Environmental Press # 321

Subj: Re: AES HBGS Report
Date: 9/15/2003 2:12:22 AM Eastern Daylight Time
From: Jon V3

In a message dated 9/10/2003 5:07:34 PM Pacific Daylight Time, Lwhite@energy.state.ca.us writes:

Hello Everyone
As I informed you in a previous email surf zone water quality impacts report for the AES Huntington Beach Generating Station is available (see web address below).

Please direct technical comments to me at this email address asap so that we may respond to input or comments you may have and complete this report.

Hi Lorraine,

I would like to submit the following comments below:

1. I believe that bacterial readings should have been taken at the intake port and outfall port to see if the readings in the ocean correspond with the findings in the


intake vault and discharge vault. The report claims that high intake vault bacterial readings are due to a "contaminated ocean". If true, this would be the first instance of a "contaminated ocean" 1500 feet away from the shoreline, or .28 mile. Previously, OCSD has claimed that there is a clear zone from 1 mile out to the shoreline. If there is a contaminated ocean 1500 feet out with high bacterial readings coming into the AES plant, this should be documented.

2. The reasons for high ammonia levels in the intake vault and discharge vaults should be further clarified. If biofouling from bivalves is going to be blamed for the high ammonia levels, then the density of 500,000 bivalves per square meter of pipe surface could be easily verified by a diver taking photographs and counting the bivalves (much the same way dermatologists count hair density on a person's scalp).

3. The failings of the salinity-measuring equipment and ammonia-measuring equipment offshore should be rectified. The report should not be accepted when there are several instances of equipment malfunction, misplacement, data-being thrown out because the values are too low (cast 1), etc. For example, the Grant hypothesis apparently could not be adequately tested because the ammonia levels were not collected offshore for some reason.

4. In different sections, the Grant hypothesis either is said to be dismissed or could not be discounted. Which is it?

5. The 2001 MBC report showed much higher bacterial levels in the AES system than the 2002 Komex study, including the intake forebay and discharge vault. Why is there such a difference? The report says that "internal practices" within AES made the difference. What were these "internal practices" and how are these practices going to be prevented in the future? Were these "internal practices" being done in the summer of 1999? Could these "internal practices" have been responsible for the beach closures in 1999?

6. The dye study demonstrates that the dilution from discharge port to shoreline is only 36 to 1, 1200 feet away from the discharge port, in contrast to the OCSD discharge 4.5 miles out, which is 148 to 1, 200 feet away from the diffuser. This finding seems to show, for the very first time, a direct transport mechanism for bacteria to reach the beach from a land-based source, the AES plant. If the 36 to 1 dilution is applied to the bacterial readings taken in 2001 from the MBC study, where total coliform levels exceeded the instrument's capability of reading the levels, (> 24,192), then a significant component to shoreline bacterial levels could have been reached in 1999. These bacteria can build up on the beach, especially overnight, when UVL from sunlight would not have killed the indicator bacteria.

7. The high bacteria and fresh water within the discharge vault are said to come from fresh water sources in and around the AES plant, including the General Purpose Retention Basin, Boiler Fireside Wash, Boiler Sump Wash, Storm Water Sump, Blackford's Ditch, Newland/PCH storm drain, yard drains, etc. If so, then we have a direct drain from bacteria-laden water going directly out into the ocean without interference, from the discharge vault. Since storm drains throughout Huntington Beach are intercepted and diverted to OCSD, it would seem the proper recommendation would be to divert all fresh water sources, including the General Purpose Retention Basin (including both East and West Retention Basins) to OCSD (not just storm drains). This requirement would also reduce bacterial loads to the proposed desalination plant.

8. The report calls Blackford Ditch a creek and refers to water, fish, and "adapted plants", without calling it a wetland. The status of this ditch as a wetland under Coastal Commission jurisdiction, should be clarified.

9. Ultimately, the report recommends no further investigation of AES. This recommendation is absurd, given the importance of the shoreline beach postings and closures in this exact stretch of beach affected by the AES discharge, the shallow nature of the discharge plume, the low dilution, and the findings that the AES plume reaches the beach, and the high bacterial readings in the different studies that show that AES "internal practices" affect bacterial readings in the intake vault and discharge vaults. The AES operations should be examined further under a high-powered microscope, including examining its operations in 1999, the MBC findings in 2001 and the dye studies and dilution factors discovered by Komex in 2002, applied retroactively to the MBC studies.

10. The possibility of contaminated water from the discharge port recirculating back into the intake port should be considered, since the intake port is only 700 feet away from the discharge port, and the dye study showed the discharge plume going to the shoreline, 1200 feet away from the discharge port.

