Environmental Press # 241

Subj: DRAFT:Poseidon Desalination Plant Comments.
Date: Fri, 23 May 2003 9:00:25 PM Eastern Daylight Time
From: Ssurfdad@cs.com
To: rramos@surfcity-hb.org
Cc: Surfdaddy@compuserve.com

Rick,
Thanks for the information regarding the AES HBGS NPDES permit referenced above.
Here are some comments that I would like to pass on to the City Council members;

RE: ORDER NO. 00-5 NPDES NO. CA0001163 AES Huntington Beach LLC Huntington Beach Generating Station. states (last page):

PERMIT RE-OPENING, REVISION, REVOCATION, and RE-ISSUANCE.

1. "This order may be re-opened to address any changes in State or Federal plans,
policies or regulations which would affect the quality requirements for the discharge."

Also, pg. 4 states; "...compliance with California Ocean Plan amended most recently" (June 23, 1997).

The most recent California Ocean Plan is dated Dec. 3, 2001.

 

This plan (Dec. 3, 2001) has several amendments which are not reflected in the current AES NPDES discharge permit such as,
1. Replacement of acute toxicity effluent limitation.
2. Revise and changes water quality objectives for the protection of human health.
3. Addition of provisions for compliance determination for chemical water quality objectives.
4. Sample reporting protocol. (DNQ Vs.ND)
5. Power plant compliance reporting (mass emissions).

All of these changes and amendments have either a direct, or indirect bearing on the decision to allow a 50MGD desalination plant to operate in conjunction with the HBGS. Also, it is my understanding that the water quality requirements of the California Ocean Plan (COP) do not require Federal (EPA) approval to become effective in state-owned waters. Federal requirements (if any) are additional to state mandated regulations. NPDES discharge permits are supposed to be reviewed periodically (every 5 years) unless "administratively extended." CEQA allows for public comment to be held prior to revisions or amendments to a renewed NPDES permit. It is suggested that the Planning Commission consider delaying a decision on the Poseidon Seawater Desalination Plant until the current NPDES permit held by AES HBGS is re-opened, revised, and reviewed by the public, prior to being re-issued by the Regional Water Quality Control Board. (SARWQCB).

I greatly appreciate this opportunity to make these comments to the Huntington Beach City Council, and Planning Commission.

Don Schulz (562)430-2260
Surfrider Foundation
Huntington Beach/Seal Beach Chapter

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