HomeMy WebLinkAbout1999-04-12 City CouncilTO:
City
HONORABLE CITY COUNCIL
City of Palo Alto
Manager’s Re
]1
FROM:CITY MANAGER DEPARTMENT: PUBLIC WORKS
DATE:APRIL 12, 1999 CMR:157:99
SUBJECT:APPROVAL TO AMEND THE CAPITAL IMPROVEMENT
PROGRAM IN ORDER TO MOVE FORWARD FUNDING FOR
PROJECT 9707, "WASTEWATER SOLIDS DISPOSAL" FOR
INCINERATOR IMPROVEMENTS AND APPROVAL OF A BUDGET
AMENDMENT ORDINANCE IN THE AMOUNT OF $6.5 MILLION
RECOMMENDATION
Staff recommends that Council approve the attached Budget Amendment Ordinance of $6.5
million to move forward to 1998-99 funding for the rehabilitation of two existing incinerators
at the Regional Water Quality Control Plant (RWQCP).
BACKGROUND
In May 1997, Council approved a Solids Facility Plan to rehabilitate two incinerators at the
RWQCP and directed staffto develop a financial plan for the project (CMR:236:97). Staff
obtained Council approval in March 1998 (CMR: 165:98) to sell utility revenue bonds to fund
the project, and for the City of Palo Alto to be the lead agency in issuing the bonds on behalf
.of all RWQCP partner cities (Mountain View, Los Altos, Stanford, East Palo Alto Sanitary
District, and Los Altos Hills). An addendum to the Basic Partners Agreement was
implemented to facilitate the debt financing and further define partner obligations to pay the
City their proportionate share of debt service over the life of the bonds. Council approved
the addendum to the Partners Agreement and directed staff to finalize design, secure the
necessary permits, and pursue bond financing so construction could begin in summer 1999.
Under Project 9707 "Wastewater Solids Disposal," rehabilitation of the existing incinerators
originally was planned to begin in 1999-00. To meet requirements of the Bay Area Air
Quality Management District (BAAQMD) construction permit, which expires on Januaryl 1,
2001, construction must begin as soon as possible. The use of appropriated funds and the
start of construction will be contingent upon the sale of bonds in early June.
DISCUSSION
Staff has completed the.final design for the incinerators’ rehabilitation and is in the process
of obtaining a building permit from the City’s Planning Department. Staff is optimistic that
the permit will be issued in early April.
CMR:157:99 Page 1 of 3
In addition, staffhas obtained the required construction permit from Bay Area Air Quality
Management District. This permit was issued on January 11, 1999 and gives the City only
two years to complete the project. Since the RWQCP must continue to treat all incoming
wastewater, only one incinerator can be rehabilitated at a time. It is estimated that
rehabilitating and testing each incinerator will take a’minimum of nine months, for a total
construction period of 18 months. The two-year permi.t requirement and the necessity of
sequencing incinerator rehabilitation over two nine month periods results in an extremely
tight construction schedule and a somewhat atypical schedule for Council approvals of
financing and contract awards.
To comply with the BAAQMD permit expiration date of January. 11, 2001, construction
should begin in June 1999. For this to occur, a contract must be awarded in May, with the
appropriate project budget in place.. The attached Budget Amendment Ordinance (BAO)
accomplishes this by moving forward the incinerator rehabilitation Capital Improvement
Program (CIP) project budget from 1999-2000 ($3.0 million) and from 2000-2001 ($3.5
million) to 1998-99. A revised CIP project description indicating the timing and amount of
funds is provided as Attachment B. Funding for the completed design of the project
($700,000) was budgeted in 1998-99.
The tight permit and construction schedule has additional consequences. Staff will be
returning to Council in late April to request that Council approve the project’s bond financing
package two weeks prior to the award of contract. Staff recommends that financing be
moved up so that funding is in hand as soon as is practical after the construction award is
issued. Due to the current favorable interest rate climate and the expected high credit Palo
Alto can command in the bond marketplace, there is virtually no risk to Palo Alto to award
the construction contract prior to receipt of bond funds. The construction contract will be
awarded contingent upon the successful sale of the RWQCP utility bonds.
RESOURCE IMPACT
At this time, total costs for this project, which include design and construction, are estimated
at $7.2 million. This includes $.7 million for design and $6.5 million for construction. These
capital costs will be funded through a City of Palo Alto bond financing that will be
proportionately distributed and paid according to the Regional Water Quality Control Plant’s
Partners’ Agreement. Each partner agency’s city council has approved the sale of bonds to
finance incinerator improvements. It is estimated that the City of Palo Alto’s share of debt
service payments for this project will be around 3 8 percent.
ENVIRONMENTAL REVIEW
On February 23, 1998, Council approved a Negative Declaration (CMR: 141:98).
POLICY IMPLICATIONS
The recommended project is consistent with past Council direction.
CMR: 157:99 Page 2 of 3
TIMELINE
If the BAO is approved, the project will proceed according to the following schedule:
Building permit issued
City Council approves financing package/bond documents
Council awards construction contract ;
Bonds sold
Construction starts
Finish construction
April t999
April 1999
May 1999
June 1999
June 1999
December 2000
ATTACHMENTS
Attachment A:
Attachment B:
Attachment C:
Attachment D:
Attachment E:
Budget Amendment Ordinance
Revised Project Description 9707 "Wastewater Solids Disposal"
CMR:236:97
CMR:165:98
CMR:141:98
PREPARED BY:Bill Miks, Manager RWQCP
Joe Saccio, Senior Financial Analyst
DEPARTMENT HEAD:
CITY MANAGER APPROVAL:
~ City Manag-’JIJN~ I~LE r~
CMR:157:99 Page 3 of 3
ATTACHMENT A
ORDINANCE NO.
ORDINANCE OF THE COUNCIL OF THE CITY OF PALO ALTO
AMENDING THE BUDGET FOR THE FISCAL YEAR 1998-99 TO
PROVIDE AN ADDITIONAL APPROPRIATION OF $6,500,000 TO
CAPITAL IMPROVEMENT PROGRAM PROJECT NUMBER 9707
’WASTEWATER SOLIDS DISPOSAL’ FOR INCINERATOR IMPROVEMENTS
WHEREAS, pursuant to the provisions of Section 12 of Article
III of the Charter of the City of Palo Alto, the Council on June
22, 1998 did adopt a budget for fisca! year 1998-99; and
WHEREAS, the Regional Water Quality Control Plant’s
RWQCP)incinerators are approaching the end of their useful lives and
are showing signs of deterioration; and
WHEREAS, on May 12, 1997, Council approved a Solids Facility
Plan to rehabilitate two incinerators at the RWQCP and directed
staff to develop a financial plan for the project; and
WHEREAS, on March 16, 1998, Council approved staff’s request to
seek bond financing for the project and approved Addendum Number 6
to the RWQCP Partners’ Agreement which defined partner financial
obligations for incinerator improvements; and
WHEREAS, the City Councils of our Partner Cities, Mountain
View and Los Altos, also approved Addendum Number 6 concurrently;
and
WHEREAS, the final design for the rehabilitation project has
been completed and the Bay Area Air Quality Management District
(BAAQMD) has issued a construction permit on January ii, 1999; and
WHEREAS,-an award of contract should be awarded in May 1999
so construction can begin in June 1999 and be completed before
BAAQMD’s permit expires on January ii, 2001; and
WHEREAS, CIP 9707, Wastewater Solids Disposal, needs to be
increased by $6,500,000 to provide budgeted funds that can be
encumbered when a contract is awarded in May for rehabilitation of
the incinerators to begin in June 1999; and
WHEREAS, funding had been planned in the 1999-00 CIP budget,
and needs to be moved forward to expedite construction to ensure
completion within the BAAQMD permit expiration date; and
WHEREAS, the use of appropriated funds for the award
of the construction contract and for construction are contingent
upon the successful sale of bonds in early June 1999; and
WHEREAS, the budget needs to be: amended to fund capital
improvements for Project 9707, Wastewater Solids Disposal; and
WHEREAS, City Council authorization is needed to amend the
1998-99 budget as hereinafter set forth.
NOW, THEREFORE, the Council of the City of Palo Alto does
ORDAIN as follows:
SECTION io The sum of Six Million Five Hundred Thousand
Dollars ($6,500,000) is hereby appropriated to Capital Improvement
Project No. 9707 Wastewater Solids Disposal, which will be funded
from the sale of bonds in June 1999.
SECTION 2. This transaction will have no impact on Reserves.
SECTION 3. As specified in Section 2.28.080(a) of the Palo
Alto Municipal Code, a two-thirds vote of the City Council is
required to adopt this ordinance.
SECTION 4. On February 23, 1998 The Council of the City of
Palo Alto approved a Negative Declaration for the project.
SECTION 5. As provided in Section 2.04.350 of the Palo Alto
Municipal Code, this ordinance shall become effective upon adoption.
INTRODUCED AND PASSED:
AYES:
NOES:
ABSTENTIONS:
ABSENT:
ATTEST:
City Clerk
APPROVED AS TO FORM:
Senior Asst. City Attorney
APPROVED:
Mayor
City Manager
Director of
Services
Administrative
Director of Public Works
ATTACHMENT B
PROJECT DESCRIPTION
All pollutants and waste solids removed from the wastewater during treatment must be stabilized and disposed of
properly. Currently, solids are fully stabilized by incineration. The ash is then recovere2 and used as a soil
amendment on alfalfa fields near Hollister. This project is to investigate, design and bu!d a solids handling system
to replace the current incinerators. Design work for this project was already budgeted i~ 1998-99 and final design
work was completed in 1998-99. With the issuance of a Bay Area Air Quality Management District (BAAQMD)
construction permit that expires on January 11, 2001, staff is targeting completion of construction by December
2000.
