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Home My WebLink About2001-10-02 City CouncilTO: ATTN: City of Palo Alto City Manager’s Report HONORABLE CITY COUNCIL POLICY AND SERVICES COMMITTEE FROM:CITY MANAGER DEPARTMENT: PUBLIC WORKS DATE:OCTOBER 2, 2001 CMR:342:01 SUBJECT:ENDORSEMENT OF LONG-TERM GOALS FOR THE PALO ALTO REGIONAL WATER QUALITY CONTROL PLANT (RWQCP) REPORT IN BRIEF Through the Long-term Goals Study, the RWQCP re-established long-term goals that not only align with today’s environmental and socioeconomic needs of the communities, but are also consistent with the underlying theme of sustainability: ¯ ¯ ¯ ¯ ¯ ¯ ¯ ¯ ¯ ¯ ¯ ¯ ¯ ¯ Meet future capacity needs Meet or exceed regulatory requirements Minimize or eliminate toxins in the influent (e.g. dioxin) Minimize energy consumption and maximize energy life cycle efficiency Minimize or eliminate potentially hazardous chemical usage Minimize or eliminate total release of toxins to the environment Minimize impact on ecosystem Minimize impacts on community, including neighboring communities Minimize or justify financial impacts on ratepayer Involve stakeholder in the decision making process Immobilize or beneficially reuse persistent toxins Take leadership role in promoting beneficial reuse and environmental enhancement Maximize worker safety Maximize recycled water as a supplemental water source The RWQCP will apply these goals to future activities for a sustainable wastewater management system. CMR.~42.01 Page I of 5 RECOMMENDATION Staff recommends that Council endorse the list of long-term goals for the Palo Alto Regional Water Quality Control Plant (RWQCP). BACKGROUND On February 23, 1998 Council approved the Incinerator Rehabilitation project and directed staff to perfo.rm a Long-Term Goals Study (Goals Study) for the RWQCP. During the discussion of the Incinerator Rehabilitation Project, certain environmental advocacy groups had serious reservations about the continuation of the existing treatment technologies at the RWQCP. The RWQCP, constructed in 1970, was designed to operate under its current design through the year 2020. When the RWQCP was originally designed, the public provided inputs that guided the selection of technologies used to treat the wastewater. Over the years, environmental concerns, technologies, and regulations have changed significantly. Today’s environmental values and criteria differ from those that guided the original design of the RWQCP. The wastewater system of the future must respond to the environmental and socioeconomic concerns of the RWQCP’s service area. The system needs to be consistent with the concept of sustainability in the future. The first step of the RWQCP’s planning effort is to analyze future options, and reevaluate and adopt a set of long range goals that are responsive to the communities. The Goals Study is also needed so that the RWQCP partner cities can make decisions on future partnership. In 1968, the Partner Cities signed a Joint Sewer Agreement that funded the design and construction of the RWQCP. The Joint Sewer Agreement is binding for fifty years, and may be terminated at the end of the fiftieth year with a ten-year prior notice. The term of the Agreement coincides with the design life of the RWQCP. The useful life of the RWQCP will near its end in the year 2020. At that time, the RWQCP may need to be upgraded or replaced. Two dates are of significance for the planning effort of the RWQCP: ¯The year 2009 - Notification of intent to terminate the Joint Sewer Agreement may be issued by any partner ¯The year 2019 - The Agreement may be terminated, and the RWQCP will need to be upgraded or replaced. It is anticipated that the planning effort, pre-design studies, and environmental impact study will take many years to complete. In order to provide the necessary information to the decision-makers so that informed decisions can be made in the critical planning years, it is necessary to start the planning studies now. CMR:342:01 Page 2 of 5 DISCUSSION The final report of the Goals Study is attached as Attachment A. The Goals Study was structured to provide an open forum to solicit public opinions. The process took a participatory and collaborative approach through inter-active public workshops and use of the Internet. The RWQCP hosted a series of four workshops. Invitations were sent to more than fifty stakeholders. The stakeholder’s list included Bay Area environmental groups, local businesses, local community groups, parmer cities, public agencies, and various City departments. A core group, made up of over twenty stakeholders, attended the workshops. The Goals Study web site was created to communicate with the public and provide up to date information on the project. It can be accessed through the City web page or directly at: http://www.parwqcp.org/longtermgoals/New start.html. A comment form was available on the web site for the public to send comments to the RWQCP at any time of the process. Project activities were posted on the project web site and the City Activities Calendar to encourage public participation. The workshops resulted in a list of long-term goals for the RWQCP: ¯ ¯ ¯ ¯ ¯ ¯ ¯ ¯ ¯ ¯ ¯ ¯ ¯ ¯ The Meet future capacity needs Meet or exceed regulatory requirements Minimize or eliminate toxins in the influent (e.g. dioxin) Minimize energy consumption and maximize energy life cycle efficiency Minimize or eliminate potentially hazardous chemical usage Minimize or eliminate total release of toxins to the environment Minimize impact on ecosystem Minimize impacts on community, including neighboring communities Minimize or justify financial impacts on ratepayer Involve stakeholder in the decision making process Immobilize or beneficially reuse persistent toxins Take leadership role in promoting beneficial reuse and environmental enhancement Maximize worker safety Maximize recycled water as a supplemental water source Goals Study is a living document that will assist theRWQCP in two ways: When tackling problems at hand, the RWQCP will look to the Goals Study to align short-term projects with long-term objectives so that each step will be in the right direction. CMR.~42.01 Pa=e 3 of 5 The RWQCP will apply the long-term goals to Capital Improvement Program (CIP) projects and programs immediately. Alternative evaluations for the CIP will be considered in light of the long-term goals, and conflicting goals will be reconciled. The RWQCP will also take an active role to cooperate and work with Santa Clara Valley Water District on various reclaimed water issues including water quality, funding, public education, institutional requirements, etc. When designing the future plant, the RWQCP will look to the Goals Study to develop the appropriate strategies and programs for a sustainable wastewater management system. The Goals Study resulted in a list of long-term goals that are consistent with the sustainability criteria. The sustainability criteria used in the Goals Study were developed by Nattrass and Altmore who authored and published the book on sustainability "The Natural Step for Business". These criteria are similar to the criteria developed by other sustainability experts. A sustainability matrix that compares the goals to the criteria is included as Attachment B. Integration of the goals in future RWQCP activities will lead to a sustainable wastewater management system. In response to the concerns of the stakeholders, the RWQCP plans to conduct an alternatives study on the disinfection process in FY 2002, and plans to start the conceptual design of the future wastewater system in FY 2004. The RWQCP will work with the stakeholders to select the technologies and programs that adhere to the long-term goals for the future wastewater management system. To track the progress and the accomplishment of the long-term goals, the RWQCP will distribute an annual report to the stakeholders. The annual report will detail the efforts spent in pursuit of the long-term goals and the results. RESOURCE IMPACT Funds for the planning studies will be included in the corresponding year’s budget. Staff will return to Council for approval of each project. POLICY IMPLICATIONS The recommendations of this staff report are consistent with City policies. ATTACHMENTS Attachment A:Long-Term Goals Study Final Report Attachment B:Sustainability Matrix Attachment C:CMR:141:98 Attachment D:CMR:440:99 PREPARED BY:Daisy Stark, Senior Engineer RWQCP William D. Miks, Manager RWQCP Phil Bobel, Environmental Compliance Manager CMR:342:01 Page 4 of 5 DEPARTMENT HEAD: GLENN S. ROBERTS Director of Public Works CITY MANAGER APPROVAL: CHRIS Assistant to the City Manager CMR:342:01 Page 5 of 5 ATTACHMENT A Paio Alto Long-Term Goals Study The Palo Alto Reb~onal \’~ter Quality., Control Plant (R\VQCP), operated by the City of Palo .,’Mto, was designed to serve the wastewater management needs of the (.’it}, and neighboring communities through the year 2020. The RWQCP is now starting the process of planning for its furore beyond this timeframe. The RWQC’P envisions that the wastewater system of the future must be consis- tent x~’ith the concept of sustainability. The first step of the R~(:QCP’s planning effort is therefore to establish long term goals that aligm with the environmenral and socioeconomics needs of the communities. To achieve this, the RWQCP initiated this Long Term Goals Study- (LTGS) in July 2000. it was structured to provide an open forum to solicit public opinions. As part of the LTGS, the RWQCP has hosted a series of workshops that lead to the development of the long-term goals for the RXVQCP bv stakeholders. In the future, the LTGS will assist the RWQCP in r, vo ways: \Vhen designing the future plant, the R\VQCP will look to the LTGS fi3r gmidance in developing appropriate strategies and programs for a sustain- able treatment system. When tackling near-term operational issues and capital improvements, the R\VQCP will look to the LTGS to align short term improvements with long term obiectives. TNs report concludes a one-year effort, punctuated by four workshops that were held in Januar.v; .March, Ma}; and July 20{11. The primary objective of this report is to summ~ze fl~e LTGS process and the final LTGS outcomes, including a final list of issues and primary long-term goals. This report is orgaNzed as follows: 1. Background Information 2. LTGS Process 2a. Stakeholder Involvement 2b. Process 3. LTGS Outcomes7z00 Es-,t a/~s h 3a. Issues /Goals~ 3b. Long-Term Goals8~0~ - - -/ ,~ 4. Integration of Goals to Future RWQCP Activities /~,~i~p~!-~r, x~ 5. LTGS Conclusions ~\Vorkshop minutcs, handouts, and graphics arc appended to this report, andImplement PrNect:~provide a summary of the discussion hckl during each workshop. 1. Background Information In 1968, the Partner Cities signed a Joint Sewer Agreement that funded the desigm and construction of the RWQCP. The Parmer Cities are the cities of Mountain Viex~; Los Altos, Palo ~Mto, the Town of Los Altos Hills, Stanford Universit3; and the East Palo Alto Sanitary District. The tTpical design life of a wastewater facilib" is fifty years. The use~\~I life of the RWQCP will near its end in the year 2020. At that time, the RWQCP may need to be Upgraded or replaced. In addition, the Joint Sewer Agreement is binding for rift3." years, and may be terminated at the end of fl~e fiftieth year with a ten-year prior notification. Two dates ,’ire significant for the planning effort of the RWQCP: ¯The year 2009 - Notification of intent to terminate may be issued by any partner. ¯The year 21)19 - Agreement may be terminated; RWQCP may need to be upgraded or replaced. The RWQCP moy upgraded or r~p!oced in the yeor2020 1934 C~nstrT¢ction q[ "l~rcatmewt Plant I. gcuate, r Pa/o Alto 7)eatm~:nt Plant h, the, I960s Paid Alto Treatment P/anJ h~ the 1990s Paid A/lo iP’ast~.water S}’st~.m b~ the 2020s lr was anticipated that the planning effort and pre-design studies would take over a decade. In order to provide the necessary information to the decision-makers so that informed decisions can be made in the critical planning years, it is necessary to start the planning effort no later than the year 2(}0(}. In addition, the RWQCP envisions that the wastewater system of the future must be consistent with the concept of sustainabiJitv and align with the environment~ and socioeconomics needs of the communities. When the R\xTQCP was originally designed, the communities provided inputs on selecting the technologies used to treat the wastewater. Over the }’ears, environmental concerns, technologies, and regulations have changed significand> Consequently, today’s environmental values and criteria may differ from those tha~ guided the ori~nal desi~m of the RWQCP. The first step of the RWQCP’s planning effort is therefore to re-establish long- term goals that all,kin with today’s environmental and socioeconomics needs of the communities ConsequentlB the R\xTQCP initiated a Long Term Goals Study in July 2000. The RWQCP must ~tart the pi~nning effor~ no k~er than t~,¢~, year 2000 The RWQCP must re-estebfish tong- t~m~ goals 2, LTGS Process The I_x~ng Term C-oals Study (LTGS) was structured to provide an open forum to soli- :r. public opinions. Stakeholder involvement was criticM to fl~e LTGS process. Th,,- process of developing long-term goals was divided into fi)ur phases fl~at are further described in this section. 