11. I would also like to submit the following analysis of the report that I performed and distributed by email to the Huntington Beach Planning Commission on September 8, 2003, for your review and comments:

"September 8, 2003

Re: Poseidon CUP, HB Planning Commission, September 9, 2003

Dear Huntington Beach City Council and Planning Commissioners:

This is part of my ongoing analysis of the AES Huntington Beach Generating Station Surf Zone Water Quality Study, Final Draft, prepared for the California Energy Commission, prepared by Komex H20 Science Inc, dated August 4, 2003. After spending some 20 hours reading and rereading this report, these are my recommendations and findings for the Poseidon EIR, CUP, and further AES proceedings:


1. Because the AES CEC report shows that bacteria from the AES operations are discharged into the ocean and come back to shore via the AES plume, this whole report should be included in the Poseidon Desalination EIR, as a Supplemental EIR, because the findings in this report were not considered in the Poseidon Desalination EIR, and Poseidon will alter the AES discharge by virtue of concentration and addition.

2. The Conditional Use Permit for the Poseidon Desalination Project should contain requirements that: 1. All freshwater discharges from AES into the Discharge Vault of AES should be diverted to the OCSD for further treatment and not be allowed to enter either the Poseidon intake pipes or the AES discharge pipe. 2. The brine concentrate from Poseidon should be diverted to OCSD for further treatment, similar to the treatment of the brine concentrate from the GWRS system. 3. Blackford's Ditch has characteristics of a wetland and should be considered as such in terms of enclosing it in a box culvert as part of the widening of Newland. 4. Internal practices by AES that resulted in lower bacterial counts in 2002 than in 2001 should be identified and required for future practices to prevent backsliding.

These recommendations are based on the following findings, with page numbers referring to the AES CEC Report:

1. The AES discharge plume into the ocean 1200 feet from the shoreline comes back through the surf zone and affects the beach, as proven by the August 2002 dye study. The plume reached the beach first at Station 12 North, and then appeared on the beach to the south (p.116-118) (plates 4-18, 4-19b).

2. The discharge plume goes straight up to the surface of the ocean, without dilution, from the AES discharge port, which is 19 feet wide and only 11 feet below the surface of the ocean, at a distance of 1200 feet from the shoreline. At the surface of the ocean, the plume is diluted by 6 to 1, reaches the surf zone at 24 to 1, then the beach at a minimum of 36 to 1 dilution (p. 123).

3. The discharge plume, as evidenced by the dye study, can reach the intake port some 700 feet away from the discharge port, at a dilution of 24 to 1 at 600 feet (p. 117), and the plume fills the entire water column (p.126). Komex did no measurements of dye inside of the intake pipe, however.

4. The bacteria from the discharge pipe get on the beach, contributing total coliforms, fecal coliforms, and enterococci to the beach bacteria. Komex estimates that up to 16% of the Enterococci bacteria on the beach come from the AES discharge (p. 134).

5. Komex fails to consider the influence of beach sand acting as a reservoir and sink for continuous bacterial buildup and propagation from the AES discharge, although it does give an analysis of how bacteria survive and enhance in a saline environment (p.178-183). The independent peer review panel evaluating the OCSD Phase 2 investigation first proposed the role of beach sand acting as a reservoir. However, OCSD consistently denies that bacteria from its outfall ever reach the beach. On the other hand, Komex has shown in this report that bacteria from the AES outfall consistently reach the beach.

6. The intake vault contains high bacteria levels that Komex blames on a contaminated ocean (p. 107). However, Komex did not do any studies of the ocean bacteria at the intake port or the discharge port. If the ocean is contaminated at the intake port, this would be the first evidence that the ocean is contaminated with measurable levels of indicator bacteria at 1500 feet out from the shoreline, where the intake port is located 23 feet below the surface of the ocean. (p.17).

7. Intake Forebay bacterial concentrations between May 30 and September 28, 2001, ranged up to 12,997 MPN/100 cc Enterococci (AB 411 standard is 104 CFU/100cc for a single water sample) (p.42).

8. Intake Vault bacterial concentrations in the summer of 2002 between July 12 and October 5, 2002, would have caused 4 exceedances of AB 411 if collected in the surf zone (p.80).

9. Discharge Vault bacterial concentrations ranged up to total coliforms >24,192 MPN/100cc, fecal coliforms up to 1,296 MPN/100cc, and Enterococci to 1,694 MPN/100cc between May 30 and September 28, 2001 (p.42) (AB 411 standards are a maximum of 10,000 Total Coliforms, 400 Fecal Coliforms MPN/100cc, or 104 Enterococcus CFU/100cc in a single water sample). Note that values >24, 192 exceeded the instrument's capacity; therefore the actual numbers are higher, maybe much higher.

10. Discharge Vault concentrations in the summer of 2002 would have caused a total of 6 exceedances of AB 411 standards if the samples were collected in the surf zone.

