HomeMy WebLinkAbout1998-02-23 City Council (15)City
City of Palo Alto
Manager’s Report
TO:HONORABLE CITY COUNCIL
6
FROM:CITY MANAGER DEPARTMENT: PUBLIC WORKS
DATE:FEBRUARY 23, 1998 CMR:141:98
SUBJECT:ADOPTION OF THE NEGATIVE DECLARATION - REGIONAL
WATER QUALITY CONTROL PLANT, AND APPROVAL OF THE
SOLIDS FACILITY PLAN’S RECOMMENDATION TO
REHABILITATE THE INCINERATORS
REPORT IN BRIEF
The Solids Facility Plan evaluates options and recommends a plan to manage the solid
residue at the Regional Water Quality Control Plant (RWQCP). The RWQCP currently uses
two incinerators to burn and reduce the sludge to a manageable amount of ash product for
beneficial reuse. After 26 years of continuous operation, the incinerators have deteriorated
significantly prompting the preparation of the Plan. The Plan examines the environmental,
economic, and operational impact of sludge treatment options and recommends rehabilitation
of the two incinerators immediately, with the addition of a sludge dryer in the future, if
needed.
Certain environmental advocacy groups have serious reservations about the continuation of
sewage sludge incineration. However, following extensive discussions with such groups and
further data gathering, staff was unable to conclude that other options are environmentally
better.
Staff believes the RWQCP should continue to analyze future options, reevaluate and adopt
a set of long range goals that are responsive to the communities and in context with future
regulations. Major changes in plant design and policy should not be made until long range
goals are complete.
CMR:141:98 Page I of 8
RECOMMENDATIONS
Staff recommends that Council:
o
Approve the recommendations of the Solids Facility Plan to rehabilitate the sewage
sludge incinerators at the RWQCP immediately, and add a thermal dryer when peak
loading capacity is required, or if pilot testing of a sludge dryer is desired.
Adopt the negative-declaration for the recommended project to rehabilitate the
incinerators at the RWQCP immediately, and add a thermal dryer, if needed.
Direct staff to forward the amendments to the Partners’ Agreements to Partner
agencies for approval.
Direct staff to develop policies for reducing environmental releases of mercury,
dioxins, polychlorinated biphenols.
Direct staff to establish a process for developing long term goals for the RWQCP, and
then return to Council for approval of the process.
BACKGROUND
The RWQCP is required to continuously process all incoming sewage. It currently operates
two incinerators to treat the solid residue (sludge) of the sewage. The sludge is burned and
reduced to a manageable amount of ash suitable for beneficial reuse. The sludge, before
burning, is unsuitable for disposal in landfills. The incinerators are the RWQCP’s only
means to treat and prepare the sludge for proper disposal. The reliability and redundancy of
these incinerators are extremely important to the RWQCP. Concerns with the incinerators
were discussed in.earlier staff reports, (CMR:278:96 and CMR:236:97), and are summarized
below.
The first concern is reliability: The incinerators were constructedin 1971 and have become
more and more difficult to keep in operating condition. Large cracks have developed in the
half-inch steel shell, and the chances of both incinerators being down at the same time have
increased to a point of very serious concern. Given the 24-hour per day, 365 day per year
nature of the operation, inability to operate the incinerators would present immediate
emergency conditions and, within 24 hours, human health concerns.
The second concem is redundancy: The wastewater flow going into the RWQCP varies daily
and seasonally. While the two existing incinerators are permitted to operate concurrently to
meet varying flow requirements, this operating mode does not allow for emergencies or
repairs. Currently, one of the incinerators is so frequently under repair that a back-up almost
never exists. The RWQCP is required to provide reliable, uninterrupted service.
CMR: 141:98 Page 2 of 8
The third concern is pollutant releases: The RWQCP incinerators are in compliance with
current regulations. However, the existing emission control devices on the incinerators are
outdated and therefore, maximum reduction of pollutants cannot be achieved. The solids
treatment and disposal options are currently heavily regulated, and future regulations are
uncertain. The issues associated with the pollutant releases to air, land, and water from
sludge treatment and disposal continue to be a concern with the public and regulatory
agencies.
These concerns prompted the preparation of the Solids Facility Plan(Plan). The Plan
examines the current and future potential regulations, and evaluates the environmental and
economic impact of several options.
DISCUSSION
RWQCP staff and staff from Partner agencies worked as technical advisors in preparing the
Plan. The Plan was developed through two studies, which have been under way since 1994.
The first study evaluated the feasibility of the full realm of technologies for handling the
sludge, and reduced down the number of feasible options. The recommendation of the
feasibility study formed the basis of the second study, the Plan. Two technologies are
considered feasible options besides incineration: sludge digestion and sludge drying. Sludge
digestion is the anaerobic breakdown of sludge in large holding tanks over long periods. The
end product is digested sludge, commonly called bi0solids. Sludge drying uses low heat to
evaporate the water out of the sludge without burning the organics. The residue from the
dryer is in the form of pellets. The residue from both processes are typically used on
agricultural land as soil supplement.
Virtually all sewage treatment plants the size of the RWQCP use incineration, digestion, or
drying. In the West, almost all plants use digestion, with land application of the digested
sludge. The RWQCP chose incineration 27 years ago because incineration takes less land
and produces less odor and residue. Recent studies demonstrate that another advantage of
incineration is that pathogens, and most organic pollutants in the sludge such as
polychlorinated biphenols (PCBs) and organochlorine pesticides (e.g. DDT), are destroyed
in the incinerators. Thus, when the ash from the incinerators is applied to land, itcontains
less pollutants than the residue from digestion or drying.
It is difficult to compare the environmental effects of the three options. Staff was unable to
conclude that one technology is "better" for the environment than another. All options have
certain negative environmental impacts. Each releases-different pollutants to different media
- air, land or water. Incineration produces air pollutants, consumes energy, and does not
preserve the organic material for sludge reuse. Digestion does not destroy organic pollutants,
or dioxin. Dryers consume even more energy and apparently have never been tested for
dioxin air emissions. The inability to draw conclusions is also due to the difficulty of
comparing different types of environmental releases. The pathways for the final impact
CMR: 141:98 Page 3 of 8
resulting from initial pollutant releases are numerous and difficult to trace. All three options
can meet all current environmental, health and safety requirements Therefore, staff focussed
on the following criteria in comparing the options:
¯
0
0
Cost
Land use
Visual impact
Potential odor
The table below is the comparison of the three options:
Options
Incinerator Rehab.
Plus Dryer
Digesters
Dryers
Total Cost
$11.4 million
$29.7 million
$17.2 million
Footprint
800 sf:; existing
45,000 sf> existing
1500 sf> existing
Visual Impact
Low
High
Low
Odor
Low
High
Medium
The incinerator rehabilitation, plus dryer option, will meet the current and the known future
regulations; it is the lowest cost, has the smallest, footprint, least visual impact, and least
odor. Staff, therefore, recommends the project to rehabilitate the incinerators immediately,
and to add the dryer if needed. The project will include three major elements:~
1.Repair the existing incinerators to ensure safe and reliable operation.
Relocate the emission control device to outside of the incinerator to allow full
utilization of the entire incinerator for combustion. The improved efficiency will
enable a single incinerator to take care of the varying flow most of the time, leaving
one incinerator as a reliable standby. A dryer may be installed, if the City decides to
pilot test the dryer, or when it is needed to help treat the solids.
Replace the existing emission control devices with new state-of-the-art devices to
improve the emission.
The Partners’ staff support City staff’s recommendation and have agreed to participate in a
joint financial plan entailing debt financing. City staffis presently working with the Partners
on the amendment to finance the project. Palo Alto would issue the debt, and Partner
agencies would pay Palo Alto in accordance with the amendment to the Partners’
CMR: 141:98 Page 4 of 8
agreements, which is consistent with past capital financing. The draft amendment was
prepared jointly by Palo Alto’s City Attomey’s office and outside counsel at Jones, Hall, Hill
& White. It incorporates comments from the City’s financial advisor, Stone & Youngberg:
The amendment will be presented to the Council in March 1998.
Many environmental advocacy groups (EAGs) raised the concern that a non-incineration
option may be better for the environment (CMR:356:97). In response to their concerns,
additional data was collected and a Response Study was prepared. Many of the EAGs made
the point that, if the sludge were made substantially cleaner by keeping pollutants out of the
wastewater, non-incineration technologies (principally sludge digestion or sludge drying)
would be better for the environment. The non-incineration option uses less energy, produces
less air emission, and would allow reuse of the organic matter as a soil supplement without
the current negative side-effect of putting pollutants on the soil as well, if the wastewater is
"cleaner."
While this logic is sound, it depends upon making the sludge cleaner through source control.
