This undated letter was received by courier on August 21, 2001, at 5:55 PM. The fact that it is not dated makes it difficult to cite as a reference. Therefore I will refer to it as the letter from FPL delivered on August 21, 2001.

FPL, without my permission, distributed copies of their letter to me to the public at the CPAC (Community Planning Advisory Council) meeting on August 21, 2001. The copies they distributed disclosed my residence address, which I do not generally publish, and it is not in the telephone book. Of course it is in the public records, available to anyone who would put forth the effort to look for it; I was distressed, however, to learn of FPL's publication of my address.

Besides the date on the letter, another omission by FPL was "Figure 1", which is referred to by answer number 5 below. FPL handed me a copy of Figure 1 at the CPAC meeting two hours after the letter was delivered to me. Click here to view "figure 1".

Click here to review a direct scan of the FPL letter. It is about 750K in size. The letter below was scanned from the original into HTML for convenience.

Note that the URL provided by FPL in their answer number 6 below contains a typographical error; the link returns an error message from the military site specified by FPL. The other URL specified by FPL in answers 9 and 10 is valid.

Mr. Jay O'Brien
6851 Second Street
Rio Linda, CA

Re:          Responses to Data Requests

Dear Mr. O'Brien:

    This letter contains the Rio Linda/Elverta Power Project's responses to several issues you raised at the July 17, 2001 Data Request Workshop. We hope you find these responses helpful: If you feel we have not fully answered your questions, or if you have additional questions about the RLEPP, please feel free to call me directly at 561-219-0042. As project manager, I assure you that any additional questions will be answered promptly.

1.     For FPL vs. SEPCO, compare the types and quantities of air pollutants per hour, day, month, and over the life of the power plants.

The SEPCO project consisted of an ethanol production facility coupled with one GE Frame 7 gas turbine equipped with a heat recovery steam generator (generating 148 MW of power at peak load). The Rio Linda Elverta Power Plant generates significantly more power (560 MW of power at peak load) and consists of two GE Frame 7FA gas turbines, each equipped with heat recovery steam generators. Because the Rio Linda Elverta Power Plant is designed to produce significantly more power, the emissions, prior to mitigation, are higher than the SEPCO project. The following table compares the difference in emissions between the two projects:
 
 

Average 1-Hour Emissions (lb/hr)

Average 24 Hour Emissions (lb/day)

Average Monthly Emissions (tons/month)

Expected Annual Emissions (tons/yr)

Average emissions are annual emissions divided into the appropriate time interval. These emissions estimates are closest to expected short-term emissions.

The area air quality impacts of the RLEPP, however, are actually lower than the SEPCO project, despite higher emissions, as addressed in the response to Question 2. FPL is acquiring emissions offset credits 30 to 40 percent in excess of its estimated actual emissions, to account for distances between the source of the credits and the project site.

2.     For FPL vs. SEPCO, compare the types and amounts of expected deposits on my property per day, each month, year, and over the life of the power plants, of particulates and other materials originating at the power plants. Take into consideration moisture and temperature inversion conditions, and the effects of the plume from the power plant.

The deposition of particulate matter from the RLEPP will be minimal and certainly less than what would have occurred as a result of the SEPCO project.

Materials can only be deposited on land in particulate form. Deposition of materials on the O'Brien property originating from the SEPCO project were investigated in 1993. This methodology was repeated for the Rio Linda Elverta project.

Based on the annual average PM10 concentration (0.025 ug/m3) and a conservative deposition velocity of 0.02 m/sec, the annual average deposition rate would be 0.175 g/acre/day. This result is half of the amount for the SEPCO project (0.35 g/acre/day), which itself was found to be insignificant. The Rio Linda deposition is roughly equivalent to sprinkling the amount of material in a "Sweet and Low" packet uniformly over six acres each day. The deposited material would be microscopic carbonaceous matter.

Although the emissions out of the stack are higher for the Rio Linda Elverta Power Plant, the air quality impacts are actually lower. The reason for this apparent disparity is that the stack height for the Rio Linda project (150 feet) is much greater than the SEPCO project stack height (60 feet). Greater stack heights allow for better dispersion of emissions into the atmosphere. This allows the emissions to be more evenly distributed over a larger area of land, thereby decreasing air impacts to neighboring areas.

