Long Beach City Council
January 4, 2022

The ground -borne energy of vibration has the potential to cause structural damage and annoyance.

Vibration can be felt outdoors, but the perceived intensity of vibration effects is much greater indoors due to the shaking of structures. Several land uses are considered sensitive to vibrations, and include hospitals, libraries, residential areas, schools, and churches. Additionally, land uses such as research and manufacturing where vibration-sensitive equipment is used (e.g., electron microscopes and high - resolution lithographic equipment), cultural and his toric resources, and concert halls are sensitive to vibration.

There are several different methods that are used to quantify vibration. The peak particle velocity (PPV) is defined as the maximum instantaneous peak of the vibration signal and is most frequently used to describe vibration impacts to buildings. The PPV velocity is normally described in inches per second (in/sec). California Department of Transportation (Caltrans) guidance states that for continuous/ frequent vibration sources the vibration damage potential threshold is 0.1 in/sec PPV for fragile buildings, 0.25 in/sec PPV for historic and some old buildings, 0.3 in/sec PPV for older residential structures, and 0.5 in/sec for new residential structures and modern industrial/commercial buildings (Caltrans, 2013b – Table 19). Human response/annoyance potential is barely perceptible at 0.01 in/sec PPV, distinctly perceptible at 0.04 in/sec PPV, strongly perceptible at 0.10 in/sec PPV, and severe at 0.4 in/sec PPV (Caltrans, 2013b – Table 20).
a. Would the project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? L
ESS THAN SIGNIFICANT IMPACT. Long Beach Municipal Code (LBMC) Title 8 (Health and Safety), Section 8.80 (Noise) prescribes exterior noise level limits by land use district, as shown in Table 4.13-2. The noise limits specified in Table 4.13-2 apply to noise sources that persist for a cumulative total of more than 30 minutes in any hour. The noise level limit is to be applied at the property line of the receiving property. The proposed Project would be located in Land Use District Four; the sensitive receptors are located in Land Use District One. In the event that the noise source contains a steady audible tone such as a whine, screech, or hum, or is a repetitive noise such as hammering or riveting, Chapter 8.80.160 of the LBMC requires that the exterior noise limits presented in Table 4.13 -2 be reduced (made more stringent) by 5 dB. This 5 -dB penalty for tonal/impulsive noise would apply to many construction activities, such as vibratory hammering.

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Table 4.13-2. Long Beach Municipal Code Exterior Noise Limits Receiving Land Use District Time Period
Noise Level
(dBA) 1, 2
District One – Predominately residential with other land use types also present 10:00 pm – 7:00 am 45 7:00 am – 10:00 pm 50
District Two – Predominately commercial with other land use types also present 10:00 pm – 7:00 am 55 7:00 am – 10:00 pm 60
District Three – Predominately industrial with other land use types also present Anytime 65 District Four – Predominately industrial with other land use types also present Anytime 70 District Five – Airport, freeways, and waterways regulated by other agencies Regulated by other agencies and laws Source: LBMC, 2020b – Chapter 8.80.160 – Exterior noise limits, Table A.

Notes:
1 – Districts Three and Four limits are intended primarily for use at their boundaries rather than for noise control within those districts. 2 – In the event that alleged offensive noise contains a steady audible tone such as a whine, screech, or hum, or is a repetitive noise such as hammering or riveting or contains music or speech conveying informational content, the standard limits set forth shall be reduced by 5 decibels.

Section 8.80.150 (Exterior noise limits – Sound levels by receiving land use district), Part B, further states that the following limits shall not be exceeded:
(1) The noise standard for the various land use districts identified in Table 4.13-2 for a cumulative period of more than 30 minutes in any hour; or
(2) The noise standard plus 5 dB for a cumulative period of more than 15 minutes in any hour; or (3) The noise standard plus 10 dB for a cumulative period of more than 5 minutes in any hour; or (4) The noise standard plus 15 dB for a cumulative period of more than 1 minute in any hour; or (5) The noise standard plus 20 dB or the maximum measured ambient, for any period of time.

In addition, the City’s noise ordinance states that in receptor locations where the existing ambient noise level exceeds the permissible noise limit within any of the first four noise limit categories (above), the LBMC allows the noise exposure standard to be increased in 5 dB increments as necessary to encompass or reflect the ambient noise level. In the event the ambient noise level exceeds the fifth noise limit category, the maximum allowable noise level shall be increased to reflect the maximum ambient noise level.

The LBMC imposes additional regulations on construction activity noise in Section 8.80.202, which limit construction hours to 7:00 am to 7:00 pm weekdays, 9:00 am to 6:00 pm Saturdays, and no work on Sundays except for emergency work or with a Sunday work permit. These additional regulations do not strictly apply to construction activities within the Long Beach Harbor District. Construction of the proposed Project is anticipated to occur Monday through Friday (5-day work weeks) between 7:00 am and 5:00 pm (one 10-hour shift per day).

Noise associated with the proposed Project would occur during construction, which is estimated to last approximately 10 months. Equipment utilized during construction would vary by construction phase as shown in Table 2-2. As shown in Table 4.12-3, typical maximum noise levels (Lmax) generated by the types of construction equipment expected to be utilized range from approximately 7 3 to 101 dBA (e.g. generator, vibratory pile driver) at a distance of 50 feet. These represent actual measured instantaneous maximum noise levels.

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Table 4.13-3. Noise Levels and Use Factors for Construction Equipment

Equipment List
Equivalent Federal Highway
Administration Classification
Acoustical Use
Factor (Percent)
Measured Lmax
(at 50 feet)
Air Compressor Compressor (air) 40 78
Bobcat Backhoe 40 78
Concrete Concrete Mixer Truck 40 79
Crane Crane 16 81
Dump Truck Dump Truck 50 80
Excavator Excavator 40 81
Flat Bed Truck, Dump Truck Flat Bed Truck 40 841
Generator Generator (<25 KVA) 50 73
Skip Loader Front End Loader 40 79
Man-Lift Man Lift 20 75
Pile Driver 2 Mounted Impact Hammer
(hoe ram)
20 90
Pick-up Truck Pick-up Truck 40 75
Source: FWHA, 2006.

Notes:
1 – Due to the limited number of actual data samples, the Spec. 721.560 Lmax at 50 feet is used. 2 – Piles to be vibro piles or rammed aggregate piers (RAPs), which would utilize a down-hole vibrator suspended from a crane or specialty rig, or may involve a hydraulic break hammer and rammer, or mounted impact hammer (hoe ram). The latter is assumed for this analysis.

The construction site is limited by the existing containment wall, tanks, and pipes, such that no more than two to three pieces of equipment would be in operation at any given time. Assuming worst-case operation of a pile driver (mounted impact hammer/hoe ram), crane, and bobcat during the foundation installation phase, maximum noise levels at the nearest sensitive receptor ( residence) would be approximately 40 dBA taking into account distance, location, and intervene structures (see Appendix C) . This residence is located within District 1, where the exterior noise limit during daytime is 50 dBA (see Table 4.13 -2).

However, ambient noise measured at this location ranged from 47 dBA (minimum) to 64 dBA (maximum) with an average of 53 dBA Leq . Per LBMC Chapter 8.80.160, the exterior noise limit threshold would thereby increase to 55 dBA but would then be reduced to 50 dBA due to tonal/impulsive noise associated with pile driving (per LBMC Chapter 8.80.160). As such, construction activities would not result in temporary increases in ambient noise levels in excess of the established LBMC exterior noise limits at the closest residence. Construction noise levels at the elementary schools (Edison and Cesar Chavez) would be lower than the estimated 40 dBA as they are located farther from the Project site. As such, temporary construction noise levels at the schools would also be below the District 1 exterior noise limit threshold of 45 dBA ( This is conservative since the limit would also increase due to higher ambient noise levels).

Therefore, temporary noise levels from construction of the proposed Project would not result in a substantial increase in ambient noise levels in excess of established standards. Impacts would be less than significant.

Operational activities associated with the proposed Project would be similar to existing operations. The new tanks would supplant the terminal's existing crude tanks , such that a dditional existing tanks would then be available for third-party lease, as is currently done for several existing tanks. This would result in additional fuel oil transfers via existing piping , as well as up to a 10 percent in crease in use of the truck loading rack, which equates to approximately three additional trucks entering and leaving the facility per

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day. This limited increase in operational truck traffic would not increase ambient noise levels. No impact would occur.

Mitigation Measures: No mitigation is required.
b. Would the project result in generation of excessive groundborne vibration or groundborne noise levels?
LESS THAN SIGNIFICANT IMPACT. Vibration-sensitive land uses include high-precision manufacturing facilities or research facilities with optical and electron microscopes. None of these occur in the Project area.

Therefore, the significance threshold for “excessive ground-borne vibration ” depends on whether a nuisance, annoyance, or physical damage to any buildings could occur. As there are no sensitive receptors nearby, this assessment will focus on physical damage to any buildings, specifically the control building and nearby tanks on the site.

As described in the Project Description, equipment used during construction would include trucks, cranes, excavator, skip loader, bobcat, pile driver (e.g., vibro pier or RAPs utilize a down-hole vibrator suspended from a crane or mounted impact hammer/hoe ram), manlift, air compressor, and generator. Operation of large trucks, specifically flatbed truck and dump trucks, could result in ground -borne vibration not only due to general operations but also due to travel on cracked/potholes or faulting roadway surfaces (Caltrans, 2013b). Truck traveling over pavement discontinuities often rattle and make noise, which tend to make the event more noticeable when the ground vibration generated may only be barely noticeable.

Vehicles traveling on a smooth roadway are rarely, if ever, the source of perceptible ground vibration (Caltrans, 2013b). Paved roads in the Project area are maintained and relatively smooth, such that ground- borne vibration is not anticipated to occur from the use of haul or material delivery trucks or trucks during operations.

Loaded trucks would result in vibration levels of 0.076 in/sec PPV at 25 feet (FTA, 2018 – Table 7-4). Vibro piers or RAPs would utilize a down-hole vibrator , mounted impact hammer (hoe ram), or equivalent (referred to as “pile driver” in the equipment list) . Operation of a hoe ram would typically result in vibration levels of 0.089 in/sec PPV at 25 feet, or a sonic pile driver would result in vibration levels of 0.17 in/sec PPV at 25 feet (FTA, 2018 – Table 7-4). These vibration levels would attenuate rapidly (i.e., 200 feet or less) from the source and would not be perceptible outside of the construction areas and immediately adjacent to the haul routes, which are not located in proximity to vibration-sensitive land uses. However, with the existing World Oil tanks and control building located immediately adjacent to the construction area, these vibrations may result in building damage. As discussed above, the vibration damage potential threshold is 0.3 in/sec PPV for older residential structures (e.g., control building) and 0.5 in/sec for new residential structures and modern industrial/commercial buildings (e.g., existing tanks) (Caltrans, 2013b – Table 19). Based on the Project’s specified equipment, the vibration levels generated (maximum of 0.17 in/sec PPV at 25 feet) would not result in damage to the control building and nearby tanks. No traditional impact pile driving would occur. Vibrations would not be enough to annoy people outside of the World Oil Terminal. Therefore, impacts from groundborne noise and vibration would be less than significant.

Mitigation Measures: No mitigation is required.

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c. For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? NO IMPACT. The Project site is not located within 2 miles of a public airport or private airstrip. The Long Beach Municipal Airport is located approximately 4 miles to the northeast and the Torrance Municipal Airport is over 14 miles to the northwest . As such, the proposed Project would not expose construction workers to excessive noise levels associated with airport operations. No impact would occur.

Mitigation Measures: No mitigation is required.

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4.14 Population and Housing

POPULATION AND HOUSING
Would the project:

Potentially
Significant
Impact
Less Than
Significant
With Mitigation
Incorporated
Less Than
Significant
Impact No Impact
a. Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
☐ ☐ ☐ ☒
b. Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing
elsewhere?
☐ ☐ ☐ ☒
Significance criteria established by CEQA Guidelines, Appendix G.

Discussion
a. Would the project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
NO IMPACT. A project could in duce population growth in an area, either directly (e.g., by proposing new homes and/or business) or indirectly (e.g., through extension of roads or other infrastructure) . No residential uses, major businesses, offices, or infrastructure expansions would be developed as part of the proposed Project. Therefore, the proposed Project would not induce unplanned direct population growth in the area and no impact would occur.

Mitigation Measures: No mitigation is required.
b. Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
NO IMPACT. The Project site is located within an existing terminal at the POLB. No housing or residential uses occur within the Project site or POLB. Project implementation would not displace any existing housing or residents. Therefore, the proposed Project would not necessitate the construction of replacement housing elsewhere and no impact would occur.

Mitigation Measures: No mitigation is required.

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4.15 Public Services

PUBLIC SERVICES
Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered govern- mental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environ- mental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:

Potentially
Significant
Impact
Less Than
Significant
With Mitigation
Incorporated
Less Than
Significant
Impact No Impact
a. Fire protection? ☐ ☐ ☒ ☐
b. Police protection? ☐ ☐ ☐ ☒
c. Schools? ☐ ☐ ☐ ☒
d. Parks? ☐ ☐ ☐ ☒
e. Other public facilities? ☐ ☐ ☐ ☒
Significance criteria established by CEQA Guidelines, Appendix G.

Discussion
Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facili- ties, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:
a) Fire protection?
L
ESS THAN SIGNIFICANT IMPACT. The Project site is currently served by the Long Beach Fire Department (LBFD) Fire Station No. 20 located at 331 Pier D Avenue in Long Beach, approximately one mile southwest of the Project site (LBFD, 2020).

Construction and operations of the proposed Project would not result in the need for a new fire station or expansion of an existing facility to maintain LBFD’s existing level of service. Construction activities would occur on site, and no street closures are anticipated that would potentially impact servic e ratios, response times, or other fire department performance objectives. Given the presence of flammable materials such as crude oil, diesel, and other petroleum products, the proposed Project would follow existing safety protocols and risk management pr ocedures (e.g., the American Petroleum Institute 653 Standard inspection, daily operator inspections, and annual cathodic protection surveys) and thus would not substantially exacerbate the potential for fire hazards. Further, the terminal would maintain on-site fire lane access during construction and operation. Operations of the terminal would be similar to existing conditions, and thus, would not increase demand for fire services.

As discussed in Section 4.14(a), the proposed Project would not induce population growth in the area or establish any new businesses and, therefore, would not result in a substantial increase in the demand for fire protection services. The proposed Project would have a less than significant impact.

Mitigation Measures: No mitigation is required.

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b) Police Protection?
NO IMPACT. The Long Beach Police Department provides police services to the Project site. The closest police station is the West Patrol Division located at 1835 West Santa Fe Avenue, approximately 1.3 miles north of the site (LBPD, 2020). Other agencies responsible for security at the POLB include the U.S . Coast Guard, Customs and Border Protection, and Homeland Security.

The proposed Project would add two new crude oil storage tanks to i mprove the efficiency of terminal operations by allowing World Oil to lease existing tanks to third -party vendors. As discussed in Section

4.14(a), the Project would not induce population growth and, therefore, would not result in a substantial increase in the demand for police protection services. Construction activities and staging would occur on- site, and no street closures are anticipated that may potentially affect service ratios, response times, or other police department performance objectives. Therefore, the proposed Project would not require new or expanded police facilities that would cause significant environmental impacts. No impacts related to police services would occur.

Mitigation Measures: No mitigation is required.
c) Schools?
N
O IMPACT. The Long Beach Unified School District (LBUSD) serves over 72,000 students from preschool to high school in 85 public schools located in the cities of Long Beach, Lakewood, Signal Hill, and Avalon on Catalina Island (LBUSD, 2020). The proposed Project does not propose any residential development that may introduce new permanent student residents in the LBUSD. Throughout the two construction phases, approximately eight workers per day would be present for approximately 10 months. It is anticipated that this nominal amount of construction workers would come from the local labor force. No increase in staff during operations is anticipated that could potentially i ntroduce new families with school-aged children into the LBUSD. Construction and operation of the proposed Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities. No impacts related to existing or planned schools would occur.

Mitigation Measures: No mitigation is required.
d) Parks?
N
O IMPACT. Construction and operation of the proposed Project would not induce population growth in the area that could cause an increase in the use of existing parks of recreational facilities provided by the Long Beach Department of Parks, Recreation and Marine. As discussed in Section 4.15(c), approximately eight workers per day would be on-site for approximately 10 months during construction. This nominal amount would occur temporarily, and it is anticipated that these workers would come from the local labor force. No increase in permanent staff would occur that would introduce new permanent residents to the City of Long Beach. Therefore, the proposed Project would not require the construction of new or expanded park facilities. No impact related to existing or planned parks in the region would occur.

Mitigation Measures: No mitigation is required.
e) Other Public Facilities?
N
O IMPACT. Construction and operations of the proposed Project would not generate additional permanent residents. Therefore, the proposed Project would not result in substantial adverse physic al impacts associated with the provision of new or physically altered public facilities (e.g., hospitals, libraries,

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and post offices), the construction of which would cause significant environmental impacts. No impact related to other government services or public facilities would occur.

Mitigation Measures: No mitigation is required.

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4.16 Recreation
RECREATION Potentially
Significant
Impact
Less Than
Significant
With Mitigation
Incorporated
Less Than
Significant
Impact No Impact
a. Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? ☐ ☐ ☐ ☒
b. Does the project include recreational facilities or require the construction or expansion of recreational facilities, which might have an adverse physical effect on the environment?
☐ ☐ ☐ ☒
Significance criteria established by CEQA Guidelines, Appendix G.

Discussion
a. Would the project increase the use of existing neighborhood and regional parks or other recrea- tional facilities such that substantial physical deterioration of the facility would occur or be accelerated?
NO IMPACT. The nearest recreational facility to the proposed Project is Cesar E. Chavez Park (401 Golden Avenue), located approximately 2,700 feet east across the Los Angeles River . As discussed in Section

4.14(a), the proposed Project would not substantially induce population growth in the area, and therefore, would not cause an increase in the use of existing parks or recreational facilities. Approximately eight workers would work on-site during construction, which is expected to occur over a 10-month period. This minimal quantity of workers would likely come from the local labor force and no additional employees would be hired for Project operations that could potentially introduce permanent residents to the City of Long Beach. Therefore, construction and operation of the proposed Project would not increase the use of existing neighborhood and regional parks or other recreational facilities. No impact on existing parks or recreational facilities would occur.

Mitigation Measures: No mitigation is required.
b. Does the project include recreational facilities or require the construction or expansion of recrea- tional facilities, which might have an adverse physical effect on the environment? N
O IMPACT. The proposed Project would not include construction of recreational fa cilities. Furthermore, the proposed Project is not expected to induce substantial population growth that would result in increased demand for or use of existing recreational facilities. As discussed above in Section 4.16(a), construction workers would likely come from the local labor force and no additional employees would be hired for Project operation. No increase in permanent residents would occur; therefore, construction or expansion of recreational facilities would not be needed. Therefore, no impact o n recreational facilities would occur.

Mitigation Measures: No mitigation is required.

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4.17 Transportation

TRANSPORTATION
Would the project:

Potentially
Significant
Impact
Less Than
Significant
With Mitigation
Incorporated
Less Than
Significant
Impact No Impact
a. Conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities?
☐ ☐ ☒ ☐
b. C onflict or be inconsistent with CEQA Guidelines §15064.3, subdivision (b)? ☐ ☐ ☒ ☐
c. Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
☐ ☐ ☒ ☐
d. Result in inadequate emergency access? ☐ ☐ ☒ ☐
Significance criteria established by CEQA Guidelines, Appendix G.

Discussion
a. Would the project conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? LESS THAN SIGNIFICANT IMPACT. The proposed Project would result in temporary vehicle trips during construction. Construction worker trips would occur in the morning and early evening hours. Truck trips associated with materials and equipment deliveries to the Project site would likely be distributed throughout the workday, with more frequent trips in the early s tages of construction when the site is prepared, foundations are poured, and the tank components are delivered. Given the temporary period of construction (10 months), trips would be for a limited time along roadways accessing the Project site.

Temporary construction trips are assumed to come from the local area or from the greater Los Angeles County area. While construction-related trips would utilize regional freeways (likely converging on to the I-710 freeway) to access Ocean Boulevard/Pico Avenue and the site, these temporary trips would not be in numbers that could substantially diminish the performance of the circulation system. As shown in Appendix A, construction would generate a maximum of 116 daily total trips (64 worker commute trips, 44 haul related trips, and 8 vendor/delivery trips). It is assumed that haul and vendor trips would be spread throughout the day. Therefore, worst -case temporary peak hour trips (between 7:00 a.m. and 9:00 a.m. and between 4:00 p.m. and 6:00 p.m.) would be 32. These peak hour trips would result from construction worker commutes to and from the Project site. Please note, these represent peak daily trips during construction. Average daily trips during construction would be less. All construction-related trips would only occur temporarily during construction. While these trips would occur on regional and local roadways that connect to the Project site, they would be temporary and the Project would not impact any City of Long Beach or Los Angeles County program, plan, ordina nce, or policy related to transit, bicycle, or pedestrian facilities in the vicinity of the site or along local roadways (not including programs or plans that pertain to vehicle miles travelled, which is addressed under checklist question 4.17(b)). There would be a less-than-significant impact to such facilities.

Baseline maximum truck count at the loading rack is 28 per day. As discussed in Section 2.11, Operations and Maintenance, once constructed, as a worst -case under atypical operations, a maximum increase in truck trips would increase byof 10 percent has been assumed. This would result in a project increase of three truck trips per day (a new maximum of 31 trucks per day at the loading rack). The number of truck trips (approximately one truck per month) associated with crude oil balancing is not anticipated to

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increase during operations as a result of the proposed Project . An increase of three trips per day associated with the proposed project would not conflict with any program pertaining to performance of the circulation system and less than significant impacts would occur.

Mitigation Measures: No mitigation is required.
b. Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)? LESS THAN SIGNIFICANT IMPACT. Per State CEQA Guidelines Section 15064.3(b)(3) and the City of Long Beach SB 743 Implementation Plan ( City of Long Beach, 2020 b), a qualitative analysis of construction traffic vehicle miles travelled (VMT) may be appropriate. As discussed under Section 4.17 (a), temporary construction-related trips are assumed to come from the local area or from the greater Los Angeles County area. A worst-case average would assume that each construction worker commute may generate up to 29.4 VMT, material delivery trips may generate up to 13.8 VMT, and haul trips would be variable (see Appendix A). This VMT is generally consistent with typical employee VMT in the City of Long Beach (City of Long Beach, 2020).

While construction would result in additional trips and VMT, these trips would be temporary and only in volumes necessary for the delivery of equipment and materials to the site , hauling away debris, and constructing the proposed Project. These construction-related trips are not considered to be tr ansit- friendly trips. Equipment and material deliveries, as well as haul trips, cannot utilize public transportation in efforts to reduce overall VMT of the Project. Additionally, most construction workers trips are also not considered transit -friendly, as many workers are required to bring their own tools and protective equipment, making it essential they utilize personal vehicles. Therefore, while the proposed Project would generate temporary construction trips and VMT, they would be temporary and cease upon completion of construction.

Baseline maximum truck count at the loading rack is 28 per day. As discussed in Section 2.11, Operations and Maintenance, as a worst -case under atypical operations, a once constructed, maximum increase in truck trips would increase byof 10 percent has been assumed. This would result in a Project increase of 3 truck trips per day (a new maximum of 31 trucks per day at the loading rack). With respect to permanent “operations” trips, absent substantial evidence indicating that a project would generate a potentially significant level of VMT, projects that generate or attract fewer than 110 permanent trips per day generally may be assumed to cause a less-than-significant transportation impact (OPR, 2018; City of Long Beach, 2020). The proposed Project increase of 3 trips per day is well below this threshold. Therefore, the proposed Project would have no permanent effect on existing VMT of the area. For these reasons, the proposed Project is found to not affect existing transit uses or corridors and is recognized to cause a less- than-significant transportation impact with respect to State CEQA Guidelines Section 15064.3(b)(3).

Mitigation Measures: No mitigation is required.
c. Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? LESS THAN SIGNIFICANT IMPACT. All construction disturbance would occur within the existing World Oil Terminal facility. The proposed Project does not require the realignment of existing internal access roads and the main public entrance to World Oil Terminal on Pico Avenue would be unaffected by the proposed Project. The proposed Project does not include the modi fications to any public roadways or driveways.

During construction, oversized truck trips could be required to deliver large pieces of construction equipment and materials to the site. If needed, any necessary oversized truck trips would obtain all

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required permits from Caltrans and local jurisdictions. The construction contractor would follow the rules and requirements of such permits, which would ensure no hazards to motorists or others utilizing the public roadway system occur. Impacts would be less than significant.

Mitigation Measures: No mitigation is required.
d. Would the project result in inadequate emergency access? LESS THAN SIGNIFICANT IMPACT. Project construction would not encroach upon or cause any temporary disruptions to public roadways. As discussed under Section 4.17(c), in the event any oversized truck trips are necessary during construction, the construction contractor would follow all rules and requirements of any required permits which typically include assurances for emergency vehicle m ovements. Once operational, the proposed Project would have no impact on access or movement to emergency service providers. Impacts would be less than significant.

Mitigation Measures: No mitigation is required.

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4.18 Tribal Cultural Resources

TRIBAL CULTURAL RESOURCES

Potentially
Significant
Impact
Less Than
Significant
With Mitigation
Incorporated
Less Than
Significant
Impact No Impact
a. Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code §21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:

(i) listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code §5020.1(k), or
☐ ☐ ☐ ☒
(ii) a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code
Section 5024.1. In applying the criteria set
forth in subdivision (c) of Public Resource Code §5024.1, the lead agency shall consider the significance of the
resource to a California Native American tribe.
☐ ☐ ☐ ☒
Significance criteria established by CEQA Guidelines, Appendix G.

Discussion
a. Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
(i) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k)? N
O IMPACT. As discussed in Section 4.5, Cultural Resources, there is no potential to discover an unknown tribal cultural resource within the Project site as part of the proposed Project’s construction, since the site is previously disturbed and underlain by hydraulic and imported fill (Albus-Keefe, 2018). The record search and literature information obtained from South Central Coastal Information Center did not indicate the presence of any eligible or listed historic resources within the Project area (see Appendix B – Confidential).

Since there are no significant historical resources located within the Project area, and ground disturbance is planned within hydraulic and imported fills only, the proposed Project would not have an impact on tribal cultural resources.

Mitigation Measures: No mitigation is required.

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(ii) a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe?
NO IMPACT. As discussed previously, the proposed Project would not have the potential to encounter an unknown or buried tribal cultural resource because the Project area is previously disturbed and is located on hydraulic and imported fill. Furthermore, there are no known tribal cultural resources within the Project area. Therefore, the proposed Project would not have an impact on such resources.

Mitigation Measures: No mitigation is required.

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4.19 Utilities and Service Systems

UTILITIES AND SERVICE SYSTEMS
Would the project:

Potentially
Significant
Impact
Less Than
Significant
With Mitigation
Incorporated
Less Than
Significant
Impact No Impact
a. Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
☐ ☐ ☒ ☐
b. Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?
☐ ☐ ☒ ☐
c. Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
☐ ☐ ☒ ☐
d. Generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals ?
☐ ☐ ☒ ☐
e. Comply with federal, state, and local management and reduction statutes and regulations related to solid waste? ☐ ☐ ☒ ☐ Significance criteria established by CEQA Guidelines, Appendix G.

Discussion
a. Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects? LESS THAN SIGNIFICANT IMPACT. The proposed Project would not require any new or expanded wastewater treatment, stormwater drainage, electrical power, natural gas, or telecommunications facilities. The proposed Project is located in a developed area that is served by existing utilities. The two new tanks would be connected to the existing site pipe system through the addition of approximately 40 linear feet of piping, and a short electrical conduit connection would link the new tanks to the existing subpanel located just outside the containment wall to the north. These connections would not require expansion or construction of new utility facilities.

Sanitation Districts of Los Angeles County (LACSD) oversees wastewater treatment facilities that serve the City. The LACSD constructs, operates, and maintains f acilities to collect, treat, recycle, and dispose of sewage and industrial wastes. Wastewater generated on site would be delivered to either the Joint Water Pollution Control Plant (JWPCP) of LACSD or the Long Beach Water Reclamation Plant for wastewater treatment (LACSD, 2020) . The proposed Project is not expected to generate wastewater that exceeds LACSD’s wastewater treatment capacity . The proposed Project would result in a slight increase in wastewater production with the addition of eight workers on site during construction activities.

Wastewater generated by construction workers is expected to be nominal due to the minimal number of workers present. Approximately 50,000 bbl of water sourced from the Long Beach Water Department (LBWD) would be used to hydrotest the two new tanks. The wastewater produced from the hydrotest would be tested for any contaminants in compliance with the National Pollutant Discharge Elimination System (NPDES) requirements before being discharged into the harbor. As such, the wa stewater would

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not be transported to the LACSD treatment facility and would not exceed its wastewater treatment capacity.

During operations , the two new tanks are anticipated to generate less than 300 gallons of dewatered wastewater per tank per day. The dewatered wastewater would be transferred through existing pipes into the existing three 10,000 -gallon wastewater treatment storage tanks and then discharged to the LACSD treatment facility in compliance with World Oil’s discharge permit, as is currently done for the existing tanks. No additional staffing is anticipated under the proposed Project, and therefore, the proposed Project would not generate a substantial amount o f additional wastewater compared with existing conditions. Impacts to utilities facilities would be less than significant.

Mitigation Measures: No mitigation is required.
b. Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years ? LESS THAN SIGNIFICANT IMPACT. The proposed Project would not generate a substantial increase in demand for water. The proposed Project would not introduce a new land use that could increase demand for water services. During construction, a small amount of water may be used during excavation for tank foundations to maintain optimum moisture content of soil layers for compaction. This water use would be temporary and occur over a short duration (approximately three months). Additionally, as discussed in Section 4.19(a), approximately 50,000 bbl of water sourced from the LBWD would be used for the NPDES permitted hydrotest. This activity would only occur once during construct ion to test the tanks for leaks and structural integrity.