Staff investigated the potential for source control of key pollutants (dioxins, mercury,
organochlorine pesticides, polychlorinated biphenols - PCB ) and found that there was no
reason to assume that major reductions would occur quickly. Action items for
implementation by Palo Alto were developed, but it is not anticipated that those reductions
will be greater than approximately 20 percent. Thus, non-incineration options will continue
to have the draw-back of placing the pollutants on the soil.
For this and other reasons described in the Response Study, staff’s recommendation has not
been changed. Given currently available data, the current pollutant levels in sludge, and the
current ability to evaluate impact on the environment, staff believes this recommendation to
be the appropriate one. However, it is not at all certain that incineration should be the long
term technology of choice for the RWQCP. Air emissions, high energy use, and failure to
reuse organic matter are features of incineration that raise significant concerns about its long
term use. Therefore, staff is also recommending the development of long term goals to guide
future design work at the RWQCP. Staff is also recommending the development of specific
policies to achieve reductions of releases of mercury, dioxins, and organochlorine pesticides
to the environment. These policies will also assist staff in the long term planning that must
be accomplished for the RWQCP.
ALTERNATIVES TO STAFF RECOMMENDATION
If Council does not adopt the Negative Declaration and approve the recommendations, the
RWQCP would continue to attempt to keep the incinerators in operation. Downtime, repair
costs, and safety issues would continue to escalate. Should an incinerator fail, the RWQCP
is required by law to repair the incinerator immediately. At that time, the cost of the repair
would almost certainly be higher than the planned repair, and any work to improve the air
emissions would most likely not be implemented because of the urgency of the situation.
CMR:141:98 Page 5 of 8
With respect to the alternatives to incineration, both digestion and drying options would
have a significant affect on the environment, odor control, and visual impact. Without full
environmental review by the public, these options cannot be considered as an alternate
project. Therefore, staff would be required to restart data gathering, conceptual design and
environmental review. It would be several years before staff could return to Council with
an alternative digestion or drying option.
RESOURCE IMPACT
The capital project is estimated to cost approximately $6.2 million for the rehabilitation of
the incinerators, and $5.2 million for the dryer (in 1998 dollars). The attached cash flow
analysis (Attachment B) shows the Partners’ share of a twenty-year bond funding for the
project.
If the rehabilitation is constructed in 1999 it is estimated that the sewer rate impact to the
Palo Alto rate payers will be an increase of less than three percent.
POLICY IMPLICATIONS
The recommended project is consistent with City policies. The recommendation to establish
a process for determining long term goals will lead to the adoption of new policies.
TIMELINE
If approved, the rehabilitation of the incinerators will proceed immediately at the following
schedule:
Final design starts
Permitting
Debt financing
Bid
Construction starts
Bond Sale
May 1998
February 1999
May 1999
May 1999
August 1999
Fall 1999
ENVIRONMENTAL REVIEW
An environmental check list was prepared for the recommended project (Project). Compared
to the existing incinerators, the check list showed that the Project has no major increase in
impact. The Project will result in better emissions compared to the existing facility. There
will be some temporary impact due to construction activities that will be mitigated. A
Negative Declaration (N.D.) has, therefore, been prepared for the Project.
The N.D. (Attachment A) was distributed and notice was given to the public for review and
comments. The review period started on January 16, 1998 and ended on February 14, 19982
Staff received some questions related to the details of the design and repair. A pre-design
was performed on the Project prior to the preparation of the N.D. Final design will be
CMR: 141:98 Page 6 of 8
performed upon Council approval of the Project. The fmal design will include all the details
for the repair and the construction.
A letter was received from the League of Women Voters of Palo Alto. The letter stated that
the incinerator rehabilitation project is probably the appropriate solution at the present time,
and urged the RWQCP to continue to evaluate other options and work on the long range
plan. A copy of the letter is attached (Attachment C). A second letter (Attachment D) was
received from Bay Area Action with the following five suggestions:
1.Develop dioxin reduction policy for the City of Palo Alto, and request neighboring cities
to do the same.
2.Build a solids thermal dryer to pilot test a non-dioxin creating alternative to handling
sewage sludge.
3. Explore alternatives to safely dispose of sludge or ash which contains dioxins.
4.Educate other public agencies and the public about dioxins and provide information on
how to reduce them.
" 5, Continue to monitor the influent and effluent from the RWQCP for dioxins.
Staff believes that these suggestions can be addressed in the long-term goals and policy
development process described in staff recommendations 4 and 5.
ATTACHMENTS
A - Initial Study/Negative Declaration
B - 20 year cash flow analysis
C - Letter from the League of Women Voters of Palo Alto
D - Letter from Bay Area Action
E - November informational booklet
Response Study - A copy is available for review at the Public Works Engineering, 6th floor
counter
PREPARED BY: Bill Miks, Manager Regional Water Quality Control Plant
Phil Bobel, Manager Environmental Compliance Division
CMR:141:98 Page 7 of 8
REVIEWED BY:
GLENN S. ROBERTS
Director of Public Works
CITY MANAGER APPROVAL:\
FLEMING
ity Manager
CMR: 141:98 Page 8 of 8
ATTACHMENT A
Initial Study/Negative Declaration (IS/ND)
Palo Alto Regional Water Quality Control Plant Solids Facility Plan
City of Palo Alto
°
Project Title: Palo Alto Regional Water Quality Control Plant (PARWQCP) Solids
Facility Plan
Lead Agency Name and Address:City of Palo Alto
Public Works Department
Regional Water Quality Control Plant
2501 Embarcadero Way
Palo Alto, California 94303
Contact Person and Phone Number: Daisy Stark, PARWQCP Engineer,
650-329-2598
o Project Location: 2501 Embarcadero Way, Palo Alto, California
Application Number(s): Not Applicable
Project Sponsor’s Name and Address: City of Palo Alto, Public Works Department,
Regional Water Quality Control Plant, 2501 Embarcadero Way, Palo Alto, California,
94303
General Plan Designation: Major Institution/Special Facilities
Zoning: Public Facilities with Site Design overlay (PF(D))
Desc.ripfion of Project:
PARWQCP Background
The Palo Alto Regional Water Quality Control Plant (PARWQCP) provides advanced
wastewater treatment for Palo Alto, Mountain View, Los Altos, Stanford University, Los
Altos Hills, and much of East Palo Alto (Figure 1). The Project is located at the PARWQCP
in the City of Palo Alto at the east end of Embarcadero Way, east of Highway 101 (Figure 2).
The PARWQCP separates the solid substances from the incoming wastewater (influent)
EAST PALO ALTO
SANITARY DIST.
To San Francisco
WATER QUALITY
CONTROL PLANT
Not To Scale
San Francisco Bay
PALO
ALTO
To San Jose
PALO ALTO
Figure 1
Service Area
Palo Alto Regional Water Quality Control Plant
CH2MHILL ~
(see Figure 3). The liquid and solid portions are then treated. The .treated wastewater is
discharged via an outfall to the San Francisco Bay. The solid substance removed from the
wastewater is called sewage sludge and is treated in the solids facility of the PARWQCP.’The
solids facility includes gravity thickeners and belt presses which remove more of the water
from the sludge, two existing incinerators which bum the sludge to an ash product, and an
ash storage silo and bagging system. The ash product is trucked to the Central Valley and
applied to agricultural lands as a soil amendment.
Figure 3
Simph’Sed PARWQCP Schematic
PARWOCP
Wastewater
Wastewater
Treatment
Processes
Solids
Incineration
Treated San Francisco
Wastewater Bay
-Ash ~ Farmland
A more detailed discussion of the incineration process and the need for the Project is
provided in the following sections of this IS/ND.
4
The Incineration Process and the Need for Project
The Incineration Process
Figure 4 shows the location of the incineration building at the PARWQCP. The incineration
process, depicted graphically in Figure 5, consists of two multiple-hearth incinerators, each
with two air pollution control devices to minimize emissions into the atmosphere. The two
incinerators each consist of six hearths (separate chambers) in a vertical column where
’natural gas can be used in varying amounts to ignite the residual solids. Currently, the top
hearth in each incinerator is used as an afterburner to bum organic molecules in the stack gas
and prevent their release into the environment. In addition, each incinerator has a wet
scrubber that removes pollutants from the incinerator stack gases.
Need for the Proiect
The PARWQCP incinerators, which have been in service since 1971, have become more and
more difficult to maintain in. recent years and require frequent, costly repairs. Equipment
downtime has increased dramatically because of the frequent repairs. The chance of both
incinerators being out of service at the same time has increased to the point of causing
concerns about safe operations of the plant. The wastewater treatment plant must be able to
continuously process all incoming .sewage. Given the 24-hour-per-day, 365-day-per-year
nature of the operation, the inability to operate the incinerators would present immediate
emergency conditions and, within 24 hours, human health concerns.
Project Goals
The proposed Project involves improvements to the solids facility, and is designed to meet
the following goals:
o
Repair the two existing incinerators to ensure a safe operating environment.
Improve the efficiency of the incinerators so that only one incinerator needs to operate
at a time, leaving one incinerator as a firm, reliable standby.
