Richmond City Council
May 16, 2023

1 March 21, 2023
Lina Velasco
Community Development Director
City of Richmond
Re: Raven SR Bioenergy Project (PLN21-282)
Dear Lina:

Thank you for advising Raven SR regarding the status of our application for the Raven SR Bioenergy Project (PLN21-282) (Raven Project) and confirming that the 90-day continuance was granted to address the comments raised in the appeal of the Raven Project Conditional Use Permit (CUP) and the October 7, 2022 Initial Study/ Mitigated Negative Declaration (October IS/MND). We received notice on March 9, 2023 that the City released the Raven Project Updated IS/MND for public review and comment. We understand that the new hearing date is tentatively scheduled for the May 2, 2023 City Council meeting.

You asked that we provide the following documents for the City’s consideration regarding the Raven Project:
Raven’s response to the Appeal of the City Planning Commission Decision to Adopt Initial Study/Mitigated Negative Declaration (IS/MND) for the Raven SR Bioenergy Project (PLN21-282) filed by Communities for a Better Environment (CBE) and Natural Resources Defense Council (NRDC) on December 19, 2022 (Appeal); and A Health Risk Assessment (HRA) for review by the City’s CEQA consultant, ESA.

In reviewing the Appeal, it occurred to us that there may be some confusion about the proposed Raven Project and the information contained in the October 2022 draft IS/MND. The Raven SR team prepared responses to the questions raised in the Appeal in order to address CBE and NRDC’s comments and concerns in a more robust manner. We agree with CBE and NRDC that the IS/MND would benefit from further clarifications and amplifications regarding the project description, as well as the available technical information and analyses. Much of this information was already generated as part of our air permit application, so we asked our consultants to compile this information for the City’s use.

With this in mind, we have enclosed following updated description for the Raven Project that includes further details about the operational aspects of the Raven SR technology (see Attachment A). The updated project description also includes information Raven has compiled as part of its permitting process that describes safety protocols, standards and management plans in response to the Appeal. Based on the updated project description information and technical analyses our technical team completed, we also prepared a redlined version of the October 2022 2 Draft IS/MND for the Planning Department and ESA’s use to identify the corresponding sections of the IS/MND that the Raven team believed would benefit from further clarification and the updated project information. We submitted the redlined version of the Draft IS/MND on February 22, 2023 reflecting our changes to correspond to the clarifications contained in the attached updated project description. Additionally, the updated project description and the information we submitted to the City on February 22, 2023 answers some of CBE and NRDC’s questions about the Raven Project.

We appreciate CBE and NRDC bringing their concerns to the City’s attention. Raven is committed to sharing information about its Project in a transparent manner and believes that the proposed Raven SR technology will result in environmental and economic benefits for the Richmond community, while supporting the State’s efforts to increase the production of low- carbon fuels. Raven SR looks forward to working many years in the City of Richmond, reducing waste and providing clean fuels for the region, and wants to be a good neighbor to the residents of the community.

Thank you for your consideration.

Regards,
Mike Fatigati
Raven SR
Chief Technology Officer
cc: Lydia Elias
Shannon Chaffin
Matt Murdock
John Scanlon
1 Raven SR Responses to Appeal
Raven SR reviewed CBE and NRDC’s Appeal filed against the City of Richmond (City) Planning Commission’s approval of the Raven One Project. The Raven One Project proposes to convert a blend of urban green waste and organic food waste into hydrogen. CBE and NRDC expressed their concerns about the City’s analysis of the Raven One Project and noted that the City’s analysis in the initial study (IS)/mitigated negative declaration (MND) is governed by the “fair argument” standard. We acknowledge that the fair argument standard applies to a lead agency’s preparation and adoption of an IS/MND. Raven SR believes that the additional clarifying information about our project included with this submittal will assist in informing the City’s further review of the Raven One Project and allay the concerns of the Appellants.

Before addressing CBE and NRDC’s Appeal, first we would like to provide some background about Raven SR’s technology and provide clarifying information about our Project. Following this discussion, we have prepared a guide for the City staff and decisionmakers, and the Appellants to use to find answers to their questions in the Updated IS /MND and the technical appendices. We also have provided some updated information in response to the outdated data used by the Appellants in their Appeal.

Raven One Project Objectives
Raven SR believes its Project is aligned with California’s goals for a transition to a hydrogen fuel infrastructure. Our Project results in the production of hydrogen from waste materials with lower power demand and lower demand of fresh water when compared to other, more traditional means of producing hydrogen, and it does so at a negative carbon intensity (CI) score. A transition from fossil fuels to renewable hydrogen fuel will greatly reduce GHG impacts, and reduce air pollution in the nearby community. The benefits that will accrue to the community that hosts the Project include reduced air pollution from reduced flaring of LFG, from displacement of fossil-fueled heavy-duty trucks, and from avoided landfill emissions.

Reduction in Pollution and Greenhouse Emissions
Landfills are the third largest source of methane in both California and the US. California Senate Bill (SB) 1383 requires 75 percent of all organic waste to be diverted from landfills by 2025.

Diversion of organic waste by the Raven One process will eliminate up to 34,000 metric tons of mixed green and food waste from the WCCSL landfill each year. This will also potentially avoid emissions of 7,200 metric tons of methane per year from organic waste in the landfill. The hydrogen that Raven will produce also will displace diesel truck engines that are major producers of toxic emissions and particulates, not to mention light-duty vehicles. For example, if Raven produces 2,342,000 kgs of H2 and 50% is for heavy-duty vehicles and 50% is light-duty vehicles, then the avoided emissions from vehicles alone represents a significant reduction. 2 Importantly, Raven will also replace highly polluting generation sets and flaring that today, contribute to significant pollution in the Richmond area.

And all of this locally produced and regionally used.

Hydrogen
The use of low-carbon hydrogen is a cornerstone of California’s transition away from fossil fuels. Nearly all of the hydrogen currently produced and used in California is manufactured from fossil fuels. The Raven One Project is designed to produce hydrogen from the conversion of green waste and food waste obtained from the co-located WCCSL, using technology that will use demonstrably less electricity per mass unit of hydrogen produced than electrolysis, and with a lower carbon footprint. No other biofuel, liquid or gaseous, will be produced at the Richmond Project site. The renewable hydrogen will initially be used as transportation fuel for light-, medium-, and heavy-duty vehicles powered by fuel cells. Other potential uses of low-carbon hydrogen include replacements for fossil-based natural gas and the manufacturing of green electro fuels, all designed to reduce California’s carbon footprint.

Hydrogen fuel cell electric vehicles (FCEVs) are an enabling technology required for (1) achieving Governor Newsom’s target of 5 million zero-emission vehicles on the road in California by 2030; (2) meeting environmental goals directed toward removing the emissions of carbon and criteria pollutants from the transportation sector; (3) retaining the range, fueling time, and scalability (for example, light-, medium-, and heavy-duty vehicles) to which the public is accustomed; and (4) succeeding in achieving fuel independence.

To keep pace with the expanding FCEV population and fueling capacity, the supply of renewable hydrogen must expand rapidly. The renewable hydrogen market in California is still in the early stages of development. No fully dedicated renewable hydrogen production plants are operating anywhere in the state. Reformed biomethane from anaerobic digestions using existing steam methane reformation (SMR) capacity is the dominant supply approach.

Raven’s hydrogen production process has several advantages over other methods such as SMR and even over other green methods, such as electrolysis. First, it uses less electricity per kilogram of hydrogen than electrolysis. Second, it disposes of waste that would otherwise be a persistent environmental problem. Third, it produces hydrogen close to where it will be used.

A goal of the Raven Project is to reduce emissions from the co-located 1980’s vintage Waukesha (3 x Model 7042 GL) landfill gas generators currently located on the WCCSL site. These obsolete, aging, highly polluting generators would be removed from the site and replaced with new, low pollution Jenbacher engines (3 x JGS 420 GS-L.LC), equipped with the best available

3 air emissions control technology. This replacement will contribute to improvements in air quality for the Richmond community.

California policy calling for a 80% reduction in CO2 emissions from the 1990 level by 2050 will create new demand for low to zero-carbon hydrogen and necessitate a shift in current demand from fossil-derived hydrogen to low-carbon hydrogen. Hydrogen transportation fuel produced from biomass such as green waste and food waste, in the case of Raven SR’s Project, is a low-carbon fuel from renewable feedstock. Diversion of this organic waste will help fulfill the legislative mandates of California Senate Bill 1383 to significantly reduce short-lived climate pollutants such as methane by converting methane producing organic wastes to hydrogen.

With this background in mind, the following addresses the specific issues raised in the Appeal.

References in the headings below to sections refer to the corresponding sections identified in the Appeal. Our responses to the comments in the Appeal refer to specific page numbers and section references from the March 9, 2022, Updated IS/MND.

Section III.A.i. Significant Information Regarding Air Quality is Missing From The Record, Which the City Should Review Before Issuing a CEQA Determination The Raven Project represents a first-of-a-kind use of renewable feedstocks with a novel technology to produce a next generation fuel for transportation. The Project configuration is quite different from those previously studied and evaluated by regulatory agencies. For that reason, we believed it was important to establish a line of communication with engineers at BAAQMD for the purpose of consultation going forward.

Having initiated discussions with the appropriate team at BAAQMD, we were immediately informed of the need to first file an air permit application and pay the associated fee, after which we could engage the BAAQMD team in discussions regarding process, evaluation of alternate project configurations, and other concerns and implications raised concerning the location of the Project within a community newly designated as “overburdened.” Raven SR filed a preliminary application, in order to commence discussions with the BAAQMD.

BAAQMD published notice of the preliminary application as required, thus notifying the region of the Raven Project and supporting a process by which BAAQMD could develop their understanding of the project. Following BAAQMD’s initial review of data from the preliminary application, Raven SR received the anticipated ‘letter of incomplete’ from the District, which established a platform for Raven engineers and BAAQMD engineers to intelligently and diligently discuss and adhere to the requirements for the project.

Since that initial filing, Raven SR engineers and consultants have continued to work with BAAQMD to answer their questions regarding the expected emissions profile of the Raven Project. The configuration of the project has certainly evolved from its conception in response to concerns about the safety and welfare of the community. The data presented to the BAAQMD since the preliminary filing has been developed by working closely with our engineering team and with equipment suppliers for selection of best-in-class equipment. The Updated Air Quality and Greenhouse Gas Assessment Technical Memo and Updated Air Quality and New Health 4 Risk Assessment Technical Memo attached as Appendix A to the City’s March 2022 Updated IS/MND is based on the information Raven submitted to the BAAQMD as part of the processing of its authority to construct permit.

