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Ordinance No. 1235 (21)
POWER ENGINEERS, INC. Distributed Generation Impact Study APPENDIX D HAZARDOUS MATERIALS ASSESSMENT ANA 092-062 (SR 02) COV 135853 (05/08/2015) YU PAGE D-1 THIS PAGE INTENTIONALLY LEFT BLANK ANA 092-062 (SR 02) COV 135853 (05/08/2015) YU POWER ENGINEERS, INC. Distributed Generation Impact Study PAGE D-2 F a �+ ty e s -r.. .a Preliminary Hazardous Materials Assessment for the Vernon Distributed Generation Project Consultant: RBF Consulting, a Michael Baker International Company 14725 Alton Parkway Irvine, California 92618 Contact: Ms. Kristen Bogue Hazardous Materials Specialist 949.472.3505 PRELIMINARY HAZARDOUS MATERIALS ASSESSMENT Vernon Distributed Generation Project City of Vernon State of California Prepared For: POWER Engineers, Inc. 731 E. Ball Road, Suite 100 Anaheim, CA 92805 Contact. Mr. Dev D. Birta, Sr. Project Manager Prepared By: INTERNATIONAL RBF Consulting, a Michael Baker International Company 14725 Alton Parkway Irvine, California 92618 March 20, 2015 JN 143818 Table of Contents Paqe 1.0 Introduction 1.1 Purpose..........................................................................................................1-1 1.2 Project Characteristics....................................................................................1-1 1.3 Regulatory Setting..........................................................................................1-5 2.0 Methodology 2.1 Scope of Services and Methodology Used......................................................2-1 2.2 Limiting Conditions of Assessment.................................................................2-2 3.0 Physical Setting 3.1 Project Site Characteristics............................................................................. 3-1 3.2 Topography....................................................................................................3-2 3.3 Current Uses of Adjoining Properties..............................................................3-2 3.4 Geologic Conditions........................................................................................3-3 3.5 Biological Setting............................................................................................3-4 3.6 Drainage/Hydrology........................................................................................3-4 3.7 Groundwater and Water Wells........................................................................ 3-4 4.0 Regulatory Searches 4.1 Regulatory Sources........................................................................................4-1 6.0 Hazardous Materials Analysis 5.1 Significance Criteria........................................................................................5-1 5.2 Hazardous Materials Impacts..........................................................................5-1 6.0 Mitigation Measures 6.1 Recommended Measures............................................................................... 6-1 7.0 Level of Significance After Mitigation..................................................................7-1 8.0 References............................................................................................................. 8-1 ............................................................................... Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment i M Table of Contents LIST OF EXHIBITS 1. Regional Vicinity.............................................................................................1-2 2. Local Vicinity...................................................................................................1-3 LIST OF TABLES 1. CEQA Appendix G Hazardous Materials Checklist.........................................5-1 APPENDIX A. Regulatory Database Searches B. Qualifications ........................................................................................................................ Vemon Distributed Generation Project Preliminary Hazardous Materials Assessment ii L List of Acronyms . .................................... LIST OF ACRONYMS AC alternating current ACM Asbestos Containing Materials AEHRA Asbestos Emergency Hazard Response Act APN Assessor's Parcel Number APST Aboveground Petroleum Storage Tank AST Aboveground Storage Tank AULs Activity and Use Limitations BEP Business Emergency Plan CADD Computer Aided Design and Drafting CalARP California Accidental Release Prevention Cal EPA California Environmental Protection Agency Cal OSHA California Division of Occupational Safety and Health Caltrans California Department of Transportation CARB California Air Resources Board CCR California Code of Regulations CEQA California Environmental Quality Act CERCLA Comprehensive Response Compensation and Liability Act CERCLIS Comprehensive Environmental Response, Compensation, and Liability Information System (maintained by the Environmental Protection Agency) CFR Code of Federal Regulations CHAPIS Community Health Air Pollution Information System CHP California Highway Patrol CORRACTS facilities subject to Corrective Action under RCRA CPSC United States Consumer Product Safety Commission CUPA Certified Unified Program Agency DDD Dichlorodiphenyldichloroethane DDE Dichlorodiphenyldichloroethylene DDT Dichlorodiphenyltrichloroethane DOGGR California Department of Oil, Gas, and Geothermal Resources Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment FM OR List of Acronyms DOT Department of Transportation DTSC Department of Toxic Substances Control EDR Environmental Data Resources EPA United States Environmental Protection Agency EPCRA Emergency Planning and Community Right to Know Act (also known as SARA Title III), 42 U.S.C. §§ 11001-11050 et seq.) ERNS emergency response notification system FEMA Federal Emergency Management Act FIRM Flood Insurance Rate Map FOIA U.S. Freedom of Information Act (5 U.S.C. §552 as amended by Public Law No. 104-231, 110 Stat.) FR Federal Register GIS Geographic Information System HMD Hazardous Materials Disclosure HW Hazardous Waste LBP Lead Based Paints LUFT Leaking Underground Fuel Tank LUST Leaking Underground Storage Tank MM Mitigation Measure MSDS Material Safety Data Sheet msl mean sea level NFRAP former CERCLIS sites where no further remedial action is planned under CERCLA NPDES National Pollutant Discharge Elimination System NPL National Priorities List NRCS Natural Resources Conservation Service OES Office of Emergency Services OSHA Occupational Safety and Health Administration PCBs Polychlorinated Biphenyls pCi/L Picocuries per liter Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment iv OR List of Acronyms RCRA Resource Conservation and Recovery Act (as amended, 42 U.S.C. §§6901 et seq.) RWQCB Regional Water Quality Control Board SARA Superfund Amendment and Reauthorization Act SBBM San Bernardino Base and Meridian SCAQMD South Coast Air Quality Management District SWRCB State Water Resources Control Board TPH Total Petroleum Hydrocarbons TRI Toxics Release Inventory TSDF hazardous waste treatment, storage, or disposal facility USDA United States Department of Agriculture USGS United States Geological Survey UST Underground Storage Tank Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment u �.- Section 1 Introduction 1.1 PURPOSE The purpose of this Preliminary Hazardous Materials Assessment (Assessment) is to review the existing conditions, analyze potential environmental impacts, and suggest feasible mitigation measures to reduce potentially significant effects, if any, associated with hazardous materials for the Vernon Distributed Generation Project, herein referred to as the "project." For the purposes of this Assessment, the term "hazardous material" refers to both hazardous substances and hazardous waste. A material is defined as "hazardous" if it appears on a list of hazardous materials prepared by a Federal, tribal, State, or local regulatory agency, or if it possesses characteristics defined as "hazardous" by such an agency. A "hazardous waste" is a solid waste that exhibits toxic or hazardous characteristics (i.e., ignitability, corrosivity, reactivity, and/or toxicity). 1.2 PROJECT CHARACTERISTICS 1.2.1 Project Site The City of Vernon (City) is located within Los Angeles County, California, approximately two miles south of downtown Los Angeles; refer to Exhibit 1, Regional Vicinity. The City is bordered by the �... City of Los Angeles to the north and west, the City of Commerce to the east, and the cities of Huntington Park and Maywood to the south; refer to Exhibit 2, Local Vicinity. M, Consisting almost entirely of warehouses and factories, the City's main industries are food service manufacturing, metalworking, rendering plants, food processors, smelters, and manufacturing of glass and plastic equipment. Housing is owned by the City and its few residents are employed within the City's limits. In the foreseeable future, the City will continue to be an almost completely industrial city, with limited retail, commercial, and food service operations to support the large day -time business population and few residences. 1.2.2 Project Description The Vernon City Comprehensive Zoning Ordinance (Zoning Ordinance) permits generating facilities, power plants, and cogeneration facilities to be built subject to a City issued Conditional Use Permit. Interest in Distributed Generation (DG) has grown recently to either lower on -site energy demand or to export the energy via the DG&E distribution system. As a result, the City is considering whether changes to the Zoning Ordinance should be made to address DG. The City of Vernon General Plan contains one land use category (Industrial), and five Overlay Districts (Commercial, Rendering, Slaughtering, Housing, and Emergency Shelter). All uses allowed ............................................................................................................................................................................................................................................ Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 1-1 Th K E R N COUNTY I Lebec -- -- -- I — — — — — — — —� -- -- — I — Gorman I I \ \ Lancaster I \ Pyramid Lake \ I \ Palmdale rastaic \ Lake Lake 1 I \ \ Lake��\ Caslaic . I I Piru 12 ` ® \\ Piru LOS ANGEL.ES Fillmore COUNTY \ Santa VENTURA \ an I ® COUNTY \\ Sylmar j i Moorpark Simi Pacoima Valley Chatsworth / Canoga Burbank Park Van Glendale — — Nuys ANA Monrovia ousand aura Hi Is Woodla Oaks Hills Westlake 101 Calabasas Village Marina Del Rey Playa Del Ri El Segi Manhattan pq C ;c Subject Site se oc F9 ti NOT TO SCALE PF 10- A � Cano•m 01/15•JN 143818 Alhambra Beverly Hills Inglewood South Gate Dow He i me Compton Bellflol h Torrance Lake Carson i Palos Verdes Estates Long San peach Pedro � — adena r Azuza Claremont / i Arcadia Upland Baldwin i San Covina Oimas i i West Pomona/ grey Covina Walnut i Pico �i� ,i Chino iivere Whittier Habra H Heights — — IVY i Brea Yorba iroda i inda or Fullerton ood rr ) Anaheim ORANGE J Orang COUNTY Garden Grove Saida Tustin Ana Huntington Beach Costa i Irvine ake� Mesa F PRELIMINARY HAZARDOUS MATERIALS ASSESSMENT VERNON DISTRIBUTED GENERATION PROJECT Regional Vicinity Exhibit 1 This page intentionally left blank Introduction in the Industrial category are permitted in the Overlay Districts. Each Overlay District allows certain specialized uses not permitted in other areas of the City. Additionally, all power generation facilities require a Conditional Use Permit (CUP) for approval. Distributed generation (DG) refers to small scale power generation at the point of consumption. DG consists of a variety of small, grid -connected devices and typically includes solar power, wind power, microturbines, combustion gas turbines, fuel cells, biomass energy, and waste to energy. The following provides a brief description of each of these generation types: • Solar Power (Photovoltaic LPVJ Systems). PV solar panels are made up of discrete cells connected together that convert light radiation into electricity. The PV cells produce direct - current (DC) electricity, which must then be inverted for use in an alternating -current (AC) system. • Wind Power. Wind turbines use the wind to produce electrical power. A wind system includes the rotor, generator, turbine blades, and drive or coupling device. As wind blows through the blades, the air exerts aerodynamic forces that cause the blades to turn the rotor. As the rotor turns, its speed is altered to match the operating speed of the generator. A single wind turbine can range in size from a few kW for residential applications to more than 5 MW. As with PV systems, the output of the generator is processed by an inverter that changes the electricity from DC to AC so that the electricity can be used. • Microturbines. Microturbines are small combustion turbines that produce between 25 kW and 500 kW and consist of a compressor, combustor, turbine, and generator. • Combustion Gas Turbines. Combustion turbines range in size from about 500 kW to several hundred MW when configured as a combined cycle power plant. They are fueled by natural gas, oil, or a combination of fuels. Units smaller than 15 MW are generally referred to as industrial turbines, which differentiates them both from larger utility grade turbines and smaller microturbines. • Fuel Cells. Fuel cells use an electrochemical process to convert fuel into electricity. In addition to providing power, they can supply a thermal energy source for water and space heating, or absorption cooling. • Biomass Energy. Biomass energy refers to material from plants and animals that can be burned to produce energy. As an energy source, biomass can either be used directly via combustion to produce heat, or indirectly after converting it to various forms of biofuel. Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 1-4 Introduction • Waste to Energy. Waste to energy refers to the process of generating energy in the form of electricity and/or heat from the incineration of waste. The City of Vernon General Plan (Section 2.2) and Zoning Ordinance (Section 26.4.1-3) currently require power generation projects to obtain a CUP. This analysis identifies potential hazardous materials constraints and mitigation measures related to allowing various DG projects to be allowed by "right" instead of through the CUP process. 1.3 REGULATORY SETTING The United States Environmental Protection Agency (EPA) is responsible for researching and setting national standards for a variety of environmental programs and delegates to states and tribes responsibility for issuing permits, and monitoring and enforcing compliance. The management of hazardous materials and waste within the State of California is under the jurisdiction of the California Environmental Protection Agency (Cal EPA) and the Department of Toxic Substances Control (DTSC). The Cal EPA was created by the State of California to establish a cabinet level voice for the protection of human health and the environment and to assure the coordinated deployment of State resources. The DTSC regulates hazardous waste, clean-up of existing contamination, emergency planning, and identifies alternatives to reduce the hazardous waste produced in California. Additionally, the Regional Water Quality Control Board (RWQCB) regulates the quality of water within the State, including contamination of State waters as a result of hazardous materials and/or `a..- waste. Other local departments (i.e., fire department, environmental health services department, etc.) may also have jurisdiction over hazardous materials. 1.3.1 Federal and State 1.3.1.1 Environmental Protection Agency According to the EPA, a "hazardous" waste is defined as one "which because of its quantity, concentrations, or physiochemical or infectious properties, may either increase mortality or produce irreversible or incapacitating illness, or pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed" (U.S. Public Health and Welfare Code Section 6903). Special handling and management are required for materials and wastes that exhibit hazardous properties. Treatment, storage, transport, and disposal of these materials are highly regulated at both the Federal and State levels. Compliance with Federal and State hazardous materials laws and regulations minimizes the potential risks to the public and the environment presented by these potential hazards, which include, but are not limited to, the following: • Resources Conservation and Recovery Act (RCRA) — hazardous waste management; • Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) — cleanup of contamination; ................................................................................................ Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 1-5 Introduction • Superfund Amendment and Reauthorization Act (SARA) — cleanup of contamination; and Hazardous Materials Transportation Act (HMTA) — safe transport of hazardous materials. These laws provide the "cradle to grave" regulation of hazardous wastes. Businesses, institutions, and other entities that generate hazardous waste are required to identify and track their hazardous waste from the point of generation until it is recycled, reused, or disposed of. The primary responsibility for implementing RCRA is assigned to the EPA, although individual states are encouraged to seek authorization to implement some or all RCRA provisions. The EPA and the DTSC have developed and continue to update lists of hazardous wastes subject to regulation. In addition to the EPA and DTSC, the RWQCB, Los Angeles Region (Region 4), is the enforcing agency for the protection and restoration of water resources, including remediation of unauthorized releases of hazardous substances in soil and groundwater. Other State agencies involved in hazardous materials management include the Office of Emergency Services, California Department of Transportation (Caltrans), California Highway Patrol (CHP), California Air Resources Board (CARB), and CalRecycle. California hazardous materials management laws include, but are not limited to, the following: • Hazardous Materials Management Act — business plan reporting; • Hazardous Substance Act — cleanup of contamination; • Hazardous Waste Control Act — Hazardous waste management; and • Safe Drinking Water and Toxic Enforcement Act of 1986 — releases of and exposure to carcinogenic chemicals. 1.3.1.2 Department of Toxic Substances Control The responsibility for implementation of RCRA was given to Cal EPA's DTSC in August 1992. The DTSC is also responsible for implementing and enforcing California's own hazardous waste laws, which are known collectively as the Hazardous Waste Control Law. Although similar to RCRA, the California Hazardous Waste Control Law and its associated regulations define hazardous waste more broadly and regulate a larger number of chemicals. Hazardous wastes regulated by California, but not by EPA, are called "non-RCRA hazardous wastes." 1.3.1.3 State Water Resources Control Board Brownfields are underutilized properties where reuse is hindered by the actual or suspected presence of pollution or contamination. The goals of the State Water Resources Control Board's (SWRCB) Brownfield Program are to: • Expedite and facilitate site cleanups and closures for Brownfields sites to support reuse of those sites; • Preserve open space and greenfields; Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 1-6 Introduction Protect groundwater and surface water resources, safeguard public health, and promote environmental justice; and Streamline site assessment, clean up, monitoring, and closure requirements and procedures within the various SWRCB site cleanup programs. Site cleanup responsibilities for brownfields primarily reside within four main programs at the SWRCB: the Underground Storage Tank Program, the Site Cleanup Program, the Department of Defense Program, and the Land Disposal Program. These SWRCB cleanup programs are charged with ensuring sites are remediated to protect the State of California's surface and groundwater and return it to beneficial use. 1.3.1.4 California Air Resources Board One of CARB's major goals is to protect the public from exposure to toxic air contaminants. The California Air Toxics Program establishes the process for the identification and control of toxic air contaminants and includes provisions to make the public aware of significant toxic exposures and for reducing risk. The Toxic Air Contaminant Identification and Control Act (AB 1807, Tanner 1983) created California's program to reduce exposure to air toxics. The Air Toxics "Hot Spots" Information and Assessment Act (AB 2588, Connelly 1987) supplements the AB 1807 program, by requiring a statewide air toxics inventory, notification of people exposed to a significant health risk, and facility plans to reduce these risks. Under AB 1807, CARB is required to use certain criteria in the prioritization for the identification and control of air toxics. In selecting substances for review, the CARB must consider criteria relating to "the risk of harm to public health, amount or potential amount of emissions, manner of, and exposure to, usage of the substance in California, persistence in the atmosphere, and ambient concentrations in the community." AB 1807 also requires CARB to use available information gathered from the AB 2588 program to include in the prioritization of compounds. This report includes available information on each of the above factors required under the mandates of the AB 1807 program. AB 2588 air toxics "Hot Spots" program requires facilities to report their air toxics emissions, ascertain health risks, and to notify nearby residents of significant risks. In September 1992, the "Hot Spots" Act was amended by Senate Bill 1731 which required facilities that pose a significant health risk to the community to reduce their risk through a risk management plan. 1.3.1.5 Accidental Release Prevention Law The State's Accidental Release Prevention Law provides for consistency with Federal laws (i.e., the Emergency Preparedness and Community Right -to -Know Act and the Clean Air Act) regarding accidental chemical releases and allows local oversight of both the State and Federal programs. State and Federal laws are similar in their requirements; however, the California threshold planning Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 1-7 Introduction quantities for regulated substances are lower than the Federal quantities. Local agencies may set lower reporting thresholds or add additional chemicals to the program. The Accidental Release Prevention Law is implemented by the Certified Unified Program Agencies (CUPAs) and requires that any business, where the maximum quantity of a regulated substance exceeds the specified threshold quantity, register with the responsible CUPA as a manager of regulated substances and prepare a Risk Management Plan. A Risk Management Plan must contain an offsite consequence analysis, a five-year accident history, an accident prevention program, an emergency response program, and a certification of the truth and accuracy of the submitted information. Businesses submit their plans to the CUPA, which makes the plans available to emergency response personnel. The Business Plan must identify the type of business, location, emergency contacts, emergency procedures, mitigation plans, and chemical inventory at each location. 1.3.1.6 Transportation of Hazardous Materials Wastes Transportation of hazardous materials/wastes is regulated by California Code of Regulations (CCR) Title 26. The United States Department of Transportation (DOT) is the primary regulatory authority for the interstate transport of hazardous materials. The DOT establishes regulations for safe handling procedures (i.e., packaging, marking, labeling, and routing). The CHP and Caltrans enforce Federal and State regulations and respond to hazardous materials transportation emergencies. Emergency responses are coordinated as necessary between Federal, State, and local governmental authorities and private persons through a State mandated Emergency Management Plan. 1.3.1.7 Worker and Workplace Hazardous Materials Safety Occupational safety standards exist to minimize worker safety risks from both physical and chemical hazards in the workplace. The California Division of Occupational Safety and Health (Cal/OSHA) is responsible for developing and enforcing workplace safety standards and assuring worker safety in the handling and use of hazardous materials. Among other requirements, Cal/OSHA requires many businesses to prepare Injury and Illness Prevention Plans and Chemical Hygiene Plans. The Hazard Communication Standard requires that workers be informed of the hazards associated with the materials they handle. 1.3.2 Regional 1.3.2.1 Los Angeles Regional Water Quality Control Board The Los Angeles RWQCB is the enforcing agency for the protection and restoration of water resources, including remediation of unauthorized releases of hazardous substances in soil and groundwater. The UST Section directs environmental cleanup activities at leaking UST sites. Such sites include active and inactive gasoline stations, agricultural sites, brownfield redevelopment sites, airports, bulk petrochemical storage terminals, pipeline facilities, and various chemical and industrial facilities. The Site Cleanup Section oversees activities at non -UST sites where soil or groundwater ........................................................................................................................................................................................................................................... Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 1-8 Introduction contamination have occurred. Many of these sites are former industrial facilities and dry cleaners, where chlorinated solvents were spilled, or have leaked into the soil or groundwater. 1.3.2.2 South Coast Air Quality Management District The South Coast Air Quality Management District (SCAQMD) works with CARB and is responsible for developing and implementing rules and regulations regarding air toxics on a local level. The SCAQMD establishes permitting requirements, inspects emission sources, and enforces measures through educational programs and/or fines. 1.3.2.3 Los Angeles County Fire Department The Los Angeles County Fire Department (LACFD) is one of two designated CUPA for the City of Vernon (the Los Angeles County Certified Unified Program Agency [LACoCUPA]) by the State Secretary for Environmental Protection. The LACoCUPA is the local administrative agency that coordinates the regulation of hazardous materials and hazardous wastes in Los Angeles County. 1.3.3 Local 1.3.3.1 Vernon Health and Environmental Control Department The Vernon Health and Environmental Control Department (VHECD) is focused on protecting the environment and ensuring the health and safety of its residents, workers, visitors and neighboring communities. The VHECD provides comprehensive and efficient services to accomplish this goal, tailoring its operations to regulate and meet the needs of the City's large industrial sector. The VHECD is also the designated CUPA for the City of Vernon by the State Secretary for Environmental Protection, and enforces the following seven programs: • Hazardous Materials Inventory, • Hazardous Waste Generator, • Tiered Permitting, California Accidental Release Program (CaIARP), • Underground Storage Tanks (UST), • Aboveground Storage Tanks (AST), • Emergency Response, and • California Environmental Reporting System (CERS). 1.3.3.2 Vernon Fire Department The City of Vernon has four fire stations, strategically located throughout the City. Each station is staffed with full-time fire personnel working three shifts rotating every 48 hours. Specialized equipment is pre -positioned in each station to meet the needs of Vernon's industrial community. The City's Fire Department (Vernon Fire Department) has been awarded a Class I Public Protection Classification rating by the Insurance Services Office (ISO), an organization that independently evaluates municipal fire protection efforts in communities throughout the United States. The Class 1 ............................................................................................................................................................................................................................................ Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 1-9 M Introduction rating is the highest possible score that can be given to any fire department nationwide. Vernon Fire Department is 1 of only 10 fire agencies in California, and a total of 57 nationally to have achieved this prestigious and significant ranking. The ISO ratings process involves a periodic, detailed analysis of all fire department equipment and operations, the city's water system, and emergency 9-1- 1 communications system. The program provides an objective nationwide standard that helps fire departments in planning and budgeting for facilities, equipment, and training. By offering economic benefits for communities that invest in their firefighting services, the program provides an incentive for improving and maintaining public fire protection. The Operations Division of Vernon Fire Department performs all duties related to emergency response (fire, rescue, medical and hazard abatement), non -emergency service calls, fire prevention and public education programs, in-service training for all personnel, comprehensive fire preplanning for high risk and special hazard properties, along with maintaining fire facilities, apparatus, and equipment. The Fire Prevention Division is the focal point of the Department's efforts to minimize fire and hazard losses in the City. Fire Prevention's key role is improving the safety and quality of life for its citizens and businesses. Under the direction of the Fire Marshal, the Fire Prevention Division is staffed by sworn and civilian personnel dedicated to increasing safety, preventing or reducing fire losses, and ensuring compliance with applicable codes and ordinances. The goal of the Fire Prevention Division is to safeguard the community from fire and environmental hazards through programs providing adherence to fire regulations, public education, and hazard mitigation. To achieve this goal, the responsibilities include, but are not limited to: • Supervise and conduct fire safety inspections at all businesses, apartment buildings, schools, public assembly occupancies, health care facilities, and special events including television and film production sites. • Issuance of fire permits for fire code related construction, and high hazard activities. • Perform plan reviews for new construction, tenant improvements, and automatic fire protection systems. • Manage inspections of new construction, tenant improvements, and existing businesses and occupancies to confirm their compliance with codes and ordinances. • Direct public education and safety awareness programs. • Investigate fire related incidents. 1.3.3.3 Vernon General Plan The Safety Element of the City of Vernon General Plan (General Plan) identifies the natural and man- made hazards which affect public safety in the City, and established policies the City will pursue to minimize associated risks to life and property. The following policies set forth in the Safety Element of the City's General Plan are applicable to the project: Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 1-10 Introduction Goal S-1: Minimize the risk to public health, safety, and welfare associated with the presence of natural and human -caused hazards. Policy S-1.1: Periodically update and maintain the Multi -hazard Functional Plan in an effort to identify potential contingencies and emergency conditions and define the necessary response by public safety and other personnel. Policy S-1.2: Cooperate with other jurisdictions in the southeast area of Los Angeles County to maintain an up-to-date emergency response system for the region. Policy S-1.4: Maintain the public water distribution and supply system facilities to provide adequate capacity to meet both everyday and emergency fire -flow needs. Policy S-1.5: Coordinate with the Los Angeles Unified School District for protection and or evacuation of school children in the event of an emergency condition, which could affect the school in or near Vernon. Goal S-2: Provide a high degree of protection for all residents and workers from hazardous materials and the hazards associated with transport of such materials. Policy S-2.1: Continue to support and encourage State efforts to identify existing or previously existing hazardous waste generators or disposal sites in the City of Vernon. Policy S-2.2: Continue to require every business to maintain a list of the chemicals and other hazardous materials used or stored on site on appropriate material safety data sheets and otherwise in accordance with law, and to provide that list to the Fire Department and Environmental Health Department. Require that the Fire Department and Environmental Health Department to maintain a list of such materials and the location where they are stored or used to permit emergency personnel to respond appropriately, if required. Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 1-11 Introduction Goal S-3: Maintain high standards for the provision of City emergency services. Policy S-3.1: Establish and implement plans for continuity of government for Vernon in the event of a catastrophe. Policy S-3.2: Require businesses handling, transporting, or producing materials considered acutely hazardous to prepare contingency plans for accidents involving these chemicals. Policy S-3.3: Support the development and continued updating of public safety education programs. Goal S-4: Provide a high degree of protection for all workers and residents in the event of any disaster. Policy S4.2: Review the design of new development projects to consider public safety and issues such as emergency access, defensible space, and overall worker safety. 1.3.3.4 Vernon Natural Hazards Mitigation Plan The City of Vernon Natural Hazards Mitigation Plan provides a set of action items to reduce risk from natural hazards through education and outreach programs and to foster the development of partnerships, and implementation of preventative activities such as land use programs that restrict and control development in areas subject to damage from natural hazards. The resources and information within the Mitigation Plan: (1) Establish a basis for coordination and collaboration among agencies and the public in City of Vernon; (2) Identify and prioritize future mitigation projects; and (3) Assist in meeting the requirements of federal assistance programs. The mitigation plan works in conjunction with other City plans, including the Multi -Hazard Functional Plan. 1.3.3.5 Vernon Multi -Hazard Functional Plan The City of Vernon's Standardized Emergency Management System (SEMS) Multi -Hazard Functional Plan (MHFP) discusses and contains programs and plans for emergency responses to safety concerns pertaining to hazards. The MHFP includes pre -emergency preparedness plans and programs for mutual aid between organizations for most emergency situations. Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 1-12 L.- Section 2 METHODOLOGY The purpose of this Assessment is to review the existing conditions, analyze potential environmental impacts, and suggest feasible mitigation measures to reduce potentially significant effects associated with hazardous materials for the project. 2.1 SCOPE OF SERVICES AND METHODOLOGY USED The scope of this Assessment includes the following guidelines which are utilized as thresholds of significance criteria for the project analysis: ♦ Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials; ♦ Create a significant hazard to the public or the environment through reasonable foreseeable upset and accident conditions involving the release of hazardous materials into the environment; ♦ Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 'A mile of an existing school or proposed school; and ♦ Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment. The Assessment included the following components, which are designed to aid in the discovery and evaluation of potential existing hazardous materials -related conditions at the project site: ♦ A review of information available on general geology and topography of the project site and local groundwater conditions; and ♦ A review of the available online regulatory databases maintained by the Cal EPA, RWQCB, and DTSC regarding public agency records. This Assessment analyzes the proposed hazardous materials -related impacts at a programmatic level as a result of the proposed Zoning Ordinance Amendment allowing DG within the City. This Assessment is not intended to provide specific qualitative or quantitative information as to the actual presence of hazardous materials at the site, but merely to identify the potential presence based on available information, per the limitations of the scope of work. ................................................................................ Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 2-1 Methodology ........................... 116.1 RBF Consulting, a Michael Baker International Company (RBF Baker), compiled the data reviewed, discussed the project and analyzed the environmental impacts pertaining to hazardous materials, formulated conclusions and mitigation measures (if necessary) relative to site conditions, and prepared this Assessment documenting the findings. 2.2 LIMITING CONDITIONS OF ASSESSMENT The findings and professional opinions of RBF Baker are based on the information made available to RBF Baker from public records, and should be understood to be preliminary only. RBF Baker makes no warranties, either expressed or implied, concerning the completeness of the data made available to us for this study and withholds certification of any type concerning the presence or absence of contamination of the project site. Property conditions, as well as local, State, and Federal regulations, can change significantly over time. Therefore, the recommendations and conclusions presented as a result of this Assessment apply strictly to the environmental regulations and property conditions existing at the time the Assessment was performed. RBF Baker is not responsible for the quality or content of information from these sources. The report states our conclusion based on the limitations of RBF Baker's Scope -of -Services. Subsurface exploration, geologic mapping, laboratory testing of soil or water samples, lead and asbestos sampling, and operations/inventory review of adjacent uses were not performed in �- connection with this Assessment. This Assessment represents our professional judgment, based on the level of effort described above, as to the present potential for hazardous materials at the site. This Assessment specifically excludes air quality issues such as "indoor air quality" (vapor intrusion). This Assessment does not fulfill the requirements for a Phase I Environmental Site Assessment, per the ASTM International (ASTM) E 1527 Standard Practice. The information and opinions rendered in this Assessment are exclusively for use by Power Engineers and the City of Vernon. RBF Baker will not distribute or publish this report without the consent of Power Engineers and the City of Vernon, except as required by law or court order. The information and opinions expressed in this Assessment are given in response to RBF Baker's Scope - of -Services and Limitations, indicated above, and should be considered and implemented only in light of the Scope -of -Services and Limitations. The services provided by RBF Baker in completing this Assessment are consistent with normal standards of the profession. The RBF Baker's Scope -of - Services does not include the fulfillment of the requirements of a Phase I Environmental Site Assessment (per the ASTM Standard Practice E 1527) or the requirements for All Appropriate Inquiry. No warranty, expressed or implied, is made. ............................................................................................................................................................ .................... Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 2-2 Section 3 PHYSICAL SETTING Per Section 15125 of the CEQA Guidelines, this section provides a description of the physical environmental conditions in the vicinity of the project from both a local and regional perspective. This environmental setting will normally constitute the baseline physical conditions by which a lead agency determines whether an impact is significant. The description of the environmental setting shall be no longer than is necessary to an understanding of the significant effects of the proposed project. Physical setting sources typically provide information regarding geologic, hydrogeologic, hydrologic, or topographic characteristics of a property. The following information is primarily based on review of the United States Geological Survey (USGS) Los Angeles, California Quadrangle, dated 1966, photorevised 1981, and the South Gate, California Quadrangle, dated 1964, photorevised 1981. Other miscellaneous resources utilized within this section and throughout the Assessment are referenced in Section 8.0, References. 3.1 PROJECT SITE CHARACTERISTICS 3.1.1 Existing Use(s) and Activities in the City The project site is comprised entirely of the City of Vernon with an approximate area of 13.36 square kilometers. Land uses within the project site consist primarily of industrial land uses and associated infrastructure as well as services required to serve those industrial uses. Other uses in the City consist �.- of commercial, residential, emergency shelter, rendering, and slaughtering. Warehouses and factories intended to serve the industrial nature of the City are present. City -owned housing is located within the eastern portion of the City. The local roadway and freeway systems directly connect the industrial businesses in Vernon with adjacent communities. Streets in Vernon generally form a grid pattern. Interstate 710 (I-710) is located within the eastern portion of the City and provides an important direct connection to surrounding communities and the ports of Long Beach and Los Angeles. Several rail lines cross Vernon including the Alameda Corridor, Union Pacific (UP), and the Burlington Northern Santa Fe (BNSF) lines. 3.1.3 Zoning/Land Use Records Zoning/land use records generally consist of records maintained by the local government in which the project site is located. They indicate the uses permitted by the local government for particular zones within its jurisdiction. The records may consist of maps and/or written records. The City's General Plan contains one land use category (Industrial), and five Overlay Districts (Commercial, Emergency Shelter, Housing, Rendering, and Slaughtering). The entire City of Vernon is zoned for General Industry (I Zone). ............................................................................................................................................................................................................................................. Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 3-1 1�. 3.2 TOPOGRAPHY M Physical Setting .................................................................................................... USGS topographic maps show geological formations and their characteristics, describing the physical setting of an area through contour lines and major surface features including lakes, rivers, streams, buildings, landmarks, and other geologic or infrastructure characteristics. Additionally, the maps depict topography through color and contour lines and are helpful in determining elevations and site latitude and longitude. Based on the USGS Los Angeles, California Quadrangle, dated 1966, photorevised 1981, and the South Gate, California Quadrangle, dated 1964, photorevised 1981, on -site topography is generally flat, sloping to the southeast with an approximate elevation ranging from 145 to 210 feet above mean sea level (msl). The project site appears to consist of a built-up area. The Los Angeles River is visible trending through the City of Vernon in a north -south direction. The Atchison Topeka and Santa Fe Railroad is visible within the City. The City is characterized by large industrial buildings with multiple railroad tracks and spurs throughout. Multiple tanks are also noted. Surrounding communities appear to be urban land and transportation uses associated with the Los Angeles area. 3.3 CURRENT USES OF ADJOINING PROPERTIES For the scope of this Assessment, properties are defined and categorized based upon their physical proximity to the project site. An adjoining property is considered any real property or properties the border of which is contiguous or partially contiguous with that of the project site, or that would be contiguous or partially contiguous with that of the project site but for a street, road, or other public thoroughfare separating them. An adjacent property is any real property located within 0.25 mile of the project site's border. The following is a detailed description of each adjoining land use surrounding the project site: • North: Industrial, commercial, and transportation land uses are located to the north of the project site. • South: Residential, commercial, industrial, institutional, and transportation land uses are located to the south of the project site. • East: Industrial, military commercial, and transportation land uses are located to the east of the project site. • West: Industrial, commercial, and residential land uses located to the west of the project site. ............................................................................................................................................................................................................................................ Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 3-2 Physical Setting .................................................................................. %... 3.4 GEOLOGIC CONDITIONS 3.4.1 Geology According to the City of Vernon Natural Hazards Mitigation Plan, the City of Vernon is located in the greater Los Angeles Basin which is the product of rainstorms and erosion for millennia. Most of the mountains that ring the valleys and coastal plain are deeply fractured faults and, as they (the mountains) grew taller, their brittle slopes were continually eroded. Rivers and streams carried boulders, rocks, gravel, sand, and silt down these slopes to the valleys and coastal plain. In places these sediments are as much as twenty thousand feet thick. Much of the coastal plain rests on the ancient rock debris and sediment washed down from the mountains. This sediment can act as a sponge, absorbing vast quantities of rain in those years when heavy rains follow a dry period. But like a sponge that is near saturation, the same soil fills up rapidly when a heavy rain follows a period of relatively wet weather. Even in some years of heavy rain, flooding is minimal because the ground is relatively dry. The same amount of rain following a wet period of time can cause extensive flooding. The greater Los Angeles Basin is for all intents and purposes developed. This leaves precious little open land to absorb rainfall. This lack of open ground forces water to remain on the surface and rapidly accumulate. If it were not for the massive flood control system with its concrete lined river and stream beds, flooding would be a much more common occurrence. 3.4.2 Soils The surface material includes unconsolidated, fine-grained deposits of silt, sand, and recent flood plain deposits. Torrential flood events can introduce large deposits of sand and gravel. Sandy silt and silt containing clay are moderately dense and firm. 3.4.3 Radon Radon is a radioactive gas that is found in certain geologic environments and is formed by the natural breakdown of radium, which is found in the earth's crust. Radon is an invisible, odorless, inert gas that emits alpha particles, known to cause lung cancer. Radon levels are highest in basements (areas in close proximity to the soil) that are poorly ventilated. A radon survey was not included within the scope of this investigation. According to the "U.S. EPA Map of Radon Zones," the County of Los Angeles is located within Zone 2, which has a predicted average indoor screening greater than or equal to 2.0 Picocuries per liter (pCi/L) and less than or equal to 4.0 pCi/L. EPA recommends remedial actions when radon levels are greater than 4.0 pCi/L. Emergency Planning Consultants, City of Vernon, Natural Hazards Mitigation Plan, October 20, 2004. ............................................................................................................................................................................................................................................ Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 3-3 Physical Setting ......................................................... 3.5 BIOLOGICAL SETTING The biotic community that exists within the project site appears to consist of that typical of built -out uses in the Los Angeles area consisting of minimal ornamental landscaping. As a fully developed city, Vernon has few remaining natural resources in the conventional sense of undeveloped land, native vegetation, and wildlife habitat. No natural habitats are present on -site. 3.6 DRAINAGE/HYDROLOGY 3.6.1 Drainage Drainage within the project site is accomplished by overland sheet flow which enters the city's storm drain facilities and sewer system conveying flows into the Los Angeles River. 