Upon completion, future Project operation would remain similar to existing operations. Approximately 300 gallons of water per day are currently dewatered from the existing tanks. A smaller amount would be dewatered from the smaller 25,000-bbl tanks per day. As such, the proposed Project would marginally increase the facility’s total amount of dewatered wastewater to be piped to the 10,000-gallon wastewater treatment storage tanks and LACSD treatment facility. No additional water is anticipated to be used during operation, as the number of staff is expected to remain the same. The proposed Project would continue to be adequately served by the LBWD ’s existing water entitlements and facilities. Therefore, the LBWD’s ability to serve the proposed Project and reasonably foreseeable future development would not be adversely impacted. Impacts would be less than significant.

Mitigation Measures: No mitigation is required.
c. Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?
L
ESS THAN SIGNIFICANT IMPACT. As discussed in Section 4.19(a), approximately 50,000 bbl of water would be used to hydrotest the two new tanks during construction. The hydrotest wastewater would not be sent to the LACSD treatment facility, and thus, would not reduce the capacity of the treatment facility. During operation, the two new tanks would be regularly dewatered. The dewatered wastewater would be transferred through existing pipes into the existing three 10,000 -gallon wastewater treatment storage tanks and then discharged to the LACSD treatment facility in compliance with World Oil’s discharge permit, as is currently done for the existing tanks. The proposed Project would not exceed the wastewater

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treatment capacity of the JWPCP or Long Beach Water Reclamation Plant, and impacts would be less than significant.

Mitigation Measures: No mitigation is required.
d. Wo uld the project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? LESS THAN SIGNIFICANT IMPACT. The proposed Project would te mporarily generate waste associated with construction activities . All construction waste and debris such as trash, scrap metal, abrasive blasting material, paint, pallets, concrete, and general construction scrap would be disposed of or recycled according to the California Green Building Standards Code and the City of Long Beach Construction and Demolition Debris Recycling Program (City of Long Beach, 20 07). Solid waste generated during Project operation is expected to be approximately the same as that of current operations, as operations would remain similar and no increase in staff is anticipated. Approximately every 10 years, the tanks would be cleaned of sludge, repaired, and/or hydrotested. Sludge tank bottom quantities are estimated to be approximately 1,500 bbl every 10 years and are disposed of at permitted treatment, storage, and disposal facilities. The addition of two new storage tanks would slightly increase the total amount of solid waste generated by the facility, but disposal would occur infrequently. The Project would be served by a landfill with sufficient permitted capacity to accommodate the Project’s waste during construction and operation.

Impacts relating to local waste infra structure and solid waste reduction goals would be less than significant.

Mitigation Measures: No mitigation is required.
e. Would the project comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
L
ESS THAN SIGNIFICANT IMPACT. The proposed Project is subject to federal, State, and local regulations and codes relating to solid waste disposal. Specifically, construction activities of the proposed Project would be required to comply with all applicable regulations pertaining to solid waste disposal. These regulations include but are not limited to Assembly Bill (AB) 939, California Waste Management Act , which requires each city in the state to divert at least 50 percent of their solid waste from landfill disposal through source reduction, recycling and composting (CalRecycle, 2018); LBMC Chapter 8.6, Solid Waste, Recycling, and Litter Prevention; California Health and Safety Code Part 13 Title 42, Public Health and Welfare ; and U.S.

Code Chapter 39, Solid Waste Disposal. In addition, waste would be disposed of or recycled according to the California Green Building Standards Code and the City of Long Beach Construction and Demolition Debris Recycling Program (City of Long Beach, 2 007). Solid waste generated during operational activities is expected to remain similar to existing conditions and would be hauled away by the current waste service provider. Therefore, construction and operation of the proposed Project would comply with f ederal, State, and local statutes and regulations related to solid waste. Impacts regarding compliance with federal, state, and local solid waste regulations would be less than significant.

Mitigation Measures: No mitigation is required.

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4.20 Wildfire

WILDFIRE
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:

Potentially
Significant
Impact
Less Than
Significant
With Mitigation
Incorporated
Less Than
Significant
Impact No Impact
a. Substantially impair an adopted emergency response plan or emergency evacuation plan? ☐ ☐ ☐ ☒
b. Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
☐ ☐ ☐ ☒
c. Require the installation or maintenance of associated infrastruc- ture (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? ☐ ☐ ☐ ☒
d. Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? ☐ ☐ ☐ ☒
Significance criteria established by CEQA Guidelines, Appendix G.

Discussion
a. Would the project substantially impair an adopted emergency response plan or emergency evacuation plan?
NO IMPACT. According to the California Department of Forestry and Fire, the project site and entire City of Long Beach is not located within a High Fire Risk Area (CAL FIRE, 2007). Furthermore, the project site and overall POLB are listed as “not burnable” on the U.S . Forest Service Wildfire Hazard Potential website (USFS, 2020). Therefore, wildfire impacts would not occur.

There are no wildfire response plans applicable to the Project site. No impact would occur.

Mitigation Measures: No mitigation is required.
b. Would the project, due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
NO IMPACT. Refer to Section 4.20(a).

Mitigation Measures: No mitigation is required.
c. Would the project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? N
O IMPACT. Refer to Section 4.20(a).

Mitigation Measures: No mitigation is required.

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d. Would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
NO IMPACT. Refer to Section 4.20(a).

Mitigation Measures: No mitigation is required.

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4.21 Mandatory Findings of Significance
MANDATORY FINDINGS OF SIGNIFICANCE Potentially
Significant
Impact
Less Than
Significant
With Mitigation
Incorporated
Less Than
Significant
Impact No Impact
a. Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self -sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory?
☐ ☐ ☒ ☐
b. Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.)
☐ ☐ ☒ ☐
c. Does the project have environmental effects that would cause substantial adverse effects on human beings, either directly or indirectly?
☐ ☐ ☒ ☐
Significance criteria established by CEQA Guidelines, Appendix G.

Discussion
a. Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory? L
ESS THAN SIGNIFICANT IMPACT. As discussed in Section 4.4, Biological Resources, the proposed Project would not substantially adversely impact candidate, sensitive, or special -status species. The Project site is completely developed and does not contain suitable habitat for wildlife species. No special-status wildlife or plant species occur within the Project site, and thus, would not be impacted by Project construction or operation activities. Several non-native grasses and herbaceous weedy species, as well as common bird species were observed on -site during the site visit conducted o n March 3, 2020. To comply with the federal MBTA, the Applicant will be required to follow the requirements of the MBTA as specified in Special Condition BIO-1 (see Section 4.4 [a]). Compliance with the Special Condition BIO -1 would protect any nesting migratory bird on -site during construction. No sensitive riparian habitats or protected wetlands are located within or near the Project site; as such, the proposed Project would not impact sensitive habitat for fish or wildlife. Project construction would be confined to the Project site and would not affect the movement of or restrict the range of any native resident or migratory fish or wildlife species.

Additionally, as discussed in Section 4.5, Cultural Resources , the proposed Project would not impact the significance of a historical or archaeological resource. The Project site is in District 2 of the POLB, which is an artificial landform composed of hydraulic fill. There are no records of any eligible or listed California historic properties or archaeological resources within the Project area. Therefore, the proposed Project would not eliminate any important examples of the major periods of California history or prehistory.

Overall, the proposed Project would not substantially degrade the quality of the environment and suitable

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habitat, adversely impact wildlife and fish species, or eliminate important examples of a major period of California history or prehistory. Impacts would be less than significant. b. Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, effects of other current projects, and the effects of probable future projects.)
LESS THAN SIGNIFICANT IMPACT. The proposed Project involves the construction and installation of two new storage tanks to the existing World Oil Terminal. Although the proposed Project has impacts that were determined to be less than significant that may incrementally affect other resources , they are not considered cumulatively considerable due to the relatively nominal level and area of impact, highly developed industrial surroundings, and temporary nature of the proposed Project. For example, a cumulatively considerable impact may occur if the Project generates sludge tank bottoms at substantial quantities compared with the capacity of a TSDF. As described in Section 4.9 (Hazards and Hazardous Materials), the proposed Project would generate approximately 15,000 bbls of sludge tank bottoms over its 50-year service life, which is a small portion compared with the overall capacity (1 million gallons with an additional 400,000-gallon equivalent of container storage) at the nearest U.S. Ecology waste facility in Vernon, California. As such, the proposed Project would not result in cumulatively considerable hazardous waste impacts.

Generally, contributions to air quality and greenhouse gas emissions impacts are cumulative due to the regional and global nature of air pollution and climate change, respectively . As discussed in Section 4.3, Air Quality, and Section 4.8, Greenhouse Gas Emissions, the proposed Project ’s impacts would be less than significant with regards to these environmental factors. The proposed Project, as well as all other current projects (e.g., similar ongoing or reasonably foreseeable future construction projects) in the region, would comply with applicable SCAQMD standards, recommendations, and regulations, which are designed to limit air quality impacts within its jurisdiction, as well as State laws. As such, all potential cumulative impacts regarding air quality and greenhouse gas emissions would be limited and minimized.

The construction activities are minor and would be completed within approximately 10 months.

Operational activities would not substantially change. As such, the proposed Project’s cumulative impacts are considered less than significant.
c. Does the project have environmental effects, which would cause substantial adverse effects on human beings, either directly or indirectly?
LESS THAN SIGNIFICANT IMPACT. As discussed in the analysis above, implementation of the proposed Project would result in no impacts or l ess than significant impacts to all environmental issues areas, including those which may cause adverse effects on humans . No potentially significant impacts were found, and impacts were determined not to be cumulativ ely considerable. Therefore, implementation of the proposed Project would not have a significant environmental effect that could cause substantial adverse effects on human beings, either directly or indirectly.

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5. Application Summary Report
This chapter, in conjunction with the Initial Study /Negative Declaration , constitutes an Application Summary Report prepared in accordance with the certified 1990 Port of Long Beach Port Master Plan (PMP), as amended, and the California Coastal Act of 1976 (CCA). In the consistency analysis discussed below, the proposed Project is in conformance with the stated policies of the PMP and the CCA.

5.1 California Coastal Act Consistency Analysis
In accordance with the CCA, the Coastal Zone includes all areas within 3 miles seaward and approximately 1,000 yards inland, depending upon the level of existing inland development. Chapter 3 of the CCA provides the standards by which the adequacy of local coastal programs is determined, while Chapter 8 of the CCA governs California ports, including the POLB, and recognizes these ports as pri mary economic and coastal resources that are essential elements of the national maritime industry (Section 30701[a]).

The following is a discussion of applicable CCA sections and appropriate project-related information.

5.1.1 Chapter 3 of CCA
The specific policies of Chapter 3 of the CCA would not apply to the proposed Project because the proposed improvements at the existing World Oil Terminal Facility at Pier C is not among the appealable project categories in Section 30715 of Chapter 8 of the CCA, as further discussed in Section 5.1.2.

5.1.2 Chapter 8 of CCA
Chapter 8 of the CCA recognizes California ports, including the Port of Long Beach, as primary economic and coastal resources that are essential elements of the national maritime industry (Section 30701[a]).

Relevant Chapter 8 sections of the CCA are listed below and their relationship to the proposed Project is discussed below.

Section 30708: Location, Design and Construction of Port-related Developments All port-related developments shall be located, designed, and constructed so as to:
(a) Minimize substantial adverse environmental impacts. (b) Minimize potential traffic conflicts between vessels. (c) Give highest priority to the use of existing land space within harbors for port purposes, including, but not limited to, navigational facilities, shipping industries, and necessary support and access facilities. (d) Provide for other beneficial uses consistent with the public trust, including, but not limited to, recreation and wildlife habitat uses, to the extent feasible.
(e) Encourage rail service to port areas and multicompany use of facilities. (a) Minimize substantial adverse environmental impacts.

This Initial Study/Negative Declaration prepared pursuant to CEQA finds that the proposed Project would result in less than significant impacts to the environmental factors listed in Section 3.1. As designed, t he proposed Project would avoid substantial adverse effect s on the environment and wou ld be consistent with CCA Section 30708(a).

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(b) Minimize potential traffic conflicts between vessels.

Vessel trips are not associated with existing or proposed operations of the World Oil Terminal, nor would they  be  associated  with  construction  of  the  proposed  Project.  No  vessel  trips  are  associated  with operations of the World Oil Terminal. The proposed Project would expand storage capacity at the World Oil Terminal but would not increase current or future vessel traffic within the Port. Construction materials would be transported via regional and local roadways and, as discussed in IS/ND Section 2.11 (Operations and Maintenance), no vessel transport would occurterminal operations would remain similar once the proposed Project is implemented. During operations, World Oil Terminal would not require an increase in staff. Crude oil and fuel oils would continue to be shipped through pipeline and/or truck loading racks to and from onsite tanks.  Third‐party vendors  who import/export  petroleum from the Project site would generally utilize existing pipelines. Existing operations of the truck loading racks are also anticipated to increase 10 percent, but nNo marine transport would be needed. As such, operational activities would have no effect on marine transport. The proposed Project would be consistent with CCA Section 30708(b). (c) Give highest priority to the use of existing land space within harbors for port purposes.

The proposed Project would be developed at an World Oil’s existing petroleum bulk station and terminal at Pier C, which would serve to expand realign World Oil’s storage capacity and improve the efficiency of terminal  operations  by  allowing  more  tanks  to  be  available  for  lease  by  third‐party  vendors.  As  the proposed  Project  would  improve  existing  Port  operations,  it  would  be  consistent  with  CCA  Section 30708(c).
(d) Provide for other beneficial uses consistent with the public trust, including, but not limited to, recreation and wildlife habitat uses, to the extent feasible.

The Project site is located within Harbor Planning District 2 (Northeast Harbor). As described in the PMP , the primary goals for Planning District 2 are to improve efficiency in cargo movements and provide better allocation  of  available  primary  Port  facilities  by  expansion  through  acquiring  privately  held  property (POLB, 1990). Recreational uses are considered inconsistent with the primary Port development goals of Planning District 2 and therefore are not encourage d in this district (POLB, 1990). Currently the Project site consists of a gravel area within an existing petroleum bulk station and terminal and does not contain any riparian habitat or other sensitive natural communities. As the proposed Project would not affect an area that cou ld  provide beneficial uses for the public or suitable wildlife habitat, the proposed Project would be consistent with CCA Section 30708(d).
(e) Encourage rail service to port areas and multicompany use of facilities.

None  of  the  proposed  Project  activities  would  affect  rRail  service  is  not  associated  with  existing  or proposed operations of the World Oil Terminal, nor would they be associated with construction of the proposed Project. The proposed Project would increase multi‐company use of the World Oil Terminal by enabling third‐party vendors to import/export petroleum from the Project site via existing pipelines and truck loading racks. The proposed Project would be consistent with CCA Section 30708(e).

Section 30715(a)(1): Permit Authority; Appealable Approvals As stated in Chapter 8, Section 30715(a) of the CCA, certification of the PMP allows the Board of Harbor Commissioners to exercise permit authority over any new development contained in the certified PMP, except for categories of development that are appealable to the California Coastal Commission (CCC). The proposed Project would not be appealable under the CCA.

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(a) Until such time as a port master plan or any portion thereof has been certified, the commission  shall  permit  developments  within  ports  as  provided  for  in  Chapter  7 (commencing with Section 30600). After a port master plan or any portion thereof has been  certified,  the  permit  authority  of  the  commission  provided  in  Chapter  7 (commencing with Section 30600) shall no longer be exercised by the commission over any new development contained in the certified plan or any portion thereof and shall at that time be delegated to the appropriate port governing body, except that approvals of any  of  the  following  categories  of  development  by  the  port  governing  body  may  be appealed to the commission:
(1) Developments for the storage, transmission, and processing of liquefied natural gas and crude oil in such quantities as would have a significant impact upon the oil and gas supply of the state or nation or both the state and nation. A development which has a significant impact shall be defined in the master plans.

Under the authority delegated by the CCA, the POLB issues consolidated coastal development permits under the certified 1990 PMP and construction permits under the Long Beach City Charter Section 1215 termed  a  “Harbor  Development  Permit”.  The  proposed  Project  would  construct  two  new  petroleum storage tanks to support existing operations at the World Oil Terminal. The relatively small size of the proposed storage tanks (i.e., 25,000 bbl) would not have a significant impact on State or national oil and gas supply. The U.S. produced around 10‐12 million bbl per day of crude oil and 80‐100 billion cubic feet per day of natural gas between 2018 and 2020 (EIA, 2021a). California produced 10‐14 million bbl per month of crude oil (EIA, 2021b) and 10‐17 million cubic feet per month of natural gas between 2018 and 2020 (EIA, 2021c). In addition, World Oil Corporation is primarily a recycler of oil‐based waste. Used motor oil,  antifreeze,  and  oily  wastewater  is  collected  and  then  recycled  into  marine  diesel  fuel,  paving  and roofing asphalt blending components, and new anti‐freeze at the World Oil Refinery in Southgate, CA. As such, World Oil is providing a service to the oil and gas industry as opposed to being a producer or refiner of crude oil or natural gas.

The proposed Project would provide additional petroleum storage capacity but that would not affect local refinery operations. Refinery processing capacities are constrained by many factors including equipment design capacity, permit conditions, firing rates for combustion sources, and maintenance schedules of the various operating units within a refinery. Refinery processes are not influenced by storage capacity. In addition,  the  proposed  Project  would  not  debottleneck  the  facility  to  allow  for  greater  actual  crude throughput beyond the permitted limits through the existing pipelines, tanks, or loading racks. As such, the proposed Project would have little to no impact on the oil and gas supply of the state or nation and is not appealable under Coastal Act Section 30715(a)(1).

5.2  Consistency with the Port Master Plan
This ASR has been prepared to evaluate the proposed Project for consistency with the certified 1990 PMP, as amended.

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5.2.1  Overview1990 Certified PMP
The PMP was first certified by the California Coastal Commission (CCC) in 1978 as being in conformance with the policies of Chapter 8 (Ports) of the CCA. The PMP was updated and certified in 1983 and again in 1990. Since 1990, numerous plan amendments have been adopted by the POLB and certified by the CCC.

Currently, the POLB is reviewing Amendment #20, which would serve as an independent PMP Update document that incorporates all certified amendments since 1990 and addresses current economic trends and foreseeable projects (POLB, 2019). Because PMP Amendment #20 has not been adopted or certified, it is only referenced in the following section to highlight possible changes to PMP goals or implementation recommendations that may be relevant to the proposed Project.

The Project site is located within Harbor Planning District 2 (Northeast Harbor), which is designated for primary Port facilities, Port related uses, hazardous cargo facilities, ancillary Port facilities, oil production, and navigation (POLB, 1990). The proposed construction and operation of two petroleum storage tanks at the existing World Oil Terminal at Pier C would be consistent with the Northeast Harbor’s allowable and permitted designated use of hazardous cargo facilities.

5.2.2  Port Development Goals
The 1990 Certified PMP identifies six long‐range planning goals and objectives for developing Port policies involving future Port development and expansion. Among the goals for Port development in Chapter IV of the PMP,Port‐wide development and expansion goals cited in the PMP , the proposed Project would support the following:

Goal 2: Encourage maximum use of facilities
The proposed Project would serve to maximize uses at the World Oil Terminal by expanding realigning their  storage  capacity  and  improving  to  increase  the  efficiency  of  terminal  operations.  However,  the proposed  Project  would  not  debottleneck  the  facility  to  allow  for  greater  actual  crude  oil  throughput beyond  the  permitted  limits  through  the  pipelines,  tanks,  or  truck  loading  racks.  Furthermore,  the proposed Project would be consistent with tThe objectives of Port Development Goal 2 to rehabilitate under‐utilized terminal facilities and to improve the efficiency of cargo handling facilities would be met by the proposed Project.

Goal 5: Develop land for primary port facilities and port‐related uses The proposed Project would be constructed at World Oil’s an existing petroleum bulk station and terminal at Pier C. By expanding therealigning World Oil’s storage capacity of thisat the terminal, the proposed Project would be consistent with the objectives of Port Goal 5 to intensify existing development and to redevelop existing land within the Harbor District.

5.2.3  Plan Elements
The PMP provides guidance and direction for policy and business decisions affecting the future growth and development of the POLB. The six plan elements of the certified PMP include Public Access, Visual Quality, and Recreation/Tourist; Navigation; Environmental; Transportation/Circulation; Intermodal Rail Facilities;  and  Oil  Production  and  Operations.  Each  plan  element  outlines  specific  plan ning   goals  and issues, and provides a list of recommendations and/or an implementation program. The proposed PMP

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Amendment #20 would add two additional plan elements: Climate Change Adaptation and Terminal Operations (POLB, 2019).

The goals and implementation recommendations from the En vironmental Element and, Transportation/Circulation Element relevant to the proposed Project . , the proposed Climate Change Adaptation Element, and the proposed Terminal Operations Element would be relevant to the proposed tank installation project. These elements are discussed below.

Environmental Element
The Environmental Element identifies specific issues of concern regarding Port development and operations, which include air quality , habitat preservation/marine mitigation , hazardous waste , and permit processing. The following goal s and implementation recommendations from the Environmental Element would be applicable to the proposed Project:
 Goal 1: Minimize pollutant levels from existing and future sources.  Air Quality Recommendations:
– Limit idling of construction equipment and vehicles.
– Implement a watering program to minimize fugitive dust. – Use low sulfur fuel.

As discussed in Initial Study/Negative Declaration Section 4.3 (Air Quality), the proposed Project would be required to c omply with applicable Clean Air Action Plan construction best management practices and South Coast Air Quality Management District Rule 403 (Fugitive Dust) control measures . The proposed Project would also comply with Special Condition AQ-1 in the Harbor Development Permit (see Section

5.3 [Special Conditions]). Theisse condition requirements would minimize daily construction emissions, which would ensure that emissions remain below significance thresholds.

The proposed Project would avoid substantial adverse effect s on the environment, and any short-term construction impact s would be less than significant . The proposed Project would not conflict with the planning goals or implementation recommendations of this element.

Transportation/Circulation Element
The purpose of the Transportation/Circulation Element is to: (1) identify existing transportation/circulation problems; (2) identify future transportation needs of the Port; and (3) present current plans and recommendations to ad dress the POLB’ s transportation demands. Goal 1 from the Transportation/Circulation Element would be applicable to the proposed Project:
 Goal 1: Provide for efficient circulation of vehicular and rail traffic within the Port (with minimum disruption to Port activities).

The proposed construction and operation of two petroleum storage tanks at the existing World Oil Terminal would not require the realignment of existing internal access roads, and the main public entrance to World Oil Terminal on Pico Avenue would be unaffected by the proposed Project.

Furthermore, the proposed Project does not include the modifications to any public roadways or driveways. Temporary construction-related vehicle trips over the 10 -month construction period would not be in numbers that could substantially diminish the performance of the circulation system. As a worst- case assumption, such as an atypical condition involving a pipe being service d, truck trips are estimated World Oil Tank Installation Project
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to increase 10 percent (three daily trucks) during proposed Project operations. ‐ case assumption, Project operation would result in a 10 percent increase in use of the truck loading racks, resulting in an estimated increase of three daily truck trips. These additional trips are sufficiently limited such that they would have negligible effects on transportation within the POLB. The proposed Project would not conflict with the planning goals or implementation recommendations of the Transportation/Circulation Element.

Terminal Operations Element (Proposed)
The Terminal Operations Element is a new plan element that would be added with certification of PMP Amendment #20. The purpose of this element is to ensure that the POLB meets the challenges of changing vessel sizes, terminal capacities, the intermodal supply chain, and advances in technology by modernizing and expanding Port facilities in ways that are consistent with the CCA (POLB, 2019). The element includes goals to increase the POLB’s marine terminal capacity to accommodate future demand.

The proposed project would be compatible with the Terminal Operations Element, as it would maximize current land uses at the World Oil Terminal by expanding storage capacity and improving the efficiency of terminal operations.

5.2.4  District Goals
The certified 1990 PMP identifies the following goal for the District 2, Northeast Harbor Planning District:
 Goal 1: Acquire private property and increase primary Port use.

The proposed tank construction would serve to expand realign World Oil’s storage capacity and improve the efficiency of terminal operations, and therefore would be consistent with this District goal. None of the proposed Project activities would impede or conflict with POLB goals of acquiring non‐Port property.

The proposed Project would be consistent with the certified PMP’s goal for the Northeast Harbor.

Proposed PMP Amendment #20 include s  four planning goals for the Northeast Harbor Planning District (POLB, 2019). Of these four goals, the following would be applicable to the Project:
 Goal 4: Incorporate environmentally sustainable operations.

The proposed Project has been designed to avoid substantial adverse effects on the environment, and any  short‐term  construction  impacts  would  be  less  than  significant.  No  adverse  impacts  to  the environment would occur during operation. The proposed Project would be consistent with the proposed goals from PMP Amendment #20.

5.2.5   Risk Management Plan
In  1981,  the  California  Coastal  Commission  certified  the  Port’s  Risk  Management  Plan  (RMP)  as Amendment  No.  1  to  the  1978  certified  PMP,  which  provided  the  Long  Beach  Board  of  Harbor Commissioners the ability to issue coastal development permits for hazardous liquid bulk cargo facilities, as well as other developments in the Port that are in conformance with the Certified Port Master Plan (POLB, 1981). The RMP contains policies for the Port to apply in the permitting of new hazardous liquid bulk cargo developments or in the permitting of modifications or expansions to existing facilities involved with the transfer, handling, storage, and transport of hazardous liquid bulk cargoes. The approach taken is to define the casualties or accidents possible at the hazardous facility, in this case a spill from the largest container, and then calculate or derive from actual case data the extent of the hazard area produced, referred  to  as  the  “hazard  footprint”.  The  RMP  states  that  if  a  development  involves  the  storage  or

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transfer in liquid bulk form of any hazardous material, or if the development may places a vulnerable resource within an existing hazard footprint as described in the RMP, then a risk analysis is required (POLB, 1981). The RMP defines vulnerable resources as residential populations, recreational and visitor serving areas, high density working populations, and facilities with high total value, including cargo and equipment (POLB, 1983). The RMP mandates that the resulting hazard footprint of a development must not overlap any vulnerable resources. The boundary of a hazard footprint represents the distance at which the impacts of the worst probable events will be reduced to levels which are not likely to cause injury or property damage, as calculated and mapped by the Port.

In 2018, the POLB conducted a risk assessment of the World Oil Terminal, per the guidelines of the 2009 Application Document for Conducting Hazard Impact Assessments in Support of the Risk Management Plans of the Ports of Los Angeles and the Port of Long Beach ( Risk Assessment Report) . The Risk Assessment Report concluded that the largest hazard footprints and subsequent vulnerability zone can be defined by releasing the most volatile material stored in the World Oil Terminal (marine diesel) into the largest impoundment basin and performing the consequence analysis calculations under the POLB - prescribed weather conditions. The Risk Assessment Report de termined the p otential hazard zones by considering wind directions during a fire event from both within the containment wall and at the truck loading rack. When all combinations of wind directions are considered, the distance away from the containment wall and truck loading rack is referred to as a vulnerability zone. The vulnerability zone simply identifies the area that could be affected by a specific radiant flux level, but does not identify what area could be affected at one time. The vulnerability zone approach is used to identify the area that could affect a vulnerable resource . The Project site is not adjacent to a hazardous facility or vulnerable resources. The two additional 25,000 bbl storage tanks would be installed in the vacant northwest corner within an terminal’s existing 12-foot containment wall. After the implementation of the proposed Project, marine diesel oil would remain the most volatile material stored/handled at the terminal therefore the largest hazard footprint and subsequent vulnerability zone remains the same a nd would remain in conformance with the RMP.

5.3 Draft PMP Update
An update to the certified 1990 PMP U pdate (PMPU) is currently underway. In July 2019, the POLB released the Draft PMPU for public review. The PMP U would serve as an independent PMPU document that incorporates all certified amendments since 1990 and addresses current economic trends and foreseeable projects (POLB, 2019). Because the Draft PMPU has not yet been adopted by the Long Beach Board of Harbor Commissioners or certified by the CCC, it is only referenced in the following sections to highlight potential changes to PMPU goals or implementation recommendations that may be relevant to the proposed Project.

Under the Draft PMPU, the proposed Project site would be within the Northeast Harbor Planning District (District 2).

5.3.1 Draft PMP Update Port Development Goals
The Draft PMPU currently identifies four long-range planning goals and corresponding objectives for Port development that are designed to maintain flexibility, respond to Port tenant needs, and allow the Port to respond effectively to requirements dictated by national and international economic trends. Among the proposed goals for Port development in the D raft PMPU, the proposed Project would support the following:

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Goal 2: Develop Modern Terminal Facilities with Efficient Operations The proposed Project would construct two additi onal tanks in the generally vacant northwest corner of the existing terminal providing additional storage capacity to increase the efficiency of terminal operations. The new tanks would supplant the terminal’s existing tanks that provide crude oil storage to the World Oil Refinery in South Gate. The existing tanks would then be removed from dedicated refinery service and become available for lease to third-party vendors. Objectives under Goal 2 would be met by the proposed Project.

5.3.2 Draft PMP Update Plan Elements
In addition to the long-range planning goals addressed above, the Draft PMPU currently also includes plan elements, which provide the policy framework for future POLB development and Port -wide guidance on major operational/functional areas and policy areas. The eight plan elements of the proposed Draft PMPU include Public Access and Recreation; Environment and Sustainability; Climate Change Adaptation; Visual Quality; Transportation and Circulation; Navigation; Terminal Operations; Rail Operations; and Oil Operations. Each of these plan elements consist of planning goals and issu es and recommended actions.

Of the eight plan elements currently listed in the Draft PMPU, Environment and Sustainability, Climate Change Adaptation, and Terminal Operations are discussed below.

Environment and Sustainability Element
The Environmental and Sustainability Element embodies the POLB’s ongoing efforts to preserve and enhance the environment through its leadership in innovative goods movement, natural resources stewardship, and sustainability. The Environment and Sustainabil ity Element reflects the Green Port Policy, which was adopted by the Board of Harbor Commissioners in January 2005.

Of the six goals currently identified for the Environment and Sustainability Element, the proposed Project would support the following planning goal:

Goal 1: Reduce environmental and health impacts from Port operations sources.

As discussed in Initial Study/Negative Declaration Section 4.3 (Air Quality), the proposed Project would be required to c omply with applicable Clean Air Action Plan construction best management practices and South Coast Air Quality Management District Rule 403 (Fugitive Dust) control measures. The proposed Project would also comply with Special Condition AQ -1 in the Harbor Development Permit (see Section

5.3 [Special Conditions]). This condition would minimize daily construction emissions, which would ensure that emissions remain below significance thresholds.

