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HomeMy WebLinkAbout1999-12-14 City CouncilCity of Palo Alto City Manager’s Report TO:HONORABLE CITY COUNCIL ATTN:POLICY AND SERVICES COMMITTEE FROM:CITY MANAGER DEPARTMENT: PUBLIC WORKS DATE: SUBJECT: DECEMBER 14, 1999 CMR:440:99 SCOPE- OF SERVICES REVIEW OF A REQUEST FOR PROPOSALS FOR CONSULTANT SERVICES TO PERFORM A STUDY TO DEVELOP THE LONG TERM GOALS FOR THE PALO ALTO REGIONAL WATER.QUALITY CONTROL PLANT RECOMMENDATION Staff recommends that the Policy and Services Committee review, comment, and direct staff to issue a Request for Proposal (RFP) for consultant services to perform a study to develop the long term goals for the Palo Alto Regional Water Quality Control Plant (RWQCP). BACKGROUND In February 1998, Council directed staff to establish a process for developing the long term goals for the RWQCP, CMR:141:98. The long term goals will be used by the RWQCP to guide the !ong range plan for environmental management of wastewater within the RWQCP service area. This RFP is for consultant services to assist the RWQCP in a process that would establish a set of sustainable long term goals. DISCUSSION The RWQCP, constructed in 1969, is planned to operate under its current design t~ough the year 2020. At that time the existing treatment system will be updated or replaced. The RWQCP envisions that the wastewater system of the future must respond to the environmental and socioeconomic concerns of its service area. In effect, the system will become consistent with the concept of sustainability in the future. The RWQCP is starting to plan for its future system. The first step of the RWQCP’s planning effort is to develop long term goals. The scope of the consultant services includes: CMR:440:99 Page 1 of 2 ATTACHMENT A A STUDY to develop THE LONG TERM GOALS for the PALO ALTO REGIONAL WATER QUALITY CONTROL PLANT INTRODUCTION In February 1998, Council directed staff to establish a process for developing the long term goals for the Palo Alto Regional Water Quality Control Plant (RWQCP): The long term goals will be used by the RWQCP to guide the long range plan for environmental management of wastewater within the RWQCP service area. This Request for Proposal (RFP) is.issued by the RWQCP for consultant services to assist the City in a process that would provide the RWQCP a set of sustainable long term goals. The RWQCP, constructed in 1969, is planned to operate under its current design through the year 2020. At that time the existing treatment system will be updated or replaced..The RWQCP envisions that the wastewater sYstem of the future must respond to the environmental and socioeconomic concerns of its service area. In effect, the system will become consistent with the concept of sustainability in the future. The RWQCP is starting to plan for its future system. The first step of the RWQCP’s planning effort is to develop long term goals. From these long term goali can flow an examination of alternatives and selections of programs and facilities. This study will provide an open forum for the development of the long term goals. The final report from the study will serve as a guide for selections and decisions on alternatives for the long range plan by describing the long term goals. BACKGROUND INFORMATION RWQCP .SERVICE AREA The RWQCP provides treatment for the sewage from the Cities of Palo Alto, Mountain View, Los Altos, East Palo Alto, the Town of Los Altos Hills, and Stanford University. impacts of changes in the regulations and recommendations on goal setting to encompass the uncertainties. Task 3: Identify. Issues and Concerns Consultant shall assist the City in organizing and conducting meetings and workshops with the stakeholders to identify the concerns. Consultant shall evaluate all issues that are raised, highlight the real issues that need to be addressed, and explain or qualify the "non- issues". .Task 4: Evaluate Issues, Develop.and Prioritize Goals Consultant shall utilize an effective and friendly tool to accomplish this task. Consultant shall evaluate and identify the drivers and the impacts of the issues of concern as directed by the City. The evaluation of impacts shall include all factors such as environment, regulations, economics, technologies, land use. Consultant shall assist the City in conducting workshops to develop the goals that are responsive. Consultant shall prioritize the goals in context with the. "big picture" that would enable the RWQCP to achieve the best overall environmental management of wastewater. Task 5: Obtain Buy-in and Prepare Report ¯Consultant shall assist the City in obtaining support from the stakeholders, prepare the . Goals Report which documents the study, and enumerate the long term goals that will be the guide for long range planning. DELIVERABLES Consultant shall prepare and deliver twenty (20) copies of the draft Goals Report to City for review and comments. Consultant shall respond to all review comments, incorporate comments as appropriate, and submit twenty (20) copies of the final report to City for distribution by City. PROJECT MANAGEMENT Project management