3.6.2 Flood Hazards Flood Insurance Rate Maps (FIRM) produced by the Federal Emergency Management Agency (FEMA) were obtained for the project site. According to FEMA, the project site is not located within a 100-year flood zone. Further, based on the City's General Plan, with the flood control system of the Los Angeles River in place, FEMA does not identify any floodplain area in the City. 3.7 GROUNDWATER AND WATER WELLS RBF Baker assumes groundwater flow would follow the slope of the ground surface elevations towards the nearest open body of water or intermittent stream. Groundwater is assumed to flow towards the Los Angeles River. According to the City of Vernon 2010 Urban Water Management Plan, dated June 2011, eight existing groundwater supply wells are located in the City. Additional water wells are reported in the surrounding area as well. ........................................................................................................................................................................................................................................... Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 3-4 `. Section 4 REGULATORY SEARCHES The following historical and regulatory information is based upon review of available online regulatory databases maintained by the RWQCB and DTSC. 4.1 REGULATORY SOURCES 4.2.1 Standard Environmental Record Searches As part of this Assessment, RBF Baker has searched records, in accordance with RBF Baker's scope of work. The records searches included the Cal EPA's Cortese list, pursuant to Government Code Section 65962.5, as well as other records maintained by the DTSC. Refer to Appendix A, Regulatory Database Searches, for the database search documentation. 4.2.1.1 Cortese Listed Sites The Cal EPA's Cortese List is a planning tool used by the State, local agencies and developers to comply with the California Environmental Quality Act requirements by providing information about the location of hazardous materials release sites. Government Code Section 65962.5 requires Cal EPA to develop an updated Cortese List on an annual basis. The DTSC and SWRCB to compile and update a regulatory sites listing (per the criteria of the Section). The California Department of Health Services is also required to compile and update, as appropriate, a list of all public drinking water wells that contain detectable levels of organic contaminants and that are subject to water analysis pursuant to Section 116395 of the Health and Safety Code. Section 65962.5 requires the local enforcement agency, as designated pursuant to Section 18051 of Title 14 of the CCR, to compile, as appropriate, a list of all solid waste disposal facilities from which there is a known migration of hazardous waste. Multiple facilities in the City are listed on the Cortese list.2 Many of these facilities are known to handle/store/transport hazardous materials. Existing soil, soil gas, and/or groundwater contamination has been reported as a result of many of these activities. The following is a discussion of the listings: List of Hazardous Waste and Substances Sites Maintained by DTSC Two sites are listed in the Cortese "hazardous waste and substances site" list, maintained by the DTSC, which may present a concern related to soil, soil gas, and/or groundwater in the City, as described in Appendix A. 2 Department of Toxic Substances Control, http://www.envirostor.dtsc.ca.gov/public/mandated reports.asp, accessed on May 6, 2013. ............................................................................................................................................................................................................................................ Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 4-1 Regulatory Searches State Water Resources Control Board (GeoTracker) Listed Sites3 RBF Baker reviewed the SWRCB's GeoTracker database for reported sites in the City of Vernon. GeoTracker was developed pursuant to a mandate by the California State Legislature to investigate the feasibility of establishing a statewide Geographic Information System (GIS) for leaking underground fuel tank (LUFT) sites and is maintained by the SWRCB. RBF Baker makes no claims as to the completeness or accuracy of GeoTracker; our review of GeoTracker's findings can only be as current as their listings and may not represent all known or potential hazardous waste or contaminated sites. Refer to Appendix A. According to GeoTracker, multiple open regulatory sites are listed in the City of Vernon. Typical uses consist of gas stations, automotive, aerospace companies, chemical companies, commercial uses, and institutional uses. Sites with current "open" status include uses such as waste companies, metal companies, chemical companies, paint companies, and service stations. Cortese Hazardous Waste Facilities Subject to Corrective Action Pursuant to Section 25187.5 of the Health and Safety Code One site is listed on the Cortese hazardous waste facilities subject to corrective action pursuant to Section 25187.5 of the Health and Safety Code, identified by the DTSC, provided in Appendix A. Based on these records reviewed this regulatory site may present a concern to soil, soil gas, and groundwater in the City. 4.2.1.2 Department of Toxic Control Substances EnviroStor Listed Sites4 In addition to those Cortese listings, the DTSC has reported multiple releases in the City via the EnviroStor database. The EnviroStor Database was developed by the DTSC to allow the public to search for properties regulated by the DTSC's Site Mitigation and Brownfields Reuse Program where extensive investigation and/or cleanup actions are planned or have been completed. RBF Baker makes no claims as to the completeness or accuracy of EnviroStor Database; our review of EnviroStor Database's findings can only be as current as their listings and may not represent all known or potential hazardous waste or contaminated sites. 3 State Water Resources Control Board. GeoTracker. http://geotracker.waterboards.ca.gov/. Site accessed December 22, 2014. 4 California Department of Toxic Control Substances. EnviroStor. http://www.envirostor.dtsc.ca.gov/public/ mapfull.asp?global id=36000003. Site accessed December 22, 2014. Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 4-2 Regulatory Searches .............................................. The types of sites that are listed consist primarily of industrial uses including manufacturing companies and chemical companies as well as dry cleaning sites. These sites are known to handle/store/transport hazardous materials. Existing contamination has been reported as a result of these activities, and presents a concern to soil, soil gas, and groundwater in the City. Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 4-3 �- Section 5 HAZARDOUS MATERIALS ANALYSIS 5.1 SIGNIFICANCE CRITERIA Appendix G, Environmental Checklist Form, of the CEQA Statutes and Guidelines contains analysis guidelines related to the assessment of hazardous materials. These guidelines have been utilized to evaluate the potential for specific DG facilities to cause potentially significant hazardous materials - related impacts. ■ Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials; ■ Create a significant hazard to the public or the environment through reasonable foreseeable upset and accident conditions involving the release of hazardous materials into the environment; ■ Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 'A mile of an existing school or proposed school; and ■ Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment. Maintaining the CUP requirement for facility types that could result in potentially significant impacts based on the analysis presented herein would provide the City an avenue to establish permit conditions and require studies that would address these potential hazardous materials -related impacts on a project -specific basis. 5.2 HAZARDOUS MATERIALS IMPACTS The following analysis and opinions are based upon review of reasonably ascertainable referenced material available to RBF Baker during the preparation of this Assessment, which included regulatory database searches. 5.2.1 Short -Term Construction Impacts 5.2.1.1 Structural Modification/Demolition The installation of DG could result in the modification or demolition of structures. These activities could expose construction personnel and the public to hazardous substances such as asbestos containing materials (ACMs) or lead -based paints (LBPs). Given the age of many buildings and ............................................................................................................................................................................................................................................ Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 5-1 Hazardous Materials Analysis other structures in the City, constructed prior to 1978, it is likely that these structures could contain LBPs and/or ACMs. As a result, construction workers and the public could be exposed. Federal and State regulations govern the renovation and demolition of structures where ACMs and LBPs are present. All demolition that could result in the release of ACMs or LBPs must be conducted according to Federal and State standards. For those DG facilities that require structural modification/demolition, the National Emission Standards for Hazardous Air Pollutants (NESHAP) mandates that building owners conduct an asbestos survey to determine the presence of ACMs prior to the commencement of any remedial work, including demolition. If ACM material is found, abatement of asbestos would be required per State law. With the exception of PV Systems, the installation of DG facilities could result in the disturbance of painted materials. If paint is separated from building materials (chemically or physically) during demolition/relocation of the structures, the paint waste would be required to be evaluated independently from the building material by a qualified Lead Specialist as required by State law. If lead -based paint is found, abatement would be required to be completed. 5.2.1.2 Grading/Excavation Activities PV Systems Implementation of proposed PV Systems would occur atop roofs or would be proposed in surface parking areas as carport structures. Those atop roofs would not require grading or excavation �.. activities. Potential hazards associated with soil disturbance would not occur. Those proposed in surface parking lots would only require minimal activities to install structure footings/foundations in paved parking areas. These construction activities are not anticipated to significantly expose workers or the public to contaminated soils. Thus, less than significant impacts pertaining to exposure to hazardous soils would occur. Other DG Facilities Based on the Cortese listings and other records maintained by the DTSC, existing properties within the City have reported contamination to soil, soil gas, and groundwater. Grading/clearing activities could expose construction workers and the public to hazardous substances present in the soil, soil gas, and/or groundwater. Grading/excavation activities may be associated with other DG types such as microturbines, combustion gas turbines, fuel cells, biomass, and waste -carpet to energy, which could result in the disturbance of existing contamination in soil, soil gas, and/or groundwater. Exposure of the public or the environment to hazardous substances is considered a potentially significant impact. However, it should be noted that these potential hazardous materials contamination concerns that may be encounter associated with the development of these DG Facilities are similar to any other ground disturbing occurrences in the City. Due to the City's industrial nature, installing small DG facilities would not be substantially different than many other site improvement or construction projects that already occur in the City on a regular basis without a CUP. A formal Phase I Environmental Site Assessment (ESA) would be prudent for any development project (including DG Facilities) that ...................................................................................................................................................................................... Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 5-2 `_ Hazardous Materials Analysis ............................................................... requires site grading/excavation on commercial and/or industrial properties. Any Phase I ESA conducted would be prepared in accordance with the most current ASTM Standard Practice E 1527 or the Standards and Practices for All Appropriate Inquiry (AAI), prior to any site disturbance. The Phase I ESA would identify specific Recognized Environmental Conditions (RECs), which may require further sampling/remedial activities by a Phase II/Site Characterization Specialist. The Phase II/Site Characterization Specialist would identify proper remedial activities, if necessary. Therefore, with implementation of a Phase I ESA, potential accidental conditions during construction, as a result of current and historic uses within the City, would be reduced to less than significant levels. If the City believes that a Phase I ESA would not occur without a requirement from the City, and is necessary, implementing the sample mitigation measure MM-1 would address this concern. Multiple railroads are located within the City of Vernon. Petroleum product concentrations and lead concentrations are derived from drippings from rail vehicles and flaked paint, respectively. Wooden railroad ties may contain preservatives (i.e., creosote), some of which may contain hazardous constituents. Railroad spurs may include hazardous materials such as metals, total petroleum hydrocarbons (TPH), related compounds (i.e., fuel -related volatile organic compounds) and persistent organchlorine pesticides (i.e., toxaphene, dieldrin, chlordane, and dichlorodiphenyltrichloroethane (DDT). Track switch locations often have elevated levels of petroleum hydrocarbons. Inorganic and organic herbicides, along with diesel fuel, may have been used for vegetation control. Development of the conveyance systems may result in soil disturbance activities within the existing railroad rights - of -way. Due to the City's industrial nature, installing small DG facilities in areas of bare soil at properties with railroad spurs would not be substantially different than many other site improvement or construction projects that already occur in the City on a regular basis without a CUP. However, it is noted that for DG Facilities, or any other ground disturbing occurrences that would disturb bare soils at properties with railroad spurs, it would be prudent for a property owner to have a qualified Phase II/Site Characterization Specialist conduct sampling in order to ensure worker safety during these activities. Should a hazardous condition for construction workers be potentially present, the Phase II/Site Characterization Specialist would be required to prepare a Worker Safety Plan, pursuant to Cal/OSHA regulations, to ensure worker safety during construction. If the City believes that the property owner would not conduct these investigations and they are necessary to ensure worker safety during construction, implementing the sample mitigation measure MM-2 would address this concern. In the event that unknown hazardous materials are encountered during construction, such as soil discoloration, noxious odors, debris, or buried storage containers, the contractor would be required to implement a contingency plan for sampling and analysis of potentially hazardous substances (sample mitigation measure MM-3). The required handling, storage, and disposal methods would depend on the types and concentrations of chemicals identified in the soil, as applicable. Any site investigations or remediation would be required to comply with applicable laws and the project contractor would coordinate with the appropriate regulatory agencies. With implementation of the recommended MM- ............................................................................................................................................................................................................................................ Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 5-3 Hazardous Materials Analysis ................................................................................... 1 through MM-3, potential impacts during site grading/excavation would be reduced to less than significant levels. 5.2.1.3 Construction Equipment During short-term construction, there is a possibility of accidental release of hazardous substances such as petroleum -based fuels or hydraulic fluid used for construction equipment. The level of risk associated with this potential accidental release would be minimal. Standard construction practices would be observed such that any such materials released are appropriately contained and remediated as required by local, State, and Federal law. Impacts in this regard are less than significant. 