Table of Contents
Raven SR Bioenergy Project
i
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October 7,
2022
TABLE OF CONTENTS
Raven SR Bioenergy Project Initial Study
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
................................
................................
................................
......
6 1.1
0 Environmental Setting
................................
................................
..............................
6 1.11
Required Discretionary Approvals
................................
................................
...........
6 1.1
2 Other Public A
gencies Whose Approval is Required
................................
..............
7 1.1
3 California Native American Tribes Consultation
................................
......................
7 2
.
Project Description
................................
................................
................................
..........
9 2
.1
Existing
Site
Conditions and Ownership
................................
................................
..
9 2
.2
Surrounding Uses and Conditions
................................
................................
...........
9 2
.3
Site Plan and
Structures
................................
................................
........................
12 2
.4
Technology
................................
................................
................................
.............
17 2
.5
Op
erations
................................
................................
................................
..............
19 2.6
Employment
................................
................................
................................
...........
22 2.7
Transportation and Circulation
................................
................................
...............
22 2.8
Construction
,
Site Coverage
and Drainage
................................
...........................
22 2.
9 Off
-
site Improvements: Landscaping
................................
................................
.....
23 3.
Environmental Factors Potentially Affected
................................
..............................
24 4
.
Environmental Checklist
and Analysis
................................
................................
.......
2 5
4.1 Aesthetics
................................
................................
................................
...............
2 5
4. 2
Agriculture and
Forestry Resources
................................
................................
......
3 1
4. 3
A
ir
Quality
................................
................................
................................
...............
3 4
4.4 Biological Resources
................................
................................
..............................
43 4.5
Cultural
Res
ources
................................
................................
................................
.
53 4.6
Energy
................................
................................
................................
....................
57 4.
7 Geology, Soils and Mineral Resources
................................
................................
..
61 4.
8 Greenhouse Gas Emissions
................................
................................
..................
65 4.9
Hazards and Hazardous Materials
................................
................................
.........
7 2
4. 10
Hydrology and Water Quality
................................
................................
.................
77 4.1
1 Land Use and Planning
................................
................................
..........................
82 4.1
2 Noise
and Vibration
................................
................................
................................
84 4.1
3 Population
and
Housing
................................
................................
.........................
90 Table of Contents
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4.1 4
Public Services
and Recreation
................................
................................
.............
91 4.1
5 Transportation
................................
................................
................................
........
93 4.1
6 Tribal Cultural Resources
................................
................................
.......................
97 4.17
Utilities and Service System
s
................................
................................
.................
99 4.1
8 Wildfire
................................
................................
................................
.................
102
4.1 9
Mandatory Findings of Significance
................................
................................
.....
104
5 .
Document
Preparers
................................
................................
................................
...
106
List of Figures
1 -
1 Regional Context
................................
................................
................................
.......
3 1
-
2 Local Context
–
North Richmond
................................
................................
..............
4 1
-
3 Project Site and Surrounding
Landfill
Context
................................
..........................
5 2
-
0 Birdseye View of Project Si
te
................................
................................
..................
10 2
-
1 Project Site
and Raven SR Facility Areas
................................
...............................
11 2
-
2 Simulated
3D Site Development
................................
................................
..............
13 2
-
3 a
South Elevation (
West E
nd)
................................
................................
....................
14 2
-
3 b
South Elevation (
E
ast
E
nd)
................................
................................
.....................
15 2
-
4 Detailed Site Layout and
Raven SR
Facility Plan
................................
...................
16 2
-
5 Raven SR Process Diagram
................................
................................
...................
18 4
.1
-
1 Wildcat Marsh Trail Approach Toward Project Site (from E )
................................
..
27 4.1
-
2 Onsite View toward Project Site
................................
................................
.............
29 List of Tables
4 .3
-
1 Average Daily Construction
-
related Criteria Pollutant Emissions (pounds
per day) Without Mitigation
................................
................................
...................
3 6
4.3 -
2 Air Permit Ap
plication's Average Annual Operational Criteria Pollutant Emissions (tons
per year)
................................
................................
.....................
3 7
4.3 -
3 CalEEMod Average Daily Operational
-
Related Criteria Pollutant
Emissions (pounds per day)
................................
................................
.................
3 7
4.3 -
4 Average Annual Operational
-
Related Criteria Pollutant Emissions
(tons
per year)
................................
................................
................................
...............
3 8
4.8 -
1 BAAQMD GHG Thresholds of Significance
................................
............................
67 4.8
-
2 Annual Construction
-
Related Greenhouse Gas Emissions
................................
....
68 4.8
-
3 Unmitigated Annual Operational Greenhouse Gas Emissions
..............................
70 4.12
-
1 Localized Roadway Traffic Noise
................................
................................
............
86 4.12
-
2 Construc
tion Equipment Noise Levels
................................
................................
....
87 4.12
-
3 Reference Noise Levels for Stationary Noise Sources Associated with the Proposed Project
................................
................................
............................
89 4.15
-
1 Project Daily Trip Generation Summary
................................
................................
..
95 4.15
-
2 Project VMT Summary
................................
................................
.............................
96 Appendix
A
Emissions Data, Assumptions and Mo
deling Files
................................
................
A
-
1 B
Special Status Species Lists
................................
................................
.................
B
-
1 C
Draft
Mitigation Monitoring and Reporting Program
(MMRP)
...............................
C
-
1 1
. General Project Information
Raven SR Bioenergy Project
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1. General Project Information
1.1 Project Title
Raven SR Bioenergy Project
1.2 Lead Agency Name and Address
City
o
f Richmond
(City)
Planning and Build
ing Services 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 Departm
ent
(510) 620
-
6841
1.5 Pr
o
j
e
c
t L
o
c
a
t
i
on
1 Parr Boulevard, Richmond, California
(generally)
.
The proposed
Raven SR P
roject location is
within the West Contra Costa Sanitary Landfill
(WCCSL) facility
located in the northwest area o
f the
City of Richmond, in Contra Costa County,
California.
For purpose of
this environmental
document, t
he project
would
occur
within
approximately
2.5 acres
of
the existing
Republic Services
Bulk Materials Processing Center
(BMPC)
within “Area A”
of the
WCCSL
.
1 ,
2 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 jur
isdiction line
; the project
site is located
wholly within the City of Richmond, except for
use of
an
existing access/egress road located within the County
.
The project site is located
within
Assessor’s Parcel Number (APN)
408
-
140
-
009
.
1 Actual project operations will occur on a subset area of approximately 1.3 acre s that Raven SR will lease from
BMPC.
2 “Area A” of the WCCSL is approximately 12 acres in the upland portion of the property that encompasses p ollution
control facilities and stockpile areas (separate from
the
closed
Class I and active Class II
landfill a
reas,
the
runoff
ponds
or lagoons delineated as “
Area B
”
, and tidal waters
delineated as “
Area C
”
).
Shown in
Figure 3
-
1, Vicinity
Map, of the
Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Relat
ed Actions
,
June 2004. SCH. 2002102057.
1. General Project Information
Raven SR Bioenergy Project
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See
Figure 1
-
1, Regi
onal Context
;
Figure 1
-
2, Local Context
–
North Richmond
; and
Figure
1 -
3, Project Site and
Surrounding
Landfill Setting
, on the following pages.
1.6 Project Applicant’s Name and Address
Raven SR
S1
,
LLC
3 Matt W. Murdock CEO
PO Box 1360
Pinedale, WY 82941
1.7 Exis
ting General Plan and Zoning Designations
The project site and surrounding area is located within the “Open Space” General Plan land use designation and “Open Space” zoning district.
1.8 Purpose and Intended Use of this Document
The purpose of this Draft Initi
al 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 who
lly located within the City limits, t
he City
of Richmond
has discretionary authority over the
proposed project and is the
lead agency
in the preparation of this
Draft
IS/MND. The intended
use of this document is
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.
This CEQA document is a stand
-
alone analysis for the proposed project. Where appropriate and suitable, setting a
nd context information from prior CEQA documents certified for the WCCSL
/
BMPC facility
and operations is used in parts of this Draft IS/MND given that the project site is
located
within the WCCSL/BMPC facility.
4 However, no part of the proposed
project aff
ects existing WCCSL/BMPC operations; the proposed development and Raven SR system is a wholly independent utility, except that it
would
use feedstock available from the
current BMPC operation. Mitigation measures identified in this document will apply sole ly to the
proposed project and do not conflict with any applicable mitigation measures identified in the previously certified WCCSL/BMPC CEQA documents. Similarly, and addressed separately from this CEQA document, the proposed project requires approval of a City of Richmond
Conditional
Use Permit
(see Section 1.11, below), which is wholly independent from the existing City Conditional Use Permit (
CU 1101132
as amended
)
and Contra Costa County Land Use Permit
(LUP 2054
-
92 as amended) for the WCCSL/BMPC, as w
ell as any existing permits, control
3 The project applicant 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 on the West Contra
County Sanitary Landfill Bulk Materials Processing Center and Related Actions
,
June 2004
; and
Addendum to the
Final
EIR
for the WCCSL BMPC and Related Actions
, 2009
.
SCH. 2002102057.
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 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 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 agreements executed by various regulatory agencies that ha ve permitting
authority for the WCCSL/BMPC.
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,
Se
ction 3
is the draft environmental declaration, and
Section 4
is the
environmental
checklist that
evaluates
the
potential
environmental
impacts that may result from
construction or
operation of the
proposed
project
.
Section
5 contains the List of Preparers
.
1.9 Project Overview
The Raven SR Bioenergy Project (project) proposes to construct and operate a bioenergy system composed of the Raven SR multi
-
patented Steam/CO
2 Reformation process at the project site.
5 The
non
-
combust
ion
process
would
convert blended gr
een waste and food waste
,
obtained from
the existing BMPC operation adjacent to the project site ,
into renewable, transportation grade
hydrogen that
would
be exported offsite for various renewable energy products.
No
long
-
term
hydrogen storage
would
occur
onsite.
The project would involve the erection of a modular
structure 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.
The
WCCSL facility spans
app
roximately
340 acres
generally between Parr
Boulevard and San Pablo Bay, south of San Pablo Creek
. This area is composed of
expansive
planted
disposal areas
/landfill mounds
, runoff control ponds and lagoons, the organic material processing facility and com
posting areas
, and the location of the proposed project (within
part of
the BMPC area), is situated in the southeast area of the WCCSL facility.
San Pablo Creek
and
the
San
Pablo
and
Wildcat
Creek
tidal
marshlands
exist north and south of the WCCSL facilit
y
.
O
pen
water 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 approximately 300 feet southwest of the proposed project location
, an
d the West
County
Wastewater
District Treatment Plant and the Wildcat
Marsh
Trail and trail head
parking
exist
approximately 1,000
feet east of the
project location. The
surrounding uses are industrial
,
commercial
and open space
; the
nearest
sensitive rece
ptors to the project site are
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
CEQ
A
Documentation, Mitigated
Negative Declaration;
Conditional Use Permit
for
a new activity and facility to convert
5 CO
2 is
carbon dioxide.
1. General Project Information
Raven SR Bioenergy Project
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organic waste to
hydrogen
6 ; and
various development permits, including but
not limited
to
site preparation, construction and building activit
ies
.
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 issued by B
AAQMD
.
This permit application is currently
undergoing
review.
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 Construction NOI prior to
any grading on the project site
obtain coverage under both the statewide General Permit for Discharges of Storm Water Associated with Construction Activity and General Permit for Storm Water Discharges Associat
ed with Industrial Activities. 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 California Native American Tribes Consultation
P
ursuant to Publi
c Resources Code section 21080.3.1
,
on May 4, 2022, the City received a
response for consultation from a representative of the Confederated
Villages of Lisjan.
Consultation occurred on
May 18, 2022,
during which
the tribe
posed
no concerns with the
propose
d
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
.
6 The existing WCCSL facility operates under an
existing City of Richmond Conditional Use Permit (CUP) and other resources agency permits.
1. General Project Information
Raven SR Bioenergy Project
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Blank Page
2. Project Description
Raven SR Bioenergy Project
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2. Project Description
2.1 Existing
Site Conditions
and
Ownership
Existing
conditions of the project site are shown in
Figure 2
-
0, Birdseye View of Project Site
and Surrounding
.
T
he proposed Raven SR operation would be developed on approximately 1.3 acres
that Raven
SR
would
lease within
par
t of
the existing Republic Services
BMPC property
shown in Figure 2
-
0 , however it
would
operate separately from the existing
BMPC
operation
,
which
extends west of the project site
.
Figure
2 -
1, Project Site and Raven SR Facility Areas
,
delineates
the propos
ed
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 remainder
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
trailers
housing
ancillary
uses
on the site
would be
r
emoved
, and
remnant concrete foundations
from previous
uses
exist on the
north portion of the
site
.
(See Figure 2
-
0).
The project site is currently served by utility infrastructure and services by East Bay Municipal Utilities District (EBMUD),
West County
Wastewater District,
PG&E, and
City of
Richmond
police, fire and emergency services departments.
The owner of the property is West County
Sanitary
Landfill, Inc.
,
a
subsidiar
y
of Republic
Services, Inc.
2.2 Surrounding
Uses and Conditions
As highlighted in
Fi
gure 2
-
1 , the project site is
bound
by
existing fencing on the north, east and
south
, and connect
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
Figu
re
2 -
0 , t
he
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
,
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
so
uth
east of the
property.
Figure 1
-
2 and Figure 1
-
3 show t
he
surrounding
expanse
consists of
components of the
340
-
acre WCCSL facility
,
which consists of several distinct operations that function as a whole.
Notably, these
areas and uses
include
grass
-
cover
ed
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 t
he 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 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
Raven SR Bioenergy Project
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2.3 Site Plan and
Structures
Figure 2
-
2,
Simulated
3D Site Development
, illustrates the proposed fa
cility and key operation
components
simulated in a birds
-
eye view
.
All Raven SR’s materials handling systems would be
located inside
a
proposed modular structure
.
The proposed project
would
erect a new stand
-
alone
modular structure where storage uses
and r
emnant 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
.
F
igure
s
2 -
3 a and 2
-
3b
,
South
Elevation
s
,
illustrate the proposed facility and key operations in
elevation, and
Figure 2
-
4, Detailed Site Layout and Raven SR Facility Plan
, identifies each
component in detail.
The total new building area
would be
approximate
ly 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 area,
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 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
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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2.4 Technology
Raven SR
’s multi
-
patented
Steam/CO
2 Reformation technology can convert a variety of
organic
waste
feedstocks into a hydrogen
-
rich synth
esis gas (syngas)
through a three
-
step process shown
in
Figure 2
-
5 , Raven SR Process Diagram
.
7 Organic feedstocks include
biomass, municipal
solid waste, bio
-
solids, industrial waste, sewage, medical waste,
or a combination of these
,
obtained from the exis
ting
WCCSL
.
T
he first stage of the process to turn feedstock into a raw syngas begins with an externally
-
heated
“
biomass
steam
reformer
”
and a “syngas steam
reformer”
.
The
raw syngas is then
polished
,
and then processed
through purification of hydrogen
to
mak
e
the
hydrogen product
:
transportation
-
grade
hydrogen
-
rich syngas
.
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 seque
sters 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 within the organic waste feedstock (d
irt, 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.
8 The
amount of biocarbon
mixture
is approximately 15 to 20 percent of the volume of dry feedstock input.
(Also see Section 2.5,
Safety and Controls, Non
-
Combustion
, below.)
Solid material that goes through the feed handling system, including any volatile material (such
as
plastics
,
refrigerants, batteries) that may incidentally flow through to the rotary refo rmer would
be converted to syngas as they thermally decompose by exposure to temperatures in the range of 1,400
degrees
F
.
Any volatile material
would
become part of the syngas
, and
non
-
volatile, inert
material
would
report to the biocarbon solid phase.
No
emissions would be generated by any
volatile material
s that may inadvertently enter the process. (Also see
Feedstock Processing
,
below.)
As also shown in Figure 2
-
5 , the waste heat or “tail gas” from the conversion process can be blended
with existing lan
dfill gas (LFG, gas produced from the decomposition of organic solid wastes in the landfill) to generate power and increase the efficiency of the process.
At some point
in the cycle
,
the
tail gas
would
no longer recycle into the process and
instead
go to t
he
stack or
flare
, described below
.
Flare System
Raven SR anticipates use of its flare system
as
a backup for the
evacuation or venting
of
sy
n
gas
and, on rare occasion, vent hydrogen product
.
The flare system
would be in the constant state of
readiness th
rough a hoo
ded, continuous propane pilot
system. Use of the flare would be no more
than 100 hours per year and occur on three typical instances:
7 Hydrogen
-
rich
,
55 to 63 percent H
2 .
8 The biocarbon is considered sterile following thermal treatment by the first stage of the process, when biological pathogen
s (if any) are destroyed by elevated temperature and residence time of approximately 45 minutes.
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
generated and
evacuated from the system to the flare for destruction of
volatiles.