Section III.A.ii. There is Substantial Evidence of a Fair Argument that the Project Will Have a Significant Health Risk Impact from its Air Quality Impacts Upon becoming aware of the Appellant’s concerns, Raven SR immediately commissioned Ramboll to undertake a Health Risk Assessment (HRA) utilizing the same protocols used by BAAQMD. The Updated Air Quality and Greenhouse Gas Assessment Technical Memo and Updated Air Quality and New Health Risk Assessment Technical Memo attached as Appendix A to the City’s March 2022 Updated IS/MND contains the HRA requested by the Appellants. The HRA determined that the Raven Project would not result in a significant impact, and does not exceed the risk threshold allotted to “overburdened” communities.

Appellants expressed concern that emissions of criteria pollutants from the Raven Project, while below the threshold for mitigation, is not sufficiently low, suggesting that the adopted threshold limits should not apply. As a result of this opportunity to review the data, Ramboll, the expert consultants retained by Raven SR, determined that the Project had erred in double-counting some of the emissions from point sources, with the result that the Project is even less impactful than was first discussed in the City’s October IS/MND.

Raven SR cannot account for the emissions data attributed to LFG engines as outlined in this section of the Appellant’s comments and would instead refer Appellants to the information supplied to BAAQMD for selected equipment that includes Selective Catalytic Reduction (SCR) and an oxidative catalyst for VOC destruction – equipment that improves upon the dated and ineffective equipment now in operation at WCCSL.

As demonstrated in Section 4.3 of the March 2023 Updated IS/MND and Appendix B, the Project’s air quality and health risk impacts would all be below levels of significance and the Project would not result in a significant impact.

Section III.A.iii. The City Failed to Rebut the Substantial Evidence for a Fair Argument that The Project Will Have a Significant Health Risk Impact from its Air Quality Impacts As part of the HRA commissioned by Raven SR (see Attachment B of this document and Appendix A of the City’s March 2023 Updated IS/MND), dispersion models of the immediate area of potential impact by the Raven Project were developed in accordance with methodology used by BAAQMD and studied, with a focus on nearby receptors as identified by the Appellants in their Appeal. The results of the HRA confirmed the earlier findings of Ramboll and ESA as set forth in the October 2022 IS/MND assessment of no significant impact.–the Project’s potential impacts during its Construction and Operation phases are below thresholds of significance for impacts on overburdened communities, and as the City determined in the October 2022 IS/MND, the City similarly found in the March 2023 Updated IS/MND that the Project will not result in a significant health risk impact or air quality impacts to any sensitive receptors. Substantial evidence contained in Appendix B to the Updated IS/MND demonstrates 5 that the Project would result in less than significant air quality, greenhouse gas emissions and health risk impacts.

Raven SR reviewed the various sources and characteristics of the Project emissions during its Construction and Operation phases. In conducting the review, our team realized that we had erred in our calculations by a duplication of emissions in our accounting. This has been corrected with a net result that the emissions profile of the project has been further reduced.

The proposed Project would not result in a Significant Health Risk Impact.

Section III.A.iv. Insufficient Public Outreach
Raven SR has presented at more than 15 group meetings and is continuing to expand its outreach efforts to neighborhood groups and organizations in the Richmond community. Raven SR held an open house for the community on March 8 and continues to work with several community leaders to ensure its outreach is touching key areas. Various community groups participating in Raven SR’s briefings include: NRDC, West County Mayors, Council on Industry, Communities For A Better Environment, Urban Tilth, Richmond Future Coalition Sierra Club, Richmond Our Power Coalition, North Richmond Advisory Committee, West Water District Joint Powers Agency, Asian Pacific Environmental Network, West County Sierra Club, City of Hercules, Richmond Neighborhood Coordinating Council, El Cerrito Rotary Club, Richmond Rotary Club, Council on Industry/Richmond Chamber of Commerce Breakfast, Iron Triangle Neighborhood, Senator Nancy Skinner’s office, Assemblywoman Buffy Wicks’ office, Congressman John Garamendi’s office, Richmond Planning Commissioners, Councilman Cesar Zepada, Supervisor John Gioia, Councilwoman Gayle McLaughlin, and Councilwoman Claudia Jimenez.

Section III.B. Cumulative Impacts
Appellants suggest that Raven SR speculates about the potential and cumulative pollution impacts resulting from two other hydrogen projects in the Richmond area. Raven SR notes the following:

1. Raven SR is the project applicant for the Raven One Project. Our project is located within the existing landfill that was subject to a prior environmental impact report and an analysis of cumulative impacts at that time. Our project is not related to other hydrogen efforts that the Appellants indicated may be under consideration for the Richmond area.

We have attempted to identify the other projects referred to by the Appellants. We believe that one of the references may be to a possible concept at the Chevron Richmond refinery to produce additional hydrogen from their existing reactors. To our knowledge, Chevron may have discussed this concept with the City but there was no record of an application for any approvals. We have not been able to identify a second project; nor is it identified by the Appellants.

2.Appellants seem to misunderstand the facts regarding the additional traffic that may be generated by the Raven Project. Appellants suggest that the project will lead to an additional 100 trips per day by “heavy-duty trucks”. The Appellants seem to be confused 6 about the number of actual project-generated truck trips. Section 2.8 of the Updated IS/MND accounts for the presence of 25 heavy-duty trucks that will be associated with the project. However, for the purposes of comparison, the study then converts those truck trips into “passenger car equivalents” by first multiplying the number of trucks by two, accounting for their round trips to the site. That figure is then again multiplied by a factor of another two (arriving at 100 passenger car equivalents; 25 x 2 x 2) to conform with accepted practice in assessing vehicular pollution impacts. Thus, the actual number of truck trips is 25, not 100.

Section III.C. Hazards and Safety
Appellants believe that the October 2022 IS/MND was vague in describing an intent to comply with various health, hazard, and process safety management regulations. In the IS/MND, the Raven Project was described as being subject to various local, state, and federal programs governing the health and safety of workers in industry. Section 2.6 of the March 2023 Updated IS/MND also referred to Raven SR’s intended compliance with the OSHA Process Safety Management (29 CFR 1910.119) and the EPA Risk Management Program (Section 112(r) of the Clean Air Act), commonly referred to as PSM/RMP. These programs provide a process for safety, mechanical reliability and operator involvement. PSM/RMP is mandatory for systems that exceed a threshold of 10,000 pounds of flammable material. The Raven Project will NOT exceed this threshold but will voluntarily comply with the program requirements. Various other programs administered at the state and local levels require documentation and reporting (with periodic audit of the site and updating of requisite documentation) for processes associated with the project’s operations and maintenance. Though Appellants raise the question of “how much” description of intent to comply is sufficient to allay concerns, Raven SR appreciates the opportunity to revise and expand upon its intent to comply with an amplified discussion within the revised IS/MND of those programs under which is it legally compelled to operate.

Appellants seem to suggest that Raven SR must implement mitigation measures beyond those that have been anticipated by experts in process engineering and plant operations in the conduct of the design of the Raven Project. Those experts were retained primarily for their experience base and their facility with and understanding of governing standards for civil (including environmental and traffic), mechanical, and chemical engineering practices. Team consultants were selected for their expertise in the characterization and evaluation of best practices regarding the mitigation of pollutants, health risks, and plant operations. The construction arm of the Raven SR team was selected in part for their demonstrated exemplary record of on-the-job safety as well as cost and schedule management. Raven’s team of recognized experts have undertaken standard, reasonable efforts and best management practices to mitigate foreseeable risks and to incorporate standard best management practices into the Project design and operation.

Appellants identify hazards presented by the production and transport of hydrogen. Raven SR is not the first to have produced hydrogen, nor are its off-takers the first to transport hydrogen. The standards and practices for engineering, design, and operation that are and will be utilized, with ever improving sensors and instrumentation for process control, reasonably demonstrate the intent and capability of Raven SR and its project team to minimize and mitigate risk as explained in Section 2.6 of the Updated IS/MND.
7 For example, the plant itself is open to the air. Any inadvertent leakage of hydrogen, which is 14 times lighter than air, will quickly disperse. Opportunities for containment of hydrogen in sufficient amounts to risk an on-site explosion are negligible. Tube trailers used for the transport of the hydrogen product have been engineered and produced with great attention to safety, programs for which are administered by the US DOT.

Appellants quote from a notable paper on the impact of hydrogen released into the atmosphere and its contribution to potentiating the impact of other greenhouse gases. A review of that paper reveals the author’s conclusions that the hypothetical reactions and mechanisms presented therein are not proven, but instead are only offered with a “high level of uncertainty” as topics for further research. In our own research, we uncovered claims in a publication1 suggesting that replacement of the entire global fossil fuel infrastructure with hydrogen, and with a leakage rate of 1% (average for the global system), would result in greenhouse gas impacts 0.6% lower than the current system. In mentioning this reference, it is Raven SR’s intention to acknowledge that, like all science, the science of climate change is evolving as new information is made available.

It is our belief based on extensive scientific research, however, that a transition to renewable fuels like hydrogen, is, on the whole, beneficial to the environment and to society.

Section III.D. Project Description
Raven SR appreciates the opportunity to further refine and clarify the Project Description for the City’s use as set forth in Section 2 of the March 2023 Updated IS/MND. We are optimistic about the benefits to the City of Richmond by our novel technological approach of converting urban green wastes and organics to hydrogen for the transition from fossil fuels, including increasing diversity of options for waste utilization, reduced emissions, and local jobs. We have attached our updated project description clarifying information to this letter to assist the Appellants in their review of our Project.

Appellants ask about the future energy supply to the Raven Project in the event that the LFG supply is exhausted. Raven SR believes this question to be largely speculative, but also observes that it is the goal of the State of California (and PG&E) to be 100% reliant on renewable power within the same 15-20 year timeframe suggested by Appellants. Thus, one can reasonably speculate that the project will continue to utilize 100% renewable power in any configuration of the state’s future power portfolio.

Section III.E. Additional Concerns
The condition of the groundwater at the site has been at the center of attention for Republic Services and WCCSL as stewards of an old, closed landfill. A review of recent results from groundwater monitoring stations in the vicinity of the plot identified for the Raven Project show little to no evidence of the incursion of leachate from the landfill. The results of the Geotechnical survey conducted on behalf of Raven SR did not result in detection of groundwater or waste 1Derwent, Richard & Simmonds, Peter & O'Doherty, Simon & Manning, Alistair & Collins, William & Stevenson, David (2006). Global environmental impacts of the hydrogen economy. Int. J. Nuclear Hydrogen Production and Application Int. J. Nuclear Hydrogen Production and Application. 1. 57-67. 10.1504/IJNHPA.2006.009869. 8 materials to a level of 150 feet. This survey was done to measure the load carrying capability of the soil mix and out of a concern that pilings might have been required to support the anticipated loads. The result of the study is that construction may proceed using concrete slabs varying in thickness to 18 inches, sufficient for load carrying. No digging or excavation beyond 6 feet of depth is anticipated for the necessary installation of pipes for wastewater and freshwater conveyance for the Raven Project. The City of Richmond included this information in the March 2023 Updated IS/MND and further documented that the proposed Project will not result in a significant hazardous materials impact.