PROJECT JUSTIFICATION
The current incinerators are 25 years old and their estimated useful life is 15 to 25 year.~. Due to the high demands
placed on the incinerators, they are showing signs of deterioration. After investigating 2 number of options such as
completely refurbishing the existing incinerators to replacing them or providing another solids disposal alternative,
the participating Regional Water Quality Control Plant (RWQCP) agencies, which include Palo Alto, Mountain
View, Los Altos, Los Altos Hills, Stanford University, and the East Palo Alto Sanitary District, decided to
rehabilitate the existing incinerators. Since the BAAQMD permit for construction expi.-es on January 11, 2001,
staff needs to begin construction by June 1999. Staff is requesting that $6.5 million in construction funds be
appropriated in 1998-99. Use of these funds for construction will be made contingent upon the successful sale of
bonds in early June.
FUTURE FINANCIAL REQUIREMENTS
FISCAL
YEAR AMOUNT
1998-99 $7,200,000
1999-00
2001-02
2002-03
Sources of Funding: Bond financing whose costs will be shared by RWQCP partners.
COMPONENTS
Design ($700,000) and Construction ($6,500,0.0)
IMPACT AND SUPPORT ANALYSIS
Environmental:
Design Elements:
Operating:
Telecommunications:
On February 23, 1998, Council approved a Negative Declaration.
Design elements have been completed.
Operating requirements will be reviewed and recommended during engineering
design.
None.
COMPREHENSIVE PLAN
The project furthers Goal N-4 of the Natural Environment Element, Support Urban Activities, and Protect Public
Health and Safety.
236
ATTACHMENT C 7City of Palo Alto
City Manager’s Report
TO:
FROM:
HONORABLE .CITY COUNCIL
CITY MANAGER
AGENDA DATE: MAY 12,1997
DEPARTMENT: Public Works
CMR:236:97
SUBJECT:POLICY DIRECTION FOR THE SOLIDS FACILITY PLAN FOR
THE REGIONAL WATER QUALITY CONTROL PLANT
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).
RECOMMENDATIONS
Staff recommends that Council:
Accept the Plan and its recommendation of a two-phase project m 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 f’mancial planning m implement the first phase of the
recommended project of the Plan. Funding for the second phase will be deferred until
needed.
Direct staff m PrePare the amendment to the Parmers’ agreement m formally obtain
Partners’ approval of the project, and their agreemem to pay their proportionate share
of the project costs.
Direct staff to repo.rt back to Council for approval of the signed amendment, the
financial package, and approval of the projects when the preparations are in place.
The recommendations in the Plan do not represent any change m current City policies.
CMR:236:97 Page 1 of 4
EXECUTIVE SUMMARY
The RWQCP provides advanced wastewater treatment for the cities of Palo Alto, Mountain
View, Los Altos, the Town of Los Altos Hills, East P.alo Alto, and Stanford University.
The Solids Facility Plan is the RWQCP’s road map for the next twenty years to manage
the sewage sludge inan economical and environmentally 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 highlighted 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.
Parmer 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 IMPACT
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 Partners’
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 ambiguous 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.
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 re6ommended 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
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
PALO ALTO
REGIONAL WATER QUALITY
CONTROL PLANT
Solids Facility Plan
EXECUTIVE SUMMARY
CH2MHILL
in association with
Applied Decision Analysis
Carlson Associates
Kennedy Jenks Consultants
May 1997
Palo Alto Regional Water Quality Control Plant
Solids Facility Plan
Executive Summary
C~=I21WHILL
in association with
Applied Decision Analysis
Carlson Associates
Kennedy Jenks
May 1997
Executive Summary.
Introduction -
:
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. The facility includes both liquid and solids treat-
ment processes. The two processes must both operate efficiently so that the overall plant
operations can be called a success. The liquid process removes particulates and dissolved
organics from the flow stream, while the solids processes treat the material removed by the
liquid processes. Further, the solids processes will normally recycle a relatively small per-
centage of solids back to the liquid process for additional treatment. The solids that are
removed in the liquid processes include screenings, grit, primary set~led solids, secondary
settled solids, scum, and solids from the tertiary filters.
The screenings and grit that are removed are hauled to a landfill for disposal. The filtered
solids are returned to the plant headworks for subsequent treatment. The primary settled
solids and the secondary settled solids are thickened in gravity thickeners, dewatered in
belt dewatering presses, and subsequently incinerated in one of two multiple-hearth incin-
erators. The liquid from the dewatering process and the incinerator emissions scrubber
water are recycled to the plant headworks. The scum is concentrated and incinerated with
the dewatered solids. The ash from the incinerators is hauled to the Central Valley and
applied to agricultural lands as a fertilizer supplement.
Reliability is an important part of wastewater treatment. The treatment process must be
able to operate in essentially all conditions. These conditions include periods of peak
wastewater production and periods when equipment may malfunction. This aspect of reli-
abiliD" is addressed through provision of a spare piece of equipment during peak operating
periods. This might be accomplished, for example, by operating one incinerator during
peak periods, while keeping the second in reserve.
Facility Plan Scope
This Solids Facility Plan addresses the handling and treatment of primary settled solids,
secondaD" settled solids, and scum. A previous Solids Management Plan dated June 1995
addressed the handling of the screenings, grit, and filtered solids. That plan also evaluated
the full realm of alternatives for handling the primary settled solids, secondary settled sol-
ids, and scum. The recommended alternatives from that previous Plan, which form the
basis for the alternatives in this Solids Facility Plan, include:
Continue incineration.
Phase out incineration.
-Replace with anaerobic digestion.
-Replace with heat drying.
SFO/G \WATER\I35921\027ES_1 DOC ES-I
EXECUTIVE SU~Y
)
)
)
Decision Process
The Solids Facility Plan has been organized and conducted according to a mod~cation of a
proven model called Decision Analysis. The overall goal of this decision process is to build
consensus among the stakeholders and decision makers, to include the values and priori-
ties of all affected parties, to evaluate alternatives according to a rigorous econoEdc and
non-econor~c model, and to produce an effective decision making tool, The modred deci-
sion analysis process includes five steps.
1. Develop project commitment and vision
2..Identify key stakeholder values
3.Frame the problem and develop alternatives
4.Collect reliable, meaningful data
5.Evaluate alternatives and decide
As part of this process, it is important to present the project vision as developed by staff
representatives, stakeholders, and decision makers. This vision includes the following points:
Create healthy operations in terms of the impacts to operations and maintenance
personnel and the surrounding environment and in terms of reliable, well oper-
ating equipment.
Reduce the level of air emissions from current levels.
Create a smooth, reliable operation.
Identify a project scope and phasing, such that increases to sewer charges/rates
will not exceed approximately 10 percent.
Consider alternatives from an overall, "cradle-to-grave perspective."
Beneficially reuse all byproducts, such as biosolids and ash.
Demonstrate to stakeholders and decision makers that alternatives have been
effectively analyzed so that the best alternative has been identified.
Solids Production
The PARWQCP construction was completed Ln 1971. The nominal rated capacity is 39 mgd.
Currently the flowrate is about 22 mgd (or 56 percent of the rated capacity). These capaci-
ties represent average annual conditions. The facility must, however, be able to operate sat-
isfacto.rily during various peak conditions, such as the maximum week, day, and hour.
Therefore, all treatment facilities must have peak capacities in addition to the nominal capac-
ity. Additionally, it is often the case that the liquid and solids capacities do not match. This
is the situation at the PARWQCP. The incinerators were recently tested and visually inspected.
The testing indicated the existing incineration capacity for each incinerator should be rated
at 21 dry tons per day (DTPD) of solids, assuming a feed solids concentration of 28 percent.
(Incinerator capacity is related to feed solids concentration, up to a limit. Generally, the
greater the reliable feed solids concentration, the greater the incinerator capacity.) This is
the capacity for all average and peak loading conditions. Currently, the average solids load-
ing is approximately 17 DTPD and the maximum week is about 32 DTPD. During average
conditions there is sufficient capacity available when operating one incinerator; however,
SFO/G \WATER\~35921\027ES_I DOC ES.2
EXECUTIVE
during peak conditions, a single incinerator’s capacity is, at best, marginal. Plant operators
are able to handle peak conditions by storing solids in the thickeners and by adopting
aggressive operating techniques. These procedures are not considered reliable, long-term
options because they increase the risk of process failure. The capacity must be increased to
accommodate the peak solids loading conditions.
Service Area Growth
The planning period for this Facility Plan extends through the year 2020. Projections for
growth in the service area have been developed based on information from the Association
of Bay Area ~Governments (ABAG) and by the Santa Clara County Center for Urban Analy-
sis. Based on these sources, the residential population is expected to increase a total of 5.8 per-
cent during the planning period, while total jobs are projected to increase by 16 percent.
This translates into an overall increase in solids production of 9.2 percent. The projected
average solids loading in 2020 is, therefore, projected to be 18.5 DTPD and the maximum
week is 35 DTPD. The maximum week is the typical design criterion for incineration sys-
tems. Again, a single incinerator does not have sufficient capacity. The capacity must,
therefore, also be increased to accommodate projected growth in addition to being increased
to simply meet current maximum week conditions reliably.
Existing Incinerator Condition
In addition to capacity testing, the incinerators have had several recent visual inspections to
evaluate operational parameters and the structural conditions. The incinerators have been
in service since 1971. They have provided good service over the years and there has been a
good, ongoing preventative maintenance program. Still, incinerator systems are mechani-
cally intensive and they experience relatively severe service conditions. Currently, there
are some special rehabilitation issues that have been identified together with conditions asso-
ciated with general aging of the equipment. The rehabilitation issues include items such as
the structural condition of the shell, the structural condition of the hearths that are internal
to the incinerators, and the condition of ancillary systems, such as inlet fans, controls, and
air emission equipment. All of these can be addressed using conventional technology so
that the resulting units will provide reliable, efficient service through the planning period.
