Cities Index.
Attachment 1 - Exhibit B - Updated ISMND.pdf

Richmond City Council
May 16, 2023

Document
Attachment 1 - Exhibit B - Updated ISMND.pdf
Meeting
May 16, 2023
Body
Richmond City Council
Pages
53
Original file
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Text extracted from the city's file for reading and search. Open the original on pub-richmond.escribemeetings.com. That file is the official record.

Raven SR Bioenergy Project

i

ESA

/
D202100382

Updated Initial Study

March 9
, 2023

TABLE OF CONTENTS

Raven SR Bioenergy Project

Updated

Initial Study
/ Mitigat
ed Negative

Decla
ration

Page

1. General Project Information

and Overview

................................
................................
..

1 1.1

Project Title

................................
................................
................................
..............

1 1.
2 Lead Agency Name and Address

................................
................................
............

1 1.3

Project Case File Number

................................
................................
........................

1 1.4

C
ontact Person and Phone Number

................................
................................
........

1 1.5

Project
Location

................................
................................
................................
.......

1 1.6

Projec
t Applicant’s Name and Address

................................
................................
...

2 1.7

Existing General Plan
and Zoning
Designation

................................
.......................

2 1.
8 Purpose and Intended Use of this Document

................................
.........................

2 1.
9 Project Overview

................................
................................
................................
......

8 1.1
0 Environmental Setting

................................
................................
..............................

8 1.11

Required Discretionary Approvals

................................
................................
...........

9 1.1
2 Other

Public Agencies Whose Approval is Required

................................
..............

9 1.1
3 California Native American Tribes Consultation

................................
......................

9 2
.

Project Description

................................
................................
................................
........

1 0

2 .1

P
roject Purpose

................................
................................
................................
......

1 0

2 .
2 Existing
Site

Conditions and Ownership

................................
................................

12 2
.
3 Surrounding Uses and Conditions

................................
................................
.........

12 2
.
4 Site Plan and
Structures

................................
................................
........................

16 2
.
5 Technology

................................
................................
................................
.............

2 1

2 .
6 Operations

................................
................................
................................
..............

2 4

2. 7

Employment

................................
................................
................................
...........

31 2.
8 Transportation and Circulation

................................
................................
...............

31 2.
9 Construction
,

Site Coverage

and Drainage

................................
...........................

3 1

2. 10

Off
-
site Improvements: Landscaping

................................
................................
.....

32 3.

Environmental Factors Potentially Affected

................................
..............................

3 3

4 .

Environmental Checklist

and Analysi
s

................................
................................
.......

35 4.1

Aesthetics

................................
................................
................................
...............

35 4.
2 Agriculture and
Forestry Resources

................................
................................
......

4 1

4. 3

A
ir
Quality

................................
................................
................................
...............

45 4.4

Biological Resources

................................
................................
..............................

60 4.5

Cultural

Res
ources

................................
................................
................................
.

7 1

4.6 Energy

................................
................................
................................
....................

7 5

4. 7

Geology, Soils and Mineral Resources

................................
................................
..

7 9

4. 8

Greenhouse Gas Emissions

................................
................................
..................

8 2

4.9 Hazards and Hazardous Ma
terials
................................
................................
.........

9 5

Table of Contents

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4. 10

Hydrology and Water Quality

................................
................................
...............

1 03

4.1 1

Land Use and Planning

................................
................................
........................

1 0
9 4.1
2 Noise

and Vibration

................................
................................
..............................

1 11

4.1 3

Population

and
Housing

................................
................................
.......................

1 17

4.1 4

Public Services

and Recreation

................................
................................
...........

1 19

4.1 5

Transportation

................................
................................
................................
......

1 2
1 4.1
6 Tribal Cultural Resources
................................
................................
.....................

1 27

4.17 Utilities and Servi
ce Systems

................................
................................
...............

1 2
9 4.1
8 Wildfire

................................
................................
................................
.................

1 33

4.1 9

Mandatory Findings of Significance

................................
................................
.....

1 35

5 .

Document
Preparers

................................
................................
................................
...

1 39

List of Figures

1 -
1 Regional Context

................................
................................
................................
.......

4 1
-
2 Local Context
–

North Richmond

................................
................................
..............

5 1
-
3 Project Site and Surrounding
Landfill
Context

................................
..........................

6 2
-
0 Birdseye View of P
roject Site

................................
................................
..................

14 2
-
1 Project Site

and Raven SR Facility Areas

................................
...............................

1 5

2 -
2 Simulated

3D Site Development
................................
................................
..............

17 2
-
3 a

South Elevation (
West E
nd)

................................
................................
....................

18 2
-
3 b

South Elevation (
E
ast
E
nd)

................................
................................
.....................

1 9

2 -
4 Detailed Site Layout and
Raven SR
Facility Plan

................................
...................

20 2
-
5 Raven SR Process Diag
ram

................................
................................
...................

22 4.1
-
1 Wildcat Marsh Trail Approach Toward Project Site (from E ast
)

.............................

3 7

4.1 -
2 Onsite View toward Project Site

................................
................................
.............

3 9

List of Tables

4 .3
-
1 Average Daily Construction
-
related Criteria Pollutant Emissions (pounds
per day) Without Mitigation

................................
................................
...................

4 7

4.3 -
2 Pr
ocess Operations
Air Permit Application's
Average Annual Operational
Criteria Pollutant Emissions (tons
per year)

................................
.........................

48 4.3
-
3 Auxiliary Operations
CalEEMod

Average Daily Operational
-
Related
Criteria Pollutant Emissions (
pounds
tons

per day)

................................
..............

4 9

4.3 -
4 Average Ann
ual Operational
-
Related Criteria Pollutant Emissions (tons
per year)

................................
................................
................................
...............

4 9

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

................................
................................
................................
.................

50 4.3
-
6 Health Risk Impacts at the Maximum Exposed Sensitive Receptors)

....................

53 4.3
-
7 Cumulative Health Ri
sk Impacts at the Maximum Exposed Sensitive
Receptors)

................................
................................
................................
............

56 4.8
-
1 BAAQMD GHG Thresholds of Significance

................................
............................

8 5

4.8 -
2 Annual Construction
-
Related Greenhouse Gas Emissions

................................
....

8 6

4.8 -
3 Unmitigated Annual Operational Greenhouse Gas Emissions

..............................

8 8

4.12 -
1 Localized Road
way Traffic Noise

................................
................................
..........

10 8

4.12 -
2 Construction Equipment Noise Levels

................................
................................
..

10 9

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

................................
................................
..........................

1 11

4.15 -
1 Project Daily Trip Generation Summary

................................
................................

1 18

4.15 -
2 Project VMT Summary
................................
................................
...........................

12 0

1. General Project Information

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Appendix

A

Emissions Data, Assumptions and Modeling Files

................................
................

A
-
1 A.1
-
1 Original Emissions Data, Assumptions and Modeling Files

...............

A.1
-
1 A.2
-
1 Updated Air Quality and Greenhouse Gas Assessment
Technical Memo

................................
................................
..............

A.2
-
1 A.2
-
2 Updated Air Quality and New Health Risk Assessment
Technical Memo

................................
................................
..............

A.2
-
2 B

Special Status Species Lists

................................
................................
.................

B
-
1 C

Updated
Draft
Mitigation Monitoring and Reporting Program (MMRP)

................

C
-
1 D

Response to Comments
Received on the Raven SR Bioenergy Project
Initial Study / Mitigated Negative Declaration (November, 11,

2022)

...............

D
-
1 1. General Project Information

Raven SR Bioenergy Project

1 ESA

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Updated Initial Study MND

March
9 , 2023

1. General Project Information

1.1 Project Title

Raven SR Bioenergy Project

1.2 Lead Agency Name and Address

City

o
f Richmond

(City)

Community Development

Department

450 Civic Center Plaza

PO Box 4046

Richmond, CA 94804
-
1630

1.3 Project Case File Number

City
Project Case Number:

PLN21
-
282

1.4 Contact Person and Phone Number

Lina Velasco, Director of Community Development

Community Development Department

[email protected]

(510) 620
-
6841

1.5 Pr
o
j
e
c
t L
o
c
a
t
i
on

1 Parr Boulevard, Richmond, California

(general
ly)
.

The proposed

Raven SR P
roject 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, t
he projec
t

would

occur
within
approximately

2.5 acres
of

the existing
Republic Services
Bulk Materials Processing Center
(BMPC)
within “Area A”
of the WCCSL
.
1 ,
2 T
he 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 acce
ss/egress road located within the County
.

The project site is located
within

Assessor’s Parcel Number (APN)
408
-
140
-
009
.

1 Actual project operations will occur on a subset area of approximately 1.3 acres that Raven SR will lease from BMPC.

2 “Area A” of the WCCSL is approximately 12 acres in the upland portion of the property that e ncompasses p
ollution
control facilities and stockpile areas (separate from
the
closed
Class I and active Class II
landfill areas,
the
runoff
ponds
or lagoons delineated as “
Area B
”
, and tidal waters

delineated as “
Area C
”
).

Shown in
Figure 3
-
1, Vicinity
Ma
p, of the

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

1. General Project Informati
on

Raven SR Bioenergy Project

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See
Figure 1
-
1, Regional Context
;
Figure 1
-
2, Local Context
–

North Richmond
; and
Figure
1 -
3, Project Site and
Surrounding

Landfill Se
tting
, on the following pages.

1.6 Project Applicant’s Name and Address

Raven SR

S1
,
LLC

3 Matt W. Murdock CEO

PO Box 1360

Pinedale, WY 82941

1.7 Existing General Plan and Zoning Designations

The project site and surrounding area is located within the

Richmond’s

“
Open Space” General
Plan land use designation and
Richmond’s

“Open Space” zoning district.

1.8 Purpose and Intended Use of this Document

The purpose of this Draft Initial Study/Mitigated Negative Declaration (IS/MND) is to identify any potential environmental
impacts that would result from implementation of the proposed project pursuant to California Environmental Quality Act (CEQA) Guidelines.

As the project site
is wholly located within the City limits, t
he City
of Richmond
has discretionary authority over th
e
proposed project and is the
lead agency

in the preparation of this
Draft
IS/MND. The intended
use of this document is
to

disclose the potential environmental impacts and mitigation measures, if any,

and to provide the basis for input from public agencies , organizations, and interested
members of the public.

Extensive prior CEQA analyses have been conducted for the WCCSL site over the last three decades. Solid waste disposal operations at the WCCSL began in 1952, prior to implementation of CEQA. Over the y
ears, operational changes have occurred as new regulations, permits, and recycling operations have been implemented. Currently, solid waste management facilities at the WCCSL include a closed Class II municipal solid waste landfill, a Waste Shuttle Facilit y, and the
BMPC. The BMPC was originally analyzed under CEQA in the early 1990’s. The City of Richmond issued a conditional use permit (CUP), and Contra Costa County issued a Land Use Permit (LUP) for the facility. In the early 2000s, in response to Republ ic Services’ request, the
City and County approved amendments to the use permits to allow expanded and additional waste streams for the BMPC. An EIR was prepared and certified by Contra Costa County

in 200
4 to
address the additional and expanded waste stre
ams.
4 This CEQA document is a stand
-
alone analysis for the proposed
Raven SR

p
roject.

Where
appropriate and suitable, setting and context information from prior CEQA documents certified for the
WCCSL
/
BMPC facility
and operations is used in parts of this D
raft IS/MND
to describe

3 The
P
p
roject

A
a
pplicant
is referred to throughout as “Raven SR”. “Raven SR” also refers to

the multi
-
patented
process/system.

“Raven” refers to the proposed facility.

4 Environmental Impact Report for the WCCSL Bulk Materials Processing Center and Related Actions , State
Clearinghouse No. 2002102057, June 2004.

1. General Project Information

Raven SR Bioenergy Project

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the existing setting and baseline conditions
,

given that the project site is
located
within the
WCCSL/BMPC facility.
5 However, no part of the proposed project affects existing WCCSL/BMPC operations; the proposed development and Rave n SR system is a wholly
independent utility, except that it
would

use feedstock available from the current
onsite
composting facility referred to as the
West Contra Costa Sanitary Landfill Organic Materials
Processing Facility (OMPF)
BMPC

operation
. Mitigat
ion measures identified in this document
will apply solely to the proposed project and do not conflict with any applicable mitigation measures identified in the previously certified WCCSL/BMPC CEQA documents. Similarly, and addressed separately from this C
EQA document, the proposed project requires approval of a City of Richmond
Conditional Use Permit

(see Section 1.11, below), which is wholly independent
from the existing City Conditional Use Permit (
CU 1101132

as amended
)
and Contra Costa
County Land Use
Permit (LUP 2054
-
92 as amended) for the WCCSL/BMPC, as well as any
existing permits, control

5 Environmental Impact Report on t
he West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions
,
June 2004
; and
Addendum to the

Final

EIR

for the WCCSL BMPC and Related Actions
, 2009
.

SCH. 2002102057.

Figure 1-1
Regional Context
Raven SR Bioenergy Project Initial StudySOURCE: Raven LLC, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator r ESA
~
Figure 1-2
Local Context - North Richmond
Raven SR Bioenergy Project Initial StudySOURCE: Raven LLC, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator r ESA
~
Raven SR
Facility Location
WCCSL Organics Materials
Processing Facility (OMPF)
West Entrance & Scale Plaza
Parr Blvd
Wildcat Marsh Trail
Golden Bear Transfer Station
West County
Water District
Treatment Plant
WCCSL Organics Materials
Processing Facility (OMPF)
West Entrance & Scale Plaza
Parr Blvd
Wildcat Marsh Trail
Raven SR
Facility Location
Contra Costa County
City of Richmond
Contra Costa County
City of Richmond
Golden Bear Transfer Station
West County
Water District
Treatment Plant
Figure 1-3
Project Site and Surrounding Land/f_ill Context
Raven SR Bioenergy Project Initial StudySOURCE: Raven LLC, 2022; ESA, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator

1. General Project Information

Raven SR Bioenergy Project

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measures or cooperative ag
reements executed by various regulatory agencies that have permitting authority for the WCCSL/BMPC.

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

Approximately 19 written comments were received during this period.

Although not required by
CEQA, the City

the

responded

in writing

to all written comments received on the IS/MND during
the public review period.

The City’s Response to Comments memorandum is included as Appendix
D

to this
document
.

The project

was
then presented to the City’s Planning
Commission, which held a public hearing on December 15, 2022,

to consider
approval of
the
project
by

a
pproval

of the IS/MND and Mitigation Monitoring and Reporting Program (MMRP) and Design Review and Conditional Use P
ermit
, which would allow the project

to construct and
operate a bioenergy facility that converts food and green waste into transportation -
grade
hydrogen for various renewable energy products (
PLN21
-
282
). After consideration of all
evidence before it, inclu
ding public comment
,

both written and oral, the Planning Commission
then approved the project. The approval was then appealed.

Given

the comments provided during the hearing and
in the written
appeal, it appeared that there
were still questions

and concer
ns

from the public and the appellants regarding aspects of the proposed project.

It

became evident that the public would benefit from additional information added to the IS/MND that would clarify, amplify, or otherwise more fully explain the information in

the original IS/MND. For example,

additional description of a greater number of proposed
operational details was requested. Additionally,

although not required as the initial significance
thresholds had not been met, the City required a preparation of a h ealth risk assessment (HRA)
and further assessment of the project impacts on air quality and greenhouse gas

(
s
ee Appendix
A
to this document
)
.

This information, including clarification

of operations and

that the project
would result in better health outcom
es and reduced impacts to air quality, etc., as compared to current operations and landfill flare emissions at the site, ha s

been incorporated into this updated
IS/MND.

This updated IS/MND
has

highlighted these refinements by noting them
in
either as
delet
ions in “
strike through
” and additions in “double underline” (such as this sentence)

to
facilitate review.

Given that

the new information added to the updated IS/MND merely clarifies, amplifies, or otherwise makes insignificant modifications to the origi nal IS/MND
,
recirculation
of the
document
is not required

by CEQA
.

Regardless
, to ensure greater transparency and to make
additional clarifying information available to the public, the City has again recirculated this (now updated) IS/MND for public commen
t. It is anticipated that this updated IS/MND and the
comments received during review, will be considered by the City Council during its consideration of the appeal from the decision of the Planning Commission.

The remainder of this
S
ection
1 provides a
n
overview
of the project
’s

primary
characteristics

and
its
environmental

setting and required
discretionary approvals
.

Section 2

describes the project in
more detail,
Section 3

is the draft environmental declaration, and

Section 4
is the

environmental

1. General Project Informati
on

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check
list that
evaluates

the

potential
environmental
impacts that may result from

construction or
operation of the

proposed
project
.

Section
5 contains the List of Preparers.

1.9 Project Overview

The Raven SR Bioenergy Project (project) proposes to construct and op erate a bioenergy system
composed of the Raven SR multi
-
patented Steam/CO
2 Reformation process at the project site.
6 The
non
-
combust
ion

Raven SR

process
would

convert blended green waste and food waste
,

obtained from the existing
on
site
OMPF

composting
BMP
C

operation
adjacent to
located
approximately

1,100 feet west of

the project site
,

into renewable,
low
-
carbon
,

transportation
grade hydrogen
.

The low
-
carbon hydrogen produced
from renewable feedstock
would be for
off
-
site
use
in trucks and other heavy
-
duty
applications in lieu of petroleum
-
based diesel
.
to the
project will

reduce
emissions of
criteria
pollutant
s

and
produce low
-
carbon hydrogen to reduce
greenhouse gas (GHG) emissions from transportation and other hard -
to
-
abate sources.

The
produced
hydrogen
that

would be exported offsite for various renewable energy products. No long
-
term hydrogen storage would occur onsite.

The Raven SR process would reduce existing flaring of landfill gas (LFG ,

gas
produced from the
decomposition of organic solid wastes in

the
landfill to generate power
.

Raven intends to

produce

the
hydrogen through a process that uses less power consumption per kilogram of hydrogen produced than conventional electrolysis
technologies.
7 The

project would involve the erection of
a modular st
ructure and
industrial
canopy
.

1.10 Environmental Setting

As
shown in Figure 1
-
2, i
ndustrial use and natural waterways create the environment setting of the project site

located within the boundary of the WCCSL facility
.

The

WCCSL facility spans
approximately

3 40 acres

generally between Parr Boulevard and San Pablo Bay, south of San Pablo Creek
. This area is composed of
expansive
planted
disposal areas
/landfill mounds
, runoff
control ponds and lagoons, the organic material processing facility and composting area s
, and the
location of the proposed project (within
part of
the BMPC area), is situated in the southeast area
of the WCCSL facility.

San Pablo Creek

and

the
San

Pablo

and
Wildcat

Creek

tidal
marshlands

exist north and south of the WCCSL facility
.

O
pen wate
r of
San Pablo Bay

is approximately 0.25
miles west from the project site.

Figure 1
-
3 shows t
he closest
structure and
development is the Golden Bear Waste Recycling
Facility
(part of the BMPC)

approximately 300 feet southwest of the proposed project locat
ion
,
and the West
County Wastewater

District Treatment Plant and the Wildcat
Marsh
Trail and trail
head
parking
exist approximately 1,000

feet east of the
project location. The
surrounding uses are
industrial
,

commercial

and open space
; the
nearest
sensiti
ve receptors to the project site are

6 CO
2 is
carbon dioxide.

7 Electrolysis is a process that

uses an electric current to split water molecules into their constituent elements of hydrogen and oxygen.

Hydrogen that is produced through electrolysis using renewable energy sources is known as “green hydrogen”.

1. General Project Information

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residential uses
, an elementary school, and a health clinic, all within approximately 0. 75 to 1.2
miles
southeast in the North Richmond area.

1.11 Required Discretionary Approvals

City of Richmond (Lead Agency)
:

Adoption of
the
CEQA
Documentation, Mitigated
Negative Declaration;

Conditional Use Permit

for

a new activity and facility to convert
organic waste to

hydrogen
8 ; and

various development permits, including but
not limited
to
site preparation, construction and building
activities
.

1.12 Other Agencies
Whose
Review or
Approval Is Required

Bay Area Air Quality Management District (BAAQMD
)
: I
ssuance of an Authority to
Construct (ATC) for the associated air pollutant emissions.

Raven SR has applied for an
ATC

air permit
to be issu
ed by BAAQMD
.

This permit application is currently
undergoing
review.

East
Bay Municipal Utilities District:

Issuance of water
s
upply s
ervice

and approval of
needed
water main extensions and
/or

any
off
-
site pipeline improvements.

West County Wastewater Dis
trict:

Issuance of
wastewater discharge
permit for the
proposed project.

This permitting from the District is pending.

Sta
te Water Resources Control Board
:

Raven SR
would

submit Notices of Intent
(NOI) to the State Water Board.

Raven SR
would

submit t
he Co
nstruction NOI prior to
any grading on the project site obtain coverage under both the statewide General Permit for Discharges of Storm Water Associated with Construction Activity and General Permit for Storm Water Discharges Associat
ed with Industrial Act
ivities. T
he Industrial NOI
would be
submitted prior to operation of the waste conversion system.

State Department of Resource Recovery and Recycling (CalRecycle)

and Local
Enforcement Agency (LEA)
:

Issuance of
Solid Waste Facility Permit (SWFP).

1.13 Californ
ia Native American Tribes Consultation

P
ursuant to Public Resources Code section 21080.3.1
,

on May 4, 2022, the City received a
response for consultation from a representative of the Confederated

Villages of Lisjan.

Consultation occurred on

May 18, 2022,
d
uring which

the tribe
posed

no concerns with the
proposed
project
or potential mitigation measures
as it relates to impacts to tribal cultural
resources and cultural resources. See
Section 4.
16 ,

Tribal Cultural Resources
,
of this checklist for
more detail
.

8 The existing WCCSL facility operates u
nder an existing City of Richmond Conditional Use Permit (CUP) and other resources agency permits.

1. General Project Informati
on

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, 2023

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2. Project Description

Raven SR Bioenergy Project

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9 , 2023

2. Project Description

2.1 Project

Purpose

The
purpose of
Raven SR’s

proposed project

and its non
-
combustion Raven SR process is
to
reduce pollution
,

help reduce greenhouse gas emissions
, and produce

renewable
and green
hydrogen
usi
ng

a low
-
carbon

process
.

This section

introduces each
of these
goal
s
and relevant
characteristics of the proposed project.

Reduce Pollution and GHG Emissions

The project proposes to convert blended green waste and food waste obtained from the existing onsi
te
OMPF

west of
the project site into renewable,
low
-
carbon,
transportation grade hydrogen.

Use of the
low
-
carbon hydrogen as a substitute for petroleum
-
based fuels in heavy
-
duty vehicles
and many other applications,

would reduce the criteria pollutant emi
ssions and GHG emissions
from those vehicles and other applications.

The project would use WCCSL landfill gas that would otherwise be combusted in a flare -

or in
older, inefficient generators
-

in new generators. Existing 1980’s
-
vintage Waukesha (3 x mod
el
7042 gl) landfill gas generators exist on the Republic Services site. These obsolete, aging, hig h
-
emission

generators would be removed from the site and replaced by new, low -
emission

Jenbacher engines (3 x jgs 420 gs
-
l.lc), equipped with
Best Available
Control Technology
(BACT)
. Installation of the new generators for the project would significantly reduce existing emissions that would otherwise occur from continued flaring or the existing, poorly -
controlled
generators.

Produce Low
-
Carbon, Renewable Hydr
ogen

Hydrogen is a key mitigation strategy identified for several sectors by the California Air Resources Board (CARB) in its
2022 Scoping Plan for Achieving Carbon Neutrality

(CARB,
2022
a
). The 2022 Scoping Plan
is the state’s identified scenario for achi
eving carbon neutrality
statewide no later than 2045. The Scoping Plan
“calls for accelerating the transition from
combustion of fossil fuels,” including by increasing the use of renewable and green hydrogen in zero
-
emissions vehicles, heavy
-
duty vehicles,

aviation, ocean
-
going vessels, freight and
passenger rail, and industrial applications. The Scoping Plan calls for increasing the current amount of hydrogen supply about 1,700 times and notes that hydrogen production from gasification of forest or agricul
tural waste is a possible technology to produce low
-
carbon
hydrogen. In support of the Scoping Plan, Senate Bill (SB) 1075 (Skinner, 2022) directs CARB to make recommendations that accelerate progress in green hydrogen production, scaling and use.

To adva
nce the Scoping Plan, Raven SR’s purpose is the conversion of organic feedstock input

to
produce renewable and green hydrogen with a lower carbon intensity than could be produced using electricity from the grid, that would consume less electricity per kilo gram of hydrogen
produced, and do so without using freshwater resources. Aligned with SB 1075, the project’s

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

fueling capacity.
9 2.2

2.1 Existing Site Conditions

and
Ownership

Existing
conditions
of
at

the project site are shown in
Figure 2
-
0, Birdseye View of Project Site

and Surrounding
.

T
he proposed Raven SR
operation
project

would be developed on
approximatel
y 1.3 acres
that Raven
SR
would

lease within
part of
the existing Republic Services

BMPC property

shown in Figure 2
-
0 , however it
would

operate separately from the existing

BMPC
operation
, which
extends west of the project site
.

Figure
2 -
1, Project Site an
d Raven SR
Facility Areas
,

delineates
the proposed

2.5 -
acre
s that is referred to as the “
project site
” and
highlights the 1.3 acres where the
Raven facilities

and operations
would

occur.

The
project site is
relatively flat and
partially paved,
with
the rem
ainder

consisting of

compacted soil and ruderal
groundcover

along the north edge. N
o trees or landscaping exist.

T
he existing landfill power plant and
maintenance building

are
primary
structures
near

the project
site
,

and
both
would

remain. Existing

traile
rs
housing

ancillary
uses
on the site
would be
removed
, and
remnant concrete foundations

from previous
uses

exist on the
north portion of the
site
.

(See Figure 2
-
0).

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

The
existing

owner of the property is West County
Sanitary
Landfill, Inc.
,

a
subsidiar
y

of
Republic Services,
Inc.

Th
e

property ownership
is not proposed to

change
with

the
construction
of the
proposed
p
roject.

2.3 2.2

Surrounding

Uses and Conditions

As highlighted in

Figure 2
-
1 , the project site is
bound

by
existing fencing on the north, east and
south
, and connec
t
s

to the
surrounding
WCCSL
areas and operations

via existing
service
road
.

Not part of the proposed project, but
within
part of
the BMPC property

shown in
Figure

2 -
0 , t
he

9 To be clear, the proposed project is a separate and independent project from other possible hydrogen -
related projects
within the City that may be proposed
in the near future. The Raven project has a separate and independent owner, located on a separate and independent site, has a separate and completely independent source stream to make hydrogen, is proposing “green” hydrogen, and is seeking separate entitle ments. Additionally, baseline for the
Raven project was established at the time that the completed application was filed by the applicant on July 30, 2021.

At that time, other hydrogen
-
related projects were not in the entitlement process with the City.

Mo
nths later
Chevron submitted and application on November 15, 2021, for an alternatives fueling station that would include fueling equipment for hydrogen (H2) and compressed natural gas (CNG).

That application did not propose the
manufacturing of hydrogen.

Additionally, after Raven’s project was received no other application has been received by the City for a hydrogen production project.

As a result, the Raven project is not required to analyze the potential cumulative impacts for subsequent/potentially f uture 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 t hat
have yet to be received.

Finally, any hydrogen
-
related projects submitted after

the Raven project or at some future
date would be required to comply with CEQA. As part of that process, those projects would also need to include the Raven project in either the baseline or a reasonably foreseeable project for that project’s initial stud y
–

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

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existing WCCSL maintenance building
, power plant,

and a leachate treatment facility
sit within
50 to 100 feet of the
site
, and
leachate tanks

operate just west of the
north
driveway

into the
property

from the main WCCSL access road
.

Figure
1 -
3 shows the

nearby
Golden Bear Waste Recycling Facility

(part of the BMPC)
,

located
approximately

300 feet southwest of the property
.

Also, t
he
West
County Wastewater

District
Treatment Plant

and the Wildcat
M
ars
h
Trail and trail head
parking
exist

approximately
1,000
feet
south
east of the property.

Figure 1
-
2 and Figure 1
-
3 show t
he
surrounding
expan
se
consists
of

components of the 340
-
acre WCCSL facility
,
which consists of several distinct operations that
function as a whole. Notably, these
areas and uses
include
grass
-
covered

disposal areas

that are
landfill

mounds
,

runoff control ponds and lagoons
,

and composting

areas
, in addition to

the
tidal
marshlands of
San Pablo and Wildcat Creek tidal marshlands
. Open water of San Pablo Bay is
approximately 0.25 miles westward from the project site. (WCCSL BMPC Draft EIR, 2003)

Figure 2-0
Birdseye View of Project Site and Surrounding (from SE) Raven SR Bioenergy Project Initial StudySOURCE: ESA, 2022; Google Earth, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator r ESA
~
Conversion Operation
(modular building and canopy)
Conversion Operation
(modular building and canopy)
Fire Water Tank
& Equipment
Fire Water Tank
& Equipment
Export Panels/TrucksExport Panels/Trucks
Figure 2-1
Project Site and Raven SR Facility Areas
N
Raven SR Bioenergy Project Initial StudySOURCE: Raven LLC, 2022; ESA, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator Bulk Materials Processing Center Property Raven SR Facility Areas

2. Project Description

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2.4 2.3

Site Plan and
Structures

Figure 2
-
2,
Simulated

3D Site Development
, illustrates the proposed facility and key operation
components

simulated in a birds
-
eye view
.

Al
l Raven SR’s materials handling systems would be
located inside
a

proposed modular structure
.

The proposed project
would

erect a new stand
-
alone
modular structure where storage uses
and remnant foundations
currently exist
at the north edge

of
the property
.

The proposed modular structure and ind
ustrial metal canopy

for the feed (or input)
area would

contain
three primary areas for the three
-
stage process of the operation described
below
.

Figure
s

2 -
3 a and 2
-
3b
,
South

Elevation
s
,

illustrate the proposed facil
ity and key operations in
elevation, and
Figure 2
-
4, Detailed Site Layout and Raven SR Facility Plan
, identifies each
component in detail.

The total new building area

would be

approximately 40,000 square feet
. The

industrial
feed
material handler

would be
up to
31 feet tall

and the tallest
facility

element.

Other
elements of height and size include the nitrogen tank (30 feet tall); the cooling tower and the fire water tank (both 25.5 feet tall); and the
ind
ustrial metal canopy

over the feed/unload storage a
rea,
the adjacent steam reformer structure, and the nitrogen tank (each 26 feet tall) .