Raven SR has directed that the groundwater under the available plot provided by Republic be sampled to establish a baseline to be used against future sampling.

Raven SR has confirmed with soil experts and subsequently directed that additional provisions be taken for the safety of construction labor to install impermeable vapor barriers under the concrete slabs to contain and prevent any migration to the surface of soil VOCs that may be present.

Raven provided the information above, and the technical studies included in the City’s Updated IS/MND to further clarify and amplify the Project construction and operation and address the comments raised by Appellants. The robust technical information we have provided for the City’s use in the Updated IS/MND demonstrates the Raven Project would not result in any significant impacts that cannot otherwise be mitigated to a less than significant level. Raven is committed to implementing best management practices for the safety of the community and our employees during the construction and operation of the Raven One Project.

ATTACHMENT A
9 Raven SR, Inc.

Project Description: Richmond S-1
Introduction:

Raven SR will be constructing and operating one of its Steam/CO2 Reformation systems at the West Contra Costa Sanitary Landfill ("WCCSL") in Richmond, CA to convert up to 99.9 wet-tons per day (WTPD) of blended green waste and food waste into renewable, transportation grade hydrogen. The WCCSL is operated by Republic Services.

In 1993, the California Environmental Protection Agency’s Department of Toxic Substances Control determined that the Raven process for the production of synthesis gas (i.e., “syngas”) from biomass and other carbonaceous solids was not categorized as either incineration or combustion according to the definitions listed in Section 260.10, Title 40, Code of Federal Regulations (40 CFR) and Section 66260.10, Title 22, California Code of Regulations (22 CCR) and was therefore a suitable technology for use in California. Since 2017, a Raven pilot engineering unit, sized at 100 wet pounds per day of feedstock, has been operating at the UC Berkeley’s Richmond Field Station and is permitted for operation by the Bay Area Air Quality Management District (BAAQMD) under permit Nos. 23993 and 23320.

Summary of Technology:

Raven SR’s patented, Steam/CO2 Reformation technology can convert a wide variety of carbonaceous (organic) feedstocks into a hydrogen-rich synthesis gas (syngas). The technology is strictly non-combustion (i.e., anoxic, indirect heating), low pressure, and catalyst-free 1 process transforming carbonaceous feedstocks into a hydrogen-rich synthesis gas. 2 The synthesis gas can be converted to downstream renewable energy products such as transportation-grade hydrogen and nitrogen-free Fischer-Tropsch (FT) liquid fuels, methanol, olefins, as well as electricity derived from fuel cells or turbines and/or internal combustion engine generator sets. Raven SR’s patented technology offers a variety of feedstock options and a menu of output alternatives.

The Raven SR system is designed to be modular with a small footprint and recycles waste heat to increase process efficiency. Apart from the advantage of physically reducing organic waste into clean fuels, the Raven SR system has low-air emissions and sequesters solid carbon in a useful and salable byproduct (biocarbon), in quantities usually around 15-20% of total feedstock input dry volume. The sterile3 biochar is composed of many elements within the organic waste feedstock (dirt, glass, grit, rocks, inorganic salts, etc.) that are inert to the process, not gasified, and drop out in the first-stage, avoiding slag and tars. The biocarbon is a saleable product that can be used for fertilizer, filler for concrete etc. 2 Carbonaceous feedstocks include biomass, biogas, municipal solid waste, bio-solids, industrial waste, sewage, medical waste, etc.
3 Following thermal treatment by the first stage reformer, biological pathogens (if any) are destroyed by elevated temperature and residence time of ~45 minutes.

ATTACHMENT A
10 3 Stage Process:

There are three stages of the process (see Figure 1 below). To convert the organic waste feedstock into hydrogen, the process begins with an externally-heated, sealed rotary reformer which turns feedstock into a raw syngas which is then “polished” using a second steam reformer making a hydrogen-rich syngas (55-63% H 2). From there the syngas may be processed through an industry standard water gas shift reactor (WGS) and a pressure swing absorption (PSA) unit producing transportation-grade hydrogen. If the desired output is synthetic fuels (diesel, jet, etc.) instead, the process would use FT vessels (forming long chain hydrocarbons through an exothermic, catalytic process) in place of the hydrogen unit.

Figure 1 – Simplified Schematic of the Raven SR Process Feedstock Input:

Solid feedstock is best processed when wet and after being pre-sorted to reclaim any valuable metals and recyclables. The solid feedstock is 1-2” diameter so that it can be manipulated by the rotary reformer.

Ideally, the feedstock will have a moisture content between 40-55%. Feedstock with excess moisture can be treated with a dewatering screw, while steam can be added if the moisture content is too low. No combustion. The Raven SR system does not have any free-oxygen in its process (see Section 260.10, Title 40, Code of Federal Regulations (40 CFR) and Section 66260.10, Title 22, California Code of Regulations (22 CCR)). Instead, it uses a chemical process provoked by steam to break down waste into its base chemical elements. This process has two key benefits: by not burning the feedstock, it converts more of the waste feedstock into fuel and there are no typical or hazardous combustion emissions (i.e., particulate matter, oxides of nitrogen and sulfur, dioxins and dibenzofuran) from the conversion system.
Flexible inputs. Raven SR systems can convert multiple types of biomass, solid waste, landfill gas, wastewater, or a combination of these, and can switch between them.

ATTACHMENT A
11 Highest safety standards. Raven SR units are equipped with continuous monitoring systems and can automatically shut down plant operations without human intervention. The project will comply with applicable RMP/PSM guidelines.

Description of operations:

The Raven facility will receive up to 99.9 WTPD of blended green waste and food waste feedstock to produce up to 4,800 kg of hydrogen per day. Along with hydrogen, about 20 tons per day of biocarbon is produced from the system. The system is electrically heated and, with balance of plant loads, consumes about 5 MW of electricity.

The solid feedstock from the WCCSL is taken from existing on-site grinding operations and will be trucked approximately 2,500 feet from the existing landfill facility footprint by WCCSL’s existing equipment to Raven SR’s solids handling system which will prepare the feedstock for thermal processing. All Raven SR’s materials handling systems will be located inside a building. The rest of the facility will also be underneath an industrial metal canopy with partial drop-down walls. This system mixes the feed with granular lime which is fed directly into the systems first stage reformer (SR1) through a lock hopper which prevents the incursion of air with the feed. SR1 heats the material in a reducing environment (i.e., anoxic), thermally decomposing the organic compounds, converting a portion of the feedstock into syngas. While the residual biocarbon is collected as it comes out at the end of SR1 process, the “raw” syngas exits for further processing – all fully contained. All inerts like rocks, glass, grit, sand, and other inerts that was in the feed will be collected with the biocarbon. At this point, the syngas will go into the second stage reformer (SR2).

SR2 converts the remaining methane and other remaining hydrocarbons into syngas. The resulting gas is mostly hydrogen, carbon monoxide, carbon dioxide and water. The syngas then goes through a complete polishing to remove impurities such as particulates, H 2S, HCl, or HCN. The syngas moves into a water gas shift reactor (WGS) converting CO to H 2, and finally into a pressure swing adsorption (PSA) unit to purify the hydrogen product. The remaining tail gas, containing residual hydrogen and CO2, from the PSA are sent to the power generation engines. The hydrogen product is compressed for short term storage before being exported via truck- mounted tube trailers for delivery to facilities using hydrogen for transportation or processes needing green hydrogen.

Upon startup, the plant will consume approximately 5 MWe to operate and produce 200 kg/hr of hydrogen. The majority of this power will come from onsite power generation using newly installed Jenbacher engine generator sets (these engines will replace existing, inefficient engines). The fuel to be used for the generation is the landfill gas (LFG) from Republic Services landfill, combined with the tail gas from the PSA. Approximately 2.2 MW will be generated from the LFG, and 0.5 MW from the tail gas produced in the conversion process. The energy value of the tail gas comes from the unrecovered residual of hydrogen from the PSA. Republic Services will offtake approximately 0.5 MW from the power generation for their onsite operation needs and the rest will be used to power the hydrogen plant. The additional electrical power required beyond that generated onsite will come from an existing PG&E power drop to the site.

Some key points:

ATTACHMENT A
12 Run Time: The system is designed to run 24/7 with 1.5 days per month allotted for scheduled maintenance, this is an average across a quarter. This is approximately 8,300 hours of operation per year. The system is design for continuous operation without many start-ups or shut-downs. Fugitive Emissions: The system is a closed process from the first-stage reformer to the PSA.

Mechanical seals prevent fugitive emission from the first-stage reformer which operates under pressure that is only slightly above atmospheric. The unit will be shielded from sun and rain with a canopy that will also serve as the suction for thermal oxidation of waste gases. Any fugitives from the vessel will be accumulated and sent to the thermal oxidizer for destruction; continuous monitoring systems for criteria pollutants will be incorporated. Odor Control: Odor control will be in place to minimize possible odors. A canopy will be placed over the feedstock tip floor and infeed equipment to the process to prevent stormwater contact. The canopy will collect air from the feedstock management area and use that air as primary air for downstream control of emissions.
Only Hydrogen: While Raven SR can produce synthetic liquid fuels, the Richmond location is only going to produce transportation grade hydrogen due to the interest of the local and regional markets for non-fossil fuel based hydrogen.
Hydrogen Export Panel: The produced hydrogen will be onboarded by Shell designed hydrogen gas export panel incorporating best-practice Health, Safety, Security and Environment (HSSE) and compliant with industry standards for handling hydrogen. Truck volumes: Approximately 28 hydrogen tube trucks and 7 biocarbon trucks (total 35) per week with an average trip of 40 miles. There will be no additional WCCSL traffic as the Raven system will only use feedstock from ongoing onsite WCCSL operations. Vehicular Circulation: Presently no changes are being proposed or required to vehicular circulation entering or exiting the project site.
Tube-truck idle time: No more than 5 minutes once at project site (as required per state regulations)
Standard throughput: The current plan has the same throughput over time, but because the system is modular its capacity could be increased in the future. Employees: Raven will be employing approximately 3-4 employees per shift for the operation of the Raven facility. Raven will be hiring 9-12 new employees exclusively for this project to cover all shifts and provide necessary support the facility.

Timing:

Raven SR anticipates breaking ground for the Richmond facility in Q3 2022. It is expected to launch production in early Q1 of 2023.

Principal Environmental Permits Required:

The City of Richmond has determined that the proposed Raven system at the WCCSL will require a conditional use permit (CUP) and will the Lead Agency for the CEQA environmental review process. The Bay Area Air Quality Management District will need to issue an Authority to Construct (ATC) for the air

ATTACHMENT A
13 pollutant emissions of the project. A solid waste Transfer and Processing permit will be required from the CA Department of Resource Recovery and Recycling (CalRecycle). Raven has submitted the necessary CUP application to the City of Richmond and is preparing the necessary application forms and supporting information for the ATC and CalRecycle permits.

