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December 2015 5-1 Encina MOT DecommissioningProject MND

5.0 MITIGATION MONITORING PROGRAM1

The California State Lands Commission (CSLC) is the lead agency under the California2

Environmental Quality Act (CEQA) for the Cabrillo Power I LLC Encina Marine Oil3

Terminal Decommissioning Project (Project). In conjunction with approval of this4

Project, the CSLC adopts this Mitigation Monitoring Program (MMP) for implementation5

of mitigation measures (MMs) for the Project to comply with Public Resources Code6

section 21081.6, subdivision (a) and State CEQA Guidelines sections 15091,7

subdivision (d) and 15097.8

The Project authorizes Cabrillo Power I LLC (Applicant) to decommission the existing9

non-operational Encina Marine Oil Terminal (MOT), which is part of the Encina Power10

Station (EPS), in accordance with the terms and conditions of its existing CSLC Lease11

PRC 791.1.12

5.1 PURPOSE13

It is important that significant impacts from the Project are mitigated to the maximum14

extent feasible. The purpose of a MMP is to ensure compliance and implementation of15

MMs; this MMP shall be used as a working guide for implementation, monitoring, and16

reporting for the Project’s MMs.17

5.2 ENFORCEMENT AND COMPLIANCE18

The CSLC is responsible for enforcing this MMP. The Project Applicant is responsible19

for the successful implementation of and compliance with the MMs identified in this20

MMP. This includes all field personnel and contractors working for the Applicant.21

5.3 MONITORING22

The CSLC staff may delegate duties and responsibilities for monitoring to other23

environmental monitors or consultants as necessary. Some monitoring responsibilities24

may be assumed by other agencies, such as affected jurisdictions, cities, and/or the25

California Department of Fish and Wildlife (CDFW). The CSLC and/or its designee shall26

ensure that qualified environmental monitors are assigned to the Project.27

Environmental Monitors. To ensure implementation and success of the MMs, an28

environmental monitor must be on site during all Project activities that have the potential29

to create significant environmental impacts or impacts for which mitigation is required.30

Along with the CSLC staff, the environmental monitor(s) are responsible for:31

• Ensuring that the Applicant has obtained all applicable agency reviews and32

approvals;33

Mitigation Monitoring Program

Encina MOT Decommissioning 5-2 December 2015Project MND

• Coordinating with the Applicant to integrate the mitigation monitoring procedures1

during Project implementation (for this Project, many of the monitoring2

procedures shall be conducted during the deconstruction phase); and3

• Ensuring that the MMP is followed.4

The environmental monitor shall immediately report any deviation from the procedures5

identified in this MMP to the CSLC staff or its designee. The CSLC staff or its designee6

shall approve any deviation and its correction.7

Workforce Personnel. Implementation of the MMP requires the full cooperation of8

Project personnel and supervisors. Many of the MMs require action from site9

supervisors and their crews. The following actions shall be taken to ensure successful10

implementation.11

• Relevant mitigation procedures shall be written into contracts between the12

Applicant and any contractors.13

• For this Project, a marine wildlife training seminar (under MM BIO-1: Marine14

Wildlife Contingency Plan (MWCP)) for all Project personnel working in the15

marine environment would be held as part of a Project kickoff meeting wherein16

Project mitigation would be discussed.17

General Reporting Procedures. A monitoring record form shall be submitted to the18

Applicant, and once the Project is complete, a compilation of all the logs shall be19

submitted to the CSLC staff. The CSLC staff or its designated environmental monitor20

shall develop a checklist to track all procedures required for each MM and shall ensure21

that the timing specified for the procedures is followed. The environmental monitor shall22

note any issues that may occur and take appropriate action to resolve them.23

Public Access to Records. Records and reports are open to the public and would be24

provided upon request.25

5.4 MITIGATION MONITORING TABLE26

This section presents the mitigation monitoring table (Table 5-1) for the following27

environmental disciplines: Aesthetics, Biological Resources, Cultural Resources,28

Hazards and Hazardous Materials, Hydrology and Water Quality, Noise, and29

Transportation/Traffic. All other environmental disciplines were found to have less than30

significant or no impacts and are, therefore, not included below. Additionally, Applicant-31

proposed measures (APMs) would be implemented, as feasible, to further minimize less32

than significant impacts for the following environmental disciplines: Air Quality,33

Biological Resources, Greenhouse Gas Emissions, and Utilities and Service Systems.34



