Attachment 1 - Exhibit B - Updated ISMND.pdf — Richmond City Council, May 16, 2023 (part 2 of 3)

RAVEN - Contra Costa County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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
Date: 8/11/2022 11:05 AM

Page 2 of 28 ends

RAVEN - Contra Costa County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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
Date: 8/11/2022 11:05 AM

Page 3 of 28 ends

RAVEN - Contra Costa County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

2.0500e-
003

4.8300e-
003

0.0433

0.0481

9.8000e-
004

0.0411

0.0420

0.0000
176.5135
176.5135

0.0420

8.4000e-
004
177.8124
2023

0.0572

0.4813

0.5134

9.4000e-
004

1.3300e-
003

0.0217

0.0230

3.7000e-
004

0.0208

0.0212

0.0000

80.1650

0.0148

3.8000e-
004

80.6476
Maximum

0.1109

1.0010

0.9211

2.0500e-
003

4.8300e-
003

0.0433

0.0481

9.8000e-
004

0.0411

0.0420

0.0000
176.5135
176.5135

0.0420

8.4000e-
004
177.8124
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

2.0500e-
003

3.6600e-
003

0.0433

0.0469

8.5000e-
004

0.0411

0.0419

0.0000
176.5133
176.5133

0.0420

8.4000e-
004
177.8122
2023

0.0572

0.4813

0.5134

9.4000e-
004

1.3300e-
003

0.0217

0.0230

3.7000e-
004

0.0208

0.0212

0.0000

80.1649

0.0148

3.8000e-
004

80.6476
Maximum

0.1109

1.0010

0.9211

2.0500e-
003

3.6600e-
003

0.0433

0.0469

8.5000e-
004

0.0411

0.0419

0.0000
176.5133
176.5133

0.0420

8.4000e-
004
177.8122
Mitigated Construction
CalEEMod Version: CalEEMod.2020.4.0
Date: 8/11/2022 11:05 AM

Page 4 of 28 ends

RAVEN - Contra Costa County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

18.99 0.00

1.64 9.63

0.00 0.21

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

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

3.7000e-
004

0.0000

7.1000e-
004

0.0000

7.6000e-
004
Energy

5.3000e-
003

0.0482

0.0405

2.9000e-
004

3.6600e-
003

0.0000

79.9440

5.4500e-
003

1.5000e-
003

80.5276
Mobile

0.0133

0.0161

0.1306

2.8000e-
004

0.0289

2.1000e-
004

0.0292

7.7300e-
003

1.9000e-
004

7.9200e-
003

0.0000

25.5208

1.5700e-
003

1.1800e-
003

25.9122
Offroad

0.1481

1.4534

0.8266

3.4300e-
003

0.0487

0.0448

0.0000
300.7720
300.7720

0.0973

0.0000
303.2039
Waste

0.0000

10.0684

0.0000

10.0684

0.5950

0.0000

24.9439
Water

0.0000

2.9346

4.6310

7.5656

0.3022

7.2100e-
003

17.2675
Total

0.3438

1.5177

0.9981

4.0000e-
003

0.0289

0.0525

0.0815

7.7300e-
003

0.0486

0.0564

13.0030
410.8685
423.8714

1.0015

9.8900e-
003
451.8558
Unmitigated Operational
CalEEMod Version: CalEEMod.2020.4.0
Date: 8/11/2022 11:05 AM

Page 5 of 28 ends

RAVEN - Contra Costa County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

3.7000e-
004

0.0000

7.1000e-
004

0.0000

7.6000e-
004
Energy

5.3000e-
003

0.0482

0.0405

2.9000e-
004

3.6600e-
003

0.0000

79.9440

5.4500e-
003

1.5000e-
003

80.5276
Mobile

0.0133

0.0161

0.1306

2.8000e-
004

0.0289

2.1000e-
004

0.0292

7.7300e-
003

1.9000e-
004

7.9200e-
003

0.0000

25.5208

1.5700e-
003

1.1800e-
003

25.9122
Offroad

0.1481

1.4534

0.8266

3.4300e-
003

0.0487

0.0448

0.0000
300.7720
300.7720

0.0973

0.0000
303.2039
Waste

0.0000

10.0684

0.0000

10.0684

0.5950

0.0000

24.9439
Water

0.0000

2.9346

4.6310

7.5656

0.3022

7.2100e-
003

17.2675
Total

0.3438

1.5177

0.9981

4.0000e-
003

0.0289

0.0525

0.0815

7.7300e-
003

0.0486

0.0564

13.0030
410.8685
423.8714

1.0015

9.8900e-
003
451.8558
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
CalEEMod Version: CalEEMod.2020.4.0
Date: 8/11/2022 11:05 AM

Page 6 of 28 ends

RAVEN - Contra Costa County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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
Date: 8/11/2022 11:05 AM

Page 7 of 28 ends

RAVEN - Contra Costa County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

2.7900e-
003

0.0193

0.0205

5.0000e-
005

9.1000e-
004

8.9000e-
004

0.0000

4.3996

4.1000e-
004

0.0000

4.4099
Total

2.7900e-
003

0.0193

0.0205

5.0000e-
005

9.1000e-
004

8.9000e-
004

0.0000

4.3996

4.1000e-
004

0.0000

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
Date: 8/11/2022 11:05 AM

Page 8 of 28 ends

RAVEN - Contra Costa County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

5.0000e-
005

1.7100e-
003

3.6000e-
004

1.0000e-
005

1.7000e-
004

2.0000e-
005

1.9000e-
004

5.0000e-
005

1.0000e-
005

6.0000e-
005

0.0000

0.6262

2.0000e-
005

1.0000e-
004

0.6563
Vendor

0.0000

0.0000
Worker

1.0000e-
005

1.2000e-
004

0.0000

4.0000e-
005

0.0000

4.0000e-
005

1.0000e-
005

0.0000

1.0000e-
005

0.0000

0.0319

0.0000

0.0322
Total

6.0000e-
005

1.7200e-
003

4.8000e-
004

1.0000e-
005

2.1000e-
004

2.0000e-
005

2.3000e-
004

6.0000e-
005

1.0000e-
005

7.0000e-
005

0.0000

0.6581

2.0000e-
005

1.0000e-
004

0.6884
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

2.7900e-
003

0.0193

0.0205

5.0000e-
005

9.1000e-
004

8.9000e-
004

0.0000

4.3996

4.1000e-
004

0.0000

4.4099
Total

2.7900e-
003

0.0193

0.0205

5.0000e-
005

9.1000e-
004

8.9000e-
004

0.0000

4.3996

4.1000e-
004

0.0000

4.4099
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 8/11/2022 11:05 AM

Page 9 of 28 ends

RAVEN - Contra Costa County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

5.0000e-
005

1.7100e-
003

3.6000e-
004

1.0000e-
005

1.7000e-
004

2.0000e-
005

1.9000e-
004

5.0000e-
005

1.0000e-
005

6.0000e-
005

0.0000

0.6262

2.0000e-
005

1.0000e-
004

0.6563
Vendor

0.0000

0.0000
Worker

1.0000e-
005

1.2000e-
004

0.0000

4.0000e-
005

0.0000

4.0000e-
005

1.0000e-
005

0.0000

1.0000e-
005

0.0000

0.0319

0.0000

0.0322
Total

6.0000e-
005

1.7200e-
003

4.8000e-
004

1.0000e-
005

2.1000e-
004

2.0000e-
005

2.3000e-
004

6.0000e-
005

1.0000e-
005

7.0000e-
005

0.0000

0.6581

2.0000e-
005

1.0000e-
004

0.6884
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
Off-Road

0.0177

0.1696

0.1377

5.0000e-
004

5.6500e-
003

5.2400e-
003

0.0000

43.0480

0.0135

0.0000

43.3865
Total

0.0177

0.1696

0.1377

5.0000e-
004

0.0000

5.6500e-
003

0.0000

5.2400e-
003

0.0000

43.0480

0.0135

0.0000

43.3865
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 8/11/2022 11:05 AM

Page 10 of 28 ends

RAVEN - Contra Costa County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

7.0000e-
005

2.7400e-
003

5.8000e-
004

1.0000e-
005

2.7000e-
004

2.0000e-
005

3.0000e-
004

7.0000e-
005

2.0000e-
005

1.0000e-
004

0.0000

1.0019

3.0000e-
005

1.6000e-
004

1.0501
Vendor

0.0000

0.0000
Worker

8.0000e-
005

6.0000e-
005

7.3000e-
004

0.0000

2.4000e-
004

0.0000

2.4000e-
004

6.0000e-
005

0.0000

6.0000e-
005

0.0000

0.1911

1.0000e-
005

0.1929
Total

1.5000e-
004

2.8000e-
003

1.3100e-
003

1.0000e-
005

5.1000e-
004

2.0000e-
005

5.4000e-
004

1.3000e-
004

2.0000e-
005

1.6000e-
004

0.0000

1.1930

4.0000e-
005

1.7000e-
004

1.2430
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
Off-Road

0.0177

0.1696

0.1377

5.0000e-
004

5.6500e-
003

5.2400e-
003

0.0000

43.0480

0.0135

0.0000

43.3864
Total

0.0177

0.1696

0.1377

5.0000e-
004

0.0000

5.6500e-
003

0.0000

5.2400e-
003

0.0000

43.0480

0.0135

0.0000

43.3864
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 8/11/2022 11:05 AM

Page 11 of 28 ends

RAVEN - Contra Costa County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

7.0000e-
005

2.7400e-
003

5.8000e-
004

1.0000e-
005

2.7000e-
004

2.0000e-
005

3.0000e-
004

7.0000e-
005

2.0000e-
005

1.0000e-
004

0.0000

1.0019

3.0000e-
005

1.6000e-
004

1.0501
Vendor

0.0000

0.0000
Worker

8.0000e-
005

6.0000e-
005

7.3000e-
004

0.0000

2.4000e-
004

0.0000

2.4000e-
004

6.0000e-
005

0.0000

6.0000e-
005

0.0000

0.1911

1.0000e-
005

0.1929
Total

1.5000e-
004

2.8000e-
003

1.3100e-
003

1.0000e-
005

5.1000e-
004

2.0000e-
005

5.4000e-
004

1.3000e-
004

2.0000e-
005

1.6000e-
004

0.0000

1.1930

4.0000e-
005

1.7000e-
004

1.2430
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

2.1200e-
003

0.0000

2.1200e-
003

2.3000e-
004

0.0000

2.3000e-
004

0.0000

0.0000
Off-Road

0.0166

0.1854

0.1437

3.5000e-
004

7.5100e-
003

6.9100e-
003

0.0000

30.8182

9.9700e-
003

0.0000

31.0674
Total

0.0166

0.1854

0.1437

3.5000e-
004

2.1200e-
003

7.5100e-
003

9.6300e-
003

2.3000e-
004

6.9100e-
003

7.1400e-
003

0.0000

30.8182

9.9700e-
003

0.0000

31.0674
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 8/11/2022 11:05 AM

Page 12 of 28 ends

RAVEN - Contra Costa County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

5.0000e-
005

1.7100e-
003

3.6000e-
004

1.0000e-
005

1.7000e-
004

2.0000e-
005

1.9000e-
004

5.0000e-
005

1.0000e-
005

6.0000e-
005

0.0000

0.6262

2.0000e-
005

1.0000e-
004

0.6563
Vendor

0.0000

0.0000
Worker

8.0000e-
005

6.0000e-
005

7.3000e-
004

0.0000

2.4000e-
004

0.0000

2.4000e-
004

6.0000e-
005

0.0000

6.0000e-
005

0.0000

0.1911

1.0000e-
005

0.1929
Total

1.3000e-
004

1.7700e-
003

1.0900e-
003

1.0000e-
005

4.1000e-
004

2.0000e-
005

4.3000e-
004

1.1000e-
004

1.0000e-
005

1.2000e-
004

0.0000

0.8173

3.0000e-
005

1.1000e-
004

0.8492
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

9.5000e-
004

0.0000

9.5000e-
004

1.0000e-
004

0.0000

1.0000e-
004

0.0000

0.0000
Off-Road

0.0166

0.1854

0.1437

3.5000e-
004

7.5100e-
003

6.9100e-
003

0.0000

30.8182

9.9700e-
003

0.0000

31.0674
Total

0.0166

0.1854

0.1437

3.5000e-
004

9.5000e-
004

7.5100e-
003

8.4600e-
003

1.0000e-
004

6.9100e-
003

7.0100e-
003

0.0000

30.8182

9.9700e-
003

0.0000

31.0674
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 8/11/2022 11:05 AM

Page 13 of 28 ends

RAVEN - Contra Costa County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

5.0000e-
005

1.7100e-
003

3.6000e-
004

1.0000e-
005

1.7000e-
004

2.0000e-
005

1.9000e-
004

5.0000e-
005

1.0000e-
005

6.0000e-
005

0.0000

0.6262

2.0000e-
005

1.0000e-
004

0.6563
Vendor

0.0000

0.0000
Worker

8.0000e-
005

6.0000e-
005

7.3000e-
004

0.0000

2.4000e-
004

0.0000

2.4000e-
004

6.0000e-
005

0.0000

6.0000e-
005

0.0000

0.1911

1.0000e-
005

0.1929
Total

1.3000e-
004

1.7700e-
003

1.0900e-
003

1.0000e-
005

4.1000e-
004

2.0000e-
005

4.3000e-
004

1.1000e-
004

1.0000e-
005

1.2000e-
004

0.0000

0.8173

3.0000e-
005

1.1000e-
004

0.8492
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

1.0900e-
003

0.0291

0.0279

0.0000

91.9681

0.0179

0.0000

92.4146
Total

0.0729

0.6117

0.6119

1.0900e-
003

0.0291

0.0279

0.0000

91.9681

0.0179

0.0000

92.4146
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 8/11/2022 11:05 AM

Page 14 of 28 ends

RAVEN - Contra Costa County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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
Vendor

3.5000e-
004

8.5500e-
003

2.5900e-
003

3.0000e-
005

9.9000e-
004

9.0000e-
005

1.0800e-
003

2.9000e-
004

9.0000e-
005

3.8000e-
004

0.0000

3.1336

7.0000e-
005

4.6000e-
004

3.2713
Worker

2.1000e-
004

1.5000e-
004

1.8200e-
003

1.0000e-
005

5.9000e-
004

0.0000

6.0000e-
004

1.6000e-
004

0.0000

1.6000e-
004

0.0000

0.4777

2.0000e-
005

1.0000e-
005

0.4823
Total

5.6000e-
004

8.7000e-
003

4.4100e-
003

4.0000e-
005

1.5800e-
003

9.0000e-
005

1.6800e-
003

4.5000e-
004

9.0000e-
005

5.4000e-
004

0.0000

3.6113

9.0000e-
005

4.7000e-
004

3.7535
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

1.0900e-
003

0.0291

0.0279

0.0000

91.9680

0.0179

0.0000

92.4145
Total

0.0729

0.6117

0.6119

1.0900e-
003

0.0291

0.0279

0.0000

91.9680

0.0179

0.0000

92.4145
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 8/11/2022 11:05 AM

Page 15 of 28 ends

RAVEN - Contra Costa County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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
Vendor

3.5000e-
004

8.5500e-
003

2.5900e-
003

3.0000e-
005

9.9000e-
004

9.0000e-
005

1.0800e-
003

2.9000e-
004

9.0000e-
005

3.8000e-
004

0.0000

3.1336

7.0000e-
005

4.6000e-
004

3.2713
Worker

2.1000e-
004

1.5000e-
004

1.8200e-
003

1.0000e-
005

5.9000e-
004

0.0000

6.0000e-
004

1.6000e-
004

0.0000

1.6000e-
004

0.0000

0.4777

2.0000e-
005

1.0000e-
005

0.4823
Total

5.6000e-
004

8.7000e-
003

4.4100e-
003

4.0000e-
005

1.5800e-
003

9.0000e-
005

1.6800e-
003

4.5000e-
004

9.0000e-
005

5.4000e-
004

0.0000

3.6113

9.0000e-
005

4.7000e-
004

3.7535
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

9.1000e-
004

0.0217

0.0208

0.0000

77.2516

0.0148

0.0000

77.6205
Total

0.0569

0.4756

0.5101

9.1000e-
004

0.0217

0.0208

0.0000

77.2516

0.0148

0.0000

77.6205
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 8/11/2022 11:05 AM

Page 16 of 28 ends

RAVEN - Contra Costa County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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
Vendor

1.4000e-
004

5.6200e-
003

1.8400e-
003

3.0000e-
005

8.3000e-
004

3.0000e-
005

8.6000e-
004

2.4000e-
004

3.0000e-
005

2.7000e-
004

0.0000

2.5248

5.0000e-
005

3.7000e-
004

2.6349
Worker

1.6000e-
004

1.1000e-
004

1.4100e-
003

0.0000

5.0000e-
004

0.0000

5.0000e-
004

1.3000e-
004

0.0000

1.4000e-
004

0.0000

0.3886

1.0000e-
005

0.3922
Total

3.0000e-
004

5.7300e-
003

3.2500e-
003

3.0000e-
005

1.3300e-
003

3.0000e-
005

1.3600e-
003

3.7000e-
004

3.0000e-
005

4.1000e-
004

0.0000

2.9134

6.0000e-
005

3.8000e-
004

3.0271
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

9.1000e-
004

0.0217

0.0208

0.0000

77.2515

0.0148

0.0000

77.6204
Total

0.0569

0.4756

0.5101

9.1000e-
004

0.0217

0.0208

0.0000

77.2515

0.0148

0.0000

77.6204
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 8/11/2022 11:05 AM

Page 17 of 28 ends

RAVEN - Contra Costa County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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
Vendor

