# Clean Water Act Section 316(b) Proposal for Information Collection for Scattergood Generating Station

City of Los Angeles Department of Water and Power 111 N. Hope Street Los Angeles, California 90012-2607



# October 2005

Prepared by: URS Corporation Alden Research Laboratory, Inc. EPRI Solutions, Inc. MBC Applied Environm ental Sciences Tenera Environm ental, Inc.Scattergood Generating Station Proposal for Information Collection



## TABLE OF CONTENTS

Section Page

1.0 E X E C U T I V E S U M M A R Y

........................................................................................ 1-1

2.0 I N T R O D U C T I O N

....................................................................................................... 2-1

3.0 D E S C R I P T I O N O F S C A T T E R GOOD GENERATING STATION

..................... 3-1 3.1 Location and Physical Description of Cooling W a ter Intake Structure and Cooling System

............................................................................................. 3-1 3.2 Description of Cooling Wa ter Intake Structure

................................................... 3-2 3.3 Existing Hy draulic Conditions

............................................................................. 3-3 3.4 Applicable Perform a nce Standards

...................................................................... 3-8 3.5 Confor m a nc e with the C a lculation B a seline........................................................ 3-8

4.0 C O M P L I A N C E A L T E RN A T I V E S T O B E E V A L U A T E D

................................... 4-1 4.1 Taking Credit for Existing Use of Fish Protection Technologies and Operational Measures Under the Rule’s Calculation Baseline – Com p liance Alternative 2......................................................................................................... 4-1 4.1.1 Im pinge m e nt Mortality Reduction C r edits

.............................................. 4-1 4.1.2 Entrainm ent Reduction Credit

................................................................. 4-2 4.2 Use of Restoration Under Com p liance Alternative 3

.......................................... 4-2 4.3 Use of Fish Protection Technologies and/or Operational Measures Under Com p liance Alternatives 3, 4, and 5

.................................................................... 4-3 4.3.1 Narrow-Slot Cylindrical Wedgewire Screens

.......................................... 4-5 4.3.2 Fine-Mesh Ristroph Trav eling W a ter Screens

......................................... 4-6 4.3.3 Use of Pilot Studies

................................................................................ 4-10 4.3.4 Use of Operational Measures

................................................................. 4-10 4.4 Use of an Approved Technology Under Com p liance Alternative 4

.................. 4-10 4.5 Use of Site-Specific Standards Under Com p liance A lternative 5

..................... 4-11 4.5.1 Evaluation of Cost-Cost Test

................................................................. 4-11 4.5.2 Evaluation of Cost-Benefit Test............................................................. 4-12

5.0 BIOLOGICAL STUDIES

.......................................................................................... 5-1

6.0 SUMMARY OF PAST OR ONGOING CONSULTATIONS WITH AGENCIES

.................................................................................................................. 6-1

7.0 SCHEDULE FOR INFORMATION COLLECTION

............................................ 7-1

iScattergood Generating Station Proposal for Information Collection

Ta b l e s Page

Table 1 Capacity Utilization for Units 1, 2, and 3

............................................................ 3-2 Table 2 Applicability of Other Technologies

................................................................... 4-4

Figur e s P a g e
Figure 1 Location of Scatter good Generating Station

........................................................ 3-1 Figure 2 Site Configuration of S cattergood Generating Station

........................................ 3-4 Figure 3 Plan and Side Views of Scatte rgood Generating Station Intake Offshore Velocity Cap

........................................................................................................ 3-5 Figure 4 Plan View of Scattergood Generati ng Station Onshore Intake Structure

............ 3-6 Figure 5 Side View of Scattergood Generati ng Station Onshore Intake Structure

............ 3-7 Figure 6 Narrow Slot W e dgewire Screens

......................................................................... 4-6 Figure 7 Ristroph Screen Buckets Attached to Bottom of Traveling Screen Panels

......... 4-8 Figure 8 Exam ple of Fine Mesh Screen Pa nels Used in Test Setup at Alden Research Laboratory

............................................................................................ 4-9

Appendices

A Sum m a ry of Existing Physical and Biologi cal Inform ation and IM&E Characterization Study Sam p ling Plan B Velocity Calculations C Restoration Measures D Proposed Method for Evaluation of Environm ental Benefits

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Acr o nyms and Abbr eviations

AFS Am erican Fisheries Society BMP Best Managem e nt Practice BTA Best Technology Available CCRW QCB Central Coast Regional W a ter Quality Control Board CDFG California Departm e nt of Fish and Gam e CDS Com p rehensive Dem onstration Study cfs Cubic Feet per Second CW IS Cooling W a ter Intake Structure CW RP Corporate W e tlands Restoration Project El. Elevation ft Feet ft/s Feet per Second GDNR Georgia Departm e nt of Natural Resources gpm Gallons per Minute IM&E Im pingem e nt Mortality and Entrainm ent LADW P City of Los Angeles Departm e nt of W a ter and Power LARW QCB Calif ornia Regional W a ter Quality Control Board, Los Angeles Region MBNEP Morro Bay National Estuary Program

m gd Million Gallons per Day MLLW Mean Lower Low W a ter

m m m illim eter MW Megawatt NGO Non-Governm e ntal Organization NMFS National Marine Fisheries Service NOAA National Oceanic and Atm o spheric Adm i nistration NPDES National Pollutant Discharge Elim ination System PIC Proposal for Inform ation Collection PSEG Public Service Electric & Gas psi Pounds per Square Inch psig Pounds per Square Inch (gauge) QA/QC Quality Assurance/Quality Control rpm revolutions per m i nute Rule Clean W a ter Act Section 316(b) Phase II Final Rule RUM Random Utility Model SCE Southern California Edison SONGS San Onofre Nuclear Generating Station USEPA United States Environm ental Protection Agency USFW S United States Fish and W ildlife Service

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## 1

. 0 EXECUTIVE SUMMAR Y
This Proposal for Inform ation Collection (PIC ) is subm itted in com p liance with the Clean W a ter Act Section 316(b) Phase II Final Rule (Rule) for existing electric generating stations published in the Federal Register on July 9, 2004. This PIC is specific to the City of Los Angeles Departm e nt of W a ter and Power’s (LADW P) Scattergood Generating Station and provides the Calif ornia Regional W a ter Qu ality Control Board, Los Angeles Region (LARW Q CB) with LADW P’s plans for:

• Providing necessary biological inform ation;

• Evaluating alternative fish protection technologies;

• Evaluating the Rule’s Com p liance Alternatives and options; and

• Providing inform ation on consultations with fish and wildlife agencies. The Rule requires f acilities that withdraw coo ling water greater than 50 m illion gallons per day (m gd) f r om waters of the United States and that have a capacity utilization that exceeds 15% to m eet both the Rule’s im pingem e nt m o rtality and entrainm ent (IM&E) reduction standards of 80-95% and 60-90%, respectively. Scattergood Generating Station is subject to both reduction standards.

LADW P believes it is likely to be in com p liance with the im pingem e nt m o rtality perform a nce standard through use of a subm erge d offshore intake equipped with a velocity cap. LADW P’s preferred m eans to com p ly with the Rule’s entrainm ent perform a nce standard is through the use of restoration m easures. Howe ver, due to som e uncertainty regarding use of the restoration option as a result of Phase II Rule litigation, technologies and/or operational m easures as well as site-specif i c standards will also be evaluated as discussed in Section 4 of this PIC. LADW P plans to in itiate IM&E studies to establish the IM&E characterization baseline in January 2006. Studies to confirm the effectiven ess of the velocity cap are also planned. This PIC also provides an updated schedule consistent with LADW P’s proposed schedule subm itted on Novem b er 4, 2004, to the LARW QCB.

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## 2

. 0 INTRODUCTION

The United States Environm ental Protection Agency (USEPA) signed into regulation new requirem e nts f o r existing electric power gene rating f acilities f o r com p liance with Section 316(b) of the Clean W a ter Act on July 9, 2004. These regulations becam e effective on Septem ber 7, 2004, and are based on num eric perform a nce standards 1 . The Rule at 125.94(a)(1-5) provides facilities with five Com p liance Alternatives as follows:

1. A facility can demonstrate it has or will reduce cooling water flow commensurate with wet closed-cycle cooling to be in compliance with all applicable performance standards. A facility can also demonstrate it has or will reduce the maximum design through-screen velocity to less than 0.5 ft/s in which case it is in compliance with the impingement mortality (IM) performance standard (the entrainment standard, if applicable, still applies)

. 2. A facility can demonstrate that it alre ady has a combination of technologies, operational measures, and restoration meas ures in place to meet the applicable performance standards.
3. A facility can propose to install a comb ination of new technologies, operational measures, and restoration measures to meet applicable performance standards.
4. A facility can propose to install, operate and maintain an approved design and construction technology.
5. A facility can request a site-specific de termination of best technology available (BTA) by demonstrating that the cost of installing technologies, operational measures, and restoration measures are e ither significantly greater than the cost for the facility listed in Appendix A of th e Rule or significantly greater than the benefits of complying with the applicable performance standards.

All f acilities that use Com p liance Alternatives 2, 3, and 4 are required to dem onstrate a

m i nim u m reduction in im pingem e nt m o rtalityof 80% [125.94(b)(1)]. Facilities with a capacity factor that is greater than 15% that are located on oceans, estuaries or the Great Lakes, or on rivers and have a design intake flow that exceeds m o re than 5% of the m e an annual flow, m u st also reduce entrainm ent by a m i nim u m of 60% [125.94(b)(2)].

The Rule f u rther requires that f acilities using Com p liance Alternatives 2, 3, and 5 prepare a Com p rehensive Dem onstration Study (CDS) as described at 125.95(b) of the Rule based on each of the seven com ponents of the CDS (as a ppropriate) for the Com p liance Alternative(s) selected. Facilities using Com p liance Alterna tive 1 are not required to subm it a CDS and those using Com p liance Alternative 4 are only required to subm it the Technology Installation and Operation Plan and Verif i cation Monito ring Plan. All f acilities that use Com p liance

1 Perform ance st andards are found at Federal Register , Vol

. 69, 7/ 9/ 04, 125.94(b).

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Alternatives 2, 3, and 5 are required to prepare and subm it a PIC, the first com ponent of the CDS.
The Rule at 125.95(b)(1) requires that the PIC include:

1. A description of the proposed and/or implemented technologies, operational measures, and restoration measures to be evaluated.
2. A list and description of any historical studies characterizing (IM&E) , and/or the physical and biological conditions in the vi cinity of the cooling water intake structures and their relevance to this proposed Study. If you propose to use existing data, you must demonstrate that the data are representative of current conditions and were collected using appropriate quality assurance/quality control procedures.
3. A summary of any past or ongoing consulta tions with relevant Federal, State, and Tribal fish and wildlife agencies and a copy of written comments received as a result of each consultation.
4. A sampling plan for any new studies you plan to conduct in order to ensure that you have sufficient data to develop a scientifically valid estimate of IM&E at your site. The sampling plan must document all methods and quality assurance/quality control procedures for sampling and data analysis. The sampling and data analysis methods you propose must be appropriate for a quantitative survey and include considerati on of the methods used in other studies performed in the source water body. The sampling plan must include a description of the study area (includi ng the area of influence of the Cooling Water Intake Structure [ C WIS] ) , and prov ide a taxonomic identification of the sampled or evaluated biological assembl ages (including all life stages of fish and shellfish)

. The pream ble to the Rule on Federal Register Page 41635 states that the PIC should provide other inform ation, where available, to the National Pollutant Discharge Elim ination System (NPDES) perm itting authority regarding plans f o r preparing the CDS such as how the f a cility plans to conduct a Benefits Valuation Study or gather additional data to support developm ent of a Restoration Plan.

An im portant feature of the Rule is use of the calculation baseline. The calculation baseline is def i ned in the rule as f o llows:
“Calculation baseline means an estimate of impingement mortality and entrainment that would occur at your site assuming that: the cooling water system has been designed as a once-through system; the openi ng of the cooling water intake structure is located at, and the face of the standard 3/8- inch mesh traveling screen is oriented

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parallel to, the shoreline near the surface of the source waterbody; and the baseline practices, procedures, and structural configur ation are those that your facility would maintain in the absence of any structural or operational controls, including flow or velocity reductions, implemented in whole or in part for the purposes of reducing impingement mortality and entrainment. You may also choose to use the current level of impingement mortality and entrainmen t as the calculation baseline. The calculation baseline may be estimated usi ng: historical impingement mortality and entrainment data from your facility or fr om another facility with comparable design, operational, and environmental conditions; cu rrent biological data collected in the waterbody in the vicinity of your coo ling water intake structure; or current impingement mortality and entrainment data collected at your facility. You may request that the calculation baseline be modified to be based on a location of the opening of the cooling water intake structur e at a depth other than at or near the surface if you can demonstrate to the Dir ector that the other depth would correspond to a higher baseline level of impingement mortality and/or entrainment.”
This definition provides existing facilities with a variety of study options to take credit for f acility f eatures that deviate f r om the calculation baseline and provide the benef it of f

i sh protection. Facilities can also sim p ly develop the baseline by docum enting current IM&E.
This PIC provides a description of Scattergood Generating Station including deviations from the calculation baseline and applicable perf orm a nce standards in Section 3. Section 4 describes the Com p liance Alternatives and options to be evaluated including a description of alternative fish protection technologies and ope rational m e asures. Section 5 provides a brief description of existing biological inform ati on and plans for new studies with a detailed

summ a ry of biological inform ation and descrip tion of new studies provided in Appendix A. Section 6 sum m a rizes voluntary and ongoing discu ssions with fish and wildlife agencies related to Clean W a ter Act Section 316(b), and Section 7 discusses the schedule for

com p letion of studies.