Other permits such as Storm Water permits from the CA Water Resources Control Board and hazardous materials and waste generation permitting by Contra Costa County Health Services will also be required for the project.

The CEQA document will address the above agencies’ permitting needs as the permits all require discretionary decision making by the respective agency.

Primary Project Site Layout
A rendering of the Richmond site, without the protective canopy, is shown below, which is approximately

1.5 acres:

ATTACHMENT A
14 ATTACHMENT B
15 Health Risk Assessment (Ramboll)
HRA Tables.pdf
Construction Subphase1 Start Date End Date Year Number of Work Days Days per Week
Demolition 7/17/2023 7/21/2023 2023 5 5
Site Preparation 7/24/2023 9/1/2023 2023 30 5
Grading 9/4/2023 10/13/2023 2023 30 5
Building Construction 9/18/2023 3/28/2024 2024 139 5
Notes:

1. All construction phasing information was provided by the Project Sponsor. The start and end dates of construction subphases were adjusted due to project delays.

Table 1
Construction Schedule
Raven SR
Richmond, CA
7/17/2023
Construction
Subphase(s) Equipment Name1 Fuel1 Number1 Horsepower2 Days Per Phase1
Daily Usage
(hours/day)1 Utilization1 Uncontrolled
Engine Tier3
Air Compressors Diesel 1 37 5 8 100% No Specific Tier
Crushing/Proc. Equipment Gasoline 1 12 5 8 100% No Specific Tier Excavators Diesel 1 36 5 8 100% No Specific Tier
Dumpers/Tenders Diesel 2 16 5 8 100% No Specific Tier
Excavators Diesel 3 36 30 8 100% No Specific Tier
Tractors/Loaders/Backhoes Diesel 1 84 30 8 100% No Specific Tier Rough Terrain Forklifts Diesel 1 96 30 4 100% No Specific Tier Dumpers/Tenders Diesel 1 16 30 8 100% No Specific Tier
Plate Compactors Diesel 2 8 30 8 100% No Specific Tier
Crawler Tractors Diesel 1 87 30 8 100% No Specific Tier Rollers Diesel 1 36 30 8 100% No Specific Tier
Tractors/Loaders/Backhoes Diesel 1 84 30 8 100% No Specific Tier Excavators Diesel 1 36 30 8 100% No Specific Tier
Cranes Diesel 1 367 139 8 100% No Specific Tier
Rough Terrain Forklifts Diesel 1 96 139 8 100% No Specific Tier Air Compressors Diesel 1 37 139 8 100% No Specific Tier Generator Sets Diesel 1 14 139 8 100% No Specific Tier
Welders Diesel 2 46 139 8 100% No Specific Tier
Other Construction Equipment Diesel 1 82 139 8 100% No Specific Tier Notes:

1. 2.

3. Abbreviations:

ARB - California Air Resources Board
CalEEMod - California Emissions Estimator Model
References:

Table 2
Construction Equipment
Raven SR
Richmond, CA
Anticipated Construction Start Date:

The California Emissions Estimator Model (CalEEMod). Available at: http://www.caleemod.com/ Demolition
Site Preparation
Grading
Building Construction
Construction equipment information was provided by the Project Sponsor or based on CalEEMod defaults if not given.

Equipment horsepower is based on CalEEMod Appendix G defaults.

Equipment engine tiers are based on CalEEMod fleet averages.

Type Source Methodology and Formula Reference
Construction
Equipment Off-Road Equipment1 Ec = Σ(EFc * HP * LF * Hr * UF * C) OFFROAD2017 and
ARB/USEPA Engine
Standards
Construction
Fugitive Dust
Mechanical Dismemberment,
Grading, Truck Loading CalEEMod® CalEEMod
Exhaust – Running ER = Σ(EFR * VMT * C) , where
VMT = Trip Length * Trip Number EMFAC2021
Brake Wear and Tire Wear EBW,TW = Σ(EFBW,TW * VMT * C), where VMT = Trip Length * Trip Number EMFAC2021
Exhaust - Idling EI = Σ(EFI * Trip Number *TI* C) EMFAC2021 Entrained Road Dust ERD = Σ(EFRD * VMT * C) , where
VMT = Trip Length * Trip Number
ARB 2021 Miscellaneous
Process Methodology 7.9
Notes:

1. Ec: off-road equipment exhaust emissions (lb)
EFc: emission factor (g/hp-hr). CalEEMod default emission factors used HP: equipment horsepower. From CalEEMod defaults
LF: equipment load factor. From OFFROAD2017
Hr: equipment hours
UF: Utilization factor
C: unit conversion factor

2. ER: running exhaust and running losses emissions (lb) EFR: running emission factor (g/mile). From EMFAC2021
VMT: vehicle miles traveled
C: unit conversion factor
The calculation involves the following assumptions:
a. All material transporting and soil hauling trucks are heavy-heavy duty trucks.

EI: vehicle idling emissions (lb).

EFI: vehicle idling emission factor (g/hr-trip). From EMFAC2021 TI: idling time
C: unit conversion factor
ERD: entrained road dust emissions (lb)
EFRD: annual average emission factor (lb/VMT) = k*(sL)^0.91 * (W)^1.02 * (1-P/4N) k: particle size multiplier for particle size range
sL: roadway silt loading [grams per square meter - g/m 2] W: average weight of vehicles traveling the road [tons] P = number of “wet” days in county with at least 0.01 in of precipitation during the annual averaging period N = number of days in the averaging period
VMT: vehicle miles traveled
C: unit conversion factor
Abbreviations:

ARB: California Air Resources Board lb: pound
BW: Brake Wear LF: Load Factor
EF: Emission Factor mi: mile
EMFAC: EMission FACtor Model USEPA: United States Environmental Protection Agency g: gram RL: Running Losses
HP: horsepower VMT: vehicle miles traveled
References:

Table 3
Emission Calculation Methodology
Raven SR
Richmond, CA
Construction and
Operational On-
Road Mobile
Sources2
On-road mobile sources include truck and passenger vehicle trips. Emissions associated with mobile sources were calculated using the following formulas.
b. Trip Length: The one-way trip length as calculated based on CalEEMod Appendix G defaults for Contra Costa County or provided by the Project Sponsor
c. Trip Number: Worker, vendor and hauling trip rates were provided by the Project Sponsor.

ARB/USEPA. 2013. Table 1: ARB and USEPA Off-Road Compression-Ignition (Diesel) Engine Standards. Available online at:
http://www.arb.ca.gov/msprog/ordiesel/documents/Off-Road_Diesel_Stds.xls The California Emissions Estimator Model (CalEEMod). Available at: http://www.caleemod.com/ California Air Resources Board (ARB) 2021. EMFAC2021. Available at: https://ww2.arb.ca.gov/our-work/programs/mobile-source-emissions- inventory/msei-modeling-tools
Trip Data
Trip Rates1 (one-way
trips/subphase)
Worker Trips Vendor Trips Hauling Trips Worker Trips Vendor Trips Hauling Trips Demolition 2023 5 2 0 100 12.9 7.4 20
Site Preparation 2023 30 2 0 0 12.9 7.4 20
Grading 2023 30 2 0 0 12.9 7.4 20
Building Construction 2023 76 2 4 0 12.9 7.4 20
Building Construction 2024 63 2 4 0 12.9 7.4 20
EMFAC Data4
Trip Type EMFAC Settings Fuel Type
Worker Gasoline
Vendor Diesel
Hauling Diesel
Notes:

1. 2.

3. Abbreviations:

CalEEMod - California Emissions Estimator Model
EMFAC2021 - California Air Resources Board EMission FACtor model LDA - light-duty automobiles
LDT - light-duty trucks
HHDT - heavy-heavy duty trucks
sqft - square feet
References:

Worker, vendor, and hauling trip lengths are based on CalEEMod Appendix G defaults for Contra Costa County.

Emissions were calculated using emission factors from EMFAC2021 with the specified settings and fleet and fuel assumptions.

The California Emissions Estimator Model (CalEEMod). Available at: http://www.caleemod.com/ California Air Resources Board (ARB) 2021. EMFAC2021. Available at: https://ww2.arb.ca.gov/our-work/programs/mobile-source-emissions-inventory/msei-modeling-tools Trip Lengths2 (miles/one-way trip)
Construction
Fleet Mix
Contra Costa County
Calendar Years 2023-2024
Annual Season
Aggregated Model Year
EMFAC2007 Vehicle Categories
25% LDA, 50% LDT1, 25% LDT2
50% MHDT, 50% HHDT
100% HHDT
Construction Phase Construction Subphase Year Construction Days
Table 4
Richmond, CA
Raven SR
Construction Trips
Worker, vendor, and hauling trip rates were provided by the Project Sponsor.

Trip Rates1 (trips/day)
Roadway Category Silt Loading1 (g/m2) Travel Fraction 1 Freeway 0.015 50%
Major 0.032 37%
Collector 0.032 9%
Local - Urban 0.32 4%
Weighted Silt Loading Factor 0.035 100%
Notes:

1. Abbreviations:

ARB - Air Resources Board
g - gram(s)
m - meter
References:

California Air Resources Board (ARB). 2021. Miscellaneous Process Methodology 7.9, Entrained Road Travel, Paved Road Dust. March. Available online at:
https://ww3.arb.ca.gov/ei/areasrc/fullpdf/2021_paved_roads_7_9.pdf Table 5
Silt Loading Emission Factors
Raven SR
Richmond, CA
Entrained Roadway Dust Constants for San Francisco County Travel fraction by roadway category and silt loading are based on ARB's Entrained Road Travel Emission Inventory Source Methodology Tables 2 and 4, respectively.

Road Dust Equation1
E [lb/VMT] = [k*(sL)^0.91 * (W)^1.02]*(1-P/4N)
Parameters2,3 Value
E = annual average emission factor in the same units as k [calculated] k = particle size multiplier for particle size range
PM2.5 (lb/VMT) 3.3E-04
sL = roadway silt loading [grams per square meter - g/m 2] 0.035 W = average weight of vehicles traveling the road [tons] 2.4 P = number of “wet” days in county with at least 0.01 in of precipitation during the annual averaging period 3 30
N = number of days in the averaging period 365
Entrained Road Dust Emission Factors
PM2.5 Emission Factor [lb/VMT] 3.74E-05
Notes:

1. 2.

3. Abbreviations:

ARB - California Air Resources Board lb - pound
CalEEMod - California Emissions Estimator Model PM2.5 - particulate matter less than 2.5 microns EMFAC - EMission FACtor Model VMT - vehicle miles traveled g - gram
References:

The number of "wet" days for Richmond, CA is from CalEEMod Appendix G Table G-2 (30 days).

California Air Resources Board (ARB). 2021. Miscellaneous Process Methodology 7.9, Entrained Road Travel, Paved Road Dust. March. Available online at: https://ww3.arb.ca.gov/ei/areasrc/fullpdf/2021_paved_roads_7_9.pdf The California Emissions Estimator Model (CalEEMod). Available at: http://www.caleemod.com/ Table 6
Emission Factors for Entrained Roadway Dust
Raven SR
Richmond, CA
Road dust equation and parameters are from the California Air Resources Board's (ARB) 2021 Miscellaneous Process Methodology 7.9 for Entrained Road Travel, Paved Road Dust.

