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HomeMy WebLinkAbout1997-08-07 City CouncilCity of Palo Alto City Manager’s Report TO:HONORABLE CITY COUNCIL FROM:CITY MANAGER DEPARTMENT: PUBLIC WORKS DATE:AUGUST 7, 1997 CMR:356:97 SUBJECT:REGIONAL WATER QUALITY CONTROL PLANT SOLIDS FACILITY PLAN - ENVIRONMENTAL CONCERNS RECOMMENDATIONS This is an informational report summarizing the concerns and comments that environmental advocacy organizations have raised with the proposed Solids Facility Plan for the Regional Water Quality Control Plant (RWQCP). POLICY IMPLICATIONS Several environmental advocacy organizations have raised concerns with the staff proposal to rehabilitate the existing sludge incinerators at the RWQCP. The alternatives involve switching to one of several non-incineration technologies. Staff will bring forward the environmental impact analysis and cost comparison of the alternatives in December 1997 for a final policy decision. The purpose of this report is to alert Council to the issues being raised. EXECUTIVE SUMMARY The RWQCP’s two sludge incinerators are over 25 years old and have become very difficult to maintain and operate. Cracks which have developed in the incinerator walls, and other problems, have made the sludge management project the top priority for the RWQCP. Analysis of alternatives began in 1994 and resulted in the Solids (Sludge) Facility Plan forwarded to Council on May 12, 1997 (see attached CMR:236:97). The project recommended by staff is to rehabilitate the incinerators. The other principal alternatives would use relatively low temperature technologies (biological digestion or drying) to treat the sludge. The end product (either ash or treated sludge) of all alternatives would most likely be used as a soil amendment/fertilizer. Rehabilitating the incinerators was the alternative chosen by staff, principally because of its lower estimated cost. The rehabilitation project cost was estimated to be $11.4 million vs $17.2 million for drying and $29.7 million for digestion. All alternatives would be designed to meet all current environmental regulatory requirements. CMR:356:97 Page 1 of 3 A number of environmental advocacy organizations have expressed concerns about the staff proposal and have submitted detailed comments on the Solids Facility Plan (Attachment C). A series of meetings have been held between staff and environmental groups. The environmental groups are questioning continuing the use of incinerators to burn sludge. Their principal concerns with incineration are air emissions, especially dioxins, and the destruction of organic matter which could otherwise be used to augment soil. Dioxins are of concern because they are the most toxic compounds known, and are present in sewage, sewage sludge, incinerator emissions, and truck exhaust. Dioxins are therefore important in analyzing each alternative. Many of the concerns and questions require more data gathering and analysis which is now under way. The following are the key questions now being explored: What are all of the environmental impacts of the principal alternatives? Will alternatives to diesel trucks that will produce less air pollution be available to haul sludge products to agricultural land? Can the City further control pollutants at their source and get the sludge cleaner than it is now? Can the City market a cleaner sludge for soil augmentation, produce more income, and change the economics presented in the Solids Facility Plan? What are the air emissions and operational difficulties associated with low temperature drying of sludge? How does this project relate to appropriate long-term environmental goals for the RWQCP? Staff intends to bring the new information, the appropriate CEQA documentation, and fmal recommendation back to Council in December 1997. The project schedule (Attachment D) has been extended by three months to gather and analyze the new information. The work will be completed by RWQCP staff, consultants, and environmental advocacy organizations, as shown in the "Solids Facility Plan Tasks" (Attachment E). The Palo Alto City Council will be asked to certify the CEQA documentation in December 1997 and forward it to the Partner cities for their use. This will be the second time that the Solids Facilities Plan will have been considered by Council. Following action and appropriate CEQA consideration by the Parmer cities, the matter will return to the Palo Alto Council for final project approval. FISCAL