Upgrade the air pollution control devices to improve the emissions of the incinerators.
5
0
Figure 5
Current Incinerator Process
Incinerator
.,~......,.~ Atmosphere
Air Scrubber
StactGas
Afterburner
Cooling Hearth
Residual
Solids ~
Air Scrubber
Stact Gas
Afterburner
Cooling Hearth
~Burning
Hearths
Incinerator
The first goal of the proposed Project is to make repairs to the two incinerators that xvill
eliminate the frequent and costly short-term repairs, greatly reduce equipment downtime,
and insure a safe operating environment for plant personnel. This will include repair of cracks
that have developed in the half-inch steel shell of the incinerators.
The second goal of the proposed Project is to provide redundancy in the incineration process,
allowing one of the incinerators to be held in reserve as a back up to deal with emergency
situations. The wastewater flow going into the PARWQCP varies daily and seasonally.
While the two existing incinerators are permitted to operate Concurrently to meet the varying
7
flow requirements, this operating mode does not allow for emergencies or repairs. Currently,
one of the incinerators is under such frequent repair that a back-up incinerator almost never
exists and urgent conditions are the norm.
To relieve these urgent conditions, two Project components are proposed. The first
component, a tree (separate) afterburner, will be constructed to allow the top hearth to be
used to burn the solids. This Will increase the throughput (the amount of solids that can be
handled by one incinerator) and will also reduce the need to run both incinerators
simultaneously. The second component, a solids thermal dryer, will be added if the City
decides to pilot test the dryer or when it is needed to help treat the solids from anticipated
population growth in the PARWQCP service area. The dryer will further reduce the water
content of some of the solids before feeding the solids to the incinerators. The drier solids are
much easier for the incinerator to handle and further decrease the likelihood that both
incinerators would have to be operated simultaneously.
The third goal of the proposed Project is to upgrade the solids facility’s air pollution control
equipment. This goal will be met with two Project components for each incinerator. First, the
new afterburners, which will help to meet the second goal, will be more efficient than the
current afterburner and will operate at a higher temperature to completely oxidize the
organics in the stack gas. Second, new two-stage wet scrubbers will be installed that capture
substantially more gases and particulate matter than the current scrubbers. Figure 6 shows the
improved incineration system upon completion of the Project.
Impact of the Proposed Proiect on PARWQCP Treatment Capacity
The proposed project will not increase the PARWQCP’s treatment capacity. The incineration
system is a component of the PARWQCP, and a modification to the incineration system
would only cause an increase in the PARWQCP capacity if it were currently the only limiting
component of the plant. The average dry weather flow to the PARWQCP in 1996 was 24
million gallons per day (MGD) from the PARWQCP’s service area of approximate 220,000
Figure 6
Proposed Incineration System
Residual
S
] Dryer I
Incinerator
2-Stage Scrubber
Afterburner
Stack Gas
Cooling Hearth
Atmosphere
2-Stage Scrubber
Afterburner I
Stack Gas
Residual
.Solids
Cooling Hearth
Ash
Farmland
Incinerator
Burning
Hearths
people. The wastewater treatment processes (as distinguished from the incineration system
shown in Figure 3) have a design capacity of 38 MGD average dry weather flow, which
could serve a population of approximately 350,000.
By contrast, the incineration system has a current approved maximum capacity of 60 dry tons
per day (DTiD) (30 DT/D per incinerator), with a 1996 usage of approximately 17 DT/D to
serve 220,000 people. The proposed Project will increase the peak capacity of one incinerator
to 32 DT/D. While it could be argued that the capacity of incinerator system would then be
64 DT/D (32 X 2 incinerators), this is not the case for two reasons. First, only one incinerator
would be operated at a time. The purpose of the project components is to insure a back-up
incinerator is ready at all times. Second, the Bay Area Air Quality Management District
(BAAQMD)Permit to Operate for the PARWQCP limits maximum throughput to 60 DT/D.
No modification to that permit is being sought. Therefore, the incinerator system capacity
would remain at 60 DT/D. This system could serve a population as great as approximately
410,000.
The incinerator capacity can support a larger additional population than the available capacity
in the wastewater treatment processes. The incineration system could serve a population as
great as approximately 410,000, while the wastewater treatment process could only serve a
population of approximately 350,000 (see Table 1). Therefore, it is the wastewater treatment
Table 1
Current Throughput and Maximum CapaCity
Wastewater Treatment
Processes
Incineration System
1996 VALUES CURRENT MAXIMUM
CAPACITY
PopulationThroughput
Average
24 MGD
17 DTD
220,000
220,000
Throughput
Capaci~
38 MGD*
60 DTD**
Approximate
Population
Equivalency
350,000
410,000
*Average
**60 DTD = Maximum Peak Daily Capacity. Average capacity associated
with this peak capacity used to determine Population Equivalency
10
processes, not the incineration system, that limit the PARWQCP’s capacity. The proposed
Project does not increase the capaci.ty of the PARWQCP. A major capital improvement
project for the wastewater treatment processes and regulatory agency approval would both be
required to increase the capacity of the wastewater.treama, ent processes and thus increase the
. capacity of the PARWQCP. Such a project is unlikely within the next several decades
¯ because the current PARWQCP capacity exceeds current demand by almost 100%, while the
anticipated growth in the service area during the 20-year life of the proposed Project is less
than 10%.
Project Approach
Following are additional details on the proposed Project components.
Repair of Existing Incinerators
The two incinerators are 18.75 foot diameter, 6-hearth furnaces. The interior of each
incinerator is lined with refractories of firebrick and insulation material. Dewatered solids are
introduced into the furnace for combustion. An ash handling system conveys the ash to a
storage silo. The repair of the incinerators, all taking place within the existing building, will
consist of the following measures:
¯Identify hot spots on the steel shell and flaws in the refractory and insulation
¯Add steel plate patches on the shell
¯Replace hearths (including flattened hearth) as needed
¯Repairer incinerator steel shells
¯Replace fans and ducting to the stack, incinerator control systems, and furnace draft
control system
¯Add new sludge feed conveyor
II
Modification of Incineration System
The modification will increase the efficiency of the existing incinerators and improve air
emissions. It will consist of the following:
¯
Construction of a new structure (possible location shown on Figure 4) immediately
adjacent to the existing building to house the new air pollution control equipment,
including an external afterburner, Venturi-Pak scrubber, and exhaust.ducting. The new
structure will be an 800 square foot addition to the existing 5,300 square foot incinerator
building. It will be about the same height as the existing building (46 feet), and will be
sheltered from the street and the public by other treatment plant structures and trees
surrounding the plant. The new air pollution control equipment will provide significant
reductions in emissions compared to current emissions.
Operational changes to use the top hearth as a burning hearth.
Installation of an equalization storage tank. The quantity of dewatered sludge to be
incinerated will vary hourly. The ability to temporarily store, or equalize, these variations
will enhance operating results, particularly at peak conditions. A new equalization storage
tank will be constructed adjacent to the south side of the incinerator building as shown on
Figure 4. It will consist of a steel storage tank with a closed top and mixers. It will be 25
feet in diameter and 30 feet tall, providing 100,000 gallons of storage. It will be sized for
the projected average annual day’s sludge production of 18.5 DT/D. The tank will be
vented to the incinerator inlet combustion air to make use of the incinerators’ new air
pollution control equipment. The height of the-tank is lower than the existing incinerator
building and the surrounding structures. It will not be visible from the street or by the
public.
Addition of a Thermal Dryer
A small thermal dryer unit would be added if the City decides to pilot test the dryer or when a
single incinerator is unable to meet peak loads during the project life (through 2020). The
purpose of the thermal dryer is to increase the dryness of sludge beyond that which can be
12
achieved with the existing beltpress dewatering. Available incinerator capacity is greater with
drier solids. The sludge dried by the thermal dryer during peak periods would be added to the
remaining dewatered sludge before incineration. The thermal dryer is expected to be operated
only sporadically during peak loading conditions, for a total of about 4 weeks during the
year. This will typically occur during the wet weather months in the winter after periods of
particularly heavy storms.
Thermal drying involves removal of moisture from the solids to a heated air stream. There
are certain issues associated with drying that can be successfully addressed with proper
design and operational procedures. The product from the dryers is organic and very dry,
which can cause dust. Since organic dust can be a source of exp!osions, thereby creating a
potential safety problem, the system will be designed and constructed with dust handling
systems that bring the level of dust down below the hazardous level and that meet all
applicable safety requirements.
Also, the dried sludge product is initially hot. If it is placed directly into a storage hopper,
there is a potential for heat buildup, which may eventually cause the pellets to catch fire. Two
measures will be included to reduce the fire hazard. First, the pellets will be cooled before
being placed in storage to reduce the fire hazard. Second, nitrogen padding of the storage
hopper air space can also be implemented as a means to reduce the fire hazard.