Leachate
Tanks
Leachate
Tanks
WCCSL
Maintenance
Building
Bay Trail/LeveeBay Trail/Levee
Power
Generation
Building
Leachate Pond
Closed Class I Disposal SiteClosed Class I Disposal Site Figure 2-2
Simulated 3D Site Development
Raven SR Bioenergy Project Initial StudySOURCE: Raven LLC, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator Figure 2-3a
South Elevation (West End)
Raven SR Bioenergy Project Initial StudySOURCE: Raven LLC, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator r ESA
~
Figure 2-3b
South Elevation (East End)
Raven SR Bioenergy Project Initial StudySOURCE: Raven LLC, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator r ESA
~
FEEDUNLOAIII~
''°""'
-------""4














Figure 2-4
Detailed Site Layout and Raven SR Facility Plan
Raven SR Bioenergy Project Initial StudySOURCE: Raven LLC, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator

2. Project Description

Raven SR Bioenergy Project

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2.5 2.4

Technology

Raven SR
’s multi
-
patented

Steam/CO
2 Reformation technology can convert a variety of
organic

waste
feedstocks into a hydrogen
-
rich synthesis gas (syngas)

through a three
-
step
process shown in
Figure
2 -
5 , Raven SR Process Diagram
.
10 Organic feedstocks include
biomass, municipal solid waste, bio
-
solids, industrial waste, sewage, medical waste,
or a
combination of these
,
obtained from the existing
WCCSL
.

T
he first stage of the process to
turn feedstock in
to a raw syngas begins with an externally
-
heated

“
biomass
steam

reformer
”

and a “syngas steam reformer”
.

The

raw syngas is then
polished
,

and then processed
through
purification of hydrogen to
mak
e

the

hydrogen product
:

transportation
-
grade
hydrogen
-
rich
s
yngas
.

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

While
T
t
he
Raven SR
t
T
echnology
can use a variety of potential feedstocks, the selected feedstock for this Project is a blend of urban greenwaste and organic food waste supplied by WC
CSL. The first stage of the process to turn feedstock into a raw syngas begins with an externally heated “biomass steam reformer” and a “syngas steam reformer .
”

The

raw

syngas

is

then

conditioned, compressed and

processed

through

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

11 The technology is strictly non
-
combustion (i.e., anoxic, indirect heating), low pressure, and a catalyst
-
free process.

As indicated in Figure 2
-
5 , e
arly in the process, t
he

system sequesters solid
carbon in a byproduct, biocarbon

(also referred

to as “biochar”)
, which is a salable product that
can be used for fertilizer or filler for concrete, for example. The biocarbon mixture also includes

elements
non
-
reactive components

w
ithin the organic waste feedstock (dirt, glass, grit, rocks, inorganic salts, etc.) that are inert to the process, not gasified, and drop out in the first

stage,
avoiding slag and tars.
12 The amount of biocarbon
mixture

is a
A
pproximately

15 to 20 percent o
f
the volume of dry feedstock input.
(Also see Section 2.5,
Safety and Controls, Non
-
Combustion
,
below.)

Feedstock is supplied by the Republic WCCSL and based on a blend of urban green waste (grass, tree branches, etc.) and organic food waste that has alre ady been subject to visual inspection for
contaminants by Republic before delivery to the Project’s receiving floor. Any incidental, non greenwaste/organic food waste

s
S
olid material that
goes

may inadvertently make it
through
the
feed handling

earlier ins
pection and removal by the Republic WCCSL process before the Raven system, including any

inorganic
volatile
material
(such as
bits of

plastic
s
,
cardboard, wrappers,

10 Hydrogen
-
rich
,
55 to 63 percent H
2 .

11 “
Conditioned” or “conditioning” refers to steps in the process to convert residual impurities, primarily sulfur compo
unds, into
a form that can easily be removed from the syngas. If the sulfur is not removed, it will contaminate
downstream catalyst/media, deactivating it, significantly reducing performance in downstream processing.

12 The biocarbon is considered sterile f
ollowing thermal treatment by the first stage of the process, when biological pathogens (if any) are destroyed by elevated temperature and residence time of approximately 45 minutes.

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etc.
refrigerants, batteries
) that may incidentally flow through to the rotary reformer would

be
converted
undergo conversion

to syngas as
they
it
thermally decompose
s

by exposure to
temperatures in the range of 1,400

degrees
F
.

Any volatile material
would
become part of the
syngas
,
while
and

non
-
volatile, inert material
would

report to the biocarbo
n solid phase.

No
emissions would be generated by any volatile materials that may inadvertently enter the process .

As stated earlier, the solid components of the feedstock that do not thermally decompose at 1400

degrees
F+ would report to the solid phase a
nd become biocarbon, while the volatile components
would become part of the raw syngas and go to the secondary steam reformer (SR2) operating at 1900

degrees
F+.

(Also see
Feedstock Processing
, below.)

Processing other potential feedstocks
within the confi
nes of this project is not consistent with Raven SR’s intent or Project Business Plan as shown by its agreement with allowed conditional uses of the site.

As also shown in Figure 2
-
5 , the
waste heat or

“tail gas”
(i.e., other gaseous components of the
syng
as that have been separated from the hydrogen product with residual, otherwise unrecoverable energy content)

from the conversion process can be
blended

with existing
LFG
to
generate power

and increase the efficiency of the process
.

At some point

in the cyc
le
,

This occurs

in new state
-
of
-
the
-
art, higher efficiency, low emission Jenbacher engines, which will provide approximately

half the electrical demand needed for the biomass conversion process. Emissions estimates for these engines were made using the bl
ended fuel composition of LFG and Raven
process tailgas. These engines will incorporate exhaust emissions control systems for low emissions.

The hot engine exhaust is used to dewater the incoming biomass feed stream before it enters the rotary reformer. U
sing this available heat increases overall process energy efficiency, and eliminates fuel combustion or costly electricity to supply heat at the dryer for dewatering feedstock. Use of the
LFG

and
the

tail gas
would

no longer recycle into the process and
in
stead
go to the
stack or

in the Jenbacher engines will result in a reduction in emissions of criteria pollutants from combustion of the landfill gas in the existing

flare

or existing engines
, described
below
.

Flare System

Raven SR anticipates use of its f
lare system

as

a
safety
backup for
the
evacuation

or venting

of
sy
n
gas

and, on rare occasion, vent hydrogen product
.

The
new Raven SR flare is in addition to the
existing LFG flares operated by Republic that serve to destroy LFG in the event the LFG engine s
are not available
.

The Raven SR

flare system
, for syngas vented in the event of an unexpected or emergency shutdown,

would be in the constant state of readiness through a hoo ded, continuous propane pilot

system. Use of the flare
would be
is expected to b
e infrequent

no more than 100 hours per year

and
only for emergency situations, expected to
occur

in few
on three

typical
instances
occasions
:

Feedstock
Management
Biomass Steam
Reforming
Syngas Steam
Reforming
Syngas
Polishing
Hydrogen
Purification
Blend of
Greenwaste
and Organic
Foodwaste
Overs
To Compost
Biochar
Tailgas
Hydrogen
Product
Power GenerationBlend of LFG and
Tailgas
Stack
Or
Flare
LFG
Electricity
To Process
Supplemental
Electricity
From Grid
Richmond ONE – Simplified Block Flow Diagram
Copyright 2022 Raven SR, USA
Figure 2-5
Raven SR Process Diagram
Raven SR Bioenergy Project Initial StudySOURCE: Raven LLC, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator

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1. System start
-
up: During start
-
up of the system, off
-
spec syngas
would

be

g
enerated and
evacuated from the system to the flare for destruction of

volatiles.

2. System shut
-
down: Whether for emergency shut
-
down or planned shutdown,

the system
would

require its inventory of syngas to be vented to the

flare for destruction of volatiles
.

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

have no provision for
emergency storage.

These instances have been quantified in Raven SR’s air permit application to BAAQMD, and are included in the air emissions evaluated in this documen t.

Note that item #3 has been
clarified in this
updated IS/MND.

The reason is that hydrogen is not a criterial pollutant. In the unlikely case that no off
-
take is immediately available, the design plans call for the product gas (which is greater than

99.9 9 percent hydrogen) to be safely vented to the atmosphere rather than flared.

The purified,
high
-
pressure hydrogen is not proposed to be flared as the pressure could create potential noise emissions.

The design plan also contemplates that if no off
-
taker

is available for a significant
period of time, the plant will determine the proper response such as reducing the rate of production, pausing production, and/or shutting down production.

Even in the worst
-
case scenario it is
anticipated that not more than

an hour’s worth of production of hydrogen would be in the system even if venting were necessary.

As the produced hydrogen is valuable, venting is not a preferred option from an operator perspective.

Instead, the expectation is that the plant would not co ntinue to
operate by consuming feedstock and power, and that any venting of hydrogen product would only occur in rare circumstances for brief durations of time.

These instances have been quantified in Raven SR
’s

air permit application

to BAAQMD
, and are
in
cluded in the air emissions evaluated in this document
.

In 1993, the California Environmental Protection Agency’s Department of Toxic Substances Control (DTSC) determined that the Raven SR process for the production of syngas from biomass and other carbon
aceous solids was not categorized as either incineration or combustion and was therefore a suitable technology for use in California.
13 2.6

2.5 Operations

Pre
-
Processing and Load Checks

The origin of the feedstock and the pre
-
processing and screening redund
ancies built into the
s
S
ystem

processes
would

to
ensure that little or no material
contamination
that is incompatible
with the Raven SR process
would

be introduced to the conversion system.

These processes

13 According to the definitions listed in Section 260.10, Title 40, Code o f Federal Regulations (40 CFR) and Section
66260.10, Title 22, California Code
of Regulations (22 CCR). Also, s
ince 2017, a Raven pilot engineering unit,
sized at 100 wet pounds per day of feedstock, has been operating at the UC Berkeley’s Richmond Field S tation and
is permitted for operation by the Bay Area Air Quality Management District (BAAQMD) under permit Nos. 23993 and 23320.

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include d
ocumenting the feedstock origin, as well
as pre
-
processing and screening redundancies.

First,
Republic Services
would

grind and

visually
screen
,
load check and
grind

the incoming mix
of green waste and organic food waste before delivering the feedstock to Raven. Any non
-
compostable
incompatible

ma
terial and other prohibited wastes would be
minimized

through
Republic’s screening and load checking programs

that occur at
its
compost facility.

In addition,
all incoming pre
-
processed feedstock received at the Raven SR facility will also be subject to th e
Raven SR’s own screening and load checking program as required by State solid waste facility regulations.

14 After screening and load checking, the organic material is pre -
processed by grinding to reduce
volume
,

provide for a uniform mixture of material
and particle size
, and further screen out any
remaining contaminants
.

T
he pre
-
processed organic
material would then be
delivered
approximately 2,500
feet
from the compost area to the Raven SR facility
by Republic personnel
and vehicles. The
trucks
would

co
nsist of self
-
unloading transfer trucks or other suitable vehicles

that would discharge
loads as directed by a spotter onto the floor of
Raven SR’s

material
receiving area.

There

the material
would be

visually inspected and
subject to Raven’s load
checking

program,
then pushed by a loader into storage bunkers or other designated material storage areas. The pre
-
processed feedstock material
would

be fed into a metering hopper to cross
a screen to remove any oversized material, and then a magnetic separator to

remove any
unexpected metal. Any oversized material would be returned to Republic’s composting facility, and any recovered metal
would

be sent for recycling.

As discussed above in

2.4 2.5
,
Technology
, if any materials
are

missed by the screening processes

and enters the rotary reformer, those materials become part of process feed and would

eventually
become syngas or biocarbon.

Daily Quantities and Operations

The Raven facility
would

receive
up
to 99.9

wet tons per day

of blended green waste and food
waste

feedstock to produce
approximately

14 tons per day of biocarbon and
up to 4,800
kilograms (kg)
(5.3 tons)
of hydrogen per day.
15 Feedstock

would
be weighed on Republic scales
before arriving at the Raven
SR site, and the

commodities that come out of the
pr
ocess would be

weighed on Republic scales outside of the Raven
SR
site. The

WCCSL

material
that would be
diverted to the Raven
SR
facility by Republic represents a portion of their permitted 250 tons per day of compost processing capacity
.

The
Raven SR pr
ocess and facility i
s design
ed

for continuous operation
without many
and would
minimize

start
-
ups or shut
-
downs.

Accordingly, the

Raven SR system
would

operate
run
up to
24 14

A load checking program are developed in compliance with Title 14, Code of California Regulations (CCR), §17409.5, and gener
ally address the number of load checks to be performed; the location for the storage of prohibited wastes removed during the load checking process that is separately secured or isolated; records of load checks and the personnel training.

15 While Raven SR
can produce synthetic liquid fuels, the
proposed
Richmond location
proposes to
only produce
transportation grade hydrogen

due to the interest of the local and regional markets for non -
fossil fuel based
hydrogen.

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hours per day,
seven

days per week,
although
an average of

1.5 days per month are pl
anned down
times

with a single, extended outage for annual maintenance
. This
totals

approximately 8,3
00 hours of operation per year.

Energy and Fuel Use

The plant
would

consume approximately
6 .0
+

MW of electricity (MWe) to operate and produce
the 4,800
kg
of hydrogen per
day

(200 kg of hydrogen per hour)
. The majority of
th
e
this

power
would

come from onsite power generation using newly installed LFG
engine
s
,
that
would

replace

existing,
featuring higher efficiency and lower emissions than the

inefficient

WC
CSL

engines

with relatively higher emissions
.

The
fuel to
new engines will

be
used for

equipped with state
-
of
-
art

air pollution controls that represent
BACT
. For comparison, the new engines will achieve a
NOx emission rate that is 81

percent

lower than the
existing WCCSL engines. Using the blended
LFG/tail gas fuel, the new engines will also achieve CO emissions that are 53

percent

to 62
percent

lower than the WCCSL engines being replaced.

t
T
he
proposed fuel for power
generation is the
existing
LFG

from the
Republic Services BMPC
,
combined

WCCSL, blended
with the tail gas from
the
pressure swing absorber

(PSA)
unit
that
serves
to purify the hydrogen product
. Republic Services
would

receive
approximately 0.5 MW
from the power generation for
its
onsite operatio
n needs and the rest
would

be used to power the
proposed project
. Any additional electrical power required beyond that generated onsite would

come from an existing PG&E power drop to the site
, as also indicated in Figure 2
-
5 .

Safety and Controls

No Combus
tion

Technology
.

The
Raven SR’s facilit
y’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 bou
nded by high/low
alarm limitations

to

draw

the operator’s attention to the specific problem. The control system would
represent state
-
of
-
the
-
art digital technology with redundant instrumentation where necessary to ensure safe operation.

Raven would initia
te inspection, monitoring maintenance procedures to ensure safe facility operations.

Because the
Raven SR
process
itself
is
closed and
oxygen
-
free, there
would be

no
opportunity within the process for explosion. Piping and vessels would
be periodically sca
nned
with
infrared
equipment to identify hot spots or gas leaks that may threaten safety.

If hot spots or
leaks were
identified, immediate steps
would

be taken to correct or mediate the condition.

Also,
r
emote monitoring of the facility by Raven SR corpora
te
provides

oversight of the operation and
early identification of problems as they development.

The facility
would
maintain a “Plant Safety Handbook” and establish
industry
-
accepted
procedures to be followed
if

events threaten the safety of
employees,
th
e facility

or surrounding

area
s
. The

facility
would

maintain and evolve Standard Operating Procedures for aspects of the plant th
at

require frequent intervention
, for example
.

One example of such activity is the daily
acceptance of trucks for loading with
hydrogen product, wherein

accepted procedure
s

to accept a
truck for loading of hydrogen product,
to
fill to
regulated

maximum allowable pressures,
to

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ensure a
cool
-
down period to allow the pressurized gas to
dissipate the heat of compression prior
to depar
ture from the site. These procedures are informed and well -
defined from industry
experience and with oversight for the entire fueling process from federal agencies that handoff responsibility during their respective stage of the fueling process. For examp le
,

arriving for
fueling (USDOT), Fueling (USEPA, OSHA), Departing from fueling (USDOT) shed the heat of
compression, etc
.

Safety Standards

and Maintenance
.

Raven SR units are equipped
The
project is being designed
in accordance

with
continuous monitoring

Ca
lifornia Fire Code for all

systems and
can
automatically shut down
equipment installation containing flammable, combustible, or hazardous materials, and an equipment maintenance program agreed upon by the City and the Fire Marshall
will be implemented.

As
part of the Project design process, Raven SR will conduct a Process Hazard Analysis (PHA) in which a detailed risk evaluation will be conducted of the proposed

plant

design and plans for

o
perations

without human intervention
.

The project
would

comply
The P
HA will identify all
potential hazards associated with the proposed process operations, including potential hazards associated with the properties of hydrogen; evaluate the controls and safeguards planned in the design to ensure safe operation of the proce
ss; and identify recommendations for additional risk
mitigation that will be addressed during the final design phase.

The PHA is one element of the process safety and risk management programs (PSM/RMP) that will be implemented in accordance

with applicable

Environmental Protection Agency (EPA)
risk
management plan (RMP) and

Occupational Safety and Health Administration (OSHA)
process
safety management (PSM) guidelines
,
as

and Richmond Industrial Safety Ordinance (RISO)
regulations to ensure the plant is des
igned to mitigate potential risks and operate safely. Raven SR has chosen to implement these programs even though a preliminary determination has indicated that these requirements
may
not
be
applied
applicable

to the facility
.

to ensure the safety of its
op
erations staff and the surrounding community
.

The proposed design would have less than
10,000
pounds

of flammable substances within the process, which is the threshold quantity that triggers applicability. Though Raven SR’s flammable inventory would

be bel
ow this threshold,
Raven SR
would

voluntarily adhere to the requirements of PSM as a process to facilitate safe, reliable operation of the facility.

PSM policies and programs
,

and the pertinent agencies that minister and provide oversight to qualifying
p
ro
jects
,

fall under the umbrella of the California
Certified Unified Program Agencies
(
CUPA
)

Forum
.

CUPA is a statewide alliance of Certified Unified Program Agencies and Participating Agencies (collectively known as Unified Program Agencies -
UPAs) that imple
ment
the Unified Program under California Health and Safety Code Division 20, Chapter 6.11. The organization works to update and continuously improve the Unified Program for the agencies, businesses and communities served.

The OSHA PSM and EPA RMP program
s contain many elements to promote safety and are well
known in industry. Information is available to the public on -
line. For the Raven facility, these
elements are under development and include, but are not limited to:

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Comprehensive P
rocess Safety Inform
ation

(PSI),

which will be utilized in the
Process Hazards Analysis

and for developing safe work practices and operating
procedures
;

E
mployee Participation

to ensure employee involvement in the PSM/RMP process
;

O
perating Procedures

to develop safe work pra
ctices and protocols
;

Training

of all employees and contractors on the potential hazards and safe operation s
;

Management of Change

process to verify any new systems, components, parts, etc. are evaluated b
efore being placed into service
;

Pre
-
Start Safety R
eview

(PSSR)

to verify the process/equipment is ready for service
before starting. This includes all safety and control items are functioning and operators are aware/trained on any changes
;

I
ncident Investigation

to identify and understand the root cause o
f equipment or system
failures and develop/implement corrective actions to keep from happening again ;

Management
of Contractors

in a manner
that ensures
they are aware the safety aspects
of the facility as well as the requirement while working on site ;

Mec
hanical
I
ntegrity

including routine maintenance, to verify the mechanical reliability of equipment
;
and

E
mergency Planning and Response

to have a process/procedure in place in the event of
an issue, so a standard protocol can be followed. This requires un derstanding of the
process and determining potential issues that could occur, and developing protocols to manage the situation should an event occur.

The
p
ro
posed pro
ject is divided into two key phases with specific needs incorporated into the p
roject desi
gn that adhere to safety guidelines in order to further maintain safe practices at the facility. During the
Construction Phase

of the
p
roject, Raven SR’s contractor would carry
responsibility for site conditions and the safety of labor, contractors, and su ppliers that may have
access to the site. Safety training for the various construction roles prior to access to the site would be

mandatory
,

using programs developed by the general contractor. Daily briefings would

be conducted to highlight safety and aler
t crew and labor to potential hazards that may be
scheduled for that day’s work.

Although not
likely to exist
, any w
ork areas subject to potential
physical harm such as those presenting fall hazards, exposure to hot work, or
loud noise will be
appropriate
ly marked and identified with physical barriers to prevent unwitting access.

During the
Operations Phase

of the Project, Raven SR will comply with local, state and federal regulations. Raven SR and its
operations and maintenance (
O&M
)

service
would

instit
ute a video
library of tutorials on aspects of conduct on
-
site related to safe operation of equipment.

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

Raven SR
would

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

be marked
with

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

A maintenance program of
regular and

routine,
preventative
and predicti
ve

maintenance would
also be implemented to maintain equipment in a reliable manner.

Raven SR
would
contract with a
capable and experienced O&M service provider from among those with experience in feedstock management and with high temperature, high pressu
re process equipment. As is typical practice,
Raven SR
would

closely oversee the development of operating, training, safety, and maintenance manuals that are specifically targeted for the Project’s needs. Raven SR would

monitor the
development of the requi
site Plant documentation and assist in the management of risk during plant operation at the corporate level.

Fugitive Emissions.

The
system is a closed

process
once the orga
nic feedstock input is
managed
. Mechanical

unit would have mechanical

seals

on the
feed inlet and the biochar outlet,

prevent
ing

fugitive emission from the first
-
stage reformer which operates under
mild

pressure.

The first stage vessel (SR1) has mechanical seals
that are purged of air using

with
pressurized
nitrogen, which would prohibit

the release of fugitive emissions.

Tail gas
,

generated by the
process
and consisting of the non
-
hydrogen syngas components, with residual unrecoverable hydrogen,

would be

is

combined with LFG
and used

to use its residual energy content

as a fuel
for the L
FG generators

to generate
additional
energy.

Due to its extremely small molecule size, hydrogen has unique physical

properties, such as
buoyancy. Hydrogen
is 14 times lighter than

air and moves upward quickly.

Raven SR operations
would

institute proactive
measures to periodically monitor plant piping for hot spots that may be indicative of potential gas
leaks.

Technology, such as an FLIR camera, will be used to highlight and identify a potential hotspot, so remedial actions are implemented to prevent or cor rect

any gas
leak, as appropriate.

Hydrogen is not a criteria pollutant and

is a key mitigation strategy in the
2022 Scoping Plan’s objectives for carbon neutrality
.

Odor Control.

Odors may exist
and d
e
rive
from the organic feedstock input that is already
produced and processed at the
WCCSL
.

N
uisance odor from

The first step in the
Raven
process
is
unlikely since

to dry incoming
feedstock
material would only be on the feedstock management
area floor for relatively short periods of time

using waste heat from

the LFG engines before
introduction to Raven’s
first

stage reformer. Dry feedstocks do not typically create or form odors.

To proactively address the potential for odors, the Raven SR Project includes the implementation of a number of odor minimization pr
ocedures and regulatory requirements.

These odor
minimization requirements include

i.

F
eedstock load checking at the Republic site for identification and removal of prohibited material including any highly
-
odorous loads;

ii.

F
eedstock pre
-
processing at the Repu
blic site before being sent to the Raven facility;

iii.

O
perations protocol for first in/first out feedstock consumption;

iv.

F
eedstock will typically be processed within 24 hours with a maximum limit within 48 hours of receipt;

v.

D
aily cleaning of the feedstock h
andling area; and

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vi.

U
se of odor suppressants if necessary.

Feedstock for the Raven process will only include pre
-
processed

consisting primarily of blended
green waste and food waste. The source of this material is from the onsite composting facility referred

to as the O
MPF
. The OMPF receives vehicle loads directly from residential and commercial organics collection programs. The OMPF operating procedures include initial visual screening and a load checking program designed to identify and remove prohibited ma terial,
including any highly odorous loads.

A
fter screening and load checking, remaining organic
material
is

pre
-
processed by grinding. Only material that has been through the screening, load checking and grinding process at the OMPF
would
be delivered to
the Raven facility, thus
minimizing the potential for receiving prohibited or highly odorous material. In addition, all incoming pre
-
processed
feedstock received at the Raven SR facility would also be subject to the Raven SR’s own screening and load checki
ng program as required by State solid waste facility
regulations
.

To

further minimize potential odor
effects of the proposed project
, the standard operating
procedures for the Raven facility would include a “first in first out protocol” for the processing

of
material. Typically, any material received would be processed within 24 hours of receipt through the hydrogen conversion system. As a requirement of both the draft
CUP and the Solid Waste
Facility Permit (SWFP) for the facility, all feedstock material would, at a maximum, be processed
within 48 hours of receipt. With this minimal time
effects of the proposed project

in the feedstock
handling area, the potential for odor
would be
greatly reduced as opposed to odors arising over
time from decomposing feed
stock.

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

However, o
dor control
for the proposed
Raven SR

operation
would

be in place to minimize possible odors.

Also, t
he
proposed industrial metal canopy
would

be placed over the feedstock floor and infeed equipment to prevent stormwater
contact.

O
dor control would be added to the management area if
objection
able odors occur. The facility could also store topical treatment solutions (non -
toxic and
biodegradable) onsite, which would be applied to neutralize odors if an immediate need arises.

Hydrogen

Storage and

Export Panel.

The hydrogen product is compressed
for short term
storage
after the first
-
stage compressor,
before being

compressed with a second
-
state, higher
pressure compressor and

exported via truck
-
mounted tube trailers for delivery to facilities using
hydrogen for transportation or processes needing
green hydrogen.

There is no compression tank
in the design.

T
he produced hydrogen
would

be onboarded by
a
hydrogen gas export panel

designed by a global manufacturer of hydrogen fueling stations

to industry standards
,

incorporating best
-
practice Health, Sa
fety, Security and Environment (HSSE)
design
. The panel

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is

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

Onsite
Water Tank /
Fire Equipment
.

A

new
250
,000
-
gallon

integrated

fire

water tank and
diesel
engine
is proposed

in the northeast corner of the site

emergency use
, as required by fire
department regulations

The fire water tank would be up to 25.5 feet tall
.

(
Shown in
Figure
s 2
-
1 through 2
-
4 .)

2.7 2.6

Employment

Raven
would

employ

approximately
thre
e

to
four

employees per shift for the operation of the
Raven facility, for a total of
nine

to
12 new employees to cover all shifts and provide necessary support of the facility.

The facility would not involve customers onsite
.

2.8 2.7

Transportation and Cir
culation

As indicated under
“
Safety Controls”
above, t
he proposed project
would

export the produced
hydrogen offsite via truck
-
mounted tube
trailers

(shown in Figures 2
-
2 through 2
-
4)
.

The
operation
would

involve
up
is expected

to
service
approximately
12 14

hydrogen tube
trucks

and
up to approximately 15

biocarbon trucks (total
37 trucks
)

per
week
day
,

each
with an average trip
of 40 miles

after leaving the site
.

In addition,
up to
approximately

11 biocarbon trucks per day
would be in use for the co
-
product.

Considering this with other trucks and employees coming to and leaving the project site daily
,
12 employee vehicles and 25 trucks would access the site daily
the project is estimated to generate about 130 vehicle trips on a typical weekday .

In addition,
th
e Raven SR system
would

only use feedstock from ongoing existing
composting
BMPC

operations on the property

that would not leave the WCCSL site.

Figure
s

2 -
2 and
2 -
4 show
where WCCSL feedstock supply trucks would approach and exit the Raven facility from th
e feedstock prep area
,

and
in addition to Figure
2 -
3 a

show three stalls where the tube
trucks

would
connect to a hose and receive the hydrogen product. The t ube trailers
would
idle for
no
more than
five

minutes once at project site, as required per State r
egulations
.

2.9 2.8

Construction
,

Site Coverage

and Drainage

Raven anticipates
initiating construction activity on the project site
in
Fourth
Second

Quarter

of
2022
2023
, which would contin
ue for approximately
eight

months.

Start
-
up of the plant

is
projected

to

begin

in
Fourth Quarter of 2023, or First Quarter of 2024
early
the Second or Third
Q
uarter

of 2023
.

Construction proposed is to demolish
the existing
materials

and remove existing equipment

from
the project site
, lightly regrade the site, add up to six

inches of fill, and
erect
the new facility. The
existing project site is mostly paved and partially pervious compacted soil and ruderal groundcover (see Figure 2
-
1 ). E
xisting materials

to be excavated include

remnant
concrete
foundations that
would

be pul
verized and partially used as fill material.

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The maximum
depth of excavation would be up to 2.5 feet. All excavation spoils and remaining concrete debris
would

remain on the landfill site.

Minimal
fill
, approximately 250 cubic yards,

may be required and
w
ould be
hauled

obtained from suitable, available materials already
on site

for

generated during site

grading
; only demolition materials (asphalt and concrete) would be off hauled.

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

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

1.21 acres of impervious area (including modular structures), resulting in a total of 1.97 acres (or 78 percent) of impervious area on the

site. Approximately 0.53 acres of unpaved area along the north edge of the site would remain undisturbed. There are no natural drainage paths on the site.

The project would adhere to all applicable regulatory stormwater runoff controls and would

pursue it
s own National Pollutant Discharge Elimination System (NPDES) permit. The project’s stormwater plan would be integrated into the existing WCCSL system and ensure drainage from the proposed project site
would

drain towards existing stormwater runoff control

ponds (or
bioretention facility) to which the rest of the WCCSL property currently drains.

2.10 2.9

Off
-
site Improvements: Landscaping

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

Due to limited space and potential safety hazards, no new plants or vegetation would

be installed
within the Raven project site. Instead, new trees
would

be added to the public par
king area near
the trailhead.

Eleven drought
-
tolerant trees would be planted: either six large Coast Live Oak ( Quercus
agrifolia
) or Big Leaf Maple (
Acer macrophyllum
), and five small California Buckeye (
Aesculus
californica
). Both species are on City’s ap
proved list of trees. Tree size planted would be
associated with
1 5
-
gallon containers
.

References

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

Available online:

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

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

3. Environmental Factors Potentially Affected

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

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

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

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

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

Si~nature [ \
L~ clio" . \as
Print~Name
Raven SR Bioenergy Project
Updated Initial Study MND
Date
For
33 ESA / D202100382
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B
lank Page

4. Environmental Checklist and
E
valuation

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4. Environmental Checklist and
Evaluation

4.1 Aesthetics

Environmental

Issues

Potentially

Significant

Impact

L
ess

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Aesthetics

Except

as

provided

in Public Resources Code Section 21099, would
the

project:

a)

Have

a
substantial

adverse

effect

on

a

scenic

vista?

b)

Substantially damage

scenic resources, including,

but

not

limited to, trees,

rock outcroppings,
and

historic

building

within
a

State

Scenic Highway?

c)

In

non
-
urbanized

areas, substantially

degrade

the

existing

visual

charact
er

or

quality

of public views of

the
site

and its surroundings?

(Public

views are those

that

are

experienced

from publicly

accessible

vantage point).