The silt loading emission factor assumes Contra Costa County default roadway fractions and silt loading levels from ARB 2021. Other parameters (average weight of vehicles, size multipliers) are from ARB 2021. PM 2.5 is assumed to be 15% of PM10 based on paved road dust sampling in California (ARB Speciation Profile #471), which is a more representative fraction than provided in the older AP-42 fugitive dust methodology as discussed in ARB 2021 (page 17).

Worker Trip length (miles/trip) 0.189
Vendor Trip Length (miles/trip) 0.189
Hauling Trip Length (miles/trip) 0.189
PM2.5 Emission Factor [lb/VMT] 3.74E-05
PM2.5
Demolition 2023 5 2 0 100 2 0 19 21 7.8E-04
Site Preparation 2023 30 2 0 0 11 0 0 11 4.2E-04
Grading 2023 30 2 0 0 11 0 0 11 4.2E-04
Building Construction 2023 76 2 4 0 29 58 0 86 0.0032
Building Construction 2024 63 2 4 0 24 48 0 72 0.0027
Notes:

1. 2.

Abbreviations:

CalEEMod - California Emissions Estimator Model lb - pound PM2.5 - particulate matter less than 2.5 microns VMT - vehicle miles traveled Table 7
Emission Calculation for Entrained Roadway Dust
Raven SR
Richmond, CA
Construction Area Subphase Year Construction
Days
Entrained Road Dust Emission Factors2
Calculated
1000 feet
1000 feet
1000 feet
Inputs
Trip Length1
Entrained road dust emission factors were obtained from Table 6.

Total VMT
(miles)
Total Emissions
(lb)
Construction
VMTs for worker, vendor, and hauling are obtained from Table 4.

Vendor Trips
(trips/day)
Hauling Trips
(trips/subphase)
Worker VMT
(miles)
Vendor VMT
(miles)
Hauling VMT
(miles)
Worker Trips
(trips/day)
PM2.5 PM2.5
days ton lb/day ton/yr
Construction 2023 5.0 828 3.5E-04 0.0031 0.57 0.0014
Notes:

1. 2.

0.053 = k, PM2.5 particle size multiplier (dimensionless)

3.90 = mean wind speed (U), meters per second, Oakland International Airport

8.7 = U, mean wind speed (mph)
2 = M, material moisture content (%)

3. 0.053 = k, PM2.5 particle size multiplier (dimensionless)

0.058 = EFL-TSP, lb/ton

4. Abbreviations:

CalEEMod - California Emissions Estimator Model
cy - cubic yards
EF - emission factor
lb - pounds
PM2.5 - particulate matter less than 2.5 microns
VMT - vehicle miles traveled
yr - years
Table 8
Fugitive Dust Emissions from Demolition Activity
Raven SR
Richmond, CA
Construction Area Year
Number
of Days
Emissions were estimated conservatively assuming no fugitive dust control measures.

Building
Waste1
Emission Factor -
Mechanical or
Explosive
Dismemberment2
Emission Factor -
Debris Loading3
Uncontrolled
Emissions4
PM2.5
lb/ton lb/ton
Building square footage was provided by the Project Sponsor. Conversion of building waste to tons assumes an average soil density of 1.5 grams per cubic centimeter, per the CalEEMod User's Guide, Appendix C Truck Loading.

Emission factor calculated following guidance in the CalEEMod User's Guide, Appendix C Mechanical or Explosive Dismemberment, which is based of AP 42 Section 13.2.4.3 for batch drop operations. The equation is:

EF = k*(0.0032)*(U/5)1.3/(M/2)1.4 (lb/ton of debris)
Emission factor calculated following guidance in the CalEEMod User's Guide, Appendix C Debris Loading, which is based of AP 42 Section

13.2. The equation is:

EF = k*EFL-TSP
PM2.5
acre/8hr-day acre/day mile/day lb/VMT
Construction Grading 2023 30 Crawler Tractors 1 100% 0.5 0.50 0.34 0.17 1.72 Notes:

1. 2. Based on CalEEMod® default daily acres graded by equipment type, Table G-14, below.

Equipment
Acres Graded per 8
Hour Day
Crawler Tractors 0.5
Graders 0.5
Rubber Tired Dozers 0.5
Scrapers 1

3. AS = AS, acres graded per day (varies by sub-activity); in this case using maximum estimated disturbed acres/day 12= Wb, blade width of grading equipment (CalEEMod® default) in ft

3. 7.1= S, mean vehicle speed (mph) (AP-42 default)

0.6= FPM10, PM10 scaling factor (AP-42 default)

0.031= FPM2.5, PM2.5 scaling factor (AP-42 default)
Abbreviations:
mph - miles per hour
PM2.5 - particulate matter less than 2.5 microns
ft - feet VMT - vehicle miles traveled
lb - pounds yr - year
EF - emission factor
Grading VMT2 Uncontrolled PM2.5
Emission Factor3
Uncontrolled
Emissions
Maximum graded area calculated following guidance in the CalEEMod® User's Guide, Appendix C.

VMT per day calculated following guidance in the CalEEMod® User's Guide, Appendix C, which is based on AP-42, Section 11.9 for grading equipment. The equation is:

Emission factors calculated following guidance in the CalEEMod® User's Guide, Appendix C, which is based on AP-42, Section 11.9 for grading equipment. The equations are:

CalEEMod® - California Emissions Estimator Model
lb/yr
Total Work Days
(per year) Equipment Quantity Utilization %
CalEEMod
Grading rate2
Maximum Area
Disturbed1
Table 9
Fugitive Dust Emissions from Off-Road Grading Activity
Raven SR
Richmond, CA
Construction Area Construction
Subphase1 Year
PM2.5
days # trips ton ton lb/day ton/yr
Construction Demolition 2023 5 100 828 828 2.85E-05 4.7E-03 1.2E-05 Notes:

1. 2.

0.053

3.9 8.7
12 Abbreviations:

CalEEMod - California Emissions Estimator Model
EF - emission factor
lbs - pounds
PM2.5 - particulate matter less than 2.5 microns
Table 10
Fugitive Dust Emissions from Truck Loading Activity
Raven SR
Richmond, CA
Construction Area Construction Subphase Year
Number of
Days
lb/ton
Emission factor calculated following guidance in the CalEEMod User's Guide, Appendix C, which is based on AP-42, Section 13.2.4 for aggregate handling. The equation is:

EF = k x (0.0032) x (U/5)1.3 / (M/2)1.4 , where the following default values are used:

PM2.5
Haul Trips Total Material
Loaded1
Material
Loaded
Uncontrolled
Emission Factor2 Uncontrolled Emissions
= kPM2.5, PM2.5 particle size multiplier
= mean wind speed (U), meters per second, Oakland International Airport = mean wind speed (U), miles per hour
= material moisture content (M), %
Total materials loaded for demolition phase were the building waste converted from square feet to tons assuming an average soil density of 1.5 grams per cubic centimeter, per the CalEEMod User's Guide, Appendix C Truck Loading. Total exported materials for other phases is assumed to be zero, as provided by the Project Sponsor.

DPM PM2.5 DPM PM2.5
2023 0.0018 0.0018 1.9E-07 3.9E-07
2024 9.0E-04 8.3E-04 1.1E-07 2.2E-07
Notes:

1. Abbreviations:

BAAQMD - Bay Area Air Quality Management District
CalEEMod® - California Emissions Estimator Model®
DPM - diesel particulate matter
PM2.5 - particulate matter less than 2.5 microns
References:

Construction TAC emissions were estimated from on-site off-road emissions, where all PM10 tailpipe emissions are assumed to be DPM (although a portion of this is likely not from diesel sources). On-road emissions from hauling, vendor and worker vehicles were estimated using a modeled trip length of 1000 ft. The inclusion of on-road emissions is conservative as the estimated traffic volumes do not exceed the screening levels recommended by BAAQMD (i.e., more than 10,000 vehicles per day and 100 trucks per day) and can be considered minor sources (BAAQMD 2011).