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## 3

. 0 DESCRIPTION OF SCA TTERGOOD GENERA TING ST A

T ION

3.1 LOCATION AND PHYSICAL DESCRIPTION OF COOLING WATER INTAKE STRUCTURE AND COOLING SYSTEM
Scattergood Generating Station is located on the s hore of the Santa Monica Bay in the City of Los Angeles, California (Figure 1). Scatte rgood Generating Station uses a once-through cooling water system for all three of its generating units and has a total net generating capacity of 818 m e gawatts (MW ) . Units 1 and 2 are oil/gas system boilers, each with a net output of 179 MW . Unit 3 is a gas-fired boiler with a net output of 460 MW . For the years 2000 through 2004 the capacity factor of Unit 1 wa s 25%, Unit 2 had a capacity factor of 31%, and Unit 3 had a capacity f actor of 23%. Capacity utilization f o r Units 1, 2, and 3 is shown in Table 1.

FIGURE 1 LOCATION OF SCATTERGOOD GENERATING STATION

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TABLE 1 CAPACITY UTILIZ ATION FOR UNITS 1, 2, AND 3

Capacity Utilization (%)
2 0 0 0 2 0 0 1 2 0 0 2 2 0 0 3 2 0 0 4 5-Year A v e r a g e U n i t 1 1 0 3 1 2 8 2 7 2 9 2 5 U n i t 2 4 1 2 2 3 2 2 9 2 9 3 1 U n i t 3 3 3 2 3 6 3 4 2 1 2 3

3.2 DESCRIPTION OF COOLING WATER INTAKE STRUCTURE

One CW IS at Scattergood Generating Station serves all three units. The CW IS includes a single offshore intake pipe with velocity cap located approxim a tely 1,600 feet (ft) offshore (Figure 2). The ocean bottom surrounding the intake is at elevation 2 (El.) -29.0 ft (Figure 3). The top lip of the intake riser is at a depth of El. -11.0 ft. The concrete pipe extends 13.0 ft above the sea floor. A circular velocity cap wa s installed in 1974 to replace the cap from the original 1958 construction, which was severely da m a ged in a large storm

. The concrete cap has a radius of 16.3 ft with a 5 ft opening betw een the bottom of the cap and the top of the intake riser. The velocity cap redirects the intake f l ow f r om a vertical direction to a horizontal direction. W a ter flows through the ve locity cap, down a 17.5 ft internal diam eter vertical riser pipe, and into a 12.0 ft internal di am eter intake pipe that conveys the water to the onshore screen structure.
The intake pipe is connected to an inlet ch am ber configured in a 68.8 ft long, 60° wide arc (Figures 4 and 5). The length of the intake pipe f r om the velocity cap to the inlet cham ber is 2,100 ft (Figure 2). W a ter entering the inlet cham ber is redirected by guide vanes into the eight trash rack bays (Figure 4). These trash racks prevent large debris from reaching the traveling screens. Each trash rack bay is 6 ftwide, with a bottom located at El. -23.5 ft, and extends to El. 12.0 ft. The trash racks are verti cal 3/8-inch by 4-inch steel bars centered 5 inches apart.
Traveling water screens are positioned 30 ft downs tream of the trash rack (Figures 4 and 5). The screens are 6.0 ft wide and have a bottom elevation of El. -23.5 ft. The traveling screens have a rectangular 3/8-inch by 3/4-inch m e sh pattern and are rotated and washed every eight hours. Each screen is washed by internal and ex ternal spray nozzles that spray debris from the descending screen panels into two troughs that lead to debris basket pits located on either side of the structure.
The circulating water pum ps are located 25 ft dow nstream of the traveling screens (Figures 4 and 5). Units 1 and 2 each have two circula ting water pum ps, while Unit 3 has four pum ps.

2 All elevations refer to m ean sea level.

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The Units 1 and 2 pum ps are each rated at 86.9 cubic feet per second (cfs) [39,000 gallons per m i nute (gpm )], while the four pum ps fo r Unit 3 are each rated at 104.7 cfs (47,000 gpm ). The total circulating water flow for S cattergood Generating Station is 766.5 cfs (344,000 gpm ).
After passing through the condensers, warm ed wa ter is discharged into a 12 ft internal diam eter pipe that runs 1,200 ft offshore paralle l to the intake pipe. The discharged water exits through a 7.5 ft diam eter vertical riser located 400 ft away from the intake velocity cap.
The cooling water is heat treated approxim a tely once every eight weeks to prevent condenser biofouling. This is done by recirculation of the cooling water through the system . The circulated water is m a intained at a tem p er ature of 115°F for 1 hour and 40 m i nutes. Each cooling water pipeline is also injected with li quid chlorine for 40 m i nutes per day per shift. Chlorine levels in the discharge water are kept within the lim its of the NPDES perm it.

3.3 EXISTING HYDRAULIC CONDITIONS
Scattergood Generating Station CW IS is located within the near-shore zone of the Pacific Ocean (Figure 2). The near-shore zone is defi ned as the zone between the shoreline and 1,000 ft from shore or the 30-ft depth contour, wh ichever is farther. The horizontal velocity at the velocity cap opening is approxim a tely 1.5 feet per second (ft/s) assum i ng uniform flow distribution. The velocities in the intake pipe ar e 6.8 ft/s. The calculated approach velocity to the traveling screens is 0.6 ft/s for Units 1 a nd 2 and 0.7 ft/s for Unit 3. All velocities were calculated at full flow conditions (766.5 cfs) and m ean lower low water (El. 0.0 ft). Intake structure characteristics, form ulas, and velo city calculations for Scattergood Generating Station are provided in Appendix B.

3-3Scattergood Generating StationProposal for Information CollectionFIGURE 2SITE CONFIGURATION OF SCATTERGOOD GENERATING STATION3-4Scattergood Generating StationProposal for Information CollectionFIGURE3PLAN AND SIDE VIEWS OF SCATTERGOOD GENERATING STATION INTAKE OFFSHORE VELOCITY CAP3-5Scattergood Generating Station Proposal for Information Collection

FIGURE 4 PLAN VIEW OF SCATTERGOOD GENERATING STATION ONSHORE INTAKE STRUCTURE

3-6Scattergood Generating StationProposal for Information CollectionFIGURE 5SIDE VIEW OF SCATTERGOOD GENERATING STATION ONSHORE INTAKE STRUCTURE3-7Scattergood Generating Station Proposal for Information Collection

3.4 APPLICABLE PERFORMANCE STANDARDS
The Rule requires f acilities that withdraw cooling water greater than 50 m gd f r om waters of the United States and that have a capacity utilization that exceeds 15% to m eet both the Rule’s IM&E reduction standards of 80-95% and 60-90%, respectively. Since Scattergood Generating Station withdraws m o re than 50 m gd of cooling water and has a 5-year average capacity utilization f actors ranging f r om 23-31% f o r its three units, it is subject to both the IM&E reduction perform a nce standards.

3.5 CONFORMANCE WITH THE CALCULATION BASELINE
Scattergood Generating Station CW IS does not c onform to the Rule’s calculation baseline. Significant deviations from the calculation baseline are:

• The intake is offshore rather than located at the shoreline;

• The intake is subm erged rather than located at or near the surface; and

• The intake design includes use of a velocity cap.

The Rule allows f acilities to take credit f o r de viations f r om the calculation baseline if it can be dem onstrated that these deviations provide the benefit of fish protection to im pingeable sized organism s. Opportunities to take a credit are discussed in the next section.

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## 4

. 0 COMPLIANCE AL TERNA TIVES T O BE EV ALUA TED

LADW P intends to evaluate the f u ll range of Com p liance Alternatives and options available in the Rule f o r potential use in the CDS. Howe ver, LADW P also has certain preferences for

com p liance because som e options are considered to be m o re feasible, cost-effective, and environm entally beneficial than others. This section of the PIC provides a description of specif i c alternatives and options that will be evaluated f o r com p liance. It also indicates LADW P’s pref erred Com p liance Alternatives and options based on currently available inform ation, as well as som e of the issues currently identified with these alternatives and options.

4.1 TAKING CREDIT FOR EXISTING USE OF FISH PROTECTION TECHNOLOGIES AND OPERATIONAL MEASURES UNDER THE RULE’S CALCULATION BASELINE – COMPLIANCE ALTERNATIVE 2
The Rule specif i cally entitles f acilities to take credit f o r deviations f r om the calculation baseline (described in Section 2) that provide the benefit of fish protection. As discussed in Section 3.5, Scattergood Generating Station has a num ber of facility design and operational deviations from the Rule’s calculation baseline that provide the benefit of fish protection. These beneficial deviations include use of a subm erged offshore intake with a velocity cap and overall low capacity utilization.

4.1.1 Impingement Mortality Reduction Credits
The original 1958 velocity cap at Scattergood Generating Station’s CW IS was destroyed by a storm in April 1970. Subsequently to the storm , Scattergood Generating Station continued operation of the CW IS by reversing flow inthe cooling water system . The California Departm e nt of Fish and Gam e (CDFG) request ed that studies be conducted to estim ate the fish protection benefit of the velocity cap to com p are im pingem e nt rates without the velocity cap to the im pingem e nt rates when the original velocity cap was in place. The result of these studies indicated a significant im pingem e nt reduc tion benefit and the CDFG requested that a new velocity cap be installed. The new velocity cap installed in 1974 on the subm erged offshore intake for Scattergood Generating Station re sulted in a system very sim ilar to that at AES’s Huntington Beach Generating Station.
Site-specific studies were conducted at H untington Beach Generating Station in 1979 and 1980 to evaluate the effectiveness of the velo city cap in reducing im pingem e nt. A high level of fish protection perform a nce was reported for Huntington Beach Generating Station with average effectiveness for the two years ex ceeding the m i nim u m 80% im pingem e nt reduction perform a nce standard. LADW P plans to conduc t sim ilar studies at Scattergood Generating Station to verify site-specific perform a nce a nd credit towards the perform a nce standards. A description of the proposed study is provided in Appendix A.

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4.1.2 Entrainment Reduction Credit
In addition, the offshore subm erged location of the intake m a y have the benefit of reducing entrainm ent relative to a surface, on-shore lo cation. An evaluation of the potential for an entrainm ent reduction credit for this calculation baseline deviation m a y also be considered.

4.2 USE OF RESTORATION UNDER COMPLIANCE ALTERNATIVE 3
The Rule provides that applicants m a y use restor ation m easures in addition to, or in lieu of, technology m easures to m eet perform a nce standa rds. The basic philosophy of restoration is

m itigation of fish losses at a CW IS by either di rect supplem entation (stocking) of a “species of concern” potentially im pacted by the CW IS , or provision, protection, and restoration of habitat that “produces” fish and thereby, replaces those lost due to IM&E. Wh ile the use of restoration is dependent upon the outcom e of Phase II Rule litigation 3 , LADW P views restoration as a preferred m e thod for m ee ting the entrainm ent reduction perform a nce standard for a num ber of reasons. The first r eason, as discussed in Section 4.3, is a concern with the feasibility and/or cost of the available technologies and operational m easures to

m eet the entrainm ent perform a nce standard. The second reason is that LADW P believes the environm ental benefits of a restoration project are m o re directly quantifiable and m a y be

m o re environm entally beneficial than the us e of technologies and/or operational m easures. This is due to the fact that a restoration pr oject, such as wetland habitat creation, can provide benefits that go beyond offsetting entrainm ent losses and can provide those benefits over a longer period than technologies and/or operational m easures. Appendix C provides a summ a ry of restoration m easures that will be considered. Project

exam ples are listed for the following reasons: (1) their 316(b) application history by other power com p anies, (2) known interest in the local area based on an internet review of state program s, and (3) because design and im plem enta tion inform ation is readily available. The basic categories of considered restoration projects are:

• Habitat Protection or Creation Program ;

• Fish Stocking; and

• W a terbody Restoration. Other types of projects m a y be identified in di scussions with appropriate state and federal agencies.

3 The Second C i rcui t rul e d th at rest orat i on coul d not be used for com p l i a nce wi th th e C l ean W a t e r Act Section 316(b) Phase I Rule. Based on the Phase I Rule litigation decision, USEPA added significant text to the Phase II Rule to support its use in Phase II. LADW P plans to initially lim it eval uation of this com p liance opt i on i n 2005 t o di scussi ons wi th th e LARW QC B and appropri a t e st at e and federal fi sh and wi l d l i f e agenci es t o i d ent i f ypot ent i a l project s of i n t e rest and m e thods for scal i ng and veri fi cat i on m oni t o ri ng rel a t e d to projects of interest. It is L ADW P’s current understanding that the Ph ase II Rule litigation decision should be rendered som e t i m e i n th e second quart er of 2006.