The proposed Project would avoid substantial adverse effect s on the environment, and any short-term construction impacts would be less than significant . The proposed Project would not conflict with the planning goals of this element.

Climate Change Adaptation Element
The Climate Change Adaptation Element would be a new plan element which outlines the Port’s goals for climate change adaptation and coastal resiliency. The element incorporates the strategies identified in the POLB’s 2016 Climate Adaptation and Coastal Resiliency Plan (CRP) that address climate change impacts through existing POLB policies, plans, and guidelines, including incorporating climate change analysis and considerations to the POLB ’s development permitting process. Of the three goals identified

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for the Climate Change Adaptation E lement, the proposed Project would support the following planning goal:
 Goal 2: Safeguard vulnerable assets to minimize impact of damage or loss.

As discussed in Initial Study Section 4.10 (Hydrology and Water Quality), the proposed petroleum storage tanks would be constructed and operated within the existing 12.5 to 13-feet high containment wall that is designed to hold the largest tanks capacity (90,000 barrels ) plus a 100 -year storm event. The containment wall would continue to offer the same level of adequate protection for the proposed tanks as they do for the existing tanks. Although a flood control system is not in place at the P roject site, air driven pumps may be used to divert water over the containment wall during a flood event. According to the 2016 CRP, t he project site would not be subject to permanent inundation from projected sea level rise, and would only be subject to temporary inundation of up to four feet with the combination of sea level rise and a 100 -year storm event. With the infrastructure protection provided by the existing containment wall and air driven pumps, the proposed P roject would be compatible with the Climate Change Adaptation Element.

Terminal Operations Element
The Terminal Operations Element would be a new plan element that details the POLB’s need to accommodate forecast deman d for containerized and non -containerized cargo . T his element would ensure that the POLB meets the challenges of changing vessel sizes, terminal capacities, the intermodal supply chain, and advances in technology by modernizing and expanding Port facilities in ways that are consistent with the CCA (POLB, 2019). The element currently includes goals to increase the POLB’s marine terminal capacity to accommodate future demand. Of the five goals currently identified for the Terminal Operations Element, the proposed Project would support the following planning goal:
 Goal 4: Modernize container terminals to improve operational efficiency.

The proposed Project would be compatible with the Terminal Operations Element, as it would maximize current land uses at the World Oil Terminal by providing additional storage capacity and improving the efficiency of terminal operations.

5.3.3 Draft PMP Update District Goals
Under the Draft PMPU, t he proposed Project would be located within the Northeast Planning District (District 2 ). The D raft PMPU currently includes four planning goals for the Northeast Harbor Planning District. Of the four goals, Goal 4 would be applicable to the Project:
 Goal 4: Incorporate environmentally sustainable operations.

The proposed Project has been designed to avoid substantial adverse effect s on the environment, and any short- term construction impacts would be less than significant . No adverse impacts to the environment would occur during operation. The proposed Project would be consistent with Goal 4.

5.3.4 Draft PMP Update Permitted Land and Water Uses
The permitted uses for the Northeast Planning District would include the following permitted land uses:
primary port facilities, port-related facilities, maritime support facilities, hazardous cargo facilities, oil and gas production facilities, utilities, visitor-serving commercial facilities, and institutional.

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The proposed Project would continue to be consistent with the Northeast Ha rbor’s allowable and permitted use of hazardous cargo facilities.

5.43 Special Conditions
In instances where the proposed Project presents no significant impact and no mitigation is required, there may be additional ‘Special Conditions’ imposed on the project by the POLB that would further lessen a ‘no significant impact’ below a significance threshold or potentially eliminate an impact. These Special Conditions would be implemented as required in the Harbor Development Permit (HDP), project specifications, or other applicable documents governing site use and or facility operations. Special Conditions are consistent with the Green Port Policy, C lean Air Action Plan, and the Water Resources Action Plan.

Special Conditions are the federal, State, and local regulations and permit requirements, environmental measures, and/or assumptions that are applied to proposed projects in the POLB on a typical basis and are, therefore, considered to be part of project descriptions. All applicable Special Conditions proposed by the Port or regulatory agencies would be implemented as required in tenant lease agreements, project specifications, or other applicable documents governing site use and or facility operations. Special Conditions are consistent with the Green Port Policy, the San Pedro Bay Ports Clean Air Action Plan, and the Water Resources Action Plan.

Special Conditions are assumed to be part of the proposed p roject for analysis purposes, as opposed to mitigation measures, which are added to lessen a significant impact after analyses have been completed.

The following Special Conditions for Air Quality, Biological Resources , and Geology and Soils would be incorporated as part of the proposed Project to ensure that P roject co nstruction further reduces construction emissions and complies with the requirements of the Migratory Bird Treaty Act and the design recommendations of the geotechnical investigation performed at the site ( Albus-Keefe & Associates Geotechnical Update Report, 2018). Included below are the various means used to implement the Special Conditions as well as the timing for implementation.

Special Condition AQ -1. Non-Road Engine Emission Standards. Permittee shall ensure that all construction equipment meet the United States Environmental Protection Agency Tier 4 non-road engine standards. Prior to construction, Permittee shall instruct construction crews on the implementation of Special Conditions.

Special Condition BIO-1. Nesting Bird Surveys. To prevent taking active bird nests during the nesting season (approximately February 1 through August 31), the following measures shall be implemented by the Applicant as appropriate:
 Prior to the onset of construction activities (i.e., mobilization, staging, demolition, or heavy plant trimming) during the nesting season, the Applicant shall retain a qualified avian biologist to conduct pre-construction surveys in all areas located within 300 feet of the Project area. The required survey dates may be modified based on local conditions, as determined by the qualified avian biologist.  If breeding birds with active nests are found prior to or during construction, the qualified avian biologist will establish a species-appropriate non-disturbance buffer and will periodically monitor the nest during construction activity.
 During construction within the nesting season, activities will be periodically monitored to ensure that no new nest building occurs within work areas.

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• The Applicant shall provide weekly reports describing monitoring actions, relevant observations, and any protective actions taken to the POLB Director of Environmental Planning.

Special Condition GEO-1. Geotechnical Recommendations . To ensure impacts from ground shakin g, liquefaction, unstable soils, and expansive soils would be reduced to the extent feasible, the final Project design shall implement the geotechnical recommendations provided in the Albus -Keefe & Associates Geotechnical Update Report, 2018. The final Project design shall be reviewed for consistency by a qualified geotechnical engineer prior to Project implementation and provide a letter stating that the plans correctly incorporate the geotechnical recommendations.

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6. Report Preparation
A consultant team headed by Aspen Environmental Group prepared this document under the direction of the Port of Long Beach. The preparers and technical reviewers of this document are presented below.

Lead Agency
Port of Long Beach
Jennifer Blanchard, Project Manager ......................................................... Lead Agency Contact, Environmental Planning Matthew Arms, Director ........................................................................................... Environmental Planning Dawn A. McIntosh, Deputy City Attorney ............................................. Long Beach City Attorney’s Office Allyson Teramoto, Manager of CEQA/NEPA Practices .......... Environmental Planning Dan Ramsay, Manager of Environmental Remediation ........ Environmental Planning James Vernon, Manager of Water Quality PracticesAssistant Director Environmental Planning Dylan Porter, Manager of Water Quality PracticesSenior Environmental Specialist Environmental Planning Justin Luedy, Environmental Specialist Associate ........................ Environmental Planning Shashank Patil, Senior Port Planner ............................................................. Transportation Planning Tony Chan, Ph.D., Office Systems Analyst ............................................ Master Planning

Project Management and Document Production
Aspen Environmental Group – Prime Contractor
Lisa Blewitt, Senior Associate .............................................................................. Project Manager, Noise William Walters, PE, Senior Associate ....................................................... Air Quality, Greenhouse Gas Emissions, Energy Chris Huntley, Vice President, Biological Team Lead ............... Biological Resources (Reviewer) Brigit Harvey, MS, Wildlife Biologist ............................................................ Biological Resources James Allan, PhD, RPA, Cultural Resources Manager .............. Cultural Resources, Tribal Cultural Resources Lauren DeOliveira MS, Cultural Resource Specialist ................. Cultural Resources, Tribal Cultural Resources Stephanie Tang, Environmental Scientist .............................................. Aesthetics, Agriculture and Forestry Resources, Hydrology and Water Quality, Land Use and
Planning, Mineral Resources, Population and
Housing, Public Services, Recreation, Utilities and
Service Systems, Wildfire, Mandatory Findings of
Significance
Scott Debauche, CEP, Environmental Planner
................................. Transportation
Tatiana Inouye, Environmental Planner .................................................. Application Summary Report ENGEO – Geotechnical Subcontractor
James Thurber, CHG, CEG, PG, Principal ................................................. Geology and Soils, Hazards and Hazardous Materials, Hydrology and Water Quality (Groundwater)
Jennifer Knipper, Staff Geologist ..................................................................... Geology and Soils, Hazards and Hazardous Materials, Hydrology and Water Quality (Ground Water)

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7. References
ADI Analytics. 2021. Regulations to drive U.S renewable diesel capacity growth through 2025. [Online]:
https://adi-analytics.com/2020/02/10/regulations-to-drive-u-s-renewable-diesel-capacity-growth- through-2025/. Accessed July 2021.

Albus-Keefe (Albus-Keefe & Associates, Inc.). 2018. Geotechnical Update Report, Proposed Tanks, 1405 Pier “C” Street, Long Beach, California. May 2.

CAL FIRE (California Department of Forestry and Fire Protection). 2007. Draft Fire Hazard Severity Zones in Local Responsibility Area – State of California. [Online]: https://osfm.fire.ca.gov/media/6827/ fhszl06_1_map.pdf. Accessed May 1, 2020.

CalRecycle. 2018. History of California Solid Waste Law, 1985-1989. July 27. [Online]:
https://www.calrecycle.ca.gov/laws/legislation/calhist/1985to1989. Accessed May 4, 2020.

Caltrans (California Department of Transportation). 2013a. Technical Noise Supplement to the Traffic Noise Analysis Protocol. September. [Online]: https://www.gsweventcenter.com/ Draft_SEIR_References/2013_09_Tech_Noise_Supp.pdf. Accessed March 6, 2020. _____. 2013b. Transportation and Construction Vibration Guidance Manual. September. [Online]:
http://website.dot.ca.gov/env/noise/docs/tcvgm-sep2013.pdf. Accessed March 6, 2020. _____. 2019. List of Eligible and Officially Designated State Scenic Highways. Microsoft Excel digital file.

Obtained from: https://dot.ca.gov/programs/design/lap-landscape-architecture-and-community- livability/lap-liv-i-scenic-highways. Accessed April 28, 2020.

CARB (California Air Resources Board). 2016. SIP Emissions Projection Data. [Online]:
https://www.arb.ca.gov/app/emsinv/2017/emssumcat.php. Accessed May 2021. _____. 2017. California’s 2017 Climate Change Scoping Plan. November. [Online]: https://ww3.arb.ca.gov/ cc/scopingplan/scoping_plan_2017.pdf. Accessed April 2020.

CDFW (California Department of Fish and Wildlife). 2020. California Natural Diversity Database (CNDDB) Rarefind 5, Version 5.2.14. [Online]: http://wildlife.ca.gov/Data/CNDDB/Maps-and-Data/.

Accessed April 23, 2020.

CGS (California Geological Survey). 1999a. Fault Rupture Hazard Zones in California, CGS Special Publication #42.
_____.1999b. Seismic Hazard Zone Map, Long Beach Quadrangle. March 25. [Online]:
http://gmw.consrv.ca.gov/shmp/download/quad/LONG_BEACH/maps/ozn_longb.pdf. Accessed May 4, 2020.
_____. 2009. Tsunami Inundation Map for Emergency Planning, Long Beach Quadrangle. [Online]:
https://www.conservation.ca.gov/cgs/Documents/Tsunami/Maps/Tsunami_Inundation_LongBeac h_Quad_LosAngeles.pdf. Accessed May 5, 2020.
_____. 2010. San Gabriel Valley P-C Region Showing MRZ-2 Areas and Active Mine Operations. [Online]:
ftp://ftp.consrv.ca.gov/pub/dmg/pubs/sr/SR_209/. Accessed April 28, 2020. _____. 2020. Probabilistic Seismic Hazards Ground Motion Interpolator (2008). [Online]:
https://www.conservation.ca.gov/cgs/ground-motion-interpolator-for-embedding.htm. Accessed May 4, 2020.

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City of Long Beach. 1995. Chapter 21.33 Industrial Districts. [Online]: https://library.municode.com/ca/ long_beach/codes/municipal_code?nodeId=TIT21ZO_CH21.33INDI. Accessed April 28, 2020. _____. 2007. Construction & Demolition (C&D) Debris Recycling Program. [Online]:
http://www.longbeach.gov/lbds/building/cd/. Accessed April 27, 2020. _____. 2013. City of Long Beach General Plan, Mobility Element. [Online]: http://www.longbeach.gov/ globalassets/lbds/media-library/documents/orphans/mobility- element/320615_lbds_mobility_element_web. Accessed April 28, 2020. _____. 2019. City of Long Beach General Plan, Land Use Element. December. [Online]:
http://www.longbeach.gov/globalassets/lbds/media-library/documents/planning/advance/ lueude/land-use-element-final-adopted-december-2019. Accessed March 6, 2020. _____. 2020a. City of Long Beach Zoning and Land Use App. [Online]:
https://longbeachca.maps.arcgis.com/apps/webappviewer/index.html?id=17b68e7082ef4a4ea8b a6b0d04729758. Accessed April 28, 2020.
_____. 2020b. SB 743 Implementation for the City of Long Beach. May 6.

City of Rancho Palos Verdes. 2018. Final Draft Natural Community Conservation Plan and Habitat Conservation Plan. [Online]: https://www.rpvca.gov/DocumentCenter/View/13211/NCCPHCP.

Accessed April 23, 2020.

County of Los Angeles Airport Land Use Commission. 2003. Long Beach Airport – Airport Influence Area. [Online]: http://planning.lacounty.gov/assets/upl/project/aluc_airport-long-beach.pdf. Accessed May 1, 2020.

DOC (California Department of Conservation). 2016. Los Angeles County Important Farmland 2016. [Online]: https://www.conservation.ca.gov/dlrp/fmmp/Pages/Maps-and-Data.aspx. Accessed May 5, 2020.
_____. 2020. CalGEM GIS Well Finder. [Online]: https://maps.conservation.ca.gov/doggr/wellfinder/ #openModal/-118.20986/33.77431/17. Accessed April 28, 2020.

Dougherty, John. 2020. Personnel Communication between John Dougherty, World Oil Terminal Manager and Aspen Environmental Group during the site visit conducted March 3, 2020.

DTSC (Department of Toxic Substances Control). 2020. DTSC Envirostor Hazardous Waste and Substances Site List. [Online]: https://www.envirostor.dtsc.ca.gov/public/search.asp?cmd=search&reporttype =CORTESE&site_type=CSITES,OPEN,FUDS,CLOSE&status=ACT,BKLG,COM&reporttitle=HAZARDOU S+WASTE+AND+SUBSTANCES+SITE+LIST. Accessed June 17, 2020.

DWR (California Department of Water Resources). 2014. SGMA Groundwater Management. [Online]:
https://water.ca.gov/Programs/Groundwater-Management/SGMA-Groundwater-Management.

Accessed May 5, 2020.
_____. 2020. SGMA Basin Prioritization Dashboard. [Online]: https://gis.water.ca.gov/app/bp-dashboard/ final/. Accessed May 5, 2020.

EIA (U.S. Energy Information Administration). 2021a. Article: U.S. oil and natural gas production to fall in 2021, then rise in 2022. January 14. [Online]: https://www.eia.gov/todayinenergy/detail.php?id =46476. Accessed June 2021.

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_____. 2021b. Petroleum & Other Liquids, Data Tab, California Field Production of Crude Oil. [Online]:
https://www.eia.gov/dnav/pet/hist/LeafHandler.ashx?n=pet&s=mcrfpca1&f=m. Accessed June 2021.
_____. 2021c. Natural Gas, Data Tab, California Natural Gas Marketed Production. [Online]:
https://www.eia.gov/dnav/ng/hist/n9050ca2m.htm. Accessed June 2021.

Environmental Data Resources (EDR). 2020. EDR Radius Map Report with Geocheck - World Oil Terminals Long Beach. March.

FEMA (Federal Emergency Management Agency). 2008. FEMA Flood Map Service Center: Search by Address. September 26. [Online]: https://msc.fema.gov/portal/search?AddressQuery=port% 20of%20long%20beach#searchresultsanchor. Accessed May 5, 2020.

FHWA (Federal Highway Administration). 2006. FHWA Highway Construction Noise Handbook. Final Report. August. [Online]: https://www.fhwa.dot.gov/Environment/noise/construction_noise/ handbook/. Accessed March 6, 2020.

FTA (U.S. Department of Transportation, Federal Transit Administration, Office of Planning and Environment). 2018. Transit Noise and Vibration Impact Assessment. FTA Report No. 0123. [Online]: https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/ transit-noise-and-vibration-impact-assessment-manual-fta-report-no-0123_0.pdf. Accessed March 6, 2020.

Hayward Baker. 2015. Vibro Piers. June. PDF file.

Keller. 2020. Vibro stone columns (vibro replacement). [Online]: https://www.keller-na.com/expertise/ techniques/vibro-stone-columns-vibro-replacement. Accessed April 24, 2020.

LACSD (Los Angeles County Sanitation Districts). 2020. Wastewater Treatment Districts. [Online]:
https://www.lacsd.org/services/wastewatersewage/facilities_information/wwtreatmentplant/def ault.asp. Accessed May 4, 2020.

LARWQCB (Los Angeles Regional Water Quality Control Board). 2018. Order No. R4-2018-0125, General NPDES Permit No. CAG994004, Waste Discharge Requirements for Discharges of Groundwater from Construction and Project Dewatering to Surface Waters in Coastal Watersheds of Los Angeles and Ventura Counties. Adopted on September 13. [Online]:
https://www.waterboards.ca.gov/
losangeles/board_decisions/adopted_orders/general_orders/r4-2018-0125/OrderNoR4-2018- 0125(Order).pdf. Accessed May 5, 2020.

LBFD (Long Beach Fire Department). 2020. Station Locations. [Online]: http://www.longbeach.gov/fire/ about-us/station-locations/. Accessed April 30, 2020.

LBMC (Long Beach Municipal Code). 2020a. Municipal Code. Codified through Ordinance No. ORD-20-004.

Supplement 27. Update 2. Online content updated February 17, 2020. [Online]:
https://library.municode.com/ca/long_beach/codes/municipal_code. Accessed April 23, 2020. _____. 2020b. Supplement 27 Update 2. February 17. [Online]: https://library.municode.com/ca/ long_beach/codes/municipal_code?nodeId=TIT8HESA_CH8.80NO. Accessed March 6, 2020.

LBPD (Long Beach Police Department). 2020. West Patrol Division. [Online]: http://www.longbeach.gov/ police/about-the-lbpd/bureaus/patrol-bureau/west-patrol-division/. Accessed April 30, 2020.

LBUSD (Long Beach Unified School District). 2020. About – Long Beach Unified School District. [Online]:
https://www.lbschools.net/District/. Accessed April 30, 2020.

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Matrix (Matrix PDM Engineering). 2019. API 650 Foundation Design Drawings. Sheet 3 of 3: Foundation Notes. World Oil. January 18.

MBC and Merkel & Associates. 2016. 2013-2014 Biological Surveys of Long Beach and Los Angeles Harbors.

Prepared for the Ports of Long Beach and Los Angeles. June 1. [Online]:
https://www.portoflosangeles.org/pola/pdf/biobaseline2014.pdf. Accessed April 23, 2020.

Moffatt & Nichol. 2007. Tsunami Hazard Assessment for the Ports of Long Beach and Los Angeles Final Report. April. [Online]: https://kentico.portoflosangeles.org/getmedia/e3955258-c8a7-4a95-bff0- e3a4bc1d573b/Appendix_M_Tsunami_Hazard_Assessment. Accessed May 6, 2020.

OEHHA (Office of Environmental Health Hazard Assessment). 2015. Air Toxics Hot Spots Program Risk Assessment Guidelines – Guidance Manual for Preparation of Health Risk Assessments. [Online]:
http://oehha.ca.gov/air/hot_spots/2015/2015GuidanceManual.pdf. Accessed May 2020.

OPC Guidance (Ocean Protection Council). 2018. State of California’s Sea-Level Rise Guidance 2018 Update.

OPR (California Office of Planning and Research). 2018. Technical Advisory on Evaluating Transportation Impacts in CEQA. December. [Online]: https://opr.ca.gov/ceqa/technical-advisories.html. Accessed June 2020.

POLB (Port of Long Beach). 1981. Risk Management Plan, An Amendment to the Certified Port Master Plan.
_____. 1990. Port Master Plan, Update 1990, An Amendment to the 1978 and 1983 Port Master Plans. [Online]: https://www.polb.com/port-info/mission-vision/#master-plan-update. Accessed April 24, 2020.
_____. 2016a. Port of Long Beach Climate Adaptation and Coastal Resiliency Plan. [Online]:
https://www.slc.ca.gov/wp-content/uploads/2018/10/POLB.pdf. Accessed February 12, 2021. _____. 2016b. Port of Long Beach Community Grants Program and Investment Plan. Port of Long Beach. _____. 2019. Draft Port Master Plan Update 2020. July. [Online]: https://www.polb.com/port-info/ mission-vision/#master-plan-update. Accessed May 12, 2020. _____. 2020. Environment – Air – Program Details. [Online]: https://www.polb.com/environment/air/#air- program-details. Accessed May 2021.
_____. 2021. Email RE: World Oil Risk Analysis, from Tony Chan, Hazards Section, to Jennifer Blanchard, Environmental Specialist Associate. May 12.

QUEST. 2018. POLB RMP Guideline Analysis World Oil’s Ribost Terminal. June.

SCAQMD (South Coast Air Quality Management District). 2003. SCAQMD White Paper on Potential Control Strategies to Address Cumulative Impacts From Air Pollution, Appendix D – Cumulative Impact Analysis Requirements Pursuant to CEQA, p.D-3. August. [Online]: http://www.aqmd.gov/docs/ default-source/Agendas/Environmental-Justice/cumulative-impacts-working-group/cumulative- impacts-white-paper-appendix.pdf?sfvrsn=4. Accessed May 2021. _____. 2009. Appendix C - Mass Rate LST Look-up Table. [Online]: http://www.aqmd.gov/docs/default- source/ceqa/handbook/localized-significance-thresholds/appendix-c-mass-rate-lst-look-up- tables.pdf?sfvrsn=2. Accessed May 2020.

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_____. 2017. PERMIT APPLICATION PACKAGE “N” For use in conjunction with the RISK ASSESSMENT PROCEDURES FOR RULES 1401, 1401.1, AND 212, VERSION 8.1. [Online]: http://www.aqmd.gov/ docs/default-source/permitting/rule-1401-risk-assessment/attachmentn-v8-1.pdf?sfvrsn=4.

Accessed May 2020
_____. 2019a. South Coast AQMD Air Quality Significance Thresholds, last revised April 2019. [Online]:
http://www.aqmd.gov/docs/default-source/ceqa/handbook/scaqmd-air-quality-significance- thresholds.pdf. Accessed April 2020May 2021.
_____. 2020. SCAQMD Response to the Communities for a Better Environment comments on the Proposed Title V Significant Permit Revision for Tesoro Refining & Marketing Co. LLS. June 23, 2020. Provided by J. Wong, personal communication, January 20, 2021. _____. 2021a. SCAQMD Rule 205 Expiration of Permits to Construct. [Online]: http://www.aqmd.gov/ docs/default-source/rule-book/reg-ii/rule-205.pdf?sfvrsn=4. Accessed April 1, 2021. _____. 2021b. Email Subject: RE: Tank Project Analysis Confirmation, from Tom Liebel, Senior Engineering Manager, South Coast AQMD to Jennifer Blanchard, Environmental Specialist Associate, Environmental Planning, Port of Long Beach. May 28.
_____. 2021c. Email Subject: Ribost: Tank Project Analysis Confirmation, from Tom Liebel, Senior Engineering Manager, South Coast AQMD to Jennifer Blanchard, Environmental Specialist Associate, Environmental Planning, Port of Long Beach. June 16. _____. 2019b. South Coast AQMD Applications Evaluations and Calculations, Permit to Construct Evaluation, Application 614274. Approved 8/5/19.
_____. 2020a. South Coast AQMD Permit to Construct, Application 614274. Approved 1/2/20. _____. 2020b. South Coast AQMD Permit to Construct, Application 614275. Approved 1/2/20.

SCE (Southern California Edison). 2020. Electric Company ESG/Sustainability Quantitative Information.

October 30. [Online]: https://www.edison.com/content/dam/eix/documents/sustainability/eix- esg-pilot-quantitative-section-sce.pdf. Accessed May 2021.

SWRCB (State Water Resources Control Board). 2020. GeoTracker Database. [Online]: http://geotracker. waterboards.ca.gov/. Accessed June 17, 2020.

The Cornell Lab of Ornithology. 2020. All About Birds. [Online]: https://www.allaboutbirds.org/news/.

Accessed April 23, 2020.

U.S. Ecology. 2021. U.S. Ecology Vernon. [Online]: https://www.usecology.com/location/us-ecology- vernon. Accessed February 11, 2021.

USEPA (U.S. Environmental Protection Agency). 1974. Information on Levels of Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety. March. [Online]: http://www.nonoise.org/library/levels74/levels74.htm. Accessed March 6, 2020. _____. 2020. U.S. EPA AP-42 Compilation of Air Pollutant Emissions Factors, Volume 1: Stationary Point and Area Sources Section 7.1 Organic Liquid Storage Tanks. [Online]: https://www.epa.gov/air- emissions-factors-and-quantification/ap-42-fifth-edition-volume-i-chapter-7-liquid-storage-0.

Accessed May 2021.

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USFS (U.S. Forest Service). 2020. Interactive ArcGIS mapping of U.S. Forest Service Wildfire Hazard Potential website. [Online]: https://www.arcgis.com/home/webmap/viewer.html?useexisting =1&layers=fc0ccb504be142b59eb16a7ef44669a3. Accessed May 1, 2020.

USFWS (U.S. Fish and Wildlife Service). 2019a. California Natural Community Conservation Plans. [Online]:
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=68626&inline. Accessed April 23, 2020. _____. 2019b. Environmental Conservation Online System (ECOS). Habitat Conservation Plans. [Online]:
https://ecos.fws.gov/ecp0/conservationPlan/region/summary?region=8&type=HCP. Accessed April 23, 2020.
_____. 2020. National Wetlands Inventory, Wetlands Mapper. [Online]: https://fwsprimary.wim.usgs.gov/ wetlands/. Accessed April 23, 2020.

USGS and CGS (U.S. Geological Survey and California Geological Survey). 2015. GIS data for the Quaternary fault and fold database for the United States. [Online]: https://www.usgs.gov/natural-hazards/ earthquake-hazards/faults?qt-science_support_page_related_con=4#qt- science_support_page_related_con. Accessed May 4, 2020.

Uslu et al. 2010. Tsunami Assessment Special Series: Vol. 2 Distant tsunami threats to the ports of Los Angeles and Long Beach, California. [Online]: https://repository.library.noaa.gov/view/noaa/ 11108. Accessed April 2021.

World Oil Corp. 2021. Sustainability Beyond the Surface. [Online]: https://worldoilcorp.com/refining/.

Accessed May 2021.

World Oil Terminals. 2019. Application for Harbor Development Permit, Ribost Terminal LLC, DBA World Oil Terminals. August 14.

WRD (Water Replenishment District of Southern California). 2016. Groundwater Basins Master Plan. [Online]: https://www.wrd.org/sites/pr/files/GBMP_FinalReport_Text%20and%20 Appendicies.pdf. Accessed May 5, 2020.

Yorke (Yorke Engineering, LLC). 2021. Application for Permit to Construct/Permit to Operate – Two Additional Petroleum Storage Tanks. Ribost Terminal, LLC. 1405 Pier “C” Street, Long Beach, CA 90802, SCAQMD Facility ID: 111238. February.

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8. Responses to Comments
The public review period for a draft environmental document is a critical part of the CEQA public partici - pation process. It provides the opportunity for other responsible agencies and interested parties to analyze the proposed project and provide any comments they might have on the adequacy of the environmental document. The prepared responses to comments are intended to provide complete explanations to the commenters and to improve the overall understanding of the project. POLB originally circulated a Draft IS/ND for the proposed project for a 30 -day public review period from October 7, 2020 through Novem- ber 5, 2020, but extended the public review period to 45 days, ending on November 20, 2020. During the 45-day public review period, POLB received 20 comment letters from a total of 8 agencies, groups/organizations, and individuals. This section provides responses to the comments received and has been organized by assigning each commenter a letter code based on the name of commenter or affiliation (e.g., California Department of Transportation, District 7 is given the letter code “CADOT”). An abbreviation for the name of the organization is used if the commenter is represented by a law firm.

Comments received are bracketed and numbered and are referred to by the Commenter Letter Code and Response Number. Each comment letter is followed by POLB’s written responses to the comments in that letter. Due to the size of the attachments referenced and submitted in the Comment Letters from Earthjustice (EJ) and Safe Fuel and Energy Resources California (SAFERCA), the attachments are not included in this section, however, are available online on the POLB website at https://www.polb.com/ceqa. The comments received did not result in any substantive modifications to the analyses in the IS/ND. The following table lists commenters that submitted written comments on the IS/ND.

Commenter Letter Code Comment Codes Date
Agencies
California Coastal Commission CCC CCC-1 to CCC-2 November 20, 2020 California Department of
Transportation, District 7 CADOT CADOT-1 to CADOT-3 October 22, 2020 City of Paramount CP CP-1 October 27, 2020
Organizations
Citizens Coalition for a Safe
Community CCSC CCSC-1 to CCSC-15
October 11, 2020 (3)
October 15, 2020 (2)
October 28, 2020
October 29, 2020
Earthjustice, et al. EJ EJ-1 to EJ-51
October 20, 2020
November 20, 2020
March 16, 2021
Gabrieleno Band of Mission
Indians – Kizh Nation GBKN GBKN-1 October 28, 2020
Safe Fuel and Energy Resources
California SFERCA SFERCA-1 to SFERCA-43
October 8, 2020
October 9, 2020 (2)
October 29, 2020
November 20, 2020
Individuals
Dianne Flowers DF DF-1 to DF-2 November 20, 2020

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CCC – California Coastal Commission

CCC-1
CCC-2

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Response to Comments – CCC
California Coastal Commission
Dani Ziff, Coastal Planner
November 20, 2020
Response to Comment CCC-1
The comment provides introductory text to describe the California Coastal Commission’s understanding of the project, and states that pursuant to Coastal Act Section 30715(a)(1), the proposed Project ’s harbor/coastal development permit may be appealable to the Coastal Commission. The comment also states that a Port Master Plan (PMP) amendment would be required if the proposed development is not currently contemplated in the certified PMP pursuant to Coastal Act Section 30711.