1.4000e-
004

5.6200e-
003

1.8400e-
003

3.0000e-
005

8.3000e-
004

3.0000e-
005

8.6000e-
004

2.4000e-
004

3.0000e-
005

2.7000e-
004

0.0000

2.5248

5.0000e-
005

3.7000e-
004

2.6349
Worker

1.6000e-
004

1.1000e-
004

1.4100e-
003

0.0000

5.0000e-
004

0.0000

5.0000e-
004

1.3000e-
004

0.0000

1.4000e-
004

0.0000

0.3886

1.0000e-
005

0.3922
Total

3.0000e-
004

5.7300e-
003

3.2500e-
003

3.0000e-
005

1.3300e-
003

3.0000e-
005

1.3600e-
003

3.7000e-
004

3.0000e-
005

4.1000e-
004

0.0000

2.9134

6.0000e-
005

3.8000e-
004

3.0271
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 8/11/2022 11:05 AM

Page 18 of 28 ends

RAVEN - Contra Costa County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

2.8000e-
004

0.0289

2.1000e-
004

0.0292

7.7300e-
003

1.9000e-
004

7.9200e-
003

0.0000

25.5208

1.5700e-
003

1.1800e-
003

25.9122
Unmitigated

0.0133

0.0161

0.1306

2.8000e-
004

0.0289

2.1000e-
004

0.0292

7.7300e-
003

1.9000e-
004

7.9200e-
003

0.0000

25.5208

1.5700e-
003

1.1800e-
003

25.9122

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
Date: 8/11/2022 11:05 AM

Page 19 of 28 ends

RAVEN - Contra Costa County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

27.4981

4.4500e-
003

5.4000e-
004

27.7700
Electricity
Unmitigated

0.0000

27.4981

4.4500e-
003

5.4000e-
004

27.7700
NaturalGas
Mitigated

5.3000e-
003

0.0482

0.0405

2.9000e-
004

3.6600e-
003

0.0000

52.4460

1.0100e-
003

9.6000e-
004

52.7576
NaturalGas
Unmitigated

5.3000e-
003

0.0482

0.0405

2.9000e-
004

3.6600e-
003

0.0000

52.4460

1.0100e-
003

9.6000e-
004

52.7576

5.1 Mitigation Measures Energy
Historical Energy Use: N
CalEEMod Version: CalEEMod.2020.4.0
Date: 8/11/2022 11:05 AM

Page 20 of 28 ends

RAVEN - Contra Costa County, Annual
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

5.3000e-
003

0.0482

0.0405

2.9000e-
004

3.6600e-
003

0.0000

52.4460

1.0100e-
003

9.6000e-
004

52.7576
Total

5.3000e-
003

0.0482

0.0405

2.9000e-
004

3.6600e-
003

0.0000

52.4460

1.0100e-
003

9.6000e-
004

52.7576
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

5.3000e-
003

0.0482

0.0405

2.9000e-
004

3.6600e-
003

0.0000

52.4460

1.0100e-
003

9.6000e-
004

52.7576
Total

5.3000e-
003

0.0482

0.0405

2.9000e-
004

3.6600e-
003

0.0000

52.4460

1.0100e-
003

9.6000e-
004

52.7576
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

4.4500e-
003

5.4000e-
004

27.7700
Total

27.4981

4.4500e-
003

5.4000e-
004

27.7700
Unmitigated
Electricity
Use
Total CO2
CH4
N2O
CO2e
Land Use
kWh/yr
MT/yr
General Light
Industry
297200

27.4981

4.4500e-
003

5.4000e-
004

27.7700
Total

27.4981

4.4500e-
003

5.4000e-
004

27.7700
Mitigated
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EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

3.7000e-
004

0.0000

7.1000e-
004

0.0000

7.6000e-
004
Unmitigated

0.1771

0.0000

3.7000e-
004

0.0000

7.1000e-
004

0.0000

7.6000e-
004

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
Consumer
Products

0.1562

0.0000

0.0000
Landscaping

3.0000e-
005

0.0000

3.7000e-
004

0.0000

7.1000e-
004

0.0000

7.6000e-
004
Total

0.1771

0.0000

3.7000e-
004

0.0000

7.1000e-
004

0.0000

7.6000e-
004
Unmitigated
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7.1 Mitigation Measures Water

7.0 Water Detail

0.0209

0.0000

0.0000
Consumer
Products

0.1562

0.0000

0.0000
Landscaping

3.0000e-
005

0.0000

3.7000e-
004

0.0000

7.1000e-
004

0.0000

7.6000e-
004
Total

0.1771

0.0000

3.7000e-
004

0.0000

7.1000e-
004

0.0000

7.6000e-
004
Mitigated
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EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

Total CO2
CH4
N2O
CO2e
Category
MT/yr
Mitigated

7.5656

0.3022

7.2100e-
003

17.2675
Unmitigated

7.5656

0.3022

7.2100e-
003

17.2675

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

7.2100e-
003

17.2675
Total

7.5656

0.3022

7.2100e-
003

17.2675
Unmitigated
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EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

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

7.2100e-
003

17.2675
Total

7.5656

0.3022

7.2100e-
003

17.2675
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

3.4300e-
003

0.0487

0.0448

0.0000
300.7720
300.7720

0.0973

0.0000
303.2039
Total

0.1481

1.4534

0.8266

3.4300e-
003

0.0487

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

Blank

This page is intentionally blank.

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 th is 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 Prote ction 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 l andfill 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 CO 2e). Carbon dioxide equivalents are emissions of carbon dioxide (CO 2), methane (CH 4), and nitrous oxide (N 2O), 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,

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.

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.

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-and-
research/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.

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/

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

6 TABLES

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 WearEBW,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 On-
Road 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-emissions- inventory/msei-modeling-tools
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.

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 DistrictPM - 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
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.

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 DistrictNOx - 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 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
Average Trip Rate Average Trip Length Annual ActivityAnnual 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
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-source- emissions-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.

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)
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 N 2O - 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/chapter- I/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/chapter- I/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
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:

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
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 N 2O - 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/chapter- I/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/chapter- I/subchapter-C/part-98/subpart-C
Table 12
Fire Pump Engine GHG Emissions
Raven SR
Richmond, CA
Diesel Usage
Pollutant Fire Pump Engine Emissions
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:

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/subpart- A/appendix-Table%20A-1%20to%20Subpart%20A%20of%20Part%2098 Summary of Default Construction Emissions by Source
Default
Construction GHG
Emissions2
ROG NOx PM10 (Exhaust) PM2.5 (Exhaust) CO 2e
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) CO 2e
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 PM 2.5 - 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/subpart- A/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/msei- modeling-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
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-source- emissions-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
Emissions Summary1
GHG Emissions
(55% landfill gas)
GHG Emissions
(100% landfill gas)
CO2e CO 2e
(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/our- work/programs/mobile-source-emissions-inventory/msei-modeling-tools Table 16
Operational GHG Emission Summary
Raven SR
Richmond, CA
Emissions Source
F
IGURES
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PROJECT: 1690025248 | DATED: 1/20/2023 | DESIGNER: ANSHI Service Layer Credits: World Imagery: Maxar, Microsoft
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RAMBOLL US CONSULTING, INC.

A RAMBOLL COMPANY
FIGURE 01Project Boundary
Onsite Buildings
Leachate Tanks
Green Waste Storage Pile
Fire Pump Engine Housing
Biogas Engine
Fire Pump Engine
Flare
Existing Landfill Flare
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Raven SR
1 Parr Blvd.

Richmond, CA

MODELED SOURCES AND BUILDINGS

Raven SR Bioenergy Project

A.2
-
2 ESA

/
D202100382

Updated Initial Study MND

March 9
, 2023

A.2
-
2 Updated Air Quality and New H
ealth Risk
Assessment Technical Memo

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This page is intentionally blank.

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 methodolog ies 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 (U SEPA).

The steps conducted in performing this health ris k 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.

References 2 Ramboll

4. Calculate resulting cancer risk , non-cancer chronic hazard index (HI), acute hazard index (HI), and fine particulate matter (PM 2.5) 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.

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 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.

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 PM

2.5 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.

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 PM

2.5 impacts
in the HRA for the Project were based on the expected TAC emissions from the modeled sources.

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 off- road 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.

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.

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 PM

2.5 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 A ssumptions: 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
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:

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) 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).

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.

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.

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-and- regs/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-and-
research/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-risk- reduction/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-act- ceqa/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/appendix- Table%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 References 14 Ramboll
US Census Bureau. American Community Survey. 2020: ACS 5-Year Estimates Data Profiles.

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

16 TABLES

Construction Subphase1 Start Date End Date Year Number of Work DaysDays 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
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:

EI: vehicle idling emissions (lb).

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-emissions- inventory/msei-modeling-tools
Table 3
Emission Calculation Methodology
Raven SR
Richmond, CA
Construction and
Operational On-
Road Mobile
Sources2
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
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.

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).

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
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
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
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 TripsTotal 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
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-may- 2012.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-and- research/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en
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
ChronicAcute
Pollutant
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
Construction Sources
Source
Dimension Release HeightInitial 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 DiameterStack
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 DiameterStack
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-v- permits/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
SourcesSource TypeSource
Source Source Type Number of
Sources
Source Source Type Number of
Sources
Source Source Type Number of
Sources
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 m3 - cubic meter
EF - exposure frequency OEHHA - Office of Environmental Health Hazard Assessment References:

Exposure Parameters
Year
School
Resident Operation All
AllOperation
All
Operation All
BAAQMD. 2016. Air Toxics NSR Program Health Risk Assessment (HRA) Guidelines. January.

Resident
ConstructionWorker
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
Cancer Potency
Factor
Acute Noncancer
Reference Exposure Level
Chronic Noncancer
Reference Exposure Level
(mg/kg-day)-1 (μg/m3) (μg/m 3)
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 Agencyµg/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.

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.

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
Table 18
Cumulative Health Impacts
Raven SR
Richmond, CA
Notes:
1 2
3 Abbreviations:

HI - hazard index PM 2.5 - particulate matter less than 2.5 microns m3 - 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-and- research/ceqa/tools/baaqmd-health-risk-calculator-beta-4-0-xlsx.xlsx?la=en&rev=dab7d85a772d45caa9c99e59395bf12d\ F
IGURES
LAST SAVE: 1/18/2023 4:10 PM
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0 1,000500
Feet
RAMBOLL US CONSULTING, INC.

Richmond, CA

MODELED SOURCES AND BUILDINGS
LAST SAVE: 3/7/2023 10:55 AM
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PROJECT: 1690025248 | DATED: 3/7/2023 | DESIGNER: ANSHI Service Layer Credits: World Imagery: Maxar
0 4,0002,000
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
! á(N

Raven SR Bioenergy Project

B
-
1 ESA

D202100382

Updated Initial Study MND

March 9
, 2023

APPENDIX B

Special Status Species Lists
Blank

This page is intentionally blank.

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) 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-to- birds.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.
06/14/2022 3

▪
Attachment(s):

Official Species List
06/14/2022 1

Official Species List
This list is provided pursuant to Section 7 of the Endangered Species Act, and fulfills the requirement for Federal agencies to "request of the Secretary of the Interior information whether any species which is listed or proposed to be listed may be present in the area of a proposed action".

This species list is provided by:

Sacramento Fish And Wildlife Office
Federal Building
2800 Cottage Way, Room W-2605
Sacramento, CA 95825-1846
(916) 414-6600
06/14/2022 2

Project Summary
Project Code: 2022-0054185
Event Code: None
Project Name: Raven SR Bioenergy Project
Project Type: Commercial Development
Project Description: The proposed 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. The non-combustible process would convert blended green waste and food waste obtained from the existing BMPC operation adjacent to the project site into renewable, transportation grade hydrogen that would be exported offsite for various renewable energy products. No hydrogen storage would occur onsite. The project would involve the erection of a modular structure and industrial canopy and would not add vehicle trips or other substantial traffic to the property.

Project Location:

Approximate location of the project can be viewed in Google Maps: https:// www.google.com/maps/@37.967288499999995,-122.38296104113344,14z Counties: Contra Costa County, California
06/14/2022 3

1. Endangered Species Act Species
There is a total of 14 threatened, endangered, or candidate species on this species list.

Species on this list should be considered in an effects analysis for your project and could include species that exist in another geographic area. For example, certain fish may appear on the species list because a project could affect downstream species.

IPaC does not display listed species or critical habitats under the sole jurisdiction of NOAA Fisheries , as USFWS does not have the authority to speak on behalf of NOAA and the Department of Commerce.

See the "Critical habitats" section below for those critical habitats that lie wholly or partially within your project area under this office's jurisdiction. Please contact the designated FWS office if you have questions.

NOAA Fisheries, also known as the National Marine Fisheries Service (NMFS), is an office of the National Oceanic and Atmospheric Administration within the Department of Commerce.

Mammals

NAME STATUS
Salt Marsh Harvest Mouse Reithrodontomys raviventris
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/613
Endangered
Birds

NAME STATUS
California Clapper Rail Rallus longirostris obsoletus
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/4240
Endangered
California Least Tern Sterna antillarum browni
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/8104
Endangered
Western Snowy Plover Charadrius nivosus nivosus
Population: Pacific Coast population DPS-U.S.A. (CA, OR, WA), Mexico (within 50 miles of Pacific coast)
There is final critical habitat for this species. The location of the critical habitat is not available.

Species profile: https://ecos.fws.gov/ecp/species/8035
Threatened
1 06/14/2022 4

Reptiles

NAME STATUS
Green Sea Turtle Chelonia mydas
Population: East Pacific DPS
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/6199
Threatened
Amphibians

NAME STATUS
California Red-legged Frog Rana draytonii
There is final critical habitat for this species. The location of the critical habitat is not available.

Species profile: https://ecos.fws.gov/ecp/species/2891
Threatened
Fishes

NAME STATUS
Delta Smelt Hypomesus transpacificus
There is final critical habitat for this species. The location of the critical habitat is not available.

Species profile: https://ecos.fws.gov/ecp/species/321
Threatened
Tidewater Goby Eucyclogobius newberryi
There is final critical habitat for this species. The location of the critical habitat is not available.

Species profile: https://ecos.fws.gov/ecp/species/57
Endangered
06/14/2022 5

Flowering Plants

NAME STATUS
Marin Dwarf-flax Hesperolinon congestum
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/5363
Threatened
Showy Indian Clover Trifolium amoenum
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/6459
Endangered
Tiburon Jewelflower Streptanthus niger
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/4187
Endangered
Tiburon Mariposa Lily Calochortus tiburonensis
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/2858
Threatened
Tiburon Paintbrush Castilleja affinis ssp. neglecta
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/2687
Endangered
White-rayed Pentachaeta Pentachaeta bellidiflora
No critical habitat has been designated for this species.

Species profile: https://ecos.fws.gov/ecp/species/7782
Endangered
Critical habitats

THERE ARE NO CRITICAL HABITATS WITHIN YOUR PROJECT AREA UNDER THIS OFFICE'S JURISDICTION.
06/14/2022 6

IPaC User Contact Information
Agency: Environmental Science Associates
Name: Sharon Dulava
Address: 787 The Alameda
Address Line 2: Suite 250
City: San Jose
State: CA
Zip: 95126
Email [email protected]
Phone: 9252859473
Species
Element Code
Federal Status
State Status
Global Rank
State Rank
Rare Plant
Rank/CDFW
SSC or FP
Accipiter cooperii
Cooper's hawk
ABNKC12040
None
None
G5
S4
WL
Acipenser medirostris pop. 1
green sturgeon - southern DPS
AFCAA01031
Threatened
None
G2T1
S1
Antrozous pallidus
pallid bat
AMACC10010
None
None
G4
S3
SSC
Ardea alba
great egret
ABNGA04040
None
None
G5
S4
Asio flammeus
short-eared owl
ABNSB13040
None
None
G5
S3
SSC
Astragalus tener var. tener
alkali milk-vetch
PDFAB0F8R1
None
None
G2T1
S1
1B.2
Athene cunicularia
burrowing owl
ABNSB10010
None
None
G4
S3
SSC
Bombus caliginosus
obscure bumble bee
IIHYM24380
None
None
G2G3
S1S2
Bombus occidentalis
western bumble bee
IIHYM24250
None
None
G2G3
S1
Calystegia purpurata ssp. saxicola
coastal bluff morning-glory
PDCON040D2
None
None
G4T2T3
S2S3
1B.2
Chloropyron maritimum ssp. palustre
Point Reyes salty bird's-beak
PDSCR0J0C3
None
None
G4?T2
S2
1B.2
Chloropyron molle ssp. molle
soft salty bird's-beak
PDSCR0J0D2
Endangered
Rare
G2T1
S1
1B.2
Circus hudsonius
northern harrier
ABNKC11011
None
None
G5
S3
SSC
Danaus plexippus pop. 1
monarch - California overwintering population
IILEPP2012
Candidate
None
G4T2T3
S2S3
Dirca occidentalis
western leatherwood
PDTHY03010
None
None
G2
S2
1B.2
Egretta thula
snowy egret
ABNGA06030
None
None
G5
S4
Elanus leucurus
white-tailed kite
ABNKC06010
None
None
G5
S3S4
FP
Emys marmorata
western pond turtle
ARAAD02030
None
None
G3G4
S3
SSC
Fritillaria liliacea
fragrant fritillary
PMLIL0V0C0
None
None
G2
S2
1B.2
Helminthoglypta nickliniana bridgesi
Bridges' coast range shoulderband
IMGASC2362
None
None
G3T1
S1S2
BIOS selection
Raven SR Bioenergy Project Initial Study: 5 Mile Study Area Query Criteria:

Report Printed on Tuesday, June 14, 2022

Page 1 of 3 ends

Commercial Version -- Dated June, 3 2022 -- Biogeographic Data Branch Information Expires 12/3/2022
Selected Elements by Scientific Name
California Department of Fish and
Wildlife
California Natural Diversity Database

Species
Element Code
Federal Status
State Status
Global Rank
State Rank
Rare Plant
Rank/CDFW
SSC or FP
Hoita strobilina
Loma Prieta hoita
PDFAB5Z030
None
None
G2?
S2?
1B.1
Holocarpha macradenia
Santa Cruz tarplant
PDAST4X020
Threatened
Endangered
G1
S1
1B.1
Hydroprogne caspia
Caspian tern
ABNNM08020
None
None
G5
S4
Lasiurus cinereus
hoary bat
AMACC05030
None
None
G3G4
S4
Laterallus jamaicensis coturniculus
California black rail
ABNME03041
None
Threatened
G3T1
S1
FP
Melospiza melodia pusillula
Alameda song sparrow
ABPBXA301S
None
None
G5T2T3
S2S3
SSC
Melospiza melodia samuelis
San Pablo song sparrow
ABPBXA301W
None
None
G5T2
S2
SSC
Microtus californicus sanpabloensis
San Pablo vole
AMAFF11034
None
None
G5T1T2
S1S2
SSC
Nannopterum auritum
double-crested cormorant
ABNFD01020
None
None
G5
S4
WL
Northern Coastal Salt Marsh
Northern Coastal Salt Marsh
CTT52110CA
None
None
G3
S3.2
Nycticorax nycticorax
black-crowned night heron
ABNGA11010
None
None
G5
S4
Pandion haliaetus
osprey
ABNKC01010
None
None
G5
S4
WL
Rallus obsoletus obsoletus
California Ridgway's rail
ABNME05011
Endangered
Endangered
G3T1
S1
FP
Rana draytonii
California red-legged frog
AAABH01022
Threatened
None
G2G3
S2S3
SSC
Reithrodontomys raviventris
salt-marsh harvest mouse
AMAFF02040
Endangered
Endangered
G1G2
S1S2
FP
Sorex vagrans halicoetes
salt-marsh wandering shrew
AMABA01071
None
None
G5T1
S1
SSC
Spergularia macrotheca var. longistyla
long-styled sand-spurrey
PDCAR0W062
None
None
G5T2
S2
1B.2
Spirinchus thaleichthys
longfin smelt
AFCHB03010
Candidate
Threatened
G5
S1
Symphyotrichum lentum
Suisun Marsh aster
PDASTE8470
None
None
G2
S2
1B.2
Thaleichthys pacificus
eulachon
AFCHB04010
Threatened
None
G5
S2
Trifolium hydrophilum
saline clover
PDFAB400R5
None
None
G2
S2
1B.2
Report Printed on Tuesday, June 14, 2022

Page 2 of 3 ends

Species
Element Code
Federal Status
State Status
Global Rank
State Rank
Rare Plant
Rank/CDFW
SSC or FP
Tryonia imitator
mimic tryonia (=California brackishwater snail)
IMGASJ7040
None
None
G2
S2
Valley Needlegrass Grassland
Valley Needlegrass Grassland
CTT42110CA
None
None
G3
S3.1
Xanthocephalus xanthocephalus
yellow-headed blackbird
ABPBXB3010
None
None
G5
S3
SSC
Record Count: 44
Report Printed on Tuesday, June 14, 2022

Page 3 of 3 ends

Blank

This page is intentionally blank.