The proposed thermal dryer uses indirect drying, in which fuel is combusted in a boiler to.
produce steam or in a thermal oil heater to heat oil. The steam or heated oil is passed through
an indirect dryer, where hollow metal disks or paddles are heated from the inside and conduct
heat to the solids on the outside of the paddles.
The thermal drying facility can be located inside or outside the existing sludge incinerator
building. A site just north of and adjacent to the existing incinerator building, as shown in
Figure 4, has been identified for an outside location. Conveyors will be installed to transport
13
the dewatered solids to the thermal drying system from the belt presses and to return the dried
solids to the incinerator. Also, for odor control, the foul air created during the thermal drying
process will be discharged to the incinerator inlet air stream as part of the inlet combustion
air. This air eventually flows to the incinerator air emissions control system and helps in fuel
savings in incinerator operations since it is heated. The dryer unit includes abatement
equipment for the boiler, which bums natural gas to heat the dryer. If the outdoor location is
selected, the facility will be lower in height than the existing incinerator building and other
surrounding structures. It will be sheltered from the street and the public by other treatment
plant structures and trees surrounding the ialant.
California Environmental Quality Act (CEQA) Requirements
The California Environmental Quality Act (CEQA) requires that potential significant
environmental effects of a project proposed by a public agency be identified and disclosed to
the public. A significant effect on the environment is generally defined as a "substantial or
potentially substantial adverse change in the physical environment." "Environment" means
the physical conditions, including both natural and man-made conditions, that exist within
the area affected by a proposed project.
The environmental assessment for the proposed project has identified no significant
environmental effects. A Negative Declaration must include a written statement briefly
explaining why a proposed project will not have a significant environmental effect when
compared to the existing environment. It must include a description of the project and
location, identification of the project proponent, and proposed finding of no significant effect.
It must also include a copy of the Initial Study checklist that justifies the finding of no
significant effect. This Negative Declaration contains all of the required information.
14
11.Other agencies whose approval is required (e.g., permits, financing approval, or
participation agreement.)
State/Regional Agencies
Bay Area Air Quality Management
District
San Francisco Bay Regional Water
Quality Control Board
City of Palo Alto
City of Palo Alto Public Works
Department
City of Palo Alto Department of
Planning and Community
Development
City of Palo Alto Architectural
Review Board
City of Palo Alto Fire Department
Other Local Agencies
City .of Mountain View
City of Los Altos
East Palo Alto Sanitary District
Town of Los Altos Hills
Authority to Construct (A/C) and Permit to
Operate(P/O) - if grandfather status is not maintained,
then will be needed (existing facility attained
grandfather status because it was constructed before
1972, and will retain this status as long as it is not
modified in a manner that results in an air emission
increase of a regulated pollutant or the repair costs are
not greater than 50% of the capital cost of a new
incinerator)
Clean Water Act: 40 CFR Part 503 Rulesmproposed
revisions to CWA Part 503 will be incorporated into
the existing NPDES Permit; will require Continuous
Emissions Monitoring for CO and NOx along with
existing requirements for Total Hydrocarbons by 2000
Grading and Drainage Review
Building Use Permit
Site and Design Review
Architectural Review
Hazardous Materials Disclosure Checklist/Inspection
Approval and Funding
Approval and Funding
Approval and Funding
Approval and Funding
15
Environmental Factors Potentially Affected:
The environmental factors checked below would be potentially affected by this project as
indicated by the checklist on the following pages.
[]Land Use and Planning
[]Population and Housing
[]Geologic Problems
[] Water
[] Air Quality
[]Transportation/Circulation
[]Biological Resources
[]Energy and Mineral Resources
[]Hazards
[]Noise
[] Mandatory Findings of
Significance
[] Public Services
’l’-I Utilities and Service Systems
[] Aesthetics
[] Cultural Resources
[] Recreation
16
Determination:
On the basis of this initial evaluation:
I find that the proposed project COULD NOT have a significant effecton 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 the mitigation
measures described on an attached sheet have been added to the project. A.
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 significant effect(s) 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, if
the effect is a "potentially significant impact" or "potentially significant unless
mitigated." An ENVIRONMENTAL IMPACT REPORT is required, but it must
analyze only the effects that remain to be addressed..
Project Planner Date
Director of Planning & Community Environment Date
17
Evaluation of Environmental Impacts:
1)
3)
4)
6)
7)
A brief explanation is required for all answers except "No Impact" answers that are adequately
supported by the information sources a lead agency cities in the parentheses following each question. A
"No Impact" answer is adequately-supported if the referenced information sources show that the impact
simply does not apply to projects like the one involved (e.g. the project falls outsidea fault rupture
zone). A "No Impact" answer should be explained where it is based on project-specific factors as well
as general standards (e.g. the project will not expose sensitive receptors to pollutants, based on a project-
specific screening analysis).
All answers must take account of the whole action involved, including off-site as well as on-site,
cumulative as well as project-level, indirect as well as direct, and construction as well as operational
impacts.
"Potentially Significant Impact" is appropriate if there is substantial evidence that an effect is
significant. If there are one or more "Potentially Significant Impact" entries when the determination is
made, an EIR is required.
"Negative Declaration: Potentially Significant Unless Mitigation Incorporated" applies where the
incorporation of mitigation measures has reduced an effect from "Potentially Significant Impact" to a
"Less than Significant Impact." The lead agency must describe the mitigation measures, and briefly
explain how they reduce the effect to a less than significant level (mitigation measures from Section
XVII, "Earlier Analyses," may be cross-referenced).
Earlier analyses may be used where, pursuant to the tiering, program EIR, or other CEQA process, an
effect has been adequately analyzed in an earlier EIR or negative declaration. Section 15063(e)(3)(D).
Earlier analyses are discussed in Section XVII at the end of the checklist.
Lead agencies are encouraged to incorporate into the checklist references to information sources for
potential impacts (e.g. g~neral plans, zoning ordinances). Reference to a previously prepared or outside
document should, where appropriate, include a reference to the page or pages where the statement is
substantiated. See the sample question below. A source list should be attached, and other sources used
or individuals contacted should be cited in the discussion.
This is only a suggested form, and lead agencies are free to use different ones.
18
Issues (and Supporting Information Sources):
I. LAND USE AND PLANNING. Would the
proposal:
a)
b)
c)
II.
d)
e)
a)
b)
c)
Conflict with general plan designation or zoning?
Conflict with applicable environmental plans or
policies adopted by agencies with jurisdiction over
the project?
Be incompatible with. existing land use in the
vicinity?
Affect agricultural resources or operations (e.g.
impacts to soils or farmlands, or impacts from
incompatible land uses)?
Disrupt or divide the physical arrangement of an
established community (including a low-income or
minority community?
POPULATION AND HOUSING. Would the
proposal:
Cumulatively exceed official regional or local
population projections?
Induce substantial growth in an area either directly
or indirectly (e.g. through projects in an
undeveloped area or extension of major
infrastructure)?
Displace existing housing, especially affordable
housing?
III. GEOLOGIC PROBLEMS. Would the proposal
result in or expose people to potential impacts
involving:
a) Fault rupture?
b) Seismic ground shaking?
Sources
1,2
1,2
3
3
Potentially
Significant
Impact
Negative
Declaration:
Potentially
Significant
Unless
Mitigatibn
Incorporated
Less Than
Significant
Impact
No
Impact
19
issues (and Supporting Information Sources):
c) seismic ground failure, including liquefaction?
d) Seiche, tsunami, or volcanic hazard?
e) Landslides or mudflows?
f) Erosion’, changes in topography or unstable soil
conditions from excavation, grading, or fill?
g) Subsidence of the land?
h) Expansive soils?
i) Unique geologic or physical features?.
IV. WATER. Would the proposal result in:
a)Changes in absorption rates, drainage patterns, or the
~rate and amount of surface runoff?.
b)Exposure of people or property to water related
hazards such as flooding?
c)Discharge into surface waters or other alteration of
surface water quality (e.g. temperature, dissolved
oxygen or turbidity)?
d)Changes in the amount of surface water in any water
body?
e)Changes in currents, or the course or direction of
water movements?
f) Change in the quantity of ground waters, either
through direct additions or withdrawals, or through
interception of an aquifer by cuts or excavations or
through substantial loss of groundwater recharge
capability?
g) Altered direction or rate of flow of groundwater?
h) Impacts to groundwater quality?
Sources
3
3
3
1,3
3
3
1,3
Potentially
Significant
Impact
1
1
Negative
Declaration:
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
20
Issues (and Supporting Information Sources):
i) Substantial reduction in the amount of groundwater
otherwise available for public water supplies?
V. AIR QUALITY. Would the proposal:
a)Violate any air quality standard or contribute to an
existing or projected air qt~ality violation?
b) Expose sensitive receptors to pollutants?
c)Alter air movement, moisture, or temperature, or
cause any change in climate?
d) Create objectionable odors?