Further decreasing air impacts, FPL is acquiring emissions offset credits 30 to 40 percent in excess of its estimated actual emissions.

3.     For FPL vs. SEPCO, compare the expected sound levels at a height of 14 feet above ground level (second floor deck) at my property, showing average, peak, and minimum, with explanatory information identifying the conditions which produce these levels. Take into consideration moisture and temperature inversion conditions, and the effects of the plume from the power plant.

Both the FPL and SEPCO projects were designed such that noise levels would not exceed 45 dBA at any residence. Thus, noise levels are expected to be similar at the O'Brien residence from either project. Average, peak and minimum noise levels would occur under the following plant operating conditions. Average noise levels would occur during steady-state power production at full output. Peak levels could occur during startup, shutdown and upset conditions for brief periods when steam may be released to the atmosphere. Minimum levels would occur when the plant is shut down and off-line but the transformers remain energized and some auxiliary equipment, such as lube oil systems and turning gear, continue to operate.

The noise modeling analysis performed for the Application for Certification demonstrates expected sound levels under a variety of conditions. The analysis assumed certain atmospheric conditions (such as temperature inversion or downwind conditions) which would effectively cancel any reduction in noise levels that could be expected as a result of ground effects from grass and brush. Thus, while the "Standard conditions" described below include ground effects that can result in a range of decibel reductions of up to 20 dBA, only 10 dBA was assumed for this conservative analysis. The plume from the power plant would have no effect on noise levels at the O'Brien residence.

Summer extremes            21.5         31.5         6.5
(105°F, 100% RH)

Winter extremes            18.1         28.1         3.1
(20°F, 10% RH)

Temperature Inversion     28.1/31.0    38.1/41.0    13.1/16.1
extremes (Winter/Summer)

4.     For FPL vs. SEPCO, compare the usage of natural gas per year as expressed in the number of average residences that would use the same amount of natural gas.

The Rio Linda Elverta Power Project will use the equivalent natural gas of approximately 428,000 residential customers. This is based on continuous operations at annual average baseload conditions (514 MW, 60 degrees F) and is based on PG&E published baseline consumption rates for residential customers. By comparison, the smaller SEPCO project would have consumed the natural gas equivalent of approximately 124,000 customers. This is based on the estimated hours of operation stated in the SEPCO air permit process.

5.     FPL Spokesperson Jocelyn Thompson, on July 17, 2001, at 9:07 PM, stated that all siting for the wells to provide water to FPL is based on specific locations as shown in the Rio Linda/Elverta Community Water District (RLECWD) Master Plan. Please identify these locations, by assessors parcel number or more specific location, that were identified by FPL as those that would provide the water for FPL.

The RLECWD Master Plan located conceptual well sites to serve the community, including more than 3,000 AF/yr anticipated demand from a customer located on a 90 acre site east of the intersection of West 6th Street and U, described sometimes as "future large industry" and other times as a "power plant" (see, e.g., Table 2-2 at p. 2-3). Well sites appear on a number of the maps contained in the Master Plan. See, for example, the designations of "new well" on Figure 7-1.

At the Data Response Workshop of July 18, 2001, Mr. Dwight Mudry, consultant to FPL, described how the sites in the Master Plan were used in the CEC process for the RLEPP. Mr. Mudry reviewed the conceptual well sites with Mike Phelan of the RLECWD, and was directed to identify the three conceptual well sites closest to the plant as the wells that would be installed to meet RLEPP demand. Mr. Mudry then visited the conceptual locations of the three wells. Based on the visit, slight adjustments were made based on site-specific constraints (e.g., moving the location 100 feet). Only very minor adjustments were made in order to be consistent with the engineering or other work that had already gone into the Water District's selection of conceptual sites.

In particular, based on the conceptual locations identified in the RLECWD Water Master Plan, the wells will be near the following locations: one well will be located near the intersection of West 6th Street and M Street; one will be on the project site near West 6th and U Streets; and, one will be near the intersection of U Street and Elwyn Avenue. (See Figure 1 (from FPL's Response to Data Adequacy Comment #3 through #6)).