2. System shut
-
down: Whether for emergency shut
-
down or planned shutdown,
the system
would
require its inventory of syngas to be vented to the
flare for destruction of volat
iles.
3. No off
-
take available: On the rare occasion when a product load -
out truck
is not available
(e.g., traffic, breakdown, etc.) or an unplanned outage on the export equipment is experienced, and arrangements are in process
for replacement and/or repair,
Raven SR
must vent valuable hydrogen
product to the flare as it
would
have no provision for
emergency storage.
These instances have been quantified in Raven SR
’s
air permit application
to BAAQMD.
In 1993, the California Environmental Protection Agency’s D epartment of Toxic Substances
Control (DTSC) determined that the Raven SR process for the production of syngas from biomass and other carbonaceous solids was not categorized as either incineration or combustion and was therefore a suitable technology for u
se in California.
9 2.5
Operations
Pre
-
Processing and Load Checks
The origin of the feedstock and the pre
-
processing and screening redundancies built into the
system processes
would
to ensure that little or no material contamination that is incompatible with t
he Raven SR process
would
be introduced to the conversion system.
First,
Republic
Services
would
grind and
screen the incoming mix of green waste and organic food waste before delivering the feedstock to Raven. Any non
-
compostable material and other prohib
ited wastes
would be
minimized
through Republic’s screening and load checking programs
that occur at
its
compost facility.
10 After screening and load checking, the organic material is pre -
processed by grinding to reduce
volume
,
provide for a uniform mixtu
re 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
consist of self
-
unloading transfer trucks or other suitable vehicles
that would discharge
loads as directed by a spotter onto the floor of
Raven SR’s
material
9 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 Regu
lations (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 Station and is permitted for operation by the Bay Area Air Quality Management District (BAAQMD) under permit Nos. 23993
and 23320.
10 A load checking program are developed in compliance with Title 14, Code of California Regulations (CCR), §17409.5, and generally address the number of load checks to be performed; the location for the storage o f
prohibited wastes removed during the load checking process that is separately secured or isolated; records of load checks and the personnel training.
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receiving area.
There
the material
would be
visually inspected and 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 meta
l. 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,
Technology
, if any materials
are
missed by the screening processes
and enters the rotary reforme
r, 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
approxim
ately
14 tons per day of biocarbon and
up to 4,800
kilograms (kg)
(5.3 tons)
of hydrogen per day.
11 Feedstock
would
be weighed on Republic scales
before arriving at the Raven
SR site, and the
commodities that come out of the
process would be
weighed on Repu
blic scales outside of the Raven
SR
site. The
WCCSL
material
that would be
diverted to the Raven
SR
facility by Republic represents a portion of their permitted 250 tons per day of compost processing capacity
.
The
Raven SR process and facility i
s design
ed
for continuous operation without many start
-
ups or
shut
-
downs.
Accordingly, the
Raven SR system
would
run
up to
24 hours per day,
seven
days per
week,
although
an average of
1.5 days per month are planned down
times
. 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
power
would
come from onsite power gene
ration using newly installed engine
s
,
that
would
replace
existing, inefficient
engines
.
The fuel to be used for the generation is the
existing
LFG
from the
Republic Services BMPC
, combined with the tail gas from
the
pressure swing absorber
(PSA)
unit to pu
rify the hydrogen product. Republic Services
would
receive
approximately 0.5 MW
from the power generation for
its
onsite operation needs and the rest
would
be used to power the
proposed project
. Any additional electrical power required beyond that generate d onsite
would
come from an existing PG&E power drop to the site
, as also indicated in Figure 2
-
5 .
Safety and Controls
No Combustion.
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 bounded by high/low alarm
11 While Raven SR can produce synthetic liquid fuels, the proposed
Richmond location
proposes to
only pr
oduce
transportation grade hydrogen
due to the interest of the local and regional markets for non -
fossil fuel based
hydrogen.
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limitations
to
draw
the operator’s attention to the specific problem. The control system would
represent state
-
of
-
t
he
-
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 the process for
explosion. Piping and vessels
would
be periodically scanned
with
infrared
equipment to identify
hot spots or gas leaks that may threaten safety.
If hot spots or leaks were
identified, immediate
steps
would
be taken to correct or mediate the condition.
Also, r
emote monitoring of the facility
by Raven SR corporate
pr
ovides
oversight of the operation and early identification of problems as they development. The facility
would
maintain a “Plant Safety Handbook” and establish
procedures to be followed
if
events threaten the safety of the facility
or surroundings
. The fac
ility
would
maintain and evolve Standard Operating Procedures for aspects of the plant th at
require
frequent intervention
, for example,
accepted procedure
s
to accept a truck for loading of hydrogen
product,
to
fill to
regulated
maximum allowable pressures,
to ensure a
cool
-
down period to allow
the pressurized gas to shed the heat of compression, etc.
Safety Standards
and Maintenance
.
Raven SR units are equipped with continuous
monitoring systems and can automatically shut down plant operations without human
intervention. The project
would
comply with applicable
Environmental Protection Agency (EPA)
risk management plan (RMP) and
Occupational Safety and Health Administration (OSHA)
process safety management (PSM) guidelines
, as may be applied to the facility
to ensure the
safety of its operations staff and the surrounding community .
A maintenance program of regular
and preventative maintenance would also be implemented to maintain equipment in a reliable manner.
Fugitive Emissions.
The system is a closed proc
ess
once the orga
nic feedstock input is
managed
. Mechanical seals prevent fugitive emission from the first -
stage reformer which
operates under
mild
pressure.
The first stage vessel (SR1) has mechanical seals with pressurized nitrogen, which would prohibit
the release of fugitive emissions.
Tail gas generated by the
process is combined with LFG and used as a fuel to generate additional energy.
Odor Control.
Odors may exist from the organic feedstock input that is already produced and processed at the
WCCSL
.
N
uisance odor
from Raven
is unlikely
since
feedstock material
would
only be on the feedstock management area floor for relatively short periods of time . 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
w
ould be added to the management area if
objectionable odors
occur.
The facility could also store topical
treatment solutions (non
-
toxic and
biodegradable) onsite, which would be applied to neutralize odors if an immediate need arises.
Hydrogen
Storage and
Export Panel.
The hydrogen product is compressed for short term
storage before being exported via truck
-
m
ounted 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
,
2. Project Description
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incorporating best
-
practice Health, Safety, Security and Environment (HSSE) design
. The panel
is
compliant with
National Fire Protection Association (NFPA)
industry standards for handling
hyd
rogen.
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 .)
2.6 Employment
Raven
would
employ
approximately
three
to
four
employees per shift for the operation of the
Raven facility, for a total of
nine
to
12 new employees to cover all shifts and provide necessary suppor
t of the facility.
The facility would not involve customers onsite
.
2.7 Transportation and Circulation
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 to
approximately
12 hydrogen tube trucks and
up to approximately 15
biocarbon trucks (total
37 trucks
) per week
,
each
with an average trip of 40 miles
after leaving the
site
.
Considering this with other tru
cks and employees coming to and leaving the project site daily, the project is estimated to generate about 130 vehicle trips on a typical weekday.
In addition,
the Raven SR system
would
only use feedstock from ongoing existing
BMPC
operations on the prope
rty
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 the feedstock prep area
,
and
in addition to Figure
2 -
3 a
show three stalls where the tube
trucks
would
conn
ect 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 regulations .
2.8 Construction
,
Site Coverage
and Drainage
Raven anticipates
initiating construction activity
on the project site
in
Fourth
Quarter
of
2022
,
which would contin
ue for approximately
eight
months.
Start
-
up of the plant
is projected to
begin
in early
the Second or Third
Q
uarter
of 2023.
Construction proposed is to demolish
the existing
materials
and r
emove 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
x
isting materials
to be excavated include
remnant
concrete
foundations that
would
be pulverized and partially used as fill material.
The maximum
depth of excavation would be up to 2.5 feet. All excavation spoils and remaining concrete debris
would
remain o
n the landfill site.
Minimal
fill
, approximately 250 cubic yards,
2. Project Description
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23 ESA
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Initial Study
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would be hauled on site
for grading
; only demolition materials (asphalt and concrete) would be off hauled.
Approximately 0.76 acres of the 2.5
-
acre project site is currently impervious conc
rete or asphalt.
The proposed project would repave the existing 0.76 acres in addition to adding approximately
1.21 acres of impervious area (including modular structures), resulting in a total of 1.97 acres (or 78 percent) of impervious area on the site.
Approximately 0.53 acres of unpaved area along the
north edge of the site would remain undisturbed. There are no natural drainage paths on the site.
The project would adhere to all applicable regulatory stormwater runoff controls and would
pursue its own N
ational 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.
2.9 Off
-
site Improvements: Landscaping
As part of the proposed project, off
-
site landscaping improvements to the Wildcat Marsh Trail and trail head parking located approximat
ely 1,000 feet east of the project location. Due to
limited space and potential safety hazards, no new plants or vegetation would
be installed within
the Raven project site. Instead, new trees
would
be added to the public parking area near the
trailhead.
E
leven 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
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
Biological Resources
Geology, Soils and Seismicity
Hydrology and Water Quality
Noise/Vibration
Recreation
Utilities and Service Systems
Agriculture and Forestry Resources
Cultural Resources
II Greenhouse Gas Emissions
II Land Use and Planning
Population and Housing
II Transportation
Wildfire
Air Quality
Energy
Hazards /Hazardous Materials
Mineral Resources
Public Services
Tribal Cultural Resources
Mandatory Findings of Significance
Determination: (To be completed by Lead Agency)
On the basis of this initial study:
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.
I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.
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.
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. (/• /.>/\!•JL.
f.^
1^- 10 [ 07 i ^'-^
^ignatyre
/^'
Date
Printed Name For
Raven SR Bioenergy Project
Initial Study
24 ESA /D202100382
October 7, 2022
4. Environmental Checklist and
E
valuation
Raven SR Bioenergy Project
25 ESA
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4. Environmental Checklist and
Evaluation
4.1 Aesthetics
Environmental
Issues
Potentially
Significant
Impact
Less
than
Significant
Impact
with
Mitigation
Incorporated
Les
s
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, includ
ing,
but
not
limited to, trees,
rock outcroppings,
and
historic
building
within
a
State
Scenic Highway?
c)
In
non
-
urbanized
areas, substantially
degrade
the
existing
visual
character
or
quality
of public views of
the
site
and its surroundings
?
(Public
views are those
that
are
experienced
from publicly
accessible
vantage point).
If
the
project is
in
an
urbanized
area,
would
the
project conflict
with
applicable zoning and
other
regulations
governing
scenic quality?
d)
Create
a
new
source
of
substantial
light or
glare
which
would
adversely
affect
day
or
nighttime
views
in
the
area?
Setting
The
project site is within the
WCCSL
within
an
industrial
, commercial,
and open space
setting of
North Richmond. It is an integrated solid
waste management and
disposal facility and does not
have significant visual value.
Grading on the site over the years has
resulted in
topographic
variation
s created by the
hill forms
or mounds that are
the grass
-
covered landfills
. The hill forms
range
from
between elevations 110 and 160 feet
above mean sea level, with up to an additional
seven
feet of soil layer
(
WCCSL BMPC Draft EIR, 2003)
.
The area has
little or no distinctive
visual features
, except for
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 panoramic views of San Pablo Bay
, San
Pablo Ridge and Mt. Tamalp
ais 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 affect visual quality .
(
WCCSL BMPC Draft EIR, 2003)
Evaluation
a)
Have a substantial adverse effect on a scenic vista?
4. Environmental Checklist and
Evaluation
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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
areas are mostly at
lower
elevation
s
than that
of the WCCSL; dista
nt views are blocked by buildings or landscaping.
Views
toward the WCCSL and the project site from Richmond Parkway are blocked by trees and the property is difficult to distinguish
from adjacent and background across the Bay
.
Northbound and southbound mot
orists on the Richmond Parkway can view
the WCCSL,
but views are limited, short
-
term and sometimes obscured or blocked by median
landscaping or intervening trees and buildings. The proposed project site within part of
the BMPC area
is not visible from offs
ite areas
as it is at an even
lower elevation
and
behind intervening berms and
levees
.
Figure 4.1
-
1, Wildcat Marsh Trail Approach Toward Project Site (from East) ,
captures part of the project site that would be visible to users of this public trail. The v
iewshed 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 fac ilities
will appear consistent with the industrial nature of the existing visible facilities. The project
would
not have an adverse effect on a scenic vista.
The impact would be less than
significant.
b)
Substantially damage scenic resources, including,
bu
t not limited to, trees, rock
outcroppings, and historic building within a State Scenic Highway?
No Impact
.
No
designated
scenic highways currently exist
within the City of Richmond,
according to California Scenic Highway
Program
mapping system.
(Caltrans,
2016
)
While the City’s prior 1994 General Plan and General Plan EIR identified portions of Richmond Parkway as having a positive aesthetic value, the proposed
project site is not
visible from the parkway. (Richmond, 2011)
c)
In non
-
urbanized areas, substa
ntially degrade the
existing visual character or
quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project confl
ict 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
4. Environmental Checklist and
Evaluation
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Less than Significant Impact
.
The 340
-
acre WCCSL facility
,
in which the project site
sits
,
consists of several distinc
t 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 of the activities would significantly affect the visual quality of the facility.
Th
e 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
recycling activities within the WCCSL
property
. T
o the extent that the proposed project
f
acilities 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
Project 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 BMPC operation; no feedstock
would
be brought directly to the Raven
facility from offsite.
Product from the project operation
would
leave the pr
oject 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
could 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
BMPC activities
and waste recovery
operations. Other onsite processing operations operate until midnight. All existing operations operate under approved C
ounty and City use permits, which requires all
lighting system
s
to reduce glare and to not substantially impact area residents.
Existing
lighting is varied and includes various sizes of portable and directional flood lights
on
certain operations.
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
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The proposed project would also operate 24 hours a day, seven days per week, and would
be developed within an existing, functional area of the BMPC operation, which is currently lighted.
The project proposes LED lighti
ng mounted on 30
-
foot
-
tall poles.
Like
the existing WCCSL and BMPC conditions,
the
additional lighting would be focused and
shaded, incorporating directional shading
(down
-
shot reflectors) to limit light pollution
during
night 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 org
anic
sy
n
gas
or
on rare occasion vent hydrogen product
, would
be
hooded
, thus minimizing its v
isibility
from offsite
.
Given existing lighting conditions and that the proposed project site is located within the varied topography of the WCCSL and would not b
e 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
Cali
fornia Department of Transportation
(Caltrans)
, 2016. Scenic Highways Program. Available
at:
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8 057116f1aacaa
. Accessed
June 3, 2022
.
City of Richmond, 2011.
General Plan 2030
EIR
. August
2011
.
Contra Costa County
, 2003
. Draft Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions ,
SCH#
2002102057
.
November 2003.
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4.2 Agriculture and Forestry Resources
Env
ironmental
Issues
Potentially
Significant
Impact
Less
than
Significant
Impact
with
Mitigation
Incorporated
Less
than
Significant
Impact
No
Impact
Agriculture
and
Forestry
Resources
In
determining whether
impacts
to
agricultural
resources
are
signif
icant
environmental
effects,
lead
agencies may
refer
to
the
California Agricultural
Land Evaluation and Site Assessment
Model
(1997)
prepared
by
the
California
Dept.
of
Conservation
as
an
optional
model
to
use
in assessing
impacts
on
agriculture
and
farmla
nd.
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
inventor
y
of
forest
land,
including
the
Forest
and
Range Assessment Project
and
the
Forest
Legacy
Assessment
project;
and
forest
carbon
measurement
methodology provided
in
Forest
Protocols
adopted
by
the
California Air
Resources Board.
Would
the
project:
a)
Convert
Prime Farmland,
Unique Farmland, or
Farmland of
Statewide
Importance (Farmland),
as
shown
on
the maps
prepared
pursuant
to
the
Farmland
Mapping and
Monitoring
Program
of
the
California
Resources
Agency,
to
non
-
agricultural
use?
b)
Conflict
with
existing
zoning for
agricultural
use,
or
a
Williamson
Act contract?
c)
Conflict
with
existing
zoning for,
or
cause
rezoning
of,
forest land
(as
defined
in Public Resources
Code
Section
12220(g)),
timberland
(as
defined by Public
Resources
Code
Section 4526),
or
timberland
zoned
Timberland
Production
(as
defined
by
Government
Code
Section
51104(g))?
d)
Result
in
the
loss
of
forest
land
or
conversion
of
forest
land
to
non
-
forest use?
e)
Involve
other cha
nges
in
the
existing
environment
which, due
to
their
location
or
nature, could result
in
conversion
of
Farmland,
to
non
-
agricultural
use
or
conversion
of forest
land
to
non
-
forest use?
Setting
The 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 the
area that is now the WCCSL
in the early 1950s
on previously undeveloped land.
