HomeMy WebLinkAboutReso 1990-15826 RESOLUTION NO. 15826
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CHULA VISTA
ADOPTING PRELIMINARY REPORT TO THE CALIFORNIA ENERGY COM~4ISSION
REGARDING PROPOSAL BY SDG&E FOR A NEW POWER PLANT IN CHULA
VISTA (89-NOI-1)
The City Council of the City of Chula Vista does hereby resolve as
follows:
WHEREAS, the San Diego Gas and Electric Company (SDG&E) has filed a
Notice of Intention with the California Energ~v Commission to construct a
combined cycle electrical generating facility of approximately 460 megawatts,
and
WHEREAS, one of the potential five sites for the location of that
facility is the Chula Vista South Bay Power Plant site, and
WHEREAS, the application of SDG&E in California Energy Commission
proceeding 89-NOI-1 was determined to be data adequate by the California
Energy Commission on March 28, 1990, and
WHEREAS, the City has extensively gathered facts and participated in the
proceedings and obtained sufficient information in order to allow it to
prepare a Preliminary Issues Report to the California Energy Commission, a
copy of which is on file in the City Clerk's Office, and
WHEREAS, staff and retained outside counsel filed the Preliminary Issues
Report with the California Energy Commission on August 17, 1990 as required by
the preliminary scheduling order in said proceeding.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Chula
Vista:
1. That the above recitals are true and correct.
2. That the Preliminary Issues Report of the City of Chula Vista
attached as Exhibit "A" is approved and its filing by staff with the
California Energy Commission is ratified and approved.
3. The City Clerk is hereby directed to file a copy of this resolution
with the California Energy Commission.
Resolution No. 15826
Page 2
4. The Offices of the City Attorney and City Manager are directed to
continue to obtain information and data on the issues identified in the
Preliminary Report and any other issues that may become of concern to the City
and return to the City Council for further direction regarding participation
in the Energy Commission proceedings.
Presented by Appr d as to for by
Heorg mp) - / ~
DepU~}~y~ City Manager ' ' '
Resolution No. 15826
Page 3
PASSED, APPROVED, and ADOPTED by the City Council of the City of Chula
Vista, California, this 4th day of September, 1990 by the following vote:
AYES: Councilmembers: Malcolm, McCandliss, Moore, Nader
NOES: Councilmembers: None
ABSENT: Councilmembers: Cox
ABSTAIN: Councilmembers: None
G yle'L. McCandliss
~ayYor Pro Tempore
ATTEST:
STATE OF CALIFORNIA )
COUNTY OF SAN DIEGO ) ss.
CITY OF CHULA VISTA )
I, Beverly A. Authelet, City Clerk of the City of Chula Vista, California, do
hereby certify that the foregoing Resolution No. 15826 was duly passed,
approved, and adopted by the City Council of the City of Chula Vista,
California, at a regular meeting of said City Council held on the 4th day of
September, 1990.
Executed this 4th day of September, 1990.
Be~the~et, City Clerk
Fran M. Layton
Ellen J. Garber
SHUTE, MIHALY & WEINBERGER
396 Hayes Street
San Francisco, California 94102
Telephone: (415) 552-7272
Christopher T. Ellison
GRUENEICH & ELLISON
1121 L Street, Suite 1000
Sacramento, California 95814
Telephone: (916) 449-9971
Bruce M. Boogaard
City Attorney
D. Richard Rudolf
Assistant City Attorney
CITY OF CHULA VISTA
276 Fourth Avenue
Chula Vista, California 92010
Telephone: (619) 691-5037
STATE OF CALIFORNIA
State Energy Resources
ConServation and Development Commission
In the Matter of:
THE NOTICE OF INTENTION OF SAN DIEGO No. 89-NOI-1
G~ & ELECTRIC COMP~uNY TO FILE AN
APPLICATION FOR CERTIFICATION OF A PRELIMIN~RY REPORT OF
COMBINED-CYCLE ELECTRIC GENERATING CITY OF C~U~ V~STA
FACILITY AND RELAT__ED FACILITIES KNOWN
AS THE COMBINED-CYCLE PROJECT ~..
PRELIMINARY REPORT OF
CITY OF CHULA VISTA: (SDG&E] 89-NOI-1
August 17, 1990
Consultants:
Michael Brandman Associates
7676 Hazard Center Drive, Suite 400
San Diego, CA 92108
Attn: Keith Bo Macdonald, Ph.D.
Philip Williams & Associates, Ltd.
Pier 33 North, The Embarcadero
S~Francisco, CA 94111
~ttn: Peter Goodwin, Ph.D. ~'~
TRC Environmental Consultants, Inc.
21907 - 64th Avenue West, Suite 230
Mountain Lake Terrace, WA 9~043
Attn: Kirk D. Winges,
Principal Consulting Scientist
EXECUTIVE SUMMARY AND CONCLUSIONS
PRELIMINARY REPORT
I. Land Use I-1
II. Visual Impacts II-1
III. Biology, Hydrology and Thermal Plume Issues III-1
IV. Air Quality Iv-1
V. Geology and Soils V-1
VI. Hazardous Materials and Fire Safety VI-1
VII. Public Health: Electromagnetic Field Issues VII-1
VIII; Transportation VIII-1
X. Socioeconomic Impacts X-1
XI. Cumulative Impacts XI-1
EXHIBITS
A. San Diego Bay-wide Habitat changes,
1856-1984. III-A
B. South San Die~Bay: Changing Habitat III-B
Acreages, ~856-1984. ~..
C. Results of the San Diego County coastal
wetlands census, 22 April 1989: Shorebirds. III-C
D. Traffic Conditions at Key Intersections. VIII-D
EXECUTIVE SUMMARY AND CONCLUSIONS
This Preliminary Report responds to the request of the
Energy Commission staff for comments from the City of chula Vista
on the proposal of San Diego Gas and Electric Company ("SDG&E")
to construct a new 460 MW combined-cycle power plant at any of
five alternate locations, one of which is the South Bay site in
Chula Vista. This project is one of the largest and most
controversial development proposals in Chula Vista's history.
Indeed, this power plant is one of the largest such facilities
proposed for location anywhere in California in many years. For
that reason, Chula Vista has carefully considered the Energy
Commission's request for comments and the impact that SDG&E's
proposed facility would have on the people and the environment of
the City. For the reasons set forth in this report, Chula Vista
has concluded that the project as proposed would cause numerous
significant adverse environmental impacts. In addition, Chula
Vista has concluded that locating the project at the South Bay
site would violate local ~and use ordinances and policies as well
as other applicable laws. Based on these conclusions, Chula
Vista recommends that the Commission find South Bay an
unacceptable site for this project.
As its name suggests, the South Bay site is located at
the southern end of San Diego Bay. Notwithstanding the
development that has already occurred there, the land and the
environment of the Bayfront is an extremely rare and rapidly
diminishing resource. Even among the scarce resources of the
California coast generally, tidelands and shallow marine
environments such as exist at this site are arguably unique and
the most valuable of all. The Bayfront supports a wide variety
of animals, birds, fish and plants, many of which require the
unique features of this type of habitat to survive.
At the same time, the special features of the Bayfront
also attract people and development. The natural setting creates
a pleasant locale for both residential and visitor-commercial
uses. The proximity to the ocean and a major metropolitan area
attracts industry, especially industry dependent on
transportation.
In balancing these competing inZerests, Chula Vista
seeks to al~,w development of the Bayfront in a fashion that
preserves to the greatest extent possible its natural scenic and
environmental value. In this regard, careful scrutiny of the
individual and cumulative impacts of development proposals is
essential.
1 This report does not consider the details of project design
and construction, such as utilities, building design and tower
placement, since these issues will be addressed by SDG&E at the AFC
stage.
1
This new 460 MW combined-cycle facility, together with
the 140 MW augmentation project and the existing power plant,
will lend a substantially greater industrial character to the
Bayfront area than currently exists. As noted in the Land Use
Chula Vista's plans ~h~1 pm consistent with
y fundamentally,
this project is inconsistent with the City's goal of preserving
and enhancing this unique environment.
A careful evaluation of the potential environmental
impacts of the proposed project reveals significant problems
associated with the South Bay site. The impacts identified in
this report contrast markedly with SDG&E's assessment of the
South Bay site in its Site Screening Analysis, section 5.0 of the
NOI. In that analysis, SDG&E's favorable evaluation of the South
Bay site rested entirely on the capital cost of the facility.
The Site Screening Analysis did not take into account, however,
many of the potentially significant environmental impacts of the
project, including but not limited to the environmental impacts
of the extensive new transmission facilities associated with the
South Bay site, and the cumulative impacts of the combined-cycle
project in conjunction with the augmentation project and other
proposed development. Hence, the .Commission cannot rely on
SDG&E's evaluation of the South Bay site without the additional
information and analysis recommended in this report. Absent such
reevaluation, the significant environmental impacts of the
Summary of Impacts
I. Land use
SDG&E's South Bay site comprises approximately 152
acres of the 790-acre Bayfront Planning Area. The area is
predominately open space, parkland and other environmentally
sensftive uses. The proposed power plant would be inconsistent
with many of the existing and planned land uses in the vicinity
as well as applicable land-use policies of Chula Vista. The
specific zoning document for the South Bay site is the Bayfront
Specific Plan, whic~ is part of and incorporated by reference~.'
into the General Plan. Power plants a~e not an allowable use for
Even the apparent advantages of locating a facility within
the existing infrastructure of another power plant a~e questionable
at South Bay. Most notably, this project would require
approximately 36 miles of new and upgraded transmission lines.