If

the

project is

in

an

urbanized

area,

would

the

project conflict

with

applicable zoning and

other

regula
tions

governing

scenic quality?

d)

Create

a

new source

of

substantial

light or

glare

which

would

adversely

affect
day

or

nighttime

views

in

the

area?

Setting

The
project site is within the
WCCSL
within

an

industrial
, commercial,

and op
en space
setting of
North Richmond. It is an integrated solid waste management and

disposal facility and does not
have significant visual value.

Grading on the site over the years has
resulted in

topographic

variation
s created by the
hill forms
or mounds t
hat are
the grass
-
covered landfills
. The hill forms

range
from
between elevations 110 and 160 feet
above mean sea level, with up to an additional
seven
feet of soil layer
.

(
WCCSL BMPC Draft EIR, 2003)

The area has

little or no distinctive
visual features
,
except for

l
eachate

treatment
ponds
,
runoff control ponds and
lagoons,

and
marshlands of Wildcat Creek.

Despite the abse
nce of significant visual value

within the WCCSL itself, the site

provides
extensive views in all directions
, including u
nobstructed pa
noramic views of San Pablo Bay
, San
Pablo Ridge and Mt. Tamalpais across the Bay
.

The visual quality of the WCCSL has been
assessed

in n
umerous
CEQA analyses over the years
,

and
each
determined that no aspect of the
WCCSL operations would significantly aff
ect visual quality
.

(
WCCSL BMPC Draft EIR, 2003)

Evaluation

a)

Have a substantial adverse effect on a scenic vista?

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Less than Significant Impact
.

Visual access th
e

W
CCSL from nearby
public
areas
are
distant and limited
, largely because
the
surrounding

area
s are mostly at
lower

elevation
s

than that
of the WCCSL; distant views are blocked by buildings or landscaping.

Views
toward the WCCSL and the project site from Richmond Parkway are blocked by trees and the property is difficult to distinguish

from adjacen
t and background across the Bay
.

Northbound and southbound motorists on the Richmond Parkway can view

the WCCSL,
but views are limited, short
-
term and sometimes obscured or blocked by median

landscaping or intervening trees and buildings. The proposed proj ect site
within part of
the BMPC area

is not visible from offsite areas
as it is at an even
lower elevation

and
behind intervening berms and
levees
.

Figure 4.1
-
1, Wildcat Marsh Trail Approach Toward Project Site (from East) ,
captures part of the project s
ite that would be visible to users of this public trail. The viewshed from this location does not capture any scenic vistas in the direction of the project site. Views toward the opposite direction of the site from the trail provides direct expansive views

of the Wildcat Creek Marsh. Moreover, once developed, the facilities will appear consistent with the industrial nature of the existing visible facilities. The project
would

not have an adverse effect on a scenic vista.

The impact would be less than
signif
icant.

b)

Substantially damage scenic resources, including,

but not limited to, trees, rock
outcroppings, and historic building within a State Scenic Highway?

No Impact
.

No
designated
scenic highways currently exist
within the City of Richmond,
according t
o California Scenic Highway
Program
mapping system.
(Caltrans, 2016
)

While the City’s prior 1994 General Plan and General Plan EIR identified portions of Richmond Parkway as having a positive aesthetic value, the proposed
project site is not
visible from t
he parkway. (Richmond, 2011)

c)

In non
-
urbanized areas, substantially degrade the

existing visual character or
quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). I f the project is in an
urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?

Raven SR Bioenergy Project Initial Study
Figure 4.1-1
Wildcat Marsh Trail Approach Toward Project Site (from East) SOURCE: ESA, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator

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Less than Significant Impact
.

The 34
0 -
acre WCCSL facility
,

in which the project site
sits
,

consists of several distinct operations that function as a whole. Notably, these operations and areas
include
grass
-
covered disposal areas
, notably the main
central
,

landfill

hill
,

runoff control ponds

and lagoons, and composting
areas
, in addition to
the
tidal marshlands of Wildcat Creek
.

As previously stated in this section, numerous
e
nvironmental reviews
pursuant to

CEQA have been conducted on all WCCSL activities,
all of which determined that none o
f the activities would significantly affect the visual
quality of the facility.

The proposed
project

could

be visible from points along the adjacent and lower Bay Trail
, since se
gments of the Trail allow users
to observe, from a safe distance, some
recycli
ng activities within the WCCSL

property
. T
o the extent that the proposed project
facilities and operation

c
ould

be visible, the views
would

be distant and would not be
adverse
relative

to other visible WCCSL
activities.

Figure 4.1
-
2, Onsite View Toward
Pro
ject Site
, shows the existing
visual character

in which

the proposed project would
exists.

All feedstock material for the proposed operation
would

be
organic
material
s sorted from
the existing

onsite
BMPC
OMPF

composting

operation; no feedstock
would

be br
ought
directly to the Raven facility from offsite.

Product from the project operation
would

leave
the project site in
hydrogen tube trucks and biocarbon trucks
. Therefore, o
perations of the
Raven facility are not expected to be a source of
litter that

coul
d exacerbate litter and
dumping in the nearby neighborhoods.

Overall, t
he project’s effect on existing visual character or quality of public views of the site and its surroundings would be less than significant.

d)

Create a new source of substantial light

or glare

which would adversely affect day
or nighttime views in the area?

Less than Significant

Impact
.

Many activities
within

the WCCSL facility operate 24
hours a day, seven days per week, including the

onsite
OMPF
BMPC activities

and waste
recovery

comp
osting
operations. Other onsite processing operations operate until midnight. All existing operations operate under approved County and City use permits, which requires all
lighting system
s

to reduce glare and to not substantially impact area
residents.

Ex
isting lighting is varied and includes various sizes of portable and directional flood lights

on certain operations.

Figure 4.1-2
Onsite View Toward Project Site
Raven SR Bioenergy Project Initial StudySOURCE: ESA, 20222021\D202100382.00 - Raven SR Bioenergy ISMND/05 Graphics-GIS-Modeling/Illustrator r ESA
~

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The proposed project would also operate 24 hours a day, seven days per week, and would

be de
veloped within an existing, functional area of the BMPC operation
property
, which
is currently lighted.

The project proposes LED lighting mounted on 30
-
foot
-
tall poles.

Like the existing WCCSL
and
BMPC conditions,
the

additional lighting would be
focused an
d shaded, incorporating directional shading
(down
-
shot reflectors) to limit
light pollution during

night operation
s
.

The project would place nine single
-
light fixtures
at throughout the site and three double
-
light fixtures in the truck loading area in the
south
portion of the site.

Also, the continuous
propane
pilot light

that fuels the flare system
used as needed to evacuate or vent organic
sy
n
gas
or

on rare occasion vent hydrogen
product
, would
be hooded
, thus minimizing its v
isibility

from offsite
.

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

Moreover, any new lighting would not
affect nighttime views
in the area.

This i
mpact
would be less than significant.

References

California Department of Transportation

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

City of Richmond, 2011.

General Plan 2030 EIR
. August
2011
.

Contra Costa County
, 2003
. Draft Environmental Impact Report on the West Contra County Sanitary Landfil
l Bulk Materials Processing Center and Related Actions
,
SCH#
2002102057
.

November 2003.

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4.2 Agriculture and Forestry Resources

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

S
ignificant

Impact

No

Impact

Agriculture

and

Forestry

Resources

In

determining whether

impacts

to

agricultural

resources

are

significant
environmental

effects,

lead

agencies may

refer

to

the

California Agricultural

Land Evaluation and Site Assessment

Mo
del

(1997)

prepared

by

the

California
Dept.

of
Conservation

as

an

optional

model

to
use
in assessing

impacts
on

agriculture

and

farmland.

In

determining
whether

impacts
to

forest

resources,

including

timberland,

are

significant

environmental
effects,

lead

agencies

may

refer

to

information compiled by the

California

Department
of

Forestry

and Fire

Protection regarding

the
State’s

inventory

of

forest

land,

including
the

Forest

and

Range Assessment Project
and

the

Forest

Legacy

Assessment
project;
and

forest

c
arbon

measurement

methodology provided

in

Forest

Protocols

adopted

by
the

California Air

Resources Board.

Would

the

project:

a)

Convert

Prime Farmland,

Unique Farmland, or

Farmland of

Statewide

Importance (Farmland),
as

shown

on

the maps

prepared

pursuant

to

the

Farmland
Mapping and

Monitoring

Program

of

the

California

Resources

Agency,

to
non
-
agricultural

use?

b)

Conflict

with

existing

zoning for

agricultural

use,

or

a

Williamson

Act contract?

c)

Conflict

with

existing

zoning for,

or

cause

rezoning

of,

forest land

(as
defined

in Public Resources

Code

Section

12220(g)),

timberland
(as

defined by Public

Resources

Code

Section 4526),

or

timberland

zoned

Timberland

Production
(as

defined
by

Government

Code
Section

51104(g))?

d)

Result

in
the

loss

of

forest

land

or

conversion

of

forest

land
to

non
-
forest use?

e)

Involve

other changes

in
the

existing

environment

which, due

to

their

location

or

nature, could result

in

conversion

of

Farmland,

to

non
-
ag
ricultural

use

or

conversion

of forest

land
to

non
-
forest use?

Setting

The p
roject site
and its surroundings are
zoned for
“Open Space”
, and has no history of
agricultural uses (Richmond, 2012).

Richmond sanitary service operations initiated
within t
he
area that is now the WCCSL

in the early 1950s

on previously undeveloped land.

Evaluation

a
)

Convert Prime Farmland, Unique Farmland, or

Farmland of Statewide Importance
(Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monit
oring Program
(FMMP)
of the California Resources Agency, to non
-
agricultural use?)

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No Impact
.

The p
roject

site is

located entirely within a
n area of and
surrounded by
industrial
, commercial and

open space use
s
. The site is not identified as Prime Farmla
nd,
Unique Farmland, or Farmland of Statewide or

Local Importance by the FMMP, bu
t is
designated as Other Land
,

and

is

surrounded by

lands designated as

Urban Land and
Other Land
. The proposed p
roject would have no impact on important farmland.

(DLRP,
201
2 )

b)

Conflict with existing zoning for agricultural use, or a

Williamson Act contract?

No Impact
.

The p
roject site
and its surroundings are
zoned for
“Open Space”
, and
has

no
history of agricultural uses

(Richmond, 2012)
.

Also,
the site is not covered by a

Williamson Act contract

(DLRP, 2012)

Therefore
, the
proposed
p
roject would
have no
impact regarding

existing agricultural zoning or a Williamson Act contract .

c)

Conflict with existing zoning for, or cause rezoning

of, forest land (as defined in
Public Re
sources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))?

No Impact
.

The proposed project

site is not zoned as forest land or t
imberland, and there
are no forests on the
project

site. No impact would occur with implementation of the
proposed project
.

d, e
)

Result in the loss of forest land or conversion of

forest land to non
-
forest use?
Involve other changes in the existing enviro
nment

which, due to their location or
nature, could result in conversion of Farmland, to non
-
agricultural use or
conversion of forest land to non
-
forest use?

No Impact
.

As stated above, the proposed project

is not zoned as forest land a
nd there are
no fore
sts on the project site. The p
roject would not result in the loss of forest land or
conversion of forest land to non
-
forest uses, and
would have no impact.

Also, the project

would be constructed and operated entirely within a previously developed area

with
in the WCCSL that is

designated as Other Land by the FMMP. The
project site

does not contain farmland
or forest land
and there are no aspects of the
p
roject that would affect any agricultura
l land or forest land off
-
site. Therefore, the
proposed project
wo
uld not result in conversion of farmland

or forest land
, on
-
site or off
-
site, to a non
-
agricultural use

or

non
-
forest use. The
p
roject would have no impact.

References

California Department of Conservation, Division of Land Resource Protection (DLRP), 201 2 .

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

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

City of Richmond, 2012.

Richmond General Plan 2030: Land Use Element.

April 25,
2012.

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B
lank Page

4. Environmental Checklist and Evaluation

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4.3 Air

Quality

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Air Quality

Where

available,

the significance

criteria

established by
the

applicable air

quality management district

or

air

pollution

control

district

may

be

relied

upon

to

make

the following determinations.

Would

the

project:

a)

Conflict

with

or

obstruct

implementation of
the

applicable

air

quality plan?

b
)

Result

in
a

cumulatively

considerable

net increase

of

any

criteria pollutant for

which

the

project

region

is

non
-
attainment

under

an

applicable

federal

or

State

ambient

air

quality

standard?

c)

Expose

sensitive

receptors
to

substantial

p
ollutant

concentrations?

d)

Result

in other

emissions (such

as

those

leading

to

odors

or) adversely

affecting

a
substantial

number

of

people?

Setting

The project
site

is

located in
Contra Costa

County, which is in the San Francisco Bay
Area Air
Basin (
SFBAAB
), within the jurisdiction of the Bay Area Air Quality Management District (BAAQMD).

The SFBAAB is currently designated as a nonattainment area for state and national ozone standards and national particulate matter ambient air quality

standards. Development
projects can contribute to a region’s adverse air quality impacts on a cumulative basis so the BAAQMD considered the emission levels for which a project’s individual emissions would be cumulatively considerable when developing thres
holds of significance for air pollutants. The
significance thresholds used for project construction and operational impact analyses are based on thresholds set in the BAAQMD’s CEQA Guidelines (BAAQMD 2017b).

For the purposes of this air quality analysis,
sensitive receptors are defined as facilities and land
uses that include members of the population that are particularly sensitive to the effects of air pollutants, such as children, the elderly, and people with illnesses. Examples of these types of uses i
nclude schools, hospitals, and daycare centers. Residential areas are also considered sensitive to poor air quality because these sensitive individuals could be present there, and people usually stay home for extended periods of time, which results in grea ter exposure to ambient air
quality
.

There are no sensitive receptors within 1
,
000 feet of the
project

site. The nearest sensitive
receptors
to

the project site
are

r
esiden
ces at generally West Gertrude Avenue/Malcolm Drive
(
approximately 0.
75 miles

southe
ast
),

Verde Elementary School

at 2000 Giaramita Street
(approximately

1.1 miles

southeast
)
,

and

Contra Costa Health Clinic

at 1501 Fred Jackson Way
(
approximately

1.2 miles

southeast
)
.

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Evaluation

a)

Conflict with or obstruct implementation of the applicabl e air quality plan?

Less than Significant Impact
.

BAAQMD is the regional air quality authority in the
p
roject area.

Primary goals of
BAAQMD’s adopted

2017 Clean Air Plan

are to protect
public health by achieving attainment of air quality standards

(BAAQMD
, 2017a)
. The
plan includes a wide range of proposed control measures, which consist of actions to reduce the non
-
attainment pollutants
:
state and federal 8
-
hour ozone standard, the state 1
-
hour ozone standard, the state PM
10 standard, and the state and fe
deral PM

2.5 standards
.

BAAQMD guidance states that “if approval of a project would not result in significant and unavoidable air quality impacts, after the application of all feasible mitigation, the project would be considered consistent with the Clean Ai r Plan” (BAAQMD 2017b).

As
indicated in the discussion of
criteria “
b
”

and
“
c
”

below, the
p
roject would not result in
significant air quality impacts. Therefore, this impact would less than significant .

b)

Result in a cumulatively considerable net increas
e of any criteria pollutant for
which the project region is non
-
attainment under an applicable federal or state
ambient air quality standard?

Construction

Emissions from the construction phase of the project would be generated primarily from heavy duty e
quipment such as excavators, cranes, and forklifts.

C
riteria air pollutant
emissions
from equipment and on
-
road vehicle exhaust
were estimated using CalEEMod
(version
2020.4.0
2022.1
)
;

modeling output files are included in
Appendix A

to this
checklist
.

Cons
truction

is assumed to take place over
a
n eight
-
month period
. Project
specific data for construction phasing schedule and equipment fleet provided by the P
roject
A
pplicant was used in the model to estimate emissions
for

the construction
period.

The total e
missions
(without mitigation)
generated over the duration of construction
were

divided by the number of construction days for each
partial
construction year to
determine average
annual

daily
emissions from construction. Emissions from equipment
and vehicle

exhaust are presented in
Table
4 .3
-
1 .

As shown in the table, emissions of
reactive organic gases (ROG) and nitrogen oxides (NOx), which are ozone precursors, and particulate matter (PM
10 and PM

2.5 )
would all be below their respective significance
threshol
ds, which for construction have been established by BAAQMD in terms of average
annual
daily
emissions.

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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 Dail
y
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

10 54

15 82

10 54

Potential Significa
nt Impact?

No

No

No

No

NOTES: Construction emissions were revised to account for the one
-
year

construction schedule delay.

The B
AAQMD
significan
ce

thresholds
for pounds
-
per
-
day (rather than tons
-
per
-
year) now apply
.

SOURCE:

ESA
Ramboll

(Appendix A

to this

document
checklist
)

Operations

After
the

project is built, operational emissions, including
stationary,
mobile
,

and area
sources, are anticipated to occur continuously throughout the project’s lifetime.

The
project is anticipated to begin operations in
20 23
2024
.

The
P
roject
A
pplicant has submitted an air permit application that includes multiple stationary sources
,
shown in
Table
4 .3
-
2 . According to the applicant’s air permit
application, the majority of emissions
would

be generated from the biogas engine

combustion process, where the engines emit exhaust that heats up a green waste rotary drier. The biogas engines are included in the list of proposed permitted sources, along with
a green waste storage pile of up to 200 tons,

a sheltered
storage of limesto
ne pellets

that
would

be used as a co
-
feed to the feedstock

needed to reduce acid gas formation in
the
system process, a diesel
-
fired fire pump engine, as well as a flare that is a backup for the

evacuation

or venting
of organic
syngas

or on rare occasion
vent hydrogen product
.

Fugitive emissions from piping components such as valves and pumps are also anticipated. Cooling towers, pressure storage tanks, raw water storage tanks, treated water storage tanks, bisulfite storage tanks, anti
-
scalant storage tank
s, 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 analys
is prepared for
the IS/MND is based on protocols used for the emissions analysis under review by the BAAQMD as part of the Authority to Construct (ATC) permit application .

This replacement would result in a lower emissions profile in contrast to current
op
erations at

the facility using the existing engine.

The project is also
For a given volume
of LFG combusted, NOx emissions would be reduced by 81

percent

and CO emissions
would be reduced by 53 to 62

percent
. The WCCSL engines remain active, permitted
sourc
es, but have not been used recently due to disrepair. This results in the majority of LFG produced being flared. The Project is therefore
expected to increase the functional
use of landfill
-
produced

biogas,

thereby

reducing

the

amount

of

organic

gas

sent

t
o

a

flare

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for

venting

or evacuation and ultimately reducing the flare
-
based emissions.

The
reduction in flaring emissions has been quantified below.

Notably, the

project
would

replace
an
three (3)
existing
WCCSL
biogas
-
fired engine
s

with
three (
3 )

newer
, lower emitting, and more efficient

Waukesha or

Jenbacher

engine
s
,
equipped with state
-
of
-
the
-
art air emissions controls, including Selective Catalytic Reduction (SCR) and oxidation catalyst, which represent BACT for this type of equipment
.

This replaceme
nt
would

result in a lower emissions
profile
in contrast to
operating the facility using the existing engine.

The project is also

For a given volume of
LFG combusted, NOx emissions would be reduced by 81

percent

and CO emissions
would be reduced by 53

perc
ent

to 62

percent
. The WCCSL engines remain active,
permitted sources, but have not been used recently due to disrepair. This results in the majority of LFG produced being flared. The
p
roject is therefore

expected to increase the
functional use of landfill
-
produced biogas, thereby reducing the amount
of organic gas
sent to a flare for
venting or evacuation

and ultimately reducing the flare
-
based
emissions.

Operational
-
related
mobile source
activities, such as
employee commuting, truck trips for
delivery an
d 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, landsc
ape maintenance equipment, and fireplaces/stoves, evaporative emissions from architectural coatings, and consumer products.

Although these sources are not regulated
under the BAAQMD’s air permitting program,

Table
4 .3
-
4 shows the emissions from
operational

emission
source
s

as
background
considered with
the project

emissions
sources

that are not part of the air permit application
.

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

CO

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

N/A

2.38 N/A

N/A

N/A

Fugitive component leaks

N/A

N/A

0 .63

N/A

N/A

N/A

Lime
stone

handling

N/A

N/A

N/A

N/A

0 .003

0 .0005

Lime
stone

storage

N/A

N/A

N/A

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

NOTES:

Operational emissions were revised t
o align
with
the more detailed project information

from the Project
Applicant
.

SOURCE:

Ramboll
Permit Application

(
Raven, 2022
a
Appendix A

to this document
)

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T
ABLE

4 .3
-
3 C
AL
EEM
OD
A

UXILIARY
O

PERATIONS

A
VERAGE
A
NNUAL

O
PERATI
ONAL
-
R
ELATED

C

RITERIA
P

OLLUTANT
E
MI
SSIONS

(

TONS PER YEAR
)

Project
Operations

Emissions
by
Category

ROG

NO
x

Exhaust
PM
10 Exhaust
PM

2.5 Area

0.1 8

0 0

0 Energy

<0.01

0.05 <0.01

<0.01

Mobile

0.03 0.14

2 .3

0 .16

0.16 <0.01

0.07 <0.01

Mobile
–

Road Dust

0 0

0.14 0.02

Off
-
road

0.1 5

1.4 5

0.05 0.04

Waste

N/A

N/A

0 0

Water

N/A

N/A

0 0

Total

0.18 0.47

3.75 1.66

0.35 0.05

0.13 0.05

NOTES: Operational mobile emissions were revised to align with the more detailed project information from the Project Applicant .

SOURCE: ESA
and Ramboll

(Appendix A

to this
document
checklist
)

T
ABLE
4 .3
-
4 A
VERAGE
A
NNUAL
O

PERATIONAL
-

RELATED

C

RITERIA
P

OLLUTANT
E
MI
SSIONS

(

TONS PER YEAR
)

Project
Operations

Emissions

NO
x

VOC/ROG

Exhaust

PM
10 Exhaust
P
M

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

15.83 8.71

0.10 -

0.19 3.35

6.09 3.35

-

6.09 Overall Total

9.05 2.43

9. 1
9 7.55

5. 2
1 2.16

5. 1
9 1.92

BAAQMD Threshold for Significant
Operational

Impacts

10 10

15 10

Potential Significant Impact?

No

No

No

No

NOTES: Operational mobile emissions were revised to align with more detailed project information from the Project Applicant .

Source
: ESA
and Ramboll

(Appendix A

to this
document
checklist
)
and Ramboll Permit Application (Raven
,

2022
a
)

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T
ABLE

4.3 -
5 A
VERAGE
D
AILY
O

PERATIONAL
-

RELATED
C

RITERIA
P

OLLUTANT
E

MISSIONS

(

POUNDS PER DAY
)

Project Operations Emissions

NO
x

VOC/ROG

PM
10 PM

2.5 Process Operations

40.49 40.94

28.27 28.16

Auxiliary Operations

20.55 0.99

1.92 0.72

Reduction in Flared Landfill Gas

-

47.70 -

0.57 -

18.35 -

18.35 Overall Total

13.34 41.36

11.85 10.54

BAAQMD Threshold for Significant
Operationa
l Impacts

54 54

82 54

Potential Significant Impact?

No

No

No

No

NOTES: Operational mobile emissions were revised to align with more detailed project information from the
Project Applicant
.

SOURCE: ESA and Ramboll (see A
ppendix A

to this document
)

Table 4.3
-
4 and
Table 4.3
-
5 present the facility total annual operational emissions and their comparison to BAAQMD thresholds of significance for operations.

These tables show
that on a project
-
level
assessment, emissions do n
ot exceed
significant
significance

thresholds determined by BAAQMD
under CEQA
for criteria pollutants emitted during
operations, and therefore

would result in

are

less than significant

impacts
.

Construction Air Emissions

Less than Significant Impact
.

Const
ruction activities would result in emissions of
the
following non
-
attainment
pollutants
: r
eactive organic gases (ROG) and nitrogen oxides
(NOx)
, which are ozone precursors, and

particulate matter (PM
10 and PM

2.5 ).

These
pollutant

emissions would be generat
ed
in the form of fugitive dust
(PM
10 and PM

2.5 )

and in
the form of exhaust
by construction equipment, on
-
road vehicle trips of haul trucks for
delivering construction material, water trucks for site dust control, and construction worker commutes to and fr
om the project site.

Construction Dust

Less than Significant Impact
, after

Mitigation
.

Activities that generate dust include
excavation and equipment movement across unpaved construction sites. Dust can be an irritant causing watering eyes or irritation t
o the lungs, nose, and throat.

E
xcavation,
grading, and other construction activities can cause wind -
blown dust that adds PM
10 and
PM

2.5 to the local atmosphere. The BAAQMD has taken a qualitative approach to addressing fugitive dust emissions during const
ruction, such that any project that
implements the BAAQMD Basic Construction Mitigation Measures Recommended for All Projects (Best Management Practices)
would not result in a significant impact with
respect to fugitive dust

(BAAQMD 2017b)
.

Mitigation Meas
ure AQ
-
1: Best Management
Practices
, provided below, spe
cifies BAAQMD recommended measures and would apply
to all individual projects to address construction dust .

In conclusion, while air emissions

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from construction equipment are all below the BAAQMD CEQA

thresholds construction
dust emissions are always considered significant within the SFBAAB unless the mitigation measures below are applied.

Mitigation Measure
s

AQ
-
1: Best

Management Practices.

All subsequent projects, regardless of size,
The project

shal
l implement
the
following
best management practices to reduce construction impacts, particularly fugitive dust, to a less
-
than
-
significant level:

All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads)

shall be watered two times per day
, except
when not required for dust control
.

All haul trucks transporting soil, sand, or other loose material off -
site shall be
covered.

All visible mud or dirt track
-
out onto adjacent public roads shall be removed
usin
g 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 possib
le. 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 th e
California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations [CCR]). Clear signage shall be provided for construction workers at all access points.

All construction equipment shall be maintained and properly tuned in
accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation.

Post a publicly visible sign with the telephone number and person to contact at t
he Lead Agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s phone number shall also be visible to ensure compliance with applicable regulations.

BMP #6: All excavation, grading, and/or
demolition activities shall be
suspended when average wind speeds exceed 20 mph.

BMP #7: All trucks and equipment, including their tires, shall be washed off prior to leaving the site.

BMP #8: Unpaved roads providing access to sites located 100 feet or fur ther
from a paved road shall be treated with a 6
-

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

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

disturbing construction activities.

Additional BMP:

Install wind breaks (e.g., trees, fences) on the windward side(s) of actively disturbed areas of construction. Wind breaks should have at maximum 50 percent air porosity.

Additional BMP: Plant vegetative ground cover (e.g., fast -
germinating native
grass
seed) in disturbed areas as soon as possible and watered appropriately until vegetation is established.

Additional BMP: Install sandbags or other erosion control measures to prevent silt runoff to public roadways from sites with a slope greater than one pe
rcent.

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 1
0 calendar days.

Require zero visible fugitive dust and use fence line air monitoring to demonstrate compliance with this requirement.

Set requirements for when dust generating operations have to be shut down due to dust crossing the property boundary or

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

Prohibiting grading on days when a Spare the Air is in effect (
https://www.sparetheair.org/
) Prohibiting grading on days with an Air
Quality Index forecast of greater than 100 for particulates for the project area.
16 Operational Air Emissions

Less than Significant

Impact.

Based on the operational emissions modelled and

summarized

in

Table

4.3 -
4 and Table 4.3
-
5 above,

activities

related

to

operating

the

bioenergy

system would all be below significance thresholds.

Appendi
x

A

contain
s

additional

analyses and emissions

numbers
in

support

of

this
conclusion
.

c)

Expose sensitive receptors to substantial pollutant concentrations?

Construction

Less than Significant Impact
.

Construction equipment and associated heavy
-
duty truck
traffic generate diesel exhaust, which is a

known TAC. Construction exhaust emissions
may pose health risks for sensitive receptors.

However, there are no sensitive receptors
near
by

the project site, which is zoned for
open space

us
es
.

The nearest sensitive
receptor
s are

0. 75

miles southeast
, or mo
re than 1
,
000 feet, which is the distance
considered in the BAAQMD CEQA
G
uidelines
.

Therefore, any concentrations of
diesel

16 The additional
bulleted
items

to Mitigatio
n Measure AQ
-
1 (
formatted as s
ingle under
lin
e

since they
are not
updates
pro
posed in this updated IS
/MND
)

were added as expanded mitigation at the Planning Commission.

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particular matter (
DPM
)

generated during construction would be less than significant.

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

Operations

Less than Significan
t Impact
.

The proposed project would introduce
new sources of
TAC emissions, including the biogas engines and a new flare. Sources have been assumed to operate on a continuous basis at their maximum rated capacity, when determining emissions.

The proposed
p
roject would also introduce

a new source of DPM
and PM

2.5 emissions due to the installation of an
emergency
backup firepump

diesel
engine
generator

at the centralized treatment facility

that
would

use
California Air
Resources Board (CARB)
-

certified diesel
fuel. Emergency generators would be subject
to BAAQMD permit

requirements, which would ensure that operation of these generators would not significantly impact nearby receptors
.

These activities would result in minimal
TAC emissions for emergency operation
s only (typically less than 50 hours per year), and
therefore have negligible associated health risks to existing sensitive receptors in the area ,
the nearest being 0.
75 miles from the project site
.

Other annual TAC concentrations from
non
-
emergency operat
ions
of the generator
were
estimated
in an annual emissions
summary for operations at
the
project

site (Raven
,

2022
a
).

A
n HRA was not conducted
due to there not being any sensitive receptors within 1 ,
000 feet of the project site and
trigger levels not appl
ying to the
p
roject.

There would also be a rubber
-
tired loader
associated with operations that would run 24 hours a day 7 days a week. Emissions from the loader were calculated using CalEEMod and included in the operational emissions, shown in
Table 4.3
-
4 .

Reduced TAC emissions due to the reduction in flaring of landfill gas at the existing
WCCSL

flare were also quantified and included in this analysis.

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

The HRA uses EPA’s AE
RMOD model, version
22112
, to model hourly and annual
average TAC and PM

2.5 concentrations at nearby receptors. Modeling inputs, including emission rates in grams of pollutant emitted per second, and source characteristics (e.g., release height, stack diam
eter, plume width) were based on data provided by the
P
roject
A
pplicant, and all exposure parameters and the overall risk calculation methodology are consistent with guidance provided by OEHHA and BAAQMD. The results of this analysis are included in Append
ix
A

and are presented in
Table 4.3
-
6 .

The results in
Table 4.3
-
6 demonstrates that health impacts associated with operational sources are below significance thresholds, including impacts due to toxic air contaminants released by the biogas engines.