VI. TRANSPORTATION/CIRCULATION. Would
the proposal result in:
a) Increased vehicle trips or traffic congestion?
b)Hazards to safety from design features (’e.g. sharp
curves or dangerous intersections) or incompatible
uses (e.g. farm equipment)?
c)Inadequate emergency access or access to nearby
uses?
d) Insufficient parking capacity on-site or off-site?
e) Hazards or barriers for pedestrians or bicyclists?
t:) Conflicts with adopted policies supporting alternative
transportation (e.g. bus turnouts, bicycle racks)?
g) Rail, waterborne or air traffic impacts?
Vii.BIOLOGICAL RESOURCES. Would the
proposal result in impacts to:
a)Endangered, threatened or rare species or their
habitats (including but not limited to plants, fish,
insects, animals, and birds)?
Sources
I
1
1
1
1
1,2
1,2
1,2
Potentially
Significant
Impact
Negative
Declaration:
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
21
Issues (and Supporting Information Sources):
e)
VIII.
b) Locally designated species (e.g. heritage trees)?
c)Locally designated natural communities (ei"~. oak
forest, coastal habitat, etc.).’?
d)Wetland habitat (e.g. marsh, riparian and vernal
pool)?
Wildlife dispersal or migration corridors?
ENERGY AND MINERAL RESOURCES.
Would the proposal:
a) Conflict with adopted energy conservation"’~lans?
b)’Use non-renewable resources in ~"wasteful and
inefficient manner?
c)
b)
c)
Result in the loss of availability of a known mineral
resource that would be of future value to the region
and the residents of the State?
HAZARDS. Would the proposal’ involve:
A risk of accidental explosion or release of
hazardous substances (including, but not limited to:
oil, pesticides, chemicals or radiation)?
d)
e)
Possible interference with an emergency response
plan or emergency evacuation plan?
The creation of any health hazard"~r potential health
hazards?
Exposure of people to existing sources of potential
health hazards?
i’ncreased fire hazard in areas with flammable brush,
grass, or trees?
X. NOISE. Would the proposal result in:
a) Increases in existing noise levels?
Sources
l
l
1,2
1
Potentially
Significant
Impact
Negative
Declaration:
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
22
Issues (and Supporting Information Sources):
b) Exposure of people to severe noise levels?
Xl.PUBLIC SERVICES. Would the proposal have an
effect upon, or result in a need for new or altered
government services in any of the following areas
a) Fire protection?
b) Police protection?
c) Schools?
d) Maintenance of public facilities, including roads?
e) Other governmental services?
XII.UTILITIES AND SERVICE SYSTEMS. Would
the proposal result in a need for new systems or
supplies, or substantial alterations to the following
utilities:
a) Power or natural gas?
b) Communications systems?
c)Local or regional water treatment or distribution
facilities?
d) Sewer or septic tanks?
e) Storm water drainage?
f) Solid waste disposal?
g) Local or regional water supplies?
XII1. AESTHETICS. Would the proposal:
a) Affect a scenic vista or scenic highway?
b) Have a demonstrable negative aesthetic effect?
Sources
l
l
l
l
I
1
1
1
l
1
l
l
l
l
Potentially
Significant
Impact
Ndgative
Declaration:
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
23
Issues (and Supporting Information Sources):
c) Create light or glare?
XIV. CULTURAL RESOURCES. Would the proposal:
a) Disturb paleontological resources?
b) Disturb archaeological resources?
c) Affect historical resources?
d)Have the potential to cause a physical change which
would affect unique ethnic cultural values?
e)Restrict existing religious or sac’red uses within the
potential impact area?
XV. RECREATION. Would the proposal:
a)Increase the demand for neighborhood or regional
parks or other recreational facilities?
XVI.
a)
Affect existing recreational opportunities?
MANDATORY FINDINGS OF SIGNIFICANCE.
Does the project have the potential to 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, 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?
Sources
1
1
1,2
1,2
1,2
I;2
1,2
Potentially
Significant
Impact
Negative
Declaration:
Potentially.
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
NO
Impact
24
b)Does the project have the potential to achieve short-
term, to the disadvantage of long-term,
environmental goals?
c)
d)
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)
Does the project have environmental effects which
will cause substantial adverse effects on human
beings, either directly or indirectly?
XVII.
a)
c)
EARLIER ANALYSES.
Earlier analyses may be used where, pursuant to the tiering, program EIR, or other CEQA process, one or more effects have
been adequately analyzed in an earlier EIR or negative declaration. Section 15063(C)(3)(D). In this case a discussion should
identify the following on attached sheets:
Earlier analyses used. Identify earlier analyses and state where they are available for review.
Impacts adequately addressed. Identify which effects from the above checklist were within the scope of and adequately
analyzed in an earlier document pursuant tot he applicable legal standards, and state whether such effects were addressed by
mitigation measured based on the earlier analysis.
Mitigation measures. For effects that are "Negative Declarations: Less than Significant with Mitigation Incorporated,"
describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they
address sit¢-specifi’c conditions for the project.
XVIII. SOURCE REFERENCES
1 Palo Alto Regional Water Quality Control Plant, Solids Facility Plan, May 1997
2 Palo Alto Comprehensive Plan, 1980-1995
3 Palo Alto Comprehensive Plan Update Draft Environmental Impact Report, December 1996
4 Voice mail message from Jim Giililand (City of Palo Alto) regarding zoning, on June 24, 1997
5 Voice mail message from Jim Gilliland (City of Palo Alto) regarding zoning, on June 26, 1997
25
IXX. EXPLANATIONS FOR CHECKLIST RESPONSES
I a The proposed project is ~onsiste~t with the existing Major Institution/Special Facilities general plan designation of the
PARWQCP and the Public Facilities with Site Design Overlay (PF(D)) zoning. The PARWQCP site is bordered on the
west by one- and two-story office buildings, on the south by the City landfill, on the east by the Bay and Baylands
Nature Preserve, and on the north by the Palo Alto Airport. The Palo Alto Golf Course is also located just west of the
airport. Much of the PARWQCP site is screened from these land uses by trees along its perimeter. However, the access
road to tile landfill runs directly along the east plant boundary, so some PARWQCP facilities, such as the fixed film
reactors, are clearly visible. The proximity to the airport places height restrictions on the treatment facilities. The top
of the existing incinerators are generally considered the maximum height allowed.
1 b The proposed project does not conflict with any applicable environmental plans or policies adopted by agencies with
jurisdiction over the project.
I c The proposed project would not be incompatible with existing land use in the vicinity. Modifications to PARWQCP
facilities would be limited to the existing treatment plant site,
I d The proposed project would not impact agricultural resources or operations.
I e The proposed project has no impact on the physical arrangement of any established communities.
II a The proposed project will not cumulatively exceed official regional or local population projections. See discussion for
Issue II b below.
II b The proposed project will not induce growth directly or indirectly. See discussion on pages 5 to7 of the attached
project description.
II c The proposed project is limited to the existing treatment plant site and would not displace any existing housing..
II1 a The proposed project is not located on a fault and would not result in or expose people to fault rupture.
II1 b The Palo Alto Comprehensive Plan designates the project area to be prone to violent shaking in the event of a major
earthquake. This shaking could cause significant damage to structures if not properly designed or constructed. A
geotechnical report for the project will be prepared and the recommended design measures identified in that report will
be incorporated into the project.
Iit c Liquefaction can occur when loose, saturated, relatively clean cohesionless soils are subjected to ground vibrations.
The project area is situated adjacent to the San Francisco Bay and is underlain in part by Bay mud, an organic clay
which is soft and compressible. Sand lenses are interspersed throughout the Bay mud; these lenses carry groundwater in
the vicinity of the Bay and, during seismic events, have the potential t6 liquefy. According to’ the City of Palo Alto
Comprehensive Plan, the site has a high liquefaction potential. The geotechnical investigation to be prepared for the
9roject will identify appropriate design measures that will be incorporated into the project to address liquefaction
Issues.
111 d The proposed project would not result in or expose people to seiche, Tsunami, or volcanic hazard.
III e The proposed project would not result in or expose people to landslides or mudflows.
1II f The proposed project would not result in or expose people to erosion, changes in topography or unstable soil conditions
from excavation, grading, or fill.
III g The proposed project would not result in or expose people to subsidence of land.
III h The proposed project would not result in or expose people to potential impacts from expansive soils.
II1 i No unique geologic or physical features exist at the project site, so the proposed project would not result in or expose
people to potential impacts from unique geologic or physical features.
IV a The proposed project would be constructed on currently paved ground and would not add paved area. Hence the
proposed project would not result in’any changes in absorption rates, drainage patterns, or the rate and amount of
26
IXX. EXPLANATIONS FOR CHECKLIST RESPONSES
surface runoff.
IVb The treatment plant site is in a flood zone, as designated by FEMA. However, the proposed project would not result in
any additional exposure of people or property to water related hazards such as flooding. All applicable FEMA
requirements will be met.