Recommended Methods for Screening and Modeling Local Risks and Hazards. 2012. BAAQMD. May. Available online at: https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/risk-modeling-approach-may- 2012.pdf?la=en
The California Emissions Estimator Model (CalEEMod). Available at: http://www.caleemod.com/ California Environmental Quality Act (CEQA) Guidelines. 2017. Bay Area Air Quality Management District (BAAQMD). May. Available online at: http://www.baaqmd.gov/~/media/files/planning-and- research/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en
Table 11
Modeled Emission Rates - Project Construction Sources
Raven SR
Richmond, CA
Year
Construction Emissions1 [g/s]
Offroad Onroad
Biogas Engines1 Green Waste
Offgas2 Flare2 Fire Pump
Engine2 Biogas Engines1 Green Waste
Offgas2 Flare2 Fire Pump
Engine2
(g/s) (g/s) (g/s) (g/s) (g/s) (g/s) (g/s) (g/s)
1,1-Dichloroethane (Ethylidene dichloride) 0.0017 -- -- -- 0.0017 -- -- -- 1,1-Dichloroethene (Vinylidene chloride) 7.3E-05 -- -- -- 7.3E-05 -- -- -- 1,1,1-Trichloroethane (Methyl chloroform) 3.3E-05 -- -- -- 3.3E-05 -- -- -- 1,1,2-Trichloroethane (Vinyl trichloride) 9.7E-06 -- -- -- 9.8E-06 -- -- -- 1,1,2,2-Tetrachloroethane 1.2E-05 -- -- -- 1.2E-05 -- -- -- 1,3-Butadiene 3.9E-06 -- -- -- 4.0E-06 -- -- --
1,4-Dichlorobenzene 1.7E-04 -- -- -- 1.7E-04 -- -- --
1,4-Dioxane (1,4-Diethylene dioxide) 6.4E-06 -- -- -- 6.4E-06 -- -- -- Acetaldehyde 0.0062 1.3E-04 1.2E-05 -- 0.0062 8.7E-05 2.0E-07 -- Acrolein 8.0E-04 -- 7.7E-06 -- 8.0E-04 -- 1.3E-07 --
Acrylonitrile 7.8E-06 -- -- -- 7.8E-06 -- -- --
Allyl Chloride (3-Chloropropene) 5.6E-06 1.6E-06 -- -- 5.6E-06 1.0E-06 -- -- Ammonia 1.5E-05 2.3E-04 -- -- 0.48 1.5E-04 -- --
Arsenic -- -- 5.7E-07 -- -- -- 9.5E-09 --
Benzene 0.0042 -- 2.3E-05 -- 0.0042 -- 3.8E-07 --
Benzyl Chloride 7.3E-06 -- -- -- 7.3E-06 -- -- --
Beryllium -- -- 1.7E-08 -- -- -- 2.8E-10 --
Cadmium -- -- 3.1E-06 -- -- -- 5.2E-08 --
Carbon Disulfide 5.6E-06 1.8E-06 -- -- 5.6E-06 1.2E-06 -- -- Carbon Tetrachloride 1.1E-05 -- -- -- 1.1E-05 -- -- --
Chlorobenzene 4.2E-05 -- -- -- 4.2E-05 -- -- --
Ethyl Chloride (Chloroethane) 8.7E-05 -- -- -- 8.7E-05 -- -- -- Chloroform 6.9E-05 -- -- -- 6.9E-05 -- -- --
Copper -- -- 2.4E-06 -- -- -- 4.0E-08 --
Diesel particulate matter -- -- -- 0.83 -- -- -- 9.4E-05 Dioxins PCDDs 3.6E-09 -- -- -- 3.6E-09 -- -- --
Ethylbenzene 6.0E-04 7.3E-06 2.7E-05 -- 6.0E-04 4.9E-06 4.5E-07 -- Ethylene Dibromide (1,2-dibromoethane) 1.4E-05 -- -- -- 1.4E-05 -- -- -- Ethylene Dichloride (1,2-dichloroethane) 2.9E-04 3.3E-06 -- -- 2.9E-04 2.2E-06 -- -- Formaldehyde 0.031 -- 6.3E-04 -- 0.031 -- 1.0E-05 --
n-Hexane 0.0027 -- 1.8E-05 -- 0.0027 -- 2.9E-08 --
Hydrochloric Acid (Hydrogen Chloride) 0.48 -- -- -- 0.10 -- -- -- Hydrofluoric Acid (Hydrogen Fluoride) 0.015 -- -- -- 0.0031 -- -- -- Hydrogen Sulfide (H2S) 2.1E-06 -- -- -- 2.1E-06 -- -- -- Isopropyl alcohol (IPA, 2-Propanol) 6.9E-05 1.4E-05 -- -- 6.9E-05 9.1E-06 -- -- Lead -- -- 1.4E-06 -- -- -- 2.4E-08 --
Manganese -- -- 1.1E-06 -- -- -- 1.8E-08 --
Mercury 3.3E-08 -- 7.4E-07 -- 3.3E-08 -- 1.2E-08 --
Methanol (Methyl alcohol) 2.3E-05 0.0073 -- -- 2.4E-05 0.0049 -- -- Methyl Bromide (Bromomethane) 6.9E-06 -- -- -- 6.9E-06 -- -- -- Methyl Ethyl Ketone (2-butanone) 1.1E-05 2.7E-04 -- -- 1.1E-05 1.8E-04 -- -- Methyl tert-Butyl Ether 6.4E-06 -- -- -- 6.4E-06 -- -- -- Methylene Chloride (dichloromethane) 0.0074 -- -- -- 0.0074 -- -- -- Naphthalene 5.2E-04 4.6E-07 1.7E-06 -- 5.2E-04 3.1E-07 2.9E-08 -- Nickel -- -- 6.0E-06 -- -- -- 1.0E-07 --
PAH Equivalents as Benzo(a)pyrene 1.0E-05 -- 1.9E-08 -- 1.0E-05 -- 3.2E-10 -- Perchloroethylene (tetrachloroethylene) 0.0040 -- -- -- 0.0040 -- -- -- Propene (Propylene) 6.8E-04 1.0E-05 0.0021 -- 6.8E-04 6.6E-06 3.5E-05 -- Selenium -- -- 3.4E-08 -- -- -- 5.7E-10 --
Styrene 1.8E-05 1.8E-05 -- -- 1.8E-05 1.2E-05 -- --
Toluene 9.4E-04 1.3E-05 1.0E-04 -- 9.4E-04 8.4E-06 1.7E-06 -- Trichloroethylene 8.4E-04 -- -- -- 8.5E-04 -- -- --
Vanadium -- -- 6.5E-06 -- -- -- 1.1E-07 --
Vinyl Acetate 1.3E-05 7.9E-05 -- -- 1.3E-05 5.2E-05 -- -- Vinyl Chloride (chloroethylene) 0.0011 -- -- -- 0.0011 -- -- -- Xylene (Total) 7.5E-04 7.6E-06 7.7E-05 -- 7.5E-04 2.7E-06 1.3E-06 -- Notes:

1. 2.

Abbreviations:

BAAQMD - Bay Area Air Quality Management District
g - gram
s - second
Biogas engine TAC emissions were estimated by BAAQMD using concentrations and speciation from facility data, and assuming 85% abatement efficiency.

Estimated TAC emissions were consistent with previous operational emission analyses for BAAQMD air permit application.

Table 12
Modeled Emission Rates - Project Operational Sources
Raven SR
Richmond, CA
ChronicAcute
Pollutant
Acute Chronic
Landfill Flare Landfill Flare
(g/s) (g/s)
1,1-Dichloroethane (Ethylidene dichloride)75-34-3 0.011 0.011 1,1-Dichloroethene (Vinylidene chloride)75-35-4 4.9E-04 4.9E-04 1,1,1-Trichloroethane (Methyl chloroform)71-55-6 2.2E-04 2.2E-04 1,1,2-Trichloroethane (Vinyl trichloride)79-00-5 6.5E-05 6.5E-05 1,1,2,2-Tetrachloroethane 79-34-5 8.2E-05 8.2E-05
1,3-Butadiene 106-99-0 2.6E-05 2.6E-05
1,4-Dichlorobenzene 106-46-7 0.0011 0.0011
1,4-Dioxane (1,4-Diethylene dioxide)123-91-1 4.3E-05 4.3E-05 Acetaldehyde 75-07-0 0.041 0.041
Acrolein 107-02-8 0.0053 0.0053
Acrylonitrile 107-13-1 5.2E-05 5.2E-05
Allyl Chloride (3-Chloropropene) 107-05-1 3.7E-05 3.7E-05 Ammonia 7664-41-7 1.0E-04 3.2
Benzene 71-43-2 0.028 0.028
Benzyl Chloride 100-44-7 4.8E-05 4.8E-05
Carbon Disulfide 75-15-0 3.7E-05 3.7E-05
Carbon Tetrachloride 56-23-5 7.5E-05 7.5E-05
Chlorobenzene 108-90-7 2.8E-04 2.8E-04
Ethyl Chloride (Chloroethane) 75-00-3 5.8E-04 5.8E-04
Chloroform 67-66-3 4.6E-04 4.6E-04
Dioxins PCDDs 1-08-6 2.4E-08 2.4E-08
Ethylbenzene 100-41-4 0.0040 0.0040
Ethylene Dibromide (1,2-dibromoethane)106-93-4 9.2E-05 9.2E-05 Ethylene Dichloride (1,2-dichloroethane)107-06-2 0.0020 0.0020 Formaldehyde 50-00-0 0.20 0.21
n-Hexane 110-54-3 0.018 0.018
Hydrochloric Acid (Hydrogen Chloride)7647-01-0 3.2 0.64 Hydrofluoric Acid (Hydrogen Fluoride)7664-39-3 0.10 0.020 Hydrogen Sulfide (H2S) 2148-87-8 1.4E-05 1.4E-05
Isopropyl alcohol (IPA, 2-Propanol) 67-63-0 4.6E-04 4.6E-04 Mercury 7439-97-6 3.3E-08 3.3E-08
Methanol (Methyl alcohol) 67-56-1 1.6E-04 1.6E-04
Methyl Bromide (Bromomethane) 74-83-9 4.6E-05 4.6E-05
Methyl Ethyl Ketone (2-butanone) 78-93-3 7.1E-05 7.1E-05 Methyl tert-Butyl Ether 1634-04-4 4.3E-05 4.3E-05
Methylene Chloride (dichloromethane)75-09-2 0.049 0.049 Naphthalene 91-20-3 0.0035 0.0035
PAH Equivalents as Benzo(a)pyrene 1150/1151 6.8E-05 6.8E-05 Perchloroethylene (tetrachloroethylene)127-18-4 0.027 0.027 Propene (Propylene) 115-07-1 0.0045 0.0045
Styrene 100-42-5 1.2E-04 1.2E-04
Toluene 108-88-3 0.0062 0.0063
Trichloroethylene 79-01-6 0.0056 0.0056
Vinyl Acetate 108-05-4 8.4E-05 8.4E-05
Vinyl Chloride (chloroethylene) 75-01-4 0.0073 0.0073
Xylene (Total) 1330-20-7 0.0050 0.0050
Notes:

1. Abbreviations:

BAAQMD - Bay Area Air Quality Management District
g - gram
s - second
Existing landfill flare TAC emission reductions were calculated based on BAAQMD estimates for biogas engines TAC emissions and assuming no abatement efficiency.

Pollutant CAS
Table 13
Modeled Emission Rates - Existing Landfill Flare Reductions Raven SR
Richmond, CA
Construction Sources
Source
Dimension Release HeightInitial Vertical
Dimension
Initial Lateral
Dimension
[m] [m] [m] [m]
Construction Equipment1 Area 1 Approximate
Equipment Area 5.0 1.16 --
Fugitive Dust2 Area 1 Approximate
Equipment Area 0.0 1 --
Operational Sources3
Release Height
[m]
Green Waste Offgas Area 1 4.97
Stack Height Stack Velocity Exit DiameterStack
Temperature
[m] [m/s] [m] °F
Biogas Engines Point 3 7.92 52.39 0.20 850
Flare Point 1 12.19 0.18 2.24 1,500
Fire Pump Engine Point 1 1.83 13.17 0.20 869
Existing Landfill Sources4
Stack Height Stack Velocity Exit DiameterStack
Temperature
[m] [m/s] [m] °F
Flare Point 2 12.19 0.15 2.51 1,502
Notes:

1. 2.

3. 4.

Abbreviations:
°F - Fahrenheit
BAAQMD - Bay Area Air Quality Management District m - meter CRRP - Community Risk Reduction Plan s - second
HRA - Health risk assessment USEPA - United States Environmental Protection Agency References:

Source Source Type Number of
Sources
Source Source Type Number of
Sources
Table 14
Modeling Parameters
Raven SR
Richmond, CA
Number of
SourcesSource TypeSource
Source Source Type Number of
Sources
Construction off-road equipment was modeled as one area source covering the parcel under construction. According to the CRRP-HRA methodology, release height of a modeled area source representing construction equipment was set to 5 meters and the initial vertical dimension is set to the release height divided by 4.3.

Construction fugitive dust will be modeled as one area source covering the parcel under construction. According to the 2012 San Francisco Community HRA methodology, the initial vertical dimension of the modeled fugitive dust area source will be set to 1 meter and the release height will be set to 0 meters consistent with SCAQMD LST methods.