11. Bacterial concentrations at the intake and discharge vaults exceeded AB 411 21 times if the samples had been collected in the surf zone (Table 5.1). Of these exceedances nine were observed in the intake value and therefore represent an import of contamination from the ocean. (p. 107)

12. A considerable amount of bacteria comes into the discharge vault of the AES plant from on-site fresh water sources. "The source of the bacterial contamination within the discharge vault is most likely a freshwater source" (p. 107). These on-site sources include the General Purpose Retention Basin, receiving water from yard and in-plant drains (p. 20), the Boiler Fireside Wash, the Boiler Sump Wash, the Storm Water Sump, and Blackford's Ditch on Newland. The discharge from the General Purpose Retention Basin goes into the discharge vault at a rate of up to 230,000 gallons a day. (p. 121). Indicator bacteria concentrations from these sources added up to 644 exceedances of AB 411 standards if the samples had been collected from the surf zone (p. 82 to 84).

13. Ammonia levels are very high within the system at both intake and discharge vaults, without adequate explanation. Only surmises are offered to explain high ammonia levels, including the highly questionable contention that bivalve biofouling occurs at an arbitrary density of 500,000 bivalves (mussels, clams) per square meter lining the intake pipe surface (p.112), despite procedures to prevent biofouling such as reverse flow heat treatments (p.19) and removal by divers. This would equate to a diameter of a bivalve being .003 of an inch, or 323 bivalves per square inch. The other explanation questions the accuracy and sensitivity of the EPA methodology, as Komex could not explain consistently high ammonia levels above 1.0 mg/l in both intake and discharge vaults (p.112).

14. Data is thrown out if Komex could not explain it, such as low salinities on CTD Cast #1. These salinities were thought to be not possible, so the salinity values were not included in the subsequent analyses (p. 97).

15. Data had to be "rectified" or altered to match the data from other studies, including adjusted temperature data that was used to calculate adjusted salinities. (p. 95)

16. The Grant hypothesis of entrainment of OCSD discharge could not be dismissed, and evidence of cold subthermocline water in the intake vault was found (P.138).

17. An alternate hypothesis of entrainment of water and bacteria from the San Gabriel, Los Angeles, or Santa Ana River, by the AES plume is suggested. (P.141).

18. The computer model of the plume discharge did not match the actual observations of the dye study until far field distance. The near field and intermediate field were not accurately depicted by the UM computer model (p.127).

19. Blackford's Ditch along Newland qualifies as a wetland. It is called a creek (p.58). "Approximately 100 feet of the creek has water present to a depth of two feet. The presence of adapted plants and small fish observed in the creek suggests that the creek is a standing body of water for long periods" …"The creek is hydraulically connected to the discharge vault and, at high tides; ocean water from the discharge vault may be forced up into the creek." (p.58). Also, salinity concentrations were approximately 2/3 of ocean water and decreased along the length of the ditch from the pump house to the dry inlet (p. 93). Also, tolytriazole, a corrosion inhibitor used in the AES plant, was found in the ditch (p. 93). Blackford's Ditch is also called a creek, with poor water quality and high concentrations of indicator bacteria (p.108).

20. Internal practices in the AES plant improved high bacterial counts in the discharge vaults and other locations in 2002 compared to 2001 (p. 136). No mention of what these "internal practices" actually were. If verified, these practices should be codified.

21. In-Plant Water Quality Measurements included the following high values:
Intake Vault: Enterococcus to 590 cfu/100 cc (AB 411 is maximum 104) (p.80)
Discharge Vault: Enterococcus to 610 cfu/100cc (p.81)
Blackford's Ditch: Total Coliforms up to 370,000 cfu/100cc (AB 411 is 10,000)
Fecal Coliforms to 31,000 cfu/100cc (AB 411 is 400),
Enterococcus to 62,000 cfu/100cc (AB 411 is 194) (p. 82)
Boiler Fireside Wash: Total Coliforms to 68,000, Fecal Coliforms to 4,300, Enterococcus to 160,000 cfu/100cc (p.82)
Boiler Sump Wash: Total Coliforms 21,000, Fecal Coliforms 3,800, Enterococcus to 11,000 (p.83)
Storm Water Sump: Total Coliforms to 11,000, Fecal Coliforms to 1,400, Enterococcus to 2,200 (p.83)
General Purpose Retention Basin: Total Coliforms to 32,000, Fecal Coliforms to 9,400, Enterococcus to 700 (p.84)

These all show high numbers of indicator bacteria that get discharged into the Discharge Vault and ultimately out into the ocean, where they come back to shore. The Poseidon desalination operations may act to concentrate these bacteria and other freshwater toxics such as corrosion inhibitor, and therefore all freshwater inputs to the discharge vault should be diverted to OCSD, where the toxics can be regulated under OCSD's source control program. In addition, whatever toxics and bacteria that are concentrated after Poseidon's operations should be sent to OCSD for further treatment similar to the GWRS program.

Respectfully submitted,

Jan D. Vandersloot, MD
2221 East 16th Street
Newport Beach, CA 92663
(949) 548-6326

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