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LADW P plans to discuss these ideas and consider other restoration alternatives that m a y be suggested and will also consider working w ith other com p anies with Phase II facilities located on Santa Monica Bay to develop joint proj ects. As part of the requirem e nt for use of restoration, LADW P plans to fully evaluate available technologies and/or operational

m easures to determ ine if in fact restora tion is m o re f easible, cost-ef f e ctive, or environm entally desirable than m eeting the perform a nce standards through use of technologies and/or operational m easures (see Section 4.3). The analysis of IM&E data described in Appendix A will be used in determ ining the am ount of restoration necessary to provide a m i nim u m benef it equivalent to an 80% im pingem e nt m o rtality reduction and 60% entrainm ent reduction as required by the Rule.

4.3 USE OF FISH PROTECTION TECHNOLOGIES AND/OR OPERATIONAL MEASURES UNDER COMPLIANCE ALTERNATIVES 3, 4, AND 5

LADW P plans to evaluate a variety of technologies and operational m easures for

com p liance. Generally, the cost of technologies required for com p liance with the entrainm ent perform a nce standard is significantly m o re cos tly than those required f o r com p liance with the im pingem e nt reduction perform a nce standard. LADW P is using Alden Research Laboratory to assist in evaluating fish protection technol ogies and operational m easures. Based on a site visit and review of existing facility inform a tion, Alden Research Laboratory has provided the

recom m e ndations for technologies and/or operationa l m easures to be evaluated in this PIC. Table 2 is a list of alternative technologies and the potential factors preventing im plem entation. It should also be noted that the entrainm ent reduction technologies and operational m easures proposed for evaluation also provide the benefit of im pingem e nt

m o rtality reduction as well.

Since LADW P believes that it is likely that Scattergood Generating Station currently m e ets the im pingem e nt m o rtality reduction perform a n ce standard (see Section 1 and Section 4.1.1), LADW P plans to focus on the evaluation of entrainm ent reduction technologies and/or operational m easures. However, if studies conf irm that the current design f eatures f a il to

m eet the im pingem e nt m o rtality reduction standa rd, the PIC will be am ended as necessary to consider such technologies or to consider the use of other com p liance alternatives for im pingem e nt m o rtality reduction.

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TABLE 2 APPLICABILITY OF OTHER TECHNOLOGIES

Concept Alternatives Mode of Action Potential Factors Preventing Implementation Further Consideration Behavioral Barriers Sound, infrasound, strobe lights, mercury lights, chemicals, electric screens, air bubble curtain, water jet curtain, visual keys, hybrid barriers Reduce impingement through behavioral deterrents Ineffective with the species present in the source waterbody No

Physical Barriers Fixed-panel screens, traveling water screens, rotary drum screens, barrier net, bar rack barrier, infiltration intakes, porous dike, aquatic filter barrier (Gunderboom), cylindrical wedgewire screens Reduce impingement by physically excluding fish from entering the intake Potential interference with navigation, debris, installation spatial requirements (size of installation), water depth, ocean currents Yes. Coar semesh barrier net; wide- and narrow-slot wedgewire
screens

Collection/ Handling Systems Modified traveling (Ristroph) screens, fish pumps Reduce impingement mortality by collecting and/or handling fish and returning them to the source waterbody Installation spatial requirements, fish and debris transport Yes. Fine- and coarse-mesh Ristroph screens

Diversion Systems Louvers and angled bar racks, angled screens (fixed or traveling), angled rotary drum screens, inclined plane screens, Eicher screen, modular inclined screen, submerged traveling water
screen Reduce impingement by diverting fish that enter the intake back to the source waterbody Spatial requirements, Fish/debris transport No

The Rule specifically identifies three tec hnologies with the potential to provide an entrainm ent reduction benef it. These include use of an aquatic f ilter barrier, use of cylindrical fine m e sh (narrow slot) wedgewire screens, and use of fine m e sh traveling screens. Presently, the aquatic filter barrier has yet to be succe ssfully deployed in a full-scale m a nner at any generating station and dem onstrated to be capab le of m eeting the perform a nce standard. The aquatic f ilter barrier is currently being tested at Mirant’s Lovett Generating Station on the Hudson River. During the first year of deploym ent at Lovett in 2004, the aquatic filter barrier tore. The aquatic filter barrier requires a large am ount of surface water and use of an air blast system to control debris and fouling buildup on the filter fabric. At this point the technology is not considered feasible for deploym ent in an open ocean environm ent such as Scattergood

4-4Scattergood Generating Station Proposal for Information Collection

Generating Station. Therefore, in the event that us e of restoration m easures is not available to offset entrainm ent losses, the following t echnologies and operational m easures will be evaluated.

4.3.1 Narrow

- Slot Cylindrical Wedgew ire Screens

A schem a tic of this technology is shown in Fi gure 6. This technology is designed to work by using a low through screen velocity relative to the am bient water current velocity. Protection of entrainable organism s is a function of the sw eeping velocity of the water current past the screens relative to the through screen veloc ity. These screens would replace the existing velocity cap. Based on Scattergood Generating Station cooling water flow of 766.5 cfs, Alden has estim ated that 23 – T84 (i.e., 84-in ch diam eter) cylindrical wedgewire screen

m odules would be necessary to provide the necessary cooling water flow to Scattergood Generating Station. This num ber of wedgewire sc reens is based on use of the typical design standard using 0.5 m illim eter (m m ) slots. However, Scattergood Generating Station entrainm ent data will be reviewed to determ ine if a larger or sm aller size would be appropriate. The cost of this technology is a func tion of slot size, since a sm aller slot size requires use of m o re or larger screens to provide the sam e volum e of cooling water. In addition, the industry standard design for we dgewire screens is a m a xim u m through slot velocity of 0.5 ft/s, which would also allow the use of this Com p liance Alternative for

m eeting the im pingem e nt perform a nce standard.

To verif y the ef f ectiveness f o r reducing entrainm ent, LADW P will need to evaluate current velocities in the area where the screens would be deployed to conf irm there is suf f i cient sweeping velocity past the screen m odules to prevent im pingem e nt of entrainable organism s. W h ile these screens have been deployed at a num ber of f

r eshwater f acilities, they have not yet been deployed in m a rine environm ents su ch as the Pacific Ocean. The higher biofouling rates in an ocean environm ent m a y present feasibility issues for this technology. The technology uses com p ressed air released in a m a nner to cause a blast of air through the screens to control fouling and debris buildup. Ho wever, due to the distance offshore that the wedgewire screen m odules would be located, use of the com p ressed air system m a y not be feasible. Also due to the high fouling ocean envi ronm ent, it will be im portant to ensure that the air blast system is adequate or that other fouling control m e thods are used to ensure an uninterrupted supply of cooling water for S cattergood Generating Station. This m a y include conducting pilot studies in the ocean in the vicinity of the facility.

4-5Scattergood Generating Station Proposal for Information Collection

FIGURE 6 NARROW SLOT WEDGEWIRE SCREENS

4.3.2 Fine-Mesh Ristroph Traveling Water Screens

LADW P also plans to evaluate replacing the ex isting 3/8-inch traveling water screens f o r Units 1, 2, and 3 with new 0.5 mm fine-m esh Ristroph screens. This fish protection technology is based on first collecting im pinged organism s in a m a nner to m a xim i ze survival and then returning them to the source waterbody. The technology em ploys a com b ination of Ristroph fish buckets attached to the bottom of traveling screen panels (Figure 7) and replacing the 3/8-inch stainless steel m e sh with a fine m e sh fabric (Figure 8).
A low pressure screenwash spray system [~10 pounds per square inch (psi)] is installed to wash im pinged fish eggs and larvae gently o ff the screens into the Ristroph buckets. The Ristroph buckets then discharge the fish into a fi sh return system to transport them back to the source waterbody in a location away from the intake to prevent them being drawn back to the CW IS. Fine-m esh screens are typically designe d with an approach velocity of 0.5 ft/s to help m a xim i ze survival of fish eggs and larvae.

4-6Scattergood Generating Station Proposal for Information Collection

Ristroph screens differ from standard trave ling water screens in that they operate continuously and have additional spray washes. These features prevent debris from building up in front of the screens and reduce debris ca rryover to the condensers. In addition, the finer

m e sh provides a sm oother surface than conventi onal woven wire m e sh, potentially increasing the effectiveness of the spray washes.

There are several issues that will need to be evaluated relative to this technology. First, the current approach velocity to the traveling scr eens exceeds the typical design velocity for this technology. Currently, the approach velocities are som e what higher at 0.6 ft/s for Units 1 and 2 and 0.7 ft/s for Unit 3. Due to the higher velocities it will be essential to perform laboratory and/or field studies to verify that the survival of organism s that would otherwise be entrained is adequate to m eet the en trainm ent reduction perform a nce standard. If im pingem e nt survival of entrainable organi sm s is low at the current velocities, the screenhouse would need to be expanded to accom m odate additional screens necessary to reduce the approach velocity. Such an expansi on would require each unit to be shut down for a substantial am ount of tim e and would require considerable site work. Second, due to the location of the existing traveling screens onshore, im pinged and entrainable organism s collected will have to be transported a consid erable distance to a saf e release point. Third, results of the entrainm ent study m a y indicate th at a screen m e sh size other than 0.5 m m is necessary to m eet the entrainm ent reduction st andard. Screen m e sh sizes used to prevent entrainm ent can possibly adversaly af f ect plant operation and reliability. Furtherm ore, f i ner
m e sh sizes m a y affect velocity and cost. Fina lly, species and associated life stages tend to vary considerably in term s of their ability to tolerate the collection and handling associated with this option, again em phasizing the need fo r species and life stage specific testing to verify survival rates. For these reasons, and especially if expansion of the intake and installing m o re Ristroph screens are required, th is option m a y not be a cost-effective solution under Com p liance Alternative 5.

4-7Scattergood Generating Station Proposal for Information Collection

FIGURE 7 RISTROPH SCREEN BUCKETS ATTACHED TO BOTTOM OF TRAVELING SCREEN PANELS

4-8Scattergood Generating Station Proposal for Information Collection

FIGURE 8 EXAMPLE OF FINE MESH SCREEN PANELS USED IN TEST SETUP AT ALDEN RESEARCH LABORATORY

4-9Scattergood Generating Station Proposal for Information Collection

4.3.3 Use of Pilot Studies

W h en results of the proposed IM&E sam p ling ar e available in early 2007, and if the use of restoration m easures is not available, L ADW P m a y decide to com p ly using one or a

com b ination of technology and/or operational m easures. LADW P m a y propose pilot studies in the 2006/2007 tim e fram e to verify perform a nce. Due to the high cost of pilot studies, they would not be im plem ented unless use of restoration is not available.

4.3.4 Use of Operational Measures

If

use of restoration m easures is not availabl e, LADW P will also consider using reduced f l ow on a diel or seasonal basis. It is im portant to note that the prim ary function of Scattergood Generating Station is to generate electric pow er in response to LADW P’s generation needs. A reduction in cooling water flow has the pot ential to affect generation output. However, depending on the results of the proposed entrainm ent study and the prim ary periods of diel or seasonal entrainm ent, LADW P m a y consider operational m easures. Any flow lim itation from a perm itting standpoint m u st be lim ited to a reduction over the term of the perm it so as to ensure that, at any specific tim e, Sca ttegood Generating Station has the flexibility to operate at full load in order to m eet LADW P’s generation needs.

4.4 USE OF AN APPROVED TECHNOLOGY UNDER COMPLIANCE ALTERNATIVE 4
Currently, use of wedgewire screens in rivers that m eet certain criteria is the only USEPA “approved design and construction technology.” However, the Rule provides a process that allows additional technologies to becom e listed as pre-approved technologies. New technologies can be so designated by providing info rm ation to dem onstrate that if installed in the waterbody type, the technology would have little trouble m eeting the perform a nce standard for which they are approved. Now that the Rule is in place, a good deal of interest has been generated in developing new fish protection technologies. LADW P is actively

m onitoring the developm ent and testing of new technologies for potential use. If other technologies m o re effective in term s of fish protection efficacy and cost-effectiveness becom e available, LADW P will contact the LARW QCB to recom m e nd it for public review and com m e nt as required for the addition of new “approved design and construction technologies” (under Com p liance Alternative 4), and LADW P will inform the LARW QCB that the new technology m a y be added to the PIC for evaluation at Scattergood Generating Station.

4-10Scattergood Generating Station Proposal for Information Collection

4.5 USE OF SITE-SPECIFIC STANDARDS UNDER COMPLIANCE ALTERNATIVE 5

LADW P plans to evaluate potential use of bot h the cost-cost and cost-benefit tests under Com p liance Alternative 5 for use at Scattergood Ge nerating Station. Use of this alternative is provided to allow Phase II f acilities to not incur costs that would be considered signif i cantly greater than either the costs estim ated by US EPA for facilities or the econom ic value of the site-specific environm ental benefits that will be achieved. Should the evaluation of the current im pingem e nt reduction technologies and operational m easures determ ine that the im pingem e nt perform a nce standard is not m e t, or if the use of restoration for offsetting entrainm ent losses is not available, these tests will be used in conjunction with the evaluation of technologies and operational m easures discussed previously in the PIC.