Evaluation
a
)
Convert Prime Farmland, Unique Farmland
, or
Farmland of Statewide Importance
(Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program
(FMMP)
of the California Resources Agency, to 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 Farmland,
Unique Farmland, or Farmland of Statewide or
Local Importance by the FMMP, bu
t is
designated as Other Land
,
and
is
surrounded by
l
ands 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 surrounding
s 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 Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Producti on (as
defined by Government Code Section 51104(g))?
No Impact
.
The proposed project
site is not zoned as forest land or timberland, and there are no forests on the
project
site. No impact would occur with implementation of the
proposed project
.
d, e
)
Resu
lt in the loss of forest land or conversion of
forest land to non
-
forest use?
Involve other changes in the existing environment
which, due to their location or
nature, could result in conversion of Farmland, to non
-
agricultural use or
conversion of forest
land to non
-
forest use?
No Impact
.
As stated above, the proposed project
is not zoned as forest land a
nd there are
no forests 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
within the WCCSL that is
designated as Other Land by the FMMP. The
project site
does not contain farmland
or forest land
and there are no
aspects of the
p
roject that would affect any agricultura
l land or forest land off
-
site. Therefore, the
proposed project
would 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.
4. Environmental Checklist and Evaluation
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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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4.3 Air
Quality
Environmental
Issues
Potentially
Significant
Impact
Less
than
Significant
Impact
with
Mitigation
Incorporat
ed
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
pollutant
concentrations?
d)
Result
in other
emissions (such
as
those
leading
to
odors
or) adversely
affecting
a
substant
ial
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 des
ignated 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 consider
ed the emission levels for which a project’s individual emissions would be cumulatively considerable when developing thresholds of significance for air pollutants. The significance thresholds used for project construction and operational impact analyses ar e based on
thresholds set in the BAAQMD’s CEQA Guidelines (BAAQMD 2017b).
For the purposes of this air quality analysis, sensitive receptors are defined as facilities and land uses that include members of the population that are particularly sensitive to the effects of air
pollutants, such as children, the elderly, and people with illnesses. Examples of these types of uses include schools, hospitals, and daycare centers. Residential areas are also considered sensitive to poor air quality because these sens
itive individuals could be present there, and people
usually stay home for extended periods of time, which results in greater exposure to ambient air quality
.
There are no sensitive receptors within 1
,
000 feet of the
project
site. The nearest sensitive
rec
eptors
to
the project site
are
r
esiden
ces at generally West Gertrude Avenue/Malcolm Drive
(
approximately 0.
75 miles
southeast
),
Verde Elementary School
at 2000 Giaramita Street
(approximately
1.1 miles
southeast
)
,
and
Contra Costa Health Clinic
at 1501 Fre
d Jackson Way
(
approximately
1.2 miles
southeast
)
.
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Evaluation
a)
Conflict with or obstruct implementation of the applicable air quality plan?
Less than Significant Impact
.
BAAQMD is the regional air quality authority in the
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 pollutant
s
:
state and federal 8
-
hour ozone standard, the state 1
-
hour ozone standard, the state PM
10 standard, and the state and federal PM
2.5 standards
.
BAAQMD guidance states that “if approval of a project would not result in significant and unavoidable air quali
ty impacts, after the application of all feasible mitigation, the project would be considered consistent with the Clean Air Plan” (BAAQMD 2017b).
As
indicated in the discussion of
criteria “
b
”
and
“
c
”
below, the
p
roject would not result in
significant air
quality impacts. Therefore, this impact would less than significant .
b)
Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non
-
attainment under an applicable federal or state
ambient air quality st
andard?
Construction
Emissions from the construction phase of the project would be generated primarily from heavy duty equipment such as excavators, cranes, and forklifts.
C
riteria air pollutant
emissions
from equipment and on
-
road vehicle exhaust
were e
stimated using CalEEMod
(version 2020.4.0)
;
modeling output files are included in
Appendix A
to this checklist
.
Construction
is assumed to take place over
a
n eight
-
month period
. Project specific data
for construction phasing schedule and equipment fleet pr ovided by the
P
roject
A
pplicant
was used in the model to estimate emissions
for
the construction period.
The total
emissions
(without mitigation)
generated over the duration of construction
were
divided by
the number of construction days for each
partial
c
onstruction year to determine average
annual
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 thresholds, which for construction have been established by BAAQMD in terms of average annual
emissions.
4. Environmental Checklist and
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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
)
W
ITHOUT
M
ITIGATION
Project Average Daily
Construction Emissions by
Year
ROG
NO
x
Exhaust PM
10 Exhaust PM
2.5 2022
0 .
11 1.00
0.04 0.04
2023
0.06 0.48
0.02 0.02
BAAQMD Threshold for
Significant Construction Imp
acts
10 10
15 10
Potential Significant Impact?
No
No
No
No
SOURCE:
ESA (Appendix A
to this checklist
)
Operations
After
the
project is built, operational emissions, including
stationary,
mobile
,
and area
sources, are anticipated to occur continuously th
roughout the project’s lifetime.
The
project is anticipated to begin operations in 2023.
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 limestone pellets
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, tre ated
water storage tanks, bisulfite storage tanks, anti
-
scalant storage tanks, and condensate
recovery tanks are exempt from the permit requirement under BAAQMD Regulation 2, Rule 1 (BAAQMD 2017c), as described in the permit application.
Table
4 .3
-
3 shows
the
anticipated emissions from the permitted sources.
Notably, the project
would
replace an existing biogas
-
fired engine with
three (
3 )
newer,
lower emitting, and more efficient
Waukesha or Jenbacher
engine
s.
This replacement
would
result in a lower emiss
ions
profile
in contrast to operating the facility using the
existing engine. The project is also expected to increase the functional use of landfill -
produced biogas, thereby reducing the amount
of organic gas sent to a flare for
venting or
evacuation
and
ultimately reducing the flare
-
based emissions.
Operational
-
related
mobile source
activities, such as
employee commuting, truck trips for
delivery and materials hauling
, use of landscape equipment,
and other sources 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,
4. Environmental Checklist and Evaluation
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landscape maintenance equipment, and fireplaces/stoves, evaporative emissions from architectural coatings, and co
nsumer products.
Table
4 .3
-
4 shows the emissions from
operational emission sources that are not part of the air permit application.
T
ABLE
4 .3
-
2 A
IR
P
ERMIT
A
PPLICATION
'
S
A
VERAGE
A
NNUAL
O
PERATIONAL
C
RITERIA
P
OLLUTANT
E
MISSIONS
(
TONS PER YEAR
)
Project Oper
ations
Emissions by Source
CO
NO
x
VOC/ROG
SO
2 Exhaust
PM
10 Exhaust
PM
2.5 Biogas engines
50.69 7.19
5.70 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
6.64 5.1
6 5.1
4 SOURCE:
Ramboll Permit Application (Raven
,
2022
a
)
T
ABLE
4 .3
-
3 C
AL
EEM
OD
A
VERAGE
A
NNUAL
O
PERATIONAL
-
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
0.14 0.
1 6
<0.01
<0.01
Offroad
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. 47
1. 66
0.0 5
0.05 SOURCE: ESA (
Appendix A
to this checklist
)
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T
ABLE
4 .3
-
4 A
VERAGE
A
NNUAL
O
PERATIONAL
-
RELATED
C
RITERIA
P
OLLUTANT
E
MI
SSIONS
(
TONS PER YEAR
)
Project
Op
erations
Emissions
NO
x
VOC/ROG
Exhaust
PM
10 Exhaust
PM
2.5 Air Permit
7.39 8.72
5.1 6
5.1 4
CalEEMod
1. 66
0. 47
0.0 5
0.05 Overall Total
9.05 9.
1 9
5. 2
1 5.1
9 BAAQMD Threshold for Significant
Operational
Impacts
10 10
15 10
Potential Significant Impact?
N
o
No
No
No
Source
: ESA (Appendix A
to this checklist
) and Ramboll Permit Application (Raven
,
2022
a
)
These tables show that on a project
-
level
assessment, emissions do not exceed significant
thresholds determined by BAAQMD for criteria pollutants emitted
during operations, and
therefore are less than significant.
Construction Air Emissions
Less than Significant Impact
.
Construction activities would result in emissions of
the
following non
-
attainment
pollutants
: r
eactive organic gases (ROG) and nitrogen o
xides
(NOx)
, which are ozone precursors, and
particulate matter (PM
10 and PM
2.5 ).
These
pollutant
emissions would be generated
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 from the project site.
Construction Dust
Less than Significant Impact
, after
Mitigation
.
Activities that generate dust include
excava
tion and equipment movement across unpaved construction sites. Dust can be an irritant causing watering eyes or irritation to the lungs, nose, and throat.
E
xcavation,
grading, and other construction activities can cause wind -
blown dust that adds PM
10 and
P
M
2.5 to the local atmosphere. The BAAQMD has taken a qualitative approach to addressing fugitive dust emissions during construction, such that any project that implements the BAAQMD Basic Construction Mitigation Measures Recommended for All Projects (Best
Management Practices)
would not result in a significant impact with
respect to fugitive dust
(BAAQMD 2017b)
.
Mitigation Measure AQ
-
1: Best Management
Practices
, provided below, spe
cifies BAAQMD recommended measures and would apply
to all individual project
s to address construction dust
.
In conclusion, while air emissions
from construction equipment are all below the BAAQMD CEQA thresholds construction dust emissions are always considered significant within the SFBAAB unless the mitigation measures below are
applied.
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Mitigation Measure
s
AQ
-
1: Best
Management Practices.
All subsequent projects, regardless of size, shall implement the following
best
management practices to reduce construction impacts, particularly fugitive dust, to a less
-
than
-
significant lev
el:
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 mater ial off
-
site shall be
covered.
All visible mud or dirt track
-
out onto adjacent public roads shall be removed
using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.
All vehicle speeds on unpaved roads sh
all be limited to 15 mph.
All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.
Idling times shall be minimized ei
ther by shutting equipment off when not in
use or reducing the maximum idling time to 5 minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations [CCR]). Clear signage shall be provided for
construction workers at all access points.
All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in prope r
condition prior to operation.
Post a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s phone numbe r shall
also be visible to ensure compliance with applicable regulations.
Operational Air Emissions
Less than Significant Impact.
Based on the operational emissions modelled and
summarized
in
Table
4.3 -
4 above,
activities
related
to
operating
the
bioenerg
y
system
would all be below significance thresholds.
c)
Expose sensitive receptors to substantial pollutant concentrations?
Construction
Less than Significant Impact
.
Construction equipment and associated heavy
-
duty truck
traffic generate diesel exhaus
t, which is a known TAC. Construction exhaust emissions may pose health risks for sensitive receptors.
However, there are no sensitive receptors
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nearby the project site, which is zoned for
open space
us
es
.
The nearest sensitive
receptor
s are
0. 75
miles sou
theast
, or more than 1
,
000 feet, which is the distance
considered in the BAAQMD CEQA
G
uidelines
.
Therefore, any concentrations of
diesel
particular matter (
DPM
)
generated during construction would be less than significant.
Operations
Less than Significan
t Impact
.
The proposed project would introduce a new source of
DPM and PM
2.5 emissions due to the installation of an emergency diesel generator at the centralized treatment facility
that
would
use
California Air Resources Board (CARB)
-
certified diesel fue
l. Emergency generators would be subject to BAAQMD permit
requirements, which would ensure that operation of these generators would not significantly impact nearby receptors
.
These activities would result in minimal TAC
emissions for emergency operations o
nly (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 operation
s
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 applyin
g 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 .
d
)
Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Less than Significant Impact
.
Existing uses on and near the WCCSL include operations
that are among t
ypical odor sources of concern
. These
incl
ude 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 proc
essed 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 receptors to the project site are residences a
t generally West
Gertrude Avenue/Malcolm Drive, approximately 0.75 miles southeast .
This is closer than
the 1.0
-
mile odor screening distance for greenwaste handling established in the BAAQMD’s CEQA Guidelines
.
Also, an elementary school and a health clinic
exist
approximately 1.1 and 1.2 miles, respectively, from the project site
-
slightly beyond the
screening distance
.
Uses
between the project site and these
the nearest sensitive receptors
to the southeast
include the
West
County Wastewater
District Treat
ment 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 relative flat, and no substantial areas of veg etation exist.
4. Environmental Checklist and Evaluation
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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 sens itive receptor area,
for approximately two months of the year (December and January).
N
uisance odor
from Raven
is unlikely
since
feedstock material
would
only be on the
feedstock management area floor for relatively short periods of time .
Nor would
the
sy
stem’s
tail gas
or the as
-
needed
flare
generate noticeable odor
.
Also, other than the
input of organic feedstock within the
system
, the
process
would not involve the storage
or
processing
of
other
potentially odor
ous
materials
nor contribute to odor from n
earby
existing WCCSL activities
.
Regardless, a
s described in Section 2,
Project Description¸
the project
would
involve
o
dor control
mechanisms to minimize
possible
additional
odors
from its operation. T
he proposed industrial metal canopy would be placed ov
er the
feedstock floor and infeed equipment to prevent stormwater contact.
The project may
incorporate control measures similar to those current employed by WCCSL, such as ensuring the input of feedstock into the system within a designated period of time f rom
receiving it from
WCCSL’s
o
nsite
organic material processing facility
to prevent
potential odor buildup; routine cleaning of floors, walls, and
equipment; use of odor
suppressants as
deemed necessary.
O
dor control
w
ould 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
attrib
utable to the proposed project, the project applicant shall promptly log and respond to any complaints and remediated.
Therefore,
any odor impacts
from the proposed project
would
not be
considered
substantial nor likely contribute substantially to any exi sting 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, 2017b
.
CEQA Air Quality Guidelines. Available online:
https://www.baaqmd.gov/~/media/files/planning
-
and
-
research/ceqa/ceqa_guidelines_may2017
-
pdf
.pdf?la=en
. Accessed April 22, 2022.
BAAQMD, 2017c. Regulations 2 Permits Rule 1 General Requirements. Available online:
https://www.baaqmd.gov/~/media/dotgov/files/rules/regulation -
2 -
rule
-
1/documents/20171206_fr_0201
-
pdf.pdf?la=en&rev=42c6de7702484ea58dfcbcecaeafa29f
. Accessed May 1, 2022.
RAVEN
,
2022
a
Air Permit Application
-
Bioenergy Facilit
y
. Prepared by Ramboll US Consulting,
Inc.
,
(Ramboll) for Raven SR, April 2022.
4. Environmental Checklist and
Evaluation
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42 ESA
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D202100382
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Blank Page
4. Environmental Checklist and Evaluation
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4.4 Biological
Resources
Environmental
Issues
Potentially
Significant
Impact
Less
than
Significant
Impact
with
Mitigation
Incorporated
Less
than
Significant
Impact
No
Impact
Biological
Resources
Would
the
project:
a)
Have
a
substantial
adverse
effect, either
directly or
through habitat
modifications,
on any
species
identified
as
a
candidate,
sensitive,
or
special
-
status
spe
cies in
local
or
regional
plans,
policies,
or
regulations,
or
by
the
California
Department of
Fish
and
Wildlife
or
United States
Fish
and
Wildlife
Service?
b)
Have
a
substantial
adverse
effect
on
any riparian
habitat or
other
sensitive
natura
l
community
identified
in
local
or
regional
plans, policies,
and
regulations
or
by
the
California
Department of
Fish
and
Wildlife
or
United
States
Fish
and Wildlife
Service?
c)
Have
a
substantial
adverse
effect
on
State
or
federally protected
wetlands
(including,
but
not
limited
to,
marsh,
vernal
pool,
coastal,
etc.)
through
direct
removal,
filling, hydrological
interruption,
or
other
means?
d)
Interfere
substantially
with the
movement
of
any
native
resident or
migratory
fish
or
wildlife
species
or
with
established native
resident
or
migratory
wildlife
corridors,
or
impede the
use of
wildlife
nursery
sites?
e)
Conflict
with
any
local
policies or
ordinances
protecting biological
resources,
such
as
a
tree
preservation
policy
or
ordinance?
f)
Conflict
with
the
provisions
of
an
adopted
Habitat
Conservation
Plan, Natural
Community Conservation
Plan,
or
other
approved local,
regional,
or
State
habitat
conservation
plan?
Setting
The project site is locat
ed
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 th
e WCCSL property
is a low density
industrial and open space area.
The local context in Figure
1 -
2 shows the project site located approximately 0.25
-
mile east of the
San Pablo Bay shoreline, mudflats
,
and open water. The tidal marshland of San Pablo Creek
i
s
approximately 0.3 miles north/northeast of the project site, bordering the WCCSL north boundary which is an elevated levee. As shown in Figure 2
-
0, the marshlands of Wildcat Creek sit
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approximately 280 feet south/southeast of the project site, bordering the WCCSL south boundary
,
which is also an elevated levee.
A
closed Class I landfill
is immediately north of the project site
and the main access road supports a cover of non
-
native grassland and ruderal
vegetation
species.