shall be an integral part of the Consultant services. The Consultant shall monitor all activities, schedule, and budgets of the project. Consultant shall keep the City informed of the project schedule, budget, and progress on a periodic basis. All activities shall be coordinated through the City Project Manager. MEETINGS AND WORKSHOPS Consultant shall assist the City in meetings and workshops as requested by the City Project 3 P~AYMENT Progress payments for Consultant services shall reflect the amount of effort and percent completion. The cumulative payment shall not exceed the completed percent of the total project fee based on the completed tasks or deliverables. PROPOSAL The Consultant shall submit ten (10) copies of the proposal. The proposal shall provide sufficient information on the Consultant’s experience, knowledge, ability, approach, and understanding of the project. Consultant shall include a statement of qualification and project references with names and phone numbers of the contacts. The proposal shall identify the key members of the project team. The role and the resume of each key member shall be included in the proposal. The proposal shall state the amount of involvement and availability of each .key member. The Consultant shall provide one copy of the fee.information for the basic services, and. ¯ the schedule of charges for the additional services. The fee information and schedule of ¯ ..charges. shall be submitted separately with the proposals. .SELECTION PROCEDURES The City’s selection committee will evaluate all consultant proposals. Interviews will be scheduled for those consultants who are selected by the committee upon completion of the proposal evaluation. Key members of the selected consultant team will be required at the interview to present their proposal, and answer questions. SELECTION CRITERIA The proposals will be evaluated, in no special order of preference, based on the following criteria: 1.Specialized experience in the type of work. Past performance and record of the firm and the proposed project team on similar projects. 3. Familiarity with issues associated with the project. ATTACHMENT B City of Palo Alto City Manager’s Report 6 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 opeyation, the incinerators have deteriorated significantly prompting the preparation of the Plan. The Plan examines the environmental, economic, and operational impact of sludge treatment options and recommends rehabilitation of the two incinerators immediately, with the addition of a sludge dryer in the future, if needed. Certain environmental advocacy groups have serious reservations about the continuation of sewage sludge incineration. However, following extensive discussions with such groups and further data gathering, staff was unable to conclude that other options are environmentally better. Staff believes the RWQCP should continue to analyze future options, reevaluate and adopt a set of long range goals that are responsive to the communities and in context with future regulations. Major changes in plant design and policy should not be made until long range goals are complete. CMR:141:98 Page 1 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 concems 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 0f technologies for handling the sludge, and reduced down the number of feasible options. The recommendation of the feasibility study formed the basis of the second study, the Plan. Two technologies are considered feasible options besides incineration: sludge digestion and sludge drying. Sludge digestion is the anaerobic breakdown of sludge in large holding tanks over long periods. The end product is digested sludge,-commonly called bi0solids. Sludge drying uses low heat to evaporate the water out of the sludge without burning the organics. The residue from the dryer is in the form of pellets. The residue from both processes are typically used on agricultural land as soil supplement. Virtually all sewage treatment plants the size of the RWQCP use incineration, digestion, or drying. In the West, almost all plants use digestion, with land application of the digested sludge. The RWQCP chose incineration 27 years ago because incineration takes less land and produces less odor and residue. Recent studies demonstrate that another advantage of incineration is that pathogens, and most organic pollutants in the sludge such as P01ychlorinated biphenols (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 also due to the difficulty of comparing different types of environmental releases. The pathways for the final impact CMR:141:98 Page 3 of 8 agreements, which is consistent with past capital financing. The draft amendment was prepared jointly by Palo Alto’s City Attorney’s office and outside counsel at Jones, Hall, Hill & White. It incorporates comments fi~om the City’s financial advisor, Stone & Youngberg. The amendment will be presented to the Council in March 1998. Many environmental advocacy groups (EAGs) raised the concern that a non-incineration option may be better for the environment (CMR:356:97). In response to their concerns, additional