IMPACT The alternatives analyzed in the Solids Facility Plan range from a total project cost of $11.4 million for incinerator rehabilitation to $29.7 million for digestion. The analysis currently under way could result in changes to those figures. CMR:356:97 Page 2 of 3 ENVIRONMENTAL ASSESSMENT The CEQA documentation associated with the project is currently being prepared and will be forwarded to Council for certification in December 1997. ATTACHMENTS A - CMR:236!97 B - Letter from Glenn Roberts dated 7/8/97 ’ C - Letters from Environmental Advocacy Organizations dated 6/27/97 D - Project Schedule (7/25/97) E - Solids Facility Plan Tasks PREPARED BY: Phil Bobel, Manager, Environmental Compliance Division DEPARTMENT HEAD REVIEW:/-GLENN S. ROBERTS - Director of Public Works CITY MANAGER APPROVAL: EI’~IILY HARRISION Assistant City Manager CMR:356:97 Page 3 of 3 ATTACI-IMENTA City of Palo Alto City Manager’s Report 7 TO:HONORABLE CITY COUNCIL FROM:CITY MANAGER DEPARTMEN~r: Public Wor’ks AGENDA DATE: MAY 12,1997 CM~:236:97 SUBJECT:POLICY DIRECTION FOR THE SOLIDS FACILITY PLAN FOR THE REGIONAL WATER QUALITY CONTROL PLANT REQUEST This report requests that Council accept the Solids Facility Plan (Plan) and direct staff to make the necessary preparations to implement the Plan for the Regional Water Quality Control Plant (RWQCP). RECO~’EVIE .NDATIONS Staff recommends that Coundil: Accept the Plan and its recommendation of a two-phase project to rehabilitate the existing incinerators immediately and to add a dryer for peak loads if and when needed, potentially in ten years’ time. Direct staff to proceed with the financial planning to implement the first phase of the recommended project of the Plan. Funding for the second phase will be deferred until needed. Direct staff to prepare the amendment to. the Partners’ agreement to formally obtain Partners’ approval of the project, and their agreement to pay their proportionate share of the project costs. Direct staff to report back to Council for approval of the signed amendment, the financial package, and approval of the projects when the preparations are in place. ~CATIONS The recommendations in the Plan do not represent any change to current City policies. CMR:236:97 Page 1 of 4 EXECUTIVE SUM3,IARY The RWQCP provides advanced wastewater treatment for the cities of Palo Alto, Mountain View, Los Altos, the Town of Los Altos Hills, East Palo Alto, and Stanford University. The Solids Facility Plan is the RWQCP’s road map for the next twenty years to manage the sewage sludge in an economical and enviromflentally sensitive way. Sludge is the solid material removed from the incoming wastewater. The RWQCP removes and treats approximately 40 tons of sludge each day in its incinerators. There are many issues concerning the aging incinerators that prompted the RWQCP to initiate the Plan. These issues were higNighted in previous reports and informational reports. The latest updated informational booklet was di.stributed among the Partners in March this year. A copy of the booklet is attached to this staff report. 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 alternatives for handling the sludge, and narrowed down the number of feasible alternatives. The recommendation of the feasibility study formed the basis of the second study, the Plan. The Plan has been conducted according to a decision analysis process. The goal of the decision process is to build a consensus among the stakeholders and to include the values and priorities of all affected parties in evaluating the alternatives. Staffs of the Partner agencies worked with the RWQCP staff as technical advisors to the Plan. Informal meetings were conducted ’ with focus groups to discuss issues of concern. The Plan focused on six solids treatment options. The options were evaluated from an overall "cradle-to-grave" perspective as to the environment, cost, energy, and resources. One treatment option was dropped from consideration because it will not meet the capacity requirement for the next 20 years. The costs of the remaining five options range from $11.4 million to $29.7 million in 1998 dollars. The recommended solids facility includes a two-phase project at a total cost of $11.4 million to rehabilitate the existing incinerators immediately and to add a dryer for peak loads when needed, probably in ten years time. A copy of the executive summary of the Plan is attached. The recommendation was made because of the following reasons: The