
feet above sea level; construction of additional transmission lines
and related generating and transmission appurtenances; and enlarge-
ment of building housing the existing four units.
STAFF RECOMMENDATION
..:S*a'ff recommends that the San Diego Coast Regional Commission NOT ISSUE a permit for the
expansion of the Encina Power Plant.
REASONS FOR RECOMMENDATION
1. Inconsistency with Applicable Pro_visipns of the California Coastal Zone Conservation
Acrt: Section 27402 of the Act provides that no permit shall be issued unless the Regional
Commission has first found both of the following:
"(a) That .the development will have no substantial adverse environmental or
ecological effect.
(b) That the -development is consistent with the findings and declarations
set forth in Section 27001 and with the objectives set forth in
Section 27302."
3-H-75
TAC:dy
STAFF RECOMMENDATION, F0451
Page 2
In analyzing the implications of the above sections of the Act that are related to this
application, the staff was forced to answer the following questions:
(a) Are the adverse effects of the project upon offshore kelp beds and associated
living organisms, marine organisms • entrained in the plant's cooling water, visual amenities
of the area, and air quality, substantial? (Section 27402)
(b) Will the project as now envisioned permanently protect the remaining natural and
scenic resources of the coastal zone? (Section 27001)
(c) Will the project preserve the ecological balance of the coastal zone and prevent
its further deterioration and destruction? (Section 27001)
(d) Will the project lead to the maintenance, restoration, and enhancement of the overall
quality of the coastal zone environment, including, but not limited to, its amenities arid
aesthetic values? (Section 2.7302[a])
(e) Will the project provide for continued, existence of optimum populations of all
species of living organisms? (Section 27302[b])
(f) Will the project lead to the orderly, balance.d utilization and preservation, consis-
tent with sound conservation principles, of all living and non-living coastal zone resources?
(Section 27302[c])
i
(g) Will the plant expansion and stack result in the avoidance of irreversible and
irretrievable commitment of coastal zone resources? (Section 27302[a])
In answering the above questions, as is required for determining the consistency of any
proposed project with the intent of the Act, the staff's conclusions were generally negative.
Specific examples of the substantial adverse environmental effects of the proposed development
are as follows:
(a) Air Quality: The Carlsbad area and metropolitan San Diego area is in a critical air
basin as defined by the State Air Resources Board. Coastal areas are especially significant
in terms of air quality problems since temperature inversion layers which trap air pollu-
tants by stopping upward air movement tend to occur at lower levels and, in Southern
California, last longer into the day. Land-sea breezes often confine these pollutants to
relatively small areas rather than dispersing them, especially where there are mountain
ranges close to the coast and where the winds are relatively weak. In foggy coastal areas,
airborne sulfur dioxide often results in the formation of weak sulfuric acid, which over time,
can-be"injurious to plants and animals. In addition, many .coastal related crops, such as cut
flowers and some specialty crops, thrive on clean, clear air. Downwind agriculture in the
Carlsbad area could be adversely impacted by a continued increase of air pollutants from the -
Encina generating station.
Encina 5» based on burning 2.B million barrels of Q.5% sulfur content oil per year, will
emit about 12.6 tons of S09 per day (APCD Encina 5 Status Report, February 1975). This
amounts to about 23% of the total S0? emissions from all units, 1-5 (Units 1-4 emit 42.5
tons of S09 per day). In addition to S02, Encina 5 will emit 6.2 tons per day of nitric
oxide and 1.7 tons per day of particulate matter, compared to 21.0 tons per day and 5.8 tons
per day of nitric oxide and particulates respectively for Units 1-4.
In order to meet Air Quality Standards, 3DG&E proposes construction of the 400 foot stack.
Construction of the stack would improve ground level concentrations in the near vicinity of
the plant, but would not reduce the total quantity of emissions from the plant. In staff's
judgment, total emissions into the regional air shed must be taken into account, particularly
in the agriculturally sensitive North County area.
STAFF RECOMMENDATION, F0451
Page 3
Since costs, waste disposal, and adverse aesthetic impacts preclude the use of scrubbing
systems which would limit total emissions of the Encina plant; since the coastal area, par-
ticularly in North County, is susceptible to air pollution problems; and since SDG&E cannot
guarantee the availability of low sulfur fuel beyond 1984, significant air quality problems
could result from the construction.of Encina Unit 5.
(b) Marine Resources; Both SDG&E in their EIR for the project and the State Department
of Filsla land Game acknowledge that the increase in hot water discharges from 382,000 gallons
perifninute to 800,000 gallons per minute because of the addition of Unit #5 will have an
adverse effect upon the kelp bed offshore of the discharge point. The difference between
the two is only the matter of degree of adverse effect. SDG&E's position is that the effect
will be.relatively minor while the State Department of Fish and Game's position is that the
effect will be quite significant. In the absence of.concensus on the matter, and in looking
at the intent of the permit provisions of the Act to prevent any developments during the
Commission's planning period that could have an adverse impact.,..on. the. ecology of the shore-
line, the staff's position is that since the plant will have an identifiable adverse effect
upon the kelp bed, and the organisms that depend upon the food and protection provided by the
kelp for their existence, it should not be approved.
Fish entrainment does not appear to be a problem with Encina1s low velocity intake
structure located in the outer lagoon. History suggests more severe problems result with
offshore intake structures. Firm data on the mechanical stress and heat kill of entrained
plantonic species is not available. Estimates range from 30% to 100$. The number of
entrained organisms will obviously rise proportionately with the increased demand for
cooling water necessary for the construction of Encina Unit 5. A relatively unknown impact,
but of concern to staff, is the effect of the cooling water increase on natural biological
relationship of the lagoon and ocean. A large percentage of the water entering the lagoon
is channeled through "the power plant, thus eliminating the natural sea water exchange with
the inner portions of the lagoon. This could not help but adversely affect to some extent
the lagoon-sea ecosystem, particularly as the lagoon serves as breeding habitat for
various marine species.
(c) Land and Scenic Resources; The existing site, being located adjacent to the Agua
Hedionda Lagoon and the Pacific Ocean, occupies a valuable and scenic portion of the
California coastline. The construction of Unit 5 will not only reinforce permanent commit-
['ic-ut of this scenic area for the generation of electric power, but will extend and perpe-
trate the view blockage problems resulting from the construction of Units 1-4.
In the case of the adverse effect upon the visual amenities of the area, the staff's
position is that there will be a substantial adverse impact. The proposed 400 foot stack
wills-certainly not improve the appearance of the rather scenic stretch of coastal, land in
question and in the opinion of the staff, it would degrade the appearance of the area.
Clearly, such a position is subjective. However, in areas such as Morro Bay and Moss
Landing where utilities have constructed large stacks to dissipate air pollutants, public
opinion seems to strongly support the position that such stacks have an adverse visual
effect. It should also be noted that the existing very large building will be heightened
by some 24 feet and will be lengthened to accommodate Unit #5. The effect of this
enlargement will be to further impinge upon views to and along the coast from a number of
surrounding areas.
The 400 foot high stack (above MSL) will be visible in certain areas over five miles
away. The visual impact of such an imposing structure cannot be adequately mitigated
through the use of landscaping, berming, or plant design, and thus constitutes an irrecon-
cilable deterioration of scenic coastal amenities. The applicant has sufficiently demon-
strated that the use of scrubbing systems as a stack alternative would result in an equally
imposing impact on scenic resources.
STAFF'' RECOMMENDATION, F0451 -
Page. 4
It should be noted that as part of their approval of the EIR for the. project, Carlsbad
attached the following condition to their approval of the project. The intent of the City
was to deal with the adverse aesthetic impact of the 400 foot stack. However, in the
staff's judgment, the condition is not likely to result in the removal of the stack nor
does it deal with the aesthetic problems related to the rather significant enlargement of
the existing building housing the generating units.
Condition: "The approval granted herein is subject to review on a five year
basis. Prior to the fifth year anniversary of approval, the applicant and
City Council shall decide if a report describing the 'state of the art' and
alternate emission. control systems that could be utilized in lieu of the
400 foot stack is appropriate. Said report shall be considered as an amend-
ment to the accepted EIR. When a reasonable alternative system is found to
exist, the applicant shall make every effort to convert the Encina Power
Plant to said system. Said conversion should include the consideration
of the removal of the 400 foot stack."
d. Public Access: Currently, public access along the beach in front of the Encina
Power Plant is blocked by SDG&E's across-the-beach discharge system. Not only do the two
jetties on either side of the outfall channel and the flow of heated water block public
access, but the company has also fenced off the beach area to the south of the outfall .
structure. This beach area is made available to company employees but it is not available
to the general public. Further, no provision has been made for public access along much of
the south side of Agua Hedionda Lagoon of lands owned by SDG&E. It should be noted, however,
that the company does allow boaters to land on certain areas along the south shore. With
respect to the water surface itself, the company has not discouraged public recreational
use and probably legally cannot interfere with such use.
The proposed project will do nothing to improve public access to the beach area west
of the power plant nor are any measures being taken to make access to the south shore of
the lagoon available to the non-boater.
2. Need; After an extensive review of available information, the staff has concluded
that the applicant has adequately justified a need for additional generating capacity in
the 1979-1981 time period. (See attached appendix for detailed staff analysis of need.)
(.Commercial power from the San Onofre Units 2 and 3 and Kaiparowits Units 1-4 will not be
'available until after mid-1981. Without Encina 5> SDG&E's reserve margins would drop to
'an excessively low level between 1980 and the time that San Onofre and Kaiparowits came
on line. However, it seems to the staff that there are other ways besides the construc-
tion of Encina Unit 5 to deal with the critical period of 1980-1981. For example, SDG&E
could reactivate their plans for construction of the 404 Mw combined cycle unit at
Sycamore Canyon, could construct additional peaking units to cover the high demand peaks in
1980-1981, or could instigate conservation efforts that would reduce peak load demands
during the critical 1980-1981 period. •
Some advantages of the Sycamore Canyon alternative, for example, are: increased fuel-
output efficiencies because of the use of combined' cycle units as opposed to conventional
steam units such as Encina 5; additional load capacity which could reduce the need for
less efficient and smaller generating units; the elimination of adverse impacts upon coastal
zone resources through the construction of Encina 5 and the required 400 foot s^ack; and
making available additional capacity which would allow the reduction in use of some older
and less efficient units currently on line. Furthermore, the Sycamore Canyon project is
designed to use sewage effluent for cooling purposes. This not only seems to the staff
to be a step forward in conserving the scarce freshwater resources of Southern California,
but it would also help deal with the water quality problems now jeopardising the continued
availability of the Santee Lakes for public recreation.
STAFF RECOMMENDATION, F045J
Page 5
, , A second viable alternative to the construction of Encina 5 is the development of a
rigorous program of energy conservation in SDG&E's service area. It may be that as the
price of electricity continues to rise and as the public's awareness of the need to con-
serve petroleum resources continues to grow, individuals will institute their own conserva-
tion programs with a resulting decrease in demand to the point where SDG&E will have
adequate capacity to serve the critical 1980-1981 period. Over the next year, it is
likely that information will become available that will allow all to better assess the
impact of the individual's conservation efforts upon the total demand picture. However,
should the individual's energy conservation efforts not be enough to bring into line
energy demand and availability for the critical period in the early 1980's, then it is
likely that the company, in cooperation with the new Energy Commission, can develop con-
servation techniques that will reduce demand to the required level, in the judgment of
staff. In fact, the staff would suggest that the best alternative for SDG&E is to not
think in terms just of responding to the demand for electrical energy, but rather, begin
thinking in terms of bringing demand into reasonable alignment with available energy
supplies through a combination of voluntary and enforced conservation measures.
3. Alternatives to Denial; Although not set forth explicitly in the Act, the Commis-
sion cannot avoid the responsibility of weighing the social and economic impacts of their
decisions upon the citizens of the region and state. Therefore, even though the intent of
the permit provisions of the Act is to delay during_the Commission's life those projects
that have a substantial adverse environmental effect and which might be inconsistent with
the plan as acted upon by the' Legislature, the Commission may wish to consider alternatives
to outright denial. Therefore, the staff has drafted two alternative conditional approvals
for the project. The first of these alternatives is the traditional kind of approach with
suggested conditions which will minimize the adverse environmental impacts noted in
Section 1 above.
(a) Alternative 1; The Encina 5 power generating unit and associated developments
shall be approved subject to the following conditions:
(l) To promote public access to the beach, that that portion of applicant's
property lying between Carlsbad Boulevard and the Pacific Ocean be fully
dedicated to the State of California for public park purposes, excepting
easements thereof in favor of the Utility for discharge channel maintenance..
.(2) To promote public access to the south side of Agua Hedionda Lagoon east
of Interstate Highway 5* that prior to construction of Encina Unit 5> the
~" applicant submit and have approved by the Commission a public access plan
showing the method and physical improvements necessary to promote public
_.,,,:•-•• access to said section of the Lagoon. Such physical improvements as
'"''*" required shall be installed prior to the commercial operations of Unit 5.
Full costs shall be borne by the applicant.
(3) To improve plant aesthetics, that all distribution and transmission
facilities, excepting the switchyard, be placed underground from the
plant site to a point 1,800 feet easterly of Interstate Highway 5.
Oil cooled pumping facilities and/or other underground transmission
appurtenances shall be placed below ground.
(4) To improve plant aesthetics, that an qarth berm shall be constructed
and landscaped immediately adjacent to and easterly of the switchyard,
thereby effectively screening the top of the switching station as seen
from Interstate Highway 5.
STAFF RECOMMENDATION, F045:
Page 6 "-
(5) To minimize adverse impacts on off-shore resources, that a single ocean
outfall be constructed to accommodate all Encina Units, should the State.