IV c The air pollution control equipment in the proposed project would recycle trace amounts of metals from the scrubber
back to the tre’atnlent plant headworks. With the addition of scrubber water treatment there will be no increase in
metals in the wastewater discharged to the Bay and the adjacent Baylands Nature Preserve The wastewater discharged
will still meet permit requirements for metals.
IV d The proposed project would not change the amount of surface water in any water body.
IV e The proposed project would not change currents or the course or direction of water movements.
IV f The proposed project would not change the quantity of ground waters, either through direct additions or withdrawals,
or through interception of an aquifer by cuts or excavations or through substantial loss of groundwater recharge
capability.
IV g The proposed project would not alter the direction or rate of flow of groundwater.
, IV h The proposed project would not result in impacts to groundwater quality.
IV i The proposed project would not result in substantial reduction in the amount of groundwater otherwise available for
)ublic water supplies.
V a Construction-related emissions, such as dust (fine particulate matter, PMI0), vehicle exhaust, and equipment exhaust are
expected to occur at the facility for a period of up to 6 months. Minimal dust emissions are anticipated since the facility
has paved roads and controlled speed limits, and major demolition and grading would not occur. Some excavation will
be required to pour the foundation for the project facility, but minimal dust emissions are expected because the
construction area is relatively small (800 square feet for air pollution control equipment, about 500 square feet for the
equalization basin).
Basic dust control measures, such as watering active construction areas and water sweeping all paved access roads,
parking lots, and staging areas’, will be required by the Bay Area Air Quality Management District (BAAQMD) to
reduce any potential du~t emissions. Applying effective and comprehensive control measures during project
construction would prevent violations, of any air standards.
There will be no net increase in emissions as compared with current emission levels based on recent source test data.
Table 1 at the end of this checklist summarizes the current and future emissions associated with this project.
The project will be designed with a new air emissions abatement system that willhandle emissions from the
incinerator, thermal solids dryer, scum handling system, and feed sludge equalization tank, The Solids Facility Plan
describes in greater detail the air emissions abatement system. The proposed system will be more efficient and capable
of handling the projected solids increase, and will improve existing air emissions by reducing, on the average, metals
by 54 percent~ criteria pollutants by 48 percent, and dioxins/furans by 99 percent from current emission levels.
The project does not require an increase in truck pick-ups for ash. Therefore, there will be no increased truck traffic
emissions beyond what is currently occurring.
With operation of the new emissions abatement technology and implementation of dust control measures during
construction, the project would meet all current and known potential future air quality requirements and no significant
mr quality impacts would occur.
V b Because the project site is not located near sensitive receptors and no net increases in air emissions would occur based
on current source test data and future emission estimates, there will be no pollutant exposure to sensitive receptors.
Sensitive receptors include schools, daycare centers, hospitals, and nursing homes. The PARWQCP staffwill adhere to
27
IXX. EXPLANATIONS FOR CHECKLIST RESPONSES
proper abatement equipment installation (including scheduled shutdown of incinerators during installation), testing, and
operating procedures to minimize any potential air emission impacts to workers in the light industrial businesses near
tl~e project site.
V c The project does not include the addition or modification of major heat or moisture sQurces and would not result in a
significant alteration of air movement, moisture, temperature, or other climatic changes.
Vd
VI a
The dryer, which would only be operated only occasionally (typically maximum 4 weeks per year), is the only new
potential odor source, but is not expected to create an impact. The project will be designed to handle odor sources (i.e.,
dryer, scum handling, and feed tank) by venting the exhaust directly to the incinerator inlet air. There it will be
combusted and then sent to the incinerator emissions abatement system for added destruction of combustion by-
products. Because of this configuration, the potential for odor outside of the abatement system will not be created.
Therefore~ no additional odors will be released beyond current operating conditions. Objectionable odors are not
expected to occur.
Facility construction will have a less than significant impact on traffic. The number of trucks to haul solids by-products
(ash) will be the same as the current number, which is one truck per week. Traffic related to construction activities are
expected to be similar to the traffic that occurs during annual maintehance and rehabilitation of the Plant’s existing
systems. This could include up to 8-10 workers entering the.site per day and a limited number of trucks delivering
concrete, other materials, and equipment to the site. Traffic impacts from construction would be less than significant.
VI b The proposed project does not contain any transportation design features and would not result in hazards to safety from
design features such as sharp curves o.r dangerous intersections.
VI c Project construction activities and operations at PARWQCP would not interfere with emergency access or access to
nearby uses, nor are they expected to interfere with emergency access at the PARWQCP.
VI d PARWQCP currently has adequate parking capacity and would not add any additional employees as a result of the
project. Parking needs for construction activities would not exceed current parking needs for rehabilitation and
maintenance activities.
VIe Facilities at PARWQCP would not be expanded outside the current plant boundaries and would not be a hazard to
9edestrians or bicyclists. There are no pedestrian or bicycle paths within the PARWQCP.
VI f The project does not conflict with City of Palo Alto adopted policies supporting alternative transportation.
VI g The project would have no impacts on rail or waterborne traffic. Traffic at the adjacent airport would not be impacted
by the project construction or operation. No part of the rehabilitation or expansion would be greater in height than the
existing incinerators, which are considered the maximum height allowable to avoid impacting airport traffic.
VII a The proposed project will result in a 99.9% decrease in dioxin and furan emissions, an average 54 percent decrease in
metals air emissions, and an average 48 percent decrease in criteria pollutant emissions compared to current emissions,
resulting in a project benefit. As a result, no impacts to endangered, threatened, or rare species in the adjacent marshes
are expected.
VII b The proposed project would require the removal of one or two eucalyptus trees next to the incinerator on the
PARWQCP site. However, these trees are not heritage trees and they are less than 20 years old. They will need to be
removed with or without this project, since they pose a fire hazard due to their proximity to the incinerator chimney,
and the tree roots are invasiwe and have the potential to damage building foundations, pipes, and high voltage conduits.
VII c The proposed project would not result in impacts to locally designated natural communities such as oak forest 0r
coastal habitat.
VII d The incinerator abatement air scrubber would recycle trace amounts of metals removed from the air stream b~ick to the
plant headworks. Use of scrubber water treatment to precipitate, concentrate, and remove metals from the recycle water
will result in no increase in metals in the wastewater discharged to the Bay and the adjacent Baylands Nature Preserve.
This is a mitigation measure to prevent discharge of the metals to air or water. The wastewater discharged will still
28
IXXo EXPLANATIONS FOR CHECKLIST RESPONSES
VII e
Vllla
VIII b
VIII c
meet permit requirements for metals. As a result, no impacts to wetland habitat are expected.
The proposed project would be located on the existing PARWQCP site and would not result in impacts to wildlife
dispersal or migration corridors.
The proposed project would not conflict with adopted energy conservation plans.
Through the rehabilitation measures, the proposed project would result in greater fuel efficiency (i.e., less fuel use per
unit of sludge processed) compared to current efficiency. The proposed project would not use non-renewable resources
in a wasteful and inefficient manner.
The proposed project would not result in the loss of availability of a known mineral resource that would be of future
value to the region and to the residents of the State.
The thermal dryer may present a small risk of accidental’ ’explosion or fire. However, the proposed project would be
designed with safety measures including proper dust handling systems to reduce explosion potential, and nitrogen
padding of the storage hopper air space to reduce fire hazard. With these design measures, the potential impacts are
expected to be less than significant. .
IX b The proposed project would not interfere with an emergency response plan or emergency evacuation plans.
IX c The proposed project will result in a 99.9% decrease in dioxin and furan emissions, an average 54 percent decrease in
metals air emissions, and an average 48 percent decrease in criteria pollutant emissions compared to current emissions
from the incinerators, resulting in a project benefit. As a results the project will result in no new impacts to health. "
IX d Neither the proposed project nor the PARWQCP create metals; any metals emissions result from metals in the plant
influent. However, the metals,, primarily mercury, that would be removed by scrubber water treatment discussed in
Vlld may need to be recycled or handled as a hazardous waste. Amounts that would be removed would be small and
are estimated to be approximately 0.1 Ib/year for the lightest metals and approximately 30 Ib/year of the heaviest
metals. Metals resulting from scrubber water treatment would be handled properly in accordance with all applicable
and stringent local, state, and federal regulations that govern the use, storage, and disposal of such materials. As a
result, no significant impacts are expected.
IX e The proposed project area does not contain flammable brush, grass,’or trees, and the proposed project would ngt
increase fire hazard in areas with flammable brush, grass, or trees.
X a The proposed project may result in short-term increases in existing noise levels associated with qonstruction activities.
However, the impacts are expected to be minor and not noticeably different than current noise associated with
rehabilitation and maintenance activities. No sensitive receptors are located near the project area. Therefore, impacts
to existing noise levels are expected to be less than significant.
X b The proposed project would not result in exposure of people to severe noise levels.
XI a The proposed project Would not affect or result in a need for new or altered fire protection services.
