Richmond City Council
May 16, 2023

RESOLUTION NO. ________

A RESOLUTION OF THE COUNCIL OF THE CITY OF RICHMOND, CALIFORNIA, ADOPTING THE FISCAL YEAR 2022-23 QUARTER 3 BUDGET AMENDMENTS WHEREAS, pursuant to Section 1(b) of Article IV of the Richmond City Charter the City Manager is required to prepare an annual budget for the review and approval by the City Council; and
WHEREAS, the City’s budget was originally adopted on June 21, 2022; and WHEREAS, the City’s quarter 1 budget report was received on December 6, 2022 to monitor budget to actual trends between the time period of July 1, 2022 and September 30,2022; and
WHEREAS, the City’s mid-year budget report was received on March 28, 2023 to monitor budget to actual trends between the time period of July 1, 2022 and December 31, 2022; and
WHEREAS, the City’s quarter 3 budget report was received on May 16, 2023 to monitor budget to actual trends between the time period of July 1, 2022 and March 31, 2023; and WHEREAS, the City Council has reviewed the proposed budget adjustments in the quarter three budget report; and at a public meeting on May 16, 2023; and NOW, THEREFORE, BE IT RESOLVED, that the Council of the City of Richmond, California hereby adopts the resolution to receive the City’s quarter 3 budget report and approve the proposed budget amedments set forth in Table 1, below:

Table 1: Non-General Fund Budget Amendments
Fund Type Amount
General Capital Transfer In from General Fund ($15,000,000) General Capital Capital Expenditures, Main Library Renovation $15,000,000 **********************
I certify that the foregoing resolution was passed and adopted by the City Council of the City of Richmond at a _________ meeting held on _____________ by the following vote:
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Reso. No.

AYES:

NOES:

ABSTENTIONS:

ABSENT:
________________________________________
Clerk of the City of Richmond
(SEAL)
Approved:
_______________________________
Mayor
Approved as to form:
____________________________
City Attorney
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Community Development
DATE: May 16, 2023
TO: Mayor Martinez and Members of the City Council
FROM: Lina Velasco, Director of Community Development
Subject: Raven Bioenergy Project Appeal Consideration Appeal Consideration
FINANCIAL IMPACT: There is no fiscal impact to the general fund related to this project; however, the proposed bioenergy facility
would create construction and operational jobs, increase the property value of the subject site, and will contribute to the economic viability of this area.

PREVIOUS COUNCIL
ACTION:

None.

STATEMENT OF THE
ISSUE:

On December 19, 2022, an appeal was filed by Tessa
Wardle on behalf of Communities for a Better
Environment (“CBE”) and National Resources Defense
Council (“NRDC”), objecting to the Planning
Commission’s conditional approval to adopt a Mitigated
Negative Declaration (MND) and Mitigation Monitoring
and Reporting Program (MMRP) and approval of a
Conditional Use Permit and Design Review (PLN21-282)
to construct and operate a bioenergy facility that converts food and green waste into transportation-grade hydrogen for various renewable energy products.

RECOMMENDED ACTION: HOLD a public hearing on an appeal filed objecting to the Planning Commission’s conditional approval to adopt a
Mitigated Negative Declaration (MND) and Mitigation
Monitoring and Reporting Program (MMRP) and approval
of a Conditional Use Permit and Design Review (PLN21-
282) to construct and operate a bioenergy facility that AGENDA
REPORT
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converts food and green waste into transportation-grade hydrogen for various renewable energy products; and
EITHER: (a.) Adopt the Resolution in Attachment 1,
denying the appeal and approving the Raven project with changes to conditions of approval as represented in
Exhibit C of the Resolution, (b.) Refer the matter back to the Planning Commission to consider the significant new evidence presented after its decision, identifying the
evidence used as a basis for this decision, or (c.) Grant the appeal, deny the project, and direct staff to return with a resolution containing written findings consistent with this motion for final approval by the City Council - Community Development Department (Lina Velasco 510-
620-6841).

BACKGROUND:

The project site is located within the West Contra Costa Sanitary Landfill (WCCSL) property located in the northwest area of the City of Richmond. The WCCSL property is approximately 175 acres. The project site occupies approximately 2.5 acres of the WCCSL property and is located approximately 0.25 miles west of Parr Boulevard. The northern boundary of the project site is the City of Richmond / Contra Costa County jurisdiction line; the project site is located wholly within the City of Richmond.

Existing conditions of the project site are shown in the figure below. The project site is relatively flat and partially paved, with the remainder consisting of compacted soil and ground cover along the north edge. No trees or landscaping exist. The existing landfill power generation plant and the adjacent maintenance building are primary structures that would remain. Existing trailers housing ancillary uses on the project site would be removed. The project site is fenced on the north, east and south, and connects to the surrounding WCCSL areas and operations via an existing service road.

The project site is currently served by utility infrastructure provided by East Bay Municipal Utilities District (EBMUD), West County Wastewater District, PG&E, and City of Richmond police and fire services. The owner of the property is West Contra Costa Sanitary Landfill, Inc., a subsidiary of Republic Services, Inc. 842

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Figure 1: Project Site
PROPOSAL:

The applicant, Raven SR, LLC, proposes to construct and operate a bioenergy facility that converts blended green and food waste into renewable, transportation-grade hydrogen to be exported off-site for various renewable energy products. The waste would be obtained from the existing Bulk Materials Processing Center (BMPC) located adjacent to the project site. The applicant would lease the project site, which is part of the larger BMPC. No long-term hydrogen storage would occur onsite.

The project would involve the construction of two modular structures and an industrial canopy as shown in Exhibit A, including various processing equipment. All Raven SR’s material handling systems would be located inside the proposed modular structure. This new modular structure would be located where the storage uses and remnant foundations currently exist at the north edge of the site.

The key project components include an industrial feed material handler that would be up to 31 feet tall, which is the tallest facility element. Other elements of height and size include the nitrogen tank (30 feet tall); cooling tower and fire water tank (both 25.5 feet tall); and the industrial metal canopy over the feed/unload storage area, the adjacent steam reformer structure; and the second nitrogen tank (each 26 feet tall).

This project would also require permits from the following agencies: Bay Area Air Quality Management District (BAAQMD), State Water Resources Control Board, State Department of Resource Recovery and Recycling (CalRecycle), and Local Enforcement Agency (LEA).
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DISCUSSION:

The applicant, Raven SR, LLC, is seeking a conditional use permit and design review permit to construct and operate a bioenergy facility that converts food and green waste into hydrogen for various renewable energy products.

The project consists of the following major project components:
 Two modular structures;
 Feedstock storage area cover (also referred to as industrial metal canopy);  Other elements of the bioenergy system including, but are not limited to: the two nitrogen tanks, cooling tower, steam reformer structure, and fire water tank; and,  Site improvements including paving, utilities, fencing, etc.

Biomass and Waste to Energy Conversion Facilities
The Raven SR Steam/CO2 Reformation process would convert blended green and food waste into renewable, transportation grade hydrogen to be exported off-site for various renewable energy products. The blended green and food waste would be collected from the existing Bulk Materials Processing Center (BMPC) located adjacent to the project site, and would already have been pre-processed by Republic to remove contaminants and standardize the size of the materials. The reformation process is a three-step process that (1) converts waste to gas, (2) turns gas to H2 syngas, and (3) produces hydrogen output. The technology is strictly non-combustion, low pressure and a catalyst-free process.

The project would work in tandem with other facilities in the area, such as directing blended green and food waste from the existing BMPC for feedstock for the proposed bioenergy system. Therefore, the proposed project is complementary to existing uses in the surrounding areas.

Site Parking
The applicant does not propose to construct any new parking to serve the project; rather, employees would use the existing employee and visitor parking area located east of the hydrogen storage and load out area. The new bioenergy facility would involve 3 to 4 new employees per shift, for a total of 9 to 12 employees per day. The current site has 19 regular parking stalls and 2 ADA accessible parking stalls. The existing lot has sufficient stalls to serve the existing uses, including the proposed project. Additionally, in the visitor parking area there are 15 regular stalls and 2 ADA accessible stalls.

Bay Trail Improvements
Landscaping for the project will be provided off-site, primarily at the Landfill Loop Trail, near the Wildcat Marsh Trail and trailhead parking located approximately 1,000 feet east of the project location. Due to limited space and potential safety hazards within the proposed processing facility, no new vegetation will be installed within the project area boundaries.
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Raven proposes to plant 21 drought-tolerant trees: six Coast Live Oak trees, six California Buckeye trees and nine Pink Dawn Chitalpa and Toyon trees. Trees planted would be either 15-gallon or 24” box trees, per City requirements. The applicant has prioritized drought tolerant species and will have an adequate maintenance program.

Zoning Analysis
The proposed use is defined as a Utilities, Major and is conditionally allowed in the OS, Open Space zoning district as set forth in Richmond Municipal Code (RMC) Section

15.04.206.020. The project requires a Conditional Use Permit, as well as Design Review for the new facility and associated site improvements.

Biomass and waste to energy conversion facilities falls under the Utilities, Major uses which are conditionally allowed in the OS, Open Space Zoning District. A conditional use permit is required for any biomass and waste to energy conversion facilities.

Utilities, Major is defined as generating plants, electric substations, and solid waste collection, including transfer station and materials recovery facilities, solid waste treatment and disposal, water or wastewater treatment plants, biomass and waste to energy conversion facilities, and similar facilities of private companies, public agencies or public utilities.

The site is located in the OS, Open Space zoning district; therefore, the Project must comply with the applicable development standards in section 15.04.206.040 as follows:

Maximum Height: The maximum height in the OS zoning district is 35 feet. The tallest proposed structure is ±31 feet. Therefore, the project satisfies this requirement.

Minimum Setbacks: The minimum setbacks for the OS zoning district are as follows:
 Front: 20% of lot depth, not to exceed 40 feet.
 Side: 10% of lot depth, not to exceed 20 feet.
 Rear: 20% of lot depth; not to exceed 20 feet.

The project site is within the larger WCCSL property, in a location that exceeds the minimum 20-foot and 40-foot setback requirements; therefore, the project satisfies this requirement.

Maximum Floor Area Ratio (FAR): The maximum buildable floor area ratio allowed is

0.1. The proposed floor area ratio is 0.005. Therefore, the project satisfies this requirement.

The proposed project meets all the development standards set forth in the Zoning Ordinance for the OS zoning district.

DESIGN REVIEW BOARD RECOMMENDATION:

Pursuant to RMC Section 15.04.805 (Design Review), Major Design Review is required when improvements and development exceeds 1,000 square feet of floor area. The total floor area of all proposed structures would be approximately 40,000 square feet. 845

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The Design Review Board provided a recommendation of approval, with conditions, to the Planning Commission of the requested Design Review Permit at its October 26, 2022 public hearing. The Design Review findings required per RMC section

15.04.805.050 are in the attached resolution with supporting statements of fact.

Two additional conditions (Nos. 7 and 8) regarding landscaping were recommended by the Design Review Board and are included in the attached resolution. Additionally, the applicant agreed to a third condition (No. 10) requested by TRAC to create and install a 2-foot by 3-foot interpretive panel about the bioenergy facility along the Landfill Loop Trail, which would be subject to approval by the City and Republic Services.

PLANNING COMMISSION APPROVAL:

On December 15, 2022, the Planning Commission voted unanimously to adopt the MND and Final MMRP and approve the Conditional Use Permit and Design Review of the Raven Bioenergy Project by approval of Planning Application No. PLN21-282. The Planning Commission adopted Resolution No. 22-18 (Attachment 4), adding Condition No. 91 restricting project’s production to hydrogen only and Condition No. 92 requiring convenient and secure bicycle parking on the project site.

APPEAL ACTION:

Pursuant to Section 15.04.803.140.E of the Zoning Ordinance, the City Council determines whether an underlying decision is supported by substantial evidence and/or constitutes an abuse of discretion. The same standards and evaluation criteria, including the findings required, apply as they were for the original application. The appellate body’s review is limited to the issue(s) raised in the petition for the appeal.

The Richmond Municipal Code allows for appeal of Planning Commission decisions per Section 15.04.803.140 of the Zoning Ordinance. Communities for a Better Environment CBE”) and National Resources Defense Council (NRDC) timely submitted a joint appeal on December 16, 2022. The appeal challenged all approvals, including the Initial Study/Mitigated Negative Declaration (IS/MND), Design Review Permit (DRP) and Conditional Use Permit (CUP) for Raven SR Bioenergy Project (PLN21-282).

A public hearing is required for an appeal, and new testimony and other new evidence can be provided and considered by the City Council. The City Council is not bound by the Planning Commission’s decision, and is not required to decide the matter based on the conclusions or assumptions made by the Planning Commission. Instead, the City Council has the authority to affirm, modify, or reverse the original decision. However, if the City Council decides to modify or reverse the approval, the City Council must state specific reasons for doing so and provide a decision within 30 days of the close of the public hearing. The City Council may also choose to refer the matter back to the Planning Commission for further consideration and a decision, but only if significant new evidence is presented in conjunction with the appeal, which may include substantial changes to the original proposal.
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An action to grant the appeal (and deny the project) requires a majority vote of the Council members. A tie vote has the effect of rejecting the appeal, which would mean that the Planning Commission’s approval of the Project would remain in effect.

BASIS OF APPEAL:

The appeal letter (Attachment 5) submitted by Tessa Wardle on behalf of CBE and NRDC (“Appellant”) asserts that there is substantial evidence of a fair argument that the Raven Bioenergy Project would have significant adverse environmental impacts and a full, environmental impact report (“EIR”) is necessary and the draft IS/MND is inadequate in terms of provided information and mitigation measures.

The applicant’s response to the appeal (Attachment 6) recognizes the appellant’s request for further clarification regarding the proposed project. Attachment 6 includes an updated description for the project that includes further details about the operational aspects of the Raven SR technology, a Health Risk Assessment (HRA) prepared by Ramboll on behalf of the applicant, and the applicant’s suggested redlines to the Draft IS/MND to provide further clarification and details on the proposed project. The applicant asserts that an IS/MND is sufficient to address environmental concerns and are willing and have worked with the City to update the IS/MND to provide more comprehensive information. The Raven SR IS/MND vs EIR Comparison Chart (Attachment 9) expands and further clarifies the differences between the IS/MND process and completing an EIR. The City has reviewed the provided comparison chart for accuracy.

Staff also notes that the appeal letter connects the Raven project with an unrelated Chevron hydrogen project. To be clear, the proposed project is a separate and independent project from other possible hydrogen-related projects within the City that may be proposed in the near future. The Raven project has a separate and independent owner, located on a separate and independent site, has a separate and completely independent source stream to make hydrogen, and is seeking separate entitlements.

Additionally, baseline for the Raven project was established at the time that the completed application was filed by the applicant on July 30, 2021. At that time, other hydrogen-related projects had not submitted an application for an entitlement from the City. Months later Chevron submitted an application on November 15, 2021, for an alternative fueling station that would include fueling equipment for hydrogen (H2) and compressed natural gas (CNG). That application did not propose the manufacturing of hydrogen. Additionally, after Raven’s project was received no other application has been received by the City for a hydrogen production project. As a result, the Raven project is not required to analyze the potential cumulative impacts for subsequent/potentially future projects as i) the fueling station application was submitted after the Raven project’s baseline; and/or ii) CEQA does not require analysis of speculative projects that have yet to be received.

Next, any hydrogen-related projects submitted after the Raven project or at some future date would be required to comply with CEQA. As part of that process, those projects would also need to include the Raven project in either the baseline or a reasonably 847

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foreseeable project for that project’s initial study – assuming that the type of project impacts overlap for the purposes of a cumulative analysis.

City staff submitted a request to the Lawrence-Livermore National Laboratory to clarify certain facts surrounding hydrogen’s potential hazard and environmental impacts, provided as Attachment 8 to this report. This letter states, in part, “hydrogen is a nontoxic, light gas that diffuses fast, which results in a narrow window for the right hydrogen-air mixture to result in a fire/explosion… We are not aware of any hydrogen explosions caused by hydrogen leaked from fuel cell electric vehicles, despite multiple reports of such vehicles involved in road accidents.” The letter also indicates that while there’s a possibility of hydrogen leaking out of the process and that the leakage would have negative climate impacts, the leakage would be unlikely to negate the environmental benefit of using the hydrogen as an alternative to “dirtier” fuels. There is no on-site hydrogen storage proposed.

Raven prepared a memorandum to address the matter of potential noise from the site, the Hydrogen Vent Sound Attenuation Memorandum (Attachment 3 to Attachment 7).

This document further clarifies the project applicant’s basis for affirming that the project would not exceed the noise limits imposed by Condition 42 and Richmond Municipal Code 9.52.100, which is 70 dB at the property line.

Finally, the Health Risk Assessment covered an expanded area from 1,000-foot distance to 6,000-foot distance. The HRA determined that, “The proposed project provides an overall reduction of cancer risk, chronic hazard index, acute hazard index, and particulate matter concentrations as compared to the portions of the existing landfill flare operation it would be replacing.” This overall reduction by the project effectively improves air quality as compared to current operations.

ENVIRONMENTAL REVIEW:

The City initiated the preparation of a draft Initial Study/Mitigated Negative Declaration (IS/MND) (State Clearinghouse #2022100145) (see Attachment 2). Its purpose is to identify any potential environmental impacts that would result from implementation of the proposed project pursuant to the CEQA Guidelines. The draft IS/MND was published for a 30-day review and comment period on October 7, 2022. The City extended the public comment period from November 7 to November 22, 2022, for a total 45-day review period. During the comment period, 19 comment letters were received.

The Planning Commission’s role was to determine the adequacy of the final IS/MND (consisting of the draft IS/MND and the Responses to Comments Technical Memorandum) for the Project and consider Raven’s request for a Conditional Use and Design Review Permits. The Responses to Comments in Attachment 3 addresses environmental comments received regarding the draft IS/MND.

After the appeal was filed, City staff worked with environmental consultants to write an Updated IS/MND (Exhibit B of Attachment 1). This updated document provided further clarification on the proposed project, its environmental impacts as well as the HRA that 848

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was peer-reviewed by the City and environmental consultants, included as an appendix.

Given that the new information added to the Updated IS/MND merely clarifies, amplifies or otherwise makes insignificant modifications to the draft IS/MND, recirculation of the document was not required by CEQA. Regardless, to ensure greater transparency and to make additional clarifying information available to the public, the City has recirculated the Updated IS/MND for public comment. The Updated IS/MND was published for a 30- day review and comment period on March 9, 2023. The City extended the public comment period from April 7 to April 12, 2023, for a total 34-day review period for the Updated IS/MND. During the comment period for the Updated IS/MND, 19 comment letters were received, 7 were letters of support and the remaining 12 letters were a mix of environmental concerns, request for an EIR, or additional conditions. The Updated IS/MND (Exhibit B) and Responses to Comments on the Updated IS/MND Technical Memorandum (Attachment 7) will be considered by the City Council during its consideration of the appeal from the decision of the Planning Commission.

According to the Updated IS/MND, four environmental areas may have potentially significant impact unless mitigation measures are incorporated into the project. These areas are cultural resources, air quality and tribal cultural resources and biological resources. Additional details on these potential impacts are described below. An Updated MMRP is recommended and attached in Exhibit B. The resolution requires the project to comply with the adopted MMRP.

Transportation
The operation is expected to service approximately 14 hydrogen tube trucks per day, each with an average trip of 40 miles after leaving the site. In addition, up to approximately 11 biocarbon trucks per day would be in use for the co-product.

Considering this with other trucks and employees coming to and leaving the project site daily, 12 employee vehicles and 25 trucks would access the site daily.

Section 4.15 of the Updated IS/MND concludes the project would have less than significant impact on transportation. Parr Boulevard and Richmond Parkway are Citydesignated truck routes (established in the Richmond General Plan, Map 4.4) that serve primarily industrial areas, the additional trips would not conflict with the existing and proposed transit, roadway, bicycle or pedestrian facilities in the project vicinity.

Additionally, the vehicle miles traveled (VMT) for this project is approximately 174 VMT per day, which is well below the City’s and County’s screening criterion of 836 VMT per day.

Noise
Construction activities associated with the proposed Project would result in temporary increases in ambient noise levels. As discussed in Section 4.12 of the Updated IS/MND, onsite construction activities would require the use of heavy construction equipment (e.g., excavator, loader, crane) that would generate varying noise levels. Offsite construction noise sources would consist of passing trucks and other constructionrelated vehicles. The proposed project would adhere to the City’s construction work hours and the construction noise level limitations.
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In terms of operation, the Raven SR system would run up to 24 hours per day, 7 days per week, although an average of 1.5 days per month are planned down times. The primary source of noise during project operation would be mechanical equipment associated with the Steam/CO2 Reformation system, including heating systems, HVAC equipment. Also, feedstock would be physically deposited in the receiving area via selfunloading transfer trucks or other suitable vehicles. Per Section 9.52.100, noise levels caused by mechanic equipment on public property in residential areas should not result in noise levels in excess of 65 dBA. Given the data in Table 4.12-3 of the IS/MND and the known distance to the nearest noise receptors, the operational noise levels would be substantially below the 65 dBA standard of the City of Richmond Noise Ordinance and the operational noise impact would be less than significant.

Air Quality: Odor
Odors may exist and derive from the organic feedstock that is already produced and processed at the WCCSL. The first step in the Raven process is to dry incoming feedstock using waste heat from the LFG engines before introduction to Raven’s first stage reformer. Dry feedstocks do not typically create or form odors. To proactively address the potential for odors, the Raven SR Project included the implementation of several odor minimization procedures and regulatory requirements. These odor minimization requirements include:
 Feedstock load checking at the Republic site for identification and removal of prohibited material including any highly-odorous loads;  Feedstock pre-processing at the Republic site before being sent to the Raven facility;
 Operations protocol for first in/first out feedstock consumption;  Feedstock will typically be processed within 24 hours with a maximum limit within 48 hours of receipt;
 Daily cleaning of the feedstock handling area; and
 Use of odor suppressants if necessary.

Feedstock for the Raven process will only include pre-processed, consisting primarily of blended green waste and food waste. The source of this material is from the onsite composting facility referred to as the OMPF. The OMPF receives vehicle loads directly from residential and commercial organics collection programs. The OMPF operating procedures include initial visual screening and a load checking program designed to identify and remove prohibited material, including any highly odorous loads. After screening and load checking, the remaining organic material is pre-processed by grinding. Only material that has been through the screening, load checking and grinding process at the OMPF would be delivered to the Raven facility, thus minimizing the potential for receiving prohibited or highly odorous material. In addition, all incoming pre-processed feedstock received at the Raven SR facility would also be subject to the Raven SR’s own screening and load checking program as required by State solid waste facility regulations.
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To further minimize potential odor effects of the proposed project, the standard operating procedures for the Raven facility would include a “first in first out protocol” for the processing of material. Typically, any material received would be processed within 24 hours of receipt through the hydrogen conversion system. As a requirement of both the draft CUP and the Solid Waste Facility Permit (SWFP) for the facility, all feedstock material would, at a maximum, be processed within 48 hours of receipt. With this minimal time effects of the proposed project in the feedstock handling area, the potential for odor would be greatly reduced as opposed to odors arising over time from decomposing feedstock.

Additional odor minimization provisions and requirements would be incorporated into the proposed project in accordance with the draft CUP and SWFP and addressing maximum volumes for daily input and storage, facility cleaning schedule, complaint response and reporting protocols, preparation and adherence to an Odor Prevention and Management Plan (OPMP) the requires an annual evaluation report. As discussed in more detail in the CEQA assessment of potential odor impacts (Section 4.3, Air Quality), Raven SR will implement operating procedures and comply with regulatory requirements related to minimizing potential odor impacts at the Raven SR facility in order to address and minimize potential odor impacts.

Therefore, any odor impacts from the proposed project would not be considered substantial nor likely contribute substantially to any existing odor sources of the WCCSL. The Updated IS/MND concludes the impact would be less than significant.

Air Quality: Dust
Activities that generate dust include excavation and equipment movement across unpaved construction sites. Dust can be an irritant causing watering eyes or irritation to the lungs, nose, and throat. Excavation, grading, and other construction activities can cause wind-blown dust that adds PM10 and PM2.5 to the local atmosphere.

The Bay Area Air Quality Management District (BAAQMD) has taken a qualitative approach to addressing fugitive dust emissions during construction, such that any project that implements the BAAQMD Basic Construction Mitigation Measures Recommended for All Projects (Best Management Practices) would not result in a significant impact with respect to fugitive dust (BAAQMD 2017b). Mitigation Measure AQ-1: Best Management Practices, provided in the Updated IS/MND, specifies BAAQMD recommended measures and would apply to all individual projects to address construction dust. In conclusion, while air emissions from construction equipment are all below the BAAQMD CEQA thresholds construction dust emissions are always considered significant within the San Francisco Bay Area Air Quality Basin (SFBAAB) unless the mitigation measures in Section 4.3 of the IS/MND are applied.

The Updated IS/MND concludes that dust impacts will be less than significant after mitigation.

Cultural Resources
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To determine the cultural resources sensitivity of the project site, a records search and background research, including a review of historic maps, aerial imagery, and geologic/soils data was completed. No cultural resources have been previously recorded in the vicinity of the project site and there are no historic-age architectural resources in or adjacent to the project site. The nearest cultural resources are a series of pre-contact archaeological sites nearly 1 mile to the east that contribute to the Lower San Pablo Creek Archaeological District. These resources would not be impacted by the proposed project.

Based on the results of the background research and environmental context, the potential for encountering archaeological resources during project implementation is low. However, in the unlikely event that a previously unrecorded archaeological resource is identified during project ground-disturbing activities and found to qualify as a historical resource or a unique archaeological resource, any impacts on the resource resulting from the project could be potentially significant.

Implementation of Mitigation Measure CUL-1a: Cultural Resources Awareness Training and Mitigation Measure CUL-1b: Inadvertent Discovery of Cultural Materials or Tribal Cultural Resources would reduce potentially significant impacts to less than significant.

Tribal Cultural Resources
As part of the IS/MND, the California State Native American Heritage Commission (NAHC) was contacted to request a search of the NAHC’s Sacred Lands File and a list of Native American representatives who may have knowledge of tribal cultural resources in the project vicinity or interest in the proposed project. The NAHC noted that the Sacred Lands File has no record of any sacred sites within the project site and provided a list of 15 Native American representatives from tribal groups who may have knowledge of tribal cultural resources in the vicinity of the project site. Staff sent notices to the 15 tribes and no tribes requested consultation.

Based on the Northwest Information Center records search and the NAHC Sacred Land File negative search results, there are no known tribal cultural resources listed or determined eligible for listing in the California Register of Historical Resources or included in a local register of historical resources.

In the event that cultural materials are identified during project construction activities that are determined to be tribal cultural resources, implementation of Mitigation Measure CUL-1a: Cultural Resources Awareness Training, Mitigation Measure CUL-1b:

Inadvertent Discovery of Cultural Materials or Tribal Cultural Resources, and Mitigation Measure CUL-2: Inadvertent Discovery of Human Remains, as identified in Section 4.5, Cultural Resources of the Updated IS/MND (Exhibit B), would reduce potentially significant impacts to less than significant.

Biological Resources
As part of the IS/MND, a list of special-status species that occur in the project region was identified based upon review of existing information, including queries of the California Natural Diversity Database (CNDDB), U.S. Fish and Wildlife Service 852

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(USFWS) Official Species List, and the California Native Plant Society (CNPS). Habitats at the project area were assessed for their potential to support special-status species using information about local species occurrences and species’ habitat requirements.

No special-status plant species are expected to occur on the disturbed project site.

Impacts during the non-breeding season are not considered significant, primarily due to the birds’ mobility and ability to access other high-quality foraging habitat in the region.

Also, the project site is disturbed and provides poor habitat for nesting birds. However, equipment staging and project construction could render the site and adjacent areas temporarily unsuitable for breeding birds due to the noise, vibration, and increased activity levels associated with grubbing, earth moving, heavy equipment operation, and increased human presence even when the nest itself is unaffected.

These activities could cause birds that have established a nest prior to the start of construction to change their behavior or even abandon an active nest, putting eggs and nestlings at risk for mortality. This would be considered a significant impact.

Implementation of Mitigation Measure BIO-1: Avoid and Minimize Impacts to Nesting Birds, Except Rails, and Mitigation Measure BIO-2: Avoid and Minimize Impacts to California Black Rail and California Ridgway’s Rail would reduce potential construction related impacts to nesting special-status birds to a less-than-significant level by requiring avoidance of construction-related work during the nesting bird season, or if avoidance of the nesting season is not possible, pre-construction nesting bird surveys and establishment of no-construction buffer zones around active bird nests.

With implementation of Mitigation Measures BIO-1 and BIO-2, construction-related impacts would be less than significant.

PUBLIC COMMENTS:

The project site is not located within a neighborhood council boundary. Staff received 13 comment letters of support for the project as well as 6 comment letters citing environmental concerns during the initial IS/MND process. In response to the Updated IS/MND, Staff received 7 letters of support for the project, 9 letters citing environmental concerns, and 3 neutral letters. All letters received are provided in the Responses to Comments Technical Memorandums (see Attachments 3 & 7).

Most of the letters citing environmental concerns requested that City Council approve the appeal and require an EIR to be completed. This request is discussed in the Basis of Appeal section of this report, starting on page 7.

GENERAL PLAN CONSISTENCY:

The General Plan designation for the subject site is Open Space. The project would provide a service to the community, create construction and operational jobs, help in maintaining the economic viability of this area, while being conducted in a secure setting. The proposed project is harmonious with, and relates properly to, the surrounding WCCSL property and the project site itself. The project is also consistent with the General Plan Land Use Goal LU3.J – Industrial Modernization as well as the General Plan’s Policy CR5.2 – Renewable Energy and Clean Technology. The project 853

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is also consistent with the City’s Climate Action Plan. The proposed major utilities use is consistent with the General Plan policies and the Open Space land use designation.

CONDITIONAL USE PERMIT FINDINGS:

To approve any CUP, the City Council must make the findings below in accordance with RMC Section 15.04.806.040:

1. The location of the proposed conditional use is in accordance with the General Plan and any applicable specific plan and the land use designations for the project site;

2. The location, size, design, and operating characteristics of the proposed use will be compatible with and will not adversely affect the livability or appropriate development of abutting properties and the surrounding neighborhood;

3. The proposed use will not create any nuisances arising from the emission of odor, dust, gas, noise, vibration, smoke, heat or glare at a level exceeding ambient conditions;

4. The proposed use complies with all applicable provisions of Article XV; and

5. The site of the proposed use is adequately served by highways, streets, water, sewer, and other public facilities and services.

Staff believes all the findings above can be made for the proposed project, and the Planning Commission made findings in alignment with the above. If the Council is inclined to approve this project and deny the appeal, the findings and recommended statements of fact for the updated mitigated negative declaration, design review and conditional use permit findings are provided in the resolution in Attachment 1; and substantially mirror the findings of the Planning Commission in its Resolution No. 22-18 (Attachment 4).

After Planning Commission approval, some details about site operations were changed, resulting in necessary adjustments to the Conditional Use Permit (CUP) approved by the Planning Commission. City Council has the authority to adopt an adjusted Conditional Use Permit which would supersede that approved by the Planning Commission. The Planning Commission would thereafter have the authority to adjust and uphold CUP conditions in accordance with the language provided in the Updated Conditional Use Permit Conditions of Approval (Exhibit C of Attachment 1), which would be adopted as the part of the Resolution in Attachment 1.

City staff is recommending certain additional conditions to be included in the CUP, summarized as follows:

1. Incorporation of emergency hydrogen venting system.
854

May 16, 2023

2. Expansion on, and clarification of, the existing five-year review process to clarify review of implementation of OSHA guidelines, worker safety, air quality monitoring, and best efforts to hire North Richmond residents.

3. Zero or Near Zero Emission Vehicles best efforts language around commercial availability and contracting with third-party haulers.

Administrative language changes reflecting the adoption of the CUP by the City Council rather than the Planning Commission are also included.

DOCUMENTS ATTACHED:

Attachment 1 – Resolution to Uphold the Planning Commission’s conditional approval in part and adopt the Updated MND, MMRP, Conditional Use and Design Review Permits by approving Planning Application No. PLN21-282
Exhibit A – Project Plans
Exhibit B – Updated IS/MND & MMRP
Exhibit C – Updated Conditional Use Permit Conditions of Approval Attachment 2 – Draft IS/MND
Attachment 3 – Responses to Comments of IS/MND & MMRP
Attachment 4 – Planning Commission’s Resolution No. 22-18 approving the Conditional Use Permit and Design Review and adopt an MND and MMRP
Attachment 5 – Appeal letter from Tessa Wardle on behalf of CBE and NRDC Attachment 6 – Applicant’s Response to the Appeal letter Attachment 7 – Responses to Comments of Updated IS/MND Technical Memorandum Attachment 8 – Letter from Carbon Management Partnerships, Lawrence Livermore National Laboratory
Attachment 9 – IS/MND vs EIR Comparison Chart
855
Res. No. ____

ATTACHMENT 1
DRAFT RESOLUTION NO. ____

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF RICHMOND

DENYING THE APPEAL OF, AND AFFIRMING THE DECISION OF THE

PLANNING COMMISSION AS MODIFIED, REGARDING PLANNING
APPLICATION NO. PLN21-282, AND I) ADOPTING AN UPDATED MITIGATED NEGATIVE DECLARATION; II) APPROVING A MITIGATION MONITORING AND REPORTING PROGRAM; AND III) APPROVING CONDITIONAL USE

AND DESIGN REVIEW PERMITS FOR THE RAVEN BIOENERGY PROJECT (PLN21-282)
WHEREAS, on July 30, 2021, Raven SR, LLC (“applicant” or “permittee”), filed Planning Application No. PLN21-282, requesting approval of design review and conditional use permits for the proposed Raven Bioenergy Project (“project”) to be located at 1 Parr Boulevard in the OS (Open Space) District, Assessor’s Parcel No. 408-140-009 (“project site”); and
WHEREAS, the project involves the construction and operation of a bioenergy facility that would convert food and green waste into transportationgrade hydrogen; and WHEREAS, the project is governed by the Richmond General Plan and Richmond Municipal Code (“RMC”); and
WHEREAS, the Project is subject to the California Environmental Quality Act (“CEQA”) (Public Resources Code 21000-21189) and the State CEQA Guidelines (California Code of Regulations, Title 14, Division 6, Chapter 3, Sections 15000-15387); and
WHEREAS, the City, as the lead agency under CEQA, prepared an environmental initial study for the project; and
WHEREAS, based on the analysis in the initial study, the potentially significant effects of the project could be reduced to a less-than-significant level through implementation of specific mitigation measures, and subsequently, a mitigated negative declaration was prepared; and
WHEREAS, on November 7, 2022, a notice of intent to adopt a mitigated negative declaration (“NOI”) was distributed for 30-day public review and comment period, in accordance with CEQA Guidelines Section 15072 and 15105; and
WHEREAS, on December 7, 2022, the public review and comment period for the mitigated negative declaration was extended for an additional 15 days to 856
Res. No. ____

allow interested parties more time to review the document; and WHEREAS, although not required by CEQA, the City responded to all written comments received during the public review and comment period; and WHEREAS, on or prior to December 2, 2022, notice of the December 15, 2022 public hearing was given in accordance with Richmond Municipal Code (“RMC”) Section 15.04.803.070 (Public Notice) and applicable State law; and WHEREAS, on December 15, 2022, the Planning Commission considered the mitigated negative declaration (State Clearinghouse #2022100145) and conditional use and design review permits, and held a public hearing on the project, at which time oral and/or written testimony was considered; and WHEREAS, following the close of the public hearing on the matter, the Planning Commission made findings regarding the mitigated negative declaration, and conditional use and design review permits, and voted to conditionally approve Planning Application No. PLN21-282; and WHEREAS, within the 10-day appeal period provided to file an appeal of the Planning Commission’s decision, an appeal was timely filed with the City; and WHEREAS, to provide clarity to questions raised in the appeal, the City prepared an updated mitigated negative declaration to clarify, amplify, and refine the language of the mitigated negative declaration. Among other items, the update provided an additional description of proposed operational details, information from a health risk assessment (HRA), and more details regarding the project’s impacts on air quality and greenhouse gases; and WHEREAS, although not required by CEQA, on March 9, 2023, a notice of intent to adopt an updated mitigated negative declaration was distributed for a 30-day public review and comment period; and
WHEREAS, on March 14, 2023, the public review and comment period for the updated mitigated negative declaration was extended through April 12, 2023, for a total of 34 days, to allow interested parties more time to review the document and a clarified table; and
WHEREAS, written comments were received, and although not required by CEQA, the City responded to all written comments received during the public review and comment period and made those responses available on April 26, 2023; and
WHEREAS, the City provided notice of the City Council hearing on the appeal as required by law; and
WHEREAS, on May 16, 2023, the City Council received and reviewed the 857
Res. No. ____

appeal of the Planning Commission’s decision granting Planning Application No.

PLN21-282, including the mitigated negative declaration for the project, at a duly noticed meeting; and
WHEREAS, a public hearing was held, and the opportunity for public comment on the appeal of the Planning Commission’s decision was provided; and
WHEREAS, any and all public testimony and evidence, both written and oral, was considered by the City Council; and
WHEREAS, after considering any public testimony and receiving information provided to date, the City Council closed public testimony and deliberated on the appeal based on the evidence in the administrative record; and
WHEREAS, after consideration of said public testimony and information in the record, the City Council determined that there was substantial evidence in the record that the project complied with the RMC, CEQA, and all requirements for approval of Planning Application No. PLN21-282; and
WHEREAS, the City Council now desires to deny the appeal and uphold the decision of the Planning Commission to approve Planning Application No.

PLN21-282 as further conditioned, including the adoption of the updated mitigated negative declaration for the project.

NOW, THEREFORE, the City Council of the City of Richmond resolves and finds as follows:

Recitals

1. The City Council finds that the recitals are true and correct and incorporates the same herein as if set forth in full.

Administrative Record

2. The record of proceedings (“Record”) for the project includes, but is not limited to: (1) all staff reports, City files and records and other documents prepared for and/or submitted to the Planning Commission, City Council, and the City relating to the project; (2) the evidence, facts, findings and other determinations set forth in this resolution; (3) the City of Richmond General Plan and the RMC; (4) all applications, designs, plans, studies, data and correspondence submitted by the applicant in connection with the project; (5) all documentary and oral evidence received at public hearings or submitted to the City relating to the project; (6) all other matters of common knowledge to the Planning Commission and City Council including, but not limited to, City, state 858
Res. No. ____

and federal laws, policies, rules regulations, reports, records and projections related to development within the City and its surrounding areas; and (7) all documents specified under applicable State law including Public Resources Code section 21167.6(e).

Mitigated Negative Declaration Findings:

3. The City Council finds and determines that there is no substantial evidence in the record that Planning Application No. PLN21-282 may have a significant effect on the environment as identified by the Initial Study/Mitigated Negative Declaration, as updated, prepared for the project. The City Council finds that an Initial Study (Environmental Assessment) was prepared for this project in accordance with the requirements of the California Environmental Quality Act (CEQA) Guidelines, and reflects the Council’s independent judgement and analysis. This process included the distribution of requests for comment from other responsible or affected agencies and interested organizations. Preparation of the Environmental Assessment necessitated a thorough review of the proposed project and relevant environmental issues and considered previously prepared environmental and technical studies. While the proposed project could have a potentially significant effect on the environment, based on its independent judgement and analysis, the City Council finds that feasible mitigation measures or alternatives have been incorporated into the project in order to avoid the effects or mitigate the effects to a point where no significant effect on the environment will occur, and there is no substantial evidence in the record that this project may have any direct, indirect or cumulative effects on the environment that are potentially significant and adverse. The proposed project will not result in any adverse effects which fall within the “Mandatory Findings of Significance” contained in Section 15065 of the State CEQA Guidelines. The project-specific mitigation measures included in the Project to avoid potentially significant effects are set forth in the Initial Study/Mitigated Negative Declaration and accompanying Mitigation Monitoring and Reporting Program. With the project specific mitigations imposed, there is no substantial evidence in the record that this project may have significant direct, indirect, or cumulative effects on the environment. As such, the City Council finds and determines that there is substantial evidence in the administrative record to support the Planning Commission determination that the project has been adequately environmentally assessed as required by CEQA. The City Council also finds and determines that in light of the entire administrative record and the substantial evidence before it, the project has been adequately environmentally assessed as required by CEQA. 859
Res. No. ____

Conditional Use Permit Findings and Statements of Fact:

4. The City Council finds and determines that there is substantial evidence in the administrative record to support the City Council’s review of the Planning Commission’s adoption of Planning Application No. PLN21-282 as being consistent with the requirements of the Municipal Code requirements applicable to conditional use permits, including RMC Section 15.04.806.040. Additionally, the City Council also finds and determines that there is substantial evidence in the entire administrative record that Planning Application No. PLN21-282, as conditioned, is consistent with the requirements of the Municipal Code requirements applicable to conditional use permits. The City Council further approves, accepts as its own, incorporates as if set forth in full herein, and makes each and every one of the findings, based on the evidence in the record, as set forth below.

5. The location of the proposed conditional use is in accordance with the General Plan and any specific plan and land use designations for the project site.

Statement of Fact: The project site is not located in any specific plan area. The General Plan land use designation for the project site is “Open Space”. According to the General Plan, this designation is intended to include wetlands, mudflats, creek corridors and other natural preservation areas, as well as private lands used for recreational purposes or deed-restricted for open space preservation, and utilities. The proposed use falls under the classification of “Utilities, Major” and is therefore consistent with the General Plan land use designation. RMC Section 15.04.104.020 defines “Utilities, Major” as generating plants, electric substations, and solid waste collection, including transfer stations and materials recovery facilities, solid waste treatment and disposal, water or wastewater treatment plants, biomass and waste to energy conversion facilities, and similar facilities of private companies, public agencies or public utilities.

6. The location, size, design and operating characteristics of the proposed use will be compatible with and will not adversely affect the livability or appropriate development of adjacent properties and the surrounding neighborhood.

Statement of Fact: The project site is in a non-residential area that is dominated by industrial uses with similar operating characteristics, including the West County Wastewater District Treatment Plant, EBMUD’s North Richmond Water Reclamation Plant, the Richmond Sanitary District, and other refuse services.

7. The proposed use will not create any nuisances arising from the 860
Res. No. ____

emission of odor, dust, gas, noise, vibration, smoke heat or glare at a level exceeding ambient conditions.

Statement of Fact: The project is required to comply with RMC Articles

15.04.604 (Lighting and Illumination), 15.04.605 (Noise), and

15.04.608 (Performance Standards). These articles prescribe standards and limitations designed to avoid potential nuisances from glare, noise, odors, particulate matter, air contaminants, and vibration.

The mitigated negative declaration also identifies measures that the project will implement to mitigate the project’s potential air quality impacts.

8. The proposed use complies with all applicable provisions of Article XV.

Statement of Fact: The proposed use falls under the classification of “Utilities, Major” and this classification is permitted in the OS (Open Space) District after review and approval of a conditional use permit by the Planning Commission. RMC Section 15.04.206.040 (Development Standards) prescribes development standards for the OS District and the project meets these standards which include minimum and maximum height, setbacks, and floor area ratio. The project also complies with RMC Article 15.04.805 (Design Review), which requires Major Design Review for industrial additions or improvements over 1,000 square feet. On October 26, 2022, the Design Review Board considered the project and recommended the Planning Commission grant design review approval, subject to conditions of approval.

9. The site of the proposed use is adequately served by highways, streets, water, sewer and other public facilities and services.

Statement of Fact: The project site is in an area adequately served by existing public infrastructure, streets, and highways such as Richmond Parkway and Interstates 80 and 580. In addition, there is adequate capacity in nearby public facilities and services to serve the project site.

Design Review Permit Findings:

The City Council finds and determines that there is substantial evidence in the administrative record to support the City Council’s review of the Planning Commission’s adoption of Planning Application No. PLN21- 282 as being consistent with the requirements of the Municipal Code requirements applicable to design review permits, including RMC Section 15.04.805.050. Additionally, the City Council also finds and determines that there is substantial evidence in the entire administrative record that Planning Application No. PLN21-282, as conditioned, is consistent with the requirements of the Municipal Code requirements 861
Res. No. ____

applicable to design review permits. The City Council further approves, accepts as its own, incorporates as if set forth in full herein, and makes each and every one of the findings, based on the evidence in the record, as set forth below.

10.The project is consistent with General Plan and any applicable specific plans;
Statement of Fact: The project site is not located in any specific plan area. The General Plan land use designation for the project site is “Open Space”. According to the General Plan, this designation is intended to include wetlands, mudflats, creek corridors and other natural preservation areas, as well as private lands used for recreational purposes or deed-restricted for open space preservation, and utilities. The proposed use falls under the classification of “Utilities, Major” and is therefore consistent with the General Plan land use designation. RMC Section 15.04.104.020 defines “Utilities, Major” as generating plants, electric substations, and solid waste collection, including transfer stations and materials recovery facilities, solid waste treatment and disposal, water or wastewater treatment plants, biomass and waste to energy conversion facilities, and similar facilities of private companies, public agencies or public utilities. The project will advance several General Plan policies, including EC2.2 (ClimateFriendly Fuel) which calls for supporting the production and distribution of climate-friendlier fuel at appropriate locations; and EC5.1 (Green Businesses and Jobs), which calls for promoting green industries, including those that fill the growing need for clean fuels.

11.The project is consistent with any applicable design guidelines; Statement of Fact: There are no design guidelines in place for the area in which the project is located; however, the Design Review Board considered the project on October 26, 2022, and recommended the Planning Commission grant design review approval, subject to conditions of approval.

12.The project is consistent with any approved tentative map, use permit, variance, or other planning or zoning approval that the projectrequired; Statement of Fact: The design review and conditional use permit for the project have been reviewed concurrently to ensure consistency between the approvals. No tentative map, variance, or other planning or zoning approval are being requested.

13.The project is consistent with the design review criteria in Section

15.04.805.04:
a. The overall design of the project, including its scale, massing, 862
Res. No. ____

site plan, exterior design, and landscaping, reflects design integrity and the relationship of form and function in a coherent manner.
b. The project design evidences a sense of place and
consideration of scale, mass, height, building siting, an privacy in a neighborhood and community context; does not overwhelm or adversely impact adjoining properties; and respects
prevailing setbacks and the scale and heights of neighboring buildings and how they relate to the street.
c. The project’s design elements, materials, signage, and landscaping are internally consistent, fully integrated with one another, and applied in a manner that is visually consistent with the proposed architectural design.
d. Lighting and lighting fixtures are designed to complement buildings, be of appropriate scale, provide adequate light over walkways and parking areas to create a sense of pedestrian safety, and avoid creating glare.
e. The proposed building design and landscaping supports public safety and security by allowing for surveillance of the street by people inside buildings and elsewhere on the site.
f. Landscaping is designed to be compatible with and enhance the architectural character of the buildings on site. Proposed planting materials avoid conflicts with views, lighting, and signage.

Statement of Fact: The project will meet design criteria “a” through “f.” The project will achieve a design that will be compatible with the surrounding uses in the area. The project buildings will be low in height to reduce impacts on views and are within the existing WCCSL property. The project includes landscaping improvements offsite to the Landfill Loop Trail and the trail head parking lot. Conditions of approval will ensure any new lighting and lighting fixtures are designed to avoid creating glare.

NOW, BE IT FURTHER RESOLVED that for all the foregoing reasons, and each of them, the City Council finds that there was no substantial evidence submitted into the administrative record that would warrant denial of Planning Application No. PLN21-282, including the design review permit, conditional use permit, or the mitigated negative declaration, for this project as conditioned during the public hearing and appeal process. As such, the appeal is denied in its entirety.
863
Res. No. ____

NOW, BE IT FURTHER RESOLVED that for all the foregoing reasons, and each of them, the City Council upholds the Planning Commission approval of Planning Application No. PLN21-282 as further conditioned by the City Council.

Further, for all of the foregoing reasons and based upon the substantial evidence in the record before it, and given that after the conditions and restrictions added by the Planning Commission and after the appeal, there is no substantial evidence in the administrative record that would warrant denial, the City Council also independently approves Planning Application No. PLN21-282 as further conditioned by the City Council as set forth below. This approval includes approval of the submitted Project Plans (Exhibit A), adoption of the updated Mitigated Negative Declaration for the project (Exhibit B), including the associated Mitigation Monitoring and Reporting Program included as a part of Exhibit B, as the project will not result in any significant, adverse, environmental impacts with the mitigation imposed. The City of Richmond Community Development Department, Planning Division, located at 450 Civic Center Plaza, Richmond, CA 94804 designated as the custodian of the documents and other materials that constitute the record of proceedings upon which the decision is based. The City Council authorizes the Director, or designee, to execute and file with the Contra Costa County Clerk, as appropriate, a Notice of Determination for approval of the project. Finally, the approval of the design review and conditional use permit for Planning Application No. PLN21-282, is subject to the ProjectSpecific Conditions of Approval provided as Exhibit C.

NOW, BE IT FURTHER RESOLVED that this Resolution shall become effective immediately.
----------------------------------------
I certify that the foregoing resolution was passed and adopted by the City Council of the City of Richmond at a regular meeting held on May 16, 2023 by the following vote:

AYES:

NOES:

ABSTENTIONS:

ABSENT:

Clerk of the City of Richmond
(SEAL)
Approved:

Mayor
Approved as to form:

City Attorney
864
PLAN
NORTH

INFORMATION TABLE

1. 2.3.4.5.

6. 7.8.9.
10 ITEM

LOT SIZELOT WIDTHPROJECT DENSITYTOTAL BUILDING AREA AND FLOOR-TO-AREA-RATIOSNUMBER OF BUILDING STORIES AND HEIGHTSPERCENT LOT COVERAGE PERCENT LANDSCAPE AREAPERCENT COMMON AND PRIVATE OPEN SPACETOTAL IMPERVIOUS SURFACE AREA (NEW AND/OR REPLACED)PARKING BY Ti/PE

RESPONSE
N/AN/AN/AN/A1 STORY CONTROL ROOM; <35 FT MAX HEIGHTN/ASEE LANDSCAPE PLANN/A"1.75 ACRESOFF STREET T/TLE: RAVEN SR BIOENERGY PROJECT
ADDRESS: 1 PARR BLVD, RICHMOND, CA
APN 408-140-009-7
CONTACT:

RAVEN SR LLC

MATT MURDOCK CEO
PO BOX 1360, PINEDALE, WY 82941

GENERAL PLAN AND ZONING DESIGNATIONS

THE PROJECT SITE AND SURROUNDING AREA IS
LOCATED WITHIN THE "OPEN SPACE: GENERAL PLANLAND USE DESIGNATION AND "OPEN SPACE" ZONING DISTRICT.

PRELIMINARY

NOT FOR

CONSTRUCTION

THIS DRAWING WAS PREPARED BY POWER
ENGINEERS, INC. FOR A SPECIFIC PROJECT,
I TAKING INTO CONSIDERATION THE SPECtFtCI AND UNIQUE REQUIREMENTS OF THE PROJECT.

REUSE OF THIS DRAWING OR ANY INFORMATIONCONTAINED IN THIS DRAWING FORANY PURPOSEIS PROHIBITED UNLESS WRITTEN PERMISSIONFROM BOTH POWER AND POWER'S CUENT ISGRANTED.

RAV?N
REV

ISSUED FOR REVIEW

REVISIONS
09f1S/2022
DATE
TGC
DRN
TGC

DSGN CKD REFERENCE DRAWINGS
DSGN
CKD
TGCTGC
09/1B2022

AS-SHOWN
FOR 22x34 DWG ONLY
PROJECT:
.POWER'ENGINEERS
2041 South Cobalt Point Way, Meridian, ID 83642
(208)2B8-6464:COA:77?7?
POWER ENGINEERS INC.

STELLAR J / RAVEN ONE PROJECT

CEQA TITLE SHEET

LOCATION
RCHCA
REV
A

DRAWING NUMBER
1-00-CEQA-4

EXHIBIT A
865
•CITffCOUNTT

BOUNDARY LINE
-•-/ELEC
^>..
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<<

EXISTINGREPUBLIC

STORAGE
\. / ?sv
KEYED NOTES" .:^)FEED MATERIAL HANDLING EQUIPMENT, DRYER 2 >SR1 ROTARY PRIMARY REFORMER
Q HEAT RECOVERY STEAM GENERATOR (f1</4)BAGHOUSE FILTRAT10N SYSTEM</5) SR2 SECONDARY REFORMER <6> ASH MANAGEMENT SYSTEM
(T/ HCN REACTOR, HEAT RECOVERY STEAM GENERATOR #2(a) SYNGAS CONDITIONING - COOLER(s)sYNGAS COMPRESSOR ; 10 >SYNSAS CONDITION - SULFUR REMOVAL

HTSLTS WGS REACTORS
^PRESSURE SWING ADSORPTION UNITS((^HYDROGEN FILTERS - CARBON BEDS@ HYDROGEN COMPRESSION SYSTEMl(u) AMMONIA CHILLER SYSTEM (w) TAIL GAS TANK
(w) WATER TREATMENT SYSTEM
<^7) STEAM AND CONDENSATE SYSTEM^COOLING TOWER<(l9>NrTROGEN SYSTEM^20) PROFANE SUPPLY<^2l) COMPRESSED AIR SYSTEM^22) FLARE SYSTEM (LOCATION TBD)<^a)HYDROGEN EXPORT PANEL<24> CONTROL ROOM AND OPERATOR FACILIT/ (1500 SQ FT) ^)E-HOUSE(GOOSQFT)
; 26 > ABOVE GROUND FP WATER STORAGE
(30'DIAX32'TALL)
<^ FIRE PUMP HOUSE
: 29 > POWER GENERATION BUILDING
^30) IN FEED HOPPER<31) FEED STOCK STORAGE COVERED STRUCTURE (3500 SQ FT) <32) FEED STOCK TRAILER@) HYDROGEN TRAILER(^COVERED LIMESTONE STORAGE (480 SQ FT) : 35 > CONCRETE PAD (1700 SQ FT)

PRELIMINARY

NOT FOR

CONSTRUCTION

LS PREPARED BY POWER
ENGINEERS, (MC, FORA SPECIFIC PROJECT.

FAKING 1WTO CONSIDERATION THE SPECIFIC
AND UNIQUE REQUIREMENTS OF THE PROJECT.

REUSE OF THIS DRAWING OR ANY INFORMATION
;ONTAINED [N THIS DRAWING FOR ANY PURPOSE
; PROHIBrTED UNLESS WRITTEN PERMiSSION

FROM BOTH POWER AND POWER'S CLIEKT IS
GRANTED.

RAVfN STELLAR J cB
A
REV
ISSUED FOR REVIEWISSUED FOR 30% REVIEWISSUED FOR REVIEWINITIAL ISSUE

REVISIONS
07/19/202203/17/202203/02/202207/07/2021
DATE
JAS
TGC
HJE

WRLWRLWRL JKA
JKA
CKD
SKASKA

APPD REFERENCE DRAWINGS

DSGNDRNCKD
WRL
HJEJKA
07/08/2107/08(2107/09/21
SCALE: NTS
FOR 22x34 DWG ONLY
PROJECT: 174550
^POWER
^ENGINEERS
2041 South Cobalt Point Way, Meridian, ID B3642(20a)2?W84:COA:???7? POWER ENGINEERS INC.

STELLAR J / RAVEN ONE PROJECT

BASE CASE

CEQA PLOT PLAN

LOCATION
RCHCA
REV
A

DRAWING NUMBER
il-00-GA-CEQA-'
866

GENERAL LAYOUT

PRBJWARY

NOT FOR

CONSTRUCTION

DRAWING WAS PREPARED BY POWER
ENGINEERS, INC. FOR A SPECIFIC PROJECT,

FAKING INTO CONSIDERATION THE SPECIFIC
AND UNIQUE REQUIREMENTS OF THE PROJECT.

REUSE OF THIS DRAWING OR ANY INFORMATIONCONTAINED !N THIS DRAWING FORANY PURPOSEIS PROHIBITED UNLESS WRITTEN PERMISSION

FROM BOTH POWER AND POWER'S CUENT IS
GRANTED.

RAVrN
REV
ISSUE FOR PERMITTING 07/22/2022
DATE
TGC
DRN
TGC
DSGN
HS

CKD REFERENCE DRAWINGS

DSGNDRNCKD
TGCTGC
HS
07/22/202207/22/202207/22/2022
SCALE: NTS
FOR 22x34 DWG ONLY
PROJECT: 174550
.POWER
^ENGINEERS
POWER ENGINEERS INC.

STELLAR J / RAVEN ONE PROJECT
RICHMOND CA. PLANT

GENERAL LAYOUT

LOCATION
RCHCA
REV
A

DRAWING NUMBER
1-00-GA-002
867

FEED MATERIAL
HANDLING WATER TANKS L COOLING TOWERS •HYDROGEN TRUCK LOADING ELEVATION LOOKING SOUTH 1 OF 2
PRBJ^NARY

NOT FOR
CONSTOUCnON
/ING WAS PREPARED BY POWER
ENGINEERS, INC. FORASPECIFIC PROJECT.FAKING mo CONSIDERATION THE SPECIFIC HD UNIQUE REQUIREMENTS OF THE PROJECT.

IREUSE OF THIS DRAWING OR AMV INFORMATION
;ONTAINED IN THIS DRAWING FORANY PURPOSE

PROHIBITED UNLESS WRITTEN PERMISSION
[FROM BOTH POWER AND POWER'S CUENT IS
I GRAFTED.

RAVfN
REV

ISSUE FOR PERMITTING TGC TGC HS

REFERENCE DRAWINGS
CKD
"TGC"
TGC
HS
07/22/202207/22/2022
SCALE:

PRCUECTT
.POWER
'ENGINEERS
2041 South Coball Point Way, Meridian, ID 83642
POWER ENGINEERS INC.

STELLAR J / RAVEN ONE PROJECT
RICHMOND CA. LOCATION

GENERAL ARRANGEMENT

LOCATION
RCHCA
REV
A'

DRAWING NUMBER
1-00-GA-003
868

FIRE WATER TANK

AND PUMP SYSTEM
FEED MATERIAL ^-FLAREHANDLING
ELEVATION LOOKING SOUTH 2 OF 2
PfBAWAHY
NOTTOR

CONSTRUCTION
Q IENGINEERS, INC. FOR A SPECIFIC PROJECT,
TAKING INTO CONSIDERATION THE SPECiFlCAND UNIQUE REQUIREMENTS OF THE PROJECT.REUSE OF THIS DRAWING OR ANY INFORMATIONCONTAINED IN THIS DRAWING FOR ANY PURPOSE iOHIBITED UNLESS WRITTEN PERMISSION
FROM BOTH POWER AND POWER'S CUENT iSGRAm'ED.

RAVfN
REV

ISSUE FOR PERMITTING

REVISIONS
07(22/2022
DATE
TGC
DRN
TGC
DSGN
HS

APPD REFERENCE DRAWINGS
DSGN^DRN
TGCTGC
07/22/2022
SCALE: NTS
FOR 22x34 DWG ONLY
e^. POWER ENGINEERS
POWER ENGINEERS INC.

STELLAR J / RAVEN ONE PROJECT
RICHMOND CA. PLANT
ELEVATION LOOKING SOUTH 2 OF 2

LOCATION
RCHCA
REV
A

DRAWING NUMBER
1-00-GA-004
869

ELEVATION LOOKING WEST

PRBAWARY

NOT FOR

CONSTRUCTION
ENGINEERS. INC. FORASPECIFIC PROJECT,

FAKING INTO CONSIDERATION THE SPECIFIC
AND UNIQUE REQUIREMENTS OF THE PROJECT.REUSE OF THIS DRAWING OR ANY INFORMATION ;ONTAINED IN THIS DRAWING FORANY PURPOSE
!S PROHIBITCD UNLESS WRIHEN PERMISSION

TOM BOTH POWER AND POWER'S CUENTI
GRANTED.

RAVfN
REV

ISSUE FOR PERMITTING

REVISIONS
07/22/2022
DATE
TGC
DRN
HS

APPD REFERENCE DRAWINGS
CKD
TGC"TGC
W12WW2
07/22/2022
SCALE: NTS
FOR 22x34 DWG ONLY
PROJECT: 774550^3LPOWER

ENGINEERS
POWER ENGINEERS INC.