USEPA. 2022. User's Guide for the AMS/EPA Regulatory Model (AERMOD). Office of Air Quality Planning and Standards. Research Triangle Park, North Carolina. EPA-454/B-22-007, June 2022). Available at: https://gaftp.epa.gov/Air/aqmg/SCRAM/models/preferred/aermod/aermod_userguide.pdf South Coast Air Quality Management District (SCAQMD). 2008. Final Localized Significance Threshold Methodology. July. Available at:
http://www.aqmd.gov/docs/default-source/ceqa/handbook/localized-significance-thresholds/final-lst-methodology-document.pdf?sfvrsn=2 The existing landfill flare stack parameters were estimated by POWER Engineers and obtained from the Semi-Annual Monitoring Report 2021 submitted by West Contra Costa Sanitary Landfill to BAAQMD, available at: https://www.baaqmd.gov/~/media/files/engineering/title-v- permits/a1840/a1840_wccc_landfill_053122_2021_a-pdf.pdf?la=en&rev=af45f67469484d85b592e41dd6866b23 Bay Area Air Quality Management District (BAAQMD). 2012. The San Francisco Community Risk Reduction Plan: Technical Support Documentation.

December. Available at: https://www.gsweventcenter.com/Appeal_Response_References/2012_1201_BAAQMD.pdf.

Bay Area Air Quality Management District (BAAQMD). 2020. Health Risk Assessment Modeling Protocol. December. Available online at:
https://www.baaqmd.gov/~/media/files/ab617-community-health/facility-risk-reduction/documents/baaqmd_hra_modeling_protocol-pdf.pdf?la=en San Francisco Department of Public Health (SF DPH), San Francisco Planning Department (SF Planning), and Ramboll. 2020. San Francisco Citywide Health Risk Assessment: Technical Support Documentation. Available online at:
https://www.sfdph.org/dph/files/EHSdocs/AirQuality/Air_Pollutant_Exposure_Zone_Technical_Documentation_2020.pdf For Project operation, the biogas engines, flare, and fire pump engine are modeled as point sources. The green waste storage pile is modeled as an area source. Source parameters were provided by the Project Sponsor.

Construction+Operation
Daily Breathing
Rate (DBR)1
Exposure
Duration (ED)2
Fraction of Time
at Home (FAH)3
Exposure
Frequency
(EF)4
Averaging
Time (AT)
Modeling
Adjustment
Factor5
Intake Factor,
Inhalation (IFinh)
[L/kg-day] [years] [unitless] [days/year] [days] [unitless] [m3/kg-day] 2023 3rd Trimester 361 0.46 1 350 25,550 1.0 0.0023
2023 Age 0-<2 Years 1,090 0.54 1 350 25,550 1.0 0.0081
2024 Age 0-<2 Years 1,090 0.24 1 350 25,550 1.0 0.0036
Age 0-<2 Years 1,090 1.22 1 350 25,550 1.0 0.0182
Age 2-<16 Years 572 14 1 350 25,550 1.0 0.11
Age 16-30 Years 261 14 0.73 350 25,550 1.0 0.037
2023 16-70 years 230 1 -- 250 25,550 4.2 0.0023
2024 16-70 years 230 0.24 -- 250 25,550 4.2 0.0005
Operation All 16-70 years 230 23.76 -- 250 25,550 4.2 0.053 2023 Age 2-<9 Years 640 1 -- 180 25,550 4.2 0.0045
2024 Age 2-<9 Years 640 0.24 -- 180 25,550 4.2 0.0011
Age 2-<9 Years 640 2.76 -- 180 25,550 4.2 0.0124
Age 2-<16 Years 520 4 -- 180 25,550 4.2 0.015
Operation-Only
Daily Breathing
Rate (DBR)1
Exposure
Duration (ED)6
Fraction of Time
at Home (FAH)3
Exposure
Frequency
(EF)4
Averaging
Time (AT)
Modeling
Adjustment
Factor5
Intake Factor,
Inhalation (IFinh)
[L/kg-day] [years] [unitless] [days/year] [days] [unitless] [m3/kg-day] 3rd Trimester 361 0.25 1 350 25,550 1.0 0.0012
Age 0-<2 Years 1,090 2 1 350 25,550 1.0 0.030
Age 2-<16 Years 572 14 1 350 25,550 1.0 0.11
Age 16-30 Years 261 14 0.73 350 25,550 1.0 0.037
Worker Operation All 16-70 years 230 25 -- 250 25,550 4.2 0.056 Age 2-<9 Years 640 4 -- 180 25,550 4.2 0.018
Age 2-<16 Years 520 4 -- 180 25,550 4.2 0.015
Notes:

1. 2.

3. 4.

5. 6.

Calculation:

IFinh = DBR * FAH * EF * ED * CF / AT
CF = 0.001 (m3/L)
Abbreviations:

AT - averaging time IFinh - intake factor
BAAQMD - Bay Area Air Quality Management District kg - kilogram DBR - daily breathing rate L - liter
ED - exposure duration m3 - cubic meter
EF - exposure frequency OEHHA - Office of Environmental Health Hazard Assessment References:

Table 15
Exposure Parameters
Raven SR
Richmond, CA
Population Receptor Age Group
Exposure Parameters
Project Phase Year
BAAQMD. 2020. Health Risk Assessment (HRA) Modeling Protocol. December.

OEHHA. 2015. Air Toxics Hot Spots Program Risk Assessment Guidelines. Guidance Manual for Preparation of Health Risk Assessments. February.

Daily breathing rates for residents reflect default breathing rates from OEHHA 2015 and BAAQMD 2016 as follows: 95th percentile 24-hour daily breathing rate for 3rd trimester and age 0-<2 years; 80th percentile for ages 2 years and older (per BAAQMD 2016 and 2020 Health Risk Assessment (HRA) Modeling Guidelines). Daily breathing rates for workers assume 230 L/kg-8 hours, which represents the 95th percentile 8-hour breathing rate based on moderate activity of 16-70 years-old age range, per BAAQMD 2016 and 2020 Health Risk Assessment (HRA) Modeling Guidelines. Daily breathing rates for school receptors reflect 95th percentile 8-hour daily breathing rates for Moderate Intensity Activity for all ages.

Exposure duration for residents is assumed to begin at the start of construction and continue for 30 years of operation. Exposure duration for workers is assumed to begin at the start of construction and continue for 25 years of operation. Exposure duration for school receptors was assumed to include ages 5-13 for children attending Kindergarten through 8th Grade.

Fraction of time spent at home is conservatively assumed to be 1 (i.e., 24 hours/day) for age groups from the third trimester to less than 16 years old based on the recommendation from BAAQMD (BAAQMD 2016 and 2020) and OEHHA (OEHHA 2015).

The fraction of time at home for adults age 16-30 reflects default OEHHA guidance (OEHHA 2015) as recommended by BAAQMD (2016 and 2020).

Exposure frequency reflects default resident, worker, and school receptor exposure frequencies from OEHHA 2015 and BAAQMD 2016.

Modeling adjustment factors are calculated based on the methodology from OEHHA's Guidance Manual for Preparation of Health Risk Assessments (2015). The MAF for the worker and school receptors is calculated to adjust from 24 hours/day to 8 hours/day and from 7 days/week to 5 days/week ([24 hours/8 hours] * [7 days/5 days] = 4.20). Resident types are expected to be exposed 24 hours/day and 7 days/week; as a result, the MAF is 1.

All
Operation All
BAAQMD. 2016. Air Toxics NSR Program Health Risk Assessment (HRA) Guidelines. January.

Resident
ConstructionWorker
School
Construction
Operation
Construction
Exposure duration for residents is assumed for 30 years of operation and for workers is assumed for 25 years of operation. Exposure duration for school receptors was assumed to include ages 5-13 for children attending Kindergarten through 8th Grade.

Population Project Phase Receptor Age Group
Exposure Parameters
Year
School
Resident Operation All
AllOperation
Cancer Potency
Factor
Acute Noncancer Reference
Exposure Level
Chronic Noncancer
Reference Exposure Level
(mg/kg-day)-1 (μg/m3) (μg/m 3)
1,1-Dichloroethane (Ethylidene dichloride) 75-34-3 0.0057 -- -- 1,1-Dichloroethene (Vinylidene chloride) 75-35-4 -- -- 70 1,1,1-Trichloroethane (Methyl chloroform) 71-55-6 -- 68000 1000 1,1,2-Trichloroethane (Vinyl trichloride) 79-00-5 0.057 -- -- 1,1,2,2-Tetrachloroethane 79-34-5 0.2 -- --
1,3-Butadiene 106-99-0 0.6 660 2
1,4-Dichlorobenzene 106-46-7 0.04 -- 800
1,4-Dioxane (1,4-Diethylene dioxide) 123-91-1 0.027 3000 3000 Acetaldehyde 75-07-0 0.01 470 140
Acrolein 107-02-8 -- 2.5 0.35
Acrylonitrile 107-13-1 1 -- 5
Allyl Chloride (3-Chloropropene) 107-05-1 0.021 -- --
Ammonia 7664-41-7 -- 3200 200
Arsenic 7440-38-2 12 0.2 0.015
Benzene 71-43-2 0.1 27 3
Benzyl Chloride 100-44-7 0.17 240 --
Beryllium 7440-41-7 8.4 -- 0.007
Cadmium 7440-43-9 15 -- 0.02
Carbon Disulfide 75-15-0 -- 6200 800
Carbon Tetrachloride 56-23-5 0.15 1900 40
Chlorobenzene 108-90-7 -- -- 1000
Ethyl Chloride (Chloroethane) 75-00-3 -- -- 30000
Chloroform 67-66-3 0.019 150 300
Copper 7440-50-8 -- 100 --
Diesel particulate matter 9-90-1 1.1 -- 5
Dioxins PCDDs 1-08-6 130000 -- 0.00004
Ethylbenzene 100-41-4 0.0087 -- 2000
Ethylene Dibromide (1,2-dibromoethane) 106-93-4 0.25 -- 0.8 Ethylene Dichloride (1,2-dichloroethane) 107-06-2 0.072 -- 400 Formaldehyde 50-00-0 0.021 55 9
n-Hexane 110-54-3 -- -- 7000
Hydrochloric Acid (Hydrogen Chloride) 7647-01-0 -- 2100 9 Hydrofluoric Acid (Hydrogen Fluoride) 7664-39-3 -- 240 14 Hydrogen Sulfide (H2S) 7783-06-4 -- 42 10
Isopropyl alcohol (IPA, 2-Propanol) 67-63-0 -- 3200 7000 Lead 7439-92-1 0.042 -- --
Manganese 7439-96-5 -- -- 0.09
Mercury 7439-97-6 -- 0.6 0.03
Methanol (Methyl alcohol) 67-56-1 -- 28000 4000
Methyl Bromide (Bromomethane) 74-83-9 -- 3900 5
Methyl Ethyl Ketone (2-butanone) 78-93-3 -- 13000 --
Methyl tert-Butyl Ether 1634-04-4 0.0018 -- 8000
Methylene Chloride (dichloromethane) 75-09-2 0.0035 14000 400 Naphthalene 91-20-3 0.12 -- 9
Nickel 7440-02-0 0.91 0.2 0.014
PAH Equivalents as Benzo(a)pyrene 1-15-0 -- -- --
Perchloroethylene (tetrachloroethylene) 127-18-4 0.021 20000 35 Propene (Propylene) 115-07-1 -- -- 3000
Selenium 7782-49-2 -- -- 20
Styrene 100-42-5 -- 21000 900
Toluene 108-88-3 -- 5000 420
Trichloroethylene 79-01-6 0.007 -- 600
Vanadium 7440-62-2 -- 30 --
Vinyl Acetate 108-05-4 -- -- 200
Vinyl Chloride (chloroethylene) 75-01-4 0.27 180000 --
Xylene (Total) 1330-20-7 -- 22000 700
Notes:

1. Abbreviations:
-- - not available or not applicable mg/kg-day - milligrams per kilogram per day ARB - Air Resources Board OEHHA - Office of Environmental Health Hazard Assessment Cal/EPA - California Environmental Protection Agencyµg/m3 - micrograms per cubic meter CAS - chemical abstract services
Reference:

Table 16
Toxicity Values
Raven SR
Richmond, CA
Cal/EPA. 2022. OEHHA/ARB Consolidated Table of Approved Risk Assessment Health Values. September. Available at:
http://www.arb.ca.gov/toxics/healthval/contable.pdf.