XI b The proposed project would not affect or result in a need for new or altered police protection services.
XI c
XI d
The proposed project would not affect or result in a need for new or altered schools.
The proposed project consists of rehabilitation and modifications to a public facility (a po’rtion of the PARWQCP).
The rehabilitation and modifications are expected to improve the operations and reduce the maintenance needs of the
solids handling facility. As a result, the proposed project would not affect or result in a need for new or altered
maintenance of public facilities.
XI e The proposed project would not affect or result in a need for any other new or altered governmental services.
XII a The proposed project would not result in a need for new systems or supplies of or substantial alterations to power or
natural gas utilities.
29
IXX. EXPLANATIONS FOR CHECKLIST RESPONSES
XII b
XII c
The proposed project would not result in a need for new systems or supplies of or substantial alterations to
communications systems.
The proposed project would not result in a need for new systems or supplies of or substantial alterations to local or
regional water treatment or distribution facilities.
The proposed project would not result in a need for new systems or supplies of or substantial alterations to sewer or
septic tanks.
XII d
XII e The proposed project would not result in a need for new systems or supplies of or substantial alterations to storm water
drainage.
XII f The proposed project would not result in a need for new systems or supplies of or substantial alterations to solid waste
disposal,
XII g The proposed project would not result in a need for new systems or supplies of or substantial alterations to local or
regional water supplies.
XIII a The proposed project would not affect a scenic vista or scenic highway.
XIII b The proposed project would not have a demonstrable.negative aesthetic effect. The new facilities would be within the
~xisting plant boundaries and would not be visible to the general public. New structures would be attached or adjacent
to existing structures, would match existing exteriors, would be the same as or lower in height than the existing
structures, and would be sheltered from view by other existing structui’es in the plant and by trees that surround the
plant.
XIII c The proposed project would not create light or glare.
XIV a The proposed project would be located on the existing PARWQCP site and would not disturb paleontological "
resources.
XIV b The proposed project would be located on the existing PARWQCP site and would not disturb archaeological resources.
XIV c The proposed project would be located on the existing PARWQCP site and would not affect historical resources.
XIV d The proposed project would not have the potential to cause a physical change which would affect unique ethnic cultural
values.
XIV e The proposed project would not restrict existing religious or sacred uses within the. potential impact area.
XV a The proposed project would not eliminate any existing parks or recreational facilities and would not induce growth in
the region. As a result, the proposed project would not increase the demand for neighborhood or regional parks or
other recreational facilities.
XV b The proposed project would not affect existing recreational opportunities.
30
Table 1: Current and Future Emissions, PARWQCP Incinerator Rehabilitation
Pollutant Current Emissions
(ib/day)
Criteria Pollutants
Carbon monoxide
.Nitrous Oxides
Sulfur oxides
THC
Particulate matter
Volatile Organic Carbons
Hazardous Air Pollutants
Dioxin
Furans
Metals
Arsenic
Beryllium
Cadmium
Chromium
Copper 1.23 x
Manganese 9.01 x
Mercury
Nickel
Selenium
Zinc
I 16.98
87.96
52.99
2.16
16.2
0,54
2.34 x 10-8
1.03 x 10-7
4.51 x 10-3
4.33 x 10-6
1.53 x 10-2
2.34 x 10-3
10-2
10-3
4.15 x 10-2
2.34 x 10-3
8.47 x 10-3
6.49 x 10"1
Emissions After Incinerator
Rehabilitation
(Ib/day)
22.64
37.07
1.55
1.45
12.95
0.53
2.17 x 10"11
9.50 x 10"11
3.48 x 10-3
3.98 x 10"6
4.11 x 10-3
5.37 x 10-4
1.18 x 10-2
3.52 x 10-4
4.05 x 10-2
2.96 x 10-4
3.69 x 10-4
1.64 x 10"1
AulhoriD’: Public Resources Code Sections 21083 and 21087.
Reference: Public Resources Code Sections 21080(c). 21080. I. 21080.3, 2 i 082. I, 2 i 083, 21083.3, 2 i 093:21094. 21151;
Sundstrom v. County of Mendocino, 202 Cal. App. 3d 296 (1988); Leonoffv. Monterey Board of Supervisors, 222 Cal. App. 3d 1337 (1990)
31
ATTACHMENT B
ATTACHMENT C
February 4, 1998
Palo Alto City Council
250 Hamilton Avenue
Palo Alto, CA 94301
Dear Mayor Rosenbaum and members of the City Council:
The League of Women Voters of Palo Alto supports comprehensive measures to
provide maximum protection to human health and the environment from the adverse
effects of hazardous materials. Because certain hazardous materials are associated
with the treatment and disposal of sewage sludge, we have some concerns about the
proposal to repair and improve the existing sewage sludge incinerators at the Palo
Alto Regional Water Quality Control Plant.
The proposed solution to the problem of how to handle the sludge from sewage
treatment when the present incinerators are on the verge of breaking down, may not
be the best solution from an environmental perspective, but when space requirements,
time, and cost are considered, it is probably the appropriate solution at the present
time.
We are concerned that the performance figures presented in the EIR are estimates and
projections that may have no relation to how the rehabilitated incinerators, with the
addition of an afterburner and new scrubbers, will actually work. If you approve this
proposal, we believe it is imperative that you include a regular and frequent monitoring
program to ensure that the system is working as well or better than advertised.
Although the dryer is included in the negative declaration, it appears that the addition
of this dryer needs more study to avoid safety problems and will not be added to the
system unless volume makes it necessary. However, there is a possibility that the
addition of such a dryer could act as a pilot project for possible elimination of the
incinerators in the future. This idea should be considered in deliberations over a long
range plan.
The repaired system and the existing treatment plant are expected to last less than
¯twenty years. In the context of planning for major changes, that is not a long time. It is
not necessary to wait twenty years to make changes; the establishment of long range
environmental goals and the search for more effective ways to recycle the sludge
should be an ongoing process. We encourage you to instruct the staff of the Regional
Water Quality Control Plant to begin now to work on a long range plan for waste water
management that will meet the needs of the area in an environmentally friendly way.
We commend Phil Bobel and his staff for the efforts they made to meet with local
citizens to try to address the concerns of those who are worried about the effects of
incineration. Dioxin production is a major concern. The staff was able to show that so
much dioxin comes into the plant in the waste water (from toilet paper, laundry water,
human waste, etc.) that the proposed system will actually reduce the total dioxin level,
even though some new dioxins will likely be produced in the incinerator. We hope this
reduction will be true.
The League of Women Voters of Palo Alto believes that the public has the right to
know the potentially harmful effects of materials they encounter in the home, the
workplace and the community, and so encourages you to help educate them in ways
to reduce toxins in waste water. We also encourage you to include citizens in the
planning and decision-making processes of hazardous material management.
Sincerely,
Ruth Lacey Geri Stewart
Co-Presidents, League of Women Voters of Palo Alto
cc:Phil Bobel, Manager, Environmental Compliance D’ivision, PARWQCP
Daisy Stark, Engineer, PARWQCP J
main telephone no.
6yo.3:zz.x994
facsihlile 650.321.1995
Schools Group 650:325.5680
Palo Alto City_Council
City, Hall
250 Hamilton Ave.
Palo Alto, CA 94301
P E 0 P L[FOR TH~ENVIRO HMEHT
_ ATTACHMENT D
’715 Colorado Avenue. Suite 1
Palo A|to. Celifornia 94303-3913
email b,~action ~’ig c.or~
http:l/www.beaction.org
x
Feb. 13, 1998 ),, "\,
Dear City Council,
On February 23, ~alo Alto City Council i’s scheduled to consider the "WQCP. Solids Management t~roject.’’ Bay Area Adtion and
a number of other local environmental groups iri conjuction with City staff, have been reviewing the proposed plan to repair.the,
incinerators at the Palo Alto Regional Water Quality Control Plartt (RWQCP). According tO reports prepared for the RWQCP, as
wlell as numerous other supporting documents, there are serious health and environmental co.ficterns~associated With dioxins ’
contained in both the influent and effluent of the plant that need the due consideration of the Council before the~ make a decisirn ,
about this projec~t, r ....
.According to "Dioxins Source Identification," a report written for the RWQCP in ~ept. 1997, dioxin~ enter the RWQCP througli
the following sources: laundry graywater, storm water, human waste, shower water, and toilet paper. The, incineration of the..’
sludge destroys some of the dioxins coming into the plant, but also creates more in the burning pr.ocess. The city staff estimates
that thee incinerators release hal~as many dioxins intothe environment as come into the plant from the abovementioned soui’ces;
however, there is a high level of uncertainty of how ma~iy dioxins re-form after being released into thd air, which may~skew~ this
approximation. Dioxins are also released from the inginerators through the water effluent and through tile ash.’The water effluent
pollutes the bay,’ and the ash is shipped to the Central Valley’and used in agricult~e, thus completing the circle of, c~ntaminating
our food supply.
