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
./