September 16, 1998
Mr. Bruce Kaneshiro, Project Manager
C/o Environmental Science Associates
225 Bush Street, Suite 1700
San Francisco, CA 94104

RE: Written Comments on the Draft EIR for Application No. 98-01-008

Dear Mr. Kaneshiro:

[Begin N1]

Please accept the attached written comments submitted by Calpine Corporation on the above draft EIR. We hope that ESA will find our comments environmentally relevant and thus address them in the final EIR. We are especially concerned that the Cumulative Impacts Analysis be modified to more accurately reflect how output projections will vary under the ownership Scenarios 1 and 3. We believe that Geysers’ plant outputs have been optimistically projected (in an ambiguous fashion) in the supporting tables and would urge that ESA concentrate their efforts on adjusting those projections in a more realistic, understandable fashion.

[End N1]

Thank you for the opportunity to comment.

J.M. Rudisill
Vice President – Geothermal Operations
cc w/attach: C.L. Wardlow
J.E. Ronan, Jr. Esq.
E. Ko, Esq.
L.R. Krumland
R. Zahner
D.J. Gilles

Calpine Corporation’s

Comments on

CPUC PG&E Power Plant Sale Draft Environmental Impact Report, 8/98

Compiled by Jacob M. Rudisill and Charlene Wardlow

Significant EIR Issues


EIR Location


1. Santa Rosa Reclaimed Water--Geysers Recharge Project.

Page 5-10, 5-11 & 6-24

"PG&E is one of the key players in the Santa Rosa Wastewater Modified Geysers Recharge Project."

[Begin N2] PG&E is not a "key player" in Santa Rosa Reclaimed Water Project. They are not involved in the project and there will be no role for a new owner to assume in the process. [End N2]


Page 6-24

"...steam field operators and PG&E have entered into an agreement to inject..."

[Begin N3] No such agreement or commitment of Santa Rosa water to PG&E’s plant area exists (for the Santa Rosa project). [End N3]


Page 5-11

"...existing units could be operated at sustained power generation rates for 20 to 30 years."

[Begin N4] Field capacity of 700 MWs is assumed to be sustainable for 25 years.

This unsupported assumption is contrary to the field decline data shown in Table C-1. The assertion is not supported by any analysis or reference.

[End N4]

2. Generation Forecast

Page C-9, Tables C-1, S.1, S.3, 5.2, 6.1.

Generation from the Sonoma County units increases 4 MW from 1999 to 2005 while they operate at maximum base load output. The Lake County units decline only 8 MW.

[Begin N5] This claim that the field will undergo a dramatic reversal of its historic performance trends is unsupported by any assumption in the document. PG&E’s estimates of hypothetical available generation in years of heavy curtailment appear to have been extrapolated without regard for the actual operating conditions of the forecast period.

3. Confusion over capacity factors.

Table S.3 and Footnotes, Tables 5.2, 6.1, C-1

We recommend that actual megawatt-hours be projected instead of percentages. The interchanging use of ‘net generating capacity’ for design capacity and net output throughout the draft EIR is confusing. [End N5]

[Begin N6] The term "Capacity Factor" is used to refer to ratios with different bases within the same table, and which are inconsistent with conventional terminology as used in Table 2.1. It is unclear whether one of the "Capacity Factor" used is the same as the "Adjusted Capacity Factor" used by PG&E in its CPUC filings. The text and table should either avoid using ratios ("Factors") and simply state values in Megawatt hours or annual average power output (in mw). Additionally, adequate definitions and explanations should be provided. The draft document is ambiguous in the analysis of production. [End N6]

4. Cumulative Impacts – Energy and Mineral Resources

Table S.4

[Begin N7] Benefit is claimed for the proposed project that actually occurs only under Alternative 3. The Executive Summary should already state that ownership by the Steam Supplier provide environmental benefit.

[End N7]

5. NEC ownership.

Page 6-23

[Begin N8] NEC is not a Japanese turbine producer, but a geothermal steam production company.

[End N8]

6. "Increased electrical demand" leading to increased Geysers output.

Overhead presented in Cobb and Santa Rosa.

[Begin N9] The Geysers is a declining resources. It is not logical that increased electrical demand will have any bearing on The Geysers’ output.