No trees exist on the project si
te. Several landscape trees
occur at
the Golden Bear Waste
Recycling Facility, located approximately 300 feet southwest of the project site.
Biological resources were
characterized
through the review and compilation of existing
information
and a biological
reconnaissance survey conducted by ESA biologists on June 29, 2022
.
T
he
study area included
the
project construction area
plus a 250
-
foot buffer
, to account for
potential indirect impacts to special
-
status species
. The
study area
for special
-
status plant
s
pecies
includes the
project construction area
, plus a 10
-
foot buffer due to the lack of potential for
indirect impacts to
plants.
No detailed surveys were conducted
for special
-
status plants or wildlife
or are
deemed
necessary based on the
developed and m
anipulated
conditions of the
project
site
and surroundings
, the scope of the proposed project’s construction and operations, and the
proposed standard methods to minimize disturbance to sensitive resources in the vicinity.
Species / Habitats
The uplands
of
the WCCSL are either
devoid of vegetation from on
-
going landfill operations and
roadways, or are dominated by nonnative grasses and forbs. Plant species observed in the grassland at the periphery of the project site
are dominated by non
-
native species suc
h 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 (
Carpo
brotus 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 -
st
atus
plants and wildlife, the surrounding grasslands and wetlands provide habitat for a variety of wildlife and plant species. Wildlife observed in the surrounding study area during the site reconnaissance survey include
American crow (
Corvus brachyrhyncho
s
), 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
-
necked
stilt
(
Himantopus mexicanus
), turkey
vulture (
Cathartes aura
), mallards (
Anas
platyrhynchos
), killdeer (
Charadrius vociferus
), and several gull species (
Larus
spp.)
.
Sensitive aquatic habitats occur outside of the project boundary, and include wetlands ,
sloughs,
creek 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 the San Francisco Bay after flowing throu gh
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
site. Numerous s
horebirds, waterfowl, and other wildlife use the marsh
and mudflats for foraging
and
resting
; however, the marsh is beyond the 250
-
foot project study area
.
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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 harv
est mouse (
Reithrodontomys
raviventris
)
and
California
Ridgway’s
rail
(
Rallus longirostris obsoletus
)
,
state
-
threatened
California black rail
(
Laterallus jamaicensis coturniculus
)
, and
several
other species considered
to be California
Species of
Special Co
ncern
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 plants), and the potential for occurrence
within
study areas.
Higher elevations of the marsh typically provide important refuge for small
mammals and birds during storms and high tides. However, due to
the extent of
developed and otherwise disturbed habitat on the project site , the narrow band of
cover along the
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 wetland habitats
.
Several special
-
status plant
species are known from the uplands and coastal salt marsh
habitats
along the shoreline of San Francisco and San Pablo Bays, but none have been reported
from the
vicinity of the WCCSL. A single occurrence of fragrant fritillary ( Fritillaria liliacea
)
was
r
eported from the Point Richmond area in 1900, but this occurrence is believed to have been
extirpated by development, and suitable habitat is absent on the site. Other special -
status plant
species known from marshland habitat along the shoreline of San Pab lo 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
Plant Rank
1B
species
are considered rare
under
Section 13580 of the California Environmental
Quality Act (CEQA) Guidelines. None have
been reported from the WCCSL, and suitable habitat
is absent on portions of the site proposed
for improvements.
Wetlands
No wetlands or other aquatic resources occ
ur within the project site.
Jurisdictional wetlands and
unvegetated
waters extend over the northern
coastal salt
marsh,
open water habitat, and San Pablo
Creek
channel.
The sloughs,
creek channel, and bay shoreline
which border the WCCSL property
are all u
nder
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 r
egulations, or by the California Department of Fish and Wildlife or United States Fish and Wildlife Service?
A list of special
-
status species that occur in the project region was identified based upon review of existing information
, including
q
ueries of th
e California Natural
Diversity
Database (CNDDB), U.S. Fish and Wildlife Service (USFWS) Official Species List, and
4. Environmental Checklist and
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the California Native Plant Society (CNPS). Habitats at the project area were assessed for their potential to support special
-
status species
using information about local species
occurrences and species’ habitat requirements, in
combination with the site visit
described above
(
Appendix B
)
.
Plants
No special
-
status plant species are
expected
to occur on the
disturbed
project site. Site
preparati
on 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 of past
development,
no
special
-
status
wi
ldlife
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, surroundi
ng 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 cunicula
ria 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 habit
at. Short
-
eared owl and northern harrier are ground nesting species, while loggerhead shrikes nest in shrubs and occasionally items such as brush piles, generally between two and four feet off the ground. Western burrowing owls nest underground in burrows
dug by mammals such as California ground squirrels
(
Otospermophilus beecheyi
)
.
California Ridgway’s
is listed as endangered under both
the Federal Endangered Species
Act (
FESA
)
and
the California Endangered Species Act (
CESA
)
, and is a state fully
-
protect
ed 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
these species
is present within
500 feet of the project site
and multiple oc
currences are
known from marshes adjacent to or nearby the project
site
.
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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 large truck traffic, human activity, operat ion of
machinery and elevated noise levels.
Regardless, some bird species, such as killdeer
(
Charadrius vociferus
) and American crow (
Corvus brachyrhynchos
), tend to be highly
tolerant of human disturbance and may still nest in areas with relatively high l evels of
human activity
.
Construction
Less than Significant Impact
, after Mitigation
.
Bird species listed under FESA and
CESA, as well as non
-
ESA
-
listed birds, are afforded conservation protections. Breeding birds are protected under California Fish and
Game Code
(FGC)
Section 3503 and
raptors are protected under Section 3503.5. In addition, FGC
Section 3513 and the
Federal MBTA (16 USC, Sec. 703 Supp. I, 1989) prohibit the killing, possession, or trading of migratory birds. Finally,
FGC
Section 3800 pro
hibits the taking of non
-
game
birds, which are defined as birds occurring naturally in California that are not game birds or fully protected species.
Impacts during the non
-
breeding season are not considered
significant, primarily due to the birds’ mobilit
y and ability to access other high
-
quality
foraging habitat in the region.
Also, the project site is disturbed and provides poor habitat for nesting birds.
However, equipment staging and project construction could render the site
and adjacent areas
tempora
rily 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 ca
use birds that have established a nest prior to the start of construction to change their behavior or even abandon an active nest, putting eggs and nestlings at risk for mortality. This would be considered a significant impact.
Implementation of Mitigatio
n Measure BIO
-
1: Avoid and Minimize Impacts to Nesting
Birds,
Except
Rails, and Mitigation Measure BIO
-
2: Avoid and Minimize Impacts to
California Black Rail and
California
Ridgway’s Rail would reduce potential construction
-
related impacts to nesting speci
al
-
status birds to a less
-
than
-
significant level by requiring
avoidance of construction
-
related work during the nesting bird season, or if avoidance of the nesting season is not possible, pre
-
construction nesting bird surveys and
establishment of no
-
constr
uction buffer zones around active bird nests. With
implementation of Mitigation Measures BIO
-
1 and BIO
-
2 , construction
-
related impacts
would be less than significant.
Mitigation Measure BIO
-
1 : Avoid and Minimize Impacts
to Nesting Birds, Except
Rails
To th
e extent practicable, project construction
activities requiring heavy equipment, or
any
tree trimming
,
shall be performed outside of the bird nesting season (February 1st through August 31st) to avoid impacts to nesting birds
. I
f these activities must be
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p
erformed during the nesting bird season, a qualified biologist shall be retained to conduct a pre
-
construction survey in the project construction and staging areas for nesting birds and verify the presence or absence of nesting birds no more than 14 calend ar days
prior to construction activities or after any construction breaks of 14 calendar days or more. Surveys shall be performed for the project construction and staging areas and suitable habitat within 250
feet of the project construction and staging ar
eas in order to
locate any active passerine (perching bird) nests and within 500 feet of the project construction and staging areas to locate any active raptor (birds of prey) nest , including
potential burrowing owl burrows
. If nesting birds and raptors do
not occur within 250 and
500
feet of the
project
area, respectively, then no further action is required if construction begins within 14 calendar days.
If active nests are located during the pre
-
construction bird nesting surveys, no
-
disturbance buffer zon
es shall be established around nests, with a buffer size established by the qualified biologist. Typically, these buffer distances are between 50 feet and 250
feet for passerines and between
150
feet and 500 feet for raptors. These distances
may be adjuste
d depending on the level of surrounding ambient activity and if an obstruction, such as a building or structure, is within line -
of
-
sight between the nest and
construction. Reduced buffers may be allowed if a full
-
time qualified biologist is present
to moni
tor 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 abandon
ed.
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 by the qualified biologist.
Mitigation Mea
sure BIO
-
2 : Avoid and Minimize Impacts to
California Black Rail
and California
Ridgway’s Rail
To minimize or avoid the loss of
individual California black rail and Ridgway’s rail
,
construction activities requiring heavy equipment
, adjacent to tidal marsh a
reas
(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 ar
eas 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
indire
ctly
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 develop
ed for use by USFWS and partners
(Wood et al.
2017).
Surveys are concentrated during the approximate period of peak detectability, January 15 to March 25 and are structured to efficiently sample an area in three rounds of surveys by broadcasting calls of t
arget 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
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adopted by Invasive Spartina Project (ISP) and
Point Blue Conservation Science to
survey
Ridgway
’s rails at sites throughout San Francisco Bay
Estuary
.
The
survey
protocol for Ridgway’s rail
is
summarized below.
Previously used survey locations (points) should be used when available to maintain consis
tency 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 vegetation.
Up to 8 points can be located on
a transect.
At
each
transect
,
three
surveys
(rounds)
are to be conducted
, with the first round
of s
urveys initiated between January 15 and February
6, the second round
performed February 7 to February 28, and the third round March 1 to March 25 .
Surveys s
hould be spaced at least
one
week apart and
the period between March
25 to April 15 can be used to complete surveys delayed by logistical or weather issues
. A
Federal Endangered Species Act Section
10(a)(1)(A) permit is required
to conduct active surveys.
Each point on a transect will be surveyed for 10 minutes each round. A recording of calls available from USFWS is broadcast at each point. The recording consists of 5 minutes of silence, followed by a 30
-
second recording of Ridgway’s rail
vocalizations, fo
llowed 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 5
00 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 apply to project activities
conducted duri
ng
their
breeding season (February 1
-
August 31)
:
The applicant shall coordinate with the
USFWS
-
and CDFW, as appropriate
depending upon species, to determine if project activities can continue during the nesting season based on nest location, natural visu
al barriers (e.g., levees)
between the project and marshlands, and the distance between proposed activities and identified activity centers. If impact cannot be avoided during the rail nesting season, activities would be delayed until after the nesting sea son.
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 signi ficant 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 BMPC and the project site
. The proposed
project would not substantially
increase
existing
night
time
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 focused and shaded, incorporating directional shading
(dow
n
-
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.
No
part of the propo
sed 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
i
nd
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 height, in which case the project would comply with the Ci
ty of
Richmond’s Bird
-
Safe Buildings Municipal Ordinance.
Overall, the proposed project also would not alter any of the area’s natural resources or native vegetation in a way that could adversely impact biological resources. The impact would be less than
significant.
b)
Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of Fish and Wildlife or United States Fish and W ildlife
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 along 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 Trai l levee.
The
proposed project does not involve any activity that would affect these areas. Therefore ,
the proposed project would have no impact.
c)
Have a substantial adverse effect on State or federally protected wetlands (including, but not limited to, m
arsh, 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 native resident or migratory wildlife corridors, or impede th
e 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 existing
developed nature of the site, the project site do
es not provide suitable habitat to be
considered a wildlife nursery site. Additionally, wildlife movement within the project site is restricted by existing privacy fencing that surrounds the project area. While the surrounding uplands and wetlands provide
habitat for the movement of native resident and
migratory wildlife, activities associated with the project are not expected to directly impact these areas or impede wildlife movement
. Therefore, this impact would be less than
significant.
e)
Conflict with
any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Less than Significant Impact
.
Construction or operation of the proposed project
would
not conflict with any local policies or ordinances pro
tecting 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
-
site landscaping
improvements
are proposed
to the Wildcat M
arsh 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 Californi
a 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.
A
lso, 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 activity, as well as the operational noise levels.
Therefore
, this impact would be less than significant.
f)
Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan?
No
Impact
.
The project site
does not lie within the boundaries of any an adopted Habitat Conservation Plan (HCP) or Natural Community Conservation Plan (NCCP) or any other approved local, regional, or State habitat conservation plan.
References
California Department of Fish and Gam
e
(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. Av
ailable online: www.dfg.ca.gov/biogeodata/vegcamp/natural_comm_list.asp.
Accessed
June 14, 2022
.
4. Environmental Checklist and
Evaluation
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/
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ial Study
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CDFW. California Natural Diversity Database (CNDDB) for 7.5 -
minute topographic quadrangles
Richmond, Briones Valley, San Francisco North, Oakland West, Oakland
East, Petaluma
Point, Mare Island, Benicia, San Quentin
, Commercial Version.
Accessed
June 14, 2022
.
CDFW.
Natural Diversity Database.
2022
.
Special Animals List. Periodic publication.
CDFW. Special Vascular Plants, Bryophytes, and Lichens List.
Accessed
2022
.
California Native Plant 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.
Ric
hmond General Plan 2030: Conservation, Natural Resources and Open Space Element.
Adopted April 25, 2012.
Contra Costa County 2004.
Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions ,
SCH. 2002102057
.
June
2004
.
Contra Costa County 2009.
Addendum to the
Final
EIR
for the WCCSL BMPC and Related
Actions
,
SCH. 2002102057
. 2009
.
United States Fish and Wildlife Service (USFWS)
.
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 E
dwards 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.
4. Environmental Checklist and Evaluation
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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
s
ignificance
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 th
ose interred
outside
of formal
cemeteries?
Setting
To determine the cultural resources sensitivity of the project site, ESA completed a records search and background research, including a review of historic maps, aerial imagery, and geologic/soils da
ta.
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 cultura l resources have been
recorded
in the vicinity of the
project site
; (2) assess the likelihood for unrecorded cultural
resources to be present based on historical references and the distribution of nearby sites; and (3) develop a context for the identificat
ion 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 studi
es within a 0.
5 -
mile radius of the
project site
.
NWIC digitized base maps (USGS
San Quentin
, CA 7.5
-
minute topographic map), to identify
recorded historic
-
era resources of the built environment (building, structures, and objects) within
and adjacent to
th
e
project site
.
Resource Inventories:
California Inventory of Historical Resources, California Historical Landmarks, Built Environment Resource Directory
(BERD) (through March 2020) and
Archaeological Determinations of Eligibility
(as of April 2012) for
C
ontra Costa
County.
No
cultural resources
have been previously recorded in the vicinity of the
project site
and there
are no historic
-
age architectural resources in or adjacent to the project site .
The nearest cultural
resources are a series of pre
-
contact
archaeological sites nearly 1 mile to the east that contribute to the Lower San Pablo Creek Archaeological District. These resources would not be impacted by the proposed project.
The underlying geology of the
project site
consists of
artificial fill over
Holocene Bay Mud deposits
.
The historic shoreline is approximately 0.4 miles (2,000 feet) east of the project site; pre
-
contact and historic
-
era archaeological sites in this environment would be
located at or very near to the historic shoreline.
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Therefor
e, 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 chan
ge 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 buildi
ng, structure, site, or object listed in or determined to be eligible for listing in the California Register
of Historical Resources (California Register)
, or determined by a lead
agency to be significant in the
architectural, engineering, scientific, econ
omic, agricultural,
educational, social, political,
or
cultural annals of California. The following discussion focuses on architectural and structural resources. Archaeological resources, including those that are potentially
historical resources according
to CEQA Guidelines Section 15064.5,
are addressed below under
question
b).
As a result of the records searc
h and
background research, it was
determined
that there are
no
architectural or structural resources
in or adjacent to
the
project site
that
potentia
lly
qualify as historical resources,
as defined in CEQA Guidelines Section 15064.5. As
such, there are no historical resources present within the project site
and there would be
no impact
on
historical resources.
b)
Cause a substantial adverse change in th
e significance of an archaeological resource
pursuant to Section 15064.5?
Less than Significant
Impact, after
Mitigation
.
This section discusses archaeological
resources, both as historical resources according to CEQA Guidelines Section 15064.5, as well as
unique archaeological resources, as defined in California Public Resources (PRC) (CEQA) Section 21083.2(g). A significant impact would occur if the project would cause a substantial adverse change to an archaeological resource through physical demolition,
destruction, relocation, or alteration of the resource.
Based on the results of the background research and environmental context, the potential for encountering archaeological resources during project implementation is low. However, in the unlikely event
that a previously unrecorded archaeological resource is identified during project ground
-
disturbing activities and found to qualify as a historical resource or a unique archaeological resource, any impacts on the resource resulting from the project could
be potentially significant.
