September 18, 1998
Mr. Bruce Kaneshiro
Project Manager
Environmental Science Associates
225 Bush St.
Suite 1700
San Francisco, CA 94104

Re: Draft PG&E Environmental Impact Report

Dear Mr. Kaneshiro:

On August 5, 1998 Environmental Sciences Associates issued a Draft Environmental Impact Report ("EIR") on the proposed sale by PG&E of certain generating plants. Among the plants to be sold are the Pittsburg and Contra Costa generating facilities in Contra Costa County. In its discussion of cumulative impacts, the EIR references the Pittsburg District Energy Facility ("PDEF"), a proposed merchant generating facility to be located in Pittsburg, California. This submittal addresses assumptions and conclusions that the PDEF considers to be erroneous. PDEF requests that Environmental Sciences Associates review the comments below and revise the Environmental Impact Report to reflect these corrections. Additionally, certain corrections may require additional model runs to support any conclusions that require modeling input.

PDEF respectfully submits the following comments for your review. If you have any questions regarding these comments please do not hesitate to contact a representative of the PDEF.

Section 5.2.2, page 5-5. In the paragraph describing the PDEF, these are two misstatements:

[Begin O1]

The PDEF is not a joint venture between the City of Pittsburg, Enron and USS Posco. Enron is the developer and is solely responsible for licensing, constructing and operating the PDEF. The City of Pittsburg will share in project profits and USS Posco has agreed to purchase steam and electric energy from the PDEF.

[End O1]

[Begin O2]

Although the EIR is correct that the PDEF CEC application was filed on June 15, 1998, the CEC did not "accept" the application until July 29, 1998. The CEC has one year from July 29, 1998 to process the application.

[End O2]

[Begin O3]

Section 5.3.4, page 5-40. The first full paragraph on this page describes PDEF impacts upon water resources in the Bay-Delta. There will be no such impacts as the PDEF will not make any thermal discharges to the Bay-Delta. The PDEF will utilize cooling towers for heat rejection.

[End O3]

[Begin O4]

Section 5.3.4, page 5-41. The EIR makes certain conclusions regarding air quality impacts, apparently drawn from data on Tables G-6 and G-14. Table G-6 does not contain any PDEF data so it is assumed that the IER makes a comparison between operation without the PDEF (Table G-6) and operation with the PDEF (Table G-14). The actual values for PDEF emissions, compared with EIR values, are listed below:

Table G-14 Actual PDEF    
NOx lb/MWH   .01 .071
  lb/MMbtu   .014 .009
SOx lb/MWH   .01 .008
  lb/MMbtu   .001 .001
PM10 lb/MWH   .05 .056
  lb/MMbtu   .008 .007
CO lb/MWH   .08 .104
  lb/MMbtu   .011 .014
VOC lb/MWH     .033
  lb/MMbtu     .004

To the extent that insertion of the above listed values changes the conclusions regarding air quality impacts which are contained in the EIR, PDEF requests that new computer simulations be run to accurately reflect the impacts of the PDEF.

[End O4]

If you should have any questions, please call me at 415-782-7811.

Respectfully,
/s/
Samuel L. When
Director

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