[End N9]

7. Steam stacking and "puff" definitions

Pages S-16, 1-7, 4.5-47; 4.5-75, Page 6-24 (steam stacking)

Page 6-23, 6.4.3, 2nd paragraph (puff)

[Begin N10] Steam stacking is "the controlled release of unabated geothermal steam." This activity is conducted in accordance with local Air Pollution Control District regulations. The technical discussion of the puff is incorrect. [End N10]

8. Noise level increase for alternative 3.

Page S-24, 4.10-2 Alternative 3.

[Begin N11] Please explain how the noise level will be greater under Alternative 3 – Geysers than under the proposed project. [End N11]

9. "Wasted resource" if plant capacity factor is lower.

Page S-22, Impact 4.8-2, Page 4.8-4 Impact 4.8-2

[Begin N12] If the new owner operates the power plant in a manner similar to PG&E’s operations (Page S-6), the project would promote wasteful and inefficient use of a valuable natural resource.

[End N12]

10. The phrase "reasonably foreseeable" could be misleading

Page S-6

[Begin N13] The steam sales agreements between PG&E and each of Unocal, NEC, and Thermal are long term legal obligations which will bind the permitted successors and assigns of the parties.

[End N13]

11. Power plant cooling tower drift impact at Geysers.

Pages 4.5-15 & 4.9-13 (Potential Site Contamination 1st Paragraph, last sentence.)

[Begin N14] FTP is discussed but not Geysers cooling tower drift impacts inside and outside of power plant yard. Cooling tower drift is an ongoing issue and has been extensively studies by PG&E (including the Phase 1 Environmental Site Assessment). What are impacts outside of power plant yard? This could be important to new owners in regard to remediation and liability issues. [End N14]

General Comments

[Begin N15]

¨ Review focus on accuracy and environmental remediation issues (for due diligence efforts).

[End N15]

[Begin N16]

¨ General comment throughout -- refer to condensate as steam condensate

[End N16]

Page S-21

[Begin N17]

Typos, font of 4.6-4. [End N17]

Page 1-7

[Begin N18]

Item 1 The statement that Geysers power production becoming non-economic may lead to shutdowns and thus stacking is unsupported. [End N18]

[Begin N19]

Item 4; The assertion that increased stream water diversion will occur if sales are unsupported. [End N19]

Page 2-28

[Begin N20]

GEO should be GEP. [End N20]

[Begin N21]

SMUD is now Sonoma>>>>change throughout EIR [End N21]

[Begin N22]

Santa Fe is now Silverado/Calistoga [End N22]

Page 2-35

[Begin N23]

Geysers Geothermal Field – What is the "Geysers Geothermal Area" Isn’t The Geysers Known Geothermal Resource Area what is really meant? And it is much larger than 5.5 miles by 1 mile. Big Sulphur Creek or Big Sulfur Creek [End N23]

Page 2-36

[Begin N24]

3rd full paragraph, last sentence--add "a conceptual diagram of’ after and before "the circulation." [End N24]

[Begin N25]

4th paragraph, 5th sentence—Southeast Geysers Effluent Pipeline is operating; Santa Rosa Wastewater is a project which the City of Santa Rosa has adopted but it still faces legal challenges and it is undergoing design engineering and funding efforts. [End N25]

[Begin N26]

Strike "evaluated as a viable" and replace with "used as a" [End N26]

Page 2-38

[Begin N27]

1st full paragraph, first sentence -- remove "purified", "pressurized." Add "to power plants" after "insulated pipes." [End N27]

Page 2-39

[Begin N28]

1st paragraph, 2nd sentence -- steam condensate has been injected since 1968. [End N28]

[Begin N29]

Strike "is believed to"; add s to "increase": strike "to" and add "s" to "increase. [End N29]

[Begin N30]

3rd sentence—strike "it is expected that" [End N30

[Begin N31]

2nd paragraph, first sentence, last word -- change "agencies" to "steamfield operators". [End N31]

Page 2-42

[Begin N32]

Top of page -- add "Lake County" before "area." [End N32]

[Begin N33]

Table 2-3 -- add Lake County under local and elsewhere. [End N33]

Page 4.1-1

[Begin N34]

4th paragraph, first sentence -- change "Geysers" to "thermal features." [End N34]

Page 4.1-15

[Begin N35]

Under Geysers Power Plant -- change "10" to "30." [End N35]

Page 4.3-4

[Begin N36]