pollutant emissions of the recommended facility will be either lower than or the same as the current emissions. The recommended facility meets all current and known potential future air quality requirements. CMR:236:97 Page 2 of 4 The recommended facility has the advantage of destroying PCBs and pesticides. other options utilizing digestion and heat drying do not. The The recommended project is the lowest in total cost, and the non-economic benefits gained by choosing the more expensive options do not seem to merit their additional cost. Staff met with Partner agencies to discuss the recommendation and the funding options. Partner staffs support the recommendation of the Plan and prefer to participate in a joint financing plan that would pay for the project via the issuance of debt. FISCAL ~IPACT The Plan recommended a two-phase project costing approximately $6.2 million in 1998 and approximately $6.7 in the year 2009. A cash flow analysis was prepared for the life of the project which assumed funding the project by revenue bonds. The estimated annual payment for the bonds for each Partner agency is tabulated in the March informational booklet. Due to the complexities and time involved in arranging the funding for a joint project, the financial plan will need to proceed immediately. Amendment to the Parmers’ agreement is also needed to arrange for the Partners to assume their proportionate shares of the project costs. Such an amendment will require a rate increase in the future. Proposition 218, the "Right to Vote on Taxes" initiative, passed by voters in November 1996, appears to cover wastewater rate increases to residents and businesses in Palo Alto, to the extent wastewater charges fit within the ambig~aous definition of "property related fees" in the proposition. Part of staff’s eventual work with bond counsel and rating agencies, when this project is ready for the sale of bonds, is to determine the extent to which the bonds’ ratings may be impacted by Proposition 218. ENVIRONMENTAL ASSESSMENT The Plan recommends the rehabilitation of the existing incinerators that will result in emissions either at the same level or lower than the current emissions, hence would not trigger a new source permit. The cost of the rehabilitation is substantially lower than the cost of new replacement incinerators. The recommended project is a repair project of an existing facility that could be categorically exempt from CEQA either under Section 15301 or Section 15302. The project will be submitted to the Planning Department for determination. Planning Department’s determination on the project’s environmental impact will be submitted to Council when staff returns to Council for project approval. CMR:236:97 Page 3 of 4 ,~TTACI-IMENTS March 1997 Informational Booklet Executive Summary of the Solids Facility Plan PREPARED BY: William Miks, Manager, Water Quality Control Plant DEPARTMENT HEAD REVIEW: CITY MANAGER APPROVAL: GLENN S. ROBERTS Director of Pu~~ orks E FLEMING Manager CMR:236:97 Page 4 of 4 ATTACHMENT B City of Palo Alto Public Works Department July 8, 1997 Greg Karras Commuhities for a Better Environment 500 Howard Street, Suite 506 San Francisco, California 94107 Dear Mr. Karras: DM.sions Adrninistmtion 415.329.2373 415.329.2299 Fax 415. 329.2151 415.329.2299Fax Environmental Compliance 415.329.2598 415.494. 3531 Fax Equipment Management 415.496.699-2 415.496. 6958 Fax Facilities Management 415.496. 6900 415.496.6958 Fax Operations 415.496.6974 415.496. 6924 Fax Regional Water QualityControl 415.329.2598 415.494.3531 Fax Thank you for your June 27, 1997 letters concerning the Solids Management Plan for our sewage sludge incinerator. Let me assure you that I amwell aware of the status of the project. Implementing a solids management plan quickly is of critical importance to Palo Alto and its partner cities because of the age and condition of our incinerators. Our consultants have analyzed the currently available, altematives for solids handling and the consultants concluded that the most cost effective alternative is to rehabilitate the incinerators, enhance the air pollution control equipment, and plan for the addition of drying capacity to handle future peak loads. However, we are carefully reviewing the details of your letters, and my staffis meeting with you to insure that we understand the additional data which you and others feel should be collected. Once we have analyzedthis information, we will be able to respond to