Implementation of Mitigation Measure CUL
-
1a: Cultural Resources Awareness
Training
and
Mitigation Measure CUL
-
1b:
Inadvertent Discovery of Cultural Materials or Tribal Cultural Resources would reduce potentially significant imp
acts 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 cultural resources
awareness training prior to any ground
-
di
sturbing 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 Awa
reness Training
.
Prior to authorization to proceed,
the City shall engage
a qualified archaeologist,
defined as an archaeologist meeting the U.S. Secretary of the Interior’s Professional Qualification Standards for Archeology,
to
conduct a training program
for all construction workers involved
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 the procedures to follow in the event an
archaeological res
ource 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
assessmen
t. 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; sto
ne milling equipment (e.g., mortars, pestles, handstones, or milling slabs); and battered stone tools, such as hammerstones and pitted stones.
Historic
-
era
cultural
materials might include building or structure footings and walls, and deposits of metal, gl
ass, and/or ceramic refuse.
If
the City
determines, based on recommendations from a qualified
archaeologist
and a Native American representative (if the resource is pre -
contact
), that the
resource may qualify as a historical resource or unique archaeologi
cal resource (as
defined in CEQA Guidelines Section 15064.5) or a
tribal cultural resource (as
defined in PRC Section 21080.3), the resource shall be avoided if feasible.
Consistent with Section
15126.4(b)(3), this may be accomplished through planning cons
truction to avoid the resource, incorporating the resource within open space, capping and covering the resource, or deeding the site into a permanent conservation easement.
If avoidance is not feasible, the City shall consult
with a qualified archaeologis
t
and
a
Native American representative (if the resource is pre
-
contact) to determine
treatment measures to avoid, minimize, or mitigate any potential impacts to the resource pursuant to PRC Section
21083.2 and CEQA Guidelines Section
15126.4.
This shall in
clude 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 integr
ity 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 records search and background
research
conducted for the projec
t
determined that no human remains are known to exist
within the
project site
. Therefore, the
project
is not anticipated to impact human remains,
including those interred outside of formal cemeteries.
While unlikely, if any previously
unknown human remains
were encountered during ground
-
disturbing activities, impacts
on the human remains resulting from the
project
could be
potentially significant
.
Implementation of Mitigation Measure CUL
-
2: Inadvertent Discovery of Human
Remains
,
would
reduce potentially si
gnificant 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
o
roner. 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 Section 5097.98).
Mitigation Measure CUL
-
2: Inadvertent Disco
very 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
de
termine 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
p
ersons it believes to be the Most Likely Descendant from the deceased Native American, who in turn would make recommendations for the appropriate means of treating the human remains and any grave goods.
References
Northwest Information Center (NWIC), Recor
ds Search File No. File No.
21 -
1575
. On file,
ESA, March 23, 2022.
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4.6 Energy
Environmental
Issues
Potentially
Significant
Impact
Less
than
Significant
Impact
with
Mitigation
Incorporated
Less
than
Significant
Impact
No
Impact
Energy
Would
the
project:
a)
Result
in potentially
significant
environmental
impact
due
to
wasteful,
inefficient, or
unnecessary
consumption of
energy
resources,
during
project
construction or
operation?
b)
Conflict
with
or
obstruct
a
State
or
local
plan
for
renewable
energy
or
energy efficiency?
Setting
In 2020, more than 35 percent of the electricity PG&E delivered to its customers came from eligible renewable resources including solar, wind, bioenergy, geothermal and small hydropower and is o
n 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
updated
onsite power generation
, and the
fuel to be used is t
he existing
LFG
combined with
tail gas from the
project operation. An
existing PG&E power drop
is
available to the project site.
Evaluation
a)
Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption
of energy resources, during project construction or
operation?
Less than Significant Impact
.
Both construction and operation of the
project
would
involve expenditure of energy.
Below are discussions of the energy resources that would be consumed during con
struction and operation of the project.
Construction
During construction, energy use would be both direct and indirect. Direct energy use would include the consumption of fuel (typically gasoline and diesel fuel) for the operation of construction equipment
and vehicles. Energy in the form of electricity may
also be consumed by some pieces of construction equipment, such as welding machines, power tools, lighting, etc.; however, the amount of consumed electricity would be relatively minimal. Indirect energy
use would include the energy required to make the
materials and components used in construction. This includes energy used for extraction of raw materials, manufacturing, and transportation associated with manufacturing.
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CEQA focuses on the efficient use
of energy rather than
comparisons of
estimated
energy
amounts to be
consumed
to
quantitative significance thresholds. Construction activities at the project site would occur over a period of approximately 8 months. Construction activities would include use
of heavy
-
duty construction equipment
and offsite vehicles to
transport equipment, materials, and workers to the project component sites.
Energy use requirements in the form of diesel fuel
that would be
consumed by off
-
road
construction equipment
at the pr
oject site
have been estimated based on the GHG
emissions estimates
obtained from
the CalEEMod modeling conducted for the Air
Quality and GHG analysis
in Sections 4.3 and 4.8, respectively, of this checklist . GHG
emissions from CalEEMod were used in conjun
ction 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 equipment would be fueled by
diesel.
T
he analysis assumes that light
-
du
ty automobiles and trucks used by commuting
construction
workers would be fueled by gasoline, and that vendor vehicles and trucks that would
haul demolition debris, soil, and other materials would use diesel fuel . This
analysis assumes that no electric on
-
road vehicles would be used during
project
construction.
GHG emissions associated with commuting workers and vendor and haul trips were estimated using information provided by the
City
for estimated trip counts and
CalEEMod default trip lengths
.
In additi
on to fuels used by equipment and vehicles, construction activities would use water for dust suppression and management, which in turn would require electricity to supply, treat, and transport the water to the
project
area.
It is estimated that over the e
ntire construction period of the
project
, off
-
road equipment
and on
-
road
vender and haul trucks
would consume approximately
25,0
61 g
allons
of
diesel
fuel
,
and
commuting
worker vehicles would consume approximately
146
gallons
of gasoline.
Due to the relati
vely small scope of the
project
, as well as the limited duration of
construction activities, the consumption of fuel energy during construction would be temporary, localized, and would amount to a very small fraction of the 47 million gallons
of diesel and
336 million
gallons of
gasoline sold in Contra Costa County (California
Energy Commission [CEC], 2020).
Vehicles used for
project
construction and operation
would be required to comply with all federal and state efficiency standards. Additionally, there a
re no
project
characteristics or features that would be inefficient or that would result in the use of equipment and vehicles in a manner that would be less energy efficient than similar construction projects.
Therefore,
project
construction would not res
ult in wasteful, inefficient, or unnecessary
use of energy, and would result in a less
-
than
-
significant impact associated with energy
consumption.
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Operation
Once operational, the majority of the
project
’s power requirements would come from
electricity gen
erated onsite. The electricity would be generated using equipment such as
newly installed
Jenbacher
generator sets. The fuel that would be used for the generation is
LFG
from the Republic Services landfill,
blended
with the tail gas from a pressure
swing a
dsorption
(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
and the rest
of the generated energy
would be used to power the hydrogen plant. The
plant w
ould 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 requ
ired 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 woul
d therefore be minimal.
Energy would be consumed by new truck trips to the
site, with is also relatively minimal at up to approximate 100 truck trips per week.
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 associated with the
project
would
be net positive (i.e. more power would be generated than consumed) and not be
considered inefficient
or
wasteful and h
ence, this impact would be considered less than
significant.
b
)
Conflict with or obstruct a State or local plan for renewable energy or energy efficiency?
No
Impact
.
As discussed above,
project
construction would require the use of off
-
road
construction eq
uipment 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, idl
ing of commercial vehicles over 10,000 pounds and off
-
road equipment over 25
horsepower would be limited to a maximum of five minutes. Fuel use for project
construction would be consistent with typical construction and manufacturing practices, and energy s
tandards such as the Energy Policy Acts of 1975 and 2005, which promote strategic planning and building standards that reduce consumption of fossil fuels, increase use of renewable resources, and enhance energy efficiency.
Once operational, the
project
’s
primary
energy use would be
electricity generated onsite
using a fuel that would consist of
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 subj
ect 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
-
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free resources by 2045. PG&E, as the utility provider
,
is subject to these requirements.
T
here are no aspects of the proposed
project
that would conflict with or obstruct a state or
local plan for renewable energy
or energy efficiency
, so there would be no impact
.
References
California Energy Commission (CEC), 2020. 2020 California Annual Retail Fuel Outlet Report Results (CEC
-
A15), August 31, 2020. Available: https://www.energy.ca.gov/media/3874.
Accessed April 26
, 2022.
Pacific Gas & Electricity (PG&E), 2021. PG&E Currents, April 19, 2021. Available:
https://www.pgecurrents.com/2021/04/19/a
-
renewable
-
revolution
-
how
-
pge
-
and
-
its
-
customers
-
helped
-
write
-
californias
-
clean
-
energy
-
success
-
story/. Accessed April 26, 2022.
The Climate Registry (TCR), 2021. 2021 Default Emission Factors, Table 2.1 —
U.S. Default
Factors for Calculating CO2 Emissions from Combustion of Transport Fuels. May 2021.
Available: https://www.theclimateregistry.org/wp
-
content/uploads/2021/05/2021
-
Defau
lt
-
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
than
Significant
Impact
with
Mitigation
Incorporated
Less
than
Significant
Impact
No
Impact
Geology
and
Soils
Would
the
project:
a)
Directly or
indirectly cause potential
substantial
adverse
effects,
including
the
risk
of loss, injury,
or
death
involving:
i)
Rupture
of
a
known
earthquake
fault,
as
delineated on
the
most
recent Alquist
-
Priolo
Earthquake
Fault
Zoning Map
issued
by
the
State
Geologist
for
the
area or
based on
other
substantial
evidence
of
a
known
fault? Refer
to
Division
of
Mines
and
Geology
Special
Publication 42.
ii)
Stro
ng
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 o
r
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 Ta
ble
18 -
1 -
B
of
the
Uniform Building
Code
(1994), creating
substantial direct
or
indirect
risks
to
life
or
property?
e)
Have
soils
incapable
of adequately
supporting
the
use
of
septic tanks
or
alternative
wastewater
disposal
systems where
sewe
rs
are
not available
for
the
disposal
of wastewater?
f)
Directly or
indirectly destroy
a
unique
paleontological
resource
or site
or
unique geologic
feature?
Mineral Resources
Would the project:
a) Result in the loss of availability
of a known mineral
resource that would be of value to the region and the
residents of the State?
b) Result in the loss of availability of a locally important
mineral resource recovery site delineated on a local
general plan, specific plan or othe
r land use plan?
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Setting
There are several known active faults in the vicinity of the project site. The location lies within a geologic province of the San Francisco Bay named the “Richmond Basin," bounded by the San Pablo and Hayward faults. The act
ive fault in the region that are capable of producing the most significant ground shaking at the project site is the Hayward Fault, located approximately
3.7 miles
southwest of the project site.
(Rockridge, 2022)
A Geotechnical Investigation report was pr
epared 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 be relatively well compacted. The fill is underlain
by you
ng bay sediments known locally as
Bay Mud
,
which extends to depths of approximately
110 to 117 feet
below ground surface (
bgs
)
.
Bay Mud layer is generally soft to depths of
approximately 50 to 60 feet bgs, but can be more stiff below, depending on the degr ee of
over
consolidation
.
The Bay Mud is underlain by alluvium consisting of dense to very dense sand/silty sand that
extends to the maximum depth explored (120 feet bgs).
This analysis considers information
from the geotechnical investigation as well as
f
rom numerous
studies conducted for the WCCSL
property
.
Evaluation
Geological Resources and Soils
a)
Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving (
i
) Rupture of a known earthquake
fault, as
delineated on the most recent Alquist
-
Priolo Earthquake Fault Zoning Map issued
by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42. ( ii
)
Stro
ng seismic ground shaking? (
iii
) Seismic
-
related ground failure, including
liquefaction? (
iv
) Landslides?
Less than Significant Impact
.
Intense ground shaking during a large earthquake would
be expected at the project site, particularly given its close pro ximity of the nearest active
fault.
The project
would
adhere to standard industry practices, code requirements, and any geotechnical recommendations or design parameters
identified
in the geotechnical
study prepared for the project (Rockridge, 2022). (
for
the proposed earthwork, foundation
slabs, and any surrounding related improvements, utilities, or paved areas associated with the project, would reduce the potential impacts associated with ground shaking during a major seismic event; seismically
-
related g
round 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 Building Code, which would generally reduce known seismic hazar
ds to minimize
potential adverse effects
.
The
project
would
introduce an industrial operation and modular structures on the project site ,
involving up to three to four employees onsite at any particular time , and no customers
.
The impact
would
be less than
significant.
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b)
Result in substantial soil erosion or the loss of
topsoil?
Less than Significant Impact
.
The project, which relatively flat and partially paved and partially compacted soil and ruderal groundcover, would develop and implement an Erosion Co
ntrol 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 landslide
,
lateral spreading, subsidence, liquefaction or coll
apse
due to
unstable geologic units or
soil
.
Based on the results of previous analyses, most of the
sand layers present at the site
(primarily within the Bay Mud) are sufficiently dense, have
sufficient clay content,
and/or are overlain by a sufficient thi
ckness of Bay Mud, such that
the potential for
liquefaction is low
although the site is in a liquefaction hazard zone (see “a”) . The
greatest potential for liquefaction is
approximately
0.3 miles northward,
adjacent
to
San
Pablo Creek.
The project site is
not located on areas of landfill, which also sits upon Bay Mud and is susceptible to risks of settlement
over time. The impact would be less than
significant.
d)
Be located on expansive soil, as defined in Table 18
-
1 -
B of the Uniform Building
Code (1994)
, creating substantial direct or indirect risks to life or property?
No Impact
.
Expansive soil is not known to exist at the
WCCSL
site
(County, 2004)
.
No
impact would occur.
e)
Have soils incapable of adequately supporting the
use of septic tanks or alter
native
wastewater disposal systems where sewers are not available for the disposal of wastewater?
No Impact
.
The project does not proposed installation or use of septic tanks
or alternative
wastewater disposal systems
; the site is currently served by
West
County Wastewater
District
sanitary sewer
service and facilities which
would
continue with the proposed
project
.
f)
Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?
Less than Significant
Impact, after
Mi
tigation
.
Based on the evaluation in
Section 4.5,
Cultural Resources,
in this checklist, the
potential for encountering
paleontological or
unique geologic features on the project site during
ground
-
disturbing activities
for the
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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 H
uman Remains
,
all
identified
above
in
Section
4.5 ,
Cultural Resources
,
also apply to
reduce
the potential and unlikely
event
paleontological resources
are discovered.
Mineral Resources
a, b)
Result in the loss of availability of a known mineral
resource t
hat would be of
value to the region and the residents of the State? Result in the loss of availability of a locally important
mineral resource recovery site delineated on a local general plan, specific plan or other land use plan?
No Impact
.
The
proposed
p
roject
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.
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,
Liquefaction
.
2012.
Contra Costa County 2004.
Environmental Impact Report on
the West Contra County Sanitary
Landfill Bulk Materials Processing Center and Related Actions ,
SCH. 2002102057
.
June
2004
.
Contra Costa County 2009.
Addendum to the
Final
EIR
for the WCCSL BMPC and Related
Actions
,
SCH. 2002102057
. 2009
.
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4.8 Greenhouse Ga
s Emissions
Environmental
Issues
Potentially
Significant
Impact
Less
than
Significant
Impact
with
Mitigation
Incorporated
Less
than
Significant
Impact
No
Impact
Greenhouse Gas
Emissions
Would
the
project:
a)
Generate greenhouse
gas
em
issions,
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
St
ate
and Regional
The California Global Warming Solutions Act (Assembly Bill [AB] 32, 2006), as amended, sets statewide greenhouse gas (GHG) emissions caps. The California Air Resources Board (CARB) established the Climate Change Scoping Plan, which outline d a framework for achieving the
emission reduction goals set in the California Global Warming Solutions Act. In 2016, SB 32 and its companion bill AB
197 established a new climate pollution reduction target of 40 percent below 1990 levels by 2030 and inclu
ded provisions to ensure the benefits of State climate policies reach into disadvantaged communities.
Senate Bill (SB) 375 requires CARB to develop regional GHG reduction goals for the automobile and light truck sectors. The
Plan Bay Area 2040
is a plan t
o 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 i
ntended 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 possi
ble, 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, 2022) presents several scenarios for achieving carbon neutrality statewide no la
ter than 2045.
Significance Threshold
Greenhouse gas impacts are, by their nature, cumulative impacts because one project by itself cannot cause global climate change. As such, GHG emissions are evaluated under CEQA as a cumulative impact. To evaluate cum
ulative impacts, a lead agency must assess (1) whether the overall cumulative impact
would
be significant and, (2) if the overall impact is significant,
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whether the incremental contribution that the individual project under review would
add to the
overall
cumulative problem
would
be cumulatively considerable.