Final well locations will minimize the potential adverse impacts on local wells, will be accessible/obtainable, and will meet the RLECWD standards for well siting.

6.     FPL Spokesperson Jocelyn Thompson, on July 17, 2001, at 9:10 PM, stated "literally hundreds of monitoring wells" are in place to track the McClellan contaminant plume and assure that it does not migrate toward Rio Linda. Please identify the monitoring wells, who obtains and processes the data, and describe how they are used to contain the plume.

Treatment of contaminated groundwater at McClellan Air Force Base has been ongoing for several years and is expected to continue until 2150. See Rio Linda/Elverta Power Project Response to CEC Data Request #80. To the best of RLEPP's knowledge, Mr. Phil Mook, the Installation Restoration Program Division Chief for McClellan AFB, and Mr. Paul Brunner, the Base Environmental Manager for McClellan AFB, would be knowledgeable concerning these efforts and any existing groundwater data.

Investigation of groundwater contamination at McClellan AFB began in 1979. See Pump and Treat of Contaminated Groundwater at Operable Unit B/C McClellan Air Force Base, California (https://www.denix.osd.mil/denis/Public/Library/Remedy/MCBC/mclebc01.html). ("Pump & Treat Study") Over 300 monitoring wells and 14 extraction wells have been installed basewide to monitor the plume. Pump & Treat Study at "Site Characteristics." The primary objective of the treatment program is to prevent migration of contamination plumes. Pump & Treat Study at "Performance."

The Negative Declaration (adopted by the RLECWD Board on February 26, 2001) refers to a May 1997 study of movement of the McClellan Plume by the Sacramento County Water Agency entitled "Baseline Conditions for Groundwater Yield Analysis." See Negative Declaration, page 25. This study is also discussed in the Water Master Plan at pages 3-5. The study evaluated the potential for movement of the McClellan plume assuming full buildout of the County General Plan in 2030, including the effects of groundwater pumping in the North Sacramento area. The model results indicated that the projected future groundwater declines for projected pumping of 148,800 AF/yr in 2030 would result in a movement of about 200 feet in a northeasterly direction for the shallow aquifer. The Negative Declaration found this to be a less-than-significant impact.

7.     FPL Spokesperson Jocelyn Thompson, on July 17, 2001, at 9:14 PM, stated that an EIR was submitted to CEC that was prepared by RLECWD. FPL stated the subject EIR said there would be no significant environmental effects from the FPL demand. Please identify that EIR document and provide citation(s) from that EIR substantiating FPL's statement.

The RLECWD's adoption of its Master Plan was subject to the California Environmental Quality Act (CEQA). This means that the Board of the District was required to analyze the potential adverse environmental impacts of the Master Plan before the Plan could be approved. CEQA provides several different levels of environmental review, depending upon whether the project is expected to result in significant adverse environmental impacts. If it is not, then the agency may prepare a Negative Declaration or a Mitigated Negative Declaration. However, if there is substantial evidence demonstrating that the project may have a significant adverse environmental effect, then an environmental impact report (EIR) must be prepared.

The RLECWD completed an Environmental Checklist and completed an Initial Study that identified no potentially significant adverse environmental impacts of the increased groundwater withdrawals anticipated under the Master Plan. (See Water Master Plan Initial Study, page 11.) Based on the Checklist and Initial Study, it was determined that "the Proposed Project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared." (Emphasis in original.) The Board of the RLECWD adopted the Negative Declaration at its meeting on February 26, 2001, finding that "there is no substantial evidence that the project will have a significant effect on the environment."

The Mitigated Negative Declaration identifies a district use of 26,557 AFA, which is approximately 4,000 AF/yr more than the amount considered in the Community Plan and the Water Forum EIR. The Negative Declaration concluded that even this higher amount would not substantially deplete groundwater supplies or degrade water quality. See Negative Declaration, page 27. Because the amounts for the power plant are included in the Master Plan and Negative Declaration analyses, the conclusion that the Master Plan will not cause significant adverse effects also applies to the much smaller amounts required for the power plant.