4.5.1 Evaluation of Cost-Cost Test
USEPA, in developing the national cost of im plem enting the Rule, considered the cost for each Phase II facility to com p ly. If the actual cost estim ated for a facility to m e et the perform a nce standard, based on a site-specific an alysis, is determ ined to be signif i cantly greater than the cost estim ated by USEPA f o r th e f acility to com p ly, the f a cility can apply f o r a site-specific standard under the cost-cost test using Com p liance Alternative 5. The sitespecific standard would be that achieved by th e use of the best perform i ng technology (i.e., achieve the highest level of protection) or ope rational m easure that would pass the cost-cost test. In the Rule, Scattergood Generating Sta tion is identified by the USEPA as facility

num ber AUT0068, and assigned a cost of NA. USEPA, in the pream ble of the Rule, m a kes the f o llowing statem ent regarding f acilities assigned NA:
“Note that some entries in Appendix A have NA indicated for the EPA assumed design intake flow in column 2. These are facilities for which EPA projected that they would already meet otherwise applicable performance standards based on existing technologies and measures. EPA projected zero compliance costs for these facilities, irrespective of design intake flow, so no flow adjustment is needed. These facilities should use $0 as their value for the costs considered by EPA for a like facility in establishing the applicable performance standards.” 4

Consistent with the Rule, LADW P plans to use $0 assigned for the cost of Scattergood Generating Station in evaluating the cost-cost test.

4 Federal Register , Vol

. 69, No. 131, 7/ 9/ 04, pg. 41646, col u m n 3, 2 nd Paragraph.

4-11Scattergood Generating Station Proposal for Information Collection

4.5.2 Evaluation of Cost-Benefit Test

The econom ic value of the environm ental benef it of m eeting the perform a nce standards will also be evaluated. This evaluation will incl ude the cost of any additional im pingem e nt

m o rtality reduction technologies needed to m a ke up any shortfall after taking credit for the of f

s hore subm erged intake and velocity cap. It will also include evaluation of the costs of

m eeting the entrainm ent perform a nce standard (a gain after taking any credits as a result of baseline deviations that can be dem onstrated to provide the benefit of fish protection) and the resulting benefit of m eeting the entrainm ent st andard. The approach for this analysis is discussed in Appendix D.

4-12Scattergood Generating Station Proposal for Information Collection



## 5

. 0 BIOLOGICAL STUDIES
The Rule requires that a sum m a ry of historical IM&E and/or physical and biological studies conducted in the vicinity of the CW IS be provided, as well as plans for any new IM&E studies.
One year of biweekly entrainm ent sam p ling was conducted at Scattergood Generating Station starting in 1978 and endi ng in 1979. Most sam p ling events consisted of both day and night sam p les. The results provided an estim ate of equivalent adult losses for target species. The species in term s of losses were croakers (that could not be identified to species), silversides, queenfish, white croaker, and an chovies. One year of im pingem e nt sam p ling was also conducted starting in 1978 and ending in 1979. Queenfish, white croaker, walleye surfperch, and white seaperch were the dom inant species im pinged.
In 1997, an analysis of heat treatm e nt da ta from 1989 – 1995 was conducted to update the

assessm ent of im pingem e nt levels. In fact, heat treatm e nt surveys have been conducted since the 1970s. During the last six years there has beenan average of six heat treatm e nts per year. Since 1990, the fish species prim arily affect ed by the operation of Scattergood Generating Station have been nearshore schooling/aggr egating species, such as topsm e lt (27%), queenfish (24%), Pacific sardine (21%), jack m ackerel (7%), jacksm elt (6%), white croaker (4%), and northern anchovy (3%). These seve n species com b ined accounted for 92% of im pingem e nt abundance at Scattergood Genera ting Station. The rem a ining 94 taxa each contributed 2% or less to the 15-year im pingem e nt total.
Most recently ichthyoplankton data were coll ected between m i d-May and m i d-July of 2004 in preparation for entrainm ent studies to be initiated under the Rule. Abundance near the Scattergood Generating Station intake was dom inated by unidentified gobies (79%),

com b tooth blennies (6%), queenfish (5%), and northern anchovy (5%). A detailed summ a ry of all of the historical studies and m a jo r findings is presented in Appendix A.

LADW P plans to initiate a new IM&E study in 2006 to establish the IM&E baseline as required for the CDS because no recent IM&E data have been collected over a full year of operations. These studies will include a study to quantify the credit toward the perform a nce standards as a result of the calculation baselin e deviations discussed in Sections 2 and 3. Reverse flow studies will be conducted at S cattergood Generating Station and used as the basis to estim ate credit for the subm erged offshor e intake and velocity cap in term s of the fish protection benefit it provides. In add ition, a source waterbody study of entrainable life stages is a com ponent of the overall study plan for use in scaling a restoration project to offset the estim ated proportional loss of m a rine life since this is currently the preferred Com p liance Alternative. Should the Phase II Rule litigation court decision determ ine that use of restoration m easures not be allowed, the source waterbody study of entrainable life stages

m a y be term inated. Final data analysis decisions will be m a de as appropriate to support the

5-1Scattergood Generating Station Proposal for Information Collection

Com p liance Alternative(s) and option(s) sel ected. A detailed description of the existing IM&E data, biological and physical inform ati on, and plans for new biological studies and analytical approaches are also provided in Appendix A.

5-2Scattergood Generating Station Proposal for Information Collection



## 6

. 0 SUMMAR Y

OF P A ST OR ONGOING CONSUL T

A

TIONS WITH AGENCIES
The Rule requires that “a sum m a ry of any pa st or ongoing consultations with appropriate Federal, State, and Tribal fish and wildlife ag encies that are relevant to the CDS and a copy of written com m e nts received as a result of such consultations be provided.”
Subsequent to the consultation with CDFG in the early 1970s regarding the repair/replacem ent of the velocity cap that was destroyed by a storm in April 1970, LADW P has had no discussions with stat e or federal fish and wildlife agencies regarding Clean W a ter Act Section 316(b) issues relative to Scattergood Generating Station.

6-1Scattergood Generating Station Proposal for Information Collection



## 7

. 0 SCHEDULE FOR INFORMA T ION COLLECTION

The Rule allows f acilities with NPDES perm its that expire within f our years of the date of publication of the Rule in the Federal Register (July 9, 2004), up to three years and six

m onths to subm it the CDS (125.95(2)(ii)). LADW P subm itted a letter to the LARW QCB on Novem b er 4, 2004, requesting approval of a sche dule to prepare and subm it the PIC, conduct necessary studies, and prepare and subm it the CDS. The letter requested approval to subm it the CDS for Scattergood Generating Station in January 2008, which is consistent with the final date for subm ittal in the Rule. This sec tion provides further discussion in support of the rationale for that schedule.
As noted in Section 4, LADW P is planning to initiate new IM&E studies in 2006. Assum i ng that the LARW QCB provides com m e nts within the 60-day period suggested in the Rule, LADW P will m a ke any necessary changes to m odify the PIC within 30 days and provide a revised PIC to the LARW QCB. The f i rst m a jor task will be to com p lete the IM&E Characterization Study and analyze the data. Com p le ting this analysis is critical in order for LADW P to m a ke a f i nal decision on Com p liance Alternatives. It is anticipated that af ter

sam p ling has been com p leted, four m onths will be required to conduct the analysis (second quarter of 2007). Upon PIC approva l, LADW P will also initiate work and discussions with appropriate state and federal agencies to identify potential restoration projects of interest for use under Com p liance Alternatives 3 and/or 5.
It is expected that, based on the f i nal litiga tion schedule, the Court will issue a decision on the ongoing Phase II litigation around the end of the second quarter of 2006. This will allow LADW P to reassess available Com p liance Alte rnatives and options based on the Court’s decision. If LADW P’s preferred use of restorati on is not available for IM&E, it is anticipated

a m o re detailed evaluation of alternative technologies, including pilot studies, m a y be initiated in the latter part of 2006. Based on com p le tion of analysis of the biological data in 2007, if restoration is available, LADW P s hould be in a position to consider a final

com p liance decision in m i d to late 2007 in term s of project details to be incorporated into the CDS. If restoration is not available, the CDS is anticipated to focus on technologies and/or operational m easures under Com p liance Alternatives 3, 4, and/or 5.
Preparation of the CDS will depend on the f i na l Com p liance Alternative(s) selected as f o llows:

• Use of Technologies or Operational Measures – It is anticipated that it will require approxim a tely six m onths after results of a ny pilot studies to review and com p lete a draft and final CDS based on the technol ogy and com p liance assessm ent inform ation (i.e., Design and Construction Technology Plan and Technology Installation and Operation Plan).

7-1Scattergood Generating Station Proposal for Information Collection

• Use of Restoration – If LADW P’s preferred approach of using restoration m easures is available, work will be initiated to prepar e a restoration plan. It is anticipated that preparation of this plan and providing th e inform ation necessary to address the requirem e nts necessary f o r this plan will al so require six m onths. It is, theref ore, likely that a final CDS based on restoration can be subm itted by January 2008.

• Use of Site-Specific Standards – Should use of Com p liance Alternative 5 be a

com ponent of the CDS, it will be necessary to prepare a Com p rehensive Cost Evaluation Study and, if the Cost-Benefit test is used, a Benefit Valuation Study will be required. In addition, if a technology or operational m easure is used as part of Com p liance Alternative 5, the technology and com p liance assessm ent inform ation docum ents will also be required. Thus, the full allowable schedule will be necessary. Therefore, the final CDS will be subm itted by January 2008. The Rule recognizes that the CDS studies are an iterative process 5 and allows f acilities to

m odify the PIC based on new inform ation. L ADW P m a y request LARW QCB approval of an

am endm ent to this PIC, based on new inform ation relative to technologies and operational

m easures, use of restoration m easures, Phase II Rule litigation, or subsequent agency guidance. Such inform ation m a y also requi re m odification of the currently proposed schedule.

5 See R u l e pream bl e fi rst col u m n pg 41235 of Federal Register /V ol . 69, No. 131/ Fri 7/ 9/ 04.

7-2Scattergood Generating Station Proposal for Information Collection

APPENDIX A

SUMMARY OF EX ISTING PHYSICAL AND BIOLOGICAL INFORMATION AND IM&E CHARACTERIZ ATION STUDY SAMPLING PLANScattergood Generating Station Proposal for Information Collection

APPENDIX B

VELOCITY CALCULATIONSAPPENDIX B

SCATTERGOOD GENERATING STATION VELOCITY CALCULATIONS

DATA:
Flow (Q): Units 1 & 2: 173.8 cfs (each) Units 3: 418.8 cfs Total: 766.5 cfs W a ter Elevation: El. 0.0 ft Velocity Cap Diam eter: 32.5 ft Opening Height: 5.0 ft Intake Pipe Internal Diam eter: 12.0 ft Intake Pipe Area: 113.0 ft 2 Num b er of Intake Pipes: 1 Screen W i dth: 6.0 ft Num b er of Bays: Units 1 & 2: 2 per unit Unit 3: 4 Screenhouse Invert: El. -23.5 ft

FORMULA USED

) ( ) ( ) ( area A flow Q velocity V =
CALCULATIONS

sec / 5

. 1 * 5

. 32 * 5 5

. 766 ) ( ft ft ft cfs p Velocityca V = = π

sec / 8

. 6 0

. 113 5

. 766 ) ( 2 ft ft cfs s Intakepipe V = =

sec / 6

. 0 ) 5

. 23 0

. 0 ( * 6 * 2 8

. 173 ) 2 & 1 ( ft ft ft ft cfs screens Units V = + =

sec / 7

. 0 ) 5

. 23 0

. 0 ( * 6 * 4 8

. 418 ) 3 ( ft ft ft ft cfs screens Unit V = + =

Sc atterg ood Gene ratin g St atio n Pro p o s a l for Info rm ati o n Coll ec tio n B-1Scattergood Generating Station Proposal for Information Collection

APPENDIX C

RESTORATION MEASURESAPPENDIX C
Restoration Measures to be Evaluated for Clean Water Act Section 316(b) Compliance at LADWP’s Scattergood Generating Station
The Phase II Final Rule provides that applicants m a y use restoration m easures in addition to, or in lieu of, technology m easures to m eet pe rform a nce standards or in establishing best technology available on a site-specific basis. Sp ecifically, USEPA’s Rule states the following requirem e nt relative to the use of the restoration approach:
Facilities that propose to use restorati on measures must demonstrate to the permitting authority that they evaluated the use of design and construction technologies and operational measures and dete rmined that the use of restoration measures is appropriate because meeting the applicable performance standards or requirements through the use of other technologi es is less feasible, less cost-effective,

or [emphasis added] less environmentally desirable than meeting the standards in whole or in part through the use of restoration measures.
Types of Restoration Applicable to §316(b)
The Rule does not specify the types of restorati on m easures that can be used. This lack of specification provides flexibility in developing/ proposing a restoration approach. Restoration

m easures that have been used at other pow er stations to m eet §316(b) requirem e nts under state regulatory program s include:

• Wetland restoration [e.g., Public Service Electric & Gas (PSEG) Delaware Bay wetland restoration program for the Salem Generating Station] (W einstein et al. 2001).

• Fish stocking [e.g., Mirant Mid-Atlantic fish hatche ry at the Chalk Point Station] (Bailey et al. 2000); Exelon’s (form a lly Comm onwealth Edison) walleye hatchery at Quad Cities Station on upper Mississippi River (LaJe one and Monzingo 2000); and Southern California Edison’s (SCE’s) white sea bass hatchery.

• Submerged aquatic vegetation restoration [e.g., SCE’s kelp restoration for the San Onofre Nuclear Generating Station (SONGS)] (Deysher et al. 2002).