Water Resources Control Board or the United States Environmental Protec-
tion Agency determine an outfall is necessary for the operation of Unit 5.
(6) To minimize adverse impacts on off-shore resources, should publicly
. required environmental monitoring studies at any time indicate that
the discharge waters are not or will not comply with the regulatory
requirements of State or Federal water quality agencies, that the
applicant shall immediately undertake such modifications as may be
reasonably required to reduce such effects and comply with such regu-
latory requirements.
(?) That no construction shall take place until the applicant has acknowledged
in writing that they understand all conditions imposed herein and agree to
' abide by each and all.
(b) Alternative 2; That the San Diego Coast Regional Commission approve, the
Encina 5 project subject to the following condition:
That in exchange for public acceptance of the adverse effects upon
the amenities, air quality, water quality, and marine environment
of the area, the San Diego Gas and Electric Company agrees to convey
• • to the State of California, at the end of a 20 year period follow-
ing approval-of this permit, all lands currently under the ownership
of said company lying west of 1-5 at the Encina Plant site.
The staff*s rationale for proposing this second alternative is based upon two factors -
equity and land use. Over the past several decades, there have been strong economic
incentives for the public utilities to locate the power generating stations immediately
adjacent to the ocean. The principal such incentive is the availability of "free"
cooling water from the ocean. A substantial portion of the operating costs of inland
plants is related to the purchasing of cooling water, a cost that can be avoided by
the utilities through shoreline siting of their plants. However, not only do the
nearshore ocean waters belong to the general public, but the marine organisms
.that are adversely affected by entrainment and thermal discharges also belong to the public.
Therefore, to compensate the public for the utility's use of public cooling waters and
adversely affecting public marine resources, the staff is suggesting that land values
be transferred to the State for park purposes. This same kind of rationale applies to
the costs that are transferred to the general public because of the adverse effect of
their project at Encina upon the air resources and the scenic amenities of the region.
In effect, the staff is suggesting that SDG&E compensate the citizens of the region for
the adverse environmental effects of the project over the next 20 years through the
donation of the site for public purposes.
Such a condition would certainly be consistent with that portion of the Act which
suggests restoration of the natural values of the coastal zone as being of major concern
to the Commission. The condition would also insure that there will not be a continuing
expansion of electrical generating facilities immediately adjacent to the ocean's edge
and a lagoon, a location which the staff suggests is not appropriate from a resource use
point of view. Finally, and perhaps most important, such a condition would allow SDG&E
to amortize their investment at Encina over the next two decades and to plan for replace-
ment generating capacity in an orderly way. It should also be noted that there is a good
chance that within 20 years, the kind of generating units now found at Encina will be
obsolete because of a combination of new technology, increasing shortages of petroleum,
and the unwillingness on the part of the public to accept the adverse air pollution
effects of oil-fired plants in air basins with serious £.ir quality problems.
. STAFF, RECOMMENDATION: F0451
PAGE 7
WHEREAS San Diego Gas & Electric Company, P. 0. Box 1831, San Diego, proposes construction
of Encina Unit 5 to include: construction of a 292 megawatt fossil fuel steam tur-
bine generating unit; replacement of four existing 190 foot high stacks with a
single stack, the top of which will stand 400 feet above sea level; construction
of additional transmission lines and related generating and transmission appurten-
ances; and enlargement of building housing the existing four units. Site is
immediately adjacent to and south of the existing four unit Encina Power Plant,
which is located adjacent to Agua Hedionda Lagoon and the Pacific Ocean in the
southwest sector of the City of Carlsbad;
WHEREAS, the Commission finds that the applicant has not sustained the burden of proof
that the proposed project is consistent with the findings and .declarations
set forth in the California Public Resources Code Section 27001 and with the
objectives set forth in the California Public Resources Code Section 27302;
nor has the applicant sustained the burden of proving that the proposed project
will not have any substantial adverse environmental or ecological effect; and
THEREFORE, BE IT RESOLVED that the San Diego Coast Regional Commission deny a permit for
the proposed development.
ADOPTED by the San Diego Coast Regional Commission by vote of yes,
• abstention on this day, ,1 1974«
no;
V
ENCINA FIVE
APPENDIX
Determination of Need
When possible adverse environmental impacts on coastal zone resources have been
identified, as in the case of the construction of Encina 5, a rigorous assessment
of public necessity is in order. Plant necessity is best addressed by
considering three issues: (l) Does an increase in regional power demand require
the construction of additional generating facilities to satisfy that demand? (2)
Is the proposed generating facility to meet such demand environmentally the least
damaging alternative? And (3)» are the alternatives practical under the time,
fiscal, and technological restraints present?
Load Projections: San Diego Gas & Electric first indicated a need for Encina
Unit 5 in 1971 when the project was first conceived. Since then, however, the
date anticipated as necessary for commercial operation has been extended from 1975
to 1977- (PUG Final EIR, pg. 1-3) due to changes in load forecasts and interim
scheduling of new resources on the system.
Since filing an application with the PUG in June, 1972 for the construction of
Encina 5, San Diego Gas & Electric has revised not only their load forecasts but
their method of determining anticipated loads. Rather than using the traditional
"straight-line" method of forecasting on the basis of past trends, the Company
now uses a sophisticated computer modeling system, which will be described in
greater detail below.
The PUC staff has basically agreed with San Diego Gas & Electric1s assessment of
need, both.during the original hearings when the plant was thought necessary for
commercial operation in 1975» and now, when it is thought needed for 1977-
Although the PUC itself has not yet formally decided on the necessity question
(the proposal is now before the hearing examiner prior to the issuance of a
Certificate of Convenience and Necessity), all indications are that the PUC will
conclude that the plant is necessary (recorded testimony, now outdated, indicates
need for commercial operation in 1975 and the Final EIR indicates need for
May 1977 - the two basis for the Examiner's findings). However, regardless of
PUC staff support of the Utility Company's projections, a closer analysis is
in order. Even since the preparation of the PUC?s final EIR for instance, load
reductions on the San Diego Gas & Electric system from those originally anticipated
"Save led the Company, to announce cancelation or temporary postponement of 2
Coastal Commission approved gas turbines at South Bay (64 Mw each) and a 404 Mw
Combined Cycle Unit at Sycamore Canyon. The question is whether Encina 5 could
also be canceled or postponed, whether any resulting load deficiency could be
made up by reinstigating the South Bay units, the Sycamore Canyon unit, or a
similar alternative, and what, if anything would be gained by such cancelation
or postponement? It must be remembered that the commercial operation of San .
Onofre Units 2 and 3 (San Diego Gas & Electric's share of power is 228 Mw each)
are scheduled to be on line by October 1982 and that the first of four units -.at
Kalparowits (.176 Mw each) is scheduled to begin operation in June of 1981; the
fourth unit being in operation by December 1983- When these units are in operation,
will the San Diego Gas & Electric's system requirements be met, even without the
addition of Encina Unit 5, while still maintaining adequate reserve margins for
maintenance and unexpected outages?
*
Forecast data, and methods used in determining such forecasts, are critical to
this analysis. As mentioned previously, San Diego Gas & Electric employs a
prediction model to determine load forecasts. The model was developed in 1974
by Decision Science, Inc. for use in forecasting electric sales in the San
Diego Gas & Electric service area. It is basically a multiple regression model
which predicts by correlating forecasts of independent variables that are highly
correlated with electric sales. The independent variables include projections
of: (l) Population (San Diego County and State Department of Finance); (2)
California Personal Disposable Income; and (3) Gross National Product.
The model predicts domestic sales by predicting numbers of domestic customers and
sales per average domestic customer; commercial sales are forecast directly.
The model includes both present time (same year as forecast sales) and lag .
variables. The use of 'lag variables (a standard lag time of six years was
choosen) involves using past data as a variable for present sales (for example,
the per capita income for 1970 would be used in the prediction of 1974 electrical
sales). A technique called factor analysis is also employed which transforms
original independent variables into new variables which are linear combinations
of the original variables. These linear combinations are created in such a way
that each accounts for as much variation in the original data as possible.
Correlating these linear combinations provides the basis for San Diego Gas &
Electric 's prediction of electric sales. The total model is the sum of a
domestic sales model and a commercial sales model, plus a constant sales factor
that '.accounts for agriculture, street lighting and other sales. This constant
(approximately 200 Mw/Yr. ) is derived from San Diego Gas & Electric !s annual
sales for such uses over the historical data base (since 1956). The final model
was calibrated and checked for accuracy using actual sales data from 1956 to
1972. For all years between 1956 and 1972 the model produced results within yjo
accuracy. (See Figure l)
There are several observations and warnings to be made about use of this model.
The first concerns the model itself. The model was constructed from historical
data and is based on historical . relationships between variables. Thus, forecasts
are valid only if these relationships do not change drastically over the
predictive time frame. The second observation concerns the predictor (independent)
variables. These variables have to be predicted also, and any forecasts are
dependent on the validity of the predictor variable forecasts.
A recent forecasting problem which occurred was the impact of energy conservation
on the model forecast. The model was based on historical data over a time when
..electrical energy was abundant and relatively inexpensive. Thus when San Diego
Gas & Electric witnessed a large load drop in 1974 (at the height of the "energy
crisis") over predicted loads, they attributed the drop to "energy conservation"
efforts resulting from the energy crisis. They then dropped each successive
year's load forecast by the same amount (l,284 million Kw Hr/Ir) as dropped in
1974. However, as brought out in the .Coastal Commission's Energy Element, a
static number attributed to energy conservation applied to each year through the
forecast period means the load reduction attributed to energy conservation
gradually falls as a percent of total sales from about 13.7$ in 1974 to only 4-5$
in 1995.
Cur information,- however, indicated that many energy conservation efforts were
long range in effect; for example, the impact of 'increased prices, the increasing
shift in housing patterns from single family units to more energy efficient
A
of scale cont'd below)
12000
•'•O~O fr'l''t anc' Forecast
Actual Data
TOTAL SALES - Fit and Forecast
"-'Domestic Sales (3 factors model ) + Commercial Sales
o
multiple units, the anticipated peaking in home appliances, the shift in building
technology to more efficient buildings (including the advent of building
insulation standards and the use of thermal solar equipment for space heating
and cooling) all argue for a. continuing increase in the impact of energy
conservation efforts on load forecasts, rather than a decreasing impact as pro-
jected by San Diego Gas & Electric'. ' Since the Energy Element was prepared however,
the company has begun using a uniform, or constant percentage of total sales
reduction attributed to energy conservation, rather than a decreasing percentage.
In staff's judgement, a constant percentage would still seem to inadequately
account for anticipated reductions due to energy conservation, providing long
range conservation efforts take place as anticipated. •
The other concern with the model predictions involves the accuracy of the
independent variable projections. None of the independent variable projections
have been adjusted since inception of the model, even though they were taken
from forecasts prepared prior to the energy crisis and current decline of the
economy. These factors may not affect the projected number of domestic customers,
but they may well have a major impact on projected GNP and Personal Disposable
Income estimates. It may simply be too early to get accurate long-range GNP
estimates until the economy begins to stabalize (San Diego Gas & Electric reports
that the Bureau of Labor Statistics GNP projections have not changed .substantially
since the model was formulated).
Comparing PUC projections with San Diego Gas & Electric's, we find that the PUC
has historically projected slightly lower system loads on the San Diego Gas and
Electric system than has the Utility.
Pursuant to General Order 131, the PUC requires yearly forecasts to be submitted
by each of the California Utilities, after which the PUC makes an independent
assessment of load forecasts and publishes the results in a report entitled
10 Year and 20 Year Forecasts of Electric Utilities Loads and Resources. The most
recent report, published December 26, 1974, shows that the PUC staff considers
the San Diego Gas & Electric peak demand forecast for 1980 .to be high by 140 .
Megawatts, and the San Diego Gas & Electric forecast for 1983 to be high by 200
Megawatts (see Figures 2 and 3)«
FIGURE 2
PUC STAFF-UTILITY COMPANY FORECAST COMPARISONS
PEAK DEMAND FORECASTS
(Pursuant to General Order 131, Dec. 74)
Megawatts
1917 : 19tiO :
Itein :
PG&E
SCE ...
SDG&E
IALWP
Subtotals
Others
• -Total California
Utility
14, 870
12,280
1,890
5,610
34,650
: Staff
15,620
12,190
1,890
5,000
34
35
,700
740
,44o
: Utility :
17,650
14,620
2,540
6,650
41,460
Staff
18,470
13,810
2,400
5,800
4o,46o
910
41,390
1983
•.Utility
20
16
3
74b
,
,
t
7
,
960
440
150
760
310
: St
21
15
2
6
l
- •?•>*Cil J.
,870
,520
,950
,570
,120
48,030
CHART 4
SAN DIEGO GAS AND ELECTRIC COMPANY
PRIOR AND CURRENT LOAD FORECASTS
AUGUST PEAK DEMAND
IN THOUSAND MEGAWATTS
San Diego Gas Q Electric Co. ^
1973 Forecast
Son Diego Gas 8 Electric Co.^
2 A,*r
2p
I a
1 fiI.D
19
1974 Forecast \
H-
S y
— ~ J
H-
jh /
— f
w / • >
^~ /' ^^—^~~
s_
/
/
/
/
V
/
/
\ /
/\v \
/&
/
/
'
\ /
/
^Calif.
197'
>
X
/
/
•'"V
/
P. U.C.
4 Fore(
73 157-1 1975 1976 1977 1978 1979 I960 19
.