California Coastal Act (CCA) Section 30715(a)(1) is specific to “developments for the storage, transmission, and processing of liquefied natural gas and crude oil in such quantities as would have a significant impact upon the oil and gas supply of the state or nation or both the state and nation.” The proposed Project would construct two new petroleum storage tanks to support existing operations at the World Oil Terminal by increasing the efficiency of terminal operations and allowing more tanks to be avail able for lease by third-party vendors. As described in Section 5.1.2 (Chapter 8 of CCA), t he relatively small size of the proposed storage tanks (i.e., 25,000 bbl) would not have a significant impact on State or national oil and gas supply. The U.S. produced around 10-12 million bbl per day of crude oil and 80 -100 billion cubic feet per day of natural gas between 2018 and 2020 (EIA, 2021a). California produced 10-14 million bbl per month of crude oil (EIA, 2021b) and 10-17 million cubic feet per month of natural gas between 2018 and 2020 (EIA, 2021c). In addition, World Oil Corporation primarily recycles oil- based waste including used motor oil, antifreeze, and oily wastewater. The waste is then recycled into motor oil, marine diesel fuel, new antifreeze, and paving and roofing asphalt blending components. The asphalt blending components are used at the World Oil Refinery in South Gate, California. As such, World Oil is providing a service to the oil and gas industry as opposed to being a producer or refiner of crude oil or natural gas.

As described in IS/ND Section 2.11 (Operations and Maintenance), t he proposed Project w ould not debottleneck the facility to allow for greater actual crude throughput beyond the permitted limits through the existing pipelines, tanks, or loading racks. The proposed Project would provide additional petroleum storage capacity, but that would not affect local refinery operations. Refinery processing capacities are constrained by many factors including equipment design capacity, permit conditions, firing rates for combustion sources, and maintenance schedules of the various operating units within a refinery. Refinery processes are not influenced by storage capacity. As such , the proposed Project would have little to no impact on the oil and gas supply of the state or nation and is not appealable under CCA Section 30715(a)(1).

The World Oil Terminal is a privately-owned terminal which was built in 1964, prior to the establishment of the CCA and the adoption and certification of the POLB’s initial PMP. The PMP was first adopted and certified in 1978. It was under this PMP that the Project area was termed the Northeast Harbor District and its permitted uses were designated to Primary Port, Petroleum Import/Export, Port -related, and Oil Production. Petroleum Import/Export was defined as “operations and terminals engaged in the loading/unloading, storage and transfer of crude, and bulk refined petroleum products”. The 1983 certified PMPU replaced the term “Petroleum I mport/Export” with “Hazardous Cargo Facility ,” but the definition remains similar . “Hazardous Cargo Facility” continues to be a permitted use in the current certified 1990 PMPU. Therefore, the proposed Project would not require an amendment to the certified World Oil Tank Installation Project
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1990 PMPU as it would be located within an area of the Port (i.e., Northeast Harbor) that allows hazardous cargo facilities and oil production as permitted uses (see IS/ND Section 5.2.1, Consistency with the Port Master  Plan).  As  described  in  IS/ND  Section  2.9  (Project  Overview),  the  proposed  Project  would  be constructed entirely within the exis ting World Oil Terminal and would serve to realign storage capacity and improve efficiency of the terminal’s current operations. The proposed Project would be compatible with the site’s existing land use and would be allowable under the Northeast Harbor’s permitted uses identified in the 1990 certified PMPU. A PMP amendment would not be required for the proposed Project.

Response to Comment CCC‐2
This comment requests that the IS/ND address the potential for flooding impacts to be exacerbated by future sea level rise (SLR). This comment also suggests that the proposed Project be assessed using best available science for a medium‐high/extreme sea level rise scenario.

In  2016,  the  POLB  completed  a  Port‐wide  Climate  A daptation   and  Coastal  Resiliency  Plan  (CRP)  which draws on the best available data on climate science and the potential effects in California (data as of April 2016).  The  CRP  relied  heavily  on  California  Climate  Change  Center,  a  division  of  the  California  Energy Commission’s  Third  Assessment  on  the  science  of  climate  ch ange,   the  California  Natural  Resource Agency’s 2009 California Adaptation Strategy, peer‐reviewed publications from the U.S. Global Change Research  Program,  and  other  research  organizations.  Based  on  the  findings  of  the  reports  and publications, the POLB selected a 16‐inch, 36‐inch, and 55‐inch SLR inundation scenarios – including each under daily hi
gh tide and extreme tide and 100‐year storm event to analyze potential future impacts. The 36‐inch sea level rise scenario plus 100‐year storm surge was selected as the most appropriate scenario (medium‐high) to analyze for developments with an expected life ending in year 2070 (50‐year lifespan) and the most‐likely projection for th
e year 2100. A discussion of the CRP has been added to the IS/ND Section 4.10(d) (Hydrology and Water Quality).

Under the medium‐high SLR scenario the proposed Project’s site could experience temporary inundation of zero to 4 feet by year 2070 (2016 CRP). The CR P’s SLR medium‐high estimation aligns with the Ocean Protection Council’s 2018 State of California’s Sea‐Level Rise Guidance (OPC  Guidance) medium‐high risk SLR estimations for projects with an expected life ending in year 2070 (OPC, 2018). The OPC Guidance states  that  in  the  medium‐high  risk  sce nario,  there  is  a  1‐in‐200  chance,  or  0.5%  probability,  that  SLR meets or exceeds an estimated inundation of approximately 2.9 to 3.3 feet by year 2070 (OPC, 2018).

Under the most extreme SLR projection (55‐inch plus 100‐year storm surge) the proposed Project could experience zero to 6 feet of temporary inun dation by 2070 (POLB, 2016a).

As  stated  in  IS/ND  Section  2.9  (Project  Description),  the  proposed  tanks  would  be  constructed  and installed within the existing reinforced concrete containment wall that varies between approximately 12.5 to 13‐feet in height and wall thickness tapering from approximately 1.5 feet wide at the base to 1 foot wide  at  the  top.  Although  the  fa
cility  may  experience  temporary  inundation  under  a  medium‐ high/extreme SLR scenario, the potential for flooding impacts to be exacerbated by sea level rise in the future is less than significant due to the size of the existing containment wall .  Also,  as noted in IS/ND Section 4.10(d) (Hydrology and Water Quality), air driven pumps may be used to divert water over the containment  wall  during  a  flood  event.  With  the  infrastructure  protection  provided  by  the  existing containment wall and air driven pumps, the proposed Project would not create a new significant impa ct from sea level rise.

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CADOT – California Department of Transportation, District 7

CADOT-1
CADOT-2

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CADOT-2,
cont.

CADOT-3

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Responses to Comments – CADOT
California Department of Transportation, District 7
Miya Edmonson, IGR/CEQA Branch Chief
October 22, 2020

Response to Comment CADOT-1
The comment includes introductory remarks and summarizes Caltrans’ understanding of the proposed Project. No further response is required.

Response to Comment CADOT-2
The comment provides Caltrans’ mission statement and references Senate Bill 743 which mandates use of Vehicle Miles Traveled (VMT) as the primary metric in identifying transportation impacts from automobiles under CEQA. The comment also refers to the Governor’s Office of Planning and Research for CEQA updates, the Caltrans VMT-focused Transportation Impact Study Guide (TISG), dated May 20, 2020, and the Caltrans Interim Land Development and Intergovernmental Review Safety Review Practitioners Guidance, prepared in July 2020, for traffic impact analysis guidance and information. As described in Section 4.17(b) Transportation) the proposed Project’s potential transportation impacts were reviewed per State CEQA Guidelines Section 15064.3(b)(3) and the City of Long Beach SB 743 Implementation Plan, and is recognized to cause a less than significant impact. The comment confirms that the proposed Project would have no permanent effect on the existing VMT in the Project area. The POLB will continue to refer to the State CEQA Guidelines and Caltrans’ TISG for the use of VMT as the metric for analysis of automobile traffic for future projects.

Response to Comment CADOT-3
The comment states that if the proposed Project requires the use of oversized-transport vehicles on State highways, then a Caltrans transportation permit would be required. As described in Section 4.17 (Trans - portation), the proposed Project may require oversized truck trips to deliver large construction equipment and materials to the site. If needed, all required permits would be obtained by the Applicant and/or their contractor from Caltrans and local jurisdictions. Construction -related trips may occur during peak commute periods, but on average, trips would avoid peak commute periods to the maximum extent feasible and would occur temporarily during construction.

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CP – City of Paramount

CP-1

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Response to Comments – CP
City of Paramount
John Carver
Planning Director
October 27, 2020
Response to Comment CP-1
The comment expresses concern regarding increased trucking to the World Oil Refinery in South Gate, specifically the resulting increases in air quality emission in the region. The comment also inquires about plans the POLB has to require alternatives to diesel trucks as part of this project and funding opportunities to 710-adjacent cities for resident education regarding Port impacts and mitigation.

The proposed Project adds two additional petroleum storage tanks within the existing World Oil Terminal at t he POLB. As described in the Section 2.11 (Operations and Maintenance), truck trips are not anticipated to increase as a result of the proposed Project , however, as a conservative, worst-case assumption to account for atypical operations such as when a pip eline is out of service, a 10 percent increase (or three additional trucks) in truck trips is assumed. Diesel-fueled trucks were assumed in the analysis, and as shown in the air quality emissions estimate in IS/ND Appendix A and the results in Table

4.3-2, the emissions from on-road heavy-duty trucks and overall emissions from the proposed Project are well below the South Coast Air Quality Management District’s regional significance thresholds, nor would the proposed Project result in impact to traffic. As such, mitigation measures are not required or proposed for the proposed Project. Also, please see Response to Comment DF-3 regarding general air quality in the Port area and how it has improved over the past few decades.

The POLB, recognizing that its environmental impacts have had years to accumulate, and even the POLB’s strategic and aggressive mitigation efforts do not fully address the cumulative effects of Port operations on neighboring communities, established the Community Grants Program in March 201 7, allocating an initial $46.4 million funding amount for an implementation period of 12 to 15 years for three specific programs for community -based mitigation projects that alleviate or reduce impacts from port-related activities: Community Health, Facility Improvements and Community Infrastructure. The Facility Improvements and Community Infrastructure categories provide funding for capital projects to reduce impacts from air pollution. The Community Health category provides funding to support health proj ects and services designed to reduce the risks associated with asthma and other respiratory and/or cardiopulmonary ailments. These services may include screening and diagnosis, case management, education, training community health workers or medical personnel, and outreach.

The POLB is limited by the public trust doctrine on how and where its public trust revenues are spent.

Within the confines of these limitations, the California State Lands Commission advised the Port that trust revenues can only be used to mitigate Port impacts to the surrounding communities, over and above mitigation required by law, such as CEQA, if certain conditions are met. In 2016, the P OLB completed a Community Impact Study in the areas of air quality, traffic noise, and water quality through a CEQA -like analysis that used quantitative and qualitative, industry -accepted technical methodologies to demonstrate a connection between Port operations, impacts to local communities, and possible way to mitigate those impacts. (POLB, 2016b).

Based on the Community Impact Study, the Community Grants Program and Investment Plan identified the geographic areas most affected by Port -related operations and in which to direct Community Grants Program investments. These geographical areas, which include the entire City of Long Beach, are divided

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into two zones for grant funding: the “Priority Zone” and the “Eligibility Zone”. T he entire City of Long Beach and communities in parts of Wilmington in the City of Los Angeles, Carson, Compton, and Paramount fall within these two zones. The Eligibility Zone extends from the POLB along the I -710 north to portions of Paramount and Compton. The Eligibility Zone is the area in which significant Port impacts have been identified, and at minimum, mitigation projects must take place within. The Priority Zone is a subset of the Eligibility Zone and experiences the highest community impact from Port-related operations.

The POLB intends to invest the majority of mitigation dollars in the Priority Zone, which includes portions of Long Beach, Wilmington in the City of Los Angeles, Carson, Compton, and Paramount; as such, projects in this zone will receive the highest consideration during the evaluation process. Funding is also prioritized for mitigation projects that benefit sensitive populations, which include children, pregnant women, the elderly, the chronically ill, and those with respiratory or other cardiopulmonary conditions (POLB, 2016b).

Figure 8-1. shows the current delineati on of the Priority and Eligibility Zones for the Community Grants Program.

Through the Community Grants Program, the P OLB coordinates with local residents and communities to foster communication and collaboration to address community needs. Within this program, community groups, government agencies, and non -profit organizations are encouraged to submit applications for grant funding. Public workshops and focus groups are regularly conducted to define long-range funding priorities and provide input to annual Community Grants Program budgets. Briefings on the status of the Community Grants Program are presented at the P OLB’s public board meetings. Community leaders and citizens are invited to attend these meetings and provide input on the program. To date, through the Community Grants Program the POLB has provided $31.1 million in funding for the development of public parks, water quality improvements, LED lighting, healthcare programs, facility -based energy efficiency projects, trees and landscaping, solar panels, electric vehicles, air filtration, and noise abatement measures.

The City of Paramount is encouraged to learn more about the Community Grants Program by going to www.polb.com/grants for more information on applicant workshops, applications, and deadlines; or contact the POLB by e-mail ([email protected]) or by telephone at (562) 283-7133.

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Figure 8-1. Community Grants Program Priority and Eligibility Zones

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CCSC – Citizens Coalition for a Safe Community

CCSC-1
CCSC-3
CCSC-2

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CCSC-7
CCSC-6
CCSC-5
CCSC-4

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CCSC-11
CCSC-10
CCSC-9
CCSC-8

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CCSC-12

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CCSC-13
Attachment 2: 1947 crpd.tif Attachment 1: 1928 crpd.tif

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CCSC-14

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CCSC-14,
cont.

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CCSC-15

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CCSC-15,
cont.

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Response to Comments – CCSC
Citizens Coalition for a Safe Community
Dr. Tom Williams, Ph.D., UC Berkeley 1976
Senior Technical Adviser
October 11, 15, 28, and 29, 2020

Response to Comment CCSC-1
The comment requests a revision of the Initial Study to support a Mitigated Negative Declaration or Environmental Impact Report/Environmental I mpact Statement . The commenter does not provide rationale or basis that would require a revision to the IS/ND. No further response is required.

Nevertheless, the Port provides the following response: Per CEQA Guidelines, Article 5, Section 15063(b)(2), an Initial Study was prepared to evaluate the potential effects of the proposed P roject and potential growth -inducing or cumulative effects of the proposed Project in combination with other projects. The Initial Study concluded that the proposed Project would not result in any significant effects on the environment and no mitigation measures are required ; therefore, a Negative Declaration was prepared.

Response to Comment CCSC-2
The comment refers to information provided in the Notice of Intent issued by the Port on October 7, 2020; no comment or question about the Draft IS/ND is apparent, therefore, no response is necessary.

Response to Comment CCSC-3
The comment requests the complete Albus -Keef & Associates Geotechnical Update Report (2018) referenced in the Draft IS/ND and any preceding or related reports. On October 15, 2020, Jennifer Blanchard, Port Environmental Specialist Associate, provided the requested files via the Port’s MOVEit File Transfer Protocol (FTP) site ([email protected]). Dr. Williams confirmed receipt of the referenced files via email on the same day.

Response to Comment CCSC-4
The comment requests access to all referenced materials in the IS/ND and Sec. 7 p.7 -3 Matrix (Matrix PDM Engineering). 2019. API 650 Foundation Design Drawings. Sheet 3 of 3: Foundation Notes. World Oil. January 18. On October 15, 2020, Jennifer Blanchard, Port Environmental Specialist Associate, provided the requested files via the Port’s MOVEit FTP site ([email protected]). Dr. Williams confirmed receipt of the referenced files via email on the same day.

Response to Comment CCSC-5
Please see Response to Comment CCSC-1, as it is a duplicate comment.

Response to Comment CCSC-6
Please see Response to Comment CCSC-2, as it is a duplicate comment.

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Response to Comment CCSC-7
Please see Response to Comment CCSC-4, as it is a duplicate comment.

Response to Comment CCSC-8
The comment requests access to all referenc es mentioned in the IS/ND, specifically requesting the Environmental Data Resources (EDR) Radius Map Report with Geocheck – World Oil Terminals Long Beach dated March 2020. On October 15, 2020, Jennifer Blanchard, Port Environmental Specialist Associate, provided the requested files via the Port’s MOVEit FTP site ( [email protected]). Dr. Williams confirmed receipt of the referenced files via email on the same day.

Response to Comment CCSC-9
Please see Response to Comment CCSC-1, as it is a duplicate comment.

Response to Comment CCSC-10
Please see Response to Comment CCSC-2, as it is a duplicate comment.

Response to Comment CCSC-11
Please see Response to Comment CCSC-8, as it is a duplicate comment.

Response to Comment CCSC-12
In the email message, the commenter states “Then happy to have done this today” and referenced a Fairchild Aerial Photo from 1923, which was also provided as an attachment to the email message. There are no apparent comments on the Draft IS/ND. Therefore, no response is required.

Response to Comment CCSC-13
In the email message, the commenter provides the years, 1928 and 1947. Two black and white photos were attached to the email. No further response is required.

Response to Comment CCSC-14
The comment requests access to the references in Draft IS/ND Section 7 (References) and identifies clarifications needed for the listed references. On October 15, 2020, Jennifer Blanchard, Port Environmental Specialist Associate, provided the requested refer ences via the Port’s MOVEit FTP site ([email protected]). Dr. Williams confirmed receipt of the referenced files via email on the same day.

The POLB also reviewed the comment’s regarding references requiring revision and made the requested clarifications to the references in Section 7 (References), where applicable in the Final IS/ND.

Response to Comment CCSC-15
The comment includes introductory text and states that the Negative Declaration is inadequate, incomplete, and that many referenced documents are not readily available to the public. The commenter requests revision and recirculation of the document as a Mitigated Negative Declaration with readily accessible references. Please refer to Response to Comment CCSC-14. The commenter does not raise any specific environmental concerns or provide rationale as to why a Mitigated Negative Declaration would

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be more appropriate than a Negative Declaration, and as such, no further revisions or recirculation of the IS/ND is necessary. See also Response to Comment CCSC-1.

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EJ – Earthjustice

EJ-1
EJ-2
EJ-3

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EJ-4
EJ-5

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EJ-6
EJ-5
cont.

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EJ-6
cont.

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EJ-6
cont.

EJ-7

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EJ-7
cont.

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EJ-8
EJ-9

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EJ-9
cont.

EJ-10

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EJ-10
cont.

EJ-11
EJ-12

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EJ-12
cont.

EJ-13

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EJ-13
cont.

EJ-14

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EJ-15
EJ-14,
cont.

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EJ-15
cont.

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EJ-16

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EJ-17
EJ-16
cont.

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EJ-17
cont.

EJ-18

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EJ-19
EJ-18,
cont.

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EJ-19,
cont.

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EJ-19
cont.

EJ-20

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EJ-22
EJ-21

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EJ-22,
cont.

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EJ-22,
cont.

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EJ-23
EJ-22,
cont.

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EJ-24
EJ-23,
cont.

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EJ-25
EJ-26
EJ-24,
cont.

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EJ-26,
cont.

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EJ-29
EJ-30
EJ-27
EJ-28

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EJ-30
cont.

EJ-31
EJ-32

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EJ-32
cont.

EJ-33
EJ-34

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EJ-34
cont.

EJ-35

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EJ-36

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EJ-36
cont.

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EJ-36
cont.

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EJ-36
cont.

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EJ-36
cont.

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EJ-36
cont.

EJ-37

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EJ-37
cont.

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EJ-37
cont.

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EJ-37
cont.

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EJ-37
cont.

EJ-38

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EJ-38
cont.

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EJ-38
cont.

EJ-39

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EJ-39
cont.

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EJ-39
cont.

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EJ-39
cont.

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EJ-39
cont.

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EJ-39
cont.

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EJ-39
cont.

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EJ-39
cont.

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EJ-39
cont.

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EJ-40

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EJ-40
cont.

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EJ-40
cont.

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EJ-43
EJ-40
cont.

EJ-41
EJ-42

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EJ-43
cont.

EJ-44
EJ-45
EJ-46

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EJ-47
EJ-48

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EJ-48
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EJ-48
cont.

EJ-49

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EJ-49
cont.

EJ-50

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EJ-51

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Response to Comments – EJ
Earthjustice
Kartik Raj, Oscar Espino-Padron, Lisa Fuhrman, Adrian Martinez – Earthjustice Lauren Packard – Center for Biological Diversity
Chris Chavez – Coalition for Clean Air
Jennifer Ganata – Communities for a Better Environment
Taylor Thomas – East Yard Communities for Environmental Justice October 20, November 20, 2020, and March 16, 2021

Response to Comment EJ-1
The comment requests a 14-day extension for the public review period to end on November 19, 2020.

The 30-day public review period for the Draft IS/ND began on October 7, 2020, was originally set to end on November 5, 2020. On October 28, 2020, based on comments received, the public review period was extended by 15 days ending on November 20, 2020, for a total of 45 days.

Response to Comment EJ-2
The comment summarizes Earthjustice’s understanding of the proposed P roject and the purpose of Earthjustice’s request for an extension of the public review period. No further response is necessary.

Response to Comment EJ-3
Please refer to Response to Comment EJ-1.

Response to Comment EJ-4
The comment contends that the IS/ND prepared by the Port fails to account for substantial evidence that the Project may have significant envi ronmental effects, and that the IS/ND reveals multiple significant procedural defects that violate established guidelines for CEQA Review. Please see the Responses to Comments EJ-6 through EJ-51.

Response to Comment EJ-5
The comment references substantial technical analysis and other evidence demonstrating that issuance of a negative declaration for the Project would be scientifically unsupported an d in violation of CEQA. To the extent comments on the Draft IS/ND are raised in the supporting documents, responses are provided to the comments. Please see the Responses to Comments EJ-6 through EJ-51.

Response to Comment EJ-6
The comment states that the IS/ND violates CEQA procedural requirements since the Project received a permit to construct from the SCAQMD for the two new tanks months prior to completion of the IS/ND.

Since preparation of the Draft IS/ND, by POLB as the lead agency pursuant to CEQA in October 2020, World Oil’s permits to construct for the two new tanks issued by the SCAQMD in January 2020 lapsed, requiring World Oil to submit a new application for a permit to construct/operate for the two new proposed tanks.

In consultation with SCAQMD, World Oil has submitted a new permit application for the two proposed tanks. The POLB coordinated and consulted with the SCAQMD (a responsible agency under CEQA) as part

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of the IS/ND process. The new permits to construct will not be issued by the SCAQMD until after the IS/ND is adopted, the Project is approved, and a Harbor Development Permit is issued by the Board of Harbor Commissioners. This coordination and submittal of a new permit application to the SCAQMD address es issues related to the SCAQMD stationary source permitting requirements, including but not limited to the following:
 Tank emissions calculations,
 Fugitive VOC emissions calculations,
 Hydrogen sulfide (H2S) emissions and health risk, and  Benzene emissions and health risk.

Response to Comment EJ-7
The comment states that the Draft IS/ND does not indicate whether the POLB consulted with SCAQMD, a responsible agency, or CDFW, a trustee agency, and therefore, the POLB failed to consult with these agencies to seek their recommendations as required by CEQA.

In parallel with submitting the Application for Harbor Development Permit to the P OLB, World Oil submitted an initial Permit to Construct/Permit to Operate Application for the two additional storage tanks at the existing World Oil Terminal to SCAQMD. The POLB reviewed this information as part of the Draft IS/ND process. Additional consu ltation with agencies , including CDFW, occurred through the publication and request for agencies, organizations, and the public to review of the Draft IS/ND, which occurred between October 7, 2020 and November 20, 2020 (original review period was October 7 – November 5, 2020; extension to November 20, 2020 was issued on October 28, 2020).

The Notice of Intent to Adopt and Availability of a Draft IS/ND was sent to responsible agencies, trustee agencies, interested parties, organizations, and the public pursuant to Section 21092 and 21092.3 of the Public Resources Code and State CEQA Guidelines Section 15072. Furthermore, as shown in IS/ND Section

2.12 (Other Permits and Approvals), Table 2-5, the SCAQMD is identified as an agency from which permits are requi red. While CDFW is not identified as a permitting agency, as either no impacts or less than significant impacts to biological resources would occur, CDFW was notified as part of the notification process for the Draft IS/ND. To further support notification, the Governor’s Office of Planning and Research, State Clearinghouse, CEQANet Web Portal documents the notification process completed by the State Clearinghouse and lists agencies notified. The Air Resources Board and CDFW are listed as reviewing agencies, among others ( https://ceqanet.opr.ca.gov/2020100119/2). Additionally, as part of the review process, the POLB provided detailed air quality calculations, including all source files, to the SCAQMD to facilitate their review process. No comments were receiv ed from SCAQMD or CDFW on the Draft IS/ND.

As part of the process in preparing responses to comments on the Draft IS/ND and to further engage the SCAQMD as a responsible agency for the permits to construct for the new tanks , the POLB and World Oil completed additional consultation with SCAQMD prior to finalization of the IS/ND. As a result of this consultation process, World Oil submitted a new Permit to Construct/Permit to Operate Application to SCAQMD in February 2021, as the previous permits to construct issued by the SCAQMD in January 2020 had expired (SCAQMD, 2021a).
2 The new permit application is currently under review by the SCAQMD

2 SCAQMD Rule 205 Expiration of Permits to Construct states “A permit to construct shall expire one year from the date of issuance unless an extension of time has been approved in writing by the Executive Officer”.

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pending completion of the CEQA process. The POLB’s consultant , Aspen Environmental Group air quality specialist and registered professional (chemical) engineer, Mr. Will Walters reviewed the calculations and coordinated with SCAQMD to ensure adequacy for their use in the IS/ND, as the SCAQMD is a responsible agency under CEQA for the issuance of permits to construct for the proposed new tanks . As part of the CEQA consultation process, POLB staff and SCAQMD staff also held a conference call on January 19, 2021 to discuss th e proposed P roject and comments received on the Draft IS/ND . Mr. Walters has also had communication with the SCAQMD permitting engineer. Based on this additional consultation and in response to comments received from agencies, organizations, and the public , the Draft IS/ND has been revised and finalized and a Notice of Intent to Adopt a Negative Declaration issued in accordance with State CEQA Guidelines Section 15072.

Response to Comment EJ-8
The comment states that it is unclear if the Draft IS/ND properly identified and consulted with all responsible and trustee agencies, and the Notice of Intent and other documents provided to the public do not list the SCAQMD and CDFW, or any other responsible and trustee agencies. The comment concludes that this inadequate information suggests that these agencies did not receive sufficient notice of the Draft IS/ND. Please refer to Response to Comment EJ-7.

Response to Comment EJ-9
The comment states that the proposed Project’s VOC and benzene emissions are grossly underestimated due to the new tank emissions being estimated by the United States Environmental Protections Agency (U.S. EPA ) TANKS model. The comment further quotes information from the SCAQMD sponsored “FluxSense study” and Journal of Air & Waste Management ( JAWM) article to indicate potential magnitudes of this underestimate.

SCAQMD is the responsible agency for the assessment and approval of the emissions estimate s for the issuance of the permits to construct/operate for the proposed Project’s n ew tanks. As part of their engineering review of the new permit application, SCAQMD completed a revised emissions estimate for the proposed Project’s tanks using the current USEPA AP -42 Section 7.1 Organic Liquid Storage Tanks (USEPA, 2020) methodology, as suming a Gasoline Reid Vapor Pressure (RVP) of 10, “average” paint condition, and August as the maximum monthly emissions (SCAQMD, 2021b, 2021c ). The TANKS model was not used by SCAQMD to estimate emissions for th e proposed P roject. Fugitive emissions from components were also included. Final IS/ND Section 4.3 (Air Quality), Table 4.3 -2, has been updated to reflect the updated operation emission estimate prepared by SCAQMD as part of its review of World Oil’s new permit to construct/permit to operate application for the new tanks.

A similar comment regarding the “Fluxsense study” was made on another recent petroleum tank project’s Title V Significant Permit Revision under the permitting authority of the SCAQMD (SCAQMD, 2020c) .

SCAQMD referred the POLB to the comment response it provided in June 2020 on this comment issue, which is still considered valid, relevant, and usef ul. Therefore, the POLB is providing that SCAQMD comment response again, slightly modified in the context of World Oil’s proposed Project.

The permits will require that the crude oil storage tanks will be properly maintained and kept in good operating conditions at all times. Additionally, three South Coast AQMD rules are applicable to the crude oil storage tanks which specifically focus on reducing VOC emissions from storage tanks and fugitive components. In particular, South Coast AQMD Rules 463 - Organic Liquid Storage and 1178 - Further Reductions of VOC Emissions from Storage Tanks at Petroleum

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Facilities require semi-annual inspection of the rim seals (primary and secondary) of the floating roof, and deck fittings (e.g., roof leg socks, guide pole and float, hatches, vacuum breakers, and roof drains) and monitoring for VOC emissions in the space inside the dome above the floating roof. If a defect is found, the tank must be repaired within 72 hours of discovery. In addition, South Coast AQMD Rule 1173 - Control of Volatile Organic Compound Leaks and Releases from Components at Petroleum Facilities and Chemical Plants requires fugitive components to be monitored on a quarterly basis. If a leak is detected in a fugitive component, repairs must be made within one to seven calendar days, depending on the severity of the leak. Because the storage tanks are required to comply with BACT, the monitoring requirements of the permits will be more stringent than Sou th Coast AQMD Rule 1173. For example, the pumps, valve, and flanges associated with the proposed crude oil storage tanks are required to be initially monitored monthly, which is more stringent than the quarterly monitoring required by South Coast AQMD Rule 1173. The BACT monitoring requirements will be included in a permit condition for the crude oil storage tanks.