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T
ABLE

4.3 -
6 H
EALTH
R
ISK
I

MPACTS AT THE
M
AXIMUM
E
XPOSED
S

ENSITIVE
R

ECEPTORS

Risk Scenario / Receptor Type

Maximum
Cancer Risk
(per million)

Chronic
Hazard

Index

Acute
Hazard

Index

PM

2.5 concentration
(μg/m
3 )

Construction + Operations

Worker

3.0 0.058

0.22 0.57

Resident

0.70 0.0086

0.0039

0.024

School

0.49 0.011

0.036

0.030

Clinic

0.46 0.0058

0.032

0.016

Landfill Reductions

Worker

-

5.7 -

0.21 -

0.49 -

0.84 Resident

-

1.3 -

0.018

-

0.10 -

0.042

School

-

0.81 -

0.019

-

0.091

-

0.044

Clinic

-

0.79 -

0.011

-

0.077

-

0.026

Project Construction + Operations with Landfill Reductions

Worker

-

2.7 -

0.16 -

0.27 -

0.27 Resident

-

0.57 -

0.009

-

0.064

-

0.018

School

-

0.32 -

0.0084

-

0.055

-

0.014

Clinic

-

0.33 -

0.0056

-

0.045

-

0.010

BAAQMD Threshold of Significance

10.0 1.0

1.0 0.3

Exce
eds Significance Threshold?

Yes

No

No

No

NOTES: Numbers may not appear to sum correctly due to rounding.

SOURCE: Ramboll (Appendix A

to this document
)

The HRA also evaluated health impacts at Verde Elementary School (1.1 miles from the Project site) and

at the Contra Costa Health Clinic (1.2 miles from the Project site). The results are also
presented in Table 4.3
-
6 and
documented in Appendix
A
.

As shown in
Table 4.3
-
6, h
ealth impacts due to toxic air contaminants at each location are below significance
thresholds.

The HRA concluded that the project

provides an overall
reduction

of cancer risk, chronic
hazard index, acute hazard index, and particulate matter concentrations as compared to the portions of the existing landfill flare operation it would be re placing.

Cumulative Impact

Cumulative community risk impacts were addressed through an evaluation of TAC sources located

within

1,000

feet

of the sensitive receptors.

These

sources

include

freeways

or

highways, busy surface streets, and stationary sources
identified by BAAQMD. For
local roadways, BAAQMD has provided the
Roadway Screening Analysis Calculator
to
assess whether roadways with traffic volumes of over 10,000 vehicles per day may have a

potentially significant effect on a proposed Project (BAAQMD,

2015). These estimated

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

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

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T
ABLE

4.3 -
7 C

UMULATIVE
H
EALTH
R
ISK
I

MPACTS AT THE
M
AXIMUM
E
XPOSED
S

ENSITIVE
R

ECEPTORS

Receptor Type / Risk Scenario

Maximum
Cancer Risk
(per million)

H
azard

Index

PM

2.5 concentration
(μg/m
3 )

Worker

Existing Stationary Source Risk

45.0 0.52

1.02 Existing
Roadway

Source Risk

1.8 --

0.04 Existing Railway Source Risk

3.7 --

0.0049

Project Risk

(Construction + Operations + Landfill Reductions)

-

2.7 -

0.16 -

0.272

Total (P
roject Risk + Exiting Risk)

47.6 0.36

0.797

BAAQMD Cumulative Threshold of Significance

100.0

10.0 0.8

Exceeds Significance Threshold?

No

No

No

Resident

Existing Stationary Source Risk

0.0041

4.70E
-
05 0.001

Existing Roadway Source Risk

6.6 --

0.19 E
xisting Railway Source Risk

4.3 --

0.0059

Project Risk

(Construction + Operations + Landfill Reductions)

-

0.57 -

0.009

-

0.018

Total (Project Risk + Exiting Risk)

10 -

0.009

0.18 BAAQMD Cumulative Threshold of Significance

100.0

10.0 0.8

Exceeds Signifi
cance Threshold?

No

No

No

School

Existing Stationary Source Risk

7.10E
-
05 8.20E
-
07 1.80E
-
05 Existing Roadway Source Risk

3.2 --

0.074

Existing Railway Source Risk

15 --

0.02 Project Risk

(Construction + Operations + Landfill Reductions)

-

0.32 -

0.008

-

0.014

Total (Project Risk + Exiting Risk)

18 -

0.0084

0.08 BAAQMD Cumulative Threshold of Significance

100.0

10.0 0.8

Exceeds Significance Threshold?

No

No

No

Clinic

Existing Stationary Source Risk

5.70E
-
05 6.60E
-
07 1.40E
-
05 Existing Roadway Source R
isk

2.8 --

0.067

Existing Railway Source Risk

5.6 --

0.0077

Project Risk

(Construction + Operations + Landfill Reductions)

-

0.33 -

0.006

-

0.01 Total (Project Risk + Exiting Risk)

8.1 -

0.0056

0.065

BAAQMD Cumulative Threshold of Significance

100.0

10.0 0.8

Exceeds Significance Threshold?

No

No

No

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NOTE: The BAAQMD tool for calculating chronic hazard index does not include risk from railways or roadways . Therefore, cumulative
chronic hazard index for the resident, school, and clinic receptors would likel y not be negative
;

however the project presents an
overall reduction in chronic risk to the existing conditions.

SOURCE:

Ramboll

(Appendix A

to this document
)

Table 4.3
-
7 reports both the project

and cumulative community risk impacts. The
cumulative canc
er risk, hazard indexes, and
PM

2.5 concentrations would not exceed their
cumulative source thresholds

and the project presents an overall
reduction

risk to the
existing
conditions
. Thus, a
less
-
than
-
significant cumulative

impact would occur during
construc
tion and operation of the proposed project.

d)

Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?

Less than Significant Impact
.

Existing uses on and near the WCCSL include operations
that are amon
g t
ypical odor sources of concern
. These

include wastewater treatment
plants, sanitary landfills, transfer stations, composting facilities, petroleum refineries, chemical manufacturing facilities,
and
auto body shops. As a hydrogen production
facility, the

p
roject
would

include organic feedstock processed during operations at the WCCSL
, which is

known to
create odors.

WCCSL
implement
s

various
control

measures

to minimize odors

associated with operation of the mixed waste processing.

The nearest sensitive r
eceptors to the project site are
residences at generally West
Gertrude Avenue/Malcolm Drive, approximately 0.75 miles southeast .

This is closer than
the 1.0
-
mile odor screening distance for greenwaste handling established in the BAAQMD’s CEQA Guidelines
.

A
lso, an elementary school and a health clinic exist
approximately 1.1 and 1.2 miles, respectively, from the project site

-

slightly beyond the
screening distance
.

Uses
between the project site and these
the nearest sensitive receptors
to the southeast
incl
ude the
West
County Wastewater

District Treatment Plant,
EBMUD’s North Richmond Water Reclamation Plan
t
, the Richmond Sanitary District,
and other refuse services, automobile repair and towing businesses, an
d

lawn services,
etc.

Topography in the area is r
elative flat, and no substantial areas of vegetation exist.

The p
revailing wind direction in this area for the majority of the year (February through November) is from the south, blowing away from area of sensitive receptors. This prevailing wind direction

shifts to the north, blowing toward the sensitive receptor area, for approximately two months of the year (December and January).

Nuisance odor from Raven is unlikely
since

based upon the initial process step of
subjecting the

feedstock
material would on
ly be on the feedstock management area floor
for relatively short periods of time.

to drying given the
p
roject procedures and
requirements outlined below.

Nor would the system’s tail gas or
the infrequent use

of the
as
-
needed flare generate noticeable odo
r. Also, other than the input

of

organic

feedstock

within

the

system,

the

process

would

not

involve

the

storage

or processing of other
potentially odorous materials nor contribute to odor from nearby existing WCCSL activities.

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The
Raven SR
Project
introdu
ces a number of

odor
minimization procedures and
compliance with regulatory requirements. First, it is important to note that the feedstock for the Raven process will only include pre
-
processed material consisting primarily of
blended green waste and food
waste. The source of the material will be from the onsite composting
facility

referred to as
OMPF. The

OMPF receives vehicle loads directly from
residential and commercial organics collection programs. The OMPF operating procedures include initial visual s
creening and a load checking program designed to
identify and remove prohibited material including any highly odorous loads. After screening and load checking, remaining organic material will be pre -
processed by
grinding. Only material that has been throug
h the screening, load checking and grinding
process at the OMPF will be delivered to the Raven SR facility, thus minimizing the potential for receiving prohibited or highly odorous material. In addition, all incoming pre
-
processed feedstock received at the

Raven SR facility will also be subject to the
Raven SR’s own screening and load checking program as required by State solid waste facility regulations.

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

Typically, any material received will be processed within 24 hours of receipt through the hydrogen conversion system. As a requirement of both the CUP and the Solid Waste Facility Permit

(SWFP) for the facility all feedstock material shall, at a maximum, be processed within 48 hours of receipt

(draft Condition of Approval #48)
.

Regardless, as described in Section 2,
Project Description¸
the project would involve

o
dor control mechanisms to

minimize possible additional odors from its operation. T he
In
addition, the

proposed industrial metal canopy would be placed over the feedstock floor and infeed equipment to prevent stormwater contact.

The project may incorporate control
measures similar t
o those current employed by WCCSL, such as ensuring the input of feedstock into the system within a designated period of time from receiving it from WCCSL’s onsite organic material processing facility to prevent potential odor buildup;

The
p
roject will als
o include

routine cleaning of floors, walls, and equipment
;

and
use of
odor suppressants as deemed necessary. Odor control would be added to the management area if objectionable odors occur. The Raven facility could also store topical treatment solutions (
non
-
toxic and biodegradable) onsite, which would be applied to neutralize odors if an immediate need arises. To the extent that any new sources of odor is attributable to the proposed
project
, the
P
p
roject

A
a
pplicant shall promptly log and
respond to any c
omplaints and
work to

remediate
d
.

The CUP and SWFP impose additional odor minimization provisions and requirements on facility operations. These include but are not limited to:

Maximum Daily Quantities
–

99.9 tons per day

Maximum Storage Capacity
–

200 to
ns

Daily facility cleaning

Compliance with state minimum standards under solid waste provisions

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contained in Title 14 and Title 27 including Nuisance Control and odor compliant response and reporting requirements

Cooperation with Bay Area Air Quality Manag
ement District (BAAQMD),
the City and the County, to identify and implement measures to minimize odor emissions through the development and implementation of an Odor Prevention and Management Plan (OPMP)

(draft Condition of Approval
#77)
, which will requir
e an Annual Evaluation Report
.

This includes the
following minimum measures:

o

feedstock load checking at the Republic site for identification and removal of prohibited material including any highly
-
odorous loads;

o

feedstock pre
-
processing at the Republic
site before being sent to the
Raven facility;

o

operations protocol for first in/first out feedstock consumption;

o

feedstock will typically be processed within 24 hours with a maximum limit within 48 hours of receipt; v) daily cleaning of the feedstock hand
ling area; and

o

use of odor suppressants if necessary.

Therefore, any odor impacts from the proposed project would not be considered
substantial nor likely
significant and the Raven SR Project will not
contribute

substantially
significant odor emissions

to

an
y

existing

odor

sources

of

the

WCCSL. The
impact would be less than significant.

References

BAAQMD, 2017a
.

Clean Air Plan, Spare the Air, Cool the Climate
. April

19, 2017. Available at
https://www.baaqmd.gov/~/media/files/planning
-
and
-
research/plans/2017
-
clean
-
air
-
plan/attachment
-
a_
-
proposed
-
final
-
cap
-
vol
-
1 -
pdf.pdf?la=en
. Accessed December 2020.

BAAQMD, 2
017b
.

CEQA Air Quality Guidelines. Available online:
https://www.baaqmd.gov/~/media/files/planning
-
and
-
research/ceqa/ceqa_guidelines_may201
7 -
pdf.pdf?la=en
. Accessed April 22, 2022.

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

RAVEN
,
2022
a

Air Permit Application
-
Bioenergy Fa
cility
. Prepared by Ramboll US Consulting,
Inc.
,

(Ramboll) for Raven SR, April 2022.

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B
lank Page

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4.4 Biological

Resources

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impac
t

No

Impact

Biological
Resources

Would

the

project:

a)

Have

a
substantial

adverse

effect, either

directly or

through habitat

modifications,

on any

species

identified
as
a

candidate,

sensitive,

or

special
-
status

species in

local

or

regional

pla
ns,

policies,

or

regulations,

or

by
the

California

Department of

Fish

and

Wildlife

or

United States

Fish

and
Wildlife

Service?

b)

Have

a
substantial

adverse

effect

on

any riparian

habitat or

other

sensitive

natural

community

identified

in

loc
al

or

regional

plans, policies,
and

regulations

or

by
the

California

Department of

Fish

and

Wildlife

or

United
States

Fish

and Wildlife

Service?

c)

Have

a
substantial

adverse

effect

on
State

or

federally protected wetlands

(including,
but

not

limited

to,

marsh,

vernal

pool,

coastal,

etc.)

through

direct

removal,

filling, hydrological

interruption,

or

other

means?

d)

Interfere

substantially

with the

movement

of

any

native

resident or

migratory

fish

or

wildlife

species

or

with

esta
blished native

resident

or

migratory

wildlife

corridors,

or

impede the

use of

wildlife

nursery

sites?

e)

Conflict

with

any

local

policies or

ordinances

protecting biological

resources,

such

as

a
tree

preservation

policy

or

ordinance?

f)

Conflict

with

the

provisions

of

an

adopted

Habitat

Conservation

Plan, Natural

Community Conservation

Plan,

or

other

approved local,

regional,

or

State

habitat
conservation

plan?

Setting

The project site is located
in the upland area of the

approximately 340
-
acre WCCSL,
within the
context of expansive
grasslands and hills. The WCCSL borders

San Pablo Bay

and
tidal
marshland of
naturalized portions of
San Pablo
and Wildcat creeks
.

The

broader

surrounding area
of the WCCSL property
is a low den
sity
industrial and open space area.

The local context in Figure
1 -
2 shows the project site located approximately 0.25
-
mile east of the
San Pablo Bay shoreline, mudflats
,

and open water. The tidal marshland of San Pablo Creek
is

approximately 0.3 miles nor
th/northeast of the project site, bordering the WCCSL north boundary which is an elevated levee. As shown in Figure 2
-
0, the marshlands of Wildcat Creek sit

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approximately 280 feet south/southeast of the project site, bordering the WCCSL south boundary ,

whi
ch is also an elevated levee.

A

closed Class I landfill

is immediately north of the project site
and the main access road supports a cover of non
-
native grassland and ruderal
vegetation
species.

No trees exist on the project site. Several landscape trees o
ccur at

the Golden Bear Waste
Recycling Facility

(part of the BMPC)
, located approximately 300 feet southwest of the project site.

Biological resources were
characterized

through the review and compilation of existing
information

and a biological reconnais
sance survey conducted by ESA biologists on June 29,
2022
.

T
he
biological reconnaissance

study area included

the
project construction area

plus a
n
additional

250
-
foot buffer
, to account for potential indirect impacts to special
-
status species
. The
study ar
ea

for special
-
status plant

s
pecies

includes the
project construction area
, plus a
n
additional

10 -
foot buffer due to the lack of potential for indirect impacts to plants.

No detailed
surveys were conducted
for special
-
status plants or wildlife
or are
deeme
d

necessary based on the
developed and manipulated
conditions of the
project
site

and surroundings
, the scope of the
proposed project’s construction and operations, and
the
proposed standard methods to minimize
disturbance to sensitive resources in the vic
inity.

Species / Habitats

The uplands
of

the WCCSL are either
devoid of vegetation from on
-
going landfill operations and
roadways, or are dominated by nonnative grasses and forbs. Plant species observed in the grassland at the periphery of the project site

are dominated by non
-
native species such as

Italian
rye

grass

(
Festuca perennis
), wild oats (
Avena
spp.), storksbill (
Erodium cicutarium
), bristly ox
-
tongue (
Helminthotheca echioides
), and ribwort (
Plantago lanceolata
). Several weedy species are
also present

along the margins of the site
, including fennel

(
Foeniculum vulgare
)
, wild radish

(
Raphanus

spp.)
,
black
mustard

(
Brassica nigra
)
,
curly dock (
Rumex crispus
), prickly lettuce

(
Lactuca serriola
), and iceplant (
Carpobrotus edulis
)
. Clumps of native coyote brush
(
Baccharis
pilularis
)

are scattered through grasslands, road margins, and upper edge of the marshlands and levees.

While the highly disturbed project site provides little

habitat that is suitable for special
-
status
plants and wildlife, the surrounding grasslands and wetlands provide habitat for a variety of wildlife and plant species. Wildlife observed in the surrounding study area during the site reconnaissance survey inc
lude
American crow (
Corvus brachyrhynchos
), red
-
tailed hawk (
Buteo
jamaicensis
), western bluebird (
S
i
alia mexicana
), barn swallow (
Hirundo rustica
), common raven
(
Corvus corax
), Canada goose (
Branta canadensis
), wild turkey (
Meleagris gallopavo
), black
-
nec
ked
stilt

(
Himantopus mexicanus
), turkey vulture (
Cathartes aura
), mallards (
Anas
platyrhynchos
), killdeer (
Charadrius vociferus
), and several gull species (
Larus

spp.)
.

Sensitive aquatic habitats occur outside of the project boundary, and include wetland s
,
sloughs,
creek channel
s
, and
the San Pablo B
ay shoreline.

San Pablo Creek is located approximately 600
feet east/northeast of the project site and is separated from WCCSL

developed areas by a levee.

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

0.3 miles north/northeast

of the project

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site. Numerous s
horebirds, wat
erfowl, and other wildlife use the marsh and mudflats for foraging and

resting
; however, the marsh is beyond the 250
-
foot project study area
.

A number of special
-
status animal species have been reported from
nearby
creek
s

and
marshes,
including
the
s
tate
and federally
-
endangered salt marsh harvest mouse (
Reithrodontomys
raviventris
)

and
California
Ridgway’s

rail

(
Rallus longirostris obsoletus
)
,
state
-
threatened
California black rail

(
Laterallus jamaicensis coturniculus
)
, and
several

other species considere
d
to be California
Species of
Special Concern
and Fully Protected by the State.

Appendix
B

present
s

the special
-
status species considered in the analysis, including each species’ legal or protective status, habitat requirements, and blooming period (for pl ants), and the potential for
occurrence within
study areas.

Higher elevations of the marsh typically provide important refuge for small

mammals and birds during storms and high tides. However, due to
the extent of
developed and otherwise disturbed habitat
on the project site
, the narrow band of cover along the
lev
ee slope
, and the intensity

of human activity
,

the project site is not expected to provide
upland
retreat habitat
for wildlife species, including species associated with salt marsh and other wetlan d
habitats
.

Several special
-
status plant species are known from the uplands and coastal salt marsh

habitats

along the shoreline of San Francisco and San Pablo Bays, but none have been reported

from the

vicinity of the WCCSL. A single occurrence of fragrant

fritillary (
Fritillaria liliacea
)

was
reported from the Point Richmond area in 1900, but this occurrence is believed to have been

extirpated by development, and suitable habitat is absent on the site. Other special -
status plant

species known from marshlan
d habitat along the shoreline of San Pablo Bay include: the State

rare soft
-
haired bird’s beak
(
Chloropyron molle

ssp.
molle
), M
ason’s lilaeopsis (
Lilaeopsis

masonii
), and San Francisco gumplant (
Grindelia hirsutula
var.
maritima
).

T
hese

California Rare
Pl
ant Rank
1B
species
are considered rare under

Section 13580 of the California Environmental
Quality Act (CEQA) Guidelines. None have

been reported from the WCCSL, and suitable habitat
is absent on portions of the site proposed

for improvements.

Wetlands

No

wetlands or other aquatic resources occur within the project site.

Jurisdictional wetlands and
unvegetated

waters extend over the northern

coastal salt
marsh,

open water habitat, and San Pablo

Creek
channel.

The sloughs,
creek channel, and bay shoreline

w
hich border the WCCSL property
are all under

tidal
influence.

The upland
portions

of the WCCSL property do

not support
wetlands, and the
engineered

basins designed for
runoff

control and leachate

treatment,

including
basins located to the south and west of

the project site, are
exempt

from

state and federal wetland
jurisdiction
.

Evaluation

a)

Have a substantial adverse effect, either directly or through habitat modifications, on any
species identified as a candidate, sensitive, or special -
status species in

local or
regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or United States Fish and Wildlife Service?

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A list of special
-
status species that occur in the project region was identified based upon review of exist
ing information
, including
q
ueries of the California Natural

Diversity
Database (CNDDB), U.S. Fish and Wildlife Service (USFWS) Official Species List, and the California Native Plant Society (CNPS). Habitats at the project area were assessed for their pote
ntial to support special
-
status species using information about local species
occurrences and species’ habitat requirements, in
combination with the site visit

described above

(
Appendix
B
).

Plants

No special
-
status plant species are
expected

to occur on th
e
disturbed

project site. Site
preparation for the project would involve minimal grading for the erection of the modular building and
the
replacement of existing compacted soil, ruderal groundcover and partial
ly

pav
ed

areas

where special
-
status plants are
not expected to occur
.

Hence, no
impacts would occur to special
-
status plants.

Wildlife

The project site exists within
a
previously disturbed upland portion of the WCCSL that
do
es

not provide habitat for special
-
status
wildlife
species.

Due

to the extent o
f past
development,
no

special
-
status
wildlife

spec
ies are expected to occur within

the project
site
. Additionally, basins and runoff control ponds located to the south and west of the project site do not provide suitable habitat for special -
status species
.

Beyond the site boundaries,
S
s
urrounding wetland and annual grassland habitat may
provide habitat for special
-
status wildlife species. The following species are considered to have the potential to occur within these areas: short
-
eared owl (
Asio flammeus
)
, western
burrowing owl (
Athene cunicularia hypugaea
), northern harrier (
Circus hudsonius
),
loggerhead shrike (
Lanius ludovicianus
), California black rail (
Laterallus jamaicensis
coturniculus
), and California Ridgway’s rail (
Rallus longirostris obsoletus
)
.

Short
-
eared
owl, western burrowing owl, northern harrier, and loggerhead shrike are California
Species of Special Concern.

Uplands and wetlands outside of the project site provide potential foraging habitat for these species. Upland grassland and ruderal habitats provide
potential nesting habitat. Short
-
eared owl and northern harrier are ground nesting species, while loggerhead shrikes nest in shrubs and occasionally items such as brush piles, generally between two and four feet off the ground. Western bur rowing owls nest
underground in burrows dug by mammals such as California ground squirrels (
Otospermophilus beecheyi
)
.

California Ridgway’s
is listed as endangered under both
the Federal Endangered Species
Act (
FESA
)

and
the California Endangered Species
Act (
CESA
)
, and is a state fully
-
protected species. Ridgway’s rails are found in tidal and brackish marshes where they typically construct nests in or under dense marsh vegetation, such as marsh gumplant and pickleweed at an elevation high enough to avoid
inundation during high tides.

California
black rail

is listed as threatened under
CESA

and is a

state

f
ully
-
p
rotect
ed s
pecies.

This
species nests and forages in tidal
emergent wetland.

Suitable marsh habitat

for both of

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these species

is present within
500
feet of the project site

and multiple occurrences are
known from marshes adjacent to or nearby the project
site
.

In addition to the aforementioned special
-
status species, common r
aptors and other bird
species may forage
in uplands and marshes on the edges

of the study area.

While no trees
exist on the project site, trees approximately 300 feet southwest of the
project

site
at the
Golden Bear Waste Recycling Facility

have potential to
support raptor
nest
ing
. Current
activity on the project site involves lar
ge truck traffic, human activity, operation of
machinery and elevated noise levels.

Regardless, some bird species, such as killdeer
(
Charadrius vociferus
) and American crow (
Corvus brachyrhynchos
), tend to be highly
tolerant of human disturbance and may st
ill nest in areas with relatively high levels of
human activity
.

Construction

Less than Significant Impact
, after Mitigation
.

Bird species listed under FESA and
CESA, as well as non
-
ESA
-
listed birds, are afforded conservation protections. Breeding birds

are protected under California Fish and Game Code

(FGC)

Section 3503 and
raptors are protected under Section 3503.5. In addition, FGC
Section 3513 and the
Federal MBTA (16 USC, Sec. 703 Supp. I, 1989) prohibit the killing, possession, or trading of migrat
ory birds. Finally,
FGC
Section 3800 prohibits the taking of non
-
game
birds, which are defined as birds occurring naturally in California that are not game birds or fully protected species.

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

Also, the project site is disturbed and provides poor habitat for nesting birds.

However, equipment staging and project construction could re nder the
site
and adjacent areas
temporarily unsuitable for breeding birds due to the noise, vibration, and increased activity levels associated with grubbing, earth moving, heavy equipment operation, and increased human presence even when the nest itself is
unaffected. These activities could cause birds that have established a nest prior to the start of construction to change their behavior or even abandon an active nest, putting eggs and nestlings at risk for mortality. This would be considered a signific ant impact.

Implementation of Mitigation Measure BIO
-
1: Avoid and Minimize Impacts to Nesting
Birds,
Except

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

Mitigation Measure BIO
-
1 : Avoid and Minimize Impa
cts
to Nesting Birds, Except
Rails

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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 nes
ting birds
. 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 absenc
e of nesting birds no more than 14 calendar days
prior to construction activities or after any construction breaks of 14 calendar days or more. Surveys shall be performed for the project construction and staging areas and suitable habitat within 250

feet o
f 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 n
esting surveys, no
-
disturbance buffer zones shall be established around nests, with a buffer size established by the qualified biologist. Typically, these buffer distances are between 50 feet and 250

feet for passerines and between
150

feet and 500 feet fo
r raptors. These distances
may be adjusted depending on the level of surrounding ambient activity and if an obstruction, such as a building or structure, is within line -
of
-
sight between the nest and
construction. Reduced buffers may be allowed if a full
-
ti
me qualified biologist is present
to monitor the nest and has authority to halt construction if bird behavior indicates continued activities could lead to nest failure. Buffered zones shall be avoided during construction
-
related activities until young have

fledged or the nest is otherwise
abandoned.

If active burrowing owl dens are found within the survey area, the P
roject
A
pplicant shall implement measures at least equal to the 2012 (or subsequent applicable) CDFW Staff Report

(CDFG, 2012),

as determined b
y 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 h
eavy equipment
, adjacent to tidal marsh areas
(within 500 feet

[150 meters]

or a distance determined in coordination with
U.S. Fish
and Wildlife (
USFWS
)

or
the California Department of Fish and Wildlife (
CDFW)
),

shall

be avoided during the breeding season
from February 1 through August 31.

If areas within
500 feet of

rail habitat cannot be avoided during the breeding season (February 1 through August 31), protocol
-
level surveys shall be conducted to
determine rail
nesting
locations.

T
he surveys will focus
on potential habitat that
could

be
indirectly
disturbed by construction activities during the breeding season to ensure that rails are not
breeding

within 500 feet of project activities
.

Survey methods for rail
s

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

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

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rou
nds 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
adopte
d by Invasive Spartina Project (ISP) and Point Blue Conservation Science to survey
Ridgway
’s rails at sites throughout San Francisco Bay

Estuary
.

The

survey
protocol for Ridgway’s rail
is
summarized below.

Previously used survey locations (points) should
be used when available to
maintain consistency with past survey results. Adjacent points

should be
at least
200
meters apart along transects in or adjacent to areas

representative of the
marsh
.

Point
s should be located to minimize disturbances to marsh veg etation.

Up to 8 points can be located on a transect.

At

each
transect
,
three

surveys
(rounds)
are to be conducted
, with the first round
of s
urveys initiated between January 15 and February
6, the second round
performed February 7 to February 28, and the t
hird round March 1 to March 25
.

Surveys should be spaced at least
one

week apart and
the period between March
25 to April 15 can be used to complete surveys delayed by logistical or weather issues
. A
Federal Endangered Species Act Section
10(a)(1)(A) permi
t is required
to conduct active surveys.

Each point on a transect will be surveyed for 10 minutes each round. A recording of calls available from USFWS is broadcast at each point. The recording consists of 5 minutes of silence, followed by a 30
-
second reco
rding of Ridgway’s rail
vocalizations, followed by 30 seconds of silence, followed by a 30 -
second
recording of California black rail, followed by 3.5 minutes of silence.

If no
breeding Ridgway’s rails or black rails

are detected

during surveys,

or

if

their

breeding
territories can be avoided

by 500 feet (150 meters)
, then
p
roject 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 f
ollowing measures would a
pply 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 nes
ting season based on nest location, natural visual barriers (e.g., levees) between the project and marshlands, and the distance between proposed activities and identified activity centers. If impact cannot be avoided during the rail nesting season, activit
ies would be delayed until after the nesting season.

Operations

Less than Significant Impact
.

Current activity on the project site involves large truck traffic, human activity, operation of machinery and elevated noise levels

associated with
the
Republic
Services

BMPC property and the existing landfill power plant.

The
proposed Raven SR operation

is not expected to significantly change the level of activity that is currently conducted within the project area and, therefore, long -
term operation of
the Raven

SR operation is not expected to result in significant impacts to biological resources within the project area.

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There is also existing permanent lighting associated with the current 24 -
hour activities
of
the
adjacent
BMPC and the project site
. The propose
d
project would not substantially

increase existing
nighttime
lighting

to result in an
adverse impact

to
existing bird species.

The project propos
es LED

lighting
mounted
on 30
-
foot
-
tall poles. Similar to existing
conditions, the project

lighting would be f
ocused and shaded, incorporating directional
shading
(down
-
shot reflectors) to limit light pollution during

night operation
s
.

The
project would place nine single
-
light fixtures at throughout the site and three double
-
light
fixtures in the truck loading are
a in the south portion of the site.

No
part of the proposed facility would exceed 31 feet in height, which is the height of the industrial feed
material handler. Other elements of height and size include the nitrogen
tank (30 feet tall)
; the
cooling tower

and the fire water tank (both 25.5 feet tall); and the
ind
ustrial metal canopy

over the feed/unload storage area
, the adjacent steam reformer
structure, and the nitrogen tank (each
26 feet tall
)
.

Therefore, no part of the project would

exceed

45 feet

in h
eight, in which case the project would comply with the
City of
Richmond’s Bird
-
Safe Buildings Municipal Ordinance.

Overall, the proposed project also would not alter any of the area’s natural resources or native vegetation in a way that could adversely im
pact biological resources. The impact
would be less than significant.

b)

Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California De
partment of Fish and Wildlife or United States Fish and Wildlife Service?

No
I
mpact
.

The project site does not contain any riparian habitat or other sensitive natural communities. The nearest sensitive habitat is well -
preserved coastal salt marsh
occur alo
ng the San Pablo Bay shoreline
, Wildcat Marsh,

and along the upper banks of
San Pablo Creek.