A conservative threshold of significance for determining the cumulative impact of a project’s GHG emissions is “net zero” emissions. This concept is supported by the BAAQMD in its Justification Report
:
CEQA Thresholds for Evaluating the Significance of Climate Impacts f
rom
Land Use Projects and Plans
(BAAQMD, 2022), which states: “If a land use project incorporates all of the design elements necessary for it to be carbon neutral by 2045, then it will c ontribute its
portion of what is needed to achieve the State’s climate goals and will help to solve the cumulative problem. It can therefore be found to make a less -
than
-
cumulatively
-
considerable
climate impact” (BAAQMD 2022).
Further,
the State’s Office o
f Planning and Research’s (
OPR
)
Final Statement of Reasons
for
Senate Bill 97 revisions to the CEQA Guidelines
state that, “AB32, and regulations
implementing
that statute, will require reductions in emissions
from certain sectors in the economy, but do no
t
preclude new emissions. Moreover, as explained
in the Initial Statement of Reasons, the proposed
amendments do not establish a zero emissions
threshold
of significance because
there
is no
‘one
molecule
rule’
in CEQA”
(CNRA,
2009).
For GHG thresholds, th
e BAAQMD published the 2022 Justification Report that presents GHG thresholds, which are based on AB 32 and California Climate Change Scoping Plan reduction targets and strategies developed to reduce GHG emissions statewide (BAAQMD 2022). These thresholds
are presented in
Table 4.8
-
1 . This analysis focuses on presenting Project GHG
emissions for information
al purposes and evaluating the
p
roject against the BAAQMD 2022
GHG significance thresholds.
The new BAAQMD thresholds are focused on land development pro jects,
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
analys
is
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 Thr
esholds
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 complian
ce 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 regional average
Option B
Be consistent with a local GHG Reduction Strategy that meets the criteria under the CEQA
Guidelines Section
15183.5(b)
1 Part 11 of the Title 24 Building Energy Efficiency Standards is referred to as the California Green Building Standards (CALGr een) Code
SOURCES:
BAAQMD 2022.
Justification Report: CEQA Thresholds for Evaluating
the Significance of Climate Impacts from Land Use
Projects and Plans
, April.
Evaluation
a)
Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Less than Significant Impact
.
GHG emission
s 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 emission
s associated with the
project were
estimated using project
-
specific information provided by the Project
Applicant
, such as
construction schedule and phasing; types, number, and horsepower rating of construction
equipment
to be
used,
their
daily
usage in te
rms
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 co
ntains the data and
assumptions used to
estimate the construction
-
phase GHG emissions that would be
associated with
the
project.
Carbon Dioxide (
CO
2 )
,
methane (CH
4 ) and nitrous oxide (N
2 O)
emissions from off
-
road
construction equipment and construction veh
icle trips were derived from the CalEEMod
run to estimate criteria air pollutant emissions. N
2 O and CH
4 emissions were multiplied
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by their respective Global Warming Potentials GWPs (25 and 298) and added to the CO 2 emissions to obtain CO
2 e emissions.
Const
ruction of the proposed project is anticipated to occur over a period of
approximately eight months. It is
estimated that
p
roject construction would generate a
total of approximately
258.
9 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 emissi
ons 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
17 8
.
3 2023
80.6 Total
258.
9 Amortized
8.6 3
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.
SOURCE:
Data
c
ompiled
by
Environmental
Science
Associates
in
2022
(Appendix
A
to
this
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 construction (BAAQMD, 20 22). GHG emissions from the construction phase of a project represent a very small portion of emissions over the project’s lifetime, which for the projects such as the proposed
project
would be at least 30 years.
The BAAQMD’s proposed thresholds are inste
ad 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 equipment. Large reductions in
construction emissions are difficult
to realize because there are currently no economical alternatives to diesel fuel for powering most construction equipment. Improvements in statewide regulations governing construction equipment and fuel standards drive
n 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
4.3,
Air Quality,
will help reduce GHG emissions in addition to providing air quality
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benefits.
Therefore, GHG emissions associated with
project construction would be
considered less than significant.
Appendix A contains
details on the calculations and assumptions used to estimate construction GHG emissions as well as model outputs.
Operational
The current
BAAQMD
thresholds have been set u
sing the “fair share” analysis, which
looks at how new land use development projects need to be designed and built to ensure that they will be consistent with the goal of carbon neutrality by 2045 (BAAQMD 2022) .
The existing legacy stationary source thresh
old 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 hy
drogen.
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 ar
e derived from living cells, not fossil
fuels (BAAQMD 2017b).
The system does not have any free
oxygen in its process, and instead uses steam
promoted
processes to
thermally decompose the feed
into its chemical elements. This
process does not involve any t
ype 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.
Table 4.8
-
3 shows
operational emissions calculated using C
alEEMod (version 2020.4.0)
added to the amortized
construction emissions to get the total annual project GHG emissions. BAAQMD does not currently have a quantitative threshold for GHG emissions. The current qualitative significant thresholds are found in T
able
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 2022 Scoping Plan Update in terms of followin g the
GHG reduction strategy to reach the statewide goal of climate neutrality by 2045.
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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
)
Area
<1
Energy
80.5 Mobile
2 62.6
Off
-
road
303.2
Waste
96.7 Water
17. 0
Amortized Construction Emissions
8.6 3
Total
Project GHG
Emissions
697.17
NOTES:
A 30
-
year lifetime was assumed for the
project
, which was used to amortize
construction emissions.
MTCO
2 e = metric tons of carbon dioxide equivalent
SOURC
E:
Data compiled by Environmental Science Associates. See Appendix A to
this checklist.
Based
on
the
state carbon neutrality goal for 2045, the proposed project would
contribute
its portion of what is needed to achieve the State’s climate goals and wou
ld
help to solve
the cumulative climate problem. 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 having a less than significant impact and a l ess
-
than
-
cumulatively
-
considerable climate impact. Therefore, operation of the proposed project
would
have
a
less than significant impact.
b
)
Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenh
ouse gases?
Less than Significant Impact
.
In response to AB 32 GHG reduction goals, CARB
adopted the Climate Change Scoping Plan, which outlined a framework for achieving the emission reduction goals set in the California Global Warming Solutions Act. The Scoping Plan was most recently updated in 2017 (2017 Scoping Plan; CARB, 2017) to address California’s 2030 GHG target and identifies how the State can reach the 2030 climate target established by 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 lon
ger
-
term statewide goal to reduce emissions 80 percent
below 1990 levels by 2050, as established by Executive Order B -
3 -
15 .
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The
project
would generate GHG emissions primarily from
operational
activities and
would
most likely
result in net negative emissi
ons on an annual basis. As such, the
project
would help the City achieve its long
-
term GHG emissions goal. Neither the 2017
Scoping Plan Update or the City’s existing CAP contain any actions or measures that address GHG emissions from construction. The maj
ority of electricity supplied to the
project
would
come from an onsite power generator, fueled by LFG from the Republic Services
WCCSL
.
Any additional power required
would
be supplied from an on
-
site
PG&E power drop; PG&E is required to comply with SB 100 and the RPS.
SB 100
requires that the proportion of electricity from renewable sources be 60 percent by 2030 and 100 percent renewable power by 2045.
Therefore, the
project
would be consistent
with all applicable plans, policies and regulations adopted for
the purpose of reducing
GHG emissions. This impact would be less than significant.
References
Bay Area Air Quality Management District, (BAAQMD)
2022
. Justification Report 2022.
Available online:
Microsoft Word
-
FINAL CEQA Thresholds Report for Climate Impacts
03_30_22 revisions with tracked changes (baaqmd.gov)
.
Accessed on May 11, 2022.
Bay Area Air Quality Managemen
t 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 2
016. Available online:
https://www.ci.richmond.ca.us/DocumentCenter/View/40636/CAP -
combined
. Accessed
May 11, 2022.
California Air Resources Board (CARB), 2017. Californ
ia’s 2017 Climate Change Scoping Plan.
Available
online:
https://ww2.arb.ca.gov/sites/default/files/classic/cc/scopingplan/scoping_plan_2017 .pdf
. Accesse
d on April 26, 2022.
California Natural Resources Agency (CNRA), 2009. 2009 California Climate Adaptation Strategy. Available online:
https://resources
.ca.gov/CNRALegacyFiles/docs/climate/Statewide_Adaptation_Strategy. pdf
. Accessed May 17, 2022.
Raven SR Republic Service Summary, 2021.
Carbon Life Cycle Analysis, Life Cycle
Associates, LLC.
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4.9 Hazards
and Hazardous Materials
Environmental
Issues
Potentially
Significant
Impact
Less
than
Significant
Impact
with
Mitigation
Incorporated
Less
than
Significant
Impact
No
Impact
Hazards
and Hazardous
Materials
Would
the
project:
a)
Create
a
significant hazard
to
the
public or
the
environ
ment
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
mater
ials
into
the
environment?
c)
Emit
hazardous emissions or
handle hazardous or
acutely
hazardous
materials, substances, or
waste
within
one
-
quarter
mile
of
an
existing or
proposed
school?
d)
Be
located
on
a
site
which
is
included
on
a
list
of
hazardous
materials
sites compiled
pursuant
to
Government
Code
Section 65962.5 and,
as
a
result,
would
it create
a
significant hazard
to
the
public
or
the
environment?
e)
For
a
project
located within
an
airport land use
plan
or,
where
such
a
plan
has
not been adopted,
within
two
miles
of
a
public airport or
public
use airport,
would
the
project
result in
a
safety hazard
or
excessive
noise
for
people
residing
or
working
in
the
project area?
f)
Impair
implementation
of
or
physically
interfere
with
an
adopted
emergency
response
plan
or
emergency
evacuation
plan?
g)
Expose people or
structures, either
directly or
indirectly
to a
significant
risk of
loss,
injury or
death
involving
wildland fires?
Sett
ing
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
household waste and waste from small quantity generators, such as auto repair, auto dealers, and
gas stations
, the proposed project only involves
a
variety of organic waste
feedstock
.
As discussed below
and
in Section 2.5 (
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
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organic
solids
. The project facility and operation located 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 materia ls were properly
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 previou
sly described, the project is contiguous to a closed hazardous waste landfill portion of the WCCSL operation.
Also,
the project site was formerly occupied by three leachate evaporation ponds. Groundwater contamination on
the
WCCSL site was confirmed in a J
anuary 2021
Corrective Action Groundwater Monitoring Program Report. 12 Groundwater at the WCCSL also
has reported PFAS chemicals detected in groundwater. This is considered a recognized
environmental condition (
REC
)
, but regularly monitored and the results
are submitted to the State
regulatory agency. Additionally, the groundwater impact is not expected to pose a risk of unacceptable
exposure to workers at the
project
site.
(CEC, 2022
)
Evaluation
a, b)
Create a significant hazard to the public or the enviro nment 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 en vironment?
Less than Significant Impact
.
The
proposed
operation
of
transforming blended green
waste and food
waste
into transportation
-
grade hydrogen
-
rich
synthesis
gas
(syngas)
and
charcoal
(biochar)
could result in an adverse effect 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 that the Raven SR process for the production of syngas from organic solids was not categorized as either inciner ation or
combustion and was therefore a suitable technology for use in California. 13 The conversion method uses a non
-
combustion (i.e., anoxic, indirect external heating),
low pressure process. The only chemicals added would be carbon dioxide (CO2), calcium
12 CEC, 2022.
Operation of a groundwater monitoring system and a groundwater extraction system is required under the West County La
ndfill (WCL) corrective action groundwater monitoring program (CAGMP), in accordance with
Corrective Action Enforcement Order, Docket Number 20061079 dated September 26, 2007.
13 According to the definitions listed in Section 260.10, Title 40, Code of Feder al 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 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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carbonate
(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 out solid matter from the green and food waste feedstock, which would c onsist
largely of biocarbon, along with dirt, glass, grit, rocks, and inorganic salts. The biocarbon materials are inert to the process (i.e., not gasified) and drop out in the first stage. The process also drops out excess water. Neither the biocarbon nor
the water would be
considered a hazardous material.
There would be no long
-
term hydrogen storage onsite; the material would be fed directly into the tube trucks and transported offsite.
For
transportation, the United States
Department of Transportation (
USDOT) classifies hydrogen gas as a Division 2.1
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 Administ
ration,
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 in OSHA 1910.103, Subpart H,
Hydrogen, which
includes requirements for the containers, pressure relief valves, piping, tubing, fittings, and labeling.
On
-
road transport of hydrogen gas must comply with applicable USDOT regulations, which include equipment requirements and driver safe ty 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 in the northeast corner of the site for
em
ergency use
, as required by fire department regulations
(see Figures 2
-
1 through 2
-
4).
Diesel fuel is classified as a hazardous material,
and
therefore the above ground tanks
would
require compliance with
containment
requirements in
a
Spill Prevention, Con
trol, 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
needed.
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 islands
, taking their direction from a central Human
-
Machine Interface in the control
room with centralized data collection. Process setpoints would
be bounded by high/low
alarm limitations to draw the operator’s attention to the specific problem. The control
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sys
tem 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 the
process for explosion.
As previously descr
ibed (
Section 2.5
), p
iping and vessels would be
periodically scanned with infrared equipment to identify hot spots or gas leaks that may threaten safety. If hot spots or leaks were identified, immediate steps would
be taken to
correct or mediate the condit
ion. Also, remote monitoring of the facility by Raven SR corporate provides oversight of the operation and early identification of problems as they development.
The project would comply with applicable Environmental Protection Agency (EPA) risk management
plan (RMP) and Occupational Safety and Health Administration (OSHA) process safety management (PSM) guidelines, as may be applied to the facility to ensure the safety of its operations staff and the surroundings
A maintenance program of regular
and preven
tative maintenance would be developed to maintain equipment in a reliable manner.
The project’s adherence to all regulatory requirements mentioned in this section,
combined with
the Raven RS process, materials and operations
, the impact would be less
than
significant.
c)
Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one
-
quarter mile of an existing or proposed school?
No
impact
.
As discussed above, the proposed project would not emit hazardous emissi
ons 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 hazard ous materials sites compiled
pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
No impact
.
An inactive waste disposal area
that is a
Class I Hazardous Waste
Management Facili
ty (HWMF) is located within the WCCSL and
directly north
of the
BMPC
and project
site
(see Figure 1
-
3 in Chapter 1, and Figure 2
-
0 in Chapter 2)
. The
facility was closed pursuant to State and f
ederal regulations
, and final cap construction
was completed pr
ior to 2003
. It is a totally enclosed facility with required environmental control systems.
The proposed project site is not within the
previous
HWMF area;
therefore, no impact would occur.
e)
For a project located within an airport land use plan or, where
such a plan has not
been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?
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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 occu
r.
f)
Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Less than Significant Impact
.
In
the
event
of
a
large
-
scale disaster, emergency response
to the site would
be
coordinated by
WCCSL
facility,
City and County
fire
responders
,
and in adherence to the WCCSL Emergency Response and Evaluation Plan and local agency protocols. Emergency fire control procedures are also
included in the composting
and wood waste recycling operations plans. The
WCCSL facility and project site are
accessed from and exit to Parr Boulevard, and a serious of roadways
and paths
throughout the 340
-
acre WCCSL
provide sufficient
width
for emergency access.
The
proposed project would be developed within
part of the
exist
ing BMPC property and
would not create new or interfere with existing access or egress roads.
Therefore, there is
no potential for the project to impair implementation
of
emergency evacuation
or
an
adopted
emergency response plan.
g)
Expose people or struc
tures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
Less than Significant Impact
.
The
project site
is
flat and
surrounded
by the
WCCSL
facility
, which is composed of
grass
-
covered disposal areas
of
the landfill mounds
, runoff
control ponds and lagoons, and composting areas
, and
tidal marshlands of San Pablo and
Wildcat Creek
.
Open water of San Pablo Bay is approximately 0.25 miles westward from the project site.
Wildfire hazard maps show the site as
not being within a high wildfire
hazard zone (CPUC, 2018).
Further, as discussed in criteria “a and b”, the project would
include
a
new 250,000
-
gallon integrated fire water tank and diesel engine is proposed for
emergency use
, as required by fire departme
nt regulations
.
References
California Public Utilities Commission. Fire
-
Threat Map
–
State of California. January 19, 2018.
CEC, 2022
.
Phase I Environmental Site Assessment, West Contra Cost Sanitary Landfill, 1.5 -
Acre Clean Energy Development Project, 1 P
arr 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 Coun
ty 2009.
Addendum to the
Final
EIR
for the WCCSL BMPC and Related
Actions
,
SCH. 2002102057
. 2009.
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4.10 Hydrology and Water Quality
Environmental
Issues
Potentially
Significant
Impact
Less
than
Significant
Impact
with
Mitigation
Incorporated
Less
tha
n
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)
Substantia
lly 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 in
crease 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
drainage
systems
or
provide
subst
antial
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 bodi
es
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
approximat
ely
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
4. Environmental Checklist and
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document
).
