FINAL REPORT Evaluation of Seawater Desalination Projects ...

EVALUATION OF SEAWATER DESALINATION PROJECTS
PROPOSED FOR THE MONTEREY PENINSULA
be expected to have greatly varying air quality requirements. Most of the information needed
for an adequate air quality permitting assessment is not compiled specifically for that
purpose; rather, it is scattered throughout the materials. The proponents acknowledge that
more detailed information will be made available once costs and other feasibility concerns
are sorted out. While it is reasonable that air emissions controls can be achieved through this
proposal, it is also recommended that a legal and regulatory analysis of air quality
requirements be conducted when the project is described more clearly.
For example, file materials prepared by PBS&J suggest that air permits for construction of
the treatment vessel and docks and piers will not be an issue. Other materials explain the
basis for this assumption—the treatment vessel will not be refurbished locally, and docks and
piers will not be necessary. Nevertheless, the materials do not discuss the potential
construction permitting requirements for laying a seabed pipeline that may include air quality
emissions from barges and drill rigs. These construction-related emissions were considered
in a Minor New Source Review air permit application to EPA Region IX for a proposed
deepwater port near Ventura, California called “Cabrillo Port.” In addition, the assumption
that terminal storage for water needs to be constructed appears in the Water Standard
Company “Proponent’s Statement,” dated April 11, 2007, but is not considered part of the
proposed alternative package. Proponent’s supplied materials indicate that no permanent
mooring or turrets will be constructed; but these assumptions are not carried forward to the
Proponent’s Statement 62 . Each of these components would need to be clarified to assess
construction-related air emissions and permitting requirements.
In addition, Section 30253(3) of the California Coastal Act requires that an off-shore vessel
operating within 24 nautical miles of the California coast must be “consistent” with
requirements imposed by Air Resources Board (state) and the local air district, in this case,
Monterey Bay Unified Air Pollution Control District (MBUAPCD). The 2006 PBS&J letter
to the CPUC does not directly address the air quality impacts listed in the original NOP for
the Moss Landing Desalination Plant/Coastal Water Project, although some may continue to
apply in the SDV alternative. In addition to construction-related permitting, a key issue will
be related to power generation for the SDV. The materials generally explain that the GE
LM2500 gas turbines will power the equipment on-board. These engines are used routinely
on cruise ships and commercial aircraft, which are regulated as mobile sources of air
pollution. Nevertheless, it would be appropriate to obtain a legal opinion on the applicability
of certain stationary source requirements (including federal New Source Performance
Standards) to the gas turbines and the on-board equipment drawing power from the turbine
while it is operating at a location fixed by mooring or satellite. To complete the SDV
62 Proponent’s comments on the draft GEI/B-E report include: “For clarification, at the time the PBS&J report
was prepared, seabed pipelines were not an option and dynamic positioning was the preferred alternative.
Switching from barge delivery to pipeline has occurred during discussions with Monterey over the past year.
WSC will be in full compliance for seabed construction.
Monterey Peninsula Water Management District 7-16