ALLIANCE COLTON CENTURY SUBSTATION PROJECT STAFF ...

April 20, 2001 1 Alliance Colton Century SubstationCalifornia Energy Commission Staff Assessment

STATE OF CALIFORNIA THE RESOURCES AGENCY GRAY DAVIS, Governor

CALIFORNIA ENERGY COMMISSION1516 NINTH STREETSACRAMENTO, CA 95814-5512

ALLIANCE COLTON CENTURY SUBSTATION PROJECTSTAFF ASSESSMENT FOR EMERGENCY PERMIT

SUMMARY

The Energy Commission staff has performed a fatal flaw analysis of the Alliance ColtonCentury Substation Project (Century) and recommends that the Energy Commissionapprove the project with the Conditions of Certification proposed by staff. Staff furtherrecommends that the certification be for the life of the project if at the end of the powerpurchase agreement with the California Department of Water Resources the projectowner can verify that the project meets certain continuation criteria. Theserecommendations are based on the Energy Commission staff’s independentassessment of the emergency permit application, independent studies and siteevaluation and consultation with agencies that would normally have permitting authorityover the project except the Energy Commission’s emergency permitting authorityprovided by Emergency Executive Orders by the Governor.

On March 21, 2001 Alliance Colton, LLC. (Alliance) filed an emergency permittingapplication for the Century project. Alliance submitted supplemental applicationinformation March 30 and April 6. Alliance’s application was deemed complete on April6, 2001. The application is available in Adobe PDF format at the documents portion ofthe project website, at http://www.energy.ca.gov/sitingcases/peakers/century.

The Century project is a proposed 42 MW simple-cycle power plant on the Centurysubstation site owned by the City of Colton. The substation is located at 661 South CooleyDrive (APN #027613174) in the City of Colton in San Bernardino County. Althoughportions of the site have not been previously developed, on-site disturbances include utilityeasement access and evidence of off-road vehicle use. The site, approximately 0.67-acres, is located south of Interstate 10, east of Mount Vernon Avenue, and west ofInterstate 215. Surrounding land uses include the Santa Ana River to west and north, arailroad line and facility to the north, a motorcycle training facility immediately adjacent thesite to the south, and an industrial/office complex located to the immediate southeast of theexisting substation. In addition, a concrete flood control channel that drains to the river islocated on the east side of South Cooley Drive. However, much of the surrounding area isdeveloped, although the nearest residential developments are located approximately 0.5-mile to both the south and the east, beyond Interstate 215.

The proposed project consists of four General Electric model 10B1 simple-cycle gasturbines rated at 10.5 MW each, along with associated equipment. The proposed permitsfrom the air district will require the project to meet air emission limits set by the BestAvailable Control Technology (BACT). For a simple-cycle gas turbine, these limits are 5ppm for oxides of nitrogen (NOx) and 6 ppm for carbon monoxide (CO). Due to the criticalneed for electricity this summer, the turbines will initially operate under a ComplianceOrder Alliance will obtain from the South Coast Air Quality Management District

Alliance Colton Century Substation 2 April 20, 2001Staff Assessment California Energy Commission

(SCAQMD) for the first few months without air pollution control technology capable ofmeeting BACT emission levels. The project will initially use dry low-NOx technologycapable of limiting NOx emissions to 25 ppm. Alliance will install either Selective CatalyticReduction (SCR) emissions control or XONON combustion technology to reduceemissions to 5 ppm NOx following the schedule set in the SCAQMD Compliance Order.

The project will use water only for evaporative inlet air cooling. A maximum of 25 gallonsper minute of water will be required and will be supplied by the City of Colton through anexisting water line serving the substation. No wastewater will be generated by normaloperation of this facility. Wastewater from periodic turbine cleaning will be collected andremoved from the site for disposal. The SCR emission control technology, if used, willrequire the storage and use of aqueous ammonia. If the XONON combustion technologyis used to limit air emissions, no aqueous ammonia will be used at the site. A locationmap, site plan, and air photo of the project site from Alliance’s application are available fordownload along with this staff assessment at the project web site.

Electrical interconnections for the project will be made at the substation via a generatorstep-up transformer. Natural gas will be supplied to the project by SoCal Gas via anunderground pipeline extending approximately one and a quarter miles. The pipeline willrun southwest from the project site along an existing utility right-of-way to Mt. Vernon. Thepipeline will be hung from the Mt. Vernon Street bridge over the Santa Ana River, and thenrun along M Street to connect with an existing SoCal Gas supply pipeline.

Alliance anticipates construction to require approximately three months, and to becomplete in time to allow the power plant to go online by August. The peak constructionworkforce will be 42 workers and supervisors.

EMERGENCY PERMITTING AUTHORITYThis project is being considered outside of the Energy Commission’s normal powerplant permitting process. Under Public Resources Code section 25705, if the legislatureor the Governor declares a state of energy emergency, the Commission has emergencyauthority to order the construction and use of generating facilities under terms andconditions it specifies to protect the public interest. This authority can be invoked only ifthe Legislature or Governor declares a state of emergency and the Commissiondetermines that all reasonable conservation, allocation, and service restrictionmeasures may not alleviate an energy supply emergency.

Governor Gray Davis declared a state of emergency on January 17, 2001. On February8 and March 7, 2001, the Governor issued several executive orders and declared thatall reasonable conservation, allocation, and service restriction measures will notalleviate an energy supply emergency.

In Executive Orders D-26-01 and D-28-01, the Governor ordered the EnergyCommission to expedite the processing of applications for peaking and renewablepower plants that can be on line by September 30, 2001. The Governor also declaredthat these projects are emergency projects under Public Resources Code section21080(b)(4), and are thereby exempt from the requirements of the California


Environmental Quality Act (CEQA). A summary of the emergency permitting process,including the proposed schedule, and a checklist showing the information required in anapplication, can be found on the web at:http://www.energy.ca.gov/sitingcases/peakers/documents/index.html

NEED FOR EMERGENCY PERMITTING

SUPPLYThe electric generation system must have sufficient operating generating capacity tosupply the peak demand for electricity by consumers (including the transmission anddistribution losses associated with power delivery). Also, an additional amount ofreserve power plant capacity must be operational to act as instantaneous back-upsupplies should some power plants or transmission lines unexpectedly fail. Accordingto the Western Systems Coordinating Council (WSCC), to reliably deliver power, controlarea operators should maintain operating reserves of seven percent of their peakdemand (including losses). If operating reserves decline below that level, customersthat have agreed to be interrupted in exchange for reduced rates may be disconnected.If operating reserves get as low as one and a half percent, firm load will likely be shedlocally, resulting in rotating blackouts, to avoid system-wide blackouts.

Current estimates by Energy Commission staff of consumer peak demand for electricityand reserve requirements, and of the expected availability of electricity capacitysupplies for the summer of 2001, indicate that existing capacity supplies are notadequate to maintain a seven percent operating reserve margin particularly if summertemperatures rise above levels that have as much as a 10 percent chance of occurring.Therefore, additional capacity resources or demand reductions are needed now and bynext summer to maintain a seven percent operating reserve margin under temperatureconditions that have about a 10 percent chance of occurring.

Many efforts to reduce peak demand and supply new capacity are currently under way.More than 2,500 MW of new generation may be operational by July 2001. Theseprojects include power plants already certified by the Energy Commission that arecurrently under construction; various upgrades, rerates and returns-to-service ofexisting power facilities; and new renewable generation responding to EnergyCommission incentive programs. The emergency approval of new simple-cycle powerplants at numerous locations throughout the state is also important to respond to peaksummer demand and provide local electricity system reliability.

Staff assumes that power plant outages of about 3,000 MW will occur throughout thesummer. If power plant outages this summer turn out to be greater than assumed, newcapacity resources, such as peaking power plants, can help maintain an adequatereserve margin, and help avoid or shorten the duration of rotating blackouts.


PUBLIC HEALTH AND SAFETYThere is a reliability benefit associated with locating generation resources near thesignificant load centers. When load and generation are seriously out of balance, asthey are in most service areas, the potential for system separation, islanding andcascading outages are significantly increased (U.S. Congress, Office of TechnologyAssessment, June 1990). If additional simple-cycle projects are not licensed and built,this reliability benefit will be foregone until additional larger baseload generation is builtin such areas. Although it is impossible to accurately calculate the likelihood of systemoutages, such outages are certainly plausible and are much greater without newgeneration resources in most California service areas. Power outages frequently occurduring, and are often precipitated by, periods of extreme heat. Extreme summer heatcreates extreme demand primarily from air conditioning loads. In fact, it has beendemonstrated that demand in California is particularly sensitive to small increases inmaximum summer temperature (CEC 1999). In the summer of 1998 the systemdemand in California increased by 4,000 MW as a result of a five-degree increase intemperature as compared to more typical maximums.

When major outages occur, there is an increased risk of significant public health andsafety impacts. Fatalities and injuries associated with many types of accidents mayresult from outages, such as traffic accidents from signal and lighting failures, falls downunlighted stairways, fires caused by use of candles for lighting and unconventionalopen-flame cooking, loss of life support equipment in medical clinics, and electricalshock from improper use of portable electric generators. However, a much moreserious risk is the potential morbidity and mortality associated with summer heat waves.Behind major epidemics, heat waves in California rank among the worst of all othernatural disasters in the history of California for excess mortality. Heat waves havecaused more fatalities in individual events than the 1906 earthquake (452 deaths), theSan Francisquito Dam collapse of 1928 (450 deaths) and the Port Chicago explosion in1944 (322 deaths) (Oechsli and Buechley 1970). The mortality associated with oneCalifornia heat wave in 1955 resulted in 946 deaths (before air conditioning was incommon use). Fortunately the mortality associated with such events is completelypreventable (Semenza 1995). One of the most effective ways of avoiding mortalityduring heat waves is to spend time in air conditioned environments during the hottestparts of the day (CDC 2000). However, artificial climate control (air conditioning) maybe mandatory to avoid fatalities when temperatures change abruptly (Bridger andHelfand 1968).

The availability of air conditioning has significantly reduced the mortality associated withheat waves in California and throughout the nation. It was estimated that increased useof air conditioning during the 1963 Los Angeles heat wave saved over 800 lives(Oechsli and Buechley 1970). Sensitive populations are often dependent on airconditioning to avoid aggravation of chronic health conditions such as chronicobstructive pulmonary disease or acute health effects such as heat stroke. It is widelyrecognized that hot weather conditions can significantly increase both morbidity andmortality, particularly among sensitive populations such as the very young, the elderly,and those with chronic diseases (Bridgerand and Heland 1968) (Schickele1947)(Oechsli and Buechley 1970) (Kalkstein et al. 1989, 1993, 1997, 1998). Thus,


shortages of electricity can impose risk of very serious impacts on the public, potentiallyincreasing the risk of deaths due to heat waves. The vast majority of those who die inheat waves are at home without air conditioning and are elderly. Based on evaluationof the public health and safety risks associated with new projects, staff concludes thatnew generating projects are much more likely to reduce public health and safety risksthan increase them.

AIR EMISSIONS OF BACK UP GENERATORS COMPARED WITHEMERGENCY PERMIT POWER PLANTS

California generation is among the cleanest in the country. This is due to negligible coaland oil use as generation fuel, the Best Available Retrofit Control Technology (BARCT)and Best Available Control Technology (BACT) rules, and a robust mix of geothermal,renewable, nuclear and hydroelectric generation. With the generation shortfallsCalifornia has experienced in recent months due to abnormal forced and unforcedoutage rates and shortages of instate and out of state generation capacity, severaloptions have been considered to supply additional generation without compromisingpublic health and safety.

One option is to utilize the existing fleet of diesel engines that are used as backup orstandby generators for facilities such as hospitals, businesses, and essential servicessuch as telephone, water, sewer, police and fire. Most of these generators are exemptfrom permitting as they are designed to only run when the grid fails to deliver electricity.That fleet is older and uncontrolled. It could represent 11,500 units, producing as muchas 5,000 MW. However, as little as 1,200 MW may be compatible with operating inparallel with the grid. Most units are designed to only operate when isolated from thegrid, and only with enough power for essential load at the facility.

Another option is to rely on a small number of diesel or natural gas engines that arepermitted with emission control equipment as prime engines. Their emissions are in therange of 10 lb NOx/MWhr. However, they may not be tied to a generator (e.g., theymay operate a pump or compressor) or are already operating at or near baseload, sothey may not be able to supply much electricity to the grid. Other California generationoptions are less than 1.0 lb NOx/MWhr, but few are cleaner than the system NOxaverages with the exception of demand reduction, solar, wind, and expensive fuel cells.The generation system emission averages will continue to decrease as the BARCTrules are fully implemented and the new generation with BACT installed comes online.The generation system emission average should approach 0.1 lb NOx/MWhr by 2005.