Many smal
l 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
leve
es
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 rec
ognized 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 impede sustainable groundwater man agement of the basin?
Less than Significant Impact
.
WCCSL implements a
Storm Water Pollution Prevention
Plan (SWPPP)
under the
NPDES
permit, as amended.
The drainage plan for the
WCCSL,
which
currently
encompasses the project site,
accommodate
s
the 100
-
yea
r 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 drains
, which would manage runo
ff 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 2.8,
Construction, Site Coverage and Drainage
, t
he project
would adhere to all applicab
le 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 segrega
ted and independent of one another. This
would
minimize the creation of contact water (water that has come into contact with organic
feedstock)
as well as protecting
the
site
from
various health and safety hazards.
The receiving and handling area
would
be
in a modular structure and industrial canopy to
minimize rainfall from coming in contact with the feedstock material. The receiving area would also incorporate a berm at the opening of the receiving area to keep any potential contact water inside. The apr
ons 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 will either be reabsorbed into in
coming 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 monitoring and corrective action as
needed under RWQCB review and oversight pursuant to State regulations.
Also, neither
construction nor operation of the project
would
involve use of groundwater
.
Taken
together, the proposed stormwater program and project development would not impair wat
er quality or decrease groundwater.
The impact is less than significant.
c)
Substantially alter the existing drainage pattern of
the site or area, including
through the alteration of the course of a stream or river or through the addition of impervious sur
faces, 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 runof
f 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
invo
lve minimal grading as
needed to prepare the site for new paving and foundations for the proposed modular buildings. The site is current flat and
would
remain so
, except for slight
grading
around
the proposed modular structure to prevent contact water . As
descri
b
ed in Section 2.8,
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 undisturbed.
Although the
amount
of
im
pervious 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
the system.
A draft Stormwater Contro
l 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 propose
d and its flows
would drain to an existing pump
that is
part of the
existing
stormwater
system. DMA 2
is generally the south and southwest part
of the project site
where
existing development and paved areas
exist for
truck traffic
and
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circulation;
its flow
s
would
integrate
directly
into the existing stormwater system.
The
DMA’s are delineated to effectively capture and direct runoff to not exceed the existing system.
Based on the 24
-
hour, 100
-
year storm, pre
-
development flow is estimated at
11.89 cubic feet
per second (cfs). Post
-
development is estimated at 12.47 cfs, which is
less than 5 percent
potential change.
Also, permanent source controls would
be implemented to
address potential runoff
flows,
including.
Examples include use of
equipment closures
and
regular inspection of
potential pollutant sources for debris or blockages that may interfere with intended stormwater flows.
Adherence
to the
SWPPP
under the
NPDES
permit
(see criterion “a
and b”)
would also minimize erosion as well as polluted runoff.
Ov
erall, 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. The impact is less than significant.
d)
In flood hazard, tsu
nami, 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
flow
s 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
exceed flood levels.
Therefore
, risk of inundation at the site is low, particularly due t o
risk of
a
seich
e
or flooding on the project site.
The 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 discuss
ed in criterion “a”, the proposed project would
not conflict with implementation of the existing water quality plan nor release pollutants
from
its
construction or operation.
References
State of California, 2021, Tsunami Hazard Area Map,
Contra Costa
Count
y; produced by the
California Geological Survey, the California Governor's Office of Emergency Services, and AECOM; dated
2021. Accessed and printed September 13, 2022
.
Contra Costa County 2004.
Environmental Impact Report on the West Contra County Sanita ry
Landfill Bulk Materials Processing Center and Related Actions ,
SCH. 2002102057
.
June
2004
.
4. Environmental Checklist and Evaluation
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Contra Costa County 2009.
Addendum to the
Final
EIR
for the WCCSL BMPC and Related
Actions
,
SCH. 2002102057
. 2009
.
City of Richmond, 2012.
Richmond General Plan
Update Environmental Impact Report.
SCH.
2008022018.
2012.
Power, 2022
.
Draft 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
Miti
gation
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 indu
strial and open space land uses
, including the Bay
Trail / 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 re
fuse 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 res
idential 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.
T
he
refore, the
project could not divide any established community. The project would have no impact.
b)
Cause a significant environmental impact due to a
conflict with any land use plan,
policy, or regulation adopted for the purpose of avoiding or mitigatin g an
environmental effect?
Less than Significant Impact
.
The proposed
facility and operation
to convert
blended
green waste and food waste obtained from the existing BMPC operation adjacent to the project site into renewable, transportation grade hydrogen
would not conflict with any
existing land use plan, policy or regulation intended to mitigat e
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
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compliance with every applicable General Plan policy.
Overall, the project advances
Policy EC2.2
Climate
-
Friendly Fuel Support p
roduction and distribution of climate
-
friendlier fuels (when and if any are identified) and identify appropriate locations for fuel storage and distribution (
Energy and Climate Change Element
).
This impact would be
less than significant.
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,
Liquefaction
.
2012.
City of Richmond, 2012.
Richmond General
Plan
2030:
Conservation, Natural
Resources and
Open Space Element
.
2012.
City of Richmond, 2012.
Richmond General Plan
2030
Historic Resources Element
.
2012.
City of Richmond, 2012.
Richmond General Plan
2030:
Energy and Climate Change Element
.
2012.
Cont
ra 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 Rela
ted
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
mile
s
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
Wastewater
D
istrict Treatment Plant and other industrial uses exist east of the property. The nearest residential receptors are 0.75 miles (approximately 3,949 feet) southeast from the project site.
Approximately 7
-
to 8
-
foot
-
high sound walls were installed at these r
esidences 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 ambi ent noise
environment in the
project
vicinity may be characterized by traffic noise modeling conducted for a previous EIR (City of Richmond, 2011) for primary roadways. Results of this traffic modeling are presented in
Table
4.12 -
1 and are representative o
f 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 noise b
y 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 sta
ndards 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
Q
uarter
of
2022
, and
start
-
up of the plant is projected to begin in
the Second to Third Quarter of 2023.
.
Project construction would result in temporary increase s in ambient noise levels. Onsite
construction activities would require the use of heavy construction equipment (e.g., excavator, loader, crane) that would generate varying noise levels. Offsite construction noise sources would consist of passing trucks an
d 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 t
hese 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 sensitive receptor locations.
City of
Richmond Noise
Ordinance,
9.52.110 Temporary construction activity
, limits
noise levels
measured at
SFR
-
1, SFR
-
2, SFR
-
3 Zoning Districts
(Single
-
Family
Residential)
to 75 dBA between
the hours of
7:00 a.m. to 7:00 p.m
. on weekdays.
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The operation of each piece of equipm
ent would not be constant throughout the day, as
equipment would be turned off when not in use. Over a
typical workday, the equipment
would be operated at different locations and all the equipment would not operate concurrently at the same location
within
the
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 Construction Noise Model (RCNM) and based on the t
ype of construction equipment
that are proposed to be used. To
quantify construction
-
related noise exposure that would
occur at the nearest sensitive receptors, it was assumed that the two loudest pieces of construction equipment would operate concurrently
at
the
location
within
the
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 th
e 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
ONSTRUCTION
E
QUIPMENT
N
OISE
L
EVELS
Type of
Equipmen
t
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 Prepa
ration
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 single numerical value
; L
max
= the instantaneo
us maximum noise level measured during the
measurement period of interest.
SOURCE
:
Federal Highway Administration, 2008.
FHWA Roadway Construction Noise Model, Version 1.1
, December 2008.
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In addition to on
-
site construction equipment, the
p
roject would a
lso 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 one
-
way daily hauling trips, 4 one
-
way daily v
endor 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
-
sensitive land uses. Therefore,
the
associated increa
se in short
-
term construction
vehicular noise levels would not be expected to increase noise levels in the vicinity of existing sensitive receptors beyond the levels described in Table
4.12 -
2. Operation
The Raven SR system
would
run
up to
24 hours per day,
7 days per week,
although
an
average of
1.5 days per month are planned down times
.
The primary source of noise
during
p
roject operation would be mechanical equipment associated with the Steam/CO 2 Reformation system, including heating systems, HVAC equipme nt.
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.
Additional
ly, trucks used to
distribute fuels generated on the site would be maneuvering within the parking lot of the proposed facility.
City of Richmond Noise Ordinance, Section 9.52.100, regulates operational noise levels from public property at residential area
s. Per Section 9.52.100, noise levels caused by
mechanic equipment on public property in residential areas should not result in noise levels in excess of 65 dBA measured at any boundary of a residential zone (City of Richmond, 2022). Guidelines identified
in the Richmond General Plan 2030, Action
SN4.A, proposed commercial and industrial uses that locate in an area with day -
night
average sound level (L
dn
) of 55 or greater to provide noise study reports the City’s goal for maximum outdoor noise levels in res
idential 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 increase in ambient noise levels.
I
t is not possib
le to provide specific noise levels at individual receptor locations that would result from operation of stationary sources. However, the nearest noise -
sensitive
receptor would be
approximately 0.75 miles
from the project site property line.
Table
4.12 -
3 p
resents reference noise levels for many of the
stationary
sources for
informational purposes. Given the data in Table
4.12 -
3 and the
known distance to the
nearest noise
receptors, the operational noise levels would be
substantially
below the 65
dBA standar
d 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
Leve
ls (dBA)
Noise Level at
Nearest
Receptor
Source
HVAC Equipment
72 –
78 dBA at 30
feet without
acoustical treatments
19 -
25 dBA
Trane,
Sound Data and Application
Guide
, 2002
Standby
Diesel
Generator
75 –
90 dBA at 23
feet
(size dependent) without acoustical
en
closure
19 -
34 dBA
Cummins Power Generation,
Sound Attenuated and Weather
Protective Enclosures
, 2008
Loading Dock
77 dBA at 20
feet
20 dBA
Urban Crossroads,
Moreno Valley
Walmart Noise Impact Analysis
,
2015
NOTES:
dBA = A
-
weighted decibels; ESA = Environ
mental Science Associates; HVAC = heating, ventilation and air conditioning
SOURCE: Data compiled by Environmental Science Associates in 2022. (Additional sources noted above.)
b)
Generation of excessive groundborne vibration or groundborne noise levels ?
Less than Significant Impact
.
Operations and maintenance of the
project facility
would
not include any sources of vibration that would be considered excessive. Groundborne vibration and noise associated with some construction activities, including the us e of pile
drivers, blasting, and vibratory rollers
,
can cause excessive vibration. The
project
would not
include any such activities. Groundborne vibration and noise levels generated by the types of equipment required to
prepare the site and
construct the
proposed facility
would be
minimal and would not cause human annoyance or structure damage at a distance of 25
feet
or beyond from the source (FTA, 2018). No existing historic structures that would be potentially vulnerable to vibration are located in the
immediate vicinity of the
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
warranted
.
c)
For a project located within the
vicinity of a private airstrip or an airport land use
plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise l
evels?
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
d
evelopment of noise
-
sensitive land uses that would be exposed to excessive aircraft noise. Therefore, there would be no impact.
References
California Department of Transportation (Caltrans), 2013.
Technical Noise Supplement (TeNS)
.
September 2013.
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City of
Richmond, 2012. Richmond General Plan 2030, Chapter 12, Public Safety and Noise.
April 25, 2012.
City of Richmond, 2022. Richmond Municipal Code, Article 15.04.605
-
Noise. March 16, 2022.
City of San Rafael, 2012. San Rafael General Plan 2040 & Downtown P recise Plan, Chapter 4.13,
Noise. January, 2021.
Federal Highway Administration (FHWA), 2008. FHWA Roadway Construction Noise Model, Version 1.1, December 2008.
Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment
Manua
l. September 2018. Available:
https://www.transit.dot.gov/sites/fta.dot.gov/fil
es/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
Significant
Impact
Less
than
Significant
Impact
w
ith
Mitigation
Incorporated
Less
than
Significant
Impact
No
Impact
Population
and
Housing
Would
the
project:
a)
Induce
substantial unplanned
population
growth
in
an
area,
either
directly
(for
example,
by proposing
new
homes
and
businesses) o
r
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 discus
sed in Section 4.11,
Land
Use and Planning,
in this section, the project area
entails open space and a range of
industrial
and commercial uses. No housing exists within 0.75
miles of the area, and the proposed project would be developed within existing BMP C facilities
and operations.
Evaluation
a)
Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
No
Impact
.
The proposed project does not entail new housing, roads or other infrastructure that would induce substantial growth; the new business would involve 3 to 4 new
employees per shift, for a total of 9 to12 new employees per day, which would not consti
tute substantial population growth.
There would be no impact.
b)
Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
No Impact
.
No housing or people exist on the project site. The pro ject would have no
impact.
References
None.
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4.14 Public Services
and Recreation
Environmental
Issues
Potentially
Significant
Impact
Less
than
Significant
Impact
with
Mitigation
Incorporated
Less
than
Significant
Impact
No
Impact
Public
Services
Would
the
project
result in
substantial
adverse
physical
impacts
associated
with
the provision
of
new
or
physically
altered
governmental
facilities,
need
for
new
or
physically
altered
governmental
facilities,
the
construction
of which
could cause significa
nt
environmental
impacts, in order
to
maintain
acceptable
service
ratios, response times
or
other
performance objectives
for
any
of
the
public services:
a)
Fire
protection?
b)
Police
protection?
c)
Schools?
d)
Parks?
e)
Other
public
facilities?
Recreation
a) Would the project increase the use of existing
neighborhood
and regional parks or other recreational facilities such that substantial physical deterioration of the facility
would occur or
be accelerated?
b) Does the project include recreational facilities or
require the
construction or expansion of recreational facilities, which might have an adverse physical effect on the environment?
Setting
The project area i
s currently serviced by the
Richmond
Fire Department (RFD), which also
manages the
West
County Fire District, which also serves San Pablo, El Sobrante, and unincorporated areas of
Western
Contra Costa County, including North
Richmond.
The nearest
fire stat
ion 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 water tank would
be up to 25.5 feet tall and include two pump
s, a small jockey pump for normal
circulation, and
the diesel
-
powered fire pump
(shown in Figures 2
-
1 through 2
-
4.) A
ll
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construction
-
related mitigation measures identified in this analysis would apply to that development
onsite
.
The proposed operation
wou
ld
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, including continuous monitoring
systems
,
automatic
plant ope
rations
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 involve changes
that
would increase the demand for
policy pr
otection 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 impact
.
Recreation
a)
Would the project increase the use of e
xisting neighborhood and regional parks or
other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
No Impact
.
The project
would
not
introduce new
people
onsite that would increase the
use of
recreational facilities or parks. New population would consist of up to
3 to 4
new
employees
per shift; no
customers would be onsite
.
There would be no impact
b)
Does the project include recreational facilities or require the construction or expansion of
recreational facilities, which might have an adverse physical effect on the environment?
No Impact
.
The project
would
include
new or expanded
recreational facilities or parks.
There would be no impact
.
References
City of Richmond, 2011.
General Plan 2030
–
Map 12.6 Police and Fire Services
. August
2011
.
City of Richmond, 2012.
Richmond General Plan
Update Environmental Impact Report.
SCH.
2008022018.
2012.
Google Earth Pro, Richmond Fire Stations, June 2022.
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4.15 Transportation
Environmental
Issues
Po
tentially
Significant
Impact
Less
than
Significant
Impact
with
Mitigation
Incorporated
Less
than
Significant
Impact
No
Impact
Transportation
Would
the
project:
a)
Conflict
with
a
program
plan,
ordinance
or policy
of
the
circulation system,
i
ncluding
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 fe
ature
(e.g., sharp curves
or
dangerous
intersections) or
incompatible
uses
(e.g., farm
equipment)?
d)
Result
in inadequate emergency
access?
Setting
The Richmond Parkway is a major roadway in the area that extends from
Interstate 580 ne
ar the
east approach to the Richmond
-
San Rafael Bridge northeasterly to
Interstate 80 near Hilltop
Drive.
Parr Boulevard from Richmond Parkway is the main approach to the project site within
the
WCCSL and other nearby uses
.
Evaluation
a)
Conflict with a p
rogram, 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 ge
neration
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 (PCE) ratio of 2.0 is used to convert the truck trips
to passe
nger 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.
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T
ABLE
4.15 -
1 P
ROJECT
D
AILY
T
RIP
G
ENERATION
S
U
MMARY
Use
Amount
Daily Trip Rate
Passenger Car
Equivalent (PCE)
a
Daily Trips
Employees
12 b
2.5 c
1.0 30
Trucks
25 d
2.0 e
2.0 100
Total trips (PCE)
130
NOTES:
a
A PCE of 2.0 is used for trucks because they are lager and operate slower than passenger
vehicles
b
Per the Project Applicant and described in Chapter 2,
Project Description
c
One inbound and one outbound trip per employee per day plus 0.5 trips per employee per day for other trips such as deliveries ,
running errands, etc.
d
Per the Project
Applicant and as described in Chapter 2,
Project Description
,
125
trucks would serve the site during a typical week.