2a. Stakeholder Involvement The success of the stud.,,; i.e. the acceptance of the outcomes by the public, was dependent on stakeholders involvement in the process. The RWQCP created a LTGS website and organized public meetings to solicit stakeholder opinions. The LTGS website was created in December 2(100, one month prior to the first workshop. The purpose of the website was to inform the pubic about the LTGS stares and the process outcomes up-to-date. A comment fi)rm was available on the website for the pubic to send comments to the RWQCP at any time of ~e process. The address of the website is htq~:i.,’x~x~v~m,-~,~qc., - I-- ~r~/l- , ngt~-,-m~,o~fi,:.. . .~ . .. The LTGS website was accessible from the Cia" of Palo Alto website and ~e R~VQCP website, RWQCP hosted a series of four workshops that resulted in a set of long-term goals for the RWQCP. Meeting announcements were posted on the website and the ciw’s activities calendar three weeks before each workshop. Notices of the meetings were also mailed to the stakeholders two weeks before the meetings. Meeting minutes were posted on the LTGS website within two weeks following the workshop. A panel of stakeholders received a personal invitation m join the workshops, in addition, any one from the public was welcome to join the process at any time. The panel of stakeholders was identified based on the follo\ving criteria: The panel shall include members of groups that had expressed interest in the RWQCP projects or programs in the past; and, The panel shall be representative of the environmental and socioeconomlcs interests of the communities. Table 1 provides the list of the stakeholders that were identified and invited by phone or mail re ioin the LTGS process. s~akdgolde;s wos invi*,ed to join LTG5 Table 1: List of Invited Stakeholders Environment Siena Club - Loma Prieta Chapter San Francisco Bay Keeper Santa ClaraValley Audubon Society Peninsula Conservation CenterFoundation & Bay Area A~ion San Frandsquito Oeek CRMP Los Altos En~ronmental Commi~ee Silicon ValeyToxics Coalition Save the ~y Communities for ~tter Environment CLaN South Bay Business Syntex!Roche Biosciences NASA Ames Research Center Hewlett Packard/Agilent Technologies Affymax Communications and Power Industries (CPI) City of Pa!o Alto CC City of Mountain View CC City of Los Altos CC Stanford University Medical Center Sanmina Mountain View Mountain View Landfill Silicon Valley Manufacturing Group VA Pale Alto Stanford Stanford Facilities Operations University Environment Health and Safety Municipal Community City of Pale Alto Utilities, Planning & Fire Department City of Mountain View Public Services & Fire Department City of Los Altos Public Works & Fire Department City of Los Altos Hills Public Works Department, & Utilities (Purissima Hills WaterDistrict & California Water Service Corn paw) East Pale Alto Sanitary District California Water Service Co. of San Jose Santa Clara Valley Water District Los Altos - Mountain View Area League of Women Voters League of Women Voter Member Pale Alto League of Women Voters Interfaith Council Technical Regional Water Quality Control Board Pale Alto Regional Water Quality Control Plant ~he workshop wdJ representing the environmen~ dommunities Table 2: List of Attendees Fifteen to twenty five stakeholders attended each of the workshops.. Each category of stakeholders was represented at each \vorkshop. Members of the public also joined the process. The attendees formed a well-balanced .group representing of the environmental and socioeconomics interests of the communities. Table 2 provides the list of attendees fi)r each workshop. Allen, Jamie Ashktorab, Hossein Bobel, Phil Brown, Sydney Coombs, Ann Cutler, Bill Cwiak, Roger Davis, Anita Elliott, Claire Fritz, Needa Hughes, Stephanie Kenton, Bob Kraus, Michael Kremesec, Ken La Porte, Marty, Lefkowitz, Rosa lie Lind, Larry Miks, Bill Mulvey, Trish Nixon, Scott Olson, Nancy Santos, Silvia Serge, Dave Showalter, Pat Sims, Spencenia Stark, Daisy Wu, Edward City Of Palo Alto SCVWD Palo Alto Regional Water Quality Control Plant Interfaith Council League of Women Voters Palo Alto Resident City of Palo Alto East Palo Alto Sanitary District Palo Alto Resident East Palo Alto Sanitary District Palo Alto Regional Water Quality Control Plant SCVWD Communications and Power Industries Ci~ of Palo Alto Stanford University - Facilities Operations League of Women Voters of Palo Alto & Emily Renzel Marsh Bird Censuses City of Los Altos Palo Alto Regional Water Quality Control Plant CLEAN South Bay Hewlett Packa rd/Agilent Technologies League of Women Voters City of Palo Alto City of Mountain.View San Francisquito Creek CRMP East Palo Alto Water District Palo Alto Regional Water Quality Control Plant City of Palo Alto 2b, Process The objective of the LTGS was to efficiently extract, compile and reconcile the desires of the communit3’ and develop long-term goals that can be accepted and supported by both the industry professionals at the RWQCP and the array of stakeholders representing the environmental and socioeconomics interests of fl~e communities. The process to achieve fl~is objective was divided into four phases. ~ Prelimina~ List ~ oftssu~s Review and Discuss Issues Prelimina~Atte~nate Projects A workshop was held at each phase of the process. Each workshop was designed based on specific objectives, including: Provide background information necessary to discuss and establish goals; Get ~hc stakeholder input required to achieve the obiective of the current phase: Address concerns about the previous phase, expressed by the stakehold- ers during the previous workshop or through the comment form: and/or, Get stakeholder acceptance on the outcomes of the previous phase. Table 3 summarizes the timeffame and specific objectives associated with each workshop. Table 3: Workshop Timeframe and Objectives 1 January 2001 Get Acceptance of LTGS Overall Process Provide Background Information on PARWQCP and Regulatory Challenges Get Stakeholder Input on Potential Issues 2 March 2001 Present Fact Sheets on Complex Issues (Dioxin, Disinfection, Ash Reuse, Water Quality, and Recycled Water) Present and Review Preliminary List of Issues 3 May 2001 Get Acceptance of Final List of Issues Present and Get Acceptance of Methodology for Transforming Issues into Goals Present and Review Preliminary List of Goals 4 July 2001 Present and Review Refined List of Goals Get Acceptance of Final List of Goals Present Framework for Imegrating Goals in Future RWQCP Activities" Identify RWQCP’s Commitments and Stakeholder Future Involvement A list of issues RWQCP "wa.~ result,of workshops i and2 Table 4: Identified Issues 3. LTGS Outcomes This section provides a summar\’ of the LTGS outcomes, including the final list of issues and long-term goals. 3a. Issues \’~)rkshops i and 2 were dedicated to establishing a list of issues that would serve as a base for defining long-term go,’ds. In order to establish a list as comprehen- sive as possible, brainstorming sessions on each plant parameter were held, with categories of issues and specific issues identified. The plant parameters that were considered included influent, energ.~; chemicals, air emission, ash,. Bay discharge, recycled xvater, and plant facilities. The category of issues that were considered included expansion needs, wamr qualit3; health & safet,~; reg’u]atory compliance, . quality of life, environmental enhancement & lustice, and resource recovery. Table 4 provides this final list of issues that was established as a result of these workshop. The issues are sorted by plant parameter and category of issues. tnfluent Expansion Needs Water Quality Energy ¯ Electricity ¯ Natural Gas Chemicals Health & Safety ¯ Chlorine ¯ Sulfur Dioxide ¯ Polymer Regulatory Compliance Air Emission Health & Safety ¯ Incinerator ¯ Volatilization Quality of Life of organics Regulatory Compliance ¯ Odor Environmental Justice Ash Resource recovery Health & Safety Bay Discharge Regulatory Compliance insufficient RWQCP capacityto meet future requirements? Chlorine that contributes dioxin generation in plant influent Other component that contributes dioxin generation Decreasing reliability of electricity supply Increasing cost of electricity Energy cost to run the afterburners Use of hazardous Chemicals relative to worker safety Use of chlorine at the plant as a source of dioxin Use of hazardous chemicals relative to the environment {chlorine, sulfur dioxide) More and more stringent regulations on chlorine and sulfur dioxide Part of dioxin that is not destroyed during the treatment process Transport mecha nism and exposures pathway to dioxin? Odor Future regulations on CO2 emission? Future regulations on volatilization of organics? Future regulations on odor? Air emission impact on neighboring communities Market for ash big enough? Residual disposalltrace elements leaking in water supply sources Current bio Persistent Toxic mass loading regulation ¯Mercury, dioxin, OP pesticides ¯ PCBs ¯Poly Aromatic Hydrocarbons Current toxic element concentration regulation ¯Copper, Nickel ¯Zinc Emerging "no net loading" issue? Future reg61ations on hormones, pharmaceutically active compounds, arsenic? Future regulations on bay discharge quantity? I lnr#rtaintv nf ultimat~ n~rrnit mnuir~m~nt~ Table 4: Identified Issues, cont. Bay Discharge Environmental Bay water quality Enhancement&Justice Endangered species habitat Impact on salt water marsh Recyc ed Water ¯ Resource Recovenj Malket for recycled water big enough? Significant cost o~ recycled water: : : Higff~eCyded~wat~rsaiinity : ~ : Health & Safety Recyc ed water qual ty (hormones, pharmaceutically active compounds, arsenic) Environmental Growth:inducement Enhancement & Just ce: Envir~fimental ~nd sOc a "Ustice issUe with recycled water d stdbut on Facilities Environmental Impact of activities on other communities Enhancement & Justice Quality of Ufe Community impact (visual, noise, traffic, land-fil!) Workplace safety Water Supply "Reliability and quantity of water available from Hetch Hetchy system or other sources 3b, Long-Term Goals Workshops 3 and 4 xvere dedicated to establishing a list of primary long-term goals based on the previously identified issues. The following methodology was m~plemented to transfi)rm issues into primary goals: ¯Summarize issues identified during workshops I & 2. ¯Summarize potentia! goals and alternatives brought up during Workshops 1 & 2. Brainstorm additional potential goals associated with identified issues. ~,Determine a list of primary" long-term goals, or "overarching" goals, based on the list of potcnti~ goals. A prcliminau list of primar.v goals was presented during Workshop 3 and the wording was refined based on stakeholder comments. The refined list of long- term goals was discussed and obtained stakeholders acceptance during Workshop 4. Table 5 provides the final list of primary long-term goals for the RWQCP that will serve as a basis for future planning and project evaluations. The final fistof primo:T long-term RWQCR which wiii fi~ture planning and p~oject octivitieg wd5 result of workshops 3 and 4 Table 5: Primary Long-Term Goals for the RWQCP Meet Future Capacity Needs Meet or Exceed Regulatory Requirements Minimize or Eliminate Toxins in the Influent (e.g.dioxin) Minimize Energy Consumption and Maximize Energy Life Cycle Efficiency Minimize or Eliminate Potentially Hazardous Chemical Usage Minimize or Eliminate Total Release of Toxins to the Environment Minimize Impact on Ecosystem Minimize Impacts on Community, Including Neighboring Communities Minimize or Justify Financial Impacts on Ratepayer Involve Stakeholder in the Decision Making Process Immobilize or Beneficially Reuse Persistent Toxins Take Leadership Role in Promoting Beneficial Reuse and Environmental Enhancement Maximize Worker Safety Maximize Recycled Water as a Supplemental Water Source input from the stakehok~ers abov~ ~md beyond the primary iong..tem~ goag w~s dodu~)e~l ~e~ R9~~ future use 1~ the next phase of the p]onning process t?~e R WQCP developed a med~odoiogy ~o in future RWQCP activities, acknowledging d~dt some project- need ~o k~e ~~’ckied basis During Workshop 4, examples of secondary., goals and alternatives associated with each of the identified primary goals was presented and discussed. On the following page, Table 6 gives examples of secondary goals and ’alternatives associated "a~ith each of primary goals that were brought up by the stakeholders and completed by the RWQCR The intent of this table is not to provide a comprehensive list of secondary goals and Mternatives, but to ensure that stake- holder input has been doc~amented for furore use during the next phase of the planning process. 