Capacity
The inspection and testing of the incinerators has resulted in a determination of the poten-
tial capacity, assuming a complete rehabilitation and expansion program. The reliable
future capacity of the incinerators, at the same 28 percent feed s6lids concentration, is esti-
mated to be 32 DTPD or 91 percent of the projected maximum week capacity requirement. The
incinerator capacity can be further increased, up to a limit, if the feed solids concentration is
reliably increased. For example, ff the feed solids concentration is reliably increased to
32 percent, the incinerator capacity can be increased to approximately 35 DTPD (35 DTPD
is considered the maximum achievable capacity for these incinerators). Achieving the
higher feed solids concentration will require a significant change to the dewatering process.
As stated previously, the incinerator loading now averages about 17 DTPD. The estimated
future capaci .ty of each incinerator after rehabilitation and expansion is estimated to be approxi-
mately 32 DTPD. This compares to the estimated peak solids capacity required in the planning
year of 35 DTPD. The future capacities are estimates based on the best available information.
SFo/G \WATER\135921~027ES_l DOC ES-3
There is some uncertainty, however, in the estimates. The uncerta:ntv will be reflected pri-
marily in the dates that actual growth will cause plant solids load’,ng to exceed the 32 DTPD
of a single incinerator’s rehabilitated and expanded incinerator caTacity. The incinerator
rehabilitation and expansion will be sufficient to handle plant load:ngs for the initial years
of the planning period, say 8 to 10 years. Plant solids loadings wi’." eventually increase to
the point where they exceed a single incinerator’s expanded capac:~y. At that time, other
system modifications will be required to increase overall capacity.
Air Emissions and Controls
Air emissions and air emission controls are major considerations in ".he evaluation of alterna-
tives. The new, expanded capacity will require new emissions controls to avoid increases in
emissions relative to permitting requirements and to achieve the goal of reducing emissions..
The emissions and emissions controls for each alternative will be compared to the current
baseline conditions. These baseline conditions have been establishe~ through an extensive
stack testing program conducted as part of this Facility Plan. The evaluation of emissions
includes a complete "cradle-to-grave" approach. For example, the :tuck emissions associ-
ated with hauling ash or biosolids to reuse sites in the Central Valley are included. The
evaluation also considers the fate of metals, which are first removec~ in the liquid process
and subsequently incinerated. The evaluation addresses the metal components that are
removed with the ash and those that are scrubbed from the air errd_~sions and recycled in
the scrubber water.
Alternatives
Based on the screening of alternatives and recommendations contaLned in the previous Sol-
ids Management Plan and on a workshop with staff, five alternatives have been identified
for detailed evaluation in this Solids Facility Plan. One of the alternatives includes two sub-
alternatives. These alternatives include:
Alternative 1, phase out the existing incinerators, and revlace them with new,
larger capacity incinerators.
Alternative 2, rehabilitate and expand the capacity of the existing incinerators,
to the maximum extent feasible. (Note that this alternahve does not provide
complete redundancy during future, peak conditions.)
Alternative 3, rehabilitate and expand the existing incinerators as per Alterna-
tive 2, but address the capacity shortfall by implementing other process changes
that will either reduce the quantity of solids to be handle~ or create drier feed
solids to increase incinerator capacity. Solids can be reduced by implementing
anaerobic digestion for a portion of the solids (Alternative 3a). Drier feed solids
can be achieved by processing some of the feed solids through a thermal dryer
(Alternative 3b). The process of either reducing the amo~.nt of solids to be incin-
erated or making them drier is generally referred to as "-~alping."
Alternative 4, phase out the existing incinerators and process all solids with
anaerobic digestion.
Alternative 5, phase out the existing incinerators and prccess all solids with
thermal drying.
sFo/G \WA]’ER\135921\027ES_1 DOC ES-4
EXECUTIVE SUmMARY
Alternatives 1, 2, and 3 will produce an ash product veD" sirr~ar to the existing. Alternative 4
will produce a biosolids product that can also be applied as supplement to agricultural land.
Alternative 5 win produce a pelletized product that can be m~-keted to golf courses, parks, etc.
Evaluation of Alternatives
The alternatives have been evaluated based on Stakeholder values identified early in the
decision process. These values include capital and O&M ccsts, human health and safety
and Bay ecology impacts, energy use, solids product reuse, plant operations impacts, and
visual and odor impacts.
Cost Comparison
The alternatives have been evaluated for both capital and C&M costs. Table ES-1 summa-
rizes the costs. The capital costs for both Alternatives 3a a~n~ 3b assume that the incinerato~
rehabilitation/expansion is done in 1998 but that the addih¢n of either the digester or ther-
mal dryer is deferred until 2008. O&M costs above current annual O&M costs were used so
that only changes in O&M costs are considered as part of ti-.e total alternative cost. The net
present value (NPV) of the O&M costs have been ¢alculate~ based on a discount rate of
2 percent and a 23-year period.
Table ES-1
Estimated Costs of Alternatives
NPV of O&M Costs
Total Capital Cost Compared ’,o Current Costs Total Cost
Alternative (1998 $)(1998 $)(1998 $)
1 New Incinerators $23.6 million $0:1 million $23.6 million
2 Rehab Incinerator 6.0 million C .= million 6.8 million
3a Rehab plus Digestion 13.0 million 3 -’ m.;llion 16.4 million
3b Rehab plus Drying 10.1 million 1.3 million 11.4 million
4 Digestion 22.3 million 7 : m~!lion=29.7 million
5 Drying 24.9 million (T - re;Ilion)b 17.2 million
aCosts to haul large amounts of biosolids resulting from d=gest=on lea: to high O&M costs.
bRevenue from sale of pellets resultin~ from dr~in~ lead to a net decr--:~se in O&M costs.
Non-Economic Comparison
The alternatives were also compared based on non-economic s:akeholder values identified early
in the decision process. These values include human health ~nd safety, Bay ecology, energy
use, solids product reuse, plant operations, and aesthetics ar.~ odor. Human health and Bay
ecology were identified as the most important non-economic values for comparing alternatives.
Air emissions were used as the criterion to assess differences in Fotential impacts to human health
and safety and Bay ecology. The development of this measure ~ discussed in further detail later
in Chapter 6. To the degree possible, the life cycle emissions of each alternative were calculated,
taking into account the solids handling process emissions, associated process equipment emis-
sions, and diesel truck emissions to remove solid byproducts. "Fr~e air emissions have been evaluated
for the individual components in three categories of pollutants: criteria pollutants (nitrogen
oxides, carbon monoxide, etc.), hazardous air pollutants (dio.x’.n, etc.), and metals (mercury, cop-
per, etc.). The evaluation includes not only the direct emissions, :a "kang into account emissions
SFo/G \WATER\I35921~02.7ES_l DOC ES-5
EXECUTIVE SUMMARY
t
)
controls, but also the emissions from ancillary equipment, such as internal combustion engines
burning the digester gas, and truck exhaust associated with hauling the final biosolids product.
To assist with the decision-making process, the noneconomic benefits need to be assessed in
combination. For this project, explicit dollar values were not assigned to the non-economic
values independently of the alternatives considered, which is sometimes done in decision
analysis to determine the least-cost, maximum-value alternative. Instead, the implied
tradeoffs between alternatives, meaning what is gained or lost in noneconomic values by
choosing a more expensive alternative, are laid out. In this manner, decision makers can
make judgments as to whether specific tradeoffs are economically reasonable or not.
Recommendation
The lowest cost alternative is the Incinerators Rehabilitation alternative (Alternative 2), at a total
cost of $6.8 million. This alternative, however, cannot provide full incinerator redundancy dur-
ing the anticipated peak week loads later in the planning period (occurring approximately
4 weeks per year), constraining operational reliability. At that time, the PARWQCP may
decide to add scalping to maintain redundancy and achieve greater operational reliability.
As a result, the Rehabilitation plus Drying alternative (Alternative 3b) provides a more
accurate estimate of the "high end" cost and impacts associated with the Incineration Reha-
-bilitation alternative. It is possible that the PARWQCP might not need the scalping. As
better data is collected on the wastewater load and resulting solids load, the project peak
week load may be less. The PARWQCP may also decide to pursue source reduction meas-
ures to potentially reduce the peak week load.
Another alternative may be preferable, however, for its non-economic benefits, such as low-
ered emissions, energy conservation, odor, etc. Table E,S-2 outlines the specific tradeoffs between
the Incinerator Rehabilitation plus Dryer alternative as the low cost alternative and other
alternatives. The costs shown in Table ES-2 are the capital and total project costs. Permit-
ting costs were not included since they are relatively low compared to the total costs of alter-
natives and make a negligible difference in how the alternatives compare to each other. To
help provide perspective, dioxin emissions were compared to equivalent automobile emissions.
Table ES-2
Comparison of Alternatives to Low Cost Alternative
Estimated
Capital Estimated
Cost Project CostAlternative(NPV)(23 years!,
"3b Rehabilitation plus $10.1 M $11.4 MDrying’"i’F~ui,~iz~’,~23.6 M’23.6M
incinerators
3a Rehabilitation plus 13,0 M 16.4 MD~gestion
4 Digestion 22.3 M 29 7 M
5 Thermal Drying=24.9 M 17.2 M
Life-Cycle
Dloxln
Emissions
fib/day)
2.63 E-11
(11 eutos)
2.68 E-11
(11 autos)
2.63 E-11
(11 autos)
1.94 E-10
(81 aulos)
2.42 E.11
(10 autos)
Other
Life-Cycle
Emissions
(Ib/day)
Less CPs
Less metals
More CPs
Same metals
More CPs
Less melals
Less CPs
Less Melals
Energy Reuse/Footprint
Consumption Resource (add’l sq.
, ($1yr)=Value ,ft.)"