data was collected and a Response Study was prepared. Many of the EAGs made the point that, if the sludge were made substantially cleaner by keeping pollutants out of the wastewater, non-incineration technologies (principally sludge digestion or sludge drying) would be better for the environment. The non-incineration option uses less energy, produces less air emission, and would allow reuse of the organic matter as a soil supplement without the current negative side-effect of putting pollutants on the soil as well, if the wastewater is "cleaner." While this logic is sound, it depends upon making the sludge cleaner through source control. Staff investigated the potential for source control of key pollutants (dioxins, mercury, organochlorine pesticides, polychlorinated biphenols - PCB ) and found that there was no reason to assume that major reductions would occur quickly. Action items for implementation by Palo Alto were developed, but it is not anticipated that those reductions will be greater than approximately 20 percent. Thus, non-incineration options will continue to have the draw-back of placing the pollutants on the soil. For this and other reasons described in the Response Study, staff’s recommendation has not been changed. Given currently available data, the current pollutant levels in sludge, and the current ability to evaluate impact on the environment, staff believes this recommendation to be the appropriate one. However, it is not at all certain that incineration should be the long term technology, of choice for the RWQCP. Air emissions, high energy use, and failure to reuse organic matter are features of incineration that raise significant concerns about its long term use. Therefore, staff is also recommending the development of long term goals to guide future design work at the RWQCP. Staff is also recommending the development of specific policies to achieve reductions of releases of mercury, dioxins, and organochlorine pesticides to the environment. These policies will also assist staff in the long term planning that must be accomplished for the RWQCP. ALTERNATIVES TO STAFF RECOMMENDATION If Council does not adopt the Negative Declaration and approve the recommendations, the RWQCP would continue to attempt to keep the incinerators in operation. Downtime, repair costs, and safety issues would continue to escalate. Should an incinerator fail, the RWQCP is required by law to repair the incinerator immediately. At that time, the cost of the repair would almost certainly be higher than the planned repair, and any work to improve the air emissions would most likely not be implemented because of the urgency of the situation. CMR:141:98 Page 5 of 8 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 Alt0. 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. Build a solids thermal dryer to pilot test a non-dioxin creating alternative to handling sewage sludge. 3. Explore alternatives to safely dispose of sludge or ash which contains dioxins. 4.Educate other public agencies and the public about dioxins and provide information on how to reduce them. 5. Continue to monitor the influent and effluent from the RWQCP for dioxins. Staff believes that these suggestions can be addressed in the long-term goals and policy development process described in staff recommendations 4 and 5. ATTACHMENTS A - Initial Study/Negative Declaration B - 20 year cash flow analysis C - Letter from the League of Women Voters of Palo Alto D - Letter from Bay Area Action E - November informational booklet Response Study - A copy is available for review at the Public Works Engineering, 6th floor counter PREPARED BY: Bill Miks, Manager Regional Water Quality Control Plant Phil Bobel, Manager Environmental Compliance Division CMR:141:98 Page 7 of 8 ATrACHMENT A Initial Study/Negative Declaration (IS/N’D) 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 4.Project Location: 2501 Embarcadero Way, Palo Alto, California 5.Application Number(s): Not Applicable 6.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)) Description 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 atthe 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) 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 colunm 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 Project The PARWQCP incinerators, which have been in service since 1971, have become more and more difficult to maintain in recent years and require frequent, costly repairs. Equipment downtime has increased dramatically because of the frequent repairs. The chance of both incinerators being out of service at the same time has increased to the point, of causing concerns about safe operations of the plant. The wastewater treatment plant must be able to contir~.uously 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 followir~g goals: o Repair the two existing incinerators to ensure a safe operating environment. Improve the efficiency of the incinerators so that only one incinerator needs to operate at a time, leaving one incinerator as a firm, reliable standby. Upgrade the air pollution control devices to improve the emissions of the incinerators. 