4. Integration of Long-Term Goals in Future RWQCP Activities During workshop 3, several issues related to the application of the identified long-term goals on future RWQCP activities xvere identified. These issues in- eluded conflicting goals, quantification of goals and economic aspect of goals. Generally spe,@ing, these issues are project specific and wilJ be further addressed during the next phase of the planning process, and when applying the long-term goals to planning and project evaluations. However, a framework methodology. to address thesc issues was provided by the RWQCP during Workshop 4. Conflicting goals could be an issue, for example, when considering UV disinfec- tion as an alternative to chlorination. In this case, at least two of the goals would be con**licting. ()n the one hand, UV disinfection would help n~inimizing dioxin release into the environment. On the other hand, UV disinfection would nor help minimizing energy consumption since it is more energy intensive that chlorina- tion. The RWQCP suggested that mitigation could be used to reconcile conflict- ing goals. Second, the quantification of a goal (i.e. "what does minimize or max~ize exactly mean?") will bc very proiect specific. Using "minimize or eliminate total release of to.,dns" as an example, there arc a variety of alternative discharge levels that could be targeted between a regulatory target and "zero" discharge. ]t is likely that the decision as u} what levcI in the continuum of "zero" to rcgmlatory acceptance is appropriate will bc driven by consideration of other long term goals. Finall.~; flae economic aspect of goals should be look at in terms of extent of goal achieved, life-cycle cost, and un-mitigated issues. It is RWQCP’s belief that iud,km~ent will need to bc made with regards to cost and un-mitigatcd issues when selecting the preferred option. Table 6: Example Secondary Goals and Alternatives 0_o The RWQCP developed a general methodology to apply the identified long-term goals on planning and proiect evaluations. This methodology is flexible enou,,h to "allow for the proiect-specific issues to be tackled on a case-by-case basis. The process was presented to the stakeholders during Workshop 4. The application of the process on a future capital improvement proiect, i.e. blower replacement, was presented as an example. Table 7 details this process. Table 7: Applying the Goals Study to Planning and Project Evaluations : Minimize Impacton Community 2 Determine Process Requirements Air flow requirements 3 Evaluate Basic Technologies "Blowers with varying efficiency, sound level, and capacity exist 4 Evaluate Enhancement Technologies to Maximize Inlet and outlet control elements and/or driver and control Benefits on Goal arrangements could enhance efficiency 5 Set Acceptable Limits E.g.95% and 80 % minimumefficiency at high and low flow, respectively 6 Reconcile Conflicting Goals Mitigate sound level issue using sound enclosure and sound level (Proposed Mechanism: Mitigation)reduction technologies 7 Develop Options Matching Requirements Combination of blower technologies and mitigation measures 8 Screen Options Vs. Limits to DetermineViable Options 9 Perform Like Cycle Analysis on Viable Options Account for energy saving bonus and increasing energy cost 10 Compare Viable Options:Compare energy usage, life cycle cost, and sound level after -Extent of Goal Achieved mitigation for each viable option - Life Cycle Cost -Un-Mitigated Issues 11 Recommendation(Proposed Mechanism:Judgment to Option of lowest energy usage with judgment to be madewith be made with regards to cost and unmitigated issues) regards to life cycle cost and sound level after mitigation The RWQCP is anncipadng applying the long-term goals m the follo\ving up- coming proiects: . Example Activities FY 200t FY 2002 FY 2003 FY 2004 Reclamation1 Blower Replacement Projec~ Sewer Cleaning Program Disinfection Alternatives Study FY2005 Conceptual Design of Future RWQCP Tentative 11Vo new project will actually be implemented unless one of the triggers.established by the City of Palo exists. 5. LTGS Conclusions Through the LTGS, the RWQCP re-established long-term goals that not onh" align with today’s environmental and socioeconomics needs of the communities, but ae also consistent with the underlying theme of sustainabilitv as shown in the chart beloxx: Immobilize or Beneficially Reuse Persistent Toxins Minimize or Eliminate Total Release of Toxins to the Environment Meet or Exceed Regulatory Requirements Minimize or Eliminate Toxins in the Influent (e.g. dioxin) Minimize Energy Consumption and Maximize Energy Life Cycle Efficien cy Minimize or Eliminate Potentially Hazardous Chemical Usage Minimize Impact on Ecosystem Take Leadership Role in Promoting Benefidal Reuse and Environmental Enhancement Maximize Recycled Water as a Supplemental WaterSource Minimize Impactson Community, Including Neighboring Communities Minimize or Justify Financial Impacts on Ratepayer Involve Stakeholder in the Decision Making Process Maximize Worker Safety Meet Future Capacity Needs Nature’s functions and diversity are not systematically subject to increasing concentrations of substances extracted from the earth’s crust Nature’s functions and diversity are not systematically subject to increasing concentrations of substances produced by society Nature’s functions and diversity are not systematically impoverished by physical displacement, over-harvesting or other forms of ecosystem manipulation Resources are used fairly and efficiently in order to meet basic human needs globally The LTGS was the first step in the RWQCP’s planning effort and produced a set of goals that would guide the development of the future system and the improve- mcnts of the existing. The RWQCP Is committed m adhere to these goals and: \Vhcrevcr possible, set targets, the mcans, and dmelinc to eventually acbieve the goals: Be accountable, ,and review the goals and publish the progress towards achieving the goals on an annual basis: (.’ommunicate the goals to R\VQCP emplo.vees, and provide training and education in order that they understand the goals and can perfi)rm their jobs consistent with the goals: Communicate the goals to the general public via arrJclcs in the Pal(~ Alto \Vec "kly Report and Mountain View quarterly paper, for cxample: Meet all legislative requirements and, wherever possible, go beyond these requirements as the leader in environmental management of our waste- water system; and, Coordinate with other agencies. The R\VQCP would like the stakeholders to stay involved for the next phase of the planning effort. The estimated timeframe for the second phase is FY2002. ltowever, each RWQCP project wil! have its own timetine. It is anticipated that RWQCP wilt report in an annual report for small proiects and do public outreach on larger projects. ATTACHMENT B GOALS STUDY S USTAI NAB ILITY MATRIX Meet or Exceed Regulatory Requirements Minimize or EliminateToxins in the Influent (eog.dioxin) Minimize EnergyConsumption and Maximize Energy Ufe Cycle Effidency Minimize or Eliminate Potentially Hazardous Chemical Usage Nature’s functions and diversity are not systematically subject to increasing concentrations of substances produced by society Minimize Irn pacts on Community, lnduding Neighboring Communities Minimize or Justify Financial Impacts on Ratepayer Maximize Worker Safety Meet Future Capacity Needs Resourcesare used faidy and efficientlyin orderto meet basic human needs global y ATTACHMENT C City of Palo Alto City. Manager’s..Report ¯ TO:HONORABLE CITY COUNCIL FROM:. DATE: CITY MANAGER FEBRUARY 23, 1998 DEPARTMENT:PUBLIC WORKS 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 bum and reduce the sludge to a manageable amount of ash product for beneficial reuse. After 26 years of continuous operation, the incinerators have deteriorated significantly prompting the preparation of the Plan. The Plan examines the environmental, economic, and operational impact of sludge treatment options and recommends rehabilitation of the two incinerators immediately, with the addition of a sludge dryer in the future,- if needed. Certain environmental advocacy groups have serious, reservations about the continuation of sewage sludge incineration. However, following extensive discussions with such groups and further data gathering, staff was unable to conclude that other options .are environmentally better. Staffbelieves 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 -RECOMMENDATIONS Siafftec0mmends that C6un’cil: Approve.the recommendations of the Solids Facility Plan tO rehabilitate the sewage sludge incinerators at the RWQCP immediately, and add a thermal dryer when peak loading capacity is required, or if pilot testing of a sludge dryer is desired. Adopt the negative, declaration for Me recommended project to rehabilitate the incinerators at the RWQCP immediately, and add athermal dryer, if needed. Direct staff to forward the amendments to the Parmers’ Agreements to Partner agencies for approval. Direct staff to develop policies for reducing environmental releases of mercury, dioxins, polychlorinated biphenols. Direct staffto establish a process for developing long term goals for the RWQCP, and then remm to Council for approval 0fthe proce:ss. " BACKGROUND. The RWQCP is required to continuously process all incoming sewage. It currently operates two incinerators to treat the solid residue (sludge) of the sewage. The sludge is burned and reduced to a manageable amount of ash suitable for beneficial reuse. The sludge, before burning, is unsuitable for disposal in landfills. The incinerators .are the RWQCP’s only means to treat and prepare the sludge for pro.per disposal. The reliability and redundancy of these incinerators are extremely important to the RWQCP. Concerns with the incinerators were discussed in.earlier staff reports, (CMR:278:96 and CMR:236:97),and are summarized below. The first concern is reliability: The incinerators were constructedin 1971 and have become more and more difficult to keep in operating condition. Large cracks have developed in the half-inch steel shell, and the chances of both incinerators being down at the same time have increased to a point of very serious concern. Given the 24-hour per day, 365 day per year nature of the operation, inability to operate the incinerators would present immediate emergency conditions and, within 24 hours, human health concerns. .. The second concern is redundancy: The wastewater flow going into the RWQCP varies daily and seasonally. While. the two existing incinerators are permitted to operate concurrently to meet varying flow requirements, this operating mode does not allow for emergencies or repairs. Currently, one of the incinerators is so frequently under repair that a back-up almost never exists. The RWQCP is required to provide reliable, uninterrupted service. CMR: 141:98 Page 2 of 8 The third concern is pollutant releases: The RWQCP incinerators are in compliance with current regulations. However; the existing emission control devices on the incinerators are outdated and therefore, maximum reduction of pollutants cannot be achieved. The solids treatment and disposal options are currently heavily regulated, and future regulations are uncertain~ The issues associated with the pollutant releases to air, land, and water-from sludge treatment and disposal continue to be a concern with.the public and regulatory agencies. These concerns prompted the preparation of the Solids Facility Plan(Plan). The Plan examines the current and future potential regulations, and evaluates the environmental and economic impact of several options. - DISCUSSION RWQCp staff and staff from Partner agencies worked as technical advisors in preparing the Plan. The Plan was developed through two studies, which have been under way since 1994. The ftrst study evaluated the feasibility of the full realm of technologies for handling the sludge, and reduced down the number Of feasible options. The recommendation, of the feasibility .study formed the basis of the second study, the Plan. Two technologies are considered feasible options besides incineration: sludge digestion and sludge drying. Sludge digestion is the anaerobic breakdown of sludge in large holding tanks.over, long periods. The end product is digested, sludg’e; commonly called biosolids. Sludge drying uses low heat to evaporate the water out of the sludge without burning the organics. The residue from the dryer is in the form of pellets. The residue from both processes .are typically used on .agricultural land as soil supplement. Virtually all sewage treatment plants the size of the RWQCP use incineration, digestion, or drying.. In the West, almost all plants use digestion, with land application of the digested sludge. The RWQCP chose incineration 27 years ago because .incineration takes less land and produces less odor and residue. Recent studies demonstrate that another advantage of incineration is that pathogens, and most organic pollutants in the sludge such as polychlorinated biphenols (PCBs) and organochiorine 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. Staff was unable to conclude that one technology is "better" for the environment than another. All options have certain negative environmental impacts. Each releases different pollutants to different media - air, land or water. Incineration produces air pollutants, consumes energy, and does not preserve the organic material for sludge reuse. Digestion does not destroy organic pollutants, or dioxin. Dryers consume even more energy and apparently have never been tested for dioxin air emissions. The inability to draw conclusions is also due to the difficulty of comparing different types of environmental releases. The pathways for the final, impact CMR:141:98 " Page 3 of 8 resul ".ting from initial pollutant reieases are numerous and difficult to trace. All three options can meet all current environmental,.health andsafety requirements Therefore~.staff focussed on the following criteria in comparing the options: ¯Cost ¯Land use ¯Visual impact ¯Potential odor The table below is the comparison of the three options: :Options Incinerator Rehab. Plus Dryer . Digesters Dryers $11.4 million $29.7 milIion $17.2 million 800 sf% existing 45,000 sf> existing 1500 sf> existing . .’