• Provision of fish passage (e.g., fish ladders or dam re m oval) at non-hydropower projects (e.g., PSEG f i sh ladders in Delaware Bay tributaries f o r the Salem Generating Station).

• Contribution to, or maintena nce of, a restoration fund for im pacts associated with the re-powering of the Moss Landing Stati on on Elkhorn Slough near Monterey Bay,California – see http://www.dukeenergy.com / businesses/plants/own/us/western/m o rrobay/reports/.

• Water quality improvements (e.g., riparian area protection or im plem entation of nonpoint source best m a nagem e nt practices) that m i nim i ze sedim e nt/pollutant runoff thereby resulting in fishery habitat im provem e nts, and practices that increase dissolved oxygen content in waterbodies thereby increasing available habitat for fish spawning and survival. Wh ile this approach is plausible, there are no known existing exam ples of such a §316(a) or §316(b) restoration project.

Sc atterg ood Gene ratin g St atio n Pro p o s a l for Info rm ati o n Coll ec tio n C-1APPENDIX C

Potential Restoration Measures for LADWP California Facilities

LADW P m a y wish to consider the f o llowing exam ple restoration projects 6 to attain the IM&E reduction perform a nce standard or as part of a site-specific standard developed by the perm it director. These projects are listed because of their known interest to fish and wildlife agencies in California and because design and im plem entation inform ation is readily available:

• Fish Stocking

. Wh ile forage species (e.g., gobies, anchovies, sardines) are the m o st

comm on species im pacted at California power plants, stocking of these species to

com p ensate for the losses would likely not be of interest to any of the f e deral and state fish and wildlife agencies. The objective of a supplem entation program would be to identify a ‘species of concern’, the stocking of which would com p ensate (‘com parable to, or substantially sim ilar to’) for the producti on foregone as m easured by a gam e fish’s

consum ption (e.g., X northern anchovy are equi valent in energy or food consum ption to Y white sea bass or other recreational or co mm e rcial f i shes of concern). This is the approach used by Potom ac Electric Power Com p any for estim ating annual hatchery production of striped bass to com p ensate fo r bay anchovy (a forage species) losses at their Chalk Point Generating Station on the Patuxent River in Maryland.
Fish stocking involves the direct supplem entati on (stocking) of a fish species of concern to aid restoration efforts for that species. Restoration stocking (as opposed to recreational gam e fish stocking) is generally pursued where the species of interest has been com p letely extirpated or where associated habitat rest oration is unlikely to contribute to stock restoration. For exam ple, the Georgia De partm e nt of Natural Resources (GDNR), following six years of study, recently initiated a long-term effort to restore lake sturgeon to the Coosa River system in Georgia/Alabam a. This species is listed as threatened throughout the U.S. and has disappeared com p le tely from m u ch of its original range, including the Coosa River. Through a collabor ative effort between several state and federal agencies, GDNR released 1,100 finger lings to the Coosa River in Decem ber 2002 as the first step towards returning lake stur geon to a healthy, self-sustained population in the river. See http://georgiawildlif e.dnr.s tate.ga.us/content/displaycontent.asp?txt Docum e nt=305).

A sim ilar program m a y be of interest in California, particularly for the southern steelhead salm on or coastal rockfishes ( Sebastes spp.), both of which are federal and state listed endangered and threatened species along the California coast. See http://ecos.fws.gov/ tess_public/TESSW ebpageUsaLists? s tate=CA).

The CDFG and LARW QCB [and United St ates Fish and W ildlife Service (USFW S)/National Marine Fisheries Service (NMFS)] m a y support LADW P’s

6 Projects listed are exam ples – opportunities for cr eative restoration projects are unlim ited and depend upon corporat e i n t e rest s and negot i a t i ons wi th state and federal resource agencies.

Sc atterg ood Gene ratin g St atio n Pro p o s a l for Info rm ati o n Coll ec tio n C-2APPENDIX C
participation in a program to restore rare , threatened, and endangered fish to native habitat. Mirant Mid-Atlantic Inc. currently ra ises and stocks Atlantic sturgeon at its Chalk Point Hatchery Facility on the Patuxent River f o r the State of Maryland, Departm e nt of Environm ental Protection. Am erican shad rest oration to the Susquehanna River basin in Maryland/Pennsylvania has been accom p lished in part via stocking of juvenile shad and via provision of fish passage (St. Pierre 2003; Hendricks 1995). Restoration stocking (e.g., for southern steelhead) could also be co m b ined with provision of fish passage (i.e., dam rem oval or fish ladders). This form of restoration is discussed further below.
Fish stocking program support could be via ha tchery operation developed on or off plant property (e.g., SCE funds the operation of a fi sh hatchery in Carlsbad, California for culturing and stocking white sea bass). Su ch a hatchery would be operated and

m a intained under state and federal oversi ght. Alternatively, LADW P could possibly negotiate a direct annual contribution of funds to a state and federal hatchery supplem entation program or a private founda tion. For exam ple, the Hubbs/Sea W o rld Research Institute operates the SCE fish hatc hery for SONGS m itigation. Wh ile hatchery or stock supplem entation program s can be cont roversial due to concerns over protection of natural genetic integrity, California resource agencies, based on their approval and developm ent of SCE’s SONGS Mitigati on Project, have supported stocking as

com p ensation for fish losses. CDFG and NM FS also have a long-term fish hatchery program to support m a intenance and restorati on of anadrom ous salm onids in California coastal rivers (CDFG/NMFS 2001). Californi a resource agencies’ experience with hatchery supplem entation m a y m ean that theycould be receptive to a hatchery program established by LADW P as com p ensation for im pingem e nt and entrainm ent losses at LADW P power plants in Southern Californi a. For exam ple, when operating at design capacity, the SCE funded hatchery is expect ed to exceed com p ensation for the total SONGS fish losses estim ated by an expert panel created by the California Coastal Comm i ssion. See http://www.sce.com / sc3/006_about_sce/006b_generation/006b1_ songs/006b1c_env_prot/006b1c3_songs_m iti/default.htm )

. For approxim a te cost references, SCE provi ded $4.7 m illion in funding for the white sea bass hatchery, which began operation in late 1996. Sim ilarly, the Potom ac Electric Power Com p any established an aquaculture f acility at their Chalk Point Station at a capital cost (1990 dollars) of $1 m illion. Annual operati ng and m a intenance costs have been approxim a tely $175,000 to $250,000 depending on the species and num ber of organism s raised and stocked in Maryland waters.

• Habitat Protection Program Participation

. The im portance of wetlands, in-stream habitat, and riparian areas as aquatic habitat for fish and invertebrates, and as habitat for wildlife is reviewed in EPRI (2003). W e tland rest oration or habitat restoration in general, is becom i ng increasingly popular across the U.S. and there is a growing case history with use of habitat restoration as a 316(b) m itig ation approach (EPRI 2003). In California, over 90% of its historic wetlands and 95% of historic stream side trees, shrubs, and

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ground vegetation has been lost due to urbanization, agricultural conversion, logging, and flood control (USFW S 2001). Habitat restoration, therefore, should be of m a jor interest to federal and state resource agencies a nd non-governm e ntal organizations (NGOs) in Calif ornia. The f o llowing identif ies f e deral, st ate, and private restoration program s that provide inform ation which LADW P m a y consid er for establishing their own restoration program or offer opportunities to collaborate on potential restoration projects.

Exam ple program s include:

 SCE’s SONGS Mitigation

. The proxim ity of SONGS and its ongoing restoration program is a key starting point relative to any restoration project initiated by LADW P for im pacts at its Southern California ge nerating stations. The California resource agencies and local NGOs will likely heavily rely on lessons learned during the negotiation and developm ent of the SONGS Program . The SONGS Marine Mitigation Program is a m u lti-faceted environm ental enhancem ent program intended to m itigate unavoidable im pacts to the m arine environm ent resulting f r om operation of the SONGS Units 2&3 cooling water system s. See http://www.sce.com / sc3/006_about_sce/006b_generation/006b1_songs/ 006b1c_env_prot/006b1c3_songs_m iti/default.htm

. The program includes:

 Restoring 150 acres of degraded wetlands at San Dieguito Lagoon to m itigate im pacts to m a rine fish populations caused by estim ated m o rtality to fish eggs and larvae;

 Im proving the in-plant fish protection system s to increase survival of adult fishes which enter the cooling water system s;

 Constructing an artif icial kelp reef to m itigate im pacts to the San Onof re Kelp Bed (note this was to of f

s et therm a l ef f ects);

 Co-funding a m a rine fish hatchery program intended as supplem entary m itigation for kelp im pacts; and

 Funding for Coastal Comm i ssion staff oversight and m onitoring of these

m itigation projects.

SCE is m a naging the overall m itigation pr ogram . Through its Conservation Financing Corporation subsidiary, the two largest elem ents of the m itigation program , the wetlands restoration project at San Diegu ito Lagoon and the artificial reef at San Clem ente, are being addressed by an equity alliance with CH2MHILL, an environm ental m a nagem e nt services c onsulting firm . Conservation Financing Corporation f i nances and oversees im plem entation of these two m itigation projects.

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SCE is the plant operator and m a jority ow ner of SONGS. SONGS is jointly owned by SCE, San Diego Gas and Electric, and the c ities of Anaheim and Riverside, which are funding the m itigation work.
SONGS’ owners want to keep interested pa rties inform ed about this program , which will significantly enhance the region’s m a rine resources. Through m eetings, discussions, newsletters, a W e b site, and the public hearing process, SCE expects to inform and involve the largest possible num ber of interested parties in the developm ent and im plem entation of the m itigation/enhancem ent plans. Detailed technical progress on im plem enting and m on itoring the SONGS m itigation effort can be found in the Proceedings from the Second Annual Public W o rkshop for the SONGS Mitigation Project (Reed et al. 2002).
Duke Energy’s Morro Bay Moderniz at ion Project Habitat Enhancement Program

. As part of the station m odernizati on, Duke Energy has volunteered to fund a program that would reduce sedim e ntati on and the other m a jor factors underm ining the Bay’s productivity. The concerns for Morro Bay and the target of Duke’s proposal are the issues identif ied by the Morro Bay National Estuary Program ’s (MBNEP) Com p rehensive Conservation Managem e nt Plan . Those issues include sedim e ntation, loss of habitat, and nutrient pollution. Duke’s proposal is their preferred alternative to CEC staff recomm e ndations for dry cooli ng. The Central Coast Regional W a ter Quality Control Board (CCRW QCB) staff ag rees with Duke’s proposal and believes that habitat enhancem ent would yield greater long-term benefits for the Bay. Duke Energy’s proposal would fund habitat e nhancem ent projects authorized by the CCRW QCB and m a naged through professional groups like the MBNEP, which have plans and program s to reduce sedim e ntati on and other factors underm ining the Bay’s productivity. The special value of habitat e nhancem ent is that it not only addresses

m a rine biology, but also protects and enhan ces habitat for birds and other anim als and sustains im portant recreational resources for the comm unity. Docum e nts describing the program in detail can be downloaded fr om the noted website. Because of recent

econom ic conditions across the U.S., Duke has canceled plans for m odernizing the Morro Bay Power Station and, as a result, their habitat enhancem ent project has not been im plem ented. See http://www.duke-energy.com / businesses/plants/own/us/ western/m o rrobay/reports/.

 PSEG’s Delaw a re Bay Estuary Enhancement Program

. This is the largest restoration program the U.S. im plem ente d as com p ensation for im pingem e nt and entrainm ent losses at a power station. Established in 1995, this program was negotiated with the New Jersey Departm e nt of Environm ental Protection as a

m itigative action f o r f i sh losses at the Sa lem Nuclear Generating Station in lieu of im plem enting a closed-cycle cooling system

. Principally focused on the restoration of approxim a tely 10,000 acres of form er salt hay farm s to natural estuarine salt m a rsh in the lower Delaware Estuary, the program al so includes provision of fish passage in

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com b ination with som e lim ited fish stocking to support restoration of anadrom ous (Am e rican shad and river herring) fish stoc ks. Details of the program can be found in W e instein et al. (2001). In a following s ection, the m e thod used by PSEG to scale (i.e., convert fish loss to acres of equivale nt wetland habitat) the size of the requisite restoration project is dem onstrated. The PSEG incurred costs to date for the ongoing restoration project, including capital, O& M, and m onitoring exceed $100 m illion or $9,350/acre (EPRI 2003).

 Santa Monica Bay Restoration Commission

. In recognition of the need to restore and protect the Santa Monica Bay and its re sources, the State of California and the U.S. Environm ental Protection Agency esta blished the Santa Monica Bay Restoration Project as a National Estuary Program in Decem ber of 1988. The Project was form ed to develop a plan that would ensure the l ong-term health of the 266 square m ile Bay and its 400 square m ile watershed, located in the second m o st populous region in the United States. That plan, known as the Sant a Monica Bay Restoration Plan, won State and Federal approval in 1995. Since then, the prim ary m i ssion has been to facilitate and oversee the im plem entation of the Pl an. See http://www.santam onicabay.org/site/ aboutus/layout/index.jsp.
On January 1, 2003 the Santa Monica Bay Re storation Project form ally becam e an independent state organization and is now known as the Santa Monica Bay Restoration Comm i ssion. The Santa Moni ca Bay Restoration Comm i ssion continues the m i ssion of the Bay Restoration Projectand the collaborative approach of the National Estuary Program but with a gr eater ability to accelerate the pace and ef

f ectiveness of Bay restoration ef f o rt s. Restoration activities are based on a

com p rehensive plan of action for Bay pr otection and m a nagem e nt, known as the Bay Restoration Plan, which was approved by Governor Pete W ilson in Decem ber of 1994 and by USEPA Adm i nistrator Carol Br owner in 1995. The Plan identifies alm o st 250 actions, including 74 priority acti ons, that address critical problem s such as storm water and urban runoff pollution, habitat loss and degradation, and public health risks associated with seafood c onsum ption and swimm i ng near storm drain outlets. The Plan outlines specif i c program s to address the environm ental problem s facing the Bay and identifies im plem enters, tim elines, and funding needs.