3 As requested by the Energy Commission staff, this
Preliminary Report summarizes the informational requirements of
the City of Chula Vista in order to adequately evaluate the
proposed project. It is expected that set~sfying these'
requirements will take approximately the same amount of time as
preparation of an environmental impact report.
the site pursuant to the zoning in the specific plan. Therefore,
an amendment to the Local Coastal Plan would be required to
locate the proposed project at the South Bay site. In addition,
an amendment to the Dayfront Redevelopment Plan would also be
required.
The City's policy would not favor such amenCments.
Indeed, the City is considering changing the land use designation
of the property from Industrial General to Visitor-Commercial,
establishing a moratorium on all land use approvals on the South
Bay site for one year in order to pursue its planning efforts.
These actions reflect the evolution of the Bayfront into an area
of environmentally sensitive open space, recreational, and
visitor-serving land uses that are not compatible with a major
new power plant.
II. Visual ImPacts
The construction of the proposed combined-cycle
facility will create significant, adverse visual impacts along
the Chula Vista Bayfront, along major federal and state highways,
and in scenic residential areas throughout the city. These
impacts are the result of the project's 175-foot tall emission
stacks, major new transmission lines and towers, and additional
power plant infrastructure. Although these impacts can be
mitigated to some degree, only a major restructuring of the
facility could bring it into conformance with the city's visual
impact LORS, which include a height restriction of 44 feet.
III. Biolo~V, HVdroloqy, and Thermal Plume Issues
The proposed site is adjacent to a critical and
sensitive coastal resource -- the South San Diego Bay and its
surrounding bay waters and wetlands. Ecologically, it is an area
of special value and major regional importance and is also a
significant part of the Pacific flyway. The proposed project
will result in significant increases in both water intake from
the Bay and thermal p~Ume discharges into the Bay from the power
plant. The temperature, size, and duration of the thermal plume
will all increas~ As such, there is considerable risk of'.'
significant adverse impacts on the biological and water resources
of the Bay.
The thermal plume poses one of the most significant
potential adverse impacts of the proposed plant on South San
Diego Bay due to impacts on the biological resources of the bay.
Potential adverse impacts include direct mortality of organisms
due to impingement on the water intake screens and entrainment
through the power plant and resulting thermal shock, as well as
less direct but still lethal impacts to breeding, food sources,
and habitats as the thermal plume exits the plant and spreads
across the bay.
3
In addition, there.is the potential for transfer of
pollutants from the power plant site into south San Diego Bay
both during normal construction and operation and from accidents
and flooding by means of surface runoff, release of subsurface
contaminants, releases of airborne pollutants, and t].ansfer
through the power plant cooling water stream. Insufficient
information has been provided to conclude that the risk of
pollution to the Bay from these sources is insignificant.
Persistent violations of ambient air quality standards
in the San Diego region have resulted in its classification as
nonattainment for several pollutants including nitrogen oxides
(NOx), ozone, carbon monoxide (CO), and particulates. The
proposed 460 MW combined-cycle facility will emit significant
amounts of nitrogen oxide, carbon monoxide and other pollutants
even when fired with natural gas. When fired with fuel oil, the
project will result in even more significant emissions of air
pollutants. Moreover, any unmitigated emissions of contaminants
from the facility will likely result in greater exposures at
South Bay than at any other site due to prevailing winds and the
surrounding population.
It is likely that the SDAPCD will find that low-NOx
burners are Reasonably Available Control Technology (RACT) and
therefore ineligible as an NOx offset for either the combined-
cycle or the augmentation project. If so, SDG&E'S proposal does
not appear to have sufficient NOx offsets to meet applicable air
quality standards at South Bay.
In addition, SDG&E has failed to identify any offsets
for CO or nonmethane hydrocarbons (a precursor to ozone) based on
claims these offsets are not required. Whether failure to
mitigate these emissions is consistent with SDAPCD rules, as well
as Energy Commission zero net emissions policies, is unclear.
From Chula Vista's perspective, any substantial unmitigated
emissions of nonattainment contaminants within the City is a
significant and adver. se impact.
Chula V~sta also has significant concerns regard~ the
use of oil as an alternate fuel for the facility. Any prolonged
use of oil will result in increased emissions of sulfur dioxide,
metals and other toxic species. Indeed, SDG&E'S modeling
suggests that prolonged use of oil will result in concentrations
of cadmium significantly above the limit suggested by the
Environmental Protection Agency's Carcinogen Assessment Group.
V. ~¢o~Qgy and Soils
The proposed site is characterized by the potential for
severe erosion hazards due to the alluvial soils on site. The
site is also next to numerous active and potentially active fault
zones. For example, the Rose Canyon fault, is located only 2.5
miles away and has been the cause of repeated moderate magnitude
4
earthquakes. According to SDG&E, the South Bay site is in "close
proximity" to UBC Seismic Risk Zone 4, the zone of greatest
seismic risk identified in the UBC. The combined seismicity of
the site and the occurrence of unstable soils means that the
potential for soil liquefaction at the site is significant.
There are also significant concerns regarding possible erosion of
the banks on which the transmission towers may be located.
VI. Hazardous Materials and Fire Safety
Hazardous materials, including flammable and explosive
materials, would be stored and used on the South Bay site.
Leakage or spillage from above ground tanks or storage containers
could result in contamination of soil, the bay and wetlands, not
only through surface runoff but also through migration of
contaminated groundwater. The site lacks adequate early warning
systems for leaks and airborne releases, even though an airborne
release could adversely affect populated areas of the City,
requiring evacuation of residences and businesses. The
transportation corridors to the South Bay site are highly
populated; there is a significant risk of harm to surrounding
populations in the event of a release of hazardous materials
being transported.
In the event of a hazardous materials release at the
site or during transportation, considerable damage and injury to
the natural resources and population of the City could occur.
The proposed containment methods do not adequately provide for
containment of hazardous materials. Containment areas are
undersized and are not designed for gases and other volatile
materials. Despite these problems, no proposed mitigation
measures are listed or described in the NOI. The site currently
has fire safety deficiencies, yet nothing has been submitted to
show that they will be corrected.
VII. Pub~i~ Health: Electromaqnetic Field Issues
SDG&E's South Bay proposal would require construction
of 20 miles of new 230 kV transmission lines plus reconductor of
16 miles of existing'lines in heavily populated areas of Chula
Vista and surrouBding jurisdictions. These additional li~s will
expose adjacent populations to electric magnetic fields (EMF)
which have been linked to cancer in laboratory tests and
epidemiological studies. While a precise cause and effect
relationship between EMF and cancer has not yet been established,
there is a growing consensus that the public health risk from
high voltage transmission facilities may be significant.
Demographic data for Chula Vista shows that approximately 7,000
residents may be exposed to high EMF levels in their homes and at
least 2,500 children would face similar risks at school, In
addition, several parks, day-care centers, libraries and
recreation facilities exist in close proximity to the proposed
transmission corridor. These exposures within Chula Vista alone
are compounded by similar uses in surrounding jurisdictions.
5
7 ZO
As public concern about EMF health risks grows, SDG&E
can expect increased opposition, and a threat of litigation from
those exposed to EMF from its facilities. Given the uncertainty
regarding the causes of EMF impacts, the only established method
of reducing both health risks and the threat of litigation is to
minimize the number of people that are exposed. Accordingly, the
only feasible mitigation for EMF impacts is the selection of a
site which involves no new transmission facilities in populated
areas.
VIII. Transportatio~
Heavy traffic will be generated during construction of
the facility. Indeed, over 240 construction workers will be
employed at the site during the peak of the two-year construction
period. Even after construction ends, 41 additional employees
will be added, thus permanently increasing traffic level impacts.
While SDG&E'S traffic analysis is inadequate, it does reveal that
it is unlikely that the project will comply with the City's
transportation LORS (specifically the General Plan and the
Threshold Policy) during the construction of the plant. Because
of cumulative impacts to already congested intersections,
interchanges, and delivery routes, it is also likely that the
long-term transportation impacts of the additional employees and
delivery vehicles will be significant.
IX. Noise
Absent additional mitigation, this project will have
significant noise impacts on sensitive receptors already subject
to high ambient noise levels from the existing South Bay power
plant and I-5 traffic.
X. ~ocioeconomic Impacts
Use of the South Bay site will adversely affect the
socioeconomic environment of Chula Vista by displacing preferred
commercial/retail land uses at the site, and perhaps in
surrounding areas~ well where such land uses will be
to the City fr m use of the site for a puwer plant ($13,~4
annually iD property taxes to the City) would be significantly
lower as compared to other uses of the site such as a business
park ($180,080 in annual property taxes) or as a hotel and
conference center ($3,000,000 in various 'ax revenues). There
would be a corresponding loss in employment opportunities as
well. It is unlikely that mitigation measures can be devised
that would adequately compensate for these socioeconomic impacts.