-:!~is,M.ilmpact Low High Low Low High Medium The incinerator rehabilitation, plus dryer option, will meet the current and the known future regulations; it is the lowest cost, has the smallest, footprint, least visual impact, and least odor.. Staff, therefore, recommends the project to rehabilitate the incinerators immediately, and to add the dryer if needed. The proje. Ct will include three ¯major elements: Repair the existing incinerators to ensure safe and reliable operation. Relocate the emission control device to outside of the incinerator to allow full utilization of the entire incinerator for Combustion. The improved efficiency will enable a single incinerator to take care of the vaiying fl0w most of the time, leaving. one incinerator as a reliable .standby. A dryer may be installed, if the City decides to pilot test the dryer, or when it is needed to help treat the solids. Replace the existing emission control .devices with new state-of-the-art devices to improve the emission. The Partners’ s .taffsupport City staff’s recommendation and have agreed to participate in a joint financial plan entailing debt financing. City staffis presently working with the Partners on the amendment tofinance the project. Palo Alto would issue the debt, and Partner agencies would pay Palo Alto in accordance with the amendment to the Partners’ CMR: 141:98 Page 4 of 8 agreements, which is consistent with past capital -financing. The draft amendment was prepared jointly by Palo Alto’s City Attorney’s office and outside counsel at Jones, Hall, Hill & White. It incorporates comments from the City’s financial advisor, Stone & .Youngbergi The amendment will be presented to the Council in March1998. " Many environmental advocacy groups(EAGs) raisedthe 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 emi.’ssion, and would allow reuse of the organic matter as a soil supplement withbut the currentnegative 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 investiga(ed 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 thosereductions will be greater than approximately 20 percent. Thus, nonrincineration 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 als0 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 wouldcontinue 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 th.an the planned repair, and anywork to improve the air emissions would most likely not be implemented because of the urgency of the situation. CMR: 141:98 .. Page 5 of 8 With respect to the altematives to incineration, both digestion and drying options would haye a significant affect on the environment, odor control, and visual impact. Without full environmental, review by .the public, these options cannot be considered as an alternate project. Therefore, staff would be required to restart data gathering, conceptual design and environmental review. It would be several years, before staff could return to Council with an alternative digestion or drying option. RESOURCE IMPACT The capital project is estimated to cost approximately $6.2 million for.the rehabilitation of the incinerators, and $5.2 million for the dryer (in 1998 .dollars). The attached cash flow analysis (Attac .hment B) shows the Partners’ share of a twenty-year bond funding for the project. If the rehabilitation is constructed in 1999 it is estimated that the sewer rate impact tO the Palo Alto rate payers will be an increase of less than three percent.~ POLICY IMPLICATIONS The recommended project is consistent with City policies. The recommendation to establish a process for determining long term goals will lead to the adoption of new policies. TIMELINE If approved, the. rehabilitation of the incinerators will proceed immediately at the following schedule: .~ Final design starts Permitting Debt financing Bid Construction starts Bond Sale May 1998 February 1999 May .1999 May 1999 August 1999 Fall 1999 ENVIRONMENTAL REVIEW An environmental check list was prepared for the recommended project (Project). Compared to the existing incinerators, the check list showed that the Project has no major increase in impact. TheProject will result in better emissions compared to the existing facility. There will be some temporary impact due to construction activities that will be mitigated. A Negative Declaration (N.D.) has, therefore, been prepared for the Project. The N.D. (Attachment A) was distributed and notice was given to the public for review and comments. The review period started on January 16, 1998 and ended on February 14, 19981 Staff received some questions related to the details of the design and repair. A pre-design was performed on the Project prior to the preparation of the N.D. Final design will be CMR: 141:98 Page 6 of 8 performed.upon Council .approval of the ProjectJ The final design wil! include all the details for the repair and the construction. A letter was received from the League 0fWomen Voters of Palo Alto. The letter stated that the incinerator-rehabilitation project is ¯probably the.appropriate solution at the present ~ime, 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 Ar.ea Action with the following five suggestions: 1.Develop dioxin reduction policy for the City ofPalo Alto,-and request neighboring cities to do the same. 2.Build a solids thermal¯ dryer to pilot test a non-dioxin creatingalternative 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 CMK: 141:98 Page 7 of 8 REVIEWED BY: GLENN S. ROBERTS Director of Public Works CITY MANAGER APPROVAL.: CMR:141:98 Page 8 of 8 Initial Study/Negative Declaration (IS/ND) ATTACHMENT A Palo Kegior~ Water Qual.ity Control Plant Solids Facility Plan City of Palo Alto Project Title: Palo Alto R.egional Water Quality Control Plant (’PARWQCP) Solids Facility Plan Lead Agency Name and Address:City of Palo Alto Public Works Department Kegional Water Quality Control Plant 2501 Embarcadero Way Palo Alto; California 94303 Contact Person and Phone Number: Daisy Stark, PARWQCP Engineer, 650-329-2598 Project Location: 2501 Embarcader.o Way, Palo Alto, California Application Number(s): Not Applicable Project Sponsor’s Name and Address: City of Palo Alto, Public Works Department, Regional Water Quality Control Plant, 2501 Embarcadero Way, Palo Alto, California, 94303 7.General Plan Designation: Major Institution/Special Facilities 8.Zoning: Public Facilities with Site Design overlay (PF(D)) 9.Desc.ripfion of Project: PARWQCP Background The Palo Alt0. 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) EAST PALO ALTO SANITARY DIST. " To San Francisco WATER QUALITY CONTROL PLANT San Francisco Bay PALO ALTO PALO ALTO Figure 1 Service Area Palo Alto Regional Water Quality Control Plant Not To Scale To San Jose CH2MHILL (see Figure 3). The liquid and solid portions are then treated. The .treated wastewater is discharged via an’outfall to the San Francisco Bay. The solid substance removed from the wastewater ig called sewage sludge and is treated in the Solids facility of the PARWQCP, ,The solids facility includes ’ gravity" thickeners and belt presseswhich remove more of the ~vater from the sludge, two existing incinerators which bum the sludge to an ash product, and an , ash storage silo and bagging system. The ash product is trucked to the Central Valley and applied to agricultural lands as a soil amendment. Figure 3 ¯ $impliged PARWOCP Schemagc PARWOCP Wastewater _ ~ Wastewater Treatment Processes Solids Incineration Treated San Francisco Wastewater ,., Ash ~ Farmland A more detailed discussion of the incineration process and the need for the Project is provided in the following sections of this IS/ND. 4 The Incineration Process and the Need for Project The Incineration Process Figure 4 shows the location of the incineration building at the PAKWQCP. The incineration process, depicted graphically in Figure 5, consists of two multiple-hearth incinerators, .each ¯ wit~ two air pollution control devices .to minimize emissions into the atmosphere. ~he two incinerators each consist of six.hearths (separate chambers) in a vertical column where ~aaturai 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 ~ wet scrubber that removes pollutants from the incinerator ~ack gases. Need for the Proiect The PARWQCP incinerators, which have been in service since 1971, have become more and more difficult to maintain in. recent years and require frequent, costly repairs. Equipment downtime has increased dramatically because of the frequent repairs. The chance of both incinerators being out of service at the .same time has increased to the point of causing concerns about safe operations of the plant. The wastewater treatment plant must be able to continuously process all incoming .sewage. Given the 24-hour-per-day, 365-day-per-year nature of the operation, the inabili.ty ~o operate the incinerators would present immediate emergency conditions and, within 24 hours~ human health concerns. Project Goals The proposed Project involves improvements to the solids facility, and is designed to meet the following goals: Repair the two existing incinerators to ensure a safe operating environment. Improve the efficiency of the incinerators so that only one incinerator needs to operate at a time, leaving one incinerator as a firm, reliablestandby. Upgrade the air pollution contro! devices to improve the emissions of the incinerators. Figure 5. Current Indnerator Process Residual Solids----~ Incinerator Atmosphere ~ Air Scrubber Afterburner Residual Solids Cooling Hearth Air Scrubber S mCI.Gas - Afterburner. Codling Hearth Burning Hearths Incinerator The .first goal of the proposed Project is to make repairs to the two incinerators that .will eliminate the frequent and costly short-term repairs, great.ly 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 flow requirements, this operating mode does not allow for emergencies or repairs. Currently, one of the incinerators is under such frequent repair that a back-up incinerator almost never exists and urgent conditions are the norm. To relieve these urgent conditions, two Project .components are proposed. The first component, a true (separate) afterburner, will be constructed to allow the top hearth to be used to burn the solids. This Will increase the throughput (the amount of solids that can be handled by one incinerator) and will also reduce the need to run both incinerators simultaneously. The second componem, a solids thermal dryer, will be added if the City decides to pilot test the dryer or when it is.needed to help treat the solids from anticipated population growth in the PARWQCP service area. The dryer, will further reduce the water content of some of the solids before feeding the solids to the incinerators. The drier solids are much easier for the incinerator to handle and further decrease the likelihood that both incinerators would have to be operated simultaneously. The third goal of the proposed Project is to upgrade the solids facility’s air pollution control equipment. This goat will be met with two Project components for each incinerator. First, the new afterburners, which will help to meet the second goal, will be more efficient than the current afterburner and will operate at a higher temperature to completely oxidize the organics in the stack gas. Second, new two-stage wet scrubbers will be installed that capture substantially more gases and particulate matter than the current scrubbers. Figure 6 shows the improved incineration system upon completion of the Project. Impact of th~ Proposed Proiect on PARWQCPTreatment Capacity The proposed project will not increase the PARWQCP’s treatment capacity. The incineration system is a component of the PARWQCP, and a modification to the incineration system would only cause an increase in the PARWQCP capacity if it were currently the only limiting. component of the plant. The average dry weather flow to the PARWQCP in 1996 was 24 million gallons per day (MGD). from the PARWQCP’s service area of approximate 220,000 Figure 6 P~po~ed lncineraObn System Atmosphere Afterburner Stack Gas 2-Stage Scrubber Afterburner. Stack Gas Residual Incinerator Cooling Hearth Residual Sohds ~ Coohng.Hearth Ash Farmland B -ning. Hearths Incinerator people. The wastewater treatment processes (as distin~m.fished from the incineration system shbwn in Figure 3) have a design capacity of 38 MGD average dry weather floW, which could serve a population of approximately 350,000. By contrast, the incineration system has a current approved maximum capacity of 60 dry-tons per day (DT/D) (30 DT/D per incinerator), with a 1996 usage of approximately 17 DT/’D to serve 220,000 people. The Proposed Project will increase the peak capacity of one incinerator to 32 DT/D. While it could be argued that the capacity of incinerator system would then be 64 DT/D (32 X 2 incinerators), this is not the ease for two reasons. First, only one incinerator would be operated at a time. The purpose of the project, components is to insure a back-up incinerator is ready at all times.. Second, the Bay Area Air Quality Management District (BA.AQMD)Permit to Operate for the PARWQCP limi’ts maximum throughput to 60 DT/D. No modification to .that permit is being sought. Therefore, the incinerator system capacity would remain at 60 DT/D. This system could serve a population as great as approximately 410,000.