U.S. EPA has not approved the use of solar occultation flux data (as used in the FluxSense study) in lieu of AP -42 emissions factors for air qua lity permitting or any other regulatory purpose. By contrast, the process for adopting AP -42 emissions factors used in the Tanks model is quite detailed, based on empirical measured data evaluated by the U.S. EPA and circulated for a 60-day public comment period before being finalized.

The FluxSense study, referenced in the comment, was not specific to a single source such as a tank, but instead was a research study designed for assessing facility-wide emissions over a limited time- period (only several days). The study also assessed emissions from a tank farm (i.e., a group of tanks) at the refinery over an eight- day period. South Coast AQMD is currently conducting additional work using FluxSense technology and determining appropriate uses for it. Also, emission estimates of an entire refinery or even a tank farm are not representative of individual pieces of equipment and cannot be used to calculate emissions from a specific tank let alone be used to permit that tank that has not yet been constructed. The FluxSense study was an initial effort by South Coast AQMD to improve understanding of optical remote sensing methods to quantify VOC, NO 2, and SO 2 emissions and inferred benzene emissions from equipment for informational and potential future monitoring purpo ses. Its methodology is not suited for estimating potential future emissions from specific tanks or discreet fugitive sources because it is not capable of establishing emission factors for specific pieces of equipment.

The South Coast AQMD continues to evaluate this emerging technology and is involved in ongoing research projects to measure facility -wide emissions at all major refineries in the South Coast Air Basin on a quarterly basis (i.e. winter, spring, summer, fall) to understand seasonal variations in measurements. Optical Remote Sensing will also be used to measure emissions to establish baseline emissions of all refineries for purposes of the AB 617 Community Emission Reduction Plan for the Wilmington/Carson/West Long Beach community. As the South Coast AQMD continues to use this technology, we will also continue to consider how it can best be applied to refinery operations. But at this time, it is not ready to be used to establish emission limitations in a permit or to include permit conditions requiring its use for monitoring and enforcement.

The comment quotes a JAWM article. Th is JAWM article refers to a study conducted in Houston, Texas at a petroleum refinery/chemical plant comple x using Differential Absorption Light Detection and Ranging (DIAL). While not included in the quote, the JAWM article describes factors

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which create DIAL -based emissions rate uncertainties such as potential failures to accurately characterize the wind field. The Houston, Texas study included three tank sets (Tanks Sets 5, 6, and 9), all containing crude oils. The tanks were described as external floating roof tanks without any details about age, color, condition, number and type of fittings, or whether each tank is heated/unheated. In Emission Estimation Protocol for Petroleum Refineries, Version 3, April 2015, U.S. EPA states: “There are other direct measurement methods that have been used to measure emissions from storage tanks even when the emissions from the tank are not vented [i.e., DIAL (Differential Absorption LIDAR) techniques]; however, these methods do not provide continuous monitoring and have additional limitations (requiring consistent wind direction, etc.). Therefore, at the present time they a re not recommended as primary techniques for annual emission estimation.” Thus, while DIAL is another promising technology to measure VOC emissions, the Houston, Texas study information is not germane to the South Coast AQMD permitting process and to crude oil storage tanks in general or to the crude oil storage tanks in the proposed Title V permit. The new crude oil storage tanks in the proposed permit will be state -of-the-art, BACT - compliant, internal floating roof tanks.

Therefore, the U.S. EPA -approved AP-42 Section 7.1 emissions calculations were used by SCAQMD to complete the operations emissions estimate for the proposed P roject. The Fluxsense Study was not designed to be used for new tanks emissions estimating purposes and is not used by SCAQMD or any other air quality permitting agency for the purpose of new tank permit emission estimating.

Response to Comment EJ-10
This comment states that the IS/ND analysis of VOC localized impacts on sensitive receptors is incomplete and flawed b ecause it uses incorrect emissions thresholds and an incomplete health risk assessment completed by SCAQMD that does no t evaluate other significant health risks posed by VOC emissions including the formation of ground level ozone. Additionally, this comment notes that the POLB’s estimates of the proposed P roject’s VOC emissions are underestimated due to use of an unreliable methodology (i.e., U.S. EPA TANKS model), as previously noted in Comment EJ-9.

Both the health risk assessment associated with tank operation emissions, and the health risk analysis in the IS/ND for the Project -related construction activity emissions, were prepared in accordance with California Air Resources Board (CARB), Office of Environmental Health Hazard Assessment (OEHHA), and SCAQMD recommended methods and guidelines . The health risks associated with emissions from the proposed tanks were determined by identifying and analyzing the risk of the known air toxic air contaminants emissions that are part of the total tank VOC emissions.

The ozone precursor (VOC) emissions increase of 10.93 lbs/day associated with the proposed Project’s operations (IS/ND Table 4.3 -2, p. 4 -10) is less than 0.0024 percent of CARB’s 2020 VOC (as Reactive Organic Gases [ROG]) emissions estimate for the Los Angeles County portion of the South Coast Air Basin, and the Project’s estimated operation NOX emissions increase of 0.81 lbs/day is less than 0.00022 percent of CARB’s 2020 NO X emissions estimate for the Los Angeles County portion of the South Coast Air Basin (CARB, 2016). Therefore, the proposed Project would not create any numerically relevant direct increases in near -field ozone concentrations. Additionally, there are no agency -recommended methods or procedures to address direct health impacts from Project-level near-field ground level ozone impacts. As noted for the proposed Project, ground level ozone health impacts would be negligible.

Please also see the Responses to Comments EJ-6 and EJ-9.

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Response to Comment EJ-11
This comment states that the IS/ND did not analyze hydrogen sulfide (H2S) emissions from the new crude oil tanks and did not evaluate the proposed P roject’s H2S emissions impacts , including the cumulative impacts considering the Project area’s numerous other H2S emissions sources.

Crude oil can contain a substantial amount of total sulfur, several percent by weight; however, most of this sulfur is bound to carbon atoms and crude oil does not normally contain a large amount of dissolved H
2S. World Oil’s new permit application for the two new tanks provides an assay value for the crude of

3.5 ppm H2S and provides an emissions and risk estimate for H 2S emissions. The POLB coordinated with the SCAQMD to determine the adequacy of the H2S emissions estimate and impacts assessment contained in World Oil’s revised permit to construct/permit to operate application for the proposed new tanks .

SCAQMD performed independent calculations assuming a worst-case of 3 percent sulfur as H2S from the SDS Gas Oil, Virgin Tesoro product and August emissions due to warmer temperatures (SCAQMD, 2021b, 2021c). The annual H2S emissions are determined to be low (0.0116 pounds per year), and the combined air toxics emissions health risk is well below SCAQMD significance thresholds (SCAQMD, 2021b, 2021c).

The IS/ND Section 4.3 (Air Quality) has been updated to include the emissions estimate and impact assessment for H 2S emissions (checklist item b. discussion, just under Table 4.3 -2), including providing additional H2S emissions odor impact evaluation (checklist item d. discussion). The proposed Project’s H2S emissions would not create significant project-level or cumulative impacts.

Response to Comment EJ-12
The comment states that it is unclear if the 10 percent increase in truck trips includes truck trips anticipated to transport maintenance and waste materials and for refinery crude balancing. IS/ND Section

2.11 (Project Description), Section 4.3 (Air Quali ty), and Section 4.17 (Transportation) have been revised to clarify that the crude oil balancing is expected to remain the same (approximately one truck per month) with implementation of the proposed Project. The 10 percent increase in truck trips has been analyzed as a worst -case scenario for the purposes of the CEQA analysis and represents an atypical operation condition when, for example, a pipeline is out of service.

Response to Comment EJ-13
This comment states that the Draft IS/ND fails to consider the link between the P roject’s direct and life- cycle air pollution impacts and COVID-19. The comment cites several studies that assert that exposure to nitrogen dioxide, nitrogen oxide, ozone, carbon dioxide, carbon monoxide, and PM 2.5 is linked to higher risk of infection and mortality from COVID-19.

An analysis of the potential project-specific health impacts from air pollution emissions is required under CEQA. This analysis is presented in IS/ND Section 4.3 ( Air Quality, Item c .), using health protective standards and significance thresholds to assess the worst -case health impacts , including the SCAQMD localized significance thresholds to a ssess criteria pollutants and SCAQMD health risk significance thresholds to address air toxic pollutants. The health risk assessment methods and assumptions account for sensitive receptors with health conditions , such as asthma, chronic pulmonary disease (COPD), and emphysema, and short-term acute diseases that can impact lung function such as the flu, common colds, or COVID-19. While conservative reference exposure levels are used to assess worst -case acute health risk, there are no responsible-agency recommended methods, procedures, or requirements to separately address project effects on specific short -term acute diseases like COVID -19, as the analysis is already designed to be health protective and address es potential worst-case project impacts and baseline

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receptor health conditions. Additionally, there are no requirements to address project life-cycle air quality impacts, such an analysis would be speculative at best..

Response to Comment EJ-14
The comment states that the proposed Project’s direct and indirect operation VOC emissions were not fully addressed in the IS/ND. The comment notes that the emissions from the new pipeline pump, pipeline cleaning, and tank dewatering wastewater treatment VOC emissions were not considered and included in the P roject’s total direct emissions. The comment also notes contradictory statements regarding indirect GHG emissions from fuel pumping.

The POLB, as the lead agency under CEQA, prepared the IS/ND for the issuance of a Harbor Development Permit. In accordance with State CEQA Guidelines Section 15096, the SCAQMD is a responsible agency under CEQA for the issuance of the permit to construct/permit to operate for the two tanks, and assisted the POLB, to ensure that the proposed Project’s operations emissions estimates related to the new tanks’ operation are consistent with the permit evaluation. Specifically, the following addresses the emissions sources noted in the comment:

Pipeline Pump. The POLB coordinated with the SCAQMD n to ensure that all new piping component fugitive VOC emissions are included in the emissions estimate.

Pipeline Cleaning. The Project does not include the installation or use of any new pipelines. As such, there would be no increase in the frequency of emissions from pipeline cleaning. The IS/ND clearly identifies that the proposed Project would use existing pipelines and would no t include the construction of new pipelines, except for approximately 40 linear feet of piping to connect the new tanks to existing pipe infrastructure (see IS/ND Section 2.9 [Project Overview]).

Tank Dewatering. The proposed Project includes the construction and operation of two new crude oil tanks. The new tanks would not cause an increase in crude throughput that would increase the throughput or wastewater treatment requirements for crude oil dewatering. Therefore, the P roject would not affect VOC emissions related to tank dewatering and wastewater treatment.

Indirect Pumping GHG Emissions. The amount of any pumping electricity increase from the two proposed 25-horsepower pumps would not increase the indirect GHG emissions by a magnitude that would be significant. Given the low amount of total horsepower involved, where even if the pumps were to operate at 100 percent load 100 percent of the time, the indirect GHG emissions would be a small fraction of the SCAQMD GHG emissions significance threshold. Additionally, the new tanks are not designed to increase crude oil throughput, so the crude oil pumping energy requirement should not change, and any change in electricity use would be from the additional pumping resulting from the new use of the two existing tanks that will go into lease service. That new use for the two existing tanks is not known and cannot be reasonably estimated. However, to clearly demonstrate that the energy use from pumps of this size would not create substantial indirect GHG emissions, the following worst -case GHG emissions calculation is provided:
2 x 25 horsepower (hp) pumps x 1 (100% load) x 8,760 hours (h)/year / 1,341 hp/Megawatt (MW) = 327 MWh/year 327 MWh/year x 0.181 MT CO2e/MWh (SCE’s 2019 delivered energy GHG emissions rate3) = 59 MT CO2e/year

3 SCE, 2020.

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The actual expected pump use is a small fraction of 100 percent use at 100 percent load, well less than 10 percent of full time use, meaning the indirect emissions would be less than 10 MT CO 2e/year and the SCAQMD GHG emissions significance threshold is 10 ,000 metric tons of CO 2e/year, so the indirect emissions from pumping increase would be expected to be less than one tenth of one percent of this significance criteria and would clearly be a “minor amount of increased indirect GHG emissions” as stated in the IS/ND.

Response to Comment EJ-15
The comment states that the analysis of the proposed Project’s cumulative impacts is improper and incomplete because it does not consider the operation of the tanks or generation of tank sludge over the Project’s lifetime. When assessing whether a cumulative effect requires an EIR, State CEQA Guidelines Section 15064(h)(1) states that a “lead agency shall consider whether the cumulative impact is significant and whether the effects of the project are cumulatively considerable.” Additionally, State CEQA Guidelines Section 15064(h)(4) states that “The mere existence of significant cumulative impacts caused by other projects alone shall not constitute substantial evidence that the proposed project’s incremental effects are cumulatively considerable”.

As summarized in the Draft IS/ND, Section 3.1 (Environmental Factors Potentially Affected), no potentially significant impacts have been identified for the World Oil Tank Installation Project. All impacts were determined to be e ither “No Impact” or “Less than Significant” because they would not exceed any project-specific significant thresholds. Based on these conclusions, incremental effects of the proposed Project would be minor and, therefore not considered to be cumulatively considerable as defined by State CEQA Guidelines §15064(h)(1). Since impacts from the proposed P roject are not considered to be cumulatively considerable, the proposed Project has no po tential for generating significant adverse cumulative impacts. As stated above, projects that exceed the project-specific significance thresholds are considered by the SCAQMD to be cumulatively considerable.

SCAQMD’s guidance regarding cumulative impact assessment states the following:

Projects that exceed the project-specific significance thresholds are considered by the SCAQMD to be cumulatively considerable. This is the reason project -specific and cumulative significance thresholds are the same. Conver sely, projects that do not exceed the project- specific thresholds are generally not considered to be cumulatively significant (SCAQMD, 2003).

Using the SCAQMD guidance for cumulative air quality impact assessment, projects that have impacts below all SCAQM D significance criteria can be considered to have less than significant cumulative air quality impacts. The proposed P roject’s construction and operation emissions were found to be well below all SCAQMD emissions significance thresholds, and the health risk from the proposed P roject was found to be below SCAQMD health risk significance thresholds. Therefore, evidence supports the determination that the proposed Project would not have cumulatively considerable air quality impacts.

Furthermore, the court aff irmed based on the Leonoff decision ( Leonoff v. Monterey County Board of Supervisors (8/16/1990) 22 Cal. App. 3d 1337) that absent substantial evidence that the project would have a considerable incremental effect…an in -depth study of potential cumulative impact was not a prerequisite to preparing an MND. Specifically, the Leonoff decision states, “Under other circumstances, County might be faulted for not elaborating further on the Initial Study’s conclusions of no significant cumulative effects. But where there is no substantial evidence of any individual potentially significant effect by this project, this conclusion appears reasonable.”

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The comment also notes that the new tanks would generate approximately 15,000 barrels (bbl) of tank sludge over the co urse of the 50-year operational life. IS/ND Section 4.9 (Hazards and Hazardous Materials) and Section 4.21 (Mandatory Findings of Significance) have been revised to clarify that s ludge tank bottom quantities would be disposed of at a permitted treatment, s torage, and disposal facility (TSDF) such as U.S. Ecology waste facility. This waste is regulated by the State of California (non-Resource Conservation and Recovery Act (RCRA) hazardous waste). The closest U.S. Ecology waste facility is located in Vernon, California, approximately 17 miles from the project site. The U.S. Ecology Vernon RCRA Part B facility is capable of handling a high volume of waste, with a tank capacity of one million gallons with an additional 400,000-gallon equivalents of container sto rage (U.S. Ecology Vernon, 2021). Sludge tank bottom quantities are estimated to be approximately 1,500 bbl (63,000 gallons) every ten years. Over the approximate 50 years lifetime of the proposed Project, the sludge tank bottom quantities would be equal to 15,000 bbl. The amount of 1,500 bbl of sludge tank bottom quantity that is generated every ten years accounts for approximately 4.5 percent of the overall capacity of the U.S. Ecology Vernon facility. This amount of sludge tank bottom accounts for a small percentage of the overall capacity of the nearest U.S.

Ecology waste facility. Thus, the proposed Project’s contribution to cumulative impacts is determined to be less than significant.

Response to Comment EJ-16
The comment states that the Draft IS/ND fails to consider the proposed Project’s cumulative impacts i n the context of the existing operations at the World Oil Terminal. As explained in Response to Comment EJ-15, projects that exceed the project-specific significance thresholds are considered by the SCAQMD to be cumulatively considerable, and those that do not exceed the project -specific significance thresholds are not considered to be cumulatively considerable. The analysis in the Draft IS/ND found no significant impacts. Therefore, the analysis in the Draft IS/ND regarding cumulative impacts properly concluded that no significant adverse cumulative impacts would be expected as a result of the proposed Project.

Response to Comment EJ-17
The comment states that the Draft IS/ND fails to consider closely related refining operations in the region as part of the cumulative impact analysis. P lease see Response to Comment EJ-15. The proposed Project would not result in any significant impacts that would be cumulatively considerable. Furthermore, CEQA Guidelines Section 15064(h)(4) states that the mere existence of significant cumulative impacts caused by other projects alone shall not constitute substantial evidence that the proposed project’s incremental effects are cumulatively considerable. Therefore, CEQA does not require the IS/ND to identify cumulative projects, as the proposed Project would not have any cumulatively considerable impacts. As described in IS/ND Section 2.9 (Project Overview), the World Oil Terminal is an existing approved use that currently contains seven tanks. The proposed Project would add two tanks within the existing footprint of the facility and is consistent with the 1990 certified Port Master Plan Update (PMPU).

The Project site is a crude oil and petroleum product storage site, not a refinery. Refinery processing capacities are constrained by many factors including equipment design capacity, permit conditions, firing rates for combustion sources, and maintenance schedules of the various operating units within a refinery.

Refinery processes are not influenced by storage capacity. Therefore, the proposed Project would not affect local refinery operations.

The comment states that it is unclear what “current projects” were considered in the IS/ND as part of the cumulative analysis. “Current projects” refer to similar ongoing or reasonably foreseeable future construction projects, which are not limited to “other storage tanks” or “petroleum refinery operations,”

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which the comment references. IS/ND Section 4.21 (Mandatory Findings of Significance) has been revised to clarify that other storage tanks and petroleum refinery operations are existing, ongoing operations, not new construction projects or major modifications.

Response to Comment EJ-18
The comment states that the Draft IS/ND fails to consider the cumulative impacts from hundreds of other petroleum storage tanks projects in the region.

The cumulative impact assessment was completed in accordance with SCAQMD guidance. As noted in Comment Response EJ-8, the POLB has coordinated with the SCAQMD in the review of World Oil’s revised permit application to ensure that the impact analysis in the IS/ND complies with all SCAQMD methods , guidance, and requirements necessary for the SCAQMD to issue the permit to construct/permit to operate for the two new tanks.

While this comment, with additional permit application data provided as an attachment to comment EJ - 51, notes that there has been a very large number of tank permit applications submitted between 2010 and 2020 (1, 010 total permit applications ), a review of this information indicates very few of these applications were for construction of new petroleum product tanks. Most of these permit applications are for change of ownership (751), alteration/modification (135), and change of permit condition (39) . Only 67 of these permit applications were for new construction, and of these only 31 were for above ground petroleum product storage tanks. The comment also does not identify tank sizes to determine how many are comparable in size to the proposed Project’s tanks and also does not provide the number of retired storage tanks for this same period. As such, this comment may provide the impression that air pollutant emissions and resultant health risk from petroleum products storage tanks has increased since 2010 due to the volume of permit applications ; however, Reactive Organic Gases (ROG) emissions from the petroleum refining and marketing sector have declined since 2010, as estimated by CARB in Table EJ-18.

Table EJ-18. Los Angeles County portion of South Coast Air Basin Petroleum Refining and Marketing ROG Emissions Estimate Comparison 2010 and 2020 (Tons/Day) Emissions Sector/Subcategory 2010 2020
Petroleum Production and Marketing1 28.95 15.11
Petroleum Refining 6.10 4.54
Petroleum Marketing 14.03 8.39
1 – Not all subcategories are listed, so totals of subcategories will not match the Sector total.

Source: CARB, 2016.

Given the large emissions decline in this sector , and relevant subcategories, there are no sector -wide cumulatively significant emissions increases, and the proposed Project’s small emissions increase of approximately 0.005 tons/day (1 1 lbs/day) ROG would not be cumulatively considerable in comparison with the sector emissions shown in Table EJ-18.

Also, please see Responses to Comment EJ-15 and EJ-17.

Response to Comment EJ-19
The comment states that the Draft IS/ND Project Description fails to properly define the proposed Project because it does not account for the impacts of oil refining activities, which the comment asserts are a reasonably foreseeable consequence of the proposed Project. IS/ND Section 2.11 (Project Description)

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has been revised to clarify the differences between the proposed P roject activities and oil refiner y activities, and that fuel and crude oil throughput at refineries is not influenced by the proposed Project’s storage capacity. As described in the Draft IS/ND Project Description, oil refining activities are considered a separate action. Acti vities at refineries such as the Marathon Petroleum Carson Refinery and at terminals such as Glencore Long Beach Marine Terminal have permitting limits separate from the World Oil Terminal storage facility. Additionally, oil refineries are designed to allow for a limited quantity of oil to be refined during a given period and are not influenced by the amount of petroleum stored at separate facilities, and therefore, fuel oil throughput would not increase as a direct or indirect result of the proposed Project. Therefore, the Draft IS/ND complies with CEQA’s requirements by accurately describing the proposed Project and providing evidence that fuel and crude oil throughput at refineries would not increase as a result of the installation of two new storage tanks.

Response to Comment EJ-20
The comment states that the Draft IS/ND asserts without evidence that the proposed Project would not allow greater actual crude oil throughput.

As noted in Response to Comment EJ-19, this project would not increase the throughput capacity for the World Oil refinery, which is throughput constrained by many other factors, including air permit throughput or use limits. These new tanks provide storage only, they do not affect the downstream use and as correctly stated in the IS/ND would not allow greater actual crude oil throughput.

Response to Comment EJ-21
This comment notes that the IS/ND fails to include foreseeable combustion of distributed oil products.

While the proposed Project increases petroleum product storage capacity by 50,000 barrels at the Project site, the proposed P roject in and of itself would not increase the use of the stored petroleum products (crude oil or fuel oils) nor would the proposed Project create additional fuel oil consumers. There would be no way to determine how the proposed Project would affect existing fuel consumers and total fuel consumption; any estimate would not be foreseeable and would be pure conjecture, a speculative estimate at best 4. Additionally, World Oil stores crude oil for use at its Southern California refinery that produces asphalt roofing, paving products, and distillates used in motor fuels, but does not directly produce motor fuels (World Oil Corp, 2021). Further, the proposed Project would provide more flexibility in the storage of fuels, as California Low Carbon Fuel Standard regulations require increasing the amount of renewable fuel production/use, and through vehicle electrification regulations. Therefore, the use of petroleum-based fuels, including petroleum -based marine fuels, will be reduced through the implementation forced by regulation to be reduced over time.

As stated in IS/ND Section 2 (Project Description) and Section 4.3 (Air Quality), as a worst-case assumption for the purposes of impact analysis, truck trips are estimated to increase 10 percent during proposed Project operations, which may occur during atypical operations such as when a pipeline is being serviced.

The air quality analysis accounts for the air quality impacts associated with this increase in diesel fuel use in on-road heavy-duty trucks. This is the only normal daily increase in fossil fuel consumption that can be quantitatively directly attributed to the proposed Project.

Please also see Responses to Comment EJ-13 and EJ-15.

4 CEQA law does not require speculation; in fact, it discourages speculative analysis as noted in Article 10.

Considerations in Preparing EIRs and Negative Declarations, Section 15145 Speculation.

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Response to Comment EJ-22
The comment states that the IS/ND fails to consider GHG emissions in the context of California’s emissions reduction goals and the crisis of climate change and asserts that the IS/ND fails to analyze the potentially significant impacts of GHGs during all stag es of oil development, including lifecycle and cumulative impacts.

The IS/ND Section 4.8 (Greenhouse Gas Emissions), under the C hecklist item a. discussion, evaluates the GHG emissions in the context of the SCAQMD significant emissions thresholds for indu strial sources and the proposed Project’s conformance with GHG emissions reduction plans, policies, and regulations. The proposed Project was found to have a small increase in GHG emissions from construction and operation, an increase of less than 1/100th of the significance threshold. Operation GHG emissions were determined to be insignificant because leasing of the existing tanks would cause a minor increase in GHG emissions from electricity used to power the pipeline pumps and fugitive GHG emissions from crude oil storage and loading are negligible because the proposed Project would not cause an increase in crude oil throughput.

The IS/ND Section 4.8 (Greenhouse Gas Emissions), under the c hecklist item b. discussion, evaluates the proposed P roject in terms of conformance with applicable agency adopted GHG emissions reduction plans, policies, or regulations, where it was determined that t he proposed Project also conforms with applicable GHG emissions reduction measures.

The comment appears to overlook the State CEQA guidelines and SCAQMD significance thresholds and seeks to impose requirements for GHG emissions reductions and life-cycle impact analysis not required under CEQA or under State and local agency regulations . Life-cycle impact analysis would be speculative and speculative analysis is discouraged under CEQA law. Please see Responses to Comments EJ-13, EJ-14, EJ-19, EJ -20, EJ-21, and EJ -31 in relation to comments regarding life- cycle emissions and speculative analysis.

Response to Comment EJ-23
This comment states that the IS/ND improperly relies on SCAQMD’s outdated interim GHG threshold for significance. The IS/ND used the appropriate GHG emissions significance threshold, as determined by the local responsible agency, the SCAQMD, for the proposed Project’s GHG emissions impact analysis.

The SCAQMD GHG emissions significance threshold of 10,000 metric tons per year for industrial projects is a published threshold that is provided with the other approved SCAQMD air quality significance thresholds (SCAQMD, 2019). The SCAQMD last revised their air quality significance thresholds list in 2019, therefore it is not considered outdated for industrial sources.

Response to Comment EJ-24
The comment states that the Draft IS/ND fails to provide substantial evidence that earthquakes would not pose a risk of significant environmental impact. Located in Southern California, the proposed Project site is in a known seismically active region. The proposed Project would be subject to similar levels of impact as other development projects in Southern California and would not exacerbate seismic -related hazards relative to existing conditions. The Final IS/ND Section 4.7 (Geology and Soils) has been revised to clarify the design and construction, including site preparation and final engineering of the P roject, shall incorporate all geotechnical recommendations provided in the Albus -Keefe & Associates geotechnical update report from 2018 (Albus-Keefe & Associates, Inc., 2018). The recommendation of a ground improvement system consisting of Geopiers or the equivalent rammed aggregate piers would reduce the

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effects of static and seismic settlement at the project site (Albus -Keefe, 2018). Additionally, a ma t-raft foundation system consisting of a mat supported by caissons/piles for the two tanks would reduce the potential for seismically induced damage to the new tanks from seismic shaking, liquefaction, or lateral spreading (Albus -Keefe, 2018). The proposed tanks would be designed and constructed in accordance with applicable State and building code requirements and standards, such as the California Building Codes, City of Long Beach building codes, and the Seismic Safety Element of the City of Long Beach. C ompliance with these requirements and incorporation of all geotechnical recommendations provided in the geotechnical investigation report into the final design would reduce the potential for environmental impacts from earthquakes.

The comment also notes that earthquakes would leave the tanks vulnerable to fires, spills, and explosions.

Engineering controls on the project site serve to prevent hazardous conditions, such as a fire or explosion.

The project site contains fire extinguishing equipment, in addition to a deluge fire suppression system.

The existing tanks are equipped with a foam fire suppression system. The new tanks would also be equipped with a foam fire suppression system. In the event of a large fire, the site operator is trained to stop ongoi ng operations, close all safety isolation valves, and report a fire to the Long Beach Fire Department. The foam fire suppression system allows first responders to pump aqueous film forming foam (AFFF) both into and onto a tank. The estimated response time of the Long Beach Fire Department would be less than ten minutes.

Compliance with risk reduction requirements is achieved through implementation of existing emergency contingency plans, which include precautions to minimize potential hazards and actions to take in the event of an emergency. Existing emergency contingency plans include the Emergency Response Action Plan, Facility Response Plan, Illness and Injury Prevention Plan, and Spill Prevention Control and Countermeasure Plan. The proposed P roject requires all plans to be updated to reflect the new tanks.

World Oil is not required to comply with California Accidental Release Prevention (CalARP) or any related risk reduction regulations. World Oil would continue to conduct annual trainings and quarterly/ annual emergency drills, have evacuation plans, and shutdown procedures.

The proposed Project site is in an industrialized area, not an urban residential area. Any fire would be isolated at the Port. There is no history of fires at the project site. Constr uction and operation of the proposed Project is subject to in place emergency response and evacuation systems which are implemented by the POLB. The proposed Project is contained entirely within the POLB, and is serviced by the Long Beach Fire Department, the Long Beach Police Department, and the Port Harbor Patrol for fire protection, police protection, and emergency services. In the event of a fire, existing on - and off -site resources would put out petroleum fires quickly and not allow them to burn themselves out. The proposed Project would not exacerbate fire-related hazards relative to existing conditions.

As discussed in Section 2.9 (Project Overview) of the Draft IS/ND, the existing tanks at the project site are surrounded by a containment wall that varies between approximately 12.5 to 13-feet in height. The wall thickness tapers from approximately 1.5 feet wide at the base to 1 foot wide at the top. The wall includes a 12 to 12.5-foot-wide footing that is buried to a depth that runs from 1.5 feet below-grade at the outer edges of the wall to a depth of approximately 3 feet towards the center of the facility. The wall and its footing make a large “L” shape that is continuous around the site which prevents the wall from falling over in the event of a s pill. The containment wall was designed to hold the largest tanks capacity (90,000 barrels) plus a 100-year storm event. The new tanks would be located within the containment wall such that any spills would be contained.

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Response to Comment EJ-25
The comment asserts that the Draft IS/ND includes studies that are inadequately cited or included in the administrative record and do not account for substantial evidence showing risks of significant environmental impacts from a tsunami.