These APMs are included here for the purpose of tracking. The table lists the following1

information by column:2

• Potential Impact (impact number, title, and impact class);3

• Mitigation [or Applicant-Proposed] Measure (full text of the measure);4

• Location (where impact occurs and mitigation measure should be applied);5

• Monitoring/Reporting Action (action to be taken by monitor or Lead Agency);6

• Timing (before, during, or after construction; during operation, etc.);7

• Responsible Party; and8

• Effectiveness Criteria (how the agency can know if the measure is effective).9



Table 5-1. Mitigation Monitoring Program

PotentialImpact

Mitigation Measure (MM) LocationMonitoring/Reporting

ActionTiming

ResponsibleParty

EffectivenessCriteria

AestheticsScenic VistaView Impact

MM AES-1: Project Scheduling. Onshore Projectdecommissioning shall be conducted outside ofthe peak public beach/ocean-use periods(summer [May 31 to September 5] and weekends)in order to minimize the number of viewersaffected by the Project to the extent feasible.Exceptions allowing weekend work may occur incertain limited cases such as when work requiresan extreme low tide that only occurs on aweekend.

Onshore Review Projectschedule andobserve Projectimplementationfor consistencywith approvedschedule

ThroughoutProject

Applicantand CSLC

Peak beach-useperiods avoided

Night-Lighting

MM AES-2: Night-Lighting SpillageMinimization. Night-lighting required for Projectdecommissioning activities shall be shielded anddirected to the immediate work area to avoid lightspillage onto private property.

Onshore/Offshore

Observenighttimelightingpositioning forcompliance

Duringnighttimework

Applicantand CSLC

Off-site lightspillageminimized

Air QualityAir EmissionsandGreenhouseGases

APM AIR-1: Air Emissions ComplianceProgram. The Project will incorporate an AirEmissions Compliance Program to ensure thatProject emissions are in conformance with theapproved Project. This Program will providedetailed information regarding the internalcombustion engines used, the duration of use, thefuel consumed, and the calculated emissions.

Onshore/Offshore

Review Projectelements forcompliance withProgram

ThroughoutProject

Applicantand CSLC

Program criteriamet (e.g., limitson duration ofengine use,engine typesused, fuelconsumed)

APM AIR-2: Low-Emission Engines – Offshore.Use marine vessels and offshore equipment withlow emissions engines, certified to meet FederalTier III requirements, if available.

Offshore Documentengines used orattempts toobtain Tier 3engines

ThroughoutoffshoreProjectoperations

Applicantand CSLC

Reduce Projectemissions fromoffshore andonshore engines

APM AIR-3: Low-Emission Engines – Onshore.Use heavy equipment onshore with the bestavailable low emissions engines (Tier III or IV), ifavailable.

Onshore

APM AIR-4: Mobilize from Nearest Port.Mobilize marine vessels and equipment from the

Offshore Document baseport location

Throughoutoffshore

Applicantand CSLC

Minimizeemissions




PotentialImpact


ActionTiming

ResponsibleParty


nearest port supporting these vessels. Projectoperations

associated withtrips from baseport to Projectsite

APM AIR-5: Dispose Materials at Nearest Port.Dispose of recovered anchors and associatedmaterials at the nearest port accepting thesematerials.

Offshore Documentrecoveredoffshorematerialdisposal sites

ThroughoutoffshoreProjectoperations

Applicantand CSLC

Minimizeemissionsassociated withtrips from theProject site tomaterialsdisposal site

APM AIR-6: Low-Sulfur Fuel. All diesel-poweredequipment used during the Project shall use dieselfuel with a sulfur content of 15 parts per million(ppm) or less.

Onshore/Offshore

Document fuelsource and typeused

ThroughoutProjectoperations

Applicantand CSLC

Minimizeemissionsassociated withfuel type used

Biological ResourcesGrunionSpawning

APM BIO-1a: Grunion Avoidance. Intertidalactivities will be scheduled outside of the grunionspawning season, which is generally three or fournights after the highest tide associated with eachfull or new moon and then only for a 1- to 3-hourperiod each night following high tide from lateFebruary or early March to August or earlySeptember.

Beach/Surf Zone

Retain finalProjectschedule andconduct sitevisits

FebruarythroughSeptember

Applicantand CSLC

Projectoperations onbeach avoidedduring grunionspawning

APM BIO-1b: Grunion Surveys and Avoidance.If scheduling is not possible under APM BIO-1a,intertidal grunion surveys will be conducted duringgrunion spawning tidal periods to document thatgrunion have not used the site. Intertidal activitiesshall not occur if grunion spawning is observed inthe Project area.