DIFFERENCES IN AIR EMISSIONSEmission rates, rather than the sheer number of generators of any one type, are key tocomparing emissions from different generation sources. For example, if there is a needfor 1000 MW over 10 hours, or 10,000 MWhrs, then the NOx emissions are simply aproduct of the emission rate multiplied by 10,000. Diesel standby engine use wouldresult in 150 tons of NOx over 10 hours, versus 1.5 tons from 1000 MW of natural gas-fired generation over the same period of time. With NOx emissions controlled to 5 ppm,


the GE10B1 turbines proposed in this project would produce approximately 1.2 tons per10,000 MWhrs of generation.

The location and configuration of a source are also significant factors in assessing theeffect on air quality. If the 1000 MW is concentrated in one location (e.g., a 1000 MWcombustion turbine or combined cycle project), then the emission will be of relatively lowconcentration, will be buoyant, and will be emitted at a relatively high elevation from astack. If the 1000 MW consists of 1,000 one-MW diesel standby generators, theemissions will be emitted near ground level, at relatively high concentrations, andprobably over a wide region or even throughout the state. Similarly, a dispersed set ofpeakers (e.g., twenty 50MW General Electric LM6000s) could be located throughout thestate. Without knowing their exact locations, their effects on air quality are not entirelyknown. A peaking power plant located next to a hill or mountain, because of the terrainor topography, or in an area that is already heavily polluted could result in violationswhereas the other 1000 MW “configuration” might not.

EMISSION REDUCTION CREDIT BANKThe Governor’s Executive Order D-24-01, charges the California Air Resources Boardwith the responsibility of creating a state emission reduction credit bank for the purposeof providing offsets for new or expanded peaking facilities that could add new power bythis summer. This bank was initially funded with recent NOx reductions generatedthrough the CARB’s Carl Moyer Program, an incentive program. The incentives aregrants that cover the incremental cost of cleaner on-road, off-road, marine, locomotiveand stationary agricultural pump engines, as well as forklifts and airport ground supportequipment. Because the new or expanded peaking facilities will operate under shortterm entitlements, for the purpose of responding to the energy crisis, the use of thesemobile emission reductions are intended to provide NOx and particulate matter offsetsfor these peaking facilities.

These emission reduction credits (ERCs) are available through the Board to peakingpower plants that need emission offsets in order to add new or expanded peakingcapacity that will be on-line by September 30, 2001. These credits are intended to fullysatisfy offset requirements of these power plants. The ERCs available from this bankare nitrogen oxides (NOx) and particulate matter less than 10 microns (PM10). Whereneeded, these ERCs will be issued to qualified power plant applicants for a three-yearperiod. These ERCs will expire on November 1, 2003, to ensure that these credits willbe available for three full summer peak seasons. The amount of NOx ERCs needed forthis project is directly related to the emission control level of 5 parts per million NOx andthe number of hours of operation. The CARB bank will make up to 21 tons per yearavailable for purchase for each 50 MW power plant up to 100 MW total. Prior to theexpiration of the CARB short term ERCs, applicants who use these credits will berequired to secure permanent emission reductions for the remaining life of the powerplant peaking units if the applicant desires to continue to operate the unit.

Heavy-duty engines are a significant source of smog-forming pollutants. About 525,000heavy-duty diesel trucks are driven throughout the state, with another 680,000 diesel-fueled engines used in construction and agriculture. Together, diesel engines


contribute about 40 percent of all NOx emissions from mobile sources. NOx is one ofthe main contributors to ground-level ozone, one of the most health-damagingcomponents of smog. In addition, the fine particulate matter exhaust from heavy-dutydiesel engines is a toxic air contaminant. The Carl Moyer incentive program focuses onreducing emissions of smog-forming NOx, but will also reduce particulate emissions.

Particulate matter includes many carbon particles (also called soot) as well as othergases that become visible as they cool. In 1998, California identified diesel particulatematter (diesel PM) as a toxic air contaminant based on its potential to cause cancer andother adverse health effects. In addition to PM, emissions from diesel-fueled enginesinclude over 40 other cancer causing substances. Overall, emissions from dieselengines are responsible for the majority of the potential airborne cancer risk inCalifornia. Several studies have confirmed that the cancer risk from diesel particulatesis greater than the risk from all other identified toxic air contaminants combined. Giventhese findings, using the proposed emission reduction credit strategy will be an effectivemeans to offset peaking power plant emissions as an interim measure.


STAFF ANALYSIS OF THE ALLIANCE COLTONCENTURY SUBSTATION

The following sections briefly describe staff’s fatal flaw analysis of the Century project.Conditions of certification for the project are included at the end of this report.

ENGINEERING

The project, including its linear facilities, such as water and natural gas pipelines, will bedesigned and constructed in compliance with the California Building Code (CBC) and allother applicable engineering LORS (see Condition of Certification GEN-1 below). Thiswill be assured by the Commission’s delegate Chief Building Official (CBO), whoseduties are prescribed under the CBC. These duties include the review of projectdesigns by qualified engineers and the inspection of project construction by qualifiedinspectors. The CBO’s performance, in turn, will be ensured through monitoring by theCommission’s Compliance Project Manager.

The standard Facility Design condition of certification, GEN-1, is required. No additionalFacility Design conditions are proposed.

AIR QUALITY

The analysis of the air quality impacts of this emergency permit application wasperformed by the South Coast Air Quality Management District (SCAQMD). On March29, 2001, the SCAQMD issued a notice of intent to issue an Authority to Construct forthis facility. This notice initiates a 30-day public comment period. SCAQMD intends toissue the Authority to Construct for this facility after the close of that comment period. Acopy of the notice is included in Appendix A of this report. Staff has incorporated theAuthority to Construct by reference (see Appendix B) and proposed conditions ofcertification that require the project owner to limit fugitive dust emissions duringconstruction and to comply with the Authority to Construct issued by the South Coast AirQuality Management District.

The proposed permits from SCQAMD will require these turbines to be equipped with airpollution control equipment that will meet the following emission levels: 5 ppmv NOx @15%O2, 6 ppmv CO @ 15%O2, and 2 ppmv ROG @ 15%O2. The air pollution controlequipment will consist of either Selective Catalytic Reduction (SCR) with oxidationcatalyst, XONON™ combustor technology with oxidation catalyst. If the SCR is utilizedas the air pollution control equipment, ammonia will be used to react with NOxemissions in the exhaust gases; therefore, an ammonia storage tank is also beingproposed for the SCR control option.

Due to the critical need for electricity this summer and because the constructionschedule does not allow for full installation of air pollution control equipment prior toSeptember 2001, in implementing the Governor’s Executive Orders, the turbines will be


operated for the first few months without air pollution control equipment and under aCompliance Order that Alliance Colton LLC will obtain from the AQMD.

NOISE

Existing noise sources in the vicinity of the project area include traffic from Interstate 10and Interstate 215, noise generated by the adjacent industrial/office complex to thesouth, a motorcycle training facility to the southwest, and intermittent noise from theexisting railroad line to the north of the project site.

Noise impact information supplied by the applicant indicates that project noise levels atthe property line at the adjacent southern development, assuming use of sounddeadeners on each turbine and a 20–foot block wall, would be 65 dBA. These levelsare consistent with the City of Colton noise ordinance standard of 65 dBA at six feetabove grade on the south side of the project, where the 20-foot block wall would shieldproject noise from the adjacent industrial/ office complex. However, the applicant hasnot proposed a similar block wall around the entire project; thus, noise levels to thewest, north, and east of the project would exceed the 65 dBA standard. Additionalimpacts are not expected to result from noise levels in excess of this standard, includingany potential impacts to sensitive species within the project area. Further discussion ofpotential project-related impacts sensitive species can be found in the BIOLOGYsection of this report.

On April 11, 2001 the City of Colton Planning Commission found that the proposedproject would be “…consistent with the intent and guidelines of the General Plan” and“…consistent with the guidelines for granting a Major Variance, as outlined in Section18.58.040 of the Zoning Ordinance.” A Major Variance to exceed height and noiserestrictions was approved by the Planning Commission at that time; therefore, theproject as proposed would be in compliance with local standards.

Standard Conditions of Certification NOISE-2, NOISE-3, NOISE-4 are required toensure that project-related noise impacts will be reduced to a less than significant level.No additional Noise conditions are required.

HAZARDOUS MATERIALS

The proposed project may involve use of aqueous ammonia and will involve use ofnatural gas. Ammonia may be used for control of NOx emission in an SCR system.However, this option will be an alternative to the use of the XONON process that is theAlliance Power’s preferred approach for NOx control. The XONON system would notrequire use of ammonia. In the event that ammonia is used, Alliance has chosen to usea form of ammonia that inherently safe. The choice of a 19 percent aqueous solutionwould result in a very low emission rate in the event of accidental release of ammonia.In addition to proposing this form of ammonia, Alliance has also chosen to incorporatespill containment facilities around the storage tank and delivery areas. These measures


will reduce the potential for impact on the public as a result of ammonia handling at thefacility to less than significant levels.

Natural gas will not be stored at the site but will be handled in significant quantities.However, the systems used to handle natural gas at the facility will comply with allapplicable engineering design codes and fire protection codes. These measures willreduce the potential for impact on the public as a result of natural gas handling at thefacility to less than significant levels.

The proposed project will require the installation and operation of a natural gas pipeline,which will be designed and operated in compliance with all applicable codes. Thesemeasures will reduce the potential for impact on the public as a result of accidentalrelease to less than significant levels. Staff has reviewed potential external hazardsposed by numerous rail lines in the vicinity of the pipeline and has concluded that traintraffic near the pipeline would be at relatively slow speeds and at distances that are notlikely to pose threats to the pipeline.

Implementation of standard Conditions of Certification HAZ-1 and HAZ-2 will ensurethat potential project-related hazardous material impacts will be reduced to less thansignificant levels.

RESPONSE TO PUBLIC COMMENT ON HAZARDOUS MATERIALSMANAGEMENT

Comment:Camilla Herrera spoke at the public hearing held in Colton on April 11, and followed witha comment via e-mail because she felt her concerns were not adequately addressed.At the hearing she asked how far the underground gas lines would be installed fromresidents in the area. In her follow-up comment, she noted that the pipeline for thisproject would run immediately in front of homes along M Street. She expressedconcern about the heavy truck traffic, nearby rail lines, and the proximity of anearthquake fault as potential problems for a natural gas line along a residential area.She referred both to the damage in the Mission District of San Francisco from the LomaPrieta earthquake in 1989 and to the Duffy Street explosions in San Bernardino in 1989as examples of potential problems.

Response:As noted above, staff believes that current pipeline safety standards are adequate toensure the safety of an underground natural gas pipeline running along a residentialstreet. Staff has reviewed the seismic risk to pipelines associated with many powerplants. Existing pipeline design codes require that pipelines be designed to address site-specific seismic hazards. The performance of modern natural gas pipelines in majorearthquakes demonstrates the adequacy of these design codes in reducing the risk ofreleases to levels that are less than significant.

In addition, the accidental release that resulted in the Duffy Street explosion in SanBernardino was the result of an extraordinarily violent train derailment (California State


Fire Marshal 1993). The train involved reached a speed of over 100 miles per hourafter it lost brakes coming down the steep Cajon grade. The derailment was so violentthat the entire train literally tumbled into several homes, killing two children. All sixty-nine rail cars and five locomotive engines were destroyed in the derailment.Approximately two weeks later, after removal of the train wreckage with heavyequipment, a nearby high-pressure gasoline line ruptured, releasing 300,000 gallons offlaming gasoline. This release caused two additional deaths and resulted in thedestruction of an additional 11 homes. Staff does not believe that an accident of thisnature is plausible in the project area. The train tracks in the project area pass throughswitchyards and a populated area where train speeds are limited. There is no grade inthe immediate area that could accelerate a train to the speeds associated with the SanBernardino event.

BIOLOGY

Alliance proposes to construct the Century project within the walls of the existingsubstation and expand out from the existing substation approximately 360 feet on thesouthwest side. The expansion area is highly disturbed from vehicle use, withvegetation composed of weedy non-native species. The facility and gas pipeline willutilize the existing substation, the additional highly disturbed areas, and existing roads.Equipment will be staged in the substation, on existing access roads or in disturbedareas, all of which will require approval by the Compliance Project Manager (CPM).