- The incinerator capacity can support a larger additional population than the available capacity in the wastewater treatment processes. The incineration .system could serve a population as great as approximately 410;000, while the wastewater treatment process could only serve a population of approximately. 350,000 (see Table 1). Therefore, it is the wastewater treatment Table 1 Current Throughput and Maximum Capa~’ty Wastewater Treatment Processes Incineration System 1996 VALUES CURRENT MAXIMUM CAPACITY.. PopulationThroughput Average 24 MGD 17 DTD 220,000 220,000 Throughp~ Capacity 38 MGD* 60 DTD** Approximate Population Equivalency 350,000 410,000 *Average "60 DTD = Maximum Peak Daily Capacity. Average capacity associated with this peak capacity used to deterrnine PoPulation Equivalency 10 processes, not the incineration system, that limit the PARWQCP’s capacity. The proposed Project does not increase the-capacity of the PARWQCP. A major capital 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 PAKWQCP. Such a .project is unlikely within the next several decades because the current PARWQCP ~apacity 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 Project Approach ’ Following are additional details on the proposed Project components. Repair of Existin£ Incinerators The two incinerators are 18.75 foo~ 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 onthe 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 Modification ofIncineration System The modification will increase-the efficiency of the existing emissions. It will consist of the following: incinerators and improve air Construction of a new structure (possible location shown on Figure 4) immediately adjacent to the existing building .to house the new air pollution control equipment, including an external afterburner, Venturi-Pak scrubber, and exhaust.ducting: The new structure will be au 800 square foot addition to the existing 5,300 square foot incinerator building. It will be about the same height as the existing building (46 feet), and will be sheltered from the street and the public by other treatment plant structures and trees surrounding the plant. The new air pollution control equipment willprovide significant reductions in emissions compared to current emissions. Operational changes to use the top hearth as a burning hearth. Installation of an equalization storage tank. The quantity of dewatered sludge to be incinerated will. vary hourly. The ability to temporarily store, or e.qualize, these variations will enhance operating results, particularly at peak conditions. A new equalization storage tank will be constructed adjacent to the south side of the incinerator building as shown on Figure 4. It will consist of a steel storage tank with a closed top and mixers. It will be 25 feet in diameter and 30 feet tall, providing 100,000 gallons of storage.It wiLl be sized for the projected average annual day’s sludge production of t8.5 DT/D. The rank will be vented to the incinerator inlet combustion air to make use of the incinerators’ new air pollmion control equipment. The height of the-tank is lower than the existing incinerator building and the surrounding structures. It will not be visible from the street or by the public. Addition of a Thermal Dryer A small thermal dryer unit would be added if the City decides to pilot test the dryer or when a single incinerator is unable to meet peak loads during the project life (through 2020). The purpose of the thermal dryer is to increase the dryness of sludge beyond that which can be 12 achieved with the existing belt’press dewatering. Available incinerator Capacity is greater with drier solids. The .sludge dried bythe thermal dryer during peak periods would be added to the remaining dewatered sludge before incineration. The thermal dryer is expected to be operated only sporadically during peak loading conditions, for a total of about 4. weeks during the year. This will typically occur during the wet weather months in the winter after periods of particularly heavy storms. " Thermal drying involves removal of moisture from the solids to a heated air stream. There are certain issues associated with drying that can be successfully addressed with proper design and operational procedures. The product from the dryers is organic and very dry, which can cause dust. Since organic dust can be a source of exp!osions, thereby creating a potential safety problem, the system will bedesigned 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, wl’fich 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 hol!ow~metal disks Or paddles are heated from theinside and conduct heat to the solids on the outside of the paddles. The thermal drying facility can be located inside or outside the existing sludge incinerator building. A site just north of and adjacent to the existing incinerator building, as shown in Figure 4, has been identified for an outside location. Conveyors will be installed to transport 13 the dewatered solids to the thermal drying system from the belt presses and to return the dried solids to the indnerator. Also, for odor control, the foul air created during the thermal drying process will:be discharged to the incinerator inlet air stream as part of the inlet combustion air. This air eventually flows to the incinerator air emissions control system and.helps, ir~ fuel savings in incinerator operations .since it is heated. The dryer unit includes abatement equipment for the bOiler, which bums natural gas to heat the dryer. If the outdoor location is selected, the facility will be lower in height than the existing incinerator building and other surrounding structures, It "will be sheltered from the street and the public by Other treatment plant, structures and trees surrounding the iolant. California Environmental Quality Act (CEQA) Requirements The California Environmental Quality Act. (CEQA) requires that potential significant environmental effects ofa.project proposed by a public agency be identified and disclosed to the public. A significant effect on the environment is generally defined as a "substantial or potentially substantial adverse change in the physical environment." "Environment" means the physical conditions, including both natural and man-made conditions, that exist within the area affected by a proposed project. The environmental assessment for the proposed project has identified no significant environmental effects. A Negative Declaration must include a written statement briefly explaining why a proposed project will not have a significant environmental effect when compared to the existing environment. It must include a description of the project and location, identification of the project proponent, and proposed finding of no significant effect. It must also include a copy of the Initial Study. checklist that justifies the finding of no significant effect. This Negative Declaration contains all of the required information. 14 11.Other agencies whose approval is required (e~g., permit, financing approval, or participation agreement.) .... State/Regional Agencies Bay Area Air Quality Management District San Francisco Bay Regional Water Quality Control Board City of Palo Alto City of Palo Alto Public Works Department ~ City of Palo Alto Department of ¯ Planning and Community Development City of Palo Alto Architectural Review Board City of Palo Alto Fire Department Other Local Agencies City of Mountain View City of Los Altos East Palo Alto Sanitary District Town of Los Altos Hills Authority to Construct.(A!C) and Permit to Operate(P/O) - if grandfather status is not maintained, then will be needed (existing facility attained .- grandfather status because it was constructed before 1972, and will retain this status as long as it is not modified in a manner that results.in an air emission increase of a regulated pollutant or the repair costs are not greater than 50% of the capital cost of a new incinerator) Clean Water Act: 40 CFR Part 503 Rulesmproposed revisions to CWA Part 503 will be incorporated into the existing NPDES Permit; will require Continuous Emissions.Monitoring for CO and NOxalong with existing requirements for Total Hydrocarbons by 2000 Grading and Drainage Review Building Use Permit Site and Design Review Architectural Review Hazardous Materials Disel0sure Checklist!Inspection Approval and.Funding Approval and Funding Approval and Funding Approval and Funding 15 []Land Use and Planning []Population and Housing []Geologic Problems Environmental Factors Potentially Affected: The envir6nmental factors checked below would be potentially affected by this project as indicated by the checklist on the followhag pages. ¯ [] Transportation/Circulation [] Public Services [] Water [] Air Quality IS! Biological Resources [] Energ3’ and Mineral Resources [] Hazards ¯ [] Noise [] Mandatory Findings of Significance []Utilities and Service Systems []Aesthetics []Cultural Resources []Recreation 16 Determination: On the basis of this initial evaluation: I find that the proposed project COULD NOT.have a signific.ant effecton the environment, and a NEGATIVE DECLARATION will be.prepared. I find that although the proposed project could have a significant effect on the environment,.there will not be a significant effect in this case because the mitigation measures described on an attached sheet have been added to the project. A. NEGATIVE DECLARATION will be prepared. I findthat the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required. I find that the proposed project MAY have a significant effect(s) on the environment,but at least one effect 1) has been adequately analyzed in an earlier -document pursuant to applicable legal st~dards, 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 itmust analyze only the effects that remain to be addressed.. Project.Planner Date Director of Planning & Community Environment 17 Evaluation of Environmental Impacts: 1) 4) A brief explanation is required for all answers except "No Impact’.’ answers that are adequately supported by the information sources a lead agency cities in the.parentheses following each question. A "No Impact" answer is adequately-supported if the referenced information sources show that the impact simply does not apply to projects like the one involved (e.g. the project falls outsidea fault rupture zone). A "No Impact" answer should be expl.ained where it is based on project-specific factors as well as general standards (e.g. the project will not expose sensitive receptors to pollutants, based on a project- specific screening analysis).. All answers must take account of the whole, action involved, including off-site as well as on-site, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts. ’ "Potentially Significant Impact" is appropriate fithere is substantial evidence that an effect is significant. If there are one or more "Potentially Significant Impact" entries when the determination is made, an EIP,. is.required. "Negative Declaration: Potentially Significant Unless Mitigation Incorporated" applies where the incorporation of mitigation measures has reduced an effect from "Potentially Significant Impact" to a "’Less than Significant Impact." The lead agency must describe the mitigation measures, and briefly explain how they reduce the effect to a less than sigrdficant level (mitigation measures from Section XVII, "Earlier Analyses," may be cross-referenced). Earlier analyses may be used where, pursuant to the tiering, program EItL or other CEQA process, an effect has been adequately analyzed in an earlier EIP,. or negative declaration. Section 15063(c)(3)(D). Earlier analyses are discussed in Section X’VII at the end of the checklist. 