Beach/Surf Zone

Retain copy ofgrunion surveys

FebruarythroughSeptember

Applicantand CSLC

Projectoperations onbeach avoidedduring grunionspawning

Spread ofNon-NativeAquaticSpecies

APM BIO-2: Prevent Introduction of Non-NativeAquatic Species (NAS). All Project vessels shall:(1) originate from Oceanside Harbor, the Ports ofLong Beach/Los Angeles, or San Diego Bay; (2) be

Hullcleaning/biofoulingremoval to

RetainBiofoulingRemoval andHull Husbandry

BiofoulingremovalPrior toProject

Applicantand CSLC

Introduction ofNAS avoidedVessel operatorsmade aware of




PotentialImpact


ActionTiming

ResponsibleParty


(NAS) continuously based out of Oceanside Harbor, thePorts of Long Beach/Los Angeles, or San DiegoBay since last dry docking; or (3) have underwatersurfaces cleaned before entering southernCalifornia at vessel origination point andimmediately prior to transiting to the Project site.Additionally, and regardless of vessel size, ballastwater for all Project vessels must be managedconsistent with California State Lands Commission(CSLC) ballast management regulations, andBiofouling Removal and Hull Husbandry ReportingForms shall be submitted to CSLC staff. Projectvessels shall also be available for inspection byCSLC staff for compliance. Further, as part of theProject kickoff meeting, a qualified marine biologist,approved by CSLC staff, shall provide informationto all Project personnel about the spread of NAS inCalifornia waters and the programs (CSLC BallastWater Management Program and BiofoulingRemoval and Hull Husbandry Reporting) that willbe implemented to minimize this hazard.

beconductedat vesseloriginationsite

ROVsurveyconductedat Projectsite

At Projectkickoffmeetingsite

ReportingForms

Conduct ROVsurvey forcompliance withbiofoulingremoval

Retain Projectkickoff meetingsign-in sheet

vesselstransiting toProject site

SubmitBiofoulingRemovaland HullHusbandryReportingForms priorto Projectoperations

ROV surveyconductedprior toProjectoperations

DuringProjectkickoffmeeting

NAS regulations

MarineVessel andWildlifeInteraction

MM BIO-1: Marine Wildlife Contingency Plan(MWCP). A MWCP shall be prepared for review andapproval by California State Lands Commissionstaff prior to the commencement ofdecommissioning activities. The MWCP shallinclude, but not be limited to, the following elements:

• Description of the pre-decommissioningtraining seminar that will be provided toeducate Project personnel on identifyingmarine wildlife in the Project area and toprovide an overview of the wildlife mitigationmeasures to be implemented;

Offshore Retain MWCPand marinewildlife monitornotes

During allProjectactivitiesrequiringthe use ofmarinevessels anddynamicpiperamming

Applicantand CSLC

Vessel- andnoise-relatedimpacts tomarine wildlifeavoided




PotentialImpact


ActionTiming

ResponsibleParty


• Qualifications, number, location, and authorityof onboard Marine Wildlife Monitors (MWMs);

• Acoustic safety zone radius that will beenforced by the MWMs during dynamic piperamming activities;

• Distance, speed, and direction transitingvessels will maintain when in proximity to amarine mammal or reptile;

• Discussion of how impacts associated withmarine wildlife entanglement in Project vesselanchor lines will be minimized; and

• Observation recording procedures andreporting requirements in the event of anobserved impact to marine wildlife.

UnderwaterNoise Impacton MarineWildlife

MM BIO-2: Dynamic Pipe Ramming (DPR) Soft-Start and Ramp-Up Procedure. The contractorconducting DPR operations shall begin theprocedure at a reduced level and repeat thesound producing activity, gradually increasing theintensity of the operation prior to initiating normalconstruction levels. The duration of the ramp-upduring Project operations shall be determined by aqualified marine biologist and based upon thefindings of a sound source characterization studyfor DPR. This procedure shall be used any timeDPR operations are initiated.

Surf Zone/Offshore

On-site monitorto verify

During DPR Applicantand CSLC

Soft-start of DPRalerts wildlife ofDPR operationsprior to fullimplementation

MM BIO-3: Dynamic Pipe Ramming (DPR)Sound Source Characterization. Prior to DPRoperations, a marine acoustics specialist shall beretained to conduct underwater noisemeasurements during a trial operation of theequipment at the Project site. In coordination withthe National Oceanic and AtmosphericAdministration (NOAA), the results of theunderwater noise measurements shall be used to

Surf Zone/Offshore

Retain copy ofsoundmeasurementsfrom underwateracousticspecialist andresulting marinewildlife safetyradii