The Santa Ana River floodplain contains a number of sensitive and listed species:Santa Ana River woollystar (Eriastrum densifolum sanctorum), Santa Ana sucker(Catostomus santaanae), San Diego horned lizard (Phrynosoma coronatum blainvillei),Los Angeles pocket mouse (Perognathus longimembris brevinasus), Delhi SandsFlower-loving fly (Rhaphiomidas terminatus abdominalis), San Bernardino kangaroo rat(Dipodomys merriami parvus) and burrowing owl (Athene cunicularia) (Moore 2001&CNDD). These species are described below.

• The Santa Ana River woollystar (Eriastrum densifolum sanctorum) is federally andstate endangered. This plant is found in sandy soils on the river floodplain orterraced fluvial deposits (CNDD 2001).

• The Santa Ana sucker (Catostomus santaanae) is a federally threatened fish thatprefers sand-rubble-boulder stream bottoms with cool, clear water and algae(CNDD).

• San Diego horned lizard (Phrynosoma coronatum blainvillei) prefers friable, rocky, orshallow sandy soils in sage scrub and chaparral communities with arid and semi-aridclimates (CNDD).

• The Los Angeles pocket mouse is a federal candidate-category 2 species. Thisspecies is found in grasslands, desert and coastal sage communities with fine sandysoils in the Los Angeles basin (CNDD).

• The Delhi sands flower-loving fly (DSF) is a federally endangered species. Itrequires fine, sandy soils classified as Delhi fine sand with sparse native vegetation(57FR54547).


• The San Bernardino kangaroo rat (Dipodomys merriami parvus) is a federallyendangered species. It is found in alluvial scrub vegetation on sandy loamsubstrates characteristic of alluvial fans and flood plains (CNDD 2001).

• Burrowing owls (Athene cunicularia) are a California Department of Fish and Game(CDFG) species of concern. They are found in open dry grasslands, deserts, andscrublands characterized by low-growing vegetation.

No biological surveys were conducted by the applicant for this facility. The CaliforniaDepartment of Fish and Game recommended that protocol surveys be completed forthe undeveloped areas to be affected by this project. Staff biologist visited the site andobserved no threatened or endangered plant or animal species. The facility site,pipeline route, and surrounding areas are highly disturbed with little native vegetation.After further discussion with CDFG, staff recommends that a clearance survey beconducted prior to ground disturbance. This is reflected in Condition of CertificationBIO-8. No threatened or endangered species are expected to be found during surveysor to be impacted by construction or operation of the Century facility.

CRITICAL HABITATA number of sensitive and listed species are associated with the Santa Ana Riverfloodplain, however none of these species are expected to occur on-site or to beimpacted as a result of the construction or operation of the Century facility. Criticalhabitat for southwestern willow flycatcher (Empidonax traillii extimus) and least Bell’svireo (Vireo bellii pusillus) is located approximately 15 miles downstream from theproject site.

MITIGATION

NOISE

Excessive noise can affect nesting birds. The open field to the northeast of thesubstation is potential habitat for burrowing owl. The area of the Santa Ana Riveradjacent to the facility lacks nesting habitat for southwestern willow flycatcher(Empidonax traillii extimus) and least Bell’s vireo (Vireo bellii pusillus). Critical habitatfor these species is located approximately 15 miles downstream from the project siteand will not be impacted by the noise. The applicant has proposed mitigation todecrease noise levels. Each turbine package is equipped with sound deadeners toreduce the radiated noise from the package. Exhaust silencers will be used to reducethe noise levels of the exhaust system. There is a ten-foot block wall surrounding theexisting substation, and the applicant has proposed installing a 20-foot block wall on thesouth side of the project area. This would decrease the noise levels in potentialburrowing owl habitat to 50dBA.

W EEDS

Weeds brought in by vehicles and other construction activities could displace the nativevegetation. Non-native plants already dominate much of the area, however, additional


seed banks and/or species could be introduced through straw wattles and bales. BMP’sused in construction and operation activities, such as straw bales, will be certified weedfree, also decreasing the chances of additional non-native plants establishing on thesite.

LIGHT

Lighting at the facility could potentially impact sensitive nocturnal species (Moore 2001).Therefore, lighting at the facility will be limited to inside the walls of the facility and bescreened from the outside habitat.

Implementation of standard Conditions of Certification BIO-1 through BIO-6, as well asadditional conditions BIO-7 through BIO-11 will ensure that appropriate actions aretaken to prevent or mitigate impacts to listed species and their habitat. Implementationof this mitigation will ensure that impacts to listed species from construction andoperation of the proposed project are less than significant.

LAND USE

The proposed project site is located in a partially developed area intended for industrialuses within the City of Colton. The General Plan land use designation for the projectsite is SP/Heavy Industrial; the Zoning designation is also SP/Heavy Industrial, asColton’s General Plan and Zoning Ordinance are consistent. Existing land uses in theimmediate project vicinity include the Santa Ana River to the west and north, a railroadline and railroad facility to the northeast, a motorcycle training facility immediatelyadjacent the site to the southwest, and an industrial/office complex located to theimmediate south of the existing substation. The General Plan land use and Zoningdesignations for the surrounding areas are as follows: to the north, Open Space and OS(Open Space); to the south, General Commercial and PC (Planned Community); to theeast, Inustrial and PC; and to the west Open Space and OS (Open Space). Theproposed project is consistent with the existing land use and zoning designation of theproject site, and the project will have a less than significant impact on surrounding landuses.

General Plan land use designations along the planned natural gas pipeline corridor,from west to east, are Medium Density Residential, General Commercial, HeavyIndustrial, Open Space, and Industrial. Corresponding existing zoning classificationsalong the pipeline corridor, also from west to east, are R-2, M-2, C-2, OS, andPC/Industrial. Implementation of Condition of Certification LAND-1 will ensure that anypotential impacts related the proposed natural gas pipeline will be less that significant.

The City of Colton Zoning Ordinance has a height restriction of 50-feet. The proposedproject would include four 52–foot exhaust stacks. As previously noted, on April11,2001 the City of Colton Planning Commission found that the proposed project wouldbe “…consistent with the guidelines for granting a Major Variance, as outlined in Section18.58.040 of the Zoning Ordinance,” and approved a Major Variance for the project to


exceed city height and noise restrictions. Therefore, the exhaust stacks as proposedwill be in compliance with local height restrictions.

The applicant has not provided detailed information regarding either an equipmentlaydown area or additional parking areas that will be necessary during the constructionphase of the project. However, in a letter to Kevin Kennedy, the CEC Project Manager,dated April 4, 2001, the applicant indicated that additional land east of the project sitewill be leased as an equipment lay down area, and land adjacent to the existingsubstation will be leased to provide additional parking during the construction phase ofthe project. This letter was included in the supplemental information submitted by theapplicant. It should be noted that approval of this project does not constitute anyapproval or permitting of additional areas or facilities related to the project notspecifically included in the application, and that is the applicant’s responsibility to ensurethat the necessary permits are obtained prior to the start of construction.

Although financial arrangements between Alliance Power and General Electric areconfidential and have not been disclosed, staff estimates that the total cost of theproposed project would likely be on the order of $40 Million. As Alliance Power hassigned a lease with the City of Colton that requires the existing substation to be returnedto its original condition upon termination of the lease, the proposed project is notexpected to impact the assessed property value of the existing substation, now or in thefuture. In addition, because the existing substation is City owned and does not provideproperty tax revenue to the city, the proposed project would have no impact on currentproperty tax revenues collected by the City of Colton. Alliance will provide annual leasepayments to the city for use of a portion of the substation.

TRAFFIC AND TRANSPORTATION

Site access is provided by Interstate-10 to Mt. Vernon Avenue, south to Cooley Drive,then east on Cooley Drive to the project site. According to information received fromthe City of Colton Department of Public Works, all area roadways are currentlyoperating at a satisfactory level, and the intersection of Mount Vernon Avenue andCooley Drive is currently operating at Level of Service (LOS) B. The proposed projectwill not generate significant traffic during operation, and normal project operation will notresult in significant traffic impacts.

Offsite construction of the natural gas pipeline will occur from west to east from 9th

Street along “M” Street to Mount Vernon Avenue, where the pipeline would be hung bySoCal gas from the Mount Vernon Avenue Bridge across the Santa Ana River. Thepipeline would then follow Cooley Drive to the project site. Pipeline construction maytemporarily disrupt local traffic patterns. The applicant has not included a Traffic ControlPlan (TCP) as part of the application; a TCP would be required prior to the start of anyroadway construction activities. Implementation of a TCP and Conditions ofCertification TRANS-2 and TRANS-4 will ensure that construction-related traffic impactsare reduced to a less than significant level.


Construction traffic will be of a temporary nature, (2-3 months), and highly variable. Nospecific TCP for roads during project construction has been provided. A TCP would berequired prior to any road disruption. Conditions of Certification TRANS-1, TRANS-2,and TRANS-3 will ensure project compliance with Caltrans and City/County limitationson vehicle sizes and weights, and limitations for encroachment into public right-of-way.

Implementation of the above mitigation measures will ensure that the project’s impacton traffic and transportation will be less than significant.

SOIL & WATER

During project construction and operation, wind and water action can erode unprotectedsurfaces. An increase in the number of impervious surfaces (paved, compacted, etc.)can increase runoff, leading to the erosion of unprotected surfaces. A total of 0.97acres of disturbance (permanent and temporary) will be associated with the facility siteand the pipelines (Moreau 2001). The project is being constructed partially at anexisting substation and expanding 360 feet to the southwest.

The applicant will prepare an Erosion and Sediment Control Plan that identifies potentialtemporary and permanent erosion and storm water runoff control measures. The finalplan will include specific best management practices (BMPs) to control storm waterrelated pollution and minimize erosion during construction and operation of the facility.Staff is concerned that the applicant has not provided a plan to protect water qualityduring operation. Storm water coming in contact with the oil associated with the facilitydoes not drain to a separation sump or oily water separator. The applicant will providea plan that identifies storm water pollution prevention control measures, which is subjectto approval by the CPM.

The BMP’s used in this area will be weed free to ensure that no additional non-nativeplants are introduced into this area. For more details see the BIOLOGY section.

The applicant has provided a spill prevention plan. Secondary spill containment will beinstalled around the turbine packages and transformer to prevent oil spills in the eventof catastrophic equipment failure. Each turbine holds approximately 850 gallons oflubricating oil. The oil will not be replaced, decreasing the probability of spills.

The facility will use a total of 20 gallons of water per minute during operation.Approximately 5 gallons of water per minute per turbine is required for the evaporativecooling on the turbine air intake (Moreau 2001). The water will completely evaporateand no wastewater will be produced. The simple-cycle turbines utilize air pollutioncontrol technology that does not require water to control emissions. A water line fromthe City of Colton currently exists on site, and the City of Colton has agreed to serve thefacility.

Implementation of standard Conditions of Certification SOIL&WATER-1 throughSOIL&WATER-3, as well as additional Conditions of Certification SOIL&WATER-5 andSOIL&WATER-6 will ensure that impacts to soil and water from construction and


operation of the proposed project are less than significant. SOIL&WATER-5 requiresstraw bales and similar erosion control devices to be weed-free, and SOIL&WATER-6requires the preparation of a Storm Water Pollution Prevention Plan for the operation ofthe facility. Standard Condition of Certification SOIL&WATER-4 is not requiredbecause the facility is less than five acres and is not anticipated to have any discharge.

CULTURAL RESOURCES

The Century project is an addition to the existing Century Substation Facility. TheCentury Substation was constructed in 1986 under the CEQA guidelines. The initialproject siting process addressed cultural/historic/archaeological elements at the site.No new cultural resource mitigation is required for modifications within the existingCentury Substation. The current project proposed by Alliance will expand the existingsubstation footprint to the southwest and will require a natural gas pipeline that willextend along M Street and across the Mount Vernon Bridge.