XI. Cumulative Impacts
SDG&E has not provided any analysis of cumulative
impacts in the NOI filing and has refused to respond to data
requests seeking information On cumulative impacts. This
information is critical to the Commission's compliance with the
6
-2/
California Environmental Quality Act as well as its
responsibility to evaluate alternative sites under the Warren~
Alquist Act. In this case, the evaluation of cumulative impacts
may be a significant difference among the five NOI sites. At the
South Bay site, there are numerous other development projects
proposed for the area, including SDG&E's proposed augmentation
project. Taken together, the cumulative impacts of these
proposals in many technical areas are significant and adverse.
~' I. I~AND USE
A. Summarv/Overview
The site of the proposed combined-cycle power plant is
· ~ within the Chula Vista Bayfront Planning Area--an area of
environmentally sensitive and valuable coastal resources.
Development of an additional power plant in this area would be
inconsistent with these open space resources as well as with many
of the land uses surrounding the South Bay site and transmission
corridors. The new plant and transmission facilities would be
incompatible with the parks, schools, and residential
neighborhoods affected by their construction and operation.
include the General Plan, Redevelopment Plan, and Local Coastal
Program (including the Land Use Plan and Specific Plan). A new
power plant is inconsistent with the Specific Plan, General Plan,
and Redevelopment Plan, and would require Local Coastal Plan and
!~ I Redevelopmerit Plan amendments. More importantly, the project is
inconsistent with the City's bayfront land use policies and with
bayfront development trends favoring visitor-commercial uses and
~'!lI disfavoring additional industrialization of the coastline.
B. Analysis
1. Environmental Setting
The South Bay site is located along South San Diego Bay
in the City of Chula Vista. Chula Vista has a population of
approximately 132,000, and is located in the southern portion of
San Diego County, south of the City of San Diego.
The SDG&E property comprises approximately 152 acres of
the 790-acre Bayfront Planning Area. The predominant land uses
in the bayfront are open space, parkland, and other
environmentally sensitive uses. These include the J Street/Chula
Vista Marina, Bayside Beach, Marina View Park, Chula Vista Nature
Interpretive Centar, Sweetwater Marsh National Wildlife Refuge,
salt evaporation ponds,-~nd wetlands. The primary industrial
uses are SDG&E and ~ohr Industries. ~..
· ~' Much of the Bayfront Planning Area, including the
portion of the South Bay site north of L Street, is within the
Bayfront Redevelopment area. The Midbayfront project, a major
redevelopment project, is in the planning stages for the area
north of G Street. The proposed 135-acre project consists of
parks and man-made lagoons, hotels, high-rise apartments, one and
two-story apartments and bungalow type hotel units, retail shops,
restaurants, offices, a cogeneration facility, and a conference
center, as well as athletic facilities including a tennis
complex, swimming facility and an ice rink. In addition to the
lagoons, 32.5 acres are planned for parks and recreation, and
18.75 acres are planned for public and quasi-public uses such as
a sports complex and marsh.
I-1
~i.~ ..... ~:.
The existing use of the project site is the South Bay
Power Plant and approximately 40 acres of vacant land. The
Telegraph Canyon Creek flood control channel bisects the site.
Portions of the site are vacant, and other portions consist of
tidelands, shallow bay water, and salt ponds.
2. Potentially Significant Adve=se Impacts
An analysis of land use impacts typically considers
three different factors: 1) the compatibility of the proposed
project with the surrounding land uses; 2) the compatibility oZ
the proJect's internal uses with each other; and 3) consistency
of the site's land use designations with adopted plans and
policies. The proposed project is analyzed below according to
these three factors.
a. Compatibility With Surrounding Area
Land Uses
The proposed project consists of construction and
operation of a 460 megawatt combined-cycle electric generating
station. Two electric generating units are planned. Each unit
is expected to consist of two combustion turbine generators, two
heat recovery steam generators, one steam turbine generator, and
associated auxiliaries. NOI § 2.1.
If constructed at the South Bay site, the proposed
project will require extensive new transmission facilities -- the
most new transmission facilities for any of the five sites
examined in the NOI. The proposed transmission facilities
include a new 10-mile twin circuit 230 kV tower line from the
South Bay site to the Miguel Substation to be located in an
existing right~of-way; reconductor of an existing 16-mile 138 kV
transmission line between Miguel Substation and Los Coches
Substation; and reconductor of an existing 10-mile 230 kV
transmission line and installation of a new 10-mile 230 kV
transmission line on existing structures between the Mission and
Sycamore Canyon Substations. NOI § 9.4.1.1.1.
While the proposed combined-cycle power plant, an
industrial land ~se, would be generally consistent with t~'light
industrial u~es immediately adjoining the site to the south and
east, it would be inconsistent with uses adjoining the site to
the north and west. Immediately to the north of the site is the
J Street Marsh, an open space preserve area. Beyond the marsh is
Marina View community park, which is immediately adjacent to the
J Street Marina complex. Both are important points of public
access to the coastal area and water oriented recreation.
Addition of a second power plant at the South Bay site would
result in visual and noise impacts that would be incompatible
with current uses of these open space/park areas.
Wetlands, mudflats, salt ponds, and San Diego Bay are
located immediately to the west of the proposed project site.
I-2
Additional power plant facilities would adversely impact scenic
views from the bay toward southern Chula Vista, and noise from
the proposed uses would also adversely impact passive
recreational opportunities adjacent to the site in South San
Diego Bay.
Additional adverse impacts due to the incompatibility
of the power plant with residential areas and businesses include
impacts to traffic, noise, air quality, views/visual quality,
potential exposure to hazardous materials, and construction-
related impacts. Existing residential neighborhoods are located
approximately 800 feet east of the South Bay site just north of
L Street and east of I-5, as well as northeast of Naples Street
and Industrial Boulevard. Other residential areas are adjacent
to and in close proximity to the southern end of the South Bay
site along Palomar Street. The proposed addition of a second
power plant will be incompatible with these residential areas as
well for the reasons stated above. In addition, the tall stacks
proposed as part of the project would adversely impact views from
residential areas, which would have a negative impact on
neighborhood character. An outdoor recreation facility is
located south of L Street and east of Interstate 5, approximately
400 feet from the project site. Any air quality impacts from the
plant expansion would adversely affect users of this facility.
Increased traffic to and from the South Bay Power Plant
site has the potential to result in adverse noise and air quality
impacts to residents.and businesses both east and west of
Interstate 5. As described in more detail in Section VI,
Hazardous Materials and Fire Safety, hazardous materials
transportation routes to the South Bay site run alongside
residential areas, some as close as 100-200 feet from key
intersections. Some of the residential areas potentially subject
to the risk of an accidental spill of hazardous materials include
neighborhoods east of the Interstate 5/J Street interchange,
along the east side of Industrial Boulevard between J Street and
Palomar Street, and along Palomar Street between Industrial
Boulevard and Bay Boulevard. Harborside Elementary School is
located on Industrial Boulevard in this area, and Mueller
Elementary School is ~'6Cated on I Street at I-5. A spill of
hazardous materia]~ along these corridors would adversely a~ect
many residents and at least two schools, and could require
evacuation of these areas.
As for all residential and other uses in proximity to
the power plant site, potential air quality and visual impacts,
the possibility of exposure to hazardous materials, and increased
traffic and noise, render the proposed new power plant
incompatible with the land uses in this area.
The new 10-mile twin circuit 230 kV tower line from
South Bay to the Miguel substation, although proposed to be
located within an existing right-of-way, also poses land use
compatibility problems. The existing right-of-way runs through
densely populated portions of southern and eastern ChUla Vista.
I-3
7-25
The potential public health impacts of extensive exposure of a
large number of persons to electromagnetic fields, discussed more
fully in section VII, Public Health: Electromagnetic Field
Issues, raises land use compatibility concerns.
Industrial, commercial, parks, schools, and r~sidential
uses are located immediately adjacent to the transmission line
corridor. Three existing elementary schools (Greg Rogers,
Palomar, and Loma Verde), planned elementary schools (in
E1 Rancho del Rey and Rancho San Miguel), one junior high school
(Bonita Vista), and two high schools (Bonita Vista and Castle
Park) are located either immediately adjacent to, or within 700
feet of the transmission line right-of-way. The proximity of so
many sensitive land uses to the proposed expanded and upgraded
transmission facilities increases the potential for adverse
public health impacts. In addition, the new tower structures
that will be constructed would be visually incompatible with
surrounding areas and may lower adjacent property values.
Several city parks use the transmission line right-of
way for recreational purposes. These parks include Palomar, Greg
Rogers, Loma Verde, Rancho Del Sur, Sunridge, Discovery, and
Rancho del Rey. Installation of additional transmission
facilities would reduce the usable recreation area in these
parks, detract aesthetically, and create greater public exposure
to electromagnetic fields.
Further, the proposed project may create numerous
significant adverse construction-related impacts. Construction-
related impacts may include increased traffic congestion, noise
that may disturb nearby residents, dust and other air quality
problems, siltation in adjacent wetlands and adverse visual
impacts. SDG&E states that the entire construction workforce
will park on the South Bay site or in the transmission corridor.
NOI § 9.3.5.4.2. However, section 9.3.5.5 of the NOI proposes
mitigation measures in the event that onsite parking is
inadequate. If construction workers or construction equipment
park along Bay Boulevard, there may be a shortage of parking for
pubic access to the coastline.
~ b. Compatibility Among Internal Lar~.