Prior toDPRoperationsfor removalof the surfzonesegment ofthe fuel oilsubmarine

Applicantand CSLC

Sound sourcecharacterizationconducted andmarine wildlifesafety radiidetermined




PotentialImpact


ActionTiming

ResponsibleParty


determine preclusion radii for marine wildlife(mammals and reptiles) safety during DPRoperations based on NOAA’s acoustic thresholdsin place at the time of Project operations forpermanent and temporary threshold shifts. A copyof the sound source characterization shall beprovided to California State Lands Commissionstaff and NOAA within 2 weeks of completion.

pipeline

MM BIO-4: Marine Wildlife Monitoring DuringSound Source Characterization and DynamicPipe Ramming (DPR). Qualified marine wildlifemonitors (MWMs) shall be onsite and presentthroughout sound source characterization andDPR operations. Once the marine wildlifepreclusion radii (i.e., safety zone) have beendetermined, MWMs shall be located such thathe/she has a clear view of the marine waterswithin the safety zone and beyond. The MWMsshall indicate that a designated safety zone isclear of marine wildlife (mammals and reptiles)prior to the start of DPR operations and shall havethe authority to stop DPR operations if marinewildlife are observed at any time within the safetyzone. The initial safety zone to be implementedduring sound source characterization will be 1,000feet. The initial safety zone will be revised toreflect new thresholds for permanent andtemporary threshold shifts (PTS and TTS) shouldthey be finalized by the National Oceanic andAtmospheric Administration prior to Projectoperations. The safety zone to be implementedduring DPR will be modified as necessary basedon the sound source characterization results andwill reflect the PTS and TTS thresholds in place atthe time of Project operations.

Surf Zone/Offshore

Retain copy ofMWM report

Prior toDPRoperationsfor removalof the surfzonesegment ofthe fuel oilsubmarinepipeline

Applicant,CSLC, andNMFS

Marine wildlifeprotected duringsound sourcecharacterizationand DPR




PotentialImpact


ActionTiming

ResponsibleParty


SedimentaryHabitatAlterationfrom Project-generatedDebris

MM BIO-5: Pre- and Post-DecommissioningSeafloor Debris Survey and Debris Removal.The offshore work shall begin and end with seafloordebris surveys. The Applicant’s contractor shallperform a side-scan sonar (with 400% coverage)and bathymetric survey, or multi-beam sonarsurvey, of the underwater worksite prior to thearrival of the contractor’s marine equipment spreadat the worksite. The survey shall encompass theentire underwater worksite bordered by thecontractor’s planned derrick barge anchorages plusan offset of approximately 500 feet. Derrick bargeanchorages shall be positioned to avoid rockoutcroppings and kelp beds. A map shall beproduced by the surveyor and shall serve as thebaseline for the seafloor conditions at theunderwater worksite prior to the start of work.

All surveys employing low-energy geophysicalequipment, including remotely operated vehiclesurveys, must be conducted by an entity holding avalid geophysical survey permit under theCalifornia State Lands Commission’s (CSLC) Low-Energy Offshore Geophysical Permit Program (seewww.slc.ca.gov/Programs/OGPP.html). Therefore,the Applicant shall obtain a valid permit prior toinitiating the surveys.

After decommissioning work is complete, thecontractor shall be required to perform a secondside-scan sonar (with 400% coverage) andbathymetric survey in the same underwater workarea. The surveyors shall again produce a map ofthe survey area and use it to identify any items ofseafloor debris introduced into the underwaterworksite by decommissioning operations. The

Offshore Obtain OffshoreGeophysicalSurvey Permitfrom the CSLC

Retain copies ofsurvey data

Pre-decommiss-ioningsurvey nomore than90 daysprior to priorto marineactivities

Post-decommiss-ioningsurveys anddebrisremoval nomore than90 daysaftercompletionof Projectactivities inthe marineenviron-ment

Applicantand CSLC

Surveysconductedprovidingevidence that anyProject debris onthe ocean floorhas beenrecovered




PotentialImpact


ActionTiming

ResponsibleParty


contractor shall remove all items of debris, if any,related to the offshore tanker berth facilities andoperations and the decommissioning work.The Applicant shall provide: (1) the pre-decommissioning survey map to CSLC staff andpermitting agencies for approval at least 60 daysprior to Project implementation; and (2) the post-decommissioning map to CSLC staff within 30 daysof survey completion for agency sign-off.

Impact ofAnchorPlacementon RockyHabitat andKelp Beds

MM BIO-6: Final Marine Safety and AnchoringPlan (MSAP). A final MSAP shall be developedfollowing the analysis of seafloor habitat andbathymetric data to be collected during the pre-decommissioning survey. Additionally, a diver-biologist survey shall be conducted to ensure thatall pre-determined vessel anchor locations arepositioned in sedimentary habitats and avoidrocky substrate and kelp by at least 50 feet. Thefinal plan shall be submitted to California StateLands Commission staff for review at least 2weeks prior to the commencement of Projectactivities.