In April 2001, Mike Lerch of Statistical Research, Inc, a cultural resource managementfirm, completed the record search of the current project area at the San BernardinoArchaeological Information Center. No archaeological sites have been recorded in thevicinity of the substation, however, there was no record of a previous archaeologicalsurvey in the substation or immediately adjacent areas. A record search of existingcultural resources in the vicinity of the proposed gas transmission route was completedon April 18, 2001. The route will extend the gas line from a connection at 9th Street andM Street in Colton, about 1.5 miles west, and cross the Mount Vernon Bridge, to theCentury Substation. A recorded historic refuse deposit is located south of M Street,opposite the rail yards, which is associated with the railroad use of the area (whichdates to the 1880s). It reportedly contains dining-car china and other refuse. There arealso mapped reports of early irrigation canals crossing the gas-line route perpendicularto the route and parallel to the river. The potential to encounter buried cultural materialsis present along the entire M Street route due to the presence of the historic refusedeposit.

On April 12, 2001 Mr. Lerch conducted a survey of the substation expansion area anddid not identify any cultural remains on the surface. The expansion area is highlydisturbed due to motor vehicle use, flood and flood-control activity. However, due to theproximity of the Santa Ana River and the potential for human habitation along the riveredge, the possibility for prehistoric cultural deposits is present.

California Energy Commission (CEC) staff conducted a site visit on April 16, 2001 andinspected the expansion area and the gas line route. No cultural resources wereobserved in the expansion area or the proposed route of the natural gas lateralextension.

Due to the proximity of the Santa Ana River, the possibility for prehistoric culturaldeposits is present in the vicinity of the Century Substation and expansion area. Thepresence of a historic refuse site south of the railroad right of way along M Streetindicates a possibility of additional historic cultural remains along the route of the


proposed natural gas line extension. Cultural resource monitoring is required for allground disturbing activities on the proposed substation expansion and the natural gaslateral extension. This monitoring is required by standard Condition of CertificationCUL-2. Because of the slight possibility that cultural resources could be encountered inthe project area, standard Condition of Certification CUL-1 does not apply.

PALEONTOLOGICAL RESOURCES

The project site is located on highly disturbed alluvium and has been previously graded(Alliance Power, Inc., 2001a, page 5). The applicant indicates that no knownpaleontological resources are known within the area of the project which is likely toundergo some level of ground disturbance (Alliance Power, Inc., 2001a, page 20).However, paleontological resources information regarding the substation has not beenreceived by the CEC as of April 18, 2001. CEC staff is familiar with the project site fromwork on other projects in the Colton area and concur that there is a neglible chance ofencountering significant paleontological resources during the construction of thisproject. No significant excavations (deeper than five feet below final grade) areanticipated for this project. Ground disturbance of previously undisturbed alluvium willbe minimal since the light loads associated with the foundation of the peaker point toshallow foundation (piers not expected to exceed a depth of 14 feet below finishedgrade (Alliance Power, Inc., 2001a, page 2) and the limited length of the project linearfacilities (natural gas line and electrical transmission line). The proposed expansion andpeaker sites have been disturbed in the past and are not likely to contain significantpaleontological resources in-situ. Although the intact quaternary alluvium has a highpaleontological sensitivity due to paleontological resources finds in alluvium elsewherewithin the San Bernardino Basin, the project is considered by CEC staff to have a lowpotential for encountering significant paleontological resources.

CEC staff propose that the use of the standard Condition for Certification PALEO-2 toensure that, should significant paleontological resources be encountered duringconstruction, the resources will be appropriately assessed and managed. Because ofthe slight possibility that cultural resources could be encountered in the project area,standard Condition of Certification PALEO-1 does not apply.

VISUAL RESOURCES

The project site is characterized by flat terrain with sparse vegetation and a mixture ofdeveloped and undeveloped parcels. An electrical substation lies immediately adjacentto the site to the east, and existing transmission lines located to the north of the sitewould be utilized by the proposed project. There are no important aesthetic resourcesin or near the project area, and there are no residences in the project area. Themajority of existing public views of the site from Interstate-10, which lies approximately0.3 miles to the north, are blocked by an existing construction contractor facility adjacentto the freeway. Views of the site would be available from Interstate 215 and havealready been degraded by the existing substation and electrical transmission lines. The


proposed project would include 4 exhaust stacks, each measuring 52-feet in height, aswell as a 20-foot block wall on the south side of the project site.

The applicant has not proposed any landscaping and has indicated that the City ofColton will not require a landscape plan for the project. Given the industrial nature ofthe surrounding area, the distance of the project from Interstate 10 and 215, interveningstructures that block views of the project site, the existing lack of significant visualresources in the project area, and the Planning Commission’s approval of a MajorVariance for the project, visual impacts are considered less than significant.

The project is subject to specific Conditions of Certification VIS-1 and VIS-2, whichrequire steps to ensure mitigation of potential visual impacts. These measures willfurther reduce any potential visual impacts realted to the project to less than significantlevel. No further Visual conditions are required.

ENVIRONMENTAL JUSTICE

For all siting cases, including the emergency permitting process, Energy Commissionstaff follows the federal guidelines' two-step screening process. The process assesses:

• whether the potentially affected community includes minority and/or low-incomepopulations; and

• whether the environmental impacts are likely to fall disproportionately on minorityand/or low-income members of the community.

Estimated 2000 population data from Claritas shows numerous census tracks within sixmiles of the project site to include greater than 50% minority population, primarily to thenorth and east of the project site. Staff has determined that the impacts from thisproject, with implementation of staff’s recommended conditions of certification, will notresult in a significant impact in the surrounding community. Though minoritypopulations are present in the area, staff finds that there are no environmental justiceissues associated with this project.

TRANSMISSION SYSTEM ENGINEERING

The Alliance Century facility will connect to the city of Colton’s Century substation. Thepower produced by the generators will be stepped up to 66 kV and will connect to thesubstation via an approximately 200-foot transmission line. A new transformer andcircuit breaker will be built adjacent to the Century substation equipment. There are nosignificant transmission issues. Based on the results of the interconnection study, theoperation of proposed generators at the Century substation will not require significantdownstream electric facilities and will comply with safety standards1. The operation ofthe proposed gas turbines at the Century substation appears to reduce the loading on

1 CPUC General Order 95, CPUC Rule 21, Title 8, Articles 35, 36 and 37, Title 8 CCR, Sections 2700-2974, CPUC Decision 93-11-013, Federal Communications Commission Part 15, Public Resources Code4292-4296, and the National Electric Code.


lines bringing power from the Southern California Edison service area into Colton.Alliance Power may be required to replace circuit breakers in the Southern CaliforniaEdison substation, but that will be determined by a Facilities Study which will becompleted at a later date2. Thus, the interconnection of the Alliance Century facility willnot require the construction of linear downstream transmission facilities and there areno significant transmission issues.

CONCLUSION

The Century project, if built and operated in compliance with the proposed conditions ofcertification included in this staff assessment, will be available in time to help alleviatethe current emergency. The proposed conditions of certification serve to protect thepublic interest and the environment. Staff recommends approval of this project.

2 The replacement of circuit breakers usually occurs within the fence line of an existing substation

and is not considered a significant downstream facility for the purposes of this analysis.

Alliance Colton Century Substation 20 April 23, 2001References California Energy Commission

REFERENCES

Alliance Power, Inc. 2001a Certification Application Report for Four 10.5MW Simple-cycle Turbines at Century Substation. Submitted to the California EnergyCommission on March 21, 2001.

Bridger and Helfand. International Journal of Biometeorology. 1968. Mortality fromheat during July 1966 in Illinois, 1968.

California Department of Fish and Game. 2001. Natural Diversity Database.

California Energy Commission. 1999. High Temperatures and Electricity Demand. AnAssessment of Supply Adequacy in California, July 1999.

California State Fire Marshal, 1993. Hazardous Liquid Pipeline Risk Assessment.Sacramento, California.

CDC (Center for Disease Control). 2000. Heat-Related Illness, Death, and RiskFactors Cincinnati and Daton, Ohio, 1999, and United States, 1979-1997, June02, 2000.

City of Colton General Plan, 1985.

City of Colton Zoning Ordinance, 1992.

City of Colton, Telephone conference; John Hutton, Department of Public Works, April9, 2001.

City of Colton, Telephone conference; Nitin Modi, Department of Utilities, April 3, 9 and16, 2001.

City of Colton, Telephone conference; Andre Soto, Planning Department, April 11 and16, 2001.

City of Colton, Telephone conference; Tim Trewyn, Department of Utilities, April 4 and11, 2001.

Hickman, J.C. ed 1993. Jepson Manual: Higher Plants of California. University ofCalifornia Press. Berkeley, California.

Kalkstein and Davis, 1989. Weather and Human Mortality: An Evaluation ofDemographic and Interregional Responses in the United States, Annals ofAssociation of American Geographers, 1989.

Kalkstein et al. 1993 Health and Climate Change-Direct Impacts in Cities, Lancet,1993.

Alliance Colton Century Substation 21 April 23, 2001References California Energy Commission

Kalkstein and Green, 1997. An Evaluation of Climate/Mortality Relationships in LargeU.S. Cities and Possible Impacts of Climate Change. Environmental HealthPerspectives. 1997.

Kalkstein etal. 1998. Analysis of Differences in Hot-Weather-Related Mortality Across44 U.S. Metropolitan Areas. Elsevier. 1998.

Lerch, Michael. April 12, 2001. Personal communication, e-mail from Michael Lerch,Statistical Research, Consulting Archaeologist.

Lerch, Michael. April 17, 2001. Personal communication. Statistical Research,Consulting Archaeologist.

Long, Leon. April 17, 2001. Personal communication. Assistant General Manager; WestSan Bernardino County Water District.

Semenza. New England Journal of Medicine. 1996. Risk Factors for heat-relatedmortality during the July 1995 heat wave in Chicago, 1996.

Shickele, E. Military Surgeon. 1947. Environmental and Fatal Heat Stroke, 1947.

Moore, Y. 2001. personal communication. Environmental Specialist III; CaliforniaDepartment of Fish and Game.

Moreau, Brian, April 5, 2001. Personal communication, Project Manager; AlliancePower.

United States Congress, Office of Technology Assessment. 1990. PhysicalVulnerability of Electric Systems to Natural Disasters and Sabotage, June 1990.

Williams. Weston. 2001. Wholesale Distribution Access – System Impact Study, Letterto Timothy Trewyn, March 30, 2001.

Woulfe, Mary Beth. 2001. personal communication. Biologist; United States Fish andWildlife Service.

Zeiner, D.C. et al, 1990, California’s Wildlife: Volume I, II, III, California Department ofFish and Game, Sacramento California.

Alliance Colton Century Substation 22 April 23, 2001Evaluation Checklist California Energy Commission

STAFF CHECKLIST

The following Emergency Permit Evaluation Checklist is designed to provide an easy-to-follow guide to the application and staff’s analysis of project impacts. Included in theChecklist are the Application Requirements, a determination by staff of whether or notthe material was provided, and the location of the information in the applicant’sdocument. The checklist then shows staff’s analysis of significant issues, any specialconditions needed to resolve those issues, and any required comments or references.

Alliance Colton Century Substation April 23, 2001Evaluation Checklist California Energy Commission

23

ALLIANCE COLTON CENTURY SUBSTATION PROJECTEMERGENCY PERMIT EVALUATION CHECKLIST

CALIFORNIA ENERGY COMMISSION

Application Requirement Y/N Applicationpages

Significant Issues Special Conditions Comments

1 Project Description1.1 Project owner/operator

(Name, title, address, phone)Yes p. 1

1.2 Overview of power plant andlinear facilities

Yes pp. 1-2

1.3 Structure dimensions (sizeand height), plan and profile

Yes p. 2;attachment D

1.4 Full size color photo of thesite and rendering ofproposed facility if available

Yes Attachment D

1.5 Maximum foundation depth,cut and fill quantities

Yes Section 1.5 None None Slab foundations andpier foundations, nomore than 14 feet deep,will rest on a site gradedwith minor balanced cutand fill.

1.6 Conformance with CaliforniaBuilding Code

Yes Section 1.6 None None All engineering designand construction workwill be performed to theapplicable LORS,including the CaliforniaBuilding Code.

1.7 Proposed operation (hoursper year)

Yes pp. 2-3


24



1.8 Expected on-line date Yes p. 3 Project meets theExecutive Order D-28requirement of beingonline by Sept. 30, 2001to qualify for thisemergency permitprocess

1.9 Proposed duration ofoperation (years)

Yes p. 3

1.10 Identify transmissioninterconnection facilities

Yes 1,3 andattachment D

No significant issues See standard condition Adjacent to substation.

1.11 Transmission interconnectionapplication

Yes Attachment E

1.12 “Down-stream” transmissionfacilities, if known

Yes 3, letter fromWes Williamsto TimothyTrewyn dated3/30/01.