Im plem entation of the Plan is the focus of current efforts. Securing and leveraging funding to put solutions into action, build ing public-private partnerships, prom oting cutting-edge research and technology, facilitating a stakeholder-driven consensus process, and raising public awareness in or der to restore and preserve the Bay’s m a ny beneficial uses are key objectives of th e Santa Monica Bay Restoration Comm i ssion.

 National Oceanic and Atmospheric Admi nistration (NOAA) Community-Based Restoration Program

. This program applies a grass-roots approach to restoration by actively engaging comm unities in on-the-ground restoration of fishery habitats around the nation. The Comm unity-Based Restoration Program em phasizes

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partnerships and collaborative strategies built around restoring NOAA trust resources and im proving the environm ental quality of local comm unities. The program is: (1) providing seed m oney and technical expertis e to help comm unities restore degraded fishery habitats, (2) developing partnershi ps to accom p lish sound coastal restoration projects, and (3) leveraging resources through national, regional, and local partnerships. This program is one of th e services of the NOAA Restoration Center. This Center’s m i ssion is to enhance living m a rine resources to benefit the nation’s fisheries by restoring their habitat. W o rking with others, the Center achieves its

m i ssion by (1) restoring degraded habitats , (2) advancing the science of coastal habitat restoration, (3) transferring restor ation technology to the private sector, the public, and other governm e nt agencies, and (4) fostering habitat stewardship and a conservation ethic. Recently, under the comm unity-based program , NOAA awarded $250,000 to the Gulf of Mexico Foundation for habitat restoration in the five states bordering the Gulf of Mexico. USEPA, under their Gulf of Mexico Program , sim ilarly awarded $90,000 to the Foundati on. These awards launch a m a jor new ef

f o rt to reclaim essential f i sh habitats of the Gulf of Mexico by im plem enting field efforts to restore and im prove m a rine and coas tal habitats that have been degraded or lost. See: http://www.nm fs.noaa.gov/habitat/restoration/.

 USFWS Partnership for Fish & Wildlife

. This program is supported by funds from federal and state agencies, private landowners, and NGOs (e.g., Ducks Unlim ited, The Nature Conservancy). The program is a voluntary partnership program with a goal to restore wetlands and other vital ha bitats on private land with 70% of the current funding com i ng from private sources. The rem a ining funds, along with restoration design and technical assistan ce, are provided by USFW S. State resource agencies, such as CDFG, work with the USFW S to help establish priorities and identify focus areas. The restoration of degr aded wetlands, native grasslands, stream s, riparian areas, and other habitat to conditions as close as possible to natural is

em phasized. The Partnership for Fish a nd W ildlif e Program is im portant f o r restoration of critical habitats in California (USFW S 2001). LADW P financial support to the program and potential in-kind service could potentially be negotiated as

com p ensation f o r im pingem e nt m o rtality and entrainm ent at their power plants in Southern California. See http://partners.fws.gov/index.htm

.

 Coastal America’s Corporate Wetla nds Restoration Partnership (CWRP)

. This program is designed to foster collabora tion between the federal governm e nt, state agencies, and private corporations. Private corporations that participate in this national program will donate funds for either site-specific wetland or other aquatic habitat restoration projects or provide m a tc hing funds to a national or regional effort in support of aquatic ecosystem restoration activities. Projects that will receive funds f r om the CW RP will all be approved Co astal Am erica projects, while f e deral agencies will assist in their proper execu tion. The Coastal Am erica Partnership will coordinate am ong all of its Regional Im plem entation Team s to identify the

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appropriate private foundation or state trus t fund that will receive funds from the CW R P

. T h i s o r g a n i z a t i o n w i l l n o t l i k e l y accept support in response to regulatory requirem e nts. However, the organizati on is a source of wetland restoration inform ation and unique partnerships m a y be arranged

. See http://www.coastalam e rica.gov/text/cwrpoperating.htm l

.

 Alternative Restoration Measures

. The above m easures have been identified as the

m o st likely restoration approaches thatwould be receptive to the LARW QCB and other federal and state resource agencies. Other potential approaches include nonpoint source pollutant runoff abatem ent program s a nd contam inated sedim e nts restoration. Wh ile these types of efforts focus on wa ter quality im provem e nts, the long-term benefit is im proved fish and shellfish habita t. Such efforts would have to dem onstrate a clear linkage between the two as com p ensation f o r im pingem e nt m o rtality and entrainm ent losses at LADW P’s Southern California power stations.

The California Coastal Comm i ssion is im plem enting a statewide Nonpoint Source Program . See http://www.coastal.ca.gov/nps/npsndx.htm l . Elem ents of the program include m a nagem e nt m easures for reduc ing runoff pollution from agriculture, silviculture, urban areas, m a rinas and recreational boating, and via hydrom odification (includes m odification of stream and ri ver channels, dam s and water im poundm ents, and stream bank/shoreline erosion). The Calif ornia Coastal Comm i ssion, therefore, is a source of inform ation for developing potential nonpoint source runoff abatem ent program s or im plem enting best m a nagem e nt practices (BMPs) to m eet the goals of the State’s plan in the Los Angeles ur ban and suburban areas. The LARW QCB m a y welcom e direct support by LADW P toward im plem enting som e of the BMPs as

com p ensation for the im pingem e nt (and entrainm ent losses) at LADW P power plants.

REFERENCES
Bailey, D. E., J. J. Loos, E. S. Perry, R. J. W ood. 2000. A retrospective evaluation of 316(b)

m itigation options using a decision an alysis f r am ework. Pages S25-S36 in D. A. Dixon, D. E. Bailey, C. Jordan, J. W i sniewski, J. R. Wr ight, Jr., and K. D. Zamm it (Editors). Power Plants & Aquatic Resources: Issues and Assessm ent. Environmental Science & Policy 3(Supplem ent 1).
CDFG/NMFS. 2001. Final report on anadrom ous salm onid fish hatcheries in California. Joint Hatchery Review Comm ittee, Sacram ento , CA. Decem ber 3, 2001. A report can be downloaded from : http://www.dfg.ca.gov/lands/fish1.htm l ).
Deysher, L. E., et al. 2002. Design considerations for an artificial reef to grow giant kelp ( Macrocystis pyrifera ) in Southern California. ICES Journal of Marine Science 59: S201- S207.

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Duke Energy Morro Bay LLC. 2002. Morro Bay Po wer Plant Modernization Project. Habitat Enhancem ent Program . Morro Bay, Calif ornia. Report can be downloaded at http://www.duke-energy.com / businesses/plants/own/us/western/m o rrobay/reports/.

EPRI. 2003. Enhancem ent Strategies for Mitigati ng Potential Operational Im pacts of Cooling W a ter Intake Structures: Final Technical Report. Report 1007454. June 2003. Palo Alto, CA.

EPRI. 2002. Guidelines for Selection of 316(b) Assessm ent Method or Model. Report 1005176, May 2002. Palo Alto, CA.
Fox, D. A., J. E. Hightower, and F. M. Parauka. 2002. Estuarine and nearshore m a rine habitat use by Gulf sturgeon from the Choctawhatchee River System , Florida. Pages 111-126 in W

. Van W i nkle, P. Anders, D. Secor, and D. Dixon, editors. Biology, Managem e nt, and Protection of North Am erican Sturgeon. Am erican Fisheries Society Sym posium 28, Bethesda, MD.
Goodyear, C. P. 1978. Entrainm ent im pact estim ates using the equivalent adult approach. Report No. FW S/OBS-78/65. U.S. Fish and W ildlife Service, W a shington, D.C.
Hendricks, M. L. 1995. The contribution of hatcheryfish to the restoration of Am erican shad in the Susquehanna River. Pages 329-336 in H. L. Schramm , Jr. and R. G. Piper, editors. Uses and effects of cultured fishes in aqua tic ecosystem s. Am erican Fisheries Society Sym posium 15, Bethesda, Maryland, USA.
Jensen, A. L., R. H. Reider, and W

. P. Kovalak. 1988. Estim ation of production foregone. North American Journal of Fisheries Management 8: 191-198.
Kneib, R. T. 2003. Bioenergetic and landscape considerations for scaling expectations of nekton production from intertidal m a rshes. Marine Ecology Progress Series 264: 279- 296.
LaJeone, L. J., and R. G. Monzingo. 2000. 316( b) and Quad Cities Station, Comm onwealth Edison Com p any. Pages S313-S322 in D. A. Dixon, D. E. Bailey, C. Jordan, J. W i sniewski, J. R. Wr ight, Jr., and K. D. Zamm it (Editors). Power Plants & Aquatic Resources: Issues and Assessm ent. Environmental Science & Policy3 (Supplem ent 1).
McCay, D. P. F., and J. J. Rowe. 2003. Habita t restoration as a m itigation for lost production at m u ltiple trophic levels. Marine Ecology Progress Series 264: 233-247.
Peterson, C. H., and R. N. Lipcius. 2003. Conceptual progress towards predicting quantitative ecosystem benefits of ecologi cal restorations. Marine Ecology Progress Series 264: 297-307.

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Mettee, M. F., and P. E. O’Neil. 2003. Status of Alabam a shad and skipjack herring in Gulf of Mexico drainages. Pages 157-170 in K. E. Lim burg and J. R. W a ldm a n (Editors). Biodiversity, status, and conservation of the world’s shads. Am erican Fisheries Society Sym posium 35, Bethesda, Maryland, USA.
NOAA. 1997. Scaling com p ensatory restoration actions. U. S. Departm e nt of Comm e rce, National Oceanic and Atm o spheric Adm i nistration – Dam a ge Assessm ent and Restoration Program , Silver Spring, Maryland. See also http://www.nm fs.noaa.gov/ habitat/restoration/projects_program s/darp/index.htm l

. Pejchar, L., and K. W a rner. 2001. A rive r m i ght run through it again: criteria for consideration of dam rem oval and interim lessons from California. Environm ental Managem e nt 28(5): 561-575.
Peterson, C. H., R. T. Kneib, and C-A. Ma nen. 2003. Scaling restoration actions in the

m a rine environm ent to m eet quantitative targets of enhanced ecosystem services. Marine Ecology Progress Series 264: 173-175.
Peterson, C. H., J. H. Grabowski, and S. P. Powers. 2003. Estim ated enhancem ent of fish production resulting from restoring oyster reef habitat: quantitative valuation. Marine Ecology Progress Series 264: 249-264.
Powers, S. P., J. H. Grabowski, C. H. Peterson, and W

. J. Lindberg. 2003. Estim ating enhancem ent of fish production by offshore artificial reefs: uncertainty exhibited by divergent scenarios. Marine Ecology Progress Series 264: 265-277.
Rago, P. J. 1984. Production foregone: an alternative m e thod for assessing the consequences of fish entrainm ent and im pingem e nt losses at power plants and water intakes. Ecological Modeling 24: 79-111.
Reed, D., S. Schroeter, and M. Page. 2002. Proceedings from the second annual public workshop for the SONGS Mitigation Project . San Clem ente, CA, February 27, 2002. Subm itted to the Calif ornia Coastal Comm i ssion by the Marine Science Institute, University of California, Santa Barbara. April 3, 2002.
St. Pierre, R. A. 2003. A case hi story: Am erican shad restoration on the Susquenhanna River. Pages 315-322 in K. E. Lim burg and J. R. W a ldm a n (Editors). Biodiversity, status, and conservation of the world’s shads. Am erican Fisheries Society Sym posium 35, Bethesda, Maryland, USA.
Strange, E., H. Galbraith, S. Bickel, D. Mills , D. Belton, and J. Lipton. 2002. Determ ining ecological equivalence in service-to-ser vice scaling of salt m a rsh restoration. Environm ental Managem e nt 29(2): 290-300.

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USFW S. 2001. Partners for Fish and W ildlife: California. Partners for Fish and W ildlife Program , Sacram ento, CA.

W e instein, M. P., et al. 2001. Restoration princi ples em erging from one of the world’s largest tidal m a rsh restoration projects. W e tlands Ecology and Managem e nt 9: 387-407

Sc atterg ood Gene ratin g St atio n Pro p o s a l for Info rm ati o n Coll ec tio n C-11Scattergood Generating Station Proposal for Information Collection

APPENDIX D

PROPOSED METHOD FOR EVALUATION OF ENVIRONMENTAL BENEFITSAPPENDIX D
Proposal for Information Collection (PIC): Deriving Economic Benefits of Reduced Impingement and Entrainment at Scattergood Generating Station

D.1 BACKGROUND
For use of the Cost-Benefit test under the site-specific standards, LADW P is required to have a Benefits Valuation Study prepared. The Clean W a ter Act Section 316(b) Phase II Final Rule (herein after referred to as the Rule) requires use of a com p rehensive m e thodology to value fully the im pacts of IM&E at Scattergood Generating Station. Other requirem e nts for use of the test include:

• A description of the m e thodology(ies) used to value comm e rcial, recreational, and ecological benefits (including non-use benefits, if applicable).

