September 11, 1998
Bruce Kaneshiro
CPUC EIR Project Manager
c/o Environmental Science Associates
225 Bush Street, Suite 1700
San Francisco, CA 94184-4207

Re: Proposed Divestiture of Electric Generation Assets by Pacific Gas and Electric Company Application No. 98-01-008

Dear Mr. Kaneshiro:

On behalf of the seven thousand Sierra Club members of the Redwood Chapter, we are commenting on the Draft Environmental Impact Report for the Divestiture of PG&Eís 14 Power Plants at The Geysers.

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Attached is a list of comments on deficiencies or errors in the DEIR environmental assessment. Some comments could not be addressed to specific areas in the DEIR because they were never raised. We find the DEIR is deficient and a re-issuance of the DEIR is necessary to address the issues as follows.

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We recognize and appreciate the step taken by the CPUC of conducting an environmental review under CEQA.

Sincerely,
/s/
Krista Rector
Redwood Chapter Executive Committee

Cc: Mile Reilly, Supervisor, Sonoma County
Rue Firch, Planning Commissioner, Sonoma County
Senator Mike Thompson
Representative Virginia Strom-Martin,
Tara Mueller, Esq.
Rich Ferguson, CEERT Representative

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1) The listing of the steelhead and coho salmon under the Federal Endangered Species Act is a significant change in circumstances since the project was first authorized. Therefore, the projectís impacts on steelhead and coho salmon must be considered in the DEIR. (See CEQA Guidelines, 14 Cal. Code Regs. Section 15065.)

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2) The DEIRís "environmental baseline" against which the projectís impacts must be measured is non-existent for the project. This is different from the "no project" alternative, which is continued operation of the project under itsí current ownership. (14 Cal. Code Regs Section 15125, 15126(d).)

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3) The DEIRís alternatives analysis must consider decommissioning of the project plant(s) as one of the reasonable and feasible alternatives. (Id., 15126(d).) One reason alone would be the effect of Proposition 9. According to the Analysis of the California Energy Commissionís "Preliminary Analysis of the Utility Rate Reduction and Reform Act", rate levels for residential customers of PG&E would plunge 26 percent starting in January, 1999. PG&E would be impacted due to a $2.9 billion debt for the Diablo Canyon plant in addition to The Geysers plants, including debts for Units 21, 22, 23 and 24 which were never built. Another reason you give on pg 3-7 is that "PG&E would not be required to sell its plants, and it is not certain that the plants would be sold" thus leaving it open ended to financial decisions to decommission.

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4) The DEIR must consider the full range of environmental impacts, direct and indirect, short term and long term. Year 2005 is not sufficiently long term. (14 Cal. Code Regs. Section 15126.)

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5) See CEQA Guidelines Appendix G for effects that are normally treated as significant. We argue that certain impacts must treated as significant and mitigation measures adopted for these impacts, see Item C Ė "Substantially affect a rare or endangered species of animal of plant or the habitat of the species." (14 Cal. Code Regs. Section 15000 et seq, App. G.) Since the permits for the plants were issued, the threatened listing of Russian River Central Coast ESU for steelhead (Oncorhynchus mykiss) took place on 8/11/97 and Russian River Central Coast ESU for Coho salmon (Oncorhynchus kisutch) took place on 10/31/96. (Refer to Federal Registers Vol. 63, No. 18 and Vol. 62 No. 159.) Big Sulphur Creek, a main tributary of the Russian River, drains The Geysers 85 mile watershed and is a steelhead habitat nursery.

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In addition, you state that hydrogen sulfide in Sonoma County would increase and The Geysers is probably the largest source of atmospheric sulfur in California (Suter, 1978) and sulfur dioxide has been shown to be a phytotoxicant or a poison to plants.

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Please refer to the "Geysers-Calistoga KGRA Fish Populations and Element Loads" published in June, 1990 by the University of San Francisco with oversight by Steven Sharpe of the Sonoma County Department of Planning and the California Energy Commission. This report published the results of studies on fish muscle and organ tissue showing the impacts of chemical element levels impacts from Geothermal activity. A copy of the report is available from Steve Sharpe, who is located in the LAFCO Agency in Santa Rosa or you may contact the author of this letter. Also please refer to "The Potential Impacts on Aquatic Ecosystems From the Release of Trace Elements in Geothermal Fluids" by Cushman, Heldebrand and Brocksen (Environmental Sciences Division Publication NO. 1097, October, 1997.) This addresses the bioaccumulation hazard in the Big Sulphur Creek region. Please refer to the files at the Northern California Regional Water Quality Control Board on the condensate spills to local water ways and fish kills (files: 6/85, PG&E, 20,000 gallon spill; 4/86, Unocal, 540 gallons, Big Sulphur Creek; 8/86, Unocal, 11,440 gallons, Big Sulphur Creek; 2/87, NCPA, 15,000 gallons, Big Sulphur Creek; and 4/88, PG&E, 30,700 gallons, Big Sulphur Creek as examples.)