6/14/22, 3:26 PM CNPS Rare Plant Inventory | Search Results https://rareplants.cnps.org/Search/result?frm=T&sl=1&quad=3712284:3712283:3812214:3812213: 1/5 Search Results
CNPS Rare Plant Inventory
45 matches found. Click on scientific name for details
Search Criteria: Quad is one of [3712284:3712283:3812214:3812213] ▲ SCIENTIFIC

NAME COMMON NAME FAMILY LIFEFORM

BLOOMING
PERIOD
FED
LIST
STATE
LIST
GLOBAL
RANK
STATE
RANK
CA
RARE
PLANT

RANK PHOTO
Amorpha
californica var.
napensis
Napa false
indigo
Fabaceae perennial
deciduous
shrub
Apr-Jul None None G4T2 S2 1B.2
© 2016 John
Doyen
Amsinckia lunaris bent-flowered
fiddleneck
Boraginaceae annual herb Mar-Jun None None G3 S3 1B.2
© 2011 Neal
Kramer
Arabis
blepharophylla
coast
rockcress
Brassicaceae perennial herb Feb-May None None G4 S4 4.3 © 2011 Neal
Kramer
Arctostaphylos
pallida
pallid
manzanita
Ericaceae perennial
evergreen shrub
Dec-Mar FT CE G1 S1 1B.1
No Photo
Available
Aspidotis carlotta-
halliae
Carlotta Hall's
lace fern
Pteridaceae perennial
rhizomatous
herb
Jan-Dec None None G3 S3 4.2
No Photo
Available
Astragalus tener
var. tener
alkali milk-
vetch
Fabaceae annual herb Mar-Jun None None G2T1 S1 1B.2
No Photo
Available
Calamagrostis
ophitidis
serpentine reed
grass
Poaceae perennial herb Apr-Jul None None G3 S3 4.3
No Photo
Available
Calochortus
tiburonensis
Tiburon
mariposa-lily
Liliaceae perennial
bulbiferous herb
Mar-Jun FT CT G1 S1 1B.1
No Photo
Available
Calochortus
umbellatus
Oakland star-
tulip
Liliaceae perennial
bulbiferous herb
Mar-May None None G3? S3? 4.2
No Photo
Available
Calystegia
purpurata ssp.
saxicola
coastal bluff
morning-glory
Convolvulaceae perennial herb (Mar)Apr-
Sep
None None G4T2T3 S2S3 1B.2
No Photo
Available
Castilleja affinis
var. neglecta
Tiburon
paintbrush
Orobanchaceae perennial herb
(hemiparasitic)
Apr-Jun FE CT G4G5T1T2 S1S2 1B.2
No Photo
A il bl
6/14/22, 3:26 PM CNPS Rare Plant Inventory | Search Results https://rareplants.cnps.org/Search/result?frm=T&sl=1&quad=3712284:3712283:3812214:3812213: 2/5 Available
Castilleja ambigua
var. ambigua
johnny-nip Orobanchaceae annual herb
(hemiparasitic)
Mar-Aug None None G4T4 S3S4 4.2
©2011 Dylan
Neubauer
Chloropyron
maritimum ssp.
palustre
Point Reyes
salty bird's-
beak
Orobanchaceae annual herb
(hemiparasitic)
Jun-Oct None None G4?T2 S2 1B.2
©2017 John
Doyen
Chloropyron molle
ssp. molle
soft salty
bird's-beak
Orobanchaceae annual herb
(hemiparasitic)
Jun-Nov FE CR G2T1 S1 1B.2
No Photo
Available
Collomia
diversifolia
serpentine
collomia
Polemoniaceae annual herb May-Jun None None G4 S4 4.3
©2019 Zoya
Akulova
Dirca occidentalis western
leatherwood
Thymelaeaceae perennial
deciduous
shrub
Jan-
Mar(Apr)
None None G2 S2 1B.2
© 2017
Steve
Matson
Eleocharis parvula small
spikerush
Cyperaceae perennial herb (Apr)Jun-
Aug(Sep)
None None G5 S3 4.3
©2018 Ron
Vanderhoff
Eriogonum
luteolum var.
caninum
Tiburon
buckwheat
Polygonaceae annual herb May-Sep None None G5T2 S2 1B.2 No Photo
Available
Erythranthe
laciniata
cut-leaved
monkeyflower
Phrymaceae annual herb Apr-Jul None None G4 S4 4.3
© 2017
Steven Perry
Erythranthe
nudata
bare
monkeyflower
Phrymaceae annual herb May-Jun None None G4 S4 4.3
John Doyen
2015
Fritillaria liliacea fragrant
fritillary
Liliaceae perennial
bulbiferous herb
Feb-Apr None None G2 S2 1B.2
© 2004
Carol W.

Witham
Helianthella
castanea
Diablo
helianthella
Asteraceae perennial herb Mar-Jun None None G2 S2 1B.2

6/14/22, 3:26 PM CNPS Rare Plant Inventory | Search Results https://rareplants.cnps.org/Search/result?frm=T&sl=1&quad=3712284:3712283:3812214:3812213: 3/5 © 2013
Christopher
Bronny
Hesperolinon
congestum
Marin western
flax
Linaceae annual herb Apr-Jul FT CT G1 S1 1B.1
© 2009 Neal
Kramer
Hoita strobilina Loma Prieta
hoita
Fabaceae perennial herb May-
Jul(Aug-
Oct)
None None G2? S2? 1B.1
© 2004
Janell
Hillman
Holocarpha
macradenia
Santa Cruz
tarplant
Asteraceae annual herb Jun-Oct FT CE G1 S1 1B.1
© 2011
Dylan
Neubauer
Iris longipetala coast iris Iridaceae perennial
rhizomatous
herb
Mar-
May(Jun)
None None G3 S3 4.2
© 2014
Aaron
Schusteff
Isocoma arguta Carquinez
goldenbush
Asteraceae perennial shrub Aug-Dec None None G1 S1 1B.1 No Photo
Available
Lathyrus jepsonii
var. jepsonii
Delta tule pea Fabaceae perennial herb May-
Jul(Aug-
Sep)
None None G5T2 S2 1B.2
© 2003 Mark
Fogiel
Leptosiphon
acicularis
bristly
leptosiphon
Polemoniaceae annual herb Apr-Jul None None G4? S4? 4.2 © 2007 Len
Blumin
Leptosiphon
grandiflorus
large-flowered
leptosiphon
Polemoniaceae annual herb Apr-Aug None None G3G4 S3S4 4.2 © 2003
Doreen L.

Smith
Lessingia
hololeuca
woolly-headed
lessingia
Asteraceae annual herb Jun-Oct None None G2G3 S2S3 3
© 2015
Aaron
Schusteff
Lilaeopsis
masonii
Mason's
lilaeopsis
Apiaceae perennial
rhizomatous
Apr-Nov None CR G2 S2 1B.1
No Photo
6/14/22, 3:26 PM CNPS Rare Plant Inventory | Search Results https://rareplants.cnps.org/Search/result?frm=T&sl=1&quad=3712284:3712283:3812214:3812213: 4/5 herb Available
Pentachaeta
bellidiflora
white-rayed
pentachaeta
Asteraceae annual herb Mar-May FE CE G1 S1 1B.1
No Photo
Available
Piperia michaelii Michael's rein
orchid
Orchidaceae perennial herb Apr-Aug None None G3 S3 4.2
No Photo
Available
Plagiobothrys
glaber
hairless
popcornflower
Boraginaceae annual herb Mar-May None None GX SX 1A
No Photo
Available
Polygonum
marinense
Marin
knotweed
Polygonaceae annual herb (Apr)May-
Aug(Oct)
None None G2Q S2 3.1
No Photo
Available
Ranunculus lobbii Lobb's aquatic
buttercup
Ranunculaceae annual herb
(aquatic)
Feb-May None None G4 S3 4.2
No Photo
Available
Senecio
aphanactis
chaparral
ragwort
Asteraceae annual herb Jan-
Apr(May)
None None G3 S2 2B.2
No Photo
Available
Spergularia
macrotheca var.
longistyla
long-styled
sand-spurrey
Caryophyllaceae perennial herb Feb-May None None G5T2 S2 1B.2 No Photo
Available
Streptanthus
glandulosus ssp.
niger
Tiburon
jewelflower
Brassicaceae annual herb May-Jun FE CE G4T1 S1 1B.1
No Photo
Available
Suaeda
californica
California
seablite
Chenopodiaceae perennial
evergreen shrub
Jul-Oct FE None G1 S1 1B.1
No Photo
Available
Symphyotrichum
lentum
Suisun Marsh
aster
Asteraceae perennial
rhizomatous
herb
(Apr)May-
Nov
None None G2 S2 1B.2
No Photo
Available
Trifolium
amoenum
two-fork clover Fabaceae annual herb Apr-Jun FE None G1 S1 1B.1 No Photo
Available
Trifolium
hydrophilum
saline clover Fabaceae annual herb Apr-Jun None None G2 S2 1B.2 No Photo
Available
Triquetrella
californica
coastal
triquetrella
Pottiaceae moss None None G2 S2 1B.2
No Photo
Available
Showing 1 to 45 of 45 entries
Suggested Citation:

California Native Plant Society, Rare Plant Program. 2022. Rare Plant Inventory (online edition, v9-01 1.5). Website https://www.rareplants.cnps.org [accessed 14 June 2022].

CONTACT US ABOUT THIS WEBSITE ABOUT CNPS CONTRIBUTORS
6/14/22, 3:26 PM CNPS Rare Plant Inventory | Search Results https://rareplants.cnps.org/Search/result?frm=T&sl=1&quad=3712284:3712283:3812214:3812213: 5/5 Send questions and comments
to [email protected].

About the Inventory
Release Notes
Advanced Search
Glossary
About the Rare Plant Program
CNPS Home Page
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Database
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Copyright © 2010-2022 California Native Plant Society. All rights reserved.

Raven SR Bioenergy Project

C
-
1 ESA

/
D202100382

Updated Initial Study MND

March 9
, 2023

APPENDIX
C

Updated
Draft Mitigation Monitoring and
Reporting Program (MMRP)
Blank

This page is intentionally blank.

Raven SR Bioenergy Project

C
-
1 ESA

/ D202100382

Updated Initial Study MND

March 9, 2023

APPENDIX C
-

SECOND
FINAL

UPDATED

MITIGATION MONITORIN

G AND REPORTING PROG
RAM

Project Mitigation Measures

Implement
ed
By

Monitored By

Monitoring and Reporting
Action

Monitoring
Schedule

4.1 Aesthetics
–

None Required

4.2 Agriculture and Forestry Resources
–

None Required

4.3 Air Quality

(
Expanded)

Mitigation Measure AQ
-
1: Best Management
Practices.
1 

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 r
oads) 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 p
ossible. 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 t
uned in accordance with manufacturer’s
specifications. All equipment shall be checked by a
Project Applicant /
Construction
Contractor

Richmond
Building Division
and Engineering
Services
Department

Richmond
Engineering Services
Department to verify inclusion of
BAAQMD BMPs in applicable
construction plans and specifications.

City of Richmond Building Division to
inspect site during const
ruc
tion to
ensure compliance with P
roject
construction plans.

Prior to issuance of
building

permit.

Field inspections
during construction.

Verified by:

Date:

1 The additional
bulleted
items
(sin
gle underlined)
to Mitigation Measure AQ
-
1 were added as expanded mitigation at the Planning
Commission
.

APPENDIX C
-

Second
Final

Updated
M
itigation
Monitoring and Reporting Program

Raven SR Bioenergy Project

C
-
2 ESA

/ D202100382

Updated Initial Study MND

March 9, 2023

Project Mitigation Measures

Implement
ed
By

Monitored By

Monitoring and Reporting
Action

Monitoring
Schedule

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, an
d/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 o
r further from a paved road shall be treated with
a 6
-

to 12
-
inch layer of compacted layer of wood chips,
mulch, or gravel.



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 g
rass 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 o
ne 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 le
ast 10 calendar
days.

APPENDIX C
-

Second
Final

Updated
Mitigation Monitoring and Reporting Program

Raven SR Bioenergy Project

C
-
3 ESA

/ D202100382

Updated Initial Study MND

March 9, 2023

Project Mitigation Measures

Implement
ed
By

Monitored By

Monitoring and Reporting
Action

Monitoring
Schedule



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
bounda
ry or if dust is contained within the property
boundary but not controlled after a specified number of minutes.



4.4 Biological Resources

Mitigation Measure BIO
-
1: Avoid and Minimize Impacts to
Nesting
Birds, Except Rails.

To the extent practicable,

P
p
roject 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
.

Project Applicant
/ Construction
Contractor

Qualified Biologist

Richmond
Building Division
and
Planning
Division

City of Richmond Building Division to
ensure construction activities are
performed between February 1st and
August 31st.

Prior to
any site
a
lterations or
issuance of building
permit.

Field inspections
during construction.

Verified by:

Date:

I
f 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 perf ormed 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 stagin
g 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 beg
ins within 14 calendar days.

If active nests are located during the pre
-
construction bird nesting
surveys, no
-
disturbance buffer zones shall be established around
nests, with a buffer size established by the qualified biologist.

Typically, these buffer dis
tances are between 50 feet and 250

Qualified Biologist

Richmond
Building Division

City of Richmond Building Division to
confirm
surveys are conducted
pursuant to specified measures, and if
warranted, that buffer zone distances
are indicated in project plans and
adhered to during construction
activities.

City of Richmond Planning Divis
ion to
receive and confirm survey report.

Field inspections
during construction.

Upon completion of
surveys.

Verified by:

Date:

APPENDIX C
-

Second
Final

Updated
M
itigation
Monitoring and Reporting Program

Raven SR Bioenergy Project

C
-
4 ESA

/ D202100382

Updated Initial Study MND

March 9, 2023

Project Mitigation Measures

Implement
ed
By

Monitored By

Monitoring and Reporting
Action

Monitoring
Schedule

monitor the nest and has authority to halt construction if bird behavior indicates continued activities could lead to nest failu re. 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 e
qual 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.

Project Applicant
/ Construction
Contractor

Qualified Biologist

Richmond
Building Division
and
Planning
Division

City of Richmond Building Division to
ensure construction activities are
performed between February 1st and
August 31st.

Field inspections
during construction.

Verified by:

Date:



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 i
ndirectly disturbed by construction activities
during the breeding season to ensure that rails are not breeding within 500 feet of project activities.



Survey methods for rail
s

will follow
the
Site
-
Specific Protocol
for Monitoring Marsh Birds
, which was de
veloped 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 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 c
onsistency 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 Project Applicant
/ Construction
Contractor

Qualified Biologist

Richmond
Building Division

City of Richmond Building Division to
confirm
surveys are conducted
pursuant to
specified measures.

City of Richmond Planning Division to
receive and confirm survey report.

Field inspections
during construction.

Upon completion of
surveys.

Verified by:

Date:

APPENDIX C
-

Second
Final

Updated
Mitigation Monitoring and Reporting Program

Raven SR Bioenergy Project

C
-
5 ESA

/ D202100382

Updated Initial Study MND

March 9, 2023

Project Mitigation Measures

Implement
ed
By

Monitored By

Monitoring and Reporting
Action

Monitoring
Schedule

minimize disturbances to marsh vegetation. Up to 8
points can be locat
ed 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. Surv
eys 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 surv
eys.



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 vocalization
s, 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. I
f impact cannot
be avoided during the rail nesting season, activities
would be delayed until after the nesting season.

Project Applicant
/ Construction
Contractor

Qualified Biologist

Richmond
Building Division

City of Richmond Building Division to
ensure

construction activities are
performed between February 1st and
August 31st
, based on agency
coordination

per this measure
.

City of Richmond Planning Division to
verify agency coordination and
outcome.

Field inspections
during construction.

Upon completi
on of
surveys.

Verified by:

Date:

APPENDIX C
-

Second
Final

Updated
M
itigation
Monitoring and Reporting Program

Raven SR Bioenergy Project

C
-
6 ESA

/ D202100382

Updated Initial Study MND

March 9, 2023

Project Mitigation Measures

Implement
ed
By

Monitored By

Monitoring and Reporting
Action

Monitoring
Schedule

4.5 Cultural Resources

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 gene
ral
archaeological sensitivity of the vicinity and the procedures to follow in the event an archaeological resource and/or human remains are inadvertently discovered.

Project Applicant /
Construction
Contractor

Qualified
Archaeologist

Richmond
Building D
ivision

City of Richmond
Building Division

to
review and confirm documentation of
training, required personnel attending,
and scope of training.

Prior to
commencement of
any ground
-
disturbing
activities.

Verified by:

Date:

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 contracto
r 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 tool
s (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 bat
tered 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 re
source (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, cappin
g 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
Project Applicant /
Construction
Contractor

Qualified
Archaeologist

If applicable,
Native American
representative

Richmond
Building Division to review
and approve of archaeologist, of
cultural resources monitoring plan and
of the construction plan that includes
archaeologic
al mitigation.