5.2.2 Long -Term Operational Impacts Involving the Release of Hazardous Materials The proposed project consists of changing the Zoning Ordinance to allow for DG (small scale power generation). The long-term operation of PV Systems is not anticipated to require the use/handling or storage of hazardous materials or result in hazardous waste; therefore, there is no impact in this regard. However, other DG facilities, such as microturbines, combustion gas turbines, and/or fuel cells, could require the use of gasoline/diesel fuel, which may be stored on -site via underground or aboveground storage tanks. These facilities, on a case -by -case basis, would be required to comply with existing Federal, State, and local laws and regulations. The Prevention Law, implemented by the LACFD and VHECD, requires that any business, where the maximum quantity of a regulated substance exceeds the specified threshold quantity, register with the VHECD as a manager of regulated substances and prepare a Risk Management Plan. A Risk Management Plan must contain an offsite consequence analysis, a five-year accident history, an accident prevention program, an emergency response program, and a certification of the truth and accuracy of the submitted information. Businesses operating any proposed DG handling/storing hazardous materials would be required to submit their plans to the VHECD, which would then make the plans available to emergency response personnel. The Business Plan must identify the type of business, location, emergency contacts, emergency procedures, mitigation plans, and chemical inventory at each location. The UST Section of the VHECD would be required to direct any environmental cleanup activities involving leaking USTs. The Site Cleanup Section of the VHECD would oversee any non -UST sites where soil or groundwater contamination occurs. Therefore, with implementation of existing Federal, State, and local laws and regulations, the proposed project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. Thus, impacts in this regard would be less than significant. In addition to those long-term impacts described above, biomass and waste -carpet to energy DG facilities could result in the handling and/or transport of hazardous materials (such as high BTU' materials) and/or the production of hazardous waste as a result of operations. These facilities 5 British thermal unit - a traditional unit of energy equal to approximately 1,055 joules. . ............................................................................................................................................................................................................................................ Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 5-4 Hazardous Materials Analysis currently require a CUP and this requirement should be maintained. The CUP allows for the requirement of an evaluation of materials and wastes generated, as part of a project -specific CEQA process, and allows the City to establish project specific conditions. 5.2.3 Long -Term Operational Hazards Associated with Potential Explosions and/or Fires PV Systems Proposed PV Systems would occur atop roofs or would be proposed in surface parking areas as carport structures. PV panels generate electrical power by converting solar radiation into direct current (DC) electricity, using the photovoltaic effect in specialist semiconductor materials. DC electricity, similar to the nature of electrical installations, carry some degree of fire risk. DC electricity in particular slightly differ from other fires with live electrics present, as the DC current cannot be easily turned off in the event of a fire. Specific fire issues involved with PV System fires can include, but are not limited to: ■ Poor installation (which present a fire hazard); ■ DC supply (risk of electric shock [including arching] from the exposed DC conductors, particularly for fire-fighters); and ■ Extra weight on roof (causing early collapse). Based on the Distributed Generation Impact Study Hazard Analysis, prepared by Power Engineers, dated March 3, 2015, small inverter based DG such as a rooftop PV installation of one or two kW would not provide sufficient short circuit current to create a hazard when applying personal safety grounds on the distribution primary, nor would they provide enough short circuit current to create an arcing hazard when removing personal safety grounds. Thus, the proposed PV Facilities would not generate enough electricity to present an increased hazard and would generally be similar to existing electrical fires already experienced in the City. Less than significant impacts pertaining to explosive/fire hazards would occur with regard to PV Systems. Microturbines and Combustion Gas Turbines Microturbines and combustion gas turbines would involve the use to petroleum -related products and could be susceptible to explosion/fire hazards, similar to other industrial uses in the City. Microturbines are a relatively new technology being used for stationary energy generation applications. They are small-scale electricity generators that burn gaseous (natural and bio-gas) and liquid (gasoline, kerosene, and diesel) fuels. Due to City's industrial nature (with existing operating equipment similar to these DG facilities), installing small microturbines and combustion gas turbines at any particular site in the City would not be substantially different than many other operating facilities that occur in the City on a regular basis Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 5-5 Hazardous Materials Analysis without a CUP. These DG Facilities would be required to comply with the California Fire Code Chapter 50, Hazardous Materials -General Provisions, pertaining to the handling, storage, and use of hazardous materials, specifically to reduce the potential fire/explosion risks associated with these materials. Particularly, Chapter 53, Compressed Gases, and Chapter 57, Flammable and Combustible Liquids. Adherence to the practices presented in Chapter 57 would limit damage in the event of an accidental fire involving these materials. The danger associated with flammable and combustible liquids is that the vapors from these liquids, when combined with air in their flammable range, burn or explode at temperatures near normal living and working environment. The protection provided by the California Fire Code is to prevent the flammable and combustible liquids from being ignited. Thus, with compliance with the California Fire Code, similar to existing industrial uses already present in the City, impacts in this regard would be reduced to less than significant levels. F11A CAIQ Although fairly new and still developing, fuel cells are the cleanest of all the potential cogeneration technologies. A fuel cell releases the energy in a hydrogen rich fuel source (such as natural gas) by allowing it to combine with oxygen in a catalytic reaction that produces no flame. The outputs of a fuel cell are limited to electricity in the form of a DC voltage, water vapor and carbon or carbon dioxide. In many ways, a fuel cell is like a large battery that will produce power and heat indefinitely as long as it is provided with a hydrogen -rich fuel source. Hydrogen is a highly flammable gas that is colorless, odorless, and tasteless. This makes it very hard to detect a hydrogen leak. Hydrogen is a very light gas, so it rises quickly from any leak point and, when released in large quantities, can collect at roof level until it dissipates. Similar to other DG Facilities, there is a fire and/or explosion hazard associated with Fuel Cells should the gas leak and ignite. There are a number of ways to address the fire and explosion hazards associated with hydrogen dispensing within the building, including limiting the amount of hydrogen that may be released during an accident, controlling ignition sources, maintaining the equipment associated with hydrogen in good condition, and ensuring that dispensing units are installed properly per the required California Fire Code standards and regulations. Similar to Microturbines and combustion gas turbines discussed above, Fuel Cell DG Facilities would be required to comply with California Fire Code Chapter 53, pertaining to compressed gasses. There are also several Cal/OSHA standards that pertain to fire and explosion hazards for fuel cells. The following standards (which may not include all applicable standards) may be applicable to employers storing, using, or producing hydrogen, or can be considered as a useful source for information pertaining to hazards of hydrogen. ■ 29 CFR 1910.38, Emergency action plans, specifies the required content of an emergency action plan when an emergency action plan is required by another standard. ............................................................................................................................................................................................................................................ Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 5-6 Hazardous Materials Analysis 29 CFR 1910.101, Compressed gases (general requirements), contains requirements for compressed gases in containers including cylinders, portable tanks, rail tankcars, or motor vehicle cargo tanks. The inspection requirements of compressed gas cylinders are contained under 1910.101(a); the in -plant handling, storage, and utilization of all compressed gases in cylinders, portable tanks, rail tankcars, or motor vehicle cargo tanks under paragraph (b); and the safety relief device requirements for compressed gas containers in paragraph 1910.101(c). ■ 29 CFR 1910.103, Hydrogen, contains requirements for hydrogen systems. Paragraph (b) of this section applies to gaseous hydrogen systems on consumer premises where the hydrogen supply originates outside the consumer premises and is delivered by mobile equipment. It does not apply to gaseous hydrogen systems having a total hydrogen content of less than 400 cubic feet, nor to hydrogen manufacturing plants or other establishments operated by the hydrogen supplier or his agent for the purpose of storing hydrogen and refilling portable containers, trailers, mobile supply trucks, or tank cars. Paragraph (c) under Section 1910.103 applies to liquefied hydrogen systems on consumer premises. The standard excludes liquefied hydrogen portable containers of less than 150 liters (39.63 gallons) capacity and liquefied hydrogen manufacturing plants or other establishments operated by the hydrogen supplier or his agent for the sole purpose of storing liquefied hydrogen and refilling portable containers, trailers, mobile supply trucks, or tank cars. ■ 29 CFR 1910.119, Process safety management of highly hazardous chemicals, covers processes containing a threshold quantity of a highly hazardous chemical. A process is defined as "...any activity involving a highly hazardous chemical including any use, storage, manufacturing, handling or on -site movement of such chemicals, or combination of these activities." The standard applies to flammable liquids and gases at a threshold quantity of 10,000 pounds or more, specified quantities of chemicals listed in Appendix A of the standard, and to the manufacture of explosives. Because hydrogen would be covered as a flammable gas, the PSM standard would apply to processes containing hydrogen in quantities of 10,000 pounds or more, with some exceptions. ■ 29 CFR 1910.120, Hazardous waste operations and emergency response, contains requirements for emergency response operations. When there is more than an incidental release of hydrogen, or a substantial threat of a release, then emergency response operations must comply with Section 1910.120(q), "Emergency response to hazardous substance releases." ■ 29 CFR 1910.132(a), Personal protective equipment, requires that protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective ............................................................................................................................................................................................................................................ Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 5-7 Hazardous Materials Analysis ............................................................................................ clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever necessary. ■ 29 CFR 1910.156, Fire brigades, contains requirements for the organization, training, and personal protective equipment of fire brigades whenever they are established by an employer. The requirements under 1910.156 apply to fire brigades, industrial fire departments, and private or contractual type fire departments. Personal protective equipment requirements contained in this section apply only to members of fire brigades performing interior structural firefighting. ■ 29 CFR 1910.307, Hazardous (Classified) locations, contains requirements for electrical installations in hazardous locations. Locations where flammable concentrations of hydrogen may exist under normal or abnormal conditions may be classified as Class I, Division 1 or 2 locations. Electric equipment in these locations must be: (1) Approved as intrinsically safe for locations, (2) approved for installation in locations classified due to the presence of hydrogen, or (3) of a type and design which the employer demonstrates would provide protection from the hazards arising from the combustibility and flammability of hydrogen. ■ 29 CFR 1910.1200, Hazard communication, requires that hazards associated with hydrogen must be conveyed to employees. In addition, the standard requires that the information be transmitted through a comprehensive hazard communication program, including, but not limited to, container labeling, material safety data sheets, and employee training on the hazards associated with handling hydrogen. Thus, with compliance with the California Fire Code and OSHA standards and regulations, similar to existing industrial uses already present in the City, impacts in this regard would be reduced to less than significant levels. Other DG Facilities In addition to those long-term impacts described above, biomass and waste -carpet to energy DG facilities could result in unknown hazards associated with explosion/fire hazards as a result of operations. These facilities currently require a CUP and this requirement should be maintained. The CUP allows for the requirement of an evaluation of materials and wastes generated, as part of a project -specific CEQA process, and allows the City to establish project specific conditions. 5.2.4 Potential Impacts to School Sites One school site, City of Vernon Elementary School (located at 2360 East Vernon Avenue) is present within the City. Other existing schools are also present within one -quarter mile of the City boundary, including Holmes Elementary School, Animo Jefferson Charter Middle School, Aspire Pacific Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 5-8 M Hazardous Materials Analysis ............................................................................................................................................................................................................................................. Academy, Pacific Boulevard Elementary School, San Antonio Elementary School, Renuevo School, Maywood Elementary School, and Childtime. PV Systems are not anticipated to result in any emissions or handling of hazardous materials within one -quarter mile of an existing or proposed school facility. Thus, no impacts would result in this regard. However, other DG facilities, such as biomass, diesel -fired generators, and/or waste -carpet to energy emissions, could emit hazardous substances into the air. Under AB 1807, CARB is required to use certain criteria in the prioritization for the identification and control of air toxics. In selecting substances for review, the CARB must consider criteria relating to "the risk of harm to public health, amount or potential amount of emissions, manner of, and exposure to, usage of the substance in California, persistence in the atmosphere, and ambient concentrations in the community." AB 1807 also requires CARB to use available information gathered from the AB 2588 program to include in the prioritization of compounds. This report includes available information on each of the above factors required under the mandates of the AB 1807 program. AB 2588 air toxics "Hot Spots" program requires facilities to report their air toxics emissions, ascertain health risks, and to notify nearby residents of significant risks. In September 1992, the "Hot Spots" Act was amended by Senate Bill 1731 which required facilities that pose a significant health risk to the community to reduce their risk through a risk management plan. Thus, with implementation of a risk management plan, as required by State law, impacts in this regard would be reduced to less than significant levels. Further, some proposed DG facilities may require the handling/storage of petroleum products or other hazardous materials. These facilities would be required to comply with CUPA regulations pertaining to submittal of appropriate risk management plan(s) and/or business plans to the VHECD. Thus, with implementation of Federal, State, and local laws and regulations, impacts in this regard would be reduced to less than significant levels. As discussed above, for those DG facilities such as diesel -fired generators, biomass, and/or waste - carpet to energy, that could result in the handling and/or transport of hazardous materials (such as high BTU materials) and/or the production of hazardous waste as a result of operations. These facilities currently require a CUP and this requirement should be maintained. The CUP would also allow requiring an evaluation of materials and wastes generated as part of a project -specific CEQA process and would allow the City to establish project specific conditions. ............................................................................................................................................................................................................................................ Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 5-9 �.- Section 6 MITIGATION MEASURES RBF Baker has performed this Assessment in conformance with the Scope -of -Services for the Vernon Distributed Generation Project, located in the City of Vernon, Los Angeles County, California. 6.1 RECOMMENDED MEASURES This analysis identifies potential hazardous materials contamination concerns that may be encounter associated with the development of DG Facilities (as well as any other ground disturbing occurrences) in the City. It should be noted due to the City's industrial nature, installing small DG facilities would not be substantially different than many other site improvement or construction projects that already occur in the City on a regular basis without a CUP. If the City believes these projects, conducted under the existing building permit process, do not result in a significant environmental impacts related to hazardous materials and environmental contamination, no additional mitigation would be necessary for a proposed small DG facility. However, if the City believes that an additional level of review should be conducted for DG projects, the following mitigation measures are examples of typical mitigation to reduce or minimize in potentially significant hazardous materials - related impacts. MM-1 A formal Phase 1 Environmental Site Assessment (ESA) shall be prepared on a project -by -project basis for those DG facilities that require site grading/excavation on any commercial and/or industrial properties. The Phase I ESA shall be prepared in accordance with the most current ASTM Standard Practice E 1527 or the Standards and Practices for All Appropriate Inquiry (AAI), prior to any grading/excavation activities. The Phase I ESA shall identify specific Recognized Environmental Conditions (RECs), which may require further sampling/remedial activities by a qualified Phase II/Site Characterization Specialist. The Phase II/Site Characterization Specialist shall identify proper remedial activities, if necessary. MM-2 For proposed DG facilities that require disturbance of exposed soils along railroad spurs, a qualified Phase II/Site Characterization Specialist, retained by the Applicant, or his/her designee, shall conduct sampling in order to determine whether or not contamination exists within the areas of proposed disturbance. Should a hazardous condition for construction workers be potentially present, the Phase II/Site Characterization Specialist shall prepare a Soils Management Plan and Worker Safety Plan (compliant with Cal/OSHA standards) to ensure worker safety and proper handling of contaminated soils during construction. The plans shall be reviewed and approved by the City Engineer prior to site disturbance activities. MM-3 The project contract specification shall require that, in the event evidence of potential soil contamination such as soil discoloration, noxious odors, debris, or buried storage Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 6-1 'N . Mitigation Measures containers, is encountered during construction, the contractor shall have a contingency plan for sampling and analysis of potentially hazardous substances. The required handling, storage, and disposal methods shall depend on the types and concentrations of chemicals identified in the soil. Any site investigations or remediation shall comply with applicable laws and the project contractor shall coordinate with the appropriate regulatory agencies, as required by law. ............................................................................................................................................................................................... Vemon Distributed Generation Project Preliminary Hazardous Materials Assessment 6-2 1%, Section 7 LEVEL OF SIGNIFICANCE AFTER MITIGATION RBF Baker has performed a Preliminary Hazardous Materials Assessment (Assessment) in conformance with the Scope -of -Services for the Vernon Distributed Generation Project, located in the City of Vernon, California; also known as the project within this Assessment. This Assessment is intended to provide the City of Vernon with information regarding potential hazardous materials related impacts. Based on the analysis provided within this Assessment, potential significant impacts from the proposed project related to hazardous materials for the proposed Vernon Distributed Generation Project would be similar to other activities that already occur in the City without a CUP. However, should a condition arise, that which the City believes additional actions would be required in order to reduce potential issues of concern to less than significant levels sample Mitigation Measures I (MM-1) through MM-3 have been provided. Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 7-1 `- Section 8 REFERENCES California Department of Toxic Control Substances, EnviroStor, http://www.envirostor.dtsc.ca.gov/ public/mapfull.asp?global id=36000003, accessed January 20, 2015. California Environmental Protection Agency, Cortese List, http://www.calepa.ca.gov/SiteCleanup// CorteseList/default.htm, accessed January 20, 2015. City of Vernon, General Plan, December 2007 Emergency Planning Consultants, City of Vernon Natural Hazards Mitigation Plan. October 20, 2004. Power Engineers, Distributed Generation Impact Study Hazard Analysis, dated March 3, 2015. State Water Resource Control Board, GeoTracker, http://geotracker.swrcb.ca.gov/, accessed January 20, 2015. USGS Topographic Quadrangle, Los Angeles, Calm Quadrangle, dated 1966, photorevised 1981 and South Gate, Calif. Quadrangle, dated 1964, photorevised 1981 Vernon Distributed Generation Project Preliminary Hazardous Materials Assessment 8-1 �.- Appendix A Regulatory Database Searches Department of Toxic Substances Control: Cal/EPA "Cortese" List Page 1 of 2 Search ( j QCalEPA Site r California HOW Awill DEPARTMENTS PROORAIMS, NEWSROOM GETMOOLVIED Cortese List: Section 65962.5(a) Information Required From the Department of Toxic Substances Control (DTSC) Under Government Code Section 65962.5(a) Section 65962.5(a)(1) requires that DTSC "shall compile and update as appropriate, but at least annually, and shall submit to the Secretary for Environmental Protection, a list of all the following:....(1) [a]II hazardous waste facilities subject to corrective action pursuant to Section 25187 5 of the Health and Safety Code ("HSC").- The hazardous waste facilities identified in HSC § 25187.5 are those where DTSC has taken or contracted for corrective action because a facility owner/operator has failed to comply with a date for taking corrective action in an order issued under HSC § 25187, or because DTSC determined that immediate corrective action was necessary to abate an imminent or substantial endangerment. This is a very small and specific subgroup of facilities and they are not separately posted on the DTSC or CaIEPA's website. The facilities listed below fall under this category AAD Distribution & Dry Cleaning Inc. EPA ID CAD981397417 2306 E. 38th Street Vernon, CA 90058 The Marquardt Co. CA ID CAD044696102 16555 Saticoy Street Van Nuys, CA 91406 Section 65962.5(a)(2) requires that DTSC "shall compile and update as appropriate, but at least annually, and shall submit to the Secretary for Environmental Protection, a list of all the following:... (2) [a]II land designated as hazardous waste property or border zone property pursuant to Article 11 (commencing with Section 25220) of Chapter 6.5 of Division 20 of the Health and Safety Code." No facilities or lands are listed under this provision because DTSC has not designated any hazardous waste property or border zone property pursuant to the cited provisions. Section 65962.5(a)(3) requires that DTSC "shall compile and update as appropriate, but at least annually, and shall submit to the Secretary for Environmental Protection, a list of all the following:....(3) [a]II information received by the Department of Toxic Substances Control pursuant to Section 25242 of the Health and Safety Code on hazardous waste disposals on public land. HSC § 25242(a) requires a city, county, or state agency that owns or leases land to notify DTSC if it "has probable cause to believe that a disposal of hazardous waste, which is not authorized pursuant to this chapter has occurred on, under or into the land which the city, county, or state agency owns or leases..."; DTSC then shall determine if there has been an unauthorized disposal of hazardous waste. In practice, if a city, county or state agency contacts DTSC to provide such information, they also will have contacted or will be directed to contact DTSC's Emergency Response Duty Officer, who determines whether to authorize DTSC-funding for an emergency action to property remove and dispose of the hazardous waste. DTSC's Emergency Response program does not keep separate records of such reports that relate to city, county or state agency property. In the future, DTSC will track any reports received from cities, counties, or state agencies of hazardous waste disposal on land owned or teased by a city, county or state agency, where hazardous waste was released into the environment, and provide the information to CaIEPA for inclusion in this section of the Cortese list. Section 65962.5(a)(4) requires that DTSC "shall compile and update as appropriate, but at least annually, and shall submit to the Secretary for Environmental Protection, a list of all the following:....(4) [a]II sites listed pursuant to Section 25356 of the Health and Safety Code." HSC § 25356(b)(1) requires "a listing of hazardous substance release sites selected for, and subject to, a response action under this chapter." HSC § 25356(b)(2) requires DTSC to "update the list of sites at least annually to reflect new information regarding previously listed sites or the addition of new sites requiring response action." The implementing regulations provide that sites may be listed pursuant to HSC § 25356 if (a) they are not owned by the Federal Government and (b) a release or threatened release of hazardous substances has been confirmed by on -site sampling. (California Code of Regulations, Title 22. Section 67400.1). DTSC's list of sites that meet those criteria as well as the criteria in HSC § 25356(c), is found in a report in DTSC's "Envirostor" database: • Hazardous Waste and Substances site "Cortese" list Sites where response actions have been completed and no operation and maintenance activities are required are not included on the list. Section 65962.5(a)(5) requires that DTSC "shall compile and update as appropriate, but at least annually, and shall submit to the Secretary for Environmental Protection, a list of all the following:....(5) [a]II sites included in the Abandoned Site Assessment Program." DTSC had an abandoned site program in the 1980s. HSC § 25369, which was enacted in 1985, required an abandoned site survey in "rural unsurveyed counties." Sites identified in the abandoned site program were included in the "CalSites" database of known and potential hazardous substance release sites. After further investigation, many sites were removed from the "CalSites" database because there was no evidence that a release of hazardous substances occurred. Some time in the early 1990s, DTSC's activities under HSC § 25369, and the entire Abandoned Site Program, were concluded. DTSC recently replaced the "CalSites" database with a new database of hazardous substance release sites, known as the "EnviroStor" database. The EnviroStor database does not indicate if a specific site was at one time included in the abandoned site program and does not have a category for sites that are considered abandoned. The CalSites database also did not include this information. Consequently, DTSC does not provide the information to CaIEPA originally called for under section 65962.5(a)(5). Background and History I Cortese List Home Share This http://www.calepa.ca.gov/SiteCleanup/CorteseList/SectionA.htm 1/22/2015 Department of Toxic Substances Control: Cal/EPA "Cortese" List Page 2 of 2 Last updated: October 06, 2011 California Environmental Protection Agency, http//www. calepa. ca. gov General Public Contact, cepacomm@calepa.ca.gov (916) 323-2514 Back to Top I CaIEPA Home I Conditions of Use I Accessibility I Help I Contact Us Copyright © 2016 California Environmental Protection Agency. All rights reserved. http://www.calepa.ca.gov/SiteCleanup/CorteseList/SectionA.htm 1/22/2015 h O > F U y Z. � Vxi � L➢ .,.1 {y�{y�� a Z �� Q � 0 � Q z > ,, ❑ u p �a F° w a z uFi Q°° in LL w t+Nd z .w.t F U¢ Z, p m i o z z ° z u 3 z z Oy o N w g z ❑ U OLL } F V p w z j Op U O D U OV o o z u z u o a uW u N o o r uuf�. a z a > Q ❑ 7� V 7 z F f w C ¢ ❑ ❑ Z w z U> Q z a❑ C U 7� w Z O w a¢° '� ti V Y '] z t>zi ❑ Z. 