STELLAR J / RAVEN ONE PROJECT
RICHMOND CA. PLANT

ELEVATION LOOKING WEST

LOCATION
RCHCA
REV
A

DRAWING NUMBER
1-00-GA-005
870
!.^_j-^tl-^tM-t-ltltn4tti+ h lllln I ill I III III
•HYDROGEN TRUCK

LOADING
FEED UNLOAD?STORAGE
•FEED MATERIAL

HANDLING
ELEVATION LOOKING NORTH 1 OF 2

PRBJWARY
NOTR3R

CONSTRUCTION

WING WAS PREPARED BY POWER
ENGINEERS, INC. FORASPECIFIC PROJECT,TAKING INTO CONSIDERATION THE SPECIFICAND UNIQUE REQUIREMENTS OF THE PROJECT, tEUSE OF THIS DRAWING ORANY iNFORMATON
:ONTAINEO IN THIS DRAWING FORANY PURPOSE
!S PROHIBITED UNLESS WRITTEN PERMISSION
:ROM BOTH POWER AND POWER'S CUENT IS
GRAWED.

RAVfN
ISSUE FOR PERMITTING 07/22/2022
DATE
TGCDRN
TGC
DSGN
HS
CKD
HS

APPD REFERENCE DRAWINGS
CKD
TGCTGC
FOR 22x34 DWG ONLY
PROJECT:
.POWER

ENGINEERS
POWER ENGINEERS INC.

STELLAR J / RAVEN ONE PROJECT
RICHMOND CA. PLANT
ELEVATION LOOKING NORTH 1 OF 2

LOCATION
RCHCA Al

DRAWING NUMBER
1-00-GA-006
871
^-5

FEED UNLOADING/STORAGE
•FEED MATERIAL HANDLING -POWER GENERATION BUILDING FIREWATERTANKAND

PUMP SYSTEM
ELEVATION LOOKING NORTH 2 OF 2

PRBAWARY

NOT FOR

CONSTRUCTION
ENGINEERS, INC. FORASPECIFIC PROJECT,
fAKING INTO CONSIDERATION THE SPECIFIC
AND UNIQUE REQUIREMENTS OF THE PROJECT.
tEUSE OF THIS DRAWING OR ANY INFORMATION
;ONTAINED iN THIS DRAWINC FOR ANY PURPOSE

IS PROHIBITED UNLESS WRITTEN PERMISSION
'-ROM BOTH POWER AND POWER'S CUENT 15
SRAWED.

RAVfN

ISSUE FOR PERMITTING

REVISIONS
07/22/2022
DATE
TGC

REFERENCE DRAWINGS

DSGNDRN
CKD
TGC
TGC
HS
"07/22/2022
07/22/2022
SCALE:

PROJECT:" 174550^
e^POWER ENGINEERS
POWER ENGINEERS INC.

STELLAR J / RAVEN ONE PROJECT
RICHMOND CA. PLANT
ELEVATION LOOKING NORTH 2 OF 2

LOCATION
RCHCA
REV
A

DRAWING NUMBER
1-00-GA-007
872
•NITROGEN TANK FEED UNLOAD/

STORAGE
. ELECTRICAL (E) HOUSE LIMESTONE SILO HYDROGEN TRUCK

LOADING

ELEVATION LOOKING WEST
Pf&MNARY
NOTR3R
CON8TOUC710N
I THIS DRAWING WAS PREPARED BY POWERI ENGINEERS, INC. FORASPECtRC PROJECT,ITAKJNG INTO CONSIDERATION THE SPECIFIC|AND UNIQUE REQUIREMENTS OF THE PROJECT.I REUSE OF THIS DRAWING OR ANY WORMATtONI CONTAINED IN THIS DRAWING FORANY PURPOSE

IS PROHIBITED UNLESS WRITTEN PERMISSION
I FROM BOTH POWER ANO POWER'S CUENT ISI GRANTED.

RAVfN
REV

ISSUE FOR PERMITTING

REVISIONS
07/22/2022 TGC

REFERENCE DRAWINGS
TGC 07/22/2022
SCALE: NTS
FOR 22x34 DWG ONLY
LfOWER
^Sv EHGIHEERS
POWER ENGINEERS INC.

STELLAR J; RAVEN ONE PROJECT
RICHMOND CA. PLANT

ELEVATION LOOKING EAST

LUUAIIUN
RCHCA Al

DRAWING NUMBER
1-00-GA-008
873
874
Lane 3
Lane 2
Lane 1
Trailer Valve Panel
Trailer Valve Panel
Island
Module
Island
Module
Trailer Valve Panel
Export
Panel
Main
Module
875
A
A ISSUED FOR REVIEW 08/12/22 BRG APG BHR BHR

PRELIMINARY

FOR PERMITTING

25.00' - 30.00' (SEE PLAN) PURPOSES
876

POLE MOUNTED LED LIGHT
MOUNTING HEIGHT: 30'
(TYP)

GENERAL NOTES
DO NOT SCALE THE DRAWiNGS.CONTRACTOR SHALL VISIT THE S!TE PRIOR TOBIDDING TO DETERMINE THE EXTENT OF THE WORKTO BE PERFORMED.ALL WORK SHALL CONFORM WITH RAVEN ONESPECIFICATIONS. STANDARDS AND GOOD MANUFACTURING PRACTICES (GMPS).ALL WORK SHALL CONFORM TO ALL OSHA, FEDERAL,STATE AND LOCAL CODES,

KEYED NOTES
POLE MOUNTED FIXTURES SHALL BE INSTALLEDWITH DOWN-SHOT REFLECTORS TO UMiT LIGHTPOLUTION. CONTRACTORS TO CONFIRMINSTALLATION OF DOWN-SHOT REFLECTOR PRIORTO ORDERING LIGHTING FIXTURES.

LUMINAIRE SCHEDULE

MANUFACTURER
NAME | CATALOG NUMBER
LITHONIA | RSX2LEDP630KAFRMVOLTRPA
VOLT
208

MOUNTING

POLE MOUNTED

LAMP TYPE
LED

REMARKS

PRBAWARY
NOTTOR

CONSTRUCTION
NGiNEERS, INC. FOR A SPECIFIC PROJECT.

WNG INTO CONSIDERATION THE SPECIFIC
I AND UNIQUE REQUIREMENTS OF THE PROJECT.
tEUSE OFTtilS DRAWING OR ANY !NFORMAT10N;ONTAIN60 IN THIS DRAWING FOR ANY PURPOSE ; PROHIGiTED UNLESS WRtFr^N PERMISSION
iOMBOTM POWER AND POWER'S CUENT IS
3 RANTED.

RAVfN
REV

PRELIMINARY DESIGN

REVISIONS
07/08/2022

DATE DSGN CKD REFERENCE DRAWINGS
DSGNCKD KSASCALE: 1/16" =r-o"
PROJECT:

L?PWH? ^ENGINEERS
2041 South Cobail Point Way. Meridian, ID 33642
POWER ENGINEERS INC.

STELLAR J/RAVEN SR

BASE CASE

SITE LIGHTING PLAN

LOCATION
BFM Al

DRAWING NUMBER
EL-01
877

OVERHEAD

POWER LINES
PLANT

BOUNDARY

FRESH WATER
SUPPLY
yi/OQ EXISTING

REPUBLICSTORAGE
I \
/ /
/ / GRAVEL \- BOUNDAR<AT FENCE
/ I FORASPHACl
/ /
TANK ) / 0

SANITARY
SEWER

FAN K) /
,/-'

PRELIMINARY

NOT FOR

CONSTRUCTION
ENGINEERS, INC. FORASPECtFIC PROJECT.
(]NQ INTO CONSIDERATION THE SPECIFIC
,ND UNIQUE REQUIREMENTS OF THE PROJECT.

REUSE OF THIS DRAWING OR ANY INFORMATION
3NTAINED IN THIS DRAWING FORANY PURPOSE
. PROHIBITED UNLESS WRIHEN PERMISSION
:ROM BOTH POWER AND POWER'S CUENT IS
3RAMTED.

RAVfN

REV REVISIONS
09f2(V2021

DATE APPD REFERENCE DRAWINGS
DRN
CKD
07/08/21
07/09/21
SCALE: NTS
PROJECT:
.POWER
'ENGINEERS
2041 South Coball Point Way, Meridian, ID B3642
POWER ENGINEERS INC.

STELLAR J / RAVEN ONE PROJECT

CEQA PRELIMINARY

UTILIT/ PLAN

LOCATION
RCHCA
REV
A

DRAWING NUMBER
1-00-GA-CEQA-3]
878
COAST LIVE OAK, 40 ft.

Quercus agrifolia
CALIFORNIA BUCKEYE, 20 ft.

Aesculus californica
PINK DAWN CHITALPA, 15 ft.

Chitalpa x tashkentensis ‘Pink Dawn’
TOYON, 12 ft.

Heteromeles arbutifolia
DWARF COYOTE BUSH, 6 ft.

Baccharis pilularis
ROGER’S RED WILD GRAPE, 6 ft.

Vitis x californica ‘Roger’s Red’
JULIA PHELPS CALIFORNIA LILAC, 8 ft.

Ceanothus ‘Julia Phelps’
JUNE GRASS, 3 ft.

Figure 1
Koeleria macrantha
879
f^^.^9 n
^
r^i^ •^ \. \^w ^.Ps^s®;£^--> ^NStefe^
""'"•";.^'/'-i-- '•^:. ..^•^ ~^s

GENERAL LAYOUT

PRBJMINARY
NOTTOR

CONSTRUCTION
I THIS DRAWING WAS PREPARED BY POWERI ENGINEERS, MC. FORA SPECIRC PRCUECT,I TAKING INTO CONSIDERATTON TOE SPECIFICI AND UNIQUE REQUIREMBfTS OF THE PROJECT.[ REUSE OF TMIS DRAWING OR ANY INFORMATIONI CONTAINED IN THIS DRAWING FOR ANY PURPOSEI IS PROHIBHED UNLESS WRTTTEN PEftMtSSIONI FROM BOTH POWERAND POWER'S CUENT ISIGRWTED.

RAVfN STELLAR J
REV

ISSUE FOR PERMITTING

REVISIONS
07/22/2022
DATE
TGC
DRN
TGC
DSGN
HS
CKD
HS

APPD REFERENCE DRAWINGS

DSGNDRNCKD
TGCTGC
HS
07/22/202207/22/2022
SCALE; NTS
FOR 22x34 DWG ONLY
PROJECT: 174550
^ POWER

ENGINEERS
2041 South Cobalt Point Way, Meridian, ID 835+2(208}2BM464:COA:???7? POWER ENGINEERS INC.

STELLAR J / RAVEN ONE PROJECT
RICHMOND CA. PLANT

GENERAL LAYOUT COLOR SCHEME

LOCATION
RCHCA Al

DRAWING NUMBER
1-00-GA-009
880
}S^W-:W^'-
a8 fS' -y ,-'' ./'''.^•^----'' "^
^.Np-T&^j^^ /'^"-y^' ^
u ,/•
.-.—-23-,
^' , 20.7 t

SCATTERED BRUSH
•'/ /
m:
'"/;'•'
DMA 1

1.19 AC

DRAINS TO SUMP PUMP
(TO BE CONNECTED TO;;
EXISTING STORMWATERt

SYSTEM)
j??J
^-^^^.-^-~--"
M \ \.t / &\yLr .''/'
!\Xld
~?^>F^U<RF.I^j
:y/i
iS-'tj /\
HNPERVIOUS AREA: 0.87 ACRES)
|IMPERVIOUS-AREA: 1.10 ACRES)
'IW Yfffl, ^7-'^
SCAHERED-BRUSH l.<-
.,-——12-—'
.^
!->"<%T - // / ^,A^r I/ /&
F/' ^M-
^(!SW///A WV/y'/M
// / /', / /-'/
'//y ^ // ;
//7 / / //h 7
'^
%??
M-
^?S$^
'^- ..•<;7 •'- .s^' F%y -^"
J» My^w-y w/w^ m^^y
L^xy,/
^^//^ /'' /MWW//M l/i
^""^ /' /iSiW'7./w^-'7//' / -•""^Gy'MiW/W \M// . "(/Mwy// IJ/,w -<<y /x5'5 -y?y//iM0/ \/w/////////.//// /
^RUSH/ /,////// .' /.// ' Wf) / ////W/ / /7/ '
\-
2 -/S'/'^' jj'/'w.yy^'
IWiW/-
MM!//?/// /^//MV /;/ ,/ WF^T no lit

STORM DRAINAGE KEYNOTES

PRELIMINARY STORMWATER

CONTROL PLAN EXHIBFT
N: 2180292.77E: 6019006.79FLARED END SECTIONFLOWLINE IN (E): = 9.00' •P 2180282.98
E: 6019006.794'X4'AREAINLETTOP EL =18.00'
<D
):21 ; 2180260.08 TC2180247.98 '^2180253.83 W2180246.60 ^2180241.46 E: 6018995.83 E:6018892.27 E:6018884.88 E:6018823.07 E:6018779.114'X4'AREAINLET 4'X 4'AREA INLET 45 DEGREE BEND 4' X4'AREA INLET 45 DEGREE BEND TOP EL =14.00' TOP EL =13.50' FLOWLINE IN (SE) = 10.47' TOP EL =14.00' FLOWLINE IN (E) = 10.14' ^5RLF11o2."SDIA PERF(:)RATED CHDPE PIPE ^m,WL^E o,w <E),: l5;00^, FLOWLINE IN (NE) =11.00' FLOWLINE OUT (NW) = 10.47' F[6wLINE OU'f(W) =To.47' FLOWLINE IN-(E) = 10.14' FLOWLINE OUT (SW) = 10.14' FLOWLINE OUT (W) =11.00' 9 LF 12" DIA PERFORATED CHDPE PIPE 62 LF 12" DIA PERFORATED CHDPE PIPE FLOWLINE OUT (W) = 10.14' 18 LF 12" DIA PERFORATED CHDPE PIPE25 LF 12" DIA PERFORATED CHDPE PIPE FLOWLINE IN (E) = 10.47' 44 LF 12" DIA PERFORATED CHDPE PIPE 104 LF 12" DIA PERFORATED CHDPE PIPE

GRADING AND DRAINAGE KEYNOTES
1 ) INSTALL TOTAL OF 10 CY OF 8" MEAN DIA RIPRAP 20" DEEP, SEE PLAN FOR DIMENSIONS. SEE SITE DETAILS ON DRAWING1-100C1-500. 2 ) INSTALL STATION ROCK SURFACE. SEE SITE DETAILS ON
DRAWING 1-100-C1-500.
.3^1 RELOCATE EXISTING PUMP. TIE INTO EXISTING PRESSURE PIPE. (4) REMOVE MOUND
rS~) PROTECT EXISTING RISER.

GRADING NOTES

1. ALL CONSTRUCTION SHALL MEET THE STANDARDS AND SPECIFICATIONS OF CONTRA COSTA COUNTY LATEST EDITION.

2. PROVIDE POSITIVE SLOPE DRAINAGE AWAY FROM ALL SITE STRUCTURES AND FOUNDATIONS, CONTRACTOR IS RESPONSIBLE TO GRADE PROJECT TO MAINTAINDRAINAGE. NO WATER SHALL POND.

3. CONTRACTORS SHALL SET CONSTRUCTION STAKING TO VERIFY PROJECT EXTENTS IF PROPERTi' CORNERS HAVE NOT BEEN ESTABLISHED.

4. SITE GRADES SHOWN OUTSIDE OF STATION ROCK AREA ARE FINISH GRADES.

CONTRACTOR SHALL GRADE TO DRAIN.

5. ALL STORM SEWER STRUCTURES INCLUDING CULVERTS, GRATES, FRAMES AND MANHOLES UTILIZED ON-SITE SHALL BE TRAFFIC RATED FOR AASHTO HS-20LOADING.

6. PIPE LENGTHS EXCLUDE END SECTIONS AND ARE MEASURED ALONG CENTERLINE OF PIPE FROM CENTER OF INSIDE FACE TO CENTER OF INSIDE FACE OFSTRUCTURES.

7. EROSION CONTROL STRUCTURES SHALL BE CONSTRUCTED PRIOR TO GRADING ACTIVITIES. SEE 1-00-C1-300 EROSION CONTROL PIAN.

B. NORTHING AND EASTING COORDINATES FOR MANHOLES, AREA INLETS, FIELD INLETS, AND JUNCTION BOXES ARE MEASURED TO CENTER OF STRUCTURE.

9. NORTHING AND EASTING COORDINATES FOR FLARED END SECTIONS ARE MEASURED TO END OF PIPE AT PIPE CENTERLINE. FLOWLINE ELEVATIONS ARE MEASURED AT THE END OF THE FLARED END SECTION.

10. SLOPES SHALL BE MADE AT 3:1 MAXIMUM GRADE (H:V).11. DRAINAGE CHANNELS SHALL BE MINIMUM 3' FLAT BOTTOM AND SHALL HAVE A4:1 SIDE SLOPE.

12. HORIZONTAL DATUM IS NAD83 CALIFORNIA STATE PLANES, ZONE III, US FOOT ESTIMATED QUANTITIES NOTES1. ALL ESTIMATED MATERIAL QUANTITIES ARE IN-PLACE

QUANTITIES AND DO NOT INDICATE ALL MATERIALS REQUIRED
TO COMPLETE CONSTRUCTION. ESTIMATED QUANTITIES DO NOTREFLECT CUT OR FILL FACTORS AND DO NOT TAKE OTHERADJUSTMENTS INTO ACCOUNT. CONTRACTOR SHALL BERESPONSIBLE FOR VERIFYING ALL QUANTITIES AND MATERIALSAS INDICATED ON THE DRAWINGS.

2. REMOVE TOP 8" OF ORGANIC MATERIAL FROM 1.52 ACRES SITE = 1700CUYDS.

3. CUT=60CUYDS.4. FILL = 350 CU YDS.5. COVER PROPOSED FACILITY SITE SURFACE WITH 6" COMPACTED BASE MATERIAL = 170 CU YDS.

6. COVER PROPOSED FACILITi' WITH 4" OF SURFACE ROCK = 120 CU YDS.

7. INSTALL TENSAR INTERAX NX750 ON PREPARED SUBGRAGE OF

PROPOSED ROAD SURFACE PRIOR TO INSTALLATION OF
CRUSHED ROCK = 42,000 SF.

8. COVER PROPOSED ROAD SURFACE WITH 6" COMPACTED BASE
MATERIAL =1350 CUYDS.

LEGEND
37B — EXISTING CONTOUR

EXISTING CHAIN LINK FENCEPROPOSED DRIVE CENTERLINE
-3BO— PROPOSED CONTOUR
•x— PROPOSED CHAIN LINK FENCE

PROPOSED SITE SURFACE
^2180227.23
E:6018767.8645 DEGREE BENDFLARED END SECTIONFLOWLINE 9.83'

PROPOSED ROAD SURFACE
15 30
1"= 30'
JGINEERS, WC. FORASPECIFtC PROJECT,

WING INTO CONSIDERATION THE SPECIFIC
^D UNIQUE REQUIREMENTS OF THE PROJECT.:LJSEOF THIS DRAWING OR ANY INFORMATION ONTAiNED IN THIS DRAWING FOR ANY PURPOSEi PROHBFTED UNLESS WRITTEN PERMISSIONWM BOTH POWER AND POWER'S CLIENT IS RANTED.

RAV?N

ISSUED FOR REVIEW

REVISIONS
07-08-22 APG BHR
CKD
BHR

APPD REFERENCE DRAWINGS
DSGN
07/08/22
SCALE: AS NOTED
PROJECT: 174550
.POWER'ENGINEERS
2041 South Cobalt Point Way, Meridian, [D 83642
POWER ENGINEERS INC.

STELLAR J/RAVEN SR

PRELIMINARY STORMWATER

CONTROL PLAN EXHIBFT

LOCATION
RCHCA
REV
A

DRAWING NUMBER
1-00-C1-100
881
LOT 22

RICHMOND OTY LIMITS
CITY OF IBICHMOND \
nm-se'frv

CITY OF RICHMOND
RICHMOND QT(r UMITS

UNINCORPORATED AREA OF

CONTRA COSTA COUNH

LANOS OF
WEST COUNTf LANDFILL, U.C.

AFH; WS-Htl-013-9

AREA SHOWN AS
PARCEL 1262A ON ffil)
UNINCORPORATED ]AREA OF

CONTRA COSTA COUNTY
\Y
_\
EXC. 6, ROADWAY * UTaiTiES ESUT PARCEL WE, 1158 QA 205
\'&

SC'SS'STE

PARCEL SEVEN (PTS)
'ARCEL XI262.1B
WhD EASEHQfT
[THERE [S HO RECORD mroRMWTQN ^^
N25S'57"|P \'
312.02'
BASIS OF BEABINGSTHE BASS OF BEARINGS OF THiS SURVEY IS TAKEN BEfflEEN FOUNDS1RECT MCNUUEHT AT THE INTERSECTION Of HTT5BURG AVENUE ANDRICHKOND PARKWAY AND THE FOUND STREET UONUUENT AT THEIKTERSECHGN CF FRED JACKSON WAY (FQRUERLY 3RD STREET} AND PARKBOULEVAfiO AS StiOHW ON THAT CERTAIN UAP ENTIHID "SAN PABLOCREEK, PHASE 1. TOIRD ST. VEST TCI S? PA8LO BAT. RIGHT CF INAf BYCONTRA COSTA COUNTY PUBUC WORKS DEPARTUEOT, UARHNEZ,CAUFORMA, DRAHHNG NO. ED-723 THROUGfi ED-727, DATED FEBRUARY. 1984, TAKEN AS NORTH W03W EAST.

REFERENCES(R1) •SAN PABLD CPEK, PHASE 1, THIRD ST. HEST TO SAN PABLOBAY. RIGHT OF WATf" BY CCNreA COSTA COUNTY PUBLIC WORKSDEPARTMENT, KARTDCZ, CAUFCRNIA, DRAWKG HO. ED-723 TtiROUSSED-727, DATED FEBRUARY. 1984.(R2) "SAN PABLO CREDt. PHASE 1, ffi!RD ST. VEST TO SAN PABLOBAY, RGHT OF WAV BY COK1RA COSTA COUKTT PiJBUC WRKSDEPARTMENT. UAST1NEZ, CAUFCRNIA, DRAWNS NO. ED-727.1 TOED-72a,1,:OA7ED JUNE, 1986,(R3) RECOfiO Of SURVEY, HL£D APRIL 14, 1992 IN BOOK 100 OFLJCENSED SURVEWR'S MAPS, AT PAGE 37, IN THE CFFICE OF THECOUNTT RECORDER OF CONTRA COSTA COUNTY. STATE OF UUFOBNiA.(R4) RECORD OF SURREY, RS Na 3553, FU£D DECEMBER 12, 2012 INBOOK 146 OF UCEKSEB SURVEYOR'S MAPS, AT PAGE 35, IN THE CFFICECF THE COUNPf RECORDER OF CONTRA COSTA COUNTf, STATE OFCAUFDRNIA.(R5) RECORD OF SURVEY FlLfB DECOIBER 24, 19S1 M SOOK S9 CF LICENSED SJRVEYOirs U?S. AT PAGE 33, W THE OFFICE OF THECQUNTT RECORDER OF CONTRA COSTA COUNTT. STATE CF CAUFDRNtA. (R6) GRANT DEED RECORDED QECEMBER 29,1989 AS DOCSJMENT HUUBER 89-2632E5, OmQAL RECORDS OF CONTRA COSTA COUNTY, STATE OF CUffDRNIA.(R7) GRANT DEED RECORDED FEBRUARY 11, 1992 AS DOCUMDITNUMBER 92-29460, OFFICIAL RECORDS OF CONTRA COSTA COUNTY,STATE OF CMJFWNIA,

C SHOWN ON

PARCEL MAP BUT
THESE !S NO t£(3AL OESCRiFTON
°/<€. \^ ^/ '^ pwca. SEVEN (pm)
.PARCEL X12G2.1A-1

ACCESS ROAD EASEMENT
/': /
";*-><\ / /1/
RICHMOND CH-Y UM)T5

CITY OF RICHMOND

LANDS OF
WEST COUNTY IANDRH, LLC.

APN: 4(!a-140-0as-7
J X^/ psi %) '^
THERE IS NO LEGAL GESCRIPT10N

LANDS OF
WEST COLlHPr UHDfllL, LLC.

APH: 4t)8-H 4t)8-H
(SEE NOTE 2)

LANDS OF
WEST COUNTY WA51EWATER DISTRICT
AFK: +08-150-00+

UHDS OF
WEST COUNFf WASTEWATCR aSTRICT
APN: 408-150-008

LANDS CF
WEST CDUKn' WASTEWMER BS7H1CT
APN; 40a-l50-005 UNINCORPORATED AREA OF

CONTRA COSTA COUNTY
RICHMOND CfTY UMITS
UNE
-^-M.

M.

EUWG
535W5TE
swssr^,
Ts.^'?fnl
'^^1

EXSTANCE
s.w
ir'SSniro5CL77
CITY OF RICHMOND aOWBMKf OF SUBJECT nKFERTT
RKHTCFfHYUCIfflEiBORPnOPERIYUNE
UCfUOfTiUC
TEUNEOLD LOT U?asaon-uNE
® fWM SIBEET UONUCTT AS fflOD
CCTCklC) CanW COSTA COUNTY FLOCOCMTfiOL

I WATER CONSERVAHW BSIRET
.-..-..J..-.._
•I-'
EStfT
DOC.KO. DCCUUBfrHUBER
R/K ISBtT OF WY

CFRCUL RECORDS
f.ssnsf) REOBD vtsrwcE
(R!) REFEIBKEEXC. TITLEEMZPnoN
CBHEfaNECUSIATH)
CRCBCTWE:OBXJW DCTAHCE
UONWOfT TO MCIMCTT
SAROffORANDHDTRXIO
NOTES
BASED W WE CURRENT ASSESSOR'S PARCEL MAP, APNW&-HO-01&-5 IS AU. LTfTNG WTHIN PARCEL ONE. THERE IS NOLEGAL DESCBPT10W FCfi APK 40B-HO-010-5. 2} BASED ON THE CURRENT ASSESSOR'S PARCEL UAP. fPH
<08-H(i-OOB-9 iS AUL LUNG mffl PASCEL CNE, PARCB TW,ASD PARCB THtEE, THESE IS NO LEGAL DESCBPTON FOR APH40a-t40-008-9.

DATE OF FIELD SURVEYMARCH 9, APRIL 20, MAY 11 AND 25, 2022 AS TO THEBOUNDARY AND TOPOGRAPNC SSTSf OF THE SUBJECTPROPERTf.

SUEVEYOR'S STATEMENT
^ TOPOGRAPfflC & BOUNDARY SURVEY OF

RAVM ONE

CITY OF RICHMOND, CONTRA COSTA COUNTT, CALIFORNIA
JULY 2022

PREPARES BY

LUK AND ASSOCIATES

CIVIL ENGINEER - LAND PLANNERS - LAND SURVEYORS
738 ALFRED NOBEL DRIVE
HERCULES, .CAUFORNIA 94547
(510) 724-33SS
882
..-..-..-..-..-//_. U./_i._
-IEGENB
BOUKDWr Of SUBJECT PBd>E«Tr
RIGHT OF WAY UH£INTERIOR PROPERTC I^E

MONUMENT UNE

CITY UMFT UNE
EUHStHG WE«*1E» BTCN U»E

SANFTARY SEWR UNE
STORM DRAIN UNEMEPHOfffi UW

SWAL UNE

OTOHBU UNE
B£CTRfCUHESTREET UGHT UNE
^ PAMENT ASPIUU CONraETE PAWUfflT
;as» ia™i?~E^C ELECTRIC SC«
UT VAULT UT1UTC VAULT
cs CATCH BASIS
Fti PRE HWRANT
{... janr P(X£ a" euy WE ^SDSP STORM DRAIN SUUP PUMP
SFP BACKFLOW PREV&i'TiK*

VECETATON/GROUND UNE
WALL>AIER CUUE8T
PIPE

TOPOGRAPHIC & BOUNDARY SUEVEY

HAVEN ONE
an OF RICHMOND. CONTRA COSTA COUNTY, CAUFORNIA
TOLY ZOZZ" '"""'
HeRCUL£S._^AUFORNIA"945'47
71 883
MATCHUMS SEE SBffiT 1
I

GRAPHIC SCALE
LEGEND

INTCSIOR PROPERTT UNEMONUMENT UNECITY UMFT UNE
aUILDING ISiE
WATER DiTCH UNESANITARY SCTER UNE

STORM DRAIN UNETHS'HONE UNESGMAL UNEOVERHEAD LINE
E1ECTOIC UNESTREET UGHT UNE
AC PAVEMENT ASPHALT CONCRETE PAVEMENT53MH SANITARY SEWER MANHOLEUT BOX UTILITY 90X EL£C ELECTRIC BOX
UT VAULT UT1UTT VAULT
CS CATCH aASN
FH FIRE HVDRANTJP JOINT POLEGUY SUY W!RE

SQSP STORM DRAIN SUMP PUMP
BFP BACKFLOW PRBdTER
VECCTA-nON/GROUND UNE

WATER CULVERT
PIPE
TOPOGRAPfflC & BOUNDARY SURVEY
BA™ ONE
an OF RICHMOND, CONTRA COSTA COUNTY, CAUFORNIA
JULY 2022

PREPARED SY

LUK AND ASSOCIATES

CIVIL ENGINEER - LAND PLANNERS - LAND SURVEYORS
738 ALFRED NOBEL DRIVE
HERCULES. .CAUFORNIA 94547
(51 d) 724-33SB
F: VfCGS\FIL£20ZZ\Z20GIA10\TOPOaORY-2ZOei Al 0
884
ft' / PROPERH
/ LINE
LEGEND

BENCHMARK
BM DEB480, BBNG A SUR?Y DISK LOCATED ABOUT 25 Ml {4.0 KU) NORTH OF RICHUONO JUD ABOUT 0.5 Ml (0.8 KM} NORffi OF SAN PABLQ ON THE PRQPERTT OFCONTRA COSTA COLLEGE, U U (27.6 FT) WEST OF THE CEN7ERLBC OF THESOUTHBOUND LANE OF THE TRAFFiC CKdf, +.6 U (15.1 n) WEST OF THE W51FACEOF THE CONCRETE OCT MID 11 M (1CL2 FT) EAST OF A CHAIN UNK FENCE, SET 9iSK AN B iH PVC PIPE W7H CAP WO ABOUT &i5 M BELOW THE TOP OF TtiE WE.

ElfVATCTf = 515 FEET, NORTH AUEBCAN VERTICAL SATUU 1988 (HAVD 88).

DATE OF FIELD SURVEY
MARCH 9 AND APRL 20, 2022

SURVEYOR'S STATEMENT
THE UAP CORRECTLY REPRESENTS A SURVEY UADE BY »E OR UNDER UY DiRECDON INCCNFWUtiiCE Wti THE SEQU!REMENT5 OF THE CAUFCRNiA LAND SURVETORS' ACT IN

GRAPHIC SCALE
J^<.. JACQUEUNE UK PJLSL 8934

FOR UUK A ASSOQATES, IHCL
AC PAYMENT55MH
UT90XB£CUT VAULTCBFti-JPGUY

SDSPBFP
aOUNDASY OF SUBJECT PROPERTYRIGHT OF WAY LIKEINTERIOR PROPERTY UMEMONUMENT UNEOTY UMtT UN£ BUfLDING LINEWATER DITCH UNESANITARY SEWR UNESTORM DRAIN LIKE TB£PHONE UNE

SIGNAL UNE
OVERHEAD UtiEEL£CTR!C UNESTREET LIGHT UNEASPHALT CONCRETE PAVEMENTSANITARY SEWER MANHOLEU'nUTY BOXELECTRIC SOXUTtUTY VAULTCATCH BASINFIRE HYDRANTJOINT POLEGUYWRESTORM DRAIN SUMP PUMPSACKFLOW PREVEhTERVEGCTATtON/GROUND WE

WALLWATER CULVERT
TOPOGRAPHIC &; BOUNDAEY SURVEY
RAVEN ON;
CITr OF RICHMOND, CON7KA COSTA COUNTT. CAUFORNIA
JULY 3022

PREPARED BY

LUK AND ASSOCIATES

CIVIL ENGINEER - LAND PLANNERS - LAND SURVEYORS
738 ALFRED NOBEL DRIVE
HERCULES, .CAUFORNIA 94547
[510) 724-33ES
F: VOBS\F]I£ZOZ2\22Q61 A10\TOPOBORY-2Z061 AIQ
885
u ,-"
'SSST-TBSO'Eigj;
iTORM DRAINAGE KEYNOTES <L>
K1180241.46
NT21S0292.77 E;6°19°°6.re,,^ E: 6018995.83 E:6018892.27 E:6oT8884.88 E:601'8823.07 E:6018779.11E:6019006.79 'LA4_ftKtH "lLtl' 4'X4'AREA INLET 4'X 4'AREA INLET 45 DEGREE BEND 4'X 4'AREA INLET 45 DEGREE BENDFLAREDENDSECTI°N. I,OF',E,L,^18'W^>_^^, TOP EL =14.00' TOP EL =13.50' FLOWLINE IN (SE)= 10.47' TOP EL =14.00 FLOWLINE IN (E)= 10.14' FLOWLINE IN (E): = 9.00' ^L^".",LI^C w^ !^ i3;w», FLOWLINE IN (NE) = 11.00' FLOWLINE OUT (NW) = 10.47' FLOWLINE OUT (W) = 10.47' FLOWLINE IN (E) = 10.14' FLOWLINE OUT (SW) = 10.14'85LM2-DIA PERFORATED CHDPE PIPE FLOWLINE OUT (SW) = 15.00' FLOWLINE OUT (W) = 11.00' 9 LF 12" DIA PERFORATED CHDPE PIPE 62LM2-DIAPERFORATED CHDPE PIPE FLOwCiNi 6uf'(W)'='10.14' 18 LF 12" DIA PERFO'RATED CHDPE PIPE @8-11%SL 25 LF 12" DIA PERFORATED CHDPE PIPE FLOWLINE IN (E) = 10.47' "- ---••-"-•-••—-—--•"- 44LF.|2"DIA-PERF'ORATEDCHDPEPIPE 104 LF 12" DIA PERFORATED CHDPE PIPE
1:2180227.23
E:6018767.8645 DEGREE BENDFLARED END SECTION
FLOWLINE 9.83'
I

GRADING AND DRAINAGE KEYNOTES
1 ) INSTALL TOTAL OF 10 CY OF 8" MEAN DIA RIPRAP 20" DEEP, SEE PLAN FOR DIMENSIONS. SEE SITE DETAILS ON DRAWING1-100C1-500. (z) INSTALL STATION ROCK SURFACE. SEE SITE DETAILS ON
DRAWING 1-100-C1-500.

JL) RELOCATE EXISTING PUMP, TIE INTO EXISTING PRESSURE PIPE. (4) REMOVE MOUND
'S'} PROTECT EXISTING RISER.

GRADING NOTES

1. ALL CONSTRUCTION SHALL MEET THE STANDARDS AND SPECIFICATIONS OF CONTRA COSTA COUNFi' LATEST EDITION.

2. PROVIDE POSITIVE SLOPE DRAINAGE AWAY FROM ALL SITE STRUCTURES AND FOUNDATIONS, CONTRACTOR IS RESPONSIBLE TO GRADE PROJECT TO MAINTAINDRAINAGE, NO WATER SHALL POND.

3. CONTRACTORS SHALL SET CONSTRUCTION STAKING TO VERIFY PROJECT EXTENTS IF PROPERPl' CORNERS HAVE NOT BEEN ESTABLISHED.

4. SITE GRADES SHOWN OUTSIDE OF STATION ROCK AREA ARE FINISH GRADES.

CONTRACTOR SHALL GRADE TO DRAIN.

5. ALL STORM SEWER STRUCTURES INCLUDING CULVERTS, GRATES, FRAMES AND MANHOLES UTILIZED ON-SITE SHALL BE TRAFFIC RATED FOR AASHTO HS-20LOADING.

6. PIPE LENGTHS EXCLUDE END SECTIONS AND ARE MEASURED ALONG CENTERLINE OF PIPE FROM CENTER OF INSIDE FACE TO CENTER OF INSIDE FACE OFSTRUCTURES.

7. EROSION CONTROL STRUCTURES SHALL BE CONSTRUCTED PRIOR TO GRADING ACTIVITIES. SEE 1-00-C1-300 EROSION CONTROL PLAN.

8. NORTHING AND EASTING COORDINATES FOR MANHOLES, AREA INLETS, FIELD INLETS, AND JUNCTION BOXES ARE MEASURED TO CENTER OF STRUCTURE.

9. NORTHING AND EASTING COORDINATES FOR FLARED END SECTIONS ARE MEASURED TO END OF PIPE AT PIPE CENTERLINE. FLOWLINE ELEVATIONS ARE MEASURED AT THE END OF THE FLARED END SECTION.

10. SLOPES SHALL BE MADE AT 3:1 MAXIMUM GRADE (H:V).

11. DRAINAGE CHANNELS SHALL BE MINIMUM 3' FLAT BOTTOM AND SHALL HAVE A 4:1 SIDE SLOPE.

ESTIMATED QUANTITIES NOTES1. ALL ESTIMATED MATERIAL QUANTITIES ARE IN-PLACE

QUANTITIES AND DO NOT INDICATE ALL MATERIALS REQUIRED
TO COMPLETE CONSTRUCTION. ESTIMATED QUANTITIES DO NOT
REFLECT CUT OR FILL FACTORS AND DO NOT TAKE OTHERADJUSTMENTS INTO ACCOUNT. CONTRACTOR SHALL BERESPONSIBLE FOR VERIFYING ALL QUANTITIES AND MATERIALS AS INDICATED ON THE DRAWINGS.

2. REMOVE TOP 8" OF ORGANIC MATERIAL FROM 1.52 ACRES SITE = 1700CUYDS.

3. CUT=60CUYDS.4. FILL = 350 CU YDS.

5. COVER PROPOSED FACILITl' SITE SURFACE WITH 6" COMPACTED BASE MATERIAL = 170 CU YDS.

6. COVER PROPOSED FACIUFi' WITH 4" OF SURFACE ROCK = 120 CU YDS.

7. INSTALL TENSAR INTERAX NX750 ON PREPARED SUBGRAGE OF PROPOSED ROAD SURFACE PRIOR TO INSTALLATION OFCRUSHED ROCK = 42,000 SF.

8. COVER PROPOSED ROAD SURFACE WITH 6" COMPACTED BASE
MATERIAL =1350 CUYDS.

LEGEND
— 378 — EXISTING CONTOUR

EXISTING CHAIN LINK FENCEPROPOSED DRIVE CENTERLINE
-380— PROPOSED CONTOUR
•x— PROPOSED CHAIN LINK FENCE

PROPOSED SITE SURFACE

PROPOSED ROAD SURFACE
;NG1NEERS, INC. FORASPECIFIC PROJECT.

AKING INTO CONSIDERATION THE SPECIFIC
ND UNIQUE REQUIREMEMTS OF THE PROJECT.
iEUSE OF THIS DRAWING OR ANY INFORMATION;ONTA)NED IN THIS DRAWING FOR ANY PURPOSE ; PROHIBITED UNLESS WRITTEN PERMISSION
tOM BOTH POWERAND POWER'S CLIENT IS
.RANTED.

RAVfN STEU-AR^

ISSUED FOR REVIEW

REVISIONS
07-08-22
DATE
APG

DSGN APPD REFERENCE DRAWINGS
DSGN
DRNCKD
BRGBHR
04/28/2207/08/22
SCALE: AS NOTED
PROJECT: 174550
.POWER
Vw ENGINEERS
2041 South Cobalt Point Way, Meridian, ID 83642
POWER ENGINEERS INC.

STELLAR J/RAVEN SR

SITE GRADING PLAN

LOCATION
RCHCA
REV
A

DRAWING NUMBER
1-00-C1-100
886
Raven SR Bioenergy Project i ESA / D202100382
Updated Initial Study March 9, 2023

TABLE OF CONTENTS
Raven SR Bioenergy Project
Updated Initial Study / Mitigated Negative
Declaration
Page

1. General Project Information and Overview .................................................................. 1

1.1 Project Title .............................................................................................................. 1

1.2 Lead Agency Name and Address ............................................................................ 1

1.3 Project Case File Number........................................................................................ 1

1.4 Contact Person and Phone Number........................................................................ 1

1.5 Project Location ....................................................................................................... 1

1.6 Project Applicant’s Name and Address ................................................................... 2

1.7 Existing General Plan and Zoning Designation....................................................... 2

1.8 Purpose and Intended Use of this Document ......................................................... 2

1.9 Project Overview ...................................................................................................... 8

1.10 Environmental Setting.............................................................................................. 8

1.11 Required Discretionary Approvals ........................................................................... 9

1.12 Other Public Agencies Whose Approval is Required .............................................. 9

1.13 California Native American Tribes Consultation...................................................... 9

2. Project Description........................................................................................................ 10

2.1 Project Purpose...................................................................................................... 10

2.2 Existing Site Conditions and Ownership................................................................ 12

2.3 Surrounding Uses and Conditions ......................................................................... 12

2.4 Site Plan and Structures ........................................................................................ 16

2.5 Technology............................................................................................................. 21

2.6 Operations.............................................................................................................. 24

2.7 Employment ........................................................................................................... 31

2.8 Transportation and Circulation............................................................................... 31

2.9 Construction, Site Coverage and Drainage ........................................................... 31

2.10 Off-site Improvements: Landscaping..................................................................... 32

3. Environmental Factors Potentially Affected .............................................................. 33

4. Environmental Checklist and Analysis....................................................................... 35

4.1 Aesthetics............................................................................................................... 35

4.2 Agriculture and Forestry Resources ...................................................................... 41

4.3 Air Quality............................................................................................................... 45

4.4 Biological Resources.............................................................................................. 60

4.5 Cultural Resources................................................................................................. 71

4.6 Energy .................................................................................................................... 75

4.7 Geology, Soils and Mineral Resources.................................................................. 79

4.8 Greenhouse Gas Emissions .................................................................................. 82

4.9 Hazards and Hazardous Materials......................................................................... 95 887
Table of Contents
Raven SR Bioenergy Project ii ESA / D202100382
Updated Initial Study MND March 9, 2023

4.10 Hydrology and Water Quality............................................................................... 103

4.11 Land Use and Planning........................................................................................ 109

4.12 Noise and Vibration.............................................................................................. 111

4.13 Population and Housing....................................................................................... 117

4.14 Public Services and Recreation........................................................................... 119

4.15 Transportation ...................................................................................................... 121

4.16 Tribal Cultural Resources..................................................................................... 127

4.17 Utilities and Service Systems............................................................................... 129

4.18 Wildfire ................................................................................................................. 133

4.19 Mandatory Findings of Significance..................................................................... 135

5. Document Preparers ................................................................................................... 139 List of Figures
1-1 Regional Context ....................................................................................................... 4 1-2 Local Context – North Richmond .............................................................................. 5 1-3 Project Site and Surrounding Landfill Context .......................................................... 6 2-0 Birdseye View of Project Site .................................................................................. 14 2-1 Project Site and Raven SR Facility Areas............................................................... 15 2-2 Simulated 3D Site Development.............................................................................. 17 2-3a South Elevation (West End) .................................................................................... 18 2-3b South Elevation (East End) ..................................................................................... 19 2-4 Detailed Site Layout and Raven SR Facility Plan ................................................... 20 2-5 Raven SR Process Diagram ................................................................................... 22

4.1-1 Wildcat Marsh Trail Approach Toward Project Site (from East) ............................. 37

4.1-2 Onsite View toward Project Site ............................................................................. 39 List of Tables

4.3-1 Average Daily Construction-related Criteria Pollutant Emissions (pounds per day) Without Mitigation................................................................................... 47

4.3-2 Process OperationsAir Permit Application's Average Annual Operational Criteria Pollutant Emissions (tons per year)......................................................... 48

4.3-3 Auxiliary OperationsCalEEMod Average Daily Operational-Related Criteria Pollutant Emissions (poundstons per day).............................................. 49

4.3-4 Average Annual Operational-Related Criteria Pollutant Emissions (tons per year) ............................................................................................................... 49

4.3-5 Average Daily Operational-Related Criteria Pollutant Emissions (pounds per day)................................................................................................................. 50

4.3-6 Health Risk Impacts at the Maximum Exposed Sensitive Receptors).................... 53

4.3-7 Cumulative Health Risk Impacts at the Maximum Exposed Sensitive Receptors) ............................................................................................................ 56

4.8-1 BAAQMD GHG Thresholds of Significance ............................................................ 85

4.8-2 Annual Construction-Related Greenhouse Gas Emissions .................................... 86

4.8-3 Unmitigated Annual Operational Greenhouse Gas Emissions .............................. 88

4.12-1 Localized Roadway Traffic Noise .......................................................................... 108

4.12-2 Construction Equipment Noise Levels .................................................................. 109

4.12-3 Reference Noise Levels for Stationary Noise Sources Associated with the Proposed Project.......................................................................................... 111

4.15-1 Project Daily Trip Generation Summary................................................................ 118

4.15-2 Project VMT Summary........................................................................................... 120 888

1. General Project Information
Raven SR Bioenergy Project iii ESA / D202100382
Updated Initial Study MND March 9, 2023
Appendix
A Emissions Data, Assumptions and Modeling Files ................................................A-1 A.1-1 Original Emissions Data, Assumptions and Modeling Files...............A.1-1 A.2-1 Updated Air Quality and Greenhouse Gas Assessment Technical Memo ..............................................................................A.2-1 A.2-2 Updated Air Quality and New Health Risk Assessment Technical Memo ..............................................................................A.2-2 B Special Status Species Lists .................................................................................B-1 C Updated Draft Mitigation Monitoring and Reporting Program (MMRP) ................ C-1 D Response to Comments Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration (November, 11, 2022)............... D-1 889

1. General Project Information
Raven SR Bioenergy Project 1 ESA / D202100382
Updated Initial Study MND March 9, 2023

1. General Project Information

1.1 Project Title
Raven SR Bioenergy Project

1.2 Lead Agency Name and Address
City of Richmond (City)
Community Development Department
450 Civic Center Plaza
PO Box 4046
Richmond, CA 94804-1630

1.3 Project Case File Number
City Project Case Number: PLN21-282

1.4 Contact Person and Phone Number
Lina Velasco, Director of Community Development
Community Development Department
[email protected]
(510) 620-6841

1.5 Project Location
1 Parr Boulevard, Richmond, California (generally).

The proposed Raven SR Project location is within the West Contra Costa Sanitary Landfill (WCCSL) facility located in the northwest area of the City of Richmond, in Contra Costa County, California. For purpose of this environmental document, the project would occur within approximately 2.5 acres of the existing Republic Services Bulk Materials Processing Center (BMPC) within “Area A” of the WCCSL.
1,2 The property is located approximately 0.25 miles
west of Parr Boulevard (approximately 0.25 miles west from Richmond Parkway) via an unpaved access road. The northern boundary of the project site is the City of Richmond / Contra Costa County jurisdiction line; the project site is located wholly within the City of Richmond, except for use of an existing access/egress road located within the County. The project site is located within Assessor’s Parcel Number (APN) 408-140-009.
1 Actual project operations will occur on a subset area of approximately 1.3 acres that Raven SR will lease from BMPC.
2 “Area A” of the WCCSL is approximately 12 acres in the upland portion of the property that encompasses pollution control facilities and stockpile areas (separate from the closed Class I and active Class II landfill areas, the runoff ponds or lagoons delineated as “Area B”, and tidal waters delineated as “Area C”). Shown in Figure 3-1, Vicinity Map, of the Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions, June 2004. SCH. 2002102057. 890

1. General Project Information
Raven SR Bioenergy Project 2 ESA / D202100382
Updated Initial Study MND March 9, 2023
See Figure 1-1, Regional Context; Figure 1-2, Local Context – North Richmond; and Figure 1-3, Project Site and Surrounding Landfill Setting, on the following pages.

1.6 Project Applicant’s Name and Address
Raven SR S1, LLC 3
Matt W. Murdock CEO
PO Box 1360
Pinedale, WY 82941

1.7 Existing General Plan and Zoning Designations
The project site and surrounding area is located within the Richmond’s “Open Space” General Plan land use designation and Richmond’s “Open Space” zoning district.

1.8 Purpose and Intended Use of this Document
The purpose of this Draft Initial Study/Mitigated Negative Declaration (IS/MND) is to identify any potential environmental impacts that would result from implementation of the proposed project pursuant to California Environmental Quality Act (CEQA) Guidelines. As the project site is wholly located within the City limits, the City of Richmond has discretionary authority over the proposed project and is the lead agency in the preparation of this Draft IS/MND. The intended use of this document is to disclose the potential environmental impacts and mitigation measures, if any, and to provide the basis for input from public agencies, organizations, and interested members of the public.

Extensive prior CEQA analyses have been conducted for the WCCSL site over the last three decades. Solid waste disposal operations at the WCCSL began in 1952, prior to implementation of CEQA. Over the years, operational changes have occurred as new regulations, permits, and recycling operations have been implemented. Currently, solid waste management facilities at the WCCSL include a closed Class II municipal solid waste landfill, a Waste Shuttle Facility, and the BMPC. The BMPC was originally analyzed under CEQA in the early 1990’s. The City of Richmond issued a conditional use permit (CUP), and Contra Costa County issued a Land Use Permit (LUP) for the facility. In the early 2000s, in response to Republic Services’ request, the City and County approved amendments to the use permits to allow expanded and additional waste streams for the BMPC. An EIR was prepared and certified by Contra Costa County in 2004 to address the additional and expanded waste streams.4
This CEQA document is a stand-alone analysis for the proposed Raven SR project. Where appropriate and suitable, setting and context information from prior CEQA documents certified for the WCCSL/BMPC facility and operations is used in parts of this Draft IS/MND to describe 3 The Pproject Aapplicant is referred to throughout as “Raven SR”. “Raven SR” also refers to the multi-patented process/system. “Raven” refers to the proposed facility. 4 Environmental Impact Report for the WCCSL Bulk Materials Processing Center and Related Actions, State Clearinghouse No. 2002102057, June 2004.
891

1. General Project Information
Raven SR Bioenergy Project 3 ESA / D202100382
Updated Initial Study MND March 9, 2023
the existing setting and baseline conditions, given that the project site is located within the WCCSL/BMPC facility.5 However, no part of the proposed project affects existing WCCSL/BMPC operations; the proposed development and Raven SR system is a wholly independent utility, except that it would use feedstock available from the current onsite composting facility referred to as the West Contra Costa Sanitary Landfill Organic Materials Processing Facility (OMPF)BMPC operation. Mitigation measures identified in this document will apply solely to the proposed project and do not conflict with any applicable mitigation measures identified in the previously certified WCCSL/BMPC CEQA documents. Similarly, and addressed separately from this CEQA document, the proposed project requires approval of a City of Richmond Conditional Use Permit (see Section 1.11, below), which is wholly independent from the existing City Conditional Use Permit (CU 1101132 as amended) and Contra Costa County Land Use Permit (LUP 2054-92 as amended) for the WCCSL/BMPC, as well as any existing permits, control
5 Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions, June 2004; and Addendum to the Final EIR for the WCCSL BMPC and Related Actions, 2009.

SCH. 2002102057.
892
Figure 1-1
Regional Context
SOURCE: Raven LLC, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator r ESA
~ 893
Figure 1-2
Local Context - North Richmond
SOURCE: Raven LLC, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator r ESA
~ 894
Raven SR
Facility Location
WCCSL Organics Materials
Processing Facility (OMPF)
West Entrance & Scale Plaza
Parr Blvd
Wildcat Marsh Trail
Golden Bear Transfer Station
West County
Water District
Treatment Plant
WCCSL Organics Materials
Processing Facility (OMPF)
West Entrance & Scale Plaza
Parr Blvd
Wildcat Marsh Trail
Raven SR
Facility Location
Contra Costa County
City of Richmond
Golden Bear Transfer Station
West County
Water District
Treatment Plant
Figure 1-3
Project Site and Surrounding Landll Context
SOURCE: Raven LLC, 2022; ESA, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator Wildcat Creek Marsh Closed Class I Disposal Site Bay Trail / Levee Waste Recycling Facility Stormwater Leachate Trailhead/ Parking Lot
Basin Pond Golden Bear
895

1. General Project Information
Raven SR Bioenergy Project 7 ESA / D202100382
Updated Initial Study MND March 9, 2023
measures or cooperative agreements executed by various regulatory agencies that have permitting authority for the WCCSL/BMPC.

On October 7, 2022, the City as lead agency released for public review the draft IS/MND pursuant to requirements of CEQA. The original public review and comment period on the IS/MND was October 7, 2022, through November 7, 2022. However, the City extended the comment period to November 22, 2022, to allow for additional opportunity for public review.

Approximately 19 written comments were received during this period. Although not required by CEQA, the City the responded in writing to all written comments received on the IS/MND during the public review period. The City’s Response to Comments memorandum is included as Appendix D to this document. The project was then presented to the City’s Planning Commission, which held a public hearing on December 15, 2022, to consider approval of the project by approval of the IS/MND and Mitigation Monitoring and Reporting Program (MMRP) and Design Review and Conditional Use Permit, which would allow the project to construct and operate a bioenergy facility that converts food and green waste into transportation-grade hydrogen for various renewable energy products (PLN21-282). After consideration of all evidence before it, including public comment, both written and oral, the Planning Commission then approved the project. The approval was then appealed.

Given the comments provided during the hearing and in the written appeal, it appeared that there were still questions and concerns from the public and the appellants regarding aspects of the proposed project. It became evident that the public would benefit from additional information added to the IS/MND that would clarify, amplify, or otherwise more fully explain the information in the original IS/MND. For example, additional description of a greater number of proposed operational details was requested. Additionally, although not required as the initial significance thresholds had not been met, the City required a preparation of a health risk assessment (HRA) and further assessment of the project impacts on air quality and greenhouse gas (see Appendix A to this document). This information, including clarification of operations and that the project would result in better health outcomes and reduced impacts to air quality, etc., as compared to current operations and landfill flare emissions at the site, has been incorporated into this updated IS/MND. This updated IS/MND has highlighted these refinements by noting them in either as deletions in “strike through” and additions in “double underline” (such as this sentence) to facilitate review.

Given that the new information added to the updated IS/MND merely clarifies, amplifies, or otherwise makes insignificant modifications to the original IS/MND, recirculation of the document is not required by CEQA. Regardless, to ensure greater transparency and to make additional clarifying information available to the public, the City has again recirculated this (now updated) IS/MND for public comment. It is anticipated that this updated IS/MND and the comments received during review, will be considered by the City Council during its consideration of the appeal from the decision of the Planning Commission.

The remainder of this Section 1 provides an overview of the project’s primary characteristics and its environmental setting and required discretionary approvals. Section 2 describes the project in more detail, Section 3 is the draft environmental declaration, and Section 4 is the environmental 896

1. General Project Information
Raven SR Bioenergy Project 8 ESA / D202100382
Updated Initial Study MND March 9, 2023
checklist that evaluates the potential environmental impacts that may result from construction or operation of the proposed project. Section 5 contains the List of Preparers.

1.9 Project Overview
The Raven SR Bioenergy Project (project) proposes to construct and operate a bioenergy system composed of the Raven SR multi-patented Steam/CO2 Reformation process at the project site.6 The non-combustion Raven SR process would convert blended green waste and food waste, obtained from the existing onsite OMPF composting BMPC operation adjacent tolocated approximately 1,100 feet west of the project site, into renewable, low-carbon, transportation grade hydrogen. The low-carbon hydrogen produced from renewable feedstock would be for offsite use in trucks and other heavy-duty applications in lieu of petroleum-based diesel. to the project will reduce emissions of criteria pollutants and produce low-carbon hydrogen to reduce greenhouse gas (GHG) emissions from transportation and other hard-to-abate sources. The produced hydrogen that would be exported offsite for various renewable energy products. No long-term hydrogen storage would occur onsite.

The Raven SR process would reduce existing flaring of landfill gas (LFG, gas produced from the decomposition of organic solid wastes in the landfill to generate power. Raven intends to produce the hydrogen through a process that uses less power consumption per kilogram of hydrogen produced than conventional electrolysis technologies.7 The project would involve the erection of a modular structure and industrial canopy.

1.10 Environmental Setting
As shown in Figure 1-2, industrial use and natural waterways create the environment setting of the project site located within the boundary of the WCCSL facility. The WCCSL facility spans approximately 340 acres generally between Parr Boulevard and San Pablo Bay, south of San Pablo Creek. This area is composed of expansive planted disposal areas/landfill mounds, runoff control ponds and lagoons, the organic material processing facility and composting areas, and the location of the proposed project (within part of the BMPC area), is situated in the southeast area of the WCCSL facility. San Pablo Creek and the San Pablo and Wildcat Creek tidal marshlands exist north and south of the WCCSL facility. Open water of San Pablo Bay is approximately 0.25 miles west from the project site.

Figure 1-3 shows the closest structure and development is the Golden Bear Waste Recycling Facility (part of the BMPC) approximately 300 feet southwest of the proposed project location, and the West County Wastewater District Treatment Plant and the Wildcat Marsh Trail and trail head parking exist approximately 1,000 feet east of the project location. The surrounding uses are industrial, commercial and open space; the nearest sensitive receptors to the project site are 6 CO2 is carbon dioxide.
7 Electrolysis is a process that uses an electric current to split water molecules into their constituent elements of hydrogen and oxygen. Hydrogen that is produced through electrolysis using renewable energy sources is known as “green hydrogen”.
897

1. General Project Information
Raven SR Bioenergy Project 9 ESA / D202100382
Updated Initial Study MND March 9, 2023
residential uses, an elementary school, and a health clinic, all within approximately 0.75 to 1.2 miles southeast in the North Richmond area.

1.11 Required Discretionary Approvals
 City of Richmond (Lead Agency): Adoption of the CEQA Documentation, Mitigated Negative Declaration; Conditional Use Permit for a new activity and facility to convert organic waste to hydrogen8; and various development permits, including but not limited to site preparation, construction and building activities.

1.12 Other Agencies Whose Review or Approval Is Required  Bay Area Air Quality Management District (BAAQMD): Issuance of an Authority to Construct (ATC) for the associated air pollutant emissions. Raven SR has applied for an ATC air permit to be issued by BAAQMD. This permit application is currently undergoing review.
 East Bay Municipal Utilities District: Issuance of water supply service and approval of needed water main extensions and/or any off-site pipeline improvements.  West County Wastewater District: Issuance of wastewater discharge permit for the proposed project. This permitting from the District is pending.  State Water Resources Control Board: Raven SR would submit Notices of Intent (NOI) to the State Water Board. Raven SR would submit the Construction NOI prior to any grading on the project site obtain coverage under both the statewide General Permit for Discharges of Storm Water Associated with Construction Activity and General Permit for Storm Water Discharges Associated with Industrial Activities. The Industrial NOI would be submitted prior to operation of the waste conversion system.  State Department of Resource Recovery and Recycling (CalRecycle) and Local Enforcement Agency (LEA): Issuance of Solid Waste Facility Permit (SWFP).

1.13 California Native American Tribes Consultation
Pursuant to Public Resources Code section 21080.3.1, on May 4, 2022, the City received a response for consultation from a representative of the Confederated Villages of Lisjan.

Consultation occurred on May 18, 2022, during which the tribe posed no concerns with the proposed project or potential mitigation measures as it relates to impacts to tribal cultural resources and cultural resources. See Section 4.16, Tribal Cultural Resources, of this checklist for more detail.
8 The existing WCCSL facility operates under an existing City of Richmond Conditional Use Permit (CUP) and other resources agency permits.
898

1. General Project Information
Raven SR Bioenergy Project 10 ESA / D202100382
Updated Initial Study MND March 9, 2023
Blank Page
899

2. Project Description
Raven SR Bioenergy Project 11 ESA / D202100382
Updated Initial Study MND March 9, 2023

2. Project Description

2.1 Project Purpose
The purpose of Raven SR’s proposed project and its non-combustion Raven SR process is to reduce pollution, help reduce greenhouse gas emissions, and produce renewable and green hydrogen using a low-carbon process. This section introduces each of these goals and relevant characteristics of the proposed project.

Reduce Pollution and GHG Emissions
The project proposes to convert blended green waste and food waste obtained from the existing onsite OMPF west of the project site into renewable, low-carbon, transportation grade hydrogen.

Use of the low-carbon hydrogen as a substitute for petroleum-based fuels in heavy-duty vehicles and many other applications, would reduce the criteria pollutant emissions and GHG emissions from those vehicles and other applications.