If resources are encountered,
Contractor to verify work is suspended
as required, review and approve
qualified archaeologist and
recommendations.

If resources encountered are found to
be qualifying as described in the
measure, the City to en
sure
preservation measures are
implemented or that the ARDTP is
completed and submitted to NWIC.

City to inspect site during construction
to ensure compliance with project
construction plans.

Prior to issuance of
building permit for, or
commencement of,
any ground
-
disturbing
activities.

Field inspections
during construction.

Verified by:

Date:

APPENDIX C
-

Second
Final

Updated
Mitigation Monitoring and Reporting Program

Raven SR Bioenergy Project

C
-
7 ESA

/ D202100382

Updated Initial Study MND

March 9, 2023

Project Mitigation Measures

Implement
ed
By

Monitored By

Monitoring and Reporting
Action

Monitoring
Schedule

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).

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 Amer
ican, 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
recomme
ndations for the appropriate means of treating the human remains and any grave goods.

Project Applicant /
Construction
Contractor

Qualified
Archaeologist

Richmond Building Division verify
mitigation measure on construction
plans.

Inspect site during
construction to
ensure compliance with project
construction plans.

If needed, engage County Coroner
and ensure NAHC contact.

Prior to issuance of a
building permit for, or
commencement of,
any ground
-
disturbing
activities.

Field inspections
during
construction
.

Verified by:

Date:

4.6 Energy
–

None Required

4.7 Geology, Soils, and Mineral Resources
-

MM CUL
-
1a, CUL
-
1b, CUL
-
2 (see 4.5, Cultural Resources)

4.8 Greenhouse Gas Emissions
–

None Required

4.9 Hazards and Hazardous Materials
–

None
Required

4.10 Hydrology and Water Quality
–

None Required

4.11 Land Use and Planning
–

None Required

4.12 Noise / Vibration
–

None Required

4.13 Population and Housing
–

None Required

4.14 Public Services and Recreation
–

None Required

4.15 Transportation
–

None Required

4.16 Tribal Cultural Resources
-

MM CUL
-
1a, CUL
-
1b, CUL
-
2 (see 4.5, Cultural Resources)

4.17 Utilities and Service Systems
–

None Required

4.18 Wildfire
–

None Required

APPENDIX C
-

Second
Final

Updated
M
itigation
Monitoring and Reporting Program

Raven SR Bioenergy Project

C
-
8 ESA

/ D202100382

Updated Initial Study MND

March 9, 2023

Raven SR Bioenergy Project

D
-
1 ESA

/
D202100382

Updated
Initial Study

MND

March
9 , 2023

APPENDIX
D

Response to Comments Received on the Raven
SR Bioenergy Project Initial Study / Mitigated
N
egative Declaration (November, 11, 2022)

Blank

This page is intentionally blank.

180 Grand Avenue

Suite 1050

Oakland, CA 94612

510.839.5066
phone

510.839.5825
fax

esassoc.com

M
emorandum

date

November 30, 2022

Lydia

Elias
, Planner I

Lina Velasco
, Director

from

Crescentia Brown
, Project Director

Tim Sturtz
, Project Manager

subject

RESPONSE TO
COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

Background

On October 7, 2022, the City of Richmond (Lead Agency) released for public review a

Draft
Initial Study
(IS)
and Mitigated Negative Declarati
on (MND)
pursuant to the California Environmental Quality Act (CEQA) for
the proposed
Raven SR Bioenergy Project
(Project)

(SCH#

2022
01045
). The
original
public review and comment
period on the
IS/
MND

was
October
7 , 20
22 through November 7, 2022, and the C
ity extended the comment
period to November 22, 2022.

Although not required by CEQA, this document includes the comments received on the IS/MND

(see
Table 1
)

and responses to each comment.

TABLE 1

COMMENT LETTERS RECE

IVED ON THE IS/MND

Letter #

Entity

Author(s) of Comment Letter/e
-
mail

Comment Date

Agencies

–

Public / Quasi
-
Public

1 Contra Costa Environmental
Health

Nicole Soto
, REHS

November 22, 2022

2 Berkeley Lab

Vi H. Rapp, PhD
, Deputy for Building and Industrial
Applications Department

November
21, 2022

3 CalRecycle

Harprit Mattu, Environmental Scientist

November 7, 2022

4 Department of Toxic
Substances Control

Rebecca De Pont, Supervising Environmental
Planner

November 4, 2022

5 California State Senate

Nancy Skinner, State Senator District
9 October 21, 2022

6 MCE

Dawn Weisz, CEO

October 20, 2022

7 Bay Area Air Quality
Management District

Kelly Malinowski, MPA | Senior Environmental
Planner

October 19, 2022

8 Republic Services

Ken Lewis, P.E., General Manager

October 13, 2022

continued

RESPONSE TO COMMENTS Received on
the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

2 TABLE 1 (CONTINUED)

COMMENT LETTERS RECE

IVED ON THE IS/MND

Letter #

Entity

Author(s) of Comment Letter/e
-
mail

Comment Date

Organizations

/ Individual

9 Environmental Justice Groups

November 22, 2022



Communities for a
Better Environment

Connie Cho, Attorney / Tessa Wardle, Staff
Researcher



Sierra Club

Teresa Cheng, Senior Campaign Representative



Asian Pacific
Environmental Network

Faraz Rizvi, Campaign and Policy Manager



Richmond Our Power
Coalition

Katt Ramos, Managing
Director
-

Richmond Our
Power Coalition



Urban Tilth

Kiara Pereira, Just Transition Organizer / Rafael
Castro, Just Transition Organizer



Natural Resources
Defense Council

Ann Alexander, Senior Attorney

10 Shell Hydrogen

Humberto Orantes
, Acting
Commercial Head, North
America

November 7, 2022

11 Powers Engineers

James P. Hays
, Business Unit Director

November 7, 2022

12 Trails for Richmond Action
Committee (TRAC)

Bruce Beyaert
, TRAC Chair

October 27, 2022

13 Benicia Fabrication & Machine

Carmelo

Santiago
, CEO & President

October 20, 2022

14 Contra Costa Construction and
Building Trades Council

William Whitney

October 17, 2022

15 Watlow

Ashish Bhatnagar
, Chief Technology Officer

October 14, 2022

16 Iron Workers Local 378

Jason Gallia
, Business
Manager, Financial
Manager/Treasurer

October 13, 2022

17 Local Union
No
. 302
International Brotherhood of
Electrical Workers

Tom Hansen
, Business Manager, Financial
Secretary

October 13, 2022

18 Green Hydrogen Coalition

Nicholas Connell
, Policy Director

October 10, 2022

19 Not Identified

Christina Strawbridge

October 10, 2022

No “substantial revisions” that would require recirculation of the IS/MND are warranted. Specifically, (1)

no
new, avoidable significant effect is identified and mitigation measures or project revisions must be added in order to reduce the effect to insignificance, or
(2)

The lead agency determines that the proposed mitigation measures or project revisions wil
l not reduce potential effects to less than significance and new measures or revisions must be required (CEQA
Guidelines

Section

15073.5).

Although
a
m
itigation measure
(
AQ
-
1: Best Management
Practices
) is expanded

with equal or more effective measures pur
suant to Section 15074.1, recirculation of the
MND is not required.

The updated
Mitigation

Measure Monit
oring and Reporting Pro
gram (MMRP
) with the
expanded
miti
gation measure

is included as
Attachment A

to
this memo.

RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

3 Comments

and Responses

Responses focus on comments that pertain to the adequacy of the analysis in the IS/MND or to other aspects pertinent to the potential effects of the proposed Project

on the environment pursuant to CEQA. Comments that
address topics beyond the purview of the IS/MND or CEQA or that state opinions about the overall merit of the proposed Project are acknowledged for the public record and will be taken into account by City

decision
-
makers.

The following pages present each comment letter

with each
individual comment bracketed
with a
numeric code,
followed by the
corresponding
response to each
individual
comment.

ANNA M. ROTH, RN, MS, MPH
HEALlH SERVICES DIRECTOR
MATTHEWS. KAUFMANN

DEPUTY HEALTH DIRECTOR

JOCELYN STORTZ, MS, REHS

ENVIRONMENTAL HEALTH DIRECTOR

CONTRA COSTA ----

HEALTH SERVICES
November 22, 2022
City of Richmond Planning Division
Attn: Lydia Elias
450 Civic Center Plaza- 2nd Floor
Richmond, CA 94804
lydia [email protected]
RE: PLN21-282-Raven SR Bioenergy Project
1 Parr Boulevard Richmond, CA 94801
APN: 408-140-009
Service Request #: SR0020187
Facility Identification#: FA0047036
Dear Lydia Elias:

CONTRA COSTA

ENVIRONMENTAL HEALTH
2120 Diamond Boulevard, Suite 100
Concord, California 94520
Ph (925) 608-5500
Fax (925) 608-5502
www.cchealth.org/eh/
Contra Costa Environmental Health (CCEH) has received a request for agency comment regarding the above referenced project. The following are our comments:

1. A permit from CCEH is required for any well or soil boring prior to commencing drilling activities, including those associated with water supply, environmental investigation and cleanup, or geotechnical investigation.

2. It is recommended that the project be served by public sewer and public water.

3. The CCEH is designated by the California Department of Resources Recycling and Recovery (CalRecycle) as the Local Enforcement Agency (LEA) for solid waste facilities, including landfills, transfer stations, and waste tire generators and haulers. The prospective operators of Raven SR should be directed to CCEH to submit a Registration Permit application and facility plan for a Transfer/Processing Facility.

4. In the Raven SR Bioenergy Project Initial Study subsection Odor Control, additional clarification is requested.
• What is the time frame for the feedstock to remain on the management area floor? • What do the odor control measures consist of?
10 ~ ~ ~~.J • Contra Costa Behavioral Health Services • Contra Costa Emergency Medical Services • Contra Costa Environmental Health & Hazardous Materials Programs • • Contra Costa Health, Housing & Homeless Services • Contra Costa Health Plan • Contra Costa Public Health • Contra Costa Regional Medical Center & Health Centers •

5. In the Raven SR Bioenergy Project Initial Study section 2.4 Technology, the document lists medical waste as one of the types of organic feedstocks. • Medical waste cannot be accepted at the solid waste facility, unless approved by the appropriate regulatory agency. Contact California Department of Public Health regarding medical waste permitting.

6. The project is adjacent to Class I & II landfills, the operator should ensure the project is compliant with the Post Closure Maintenance Plans of the landfills.

7. Substantial construction and demolition (C & D) waste could result from this project.

Hazardous construction and demolition materials should be separated from those that can be recycled or disposed.

8. Debris from construction or demolition activity must go to a solid waste or recycling facility that complies with the applicable requirements and can lawfully accept the material (e.g., solid waste permit, EA Notification, etc.). The debris must be transported by a hauler that can lawfully transport the material. Debris bins or boxes of one cubic yard or more owned by the collection service operator shall be identified with the name and telephone number of the agent servicing the container.

9. Non-source-separated waste materials must not be brought back to the contractor's yard unless the facility has the appropriate solid waste permit or EA Notification.

These comments do not limit an applicant's obligation to comply with all applicable laws and regulations. If you should have any questions, please do not hesitate to call me at (925) 608- 5550.

Sincerely,
Nicole Soto , REHS
Environmental Health Specialist II
cc
Harprit Mattu, California Department of Resources Recycling and Recovery Harprit.Mattu@calrec ycle.ca. gov

RESPONSE TO COMMENTS Received on

the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

6 Response
s to
Letter 1
-

Contra Costa Environmental Health

1 -
1 The comment specifies that the
project

must obtain a
permit from
Contra Costa Environmental Health
(
CCEH
)
for any well or soil boring prior to commencing drilling activities.

The project applicant
acknowled
ges this requirement and shall comply
.

1 -
2 The comment
recommend
s

that the project be served by public sewer and public water.

As specified in
Section 4.17,
Utilities and Service Systems
, of the IS/MND, the proposed project will continue to be served by
EBMUD and West County Wastewater District, which already serves the site.

1 -
3 The comment specifies application information that the project applicant/operator must obtain from C
CEH

as the Local Enforcement Agency (LEA)
relevant to the proposed project facility and operation.

The project applicant/operator will submit and obtain all required permitting applications for the proposed
Transfer/Processing Facility.

1 -
4 The comment requests clarification of the duration of tim e for
the
project’s
feedstock to remain on the
management area floor
, and

what the o
dor control measures consist of
.

The project applicant has clarified
that
all incoming organic feedstock material shall be received and stored under roof in designated area s
and

shall be processed within 48 hours
of receipt.

The project will incorporate control mechanisms to
minimize possible additional odors from its operation. Odor control would be both preventative and performance based, triggered “if objectionable odors
occur”, such as the immediate application of odor
neutralizing solutions onsite as needed. Also, as previously mentioned in Response to Comment 1 -
4, the
site shall be cleaned daily to remove loose material and litter. Boxes, bins, and containers shall be c leaned
on a regular basis. The site and receiving area shall be swept regularly. Specifically, these will include preparation, implementation, and monitoring and annual evaluation of, and adherence to, the operational Odor Prevention and Management Plan (O
PMP) detailed in project Condition No. 19.3 regarding odors and that is consistent with Contra Costa County requirements prior to commissioning and operation of the facility.

Condition No. 19.3
-

Odor Containment.

During the construction phase of the Proj
ect, the
operational Odor Prevention and Management Plan (OPMP) shall be developed and implemented upon commissioning of the renewable fuels processes, intended to become an integrated part of daily operations at the Facility and other sites, so as to prev ent any
objectionable offsite odors and effect diligent identification and remediation of any potential objectionable odors generated by the facility and associated sites. The plan shall outline equipment that is in place and procedures that facility perso nnel shall use to address odor
issues, facility wide. The OPMP shall include continuous evaluation of the overall system performance, identification of trends to provide an opportunity for improvements to the plan, and updating the odor prevention and mana
gement strategies, as necessary. This plan shall be
retained at the facility for City or any other government agency inspection upon request. The following practices shall be included in the OPMP to reduce the potential of objectionable odors from the stor
age of renewable feedstocks, operation of the Facility, and any other odor generating activity:

RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

7 •

Develop operating procedures to inspect and evaluate the effectiveness of odor control equipment and operation of the wastewater treatment plant.

•

The OPMP shal
l include guidance for the proactive identification and documentation of odors through routine employee observations, routine operational inspections, and odor compliant investigations.

•

Inspections to be conducted on a semi
-
annual basis.

•

If there are fewer

than an average of five confirmed complaints per year during the first 3 years of operation, then the inspection frequency can be reduced to an annual basis.

•

If there are more than five confirmed complaints in any single year, then the application shall d
evelop additional mitigation strategies in consultation with the BAAQMD.

•

All odor complaints received by the facility shall be investigated as soon as is practical within the confines of proper safety protocols and site logistics. The goal of the investiga tion
will be to determine if an odor originates from the facility and, if so, to determine the specific source and cause of the odor, and then to remediate the odor.

•

Prepare an annual evaluation report of the overall system performance, identifying any tre
nds to provide an opportunity for improvements to the plan, and updates to the odor management and control strategies, as necessary. The report shall be provided to the City for review and approval.

Also see Response to Comment 9
-
5 regarding the related e
nvironmental impacts of odor.

1 -
5 In response to the comments statement regarding
medical waste as one of the types of organic feedstocks ,
the project applicant has clarified, as limited by project Condition No. 8.1 regarding eligible feedstocks, that the
project shall be prohibited from intentionally accepting industrial or medical waste in the eligible feedstock. The IS/MND is updated as shown below.



2.4 Technology (p. 17)

Organic feedstocks include biomass, municipal solid waste, bio -
solids, industrial
waste,
sewage,
medical waste,

or a combination of these, obtained from the existing WCCSL.

1 -
6 The comment seeks to

ensure the project is compliant with the Post Closure Maintenance Plans of the landfills.

Project Condition No. 4.5 specifically requires that the project operations shall be consistent with, and shall not conflict with, the Closure/Post Closure Maintenance Plan required by CalRecycle, the SFRWQCB, and the LEA for the existing WCCSL.

1 -
7 The c
omment addresses the treatment of h
azardous construction and demolition materials
, t
he required
management of d
ebris from construction or demolition

activity
, and states that
n
on
-
source
-
separated
waste materials must not be brought back to the contractor's

yard unless the facility has the appropriate
solid waste permit or EA Notification.

Each of these requirements are part of standard local, State and federal regulatory requirements
and project conditions
pertaining to solid waste, water
/

stormwater
resour
ces
,

and hazardous site conditions
. The project applicant acknowledges this requirement and shall comply.

________________________

•

BERKELEY LAB
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Lydia,
November 21, 2022
I am writing to support Raven SR's Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service's West Contra Costa County Sanitary Landfill.

Raven SR's novel system provides a unique opportunity to demonstrate a new hydrogen production technology that could revolutionize waste-to-hydrogen production. In addition to providing clean hydrogen fuel, the technology may also help the City of Richmond further divert waste from landfills to meet California's SB 1383's goal of reducing organic waste disposal by 75% from 2014 levels (up to 27 M tons of organic waste) by 2025.

In addition to reducing methane and short-lived climate pollutants from the landfill, Raven SR will also support and expand jobs in the community, including construction jobs to build their facilities. Raven SR recently signed a Project Labor Agreement with the Contra Costa Building & Construction Trades Council and the I.B.E.W. Local #1245, demonstrating their commitment to using the community's talents.

California has taken a leadership role in the nation for launching the hydrogen economy and Richmond has an opportunity, with Raven SR, to join the state in supporting advancement of hydrogen production, while also reducing emissions and addressing climate change. Because of this opportunity, I hope you will consider approving Raven SR's CUP application and the CEQA MND so they may begin construction this year and start production in early 2023.

Sincerely,
Vi H. Rapp, PhD
Deputy for Building and Industrial Applications Department I Research Scientist Lawrence Berkeley National Laboratory
Energy Technologies Area I Building Technologies and Urban Systems Division Office: 510-495-2035 I Email: [email protected]
Lawrence Berkeley National Laboratory
One Cyclotron Road I Berkeley, California 94720 / phone 510-486-4000

RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

9 Response
s to
Letter 2
–

Berkeley Lab

2 -
1 The comment is in support of the proposed Project and notes that the proposed Proje ct will help the City
further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment also opines that the proposed Project’s non -
combustion
system would reduce methan
e and short
-
lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this commen t, however, it is
noted and will be made available to City decision
-
makers as they consider the Project and whether or not
to approve it.