This comment is unclear. Nevertheless, the citations throughout IS/ND Section 4.10(d) (Hydrology and Water Quality) have been updated to correct the spelling of the author of the 2007 Tsunami Hazard Assessment for the Ports of Los Angeles and Long Beach Final Report (Hazard Assessment), Moffatt & Nichol. The comment’s footnotes (No. 174, 176, and 177) refer to Appendix A, Section V.A. of the comment letter. Appendix A, Section V.A focuses on potential cumulative impacts experienced by disadvantage communities in the general harbor area and does not provide evidence of, or relate to, potential significant environmental impacts from a tsunami.

As discussed in IS/ND Section 4.10(d) (Hydrology and Water Quality), the 2007 Tsunami Hazard Assessment for the Port of Los Ange les and Port of Long Beach prepared by Moffat & Nichol concluded that large earthquakes (e.g., magnitude ~7.5) are very infrequent and have not occurred in the offshore area of California within historical times and that a large and locally generated tsunami would not likely occur more than once every 10,000 years (Moffatt & Nichol, 2007).

In 2010, the Joint Institute for the Study of the Atmosphere and Ocean (JISAO) and National Oceanic and Atmospheric Administration (NOAA)/Pacific Marine Environmental La boratory (PMEL) investigated 322 possible distant source scenarios under which a magnitude (Mw) 9.3 earthquake could generate a tsunami with potential significant impact on the POLB (Uslu et al., 2010). Of the 322 scenarios investigated, it was determined that a Mw 9.3 earthquake originating from Alaska had the most potential to trigger a tsunami capable of having the most impact to the ports (i.e., worst case scenario). This magnitude of earthquake may potentially produce wave amplitudes up to approximatel y 6.5 feet and current velocities exceeding 4 meters per second (≈8 knots or 9 miles per hour) in the ports of Los Angeles and Long Beach (Uslu et al., 2010). The potential tsunami would take approximately 2 to 7 hours to reach the Los Angeles tide station (Uslu et al., 2010).

As described in IS/ND Section 4.10(d) (Hydrology and Water Quality), the proposed Project would be constructed within the existing 12.5- to 13-foot-high concrete containment wall and would not be subject to significant damage from inundation or if struck by tsunami-borne debris. As described in the report by JISAO, NOAA, and PMEL, large tsunamis have historically caused heavy damage to waterfronts, vessels, moorings, piers, a nd docks (Uslu et al., 2010). No vessels or water -side activities are associated with existing or proposed operation of the World Oil Terminal, nor would they be associated with construction of the proposed Project. Additionally, the proposed Project is located within an inner channel that is considerably more inland than the southern portions of the Port. If a tsunami were to occur, the outermost portions of the coast and Port would be impacted first. Waves generated by a tsunami are likely to dissipate and weaken as they travel inland through the Port’s channels.

Additionally, in the event of an emergency, World Oil would comply with risk reduction requirements through implementation of existing emergency contingency plans, which include precautions to minimize potential hazards and actions to take. Refer to Response to Comment EJ-24.

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Response to Comment EJ-26
The comment states that the POLB must issue an EIR to comply with CEQA and that the Draft IS/ND ignores evidence that suggests that there are significant impacts. Please see Responses to Comments EJ-5 through EJ-25.

Response to Comment EJ-27
The comment is an introductory statement that the South Coast A ir Q uality Management District’s Application Engineering Evaluation and Permit -to-Construct documents for the Project were reviewed.

No further response is required.

Response to Comment EJ-28
The comment summarizes the commenter’s understanding of the proposed Project and asserts that there are deficiencies in the Negative Declaration requiring detailed environmental analysis. Please see Responses to Comments EJ-30 through EJ-49 for specific responses to the stated deficiencies.

Response to Comment EJ-29
The comment states that the Draft IS/ND “makes unsupported conclusions, fails to include basic information necessary for public review, and leaves mitigation for later.” This is introductory text, with detailed comments following this statement. Please see Responses to Comments EJ-30 through EJ-49.

Response to Comment EJ-30
This comment is from the Technical Appendix to the Comment Letter that provides additional details to support Comments EJ-9 and EJ-10. Please see Responses to Comments EJ-9 and EJ-10.

Response to Comment EJ-31
This comment states that the IS/ ND should have included an assessment of cancer risk from the use of portable equipment used at the site.

Portable equipment use does not occur regularly at the P roject site, where energy requirement s for all ongoing activities is provided by public utility supplied electricity or natural gas. World Oil does not keep any portable equipment on site. Project-related portable equipment use would be rent ed or contractor- owned equipment where use would be limited to very low-frequency major maintenance events, such as for tank cleaning which would occur approximately every 10 years. The emissions from such limited use of portable equipment would be minimal and subject to CARB portable equipment registration program (PERP) or SCAQMD permitting regulations . Therefore, due to limited and periodic use (approximately every 10 years), the emissions from on -site portable equipment use would not substantially affect the long-term toxic air pollutant cancer risk from the project site.

Response to Comment EJ-32
This comment is from the Technical Appendix to the Comment Letter tha t provides additional details to support Comment EJ-11. Please see the Response to Comment EJ-11.

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Response to Comment EJ-33
The comment asserts that there is a significant risk of increased and severe tsunami hazards due to the proposed Project. Please refer to Response to Comment EJ-25.

Response to Comment EJ-34
The comment states that the Draft IS/ND fails to provide substantial evidence that earthquakes would not pose a risk of significant environmental impact. Please refer to Response to Comment EJ-24.

Response to Comment EJ-35
This is a statement summarizing the experience of Julie May, Senior Scientist, CBE . No response is required.

Response to Comment EJ-36
This comment is from the Technical Appendix to the Comment Letter that provides additional details to support Comment EJ-9. Please see the response to Comment EJ-9.

Response to Comment EJ-37
This comment is from the Technical Appendix to the Comment Letter tha t provides additional details to support Comment EJ-11. Please see the response to Comment EJ-11.

Response to Comment EJ-38
The comment states that the proposed Project would result in significant impacts due to a tsunami or earthquake. Please refer to Response to Comment EJ -24 and EJ -25. The significance of the proposed Project’s impacts is determined based on whether the additional tanks would substantially exacer bate existing conditions. As stated in IS/ND Section 4.10 (Hydrology and Water Quality), the proposed tanks would be constructed and installed within existing 12.5 to 13-foot -high containment wall that would continue to offer the same level of adequate tsunami protection for the proposed tanks as they do for the existing tanks. Construction of the new tanks would not change the level of protection that the containment wall provides.

Response to Comment EJ-39
The comment states that the Draft IS/ND fails to provide substantial evidence that earthquakes would not pose a risk of significant environmental impact. Please refer to Response to Comment EJ-24.

Response to Comment EJ-40
The comment provides reference to the California Coastal Commission’s Environmental Justice Policy, the California Environmental Protection Agency CalEnviroScreen mapping tool which maps and scores concentrated environmental and socioeconomic burdens in California, including a screenshot of the residential areas surrounding the ports of Long Beach and Los Angeles. A screenshot of the Ribost Terminal identified as a “Toxic Release Facility” is also provided. Finally, the comment references the SCAQMD Community Emission Reduction Plan (CERP) for the Wilmington/Carson/West Long Beach (WCWLB). The commenter also notes that in addition to ports, related priorities in the CERP include the refineries (the World Oil terminal is not a refinery, rather refineries which use crude oil lease tanks at the

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World Oil Terminal). The comment does not state a specific concern or question regarding the sufficiency of the analysis in the Draft IS/ND. As such, no response is required.

Response to Comment EJ-41
The comment states that “[n]eighbors and community organization s in the Ports area WCWLB have long sought protective measures to slow the concentration of new polluting and hazardous sources and reduce pollution. This requires serious evaluation of cumulative impacts, rather than streamlining of permitting and environmental assessments, as in the ND’s cumulative impacts analysis.” Because the proposed Project is located in the Harbor District, the POLB has the authority for the issuance of a Harbor Development Permit pursuant to Chapter 8 of the California Coastal Act and the certified PMPU, as amended. The commenter asserts that the IS/ND’s cumulative impacts analysis did not involve “serious evaluation” so as to streamline of permitting and environmental assessment. Issuance of a Harbor Development Permit by the POLB, as a public agency, requires compliance with CEQA. CEQA establishes a duty for public agencies to avoid or minimize environmental damage where feasible (State CEQA Guidelines Section 15021 (a)). Contrary to the assertion that the POLB “streamlined” permitting and environmental assessment without serious evaluation of the cumulative impacts associated with the proposed Project, the POLB’s assessment was prepared i n accordance with State CEQA Guidelines Sections 15060 and 15063. The POLB conducted preliminary review of the proposed Project, and an Initial Study was prepared to determine if the proposed Project may have a significant effect on the environment. As summarized in the Draft IS/ND, Section 3.1 (Environmental Factors Potentially Affected), no potentially significant impacts have been identified for the World Oil Tank Installation Project. All impacts were determined to be either “No Impact” or “Less than Significant” because they would not exceed any project-specific significant thresholds. Based on these conclusions, incremental effects of the proposed Project would be minor and, therefore not considered to be cumulatively considerable as defined by State CEQA Guidelines §15064(h)(1). Since impacts from the proposed P roject are not considered to be cumulatively considerable, the proposed P roject has no potential for generating significant adverse cumulative impacts. Please also see Responses to Comments EJ-13 through EJ-16.

Response to Comment EJ-42
The comment states that “environmental assessment before finalizing a permit is necessary and appropriate, but the Project received a permit even before the ND was published…instead of the especial importance of evaluating cumulative impacts in this area, the ND analysis is very inadequate, and would allow the Project to add hazards and pollution which are significant by themselves, but also cumulatively significant”.

It is unclear which permit the commenter is referring to. The POLB is the lead agency pursuant to CEQA for the proposed Project, as it is the agency responsible for the issuance of a Harbor Development Permit to World Oil for the proposed Project in accordance with Chapter 8 of the California Coastal Act and Section 1215 of the City of Long Beach Municipal Code. The SCAQMD has been identified as a responsible agency under CEQA because of its authority to issue permits to construct/operate under the Clean Air Act.

Presuming that the comment er is referring to World Oil’s previously issued permits to construct for the two new tanks in January 2020 by the SCAQMD , as discussed in Response to Comment EJ -6, since the issuance of the Draft IS/ND by the POLB, World Oil’s permits to construct issued in January 2020 have lapsed and are no longer valid. As a result, in consultation with SCAQMD, World Oil has submitted a new permit application for the two proposed tanks. The POLB has coordinated and consulted with the

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SCAQMD as part of the IS/ND process in accordance with CEQA. The Harbor Development Permit will only be issued should the Board of Harbor Commissioners approve the project and adopt the IS/ND. As a responsible agency for issuance of permits to construct for the proposed Project, the SCAQMD would comply with CEQA by considering the IS/ ND prepared by the POLB and reaching its own conclusions on whether and how to approve the Project (State CEQA Guidelines Section 15096(a)).

The analysis in the Draft IS/ND found no significant impacts. As described in Section 4.3 (Air Quality), daily construction and operation emissions would be well below the SCAQMD’s significance thresholds for criteria air pollutants and are therefore less than significant. Therefore, the analysis in the Draft IS/ND regarding cumulative impacts properly concluded that no significant adverse cumulative impacts would be expected as a result of the proposed Project. Please refer to Response to Comment EJ-15 and EJ-17.

Response to Comment EJ-43
The comment states that the VOC and benzene emissions are already cumulatively significant in the area and the Project significantly adds to this cumulative impact. Please see Response to Comment EJ-15.

Response to Comment EJ-44
This comment infers that the proposed Project’s H2S emissions impacts, both odor and health impacts, would be cumulatively significant. Please see Responses to Comments EJ-11 and EJ-15.

Response to Comment EJ-45
This comment infers that the proposed Project’s nominal increase in diesel truck trips and use of portable engines during tank maintenance events would create cumulatively significant health risk impacts. Please see Responses to Comments EJ-15 and EJ-31.

While the proposed Project will cause a small increase in diesel truck trips and use of portable equipment, the proposed Project’s small amount of increased trucking and portable engine use would not create a cumulatively considerable increase to health risks. The increase in diesel particulate matter ( DPM) emissions from this additional fuel trucking is estimated to be 0.014 pounds per day . The facility has no resident portable equipment. Rented or contractor-owned equipment would be used infrequently during major maintenance events, like tank cleaning (once every approximately 10 years) , so emissions from portable equipment are intermittent and would be zero much of the time. The total amount of DPM emissions from these operation sources is negligible in the context of regional DPM emissions and existing ambient air health risk impacts.

Response to Comment EJ-46
The comment states that the proposed Project would have significant cumulative impacts resulting from fires, earthquakes, and tsunamis. Please refer to Responses to Comments EJ -15 regarding cumulative air quality impacts, EJ-24 for earthquake and fire hazards, and EJ-25 for tsunami hazards.

The project site is not located in an area of “dense woodframe construction” as referred to in footnote 56 of the comment. The project site is in an industrial area, not an urban residential area. Fire suppression systems include fire extinguishing equipment, a deluge fire suppression system, and foam fire suppression system on the tanks. Fire suppression systems, engineering controls, and risk reduction requirements serve to reduce the proposed Project’s contribution to cumulative impacts which are less than significant.

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Response to Comment EJ-47
The comment states that the throughput would be additional feedstocks to refineries, and as a result, the potential throughput must be evaluated. Please refer to Response to Comment EJ-19.

Response to Comment EJ-48
The comment states that the proposed Project’s GHG emissions are cumulatively significant. Please see Response to Comment EJ-15.

GHG emissions are by nature a cumulative impact issue. Unlike air pollutant impacts, there are no substantial direct downwind health or other impacts from GHG emissions sources. GHG emissions affect global climate change regionally in different ways and over long timeframes. The impacts of any one project would have negligible impacts on their own, without considering the overall global trend of GHG emissions, so their impacts are only important cumulatively. Therefore, no separate cumulative impact analysis for GHG emissions is required. The analysis performed determined that the proposed P roject’s GHG emissions are not cumulatively significant.

Response to Comment EJ-49
This comment infers that the proposed Project would have cumulatively considerable impact because the project area has existing poor air quality, is highly industrialized, and is surrounded by affected residential and commercial areas. Additionally, this comment notes the following:
 The IS/ND focused on construction impacts and minimized the significance of operation emissions.  Compliance with existing regulations do not preclude causing significant emissions.

Please see Response to Comment EJ -15 regarding cumulative impacts associated with the proposed Project.

The proposed Project is located within the South Coast Air Basin (SCAB), a region where state and federal air quality standards are often exceeded. The SCAQMD has adopted air quality significance thresholds for construction and operations that are protective of public health and would assist the SCAB attain state and federal air quality standards. As discussed in the IS/ND Section 4.3 (Air Quality), the proposed Project is not expected to exceed air quality significance thresholds for construction and operation. Therefore, air quality impacts are considered less than significant.

GHG and criter ia pollutant emissions were analyzed using tools designed for use by local, state, and federal agencies. GHG and criteria pollutant emissions for construction activities were estimated using the latest SCAQMD -recommended California Emissions Estimator Model (CalEEMod) Version 2016.3.2.

CalEEMod is a statewide emissions computer model developed for the California Air Pollution Officers Association in collaboration with the California Air Districts. The California Air Districts provide d certain default emissions data to account for local requirements and conditions. The off-road equipment and on- road v ehicle emissions factors used in CalEEMod are from CARB emissions factor models. The IS/ND evaluated criteria pollutant emissions assuming construction year 2021 using the CalEEMod estimated unmitigated fleet average emissions factors, which for off -road equipment during the construction year would be approximately the same as assuming Tier 3 diesel engine standards (not a mitigated Tier 4 fleet).

The construction emission estimates for criteria pollutants were below SCAQMD emission significance thresholds; therefore, construction emissions were determined to have less-than-significant impacts.

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Criteria pollutant emissions associated with operation of the new tanks were calculated by SCAQMD based on the information provided by World Oil using the calculations in U.S. EPA AP-42 Section 7.1 (also see Response to Comment EJ -9) to estimate emissions from fixed - and floating-roof storage tanks. The estimated increase in operation on -road criteria and GHG emissions were calculated separately using CARB fleet average emissions factors, and the related increase in loading rack emissions were calculated, and both are presented in IS/ND Appendix A. The calculation of worst -case operation indirect GHG emissions increase from the use of the new tank pumps has also been added to the emissions calculations provided in IS/ND Appendix A. The operation emission estimates for criteria pollutants were below SCAQMD emission significance thresholds; therefore, operation emissions were determined to have less than significant impacts.

The estimated GHG construction emissions were amortized over the SCAQMD -recommended life assumption of 30 years and added to the operations GHG emissions increase. The proposed P roject’s combined GHG emissions from construction and operation are below the GHG emissions significance threshold; therefore, GHG emissions were determined to have less than significant impacts.

Regarding the comment that compliance with existing regulation and laws does not preclude a project causing significant emissions, the commenter states “If they did, the region would not be in extreme non- attainment with Clean Air Act health standards.” This comment disregards the substantial improvements made in air quality over the past several decades and the forecast continued improvement in air quality due to implementation of the existing air quality regulations and laws. If the Project’s emissions or health risk is determined to exceed significance thresholds, regardless of whether the Project is in compliance with all regulations and laws, CEQA requires that all feasible mitigation measures be applied to eliminate or reduce the impacts to less than significant. Otherwise, the impacts are considered to be significant and unavoidable. However, as discussed in IS/ND Section 4.3 ( Air Quality), the proposed Project would not exceed project-specific emissions or health risk thresholds and. Therefore, the project-level impacts would be less than significant and would not be considered cumulatively significant.

Also, please see Response to Comment CP-1.

Response to Comment EJ-50
The comment states that the proposed Project has the potential to result in significant impacts, and the Draft IS/ND is inadequate and requires further evaluation. Please refer to Responses to Comment EJ -30 through EJ-46.

Response to Comment EJ-51
The comment was received by the Port on March 16, 2021, after the close of the public review period which ended on November 20, 2020. It provides updated charts from Appendix G to include additional details (“Application Type”, “Updated Status”, “Issue Date”, and “Estimated Construction Date”), pertaining to the permits granted to storage tanks by the SCAQMD from 2010 to 2020. This updates the attachment to Comment EJ-18. Please see Response to Comment EJ-18. No further response is required.

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GBKN – Gabrieleno Band of Mission Indians – Kizh Nation Email: World Oil Tank Installation Project Team

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Response to Comments – GBKN
Gabrieleno Band of Mission Indians – Kizh Nation
Brandy Salas
Admin Specialist
October 28, 2020
Response to Comment GBKN-1
The comment requests a map of the proposed Project. Jennifer Blanchard, POLB Environmental Specialist Associate, provided the requested project map via email on October 28, 2020. No further comment was received from the tribe.

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cont.

SFERCA-40

World Oil Tank Installation Project
Final Negative Declaration and Application Summary Report

September 2021 8-201

SFERCA-40
cont.

SFERCA-41

World Oil Tank Installation Project
Final Negative Declaration and Application Summary Report

September 2021 8-202

SFERCA-41
cont.

World Oil Tank Installation Project
Final Negative Declaration and Application Summary Report

September 2021 8-203

SFERCA-41
cont.

World Oil Tank Installation Project
Final Negative Declaration and Application Summary Report

September 2021 8-204

SFERCA-41
cont.

SFERCA-42

World Oil Tank Installation Project
Final Negative Declaration and Application Summary Report

September 2021 8-205

SFERCA-42
cont.

World Oil Tank Installation Project
Final Negative Declaration and Application Summary Report

September 2021 8-206

SFERCA-42
cont.

SFERCA-43

World Oil Tank Installation Project
Final Negative Declaration and Application Summary Report

September 2021 8-207

SFERCA-43
cont.

World Oil Tank Installation Project
Final Negative Declaration and Application Summary Report

September 2021 8-208

SFERCA-43
cont.

World Oil Tank Installation Project
Final Negative Declaration and Application Summary Report

September 2021 8-209

SFERCA-43
cont.

World Oil Tank Installation Project
Final Negative Declaration and Application Summary Report

September 2021 8-210

SFERCA-43
cont.

World Oil Tank Installation Project
Final Negative Declaration and Application Summary Report

September 2021 8-211

Response to Comments – SFERCA
Safe Fuel and Energy Resources California
Adams Broadwell Joseph & Cardozo
Paul Encinas, Legal Assistant
October 9, 29, and November 9, 2020
Response to Comment SFERCA-1
The comment requests mailed notice of the availability of any environmental review document related to the proposed Project as well as all hearings and/or actions related to the proposed P roject and provides a contact mailing address and email address. The PO LB has included the commenter on the mailing list for any future mailings or notices related to the proposed project.

Response to Comment SFERCA-2
The comment requests immediate access to all public records related to the proposed P roject, including but not limited to, any and all materials, correspondence, resolutions, memos, notes, analysis, electron ic mail messages, files, maps, charts, and/or any other documents related to the Project.

It is common practice for project-related documents and referenced materials to be included in the administrative record, which is kept on file and available for public review upon request in accordance with the California Public Records Act (Government Code Section 6250, et seq) . On October 9, 2020, the Port received Public Records Request #C008842-100920 from Mr. Paul Encinas, Adams Broadwell Joseph & Cardozo via the City of Long Beach’s (City) public records request portal, GovQA portal. On October 22, 2020, the POLB provided all public records related to the proposed Project in .PDF and native file format via the City’s GovQA portal, as requested.

Response to Comment SFERCA-3
The comment summarizes the proposed Project. No further response is required.

Response to Comment SFERCA-4
The comment reiterates the request for immediate access to all public records related to the proposed Project, and any and all documents referenced, relied upon, and incorporated by reference in the Draft IS/ND. Please refer to Response to Comment SFERCA-2.

Response to Comment SFERCA-5
The comment reiterates the request for immediate access to all documents referenced, relied upon, and incorporated by reference in the Draft IS/ND. Please refer to Response to Comment SFERCA-2.

Response to Comment SFERCA-6
The comment requests the remaining documents referenced in the Draft IS/ND pursuant to Public Resources Code section 21092(b)(1) and CEQA Guidelines section 15072(g)(4). O n October 29, 2020, the Port received Public Records Request #C009079-102920 from Mr. Paul Encinas, Adams Broadwell Joseph & Cardozo via the City of Long Beach’s (City) public records request portal, GovQA portal. On November 3, 2020, the POLB provided the Certificates for Emissions Reduction Credits (ERC Certificates #AQ015139

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and #AQ015145) and the SCAQMD modeling files , in .PDF and native file format via the City’s GovQA portal, as requested.

Response to Comment SFERCA-7
This is Exhibit A to SFERCA’s comment letter dated October 29, 2020, which is a duplicate of SFERCA’s letter dated October 9, 2020. Reponses to comments to that letter are provided in Response to Comment SFERCA-2.

Response to Comments SFERCA-8
This is Exhibit B to SFERCA’s Comment Letter dated October 29, 2020, which is email correspondence dated October 14, 2020 regarding Public Records Request # C008842-100920 received by the Port on October 9, 2020. Please refer to Responses to Comments SFERCA-2 and SFERCA-6.

Response to Comment SFERCA-9
This is Exhibit B to SFERCA’s Comment Letter dated October 29, 2020, which is email correspondence dated October 15, 2020 regarding Public Records Request #C008842 -100920 received by the Port on October 9, 2020. The comment request s production of documents and priori tization of the following documents: (1) South Coast Air Quality Management Permit to Construct, Application 614274. Approved 1/2/20 (referenced on IS/ND, pp. 4-8, 7-4) (the Permit Application, Engineering Analysis, and Permit itself); (2) South Coast Air Quality Management Permit to Construct, Application 614275. Approved 1/2/20 (referenced on IS/ND, pp. 4-8, 7-4) (Permit Application, Engineering Analysis, and Permit itself); (3) South Coast Air Quality Management District Applications Evaluations and Calculations, Permit to Construct Evaluation, Application 614274. Approved 8/5/19 (referenced on IS/ND, pp. 4-9, 4-10, 7-4.); (4) All Inputs and Outputs used to Calculate VOC Emissions using U.S. EPA TANKS program (referenced on IS/ND, p. 4- 9 & Table 4.3-2.); (5) All inputs for CalEEMod model, including Engine Tiers for all construction equipment; (6) Supporting data for emissions in Tables 4.3 -2 and 4.3-4 of the IS/ND ; and (7) a copy of the unlocked excel spreadsheets for all of the requested modeling file s. Please refer to Responses to Comment s SFERCA-2 and SFERCA-6.

Response to Comment SFERCA-10
This is Exhibit B to SFERCA’s Comment Letter dated October 29, 2020, which is an email from the Long Beach Public Records Center in reference to Public Records Request reference # C008842-100920 dated October 19, 2020. The email provides notice to Mr. Paul Encinas that the time within which to identify responsive documents was being extended by fourteen (14) calendar days . No further response is required.

Response to Comment SFERCA-11
This is Exhibit B to SFERCA’s Comment Letter dated October 29, 2020, which is email correspondence dated October 19 , 2020 regarding Public Record s Request #C008842-100920 received by the Port on October 9, 2020. Please refer to Responses to Comments SFERCA-2 and SFERCA-6.

Response to Comment SFERCA-12
This is Exhibit B to SFERCA’s Comment Letter dated October 29, 2020, which is email correspondence dated October 20, 2020 regarding Public Records Request #C008842 -100920 received by the Port on

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October 9, 2020. The comment requests immediate access to documents referenced in the Negative Declaration. Please refer to Responses to Comments SFERCA-2 and SFERCA-6.

Response to Comment SFERCA-13
This is Exhibit B to SFERCA’s Comment Letter dated October 29, 2020, which is email confirmation from the Long Beach Public Records Center confirming submission of Public Records Request Reference #C008842-100920 received by the Port on October 9, 2020. No further response is required.

Response to Comment SFERCA-14
This is Exhibit B to SFERCA’s Comment Letter dated October 29, 2020, which is email confirmation from the City’s GovQA portal in reference to Public Records Request Reference #C008 8958-102020. The email dated October 20, 2020, provides a “Notice” that delays in response times may be experienced due to handling of high priority issues related to COVID -19, Government Code section 6253(c) . No further response is required.

Response to Comment SFERCA-15
This is Exhibit B to SFERCA’s Comment Letter dated October 29, 2020, an email response from Jose Cruz, POLB PRA Coordinator, via the City of Long Beach’s Public Records Requests system, GovQA , confirming that Public Records Request # C008958 -102020, originally received on October 12, 2020, has closed. No further response is required.

Response to Comment SFERCA-16
This is Exhibit B to SFERCA’s Comment Letter dated October 29, 2020, which is an email confirmation from the City of Long Beach’s Public Records Request system, dated October 21, 2020, that Public Records Request # C008958-102020 has been produced. No further response is required.

Response to Comment SFERCA-17
The comment summarizes SAFERCA’s understanding of the proposed Project. No further response is necessary.

Response to Comment SFERCA-18
The comment provides introductory text to the remainder of the comment letter. No further response is required.

Response to Comment SFERCA-19
The comment provides background information on SAFERCA. No further response is necessary.

Response to Comment SFERCA-20
The comment provides background on CEQA and the content and analysis required within an EIR and states that a Negative Declaration (for the proposed Project) is improper, and an EIR is required because the proposed Project may have a significant environmental impact. This is introductory text a nd supporting assertions are provided in the remainder of the comment letter. Please refer to Response s to Comments SFERCA-21 through SFERCA-43.

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Response to Comment SFERCA-21
The comment states that the Draft IS/ND provides an inadequate project description that fails to include all potential sources of emissions and therefore does not provide a complete and accurate description of the Project. The comment asserts that because the proposed Project would increase crude oil storage, it would increase crude oil throughput at refineries and result in an increase in refinery emissions.

Please refer to Responses to Comments EJ-13, EJ-14, EJ-19, EJ-20, EJ-21, and EJ-31. The IS/ND included all proposed Project construction and operation emissions sources, including non-stationary operation emissions sources, and minor increases to existing permitted emissions sources, which were not required to be evaluated in World Oil’s application for a SCAQMD permit to construct/permit to operate the new tanks.

Response to Comment SFERCA-22
The comment states that the Draft IS/ND is inadequate because it does not disclose what third -party vendors will do with the existing tanks once they are leased. IS/ND Project Description Sections 2.9 and

2.11 have been revised to clarify that when the existing tanks are leased out to third-party vendors, they are expected to store the same or similar fuel oils as have been historically stored, including different grades of marine fuels such as marine diesel oil, bunker fuel oil, and low sulfur fuel oil.

Response to Comment SFERCA-23
The comment states that the Applicant did not provide enough information to the consultant to “quantitatively estimate emission increases from operation of the new tanks.” Since the release of the Draft IS/ND in October 2020, d ue to the lapse of the previous application for a permit to construct, in February 2021, World Oil submitted to the SCAQMD a new application for a permit to construct/permit to operate for the two new tanks. In addition to the information provided in the previously submitted application, the new permit application includes an additional estimate by the Applicant for the number of new piping components and fugitive VOC e missions and estimates for the very small amount of H 2S
emissions from the operation of the new tanks. SCAQMD has reviewed this permit to construct/permit to operate application and completed its own VOC emissions estimate for the new tanks (SCAQMD, 2021b, 2021c). Final IS/ND Section 4.3 (Air Quality), Table 4.3 -2, has been updated to reflect the updated VOC operation emission estimate prepared by SCAQMD as part of its review of World Oil’s new permit to construct/permit to operate application for the new tanks.

As part of the new permit application, and through other information provided to POLB, World Oil provided the necessary information to estimate emissions from the following normal operation emissions sources:
• Tank emissions, now including H2S emissions.
• Tank piping component fugitive emissions
• Vehicle trip emissions increase
• Thermal oxidizer emissions increase
This list represents all of the direct and secondary emissions sources that would be affected by the operation of the new tanks. The increase in petroleum storage capacity would not direct ly affect the emissions from other facilities or fuel users.

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Please see Response s to Comments EJ-4, EJ-11, EJ-13, EJ-14, EJ-19, EJ-20, EJ-21, and EJ-31 in relation to comments regarding air permit application, H2S emissions, and life-cycle emissions.

Response to Comment SFERCA-24
This comment asserts that there is fair argument that construction emissions could be significant and further notes that the emissions estimate completed using CalEEMod assumed the use of Tier 4 engines , without identifying it properly as mitigation and so only provided a mitigated emissions estimate.