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It is particularly notable that in Table 2.3 pg 2-45 "Partial List of Federal, State, Regional And Local Permits and Requirements Applicable to PG&Eís Proposed Divestiture" that you have not indicated any requirements for The Geysers from the National Marine Fisheries Service despite ESA listings and the history of spills.

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On pg 4.7-33 and 34 your assessment of adequate mitigation is to have PG&E hand over materials (unidentified) and a subsequent signing of a disclosure form noting the new owner received the forms. This constitutes all action necessary to "mitigate" impacts to endangered species. If touching the Bible were equivalent to clean living then all us Bible holders would be free from all sin.

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6) See CEQA Guidelines Appendix G for effects that are normally treated as significant. We argue that certain impacts must be treated as significant and mitigation measures must be adopted for these impacts, see Item F. "Substantially degrade public water supply" (14 Cal. Code Regs. Section 15000 et seq, App. G.) The City of Cloverdaleís historic water extraction rights, since the later 1800s, is from Pluton Creek, a tributary of Big Sulphur Creek, and from the confluence of Big Sulphur Creek with the Russian River. Today, the intake water wells are pulling from the gravels beneath the Russian River at the confluence. The City wells supply the drinking water for 6,000 people.

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7) See CEQA Guidelines Appendix G for effects that are normally treated as significant. We argue that certain impacts must treated as significant and mitigation measures adopted for these impacts, see Item X. "Violate any ambient air quality standard, contribute substantially to an existing or projected air quality violation, or expose sensitive receptors to substantial pollutant concentrations." (14 Cal. Code Regs. Section 15000 et seq, App. G.) You have not addressed in adequate manner the impacts of radon other than a "nod" on pg 4.5-47. Even though you point out on pg E-9 the California Energy Commissions concern and requirement for a significant number of Plant Units to contact them immediately if Radon exceeds standards.

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8) Financial impacts on the environment are significant because of the potential that bankruptcy and insufficient bonds will result in an inability to clean up the environment. If a single owner, such as a steam field leaseholder, purchases a plant, then their capital is sunk deeper into the same potentially insolvent generation unit. Please see the results of the Geo Operator Corporation bankruptcy that resulted in 24 leaking wells in 1997 in Sonoma and Mendocino Counties. Geoís bonds were inadequate and could only address one well head in Mendocino, leaving the remaining 23 wells to be repaired with County and State funds of over $2 million. The wells had to be replugged because of leaking hydrogen sulfide killing any living thing within hundreds of yards. (4/11/97 Final Report on GEO Abandonment filed with Sonoma County Planning Dept. and available in local libraries.)

A mitigation step should be included that would require a bonding requirement of the new owners to a level that would ensure that decommission and habitat restoration is done correctly and completely. This should be extended to address all directly related environmental damage. In addition, sufficient funds should be collected from plant operators to provide for inspections and monitoring by an independent party responsible to the public.

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9) The DEIR mentions the current and future projects for LACOSAN and Santa Rosa for injection of wastewater into 14-28 injection wells to "kickstart" the production of steam. However, there is the potential that the LACOSAN project may not be successful, and that the Santa Rosa project may not take place. You neglect in pg 2-36 to mention any of the other impacts of the steam constituents beyond sulfur. What has been unaddressed in this DEIR is the increase of corrosive solutes in the geothermal steam that have produced high levels of chloride at the wellhead with observed levels greater than 100 ppm. The chloride-bearing steam is acidic and highly corrosive and, as The Geysers reservoir dries out over time, the production of higher levels will increase with resultant long-term significance. You noted on pg C-8 that "Note that a change to cycling operations increases maintenance costs, due to the higher variability of operations and/or increased corrosion in the steam wells." You will need to reassess the impacts on both financial and environmental conditions from a continued increase of corrosive acids over the long term.

Also, item 7. on pg. S-12 stating that "the two proposed waster injection projects....are being implemented and have helped to stabilize generation capacity at the Geysers plant" is highly speculative and false, since not one inch of pipe has been laid for the more massive project. It is hard to believe that a proposed project has such far-reaching capabilities as to effect production when nothing, in fact, has occurred.

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10) On Pg. S-5 and 2-7, please elaborate on the statement that "PG&E will retain certain liabilities for existing contamination of soil and groundwater and will be responsible for conducting remediation activities of such contamination after the sales." What liabilities? What sites? What contamination? What groundwater and water hydrology courses? What mitigates the contamination? What are the standards that must be reached? On pg. 4.9-13 you note that PG&E hasnít completed a Risk assessment to determine the nature and extent of the contamination.