________________________

1001 I Street, Sacramento, CA 95814 | P.O. Box 4025, Sacramento, CA 95812 www.CalRecycle.ca.gov | (916) 322-4027

California Environmental Protection Agency

Department of
Resources Recycling and Recovery
Gavin Newsom
California Governor
Amelia Yana Garcia Gonzalez
Secretary for Environmental Protection
Rachel Machi Wagoner
CalRecycle Director
November 7, 2022

Lydia Elias, Planner I
City of Richmond Planning and Building Services Department 450 Civic Center Plaza
Richmond, CA 94804
[email protected]

Subject: SCH No. 2022100145 – Raven SR Bioenergy Project Mitigated Negative Declaration – Contra Costa County

Dear Lydia Elias,

Thank you for allowing the Department of Resources Recycling and Recovery (CalRecycle) staff to provide comments on the proposed project and for your agency’s consideration of these comments as part of the California Environmental Quality Act (CEQA) process.

Project Description

The City of Richmond Planning Department, acting as Lead Agency, has prepared and circulated a Notice of Completion (NOC) of a Draft Initial Study/Mitigated Negative Declaration (Draft IS/MND) in order to comply with CEQA and to provide information to, and solicit consultation with, Responsible Agencies in the approval of the proposed project.

The proposed Raven SR Project is located at 1 Parr Boulevard, Richmond, California. The 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. 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.

The proposed project would add a bioenergy system at the site. The non-combustion process would convert blended green waste and food waste, obtained from the existing

1001 I Street, Sacramento, CA 95814 | P.O. Box 4025, Sacramento, CA 95812 www.CalRecycle.ca.gov | (916) 322-4027

BMPC operation adjacent to the project site, into renewable, transportation grade hydrogen that would be exported offsite for various renewable energy products. No long-term hydrogen storage would occur onsite. The project would involve the erection of a modular structure and industrial canopy.

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 carbonate (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 drop out solid matter from the green and food waste feedstock, which would consist largely of biocarbon, along with dirt, glass, grit, rocks, and inorganic salts. The biocarbon materials are inert to the process (i.e., not gasified) and drop out in the first stage. The process also drops out excess water. Neither the biocarbon nor the water would be considered a hazardous material.

Prior to being received at the site, the material will be ground and screened at the WCCSL compost site. Maximum daily tonnage is estimated to be 99.9 wet tons per day of blended green waste and food waste. The Raven SR system may run up to 24 hours per day, seven days per week.

The operation would involve up to approximately 12 hydrogen tube trucks and up to approximately 15 biocarbon trucks (total 37 trucks) per week, each with an average trip of 40 miles after leaving the site. Considering this with other trucks and employees coming to and leaving the project site daily, the project is estimated to generate about 130 vehicle trips on a typical weekday.

Comments

CalRecycle staff’s comments on the proposed project are listed below. Where a specific location in the document is noted for the comment, please ensure the comment is addressed throughout all sections of the Draft IS/MND, in addition to the specific location noted.

Comments for the Draft IS/MND are summarized below:

1. Project Description, Daily Quantities and Operations, PDF Page 22 – “The Raven facility would receive up to 99.9 wet tons per day of blended green waste and food waste feedstock…” Receipt of this volume of solid waste for further processing will require a Transfer/Processing Facility Solid Waste Facility Permit. As a reminder, per PRC 40191 a solid waste facility cannot receive hazardous, radioactive, or medical wastes.

2. Project Description, Odor Control, PDF Page 23 – “Nuisance odor from Raven is unlikely since feedstock material would only be on the feedstock management area floor for relatively short periods of time.” The applicant should clarify how long the material will be stored in the storage bunkers or other designated material storage areas prior to being placed in the Raven SR’s Reformation Technology system? Given the putrescible nature of the incoming feedstock, what methods will the applicant utilize to control or prevent the propagation, 1001 I Street, Sacramento, CA 95814 | P.O. Box 4025, Sacramento, CA 95812 www.CalRecycle.ca.gov | (916) 322-4027

harborage and attraction of flies, rodents, or other vectors, and animals, and to minimize bird attraction.? Per Title 14 CCR Section 17410.1(a)(2) “facilities shall remove solid waste accepted at the site within 48 hours from the time of receipt.”

Solid Waste Regulatory Oversight

Contra Costa Health Services is the Local Enforcement Agency (LEA) for Contra Costa County and responsible for providing regulatory oversight of solid waste handling activities, including inspections. Please contact Tim Kraus, the LEA, at 925.608.5549 to discuss the regulatory requirements for the proposed project.

Conclusion

CalRecycle staff thanks the Lead Agency for the opportunity to review and comment on the environmental document and hopes that this comment letter will be useful to the Lead Agency preparing the MND and in carrying out their responsibilities in the CEQA process.

CalRecycle staff requests copies of any subsequent environmental documents, copies of public notices and any Notices of Determination for this proposed project.

If the environmental document is adopted during a public hearing, CalRecycle staff requests 10 days advance notice of this hearing. If the document is adopted without a public hearing, CalRecycle staff requests 10 days advance notification of the date of the adoption and proposed project approval by the decision making body.

If you have any questions regarding these comments, please contact me at 916.341.6119 or by e-mail at [email protected].

Sincerely,

Harprit Mattu, Environmental Scientist
Permitting & Assistance Branch – North
Waste Permitting, Compliance & Mitigation Division
CalRecycle

cc: Eric Kiruja, Supervisor
Permitting & Assistance Branch – North

Tim Kraus, REHS, LEA
Contra Costa Health Services

RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

13 Response
s to
Letter 3
-

CalRecycle

3 -
1 The comment states that per PRC
40191 and given the proposed daily volume of a solid waste the proposed facility could receive, receipt of hazardous, radioactive, or medical wastes is not permitted.

See
Response to Comment 1
-
5 above regarding
eligible feedstock.

3 -
2 The comment requests clarification of how long the feedstock material will be stored in the storage
bunkers or other designated material storage areas prior to being placed in the Raven SR’s Reformation Technology system
.

See
Response
s

to Comment
s

1 -
4 and
9 -
5 regarding potential odor
control measures
and
impacts.

3 -
3 The comment specifies contact information
for the project applicant and City to discuss t
he regulatory
requirements for the proposed project.

The project a
pplicant acknowledges this requirement and shall
comply.

3 -
4 The comment requests copies of any subsequent environmental documents, copies of public notices and any Notices of Determination for this proposed project, and specifies noticing timeframes. The

Lead
Agency will conduct all CEQA
-
related noticing and distribution of associated documents pursuant to CEQA Guidelines for an MND and City standards. Access to all project notices, documents and City actions on the project are available to the public at
https://www.ci.richmond.ca.us/4365/Raven
-
SR
-
Bioenergy
-
Project
.

Printed on Recycled Paper
November 4, 2022

Lydia Elias, Planner 1
(Sent electronically to [email protected])
City of Richmond Planning Division
450 Civic Center Plaza-2nd Floor
Richmond, CA 94804
Phone: (510) 620-5558

Subject: Raven SR Bioenergy Project Draft Initial Study/Mitigated Negative Declaration (SCH 2022100145)

Dear Ms. Elias,

Thank you for the opportunity to review and comment on the draft Mitigated Negative Declaration for the Raven SR Bioenergy Project (SCH 2022100145). The Department of Toxic Substances Control (DTSC) has identified that your project may affect, and in turn be affected by, the West County Landfill Inc. Post-Closure Permit project (CAD041844002). The Post-Closure Project area is surrounded by the Class II portion of the West Contra Costa County Sanitary Landfill. Initial wastes received included demolition debris, municipal solid waste, and industrial waste. In later years, the site was designated to receive hazardous waste. The Project area has operated a corrective action groundwater monitoring program for the Hazardous Waste Management Facility (HWMF) since March 1996. This program consists of measuring leachate and groundwater levels to evaluate inward hydraulic gradients across the HWMF and E‐22R slurry walls, and the semiannual sampling and analysis of groundwater from 33 wells to monitor groundwater quality in the surficial, shallow, and medium water‐bearing zones (WBZs) beneath the Project area.

Additional information about the permit and groundwater contamination at the site is available here.

DTSC has the following comments on the draft Mitigated Negative Declaration and Initial Study for the Raven SR Bioenergy Project:

1. The proposed Raven SR Bioenergy Project’s construction may destabilize the contamination at the West County Landfill Inc. Post-Closure Permit beyond its existing containment system. This may result in, the potential contamination of additional groundwater.

2. The groundwater monitoring system funnels leachate to a treatment area near the proposed Raven SR Bioenergy Project that may be damaged during construction.

3. DTSC believes that City of Richmond must address these concerns to avoid any significant impacts under CEQA that may occur and ensure that the West County Landfill Inc. Post-Closure care is operational during and after construction of the SR Bioenergy Project.

Thank you for your assistance in protecting California’s people and environment from the harmful effects of toxic substances. If you have any questions or would like any clarification on DTSC’s comments, please contact Rebecca De Pont, Supervising Environmental Planner at (916) 255-3638 or [email protected].

Sincerely,

Rebecca De Pont
Supervising Environmental Planner, Permitting Division
Department of Toxic Substances Control

RESPONSE TO COMMENTS Received on

the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

16 Response
s to
Letter 4
-

Department of Toxic Substances Control

4 -
1 The comment claims that the
project’
s

construction may destabilize the contamination at the West County Landfill Inc. Post
-
Closure Permit beyond its existing containment system,
and that
the existing
groundwater monitoring system may be damaged during construction, resulting in potential
con
tamination of additional groundwater and
significant impacts under CEQA.

The analysis understands
that the existing systems directs leachate from the landfill to the treatment area located near the proposed project site (IS/MND, Section 2.2
Surrounding Use
s and Conditions
). The
Geotechnical Investigation
report prepared for the proposed project (Rockridge, 2022)

involved investigation to depths of
approximately 150 feet on and around the site. The investigation confirmed that the maximum depth of disturbanc
e required for the project, specifically the foundation pads necessary to support the proposed project (up to approximately 30 to 33 feet) would not disturb existing groundwater or monitoring stations of leachate flows or migration. Thus the proposed proj ect would not
destabilize the existing
containment system or groundwater condition during construction. Further, as indicated in Response
to Comment 1
-
6,
the project shall be compliant with the Post Closure Maintenance Plans of the landfills, in accordance

with project Condition No. 4.5, the Closure/Post Closure Maintenance Plan required by CalRecycle, the San Francisco Regional Water Quality Control Board (SFRWQCB), and the LEA for the existing WCCSL.

________________________

October 21, 2022

Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804

RE: Support for Raven SR’s Conditional Use Permit for Clean Hydrogen Facility

Dear Ms. Elias,

I am writing in support of Raven SR’s Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a clean hydrogen/bioenergy facility at Republic Service’s West Contra Costa County Sanitary Landfill.

As the author of statewide legislation to jumpstart California’s use of hydrogen made from renewable sources, I am pleased that Raven is proposing to showcase a new clean hydrogen production technology in Richmond, using a waste-to-hydrogen process. In addition, Raven’s innovative project will help the city divert more waste from landfills to meet California’s goal of reducing organic waste disposal by 75% from 2014 levels by 2025.

I am also pleased that Raven has signed a Project Labor Agreement with the Contra Costa Building & Construction Trades Council and the I.B.E.W. Local #1245.

California has taken a leadership role in launching a clean hydrogen economy, and Richmond has the opportunity with Raven to advance clean fuels production and emissions reductions, and help our fight against climate change.

As such, I respectfully urge you approve Raven SR’s CUP application and the CEQA MND so they may begin construction this year and start production in early 2023.

Sincerely,

Nancy Skinner
State Senator, District 9

RESPONSE TO COMMENTS Received on

the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

18 Response
s to
Letter 5
-

California State Senate

5 -
1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The commen
t also opines that the proposed Project’s non
-
combustion
system would reduce methane and short
-
lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis con
tained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision
-
makers as they consider the Project and whether or not
to approve it.

________________________

CONCORD OFFICE: 2300 Clayton Road, Suite 1150, Concord, CA 94520 SAN RAFAEL OFFICE: 1125 Tamalpais Avenue, San Rafael, CA 94901 mceCleanEnergy.org
Lydia Elias October 20, 2022
City of Richmond’s Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804

Dear Ms. Elias,

Over the years, we have seen the incredible projects that have come to fruition in the City of Richmond. Keeping in tradition with this innovative, entrepreneurial spirit, we are pleased to watch the development of the Raven SR bioenergy facility at Republic Service’s West Contra Costa County Sanitary Landfill.

MCE’s mission is to confront the climate crisis by eliminating fossil fuel greenhouse gas emissions, producing renewable energy, and creating equitable community benefits. We understand the incredible impact that clean, green hydrogen offers California as we transition away from fossil fuels and decarbonize our economy. Raven SR’s proposed hydrogen production is expected to not only produce a consistent high-value multi-use hydrogen supply, but also reduce our community waste streams without incineration. This would help us meet our organic waste diversion goals (Senate Bill 1383) while minimizing existing methane and greenhouse gas emissions, and would avoid contributions to localized criteria air pollutants. We understand Raven SR has a PLA with the Contra Costa Building & Construction Trades Council and IBEW Local 1245, helping to ensure the quality of jobs produced at this site.

We are excited about this proposed technology, and the engagement with strong partners. In addition, we’re encouraged to see the project take root in Richmond as its first location.

In October, we attended an Alliance for Renewable Clean Hydrogen Energy Systems (ARCHES) event to discuss the possibilities that hydrogen offers California and how stakeholders must coordinate to obtain funds from the Department of Energy to create a regional Hydrogen Hub. It is likely that there could soon be strong demand for a limited supply of commercially available hydrogen. Raven’s production is poised to take advantage of this growing demand to meet decarbonization goals. Using hydrogen for transportation fuel is especially important to displace the diesel emissions of long-haul vehicles which disproportionally pollute lower-income and communities of color adjacent to transportation corridors.

Thank you for your consideration. We are supportive of these efforts and look forward to this project becoming a key part of California’s Northern California Hydrogen Hub in the future.

Sincerely,

Dawn Weisz, CEO

RESPONSE TO COMMENTS Received on

the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

20 Response
s to
Letter 6
-

MCE

6 -
1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (Californ
ia’s SB 1383). The comment also opines that the proposed Project’s non -
combustion
system would reduce methane and short
-
lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the ade quacy of the analysis
contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision
-
makers as they consider the Project and whether or not
to approve it.

________
________________

From: Kelly Malinowski
To: Lydia Elias
Cc: Samuel Garcia; Lily MacIver; Wendy Goodfriend; Alison Kirk Subject: Raven SR Bioenergy Project
Date: Wednesday, October 19, 2022 2:44:33 PM
You don't often get email from [email protected]. Learn why this is important This email originated from outside of the City's email system. Do not open links or attachments from untrusted sources.

Hi Lydia,
We have reviewed the IS/MND for the Raven SR Bioenergy Project. We will not be sending a formal CEQA comment letter, but we did want to provide some additional dust mitigation measures that you could consider for the Construction Dust, related to AQ-1 Best Management Practices, below:

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.

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
Please let us know if you have any questions, or would like to discuss! Best,
Kelly
Kelly Malinowski, MPA | Senior Environmental Planner
Planning and Climate Protection Division
Bay Area Air Quality Management District
Office: 415-749-8673
Pronouns: she/her

RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

23 Response
s to
Letter 7
-

Bay Area Air Quality Management District

7 -
1 The comment
provides

additional dust mitigation measures for consideration, which the City and the
project applicant
has elected to in
corporate in to Mitigatio
n Measure AQ
-
1 , as
shown below
.



Section 4.3, Air Quality, Criterion “b” (p. 39):

Mitigation Measures

AQ
-
1: Best Management Practices.

All subsequent projects, regardless of size, 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, so il 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 ma
ximum 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 wit
h 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 regu
lations.



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.

RESPONSE TO COMMENTS Received on

the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

24 

Additional BMP: Limit the simultaneous occurrence of excavation, g rading, and ground
-

di
sturbing
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 g
round 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 roa
dways 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 previous
ly 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 d own 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.



These modifications do not change the adequacy of the analysis or impacts identified in the IS/MND, and no further analysis is warranted, pursuant to the findings enumerated in Section 1 of this memo.

_________________
_______

'c,R~ REPUBLIC ~'v SERVICES
October 13, 2022
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Lydia:
1 am writing lo provide our company's support of Raven SR's Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioene rgy facility at Republic Serv ice's West Contra Costa County Sanita ry Landfill (WCCSL).

Raven SR has developed a new hydrogen production technolo gy that will revolutioni ze waste-to-hydrogen production. The Richmond location wi ll be the first project of its type and the community has a significant opportunity to receive recognition for being the host location for this innovative project from the pro-hydrogen focused State of California and US Department of Energy. This project will be recognized nationally as an industry shiftin g and innovative approach to clean green hydrogen production.

The Raven project will also develop an additional local, reliable, and comp liant outlet for organic wastes to complement the current compost ing operation on site. In addition to providing a new source of clean, gree n hydrogen fuel, the Raven project wi ll also help the City of Richmond further divert organic waste from landfill s to meet California 's SB 1383 ·s goal of reducing organic waste disposal by 75% from 2014 levels by the compliance date of 2025.

The development of the Raven project will gene rate jobs not only in the City of Richmond, but also ancillary jobs throughout the area throu gh eng ineering, fabrication, construction, fuels providers, waste management. and many other areas. To this end, Raven has recently signed a Project Labor Agreement with the Contra Costa Building & Construction Trades Council and the I.B. E. W. Local# 1245 relating to this project.

Because Raven's proprietary system utilizes a non-combustion process that generates minimal emissions. the project will reduce overa ll methane and short-lived climate pollutants emissions compared to other processes. Additionally, this project also provides a net positive reduction in greenhouse gases emissions when compared to other similar practices. This is an important and positive aspect to improving the air quality around the C ity of Richmond and surrounding communities.

California has taken a leadership role in the nation by launching the gree n hydrogen economy and sett ing aggressive greenho use gas reductions goa ls. The City of Richmond ~R~ REPUBLIC ~'v SERVICES
I t
has the opportunity along with Raven SR to lead in this advancement and these very important initiatives with this project. We believe development of projects such as the Raven SR bioenergy facility at the WCCSL are essential for meeting California's greenhouse gas initiatives reduction goals and making a difference towards reversing climate change.