/
'
'
t
/
X /
'
-ast
31 /9<
-=
-H
-s
-—
/'-^
/ J
./J
f —
-g
-H
-p
-=
-^
-=
-=
-s
-^
-^
-^
~=
~=
-s
3 C.D
34.."r
1 0
2 0.C3
2C.0
,. « ,1
2 0
2 r>.U
, 1 OI.O
I fi
1 4
> ,.^
<32 1983
YEAR
As can be seen on Figure 3, forecast differences between the PUG and San Diego
Gas & Electric increase as the forecast period increases. Although the PUG did
not estimate a 20 year forecast in their 1974 report, their 1972 General Order
131 report indicated 1991 peak loads, as estimated by San Diego Gas & Electric,
were high by 700 Megawatts (PUC staff estimated 5400 Mw Peak for 1991, San Diego
Gas & Electric estimated 6100).
Long range load forecasting is tenuous at best, particularly in light of the
relatively unknown impacts of variables such as rate and pricing changes; electric
power's relationship with the supply of natural gas, and changing economic
conditions. However - although not necessarily for the same reasons - the lower
PUC forecasts would seem more consistent with the long range effects of
conservation.identified earlier in this analysis.
In summary then, the staff supports the contention that the Utility's load
projections are probably higher than necessary due to two factors: (l) It is
likely that excessive values are being used as the economic predictor variables
used in the forecasting model; and (2) insufficient load reductions attributable
to energy conservation efforts are substracted from the model results. It is
important to note that staff differences with the Utility's projections are more
pronounced towards the end of the forecast period, and that accelerated energy
conservation efforts will not immediately reduce load forecasts over those
anticipated by the Utility. Thus, staff recognizes the Utility!s immediate load
projections, but questions their long range projections. .How |his relates to
the need for additional generating capacity is described below...' -
Generating; Capacity: San Diego Gas & Electric proposes 1518 Mw of additional
' capacity to meet what they anticipate as load demands for 19.84- These proposed
resources include San Onofre Units 2 and 3, 3 gas turbine units in San Diego,
Encina 5, and the coal fired Kalparowits plant in Southern Utah. San Diego
Gas & Electric has securred Coastal Commission approval for the San Onofre units
and the gas turbines - only Encina 5 remains. Proposed capacity additions are
shown in Figure 4-
San Diego Gas & Electric*s power plant resource capability (January, 1975) totals
2074 Mw. This figure includes all plants now operating on the San Diego Gas &
Electric system. In addition, San Diego Gas & Electric purchases additional power
from the Oroville State water project, from the Canadian Storage Power Exchange
and from the Washington Water and Power Company. Under normal weather conditions,
the imported power supplys 187 Mw (1975 figures). After deducting transmission
losses and scheduled maintenance (planned outages), the currently available
resources for 1975 allows margins between 38 and 51-percent in excess of anti-
''cipated peak load requirements. .(See Figure 5)
Similar tables prepared by San Diego Gas & Electric for each year's operation
through the end of 1984, which include the construction of new generating
facilities as proposed (including Encina 5 - see Figure 4) indicate anticipated
reserve margins above peak demand vary between 51% and 13.8/0. The lowest margin
occurs in March of 1981, when 295 Mw is proposed to be taken off the system for
scheduled maintenance. These anticipated reserve margins include Encina 5
(scheduled for operation in September 1977) and are based on San Diego Gas &
Electric load estimates which, as described earlier; may exceed the actual loads.
ANNED COMMERCIAL
PERATING DATE(l)
heduled Units (5)
Jul 1975
Sep 1977
Jun 1979
Jun 1979
Jul 1980
Jul 1981
Oct 1981
Oct 1982
SAN DIF.cWcAS & ELECTRIC COMPANY
GENER/, .ON RESOURCE ADDITION PLAN/
1974-1983
STATION AND UNIT
Naval Station GT 1
Encina 5
South Bay GT 2
South Bay GT 3
San Onofre 2 (Initial)
San Onofre 2
San Onofre 3 (Initial)
San Onofre 3
TYPE
Gas Turbine
Steam
Gas Turbine
Gas Turbine
Nuclear
Nuclear
Nuclear
Nuclear
FEB. 27, 1975
CAPABILITY(2)
(Mw-Net)
32
292
64
64
46(3)
182(3)
46(3)
182(3)
lanned Units (5)
Jun 1981
Jun 1982
Mar 1983
Dec 1983
Kaiparowits 1
Kaiparowits 2
. Kaiparowits 3
Kaiparowits 4
Steam-Coal
Steam-Coal
Steam-Coal
Steam-Coal
176(4)
175(4)
176(4)
175(4)
(1) Prior to the first day of month shown.
(2) Dependable winter capability. Summer capabilities of Gas .Turbine units
are,.somewhat less. ' . . . .. ' •>••' • • • .
(3) 20% share of 1140 Mw units with 20% firm capacity availability
between initial full power operation and commercial operation.
(4) 23.4% share of 750 Mw units. ':
(5) Scheduled Units are those for which application has been submitted to
the California Public Utilities Commission for a Certificate of Public
Convenience and Necessity. Planned Units are all others. -f. . •
CAPABILITY - MW (NET)
1. LOAD
A. FIRM '
AREA-SAN DIEGO GAS C ELECTRIC COMPANY
ESTIMATED LOADS AND RESOURCES FOR YEAR 1975
ADVERSE WATER CONDITIONS
NORMAL WEATHER ;
CAL. PUC G.O. 131SEC. 2A - DATA
DATE PREPARED: FEB. 27.1975
JAN. FE3.. MAR. APR. MAY JUN. JOC. AUG." SEP. OCT. MOV. DEC.
1535 1*56 1415 1357 1271 13*0 14U 1479 1518 1*88 1520 1605
FESOURCES
"'". A"." HYDRO ' . '"• •""e, FOSSIL THERMAL
C. NUCLEAR THERMAL
0. UMDE=tM'EO *'
E. TOT61.
3* FIRM TRANSFERS . ''.
A. INTRASTiTE
010VILLE
B. INTERSTATE
-CS = E
rf*» " " ' ' •
*. OFF SYSTEM LOSSES
5. PUMP STORAGE PUMPING
6. SCHFPLJlcD MAINTENANCE
----- •' •-'- •—:•-•. •': ----- -
(PURCHASE) .:.'''
•'••'• • •. '• • • . - ' • ..
(PURCHASE)
(PURCHASE) :
REQUIREMENT
. • -
7. NET RESOURCES ANO FIRM TRANSFERS ** '•
8. N5T MARGIN OVER FIRM LOAD ** •, .. .,:•;,; '.>;\''-
9. e==CENT, NET MARGIN OVER. FIR1 LOAD - '••
o-
1988
86
0
1074
54
63
"70
-13
0
105
2143
.607
39.5
0
1938
86
0
2074
54
63
70
13
0
113
2135
679
46.5
o
1988
86
0"
2074
54
63
70
13
0
107
2141
726
51.3
0
1949
86
" 0
2035
54
21
112
13
0
236
1973
.616
45.4
0
1949
86
. • 0
2035
54
21
112
13
0
"284
1925
65*
51.5
0
1957
86
0
2043
5*
21
112
13
0
267
1950
. 610
45. £
;-•- 0.
1980
86
0
2066
54
21
112
1.. 13
V o
267
1953
542
35.4
0
1978
86
0
2064
5*
21
112
. 13
0
113
2123
644
43.5
0
1944
86
0
2030
54
21
112
13
0
"" 0
2?01
663
45.0
0
1953
86
0
2039
54
21
112
13
0
66
2143
655
44.0
0'
2017
86
0
2103
54
21
112
13
0
220
2052
532
35.0
0
2020
86
0
2106
54
21
112
13
0
45
2230
625
33.9
* DETAIL £Y TASJLAR LINES OR faY FOOTNOTF AND SEPARATE SCHEDULE.
«* AFTE? SCHEDULED MAINTENANCE.
K>
NOTE: RECORDED PEAK DEMANDS FOR JANUARY AND FEBRUARY WERE 1601 MW AND 1497 MW RESPECTIVELY..
The PUC, in their 1974 report pursuant to General Order 131, forecast planned
margins on the San Diego Gas & Electric system which were based on the PUC's
load forecasts. This comparison indicated anticipated margins for 1977, I960
-and 1983 to be 32.8%, 19.6% and 2?.5% respectively. (See Figure 6). The same
report concluded! • •
"The demand margins in Table 2 for Southern California in 1983 could
appear to be on the high side. It should be born in mind, however,
that these margins are based on the utilities' plans for resource
additions and staff load estimates some of which are lower than the
utilities' load estimates."
"In view of the risk of delay in getting new generating plants into
service as scheduled, it is concluded the utilities' resource schedule
should not be altered at this time even where lower demands are
forecast."
What this seems to suggest, is that even though reserve margins may be excessive,
the PUC will hesitate to "risk delay" of the construction of new generating
facilities. With the Utilities' new 1975 load forecast figures, which are
lower than 1974's, we can expect even higher reserve margins (assuming the
utilities retain all proposed additions - San Diego Gas & Electric has since
canceled the Sycamore Canyon Plant).
A comparison between projected loads and planned capacity increases are shown on
Figures 7 and 8). As can be readily seen, without Encina 5 the most critical
period for San Diego Gas & Electric to meet demand will be mid-1981. At this
time, the margin between' peak capacity and peak demand will drop to approximately
100 Mw, or 4.3% over firm load as estimated by San Diego Gas & Electric. To the
extent that the actual peak load is less than the peak load as estimated by San
Diego Gas & Electric, the reserve margin will be increased. However, based on:
(l) past comparisons of PUC vs. San Diego Gas & Electric forecasts (the PUC
has in the past continually reduced San Diego Gas & Electric's peak demand
forecasts by about 100 Mw over the same forecast period); and (2) anticipated
accuracies with San Diego Gas & Electric forecasts in the near-term, it would
appear to staff to be optomistic to expect more than a 250 Mw difference between
anticipated.peak demand and planned capacity in Mid-1981, if Encina 5 is not
constructed.- A 250 Mw difference would equal a reserve margin of about 11%,
insufficient to cover an outage in one of the system's larger units (Encina
Unit. 4, the systems largest, is rated at 287 Mw capacity).
,-.&?"'
San Diego Gas & Electric prefers to carry a minimum 20% reserve margin, to cover
unexpected outages and/or unexpected excessively high peak loads. Larger systems,
on the other hand, such as the Southern California Edison system, can get by
with a smaller margin (i.e., SCE's 15% margin) because the larger systems can
satisfactorily accommodate demand even when their larger units are not in operation.
It is important to note that if the 404 Mw combined cycle unit at Sycamore Canyon
was not canceled by San Diego Gas & Electric, but instead was constructed and
placed in operation in mid-1979 as anticipated in last year's forecast, that the
critical reserve margin would then be 13% (based on San Diego Gas & Electric
forecast) occurring immediately prior to its commercial operation (mid-1979). If
TABLE 2
ESTIMATED LOADS AND RESOURCES
Adverse Water Conditions
• Megawatts
: Item :
Loadsi/
Northern California
PG&E and Public Agencies
Southern California
SCE and Public Agencies
SDG&E
LATOP and Public Agencies
Southern California Total
Net Resources (After Sched.Maint. )S/
Northern California
PG&E and Public Agencies •
Southern California
SCE and Public Agencies •'.'..
SDG&E
LAEWP and Public Agencies
Southern California Total
.Percent Net Margins
''•' Northern California ,. ,
' PG&E and Public Agencies •
Southern California
SCE and Public Agencies ' -
SDG&E
LAIWP and Public Agencies
Southern California Total
197U
13,010
10,I|80
1^,070
15,990
15,030
13,310
1,870
5,830
21,010
15.5$
27.0
29.9
H3.2
3lA
: 1977
15,620
12,190
1,890
5,000
19,080
19,210
1^,350
2,510
7,280
23.0$
17.7
32.8
U5.6
26.5
: 1930
18,1*70
13,810
5'eoo
22,010
16,850
2,870
7,980
27,700
22.0
19'. 6
37.6
25.9
196^
21,870
15,520
2,950
6,570
25,OUO
23,860
19,380
3,760
9,310
32,U50
2^.927.5
29.6
!1/,.-Staff forecast of loads. ' • ' " ;
''2/ G.O. 131 Reports to CPUC, March 197^ and more recent information.
J..L
SAN D' ~O GAS S, ELECTRIC COMPANY
HISTORICAL^ND ESTIMATED ANNUAL
RESOURCES AND PEAK DEMANDS
J.OW
3,400
3.200
3.000
2,800
2,600
2,400
2.2DO
2.000
1.800
1.600
1,400
1.200
'.-?&•
1.000
800
600
IfUl
1f ft200
n
•
*
EN
X
., .£>"
-
|i!e sources
iOUTH flA
!
:INA i-J
I
iOL TH
•X
"Mi (V1
n ,:,„ J
j
ff
/
HA
J0
•:ANA,
jOUTH
TH
J,
r-"--
IUV « —
....
(
31*
.
CA
CAM AC I
1
'•.*.
•:Af:^DiA;i E
CANADIAN
KEAR1
KEAR"
ANADIAN ENTJ1
NW !
OS
SAN UNGCRE !
1 1>N ENTlTLl>IEir
:JH PEAKIN'
DIVISION CT
El. 'AJON TT
KEASNV r.T
tWIN* CT
JAN QNOFRE 1 -^,
4\\'
-•».
