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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 of Fish and Game has withdrawn its objections to the'plant at this time subject to the conditions recommended to protect the offshore kelp bed; (2) the San Diego Air Pollution Control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.