Uses
The existing land uses on the South Bay site include
the South Bay power plant facilities, the T~legraph Canyon Creek
flood control channel, open space, hazardous materials storage
tanks, hazardous materials storage ponds, and salt ponds. New
power plant facilities would be compatible with the existing
power plant facilities, open space, and hazardous materials
handling facilities. Assuming the proposed expansion does not
extend into the salt pond area on the western portion of the
project site, no incompatibility among internal land uses would
be expected.
Even though the proposed transmission facilities would
I-4
be located within existing rights-of-way, the land uses in the
corridor--parks and transmission line towers--could be internally
inconsistent.
c. Consistency With Land Use Plans
(1) Local Coastal Program
The South Bay site is located in the coastal zone;
therefore, a Coastal Development Permit would be required for the
proposed project. The City's primary standard for review of a
Coastal Development Permit application is consistency with the
Local Coastal Program ("LCP"). The LCP takes precedence over the
City's general plan and zoning in the coastal area. The LCP
includes the following two documents: the Land Use Plan ("LUP"),
and the Chula Vista Bayfront Specific Plan. Together, these two
documents provide generalized land use classifications as well as
specific zoning regulations for the site.
The site of the proposed combined-cycle project is
designated General Industrial and zoned Industrial General in the
LCP. Basic Land Use Objective number 3 in Chapter III of the LUP
states:
General Industrial. General industrial uses
should be specifically excluded from the
Midbayfront area but permitted in the
existing industrial areas adjacent to Rohr
corporation, the SDG&E facilities, and the
inland parcel. The reasons for this
objective include the following:
Water Related Lands. The water-related lands
of the Chula Vista Bayfront are a unique
resource and should be reserved for public
and private uses which can benefit from, as
well as protect the location.
General Industrial Use. There are no
overriding functional reasons for using
Bayfro~t land for general industrial use; the ~.'
industrial growth of San Diego County is not
1 The South Bay site is shown as "Open Space, Research and
Limited Industrial, and General Industrial" on the Land Use Diagram
of the Chula Vista General Plan. The precise location of the
existing power plant and its immediate vicinity are shown as
"General Industrial". However, the General Plan text specifically
incorporates the Bayfront Specific Plan by reference, overriding
the apparent effect of the Land Use Diagram by its specific
language. Thus, although the General Plan is not the controlling
document in coastal areas, in fact, both documents are consistent
and the proposed second power plant is inconsistent with both of
them.
likely to be impeded if the Bayfront lands
are not developed for this use.
Non-Water Related Use. The inclusion of more
non-water related uses in the area would
irreversibly commit the shoreline from
National City south through the planning area
as an area that could be marketed only for
industrial purposes.
Economic Base. The overall economic welfare of
Chula Vista would be better served by uses of this
land which broaden the economic base of the
community.
The Land Use Map in the LUP depicts recommended
locations for pcrmitted land uses. Permitted industrial uses are
described as follows:
du/al~ltlt~. The industrial land uses are
confined to an area generally south of
G Street, plus the inland parcel east of I-5.
Existing uses will be permitted to continue
and expand.
Thus, the project could be viewed as technically compatible with
the land use category General Industrial in the LUP, although LUP
policies regarding industrial development in the bayfront area
clearly favor other, coastal-related land uses.
Zoning is typically a further refinement of broad-brush
land use designations, and may exclude, at the site-specific
level, particular uses encompassed by the broader land use
classifications. In this case, power plants are not an allowable
use in the industrial General zone as set forth in the Specific
Plan. Therefore, the proposed project is inconsistent with the
Specific Plan (zoning), and would require an LCP amendment.2
SDG&E has noted the need for an LCP amendment in Table 11-4 of
the NOI, pages 11-133.
In r~viewing and formulating a recommendation~bh an
application for an LCP amendment, City staff would focus on the
Coastal Resources Planning and Management Policies identified in
Chapter 3 of the California Coastal Act. Impacts on public
access, recreation, the marine environment, and land resources
would be included in the staff analysis. The following potential
impact areas would require further technical studies before a
staff analysis could be prepared:
a As outlined in the Local Coastal Program Post-Certification
Guide for Coastal Cities and Counties issued by the California
Coastal Commission in March 1987, Chapter VI, LCP amendments are
required for Specific Plan amendments.
I-6
J (a) The use and transportation of hazardous materials could
result in significant adverse impacts on the marine
environment and on residential neighborhoods.
Effective containment and cleanup facilities and
procedures would be required of SDG&E as part of its
application.
(b) Wildlife and fisheries resources could be significantly
impacted by the proposed project, as described in more
detail in Section ~II, Biology, Hydrology and Thermal
Plume Issues, and other sections of this report.
Technical studies need to be undertaken to detail the
potential impacts of the project on state and federally
listed endangered species and other marine and
terrestrial species.
J (c) The visual impacts of the proposed project from the
adjacent Marina View Park must be studied, as well as
the adverse visual impacts to views from Bay Boulevard
at L Street and other areas listed in Section II of
this report on Visual Impacts.
i (d) The floodplain of Telegraph Canyon Creek must be
studied to determine any potential impacts on the
proposed project site. The FEMA flood insurance rate
maps may need to be revised to reflect the current
floodplain, which was recently modified by a flood
control project.
(e) More technical information on the geologic stability of
the site is needed to assess potential seismic impacts.
(f) Air quality and noise studies need to be completed so
that the technical data can be evaluated and included
in the staff analysis.
(g) Traffic circulation is a concern, particularly if it
would impede coastal access for recreational users. A
traffic st_~udy should be conducted so that an analysis
of coastal access impacts can be prepared.
(h) The location of additional transmission lines and
towers in the coastal zone raises concerns ranging from
the potential for increased sedimentation in wetlands
due to soil disturbance to aesthetic issues. More
information on the location and construction techniques
proposed for these facilities is necessary to prepare
an analysis. In addition, the specific types of towers
proposed should be identified because the visual
impacts could vary greatly depending on the type of
B tower proposedr
%~] (2) Bayfront Redevelopment Plan
' The Bayfront Redevelopment Plan applies to the portion
I-7
of the SDG&E property north of L Street. Basic Objective number
4 in the Redevelopmerit Plan states:
Primary uses to be considered for the
Bayfront area should be limited to public
recreation, commercial activities such as
hotels, motels and restaurants, and
compatible water-related industrial
substantial public benefit. The question of
water-related industrial uses in this area
between Rohr and the San Diego Gas & Electric
power plant should be further studied.
Prior to approval of a second power plant, the question
of its public benefits would need to be studied by the
Redevelopmerit Agency and an assessment made regarding whether
further expansion is appropriate in light of the City's goals for
redevelopment of the bayfront. An amendment of the redevelopment
plan would be required.
Because the proposed power plant expansion is not
permitted under the existing LCP, there is a significant
inconsistency between the proposed project and the adopted plan.
(3) Planning for the Future of the
Day~ron~
On November 14, 1989, the City Council of the city of
Chula Vista adopted an interim ordinance (Ordinance No. 2324)
establishing a moratorium on all land use approvals on the South
Bay site for one year. As discussed above, the proposed power
plant site is not consistent with the General Plan or Specific
Plan. The purpose of this moratorium is to allow the City time
to consider a change in the land use designation of the SDG&E
property from Industrial General to Visitor-Commercial. This
change in land use__designation is consistent with the City's
policies and objectives concerning development and redevelopment
of the bayfrorE in a manner conducive to public use and~.-
enhancement of the South San Diego Bay coastal area. An
environmental impact report is being prepared to analyze the
potential environmental impacts of the proposed change in land
use designation.
The proposed power plant expansion would require land
use approvals on the South Bay site. Thus, the proposed power
plant expansion is inconsistent with the moratorium.
3. SDG&E's Proposed Mitigation
In order to mitigate the proJect's inconsistency with
the LCP, SDG&E proposes the following in section 9.3.5.5 of the
NOI:
I-8
that are unlikely to be mitigated include public health impacts
of increased human exposure to transmission facilities, impacts
of hazardous materials releases, and increased traffic congestion
and noise during construction. These impacts are described more
fully in other sections of this report.
6. Likelihood of Compliance with Law~,
Ordinances. Requlations or Standards
Power plants are not an allowable use in the Industrial
General zone under the Bayfront Specific Plan. An LCP amendment
would, therefore, be required to bring the proposed project
compliance with the City's certified LCP. Even though an LCP
amendment is possible, the project is not compatible with the
City's long term goals for development and redevelopment of the
bayfront. Fo~ instance, in order to comply with Objective 4 of
the Bayfront Redevelopment Plan, the question of the public
benefits of the South Bay Power Plant expansion must be studied
by the Redevelopment Agency and an assessment must be made
regarding whether future expansion of that use is appropriate.
Further, the proposed project is not in compliance with
the Land Use Approvals Moratorium~ That moratorium was
established to allow the City time to consider a change in the
land use designation of the SDG&E property from General
Industrial to Visitor Commercial, which would be consistent with
the City's future vision for the bayfront area.
In summary, the proposed combined-cycle power plant
project is not compatible with land use LORS. The bayfront is
evolving into an area Of environmentally sensitive open space,
recreational, and visitor-serving land uses. An industrial use
such as a power plant is not compatible with any of these uses.
In light of this land use trend, the City currently is
reexamining all applicable planning documents in order to revise
them. accordingly.