I
T1
"T ' U..)
fT
j G
PC
u) E:JT
KM
<Y -rr
<Y /T
FLEMES
>EAKU
OVILl
JTRETl
\
S
E
IN
IT
p
21
T
G
E
H
-v
•J__)
/I
3UTH B
•rriTLa
•M PCM
T LChA
u:ME^rr
\
1
NA
AN
S 1n
*.Y
Kl
r\
£•f
ct,
CANADIAJ
n«-N
:IOx
E
ENTI
NW
NJRBU
TLEME
c
\
^-L
:NTIT
LIMIT
•JCJNA
TLtME
PEAK I
C
ES
NT
CP ^
X
•VM
A
$
-
v5G(
-
:w:l > C/^
> Al t
•:.M
w.,^n . ll
..N...",: .-I — -
'' SY-'AMOMt
J.VJADI V*' tmi
CANADIAN ENTITLEMENT P~
CAS 1
< e?.Ti
uEHErn
CTI CM 5-C:pl
V
^HI- n
•URBIN
TLf-MC
^
*"
PS
NTLJ)Gf\
\.
'(
—^ff*^^
£
1
—J —
e
/
J?/ jx
25^1
Y(
Ffcte
F3(->l•%»
C Lu
ic
?Ml
*"^ ^'
'74
)
T
) RECORDED
PEflK OEMRSC
fLt
-fe
^•x
M£
w
""7
v
-^
^i
/
&~T
/i
T
Xij
^L—
/
j
A PROJECTED
PEAK OEi.!AMD
\ V
I /VV
•
1f
&
f£
&
/
'
1^
^lv
E£f
"
CO
<£tu
S
1955 I960 1965 1970 1975 1980
YFCR
'SO 91 '8Z 'S3
»
actual loads were less than what San Diego Gas & Electric expects, that margin
would increase, perhaps to as much as 17$ - a presumable safe margin for a short
period of time since there is some ability to overcome such local deficiency
through the exercise of greater mutual assistance between various California
systems.
Conclusion; The results of this staff analysis indicates:
(l) The long-range load projections forecast by San Diego Gas & Electric,
will probably prove excessive due to: (a) inadequate allowance for
long-term energy conservation efforts; and (b) optimistic economic
predictions (disposable income and GNP) used in the forecasting
model;
(2). The short-range load projections forecast by San Diego Gas &
Electric will probably prove relatively accurate;
(3) Need for additional generating capacity is demonstrated for
the critical time period - 1980 to 1981 unless strong conserva-
tion measures are undertaken;
(4) That need cannot be satisfactorily accommodated by accelerating
the commercial operation dates of the previously postponed gas
turbine units;
j
(5) That need can be accommodated by the construction of the
previously cancelled Sycamore Canyon unit in the mid-1979
time frame.
'* ALIFORNIA-CALIFORNIACO_^\L ZONE CONSERVATION COMMISSION 'G. BROWN, . Jr.,pOvernor
SAN DIEGO COAST REGIONAL COMMISSION
6154 MISSION GORGE ROAD. SUITE 220
SAN DIEGO,CALIFORNIA 92120-TEL. (714)280-6992
CONTROL NO.:
APPLICANT:
PROJECT LOCATION:
PROJECT SUMMARY
F0451
MALCOLM A. LOVE
Chairman
ROBERT C. FRAZEE
Vice Chairman
JEFFERY D. FRAUTSCHY
Representative to the
California Coastal Zone
Conservation Commission
THOMAS A. CRANDALL
Executive DirectorSan Diego Gas and Electric Company
P.O. Box 1831
San Diego, CA. 92112
Immediately adjacent to and south of the existing four unit Encina
power plant, which is located adjacent to Agua Hedionda Lagoon and
the Pacific Ocean in the southwest sector of the City of Carlsbad,
California.
PROJECT DESCRIPTION:
OTHER REQUIRED
APPROVALS:
Encina Unit 5: Construction of a 292 Megawatt fossil fuel steam
turbine generating unit; replacement of four existing 190 foot
high stacks with a single stack, the top of which will stand 400
feet above sea level; and construction of additional transmission
lines and related generating and transmission appurtenances.
City of Carlsbad, (l) Specific Plan approved Aug., 1971» amended
Dec., 1973 (2) Building and Grading Permits issued Dec., 1973-
San Diego Air Pollution Control District, (l) Construction Permit
issued Dec., 1972 (2) Operation Permit (anticipated July, 1975).
San Diego Regional Water Qjiality Control Board, Waste Discharge
Order (pending).
California Water Resources Control Board, Certificate of Compliance
(pending).
California Public Utilities Commission, Certificate of Public
Convenience and Necessity (tentative issued April, 1974,
final pending).'
APPLICANT STATES THAT:
"Pursuant to the California Coastal Zone Conservation Act of 1972, applicant has....
filed^with the Commission supporting data demonstrating that the development will. not have
any substantial adverse environmental or ecological effect. The development is consistent
with the findings, declarations, and objectives contained in Section V of this permit
application (Coastal Act, Section 27402)".
STAFF NOTES:
1. Comment On Project Summary - This summary is necessarily limited as to technical
detail. Persons desiring additional information are welcome to review the applicant's
Environmental Impact Report, the applicant f's additional information as requested 'by staff,
and the California Public Utilities Commission Final Environmental Impact Report on file
at the Coastal Commission office in San Diego.
2. Existing Plant and Site - San Diego Gas and Electric Company retains title to
the water area and lands immediately adjacent to and south of the Agua Hedionda Lagoon.
2-4-75
BH:sel
PROJECT SUMMARY; F0451
Page 2"
Unit 5 is proposed to be added to the south end of the existing power plant, which
occupies a portion of the total 680 acre site. The plant itself is bordered by the
outer lagoon of Agua Hedionda, by Carlsbad Boulevard, by Cannon Road, and by the Atchison,
Topeka and Santa Fe railroad which parallels Interstate 5«
The inner and upper (easterly) portions of the lagoon are primarily used for public
aquatic recreation, and the waters of the outer lagoon for power plant cooling purposes.
The lagoon's continuously maintained open connection with the sea guarantees adequate
flushing and continued maintenance of stocks of marine life. From the lagoon opening
there are basically two channels; one running from the entran.ce to the power plant
cooling water intake at the southwestern edge of the outer lagoon, and the other running
from the entrance to the middle lagoon. Floating steel booms have been installed for
safety purposes to prevent boat access between the three sections of the lagoon.
The western shoreline of the outer lagoon is void of man-made structures, with the
exception of the intake pipes and dock facilities for the moored dredge. In general,
the outer lagoon shoreline, with the exception of the south east and southerly portion, is
devoid of emergent or shoreline vegetation and is lined with a riprap of large granite
boulders, which serves as a habitat for many marine species.
The existing power plant consists of three base load'units (Units 1, 2 and 3) and one
cycling unit (Unit 4)« All units are fossil fueled steam turbines which are cooled by a
single intake conduit which receives water from the outer lagoon and a single discharge
system which expells water across the beach into the ocean through a riprap discharge
channel. The four existing generating units now have a combined output of 612 net
Megawatts. A small 20 Mw gas turbine is also located at Encina, giving the total plant,
with the addition of Unit 5, a total net generating capacity of 924 Mw.
3- Detailed Project Description - Unit 5 will be a base load steam turbine unit with
an expected net capability of 292 Megawatts. The unit will be located adjacent to and
southerly of Unit 4 and be controlled from a new control room located within the plant
enclosure. When completed, all 5 units will appear as a continuous building 750 feet
long and 154 feet high. The color and texture of the exterior walls will match the
appearance of the existing units.
To meet existing air quality standards, a single stack 400 foot above M.S.L. is proposed
to replace the four existing 190 foot high stacks. The new stack would be located adjacent
to and east of the plant building, between the switchyard and plant structure. The visual
impact area of the new stack is expected to encompass approximately 34 square miles,
extending from the Oceanside pier on the north to Leucadia on the south. The necessary
duct^work to route flue gases from each of the five units to the new stack will be hidden
behind a 18 foot high addition to the facade of the existing building.
All five units will be able to operate on low sulfur fuel oil and natural gas. The
boilers of Units 4 and 5 are designed for NOx emission control, and the operation of
Units 1, 2 and 3 has been modified to reduce NOx concentrations in the flue gas. The
use of low sulfur, low ash content fuels limits S02 and particulate emissions.
Cooling water for the condensers and other auxiliary equipment will be provided by increased
use of the existing circulating water system. The circulating water system flow will
increase from a total flow, for Units 1, 2, 3 and 4 of approximately 382,000 gpm to a
maximum total from five units and discharge temperature control of 800,000 gpm. The
controlled thermal dilution flow will be used as required during conditions of maximum -
plant load to ensure that the plant discharge will not exceed the natural receiving water
temperature by more than 20°F. Cooling water will be taken from Agua Hedionda Lagoon
and returned to the ocean by conduit under Carlsbad Boulevard to a riprap discharge channel
constructed across the beach.
PROJECT SUMMARY; F0451
Page '3 ,
Fuel oil for all units will be stored on site in six storage tanks with a total capacity
of 1,339,500 barrels. Oil is delivered by ocean tanker and unloaded by pipeline from an
off-shore mooring; No changes in existing oil storage facilities or the tanker mooring
system are anticipated because of the construction of Unit 5, although an additional oil
storage tank is proposed (under separa'te application F2124) to enable oil to replace the
anticipated shortages in the supply of natural gas.
. The existing switchyard is adjacent to the east side of the plant. With the completion of
Unit 5, the switchyard will be expanded south and will feed six 138 Kv transmission
circuits and two 230 Kv transmission circuits to three off-site distribution points. All
transmission circuits will be built on existing rights-of-way now occupied by lower
voltage transmission lines.
The transmission towers extending east from the switchyards are presently galvanized,
steel frame structures 115 feet above the ground. The.lines are visible when traveling
either north or south along Interstate Highway 5- With the addition of Unit 5, the first
five sets of towers extending east of the switchyards are proposed.to be replaced with
aesthetically designed poles.
4. Plant Necessity - San Diego Gas and Electric periodically adds capacity to its
electric generating system to keep pace with its continuously growing peak loads and thus
provides reliable service to its customers. In 1971, additional generating capacity was
determined to be needed in 1975 (since revised) to meet the reliability criteria in use.
The criteria required that the reserve margin exceed the largest single capacity resource
on the system in case it should fail, and 15% of the planning peak (expected peak plus
allowance for adverse weather and/or forecast error). The capacity provided by Encina
Unit 5 will enable the system to meet the above margin criteria. Furthermore, the
project's EIR points out that if Unit 5 is not installed, there would not only be a
reduction in system reliability, but most of the energy it would have generated would have
to be generated by less efficient cycling and peaking units. This would require burning
additional fuel, which is an economic as well as environmental disadvantage.
Supply-demand comparisons, with and without Encina 5 is given in the following table as
extracted from the project's environmental impact report.
SUPPLY 'COMPARED TO DEMAND
(MO
Year
Supply:
Base Load Capacity
Without Encina 5
With Encina 5
Cycling Capacity
Peaking Capacity
Total Capacity
Without Encina 5
With Encina 3
Denand:
Average Load
Expected Peak
Planning Peak
1975
901,
1196
880
646
2430
2722
1193
2107
2271
1976
904
1196
879
756
2539
2831
1289
2280
2458
1977
904
1196
874
996
2774
3066
1392
2467
2659
rPRO'JEdT.SUMMARY; F0451
'Page 4 • '
5. Alternatives - Alternative sites were considered in place of Encina 5, but were
rejected by San Diego Gas and Electric because: (l) The overall environmental impacts
at Encina are expected to be less than that of developing a totally new site; (2)
undeveloped land will be conserved; (3) auxiliary plant systems, such as fuel oil
delivery and storage, will not be duplicated; and (4) no major additions to transmission
ri^hts-of-way will be required. Expansion at the existing South Bay plant was
considered but rejected because a new once-through cooled generating unit of such a size
could not be constructed at South Bay in compliance with the existing thermal discharge
criteria for new units established by the State Water Resources Control Boad without a
major increase in cost and lead time over that required for Encina.
Prior to the decision to construct Encina 5, San Diego Gas and Electric studied several
other methods of producing electrical energy. These alternatives, as discussed in the.
project's EIR, were eventually dismissed as being in the developmental or theoretical
stage or having lead times far in excess of the time Encina 5 must begin commercial
operation.
6. Key Issues -
A. Oil Dependency and Use - Assuming full load operation and using 100% fuel
oil, it is anticipated Unit 5 alone will consume 100 million, barrels of oil in its first
25 years of 'operation. In light of current federal policy to reduce oil consumption, a
major issue involves further expansions or additions to oil fired power plants in general,
irrespective of location. With respect to this point, as well as air quality considerations,
San Diego Gas and Electric was asked to respond to the feasibility of burning Methanol
or a similar clean fuel in lieu of fuel oil (see Appendix A). Also, meeting air quality
standards is based on the availability of low sulfur oils (,5% or less). Can San Diego
Gas and Electric guarantee continuous availability of low sulfur fuel?
B. Effe_ct on Marine Life - Fish entrainment in the cooling system does not seem
to impose a problem at Encina, however the impact of the proposed discharge system is
questionable. An ocean outfall alternative would presumably better protect the offshore
kelp bed (Department of Fish and Game) than the "across-the-beach" discharge, but may
involve greater risks to the plankton passing through the system. The issue of an outfall
system vs. across-the-beach system has yet to be decided by the State Water Resources
Control Board or EPA (see related question asked San Diego Gas and Electric, .Appendix A).
C. Effect on Air Quality - The 400' high stack is proposed in order to meet
loeaMzed air quality standards. -Can a scrubbing system be constructed which would
eliminate the need for the stack and the need to purchase expensive and scarce low sulfur
content fuels? (See related question asked San Diego Gas and Electric, Appendix A).