Offshore Retain copy ofthe final MSAPand notes fromdiver biologistregardinganchorplacement

At least 30days priorto initiationofdecommiss-ioningrequiringanchoring

Applicantand CSLC

Rocky substrateand kelp bedsare avoidedduring anchorplacement

AccidentalDischarge ofPetroleumProducts intothe MarineEnvironment

MM BIO-7: Oil Spill Response Plan (OSRP). AnOSRP has been prepared for the Project. EachProject vessel shall have a copy of the plan andshall maintain the required onboard andsubcontracted spill response equipment.Additional shore-based response equipment shallbe onsite, which can be used for first-responsecontainment and collection of petroleum thatreaches the shoreline. If needed, subcontractedshoreline recovery personnel and additionalequipment, as identified in the OSRP shall bedeployed to the site to assist in the recovery anddisposal of spilled petroleum.

Offshore Retain copy ofOSRP and anyincident reports

Periodicinspection ofvessels andonshore oil spillresponseequipment

Duringdecommiss-ioningactivities inthe marineenviron-ment

Applicantand CSLC

Discharge ofpetroleumproducts into themarineenvironment areavoided or, if oneoccurs, it isappropriatelyhandled




PotentialImpact


ActionTiming

ResponsibleParty


AccidentalRelease ofPipelineWaterPreservativeinto MarineEnvironment

MM BIO-8: Flush Fuel Oil Submarine Pipeline.Prior to opening the fuel oil submarine pipeline tothe ocean during the decommissioning process,this pipeline shall be flushed from its offshoretermination to its onshore termination at the beachvalve pit with seawater to displace the potablewater and preservative. The potable water andpreservative mixture shall be recovered at thebeach valve pit and transported off-site fortreatment and disposal.

Onshore/Offshore

Site inspectionto ensurepipeline wasflushed

Retain copy ofcommunicationindicating thatdisplaced waterwas disposed atan appropriatefacility

Applicantand CSLC

Release of thepipeline waterpreservative inthe marineenvironmentavoided

Cultural and Paleontological ResourcesDisturbanceof Archaeo-logicalResources

MM CUL-1: Cultural Resource Training. A pre-construction meeting, inclusive of agencypersonnel, shall be organized to educate onsiteconstruction personnel as to the sensitivity ofarchaeological and tribal cultural resources in thearea. If agency personnel cannot attend, themeeting shall be held and documentation of themeeting shall be submitted to those agencies. TheApplicant’s personnel shall instruct all constructionand Project personnel to avoid removing culturalmaterials from the Project site. Evidence ofcompliance with this mitigation measure shall bedocumented, and provided to California StateLands Commission staff, prior to onshore work.

Documenttraining

Prior toonshoreexcavations

Applicantand CSLC

Educate workerson the potentialfor culturalresources

MM CUL-2: Archaeological and Tribal CulturalResource Monitoring. All construction will beconfined to previously disturbed areas within thebeach valve pit if feasible; however, to ensure nopreviously unknown archaeological or tribal culturalresources are unintentionally damaged, allexcavation shall be monitored by a professionalarchaeologist and a Native Americanrepresentative, who shall have the authority to

Onshore ExtendedPhase ISubsurfaceArchaeologicalInvestigation &retain studydocumentation/documentationof any additional

Prior toand/orduringonshoregrounddisturbance

Applicantand CSLC

Confine Projectdisturbance areato previouslydisturbed areas

Anyarchaeologicalresources withinthe Project




PotentialImpact


ActionTiming

ResponsibleParty


temporarily halt or redirect Project construction inthe event that potentially significant culturalresources are exposed.

mitigationcompliance

Alternately,retain monitors’records and anysubsequentmitigationactivities (e.g.,artifactcollection/curation)

disturbance areaare identified andappropriatelymanaged

MM CUL-3: Redirect Work if PreviouslyUnknown Archaeological or Tribal CulturalResources are Discovered. In the event thatpotentially significant archaeological or tribalcultural resources are discovered any time duringconstruction, all earth disturbing work within thevicinity of the discovery shall be temporarilysuspended or redirected until a professionalarchaeologist and a representative from theculturally affiliated California Native Americantribe(s) (tribal representative) as determined by theNative American Heritage Commission haveevaluated the nature and significance of thediscovery. In the event that a potentially significantarchaeological or tribal cultural resource isdiscovered, Cabrillo Power I LLC, the CaliforniaState Lands Commission (CSLC), and any local,State or Federal agency with approval or permittingauthority over the Project that has requested/required such notification shall be notified.