your detailed suggestions. Sincer.ely, 4~J~S. Roberts~ Director of Public Works GR/PB/maa RWQCP Partners’ City Representative Trish Mulvey and Emie Goitein, CLEAN South Bay Sydney Brown, Northern California Interfaith Council Ted Smith, Silicon Valley Toxics Coalition Laurie Mueller, Peninsula Conservation Center Foundation Julia Bott, Loma Prieta Sierra Club Peter Evans, Ujima Security Council P.O. Box 10250 Palo Alto, CA 94303 I:W HIL~CIN ERA~dlRAS.LTR California Exposure Alliance Asian Pacific Environmental Network Breast Cancer Action California Communities Against To~ics California Nurses Association California Public Interest Rasaarch Group (CalPIRG) Charlotte Maxwell Complementary Clinic Chester Street Block club Association Clean Water Action Commonweal Cock, unities for a Better Environment (CBE) co~mnulities for a Safe Environment (CSE) Desert Citizen~ Against Pollution Ecology Center Endometriosis Association Environmental Nealth Coalition Environmental Working Group Friends’of Rose Drive GABRIELA (Philippines} Greenpeace INOCHI/Plutonium Free Future Women’s Network Impart, Inc. Madras del Este de Los Angeles, Santa ~sahel Marin Breast Cancer Watch Mothers and Others Pesticide Action Network Physicians for Social Responsibility Bay Area Chapter Political Ecology Group PUEBLO - People United for a Better Oakland Resource Renewal Group San Francisco Bay Advocates for Environmental Rights| (SAFER|) San Francisco BayKseper Santa Clara Center for Occupational Safety and Nealth (SCCOSH) Save San Francisco Bay Association Shoreline Environmental Alliance (SEA) Southeast Alliance for Environmental Justice (SAEJ) Silicon Valley Toxics Coalition Toxic Links Coalition UJlma Security Council United Anglers of California West County Toxics Coalition West Valley Citizens Air Watch Women’s Cancer Resource Center Workers Acting Together Zor Change (WATCN} June 27, 1997 Glenn Roberts, Director of Public Works City of Palo Alto P.O. Box 12050 Palo Alto, CA 94301 ATTACHMENT C Update to Water Quality Control Plant partners - technical assistance request on sewage sludge incinerators Dear Mr. Roberts: We are writing you and other partners of the Regional Water Quality Control Plant, to inform you of the status of our continuing discus- sions with Palo Alto staff regarding two sludge incinerators at the Plant. We are concerned about the proposal to fund incinerator reha- bilitation. Instead, we have asked Palo Alto to explore alternative options before making a decision. Before committing $11 million over twenty years, we have asked Palo Alto for $50,000 for technical assistance and an additional four months to explore alternatives to sludge incineration that appear to be better for our environmental health and may, in fact, be cheaper. Exploring the option of potentially using the Plant’s 20 ton-per-day sludge output as a marketable and valuable resource to be sold instead of burned may be a more attractive and cheaper solution. Indeed, in other communities, sludge is sold as a soil conditioner, and 90% of Bay Area sewage treatment plants do not use incinerators to burn their sludge. This option prevents serious health problems, and increased costs associated with these concerns, from incinerator emissions of dioxin and mercury. We believe that it is important to investigate this option before a final decision to commit public funds to incineration over the long term. We will keep you informed of progress in our discussions with Palo Alto staff, and of new information as it is developed. Sincerely, Greg Karras, Communities for a Better Environment ~Trish Mulvey and Ernie Goitein, CLEAN South Bay i Sydney Brown, Northern California Interfaith Council ..Ted Smith, Silicon Valley Toxics Coalition / Laurie Mueller, Peninsula Conservation Center Foundation’ Julia Bott, Loma Prieta Sierra Club ~ Peter Evans, Ujima Security Council For the California Zero Dioxin Exposure Alliance cc: Phil Bobel and Bill Miks California Exposure Alliance Asian Pacific Environmental Network Breast Cancer Action California Co~nities Against Toxics California Nurses Association California Public Xnterast Research Group (CalPIRG) Charlotte Maxwell Complementary Clinic Chester Street Block club Association Clean Water Action Commonweal Counnunities for a Better Environment Communities for a Safe Environment(CSZ) Desert Citizens Against Pollution Ecology Center Emdometrioeie Association Environmental Health Coalition Environmental Working Group Friends of