1-10
'7 -3 t
I
i
Were it not for the CEC's jurisdiction
i regarding siting of power plants, SDG&E would
seek to amend the City of Chula Vista's Local
Coastal Program (Phasa III) Specific Plan
i regarding power plant use of the South Bay
Site. Further, should the site be
redesignated to Visitor Serving-Commercial,
SDG&E would consider submitting an amendment
I application that would allow their proposed
project, notwithstanding the CEC authority.
I SDG&E also proposes the following measures to alleviate
the construction-related of the proposed project:
I a. Limiting construction activities to the minimum
amount of area needed on the site.
I b. Practicing fugitive dust control.
c. Using noise-control devices on machinery.
I d. Limiting hours of construction to minimize impacts
on nearby residences~
I e. Providing for site cleanup and possible screening,
as needed and feasible, between the project and sensitive
neighboring uses.
I f. Supplying offsite parking away from parking areas
currently used for access to the coastal area and a shuttle bus
system for construction workers if sufficient parking were not
I available onsite.
4. Additional or Alternative Mitigation
I The following sections of this report discuss specific
mitigation measures~for the various significant adverse
I environmental impacts of the proposed project, such as noise, air
quality, visualSimpacts, traffic and transportation, pubTfc
health, and exposure to releases of hazardous materials.
I 5. Potentially Significant Adverse Impacts
That Are Not Likely To Be Mitigated
i The basic incompatibility of the proposed project with
emerging bayfront land use policies and trends cannot be
mitigated. Other project impacts on surrounding land uses that
I are not likely to be mitigated include the visual impacts of the
new facilities, in particular the two new 175-foot stacks.
Regardless of paint color, the stacks will be visible from many
i portions of the bayfront and nearby residential areas, which will
contribute further to the undesirable industrialized character of
the coastal area. Still other significant impacts of the project
II. VISUAL IMPACTS
A. ~
The construction of the proposed combined-cycle power
plant project, especially when viewed in combination with the
proposed augmentation project, will create significant, adverse
visual impacts along the Chula Vista bayfront, along major
federal and state highways, and in scenic residential areas
throughout the city. The construction of this project, which
will include additional operations buildings, power plant
infrastructure, two 175-foot high emission stacks, and
transmission lines and towers, is in direct conflict with
existing City policies guiding the development of the bayfront,
including the Local Coastal Program ("LCP") and Bayfront Specific
Plan, and the Chula Vista General Plan. The 175-foot high
emission stacks are 131 feet above the height limit set forth in
the LCP, and will require an LCP amendment.
The adverse visual impacts of the project are
particularly significant in light of the City's plan to redevelop
the bayfront for visitor-commercial uses. Visual access to the
bayfront's wetland areas and scenic coast must not be impaired if
such redevelcpment efforts are to be successful. SDG&E should
prepare a visual impact study, including the use of visual
simulation techniques, to properly analyze the degree of change
the project would create in the natural environment, as well as
to assess the significance of adverse visual impacts.
Mitigation of significant adverse visual impacts should
be required prior to the issuance of grading, building, or
coastal development permits. Even with such mitigation measures,
however, this project will have serious social and economic
repercussions for the City of Chula Vista.
B. Analysis
As the NOI acknowledges, visual sensitivity is high at
the South Bay sita. NOI § 9.3.7.1. The site is located alo'~g
the Chula Vista bayfront, an integral part of the San Diego Bay
shoreline. The bayfront is highly visible to southbound
travelers on Interstate 5, and will have a similar high
visibility from State Route 54, planned for completion in the
early 1990's. The site's location adjacent to the principal
federal and state highway systems connecting the City of San
Diego with Mexico make the Chula Vista bayfront a visual resource
of statewide importance.
The visual characteristics of the South Bay site and
vicinity include views along the bayfront of open space, natural
salt marshlands, landscaped public parks, a boating marina, and
scattered industrial uses. The City is currently in the process
II-1
of changing the industrial image of the bayfront to facilitate
recreational use and create an open space image that will attract
commercial development and tourism. For example, the City has
designated Bay Boulevard as a bikeway, and is developing plans
for a major bayfront commercial development. See Chula Vista
Local Coastal Program, Areawide Plan Provisions (as amended April
1989).
Thus, the City's bayfront represents a unique scenic
resource critical to the success of current redevelopment
efforts. Reducing industrial uses along the bayfront is also
necessary if the City is to succeed in promoting its image as a
bay community and thereby attract tourists.
The site is highly visible from local roadways,
especially at the intersection of L Street and Bay Boulevard, and
along Marina Parkway, a designated scenic highway within the
City. Marina Parkway is the principal roadway providing access
along the bayfront and, as such, establishes the initial
aesthetic impression of the Bayfront Redevelopment Area, an area
which has been targeted for visitor-commercial land uses. Such
uses are highly dependent on the visual setting. A power plant
with 175-foot emission stacks will be prominently visible
throughout much of this area.
Transmission lines and towers extending from the South
Bay site along the South Bay to Miguel Corridor will create
additional visual impacts, not only in the bayfront area but also
throughout the City of Chula Vista along an approximately ten-
mile stretch of the linear corridor. In addition to bisecting
heavily populated residential areas of the City, the transmission
corridor also causes visual impacts along highly scenic roadways
of the City, especially Telegraph Canyon Road, East "H" Street,
and Otay Lakes Road.
2. Potentially Siqnificant Adverse Impacts
SDG&E's proposal for two 175-foot emissions stacks, two
combustion turbine generators, two heat recovery steam
generators, one steam tuz~ine generator and associated
auxiliaries in the h' hly sensitive bayfront environment would~
create significant adverse visual impacts. The bayfront is an"
area of high scenic value which includes natural water features,
a marina, recreational areas, and landscaped public parks such as
Marina View Park. Scenic areas immediately adjacent to the site
include Marina View Park and Bayside Park, the J Street Marina,
are being developed. The City has requested that SDG&E provide
an expanded analysis of visual impacts from these and other key
observation points. Data Request No. 25, City of Chula Vista Set
One. No response has been received to date.
Moreover, the Bayfront Specific Plan places a height
restriction of 44 feet in this area, 131 feet lower than the
emissions stacks proposed for this projects. See the Chula Vista
iI-2
Local Coastal Program Land Use Plan, Section 19.85.01. Thus, the
project design is incompatible with the LCP, and would therefore
require SDG&E to seek an LCP amendment.
Significant adverse visual impacts will also occur in
conjunction with the addition of transmission lines and towers
along the South Bay to Miguel Transmission Corridor, which
bisects heavily populated and scenic areas of Chula Vista.
Additional infrastructure for the linear facilities constructed
throughout the City will be observable from key observation
points, thereby creating significant adverse visual impacts to
existing views.. The City has already requested SDG&E to providv
maps and other data and illustrations which depict both the
visual impacts from key observation points. Data Requests
Nos. 24-25, City of Chula Vista Set One. No response has been
received from SDG&E to date.
Significant cumulative visual impacts will also be
created by the buildings, stacks, and other power plant
structures required for the augmentation project proposed for the
South Bay site. Cumulative impacts from the combination of the
significant.
3. SDG&E's Proposed Mitication
The two design changes mentioned as potential
mitigation measures in the NOI are "using existing structures and
lowering the stack height." NOI § 9.3.7.3. SDG&E has rejected
these mitigation measures, citing the capacity limitations of
existing stacks and the air pollution control advantages of
higher stacks. There is no discussion of alternative air
pollution control or operational technologies which might permit
the lowering of stack heights without compromising air quality
standards.
The only mitigation measure actually proposed by SDG&E
blend in with the exil'ting generating station. This does not
constitute adequate mitigation of the impacts created by
construction of two 175-foot high stacks, which will create
significant ~dverse visual impacts due to their visibility from
sensitive observation points in an important redevelopment area
and along heavily traveled state and federal highways. SDG&E's
proposed mitigation measure is equally inadequate to mitigate the
cumulative visual impacts from the combined-cycle project in
combination with the augmentation project.
4. Additional or Alternative Mitication.
The City of Chula Vista recommends adoption of the
i'~;~:' following measures necessary to mitigate visual impacts of the
:~ proposed proJ oct.
=~ II-3
(1) SDG&E should undertake a visual impact study based on
the principles of visual contrast established by the BLM in the
Visual Resource Management System, including the use of visual
simulation techniques to assess the degree of change in line,
form, color, and/or texture that would be created by the proposed
project from sensitive observation points. This is necessary to
determine the degree of change in the visual environment created
by the proposed power plant infrastructure, operations buildings,
transmission lines and towers, as well as to assess the
significance of the views impeded along critical visual
corridors.
(2) An extensive landscaping program designed to screen
views of the proposed facility from the north, east, and west
should be implemented to reduce the potential visual impacts of
the proposed project. To ensure that SDG&E's landscaping plan is
sufficient to mitigate adverse visual impacts, SDG&E should meet
with the City Landscape Architect to review the landscape plan
prior to the issuance of grading, building, or coastal
development permits for the project. At a minimum, SDG&E should
be required to comply with the already approved South Bay Power
Plant Landscape Master Plan.
(3) The plant should be built using materials and colors
which are harmonious with the environment. Reflective glass and
reflective roof materials should not be used. The proposed
facilities should be painted a color that minimizes visual
impacts. The specific color should be submitted for approval to
the City of Chula Vista Planning Department.