5 Figure 5 Current/ncinerator Process Incinerator Atmosphere Air Scrubber StactGas Afterburner Cooling Hearth Residual Solids ~ Air Scrubber Afterburner Cooling Hearth Ash Burning Hearths Incinerator The first goal of the proposed Project is to make repairs to the two incinerators that will eliminate the frequent and cosily short-term repairs, greatly reduce equipment downtime, and insure a safe operating environment for plant personnel. This will include repair of cracks that have developed in the half-inch steel shell of the incinerators. The second goal of the proposed Project is to provide redundancy in the incineration process, allowing one of the incinerators to be held in reserve as a back up to deal with emergency situations. The wastewater flow going into the PARWQCP varies daily and seasonally. While the two existing incinerators are permitted to operate concurrently to meet the varying 7 Figure 6 Proposed IncineraObn System 2-Stage Scrubber Stack Gas Atmosphere 2-Stage Scrubber Stack Gas Residual S Dryer 7 ,.. Incinerator Residual Solids Cooling Hearth Cooling Hearth Ash Farmland Burning Hearths Incinerator people. The wastewater treatment processes (as distinguished from the incineration system shown in Figure 3) have a design capacity of 38 MGD average dry weather flow, which could serve a population of approximately 350,000. By contrast, the incineration system has a current approved maximum capacity of 60 dry tons per day (DT/D) (30 DT/D per incinerator), with a 1996 usage of approximately 17 DT/D to processes, not the incineration system, that limit the PARWQCP’s capacity. The proposed Project does not increase the capacity of the PARWQCP. A major capitol 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 steel plate 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 11 achieved with the existing belt’press dewatering. Available incinerator capacity is greater with drier solids. The sludge dried by the thermal dryer during peak periods would be added to the remaining dewatered sludge before incineration. The thermal dryer is expected to be operated only sporadically during peak loading conditions, for a total of about 4 weeks during the year. This will typically occur during the wet weather months in the winter after periods of particularly heavy storms. Thermal drying involves removal of moisture from the solids to a heated air stream. There are certain issues associated with drying that can be successfully addressed with proper design and operational procedures. The product from the dryers is organic and very dry, which can cause dust. Since organic dust can be a source of 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 fire hazard. The proposed thermal dryer uses indirect drying, in which fuel is combusted in a boiler to produce steam or in a thermal oil heater to heat oil. The steam or heated oil is passed through an indirect dryer, where hollow metal disks or paddles are heated from the inside and conduct heat to the solids on the outside of the paddles. The thermal drying facility can be located inside or outside the existing sludge incinerator building. A site just north of and adjacent to the existing incinerator building, as shown in Figure 4, has been identified for an outside location. Conveyors will be installed to transport 13 11.other agencies whose approval is required (e.g., permits, f’mancing approval, or participation agreement.) State/Regional Agencies Bay Area Air Quality Management District San Francisco Bay Regional Water Quality Control Board City of Palo Alto City of Palo Alto Public Works Department City of Palo Alto Department of Planning and Commtmity 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 Lgs Altos Hills Authority to Construct (A/C) and Permit to Operate(P/O) - if grandfather status is not maintained, then will be needed (existing facility attained grandfather status because it was constructed before 1972, and will retain this status as long as it is not modified in a manner that results in an air emission increase of a regulated pollutant or the repair costs are not greater than 50% of the capital cost of a new incinerator) Clean Water Act: 40 CFR Part 503 Rulesmproposed revisions to CWA Part 503 will be incorporated into the existing NPDES Permit; will require Continuous Emissions Monitoring for CO and NOx along with existing requirements for Total Hydrocarbons by 2000 Grading and Drainage Review Building Use Permit Site and Design Review Architectural Review Hazardous Materials Disclosure Checklist/Inspection Approval and Funding Approval and Funding Approval and Funding Approval and Funding 15 Determination: On the basis of this initial evaluation: t fred that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared. I fred 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 f’md 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, bm 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 8,: Community Environment Date 17 Issues (and Supporting Information Sources): I. LAND USE AND PLANNING. Would the proposal:. a) Conflict with general plan designation or zoning? b)Conflict