168,000 Moderale 800
122.000 Moderate 1.500
106.000 Moderate 20.000
(109.000)Low 45.000
227,000 High 1
Odor
Potential Visibility
Low Low
Low Low
High High
High High
Medium Low
=Cost of energy v~s decided to be the besl measure of total energy consumption and =ncludes electricity, natural gas, end d~esal fuel.=A large addihonal footprint reduces operalmnal flexibility and limits options for future facility changes or expansion,
=Total Then’nat Drying Project Cost is less Ihan Thermal Drying Capital Cost due to Iong-lerm savings in Operations and Ma=ntenance costs,
CP = Criteria pollutanls
SFO/G \ViATER\135921\027E$_l DOC ES..6
The information in Table ES-2 can be used by decision-makers to evaluate the tradeoffs
obtained by paying for one of the more expensive alternatives. For example, the additional
$5.0 million for the Incinerator Rehabilitation plus Digestion alternative "buys" some
reduction in energy consumption but also imposes substantial plant operations and
aesthetics penalties and increases the criteria pollutant emissions. In this case, the choice of
Rehabilitation plus Digestion over Rehabilitation plus.Drying is a poor tradeoff. Other
tradeoffs can be evaluated in a similar manner by decision-makers.
The recommended alternative is Rehabilitation plus Drying, for the following reasons:
Alternative has the °lowest capital cost of alternatives that provide complete redun-
dancy in the primary process and meets capacity needs through 2020. As discussed
above, the City may not need to add the scalping in the future, which would lower,
the capital cost to .the same as the Incinerator Rehabilitation alternative.
Alternative pollutant emissions are either the same or lower than current emissions
for this alternative.
Alternative meets all current and know potential future air quality requirements,
including dioxin requirements.
Alternative should be able to maintain Grandfather Status and as a result would not
trigger a new permit application.
Alternative has the advantage of destroying PCBs and pesticides, which the Diges-
tion and Thermal Drying alternatives do not.
The non-economic benefits gained by choosing one of the more expensive alterna-
tives do not seem to merit their additional cost. For example, the air emissions
benefits from the Fluidized Bed Incinerators or Thermal Drying would cost millions
of dollars. The same benefits could be achieved at a much lower cost through other
programs, such as ride sharing programs that reduce auto use. Some of the more
expensive alternatives also have substantial non-economic penalties, such higher
life-cycle dioxin emissions or increased odor potential, compared to the Rehabilita-
tion plus Drying alternative.
Reference Figures
Five figures taken from Chapter 1 of the report have been appended to this Executive Sum-
mary for reference.
)
)
SFO/G \WATER\13592~\027ES_l DOC ES-7
E
Belt
Presses
Solids Cake Feed Screw
Combustion
Air
Blower
Bypass
To Truck
=1
Air Inlet I
I
Air Inlet
Ash
Conditionei
To
Truck
Ash Screw Conveyor
Exhaust
Stack
01
Cooling Air
: Recy~cle
~T,--Cooling AirExhaust
Hearth 1
Hearth 2
Hearth 3
Hearth 4
Hearth ,5
Hearth 6 T
Note:
Hearth 1 currently
used as the afterburner
Induced Draft
Fan
Inlet
Damper
Drain
~F urnE~ace
Natural Gas
CoolingAir (~C°°ling Fan
=
Figure 1.4
Sewage Solids Incineration
Palo Alto Regional Water Quality Control Plant
Solids Facility Plan
CH:21VIHILL
Steel
She{I
Insulatio
Refracto
Belly Band
(Typical) -.~
I
AIternate
Sludge
Feed
Point
HEARTH 1
HEARTH 2
Current I
SludgeIFeed I
Point~
~ :~::::..
HEARTH 4
1
I
HEARTH 3
/
/
Rabble
(Typical)
Center
Shaft
Figure 1-5
Typical Furnace Construction
Palo Alto Regional Water Quality Control Plant
Solids Facility Plan
ATTACHMENT D
Cite of Palo Alto
City Manager’s Report
5
TO:
FROM:
HONORABLE CITY COUNCIL
CITY MANAGER DEPARTMENT: PUBLIC WORKS
DATE:MARCH 16, 1998 CMR:165:98
SUBJECT:APPROVAL OF ADDENDUM NO. 6 TO THE WATER QUALITY
CONTROL PLANT PARTNERS’ BASIC AGREEMENT TO:
INCREASE THE ANNUAL ONGOING CAPITAL IMPROVEMENT
BUDGET CAP; DEFINE PARTNER OBLIGATIONS WITH
REGARDS TO REIMBURSING PALO ALTO FOR COSTS FOR
INCINERATOR REHABILITATION
PORT IN BRIEF
Following Council’s direction to proceed with the financial planning for the rehabilitation
of the RWQCP’s incinerators, staff is submitting Addendum No.6 to the Partners’ agreement
for Council’s approval.
The RWQCP partners (the cities of Palo Alto, Mountain View, and Los Altos) are
responsible for financing the project. The financial advisor and Partners’ staff recommend
that the project be bond funded to spread the cost to ratepayers over a number of years. The
City of Palo Alto will be the lead agency in issuing the debt. The addendum to the Partners’
agreement is needed prior to bond sale to clarify the financial obligations among the Partnei"
agencies.
The addendum also increases the cap for the ongoing capital improvement budget. The-
existing cap is ambiguous and is based on the original value of the RWQCP. The capital
improvement program will continue to be reviewed by the Partner agencies prior to approval
by Palo Alto City Council.
CMR.: 165:98 Page 1 of~"-~
RECOMMENDATION
Staff recommends that Council:
Direct staff to proceed with the necessary steps to obtain bond financing for
rehabilitating the incinerators at the Water Quality Control Plant (RWQCP). Bond
financing would occur concurrently with the beginning of construction, approximately
August 1999. Prior to the bond sale, staff will return to Council for approval of the
bond documents.
Approve and authorize the Mayor to execute Addendum No. 6 to the Basic Partners
Agreement between the City of Palo Alto, the City of Mountain View, and the City of
Los Altos. Addendum No. 6 increases the annual budget cap for ongoing capital
improvements, and defines Partner obligations to reimburse Palo Alto for the future
costs of debt service for bond financing of RWQCP incinerator rehabilitation project.
BACKGROUND
The City disposes of solid wastes treated by the RWQCP by means of incineration. In May
1996 (CMR:278:96), staff reported to Council that a recent study had concluded "the
incinerators (at the Plant) have reached the end of their economic life, and that major
rehabilitations are required if the RWQCP is to continue with incineration."
Council approved staff’s selection of the consulting firms CH2M Hill and Kennedy Jencks
to prepare a Solids Facility Plan (Plan) for the RWQCP. The Plan examined the issues and
solutions for continued use of incineration, and evaluated other technologies that replace
incineration.
In May 1997, staffretumed to Council (CMR:236:97) with the results of the Plan. The Plan
was approved by Council, and included:
A two-phase project to rehabilitate the existing incienerators immediately, and in ten
years potentially add a dryer for peak loads if and when needed.
Direction for staff to proceed with financial planning to implement the incinerator
rehabilitation.
Direction to obtain Partners’ approval of the necessary addendum to the existing
Partners’ agreement and financial package needed to implement the Plan.
The Partners" Agreement was originally written in 1968, and has been amended five times
to date. Changes are needed to clarify various financial obligations now that the City of Palo
Alto is preparing to rehabilitate the RWQCP.
CMR: 165:98 Page 2 of 5
DISCUSSION
Staff met several times with the Partner agencies staff to discuss the funding of the project,
and has obtained the advice of a financial advisor, Stone and Youngberg. The financial
advisor and Palo Alto’s outside counsel attended two meetings with the Partner agencies’
staff.
Given the size of the improvements, and the need to spread the cost to ratepayers over a
number of years, and given the varying levels of wastewater financial reserves currently
available to the different Partner cities, staff recommends that the, improvements be bond
funded. As has been done in a previous debt issuance in early 1980, staff recommends that
the City of Palo Alto, as the operator of the RWQCP, be the lead agency in issuing the debt.
This approach was unanimously agreed to by the staff from all Partner agencies. Staff
anticipates selling bonds prior to construction, approximately May 1999. Palo Alto has
sufficient funds in its Wastewater Treatment Fund reserve for the design itself, and will be
reimbursed from bond proceeds later. The attached Addendum requires, that the Partner
agencies reimburse Palo Alto for their share of the bond costs, including the front design
costs, over the life of the bonds. The approximate cos~-for the design is $700,000, and is
included in the proposed FY 1998-99 capital budget for the Wastewater Treatment Fund.
In order to clarify the financial obligations among all Farmer agencies, staffhas worked with
the City Attorney’s Office and outside counsel to amend the current Partner’s agreement.
That addendum is attached to this report and is being submitted to Council for approval.
Staff from the other Partner agencies are also taking this addendum to their respective
Councils concurrently.
Major provisions of the addendum include the following:
The revision of the annual capital improvement budget cap for ongoing repair and
replacement. It will now be set at a base level of $1.9 million for 1998-99, and will be
adjusted annually by the Consumer Price Index (CPI). The existing cap is ambiguous,’
and is based on the original value of the RWQCP. This change is needed to provide for
more budget flexibility in the future.
The annual capital improvement program will continue to be reviewed by staff from
each Partner agency prior to submission to the Palo Alto City Council.
°Authorization for the City of Palo Alto to implement the Solids Facility Plan,-including
rehabilitation of the incinerators: Each Partner city is responsible to pay Palo Alto for
its proportionate share of the rehabilitation.
Authorization for the City, of Palo Alto to issue debt to pay for the rehabilitation, and
requiring the Partners to pay Palo Alto for their proportionate share of the debt service.
CMK: 165:98 Page 3 of 5
Because Palo Alto will issue the debt, it must covenant in its bond documents to raise
sufficient revenues to meet annual debt service requirements. All of the requirements
below are legal commitments that the Partners are making to each other, and are
consistent with the legal commitments Palo Alto will have to make in its bond
documents in order to issue debt.
