Cosumnes power plant (01-afc-19) data response, set 1A

SACRAMENTO MUNICIPAL UTILITY DISTRICT

MEMORANDUM

DATE: January 7, 2002

CPP 02-001
TO: File
FROM: Kevin Hudson

SUBJECT: Phone Record of Conversation with Prabhakar Somavarapu at the Sacramento Regional Wastewater Treatment Plant

I spoke with Prabhakar Somavarapu, Civil Engineer for the Sacramento Regional Wastewater Treatment Plant. I inquired if there was space on County property at SRWTP to locate a power plant requiring approximately 30 acres. He said that space is definitely not available contiguous to the existing Carson Ice-Gen Plant. When I asked if there was other space available on the County’s property, he said that eventual buildout of the treatment plant over 900 acres will require use of the remaining development space for treatment activities. Prabhakar said that the remaining buffer zone is designated as wildlife habitat/refuge, and development could not take place in those areas. The current rate of effluent is 400 MGD, and eventual buildout of SRWTP is 800 MGD. Eventual buildout will require space for biosolids fields, settling ponds, interceptor pipes, and interconnecting piping.

cc: John Carrier (CH2M HILL)

Chron File

INSERT Figure Alt-2, Location of Alternative Site 1

INSERT Figures Alt-5a and Alt-5b

In AFC Section 8.2, Biology and 8.14, Water Resources, Clay Creek and the tributaries to Clay Creek are briefly described. The sections state that Clay Creek via Laguna Creek is a tributary to the Cosumnes River, and that the Cosumnes River contains anadramous fish species. In addition, Appendix 8.2B of the AFC contains a letter from NMFS that contains LORS information and a summary of conservation measures, yet the Magnuson-Stevens Act is not listed in Table 8.2-1, no fish species are listed in Table 8.2-4, nor is the National Marine Fisheries Service (NMFS) listed as a contact in Table 8.2-5.

7. 
   Please provide more detail (e.g., habitat types, spawning areas, jurisdictional wetland areas) about the biological resources and fish species found in Clay Creek and discuss the likelihood of anadramous fishes using that stream channel as habitat.
   

8. 
   Please provide a schedule for when the Biological Assessment will be submitted to NMFS, an estimate of how long consultation may take, and when a draft and final Biological Opinion from NMFS will be provided to the Energy Commission staff. Provide a record of communication with the agency person assigned to the project.
   

TABLE BR-8 Anticipated Consultation Schedule
Submit NPDES application	January 15, 2002
	RWQCB/EPA/ACOE initiate consultation with NMFS	January 31,2002
Applicant Prepares Biological Assessment		February 15, 2002
	NMFS Submits Biological Opinion.	May 15, 2002
RWQCB/EPA/ACOE initiate consultation with USFWS		January 31, 2002
	Prepare Biological Assessment USFWS	February 27, 2002
USFWS Submits Biological Opinion.		July 15, 2002

9. 
   Please provide the temperature and total dissolved solids limitations for any threatened and endangered species that may be in the receiving waters.
   

In AFC Section 8.14.4.1, page 8.14-17 and Appendix 8.14A, the discharge of the circulating water system blowdown into Clay Creek is described. It also states that water quality will meet the requirements of the NPDES permit that will be issued.

10. 
    Provide information on whether the blowdown water will be discharged continuously throughout the day, month, and year, and what the rate of flow of the discharge would be when occurring.
    

11. 
    Provide monthly average water temperatures in Clay Creek and the anticipated temperature of the blowdown water.
    

TABLE BR-11 Monthly Average Temperatures of Clay Creek, (Based on Year 2000)
	Month		Temperature (°F)
January		52
February		55
March		55
April		68
May		67
June		72
July		75
August		82
September		75
October		68
November		61
December		54

12. 
    Provide a map showing the location of the proposed outfall, and describe the habitat within the immediate area of the outfall. Identify other discharges into Clay Creek for the entire section upstream of the project site to the conjunction of Clay Creek with Hadselville Creek downstream of the site.
    