Impacts to previously unknown significantarchaeological or tribal cultural resources shall beavoided through preservation in place if feasible.

Onshore/Offshore

Inform Projectcontractors ofarchaeologicalresourcenotificationprocedure

Document anyreported findsincludingretention of anyassociatedarchaeologicalreports

ThroughoutgrounddisturbingProjectoperations

Applicantand CSLC

Anyunanticipatedcultural resourcefinds are avoideduntil evaluatedand mitigated




PotentialImpact


ActionTiming

ResponsibleParty


Damaging effects to tribal cultural resources will beavoided or minimized following the measuresidentified in Public Resources Code section21084.3, subdivision (b), if feasible, unless othermeasures are mutually agreed to by the leadarchaeologist and tribal representative that wouldbe as or more effective.

If the lead archaeologist and tribal representative(s)mutually agree that damaging effects to tribalcultural resources will be avoided or minimized,then work in the area may resume. If the leadarchaeologist and tribal representative(s) do notagree, the CSLC’s tribal liaison will attempt toresolve the issue. If the tribal liaison cannot resolvethe issue, the tribal liaison will submit the matter tothe CSLC’s Executive Officer for resolution. ANative American representative shall monitor anymitigation work associated with Native Americancultural material.

Disturbanceof Paleon-tologicalResources

MM CUL-4: Paleontological ResourceEvaluation and Mitigation Plan. A qualifiedpaleontologist shall be retained to evaluate theonshore activities and develop a PaleontologicalResource Evaluation and Mitigation Plan if Projectactivities extend into previously undisturbedsedimentary formations. The mitigation plan shallinclude construction monitoring and collection andarchiving of any paleontological finds.

Onshore Retainpaleontologistand resultingreport

ThroughoutonshoregrounddisturbingProjectoperations

Applicantand CSLC

Paleontologicalresources areavoided orappropriatelymitigated (e.g.,collected andcurated)

Disturbanceof HumanRemains

MM CUL-5: Proper Disposition of HumanRemains. If human remains are unearthed, StateHealth and Safety Code section 7050.5 requiresthat no further disturbance shall occur until theCounty Coroner has made the necessary findingsas to origin and disposition pursuant to PublicResources Code section 5097.98. If the remains

Onshore/Offshore

Retain record ofany finds thatare investigatedas possiblehuman remains

ThroughoutProjectimplemen-tation

Applicantand CSLC

Any humanremainsencountered onthe Project siteare appropriatelymanaged




PotentialImpact


ActionTiming

ResponsibleParty


are determined to be of Native American descent,the coroner has 24 hours to notify the NativeAmerican Heritage Commission. Cabrillo Power ILLC and California State Lands Commission staffshall be notified immediately of the discovery.

Hazards and Hazardous MaterialsAsbestos MM HAZ-1: Use Certified Asbestos Abatement

Contractor. Pipeline removal shall be conductedin accordance with all regulations pertaining toasbestos utilizing a certified asbestos abatementcontractor to perform any such work.

Onshore/Offshore

Confirm certifiedasbestoscontractor

Conduct siteinspections toensure certifiedpersonnel areconducting work

Duringpipelineremovalactivitiesimpactingasbestos-containingmaterial

Applicantand CSLC

Asbestos-containingmaterialappropriatelyhandled to avoidhealth impacts

Lead-BasedPaint (LBP)

MM HAZ-2: Licensed/Certified Lead-BasedPaint (LBP) Contractor. A California licensedcontractor certified by the California Department ofPublic Health shall be contracted to accomplishLBP abatement prior to the commencement ofonshore demolition and to ensure proper disposalof paint flakes (which must be handled as ahazardous waste), abated pipes, and equipment.

Onshore Confirm certifiedLBP contractor

Conduct siteinspections toensure certifiedpersonnelconducting work

Beforedecom-missioningoperationsimpactingLBP

Applicantand CSLC

LBP healthhazardappropriatelyabated

Impacted Soil MM HAZ-3a: Extended Phase I EnvironmentalSite Assessment (ESA). An extended Phase IESA review, as well as the assessment of soilsaround and in the beach valve pit, shall beconducted to address potential soil contaminationissues at the Project site prior to thecommencement of decommissioning activities. Ifcontamination is identified, the appropriatemeasures to address the hazard shall be added tothe Contractor Work Plan. This may includeexcavation and removal of contaminated soil to alegal disposal site, or onsite treatment ofcontaminated soil. A copy of the Phase 1 ESA

