SMUD Transmission Line Steel Pole Recoating Project
Summary
SCH Number
2024090743
Public Agency
Sacramento Municipal Utility District
Document Title
SMUD Transmission Line Steel Pole Recoating Project
Document Type
NOE - Notice of Exemption
Received
Posted
9/19/2024
Document Description
SMUD is proposing to recoat fourteen transmission line painted steel poles with nominal operational line voltages of 115 and 230 kilovolt (kV) phase to phase, seven (7) 115kV poles in 2024 and seven (7) 230kV poles in 2025. The heights of the poles are between 95 and 125 feet. The poles were originally installed in the late 1970s and the paint to be removed contains lead/zinc. The proposed project is not subject to Article 19, Section 15330 for "minor actions to prevent, minimize, stabilize, mitigate, or eliminate the release or threat of release of hazardous waste or substance," because the proposed action is not undertaken to address the potential release of lead paint, but rather to perform a traditional form of maintenance and prevent further corrosion of the existing poles. The effects of the paint removal and pole repainting on the environment have been evaluated indicating the project will comply with air quality and worker exposure regulations and will have no significant adverse effects on any other resources.
One transmission pole requires all existing coating of this pole to be fully removed. The entire pole shaft and the cross arms bracket mounting area will be enclosed with scaffolding, and all existing coating will be removed by blasting. For the initial refinishing of this pole, it will be necessary to remove all paint layers down to exposed steel to eliminate rust and ensure appropriate adhesion and life of the paint re-coating. All removed material will be captured with high efficiency particulate air (HEPA) filter-equipped vacuum attachments. The material will be tested and if found to be hazardous, disposed of in a Class I controlled landfill. The remaining poles will be recoated with brushes and/or rollers. All coating and overcoat applications shall be done according to the paint manufacturer's recommendations.
All work performed for the recoating will be done with the transmission lines de-energized The pole locations are located directly adjacent to the RT Gold Line East Sacramento corridor. The trains will remain in operation with the use of flaggers who will work cooperatively with the pole maintenance crews. Maintenance will occur between the hours of 7 am and 7 pm Monday through Friday. The fourteen poles are owned by SMUD and seven are located within the Sac RT right of way from 46th to 35th Streets, Sacramento, CA. The seven poles proposed to be recoated in 2025 are located south of Elder Creek Road and east of Power Line Road to just east of Florin Perkins Road, Sacramento, CA. The seven poles to be recoated in 2024 will occur in October over approximately 4 weeks, and the poles to be recoated in 2025 are anticipated to be of similar schedule and duration.
Cal/OSHA’s Lead in Construction Standards (Title 8 CCR 1532.1) sets an action level (AL) of 30ug/m3 and an 8-hour permissible exposure limit (PEL) of 50ug/m3 for this type of activity and requires implementation of protective measures until air monitoring indicates that exposure is at or below the PEL. The painting contractors will comply with all environmental regulatory requirements by capturing lead dust generated during paint removal with HEPA-filtered vacuum attachments and employing Best Management Practices (BMPs) to control releases of lead into the surrounding environment. These measures consist of laying a plastic tarp at the base of each tower to collect paint scrapings and collecting and labeling the worker clothing sent to the laundry. All lead contaminated wastes will be collected, sealed, and transferred to an appropriate Treatment Storage and/or Disposal Facility (TSDF). The plastic sheeting will be placed around the base of the poles at a distance of 20 feet out from the base of the poles. Additional sheeting will be used where there is the possibility of material entering storm drains or being transmitted onto adjacent properties.
Contact Information
Name
Ammon Rice
Agency Name
Sacramento Municipal Utility District
Job Title
Supervisor, Environmental Services
Contact Types
Lead/Public Agency / Project Applicant / Parties Undertaking Project
Phone
Email
Location
Cities
Sacramento
Counties
Sacramento
Regions
Citywide
Other Information
The two proposed project locations are in the vicinity of 35th Street and 46th Street adjacent to the Sacramento Rapid Transit (RT), Sacramento, CA and south of Elder Creek Road, from east of Power Line Road to just east of Florin Perkins Road, Sacramento, CA. Seven poles are located within the Sac RT right of way from 46th to 35th Streets, Sacramento, CA. The other seven are located south of Elder Creek Road and east of Power Line Road to just east of Florin Perkins Road, Sacramento, CA.
Notice of Exemption
Exempt Status
Categorical Exemption
Type, Section or Code
CEQA Guidelines §15301(b), Existing Faciliites
Reasons for Exemption
SMUD has determined that the SMUD Transmission Line Steel Pole Recoating Project is exempt under CEQA Guidelines §15301, Class 1 Existing Facilities. CEQA Guidelines §15301, Class 1 Existing Facilities exemption applies to the "operation, repair, maintenance, permitting, leasing, licensing, or minor alteration of existing public or private structures, facilities, mechanical equipment, or topographical features, involving negligible or no expansion of existing or former use. Examples of this exemption include but are not limited to: (b) Existing facilities of both investor and publicly owned utilities used to provide electric power, natural gas, sewerage, or other public utility services. The SMUD Transmission Line Steel Pole Recoating Project involves maintenance of existing facilities, and therefore is considered exempt in accordance with CEQA Guidelines §15301(b).
The Secretary of Resources has identified general categories of projects that do not have a significant effect on the environment, including maintenance projects. Section 15300.2 of the Guidelines, however, lists the following exceptions to categorical exemption status: projects that will have significant cumulative impacts from successive activity of the same type in the same place over time, projects with significant effects due to unusual circumstances, projects that will cause damage to scenic resources within a state scenic highway, projects located on a site included on any list complied pursuant to Section 65962.5 of the Government Code, and projects that will cause a substantial adverse change in the significance of a historical resource. The poles were first painted and installed in the late 70’s, and the paint to be removed contains lead but is not lead based with a very low percentage, thus it is not categorized as lead based paint. The proposed project is not subject to Article 19, Section 15330 for "minor actions to prevent, minimize, stabilize, mitigate, or eliminate the release or threat of release of hazardous waste or substance," because the proposed action is not undertaken to address the potential release of lead paint, but rather to perform a traditional form of maintenance and prevent further corrosion of the existing poles. The effects of the pole recoating on the environment have been evaluated indicating the project will comply with air quality and worker exposure regulations and will have no significant adverse effects on any other resources.
County Clerk
Sacramento
Attachments
Notice of Exemption
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