The project would use WCCSL landfill gas that would otherwise be combusted in a flare - or in older, inefficient generators - in new generators. Existing 1980’s-vintage Waukesha (3 x model 7042 gl) landfill gas generators exist on the Republic Services site. These obsolete, aging, highemission generators would be removed from the site and replaced by new, low-emission Jenbacher engines (3 x jgs 420 gs-l.lc), equipped with Best Available Control Technology (BACT). Installation of the new generators for the project would significantly reduce existing emissions that would otherwise occur from continued flaring or the existing, poorly-controlled generators.

Produce Low-Carbon, Renewable Hydrogen
Hydrogen is a key mitigation strategy identified for several sectors by the California Air Resources Board (CARB) in its 2022 Scoping Plan for Achieving Carbon Neutrality (CARB, 2022a). The 2022 Scoping Plan is the state’s identified scenario for achieving carbon neutrality statewide no later than 2045. The Scoping Plan “calls for accelerating the transition from combustion of fossil fuels,” including by increasing the use of renewable and green hydrogen in zero-emissions vehicles, heavy-duty vehicles, aviation, ocean-going vessels, freight and passenger rail, and industrial applications. The Scoping Plan calls for increasing the current amount of hydrogen supply about 1,700 times and notes that hydrogen production from gasification of forest or agricultural waste is a possible technology to produce low-carbon hydrogen. In support of the Scoping Plan, Senate Bill (SB) 1075 (Skinner, 2022) directs CARB to make recommendations that accelerate progress in green hydrogen production, scaling and use.

To advance the Scoping Plan, Raven SR’s purpose is the conversion of organic feedstock input to produce renewable and green hydrogen with a lower carbon intensity than could be produced using electricity from the grid, that would consume less electricity per kilogram of hydrogen produced, and do so without using freshwater resources. Aligned with SB 1075, the project’s 900

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purpose is also to contribute to the expansion of renewable hydrogen supply needed to keep pace with the expanding fuel-cell vehicle population and fueling capacity.9

2.22.1 Existing Site Conditions and Ownership
Existing conditions ofat the project site are shown in Figure 2-0, Birdseye View of Project Site and Surrounding. The proposed Raven SR operation project would be developed on approximately 1.3 acres that Raven SR would lease within part of the existing Republic Services BMPC property shown in Figure 2-0, however it would operate separately from the existing BMPC operation, which extends west of the project site. Figure 2-1, Project Site and Raven SR Facility Areas, delineates the proposed 2.5-acres that is referred to as the “project site” and highlights the 1.3 acres where the Raven facilities and operations would occur. The project site is relatively flat and partially paved, with the remainder consisting of compacted soil and ruderal groundcover along the north edge. No trees or landscaping exist.

The existing landfill power plant and maintenance building are primary structures near the project site, and both would remain. Existing trailers housing ancillary uses on the site would be removed, and remnant concrete foundations from previous uses exist on the north portion of the site. (See Figure 2-0).

The project site is currently served by utility infrastructure and services by East Bay Municipal Utilities District (EBMUD), West County Wastewater District, PG&E, and City of Richmond police, fire and emergency services departments.

The existing owner of the property is West County Sanitary Landfill, Inc., a subsidiary of Republic Services, Inc. The property ownership is not proposed to change with the construction of the proposed project.

2.32.2 Surrounding Uses and Conditions
As highlighted in Figure 2-1, the project site is bound by existing fencing on the north, east and south, and connects to the surrounding WCCSL areas and operations via existing service road.

Not part of the proposed project, but within part of the BMPC property shown in Figure 2-0, the 9 To be clear, the proposed project is a separate and independent project from other possible hydrogen-related projects within the City that may be proposed in the near future. The Raven project has a separate and independent owner, located on a separate and independent site, has a separate and completely independent source stream to make hydrogen, is proposing “green” hydrogen, and is seeking separate entitlements. Additionally, baseline for the Raven project was established at the time that the completed application was filed by the applicant on July 30, 2021. At that time, other hydrogen-related projects were not in the entitlement process with the City. Months later Chevron submitted and application on November 15, 2021, for an alternatives fueling station that would include fueling equipment for hydrogen (H2) and compressed natural gas (CNG). That application did not propose the manufacturing of hydrogen. Additionally, after Raven’s project was received no other application has been received by the City for a hydrogen production project. As a result, the Raven project is not required to analyze the potential cumulative impacts for subsequent/potentially future projects as i) the fueling station application was submitted after the Raven project’s baseline; and/or ii) CEQA does not require analysis of speculative projects that have yet to be received. Finally, any hydrogen-related projects submitted after the Raven project or at some future date would be required to comply with CEQA. As part of that process, those projects would also need to include the Raven project in either the baseline or a reasonably foreseeable project for that project’s initial study – assuming that the type of project impacts overlap for the purposes of a cumulative analysis. 901

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existing WCCSL maintenance building, power plant, and a leachate treatment facility sit within 50 to 100 feet of the site, and leachate tanks operate just west of the north driveway into the property from the main WCCSL access road.

Figure 1-3 shows the nearby Golden Bear Waste Recycling Facility (part of the BMPC), located approximately 300 feet southwest of the property. Also, the West County Wastewater District Treatment Plant and the Wildcat Marsh Trail and trail head parking exist approximately 1,000 feet southeast of the property. Figure 1-2 and Figure 1-3 show the surrounding expanse consists of components of the 340-acre WCCSL facility, which consists of several distinct operations that function as a whole. Notably, these areas and uses include grass-covered disposal areas that are landfill mounds, runoff control ponds and lagoons, and composting areas, in addition to the tidal marshlands of San Pablo and Wildcat Creek tidal marshlands. Open water of San Pablo Bay is approximately 0.25 miles westward from the project site. (WCCSL BMPC Draft EIR, 2003) 902
Figure 2-0
Birdseye View of Project Site and Surrounding (from SE) SOURCE: ESA, 2022; Google Earth, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator r ESA
~ 903
Conversion Operation
(modular building and canopy)
Fire Water Tank
& Equipment
Export Panels/Trucks
Figure 2-1
Project Site and Raven SR Facility Areas
N
SOURCE: Raven LLC, 2022; ESA, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator Bulk Materials Processing Center Property Raven SR Facility Areas 904

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2.42.3 Site Plan and Structures
Figure 2-2, Simulated 3D Site Development, illustrates the proposed facility and key operation components simulated in a birds-eye view. All Raven SR’s materials handling systems would be located inside a proposed modular structure. The proposed project would erect a new stand-alone modular structure where storage uses and remnant foundations currently exist at the north edge of the property. The proposed modular structure and industrial metal canopy for the feed (or input) area would contain three primary areas for the three-stage process of the operation described below.

Figures 2-3a and 2-3b, South Elevations, illustrate the proposed facility and key operations in elevation, and Figure 2-4, Detailed Site Layout and Raven SR Facility Plan, identifies each component in detail. The total new building area would be approximately 40,000 square feet. The industrial feed material handler would be up to 31 feet tall and the tallest facility element. Other elements of height and size include the nitrogen tank (30 feet tall); the cooling tower and the fire water tank (both 25.5 feet tall); and the industrial metal canopy over the feed/unload storage area, the adjacent steam reformer structure, and the nitrogen tank (each 26 feet tall). 905
Leachate
Tanks
WCCSL
Maintenance
Building
Bay Trail/Levee
Power
Generation
Building
Leachate Pond
Closed Class I Disposal Site
Figure 2-2
Simulated 3D Site Development
SOURCE: Raven LLC, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator 906
Figure 2-3a
South Elevation (West End)
SOURCE: Raven LLC, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator r ESA
~ 907
Figure 2-3b
South Elevation (East End)
SOURCE: Raven LLC, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator r ESA
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Figure 2-4
Detailed Site Layout and Raven SR Facility Plan
SOURCE: Raven LLC, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator 909

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2.52.4 Technology
Raven SR’s multi-patented Steam/CO2 Reformation technology can convert a variety of organic waste feedstocks into a hydrogen-rich synthesis gas (syngas) through a three-step process shown in Figure 2-5, Raven SR Process Diagram.
10 Organic feedstocks include
biomass, municipal solid waste, bio-solids, industrial waste, sewage, medical waste, or a combination of these, obtained from the existing WCCSL. The first stage of the process to turn feedstock into a raw syngas begins with an externally-heated “biomass steam reformer” and a “syngas steam reformer”. The raw syngas is then polished, and then processed through purification of hydrogen to make the hydrogen product: transportation-grade hydrogen-rich syngas. In 1993, the California Environmental Protection Agency’s Department of Toxic Substances Control (DTSC) determined that the Raven SR process to produce syngas from biomass and other carbonaceous solids was not categorized as either incineration or combustion and was therefore a suitable technology for use in California.

While Tthe Raven SR tTechnology can use a variety of potential feedstocks, the selected feedstock for this Project is a blend of urban greenwaste and organic food waste supplied by WCCSL. The first stage of the process to turn feedstock into a raw syngas begins with an externally heated “biomass steam reformer” and a “syngas steam reformer.” The raw syngas is then conditioned, compressed and processed through purification systems to produce hydrogen product: transportation-grade (compliant with SAE J2719) hydrogen. 11 The technology is strictly non-combustion (i.e., anoxic, indirect heating), low pressure, and a catalyst-free process. As indicated in Figure 2-5, early in the process, the system sequesters solid carbon in a byproduct, biocarbon (also referred to as “biochar”), which is a salable product that can be used for fertilizer or filler for concrete, for example. The biocarbon mixture also includes elementsnon-reactive components within the organic waste feedstock (dirt, glass, grit, rocks, inorganic salts, etc.) that are inert to the process, not gasified, and drop out in the first stage, avoiding slag and tars.12 The amount of biocarbon mixture is aApproximately 15 to 20 percent of the volume of dry feedstock input. (Also see Section 2.5, Safety and Controls, Non-Combustion, below.)
Feedstock is supplied by the Republic WCCSL and based on a blend of urban green waste (grass, tree branches, etc.) and organic food waste that has already been subject to visual inspection for contaminants by Republic before delivery to the Project’s receiving floor. Any incidental, non greenwaste/organic food waste sSolid material that goes may inadvertently make it through the feed handling earlier inspection and removal by the Republic WCCSL process before the Raven system, including any inorganicvolatile material (such as bits of plastics, cardboard, wrappers, 10 Hydrogen-rich, 55 to 63 percent H2. 11 “Conditioned” or “conditioning” refers to steps in the process to convert residual impurities, primarily sulfur compounds, into a form that can easily be removed from the syngas. If the sulfur is not removed, it will contaminate downstream catalyst/media, deactivating it, significantly reducing performance in downstream processing.
12 The biocarbon is considered sterile following thermal treatment by the first stage of the process, when biological pathogens (if any) are destroyed by elevated temperature and residence time of approximately 45 minutes. 910

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etc.refrigerants, batteries) that may incidentally flow through to the rotary reformer would be convertedundergo conversion to syngas as they it thermally decomposes by exposure to temperatures in the range of 1,400 degrees F. Any volatile material would become part of the syngas, whileand non-volatile, inert material would report to the biocarbon solid phase. No emissions would be generated by any volatile materials that may inadvertently enter the process.

As stated earlier, the solid components of the feedstock that do not thermally decompose at 1400 degrees F+ would report to the solid phase and become biocarbon, while the volatile components would become part of the raw syngas and go to the secondary steam reformer (SR2) operating at 1900 degrees F+. (Also see Feedstock Processing, below.) Processing other potential feedstocks within the confines of this project is not consistent with Raven SR’s intent or Project Business Plan as shown by its agreement with allowed conditional uses of the site.

As also shown in Figure 2-5, the waste heat or “tail gas” (i.e., other gaseous components of the syngas that have been separated from the hydrogen product with residual, otherwise unrecoverable energy content) from the conversion process can be blended with existing LFG to generate power and increase the efficiency of the process. At some point in the cycle, This occurs in new state-of-the-art, higher efficiency, low emission Jenbacher engines, which will provide approximately half the electrical demand needed for the biomass conversion process. Emissions estimates for these engines were made using the blended fuel composition of LFG and Raven process tailgas. These engines will incorporate exhaust emissions control systems for low emissions. The hot engine exhaust is used to dewater the incoming biomass feed stream before it enters the rotary reformer. Using this available heat increases overall process energy efficiency, and eliminates fuel combustion or costly electricity to supply heat at the dryer for dewatering feedstock. Use of the LFG and the tail gas would no longer recycle into the process and instead go to the stack or in the Jenbacher engines will result in a reduction in emissions of criteria pollutants from combustion of the landfill gas in the existing flare or existing engines, described below.

Flare System
Raven SR anticipates use of its flare system as a safety backup for the evacuation or venting of syngas and, on rare occasion, vent hydrogen product. The new Raven SR flare is in addition to the existing LFG flares operated by Republic that serve to destroy LFG in the event the LFG engines are not available.

The Raven SR flare system, for syngas vented in the event of an unexpected or emergency shutdown, would be in the constant state of readiness through a hooded, continuous propane pilot system. Use of the flare would beis expected to be infrequent no more than 100 hours per year and only for emergency situations, expected to occur in fewon three typical instancesoccasions:
911
Feedstock
Management
Biomass Steam
Reforming
Syngas Steam
Reforming
Syngas
Polishing
Hydrogen
Purification
Blend of
Greenwaste
and Organic
Foodwaste
Overs
To Compost
Biochar
Tailgas
Hydrogen
Product
Power Generation Blend of LFG and
Tailgas
Stack
Or
Flare
LFG
Electricity
To Process
Supplemental
Electricity
From Grid
Richmond ONE – Simplified Block Flow Diagram
Copyright 2022 Raven SR, USA
Figure 2-5
Raven SR Process Diagram
SOURCE: Raven LLC, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator 912

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1. System start-up: During start-up of the system, off-spec syngas would be generated and evacuated from the system to the flare for destruction of volatiles.

2. System shut-down: Whether for emergency shut-down or planned shutdown, the system would require its inventory of syngas to be vented to the flare for destruction of volatiles.

3. No off-take available: On the rare occasion when a product load-out truck is not available (e.g., traffic, breakdown, etc.) or an unplanned outage on the export equipment is experienced, and arrangements are in process for replacement and/or repair, Raven SR must vent valuable hydrogen product to the flare as it would have no provision for emergency storage.

These instances have been quantified in Raven SR’s air permit application to BAAQMD, and are included in the air emissions evaluated in this document. Note that item #3 has been clarified in this updated IS/MND. The reason is that hydrogen is not a criterial pollutant. In the unlikely case that no off-take is immediately available, the design plans call for the product gas (which is greater than

99.99 percent hydrogen) to be safely vented to the atmosphere rather than flared. The purified, high-pressure hydrogen is not proposed to be flared as the pressure could create potential noise emissions. The design plan also contemplates that if no off-taker is available for a significant period of time, the plant will determine the proper response such as reducing the rate of production, pausing production, and/or shutting down production. Even in the worst-case scenario it is anticipated that not more than an hour’s worth of production of hydrogen would be in the system even if venting were necessary. As the produced hydrogen is valuable, venting is not a preferred option from an operator perspective. Instead, the expectation is that the plant would not continue to operate by consuming feedstock and power, and that any venting of hydrogen product would only occur in rare circumstances for brief durations of time.

These instances have been quantified in Raven SR’s air permit application to BAAQMD, and are included in the air emissions evaluated in this document.

In 1993, the California Environmental Protection Agency’s Department of Toxic Substances Control (DTSC) determined that the Raven SR process for the production of syngas from biomass and other carbonaceous solids was not categorized as either incineration or combustion and was therefore a suitable technology for use in California.13

2.62.5 Operations
Pre-Processing and Load Checks
The origin of the feedstock and the pre-processing and screening redundancies built into the sSystem processes would to ensure that little or no material contamination that is incompatible with the Raven SR process would be introduced to the conversion system. These processes 13 According to the definitions listed in Section 260.10, Title 40, Code of Federal Regulations (40 CFR) and Section 66260.10, Title 22, California Code of Regulations (22 CCR). Also, since 2017, a Raven pilot engineering unit, sized at 100 wet pounds per day of feedstock, has been operating at the UC Berkeley’s Richmond Field Station and is permitted for operation by the Bay Area Air Quality Management District (BAAQMD) under permit Nos. 23993 and 23320.
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include documenting the feedstock origin, as well as pre-processing and screening redundancies.

First, Republic Services would grind and visually screen, load check and grind the incoming mix of green waste and organic food waste before delivering the feedstock to Raven. Any noncompostableincompatible material and other prohibited wastes would be minimized through Republic’s screening and load checking programs that occur at its compost facility. In addition, all incoming pre-processed feedstock received at the Raven SR facility will also be subject to the Raven SR’s own screening and load checking program as required by State solid waste facility regulations. 14
After screening and load checking, the organic material is pre-processed by grinding to reduce volume, provide for a uniform mixture of material and particle size, and further screen out any remaining contaminants. The pre-processed organic material would then be delivered approximately 2,500 feet from the compost area to the Raven SR facility by Republic personnel and vehicles. The trucks would consist of self-unloading transfer trucks or other suitable vehicles that would discharge loads as directed by a spotter onto the floor of Raven SR’s material receiving area. There the material would be visually inspected and subject to Raven’s load checking program, then pushed by a loader into storage bunkers or other designated material storage areas. The pre-processed feedstock material would be fed into a metering hopper to cross a screen to remove any oversized material, and then a magnetic separator to remove any unexpected metal. Any oversized material would be returned to Republic’s composting facility, and any recovered metal would be sent for recycling.

As discussed above in 2.42.5, Technology, if any materials are missed by the screening processes and enters the rotary reformer, those materials become part of process feed and would eventually become syngas or biocarbon.

Daily Quantities and Operations
The Raven facility would receive up to 99.9 wet tons per day of blended green waste and food waste feedstock to produce approximately 14 tons per day of biocarbon and up to 4,800 kilograms (kg) (5.3 tons) of hydrogen per day.15 Feedstock would be weighed on Republic scales before arriving at the Raven SR site, and the commodities that come out of the process would be weighed on Republic scales outside of the Raven SR site. The WCCSL material that would be diverted to the Raven SR facility by Republic represents a portion of their permitted 250 tons per day of compost processing capacity.

The Raven SR process and facility is designed for continuous operation without manyand would minimize start-ups or shut-downs. Accordingly, the Raven SR system would operate run up to 24 14 A load checking program are developed in compliance with Title 14, Code of California Regulations (CCR), §17409.5, and generally address the number of load checks to be performed; the location for the storage of prohibited wastes removed during the load checking process that is separately secured or isolated; records of load checks and the personnel training.
15 While Raven SR can produce synthetic liquid fuels, the proposed Richmond location proposes to only produce transportation grade hydrogen due to the interest of the local and regional markets for non-fossil fuel based hydrogen.
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hours per day, seven days per week, although an average of 1.5 days per month are planned down times with a single, extended outage for annual maintenance. This totals approximately 8,300 hours of operation per year.

Energy and Fuel Use
The plant would consume approximately 6.0+ MW of electricity (MWe) to operate and produce the 4,800 kg of hydrogen per day (200 kg of hydrogen per hour). The majority of thethis power would come from onsite power generation using newly installed LFG engines, that would replace existing, featuring higher efficiency and lower emissions than the inefficient WCCSL engines with relatively higher emissions. The fuel tonew engines will be used for equipped with state-ofart air pollution controls that represent BACT. For comparison, the new engines will achieve a NOx emission rate that is 81 percent lower than the existing WCCSL engines. Using the blended LFG/tail gas fuel, the new engines will also achieve CO emissions that are 53 percent to 62 percent lower than the WCCSL engines being replaced.
tThe proposed fuel for power generation is the existing LFG from the Republic Services BMPC, combined WCCSL, blended with the tail gas from the pressure swing absorber (PSA) unit that serves to purify the hydrogen product. Republic Services would receive approximately 0.5 MW from the power generation for its onsite operation needs and the rest would be used to power the proposed project. Any additional electrical power required beyond that generated onsite would come from an existing PG&E power drop to the site, as also indicated in Figure 2-5.

Safety and Controls
No Combustion Technology. The Raven SR’s facility’s controls would be distributed through the various process islands, taking their direction from a central Human-Machine Interface in the control room with centralized data collection. Process setpoints would be bounded by high/low alarm limitations to draw the operator’s attention to the specific problem. The control system would represent state-of-the-art digital technology with redundant instrumentation where necessary to ensure safe operation.

Raven would initiate inspection, monitoring maintenance procedures to ensure safe facility operations. Because the Raven SR process itself is closed and oxygen-free, there would be no opportunity within the process for explosion. Piping and vessels would be periodically scanned with infrared equipment to identify hot spots or gas leaks that may threaten safety. If hot spots or leaks were identified, immediate steps would be taken to correct or mediate the condition. Also, remote monitoring of the facility by Raven SR corporate provides oversight of the operation and early identification of problems as they development.

The facility would maintain a “Plant Safety Handbook” and establish industry-accepted procedures to be followed if events threaten the safety of employees, the facility or surrounding areas. The facility would maintain and evolve Standard Operating Procedures for aspects of the plant that require frequent intervention, for example. One example of such activity is the daily acceptance of trucks for loading with hydrogen product, wherein accepted procedures to accept a truck for loading of hydrogen product, to fill to regulated maximum allowable pressures, to 915

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ensure a cool-down period to allow the pressurized gas to dissipate the heat of compression prior to departure from the site. These procedures are informed and well-defined from industry experience and with oversight for the entire fueling process from federal agencies that handoff responsibility during their respective stage of the fueling process. For example, arriving for fueling (USDOT), Fueling (USEPA, OSHA), Departing from fueling (USDOT)shed the heat of compression, etc.

Safety Standards and Maintenance. Raven SR units are equippedThe project is being designed in accordance with continuous monitoring California Fire Code for all systems and can automatically shut down equipment installation containing flammable, combustible, or hazardous materials, and an equipment maintenance program agreed upon by the City and the Fire Marshall will be implemented.

As part of the Project design process, Raven SR will conduct a Process Hazard Analysis (PHA) in which a detailed risk evaluation will be conducted of the proposed plant design and plans for operations without human intervention. The project would comply The PHA will identify all potential hazards associated with the proposed process operations, including potential hazards associated with the properties of hydrogen; evaluate the controls and safeguards planned in the design to ensure safe operation of the process; and identify recommendations for additional risk mitigation that will be addressed during the final design phase.

The PHA is one element of the process safety and risk management programs (PSM/RMP) that will be implemented in accordance with applicable Environmental Protection Agency (EPA) risk management plan (RMP) and Occupational Safety and Health Administration (OSHA) process safety management (PSM) guidelines, as and Richmond Industrial Safety Ordinance (RISO) regulations to ensure the plant is designed to mitigate potential risks and operate safely. Raven SR has chosen to implement these programs even though a preliminary determination has indicated that these requirements may not be appliedapplicable to the facility. to ensure the safety of its operations staff and the surrounding community. The proposed design would have less than 10,000 pounds of flammable substances within the process, which is the threshold quantity that triggers applicability. Though Raven SR’s flammable inventory would be below this threshold, Raven SR would voluntarily adhere to the requirements of PSM as a process to facilitate safe, reliable operation of the facility.

PSM policies and programs, and the pertinent agencies that minister and provide oversight to qualifying projects, fall under the umbrella of the California Certified Unified Program Agencies (CUPA) Forum. CUPA is a statewide alliance of Certified Unified Program Agencies and Participating Agencies (collectively known as Unified Program Agencies-UPAs) that implement the Unified Program under California Health and Safety Code Division 20, Chapter 6.11. The organization works to update and continuously improve the Unified Program for the agencies, businesses and communities served.

The OSHA PSM and EPA RMP programs contain many elements to promote safety and are well known in industry. Information is available to the public on-line. For the Raven facility, these elements are under development and include, but are not limited to:
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 Comprehensive Process Safety Information (PSI), which will be utilized in the Process Hazards Analysis and for developing safe work practices and operating procedures;
 Employee Participation to ensure employee involvement in the PSM/RMP process;  Operating Procedures to develop safe work practices and protocols;  Training of all employees and contractors on the potential hazards and safe operations;  Management of Change process to verify any new systems, components, parts, etc. are evaluated before being placed into service;
 Pre-Start Safety Review (PSSR) to verify the process/equipment is ready for service before starting. This includes all safety and control items are functioning and operators are aware/trained on any changes;
 Incident Investigation to identify and understand the root cause of equipment or system failures and develop/implement corrective actions to keep from happening again;  Management of Contractors in a manner that ensures they are aware the safety aspects of the facility as well as the requirement while working on site;  Mechanical Integrity including routine maintenance, to verify the mechanical reliability of equipment; and
 Emergency Planning and Response to have a process/procedure in place in the event of an issue, so a standard protocol can be followed. This requires understanding of the process and determining potential issues that could occur, and developing protocols to manage the situation should an event occur.

The proposed project is divided into two key phases with specific needs incorporated into the project design that adhere to safety guidelines in order to further maintain safe practices at the facility. During the Construction Phase of the project, Raven SR’s contractor would carry responsibility for site conditions and the safety of labor, contractors, and suppliers that may have access to the site. Safety training for the various construction roles prior to access to the site would be mandatory, using programs developed by the general contractor. Daily briefings would be conducted to highlight safety and alert crew and labor to potential hazards that may be scheduled for that day’s work. Although not likely to exist, any work areas subject to potential physical harm such as those presenting fall hazards, exposure to hot work, or loud noise will be appropriately marked and identified with physical barriers to prevent unwitting access.

During the Operations Phase of the Project, Raven SR will comply with local, state and federal regulations. Raven SR and its operations and maintenance (O&M) service would institute a video library of tutorials on aspects of conduct on-site related to safe operation of equipment.

Employees and those contractors needed to access the site during operations would be required to complete applicable training videos.

Raven SR would provide its employees and visitors specialized Personal Protective Equipment (“PPE”) (e.g., gloves, goggles, respirators, boots, etc.) required for access to process areas that operate at high temperature and high pressure. Areas requiring PPE would be marked with 917

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signage for clear instruction to those seeking to enter and work within these areas. Raven SR would ensure that employees and visitors are appropriately trained in the use of PPE.

A maintenance program of regular and routine, preventative and predictive maintenance would also be implemented to maintain equipment in a reliable manner. Raven SR would contract with a capable and experienced O&M service provider from among those with experience in feedstock management and with high temperature, high pressure process equipment. As is typical practice, Raven SR would closely oversee the development of operating, training, safety, and maintenance manuals that are specifically targeted for the Project’s needs. Raven SR would monitor the development of the requisite Plant documentation and assist in the management of risk during plant operation at the corporate level.

Fugitive Emissions. The system is a closed process once the organic feedstock input is managed. Mechanical unit would have mechanical seals on the feed inlet and the biochar outlet, preventing fugitive emission from the first-stage reformer which operates under mild pressure.

The first stage vessel (SR1) has mechanical seals that are purged of air using with pressurized nitrogen, which would prohibit the release of fugitive emissions. Tail gas, generated by the process and consisting of the non-hydrogen syngas components, with residual unrecoverable hydrogen, would be is combined with LFG and used to use its residual energy content as a fuel for the LFG generators to generate additional energy.

Due to its extremely small molecule size, hydrogen has unique physical properties, such as buoyancy. Hydrogen is 14 times lighter than air and moves upward quickly. Raven SR operations would institute proactive measures to periodically monitor plant piping for hot spots that may be indicative of potential gas leaks. Technology, such as an FLIR camera, will be used to highlight and identify a potential hotspot, so remedial actions are implemented to prevent or correct any gas leak, as appropriate. Hydrogen is not a criteria pollutant and is a key mitigation strategy in the 2022 Scoping Plan’s objectives for carbon neutrality.

Odor Control. Odors may exist and derive from the organic feedstock input that is already produced and processed at the WCCSL. Nuisance odor from The first step in the Raven process is unlikely since to dry incoming feedstock material would only be on the feedstock management area floor for relatively short periods of time using waste heat from the LFG engines before introduction to Raven’s first stage reformer. Dry feedstocks do not typically create or form odors.

To proactively address the potential for odors, the Raven SR Project includes the implementation of a number of odor minimization procedures and regulatory requirements. These odor minimization requirements include
i. Feedstock load checking at the Republic site for identification and removal of prohibited material including any highly-odorous loads;
ii. Feedstock pre-processing at the Republic site before being sent to the Raven facility; iii. Operations protocol for first in/first out feedstock consumption; iv. Feedstock will typically be processed within 24 hours with a maximum limit within 48 hours of receipt;
v. Daily cleaning of the feedstock handling area; and
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vi. Use of odor suppressants if necessary.

Feedstock for the Raven process will only include pre-processed consisting primarily of blended green waste and food waste. The source of this material is from the onsite composting facility referred to as the OMPF. The OMPF receives vehicle loads directly from residential and commercial organics collection programs. The OMPF operating procedures include initial visual screening and a load checking program designed to identify and remove prohibited material, including any highly odorous loads. After screening and load checking, remaining organic material is pre-processed by grinding. Only material that has been through the screening, load checking and grinding process at the OMPF would be delivered to the Raven facility, thus minimizing the potential for receiving prohibited or highly odorous material. In addition, all incoming pre-processed feedstock received at the Raven SR facility would also be subject to the Raven SR’s own screening and load checking program as required by State solid waste facility regulations.

To further minimize potential odor effects of the proposed project, the standard operating procedures for the Raven facility would include a “first in first out protocol” for the processing of material. Typically, any material received would be processed within 24 hours of receipt through the hydrogen conversion system. As a requirement of both the draft CUP and the Solid Waste Facility Permit (SWFP) for the facility, all feedstock material would, at a maximum, be processed within 48 hours of receipt. With this minimal time effects of the proposed project in the feedstock handling area, the potential for odor would be greatly reduced as opposed to odors arising over time from decomposing feedstock.

Additional odor minimization provisions and requirements would be incorporated into the proposed project in accordance with the draft CUP and SWFP and addressing maximum volumes for daily input and storage, facility cleaning schedule, complaint response and reporting protocols, preparation and adherence to an Odor Prevention and Management Plan (OPMP) the requires an annual evaluation report. As discussed in more detail in the CEQA assessment of potential odor impacts (Section 4.3, Air Quality), Raven SR will implement operating procedures and comply with regulatory requirements related to minimizing potential odor impacts at the Raven SR facility in order to address and minimize potential odor impacts. However, odor control for the proposed Raven SR operation would be in place to minimize possible odors. Also, the proposed industrial metal canopy would be placed over the feedstock floor and infeed equipment to prevent stormwater contact. Odor control would be added to the management area if objectionable odors occur. The facility could also store topical treatment solutions (non-toxic and biodegradable) onsite, which would be applied to neutralize odors if an immediate need arises.

Hydrogen Storage and Export Panel. The hydrogen product is compressed for short term storage after the first-stage compressor, before being compressed with a second-state, higher pressure compressor and exported via truck-mounted tube trailers for delivery to facilities using hydrogen for transportation or processes needing green hydrogen. There is no compression tank in the design. The produced hydrogen would be onboarded by a hydrogen gas export panel designed by a global manufacturer of hydrogen fueling stations to industry standards, incorporating best-practice Health, Safety, Security and Environment (HSSE) design. The panel 919

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is compliant with National Fire Protection Association (NFPA) industry standards for handling hydrogen.

Onsite Water Tank / Fire Equipment. A new 250,000-gallon integrated fire water tank and diesel engine is proposed in the northeast corner of the site emergency use, as required by fire department regulations The fire water tank would be up to 25.5 feet tall. (Shown in Figures 2-1 through 2-4.)

2.72.6 Employment
Raven would employ approximately three to four employees per shift for the operation of the Raven facility, for a total of nine to 12 new employees to cover all shifts and provide necessary support of the facility. The facility would not involve customers onsite.

2.82.7 Transportation and Circulation
As indicated under “Safety Controls” above, the proposed project would export the produced hydrogen offsite via truck-mounted tube trailers (shown in Figures 2-2 through 2-4). The operation would involve upis expected to service approximately 1214 hydrogen tube trucks and up to approximately 15 biocarbon trucks (total 37 trucks) per weekday, each with an average trip of 40 miles after leaving the site. In addition, up to approximately 11 biocarbon trucks per day would be in use for the co-product. Considering this with other trucks and employees coming to and leaving the project site daily, 12 employee vehicles and 25 trucks would access the site dailythe project is estimated to generate about 130 vehicle trips on a typical weekday.

In addition, the Raven SR system would only use feedstock from ongoing existing composting BMPC operations on the property that would not leave the WCCSL site. Figures 2-2 and 2-4 show where WCCSL feedstock supply trucks would approach and exit the Raven facility from the feedstock prep area, and in addition to Figure 2-3a show three stalls where the tube trucks would connect to a hose and receive the hydrogen product. The tube trailers would idle for no more than five minutes once at project site, as required per State regulations.

2.92.8 Construction, Site Coverage and Drainage
Raven anticipates initiating construction activity on the project site in FourthSecond Quarter of 20222023, which would continue for approximately eight months. Start-up of the plant is projected to begin in Fourth Quarter of 2023, or First Quarter of 2024early the Second or Third Quarter of 2023.

Construction proposed is to demolish the existing materials and remove existing equipment from the project site, lightly regrade the site, add up to six inches of fill, and erect the new facility. The existing project site is mostly paved and partially pervious compacted soil and ruderal groundcover (see Figure 2-1). Existing materials to be excavated include remnant concrete foundations that would be pulverized and partially used as fill material. 920

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The maximum depth of excavation would be up to 2.5 feet. All excavation spoils and remaining concrete debris would remain on the landfill site. Minimal fill, approximately 250 cubic yards, may be required and would be hauled obtained from suitable, available materials already on site for generated during site grading; only demolition materials (asphalt and concrete) would be off hauled.

Approximately 0.76 acres of the 2.5-acre project site is currently impervious concrete or asphalt.

The proposed project would repave the existing 0.76 acres in addition to adding approximately

1.21 acres of impervious area (including modular structures), resulting in a total of 1.97 acres (or 78 percent) of impervious area on the site. Approximately 0.53 acres of unpaved area along the north edge of the site would remain undisturbed. There are no natural drainage paths on the site.

The project would adhere to all applicable regulatory stormwater runoff controls and would pursue its own National Pollutant Discharge Elimination System (NPDES) permit. The project’s stormwater plan would be integrated into the existing WCCSL system and ensure drainage from the proposed project site would drain towards existing stormwater runoff control ponds (or bioretention facility) to which the rest of the WCCSL property currently drains.

2.102.9 Off-site Improvements: Landscaping
As part of the proposed project, off-site landscaping improvements are planned for to the Wildcat Marsh Trail and trail head parking located approximately 1,000 feet east of the project location.

Due to limited space and potential safety hazards, no new plants or vegetation would be installed within the Raven project site. Instead, new trees would be added to the public parking area near the trailhead.

Eleven drought-tolerant trees would be planted: either six large Coast Live Oak (Quercus agrifolia) or Big Leaf Maple (Acer macrophyllum), and five small California Buckeye (Aesculus californica). Both species are on City’s approved list of trees. Tree size planted would be associated with 15-gallon containers.

References
CARB, 2022a. California’s Final 2022 Climate Change Scoping Plan, November 16, 2022.

Available online:
https://ww2.arb.ca.gov/our-work/programs/ab-32-climate-change-scoping-plan/2022- scoping-plan-documents. Accessed on March 4, 2023.

Skinner, 2022. California Senate Bill No. 1075, September 19, 2022. Available online:
https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202120220SB1075 921

3. Environmental Factors Potentially Affected

3. Environmental Factors Potentially Affected
The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a "Potentially Significant Impact," as indicated by the checklist on the following pages.
□ Aesthetics □ Agriculture and Forestry Resources ~
~ Biological Resources ~ Cultural Resources □
□ Geology, Soils and Seismicity □ Greenhouse Gas Emissions □ □ Hydrology and Water Quality □ Land Use and Planning □ □ NoiseNibration □ Population and Housing □
□ Recreation □ Transportation ~
□ Utilities and Service Systems □ Wildfire □
Determination: (To be completed by Lead Agency)
On the basis of this initial study:

Air Quality
Energy
Hazards /Hazardous Materials
Mineral Resources
Public Services
Tribal Cultural Resources
Mandatory Findings of Significance
D I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.
~ I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.

D I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENT AL IMPACT REPORT is required.

D I find that the proposed project MAY have a "potentially significant impact" or "potentially significant unless mitigated" impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.

D I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, no further environmental documentation is required.

Si~nature [ \
L~ clio" . \as
Print~Name
Raven SR Bioenergy Project
Updated Initial Study MND
Date
For
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4. Environmental Checklist and Evaluation

4.1 Aesthetics
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Aesthetics
Except as provided in Public Resources Code Section 21099, would the project:
a) Have a substantial adverse effect on a scenic vista?  b) Substantially damage scenic resources, including,
but not limited to, trees, rock outcroppings, and
historic building within a State Scenic Highway?

c) In non-urbanized areas, substantially degrade the
existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing
scenic quality?

d) Create a new source of substantial light or glare
which would adversely affect day or nighttime views in the area?

Setting
The project site is within the WCCSL within an industrial, commercial, and open space setting of North Richmond. It is an integrated solid waste management and disposal facility and does not have significant visual value. Grading on the site over the years has resulted in topographic variations created by the hill forms or mounds that are the grass-covered landfills. The hill forms range from between elevations 110 and 160 feet above mean sea level, with up to an additional seven feet of soil layer. (WCCSL BMPC Draft EIR, 2003) The area has little or no distinctive visual features, except for leachate treatment ponds, runoff control ponds and lagoons, and marshlands of Wildcat Creek.

Despite the absence of significant visual value within the WCCSL itself, the site provides extensive views in all directions, including unobstructed panoramic views of San Pablo Bay, San Pablo Ridge and Mt. Tamalpais across the Bay. The visual quality of the WCCSL has been assessed in numerous CEQA analyses over the years, and each determined that no aspect of the WCCSL operations would significantly affect visual quality. (WCCSL BMPC Draft EIR, 2003) Evaluation
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Less than Significant Impact. Visual access the WCCSL from nearby public areas are distant and limited, largely because the surrounding areas are mostly at lower elevations than that of the WCCSL; distant views are blocked by buildings or landscaping. Views toward the WCCSL and the project site from Richmond Parkway are blocked by trees and the property is difficult to distinguish from adjacent and background across the Bay.

Northbound and southbound motorists on the Richmond Parkway can view the WCCSL, but views are limited, short-term and sometimes obscured or blocked by median landscaping or intervening trees and buildings. The proposed project site within part of the BMPC area is not visible from offsite areas as it is at an even lower elevation and behind intervening berms and levees.

Figure 4.1-1, Wildcat Marsh Trail Approach Toward Project Site (from East), captures part of the project site that would be visible to users of this public trail. The viewshed from this location does not capture any scenic vistas in the direction of the project site. Views toward the opposite direction of the site from the trail provides direct expansive views of the Wildcat Creek Marsh. Moreover, once developed, the facilities will appear consistent with the industrial nature of the existing visible facilities. The project would not have an adverse effect on a scenic vista. The impact would be less than significant.
b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic building within a State Scenic Highway? No Impact. No designated scenic highways currently exist within the City of Richmond, according to California Scenic Highway Program mapping system. (Caltrans, 2016) While the City’s prior 1994 General Plan and General Plan EIR identified portions of Richmond Parkway as having a positive aesthetic value, the proposed project site is not visible from the parkway. (Richmond, 2011)
c) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
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Figure 4.1-1
Wildcat Marsh Trail Approach Toward Project Site (from East) SOURCE: ESA, 2022
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Less than Significant Impact. The 340-acre WCCSL facility, in which the project site sits, consists of several distinct operations that function as a whole. Notably, these operations and areas include grass-covered disposal areas, notably the main central, landfill hill, runoff control ponds and lagoons, and composting areas, in addition to the tidal marshlands of Wildcat Creek. As previously stated in this section, numerous environmental reviews pursuant to CEQA have been conducted on all WCCSL activities, all of which determined that none of the activities would significantly affect the visual quality of the facility.

The proposed project could be visible from points along the adjacent and lower Bay Trail, since segments of the Trail allow users to observe, from a safe distance, some recycling activities within the WCCSL property. To the extent that the proposed project facilities and operation could be visible, the views would be distant and would not be adverse relative to other visible WCCSL activities. Figure 4.1-2, Onsite View Toward Project Site, shows the existing visual character in which the proposed project would exists.

All feedstock material for the proposed operation would be organic materials sorted from the existing onsite BMPCOMPF composting operation; no feedstock would be brought directly to the Raven facility from offsite. Product from the project operation would leave the project site in hydrogen tube trucks and biocarbon trucks. Therefore, operations of the Raven facility are not expected to be a source of litter that could exacerbate litter and dumping in the nearby neighborhoods.

Overall, the project’s effect on existing visual character or quality of public views of the site and its surroundings would be less than significant. d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Less than Significant Impact. Many activities within the WCCSL facility operate 24 hours a day, seven days per week, including the onsite OMPFBMPC activities and waste recovery composting operations. Other onsite processing operations operate until midnight. All existing operations operate under approved County and City use permits, which requires all lighting systems to reduce glare and to not substantially impact area residents. Existing lighting is varied and includes various sizes of portable and directional flood lights on certain operations.
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Figure 4.1-2
Onsite View Toward Project Site
SOURCE: ESA, 2022 Raven SR Bioenergy Project Initial Study 2021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator r ESA
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The proposed project would also operate 24 hours a day, seven days per week, and would be developed within an existing, functional area of the BMPC operationproperty, which is currently lighted. The project proposes LED lighting mounted on 30-foot-tall poles.

Like the existing WCCSL and BMPC conditions, the additional lighting would be focused and shaded, incorporating directional shading (down-shot reflectors) to limit light pollution during night operations. The project would place nine single-light fixtures at throughout the site and three double-light fixtures in the truck loading area in the south portion of the site. Also, the continuous propane pilot light that fuels the flare system used as needed to evacuate or vent organic syngas or on rare occasion vent hydrogen product, would be hooded, thus minimizing its visibility from offsite.

Given existing lighting conditions and that the proposed project site is located within the varied topography of the WCCSL and would not be directly visible from offsite locations, the proposed project would not substantially alter current lighting conditions.

Moreover, any new lighting would not affect nighttime views in the area. This impact would be less than significant.

References
California Department of Transportation (Caltrans), 2016. Scenic Highways Program. Available at:
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8 057116f1aacaa. Accessed June 3, 2022.

City of Richmond, 2011. General Plan 2030 EIR. August 2011.

Contra Costa County, 2003. Draft Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions, SCH# 2002102057. November 2003.
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4.2 Agriculture and Forestry Resources
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Agriculture and Forestry Resources
In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the State’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:
a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland), as
shown on the maps prepared pursuant to the Farmland
Mapping and Monitoring Program of the California
Resources Agency, to non-agricultural use?

b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? 
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code
Section 12220(g)), timberland (as defined by Public
Resources Code Section 4526), or timberland zoned
Timberland Production (as defined by Government Code
Section 51104(g))?

d) Result in the loss of forest land or conversion of
forest land to non-forest use? 
e) Involve other changes in the existing environment
which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or
conversion of forest land to non-forest use?

Setting
The project site and its surroundings are zoned for “Open Space”, and has no history of agricultural uses (Richmond, 2012). Richmond sanitary service operations initiated within the area that is now the WCCSL in the early 1950s on previously undeveloped land.

Evaluation
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program (FMMP) of the California Resources Agency, to nonagricultural use?) 930

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No Impact. The project site is located entirely within an area of and surrounded by industrial, commercial and open space uses. The site is not identified as Prime Farmland, Unique Farmland, or Farmland of Statewide or Local Importance by the FMMP, but is designated as Other Land, and is surrounded by lands designated as Urban Land and Other Land. The proposed project would have no impact on important farmland. (DLRP, 2012)
b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? No Impact. The project site and its surroundings are zoned for “Open Space”, and has no history of agricultural uses (Richmond, 2012). Also, the site is not covered by a Williamson Act contract (DLRP, 2012) Therefore, the proposed project would have no impact regarding existing agricultural zoning or a Williamson Act contract. c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))?
No Impact. The proposed project site is not zoned as forest land or timberland, and there are no forests on the project site. No impact would occur with implementation of the proposed project.
d, e) Result in the loss of forest land or conversion of forest land to non-forest use? Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to non-forest use?
No Impact. As stated above, the proposed project is not zoned as forest land and there are no forests on the project site. The project would not result in the loss of forest land or conversion of forest land to non-forest uses, and would have no impact.

Also, the project would be constructed and operated entirely within a previously developed area within the WCCSL that is designated as Other Land by the FMMP. The project site does not contain farmland or forest land and there are no aspects of the project that would affect any agricultural land or forest land off-site. Therefore, the proposed project would not result in conversion of farmland or forest land, on-site or offsite, to a non-agricultural use or non-forest use. The project would have no impact.

References
California Department of Conservation, Division of Land Resource Protection (DLRP), 2012.

Contra Costa County Williamson Act FY 2012/2013. Available at:
ftp://ftp.consrv.ca.gov/pub/dlrp/wa/. Accessed May 12, 2022. 931

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DLRP, 2014. Farmland Mapping and Monitoring Program. Contra Costa County Important Farmland Available at: www.conservation.ca.gov/dlrp/FMMP/Pages/Index.aspx. Accessed May 12, 2022.

City of Richmond, 2012. Richmond General Plan 2030: Land Use Element. April 25, 2012. 932

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4.3 Air Quality
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Air Quality
Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations.

Would the project:
a) Conflict with or obstruct implementation of the
applicable air quality plan?

b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or State ambient air quality standard?

c) Expose sensitive receptors to substantial pollutant
concentrations? 
d) Result in other emissions (such as those leading to
odors or) adversely affecting a substantial number of
people?

Setting
The project site is located in Contra Costa County, which is in the San Francisco Bay Area Air Basin (SFBAAB), within the jurisdiction of the Bay Area Air Quality Management District (BAAQMD). The SFBAAB is currently designated as a nonattainment area for state and national ozone standards and national particulate matter ambient air quality standards. Development projects can contribute to a region’s adverse air quality impacts on a cumulative basis so the BAAQMD considered the emission levels for which a project’s individual emissions would be cumulatively considerable when developing thresholds of significance for air pollutants. The significance thresholds used for project construction and operational impact analyses are based on thresholds set in the BAAQMD’s CEQA Guidelines (BAAQMD 2017b).

For the purposes of this air quality analysis, sensitive receptors are defined as facilities and land uses that include members of the population that are particularly sensitive to the effects of air pollutants, such as children, the elderly, and people with illnesses. Examples of these types of uses include schools, hospitals, and daycare centers. Residential areas are also considered sensitive to poor air quality because these sensitive individuals could be present there, and people usually stay home for extended periods of time, which results in greater exposure to ambient air quality. There are no sensitive receptors within 1,000 feet of the project site. The nearest sensitive receptors to the project site are residences at generally West Gertrude Avenue/Malcolm Drive (approximately 0.75 miles southeast), Verde Elementary School at 2000 Giaramita Street (approximately 1.1 miles southeast), and Contra Costa Health Clinic at 1501 Fred Jackson Way (approximately 1.2 miles southeast).
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Evaluation
a) Conflict with or obstruct implementation of the applicable air quality plan? Less than Significant Impact. BAAQMD is the regional air quality authority in the project area. Primary goals of BAAQMD’s adopted 2017 Clean Air Plan are to protect public health by achieving attainment of air quality standards (BAAQMD, 2017a). The plan includes a wide range of proposed control measures, which consist of actions to reduce the non-attainment pollutants: state and federal 8-hour ozone standard, the state 1- hour ozone standard, the state PM10 standard, and the state and federal PM2.5 standards.

BAAQMD guidance states that “if approval of a project would not result in significant and unavoidable air quality impacts, after the application of all feasible mitigation, the project would be considered consistent with the Clean Air Plan” (BAAQMD 2017b). As indicated in the discussion of criteria “b” and “c” below, the project would not result in significant air quality impacts. Therefore, this impact would less than significant. b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
Construction
Emissions from the construction phase of the project would be generated primarily from heavy duty equipment such as excavators, cranes, and forklifts. Criteria air pollutant emissions from equipment and on-road vehicle exhaust were estimated using CalEEMod (version 2020.4.02022.1); modeling output files are included in Appendix A to this checklist. Construction is assumed to take place over an eight-month period. Project specific data for construction phasing schedule and equipment fleet provided by the Project Applicant was used in the model to estimate emissions for the construction period. The total emissions (without mitigation) generated over the duration of construction were divided by the number of construction days for each partial construction year to determine average annual daily emissions from construction. Emissions from equipment and vehicle exhaust are presented in Table 4.3-1. As shown in the table, emissions of reactive organic gases (ROG) and nitrogen oxides (NOx), which are ozone precursors, and particulate matter (PM10 and PM2.5) would all be below their respective significance thresholds, which for construction have been established by BAAQMD in terms of average annual daily emissions.
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TABLE 4.3-1

AVERAGE DAILY CONSTRUCTION-RELATED CRITERIA POLLUTANT EMISSIONS (TONS PER YEARPOUNDS PER DAY) WITHOUT MITIGATION
Project Average Daily
Construction Emissions by Year ROG NOx Exhaust PM10 Exhaust PM2.5 20222023 3.330.11 16.671.00 0.770.04 0.700.04
20232024 0.130.06 1.140.48 0.050.02 0.040.02
BAAQMD Threshold for Significant
Construction Impacts 1054 1054 1582 1054
Potential Significant Impact? No No No No
NOTES: Construction emissions were revised to account for the one-year construction schedule delay. The BAAQMD significance thresholds for pounds-per-day (rather than tons-per-year) now apply.

SOURCE: ESARamboll (Appendix A to this documentchecklist) Operations
After the project is built, operational emissions, including stationary, mobile, and area sources, are anticipated to occur continuously throughout the project’s lifetime. The project is anticipated to begin operations in 20232024.

The Project Applicant has submitted an air permit application that includes multiple stationary sources, shown in Table 4.3-2. According to the applicant’s air permit application, the majority of emissions would be generated from the biogas engine combustion process, where the engines emit exhaust that heats up a green waste rotary drier. The biogas engines are included in the list of proposed permitted sources, along with a green waste storage pile of up to 200 tons, a sheltered storage of limestone pellets that would be used as a co-feed to the feedstock needed to reduce acid gas formation in the system process, a diesel-fired fire pump engine, as well as a flare that is a backup for the evacuation or venting of organic syngas or on rare occasion vent hydrogen product.

Fugitive emissions from piping components such as valves and pumps are also anticipated. Cooling towers, pressure storage tanks, raw water storage tanks, treated water storage tanks, bisulfite storage tanks, anti-scalant storage tanks, and condensate recovery tanks are exempt from the permit requirement under BAAQMD Regulation 2, Rule 1 (BAAQMD 2017c), as described in the permit application. Table 4.3-3 shows the anticipated emissions from the permitted sources. The air quality analysis prepared for the IS/MND is based on protocols used for the emissions analysis under review by the BAAQMD as part of the Authority to Construct (ATC) permit application.

This replacement would result in a lower emissions profile in contrast to current operations at the facility using the existing engine. The project is alsoFor a given volume of LFG combusted, NOx emissions would be reduced by 81 percent and CO emissions would be reduced by 53 to 62 percent. The WCCSL engines remain active, permitted sources, but have not been used recently due to disrepair. This results in the majority of LFG produced being flared. The Project is therefore expected to increase the functional use of landfill-produced biogas, thereby reducing the amount of organic gas sent to a flare 936

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for venting or evacuation and ultimately reducing the flare-based emissions. The reduction in flaring emissions has been quantified below.

Notably, the project would replace anthree (3) existing WCCSL biogas-fired engines with three (3) newer, lower emitting, and more efficient Waukesha or Jenbacher engines, equipped with state-of-the-art air emissions controls, including Selective Catalytic Reduction (SCR) and oxidation catalyst, which represent BACT for this type of equipment. This replacement would result in a lower emissions profile in contrast to operating the facility using the existing engine. The project is also For a given volume of LFG combusted, NOx emissions would be reduced by 81 percent and CO emissions would be reduced by 53 percent to 62 percent. The WCCSL engines remain active, permitted sources, but have not been used recently due to disrepair. This results in the majority of LFG produced being flared. The project is therefore expected to increase the functional use of landfill-produced biogas, thereby reducing the amount of organic gas sent to a flare for venting or evacuation and ultimately reducing the flare-based emissions.

Operational-related mobile source activities, such as employee commuting, truck trips for delivery and materials hauling, use of landscape equipment, and other sources would generate emissions of criteria air pollutants, their precursors, and toxic air contaminants (TACs). Area sources generally include fuel combustion from space and water heating, landscape maintenance equipment, and fireplaces/stoves, evaporative emissions from architectural coatings, and consumer products. Although these sources are not regulated under the BAAQMD’s air permitting program, Table 4.3-4 shows the emissions from operational emission sources as background considered with the project emissionssources that are not part of the air permit application.

TABLE 4.3-2

PROCESS OPERATIONS AIR PERMIT APPLICATION'S AVERAGE ANNUAL OPERATIONAL CRITERIA

POLLUTANT EMISSIONS
(TONS PER YEAR)
Project Operations
Emissions by Source CO NOx VOC/ROG SO2 PM10 PM2.5
Biogas engines 50.69 7.19 5.70 6.83 6.63 5.13 5.13
Green waste off gas N/A N/A 2.38 N/A N/A N/A
Fugitive component leaks N/A N/A 0.63 N/A N/A N/A
Limestone handling N/A N/A N/A N/A 0.003 0.0005
Limestone storage N/A N/A N/A N/A 0.016 0.0024
Flare 0.092 0.16 0.0098 0.0002 0.0086 0.0086
Fire pump engine 0.055 0.04 0.0022 0.00009 0.0033 0.0033 Total 50.84 7.39 8.72 7.47 6.64 5.16 5.14
NOTES: Operational emissions were revised to align with the more detailed project information from the Project Applicant.

SOURCE: Ramboll Permit Application (Raven, 2022aAppendix A to this document) 937

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TABLE 4.3-3

CALEEMODAUXILIARY OPERATIONS AVERAGE ANNUAL OPERATIONAL-RELATED CRITERIA

POLLUTANT EMISSIONS
(TONS PER YEAR)
Project Operations Emissions
by Category ROG NOx Exhaust PM10 Exhaust PM2.5
Area 0.18 0 0 0
Energy <0.01 0.05 <0.01 <0.01
Mobile 0.03 0.14 2.3 0.16 0.16 <0.01 0.07 <0.01
Mobile – Road Dust 0 0 0.14 0.02
Off-road 0.15 1.45 0.05 0.04
Waste N/A N/A 0 0
Water N/A N/A 0 0
Total 0.18 0.47 3.75 1.66 0.35 0.05 0.13 0.05
NOTES: Operational mobile emissions were revised to align with the more detailed project information from the Project Applicant.

SOURCE: ESA and Ramboll (Appendix A to this documentchecklist) TABLE 4.3-4

AVERAGE ANNUAL OPERATIONAL- RELATED CRITERIA POLLUTANT EMISSIONS (TONS PER YEAR)
Project Operations Emissions NOx VOC/ROG Exhaust PM10 Exhaust PM2.5 Air PermitProcess Operations 7.39 7.47 8.72 5.16 5.14
CalEEModAuxiliary Operations 3.75 1.66 0.18 0.47 0.35 0.05 0.13 0.05 Reduction in Flared Landfill Gas 15.83 8.71 0.10 -0.19 3.35 6.09 3.35 -6.09 Overall Total 9.05

2.43 9.19

7.55 5.21

2.16 5.19

1.92 BAAQMD Threshold for Significant
Operational Impacts 10 10 15 10
Potential Significant Impact? No No No No
NOTES: Operational mobile emissions were revised to align with more detailed project information from the Project Applicant.

Source: ESA and Ramboll (Appendix A to this documentchecklist) and Ramboll Permit Application (Raven, 2022a) 938

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TABLE 4.3-5

AVERAGE DAILY OPERATIONAL- RELATED CRITERIA POLLUTANT EMISSIONS (POUNDS PER DAY)
Project Operations Emissions NOx VOC/ROG PM10 PM2.5
Process Operations 40.49 40.94 28.27 28.16
Auxiliary Operations 20.55 0.99 1.92 0.72
Reduction in Flared Landfill Gas -47.70 -0.57 -18.35 -18.35 Overall Total 13.34 41.36 11.85 10.54
BAAQMD Threshold for Significant
Operational Impacts 54 54 82 54
Potential Significant Impact? No No No No
NOTES: Operational mobile emissions were revised to align with more detailed project information from the Project Applicant.

SOURCE: ESA and Ramboll (see Appendix A to this document) Table 4.3-4 and Table 4.3-5 present the facility total annual operational emissions and their comparison to BAAQMD thresholds of significance for operations. These tables show that on a project-level assessment, emissions do not exceed significantsignificance thresholds determined by BAAQMD under CEQA for criteria pollutants emitted during operations, and therefore would result in are less than significant impacts.

Construction Air Emissions
Less than Significant Impact. Construction activities would result in emissions of the following non-attainment pollutants: reactive organic gases (ROG) and nitrogen oxides (NOx), which are ozone precursors, and particulate matter (PM10 and PM2.5). These pollutant emissions would be generated in the form of fugitive dust (PM10 and PM2.5) and in the form of exhaust by construction equipment, on-road vehicle trips of haul trucks for delivering construction material, water trucks for site dust control, and construction worker commutes to and from the project site.

Construction Dust
Less than Significant Impact, after Mitigation. Activities that generate dust include excavation and equipment movement across unpaved construction sites. Dust can be an irritant causing watering eyes or irritation to the lungs, nose, and throat. Excavation, grading, and other construction activities can cause wind-blown dust that adds PM10 and PM2.5 to the local atmosphere. The BAAQMD has taken a qualitative approach to addressing fugitive dust emissions during construction, such that any project that implements the BAAQMD Basic Construction Mitigation Measures Recommended for All Projects (Best Management Practices) would not result in a significant impact with respect to fugitive dust (BAAQMD 2017b). Mitigation Measure AQ-1: Best Management Practices, provided below, specifies BAAQMD recommended measures and would apply to all individual projects to address construction dust. In conclusion, while air emissions 939

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from construction equipment are all below the BAAQMD CEQA thresholds construction dust emissions are always considered significant within the SFBAAB unless the mitigation measures below are applied.

Mitigation Measures
AQ-1: Best Management Practices.

All subsequent projects, regardless of size,The project shall implement the following best management practices to reduce construction impacts, particularly fugitive dust, to a less-than-significant level:
 All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day, except when not required for dust control.
 All haul trucks transporting soil, sand, or other loose material off-site shall be covered.
 All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.
 All vehicle speeds on unpaved roads shall be limited to 15 mph.  All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.
 Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations [CCR]). Clear signage shall be provided for construction workers at all access points.
 All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation.
 Post a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s phone number shall also be visible to ensure compliance with applicable regulations.  BMP #6: All excavation, grading, and/or demolition activities shall be suspended when average wind speeds exceed 20 mph.
 BMP #7: All trucks and equipment, including their tires, shall be washed off prior to leaving the site.
 BMP #8: Unpaved roads providing access to sites located 100 feet or further from a paved road shall be treated with a 6- to 12-inch layer of compacted layer of wood chips, mulch, or gravel.
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 Additional BMP: Limit the simultaneous occurrence of excavation, grading, and ground- disturbing construction activities.
 Additional BMP: Install wind breaks (e.g., trees, fences) on the windward side(s) of actively disturbed areas of construction. Wind breaks should have at maximum 50 percent air porosity.
 Additional BMP: Plant vegetative ground cover (e.g., fast-germinating native grass seed) in disturbed areas as soon as possible and watered appropriately until vegetation is established.
 Additional BMP: Install sandbags or other erosion control measures to prevent silt runoff to public roadways from sites with a slope greater than one percent.
 Additional BMP: Minimize the amount of excavated material or waste materials stored at the site.
 Additional BMP: Hydroseed or apply non-toxic soil stabilizers to construction areas, including previously graded areas, that are inactive for at least 10 calendar days.
 Require zero visible fugitive dust and use fence line air monitoring to demonstrate compliance with this requirement.
 Set requirements for when dust generating operations have to be shut down due to dust crossing the property boundary or if dust is contained within the property boundary but not controlled after a specified number of minutes.  Prohibiting grading on days when a Spare the Air is in effect (https://www.sparetheair.org/) Prohibiting grading on days with an Air Quality Index forecast of greater than 100 for particulates for the project area.16
Operational Air Emissions
Less than Significant Impact. Based on the operational emissions modelled and summarized in Table 4.3-4 and Table 4.3-5 above, activitiesrelated to operating the bioenergy system would all be below significance thresholds. Appendix A contains additional analyses and emissions numbers in support of this conclusion. c) Expose sensitive receptors to substantial pollutant concentrations? Construction
Less than Significant Impact. Construction equipment and associated heavy-duty truck traffic generate diesel exhaust, which is a known TAC. Construction exhaust emissions may pose health risks for sensitive receptors. However, there are no sensitive receptors nearby the project site, which is zoned for open space uses. The nearest sensitive receptors are 0.75 miles southeast, or more than 1,000 feet, which is the distance considered in the BAAQMD CEQA Guidelines. Therefore, any concentrations of diesel 16 The additional bulleted items to Mitigation Measure AQ-1 (formatted as single underline since they are not updates proposed in this updated IS/MND) were added as expanded mitigation at the Planning Commission. 941

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particular matter (DPM) generated during construction would be less than significant.