Rose Drive GABRIELA (Philippines) Greenpeace INOCHI/Plutonium Fr~e Future Women’s Network Impart, Xnc. Madras del Esta de Los Santa Isabel Matin Breast Cancer Watch Mothers and Others Pesticide Action Network Physicians for Social Responsibility Hay A/ea Chapter Political Ecology Group PD’EBLO - People United for a Better Oakland Resource Renewal Group San Francisco Bay Advocates forEnvironmental Rights! (SAFER~} San Francisco BayKeeper Santa Clara Center for Occupational Safety and Health (SCCOSH) Save San Francisco Bay Association Shoreline Environmental Allianco (SEA) Southeast Alliance for Environmental Justice (SAEJ) Silicon Valley Toxics Coalition TO~IC Li~ks Coalltio~ U~ima Security Council United Anglers of California West county Toxics Coalition West Valley Citizens Air Watch Women’s Cancer Resource Canter Workers Acting Together for Cha.~e (WATCH) June 27, 1997 Phil Bobel Environmental Compliance Manager Palo Alto Regional Water Quality Control Plant 2501 Embarcadero Way Palo Alto, CA 94303 SOLIDS FACILITY PLAN - Technical assistance for additional analysis before a long-term investment in sewage sludge incineration Dear Mr. Bobeh We are writing to propose that Palo Alto provide $50,000 in techni- cal assistance for analysis of options to address the ailing sludge incinerators at the City’s Regional Water Quality Control Plant. This analysis of the environmental, health, social and economic impacts of these options by us and independent experts would be presented to the City, public, and other interested parties by November 1, 1997. INTRODUCTION Before millions of public dollars are committed to incinerate sewage sludge for twenty years, we seek to provide new information needed to address serious public health, environmental, and process con- cerns, and confirm data suggesting a cheaper alternative may exist. We have shown a long-term commitment to effective involvement in better environmental decisions by the City. In the early 1990s we provided key information and input which led to cooperative, highly effective cost-saving toxic metals pollution prevention. In 1994 some of us approached City staff on the need for planning regarding dioxin and the incinerators. We met with staff on this issue in June and September of 1996, and in May and June of 1997, and sponsored a public hearing on dioxin attended by staff on May 6, I997. This proposal is our attempt to resolve problems in this decision process. The May, 1997 Solids Facility Plan report by CH2MHill says that its "modified decision analysis" includes our values and priorities (page 1-11). However, our priority to eliminate dioxin wherever feasible was not included in its analysis. The alternative we identified to achieve this priority was not included in its analysis. Our value of meaningfu.1 public participation was not included in the process that brought this report and a recommendation to negotiate funding for a dioxin-creating option to a City Council decision before we learned of the CH2MHill Report or this portion o~’ the decision process. Our proposal would address key information gaps resulting from this process, analyze an option which prevents pollution and reuses a valuable resource, and possibly result in a safer and cheaper solution. Technical Assistance Proposal Page two POLLUTION PREVENTION ALTERNATIVE Problems addressed: Instead of any public scoping process, the-CH2MHill Report used a previ- ous engineering study (page 1-12) and "a workshop where one of the topics was the formal identification and adoption of alternatives to be considered" in the report (page 5-1). The alter- native we have identified -- prevention of pollution at its sources in the sewage plant, before discharge to the sewer, and in solids handling -- was not included. As a result every altemativ.e Considered manages toxic pollution instead of preventing it.1 This type of analysis is erroneously limited to false choices. Thus, the CH2MHill Report pre- sents a false choice between dioxin from incineration, or dioxin from trucks, when both might be eliminated through pollution prevention. It is also largely limited to worry over the accept- ability of contaminated sludge,2 which favors burning to dispose of a smaller amount of ash, when the value of reusing clean sludge may be destroyed or reduced by this burning. Solution proposed: Analyze a "Pollution Prevention Alternative" for comparison with the pol- lution management alternatives included in the CH2MHill Report: Thermal