Thank you for your consideration and we respectfully request you approve Raven SR 's CUP application and the CEQA MND so they may begin construction this year and start production in early 2023.

Sincerely,
Ken Lewis, .

General Manager - North Bay

RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

27 Response
s to
Letter 8
-

Republic Services

8 -
1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste d isposal for target
year 2025 (California’s SB 1383). The comment also opines that the proposed Project’s non -
combustion
system would reduce methane and short
-
lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission
. The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision
-
makers as they consider the Project and wh
ether or not
to approve it.

________________________

November 22, 2022
Lydia Elias, Planner 1City of Richmond Planning Division450 Civic Center Plaza—2nd FloorRichmond, CA 94804510-620-5558 Submitted electronically via [email protected] Re: Comment on Draft Initial Study/Mitigated Negative Declaration (IS/MND) for RavenSR Bioenergy Project (PLN21-282) Dear Ms. Elias,
Please accept these comments from the undersigned organizations concerning the DraftInitial Study and Mitigated Negative Declaration (IS/MND) for the Raven SR Bioenergy Project,Project No. PLN21-282 (Project). We are thankful for the opportunity to share our concernsduring this extended comment period. For the reasons described below, we do not believe theanalysis supporting the IS/MND is sufficient, and therefore request that you produce a fullEnvironmental Impact Report (EIR).

Raven SR Inc. (Applicant) proposes the construction of a novel technology for creatinghydrogen that has no real precedent, making the need to do a thorough environmental impactanalysis even more important. We would like to work collaboratively with the City PlanningDivision to ensure that the already overburdened community in North Richmond does not faceany unexpected cumulative impacts from this new project. While the project is being touted asgreen, such claims should not influence the need for thorough in-depth analysis of Projectimpacts under the California Environmental Quality Act (CEQA). We believe the City should beasking many more questions, and providing the public with transparent answers about the scopeof the Project; and answering them in a full EIR.

I. Outstanding air permit items must be resolved and disclosed in order to properlyassess the Project’s potential environmental impact On May 11, 2022, the Bay Area Air Quality Management District (BAAQMD)determined that the Air Permit Application to construct the Raven SR Bioenergy Project(Application #31700) was incomplete. BAAQMD, as a responsible agency, needs completeinformation to weigh in on the review; and accordingly, the City needs such information to fullyevaluate the Project’s air quality impacts. The Air Permit Application remains a live application under review and the City’s IS/MND does not include a disclosure or assessment of essentialinformation requested by BAAQMD in its letter.

Specifically, BAAQMD flagged a staggering 57 missing or incomplete items that stillneed to be disclosed and analyzed, including important information needed to assess communityhealth impacts—such as missing Health Risk Assessment (HRA) forms for specific emissionsources, missed potential sources of emissions (i.e. lime stored onsite and biochar if storedonsite), confirmation that formaldehyde would not be released from the bioengines, and clearenforceable limits on flare use. Until and unless all 57 concerns are addressed, the City shouldnot move forward with a MND. Full information regarding air pollutant loads and impact is allthe more important because the Project would be located in an already overburdened community.

II. Exceedances of chronic and acute thresholds for toxic chemicals trigger the need fora Health Risk Assessment (HRA) Based on the current version of the BAAQMD Air Permit Application, emissions fromthe biogas engines powered by landfill gas (LFG) exceed chronic and acute thresholds thattrigger the need for a Health Risk Assessment (HRA) under Rule 2-5 for eight different toxicchemicals. Acute HRA limits are exceeded for formaldehyde, while chronic limits are exceededfor 1,3-butadiene, acetaldehyde, acrolein, ammonia, benzene, diesel particulate matter (PM),formaldehyde, and naphthalene.

We also request that the City be conservative in determining the scope of an HRA forthese chemicals. According to the Initial Study, an HRA was not conducted for the impacts ofdiesel PM from construction because sensitive receptors are not within 1,000 ft of the site anddue to “trigger levels not applying to the project”. However, there are sensitive receptors(residences) within 0.75 miles, an elementary school within 1.1 mile and a health clinic within1.2 miles, which is still close enough to warrant full analysis. In reviewing Rule 2-5, it is unclearwhy HRA trigger levels would not apply to this project. Further, while emissions of criteriapollutants NOx and VOCs are estimated to be below the BAAQMD threshold for significantimpact, they are extraordinarily close to the threshold. NOx emissions are estimated at 9.05 tonsper year (tpy) and VOCs at 9.19 tpy, both with a threshold of 10 tpy.

III. Cumulative pollution impacts should be considered more fully Increased emissions from this project adds to the cumulative pollution impacts of themany projects currently in operation and primed for development in North Richmond andadjacent Richmond areas—which is one of the most pollution burdened areas of the state. 1 Full
1 OEHHA, CalEnviroScreen 4.0. Available at https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40. and robust cumulative impacts analysis, as required under CEQA, is thus particularly criticalhere.

Two cumulative impacts stand out with particular importance. First, there will beincreased truck traffic as a result of this project, which is expected to add 100 trips per day ofheavy duty trucks. The Initial Study minimizes the importance of this increase as ‘notsignificant’ because the area already has high truck volumes. However, this reasoning is exactlybackwards: the existing high truck volumespointsto the needto carefully assess potentialcumulative impacts from even more heavy duty trucks. This is particularly so given, as describedabove, how close NOx and VOC pollutant emissions will potentially come to the BAAQMDthreshold for significant impacts.

Second, there are two other hydrogen-related projects being evaluated by and/or withinthe City that are not recognized in this IS/MND:
2,3
Chevron has proposed to expand itsproduction of hydrogen for retail sale and Chevron has also proposed an almost certainly relatedapplication to construct a hydrogen fueling station. Chevron’s production expansion will result inincreased air pollutant emissions; and it is very possible, in the absence of information to thecontrary, that the hydrogen produced at the Project would be marketed via,inter alia, theproposed filling station. Yet these two other projects were not even mentioned in the MND.

All three projects should have been addressed in the IS/MND for a cumulative impactsanalysis. Pollution increases from the Chevron production project should have been consideredcumulatively with pollutant emissions from this Project. To the extent it remains unclear whetherthe hydrogen produced by the Raven project will be marketed at the proposed Chevron fillingstation, the City should have asked that question of Chevron and Raven, and adjusted its analysisaccordingly - possibly even considering the two projects in one EIR, but at the very leastconsidering their impacts cumulatively. Richmond is overall being driven toward a hydrogeneconomy that has the potential to be highly polluting, risking the health and safety of residents 4,5
;and it behooved the City to consider that direction as a whole before simply signing off on onlyone corner of it. 5 Raven SR, Renewable fuels company Raven SR announcesstrategic investment from Chevron, ITOCHU, HyzonMotors and Ascent Hydrogen Fund. Available athttps://ravensr.com/investment-from-chevron-itochu-hyzon-motors-and-ascent-hydrogen-fund/. 4 Chevron U.S.A. Inc., Chevron, Iwatani Announce Agreement to Build 30 Hydrogen Fueling Stations in California.Available athttps://www.chevron.com/newsroom/2022/q1/chevron-iwatani-announce-agreement-to-build-30-hydrogen-fueling-stations-in-california. 3 Raven SR, Renewable fuels company Raven SR announcesstrategic investment from Chevron, ITOCHU, HyzonMotors and Ascent Hydrogen Fund. Available athttps://ravensr.com/investment-from-chevron-itochu-hyzon-motors-and-ascent-hydrogen-fund/. 2 Chevron U.S.A. Inc., Chevron, Iwatani Announce Agreement to Build 30 Hydrogen Fueling Stations in California.Available athttps://www.chevron.com/newsroom/2022/q1/chevron-iwatani-announce-agreement-to-build-30-hydrogen-fueling-stations-in-california.

IV. The biogas engines using landfill gas involves combustion, and the air pollutionimpacts of this combustion should be analyzed in more detail Landfill gas is primarily methane and CO2
, but italso contains many toxic chemicalsfrom the landfill contents. Based on past studies, biogas engines have potential to emit multipletoxic chemicals that are associated with the landfill contents. 6 The Project includes the use ofbiogas engines to power the hydrogen extraction and purification process, and results inemissions of both criteria air pollutants and toxic air contaminants. While the Initial Studymentions the existing biogas engines already onsite and a lower emission profile from the newengines, it does not appear that the likely increased volume of landfill gas processed by thebiogas engines was taken into account. A thorough multi-criteria lifecycle assessment isimportant to understanding the relevant air quality impact of the new biogas engines.

V. The odor mitigation plan is inadequate
The proposed odor mitigation measures are insufficient. The Initial Study states that themethod of odor control would be to employ “control measures similar as those currentlyemployed by WCCSL [West Contra Costa Sanitary Landfill].” However, those measures havealready proven insufficient, as local residents are currently complaining of odors from WCCSL.

Moreover, possible solutions are framed as a form of deferred mitigation, a proposal toaddress an odor problem only if it arises later rather than a plan to address it from the start.CEQA requires concrete and immediate mitigation plans, not promises to develop mitigation inthe future.

And it is fairly clear that odor is going to be a problem. The site of this facility thatwould have piles of putrescible green waste is approximately 158 feet closer to residences thanthe existing composting facility. The IS claims that “nuisance odor from Raven is unlikely sincefeedstock material would only be on the feedstock management area floor for relatively shortperiods of time.” However, the air permit lists the duration of feedstock onsite as 12 hours. Sincethe facility is running 24/7, it seems unavoidable that there would be compost and green wasteonsite at all times.

VII. Potential to convert and create other fuels
Finally, the Raven SR patented technology covers other fuel products that have greaterclimate implications than hydrogen. We question whether the intended use of the facility is fully 6 Konkol et al, 2022.Biogas Pollution and Mineral Deposits Formed on the Elements of Landfill GasEngines. Materials.Available athttps://www.ncbi.nlm.nih.gov/pmc/articles/PMC8999940/ disclosed, and whether there is any potential that the facility could be used down the line to makeliquid fuels such as alternative aviation fuel. The Initial Study should have explored thatpossibility.

VI. Conclusion
We appreciate the opportunity to comment on this project and are especially grateful forthe extension of the comment period. We hope to work collaboratively with the City to ensurethe full consideration of impacts to the community of North Richmond.

Sincerely,
Connie Cho, CBE AttorneyTessa Wardle, CBE Staff ResearcherCommunities for a Better Environment Teresa Cheng, Senior Campaign RepresentativeSierra Club Faraz Rizvi, Campaign and Policy ManagerAsian Pacific Environmental Network Katt Ramos, Managing DirectorRichmond Our Power Coalition Kiara Pereira, Just Transition OrganizerRafael Castro, Just Transition OrganizerUrban Tilth Ann Alexander, Senior AttorneyNatural Resources Defense Council

RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

33 Response
s to
Letter 9
-

Environmental Justice Groups

9 -
1 The comment asserts that the o
utstanding air permit items
for the
proposed

project
must be resolved
and
disclosed in order to properly

assess the
p
roject’s potential environmental impact
.

The CEQA and
permitting processes are separat
e and distinct. T
he pendency of the air permit should not impact the
CEQA process
, rather the
air permit will be constraine
d by CEQA
.

The project applicant is working closely with the BAAQMD to

acquire an air permit for the p
roject. The
information provided in the IS/MND reflects the best air emissions data available from the applicant at the time of publication for determini
ng significance of the project. The
final
IS/MND include updates to
the emission totals that are associated with updates to the permit application materials due to the applicant’s discussions with the air district. The emissions presented in the IS/MND are

not anticipated to
undergo any considerable changes prior to the issuance of an air permit. As such, the IS/MND is reflective of the best available information for assessing potential impacts to the atmospheric environment under BAAQMD guidance.

No furthe
r analysis is warranted
.

9 -
2 The comment asserts that exceedances of chronic and acute thresholds for toxic chemicals trigger the need for a Health Risk Assessment (HRA).

The emissions of toxic air contaminants do exceed trigger thresholds for an HRA unde
r air permitting rules and a HRA will be produced as part of the air permitting process.

For permitting, a

HRA is triggered by the project exceeding emission limits, irrespective of its location and proximity to sensitive receptors. However, under CEQA, we

use HRA as a tool to answer
checklist question 3
-

whether the project would expose sensitive receptors to substantial pollutant concentrations. The BAAQMD recommends methodology and thresholds that can be used in this CEQA
analysis. Since the checklist question specifically talks about exposure of sensitive receptors (and not emissions levels), using the BAAQMD's recommended zone of influence of 1000 feet is a reasonable way to screen for impacts and determine
a less than si
gnificant
impact if there are no receptors within that
distance

For the proposed project and u
nder the BAAQMD CEQA guidance, an HRA must be conducted for sensitive receptors identified within 1,000 feet of the project facility property line. However, no se nsitive
receptors
exist

within that buffer distance, nor within a distance of 2,000 feet of the property line. Given that the project does not have sensitive receptors within the distances indicated by the BAAQMD, an HRA was not developed as part with e CE
QA IS/MND, but an HRA will be produced as part of the air permitting process.

No further analysis is warranted
.

9 -
3 The comment asserts that cumulative pollution impacts should be considered more fully in the IS/MND analysis.

Similar to
Response to Commen
t 9
-
2 regarding
developing a HRA
,
the BAAQMD guidance
indicates that a cumulative health risk analysis should be conducted for all sources within 1,000 feet of the project property line, but no the BAAQMD screening tool indicates that no additional sources

exists
within that distance. Additionally, no sensitive receptors are within 1,000 feet of the project property line, thereby negating the need for an HRA. A cumulative risk analysis is not provided as part of the IS/MND.

No further analysis is warranted
.

9 -
4 The comment claims that the biogas engi
nes using landfill gas involve
combustion, and the air pollution
impacts of this combustion should be analyzed in more detail than presented in the IS/MND analysis.

The
air permitting process being conducted by
the applicant to acquire a permit from the BAAQMD will

RESPONSE TO COMMENTS Received on

the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

34 provided the additional detail that is being requested. As noted in Response to Comment
9 -
1, the most up
to date estimates of air emissions from operation of the facility have been provided in the IS/M ND and
compared against the BAAQMD’s thresholds for significance . No further analysis is warranted
.

9 -
5 The comment opines that the odor mitigation plan is inadequate due to the efficacy of the existing WCCSL odor control measures, the

operational

storage
characteristics of the feedstock materials. The
comment also cites that the project operation would be
approximately

158 feet closer
than the existing
WCCLS
to existing residents
; that distance is

currently
1,750 feet

from the WCCSL.

The IS/MND st
ates that “nuisance odor from Raven is unlikely since feedstock material would only be on the feedstock management area floor for relatively short

periods of time.” The
project

applicant and
operator
, in coordination with City and BAAQMD staff, have furthe r detailed the
draft
conditions of
approval

to fully address Raven operations

specifically
.

As stated in Response to Comment

1 -
4 ,
all
incoming organic feedstock material shall be received and stored under roof in designated areas and shall be processed wit
hin 48 hours of receipt
.

Response to Comment 1
-
4 f
urther detail
s the requirements of
Condition No. 19.3 that is consistent with Contra Costa County requirements prior to commissioning and operation of the facility.

As with all
c
onditions
of approval, the p
roposed project’s adherence is presumed
as part of the project, even though full text of conditions may not be stated in the environmental document.

The environmental impact under CEQA remains less than significant according to the applicable CEQA significance criteria, as analyzed
in IS/MND Section 4.3,
Air Quality

(criterion “d”)
, which assumes
adherence to Condition

19.3 . No mitigation measure is re
quired.

For clarity

and update
, the following
update is made to the IS/MND:



Section 4.3, Air Quality, Criterion “d” (p.
41 ):

Nuisance odor from Raven is unlikely since
feedstock material would only be on the feedstock management area floor for relatively

short
periods of time
; all incoming organic feedstock material shall be received and stored under roof in designated areas and shall be processed within 48 hours of receipt , pursuant to project
Condition No. 19.3
,

which is incorporated as part of the prop
osed project
…

…
The project
may

will
incorporate control measures similar to those current employed by WCCSL,
but expanded and tailored per project Condition No. 19.3, such as ensuring the
input of feedstock into the system within a designated period of ti me from receiving it from
WCCSL’s onsite organic material processing facility to prevent potential odor buildup; routine cleaning of floors, walls, and equipment; use of odor suppressants as deemed necessary.

Also pursuant to Condition No. 19.3, o
O
dor cont
rol would be added to the
management area if objectionable odors occur. The Raven facility could

would
also store
topical treatment solutions (non
-
toxic and biodegradable) onsite, which would be applied to neutralize odors if an immediate need arises.

___
_____________________

November 7
th, 2022

Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804

Dear Lydia,

I am writing in support of Raven SR’s Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service’s West Contra Costa County Sanitary Landfill.

Raven’s Waste to Renewable Hydrogen Project will provide important progress enabled by innovations in California policy and the hydrogen industry. Raven SR is providing the City of Richmond the opportunity to showcase a new hydrogen production technology that will revolutionize waste-to-hydrogen production. The focus in California policy on renewable content and carbon intensity enables the diversity of hydrogen production methods to make the best use of renewable feedstocks in California. Innovations improving the gaseous hydrogen approach by companies like Shell Hydrogen – including high-pressure high-capacity tube trailers that triple capacity while halving cost and refueling stations that enable up to 95% usable fraction – enable a market for distributed hydrogen production with significant benefits for the safety, environment, and economy in California. Please consider:

• New hydrogen production facilities can be built by a wide range of innovative companies, deploying technologies and production pathways that make the very best use of renewable resources in California.

• New hydrogen production facilities can be built in California, close to market, making use of local renewable resources and creating local employment and economic development.

• Hydrogen supply for mobility can become reliable and resilient most quickly, with rapid increase in the number and diversity of production facilities and in the aggregate hydrogen storage capacity in the system.

• Distributed gaseous hydrogen supply for mobility can be safer, lower cost and lower carbon intensity than centralized liquid hydrogen by avoiding the capital cost and energy requirements for liquefaction; minimizing the road transport distances,

costs, and emissions; and enabling storage without product loss to boil-off.

In closing, Shell is committed to a low carbon energy future, with more and cleaner energy, and is working to become a net-zero energy business by 2050 or sooner in step with society. Shell already offers customers a range of decarbonized renewable power, fuels, and energy products, including hydrogen dispensed as a transportation fuel. Thank you for your consideration and I respectfully ask that you approve Raven SR’s CUP application and the CEQA MND so they may begin construction this year and start production in early 2023.