No significantdownstream facilities.However, additionalcircuit breakers beyondthose identified in studymay need to bereplaced. Suchreplacement will notcause significantenvironmental impacts.

Circuit breakers shouldbe sized to comply witha short-circuit analysis.

Further studies mayidentify breakers thatwill need to be replaced.

1.13 Fuel interconnection facilities Yes p. 3

1.14 Fuel interconnectionapplication

Yes Attachment E

1.15 Water requirements andtreatment

Yes p. 4

1.16 Water interconnectionfacilities (supply/discharge)

Yes p. 4

April 23, 2001 Alliance Colton Century SubstationCalifornia Energy Commission Evaluation Checklist

25



1.17 Source and quality of watersupply

Yes p. 4,attachment E

1.18 Water supply agreement/proof of water supply

Yes p. 4,attachment E

2 Site Description2.1 Site address (street, city,

county)Yes Page 5 None

2.2 Assessor’s parcel number Yes Page 5 None

2.3 Names and addresses of allproperty owners within 500feet of the project site orrelated facilities in both hardcopy and electronic mailmerge format.

Yes Page 5 refersto attachmentF.

None

2.4 Existing site use Yes Page 5 Portions of the site havenot been previouslydeveloped, althoughevidence of humandisturbance is present.

See potential impactsanalysis in Section 8,Biological Resources,and Section 13, CulturalResources.

2.5 Existing site characteristics(paved, graded, etc.)

Yes Page 5 andattachment D.

Portions of the site havenot been previouslydeveloped, althoughevidence of humandisturbance is present.

See potential impactsanalysis in Section 8,Biological Resources,and Section 13, CulturalResources.

2.6 Layout of site (include plotplan)


Location of laydownarea not clearlyidentified.

See text.


26



2.7 Zoning and general plandesignations of site andlinear facilities

Yes Page 6 None

2.8 Ownership of site (Name,address, phone)

Yes Page 6 None

2.9 Status of site control Yes Page 6 andattachment G.

None

2.10 Equipment laydown area –size and location

Y Page 6 Location of laydownarea not clearlyidentified at this time.

See text.

3 Construction Description3.1 Construction schedule Yes p. 7, April 4

supplementalletter

3.2 Workforce requirements(peak, average)

Yes p. 7, April 4supplementalletter

4 Power Purchase Contract(DWR, ISO, other)

4.1 Status of negotiations andexpected signing date

Yes p. 8 Final contractnegotiations betweenDWR and Alliance inprogress.

5 Air Emissions5.1 Nearest monitoring station

(location, distance)Yes p. 9


27



5.2 Provide complete selfcertification air permitchecklist

Yes Attachment B,revised inMarch 20supplement

5.3 Provide complete air permitapplication

Yes Attachment I,revised inMarch 20supplement

5.4 Status of air permitapplication with air district

Yes pp. 9-10 Condition AIR-2requires the projectowner to comply withthe final permitapproved by the airdistrict

South Coast AQMDissued a notice of theirdraft permit on March29, starting a 30-daypublic comment period.The final permit isexpected to be issuedshortly after the end ofthe comment period.The notice is included inthis report as App. A,and the draft permit isincluded as App. B.

5.5 Status of offsets and/ormitigation fees, as required

Yes p. 10

6 Noise6.1 Local noise requirements Yes Page 11 None

6.2 Nearest sensitive receptor(type, distance)

Yes Page 11 None


28



6.3 Project noise level at nearestproperty line

Yes Page 11 Project noise levels atthe property line wouldexceed allowable noisestandards.

The Colton PlanningCommission approved aMajor Variance on April11, 2001 to allow theproject to exceed noiselimitations.

6.4 Proposed mitigation ifrequired

Yes Page 11 None

7 Hazardous Materials7.1 Type and volume of

hazardous materials on-siteY Page 12,

April 4supplementalletter

No No No

7.2 Storage facilities andcontainment

Y Page 12,April 4supplementalletter

No No No

8 Biological resources8.1 Legally protected species*

and their habitat on site,adjacent to site and alongright of way for linear facilities(*threatened or endangeredspecies on State or federallists, State fully protectedspecies)

Y Page 13,Attachment K

No biological surveyswere conducted at thesite or along the linearfacilities.

Bio-7Bio-8Bio-9

No surveys were done,however, the area ishighly disturbed andhabitat required is notpresent.


29



8.2 Designated critical habitat onsite or adjacent to site(wetlands, vernal pools,riparian habitat, preserves)


The Santa Ana River isadjacent to the site.

Bio-10 Habitat will be avoidedduring construction andoperation of the facility.

8.3 Proposed mitigation asrequired


Additional lighting Bio-11 CDFG is requiringlighting to be focusedaway from habitat.

9 Land Use9.1 Local land use restrictions

(height, use, etc.)Yes Page 14 None The Colton Planning

Commission approved aMajor Variance on April11, 2001 to allow theproject to exceed hieghtand noise limitations.

9.2 Use of adjacent parcels(include map)


None

9.3 Ownership of adjacentparcels – site and linears

Yes Page 14 andattachment F.

None

9.4 Demographics of censustract where project is located(most current available)

Yes Attachment F. None

10 Public Services10.1 Ability to serve letter from

Fire DistrictYes Attachment L

10.2 Nearest fire station Yes p. 15


30



11 Traffic and Transportation11.1 Level of Service (LOS)

measurements onsurrounding roads – a.m. andp.m. peaks

Yes Page 16 None 24-hour counts suppliedby applicant. Furtherinformation obtainedfrom the City of ColtonDepartment of PublicWorks.

11.2 Traffic Control Plan for roadsduring construction period

Yes Pages 16 None

11.3 Traffic impact of linear facilityconstruction

Yes Page 16 None

11.4 Equipment transport route Yes Page 16-17 None

11.5 Parking requirements –workforce and equipment

Yes Page 17 Location of laydownarea not clearlyidentified.

See text.

12 Soil and Water Resources12.1 Wastewater volume, quality,

treatmentY Page 18 The facility will have no

waste water.

12.2 Status of permits forwastewater discharge or draftpermit (WDR/NPDES)

Y Page 18 Not required for siteswith less than 5 acres ofdisturbance and nowaste water.

12.3 Draft Erosion Prevention andSedimentation Control Planor Mitigation Strategy

Y Page 18 Addition of non-nativeseeds in straw balesand wattles used inerosion prevention.

Soil&water-5


31



12.4 Spill Prevention/WaterQuality Protection Plans

Y Attachment MPage 3

Storm water runoff fromfacility is not routed to aseparation sump.

Soil&water-6 SWPPP is needed foroperation andconstruction.

13 Cultural Resources13.1 Identification of known

historic/prehistoric sitesY Page 19 None None None


Y Page 19 None Standard ConditionCUL-1 will not apply.Standard ConditionCUL-2 will apply to thesubstation, expansionarea, and the naturalgas lateral extension.

It is critical to require amonitor duringexcavation along theproposed natural gaslateral extension due tothe potential forencountering culturalremains.

14 Paleontological Resources14.1 Identification of known

paleontologic sitesY Page 20 None None The applicant has yet to

submit a copy of theexiting paleontologicalresources review resultsfor the substation.


Y Page 20 None None None.

15 Visual resources15.1 Plan for landscaping and

screening to meet localrequirements

Yes Page 21 None The City of Colton doesnot require additionallandscaping orscreening for theproject.


32



15.2 Full size color photo of thesite and rendering ofproposed facility with anyproposed visual mitigation ifavailable

Yes Attachment D. None The City of Colton doesnot require visualmitigation for theproject.

16 Transmission SystemEngineering

16.1 Conformance with Title 8,High Voltage ElectricalSafety Orders, CPUCGeneral Order 95 (or NESC),CPUC Rule 21, PTOInterconnectionRequirements, and NationalElectric Code

Yes Page 22 None

April 23, 2001 33 Alliance Colton Century Substation ProjectCalifornia Energy Commission Compliance Plan

ALLIANCE COLTON CENTURY SUBSTATION PROJECTGENERAL CONDITIONS INCLUDING COMPLIANCE

MONITORING AND CLOSURE PLAN

INTRODUCTION

General conditions (and the Compliance Plan) have been established as required byPublic Resources Code section 25532. The plan provides a means for assuring that thefacility is constructed, operated and closed in accordance with applicable environmentaland public health and safety laws, ordinances, regulations, and standards, and withconditions of certification as approved by the California Energy Commission (EnergyCommission).

The Compliance Plan is comprised of general conditions and technical (environmentaland engineering) conditions as follows:

• General conditions that set forth the duties and responsibilities of the ComplianceProject Manager (CPM), the project owner, and delegate agencies; the requirementsfor handling confidential information and maintaining the compliance record;procedures for settling disputes and making post-certification changes;administrative procedures to verify the compliance status; and requirements forfacility closure plans.

• Specific conditions for each technical area contain the measures required to mitigatepotential adverse impacts associated with construction, operation and closure to aninsignificant level. Specific conditions may also include a verification provision thatdescribes the method of verifying that the condition has been satisfied.

DEFINITIONSTo ensure consistency, continuity and efficiency, the following terms, as defined, applyto all technical areas, including Conditions of Certification:

SITE MOBILIZATION

Moving trailers and related equipment onto the site, usually accompanied by minorground disturbance, grading for the trailers and limited vehicle parking, trenching forutilities, installing utilities, grading for an access corridor, and other related activities.Ground disturbance, grading, etc. for site mobilization are limited to the portion of thesite necessary for placing the trailers and providing access and parking for theoccupants. Site mobilization is for temporary facilities and is therefore not consideredconstruction.

Alliance Colton Century Substation 34 April 23, 2001Compliance Plan California Energy Commission

GROUND DISTURBANCE

Onsite activity that results in the removal of soil or vegetation, boring, trenching oralteration of the site surface. This does not include driving or parking a passengervehicle, pickup truck, or other light vehicle, or walking on the site.

GRADING

Onsite activity conducted with earth-moving equipment that results in alteration of thetopographical features of the site such as leveling, removal of hills or high spots, ormoving of soil from one area to another.

CONSTRUCTION

[From Public Resources Code section 25105.] Onsite work to install permanentequipment or structures for any facility. Construction does not include the following:a. The installation of environmental monitoring equipment.b. A soil or geological investigation.c. A topographical survey.d. Any other study or investigation to determine the environmental acceptability or

feasibility of the use of the site for any particular facility.e. Any work to provide access to the site for any of the purposes specified in a, b, c, or

d.

TERM OF CERTIFICATION

Certification is for the life of the project if at the end of the power purchase agreementwith either the California Independent System Operator or the California Department ofWater Resources the project owner can verify that the project meets the followingcontinuation criteria:

• the project is permanent, rather than temporary or mobile in nature;

• the project owner demonstrates site control;

• the project owner has secured permanent emission reduction credits (ERCs)approved by SCAQMD and the California Air Resources Board (CARB) to fully offsetproject emissions for its projected run hours prior to expiration of any temporaryERCs obtained from CARB or SCAQMD;

• the project is in current compliance with all Energy Commission permit conditionsspecified in the final decision;

• the project is in current compliance with all conditions contained in the Permit toConstruct and Permit to Operate issued by SCAQMD for the project; and

• the project continues to meet BACT requirements under SCAQMD and CARBrequirements.


The project shall expire if these continuation criteria are not met. At least six monthsprior to the expiration of the power purchase agreement with the Department of WaterResources (DWR), or prior to the expiration of the Summer Reliability Agreement withthe California Independent System Operator if no DWR contract is signed, the projectowner shall provide verification that these conditions have been meet.In addition, the project owner shall submit a report after completion of the first threeyears in operation, as described below.

COMPLIANCE PROJECT MANAGER (CPM) RESPONSIBILITIESA CPM will oversee the compliance monitoring and shall be responsible for:1. ensuring that the design, construction, operation, and closure of the project facilities

is in compliance with the terms and conditions of the Commission Decision;2. resolving complaints;

3. processing post-certification changes to the conditions of certification, projectdescription, and ownership or operational control;

4. documenting and tracking compliance filings; and,

5. Ensuring that the compliance files are maintained and accessible.

The CPM is the contact person for the Energy Commission and will consult withappropriate responsible agencies and the Energy Commission when handling disputes,complaints and amendments.

The Commission has established a toll free compliance telephone number of 1-800-858-0784 for the public to contact the Commission about power plant construction oroperation-related questions, complaints or concerns.