drying or digestion of sludge instead of incineration; Clean sludge through pollution prevention before pollutant releases into sewers; and Sludge products transportation alternatives that prevent pollution. This alternative could eliminate dioxin, reduce other toxic pollutant emissions, improve sludge reuse benefits, and provide economic benefits that are not provided by the other alternatives. The past success of metals pollution prevention and the widespread use of alternatives to sludge incineration at 90% of Bay Area sewage treatment plants suggest it is feasible. ENVIRONMENTAL IMPACTS ANALY~iS Problems addressed: The CH2MHill Report includes no data or analysis on the actual negative effects from the project’s contributions to cumulative exposures to persistent toxic pollutants. Dioxin and mercury are two examples. Incineration will add to cumulative dioxin exposures which already cause health effects in a significant portion of the population, increasing the inci- dence and severity of problems which may include cancer, endometriosis, immunotoxicity, slow learning, and other serious health problems. Similarly, all the CH2MHill Report alternatives will continue to release mercury which will add to already dangerous exposure levels for people who rely on locally-caught fish for food. Bay wildlife including harbor seals and waterfowl are also threatened by cumulative ongoing exposures to dioxin-like chemicals and mercury. These are extremely serious impacts on the environment and human health. 1 Evidence that the CH2MHill Report alternatives are all pollution management alternatives is conclusi’;’e: "It is important, therefore, that modification to the solids process, including air emission controls, address the ultimate fate of these metals, whether they are eventually discharged in the air, the solids byproduct (such as ash), or the plant’s liquid effluent. This is a common issue to all alternatives" considered by the CH2MHill Report. Pages 5-1, 5-2. (Emphasis added.) 2 See e.g. page 4-36: "...application of recycled water and biosolids in the Delta was banned approximately 2 years ago." "Del Monte, Heinz and Campbells do not accept crops that’have been grown on land where biosolids have been applied." "San Joaquin County banned application of biosolids on unincorporated land." Technical Assistance Proposal Page three The CH2MHill Report’s 37 page chapter on regulatory requirements does not include or substi- tute for a description of the effects of pollutants that will be released by the project on people and the environment) The potential for prolonged or increased environmental impacts from incineration alternatives over the next 20 years is far too serious for this long-term decision to be supported without environmental impact analysis and documentation. This failure to analyze environmental impacts further compromises the CH2MHill Report’s pro- jections regarding future environmental requirements. Based on experience, it is likely that serious environmental concerns will drive stricter monitoring and compliance requirements for sludge, ash and emissions. Different future requirements from those predicted will result in dif- ferent costs from those projected, especially for incineration and disposal of contaminated ash. A major long-term public investment needs to be based upon more reliable projections. Solution proposed: Perform screening level analysis of the human health and ecological impacts of the alternatives, including the cumulative impacts of pollutants that may be released by the alternatives, and assessment of key pollutants of concern for reuse of sludge. Use this analysis to refine projections of potential future regulatory requirements for use in cost analysis. RELIABILITY AND TRANSPORTATION ANALYSIS Problems addressed: Despite observations that incineration is wear-intensive4 and alternatives to incineration may have a longer useful life,5 the CH2MHill Report does not complete analysis of the relative reliability costs and benefits of the alternatives. Similarly, the CH2MHill Report mentions possible safety issues with the thermal drying technology6 but does not analyze these possible issues. This analysis seems feasible since thermal drying is in use outside California. This analysis seems important for technologies that are integral to several alternatives, includ- ing the one chosen. Further, the CH2MHill Report analyzes pollutant emissions from trucking solids outside the Bay Area, but