The RLECWD Master Plan and Negative Declaration were submitted to the CEC on June 18, 2001, as Attachments 85A and 85B of FPL Energy's Responses to CEC Data Requests.

8.     With respect to the EIR document referenced in item 7 above, FPL Spokesperson Thompson identified me specifically and individually as having knowledge and responsibility, as a RLECWD Board member, for that Environmental document. Please provide substantiation for that FPL contention as it refers to me.

As explained above in response to Question 7, on February 26, 2001, the Board of the RLECWD - of which you are a member -- concluded that there was no possibility that the Master Plan would have a significant adverse impact on the environment. The Master Plan assumes that 3,000 AF/yr of groundwater would be used by the RLEPP. Therefore, the Board complied with CEQA by adopting the Negative Declaration for the RLECWD Master Water Plan, rather than an EIR. The Board specifically found that "there is no substantial evidence that the [Master Plan] will have a significant effect on the environment."

9.     FPL Spokesperson Jocelyn Thompson, on July 17, 2001, at 9:34 PM, stated that an EIR was prepared by the Sacramento Water Forum that somehow involves this project. Please identify that EIR document and provide citation(s) from that EIR substantiating FPL's statement.

The EIR document is entitled Final Environmental Impact Report for the Water Forum Proposal (Responses to Comments & Additional Information) (October 1999) by County of Sacramento and City of Sacramento. The Draft EIR is entitled Draft Environmental Impact Report (Draft EIR) on the Water Forum Proposal (WFP). A copy of the Draft EIR can be downloaded at http://www.waterforum.org.

The Water Forum EIR analyzed the potential environmental impacts of the Water Forum Proposal (WFP). The WFP is a plan for the effective, long-term management of the region's water resources. The EIR is based on an evaluation of how environmental conditions would be expected to change as a result of implementing the WFP. The WFP is comprised of seven related elements, one of which is "groundwater management." Draft EIR, page 2-3. The groundwater management element "provides a framework by which the groundwater resource in Sacramento County can be protected and used in a sustainable manner. . . ." Draft EIR, pages 2-6 and 3-26. A key provision of that element is the concept of "sustainable yield," or the amount of water that can be safely pumped from the basin over a long period of time without damaging the aquifer. The WFP estimated the average annual sustainable yield recommendation for the North Area (in which the RLEPP would be located) at 131,000 AF. Thus, the WFP already takes into account the RLEPP's groundwater usage. In conducting its review, the WFP used the Integrated Groundwater and Surface Water Model (IGSM) to analyze the impacts of the WFP on groundwater. Draft EIR, page 4.2-8. The IGSM simulated six "what if' scenarios up through 2030. A synopsis of the Community Plan FEIR and the Water Forum EIR and this project can be found in the RLECWD Mitigated Negative Declaration at pages 3-5 and 27-34.

10.     FPL Spokesperson Jocelyn Thompson, on July 17, 2001, at 9:34 PM, stated that an EIR was prepared by the Sacramento North Area Groundwater Management Authority (SNAGMA) that somehow involves this project. Please identify that EIR document and provide citation(s) from that EIR substantiating FPL's statement.

SNAGMA is a joint powers authority formed on August 11, 1998 by the City of Citrus Heights, City of Folsom, City of Sacramento and County of Sacramento. SNAGMA's express purpose is to implement the groundwater management policies contained in the "Groundwater Management Element" of the Water Forum.

SNAGMA is among the authorities involved in preparation of an EIR document entitled Final Environmental Impact Report for the Water Forum Proposal (Responses to Comments & Additional Information) (October 1999) by County of Sacramento and City of Sacramento. The Draft EIR is entitled Draft Environmental Impact Report (Draft EIR) on the Water Forum Proposal (WFP). A copy of the Draft EIR can be downloaded at http://www.waterforum.org. This EIR does not directly involve this project, although it does evaluate water resources in the Sacramento region in which the project is located.

If you have any questions about these responses, please do not hesitate to contact me.

Sincerely,

/s/

Tim Rossknecht