Sincerely,

Humberto Orantes
Acting Commercial Head, North America
Shell Hydrogen

RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

37 Response
s to
Letter 10
-

Shell Hydrogen

1 0
-
1 The comment is in support of the proposed Project and does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to thi s comment, however, it is
noted and will be made available to City decision
-
makers as they consider the Project and whether or not
to approve it.

________________________

POWER ENGINEERS, INC.
2041 SOUTH COBALT POINT WAY
MERIDIAN, ID 83642 USA

PHONE
FAX
208-288-6100
208-288-6199

BOI (2022 -11 -07) JPH

Lydia Elias November 7, 2022 City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804

Subject: Raven SR Conditional Use Permit (CUP)

Dear Lydia,

I am writing to provide my support of Raven SR’s Co nditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the c onstruction and operation of a bioenergy facility at Republic Service’s West Contra Costa County Sanitary Landfill.

Raven SR has developed a new hydrogen production te chnology for waste-to-hydrogen production. Richmond will be their first location, and the community has a significant opportunity to receive attention in the current pro-hydrogen focus by the State of California and Department of Energy. In addition to providing clean hydrogen fue l for the Bay area, Raven will also help Richmond further divert waste from landfills to mee t California’s SB 1383’s goal of reducing organic waste disposal by 75% from 2014 levels (up to 27 M tons of organic waste) by 2025.

The development of the Raven systems will generate jobs not only in Richmond, but also ancillary jobs through the fabrication, fuels providers, engi neering, waste management and so many other areas. Raven has signed a Project Labor Agreement w ith the Contra Costa Building & Construction Trades Council and the I.B.E.W. Local #1245.

Because Raven’s system is non-combustion with minim al emissions, they will actually be reducing methane and short-lived climate pollutants from the landfill, and there will be a positive reduction in greenhouse gases. This is such a posit ive aspect to improving the air around the Richmond area.

California has taken a leadership role in the natio n for launching the hydrogen economy, and Richmond has the opportunity with Raven SR to lead the advancement of clean fuels production, emissions reduction, and reversing climate change in the East Bay region.

Thank you for your consideration and we respectfull y request you approve Raven SR’s CUP application and the CEQA MND so they may begin construction this year.

Respectfully Submitted,

James P. Hays, PE
Business Unit Director, POWER Engineers

RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

39 Response
s to
Letter 11
-

Powers Engineers

11 -
1 The comment is in support of the
proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment also opines that the proposed P roject’s non
-
combustion
system would reduce methane and short
-
lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis contained in the IS/MND. No addition
al analysis or response is required to this comment, however, it is noted and will be made available to City decision
-
makers as they consider the Project and whether or not
to approve it.

________________________

Trails for Richmond Action Committee
TRAC
73 Belvedere Avenue
Richmond, CA 94801
Phone/Fax 510-235-2835
[email protected]
October 27, 2022
VIA Email:

Ms. Lydia Elias, Planner I
City of Richmond Planning Division
Dear Ms, Elias:

TRAC, the Trails for Richmond Action Committee, would like to comment on the Octo- ber 7 Draft IS/MND for the Raven SR Bioenergy Project (PLN21-282).

The project site is very close to the Landfill Loop Trail, which is part of the regional San Francisco Bay Trail as shown on the attached Bay Trail map for Richmond. However, the draft IS/MND in many locations erroneously refers to the Wildcat Marsh Trail, e.g. in Sections 1.10, 2.9 & 4.1a and on Figure 4.1-1. The Wildcat Marsh Trail is located on West County Wastewater District property, whereas the Landfill Loop Trail is located on the Republic Services site of the Raven SR facility as shown by the attached orientation map posted at the Landfill Loop trailhead staging area.

Section 4.12 Noise and Vibration: The nearest noise-sensitive receptors would be those walking, bicycling and bird watching on the Landfill Loop Trail. Noise impacts on trail users should be assessed and mitigated as appropriate.

TRAC hopes that these comments will prove helpful in finalizing the IS/MND.

Sincerely,

Bruce Beyaert, TRAC Chair
Attachments:

Richmond Bay Trail Map
Wildcat Marsh & Landfill Loop Trail orientation map

14.6” x 17.3” — G arrard Blvd.

Atlas Rd
San Pablo
80 580
Point San Pablo
Yacht Harbor
Point Molate Beach Park
Point Pinole
Regional
Shoreline
Point San Pablo
Point
Wilson
Winehaven
Historic District
Shimada
Park
Miller-Knox
Regional
Shoreline
Point Isabel
Regional
Shoreline
Jay &
Barbara
Vincent
Park
Richmond-
San Francisco
Ferry Terminal
Lucretia
Edwards
Park
Rosie the Riveter/
WWII Home Front
NHP Visitor Center
SS
Red Oak
Victory
Marina
Bay
Park
Richmond
BART Station
El Cerrito
Plaza
BART
Station
El Cerrito del Norte
BART Station
Cutting Blvd
Marina
Bay
Gertrude Ave
Castr
o St
He
nsley St
Richmond
El Cerrito
Richmond
y
W anira
M
Keller
Beach
Ferry
Point
Point
Molate
Brooks Island
Point
Potrero
Hall
Wright
Nevin Ave
Barrett Ave
Pennsylvania Ave
Ohio Ave
To Point Isabel
Regional Shoreline
Richmond Greenway
Landﬁ ll
Loop Trail
Boat
Ramp St
Richmond
Museum of History
West Macdonald
Point
Richmond
23rd St
Kaiser
Shipyard 3
Richmond
Goodrick Ave
51st St
Wildcat Creek Trail
Canal Blvd
Harbour W
ay Soutn
Ho
man
Trail Open — Pilot Project
Richmond-San Rafael Bridge
Garrard Blvd
Regatta Blvd
Dorna
n Dr
Brickyard Cove
Pkwy
Marina Bay
Open
Fall
2019
Ohlone Greenway
Wildcat
Marsh
Trail
Richmond
Wellness
Trail
Richm
ond Pkwy
Parkway
San Pablo Ave
Pin
Trail
Stenm
ark Dr
Welcome to
Richmond
August 2022

Over 36 miles of Bay Trail
linking a necklace of
12 shoreline parks

0 MILES

10.50.25 0.75
Bay Trail
Complete
Incomplete
Connector Trail
Complete
Incomplete
Parks/Open Space
Water Trail site
Water Trail site
(planned)
Water Bodies

A part of the San Francisco Bay Trail
The story of this portion of the Bay Trail is one
based on the very essence of today's meaning
of ''green.'' Non-existent until now, the trail
incorporates fantastic views of San Pablo Bay,
Wildcat and San Pablo Creeks with remarkable examples of industrial water conservation and reuse, resource recovery, electrical generation, recycling and recreation.

Map Legend
~*'~' -· ••
~*'-J
■■■■■■■■■■■■■■■
Bay Trail suitable for walking, biking,
roller skating & wheelchair access
Bay Trail of compacted aggregate
c::.
~
~
~--
m Picnic Area
Concrete
Crusher
'~' I o.oo mi I
Distance markers and mileage
between two markers ~ Retention Pond
I ■■■■■■■■■ Future Bay Trail
*
Connector Trail
~ Parking m Drinking Water
m Picnic area f ♦ ITl Restrooms
AS A WORKING INDUSTRY, Republic Services has
established regulations that will assure continued public enjoyment of this unique portion of the Bay Trail that is located on private landfill property. Visitors use the trail at their own risk.

NORTH
'
9~ -· '"!,;.
b
.~
-:¾ ~---
NOT ALLOWED: No dogs (excepting seeing eye dogs)
or horses. No fishing or swimming, fires, fireworks or
firearms, smoking, camping, motorized vehicles, boating, alcoholic beverages, straying off trail, climbing fences or on shoreline riprap, or feeding of wildlife. Bicycles are not allowed on the upper trail.

Credit for the Landfill Loop Trail goes to Larry Burch and Jay Vincent for their vision, and to Republic Services, Inc., and the Trails for Richmond Action Committee (TRAC) for carrying out this vision. Credit for the Wildcat Marsh Trail goes to East Bay Regional Park District for building and maintaining it, to West County Wastewater District for making their land available, and to funding from both the San Francisco Bay Trail Project and voter approval of East Bay Regional Park District Measure CC. :ni 1.18mi
Compost
Garbage Mountain
(158
1 elevation)
Green Waste
Construction
& Demolition
Pickleweed Marsh
, mi
~
HOURS: The Landfill Loop Trail is generally open 8:30
a.m. to 4 p.m., seven days a week. The gates are
locked at 5 p.m. The trail will be closed on the
following holidays: New Year•s Day, Easter, July 4,
Labor Day, Thanksgiving and Christmas. Some trail
sections may be closed for routine maintenance. Call
510-262-1660 for trail information. Wildcat Creek Trail Head and Wildcat Marsh Trail are open dawn to dusk.
~
-
•
~ ~
V\
QJ
~
0 0)
~ 0
~
f.) 0 Landfill Loo
Trail Heads
Power
Generator
Transfer
Station
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•.
~
.. ,
,+.
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~~
You are ere.
r.,& ....... .
••• ..

Oi Solar
Panels
'-1 E
* l~
~
•♦ ♦•
Wastewater
Treatment
Plant

PARR BLVD
♦•
•♦
•••••••
t
To 1-80
•
--
•
►
•
►
~ ~••w ~.
•
•
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•
•
PITTSBURG AVE.
'
'
'
•
"-. 1 .2smi 1 ~ lmlil~
c?:J.\ Creef
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Trail Head
To 1-580
t
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RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

43 Response
s to
Letter
12 -

Trails for Richmond Action Committee (TRAC)

12 -
1 The comment distinguishes the existing Landfill Loop Trail from the Wildcat Marsh Trail, both of which are part of the regional San Francisco Bay Trail. In the following

instances, the IS/MND is updated

to
specify the two facilities that exist near to the proposed Project site.



Section

1.10 , p. 6:

Figure 1
-
3 shows the closest structure and development is the Golden Bear Waste Recycling Facility approximately 300 feet southwest of the proposed project l
ocation, and the West County Wastewater District Treatment Plant and the Landfill
Loop
Wildcat Marsh

Trail and trail head parking exist approximately 1,000 feet east of the project location.



Section

2.9 , p. 22:

As part of the proposed project, off
-
site la
ndscaping improvements to the
Landfill Loop
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 will be installed within the

Raven project site. Instead, new trees will be added
to the public parking area near the trailhead.



Section 4.1a and Figure 1
-
1:

Figure 4.1
-
1,
Landfill Loop
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.

1 2
-
2 The comment asserts that
trail users should be

considered the
nearest noise
-
sensitive receptors
to the
proposed Project and factored into the noise analysis. This consideration would not be consistent with the City’s established approach to noise analy
ses in other CEQA documents for project located adjacent to public trails. Moreover, users of the trail would be electing their activity in the noise environment and would be a temporary, relatively short
-
term recreational users, unlike residences, schools

and medical
facilities or wildlife species. No additional analysis is warranted in response to the comment.

________________________

@
Benicia
Fabrication
&Mach ine
10/20/2022
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Lydia,
I 01 East Channel Rd
Benicia, CA 94510
Phone (707) 745-8111
Fax (707) 745-8102
www.beniciafab .com
I am writing to provide our company's support of Raven SR's Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service's West Contra Costa County Sanitary Landfill.

Raven SR has developed a new hydrogen production technology that will revolutionize waste-to-hydrogen production , and as Richmond will be their first location, the community has a significant the opportunity to receive attention in the current pro-hydrogen focus by the State of California and Department of Energy. In addition to providing clean hydrogen fuel for the Bay area, Raven will also help Richmond further divert waste from landfills to meet California's SB 1383's goal of reducing organic waste disposal by 75% from 2014 levels (up to 27 M tons of organic waste) by 2025.

The development of the Raven systems will generate jobs not only in Richmond , but also ancillary jobs through the fabrication, fuels providers, engineering , waste management and so many other areas. Raven has signed a Project Labor Agreement with the Contra Costa Building & Construction Trades Council and the 1.B.E.W. Local #1245.

Because Raven 's system is non-combustion with minimal emissions, they will actually be reducing methane and short-lived climate pollutants from the landfill, and there will be a positive reduction in greenhouse gases. This is such a positive aspect to improving the air around the Richmond area.

California has taken a leadership role in the nation for launching the hydrogen economy , and Richmond has the opportunity with Raven SR to lead the advancement of clean fuels production , emissions reduction, and reversing climate change in the East Bay region.

Thank you for your consideration and we respectfully request you approve Raven SR's CUP application and the CEQA MND so they may begin construction this year and start production in early 2023. sQJ
~ :I Santiago
CEO & President
Benicia Fabrication & Machine , Inc.

RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

45 Response
s to
Letter 13
-

Benicia Fabrication & Machine

13 -
1 The comment is in support of the proposed Project and notes

that the proposed Project will help the City
further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment also opines that the proposed Project’s non -
combustion
sy
stem would reduce methane and short
-
lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is

required to this comment, however, it is
noted and will be made available to City decision
-
makers as they consider the Project and whether or not
to approve it.

________________________

Contra Costa Building and Construction Trades Council
2727 Alhambra Ave. Suite 5
Martinez, CA 94553
FAX (925) 372-7414
October 17, 2022
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Ms. Elias,
Bill Whitney
C.E.O.

Phone (925)228-0900
On behalf of the Contra Costa Building & Construction Trades Council we are writing in support of Raven SR's Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service's West Contra Costa County Sanitary Landfill.

Raven SR is poised to place the City of Richmond front and center in the production of clean hydrogen fuels not only in the Bay Area, but in the State of California. We have the opportunity to showcase a new hydrogen production technology that will revolutionize waste-to-hydrogen production. No longer will we be dependent on our hydrogen being shipped in from out of state, and we will ensure energy security for the owners of commercial and passenger hydrogen vehicles.

In addition to providing clean hydrogen fuel to our community, Raven will also help the City further divert waste from landfills to meet California's SB 1383's goal of reducing organic waste disposal by 75% from 2014 levels (up to 27 M tons of organic waste) by 2025.

Because Raven's system is non-combustion with minimal emissions, the company will actually be reducing methane and short-lived climate pollutants from the landfill, and we will see a positive reduction in greenhouse gases in our community. Clearly this project advances the production of clean fuels, as well as reducing emissions, and a crucial step in reversing climate change.

This project will be built with a PLA which means middle class, skilled and trained Union jobs. Local hire, apprenticeship training, and a veteran hire program are additional community benefits of the PLA.

We respectfully request that you approve Raven SR's CUP application and the CEQA MND so they may begin construction this year, which creates jobs for our Union workers, and starts the production of clean hydrogen as early as 2023.

Sincerely,
"v/)J_____/4,
William Whitney

RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

47 Response
s to
Letter 14
-

Contra Costa Construction and Building Trad
es
Council

14 -
1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1
383). The comment also opines that the proposed Project’s non -
combustion
system would reduce methane and short
-
lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis
contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision
-
makers as they consider the Project and whether or not
to approve it.

__________________
______

♦ WATLOW.

October 14, 2022
Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Lydia,
I am writing to provide Watlow ' s support of Raven SR's Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service 's West Contra Costa County Sanitary Landfill.

Raven SR has developed a new hydrogen production technology that will revolutionize waste-to-hydrogen production, and Watlow has been a proud technology partner providing our thermal expertise, engineering assistance and partnership towards this exciting and promising new technology .

We commend Richmond's vision and leadership becoming the first location to implement Raven's SR2 Reformer, representing the opportunity to receive both recognition and attention by the State of California and Department of Energy related to their desire to promote the hydrogen economy.

Watlow remains committed to Raven's efforts and we share a passion for providing leading products and solutions contributing to the advancement of clean fuels production, emissions reduction and energy transition.

Thank you for your consideration and we respectfully request that you approve Raven SR's CUP application and the CEQA MND so they may begin construction this year and start production in early 2023.

Please let me know if Watlow can be of any further assistance to you on your decision process.

Sincerely,
Dr. Ashish Bhatnagar
Chief Technology Officer
Watlow
12001 Lackland Road • St. Louis, M issouri 63146 USA
Phone: 314-878-4600 • www .watlow .com

RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

49 Response
s to
Letter 15
-

Watlow

15 -
1 The comment is in support of the proposed Project and does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted a
nd will be made available to City decision
-
makers as they consider the Project and whether or not
to approve it.

________________________

IRON WORKERS LOCAL 378

UNION OFFICE OF BRIDGE, STRUCTURAL, ORNAMENTAL AND REINFORCING 3120 Bayshore Road, Benicia CA 94510 | www.ironworkers378.org P. (707) 746-6100 | F. (707) 746-0979
Jason

October 13, 2022

Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804

Dear Mrs. Elias,

On behalf of the Iron Workers Local 378, we are writing in support of Raven SR’s Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service’s West Contra Costa County Sanitary Landfill.

Raven SR is poised to place the City of Richmond front and center in the production of clean hydrogen fuels not only in the Bay Area, but in the State of California. We have the opportunity to showcase a new hydrogen production technology that will revolutionize waste - to-hydrogen production. No longer will we be dependent on our hydrogen being shipped in from out of state, and we will ensure energy security for the owners of commercial and passenger hydrogen vehicles. It may even generate additional drivers coming to our community to fuel their cars, increasing our retail and gas revenues.

In addition to providing clean hydrogen fuel to our community, Raven will also help the City further divert waste from landfills to meet California’s SB 1383’s goal of reducing organic waste disposal by 75% from 2014 levels (up to 27 M tons of organic waste) by 2025. In an era when disadvantage communities are pleading for improvements, Raven SR is providing us solutions. Because Raven’s system is non-combustion with minimal emissions, the company will actually be reducing methane and short-lived climate pollutants from the landfill, and we will see a positive reduction in greenhouse gases in our community. It is a win-win all the way around! California has taken a leadership role in the nation for launching the hydrogen economy, and Richmond has the opportunity with Raven SR to take our place in the advancement of clean fuels production, emissions reduction, and reversing climate change.

Thank you for your consideration and we respectfully request that you approve Raven SR’s CUP application and the CEQA MND so they may begin construction this year, creating jobs for our Union Iron Workers, and start production of clean hydrogen in early 2023.

Best Regards,

Jason Gallia
Business Manager
Financial Secretary/Treasurer

JG:ym
opeiu-29/afl-cio

Jason Gallia
Business
Manager/Financial
Secretary-Treasurer

Jason Lindsey
President/Business
Agent

James Ashcroft
Business Agent

Ken Miller
Business Agent/
Organizer

RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

51 Response
s to
Letter 16
-

Iron Workers Local 378

16 -
1 The comment is in support of the proposed Project and notes that

the proposed Project will help the City
further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment also opines that the proposed Project’s non -
combustion
system
would reduce methane and short
-
lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is requ ired to this comment, however, it is
noted and will be made available to City decision
-
makers as they consider the Project and whether or not
to approve it.