T
he project site is located 0.25 miles east of the shoreline ,

approximately 0.3 miles south of San Pablo Creek’s upper banks , and within 300 feet
of
Wildcat Marsh,

which is separated from the project site by the Bay Trail levee.

The
proposed project does not involve any activity that would affect these areas. Therefore ,

the proposed project would have no impact.

c)

Have a substantial adverse effect on State or feder
ally protected wetlands
(including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?

No

Impact
.

The

project

site

does

not

contain

any

State

or

federally

protected

wetlands
.

T
he

proposed development

would not

impact

any waterbodies i
n

any

way

and
th
erefore

would

have

no

impact

on protected wetlands
.

d)

Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established nati
ve resident or migratory wildlife
corridors, or impede the use of wildlife nursery sites?

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Less than Significant Impact
.

The
project

site

is

not in a

natural condition and contains
development and current truck and other operations of the BMPC.

Due to the e
xisting
developed nature of the site, the project site does not provide suitable habitat to be considered a wildlife nursery site. Additionally, wildlife movement within the project site is restricted by existing privacy fencing that surrounds the project area. While the
surrounding uplands and wetlands provide habitat for the movement of native resident and migratory wildlife, activities associated with the project are not expected to directly impact these areas or impede wildlife movement
. Therefore, this

impact would be less than
significant.

e)

Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?

Less than Significant Impact
.

Construction or operation of the proposed project
wou
ld

not conflict with any local policies or ordinances protecting biological resources.

There are
no existing trees on the project site, nor are any proposed

d
ue to limited space and
potential safety hazards
. However, a
s part of the proposed project
,
off
-
si
te landscaping
improvements
are proposed
to the Wildcat Marsh Trail and trail head parking located approximately 1,000 feet east of the project
site.

Eleven drought
-
tolerant trees would be
planted: either six large Coast Live Oak (
Quercus agrifolia
) or Big

Leaf Maple (
Acer
macrophyllum
), and five small California Buckeye (
Aesculus californica
). Both species
are on City’s approved list of trees. Tree size planted would be associated with 1 5
-
gallon
containers
.

The

project is subject

to and
would

adhere

to the

City’s local tree protection
policies and regulations.

Also, a
s addressed under
Section

4.12,
Noise and Vibration
,
of
this checklist,
the project
would

adhere to the City of Richmond Noise Ordinance
regarding noise levels during temporary construction act ivity, as well as the operational
noise levels.

Therefore, this impact would be less than significant.

f)

Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or Stat e habitat
conservation plan?

No

Impact
.

The project site does not lie within the boundaries of any an adopted Habitat Conservation Plan (HCP) or Natural Community Conservation Plan (NCCP) or any other approved local, regional, or State habitat conservation

plan.

References

California Department of Fish and Game

(CDFG)
. 2012. Staff Report on Burrowing Owl
Mitigation. Dated March 7, 2012.

California Department o
f Fish and Wildlife (CDFW)
. List of Vegetation Alliances and
Associations (or Natural Communities

List), Vegetation Classification and Mapping
Program. Available online: www.dfg.ca.gov/biogeodata/vegcamp/natural_comm_list.asp.

Accessed
June 14, 2022
.

4. Environmental Checklist and
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CDFW. California Natural Diversity Database (CNDDB) for 7.5 -
minute topographic quadrangles
Richmond, B
riones Valley, San Francisco North, Oakland West, Oakland East, Petaluma Point, Mare Island, Benicia, San Quentin
, Commercial Version.

Accessed
June 14, 2022
.

CDFW.

Natural Diversity Database.
2022
.

Special Animals List. Periodic publication.

CDFW. Specia
l Vascular Plants, Bryophytes, and Lichens List.

Accessed
2022
.

California Native Plant Socie
ty (CNPS)
. Inventory of Rare and Endangered Plants (online
edition,
v9
-
01 1.
5 ),

California Native Plant Society, Sacramento, CA. Available at:
www.rareplants.cnps.
org. Accessed

June 14
, 2022
.

City of Richmond, 2012.

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

Adopted April 25, 2012.

Contra Costa County 2004.

Environmental Impact Report on the West Contra County Sanitary Landf
ill Bulk Materials Processing Center and Related Actions ,
SCH. 2002102057
.

June
2004
.

Contra Costa County 2009.

Addendum to the

Final

EIR

for the WCCSL BMPC and Related
Actions
,
SCH. 2002102057
. 2009
.

United States Fish and Wildlife Service (USFWS)
.

20 22
.

List of threatened and endangered
species that may occur in your proposed project location, and/or may be affected by the
Raven SR Bioenergy Project
. Consultation Code:
2022
-
0054185
.

June 14, 2022.

Wood, J.K., Nur, N., Salas, L. and O.M.W. Richmond. 2017.

Site
-
specific Protocol for
Monitoring Marsh Birds: Don Edwards San Francisco Bay and San Pablo Bay National Wildlife Refuges
. Prepared for the U.S. Fish and Wildlife Service, Pacific Southwest Region Refuge Inventory and Monitoring Initiative. Point Blue Conservation Science.

Petaluma, CA.

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4.5 Cultural

Resources

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Cultural

Resources

Would

the

project
:

a)

Cause

a
substantial

adverse change

in
the

significance

of
a
historical

resource
as
pursuant

to

Section

15064.5?

b)

Cause

a
substantial

adverse change

in
the

significance

of
an
archaeological

resource

pursuant

to
Section 15064.5?

c)

Disturb

any human

remains, including those interred

outside

of formal

cemeteries?

Setting

To determine the cultural resources sensitivity of the project site, ESA completed a records search and background research, including a revie
w of historic maps, aerial imagery, and geologic/soils
data.

ESA
staff
conducted a records search at the Northwest Information Center (NWIC) of the California Historical Resources Information System on
March 23, 2022

(File No.

21 -
1575
). The
purpose of the
records search was to (1) determine whether known cultural resources have been recorded
in the vicinity of the

project site
; (2) assess the likelihood for unrecorded cultural
resources to be present based on historical references and the distribution of ne arby sites; and (3)
develop a context for the identification and preliminary evaluation of cultural resources. The records search consisted of an examination of the following documents:

NWIC digitized base maps (USGS
San Quentin
, CA 7.5
-
minute topographic
map), to identify
recorded archaeological sites and studies within a 0.
5 -
mile radius of the
project site
.

NWIC digitized base maps (USGS
San Quentin
, CA 7.5
-
minute topographic map), to identify
recorded historic
-
era resources of the built environment (bui
lding, structures, and objects)
within
and adjacent to

the
project site
.

Resource Inventories:

California Inventory of Historical Resources, California Historical Landmarks, Built Environment Resource Directory

(BERD) (through March 2020) and
Archaeologic
al Determinations of Eligibility
(as of April 2012) for
Contra Costa

County.

No
cultural resources

have been previously recorded in the vicinity of the
project site

and there
are no historic
-
age architectural resources in or adjacent to the project site .

T
he nearest cultural
resources are a series of pre
-
contact archaeological sites nearly 1 mile to the east that contribute to the Lower San Pablo Creek Archaeological District. These resources would not be impacted by the proposed project.

The underlying geo
logy of the
project site

consists of
artificial fill over
Holocene Bay Mud deposits
.

The historic shoreline is approximately 0.4 miles (2,000 feet) east of the project site; pre
-
contact and historic
-
era archaeological sites in this environment would be
loc
ated at or very near to the historic shoreline.

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Therefore, this analysis concludes that the sensitivity for pre -
contact
and
historic
-
era
archaeological resources is low

and the potential to uncover archaeological resources during project implementation is

also low
.

Evaluation

a)

Cause a substantial adverse change in the significance of a historical resource as pursuant to Section 15064.5?

No Impact
.

CEQA Guidelines Section 15064.5 requires the lead agency to consider the effects of a project on historical
resources. A historical resource is defined as any
building, structure, site, or object listed in or determined to be eligible for listing in the California Register

of Historical Resources (California Register)
, or determined by a lead
agency to be signif
icant in the
architectural, engineering, scientific, economic, agricultural, educational, social, political,
or
cultural annals of California. The following discussion focuses on architectural and structural resources. Archaeological resources, including t hose
that are potentially
historical resources according to CEQA Guidelines Section 15064.5, are addressed below under
question

b).

As a result of the records searc
h and

background research, it was
determined
that there are
no
architectural or structural r
esources
in or adjacent to

the
project site

that

potentially

qualify as historical resources,
as defined in CEQA Guidelines Section 15064.5. As
such, there are no historical resources present within the project site

and there would be
no impact

on
historic
al resources.

b)

Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5?

Less than Significant
Impact, after

Mitigation
.

This section discusses archaeological
resources, both as historical resources

according to CEQA Guidelines Section 15064.5, as
well as unique archaeological resources, as defined in California Public Resources (PRC) (CEQA) Section 21083.2(g). A significant impact would occur if the project would cause a substantial adverse change t
o an archaeological resource through physical demolition, destruction, relocation, or alteration of the resource.

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

Implementation of Mitigation Measure CUL
-
1a: Cultural Resources Awareness
Training
and

Mitigation Measure CUL
-
1b:

Inadvertent Discovery of Cultural Materials or Tribal Cu ltural
Resources would reduce potentially significant impacts to less than significant.

In the
event of an inadvertent

discovery of
any cultural materials

or tribal cultural resource,

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these

mitigation
measures
would ensure that
all personnel complete a cul
tural resources
awareness training prior to any ground
-
disturbing activity and
that work
halts

in the
vicinity until a qualified archaeologist can make an
assessment and provide additional
recommendations if necessary, including contacting Native American tribes.

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

Prior to authorization to proceed,
the City shall engage
a qualified archaeologist,
defined as an archaeologist meeting the U.S. Secretary of the Interior’s Professional Qualificatio
n Standards for Archeology,
to

conduct a training program
for all construction workers involved
o
n site disturbance. On
-
site personnel
shall
attend a mandatory pre
-
p
roject training that outline
s

the general
archaeological
sensitivity of the
vicinity

and th
e procedures to follow in the event an
archaeological resource and/or human remains are inadvertently discovered.

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

If pre
-
contact or historic
-
era
cultural
materials

are encountered during
p
roject
implementation, all construction activities within 100

feet
of the find shall halt and the
contractor shall notify the City. The City shall notify

a
qualified
archaeologist
who
will

inspect the find within 24

hours
of discovery and
provide

the City

of
an

initial
assessment. Pre
-
contact
cultural

materials might include obsidian and chert
flaked
-
stone tools (e.g., projectile points, knives,
scrapers) or toolmaking debris;
culturally darkened soil (“midden”) containing
heat
-
affected rocks, artifacts, or
shellfish remains; stone milling equipment (e.g., mortars, pestles, handstones, or milling slabs); and battered stone tools, such as hammerstones and pitted stones.

Historic
-
era
cultural
materials might include building o
r 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 m
ay qualify as a historical resource or unique
archaeological resource (as
defined in CEQA Guidelines Section 15064.5) or a
tribal cultural resource (as
defined in PRC Section 21080.3), the resource shall be avoided if feasible.

Consistent with Section
1512

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

If avoidance is not feasi
ble, 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

2 1083.2 and CEQA Guidelines Section

15126.4.

This shall include documentation of the resource and may include data recovery (according to PRC Section

21083.2), if deemed appropriate, or other actions such
as treating the resource with culturally appropriate

dignity and protecting the
cultural character and integrity of the resource (according to PRC Section

21084.3).

c)

Disturb any human remains, including those interred

outside of formal
cemeteries?

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Less than Significant Impact
, after Mitigation.

The record
s search and background
research
conducted for the project
determined that no human remains are known to exist
within the
project site
. Therefore, the
project

is not anticipated to impact human remains,
including those interred outside of formal cemeteries
.

While unlikely, if any previously
unknown human remains were encountered during ground
-
disturbing activities, impacts
on the human remains resulting from the
project

could be
potentially significant
.

Implementation of Mitigation Measure CUL
-
2: Inadverten
t Discovery of Human
Remains
,

would

reduce potentially significant impacts to
less than significant
. This
measure shall comply with applicable state laws, including Section 7050.5 of the Health and Safety Code. This would require work halt in the vicinity of a find and the immediate
notification of the County
C
oroner. If the
C
oroner determines that the human remains are
Native American, they
would

notify the California Native American Heritage
Commission, who shall appoint a Most Likely Descendant (PRC Sect ion 5097.98).

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

If human remains are encountered during
project

implementation,
t
he
contractor
shall
halt all construction activities within 100

feet of the find

and notify the City.

The City
shall contact the

Contra Costa

County Coroner
who will

determine that no
investigation of the cause of death is required.

If

it is determined that the remains
are Native American
, the Coroner shall contact the

Native American Heritage
Commission within 24
hours. The Commission
sha
ll then identify the person or
persons it believes to be the Most Likely Descendant from the deceased Native American, who in turn would make recommendations for the appropriate means of treating the human remains and any grave goo
ds.

References

Northwest Information Center (NWIC), Records Search File No. File No.

21 -
1575
. On file,
ESA, March 23, 2022.

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4.6 Energy

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Les
s

than

Significant

Impact

No

Impact

Energy

Would

the

project:

a)

Result

in potentially

significant

environmental

impact
due

to

wasteful,

inefficient, or

unnecessary

consumption of

energy

resources,

during

project

construction or

operation?

b)

Conflict

with

or

obstruct

a

State

or

local

plan

for

renewable

energy

or

energy efficiency?

Setting

In 2020, more than 35 percent of the electricity PG&E delivered to its customers came from eligible renewable resources including solar,
wind, bioenergy, geothermal and small hydropower
and is on target to meet the 2045 goal (PG&E, 2021).

As intro
duced in Section 2,
Project
Description,
the Raven SR project

would consume electricity
to operate
, the
majority of the
power would come from
upda
ted
onsite power generation
, and the

fuel to be used is the existing
LFG
combined with
tail gas from the
project operation. An

existing PG&E power drop
is
available to the project site.

Evaluation

a)

Result in potentially significant environmental impact d ue to wasteful, inefficient, or
unnecessary consumption of energy resources, during project construction or operation?

Less than Significant Impact
.

Both construction and operation of the
project

would
involve expenditure of energy.

Below are discussions o
f the energy resources that would
be consumed during construction and operation of the project.

Construction

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

with manufacturing.

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CEQA focuses on the efficient use of energy rather than comparisons of

estimated

energy
amounts to be
consumed

to
quantitative significance thresholds. Construction activities at the project site would occur over a period of approxima tely 8 months. Construction
activities would include use of heavy
-
duty construction equipment

and offsite vehicles to
transport equipment, materials, and workers to the project component sites.

Energy use requirements in the form of diesel fuel
that would
be
consumed by off
-
road
construction equipment
at the project site
have been estimated based on the GHG
emissions estimates
obtained from

the CalEEMod
and EMFAC2021

modeling conducted
for the Air Quality and GHG analysis

in Sections 4.3 and 4.8, respective
ly, of this
checklist
. GHG emissions from CalEEMod were used in conjunction with The Climate
Registry’s 2021 default factors for
calculating
c
arbon dioxide (
CO
2 )
emissions

from
diesel fuel (TCR,
2021)
. The

analysis
assumes that all off
-
road construction eq
uipment
would be fueled by diesel.

T
he analysis assumes that light
-
duty automobiles and trucks used by commuting
construction
workers would be fueled by gasoline, and that vendor vehicles and trucks that would
haul demolition debris, soil, and other mater
ials would use diesel fuel
. This
analysis assumes that no electric on
-
road vehicles would be used during
project

construction.

GHG emissions associated with commuting workers and vendor and haul trips were estimated using information provided by the
City

f
or estimated trip counts and
CalEEMod default trip lengths
.

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

area.

It is estimated that over the entire construction period of the project
, off
-
road equipment
and on
-
road
vender

vendor
and haul trucks

would consume approximately

25,0
61 20,062

g
allons

of diesel

fuel
,

and
commuting

work
er vehicles would consume approximately
146

203
gallons of gasoline
17 .

Due to the relatively small scope of the
project
, as well as the limited duration of
construction activities, the consumption of fuel energy during construction would be temporary, loc
alized, and would amount to a very small fraction of the 47 million gallons
of diesel and 336 million
gallons of
gasoline sold in Contra Costa County (California
Energy Commission [CEC], 2020).

Vehicles used for
project

construction and operation
would be
required to comply with all federal and state efficiency standards. Additionally, there are no
project

characteristics or features that would be inefficient or that would result in the use of equipment and vehicles in a manner that would be less energy eff
icient than similar construction projects.

17 Construction energy estimates
are updated

to account for the project’s construction schedule delay.

As part of the
updated construction modeling, the most recent version of CalE EMod (version 2022.1) and EMFAC2021 were
utilized, which result in differing emission factors for the CO 2 e estimates for both off
-
road and on
-
road equipment.

Fuel consumption estimates are based on the changed CO
2 e emissions.

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Therefore,
project

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

Operation

Once oper
ational, the majority of the
project
’s power requirements would come from
electricity generated onsite. The electricity would be generated using equipment such as

newly installed
Jenbacher
generator sets. The fuel that would be used for the generation is
L
FG

from the Republic Services landfill,
blended
with the tail gas from a pressure
swing adsorption
(PSA)
unit to purify the hydrogen product. Republic Services would offtake approximately 0.5 MW from the power generation for its onsite operation al

needs
an
d the rest
of the generated energy
would be used to power the hydrogen plant. The
plant would consume approximately

6.0+

MWe to operate and produce 200 kg of
hydrogen per hour. Any additional electricity needed to operate the facility would be sourced from

an existing PG&E power drop to the site and no new distribution power line would be required for the
project
.

Operation and maintenance of the new facility
would require 3

to
4 employees per shift, for a total of 9

to
12 new employees

per day

to
cover all
shifts and provide necessary support of the facility; energy use from employee trips would therefore be minimal.

Energy would be consumed by new truck trips to the
site,
with
which

is also relatively minimal at up to approximate
100

125
truck trips per
week
.
18 T
he facility

would not

involve customers onsite
.

Since the majority of the required power would be generated onsite ,

and the power would
be used to produce hydrogen fuel at the plant,
the
energy use

imports of grid power

associated with
the
project wou
ld be net positive (i.e.
,

more

power would be generated
than consumed

energy available in the hydrogen product as compared to the grid power import
)
and
are

not
be

considered inefficient
or

wasteful and hence, this impact would be
considered less than sign
ificant.

b
)

Conflict with or obstruct a State or local plan for renewable energy or energy efficiency?

No

Impact
.

As discussed above,
project

construction would require the use of off
-
road
construction equipment and on
-
road trucks. Construction activities
would comply with
state and local requirements designed to minimize idling and associated emissions, which would also minimize the use of fuel. Specifically, pursuant to 13 CCR Sections 2485 and 2449, idling of commercial vehicles over 10,000 pounds and of f
-
road equipment over 25
horsepower would be limited to a maximum of five minutes. Fuel use for project

construction would be consistent with typical construction and manufacturing practices, and energy standards such as the Energy Policy Acts of 1975 and 2005, which promote

18 This estimate assumes
25 trucks per day,
evenly distributed on five weekdays

(per the Project Applicant, see Table

4.15 -
1, note “d”).

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strategic planning and building standards that reduce consumption of fossil fuels, increase use of renewable resources, and enhance energy efficiency.

Once operational, the
project
’s
primary
energy use would be
electricity generated on
site
using a fuel that would consist of
LF
G combined with tail
gas
.

Energy

used for
operational vehicle trips would be negligible. Any additional electricity would be provided by PG&E
,

which would be subject to SB 100 under California’s Renewable Portfolio

Standard (RPS) Program. Signed into law by Governor Brown, SB 100 increased California’s RPS target to 60 percent of total electric retail sales by 2030, and requires 100 percent of electric retail sales to come from eligible renewable or carbon -
free reso
urces by 2045. PG&E, as the utility provider
,

is subject to these requirements.

As a result, even if the availability of
flaring of landfill gas produced from the
decomposition of organic solid wastes

declines over time, which would require the
project to

import a larger fraction of its power from the existing PG&E facilities

(
and/or a
renewable source
)

to maintain operational levels, 100

percent

of this electricity will
renewable by 2045.

T
here are no aspects of the proposed
project

that would conflict wi
th
or obstruct a state or local plan for renewable energy or energy efficiency , so there would
be no impact
.

References

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

Accessed April 26, 2022.

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

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

Available: https://www.the
climateregistry.org/wp
-
content/uploads/2021/05/2021
-
Default
-
Emission
-
Factor
-
Document.pdf?mc_cid=4b45d12237&mc_eid=5f138d1baa. Accessed March 29, 2022.

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4.7 Geology, Soils and Mineral Resources

Environmental

Issues

Potentially

Significant

Impact

Less

th
an

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Geology

and

Soils

Would

the

project:

a)

Directly or

indirectly cause potential

substantial

adverse

effects,

including

the
risk

of loss, injury,

or

death

invo
lving:

i)

Rupture

of

a

known

earthquake

fault,

as

delineated on

the
most

recent Alquist
-
Priolo

Earthquake

Fault

Zoning Map

issued
by

the

State
Geologist

for

the

area or

based on

other

substantial

evidence

of
a
known

fault? Refer

to

Division

of

Mines

and

Geology

Special

Publication 42.

ii)

Strong

seismic ground

shaking?

iii)

Seismic
-
related

ground

failure,

including

liquefaction?

iv)

Landslides?

b)

Result

in substantial

soil

erosion

or

the

loss

of

topsoil?

c)

Be
located

on
a
geologic unit or

soil

that

is

unstable,

or

that

would

become unstable

as a
result of

the

project,

and potentially

result

in

on
-

or

off
-
site

landslide,

lateral

spreading, subsidence, liquefaction

or

collapse?

d)

Be
located

on expansive

soil,
as

defined

in Table

18 -

1 -
B

of
the

Uniform Building

Code

(1994), creating

substantial direct

or

indirect

risks

to
life

or

property?

e)

Have

soils

incapable

of adequately

supporting

the

use

of

septic ta
nks

or

alternative

wastewater

disposal

systems where

sewers

are

not available

for

the
disposal

of wastewater?

f)

Directly or

indirectly destroy

a
unique

paleontological

resource

or site

or

unique geologic

feature?

Mineral Resources

Wou
ld the project:

a) Result in the loss of availability of a known mineral

resource that would be of value to the region and the
residents of the State?

b) Result in the loss of availability of a locally important

mineral resource recovery site
delineated on a local
general plan, specific plan or other land use plan?

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Setting

There are several known active faults in the vicinity of the project site. The location lies within a geologic province of the San Francisco Bay named the “Richmond Bas in," bounded by the San
Pablo and Hayward faults. The active fault in the region that are capable of producing the most significant ground shaking at the project site is the Hayward Fault, located approximately

3.7 miles
southwest of the project site.

(Roc
kridge, 2022)

A Geotechnical Investigation report was prepared for the proposed project (Rockridge, 2022).

T
he
project site
is blanketed by about 12 to 18 feet of heterogeneous fill, the upper five feet of which in the areas studied generally appears to b
e relatively well compacted. The fill is
underlain
by young bay sediments known locally as

Bay Mud
,

which extends to depths of approximately
110 to 117 feet
below ground surface (
bgs
)
.

Bay Mud layer is generally soft to depths of
approximately 50 to 60 fee
t bgs, but can be more stiff below, depending on the degree of over
consolidation
.

The Bay Mud is underlain by alluvium consisting of dense to very dense sand/silty sand that

extends to the maximum depth explored (120 feet bgs).

This analysis considers inf
ormation
from the geotechnical investigation as well as
from numerous
studies conducted for the WCCSL

property
.

Evaluation

Geological Resources and Soils

a)

Directly or indirectly cause potential substantial adverse effects, including the risk of loss, inj
ury, or death involving (
i
) Rupture of a known earthquake fault, as

delineated on the most recent Alquist
-
Priolo Earthquake Fault Zoning Map issued
by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Divisi
on of Mines and Geology Special Publication 42. (
ii
)
Strong seismic ground shaking? (
iii
) Seismic
-
related ground failure, including

liquefaction? (
iv
) Landslides?

Less than Significant Impact
.

Intense ground shaking during a large earthquake would
be expec
ted at the project site, particularly given its close proximity of the nearest active fault.

The project
would

adhere to standard industry practices, code requirements, and any geotechnical recommendations or design parameters
identified

in the geotechnica
l
study prepared for the project (Rockridge, 2022). (
for the proposed earthwork, foundation
slabs, and any surrounding related improvements, utilities, or paved areas associated with the project, would reduce the potential impacts associated with ground sh aking during a
major seismic event; seismically
-
related ground failure, including liquefaction

for which
the

project

area is susceptible (
Richmond
, 2012)
. T
he project
would

also adhere to all
requirements in the applicable versions of the California Buildi ng Code, which would
generally reduce known seismic hazards to minimize
potential adverse effects
.

The
project
would
introduce an industrial operation and modular structures on the project site ,
involving up to three to four employees onsite at any particu lar time
, and no customers
.

The impact
would
be less than significant.

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b)

Result in substantial soil erosion or the loss of

topsoil?

Less than Significant Impact
.

The project, which relatively flat and partially paved and partially compacted soil and ruder
al groundcover, would develop and implement an
Erosion Control Plan and
applicable

best management practices
as part of the
National
Pollutant Discharge Elimination System (NPDES)
Construction General Permit
,

would
reduce
potential
impacts associated with
erosion to a less than significant level.

c)

Be located on a geologic unit or soil that is unstable,

or that would become unstable
as a result of the project, and potentially result in on -

or off
-
site landslide, lateral
spreading, subsidence, liquefaction

or collapse?

Less than Significant Impact
.

As mentioned in criterion “a”

above,

t
he project
would

adhere to standard industry practices, code requirements, and any geotechnical recommendations or design parameters
that would
reduce the likelihood
of lands
lide
,
lateral spreading, subsidence, liquefaction or collapse

due to
unstable geologic units or
soil
.

Based on the results of previous analyses, most of the

sand layers present at the site
(primarily within the Bay Mud) are sufficiently dense, have

suffici
ent clay content,
and/or are overlain by a sufficient thickness of Bay Mud, such that

the potential for
liquefaction is low

although the site is in a liquefaction hazard zone (see “a”) . The
greatest potential for liquefaction is
approximately

0.3 miles nor
thward,
adjacent

to
San
Pablo Creek.

The project site is not located on areas of landfill, which also sits upon Bay Mud and is susceptible to risks of settlement

over time. The impact would be less than
significant.

d)

Be located on expansive soil, as def
ined in Table 18
-

1 -
B of the Uniform Building
Code (1994), creating substantial direct or indirect risks to life or property?

No Impact
.

Expansive soil is not known to exist at the
WCCSL
site

(County, 2004)
.

No
impact would occur.

e)

Have soils incapable
of adequately supporting the

use of septic tanks or alternative
wastewater disposal systems where sewers are not available for the disposal of wastewater?

No Impact
.

The project does not proposed installation or use of septic tanks

or alternative
wastewate
r disposal systems
; the site is currently served by
West County Wastewater
District

sanitary sewer
service and facilities which
would

continue with the proposed
project
.

f)

Directly or indirectly destroy a unique

paleontological resource or site or unique

geologic feature?

Less than Significant

Impact, after
Mitigation
.

Based on the evaluation in

Section 4.5,
Cultural Resources,

in this checklist, the
potential for encountering
paleontological or
unique geologic features on the project site during
ground
-
d
isturbing activities

for the

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proposed project is unlikely.

However,
the implementation of
Mitigation Measure CUL
-
1a: Cultural Resources Awareness Training
,

Mitigation Measure CUL
-
1b:

Inadvertent Discovery of Cultural Materials or Tribal Cultural Resources ,

and

Mitigation Measure CUL
-
2: Inadvertent Discovery of Human Remains
,
all
identified

above

in
Section

4.5 ,
Cultural Resources
,

also apply to
reduce
the potential and unlikely
event

paleontological resources
are discovered.

Mineral Resources

a, b)

Result i
n the loss of availability of a known mineral

resource that would be of value
to the region and the residents of the State? Result in the loss of availability of a locally important

mineral resource recovery site delineated on a local general plan, specifi
c plan or other land use plan?

No Impact
.

The
proposed

project
would

not require the use of vast amounts of natural
resources or
mineral

resources for construction or operation.

Input to the operation is
existing organic feedstock from the project site. No

impact would
occur
.

The

California
Geological Survey (formerly California Division of Mines and Geology) identifies mineral resources present within California and designates mineral resource zones. These mineral resource zones (MRZs) are
based

on known
mineral resources present (e.g., existing mines)
or documented geological units present or underlying surface locations. Each MRZ is classified based on potential economic value of the underlying resources. The proposed Project is located in MRZ
-

1. This

zone classification indicates that no significant mineral deposits are present, or little likelihood exists for their presence (Stinson, Manson and Plappert, 1987). Therefore, the proposed Project would not result in the loss of a locally important miner
al resource and no impact would occur
.

References

City of Richmond, 2012.

Richmond General Plan
Update Environmental Impact Report.

SCH.
2008022018.
2012.

City of Richmond, 2012.

Richmond General Plan

2030:

Public Safety and Noise E
lement.

Table

3.7 -
4,
Liq
uefaction
.
2012.

Contra Costa County 2004.

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

June
2004
.

Contra Costa County 2009.

Addendum to the

Final

EIR

for th
e WCCSL BMPC and Related
Actions
,
SCH. 2002102057
. 2009
.

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4.8 Greenhouse Gas Emissions

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Greenhous
e Gas

Emissions

Would

the

project:

a)

Generate greenhouse
gas

emissions,

either

directly

or

indirectly, that

may

have
a
significant

impact on

the
environment?

b)

Conflict

with

any

applicable plan, policy or

regulation

adopted

for

the

purpose

of reducing
the

emissions

of

greenhouse gases?

Setting

State

and Regional

The California Global Warming Solutions Act (Assembly Bill [AB] 32, 2006), as amended, sets statewide greenhouse gas (GHG) emissions caps. The California Air Resource s Board (CARB)
established the Climate Change Scoping Plan, which outlined a framework for achieving the emission reduction goals set in the California Global Warming Solutions Act. In 2016, SB 32 and its companion bill AB

197 established a new climate pol
lution reduction target of 40 percent
below 1990 levels by 2030 and included provisions to ensure the benefits of State climate policies reach into disadvantaged communities.

Senate Bill (SB) 375 requires CARB to develop regional GHG reduction goals for t he automobile
and light truck sectors. The
Plan Bay Area 2040
is a plan to achieve regional GHG reduction
goals by improving transportation access, maintaining the region’s infrastructure, and enhancing resilience to climate change through strategies such
as fostering open space. There are a number
of other laws in California intended to reduce GHG emissions through the regulation of construction standards, growth, and municipal operations.