Chemical1 CAS Number
Toxicity values are taken from ARB's Consolidated Table of OEHHA/ARB Approved Risk Assessment Health Values.

Excess Lifetime
Cancer Risk (in
a million)1
Non-Cancer
Hazard Index
(unitless)2,3
Acute Hazard
Index
(unitless)4
PM2.5
Concentration
(µg/m3, Annual
Average)3
Excess Lifetime
Cancer Risk (in
a million)1
Non-Cancer
Hazard Index
(unitless)2,3
Acute Hazard
Index
(unitless)4
PM2.5
Concentration
(µg/m3, Annual
Average)3
Project Construction +
Operations 2.0 0.079 0.15 0.57 0.33 0.0042 0.022 0.030
Project Operations 2.0 0.079 0.15 0.57 0.31 0.0042 0.022 0.030 Landfill Reductions -16 -0.66 -1.6 -0.84 -2.8 -0.040 -0.22 -0.051 Project Construction +
Operations with Landfill
Reductions
-14 -0.58 -1.4 -0.27 -2.5 -0.036 -0.20 -0.021
Project Operations with
Landfill Reductions -14 -0.58 -1.4 -0.27 -2.5 -0.036 -0.20 -0.021

BAAQMD CEQA
Significance Threshold 5 10 1.0 1.0 0.30 10 1.0 1.0 0.30 Excess Lifetime
Cancer Risk (in
a million)1
Non-Cancer
Hazard Index
(unitless)2,3
Acute Hazard
Index
(unitless)4
PM2.5
Concentration
(µg/m3, Annual
Average)3
Excess Lifetime
Cancer Risk (in
a million)1
Non-Cancer
Hazard Index
(unitless)2,3
Acute Hazard
Index
(unitless)4
PM2.5
Concentration
(µg/m3, Annual
Average)3
Project Construction +
Operations 0.20 0.0045 0.018 0.032 0.17 0.0023 0.016 0.016 Project Operations 0.20 0.0045 0.018 0.032 0.17 0.0023 0.016 0.016 Landfill Reductions -1.6 -0.037 -0.17 -0.047 -1.4 -0.021 -0.14 -0.026 Project Construction +
Operations with Landfill
Reductions
-1.4 -0.033 -0.15 -0.015 -1.3 -0.018 -0.12 -0.010
Project Operations with
Landfill Reductions -1.4 -0.033 -0.15 -0.015 -1.3 -0.018 -0.12 -0.010

BAAQMD CEQA
Significance Threshold 5 10 1.0 1.0 0.30 10 1.0 1.0 0.30 Notes:

1. 2.

3. 4.

5. Abbreviations:

ASF - Age Sensitivity Factors PM2.5 - particulate matter 2.5 microns or less CPF - Cancer Potency Factor REL - Reference Exposure Level HI - hazard index TAC - Toxic Air Contaminant
HQ - hazard quotient ug - microgram
m - meter UTM - Universal Transverse Mercator
MEI - maximally exposed individual
References:

Table 17
Project Health Impacts
Raven SR
Richmond, CA
Source
School Clinic
Source
Worker Resident
Thresholds from BAAQMD California Environmental Quality Act (CEQA) 2017 Guidelines.

California Environmental Quality Act (CEQA) 2017 Guidelines. Available at: http://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa_guidelines_may2017-pdf BAAQMD. Regulation 2 Permits Rule 5 New Source Review of Toxic Air Contaminants. Available at: https://www.baaqmd.gov/~/media/dotgov/files/rules/reg-2-permits/2021- amendments/documents/20211215_rg0205-pdf.pdf?la=en&rev=c403a2e96fde4799b1aa950cd4367aa2 Excess lifetime cancer risks are estimated as the upper-bound incremental probability that an individual will develop cancer over a lifetime as a direct result of exposure to potential carcinogens. The estimated risk is expressed as a unitless probability. The cancer risk attributed to the emissions associated with the Project was calculated based on the modeled annual average concentration, the intake factor for a resident child, the Cancer Potency Factors (CPF) for the TACs, and the Age Sensitivity Factors (ASF).

The potential for exposure to result in adverse chronic noncancer effects is evaluated by comparing the estimated annual average air concentration to the noncancer chronic Reference Exposure Level (REL) for each chemical. When calculated for a single chemical, the comparison yields a ratio termed a chronic hazard quotient (HQ). To evaluate the potential for adverse chronic noncancer health effects from simultaneous exposure to multiple chemicals, the chronic hazard quotients for all chemicals are summed, yielding a hazard index (HI).

PM2.5 concentration and Non-Cancer Hazard Index represent annual values.

The acute non-cancer HI analysis assumes that all sources are operating in any one hour time period, which is a conservative assumption.

Lifetime Excess Cancer
Risk1 PM2.5 Concentration1
(in a million) (µg/m3)
Existing Stationary Sources -- -- --
Highway2 1.3 -- 0.026
Major Streets2 0.46 -- 0.014
Roadway Total 1.8 -- 0.040
Railways2 3.7 -- 0.0049
Existing Total 5.4 -- 0.045
Project Construction + Operations
with Landfill Reductions -14.04 -0.58 -0.27
Total -8.6 -0.58 -0.227
Exceeds Threshold? NO NO NO
Existing Stationary Sources -- -- --
Highway2 1.3 -- 0.026
Major Streets2 5.30 -- 0.168
Roadway Total 6.6 -- 0.194
Railways2 4.3 -- 0.0059
Existing Total 10.9 -- 0.200
Project Construction + Operations
with Landfill Reductions -2.48 -0.04 -0.02
Total 8 -0.04 0.18
Exceeds Threshold? NO NO NO
Existing Stationary Sources -- -- --
Highway2 2.1 -- 0.042
Major Streets2 1.14 -- 0.032
Roadway Total 3.2 -- 0.074
Railways2 14.9 -- 0.0202
Existing Total 18.1 -- 0.094
Project Construction + Operations
with Landfill Reductions -1.37 -0.03 -0.01
Total 17 -0.03 0.079
Exceeds Threshold? NO NO NO
Existing Stationary Sources -- -- --
Highway2 1.4 -- 0.029
Major Streets2 1.37 -- 0.039
Roadway Total 2.8 -- 0.067
Railways2 5.6 -- 0.0077
Existing Total 8.4 -- 0.075
Project Construction + Operations
with Landfill Reductions -1.27 -0.02 -0.01
Total 7.1 -0.02 0.065
Exceeds Threshold? NO NO NO
Existing Stationary Sources -- -- --
Highway2 1.3 -- 0.026
Major Streets2 0.46 -- 0.014
Roadway Total 1.8 -- 0.040
Railways2 3.7 -- 0.0049
Existing Total 5.4 -- 0.045
Project Operations with Landfill
Reductions -14.08 -0.58 -0.27
Total -8.6 -0.58 -0.227
Exceeds Threshold? NO NO NO
Existing Stationary Sources -- -- --
Highway2 1.3 -- 0.026
Major Streets2 5.30 -- 0.168
Roadway Total 6.6 -- 0.194
Railways2 4.3 -- 0.0059
Existing Total 10.9 -- 0.200
Project Operations with Landfill
Reductions -2.50 -0.04 -0.02
Total 8 -0.04 0.18
Exceeds Threshold? NO NO NO
Existing Stationary Sources -- -- --
Highway2 2.1 -- 0.042
Major Streets2 1.14 -- 0.032
Roadway Total 3.2 -- 0.074
Railways2 14.9 -- 0.0202
Existing Total 18.1 -- 0.094
Project Operations with Landfill
Reductions -1.37 -0.03 -0.01
Total 17 -0.03 0.079
Exceeds Threshold? NO NO NO
Existing Stationary Sources -- -- --
Highway2 1.4 -- 0.029
Major Streets2 1.37 -- 0.039
Roadway Total 2.8 -- 0.067
Railways2 5.6 -- 0.0077
Existing Total 8.4 -- 0.075
Project Operations with Landfill
Reductions -1.27 -0.02 -0.01
Total 7.1 -0.02 0.065
Exceeds Threshold? NO NO NO
100 10 0.80Threshold
School
Clinic
Operation
Worker
Resident
Clinic
Construction + Operation
Worker
Resident
School
Table 18
Cumulative Health Impacts
Raven SR
Richmond, CA
Scenario Receptor Type Source Noncancer Chronic
HI1
Table 18
Cumulative Health Impacts
Raven SR
Richmond, CA
Notes:
1 2
Abbreviations:

HI - hazard index PM 2.5 - particulate matter less than 2.5 microns m3 - cubic meter µg - microgram
MEIR - maximum exposed individual receptor
References:

If the cell is marked with "--", no risk was calculated. For existing stationary sources, this is because the source was more than 1,000 feet from the onsite MEIR. For roadways, the chronic HI is not calculated in the BAAQMD screening tool.

Cancer risk and PM2.5 concentration values were determined using BAAQMD screening tools and are based on the maximum impact of a raster cell located on the MEIR.

Bay Area Air Quality Management District (BAAQMD). 2020. Permitted Sources Risk and Hazards Map. June. Available at:
https://baaqmd.maps.arcgis.com/apps/webappviewer/index.html?id=2387ae674013413f987b1071715daa65 Bay Area Air Quality Management District (BAAQMD). 2020. Health Risk Calculator Beta 4.0. March. Available at: https://www.baaqmd.gov/~/media/files/planning-and- research/ceqa/tools/baaqmd-health-risk-calculator-beta-4-0-xlsx.xlsx?la=en&rev=dab7d85a772d45caa9c99e59395bf12d\