6)Lead agencies are encouraged to incorporate into the checklist references to information sources for potential impacts (e.g. g~neral plans, zoning ordinances). Keference to a.previously prepared or outside documen~ should, where appropriate, include a reference to the page or pages where the statement is substantiated. See the sample question below. A source list should be attached, and other sources used or individuals contacted should be cited in the discussion. 7)This is only a suggested form, and lead agencies are free to use different ones. 18 Issues (and Supporting Information Sources): I. LAND USE AND PLANNING. Wouldthe proposal: Conflict with general plan designation or zoning? b) II. d) e). a) b) c) Conflict with applicable environmental plans, or policies adopted by agencies with jurisdiction over the project? Be incompatible with. existing land use in the vicinity? Affect agricultural resources or operations (e.g. impacts to soils or farmlands, or impacts from incompatible land uses)? Disrupt or divide the physical arrangement of an established community (including a low-income or minority community? POPULATION AND HOUSING. Wou’ld the proposal: Cumulatively exceed official regional or local population projections? Induce substantial.growth in an area either directly or indirectly (e.g. through projects in an undeveloped area or extension of major infrastructure)? Displace exi~ing housing, especially, affordable housing? III. GEOLOGIC PROBLEMS. Would the proposal result in or expose people to potential impacts involving: a) Fault rupture? b) Seismic ground shaking? Sources ,2, 4 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): c) Seismic ground failure, including liquefaction? d) Seiche, tsunami, or volcanic hazard? e) Landslides or mudflows? f) Erosion’, changes in topography or unstable soil conditions from excavation, grading, or fill? g) Subsidence of the land? h) Expansive soils.? i) Unique geologic or physical features?. IV. WATER. Would the proposal result in: a)Changes in absorption rates, drainage patterns, or the ,rate and amount of Surface runotT?. - b)Exposure ofpe0ple or property, to water related hazards such as flooding? c)Discharge into surface waters or other alteration of surface water quality (e.g. temperature, dissolved oxygen or turbidity)? d)Changes in the amount of surface water in any water body? e)Changes in currents, or the course or direction of water movements? f) Change in the quantity of ground waters, either through direct additions or withdrawals, or through interception of an aquifer by cuts or excavations or through substantial loss of groundwater recharge capability? g) Altered direction or rate of flow of-groundwater? h) Impacts to groundwater quality?, Sources 3 3 1,3 3 3 1,3. Potentially Significant Impact l 1 1 Negative Declaration: Potentially Significant Unless Mitigation Incorporated. Less Than Significant Impact ,No Impact ÷ ÷ ÷ .÷ ÷ ¯ 20 Issues (and Supporting Information Sources): i) Substantial reduction in th.e amount of groundwater otherwise available for public water suppliesZ V.’ AIR QUALITY. Would tlic proposal: a)Violate any air quality standard or contribute to an existing or projected air qtJality violation.’? b) Expose sensitive receptors to pollutants? c)Alter air mo~;ement, moisture, or temperature, or cause any change in climate? d) Create objectionableodors? VI. TRANSPORTATION/CIRCULATION. Would the proposa.l 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)?. Sources 1 1 -1 1 1,2 1,2 1,2 Potentially Significant Impact !~/egative Declaration: Potentially Significant Unless Mitigation Incorporated .Less T.han Significant Impact NO Impac 21 .Issues (and Supporting Information Sources): b) Locally designated species (e.g. heritage trees)7 c)Locally designated natural communities (e.g. oak forest, coastal habitat, etc.)? d) e) VIII. a) b) c) Wetland habitat (e.g. marsh, riparian and vernal pool)? Wildlife dispersal or migration corridors? ENERGY AND MINERAL RESOURCES. Would the proposal: " Conflict with adopted energy conservation plans? " Use non-renewable resources in a wasteful and inefficient manner? Result in the loss of availability of a known mineral resource that would be of future valueto the region and the residents of the State? IX. HAZARDS. Would the proposal involve: a) c) A risk of accidental explosion or release of hazardous substances (including, but not limited to: oil, pesticides, chemicals or radiation)? Possible inte.rference with an emergency response plan or emergency.evacuation plan? The creation of any health hazard or potential health hazards? d)Exposure of people to existing sources of potential health hazards? e)Increased fire hazard in areas with flammable brush, grass, or trees? X. NOISE. Wo’uld the proposal resul! in: Sources 1 1 1 Potentially Significant Impact " Negative Declaration: Potentially Significant Unless ¯ Mitigation Incorporated Less Than Significant Impact a) Increases in existing noise levels? No Impact 22 Issues (and Supporting Information Sources): b) Exposure of people to severe noise levels? Xl.PUBLIC SERVICES. Would the proposal have an effect upon, or resolt in a need for new or altered government services in any of the following areas a) Fire protection? b) Police protection? c) Schools? :" "" ......... : d) Maintenance of public facilities, including roads? e) Other g0vemmental services? XII.UTILITIES AND SERVICE SYSTEMS. Would the proposal result in a need for new systems or supplies, or substantial alterations to tl~e following utilities: a) Power or natural ~,as’~ b) Communications systems? c)Local or regional water treatment or distribution facilities? d) Sewer or septic tanks? e) Storm water drainage? f) Solid waste disposal? g) Local or regional water supplies? XIII. AESTHETICS. Would the proposal: a) Affect a scenic vista or scenic highway? b) Have a demonstrable negative aesthetic effect? SonFces 1 1 1 1 1 1 1 1 1 1 1 1 Potentially Significant Impact Ndgative Declaration: Potentially Significant Unless Mi.tigation Incorporated Less Than Significant Impact NO Impac~ 23 Issues (and Supporting Information Sources):Sources c) Create light or glare? XIV.CULTURAL RESOURCES. Would the proposal: a) Disturb paleontological resources? b) Disturb archaeological resources? c) Affect historical resources? d)Have. the potential to cause a physical change which would affect unique ethnic cultural values? e)Restrict existing religious or sacred uses within the potential impact area? XV. RECREATION. Would the proposal: a)Increase the demand for neighborhood or regional parks or other recreational facilities? Affect existing recreational opportunities? MANDATORY FINDINGS OF SIGNIFICANCE. 1 I 1,2, 1,2 1,2 Potentially Significant Impact Negative " Declaration: Potentially. Significant Unless Mitigation Incorporated- Less Than Significant Impact NO Impact 1,2 * b)1,2 XVI. a)’" ~ .........Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self=sustaining levels, threaten to eliminate a plant or animal ¯ community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the majoi" periods of California history or prehistory? 24 b)Does the project have the potential to achieve short- term, to, the disadvantage of long-term, environmental goals? c) d) Does the project have in/pacts 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. a) c) Earlier analyses may be used where, pursuant to the tiering, program EIR~ or other CEQA process, one or more effects have been adequately analyzdd in an earlier EIR or negative declaration. Section 15063(C)(3){D). In this case a discussion should identify the following on attached sheets: Earlier analyses used. Identify earlier analyses and state where they are available for review. Impacts adequately addressed. Identify which effects from the abovechecklist were within the scope of and adequately analyzed in an earlier, document pursuant tot he applicable legal standards, and state whether such effects were addressed by mitigation measured based on the earlier analysis. Mitigation measures. For effects that are "Negative Declarations: Less than Significant with Mitigation Incorporated," describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address sit.e-specifi~ conditions for the project. XVIII. SOURCE REFERENCES l "2 3 4 5" Palo Alto Regional Water Quality Control Plant, Solids Facility Plan, MaY 1997 Palo Alto Comprehensive Plan, 1980-1995 Palo Alto Comprehensive Plan Update Draft Environmental Impact R.epon, December 1996 Voice mail message fi-o=~-= Jim Gilliland (City of Palo Alto) regarding zoning, on June -94, 1997 Voice mail message from Jim Gilliland (City of Palo Alto) regardingzoning, on .lune 26, 1997 25 EXPLANATIONS FOR CHECKLIST RESPONSES la lb The proposed project is~onsistent with the existing Major Institution/Special Facilities general plan designation of th~ PAR.WQCP and the Public Facilities with Site Design Overlay (PF(D)) zoning. The PAR.WQCP site is bordered on the west by one- and two-story office buildings, on the south by the City landfill, on the east by the B.ay.and. Baylands Nature Preserve, and on the north by the Palo Alto Airport. The Pal0 Alto Golf Course is also. locate.d just west of the airport. Much of the PAR.WQCP site is screened from these.land uses by trees along its perimeter. However, the access road to the landfill runs directly alongthe east plant boundary, so some PARWQCP facilities, such as the fixed film reactors, are clcarty visible. The proximity to the airport places height restrictions on the treatment facilities. The top of the existing incinerators are generally considered the maximum height allowed. The proposed project does not conflict with any applicable environmental plans or policies adopted by agencies with jurisdiction over the project. " .. The proposed project would not be incompatible .with existing land use in the vicin.ity. Modifications to PAR.WQCP facilities would be limited to the existing treatment plant site, .. I d The proposed project would not impact agricultural resources or operations. ¯I e ......The p.roposed project has no impact on the physical arrfingement of any established communities. II a The propo.sed project will not cumulatively exceed official regional or local population projections. See discussion for Issue II b below. 1I b The proposed project will not induce growth directly or indirectly. See discussion on pages 5 to7 of the attached .project description. !1 c The proposed project is limited to the existing treatment plant site and would not displace any existing housing.. ¯ III a lllb III c I11 d III e III f III g III h lll i IVa The proposed project is not located on a fault and would not result in or expose people to fault rupture. The Palo Alto Comprehensive Plan designates the project area to be prone to violent shaking in the event of a major earthquake. This shaking cou!d cause significant damage to structures if not properly designed or constructed. A geotechnical report for the project will be prepared and the recommended design measures identified in that report will be incorporated into the project. Liquefaction can occur when loose, saturated, relatively clean cohesionless.soils are subjected to ground vibrations. The project area is situated adjacent to the San Francisco Bay and is underlain in part by Bay mud, an organic clay which ~s so~t and compressible. Sand lenses are interspersed throughout the Bay mud; these lenses carry groundwater in the vicinity of the B.ay and, during seismic events, have the potential t6 liquefy. According to’ the City of Palo Alto Comprehensive Plan, the site has a high liquefaction potential. The geotechnical investigation to be pre~a~ed for the project will ide.ntify appropriate design measures that will be incorporated into the project to address liquefaction issues. The proposed project would not result in or expose people to seiche; Tsunami, or volcanic hazard. The.proposed project would not result in or expose people to landslides or mudflows. The proposed project would not result in or expose people to erosion, changes in ¢opography or Unstable soil conditions from excavation, grading, or fill. The proposed project would not result in or expose people to subsidence of land. The proposed project.would not result in¯ or expose people to potential impacts from expansive soils. No uniq.ue geologic or physical features e.xist at the project site, so the proposed project would not result in or expose people to potential impacts from unique-geologic or physical features. The proposed project would be constructed on currently paved ground and would not add paved area. Hence the. proposed project would not result inany changes in absorption rates, drainage patterns, or the rate and amount of EXPLANATIONS FOR CHECKLIST RESPONSES surface runoff. IV b The treatment p!ant site is in a flood zone, as designated by FEMA. How’~ver, the proposed project would not result in any additional exposure of people or property to water related hazards such as flooding. All applicab.le FEMA requiremen,ts Will be met. IVc The air pollution control equipment in the proposed project would recycle trace amounts of metals from the scrubber back to thc trcamlcnt plant headwor "ks. 