• Docum e ntation of the basis f o r any assum p tions and quantitative estim ates. If the valuation includes use of an entrainm ent surviv al rate other than zero, a determ ination of entrainm ent survival at the facility based on a study approved by the NPDES perm itting authority m u st be subm itted.

• An analysis of the effects of significant sour ces of uncertainty on the results of the study.

• If requested by the NPDES perm itting authority, a peer review of the item s subm itted in the Benefits Valuation Study. The peer reviewers m u st be chosen in consultation with the Director who m a y consult with USEPA and Fede ral, State, and Tribal f i sh and wildlif e
m a nagem e nt agencies with responsibility for fish and wildlife potentially affected by the cooling water intake structure. Peer revi ewers m u st have appropriate qualifications depending upon the m a terials to be reviewed.

• A narrative description of any non-m onetized benef its that would be realized at the site if the applicable perf orm a nce standards were to be m e t and a qualitative assessm ent of their

m a gnitude and significance.
All benefits, whether expressed qualitatively or quantitatively, should be addressed in the Benefits Valuation Study and considered by the NPDES perm itting authority and in determ ining whether com p liance costs significantly exceed benefits.

The benefits assessm ent begins with an IM&E study that quantifies both the baseline

m o rtality as well as the expected deviation f r om the Rule com p liance. Based on the inf o rm ation generated by the IM&E studies, the benef its assessm ent includes a qualitative and/or quantitative description of the benefits that would be produced by com p liance with the applicable perf orm a nce standards at the f acility site. To the extent f easible, dollar estim ates of all significant benefits categories would be m a de using well-established and generally accepted valuation m e thodologies.

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In order to have the appropriate inform ation if the benefit/cost option is chosen, we propose a strategy for the collection and analysis of econom ic inform ation. It should be noted that one particular benefit category, benefits accruing to i ndividuals even if they have no plans ever to use resources associated with Scattergood Gene rating Station (non-use benefits), are to be estim ated only:

In cases where the im pingem e nt or entrainm ent study identifies substantial harm to a threatened or endangered species, to the sustainability of populations of im portant species of f

i sh, shellf ish or wildlif e, or to the m a intenance of comm unity structure and function in a facility’s waterbody or watershed. (Final Rule, Federal Register page 41648).

“Substantial harm ” is a stringent requirem e nt to necessitate estim ation of non-use values, and thus, non-use values usually would not be incl uded in the final analysis. However, because the Final Rule does raise the potential for estim ation of non-use values, we do provide som e contingency for their estim ation.
The overall approach proposed for use at Scatte rgood Generating Station is consistent with the approach that USEPA used in developing th e assessm ent of the national benefits of the Rule as discussed in the Rule’s pream ble 7 . The USEPA quantified the econom ic benefit of the Rule based on quantification of recrea tional and comm e rcial fishing benefits. The recreational econom ic benefit uses a region specific random utility m odel (RUM) based on fisherm a n behavior com b ined with a benefit function transfer approach. USEPA estim ated the comm e rcial fishing benefit using a four-step process as follows:

1. Estim ate IM&E losses under current cond itions using a linear stock to harvest

assum p tion. The percent harvest is based on historical f i shing m o rtality rate data.

2. Estim ating the gross revenue of the lost comm e rcial catch. This was based on use of NOAA 1991-2001 landings and dockside price ($/lb) data.

3. Estim ating the lost econom ic surplus. US EPA assum e d a range of 0-40% of the gross revenue losses estim ated in Step 2 as a m eans of estim ating the change in producer surplus.

4. Estim ating the increase in surplus as a resu lt of the Rule. Based on Steps 2 and 3, USEPA estim ates the percent reduction in IM&E at a regional level.

The m a jor changes to the USEPA approach to be used in the Scattergood Generating Station analysis will be to use m o re current or site-specif i c inf o rm ation wherever possible.

7 Federal Register , Vol 69, No 131, 7/ 9/ 04, pg 41657.

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D.2 DESCRIPTION OF METHODOLOGIES TO DETERMINE BENEFITS
The Rule defines a perform a nce standard that the USEPA has established f o r all existing power plant facilities to m eet. Scattergood Ge nerating Station m a y be subject to the im pingem e nt m o rtality perf orm a nce standard (requiring a reduction in im pingem e nt

m o rtality of 80-95%) and the entrainm ent reduction perf orm a nce standard (requiring a reduction in entrainm ent of 60-90%). However, th e Rule states that f acilities do not have to

m eet the IM&E perform a nce st andards if it can be shown that the costs of achieving the perform a nce standards are significantly greater than the benefits. Therefore we are providing a plan to collect inform ation in case it is nece ssary to determ ine whether the benef its to be provided by the identified technology are significantly less than costs.

Im pingem e nt studies were conducted in1978-1979 and again in 2002 and 2003 (MBC, 2003). The early studies indicate that queenfi sh, jacksm elt, northern anchovy, and white croaker had the m o st individuals im pinged. At th is point in tim e it is dif f i cult to say which of the species will be selected as representative f o r the benef its analysis. The species chosen will be based on the planned IM&E studies. Wh en the IM&E studies are done, we will know which species are directly or indirectly (thr ough forage fish changes) affected. For now, we will consider the typical recreational and co mm e rcial species that are caught in and around Santa Monica Bay. Wh en better inf o rm ation is available, m o re specif i cation will be possible and be m a de. It is possible, although highly unlikely, that non-use values will need to be addressed.

The USEPA exam ined a technology (closed-cycle c ooling) to achieve a national standard for IM&E. In determ ining benefits at a national level, USEPA used certain econom ic concepts of benef its associated with using the assets that cooling water adversely affects and the

m e thodologies to estim ate the benefits (USEPA, 2004a; USEPA 2004b; USEPA 2004c). In order to m a ke the benef its com p arable to cost s, they presented benef its in a m onetary unit (i.e., dollars). Their benefit estim ates reflect ed the willingness of individuals to pay to go from the current environm ental status to one associated with an identified technology.
More specifically, the benefits analysis will seek to provide a unit value per fish caught ($/fish) for recreational and comm e rcial species af f ected. W ith this inf o rm ation, total recreational and comm e rcial benef its can be determ ined by m u ltiplying the unit value tim es the expected increase in recreational and co mm e rcial catch arising f r om the identif ied technology. In addition, som e inform ation will be provided with respect to non-use values.

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D.3 VALUATION OF RECREATIONAL ANGLING ECONOMIC BENEFITS
For recreational angling, there are two potential ways to quantify benefits:

1. Benefit Transfer – the application of be nefit estim ates provided in other studies to Scattergood Generating Station.
2. Prim ary Research – collection and/or assem b lage of data on recreational fishing in the Southern California area and use of the data to derive an estim ate of the value per fish for the im portant species.

Wh ile the two approaches initially will be discu ssed independently (i.e., the benef it transf er approach is discussed in Section D.3.1 and the prim ary research is discussed in Section D.3.2), there is a sound reason to consider them in concert with one another. That is, the benef it transf er inf o rm ation provides a reality check f o r any values derived in the prim ary research. Conversely, any prim ary research effort should contain a thorough literature review, a com ponent that would have inform a tion very sim ilar in nature to the benefit transfer analysis. Also, the benefit transfer approach m a y provide a fallback position if the prim ary research is unsuccessful in providing benefit estim ates. After both have been discussed independently, a strategy that integrates them will be developed and proposed (see Section D.3.3).

D.3.1 Benefit Transfer Approach
The use of benefit transfers requires finding a previous econom ic study (or studies) that considers a com p arable situation to fishing n ear Scattergood Generating Station and contains dollar values per unit fish caught or a value function for dollar values per unit fish caught. Although there are num erous aspects to the bene fit transfer valuation, of particular im portance is having species sim ilar to the a ffected species and a population sim ilar to the local fishing population.
In order to identify an appropriate study or studi es, it would be essential to visit the site to

exam ine first-hand the type of recreational fishi ng that is occurring. At the sam e tim e, contact with key people in the area will be m a de to dete rm ine if any relevant studies or data do exist (see ref e rences f o r som e articles). W e would consider it essential that the f o llowing sources be contacted or exam ined:

1. State or federal hearings on previous Scattergood Generating Station perm it renewals.
2. State or f e deral hearings on previous power plant f acilities in the general Southern California area.
3. Authors of USEPA “in-house” studies associ ated with the Final Rule. In particular, USEPA’s RUM analysis of the California region (USEPA. 2004d) should be considered.

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4. Personnel from CDFG. Drs. Dale Squire s, Cynthia Thom pson and Sam Herrick are experts in fisheries econom ics and m a nagem e nt.
5. Researchers at universities or other research f acilities:

a. University of California, San Diego: Dr. Richard Carson (Departm ent of Econom ics) is an expert in contingent valuation and non-use valuation.
b. University of Calif ornia, Berkeley : Dr. Michael Hannem a n (Departm ent of Agricultural and Resource Econom ics) is anexpert in econom ic valuation and has studied sportfishing in Southern California.

c. University of California, Los Angele s: Dr. Trudy Cam e ron is an expert in

econom etrics and has studied sportfishing in California.
d. Local Consulting firm s: Jones and Stokes Inc. (particularly Thom as W e gge) of Sacram ento com p leted num erous sportfishing studies in California.

6. Existing bibliography sources available by internet:

a. National Marine Fisheries Service, Southeast Fisheries Center
b. Sportfishing Values Database

c. Environm ental Valuation Reference Inventory: Canadian based
d. Beneficial Use Values Database

e. Regulatory Econom ic Analysis Inventory, which is m a intained by the USEPA
f. ENVALUE, an environm ental value database m a intained in Australia

7. Investigation and Valuation of Fish K ills [Am e rican Fisheries Society (AFS), 1992] Excerpt: “Chapter 4 (“Monetary and Econom ic Valuation of Fish Kills”) dates back to the Pollution Comm ittee’s Monetary Values of Fish booklets of 1970 and 1975, which dealt with southern U.S. species. In 1978, the AFS North Central Division’s Monetary Values of Fish Comm ittee published Reim burse m e nt Values for Fish, addressing species in 12 northern states and 2 Canadian provin ces. To integrate these and other regional values, a special AFS Monetary Values of Freshwater Fish Comm ittee collected values from 135 federal, state, provincial, and privat e agencies and hatcheries. These data were published in 1982 as Part I of AFS Special Publication 13. For the present book, the Socioeconom ics Section has repeated the earlier survey to update replacem ent costs for killed fish and summ a rized procedures for estim ating the broader econom ic losses resulting f r om a f i sh kill.”
These potential sources will be used to obtain “o f f

- the-shelf ” values that could possibly be relevant to the affected species at Scattergood Generating Station. In addition, som e of these contacts m a y be useful as researchers, data sources, and/or witnesses for any hearings that

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m a y occur. They m a y also be useful as peer reviewers or as sources to identify peer reviewers.
D.3.2 Primary Research

There are several other m e thodologies that could be used to estim ate econom ic values for the species considered, but they will require som e level of prim ary research.
Data and program s could be obtained from the USEPA and exam ined to see if the results reported in USEPA (2004d) are defensible. If they are not, a new RUM m odel could be estim ated with the data. The m a jor changes introduced in the research would be to consider:

• Correcting (if necessary) problem s associated with the original analysis;

• Grouping the representative species individually rather than in a general grouping 8 ; and

• Specifying that the Scattergood Generating Station site rather than aggregate sites be used in the USEPA study (Southern California counties were used as sites).
The analysis would also update the angling activity and possibly generalize the RUM m odel in ways that current research is including.

One of the m a jor problem s in San Pedro Ba y and Santa Monica Bay is the potential for harvest of contam inated fish. California’s De partm e nt of Health Services issues seafood

consum ption warnings and it will be necessary to consider the effect of sportfish and seafood

consum ption advisories on the value of recrea tional fish. This was not done in the USEPA study (2004d).

A num ber of scientific studies and events brought the PCB and DDT contam ination of the

m a rine waters around Los Angeles to the attention of the press and subsequently the public. Som e of the first news appeared in the 1970s when, on several occasions, the Food and Drug Adm i nistration banned the distribution of several species of comm e rcial fish caught in Los Angeles coastal waters because of DDT found in fish tissues (Stull, Dryden and Gregory, 1987). The 1980s produced studies that brought to the public’s attention the potential danger from consum ing sport caught fish. A 1983 study by Gossett et al. dealt with the contam ination of sport fish, specifically wh ite croaker, and focused on the body burden of PCB/DDT in fish. Based on an intercept survey of sports anglers, Pu ffer et al. (1982) were able to estim ate the quantity of certain species of f

i sh consum ed by anglers. The Santa Monica Bay Seafood Consum ption Study (see M BC Applied Environm ental Sciences 1993) provides evidence that newspapers are an im portant source of inform ation about sport fish

8 For exam ple, white croaker and queenfish are consider ed i n th e cat egory“bot t o m f i s h” i n previ ous st udi es. If there were sufficient anglers targe t i ng th em , th en a cat egory“queenfi sh and whi t e croaker” coul d be desi gnat e d.

