1 Site Visit Report Hay nes Generating Station ( HnGS ) 6801 Westminster Avenue Long Beach, CA 90803 September 2, 2009 1.0 Background and Objectives The Environmental Protection Agency (EPA) is in the process of developing 316(b) cooling water intake structure requirements that reflect the best technology available (BTA) for minimizing adverse environmental impact for all existing power plants and manufacturing facilities. As part of this process, EPA staff is visiting electric generators and manufacturers to be tter understand the cooling water intake structure (CWI S) technologies in use at facilities, including the site

specific characteristics of each facility and how these affect the selection and performance of CWI S technologies. EPA is also visiting facilit ies to better understand cooling water use and specific issues or technologies that can affect 316(b) compliance. EPA selected Hay nes Generating Station ( HnGS ) for a site visit due to its coastal location near the Pacific Ocean and its recent repowering p roject. 2.0 Facility Description HnGS is a natural gas

– fired steam electric generating facility located in the City of Lo ng Beach in Los Angeles County (a small portion of the facility property lies within the City

of Seal Beach, Orange County). HnGS is owned and operated by the City of Los Angeles Department of Water and Power (LADWP). The facility occupies approximately 160 acres of an industrially zoned site approximately 2 miles northeast of the entrance to Alamitos Bay

. The propert y parallels the east b ank of the San Gabriel River for approximately 3⁄4 mile north of 2 nd Street to State Highway

22. The eastern edge of the property is bounded by

the Orange County Flood Control District Channel. AES’s Alamitos Generating Station lies opposite HnGS on the wes t bank of the San Gabriel River. A large residential neighborhood, L eisure World, lies across the flood control channel and extends the entire length of Hay nes’ eastern boundary

. Another residential neighborhood, Island Village, lies southeast of the fac ility ’s southern boundary

. Elevation at the site is relatively flat, with most of the site situated between 10 and 15 feet a bove sea level (asl)

. The southern portion of the property is occupied by the generating units, parking areas, switchyard, and active fuel storage tanks, as well as miscellaneous storage and maintenance buildings. Large fuel storag e tanks used to occupy the northern portion of the property, although they have since b een decommissioned and removed. This area has been set aside by LADWP for the next planned2 repowering phase due to commence construction in January 20 11, consisting of six 100 MW simple cycle combustion turbines wi th dry cooling. Wastewater discharges to the San Gabriel River and water withdrawals from Alamitos Bay

are covered under NPDES Permit No. CA0000353, which is administered at the state level b y a regional water board. Order No. 00

- 081, issued by the Los Angeles Regional Water Board, expired on May 10, 2005 but has been administrativel y continued to the present. The facility had been previously

notified that a reissued permit was delayed pending the outcome of the State Water Board’s ongoing once

- through c ooling policy development. At the time of EPA’s site visit , it was unclear when the NPDES permit would be reissued. Power generation began in 1962

- 3 with the commissioning of Units 1 & 2. Units 5 & 6 were commissioned in 1966

- 7. Units 3 & 4 have been de commissioned and retired and were replaced by combined cycle generating unit s (Unit s 8 , 9 and 10 ) in 2005. Hay nes currentl y has 165 employees. 3.0 Electricity Generation and Transmission HnGS currentl y operates four conventional steam turbine units (Units 1 & 2, 5 & 6) as well as one combined cycle sy stem that consists of two combustion turbines (Units 9 and 10) and a heat recovery steam generator (HRSG) (Unit 8)

. The combined generating capacity for HnGS is approximately 1, 625 MW ( Table 1 ). Facility representatives noted that, with the exception of Unit s 8 , 9 and 10 , the capacity utilization rate (CUR) at HnGS has consistently tre nded downward over recent ye ars as more modern and efficient sources have come online in the region , including an expanded renewable portfolio to meet s tate greenhouse gas objectives. However, depending upon federal and state climate legislation, greater dependence on these local plants for base load energy suppl y and the balancing of new intermittent renewable resources may be necessary

if LADWP is required to undertake an earl y divestiture of its coal resources.3 Table 1 –HnGS Rate d Capacity
Unit Rated capacity (MW) 2008 CUR Unit 1 230 13% Unit 2 230 13% Unit 5 330 7.3% Unit 6 260 1 7.3 % Unit 8 575 41 % HnGS total 1625 25 % Energy efficiencies for HnGS ’s four natural