Pre-Construction and Pre-Operation Compliance Meeting

The CPM may schedule pre-construction and pre-operation compliance meetings priorto the projected start-dates of construction, plant operation, or both. The purpose ofthese meetings will be to assemble both the Energy Commission’s and the projectowner’s technical staff to review the status of all pre-construction or pre-operationrequirements contained in the Energy Commission’s conditions of certification toconfirm that they have been met, or if they have not been met, to ensure that the properaction is taken.

Energy Com mission Record

The Energy Commission shall maintain as a public record, in either the Compliance fileor Docket file, for the life of the project (or other period as required):1. All documents demonstrating compliance with any legal requirements relating to the

construction and operation of the facility;


2. All complaints of noncompliance filed with the Energy Commission; and,

3. All petitions for project modifications and the resulting staff or Energy Commissionaction taken.

PROJECT OWNER RESPONSIBILITIESIt is the responsibility of the project owner to ensure that the general complianceconditions and the conditions of certification are satisfied. The general complianceconditions regarding post-certification changes specify measures that the project ownermust take when requesting changes in the project design, compliance conditions, orownership. Failure to comply with any of the conditions of certification or the generalcompliance conditions may result in reopening of the case and revocation of EnergyCommission certification, an administrative fine, or other action as appropriate.

Access

The CPM, responsible Energy Commission staff, and delegate agencies or consultants,shall be guaranteed and granted unrestricted access to the power plant site, relatedfacilities, project-related staff, and the records maintained on site, for the purpose ofconducting audits, surveys, inspections, or general site visits. Although the CPM willnormally schedule site visits on dates and times agreeable to the project owner, theCPM reserves the right to make unannounced visits at any time.

Compliance Record

The project owner shall maintain project files on-site or at an alternative site approvedby the CPM, for the life of the project. The files shall contain copies of all “as-built”drawings, all documents submitted as verification for conditions, and all other project-related documents for the life of the project, unless a lesser period is specified by theconditions of certification.Energy Commission staff and delegate agencies shall, upon request to the projectowner, be given unrestricted access to the files.

Compliance Reporting

The project owner shall submit status reports to the CPM every two weeks indicating itsprogress in meeting milestones for procuring necessary project components and allrequired approvals for construction and operation of the facility by August 1, 2001. Thefirst of these reports will be due two weeks after certification of the project by the EnergyCommission.

Start of Operations

The Alliance Colton Drews Substation Project (Drews) shall be on-line by the expecteddate of operation of August 1, 2001, or the earliest possible date thereafter, but no laterthan September 30, 2001. If Drews is not operational by September 30, 2001, theEnergy Commission will conduct a hearing to determine the cause of the delay and


consider what sanctions, if any, are appropriate. If the Energy Commission finds thatthe project owner failed to proceed with due diligence to have Drews in operation bySeptember 30, 2001, the Energy Commission will set a specific date by which Drewsmust be brought on-line as a condition precedent to continue the certification.

Three-Year Review

No later than 15 days after completion of the first three years in operation, the projectowner shall submit to the Energy Commission a report of operations that includes areview of Drew’s compliance with the terms and conditions of certification, the numberof hours in operation, and the demand for power from the facility during the three yearperiod.

Compliance Verifications

Condition of certification may have appropriate means of “verification”. The verificationdescribes the Energy Commission’s procedure(s) to ensure post-certificationcompliance with adopted conditions. The verification procedures, unlike the conditions,may be modified, as necessary by the CPM, without full Energy Commission approval.

Verification of compliance with the conditions of certification can be accomplished by:1. reporting on the work done and providing the pertinent documentation in monthly

and/or annual compliance reports filed by the project owner or authorized agent asrequired by the specific conditions of certification;

2. appropriate letters from delegate agencies verifying compliance;3. Energy Commission staff audits of project records; and/or4. Energy Commission staff inspections of mitigation and/or other evidence of

mitigation.

A cover letter from the project owner or authorized agent is required for all compliancesubmittals and correspondence pertaining to compliance matters. The cover lettersubject line shall identify the involved condition(s) of certification by condition numberand include a brief description of the subject of the submittal.

All submittals shall be addressed as follows:

Compliance Project ManagerCalifornia Energy Commission1516 Ninth Street (MS-2000)Sacramento, CA 95814

Confidential Information

Any information, which the project owner deems confidential shall be submitted to theEnergy Commission’s Docket with an application for confidentiality pursuant to Title 20,


California Code of Regulations, section 2505(a). Any information, which is determinedto be confidential, shall be kept confidential as provided for in Title 20, California Codeof Regulations, section 2501 et. seq.

Reporting of Complaints, Notices, and Citations

Prior to the start of construction, the project owner must send a letter to property ownersliving within 500 feet of the project notifying them of a telephone number to contactproject representatives with questions, complaints or concerns. If the telephone is notstaffed 24 hours per day, it shall include automatic answering, with date and time stamprecording. The telephone number shall be posted at the project site and easily visible topassersby during construction and operation.

The project owner shall report and provide copies of all complaint forms, notices ofviolation, notices of fines, official warnings, and citations, within 10 days of receipt, tothe CPM.

GENERAL CONDITIONS FOR FACILITY CLOSUREIn order to ensure that a planned facility closure does not create adverse impacts, plantclosure must be consistent with all applicable laws, ordinances, regulations, standards(LORS), and local/regional plans in existence at the time of closure. To ensureadequate review of a planned project closure, the project owner shall submit a proposedfacility closure plan to the Energy Commission for review and approval at least threemonths prior to commencement of closure activities (or other period of time agreed toby the CPM).

DELEGATE AGENCIESTo the extent permitted by law, the Energy Commission may delegate authority forcompliance verification and enforcement to various state and local agencies that haveexpertise in subject areas where specific requirements have been established as acondition of certification. If a delegate agency does not participate in this program, theEnergy Commission staff will establish an alternative method of verification andenforcement. Energy Commission staff reserves the right to independently verifycompliance.

In performing construction and operation monitoring of the project, the EnergyCommission staff acts as, and has the authority of, the Chief Building Official (CBO).The Commission staff retains this authority when delegating to a local CBO. Delegationof authority for compliance verification includes the authority for enforcing codes, theresponsibility for code interpretation where required, and the authority to use discretion,as necessary, in implementing the various codes and standards.

ENFORCEMENTThe Energy Commission’s legal authority to enforce the terms and conditions of itsDecision is specified in Public Resources Code sections 25534 and 25900. The Energy


Commission may amend or revoke the certification for any facility, and may impose acivil penalty for any significant failure to comply with the terms or conditions of theCommission Decision. The specific action and amount of any fines the Commissionmay impose would take into account the specific circumstances of the incident(s). Thiswould include such factors as the previous compliance history, whether the cause of theincident involves willful disregard of LORS, inadvertence, unforeseeable events, andother factors the Commission may consider.

Moreover, to ensure compliance with the terms and conditions of certification andapplicable laws, ordinances, regulations, and standards, delegate agencies areauthorized to take any action allowed by law in accordance with their statutory authority,regulations, and administrative procedures.

NONCOMPLIANCE COMPLAINT PROCEDURESAny person or agency may file a complaint alleging noncompliance with the conditionsof certification. Such a complaint will be subject to review by the Energy Commissionpursuant to Title 20, California Code of Regulations, section 1230 et. seq., but in manyinstances the noncompliance can be resolved by using the informal dispute resolutionprocess. Both the informal and formal complaint procedures, as described in currentState law and regulations, are described below. They shall be followed unlesssuperseded by current law or regulations.

INFORMAL DISPUTE RESOLUTION PROCEDUREThe following procedure is designed to informally resolve disputes concerninginterpretation of compliance with the requirements of this compliance plan. The projectowner, the Energy Commission, or any other party, including members of the public,may initiate this procedure for resolving a dispute. Disputes may pertain to actions ordecisions made by any party including the Energy Commission’s delegate agents.

This procedure may precede the more formal complaint and investigation procedurespecified in Title 20, California Code of Regulations, section 1230 et. seq., but is notintended to be a substitute for, or prerequisite to it. This informal procedure may not beused to change the terms and conditions of certification as approved by the EnergyCommission, although the agreed upon resolution may result in a project ownerproposing an amendment.The procedure encourages all parties involved in a dispute to discuss the matter and toreach an agreement resolving the dispute. If a dispute cannot be resolved, then thematter must be referred to the full Energy Commission for consideration via thecomplaint and investigation process. The procedure for informal dispute resolution is asfollows:

Request for Informal Investigation

Any individual, group, or agency may request the Energy Commission to conduct aninformal investigation of alleged noncompliance with the Energy Commission’s terms


and conditions of certification. All requests for informal investigations shall be made tothe designated CPM.

Upon receipt of a request for informal investigation, the CPM shall promptly notify theproject owner of the allegation by telephone and letter. All known and relevantinformation of the alleged noncompliance shall be provided to the project owner and tothe Energy Commission staff. The CPM will evaluate the request and the information todetermine if further investigation is necessary. If the CPM finds that further investigationis necessary, the project owner will be asked to promptly investigate the matter andwithin seven (7) working days of the CPM’s request, provide a written report of theresults of the investigation, including corrective measures proposed or undertaken, tothe CPM. Depending on the urgency of the noncompliance matter, the CPM mayconduct a site visit and/or request the project owner to provide an initial report, withinforty-eight (48) hours, followed by a written report filed within seven (7) days.

Request for Informal Meeting

In the event that either the party requesting an investigation or the Energy Commissionstaff is not satisfied with the project owner’s report, investigation of the event, orcorrective measures undertaken, either party may submit a written request to the CPMfor a meeting with the project owner. Such request shall be made within fourteen (14)days of the project owner’s filing of its written report. Upon receipt of such a request,the CPM shall:1. Immediately schedule a meeting with the requesting party and the project owner, to

be held at a mutually convenient time and place and secure the attendance ofappropriate Energy Commission staff and staff of any other agency with expertise inthe subject area of concern as necessary;

2. Conduct such meeting in an informal and objective manner; and,3. After the conclusion of such a meeting, promptly prepare and distribute copies to all

in attendance and to the project file, a summary memorandum which fairly andaccurately identifies the positions of all parties and any conclusions reached.

FORMAL DISPUTE RESOLUTION PROCEDURE-COMPLAINTS ANDINVESTIGATIONSIf either the project owner, Energy Commission staff, or the party requesting aninvestigation is not satisfied with the results of the informal dispute resolution process,such party may file a complaint or a request for an investigation with the EnergyCommission’s General Counsel. Disputes may pertain to actions or decisions made byany party including the Energy Commission’s delegate agents. Requirements forcomplaint filings and a description of how complaints are processed are in Title 20,California Code of Regulations, section 1230 et. seq.

The Chairman, upon receipt of a written request stating the basis of the dispute, maygrant a hearing on the matter, consistent with the requirements of noticing provisions.The Commission shall have the authority to consider all relevant facts involved and


make any appropriate orders consistent with its jurisdiction (Title 20, California Code ofRegulations, sections 1232 - 1236).

POST CERTIFICATION CHANGES TO THE COMMISSION DECISION:AMENDMENTS, INSIGNIFICANT PROJECT CHANGESThe project owner must petition the Energy Commission, pursuant to Title 20, CaliforniaCode of Regulations, section 1769, to 1) delete or change a condition of certification; 2)modify the project design or operational requirements; and 3) transfer ownership oroperational control of the facility.

A petition is required for amendments and for insignificant project changes. In allcases, the petition or letter requesting a change should be submitted to theCommission’s Docket in accordance with Title 20, California Code of Regulations,section 1209. The criteria that determine which type of change process applies areexplained below.

EXECUTIVE ORDERExecutive Order D-25-01 issued by the Governor of the State of California, whichaccelerates processing of certain project modifications, will be applied to all qualifyingproject modifications requested until December 31, 2001.

AMENDMENTA proposed project modification will be processed as an amendment if it involves achange to a condition of certification, an ownership or operator change, or a potentialsignificant environmental impact.

INSIGNIFICANT PROJECT CHANGEThe proposed modification will be processed as an insignificant project change if it doesnot require changing the language in a condition of certification, have a potential forsignificant environmental impact, and cause the project to violate laws, ordinances,regulations or standards.

VERIFICATION CHANGEChanges to condition verifications require CPM approval and may require either awritten or oral request by the project owner. The CPM will provide written authorizationof verification changes.

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Alliance Colton Century Substation 42 April 23, 2001Conditions of Certification California Energy Commission

TECHNICAL AREA CONDITIONS OF CERTIFICATION

NOISE

Standard Condition of Certification NOISE-1 is not required because the City of Coltonapproved a Major Variance allowing the project to exceed the local noise standards.