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Q m 0 w C Envirostor Page 1 of 3 DEPAMMU OF TOXIC fDRRANCO COMM ENVIROSTOR HAZARDOUS WASTE AND SUBSTANCES SITE LIST EARCH CRITERIA: 54 RECORDS FOUND EXPORT TO EXCEL PAGE 11 OF 12 SITE / FACILITY PROGRAM ADDRESS ESTOR I EPA ID STATUS CITY ZIP COUNTY NAME TYPE DESCRIPTION MONTROSE FEDERAL 20201 LOS .EPORT] [MAPI CHEMICAL 19280024 SUPERFUND -ACTIVE NORMANDIE TORRANCE 90502 ANGELES CORP LISTED AVENUE HALBERTS STATE 2026 ABALONE LOS EPORTI [MAPI 19240022 BACKLOG TORRENCE 90501 LUMBER, INC. RESPONSE AVENUE ANGELES CORNER OF TRACY BLVD RENOWN STATE SAN REI PORTI fMAPI 39650001 BACKLOG AND TRACY 95376 HOMES RESPONSE OAQUIN JOAQUIN BEECHNUT AVE LAWRENCE FEDERAL CORRAL SAN [REPORTI (MAPI LIVERMORE NAT 39730018 SUPERFUND -ACTIVE HOLLOW TRACY 94550 JOAQUIN LAB 300(USDOE) LISTED ROAD DEFENSE FEDERAL ACTIVE - LAND 25600 S REf PORTI [MAPI DISTRIBUTION SAN39970003 SUPERFUND -USE CHRISMAN TRACY 95304 SAN JOAQUIN (DDJC) JOAQUIN LISTED RESTRICTIONS RD TRACY FEDERAL ACTIVE - LAND 5025 ACRES; 3 TRAVIS AFB - REj_ PORK (MAPI 48970001 SUPERFUND -USE MILES EAST OF TRAVIS 94535 SOLANO IR/MMRP LISTED RESTRICTIONS FAIRFIELD,CA VALLEY WOOD FEDERAL ACTIVE - LAND 2237 SOUTH REf PORT] (MAPI PRESERVING, 50240001 SUPERFUND -USE GOLDEN STATETURLOCK 95380 STANISLAUS INC. LISTED RESTRICTIONS BLVD NEWPORT TUSTIN MARINE ACTIVE - LAND STATE FREEWAY AT REPOR (MAPI CORPS AIR 30970002 USE TUSTIN 92710 ORANGE RESPONSE EDINGER STATION RESTRICTIONS AVENUE 595,367 TWENTY-NINE ACRES;5MI NOTWENTYNINE PALMS MARINE STATE SAN REPORT (MAPI 60001867 ACTIVE OF 92278 CORPS AGCC RESPONSE PALMS BERNARDINO TWENTYNINE (MMRP) PALMS 595,367 TWENTY-NINE ACRES;5MI NO STATE TWENTYNINE SAN RE( PORT] [MAP] PALMS MARINE 36970007 ACTIVE OF 92278 RESPONSE PALMS BERNARDINO CORPS AGCC TWENTYNINE PALMS CAMP COOKE MILITARY SANTA [REPORT] [MAPI 80001130 ACTIVE TANGAIR POW CAMP EVALUATION BARBARA 5 MILES EAST RE[ PORTI (MAPI TEMECULA LA BOMB 80001161 STATE BACKLOG OF DOWNTOWNTEMECULA 92593 RIVERSIDE TARGET RESPONSE TEMECULA STATE 1918 ARTESIA LOS [REPORT] [MAPI MOMIN LODGE 60001010 ACTIVE TORRANCE 90504 RESPONSE BOULEVARD ANGELES FREEMAN STATE 2040 ARTESIA LOS REf PORTIfMAPI PRODUCTS/ 60000835 ACTIVE TORRANCE 90504 RESPONSE BOULEVARD ANGELES AVNET INC. OTH BRS STATE N 41.710423; W [REPORT] (MAPI 60001244 ACTIVE TULELAKE 96134 MODOC TULELAKE - IR RESPONSE 121.178084 [REPORT] (MAPI COAST WOOD 23240013 CERTIFIED / PLANT RD & UKIAH 95482 MENDOCINO PRESERVING OPERATION & TAYLOR DR http://www.envirostor.dtsc.ca.gov/public/search.asp?page= I I &cmd=search&business_na... 1 /23/2015 Envirostor Page 2 of 3 PACIFIC STATES IMAPI STEEL -PHASE 01330031 III OLD ORCHARD 'REPORTI IMAP1 SHOPPING 19720018 CENTER IREPORTI IMAPI MARE ISLAND 48330003 LENNAR MARE ISLAND REf PORT] IMAPI NAVAL 48970002 SHIPYARD [REPORTI IMAPI MARE ISLAND 48000004 WESTON [REPORTI IMAPI B & S AUTO 56750014 PARTS/SALVAGE AAD DISTRIBUTION [REPORTI IMAPI & DRY CLEANING, 19000031 INC. [REPORTI IMAPI VICTORVILLE PBR 80000529 SO CAL IMAPI GASIVISALIA 54490015 MGP GOSHEN AVENUE IMAPI AND SHIRK ROAD 54270005 SITE IMAPI OXNARD FLIGHT 80000858 STRIP IMAPI PECHINEY 60001187 [MAPI LA ORDNANCE 80000292 DEPOT IMAPI VICTORVILLE PBR 80000509 2 [MAPI VICTORVILLE PBR 80000406 NO 10 FEDERAL MAINTENANCE SUPERFUND - LAND USE LISTED RESTRICTIONS CERTIFIED / STATE OPERATION & 35124 RESPONSE MAINTENANCE - ALVARADO- UNION CITY 94587 ALAMEDA LAND USE NILES ROAD RESTRICTIONS STATE 23357LYONS LOS ACTIVE VALENCIA 91355 RESPONSE AVENUE ANGELES ACTIVE - LAND 900 WALNUT STATE USE AVENUE, VALLEJO 94592 SOLANO RESPONSE RESTRICTIONS QUARTERS D W END OF ACTIVE - LAND STATE TENNESSEE USE VALLEJO 94590 SOLANO RESPONSE STREET, MARE RESTRICTIONS ISLAND ACTIVE - LAND 750 DUMP STATE USE ROAD - PO BOX VALLEJO 94592 SOLANO RESPONSE RESTRICTIONS 2135 STATE 89 PEKING BACKLOG VENTURA 93001 VENTURA RESPONSE STREET STATE 2306 E. 38TH LOS ACTIVE VERNON 90058 RESPONSE STREET ANGELES 42 MILES EAST MILITARY BAN ACTIVE OF VICTORVILLE 92278 EVALUATION BERNARDINO VICTORVILLE CERTIFIED / OPERATION & 300 NORTH STATE MAINTENANCE - TIPTON VISALIA 93277 TULARE RESPONSE LAND USE STREET RESTRICTIONS 6941 AND 6707 STATE ACTIVE WEST GOSHEN VISALIA 93291 TULARE RESPONSE AVENUE MILITARY ACTIVE EVALUATION STATE ACTIVE RESPONSE MILITARY ACTIVE EVALUATION MILITARY ACTIVE EVALUATION MILITARY ACTIVE EVALUATION VICTORVILLE PBR MILITARY [REPORTI IMAPI 80000507 ACTIVE NO 17 EVALUATION [REPORT] [MAPI VICTORVILLE PBR 80001184 MILITARY ACTIVE NO 12 EVALUATION VICTORVILLE PBR MILITARY [REPORT] IMAPI 80000526 ACTIVE NO 6 EVALUATION VICTORVILLE PBR MILITARY RE[ PORT] [MAPI 80000511 ACTIVE NO 3 EVALUATION [REPORTI IMAPI VICTORVILLE PBR 80000522 MILITARY ACTIVE NO 15 EVALUATION VENTURA VENTURA 3200 LOS FRUITLAND VERNON 90058 ANGELES AVENUE LOS VERNON ANGELES 8 MILES EAST SAN OF VICTORVILLE 92356 BERNARDINO VICTORVILLE 34 MILES EAST SAN OF VICTORVILLE 92278 BERNARDINO VICTORVILLE 75 MILES EAST SAN OF VICTORVILLE 92278 BERNARDINO VICTORVILLE 43 MILES EAST SAN OF VICTORVILLE 92278 BERNARDINO VICTORVILLE 15 MILES EAST SAN OF VICTORVILLE 92356 BERNARDINO VICTORVILLE 10 MILES SAN NORTHEAST OFVICTORVILLE 92307 BERNARDINO VICTORVILLE 60 MILES EAST SAN OF VICTORVILLE 92278 BERNARDINO VICTORVILLE http://www.envirostor.dtsc.ca.gov/public/search.asp?page= I I &cmd=search&business_na... 1 /23/2015 Envirostor Page 3 of 3 REf PORTI [MAPI VICTORVILLE PBR 80000506 MILITARY ACTIVE NO 16 EVALUATION FREPORTI (MAPI VICTORVILLE PBR 80000521 MILITARY ACTIVE NO 14 EVALUATION [REPORTI [MAP] VICTORVILLE PBR 80000520 MILITARY ACTIVE NO 11 EVALUATION [REPORT] [MAP] VICTORVILLE PBR 80000528 MILITARY ACTIVE NO 8 EVALUATION VICTORVILLE PBR MILITARY RE[ PORT[ [MAPI 80000524 ACTIVE NO 4 EVALUATION MILLERS DRY STATE RE[ PORTI [MAPI 60000242 ACTIVE CLEANERS RESPONSE MISSION STATE REf PORT[ fMAP1 60000969 ACTIVE UNIFORM RESPONSE ONE HOUR STATE RE[ PORT[ MAP 60000236 ACTIVE MARTINIZING RESPONSE COUNTRY CLUB STATE rREPORTI (MAPI CLEANERS, 60001054 ACTIVE RESPONSE WHITENDALE LAMOUR'S STATE REr PORTI [MAPI CLEANERS, 60001052 ACTIVE RESPONSE MOONEY VISALIA DRY STATE REr PORTI [MAP] CLEANER 60000403 ACTIVE RESPONSE INVESTIGATION FORMER STATE RE[ PORTI [MAPI WEBSTER 60001352 ACTIVE RESPONSE CLEANERS PARAGON DRY STATE RE[ PORT[ IMAPI 60000240 ACTIVE CLEANERS RESPONSE MILLER'S STATE RE[ PORT[ [MAPI CLEANERS, 60001050 ACTIVE RESPONSE WHITENDALE Prey 50 JUMP TO PAGE: 1 2 3 4 5 6 7 8 9 10 11 12 65 MILES EAST VICTORVILLE 92278 SAN OF BERNARDINO VICTORVILLE 50 MILES EAST SAN OF VICTORVILLE 92278 BERNARDINO VICTORVILLE 42 MILES EAST SAN OF VICTORVILLE 92278 BERNARDINO VICTORVILLE 26 MILES EAST SAN OF VICTORVILLE 92395 BERNARDINO VICTORVILLE 11 MILES SAN SOUTHEAST OFVICTORVILLE 92307 BERNARDINO VICTORVILLE 110 NORTH VISALIA 93291 TULARE WILLIS 520 E. MINERAL KING VISALIA 93292 TULARE AVENUE 717 WEST MAIN VISALIA 93291 TULARE STREET 2000 W. WHITENDALE WHITEVISALIA 93277 TULARE WHI 2911 S. MOONEY VISALIA 93277 TULARE BLVD. CENTRAL CITY VISALIA 93277 TULARE AREA 4634 W. MINERAL KING VISALIA 93291 TULARE AVENUE 119 SOUTH WILLIS VISALIA 93291 TULARE STREET 2235 W. 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Document preparation was conducted by both Ms. Bogue and Mr. Wesley Salter. Document research and records gathering was conducted by Mr. Timothy Tidwell. Kristen Bogue Environmental Professional Ms. Bogue graduated from the University of California, Irvine, with a degree in Environmental Analysis and Design. Mr. Bogue's professional environmental experience of nine years includes the management, review, and preparation of hazardous material assessments, which include: Phase I Environmental Site Assessments, Initial Site Assessments for the California Department of Transportation (Caltrans), Preliminary Hazardous Material Assessments, Existing Hazardous Material Conditions Assessments, and Environmental Baseline Surveys for the Department of the Navy for sites located throughout California, Arizona, and New Mexico. As an environmental analyst, Ms. Bogue is also involved with preparation of Environmental Documentation compliance with the California Environmental Quality Act (CEQA)/National Environmental Protection Act (NEPA), Visual Impact Assessments (VIAs), field studies, as well as various technical studies in support of CEQA and NEPA. In the past nine years Ms. Bogue has personally evaluated over 250 real properties in California. Wesley Salter Environmental Professional Mr. Salter graduated from California Polytechnic State University, San Luis Obispo, with a degree in Forestry and Natural Resources. Mr. Salter assists in the preparation of environmental and planning studies for public and private sector clients. As an Environmental Analyst at RBF Baker, Mr. Salter is involved with 404/401/1600 permit processing, wetland delineations, field studies, Phase I ESAs, and permitting in accordance with CEQA and NEPA. Mr. Salter's professional environmental experience of five years includes the management, review, and preparation of hazardous material assessments, which include: Phase I Environmental Site Assessments, Initial Site Assessments for the California Department of Transportation (Caltrans), Preliminary Hazardous Material Assessments, and Environmental Baseline Surveys for the Department of the Navy for sites located throughout California, Nevada, and Arizona. Tim Tidwell Environmental Analyst Mr. Tidwell assists in the preparation of environmental and planning studies for public and private sector clients. As an Environmental Analyst at RBF Baker, Mr. Tidwell is involved with 404/401/1600 permit processing, wetland delineations, field studies, Phase I ESAs, and permitting in Qualifications accordance with CEQA and NEPA. Mr. Tidwell's professional environmental experience includes the management, review, and preparation of hazardous material assessments, which include: Phase I Environmental Site Assessments, Initial Site Assessments for the California Department of Transportation (Caltrans), and Preliminary Hazardous Material Assessments. POWER ENGINEERS, INC. Distributed Generation Imvact Study APPENDIX E VERNON GAS AND ELECTRIC DEPARTMENT RATE STRATEGY ANA 092-062 (SR 02) COV 135853 (05/08/2015) YU PAGE E-1 POWER ENGINEERS, INC. Distributed Generation Impact Study I%.- THIS PAGE INTENTIONALLY LEFT BLANK ANA 092-062 (SR 02) COV 135853 (05/08/2015) YU PAGE E-2 DraftReport I May 4, 2015 Rate Strategy Vernon Department of Gas and Electric Prepared by: NewGen Strategies \1 1.. Table of Contents Vernon Gas and Electric Department Draft Rate Strategy...................................................1 Introductionand Purpose................................................................................................1 Alignment with the City of Vernon and VG&E's Strategic Plan and Direction ................. 2 RateStrategy....................................................................................................................3 Comply with City Council Policy and Regulations .................................................. 3 FinancialStability...................................................................................................4 Equityand Fairness................................................................................................4 Comply with Conservation and Renewable Energy Requirements While Offering Customer Choice........................................................................... 5 Maintain Competiveness and High Value Services while Accomplishing Changes through Gradualism................................................................................ 6 Engage Stakeholders and Communication............................................................ 7 AccommodatingGrowth........................................................................................ 8 NewGen Strategies Economics I Strategy I Stakeholders I Sustainability VERNON GAS AND ELECTRIC DEPARTMENT DRAFT RATE STRATEGY Introduction and Purpose Vernon Gas and Electric Department (VG&E) is a publicly owned utility offering natural gas, electric, and fiber broadband services governed by a City Council. Electric distribution services are provided to approximately 1,900 retail customers in the City of Vernon. VG&E primarily serves commercial and industrial customers within its service territory. Approximately 95 percent of VG&E's customers are commercial or industrial, while only five percent are residential and other. VG&E purchases all of their power and energy needs from the California Independent System Operator (CAISO) (e.g. market) and long term purchased power agreements. VG&E owns and operates a 30 mw facility located at 2715 E 50th St for power generation.. In 2008, VG&E sold the Malburg Generating Station (MGS) to a third party and entered into a long term power purchase and tolling agreement to purchase power from MGS while supplying the natural gas to operate the plant. VG&E receives power from natural gas, nuclear, hydroelectric and renewable resources. To meet renewable energy requirements in the state of California, VG&E purchased 20 percent of its retail energy needs from renewable energy sources including renewable biomethane gas to operate gas power plants and renewable energy certificates (RECs). By the end of 2020, VG&E will be required to purchase 33 percent of its total retail needs from approved renewable energy resources and RECs. VG&E's service territory encompasses 5.2 square miles and includes 145 miles of transmission and distribution lines serving eight substations. 70 percent of VG&E's system is overhead conductors and lines. VG&E did own and operate the 134 MW natural gas fired, combined cycle MGS it originally constructed in 2005; however, the plant was sold in 2008. While VG&E and the City of Vernon have a long history of providing competitive, reliable power to its customers, the utility, similar to others across the country, is facing significant changes and challenges. The electric industry and market is changing like no other time in the past 50 years. Technological advancements such as advanced metering, heightened customer interest in renewable energy, energy efficiency, sustainability, and other environmental concerns are driving significant change in the operation of the power grid, utility systems, and customer expectations. These changes result in increasing the cost of power supply and distribution operating and capital costs while lowering overall power sales per customer. As the business environment is becoming increasingly complex and uncertain, utilities must identify and successfully manage their business risk through a variety of strategies that encompass power supply, conservation, renewables, efficiency, distributed generation, and demand response options. To be successful, the City of Vernon and VG&E must send a consistent message to customers aligning the values of the community and utility to the corresponding customer incentives. Rate design is the most important customer incentive or pricing signal given to VG&E customers. To successfully support utility strategies over the long-term, pricing structures and signals must align with desired changes in customer behavior and utility financial objectives. The purpose of this document is to describe VG&E's financial objectives and rate design strategies to successfully achieve the utility's long range goals and objectives. Rate Strategy Document —DRAFT —for Report v4.docx �& Solutions Vernon Gas and Electric Department Draft Rate Strategy Together, VG&E's rate design strategies and financial objectives are known as the Rate Strategy. Due to the increasingly complicated and changing business environment, having a clear Rate Strategy, which is integrated with stakeholder engagement, is becoming a best practice for high performing utilities. The development of this initial Rate Strategy was facilitated by NewGen Strategies and Solutions, LLC (NewGen). An internal City of Vernon team met to discuss utility rate, finance, customer, and operational issues affecting the utility and the City. The team included representatives across the organization including City of Vernon finance, VG&E, economic development , City Administrator, resource planning, operations, and engineering. External stakeholder engagement is recommended and VG&E plans to hold a workshop with the existing Vernon Business and Industry Commission for targeted customer feedback in addition to potential public meetings / presentations (as needed) to provide all customers an opportunity for input to provide community and customer insight and feedback The benefits of the Business and Industry Commission include providing valuable input and feedback, fostering open dialogue, providing a forum to test decisions, and creating a common understanding about the issues and business environment the utility is facing. Additionally, the Business and Industry Commission can help create advocates in the community and gain endorsement of recommendations presented to the broader public. This process also allows the Rate Strategy recommendations to be vetted prior to presentation and review by the City Council. Alignment with the City of Vernon and VG&E's Strategic Plan and Direction �.. VG&E's financial strategy, service offerings, and rate structure must complement the existing strategic direction of the utility. Rate structures that do not align with strategic objectives can adversely impact initiatives taken by the utility to achieve those objectives and ultimately harm the overall financial stability of the utility. Additionally, misalignment between rates and strategic direction may send contradictory or confusing price signals to customers or negate incentives provided to support efficiency, conservation, or other emerging technologies the utility supports. The lack of consistency with strategic direction would erode trust by both internal and external stakeholders. For these reasons, the Rate Strategy is aligned with and supports the broader City of Vernon strategy and vision. The City of Vernon's utility system is unique when compared to other municipal and investor owned electric systems in California and across the country. The City of Vernon's electric utility was initially developed in 1932 to support and facilitate a major manufacturing and commercial business district. Today, the City of Vernon remains clearly focused on the manufacturing and business sector with more than 95 percent of customers classified as commercial or industrial. The City of Vernon's strategic focus outlines the utility's overall strategy and vision by defining the guiding principles for the utility to ensure it is well positioned for the future. This strategic focus at the City of Vernon includes: • Vernon Means Business includes a focus on developing an environment to support businesses, economic growth, and offering businesses a range of advantages compared to nearby cities. ■ Good Governance involves maintaining a transparent and robust governance structure in compliance with state requirements and financial best practices 2 Rate Strategy Document -DRAFT -for Report v4.docx Vernon Gas