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 xvould 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 ~th.rough substantial loss of groundwater recharge capability. IV g The proposed project would not alter the direction or rate of flow of groundwater. : IV h The proposed project would not result in impacts to groundwater quality. IV i The proposed project would not result in substantial reduction in the amount of groundwater otherwise available for public water supplies, V a Construction-related emissions, such as dust (fine paniculate matter, 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 wa(er sweeping all paved access roads, parking lots, and staging areas, will be required by the Bay Area Air Quality Management District (BAAQMD) to reduce any potential dugt emissions. Applying effective and comprehensive control measures during project construction would p~:event violations, of any air standards. There will be no net increase in emissions as compared with current emission levelsbased on recent source test data. Table 1 at the end.of this checklist summarizes the current and future emissions associated with this project. The project will be designed with a new air emissions abatement system that willhandle emissions from the incinerator, thermal solids dryer, scum handlingsystem, 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 wilt improve existing air emissions by reducing, on the average, metats by 54 percentl 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 pollutan~ exposuCe to sensitive receptors. Sensitive receptors include schools, daycare centers, hospitals, and nursing homes. The PARWQCP staff will adhere to IXX. EXPLANATIONS FOR CHECKLIST RESPONSES Vc Vd VI a Vl b VI c VI d VI e VII a VII b " VII c Vll d proper abatement equipment installation (including scheduled shutdown of incinerators during installation), testing, and operating procedures to minimize any potential air emission impacts to workers in the light industrial businesses near tl~e project site. . . The project does not include the addition or modification of major heat or moisture sQurces and would riot result in a significant alteration of air movement, moisture, temperature, or other climatic changes. The dryer, which would only be operated only occasionally (typically maximum 4 weeks per year), is the only new potential odor source, but is not expected to create an impact. The project will be designed to handle odor sources (i.e., dryer, scum handling, and feed tank) by venting the exhaust directly to the incinerator inlet air. There it will be combusted and then sent to the incinerator emissions abatement system for added destruction of combustion by- products. Because of this configuration, the potential for odor outside of the abatement system will notbe created. Therefore; no additional odors will be released beyond current operating conditions. Objectionable odors are not expected to occur. Facility construction will have a less than significant impact on traffic..The number of trucks to haul solids by-products (ash) will be the same asthe current number, which is one truck per week. Traffic related to construction activities are expected to be similar to the traffic that occurs during annual maintehance and rehabilitation of the Plant’s existing " systems. This could include up to 8-10 workers entering the.site per day and a limited number of trucks delivering concrete, other materials, and equipment to the site. Traffic impacts from .construction would be less than significant. The proposed project does not contain any transportation design features.and would not result in hazards to safety from design features such as sharp curves or dangerous intersections. Project construction activities and operations at PARWQCP would not interfere with emergency access or access to nearby uses, nor are they expected to interfere with emergency access at the PARWQCP. PARWQCP currently has adequate parking capacity and would not add any additional employees as a rcsult of the project. Parking needs for construction activities would not exceed current parking needs for rehabilitation and maintenance activities. Facilities at PARWQCp would not be expanded outside the current plant boundaries and would not be a hazard to pedestrians or bicyclists. There are no pedestrian or bicycle paths within the PARWQCP. The project does not conflict with City. of Palo Alto adopted policies supporting alternative transportation. The project would have no impacts on rail or Waterborne traffic. Traffic at the adjacent airport would not be impacted by the project constru(tion or operation. No pan of the rehabilitation or expansion would be greater in height than the existing incinerators, which are considered the maximum height allowable to avoid impacting airport traffic. The proposed project will result in a 99.9% decrease in dioxin and furan emissions, an average 54 percent decrease in metals air emissions, and an average 48 percent decrease in criteria pollutant emissions compared to current emissions, resulting in a project benefit. As a result, no impacts to endangered, threatened, or rare species in the adjacent marshes are expected. The proposed project would require the removal of one or two eucalyptus trees next to the incinerator on the PARWQCP site. However, these trees are not heritage trees and they are less than 20 years old. They will need to be removed with or without this project, since they pose a fire hazard due to their proximity, to the incinerator chimney, and the tree roots are invasiv.e and have the potential to damage building foundations, pipes, and high voltage conduits. The proposed project would not result in impacts ~o locally designated natural communities such as oak forest Or coastal habitat. - The incinerator abatement air scrubber would recycle trace amounts of metals removed from the air stream back to the plant headworks. Use of scrubber water treatment to precipitate, concentrate, and remove metals from the recycle water will result in no increase in metals in the wastewater discharged to the Bay and the adjacent Baylands Nature Preserve. This is a mitigation measure to prevent discharge of the metals to air or water. The wastewater discharged will still 28 IXX. EXPLANATIONS FOR CHECKLIST RESPONSES Vile VIII a VIII b . VIII c IX a meet permit requirements for metals. As a result, no impacts to wetland habitat are expected.i The proposed projec.t would be located on the existing PARWQCP site and would not result in impacts to wildlife dispersal or migTation corridors. .. . The proposed project would not conflict with adopted energy.c0nservation plans. Through ihe rehabilitation measures, the proposed project would result in greater fuel efficiericy (i.e., less fuel use per unit of sludge processed) compared to current efficiency. The proposed project would not use non-renewable resources in a wasteful and inefficient manner. The proposed project would not result in the loss of availability of a "known mineral resource that would be of future value to the region and to the residents of the State.. The thermal dryer may present a small risk of accidental explosion or"fire. However, the proposed project would be designed with safety.measures including proper dust handling systems to reduce explosion potential, and nitrogen padding of the storage hopper air space to reduce fire hazard. With these design measures, the potential impacts are expected to be less than significant. . - IX b The proposed project would not interfere with an emergency response plan or emergency evacuation plans. IX c IXd IXe Xa. Xb Xla XI b XI c Xld The proposed project will result in a 99.9% decrease in dioxin and furan emission~;, an average 54 percent decrease in metals air emissions, and an average 48 percent decrease in criteria pollutant emissions compared to current emissions from the incinerators, resulting in a project benefit. As a result;ithe project will result in no new impacts to health. ’ Neitherthe proposed project nor the pARWQCP create metals; any metals emissions result from metals in the plant influent. However, the metals,- primarily mercury, that would be removed by scrubber water treatment discussed in Vlld may need to be recycled or handled as a hazardous waste. Amounts that would be removed would be small and are estimated to be approximately 0.1 lb/year for the lightest metals and approximately 30 lb/year of the heaviest metals. Metals resulting from scrubber water treatment would be handled properly in accordance with all applicable and stringent local, state, and federal regulations that govern the use, storage, and disposal of such materials. As a result, no significant impacts are expected. The proposed project area does not contain flammable brush, grass, "or trees, and the proposed project would not increase fire hazard in areas with flammable brush, grass, or trees. The proposed project may result in short-term increases in existing noise levels associated with c.onstruction activities. However; the impacts ar.e ~xpected 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. The proposed project would not result in exposure of people to severe noise levels. The proposed project would not affect or result in a need for new or altered fire protection services. The proposed project would not affect or result in a need for new or altered police protection services. The proposed project would not affect or result in a need for new or altered schools. The proposed project consists of rehabilitation and modifications to a public facility (a 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 0r substantial alterations to power or natural gas ut.ilities. 29 IXX. EXPLANATIONS FOR CHECKLISTRESPONSES XII b The proposed project would not result in a need for new systems or ~upplies of or substantial alterations to communications systems. XII c The proposed project would not result in a need for new systems ~: supplies of or substantial alterations to local or regional water treatment or distribution facilities. XII d The Proposed project would not result in a need for new systems or supplies of or substantial alterations to sewer or septic tanks. . XII e The proposed project would not result in a need for new systems or supplies of or substantial alterations to storm water drainage. .. ¯XII f The proposed proje.ct would not result in a need for new systems or supplies of or.substantial alterations to solid waste XII g The proposed project would not result ina need for new systems or supplies of or substantial alterations to local or regional water supplies. XIII a The proposed project would not affect a scenic vista or scenic hig.hway. XIII b The proposed project would not have a demonstrable.negative aesthetic effect. The new facilities would be within the ~xisting plant boundaries and would not be visible to the general public. New structures would be attached or adjacent to existing structures, would match¯ existing exteriors, would be the same as or lower in height than the existing structures, and would.be sheltered from view by other existing structui’es in the plant and by trees that surround the plani. XIII c XIV a XIV b XIV c XIV d The proposed project would The proposed project would resources. The proposed project would The proposed project would The proposed project would values. not create light or glare. be located on the existing PAR.WQCP site and would not disturb paleontological " be located on the existing PAKWQCP site and would not disturb archaeological resources. be located on the existing PAKWQCP site and would not affect historical resources. not.have the potential to cause a physical change which would affect unique ethnic cultural XIV e The propo.sed project would not restrict existing religious or sacred uses within the. potential impact area. XV a The proposed project would not eliminate any existing parks or recreational facilities and would not induce growth in the region. As a result, the proposed project would not increase the demand for neighborhood or regional parks or other recreational facilities. XV b The proposed project would not affectexisting recreational opportunities. 