Although the nearest sensitive receptor is located further than the 1,000 distance, Raven conducted a Health Risk Assessment (HRA) to quantify construction-related emissions and associated health risks due to DPM exposure during construction. The results of this analysis are presented in Appendix A. Even though an HRA was not required based on adopted thresholds, the HRA demonstrates that health impacts are below significance thresholds, and the project would result in a less than significant impact during construction.

Operations
Less than Significant Impact. The proposed project would introduce new sources of TAC emissions, including the biogas engines and a new flare. Sources have been assumed to operate on a continuous basis at their maximum rated capacity, when determining emissions. The proposed project would also introduce a new source of DPM and PM2.5 emissions due to the installation of an emergencybackup firepump diesel enginegenerator at the centralized treatment facility that would use California Air Resources Board (CARB)- certified diesel fuel. Emergency generators would be subject to BAAQMD permit requirements, which would ensure that operation of these generators would not significantly impact nearby receptors. These activities would result in minimal TAC emissions for emergency operations only (typically less than 50 hours per year), and therefore have negligible associated health risks to existing sensitive receptors in the area, the nearest being 0.75 miles from the project site. Other annual TAC concentrations from non-emergency operations of the generator were estimated in an annual emissions summary for operations at the project site (Raven, 2022a). An HRA was not conducted due to there not being any sensitive receptors within 1,000 feet of the project site and trigger levels not applying to the project. There would also be a rubber-tired loader associated with operations that would run 24 hours a day 7 days a week. Emissions from the loader were calculated using CalEEMod and included in the operational emissions, shown in Table 4.3-4. Reduced TAC emissions due to the reduction in flaring of landfill gas at the existing WCCSL flare were also quantified and included in this analysis.

An HRA was conducted to quantify impacts from construction and operational sources.

The HRA uses EPA’s AERMOD model, version 22112, to model hourly and annual average TAC and PM2.5 concentrations at nearby receptors. Modeling inputs, including emission rates in grams of pollutant emitted per second, and source characteristics (e.g., release height, stack diameter, plume width) were based on data provided by the Project Applicant, and all exposure parameters and the overall risk calculation methodology are consistent with guidance provided by OEHHA and BAAQMD. The results of this analysis are included in Appendix A and are presented in Table 4.3-6. The results in Table 4.3-6 demonstrates that health impacts associated with operational sources are below significance thresholds, including impacts due to toxic air contaminants released by the biogas engines.
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TABLE 4.3-6

HEALTH RISK IMPACTS AT THE MAXIMUM EXPOSED SENSITIVE RECEPTORS Risk Scenario / Receptor Type
Maximum
Cancer Risk
(per million)
Chronic
Hazard Index
Acute
Hazard
Index
PM2.5
concentration
(μg/m3)
Construction + Operations
Worker 3.0 0.058 0.22 0.57
Resident 0.70 0.0086 0.0039 0.024
School 0.49 0.011 0.036 0.030
Clinic 0.46 0.0058 0.032 0.016
Landfill Reductions
Worker -5.7 -0.21 -0.49 -0.84
Resident -1.3 -0.018 -0.10 -0.042
School -0.81 -0.019 -0.091 -0.044
Clinic -0.79 -0.011 -0.077 -0.026
Project Construction + Operations with Landfill Reductions Worker -2.7 -0.16 -0.27 -0.27
Resident -0.57 -0.009 -0.064 -0.018
School -0.32 -0.0084 -0.055 -0.014
Clinic -0.33 -0.0056 -0.045 -0.010
BAAQMD Threshold of Significance 10.0 1.0 1.0 0.3
Exceeds Significance Threshold? Yes No No No
NOTES: Numbers may not appear to sum correctly due to rounding.

SOURCE: Ramboll (Appendix A to this document)
The HRA also evaluated health impacts at Verde Elementary School (1.1 miles from the Project site) and at the Contra Costa Health Clinic (1.2 miles from the Project site). The results are also presented in Table 4.3-6 and documented in Appendix A. As shown in Table 4.3-6, health impacts due to toxic air contaminants at each location are below significance thresholds.

The HRA concluded that the project provides an overall reduction of cancer risk, chronic hazard index, acute hazard index, and particulate matter concentrations as compared to the portions of the existing landfill flare operation it would be replacing.

Cumulative Impact
Cumulative community risk impacts were addressed through an evaluation of TAC sources located within 1,000 feet of the sensitive receptors. These sourcesinclude freeways or highways, busy surface streets, and stationary sources identified by BAAQMD. For local roadways, BAAQMD has provided the Roadway Screening Analysis Calculator to assess whether roadways with traffic volumes of over 10,000 vehicles per day may have a potentially significant effect on a proposed Project (BAAQMD, 2015). These estimated 943

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health impacts were added to the total project health impacts and are presented in Table

4.3-7 and Appendix A. The screening calculator does not provide estimates of chronic HI because chronic HI is expected to be minor for traffic sources. Therefore, the impact from vehicles on chronic HI is not included in the cumulative analysis. 944

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TABLE 4.3-7

CUMULATIVE HEALTH RISK IMPACTS AT THE MAXIMUM EXPOSED SENSITIVE RECEPTORS Receptor Type / Risk Scenario
Maximum
Cancer Risk
(per million)
Hazard Index
PM2.5
concentration
(μg/m3)
Worker
Existing Stationary Source Risk 45.0 0.52 1.02
Existing Roadway Source Risk 1.8 -- 0.04
Existing Railway Source Risk 3.7 -- 0.0049
Project Risk
(Construction + Operations + Landfill Reductions)
-2.7 -0.16 -0.272
Total (Project Risk + Exiting Risk) 47.6 0.36 0.797
BAAQMD Cumulative Threshold of Significance 100.0 10.0 0.8 Exceeds Significance Threshold? No No No
Resident
Existing Stationary Source Risk 0.0041 4.70E-05 0.001
Existing Roadway Source Risk 6.6 -- 0.19
Existing Railway Source Risk 4.3 -- 0.0059
Project Risk
(Construction + Operations + Landfill Reductions)
-0.57 -0.009 -0.018
Total (Project Risk + Exiting Risk) 10 -0.009 0.18
BAAQMD Cumulative Threshold of Significance 100.0 10.0 0.8 Exceeds Significance Threshold? No No No
School
Existing Stationary Source Risk 7.10E-05 8.20E-07 1.80E-05 Existing Roadway Source Risk 3.2 -- 0.074
Existing Railway Source Risk 15 -- 0.02
Project Risk
(Construction + Operations + Landfill Reductions)
-0.32 -0.008 -0.014
Total (Project Risk + Exiting Risk) 18 -0.0084 0.08
BAAQMD Cumulative Threshold of Significance 100.0 10.0 0.8 Exceeds Significance Threshold? No No No
Clinic
Existing Stationary Source Risk 5.70E-05 6.60E-07 1.40E-05 Existing Roadway Source Risk 2.8 -- 0.067
Existing Railway Source Risk 5.6 -- 0.0077
Project Risk
(Construction + Operations + Landfill Reductions)
-0.33 -0.006 -0.01
Total (Project Risk + Exiting Risk) 8.1 -0.0056 0.065
BAAQMD Cumulative Threshold of Significance 100.0 10.0 0.8 Exceeds Significance Threshold? No No No
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NOTE: The BAAQMD tool for calculating chronic hazard index does not include risk from railways or roadways. Therefore, cumulative chronic hazard index for the resident, school, and clinic receptors would likely not be negative; however the project presents an overall reduction in chronic risk to the existing conditions.

SOURCE: Ramboll (Appendix A to this document)
Table 4.3-7 reports both the project and cumulative community risk impacts. The cumulative cancer risk, hazard indexes, and PM2.5 concentrations would not exceed their cumulative source thresholds and the project presents an overall reduction risk to the existing conditions. Thus, a less-than-significant cumulative impact would occur during construction and operation of the proposed project.
d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Less than Significant Impact. Existing uses on and near the WCCSL include operations that are among typical odor sources of concern. These include wastewater treatment plants, sanitary landfills, transfer stations, composting facilities, petroleum refineries, chemical manufacturing facilities, and auto body shops. As a hydrogen production facility, the project would include organic feedstock processed during operations at the WCCSL, which is known to create odors. WCCSL implements various control measures to minimize odors associated with operation of the mixed waste processing.

The nearest sensitive receptors to the project site are residences at generally West Gertrude Avenue/Malcolm Drive, approximately 0.75 miles southeast. This is closer than the 1.0-mile odor screening distance for greenwaste handling established in the BAAQMD’s CEQA Guidelines. Also, an elementary school and a health clinic exist approximately 1.1 and 1.2 miles, respectively, from the project site - slightly beyond the screening distance. Uses between the project site and these the nearest sensitive receptors to the southeast include the West County Wastewater District Treatment Plant, EBMUD’s North Richmond Water Reclamation Plant, the Richmond Sanitary District, and other refuse services, automobile repair and towing businesses, and lawn services, etc. Topography in the area is relative flat, and no substantial areas of vegetation exist.

The prevailing wind direction in this area for the majority of the year (February through November) is from the south, blowing away from area of sensitive receptors. This prevailing wind direction shifts to the north, blowing toward the sensitive receptor area, for approximately two months of the year (December and January).

Nuisance odor from Raven is unlikely since based upon the initial process step of subjecting the feedstock material would only be on the feedstock management area floor for relatively short periods of time. to drying given the project procedures and requirements outlined below. Nor would the system’s tail gas or the infrequent use of the as-needed flare generate noticeable odor. Also, other than the input of organic feedstock within the system, the process would not involve the storage or processing of other potentially odorous materials nor contribute to odor from nearby existing WCCSL activities.
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The Raven SR Project introduces a number of odor minimization procedures and compliance with regulatory requirements. First, it is important to note that the feedstock for the Raven process will only include pre-processed material consisting primarily of blended green waste and food waste. The source of the material will be from the onsite composting facility referred to as OMPF. The OMPF receives vehicle loads directly from residential and commercial organics collection programs. The OMPF operating procedures include initial visual screening and a load checking program designed to identify and remove prohibited material including any highly odorous loads. After screening and load checking, remaining organic material will be pre-processed by grinding. Only material that has been through the screening, load checking and grinding process at the OMPF will be delivered to the Raven SR facility, thus minimizing the potential for receiving prohibited or highly odorous material. In addition, all incoming pre-processed feedstock received at the Raven SR facility will also be subject to the Raven SR’s own screening and load checking program as required by State solid waste facility regulations.

To further minimize potential odor impacts, the Raven SR facility standard operating procedures will include a “first in first out protocol” for the processing of material.

Typically, any material received will be processed within 24 hours of receipt through the hydrogen conversion system. As a requirement of both the CUP and the Solid Waste Facility Permit (SWFP) for the facility all feedstock material shall, at a maximum, be processed within 48 hours of receipt (draft Condition of Approval #48).

Regardless, as described in Section 2, Project Description¸ the project would involve odor control mechanisms to minimize possible additional odors from its operation. TheIn addition, the proposed industrial metal canopy would be placed over the feedstock floor and infeed equipment to prevent stormwater contact. The project may incorporate control measures similar to those current employed by WCCSL, such as ensuring the input of feedstock into the system within a designated period of time from receiving it from WCCSL’s onsite organic material processing facility to prevent potential odor buildup; The project will also include routine cleaning of floors, walls, and equipment; and use of odor suppressants as deemed necessary. Odor control would be added to the management area if objectionable odors occur. The Raven facility could also store topical treatment solutions (non-toxic and biodegradable) onsite, which would be applied to neutralize odors if an immediate need arises. To the extent that any new sources of odor is attributable to the proposed project, the Pproject Aapplicant shall promptly log and respond to any complaints and work to remediated.

The CUP and SWFP impose additional odor minimization provisions and requirements on facility operations. These include but are not limited to:
 Maximum Daily Quantities – 99.9 tons per day
 Maximum Storage Capacity – 200 tons
 Daily facility cleaning
 Compliance with state minimum standards under solid waste provisions 947

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contained in Title 14 and Title 27 including Nuisance Control and odor compliant response and reporting requirements
 Cooperation with Bay Area Air Quality Management District (BAAQMD), the City and the County, to identify and implement measures to minimize odor emissions through the development and implementation of an Odor Prevention and Management Plan (OPMP) (draft Condition of Approval #77), which will require an Annual Evaluation Report. This includes the following minimum measures:
o feedstock load checking at the Republic site for identification and removal of prohibited material including any highly-odorous loads; o feedstock pre-processing at the Republic site before being sent to the Raven facility;
o operations protocol for first in/first out feedstock consumption; o feedstock will typically be processed within 24 hours with a maximum limit within 48 hours of receipt; v) daily cleaning of the feedstock handling area; and
o use of odor suppressants if necessary.

Therefore, any odor impacts from the proposed project would not be considered substantial nor likelysignificant and the Raven SR Project will not contribute substantiallysignificant odor emissions to any existing odor sources of the WCCSL. The impact would be less than significant.

References
BAAQMD, 2017a. Clean Air Plan, Spare the Air, Cool the Climate. April 19, 2017. Available at https://www.baaqmd.gov/~/media/files/planning-and-research/plans/2017-clean-airplan/attachment-a_-proposed-final-cap-vol-1-pdf.pdf?la=en. Accessed December 2020.

BAAQMD, 2017b. CEQA Air Quality Guidelines. Available online:
https://www.baaqmd.gov/~/media/files/planning-andresearch/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en. Accessed April 22, 2022.

BAAQMD, 2017c. Regulations 2 Permits Rule 1 General Requirements. Available online:
https://www.baaqmd.gov/~/media/dotgov/files/rules/regulation-2-rule1/documents/20171206_fr_0201- pdf.pdf?la=en&rev=42c6de7702484ea58dfcbcecaeafa29f. Accessed May 1, 2022.

RAVEN, 2022a Air Permit Application-Bioenergy Facility. Prepared by Ramboll US Consulting, Inc., (Ramboll) for Raven SR, April 2022.
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4.4 Biological Resources
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Biological Resources
Would the project:
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or United States Fish and Wildlife Service?

b) Have a substantial adverse effect on any riparian
habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of Fish and Wildlife or United
States Fish and Wildlife Service?

c) Have a substantial adverse effect on State or
federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?

d) Interfere substantially with the movement of any
native resident or migratory fish or wildlife species or with established native resident or migratory wildlife
corridors, or impede the use of wildlife nursery sites? 
e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?

f) Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat
conservation plan?

Setting
The project site is located in the upland area of the approximately 340-acre WCCSL, within the context of expansive grasslands and hills. The WCCSL borders San Pablo Bay and tidal marshland of naturalized portions of San Pablo and Wildcat creeks. The broader surrounding area of the WCCSL property is a low density industrial and open space area.

The local context in Figure 1-2 shows the project site located approximately 0.25-mile east of the San Pablo Bay shoreline, mudflats, and open water. The tidal marshland of San Pablo Creek is approximately 0.3 miles north/northeast of the project site, bordering the WCCSL north boundary which is an elevated levee. As shown in Figure 2-0, the marshlands of Wildcat Creek sit 950

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approximately 280 feet south/southeast of the project site, bordering the WCCSL south boundary, which is also an elevated levee. A closed Class I landfill is immediately north of the project site and the main access road supports a cover of non-native grassland and ruderal vegetation species.

No trees exist on the project site. Several landscape trees occur at the Golden Bear Waste Recycling Facility (part of the BMPC), located approximately 300 feet southwest of the project site.

Biological resources were characterized through the review and compilation of existing information and a biological reconnaissance survey conducted by ESA biologists on June 29, 2022. The biological reconnaissance study area included the project construction area plus an additional 250-foot buffer, to account for potential indirect impacts to special-status species. The study area for special-status plant species includes the project construction area, plus an additional 10-foot buffer due to the lack of potential for indirect impacts to plants. No detailed surveys were conducted for special-status plants or wildlife or are deemed necessary based on the developed and manipulated conditions of the project site and surroundings, the scope of the proposed project’s construction and operations, and the proposed standard methods to minimize disturbance to sensitive resources in the vicinity.

Species / Habitats
The uplands of the WCCSL are either devoid of vegetation from on-going landfill operations and roadways, or are dominated by nonnative grasses and forbs. Plant species observed in the grassland at the periphery of the project site are dominated by non-native species such as Italian rye grass (Festuca perennis), wild oats (Avena spp.), storksbill (Erodium cicutarium), bristly oxtongue (Helminthotheca echioides), and ribwort (Plantago lanceolata). Several weedy species are also present along the margins of the site, including fennel (Foeniculum vulgare), wild radish (Raphanus spp.), black mustard (Brassica nigra), curly dock (Rumex crispus), prickly lettuce (Lactuca serriola), and iceplant (Carpobrotus edulis). Clumps of native coyote brush (Baccharis pilularis) are scattered through grasslands, road margins, and upper edge of the marshlands and levees.

While the highly disturbed project site provides little habitat that is suitable for special-status plants and wildlife, the surrounding grasslands and wetlands provide habitat for a variety of wildlife and plant species. Wildlife observed in the surrounding study area during the site reconnaissance survey include American crow (Corvus brachyrhynchos), red-tailed hawk (Buteo jamaicensis), western bluebird (Sialia mexicana), barn swallow (Hirundo rustica), common raven (Corvus corax), Canada goose (Branta canadensis), wild turkey (Meleagris gallopavo), blacknecked stilt (Himantopus mexicanus), turkey vulture (Cathartes aura), mallards (Anas platyrhynchos), killdeer (Charadrius vociferus), and several gull species (Larus spp.).

Sensitive aquatic habitats occur outside of the project boundary, and include wetlands, sloughs, creek channels, and the San Pablo Bay shoreline. San Pablo Creek is located approximately 600 feet east/northeast of the project site and is separated from WCCSL developed areas by a levee.

San Pablo Creek is tidally influenced and flows into the San Francisco Bay after flowing through San Pablo Creek Marsh. Emergent salt marsh vegetation occurs approximately 280 feet south/southwest of the project site within Wildcat Marsh, 0.3 miles north/northeast of the project 951

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site. Numerous shorebirds, waterfowl, and other wildlife use the marsh and mudflats for foraging and resting; however, the marsh is beyond the 250-foot project study area.

A number of special-status animal species have been reported from nearby creeks and marshes, including the state and federally-endangered salt marsh harvest mouse (Reithrodontomys raviventris) and California Ridgway’s rail (Rallus longirostris obsoletus), state-threatened California black rail (Laterallus jamaicensis coturniculus), and several other species considered to be California Species of Special Concern and Fully Protected by the State. Appendix B presents the special-status species considered in the analysis, including each species’ legal or protective status, habitat requirements, and blooming period (for plants), and the potential for occurrence within study areas. Higher elevations of the marsh typically provide important refuge for small mammals and birds during storms and high tides. However, due to the extent of developed and otherwise disturbed habitat on the project site, the narrow band of cover along the levee slope, and the intensity of human activity, the project site is not expected to provide upland retreat habitat for wildlife species, including species associated with salt marsh and other wetland habitats.

Several special-status plant species are known from the uplands and coastal salt marsh habitats along the shoreline of San Francisco and San Pablo Bays, but none have been reported from the vicinity of the WCCSL. A single occurrence of fragrant fritillary (Fritillaria liliacea) was reported from the Point Richmond area in 1900, but this occurrence is believed to have been extirpated by development, and suitable habitat is absent on the site. Other special-status plant species known from marshland habitat along the shoreline of San Pablo Bay include: the State rare soft-haired bird’s beak (Chloropyron molle ssp. molle), Mason’s lilaeopsis (Lilaeopsis masonii), and San Francisco gumplant (Grindelia hirsutula var. maritima). These California Rare Plant Rank 1B species are considered rare under Section 13580 of the California Environmental Quality Act (CEQA) Guidelines. None have been reported from the WCCSL, and suitable habitat is absent on portions of the site proposed for improvements.

Wetlands
No wetlands or other aquatic resources occur within the project site. Jurisdictional wetlands and unvegetated waters extend over the northern coastal salt marsh, open water habitat, and San Pablo Creek channel. The sloughs, creek channel, and bay shoreline which border the WCCSL property are all under tidal influence. The upland portions of the WCCSL property do not support wetlands, and the engineered basins designed for runoff control and leachate treatment, including basins located to the south and west of the project site, are exempt from state and federal wetland jurisdiction.

Evaluation
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or United States Fish and Wildlife Service?
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A list of special-status species that occur in the project region was identified based upon review of existing information, including queries of the California Natural Diversity Database (CNDDB), U.S. Fish and Wildlife Service (USFWS) Official Species List, and the California Native Plant Society (CNPS). Habitats at the project area were assessed for their potential to support special-status species using information about local species occurrences and species’ habitat requirements, in combination with the site visit described above (Appendix B).

Plants
No special-status plant species are expected to occur on the disturbed project site. Site preparation for the project would involve minimal grading for the erection of the modular building and the replacement of existing compacted soil, ruderal groundcover and partially paved areas where special-status plants are not expected to occur. Hence, no impacts would occur to special-status plants.

Wildlife
The project site exists within a previously disturbed upland portion of the WCCSL that does not provide habitat for special-status wildlife species. Due to the extent of past development, no special-status wildlife species are expected to occur within the project site. Additionally, basins and runoff control ponds located to the south and west of the project site do not provide suitable habitat for special-status species.

Beyond the site boundaries,Ssurrounding wetland and annual grassland habitat may provide habitat for special-status wildlife species. The following species are considered to have the potential to occur within these areas: short-eared owl (Asio flammeus), western burrowing owl (Athene cunicularia hypugaea), northern harrier (Circus hudsonius), loggerhead shrike (Lanius ludovicianus), California black rail (Laterallus jamaicensis coturniculus), and California Ridgway’s rail (Rallus longirostris obsoletus). Short-eared owl, western burrowing owl, northern harrier, and loggerhead shrike are California Species of Special Concern. Uplands and wetlands outside of the project site provide potential foraging habitat for these species. Upland grassland and ruderal habitats provide potential nesting habitat. Short-eared owl and northern harrier are ground nesting species, while loggerhead shrikes nest in shrubs and occasionally items such as brush piles, generally between two and four feet off the ground. Western burrowing owls nest underground in burrows dug by mammals such as California ground squirrels (Otospermophilus beecheyi).

California Ridgway’s is listed as endangered under both the Federal Endangered Species Act (FESA) and the California Endangered Species Act (CESA), and is a state fullyprotected species. Ridgway’s rails are found in tidal and brackish marshes where they typically construct nests in or under dense marsh vegetation, such as marsh gumplant and pickleweed at an elevation high enough to avoid inundation during high tides. California black rail is listed as threatened under CESA and is a state fully-protected species. This species nests and forages in tidal emergent wetland. Suitable marsh habitat for both of 953

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these species is present within 500 feet of the project site and multiple occurrences are known from marshes adjacent to or nearby the project site.

In addition to the aforementioned special-status species, common raptors and other bird species may forage in uplands and marshes on the edges of the study area. While no trees exist on the project site, trees approximately 300 feet southwest of the project site at the Golden Bear Waste Recycling Facility have potential to support raptor nesting. Current activity on the project site involves large truck traffic, human activity, operation of machinery and elevated noise levels. Regardless, some bird species, such as killdeer (Charadrius vociferus) and American crow (Corvus brachyrhynchos), tend to be highly tolerant of human disturbance and may still nest in areas with relatively high levels of human activity.

Construction
Less than Significant Impact, after Mitigation. Bird species listed under FESA and CESA, as well as non-ESA-listed birds, are afforded conservation protections. Breeding birds are protected under California Fish and Game Code (FGC) Section 3503 and raptors are protected under Section 3503.5. In addition, FGC Section 3513 and the Federal MBTA (16 USC, Sec. 703 Supp. I, 1989) prohibit the killing, possession, or trading of migratory birds. Finally, FGC Section 3800 prohibits the taking of non-game birds, which are defined as birds occurring naturally in California that are not game birds or fully protected species. Impacts during the non-breeding season are not considered significant, primarily due to the birds’ mobility and ability to access other high-quality foraging habitat in the region. Also, the project site is disturbed and provides poor habitat for nesting birds. However, equipment staging and project construction could render the site and adjacent areas temporarily unsuitable for breeding birds due to the noise, vibration, and increased activity levels associated with grubbing, earth moving, heavy equipment operation, and increased human presence even when the nest itself is unaffected. These activities could cause birds that have established a nest prior to the start of construction to change their behavior or even abandon an active nest, putting eggs and nestlings at risk for mortality. This would be considered a significant impact.

Implementation of Mitigation Measure BIO-1: Avoid and Minimize Impacts to Nesting Birds, Except Rails, and Mitigation Measure BIO-2: Avoid and Minimize Impacts to California Black Rail and California Ridgway’s Rail would reduce potential constructionrelated impacts to nesting special-status birds to a less-than-significant level by requiring avoidance of construction-related work during the nesting bird season, or if avoidance of the nesting season is not possible, pre-construction nesting bird surveys and establishment of no-construction buffer zones around active bird nests. With implementation of Mitigation Measures BIO-1 and BIO-2, construction-related impacts would be less than significant.

Mitigation Measure BIO-1: Avoid and Minimize Impacts to Nesting Birds, Except Rails
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To the extent practicable, Pproject construction activities requiring heavy equipment, or any tree trimming, shall be performed outside of the bird nesting season (February 1st through August 31st) to avoid impacts to nesting birds. If these activities must be performed during the nesting bird season, a qualified biologist shall be retained to conduct a pre-construction survey in the project construction and staging areas for nesting birds and verify the presence or absence of nesting birds no more than 14 calendar days prior to construction activities or after any construction breaks of 14 calendar days or more. Surveys shall be performed for the project construction and staging areas and suitable habitat within 250 feet of the project construction and staging areas in order to locate any active passerine (perching bird) nests and within 500 feet of the project construction and staging areas to locate any active raptor (birds of prey) nest, including potential burrowing owl burrows. If nesting birds and raptors do not occur within 250 and 500 feet of the project area, respectively, then no further action is required if construction begins within 14 calendar days.

If active nests are located during the pre-construction bird nesting surveys, nodisturbance buffer zones shall be established around nests, with a buffer size established by the qualified biologist. Typically, these buffer distances are between 50 feet and 250 feet for passerines and between 150 feet and 500 feet for raptors. These distances may be adjusted depending on the level of surrounding ambient activity and if an obstruction, such as a building or structure, is within line-of-sight between the nest and construction. Reduced buffers may be allowed if a full-time qualified biologist is present to monitor the nest and has authority to halt construction if bird behavior indicates continued activities could lead to nest failure. Buffered zones shall be avoided during construction-related activities until young have fledged or the nest is otherwise abandoned. If active burrowing owl dens are found within the survey area, the Project Applicant shall implement measures at least equal to the 2012 (or subsequent applicable) CDFW Staff Report (CDFG, 2012), as determined by the qualified biologist.

Mitigation Measure BIO-2: Avoid and Minimize Impacts to California Black Rail and California Ridgway’s Rail
 To minimize or avoid the loss of individual California black rail and Ridgway’s rail, construction activities requiring heavy equipment, adjacent to tidal marsh areas (within 500 feet [150 meters] or a distance determined in coordination with U.S. Fish and Wildlife (USFWS) or the California Department of Fish and Wildlife (CDFW)), shall be avoided during the breeding season from February 1 through August 31.  If areas within 500 feet of rail habitat cannot be avoided during the breeding season (February 1 through August 31), protocol-level surveys shall be conducted to determine rail nesting locations. The surveys will focus on potential habitat that could be indirectly disturbed by construction activities during the breeding season to ensure that rails are not breeding within 500 feet of project activities.

Survey methods for rails will follow the Site-Specific Protocol for Monitoring Marsh Birds, which was developed for use by USFWS and partners (Wood et al. 2017).

Surveys are concentrated during the approximate period of peak detectability, January 15 to March 25 and are structured to efficiently sample an area in three 955

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rounds of surveys by broadcasting calls of target species during specific periods of each survey round. Call broadcast increase the probability of detection compared to passive surveys when no call broadcasting is employed. This protocol has since been adopted by Invasive Spartina Project (ISP) and Point Blue Conservation Science to survey Ridgway’s rails at sites throughout San Francisco Bay Estuary. The survey protocol for Ridgway’s rail is summarized below.
 Previously used survey locations (points) should be used when available to maintain consistency with past survey results. Adjacent points should be at least 200 meters apart along transects in or adjacent to areas representative of the marsh. Points should be located to minimize disturbances to marsh vegetation.

Up to 8 points can be located on a transect.
 At each transect, three surveys (rounds) are to be conducted, with the first round of surveys initiated between January 15 and February 6, the second round performed February 7 to February 28, and the third round March 1 to March 25.

Surveys should be spaced at least one week apart and the period between March 25 to April 15 can be used to complete surveys delayed by logistical or weather issues. A Federal Endangered Species Act Section 10(a)(1)(A) permit is required to conduct active surveys.
 Each point on a transect will be surveyed for 10 minutes each round. A recording of calls available from USFWS is broadcast at each point. The recording consists of 5 minutes of silence, followed by a 30-second recording of Ridgway’s rail vocalizations, followed by 30 seconds of silence, followed by a 30-second recording of California black rail, followed by 3.5 minutes of silence.  If no breeding Ridgway’s rails or black rails are detected during surveys, or if their breeding territories can be avoided by 500 feet (150 meters), then project activities may proceed at that location.
 If protocol surveys determine that breeding Ridgway’s rails or black rails are present in the project area, the following measures would apply to project activities conducted during their breeding season (February 1- August 31):
 The applicant shall coordinate with the USFWS- and CDFW, as appropriate depending upon species, to determine verify if project activities can continue during the nesting season based on nest location, natural visual barriers (e.g., levees) between the project and marshlands, and the distance between proposed activities and identified activity centers. If impact cannot be avoided during the rail nesting season, activities would be delayed until after the nesting season.

Operations
Less than Significant Impact. Current activity on the project site involves large truck traffic, human activity, operation of machinery and elevated noise levels associated with the Republic Services BMPC property and the existing landfill power plant. The proposed Raven SR operation is not expected to significantly change the level of activity that is currently conducted within the project area and, therefore, long-term operation of the Raven SR operation is not expected to result in significant impacts to biological resources within the project area.
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There is also existing permanent lighting associated with the current 24-hour activities of the adjacent BMPC and the project site. The proposed project would not substantially increase existing nighttime lighting to result in an adverse impact to existing bird species.

The project proposes LED lighting mounted on 30-foot-tall poles. Similar to existing conditions, the project lighting would be focused and shaded, incorporating directional shading (down-shot reflectors) to limit light pollution during night operations. The project would place nine single-light fixtures at throughout the site and three double-light fixtures in the truck loading area in the south portion of the site.

No part of the proposed facility would exceed 31 feet in height, which is the height of the industrial feed material handler. Other elements of height and size include the nitrogen tank (30 feet tall); the cooling tower and the fire water tank (both 25.5 feet tall); and the industrial metal canopy over the feed/unload storage area, the adjacent steam reformer structure, and the nitrogen tank (each 26 feet tall). Therefore, no part of the project would exceed 45 feet in height, in which case the project would comply with the City of Richmond’s Bird-Safe Buildings Municipal Ordinance.

Overall, the proposed project also would not alter any of the area’s natural resources or native vegetation in a way that could adversely impact biological resources. The impact would be less than significant.
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of Fish and Wildlife or United States Fish and Wildlife Service?
No Impact. The project site does not contain any riparian habitat or other sensitive natural communities. The nearest sensitive habitat is well-preserved coastal salt marsh occur along the San Pablo Bay shoreline, Wildcat Marsh, and along the upper banks of San Pablo Creek. The project site is located 0.25 miles east of the shoreline, approximately 0.3 miles south of San Pablo Creek’s upper banks, and within 300 feet of Wildcat Marsh, which is separated from the project site by the Bay Trail levee. The proposed project does not involve any activity that would affect these areas. Therefore, the proposed project would have no impact.
c) Have a substantial adverse effect on State or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? No Impact. The project site does not contain any State or federally protected wetlands.

The proposed development would not impact any waterbodies in any way and therefore would have no impact on protected wetlands.
d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of wildlife nursery sites? 957

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Less than Significant Impact. The project site is not in a natural condition and contains development and current truck and other operations of the BMPC. Due to the existing developed nature of the site, the project site does not provide suitable habitat to be considered a wildlife nursery site. Additionally, wildlife movement within the project site is restricted by existing privacy fencing that surrounds the project area. While the surrounding uplands and wetlands provide habitat for the movement of native resident and migratory wildlife, activities associated with the project are not expected to directly impact these areas or impede wildlife movement. Therefore, this impact would be less than significant.
e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Less than Significant Impact. Construction or operation of the proposed project would not conflict with any local policies or ordinances protecting biological resources. There are no existing trees on the project site, nor are any proposed due to limited space and potential safety hazards. However, as part of the proposed project, off-site landscaping improvements are proposed to the Wildcat Marsh Trail and trail head parking located approximately 1,000 feet east of the project site. Eleven drought-tolerant trees would be planted: either six large Coast Live Oak (Quercus agrifolia) or Big Leaf Maple (Acer macrophyllum), and five small California Buckeye (Aesculus californica). Both species are on City’s approved list of trees. Tree size planted would be associated with 15-gallon containers. The project is subject to and would adhere to the City’s local tree protection policies and regulations. Also, as addressed under Section 4.12, Noise and Vibration, of this checklist, the project would adhere to the City of Richmond Noise Ordinance regarding noise levels during temporary construction activity, as well as the operational noise levels. Therefore, this impact would be less than significant. f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan?
No Impact. The project site does not lie within the boundaries of any an adopted Habitat Conservation Plan (HCP) or Natural Community Conservation Plan (NCCP) or any other approved local, regional, or State habitat conservation plan.

References
California Department of Fish and Game (CDFG). 2012. Staff Report on Burrowing Owl Mitigation. Dated March 7, 2012.

California Department of Fish and Wildlife (CDFW). List of Vegetation Alliances and Associations (or Natural Communities List), Vegetation Classification and Mapping Program. Available online: www.dfg.ca.gov/biogeodata/vegcamp/natural_comm_list.asp.

Accessed June 14, 2022.
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CDFW. California Natural Diversity Database (CNDDB) for 7.5-minute topographic quadrangles Richmond, Briones Valley, San Francisco North, Oakland West, Oakland East, Petaluma Point, Mare Island, Benicia, San Quentin, Commercial Version. Accessed June 14, 2022.

CDFW. Natural Diversity Database. 2022. Special Animals List. Periodic publication.

CDFW. Special Vascular Plants, Bryophytes, and Lichens List. Accessed 2022.

California Native Plant Society (CNPS). Inventory of Rare and Endangered Plants (online edition, Z
), California Native Plant Society, Sacramento, CA. Available at:
www.rareplants.cnps.org. Accessed June 14, 2022.

City of Richmond, 2012. Richmond General Plan 2030: Conservation, Natural Resources and Open Space Element. Adopted April 25, 2012.

Contra Costa County 2004. Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions, SCH. 2002102057. June 2004.

Contra Costa County 2009. Addendum to the Final EIR for the WCCSL BMPC and Related Actions, SCH. 2002102057. 2009.

United States Fish and Wildlife Service (USFWS). 2022. List of threatened and endangered species that may occur in your proposed project location, and/or may be affected by the Raven SR Bioenergy Project. Consultation Code: 2022-0054185. June 14, 2022.

Wood, J.K., Nur, N., Salas, L. and O.M.W. Richmond. 2017. Site-specific Protocol for Monitoring Marsh Birds: Don Edwards San Francisco Bay and San Pablo Bay National Wildlife Refuges. Prepared for the U.S. Fish and Wildlife Service, Pacific Southwest Region Refuge Inventory and Monitoring Initiative. Point Blue Conservation Science.

Petaluma, CA.
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4.5 Cultural Resources
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Cultural Resources
Would the project:
a) Cause a substantial adverse change in the
significance of a historical resource as pursuant to
Section 15064.5?

b) Cause a substantial adverse change in the
significance of an archaeological resource pursuant to
Section 15064.5?

c) Disturb any human remains, including those interred
outside of formal cemeteries? 
Setting
To determine the cultural resources sensitivity of the project site, ESA completed a records search and background research, including a review of historic maps, aerial imagery, and geologic/soils data. ESA staff conducted a records search at the Northwest Information Center (NWIC) of the California Historical Resources Information System on March 23, 2022 (File No. 21-1575). The purpose of the records search was to (1) determine whether known cultural resources have been recorded in the vicinity of the project site; (2) assess the likelihood for unrecorded cultural resources to be present based on historical references and the distribution of nearby sites; and (3) develop a context for the identification and preliminary evaluation of cultural resources. The records search consisted of an examination of the following documents:
 NWIC digitized base maps (USGS San Quentin, CA 7.5-minute topographic map), to identify recorded archaeological sites and studies within a 0.5-mile radius of the project site.  NWIC digitized base maps (USGS San Quentin, CA 7.5-minute topographic map), to identify recorded historic-era resources of the built environment (building, structures, and objects) within and adjacent to the project site.
 Resource Inventories: California Inventory of Historical Resources, California Historical Landmarks, Built Environment Resource Directory (BERD) (through March 2020) and Archaeological Determinations of Eligibility (as of April 2012) for Contra Costa County.

No cultural resources have been previously recorded in the vicinity of the project site and there are no historic-age architectural resources in or adjacent to the project site. The nearest cultural resources are a series of pre-contact archaeological sites nearly 1 mile to the east that contribute to the Lower San Pablo Creek Archaeological District. These resources would not be impacted by the proposed project. The underlying geology of the project site consists of artificial fill over Holocene Bay Mud deposits. The historic shoreline is approximately 0.4 miles (2,000 feet) east of the project site; pre-contact and historic-era archaeological sites in this environment would be located at or very near to the historic shoreline.
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Therefore, this analysis concludes that the sensitivity for pre-contact and historic-era archaeological resources is low and the potential to uncover archaeological resources during project implementation is also low.

Evaluation
a) Cause a substantial adverse change in the significance of a historical resource as pursuant to Section 15064.5?
No Impact. CEQA Guidelines Section 15064.5 requires the lead agency to consider the effects of a project on historical resources. A historical resource is defined as any building, structure, site, or object listed in or determined to be eligible for listing in the California Register of Historical Resources (California Register), or determined by a lead agency to be significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, or cultural annals of California. The following discussion focuses on architectural and structural resources. Archaeological resources, including those that are potentially historical resources according to CEQA Guidelines Section 15064.5, are addressed below under question b).

As a result of the records search and background research, it was determined that there are no architectural or structural resources in or adjacent to the project site that potentially qualify as historical resources, as defined in CEQA Guidelines Section 15064.5. As such, there are no historical resources present within the project site and there would be no impact on historical resources.
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5?
Less than Significant Impact, after Mitigation. This section discusses archaeological resources, both as historical resources according to CEQA Guidelines Section 15064.5, as well as unique archaeological resources, as defined in California Public Resources (PRC) (CEQA) Section 21083.2(g). A significant impact would occur if the project would cause a substantial adverse change to an archaeological resource through physical demolition, destruction, relocation, or alteration of the resource.

Based on the results of the background research and environmental context, the potential for encountering archaeological resources during project implementation is low. However, in the unlikely event that a previously unrecorded archaeological resource is identified during project ground-disturbing activities and found to qualify as a historical resource or a unique archaeological resource, any impacts on the resource resulting from the project could be potentially significant.

Implementation of Mitigation Measure CUL-1a: Cultural Resources Awareness Training and Mitigation Measure CUL-1b: Inadvertent Discovery of Cultural Materials or Tribal Cultural Resources would reduce potentially significant impacts to less than significant. In the event of an inadvertent discovery of any cultural materials or tribal cultural resource, 961

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these mitigation measures would ensure that all personnel complete a cultural resources awareness training prior to any ground-disturbing activity and that work halts in the vicinity until a qualified archaeologist can make an assessment and provide additional recommendations if necessary, including contacting Native American tribes.

Mitigation Measure CUL-1a: Cultural Resources Awareness Training.

Prior to authorization to proceed, the City shall engage a qualified archaeologist, defined as an archaeologist meeting the U.S. Secretary of the Interior’s Professional Qualification Standards for Archeology, to conduct a training program for all construction workers involved on site disturbance. On-site personnel shall attend a mandatory pre-project training that outlines the general archaeological sensitivity of the vicinity and the procedures to follow in the event an archaeological resource and/or human remains are inadvertently discovered.

Mitigation Measure CUL-1b: Inadvertent Discovery of Cultural Materials or Tribal Cultural Resources.

If pre-contact or historic-era cultural materials are encountered during project implementation, all construction activities within 100 feet of the find shall halt and the contractor shall notify the City. The City shall notify a qualified archaeologist who will inspect the find within 24 hours of discovery and provide the City of an initial assessment. Pre-contact cultural materials might include obsidian and chert flaked-stone tools (e.g., projectile points, knives, scrapers) or toolmaking debris; culturally darkened soil (“midden”) containing heat-affected rocks, artifacts, or shellfish remains; stone milling equipment (e.g., mortars, pestles, handstones, or milling slabs); and battered stone tools, such as hammerstones and pitted stones.

Historic-era cultural materials might include building or structure footings and walls, and deposits of metal, glass, and/or ceramic refuse.

If the City determines, based on recommendations from a qualified archaeologist and a Native American representative (if the resource is pre-contact), that the resource may qualify as a historical resource or unique archaeological resource (as defined in CEQA Guidelines Section 15064.5) or a tribal cultural resource (as defined in PRC Section 21080.3), the resource shall be avoided if feasible.

Consistent with Section 15126.4(b)(3), this may be accomplished through planning construction to avoid the resource, incorporating the resource within open space, capping and covering the resource, or deeding the site into a permanent conservation easement.

If avoidance is not feasible, the City shall consult with a qualified archaeologist and a Native American representative (if the resource is pre-contact) to determine treatment measures to avoid, minimize, or mitigate any potential impacts to the resource pursuant to PRC Section 21083.2 and CEQA Guidelines Section 15126.4.

This shall include documentation of the resource and may include data recovery (according to PRC Section 21083.2), if deemed appropriate, or other actions such as treating the resource with culturally appropriate dignity and protecting the cultural character and integrity of the resource (according to PRC Section 21084.3). c) Disturb any human remains, including those interred outside of formal cemeteries? 962

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Less than Significant Impact, after Mitigation. The records search and background research conducted for the project determined that no human remains are known to exist within the project site. Therefore, the project is not anticipated to impact human remains, including those interred outside of formal cemeteries. While unlikely, if any previously unknown human remains were encountered during ground-disturbing activities, impacts on the human remains resulting from the project could be potentially significant.

Implementation of Mitigation Measure CUL-2: Inadvertent Discovery of Human Remains, would reduce potentially significant impacts to less than significant. This measure shall comply with applicable state laws, including Section 7050.5 of the Health and Safety Code. This would require work halt in the vicinity of a find and the immediate notification of the County Coroner. If the Coroner determines that the human remains are Native American, they would notify the California Native American Heritage Commission, who shall appoint a Most Likely Descendant (PRC Section 5097.98).

Mitigation Measure CUL-2: Inadvertent Discovery of Human Remains.

If human remains are encountered during project implementation, the contractor shall halt all construction activities within 100 feet of the find and notify the City.

The City shall contact the Contra Costa County Coroner who will determine that no investigation of the cause of death is required. If it is determined that the remains are Native American, the Coroner shall contact the Native American Heritage Commission within 24 hours. The Commission shall then identify the person or persons it believes to be the Most Likely Descendant from the deceased Native American, who in turn would make recommendations for the appropriate means of treating the human remains and any grave goods.

References
Northwest Information Center (NWIC), Records Search File No. File No. 21-1575. On file, ESA, March 23, 2022.
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4.6 Energy
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Energy
Would the project:
a) Result in potentially significant environmental
impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project
construction or operation?

b) Conflict with or obstruct a State or local plan for
renewable energy or energy efficiency? 
Setting
In 2020, more than 35 percent of the electricity PG&E delivered to its customers came from eligible renewable resources including solar, wind, bioenergy, geothermal and small hydropower and is on target to meet the 2045 goal (PG&E, 2021). As introduced in Section 2, Project Description, the Raven SR project would consume electricity to operate, the majority of the power would come from updated onsite power generation, and the fuel to be used is the existing LFG combined with tail gas from the project operation. An existing PG&E power drop is available to the project site.

Evaluation
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Less than Significant Impact. Both construction and operation of the project would involve expenditure of energy. Below are discussions of the energy resources that would be consumed during construction and operation of the project.

Construction
During construction, energy use would be both direct and indirect. Direct energy use would include the consumption of fuel (typically gasoline and diesel fuel) for the operation of construction equipment and vehicles. Energy in the form of electricity may also be consumed by some pieces of construction equipment, such as welding machines, power tools, lighting, etc.; however, the amount of consumed electricity would be relatively minimal. Indirect energy use would include the energy required to make the materials and components used in construction. This includes energy used for extraction of raw materials, manufacturing, and transportation associated with manufacturing. 964

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CEQA focuses on the efficient use of energy rather than comparisons of estimated energy amounts to be consumed to quantitative significance thresholds. Construction activities at the project site would occur over a period of approximately 8 months. Construction activities would include use of heavy-duty construction equipment and offsite vehicles to transport equipment, materials, and workers to the project component sites.

Energy use requirements in the form of diesel fuel that would be consumed by off-road construction equipment at the project site have been estimated based on the GHG emissions estimates obtained from the CalEEMod and EMFAC2021 modeling conducted for the Air Quality and GHG analysis in Sections 4.3 and 4.8, respectively, of this checklist. GHG emissions from CalEEMod were used in conjunction with The Climate Registry’s 2021 default factors for calculating carbon dioxide (CO2) emissions from diesel fuel (TCR, 2021). The analysis assumes that all off-road construction equipment would be fueled by diesel.

The analysis assumes that light-duty automobiles and trucks used by commuting construction workers would be fueled by gasoline, and that vendor vehicles and trucks that would haul demolition debris, soil, and other materials would use diesel fuel. This analysis assumes that no electric on-road vehicles would be used during project construction. GHG emissions associated with commuting workers and vendor and haul trips were estimated using information provided by the City for estimated trip counts and CalEEMod default trip lengths.

In addition to fuels used by equipment and vehicles, construction activities would use water for dust suppression and management, which in turn would require electricity to supply, treat, and transport the water to the project area.

It is estimated that over the entire construction period of the project, off-road equipment and on-road vender vendor and haul trucks would consume approximately 25,06120,062 gallons of diesel fuel, and commuting worker vehicles would consume approximately 146 203 gallons of gasoline17.

Due to the relatively small scope of the project, as well as the limited duration of construction activities, the consumption of fuel energy during construction would be temporary, localized, and would amount to a very small fraction of the 47 million gallons of diesel and 336 million gallons of gasoline sold in Contra Costa County (California Energy Commission [CEC], 2020). Vehicles used for project construction and operation would be required to comply with all federal and state efficiency standards. Additionally, there are no project characteristics or features that would be inefficient or that would result in the use of equipment and vehicles in a manner that would be less energy efficient than similar construction projects.
17 Construction energy estimates are updated to account for the project’s construction schedule delay. As part of the updated construction modeling, the most recent version of CalEEMod (version 2022.1) and EMFAC2021 were utilized, which result in differing emission factors for the CO2e estimates for both off-road and on-road equipment.

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Therefore, project construction would not result in wasteful, inefficient, or unnecessary use of energy, and would result in a less-than-significant impact associated with energy consumption.

Operation
Once operational, the majority of the project’s power requirements would come from electricity generated onsite. The electricity would be generated using equipment such as newly installed Jenbacher generator sets. The fuel that would be used for the generation is LFG from the Republic Services landfill, blended with the tail gas from a pressure swing adsorption (PSA) unit to purify the hydrogen product. Republic Services would offtake approximately 0.5 MW from the power generation for its onsite operational needs and the rest of the generated energy would be used to power the hydrogen plant. The plant would consume approximately 6.0+ MWe to operate and produce 200 kg of hydrogen per hour. Any additional electricity needed to operate the facility would be sourced from an existing PG&E power drop to the site and no new distribution power line would be required for the project. Operation and maintenance of the new facility would require 3 to 4 employees per shift, for a total of 9 to12 new employees per day to cover all shifts and provide necessary support of the facility; energy use from employee trips would therefore be minimal. Energy would be consumed by new truck trips to the site, withwhich is also relatively minimal at up to approximate 100 125 truck trips per week.
18 The facility would not involve customers onsite.

Since the majority of the required power would be generated onsite, and the power would be used to produce hydrogen fuel at the plant, the energy use imports of grid power associated with the project would be net positive (i.e., more power would be generated than consumed energy available in the hydrogen product as compared to the grid power import) and are not be considered inefficient or wasteful and hence, this impact would be considered less than significant.
b) Conflict with or obstruct a State or local plan for renewable energy or energy efficiency?
No Impact. As discussed above, project construction would require the use of off-road construction equipment and on-road trucks. Construction activities would comply with state and local requirements designed to minimize idling and associated emissions, which would also minimize the use of fuel. Specifically, pursuant to 13 CCR Sections 2485 and 2449, idling of commercial vehicles over 10,000 pounds and off-road equipment over 25 horsepower would be limited to a maximum of five minutes. Fuel use for project construction would be consistent with typical construction and manufacturing practices, and energy standards such as the Energy Policy Acts of 1975 and 2005, which promote 18 This estimate assumes 25 trucks per day, evenly distributed on five weekdays (per the Project Applicant, see Table

4.15-1, note “d”).
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strategic planning and building standards that reduce consumption of fossil fuels, increase use of renewable resources, and enhance energy efficiency.

Once operational, the project’s primary energy use would be electricity generated onsite using a fuel that would consist of LFG combined with tail gas. Energy used for operational vehicle trips would be negligible. Any additional electricity would be provided by PG&E, which would be subject to SB 100 under California’s Renewable Portfolio Standard (RPS) Program. Signed into law by Governor Brown, SB 100 increased California’s RPS target to 60 percent of total electric retail sales by 2030, and requires 100 percent of electric retail sales to come from eligible renewable or carbonfree resources by 2045. PG&E, as the utility provider, is subject to these requirements.

As a result, even if the availability of flaring of landfill gas produced from the decomposition of organic solid wastes declines over time, which would require the project to import a larger fraction of its power from the existing PG&E facilities (and/or a renewable source) to maintain operational levels, 100 percent of this electricity will renewable by 2045. There are no aspects of the proposed project that would conflict with or obstruct a state or local plan for renewable energy or energy efficiency, so there would be no impact.

References
California Energy Commission (CEC), 2020. 2020 California Annual Retail Fuel Outlet Report Results (CEC-A15), August 31, 2020. Available: https://www.energy.ca.gov/media/3874.

Accessed April 26, 2022.

Pacific Gas & Electricity (PG&E), 2021. PG&E Currents, April 19, 2021. Available:
https://www.pgecurrents.com/2021/04/19/a-renewable-revolution-how-pge-and-itscustomers-helped-write-californias-clean-energy-success-story/. Accessed April 26, 2022.

The Climate Registry (TCR), 2021. 2021 Default Emission Factors, Table 2.1—U.S. Default Factors for Calculating CO2 Emissions from Combustion of Transport Fuels. May 2021.

Available: https://www.theclimateregistry.org/wp-content/uploads/2021/05/2021-DefaultEmission-Factor-Document.pdf?mc_cid=4b45d12237&mc_eid=5f138d1baa. Accessed March 29, 2022.
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4.7 Geology, Soils and Mineral Resources
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Geology and Soils
Would the project:
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as
delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the State
Geologist for the area or based on other substantial
evidence of a known fault? Refer to Division of
Mines and Geology Special Publication 42.

ii) Strong seismic ground shaking? 
iii) Seismic-related ground failure, including
liquefaction? 
iv) Landslides? 
b) Result in substantial soil erosion or the loss of
topsoil? 
c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?

d) Be located on expansive soil, as defined in Table 18- 1-B of the Uniform Building Code (1994), creating
substantial direct or indirect risks to life or property? 
e) Have soils incapable of adequately supporting the
use of septic tanks or alternative wastewater disposal
systems where sewers are not available for the disposal of wastewater?

f) Directly or indirectly destroy a unique
paleontological resource or site or unique geologic
feature?

Mineral Resources
Would the project:
a) Result in the loss of availability of a known mineral resource that would be of value to the region and the
residents of the State?

b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local
general plan, specific plan or other land use plan?

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Setting
There are several known active faults in the vicinity of the project site. The location lies within a geologic province of the San Francisco Bay named the “Richmond Basin," bounded by the San Pablo and Hayward faults. The active fault in the region that are capable of producing the most significant ground shaking at the project site is the Hayward Fault, located approximately 3.7 miles southwest of the project site. (Rockridge, 2022)
A Geotechnical Investigation report was prepared for the proposed project (Rockridge, 2022).

The project site is blanketed by about 12 to 18 feet of heterogeneous fill, the upper five feet of which in the areas studied generally appears to be relatively well compacted. The fill is underlain by young bay sediments known locally as Bay Mud, which extends to depths of approximately 110 to 117 feet below ground surface (bgs). Bay Mud layer is generally soft to depths of approximately 50 to 60 feet bgs, but can be more stiff below, depending on the degree of over consolidation. The Bay Mud is underlain by alluvium consisting of dense to very dense sand/silty sand that extends to the maximum depth explored (120 feet bgs).

This analysis considers information from the geotechnical investigation as well as from numerous studies conducted for the WCCSL property.

Evaluation
Geological Resources and Soils
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving (i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42. (ii) Strong seismic ground shaking? (iii) Seismic-related ground failure, including liquefaction? (iv) Landslides?
Less than Significant Impact. Intense ground shaking during a large earthquake would be expected at the project site, particularly given its close proximity of the nearest active fault. The project would adhere to standard industry practices, code requirements, and any geotechnical recommendations or design parameters identified in the geotechnical study prepared for the project (Rockridge, 2022). (for the proposed earthwork, foundation slabs, and any surrounding related improvements, utilities, or paved areas associated with the project, would reduce the potential impacts associated with ground shaking during a major seismic event; seismically-related ground failure, including liquefaction for which the project area is susceptible (Richmond, 2012). The project would also adhere to all requirements in the applicable versions of the California Building Code, which would generally reduce known seismic hazards to minimize potential adverse effects. The project would introduce an industrial operation and modular structures on the project site, involving up to three to four employees onsite at any particular time, and no customers.

The impact would be less than significant.
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b) Result in substantial soil erosion or the loss of topsoil? Less than Significant Impact. The project, which relatively flat and partially paved and partially compacted soil and ruderal groundcover, would develop and implement an Erosion Control Plan and applicable best management practices as part of the National Pollutant Discharge Elimination System (NPDES) Construction General Permit, would reduce potential impacts associated with erosion to a less than significant level. c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?
Less than Significant Impact. As mentioned in criterion “a” above, the project would adhere to standard industry practices, code requirements, and any geotechnical recommendations or design parameters that would reduce the likelihood of landslide, lateral spreading, subsidence, liquefaction or collapse due to unstable geologic units or soil. Based on the results of previous analyses, most of the sand layers present at the site (primarily within the Bay Mud) are sufficiently dense, have sufficient clay content, and/or are overlain by a sufficient thickness of Bay Mud, such that the potential for liquefaction is low although the site is in a liquefaction hazard zone (see “a”). The greatest potential for liquefaction is approximately 0.3 miles northward, adjacent to San Pablo Creek. The project site is not located on areas of landfill, which also sits upon Bay Mud and is susceptible to risks of settlement over time. The impact would be less than significant.
d) Be located on expansive soil, as defined in Table 18- 1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? No Impact. Expansive soil is not known to exist at the WCCSL site (County, 2004). No impact would occur.
e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?
No Impact. The project does not proposed installation or use of septic tanks or alternative wastewater disposal systems; the site is currently served by West County Wastewater District sanitary sewer service and facilities which would continue with the proposed project.
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Less than Significant Impact, after Mitigation. Based on the evaluation in Section 4.5, Cultural Resources, in this checklist, the potential for encountering paleontological or unique geologic features on the project site during ground-disturbing activities for the 970

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proposed project is unlikely. However, the implementation of Mitigation Measure CUL1a: Cultural Resources Awareness Training, Mitigation Measure CUL-1b:

Inadvertent Discovery of Cultural Materials or Tribal Cultural Resources, and Mitigation Measure CUL-2: Inadvertent Discovery of Human Remains, all identified above in Section 4.5, Cultural Resources, also apply to reduce the potential and unlikely event paleontological resources are discovered.

Mineral Resources
a, b) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the State? Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan?
No Impact. The proposed project would not require the use of vast amounts of natural resources or mineral resources for construction or operation. Input to the operation is existing organic feedstock from the project site. No impact would occur. The California Geological Survey (formerly California Division of Mines and Geology) identifies mineral resources present within California and designates mineral resource zones. These mineral resource zones (MRZs) are based on known mineral resources present (e.g., existing mines) or documented geological units present or underlying surface locations. Each MRZ is classified based on potential economic value of the underlying resources. The proposed Project is located in MRZ-1. This zone classification indicates that no significant mineral deposits are present, or little likelihood exists for their presence (Stinson, Manson and Plappert, 1987). Therefore, the proposed Project would not result in the loss of a locally important mineral resource and no impact would occur.

References
City of Richmond, 2012. Richmond General Plan Update Environmental Impact Report. SCH. 2008022018. 2012.

City of Richmond, 2012. Richmond General Plan 2030: Public Safety and Noise Element. Table

3.7-4, Liquefaction. 2012.

Contra Costa County 2004. Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions, SCH. 2002102057. June 2004.

Contra Costa County 2009. Addendum to the Final EIR for the WCCSL BMPC and Related Actions, SCH. 2002102057. 2009.
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4.8 Greenhouse Gas Emissions
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Greenhouse Gas Emissions
Would the project:
a) Generate greenhouse gas emissions, either directly
or indirectly, that may have a significant impact on the environment?

b) Conflict with any applicable plan, policy or regulation adopted for the purpose of reducing the emissions of
greenhouse gases?

Setting
State and Regional
The California Global Warming Solutions Act (Assembly Bill [AB] 32, 2006), as amended, sets statewide greenhouse gas (GHG) emissions caps. The California Air Resources Board (CARB) established the Climate Change Scoping Plan, which outlined a framework for achieving the emission reduction goals set in the California Global Warming Solutions Act. In 2016, SB 32 and its companion bill AB 197 established a new climate pollution reduction target of 40 percent below 1990 levels by 2030 and included provisions to ensure the benefits of State climate policies reach into disadvantaged communities.

Senate Bill (SB) 375 requires CARB to develop regional GHG reduction goals for the automobile and light truck sectors. The Plan Bay Area 2040 is a plan to achieve regional GHG reduction goals by improving transportation access, maintaining the region’s infrastructure, and enhancing resilience to climate change through strategies such as fostering open space. There are a number of other laws in California intended to reduce GHG emissions through the regulation of construction standards, growth, and municipal operations.

Governor Brown signed Executive Order B-55-18 in September 2018 to establish a statewide goal to achieve carbon neutrality as soon as possible, and no later than 2045, and to achieve and maintain net negative emissions thereafter. In response to this Executive Order, CARB’s Draft 2022 Scoping Plan Update (May 10CARB, 2022b) presents several scenarios for achieving carbon neutrality statewide no later than 2045. Additionally, in 2022, California enacted the California Climate Crisis Act (AB 1279), which amended AB 32 by establishing state policy to achieve net zero GHG emissions as soon as possible, but no later than 2045, and to ensure that, by 2045, anthropogenic GHG emissions are reduced to at least 85 percent below 1990 levels.

CARB’s Final 2022 Scoping Plan for Achieving Carbon Neutrality (CARB, 2022a) describes the selected Scoping Plan Scenario to achieve these goals, in comparison to other proposed scenarios and a Reference Scenario.
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Significance Threshold
Greenhouse gas impacts are, by their nature, cumulative impacts because one project by itself cannot cause global climate change. As such, GHG emissions are evaluated under CEQA as a cumulative impact. To evaluate cumulative impacts, a lead agency must assess (1) whether the overall cumulative impact would be significant and, (2) if the overall impact is significant, whether the incremental contribution that the individual project under review would add to the overall cumulative problem would be cumulatively considerable.