- gas fired units are typical for units of this ty pe and age. Under peak conditions, Units 1 and 2 can operate at approximate efficiencies of 33% (9,650 BTU/kWh) while Units 5 & 6 which are supercritical units are slightl y more efficient at 36% (9,400 BTU/kWh). The combined cycle unit s , taken as a whole, operate mor e efficientl y than conventional steam boiler units. Under optimal conditions, the Unit 8 , 9 and 10 efficiency can reach 50% or higher (6,800 BTU/kWh). LADWP representatives noted that capacity utilization rates are an inexact metric for determining a par

ticular facility ’s importance to the overall s ys tem. Although HnGS ’s overall CUR is relatively low, it occupies a critical position in LADWP’s overall generation and transmission plans during peak periods. The existing transmission system is limited in i ts ability to move electricity

between the northern and southern sections of LADWP’s service areas during high demand periods. The ph ys ical location of HnGS , along with LADWP’s other coastal units, enables LADWP to maintain a proper balance in the s ys tem without compromising service. This is particularly notable since LADWP is its own balancing authority and as mentioned in Section 10 of this report, as a vertically integrated utility

responsible for its own generation, transmission, and distribution of e lectricity , does not rely on the energy

market for power purchases to supply its energy needs. Therefore, LA DWP believes that its coastal plants serve a critical function in providing local resource adequacy , reliability , and s ys tem stability

. 4.0 Cooling Wat er System and Intake Structure All steam units at HnGS , including the Unit 8 HRSG, use ocean water for condenser cooling in a single

- pass configuration (“once

- through cooling”). HnGS operates one CWIS to provide condenser cooling water to each of the five generating units. Water is withdrawn from San Pedro Bay , via Alamitos Bay through seven openings in a bulkhead wall in the northeast corner of the Long Beach Marina. Seven 8

- foot diameter pipes (onl y six are ty picall y used) lead

1 Unit 6 was derat ed from 330 to 260 MW in 2004. The facility ultimately plans to retire both Units 5 and 6.4 under the San Gabriel Ri ver to a manmade canal extending 1.5 miles northeast to the station, where six separate screenhouses draw water from the canal

. The screenhouses for Units 1 and 2 are identical, with each containing two screen bay s fitted with stationary screens. Each scr een is 10 feet wide with 3/8

- inch wire mesh panels. Velocities at the screens are reported to be 0.9 feet per second (fps). Downstream of each screen is a circulating water pump rated at 48,000 gallons per minute (gpm), for a total capacity of 192,000 gp m, or 276 million ga llons per day (mgd)

. The screenhouses for Units 5 and 6 are identical, with each consisting of four screen bay s fitted with vertical traveling screens (Figure 1)

. Each screen is 8 feet wide with 3/8

- inch wire mesh panels. Velocities at the screens are reported to be 0.8 feet per second (fps). Screens are normally rotated and cleaned once every 8 hours. A high

- pressure spray removes an y debris from the screens, including impinged fish, for disposal at a landfill. Two circulating wate r pumps for each unit are located downstream of the screens, with a design rating of 80,000 gpm, for a total capacity of 320,000 gpm, or 461 mgd

. Unit 8 uses the two screenhouses previously used by Unit 3 and Unit 4. Each screenhouse consists of two screen bay s (Figure 2)

. Each screen is 10 feet wide with 3/8

- inch wire mesh panels. Velocities at the screens are reported to be 0.7 feet per second (fps). Screens are normally rotated and cleaned once every 8 hours. A high

- pressure sp ray removes an y debris from the screens, including impinged fish, for disposal at a landfill. Two circulating water pumps for each unit are located downstream of the screens, with a design rating of 40,000 gpm for a total capacity

of 160,000 gpm, or 230 m gd. The total design intake flow (DIF) for HnGS is 967 mgd.