;
a)In order to protect the City of Palo Alto, and to reassure potential investors, the
Parmer agencies are required by this addendum to raise sewer revenues sufficient
to pay their share of the debt service to Palo Alto in the future. These
clarifications will make the debt less risky to investors, and therefore will help the
Cit-y of Palo Alto obtain the highest rating it can get for the bonds. This will lower
the interest rate, and therefore will lower the financing costs for the bonds. Based
on discussions with Stone and Youngberg, staff expects that the bonds can be sold
at around a double A rating.
b)Specifies that while the bonds are to be issued by Palo Alto, the Partners will
reimburse Palo Alto annually for an amou~ equal to their share of the debt
service.
c)Defines the annual Partner obligations to Palo Alto as special obligations payable
"solely from the net revenues" of the Partners’ sewer systems. (The obligations
are therefore not general obligations of the Partner cities).
d)States that the obligations of Mountain View and Los Altos are unconditional until
the time that debt service is paid off.
e)Obligates the cities of Mountain View and Los Altos to collect sufficient sewer
revenues to pay for at least 1.25 times the annual debt service requirement.
g)
Clarifies that for as long as this debt is still outstanding, no party may issue sewer
bonds for its oWn City that are superior in credit obligation to this debt obligation.
Parity debt, or debt equal in stature to creditors to this debt may be issued
provided that the Partner city continues to collect revenues at least 1.25 times its
total level of debt service. Clarifies that revenue growth due to sewer expansions
by Partner cities, such as a new development, may be counted towards the revenue
requirement of 1.25 times debt service.
Clarifies that neither Mountain View nor Los Altos are liable for each other’s
obligations to Palo Alto.
S . EMP T
Funds for the capital improvements are being proposed in the 1998-99 Wastewater Treatment
capital improvement budget. 1998-99 funding inctudes $700,000 for design, and future
years" capital budgets will include construction dollars. Those dollars and design costs, will
CMR: ! 65:98 Page 4 of 5
be reimbursed out of bond proceeds in approximately August 1999. Capital expenditures for
design and construction are estimated to cost a total of approximately $6.2 million.
ENVIRONMENTAL REVIEW
On February 23, 1998, Council approved the Negative Declaration and the project to
rehabilitate the RWQCP’s incinerators, CMR: 141:98.
TIMELINE
Attached is a rough timeline for the project:
City Councils of Partner cities approve addendum
Palo Alto awards design contract
Final design completed
Sell bonds
Begin construction
Finish construction on incinerators
March 1998
April 1998
February 1999
August 1999
August 1999
August 2001
POLICy IMPLICATIONS
The recommendation of this staff report is consistent with City policies,
ATTACHMENTS
Addendum No. 6 to Basic Agreement
PREPARED BY:Bill Miks, Manager RWQCP
Jim Steele, Manager Investments and Debt
DEPARTMENT HEAD: Glenn S.
Melissa
berts, Director
Acting:
ublic Works
of Administrative Services
CITY MANAGER APPROVAL:
JUNE
City Manager
CMR: 165:98 Page 5 of 5
ADDENDUM NO. 6 TO BASIC AGREEMENT BETWEEN THE
CITY OF PALO ALTO, THE CITY OF MOUIqTAIN VIEW
Ah’D THE CITY OF LOS ALTOS FOR ACQUISITION,
CONSTRUCTION A!hTD 5LkINTENA~CE OF A JOINT SEWER
SYSTEM
This Addendum No.’ 6 to ~asic Agreement is made and
entered into on , 1998, by and among the CITY
O? PALO ALTO ("Palo Alto"), the CITY OF MOUNTAIN VIEW ("Mo[~nEain
View"), and the CITY OF LOS ALTOS ("Los Altos") (individually,
"Party", and collec~vely, the "Parties"), all municipal
corporations under the laws of the State of California.
i. The Parties have entered into an agreemen~ for the
acquis!tion~ construction, nnd maintenance of a joint sewer system
("Joint sewer’"), executed o~ October I0, 1968, and as amended from
time to ~ime ("Basic Agreement"). The Basic Agreement has been
amended five times on 1977, 1980, 1985, 1990 and 1992, respectively
(collectively, "Addenda").
2. Palo Alto is the administrator of the Joint Sewer
and is responsible for capital additions. Under the Basic
Agreement and Addenda thereto, capital additions for the
replacement of obsolete or worn-out units or minor capital
additions to improve the efficiency of the plant operations shall
not exceed two percent (2%) of the total capita! investment in any
one year, except.with the prior written approval of the Parties
hereto.
3. .The solids Management Study of June 1995 prepared by
Carollo Engineers concluded that. the incineration facility needs to
bc rebuilt or replaced. The Solids Facility Pl~n of May 1997
prepared by CH2M HILL recommended a two-phase project to rebuild
the existins incineration facility portion of the Joint Sewer. The
Parties desire tO implement the recommended project, and,
accordingly, hereby revise the Basic Agreement and ~he AddeI~da
thereto, to provide for the rehabilitation of the inciuerator
facility portion of the Joint System, and i~crease the total
capita! investment in capital additions.
NOW, THEREFORE, in consideration of the terms, conditions
and covenants set forth in this Addendum No. ~ to Basic Agreement,
the Basic Agreement is hereby amended as follows:
~F~.¢TION I. Subparagraph 8(e) is hereby amended in its
entirety to read as follows:
2
SHARING OF COST~.q OF
~,ODIFIC~TrO~_~ID REHABILITATION OF THE
CON STR U CT ~ 0[{.
(e) Capital additions for the replacement of obsolete or
worn-out units, or minor capital additions to improve the
cfficiency of the plant operations, shall not exceed the amount
specif£ed for the base year adjusted annually in accordance with
the Consumer Price Index-Urban Wage Earners and Clerica! Workers
for the San Francisco-Oakland-San Jose area ("CPI"]. The base year
shall be fiscal year 1998-19S9. The capital addition amou~]t for
the base year is set at 1.9 million dollars. The CPI for the
twelve (12) months prior to Ju].y of each fiscal year shall be used
to calculate the adjusted.capital addition cost for the following
fiscal year."
SECTIO~ 2, Paragraph 36 is hereby added to the Basic
Agreement to read as follows:
"36. IMPLEMENTATYON O2_THE ~0LIDS FACI~.~TY P~AN, PALe
ALTO, MOUNTAIN VIEW, and LOS ALTOS approve a two-phase project to
in, mediately rehabilitate, the incinerators as soon as possible an~
add a dryer for peak loads in approximately ten (i0) years in
accordance with the Solids Facility Plan prepared by CH2M Hill,
consulting engineers. The funding~ for the incinerator
rehabilitation will be developed as soon as possible by each of the
Parties, wh~le the funding for the dryer w~ll be deferred until
needed.’ As determined by each Party, each Party shall proceed to
pay for the rehabilitation of the incinerators in proportion as the
Parties own capacity in the Joint System or portion thereof as
shown in Exhibit "H". If the Parties intend to defray the costs of
rehabilitation through Pale Alto’s issuance of debt for the
rehabilitaZion, the Parties shall pay £o Pale Alto their
Proportionate Share of Debt Service in accordance with Addendum 4
of the Basic Agreement, as revised by Section 3 of this Addendum
SECTIQN ..i. Section 5 of Addendum 4 to the Basic
Agreement is hereby amended in its entirety to read as follows:
"(a) D_~.~initions. For purposes of this Section 5, the
followin~ capitalized terms shall have the meanings set forth
below.
’Bond Do=umen~s’ meansthe bond resolutions, indentures,
t~ust agreements, installment sale agreements or other dozuments
under which Bonds are issued.
’Bonds’means bonds, installment sale agreements or ether
obligations already issued or to be issu4d by the City of Palo Alto
to finance improvements, additions or extensions to the Joint
System, payable from the ’Net Revenues’, as defined in the Bond
Documents.
’Debt Service’ means, for any period in question, the sum
of the debt service on the Bonds due and payable in such period.
’ Gross Revenues’ means all gross income and revenue
received by either Mo%~ntain View or Los Al~os from the ownership
and opel’ation of its Sewer System, including, without limiting the
generality of the foregoing, (a) all income, rents, rates, fees,
connection fees, cha1"ges or other moneys derJ.ved from the services,
facilities and corn.modifies sold, furnished or supplied through the
facilities of its Sewer System, (b) reserves on deposit in the
sewer utility enterprise fund of Mountain View or Los Altos, as
~appropriate, including unrestricted cash available and (c) the
earnings on and income derived from the invest~..ent of such income,
ren~s, rates, fees,, charges or other moneys to the ex’.ent that the
use of such earnings and income is limited by or pursuan~ to the
law to its Sewer System (including interest earnings on reserves)~
¯ provided, however, that the term ’Gross Revenues’ shall not include
customers’ deposits or any other deposits subject to refund until
such deposits have become the p~-operty of Mountain View. or Los
Altos, as appropriate.
"Joint System’ has the meaning given to said term in the
Basic Agreement.
’Net Revenues’ means Gross Kevenues less Operation and
Maintenance Expenses.
’Operation and Maintenance Expenses’ means all expenses
and costs of management, operation, maintenance and repair of a
Sewer System, bu~ excluding debt service or other simila~ payments
on Parity Debt or other obligations and depreciation and
obsolescence ~charges or reserves therefor and amortization of
intangibles or other bookkeeping entries of a similar nature, and
any expense classified.as discretionary by Mc\~ntain View or Los
Altos tc the operation of its Sewer System.
9{~0304 I-,~ 003191 }
’Parity Debt’ means bonds, indebtedness o[" other
ob!ig~tions (including leases and installment sale agreements)
hereafter issuedor incurred by Mountain View or Los Altos and
secured by a pledge of and.llen on Net Revenues equall)’ and ratably
with Mountain View’s cr Los Altos’s Proportionate Share of Debt
-Service. :
’Part}" means the city o£ Palo Alto, Mountain View or Los
Altos. ’Parties’. means the Cities of Palo Alto, Mountain View and
Los Altos.