Onshore RetainExtendedPhase I ESAReport

Conduct sitevisits to ensureany requiredremedialactivities areconducted

Before startof onshoredecom-missioningactivities

Applicantand CSLC

County of SanDiegoDepartment ofEnvironmentalHealth,HazardousMaterialsDivision

Any on-sitecontaminated soilis appropriatelyaddressed toensure that nohuman orenvironmentalhealth hazardsresult fromProject activities




PotentialImpact


ActionTiming

ResponsibleParty


shall be provided to California State LandsCommission staff within 2 weeks of completion.Alternative to MM HAZ-3a:MM HAZ-3b: Use Personnel Trained to Workwith Hazardous Substances. All work requiringremoval of facilities shall be conducted bypersonnel trained to work with hazardoussubstances and any suspicious soils (stained orwith an unusual odor) or groundwater (showing asheen or with an unusual odor), shall be testedand treated in accordance with all applicable laws.

Onshore Retain list ofProjectpersonnel andcertifications forworking withhazardoussubstances

Record allactions relatedto suspicioussoil or waterencountered atthe Project site

Conduct sitevisits to ensurecertifiedpersonnel areworking on-site

DuringonshoreProjectoperations

Applicantand CSLC

County of SanDiegoDepartment ofEnvironmentalHealth,HazardousMaterialsDivision


MM HAZ-4: Disposal of Total PetroleumHydrocarbon (TPH)-Containing Soil. Soil in thebottom of the beach valve pit known to have levelsof TPH shall be disposed of as a petroleum-containing special waste.

Onshore –beachvalve pit/verticalvault

Site inspectionto ensureimpacted soil isbeing removedfrom site (asnecessary)

Retain copy offacility-signedwaste manifestindicating soilwas accepted atan appropriatewaste disposalfacility

Beforeand/orduringonshoreProjectoperations

Applicantand CSLC





PotentialImpact


ActionTiming

ResponsibleParty


AccidentalRelease ofHazardousMaterial

MM HAZ-5: Onshore Hazardous MaterialsManagement and Contingency Plan Measures.The onshore contractor shall develop andimplement hazardous materials management andcontingency plan measures for onshore operations.The measures shall be provided to California StateLands Commission staff as part of a StormwaterPollution Prevention Plan or a separate plan priorto Project implementation. Measures shall include,but not be limited to, identification of: appropriatefueling and maintenance areas for equipment; bestmanagement practices for fueling and operation ofequipment (e.g., daily inspection of equipment); aspill response, and spill response supplies to bemaintained onsite.

Onshore Retain copy ofthe Plan

Conduct sitevisits to ensurePlan is beingimplemented

Prior toonshoreProjectoperations

Applicantand CSLC

Accidentalreleases ofhazardousmaterial isavoided orresponded toappropriately

Implement MM BIO-7: Oil Spill Response Plan (OSRP) (see above)Hydrology and Water QualityViolation ofWater QualityStandards

Implement MM BIO-6: Final Marine Safety and Anchoring Plan (MSAP) (see above)Implement MM BIO-7: Oil Spill Response Plan (OSRP) (see above)Implement MM BIO-8: Flush Fuel Oil Submarine Pipeline (see above)Implement MM HAZ-3a: Extended Phase I Environmental Site Assessment (ESA) (see above)Implement MM HAZ-3b: Use Personnel Trained to Work with Hazardous Substances (see above)Implement MM HAZ-4: Disposal of Total Petroleum Hydrocarbon (TPH)-Containing Soil (see above)Implement MM HAZ-5: Onshore Hazardous Materials Management and Contingency Plan Measures (see above)

NoiseShort-termNoise in Air

MM NOI-1: Advanced Noticing. Advanced noticesshall be posted on the beach and/or alongCarlsbad Boulevard within a 1,500-foot radiusaround the fuel oil submarine pipeline to notify thepublic about the location and timing ofdecommissioning operations. The notices shall be:(1) posted at least 1 week prior to anydecommissioning operations on the beach orocean, and shall include a map of the Project site,contact name and phone number; (2) maintained

Onshore Retain copy ofnotice

Photo documentnotices in place

Conduct siteinspections toensure noticesare maintained

At least oneweek priorto andduringbeach andoffshoreProjectoperations

Applicantand CSLC

Advancednotices posted




PotentialImpact


ActionTiming

ResponsibleParty


until all Project operations impacting the beach andmarine environment have been completed; and (3)removed within 1 week of completing theoperations described in the notice.MM NOI-2: Shielding of Stationary Equipment.Onshore stationary noise sources shall beshielded, where feasible, using enclosures orbarriers constructed of temporary prefabricatedsound blankets or sound walls.