Construction emissions for the proposed P roject were calculated assuming CalEEMod fleet average off - road equipment and fleet average on-road vehicles. The “fleet average” is the unmitigated case assumed by CalEEMod. No off-road equipment engine mitigation was assumed in the CalEEMod emissions estimate. Fleet average for the assumed construction year (2021) is approximately equivalent on average to assuming Tier 3 equipment. Appendix A (Air Quality Emissions) shows that the exhaust emissions are the same in the unmitigated and mitigation construction emissions tables (see IS/ND Appendix A, pg. A- 3). The only emission reduction controls included in the construction emissions estimate, as summarized in IS/ND Table 4.3-1, were fugitive dust controls that would be required to comply with SCAQMD Rule 403 – Fugitive Dust, where compliance with existing law is considered part of the Project, and therefore is not identified as a mitigation measure. Additional clarification regarding the construction off-road equipment and on-road vehicle assumptions has been added to Final IS/ND Section 4.3 (Air Quality), above Table 4.3-

1. This uncontrolled construction emission estimate identified that all pollutant emissions rates are below SCAQMD daily regional and localized significance thresholds. Additionally, the conservatively calculated construction air toxics emissions health risks, combined with the SCAQMD calculated operation health risks were found to be below all SCAQMD health risk significance thresholds. Therefore, no construction emissions mitigation is required under CEQA for the proposed Project, nor does the analysis take credit for the use of Tier 4 off-road construction equipment.

While no mitigation is required under CEQA for the proposed Project, the POLB is expected to require the Project to use Tier 4 equipment as a Special Condition of the Project’s Harbor Development Permit (HDP) in accordance with the P ort’s Construction Air Quality Best Management Practice (BMP) for off -road equipment engines . Section 4.3 (Air Quality) and Section 5 (Application Summary Report) have been revised to add a new Special Condition to require the use of Tier 4 off-road engines in construction equipment. Use of Tier 4 off-road construction equipment for the proposed Project would substantially reduce the on-site construction NOx and DPM emissions from the estimated levels already found to create less than significant air quality impacts.

Response to Comment SFERCA-25
This comment states that there is fair argument that operation VOC emissions could be significant and further notes that the SCAQMD permitting emissions estimate using the U.S. EPA TANKS model provides underestimated emissions for the two new tanks. Please see Response to Comment EJ-9.

Response to Comment SFERCA-26
This comment states that the IS/ND omits numerous sources of VOC emissions associated with operations and fails to consider indirect emissions. A portion of this comment reiterates issues regarding use of the U.S. EPA TANKS emissions model. Please see Response to Comment EJ-9 which addresses SCAQMD revision from the use of the TANKS model to the use of the latest U.S. EPA AP -42 Section 7.1 Organic

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Liquid Storage Tank calculation methods to estimate emissions for the new tanks ’ air quality permit to construct/permit to operate application.

The comment also notes that tank dewatering emissions have not been considered. Please see Response to Comment EJ-14.

This comment also notes tank inspection and cleaning emissions have not been disclosed. The comment further notes that the VOC emissions during degassing and tank cleaning are essentially uncontrolled. This statement is not completely factual as emission controls are required during these tank inspection and cleaning events; these events occur with a very low frequency (approximately every 10 years). Specifically, tank inspection and cleaning events must comply with SCAQMD Rule 1149 – Storage Tank an d Pipeline Cleaning and Degassing. If a tank is subject to Rule 1149 at the time it is being emptied and prepared for cleaning, the vapor space of the tank will be vented (degassed) to a portable rental thermal oxidizer until the vapor space is monitored to be below 5,000 ppm for at least an hour. Vacuum trucks hired to assist in removal of material from a tank are required to comply with Rule 1149. World Oil verifies that vacuum trucks are compliant with AQMD rules prior to hiring. Typically, vacuum trucks are equipped with an integral carbon canister for organic vapor control or bring a towable trailer with carbon canister for organic vapor control. Vacuum truck operators are required to ensure that their equipment is leak free by monitoring their trucks and equipment each time they are used. Since these maintenance events are infrequent and controlled, and that regular emissions do not occur from the tanks concurrent with these maintenance events, the emissions from these events are not expected to increase the tanks VOC emissions above normal operations.

The emissions estimate for the two new petroleum storage tanks has been revised as part of the new Permit to Construct/Permit to Operate Application to the SCAQMD (see R esponse to Comment EJ-7).

SCAQMD is the responsible agency for the tank emissions estimate; however, the POLB has reviewed the new World Oil permit application for the two tanks, provide comments on the permit application, and continues to consult with SCAQMD during their permitting process. The IS/ND has been revised to address any changes and additions to the SCAQMD emissions estimate for the new permit application.

Response to Comment SFERCA-27
The comment states that the IS/ND improperly relies on emission offsets to reduce VOC emissions and that VOC offsets are not valid to be used for CEQA mitigation.

The IS/ND does not rely on emissions offsets to reduce or mitigate VOC emissions under CEQA . The proposed Project’s operation VOC emissions are presented in the IS/ND, without taking into consideration use of the emissions reduction credits required for permitting (see IS/ND Table 4.3 -2). T he proposed Project’s operation VOC emissions are well below the SCAQMD emissions significance thresholds and therefore do not require mitigation. VOC emissions offsets are specifically discussed as a requirement of SCAQMD for permitting the new tanks (SCAQMD, 2021c) . The IS/ND indicates that VOC emissions reduction will be achieved using the emissions reduction credits in a footnote to the operation emissions table; however, use of the emissions offsets is in no way relied on to make CEQA emissions impact determinations for the proposed Project.

Response to Comment SFERCA-28
This comment notes that evidence support s a fair argument that the P roject will produce cumulatively considerable air quality impacts. Please see Responses to Comments EJ-13 and EJ-15.

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Response to Comment SFERCA-29
This comment contends that there is a fair argument that the Project would result in potentially significant health risk impacts, that the IS/ND did not provide a discussion, supported by evidence, of the nature and magnitude of impacts of air pollution on public health. The comment also argues that the IS/ND was legally deficient as the risk assessment modeling should have been supplied with the IS/ND. The comment provides the following additional specific arguments:
• The Project’s VOC emissions and benzene emissions are underestimated, so the actual health risk would be significant.
• The significant health impacts are undisclosed and were not mitigated. • The IS/ND did not evaluate impacts to all sensitive receptors in the project vicinity. • The IS/ND did not evaluate health impacts from the P roject’s VOC emissions downwind ozone formation.

The air quality impacts assessment was prepared in accordance with published SCAQMD methods and guidelines that include assessment of regional impacts, localized impacts for criteria pollutants, and health risk assessment (cancer, chronic, acute health impacts) for toxic air contaminants. Discussion, supported by evidence, was provided for these impact analyses.

Please see Response to Comment EJ-9 that addresses similar comments related to the VOC and benzene emissions estimates. The VOC and benzene emissions associated with operation of the proposed new tanks were estimated by SCAQMD, as the responsible agency for issuing the permit to construct/permit to operate, using U.S. EPA-approved emissions estimation methods (SCAQMD, 2021b, 2021c).

The IS/ND disclosed the nearest sensitive receptor locations, identified their locations and distances from the project site, and provided the worst-case risks identified for the maximum exposed sensitive receptor location. Given that the worst-case health risk impacts were found to be less than significant no additional analysis was necessary. There is no requirement to list all sensitive receptors surrounding a site that would be subject to less than significant project impacts. See also Response to Comment EJ-10.

Downwind ozone formation resulting from VOC emissions as a precursor pollutant in the regional context would be indirect, in contrast with the direct effects of Project’s TAC emissions health risk impacts addressed above. SCAQMD control strategies in the AQMP are designed to address downwind ozone formation and prevent adverse ozone health risks in the region. The IS/ND shows that the proposed Project would not conflict with the AQMP, and VOC emissions of less than 11 lbs/day (as shown in IS/ND Table 4.3-2) would be well below the SCAQMD daily emissions thresholds that are set at levels to identify potentially significant impacts to ozone from VOC as a precursor. For context , these emissions would be a 0.000026 fraction of the daily VOC emissions estimated for the Los Angeles portion of the South Coast Air Basin in 2020 (CARB, 2016).
9 No additional analysis is necessary.

Response to Comment SFERCA-30
The comment asserts that the proposed P roject is inconsistent with the City of Long Beach General Plan Land Use Element. The proposed P roject does not result in significant air quality impacts or cumulative impacts and thus, does not require mitigation. The proposed P roject would result in negligible emissions during construction and operation that are well below SCAQMD health risk significance thresholds.

9Assumes VOC is equivalent to ROG for this type of emissions source.

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Therefore, the proposed Project is not inconsistent with the City’s General Plan. Please also refer to Response to Comment EJ-15.

The comment also asserts that the proposed P roject is inconsistent with the Port Master Plan (PMP).

Section IV (Land Use Designations, Goals, Objectives, and Lon g-Range Plans ) of the Port Master Plan, Update 1990 states the following (POLB, 1990):

The long-range planning goals and objectives for the Port are essential for developing policies involving future Port development and expansion. These planning goals are intended to be general to maintain flexibility and respond to Port tenant needs. In addition, since development policies are driven by national and international economic trends, general goals allow the Port to respond to immediate and short -term requirements dictated by these trends.

The POLB’s planning goals include the following:
 Goal 1. Consolidating similar and compatible land and water areas  Goal 2. Encouraging maximum use of facilities
 Goal 3. Improving terminal circulation involving roadways and rail  Goal 4. Providing for the safe cargo handling and movement of vessels within the port  Goal 5. Developing land for primary port facilities and port-related uses  Goal 6. Protecting, maintaining, and enhancing the overall quality of the coastal environment The proposed Project would occur in an existing terminal and continue to support similar operations. The proposed Project would support the modernization and efficiency of the existing World Oil Terminal by increasing liquid bulk capacity a nd maximizing the use of the existing facility. Based on the Land Use Designations, Goals, Objectives, and Long -Range Plans chapter of the PMP, development that accommodates the consolidation of land uses and encourages the maximum use of facilities is consistent with the POLB’s goals.

The comment also states that the proposed P roject is inconsistent with the PMP’s permitting policies because the P roject has not yet met the requirements of CEQA and thus, the Board of Harbor Commissioners may not approve the application for the Harbor Development Permit (HDP).

As stated in IS/ND Section 1.1 (Proposed Project Overview), Ribost Terminal LLC, DBA World Oil Terminals (World Oil) filed an Application for a n HDP with the POLB on August 14, 2019, to construct and operate the proposed Project. As a public agency, with jurisdiction and discretionary authority for the issuance of HDPs in the Long Beach Harbor District, pursuant to the California Coastal Act and Long Beach City Charter 1215, the POLB, acting by and through the Board of Harbor Commissioners , is required to comply with CEQA by analyzing the potential environmental impacts o f the proposed Project. As such, this IS/ND and Application Summary Report (Section 5.0 of the IS/ND) have been prepared in accordance with CEQA and the Port’s Guidelines for the Implementation of the Certified PMP. A Notice of Intent to adopt the ND and public hearing will be issued for the Long Beach Board of Harbor Commissioners to consider adoption/approval of the IS/ND and Application Summary Report and issuance of an HDP for the proposed Project. Please also see IS/ND Section 1.2.1 (CEQA Process).

Therefore, the proposed Project is consistent with the PMP’s permitting policies.

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Response to Comment SFERCA-31
The comment states that approval of the proposed P roject would violate the California Coastal Act because it would result in significant air quality and public health impacts and fails to minimize these impacts. Please refer to Response to Comment EJ -15 regarding the proposed P roject’s cumulative air quality impacts. The proposed Project would not result in any significant or cumulatively considerable air quality or public health impacts and therefore, does not require mitigation. Approval of the proposed Project would not violate the California Coastal Act. Please refer to Responses to Comment SFERCA-30 regarding the proposed Project’s conformance with the certified PMP and Comment Set CCC. Please also refer to IS/ND Section 5.1 (California Coastal Act Consistency Analysis) for a discussion of how the proposed Project is consistent with the California Coastal Act.

Response to Comment SFERCA-32
The comment concludes the previous statements made, and states that the Draft IS/ND must be thoroughly revised and recirculated as an EIR. Please see Responses to Comment EJ -15 and SFERCA-21 through SFERCA-31.

Response to Comment SFERCA-33
The comment summarizes the proposed Project. No further response is required.

Response to Comment SFERCA-34
The comment provides introductory text stating that the Draft IS/ND is incomplete, has failed to identify and mitigate significant environmental impacts, and that an EIR must be prepared. Please see Responses to Comment SFERCA-35 through SFERCA-43.

Response to Comment SFERCA-35
The comment references the Technical Appendix’s author, Phyllis Fox’s resume and experience . No further response required.

Response to Comment SFERCA-36
This comment states that the Project’s construction emissions are significant and that emissions calculations are unsupported. Please see Response to Comment SFERCA -2. All requested files , including emissions estimate files, have been prov ided in a readily accessible format, or in the requested format such as the CalEEMod input file.

The comment asserts that construction schedule, equipment use, equipment horsepower, etc. are not provided; however, the CalEEMod output file presented in Appendix A provides all this information (See IS/ND Appendix A, pg. A -4). The comment further notes that the PRA request ed all the CalEEMod files, specifically inputs including information on engine tiers for construction equipment and instead an Excel spreadsheet that was not the input file was provided that summarized input values. CalEEMod input files are saved in the fo rm of Excel files (.xls), and th e Excel file provides all assumed inputs values . T his CalEEMod input Excel file was provided along with the CalEEMod output file. All unedited original format emissions and health risk assessment files, which are requested by SCAQMD to be provided with CEQA documents, were provided to address the PRA request. Please also see Response to Comment SFERCA-24.

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The comment also presents a CalEEMod input file off-road equipment table from an air quality screening analysis performed prior to the start of the IS/ND, which helped the POLB assess whether the proposed Project would result in significant air quality impacts . This air quality screening analysis used preliminary project information and was not used in the Draft IS/ND. These preliminary air quality screening emissions files were provided to fully address the PRA request.

The Draft IS/ND emissions input and output files were also provided as part of the PRA request. T hese files show that Tier 4 equipment w as not assumed in the construction emissions analysis. See also Response to Comment SFERCA-24.

Response to Comment SFERCA-37
This comment is from the attached Technical Appendix to the Comment Letter and provides additional details to support Comment SFERCA-24. Please see Response to Comment SFERCA-24.

Response to Comment SFERCA-38
This comment is from the attached Technical Appendix to the Comment Letter and provides additional details to support Comment SFERCA-25. Please see Response to Comment SFERCA-25.

Response to Comment SFERCA-39
This comment is from the attached Technical Appendix to the Comment Letter and provides additional details to support Comment SFERCA-26. Please see Response to Comment SFERCA-26.

Response to Comment SFERCA-40
This comment is from the attached Technical Appendix to the Comment Letter and provides additional details to support Comment SFERCA-27. Please see Response to Comment SFERCA-27.

Response to Comment SFERCA-41
This comment is from the attached Technical Appendix to the Comment Letter and provides additional details to support Comment SFERCA-29. Please see Response to Comment SFERCA-29.

Response to Comment SFERCA-42
This comment is from the attached Technical Appendix to the Comment Letter and provides additional details to support Comments SFERCA -28 and SFERCA-29. Please see R esponse to Comments SFERCA-28 and SFERCA-29.

Response to Comment SFERCA-43
This comment states that the IS/ND failed to demonstrate that the increase in VOC emissions would not cause a violation or make significantly worse an existing violation of [ozone], resulting in significant health impacts. Please see Response to Comment EJ-10.

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DF – Dianne Flowers

DF-1
DF-2
DF-3

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DF-3
cont.

DF-5
DF-4

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Response to Comments – DF
Dianne Flowers
November 20, 2020
Response to Comment DF-1
Thank you for your review of the Draft IS/ND. The comment states that the POLB must deny the proposed Project because it would increase fuel capacity at a fossil fuel facility, whereas the POLB should be incrementally reducing existing fossil fuel faciliti es instead to meet zero emission target dates . Your opposition to and comments on the proposed Project are acknowledged for the record and are before the decision-makers for their consideration prior to taking any action on the proposed Project.

World Oil Terminals operates their facility on privately owned property at Pier C within the Long Beach Harbor District. The POLB is obligated to review the proposed Project under CEQA for the issuance of a Harbor Development Permit, which is a consolidated coastal development permit pursuant to the California Coastal Act of 1976 and a building permit pursuant to Long Beach City Charter Section 1215.

The proposed Project would not involve or affect other fossil fuel facilities such as oil production sites or refinery activities because the facility’s purpose is solely to store and transport petroleum products. This limited project purpose does not involve large emissions sources. Petroleum production and refining processes are separate activities not influenced by the proposed Project’s storage capacity. The proposed Project would nominally increase fuel storage capacity at the facility to allow for overall terminal operational efficiencies. As discussed in Section 2.11 (Operations and Maintenance) of the IS/ND, t he proposed Project would not allow for greater actual crude throughput beyond the permitted limits through the pipelines, tanks, or loading racks.

The facility and its use are allowable within Long Beach Harbor Planning District 2 – Northeast Harbor under the POLB’s certified 1990 PMP. Please see Response to Comment SFERCA-30 regarding the Project’s consistency with the PMP. As described in IS/ND Section 2.6 (General Plan Designation), the City of Long Beach General Plan Land Use Element designates the pr oject area as a Regional -Serving Facility, which allows for “businesses and operations that not only serve the City of Long Beach, but also the region and parts of the nation.” This zoning type is consistent with Light, Medium, General, and Port-related Industrial Zoning Districts.

The commenter asserts that the Port “should be looking to implement plans for incremental reductions in existing fossil fuel facilities in order to meet zero emission target dates .” The IS/ND Section 4.8 (Greenhouse Gas Emissions) identifies the Port’s Clean Air Action Plan ( CAAP) and regulations under the Low Carbon Fuel Standard that drive progress towards zero emissions efforts. Compliance with the State Low Carbon Fuel Standard regulations will drive f uel suppliers to transition away from fossil fuel production and into renewable fuels (such as biofuels ) over time ( ADI Analytics , 2021) . The proposed Project could aid World Oil’s future ability to transition to the storage of renewable fuels (for example, by replacing petroleum storage with waste vegetable oil storage) , if required in the future to comply with State regulations (ADI Analytics, 2021) . Any future modifications at the facility needed to implement storage of renewable fuels would be subject to CEQA and review, as applicable if appropriate.

See also Responses to Comments CP-1 and EJ-19.

World Oil Tank Installation Project
Final Negative Declaration and Application Summary Report

September 2021 8-224
Response to Comment DF-2
The comment states that an ND is insufficient, and a full environmental review must be completed. The POLB, as the lead agency, followed the environmental review process required by CEQA, beginning with an IS (State CEQA Guidelines Section 15063). Information from an IS provides the basis for a lead a gency under CEQA to determine whether an environmental impact report (EIR) is necessary or if a project can be modified to mitigate adverse environmental effects before an (EIR) is prepared. The IS/ND is adequate and complete because it sufficiently analyzes all potential environmental impacts, concluding that the proposed Project would have less-than-significant impacts to the environment, including air quality, public health, and climate change (see IS/ND Section 4.2 [Air Quality ] and Section 4.8 [Greenhouse Gas Emissions]). As such, mitigation measures are not required for the proposed Project. Please also see Responses to Comments EJ-13, EJ-14, EJ-19, EJ-20, EJ-21, and EJ-31.

Response to Comment DF-3
The comment does not provide any specific questions or comments on the Draft IS/ND or the proposed Project, but rather expresses concern that communities near the Port of Long Beach have been adversely impacted by the COVID -19 pandemic and the pollution from the ports and ports -generated goods movement. The proposed Project would not involve the use of cruise ships, cargo ships, or oil tankers during construction or operation. Because this comment is general and does not relate to the content or adequacy of the Draft IS/ND, no formal response is required under CEQA.

Response to Comment DF-4
This comment does not provide any specific questions or comments on the Draft IS/ND or the proposed Project. The commenter expresses concern about air quality, public health, and climate change related to wildfires and port and freight activity. As discussed in the IS/ND, the proposed Project would not result in any significant impacts to the environment. Please also refer to Responses to Comments DF-1, DF-2, DF- 3, and SFERCA-30.

Response to Comment DF-5
The comment requests that the POLB deny the proposed Project and complete an EIR because a n ND is improper. However, the commenter does not provide evidence from the IS/ND that supports why it is an insufficient document. Please also see Responses to Comment DF-1 through DF-4.

Appendix A
Air Quality Emissions

A-1

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population User Defined Industrial 2.00 User Defined Unit 0.30 0.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
11 Wind Speed (m/s) Precipitation Freq (Days)2.2 33

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Southern California Edison
2022Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)

0.006N2O Intensity

(lb/MWhr)
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:04 AM World Oil Tanks Installation - Los Angeles-South Coast County, Summer World Oil Tanks Installation
Los Angeles-South Coast County, Summer
Project Characteristics - Two Tank Construction Project Land Use - Tank Area Assumed to be 180' by 80'
Construction Phase - Applicant dates for first two tasks, added a finishing task with tank painting and mechanical/piping interconnection.

Off-road Equipment - Added a man lift to the CalEEMod default for this phase.

Off-road Equipment - Applicant equipment list plus the addition of an excavator and grader for grading purposes. Used CalEEMod default for hp, except where

applicant estimate was greater
Off-road Equipment - Added welders to the equipment list for tank erection, using CalEEMod default horsepower.

Off-road Equipment - Applicants equipment HP corrected using CalEEMod defaults, Bore/drill rig category used for pile driver.

Trips and VMT - From applicant, with addition for architectural coating workers and fuel/sanitary, etc. vendor trips. Used CalEEMod trip distance defaults, except for site preparation phase haul trips which was adjusted to applicant assumptions.

Grading - Conservative assumptions, including no backloading, on bulk material import/export.

Architectural Coating - Coating VOC emissions, due to variable paint types and coating thickness assumptions, are calculated separately.

Construction Off-road Equipment Mitigation - Assumes SCAQMD Rule 403 compliant watering during excavation/foundation phases where there is exposed areas and bulk material handling.

A-2

2.0 Emissions Summary

2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2021 3.1789 32.2635 23.2204 0.0605 0.5040 1.2945 1.7985 0.1341 1.2015 1.3356 0.0000 5,865.659 1 5,865.659
1 1.5574 0.0000 5,904.592
7 Maximum 3.1789 32.2635 23.2204 0.0605 0.5040 1.2945 1.7985 0.1341 1.2015 1.3356 0.0000 5,865.659 1 5,865.659
1 1.5574 0.0000 5,904.592
7 Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2021 3.1789 32.2635 23.2204 0.0605 0.4993 1.2945 1.7938 0.1336 1.2015 1.3351 0.0000 5,865.659 1 5,865.659
1 1.5574 0.0000 5,904.592
7 Maximum 3.1789 32.2635 23.2204 0.0605 0.4993 1.2945 1.7938 0.1336 1.2015 1.3351 0.0000 5,865.659 1 5,865.659
1 1.5574 0.0000 5,904.592
7 Mitigated Construction
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:04 AM World Oil Tanks Installation - Los Angeles-South Coast County, Summer ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.93 0.00 0.26 0.42 0.00 0.04 0.00 0.00 0.00 0.00 0.00 0.00 A-3

3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Site Preparation Site Preparation 1/4/2021 5/10/2021 5 91 Excavation 2 Tank Construction Building Construction 4/26/2021 10/28/2021 5 134 Tank Erection 3 Architectural Coating Architectural Coating 10/18/2021 11/18/2021 5 24 Tank painting and piping/mechanical
Acres of Grading (Site Preparation Phase): 0.5; Acres of Grading (Grading Phase): 0; Acres of Paving: 0; Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural Coating ±sqft) OffRoad Equipment
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:04 AM World Oil Tanks Installation - Los Angeles-South Coast County, Summer Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Site Preparation Bore/Drill Rigs 1 7.00 350 0.50
Site Preparation Cranes 2 7.00 231 0.29
Site Preparation Excavators 1 7.00 158 0.38
Site Preparation Graders 1 7.00 187 0.41
Site Preparation Tractors/Loaders/Backhoes 3 7.00 97 0.37 Tank Construction Aerial Lifts 1 3.00 63 0.31
Tank Construction Cranes 2 3.00 231 0.29
Tank Construction Welders 2 7.00 46 0.45
Architectural Coating Aerial Lifts 1 6.00 63 0.31
Architectural Coating Air Compressors 1 6.00 78 0.48
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Site Preparation 8 16.00 2.00 278.00 14.70 6.90 40.00 LD_Mix HDT_Mix HHDT Tank Construction 5 16.00 2.00 48.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Architectural Coating 2 8.00 2.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT A-4

3.2 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 7.6700e-
003

0.0000 7.6700e-
003

9.1000e-
004

0.0000 9.1000e-
004

0.0000 0.0000
Off-Road 2.1271 23.8277 16.5528 0.0417 1.0039 1.0039 0.9236 0.9236 4,035.6111 4,035.6111 1.3052 4,068.241 0 Total 2.1271 23.8277 16.5528 0.0417 7.6700e-
003

1.0039 1.0116 9.1000e-
004

0.9236 0.9245 4,035.611
1 4,035.611
1 1.3052 4,068.241
0 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0461 1.3542 0.3493 4.4400e-
003

0.1068 4.9200e-
003

0.1117 0.0293 4.7100e-
003

0.0340 482.2464 482.2464 0.0303 483.0050
Vendor 6.0800e-
003

0.1942 0.0508 5.1000e-
004

0.0128 4.0000e-
004

0.0132 3.6900e-
003

3.8000e-
004

4.0700e-
003

54.9761 54.9761 3.2400e-
003

55.0571
Worker 0.0686 0.0471 0.6444 1.8300e-
003

0.1788 1.4500e-
003

0.1803 0.0474 1.3300e-
003

0.0488 182.2032 182.2032 5.3700e-
003
182.3374
Total 0.1208 1.5956 1.0445 6.7800e-
003

0.2984 6.7700e-
003

0.3052 0.0804 6.4200e-
003

0.0868 719.4257 719.4257 0.0390 720.3995
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:04 AM World Oil Tanks Installation - Los Angeles-South Coast County, Summer

3.1 Mitigation Measures Construction
Water Exposed Area
A-5

3.2 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 2.9900e-
003

0.0000 2.9900e-
003

3.5000e-
004

0.0000 3.5000e-
004

0.0000 0.0000
Off-Road 2.1271 23.8277 16.5528 0.0417 1.0039 1.0039 0.9236 0.9236 0.0000 4,035.6111 4,035.6111 1.3052 4,068.241 0 Total 2.1271 23.8277 16.5528 0.0417 2.9900e-
003

1.0039 1.0069 3.5000e-
004

0.9236 0.9239 0.0000 4,035.611
1 4,035.611
1 1.3052 4,068.241
0 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0461 1.3542 0.3493 4.4400e-
003

0.1068 4.9200e-
003

0.1117 0.0293 4.7100e-
003

0.0340 482.2464 482.2464 0.0303 483.0050
Vendor 6.0800e-
003

0.1942 0.0508 5.1000e-
004

0.0128 4.0000e-
004

0.0132 3.6900e-
003

3.8000e-
004

4.0700e-
003

54.9761 54.9761 3.2400e-
003

55.0571
Worker 0.0686 0.0471 0.6444 1.8300e-
003

0.1788 1.4500e-
003

0.1803 0.0474 1.3300e-
003

0.0488 182.2032 182.2032 5.3700e-
003
182.3374
Total 0.1208 1.5956 1.0445 6.7800e-
003

0.2984 6.7700e-
003

0.3052 0.0804 6.4200e-
003

0.0868 719.4257 719.4257 0.0390 720.3995
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:04 AM World Oil Tanks Installation - Los Angeles-South Coast County, Summer A-6

3.3 Tank Construction - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.8534 6.5028 4.9054 9.4300e-
003

0.2817 0.2817 0.2695 0.2695 843.1225 843.1225 0.2025 848.1858 Total 0.8534 6.5028 4.9054 9.4300e-
003

0.2817 0.2817 0.2695 0.2695 843.1225 843.1225 0.2025 848.1858 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 2.9900e-
003

0.0961 0.0225 2.8000e-
004

6.2600e-
003

2.9000e-
004

6.5600e-
003

1.7200e-
003

2.8000e-
004

2.0000e-
003

30.3205 30.3205 2.0600e-
003

30.3719
Vendor 6.0800e-
003

0.1942 0.0508 5.1000e-
004

0.0128 4.0000e-
004

0.0132 3.6900e-
003

3.8000e-
004

4.0700e-
003

54.9761 54.9761 3.2400e-
003

55.0571
Worker 0.0686 0.0471 0.6444 1.8300e-
003

0.1788 1.4500e-
003

0.1803 0.0474 1.3300e-
003

0.0488 182.2032 182.2032 5.3700e-
003
182.3374
Total 0.0777 0.3374 0.7177 2.6200e-
003

0.1979 2.1400e-
003

0.2001 0.0528 1.9900e-
003

0.0548 267.4998 267.4998 0.0107 267.7664
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:04 AM World Oil Tanks Installation - Los Angeles-South Coast County, Summer A-7

3.3 Tank Construction - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.8534 6.5028 4.9054 9.4300e-
003

0.2817 0.2817 0.2695 0.2695 0.0000 843.1225 843.1225 0.2025 848.1858 Total 0.8534 6.5028 4.9054 9.4300e-
003

0.2817 0.2817 0.2695 0.2695 0.0000 843.1225 843.1225 0.2025 848.1858 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 2.9900e-
003

0.0961 0.0225 2.8000e-
004

6.2600e-
003

2.9000e-
004

6.5600e-
003

1.7200e-
003

2.8000e-
004

2.0000e-
003

30.3205 30.3205 2.0600e-
003

30.3719
Vendor 6.0800e-
003

0.1942 0.0508 5.1000e-
004

0.0128 4.0000e-
004

0.0132 3.6900e-
003

3.8000e-
004

4.0700e-
003

54.9761 54.9761 3.2400e-
003

55.0571
Worker 0.0686 0.0471 0.6444 1.8300e-
003

0.1788 1.4500e-
003

0.1803 0.0474 1.3300e-
003

0.0488 182.2032 182.2032 5.3700e-
003
182.3374
Total 0.0777 0.3374 0.7177 2.6200e-
003