13. 
    Provide rate of flow information for Clay Creek. Describe how adding the blowdown water discharge may change the hydrology of the creek and how that may effect the biological resources of Clay Creek.
    

TABLE BR-13 CPP: Discharges from Rancho Seco Plant (in cfs)
			Average		Maximum		Minimum
	Jan		12.39		12.82		11.82
	Feb		13.96		14.42		13.67
Mar		13.07		14.24		12.11
Apr		12.87		15		11.63
May		12.97		13.94		11.01
June		9.41		12.65		5.94
Jul		11.52		12.84		9.51
Aug		10.76		13.39		8.06
Sep		11.75		14.73		10.29
Oct		10.68		14.56		9.72
Nov		10.94		13.38		9.37
Dec		12.06		12.76		11.32
RSP Discharges, Plus 3.6 cfs from CPP
		Jan		15.99		16.42		15.42
		Feb		17.56		18.02		17.27
		Mar		16.67		17.84		15.71
Apr		16.47		18.6		15.23
May		16.57		17.54		14.61
June		13.01		16.25		9.54
Jul		15.12		16.44		13.11
Aug		14.36		16.99		11.66
Sep		15.35		18.33		13.89
Oct		14.28		18.16		13.32
Nov		14.54		16.98		12.97
Dec		15.66		16.36		14.92

14. 
    Provide an analysis of the anticipated percentage of the overall volume of water in Clay Creek that the discharge would be on a month-by-month basis.
    

TABLE BR-14 Percentage of total flow in Clay Creek made up by CPP
Month	Percentage of Total Flow
Jan	29.1%
Feb	25.8%
Mar	27.5%
Apr	28.0%
May	27.8%
June	38.3%
Jul	31.3%
Aug	33.5%
Sep	30.6%
Oct	33.7%
Nov	32.9%
Dec	29.9%

Table 8.2-4 on page 8.2-35 describes a 1.5-acre storm water detention pond. The location of the pond is not mapped in the figures, although it is proposed to be located north of the project site.

15. 
    Provide a figure of the location of the 1.5-acre storm water detention pond.
    

A proposed table of contents of the Biological Resources Mitigation Implementation and Monitoring Plan (BRMIMP) is supplied in Appendix 8.2D. In the proposed outline Section 4.4, Wetland Protections, there are subsections that do not correspond to that heading, i.e. Sections 4.4.6 through 4.4.8.

16. 
    Please provide a draft BRMIMP with the following additional sections and include any information in the sections such as impact avoidance measures and proposed mitigation where appropriate.
    

• 
  Regional Setting describing all habitats that may be impacted;
  

• 
  Biological Resources to be impacted (by species);
  
• 
  Construction schedule;
  
• 
  Under the existing heading for Mitigation Measures for Sensitive Biological Resources, include subsections that address the proposed species specific mitigation and avoidance measures, for species such as (but not limited to) Swainson’s hawks, Western burrowing owls, and anadramous fish species.
  
• 
  Habitat compensation measures to mitigate for habitat loss;
  
• 
  Move the Habitat Revegetation Plan (4.4.8) to a separate section;
  
• 
  Add a section for pre-construction and post-construction aerial photos of the project area at a 1” to 100’ scale; and
  
• 
  Agency agreements and permits.
  

Appendix 8G of the AFC contains the CNDDB printouts dated 6/18/2001 with the locations of sensitive species near the site.

17. 
    Provide copies of the CNDDB forms that were filled out during biological surveys conducted in 2000 and 2001.
    

There are three drainages in the project site that the applicant proposes to reroute. There also may be impacts to Clay Creek, vernal pools along the transmission line corridor (AFC Section 8.2.5), and wetlands along the proposed natural gas pipeline route (AFC Table 8.14-8). AFC Section 8.2.3.2 states that wetland delineations of the project area were completed in April 2000. Wetland areas were depicted in AFC Figures 8.2-1 and 8.2-1R very generally and on a regional scale. USFWS guidance on vernal pools states that indirect and direct impacts are likely to occur when any project is within 250 feet of a vernal pool. Staff does not have enough information to make a final determination on whether direct or indirect impacts may occur to the vernal pools during the construction and maintenance of the transmission towers, gas pipeline, project site, construction laydown area, and water pipeline.