Figure 1 – Plan View Unit 5 & 6 Screenhouse5 Figure 2 – Unit 8 Screenhouse Data provided b y HnGS representatives shows the average dail y intake flows from 2005 through 2008 ( Table 2 ).

Table 2 – Average Annual Intake Flows Year Average Annu al Intake Flow (mgd) Percentage of DIF 2005 775 80 2006 772 80 2007 619 64 2008 738 76 A direct correlation between flow and generating capacity utilization cannot be easily made since generating CUR do not account for startup/shutdown periods, nor do they

account for “hot standby” periods during which units are held in a near - ready state wi thout generating electricity but still require cooling water withdrawals

. HnGS conducts periodic heat treatments to control biofouling (e.g., mussel growth) in the cooling water s ys tem, although these occur infrequently

. During heat treatment control gate s on the intake and discharge tunnels are closed while a by pass gate is opened allowing all water to recirculate through the s ys tem until the temperature has reached 115° F and has circulated for 120 minutes. Biofouling is also controlled through periodic chlorine (sodium hy pochlorite) injections to the intake flow. Chlorination occurs at each unit for 40 minutes twice per day

.6

5.0 Impingement and Entrainment Information Following the adoption of the Phase II rule, HnGS initiated compliance activities by submitting a Proposal for Information Collection (PI C) in October 2005 that outlined plans to conduct a source water characterization study

. Impingement and entrainment technologies would also be evaluated for their pot ential use at the site. The PI C identified fine

- mesh traveling screens, cylindrical wedgewire screens, operational measures, modular inclined screens and restoration as technologies that might offer some benefit to HnGS

. These evaluations were not comple ted, however, due to the suspension of the Phase II rule. At the direction of the Regional Water Board, HnGS co nducted a source water characterization study in 2006 to determine the composition and abundance of all life stages of fish and shellfish that might be influenced b y the intake structure (baseline characterization study)

. HnGS collected data from nine so urce water sampling locations: six in San Pedro Bay and three in Alamitos Bay

. HnGS collected monthly

sampling every

six hours in a 24 hour period at each location which allowed for diel characterization

. As part of this study , HnGS also conducted impingement and entrainment sampling. HnGS collected impingement samples at the traveling screen for each unit four times per week during 2006 2

. HGS HNGS conducted biweekl y entrainment sampling in front of the bulkhead at the L ong Beach Marina. Facilit y representatives stated that 95% of the entrained fish were forage fish (gobies and b lennies). HnGS publish ed the study in November 2007. Because HnGS does not employ an y t echnologies specificall y designed to reduce impingement or entrainment, detailed effectiveness studies have not been performed on the current cooling s ys tem
. 6.0 Cooling Tower Feasibility Facility representatives noted that the feasibility of cooling towers at the H n GS location has been considered at different points, whether as part of a repowering project or to retrofit one of the existing units. HnGS has not conducted a formal cost and engineering feasibility anal ys is, however. A report prepared for the California Ocean Protection Council (OPC) and State Water Board in 2008 identified several obstacles that would influence the feasibility of cooling towers at the HnGS location

. Sufficient space is available at the existing locat ion, primarily in the area where fuel oil tanks have been removed. Visual impacts in this location would likely be limited given the industrial nature of most of the surrounding area. The proximity of residential neighborhoods in Seal Beach, however, wou ld likely require noise mitigation measures, such as fan deck barrier walls and grade

- level barrier walls. The 2008 OPC study

considered these obstacles and configured three separate cooling towers on the northern portion of the facility with appropriate n oise

2 The impingement samples do not represent the intake location as the travelling screens are located at the end of a long intake canal.7 abatement technologies. The initial capital cost for these towers was estimated at $152 million, excluding long