with applicable environmental plans or policies adopted by agencies with jurisdiction over the project? c) d) II. e) a) b) c) Be incompatible with. existing land use in the vicinity? Affect agricultural resources or operations (e.g. impacts to soils or farmlands, or impacts from incompatible land uses)? Disrupt or divide the physica! arrangement of an established community. (including a low-income or minority community? POPULATION AND HOUSING. Would the proposal: Cumulatively exceed official regional or local population projections? Induce substantial ~owth in an area either directly or indirectly (e.g. through projects in an undeveloped area or extension of major infrastructure)? Displace existing housing, especially affordable housing? III. GEOLOGIC PROBLEMS. Would the proposal result in or expose people to potential impacts involving: a) Fault rupture? b) Seismic pound shaking? SOUrces 94 12 3 3 Potentially Significant Impact Negative Declaration: Potentially Significant Unless Mitigatibn Incorporated Less Than Significant Impact No Impact 19 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 qualit.~ violation.’? b) Expose sensitive receptors to pollutants? c)Alter air movement, moisture, or temperature, or cause any change in climate? d) Create objectionable odors? VI. TRANSPORTATION/CIRCULATION. Would the proposal result in: a) Increased vehicle trips or traffic congestion? b)Hazards to safety from design features (e.g. sharp curves or dangerous intersections) or incompatible uses (e.g. farm equipment)? c)Inadequate emergency access or access to nearby uses? d) Insufficient parking capacity on-site or off-site? e) Hazards or barriers for pedestrians or bicyclists? f) 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)? So U rces Potentially Significant Impact 1 1 1 1 1 1,2 1,2 Negative Declaration: Potentially ¯ Significant Unless Mitigation Incorporated Less Than Significant Impact No Impact 1,2 21 Issues (and Supporting Information Sources): b)Exposure of people to severe noise levels? . a) b) c) d) e) XII. PUBLIC sERVICES. Would’the proposal have an effect upon, or resuh in a need for new or altered government services in any of the following areas Fire protection? Police protection? Schools? Maintenance of public facilities, including roads? Other governmental services? 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 oas~ b) Communications systems? c)Local or regional water treatment or distribution facilities? d) Sewer or septic tanks? e) Storm water drainage? 0 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? SOUFCes l l l 1 1 1 1 1 I I I l l Potentially Significant Impact Negative Declaration: Potentially ¯ Significant Unless Mitigation Incorporated Less Than Significant Impact No Impact 23 b)Does the project have Iv~-.potentlal to achieve short- c) d) term, to the disadvantage of long-term, environmental goals? Does the project have impacts that are individually limited, but cumulatively considerable? ("Cumulatively considerable" means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly? XVII.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)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. c) Mitigation measures. For effects that are " ~, ""Ne=at~ve 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 2 Palo Alto Regional Water Quality Control Plant, Solids Facility Plan, May 1997 Palo Alto Comprehensive Plan, 1980- ! 995 Palo Alto Comprehensive Plan Update Draft Environmental Impact Report, December 1996 Voice mail message from Jim Gilliland (City of Palo Alto) regarding zoning, on June 24, 1997 Voice mail message from Jim Gilliland (City of Palo Alto) regarding zoning, on June 26, 1997 25 IXX. EXPLANATIONS FOR CHECKLIST RESPONSES surface runoff. IV b IVc The treatment plant site is in a flood zone, as designated by FEMA. However,.the proposed project would not result in any additional exposure of people or property to water related hazards such as flooding. All applicable FEMA requirements will be met. The air pollution control equipment in the proposed project would recycle trace amounts of metals from the scrubber back to the 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. IV d The proposed project would not change the amount of surface water in any water body. IV e The proposed project would not change currents or the course or direction of water movements. IV f The proposed project would not change the quantity of ground waters, either through direct additions or withdrawals, or through interception of an aquifer by cuts or excavations or through substantial loss of groundwater recharge capability. IV g The proposed project would not alter the direction or rate of flow of groundwater. IV h The proposed project would not result in impacts to groundwater quality. IV i The proposed project would not result in substantial reduction in the amount of groundwater otherwise available for ~ublic water supplies. V a Construction-related emissions, such as dust (fine paniculate matter, PM~o), 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 are~, 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 