D. Land Use, and Aesthetics, - The site occupies a valuable and scenic portion of
the coastline. Is this a favorable location for a power plant, or should the existing
units eventually be phased out of operation? If the plant is expanded, what can be done
to improve plant aesthetics? (See related question asked San Diego Gas and Electric
Appendix A).
E. Public Access - Public access is restricted along large portions of the beach-
front and lagoon. What can be done to improve public access along these resource areas?
(See related question asked San Diego Gas and Electric, Appendix A).
PROJECT SUMMARY; F0451pe'-5
LIST OF APPENDICIES
A. Questions posed to applicant relative to Encina 5«
B. Response by Applicant to Appendix "A" questions.
C. California Coastal Zone Conservation Commission adopted Marine Environment
Element policies relevant to ocean discharges.
D. California Coastal Zone Conservation Commission adopted Energy Element
policies relevant to Power Plant Siting.
E. Miscellaneous site plans and diagrams for expansion of Unit 5-
STATf. OF CALIFORNIA-CALIFORNIA COA" "PFONE CONSERVATION COMMISSION -.. •RONALD REAGAN, Governor
SAN DIEGO COAST REGIONAL COMMISSION -* MALCOLM A. LOVE
6154 MISSION GORGE ROAD, SUITE 220 Chairman
SAW DIEGO.CALir-ORNIA &2120-TEL. (714) 280-6992 ROBERT C. FRAZEE
Vice Chairman
JEFFERY D. FRAUTSCHY
January 9, 1975. ' Representative; to the
California Coastal Zone
Conservation Commission
THOMAS A. CRANDAU.
Mr. E. M. Gabrielson Executive Director
San Diego Gas and Electric Company .
P.O. Box 1831
San Diego, California 92112
SUBJECT: Questions concerning the proposed Encina 5 generating unit,
our file # F0451- '
Dear Ed;
A preliminary review of the proposed Encina 5 generating unit has raised several
questions we would, like to discuss with representatives of your company:
1. The project's EIR briefly dismisses flue gas desulfurization installations (as
an alternative to the proposed 400' stack) as being "in the prototype stage and
their effectiveness has not been substantiated" (Vol. I, 8.3~l). Yet, our
information indicates the total number of FGD units operational, under
construction, or otherwise committed equals 93 systems at 51 plants by 39
utilities. This includes at least 19 scrubbing units now on line, for both
oil and coal fired boilers. Most of the 93 units will have started up by the •
end of 1977- As to reliability, an extensive study on FGD systems by the
U.S. Environmental Protection Agency concludes:
"Based on FGD operating experience to date, the availability of commercial
methods to treat sludge wastes, and the" rapidly growing commitment of utility
companies to instalJL FGD, no other conclusion can be reached than that flue
gas desulferization systems are available and can be used to continuously,
reliably, and effectively control sulfur oxide emissions from power plants."
In light- of these conclusions, it seems prudent to staff that your company
present a more thorough analysis of FGD feasibility at Encina, as an
alternative to the proposed construction of the 400' stack.
.-^** ' "'
2. We have some confusion as to the "sunk costs" incurred in equipment purchase
of Encina 5- As of November 1, 1973 your company reports $21,800,000 committed
to equipment, purchase and engineering costs for Encina 5 as proposed. These
costs apparently have been conmitted on the assumption that the plant, as
proposed, would be eventually approved by the involved public agencies, including
the Coastal Commission and CPUC. In fact, the CPUC EIR (page 8-2) describes
the 21 million dollar1 sunk costs as one of the reasons for not pursuing the
combined cycle alternative. . '
'Mr..E.. M. Gabrielson 2 Januarv
Is there no termination clause or other mechanism to release SDG&E from their
contractual obligations, should the plant be denied ^or should equipment,
modifications be mandated? Also, to what extent can the "sunk costs" used by
the CPUC in their analysis .be recovered from resaQ.es or otherwise?
»
3- The American Chemical Society reports excellent air quality results from
burning Methanol (in comparison with natural gas and No. 5 fuel-oil) .in full-
scale boiler demonstrations. Consequently, the San Diego Coast Regional .
Commission adopted a policy requiring applicants of "new or expanded fossil
fuel power plants to demonstrate that the plant's equipment is capable of
conversion to such clean fuels when such fuels can.be made available, or
findings'of fact that clean fuels such as methanol is not and will not be
practical for use at the particular plant."
We would appreciate your company responding to this policy.
4- Federal regulations now prohibit ocean discharges unless an exemption from
Section 316 of the Federal Water Pollution Control Act can be obtained. The
State Thermal Plan, however, permits discharge through ocean outfalls but
not from "across-the-beach" discharges, as proposed at Ericina 5- Since EPA has
sanctioned the State Thermal Plan, there may be indications that an exception to
Section 316 might be granted, however there is no indication that EPA would
permit a discharge at varience with both the State and Federal regulations.
Accordingly, the CPUC EIR concluded "that the cooling system for Encina 5 should
be designed to accomodate an off-shore or closed cycle cooling system."
Given these circumstances, would your company' respond to the outfall vs across-
the-beach alternatives, particularly with respect to the standards set by the
Marine Environment Element adopted statewide policies ?(b), ?(c), ?(d), ?(f),
and 7(g).
5- The plant's location and proximity to the coast.heighten concern with plant
aesthetics. To date, we have not reviewed a detailed landscaping plan of
the plant site, however, we expect that liberal landscaping, earth berming
and other aesthetic improvements will be included. ^ In addition to your
landscape treatment, vie would appreciate a company response to the financial
and technical feasibility of depressing the switchyard out of view as proposed
in the San Onofre additions. Undergrounding the transmission lines in the
^,,near vicinity of the plant site- should also be included in your response.
6. Large portions of the Encina beach front are now unaccessible to the public,
including the current discharge area and the area directly in front of the
plant site, indicated on your long range plan as "SDG&E Employee Recreation".
Given the Commission's objective to promote public access along the shoreline,
what, if any, dedications and/or other changes can be made to increase public
use and enjoyment of the Encina beach front?
*Mr.'.E. M. Gabrielson A 3 A January 9, 1975
7- Does Encina 5 represent the last expansion unit at the Encina site, west of
Interstate Highway 5? Accordingly, is the proposal for a new p3.ant at the
Encina site, but east of Interstate 5 'being actively considered?
We expect many of these issues to be discussed at the hearing on February 7th.
We would, appreciate receiving written response by your company as soon as possible,
but at least by the Friday prior to the hearing so that we can forward your
responses to- the Regional Commission.
William T. Healy
Principal Planner
sel
cc: Don Agatep
Frank Broadhead
SAN DIEGO GAS & ELECTRIC COMPANY
P.O. BOX 1831 SAN OIEGO. CALIFORNIA 92112
(71-1) 232-4252
January 31, 1975
CAB 500
Mr. William Healy
Principal Planner
San Diego Coast Regional Commission
6l5^( Mission Gorge Road,, Suite 220
San Diego, California 92132
Dear Bill:
In response to your questions of January 9*
1975^ referencing our application No. F0^51j Encina
Unit 5* the attached is submitted. However,, with
respect to responses on items 3 and M, San Diego Gas &
Electric Company does not waive any right to contest
the legality of the imposition of planning policies
in permit proceedings. These responses have been
prepared by several disciplines within San Diego Gas &
Electric Company.
Should you have further questions, please
direct them to me for a response.
Sincerely,
E. M. Gabrielson
Supervisor
Land Planning
EMG: Ima
Enc.
Extension: 1885
cc: Thomas A. Crandall
Don Agatep
Richard Hammond/Prank Broadhead
AN INVlSTOH-OWNtD COHPOfiAT/ON
QUESTIONS CONCERNING THE PROPOSED ENCINA 5 GENERATING UNIT
1. Question: The project's EIR briefly dismisses flue gas de-
sulfurization installations' (as an alternative to the proposed
^400' stack) as being "in the prototype stage and their effective-
ness has not been substantiated" (Vol. I, 8.3-1). Yet, our in-
formation indicates the total number of FGD units operational,
under construction, or otherwise committed equals 93 systems at
51 plants by 39 utilities. This includes at least 19 scrubbing
units now on line, for both oil and coal fired boilers. Most of
the 93 units will have started up by. the end of 1977. . As to
reliability, an extensive study on PGD systems by the U. S.
Environmental Protection Agency concludes:
"Based on FGD operating experience to date, the avail-
ability of commercial methods to treat, sludge wastes, and the
.rapidly growing commitment of utility companies to install FGD,
no other conclusion can be reached than that flue gas desulfuriza-
tion systems are available and can be used to continuously, reliably,
and effectively control sulfur oxide emissions from power plants".
In light of these conclusions, it seems prudent to staff
that your company present a more thorough analysis of FGD feasi-
bility at Encina, as an alternative to the proposed construction
of the 400' stack.. .
1. Answer; In September, 197^/ the-U. S. Environmental Protection
Agency published a report entitled "Flue Gas Desulfurization In- .
stallatiori and Operations." This report contained a list of 93
flue gas desulfurization (FGD). systems of which 19 were in operation,
14 were under construction, and the remaining 60 systems were in
the planning stages. The report indicated that some systems
^,-have achieved operating reliabilities of about 90^ with other
systems reporting reliability far below 50/£. Operating reliability
refers to whether a system.is in fact operating, not the sulfur
removal efficiency of a system. It appeared from the report that
sulfur removal efficiencies of. 9C$ were achievable when the systems
were operating properly.
Most FGD systems have been .designed to reduce sulfur
dioxide (S02) from stack gases produced from burning high sulfur
coal. After such a reduction, the emissions would have an S02
content approximately the same as that of the Encina emissions.
Some of these installations are located in geographical areas
where the continued burning of high sulfur content coal by many .
facilities has. required stack heights up to 1200' to prevent high
local ambient S02 concentrations. Several FGD systems are opera-
tional on oil burning plants, which like the coal plants, are
using fuel with a high sulfur content.
To illustrate the feasibility of flue gas desul'furization
used with five 190 foot stacks at the Encina Power Plant as an
alternative to the proposed construction of the single ^100' stack,
we would assume that thorough engineering study and design could
produce an FGD system which could be operated at 90$ reliability.
Because of local meteorological conditions of wind directional
persistence, subsidence inversion trapping, and building aero-
dynamic downwash, it can be assumed that. FGD with roughly 70$
sulfur removal efficiency will be required to maintain ambient
air concentrations at the same S02 level as would be achieved by
dispersion through the single ^100 foot stack. We .would also assume
.•:••*=•*"that such a removal efficiency could be achieved with "the low
sulfur oil burned at Encina. •
The plant system would probably consist of three separate
FGD systems - one for Unit 5> one for Unit 4, and one combined
system for Units 1, 2, and 3. Considering plant layout,'boiler
and stack location, and space availability at the plant site, the
FGD equipment would be located along the entire length of the
plant east wall facing Interstate Highway 5- This equipment would
have a striking adverse visual impact on the power plant.
An PGD system is not a single piece of equipment; it
is a complete chemical processing plant. Such a system typically
consists of chemical storage silos, mills,, slurry mixing tanks,
scrubbers, fans, reheaters, ductwork, drum filters, mills,'
and conveyors. To appreciate the physical size of the equipment,
the scrubber units alone would probably consist of six vessels,
each roughly 30 feet in diameter by 100 feet high. In addition,
the toiler flue gases would be conveyed to and from the PGD systems
through three large ducts leaving and reentering the-plant along
the upper half of the east wall. As a minimum, the-scrubber vessels,
flue gas ducts, and supporting structural steel would be visible
from east of the plant.
The scrubber system would utilize about 90 tons per day
of limestone or lime and produce about 150 tons per day of .waste
calcium-sulfate sludge. To process these large material quantities,
waste and chemical handling facilities would be located at-the
south end of the plant site. A large pond would be constructed
between the railroad and Interstate Highway-5 for temporary holding
of the waste sludge prior to off-site1 removal.
To summarize,, using the. most optimistic outlook at
the state of the art of an FGD system, we do not believe that it
is a desirable alternative to the ^00 foot stack proposed for
Encina.
1. The visual impact of the FGD system, even with
aesthetic treatment, would be unappealing.• Some of the .people
in Carlsbad feel that the ^00 foot s.tack Improves the visual .
impact of the plant when compared to the 190 foot multi-stack
design. '
2. The FGD system would increase noise levels at the
plant boundary.
3. The truck or rail disposal of the large quantities
of vlaste would create noise and traffic in the vicinity of the . .
plant. .' . . .
(
•4. Cost of the system could easily exceed the cost of
the JJOQ foot stack by $40 million.
5. The 400 foot stack will ensure dispersion of the '
plant flue gases so that ambient SOp concentrations will not .
exceed regulatory limits. Even the most reliable- FGD system will
have outages which could require shutting down the electric generating
^facility or allowing ambient S02 concentrations to increase above
allowed levels. . ..
In his December 19, 197*1, exceptions to the Public
Utilities Commission's final EIR for'Encina Unit 5, George J.
Taylor, Deputy Executive Officer of the State Air Resources Board,
cited the September 197** EPA report on FGD systems and noted the
number of such systems in various stages of development. How-
ever,, his conclusion was, "Since low sulfur oil is presently avail-
able, we do not suggest that .a scrubber be installed on Encina
Unit 5-•-" We agree with Mr. Taylor's conclusion and we urge this
Commission to adopt it. ' .
-5-
2. Question,; We have some confusion as to the "sunk costs" in-
curred in equipment purchase of Encina 5- -As of November 1, 1973
your company reports $21,800,000 committed to equipment purchase
and engineering costs for Encina 5 as proposed. These costs
apparently have been committed on the assumption that the plant, •
as proposed, would be eventually approved by the involved public
agencies, including the Coastal Commission and CPUC. In fact,
the CPUC EIR (page 8-2) describes the 21 million dollar sunk
costs as one of the reasons for not pursuing the combined cycle
alternative. .