18. 
    Please provide the wetland delineation surveys that were completed of the site, the construction laydown area, and along all the linear facilities. Include a figure with the delineation points mapped, the wetland delineation data sheets that were completed, a timeline for when the wetland delineation will be submitted to the Army Corps of Engineers for jurisdictional wetland classification, and a discussion of when they expect to initiate consultation with the USFWS.
    

19. 
    Provide a figure (or aerial photos) with a scale of 1” = 100’ outlining the vernal pools and where jurisdictional wetlands occur within 250 feet of the site, the construction laydown area, and along all the linear facilities.
    

20. 
    Provide a table that estimates the amount of wetland habitat that may be directly or indirectly impacted within the 250-foot buffer.
    

Table 8.2-4 summarizes the permanent and temporary project impacts to biological resources at the site. On AFC page 8.2-14 it states that the proposed 20-acre construction laydown area on the south side of Clay Station East Road has not been evaluated for the potential presence of vernal pools and special-status species. In the AFC the proposed construction laydown area is considered to have a temporary impact.

21. 
    Provide the timeline for when the proposed laydown area would be initially graded, whether it will be graveled, when the area will be revegetated and how long after the revegetation the restoration will be considered complete.
    

The area would be revegetated within 60 days after construction laydown uses are completed. Revegetation would consist of restoring pre-construction topography, skimming off the gravel, restoring salvaged topsoil and seeding with a crop of winter barley. This will hold soil and allow local vegetation to recolonize the site. We expect the site to be “complete” 24 months from seeding.

22. 
    Provide a draft of the laydown area restoration and revegetation plan.
    

23. 
    Provide information on how the stream channel (that is seen on the aerial photo submitted during data adequacy review), that runs North-South through the proposed laydown area, may be impacted by grading and describe anticipated changes to the hydrology of the area.
    

The eastern swale is the same as that that would be re-routed on the north side of Clay East Road by CPP construction. The laydown area would fill and culvert this swale on the south side of Clay East Road, or if the ACOE suggests it, re-route the swale to the east around the end of the construction area to align more directly with downstream flow. In either case, the swale would be filled according to the terms of an ACOE Section 404 permit. Hydrology would change only in that the swale would be approximately 50 yards further east than presently. It is anticipated that in as little as 5 years naturally occurring vegetation would re-establish in the new swale and function equivalently to the existing swales.

24. 
    Identify who did the surveys, methods used, biologist qualifications, dates surveys were completed, field survey results, and any sensitive habitats and sensitive species occurrences found on or near the proposed laydown area.
    

AFC page 8.2-7 states that 16 special-status animals potentially occur in the project area. The section then briefly describes 11 of them and Table 8.2.3 (pages 8.2-30 to 8.2-34) lists 17 special-status animal species.

25. 
    Please clarify which special-status species may be present within 1 mile of the project site, including the construction laydown area, and within 1000 feet of all project linears.
    

26. 
    If there are special-status species that were not described in AFC Section 8.2.3 (pages 8.2-7 to 8.2-9), please include information on what habitat types they occupy and what the likelihood of presence is for the project site, laydown area, and linear facilities.
    

27. 
    Identify whether the species were observed in any of the surveys conducted at the site, the construction laydown areas, or along project linears.
    

The Cosumnes River Nature Preserve is within the region of the proposed project site and AFC Section 8.4 (Land Use) has a brief regional description, but there is limited information for the regional biological resources. On page 8.2-7 of the AFC, the Cosumnes River Nature Preserve is listed as having giant garter snakes (a state- and federally-threatened species) present and there is a map (Figure 6.1-5) that indicates the proposed gas pipeline route will go through the Preserve.