0.1979 2.1400e-
003

0.2001 0.0528 1.9900e-
003

0.0548 267.4998 267.4998 0.0107 267.7664
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:04 AM World Oil Tanks Installation - Los Angeles-South Coast County, Summer A-8

3.4 Architectural Coating - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Archit. Coating 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.2470 1.9773 2.6381 4.2300e-
003

0.1027 0.1027 0.1020 0.1020 403.4129 403.4129 0.0588 404.8820 Total 0.2470 1.9773 2.6381 4.2300e-
003

0.1027 0.1027 0.1020 0.1020 403.4129 403.4129 0.0588 404.8820 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 6.0800e-
003

0.1942 0.0508 5.1000e-
004

0.0128 4.0000e-
004

0.0132 3.6900e-
003

3.8000e-
004

4.0700e-
003

54.9761 54.9761 3.2400e-
003

55.0571
Worker 0.0343 0.0236 0.3222 9.1000e-
004

0.0894 7.2000e-
004

0.0901 0.0237 6.7000e-
004

0.0244 91.1016 91.1016 2.6800e-
003

91.1687
Total 0.0404 0.2178 0.3730 1.4200e-
003

0.1022 1.1200e-
003

0.1033 0.0274 1.0500e-
003

0.0285 146.0777 146.0777 5.9200e-
003
146.2258
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:04 AM World Oil Tanks Installation - Los Angeles-South Coast County, Summer A-9

3.4 Architectural Coating - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Archit. Coating 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.2470 1.9773 2.6381 4.2300e-
003

0.1027 0.1027 0.1020 0.1020 0.0000 403.4129 403.4129 0.0588 404.8820 Total 0.2470 1.9773 2.6381 4.2300e-
003

0.1027 0.1027 0.1020 0.1020 0.0000 403.4129 403.4129 0.0588 404.8820 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 6.0800e-
003

0.1942 0.0508 5.1000e-
004

0.0128 4.0000e-
004

0.0132 3.6900e-
003

3.8000e-
004

4.0700e-
003

54.9761 54.9761 3.2400e-
003

55.0571
Worker 0.0343 0.0236 0.3222 9.1000e-
004

0.0894 7.2000e-
004

0.0901 0.0237 6.7000e-
004

0.0244 91.1016 91.1016 2.6800e-
003

91.1687
Total 0.0404 0.2178 0.3730 1.4200e-
003

0.1022 1.1200e-
003

0.1033 0.0274 1.0500e-
003

0.0285 146.0777 146.0777 5.9200e-
003
146.2258
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:04 AM World Oil Tanks Installation - Los Angeles-South Coast County, Summer A-10

2.0 Emissions Summary

2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2021 3.1956 32.3049 23.1325 0.0602 0.5040 1.2945 1.7985 0.1341 1.2016 1.3357 0.0000 5,836.354 3 5,836.354
3 1.5578 0.0000 5,875.299
7 Maximum 3.1956 32.3049 23.1325 0.0602 0.5040 1.2945 1.7985 0.1341 1.2016 1.3357 0.0000 5,836.354 3 5,836.354
3 1.5578 0.0000 5,875.299
7 Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2021 3.1956 32.3049 23.1325 0.0602 0.4993 1.2945 1.7938 0.1336 1.2016 1.3351 0.0000 5,836.354 3 5,836.354
3 1.5578 0.0000 5,875.299
7 Maximum 3.1956 32.3049 23.1325 0.0602 0.4993 1.2945 1.7938 0.1336 1.2016 1.3351 0.0000 5,836.354 3 5,836.354
3 1.5578 0.0000 5,875.299
7 Mitigated Construction
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:06 AMWorld Oil Tanks Installation - Los Angeles-South Coast County, Winter World Oil Tanks Installation
Los Angeles-South Coast County, Winter
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.93 0.00 0.26 0.42 0.00 0.04 0.00 0.00 0.00 0.00 0.00 0.00 A-11

3.2 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 7.6700e-
003

0.0000 7.6700e-
003

9.1000e-
004

0.0000 9.1000e-
004

0.0000 0.0000
Off-Road 2.1271 23.8277 16.5528 0.0417 1.0039 1.0039 0.9236 0.9236 4,035.611 1 4,035.6111 1.3052 4,068.241
0 Total 2.1271 23.8277 16.5528 0.0417 7.6700e-
003

1.0039 1.0116 9.1000e-
004

0.9236 0.9245 4,035.611
1 4,035.611
1 1.3052 4,068.241
0 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0467 1.3852 0.3597 4.4000e-
003

0.1068 4.9600e-
003

0.1117 0.0293 4.7400e-
003

0.0340 477.7669 477.7669 0.0310 478.5408
Vendor 6.3800e-
003

0.1938 0.0562 5.0000e-
004

0.0128 4.1000e-
004

0.0132 3.6900e-
003

3.9000e-
004

4.0800e-
003

53.4691 53.4691 3.4500e-
003

53.5554
Worker 0.0763 0.0522 0.5892 1.7200e-
003

0.1788 1.4500e-
003

0.1803 0.0474 1.3300e-
003

0.0488 171.5602 171.5602 5.0500e-
003
171.6864
Total 0.1294 1.6312 1.0051 6.6200e-
003

0.2984 6.8200e-
003

0.3052 0.0804 6.4600e-
003

0.0869 702.7962 702.7962 0.0395 703.7825
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:06 AM World Oil Tanks Installation - Los Angeles-South Coast County, Winter A-12

3.2 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 2.9900e-
003

0.0000 2.9900e-
003

3.5000e-
004

0.0000 3.5000e-
004

0.0000 0.0000
Off-Road 2.1271 23.8277 16.5528 0.0417 1.0039 1.0039 0.9236 0.9236 0.0000 4,035.6111 4,035.6111 1.3052 4,068.241 0 Total 2.1271 23.8277 16.5528 0.0417 2.9900e-
003

1.0039 1.0069 3.5000e-
004

0.9236 0.9239 0.0000 4,035.611
1 4,035.611
1 1.3052 4,068.241
0 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0467 1.3852 0.3597 4.4000e-
003

0.1068 4.9600e-
003

0.1117 0.0293 4.7400e-
003

0.0340 477.7669 477.7669 0.0310 478.5408
Vendor 6.3800e-
003

0.1938 0.0562 5.0000e-
004

0.0128 4.1000e-
004

0.0132 3.6900e-
003

3.9000e-
004

4.0800e-
003

53.4691 53.4691 3.4500e-
003

53.5554
Worker 0.0763 0.0522 0.5892 1.7200e-
003

0.1788 1.4500e-
003

0.1803 0.0474 1.3300e-
003

0.0488 171.5602 171.5602 5.0500e-
003
171.6864
Total 0.1294 1.6312 1.0051 6.6200e-
003

0.2984 6.8200e-
003

0.3052 0.0804 6.4600e-
003

0.0869 702.7962 702.7962 0.0395 703.7825
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:06 AM World Oil Tanks Installation - Los Angeles-South Coast County, Winter A-13

3.3 Tank Construction - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.8534 6.5028 4.9054 9.4300e-
003

0.2817 0.2817 0.2695 0.2695 843.1225 843.1225 0.2025 848.1858 Total 0.8534 6.5028 4.9054 9.4300e-
003

0.2817 0.2817 0.2695 0.2695 843.1225 843.1225 0.2025 848.1858 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 3.0600e-
003

0.0973 0.0239 2.7000e-
004

6.2600e-
003

3.0000e-
004

6.5600e-
003

1.7200e-
003

2.9000e-
004

2.0000e-
003

29.7952 29.7952 2.1300e-
003

29.8485
Vendor 6.3800e-
003

0.1938 0.0562 5.0000e-
004

0.0128 4.1000e-
004

0.0132 3.6900e-
003

3.9000e-
004

4.0800e-
003

53.4691 53.4691 3.4500e-
003

53.5554
Worker 0.0763 0.0522 0.5892 1.7200e-
003

0.1788 1.4500e-
003

0.1803 0.0474 1.3300e-
003

0.0488 171.5602 171.5602 5.0500e-
003
171.6864
Total 0.0857 0.3432 0.6693 2.4900e-
003

0.1979 2.1600e-
003

0.2001 0.0528 2.0100e-
003

0.0548 254.8245 254.8245 0.0106 255.0903
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:06 AM World Oil Tanks Installation - Los Angeles-South Coast County, Winter A-14

3.3 Tank Construction - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.8534 6.5028 4.9054 9.4300e-
003

0.2817 0.2817 0.2695 0.2695 0.0000 843.1225 843.1225 0.2025 848.1858 Total 0.8534 6.5028 4.9054 9.4300e-
003

0.2817 0.2817 0.2695 0.2695 0.0000 843.1225 843.1225 0.2025 848.1858 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 3.0600e-
003

0.0973 0.0239 2.7000e-
004

6.2600e-
003

3.0000e-
004

6.5600e-
003

1.7200e-
003

2.9000e-
004

2.0000e-
003

29.7952 29.7952 2.1300e-
003

29.8485
Vendor 6.3800e-
003

0.1938 0.0562 5.0000e-
004

0.0128 4.1000e-
004

0.0132 3.6900e-
003

3.9000e-
004

4.0800e-
003

53.4691 53.4691 3.4500e-
003

53.5554
Worker 0.0763 0.0522 0.5892 1.7200e-
003

0.1788 1.4500e-
003

0.1803 0.0474 1.3300e-
003

0.0488 171.5602 171.5602 5.0500e-
003
171.6864
Total 0.0857 0.3432 0.6693 2.4900e-
003

0.1979 2.1600e-
003

0.2001 0.0528 2.0100e-
003

0.0548 254.8245 254.8245 0.0106 255.0903
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:06 AM World Oil Tanks Installation - Los Angeles-South Coast County, Winter A-15

3.4 Architectural Coating - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Archit. Coating 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.2470 1.9773 2.6381 4.2300e-
003

0.1027 0.1027 0.1020 0.1020 403.4129 403.4129 0.0588 404.8820 Total 0.2470 1.9773 2.6381 4.2300e-
003

0.1027 0.1027 0.1020 0.1020 403.4129 403.4129 0.0588 404.8820 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 6.3800e-
003

0.1938 0.0562 5.0000e-
004

0.0128 4.1000e-
004

0.0132 3.6900e-
003

3.9000e-
004

4.0800e-
003

53.4691 53.4691 3.4500e-
003

53.5554
Worker 0.0382 0.0261 0.2946 8.6000e-
004

0.0894 7.2000e-
004

0.0901 0.0237 6.7000e-
004

0.0244 85.7801 85.7801 2.5200e-
003

85.8432
Total 0.0445 0.2199 0.3508 1.3600e-
003

0.1022 1.1300e-
003

0.1034 0.0274 1.0600e-
003

0.0285 139.2492 139.2492 5.9700e-
003
139.3986
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:06 AM World Oil Tanks Installation - Los Angeles-South Coast County, Winter A-16

3.4 Architectural Coating - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Archit. Coating 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.2470 1.9773 2.6381 4.2300e-
003

0.1027 0.1027 0.1020 0.1020 0.0000 403.4129 403.4129 0.0588 404.8820 Total 0.2470 1.9773 2.6381 4.2300e-
003

0.1027 0.1027 0.1020 0.1020 0.0000 403.4129 403.4129 0.0588 404.8820 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 6.3800e-
003

0.1938 0.0562 5.0000e-
004

0.0128 4.1000e-
004

0.0132 3.6900e-
003

3.9000e-
004

4.0800e-
003

53.4691 53.4691 3.4500e-
003

53.5554
Worker 0.0382 0.0261 0.2946 8.6000e-
004

0.0894 7.2000e-
004

0.0901 0.0237 6.7000e-
004

0.0244 85.7801 85.7801 2.5200e-
003

85.8432
Total 0.0445 0.2199 0.3508 1.3600e-
003

0.1022 1.1300e-
003

0.1034 0.0274 1.0600e-
003

0.0285 139.2492 139.2492 5.9700e-
003
139.3986
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:06 AM World Oil Tanks Installation - Los Angeles-South Coast County, Winter A-17

2.0 Emissions Summary

2.1 Overall Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2021 0.1682 1.6454 1.2095 3.0700e-
003

0.0279 0.0663 0.0941 7.4400e-
003

0.0617 0.0692 0.0000 268.7605 268.7605 0.0691 0.0000 270.4890 Maximum 0.1682 1.6454 1.2095 3.0700e-
003

0.0279 0.0663 0.0941 7.4400e-
003

0.0617 0.0692 0.0000 268.7605 268.7605 0.0691 0.0000 270.4890 Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2021 0.1682 1.6454 1.2095 3.0700e-
003

0.0277 0.0663 0.0939 7.4100e-
003

0.0617 0.0692 0.0000 268.7602 268.7602 0.0691 0.0000 270.4888 Maximum 0.1682 1.6454 1.2095 3.0700e-
003

0.0277 0.0663 0.0939 7.4100e-
003

0.0617 0.0692 0.0000 268.7602 268.7602 0.0691 0.0000 270.4888 Mitigated Construction
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:03 AMWorld Oil Tanks Installation - Los Angeles-South Coast County, Annual World Oil Tanks Installation
Los Angeles-South Coast County, Annual
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.75 0.00 0.23 0.40 0.00 0.04 0.00 0.00 0.00 0.00 0.00 0.00 Quarter Start Date End Date Maximum Unmitigated ROG + NOX (tons/quarter) Maximum Mitigated ROG + NOX (tons/quarter) 1 1-4-2021 4-3-2021 0.8908 0.8908
2 4-4-2021 7-3-2021 0.5572 0.5572
3 7-4-2021 9-30-2021 0.2470 0.2470
Highest 0.8908 0.8908
A-18

3.2 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 3.5000e-
004

0.0000 3.5000e-
004

4.0000e-
005

0.0000 4.0000e-
005

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 0.0968 1.0842 0.7532 1.9000e-
003

0.0457 0.0457 0.0420 0.0420 0.0000 166.5775 166.5775 0.0539 0.0000 167.9244 Total 0.0968 1.0842 0.7532 1.9000e-
003

3.5000e-
004

0.0457 0.0460 4.0000e-
005

0.0420 0.0421 0.0000 166.5775 166.5775 0.0539 0.0000 167.9244 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 2.1100e-
003

0.0642 0.0161 2.0000e-
004

4.7700e-
003

2.2000e-
004

5.0000e-
003

1.3100e-
003

2.1000e-
004

1.5300e-
003

0.0000 19.8280 19.8280 1.2600e-
003

0.0000 19.8596
Vendor 2.8000e-
004

8.9800e-
003

2.4300e-
003

2.0000e-
005

5.7000e-
004

2.0000e-
005

5.9000e-
004

1.7000e-
004

2.0000e-
005

1.8000e-
004

0.0000 2.2431 2.2431 1.4000e-
004

0.0000 2.2466
Worker 3.1300e-
003

2.4400e-
003

0.0275 8.0000e-
005

7.9800e-
003

7.0000e-
005

8.0400e-
003

2.1200e-
003

6.0000e-
005

2.1800e-
003

0.0000 7.1993 7.1993 2.1000e-
004

0.0000 7.2046
Total 5.5200e-
003

0.0756 0.0460 3.0000e-
004

0.0133 3.1000e-
004

0.0136 3.6000e-
003

2.9000e-
004

3.8900e-
003

0.0000 29.2704 29.2704 1.6100e-
003

0.0000 29.3107
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:03 AM World Oil Tanks Installation - Los Angeles-South Coast County, Annual A-19

3.2 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 1.4000e-
004

0.0000 1.4000e-
004

2.0000e-
005

0.0000 2.0000e-
005

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 0.0968 1.0842 0.7532 1.9000e-
003

0.0457 0.0457 0.0420 0.0420 0.0000 166.5773 166.5773 0.0539 0.0000 167.9242 Total 0.0968 1.0842 0.7532 1.9000e-
003

1.4000e-
004

0.0457 0.0458 2.0000e-
005

0.0420 0.0420 0.0000 166.5773 166.5773 0.0539 0.0000 167.9242 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 2.1100e-
003

0.0642 0.0161 2.0000e-
004

4.7700e-
003

2.2000e-
004

5.0000e-
003

1.3100e-
003

2.1000e-
004

1.5300e-
003

0.0000 19.8280 19.8280 1.2600e-
003

0.0000 19.8596
Vendor 2.8000e-
004

8.9800e-
003

2.4300e-
003

2.0000e-
005

5.7000e-
004

2.0000e-
005

5.9000e-
004

1.7000e-
004

2.0000e-
005

1.8000e-
004

0.0000 2.2431 2.2431 1.4000e-
004

0.0000 2.2466
Worker 3.1300e-
003

2.4400e-
003

0.0275 8.0000e-
005

7.9800e-
003

7.0000e-
005

8.0400e-
003

2.1200e-
003

6.0000e-
005

2.1800e-
003

0.0000 7.1993 7.1993 2.1000e-
004

0.0000 7.2046
Total 5.5200e-
003

0.0756 0.0460 3.0000e-
004

0.0133 3.1000e-
004

0.0136 3.6000e-
003

2.9000e-
004

3.8900e-
003

0.0000 29.2704 29.2704 1.6100e-
003

0.0000 29.3107
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:03 AM World Oil Tanks Installation - Los Angeles-South Coast County, Annual A-20

3.3 Tank Construction - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0572 0.4357 0.3287 6.3000e-
004

0.0189 0.0189 0.0181 0.0181 0.0000 51.2462 51.2462 0.0123 0.0000 51.5539 Total 0.0572 0.4357 0.3287 6.3000e-
004

0.0189 0.0189 0.0181 0.0181 0.0000 51.2462 51.2462 0.0123 0.0000 51.5539 Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 2.0000e-
004

6.6400e-
003

1.5500e-
003

2.0000e-
005

4.1000e-
004

2.0000e-
005

4.3000e-
004

1.1000e-
004

2.0000e-
005

1.3000e-
004

0.0000 1.8295 1.8295 1.3000e-
004

0.0000 1.8327
Vendor 4.2000e-
004

0.0132 3.5900e-
003

3.0000e-
005

8.4000e-
004

3.0000e-
005

8.7000e-
004

2.4000e-
004

3.0000e-
005

2.7000e-
004

0.0000 3.3031 3.3031 2.0000e-
004

0.0000 3.3081
Worker 4.6100e-
003

3.5900e-
003

0.0405 1.2000e-
004

0.0118 1.0000e-
004

0.0118 3.1200e-
003

9.0000e-
005

3.2100e-
003

0.0000 10.6012 10.6012 3.1000e-
004

0.0000 10.6090
Total 5.2300e-
003

0.0235 0.0457 1.7000e-
004

0.0130 1.5000e-
004

0.0131 3.4700e-
003

1.4000e-
004

3.6100e-
003

0.0000 15.7338 15.7338 6.4000e-
004

0.0000 15.7498
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:03 AM World Oil Tanks Installation - Los Angeles-South Coast County, Annual A-21

3.3 Tank Construction - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0572 0.4357 0.3287 6.3000e-
004

0.0189 0.0189 0.0181 0.0181 0.0000 51.2461 51.2461 0.0123 0.0000 51.5538 Total 0.0572 0.4357 0.3287 6.3000e-
004

0.0189 0.0189 0.0181 0.0181 0.0000 51.2461 51.2461 0.0123 0.0000 51.5538 Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 2.0000e-
004

6.6400e-
003

1.5500e-
003

2.0000e-
005

4.1000e-
004

2.0000e-
005

4.3000e-
004

1.1000e-
004

2.0000e-
005

1.3000e-
004

0.0000 1.8295 1.8295 1.3000e-
004

0.0000 1.8327
Vendor 4.2000e-
004

0.0132 3.5900e-
003

3.0000e-
005

8.4000e-
004

3.0000e-
005

8.7000e-
004

2.4000e-
004

3.0000e-
005

2.7000e-
004

0.0000 3.3031 3.3031 2.0000e-
004

0.0000 3.3081
Worker 4.6100e-
003

3.5900e-
003

0.0405 1.2000e-
004

0.0118 1.0000e-
004

0.0118 3.1200e-
003

9.0000e-
005

3.2100e-
003

0.0000 10.6012 10.6012 3.1000e-
004

0.0000 10.6090
Total 5.2300e-
003

0.0235 0.0457 1.7000e-
004

0.0130 1.5000e-
004

0.0131 3.4700e-
003

1.4000e-
004

3.6100e-
003

0.0000 15.7338 15.7338 6.4000e-
004

0.0000 15.7498
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:03 AM World Oil Tanks Installation - Los Angeles-South Coast County, Annual A-22

3.4 Architectural Coating - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Archit. Coating 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 2.9600e-
003

0.0237 0.0317 5.0000e-
005

1.2300e-
003

1.2300e-
003

1.2200e-
003

1.2200e-
003

0.0000 4.3916 4.3916 6.4000e-
004

0.0000 4.4076
Total 2.9600e-
003

0.0237 0.0317 5.0000e-
005

1.2300e-
003

1.2300e-
003

1.2200e-
003

1.2200e-
003

0.0000 4.3916 4.3916 6.4000e-
004

0.0000 4.4076
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 7.0000e-
005

2.3700e-
003

6.4000e-
004

1.0000e-
005

1.5000e-
004

0.0000 1.6000e-
004

4.0000e-
005

0.0000 5.0000e-
005

0.0000 0.5916 0.5916 4.0000e-
005

0.0000 0.5925
Worker 4.1000e-
004

3.2000e-
004

3.6300e-
003

1.0000e-
005

1.0500e-
003

1.0000e-
005

1.0600e-
003

2.8000e-
004

1.0000e-
005

2.9000e-
004

0.0000 0.9494 0.9494 3.0000e-
005

0.0000 0.9501
Total 4.8000e-
004

2.6900e-
003

4.2700e-
003

2.0000e-
005

1.2000e-
003

1.0000e-
005

1.2200e-
003

3.2000e-
004

1.0000e-
005

3.4000e-
004

0.0000 1.5410 1.5410 7.0000e-
005

0.0000 1.5426
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:03 AM World Oil Tanks Installation - Los Angeles-South Coast County, Annual A-23

3.4 Architectural Coating - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Archit. Coating 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 2.9600e-
003

0.0237 0.0317 5.0000e-
005

1.2300e-
003

1.2300e-
003

1.2200e-
003

1.2200e-
003

0.0000 4.3916 4.3916 6.4000e-
004

0.0000 4.4076
Total 2.9600e-
003

0.0237 0.0317 5.0000e-
005

1.2300e-
003

1.2300e-
003

1.2200e-
003

1.2200e-
003

0.0000 4.3916 4.3916 6.4000e-
004

0.0000 4.4076
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 7.0000e-
005

2.3700e-
003

6.4000e-
004

1.0000e-
005

1.5000e-
004

0.0000 1.6000e-
004

4.0000e-
005

0.0000 5.0000e-
005

0.0000 0.5916 0.5916 4.0000e-
005

0.0000 0.5925
Worker 4.1000e-
004

3.2000e-
004

3.6300e-
003

1.0000e-
005

1.0500e-
003

1.0000e-
005

1.0600e-
003

2.8000e-
004

1.0000e-
005

2.9000e-
004

0.0000 0.9494 0.9494 3.0000e-
005

0.0000 0.9501
Total 4.8000e-
004

2.6900e-
003

4.2700e-
003

2.0000e-
005

1.2000e-
003

1.0000e-
005

1.2200e-
003

3.2000e-
004

1.0000e-
005

3.4000e-
004

0.0000 1.5410 1.5410 7.0000e-
005

0.0000 1.5426
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:03 AM World Oil Tanks Installation - Los Angeles-South Coast County, Annual A-24
World Oil Tank Installation Project
Construction - Architectural Coating VOC Emissions
Assumptions:
1) The coating types and VOC contents, coating thicknesses, area coated, coating volumes, thinners used, and work schedules are provided by the applicant 2) The interior of the tank is coated on the floor and up the sides 48 inches (4 feet) 3) The floating roof is not coated onsite.
4) The entire tank exterior, except the floating roof, is coated. 5) Each coating type is applied sequentially, so total schedule for coating task is 24 days.

VOC Emissions Estimate
Exterior Coating Product Sq.Ft./Tank Thickness Gallons Lb/Gal Total Lb's X 2 Tanks Days Avg/Lb/Day Field Primer Sherwin Williams 646-100 (3-5 mils) 2000 3-5 Mils 10 0.83 8.3 16.6 4.0 4.2 Intermediate Coat Sherwin Williams 646-100(4-6 mils) 13800 4-6 Mils 80 0.83 66.4 132.8 8.0 16.6 Finish Coat Sherloxane 800 (no thinner required) 13800 4 mils 40 0.77 30.8 61.6 8.0 7.7 Total (lbs) 211.0 20.0
Interior Coating Product Sq.Ft./Tank Thickness Gallons Lb/Gal Total Lb's X 2 Tanks Days Avg/Lb/Day Coating Duraplate UHS 4200 20-30 mils 85 0.83 70.6 141.1 4.0 35.3 Exempt Solvents Emissions Estimate
Exterior Coating Solvents Gals By Weight Density Lb/Gal Emissions Lbs 10 40% 8.8 35.0
60% 8.8 52.5
Gals By Weight Density Lb/Gal Emissions Lbs
20 100% 6.5 130.9
Components
Acetone
p-Chlorobenzotrifluoride
Acetone
R7K111 Thinner (for SW 646-100)
Cleaning Solvent
Components
Interior Coating Solvents
A-25
World Oil Tank Installation Project
Operations Criteria Air Pollutant Emissions Summary
Proposed Project Emissions Increase NOx PM10 PM2.5 ROG CO SOx Onroad Emissions 1.21 0.09 0.03 0.04 0.18 0.00
New Tanks Fugitive Emissions1 -- -- -- 9.70 -- --
Loading Rack/Vapor Control 0.20 0.01 0.01 0.09 0.16 0.00 Total 1.41 0.10 0.04 9.83 0.34 0.00
1 - New tank emissions from SCAQMD permit engineering analysis.

Operations GHG Emissions Summary
Proposed Project Emissions Increase CO2e MT
Onroad Emissions 60.5
Loading Rack/Vapor Control 32.5
Indirect Electricity Emissions 5.9
Total 98.9
Annualized Emissions Increase CO2e MT
Construction Emissions From CalEEMod 270.5
Amortized Construction Emissions (30-years) 9.0
Incremental Operations Emissions Increase 98.9
Total Increase 108.0
Daily Emissions lbs/day
A-26
World Oil Tank Installation Project
Operation - On-Road Emissions Increase
Assumptions
1) Emissions factors developed from CARB EMFAC2017 output. Paved road dust included using AP-42 and CalEEMod input defaults. 2) Heavy Duty Truck is the diesel fueled HHDT vehicle type meeting POLA/POLB's Clean Trucks Program designated as T7 POLA in EMFAC2017. 3) The additional maximum daily truck round trips caused by the project is 3 trips per day, a 10 percent increase from baseline per World Oil. 5) The distance for each additional round trip is 30 miles per World Oil. A single average trip distance is 15 miles. 6) There are no additional passenger or delivery class vehicle trips above baseline for the proposed Project.

NOx PM10 PM2.5 ROG CO SOx CO2e
Heavy Duty Truck 1.34E-02 9.66E-04 3.26E-04 4.83E-04 2.05E-03 3.68E-05 4.06 Vehicle Type NOx PM10 PM2.5 ROG CO SOx
Heavy Truck 90 1.209 0.087 0.029 0.043 0.184 0.003 60.5 4) While World Oil does not anticipate a long term increase in fuel trucking, it is conservatively assumed that the maximum daily increase in trucking occurs daily.

Incremental Increase
Emissions Factors lbs/mile
Daily VMT
Daily Emissions - Lbs GHG
MTCO2e/Yr
A-27
World Oil Tank Installation Project
Operation - Loading Rack/Vapor Control Emissions
Assumptions
1) Emissions are a 10 percent increase from 2019 baseline for loading rack thermal oxidizer use and fugitive ROG 2) Baseline emissions are from the 2019 emissions inventory submitted to SCAQMD. 3) Annual thermal oxidizer natural gas fuel use is 6.0 million standard cubic feet (assume 1,020 Btu/scf to convert to MMBtu). 4) CO2e emissions factor for natural gas is from the Climate Registry is 53.17 Kg CO2e/MMBtu (includes CH4 and N2O). 5) To adjust annual emissions, operations are 7 days per week year-round.

Thermal Oxidizer Emissions
NOx PM10 PM2.5 ROG CO SOx
745.920 45.000 45.000 42.000 573.190 3.600 325
Project Increase Annual 74.59 4.50 4.50 4.20 57.32 0.36 32.54 Daily Increase 0.20 0.01 0.01 0.01 0.16 0.00
Fuel Oil Loading Rack Fugitive Emissions
ROG
277.540
Project Increase Annual 27.75
Daily Increase 0.08
2019 Baseline Annual
Daily Emissions - Lbs GHG
MTCO2e/Yr
2019 Baseline Annual
A-28

Appendix B (Confidential)
Cultural Resources Records Search Report

Appendix C
Noise Calculations

APPENDIX C. World Oil Tank Installation Project Noise Calculations Construction Equipment
Lmax Ref
dBA
Useage Per
Hour Along Levee
Distance to
Resident
Equip
Leq(h)
Foundation Installation @ 50 ft (%) quantity feet dBA
Pile Driver (vibro pier mounted impact hammer/hoe ram) 90 20 1 2610 48.7 Crane 81 16 1 2610 38.7
Bobcat (backhoe) 78 40 1 2610 39.7
Total Quantity of Equipment: 3
Peak Unmitigated Composite Leq(h): 49.5
Line-of-Site/Intervening Structures Reduction (10dB): 39.5 Threshold:

LBMC District 1 50 dBA daytime - 5 (for tonal)=45 dBA OR increase by 5 dB to encompass ambient - 5 (for tonal) Project equipment per Application Item 21. Assume maximum of 3 pieces of equipment; worst-case vibro pier installation using mounted impact hammer/hoe ram.

Source: Federal Transit Administration (FTA). 2006. Transit Noise and Vibration Impact Assessment. Final Report, May. [Online]:
http://www.fta.dot.gov/documents/FTA_Noise_and_Vibration_Manual.pdf. Accessed March 2012.

Assumptions: Containment structure, which breaks the line of site, would provide at least 5 dBA reduction in noise levels from the project site, plus additional 5 dB reduction from topography and intervening structures (tanks).

App C-Noise calcs-World Oil 051820.xls Page 1 of 1