I 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 truck pick-ups for ash. Therefore, there will be no increased truck traffic emissions beyond what is currently occurring. With operation of the new emissions abatement technology and implementation of dust control measures during construction, the project would meet all current and known potential future air quality requirements and no significant air quality impacts would occur. V b Because the project site is not located near sensitive receptors and no net increases in air emissions would occur based on current source test data and future emission estimates, there will be no pollutant exposure to sensitix~e receptors. Sensitive receptors include schools, daycare centers, hospitals, and nursing homes. The PARWQCP staffwill adhere to 27 IXX. EXPLANATIONS FOR CHECKLIST RESPONSES Vll e VIII 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 resource: 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 The thermal dryer may present a small risk of accidental explosion or fire. However, the proposed project would be designed with safety measures including proper dust handling systems to reduce explosion potential, and nitrogen padding of the storage hopper air space to reduce fire hazard. With these design measures, the potential impacts are expected to be less than significant. IX b The proposed project would not interfere with an emergency response plan or emergency evacuation plans. IX c The proposed project will result in a 99.9% decrease in dioxin and furan emissions, an average 54 percent decrease in metals air emissions, and an average 48 percent decrease in criteria pollutant emissions compared to current emissions from the incinerators, resulting in a project benefit. As a results the project will result in no new impacts to health. " IX d Neither the proposed project nor the PARWQCP create metals; any metals emissions result from metals in the plant influent. However, the metals, primarily mercury, that would be removed by scrubber water treatment discussed in VIId 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. I Ib/year for the lightest metals and approximately 30 Ib/year of the heaviest metals. Metals resulting from scrubber water treatment would be handled properly in accordance with all applicable and stringent local, state, and federal regulations that govem the use, storage, and disposal of such materials. As a result, no significant impacts are expected. IX e The proposed project area does not contain flammable brush, grass, or trees, and the proposed project would not increase fire hazard in areas with flammable brush, grass, or trees. X a The proposed project may result in short-term increases in existing noise levels associated with construction activities. However, the impacts are expected to be minor and not noticeably different than current noise associated with rehabilitation and maintenance activities. No sensitive receptors are located near the project area. Therefore, impacts to existing noise levels are expected to be less than significant. X b The proposed project would not result in exposure of people to severe noise levels. XI a The proposed project would not affect or result in a need for new or altered fire protection services. XI b The proposed project would not affect or result in a need for new or altered police protection services. XI c The proposed project would not affect or result in a need for new or altered schools. Xld 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. XI e The proposed project would not affect or result in a need for any other new or altered governmental services. XII a The proposed project would not result in a need for new systems or supplies of or substantial alterations to power or natural gas utilities. 29 Table I: Current and Future Emissions, PARWQCP Incinerator Rehabilitation Pollutant Criteria Pollutants Carbon monoxide Nitrous Oxides Sulfur oxides THC Particulate matter Volatile Organic Carbons Hazardous Air Pollutants Dioxin Furans Metals Arsenic Beryllium Cadmium Chromium Copper Manganese Mercury Nickel Selenium Zinc Current Emissions (lb/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 I0 - 2.34 x 10-3 1.23 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"I Emissions After Incinerator Rehabilitation (lb/day) 22.64 37.07 1.55 1.45 12.95 0.53 2.17 X 10"I 1 9.50 x 10"l I 3.48 X 10-3 3.98 X l0"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 1o-4 1.64 x 10"1 Authority: Public Rcsourccs Code Scctions 21083 and 21087. Reference: Public Resources Code Sections 21080(c). 21080.1. 21080.3. 