NOISE-2 Prior to the start of rough grading, the project owner shall notify all residentswithin one mile of the site of the start of construction and will provide acomplaint resolution process.

Verification: The project owner shall provide the CPM with a statement, attestingthat the above notification has been performed.

NOISE-3 Throughout the construction and operation of the project, the project ownershall document, investigate, evaluate, and attempt to resolve all projectrelated noise complaints.

Verification: Within 30 days of receiving a noise complaint, the project owner shallfile a copy of the Noise Complaint Resolution Form, or similar instrument approved bythe CPM, with the County Environmental Health Department, and with the CPM,documenting the resolution of the complaint. If mitigation is required to resolve acomplaint, and the complaint is not resolved within a 30-day period, the project ownershall submit an updated Noise Complaint Resolution Form when the mitigation is finallyimplemented.

NOISE-4 Night construction activities may be authorized by the CPM if they areconsistent with local noise ordinances. Night construction, or specific nightconstruction activities may be disallowed by the CPM if it results in significantimpact to the surrounding community.

Verification: Noise monitoring and surveys may be conducted if complaints arereported by residence in the surrounding area of the project site.

HAZARDOUS MATERIALS MANAGEMENTHAZ-1 The project owner shall not use any hazardous material in reportable

quantities except those identified by type and quantity in the applicationunless approved by the CPM.

Verification: The project owner shall provide in the Annual Compliance Report a listof hazardous materials used at the facility in reportable quantities.

April 23, 2001 43 Alliance Colton Century SubstationCalifornia Energy Commission Conditions of Certification

HAZ-2 The project owner shall submit both the Business Plan and RiskManagement Plan to the CPM for review and comment, and shall alsosubmit these plans and/or procedures to the County Fire Department forapproval.

Verification: 30 days (or a CPM-approved alternative timeframe) prior to the initialdelivery of any hazardous materials in reportable quantities to the facility, the projectowner shall submit the Business and Risk Management Plan to the CPM for review andcomment. At the same time, the project owner shall submit these plans to the CountyFire Department for approval. The project owner shall also submit evidence to the CPMthat the local Fire Department approved of these plans, when available.

WASTEWASTE-1 The project owner shall obtain a hazardous waste generator identification

number from the Department of Toxic Substances Control prior to producingany hazardous waste.

Verification: The project owner shall keep its copy of the identification number onfile at the project site.

WASTE-2 The project owner shall have an environmental professional available forconsultation during soil excavation and grading activities. The environmentalprofessional shall be given full authority to oversee any earth movingactivities that have the potential to disturb contaminated soil. Theenvironmental professional shall meet the qualifications of such as definedby the American Society for Testing and Materials designation E 1527-97Standard Practice for Phase I Environmental Site Assessments.

Verification: If potentially contaminated soil is unearthed during excavation at eitherthe proposed site or linear facilities, the environmental professional shall inspect thesite, determine the need for sampling to confirm the nature and extent of contamination,and make a recommended course of action. The environmental professional shall havethe authority to suspend construction activity at that location. If, in the opinion of theenvironmental professional, remediation is to be required, the project owner shallconsult with the CPM and a decision will be made by the CPM within 24 hours as tohow to proceed.

BIOLOGICALBIO-1 The project permitted under this emergency process will avoid all impacts to

legally protected species and their habitat on site, adjacent to the site andalong the right of way for linear facilities.

BIO-2 The project permitted under this emergency process will avoid all impacts todesignated critical habitat (wetlands, vernal pools, riparian habitat,preserves) on site or adjacent to the site.


BIO-3 The project permitted under this emergency process will avoid all impacts tolocally designated sensitive species and protected areas.

BIO-4 The project permitted under this emergency process will reduce risk of largebird electrocution by electric transmission lines and any interconnectionbetween structures, substations and transmission lines by using constructionmethods identified in “Suggested Practices for Raptor Protection on PowerLines: The State of the Art in 1996” (APLIC 1996).

BIO-5 The Designated Biologist, a person knowledgeable of the local/regionalbiological resources and the compliance project manager (CPM) will haveaccess to the site and linear rights-of-way at any time prior to and duringconstruction and have the authority to halt construction in an area necessaryto protect a sensitive biological resource at any time.

Verification: If the Designated Biologist halts construction, the action will bereported immediately to the CPM along with the recommended implementation actionsto resolve the situation. If listed species are encountered during construction additionalagency consultation may be required. Throughout construction, the project owner shallreport on items one through six above if identified resources are found or impacted.

BIO-6 Upon decommissioning the site, the biological resource values will bereestablished at pre-construction levels or better.

BIO-7 Ground breaking activities associated with the facility and the gas pipelineshall not begin until the CPM approved Designated Biologist is available tobe on site.

Protocol: The Designated Biologist must meet the following minimumqualifications:

a. A Bachelor’s Degree in biological sciences, zoology, ecology, botany, orrelated field;

b. At least three years of experience in field biology or current certification ofa nationally recognized biological society;

c. At least one year of experience with biological resources found in or nearthe project site; or

d. Or an ability to demonstrate to the satisfaction of the CPM theappropriate education and experience for the biological resources tasksthat must be addressed during project construction and operation.

Verification: Prior to ground disturbance activities, the project owner shall submit forthe CPM for approval, the name, qualifications, address, and telephone number of theindividual selected by the project owner as the Designated Biologist.


BIO-8 A qualified biologist, with knowledge of listed plant and animal species in thisarea, shall survey the site for listed species prior to ground breaking activitiesassociated with the facility including the gas pipeline installation. Sensitiveareas shall be flagged for avoidance. If any listed species are encountered,consultation with U.S. Fish and Wildlife Service and California Department ofFish and Game will be required.

Protocol: The biologist shall survey undeveloped areas that are to bedisturbed, including the facility expansion, equipment laydown, and the gaspipeline route.

Verification: The biologist shall provide written confirmation to the CPM of thesurvey results with locations of sensitive areas and listed species presence or absence.

BIO-9 The project owner’s Construction Manager shall act on the advice of theDesignated Biologist (DB) to ensure conformance with the BiologicalResources Conditions of Certification.

Protocol: The project owner’s Construction Manager shall halt, if directedby the DB, all construction activities to assure that potentially significantbiological resource impacts are avoided.

Verification: Immediately upon the DB notification to halt construction, the projectowner shall notify the CPM of the circumstances and actions being taken to resolve theproblem.

BIO-10 During all construction activities associated with the Century facility,equipment laydown shall be within CPM approved areas.

Verification: The CPM will approve parking areas and equipment laydown.

BIO-11 If additional lighting is to be installed at the facility, it shall be limited to insidethe walls of the facility and be screened from the outside habitat.

Verification: Lighting shall be focused into the facility and not the surroundinghabitat. If additional lighting is required by the facility, the plans shall be approved bythe CPM prior to installation.

LAND USELAND–1 The project permitted under this emergency process will conform to all local,

state and federal land use requirements, including, where applicable,general plan policies, zoning regulations, local development standards,easement requirements, and encroachment permits.


Verification: Prior to start of construction or at a later time approved by the CPM,the project owner will submit to the CPM documentation verifying compliance with theabove referenced land use requirements.

TRAFFIC AND TRANSPORTATIONTRANS-1 The project permitted under this emergency process shall comply with

Caltrans and City/County limitations on vehicle sizes and weights. Inaddition, the project owner or its contractor shall obtain necessarytransportation permits from Caltrans and all relevant jurisdictions for roadwayuse.

Verification: The project owner shall keep copies of any oversize and overweighttransportation permits received at the project site.

TRANS-2 The project permitted under this emergency process shall comply with

Caltrans and City/County limitations for encroachment into public rights-of-way and shall obtain necessary encroachment permits from Caltrans and allrelevant jurisdictions.

Verification: The project owner shall keep copies of any encroachment permitsreceived at the project site.

TRANS-3 The project permitted under this emergency process shall ensure that

permits or licenses are secured from the California Highway Patrol andCaltrans for the transport of hazardous materials.

Verification: The project owner shall keep copies of all permits/licenses acquired bythe project owner and subcontractors concerning the transport of hazardous substancesat the project site.

TRANS-4 Following completion of construction of the power plant and all relatedfacilities, the project owner shall return all roadways to original or as nearoriginal condition as possible.

SOIL & WATER RESOURCESSOIL&WATER-1 Prior to ground disturbance, the project owner shall obtain CPM

approval of a Storm Water Pollution Prevention Plan (SWPPP) as requiredunder the General Storm Water Construction Activity Permit for the project.

Verification: Prior to ground disturbance, the project owner will submit a copy of theStorm Water Pollution Prevention Plan for the project to the CPM.

SOIL&WATER-2 Prior to ground disturbance, the project owner shall obtain CPMapproval of an Erosion Prevention and Sedimentation Control Plan.


Verification: The Erosion Control and Storm Water Management Plan for theproject shall be submitted to the CPM prior to ground disturbance.

SOIL&WATER-3 Prior to site mobilization, the project owner shall submit to the CPM,a copy of a valid water service agreement for water supplies for the projectfrom an authorized water purveyor, or a copy of a valid well permit for theproject from the appropriate licensing agency.

Verification: A copy of the water service agreement or well permit shall besubmitted to the CPM prior to site mobilization.

Standard Condition of Certification SOIL&WATER-4 is not required because the facilityis less than five acres and is not anticipated to have any discharge.

SOIL& WATER-5 All BMP’s such as straw wattles and straw bales shall be certifiedweed free.

SOIL&WATER-6 Prior to operation of the facility, the project owner shall obtain CPMapproval of a Storm Water Pollution Prevention Plan (SWPPP) for operationof the facility.

Verification: Prior to operation of the facility, the project owner will submit a copy ofthe Storm Water Pollution Prevention Plan for the facility to the CPM. This may includean oil/water separator or some other method to protect water quality.

CULTURALFor this project standard condition CUL-1 does not apply due to slight possibility thatcultural resources could be encountered in project area.

CUL-2 The project has been determined to have the potential to adversely affectsignificant cultural resources and the project owner shall ensure thecompletion of the following actions/activities:1. Provide a qualified Cultural Resource Specialist (CRS) who will have

access to the site and linear rights-of-way at any time prior to and duringground disturbance.

2. The CRS will provide training to appropriate construction personnel at thesite, will install avoidance measures (as necessary), and will be presentduring appropriate ground disturbing activities. The cultural specialist hasthe authority to halt construction at a location if a significant culturalresource is found. If resources are discovered and the cultural specialistis not present, the project owner will halt construction at that location andwill contact the specialist immediately. The specialist will consult with theCompliance Project Manager (CPM) and a decision will be made by theCPM within 24-hours as to how to proceed.


3. If suspected human remains are discovered during construction, all workwill stop immediately within a radius of 100 feet (30 meters) of thediscovery and the San Bernardino County Coroner’s Office will be notifiedwithin 24 hours. If the remains are identified to be Native American, theCoroner’s Office will contact the Native American Heritage Commission(NAHC) who will identify the Most Likely Descendant (MLD). The MLDwill be notified and will determine the most appropriate disposition of theremains and any associated artifacts.

4. The project owner shall allow time for the CRS to recover significantresource finds, and pay all fees necessary to curate recovered significantresources.

Verification: Throughout construction, the project owner shall inform the CPMconcerning any substantive activity related to items 1 through 4 above. The CRS willmaintain a daily log of monitoring activities and any cultural resource finds. Shouldcuration be necessary, the project owner shall inform the CPM as to how and where theresources were curated.

VISUALVIS-1 Project structures treated during manufacture and all structures treated in the

field, that are visible to the public, shall be painted in a neutral colorconsistent with the surrounding environment.

Verification: Prior to painting exposed services, the project owner shall identify theselected color for CPM approval.

VIS-2 The project owner shall design and install all lighting such that light bulbs andreflectors are not visible from public viewing areas and illumination of thevicinity and the nighttime sky is minimized. Lighting must also be installedconsistent with any local requirements.

Standard Condition of Certification VIS-3 is not required because the City of Colton isnot requiring additional landscaping or screening for the project.

FACILITY DESIGNGEN-1 The project owner shall design, construct and inspect the project in

accordance with the 1998 California Building Code (CBC) and all otherapplicable LORS in effect at the time initial design plans are submitted to theCBO for review and approval.