and Electric Department Draft Rate Strategy The Rate Strategy utilizes financial strategy and rate design best practices that support and align with the City of Vernon's economic development and governance principles. In addition to these strategic focus areas, VG&E is focused on being proactive with customers and within the market in understanding emerging technology and service impacts to its operations and reliability. In short, the utility wants to be prepared as the business model is changing. For instance, VG&E wants to be cognizant of changes and trends in the industry and to be positioned to take advantage of opportunities for its customers and ensure its operational reliability in the face of added renewable energy, and distributed generation. The Rate Strategy was developed to assist and support VG&E in pursuit of these strategic principles and objectives. Rate Strategy In order to guide the long-term development of financial strategy and rates, VG&E is adopting a core set of rate making principles that are intended to stand the test of time, help VG&E navigate the ever - changing electric market, and align rate making with Comply with City Council the City of Vernon's broader strategy. Finally, while pollicyawpMulations the Rate Strategy acts to guide current and future rate and cost of service (COS) related decisions, the Financial Stability final approval and direction for rate changes remains with the City of Vernon administrative Equity and Fairness leadership and City Council. Each of the central -- principles of the Rate Strategy are discussed below. c�nservation ;�' ue Comply with City Council Policy and MaieainlAcco High pli Services and Accomplish Regulations St LB VG&E must comply with state and federal laws and EngagesWke regulations, policies adopted by its Council, and - financial covenants made to bondholders. These AccommodatingGrowth policies and laws include: ■ Policies adopted by the City Council and City of Vernon administrative leadership; • Maintain 11.5 percent transfer of total ---- --- -- --- - electric revenue (i.e. total retail sales) as City Transfer to General Fund inclusive of VG&E in -lieu of tax, overhead transfers, shared services and operating transfers; and • California State Laws (e.g., Conservation and Renewable Portfolio Standards, Net Metering, Assembly Bill (AB) 32 Global Warming Solutions Act). In addition, VG&E must meet the requirements set forth in any outstanding bond covenants related to reserve funding level and debt service coverage amounts. Rate Strategy Document —DRAFT —for Report v4.docx 3 Vernon Gas and Electric Department Draft Rate Strategy Financial Stability The development of rates that ensure long-term fiscal integrity via an adequate and sustainable revenue stream is important to the future of VG&E. Dynamic market changes and customer usage patterns directly impact the ability to satisfy this principle and necessitate state of the art approaches. Without financial stability, VG&E could face severe financial consequences, including the inability to execute its fundamental business objectives. The Rate Strategy incorporates the following items to align with these principles: • Use of utility's financial policies as the foundation for the financial planning and rate update process. These policy targets are based on supporting a competitive and strong bond rating for the City of Vernon's debt issuances. Debt service coverage ratios and reserves are two key metrics affecting municipal utility's credit ratings. Financial stability and associated metrics will improve the credit ratings for the City and help to reduce the costs of debt. The following are key financial metrics included in the financial policies: • Debt Service Coverage Ratios (DSCR): maintain minimum ratio defined by bond official statements (currently 1.25 DSCR) with a goal and target of 1.5. • Debt to Capitalization Ratio Targets: long-term target of achieving an average annual 50/50 mix of funding for capital projects from debt issuances and cash from rates; however, retain the ability to optimize the use of debt with cash funded capital to maintain low rates. • Minimum Cash Reserves: develop and separately track reserve accounts for working capital (e.g. operating reserves), rate stabilization, and fuel cost adjustments. Minimum operating reserve account balance shall be 90 days of operating expenses, with a target of 120 days; rate stabilization reserves minimum and maximum amounts defined as [to be determined by VG&E and City staff] respectively, and a fuel cost adjustment (FCA) reserve adequate to manage the risk associated with the frequency of FCA changes (e.g. annually or seasonally). • Financial Planning: the VG&E will prepare a multi -year financial plan annually that communicates to the Council and stakeholders the current and projected financial condition of the utility and related rate change requirements. • Adopt and use an unbundled embedded cost COS framework for developing the annual cash basis revenue requirements and COS, as it is a standard approach and industry practice for public power and municipal utilities. ■ Management of fuel cost adjustment billing factors (FCABF) or charges to manage volatility in the natural gas fuel markets and the cost of power generation. The unbundled COS framework and model will provide the information and flexibility needed to develop a FCABF, as needed in the future. Equity and Fairness While the concept of fairness is subject to interpretation, a COS provides the basis for developing fair and equitable rates among different customer types. At the same time, selectively deviating from the strict COS results may be necessary to support the strategic 4 Rate Strategy Document —DRAFT —for Report v4.docx Vernon Gas and Electric Department Draft Rate Strategy objectives of the utility and values and needs of the community. When deviating from the strict COS results, the concept of fairness should be applied to determine how best to distribute those costs among customers. Closely associated with this principle is the idea that cross -subsidization between customer classes should be minimized. The Rate Strategy incorporates the following items to align with these principles: • Perform a comprehensive COS every five to seven years or when major changes to the system occur (e.g. large new customer on the system, dramatic change in power supply contracts, significant increase in distributed generation or new regulatory impacts.) which allocates costs based on cost -causation principles. ■ Gradually aligning rates with COS results, including aligning fixed and variable costs with fixed and variable portions of the rates. The unbundled COS will provide VG&E flexibility, accuracy, and transparency in allocating costs and developing rates. ■ Gradualism equates to a commitment to changing rates in smaller increments overtime rather than larger, one-time adjustments. This concept reduces volatility in rates and the potential for rate shock by smoothing rate changes over multiple periods. ■ Decrease and eliminate inter -class subsidization where material or deemed significant, and keep transparency in instances where this occurs or where guided by community values (e.g. economic development). • COS allocation methodologies should be in line with the cost incurrence in order to fairly and equitably allocate costs to the appropriate rate classes. These methodologies should be defendable and follow industry standards and guidelines. ■ Customer class criteria and class assignments should be evaluated to ensure customers with similar size, consumption requirements, and characteristics are grouped together appropriately, thus reducing intra-class subsidizations. ■ Allocation of system -wide, regulatory related, and customer distributed renewable energy costs will follow COS, regulatory requirements (e.g. Assembly Bill (AB) 327), and industry practices. • Design easy to understand rates that send clear pricing or behavioral signals to customers. Comply with Conservation and Renewable Energy Requirements While Offering Customer Choice Conservation and renewable programs provide environmental benefits to the community. VG&E has conservation and renewable energy target requirements under current California legislation including: ■ Senate Bill (SB) 1 in 2006 to incentivize and support solar photovoltaic (PV) through electric ratepayer -funded incentives. ■ AB 327 in 2013 to further define and incentivize net metering and customer -generated renewables. ■ AB 2021 in 2006 required the use and integration of cost effective energy efficiency and demand side management measures in resource plans. Rate Strategy Document —DRAFT —for Report v4.docx Vernon Gas and Electric Department Draft Rate Strategy • SB 2 in 2011 expanded and increased the Renewable Portfolio Standard program to require 33 percent of total energy procurement be from renewable energy resources by 2020. Rate structures can be developed that promote conservation and consumption patterns that promote the efficient use of resources by sending pricing signals to customers, particularly those customers with high consumption and/or inefficient consumption patterns. To encourage conservation, rates may be structured in blocks where the costs increase as consumption rises (i.e., tiered or inclining block rates). Additionally, demand charges and time - of -use pricing structures can be considered as long-term objectives to provide pricing signals to shift consumption to times when it costs less to produce and deliver the resource. Such rate structures empower customers to better manage their consumption and potentially lower their bills. However, such rate structures tend to reduce overall system load growth and can increase volatility in revenue stream. In order to lessen the negative impacts of growth decline, some utilities are recovering a greater portion of fixed costs through fixed charges. This is also in alignment with the COS results and the objective of preserving the financial stability of the utility. VG&E will follow a strategy of compliance with regard to energy efficiency and renewable energy purchases while supporting customer choice in rates, distributed renewables, and conservation. Customer rates, distributed renewable energy, and energy conservation options will use the COS results as a guide in addition to the City Council's direction. The Rate Strategy incorporates the following items to align with these principles: 1� • Comply with applicable state regulations for energy conservation and renewable energy requirements. Maintain current renewable energy compliance strategy. • Support and facilitate renewable distributed generation where desired by customers within limits for system and financial stability as defined by VG&E and the City, and in compliance with current SB-1 and AB 327 requirements where applicable. • Conservation practices are implemented to comply with requirements. Conservation oriented rates are not the current focus of the Rate Strategy and conservation services and products will be fairly valued and offered at a cost basis. ■ As or when customers begin requesting voluntary/customer choice options for the purchase of renewable energy, VG&E will provide service and product options at a cost - basis and where viable using REC's and/or other resources . • Properly recover fixed infrastructure costs from all customer classes, including distributed generation participants within customer classes. Gradually increase the customer base charge and demand related charges in current tariffs and customer classes to COS levels to better align the fixed and variable costs with the fixed and variable portions of the rates. Maintain Competiveness and High Value Services while Accomplishing Changes through Gradualism VG&E recognizes the need to maintain high value utility services for their majority commercial customers. In some stakeholders' minds, the terms "high value" and "affordable" are 6 Rate Strategy Document -DRAFT -for Report v4.docx Vernon Gas and Electric Department Draft Rate Strategy synonymous. However, the term affordable is subjective and may at times conflict with the need to raise rates to meet rising costs. Given these economic realities and VG&E's strategic objectives, a focus on high value, which includes elements such as customer service levels, reliability, choice, and cost, is more appropriate. This can be viewed as providing the right level of quality and service at the right price. The high value objective can be accomplished through clearly understanding stakeholder needs/perceptions and providing consistent customer education, as well as by phasing -in rate structure changes. Value delivered to customers can also be seen in VG&E's willingness to collaborate with customers on new services (e.g. distributed generation) by providing interconnection expertise. The phasing -in of rate change is known as gradualism and avoids "rate shock" by customers. With rate structure changes, bills can change gradually over time even as rates increase, thus supporting the objective of delivering high value. While gradualism reduces "rate shock", if rate changes are implemented at rates lower than necessary, any potential misalignment among the customer classes will be identified and tracked to identify unfunded areas for eventual corrections. In addition, gradualism allows for a "no regrets" approach to each decision and action; this is a sound method for reducing unintended consequences. Such unintended consequences potentially include having to undo actions taken previously due to customer misunderstanding and push back. An example of such an unintended consequence would be to institute an electric rate change now (e.g., tiered rates) when the longer -term strategy may lead to another approach (e.g., time of use pricing). The Rate Strategy incorporates the following items to align with these principles: ■ Utilize gradualism when faced with significant rate or customer related changes in maintaining high value services to customers. • Compare rates to benchmark utilities to ensure competitiveness and demonstrate affordability. ■ Where reserves are used for gradualism and to reduce rate increases required by the COS, VG&E will identify, quantify, and monitor unrecovered costs, underfunded areas and potential customer class recovery limitations for future COS and rate actions. Reserves shall not be used to reduce balances below previously stated levels without Council approval. Engage Stakeholders and Communication The Rate Strategy involves internal and external stakeholder engagement to foster communication, support transparency, educate, develop ideas, and encourage input and feedback. Leveraging stakeholder engagement mechanisms, groups, or key accounts are necessary to ensure proper representation and input to the Rate Strategy and ratemaking process. External stakeholders include community leaders, commercial businesses, and local representatives. This targeted engagement ensures broader participation, feedback, and eventual support of the Rate Strategy and future rate changes. Rate Strategy Document —DRAFT —for Report v4.docx Vernon Gas and Electric Department Draft Rate Strategy 1�._ Accommodating Growth As a matter of policy, VG&E implements practices that support and facilitate customer and City of Vernon growth. This current practice includes incentivizing economic development through rates and infrastructure extension by reducing and minimizing up -front or initial customer investment to extend or expand the electric infrastructure to serve the customer's load. The Rate Strategy incorporates the following item to align with these principles: • VG&E retains the flexibility to tailor cost recovery for customer related infrastructure extensions. Costs associated with significant infrastructure extensions and investments supporting specific customer growth can be recovered using two approaches or a hybrid of the two approaches: 1) extension costs are initially borne by VG&E and recovered in rates for service over a fixed period time; 2) extension costs are fully paid by the customer at the time of the extension. • VG&E will consider broader economic development benefits to the community and risks of stranded investments when evaluating and developing rates, cost recovery structures and agreements with new large loads. Where infrastructure investments are considered higher risk, VG&E may require partial or full up -front payment of infrastructure extensions or higher fixed charges in rates to reduce the utility's risk exposure or possible stranded costs if the customer were to leave prior to full repayment. 8 Rate Strategy Document —DRAFT —for Report v4.docx