’Proportionate Share’ has the meaning given to said term
in ~he Basic Agreement.
’Sewer System’ means any and all properties and assets,
real and personal, tangible and intangible, of Mountain View or Los
Altos, now or hereafter existing, used or pertaining to the
disposal or reuse of wastewater, including sewage treatment plants,
intercepting and collecting sewers, outfall sewers, force m~i,]s,
pumping stations, ejector stations, pipes,.valves, machinery mnd
all other appurtenances necessary, useful or convenient for the
collec~ion, treatment, purification or disposal of sewage, and any
necessary lands, rights of way and other real or personal property
~seful in connection therewith, and all additions, extensions,
expansions, improvements and betterments thereto and equippings
thereof.
’Subordinate Debt’ means indebtedness or other
obligations (including leases and installment sale agreements)
hereafter issued or incurred by Mountain View or Los Altos and
secured by a pledge of and lien on Net Revenues subordinate to the
obligation of Moustain View or Los Altos to pay its Fropor~ionate
Share of Debt ~Service.
"(b) ,Issuance_of_Bonds by P_~io~ Alto: Spe~qns
.of Mountain View and ~,o~Altos.
Palo Alto has issue~ Bonds to finance the Joint system,
and expects to issue Bonds in the future to finance improvements to
theJoint System. Under the Bond Documents, Palo Alto is obligated
to pay 100% of the Debt Service. In consideration of the issuance
and pa)~ent of the Bonds by Palo Alto to finance the Joint System,
Mountain View and Los Altos agree to pay their proportionate Share
of Debt Service, payable solely from Net Revenues, as hereinafter
proyided.
Mountain View’s and Los Altos’s obligation to pay their
Pz’oportionate Share of Debt Service shall be a special obligation
limited solely to Net Revenues. Under no circumstances shall
Mountain View or Los Altos be required to" advance any mcne},s
derived from any source of income other :than the Net P.evenues and
6thor sources specifically identified hereln for the payment of
their Proportionate Share of Debt Service, nor shall any other
funds or property of Mountain View or Los Altos be liable for the
payment of their Proportionate Share of Debt Service.
The obligation of Mountain View and Los Altos to pay
their Proportionate Share of Debt Service from Net Revenues and to
perfor~:, and observe the other asreements contained herein shall be
absolute and unconditional and shall not he subject to any defense
or any right of set-off, counterclaim or recoupment arising out of
any breach of a Party of any obligation to another Party or
o~herwise with respect to either of theil’-Sewer systems, whether
hereunder or otherwise, or out of indebtedness or liability at any
time owing to Mountain View or Los Altos by another Party. Until
such time as all of the Debt Service shall have been fully paid or
prepaid, Mountain View and Los Altos (a) will not suspend, abate,
or discontinue any payments provided for herein, (b) will perform
a~d observe all other agreements contained in this Agl’eement, and
(c) will not terminate this Agreement for any cause, inc].uding0
withou~ limiting the generality of the foresoing, the occurrence of
any acts or circu~stances that may constit~Ue failure of
consideration, eviction or constructive eviction, destruction of or
damage to their Sewer Systems, the taking by eminent domain of
title to cr tem, porary use of any or all of either of their Sewer
Systems, commercial frustration of pu~.-pose, .any change in th=. tax
or other laws of the United States of America or of the State or
any political subdivision of either thereof or any failure of a
Party to perform, and observe any a~reement, whether express or
i,lplied, cr any duty, liability or obligation arising out of or
connected with this Agreement.
"(c) pledme of ~e[ Revenu..e~.
(i) Pledge of Net Revenues. Mountain View and Los
Altos hereby agree that the payment of their Proportionate Share of
Debt Service shall be secured by a pledge, charge and first and
prior lien upon their Net Revenues, and Net Revenues sufficient to
pay their proportionate Share of Debt Service as the same becomes
due and p~yable are hereby pledged, charged, assigned, transfe£red
and. set over by Los Altos anl ~<ountai:l View te Palo Alto and its
assig~s for the purpose of securing payz:en% of their Proportionate
Share of Debt Service. The Net Revenues shall constitute a trust
fund for the security and payment o£ Mountain View’s and Los
Altos’s Proportionate Share of Debt Service.
[ii) Release from ’Lien. Following the payments by
~:n.untain View and Los Altos to Pale Alto o~ their Proportionate
Shnre of Debt Service, Net Revenues in excess of amounts req<~ired
for the payment of such Proportionate Share of Debt Service~ in
thmt Fiscal Year, shall be released from the lien of this Agreement
and shall be available for any !mwful purpose of Mountain View or
Los Altos, as applicable.
"(d) Rate Covenant.
Mountain View and Los Altos hereby covenant that they
shall p[escribe, revise and collect such charges for the services
and facilities of their respective Sewer Systems which, after
allowances for contingencies and error in the estiEates, shall
produce Gross Revenues sufficient’ in each Fiscal Year to provide
Net Revenues equal to 1.25 times (i) their Proportionate Share. of
Dsbt Service coming due and payable during such Fisca! Year, and
(~i) all payments required with respect to Pari.ty Debt.
LimitatioD9 O/l_F_P~ure Obliq@tions Secured by Net;
(i) No Obligations Superior to Debt Service. In
order to protect further the availability of the Net Revenues and
the security for the Debt Service, Mountain View and Los Altos
hereby agree that they shall not, so long as any Bonds are
outstanding, issue or incur any obligations payable from Gross
Revenues or Net Revenues superior to their obligation to pay their
Proportionate Share of Debt Service.
(ii) Parity Debt. Mountain View and Los Altos
further covenant that, exceFt for obligations issued or incurred to
refund any obligations secured by Net Revenues, they shall not
issue or incur any Parity Debt unless:
(A)The Party proposin9 to issue the
Parity Debt is not in default under
the terms of this Agreement; and
Net Revenues, calculated on sound
accounting principles, as shown by the
books of the Party proposing to issue
9,~0]04 I~*c 001191~
the Parity Debt, for the latest Fiscal
Year or any more recent twelve (12)
month period selected by the Party
proposing to issue the Parity Debt
ending not more than sixty (60) days
prior to the adoption of the
resolution pursuant to which
instrument such Pagity Debt is issued
or i~curred, as shown by the boo}~s of
the Party proposing to~ .issue the
Parity Debt, shall have ~mounted to at
least 1,25 times such Party’s maxi~.ulm
Properticnate Share of Debt Service,
plus, maximum annual debt service on
such Party’s Pa~’ity Debt coming due
and payable in any future Fiscal Year’.
(iii) Adjustment to Net Revenues. Either or both
of the following items may be added to such Net Revenues for~ the
purpose of applying the .restriction contained in subsection (ii) (B)
of this subsection (e):
An allowance for revenues from any
additions to or improvements or
extensions of the Sewer System to be
constructed with the proceeds of such
additional obligations, and also for
Net Revenues from any such additions,
improvements or extensions which have
been constructed ’from any source of
funds but which, during all or any
part.of such Fiscal Year, were not i~
service, all in an amount equal to
estimated additional average annual
Net Revenues~ to be derived from such
~additions, improvements and extensions
for the first 36-month period
following issuance of the proposed
Parity Debt, all as shown by the
certificate or opinion of a qualified
independent consultant employed by
Mountain View or Los Altos, as
appropriate.
An allowance for earnings arising from
any increase in the charges made for
service from the Sewer System which
has become effective prior to the
incurring of such additional
obligations but which, during all or
any part of such Fiscal Year, was not
in effect, in an amount equal to 100%
of the amount by which the Net
Revenues would have been increased if
such increase in charges had been i~i
effect during ~he whole of sucl~ Fiscal
Year and any period prior to the
incurring of such a~ditional
obligations, as shown by the
certificate or opinion of a qualified
independent consultant employed by
Mountain: View or Los Altos, as
appropriate, or upon the mutual
agreement of the other parties.
(iv) Subordinate Debt. Mountain View and Los Altos
~ay issue or incur Subordinate Debt so ions as it is not in default
hereunder or under any Parity Debt.
"(f) Compliance WIEh Lsw.
The Parties agree that they shall co~nply with provisions
of the Constitution and laws of ~he State of California, including
specifically Article XIIIC and Article XIIID of the California
Constitution. In the event a Party fails to comply with the
foreHoing covenant, any other Party may bring an action against the
Party in breach, and seek all remedies available at law or in
equity, including specific performance.
Joint and S~v_~r.~l~Liability.
Neither Mountain View nor Los Altos shall be liable for
the debts or obligations of another Party pursumnt to this Section
5, and no~hing contained in this Section 5 is intended, nor shall
it be interpreted, to create joint and several liability of
Mountain View or Los Altos."
SECTION 4. Except as herein modified, the BRsic
Agreement and all Addenda thereto shall remain unchanged, and they
are hereby ratified and confirmed.
//
//
/!
IN WITNESS WHEREOF, the parties have by their dul~’
authorized representatives executed this Amendment on the date
first above written.
ATTEST:CITY OF PALO ALTO
City Clerk
APPROVED AS TO FORM:
Mayor
Senior Asst. City Attorney
APPROVED:
Assistant City Manager
Director of Public Works
ActinH Director of
Administrative Services
Kisk Manager
ATTEST:CITY OF MOUNTAIN VIEW
City Clerk
APPROVED AS TO FORM:
City Manager
APPROVED AS TO CONTENT:
City Attorney Public Services Director
i0
:FINANCIAL APPROVALI
Finance and Administrative
Services Director
ATTEST:CITY OF LOS ALTOS
City Clerk
APPROVED AS TO FORM:
City Attorney
City Manager
APPROVED AS TO CONTENT:
Director of Public Works
CERTIFICATE OF ACKNOWLEDGMENT
(Civil Code § 1189)
STATE OF )
.C )ss.