Is there no termination clause or other mechanism to
release SDG&E from their contractual obligations, should the plant
be denied or should equipment modifications be mandated? Also,
to what- extent can the "sunk costs" used by the CPUC in their
analysis be recovered from resales or otherwise?
2. Answejr: The Company would obviously prefer to obtain all
required permits prior to incurring any costs on a project. As
of December 31.? 197^ sunk costs for the Encina Unit 5 project,
including the proposed stack, were'approximately $30,500,000.
Manufacturing lead times for major equipment (turbine-generator,
boiler, large pumps, structural steel) are such that a commitment
must be made as long as four-to five years prior to delivery. 'In
addition, regulatory agencies now require detailed knowledge
of proposed projects that can only be supplied when engineering
is nearly complete and equipment is purchased and designed. For
instance, staff's question number 3, dealing with methanol, could
only be answered with a thorough knowledge of the boiler and fuel
f' .handling system design and equipment.
-1-
Most of the major purchases for the Encina Unit 5
project had to be made several years ago, prior to the delays
which forced a slip in the project completion from 1975 to 1977.
All of these contracts contain cancellation provisions. These
provisions, in general, permit San Diego Gas & Electric to .
terminate, but. require a payment to the supplier to cover its
costs plus a percentage of its profits. Accordingly, the longer
we wait before cancelling a contract, the higher the cancelation
costs. •
In the event the project is cancelled, it might be
possible to recover some of the sunk costs by selling the
equipment to others. However, most utilities, like San Diego
Gas & Electric are cutting back on their expansion plans. It is
unlikely, therefore, that a customer could be found for the
equipment. In addition, much of the large equipment for a power
plant is custom designed to meet the plant's particular needs
(this is one reason for the long lead time on such equipment).
The fact that the equipment is custom designed limits its •
marketability. '.' • ,
-2-
Question 3
The American'Chemical Society reports excellent air quality
results from burning Methanol (in comparison with natural gas
and No. 5 fuel-oil) in full-scale bqiler demonstrations. Con-
sequently, the San Diego Coast Regional Commission adopted a
policy requiring applicants of "new or expanded fossil fuel
power plants to demonstrate that the plant's equipment is
capable of conversion to such clean fuels when such fuels can
be made available, o'r findings of fact that clean fuels such
as methanol is not and.will not be practical for use at the
particular plant."
We would appreciate your company responding to this policy.
Answer 3 ...
The boiler and fuel supply system could be converted
to use Methanol with some modifications.
, Because of the large difference in heating-value
between Methanol and fuel oil, the burners and fuel supply •
system would have to be modified to handle the higher quantity
of Methanol fuel. . • ' .'
The flue gas weight resulting from the products of
combustion of Methanol would be in the order of 2 to 5$ higher
than with natural gas producing increased heat absorption in
theJboiler superheater and reheater. This could require some
physical modification to the superheater and reheater.
The higher moisture content of the flue gas resulting
from burning Methanol would reduce boiler efficiency by about
2fo. However, boiler capacity would not be affected.
NOX generation burning Methanol would be,expected
to be comparable to that obtained on natural gas.
Followin^is a response to Questioni of the CCZCC
letter of Januar. ™ 1975.
"4. Federal regulations now prohibit ocean discharges unless
an exemption from Section 316 of the Federal Water Pollution
Control Act can be obtained. The State Thermal Plan, however,
permits discharge through Ocean outfalls but not from "across-
the-beach" discharges, as proposed at Encina 5. Since EPA
has sanctioned the State Thermal Plan, there may be indications
that EPA would permit, a discharge at varience with both the
State and Federal regulations. Accordingly, the CPUC EIR
concluded "that the cooling system for Encina 5 should be
designed to accommodate an off-shore or closed cycle cooling
system. "
Given these circumstances, would your company respond to the
outfall vs. across-the-beach alternatives, particularly with
respect to the standards set by the Marine Environment Element
adopted statewide policies 7(b), 7(c), 7 (d) , 7 (f ) , and 7(g)."
Under 40 CFR 423 Encina 5 thermal discharge is
subject to "no discharge of heat," but further provision is
made under 40 CFR 122 to obtain alternative effluent limita-
tions as authorized by section 316 (a) of the Federal Water
Pollution Control Act.
The .State Water Resources Control Board is pre-
sently proposing amendments to the State Thermal Plan which
will provide for alternative effluent limitation using the
identical procedures described in 40 CFR 122. This latter
provision is of recent origin (January 1975) and subsequent
to the CPUC review of the Encina 5 Environmental Information
Report and preparation of their Environmental Impact State-
ment.
40 CFR 122 permits the applicant to submit evidence
and data by which the State may find the effluent limitations
proposed with respect to the thermal component of the dis-
charge are "more stringent than necessary to assure the pro-
tection and propagation of a balanced, indigenous population
of shellfish, fish and wildlife in and on the body of water
into which the discharge is to be made."
Based on extensive thermal effects studies submitted
to the Regional Water Quality Control Board of the existing
thermal discharge (which has been in operation since 1954) we
are confident that a balanced, indigenous community of shell-
fish, fish and wildlife in and on the Pacific Ocean will not
be altered by the presence of the Encina Unit 5 cooling water
discharge.
In view|^ San Diego's lack of rain^jLl and the
need to import i/ freshwater supply, there ^^ample justi-
fication to use the cold waters of the Paci'rTc Ocean whenever
possible. Our experience with, the existing discharge at
Encina further indicates the proposed once-through discharge
will not interfere with the beneficial uses of the marine waters
Policy 7(c),
Independent "baseline" studies of the marine environ-
ment offshore of the Encina Power Plant have been made. A com-
plete set of the physical and biological observations are on
file with the California Regional Water Quality Board, San
Diego Region in San Diego.
These studies included, predictive results with the
increase in flow from Units 4 and 5. Unit 4 has since been
placed in service and investigations following a year of ' ;
operation verified early predictions.
Policy 7(d)
No new site will be needed for the intake of water
for Encina 5. The present intake has an excellent record of
minimizing entrapment of marine life. To our knowledge, no
conduit form of intake has a better record. Entrainment
mortality has also proven to be less than that for a closed
cycle system (where 100% mortality occurs) or for a conduit
outfall.
Policy 7(f) . .
Experience with a thermal discharge in the vicinity
of a kelp stand which appeared after the discharge commenced
has indicated there is little possibility that the habitat
will be lost. There may be some minor thermal cropping of
the canopy. But, canopy cropping is done commercially without
causing a loss of the habitat. At most, only a small fraction
of the kelp bed will be exposed to the thermal plumes.
Policy 7(g) . '..'.'
Monitoring of the thermal discharge will be performed
and regular reporting made to the Regional Water Quality Con-
trol Board and the Environmental Protection Agency. All
monitoring -will be performed by professionals whose qualifi-
cations will be reviewed by the agency.
-2-
5. Qli§.st.i.on.: "in addition to your landscape treatment, . we would
appreciate a company response to the financial and technical
feasibility of depressing the switchyard out of view as proposed
in the San Onofre additions".
5. Answer; The visibility of the present and proposed switchyard
additions from the surrounding areas will be very limited due to
the existing berms and the present and contemplated landscaping.
The substation area is almost totally obscured from all points on
Interstate 5 except at the Cannon Road overpass. Prom this loca-
tion, the power plant rather than the ocean is the background for
the existing and proposed substation facilities and, because' of
the similarity of colors, the substation structures are not
readily noticeable.
The proposed 230 kv substation structures will be no
*higher than the existing 138 kv structures. Specifically, the
maximum height of the 138 kv structures is 58'6" and the^.maximum
height of the proposed 230 kv structures is 57'3". Therefore,
since the ground elevation of both switchyards will be the same,
the new structures will be 1'3" lower than the existing structures.
Due to the-topography of the Encina site, it would be
inpossible to depress the switchyard in the same manner as San Onofre.
In the case of Encina, the existing substation grade is only 17
.'feet above sea level. While it would be technically feasible to
\
lower the present -and proposed substations to a point several feet
above sea level, it would be prohibitively expensive. Such an
expense does not appear to be warranted since the visibility of
the substation would not be materially reduced and the overall
appearanee of the Encina facilities would not be significantly
altered.
'5- Question; "Urk^rgrounding the transmissiv^/lines in the near
vicinity of the plant site should also be included in your response".
5. Answer: The installation of Encina Unit 5 will increase the
total plant capacity from approximately 600 Mw to 900 Mw; however,
the number of transmission circuits and structures emanating from
the plant will not be increased. Presently, eight 138 kv circuits
installed on four rows of'double circuit structures transmit the .'
\
electrical output of Encina Units 1-4 to the bulk power transmission
network.Encina Unit 5 -will be. connected to the bulk power system
by two new 230 kw transmission circuits -- one each to Escondido
and Old Town Substation. This will allow two of the eight exist-
ing 138 kv circuits to be removed. The six remaining 138 kv cir-
cuits will be rearranged so that when Encina Unit 5 is installed,
there will be no more than eight circuits on four rows of double
circuit structures leaving the plant and^crossing Interstate 5«
In order to construct the two new 230 kv circuits, two
rows of 138 kv structure must be replaced with 230 kv structures.
In accordance with SDG&E's established criteria, the new 230-kv
structures on either side of Interstate-5 will be aesthetic steel
poles rather than lattice steel towers.- Furthermore, since SDG&E
considers it to be extremely undesirable to have a mixture of..
structure types crossing Interstate 5^-the two remaining rows
-of lattice towers will also be replaced with aesthetic steel poles.
The planned .replacement of the existing lattice steel towers with
aesthetic steel poles on both sides of Interstate 5 will result
in a significant reduction in the visual impact of the transmission
' . ' * .facilities in this area. i.
Undergrounding of the two 230 kv circuits- and six 138 kv
circuits crossing Interstate 5 is technically feasible; however,
the cost of this installation,would be extremely high. To place
these circuits underground,, -eight five-foot wide trenches would
have to be dug from the plant to a location on the east side of
Interstate 5- Two steel pipes each containing a paper-insulated
three-phase cable surrounded by oil would be placed in each trench.
A spacing of approximately 20 feet would be required between trenches
to ensure adequate dissipation of the heat generated by each pair
of cables. East of Interstate 5, a substation type structure,
similar,-in appearance to the plant substation, would have to con-
structed to terminate the 16 pipe-type cables and connect them to
the eight overhead circuits. - .'
Detailed cost estimates have not been prepared for
undergroundi'ng the 230 kv and 138 kv transmission circuits emanat-
ing from Encina. However, based on estimates prepared for under-
grounding other high capacity transmission lines in this voltage
range, we estimate that underground transmission would be 10 to
15 times, more expensive than the equivalent overhead line. The
Authur D. Little, Inc. report entitled "Underground Power Trans-
mission" which was prepared for the Electric Research Council
•'••**"' also indicates that, based on today's technology, underground to
overhead cost ratios for 138 kv and 230 kv transmission are
within this range. Since the overhead line construction within
the Coastal Plan area is expected to cost about $2,000,000, the
cost premium for undergrounding these lines would be in the
-$18,000,000 to $28,000,000 range.
-3-
6. Question: LaV-gfe portions of the Encina •b'Sach front are now
unaccessible to the public, including the current discharge
area and the area directly in front of the plant site, indicated
on your long range plan as "SDG&E Employee Recreation".
Given the Commission's objective to promote public
access along the shoreline, what, if any, dedications and/or other
changes can be made to.increase public use and enjoyment of the
Encina beach front?
6. An_sjwer: The inner and middle lagoons which are private
property of San Diego Gas & Electric Company are both available
to the public for boating and skiing through leases to the City
of Carlsbad and the YMCA. The San Diego Gas & Electric Company
private property west of Carlsbad Boulevard and north of the
discharge channel is all open to the public for swimming and fish-
ing through leases to the City of Carlsbad. • The private property
east of Carlsbad Boulevard along the Outer lagoon is open to
the*public for fishing. The public beach south of the discharge
channel and west of SDG&E's property line is open to the public
for fishing and swimming. Public access to this area can be
attained from a southerly direction from points beyond SDG&E's
property. The private property west of Carlsbad Boulevard from
the discharge channel to our southern property line, which is
indicated on the precise plan as SDG&E employee recreation, is
restrioted from the public. The justification for such restriction
is as follows:
1. A submerged fuel oil pipeline crosses that property
from the offshore mooring facility to SDG&E's tank farm. Unre-
stricted public access would enlarge'the risks involved in plant
security surrounding a vital link in the generating capacity.
.2. Should a second discharge channel ever be .built,, it
would be across this private property in the location as depicted
on the specific plan. To preserve that future option for SDG&E,
vie cannot create a dedication to the public use for recreation/
either express or implied, which would limit SDG&E's ability to'" .
use this particular parcel•in the future for electric production,
purposes. Until such time as this particular parcel may be required
for such plant facilities,, it has been leased to the San Diego
Gas & Electric Company's Employees Association. Private access
has and will continue to be allowed, with prior approval from
the Association and SDG&E. Many organizations,, including the
Sierra Club, .have been granted permission to use this particular
parcel.
'• • 3. That portion of this parcel immediately adjacent
to the discharge channel is restricted for the further purpose
of insuring the safety of the public. The State Parks beach
lifeguards have requested that we put the public on notice of
the hazards involved in entering the discharge channel. In •
light of the numerous recreational facilities which have been
made available to the public at our plant site,, there would appear
to be rro justification for increased public use.
-2-
7' Ques^t^lon: Does Encina 5 represent the last expansion unit •
at the Encina site, west of Interstate Highway 5? Accordingly,
is the proposal for a new plant at the Encina site, but east of
Interstate 5 being actively considered?