(4) Building heights should be reduced and the plant
redesigned in order to comply with physical form and appearance
policies contained in Chula Vista's Local Coastal Program
(§ 19.89).
(5) Transmission towers specially designed to minimize
adverse visual impacts should be used. Prior to installation,
the proposed tower design should be approved by the City of Chula
Vista Planning Department.
5. Potentially Significant Adverse Impacts
~that Are Not Likely to__b~ M~tiqate~
Significant unmitigable visual impacts will be created
by the proposed facilities, in particular the two 175-foot high
stacks and auxiliary electrical generating facilities. The
visual character of the City of Chula Vistd will be permanently
altered due to the proposed proJect's high visibility location
along the bayfront. The City's plan to change the industrial
image of this area in order to encourage both public recreation
and visitor-commercial uses will be severely impeded by this
project. These adverse effects on the City's redevelopment
efforts constitute significant unmitigable impacts with
socioeconomic as well as visual ramifications.
II-4
6. Feasibility of Compliance with Laws,
Ordinances, Regulations, and Standards
~LORS)
The City's LORS governing visual impacts include the
following: (1) Chula Vista Local coastal Program, Phys~.cal Form
& Appearance Policies (as amended April 1989); (2) Chula Vista
Local Coastal Program, Coastal Visual Resources and Special
Communities Policies, Land Use Plan (as amended April 1989);
(3) Chula Vista Local Coastal Program, Development Policies,
Section 19.85.01 (Building Height Restrictions), Bayfront
Specific Plan at 24 (as amended April 1989); (4) Chula Vista
Local Coastal Program, Physical Form and Appearance Policies,
Section 19.89, Bayfront Specific Plan at 64-68 (as amended April
1989); (5) Chula Vista General Plan, Land Use Element, Designated
Scenic Roadways Policies, Section 8.1 at 1-57-64; and (6) Fine
Arts Program requirements, which are administered through the
Community Development Department, requiring all new industrial
and commercial developments to finance displays of public art.
In order to comply with LORS, the following approvals
will be required:
(1) A Coastal Development Permit must be obtained because
the project is in the coastal zone and therefore subject to the
requirements of the California Coastal Act. As part of the
Coastal Development process, visual impacts are analyzed to
ascertain compliance with LCP policies and objectives.
(2) An amendment to the LCP to allow the construction of
stacks with a proposed height of 131 feet over the maximum
allowable height limit of 44 feet. This amendment application
might also include a variance request, which would require the
approval of the Chula Vista Planning Commission.
.(3) A design review application to assess the aesthetic and
design aspects of the proposed project to ensure compliance with
the City's design review policies.
(4) Compliance with the City's Fine Arts Program, which
will require SDG&E t~ pay 1% of the bu.ilding's valuation in tTT~
form of a fee, or to finance public display of a work of art.
III. DIOLOGY. HYDROLOGY AND THERMAL PLUME ISSUES
A. INTRODUCTION
This section of the City's preliminary report examines
five fundamental concerns in the general areas of biology and
hydrology. These five concerns, each leading to potentially
serious adverse impacts to south San Diego Bay, are as follows:
Bathymetry and Sedimentation Processes in
South San Dieqo DaY:
Data describing the bathymetry and sedimentation
processes of south San Diego Bay are outdated and
inadequate. The bay appears to be slowly filling in
(shallowing). This is reducing the water volume in the
South Bay and, therefore, has significant implications
for potential adverse impacts of the power plant's
thermal plume.
Chemical/Toxic PollutiOn of South sad Dieqo Bay:
There is a significant potential for chemical or toxic
pollution of south San Diego Bay from power plant
operations. Several distinct potential pollution
transfer pathways are evident: surficial runoff,
subsurface pathways, discharges associated with the
thermal plume, and airborne transfer. Any pollutants
entering the South Bay may result in direct lethal or
non-lethal impacts to local plants and animals.
Alternatively, processes such as food chain transfer
and biomagnification may lead to significant indirect
impacts to broader regional populations.
o Tidal Flushing and Plume Behavior in
Data describing present tidal flushing in south San
Diego Bay, as-well as the present and future behavior
of the p~wer plant thermal plume, are outdated
inadequate. This is of central concern, for the
efficiency of tidal flushing and the behavior of the
thermal plume interact to control major adverse impacts
to marine populations in the South Bay. This series of
concerns relates only to impacts of proposed power
plant operations on the physical environment of South
Bay. The biological consequences of these adverse
physical impacts are dealt with as a separate issue.
An important related concern is exactly how tidal
flushing and plume behavior are being modeled in order
to accurately project both present and future proposed
power plant operations and physical impacts.
III-1
Q BioloGical Impacts of the Thermal Plume:
The most significant issue raised by the proposed
combined-cycle facility concerns potentially serious
adverse impacts to South Bay biological populations
from changes to the power plant cooling system.. These
impacts will result from substantial increases in both
impingement and entrainment mortality, as well as
impacts caused by changes to the plant's thermal plume.
Q Cumulative ImpaCts:
Finally, cumulative impacts are o~ very great concern.
Viewed from perspectives of extreme biological
sensitivity, regional scarcity, and steadily increasing
regulatory protection, any incremental reductions in
quality, or outright loss, of South Bay habitats or
biota must be viewed as unacceptable.
Each of these five areas of concern is addressed in the
subsections that follow. Prior to addressing the individual
topical concerns identified above, the report first provides a
south San Diego Bay marine habitats and resources.
B. SOUTH SAN DIEGO BAY - A REGIONAL PERSPECTIVE
San Diego Bay is the largest semi-enclosed marine
embayment located on the 900-mile stretch of coast between San
Francisco Bay to the north and Scammon's Lagoon, in central Baja
California, to the south. San Diego Bay is approximately 14
miles long and 2-1/2 miles across at its widest point. San Diego
Bay is a center of trade, shipping, commercial fishing and
recreation. Ecologically it is also considered one of the most
important embayments of the California coast. San Diego Bay is a
major spawning area for ocean and bay fish, and is a significant
part of the Pacific flyway for annual migratory birds which use
the bay for feed, nesting or resting.
central Sa g a n i e u acres of
shallow baywaters, some 600 acres of mudflats, approximately 200
acres of salt marsh, over 1,250 acres of salt ponds, and a
riparian corridor along the Otay River. Seven state or federal
endangered bird species, including Belding's Savannah sparrow
(Passerculus sandw~chens~S beldinq~), California brown pelican
(pelecanus occidentalis occidentalis), California least tern
(Ste~n~ alb~rons brownS), Light-footed clapper rail (Rallus
lon~irostris leviDes), Long-billed curlew (Numenius americanus),
Peregine falcon {Falco pere~rinus anatum), and Western snowy
plover CCharadrius alexandrinus Divosus); the Eastern Pacific
green/black sea turtle (Chelonia mydas aqassizi); and one
endangered and one rare plant species, Salt marsh bird's beak
(Cordvlanthus maritimus) and Palmer's frankenia (Franken~a
Dalmeri), respectively, have all been found in south San Diego
III-2
Bay habitats. It is important to stress that all of these
sensitive and endangered species occur most frequently, and
sometimes exclusively, in south San Diego Bay habitats.
Over the past several years the highest numbers of
nesting pairs of endangered California least terns in San Diego
Bay have occurred at the Chula Vista Wildlife Reserve,
immediately adjacent to the SDG&E plant site, and at the nearby
saltworks and Sweetwater Marsh National Wildlife Refuge. The
highest individual counts during 1988-89 seasonal surveys were
also recorded at the Chula Vista Wildlife Reserve (MBA 1989,
Vol. II, §9) (see list of references at end of this section for
full citations).
The endangered Belding's Savannah sparrow occurs in all
the remaining saltmarsh sites around south San Diego Bay.
Highest numbers during 1988-89 seasonal surveys occurred on the
Chula Vista Wildlife Reserve, outer edge of the saltworks, and
the South Bay Marine Biology Study Area -- all locations impacted
by the thermal plume from the South Bay power plant (MBA 1989,
Vol. II, § 9).
The Light-footed clapper rail is one of the most
endangered bird species in California. Only 177 pairs were
recorded, statewide, in 1988, and five of these were recorded
from the South Bay Marine Biology Study Area saltmarsh, located
immediately across the Bay from the South Bay Power Plant (MBA
1989, Vol. II, § 9)'-
The Western snowy plover, a sensitive species
evidencing serious population declines, occurred in summer 1988
along the northern border of the saltworks adjacent to the
present SDG&E power plant discharge channel. The endangered
Long-billed curlew was noted from the same location throughout
1988-89 seasonal surveys (MBS 1989, Vol. II, § 9).
San Diego Bay has experienced major reductions in
sensitive shallow-water habitats--saltmarsh, intertidal flats,
and shallow (<6 fe~t below mean lower low water, MLLW) subtidal
bay-bottom--over the past 130 years (see Exhibit A; MBA 1989).
Further, what %emains of these habitats is concentrate~tn South
Bay, south of the Sweetwater River Flood Control Channel (see
Exhibit B; MBA 1989). For example, intertidal saltmarsh in San
Diego Bay declined from 2,674 acres in 1856 to 203 acres in 1984-
-a drop of 92 percent; and all 203 acres that remain are in South
Bay. Intertidal sand and mudflats declined 81 percent (from
4,057 to 766 acres) over this same period, and 79 percent of what
remains is in South Bay; shallow subtidal areas of bay-bottom
declined 72 percent (from 6,807 to 1,928 acres), with 81 percent
restricted to South Bay.