A conservative threshold of significance for determining the cumulative impact of a project’s GHG emissions is “net zero” emissions. This concept is supported by the BAAQMD in its Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans (BAAQMD, 2022), which states: “If a land use project incorporates all of the design elements necessary for it to be carbon neutral by 2045, then it will contribute its portion of what is needed to achieve the State’s climate goals and will help to solve the cumulative problem. It can therefore be found to make a less-than-cumulatively-considerable climate impact” (BAAQMD 2022).

Further, the State’s Office of Planning and Research’s (OPR) Final Statement of Reasons for Senate Bill 97 revisions to the CEQA Guidelines state that, “AB32, and regulations implementing that statute, will require reductions in emissionsfrom certain sectors in the economy, but do not preclude new emissions. Moreover, as explainedin the Initial Statement of Reasons, the proposed amendments do not establish a zero emissions threshold of significance because there is no ‘one molecule rule’ in CEQA” (CNRA, 2009).

For GHG thresholds, the BAAQMD published the 2022 Justification Report that presents GHG thresholds, which are based on AB 32 and California Climate Change Scoping Plan reduction targets and strategies developed to reduce GHG emissions statewide (BAAQMD 2022). These thresholds are presented in Table 4.8-1. This analysis focuses on presenting Project GHG emissions for informational purposes and evaluating the project against the BAAQMD 2022 GHG significance thresholds.

The new BAAQMD thresholds are focused on land development projects, and the legacy stationary source threshold for operational GHG emissions is 10,000 MTCO2e. This threshold is not being currently updated in the BAAQMD, as staff are focusing on creating land use project and plan thresholds (BAAQMD 2022). This analysis focuses on net zero emissions and the new draft thresholds, while also taking into account the existing BAAQMD threshold. 973

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TABLE 4.8-1

BAAQMD GHG THRESHOLDS OF SIGNIFICANCE
(MUST INCLUDE A OR B FOR OPTION SCHEME)
Existing and Draft Air District Thresholds
Legacy Stationary
Source Threshold
10,000 MTCO2e
Option A Projects must include, at a minimum, the following project design elements:
1) Buildings
a. No natural gas (residential and non-residential)
2) Transportation
a. Achieve compliance with EV requirements in the most recently adopted version of CALGreen1 Tier 2
b. Achieve SB 743 target of 15% reduction in VMT per capita below regional average
Option B Be consistent with a local GHG Reduction Strategy that meets the criteria under the CEQA Guidelines Section 15183.5(b)
1 Part 11 of the Title 24 Building Energy Efficiency Standards is referred to as the California Green Building Standards (CALGreen) Code
SOURCES: BAAQMD 2022. Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans, April.

Evaluation
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Less than Significant Impact. GHG emissions would be generated during both construction and operational phases of the project.

Construction
The combustion of diesel fuel to provide power for the operation of various construction equipment results in the generation of GHGs. Construction emissions associated with the project were estimated using project-specific information provided by the Project Applicant, such as construction schedule and phasing; types, number, and horsepower rating of constructionequipment to be used, their daily usage in terms of hours per day, and the number of dayseach piece of equipment is used over the construction period; and information on construction vehicle trips for worker commute, equipment and material transport and hauling trips. Appendix A to this checklist contains the data and assumptions used to estimate the construction-phase GHG emissions that would be associated with the project.

Carbon Dioxide (CO2), methane (CH4) and nitrous oxide (N2O) emissions from off-road construction equipment and construction vehicle trips were derived from the CalEEMod 974

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run to estimate criteria air pollutant emissions. N2O and CH4 emissions were multiplied by their respective Global Warming Potentials GWPs (25 and 298) and added to the CO2 emissions to obtain CO2e emissions.

Construction of the proposed project is anticipated to occur over a period of approximately eight months. It is estimated that project construction would generate a total of approximately 258.9186.1 MTCO2e over an 8-month construction period, as shown in Table 4.8-2. BAAQMD does not have adopted significance thresholds for construction-related GHG emissions in its 2017 CEQA Guidelines (BAAQMD, 2017).

However, it recommends that the Lead Agency (i.e., the City of Richmond) quantify and disclose construction GHG emissions and incorporate best management practices to reduce GHG emissions during construction, as applicable.

TABLE 4.8-2

ANNUAL CONSTRUCTION-RELATED GREENHOUSE GAS EMISSIONS
Year GHG (MTCO2e)
2022 2023 178.3 179.3
2023 2024 80.6 6.8
Total 258.9 186.1
Amortized 8.63 6.2
NOTES:

MTCO2e = metric tons of carbon dioxide equivalent
Construction-related GHG emissions were amortized over 30 years, which is a commonly accepted method for including construction emissions as part of the proposed project’s average annual emissions.

Construction emissions are updated in this updated IS/MND to account for the project’s one-year construction schedule delay.

SOURCE: Data compiled by Environmental Science Associates in 2022Ramboll (Appendix A to this documentchecklist)
In addition, the GHG thresholds proposed by the BAAQMD in response to SB 32’s GHG reduction goals also do not contain significance thresholds for construction (BAAQMD, 2022). GHG emissions from the construction phase of a project represent a very small portion of emissions over the project’s lifetime, which for the projects such as the proposed project would be at least 30 years.

The BAAQMD’s proposed thresholds are instead designed to address operational GHG emissions from land use development projects which represent the majority of a project GHG emissions. The primary source of GHG emissions from construction is dieselpowered construction equipment. Large reductions in construction emissions are difficult to realize because there are currently no economical alternatives to diesel fuel for powering most construction equipment. Improvements in statewide regulations governing construction equipment and fuel standards driven by SB 32 and other initiatives will also contribute to reduced emissions from construction activities. Therefore, GHG emissions associated with project construction would be considered less than significant.

Though not required as mitigation to reduce a significant impact, implementation of Mitigation Measure AQ-1: Best Management Practices, identified above in Section 975

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4.3, Air Quality, will help reduce GHG emissions in addition to providing air quality benefits. Therefore, GHG emissions associated with project construction would be considered less than significant.

Appendix A contains details on the calculations and assumptions used to estimate construction GHG emissions as well as model outputs.

Operational
The current BAAQMD thresholds have been set using the “fair share” analysis, which looks at how new land use development projects need to be designed and built to ensure that they will be consistent with the goal of carbon neutrality by 2045 (BAAQMD 2022).

The existing legacy stationary source threshold is 10,000 MTCO2e annually.

The proposed system takes up to 99.9 wet-tons per day (WTPD) of blended green waste (GW), food waste (FW), using landfill gas (LFG) to provide power to the process and converts the feed into renewable, transportation grade hydrogen. This waste would otherwise be put into the landfill where it would produce GHG emissions in the form of methane gas. The landfill gas would also otherwise be creating GHG emissions if not for the bioenergy facility taking it and converting it into hydrogen. By redirecting this waste into the Raven SR, it reduces the amount of GHG emissions produced at the project site.

Biogenic CO2 emissions from green waste are not accounted for in operational GHG impacts as they are a result from materials that are derived from living cells, not fossil fuels (BAAQMD 2017b).

The Raven SR system does not have any free oxygen in its process, and instead uses steam promoted processes to thermally decompose the feed into its chemical elements.

This The process does not involve any type of combustion, and therefore does not have an GHG emissions associated with the system operational emissions. Once project operations fully begin, GHG emissions are expected to be net negative, and will continue to be net negative even if LFC is ever fully depleted.

Table 4.8-3 shows operational emissions calculated using CalEEMod (version 2020.4.0) and EMFAC2021 as well emissions from permitted activities added to the amortized construction emissions to get the total annual project GHG emissions. BAAQMD does not currently have a quantitative threshold for GHG emissions. The current qualitative significant thresholds are found in Table 4.8-1. The project would satisfy the BAAQMD Best Available Control Technology (BACT) requirements, and thus the proposed project is consistent with the 2017 Climate Change Scoping Plan as well as the draft and final 2022 Scoping Plan Update in terms of following the GHG reduction strategy to reach the statewide goal of climate neutrality by 2045 (CARB 2017, 2022a, 2022b). 976

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TABLE 4.8-3

UNMITIGATED ANNUAL OPERATIONAL GREENHOUSE GAS EMISSIONS Source GHG (MTCO2e)
Process Operations
Biogas Engines 16,398
Flare 205
Fire Pump Engines 2.5
Auxiliary Operations
Area <1
Energy 80.5
Mobile 262.6 1909.2
Off-road 303.2
Waste 96.7
Water 17.0
Amortized Construction Emissions 6.2
Amortized Construction EmissionsLandfill Flare
Reductions (blended gas) 8.63 -9,019
Total Project GHG Emissions (blended gas) 697.17 9,999
Landfill Flare Reductions (100% LFG) -16,398
Total Project GHG Emissions (100% LFG) 2,620
NOTES:

A 30-year lifetime was assumed for the project, which was used to amortize construction emissions.

Landfill flare reductions were estimated based on the landfill gas usage of the Project biogas engines, which can operate using a blended gas consisting of at least 55 percent landfill gas and up to 100 percent landfill gas
MTCO2e = metric tons of carbon dioxide equivalent
Operational emissions are revised in this updated IS/MND to align with more detailed project information from the Project Applicant.

SOURCE: Data compiled by Environmental Science Associates. (See Appendix A to this documentchecklist.)
Based on the state carbon neutrality goal for 2045, the proposed project would contribute its portion of what is needed to achieve the State’s climate goals and would help to solve the cumulative climate problem. Its emissions are considerably less than the current BAAQMD operational emissions threshold of 10,000 metric tons of CO2e per year (see Table 4.8-3 above. It can therefore be found to make a less-than-cumulativelyconsiderable climate impact. The project emission calculations, along with the supporting data from the life cycle analysis, shows that the project would be below both the new draft significant thresholds and the legacy stationary source threshold, with the possibility of reaching net negative GHG emissions, contributing to the determination of the project having a less than significant impact and a less-than-cumulatively-considerable climate impact. Therefore, operation of the proposed project would have a less than significant impact.
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
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Less than Significant Impact. In response to AB 32 GHG reduction goals, CARB adopted the Climate Change Scoping Plan, which outlined a framework for achieving the emission reduction goals set in the California Global Warming Solutions Act. The Scoping Plan was most recently updated in 20172022 (2017 Scoping Plan; CARB, 2022a2017) to address California’s 2030how the state will achieve AB 1279’s goals of achieving net zero GHG emissions target and identifies how the State can reach the 2030 climate target established an 85 percent reduction in anthropogenic GHG emissions below 1990 levels by 2045SB 32 while making substantial advancements toward the 2050 climate goal established by Executive Order (EO) S-3-05 (2005).

The City of Richmond developed and adopted a climate action plan (CAP) in 2016 to meet a city-wide 2020 GHG emissions target consistent with AB 32 and achieve reductions in line with the longer-term statewide goal to reduce emissions 80 percent below 1990 levels by 2050, as established by Executive Order B-3-15.

The project would generate GHG emissions primarily from operational activities and would most likely result in net negative emissions on an annual basis, and contributes to the long-term California goals of finding alternative sources of green energy. As such, the project would help the City achieve its long-term GHG emissions goal. Neither the 20172022 Scoping Plan Update or the City’s existing CAP contain any actions or measures that address GHG emissions from construction. The majority of electricity supplied to the project would come from an onsite power generator, fueled by LFG from the Republic Services WCCSL. Any additional power required would be supplied from an on-site PG&E power drop; PG&E is required to comply with SB 100 and the RPS. SB 100 requires that the proportion of electricity from renewable sources be 60 percent by 2030 and 100 percent renewable power by 2045. Therefore, the project would be consistent with all applicable plans, policies and regulations adopted for the purpose of reducing GHG emissions. This impact would be less than significant.

References
Bay Area Air Quality Management District, (BAAQMD) 2022. Justification Report 2022.

Available online: Microsoft Word - FINAL CEQA Thresholds Report for Climate Impacts 03_30_22 revisions with tracked changes (baaqmd.gov). Accessed on May 11, 2022.

Bay Area Air Quality Management District, (BAAQMD) 2017. CEQA Air Quality Guidelines 2017. Available online: https://www.baaqmd.gov/~/media/files/planning-andresearch/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en. Accessed May 17, 2022.

The City of Richmond, 2016. Climate Action Plan 2016. Available online:
https://www.ci.richmond.ca.us/DocumentCenter/View/40636/CAP-combined. Accessed May 11, 2022.

California Air Resources Board (CARB), 2017. California’s 2017 Climate Change Scoping Plan.

Available
online:https://ww2.arb.ca.gov/sites/default/files/classic/cc/scopingplan/scoping_plan_2017 .pdf. Accessed on April 26, 2022.
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CARB, 2022a. California’s Final 2022 Climate Change Scoping Plan, November 16, 2022.

Available online:
https://ww2.arb.ca.gov/our-work/programs/ab-32-climate-change-scoping-plan/2022- scoping-plan-documents. Accessed on March 4, 2023.

CARB, 2022b. California’s Draft 2022 Climate Change Scoping Plan, May 10, 2022. Available online: https://ww2.arb.ca.gov/sites/default/files/2022-05/2022-draft-sp.pdf . Accessed on March 4, 2023.

California Natural Resources Agency (CNRA), 2009. 2009 California Climate Adaptation Strategy. Available online:
https://resources.ca.gov/CNRALegacyFiles/docs/climate/Statewide_Adaptation_Strategy. pdf. Accessed May 17, 2022.

Raven SR Republic Service Summary, 2021. Carbon Life Cycle Analysis, Life Cycle Associates, LLC.
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4.9 Hazards and Hazardous Materials
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Hazards and Hazardous Materials
Would the project:
a) Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?

b) Create a significant hazard to the public or the
environment through reasonably foreseeable upset and
accident conditions involving the release of hazardous
materials into the environment?

c) Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? 
d) Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a result,
would it create a significant hazard to the public or the environment?

e) For a project located within 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 result in a safety hazard or excessive noise for people residing or working in the project area?

f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency
evacuation plan?

g) Expose people or structures, either directly or
indirectly to a significant risk of loss, injury or death involving wildland fires?

Setting
The project site sits within the existing WCCSL, which does not accept hazardous wastes; under State and federal laws, the landfill is permitted to accept non-hazardous wastes only. Although the municipal solid waste stream does contain small quantities of hazardous wastes that result from disposal of household waste and waste from small quantity generators, such as auto repair, auto dealers, and gas stations, the proposed project only involves a variety of organic waste feedstock. As discussed below and in Section 2.5 (under Safety and Controls (in Section 2.6NonCombustion), the Raven SR process incorporates internal safety functions and would adhere to numerous applicable state and federal regulations, plans and procedures that apply specifically to its production of hydrogen gas from organic solids. The project facility and operation located 980

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within the WCCSL would also benefit from the numerous existing safety regulations, plans and procedures.

A Phase I Environmental Site Assessment has been prepared for the project (CEC, 2022). The Phase I reports relevant site conditions observed include the storage of various commonly used hazardous materials, such as used oil, lubricants, anti-freeze, HDPE pipe sealant, pipe glue solvent, spray paint, and household cleaning supplies. All observed materials were properly stored and maintained. The Phase I also reports numerous above-ground storage tanks (ASTs) containing petroleum products located within and near the existing landfill power plant and maintenance buildings near the project site.

As previously described, the project is contiguous to a closed hazardous waste landfill portion of the WCCSL operation. Also, the project site was formerly occupied by three leachate evaporation ponds. Groundwater contamination on the WCCSL site was confirmed in a January 2021 Corrective Action Groundwater Monitoring Program Report.19 Groundwater at the WCCSL also has reported PFAS chemicals detected in groundwater. This is considered a recognized environmental condition (REC), but regularly monitored and the results are submitted to the State regulatory agency. Additionally, the groundwater impact is not expected to pose a risk of unacceptable exposure to workers at the project site. (CEC, 2022) Regarding potential site contamination, Republic previously initiated corrective actions to address the California Department of Toxic Substance Control’s (DTSC’s) concerns in 1996. These actions included installing additional wells to monitor and control leachate at the site and maintain it within the landfill boundaries as required. Republic currently operates systems to collect and treat both leachate and landfill gas under existing conditions.

The proposed project is designed to avoid interfering with existing groundwater monitoring and recovery wells, along with any associated leachate recovery systems. Leachate recovery infrastructure at the site will remain operational, and the proposed project will not affect the operation or maintenance of these facilities.

The proposed project is designed to avoid interfering with existing LFG monitoring and recovery wells. Project design would not alter the existing LFG collection and recovery infrastructure at the site, which will remain operational. The proposed project will accept LFG from existing, permitted equipment, downstream of the liquid collection system to be blended with tailgas from the Raven SR process for use as a fuel to the new, lower emitting, higher efficiency LFG engines for power production.

Raven SR will conduct a limited site investigation to validate subsurface environmental conditions during the Project’s engineering design. This evaluation will characterize soil-gas conditions at the proposed project site to ensure that project components are constructed safely and meet all OSHA and CalOSHA requirements. Raven SR will install impermeable vapor 19 CEC, 2022. Operation of a groundwater monitoring system and a groundwater extraction system is required under the West County Landfill (WCL) corrective action groundwater monitoring program (CAGMP), in accordance with Corrective Action Enforcement Order, Docket Number 20061079 dated September 26, 2007. 981

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barriers under foundations during construction to prevent potential release of soil-gas during subsurface activities. This pre-construction verification of site conditions will address concerns pertaining to potential soil-gas, also known as volatile organic compounds (VOCs), that may have migrated from the adjacent landfill in the past and beneath the proposed project site.

In regard to hazards and safety concerns, the draft CUP includes several conditions that address hazards and safety concerns. These conditions include:
 Condition 82 requires Raven to prepare and submit for approval a Public Health and Safety Plan, as well as an Emergency Plan to protect the facility and its employees from harm, and protect human health off-site as well. These measures include:
o preparation of and adherence to a comprehensive Process Safety Information (PSI) regarding safe work practices and operating procedures; o ensuring employees are involved in Raven’s required process safety and risk management programs (PSM/RMP);
o training all employees and contractors on the potential hazards and safe operations;
o establishing and implementing a process to evaluate any new systems, components, parts, etc. before they are placed into service; o establishing and implementing a Pre-Start Safety Review (PSSR) procedure to verify that the Raven process and equipment is functional and ready for service before starting;
o ensuring operators are aware of and trained on any process or equipment changes;
o managing contractors to ensure their safety awareness; o conducting routine maintenance of mechanical equipment; o investigating the cause of any equipment or system failures and implementing corrective and preventative actions; and
o establishing and adhering to emergency planning and response plan protocols.

During construction, safety training for the various construction roles prior to access to the site would be mandatory. Daily safety briefings would be conducted to alert crew and labor to potential hazards that may be scheduled for a particular day/shift.

During operations, Raven SR would contract with a capable and experienced operations and maintenance (O&M) service provider from among those with experience in feedstock management and with high temperature, high pressure process equipment. Also, Raven SR would closely oversee the implementation of the Raven-specific operating, training, safety, and maintenance manuals described above.  Condition 83 requires the project to comply with all design measures, safety precautions, and emergency response procedures as required by federal, state, and local laws and regulations.
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 Condition 84 requires the project to implement on and off site emergency response procedures, as outlined in the Emergency Plan described in Condition 82 above.  Condition 85 requires the project to develop and implement training (and refresher training) covering accident prevention, safety, identification and handling of hazardous materials, first aid, and instruction for use of equipment.  Condition 89 states that the project is further bound by the California Fire Code for all systems and equipment installation containing flammable, combustible, or hazardous materials. The City is requiring that the project have an equipment maintenance program agreed upon by the City and the Fire Marshall.

Evaluation
a, b) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? Less than Significant Impact. The proposed operation of transforming blended green waste and food waste into transportation-grade hydrogen-rich synthesis gas (syngas) and charcoal (biochar) could result in an adverse effect through the exposure to or spill of chemicals. The green waste and food waste feedstock would not be considered a hazardous material. Also, in 1993, DTSC determined that the Raven SR process for the production of syngas from organic solids was not categorized as either incineration or combustion and was therefore a suitable technology for use in California.20 The conversion method uses a non-combustion (i.e., anoxic, indirect external heating), low pressure process. The only chemicals added would be carbon dioxide (CO2), calcium/magnesium carbonate (dolomite limestone), and steam (i.e., water heated into a vapor state). No hazardous materials would be used in the process. The conversion occurs in sealed rotating drums that dropretort that drops out solid matter from the green and food waste feedstock, which would consist largely of hot biocarbon, along with dirt, glass, grit, rocks, and inorganic salts. The biocarbon materialscomponents are inert to the process (i.e., not gasified) and drop out in the first stage. The process also drops out excess A spray of water is used on the biocarbon to quickly cool it to manageable temperature. Neither the biocarbon nor the water would be considered a hazardous material.

There would be no long-term hydrogen storage onsite; the material would be fed directly into the tube trucks and transported offsite. For transportation, the United States Department of Transportation (USDOT) classifies hydrogen gas as a Division 2.1 20 According to the definitions listed in Section 260.10, Title 40, Code of Federal Regulations (40 CFR) and Section 66260.10, Title 22, California Code of Regulations (22 CCR). Also, since 2017, a Raven pilot engineering unit, sized at 100 wet pounds per day of feedstock, has been operating at the UC Berkeley’s Richmond Field Station and is permitted for operation by the Bay Area Air Quality Management District (BAAQMD) under permit Nos. 23993 and 23320.
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Flammable Gas. Vehicles transporting flammable gas are mandated to display USDOT flammable gas placards. The proposed project would pump the hydrogen gas into standard pressurized hydrogen gas trucks, called tube trailers. The gaseous hydrogen is compressed to pressures of 380 gas (about 5,500 pounds per square inch [psig]) or higher into long cylinders that are stacked on a trailer that the truck hauls. This gives the appearance of long tubes, hence the name tube trailer.

To support development of the hydrogen economy, development of tube trailers capable of storing hydrogen at pressure of about 500 bar are approved for use on public throughways use by USDOT regulations (Federal Motor Carrier Safety Administration, 49 CFR Part 393). Such tube trailers are routinely used to transport hydrogen gas, as well as other gases such as natural gas and propane. Regulations regarding the design of tube trailers that transport hydrogen gas isare in OSHA 1910.103, Subpart H, Hydrogen, which includes requirements for the containers, pressure relief valves, piping, tubing, fittings, and labeling. On-road transport of hydrogen gas must comply with applicable USDOT regulations, which include equipment requirements and driver safety training. In California, a specific driver’s license is required, a commercial driver’s license with a Hazard Materials endorsement.

A new 250,000-gallon integrated fire water tank and diesel engine is proposedwould be installed in the northeast corner of the site for emergency use, as required by fire department regulations (see Figures 2-1 through 2-4). Diesel fuel is classified as a hazardous material, and therefore the above ground tanks would require compliance with containment requirements in a Spill Prevention, Control, and Countermeasure (SPCC) Plan pursuant to federal requirements. Propane for the continuous flare pilot would be supplied from a standard 1000-gallon propane tank installed on-site. A local propane supplier would service and fill the tank as needed.

Overall, the project operations would be equipped with continuous monitoring systems and can automatically shut down plant operations without human intervention.

Specifically, the facility’s controls would be distributed through the various process islands, taking their direction from a central Human-Machine Interface in the control room with centralized data collection. Process setpoints would be bounded by high/low alarm limitations to draw the operator’s attention to the specific problem. The control system would represent state-of-the-art digital technology with redundant instrumentation where necessary to ensure safe operation.

Because the process itself is oxygen-free, there would be no opportunity withinduring the process for explosion. As previously described (Section 2.5), piping and vessels would be periodically scanned with infrared equipment during each working shift to identify hot spots or gas leaks that may threaten safety. If hot spots or leaks were identified, immediate steps would be taken to correct or mediate the condition. Also, remote monitoring of the facility by Raven SR corporate provides oversight of the operation and early identification of problems in the eventas they were to occurdevelopment. 984

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The project would comply with applicable Environmental Protection Agency (EPA) risk management plan (RMP) and Occupational Safety and Health Administration (OSHA) process safety management (PSM) guidelines, as may be applied to the facility to ensure the safety of its operations staff and the surroundings A maintenance program of regular and preventative maintenance would be developed to maintain equipment in a reliable manner.

The project’s Raven SR Project would result in a less than significant impact as designed based on the Project’s adherence to all applicable regulatory requirements mentioned in this section, combined with the operational controls and redundancy designed as part of the Raven RS process, materials and operations, the impact would be less than significant.
c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? No impact. As discussed above, the proposed project would not emit hazardous emissions or handle hazardous materials or waste. Moreover, the project site is located approximately 1.1 miles from Verde Elementary School at 2000 Giaramita Street.

Therefore, no impact would occur.
d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
No impact. An inactive waste disposal area that is a Class I Hazardous Waste Management Facility (HWMF) is located within the WCCSL and directly north of the BMPC and project site (see Figure 1-3 in Chapter 1, and Figure 2-0 in Chapter 2). The facility was closed pursuant to State and federal regulations, and final cap construction was completed prior to 2003. It is a totally enclosed facility with required environmental control systems. The proposed project site is not within the previous HWMF area; therefore, no impact would occur.
e) For a project located within 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 result in a safety hazard or excessive noise for people residing or working in the project area?
No impact. The proposed project is not located within an airport land use plan, and the closest airport to the project site is the San Rafael Airport located approximately 8.3 miles southeast. Therefore, the proposed project would not be located within two miles of an airport, and no impact would occur.
f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
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Less than Significant Impact. In the event of a large-scale disaster, emergency response to the site would be coordinated by WCCSL facility, City and County fire responders, and in adherence to the WCCSL Emergency Response and Evaluation Plan and local agency protocols. Emergency fire control procedures are also included in the composting and wood waste recycling operations plans. The WCCSL facility and project site are accessed from and exit to Parr Boulevard, and a serious of roadways and paths throughout the 340-acre WCCSL provide sufficient width for emergency access. The proposed project would be developed within part of the existing BMPC property and would not create new or interfere with existing access or egress roads. As detailed in the Setting above, in addition, the proposed project would comply with applicable Environmental Protection Agency (EPA) risk management plan (RMP) and Occupational Safety and Health Administration (OSHA), including additional voluntary compliance with OSHA process safety management (PSM) guidelines, as may be applied to the facility to ensure the safety of its operations staff and the surrounding community. PSM includes a comprehensive collection of agencies and programs providing oversight over all aspects of plant operation and maintenance. Therefore, there is no potential for the project to impair implementation of emergency evacuation or an adopted emergency response plan.
g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
Less than Significant Impact. The project site is flat and surrounded by the WCCSL facility, which is composed of grass-covered disposal areas of the landfill mounds, runoff control ponds and lagoons, and composting areas, and tidal marshlands of San Pablo and Wildcat Creek. Open water of San Pablo Bay is approximately 0.25 miles westward from the project site. Wildfire hazard maps show the site as not being within a high wildfire hazard zone (CPUC, 2018). Further, as discussed in criteria “a and b”, the project would include a new 250,000-gallon integrated fire water tank and diesel engine is proposed for emergency use, as required by fire department regulations.

References
California Public Utilities Commission. Fire-Threat Map – State of California. January 19, 2018.

CEC, 2022. Phase I Environmental Site Assessment, West Contra Cost Sanitary Landfill, 1.5- Acre Clean Energy Development Project, 1 Parr Boulevard, Richmond California 94801.

June 30, 2022.

Contra Costa County 2004. Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions, SCH. 2002102057. June 2004.

Contra Costa County 2009. Addendum to the Final EIR for the WCCSL BMPC and Related Actions, SCH. 2002102057. 2009.
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4.10 Hydrology and Water Quality
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Hydrology and Water Quality
Would the project:
a) Violate any water quality standards or waste
discharge requirements or otherwise substantially
degrade surface or groundwater quality?

b) Substantially decrease groundwater supplies or
interfere substantially with groundwater recharge such
that the project may impede sustainable groundwater
management of the basin?

c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of
impervious surfaces, in a manner which would:
(i) result in substantial erosion or siltation on- or
off-site; 
(ii) substantially increase the rate or amount of surface runoff in a manner which would result in flooding onor off-site; 
(iii) create or contribute runoff water which would
exceed the capacity of existing or planned
stormwater drainage systems or provide
substantial additional sources of polluted
runoff; or

(iv) impede or redirect flood flows? 
d) In flood hazard, tsunami, or seiche zones, risk
release of pollutants due to project inundation? 
e) Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater
management plan?

Setting
No surface water bodies exist on the project site. As previously described throughout other sections of this analysis, the following surface water bodies exist within the WCCSL property and directly south/southwest of the project site: runoff ponds or lagoons delineated as “Area B” and tidal waters delineated as “Area C” (shown in Figure 3-1, Vicinity Map, of the 2004 EIR).

San Pablo Creek is approximately 0.3 miles north of the project site, and Wildcat Creek is approximately 280 feet south/southeast of the project site, bordering the WCCSL south boundary which is an elevated levee (see Figure 2-0 and Figure 2-1 in Chapter 2 of this 988

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document). Many small tributaries that drain and feed the brackish marshlands of these creeks, and the 100-year flood flows in San Pablo Creek would be totally contained in the channel.

Open water of San Pablo Bay is approximately 0.25 miles west of the project site. The levees around the WCCSL have been designed and maintained to exceed flood levels and the upland portions are located outside wetlands under U.S. Army Corps of Engineers (Corps) jurisdiction.

Depth to groundwater at specific areas of the project site can range from 5 to 7 feet or up to 10- 1/2 feet below the ground surface. The depth to groundwater varies seasonally. Groundwater contamination on the WCCSL site was confirmed in a Phase I Environmental Site Assessment prepared for the project (CEC, 2022). This recognized environmental condition (REC) is regularly monitored and the results are submitted to the State regulatory agency. There are no anticipated plans for use of existing groundwater by the Project.

Evaluation
a, b) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality? Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin? Less than Significant Impact. WCCSL implements a Storm Water Pollution Prevention Plan (SWPPP) under the NPDES permit, as amended. The drainage plan for the WCCSL, which currently encompasses the project site, accommodates the 100-year storm event.

The WCCSL is managed to prevent the infiltration of surface water into the waste materials and to maximize and control the amount of surface water that runs off via overland flow with berms, bench drains, down drains, which would manage runoff from the project. Area 1 runoff is diverted to the siltation control basin located behind (east of) the Golden Bear Waste Recycling Center.

As introduced in Section 2.92.8, Construction, Site Coverage and Drainage, the project would adhere to all applicable regulatory stormwater runoff controls and will pursue its own NPDES permit. The project’s SWPPP would be developed prior to construction and operation of the facility and flows would be integrated into the existing WCCSL system and ensure drainage from the proposed project site would drain towards existing stormwater runoff control ponds (or bioretention facility) to which the rest of the WCCSL property currently drains. The drainage control systems would be designed such that the two systems are segregated and independent of one another. This would minimize the creation of contact water (water that has come into contact with organic feedstock) as well as protecting the site from various health and safety hazards.

The receiving and handling area would be in a modular structure and industrial canopy to minimize rainfall from coming in contact with the feedstock material. The receiving area would also incorporate a berm at the opening of the receiving area to keep any potential contact water inside. The aprons around the facility would direct any rainfall away from the canopy and into the stormwater drainage and management system described above. 989

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Any excess contact water that may be generated inside the canopy receiving area will either be reabsorbed into incoming feedstock or collected via floor drains and diverted to the facility’s sanitary sewer.

The SWPPP also requires site inspections and a preventive storm water control maintenance program, with triggers for evaluation monitoring and corrective action as needed under RWQCB review and oversight pursuant to State regulations. Also, neither construction nor operation of the project would involve use of groundwater. Taken together, the proposed stormwater program and project development would not impair water quality or decrease groundwater. The impact is less than significant. c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
(i) result in substantial erosion or siltation on- or off-site; (ii) substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site;
(iii) create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or
(iv) impede or redirect flood flows?
Less than Significant Impact. The proposed project would involve minimal grading as needed to prepare the site for new paving and foundations for the proposed modular buildings. The site is current flat and would remain so, except for slight grading around the proposed modular structure to prevent contact water. As described in Section 2.82.9, Construction, Site Coverage and Drainage, in Chapter 2, the proposed project would add approximately 1.21 acres of new impervious surface area (including modular structures) to the existing 0.76 acres of impervious area that would be repaved. This would result in approximately 78 percent of the project site (2.5 acres) being impervious. Approximately

0.53 acres, or 22 percent, of unpaved area along the north boundary of the site would remain undisturbed.

Although the amount of impervious area on the project site would nearly double compared to the existing conditions, the proposed drainage management would effectively manage increased flows to the existing system and not exceed the capacity of the system. A draft Stormwater Control Plan has been prepared for the project (Power, 2022). It delineates two nearly equally-sized drainage management areas (DMA 1 and DMA 2) across the project site. DMA 1 is the northern part of the site where the modular building and facilities are proposed and its flows would drain to an existing pump that is part of the existing stormwater system. DMA 2 is generally the south and southwest part of the project site where existing development and paved areas exist for truck traffic and 990

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circulation; its flows would integrate directly into the existing stormwater system. The DMA’s are delineated to effectively capture and direct runoff to not exceed the existing system. Based on the 24-hour, 100-year storm, pre-development flow is estimated at

11.89 cubic feet per second (cfs). Post-development is estimated at 12.47 cfs, which is less than 5 percent potential change.

Also, permanent source controls would be implemented to address potential runoff flows, including. Examples include use of equipment closures and regular inspection of potential pollutant sources for debris or blockages that may interfere with intended stormwater flows. Adherence to the SWPPP under the NPDES permit (see criterion “a and b”) would also minimize erosion as well as polluted runoff.

Overall, the proposed site alterations would not result in changes in stormwater flows that could exceed the capacity of the existing stormwater control system to which the project site would flow. It would also not impede or redirect storm flows. The impact is less than significant.
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
Less than Significant Impact. The California Geological Survey has mapped tsunami inundation areas along the Richmond shoreline, and the project site is located within the hazard zone (CGS, 2021). Seiche risk at areas along Richmond’s shoreline are minimal because there are no large confined bodies of water with depths that would cause this hazard (City of Richmond, 2011). As discussed in the above Setting, the 100-year flood flows in San Pablo Creek adjacent to the project site and would be totally contained in the channel, also the levees around the WCCSL have been designed and maintained to exceed flood levels. Therefore, risk of inundation at the site is low, particularly due to risk of a seiche or flooding on the project site. Moreover, even if inundation were to occur, the risk of release of pollutants from the proposed project is also low. The impacts would be less than significant.
e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Less than Significant Impact. As discussed in criterion “a”, the proposed project would not conflict with implementation of the existing water quality plan nor release pollutants from its construction or operation.

References
State of California, 2021, Tsunami Hazard Area Map, Contra Costa County; produced by the California Geological Survey, the California Governor's Office of Emergency Services, and AECOM; dated 2021. Accessed and printed September 13, 2022. 991

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Contra Costa County 2004. Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions, SCH. 2002102057. June 2004.

Contra Costa County 2009. Addendum to the Final EIR for the WCCSL BMPC and Related Actions, SCH. 2002102057. 2009.

City of Richmond, 2012. Richmond General Plan Update Environmental Impact Report. SCH. 2008022018. 2012.

Power, 2022. Draft Stormwater Control Plan for Raven One, July 22, 2022. 992

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4.11 Land Use and Planning
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Land Use and Planning
Would the project:
a) Physically divide an established community? 
b) Cause a significant environmental impact due to a
conflict with any land use plan, policy, or regulation
adopted for the purpose of avoiding or mitigating an
environmental effect?

Setting
The proposed project area is the existing approximately 340-acre WCCSL, a self-contained area and operation within the broader area of industrial and open space land uses, including the Bay Trail / Wildcat Creek Marsh Trail. Other nearby uses include the West County Wastewater District Treatment Plant, EBMUD’s North Richmond Water Reclamation Plan, the Richmond Sanitary District, and other refuse services, automobile repair and towing businesses, and lawn services, etc. The Richmond Parkway is a major roadway through the area and spurs the Parr Boulevard approach to the WCCSL and adjacent uses. The next nearest established community is the residential development at generally West Gertrude Avenue/Malcolm Drive, approximately 0.75 miles southeast.

Evaluation
a) Physically divide an established community?
No Impact. The proposed operation is consistent with current BMPC activities on the site and activities throughout the WCCSL site. Therefore, the project could not divide any established community, as the project is located within an existing closed landfill in an area that will not impede established transportation infrastructure to the community, is located at the outer edges of the City’s limits and is essentially surrounded by water on three sides, and is not within proximity to existing neighborhoods or other sensitive receptors. The project would have no impact.
b) Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
Less than Significant Impact. The proposed facility and operation to convert blended green waste and food waste obtained from the existing OMPF locatedoperation adjacent to west of the project site into renewable, transportation grade hydrogen would not conflict with any existing land use plan, policy or regulation intended to mitigate 994

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environmental effects. As proposed, the project does not require approval of an amendment to any aspect of the General Plan or the City’s Zoning Ordinance or Map.

CEQA does not require the project to be consistent with all policies in the General Plan, nor does it require an assessment of compliance with every applicable General Plan policy. Overall, the project advances Policy EC2.2 Climate-Friendly Fuel Support production and distribution of climate-friendlier fuels (when and if any are identified) and identify appropriate locations for fuel storage and distribution (Energy and Climate Change Element). The project also advances CARB’s Final 2022 Scoping Plan, the state’s identified scenario for achieving carbon neutrality statewide no later than 2045, including through the increased use of renewable and green hydrogen in zero-emissions vehicles and heavy-duty vehicles and by increasing the current amount of hydrogen supply. This impact would be less than significant.

References
CARB, 2022a. California’s Final 2022 Climate Change Scoping Plan, November 16, 2022.

Available online:
https://ww2.arb.ca.gov/our-work/programs/ab-32-climate-change-scoping-plan/2022- scoping-plan-documents. Accessed on March 4, 2023.

City of Richmond, 2012. Richmond General Plan Update Environmental Impact Report. SCH. 2008022018. 2012.

City of Richmond, 2012. Richmond General Plan 2030: Public Safety and Noise Element. Table

3.7-4, Liquefaction. 2012.

City of Richmond, 2012. Richmond General Plan 2030: Conservation, Natural Resources and Open Space Element. 2012.

City of Richmond, 2012. Richmond General Plan 2030 Historic Resources Element. 2012.

City of Richmond, 2012. Richmond General Plan 2030: Energy and Climate Change Element. 2012.

Contra Costa County 2004. Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions, SCH. 2002102057. June 2004.

Contra Costa County 2009. Addendum to the Final EIR for the WCCSL BMPC and Related Actions, SCH. 2002102057. 2009.
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4.12 Noise and Vibration
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Noise
Would the project result in:
a) 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?

b) Generation of excessive groundborne vibration or
groundborne noise levels? 
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?

Setting
The proposed project is located entirely within the City of Richmond. The West County Wastewater District Treatment Plant and other industrial uses exist east of the property. The nearest residential receptors are 0.75 miles (approximately 3,949 feet) southeast from the project site. Approximately 7- to 8-foot-high sound walls were installed at these residences when Richmond Parkway was constructed to lower noise levels (WCCSL BMPC, 2003).

The primary noise sources in the vicinity of the project site include vehicles on adjacent and nearby roadways: Richmond Parkway and Parr Boulevard. The existing ambient noise environment in the project vicinity may be characterized by traffic noise modeling conducted for a previous EIR (City of Richmond, 2011) for primary roadways. Results of this traffic modeling are presented in Table 4.12-1 and are representative of transportation noise levels generated by roadways.
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TABLE 4.12-1
LOCALIZED ROADWAY TRAFFIC NOISE 1
Roadway Segment Description
Predicted, Ldn2, dB at 50 feet
Background
Richmond Parkway Gertrude Street and Parr Boulevard 75.9 Richmond Parkway Parr Boulevard and San Pablo Avenue 74.7 NOTES:
1 Analytical Environmental Services. 2011. Point Molate Mixed-Use Tribal Destination Resort and Casino Project. Available online: https://www.ci.richmond.ca.us/DocumentCenter/View/7685/Section_4p11?bidId= 2 Ldn is the energy average of the A-weighted sound levels occurring during a 24-hour period, and which accounts for the greater sensitivity of most people to nighttime noise by weighting noise levels at night (“penalizing” nighttime noises).

SOURCE: Brown and Buntin Associates, 2008.

Evaluation
a) 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.

Less than Significant Impact. Noise would be generated during both construction and operational phases of the project.

Construction
Construction of the proposed project would occur over a period of approximately eight months, starting Fourth Second Quarter of 20222023, and start-up of the plant is projected to begin in the Second to ThirdFourth Quarter of 2023 or First Quarter of 2024.

Project construction would result in temporary increases in ambient noise levels. Onsite construction activities would require the use of heavy construction equipment (e.g., excavator, loader, crane) that would generate varying noise levels. Offsite construction noise sources would consist of passing trucks and other construction-related vehicles.

City of Richmond Noise Ordinance, Section 15.04.605.060, regulates construction noise by allowing construction work that generates noise to occur weekdays between the hours 7:00 a.m. and 6:00 p.m., except outside of these hours or on Sundays and federal holidays unless a temporary waiver is granted by the Building Official or his or her authorized representative (City of Richmond, 2018).

The proposed project would adhere to the City’s construction work hours. The City’s construction noise level limitation of 75 dBA is used to assess whether daytime Leq construction-related noise levels would cause a substantial temporary or periodic increase in ambient noise levels at sensitive receptor locations. City of Richmond Noise Ordinance, 9.52.110 Temporary construction activity, limits noise levels measured at SFR-1, SFR-2, SFR-3 Zoning Districts (Single-Family Residential) to 75 dBA between the hours of 7:00 a.m. to 7:00 p.m. on weekdays.
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The operation of each piece of equipment would not be constant throughout the day, as equipment would be turned off when not in use. Over a typical workday, the equipment would be operated at different locations and all the equipment would not operate concurrently at the same location within the project site or roadways to and from the site. Construction noise levels have been estimated using typical equipment source noise levels suggested in the Federal Highway Administration’s (FHWA) Roadway Construction Noise Model (RCNM) and based on the type of construction equipment that are proposed to be used. To quantify construction-related noise exposure that would occur at the nearest sensitive receptors, it was assumed that the two loudest pieces of construction equipment would operate concurrently at the location within the project site and construction vehicle paths to the nearest sensitive receptor locations.

The estimated Lmax and Leq for each of the two loudest pieces of equipment that would be used to construct the project components, and the combined Leq noise level associated with the two loudest pieces of construction equipment at the closest sensitive receptor locations for each project component are identified in Table 4.12-2. The combined Leq construction noise levels would not exceed the City’s construction noise level limitation of 75 dBA described in Table 4.12-2. This modest noise contribution would not increase the existing ambient noise level at the nearest receptor.

TABLE 4.12-2

CONSTRUCTION EQUIPMENT NOISE LEVELS
Type of
Equipment
Distance to Closest
Sensitive Receptor
(feet)
Equipment
Lmax, dBA
Equipment Hourly
Leq, dBA/Usage%
Combined Leq at
Sensitive
Receptor, dBA
Demolition
Crushing/Proc.

Equipment 3,949 (Residences)

52.3 45.3/20%

46.2 Excavators 42.8 38.8/40%
Site Preparation
Tractors
3,949 (Residences)

46.0 42.1/40%

45.6 Rough Terrain
Forklifts 47.0 43.1/40%
Grading
Excavators
3,949 (Residences)

42.8 38.8/40%

43.7 Tractors 46.0 42.1/40%
Building Construction
Rough Terrain
Forklifts
3,949 (Residences)

45.4 41.5/40%

46.0 Other Construction
Equipment 47.0 44.0/50%
NOTES: Lmax = maximum instantaneous noise level; Leq = the equivalent sound level used to describe noise over a specified period of time, in terms of a single numerical value; Lmax = the instantaneous maximum noise level measured during the measurement period of interest.

SOURCE: Federal Highway Administration, 2008. FHWA Roadway Construction Noise Model, Version 1.1, December 2008.
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In addition to on-site construction equipment, the project would also result in short-term increases in local daytime traffic volumes. The project components would each add up to approximately 84 one-way daily construction-related vehicle trips to area roadways, including 72 one-way daily hauling trips, 4 one-way daily vendor trips, and 8 one-way daily worker trips. The project truck trips would access the nearest freeway (Interstate 580) via Parr Boulevard and Richmond Parkway and would not utilize roadways with noise-sensitive land uses. Therefore, the associated increase in short-term construction vehicular noise levels would not be expected to increase noise levels in the vicinity of existing sensitive receptors beyond the levels described in Table 4.12-2.

Operation
The Raven SR system would run up to 24 hours per day, 7 days per week, although an average of 1.5 days per month are planned down times. The primary source of noise during project operation would be mechanical equipment associated with the Steam/CO2 Reformation system, including heating systems, HVAC equipment. Also, feedstock would be physically deposited in the receiving area via self-unloading transfer trucks or other suitable vehicles. The hydrogen compressors are industrial pieces that could generate noise up to as much as 85 dBa at 1.0 meter. Additionally, trucks used to distribute fuels generated on the site would be maneuvering within the parking lot of the proposed facility.

City of Richmond Noise Ordinance, Section 9.52.100, regulates operational noise levels from public property at residential areas. Per Section 9.52.100, noise levels caused by mechanic equipment on public property in residential areas should not result in noise levels in excess of 65 dBA measured at any boundary of a residential zone (City of Richmond, 2022). Guidelines identified in the Richmond General Plan 2030, Action SN4.A, proposed commercial and industrial uses that locate in an area with day-night average sound level (Ldn) of 55 or greater to provide noise study reports the City’s goal for maximum outdoor noise levels in residential areas is 60 Ldn (City of Richmond, 2012). The 65 dBA Leq measured at any boundary of a residential zone is used here to assess whether operational noise levels would cause a substantial permanent increase in ambient noise levels.

It is not possible to provide specific noise levels at individual receptor locations that would result from operation of stationary sources. However, the nearest noise-sensitive receptor would be approximately 0.75 miles from the project site property line.

Table 4.12-3 presents reference noise levels for many of the stationary sources for informational purposes. Given the data in Table 4.12-3 and the known distance to the nearest noise receptors, the operational noise levels would be substantially below the 65 dBA standard of the City of Richmond Noise Ordinance and the operational noise impact would be less than significant.
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TABLE 4.12-3

REFERENCE NOISE LEVELS FOR STATIONARY NOISE SOURCES ASSOCIATED WITH THE PROPOSED

PROJECT
Stationary
Noise Source
Documented Sound
Levels (dBA)
Noise Level at
Nearest
Receptor Source
HVAC Equipment 72–78 dBA at 30 feet without
acoustical treatments
19-25 dBA Trane, Sound Data and
Application Guide, 2002
Standby Diesel Generator 75–90 dBA at 23 feet
(size dependent) without
acoustical enclosure
19-34 dBA Cummins Power Generation,
Sound Attenuated and Weather
Protective Enclosures, 2008
Loading Dock 77 dBA at 20 feet 20 dBA Urban Crossroads, Moreno Valley Walmart Noise Impact Analysis,
2015
NOTES:
dBA = A-weighted decibels; ESA = Environmental Science Associates; HVAC = heating, ventilation and air conditioning SOURCE: Data compiled by Environmental Science Associates in 2022. (Additional sources noted above.) b) Generation of excessive groundborne vibration or groundborne noise levels? Less than Significant Impact. Operations and maintenance of the project facility would not include any sources of vibration that would be considered excessive. Groundborne vibration and noise associated with some construction activities, including the use of pile drivers, blasting, and vibratory rollers, can cause excessive vibration. The project would not include any such activities. Groundborne vibration and noise levels generated by the types of equipment required to prepare the site and construct the proposed facility would be minimal and would not cause human annoyance or structure damage at a distance of 25 feet or beyond from the source (FTA, 2018). No existing historic structures that would be potentially vulnerable to vibration are located in the immediate vicinity of the project site such that any damage related to groundborne vibration from construction activities would occur. This impact would be less than significant and mitigation measures are not warranted.
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 is located approximately 8.3 miles southeast of the San Rafael Airport and is not located within the 55 dBA Ldn noise contours for the San Rafael Airport (City of San Rafael, 2021). The proposed project would not involve the development of noise-sensitive land uses that would be exposed to excessive aircraft noise. Therefore, there would be no impact.

References
California Department of Transportation (Caltrans), 2013. Technical Noise Supplement (TeNS).

September 2013.
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City of Richmond, 2012. Richmond General Plan 2030, Chapter 12, Public Safety and Noise.

April 25, 2012.

City of Richmond, 2022. Richmond Municipal Code, Article 15.04.605 - Noise. March 16, 2022.

City of San Rafael, 2012. San Rafael General Plan 2040 & Downtown Precise Plan, Chapter 4.13, Noise. January, 2021.

Federal Highway Administration (FHWA), 2008. FHWA Roadway Construction Noise Model, Version 1.1, December 2008.

Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual. September 2018. Available:
https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transitnoise-and-vibration-impact-assessment-manual-fta-report-no-0123_0.pdf. Accessed March 31, 2022.
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4.13 Population and Housing
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Population and Housing
Would the project:
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?

Setting
As previously discussed in Section 4.11, Land Use and Planning, in this section, the project area entails open space and a range of industrial and commercial uses. No housing exists within 0.75 miles of the area, and the proposed project would be developed within the existing WCCSL and BMPC facilities and operations.

Evaluation
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)?
No Impact. The proposed project does not entail new housing, roads or other infrastructure that would induce substantial growth; the new business would involve 3 to 4 new employees per shift, for a total of 9 to12 new employees per day, which would not constitute substantial population growth. There would be no impact. b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
No Impact. No housing or people exist on the project site. The project would have no impact.

References
None.
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4.14 Public Services and Recreation
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Public Services
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 facilities, 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? 
b) Police protection? 
c) Schools? 
d) Parks? 
e) Other public facilities? 
Recreation
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?  Setting
The project area is currently serviced by the Richmond Fire Department (RFD), which also manages the West County Fire District, which also serves San Pablo, El Sobrante, and unincorporated areas of Western Contra Costa County, including North Richmond. The nearest fire station is RFD Station 62 at 1065 7th Street, Richmond.

Evaluation
Public Services
a) Fire Protection and Emergency Medical
Less than Significant Impact. The project site would be served by the same fire and emergency services that currently serve the WCCSL. The project would also install a new 250,000-gallon fire water tank and diesel engine in the northeast corner of the site for emergency use, as required by fire department regulations The fire water tank would be up to 25.5 feet tall and include two pumps, a small jockey pump for normal circulation, and the diesel-powered fire pump (shown in Figures 2-1 through 2-4.) All construction-related mitigation measures identified in this analysis would apply to that development onsite.
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The proposed operation would involve up to 3 to 4 new employees per shift and would not involve customers onsite. Also, the Raven SR system itself is not a combustion process and would incorporate several safety measures, including continuous monitoring systems, automatic plant operations shut down without human intervention, compliance with applicable EPA RMP and OSHA PSM guidelines, including applicable USDOT regulations for the on-road transport of hydrogen gas. Overall, the project would not result in noticeable increased demand for service that would require new fire or emergency medical facilities. The impact would be less than significant. b,c) Police Protection, Schools, Parks, Other
No Impact. The project would not involve changes that would increase the demand for policy protection on the project site. There would be no impact. Also, the project would not involve changes that would increase the demand for schools, parks or other public services. There would be no impact.

Recreation
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?
No Impact. The project would not introduce new people onsite that would increase the use of recreational facilities or parks. New population would consist of up to 3 to 4 new employees per shift; no customers would be onsite. There would be no impact 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?
No Impact. The project would include new or expanded recreational facilities or parks.

There would be no impact.

References
City of Richmond, 2011. General Plan 2030 – Map 12.6 Police and Fire Services. August 2011.

City of Richmond, 2012. Richmond General Plan Update Environmental Impact Report. SCH. 2008022018. 2012.

Google Earth Pro, Richmond Fire Stations, June 2022.
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4.15 Transportation
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Transportation
Would the project:
a) Conflict with a program plan, ordinance or policy of the circulation system, including transit, roadway,
bicycle and pedestrian facilities?

b) Would the project conflict or be inconsistent with
CEQA Guidelines Section 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? 
Setting
The Richmond Parkway is a major roadway in the area that extends from Interstate 580 near the east approach to the Richmond-San Rafael Bridge northeasterly to Interstate 80 near Hilltop Drive. Parr Boulevard from Richmond Parkway is the main approach to the project site within the WCCSL and other nearby uses.

Evaluation21
a) Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities? Less than Significant Impact. Table 4.15-1 summarizes the daily vehicle trip generation for the project based on the expected number of employees and truck activity at the site.

Since trucks are larger and operate slower than passenger vehicles, a passenger car equivalent (PCE) ratio of 2.0 is used to convert the truck trips to passenger vehicle trips (each truck is counted as two passenger vehicles). Accounting for PCE trips, the project is estimated to generate about 130 net new PCE trips on a typical weekdayBased on input from Raven, a total of 25 trucks are projected to access the Raven site on a daily basis, in addition to 12 employee vehicles daily.
21 All technical analysis conducted for this transportation analysis is included in this section; no separate technical appendix is warranted.
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TABLE 4.15-1

PROJECT DAILY TRIP GENERATION SUMMARY
Use Amount Daily Trip Rate Passenger Car
Equivalent (PCE) a
Daily Trips
(passenger cars
and trucks) a
Employees 12 b 2.5 c 1.0 30
Trucks 25 d 2.0 e 2.0 10050
Total Daily Trips
(PCE) 13080
NOTES:
a Specifically for use in the operational emissions and energy analysis in this document (see Sections 4.3 Air Quality, 4.6 Energy, and 4.8, GHG Emissions), aA passenger car equivalent (PCE) of 2.0 is used to convert truck trips to passenger vehicle trips (each truck is counted as two passenger vehicles, or a total of 100 PCE trips) for trucks because they are larger and operate slower than passenger vehicles. The project would have a total of 130 PCE trips (100 truck PCE trips + 30 employee trips). b Per the Project Applicant and described in Chapter 2, Project Description. c One inbound and one outbound trip per employee per day plus 0.5 trips per employee per day for other trips such as deliveries, running errands, etc.
d Per the Project Applicant and as described in Chapter 2, Project Description, 125 trucks would serve the site during a typical week.

This estimate assumes they would be evenly distributed on five weekdays. e One inbound and one outbound trip per truck.

SOURCE: Fehr & Peers, 2022
For informational purposes, Tthe addition of 13080 new trips on a typical weekday would not substantially increase the motor vehicle volumes on the nearby streets, including Parr Boulevard and Richmond Parkway.22 In addition, considering that both Parr Boulevard and Richmond Parkwaystreets currently have high truck volumes because they are Citydesignated truck routes (established in the Richmond General Plan, Map 4.4) that serve primarily industrial areas, the additional trips generated by the project would not conflict with existing and proposed transit, roadway, bicycle, and pedestrian facilities in the project vicinity, which are located and planned in coordination with the designated truck routes.

Although level of service (LOS) and other measures of vehicle delay cannot be used to identify significant impacts under CEQA, the Contra Costa Transportation Authority (CCTA), as described in their Technical Procedures (November 2022), requires the evaluation of project effects on multimodal transportation service objectives (MTSOs), (including LOS at intersections along the regional routes of significance) outside of the CEQA process for development projects that generate more than 100 net new peak hour vehicle trip. As shown in Table 4.15-1, the project would generate less than 100 net new trips daily and would be below this threshold. Thus, analysis of project impacts on traffic operations and congestion is not required for the project. 22 Or 130 new passenger car equivalent (PCE) trips on a typical weekday, as specifically calculated for use in the operational emissions and energy analysis in this document, since trucks are larger and operate slower than passenger vehicles. A PCE ratio of 2.0 is used to convert the 50 truck trips to 100 trips. Combined with the 30 employee trips per day, the project has a total 130 daily PCE trips. 1007

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The project would also not modify any transit, roadway, bicycle, or pedestrian facilities and would not conflict with existing or proposed facilities in the project vicinity.

The project would be consistent with programs, plans, ordinances, and policies addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. The impact is less than significant.
b) Would the Project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
Less than Significant Impact. CEQA Guidelines Section 15064.3, added in December 2018 and consistent with the requirements of SB 743, states that vehicle miles traveled (VMT) is the most appropriate metric to assess the environmental impacts of a project on transportation.

The City of Richmond adopted VMT analysis guidelines, methodology, and thresholds of significance on April 6, 2021, consistent with the Contra Costa Transportation Authority (CCTA)’s adopted VMT guidelines, which are also consistent with the State’s Office of Planning and Research’s (OPR) Technical Advisory on Evaluating Transportation Impacts in CEQA (December 2018). The City of Richmond guidelines includes screening criteria for development projects that meet certain criteria that can readily lead to the conclusion that they would not cause a significant impact on VMT. The screening criterion applicable to the project is the Small Projects criterion, which states that projects generating less than 836 VMT per day can be presumed to cause a less than significant impact on VMT.

Error! Not a valid bookmark self-reference. summarizes the estimated VMT generated by the project on a typical weekday. Since the City of Richmond’s adopted guidelines, which are based on the CCTA Guidelines and consistent with CEQA Guidelines section 15064.3, subdivision (a) state that the VMT analysis for transportation impact purposes can focus solely on VMT generated by passenger vehicles and light-duty trucks and not include the VMT generated by heavy trucks, the project VMT summarized in Error! Not a valid bookmark self-reference. does not include the VMT generated by trucks for the project. As shown in Error! Not a valid bookmark self-reference., the project is estimated to generate 174 VMT per day, which is below the screening criterion of 836 VMT per day.

Therefore, the project can be presumed to have a less than significant impact on VMT and is consistent with CEQA Guidelines section 15064.3, subdivision (b) and the impact is less than significant.
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TABLE 4.15-2

PROJECT VMT SUMMARY
Use Amount Daily VMT Rate Total VMT
Employees 12a 14.5b 174
Total 174
Threshold 836
Below Threshold? Yes
NOTES:
a Per the Project Applicant and described in Chapter 2, Project Description b Daily commute VMT per worker in 2020 based on the CCTA Travel Demand Model for TAZ 10347, where the project is located c Per the Project Applicant and as described in Chapter 2, Project Description, 125 trucks would serve the site during a typical week.

This estimate assumes they would be evenly distributed on five weekdays d Per the Project Applicant and described in Chapter 2, Project Description, average truck trip would be 40 miles; assuming two trips (one inbound and one outbound) per truck.

SOURCE: Fehr & Peers, 2022
c) 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. The project would not modify the access point to the existing WCCSL facility, the internal circulation within WCCSL, or the public right-ofway. Passenger vehicles and trucks would continue to access the project site through Parr Boulevard and Richmond Parkway. The project is located in an industrial area with high volume of large trucks already present on surrounding roadways, including Parr Boulevard and Richmond Parkway. The additional trucks added by the project would not result in incompatible uses or increase hazards. Thus, the impact on hazards existing roadway uses due to a geometric existing design features or incompatible uses is less than significant.
d) Result in inadequate emergency access?
Less than Significant Impact. As discussed above, the project would not modify the access point to the existing WCCSL facility, the internal circulation within WCCSL, or the public right-of-way. Emergency vehicles would continue to access the project site on Parr Boulevard.

The project would be designed and constructed according to the applicable fire and safety standards at the time of construction. Therefore, the WCCSL site would continue to be accessible by fire and emergency vehicles through public streets and the internal roadways within the WCCSL. Thus, the impact on emergency access is less than significant.

References
California State’s Office of Planning and Research’s (OPR) Technical Advisory on Evaluating Transportation Impacts in CEQA (December 2018).
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City of Richmond, 2012. Richmond General Plan 2030, Element 4 Circulation. Available at:
https://www.ci.richmond.ca.us/DocumentCenter/View/8846/Map-44---Existing-TruckRoutes?bidId= . Accessed March 6, 2023.

Contra Costa Transportation Authority (CCTA), 2020. Contra Costa County Transportation Analysis Guidelines, 2020. Available at:
https://www.contracosta.ca.gov/DocumentCenter/View/70739/FINAL-CCCTransportation-Analysis-Guidelines-v3-5-10-21?bidId=. Accessed March 6, 2023. 1010

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4.16 Tribal Cultural Resources
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Tribal Cultural Resources
Would the project:
a) 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), 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 Section 5024.1, the lead
agency shall consider the significance of the
resource to a California Native American tribe.