7. Answer: Encina Unit 5 is the last generating unit addition
currently being planned for the Encina site west of Interstate
Highway 5. For the time period for which specific plans have
been prepared no generating untis are proposed for the Encina site
east of the highway. The plans for future generating plant
additions are listed in the EIR and none of these units are planned
for installation at Encina.
However, we must point out that should electric re-
quirements continue to increase and conditions change as far as
alternative energy resources, then Encina would again be evaluated .
for additional generation. Again we would be required to obtain
regulatory approvals as in the past. . . '
)•••••••
MARINE ELEMENT
Adopted Statewide Policy Concerning Thermal Discharge
7. AVOID ADVERSE IMPACTS OF THERMAL DISCHARGES AND ENTRAINMENT
To avoid adverse effects of usijig seawater for cooling or heating in power
and industrial plants:
a) A State agency should be adequately- empowered and funded to direct and
coordinate research on the effects of thermal (heated or cooled) dis-
charges and entrainment of organisms on the marine environment.
[See (c) below.]
b) Until more is known about the effects and methods for mitigating impacts
of once-through cooling systems, closed or evaporating systems should
be required unless an applicant can demonstrate that overall environmental
advantages justify both a coastal location and the use of once-through
cooling systems. [Refer also to the Energy element policies on power
plant siting.] ,
c) Independent "baseline" studies of the existing marine system should be
conducted and evaluated for all potential sites 'at the applicant's
' expense several years in advance of the construction of a major
seawater-using power or industrial plant.
d) Where cooling or industrial processing waters are drawn from marine
waters, the best available technology should be utilized and best
potential site chosen to minimize the intake and mortality of all forms
of marine life (e.g., offshore intake points, velocity caps, and fish
return systems).
e) Warmed or cooled water discharges should be permitted only where rapid
return of water to normal ambient temperature can be assured and where
best available mitigation measures have been incorporated as necessary
to minimize effects on marine life.
f) New discharges into coastal wetlands, marine reserves, wildlife refuges,
education and research reserves, or in the vicinity of kelp beds should
be prohibited unless it can be conclusively demonstrated that there
**~*r' win be no significant adverse impacts.
g) Existing and new thermal discharges should be periodically monitored
(by independent researchers or a State agency), and appropriate
mitigation measures or alternative systems should be required where
significant adverse impacts are discovered.
ENERGY ELEMENT
Adopted Statewide Policy Concerning Power Plant Siting
15. MINIMIZE ADVERSE ENVIRONMENTAL IMPACTS ON COASTAL RESOURCES
Because the coastal zone represents a valuable, fragile, and finite resource,
because power plants have major potential impacts on land use, air quality,
and the marine environment, because virtually all of the State's major
power plants are located on the ocean coast or the shores of San Francisco
Bay and the Delta, and because studies have estimated that there may be
need by 1990 for as many as 20 major new sites, which, if located primarily
on the coast, could have significant adverse effects on coastal resources,
new power plants should be approved in the coastal zone only when it can
be demonstrated that:
^a. Energy conservation efforts, including conserted efforts by the applicant
within its service area, cannot reasonably reduce base load and peaking
requirements sufficiently to eliminate the need for the proposed facility.
b. Greater presently identifiable adverse environmental impacts would
occur from utilizing obtainable alternative inland or coastal sites or
alternative technologies. In evaluating alternative sites and
technologies, in addition to the factors included in the Warren-Alquist
Energy Act, consideration shall be given to evaporative, dry and dry/
spray, and salt water evaporative cooling towers, and the following
potential water sources should be considered in evaluating the impact
of providing cooling water an inland sites: (l) surplus freshwater
supplies already allocated to power generation but not presently being
used; (2) agricultural or municipal waste water; (3) freshwater supplies
that can eventually be replaced by waste water; and (4) other fresh-
water supplies, if it is. determined that there is sufficient water
available after the reasonable needs of other users are met so as not
to deprive inland or coastal areas of freshwater needed for agricultural
production. To assist in evaluating alternative sites the utility or
utilities proposing the coastal site shall submit e comprehensive
evaluation of reasonable alternative coastal and inland sites and
.„,,..,- generating technologies, including the environmental reasons for
" rejecting them in favor of the proposed site, sufficiently in advance
of a desired decision that an adequate and independent analysis can be
made. The primary responsibility for the identification of such
alternative inland sites should rest with the State Energy Commission,
and the identification or certification of such a site by that Commission
demonstrates that such suitable alternative inland sites are available.
c. In the case of a proposal for a new coastal site, the need for new
capacity cannot or should not be met by plant expansion at an existing
inland or coastal site which has been identified as suitable for
expansion. The primary responsibility for the identification of such
sites suitable for expansion should rest with the State Energy
Commission, and the identification, or certification of such a site
by that Commission demonstrates that such suitable sites for
expansion are available.
d. The proposed power plant- and the land use restrictions required by
the State Energy Commission on the surrounding area as required by
the Warren-Alquist Energy Act to protect public health and safety
will not conflict with other existing or planned coastal-
dependent land uses at or near the site.
e. In the case of a nuclear power plant the proposed site is in an area
of minimum seismic hazard in comparison to alternative sites
reasonably capable of serving the utility's or utilities' service
area or areas; the proposed plant is designed to safely withstand the
effects of the most severe seismic activity thought possible in the
site area; and the number of people and their distribution within the
potential radiation hazard area meets AEG and State Energy Commission
criteria, and the people can be readily evacuated in the event of an
emergency.
f. The generation and cooling systems proposed are the least environmentally
damaging, technologies projected to be available at the time of scheduled
construction. The cooling system technology employed shall satisfy
'• ' the environmental protection requirements of the Marine Environment
element; and where a once-through cooling system is proposed, the
project shall meet the standards set by the Marine Environment•State-
wide Policies ?(b), ?(c), 7(d), 7(f) and ?(g). Improvements in the
cooling systems of existing facilities at the site may be weighed by
the agency designated to carry out the Coastal Plan in determining
compliance with this subsection.
g. In the case of a proposed new coal- or oil-fired electric generating
plant at a new site, or a proposed plant expansion at an existing site,
the project will cause no significant degradation of air quality. The
facilities shall be sited and designed to minimize the effects of
pollutants for which there are designated Federal or State ambient air
quality standards, and shall employ the least polluting technology to be
available at the time the facilities are designed to go into operation.
Such facilities shall not be built in areas of the coastal zone designated
.by the Air Resources Board as "critical air areas", or in areas where
coastal resources such as health resorts or agricultural lands would be
adversely affected, unless the agency designated to carry out the Coastal
Plan determines that there is no alternative inland or coastal location
where siting would result in less adverse environmental degradation.
In no case shall expansion take place in a critical air area, or in an
area where coastal resources would be adversely affected, unless there
would be a net decrease in generating system emission of pollutants for
which national or state ambient air quality standards have been established.
Normally this requirement will apply to each individual plant for which
• - expansion is proposed, unless it can be demonstrated that the emissions
from two or more near-by plants affect the same geographic area. If such
a determination can be made, then the plants involved can be treated as
one unit for the purposes of this policy. Reduction in emissions may
be accomplished by modernization or retirement of existing facilities.
The plant will be set back from the shoreline to avoid adverse visual
impact on the shoreline, and is designed and located to minimize
adverse environmental effects, including but not limited to effects on
fish and wildlife and their habitats, and on scenic, agricultural, and
other resources of the coastal zone. The plant should riot be located
in a highly scenic area as defined in the Appearance and Design
Element.
A substantial area will be established for permanent public use and
enjoyment of the coast and may include a substantial dedication of land
to the public.
As alternative, less environmentally damaging generating technologies
become widely available so that some of the existing fossil fuel or
nuclear generating facilities can be phased out and removed, priority
shall be given to removal of these facilities which are in prime
beach recreation areas.
SDG&E
ENCINA PLANT
N
SCALE 1:24000
SAN LUIS REY, CALIF.
NE/4 OCEANSIDE 15' QUADRANGLE
N3307.5—WU715/7.5
Vicinity map SDG&E Encina Plant.
Wliii^4^-T&f^&i*? ^iXSP^J
ENCINA POWER PLANT
Unit No. 5
AERIAL VIEW
OF PLANT AND ENVIRONS
LOOKING N.E.
Figure 1.1-2
C A R \ L S B A
MIDDLE LAGOONOUTER LAGOON
LOCATION KEY
DISCHARGE:
CHANNEL
fUEL OIL FILL Uf>C
- EXISTING
- UNIT S
- FUTURE
SAN DIEGO GAS ft ELECTRIC COMPANY
SAN DlEOO, C»UfORNIA
ENCINA POWER PLANT
PROPERTY PLAN
nor mn ^-10-72 i
DIEGO GAS & ELECXJlic GO'S.
NCIISTA P-OWER. PLANT
E3 rnoi'OHED FACILITIES ADOPTED
IIV DI1DINANCE N08J79
C3 I'HOI'OSED It EXISTING LANDSCAPING
ACHICOLTUnAL USE
OPEN WATEH AI1KA
MULTIPLE USE UTILITY COflHIDOH AREA
RUU USE ••- ACIUCULTURAL
PIIOI'OSKD BINOLE STACK
E.3 L'XISTINO FACILITIES
APPROXIMATE LOCATION OF FUTURE PARK
'1 ^.
-
} .
•j»f'-l^.VW<lt»^>i^^l-^-^j»^^iAtfol^.^
-^••^\>^&<£z^g^£z^&^i£^^^« ^Hiai-i^l^jiiiii
-»w>-,.-^** .U.wa_ "ttj'^it>»l*.-/.» L>A.'3(.tlJi£lJ. .Vji'i^
.: ''77^- - . *,^: ;.^Y ;• -J'*, "^ r>- 1.'-fc^<*11-*-"' ;,. •» .-.;--^s7: • -- *"V - r '1*'*'*-*™
*"-. v,.'rv::..;*-'•'•:.' ;••;•:...-.:.'-.r--Mv .-"•".' -•.-.-.-:>-.•.': 'o^V^,,,!.*]*
.^uwusuiSEii .v.V^O-i^r^.^'^-rr.-'^Vy ;>:-' uri^t^ii .U'.-*:; r.^"->^-- >*^^^ ^'..a
•^^^^^^^•^-^- ......... /••.-•* » .•• i- •-.-~^..- -« . . • •'
' I'it
i
••Jl|p
- .1$':
""'T-f. ^^^'''ii^^'^r.., IK ' r v ''.': r:"'" ••• --7-: !'.,.-».-
' ' % ••'•'• i^ ' 11^"-^ • ^—-' ' n ^- '.. -o : ' • r,'i-T3«SJ f-i CTrrs's-miw ? !. '; sr?irrorrr^r ' Wrv? ins r. -. 1.1 i'-.^-'.* ^^-.r 5 '--V ... :;T. :. ;;y;i^!re! • . FSKf**^"* J -, • K-IK^K^S .. Mwta PHI H. :. •- .[}••••!,*.-•• •••>•:: . , 5 ••• • $ • ' ' ',"•-"-'. . r - • < , . .;.-; !,:•<! .;!•!: ,-- u'• V.-'re1-'.I'--.-N r •'•'..i'. •••• r .Ij j r"- .: «;.:-cwra ~7 B=rsB=JtT-iv-i( nsysj^T;.->. 3
C€^'T^p:#-W'' )ti{i-{-.w^lr-)K.;,-*^y^OT
-,*4
1!
i
'•' ~. .^--j^...
\~ ,:••• •• >:' •:--v--M-,^--••:,s.^-.r-v;,«-fcgju^^t&ii^m'.: VigTMi a^W^-^ki^.
i''?.L*rI'-. J»
^iy-. <^v .::, "_.jf ^q-^^^^^^^u.^;^^--;;^.^ ycyy^v.
i^... . ,....„.,.„. .. ' -.'•.-••..•• /• ', '•• .•• - -^ /-;... • .r''/-;^.".';[';" .''••>'^-'>f\'.f'^-^f •V'fyv;';M-....y,-.^-1t;.:-;;.> ^-r.A,^. .^., v.;^}
[^J_, .'*. -^J-_., "1..-I.',. •'•'• ^•'•^^X-^/*i-I-^^i^I:S^&=Ji^;>y^^
VH4^J
•^-11*1*
r~4
'^
i~~~Ar3
Italia
MI,—J
fc-*jrf3
i
3
i—4i
k^^U^
«^*^4
3^
±3
^wisfe^pi^^S^f^i^fep^^'''^ \/ ,\:v^"V'*S^JrMd^;*r -i- . - -i- -^ >-
, 'L-^V\V'P
-y.
Figure 3-2. Visual impart area — SDG&E Encinr
Table 3.9-1
ENCINA EMISSIONS TO THE ATMOSPHERE
Effluents
Sulfur Dioxide
lb/106 Btu
vol %
Nitrogen Oxides
lb/106 Btu (gas)
(oil)
ppm (gas)
(oil)
Particulates
lb/106 Btu
grain/scf
Emission Standards
EPA
(New Sources)
0.8
0.20
0.30
"
0.10
SDAPCD
0.05
existing new'3'
225 125
325 225
0.1
Emissions from Encina Unit No.
1
0.53
0.03
0.244
0.333
200
275
0.192
0.100
2
0.53
0.03
0.276
0.330
225
275
0.190
0.100
3
0.53
0.03
0.240
0.324
220
275
0.186
0.100
4
0.53
0.03
0.137
0.249
125
225
0.100
0.060
5
(New)
0.53
0.03
0.131
0.250
125
225
0.100
0.060
a. Beginning January 1, 1974, the lower limits will apply to all sources.