COUNTY OF )
On _, before me, ,
.~ notal-y public in and for said County, pcrs~nally appeared
, pel-sonally known to me
(or proved to me on the basis of satisfactory eviden=e) to be the
person(s) whose name(s) is/are subscribed to the within instrum~_nt,
and acknowledged to me that h~./she/~hey executed the same in
his/her/their authorized capacity(ies), and that by his/her/their
signature(s) on the instrument the person(s), or the entity upon
behalf of which the person(s) acted, executed the instrument.
WITNESS my hand and official seal.
00319~ 3
11
CERTIFICATE OF ACKNOWLEDGMENT
(civil Code § 1189)
STATE OF )
COUNTY OF )
On ........, before me,,
a notary public in and for said County, personally appeared
, personally known to me
(or proved to me on the basis of satisfactory evidence) to be the
person(s) whose name(s) is/are subscribed to the within instrum.ent,
and acknowledged, to me that he/she/they executed the same in
his/her/their authorized capacity(ies), and that by his/her/their
signature(s) on the instrument ~he person(s), or tile entity upon
behalf of which the person(s) acted, executed ’the instrument.
WITNESS my hand and official seal.
910.’104 h: 00,I 191f"
CERTIFICATE OF ACKNOWLEDGMENT
(Civil Code 5 1189)
STATE OF )’.
COUNTY OF )
On , before me, ,
a notary public in and for said County, personally appeared
, personally known to me
(or proved to mc on the basis of satisfactory evidence) to be th~
person(s) whose name(s) is/are subscribed to the within instrument,
~nd acknowledged to me that he/she/they executed ~he Same in
his/her/their authorized capacity(ies), and that by his/her/their
signature(s) on the instrument the person(s), or the entity upon
behalf of which the person(s) acted, executed the instrument.
WITNESS my hand and official seal.
980304 L,~ 0031915
13
ATTACHMENT E
City of Palo Alto
City Manager’s Report
TO:HONORABLE CITY COUNCIL
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, ree;caluate 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 1 of 8
RECOMMENDATIONS
Staff recommends that Council:
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.
o 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 staffto 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
buming, 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. Concems with the incinerators
were discussed in earlier staffreports, (CMR:278:96 and CMR:236:97), and are summarized
below.
The first concern is reliability: The incinerators were constructed in 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 concern 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:I41:9g 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 biosolids. 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 biphen01s (PCBs) and organochlorine pesticides (e.g. DDT), are destroyed
in the incinerators. Thus, when the ash from the incinerators is applied to land, it contains
less pollutants than the residue from digestion or drying.
It is difficult to compare the environmental effects of the three options. Staffwas 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 a!so 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 safetyrequirements Therefore, staff focussed
on the following criteria in comparing the options:
®
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:I41:98 Page 4 of 8
agreements, which is consistent with past capital financing. The dral~ 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, staffbelieves 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. Staffis also recommending the development of specific
policies to achieve reductions of releases of mercury, dioxins, and organoehlodne 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 immediate!y. 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:,I 41:98 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, staffwould 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 longterm 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 sta~ed on January 16, 1998 and ended on February 14, 1998.
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 final 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 o 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:.
~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
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
San Francisco Bay
Not To Scale
PALO
ALTO
To San Jos~
PALO ALTO
Figure 1
Service Area
Palo Alto Regional Water Quality Control Plant
0
(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
Simplified PARWOCP $¢hema#c
Wastewater
PARWQCP
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 incineraiors, 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:
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
<o
Figure 5
Currant Incinerator Process
Residual
Solids’----~
Incinerator
f Atmosphere
Air Scrubber
Afterburner
Cooling Hearth
Residual
Solids ~
Ash
Afterburner
Cooling Hearth
Burning
Hearths
Incinerator
The fast goaJ of the’ proposed Project is to make repairs to the two incinerators that will
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 crocks
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. cbmponents are proposed. The first
component, a true (separate) afterburner, will be constructed to allow the top hearth to be
used to bum 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 Project 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
wouldonly 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 (IVIGD) from the PARWQCP’s service area of approximate 220,000
Figure 6
Proposed/ncinera#on System
Residual
Solids
Incinerator
2-Stage Scrubber
[Afterburner]
Stack Gas
Atmosphere
[
[
Cooling Hearth
Ash
Farmland
2-Stage Scrubber
Afterburner ]
Stack Gas
Residual ~ ~ ~
Solids ~~
Cooling Hearth ~
Incinerator
Burning
Hearths
people. The wastewater treatment processes (as distinguished fi’om 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 (DT/D) (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/I). While it could be argued that the capacity of incinerator system would then be
64 DT/I) (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 Capaci~,
Wastewater Treatment
Processes
Incineration System
1996 VALUES CURRENT MAXIMUM
CAPACITY
PopulationThroughput
Average
24 MGD
17 DTD
220,000
220,000
*Average
Throughput
Capaci~
38 MGD*
60 DTD°*
Approximate
Population
Equivalency
350,000
410,000
"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 capacity of the PARWQCP. A major capi~l improvement
project for the wastewater treatment processes and regulatory agency approval would both be
required to increase the capacity of the wastewater.treatment 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 ste~Iplate patches on the shell
Replace hearths (including flattened hearth) as needed
Repaint 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 locati~in 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 e~nstrueted 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 be25
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 weathei" 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 explosions, 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 fife hazard.
The proposed thermal dryer uses indirect drying, in which fuel is eombusted 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 ~o 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 con~ol, the foul air created during the thermal drying
process will be discharged to the incinerator inlet air stream as part of the inlet ,’. ...~ustion
air. This air eventually flows to the incinerator air emissions control system and heii~ in fuel
savings in incinerator operations since it is heatedi 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 plant.
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 signlficani 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 sigrfi.ficant
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.)
Agency
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
:Permits/Issue
Authority to ConsU’uct (A/C) and Permit to
Operate(P/O) - if grandfather status is not maintained,
then will be needed (existing facility attained
grandfather stares 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 co~ts are
not greater than 50% of the capital cost of a new
incinerator)
Clean Water Act: 40 CFR Part 503 Rules--proposed
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
E1Energy and Mineral Resources
[]Hazards
[]Noise
[] Mandatory Findings of
Significance
[]Public Services
[]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 effect on the
environment, and a NEGATIVE DECLARATION will be prepared.
I find that although the proposed project could have a significant effect on the
environment, there will not be a significant effect in this case because 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 I) 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
17
Evaluation of Environmental Impacts:
1)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 folio’sang 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 outside a 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).
2)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. -
4)"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).
5)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.
6)Lead agencies are encouraged to incorporate into the checklist references to information sources for
potential impacts (e.g. general 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..
7)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)
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?
d)Affect agricultural resources or operations (e.g.
impacts to soils or farmlands, or impacts from
incompatible land uses)?
e)Disrupt or divide the physical arrangement of an
established community (including a low-income or
minority community?
I1. POPULATION AND HOUSING. Would the
proposal:
a)Cumulatively exceed official regional or local
population projections?
b)
c)
Induce substantial growth in an area either directly
or indirectly (e.g. through projects in an
undeveloped area or extension of major
infrastructure)?
Dispi’ace existing housing, especially affordable
housing?
IlL GEOLOGIC PROBLEMS. Would the proposal
result in or expose people to potential impacts
involving:
a) Fault"rupture?
b) Seismic ground shaking?
Sources
3
3
Potentially
Significant
Impact
Negative
Declaration:
Potentially
Significant
Unless
Mitigatibn
Incorporated
Less Than
Significant
Impact
No
Impact
19
Issues (and Supporting Information Sou~’ces):
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?
’ 19 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
1,3
3
3
1,3
Potentially
Significant
¯ Impact
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 quality violation?
b) Expose sensitive receptors to pollutants7
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?
~ 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
1
1
1
I
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):
b) Loca:. ,’ designated species (e.g. heritage trees)?
c)Locally designated natural communities (e.g. oak
forest, coastal habitat, etc.)?
d)Wetland habitat (e.g. marsh, riparian and vernal
pool)?
e)
VIII.
a)
b)
c)
Wildlife dispersal or migration corridors?
ENERGY AND MINERAL RESOURCES.
Would the proposal:
Conflict with adopted energy conservation plans?
Use non-renewable resources in a wasteful and
inefficient manner?
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)?
b)Possible interference with an emergency response
plan or emergency evacuation plan?
c)The creation of any health hazard or potential health
hazards?
d)Exposure of people to existing sources of potential
health hazards?
e)Increased fire hazard in areas with flammable brush,
grass, or trees?
X. NOISE. Would’the proposal result in:
a) Increases in existing noise levels?
Sources
1
I
Potentially
Significant
: Impact
1,2
1
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) M;iintenance of public facilities, including roads?
e) Other governmental services?
Xll.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?
XIII. AESTHETICS. Would the proposal:
a) Affect a scenic vista or scenic highway?
b) Have a demonstrable negative aesthetic effect?
Sources
1
1
1
1
1
1
1
1
I
1
i
Potentially
Significant
., Impact
Negative
Declaration:
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
NO
Impact
23
Issues (and Supporting Information Sources):
c) Create light or glare?
Sources
Potentially
Significant
~. Impact
Negative
Declaration:
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
XIV. CULTURAL RESOURCES. Would the proposal:
a) Disturb paleontological resources?
b) Disturb archaeological resources?
c) Affect historical resources?1,2
d)Have the potential to cause a physical change which
would affect unique ethnic cultural values?
1,2
Restrict existing religious or sacred uses within the
potential impact area?
1,2
XV. RECREATION. Would the proposal:
a)Increase the demand for neighborhood or regional
parks or other recreational facilities?
1,2
b) Affect existing recreational opportunities?1,2
XVI.MANDATORY FINDINGS OF SIGNIFICANCE.
a)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?