Setting
ESA contacted the California State Native American Heritage Commission (NAHC) on October 20, 2021, to request a search of the NAHC’s Sacred Lands File and a list of Native American representatives who may have knowledge of tribal cultural resources in the project vicinity or interest in the proposed project. The NAHC replied to ESA by email on November 19, 2021, noting that the Sacred Lands File has no record of any sacred sites within the project site. The NAHC response included a list of 15 Native American representatives from 13 tribal groups who may have knowledge of tribal cultural resources in the vicinity of the project site.

On May 4, 2022, the City received a response for consultation from Chairwoman Corrina Gould of the Confederated Villages of Lisjan. On May 18, 2022, the City held a virtual meeting with tribal members, Chairwoman Gould, Deja, and Cheyenne, to discuss the project and any potential impacts to cultural resources. Based on the discussion, the tribe has no concerns with the project as it relates to impacts to tribal cultural resources and cultural resources, and is comfortable with the proposed mitigation measures. See Section 4.5, Cultural Resources, of this checklist for a summary of ESA’s NWIC records search and cultural resources sensitivity assessment. 1012

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Evaluation
a.i, a.ii)
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), or significance of the resource to a California Native American tribe.

Less than Significant Impact, after Mitigation. CEQA requires the lead agency to consider the effects of a project on tribal cultural resources. As defined in PRC Section 21074, tribal cultural resources are sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are listed, or determined to be eligible for listing, on the national, state, or local register of historical resources.

Based on the NWIC records search and the NAHC SLF negative search results, there are no known tribal cultural resources listed or determined eligible for listing in the California Register of Historical Resources or included in a local register of historical resources as defined in PRC Section 5020.1(k), pursuant to PRC Section 21074(a)(1), would be affected by the project. No tribal cultural resources have been identified by Native American representatives, and background research did not identify any tribal cultural resources. In addition, the City did not determine any resource that could potentially be affected by the project to be a significant tribal cultural resource pursuant to criteria set forth in PRC Section 5024.1(c).

In the event that cultural materials are identified during project construction activities that are determined to be tribal cultural resources, implementation of Mitigation Measure CUL-1a: Cultural Resources Awareness Training, Mitigation Measure CUL-1b:

Inadvertent Discovery of Cultural Materials or Tribal Cultural Resources, and Mitigation Measure CUL-2: Inadvertent Discovery of Human Remains, all identified above in Section 4.5, Cultural Resources, would reduce potentially significant impacts to less than significant. These mitigation measures would ensure that all personnel complete a cultural resources awareness training prior to any ground-disturbing activity and that work halt in the vicinity of a find until a qualified archaeologist and a Native American representative can make an assessment and provide additional recommendations.

References
Northwest Information Center (NWIC), Records Search File No. File No. 21-1575. On file, ESA, March 23, 2022.
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4.17 Utilities and Service Systems
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Utilities and Service Systems
Would the project:
a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or
stormwater 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?

Setting
The project site, within the WCCSL BMPC property, is currently served by all public utilities, including water and wastewater treatment by EBMUD and West County Wastewater District, respectively, as well as the reuse of runoff water, and PG&E provides electric power, natural gas.

Evaluation
a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
Less than Significant Impact. The existing WCCSL would use offtake approximately

0.5 MW hour from the power generation for Republic’s onsite operation needs and the rest would be used to power the proposed project. Any additional electrical power required beyond that generated onsite, including that required as LFG may supplies diminish or are depleted, would come from an existing PG&E power drop to the site and/or a renewable source. The project would also involve a new 250,000-gallon 1014

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integrated fire water tank and diesel engine for emergency use, per fire regulations, but would continue to be served by RFD and the West County Fire District. As previously discussed in 4.14, Public Services and Recreation, all construction-related mitigation measures identified in this analysis would apply to that development onsite, which would ensure any environmental effects from the project would be less than significant. b) 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. Steam is injected into the process to promote the thermal decomposition of the feedstock. Estimated water flow required for boiler feedwater and for cooling tower make-up is about 70 percent of the total required and is on the order of 60 gallons per minute (gpm) (81,500 gallons per day [gpd]). Adding in required water flow for overall processes and wash water for cleaning, the total water flow required for the project is estimated to be 81 gpm (116,200 gpd) (Raven SR, 2022b).

Potable water is available for both domestic and fire protection to the subject property from existing major facilities (e.g., reservoirs, pumping plants), which are serviced and maintained by EBMUD. Service would be granted subject to compliance with the District’s regulations governing water service and Schedule of Rates and Charges, which may include water main extensions and/or off-site pipeline improvements (Raven SR, 2022c). For this analysis, it is not anticipated that the proposed project would require new water supplies for its operation to the extent that it would make future water supplies insufficient during future scenarios considering foreseeable future development. The impact would be less than significant.
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? Less than Significant Impact. Wastewater generated by the process is mainly cooling tower blowdown, RO system blowdown, and boiler system blowdown, along with a small flow from the syngas wash columns. Intermittent flow is from potable sources (restrooms, sinks, etc.) and area wash down water. Wastewater would be generated from the syngas wash columns, which can potentially contain low concentrations of organic compounds. Wastewater would be treated before it is discharged to the sewer systems through sump and grease/oil where the organic content would be removed for capture/reclaim/disposal, and the water portion sent to the wastewater sewer.

Total wastewater discharge from all project processes (or waste streams) is estimated to be 50,200 gallons per day, and the West County Wastewater District would permit this additional use upon its determination that the discharge may be covered by the Districts’ Pretreatment and/or Pollution Prevention programs (Raven SR, 2022b).

Discussions are occurring between the Pproject Aapplicant and the West County Wastewater District and are in the permitting process. At this time, there are no 1015

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anticipated capacity issues expected. Given the small scale of the proposed project, the lack of notable new population onsite, it is reasonable that the West County Wastewater District, as wastewater treatment provider, would maintain adequate capacity to meet its demands with the addition of the proposed project. The impact would be less than significant.
d,e) 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? Comply with federal, State, and local management and reduction statutes and regulations related to solid waste?
Less than Significant Impact. The project would not generate substantial solid waste but would convert existing organic waste into a reusable fuel product. Therefore, the project would not conflict with existing local or other laws or policies regarding the reduction, reuse and management of solid waste. The impact would be less than significant.

References
City of Richmond, 2012. Richmond General Plan Update Environmental Impact Report. SCH. 2008022018. 2012.

Contra Costa County 2004. Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions, SCH. 2002102057. June 2004.

Contra Costa County 2009. Addendum to the Final EIR for the WCCSL BMPC and Related Actions, SCH. 2002102057. 2009.

RAVEN SR, 2022b. West County Wastewater District Wastewater Discharge Permit Application. October 2022.

RAVEN SR, 2022c. Correspondence from Tracy Barrow, East Bay Municipal Utilities District, to Mike Fatigati, Raven SR. September 2022.
______________________________
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4.18 Wildfire
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Wildfire
If located in or near State Responsibility Areas or lands classified as very high fire hazard severity zones, would the project:
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 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?

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?

Setting
The project site borders expansive non-native grassland and ruderal species in open and that can get very dry during summer months. Factors that contribute to the risk of fire include dense and fire-prone vegetation, poor access to fire-fighting equipment because of slopes or inadequate roads, lack of adequate water pressure and service in fire-prone locations, and seasonal atmospheric conditions that result in warm, dry fire seasons with strong afternoon winds. Wildfire hazard maps show the site as not being within a high wildfire hazard zone (CPUC, 2018).

Evaluation
a) Substantially impair an adopted emergency response plan or emergency evacuation plan?
Less than Significant Impact. As discussed under Section 4.15, Transportation, the project would not modify the access point to the existing WCCSL facility, the internal circulation within WCCSL, or the public right-of-way. Therefore, the project would not impair any existing plans for emergency response or evaluation. The impact would be less than significant.
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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?
Less than Significant Impact. Certain project characteristics could have the potential to exacerbate wildfire risks, such as diesel fuel storage for the fire water take. However, no hazardous materials would be used in the conversion process. The biocarbon materials produced are inert to the process (i.e., not gasified). Also, the conversion process also derives electricityfrom fuel cells or turbines and/or internal combustion engine generator sets.

The project site is relatively flat, within the context of marshlands and Bay shoreline, and would also include a new fire water tank and diesel engine per fire regulations onsite. The tank would be used for emergency use, although the project site would still being served by the RFD and the West County Fire District. The impact would be less than significant. c) 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?
No Impact. The project site is fully served by existing infrastructure that currently service the WCCSL operations. It would not require the installation or maintenance of additional infrastructure that may exacerbate fire risk. There would be no impact. 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
Less than Significant Impact. The project would not introduce new people on the site, other than up to three to four employees per shift. As previously mentioned, the site is relatively flat, not located within downstream flood or landslide areas. The proposed project is not located in a high wildfire hazard zone (CPUC, 2018). The impact would be less than significant.

References
California Public Utilities Commission. Fire-Threat Map – State of California. January 19, 2018.

City of Richmond, 2011. General Plan 2030 – Map 12.6 Police and Fire Services. August 2011.

City of Richmond, 2012. Richmond General Plan Update Environmental Impact Report. SCH. 2008022018. 2012.
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4.19 Mandatory Findings of Significance
Environmental Issues
Potentially
Significant
Impact
Less than
Significant
Impact with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Mandatory Findings of Significance
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, which
will cause substantial adverse effects on human
beings, either directly or indirectly?

Findings
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?
Less than Significant Impact, after Mitigation. The proposed project may result in potential construction-related impacts to nesting special-status birds and to California Black Rail and California Ridgway’s Rail. The potential impacts are reduced to less than significant by requiring surveys and avoidance of construction-related work during specific times of year:
 Mitigation Measure BIO-1: Avoid and Minimize Impacts to Nesting Birds, Except Rails
 Mitigation Measure BIO-2: Avoid and Minimize Impacts to California Black Rail and California Ridgway’s Rail
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The proposed project may result in potential impacts to Cultural Resources, Paleontological Resources (Geology and Soils), and Tribal Cultural Resources, unless the following mitigation measures are implemented, which would reduce the potential impacts to less than significant:
 Mitigation Measure CUL-1a: Cultural Resources Awareness Training  Mitigation Measure CUL-1b: Inadvertent Discovery of Cultural Materials or Tribal Cultural Resources
 Mitigation Measure CUL-2: Inadvertent Discovery of Human Remains. 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)? Less than Significant Impact, after Mitigation. CEQA Guidelines Section 15355 defines a cumulative impact as the condition under which “two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts. The cumulative impact from several projects is the change in the environment which results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects.” (California Code of Regulations [C.C.R.] Section 15355). The purpose of the cumulative analysis is to understand the incremental impacts of the project on the neighboring areas.

The project does not result in a cumulative considerationcumulatively considerable impact for any environmental factors. The HRA evaluated the Raven SR project’s contribution to cumulative health risk-related impacts based on CEQA’s requirements for evaluating cumulative impacts and the BAAQMD’s methodology for calculating a proposed project’s contribution to background risk. The project’s contribution to cumulative health risk-related impact was less than significant. The Raven SR project impacts were measured against baseline conditions on the project site. The Raven SR project lessens air quality impacts when measured against the impacts generated by the existing WCCSL operations. CCTA Guidelines (which the City has adopted) require a cumulative analysis only if a project impact is significant and unavoidable. Moreover, the project is below the VMT screening criterion and therefore presumed to have a less than significant transportation impact. For comparative purposes, the project’s total VMT considering cumulative growth is substantially below the applicable threshold.23 One common exception, this evaluation does identify the BAAQMD Basic Construction Mitigation Measures Recommended for All Projects (Best Management Practices) to address fugitive dust during construction, which applies even though the project’s construction air emissions are all below the BAAQMD CEQA thresholds of significance. 23 The 2040 VMT rate is 15.0, so the total VMT = 12 daily trips x 15.0 = 180, compared to the 836 threshold (see Table 4.15-2).
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The BMPs also apply to all individual projects and ensure that a significant impact with respect to fugitive dust is less than significant.
 Mitigation Measure AQ-1: Best Management Practices.

Given the relatively small scope of the proposed project, its limited potential impacts, as well as the Also, the mitigation measures identified in this Draftupdated IS/MND to address potentially significant impacts would also apply to other cumulative projects that have or could occur concurrently with the proposed project and effective reduce or avoid potential combined significant effects.and listed below, the The incremental effects of the project are not cumulatively considerable when considered with the potential effects of past, current, and probable future projects. The project does not have any significant cumulative impacts. Impacts would be less than significant. c) Does the project have environmental effects, which will cause substantial adverse effects on human beings, either directly or indirectly? Less than Significant Impact, after Mitigation. All impacts identified in this Draftupdated IS/MND are either less than significant after implementation of identified mitigation measures (all listed in criterion “a” above and below in this criterion “c”), or less than significant without the need for mitigation. Of those impacts that require mitigation, only the potential impact of PM10 and PM2.5 (fugitive dust) being added to the local atmosphere during construction has the potential to adversely affect human beings, directly or indirectly. As discussed under finding “b” above, tThe project’s implementation of Mitigation Measure AQ-1: Best Management Practices, would reduce the impact to less than significant.

All mitigation measures identified for the proposed project, and clarified in this updated IS/MND, are listed in the updated Draft Mitigation Monitoring and Reporting Program (MMRP) in Appendix C to this document.
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5. Document Preparers

5.1 CEQA Consultant
ESA
180 Grand Avenue – Suite 1050
Oakland, CA 94612
Phone 510.839.5066
Project Director Crescentia Brown
Project Manager Tim Sturtz
Air Quality/GHG Chris Easter, Director
Air Quality/GHG Tim Sturtz, Principal
Sarah Patterson, Analyst
Madison Castelazo, Analyst
Human Health Risk Tim Sturtz, Principal/Peer Review
Sarah Patterson, Analyst/Peer Review
Energy Bailey Setzler, Planner
Sarah Patterson, Analyst/Peer Review
Noise/Vibration Chris Sanchez, Senior Technical Associate Hazardous Materials Michael Burns, Environmental Scientist Biological Resources Sharon, Dulava, Biologist
Cultural Resources Heidi Koenig, RPA
Tribal Consultation Heidi Koenig, RPA
Senior Review / Other Topics Crescentia Brown
Graphics Ron Teitel

5.2 Technical Subconsultant
Fehr & Peers Transportation
2201 Broadway – Suite 602
Oakland, CA 94612
Phone 510.835.1943
Transportation Sam Tabibnia, Senior Associate
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APPENDIX A
Emissions Data, Assumptions and Modeling Files
A.1-1 Original Emissions Data, Assumptions and
Modeling Files
A.2-1 Updated Air Quality and Greenhouse Gas
Assessment Technical Memo
A.2-2 Updated Air Quality and New Health Risk
Assessment Technical Memo
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A.1-1 Original Emissions Data, Assumptions and
Modeling Files
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RAVEN
Contra Costa County, Annual
Project Characteristics -
Land Use - Project specific info
Construction Phase - Project specific information
Off-road Equipment - Project specific information
Off-road Equipment - Project specific information
Off-road Equipment - Project specific information
Off-road Equipment - Project specific information
Trips and VMT - Client provided information
Grading - Project specific information
Vehicle Trips - Project specific information
Area Coating - Project specific information

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population General Light Industry 40.00 1000sqft 1.30 40,000.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
5 Wind Speed (m/s) 2.2 Precipitation Freq (Days) 58

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Pacific Gas and Electric Company
Operational Year 2023
CO2 Intensity
(lb/MWhr)
203.98 CH4 Intensity 0.033
(lb/MWhr)
N2O Intensity 0.004
(lb/MWhr)
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EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 1030
Construction Off-road Equipment Mitigation -
Operational Off-Road Equipment - Project specific information Stationary Sources - Emergency Generators and Fire Pumps - Table Name Column Name Default Value New Value
tblConstructionPhase NumDays 200.00 138.00
tblConstructionPhase NumDays 20.00 5.00
tblConstructionPhase NumDays 4.00 30.00
tblConstructionPhase NumDays 2.00 30.00
tblGrading AcresOfGrading 15.00 4.00
tblLandUse LotAcreage 0.92 1.30
tblOffRoadEquipment HorsePower 97.00 247.00
tblOffRoadEquipment HorsePower 78.00 81.00
tblOffRoadEquipment HorsePower 78.00 97.00
tblOffRoadEquipment HorsePower 212.00 187.00
tblOffRoadEquipment HorsePower 85.00 247.00
tblOffRoadEquipment HorsePower 158.00 97.00
tblOffRoadEquipment HorsePower 158.00 187.00
tblOffRoadEquipment HorsePower 80.00 247.00
tblOffRoadEquipment HorsePower 100.00 97.00
tblOffRoadEquipment HorsePower 100.00 89.00
tblOffRoadEquipment LoadFactor 0.37 0.40
tblOffRoadEquipment LoadFactor 0.48 0.73
tblOffRoadEquipment LoadFactor 0.48 0.37
tblOffRoadEquipment LoadFactor 0.43 0.41
tblOffRoadEquipment LoadFactor 0.78 0.40
tblOffRoadEquipment LoadFactor 0.38 0.37
tblOffRoadEquipment LoadFactor 0.38 0.41
tblOffRoadEquipment LoadFactor 0.38 0.40
CalEEMod Version: CalEEMod.2020.4.0 Page 2 of 28 Date: 8/11/2022 11:05 AM RAVEN - Contra Costa County, Annual
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2.0 Emissions Summary
tblOffRoadEquipment LoadFactor 0.40 0.37
tblOffRoadEquipment LoadFactor 0.40 0.20
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 1.00 tblOffRoadEquipment OffRoadEquipmentUnitAmount 3.00 2.00 tblOffRoadEquipment UsageHours 6.00 8.00
tblOffRoadEquipment UsageHours 7.00 8.00
tblOperationalOffRoadEquipment OperDaysPerYear 260.00 365.00 tblOperationalOffRoadEquipment OperHoursPerDay 8.00 24.00 tblOperationalOffRoadEquipment OperOffRoadEquipmentNumber 0.00 1.00 tblTripsAndVMT HaulingTripNumber 0.00 20.00
tblTripsAndVMT HaulingTripNumber 0.00 32.00
tblTripsAndVMT HaulingTripNumber 0.00 20.00
tblTripsAndVMT VendorTripNumber 7.00 4.00
tblTripsAndVMT WorkerTripNumber 10.00 2.00
tblTripsAndVMT WorkerTripNumber 20.00 2.00
tblTripsAndVMT WorkerTripNumber 10.00 2.00
tblTripsAndVMT WorkerTripNumber 17.00 2.00
tblVehicleTrips ST_TR 1.99 0.67
tblVehicleTrips SU_TR 5.00 0.67
tblVehicleTrips WD_TR 4.96 0.67
CalEEMod Version: CalEEMod.2020.4.0 Page 3 of 28 Date: 8/11/2022 11:05 AM RAVEN - Contra Costa County, Annual
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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
2022 0.1109 1.0010 0.9211 2.0500e0034.8300e0030.0433 0.0481 9.8000e0040.0411 0.0420 0.0000 176.5135 176.5135 0.0420 8.4000e004177.8124 2023 0.0572 0.4813 0.5134 9.4000e0041.3300e0030.0217 0.0230 3.7000e0040.0208 0.0212 0.0000 80.1650 80.1650 0.0148 3.8000e00480.6476 Maximum 0.1109 1.0010 0.9211 2.0500e0034.8300e0030.0433 0.0481 9.8000e0040.0411 0.0420 0.0000 176.5135 176.5135 0.0420 8.4000e004177.8124 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
2022 0.1109 1.0010 0.9211 2.0500e0033.6600e0030.0433 0.0469 8.5000e0040.0411 0.0419 0.0000 176.5133 176.5133 0.0420 8.4000e004177.8122 2023 0.0572 0.4813 0.5134 9.4000e0041.3300e0030.0217 0.0230 3.7000e0040.0208 0.0212 0.0000 80.1649 80.1649 0.0148 3.8000e00480.6476 Maximum 0.1109 1.0010 0.9211 2.0500e0033.6600e0030.0433 0.0469 8.5000e0040.0411 0.0419 0.0000 176.5133 176.5133 0.0420 8.4000e004177.8122 Mitigated Construction
CalEEMod Version: CalEEMod.2020.4.0 Page 4 of 28 Date: 8/11/2022 11:05 AM RAVEN - Contra Costa County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied 1033
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 18.99 0.00 1.64 9.63 0.00 0.21 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 7-1-2022 9-30-2022 0.4036 0.4036
2 10-1-2022 12-31-2022 0.6761 0.6761
3 1-1-2023 3-31-2023 0.5375 0.5375
Highest 0.6761 0.6761

2.2 Overall Operational
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
Area 0.1771 0.0000 3.7000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 7.1000e0047.1000e0040.0000 0.0000 7.6000e004 Energy 5.3000e0030.0482 0.0405 2.9000e0043.6600e0033.6600e0033.6600e0033.6600e0030.0000 79.9440 79.9440 5.4500e0031.5000e00380.5276 Mobile 0.0133 0.0161 0.1306 2.8000e0040.0289 2.1000e0040.0292 7.7300e0031.9000e0047.9200e0030.0000 25.5208 25.5208 1.5700e0031.1800e00325.9122 Offroad 0.1481 1.4534 0.8266 3.4300e0030.0487 0.0487 0.0448 0.0448 0.0000 300.7720 300.7720 0.0973 0.0000 303.2039 Waste 0.0000 0.0000 0.0000 0.0000 10.0684 0.0000 10.0684 0.5950 0.0000 24.9439 Water 0.0000 0.0000 0.0000 0.0000 2.9346 4.6310 7.5656 0.3022 7.2100e00317.2675 Total 0.3438 1.5177 0.9981 4.0000e0030.0289 0.0525 0.0815 7.7300e0030.0486 0.0564 13.0030 410.8685 423.8714 1.0015 9.8900e003451.8558 Unmitigated Operational
CalEEMod Version: CalEEMod.2020.4.0 Page 5 of 28 Date: 8/11/2022 11:05 AM RAVEN - Contra Costa County, Annual
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2.2 Overall Operational
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
Area 0.1771 0.0000 3.7000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 7.1000e0047.1000e0040.0000 0.0000 7.6000e004 Energy 5.3000e0030.0482 0.0405 2.9000e0043.6600e0033.6600e0033.6600e0033.6600e0030.0000 79.9440 79.9440 5.4500e0031.5000e00380.5276 Mobile 0.0133 0.0161 0.1306 2.8000e0040.0289 2.1000e0040.0292 7.7300e0031.9000e0047.9200e0030.0000 25.5208 25.5208 1.5700e0031.1800e00325.9122 Offroad 0.1481 1.4534 0.8266 3.4300e0030.0487 0.0487 0.0448 0.0448 0.0000 300.7720 300.7720 0.0973 0.0000 303.2039 Waste 0.0000 0.0000 0.0000 0.0000 10.0684 0.0000 10.0684 0.5950 0.0000 24.9439 Water 0.0000 0.0000 0.0000 0.0000 2.9346 4.6310 7.5656 0.3022 7.2100e00317.2675 Total 0.3438 1.5177 0.9981 4.0000e0030.0289 0.0525 0.0815 7.7300e0030.0486 0.0564 13.0030 410.8685 423.8714 1.0015 9.8900e003451.8558 Mitigated Operational

3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 7/18/2022 7/22/2022 5 5
2 Site Preparation Site Preparation 7/25/2022 9/2/2022 5 30 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 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2020.4.0 Page 6 of 28 Date: 8/11/2022 11:05 AM RAVEN - Contra Costa County, Annual
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3 Grading Grading 9/5/2022 10/14/2022 5 30
4 Building Construction Building Construction 9/19/2022 3/29/2023 5 138 OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Demolition Air Compressors 1 8.00 81 0.73
Demolition Crushing/Proc. Equipment 1 8.00 247 0.40
Demolition Dumpers/Tenders 1 8.00 16 0.38
Demolition Excavators 1 8.00 97 0.37
Site Preparation Dumpers/Tenders 1 8.00 16 0.38
Site Preparation Excavators 3 8.00 187 0.41
Site Preparation Plate Compactors 2 8.00 8 0.43
Site Preparation Rough Terrain Forklifts 1 8.00 97 0.37 Site Preparation Tractors/Loaders/Backhoes 1 8.00 247 0.40 Grading Crawler Tractors 1 8.00 187 0.41
Grading Excavators 1 8.00 158 0.38
Grading Rollers 1 8.00 247 0.40
Grading Tractors/Loaders/Backhoes 1 8.00 97 0.37
Building Construction Air Compressors 1 8.00 97 0.37
Building Construction Cranes 1 8.00 231 0.29
Building Construction Generator Sets 1 8.00 84 0.74
Building Construction Other Construction Equipment 1 8.00 172 0.42 Building Construction Rough Terrain Forklifts 1 8.00 89 0.20 Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural Coating – sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 4
Acres of Paving: 0
CalEEMod Version: CalEEMod.2020.4.0 Page 7 of 28 Date: 8/11/2022 11:05 AM RAVEN - Contra Costa County, Annual
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3.2 Demolition - 2022
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 2.7900e0030.0193 0.0205 5.0000e0059.1000e0049.1000e0048.9000e0048.9000e0040.0000 4.3996 4.3996 4.1000e0040.0000 4.4099 Total 2.7900e0030.0193 0.0205 5.0000e0059.1000e0049.1000e0048.9000e0048.9000e0040.0000 4.3996 4.3996 4.1000e0040.0000 4.4099 Unmitigated Construction On-Site

3.1 Mitigation Measures Construction
Water Exposed Area
Building Construction Welders 2 8.00 46 0.45
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
Demolition 4 2.00 0.00 20.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Site Preparation 8 2.00 0.00 32.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Grading 4 2.00 0.00 20.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT Building Construction 7 2.00 4.00 0.00 10.80 7.30 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2020.4.0 Page 8 of 28 Date: 8/11/2022 11:05 AM RAVEN - Contra Costa County, Annual
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3.2 Demolition - 2022
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 5.0000e0051.7100e0033.6000e0041.0000e0051.7000e0042.0000e0051.9000e0045.0000e0051.0000e0056.0000e0050.0000 0.6262 0.6262 2.0000e0051.0000e0040.6563 Vendor 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 Worker 1.0000e0051.0000e0051.2000e0040.0000 4.0000e0050.0000 4.0000e0051.0000e0050.0000 1.0000e0050.0000 0.0319 0.0319 0.0000 0.0000 0.0322 Total 6.0000e0051.7200e0034.8000e0041.0000e0052.1000e0042.0000e0052.3000e0046.0000e0051.0000e0057.0000e0050.0000 0.6581 0.6581 2.0000e0051.0000e0040.6884 Unmitigated Construction Off-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
Off-Road 2.7900e0030.0193 0.0205 5.0000e0059.1000e0049.1000e0048.9000e0048.9000e0040.0000 4.3996 4.3996 4.1000e0040.0000 4.4099 Total 2.7900e0030.0193 0.0205 5.0000e0059.1000e0049.1000e0048.9000e0048.9000e0040.0000 4.3996 4.3996 4.1000e0040.0000 4.4099 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 9 of 28 Date: 8/11/2022 11:05 AM RAVEN - Contra Costa County, Annual
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3.2 Demolition - 2022
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 5.0000e0051.7100e0033.6000e0041.0000e0051.7000e0042.0000e0051.9000e0045.0000e0051.0000e0056.0000e0050.0000 0.6262 0.6262 2.0000e0051.0000e0040.6563 Vendor 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 Worker 1.0000e0051.0000e0051.2000e0040.0000 4.0000e0050.0000 4.0000e0051.0000e0050.0000 1.0000e0050.0000 0.0319 0.0319 0.0000 0.0000 0.0322 Total 6.0000e0051.7200e0034.8000e0041.0000e0052.1000e0042.0000e0052.3000e0046.0000e0051.0000e0057.0000e0050.0000 0.6581 0.6581 2.0000e0051.0000e0040.6884 Mitigated Construction Off-Site

3.3 Site Preparation - 2022
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 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0177 0.1696 0.1377 5.0000e0045.6500e0035.6500e0035.2400e0035.2400e0030.0000 43.0480 43.0480 0.0135 0.0000 43.3865 Total 0.0177 0.1696 0.1377 5.0000e0040.0000 5.6500e0035.6500e0030.0000 5.2400e0035.2400e0030.0000 43.0480 43.0480 0.0135 0.0000 43.3865 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 10 of 28 Date: 8/11/2022 11:05 AM RAVEN - Contra Costa County, Annual
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3.3 Site Preparation - 2022
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 7.0000e0052.7400e0035.8000e0041.0000e0052.7000e0042.0000e0053.0000e0047.0000e0052.0000e0051.0000e0040.0000 1.0019 1.0019 3.0000e0051.6000e0041.0501 Vendor 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 Worker 8.0000e0056.0000e0057.3000e0040.0000 2.4000e0040.0000 2.4000e0046.0000e0050.0000 6.0000e0050.0000 0.1911 0.1911 1.0000e0051.0000e0050.1929 Total 1.5000e0042.8000e0031.3100e0031.0000e0055.1000e0042.0000e0055.4000e0041.3000e0042.0000e0051.6000e0040.0000 1.1930 1.1930 4.0000e0051.7000e0041.2430 Unmitigated Construction Off-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
Fugitive Dust 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0177 0.1696 0.1377 5.0000e0045.6500e0035.6500e0035.2400e0035.2400e0030.0000 43.0480 43.0480 0.0135 0.0000 43.3864 Total 0.0177 0.1696 0.1377 5.0000e0040.0000 5.6500e0035.6500e0030.0000 5.2400e0035.2400e0030.0000 43.0480 43.0480 0.0135 0.0000 43.3864 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 11 of 28 Date: 8/11/2022 11:05 AM RAVEN - Contra Costa County, Annual
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3.3 Site Preparation - 2022
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 7.0000e0052.7400e0035.8000e0041.0000e0052.7000e0042.0000e0053.0000e0047.0000e0052.0000e0051.0000e0040.0000 1.0019 1.0019 3.0000e0051.6000e0041.0501 Vendor 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 Worker 8.0000e0056.0000e0057.3000e0040.0000 2.4000e0040.0000 2.4000e0046.0000e0050.0000 6.0000e0050.0000 0.1911 0.1911 1.0000e0051.0000e0050.1929 Total 1.5000e0042.8000e0031.3100e0031.0000e0055.1000e0042.0000e0055.4000e0041.3000e0042.0000e0051.6000e0040.0000 1.1930 1.1930 4.0000e0051.7000e0041.2430 Mitigated Construction Off-Site

3.4 Grading - 2022
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 2.1200e0030.0000 2.1200e0032.3000e0040.0000 2.3000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0166 0.1854 0.1437 3.5000e0047.5100e0037.5100e0036.9100e0036.9100e0030.0000 30.8182 30.8182 9.9700e0030.0000 31.0674 Total 0.0166 0.1854 0.1437 3.5000e0042.1200e0037.5100e0039.6300e0032.3000e0046.9100e0037.1400e0030.0000 30.8182 30.8182 9.9700e0030.0000 31.0674 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0 Page 12 of 28 Date: 8/11/2022 11:05 AM RAVEN - Contra Costa County, Annual
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3.4 Grading - 2022
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 5.0000e0051.7100e0033.6000e0041.0000e0051.7000e0042.0000e0051.9000e0045.0000e0051.0000e0056.0000e0050.0000 0.6262 0.6262 2.0000e0051.0000e0040.6563 Vendor 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 Worker 8.0000e0056.0000e0057.3000e0040.0000 2.4000e0040.0000 2.4000e0046.0000e0050.0000 6.0000e0050.0000 0.1911 0.1911 1.0000e0051.0000e0050.1929 Total 1.3000e0041.7700e0031.0900e0031.0000e0054.1000e0042.0000e0054.3000e0041.1000e0041.0000e0051.2000e0040.0000 0.8173 0.8173 3.0000e0051.1000e0040.8492 Unmitigated Construction Off-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
Fugitive Dust 9.5000e0040.0000 9.5000e0041.0000e0040.0000 1.0000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0166 0.1854 0.1437 3.5000e0047.5100e0037.5100e0036.9100e0036.9100e0030.0000 30.8182 30.8182 9.9700e0030.0000 31.0674 Total 0.0166 0.1854 0.1437 3.5000e0049.5000e0047.5100e0038.4600e0031.0000e0046.9100e0037.0100e0030.0000 30.8182 30.8182 9.9700e0030.0000 31.0674 Mitigated Construction On-Site
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3.4 Grading - 2022
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 5.0000e0051.7100e0033.6000e0041.0000e0051.7000e0042.0000e0051.9000e0045.0000e0051.0000e0056.0000e0050.0000 0.6262 0.6262 2.0000e0051.0000e0040.6563 Vendor 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 Worker 8.0000e0056.0000e0057.3000e0040.0000 2.4000e0040.0000 2.4000e0046.0000e0050.0000 6.0000e0050.0000 0.1911 0.1911 1.0000e0051.0000e0050.1929 Total 1.3000e0041.7700e0031.0900e0031.0000e0054.1000e0042.0000e0054.3000e0041.1000e0041.0000e0051.2000e0040.0000 0.8173 0.8173 3.0000e0051.1000e0040.8492 Mitigated Construction Off-Site

3.5 Building Construction - 2022
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 0.0729 0.6117 0.6119 1.0900e0030.0291 0.0291 0.0279 0.0279 0.0000 91.9681 91.9681 0.0179 0.0000 92.4146 Total 0.0729 0.6117 0.6119 1.0900e0030.0291 0.0291 0.0279 0.0279 0.0000 91.9681 91.9681 0.0179 0.0000 92.4146 Unmitigated Construction On-Site
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3.5 Building Construction - 2022
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 3.5000e0048.5500e0032.5900e0033.0000e0059.9000e0049.0000e0051.0800e0032.9000e0049.0000e0053.8000e0040.0000 3.1336 3.1336 7.0000e0054.6000e0043.2713 Worker 2.1000e0041.5000e0041.8200e0031.0000e0055.9000e0040.0000 6.0000e0041.6000e0040.0000 1.6000e0040.0000 0.4777 0.4777 2.0000e0051.0000e0050.4823 Total 5.6000e0048.7000e0034.4100e0034.0000e0051.5800e0039.0000e0051.6800e0034.5000e0049.0000e0055.4000e0040.0000 3.6113 3.6113 9.0000e0054.7000e0043.7535 Unmitigated Construction Off-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
Off-Road 0.0729 0.6117 0.6119 1.0900e0030.0291 0.0291 0.0279 0.0279 0.0000 91.9680 91.9680 0.0179 0.0000 92.4145 Total 0.0729 0.6117 0.6119 1.0900e0030.0291 0.0291 0.0279 0.0279 0.0000 91.9680 91.9680 0.0179 0.0000 92.4145 Mitigated Construction On-Site
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3.5 Building Construction - 2022
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 3.5000e0048.5500e0032.5900e0033.0000e0059.9000e0049.0000e0051.0800e0032.9000e0049.0000e0053.8000e0040.0000 3.1336 3.1336 7.0000e0054.6000e0043.2713 Worker 2.1000e0041.5000e0041.8200e0031.0000e0055.9000e0040.0000 6.0000e0041.6000e0040.0000 1.6000e0040.0000 0.4777 0.4777 2.0000e0051.0000e0050.4823 Total 5.6000e0048.7000e0034.4100e0034.0000e0051.5800e0039.0000e0051.6800e0034.5000e0049.0000e0055.4000e0040.0000 3.6113 3.6113 9.0000e0054.7000e0043.7535 Mitigated Construction Off-Site

3.5 Building Construction - 2023
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 0.0569 0.4756 0.5101 9.1000e0040.0217 0.0217 0.0208 0.0208 0.0000 77.2516 77.2516 0.0148 0.0000 77.6205 Total 0.0569 0.4756 0.5101 9.1000e0040.0217 0.0217 0.0208 0.0208 0.0000 77.2516 77.2516 0.0148 0.0000 77.6205 Unmitigated Construction On-Site
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3.5 Building Construction - 2023
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 1.4000e0045.6200e0031.8400e0033.0000e0058.3000e0043.0000e0058.6000e0042.4000e0043.0000e0052.7000e0040.0000 2.5248 2.5248 5.0000e0053.7000e0042.6349 Worker 1.6000e0041.1000e0041.4100e0030.0000 5.0000e0040.0000 5.0000e0041.3000e0040.0000 1.4000e0040.0000 0.3886 0.3886 1.0000e0051.0000e0050.3922 Total 3.0000e0045.7300e0033.2500e0033.0000e0051.3300e0033.0000e0051.3600e0033.7000e0043.0000e0054.1000e0040.0000 2.9134 2.9134 6.0000e0053.8000e0043.0271 Unmitigated Construction Off-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
Off-Road 0.0569 0.4756 0.5101 9.1000e0040.0217 0.0217 0.0208 0.0208 0.0000 77.2515 77.2515 0.0148 0.0000 77.6204 Total 0.0569 0.4756 0.5101 9.1000e0040.0217 0.0217 0.0208 0.0208 0.0000 77.2515 77.2515 0.0148 0.0000 77.6204 Mitigated Construction On-Site
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3.5 Building Construction - 2023
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 1.4000e0045.6200e0031.8400e0033.0000e0058.3000e0043.0000e0058.6000e0042.4000e0043.0000e0052.7000e0040.0000 2.5248 2.5248 5.0000e0053.7000e0042.6349 Worker 1.6000e0041.1000e0041.4100e0030.0000 5.0000e0040.0000 5.0000e0041.3000e0040.0000 1.4000e0040.0000 0.3886 0.3886 1.0000e0051.0000e0050.3922 Total 3.0000e0045.7300e0033.2500e0033.0000e0051.3300e0033.0000e0051.3600e0033.7000e0043.0000e0054.1000e0040.0000 2.9134 2.9134 6.0000e0053.8000e0043.0271 Mitigated Construction Off-Site
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4.0 Operational Detail - Mobile
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
Mitigated 0.0133 0.0161 0.1306 2.8000e0040.0289 2.1000e0040.0292 7.7300e0031.9000e0047.9200e0030.0000 25.5208 25.5208 1.5700e0031.1800e00325.9122 Unmitigated 0.0133 0.0161 0.1306 2.8000e0040.0289 2.1000e0040.0292 7.7300e0031.9000e0047.9200e0030.0000 25.5208 25.5208 1.5700e0031.1800e00325.9122

4.1 Mitigation Measures Mobile

4.2 Trip Summary Information

4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
General Light Industry 26.80 26.80 26.80 78,243 78,243
Total 26.80 26.80 26.80 78,243 78,243
Miles Trip % Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by General Light Industry 9.50 7.30 7.30 59.00 28.00 13.00 92 5 3

4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH General Light Industry 0.558086 0.056127 0.180570 0.129764 0.024304 0.005480 0.007016 0.007028 0.000551 0.000343 0.026017 0.001231 0.003481 CalEEMod Version: CalEEMod.2020.4.0 Page 19 of 28 Date: 8/11/2022 11:05 AM RAVEN - Contra Costa County, Annual
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5.0 Energy Detail
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
Electricity
Mitigated

0.0000 0.0000 0.0000 0.0000 0.0000 27.4981 27.4981 4.4500e0035.4000e00427.7700 Electricity
Unmitigated

0.0000 0.0000 0.0000 0.0000 0.0000 27.4981 27.4981 4.4500e0035.4000e00427.7700 NaturalGas
Mitigated

5.3000e0030.0482 0.0405 2.9000e0043.6600e0033.6600e0033.6600e0033.6600e0030.0000 52.4460 52.4460 1.0100e0039.6000e00452.7576 NaturalGas
Unmitigated

5.3000e0030.0482 0.0405 2.9000e0043.6600e0033.6600e0033.6600e0033.6600e0030.0000 52.4460 52.4460 1.0100e0039.6000e00452.7576

5.1 Mitigation Measures Energy
Historical Energy Use: N
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5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
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
Land Use kBTU/yr tons/yr MT/yr
General Light
Industry
982800 5.3000e0030.0482 0.0405 2.9000e0043.6600e0033.6600e0033.6600e0033.6600e0030.0000 52.4460 52.4460 1.0100e0039.6000e00452.7576 Total 5.3000e0030.0482 0.0405 2.9000e0043.6600e0033.6600e0033.6600e0033.6600e0030.0000 52.4460 52.4460 1.0100e0039.6000e00452.7576 Unmitigated
NaturalGa
s Use
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
Land Use kBTU/yr tons/yr MT/yr
General Light
Industry
982800 5.3000e0030.0482 0.0405 2.9000e0043.6600e0033.6600e0033.6600e0033.6600e0030.0000 52.4460 52.4460 1.0100e0039.6000e00452.7576 Total 5.3000e0030.0482 0.0405 2.9000e0043.6600e0033.6600e0033.6600e0033.6600e0030.0000 52.4460 52.4460 1.0100e0039.6000e00452.7576 Mitigated
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6.1 Mitigation Measures Area

6.0 Area Detail

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
General Light
Industry
297200 27.4981 4.4500e0035.4000e00427.7700
Total 27.4981 4.4500e0035.4000e00427.7700
Unmitigated
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
General Light
Industry
297200 27.4981 4.4500e0035.4000e00427.7700
Total 27.4981 4.4500e0035.4000e00427.7700
Mitigated
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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
Mitigated 0.1771 0.0000 3.7000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 7.1000e0047.1000e0040.0000 0.0000 7.6000e004 Unmitigated 0.1771 0.0000 3.7000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 7.1000e0047.1000e0040.0000 0.0000 7.6000e004

6.2 Area by SubCategory
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
SubCategory tons/yr MT/yr
Architectural
Coating

0.0209 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

0.1562 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Landscaping 3.0000e0050.0000 3.7000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 7.1000e0047.1000e0040.0000 0.0000 7.6000e004 Total 0.1771 0.0000 3.7000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 7.1000e0047.1000e0040.0000 0.0000 7.6000e004 Unmitigated
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7.1 Mitigation Measures Water

7.0 Water Detail

6.2 Area by SubCategory
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
SubCategory tons/yr MT/yr
Architectural
Coating

0.0209 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

0.1562 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Landscaping 3.0000e0050.0000 3.7000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 7.1000e0047.1000e0040.0000 0.0000 7.6000e004 Total 0.1771 0.0000 3.7000e0040.0000 0.0000 0.0000 0.0000 0.0000 0.0000 7.1000e0047.1000e0040.0000 0.0000 7.6000e004 Mitigated
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Total CO2 CH4 N2O CO2e
Category MT/yr
Mitigated 7.5656 0.3022 7.2100e00317.2675
Unmitigated 7.5656 0.3022 7.2100e00317.2675

7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
General Light
Industry

9.25 / 0 7.5656 0.3022 7.2100e00317.2675
Total 7.5656 0.3022 7.2100e00317.2675
Unmitigated
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7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
General Light
Industry

9.25 / 0 7.5656 0.3022 7.2100e00317.2675
Total 7.5656 0.3022 7.2100e00317.2675
Mitigated

8.1 Mitigation Measures Waste

8.0 Waste Detail
Total CO2 CH4 N2O CO2e
MT/yr
Mitigated 10.0684 0.5950 0.0000 24.9439
Unmitigated 10.0684 0.5950 0.0000 24.9439
Category/Year
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8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
General Light
Industry

49.6 10.0684 0.5950 0.0000 24.9439
Total 10.0684 0.5950 0.0000 24.9439
Unmitigated
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
General Light
Industry

49.6 10.0684 0.5950 0.0000 24.9439
Total 10.0684 0.5950 0.0000 24.9439
Mitigated

9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type Rubber Tired Loaders 1 24.00 365 203 0.36 Diesel
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11.0 Vegetation
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
Equipment Type tons/yr MT/yr
Rubber Tired
Loaders

0.1481 1.4534 0.8266 3.4300e0030.0487 0.0487 0.0448 0.0448 0.0000 300.7720 300.7720 0.0973 0.0000 303.2039 Total 0.1481 1.4534 0.8266 3.4300e0030.0487 0.0487 0.0448 0.0448 0.0000 300.7720 300.7720 0.0973 0.0000 303.2039 UnMitigated/Mitigated

10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type Emergency Generator 1 0 50 0 0.73
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
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Raven SR Bioenergy Project A.2-1 ESA / D202100382
Updated Initial Study MND March 9, 2023
A.2-1 Updated Air Quality and Greenhouse Gas
Assessment Technical Memo
1058
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1059
References 1 Ramboll
MEMO
Date February 27, 2023
Project name Raven SR
Project no. 1690025248
To Richmond Planning and Building Service Department
Richmond, California
From Steven Branoff
Tony Wang, PhD
Subject Raven SR Project Air Quality and Greenhouse Gas Assessment
1 INTRODUCTION
Ramboll US Consulting, Inc. (Ramboll) conducted a criteria air pollutant (CAP)_and greenhouse gas (GHG) assessment for the proposed construction and operation of a new bioenergy facility in Richmond, CA (referred to hereafter as “Project”). The project would be constructed at the West Contra Costa Sanitary Landfill, which is located at 1 Parr Blvd, Richmond, CA 94801. This analysis has been performed to support the California Environmental Quality Act (CEQA) documentation at the request of the City of Richmond’s Planning and Building Service Department. The Project location and boundary are shown in Figure 1, attached.

Details on the methodology and assumptions used in this technical report are summarized in Section 2, Methodology and the results are summarized in Section 3, Results. This analysis has been performed to support the CEQA documentation at the request of the City of Richmond’s Planning and Building Service Department. The Project location and boundary are shown in Figure 1, attached. 2 METHODOLOGY
The purpose of this air quality and GHG analysis is to assess potential criteria pollutant and GHG emissions that would result from the construction and operation of the Proposed Project, consistent with guidelines and methodologies from air quality regulatory agencies, specifically, the BAAQMD, the California Air Resources Board (ARB), and the US Environmental Protection Agency (USEPA).

This analysis will follow the BAAQMD’s 2017 CEQA Guidelines and 2022 updated CEQA Thresholds of Significance for Climate Impacts, where appropriate. All CAP and GHG emissions during Project construction and operation were quantified for this Project. In this analysis, Ramboll analyzed CAP and GHG net emission changes associated with the Proposed Project including both direct Project emissions and emissions reductions from the landfill flare due to the biogas engine operation.

This document summarizes the assumptions and calculation methodologies Ramboll used to estimate CAP and GHG emissions.

Throughout this report, GHG emissions are reported in units of metric tons of carbon dioxide equivalents (MT CO2e). Carbon dioxide equivalents are emissions of carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O), weighted by the global warming potentials (GWP) of 1, 25, and 298, respectively, from Title 40 of the Code of Federal Regulations (CFR), Part 98, Table A-1, 1060
References 2 Ramboll
as referenced by the California Mandatory Reporting Rule for GHG (Title 17 of the California Code of Regulations, §§95100- 95158).

2.1 Construction Sources
Construction emission calculation methodologies cover diesel-fueled off-road construction equipment and on-road mobile sources, i.e., hauling, vendor, and worker trips. Ramboll relied on project-specific data provided by the Project Sponsor, including a construction schedule and construction equipment list, as presented in the AQTM. Where project-specific construction data was not available, California Emissions Estimator Model (CalEEMod®) defaults were used. Emissions were estimated using methods consistent with CalEEMod® to estimate emissions, as summarized in Table 1.

2.1.1 Off-Road Equipment
For diesel-powered off-road construction equipment, Ramboll used CalEEMod and methodologies consistent with CalEEMod to estimate emissions. The CalEEMod emissions methodology for off-road construction equipment relies on the ARB In-Use Off-Road Equipment model (OFFROAD2017), which incorporates statewide survey data to develop emission factors based on the fleet average for each year of construction. The OFFROAD2017 model also identifies average horsepower and load factor for each type of equipment; Ramboll used these default values since project specific information was not available. The methodology to be used to calculate emissions from off-road equipment is presented in Table 1.

2.1.2 Construction On-Road Mobile Sources
On-road mobile sources include vehicle trips associated with workers, vendors, and demolition hauling trips. Construction worker, vendor, and hauling trips were provided by the Project Sponsor. Ramboll used CalEEMod default trip lengths for Contra Costa County to calculate total vehicle miles travelled (VMT).

The emission factors for running emissions of criteria pollutants are from EMFAC2021, the latest version of ARB’s EMission FACtors Model for on-road emissions. Emission factors vary by vehicle type, fuel type, and calendar year. Consistent with CalEEMod methodology, Ramboll assumed that worker trips are 25% Light-Duty Auto (LDA), 50% Light-Duty Truck 1 (LDT1), and 25% LDT2 vehicle classes; vendor trips are 100% diesel Medium-Heavy Duty Trucks (MHDT); and haul trips are 100% diesel Heavy-Heavy Duty Trucks (HHDT) unless additional information is known. EMFAC2021 incorporates both idling and running emissions, and the running emissions include exhaust as well as brake wear and tire wear. EMFAC2021 also incorporates the Pavley Clean Car Standards and the Advanced Clean Cars program. The emission factors used for construction of the Project were provided for Contra Costa County from EMFAC2021 for 2023 and 2024.

In addition to the idling and running emissions discussed above, emissions from construction on-road mobile sources also include resuspended road dust. Resuspended road dust emissions were calculated following ARB methodology and are described below.

The methodology used to calculate emissions from on-road sources is presented in Table 1.

2.2 Project Operational Emissions
The Project’s operational emission sources include three biogas engines, one green waste storage pile, one backup flare, and one fire pump engine. The green waste storage pile is excluded from the Project CAP and GHG emissions analysis as the source would already be emitting at the landfill. Additionally, the operation of biogas engines in the Project site will use landfill gas (LFG) from the adjacent landfill site. Therefore, the Project operation would reduce the amount of LFG sent to a flare for venting or evacuation and reduce emissions from the flare-based emissions from the landfill flare. 1061
References 3 Ramboll

2.2.1 Criterial Air Pollutants
To support the Project’s air permit application, Ramboll has analyzed the operational CAP and GHG emissions for all sources. CAP emissions from the biogas engines, flare, flare pilot, and fire pump are provided in Tables 2-5.

Since the operation of biogas engines in the Project site can either use 100% landfill gas (LFG) or a blended gas consisting of up to 45% tailgas, the Project would reduce the amount of LFG at the landfill site and reduce CAP emissions from the landfill flare. To be conservative, this analysis assumed that the biogas engines would use a blended gas with 55% LFG as an emission reduction measure. The amount of LFG reduction was estimated based on the LFG flow rate of the biogas engine and the annual landfill flare operational hours. The CAP emission reductions from the existing landfill flare are provided in Table 6.

The operational CAP emissions from mobile sources were also estimated using project specific information, and on-road operational vehicle trip lengths derived from CalEEMod. On-road mobile emissions were quantified for employee passenger vehicles and haul trucks. Trip rates and distances were provided by the Project Sponsor and are shown in Table 7, and the fleet specifications are presented in Table 8. Table 9 provides a summary of operational mobile sources CAP emissions.

2.2.2 Greenhouse Gas
The operational GHG emissions for the Project’s stationary sources were estimated using project specific information. The GHG emission factors for the stationary sources were obtained from 40 CFR Part 98 for various fuel types. GHG emissions from the biogas engines, flare, fire pump, and existing landfill flare reductions are provided in Table 10-13. Since the operation of biogas engines in the Project site can either use 100% landfill gas (LFG) or a blended gas consisting of up to 45% tailgas, the Project would reduce the amount of LFG at the landfill site and reduce GHG emissions from the landfill flare. Therefore, this analysis has quantified GHG reductions in both scenarios and provided the range of Project GHG impacts.
3 RESULTS FROM PROJECT ANALYSIS

3.1 Project Construction CAP and GHG Emissions
Project construction CAP and GHG emissions are summarized in Table 14. It also shows that the Project construction emissions of all CAPs are below the BAAQMD thresholds of significance. The project is estimated to generate approximately 186 MT CO2e over a construction period of two years.

3.2 Project Operational CAP and GHG Emissions
Project operational CAP and GHG emissions along with the landfill gas flaring reductions are summarized in Table 15-16. Project CAP emission sources include three biogas engines, one flare, one fire pump engine, and operational on-road mobile emissions. By using LFG from the adjacent landfill site in the biogas engines to reduce landfill flare emissions, the Project operational ROG, NOx, PM10, and PM2.5 emissions are all below the BAAQMD thresholds of significance.

For GHG, the BAAQMD 2017 CEQA guidelines specify a 10,000 MT/yr threshold for stationary sources.

Maximum Project net annual GHG emissions incorporating the existing landfill flare reductions are estimated to be 7,586 MT CO2e per year, with the conservative assumption that the biogas engines operate using a blended gas consisting of 55% LFG. When the biogas engines operate using 100% LFG, the net annual GHG emissions incorporating the existing landfill flare reductions are estimated to be 207 MT CO2e per year. In both cases, the Project GHG emissions are below the BAAQMD threshold. 1062
References 4 Ramboll
4 REFERENCES
Bay Area Air Quality Management District (BAAQMD). Recommended Methods for Screening and Modeling Local Risks and Hazards. May 2011. Table 14. Available at:
http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/CEQA/BAAQMD%20 Modeling%20Approach.ashx?la=en.

BAAQMD. 2017. California Environmental Quality Act Air Quality Guidelines. May. Available at:
http://www.baaqmd.gov/~/media/files/planning-andresearch/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en BAAQMD. 2020. Stationary Source Screening Map. Available at:
https://baaqmd.maps.arcgis.com/apps/webappviewer/index.html?id=845658c19eae4594b9 f4b805fb9d89a3
California Environmental Protection Agency (Cal/EPA), Office of Environmental Health Hazard Assessment (OEHHA). 1998. Findings of the Scientific Review Panel on The Report on Diesel Exhaust, as adopted at the Panel’s April 22, 1998, meeting.

Cal/EPA. 2016. OEHHA/ARB Consolidated Table of Approved Risk Assessment Health Values.

March. Available at: http://www.arb.ca.gov/toxics/healthval/contable.pdf Federal Register EPA; 40 CFR Part 98 Subpart A, Table A-1, Available at:
https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-98/subpart-A/appendixTable%20A-1%20to%20Subpart%20A%20of%20Part%2098 Federal Register EPA; 40 CFR Part 98 Subpart C, Available at:
https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-98/subpart-C OEHHA. 2009. Technical Support Document for Cancer Potency Factors: Methodologies for derivation, listing of available values, and adjustments to allow for early life stage exposures. Office of Environmental Health Hazard Assessment. May. Available at:
http://www.oehha.ca.gov/air/hot_spots/2009/TSDCancerPotency.pdf US Census Bureau. American Community Survey. 2020: ACS 5-Year Estimates Data Profiles.

ACS Demographic and Housing Estimates. Available at:
https://data.census.gov/cedsci/table?t=Populations%20and%20People&g=1600000US0660 620&y=2020&tid=ACSDP5Y2020.DP05
USEPA. 2021. User's Guide for the AMS/EPA Regulatory Model (AERMOD). Office of Air Quality Planning and Standards. Research Triangle Park, North Carolina. EPA-454/B-21-001, April 2021). Available at:
https://gaftp.epa.gov/Air/aqmg/SCRAM/models/preferred/aermod/aermod_userguide.pdf United States Geological Survey (USGS). 2013. National Elevation Dataset. Available at:
http://viewer.nationalmap.gov/viewer/
1063
5 TABLES
Table 1: Emissions Calculation Methodology
Table 2: Biogas Engine CAP Emissions
Table 3: Flare CAP Emissions
Table 4: Flare Pilot CAP Emissions
Table 5: Fire Pump Engine CAP Emissions
Table 6: Landfill Flare CAP Emission Reductions
Table 7: Trip Rates for Project Operations
Table 8: On-Road Fleet Mix for Project Operations
Table 9: Mobile CAP Emissions from Project Operations
Table 10: Biogas Engine GHG Emissions
Table 11: Flare GHG Emissions
Table 12: Fire Pump Engine GHG Emissions
Table 13: Landfill Flare GHG Emission Reductions
Table 14: Construction CAP and GHG Emission Summary
Table 15: Operational CAP Emission Summary
Table 16: Operational GHG Emission Summary

FIGURES
Figure 1: Modeled Sources and Buildings
1064
6 TABLES
1065
Type Source Methodology and Formula Reference
Construction
Equipment Off-Road Equipment1 Ec = Σ(EFc * HP * LF * Hr * UF * C) OFFROAD2017 and
ARB/USEPA Engine
Standards
Construction
Fugitive Dust
Mechanical Dismemberment,
Grading, Truck Loading CalEEMod CalEEMod
Exhaust – Running ER = Σ(EFR * VMT * C) , where
VMT = Trip Length * Trip Number EMFAC2021
Brake Wear and Tire Wear EBW,TW = Σ(EFBW,TW * VMT * C), where VMT = Trip Length * Trip Number EMFAC2021
Exhaust - Idling EI = Σ(EFI * Trip Number *TI* C) EMFAC2021 Entrained Road Dust ERD = Σ(EFRD * VMT * C) , where
VMT = Trip Length * Trip Number
ARB 2021 Miscellaneous
Process Methodology 7.9
Notes:

1. Ec: off-road equipment exhaust emissions (lb)
EFc: emission factor (g/hp-hr). CalEEMod default emission factors used HP: equipment horsepower. From CalEEMod defaults
LF: equipment load factor. From OFFROAD2017
Hr: equipment hours
UF: Utilization factor
C: unit conversion factor

2. ER: running exhaust and running losses emissions (lb) EFR: running emission factor (g/mile). From EMFAC2021
VMT: vehicle miles traveled
C: unit conversion factor
The calculation involves the following assumptions:
a. All material transporting and soil hauling trucks are heavy-heavy duty trucks.

EI: vehicle idling emissions (lb).

EFI: vehicle idling emission factor (g/hr-trip). From EMFAC2021 TI: idling time
C: unit conversion factor
ERD: entrained road dust emissions (lb)
EFRD: annual average emission factor (lb/VMT) = k*(sL)^0.91 * (W)^1.02 * (1-P/4N) k: particle size multiplier for particle size range
sL: roadway silt loading [grams per square meter - g/m2] W: average weight of vehicles traveling the road [tons] P = number of “wet” days in county with at least 0.01 in of precipitation during the annual averaging period N = number of days in the averaging period
VMT: vehicle miles traveled
C: unit conversion factor
Abbreviations:

ARB: California Air Resources Board lb: pound
BW: Brake Wear LF: Load Factor
EF: Emission Factor mi: mile
EMFAC: EMission FACtor Model USEPA: United States Environmental Protection Agency g: gram RL: Running Losses
HP: horsepower VMT: vehicle miles traveled
References:

Table 1
Emission Calculation Methodology
Raven SR
Richmond, CA
Construction and
Operational OnRoad Mobile
Sources2
On-road mobile sources include truck and passenger vehicle trips. Emissions associated with mobile sources were calculated using the following formulas.
b. Trip Length: The one-way trip length as calculated based on CalEEMod Appendix G defaults for Contra Costa County or provided by the Project Sponsor
c. Trip Number: Worker, vendor and hauling trip rates were provided by the Project Sponsor.

ARB/USEPA. 2013. Table 1: ARB and USEPA Off-Road Compression-Ignition (Diesel) Engine Standards. Available online at:
http://www.arb.ca.gov/msprog/ordiesel/documents/Off-Road_Diesel_Stds.xls The California Emissions Estimator Model (CalEEMod). Available at: http://www.caleemod.com/ California Air Resources Board (ARB) 2021. EMFAC2021. Available at: https://ww2.arb.ca.gov/our-work/programs/mobile-source-emissionsinventory/msei-modeling-tools 1066
Input Data
Horsepower rating (per engine) 1,966 bhp
Fuel Gas Volumetric Flow 30,886 SCFH
Emission Factor1 Emissions,
1 Engine3
Emissions,
1 Engine3
Emissions,
3 Engines3
(g/bhp-hr) (lb/day) (tons/yr) (tons/yr)
NOx (normal)2 0.12 13 2.3 7.0
NOx (startup, upset)2 1.1 4.8 0.048 0.14
CO 0.89 93 17 51
VOC 0.12 12 2.3 6.8
PM/PM10/PM2.5 0.090 9.4 1.7 5.1
(ppmv) (lb/day) (tons/yr) (tons/yr)
SO2 100 12 2.2 6.6
Notes:

1. 2.

3. Abbreviations:

BACT - Best Available Control Technology NOx - nitrogen oxides bhp - brake horsepower PM - particulate matter
CAP - criteria air pollutant ppmv - parts per million volume CO - carbon monoxide scfh - standard cubic foot per hour g - grams SO2 - sulfur dioxide
hr - hour VOC - volatile organic compound
lb - pounds yr - year
These engines can be fired on landfill gas, process tail gas, or a combination of these. Emissions shown here represent a worst-case for any operating scenario.