COn
O2!
O O
t_c
VO•^1to
UNDISTURBED FLOW
c
Figure 5A-1
ATMOSPHERIC FLOW CHARACTERISTICS WITH A SEA BREEZE AT THE
ENCINA POVA/ER PLANT (ELEVATION LOOKING NORTH)
c_
c
U)
REGION OF HIGH CONCENTRATION
DOWNWASH
PACIFIC
OCEAN
Figure 5A-2
TYPICAL BUILDING WAKE DOWNWASH AT EXISTING ENC1NA POWER PLANT
WITH 190-FOOT MSL STACKS (ELEVATION LOOKING NORTH)
V
AVERAGE INVERSION HEIGHT
STABLE LAYER
C
CRITICAL INVERSION HEIGHT
PACIFIC
OCEAN
M
u v- . ' ,-, f .
PLUME TRAPPED BELOW INVERSION
<±^±£t AGUA HEDIONDA :fv
^ LAGOON
Figure 5A-5
LIMITED MIXING CONDITION AT THE
• ENCINA POWER PLANT
(ELEVATION LOOKING NORTH)
FUEL OIL TANKS
• 250,000 BBL. EACH,
SWITCHING
STATION
STRUCTURE
131,500 BBL. EACH
VALVE PLATFORM
MARINE FILL LINE
HOSE
ENCIJSIA POWER PLANT
Unit No. 5
FUEL OIL SYSTEM
Figure 3.6-1
ACUA HEDIONDA
LAGOON
INTAKE-DISCHARGE
INTERCONNECTION
(Gates normally doled)DISCHARGE TUNNEL
DISCHARGE-jf;
POND (i;XBRANCH TUNNELS
DISCHARGE
TUNNEL SCREEN
STRUCTURE
TRAVELING WATER SCREENS
TRAVELING WATER SCREENS
UNIT 5 CHANNEL
DISCHARGE
CHANNEL
ENCINA POWER PLANT
Unit No. 5
CIRCULATING WATER
INTAKE & DISCHARGE STR'JCTVRE
09C
m
t-o
U.S. HVVY 101 —
AGUA HEDIONDA
LAGOON
E: ENCINA POWER PLANT
G
• A-30
.A-5Q
wX1-HC/lH
O
oo
n
S
O
m
g
zc>
~ o
p m
-or~
>
ZH
•B-50
• G-10
• G-20
•G-30
•G-50
PACIFIC OCEAN
1000 FEET
KEY:C
AREA OF KELP BEDS {APPROX.)
AREA OF ROCKY BOTTOM (APPROX.)
AREA OF MEASURABLE BIOLOGICAL IMPACT
AGUA HEDIONDA
LAGOON
-P.C
DISCHARGE CHANNEL
/ 7[__ J ENCINA POWER PLANT
t-1c.
I^J^^
,J
VO-Ju>
*TJ
H-
tXJc
m
•
V
03
1
2Oo oz: wt-1
prH ij
H Wtn co
§ f0 H
O 00Z
0 0
^ f
C_ M
z nK s
M >VO 00
M
N5 O
m
*"^o
^^c>
5' 0z 5p m
en
r~
'••"-.•.adH
FLOWRATE: 620.000 GPt
TOTAL TEMPERATURE RISE: 18.8(";0
LEGEND
0 1000
SCALE IN FEET
4° ISOTHERM AREA
KELP BED AREA
CURRENT SPEED (FPS): 0.3
CURRENT DIRECTION: DOW
TIDE STAGE (FEET ABOVE MLLW) :5.0
AMBIENT OCEAN TEMPERATURE: 70F
. INTAKE TEMPERATURE: 72F
NTOAf.
OA
CARLSBAD BLVD-
• A-50
DISCHARGE CHANNEL
• B 50
PACIFIC OCEAN
.•-,;. 1 J ENCINA POWER PLANT
«,.„» """ /V-'^E-IO^T^^-r--^
____-«
»C 20
« 0-JO /••:-QE.»«F-IO
• co. »o.,o x.y||ii||itJH;-MiSii^
• £-30 -;^:-V^'?W&
''^ LXX-^*sj«sys;;• 'ViV --^vvC-.^-V^;J\\v-s.W ;.«? F-30J-.i^^:^-.r
v-^
• C-50 • D-SO
0E-60 \:\ » F-60
• G-tO
»G-JO
-'•Z?'
• 0-30
• G-60
KEVi
|/^3 AREA OF KELP BEDS IAWHOX.I
j.'.-.;..| AREA OF ROCKY BOTTOM (AJfnOX.I
['•'•::'l] AREA OF BIOLOGICAL IMPACT
[lv'-j AREA OF POSSIBLE ECOLOGICAL CHANGES
n AHEA OF KELP BEDS IAPPBOX.I
AND POSSIBLE ECOLOGICAL CHANGE
SCALE IN FEET
ENCINA POWER PLANT
Unit No. 5
PREDICTED IMPACT OF AIL 5 UNITS
Figure 5.1-15
July 1973
^^K"XD'vT* >•«£'"
H rTp^^^::i -• • - f ^immmmmmm^m^'"•L. _ j-y,- • -4'4 CLEVELAND] S>e^r- .t|»u%.^^%^^SN^^lH^\^^:ife^\*-^ ^S r-!,v^li^'^'^v^l I- - ^uffSii^^W=Mj^^S^^PR^h^^ SWffP1
•:KK-^ r'\-.-i^:2ssii*N»L>-—:-A. -\-1 .^"'TO-H^fc ^° iX^'^st^^'-^
•^"(^•.••5. \,-^^'; \'^^®^F**3%^&zu «.. IU^f s^W 3<i.nu vTZbrt- -.^N^^^t- ^ A'. ^^.>{ 1V7/-'^ '->5^V- "a...
ENCINA POWER PLANT
Unit No. 5
•^'' '
f>—' ^/ I * \ .••-•- Jt—-4——San Luis fey1 J '* \ *• '1 'A
_X<U/, ""'SKvaney Center 1 [ rH
ENCINA POWER PLANT
?^rr]m-^j
Figure B-l
ETER
230 KV
ESCONDIDO AJA
69 KV
MISSION
LEGEND
EXISTING 138 KV LINES
EXISTING 230 KV LINES
• NEW 230 KV LINES FOR
.ENCINAUNIT5
ENCINA POWER PLANT
Unit No. 5
1975 TRANSMISSION ADDITIONS
FOR ENCINA UNIT 5
Figure 3.3-2
.V-.
I
-3STREAMVIEW!*?-1
SU8. »H>
TLEOI-X'V/''V;%X
4 sn'//>6^*>=£
STATION
POWER PLANT
55.0011 KV; NET
4S.OJ/W
GAS TURBINE AT
NORTH ISLAND
J.O r.W GAS
TUREINEAT
PTLOV.A SEWAGE
TREATMENT PLANT
OCEANPACIFIC
SUBSTATIONS
230 KV TRANSMISSION LINE
63KVTRAf;S,V.ISSIONLINE
1JJKV TRANSMISSION LINE
ENCINA POWER PLANT
325,003 KW STEAM
ZO.COO KW GAS TURBINE
345.000 KW NET
1972 TRANSMISSION SYSTEM
BETh'EES ENC1NA AND SAN DIEOO
CITY UDAO CEOTER
PROPOSED230KV PROPOSED230KV \
FROM MISSION FROM MISSION
TO OLD TOWN 1} TO OLD TOWN
Ft/WLINE
PROPOSED
230KV
STEEL POLE
FUTURE PROPOSED230KV
CIRCUIT FROM ENCINA
TO OLD TOWN
PROPOSED230KV PROPOSED233KV
FROM MISSION FROMMISSION
-25FT--SOFT--Z5FT-
-108FT-
R/WLINE
EXISTING 13«KV
FROM MISSION
TO OLD TOWN
R/WLINE
TO OLD TOWN
EXISTING 69KV
TO 010 TOWN
_• _ . 180 FT i
=a.
R/VfLINE
c,
R/W CROSS SECTION L-L R/W CROSS SECTION M-M
MISSION-OLD TOWN RIGHT-OF-WAY
c, ex
ENCINA POWER PL ANT
Unit No. 5
SCHEMATIC DIAGRAM OF R1G!1TS-OF-V.'AV
AND TRANSMISSION' LINE LOCATIONS
OF THE PROPOSED 230 KV LINES
ASSOCIATED KITH ENCINA I'XIT SO. .'
Figure 3-2 (Sheet 10 of 10)
IS,
1c _
/
ih
•»'{'*)
v^»X 1
Form Approved. Budeet Bureau No. 04-R0001.
DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION
NOTICE OF PROPOSED CONSTRUCTION OR ALTERATION
TO BE COMPLETED BY FAA
AERONAUTICAL STl'DY NO.
1. NATURE OF STRUCTURE (Complete both A anil B below)
. (Check one)
NEW CONSTRUCTION Q ALTERATION
• (Check one)
(7] PERMANENT TEMPORARY
(State length
of time) ~~.Mas.
2. NAME AND ADDRESS OF INDIVIDUAL, COMPANY, CORPORATION, ETC. PROPOSING
THE CONSTRUCTION OR ALTERATION (Number. Street. City, Stale and Zif Code)
rSAN DIEGO GAS & ELECTRIC COMPANY • T
TO P. 0. BOX 1831 •';.-....
San Diego, California 92112
ATTENTION:
L
T. M. "Mutt
Right of Way Agent J
FAA WILL COMPLETE AND RETURN THiS
FORM IF ONE OR MORE .OF THE FOLLOY/ING
IS APPLICABLE, OTHERWISE SEPARATE AC-
KNOWLEDGEMENT WILL BE ISSUED.
A. A STUDY OF THIS PROPOSAL HAS DIS-
CLOSED THAT THE PROPOSED STRUCTURE:
NOT REQUIRE A NOTICE TO FAA.
WOULD NOT EXCEED ANY STANDARD
£SjoF PART 77 AND WOULD NOT BE A
HAZARD TO AIR NAVIGATION.
4 SHOULD BE MARKED AND LIGHTED PER
. _,FAA "OBSTRUCTION MARKING AN3
1X1 LIGHTING" ADVISORY CIRCULAR
70/7460-1. . ;,
REQUIRES SUPPLEMENTAL NOTICE.
{^NOTICE FORM (FAA FORM 117-1)
ENCLOSED.
B. COPY SENT TO FCC? DYES J5j NO
ViEWIN^O^ICER DATE
3. TYPE AND COMPLETE DESCRIPTION OF STRUCTURE -
Replacement of 4 stacks at San Diego Gas & Electric Company's Encina Power Plant wit
a single unit. This includes a 24' facade addition to the generator enclosures to
conceal duct work. The proposed stack will be 52 feet in diameter at the base, 33
feet at the top, and will stand 383 feet above ground level.
4. LOCATION OF STRUCTURE
•A. COORDINATES (To •COr.ct}
LATITUDE LONGITUDE
B. NEAREST CITY OR TOWN, AND STATE
Carlsbad, California
33 08 n 117 20 08
(1) DISTANCE FROM 4B
10,000+'
(2) DIRECTION FROM 48
South
.NAME OF NEAREST AIRPORT, HELIPORT, OR SEAPLANE BASE
Palomar Airport
(1) DISTANCE FROM NEAREST POINT OF
4C 15,250+
(2) DIRECTION FROM.AIRPORTNorthwest
.DESCRIPTION OF LOCATIOS OF SITE WITH RESPECT TO HIGHWAYS. STREETS. AIRPORTS. PROA!/\£.Yr TERRAIN FEATURES. EX
/ST/.VG STRUCTURES. ETC. (Attach a highway, street, or any other appropriate map or scaled drau ing showing the relationship of construction
site to nearest airport(s). If more space is required, continue on a separate sheet of paper and attach to this notice.)
Situated between the Pacific Ocean and Interstate 5, south of the city of Carlsbad.
5. HEIGHT AND ELEVATION (Complete A. B and C to the nearest foot)6. Y/ORK SCHEDULE DATES
A. ELEVATION OF SITE ABOVE MEAN SEA LEVEL
B.HEIGHT OF STRUCTURE INCLUDING APPURTENANCES AND LIGHTING
tilc-yl ABOVE GROUND, OR WATER IF SO SITUATED
C. OVERALL HEIGHT ABOVE MEAN SEA LEVEL (A + B)
17.0'
383.0'
A. WILL START
June 197g
400.0'
B. WILL COMPLETE
Unknown
7. OBSTRUCTION MARKINGS-The cem-alatcj structure wil! be:
A. MARKED AS SPECIFIED IN THE FAA ADVISORY CIRCULAR 70/7460-1, OBSTRUCTION MARKING AND LIGHTING
B'. LIGHTED AS SPECIFIED IN THE FAA ADVISORY CIRCULAR 70/7460-1, OBSTRUCTION MASKlKO AND LIGHTING
YES NO
I HEREBY CERTIFY that ail of the above statements made by me are true, complete, and correct to the best of my knowledge.
8. NAME AND TITLE OF PERSON FILING THISNOTICE ">/* <" P"'»»l 9. SIGNATURE/ «,-'«•« 771
T. M. Nutt
Right of Way Agent
9. SIGNATURE/ (/,
10. DAT.E OF SIGNATURE) 11. TELEPHONE NO. <P,fceJ, wilt, area coJ
1(714) 232-4252, Ext. 1715
Persons who knowingly and willfully fail to comply with the provisions of the Federal Aviation Regulations Part 77 are liable to a fine of
J500 for the first offense, with increased Penalties thereafter as provided by Section 902(a) of the Fedeiai Avi^iioa Act of 195S as amended.