Verification: Within 30 days (or a lesser number of days mutually agreed to by theproject owner and the CBO) after receipt of the Certificate of Occupancy, the projectowner shall submit to the CPM a statement of verification, signed by the responsibledesign engineer, attesting that all designs, construction, installation and inspectionrequirements of the applicable LORS and the Energy Commission’s Decision havebeen met. The project owner shall provide the CPM a copy of the Certificate of


Occupancy within 30 days of receipt from the CBO [1998 CBC, Section 109 –Certificate of Occupancy.] The project owner shall keep copies of plan checks andCBO inspection approvals at the project site.

PALEONTOLOGICAL RESOURCESStandard Condition of Certification PALEO-1 has not been included due to slightpossibility that paleontological resources could be encountered in project area.

PALEO-2 The project has been determined to have the potential to adversely affectsignificant paleontological resources and the project owner shall ensure thecompletion of the following actions/activities:

1. Provide a paleontological specialist who will have access to the site andlinear rights-of-way at any time prior to and during ground disturbance.

2. The paleontological specialist will provide training to appropriateconstruction personnel at the site, will install avoidance measures (asnecessary), and will be present during appropriate ground disturbingactivities. The cultural specialist has the authority to halt construction ata location if a significant paleontological resource is found. If resourcesare discovered and the specialist is not present, the project owner willhalt construction at that location and will contact the specialistimmediately. The specialist will consult with the CPM and a decisionwill be made by the CPM within 24-hours as to how to proceed.

3. The project owner shall allow time for the paleontological specialist toprotect significant resource finds, and pay all fees necessary to protectany significant resources.

Verification: Throughout construction, the project owner shall inform the CPMconcerning any substantive activity related to items 1 through 3 above.

TRANSMISSION SYSTEM ENGINEERING, SAFETY AND RELIABILITYTSE-1 The project owner shall ensure that the design, construction and operation of

the proposed transmission facilities will conform to requirements listed below:1. The power plant switchyard, outlet line and termination shall meet or

exceed the electrical, mechanical, civil and structural requirements ofCPUC General Order 95, CPUC Rule 21, Title 8, California Code ofRegulations (CCR), Articles 35, 36 and 37 of the, “High Voltage ElectricSafety Orders”, Title 8 CCR, Sections 2700-2974, CPUC Decision 93-11-013, Federal Communications Commission Part 15, PublicResources Code 4292-4296, and National Electric Code (NEC).

Verification: Within 15 days after cessation of construction the project owner shallprovide a statement to the CPM from the registered engineer in responsible charge(signed and sealed) that the switchyard and transmission facilities conform to the abovelisted requirements.


WORKER AND FIRE SAFETYWORKER SAFETY-1 The project owner must comply with all requirements in Title

8 of the California Code of Regulations, beginning with Part 450 (8 CCR Part450 et seq).

Verification: The project owner shall submit to the CPM a letter attesting tocompliance with the above and shall report any violations to the CPM.

AIR QUALITYAQ-1 Prior to the commencement of project construction, the project owner shall

prepare a Construction Fugitive Dust Mitigation Plan that will specificallyidentify fugitive dust mitigation measures that will be employed for theconstruction of the project and related facilities.

Protocol: Measures that should be addressed include the following:

• the identification of the employee parking area(s) and surface of theparking area(s);

• the frequency of watering of unpaved roads and disturbed areas;

• the application of chemical dust suppressants;

• the stabilization of storage piles and disturbed areas;

• the use of gravel in high traffic areas;

• the use of paved access aprons;

• the use of posted speed limit signs;

• the use of wheel washing areas prior to large trucks leaving the projectsite;

• the methods that will be used to clean tracked-out mud and dirt from theproject site onto public roads; and

• for any transportation of borrowed fill material, the use of covers onvehicles, wetting of the material, and insuring appropriate freeboard ofmaterial in the vehicles.

Verification: The project owner shall submit to the CPM a letter attesting tocompliance with the above and shall report any violations to the CPM.

AQ-2 The project owner shall comply with the terms and conditions of the Authorityto Construct and the Permit to Operate issued by the South Coast Air QualityManagement District, as modified by any Compliance Orders issued bySCAQMD relating to this project.

Verification: In the event that the air district finds the project to be out of compliancewith the terms and conditions of the Authority to Construct, the project owner shall notify


the CPM of the violation, and the measures taken to return to compliance, within fivedays.

AQ-3 The project owner shall operate Drews in compliance with all Best AvailableControl Technology (BACT) standards imposed by the Air District in itsAuthority to Construct permit, with the exception of an initial period ofoperation if the Air District issues a Compliance Order allowing operation ofthe facility with NOx emissions up to 25 ppm. The length of this initial periodshall be specified in the Compliance Order. Failure to meet these standardswill result in a finding that the project owner is out of compliance with thecertification.


ALLIANCE COLTON CENTURY SUBSTATION PROJECTEMERGENCY PERMIT EVALUATION PREPARATION TEAM

CALIFORNIA ENERGY COMMISSION

Kevin Kennedy ........................................................................................Project Manager

Jim Bartridge .......... Assistant Project Manager, Land Use, Noise, Transportation, Visual

Mary Dyas .............................................................................................. Project Assistant

Jeff Ogata................................................................................................... Legal Counsel

Christopher Meyer ...........................................................................Compliance Manager

Caprice Harper ....................................................................................Cultural Resources

Bob Anderson............................................................................ Paleontologic Resources

Danielle Muir.....................................................................................Biological Resources

Steve Baker................................................................................................Facility Design

Rick Tyler.......................................................................................... Hazardous Materials

Joe Crea.................................................................................. Soil and Water Resources

Mark Hesters ............................................................................Transmission Engineering

April 23, 2001 A-1 Alliance Colton Century SubstationCalifornia Energy Commission Appendix A

APPENDIX A

NOTICE OF INTENT TO ISSUE PERMIT PURSUANT TO AQMD RULES212 AND 3006This notice is to inform you that the South Coast Air Quality Management District(AQMD) has received and reviewed permit applications for two power generationfacilities to be operated by Alliance Colton LLC. The AQMD intends to issue a facilitypermit for each facility at the end of this 30-day public comment and review period andafter the applicant demonstrates full compliance with all requirements.

The AQMD is the air pollution control agency for the four county region includingOrange County and parts of Los Angeles, Riverside and San Bernardino Counties.Anyone wishing to install or modify equipment that could control or be a source of airpollution within this region must first obtain a permit from the AQMD. Under certaincircumstances, before a permit is granted, a public notice, such as this, is prepared bythe AQMD and distributed by the applicant.

The AQMD has evaluated the permit applications listed below for the following twofacilities and determined that it meets all applicable AQMD rules and regulations subjectto the conditions described below:

FACILITY: Alliance Colton, LLC Alliance Colton, LLCDrews Substation Century Substation559 South Pepper Ave. 661 South Cooley Dr.Colton, CA 92324 Colton, CA 92324

CONTACT: Brian O’NeillVice PresidentAlliance Colton, LLC7950 South Lincoln Street, Suite 114Littleton, CO 80122

AQMD APPLICATION NUMBERS

DREWS SUBSTATION

383349 Turbine #1383350 Turbine #2383351 Turbine #3383352 Turbine #4383880 Ammonia storage tank383881 Air pollution control system #1383882 Air pollution control system #2383883 Air pollution control system #3383884 Air pollution control system #4383879 Title V application

Alliance Colton Century Substation A-2 April 23, 2001Appendix A California Energy Commission

CENTURY SUBSTATION

383353 Turbine #1383354 Turbine #2383355 Turbine #3383356 Turbine #4383886 Ammonia storage tank383887 Air pollution control system #1383888 Air pollution control system #2383889 Air pollution control system #3383890 Air pollution control system #4383885 Title V application

PROJECT DESCRIPTIONEach of the two projects consists of four new electric generating gas turbines and theassociated air pollution control equipment. Each turbine has a nominal rating of 10.5megawatts, totaling 42 megawatts for all four turbines at each facility. The two facilitiesare located at Drews substation and Century substation respectively, at the addressesindicated above. Both projects are expected to be operational by September 2001 andto supply electricity to the California electricity grid system and are being permittedpursuant to Governor Gray Davis’ Executive Orders (D-24-01 and D-26-01). Bothfacilities have selected to operate under Regulation XX – RECLAIM for NOx pollutants.The proposed permits to construct will require these turbines to be equipped with airpollution control equipment that will meet the following emission levels: 5ppmv NOx @15%O2, 6 ppmv CO @ 15% O2, and 2 ppmv ROG @ 15% O2. The air pollution controlequipment will consist of either Selective Catalytic Reduction (SCR) with oxidationcatalyst, XONONtm combustor technology, or XONONtm combustor technology withoxidation catalyst. If the SCR is utilized as the air pollution control equipment, ammoniawill be used to react with NOx emissions in the exhaust gases; therefore, an ammoniastorage tank is also being proposed for the SCR control option.

PROJECTED EMISSIONSDue to the critical need for electricity this summer and since the constructionschedule does not allow for full installation of air pollution control equipment prior toSeptember 2001, in implementing the Governor’s Executive Orders, the turbines willinitially for the first few months be operated without air pollution control equipmentand under a Compliance Order that Alliance Colton LLC will obtain from the AQMD.Upon achieving full operating load, the following emissions are expected for eachfacility from the operation of these turbines with and without air pollution controlsystems:

April 23, 2001 A-3 Alliance Colton Century SubstationCalifornia Energy Commission Appendix A

Pollutant Controlled emissionsLbs/day

Uncontrolled emissionslbs/day

Nox 231 1158CO 169 564

VOC 32 32PM10 79 79SOx 41 41NH3 86* 0

* Assuming SCR will be utilized

Emissions from the proposed projects contain pollutants that are considered toxic underAQMD Rule 1401-New Source Review of Toxic Air Contaminants. Therefore, healthrisk assessments were performed for these projects. The health risk assessments usehealth protective assumptions in estimating actual risk to an individual person. Evenassuming this health protective condition, the evaluations show that the maximumindividual cancer risk increases from the projects are less than one-in-one-million.These levels of estimated risk are below the threshold limits established for new ormodified sources.

The projects will not cause or contribute to violations of any state or federalambient air quality standard for any attainment pollutants.

The AQMD will issue the permits to construct for the equipment described aboveafter the applicant demonstrates full compliance with all applicable rules andregulations meeting the following requirements:• Alliance Colton LLC must provide emission offsets, or provide contractual agreement

to provide emission offsets for NOx emissions. Emission offsets will either be in theform of RECLAIM Trading Credits in the total amount of 37,467 pounds for the firstRECLAIM compliance year or be purchased from the State-funded EmissionReduction Credit Bank, established pursuant to the Governor’s Executive Order D-24-01.

• Conduct additional refined modeling to demonstrate compliance with the air qualitystandard for Significant Changes in Air Quality Concentration of 20 µg/m3 NOx.

These facilities are classified as a Federal Title V facilities and have filed application fora Title V permit. Pursuant to AQMD Rule 3006, any person may request a proposedpermit hearing on an application for a Title V significant permit revision by filing with theExecutive Officer a complete Hearing Request Form (Form 500G) for a proposedhearing within 15 days of the date of publication of notice. On or before the date therequest is filed, the person requesting a proposed permit hearing must also send by firstclass a copy of the request to the facility address and contact person listed above.

The proposed permit and other information are available for public review at the LuqueBranch Library, 294 E. "O" Street, Colton, CA 92324. Additional information includingthe facility owner's compliance history submitted to the AQMD pursuant to Section42336, or otherwise known to the AQMD, based on credible information, is available atthe AQMD for public review by contacting Mr. Chandra Bhatt at Engineering and

Alliance Colton Century Substation A-4 April 23, 2001Appendix A California Energy Commission

Compliance, South Coast Air Quality Management District, 21865 Copley Drive,Diamond Bar, CA 91865-4182, (909) 396-2653. Anyone wishing to comment on the airquality elements of these permits should submit the comments in writing within 30 daysof the distribution/publication date. Submit written comments to the AQMD, attentionMs. Pang Mueller, Senior Engineering Manager. If you are concerned primarily aboutzoning decisions and the process by which the facility has been sited in this location,contact your local city or county planning department or the California EnergyCommission at (916) 653-0062.

DISTRIBUTION DATE: March 29, 2001

April 23, 2001 B-1 Alliance Colton Century SubstationCalifornia Energy Commission Appendix B

APPENDIX B

PROPOSED AUTHORITY TO CONSTRUCT ISSUED BY THE SOUTHCOAST AIR QUALITY MANAGEMENT DISTRICT

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