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11) Pg. S-5 The statement that "The Purchase and Sale agreement for each plant requires a deed restriction that prevents the new owner from using the site for residential or other sensitive uses" should also contain the following: "deed restrictions also commits the new owner to uphold all plant EIR mitigations that stipulated a return to native habitat after the decommissioning of the plant."

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12) On pg S-17 and 1-7 you mention that one of the areas of controversy is "the potential for the sales to increase diversions from creeks in the Geysers area" however, you never address this issue in any way in the DEIR, nor is there any attempt to show whether there is a significant impact nor an offsetting mitigation to the effect. There are almost 100 applications for increased water diversion from the Russian River and itís tributaries pending before the California Division of Water Rights. One of the two largest is an application by UNOCAL to extract additional water from the Big Sulphur Creek tributaries. Please contact the DWR for information or let the writer of the letter know that you need help and information will be supplied. What creeks are you referring to? Please note that on pg 4.4-16 you state "Changes in production at the Geysers would not be expected to affect water quality or quantity." Which is it? Affect or no affect?

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13) On pg. 2-6 you state that the sale of the power plants is to occur under the following terms and conditions, "The Geysers Power Plant will be offered for sale through a competitive bidding process to buyers who are qualified to ensure that the plant operates when needed for system reliability, and, when no longer needed, to conduct any required decommissioning in a responsible manner." Please give specific qualifications by which actions are to be ensured. What are the specific tasks that they will conduct in order to decommission in a responsible manner?

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14) On pg 2-38, we take exception to the statement that "geothermal steam is expanded through a steam turbine and cooled and condensed into water..." When, in fact, the condensate contains a vast number of toxic substances. These toxic substances are the reason condensate is reinjected instead of shipped out of the area. The original permit granters were afraid to ship that much waste over the Highways of California since the only site that could take something of this high of level of toxicity was Kettleman Hills in Southern California. You need to adequately address the environmental impacts from the handling of potentially increased amounts of condensate.

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15) You outline in Table 2.2 the fact that 14 Units are using outdated technology for "scrubbing" Hydrogen Sulfide. There are a significant number of the plants that donít use Stretford systems. You are responsible to address the environmental impacts and the potential for mitigation from decommissioning plants with non-Stretford systems and addressing the uncoupling of some plants from a single sale and bid proposal.

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16) It is noted on Pg 4.5-45 that you have included "Annual Wind Rose" patterns for air particulate impacts for all the plant sites except for The Geysers. This is notable when on pg 4.5-75 you note that hydrogen sulfide emissions will increase by 40% in the Sonoma County plants. We can only assume that you did not have them available. Please contact the Regional Air Quality Control Board or the author of this letter and air patterns will be made available to you. The fallout in The Geysers is notable and there are Deer Lung studies available. Please contact or visit the Regional Library in the town of Lakeport.

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17) On pg 4.8-2 you make an interesting statement that the problem with The Geysers is that it is "not a Ďunitaryí steam field; i.e., each operator is not Ďassignedí a percentage of the field to utilize. Instead, the more wells an operator builds, the more the operator is free and able to tap the resource. As a result, too many wells have been used to tap the KGRA. The steam resource is being unsustainably drawn upon, and the steam pressure from the field has been dropping for many years, currently to as low as 200 pounds per square inch (psi) from a peak of 500 psi." What you havenít addressed is what this impact has on the productivity and potential shutdown of certain plants. Nor have you addressed the issue that the root problem could exacerbate an accelerated shutdown of the resource extraction and the resultant impacts and mitigations.

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18) On pg 4.9-20 and E-5 you list hazardous materials at the power plants as less than significant. You mention asbestos as insulation material, but you may be unaware that The Geysers contains two unique materials, serpentine or asbestos and cinnabar or mercury. There are many abandoned mines and tailing sites going back approximately 100 years. The sites should be identified and OSHA requirements should be explained to new owners, including the run off pattern into area water ways. This would be significant for Plant #14 that "has four pumps in the turbine room from constant standing water" and from the floorplan layouts of the plants showing significant number of "sump/pump", "standing water", and "drainage pipe" sites. Also worthy of note is Plant #15 which was built directly upon a mercury mine (Bedrossian, 1980). A mercury retort and mine tailings are adjacent to the Filley 1 well pad. As stated by Mark Walters in "Geochemical Aspects of the Unit 15 Steam Field", that "therefore it is no surprise that steam from the Unit 15 steam filed contains mercury and associated elements." This is one example of many found easily in literature going back to the 1960s and can be found through a simple online search at the downtown Santa Rosa library.

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