NO
Impact
24
b)Does the project have the potential to achieve short-
term, Io 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 environmen .tal effects which
will cause substantial adverse effects on human
beings, either directly or indirectly?
XVII. 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:
a) Earlier analyses used, Identify earlier analyses and state where they are available for review.
b)
c)
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.
Miiigation 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 site-specific conditions for the project.
XVIII. SOURCE REFERENCES
1 Paio Alto Regional Water Quality Control Plant, Solids Facility Plan, May 1997
2 Paio 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 Paio 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
]a The proposed project is consistent with the existin~ 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 Pale Alto Airport. The Pale Alto Golf Course is also located just wes~ of the
airport. Much of the PARWQCP site is screened from these land uses by trees along its perimeter. However, the access
road to the land’ ~uns directly along the east plant boundary, so some PARWQCP facilities, such as the fixed film
reactors, are clcz~ ~’isible. The proximity to the airport places height restrictions on the treatment facilities. Thc top
of the existing inc;,’~erat0rs are generally considered the maximum height allowed.
I b The proposed project does not conflict with any applicable environmental plans or policies adopted by agencies wit.-
jurisdiction over the project.
I c The proposed project would not be incompatible with existing land use in the vicinity. Modificati0n~ 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.
I1 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 to 7 of the attached
project description.
I1 c The proposed project is limited to the existing treatment plant site and would not displace any existing housing.
111 a The proposed project is not located on a fault and would not result in or expose people to fault rupture.
III b The Pale 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 w!ll
be incorporated into the project.
III c
Iii d
III e
III f
111 g
III h
lll i
IVa
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 to liquefy. According to’ the City of Pale Alto
Comprehensive Plan, the site has a high liquefaction potential. The geotechnical, investigation to be prepared for the
project will identify appropriate design measures that will be incorporated into the project to address liquefaction
ISSUES.
The ’proposed project would not result in or expose people to seiche, Tsunami, or volcanic hazard.
The proposed project would not result in or expose people to landslides or mudflows.
The proposed project would not result in or expose people to erosion, changes in topography or unstable soil conditions
from excavation, grading, or fill.
The proposed project would not result in or expose people to subsidence of land.
The proposed project would not result in or expose people to potential impacts from expansive soils.
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.
The proposed project would be constructed on currently paved ground and would not add paved area. Hence the ~
proposed project would not result inany changes in abso~tion rates, drainage patterns, or the rate and amount of
IXX. EXPLANATIONS F’OR CHEcKLIsT RESPONSES
IV b
IVc
surface runoff.
The treatment plant site is in a flood zone, as designated by FEMA. However, the proposed project would not result in
an)’ additional exposure of people or property to water related hazards such as flooding. All applicable FEMA
requirements will be met.
The air pollution conirol equipment in the proposed project would recycle trace amounts of metals from the scrubber
back to thc treatment 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.
The proposed project Would not chang~ the amount of surface water in any water body.IV d
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
public water supplies.
V a Construction-related emissions, such as dust (fine paniculate matter, PMto), 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 dust 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 t 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 will handle 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 track 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
air quality impacts would occur.
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
Vc
proper abatement"~quipment installation (including scheduled shutdown of in’~inerators during installation), testing,
operating procedures to minimize any potential air emission impacts to workers in the light industrial businesses near
the project site.
The project does not include’the addition or modification of major heat or moisture sources ~nd would not result in a
significant alteration of air movement, moisture, temperature, o.r other climatic changes.
The dryer, which would only be operated only occasionally (typicaliy m~ximum 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.
VI a Facility construction will have a less than significant impact on traffic. The number of trucks to haul solids by-product~-
(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.
Vl b The proposed project does not contain any transportation design features and would not result Jn 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 rcsuk 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
aedestrians 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 poli~ies supporting altemativetransponation.
V! 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 pan 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 compa~:ed 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
VII c
vli d
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 invasive and have the potential to damage building foundations, pipes, and high voltage conduits.
The proposed project would not result in impacts to locally designated natural communities such as oak forest or
coastal habitat.
The incinerator abatement air scrubber would’ recycle trace amounts of metals removed from the air stream back to the
~lant 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
IXX. EXPLANATIONS FOR CHECKLIST RESPONSES
VII e
VII1 a
VIII b
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.
VIII c 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.
IX a
IXe
Xa
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 result; 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
VIld may need to be recycled or handled as a hazardous waste. Amounts that would be removed would be small and
are estimated to bc approximately 0.1 lb/year for the lighter 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.
The proposed project area does not contain flammable brash, grass, or trees, and the proposed project would not
increase fire hazard in areas with flammable brush, grass, or trees.
The proposed project may result in short-term increases in existing noise levels associated with c.onstruction 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.
X’i c The proposed project would not affect or result in a need for new or altered schools.
Xld
XI e
XII a
The proposed project consists of rehabilitation and modifications to a public facility (a portion 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.
The proposed project would not affect or result in a need for any other new or altered governmental services.
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 The proposed project would not result in a need’ for new systems or supplies of or substantial alterations to
communications systems.
XII c 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. .~
XII d The proposed project Would not result in a’"need for new systems or supplies of or substantial alterations to sewer or
septic tanks.
Xll e The proposed project would not resuliin a need for new systems or supplies of or substantial alterations to storm water
drainage.
XlI 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 sc~’nic vista or scenic highw’ay.
XIII b The proposed project would not have ’~ demonstrable negative aesthetic effect. The"new facilities would be within the
existing 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 di’sturb 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.
XlV 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
Criteria Pollutant5
Carbon monoxide
Nitrous Oxides
Sulfur oxides
THC
Particulate matter
Volatile Organic Carbons
Hazardous Air Pollutants
Dioxin
Furans
Metals
Arsenic
Beryllium
Cadmium
Chromium
Copper
Manganese
Mercury
Nickel
Selenium
Zinc
(Ib/day)
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
i.23 x 10-2
9.01 x 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 IO-4
1.64 x 10"1
AuthoriD’: Public RcsourccsCodc Sections21083 and21087.
Reference: Public Resourccs Code Sections 21080(c). 21080.1.21080.3. 21082. I, 21083.21083.3, 21093, 21094. 21151;
Sundstrom v. County of Mendocino, 202 Cal. App. 3d 296 (1988); Leonoff r. Monterey Board of Super~,isor~, 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 tha0
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
incin, .... tion. Dioxin production is a major concern. The staff was able to show that so
muct:, oxin 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 harmfu 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, Mana.ger, Environmental Compliance Division, PARWQCP
Daisy Stark, Engineer, PARWQCP J
ma~n telephone no.
65o.32x.x994
facsimde 650.321.1995
Schools Group 650~325.5690
Polo Alto City_Council
City, Hall
250 Hamilton Ave.
Palo Alto, CA 94301
P [ O PL E FOR THIr ENVIRONMENT
_ATTACHMENT D
"71~ Colorado Avenue, Suite 1 "
Polo Alto, California 94303.3913
email baactioneigc.or~
http://www,bo a ct~on,org
Feb. 13, 1998 :’ ’ ,’ "\
Dear City Council,
On February 23, Polo Alto City Council ~s scheduled to consider the "WQCP. Solids Management l~roject.’’ Bay Area Adtion and
a number of other local environmental groups ifi conjuction with City staff, have been reviewing the proposed plan to repair.the,
incinerators at the Palo Alto Regional Water Quality Control Plant (RWQCP). According tO reports prepared for the RWQCP, as
w~ell as numerous other supporting documents, there are serious health and environmental eghe’ems~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 decisibn ¯
about this projec~t, r . .. ....
According to "Dioxins Source Identification," a report written for the RWQCP in ~ept. 1997, dioxini; enter the RWQCP through
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 process. The city staff estimates
that th.e incinerators release halt~as many dioxins ihto the environment as come into the plant from the above mentioned sources;
however, there is a high level of uncertainty of how man’y di0xins re-form after being released into th~ a, ir, which may~ske~ this
approximation. Dioxins are also released from the incinerators through the water efflueiat and through the ash. The water effluent
pollutes the bay, and the ash is shipped to the Central Valley and used in agriculttfl’e, thus completing the circle of~ contaminating
our food supply. , "
Dioxins are a highly toxieby-product created frbm the ’" " ’ ’ " " ’" ’" ’productmn and mcmeratton of chlorine-containing products, such as
organochlorine pesticides, polyvinyl chloride’(PVC) plastics, and polychlorinated biphenyls (PCBs).’’~ Dioxins are dangerous to’
humans and wildlife, because they bioaceumulate 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 development and fertility.’’z We highly recolnmend that thecouncil review this document as well as ¯
the :’Dioxins Pollution Prevention Plan," which was prepared for the RWQCP in October 1997 before th~ Feb. 23 council ..
meeting. Both docufnents el;acidate the necessity to reduce the amount of dioxins going to and coming from the RWQCP. : ’ ¯
In addition to the sources of di~xins directly affecting the RWQCP, ~i9% of dioxins emitted locally come from diesel-fueled’.
motor vehicles, and another 15% from residential wood burning. Although these sources fall outsidd the scope of the.WQCP
Solids Management Project~ we request that the council take a comprehensive approach to addressing how to reduce the amount
of~lioxins in our environment. Some suggested approaches are as ,follows:’ "’
~ Develop a dioxins reduction policy for the.City of Palo Alto, and r~quest neighboring cities to do the sameBuild a solids thermal dryer to pilot test a non-dmxm creating alternative to handhng sewage sludge
~Explore alternatives to safely dispose of sludg~ or’ash whidh contain dioxins .~Educate other publi~ agencies and the public abouffdioxins and provid~ information how to ieduce them ,-
¯Continue to monitor, the influent ahd effluent from the RWQCP for.dioxins , ,,
Please give this serious issue your full consideration.
Thank you’,
Susan Stansbury ¯
l~ay Area,Action ~
Executive Director
~ EIP Associates. 1997. Dioxins Source ldentificatio’n2 Ibid.