21082.1, 21083, 21083.3, 21093, 21094.21151; Sundstrom v. CounO~ of Mendocino, 202 Cal. App. 3d 296 (1988); Leonoffv. Monterey Board of Supervisors, 222 Cal. App. 3d 1337 (1990) 31 ATTACHMENT B - ATTACHMENT C February 4, 1998 Palo Alto City Council 250 Hamilton Avenue Palo Alto, CA 94301 Dear Mayor Rosenbaum and members of the City Council: The League of Women Voters of Palo Alto supports comprehensive measures to provide maximum protection to human health and the environment from the adverse effects of hazardous materials. Because certain hazardous materials are associated with the treatment and disposal of sewage sludge, we have some concerns about the proposal to repair and improve the existing sewage sludge incinerators at the Palo Alto Regional Water Quality Control Plant. The proposed solution to the problem of how to handle the sludge from sewage treatment when the present incinerators are on the verge of breaking down, may not be the best solution from an environmental perspective, but when space requirements, time, and cost are considered, it is probably the appropriate solution at the present time. We are concerned that the performance figures presented in the EIR are estimates and projections that may have no relation to how the rehabilitated incinerators, with the addition of an afterburner and new scrubbers, will actually work. If you approve this proposal, we believe it is imperative that you include a regular and frequent monitoring program to ensure that the system is working as well or better than advertised. Although the dryer is included in the negative declaration, it appears that the addition of this dryer needs more study to avoid safety problems and will not be added to the system unless volume makes it necessary. However, there is a possibility that the addition of such a dryer could act as a pilot project for possible elimination of the incinerators in the future. This idea should be considered in deliberations over a tong range plan. The repaired system and the existing treatment plant are expected to last less than twenty years. In the context of planning for major changes, that is not a long time. It is not necessary to wait twenty years to make changes; the establishment of long range environmental goals and the search for more effective ways to recycle the sludge should be an ongoing process. We encourage you to instruct the staff of the Regional Water Quality Control Plant to begin now to work on a long range plan for waste water management that will meet the needs of the area in an environmentally friendly way. main telephone no. 65o,32x.x994 facsimile 650.321.1995 Schools Group 650:325~5680 Palo Alto City.Council City, Hall 250 Hamilton Ave. Palo Alto, CA 94301 PEOPLE FOR THE ENVIRONMENT _ATTACHMENT D "715 Culur~.do Avenue. Suite 1 " Pat~ AlTo, Cetifornia ~,3Q3:3913 email baectioneigc.or9 .hit p://www.ba a orion.or O Feb. 13,1998 Dear City Council, On February 23, Polo Altd City Council is scheduled to consider the "WQCP. Solids Ma£agement ~oject." Bay Area Adtion and a number of other local environmental groups ir~ conjuction with City staff, have been reviewing the proposed plan t~>repair the, incinerators at the Palo Alto Regional Water Quality Control Plant (RWQCP). According tO reports prepared for the RWQCP, as will as numerous other supporting documents, there are serious health and em)ironm~ntal co.nc/erns: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 decisi~)n ¯ 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 the incinerators release hal~as many dioxins ihto the environment as come into the plant from the above mentioned sources; howev.er, th.ere is a high level of uncertainty of how man’y dioxins re-form after being released into ih~ a, ir, which may’ske~ this approx~matmn. Dioxins are also released from the incinerators through the water effluefit and through the ash.The water effluent pollutes the bay, and the ash is shipped to the Central Valleyand used in agricultua’e, thus completing the circle of. c~ntaminating our food supply. , Dioxins are a highly toxic by-product created frbm the production and incineration’of"chlorine-contAining products; sucti as organochlorine pesticides, polyvinyl chloride’(PVC) plastics, and polychlorinated biphenyls (PCBs).’’~ Dioxins are dangerous to’ humans and wildlife because they bioaccumulate in fatty tissue. "In humans, dioxins have been shown to cause cancer, weaken the immune system, and interfere with the endocrine system, which is responsible for making hormones needed to regulate bodily functions, including sexual development and fertility.’’~ We highly recohamend that thecouncil ¢eview. this docu.rnent as well as " the :’Dioxins Polluti, on Prevention Plan," which was prepared for the RWQCP in October 1997 before the Feb, 23 council meeting. Both documents el;acidate the necessity to reduce the amount of dioxins going to and coming from the’RWO(2P. : \ 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 outsid~ the scope of the.WQCP Solids Management Project, we request that the council take a comprehensive approach to addressing how to reduce the .~mount of<lioxins in our environment. Some suggested approaches are as ~follows:’ "" Develop a dioxins reduction policy for the.City of Polo Alto, and request neighboring cities tO do the same Budd a sohds thermal dryer to pilot test a non-d~oxm creating alternative to handling sewage sludge Explore alternatives, to safely dispose of sludg~ or’ash whidh contain dioxins .~ Educate other p~blic agencies and the public abou2"dioxins and provid~ information how to reduce 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 IdentiJTcatio’n ./