fails to analyze options for reduced travel and Bay Areareuse of sludge products, or analyze options for cleaner vehicles. Finally, it discusses possible restrictions on reuse of contaminated sludge products without analyzing the potential that markets for clean sludge products may expand, increasing opportunities for Bay Area reuse and income. These problems severely limit the information regarding which options are safe, reliable, produce the least pol- lution from transportation, and have the least long-term cost. Solution proposed: Perform a screening .level analysis of the reliability, safety, and lifetime ser- vice of incineration and thermal drying in Palo Alto, the projected markets and prices for clean sludge products, and the options for reduced transportation using cleaner vehicles. 3 The CH2MHill Report does include data on pollutants in sludge, ash and air emissions, but its analysis of even these data which do not describe biological effects, is questionable: Its comparisons of scant dioxin emissions data appear technically insupportable, and it fails to address dioxin in ash which may limit reuse options. 4 See CH2MHill Report, pages ES-3, 3-1, 3-2, 3-3, 3-4. 5 See CH2MHill Report, pages 6-21, 6-22. 6 See CH2MHill Report, pages 5-22, 5-24, 5-32. Technical Assistance Proposal Page four ECONOMIC AND SOCIAL IMPACTS ANALYSIS Problems addressed: Incomplete analysis of direct costs of the alternatives severely limits the reliability of the economic analysis in the CH2MHill Report. By its own statements about its "order-of-magnitude" cost estimates, it cannot demQnstrate whether its chosen alternative of incinerator rehabilitation plus thermal drying is the cheapest or second most expensive of the six altematives it analyzed.7 Further, its assumption that there will be no additional monitoring and compliance costs (see e.g. page 6-11) may underestimate these costs for incineration over the next twenty years. An even more important error is introduced by the CH2MHill Report’s failure to analyze possible economic benefits from the sale of uncontaminated sludge products achieved through pollution prevention. In fact, sales of high quality pellets from thermal dry- ing of clean sludge might yield substantial net income and reduce the total cost to the City from $17.2 to $9.7 million, a revised cost estimate that is cheaper than the $11,4 million incinerator rehabilitation plus drying alternative,s The CH2MHill Report lacks analysis of indirect costs, including social costs, that could result from implementation of alternatives. It does not analyze the cumulative social and environmen- tal impacts on low income people and people of color who fish regularly for food and are dis- proportionately exposed to mercury, dioxin, and other pollutants released by incineration and other sources. It does not analyze or estimate the costs of health care and lost personal income from pollutant health effects resulting from the incineration alternative. Finally, it does not ana- lyze the distribution of costs that average roughly $40 to $125 per resident over the 20-year life of the project, how these costs will be rolled out over time, and whether all people should bear these costs equally or toxic sources should invest in prevention. Because of these problems the CH2MHill Report cannot show whether incinerator rehabilitation plus drying or pollution prevention is the cheapest alternative for the City, what the socio- economic impacts of incineration alternatives will be, and who would be forced to bear them. Solution proposed: Perform a more balanced cost analysis that checks the preliminary assump- tions regarding future monitoring and compliance costs, and whether "clean" sludge reuse will result in a lower cost alternative, to provide better economic certainty before investment of pub- lic money. Include a screening level analysis of potential social costs, including environmental and economic impacts, to provide social effects information. 7 Based on the CH2MHill Report’s cost estimates (pages 6-2 and 6-3) and its statement that its cost estimates are +50% to -30% (pages 5-36, 5-37), rehabilitation plus drying total costs might range from $8 million to $17.1 mil- lion, while all the other alternatives have maximum possible costs above $8 million and only one alternative (diges- tion) has a minimum possible cost above $17.1 million. 