Governor Brown signed Executive Order B
-
55 -
18 in September 2018 to

establish a statewide
goal to achieve carbon neutrality as soon as possible, and no later than 2045, and to achieve and maintain net negative emissions thereafter
.

In response to this Executive Order, CARB’s Draft
2022 Scoping Plan Update (
May 10
CARB
, 202
2 b
) presents several scenarios for achieving
carbon neutrality statewide no later than 2045.

Additionally, in 2022, California enacted the
California Climate Crisis Act (AB 1279), which amended AB 32 by establishing state policy to achieve net zero GHG emi
ssions as soon as possible, but no later than 2045, and to ensure that, by 2045, anthropogenic GHG emissions are reduced to at least 85 percent below 1990 levels.

CARB’s
Final
2022 Scoping Plan for Achieving Carbon Neutrality (
CARB
, 2022
a
) describes the
se
lected Scoping Plan Scenario to achieve these goals, in comparison to other proposed scenarios and a Reference Scenario.

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Significance Threshold

Greenhouse gas impacts are, by their nature, cumulative impacts because one project by itself cannot cause globa
l climate change. As such, GHG emissions are evaluated under CEQA as a cumulative impact. To evaluate cumulative impacts, a lead agency must assess (1) whether the overall cumulative impact
would

be significant and, (2) if the overall impact is significant ,
whether the incremental contribution that the individual project under review would

add to the
overall cumulative problem
would

be cumulatively considerable.

A conservative threshold of significance for determining the cumulative impact of a project’s G
HG emissions is “net zero” emissions. This concept is supported by the BAAQMD in its Justification Report:

CEQA Thresholds for Evaluating the Significance of Climate Impacts f
rom
Land Use Projects and Plans

(BAAQMD, 2022), which states: “If a land use proj
ect incorporates
all of the design elements necessary for it to be carbon neutral by 2045, then it will contribute its portion of what is needed to achieve the State’s climate goals and will help to solve the cumulative problem. It can therefore be found t
o make a less
-
than
-
cumulatively
-
considerable
climate impact” (BAAQMD 2022).

Further,
the State’s Office of Planning and Research’s (
OPR
)

Final Statement of Reasons

for
Senate Bill 97 revisions to the CEQA Guidelines

state that, “AB32, and regulations
impl
ementing

that statute, will require reductions in emissions

from certain sectors in the economy, but do not
preclude new emissions. Moreover, as explained

in the Initial Statement of Reasons, the proposed
amendments do not establish a zero emissions

thresh
old

of significance because

there

is no

‘one
molecule

rule’

in CEQA”

(CNRA,

2009).

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

The new BAAQMD thresholds are focused on land development projects, and

the legacy
stationary source threshold for operational GHG emissions is 10,000 MTCO 2 e. This threshold is
not being currently updated in the

BAAQMD, as staff are focusing on creating land use project and plan thresholds (BAAQMD 2022).

This

analysis
focuses

on net zero emissions and the new
draft thresholds, while also taking into account the existing BAAQMD threshold.

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T
ABLE

4.8 -
1 BAAQMD

GHG

T

HRESHOLDS OF
S

IGNIFICANCE

(M
UST
I
NCLUDE
A

OR
B

FOR
O
PTION
S
CHEME
)

Existing and Draft Air District Thresholds

Legacy Stationary
Source Threshold

10,000 MTCO
2 e

Option

A

Projects must include, at a minimum, the following project design elements:

1)

Buildings

a
.

No natural gas (residential and non
-
residential)

2)

Transportation

a
.

Achieve compliance with EV requirements in the most recently adopted version of CALGreen
1 Tier

2 b
.

Achieve SB 743 target of 15% reduction in VMT per capita below r
egional average

Option B

Be consistent with a local GHG Reduction Strategy that meets the criteria under the CEQA Guidelines Section

15183.5(b)

1 Part 11 of the Title 24 Building Energy Efficiency Standards is referred to as the California Green Building

Standards (CALGreen) Code

SOURCES:

BAAQMD 2022.

Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans
, April.

Evaluation

a)

Generate greenhouse gas emissions, either directly or indire ctly, that may have a
significant impact on the environment?

Less than Significant Impact
.

GHG emissions would be generated during both
construction and operational phases of the
project
.

Construction

The combustion of diesel fuel to provide power for
the operation of various construction

equipment
results in the generation of

GHGs. Construction emissions associated with the
project were

estimated using project
-
specific information provided by the Project
Applicant
, such as

construction schedule and pha
sing; types, number, and horsepower
rating of construction

equipment

to be

used,

their

daily

usage in terms

of hours per day,

and

the

number

of

days

each piece of equipment is used over the construction period; and information on

construction vehicle trips

for worker commute, equipment and material
transport and

hauling trips. Appendix A to this checklist contains the data and assumptions used to

estimate the construction
-
phase GHG emissions that would be

associated with

the

project.

Carbon Dioxide (
CO
2 )
,
m
ethane (CH
4 ) and nitrous oxide (N
2 O)
emissions from off
-
road
construction equipment and construction vehicle trips were derived from the CalEEMod

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run to estimate criteria air pollutant emissions. N
2 O and CH
4 emissions were multiplied
by their respective Gl
obal Warming Potentials GWPs (25 and 298) and added to the CO 2 emissions to obtain CO
2 e emissions.

Construction of the proposed project is anticipated to occur over a period of

approximately eight months. It is

estimated that
p
roject construction would gen
erate a
total of approximately
258.
9 186.1

MTCO
2 e over

an 8
-
month

construction period
, as
shown in
Table 4.8
-
2 . BAAQMD does not have adopted significance thresholds for construction
-
related GHG emissions in its 2017 CEQA Guidelines (BAAQMD, 2017).

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

T
ABLE

4.8 -
2 A
NNUAL

C

ONSTRUCTION
-
R
ELATED

G

REENHOUSE

G
AS

E

MISSIONS

Year

GHG

(MTCO
2 e)

2022

2023

17 8
.
3 179.3

2023

2024

80.6 6.8

Total

258.
9 186.1

Amortized

8.6 3

6.2 NOTES:

MTCO
2 e

=

metric

tons

of

carbon

dioxide

equivalent

Construction
-
related GHG emissions were amortized over 30 years, which is a

commonly accepted method for including construction emissions as part of the

proposed

project
’s

average

annual

emissions.

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

SOURCE
:

Data

compiled

by

Environmental

Science

Associates

in

2022
Ramboll

(Appendix

A

to

this

document
checklist
)

In addition, the GHG thresholds proposed by the BAAQMD in response to SB 32’s GHG reduction goals also do not contain significance thresholds for c onstruction (BAAQMD,
2022). GHG emissions from the construction phase of a project represent a very small portion of emissions over the project’s lifetime, which for the projects such as the proposed
project

would be at least 30 years.

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

Though not required as

mitigation to reduce a significant impact,
implementation of

Mitigation Measure AQ
-
1: Best Management Practices
, identified above in Section

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4.3,
Air Quality,

will help reduce GHG emissions in addition to providing air quality benefits.

Therefore, GHG emi
ssions associated with project construction would be
considered less than significant.

Appendix A contains

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

Operational

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

The existing legacy s
tationary source threshold is 10,000 MTCO
2 e annually.

The proposed system takes up
to

99.9 wet
-
tons per day (WTPD) of blended green waste
(GW), food waste (FW),
using

landfill gas (LFG)
to provide power to the process
and
converts
the feed
into renewable,
transportation grade hydrogen.

This waste would
otherwise be put into the landfill where it would produce GHG emissions in the form of methane gas.

The landfill gas would also otherwise be creating GHG emissions if not for the bioenergy facility taking it
and converting it into hydrogen.

By redirecting this waste
into the Raven SR, it reduces the amount of GHG emissions produced at the project site.

Biogenic CO
2 emissions from green waste are not accounted for in operational GHG impacts as they are a result

from materials that are derived from living cells, not fossil fuels (BAAQMD 2017b).

The
Raven SR

system does not have any free

oxygen in its process, and instead uses
steam
promoted

processes to
thermally decompose the feed

into its chemical elements
.

Thi
s
The
process does not involve any type of combustion, and therefore does not have an GHG emissions associated with the system operational emissions.

Once project
operations fully begin,

GHG

emissions are expected to
be

net negative
, and will continue
to
be net negative even
if

LFC is ever fully depleted
.

Table 4.8
-
3 shows
operational emissions calculated using CalEEMod (version 2020.4.0)

and
EMFAC2021
as well emissions from permitted activities

added to the amortized

construction emissions to get the tota
l annual project GHG emissions. BAAQMD does
not currently have a quantitative threshold for GHG emissions. The current qualitative significant thresholds are found in
Table

4.8 -
1 .

The project
would

satisfy the BAAQMD
Best Available Control Technology (BACT
) requirements, and thus
t
he proposed project
is consistent with the 2017 Climate Change Scoping Plan as well as the draft and final
2022 Scoping Plan Update in terms of following the GHG reduction strategy to reach the statewide goal of climate neutrality

by 2045

(CARB 2017, 2022a, 2022b)
.

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T
ABLE

4.8 -
3 U

NMITIGATED
A
NNUAL
O

PERATIONAL
G

REENHOUSE
G
AS
E

MISSIONS

Source

GHG (
MTCO
2 e
)

Process Operations

Biogas Engines

16,398

Flare

205

Fire Pump Engines

2.5 Auxiliary Operations

Area

<1

Energy

80.5 Mobile

2 62.6

1909.2

Off
-
road

303.2

Waste

96.7 Water

17. 0

Amortized Construction Emissions

6.2 Amortized Construction Emissions
Landfill Flare
Reductions (blended gas)

8.6 3

-
9,019

Total
Project GHG
Emissions

(blended gas)

697.17

9,999

Landf
ill Flare Reductions (100% LFG)

-
16,398

Total Project GHG Emissions (100% LFG)

2,620

NOTES:

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

Landfill flare reductions were estimated based on the landfil l gas usage of the Project
biogas engines, which can operate using a blended gas consisting of at least 55

percent

landfill gas and up to 100

percent

landfill gas

MTCO
2 e = metric tons of carbon dioxide equivalent

Operational emissions
are

revised
in this
updated IS/MND
to align with
more detailed
project information from the Project Applicant
.

SOURCE:

Data compiled by Environmental Science Associates.
(
See Appendix
A to this
document
checklist
.
)

Based

on

the

state carb
on neutrality goal for 2045, the proposed project
would

contribute
its portion of what is needed to achieve the State’s climate goals and would

help to solve
the cumulative climate problem.

Its emissions are considerably less than the current
BAAQMD operat
ional emissions threshold of 10,000 metric tons of CO
2 e per year (see
Table 4.8
-
3 above.

It can therefore be found to make a less
-
than
-
cumulatively
-
considerable climate impact. The project emission calculations, along with the supporting data from the life

cycle analysis, shows that the project would be below both the new draft significant thresholds and the legacy stationary source threshold, with the possibility of reaching net negative GHG emissions, contributing to the determination of the project havin
g a less than significant impact and a less
-
than
-
cumulatively
-
considerable climate
impact. Therefore, operation of the proposed project

would

have
a less than significant
impact.

b
)

Conflict with an applicable plan, policy or regulation adopted for the pur pose of
reducing the emissions of greenhouse gases?

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Less than Significant Impact
.

In response to AB 32 GHG reduction goals, CARB
adopted the Climate Change Scoping Plan, which outlined a framework for achieving the emission reduction goals set in the Calif
ornia Global Warming Solutions Act. The
Scoping Plan was most recently updated in
2017
2022

(
2017

Scoping Plan;

CARB,
2022
a
2017
) to address
California’s 2030
how the state will achieve AB 1279’s goals of
achieving net zero

GHG
emissions

target

and
identifies

how the State can reach the 2030
climate target established
an 85 percent reduction in anthropogenic GHG emissions
below 1990 levels

by
2045
SB 32 while making substantial advancements toward the
2050 climate goal established by Executive Order (EO) S -
3 -
05 (2005)
.

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

The
project

would generate GHG emissions primarily from
operational
activities
and
would
most likely

result in net negative emissions on an annual basis
,
and contributes to
the long
-
term

California goals of finding alternative sources of green energy . As such, the
project

would help the City achieve its long
-
term GHG emissions goal. Neither the
2017
2022

Scoping Plan Update or the City’s existing CAP contain any actions or measures that ad
dress GHG emissions from construction. The majority of electricity supplied to the
project

would

come from an onsite power generator, fueled by LFG from the Republic Services
WCCSL
.

Any additional power required
would

be supplied from
an on
-
site PG&E power

drop; PG&E is required to comply with SB 100 and the RPS.

SB
100 requires that the proportion of electricity from renewable sources be 60 percent by 2030 and 100 percent renewable power by 2045.

Therefore, the
project

would be
consistent with all applicab
le plans, policies and regulations adopted for the purpose of reducing GHG emissions. This impact would be less than significant.

References

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

Available online:

Microsoft Word
-

FINAL CEQA Thresholds Report for Climate Impacts
03_30_22 revisions with tracked changes (baaqmd.gov)
.

Accessed on M
ay 11, 2022.

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

The

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

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

Available
online:
https://ww2.arb.ca.gov/sites/default/files/classic/
cc/scopingplan/scoping_plan_2017
.pdf
. Accessed on April 26, 2022.

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CARB, 2022
a
. California’s
Final 2022

Climate Change Scoping Plan
, November 16, 2022
.

Available online:

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

CARB, 2022
b
. California’s
Draft 2022

Climate Change Scoping Plan
, May 10, 2022
. Availabl
e
online: https://ww2.arb.ca.gov/sites/default/files/2022 -
05/2022
-
draft
-
sp.pdf

. Accessed on March 4, 2023.

California Natural Resources

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

Raven SR Republic Service Summary, 2021.

Carbon Life Cycle Analysis, Life Cycle Associates,
LLC.

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4.9 Hazards

and Hazardous Materials

Environmental

Issues

Potentially

Significant

Impact

Less

than

Signific
ant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Hazards

and Hazardous
Materials

Would

the

project:

a)

Create

a
significant hazard

to
the
public or

the

environment

through

the

routine

transport,

use,

or

disposal

of hazardous

materials?

b)

Create

a
significant hazard

to
the
public or

the

environment

through

reasonably

foreseeable

upset

and

accident conditions

involving

the

release

of

hazardous

materials

into

the

environment?

c)

Emit

haz
ardous emissions or

handle hazardous or

acutely

hazardous

materials, substances, or

waste

within

one
-
quarter

mile

of

an

existing or

proposed

school?

d)

Be
located

on
a
site

which

is

included on

a

list

of

hazardous

materials

sites compiled

pur
suant

to

Government

Code

Section 65962.5 and,

as

a

result,

would

it create
a
significant hazard

to

the

public

or

the
environment?

e)

For

a

project

located within

an
airport land use

plan

or,

where

such
a
plan

has

not been adopted,

within

two

miles

of

a

public airport or

public

use airport,

would

the

project

result in

a

safety hazard

or

excessive

noise

for

people

residing

or

working

in

the

project area?

f)

Impair

implementation of

or

physically

interfere

with

an
adopted

emergency

response

plan

or

emergency

evacuation

plan?

g)

Expose people or

structures, either

directly or

indirectly
to a

significant

risk of

loss,

injury or

death

involving

wildland fires?

Setting

The project site sits within the existing WCCSL
,

which does not accept hazardous wastes; u
nder
State and federal laws, the

landfill is permitted to accept non
-
hazardous wastes only.

Although

the municipal solid

waste stream does contain small quantities of hazardous wastes that result from disposal of

h
ousehold waste and waste from small quantity generators, such as auto repair, auto dealers, and

gas stations
, the proposed project only involves
a

variety of organic waste
feedstock
.

As discussed below

and
in Section 2.5 (
under
Safety and Control
s

(in Sect
ion 2.6
Non
-
Combustion
)
, the Raven SR process
incorporates internal safety functions an
d

would

adhere to
numerous

applicable
state and federa
l

regulations, plans and
procedures

that apply specifically to
its
production of
hydrogen gas

from organic solids
. T
he project facility and operation located

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

A Phase I Environmental Site Assessment has been prepared for the project (CEC, 2022).

The
Phase I reports r
elevant site conditions observed include the storage of various commonly used hazardous materials, such as used oil, lubricants, anti -
freeze, HDPE pipe sealant, pipe glue
solvent, spray paint, and household cleaning supplies. All observed materials were pr operly
stored and maintained.

The Phase I
also
reports n
umerous above
-
ground storage tanks (ASTs)
containing petroleum products

located within and near the existing

landfill power plant and
maintenance buildings

near

the project site.

As previously descri
bed, the project is contiguous to a closed hazardous waste landfill portion of the WCCSL operation.

Also,

the project site was formerly occupied by three leachate evaporation ponds. Groundwater contamination on
the

WCCSL site was confirmed in a January 202
1 Corrective Action Groundwater Monitoring Program Report. 19 Groundwater at the WCCSL also
has reported PFAS chemicals detected in groundwater. This is considered a recognized
environmental condition (
REC
)
, but regularly monitored and the results are submit
ted to the State
regulatory agency. Additionally, the groundwater impact is not expected to pose a risk of unacceptable

exposure to workers at the
project

site.

(CEC, 2022
)

Regarding potential site contamination, Republic previously initiated corrective a ctions to address
the California Department of Toxic Substance Control’s (DTSC’s) concerns in 1996.

These
actions included installing additional wells to monitor and control leachate at the site and maintain it within the landfill boundaries as required. R epublic currently operates systems to
collect and treat both leachate and landfill gas under existing conditions.

The proposed
p
roject is designed to avoid interfering with existing groundwater monitoring and recovery wells, along with any associa
ted leach
ate recovery systems.

Leachate recovery
infrastructure at the site will remain operational
,

and the
p
roposed
p
roject will not affect the
operation or
maintenance of these facilities.

The proposed
p
roject is designed to avoid interfering with existing
LFG

m
onitoring and recovery
wells. P
roject design would not alter the existing
LFG

collection and recovery infrastructure at
the site, which will remain operational. The
p
roposed
p
roject will accept LFG from existing,
permitted equipment, downstream of the liqu
id collection system to be blended with tailgas from
the Raven SR process for use as a fuel to the new, lower emitting, higher efficiency LFG engines for power production.

Raven
SR
will conduct a limited site investigation to validate subsurface environm ental
conditions durin
g the Project’s engineering design. This evaluation will character ize soil
-
gas
conditions at the p
roposed
p
roject site to ensure that
p
roject components are constructed safely
and meet all
OSHA and CalOSHA requirements.

Raven SR will
install impermeable vapor

19 CEC, 2022.

Operation of a groundwater monitor
ing system and a groundwater extraction system is required under the West County Landfill (WCL) corrective action groundwater monitoring program (CAGMP), in accordance with

Corrective Action Enforcement Order, Docket Number 20061079 dated September 26, 200

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barriers under foundations during construction to prevent potential release of soil -
gas during
subsurface activities. This pre
-
construction verification of site conditions will address concerns pertaining to potential soil
-
gas, al
so known as volatile o
rganic compounds (VOCs), that may have
migrated from the adjacent landfi
ll in the past and beneath the p
roposed
p
roject site.

In regard to hazards and safety concerns, the draft CUP includes several conditions that address hazards and

safety concerns. These conditions include:

Condition 82 requires Raven to prepare and submit for approval a Public Health and Safety Plan, as well as an Emergency Plan to protect the facility and its employees from harm, and protect human health off
-
site
as well.

These measures include
:

o

preparation of and adherence to
a
comprehensive Process Safety Information
(PSI) regarding safe work practices and operating procedures;

o

ensuring employees are involved in Raven’s required process safety and risk managem
ent programs (PSM/RMP);

o

training all employees and contractors on the potential hazards and safe operations;

o

establishing and implementing a process to evaluate any new systems, components, parts, etc. before they are placed into service ;

o

establishing a
nd
implementing a Pre
-
Start Safety Review (PSSR) procedure to
verify that the Raven process and equipment is functional and ready for service before starting;

o

ensuring operators are aware of and trained on any process or equipment changes;

o

managing contra
ctors to ensure their safety awareness;

o

conducting routine maintenance of mechanical equipment;

o

investigating the cause of any equipment or system failures and implementing corrective and preventative actions; and

o

establishing and adhering to emergency p
lanning and response plan protocols.

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

scheduled for a particular day/shift.

During operations, Raven SR would contract with a capable and experienced operations and maintenance (O&M) service provider from among those with experience in feedstock management and with high temperature, high pres sure
process equipment. Also, Raven SR would closely oversee the implementation of the Raven
-
specific operating, training, safety, and maintenance manuals described above.

Condition 83 requires the
p
roject to comply with all design measures, safety precaut ions,
and emergency response procedures as required by federal, state, and local laws and regulations.

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Condition 84 requires the
p
roject to implement on and off site emergency response
procedures
,

as outlined in the Emergency Plan

described in Condition 82

above
.

Condition 85 requires the
p
roject to develop and implement training (and refresher training) covering accident prevention, safety,
identification

and handling of hazardous
materials, first aid, and instruction for use of equipment.

Condition 89 st
ates that the
p
roject is further bound by the C
alifornia

Fire Code for all
systems and equipment installation containing flammable, combustible, or hazardous materials. The City is requiring that the
p
roject have an equipment maintenance program
agreed up
on by the City and the Fire Marshall.

Evaluation

a, b)

Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Create a significant hazard to the public or the environment through

reasonably foreseeable upset and accident
conditions involving the release of hazardous materials into the environment?

Less than Significant Impact
.

The
proposed
operation

of

transforming blended green
waste and food
waste

into transportation
-
grade hydro
gen
-
rich

synthesis
gas
(syngas)
and
charcoal

(biochar)

could result in an adverse effect thr
o
u
gh

the exposure to or spill of
chemicals. The green waste and food waste feedstock would not be considered a hazardous material.

Also, in 1993, DTSC determined th
at the Raven SR process for the
production of syngas from organic solids was not categorized as either incineration or combustion and was therefore a suitable technology for use in California. 20 The conversion method uses a non
-
combustion (i.e., anoxic, ind
irect external heating),
low pressure process. The only chemicals added would be carbon dioxide (CO2), calcium
/magnesium

carbonate

(
dolomite
lime
stone
), 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
retor
t that drops

out solid matter from the green and
food waste feedstock, which would consist largely of
hot
biocarbon, along with dirt,
glass, grit, rocks, and inorganic salts. The biocarbon
mater
ials
components

are inert to the
process (i.e., not gasified) and drop out in the first stage.

The process also drops out
excess

A spray of
water

is used on the biocarbon to quickly cool it to manageable temperature
. Neither the biocarbon nor the water woul
d be considered a hazardous
material.

There would be no long
-
term hydrogen storage onsite; the material would be fed directly into the tube trucks and transported offsite.

For

transportation, the United States
Department of Transportation (USDOT) classifi
es hydrogen gas as a Division 2.1

20 According to the definitions listed in Section 260.10, Title 40, Code of Federal Regulations (40 CFR) and Section 66260.10, Title 22, California Code
of Regulations (22 CCR). Also, s
ince 2017, a Raven pilot engineering unit,
sized at 100 wet pounds pe
r day of feedstock, has been operating at the UC Berkeley’s Richmond Field Station and is permitted for operation by the Bay Area Air Quality Management District (BAAQMD) under permit Nos. 23993 and 23320.

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Flammable Gas. Vehicles transporting flammable gas are mandated to display USDOT flammable gas placards.

The

proposed
project

would pump the

hydrogen gas into
standard pressurized hydrogen gas trucks, called tube trailers.

The gaseous hydrogen is
compressed to pressures of
380 gas

(about
5,500

pounds per square inch [psig]) or higher
into long cylinders that are stacked on a trailer that the truck hauls. This gives the appearance of long tubes, hence the name tube trailer.

To support development of the hydrogen economy, development of t ube trailers
capable
of storing hydrogen at pressure of about 500 bar
are
approved for use on public
throughways use
by
US
DOT regulations (Federal Motor Carrier Safety Administration, 49 CFR
Part 393). Such tube trailers are routinely used to transport hydrogen gas, as well as other gases such as natural gas and propane. Regulations regarding the design of tube trailers that transport hydrogen gas
is
are

in OSHA 1910.103, Subpart H, Hydrogen,
w
hich includes requirements for the containers, pressure relief valves, piping, tubing, fittings, and labeling.

On
-
road transport of hydrogen gas must comply with applicable USDOT regulations, which include equipment requirements and driver safety training.

In
California, a specific driver’s license is required, a commercial driver’s license with a Hazard Materials endorsement.

A

new 250,000
-
gallon integrated fire water tank and diesel engine
is proposed
wo
u
ld be
installed

in the northeast corner of the site
for

emergency use
, as required by fire
department regulations

(see Figures 2
-
1 through 2
-
4).

Diesel fuel is classified as a
hazardous material,
and

therefore the above ground tanks
would

require compliance with
containment requirements in
a

Spill Preventio
n, Control, and Countermeasure (SPCC)
Plan

pursuant to federal requirements
.

Propane
for the continuous flare pilot would
be
supplied from a standard 1000
-
gallon propane tank

installed on
-
site. A local propane
supplier w
ould
service and fill
the
tank as

ne
eded.

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

Specifically
, the facility’s controls would be distributed through the various process i
slands, taking their direction from a central Human
-
Machine Interface in the control
room with centralized data collection. Process setpoints would

be bounded by high/low
alarm limitations to draw the operator’s attention to the specific problem. The contr ol
system would represent state
-
of
-
the
-
art digital technology with redundant instrumentation
where necessary to ensure safe operation.

Because the process itself is oxygen
-
free, there would be no opportunity
within
during

the
process for explosion.

As prev
iously described (
Section 2.5
), p
iping and vessels would be
periodically scanned with infrared equipment
during each working shift

to identify hot
spots or gas leaks that may threaten safety. If hot spots or leaks were identified, immediate steps
would

be
taken to correct or mediate the condition. Also, remote monitoring of the facility by Raven SR corporate provides oversight of the operation and early identification of problems
in the event
as

they
were to occur
development
.

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The project would comply with a
pplicable Environmental Protection Agency (EPA) risk
management plan (RMP) and Occupational Safety and Health Administration (OSHA) process safety management (PSM) guidelines, as may be applied to the facility to ensure the safety of its operations staff a
nd the surroundings

A maintenance program of regular
and preventative maintenance would be developed to maintain equipment in a reliable manner.

The
project’s
Raven SR Project would result in a less than significant impact as designed based on the Project’
s
adherence to all
applicable
regulatory

requirements mentioned in
this
section
, combined with
the
operational controls and redundancy designed as part of the
Raven RS process, materials and operations
, the impact would be less than
significant
.

c)

Emit ha
zardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one
-
quarter mile of an existing or proposed school?

No

impact
.

As discussed above, the proposed project would not emit hazardous emissions or handle hazardous

materials or waste. Moreover, t
he

project site
is

located
approximately

1. 1

miles from
Verde
Elementary School

at 2000 Giaramita Street
.

Therefore,

no impact would occur
.

d)

Be located on a site which is included on a list of hazardous materials sites com piled
pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?

No impact
.

An inactive waste disposal area

that is a
Class I Hazardous Waste
Management Facility (HWMF) is located wi
thin the WCCSL and
directly north

of the
BMPC
and project
site

(see Figure 1
-
3 in Chapter 1, and Figure 2
-
0 in Chapter 2)
. The
facility was closed pursuant to State and f
ederal regulations
, and final cap construction
was completed prior to 2003
. It is a to
tally enclosed facility with required environmental
control systems.

The proposed project site is not within the
previous

HWMF area;
therefore, no impact would occur.

e)

For a project located within an airport land use plan or, where such a plan has not be
en adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?

No impact
.

The

proposed project
is

not located
within

an

airport
land

use plan, and the
closest

airport to the project site
is

the
San Rafael
Airport located approximately

8.3 miles southeast
. Therefore, the proposed project would
not

be located within
two

miles

of

an

airport, and no impact would occur.

f)

Impair implementa
tion of or physically interfere with an adopted emergency response plan or emergency evacuation plan?

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Less than Significant Impact
.

In
the

event
of

a

large
-
scale disaster, emergency response
to the site would
be

coordinated by
WCCSL facility,
City and Coun
ty

fire
responders
,
and in adherence to the WCCSL Emergency Response and Evaluation Plan and local agency protocols. Emergency fire control procedures are also

included in the composting
and wood waste recycling operations plans. The WCCSL facility and pro ject site are
accessed from and exit to Parr Boulevard, and a serious of roadways

and paths
throughout the 340
-
acre WCCSL
provide sufficient
width

for emergency access.

The
proposed project would be developed within

part of the

existing BMPC property and
w
ould not create new or interfere with existing access or egress roads.

As detailed in the
Setting
above,
i
n addition, the proposed project would

comply

with

applica
ble

Environmental

Protection

Agency

(EPA) risk management plan (RMP) and Occupational
Safety

and Health Administration (OSHA)
, including additional voluntary compliance
with OSHA

process safety management (PSM) guidelines, as may be applied to the facility to ensure the safety of its operations staff and the surrounding community. PSM includes a
comprehensive collection of agencies and programs providing oversight over all aspects of plant operation and maintenance.

Therefore, there is no potential for the
project to impair implementation
of

emergency evacuation
or

an adopted

emergency
response pl
an.

g)

Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?

Less than Significant Impact
.

The

project site
is

flat and
surrounded
by the
WCCSL
facility
, which is composed of
gr
ass
-
covered disposal areas

of the landfill mounds
, runoff
control ponds and lagoons, and composting areas
, and
tidal marshlands of San Pablo and
Wildcat Creek
.

Open water of San Pablo Bay is approximately 0.25 miles westward from the project site.

Wildfire

hazard maps show the site as not being within a high wildfire hazard zone (CPUC, 2018).

Further, as discussed in criteria “a and b”, the project would
include

a
new 250,000
-
gallon integrated fire water tank and diesel engine is proposed for
emergency use
,

as required by fire department regulations
.

References

California Public Utilities Commission. Fire
-
Threat Map
–

State of California. January 19, 2018.

CEC, 2022
.

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

June 30,
2022.

Contra Costa County 2004.

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

June 2004
.

Contra Costa County 2009.

Addendum to the

Final

EIR

for the WCCSL BMPC and Related
Actions
,
SCH. 2002102057
. 2009.