28. 
    Please discuss all areas of critical concern (as defined in section 1702 (q) of Title 20 of the California Code of Regulations) related to biological resources in the proposed project region (e.g., within 30 miles). For all areas of critical concern, identify the distance from the proposed project site, size (in acres), habitat types, ownership, and sensitive plant and animal species present.
    

On page 8.2-7, in the special-status animals subsection, the AFC states that CNDDB records indicate that the valley elderberry longhorn beetle (VELB) (state- and federally-threatened species) is likely to occur along the Cosumnes River and other rivers that the proposed gas pipeline may cross. However, the AFC does not contain VELB field survey results.

29. 
    If VELB surveys were conducted for the project site and all project linears, then please provide the survey results (field survey dates, names and qualifications of biologists, transect spacing, locations and size of elderberry shrubs). If VELB surveys were not conducted, then conduct the appropriate (USFWS protocol) surveys and provide the survey results.
    

AFC Section 8.2.4.2 (page 8.2-10), states that although California tiger salamanders have been recorded within a mile of the site, none were observed. The AFC also states if any are disturbed within the project site or along the linear facilities, then it would be an insignificant portion of the population. However, the AFC does not contain California tiger salamander field survey results.

30. 
    If California tiger salamander surveys were conducted for the project site and all project linears, then please provide the survey results (field survey dates, names and qualifications of biologists, transect spacing, locations and size of elderberry shrubs). If California tiger salamander surveys were not conducted, then conduct the appropriate (DFG protocol) surveys and provide the survey results.
    

In AFC Section 8.2.3.3, (page 8.2-7), it states that western burrowing owls often use ground squirrel burrows along railroad tracks and road cuts and that burrowing owls are likely to occur along the railroad tracks west of Franklin Boulevard and along Twin Cities Road. It also states that none were seen on or adjacent to the project site. However, the AFC does not contain western burrowing owl field survey results.

31. 
    If California tiger salamander [burrowing owl] surveys were conducted for the project site and all project linears, then please provide the survey results (field survey dates, names and qualifications of biologists, transect spacing, locations and size of elderberry shrubs). If California tiger salamander [burrowing owl] surveys were not conducted, then conduct the appropriate (DFG protocol) surveys and provide the survey results.
    

T

Call To:

Phone No.: (916)930-3605 Date: December 11, 2001

Call From: EJ Koford Time: 05:36 pm

Message
Taken By: EJ Koford

CEC staff requested to know when we would submit a Biological Assessment and get a Biological Opinion from NMFS. This seems early, and a consultation formally needs to be initiated by a federal agency. However, I called NMFS to discuss the issue and found Madeline to be very knowledgeable and helpful. The Cosumnes is her area.

NMFS has regulatory authority for winter and spring run chinook and steelhead. The USFWS has authority for delta smelt and splittail. Madeline can offer me a “technical assistance” letter, but a Biological Opinion could only address a federal agency request. Any advice given under technical assistance would not be binding on the Biological Opinion. She laid out a schedule for me that would have her issuing a conceptual BO on 30% design drawings ahead of the final design. She says she has had this issue before under the interagency agreement.

In this case, the NPDES discharge permit, as authorized by the EPA is the likely nexus. We didn’t plan to apply for an NPDES for a couple months, but NMFS needs this to do their consultation. The other major federal agency would be the ACOE for a 404 permit.

We can provide Madeline a letter so she knows this is all coming, but formally it is the federal agency that will initiate the consultation. I asked Madeline if she was aware of any field data or studies on Clay Creek, Hadselville and Laguna. She was not, but directed me to Ramona Swenson at the Nature Conservancy 684-4012 for more information.

Information Provided by CDFG

The AFC does not provide adequate information on built environment features or facilities that may be more than 45 years old. Additional information is needed to complete the staff analysis.

32. 
    Please identify all structures, facilities and features that are more than 45 years old or appear to be exceptional and are located within 100 feet of the proposed centerline of the gas line. These could include bridges, canals, railroads, roads, and transmission lines. If any of these structures/facilities are more than 45 years old, please have an architectural historian or a historian with a specialty in industrial, architectural or public history complete a Department of Parks and Recreation (DPR) 523A form. If it appears that any cultural resources may be significant, evaluate them for eligibility for the California Register of Historical Resources (CRHR) using additional appropriate DPR 523 forms.
    