Dioxins are a highly toxic by-product created frbm the production and mcmeratmn of chlonne-containing products,°sucfi as
organochlorine pesticides, polyvinyl chloride’(PVC) plastics, and polychlorinated biphenyls (PCBs)."’ Dioxins are dangerous to~
humans and wildlife because they bioaccumulate in fatty tissue. "In humans, dioxins have been shown to cause cancer, weaken
the immune system, and interfere with the endocrine system, which is ’responsible for making hormones needed, to regulate bodily
functions, including sexual de~’elopment and fertility.’a We highly recohamend that the council eeviewthis document hs well as ¯
the-"Dioxins Polluti, on Prevention Plan," w.hich was prepared for the RWQCP in October 1997 before th~ Feb. 23 council ...
meeting. Both docurhents elhcidate the necessity to reduce the amount of dioxins going to and coming from the RW(~CP. ’
\
In addition to the sources of dioxins directly affecting the RWQCP, ~i9% of dioxins emitted locally come from diesel-fueled’
motor vehicles, and another 15% from residential wood burning. Although the~e sources fall outsid~ the scope of the.WQC16
Solids Manage.ment Project, we request that the council take a comprehensive approach to addressing how to reduce the ~imount
ofxlioxins in our environment. Some suggested approaches are as ,follows:’ "’
Develop a &oxms reduction pohcy for the.C~ty of Palo Alto, and request neighboring c~t~es to do the same
Build a sohds thermal dryer to pdot test a non-dioxm creating alternatwe to handhng sewage sludge
~ Explore alternatives to safely dispos~ of sludg~ or’ash whidh contain dioxins .Educate other p~bli~ agencies and the public abou2"~dioxins and provid~ information how to ~:educe them
¯Continue to monitor the ~nfluent and effluent from the RWQCP for.dioxins , ,,
I
Please give this serious issue your full consideration.
Thank you’, ’
Susan Stansbury ¯
l~ay Area,Action.
Executive Director
,-
~ EIP Associates. 1997. Dioxins Source ldentificat~o’n2 Ibid. ’
PALO ALTO REGIONAL WATER QUALITYCONTROL PLANT
SOLIDS FACILITY PLAN
INFORMATIONAL PACKET
UPDATED NOVEMBER 1997
The RWQCP provides treatment fo~ :the sewage from the Cities of Palo Alto, Mountain
View, Los Altos, East Palo Alto, the Town of Los Altos Hills and Stanford University.
The RWQCP, which must process continuously all incoming sewage, operates two
existing incinerators. Because incinerators occupy much less space than other sludge
treatment technologies, the incineration technology was selected when the plant was built
in order to preserve the wetlands. These incinerators are vital to the proper treatment of
the sludge, which is the solid substance of the sewage.
The two incinerators are showing signs of age after 26 years of operation. Inspection of
the incinerators found localized areas of bulging in the incinerator steel shell, cracks in the
shell, deterioration in the thickness of the shell, and flattening of the hearth of the
incinerator. The hearth is the internal structure in which incineration actually takes place.
As the hearth flattens, the design forces holding it together are reduced and the hearth
could ultimately collapse. The sludge before incineration is classified as raw sludge and
is not suitable for disposal in landfills. The incinerators are the RWQCP’s only means to
treat and prepare the sludge for proper disposal.
The Solids Facility Plan was prepared to assist the RWQCP in providing reliable, safe,
cost effective, and environmentally sensitive treatment and management of the sludge.
The Solids Facility Plan was completed in May 1997 and identified a project to rehabilitate
the two existing incinerators at the RWQCP.The incinerators need immediate
rehabilitation to allow safe and reliable operation.
The project to rehabilitate the two existing incinerators will include the following:
Repair the incinerators
Improve the emissions of the incinerators
Improve the efficiency of the incinerators
The project does not increase the RWQCP sewage treatment capacity, and will not
increase the RWQCP currently permitted total sewage sludge incineration capacity. In
the next ten to fifteen years, a heat dryer may be needed to pretreat the sludge prior to
incineration, and is therefore part of this project.
The project will allow the RWQCP to provide reliable and safe treatment for the sludge,
while reducing the emissions.
The iO.S.-Environmental Protection Agency (EPA) is proposing new standards (the
"California Toxics Rule") for San Francisco Bay south of the Dumbarton Bridge (the South
Bay). The discharge standards for the RWQCP may. change pending on the development of
the Toxics Rule. The RWQCP and other stakeholders have proacfively formed the Santa
Clara Basin Watershed Management Initiative to prepare a plan to manage beneficial uses
of the South Bay for drainage and ireated water discharge. Part of the p!an is to determine
acceptable pollutant~ ioadings to the South Bay from the RWQCP and other plants.
Information fro~m the watershed management initiative wil! provide feedback to EPA to help
in the Toxi(s Rule making. ~It is anticipated that EPA will take many months or even a year
or more to finalize the Toxics Rule.
The RWQCP expects to begin planning for the next generation wastewater and solids
management system in the next 3 to 5 years. The first step of the RWQCP’s planning is
to establish long term goals. As part of this goal setting process, the City will be identifying
long term objectives -- socioeconomic, health and safety, regulatory, and environmental.
From these objectives can flow an examination of alternatives and selections of programs
and facilities. Future alternatives will encompass both programmatic and engineering
concepts in source control, reuse, secondary treatment modification, post secondary
treatment, and solids management.
The RWQCP, constructed in 1969, is planned to operate through the year 2020. At that.
time the existing facility is expected to be retired and a new wastewater treatment system
put in. op¢ration. The City envisions that the wastewater system of the future must
respond to the environmental and socioeconomic concerns in Palo Alto, the plant’s service
area, ~ind the Bay Area. In effect, the system will become increasingly consistent With the
concept of sustainability in the future.
In order to adequately plan and design our future sygtem, we need to develop a process
that will review and set the policies and missions for the RWQCP. The process will
include goal setting, research, buy-ins, institutional and regulatory arrangements, and
policy setting that will lead to the final planning and design. During the course of this
long range plan, various components within the plant will need major rehabilitation or
modifications as the plant continues to age. The Solids Facility Plan forms a bridge
toward the long range plan. Major changes in plant design are not being made until the
long range plan can be completed.
5
Enviromnental advocacy organizations have suggested a number of specific goals for
the RWQCP:
o
o
o
o
o
o
o
Eliminate incineration
Eliminate use of chlorine
Use of bio-solids for beneficial uses within the plant’s service area
Expand pollution prevention programs to reduce introduction of pollutants into
the wastewater
Maximize composting of kitchen waste
Maximize composting of toilet waste
Maximize reuse of treated wastewater from the RWQCP
These and other possible goals will be evaluated as part of the development of the long
range plan.
6
The staff at the RWQCP is dedicated to protecting the environment. In past years, we
have successfully established partnership with the communities and businesses we serve
to clean up the South Bay while balancing our budget. We will continue our efforts as
environmental steward to seek the means to achieve the goals of the RWQCP. Our current
goals include:
¯Reduce water, materials, and energy usage
¯Reduce quantities of wastewater incoming to the plant
¯Prevent pollution by reducing toxic compounds in the incoming wastewater
¯Reduce use of chemicals in wastewater treatment or solids handling
°Reduce pollutant emission
°Increase beneficial reuse options for byproducts, including wastewater and solids
°Support local reuse of bio-solids, treated water, and grey water
¯Provide cost-effective treatment
7
The goals for the RWQCP must be presented to Council for review and approval. Goal
setting needs to be accomplished so that the appropriate alternatives are adequately
researched. The alternatives selected for the RWQCP should be tested and evaluated for
technical soundness, environmental safety, and economic feasibility. A process needs to
be in place to ensure that:
the interest and health of the communities and the
addressed
sufficient time is allowed for each phase of planning
all sectors of the communities are represented
environment are
Proper planning for an environmentally, technically, and socioeconomically sound future
is a time consuming process. Duringthe long term planning process, there will be interim
projects that must occur within the RWQCP to maintain the sewage treatment services to
the communities. Long term goals need to be established for the RWQCP so that the
interim projects are consistent with the future plant design.
RWQCP LONG TERM PLAN
Note: This preliminary time line is intended to show the relationships
and the scales of events only, it is not an official time line.
SOLIDS FACILITY PLAN
PLANNING
DESIGN
CONSTRUCTION
DISCHARGE STANDARDS
RWQCP PERMIT RENEWAL
WATERSHED MANAGEMENT INITIATIVE
CALIFORNIA TOXICS RULE
LONG TERM PLAN
ADOPT A PROCESS
GOAL SETTING
RESEARCH AND TESTING
DEVELOP PLAN
INSTITUTIONAL & REGULATORY DEVELOP’T
ENVIRONMENTAL REVIEW
I
!.; ; ,i i
t
Printed: 11/12/97
Page 8
Milestone A
Fixed Delay
Summary
Slack