This estimate assumes they
would
be evenly distributed on five weekdays
e
One inbound and one outbound trip per truck
SOURCE: Fehr & Peers
, 2022
The addition of
130
new trips on a typical weekday would not substantially increase the motor vehicle volumes on the nearby streets, including Parr Boulevard and Richmond Parkway. In addition, considering that both streets currently have high tru ck volumes
because they 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. The
p
roject would also not m
odify 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 sys
tem, including transit, roadway, bicycle, and pedestrian facilities
. The impact is
less than significant
.
b)
Would the Project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
Less than Significant
Impact
.
CEQA Guidelines
Section 15064.3, added in December
2018 and consistent with the requirements of SB 743, states that vehicle miles traveled (VMT) is the most appropriate metric to assess the environmental impacts of a project on transportation.
T
he City of Richmond adopte
d VMT
analysis
guidelines,
methodology
, and thresholds of
significance on April 6, 2021, consistent with the Contra Costa Transportation Authority (CCTA)’s adopted VMT guidelines
, which are also consistent with the State’s Office of
Planning and Research’s
(OPR)
Technical Advisory on Evaluating Transportation
Impacts in CEQA
(December 2018)
.
The City of Richmond guidelines includes
screening
criteria for development projects that meet certain criteria that can readily lead to the conclusion that they would
not cause a significant impact on VMT. The screening
criterion applicable to the
p
roject is the Small Projects criterion, which states that projects
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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 Richmond’s adopted guidelines, which are based on the CCTA Guidelines and consistent with CEQA Guidelines section
15064.3, subdivision (a) state that the VMT analysis for transportation impact purposes
can focus solely on VMT generated by
passenger vehicles
and light
-
duty trucks and not
include the VMT generated by heavy trucks
, the
p
roject VMT summarized in
Error! Not
a valid bookmark self
-
reference.
does not include
the VMT generated by trucks for the
p
roject. As shown in
Error! Not a valid boo
kmark 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 Guidelines section 15064.3, subdivision
(b)
and the impact is less than significant.
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 th
ey
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
WC
CSL
facility
, the internal circulation within WCCSL, or the public right -
of
-
way.
Passenger vehicles and trucks would continue to access the p
roject site
through
Parr
Boulevard
and Richmond Parkway
.
T
he
p
roject
is
located
in an industrial area
with high
vol
ume 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 due to a
geometric
design feature
or incompatible uses
is less
than
significant.
d)
Result in inadequate emergency access?
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Less than Significant
Impact
.
As
discussed
above, the
p
roject would
not
modify the
access point to the
existing
WCCSL
facility
,
the internal circulati
on within
WCCSL
,
or
the public right
-
of
-
way. Emergency vehicles would continue to access t
he
p
roject site
on
Parr Boulevard
.
The
p
roject
would
be designed and constructed according to the applicable fire and safety standards at the time of construction.
T
herefore, t
he
WCCSL
site would
continue to
be
accessible by fire and emergency vehicles through public streets and the internal
roadways within the WCCSL
.
Thus, the impact on emergency access is less
than
significant.
References
California State’s Office o
f Planning and Research’s (OPR)
Technical Advisory on Evaluating
Transportation Impacts in CEQA
(December 2018)
.
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4.16 Tribal Cultural Resources
Environmental
Issues
Potentially
Significant
Impact
Less
than
Significant
Impact
with
Mitigation
Incorporate
d
Less
than
Significant
Impact
No
Impact
Tribal
Cultural
Resources
Would
the
project
:
a
)
Cause a substantial adverse change in the significance
of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site,
feature, place,
cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i
)
Listed
or
eligible
for
listing
in
the
California Register
of
Historical
Resources, or
in
a
local
register
of
historical
resources
as
defined
in
Public Resources
Code Section
5020.1(k),
or
ii
)
A resource determined by the lead agency, in its
discretion and
supported by substa
ntial evidence, to
be significant
pursuant to criteria set forth in
subdivision (c)
of Public Resources Code Section
5024.1. In applying the criteria set forth in subdivision (c)
of Public Resource Code Section 5024.1, the lead
agency shall
consider the si
gnificance of the
resource to a California
Native American tribe.
Setting
ESA contacted the California State Native American Heritage Commission (NAHC) on October 20,
2021
, to request a search of the NAHC’s Sacred Lands File and a list of Native Amer ican
representatives who may have knowledge of tribal cultural resources in the project vicinity or interest in the proposed project. The NAHC replied to ESA by email on November 19, 2021
,
noting that the Sacred Lands File has no record of any sacred sites
within the project site. The
NAHC response included a list of 15 Native American representatives from 13 tribal groups who may have knowledge of tribal cultural resources in the vicinity of the project site.
On May 4, 2022, the City received a response fo
r 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 re
sources. 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 thi
s 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, after
Mitigation
.
CEQA requires the lead agency to
consider the effects of a project on tribal cultura
l resources. As defined in PRC Section
21074, tribal cultura
l resources are sites, features, places,
cultural
landscapes, sacred
places, and objects with cultural value to a California Native American tribe that are listed, or determined to be eligible for
listing, on the national, state, or local register of
historical resources.
Based on the NWIC records search and the NAHC SLF negative search results, there are no known tribal cultural resources listed or determined eligible for listing in the Californi
a
Register of Historical Resources or included in a local register of historical resources as defined in PRC Section 5020.1(k), pursuant to PRC Section 21074(a)(1), would be affected by the project. No tribal cultural resources have been identified by Nati ve
American representatives, and background research did not identify any tribal cultural resources. In addition, the City did not determine any resource that could potentially be affected by the project to be a significant tribal cultural resource pursuan t to criteria set
forth in PRC Section 5024.1(c).
In the event that cultural materials are identified during project construction activities
that
are determined to be tribal cultural resources,
implementation of
Mitigation Measure
CUL
-
1a: Cultural Resourc
es Awareness Training
,
Mitigation Measure CUL
-
1b:
Inadvertent Discovery of Cultural Materials or Tribal Cultural Resources , and
Mitigation Measure CUL
-
2: Inadvertent Discovery of Human Remains
, all
identified
above
in
Section
4.5 ,
Cultural Resources
, would
reduce potentially significant
impacts
to
less than significant.
These
mitigation
measures
would ensure that
all personnel complete
a cultural resources awareness training prior to any ground -
disturbing activity and that
work
halt
in
the vicinity of a fin
d 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
Less
than
Significant
Impact
No
Impact
Utilities
and
Service
Systems
Would
the
project:
a)
Require or
result
in
the relocation
or construction of
new or
expanded
water, wastewater
treatment
or
stormwater
drainage,
electric power, natural
gas,
or
telecommunications
facilities,
the
construction
or
relocation
of
which could cause
significant
enviro
nmental
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
exce
ss
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
Th
e
project
site, within the WCCSL BMPC, is currently served by all public utilities, including water and wastewater treatment by EBMUD and West
County Wastewater
District, respectively,
as well as the reuse of runoff water, and PG&E provides electric power,
natural gas.
Evaluation
a)
Require or result in the relocation or construction of
new or expanded water,
wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which co uld cause
significant environmental effects?
Less than Significant Impact
.
The
existing WCCSL
would
use offtake approximately
0.5 MW from the power generation for
Republic’s
onsite operation needs and the rest
would be used to power the proposed project. A
ny additional electrical power required
beyond that generated onsite would come from an existing PG&E power drop to the site.
The project
would
also involve a new
250
,000
-
gallon
integrated
fire water tank and
diesel
engine
for emergency use,
per fire regul
ations, but
would
continue to be served by RFD
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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
onsi
te, which
would
ensure any environmental effects from the
project would be less than significant.
b
)
Have sufficient water supplies available
to serve the
project and reasonably
foreseeable future development during normal, dry and multiple dry years?
Les
s 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 or
der of
60 gallons per minute
(gpm)
(81,500 gallons 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, 2022b)
.
Potab
le water is available for both domestic and fire protection to the subject property from existing major facilities (e.g., reservoirs, pumping plants), which are serviced and maintained by EBMUD. Service
would
be granted subject to compliance with the
Distr
ict’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 n
ew
water supplies for its operation to the extent that it would make future water supplies insufficient. The impact would be less than significant.
c)
Result in a determination by the wastewater
treatment provider which serves or
may serve the project tha
t 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 syste
m blowdown, along with a
small flow from the syngas wash columns. Intermittent flow is from potable sources (restrooms, sinks, etc.) and area wash down water. Wastewater would be generated from
the syngas wash columns, which can potentially contain low con cen
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 sew er.
Total
wastewater
discharge from all project processes
(or waste streams) is estimated to
be 50,200 gallons per day
, and the West County Wastewater District
would
permit this
additional use upon its determination that the discharge may be covered by the
Districts’
Pretreatment and/or Pollution Prevention programs
(Raven, 2022b)
.
Discussions are occurring
between the project applicant and the
West County Wastewater
District and
are in the permitting process.
At this time, there are no anticipated capacit
y
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
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wastewater treatment provide
r
,
would
maintain adequate
capacity
to meet its demands
w
ith 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 r
eduction goals?
Comply with federal, State, and local management
and reduction
statutes and regulations related to solid waste?
Less than Significant Impact
. The project
would
not generate
substantial
solid waste but
would convert existing organic waste in
to a reusable fuel product. Therefore, the
project
would not
conflict
with existing local or other laws or policies regarding the reduction,
reuse
and management of solid waste. The impact
would
be less than
significant
.
References
City of Richmond, 2012.
Richmond General Plan
Update Environmental Impact Report.
SCH.
2008022018.
2012.
Contra Costa County 2004.
Environmental Impact Report on the West Contra County Sanitary Landfill Bulk Materials Processing Center and Related Actions ,
SCH. 2002102057
.
June
2 004
.
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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Evaluation
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ial Study
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4.18 Wildfire
Environmental
Issues
Potentially
Significant
Impact
Less
than
Significant
Impact
with
Mitigation
Incorpo
rated
Less
than
Significant
Impact
No
Impact
Wildfire
If
located in
or
near
State
Responsibility Areas
or
lands classified
as
very
high
fire hazard
severity
zones,
would
the
project:
a)
Substantially
impair
an
adopted
emergency
response
plan
or
emergency
evacuation
plan?
b)
Due
to
slope,
prevailing
winds,
and
other
factors,
exacerbate wildfire
risks,
and thereby
expose
project
occupants
to, pollutant concentrations
from
a
wildfire
or
the
uncontrolled
spread
of
a
wildfire?
c)
Require
the
installation
or
maintenance of
associated
infrastructure
(such
as
roads,
fuel
breaks,
emergency
water
sources,
power
lines
or
other
utilities)
that
may
exacerbate
fire
risk
or
that
may
result
in
temporary
or
ongoing
impacts
to
the
en
vironment?
d)
Expose people or
structures
to
significant
risks,
including downslope
or
downstream
flooding
or
landslides,
as
a
result
of
runoff,
post
-
fire
slope
instability, or
drainage changes?
Setting
The
p
roject site borders
e
xpansi
ve
non
-
native grassland and ruderal species
in
open and that can
get very dry during
summer months. Factors that contribute to the risk of fire include dense and fire
-
prone vegetation,
poor access to fire
-
fighting equipment because of slopes or inadequate
roads, lack of adequate
water pressure and service in fire
-
prone locations, and seasonal
atmospheric conditions that result
in warm, dry fire seasons with strong afternoon winds. Wildfire hazard maps show the site as
not
being within
a high wildfire hazard
zone
(
CPUC
,
2018
).
Evaluation
a)
Substantially impair an adopted emergency
response plan or emergency evacuation
plan?
Less than Significant Impact
. As discussed under Section 4.15,
Transportation
, the
p
roject would not modify the access point to the
exi
sting
WCCSL
facility
, the internal
circulation within WCCSL, or the public right
-
of
-
way.
Therefore, the project would not
impair any existing plans for emergency response or evaluation. The impact would be less than significant.
4. Environmental Checklist and Evaluation
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b)
Due to slope, prevailing
winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
Less than Significant Impact.
Certain project characteristics
could have the p
otential 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 c
onversion 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 being served
by the RFD and the West County Fire District. The impact would be less than significant.
c)
Require the installation
or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
No
Impact.
The project s
ite is fully served by existing infrastructure that currently service the WCCSL. It would not require the installation or maintenance of additional infrastructure
that may exacerbate fire risk. The
re would be no
impact.
d)
Expose people or structures to si
gnificant 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 signi
ficant.
References
California Public Utilities Commission. Fire
-
Threat Map
–
State of California.
January 19, 2018
.
City of Richmond, 2011.
General Plan 2030
–
Map 12.6 Police and Fire Services
. August 2011.
City of Richmond, 2012.
Richmond General Plan Up
date Environmental Impact Report.
SCH.
2008022018. 2012.
4. Environmental Checklist and
Evaluation
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ial Study
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2022
4.19 Mandatory Findings of Significance
Environmental
Issues
Potentially
Significant
Impact
Less
than
Significant
Impact
with
Mitigation
Incorporated
Less
than
Significant
Impact
No
Impact
Mandatory Findings
of
Significance
a)
Does
the
project
have
the
potential
to
substantially
degrade
the
quality
of
the
environment,
substantially
reduce
the
habitat
of
a
fish
or
wildlife
species, cause
a
fish
or
wildlife
population to
drop
below
s
elf
-
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
prehistor
y?
b)
Does
the
project
have
impacts
that
are
individually
limited,
but
cumulatively
considerable?
(“Cumulatively
considerable” means
that
the
incremental
effects
of
a
project
are considerable
when
viewed
in
connection
with
the
effects
of
past
projects,
the
effects
of other
current
projects,
and
the
effects
of probable future
projects)?
c)
Does
the
project
have
environmental
effects,
which
will cause
substantial
adverse
effects
on human
beings, either
directly or
indirectly?
Findings
a)
Does the project have the potential to substantially
degrade the quality of the
environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self
-
sustaining levels, threaten
to eliminate
a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal, or eliminate important examples of the major periods of California history or prehistory?
Less than
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 reduced to
less than
significant
by requiring
surveys and
avoidance of construction
-
related work during
specific times of year:
Mitigation Measure BIO
-
1: Avoid and Minimize Impacts to Nesting Birds,
Except Rails
Mitigation Measure BIO
-
2: Avoid and Minimize Impacts to California
Black Rail and Califo
rnia Ridgway’s Rail
4. Environmental Checklist and Evaluation
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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 measures are implemented, which would reduce the potential
impacts to less than significant:
Mitigation Measure CUL
-
1a: Cultural Resources Awareness
Training
Mitigation Measure CUL
-
1b:
Inadvertent Discovery of Cultural Materials
or
Tribal Cultural Resources
Mitigation Measure CUL
-
2: Inadvertent Discove
ry of Human Remains
.
b)
Does the project have impacts that are individually
limited, but cumulatively
considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects,
the effects of other current projects, and the effects of probable future projects)?
Less than Significant Impact
, after Mitigation
.
The project does not result in a
cumulative
consideration impact for any environmental factors. One commo n 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 emi ssions
are all below the BAAQMD CEQA thresholds of significance. The BMPs also apply to all individual projects and ensure that a significant impact with respect to fugitive dust is less than significant.
Mitigation
Measure
AQ
-
1: Best
Management Practices
.
Given
the
relatively
small
scope
of
the pr
oposed pr
oject
,
its
limited
potential
impacts,
as
well as the mitigation measures
identified
in this Draft IS/MND
and listed below,
the
incremental effects
of
th
e project are
not
cumulatively
considerable
when c
onsidered
with the potential
effects
of
past, current, and probable future projects.
The
project
does
not have
any
significant cumulative
impacts
. Impacts would
be
less than significant.
c)
Does the project have environmental effects, which
will cause s
ubstantial adverse
effects on human beings, either directly or indirectly?
Less than Significant Impact
, after Mitigation
.
All
impacts identified
in
this Draft
IS/MND are either less than significant after
implementation of identified mitigation
measures (
all listed above),
or
less than significant
without the need for
mitigation.
Of
those impacts, 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
b
eings, directly or indirectly.
As discussed under finding “b” above,
the project’s
implementation of
Mitigation Measure AQ
-
1: Best Management Practices
,
would
reduce the impact
to
less
than significant.
5 . Document Preparers
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5. Document
Preparers
5.1 CEQA Consultant
ESA
180 Grand A
venue
–
Suite 1050
Oakland, CA 94612
Phone 510.839.5066
Project Director
Crescentia Brown
Project Manager
Tim Sturtz
Air Quality/GHG
Chris Easter,
Director
Air Quality
/
GHG
Tim Sturtz, Principal
Madison Castelazo, Analyst
Energy
Bailey Setzler,
Planner
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
Se
nior 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
Raven SR Bioenergy Project
A
-
1 ESA
/
D202100382
Initial Study
October 7,
2022
APPENDIX
A
Emissions Data, Assumptions and Modeling Files
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This page is intentionally blank.
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