It cannot be determined from the AFC and Data Adequacy Responses whether local historical societies and local jurisdictions (cities and counties) were contacted to determine if any historical resources in or near the project area are listed in local historical inventories or registers. Such local inventories are often not reflected in information obtained from a record search at the appropriate Archaeological Information Center. Historical resources listed on county or city inventories may be eligible for the CRHR, even if they have not been formally evaluated. Staff needs this information to complete its analysis.

33. 
    Please provide a list of any historical resources listed on Sacramento County, or SMUD District local inventories or registers within one half mile of the power plant site and within one hundred feet of the center line of all linear routes that are part of the project
    

34. 
    If local historical societies and archaeological societies were not contacted, please contact them and provide copies of any inquiries and responses from such societies. If contact is made through interviews rather than by letter, please provide a written description of contact methods used, information obtained, and the names and contact information for those interviewed.
    

• 
  El Dorado County, P.J. Reinhardt, 701 Persifer, Folsom, CA 95630
  
• 
  Elk Grove Historical, Dorothy Hrepich, 12001 Green, Wilton, CA 95693
  
• 
  Elk Grove Historical Society, Bob Fite, 10778 Calvine Road, Sacramento, CA 95830
  
• 
  Florin Historical Society, Dave Reigold, 8149 Follett, Florin, CA 95828
  
• 
  Gene Olson, POB 848, Galt, CA 95632 South West Corner of Twin Cities and Clay Station Road. She wanted to be notified when we are planning construction. Gave address to Billie Elliston.
  
• 
  Old School House, Suzanne Hiddin, 5325 Ridgefield, Carmichael, CA 95608 House over 100 years old
  
• 
  Galt Area Historical Society, Wanda Bouchey, 272 Emerald Oak, Galt, CA 95632
  
• 
  Galt Area Historical, Jason Davies, 741 Winn Drive, Galt, CA 95632
  
• 
  Rancho del Paso, Bob Kent, 3104 El Camino, Sacramento, CA 95821
  
• 
  Rancho del Paso Historical Society, Harry Schnell, 2791 Corabel Lane #46, Sacramento CA 95821 N/A Out of Jurisdiction
  
• 
  Sacramento Public Library, Ruth Ellis, 828 I Street, Sacramento CA 95814
  
• 
  West Sacramento Historical Society, Kathy Perrigo, 417 Lilac Lane, W. Sacramento, CA 95691
  
• 
  Yolo County Historical Society Lois Partridge, 1102 Redwood, Davis, CA 95616. Not in their district.
  
• 
  Miwok Tribe, Billie Blue Elliston, 604 Pringle Ave #42, Galt, CA 95632. Burial site north side of Arno Road
  

Confidential Appendix 8.3 C-2 discusses a record search summary for the Cosumnes Power Plant Project that was conducted through the California Historical Resources Information System (CHRIS). It does not specify which regional Archaeological Information Center(s) were consulted.

35. 
    Please submit all cultural resources survey reports that provide the methods and results of all surveys conducted for this project. The methods section should indicate the width of each linear survey area. If the survey coverage was less than 100 feet for historic features and less than 200 feet for archaeological features on each side of the centerline of the linear alignments, additional surveys should be completed to attain this coverage.
    

36. 
    For the surveys conducted specifically for the Cosumnes Power Plant Project, rather than the surveys conducted for other projects, the report appendices should contain resumes of investigators and a letter from the information center where the records search was performed stating they performed the search or that an in-person search was conducted by the applicant’s consultant.
    

37. 
    Provide copies of all DPR 523 site record forms for cultural resources in or within ¼-mile of the project and all linear alignments required for the project.
    