________________________

Local Union No. 302

INTERNATIONAL BROTHERHOOD OF ELECTRICAL WORKERS
REGULAR MEET ING 4TH WEDS . EACH MONTH EXECUTIVE BOARD MEETS 3RD WEDS . EACH MONTH 1875 ARNOLD DRIVE MARTINEZ, CALIFORNIA 94553-4239
October 13, 2022
Lydia Elias
City of Richmond
TELEPHONE (925) 228-2302 • FAX (925) 228-0764
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804
Dear Ms. Elias,
On behalf of the Members of IBEW Local 302 we are writing in support of Raven SR's Conditional Use Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service's West Contra Costa County Sanitary Landfill.

Sincerely,
Tom Hansen
Business Manager
Financial Secretary
TH:nlp
OPEIU#29:afl-cio

RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

53 Response
s to
Letter 17
-

Local Union No. 302 International Brotherhood
of

Electrical Workers

17 -
1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (Califor
nia’s SB 1383). The comment also opines that the proposed Project’s non -
combustion
system would reduce methane and short
-
lived climate pollutants from the landfill, and thus positive reduction in greenhouse gas emission. The comment does not address the ad equacy of the analysis
contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available to City decision
-
makers as they consider the Project and whether or not
to approve it.

________
________________

October 10, 2022

Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804

Dear Lydia,

I am writing in support of Raven SR’s Conditional U se Permit (CUP) application and CEQA Mitigated Negative Declaration (MND) for the construction and operation of a bioenergy facility at Republic Service’s West Contra Costa County Sanitary Landfill.

Raven SR is providing the City of Richmond the oppo rtunity to showcase a new hydrogen production technology that will revolutionize waste -to-hydrogen production. In addition to providing clean hydrogen fuel to the Richmond commu nity, Raven will also help the City of Richmond further divert waste from landfills to mee t California’s SB 1383’s goal of reducing organic waste disposal by 75% from 2014 levels (up to 27 M tons of organic waste) by 2025.

California has taken a leadership role in the natio n for launching the hydrogen economy, and Richmond has the opportunity with Raven SR to support the advancement of clean fuel production, emissions reduction, and reversing climate change.

Thank you for your consideration, and I respectfull y ask that you approve Raven SR’s CUP application and the CEQA MND so they may begin construction this year and start production in early 2023.

Sincerely,

/s/ Nicholas Connell

Nicholas Connell
Policy Director
Green Hydrogen Coalition
Tel: 949-558-1305
Email:
[email protected]

RESPONSE TO COMMENTS Received on the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

55 Response
s to
Letter 18
-

Green Hydrogen Coalition

18 -
1 The comment is in support of the proposed Project and notes that the proposed Project will help the City further divert waste from landfills to meet the State’s goal of reducing organi c waste disposal for target
year 2025 (California’s SB 1383). The comment does not address the adequacy of the analysis contained in the IS/MND. No additional analysis or response is required to this comment, however, it is noted and will be made available

to City decision
-
makers as they consider the Project and whether or not to approve it.

________________________

October 10, 2022

Lydia Elias
City of Richmond
Community Development Department
450 Civic Center Plaza, PO Box 4046
Richmond, CA 94804

Dear Lydia,

Raven SR is providing the City of Richmond the opportunity to showcase a new hydrogen production technology that will revolutionize waste‐to‐hydrogen production. In addition to providing clean hydrogen fuel to our community, Raven will also help the City further divert waste from landfills to meet California’s SB 1383’s goal of reducing organic waste disposal by 75% from 2014 levels (up to 27 M tons of organic waste) by 2025.

I believe that because Raven’s system is non‐combustion with minimal emissions, the company will actually be reducing methane and short‐lived climate pollutants from the landfill, and we will see a positive reduction in greenhouse gases in our community. For once, a company that is trying to improve our environment!

Another plus is that Raven has signed a Project Labor Agreement with the Contra Costa Building & Construction Trades Council and theI.B.E.W. Local #1245. The jobs that Raven SR will be generating for our community, in addition to the construction jobs to build the plant, are to be commended. Jobs in Benicia will also be impacted with Benicia Fabrication, a subsidiary company, that is building the reforming units for the project. Benicia Fabrication is located in the Industrial Park of Benicia and founded in 1983. It specializes in the repair, maintenance and new construction of pressure vessels, heat exchangers and miscellaneous industrial equipment.

California has taken a leadership role in the nation for launching the hydrogen economy, and Richmond has the opportunity with Raven SR to take our place in the advancement of clean fuels production, emissions reduction, and reversing climate change.

Thank you for your consideration and I respectfully ask that you approve Raven SR’s CUPapplication and the CEQAMNDso they may begin construction this year and start production in early 2023.

Sincerely,

Christina Strawbridge

RESPONSE TO COMMENTS Received on

the Raven SR Bioenergy Project Initial Study / Mitigated Negative Declaration

58 Response
s to
Letter 19
-

Christina Strawbridge

19 -
1 The comment is in support of the proposed Project and notes that the proposed

Project will help the City
further divert waste from landfills to meet the State’s goal of reducing organic waste disposal for target year 2025 (California’s SB 1383). The comment does not address the adequacy of the analysis contained in the IS/MND. No a
dditional analysis or response is required to this comment, however, it is noted and will be made available to City decision
-
makers as they consider the Project and whether or not to approve it.

________________________

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A
PP
-

ATTACHMENT A

Final
Mitigation Monitoring and Reporting
Program (MMRP)

(Update to IS/MND Appendix C)

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Raven SR Bioenergy Project

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FINA

L UPDATED

MITIGATION MONITORIN

G AND REPORTING PROG
RAM

Project Mitigation Measures

Implement
ed
By

Monitored By

Monitoring and Reporting
Action

Monitoring
Schedule

Verification of

Compliance

4.1 Aesthetics
–

None Required

4.2 Agriculture and Forestry Resources
–

None Required

4.3 Air Quality

(
Expanded
)

Mitigation Measure AQ
-
1: Best Management
Practices.



All subsequent projects, regardless of size, 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, so
il 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 ma
ximum
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.

P
roject Applicant /
Construction
Contractor

Richmond
Building Division
and Engineering
Services
Department

Richmond
Engineering Services
Department to verify inclusion of
BAAQMD BMPs in applicable
construction plans

and specifications.

City of Richmond Building Division to
inspect site during construc
tion to
ensure compliance with P
roject
construction plans.

Prior to issuance of
building

permit.

Field inspections
during construction.

Verified by:

Date:

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al

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

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 leavin
g 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.



Additional BMP: Limit the simultaneous occurrence of
e
xcavation, g
rading, 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 cons
truction 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 gener
ating operations
have to be shut down due to dust crossing the property
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boundary or if dust is contained within the property
boundary but not controlled after a specified number of minutes.



4.4 Biological Resources

Mitigation Measure BIO
-
1: Avoid and Minimize Impacts to
Nesting Birds, Except Rails.

To the extent practicable, project 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
.

Project Applicant
/ Construction
Contractor

Qualified Biologist

Richmond
Building Division
and
Planning
Division

City of Richmond

Building Division to
ensure construction activities are
performed between February 1st and
August 31st.

Prior to
any site
alterations or
issuance of building
permit.

Field inspections
during construction.

Verified by:

Date:

I
f 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 cale
ndar 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, no
-
disturbance buffer z
ones 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 adjus
ted 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
mo
nitor 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 aband
oned. If active
burrowing owl dens are found within the survey area, the project applicant shall implement measures at least equal to the 2012 (or Project Appl
icant
/ Construction
Contractor

Qualified Biologist

Richmond
Building Division

City of Richmond Planning Division to
receive and confirm survey report.

Fiel
d inspections
during construction.

Upon completion of
surveys.

Verified by:

Date:

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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



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.

Project Applicant
/ Construction
Contractor

Qualified Biologist

Richmond
Building Division
and
Planning
Division

City of Richmond Building Division to
ensure construction activities are
performed between February 1st and
August 31st.

Field inspections
during construction.

Verified by:

Date:



Survey methods for rail
s

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.



Qualified Biologist

Richmond
Building Division

City of Richmond Building Division to
confirm
surveys are conducted
pursuant to
specified measures.

City of Richmond Planning Division to
receive and confirm survey report.

Field inspections
during construction.

Upon completion of
surveys.

Verified by:

Date:

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March 1 to March 25. Surv
eys 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 surv
eys.





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 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 impac
t cannot
be avoided during the rail nesting season, activities
would be delayed until after the nesting season.

Project Applicant
/ Construction
Contractor

Qualified Biologist

Richmond
Building Division

City of Richmond Building Division to
ensure
construction activities are
performed between February 1st and
August 31st
, based on agency
coordination

per this measure
.

City of Richmond Planning Division to
verify agency coordination and
outcome.

Field inspections
during construction.

Upon completio
n of
surveys.

Verified by:

Date:

4.5 Cultural Resources

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.

Qualified
Archaeologist

Richmond
Building D
ivision

City of Richmond
Building Division

to
review and confirm documentation of
training, required personnel attending,
and scope of training.

Prior to
commencement of
any ground
-
disturbing
activities.

Verified by:

Date:

Fin
al

U
pdated
M
itigation Monitoring and Reporting Program

Raven SR Bioenergy Project

A
-
6 ESA

/ D202100382

N
ovember

30, 2022

Project Mitigation Measures

Implement
ed
By

Monitored By

Monitoring and Reporting
Action

Monitoring
Schedule

Verification of

Compliance

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 contracto
r shall notify the City.

The City shall notify a qualified archaeologist who will inspect the find within 24

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

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

21084.3).

Project Applicant /
Construction
Contractor

Qualified
Archaeologist

If applicable,
Native American
representative

Richmond
Building Division to review
and approve of archaeologist, of
cultural resources monitoring plan and
of the construction plan that includes
archaeologic
al mitigation.

If resources are encountered,
Contractor to verify work is suspended
as required, review and approve
qualified archaeologist and
recommendations.

If resources encountered are found to
be qualifying as described in the
measure, the City to en
sure
preservation measures are
implemented or that the ARDTP is
completed and submitted to NWIC.

City to inspect site during construction
to ensure compliance with project
construction plans.

Prior to issuance of
building permit for, or
commencement of,
a
ny ground
-
disturbing
activities.

Field inspections
during construction.

Verified by:

Date:

Final
Updated
Mitigation

Monitoring and Reporting Program

Raven SR Bioenergy Project

A
-
7 ESA

/ D202100382

N
ovember

30, 2022

Project Mitigation Measures

Implement
ed
By

Monitored By

Monitoring and Reporting
Action

Monitoring
Schedule

Verification of

Compliance

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

Project Applicant /
Construction
Contractor

Qualified
Archaeologist

Richmond Building Division verify
mitigation measure on construction
plans.

Inspect site during
construction to
ensure compliance with project
construction plans.

If needed, engage County Coroner
and ensure NAHC contact.

Prior to issuance of a
building permit for, or
commencement of,
any ground
-
disturbing
activities.

Field inspections
during const
ruction
.

Verified by:

Date:

4.6 Energy
–

None Required

4.7 Geology, Soils, and Mineral Resources
-

MM CUL
-
1a, CUL
-
1b, CUL
-
2 (see 4.5, Cultural Resources)

4.8 Greenhouse Gas Emissions
–

None Required

4.9 Hazards and Hazardous Materials
–

None Required

4.10 Hydrology and Water Quality
–

None Required

4.11 Land Use and Planning
–

None Required

4.12 Noise / Vibration
–

None Required

4.13 Population and Housing
–

None Required

4.14 Public Services and Recreation
–

None Required

4.15 Transportation
–

None Required

4.16 Tribal Cultural Resources
-

MM CUL
-
1a, CUL
-
1b, CUL
-
2 (see 4.5, Cultural Resources)

4.17 Utilities and Service Systems
–

None Required

4.18 Wildfire
–

None Required

ERRATA SHEET #1

Raven SR Bioenergy Project

Updated
Initial Study
/ Mitigated Negative
Declaration

Raven SR Bioenergy Project

1 ESA

/
D202100382

ERRATA SHEET #1 to the Updated Initial Study MND

March 14, 2023

The following clarifications are made to the Updated Initial Study / Mitigated Negative Declaration published March 9, 2023:

Page
12 , Footnote 9:

Single
-
underline changed to double
-
underline and added to footnote
number
, as follows:

_____________________________

9 To be clear, the proposed project is a separate and independent project from other possible hydrogen
-
related projects within the City t
hat 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 seek
ing 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 proces
s 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 manufac
turing 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 subs
equent/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 project
s
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 proje
ct’s initial study
–

assuming that the type of project impacts overlap for the purposes of a cumulative analysis.

Page
21 ,
Second paragraph
:

D
ouble
-
underline added to
full paragraph
, as follows:

While the Raven SR technology can use a variety of potentia l 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

then

conditioned, compressed and

processed

through

purification systems to produce
hydrogen product: transportation
-
grade (compliant with SAE J2719) hydrogen.

11 ERRATA SHEET #1

Raven SR Bioenergy Project

2 ESA

/
D202100382

ERRATA SHEET #1 to the Updated Initial Study MND

March 14, 2023

Page
21 ,
Footnote 11:

D
ouble
-
underline added to
full paragraph
, as follows:

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 contamin ate downstream catalyst/media,
deactivating it, significantly reducing performance in downstream processing.

Page
26 ,
Third full paragraph:

D
ouble
-
underline
added
, as follows:

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 alar
m 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.

Page
27 ,
First full paragraph:

D
ouble
-
underline
added
(shown highlighted), as follows:

Safety Standards

and Maintenance
.

Raven SR units
are equipped
The
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.

Page
33:

D
ouble
-
underline
added to selected “Biological Resources” fac
tor
, as follows:

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

Air Quality

Biological Resources

Cultural Resources

Energy

Geology, Soils and S
eismicity

Greenhouse Gas Emissions

Hazards
/
Hazardous Materials

Hydrology and Water Quality

Land Use and Planning

Mineral Resources

Noise
/Vibration

Population and Housing

Public Services

Recreation

Transportation

Tribal Cultural Resources

Utilities and Service Systems

Wildfire

Mandatory Findings of Significance

ERRATA SHEET #1

Raven SR Bioenergy Project

3 ESA

/
D202100382

ERRATA SHEET #1 to the Updated Initial Study MND

March 14, 2023

Page
47 ,
Table 4.3
-
1 :

Replacement note (shown
highlighted
).

T
ABLE

4 .3
-
1 A
VERAGE
D
AILY
C

ONSTRUCTION
-

RELATED
C

RITERIA
P

OLLUTANT
E

MISSIONS

(

TONS PER YEAR

POUNDS PER DAY
)

W
ITHOUT
M

ITIGATION

Project Average Daily
Construction Emissions by
Year

ROG

NO
x

Exhaust PM
10 Exhaust PM

2.5 2022
2023

3.33 0.11

16.67 1.00

0.77 0.04

0.70 0.04

2023
2024

0.13 0.06

1.14 0.48

0.05 0.02

0.04 0.02

BAAQMD Threshold for Significant
Construction Impacts

10 54

15 82

10 54

Potential Significant Impact?

NOTES: Construction emissions were revised to account for the one -
year construction schedule delay.

The applicable BAAQMD significance thresholds for pounds -
per
-
day are now shown.

SOURCE:

ESA
Ramboll

(Appendix A to this
document
checklist
)

Page
47 ,
Third

full paragraph
:

Omitted deletion shown as strike
d
-
out
, as follows:

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, bisu
lfite 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 .

Page
48 ,
Second full paragraph
:

New i
nserted text
(highlighted)
regarding Table 4.3
-
3 ,

and
correction to show deletion r
egarding Table 4.3
-
4 , as follows:

Operational
-
related
mobile source
activities, such as
employee commuting, truck trips for
delivery and materials hauling
, use of landscape equipment,
and other sources w
ould
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 equ
ipment, 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
-
3 shows the anticipated
emissions from auxiliary operatio
ns that are not the permitted sources
.

Table 4.3
-
4 shows
the emissions from operational emission sources that are not part of the air permit application.

ERRATA SHEET #1

Raven SR Bioenergy Project

4 ESA

/
D202100382

ERRATA SHEET #1 to the Updated Initial Study MND

March 14, 2023

Page
48 ,
Table 4.3
-
2:

Previously
-
omitted numerals highlighted and double striked
-
out.

T
ABLE

4 .3
-
2 P
ROCESS
O

PERATIONS

A
IR
P
ERMIT
A

PPLICATION
'
S

A
VERAGE
A
NNUAL
O

PERATIONAL
C

RITERIA
P

OLLUTANT
E

MISSIONS

(

TONS PER YEAR
)

Project Operations
Emissions by Source

NO
x

VOC/ROG

SO
2 PM
10 PM

2.5 Biogas engines

50.69 7.19

5. 70

6 .83

6.63 5.13

5.13 Green waste off
gas

N/A

2.38 N/A

N/A

Fugitive component leaks

N/A

0.63 N/A

N/A

Lime
stone

handling

N/A

0.003

0.0005

Lime
stone

storage

N/A

0.016

0.0024

Flare

0.0 92

0.16 0.00
98 0.000
2 0.00
86 0.00
86 Fire pump engine

0.0 55

0.04 0.00
22 0.0000
9 0.003
3 0.003
3 Total

50. 84

7.39 8.72

7.47 6.64

5.1 6

5.1 4

Page
49 ,
Table 4.3
-
4:

Values corrected

(shown highlighted), as follows:

T
ABLE

4.3 -
4 A
VERAGE
A
NNUAL
O

PERATIONAL
-

RELATED
C

RITERIA
P

OLLUTANT
E

MISSIONS

(

TONS PER YEAR
)

Project
Operations

Emissions

NO
x

VOC/ROG

Exhaust

PM
10 Exhaust
PM

2.5 Air Permit
Process Operations

7.39 7.47

8.72 5.1
6 5.1
4 CalEEMod
Auxiliary Operations

3.75 1.66

0.18 0.47

0.35 0.05

0.13 0.05

Reduction in Flared Landfill Gas

8.71 -

0.10 -

3.35 -

3.35 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?

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
document
checklist
)
and Ramboll Permit Application (Raven, 2022a)

Page 53 ends

Richmond City CouncilMay 16, 2023

Richmond City Council
May 16, 2023