Onshore Conduct siteinspections toverify use ofportable shields


Applicantand CSLC

Shields in placeto reduce noisetransmission

Short-termUnderwaterNoise fromDPR

MM NOI-3: Advanced Notice to Swimmers andDivers. At least 1 week prior to and duringdynamic pipe ramming (DPR) operations, writtennotice to swimmers and divers shall be posted atarea dive shops and along the beach within 1,500feet of the DPR site indicating that swimming anddiving in the Project area may be harmful due tounderwater noise impacts during DPR operations.The notice shall state that the Project area shouldbe avoided during the DPR operation period,which shall be identified on the notice along with amap showing the Project area and suggested areaof preclusion for divers and swimmers. The noticewill also provide a contact name and phonenumber.

Onshore Retain copy ofnotice

Conduct siteinspections toensure noticesare in place

At least oneweek priorto andduring DPRoperations

Applicantand CSLC

Advancednotices posted

MM NOI-4: Observation and Removal of Diversand Swimmers from Waters in Project Area.Marine wildlife monitors (MWMs) onboard Projectvessels shall be instructed to observe for non-Project-related divers or swimmers in or about toenter the safety zone established for marinewildlife; however, the safety zone for humandivers and swimmers may be modified based onthe sound source characterization to beconducted for dynamic pipe ramming. If suchpersons are observed by MWMs or vessel crews,

Offshore Retain copy ofMWM report

Immediatelyprior to andduring DPRoperations,includingsoundsourcecharacter-ization

Applicantand CSLC

Project areaavoided byswimmers anddivers duringDPR operations




PotentialImpact


ActionTiming

ResponsibleParty


a support vessel shall be mobilized to inform themthat their presence is not allowed in the Projectsafety zone, and the vessel crew shall arrange forthem to be escorted from the active survey area.

Transportation/TrafficTrafficCirculation

MM TRA-1: Trucks Avoid Peak Hours.Construction truck traffic affecting State highwaysshall be confined to hours outside of the peak AMand PM commute periods.

Onshore Conduct siteinspections


Applicantand CSLC

MM TRA-2: Carpooling. The contractor shallimplement a worker carpool program to minimizethe number of vehicular trips required to transportworkers to and from the Project site. This measureshall be identified as a requirement in thecontractor bid package.

Onshore Conduct siteinspections.

Create/maintainlist of workerswho carpool


Applicantand CSLC

TrafficHazards

MM TRA-3: Construction Safety and TrafficManagement/Control (CSTMC) Plan. A CSTMCPlan shall be developed for review by the City ofCarlsbad and implemented. The Plan shallinclude, but not necessarily be limited to: (1) trafficcontrol strategies; (2) traffic control devices to beused; (3) public awareness strategies; (4) motoristinformation methods; (5) alternate pedestrian andbicycle access routing; (6) work zone safetymanagement strategies; and (7) contingency andincident plans.

Onshore Retain copy ofPlan

Conduct siteinspections


Applicant,CSLC, and Cityof Carlsbad

Constructiontraffic safetymeasuresimplemented

Infrastructure MM TRA-4: Protect InfrastructureImprovements. The Applicant shall ensure thatthe onshore contractor includes properprecautions to protect all existing pavement,curbs, gutters, and drainage structures fromunintentional damage during Project construction.Any portion damaged as a result of Projectconstruction shall be repaired or replaced inaccordance with current City of Carlsbad Standard

Onshore List protectionmeasures andphoto documentroads before/after Projectoperations

Obtain writtenconfirmationthat any needed

Prior to,during and,ifnecessary,after Projectoperations

Applicant,CSLC, and Cityof Carlsbad

Infrastructureprotectionmeasuresimplemented andany necessaryrepairs made




PotentialImpact


ActionTiming

ResponsibleParty


Construction Details. repairs weremade to City’ssatisfaction.

OffshoreMarineTraffic

MM TRA-5: Local Notice to Mariners. Alloffshore operations shall be described in a LocalNotice to Mariners to be submitted to the U.S.Coast Guard at least 15 days prior todecommissioning activities.

Offshore Retain copy ofnotice

Prior tooffshoreProjectoperations

Applicant,CSLC, andU.S. CoastGuard

Notice posted toinform marinersof Project trafficand operations

Utilities and Service SystemsSolid WasteDisposalCapacity

APM UTI-1: Reuse and Recycle Debris. Thedecommissioning contractor shall dispose ofrecovered materials (e.g., anchors, chains, riprap,piping) that can be reused and recycled at anappropriate facility if feasible.

Onshore/Offshore

Requirecontractor toidentify finaldisposition ofProject debris

After eachProjectdecommiss-ioningphase

Applicantand CSLC

Documentedattempt to reuseor recycle Projectdebris



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