The special biological values of south San Diego Bay
are also reflected in the distribution of eelgrass beds, widely
recognized for their role as spawning/nursery areas add
protective habitat for small fish. A September 1988 survey
III-3
confirmed 299 acres of eelgrass beds in San Diego Bay--some 191
acres Of this, or 64 percent, are located in south San Diego Bay
(MBA 1989). Historical data clearly document that declines in
eelgrass cover result in parallel declines in fish, shellfish,
and birds that are dependent upon the eelgrass (Thayer, et al.
The recently prepared Batiquitos Lagoon Enhancement
Plan EIR/EIS (City of Carlsbad 1990) provides approximate figures
for total acreages of saltmarsh and tidal shallow-water habitats
along the San Diego County coast. Of county totals of 2,080 lnd
1,020 acres for saltmarsh and mudflat shallows, respectively,
some 12 and 75 percent, respectively, occur in south San Diego
Bay. Recent National Marine Fisheries Service (NMFS) sponsored
research suggests that the dramatic decline in Southern
California halibut stocks might directly reflect declining
nursery habitat in the region's shallow bays and estuaries.
Many of these same intertidal and shallow-water
habitats critical to fish populations are also critical to
migratory shorebirds and waterfowl. Ongoing surveys (1988-89)
being conducted by the Point Reyes Bird Observatory indicate that
south San Diego Bay hosts the largest concentrations of migratory
shorebirds of any site within San Diego County (see Exhibit C) or
northern BaJa California.
In summary, any environmental changes or adverse
biological impacts that may result from the proposed construction
of the combined-cycle power plant at SDG&E's existing South Bay
Power Plant site must be viewed in a regional context. South San
Diego Bay contains a substantial proportion of the remaining
examples of several critical and sensitive Southern California
coastal resources--saltmarsh, intertidal and shallow-subtidal
protected embayment habitats, eelgrass beds, fishery and
shorebird habitats. Each of these resources has suffered very
substantial historical declines, and what remains must be
protected from further degradation.
C. BATHYMET. RY AND SEDIMENTATION PROCESSES
IN SOUTH SAN DIEGO BAY
1. SummarV/Overview
Neither the present bathymetry of the bay-floor in
south San Diego Bay, nor the sedimentaticn processes that result
in shallowing of South Bay and reduction of its water volume, are
well documented. As a result, it is impossible to accurately
model and project how either present plant operations (cooling
water intake/thermal plume discharge), or future, additional
plant operations will impact the physical environment and thus
the biological communities of south San Diego Bay.
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2. Analysis
i
a. Environmental Settint
The most recently available navigation chart~ for south
San Diego Bay were published in 1984 and reflect minimum water
depths for boating rather than true bay-floor bathymetry. Lack
of accurate and more up-to-date depth data has two significant
consequences. First, it is impossible to accurately quantify the
acreages of specific water-depth-related habitats present within
South Bay. Second, it is impossible to accurately quantify the
!1 volume of water contained within South Bay under various tidal
conditions.
This latter information is critical to assessing the
impact of the present-=and proposed--power plant cooling water
system and thermal plume on south San Diego Bay. For example,
these impacts cannot be analyzed in the absence of information on
the proportion of total South Bay water volume that is presently
cycl~d through the power plant, under a given set of tidal and
plant operating conditions.
Comparison of recent (1988) low-altitude aerial
photographs of south San Diego Bay with maps in SDG&E reports
indicates substantial changes in intertidal mudflat distribution
over the past 20 years. Annual receiving waters monitoring
iI reports for SDG&E's NPDES permit also refer to changing South Bay
sediment distributions, possibly due to runoff from major
· flooding events in the late 1970s and early 1980s. A recent
eelgrass reestablishment site adjacent to the SDG&E intake
channel was unexpectedly buried by several inches.of sediment
(Merkel 1990). These data all indicate a much more dynamic
sedimentation regime than has been indicated by SDG&E in the NOI.
These issues all relate to sedimentation processes and
possible rates of deposition in South Bay. They are important
because continuing sedimentation causes shallowing of the bay
and, consequently, a reduction in the total volume of water in
South Bay. As not~ above, the relationship of power plant
I cooling water/thermal plume behavior to the total water volume
(under given tMal and plant operating conditions) will~.nfluence
the overall impacts of the thermal plume on the marine habitats
Analyses going back to the 1979-80 period, or even
earlier in the early 1970s, may now be both incorrect and
inappropriate. Accurate, updated information is needed before
the question of plume impacts can be adequately addressed--and
indeed before the physical oceanography of south San Diego Bay
b. Potentially Significant Adverse
Impacts
To the extent that the South Bay has shallowed and its
total water volume has declined, impacts of the present flow-
through cooling system and thermal plume will be greater and more
significant than previously described in the 1980, 316(b~
demonstration studies.
Since both the proposed combined-cycle and augmentation
projects will each result in major increases to both water intake
and thermal plume discharges, these potential impacts cannot be
adequately modeled without better bathymetry data. Impact
projects, based on presently available but inaccurate data, will
substantially underestimate true impacts of the new plant(s).
Clearly there is a need for an accurate, updated bathymetric
survey of South San Diego Bay. This will provide a baseline for
all tidal and hydrological modeling of physical conditions in
South Bay, including rates of tidal flushing and exchange, and
the potential behavior of the power plant thermal plume under
alternative development scenarios.
c. Need for Additiona~ Dat~
Development of two new data bases can provide the
information needed to solve the potential concerns noted above.
First, an accurate, detailed, bathymetric survey (one-foot
contour interval) must be conducted of the entire South Bay.
This will provide depth and volume data for necessary modeling
efforts. These same data will also provide a more adequate
assessment of present biological habitat distributions within
south San Diego Bay.
Second, detailed comparisons need to be made between
the new bathymetric data set and previously available data. This
would permit a quantitative assessment of sedimentary infilling
in the South Bay and of rates of sedimentation. This is critical
to assessing future changes that can be expected to occur in the
South Bay as a resul._t of sediment input.
In th~s case data collection and analysis willsserve to
identify appropriate mitigation measures to solve the problems
and concerns noted above.
The following information also is necessary to an
adequate assessment of the impacts of the proposed cooling water
intake, thermal plume discharge, and plant operation:
(1) Hydrological data regarding the increased sedimentation
potential created from the construction of additional
transmission facilities, plus a description of the type of
construction techniques that will be used to build the new
facilities and the mitigation measures that will be implemented
to reduce adverse impacts on wetland areas.
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(2) A description of when the present intake and outflow
channels were constructed, their original widths, depths, and
specific bathymetry, how these specific characteristics have
changed from initial power plant operation to the present, how
frequently depth surveys have been conducted, and what specific
quantitative bathymetric information SDG&E has used to confirm
that no significant sedimentation has occurred within south San
Diego Bay over the past 20 years, including all tests, reports,
and other supporting data.
(3) A description of the effects that the present thermal
plume has on flocculation processes and settlement rates of fine-
grained sediments in south San Diego Bay, and how these effects
will change if the thermal plume is increased in temperature,
total area, and persistence as proposed for both the combined-
cycle project alone and also in combination with the augmentation
project. In addition, information is needed regarding how the
enlarged ther:mal plume will affect water turbidity in south San
Diego Bay--whether through changes in suspended particulate
matter or in plankton concentrations.
(4) A description of how the bathymetry of south San Diego
Bay has changed during the past few decades and how the evolution
of the bed topography will be affected by the addition of both
the combined-cycle project alone and also in combination with the
augmentation project, describing in particular how deposition or
erosion will affect circulation.
D. CHEMICAL/TOXIC POLLUTION OF SOUTH
SAN DIEGO BAY
1. Summary/Overview
A wide range of chemicals and potentially toxic
substances are used during routine power plant operations and, in
many cases, are stored onsite. There are numerous different
transfer pathways--both from routine operating procedures and
from unplanned events, such as accidental spills, floods, or
other mishaps--that~c0uld carry these potentially toxic
substances into south San Diego Bay.
The data needed to assess the real potential for Bay
pollution, possible impacts to local plants and animals, and the
adequacy of proposed mitigation measures, are all incomplete.
This precludes accurate risk assessment for both present plant
operations and construction of the proposed combined-cycle plant.
2. ~nalysis
a. ~nvironmental Settinq
There is a broad-ranging potential for a wide variety
of chemicals and possibly toxic or hazardous substances, present
on the power plant site and/or used during plant operations, to
enter the sensitive aquatic habitats of adjacent south San Diego
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I
Ba .1
y Development of the proposed combined-cycle facility and
augmentation of the existing generating facilities would each
result in significant incremental increases in the presence of
potential pollutants onsite. Without appropriate mitigating
measures, there would also be a significant incremental increase
in the risk of accidental spills and possibly pollution of the
adjacent Bay.
If pollutants or toxic substances reach the Bay, they
may directly impact the physical environment through association
with, or burial within, bay sediments. They may directly impact
some of the plants and animals that utilize adjacent Bay
habitats. In extreme cases, such pollutant impacts might be
lethal. In other cases, less obvious effects might include
reduced growth rates, disrupted reproductive cycles, or shortened
life-spans. Additional indirect impacts to local or bay-wide
biological populations could occur through concentration of
pollutants due to food-chain transfer and biomagnification.