- term costs such as operation and maintenance and energy penalty costs. During the site visit, facility representatives noted that oppositi on from residents in nearb y neighborhoods was likely to be significant if cooling towers were planned for HnGS , citing the opposition during the Unit 8 repowering project. Representatives also noted that since the OPC study was issued, LADWP has decided t o move forward with a repowering project to replace Units 5 & 6 using much of the old tank farm area for the replacement units. This project, consisting of six combustion turbines with dry cooling, is slated to commence around January 20 11

. Most signific antly , however, representatives noted that retrofitting the existing once

- through cooling s ys tems for Units 1 & 2, 5 & 6 with cooling towers made little economic sense given the age and cap acity utilization of each unit. 7.0 Debris Handling Screens at HnGS can collect notable amounts of debris following storm events, although floating booms in the intake canal can provide some control. An y debris captured on the bar racks or traveling screens is disposed of in a landfill. 8.0 Repowering/Future Uses LADWP complete d the Unit 3 & 4 repowering project in 2005, replacing these units with the Unit 8 , 9 and 10 combined cycle s ystem using the existing (once

through) cooling s ys tem from Units 3 and 4

. The new unit consists of two gas combustion turbines and the HRSG. The replacement unit generates electricity at an efficiency

rate 30 to 40 percent higher than Units 3 & 4, reducing per

- unit fuel consumption, greenhouse gas emissions and NOx emissions. 3 LADWP is also pursuing a repowering project for Units 5 & 6 that would retire those units and replace them with 6 quick

- start gas combustion turbines with a total capacity of 600 MW. The gas turbines would be located on land previously occupied b y fuel oil tanks and might complicate placement of any cooling tow ers for other units. Facility

representatives noted that this project would likely be air cooled. 9.0 Cooling Ponds HnGS does not use cooling ponds for condenser cooling. 10.0 Ownership LADWP is the largest municipally owned utility

in the country

with a service p opulation of approximately 4 million people. LADWP maintains a total generating capacity

of approximately

7,200 MW from diverse portfolio of fossil,

3 According to project eng ineers, closed

- cycle cooling was not considered at the time of the retirement of Units 3 and 4.8 hydroelectric, r enewable, and nuclear units. HnGS is one of three LADWP

owned facilities on the Californi a coast that continues to use once

- through cooling (together with the Harbor and Scattergood Generating Stations). As a vertically

integrated utility , LADWP owns and operates the generating, transmission and distribution systems that provide electricit y t o a dedicated customer base. This transmission system is not limited to the City of Los Angeles, but extends into Nevada, Utah, and Arizona. The s ys tem is used to import power to all locations (LADWP owned and power exc hanges with other utilities). This differs from many investor

- owned utilities, such as Pacific Gas & Electric or Southern California Edison, which must rely on the open market to procure a significant portion of their electricity needs. LADWP must obtain approval from the Los Angeles City Council to implement any electricity

rate increases. LADWP is in the process of developing a new Integrated Resource Plan ( IRP ) and is currentl y soliciting input from the public on this new guidance document. This new 2010 IRP will help set the course that LADWP will take in determining the best path to take for repowering the existing OTC facilities. 11.0 316(a) Thermal discharges to surface waters are governed by the state’s Thermal Plan (1972), which creates separate requirements for new and existing thermal discharges to ocean waters. As an existing thermal discharger, HnGS is subject to the Thermal Plan’s narrative requirement th at an y thermal discharge must ensure protection of identified beneficial uses. This requirement is incorporated into the existing permit as a temperature limitation of no more than 100 ° F during normal operation and 120 ° F during heat treatments. The facility does not have a 316(a) variance for thermal discharges and has complied with the existing limitation during its most recent permit cycle. HnGS was notified that the San Gabriel River was being reclassified from an ocean to an estuary
- ty

pe rec eiving water. Under the Thermal Plan, thermal discharges would be limited to no more than 20 ° F above the background and may not exceed 86 ° F. LADWP has disputed the Regional Board’s interpretation and has conducted hydrody namic studies which affirm LADW P’s claim that the San Gabriel River at the point of discharge is characteristic of an enclosed bay rather than an estuary , which would entail less stringent thermal discharge limits