Richmond, CA
Raven SR
Biogas Engine CAP Emissions
Table 2
Pollutant
Emission factors represent BACT for biogas-fired engines, except PM emissions set at a level below the BACT threshold.

NOx during startup and upset are presented for operation of engine without SCR, for up to 1 hour/day and 20 hours/year.
1067
Input Data
Hydrogen gas heating value 670 Btu/scf
Flare heat input capacity 23 MMBtu/hr
100 hours/yr

2.0 hours/day
Emission Factors
Pollutant Factor Units
NOx 0.060 lb/MMBtu
CO 2.8 lb/MMScf
PM 0.90 lb/MMScf
VOC 0.0012 lb/MMBtu
SO2 1.0 ppmv
Total Flare Emissions
NOx CO VOC PM SO2
Emission Factor (lb/MMScf biogas) 40 2.8 0.80 0.90 0.16 Hourly Emission Rate (lb/hr) 1.4 0.095 0.028 0.031 0.0056 Daily Emission Rate (lb/day) 2.8 0.19 0.055 0.062 0.011 Annual Potential to Emit (lb/year) 138 9.5 2.8 3.1 0.56 Annual Potential to Emit (TPY) 0.069 0.0047 0.0014 0.0015 2.8E-04 Abbreviations:

BAAQMD - Bay Area Air Quality Management District PM - particulate matter BACT - Best Available Control Technology ppmv - parts per million volume BTU - British Thermal Unit scf - standard cubic foot
CAP - criteria air pollutant SO2 - sulfur dioxide
CO - carbon monoxide TPY - tons per year
hr - hour VOC - volatile organic compound
lb - pounds yr - year
NOx - nitrogen oxides
Flare operating hours
Table 3
Flare CAP Emissions
Raven SR
Richmond, CA
Source
Low sulfur content of H2 gas
AP-42 Table 13.5-1
AP-42 Table 2.4-4, adjusted for 6%
methane
AP-42 Table 2.4-4, adjusted for 6%
methane
BAAQMD BACT, flare
1068
Input Data
Propane gas flowrate 50 scfh
Propane density 36 scf/gal
Flare pilot propane use 1.4 gal/hr
8,760 hours/yr
24 hours/day
Emission Factors
Pollutant Factor Units
NOx 13 lb/103
gal
CO 7.5 lb/103
gal
PM 0.70 lb/103
gal
VOC 0.80 lb/103
gal
SO2 0.016 lb/103
gal
Total Flare Emissions
NOx CO VOC PM SO2
Emission Factor (lb/103 gal) 13 7.5 0.80 0.70 0.016
Hourly Emission Rate (lb/hr) 0.018 0.011 0.0011 0.0010 2.2E-05 Daily Emission Rate (lb/day) 0.44 0.25 0.027 0.024 5.4E-04 Annual Potential to Emit (lb/year) 160 92 10 8.6 0.20
Annual Potential to Emit (TPY) 0.080 0.046 0.0049 0.0043 9.8E-05 Abbreviations:

CAP - criteria air pollutant PM - particulate matter
CO - carbon monoxide scf - standard cubic foot
gal - gallon SO2 - sulfur dioxide
hr - hour TPY - tons per year
lb - pounds VOC - volatile organic compound
NOx - nitrogen oxides yr - year
Source
Flare operating hours
Table 4
Flare Pilot CAP Emissions
Raven SR
Richmond, CA
AP-42, Chapter 1.5, Table 1.5-1.

AP-42, Chapter 1.5, Table 1.5-1.

AP-42, Chapter 1.5, Table 1.5-1.

AP-42, Chapter 1.5, Table 1.5-1.

AP-42, Chapter 1.5, Table 1.5-1.
1069
Input Data
Horsepower rating 104 bhp
Diesel fuel use rate 8 gal/hr
Daily operating hours 24 hr/day
Annual operating hours (testing) 30 hr/yr
Annual operating hours (emergency) 100 hr/yr
Emission
Factor1
Hourly
Emissions
Daily
Emissions3
Annual Emissions
(Testing Only)4
Annual Emissions
(Testing +
Emergency)4
(g/bhp-hr) (lb/hr) (lb/day) (tons/yr) (tons/yr)
NOx2 2.9 0.65 16 0.010 0.042
CO 3.7 0.85 20 0.013 0.055
VOC2 0.15 0.034 0.83 5.2E-04 0.0022
PM/PM10/PM2.5 0.22 0.050 1.2 7.6E-04 0.0033
SO2 0.0059 0.0014 0.032 2.0E-05 8.8E-05
Notes:

1. 2.

3. 4.

Abbreviations:

BAAQMD - Bay Area Air Quality Management District NOx - nitrogen oxides bhp - brake horsepower PM - particulate matter
CAP - criteria air pollutant scf - standard cubic foot
CO - carbon monoxide SO2 - sulfur dioxide
g - grams TPY - tons per year
gal - gallon VOC - volatile organic compound
hr - hour yr - year
lb - pounds
NOx and VOC apportioned from the combined NOx/NMHC limit assuming 95% NOx, 5% VOC.

Daily emissions assume operation 24 hr/day for regulatory applicability purposes only Calculations of annual emissions are shown with and without emergency hours, as per BAAQMD guidance.

Pollutant
Table 5
Fire Pump Engine CAP Emissions
Raven SR
Richmond, CA
Emission factors presented for Tier 3 engine, as required by the CA Diesel Engine ATCM 1070
Input Data1
LFG gas heating value 386 Btu/scf
LFG gas volume 50,962 SCFH
Flare heat input capacity 20 MMBtu/hr
8,760 hours/yr
24 hours/day
Emission Factors
Pollutant Factor Units
NOx 39 lb/MMScf
CO 46 lb/MMScf
PM 15 lb/MMScf
VOC 0.0012 lb/MMBtu
SO2 1.0 ppmv
Landfill Flare Emission Reductions
NOx CO VOC PM SO2
Emission Factor (lb/MMScf biogas) 39 46 0.46 15 0.16
Hourly Emission Rate (lb/hr) 2.0 2.3 0.024 0.8 0.008
Daily Emission Rate (lb/day) 48 56 0.6 18 0.20
Annual Potential to Emit (lb/year) 17,411 20,536 207 6,696 73 Annual Potential to Emit (TPY) 8.7 10 0.10 3.3 0.036
Notes:

1. Abbreviations:

BTU - British Thermal Unit ppmv - parts per million volume CAP - criteria air pollutant scf - standard cubic foot
CO - carbon monoxide SO2 - sulfur dioxide
hr - hour TPY - tons per year
lb - pounds VOC - volatile organic compound
NOx - nitrogen oxides yr - year
PM - particulate matter
AP-42 Table 2.4-4
Table 6
Source
Flare operating hours
Richmond, CA
Raven SR
Landfill Flare CAP Emission Reductions
To be conservative, the landfill flare emission reductions were estimated using the scenario that the Project biogas engines operate using a blended gas consisting of 55% landfill gas.

Low sulfur content of H2 gas
AP-42 Table 13.5-1
AP-42 Table 2.4-4
AP-42 Table 2.4-4
1071
Average Trip Rate Average Trip Length Annual Activity Annual Trips2 Annual VMT2 round trips/day mi/round trip days/year round trips/yr mi/yr Employees 15 14.5 260 3,900 56,550
Trucks 50 80 260 13,000 1,040,000
Notes:

1. 2.

Abbreviations:
mi - mile(s)
VMT - vehicle miles travelled
yr - year
Average trip rate and trip length were provided by Project sponsor.

The annual trips and annual VMT were calculated assuming 5 days per week or 260 days per year for operations.

Table 7
Trip Rates for Project Operations
Raven SR
Richmond, CA
Fleet Type1
1072
Gas Diesel Natural Gas Electric Plug-in
Hybrid
LDA 65% 90.33% 0.28% -- 6.45% 2.94%
LDT1 5.3% 99.55% 0.02% -- 0.28% 0.16%
LDT2 29.7% 98.28% 0.42% -- 0.45% 0.85%
Trucks3 HHDT 100% -- 100.00% -- -- --
Notes:

1. 2.

3. Abbreviations:

EMFAC2021 - California Air Resources Board EMission FACtor model References:

Table 8
On-Road Fleet Mix for Project Operations
Raven SR
Richmond, CA
Fleet Mix
Assumption1
Vehicle
Type
Percentage of
Fleet Mix
% by Fuel Type
California Air Resources Board (ARB) 2021. EMFAC2021. Available at: https://ww2.arb.ca.gov/our-work/programs/mobile-sourceemissions-inventory/msei-modeling-tools Employees2
Fleet mixes and percentages by fuel type are calculated based on EMFAC2021 v1.0.2 vehicle miles traveled projections for Contra Costa County. EMFAC2021 was run in Emission Rates mode for calendar year 2024 in the annual season with EMFAC2007 vehicle categories and data aggregated across vehicle model year and speed. Per the Project sponsor, operations are expected to begin in 2024. For the purposes of this analysis, maximum operational emissions were conservatively calculated assuming one full year of 2024 operations rather than partial. This is conservative because on average, vehicle emission factors are expected to decrease with time as a higher percentage of the fleet is electrified.

The hydrogen delivery truck fleet is assumed to be all HHDT and diesel fueled.

The employee fleet is assumed to have the default EMFAC vehicle type distribution of passenger vehicles and default fuel distribution.
1073
ROG NOx PM10 PM2.5 CO SOx
Employees 0.0050 0.0044 0.0011 3.7E-04 0.061 1.8E-04
Trucks 0.025 2.3 0.16 0.072 0.17 0.018
Total 0.030 2.3 0.16 0.072 0.23 0.018
Notes:

1. Abbreviations:

CO - carbon monoxide PM - particulate matter
CO2e - carbon dioxide equivalents ROG - reactive organic gases MT - metric ton(s) SOx - sulfur oxides
NOx - nitrogen oxides yr - year
Richmond, CA
Table 9
Mobile CAP Emissions from Project Operations
Raven SR
Trip generation rates and fleet mix details, and emission factors used in emissions calculations are shown in Tables 7 and 8 respectively. Emission factors are derived from EMFAC 2021
Trip Type
Emissions from Mobile Sources
(tons/yr)
1074
Input1 Value Unit
Heat Content - Biogas 386 BTU/scf
Operating Hours 8,760 hr/yr
92,658 scf/hr
313,310 MMBTU/yr
GHG Emissions
Landfill Gas Emission Factors2
kg/MMBtu MT/yr
CO2 52 16,314
CH4 0.0032 1.0
N2O 6.3E-04 0.20
CO2e 52 16,398
Notes:

1. 2.

Abbreviations:

BTU - British Thermal Unit kg - kilogram
CH4 - methane MMBtu - million British thermal units
CO2 - Carbon dioxide MT- Metric tons
CO2e - carbon dioxide equialent N2O - Nitrous Oxide
GHG - green house gases scf - standard cubic foot
hr - hour yr - year
References:

Federal Register EPA; 40 CFR Part 98 Subpart A, Table A-1, Available at: https://www.ecfr.gov/current/title-40/chapterI/subchapter-C/part-98/subpart-A/appendix-Table%20A-1%20to%20Subpart%20A%20of%20Part%2098 Biogas Engine GHG Emissions
Table 10
Federal Register EPA; 40 CFR Part 98 Subpart C, Available at: https://www.ecfr.gov/current/title-40/chapterI/subchapter-C/part-98/subpart-C Biogas Usage, 3 Engines
GHG emissions factors were based on 40 CFR Part 98 for landfill gas fuel type. Emission factors for CO2e were estimated by multiplying the CH4 and N2O emission factors by their global warming potentials from the 40 CFR Part 98 Subpart A, Table A-1.

Biogas engine operation inputs were provided by the Project Sponsor.

Pollutant
Biogas Engine Emissions
Richmond, CA
Raven SR
1075
Input1 Value Unit
Heat Content - Hydrogen Gas 670 BTU/scf
Heat Content - Propane Gas 2,420 BTU/scf
Flare Operating Hours 100 hr/yr
Flare Pilot Operating Hours 8,760 hr/yr
23 MMBTU/hr
2,300 MMBTU/yr
50 scf/hr
1,060 MMBTU/yr
GHG Emissions
Landfill Gas Emission Factors2 Propane Gas Emission Factors2 MT/yr
CO2 52 61 185
CH4 0.0032 0.0030 0.012
N2O 6.3E-04 6.0E-04 0.0023
CO2e 52 62 205
Notes:

1. 2.

Abbreviations:

BTU - British Thermal Unit kg - kilogram
CH4 - methane MMBtu - million British thermal units
CO2 - Carbon dioxide MT- Metric tons
CO2e - carbon dioxide equialent N2O - Nitrous Oxide
GHG - green house gases scf - standard cubic foot
hr - hour yr - year
References:

Federal Register EPA; 40 CFR Part 98 Subpart C, Available at: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-98/subpart-C Federal Register EPA; 40 CFR Part 98 Subpart A, Table A-1, Available at: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part98/subpart-A/appendix-Table%20A-1%20to%20Subpart%20A%20of%20Part%2098 Propane Gas Usage
Pollutant
Flare Emissions
kg/MMBtu
Flare operation inputs were provided by the Project Sponsor.

GHG emissions factors were based on 40 CFR Part 98 for landfill gas and propane gas fuel types. Emission factors for CO2e were estimated by multiplying the CH4 and N2O emission factors by their global warming potentials from the 40 CFR Part 98 Subpart A, Table A-1.

Biogas Usage
Table 11
Flare GHG Emissions
Raven SR
Richmond, CA
1076
Input1 Value Unit
Heat Content - Diesel 0.14 MMBTU/gal
Operating Hours 30 hr/yr

8.0 gal/hr
33 MMBTU/yr
GHG Emissions
Diesel Emission Factors2
kg/MMBtu MT/yr
CO2 74 2.4
CH4 0.0030 9.9E-05
N2O 6.0E-04 2.0E-05
CO2e 74 2.5
Notes:

1. 2.

Abbreviations:

BTU - British Thermal Unit kg - kilogram
CH4 - methane MMBtu - million British thermal units
CO2 - Carbon dioxide MT- Metric tons
CO2e - carbon dioxide equialent N2O - Nitrous Oxide
gal - gallon scf - standard cubic foot
GHG - green house gases yr - year
hr - hour
References:

Federal Register EPA; 40 CFR Part 98 Subpart A, Table A-1, Available at: https://www.ecfr.gov/current/title-40/chapterI/subchapter-C/part-98/subpart-A/appendix-Table%20A-1%20to%20Subpart%20A%20of%20Part%2098 Fire pump engine operation inputs were provided by the Project Sponsor and the heat content of diesel was based on 40 CFR Part 98 defaults.

GHG emissions factors were based on 40 CFR Part 98 for distillate fuel oil no.2 fuel type. Emission factors for CO2e were estimated by multiplying the CH4 and N2O emission factors by their global warming potentials from the 40 CFR Part 98 Subpart A, Table A-1.

Federal Register EPA; 40 CFR Part 98 Subpart C, Available at: https://www.ecfr.gov/current/title-40/chapterI/subchapter-C/part-98/subpart-C Table 12
Fire Pump Engine GHG Emissions
Raven SR
Richmond, CA
Diesel Usage
Pollutant
Fire Pump Engine Emissions
1077
Input1 Value Unit
Heat Content - Biogas 386 BTU/scf
Flare Operating Hours 8760 hr/yr
50,962 scf/hr
172,321 MMBTU/yr
92,658 scf/hr
313,310 MMBTU/yr
GHG Emissions
Landfill Gas Combustion Emission
Factors2
Landfill Flare Emission
Reductions (55% landfill gas)
Landfill Flare Emission
Reductions (100% landfill gas)
kg/MMBtu MT/yr MT/yr
CO2 52 8,973 16,314
CH4 0.0032 0.55 1.0
N2O 6.3E-04 0.11 0.20
CO2e 52 9,019 16,398
Notes:

1. 2.

Abbreviations:

BTU - British Thermal Unit kg - kilogram
CH4 - methane MMBtu - million British thermal units
CO2 - Carbon dioxide MT- Metric tons
CO2e - carbon dioxide equialent N2O - Nitrous Oxide
GHG - green house gases scf - standard cubic foot
hr - hour yr - year
References:

Richmond, CA
Raven SR
Landfill Flare GHG Emission Reductions
Table 13
Biogas Usage (55% landfill gas)
Biogas Usage (100% landfill gas)
Landfill flare operation inputs were estimated based on the amount of landfill flare reductions that would result from the usage of the Project biogas engines, which can operate using a blended gas consisting of at least 55% landfill gas and up to 100% landfill gas.

Pollutant
GHG emissions factors were based on 40 CFR Part 98 for landfill gas fuel type. Emission factors for CO2e were estimated by multiplying the CH4 and N2O emission factors by their global warming potentials from the 40 CFR Part 98 Subpart A, Table A-1.

Federal Register EPA; 40 CFR Part 98 Subpart C, Available at: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-98/subpart-C Federal Register EPA; 40 CFR Part 98 Subpart A, Table A-1, Available at: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-98/subpartA/appendix-Table%20A-1%20to%20Subpart%20A%20of%20Part%2098 1078
Summary of Default Construction Emissions by Source
Default
Construction GHG
Emissions2
ROG NOx PM10 (Exhaust) PM2.5 (Exhaust) CO2e
MT/yr
On-Site Exhaust 172 19 3.5 2.8 1.2
Mobile Exhaust 0.20 10 0.12 0.12 3.6
On-Site Exhaust 19 164 6.4 5.9 14
Mobile Exhaust 0.28 0.22 0.0032 0.0029 0.26
On-Site Exhaust 23 185 12 11 13
Mobile Exhaust 0.28 0.22 0.0032 0.0029 0.26
On-Site Exhaust 186 1,622 70 64 140
Mobile Exhaust 1.7 21 0.22 0.21 7.0
On-Site Exhaust 8.2 72 2.9 2.7 6.5
Mobile Exhaust 0.072 0.94 0.0093 0.0089 0.32
Default Construction Emissions by Year
ROG NOx PM10 (Exhaust) PM2.5 (Exhaust) CO2e
MT/yr
2023 0.20 1.0 0.046 0.042 179
2024 0.0041 0.036 0.0015 0.0014 6.8
BAAQMD Threshold 10 10 15 15 --
Exceed threshold? No No No No --
Notes:

1. 2.

Abbreviations:

BAAQMD - Bay Area Air Quality Management District MT - metric ton CalEEMod - California Emissions Estimator Model NOx - nitrogen oxides CAP - Criteria Air Pollutants PM10 - particulate matter less than 10 microns CO2e - carbon dioxide equivalents PM2.5 - particulate matter less than 2.5 microns GHG - greenhouse gas ROG - Reactive Organic Gas
lb - pounds yr - year
References:

Raven SR
Construction CAP and GHG Emission Summary
Table 14
Federal Register EPA; 40 CFR Part 98 Subpart A, Table A-1, Available at: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-98/subpartA/appendix-Table%20A-1%20to%20Subpart%20A%20of%20Part%2098 California Air Resources Board (ARB) 2021. EMFAC2021. Available at: https://ww2.arb.ca.gov/our-work/programs/mobile-source-emissions-inventory/mseimodeling-tools The California Emissions Estimator Model (CalEEMod). Available at: http://www.caleemod.com/ Construction
Activity Year Source
Default Construction CAP Emissions1
lb/yr
Richmond, CA
Demolition 2023
Site Preparation 2023
Building
Construction
2023
2024
Grading 2023
Emissions were estimated using off-road construction equipment emission factors from CalEEMod and on-road emission factors from EMFAC2021. The emissions above include emissions from offroad equipment, and emissions from worker, vendor, and hauling trucks. Default emissions use the default construction equipment Tier. BAAQMD mass thresholds for PM10 and PM2.5 evaluate only exhaust emissions.

Emission factors for CO2e were estimated by multiplying the CH4 and N2O emission factors by their global warming potentials from the 40 CFR Part 98 Subpart A, Table A-1.

Year
Summary of Construction Emissions by Year1
ton/yr
1079
Emissions Summary1
ROG NOx PM10 (Exhaust) PM2.5 (Exhaust)
Biogas Engines 6.8 7.2 5.1 5.1
Flare 0.010 0.16 0.0086 0.0086
Fire Pump Engine 0.0022 0.042 0.0033 0.0033
Landfill Flare Reductions2 -0.10 -8.7 -3.3 -3.3
On-Road Mobile 0.030 2.3 0.16 0.072
Total 6.8 1.0 2.0 1.9
BAAQMD Threshold 10 10 15 15
Exceed threshold? No No No No
Notes:

1. 2.

Abbreviations:

BAAQMD - Bay Area Air Quality Management District PM10 - particulate matter less than 10 microns CalEEMod - California Emissions Estimator Model PM2.5 - particulate matter less than 2.5 microns CAP - Criteria Air Pollutants ROG - Reactive Organic Gas CARB - California Air Resources Board yr - year
NOx - nitrogen oxides
References:

Table 15
Operational CAP Emission Summary
Raven SR
Richmond, CA
California Air Resources Board (ARB) 2021. EMFAC2021. Available at: https://ww2.arb.ca.gov/our-work/programs/mobile-sourceemissions-inventory/msei-modeling-tools Emissions estimated using methods consistent with Project-specific information.

To be conservative, the landfill flare reductions assume the biogas engines operate using a blended gas consisting of 55% landfill gas.

BAAQMD. May 2017. California Environmental Quality Act Air Quality Guidelines. Available online at:
https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa_guidelines_may2017- pdf.pdf?la=en&rev=0d2d971e661d41f28a56953f1776bdde
Emissions Source
tons/yr
Operational CAP Emissions
1080
Emissions Summary1
GHG Emissions
(55% landfill gas)
GHG Emissions
(100% landfill gas)
CO2e CO2e
(MT/yr) (MT/yr)
Biogas Engines 16,398 16,398
Flare 205 205
Fire Pump Engine 2.5 2.5
Landfill Flare Reductions2 -9,019 -16,398
Total 7,586 207
BAAQMD Threshold 10,000 10,000
Exceed threshold? No No
Notes:

1. 2.

Abbreviations:

BAAQMD - Bay Area Air Quality Management District
CalEEMod - California Emissions Estimator Model
CARB - California Air Resources Board
CO2e - carbon dioxide equivalents
GHG - greenhouse gas
MT - metric ton
yr - year
References:

Emissions estimated using methods consistent with Project-specific information.

Landfill flare reductions were estimated based on the landfill gas usage of the Project biogas engines, which can operate using a blended gas consisting of at least 55% landfill gas and up to 100% landfill gas.

BAAQMD. May 2017. California Environmental Quality Act Air Quality Guidelines. Available online at:
https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa_guidelines_may2017- pdf.pdf?la=en&rev=0d2d971e661d41f28a56953f1776bdde
California Air Resources Board (ARB) 2021. EMFAC2021. Available at: https://ww2.arb.ca.gov/ourwork/programs/mobile-source-emissions-inventory/msei-modeling-tools Table 16
Operational GHG Emission Summary
Raven SR
Richmond, CA
Emissions Source
1081

FIGURES
1082
PROJECT: 1690025248 | DATED: 1/20/2023 | DESIGNER: ANSHI Service Layer Credits: World Imagery: Maxar, Microsoft
0 500 1,000
Feet
RAMBOLL US CONSULTING, INC.

A RAMBOLL COMPANY
FIGURE 01 Project Boundary
Onsite Buildings
Leachate Tanks
Green Waste Storage Pile
Fire Pump Engine Housing
Biogas Engine
Fire Pump Engine
Flare
Existing Landfill Flare
!(
Ná
Raven SR
1 Parr Blvd.

Richmond, CA

MODELED SOURCES AND BUILDINGS
1083
Raven SR Bioenergy Project A.2-2 ESA / D202100382
Updated Initial Study MND March 9, 2023
A.2-2 Updated Air Quality and New Health Risk
Assessment Technical Memo
1084
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This page is intentionally blank.
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References 1 Ramboll
MEMO
Date March 7, 2023
Project name Raven SR
Project no. 1690025248
To Richmond Planning and Building Service Department
Richmond, California
From Steven Branoff
Tony Wang, PhD
Subject Raven SR CEQA Air Quality and Health Risk Assessment 1 INTRODUCTION
Ramboll US Consulting, Inc. (Ramboll) conducted a health risk assessment (HRA) for the proposed construction and operation of a new bioenergy facility in Richmond, CA (referred to hereafter as “Project”). The project would be constructed at the West Contra Costa Sanitary Landfill, which is located at 1 Parr Blvd, Richmond, CA 94801. The Project location and boundary are shown in Figure 1, attached.

Details on the methodology and assumptions used in this technical report are summarized in Section 2, Methodology and the results are summarized in Section 3, Results. . Typically, an HRA will be performed if a project will generate substantial emissions of toxic air contaminants (TACs). Although the proposed Project’s Initial Study prepared pursuant to the California Environmental Quality Act (CEQA) did not indicate the Project would generate substantial emissions and was well below the TAC thresholds, the City of Richmond’s Planning and Building Service Department requested this analysis to further quantify estimated risks. As further described below, the proposed Project provides an overall reduction of cancer risk, chronic hazard index, acute hazard index, and particulate matter concentrations as compared to the portions of the existing landfill flare operation it would be replacing.
2 METHODOLOGY
The purpose of this HRA is to assess potential health risks and hazards that could result from the construction and operation of the proposed Project. Potential health risks and hazards are analyzed consistent with the guidelines and methodologies from air quality agencies, specifically: Bay Area Air Quality Management District (BAAQMD), California Air Resources Board (CARB), California Office of Environmental Health Hazard Assessment (OEHHA), and United States Environmental Protection Agency (USEPA).

The steps conducted in performing this health risk analysis are as follows:

1. Prepare toxic air contaminants (TACs) emissions from Project construction and operation.

2. Calculate TAC emission reductions from the existing landfill flare operation.

3. Perform air dispersion modeling for pollutant concentrations for area sources and point sources of TAC emissions.
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References 2 Ramboll

4. Calculate resulting cancer risk, non-cancer chronic hazard index (HI), acute hazard index (HI), and fine particulate matter (PM2.5) concentrations resulting from construction and operational sources of TACs.

5. Evaluate the cumulative health risk impacts resulting from existing stationary and mobile emissions.

2.1 Construction Sources
Construction emission calculation methodologies cover diesel-fuelled off-road construction equipment and on-road mobile sources, i.e., hauling, vendor, and worker trips. Ramboll relied on project-specific data provided by the Project Sponsor, including a construction schedule (Table 1) and construction equipment list (Table 2). Where project-specific construction data was not available, California Emissions Estimator Model (CalEEMod®) defaults were used. For the purposes of this analysis, Ramboll assumed that all non-electric off-road construction equipment is diesel powered, and that all off-road equipment emissions of PM with an aerodynamic diameter less than 10 microns (PM10) are diesel particulate matter (DPM), which is a TAC. Emissions will be estimated using CalEEMod® or equivalent methods, as summarized in Table 3.

The BAAQMD’s numeric mass thresholds for respirable particulate matter (or PM10) and fine particulate matter (or PM2.5) address exhaust PM only; therefore, the criteria area pollutant (CAP) emissions do not account for fugitive dust.

2.1.1 Off-Road Equipment
For diesel-powered off-road construction equipment, Ramboll used CalEEMod and methodologies consistent with CalEEMod to estimate emissions. The CalEEMod emissions methodology for off-road construction equipment relies on the ARB In-Use Off-Road Equipment model (OFFROAD2017), which incorporates state-wide survey data to develop emission factors based on the fleet average for each year of construction. The OFFROAD2017 model also identifies average horsepower and load factor for each type of equipment; Ramboll used these default values since project specific information was not available. The methodology used to calculate emissions from off-road equipment is presented in Table 3.

2.1.2 Construction On-Road Mobile Sources
On-road mobile sources include vehicle trips associated with workers, vendors, and demolition hauling trips. Construction worker, vendor, and hauling trips were provided by the Project Sponsor. Ramboll used CalEEMod default trip lengths for Contra Costa County to calculate total vehicle miles travelled (VMT). Fleet mix and fuel assumptions are summarized in Table 4.

The emission factors for running emissions of criteria pollutants are from EMFAC2021, the latest version of ARB’s EMission FACtors Model for on-road emissions. Emission factors vary by vehicle type, fuel type, and calendar year. Consistent with CalEEMod methodology, Ramboll assumed that worker trips are 25 percent Light-Duty Auto (LDA), 50 percent Light-Duty Truck 1 (LDT1), and 25% LDT2 vehicle classes; vendor trips are 100 d percent iesel Medium-Heavy Duty Trucks (MHDT); and haul trips are 100% diesel Heavy-Heavy Duty Trucks (HHDT) unless additional information is known.

EMFAC2021 incorporates both idling and running emissions, and the running emissions include exhaust as well as brake wear and tire wear. EMFAC2021 also incorporates the Pavley Clean Car Standards and the Advanced Clean Cars program. The emission factors used for construction of the Project were provided for Contra Costa County from EMFAC2021 for 2023 and 2024.

For HRA purposes, Ramboll will only consider DPM and PM2.5 emissions from vendor and hauling trucks because construction worker vehicle trips from construction required for the Project is not expected to 1087
References 3 Ramboll
exceed an average of 5,000 worker trips per day. Ramboll assumed a truck travel distance of 1,000 feet to evaluate localized impacts. Further distances would have diminishing impacts on receptors close to the project site. BAAQMD recommends a traffic screening criteria of 10,000 vehicles per day for lifetime cancer risk exposure analyses (BAAQMD 2011). To be conservative, Ramboll has established a revised screening criteria of 5,000 vehicles per day, consistent with a 100 percent increase in lifetime exposure. This is especially conservative for construction analyses as the actual exposure period would be much shorter. Construction worker vehicle trips from the Project are not expected to exceed an average of 5,000 worker trips per day. Therefore, construction worker vehicle emissions were not included in the health risk assessment.

In addition to the idling and running emissions discussed above, emissions from construction on-road mobile sources also include resuspended road dust. Resuspended road dust emissions were calculated following ARB methodology and are described below.

The methodology used to calculate emissions from on-road sources is presented in Table 3.

2.1.3 On-Road Fugitive Dust
CalEEMod default methods and parameters were used to calculate the annual average emission factors for fugitive PM2.5 emissions from on-road trucks and vendor and passenger vehicles using the equations in Table 3. The weighted average Contra Costa-specific silt loading factor was calculated based on travel fraction by roadway category and silt loading parameters obtained from ARB’s Entrained Road Travel Emission Inventory Source Methodology document. The average silt loading factor was then used in conjunction with parameters from the ARB Miscellaneous Process Methodology

7.9 for Entrained Road Travel, Paved Road Dust to calculate a fugitive PM2.5 emission factor.

Detailed emission calculations for resuspended roadway dust are provided in Tables 5-7.

2.1.4 Off-Road Fugitive Dust
Fugitive dust contributes to PM2.5 emissions and is generated by the various activities occurring at the Project site. The following subsections describe the methodology used to calculate fugitive dust emissions from Project off-road construction activities. To be conservative, fugitive dust emissions were included in the estimation of PM2.5 concentration resulting from construction.

Fugitive dust emissions from demolition and debris loading during demolition were estimated using CalEEMod methodology and assumptions. The emission factor is calculated on a per-ton of building waste weight. Building waste weight was estimated based on the building area to be demolished, provided by the Project Sponsor.

Fugitive dust emissions from grading were estimated based on CalEEMod default methodologies and the construction equipment list in Table 2. Fugitive dust from material loading activities includes the unloading of construction materials and loading of soil onto haul trucks during all construction phases.

Material loading fugitive dust emissions were estimated using CalEEMod methodology and assumptions. The emission factor for material loading is calculated on a per-ton basis. Material loaded in cubic yards is based on Project-specific data. More specifically, material loaded during the Demolition phase was based on the building waste weight calculated from the building area to be demolished. According to the Project Sponsor, there will be no material imported or exported from the site during construction.

Fugitive dust emissions from demolition activity, grading, and truck loading activity are provided in Table 8-10.
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References 4 Ramboll

2.2 Project Operational Emissions
The Project’s operational emission sources include three biogas engines, one green waste storage pile, one backup flare, and one fire pump engine. These emissions will be transported outside of the physical boundaries of the Project site, potentially impacting nearby sensitive receptors such as worksites and residential areas. To support the Project’s air permit application, Ramboll has analyzed the operational emissions for all sources, which are also used for this HRA.

Since the operation of biogas engines in the Project site can either use 100 percent landfill gas (LFG) or a blended gas consisting of up to 45 percent tailgas, the Project would reduce the amount of LFG at the landfill site and reduce TAC emissions from the landfill flare. To be conservative, this analysis assumed that the biogas engines would use a blended gas with 55 percent LFG as an emission reduction measure. The amount of LFG reduction was estimated based on the LFG flow rate of the biogas engine and the annual landfill flare operational hours. The TAC emission reductions were calculated based on the LFG reduction and the emission rates consistent with EPA and BAAQMD Guidelines.

As stated above, BAAQMD establishes a screening criteria of 10,000 vehicles per day for lifetime cancer risk exposure analyses, and Ramboll has adopted a conservative threshold of 5,000 vehicles/day. According to the Project Sponsor, the maximum traffic volume the Project adds to any roadway is 130 vehicles per day. Therefore, health impacts from on-road mobile emissions were not included in the operational HRA.

2.3 Estimated Air Concentrations
Consistent with the most recent BAAQMD CEQA Guidelines (BAAQMD 2017), BAAQMD Health Risk Assessment Modeling Protocol (BAAQMD 2020), and the most recent Air Toxics Hot Spots Program Risk Assessment Guidelines (OEHHA 2015), the HRA evaluated health risks and PM2.5 concentrations resulting from the Project upon the surrounding community. For the Project, Ramboll modeled the surrounding community’s TAC concentrations contributed by the Project’s emission sources.

2.3.1 Chemical Selection
The cancer risk analysis in the construction HRA for the Project is based on DPM. Diesel exhaust, a complex mixture that includes hundreds of individual constituents (California Environmental Protection Agency [Cal/EPA] 1998), is identified by the State of California as a known carcinogen (Cal/EPA 2016).

Under California regulatory guidelines, DPM is used as a surrogate measure of exposure for the mixture of chemicals that make up diesel exhaust as a whole. Cal/EPA and other proponents of using the surrogate approach to quantifying cancer risks associated with the diesel mixture indicate that this method is preferable to use of a component-based approach. A component-based approach involves estimating risks for each of the individual components of a mixture. Critics of the component-based approach believe it will underestimate the risks associated with diesel as a whole mixture because the identity of all chemicals in the mixture may not be known and/or exposure and health effects information for all chemicals identified within the mixture may not be available. Furthermore, Cal/EPA has concluded that “potential cancer risk from inhalation exposure to whole diesel exhaust will outweigh the multi-pathway cancer risk from the speciated components” (OEHHA 2003).

The Project has conducted operational emission analyses for BAAQMD air permit application.

Therefore, the same TAC emission data are used for the HRA, except for emissions from biogas engines, which were estimated using concentrations and speciation from facility data. These calculations are included in the attached Table 12. The cancer risk, chronic, acute, and PM2.5 impacts in the HRA for the Project were based on the expected TAC emissions from the modeled sources. 1089
References 5 Ramboll

2.3.2 Sources
As discussed above, this HRA included the Project construction and operational sources and resulting emission reductions from the existing landfill flare. The construction sources include construction offroad equipment and on-road mobile sources. The operational sources include three biogas engines, one green waste storage pile, one backup flare, and one fire pump engine.

2.3.3 AERMOD Modeling
Ramboll used the most recent version of the American Meteorological Society/Environmental Protection Agency regulatory air dispersion model (AERMOD Version 22112) to evaluate ambient air concentrations of TACs, and PM2.5 at receptors (USEPA 2021). For each receptor location, the model generates air concentrations (or air dispersion factors as unit emissions will be modeled) that result from emissions from multiple sources.

Air dispersion models such as AERMOD require a variety of inputs such as source parameters, meteorological data, topographical data, and receptor parameters. When site-specific information was unknown, Ramboll used default parameter sets that are designed to produce conservative (i.e., overestimates of) air concentrations (USEPA 2021).

2.3.3.1 Meteorological Data
Air dispersion modeling applications require the use of meteorological data that ideally are spatially and temporally representative of conditions in the immediate vicinity of the site under consideration.

Consistent with BAAQMD recommended methodology, Ramboll used the meteorological data from the Chevron Refinery onsite station, which is the nearest station to the Project site. Meteorological data for 2017 was the most recent available data and were processed by BAAQMD using AERMET (version 18081).

2.3.3.2 Terrain and Land Use Considerations
Elevations for all emissions sources were imported from the National Elevation Dataset maintained by the United States Geological Survey ([USGS] 2013). An important consideration in an air dispersion modeling analysis is whether to model an area as urban. Here the model assumes an urban land use as has been done for similar projects in the area. Population data for the urban land use setting was obtained from the US Census Bureau, which lists the 2020 population of Richmond, CA as 110,051.

2.3.3.3 Building Downwash
The direction-specific building downwash dimensions that were used as inputs was determined by the latest version (04274) of the Building Profile Input Program, PRIME (BPIP PRIME). Onsite and nearby offsite buildings were evaluated for downwash effects on each modeled point source. One onsite power generation building, one onsite Republic Maintenance Shop, four leachate tanks, and one fire pump engine generator enclosure were included. The buildings modeled in BPIP are shown in Figure

1. 2.3.3.4 Emission Rates
Emissions were modeled using the χ/Q (“chi over q”) method, such that each source had a unit emission rate (i.e., 1 gram per second [g/s]), and the model estimated dispersion factors (with units of [µg/m3]/[g/s]). Actual emission rates were multiplied by the dispersion factors to obtain concentrations.
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References 6 Ramboll
For annual average ambient air concentrations, the estimated annual average dispersion factors were multiplied by the annual average emission rates. Actual emission rates will vary day to day (e.g., weekday vs. weekend), with some days having no emissions, however the model assumed a constant emission rate during the entire year.

Ramboll estimated the incremental TAC emissions associated with the Project’s operation as part of the permit application. The emission rates used in modeling are summarized in Table 11-12. Ramboll also estimated the landfill flare emission reductions as a result of the Project’s operation. The emission rates used in modeling of the existing landfill flare reductions are summarized in Table 13.

2.3.3.5 Source Parameters
Source location and parameters are necessary to model the dispersion of air emissions. Modeled source parameters for the Project and for the existing landfill sources are summarized in Table 14.

For the Project operational emissions, Ramboll modeled the biogas engines, flare, and fire pump engines as point sources and the green waste storage pile as an area source. The sources were modeled at the appropriate location based on information from the Project Sponsor. The source parameters (i.e., stack height and exit diameter) were also provided by the Project Sponsor. The project boundary and the modeled sources are shown in Figure 1.

2.3.3.6 Receptors
To evaluate health impacts to sensitive receptors, Ramboll conservatively modeled annual and hourly average dispersion factors at receptors within 1,000 feet of the Project. A receptor grid with 20-m spacing was created to cover all potential worker receptors within 1,000 feet of the Project site and all potential residential receptors within 4,500 feet of the Project site. There were no residential receptors within 1000ft of the Project. Additionally, Ramboll included an elementary school around 5,800 feet from the Project site and a health clinic around 6,000 feet from the Project site. The clinic receptors were conservatively assessed as residential receptors. All receptors were modeled at a height of

1.5 meters above terrain height, consistent with BAAQMD guidance for breathing height (BAAQMD 2020).

2.3.3.7 Modeling Adjustment Factors
OEHHA (2003) recommends applying an adjustment factor to the annual average concentration modeled assuming continuous emissions (i.e., 24 hours per day, 7 days per week), when the actual emissions are less than 24 hours per day and exposures are concurrent with operational activities occurring as part of the Project. The modeling adjustment factors are discussed below.

Residents are assumed to be exposed to site emissions 24 hours per day, seven days per week. This assumption is consistent with the modeled annual average air concentration (24 hours per day, 7 days per week). Thus, the annual average concentration need not be adjusted for residential receptors.

Consistent with past guidance from BAAQMD, the emissions associated with worker and school activities are conservatively assumed to occur during the working hours and on the workdays only while the offsite workers are present and children are expected to be at school. Thus, a modeling adjustment factor (MAF) of 4.2 was applied to the annual average concentration used in the evaluation of the offsite worker and school receptors to account for an emissions schedule equivalent to a worker’s schedule of 8 hours per day, 245 days per year ([24 hours/8 hours]*[365 days/245 days]). These concentrations represent the theoretical maximum average concentrations over the operating period to which the offsite worker and school receptors might be exposed. 1091
References 7 Ramboll

2.4 Risk Characterization Methods
In February 2015, OEHHA released the updated Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments (OEHHA 2015), which combines information from previously released and adopted technical support documents to delineate OEHHA’s revised risk assessment methodologies based on current science. This updated Guidance Manual supersedes the 2003 Hot Spots Guidance Manual (OEHHA 2003) that previously provided methodologies for conducting HRAs under the Air Toxics Hot Spots Program (AB2588). BAAQMD has issued guidelines on adopting the OEHHA 2015 Guidance Manual as well as additional guidance published in December 2020 (BAAQMD 2020). This evaluation utilized the 2015 OEHHA methodology following BAAQMD guidance, as discussed below.

2.4.1 Project Sources Evaluated
Ramboll evaluated excess lifetime cancer risk, non-cancer chronic HI, non-cancer acute HI, and PM2.5 concentrations for nearby sensitive receptor exposure to emissions from the construction and operation of the Project. The HRA was conducted using the methodology explained in the following sections.

2.4.1.1 Exposure Assessment
Potentially Exposed Populations: This assessment evaluated off-site receptors potentially exposed to Project emissions from construction and operational activities. These exposed populations include resident, worker, and school receptors. Health impacts (cancer risk, chronic HI, acute HI, and PM2.5 concentration) were evaluated for the resident, worker, and school receptor locations.

Exposure Assumptions: The exposure parameters used to estimate excess lifetime cancer risks for all potentially exposed populations from construction and operational emissions were obtained using risk assessment guidelines from OEHHA (2015) and BAAQMD (2016, 2020). Table 15 summarizes the exposure parameters used in the HRA.

For offsite residential receptors, Ramboll selected conservative exposure parameters assuming that exposure would begin during the third trimester of a residential child’s life. Ramboll used 95th percentile breathing rates up to age 2, and 80th percentile breathing rates above age 2, consistent with BAAQMD guidance. For operation, off-site residents were assumed to be present at one location for a 30-year period, beginning with exposure in the third trimester.

For offsite school receptors, Ramboll selected exposure parameters using the conservative assumption that a child would be at the school starting at age 5 until 13 years. For construction and operations, the child was assumed to be present at the location for 8 hours a day, for 5 days a week. Operational exposures used the 95th percentile 8-hour moderate intensity breathing rate from the OEHHA guidelines.

Operational exposure for a worker used the 95th percentile 8–hour breathing rate from the OEHHA guidelines. A 25-year exposure duration for workers is assumed based on the OEHHA recommended exposure duration period and an exposure frequency of 250 days in a year is used in the analysis.

Calculation of Intake: The dose estimated for each exposure pathway is a function of the concentration of a chemical and the intake of that chemical. The intake factor for inhalation, IFinh, can be calculated as follows:

IFinh = DBR * FAH * EF * ED * CF
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References 8 Ramboll
Where:

AT
IFinh = Intake Factor for Inhalation (m3/kg-day)
DBR = Daily Breathing Rate (L/kg-day)
FAH = Frequency of Time at Home (unitless)
EF = Exposure Frequency (days/year)
ED = Exposure Duration (years)
AT = Averaging Time (days)
CF = Conversion Factor, 0.001 (m3/L)
The chemical intake or dose is estimated by multiplying the inhalation intake factor, IFinh, by the chemical concentration in air, Ci. When coupled with the chemical concentration, this calculation is mathematically equivalent to the dose algorithm given in the current OEHHA Hot Spots guidance (OEHHA 2015).

2.4.1.2 Toxicity Assessment
The toxicity assessment characterizes the relationship between the magnitude of exposure and the nature and magnitude of adverse health effects that may result from such exposure. For purposes of calculating exposure criteria to be used in risk assessments, adverse health effects are classified into two broad categories – cancer and non-cancer endpoints. Toxicity values that are used to estimate the likelihood of adverse effects occurring in humans at different exposure levels are identified as part of the toxicity assessment component of a risk assessment.

This analysis utilizes available toxicity values including inhalation cancer potency factors (CPFs), acute inhalation reference exposure levels (aRELs), and chronic inhalation reference exposure levels (cRELs). Toxicity values are summarized in Table 16.

2.4.1.3 Age Sensitivity Factors
The estimated excess lifetime cancer risks for a resident were adjusted using age sensitivity factors (ASFs) that account for an “anticipated special sensitivity to carcinogens” of infants and children as recommended in the OEHHA Technical Support Document (OEHHA 2009) and OEHHA 2015 Guidance (2015). Cancer risk estimates were weighted by a factor of 10 for exposures that occur from the third trimester of pregnancy to two years of age and by a factor of three for exposures that occur from two years through 15 years of age. No weighting factor (i.e., an ASF of one, which is equivalent to no adjustment) was applied to ages 16 and older.

2.4.1.4 Estimation of Cancer Risk
Excess lifetime cancer risks are estimated as the upper-bound incremental probability that an individual will develop cancer over a lifetime as a direct result of exposure to potential carcinogens.

The estimated risk is expressed as a unitless probability. The cancer risk attributed to a chemical is calculated by multiplying the chemical intake or dose at the human exchange boundaries (e.g., lungs) by the chemical specific CPF.

The equation used to calculate the potential excess lifetime cancer risk for the inhalation pathway is as follows:
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References 9 Ramboll
Riskinh =Ci x CF x IFinh x CPF x ASF
Where:

Riskinh = Cancer risk; the incremental probability of an individual developing cancer as a result of inhalation exposure to a particular potential carcinogen (unitless)
Ci = Annual average air concentration for chemicali (µg/m3) CF = Conversion factor (mg/µg)
IFinh = Intake factor for inhalation (m3/kg-day)
CPFi = Cancer potency factor for chemicali
(mg chemical/kg body weight-day)-1
ASF = Age sensitivity factor (unitless)

2.4.1.5 Estimation of Chronic HI
The potential for exposure to result in adverse chronic noncancer effects is evaluated by comparing the estimated annual average air concentration (which is equivalent to the average daily air concentration) to the noncancer chronic reference exposure level (cREL) for each chemical. When calculated for a single chemical, the comparison yields a ratio termed a hazard quotient (HQ). To evaluate the potential for adverse chronic noncancer health effects from simultaneous exposure to multiple chemicals, the chronic HQs for all chemicals are summed, yielding a chronic HI.

HQi =Ci / cREL
Where:

HQi = Chronic hazard quotient for chemical i
HI = Hazard index
Ci = Annual average concentration of chemical i (µg/m3) cRELi = Chronic noncancer reference exposure level for chemical i (µg/m³)

2.4.1.6 Estimation of Acute HI
The potential for exposure to result in adverse acute effects is evaluated by comparing the estimated one-hour maximum air concentration of chemical to the acute reference exposure level (aREL) for each chemical evaluated in this analysis. When calculated for a single chemical, the comparison yields an HQ. To evaluate the potential for adverse acute health effects from simultaneous exposure to multiple chemicals, the acute HQs for all chemicals are summed, yielding an acute HI.

HQi =Ci / aREL
Where:

HQi = Acute hazard quotient for chemical i
HI = Hazard index
Ci = One-hour maximum concentration of chemical i (µg/m3) aRELi = Acute reference exposure level for chemical i (µg/m³) 1094
References 10 Ramboll

2.4.1.7 Estimation of Project Health Risks
For all receptor types including off-site residents and off-site workers, results for cancer risk, chronic HI, acute HI, and PM2.5 concentrations are presented in Section 3 for the maximally exposed individual receptor (MEIR), which are the locations where the maximum health impacts are estimated to occur.

2.4.2 Cumulative Analysis
The cumulative analysis includes Project impacts added to background risk and risk from nearby existing stationary sources. Background risks are available through BAAQMD Roadway Screening Analysis Calculator, and stationary sources are available through the BAAQMD Stationary Source Screening Tool (BAAQMD 2020).

Ramboll used the BAAQMD Stationary Source Screening Tool to identify existing permitted stationary sources within 1,000 feet of the Maximally Exposed Individual Receptor (MEIR) locations. Ramboll submitted a stationary source inquiry form to the BAAQMD to request confirmation or revisions to the data obtained from the Stationary Source Screening Tool, but BAAQMD did not provide any new information. As such, Ramboll assumed that the data available through the Stationary Source Screening Tool is the best available data., and there are no stationary sources within 1,000 feet of the Project. Considering that the Project will utilize LFG from the landfill site, we have added the background risks from the landfill to the MEIRs in this cumulative analysis to ensure comprehensiveness and conservativeness. The risks at each MIER are calculated based on on-site risks listed in BAAQMD’s Screening Tool and a distance multiplier. We calculated the distance multiplier using the BAAQMD Distance Multiplier table and an exponential extrapolation. This is because all distances to the MEIRs are over 1,000 ft so multipliers and not directly available from the BAAQMD table.

The BAAQMD Roadway Screening Analysis Calculator from 2015 was used to find the cancer risk and PM2.5 concentrations at the MEIRs.1 These estimated health impacts were added to the total project health impacts. The screening calculator does not provide estimates of chronic HI because chronic HI is expected to be minor for traffic sources. Therefore, the impact from vehicles on chronic HI is not included in the cumulative analysis.
3 RESULTS FROM PROJECT ANALYSIS

3.1 Project Health Impacts
The purpose of this HRA is to analyze potential health impacts that would result from construction and operation of the Project. This HRA includes quantification of the estimated cancer risk, chronic HI, acute HI, and PM2.5 concentration associated with operation of the Project.

As described above, Ramboll performed air dispersion modeling using the American Meteorological Society/USEPA Regulatory Model (AERMOD) (version 22112), with representative meteorological data to determine diesel particulate matter (DPM) and PM2.5 concentrations for potentially exposed individuals. These concentrations were used to assess the potential human health risk. The estimated Project health risks account for impacts from both construction and operations. 1 The Roadway Screening Analysis Calculator is an older tool developed by BAAQMD to estimate screening level health impacts from roadways. This calculator is out of date since it uses emissions estimates that have been superseded and assumes fleet emission factors from 2014. Since the development of this tool, emissions from vehicles have been reduced due to regulations and increased penetration of electric vehicles. Therefore, this estimate of approximate health impacts from the Project traffic is conservative (i.e., overpredicts impacts). 1095
References 11 Ramboll
The maximum Proposed Project health impacts by population type along with reductions from landfill flaring, as discussed in Section 2.4, are summarized in Table A. The locations of the MEIRs for cancer risk, chronic HI, acute HI, and PM2.5 concentration are shown in Figure 2. Project health impacts from construction and operational sources as well as land fill flare reductions are summarized in Table 17.

Table A. Project Health Impacts from Construction and Operations Excess Lifetime
Cancer Risk
(in a million)
Non-Cancer
Hazard Index
(unitless)
Acute Hazard
Index
(unitless)
PM2.5
Concentration
(µg/m3)
Construction + Operations
Worker 3.0 0.058 0.22 0.57
Resident 0.70 0.0086 0.0039 0.024
School 0.49 0.011 0.036 0.030
Clinic 0.46 0.0058 0.032 0.016
Landfill Reductions
Worker -5.7 -0.21 -0.49 -0.84
Resident -1.3 -0.018 -0.10 -0.042
School -0.81 -0.019 -0.091 -0.044
Clinic -0.79 -0.011 -0.077 -0.026
Project Construction + Operations with Landfill Reductions Worker -2.7 -0.16 -0.27 -0.27
Resident -0.57 -0.009 -0.064 -0.018
School -0.32 -0.0084 -0.055 -0.014
Clinic -0.33 -0.0056 -0.045 -0.010
Source: Table 17

3.2 Cumulative Analysis
The cumulative analysis includes Project impacts added to background risk, sourced from BAAQMD’s Roadway Screening Tool. Cumulative health risks are shown in Table 18. The cumulative cancer and non-cancer risks, and the PM2.5 concentrations from the cumulative analysis are all below BAAQMD significance thresholds. It should be noted that the cumulative risks are predominantly from the background risks (i.e., the landfill), and the Project itself has a negative calculated risk, meaning the Project would reduce health risks at the worker MEIR. It should also be noted that the actual cumulative risks are likely to be even lower when considering the indoor ventilation at all MEIR sites.

We also note that the calculated risk for the landfill listed in BAAQMD’s Screening Tool is likely an overestimate. This risk would have included the existing landfill flare as well as the existing LFG-fired engines at the landfill. With this project, some portion of the LFG will be diverted to be used by the new biogas engines (meaning a reduction in LFG flaring), and the old landfill engines will be shut down.
1096
References 12 Ramboll
Additionally, Section 15355 of the State CEQA Guidelines defines a cumulative impact as the condition under which “two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts... The cumulative impact from several projects is the change in the environment which results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects.” (California Code of Regulations [C.C.R.] Section 15355). In other words, the purpose of cumulative analysis is to understand the incremental impacts of the Project on the neighboring areas.

Given that this Project will reduce health risks to all MEIRs as shown in Table A, the incremental impact of the Project is expected to be beneficial to the neighboring areas. Therefore, a quantitative cumulative health impact analysis may have been unnecessary. 1097
References 13 Ramboll
4 REFERENCES
Bay Area Air Quality Management District (BAAQMD). Recommended Methods for Screening and Modeling Local Risks and Hazards. May 2011. Table 14. Available at:
http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/CEQA/BAAQMD%20 Modeling%20Approach.ashx?la=en.

BAAQMD. 2016. Proposed Health Risk Assessment Guidelines. Air Toxics NSR Program. January.

Available at: http://www.baaqmd.gov/~/media/files/planning-and-research/rules-andregs/workshops/2016/reg-2-5/hra-guidelines_clean_jan_2016-pdf.pdf?la=en BAAQMD. 2017. California Environmental Quality Act Air Quality Guidelines. May. Available at:
http://www.baaqmd.gov/~/media/files/planning-andresearch/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en BAAQMD. 2020. Health Risk Assessment Modeling Protocol. December. Available at:
https://www.baaqmd.gov/~/media/files/ab617-community-health/facility-riskreduction/documents/baaqmd_hra_modeling_protocol-pdf.pdf?la=en BAAQMD. 2020. Stationary Source Screening Map. Available at:
https://baaqmd.maps.arcgis.com/apps/webappviewer/index.html?id=845658c19eae4594b9 f4b805fb9d89a3
BAAQMD. 2022. Health Risk Calculator with Distance Multipliers. Available at:
https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-actceqa/ceqa-tools/health-risk-screening-and-modeling California Environmental Protection Agency (Cal/EPA), Office of Environmental Health Hazard Assessment (OEHHA). 1998. Findings of the Scientific Review Panel on The Report on Diesel Exhaust, as adopted at the Panel’s April 22, 1998, meeting.

Cal/EPA. 2016. OEHHA/ARB Consolidated Table of Approved Risk Assessment Health Values.

March. Available at: http://www.arb.ca.gov/toxics/healthval/contable.pdf Federal Register EPA; 40 CFR Part 98 Subpart A, Table A-1, Available at:
https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-98/subpart-A/appendixTable%20A-1%20to%20Subpart%20A%20of%20Part%2098 Federal Register EPA; 40 CFR Part 98 Subpart C, Available at:
https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-98/subpart-C Office of Environmental Health Hazard Assessment (OEHHA). 2003. The Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments. Office of Environmental Health Hazard Assessment. August. Available at:
https://oehha.ca.gov/media/downloads/crnr/hrafinalnoapp.pdf OEHHA. 2009. Technical Support Document for Cancer Potency Factors: Methodologies for derivation, listing of available values, and adjustments to allow for early life stage exposures. Office of Environmental Health Hazard Assessment. May. Available at:
http://www.oehha.ca.gov/air/hot_spots/2009/TSDCancerPotency.pdf OEHHA. 2015. The Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments. Office of Environmental Health Hazard Assessment. August. Available at:
http://www.oehha.ca.gov/air/hot_spots/pdf/HRAguidefinal.pdf 1098
References 14 Ramboll
US Census Bureau. American Community Survey. 2020: ACS 5-Year Estimates Data Profiles.

ACS Demographic and Housing Estimates. Available at:
https://data.census.gov/cedsci/table?t=Populations%20and%20People&g=1600000US0660 620&y=2020&tid=ACSDP5Y2020.DP05
USEPA. 2021. User's Guide for the AMS/EPA Regulatory Model (AERMOD). Office of Air Quality Planning and Standards. Research Triangle Park, North Carolina. EPA-454/B-21-001, April 2021). Available at:
https://gaftp.epa.gov/Air/aqmg/SCRAM/models/preferred/aermod/aermod_userguide.pdf United States Geological Survey (USGS). 2013. National Elevation Dataset. Available at:
http://viewer.nationalmap.gov/viewer/
1099
15 TABLES
Table 1: Construction Schedule
Table 2: Construction Equipment
Table 3: Emissions Calculation Methodology
Table 4: Construction Trips
Table 5: Silt Loading Emission Factors
Table 6: Emission Factors for Entrained Roadway Dust
Table 7: Emission Calculations for Entrained Roadway Dust Table 8: Fugitive Dust Emissions from Demolition Activity Table 9: Fugitive Dust Emissions from Off-Road Grading Activity Table 10: Fugitive Dust Emissions from Truck Loading Activity Table 11: Modeled Emission Rates – Project Construction Table 12: Modeled Emission Rates – Project Operational Sources Table 13: Modeled Emission Rates – Existing Landfill Flare Reductions Table 14: Modeling Parameters
Table 15: Exposure Parameters
Table 16: Toxicity Values
Table 17: Project Health Impacts
Table 18: Cumulative Health Impacts

FIGURES
Figure 1: Modeled Sources and Buildings
Figure 2: Modeled Receptors and Maximally Exposed Individual Receptor Locations 1100
16 TABLES
1101
Construction Subphase1 Start Date End Date Year Number of Work Days Days per Week
Demolition 4/1/2023 4/7/2023 2023 5 5
Site Preparation 4/10/2023 5/19/2023 2023 30 5
Grading 5/22/2023 6/30/2023 2023 30 5
Building Construction 7/3/2023 1/8/2024 2024 136 5
Notes:

1. All construction phasing information was provided by the Project Sponsor. The April 1, 2023 construction start date was selected based on a projected start date in the First Quarter of 2023. This date is conservative in terms of estimating air emissions, although the date of actual construction is likely to be later, based on the expected dates of project permits and entitlements.

Table 1
Construction Schedule
Raven SR
Richmond, CA
1102
4/1/2023
Construction
Subphase(s) Equipment Name1 Fuel1 Number1 Horsepower2 Days Per Phase1
Daily Usage
(hours/day)1 Utilization1 Uncontrolled Engine Tier3
Air Compressors Diesel 1 37 5 8 100% No Specific Tier
Crushing/Proc. Equipment Gasoline 1 12 5 8 100% No Specific Tier Excavators Diesel 1 36 5 8 100% No Specific Tier
Dumpers/Tenders Diesel 2 16 5 8 100% No Specific Tier
Excavators Diesel 3 36 30 8 100% No Specific Tier
Tractors/Loaders/Backhoes Diesel 1 84 30 8 100% No Specific Tier Rough Terrain Forklifts Diesel 1 96 30 4 100% No Specific Tier Dumpers/Tenders Diesel 1 16 30 8 100% No Specific Tier
Plate Compactors Diesel 2 8 30 8 100% No Specific Tier
Crawler Tractors Diesel 1 87 30 8 100% No Specific Tier Rollers Diesel 1 36 30 8 100% No Specific Tier
Tractors/Loaders/Backhoes Diesel 1 84 30 8 100% No Specific Tier Excavators Diesel 1 36 30 8 100% No Specific Tier
Cranes Diesel 1 367 136 8 100% No Specific Tier
Rough Terrain Forklifts Diesel 1 96 136 8 100% No Specific Tier Air Compressors Diesel 1 37 136 8 100% No Specific Tier Generator Sets Diesel 1 14 136 8 100% No Specific Tier
Welders Diesel 2 46 136 8 100% No Specific Tier
Other Construction Equipment Diesel 1 82 136 8 100% No Specific Tier Notes:

1. 2.

3. Abbreviations:

ARB - California Air Resources Board
CalEEMod - California Emissions Estimator Model
References:

The California Emissions Estimator Model (CalEEMod). Available at: http://www.caleemod.com/ Demolition
Site Preparation
Grading
Building Construction
Construction equipment information was provided by the Project Sponsor or based on CalEEMod defaults if not given.