Several quite different pathways are available for
transfer of potential pollutants from the power plant site into
south San Diego Bay. These include the following:
(1) Transfer through surficial runoff:
Plant drainage and surface runoff.
Runoff during serious flooding events.
Accidental breaching or overtopping of containment
dikes.
Release of hazardous materials into power plant "waste
stream*'.
k.. ~ Accidental spills of fuel oil, including pipeline
ruptures.
(2) ~elease o= subsurface contaminants:
Durin~ excavation of contaminated soils for plaint
construction.
o Through release of contaminated groundwater during
plant construction.
o Contained within construction dewatering effluent.
1 Section VI, Hazardous Materials and Fire Safety, discusses
in detail the full spectrum of potential exposures to hazardous
materials from the proposed project.
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(3) Throuch release of airborne Dollutants:
I For further discussion of the potentially significant
impacts of airborne releases of hazardous materials, see
I Section VI, Hazardous Materials and Fire Safety.
(4) Transfer through the power plant cooling water stream:
o Shock chlorination impacts to minimize biofouling
buildup.
Addition of other chemicals, lubricants and cleaners,
either deliberately or accidentally, during "normal
plant operations".
Special conditions that pertain during plant startup
II and cleanout procedures.
o Addition of materials to the cooling water stream due
to dissolution, absorption and chelation, as the water
flows through the plant.
Insufficient information is provided in the NOI to
evaluate the hydrologic potential for transporting pollutants.
For example, it is unclear whether dewatering is undertaken on a
foundation of existing structures. If so, data on the intrusion
of saline groundwater and the method of disposing of the
groundwater should be documented.
The proposed plant will require dewatering during
construction, and this may lead to a change of groundwater
salinity and vegetation patterns in the area. Temporary drawdown
of the water table may dry the root zone of existing vegetation,
resulting in extensive damage unless preventive measures are
taken.
The possibility of flooding from Telegraph Canyon Creek
or failure of the per/pheral embankment pose potential flood
hazards. Section 9.2.3.2 of the NOI states that since the site
has not been affected by flooding in the past, the future~isk is
acceptable. This conclusion is irrational, since flood control
systems are usually designed to provide protection against at
least the 100-year flood, and a flood of this magnitude has not
been experienced since the construction of the existing plant.
SDG&E further states, in Section 9.3.3.2.1 of the NOI,
that the flood hazard will be eliminated by enlarging the
existing channel to convey the 100-year flood event. Despite the
channelization of Telegraph Creek, portions of the South Bay site
may still be within a flood hazard area due to tidal influence.
Whether or not the 100-year flood is eliminated, there still may
be a significant pollution risk in the event of buildings or the
site being flooded. If contamination of flood water is a
possibility, additional flood protection in excess of the 100-
year flood event may be considered and enhancements to the
structural integrity of the embankments warranted. In addition,
elimination of flood hazards through drainage channel widening
might result in significant sensitive habitat losses. This issue
needs to be addressed.
Very little information is available for the drainage channel
located at the northern boundary of the site. The potential for
bank erosion along this exposed section of embankment should be
studied. Section V, Geology and Soils, discusses erosion issues
and impacts in detail. Information on the internal drainage
system at the site should be provided, and if the runoff or
subsurface water is polluted, steps should be taken to treat the
water prior to discharge to the South Bay.
Responses from SDG&E to the Data Requests regarding
flood control often appear to conflict with statements in the
NOI. For example, the response to California Energy Commission
Data Request number 145 gives the 100-year flood elevation as 10
feet NGVD and the site elevation as 10 feet NGVD. Section
9.2.3.2 of the NOI gives the flood elevation as 14 feet. NGVD
and the site elevation as 13 feet. NGVD.
While limited information on potential pollutants and
toxics presently used or stored onsite is available in the NOI
and SD~&E's Data Responses, it is generally inadequate to
determine either present or potential future environmental
impacts. More specific details are needed on the identity and
potential concentrations of any possible onsite "pollutants;" the
amounts used, released or subject to accidental spills; and
perhaps more importantly, documented studies of the potential
lethal and sub-lethal (i.e., acute and chronic) effects that any
of these substances might have on the plans and animals found in
South Bay habitats.
Environmental concerns regarding toxic contamination in
past 20 years. An initial concern was sewage disposal with its
attendant problems of nutrient enrichment, algal blooms,
excessive oxygen depl~ion and fish kills. Subsequently,
agricultural pest{cides (especially DDT and its derivative~..and
heavy metals were of concern. Within'the last few years,
concern has been expressed over whole new "families" of
contaminants: chlorinated hydrocarbons, such as PCB's, toxic
components of petroleum hydrocarbons, and related PAH's, and
organometals.
The Mussel Watch Program and NOA's Status and Trends
Program have confirmed that these contaminants occur in San Diego
Bay, and a recent human health risk assessment study (San Diego
Bay Symposium, June 1990) confirmed that fish with pollution-
related diseases such as fin rot and liver tumors have been
collected from the Bay.
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Many of these.issues were not of concern during
previous studies of the South Bay Power Plant and all of its
possible impacts on sensitive marine bay habitats. Even now,
sampling for many of these newer toxic substances of concern in
South Bay sites.
b. Potentially Significant Adverse
The data available to date are neither adequate to
document existing pollutant/toxics-related impacts to south San
Diego Bay biology, nor to access how these risks might increase
if the new combined-cycle and augmentation projects are
constructed. While critical data are still lacking, the greatest
risks of power plant related pollution events impacting south San
Diego Bay probably include: 91) accidental spills of hazardous
materials, including fuel oil, on or near the power plant site;
(2) possible contamination of bay waters during temporary
construction dewatering; and (3) chemical-related impacts due to
normal cooling water flows through the power plan.
Should a fuel oil spill occur and lead to contamination
in South Bay, disastrous biological consequences could result.
The saltmarsh habitats of South Bay are particularly vulnerable
to longterm impacts from oil pollution and it could take years,
even decades, for these impacts to be neutralized. Since
waterbird use of all types is especially high in South Bay, a
spill could also result in serious bird losses, including to the
endangered species associated with saltmarsh habitats (i.e.,
Light-footed Clapper Rail, Beldings Savannah Sparrow).
A principal concern with dewatering effluent would be
any possible contaminant content that might impact the plants,
plankton, benthic invertebrates or fish of South Bay. As already
noted, some impacts might be fatal, while others might reduce
life spans or breeding success, thus changing regional species
populations in more subtle ways. Possible toxic contaminant
introduction during the_power plant flow-through cooling process
raises similar concerns.
To date, no field sampling or testing program has
addressed these issues in South San Diego Bay, and potentially
significant impacts from the South Bay Power Plant remain
unknown.
c. MitiGation Measures
SDG&E has proposed a variety of mitigation measures to
reduce the amounts of potentially toxic materials used or stored
onsite, as well as retaining dikes and other features to reduce
the risk of accidentally spilled materials, or contaminated
runoff, from reaching south San Diego Bay. Since the data
regarding potential pollutants remains incomplete, it is not yet
possible to access the adequacy of the mitigation measures being
proposed.
d. Need for Additional Dat~
The following information is needed to adequately
assess pollution related effects on the proposed project.
Additional requests for data regarding potentially adverse
impacts from hazardous materials can be found in Sectio~ VI,
Hazardous Materials and Fire Safety.
(1) A description of how industrial and hazardous wastes
will be handled and disposed of on and off site should be
provided in order to comply with Chula Vista industrial waste
discharge regulations, specifically Chapter 13.28 of the Chula
Vista Municipal Code, including a description of the type of
sewage system proposed to handle the waste stream from both the
combined-cycle project alone and also in combination with the
augmentation project, and an indication of the expected volumes
and types of wastes that will be produced. This should include
details on the specific types of pretreatment and other waste
treatment that will be conducted.
(2) A description of how the proposed facilities will
comply with the City of Chula Vista's NPDES permit requirements
for surface water runoff into San Diego Bay, including method of
detention, monitoring of water quality and quantity, and
pretreatment and other treatment of surface runoff should be
provided (see Order No. 90-42/NPDES No. CA 0108758: Waste
Discharge Requirements for Stormwater and Urban Runoff from the
County of San Diego, the Incorporated Cities of San Diego County,
and the San Diego Unified Port District).
(3) A description of any impacts associated with the
Telegraph Canyon Creek flood control project, including changes
in the 100-year flood plain (including a site plan, as-built
drawings, design flood profiles and discharges relating to the
channel improvements), a description of any adjustments to FEMA
flood plain boundaFfes that will be required, and a description
and map of the ~ortions of the South Day site that are s~bll
within the 100-year flood plain.
(4) A description of the adequacy of the existing plant
site drainage system and any plans to cure deficiencies and
inconsistencies with current LORS.
(5) A statement of whether process waters in the existing
facility have been tested for their ability to pick up metals or
other chemical compounds from the generation process, including
the results of all tests, studies, reports, and other data.
(6) A statement of whether the cooling water from the South
Bay plant is mixed with any other industrial waters prior to
discharge to the bay, including all studies, tests, reports, and
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