. 12.0 Ash Handling HnGS does not generate any ash. 13.0 Air Emissions Controls Uni ts 1 , 2, 5 and 6 each employ selective catal yt ic reduction to minimize NOx emissions. The gas combustion turbines that are part of the Unit 8 combined9 cycle sy stem employ

dry low NOx burners in addition to selective catal yt ic reduction. 14.0 Additional Informa tion Facility representatives noted that an ongoing legal battle over the availability of emission credits within the South Coast Air Quality Management District have raised the possibility

that no new projects would be able to obtain the necessary air per mits. This would include facilities retro fitted with wet cooling towers. HnGS ’s current NPDES permit, adopted in 2000, does not contain any numeric or narrative limitations regarding impingement or entrainment due to cooling water withdrawals. The permit carries over findings from previous permits that essentially

concluded the HnGS cooling water s ys tem represented the “best technology

available” for compliance with 316(b)

. A lthough these determinations were made prior to the adoption of the state policy on once - through cooling , future studies will determine whether this statement is still accurate or whether other technologies are available that would represent “best technology available” with costs that can be borne by industry

. HnGS is required to conduct semi

annual impingement monitoring coinciding with scheduled heat treatments. In addition to once

- through cooling water, HnGS discharges a small volume of wastewater from several low volume waste streams. These low volume wastes c onsist of boiler blowdown, floor drains, metal cleaning wastes (chemical and non - chemical) and settling basin discharges, and are commingled with once

through cooling water prior to discharge through one of 6 permitted outfalls. All wastewater is discharg ed the San Gabriel River and eventuall y to the Pacific Ocean. Domestic w astewater is captured in portable Baker tanks and disposed of and treated offsite. HnGS must comply

with both water quality - based and technology

- based effluent limitations for its was tewater discharge to the San Gabriel River. In 1988, the State Water Board granted a variance to the total residual chlorine water quality standard for biofouling control in the cooling s ys tem. EPA granted a similar variance for the total residual chlori ne effluent limitation applicable to steam electric facilities. It is not clear if these variances will be revisited in any future permit reissuance. As noted in Section 11.0 above, under the current NPDES permit for HnGS , the San Gabriel River at the poi nt of discharge is considered part of the Pacific Ocean. Thus, water quality

- based limitations are addressed b y the state’s Ocean Plan. R eclassif

ication of the receiving water from ocean to either an estuary or an embay ment , will mean that future water q ualit y - based limitations will be derived from the California Toxics Rule. L imits under the CTR may be more stringent than existing limits for certain parameters (e.g., metals). Attachments10

Attachment A List of Attendees Attachment B Site Photos Attachm ent C Facility Flows Attachment D Alden Report for Phase II Compliance (December 2004) Attachment E Addendum to Alden Report for Phase II Compliance (April 2007) Attachment F Impingement Mortality and Entrainment Study

(November 2007) Attachment G Impingement Mortality and Entrainment Study

Appendices (November 2007)11

Attachment A -- List of Attendees Paul Shriner, EPA Jan Matuszko, EPA John Kemmerer, EPA Region IX Tim Havey , Tetra Tech Kelly Meadows, Tetra Tech Ken Silver, LADWP Vic Ybarra, LADWP Kim Burmahln, LADWP Susan Damron, LADWP Dipak Patel, LADWP Dawson Dong, LADWP Ian Guthrie, LADWP Katherine Rubin, LADWP Also see attached materials for the sign

- in sheet.12 Attachment B

— Site Ph otos13 N14 Attachment C

—Facility flows Please see the attached materials. Attachment D -- Alden Report for Phase II Compliance (December 2004) Please see the attached materials. Attachment E -- Addendum to Alden Report for Phase II Compliance (April 2007) Please see the attached materials. Attachment F -- Im pingement Mortality and Entrainment Study (November 2007) Please see the attached materials. Attachment G -- Im pingement Mortality and Entrainment Study Appendices (November 2007) Please see the attached materials.