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consum ption health warnings. In a 1991-1992 fi eld survey, 1248 individuals fishing in the Long Beach-Los Angeles Harbor to Paradise Cove area of Los Angeles County were interviewed about their fishing activities. Those interviewed were asked the following question:
“Are you aware of any health warnings a bout eating fish from Santa Monica Bay? ”

W ithin the questionnaire, Santa Monica Bay is defined as anywhere from Malibu (or Point Dum e ) to Cabrillo Beach (near Long Beach). Of the 1228 answering this question, 942 people, or 76.7%, responded yes.
More recently, the California Departm e nt of Hea lth Services advised California residents to avoid eating shellfish, crabs, sardines and an chovies caught in Morro Bay because these fish and shellfish m a y be contam inated with dom oi c acid, a naturally occurring toxin that can cause illness or death. W a rnings regarding m e rcury in f i sh have been a comm on occurrence in the Calif ornia press.
The literature suggests that unit values are sm a ller when water quality is so low that states

m

u st advise anglers against the consum ption of sportfish (Jakus, et al. 1997). Additional research suggests that the effects of the advisori es vary across different types of anglers [e.g., anglers interested only in catch and release m a y actually gain from the advisories] (Jakus et al. 1998). Thus, the USEPA m odel will likely have to be changed to introduce the potential for seafood consum ption warnings on species, site, and m ode choices.

D.3.3 Strategy to Obtain Recreational Unit Values per Fish Caught
The initial portion of the benefit evaluation study would be to com p lete a benefits transfer analysis and determ ine whether or not the va lues obtained were reasonable for the purposes of

the decisions to be m a de. That is, if the m itigation strategy returned recreational benef its that were approxim a tely equal to the costs, it m a y be unwise and inefficient to m ove onto prim ary research because, in all likelihood, the estim ate of costs would not be “significantly larger” than the benefits. If, however, the bene fit transfer m e thod suggested that the benefits were to be sm all relative to costs, it m a y or m a y not be useful to do one of the prim ary research plans suggested in the previous sec tion. The quality of existing studies would also be a determ inant.
Discussions with key inf o rm ants in the benef it transf er work would determ ine the availability and reliability of data f r om the previous studies of recreational f i shing. In addition, som e notion of the potential im provem e nt in estim at es from using new data and a new m odel would be obtained.

W ith this inform ation and a better understanding on the costs of doing the prim ary research studies, decisions regarding what com b ination of benefit transfer and prim ary research would

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be m o st advantageous. The prim ary research would in all likelihood provide better estim ates of value, but m a y be m o re costly. Given the pres ent inf o rm ation, it is likely that the analysis perform e d by the USEPA in 2004 could be augm ented and im proved sufficiently to provide reliable unit values.

D.4 VALUATION OF COMMERCIAL FISHING ECONOMIC BENEFITS

The first determ ination would be whether comm e rcial fishing is affected by reduced

m o rtality to af f ected species. The CDFG and the NMFS would be consulted regarding species that the IM&E studies identified. Bo th producers and consum ers could gain from increases in comm e rcial catch, but the assessm ent would likely only estim ate the gains to direct producers (i.e., comm e rcial fisherm e n). This is based on the expectation that relatively

sm all changes in comm e rcial landings result f r om reduced IM&E m o rtalities. This is the approach that USEPA took in the 2004 study.
The approach that USEPA uses for assessing co mm e rcial benef its to producers bases the unit value on the ex-vessel price (som etim es referre d to as dockside price) of the species under consideration. One could use the ex-vessel pri ce as the unit value and determ ine benef its as the price tim es the additional harvest caused by the IM&E reductions. The logic of doing that rests on the assum p tion that the additional harv est does not induce increases in effort (inputs used in harvesting) after the reductions of entr ained and/or im pinged organism s. If this were entirely true, then the ex-vessel price tim es the increase in quantity harvested would represent producer surplus. However, USEPA appreciates th at this would not likely be true and that effort and costs would undoubtedly increase in the long run in response to increased

comm e rcial prof its (i.e., producer surplus). In th e absence of property rights to the harvest, one would expect the producer surplus to be elim inated. Recognizing this and allowing for uncertainty in effort response, the USEPA propos es using a range of 0-40% of the ex-vessel price tim es the increase in harvest as a m easure of the increase in producers’ surplus.

Additional econom ic inform ation on coastal pelagic species (e.g., sardine, anchovy, squid and m ackerel) and groundfish m a y be availabl e through the fisheries m a nagem e nt groups. For exam ple, anchovy has been m a naged for som e tim e (Huppert 1981) and m o re recently a

m a nagem e nt plan for the sm all coastal pelagic species has been developed (Bargm ann et al. 1998). These plans m a y contain inform ation that would perm it an analysis that is an im provem e nt to the USEPA approach.
In the unlikely event that the change in landings would be relatively large and cause a change in comm e rcial f i sheries prices, we would need to collect inf o rm ation on comm e rcial harvests and prices. There is not a good way to use benefit transfer m e thods for the consum ers’ surplus although USEPA is exploring one pr oposed by Bishop and Holt (2003). Presently, this approach does not look prom ising, and it doe s not appear that the change in comm e rcial landings will be suf f i ciently large to cause prices changes.

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However, if additional inform ation suggests pri ce changes, existing data from CDFG and the NMFS could be suf f i cient to estim ate an inve rse, general equilibrium dem a nd curve (see Just, et al. 2004 for a descripti on) for the species in question. W ith these estim ates, the benefits to consum ers could be calculated.

D.5 NON-USE BENEFIT VALUATION
Based on current knowledge, it does not appear n ecessary to estim ate non-use values. That is, the criteria USEPA proposed in the final ruling for their estim ation does not appear to be

me t

. But, in the unlikely event that non-use values will have to be estim ated, we would look to using a benefit transfer approach or doing prim ary research for Scattergood Generating Station. However, we do not believe that the m a gnitude of the non-use values would justify undertaking a prim ary research study for non- use values associated with Scattergood Generating Station.
Thus, if non-use values were needed, we woul d, in all likelihood, suggest using a benefit transfer m e thod. There have not been any studi es of non-use values associated with power plant activities per se. People have had to rely on studies associated with other types of activities. For exam ple, USEPA used a benefit transfer approach in their Proposal for the 316(b) regulations and in the NODA. USEP A (Tudor et al., 2003) reviewed num erous studies of use and non-use values that were associated with surface water im provem e nts (their Appendix A). Of those shown, only thr ee address both changes in fish populations and non-use values associated with them (Hua ng, et al. 1997; Wh itehead and Groothuis 1992; Olsen, et al. 1991).

W e propose considering these three studies inaddition to doing a review of the recent literature. The recent literature m a y be im porta nt because USEPA has placed som e em phasis on this ecological valuation recently. For exam ple, a m eeting entitled “Im p roving the Valuation of Ecological Benefits, a STAR Progress Review W o rkshop” was held in W a shington in October, 2004. The papers pres ented at that workshop are now available on the internet, and one of them is directly related to Calif ornia.

The results of this activity would likely be th e developm ent of a relationship (specifically a ratio) between use values and non-use values . For years, USEPA used the 50% rule, a practice that im plied that non-use values were 50% of use values. Our approach, just like

som e of their 316(b) efforts (Tudor 2003), would be to refine this ratio for situations m o re sim ilar to the changes associated with power plant operations.

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REFERENCES
Bargm a nn, G., D. Hanan, S. Herrick, K. Hill, L. Jacobson, J. Morgan, R. Parrish, J Spratt and J. W a lker. 1998. Am endm ent 8 (To th e Anchovy Fishery Managem e nt Plan) incorporating a nam e change to: The coasta l pelagic species fishery m a nagem e nt plan. Pacific Fisheries Managem e nt Council, Portland, OR.
Bishop, R. and M. Holt. 2003. “Estim ating Po st-Harvest Benefits from Increases in Comm e rcial Fish Catches with Im plication for Rem e diation of Im pingem e nt and Entrainm ent Losses at Power Plants”. Unpub lished Xerox. University of W i sconsinMadison. 10 pp.
Dotson, R. and R. Charter. 2003. “Trends inthe Southern California Sport Fishery”. CalCOFI Rep., Vol. 44: 94-106.
Gosset, R.W ., H.W

. Puffer, R.H. Arthur, J. F. Alfara, and D.R. Young. Levels of Trace Organic Com pounds in Sportfish from Sout hern California in Southern California Coastal W a ter Research Project biennial report, 29-37, Long Beach, Calif., 1981-1982.

Hanem a nn, W

. M., T. W e gge, and I. Strand. 1989. Developm ent and Application of a Predictive Model to Analyze the Econom ic Effects of Species Availability. National Marine Fisheries Service, Southwest Region, Term inal Island CA. Adm i n. Rpt. SW R 89-02. June.
Huang, J. T. Haab, and J. Wh itehead. 1997. “W illingness to Pay for Quality Im provem e nts: Should Revealed and Stated Pr eference Data Be Com b ined? ” , Journal of Environmental Economics and Management 34: 240-255.
Huppert D. 1981. “Econom ic Analysis for Northern Anchovy Managem e nt” in Economic Analysis for Fisheries Management Plans , L. Anderson, ed., Ann Arbor Science Publishers, Inc. Ann Arbor, MI.
Jakus, P. M., M. Downing, M. Bevelhim er, and J. Fly. 1997. “Do Sportfish Consum ption Advisories Affect Reservoir Anglers’ Site Choice? ” American J. of Agricultural Economics 25(3): 196-204.
Jakus, P., D. Dadakas, and J. Fly. 1998. “F ish Consum ption Advisories: Incorporating Angler-specific Knowledge, Habits and Catch Rates in a Site Choice Model”, American J. of Agricultural Economics 26(2): 1019-1024.
Just, R.E., D.L. Hueth, and A. Schm itz. 2004. “ The Welfare Economics of Public Policy: A Practical Approach to Project and Policy Evaluation .” Edward Elgar, Cheltenham UK. 688 pp.

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Kling, C. and C. Thom son. 1996. The Im pli cations of Model Specification for W e lfare Estim ation in Nested Logit Models. Am. J. Agr. Econ . 78 (February):103-114.
MBC Applied Environm ental Sciences. 1993. Santa Monica Bay Seafood Consum ption Study Septem ber 1991 to August 1992 Final Draft Report, July 1993.
McConnell, K.E., Q. W e ninger and I. Strand. “J oint Estim ation of Contingent Valuation and Truncated Recreation Dem a nds,” Chapter in Valuing the Environm ent Using Recreation Dem a nd Models (Eds. Kling and Herriges).Edward El gar Publishers, Cheltenham , UK. 199- 216. 1999.
Olsen, D., J. Richards, and R. Scott. 1991. “Existence and Sport Values for Doubling the Size of Colum b ia River Basin Salm on and Steelhead Runs”, Rivers 2(1): 44-51.
Puffer, H.W ., M. J. Duda, and S. P. Azen “P otential Health Hazards from Consum ption of Fish Caught in Polluted Coastal W a ters of Los Angeles County” North American Journal of Fisheries Management 2:74-79, 1982.
Stull, J.K., K.A. Dryden and P. A. Gregory “A Historical Review of Fisheries Statistics and Environm ental and Societal Influences o ff the Palos Verdes Peninsula, California” CalCOFI Report , XXVIII: 135-154,1987.

Thom son, C. and S. Crooke 1991. Results of the Southern California Econom ic Sportfishing Survey. NOAA Technical Mem o randum , NMFS, Southwest Fisheries Center, August.
Tudor, L., R. W a rdwell, E. Besedin, and R. Johnston. 2003. Com p arison of Non-use and Use Values from Surface W a ter Valuation Studies . Mem o to the 316 (b) Record. Office of W a ter, USEPA. W a shington, D.C.
USEPA. 2004a. “§316(b) Phase II Final Rule, Re gional Studies, Part A: Evaluation Methods, Chapter A9: Benefit Categories and Valuation”. http://www.epa.gov/ waterscience/316b/econbenefits/final.htm

. USEPA. 2004b. “§316(b) Phase II Final Rule, Re gional Studies, Part A: Evaluation Methods, Chapter A10: Methods for Estim ati ng Comm e rcial Fishing Benefits”, http://www.epa.gov/waterscience/316b/econbenefits/final.htm

. USEPA. 2004c. “§316(b) Phase II Final Rule, Re gional Studies, Part A: Evaluation Methods, Chapter A11: Estim ating Benefits with a Random Utility Model”. http://www.epa.gov/waterscience/316b/econbenefits/final.htm

. USEPA. 2004d. “§316(b) Phase II Final Rule, Re gional Studies, Part B: California Region, Chapter D4: RUM Analysis”.

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http://www.epa.gov/waterscience/316b/econbenefits/final.htm

. USEPA. 2004e. “§316(b) Phase II Final Rule, Re gional Studies, Part B: California Region, Chapter B3: Comm e rcial Fishing Analysis”.
http://www.epa.gov/waterscience/316b/econbenefits/final.htm

.
Wh itehead, J. and P. Groothuis. 1992. “Econom ic Benefits of Im proved W a ter Quality: A Case Study of North Carolina’s Tar-Pam lico River”, River 3(3): 170-178.

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