8 The CH2MHill Report estimates the total capital cost of thermal drying at $23.5 million (page 5-37). It also esti- mates that the production of pellets from thermal drying of sewage sludge at Palo Alto will average 19.7 tons per day and that these pellets sell for up to $200 per ton (~10¢ per pound), however, it assumes without explanation that Palo Alto will sell them for only $50 per ton (page 5-34). If pollution prevei~tion achieves very high quality, uncontaminated sludge, given the scarcity of such sludge throughout California the maximum price would be a more reasonable assumption. Using this $200 per ton for 19.7 tons per day in the cost analysis on pages 5-36 and 5-37 yields pellet revenue of $1.46 million per year, annual net income of $690,000 after subtracting operation and maintenance costs, and $13.8 million over the 20-year planning period. Subtracting this income from the estimated total capital cost yields a "clean sludge" cost for the thermal drying alternative of $9.7 million. Technical Assistance Proposal Page five CONCLUSIONS AND PROPOSAL An $11 million long-term investment, of which $3.2 million is for "Incinerator Expansion" (see page 5-15), is now proposed based on the belief that it is the cheapest alternative. The analysis used to support this alternative provides no or insu~cient environmental, engineering, trans- portation, economic and social impacts analysis even though the project may cause significant environmental and socio-economic impacts. However, there may be a cheaper environmentally superior alternative that was not included in the scope of the existing analysis. The City’s agreement to our proposal would, at a minimum, result in the following written work products that would .significantly. improve.the-information upon which to make the best long-term investment of public money for our environmental, economic and social health: o Identification of a new pollution prevention alternative and analysis of this alternative at an equal or greater level of detail as done for other alternatives considered at this time; ¯ Screening level analysis of the human health and ecological impacts of the alternatives, including cumulative impacts, assessment of key pollutants of concern for reuse of sludge, and refined projections of potential future regulatory requirements for use in cost analysis; ¯ Screening level analysis of the reliability, safety, and lifetime service of incineration and thermal drying in Palo Alto, the projected markets and prices for clean sludge products, and the options for reduced transportat’ion using cleaner vehicles; o Improved cost analysis which checks the pr.eliminary assumptions regarding future moni- toring and compliance costs for incineration, and whether "clean" sludge reuse will result in a lower-cost or cost-competitive alternative, for more reliable cost projections; and ° Screening level analysis of potential social costs, including those related to environmen- tal and economic impacts of alternatives, to provide social impacts information. These written work products would be available by November 1, 1997 assuming approval to start work by July 1. We would anticipate discussion of results and implications with the City at that time, and perhaps while the work proceeds as preliminary results become available. We look forward to discussing this proposal with you. As a first step, we plan to contact you to set up this discussion. In the meantime, if you have any questions or wish to discuss our pro- posal please phone Greg Karras at 415/243-8373. Sincerely, Greg Karras Communities for a Better Environment Ted Smith, Executive Director Silicon Valley Toxics Coalition Trish Mulvey / CLEAN South Bay Sydney Brown N. California Interfaith Council Technical Assistance Proposal -Page six Laurie Mueller, Executive Director Peninsula Conservation Center Foundation Peter Evans Ujima Security Council Emie Goitein/i/CLEAN Soutlt/B’ay Julia Bott Loma Prieta Sierra Club cc: Bill Miks, Manager, Water Quality Control Plant ATTACHMENT D SCHEDULE Environmental Review of Solids Facility Plan 7/25/97 (TBD) Oct. 1 Nov. 1 Dec. 22 (TBD) (TBD) (TBD) 2nd Internal Draft of CEQA Documentation Revise CEQA Documentation Complete "Tasks" A-E ICEQA Documentation Mailing I $30 Day~"-,~ Respond to CEQA ~ Documentation Comments P.A. Council CEQA Certification Partner City Project Approval P.A. Council Project Approval Update Solids Mgt. Plan Update Solids Mgt. Plan Establish Env. Goals Process ("Task" F) Deyelop Env. Goals for RWQCP Utilize Goals in Capital Projects P. Eo~ ~<o~