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4.10 Hydrology and Water Quality

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitig
ation

Incorporated

Less

than

Significant

Impact

No

Impact

Hydrology

and
Water

Quality

Would

the

project:

a)

Violate

any

water

quality

standards

or

waste

discharge

requirements

or

otherwise substantially

degrade

surface

or

groundwater

quality
?

b)

Substantially decrease groundwater

supplies

or

interfere

substantially

with groundwater

recharge

such
that

the

project

may

impede

sustainable

groundwater
management of

the

basin?

c)

Substantially alter

the

existing drainage

pattern

of

the
site

or area,

including

through

the

alteration

of

the

course

of
a

stream or

river

or

through

the

addition of

impervious

surfaces,

in
a
manner

which

would:

(i)

result

in

substantial

erosion or

siltation

on
-

or

off
-
site;

(
i
i)

substantially increase the rate or amount of surface
runoff in a manner wh
i
ch would result in flooding on
-

or off
-
site;

(iii)

create

or

contribute

runoff water

which

would

exceed
the

capacity of

existing

or

planned

stormwater

drai
nage

systems

or

provide

substantial

additional

sources

of

polluted

runoff;

or

(iv)

impede

or

redirect

flood

flows?

d)

In

flood hazard,

tsunami,

or

seiche

zones, risk

release

of

pollutants

due

to

project inundation?

e)

Conflict

with

or

obstruct

implementation of
a
water

quality control

plan or

sustainable groundwater

management plan?

Setting

No surface water bodies exist on the project site.

As
previously

described
throughout other
sections of
this

analysis, the

following surface water bodies
exist
within
the WCCSL property
and
directly south/southwest of the

project site: runoff ponds or lagoons delineated as “Area B” and tidal waters delineated as “Area C” (shown in Figure 3 -
1,
Vicinity Map
, of the 2004 EIR)
.

San Pablo Creek

is
approximately

0.3 miles north of the project site, and
Wildcat Creek

is
approximately

280 feet
south/southeast of the project site, bordering the WCCSL south boundary which is an elevated levee (see Figure 2
-
0 and Figure 2
-
1 in Chapter 2

of this

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document
).

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

Open water of San Pablo Bay is approximately 0.25 miles west of the
project

site
.

The

levees
around the WCCSL have

been designed and
maintained

to exceed flood levels and the
upland
portions

are located outside

wetlands under U.S. Army Corps of Engineers (Corps)
jurisdiction.

Depth to groundwater at specific areas
of the project site can range from 5 to 7 feet or up to 10 -
1/2 feet below the ground surface. The depth to groundwater varies

seasonally. Groundwater
contamination on the WCCSL site was confirmed in a Phase I Environmental Site Assessment prepared for the
project (CEC, 2022). This recognized environmental condition (REC) is regularly monitored and the results are submitted to the State regulatory agency.

T
here

are no
anticipated plans for use

of existing groundwater

by the Project
.

Evaluation

a, b
)

Violate

any water quality standards or waste

discharge requirements or otherwise
substantially degrade surface or groundwater quality?

Substantially decrease
groundwater supplies or

interfere substantially with groundwater recharge such
that the project may imped
e sustainable groundwater management of the basin?

Less than Significant Impact
.

WCCSL implements a
Storm Water Pollution Prevention
Plan (SWPPP)

under the
NPDES

permit, as amended.

The drainage plan for the
WCCSL,
which
currently
encompasses the project s
ite,
accommodate
s

the 100
-
year storm
event
.

T
he WCCSL is managed to prevent the infiltration of surface water into the waste materials and to maximize and control the amount of surface water th at runs off via
overland flow with
berms, bench drains, down dr
ains
, which would manage runoff from
the project. Area 1 runoff

is

diverted

to

the

siltation

control

basin

located

behind

(east

of) the Golden Bear
Waste

Recycling Center
.

As introduced in
Section

2.9 2.8
,
Construction, Site Coverage and Drainage
, t
he proj
ect
would adhere to all applicable regulatory stormwater runoff controls and will pursue its own NPDES permit. The project’s SWPPP
would
be developed prior to construction and
operation of the facility and flows would be integrated into the existing WCCSL system
and ensure drainage from the proposed project site
would

drain towards existing
stormwater runoff control ponds (or bioretention facility) to which the rest of the WCCSL property currently drains. The drainage control systems would be

designed such
that the two systems are segregated and independent of one another. This would

minimize the creation of contact water (water that has come into contact with organic
feedstock)
as well as protecting
the
site
from

various health and safety hazards.

The rece
iving and handling area
would

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

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Any excess contact water that may be generated inside the canopy receiving area w ill
either be reabsorbed into incoming feedstock or collected via floor drains and diverted to the
facilit
y’s

sanitary sewer
.

The SWPPP also requires site inspections and a preventive storm water control maintenance program, with triggers for evaluation m
onitoring and corrective action as
needed under RWQCB review and oversight pursuant to State regulations.

Also, neither
construction nor operation of the project
would

involve use of groundwater
.

Taken
together, the proposed stormwater program and project
development would not impair
water quality or decrease groundwater.

The impact is less than significant.

c)

Substantially alter the existing drainage pattern of

the site or area, including
through the alteration of the course of a stream or river or throug h the addition of
impervious surfaces, in a manner which would:

(i)

result in substantial erosion or siltation on
-

or

off
-
site;

(
ii)

substantially increase the rate or amount of surface runoff in a manner which would result in flooding on
-

or off
-
site;

(
iii)

create or contribute runoff water which would

exceed the capacity of
existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or

(iv)

impede or redirect flood flows?

Less than Significant
Impact
.

The proposed project
would

involve minimal grading as
needed to prepare the site for new paving and foundations for the proposed modular buildings. The site is current flat and
would

remain so
, except for slight
grading

around
the proposed modular structu
re to prevent contact water
. As descri
b
ed in Section

2.8 2.9
,
Construction
,

Site Coverage

and Drainage
, in Chapter 2, t
he proposed project would
add

a
pproximately

1.21 acres of

new impervious surface area
(including modular structures)
to the existing 0.76
acres of impervious area that would be repaved. This would result in approximately 78 percent of the project site (2.5 acres) being impervious. Approximately

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

Although the
amount
of
impervious area on the project site would nearly double compared to the existing conditions, the proposed dr
ainage

management

would

effectively manage increased flows to the existing system and not exceed the

capacity of
th
e system.

A draft Stormwater Control Plan has been prepared for the project (Power, 2022). It delineates two nearly
equally
-
sized drainage management areas (DMA 1 and
DMA 2) across the
project

site. DMA 1
is the northern part of the site where the modular
building and
facilities

are proposed and its flows
would drain to an existing pump
that is
part of the
existing

stormwater
system. DMA 2
is generally the south and southwest part
of the project site

where
existing development and paved areas
exist for
truc
k traffic

and

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circulation;
its flows
would

integrate
directly
into the existing stormwater system.

The
DMA’s are delineated to effectively capture and direct runoff to not exceed the existing system.

Based on the 24
-
hour, 100
-
year storm, pre
-
development fl
ow is estimated at

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

potential change.

Also, permanent source controls would
be implemented to
address potential runoff
flows
,
including
.

Examples in
clude use of
equipment closures

and
regular inspection of
potential pollutant sources for debris or blockages that may interfere with intended stormwater flows.

Adherence

to the
SWPPP

under the
NPDES

permit

(see criterion “a
and b”)
would also minimize ero
sion as well as polluted runoff.

Overall, the proposed site alterations would not result in changes in stormwater flows that could exceed

the capacity

of the existing
stormwater

control
system

to which the project
site would flow.

It would also not impede
or redirect storm flows
.

The impact is less than
significant.

d)

In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?

Less than Significant Impact
.

The California Geological Survey has mapped tsunami
inundation
areas along the Richmond shoreline
, and the project

site
is located within the
hazard

zon
e (CGS, 2021)
.

Seiche risk at areas along Richmond’s shoreline are minimal because there are no large confined bodies of water with depths that would cause this hazard

(City of Richmond, 2011)
.

As discussed in the above
Setting,
the

100
-
year flood
flows in San Pablo Creek
adjacent to the project site and
would be t
otally contained in the
channel, also t
he

levees around the WCCSL have

been designed and
maintained

to
exce
ed flood levels.

Therefore
, risk of inundation at the site is low, particularly due to risk of
a
seich
e

or flooding on the project site.

Moreover, even if inundation were to
occur, the risk of release of pollutants from the proposed project is also low.

Th
e i
mpacts
would be less than significant.

e)

Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?

Less than Significant Impact
.

As discussed in criterion “a”, the proposed project would

not co
nflict with implementation of the existing water quality plan nor release pollutants

from

its

construction or operation.

References

State of California, 2021, Tsunami Hazard Area Map,

Contra Costa

County; produced by the
California Geological Survey, the C
alifornia Governor's Office of Emergency Services, and
AECOM; dated

2021. Accessed and printed September 13, 2022
.

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Contra Costa County 2004.

Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Relat
ed Actions
,
SCH. 2002102057
.

June
2004
.

Contra Costa County 2009.

Addendum to the

Final

EIR

for the WCCSL BMPC and Related
Actions
,
SCH. 2002102057
. 2009
.

City of Richmond, 2012.

Richmond General Plan
Update Environmental Impact Report.

SCH.
2008022018.
2 012.

Power, 2022
.

Draft S
tormwater Control Plan for Raven One
, July 22, 2022.

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4.11 Land Use and Planning

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Land Use

and Planning

Would

the

project:

a)

Physically divide

an
established

community?

b)

Cause

a
significant environmental

impact due

to

a

conflict with

any

land use plan, policy,

or

regulation

adopted

for

the

purpose

of

avoiding

or

mitigating

an

environmental

effect?

Setting

The proposed project area is the existing approximately 340 -
acre WCCSL, a self
-
contained area
and operation within the broader area of industrial and open space land uses , including the Bay
Tra
il / Wildcat Creek Marsh Trail
. Other nearby use
s

include

the West
County Wastewater

District Treatment Plant, EBMUD’s North Richmond Water Reclamation Plan, the Richmond Sanitary District, and other refuse services, automobile repair and towing businesses ,
and
lawn
services, etc.

The Richmond Parkway is a major roadway through the area and spurs the Parr Boulevard approach to the WCCSL and adjacent
uses
.

The next nearest
established
community
is the residential development at generally West Gertrude Avenue /Malcolm Drive,
approximately 0.75 miles southeast.

Evaluation

a)

Physically divide an established community?

No Impact
.

The proposed operation is consistent with current BMPC activities on the site

and activities throughout the WCCSL site
.

The
refore, the

project could not divide any
established community
,
as the project is located within an existing
closed
landfill in an
area that

will not impede established transportation infrastructure to the community, is located at the outer edges of the City’s limits

and is essentially surrounded by water on
three sides, and

is not within proximity to existing neighborhoods or other sensitive receptors
. The project would have no impact.

b)

Cause a significant environmental impact due to a

conflict with any land use pl
an,
policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?

Less than Significant Impact
.

The proposed
facility and operation
to convert
blended

green waste and food waste obtained from the
existing
OMPF

located
oper
ation adjacent

to

west of
the project site into renewable, transportation grade hydrogen

would not
conflict with any existing land use plan, policy or regulation intended to mitigat e

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environmental effects.

As proposed, the project does not require approval

of an
amendment to any aspect of the General Plan or the City’s Zoning Ordinance or Map.

CEQA does not require
the project to be
consisten
t

with all policies in the General Plan,
nor
does it require
an assessment of compliance with every applicable Genera l Plan
policy.

Overall, the project advances
Policy EC2.2

Climate
-
Friendly Fuel Support
production and distribution of climate
-
friendlier fuels (when and if any are identified) and
identify appropriate locations for fuel storage and distribution ( Energy an
d Climate
Change Element
).

The project also advances
CARB’s
Final
2022 Scoping Plan
,
the
state’s identified scenario for achieving carbon neutrality statewide no later than 2045 ,
including through the increased

use of renewable and green hydrogen in zero
-
e
missions
vehicles

and

heavy
-
duty vehicles

and by increasing

the current amount of hydrogen
supply
.

This impact would be less than significant.

References

CARB, 2022
a
. California’s
Final 2022

Climate Change Scoping Plan
, November 16, 2022
.

Available online:

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

Cit
y of Richmond, 2012.

Richmond General Plan
Update Environmental Impact Report.

SCH.
2008022018.
2012.

City of Richmond, 2012.

Richmond General Plan

2030:

Public Safety and Noise E
lement.

Table

3.7 -
4,
Liquefaction
.
2012.

City of Richmond, 2012.

Richmond Gen
eral Plan

2030:

Conservation, Natural

Resources and
Open Space Element
.
2012.

City of Richmond, 2012.

Richmond General Plan

2030

Historic Resources Element
.
2012.

City of Richmond, 2012.

Richmond General Plan

2030:

Energy and Climate Change Element
.
2012.

Contra Costa County 2004.

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

June
2004
.

Contra Costa County 2009.

Addendum to the

Final

EIR

for the WCCSL BMPC and
Related
Actions
,
SCH. 2002102057
. 2009
.

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4.12 Noise

and Vibration

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Noise

Would

the

project

result

in:

a)

Generation

of
a
substantial

temporary

or

permanent

increase

in ambient noise

levels

in

the
vicinity

of
the

project
in

excess

of

standards

established in
the
local

general

plan
or

noise

ordinance,

or applicable

standards

of

other

agencies?

b)

Generation

of excessive

groundborne

vibration

or

groundborne noise

levels?

c)

For

a

project

located within the

vicinity

of
a

private

airstrip

or

an

airport

land use plan or,

where

such

a

plan
has
not

been

adopted,

within

two

miles

of

a

public airport
or

public

use airport,

would

the

project expose people
residing

or

working

in
the

project area

to excessive

noise

levels?

Setting

The
proposed p
roject is located entirely within the
City of Richmond.

The
West
County
Wastewat
er

District Treatment Plant and other industrial uses exist east of the property. The nearest residential receptors are 0.75 miles (approximately 3,949 feet) southeast from the project site.

Approximately 7
-

to 8
-
foot
-
high sound walls were installed at the
se residences when
Richmond Parkway was constructed to lower noise levels (WCCSL BMPC, 2003).

The primary noise sources in the vicinity of the
p
roject
site

include vehicles on adjacent
and
nearby
roadways: Richmond Parkway and Parr Boulevard. The existing ambient noise
environment in the
project
vicinity may be characterized by traffic noise modeling conducted for a previous EIR (City of Richmond, 2011) for primary roadways. Results of this traffic modeling are presented in
Table

4.12 -
1 and are representati
ve of transportation noise levels generated by
roadways.

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T
ABLE

4.12 -
1 L

OCALIZED
R
OADWAY
T
RAFFIC
N
OISE

1 Roadway

Segment Description

Predicted, Ldn
2 , dB at 50 feet

Background

Richmond Parkway

Gertrude Street and Parr Boulevard

75.9 Richmond Parkway

Parr Boulevard and San Pablo Avenue

74.7 NOTES:

1 Analytical Environmental Services. 2011.

Point Molate Mixed
-
Use Tribal Destination Resort and Casino Project
. Available
online:
https://www.ci.richmond.ca.us/DocumentCenter/View/7685/Section_4p11?bidId =

2 L
dn

is t
he energy average of the A
-
weighted sound levels occurring during a 24
-
hour period, and which accounts for the greater
sensitivity of most people to nighttime noi
se by weighting noise levels at night (“penalizing” nighttime noises).

SOURCE: Brown and Buntin Associates, 2008.

Evaluation

a)

Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of

standards established in the local
general plan or noise ordinance, or applicable standards of other agencies.

Less than Significant Impact
.

Noise would be generated during both construction and
operational phases of the
p
roject
.

Construction

Construction

of the
proposed p
roject would occur over a period of approximately
eight
months
, starting
Fourth
Second

Q
uarter

of
202
2 2023
, and
start
-
up of the plant is
projected to begin in the
Second to Third
Fourth

Quarter of 2023

or First Quarter of 2024
.

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

City of Richmond Noise Ordinance, Section 15.04.605.060, regulates construction noise by allowing construction work that generates noise to occur weekdays between the hours

7:00

a.m. and
6 :00 p.m.,
except outside of these hours or on Sundays and federal holidays unless a temporary waiver is granted by the Building Official or his or her authorized representative (City of Richmond, 20
18 )
.

T
he
proposed project would adhere to
the
City’s construction work hours. The City’s
construction noise level limitation of
75 dBA is

used to assess whether daytime L
eq

construction
-
related noise levels would cause a substantial temporary or periodic increase in ambient noise levels at sensiti
ve receptor locations.

City of
Richmond Noise

Ordinance,

9.52.110 Temporary construction activity
, limits
noise levels

measured at

SFR
-
1, SFR
-
2, SFR
-
3 Zoning Districts

(Single
-
Family

Residential)

to 75 dBA between
the hours of
7:00 a.m. to 7:00 p.m
. on wee
kdays.

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The operation of each piece of equipment would not be constant throughout the day, as equipment would be turned off when not in use. Over a
typical workday, the equipment
would be operated at different locations and all the equipment would not oper ate
concurrently at the same location
within
the
p
roject site

or roadways to and from the
site
. Construction noise levels have been estimated using typical equipment source noise levels suggested in the Federal Highway Administration’s (FHWA) Roadway Const
ruction Noise Model (RCNM) and based on the type of construction equipment that are proposed to be used. To
quantify construction
-
related noise exposure that would
occur at the nearest sensitive receptors, it was assumed that the two loudest pieces of cons
truction equipment would operate concurrently at
the
location

within

the
p
roject site
and
construction vehicle paths

to the nearest sensitive receptor locations.

The estimated L
max

and L
eq

for each of the two loudest pieces of equipment that would be used

to construct the
project

components, and the combined L
eq

noise level associated
with the two loudest pieces of construction equipment at the closest sensitive receptor locations for each
p
roject component are identified in
Table

4.12 -
2 . The combined L
eq

construction noise levels would not exceed the City’s construction noise level limitation of 75 dBA described in Table

4.12 -
2 . This modest noise contribution would not increase
the existing ambient noise level at the nearest receptor .

T
ABLE

4.12 -
2 C
ONSTRU
CTION
E

QUIPMENT
N
OISE
L
EVELS

Type of
Equipment

Distance to Closest
Sensitive Receptor
(feet)

Equipment
L
max
, dBA

Equipment Hourly
L
eq
, dBA/Usage%

Combined Leq at
Sensitive
Receptor, dBA

Demolition

Crushing/Proc.

Equipment

3 ,
949 (Residences)

52.3 45.3/20%

46.2 Excavators

42.8 38.8/40%

Site Preparation

Tractors

3 ,
949 (Residences)

46.0 42.1/40%

45.6 Rough Terrain
Forklifts

47.0 43.1/40%

Grading

Excavators

3 ,
949 (Residences)

42.8 38.8/40%

43.7 Tractors

46.0 42.1/40%

Building Construction

Rough
Terrain
Forklifts

3 ,
949 (Residences)

45.4 41.5/40%

46.0 Other Construction
Equipment

47.0 44.0/50%

NOTES:

L
max

= maximum instantaneous noise level; L
eq

= the equivalent sound level used to describe noise over a specified period of time, in terms of a s
ingle numerical value
; L
max

= the instantaneous maximum noise level measured
during the measurement period of interest.

SOURCE
:

Federal Highway Administration, 2008.

FHWA Roadway Construction Noise Model, Version 1.1
, December
2008.

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In addition to on
-
sit
e construction equipment, the
p
roject would also result in short
-
term
increases in local daytime traffic volumes. The
p
roject components would each add up to
approximately 84 one
-
way daily construction
-
related vehicle trips to area roadways,
including 72 o
ne
-
way daily hauling trips, 4 one
-
way daily vendor trips, and 8 one
-
way
daily worker trips
.

The
p
roject truck trips would access the
nearest
freeway
(Interstate
580)
via Parr Boulevard and Richmond Parkway and would not utilize roadways with noise
-
sensitiv
e land uses. Therefore,
the
associated increase in short
-
term construction
vehicular noise levels would not be expected to increase noise levels in the vicinity of existing sensitive receptors beyond the levels described in Table

4.12 -

2. Operation

The Rave
n SR system
would

run
up to
24 hours per day,
7 days per week,
although
an
average of

1.5 days per month are planned down times
.

The primary source of noise
during
p
roject operation would be mechanical equipment associated with the Steam/CO 2 Reformation sy
stem, including heating systems, HVAC equipment.

Also, feedstock
would be physically
deposited in the receiving area

via self
-
unloading transfer trucks or
other suitable vehicles
.

The hydrogen compressors are industrial pieces that could generat
e

noise up
to as much as 85 dBa at 1
.0

meter.

Additionally, trucks used to
distribute fuels generated on the site would be maneuvering within the parking lot of the proposed facility.

City of Richmond Noise Ordinance, Section 9.52.100, regulates operational noise le vels
from public property at residential areas. Per Section 9.52.100, noise levels caused by mechanic equipment on public property in residential areas should not result in noise levels in excess of 65 dBA measured at any boundary of a residential zone (Ci ty of
Richmond, 2022). Guidelines identified in the Richmond General Plan 2030, Action SN4.A, proposed commercial and industrial uses that locate in an area with day -
night
average sound level (L
dn
) of 55 or greater to provide noise study reports the City’s

goal
for maximum outdoor noise levels in residential areas is 60 L dn

(City o
f

Richmond,
2012). The 65 dBA L
eq
measured at any boundary of a residential zone is used here to assess whether operational noise levels would cause a substantial permanent increa se in
ambient noise levels.

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

from t
he project site property line.

Table

4.12 -
3 presents reference noise levels for many of the

stationary

sources for
informational purposes. Given the data in Table

4.12 -
3 and the
known distance to the
nearest noise
receptors, the operational noise levels wo
uld be
substantially
below the 65
dBA standard of the City of

Richmond Noise Ordinance and the operational noise impact would be
less than significant
.

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T
ABLE

4.12 -
3 R

EFERENCE
N
OISE
L

EVELS FOR
S

TATIONARY
N
OISE
S
OURCES
A

SSOCIATED WITH THE
P

ROPOSED
P
ROJECT

Stationary

Noise Source

Documented Sound

Levels (dBA)

Noise Level at
Nearest
Receptor

Source

HVAC Equipment

72 –
78 dBA at 30

feet without
acoustical treatments

19 -
25 dBA

Trane,
Sound Data and
Application Guide
, 2002

Standby

Diesel

Generator

75 –
90 dBA at 2
3 feet

(size dependent) without
acoustical enclosure

19 -
34 dBA

Cummins Power Generation,
Sound Attenuated and Weather
Protective Enclosures
, 2008

Loading Dock

77 dBA at 20

feet

20 dBA

Urban Crossroads,
Moreno Valley
Walmart Noise Impact Analysis
,
2015

NO
TES:

dBA = A
-
weighted decibels; ESA = Environmental Science Associates; HVAC = heating, ventilation and air conditioning

SOURCE: Data compiled by Environmental Science Associates in 2022. (Additional sources noted above.)

b)

Generation of excessive grou
ndborne vibration or groundborne noise levels?

Less than Significant Impact
.

Operations and maintenance of the
project facility

would
not include any sources of vibration that would be considered excessive. Groundborne vibration and noise associated with s
ome construction activities, including the use of pile
drivers, blasting, and vibratory rollers
,

can cause excessive vibration. The
project

would not
include any such activities. Groundborne vibration and noise levels generated by the types of equipment re
quired to
prepare the site and
construct the
proposed facility
would be
minimal and would not cause human annoyance or structure damage at a distance of 25

feet
or beyond from the source (FTA, 2018). No existing historic structures that would be potentiall
y vulnerable to vibration are located in the immediate vicinity of the p
roject site
such that any damage related to groundborne vibration from construction activities would occur. This impact would be
less than significant

and mitigation measures are not
w
arranted
.

c)

For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or wor king in
the project area to excessive noise levels?

No Impact
.

The
p
roject is located approximately 8.3 miles southeast of the San Rafael Airport and is not located within the 55 dBA L
dn

noise contours for the San Rafael
Airport (City of San Rafael, 2021
)
.

The
proposed p
roject would not involve the
development of noise
-
sensitive land uses that would be exposed to excessive aircraft noise. Therefore, there would be no impact.

References

California Department of Transportation (Caltrans), 2013.

Technical Nois
e Supplement (TeNS)
.

September 2013.

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

April 25, 2012.

City of Richmond, 2022. Richmond Municipal Code, Article 15.04.605

-

Noise. March 16, 2022.

City of San Rafael, 20

12. San Rafael General Plan 2040 & Downtown Precise Plan, Chapter 4.13, Noise. January, 2021.

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

Federal Transit Administration (FTA). 2018. Transi
t Noise and Vibration Impact Assessment

Manual. September 2018. Available:
http
s://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research -
innovation/118131/transit
-
noise
-
and
-
vibration
-
impact
-
assessment
-
manual
-
fta
-
report
-
no
-
0123_0.pdf
. Accessed March
31, 2022.

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4.13 Population

and Housing

Environmental

Issues

Potentially

Sign
ificant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Population

and

Housing

Would

the

project:

a)

Induce

substantial unplanned

population

growth

in

an
area,

either

directly

(for

exam
ple,

by proposing

new

homes

and

businesses) or

indirectly

(for

example,

through extension

of

roads

or other

infrastructure)?

b)

Displace

substantial

numbers

of

existing

people

or

housing, necessitating

the construction

of

replacement housing
elsewhere?

Setting

As previously discussed in Section 4.11,
Land

Use and Planning,
in this section, the project area
entails open space and a range of

industrial
and commercial uses. No housing exists within 0.75
miles of the area, and the proposed p
roject would be developed within
the
existing
WCCSL and
BMPC facilities and operations.

Evaluation

a)

Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for exampl e,
through extension of roads or other infrastructure)?

No

Impact
.

The proposed project does not entail new housing, roads or other infrastructure that would induce substantial growth; the new business would involve 3 to 4 new
employees per shift, for a to
tal of 9 to12 new employees per day, which would not
constitute substantial population growth.

There would be no impact.

b)

Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?

No Impa
ct
.

No housing or people exist on the project site. The project would have no impact.

References

None.

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B
lank Page

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4.14 Public Services

and Recreation

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Public

Services

Would

the

project

result in

substantial

adverse

physical

impacts

associated

with

the provision

of

new

or

physically
altered

governmental

facilities,

need

for

new

or

physically

altered

governmental

facilities,

the

construction

of which

could cause significant

environmental

impacts, in order

to

maintain

acceptable

service

ratios, response times
or
other

performance objectives

for

any

of

the

public services:

a)

Fire

protection?

b)

Police

protection?

c)

Schools?

d)

Parks?

e)

Other

public

facilities?

Recreation

a) Would the project increase the use of existing

neighborhood
and regional parks or other recreational facilities su
ch that
substantial physical deterioration of the facility would occur or be accelerated?

b) Does the project include recreational facilities or

require the
construction or expansion of recreational facilities, which might have an adverse physical
effect on the environment?

Setting

The project area is currently serviced by the

Richmond

Fire Department (RFD), which also
manages the
West

County Fire District, which also serves San Pablo, El Sobrante, and unincorporated areas of
Western

Contra Co
sta County, including North
Richmond.

The nearest
fire station is RFD Station 62 at 1065 7th Street, Richmond.

Evaluation

Public Services

a)

Fire Protection

and Emergency Medical

Less than Significant Impact
.

The project site
would

be
served

by the same
fire and
emergency services that currently serve the
WCCSL.

The
project
would

also install a

new
2 50
,000
-
gallon
fire water tank and
diesel engine
in the northeast corner of the site

for emergency use
, as required by fire department regulations

The fire wa
ter tank would
be up to 25.5 feet tall and include two pumps, a small jockey pump for normal circulation, and

the diesel
-
powered fire pump
(shown in Figures 2
-
1 through 2
-

4.) A
ll
construction
-
related mitigation measures identified in this analysis would ap ply to that
development

onsite
.

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The proposed operation
would

involve up to
3 to 4
new
employees per shift

and would
not involve customers onsite
.

Also, t
he Raven SR system itself is not a combust
ion

process and would incorporate several safety measures, i ncluding
continuous monitoring
systems
,
automatic
plant operations
shut down without human intervention
,
compliance
with
applicable
EPA

RMP and OSHA PSM guidelines
, including
applicable USDOT
regulations

for the on
-
road transport of hydrogen gas
.

Overall,
the project would not
result in noticeable increased demand for service that would require

new fire or
eme
rgency medical facilities. The
impact would be less than significant
.

b,c
)

Police Protection
,
Schools, Parks, Other

No Impact
.

The project
would

not i
nvolve changes
that

would increase the demand for
policy protection on the project site.

Th
ere would be
no impact. Also, t
he project
would

not involve changes
that

would increase the demand for
schools, parks or other public
services.

Th
ere would be
no imp
act
.

Recreation

a)

Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?

No Impact
.

The project
would

not

introduce new
people

onsite that would increase the
use of recreational facilities or parks. New population would consist of up to
3 to 4
new
employees
per shift; no
customers would be onsite
.

There would be no impact

b)

Does the project include recreatio
nal facilities or require the construction or
expansion of recreational facilities, which might have an adverse physical effect on the environment?

No Impact
.

The project
would

include

new or expanded

recreational facilities or parks.

There would be no imp
act
.

References

City of Richmond, 2011.

General Plan 2030

–

Map 12.6 Police and Fire Services
. August
2011
.

City of Richmond, 2012.

Richmond General Plan
Update Environmental Impact Report.

SCH.
2008022018.
2012.

Google Earth Pro, Richmond Fire Stations,
June 2022.

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4.15 Transportation

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Transportation

Would

the

project:

a)

Conflict

with

a

pro
gram

plan,

ordinance

or policy

of

the

circulation system,

including

transit,

roadway,

bicycle

and pedestrian

facilities?

b)

Would
the

project conflict

or

be
inconsistent

with

CEQA Guidelines

Section 15064.3,

subdivision

(b)?

c)

Substantially

increase hazards

due

to a

geometric

design feature

(e.g., sharp curves

or

dangerous

intersections) or

incompatible

uses

(e.g., farm

equipment)?

d)

Result

in inadequate emergency

access?

Setting

The Richmond Parkway is a ma
jor roadway in the area that extends from

Interstate 580 near the
east approach to the Richmond
-
San Rafael Bridge northeasterly to

Interstate 80 near Hilltop
Drive.

Parr Boulevard from Richmond Parkway is the main approach to the project site within
the
WC
CSL and other nearby uses
.

Evaluation
21 a)

Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities?

Less than Significan
t Impac
t.

Table

4.15 -
1 summarizes the daily vehicle trip generation
for the
p
roject based on the expected number of employees and truck activity at the site.

Since trucks are larger and operate slower than passenger vehicles, a

passenger

car
equivalent (P
CE) ratio of 2.0 is used to convert the truck
trips

to passenger vehicle trips
(each truck is counted as two passenger vehicles). Accounting for PCE trips, the p
roject
is estimated to generate about
130
net new PCE trips on a typical weekday
Based on input
from Raven, a

total of 25 trucks are projected to access the Raven site on a daily basis, in
addition to 12 employee vehicles daily
.

21 All technical analysis conducted for this trans
portation analysis is included in this section; no separate technical appendix is warranted.