2nd paragraph, 2nd sentence – change "steam generating conditions" to "production intervals"? [End N36]

Page 4.3-12

[Begin N37]

Impact 4.3.3, paragraph 2 -- suggest rewriting entire, unclear paragraph. [End N37]

Page 4.4-10

[Begin N38]

Geysers Power Plant, 1st paragraph – what about Cobb, Anderson, other creeks (See 4.4-6.)? [End N38]

[Begin N39]

2nd sentence and Table 4.4-2 -- Units 7-10, 12, 13, 16, 20 are also close to streams. [End N39]

Page 4.4-13

[Begin N40]

4th paragraph -- DOGGR regulates Class V injection, NCRWQCB also reviews injection "permits." Class V UIC program is permit by rule. No actual "permits" are issued. [End N40]

Page 4.5-47

[Begin N41]

2nd paragraph -- rewrite stacking description. Add "controlled" after "scheduled" in last sentence. [End N41]

[Begin N42]

3rd paragraph, 3rd sentence -- replace "relieving" with "lowering." [End N42]

[Begin N43]

Last paragraph -- what about H2S? [End N43]

Page 4.5-49

[Begin N44]

Do PM-10 #s assume all TSPs are PM-10? [End N44]

Page 4.8-2

[Begin N45]

3rd para. –Lake county units do not have untreated sanitary effluent from the plants injected into the steam field. [End N45]

Page 4.9-14

[Begin N46]

Impact 4.9-1 -- what is the reasoning supporting the 1st sentence ("divestiture will promote accelerated environmental cleanup....")? [End N46]

Page 4.9-19

[Begin N47]

Add sodium vanadate and hydrogen to list [End N47]

Page 4.9-22

[Begin N48]

Impact 4.9-4, 1st paragraph, last sentence -- add "hydrogen." [End N48]

Page 4.11-8

[Begin N49]

1st paragraph – Unocal responds to incipient fires only. [End N49]

Page 4.11-12

[Begin N50]

Police, 2nd sentence -- change to "remote location and restricted access." [End N50]

Page 4.11-16

[Begin N51]

Geysers Power Plant, 1st sentence -- $920,000 million? Or $920,000? [End N51]

Page 4.12-14

[Begin N52]

GPP description not accurate re: Lake county units. [End N52]

Page 4.14-5

[Begin N53]

Geysers Power Plant -- Strike "about 1971" to "1960" [End N53]

Page 5-8

[Begin N54]

Last bullet -- "and" should be "an." [End N54]

Page 5-23

[Begin N55]

Basin 2000 and 70 acre parcel are Lake County projects. Why do these projects require Sonoma County Community Development Commission review? [End N55]

Page 5-27

[Begin N56]

2nd paragraph, 2nd sentence -- change condensation to steam condensate. [End N56]

Page 5-32

[Begin N57]

Geysers Power Plant, 2nd Paragraph -- two periods at end of 2nd sentence. [End N57]

Page 6-11

[Begin N58]

Geologic Problems, 2nd Paragraph -- PG&E is not currently involved with seismic monitoring. [End N58]

Page 6-24

[Begin N59]

The flow is 8 mgd, not 6. [End N59]

Page 6-26

[Begin N60]

1st Paragraph, 1st sentence -- why would "risk of an upset condition" increase? [End N60]

Page C-7

[Begin N61]

1st paragraph, 7th sentence change "pump" to "pipe", and 200 to 130. [End N61]

[Begin N62]

4th paragraph, 2nd sentence change "pressure" to "production" [End N62]

Page C-8

[Begin N63]

Bullet 4; Change verbs to "collect" and "direct" [End N63]

Page C-9

[Begin N64]

1st sentence "injections" should be "injection" [End N64]

[Begin N65]

3rd paragraph 5th sentence -- There is no substantiation to the statement that operational changes have affected "actual geology" of the KGRA. [End N65]

Page C-21

[Begin N66]

Under Geothermal Plant, Unocal is no longer involved with refining and retailing. [End N66]

Page C-33

[Begin N67]

Footnote 63 Although technically the UNT/PG&E contract does allow the sale of steam to others, such sale can be performed only after a succession of tests and declaration by each party which severely hinders the ability of the steam supplier to sell to others. [End N67]

[Begin N68]

Footnote 65 Add Unit 15. [End N68]

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