Equipment horsepower is based on CalEEMod Appendix G defaults.

Equipment engine tiers are based on CalEEMod fleet averages.

Table 2
Construction Equipment
Raven SR
Richmond, CA
Anticipated Construction Start Date:
1103
Type Source Methodology and Formula Reference
Construction
Equipment Off-Road Equipment1 Ec = Σ(EFc * HP * LF * Hr * UF * C) OFFROAD2017 and
ARB/USEPA Engine
Standards
Construction
Fugitive Dust
Mechanical Dismemberment,
Grading, Truck Loading CalEEMod CalEEMod
Exhaust – Running ER = Σ(EFR * VMT * C) , where
VMT = Trip Length * Trip Number EMFAC2021
Brake Wear and Tire Wear EBW,TW = Σ(EFBW,TW * VMT * C), where VMT = Trip Length * Trip Number EMFAC2021
Exhaust - Idling EI = Σ(EFI * Trip Number *TI* C) EMFAC2021 Entrained Road Dust ERD = Σ(EFRD * VMT * C) , where
VMT = Trip Length * Trip Number
ARB 2021 Miscellaneous
Process Methodology 7.9
Notes:

1. Ec: off-road equipment exhaust emissions (lb)
EFc: emission factor (g/hp-hr). CalEEMod default emission factors used HP: equipment horsepower. From CalEEMod defaults
LF: equipment load factor. From OFFROAD2017
Hr: equipment hours
UF: Utilization factor
C: unit conversion factor

2. ER: running exhaust and running losses emissions (lb) EFR: running emission factor (g/mile). From EMFAC2021
VMT: vehicle miles traveled
C: unit conversion factor
The calculation involves the following assumptions:
a. All material transporting and soil hauling trucks are heavy-heavy duty trucks.

EI: vehicle idling emissions (lb).

EFI: vehicle idling emission factor (g/hr-trip). From EMFAC2021 TI: idling time
C: unit conversion factor
ERD: entrained road dust emissions (lb)
EFRD: annual average emission factor (lb/VMT) = k*(sL)^0.91 * (W)^1.02 * (1-P/4N) k: particle size multiplier for particle size range
sL: roadway silt loading [grams per square meter - g/m2] W: average weight of vehicles traveling the road [tons] P = number of “wet” days in county with at least 0.01 in of precipitation during the annual averaging period N = number of days in the averaging period
VMT: vehicle miles traveled
C: unit conversion factor
Abbreviations:

ARB: California Air Resources Board lb: pound
BW: Brake Wear LF: Load Factor
EF: Emission Factor mi: mile
EMFAC: EMission FACtor Model USEPA: United States Environmental Protection Agency g: gram RL: Running Losses
HP: horsepower VMT: vehicle miles traveled
References:

On-road mobile sources include truck and passenger vehicle trips. Emissions associated with mobile sources were calculated using the following formulas.
b. Trip Length: The one-way trip length as calculated based on CalEEMod Appendix G defaults for Contra Costa County or provided by the Project Sponsor
c. Trip Number: Worker, vendor and hauling trip rates were provided by the Project Sponsor.

ARB/USEPA. 2013. Table 1: ARB and USEPA Off-Road Compression-Ignition (Diesel) Engine Standards. Available online at:
http://www.arb.ca.gov/msprog/ordiesel/documents/Off-Road_Diesel_Stds.xls The California Emissions Estimator Model (CalEEMod). Available at: http://www.caleemod.com/ California Air Resources Board (ARB) 2021. EMFAC2021. Available at: https://ww2.arb.ca.gov/our-work/programs/mobile-source-emissionsinventory/msei-modeling-tools Table 3
Emission Calculation Methodology
Raven SR
Richmond, CA
Construction and
Operational OnRoad Mobile
Sources2
1104
Trip Data
Trip Rates1 (one-way
trips/subphase)
Worker Trips Vendor Trips Hauling Trips Worker Trips Vendor Trips Hauling Trips Demolition 2023 5 2 0 100 12.9 7.4 20
Site Preparation 2023 30 2 0 0 12.9 7.4 20
Grading 2023 30 2 0 0 12.9 7.4 20
Building Construction 2023 131 2 4 0 12.9 7.4 20
Building Construction 2024 5 2 4 0 12.9 7.4 20
EMFAC Data4
Trip Type EMFAC Settings Fuel Type
Worker Gasoline
Vendor Diesel
Hauling Diesel
Notes:

1. 2.

3. Abbreviations:

CalEEMod - California Emissions Estimator Model
EMFAC2021 - California Air Resources Board EMission FACtor model LDA - light-duty automobiles
LDT - light-duty trucks
HHDT - heavy-heavy duty trucks
sqft - square feet
References:

Table 4
Richmond, CA
Raven SR
Construction Trips
Worker, vendor, and hauling trip rates were provided by the Project Sponsor.

Trip Rates1 (trips/day)
Worker, vendor, and hauling trip lengths are based on CalEEMod Appendix G defaults for Contra Costa County.

Emissions were calculated using emission factors from EMFAC2021 with the specified settings and fleet and fuel assumptions.

The California Emissions Estimator Model (CalEEMod). Available at: http://www.caleemod.com/ California Air Resources Board (ARB) 2021. EMFAC2021. Available at: https://ww2.arb.ca.gov/our-work/programs/mobile-source-emissions-inventory/msei-modeling-tools Trip Lengths2 (miles/one-way trip)
Construction
Fleet Mix
Contra Costa County
Calendar Years 2023-2024
Annual Season
Aggregated Model Year
EMFAC2007 Vehicle Categories
25% LDA, 50% LDT1, 25% LDT2
50% MHDT, 50% HHDT
100% HHDT
Construction Phase Construction Subphase Year Construction Days
1105
Roadway Category Silt Loading1
(g/m2) Travel Fraction1
Freeway 0.015 50%
Major 0.032 37%
Collector 0.032 9%
Local - Urban 0.32 4%
Weighted Silt Loading Factor 0.035 100%
Notes:

1. Abbreviations:

ARB - Air Resources Board
g - gram(s)
m - meter
References:

California Air Resources Board (ARB). 2021. Miscellaneous Process Methodology 7.9, Entrained Road Travel, Paved Road Dust. March. Available online at:
https://ww3.arb.ca.gov/ei/areasrc/fullpdf/2021_paved_roads_7_9.pdf Table 5
Silt Loading Emission Factors
Raven SR
Richmond, CA
Entrained Roadway Dust Constants for Contra Costa County Travel fraction by roadway category and silt loading are based on ARB's Entrained Road Travel Emission Inventory Source Methodology Tables 2 and 4, respectively. 1106
Road Dust Equation1
E [lb/VMT] = [k*(sL)^0.91 * (W)^1.02]*(1-P/4N)
Parameters2,3 Value
E = annual average emission factor in the same units as k [calculated] k = particle size multiplier for particle size range
PM2.5 (lb/VMT) 3.3E-04
sL = roadway silt loading [grams per square meter - g/m2] 0.035 W = average weight of vehicles traveling the road [tons] 2.4 P = number of “wet” days in county with at least 0.01 in of precipitation during the annual averaging period3 30
N = number of days in the averaging period 365
Entrained Road Dust Emission Factors
PM2.5 Emission Factor [lb/VMT] 3.74E-05
Notes:

1. 2.

3. Abbreviations:

ARB - California Air Resources Board lb - pound
CalEEMod - California Emissions Estimator Model PM2.5 - particulate matter less than 2.5 microns EMFAC - EMission FACtor Model VMT - vehicle miles traveled g - gram
References:

The number of "wet" days for Richmond, CA is from CalEEMod Appendix G Table G-2 (30 days).

California Air Resources Board (ARB). 2021. Miscellaneous Process Methodology 7.9, Entrained Road Travel, Paved Road Dust. March. Available online at: https://ww3.arb.ca.gov/ei/areasrc/fullpdf/2021_paved_roads_7_9.pdf The California Emissions Estimator Model (CalEEMod). Available at: http://www.caleemod.com/ Table 6
Emission Factors for Entrained Roadway Dust
Raven SR
Richmond, CA
Road dust equation and parameters are from the California Air Resources Board's (ARB) 2021 Miscellaneous Process Methodology 7.9 for Entrained Road Travel, Paved Road Dust.

The silt loading emission factor assumes Contra Costa County default roadway fractions and silt loading levels from ARB 2021. Other parameters (average weight of vehicles, size multipliers) are from ARB 2021. PM2.5 is assumed to be 15% of PM10 based on paved road dust sampling in California (ARB Speciation Profile #471), which is a more representative fraction than provided in the older AP-42 fugitive dust methodology as discussed in ARB 2021 (page 17). 1107
Worker Trip length (miles/trip) 0.189
Vendor Trip Length (miles/trip) 0.189
Hauling Trip Length (miles/trip) 0.189
PM2.5 Emission Factor [lb/VMT] 3.74E-05
PM2.5
Demolition 2023 5 2 0 100 2 0 19 21 7.8E-04
Site Preparation 2023 30 2 0 0 11 0 0 11 4.2E-04
Grading 2023 30 2 0 0 11 0 0 11 4.2E-04
Building Construction 2023 131 2 4 0 50 99 0 149 0.0056 Building Construction 2024 5 2 4 0 2 4 0 6 0.0002
Notes:

1. 2.

Abbreviations:

CalEEMod - California Emissions Estimator Model lb - pound PM2.5 - particulate matter less than 2.5 microns VMT - vehicle miles traveled Entrained road dust emission factors were obtained from Table 6.

Total VMT
(miles)
Total Emissions
(lb)
Construction
VMTs for worker, vendor, and hauling are obtained from Table 4.

Vendor Trips
(trips/day)
Hauling Trips
(trips/subphase)
Worker VMT
(miles)
Vendor VMT
(miles)
Hauling VMT
(miles)
Worker Trips
(trips/day)
Table 7
Emission Calculation for Entrained Roadway Dust
Raven SR
Richmond, CA
Construction Area Subphase Year Construction
Days
Entrained Road Dust Emission Factors2
Calculated
1000 feet
1000 feet
1000 feet
Inputs
Trip Length1
1108
PM2.5 PM2.5
days ton lb/day ton/yr
Construction 2023 5.0 828 3.5E-04 0.0031 0.57 0.0014
Notes:

1. 2.

0.053 = k, PM2.5 particle size multiplier (dimensionless)

3.90 = mean wind speed (U), meters per second, Oakland International Airport

8.7 = U, mean wind speed (mph)
2 = M, material moisture content (%)

3. 0.053 = k, PM2.5 particle size multiplier (dimensionless)

0.058 = EFL-TSP, lb/ton

4. Abbreviations:

CalEEMod - California Emissions Estimator Model
cy - cubic yards
EF - emission factor
lb - pounds
PM2.5 - particulate matter less than 2.5 microns
VMT - vehicle miles traveled
yr - years
Emissions were estimated conservatively assuming no fugitive dust control measures.

Building
Waste1
Emission Factor -
Mechanical or
Explosive
Dismemberment2
Emission Factor -
Debris Loading3
Uncontrolled
Emissions4
PM2.5
lb/ton lb/ton
Building square footage was provided by the Project Sponsor. Conversion of building waste to tons assumes an average soil density of 1.5 grams per cubic centimeter, per the CalEEMod User's Guide, Appendix C Truck Loading.

Emission factor calculated following guidance in the CalEEMod User's Guide, Appendix C Mechanical or Explosive Dismemberment, which is based of AP 42 Section 13.2.4.3 for batch drop operations. The equation is:

EF = k*(0.0032)*(U/5)1.3/(M/2)1.4 (lb/ton of debris)
Emission factor calculated following guidance in the CalEEMod User's Guide, Appendix C Debris Loading, which is based of AP 42 Section

13.2. The equation is:

EF = k*EFL-TSP
Table 8
Fugitive Dust Emissions from Demolition Activity
Raven SR
Richmond, CA
Construction Area Year
Number
of Days
1109
PM2.5
acre/8hr-day acre/day mile/day lb/VMT
Construction Grading 2023 30 Crawler Tractors 1 100% 0.5 0.50 0.34 0.17 1.72 Notes:

1. 2. Based on CalEEMod® default daily acres graded by equipment type, Table G-14, below.

Equipment
Acres Graded per 8
Hour Day
Crawler Tractors 0.5
Graders 0.5
Rubber Tired Dozers 0.5
Scrapers 1

3. AS = AS, acres graded per day (varies by sub-activity); in this case using maximum estimated disturbed acres/day 12 = Wb, blade width of grading equipment (CalEEMod®
default) in ft

3. 7.1 = S, mean vehicle speed (mph) (AP-42 default)

0.6 = FPM10, PM10 scaling factor (AP-42 default)

0.031 = FPM2.5, PM2.5 scaling factor (AP-42 default)
Abbreviations:
mph - miles per hour
PM2.5 - particulate matter less than 2.5 microns
ft - feet VMT - vehicle miles traveled
lb - pounds yr - year
Table 9
Fugitive Dust Emissions from Off-Road Grading Activity
Raven SR
Richmond, CA
Construction Area Construction
Subphase1 Year
lb/yr
Total Work Days
(per year) Equipment Quantity Utilization %
CalEEMod
Grading rate2
Maximum Area
Disturbed1
EF - emission factor
Grading VMT2 Uncontrolled PM2.5
Emission Factor3
Uncontrolled
Emissions
Maximum graded area calculated following guidance in the CalEEMod® User's Guide, Appendix C.

VMT per day calculated following guidance in the CalEEMod® User's Guide, Appendix C, which is based on AP-42, Section 11.9 for grading equipment. The equation is:

VMT = A /W x (43,560 sqft/acre)/(5,280 ft/mile), where:

Emission factors calculated following guidance in the CalEEMod® User's Guide, Appendix C, which is based on AP-42, Section 11.9 for grading equipment. The equations are:

2.0 CalEEMod® - California Emissions Estimator Model
1110
PM2.5
days # trips ton ton lb/day ton/yr
Construction Demolition 2023 5 100 828 828 2.85E-05 4.7E-03 1.2E-05 Notes:

1. 2.

0.053

3.9 8.7
12 Abbreviations:

CalEEMod - California Emissions Estimator Model
EF - emission factor
lbs - pounds
PM2.5 - particulate matter less than 2.5 microns
= kPM2.5, PM2.5 particle size multiplier
= mean wind speed (U), meters per second, Oakland International Airport = mean wind speed (U), miles per hour
= material moisture content (M), %
Total materials loaded for demolition phase were the building waste converted from square feet to tons assuming an average soil density of 1.5 grams per cubic centimeter, per the CalEEMod User's Guide, Appendix C Truck Loading. Total exported materials for other phases is assumed to be zero, as provided by the Project Sponsor.

Emission factor calculated following guidance in the CalEEMod User's Guide, Appendix C, which is based on AP-42, Section 13.2.4 for aggregate handling. The equation is:

EF = k x (0.0032) x (U/5)1.3 / (M/2)1.4 , where the following default values are used:

PM2.5
Haul Trips Total Material
Loaded1
Material
Loaded
Uncontrolled
Emission Factor2 Uncontrolled Emissions
Table 10
Fugitive Dust Emissions from Truck Loading Activity
Raven SR
Richmond, CA
Construction Area Construction Subphase Year
Number of
Days
lb/ton
1111
DPM PM2.5 DPM PM2.5
2023 0.0026 0.0025 3.0E-07 5.9E-07
2024 8.4E-05 7.7E-05 1.0E-08 2.1E-08
Total 0.0027 0.0026 3.1E-07 6.1E-07
Notes:

1. Abbreviations:

BAAQMD - Bay Area Air Quality Management District
CalEEMod® - California Emissions Estimator Model®
DPM - diesel particulate matter
PM2.5 - particulate matter less than 2.5 microns
References:

Table 11
Modeled Emission Rates - Project Construction Sources
Raven SR
Richmond, CA
Year
Construction Emissions1 [g/s]
Offroad Onroad
Construction TAC emissions were estimated from on-site off-road emissions, where all PM10 tailpipe emissions are assumed to be DPM (although a portion of this is likely not from diesel sources). On-road emissions from hauling, vendor and worker vehicles were estimated using a modeled trip length of 1000 ft. The inclusion of on-road emissions is conservative as the estimated traffic volumes do not exceed the screening levels recommended by BAAQMD (i.e., more than 10,000 vehicles per day and 100 trucks per day) and can be considered minor sources (BAAQMD 2011).

Recommended Methods for Screening and Modeling Local Risks and Hazards. 2012. BAAQMD. May. Available online at: https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/risk-modeling-approach-may2012.pdf?la=en The California Emissions Estimator Model (CalEEMod). Available at: http://www.caleemod.com/ California Environmental Quality Act (CEQA) Guidelines. 2017. Bay Area Air Quality Management District (BAAQMD). May. Available online at: http://www.baaqmd.gov/~/media/files/planning-andresearch/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en 1112
Biogas
Engines1
Green Waste
Offgas2 Flare2 Fire Pump Engine2
Biogas
Engines1
Green Waste
Offgas2 Flare2 Fire Pump Engine2
(g/s) (g/s) (g/s) (g/s) (g/s) (g/s) (g/s) (g/s)
1,1,1-Trichloroethane (Methyl chloroform) 3.3E-05 -- -- -- 3.3E-05 -- -- -- 1,1,2,2-Tetrachloroethane 1.2E-05 -- -- -- 1.2E-05 -- -- -- 1,1,2-Trichloroethane (Vinyl trichloride) 9.7E-06 -- -- -- 9.8E-06 -- -- -- 1,1-Dichloroethane (Ethylidene dichloride) 0.0017 -- -- -- 0.0017 -- -- -- 1,1-Dichloroethene (Vinylidene chloride) 7.3E-05 -- -- -- 7.3E-05 -- -- -- 1,3-Butadiene 4.2E-05 -- -- -- 4.2E-05 -- -- --
1,4-Dichlorobenzene 1.7E-04 -- -- -- 1.7E-04 -- -- --
1,4-Dioxane (1,4-Diethylene dioxide) 6.4E-06 -- -- -- 6.4E-06 -- -- -- Acetaldehyde 0.0062 1.3E-04 1.2E-05 -- 0.0062 8.7E-05 2.0E-07 -- Acetone 3.1E-07 -- -- -- 3.1E-07 -- -- --
Acrolein 8.0E-04 -- 7.7E-06 -- 8.0E-04 -- 1.3E-07 --
Acrylonitrile 7.8E-06 -- -- -- 7.8E-06 -- -- --
Allyl Chloride (3-Chloropropene) 5.6E-06 1.6E-06 -- -- 5.6E-06 1.0E-06 -- -- Aluminum (Al) 7.5E-08 -- -- -- 7.5E-08 -- -- --
Ammonia 1.5E-05 2.3E-04 -- -- 0.48 1.5E-04 -- --
Arsenic -- -- 5.7E-07 -- -- -- 9.5E-09 --
Benzene 0.044 -- 2.3E-05 -- 0.044 -- 3.8E-07 --
Benzyl Chloride 7.3E-06 -- -- -- 7.3E-06 -- -- --
Beryllium -- -- 1.7E-08 -- -- -- 2.8E-10 --
Bromine (Br) 1.5E-08 -- -- -- 1.5E-08 -- -- --
Cadmium (Cd) 4.4E-08 -- 3.1E-06 -- 4.4E-08 -- 5.2E-08 -- Carbon Disulfide 5.6E-06 1.8E-06 -- -- 5.6E-06 1.2E-06 -- -- Carbon Tetrachloride 1.1E-05 -- -- -- 1.1E-05 -- -- --
Chlorine (Cl) 1.1E-08 -- -- -- 1.1E-08 -- -- --
Chlorobenzene 4.2E-05 -- -- -- 4.2E-05 -- -- --
Chloroform 6.9E-05 -- -- -- 6.9E-05 -- -- --
Chromium (Cr) 5.0E-10 -- -- -- 5.0E-10 -- -- --
Cobalt (Co) -- -- -- -- -- -- -- --
Copper (Cu) 2.2E-09 -- 2.4E-06 -- 2.2E-09 -- 4.0E-08 -- Diesel particulate matter -- -- -- 0.83 -- -- -- 9.4E-05 Dioxins PCDDs 3.6E-09 -- -- -- 3.6E-09 -- -- --
Ethene 0.026 -- -- -- 0.026 -- -- --
Ethyl Chloride (Chloroethane) 8.7E-05 -- -- -- 8.7E-05 -- -- -- Ethylbenzene 6.0E-04 7.3E-06 2.7E-05 -- 6.0E-04 4.9E-06 4.5E-07 -- Ethylene Dibromide (1,2-dibromoethane) 1.4E-05 -- -- -- 1.4E-05 -- -- -- Ethylene Dichloride (1,2-dichloroethane) 2.9E-04 3.3E-06 -- -- 2.9E-04 2.2E-06 -- -- Formaldehyde 0.031 -- 6.3E-04 -- 0.031 -- 1.0E-05 --
Furan 7.9E-07 -- -- -- 7.9E-07 -- -- --
Hydrochloric Acid (Hydrogen Chloride) 0.48 -- -- -- 0.26 -- -- -- Hydrofluoric Acid (Hydrogen Fluoride) 0.015 -- -- -- 0.0084 -- -- -- Hydrogen Sulfide (H2S) 2.1E-06 -- -- -- 2.1E-06 -- -- -- Isopropyl alcohol (IPA, 2-Propanol) 6.9E-05 1.4E-05 -- -- 6.9E-05 9.1E-06 -- -- Lead (Pb) 3.5E-07 -- 1.4E-06 -- 3.5E-07 -- 2.4E-08 --
Manganese (Mn) 8.4E-10 -- 1.1E-06 -- 8.4E-10 -- 1.8E-08 -- Mercury 3.3E-08 -- 7.4E-07 -- 3.3E-08 -- 1.2E-08 --
Methanol (Methyl alcohol) 2.3E-05 0.0073 -- -- 2.4E-05 0.0049 -- -- Methyl Bromide (Bromomethane) 6.9E-06 -- -- -- 6.9E-06 -- -- -- Methyl Ethyl Ketone (2-butanone) 1.1E-05 2.7E-04 -- -- 1.1E-05 1.8E-04 -- -- Methyl tert-Butyl Ether 6.4E-06 -- -- -- 6.4E-06 -- -- -- Methylene Chloride (dichloromethane) 0.0074 -- -- -- 0.0074 -- -- -- Naphthalene 5.2E-04 4.6E-07 1.7E-06 -- 5.2E-04 3.1E-07 2.9E-08 -- n-Butyraldehyde 2.6E-09 -- -- -- 2.6E-09 -- -- --
n-Hexane 0.0027 -- 1.8E-05 -- 0.0027 -- 2.9E-08 --
Nickel (Ni) 3.2E-10 -- 6.0E-06 -- 3.2E-10 -- 1.0E-07 -- PAH Equivalents as Benzo(a)pyrene 1.0E-05 -- 1.9E-08 -- 1.0E-05 -- 3.2E-10 -- Perchloroethylene (tetrachloroethylene) 0.0040 -- -- -- 0.0040 -- -- -- Propene (Propylene) 6.8E-04 1.0E-05 0.0021 -- 6.8E-04 6.6E-06 3.5E-05 -- Propionaldehyde 2.3E-08 -- -- -- 2.3E-08 -- -- --
Selenium -- -- 3.4E-08 -- -- -- 5.7E-10 --
Silver (Ag) 4.7E-08 -- -- -- 4.7E-08 -- -- --
Styrene 1.9E-05 1.8E-05 -- -- 1.9E-05 1.2E-05 -- --
Thallium (Tl) -- -- -- -- -- -- -- --
Toluene 9.4E-04 1.3E-05 1.0E-04 -- 9.4E-04 8.4E-06 1.7E-06 -- Trichloroethylene 8.4E-04 -- -- -- 8.5E-04 -- -- --
Vanadium -- -- 6.5E-06 -- -- -- 1.1E-07 --
Vinyl Acetate 1.3E-05 7.9E-05 -- -- 1.3E-05 5.2E-05 -- -- Vinyl Chloride (chloroethylene) 0.0011 -- -- -- 0.0011 -- -- -- Xylene (Total) 7.5E-04 7.6E-06 7.7E-05 -- 7.5E-04 2.7E-06 1.3E-06 -- Zinc (Zn) 1.2E-08 -- -- -- 1.2E-08 -- -- --
Notes:

1. 2.

Abbreviations:

BAAQMD - Bay Area Air Quality Management District
g - gram
s - second
According to the Project Sponsor, the biogas engines can operate using 100% landfill gas or a blended gas consisting of 55% landfill gas and 45% tailgas. To be conservative, the biogas engine TAC emissions were estimated using the higher emission rate between the two scenarios for each pollutant, and assuming 85% abatement efficiency. Landfill gas emission rates were estimated by BAAQMD using concentrations and speciation from facility data. Tailgas emission rates were estimated using concentrations and speciation from published syngas research data (Hoekman et al. 2013).

Estimated TAC emissions were consistent with previous operational emission analyses for BAAQMD air permit application.

Table 12
Modeled Emission Rates - Project Operational Sources
Raven SR
Richmond, CA
Acute Chronic
Pollutant
1113
Acute1 Chronic1
Landfill Flare Landfill Flare
(g/s) (g/s)
1,1-Dichloroethane (Ethylidene dichloride) 75-34-3 0.0062 0.0062 1,1-Dichloroethene (Vinylidene chloride) 75-35-4 2.7E-04 2.7E-04 1,1,1-Trichloroethane (Methyl chloroform) 71-55-6 1.2E-04 1.2E-04 1,1,2-Trichloroethane (Vinyl trichloride) 79-00-5 3.6E-05 3.6E-05 1,1,2,2-Tetrachloroethane 79-34-5 4.5E-05 4.5E-05
1,3-Butadiene 106-99-0 1.4E-05 1.5E-05
1,4-Dichlorobenzene 106-46-7 6.2E-04 6.2E-04
1,4-Dioxane (1,4-Diethylene dioxide) 123-91-1 2.4E-05 2.4E-05 Acetaldehyde 75-07-0 0.023 0.023
Acrolein 107-02-8 0.0029 0.0029
Acrylonitrile 107-13-1 2.9E-05 2.9E-05
Allyl Chloride (3-Chloropropene) 107-05-1 2.0E-05 2.1E-05 Ammonia 7664-41-7 5.6E-05 1.7
Benzene 71-43-2 0.015 0.015
Benzyl Chloride 100-44-7 2.7E-05 2.7E-05
Carbon Disulfide 75-15-0 2.0E-05 2.0E-05
Carbon Tetrachloride 56-23-5 4.1E-05 4.1E-05
Chlorobenzene 108-90-7 1.5E-04 1.5E-04
Ethyl Chloride (Chloroethane) 75-00-3 3.2E-04 3.2E-04
Chloroform 67-66-3 2.5E-04 2.5E-04
Dioxins PCDDs 1-08-6 1.3E-08 1.3E-08
Ethylbenzene 100-41-4 0.0022 0.0022
Ethylene Dibromide (1,2-dibromoethane) 106-93-4 5.0E-05 5.0E-05 Ethylene Dichloride (1,2-dichloroethane) 107-06-2 0.0011 0.0011 Formaldehyde 50-00-0 0.11 0.11
n-Hexane 110-54-3 0.010 0.010
Hydrochloric Acid (Hydrogen Chloride) 7647-01-0 1.7 0.35 Hydrofluoric Acid (Hydrogen Fluoride) 7664-39-3 0.056 0.011 Hydrogen Sulfide (H2S) 2148-87-8 7.7E-06 7.7E-06
Isopropyl alcohol (IPA, 2-Propanol) 67-63-0 2.5E-04 2.5E-04 Mercury 7439-97-6 1.8E-08 1.8E-08
Methanol (Methyl alcohol) 67-56-1 8.6E-05 8.6E-05
Methyl Bromide (Bromomethane) 74-83-9 2.5E-05 2.5E-05
Methyl Ethyl Ketone (2-butanone) 78-93-3 3.9E-05 3.9E-05 Methyl tert-Butyl Ether 1634-04-4 2.4E-05 2.4E-05
Methylene Chloride (dichloromethane) 75-09-2 0.027 0.027 Naphthalene 91-20-3 0.0019 0.0019
PAH Equivalents as Benzo(a)pyrene 1150/1151 3.7E-05 3.7E-05 Perchloroethylene (tetrachloroethylene) 127-18-4 0.015 0.015 Propene (Propylene) 115-07-1 0.0025 0.0025
Styrene 100-42-5 6.4E-05 6.4E-05
Toluene 108-88-3 0.0034 0.0034
Trichloroethylene 79-01-6 0.0031 0.0031
Vinyl Acetate 108-05-4 4.6E-05 4.6E-05
Vinyl Chloride (chloroethylene) 75-01-4 0.0040 0.0040
Xylene (Total) 1330-20-7 0.0027 0.0027
Notes:

1. Abbreviations:

BAAQMD - Bay Area Air Quality Management District
g - gram
s - second
Existing landfill flare TAC emission reductions were calculated based on BAAQMD estimates for biogas engines TAC emissions and assuming no abatement efficiency. To be conservative, the emission reductions were estimated assuming that biogas engines operate using a blended gas consisting of 55% landfill gas and 45% tailgas.

Pollutant CAS
Table 13
Modeled Emission Rates - Existing Landfill Flare Reductions Raven SR
Richmond, CA
1114
Construction Sources
Source
Dimension Release Height Initial Vertical Dimension
Initial Lateral
Dimension
[m] [m] [m] [m]
Construction Equipment1 Area 1 Approximate
Equipment Area 5.0 1.16 --
Fugitive Dust2 Area 1 Approximate
Equipment Area 0.0 1 --
Operational Sources3
Release Height
[m]
Green Waste Offgas Area 1 4.97
Stack Height Stack Velocity Exit Diameter Stack
Temperature
[m] [m/s] [m] °F
Biogas Engines Point 3 7.92 52.39 0.20 850
Flare Point 1 12.19 0.18 2.24 1,500
Fire Pump Engine Point 1 1.83 13.17 0.20 869
Existing Landfill Sources4
Stack Height Stack Velocity Exit Diameter Stack
Temperature
[m] [m/s] [m] °F
Flare Point 2 12.19 0.15 2.51 1,502
Notes:

1. 2.

3. 4.

Abbreviations:
°F - Fahrenheit
BAAQMD - Bay Area Air Quality Management District m - meter CRRP - Community Risk Reduction Plan s - second
HRA - Health risk assessment USEPA - United States Environmental Protection Agency References:

Construction off-road equipment was modeled as one area source covering the parcel under construction. According to the CRRP-HRA methodology, release height of a modeled area source representing construction equipment was set to 5 meters and the initial vertical dimension is set to the release height divided by 4.3.

Construction fugitive dust will be modeled as one area source covering the parcel under construction. According to the 2012 San Francisco Community HRA methodology, the initial vertical dimension of the modeled fugitive dust area source will be set to 1 meter and the release height will be set to 0 meters consistent with SCAQMD LST methods.

USEPA. 2022. User's Guide for the AMS/EPA Regulatory Model (AERMOD). Office of Air Quality Planning and Standards. Research Triangle Park, North Carolina. EPA-454/B-22-007, June 2022). Available at: https://gaftp.epa.gov/Air/aqmg/SCRAM/models/preferred/aermod/aermod_userguide.pdf South Coast Air Quality Management District (SCAQMD). 2008. Final Localized Significance Threshold Methodology. July. Available at:
http://www.aqmd.gov/docs/default-source/ceqa/handbook/localized-significance-thresholds/final-lst-methodology-document.pdf?sfvrsn=2 The existing landfill flare stack parameters were estimated by POWER Engineers and obtained from the Semi-Annual Monitoring Report 2021 submitted by West Contra Costa Sanitary Landfill to BAAQMD, available at: https://www.baaqmd.gov/~/media/files/engineering/title-vpermits/a1840/a1840_wccc_landfill_053122_2021_a-pdf.pdf?la=en&rev=af45f67469484d85b592e41dd6866b23 Bay Area Air Quality Management District (BAAQMD). 2012. The San Francisco Community Risk Reduction Plan: Technical Support Documentation.

December. Available at: https://www.gsweventcenter.com/Appeal_Response_References/2012_1201_BAAQMD.pdf.

Bay Area Air Quality Management District (BAAQMD). 2020. Health Risk Assessment Modeling Protocol. December. Available online at:
https://www.baaqmd.gov/~/media/files/ab617-community-health/facility-risk-reduction/documents/baaqmd_hra_modeling_protocol-pdf.pdf?la=en San Francisco Department of Public Health (SF DPH), San Francisco Planning Department (SF Planning), and Ramboll. 2020. San Francisco Citywide Health Risk Assessment: Technical Support Documentation. Available online at:
https://www.sfdph.org/dph/files/EHSdocs/AirQuality/Air_Pollutant_Exposure_Zone_Technical_Documentation_2020.pdf For Project operation, the biogas engines, flare, and fire pump engine are modeled as point sources. The green waste storage pile is modeled as an area source. Source parameters were provided by the Project Sponsor.

Table 14
Modeling Parameters
Raven SR
Richmond, CA
Number of
Sources Source Source Type
Source Source Type Number of
Sources
Source Source Type Number of
Sources
Source Source Type Number of
Sources
1115
Construction+Operation
Daily Breathing
Rate (DBR)1
Exposure
Duration (ED)2
Fraction of Time
at Home (FAH)3
Exposure
Frequency
(EF)4
Averaging
Time (AT)
Modeling
Adjustment
Factor5
Intake Factor,
Inhalation (IFinh)
[L/kg-day] [years] [unitless] [days/year] [days] [unitless] [m3/kg-day] 2023 3rd Trimester 361 0.75 1 350 25,550 1.0 0.0037
2023 Age 0-<2 Years 1,090 0.25 1 350 25,550 1.0 0.0037
2024 Age 0-<2 Years 1,090 0.02 1 350 25,550 1.0 0.0003
Age 0-<2 Years 1,090 1.73 1 350 25,550 1.0 0.0259
Age 2-<16 Years 572 14 1 350 25,550 1.0 0.11
Age 16-30 Years 261 14 0.73 350 25,550 1.0 0.037
2023 16-70 years 230 1 -- 250 25,550 4.2 0.0023
2024 16-70 years 230 0.02 -- 250 25,550 4.2 0.0000
Operation All 16-70 years 230 23.98 -- 250 25,550 4.2 0.054 2023 Age 2-<9 Years 640 1 -- 180 25,550 4.2 0.0045
2024 Age 2-<9 Years 640 0.02 -- 180 25,550 4.2 0.0001
Age 2-<9 Years 640 2.98 -- 180 25,550 4.2 0.0134
Age 2-<16 Years 520 4 -- 180 25,550 4.2 0.015
Operation-Only
Daily Breathing
Rate (DBR)1
Exposure
Duration (ED)6
Fraction of Time
at Home (FAH)3
Exposure
Frequency
(EF)4
Averaging
Time (AT)
Modeling
Adjustment
Factor5
Intake Factor,
Inhalation (IFinh)
[L/kg-day] [years] [unitless] [days/year] [days] [unitless] [m3/kg-day] 3rd Trimester 361 0.25 1 350 25,550 1.0 0.0012
Age 0-<2 Years 1,090 2 1 350 25,550 1.0 0.030
Age 2-<16 Years 572 14 1 350 25,550 1.0 0.11
Age 16-30 Years 261 14 0.73 350 25,550 1.0 0.037
Worker Operation All 16-70 years 230 25 -- 250 25,550 4.2 0.056 Age 2-<9 Years 640 4 -- 180 25,550 4.2 0.018
Age 2-<16 Years 520 4 -- 180 25,550 4.2 0.015
Notes:

1. 2.

3. 4.

5. 6.

Calculation:

IFinh = DBR * FAH * EF * ED * CF / AT
CF = 0.001 (m3/L)
Abbreviations:

AT - averaging time IFinh - intake factor
BAAQMD - Bay Area Air Quality Management District kg - kilogram DBR - daily breathing rate L - liter
ED - exposure duration m
3 - cubic meter
EF - exposure frequency OEHHA - Office of Environmental Health Hazard Assessment References:

Exposure Parameters
Year
School
Resident Operation All
Operation All
All
Operation All
BAAQMD. 2016. Air Toxics NSR Program Health Risk Assessment (HRA) Guidelines. January.

Resident
Construction Worker
School
Construction
Operation
Construction
Exposure duration for residents is assumed for 30 years of operation and for workers is assumed for 25 years of operation. Exposure duration for school receptors was assumed to include ages 5-13 for children attending Kindergarten through 8th Grade.

Population Project Phase Receptor Age Group
BAAQMD. 2020. Health Risk Assessment (HRA) Modeling Protocol. December.

OEHHA. 2015. Air Toxics Hot Spots Program Risk Assessment Guidelines. Guidance Manual for Preparation of Health Risk Assessments. February.

Daily breathing rates for residents reflect default breathing rates from OEHHA 2015 and BAAQMD 2016 as follows: 95th percentile 24-hour daily breathing rate for 3rd trimester and age 0-<2 years; 80th percentile for ages 2 years and older (per BAAQMD 2016 and 2020 Health Risk Assessment (HRA) Modeling Guidelines). Daily breathing rates for workers assume 230 L/kg-8 hours, which represents the 95th percentile 8-hour breathing rate based on moderate activity of 16-70 years-old age range, per BAAQMD 2016 and 2020 Health Risk Assessment (HRA) Modeling Guidelines. Daily breathing rates for school receptors reflect 95th percentile 8-hour daily breathing rates for Moderate Intensity Activity for all ages.

Exposure duration for residents is assumed to begin at the start of construction and continue for 30 years of operation. Exposure duration for workers is assumed to begin at the start of construction and continue for 25 years of operation. Exposure duration for school receptors was assumed to include ages 5-13 for children attending Kindergarten through 8th Grade.

Fraction of time spent at home is conservatively assumed to be 1 (i.e., 24 hours/day) for age groups from the third trimester to less than 16 years old based on the recommendation from BAAQMD (BAAQMD 2016 and 2020) and OEHHA (OEHHA 2015).

The fraction of time at home for adults age 16-30 reflects default OEHHA guidance (OEHHA 2015) as recommended by BAAQMD (2016 and 2020).

Exposure frequency reflects default resident, worker, and school receptor exposure frequencies from OEHHA 2015 and BAAQMD 2016.

Modeling adjustment factors are calculated based on the methodology from OEHHA's Guidance Manual for Preparation of Health Risk Assessments (2015). The MAF for the worker and school receptors is calculated to adjust from 24 hours/day to 8 hours/day and from 7 days/week to 5 days/week ([24 hours/8 hours] * [7 days/5 days] = 4.20). Resident types are expected to be exposed 24 hours/day and 7 days/week; as a result, the MAF is 1.

Table 15
Exposure Parameters
Raven SR
Richmond, CA
Population Receptor Age Group
Exposure Parameters
Project Phase Year
1116
Cancer Potency
Factor
Acute Noncancer
Reference Exposure Level
Chronic Noncancer
Reference Exposure Level
(mg/kg-day)-1 (μg/m3) (μg/m3)
1,1,1-Trichloroethane (Methyl chloroform) 71-55-6 -- 68000 1000 1,1,2,2-Tetrachloroethane 79-34-5 0.2 -- --
1,1,2-Trichloroethane (Vinyl trichloride) 79-00-5 0.057 -- -- 1,1-Dichloroethane (Ethylidene dichloride) 75-34-3 0.0057 -- -- 1,1-Dichloroethene (Vinylidene chloride) 75-35-4 -- -- 70 1,3-Butadiene 106-99-0 0.6 660 2
1,4-Dichlorobenzene 106-46-7 0.04 -- 800
1,4-Dioxane (1,4-Diethylene dioxide) 123-91-1 0.027 3000 3000 Acetaldehyde 75-07-0 0.01 470 140
Acetone 67-64-1 -- -- --
Acrolein 107-02-8 -- 2.5 0.35
Acrylonitrile 107-13-1 1 -- 5
Allyl Chloride (3-Chloropropene) 107-05-1 0.021 -- --
Aluminum (Al) 7429-90-5 -- -- --
Ammonia 7664-41-7 -- 3200 200
Arsenic 7440-38-2 12 0.2 0.015
Benzene 71-43-2 0.1 27 3
Benzyl Chloride 100-44-7 0.17 240 --
Beryllium 7440-41-7 8.4 -- 0.007
Bromine (Br) 7726-95-6 -- -- --
Cadmium (Cd) 7440-43-9 15 -- 0.02
Carbon Disulfide 75-15-0 -- 6200 800
Carbon Tetrachloride 56-23-5 0.15 1900 40
Chlorine (Cl) 7782-50-5 -- 210 0.2
Chlorobenzene 108-90-7 -- -- 1000
Chloroform 67-66-3 0.019 150 300
Chromium (Cr) 7440-47-3 -- -- --
Cobalt (Co) 7440-48-4 27 -- --
Copper (Cu) 7440-50-8 -- 100 --
Diesel particulate matter 9-90-1 1.1 -- 5
Dioxins PCDDs 1-08-6 130000 -- 0.00004
Ethene 74-85-1 -- -- --
Ethyl Chloride (Chloroethane) 75-00-3 -- -- 30000
Ethylbenzene 100-41-4 0.0087 -- 2000
Ethylene Dibromide (1,2-dibromoethane) 106-93-4 0.25 -- 0.8 Ethylene Dichloride (1,2-dichloroethane) 107-06-2 0.072 -- 400 Formaldehyde 50-00-0 0.021 55 9
Furan 110-00-9 -- -- --
Hydrochloric Acid (Hydrogen Chloride) 7647-01-0 -- 2100 9 Hydrofluoric Acid (Hydrogen Fluoride) 7664-39-3 -- 240 14 Hydrogen Sulfide (H2S) 7783-06-4 -- 42 10
Isopropyl alcohol (IPA, 2-Propanol) 67-63-0 -- 3200 7000 Lead (Pb) 7439-92-1 0.042 -- --
Manganese (Mn) 7439-96-5 -- -- 0.09
Mercury 7439-97-6 -- 0.6 0.03
Methanol (Methyl alcohol) 67-56-1 -- 28000 4000
Methyl Bromide (Bromomethane) 74-83-9 -- 3900 5
Methyl Ethyl Ketone (2-butanone) 78-93-3 -- 13000 --
Methyl tert-Butyl Ether 1634-04-4 0.0018 -- 8000
Methylene Chloride (dichloromethane) 75-09-2 0.0035 14000 400 Naphthalene 91-20-3 0.12 -- 9
n-Butyraldehyde 123-72-8 -- -- --
n-Hexane 110-54-3 -- -- 7000
Nickel (Ni) 7440-02-0 0.91 0.2 0.014
PAH Equivalents as Benzo(a)pyrene 1-15-0 -- -- --
Perchloroethylene (tetrachloroethylene) 127-18-4 0.021 20000 35 Propene (Propylene) 115-07-1 -- -- 3000
Propionaldehyde 123-38-6 -- -- --
Selenium 7782-49-2 -- -- 20
Silver (Ag) 7440-22-4 -- -- --
Styrene 100-42-5 -- 21000 900
Thallium (Tl) 7440-28-0 -- -- --
Toluene 108-88-3 -- 5000 420
Trichloroethylene 79-01-6 0.007 -- 600
Vanadium 7440-62-2 -- 30 --
Vinyl Acetate 108-05-4 -- -- 200
Vinyl Chloride (chloroethylene) 75-01-4 0.27 180000 --
Xylene (Total) 1330-20-7 -- 22000 700
Zinc (Zn) 7440-66-6 -- -- --
Notes:

1. Abbreviations:
-- - not available or not applicable mg/kg-day - milligrams per kilogram per day ARB - Air Resources Board OEHHA - Office of Environmental Health Hazard Assessment Cal/EPA - California Environmental Protection Agency µg/m3 - micrograms per cubic meter
CAS - chemical abstract services
Reference:

Table 16
Toxicity Values
Raven SR
Richmond, CA
Cal/EPA. 2022. OEHHA/ARB Consolidated Table of Approved Risk Assessment Health Values. September. Available at:
http://www.arb.ca.gov/toxics/healthval/contable.pdf.

Chemical1 CAS Number
Toxicity values are taken from ARB's Consolidated Table of OEHHA/ARB Approved Risk Assessment Health Values. 1117
Excess Lifetime
Cancer Risk (in
a million)1
Non-Cancer
Hazard Index
(unitless)2,3
Acute Hazard
Index
(unitless)4
PM2.5
Concentration
(µg/m3, Annual
Average)3
Excess Lifetime
Cancer Risk (in
a million)1
Non-Cancer
Hazard Index
(unitless)2,3
Acute Hazard
Index
(unitless)4
PM2.5
Concentration
(µg/m3, Annual
Average)3
Project Construction +
Operations 3.0 0.058 0.22 0.57 0.70 0.0086 0.039 0.024
Project Operations 2.2 0.058 0.22 0.57 0.69 0.0086 0.039 0.024 Landfill Reductions -5.7 -0.21 -0.49 -0.84 -1.3 -0.018 -0.10 -0.042 Project Construction +
Operations with Landfill
Reductions5
-2.7 -0.16 -0.27 -0.27 -0.57 -0.009 -0.064 -0.018
Project Operations with
Landfill Reductions -3.5 -0.16 -0.27 -0.27 -0.57 -0.0095 -0.064 -0.018

BAAQMD CEQA
Significance Threshold6 10 1.0 1.0 0.30 10 1.0 1.0 0.30 Excess Lifetime
Cancer Risk (in
a million)1
Non-Cancer
Hazard Index
(unitless)2,3
Acute Hazard
Index
(unitless)4
PM2.5
Concentration
(µg/m3, Annual
Average)3
Excess Lifetime
Cancer Risk (in
a million)1
Non-Cancer
Hazard Index
(unitless)2,3
Acute Hazard
Index
(unitless)4
PM2.5
Concentration
(µg/m3, Annual
Average)3
Project Construction +
Operations 0.49 0.011 0.036 0.030 0.46 0.0058 0.032 0.016 Project Operations 0.52 0.011 0.036 0.030 0.46 0.0058 0.032 0.016 Landfill Reductions -0.81 -0.019 -0.091 -0.044 -0.79 -0.011 -0.077 -0.026 Project Construction +
Operations with Landfill
Reductions5
-0.32 -0.0084 -0.055 -0.014 -0.33 -0.0056 -0.045 -0.010 Project Operations with
Landfill Reductions -0.29 -0.0084 -0.055 -0.014 -0.33 -0.0056 -0.045 -0.010

BAAQMD CEQA
Significance Threshold6 10 1.0 1.0 0.30 10 1.0 1.0 0.30 Notes:

1. 2.

3. 4.

5. 6.

Abbreviations:

ASF - Age Sensitivity Factors PM2.5 - particulate matter 2.5 microns or less CPF - Cancer Potency Factor REL - Reference Exposure Level HI - hazard index TAC - Toxic Air Contaminant
HQ - hazard quotient ug - microgram
m - meter UTM - Universal Transverse Mercator
MEI - maximally exposed individual
References:

Table 17
Project Health Impacts
Raven SR
Richmond, CA
Source
Worker Resident
Source
School Clinic
California Environmental Quality Act (CEQA) 2017 Guidelines. Available at: http://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa_guidelines_may2017-pdf BAAQMD. Regulation 2 Permits Rule 5 New Source Review of Toxic Air Contaminants. Available at: https://www.baaqmd.gov/~/media/dotgov/files/rules/reg-2-permits/2021- amendments/documents/20211215_rg0205-pdf.pdf?la=en&rev=c403a2e96fde4799b1aa950cd4367aa2 Excess lifetime cancer risks are estimated as the upper-bound incremental probability that an individual will develop cancer over a lifetime as a direct result of exposure to potential carcinogens. The estimated risk is expressed as a unitless probability. The cancer risk attributed to the emissions associated with the Project was calculated based on the modeled annual average concentration, the intake factor for a resident child, the Cancer Potency Factors (CPF) for the TACs, and the Age Sensitivity Factors (ASF).

The potential for exposure to result in adverse chronic noncancer effects is evaluated by comparing the estimated annual average air concentration to the noncancer chronic Reference Exposure Level (REL) for each chemical. When calculated for a single chemical, the comparison yields a ratio termed a chronic hazard quotient (HQ). To evaluate the potential for adverse chronic noncancer health effects from simultaneous exposure to multiple chemicals, the chronic hazard quotients for all chemicals are summed, yielding a hazard index (HI).

PM2.5 concentration and Non-Cancer Hazard Index represent annual values.

The acute non-cancer HI analysis assumes that all sources are operating in any one hour time period, which is a conservative assumption.

Thresholds from BAAQMD California Environmental Quality Act (CEQA) 2017 Guidelines.

Project MEIs are identified at the locations with maximum health impacts from the Project construction + operations scenario with landfill reductions. 1118
Lifetime Excess Cancer
Risk1 PM2.5 Concentration1
(in a million) (µg/m3)
Existing Stationary Sources2 45 0.52 1.02
Highway3 1.3 -- 0.026
Major Streets3 0.46 -- 0.014
Roadway Total 1.8 -- 0.040
Railways3 3.7 -- 0.0049
Existing Total 50 0.518 1.07
Project Construction + Operations
with Landfill Reductions -2.7 -0.16 -0.272
Total 47.6 0.36 0.797
Exceeds Threshold? NO NO NO
Existing Stationary Sources2 0.0041 4.7E-05 0.0010
Highway3 1.3 -- 0.026
Major Streets3 5.3 -- 0.17
Roadway Total 6.6 -- 0.19
Railways3 4.3 -- 0.0059
Existing Total 11 4.7E-05 0.20
Project Construction + Operations
with Landfill Reductions -0.57 -0.009 -0.018
Total 10 -0.009 0.18
Exceeds Threshold? NO NO NO
Existing Stationary Sources2 7.1E-05 8.2E-07 1.8E-05
Highway3 2.1 -- 0.042
Major Streets3 1.1 -- 0.032
Roadway Total 3.2 -- 0.074
Railways3 15 -- 0.020
Existing Total 18 8.2E-07 0.094
Project Construction + Operations
with Landfill Reductions -0.32 -0.008 -0.014
Total 18 -0.0084 0.080
Exceeds Threshold? NO NO NO
Existing Stationary Sources2 5.7E-05 6.6E-07 1.4E-05
Highway3 1.4 -- 0.029
Major Streets3 1.4 -- 0.039
Roadway Total 2.8 -- 0.067
Railways3 5.6 -- 0.0077
Existing Total 8.4 6.6E-07 0.075
Project Construction + Operations
with Landfill Reductions -0.33 -0.006 -0.010
Total 8.1 -0.0056 0.065
Exceeds Threshold? NO NO NO
Existing Stationary Sources2 45 0.52 1.02
Highway3 1.3 -- 0.026
Major Streets3 0.46 -- 0.014
Roadway Total 1.8 -- 0.040
Railways3 3.7 -- 0.0049
Existing Total 50 0.518 1.07
Project Operations with Landfill
Reductions -3.5 -0.16 -0.272
Total 46.9 0.36 0.797
Exceeds Threshold? NO NO NO
Existing Stationary Sources2 0.0041 4.7E-05 0.0010
Highway3 1.3 -- 0.026
Major Streets3 5.3 -- 0.17
Roadway Total 6.6 -- 0.19
Railways3 4.3 -- 0.0059
Existing Total 11 4.7E-05 0.20
Project Operations with Landfill
Reductions -0.57 -0.009 -0.018
Total 10 -0.009 0.18
Exceeds Threshold? NO NO NO
Existing Stationary Sources2 7.1E-05 8.2E-07 1.8E-05
Highway3 2.1 -- 0.042
Major Streets3 1.1 -- 0.032
Roadway Total 3.2 -- 0.074
Railways3 15 -- 0.020
Existing Total 18 8.2E-07 0.094
Project Operations with Landfill
Reductions -0.29 -0.008 -0.014
Total 18 -0.0084 0.080
Exceeds Threshold? NO NO NO
Existing Stationary Sources2 5.7E-05 6.6E-07 1.4E-05
Highway3 1.4 -- 0.029
Major Streets3 1.4 -- 0.039
Roadway Total 2.8 -- 0.067
Railways3 5.6 -- 0.0077
Existing Total 8.4 6.6E-07 0.075
Project Operations with Landfill
Reductions -0.33 -0.006 -0.010
Total 8.1 -0.0056 0.065
Exceeds Threshold? NO NO NO
100 10 0.80
Table 18
Cumulative Health Impacts
Raven SR
Richmond, CA
Scenario Receptor Type Source Noncancer Chronic
HI1
Threshold
Construction + Operation
Worker
Resident
School
Clinic
Operation
Worker
Resident
School
Clinic
1119
Table 18
Cumulative Health Impacts
Raven SR
Richmond, CA
Notes:
1 2
3 Abbreviations:

HI - hazard index PM2.5 - particulate matter less than 2.5 microns m
3 - cubic meter µg - microgram
MEIR - maximum exposed individual receptor
References:

For roadways, the chronic HI is not calculated in the BAAQMD screening tool.

The Existing Stationary Sources include the background risks from the West Contra Costa County Landfill, although it is over 1,000 ft away from all MEIRs. The risks at each MEIR are calculated based on on-site risks and a distance multiplier. The distance multipliers for individual MEIRs are calculated using the BAAQMD Distance Multipiler table and exponential extrapolation, as all distances are over 1,000 ft so health risk multipliers are not directly available from BAAQMD.

Cancer risk and PM2.5 concentration values were determined using BAAQMD screening tools and are based on the maximum impact of a raster cell located on the MEIR.

Bay Area Air Quality Management District (BAAQMD). 2020. Permitted Sources Risk and Hazards Map. June. Available at:
https://baaqmd.maps.arcgis.com/apps/webappviewer/index.html?id=2387ae674013413f987b1071715daa65 Bay Area Air Quality Management District (BAAQMD). 2020. Health Risk Calculator Beta 4.0. March. Available at: https://www.baaqmd.gov/~/media/files/planning-andresearch/ceqa/tools/baaqmd-health-risk-calculator-beta-4-0-xlsx.xlsx?la=en&rev=dab7d85a772d45caa9c99e59395bf12d\ 1120

FIGURES
1121
PROJECT: 1690025248 | DATED: 1/20/2023 | DESIGNER: ANSHI Service Layer Credits: World Imagery: Maxar, Microsoft
0 500 1,000
Feet
RAMBOLL US CONSULTING, INC.

A RAMBOLL COMPANY
FIGURE 01 Project Boundary
Onsite Buildings
Leachate Tanks
Green Waste Storage Pile
Fire Pump Engine Housing
Biogas Engine
Fire Pump Engine
Flare
Existing Landfill Flare
!(
Ná
Raven SR
1 Parr Blvd.

Richmond, CA

MODELED SOURCES AND BUILDINGS
1122
PROJECT: 1690025248 | DATED: 3/7/2023 | DESIGNER: ANSHI Service Layer Credits: World Imagery: Maxar
0 2,000 4,000
Feet
RAMBOLL US CONSULTING, INC.

A RAMBOLL COMPANY
FIGURE 02
Raven SR
1 Parr Blvd.

Richmond, CA
Maximally Exposed Residential Receptor
Maximally Exposed Worker Receptor (PM2.5)
Maximally Exposed Worker Receptor (Chronic HI)
Maximally Exposed Worker Receptor (Cancer & Acute HI)
Maximally Exposed School Receptor
Maximally Exposed Clinic Receptor
Project Boundary
Resident
Worker
School
Clinic

MODELED RECEPTORS AND MAXIMALLY

EXPOSED INDIVIDUAL RECEPTOR LOCATIONS
!(
Ná
1123
Raven SR Bioenergy Project B-1 ESA / D202100382
Updated Initial Study MND March 9, 2023

APPENDIX B
Special Status Species Lists
1124
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This page is intentionally blank.
1125
June 14, 2022
United States Department of the Interior

FISH AND WILDLIFE SERVICE
Sacramento Fish And Wildlife Office
Federal Building
2800 Cottage Way, Room W-2605
Sacramento, CA 95825-1846
Phone: (916) 414-6600 Fax: (916) 414-6713
In Reply Refer To:

Project Code: 2022-0054185
Project Name: Raven SR Bioenergy Project
Subject: List of threatened and endangered species that may occur in your proposed project location or may be affected by your proposed project
To Whom It May Concern:

The enclosed species list identifies threatened, endangered, proposed and candidate species, as well as proposed and final designated critical habitat, that may occur within the boundary of your proposed project and/or may be affected by your proposed project. The species list fulfills the requirements of the U.S. Fish and Wildlife Service (Service) under section 7(c) of the Endangered Species Act (Act) of 1973, as amended (16 U.S.C. 1531 et seq.).

New information based on updated surveys, changes in the abundance and distribution of species, changed habitat conditions, or other factors could change this list. Please feel free to contact us if you need more current information or assistance regarding the potential impacts to federally proposed, listed, and candidate species and federally designated and proposed critical habitat. Please note that under 50 CFR 402.12(e) of the regulations implementing section 7 of the Act, the accuracy of this species list should be verified after 90 days. This verification can be completed formally or informally as desired. The Service recommends that verification be completed by visiting the ECOS-IPaC website at regular intervals during project planning and implementation for updates to species lists and information. An updated list may be requested through the ECOS-IPaC system by completing the same process used to receive the enclosed list.

The purpose of the Act is to provide a means whereby threatened and endangered species and the ecosystems upon which they depend may be conserved. Under sections 7(a)(1) and 7(a)(2) of the Act and its implementing regulations (50 CFR 402 et seq.), Federal agencies are required to utilize their authorities to carry out programs for the conservation of threatened and endangered species and to determine whether projects may affect threatened and endangered species and/or designated critical habitat.

A Biological Assessment is required for construction projects (or other undertakings having similar physical impacts) that are major Federal actions significantly affecting the quality of the human environment as defined in the National Environmental Policy Act (42 U.S.C. 4332(2) 1126
06/14/2022   2
(c)). For projects other than major construction activities, the Service suggests that a biological evaluation similar to a Biological Assessment be prepared to determine whether the project may affect listed or proposed species and/or designated or proposed critical habitat. Recommended contents of a Biological Assessment are described at 50 CFR 402.12.

If a Federal agency determines, based on the Biological Assessment or biological evaluation, that listed species and/or designated critical habitat may be affected by the proposed project, the agency is required to consult with the Service pursuant to 50 CFR 402. In addition, the Service recommends that candidate species, proposed species and proposed critical habitat be addressed within the consultation. More information on the regulations and procedures for section 7 consultation, including the role of permit or license applicants, can be found in the "Endangered Species Consultation Handbook" at:
http://www.fws.gov/endangered/esa-library/pdf/TOC-GLOS.PDF Migratory Birds: In addition to responsibilities to protect threatened and endangered species under the Endangered Species Act (ESA), there are additional responsibilities under the Migratory Bird Treaty Act (MBTA) and the Bald and Golden Eagle Protection Act (BGEPA) to protect native birds from project-related impacts. Any activity, intentional or unintentional, resulting in take of migratory birds, including eagles, is prohibited unless otherwise permitted by the U.S. Fish and Wildlife Service (50 C.F.R. Sec. 10.12 and 16 U.S.C. Sec. 668(a)). For more information regarding these Acts see https://www.fws.gov/birds/policies-and-regulations.php.

The MBTA has no provision for allowing take of migratory birds that may be unintentionally killed or injured by otherwise lawful activities. It is the responsibility of the project proponent to comply with these Acts by identifying potential impacts to migratory birds and eagles within applicable NEPA documents (when there is a federal nexus) or a Bird/Eagle Conservation Plan (when there is no federal nexus). Proponents should implement conservation measures to avoid or minimize the production of project-related stressors or minimize the exposure of birds and their resources to the project-related stressors. For more information on avian stressors and recommended conservation measures see https://www.fws.gov/birds/bird-enthusiasts/threats-tobirds.php.

In addition to MBTA and BGEPA, Executive Order 13186: Responsibilities of Federal Agencies to Protect Migratory Birds, obligates all Federal agencies that engage in or authorize activities that might affect migratory birds, to minimize those effects and encourage conservation measures that will improve bird populations. Executive Order 13186 provides for the protection of both migratory birds and migratory bird habitat. For information regarding the implementation of Executive Order 13186, please visit https://www.fws.gov/birds/policies-and-regulations/ executive-orders/e0-13186.php.

We appreciate your concern for threatened and endangered species. The Service encourages Federal agencies to include conservation of threatened and endangered species into their project planning to further the purposes of the Act. Please include the Consultation Code in the header of this letter with any request for consultation or correspondence about your project that you submit to our office.
1127
06/14/2022   3
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Attachment(s):