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T
ABLE

4.15 -
1 P
ROJECT
D
AILY
T
RIP
G

ENERATION
S
UMMARY

Use

Amount

Daily Trip Rate

Passenger Car
Equ
ivalent (PCE)
a

Daily Trips

(passenger cars
and trucks)

a

Employees

12 b

2.5 c

1.0 30

Trucks

25 d

2.0 e

2.0 100
50 Total
Daily
T
ri
ps
(PCE)

130
80 NOTES:

a

Spe
cifically for use in the operational emissions and energy analys is

in this document (see Sect
ions 4.3
Air Quality,

4.6 Energy
,
and 4.8,
GHG
Emissions
), a
A

passenger car equivalent

(
PCE
)

of 2.0
is used

to convert truck
trips

to passenger vehicle trips (each
truck is counted as two passenger vehicles
, or a total of 100 PCE trips
)

for trucks
because
they are la
r
ger and operate slower than
passenger vehicles
.

The project would have a total of 130 PCE trips (100 truck PCE trips + 30 employee trips).

b

Per the Project Applicant and described in Chapter 2,
Project Description
.

c

One inbound and one outbo
und trip per employee per day plus 0.5 trips per employee per day for other trips such as deliveries, running errands, etc.

d

Per the Project Applicant and as described in Chapter 2, Project Description
,
125

trucks would serve the site during a typical wee
k.

This estimate assumes they
would

be evenly distributed on five weekdays
.

e

One inbound and one outbound trip per truck
.

SOURCE: Fehr & Peers, 2022

For informational
purposes
,

T
t
he

addition of
130
80 new trips on a typical weekday would
not substantia
lly increase the motor vehicle volumes on the nearby streets, including Parr Boulevard and Richmond Parkway.
22 In addition, considering that
both
Parr Boulevard
and Richmond Parkway
streets

currently
have high truck volumes because they

are
City
-
d
esignated t
ruck routes
(established in the Richmond General Plan, Map 4.4)

that
serve
primarily industrial areas, the additional trips generated by the p
roject would not conflict
with existing and proposed
transit, roadway, bicycle
,

and pedestrian facilities

in the
p
roject vicinity
, which are located and planned in coordination with the designated truck routes
.

Although

level of service (
LOS
)

and other measures of vehicle delay
cann
ot be used
to
identify significant impacts under CEQA,
t
he Contra Costa Transportation

Authority
(CCTA), as described in their
Technical Procedures
(November 2022)
,

requires the
evaluation of project
effects

on multimodal transportation service objectives (MTSOs), (
including LOS at intersection
s

along the regional routes of significance
)

ou
tside of the
CEQA process for development projects that generate more than 100 net new peak hour vehicle trip. As shown in Table 4.15
-
1, the project would generate less than 100 net new
trips
daily
and would be below this threshold. Thus, analysis of proje ct impacts on traffic
operations and congestion is not required for the project.

22 Or 130 new passenger car equivalent (PCE) trips

on a typical weekday
, as
specifically
calculated for use in the
operational emissions and energy analysis in thi
s document, since trucks are larger and operate slower than passenger vehicles
. A

PCE
ratio of

2.0 is used to convert the 50 truck trips to 100 trips.

Combined with

the 30
employee trips per day, the project has a total
130

daily

PCE
trips.

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The
p
roject would also not modify any
transit, roadway, bicycle
,

or
pedestrian facilities

and would not conflict with existing or proposed facilities in the p
roject vicinity.

The
p
roject would be consistent
with

programs, plans, ordinances, and policies
addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities
. The impact is

less than significant
.

b)

Would the Project conflict or be inco
nsistent with CEQA Guidelines section
15064.3, subdivision (b)?

Less than Significant

Impact
.

CEQA Guidelines Section 15064.3, added in December
2018 and consistent with the requirements of SB 743, states that vehicle miles traveled (VMT) is the most appro
priate metric to assess the environmental impacts of a project on transportation.

T
he City of Richmond adopted VMT
analysis
guidelines,
methodology
, and thresholds of
significance on April 6, 2021, consistent with
the Contra Costa Transportation Authority

(
CCTA
)
’s adopted VMT guidelines
, which are also consistent with the State’s Office of
Planning and Research’s (OPR)
Technical Advisory on Evaluating Transportation
Impacts in CEQA
(December 2018)
.

The City of Richmond guidelines includes
screening
criteri
a for development projects that meet certain criteria that can readily lead to the conclusion that they would not cause a significant impact on VMT. The screening criterion applicable to the
p
roject is the Small Projects criterion, which states that projec ts
generating less than 836 VMT per day can be presumed to cause a less than significant impact on VMT.

Error! Not a valid bookmark self
-
reference.

summarizes the estimated VM
T generated by
the
p
roject on

a typical weekday. Since the City of Rich
mond’s adopted guidelines,
which are based on the CCTA Guidelines and consistent with CEQA Guidelines section

15064.3, subdivision (a) state that the VMT analysis for transportation impact purposes
can focus solely on VMT generated by
passenger vehicles

an
d light
-
duty trucks and not
include the VMT generated by heavy trucks
, the
p
roject VMT summarized in
Error! Not
a valid bookmark self
-
refe
rence.

does not include

the VMT generated by trucks for the
p
roject. As shown in
Error! Not a valid bookmark self
-
reference.
, the

p
roject is
estimated to
generate 174
VMT per day, which is below the screening criterion of 836 VMT per day.

Therefore, the
p
roject can be presumed to have a less than significant impact on VMT and is consistent with CEQA G
uidelines section 15064.3, subdivision

(b)

and the impact
is less than significant.

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T
ABLE

4.15 -
2 P
ROJECT
VMT

S
UMMARY

Use

Amount

Daily VMT Rate

Total VMT

Employees

12 a

14.5 b

174

Total

174

Threshold

836

Below Threshold?

Yes

NOTES:

a

Per the Project Applicant and described in Chapter 2,
Project Description

b

Daily commute VMT per worker in 2020 based on the CCTA Travel Demand Model for TAZ 10347, where the project

is located

c

Per the Project Applicant and as described in

Chapter 2,
Project Description
, 125 trucks would serve the site during a typical week.

This estimate assumes they
would

be evenly distributed on five weekdays

d

Per the Project Applicant and described in Chapter 2,
Project Description
, average truck trip
would be 40 miles; assuming two trips
(one inbound and one outbound) per truck.

SOURCE: Fehr & Peers, 2022

c)

Substantially increase hazards due to a geometric design feature, (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?

Less than Significant

Impact
.

The
p
roject would not modify the access point to the
existing
WCCSL
facility
, the internal circulation within WCCSL, or the public right -
of
-
way.

Passenger vehicles and trucks would continue to access the p
roj
ect site
through
Parr
Boulevard

and Richmond Parkway
.

T
he
p
roject

is
located
in an industrial area
with high
volume of
large trucks
already present on
surrounding roadways
,

including
Parr
Boulevard

and Richmond Parkway
.

The additional trucks added by the
p
roject
would not
result in incompatible uses or increase hazards.

Thus, the impact on
hazards

existing
roadway uses
due to
a geometric

existing
design feature
s

or incompatible uses

is less

than

significant.

d)

Result in inadequate emergency access?

Less t
han Significant

Impact
.

As
discussed

above, the
p
roject would
not
modify the
access point to the
existing
WCCSL
facility
,

the internal circulation within
WCCSL
,
or
the public right
-
of
-
way. Emergency vehicles would continue to access t
he
p
roject site
on
Par
r Boulevard
.

The
p
roject
would

be designed and constructed according to the applicable fire and safety standards at the time of construction.

Therefore, t
he
WCCSL
site would
continue to
be
accessible by fire and emergency vehicles through public streets a
nd the internal
roadways within the WCCSL
.

Thus, the impact on emergency access is less

than

significant.

References

California State’s Office of Planning and Research’s (OPR) Technical Advisory on Evaluating
Transportation Impacts in CEQA
(December 2018)
.

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City of Richmond
, 20
12 .

Richmond General Plan 2030, Element 4 Circulation
.

Availa
ble at
:
https://www.ci.richmond.ca.us/DocumentCenter/View/8846/Map -
44 ---
Existing
-
Truck
-
Routes?bidId
=

. Accessed

March 6, 202

3. Contra

Costa Transportation Authority

(CCTA)
,
2020.

Contra Costa County
Transportation
Analysis Guidelines
, 2020
. Ava
ilable at:
https://www.contracosta.ca.gov/DocumentCenter/View/70739/FINAL -
CCC
-
Transportation
-
Analysis
-
Guidelines
-
v3
-
5 -
10 -
21?bidId
=
. Accessed March 6, 2023.

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4.16 Tribal Cultural Resources

Environme
ntal

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Tribal

Cultural

Resources

Would

the

project
:

a
)

Cause a substantial adverse change in the signific
ance
of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site, feature, place,
cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural va
lue to a California Native American
tribe, and that is:

i
)

Listed

or

eligible

for

listing

in

the

California Register

of

Historical

Resources, or

in
a
local

register

of

historical

resources

as

defined

in

Public Resources

Code Section

5020.1(k),

or

ii
)

A resource determined by the lead agency, in its

discretion and

supported by substantial evidence, to
be significant

pursuant to criteria set forth in
subdivision (c)

of Public Resources Code Section

5024.1. In applying the criteria set f
orth in subdivision
(c)

of Public Resource Code Section 5024.1, the lead
agency shall

consider the significance of the
resource to a California

Native American tribe.

Setting

ESA contacted the California State Native American Heritage Commission (NAH C) on October
20,
2021
, to request a search of the NAHC’s Sacred Lands File and a list of Native American representatives who may have knowledge of tribal cultural resources in the project vicinity or interest in the proposed project. The NAHC replied to E SA by email on November 19,
2021
,

noting that the Sacred Lands File has no record of any sacred sites within the project site. The NAHC response included a list of 15 Native American representatives from 13 tribal groups who may have knowledge of tribal cu
ltural resources in the vicinity of the project site.

On May 4, 2022, the City received a response for consultation from Chairwoman Corrina Gould of the Confederated Villages of Lisjan. On May 18, 2022, the City held a virtual meeting with tribal members,
Chairwoman Gould, Deja, and Cheyenne, to discuss the project and any potential impacts to cultural resources. Based on the discussion, the tribe has no concerns with the project as it relates to impacts to tribal cultural resources and cultural resources, and is comfortable with
the proposed mitigation measures. See
Section
4 .5,

Cultural Resources
,
of this checklist

for a
summary of ESA’s NWIC records search and cultural resources sensitivity assessment.

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Evaluation

a.i
,

a.
ii)

Listed or eligible for listing
in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k), or significance of the resource to a California Native American tribe .

Less than Significant
Impact, a
fter

Mitigation
.

CEQA requires the lead agency to
consider the effects of a project on tribal cultural resources. As defined in PRC Section 21074, tribal cultura
l resources are sites, features, places,
cultural

landscapes, sacred
places, and objects with c
ultural value to a California Native American tribe that are listed, or determined to be eligible for listing, on the national, state, or local register of historical resources.

Based on the NWIC records search and the NAHC SLF negative search results, th ere are
no known tribal cultural resources listed or determined eligible for listing in the California

Register of Historical Resources or included in a local register of historical resources as defined in PRC Section 5020.1(k), pursuant to PRC Section 210 74(a)(1), would be
affected by the project. No tribal cultural resources have been identified by Native American representatives, and background research did not identify any tribal cultural resources. In addition, the City did not determine any resource t hat could potentially be
affected by the project to be a significant tribal cultural resource pursuant to criteria set forth in PRC Section 5024.1(c).

In the event that cultural materials are identified during project construction activities

that
are dete
rmined to be tribal cultural resources,
implementation of
Mitigation Measure
CUL
-
1a: Cultural Resources Awareness Training
,

Mitigation Measure CUL
-
1b:

Inadvertent Discovery of Cultural Materials or Tribal Cultural Resources , and

Mitigation Measure CUL
-
2: I
nadvertent Discovery of Human Remains
, all
identified

above

in
Section

4.5 ,
Cultural Resources
, would reduce potentially significant
impacts

to
less than significant.

These

mitigation
measures
would ensure that
all personnel complete
a cultural resources a
wareness training prior to any ground
-
disturbing activity and that
work
halt
in

the vicinity of a find until a qualified archaeologist
and a Native American
representative
can make an assessment and pro
vide additional recommendations
.

References

Northwest

Information Center (NWIC), Records Search File No. File No.

21 -
1575
. On file, ESA,
March 23, 2022.

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4.17 Utilities and Service Systems

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Les
s

than

Significant

Impact

No

Impact

Utilities

and

Service
Systems

Would

the

project:

a)

Require or

result

in

the relocation

or construction of

new or

expanded

water, wastewater

treatment

or

stormwater

drainage,

electric power, natural

gas,

or

telecommunications

facilities,

the

construction

or

relocation

of

which could cause

significant

environmental

effects?

b)

Have

sufficient water

supplies

available

to
serve

the

project and

reasonably foreseeable

future

development

during

normal
, dry and

multiple

dry

years?

c)

Result

in
a

determination

by
the
wastewater

treatment provider

which serves

or

may

serve

the

project that

it
has
adequate capacity

to

serve

the

project’s

projected demand

in

addition
to
the

provider’s

existing

commitments?

d)

Generate

solid waste

in

excess

of

State

or

local

standards,

or

in

excess

of
the

capacity

of local

infrastructure,

or

otherwise

impair

the

attainment

of

solid

waste

reduction goals?

e)

Comply

with federal,

State,

and

local

management

and
reduction

statutes

and regulations

related

to

solid

waste?

Setting

The
project

site, within the WCCSL BMPC

property
, is currently served by all public utilities,
including water and wastewater treatment by EBMUD and West Cou
nty Wastewater

District,
respectively, as well as the reuse of runoff water, and PG&E provides electric power, natural gas.

Evaluation

a)

Require or result in the relocation or construction of

new or expanded water,
wastewater treatment or stormwater drain
age, electric power, natural gas, or
telecommunications facilities, the construction or relocation of which could cause significant environmental effects?

Less than Significant
Impact
.

The
existing WCCSL
would
use offtake approximately

0.5 MW
hour
from the

power generation for
Republic’s
onsite operation needs and the

rest would be used to power the proposed project. Any additional electrical power required beyond that generated onsite
,
including that required as LFG

may

supplies
diminish

or are depleted
,

w
ould come from an existing PG&E power drop to the
site

and/or a renewable
source
.

The project
would

also involve a new
250
,000
-
gallon

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integrated
fire water tank and
diesel engine
for emergency use,
per fire regulations, but
would
continue to be served by R
FD
and

the West County Fire District.

As previously
discussed in 4.14,
Public Services and Recreation,
all construction
-
related mitigation
measures identified in this analysis would apply to that development

onsite, which
would

ensure any environmental eff
ects from the project would be less than
significant
.

b
)

Have sufficient water supplies available

to serve the

project and reasonably
foreseeable future development during normal, dry and multiple dry years?

Less than Significant Impact
.

Steam is injected

into the process to promote the thermal
decomposition of the feedstock.

Estimated water flow required for boiler feedwater and
for cooling tower make
-
up
is about 70 percent of the total required and
is on the order of
60 gallons per minute
(gpm)

(81,500 g
allons per day [gpd]). A
dding in required water
flow for overall processes and wash water for cleaning, the total

water flow required for
the project is estimated
to be
81 gpm

(116,200 gpd)
(Raven

SR
, 2022b)
.

Potable water is available for both domestic a
nd fire protection to the subject property
from existing major facilities (e.g., reservoirs, pumping plants), which are serviced and maintained by EBMUD. Service
would

be granted subject to compliance with the
District’s regulations governing water service

and Schedule of Rates and Charges, which
may include water main extensions and/or off
-
site pipeline improvements

(Raven SR,
2022c)
. For this analysis, it is not anticipated that t
he proposed project would require new
water supplies for its operation to th
e extent that it would make future water supplies
insufficient

during future scenarios considering foreseeable future development . The
impact would be less than significant.

c)

Result in a determination by the wastewater

treatment provider which serves or

may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments?

Less than Significant Impact
.

Wastewater generated by the process is mainly cooling
tower blowdown, RO system
blowdown, and boiler system blowdown, along with a
small flow from the syngas wash columns. Intermittent flow is from potable sources (restrooms, sinks, etc.) and area wash down water. Wastewater would be generated from
the syngas wash columns, which can p
otentially contain low concen
trations of organic
compounds.

Wastewater
would
be treated before it is discharged to the sewer systems through sump and grease/oil
where the organic content
would
be removed for
capture/reclaim/disposal, and the water portion
sent to the wastewater sewer.

Total
wastewater
discharge from all project processes

(or waste streams) is estimated to
be 50,200 gallons per day
, and the West County Wastewater District
would

permit this
additional use upon its determination that the disch
arge may be covered by the Districts’
Pretreatment and/or Pollution Prevention programs

(Raven

SR
, 2022b)
.

Discussions are occurring
between the
P
p
roject

A
a
pplicant

and the

West County
Wastewater District and
are in the permitting process.

At this time, t
here are no

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anticipated capacity issues expected.

Given the small scale of the proposed project, the
lack of notable new
population

onsite, it is
reasonable

that the West County Wastewater
District, as wastewater treatment provide
r
,
would

maintain adequate

capacity

to meet its
demands with the addition of the proposed project. The impact would

be less than
significant.

d,e)

Generate solid waste in excess of State or local

standards, or in excess of the
capacity of local infrastructure, or otherwise impair
the attainment of solid waste
reduction goals?

Comply with federal, State, and local management

and reduction
statutes and regulations related to solid waste?

Less than Significant Impact
. The project
would

not generate
substantial
solid waste but
would co
nvert existing organic waste into a reusable fuel product. Therefore, the project

would not
conflict

with existing local or other laws or policies regarding the reduction,
reuse

and management of solid waste. The impact
would

be less than
significant
.

Refe
rences

City of Richmond, 2012.

Richmond General Plan
Update Environmental Impact Report.

SCH.
2008022018.
2012.

Contra Costa County 2004.

Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related A ctions
,
SCH. 2002102057
.

June
2004
.

Contra Costa County 2009.

Addendum to the

Final

EIR

for the WCCSL BMPC and Related
Actions
,
SCH. 2002102057
. 2009
.

RAVEN SR, 2022b. West County Wastewater District Wastewater Discharge Permit Application. October 2022.

RAVEN SR, 2022c. Correspondence from Tracy Barrow, East Bay Municipal Utilities District, to Mike Fatigati, Raven SR. September 2022.

______________________________

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4.18 Wildfire

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Wildfire

If

located in
or

near

State

Responsibility Areas

or
lands classified

as

very

high

fire hazard

severity

zones,

would

the
project:

a)

Substantially

impair

an

adopted

emergency

response

plan or

emergency

evacuation

plan?

b)

Due
to

slope,

prevailing

winds,

and

other

factors,

exacerbate wildfire

risks,

and thereby

expose

project

occupants

to, pollutant concentrations

from
a

wildfire

or

the

uncontroll
ed

spread

of

a
wildfire?

c)

Require
the

installation

or

maintenance of

associated

infrastructure

(such

as
roads,

fuel

breaks,

emergency

water

sources,

power

lines

or

other

utilities)

that

may

exacerbate

fire

risk

or

that

may

result

in

tempora
ry

or

ongoing

impacts

to
the

environment?

d)

Expose people or

structures

to

significant

risks,

including downslope

or

downstream

flooding

or

landslides,

as

a

result

of

runoff,

post
-
fire

slope

instability, or

drainage changes?

Setting

T
he
p
roject site borders
e
xpansive

non
-
native grassland and ruderal species

in

open and that can
get very dry during

summer months. Factors that contribute to the risk of fire include dense and fire
-
prone vegetation,

poor access to fire
-
fighting equipment b
ecause of slopes or inadequate
roads, lack of adequate

water pressure and service in fire
-
prone locations, and seasonal
atmospheric conditions that result

in warm, dry fire seasons with strong afternoon winds. Wildfire hazard maps show the site as
not
bein
g within
a high wildfire hazard zone

(
CPUC
,
2018
).

Evaluation

a)

Substantially impair an adopted emergency

response plan or emergency evacuation
plan?

Less than Significant Impact
. As discussed under Section 4.15,
Transportation
, the
p
roject would not mod
ify the access point to the
existing
WCCSL
facility
, the internal
circulation within WCCSL, or the public right
-
of
-
way.

Therefore, the project would not
impair any existing plans for emergency response or evaluation. The impact would be less than significa
nt.

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b)

Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?

Less than Significant Impact.

Certain project c
haracteristics
could have the potential to
exacerbate wildfire risks
, such as diesel fuel storage for the
fire water take
.

However, no
hazardous materials would be used in the
conversion
process. The

biocarbon

materials

produced
are

inert

to

the

process

(i
.e.,

not

gasified)
. Also, t
he conversion process also
derives electricity

from

fuel

cells

or

turbines and/or

internal combustion engine

generator

sets.

The project
site
is relatively flat, within the context of marshlands and Bay shoreline, and would also

include a new fire water tank
and
diesel engine
per fire regulations onsite
. The
tank would be used for emergency use, although the project site would still be
ing

served
by the RFD and the West County Fire District. The impact would be less than significa nt.

c)

Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the enviro
nment?

No

Impact.

The project site is fully served by existing infrastructure that currently service the WCCSL

operations
. It would not require the installation or maintenance of additional infrastructure
that may exacerbate fire risk. The
re would be no

im
pact.

d)

Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post
-
fire slope instability, or drainage
changes

Less than Significant Impact
. The project would not introduce new
people on the site,
other than up to three to four employees per shift. As previously mentioned, the site is relatively flat, not located within downstream flood or landslide areas.

The proposed
project is not located in a
high wildfire hazard zone (CPUC,
2018).

The impact would be
less than significant.

References

California Public Utilities Commission. Fire
-
Threat Map
–

State of California.

January 19, 2018
.

City of Richmond, 2011.

General Plan 2030
–

Map 12.6 Police and Fire Services
. August 2011.

City o
f Richmond, 2012.

Richmond General Plan Update Environmental Impact Report.

SCH.
2008022018. 2012.

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4.19 Mandatory Findings of Significance

Environmental

Issues

Potentially

Significant

Impact

Less

than

Significant

Impact

with

Mitigation

Incorporated

Less

than

Significant

Impact

No

Impact

Mandatory Findings

of

Significance

a)

Does

the

project

have

the

potential

to
substantially

degrade

the

quality

of
the

environment,

substantially
reduce

the

habitat

of
a
fish

or

wildlife

species, cause

a
f
ish

or

wildlife

population to

drop

below

self
-
sustaining

levels,
threaten
to
eliminate

a

plant

or animal

community,
substantially

reduce
the

number

or

restrict

the

range of

a
rare or

endangered

plant

or animal,

or

eliminate

important
examples of

the
major

periods

of

California

history or

prehistory?

b)

Does

the

project

have

impacts

that

are

individually

limited,

but

cumulatively

considerable?

(“Cumulatively
considerable” means

that

the

incremental

effects

of
a

project

are considerable

when

vie
wed

in

connection

with

the

effects

of

past

projects,

the

effects

of other

current
projects,

and

the
effects

of probable future

projects)?

c)

Does

the

project

have

environmental

effects,

which

will cause

substantial

adverse

effects

on human

be
ings, either

directly or

indirectly?

Findings

a)

Does the project have the potential to substantially

degrade the quality of the
environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to dr
op below self
-
sustaining levels, threaten to eliminate
a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or

prehistory?

Less than
S
ignificant
I
mpact
, after Mitigation
.

The proposed project may result in
potential
construction
-
related impacts to nesting special
-
status birds
and to
California
Black Rail and
California
Ridgway’s Rail
.

The potential impacts are red
uced to

less than
significant
by requiring
surveys and
avoidance of construction
-
related work during
specific times of year:

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

Mitigation Measure BIO
-
2: Avoid and Minimize I
mpacts to California
Black Rail and California Ridgway’s Rail

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The proposed project may result
in

potential impacts to C
ultural
R
esources
,
Paleontological Resources (Geology and Soils),

and Tribal Cultural Resources
,

unless the
following mitigation measure
s are implemented, which would reduce the potential
impacts to less than significant:

Mitigation Measure CUL
-
1a: Cultural Resources Awareness
Training

Mitigation Measure CUL
-
1b:

Inadvertent Discovery of Cultural Materials
or
Tribal Cultural Resources

Mit
igation Measure CUL
-
2: Inadvertent Discovery of Human Remains
.

b)

Does the project have impacts that are individually

limited, but cumulatively
considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable w
hen viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)?

Less than Significant Impact
, after Mitigation
.

CEQA Guidelines S
ection 15355
defines a cumulative impact as th
e condition under which “two or more individual
effects which, when considered together, are considerable or which compound or increase other en
vironmental impacts.

The cumulative impact from several
projects is the change in the environment which results from the incremental
impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects.” (California Code of Regulations [C.C.R.] Section 15355). The purpose of the cumulative analysis is to unders tand
the incremental impacts of the p
roject on the neighboring areas.

The project does not result in a
cumulative
consideration
cumulatively considerable

impact for any environmental factors.

The HRA evaluated the
Raven SR p
roject’s
contribution to
cumulat
ive
health
risk
-
related impacts based on CEQA’s requirements for
evaluating cumulative impacts and the BAAQMD’s methodology for calculating a proposed project’s co
ntribution to background risk. The project’s contribution to cumulative
health
risk
-
related i
mpact was less than significant.

The Raven
SR project
impacts

were measured

against baseline conditions on the project site. The Raven SR project lessens air quality

impacts when measured against the impacts generated by the existing
WCCSL
operations
.

CCTA

G
uidelines

(
which the City has adopted
)

require

a

cumulative analysis only if
a

project impact is
significant and unavoidable. Moreover, the
project is
below the VMT screening criterion and therefore presumed to have a less than significant transportation

impact
. For comparative purposes, the project’s total VMT
considering cumulative growth is substantially below the applicable

threshold.
23 One
common exception, this evaluation does identify
the BAAQMD Basic Construction
Mitigation Measures Recommended for

All Projects (Best Management Practices) to
address fugitive dust during construction, which applies even though the project’s construction air emissions are all below the BAAQMD CEQA thresholds of significance.

23 Th
e 2040 VMT rate is 15.0, so the total VMT = 12 daily trips x 15.0 = 180, compared to the 836 threshold (see Table 4.15
-
2).

4. Environmental Checklist and Evaluation

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The BMPs also apply to all individual proje
cts and ensure that a significant impact with
respect to fugitive dust is less than significant.

Mitigation
Measure

AQ
-
1: Best Management Practices.

Given the

relatively

small
scope of the pr
oposed pr
oject
,
its
limited
potential
impacts,

as
well as the
A
lso, t
he
mitigation measures
identified
in this
Draft
updated

IS/MND

to
address potentially significant impacts
would also apply to other cumulative
projects

that
ha
ve

or could occur concurrently with the proposed project

and effective reduce or avoid
poten
tial
combined significant effects.
and listed below,
the

The

incremental effects
of

th
e
project are
not

cumulatively
considerable
when considered with the potential
effects
of

past, current, and probable future projects.

The
project
does

not have
any

signif
icant
cumulative
impacts
. Impacts would
be

less than significant.

c)

Does the project have environmental effects, which

will cause substantial adverse
effects on human beings, either directly or indirectly?

Less than Significant Impact
, after Mitigation
.

All

impacts identified
in

this
Draft
updated

IS/MND are either less than significant after
implementation of identified
mitigation measures (
all
listed
in criterion “a”

above

and below in this criterion “c”
),
or

less than significant
without the need for

mitigation.

Of those impacts

that require
mitigation
, only the potential

impact of

PM
10 and PM

2.5 (fugitive dust) being added
to the
local atmosphere

during construction
has the pot
ential
to adversely
affect

human beings,
directly or indirectly.

As discuss
ed under finding “b” above,
t
T
he

project’s
implementation of
Mitigation Measure AQ
-
1: Best Management Practices
,

would
reduce the impact
to
less

than significant.

All mitigation measures identified for the proposed project , and
clarified

in this
updated
IS
/MND,

are listed in the updated Draft Mitigation Monitoring and Reporting Program (MMRP) in Appendix
C

to this
document
.

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B
lank Page

5 . Document Preparers

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y Project

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5. Document
Preparers

5.1 CEQA Consultant

ESA

180 Grand Avenue
–

Suite 1050

Oakland, CA 94612

Phone 510.839.5066

Project Director

Crescen
tia Brown

Project Manager

Tim Sturtz

Air Quality/GHG

Chris Easter, Director

Air Quality
/
GHG

Tim Sturtz, Principal

Sarah Patterson
, Analyst

Madison Castelazo, Analyst

Human Health Risk

Tim Sturtz, Principal/Peer Review

Sarah Patterson
, Analyst/Peer

Review

Energy

Bailey Setzler,
Planner

Sarah Patterson
, Analyst/Peer Review

Noise/Vibration

Chris Sanchez, Senior Technical Associate

Hazardous Materials

Michael Burns, Environmental Scientist

Biologi
cal Resources

Sharon, Dulava, Biologist

Cultural
Resources

Heidi Koenig, RPA

Tribal Consultation

Heidi Koenig, RPA

Senior Review / Other Topics

Crescentia Brown

Graphics

Ron Teitel

5.2 Technical Subconsultant

Fehr & Peers Transportation

2201 Broadway
–

Suite
602

Oakland, CA 9461
2 Phone

510.835.1943

Transportation

Sam Tabibnia, Senior Associate

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APPENDIX

A

Emissions Data, Assumptions and Modeling Files

A.1
-
1 Original Emissions Data, Assumptions and
Modeling Files

A.2
-
1 Updated Air Quality and Greenhouse Gas
Assessment Tech
nical Memo

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

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Raven SR Bioenergy Project

A.1
-
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9 , 2023

A.1
-
1 Original Emissions Data, Assumptions and
Modeling Files

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RAVEN
Contra Costa County, Annual
Project Characteristics -
Land Use - Project specific info
Construction Phase - Project specific information
Off-road Equipment - Project specific information
Off-road Equipment - Project specific information
Off-road Equipment - Project specific information
Off-road Equipment - Project specific information
Trips and VMT - Client provided information
Grading - Project specific information
Vehicle Trips - Project specific information
Area Coating - Project specific information

1.1 Land Usage
Land Uses
Size
Metric
Lot Acreage
Floor Surface Area
Population
General Light Industry

40.00 1000sqft

1.30 40,000.00
0 1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
5 Wind Speed (m/s)
Precipitation Freq (Days)

2.2 58

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company
Pacific Gas and Electric Company
2023
Operational Year
CO2 Intensity
(lb/MWhr)
203.98

0.033
CH4 Intensity
(lb/MWhr)

0.004
N2O Intensity
(lb/MWhr)
CalEEMod Version: CalEEMod.2020.4.0
Date: 8/11/2022 11:05 AM

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