38. 
    Provide the dimensions of the proposed Area of Potential Effects (APE) for the project site and linears.
    

39. 
    Please provide a plan to avoid (the plan should include, but not be limited to CA-SAC-93) all identified archaeological sites (both prehistoric and historic) within 200 feet and historic sites (built environment) within 100 feet of the plant site, linear routes, laydown, parking areas, and access roads. If it appears that a cultural resource cannot be avoided, provide a test plan for each archaeological resource and complete and provide the evaluation forms DPR 523, as appropriate, for historic resources, pursuant to CEQA Section 15064.5, (a), (3), (A)(B)(C) & (D).
    

40. 
    On maps 1-6 of Confidential Appendix 8.3D, please identify what areas of the proposed gas line were covered in each report. AFC page 8.3-21 discusses several sections on the route that were almost completely surveyed. Please also add the locations of areas that were not completely surveyed.
    

AFC Sections 2.2.15, 8.2.4, and figure 2.2.3-3 refer to a potential parking and laydown area south of Clay Road and the project site. No cultural resource survey information is provided for this area.

41. 
    Please survey and provide survey information for the parking and laydown area south of Clay Road and the project site.
    

42. 
    Identify the location of any areas that will be used as pipe or equipment staging and laydown areas or for parking, water supply, fire protection waterline, or other purposes. Please provide the results of a cultural resources survey for these areas.
    

43. 
    If cultural resources are present, please provide completed DPR 523 forms for the resource(s).
    

The AFC, Section 2.4.3 states that a new gas line parallel to the existing SMUD gas line would be required for operation of the second phase of the project. AFC Sections 1.2, and 2.1 indicate that construction of Phase II is within the current schedule. Staff needs additional information about cultural resources that could be impacted by construction of this pipeline. It appears from information provided in the AFC p. 2-25 that the gas line for phase II is part of this project.

44. 
    Please provide the results of a records search that extends ½-mile from the centerline of the proposed gas line for Phase II.
    

45. 
    Please conduct an archaeological pedestrian survey that extends to a minimum of 200 feet on both sides of the proposed center line of the gas line and provide the results. Complete DPR forms 523A for identified resources.
    

46. 
    Please conduct an historic resources survey that extends to a minimum of 100 feet on both sides of the center line and provide the results. The survey should be conducted by someone who meets the Secretary of the Interior Standards in history or architectural history. Record cultural resources that appear to be 45 years or older on a DPR 523A form and complete additional DPR 523 forms as appropriate for evaluation.
    

47. 
    Describe avoidance procedures for any cultural resources that are identified.
    

48. 
    If it is not possible to avoid the cultural resource(s), please provide an evaluation of the eligibility of the site(s) for the California Register of Historical Resources pursuant to (CEQA Section 15064.5, (a), (3), (A), (B), (C), and (D).
    

AFC Section 8.3.5 proposes that construction monitoring take place in areas of proximity to the cultural resources listed on Table 8.3-4 and in areas of high probability for cultural resources. It is not possible to determine from the present information which areas are to be considered of “high probability”, additional information is needed to complete the staff analysis.

49. 
    Please identify the location of areas considered “high probability areas” on maps 1-6 (Confidential Appendix 8.3D).
    

The discussion of cumulative impacts in the AFC does not provide any information on other projects in the area that could impact cultural resources. The discussion of cumulative impacts should consider such other projects. Additional information is needed to complete the staff analysis.

50. 
    Please provide a discussion of other projects (in permitting or currently under construction) within a one-mile radius of the Cosumnes Power Plant project.
    

51. 
    Please provide a discussion of the cumulative impacts relevant to the information from the previous question.
    

It appears from the content of the letters sent to the Native Americans on the Native American Heritage Commission (NAHC) contact list that the linear routes were not described. It is necessary to inform Native Americans regarding the entire project and linears.

52. 
    Please send an additional letter to members of the Native American Community listed by the NAHC for Sacramento County. In that letter, identify the location of all project linears and provide a map(s) that indicates the project location and location of the linears.
    

53. 
    Provide copies of the letters to and responses from Native Americans.
    

Attachment CR-36

Resumes of Cultural and Historic Surveyors