30 Criteria pollutants Carbon monoxide ¯ Nitrous Oxides Sulfur oxides THC Particulate matter Volatile O~anic Carbons Hazardous Air Pollutants Dioxin Table 1: Current and Future Emissions,PARWQCP Incinerato~ Rehabilitation Pollutant Current Emissions ..(lb~day) 87.96 52.99 2.16 16.2 0..54 2.34 x 10-8 Furans 1.03 x 10"7 Metals Arsenic 4.51 x 10-3 Beryllium 4.33 x 10-6 Cadmium 1.53 x 10-2 Chromium 2.34 x 10-3 Copper 1.23 x 10-2 Manganese 9.01 x 10-3 Mercury 4.15 x 10-2 Nickel 2.34 x 10-3 Selenium 8.47 x 10-3 Zinc 6.49 x 10"1 " Emissions After Incinerator Rehabilitation (Ib/day) 22.64 37.07 1.55 1.45 12.95 0.53 2.17- x 10"11 9.50 x 10"11 3.48 x 10-3 3.98 x 10-6 5.37 x 10-4 3.52 x 10-4 4.05 x 10-2 2.96 x I0-4 3:69 x 10-4 AuthoriD’: Public Resources Code Sections 21083 and 21087. Reference: Public Resources Code Sections 21080(c). 21080.1.21080.3, 21082.1, 2 | 083, 21083.3, 2 i 093, 21094, 21151; Sundstrom v. County ofbfendocino, 202 Cal. App. 3d 296 (1988); l.~onoffv. Monterey Board of Supervisors, 222 Cal. App. 3d 1337 (1990) 31 ATgACtEV[ENT B ATTACtIMENTC 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 unlessvolume makes it necessary. However, there is a possibility that the addition of such a dryer could act as a pilot project for possible elimination of the incinerators in the future. This idea should be considered in deliberations over a long range plan. The repaired system and the existing treatment plant are expected to last less than twenty years. In the context of planning for major changes, that is not a long time. It is not necessary to wait twenty years to make changes; the establishment of long range environmental goals and the search for more effective ways to recycle the sludge should be an ongoing process. We encourage you to instruct the staff of the Regional Water Quality Control Plant to begin now to work on a long range plan for waste water management that will meet the needs of the area in an environmentally friendly way. We commend Phil Bobel and his s.tatf for the efforts they made to meetwith local citizens to try to address the concerns of those who are worried about the effects of incineration. Dioxin production is a major concern. The staff was able to show that so much dioxin comes into the plant in the waste water (from toilet paper, laundry water, human waste, etc.) that the proposed system will actually reduce the total dioxin level,. even though Some new dioxins will likely be produced in the incinerator. We hope this reduction will be true. The League of Women Voters of Palo Alto believes that the public-has the right to know the potentially harmful effects of materials they encounter in the home, the workplace and the community,- and so. encourages you to help educate them in ways to reduce toxins in waste water. We also encourage you to include citizens in the planning and decision-making processes of hazardous material management: Sincerely, Ruth Lacey Geri Stewart Co-Presidents, League of Women Voters of Palo Alto cc:Phil Bobel, Manager, Environmen~tal Compliance Division, PARWQCP Daisy Stark, Engineer, PARWQCP J " main telephone no, 6Yo.3az.z994 fs ~.zi/nile 650.321.1995 Schools Group 650:325~5980 Pa]o Alto City.Council City, Hall 250 Hamilton Ave. Palo Alto, CA 94301 Feb. 13, 1998 Dear CiN Council, PEOPLE.FOR THE EHVIEOHMEHT ATTACI]MENT D "71~ Colorado Avonua. Sulfa I " Palo Alto. California 94303-’3913 " ema[I baactioneigc.or~ . http’:/]www.b a a ctio n.or g On February 23, ~alo Altd City Council is scheduled to consider the "WQC!~. Solids Mar~agement P’roject." Bay Area Adtion and a number of other local environmental groups i6 eonjuction With City staff, hav~ been reviewing the proposed plan to, repair the, incinerators at the Palo Alto Regional Water Quality Control Plant¯ (RWQCP). According t6 reports prephred for the RWQC~, as w~ell as nume~:ous other sfipponing documents, there ar~ serious health and en~ir0nrnhntal eofi~"ems’nssoeiated frith dioxins .’-’ contained in both the influent and effluent of the plant that need the¯due consideration of the’Council before the~, make a deeisibn about this projec~t. ._~ r . . .- -According to "Dioxins Source Identification," a report written for tiae RWQCP in ~ept. 1997, dioxin~ 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 m~re in the burning pr.oeess. The city staff estimates that th.e incinerators release hal~as many-dioxins ihtothe environment as come into the plant frbm the abovementionedsoui-ces; however, there is a high level of uncertainty of how man’y dioxin.~ re-form after being released into thd air,whmh" may~skew~ th~s" approximation. Dioxins are also released from the in.einerators through the w.ater effluefit and through il~e ash.The water effluent pollutes the bay,’ and the ash is shipped to the Central Valleyand used in agriculture, thus dompleting the circle of c~ntaminating our food supply. ~ " " .~ " - Dioxins are a highly toxio by-prdduct created frbm the production and ncmeratmn of chlorine-containing products,’sucl~ as organochlorine pesticides, polyvinyl chloride’(PVC) plastics, and polychlorinated biphenyls (PCBs).’’* Dioxins are dangerous to,. humans and wildlife because they bioaecumulaie in fatty tissue. "In humans, dioxins have been shown to cause cancer, weaken the.immune system, and interfere with the entlocrine system, ~hich isresponsible for making hormones needed, to regulate bodily functions, including sexual de~,elopment and fertility.’’z We highly reeo~nmend that the¯council review.this document hs well as ¯ the."Dioxins Pollution Prevention Plan," which was prepared for the RWQCP in October 1997 before thd Feb.’23 Council ...... meeting. Both docurhents elhcidate the necessity to reduce the amount ofdioxins going to and coming fromthe RW(~CP. : ’ ¯ In addition to the sources of di~xins directly affecting the RWQCP,~9% of dioxins emitted locally come fr~r~ diesel-fu~le.d". motor vehicles, nnd another 15% from residential wood burning. Although the~e sources fall outsidd the scope of the-WQCt/ Solids Manage.meat Project, we request that the council take a edmprehehsive approach to addressing how to reduce the .~mount ofdioxins in our environment. Some suggested approaches are ~as ,follows:’. : Develop a dmxms reductmn pohcy fbr the City of Palo Alto, and rrquest neighboring cities t0do the same~ Build a solids thermal dryer to pilot test a non-dmxm creating alternativ~ to handling sewage sludge -¯ ¯¯ Explore alternatives to safely dispos~ of sludg~ or’ash which contain dioxins ¯ Educate other pt~bli~ agencies and the public abou’t’~dioxins ’ "arid provide information how to ~:educe them¯ Continue to m.onitor the influent arid effluent from the RWQCP for.dioxins Please give this serious issue your full consideration. Thank you,.-’ Susan Stansbury . ~ay Area,Action.- Executive Director i EIP Associates. 1997. Dioxins Sour, ce ldentificatio’n PALO ALTO. REGIONAL WATER QUALITY CONTROL PLANT SOLIDS FACILITY PLAN INFORMATIONAL PACKET UPDATED NOVEMBER 1997 . ~,.. ~CONTENTS~ " 1.BACKGROUND o d o PROJECT SCOPE LONG TERM PLAN for TI-IE RWQCP RELATIONSHIP of SOLmS FACILITY PLAN to LONG TERM PLAN SPECIFIC GOALS sugg6sted by ENVIRONMENTAL ADVOCACIES 6.RwQCP’s CURRENT GOALS 7.GOAL SETTING GENERAL TIME LINE The RWQCP provides treatment"for:the selvage from the cities of Palo Alto, Mountain View, Los Altos, East Palo Alto, the Town of Los Altos-Hills and Stanford University.. The RWQCP, which must process continuously all incoming sewage, operates two existing incinerators. Because incinerators occupy much less space than other sludge treatment technologies, the incineration technology was selected when the plant was built in order to preserve the wetlands. These incinerators are vital to the proper treatment of the sludge, which is the solid substance of the sewage. The two incinerators are showing signs of age after 26 years of operation. Inspection of the incinerators found localized areas of bulging in the incinerator steel shell, cracks in the shell, deterioration in the thickness of the shell, and flattening of the hearth of the incinerator. The hearth is the internal structure in which incineration actually takes place. As the hearth flattens, the design forces holding it together are reduced and the hearth could ultimately collapse. The sludge before incineration is classified as raw sludge and is not suitable for disposal in landfills. The incinerators are the RWQCP’s only means to treat and prepare.the sludge for proper disposal. The Solids Facility Plan was prepared to assist the RWQCP in providing reliable, safe, cost effective, and environmentally sensitive treatment and management of the sludge. The Solids Facility Plan was completed in May 1997 and identified a project to rehabilitate the two existing incinerators at the RWQCP.The incinerators need immediate rehabilitation to allow safe and reliable operation. The project to rehabilitate the two existing incinerators will include the following: Repair the incinerators Improve the emissions of the incinerators Improve the efficiency of the incinerators The project does not increase the RWQCP sewage treatment capacity, and will not increase the RWQCP currently permitted total sewage sludge incineration capacity. In the next ten to fifteen years, a heat dryer may be needed to pretreat the sludge prior to incineration, and is therefore part of this project. The project will allow the RWQCP to provide reliable and safe treatment for the sludge, while reducing the emissions. The ~"S.: Environmental Protection Agency ~PA) is proposing new standards (the "California Toxics Rule") for San Francisco Bay south of the Dumbarton Bridge (the South Bay). The discharge standards for the RWQCP may, change pending on the development of the T0xics Rule. The RWQCP and 0ther. stakeholders have proactively formed the Santa Clara Basin Watershed Management Initiative to prepare a plan to manage beneficial uses of the South Bay for drainage and freated water discharge. Part of the p!an is to determine acceptable pollutant ioadings to the South Bay from the RWQCP and other plants. Information from the watershed management initiative wil! provide feedback to EPA to help in th~ Toxir~ Rule making. ~It is anticipated that EPA will take many months or even a year or more to finalize the Toxics Rule. The RWQCP expects to begin planning for the next generati0:n wa.ste.w.: ater and solids management system in the next 3 to 5 years~ The ftrst step of the RWQCP’s planning is to establish long term goals. As part of this goal setting process, the City will be identifying long term objectives -- socioeconomic, health and safety, regulatory, and environmental. From these objectives can flow an examination of alternatives and selections of programs and facilities. Future alternatives will encompass both programmatic and engineering concepts in source control, reuse, secondary treatment modification, post secondary treatment, and solids management. 4 The RWQCP, conswacted in 1969, is planned to operate through the year 2020. At that. time the existing facility is expected to be retired and a new wastewater treatmefit system put in. operation. The City envisions that the wastewater system .of the future midst respond to the environmental and socioeconomic concerns in Palo Alto, the plant’s servi~e area, ~dthe Bay Area. In effect, the system will become increasingly cbnsistentv~ith the concept of sustainability in the future. In order to adequately plan and design our future system, we n~ed to develop a process that will review and set the policies and missions for theRWQCP. The process will include goal setting, research, buy-ins, institutional and regulatory arrangements, and policy setting tllat will lead to the fmai planning and design. During :the course¯ of this long range plan, various components within the plant will need major rehabilit~(ion or modifications as the plant continues to age. The Solids Facility Plan forms a bridge toward the long range plan. Major changes in plant design are not being made until the long range plan can be completed. Environmemal advocacy organizations have suggested a number of specific goals for the RWQCP: ¯Eliminate indineration ¯Eliminate use of chlorine ¯Use of bio-~olids for beneficial uses within the plant’s service area ¯Expand pollution prevention programs to reduce introduction of pollutants into the wastewater Maximize composting of kitchen waste Maximize composting of toilet waste : Maximize reuse of treated wastewater from the RWQCP These and other range plan. 9ossible goals will be evaluated as part of the development of the long 6 The staff at the RWQCP is dedicated to protecting the environment. In past years, we have successfully established partnership with the communities and businesses we serve to clean up the South Bay while balancing our budget. We will continue our efforts as environmental steward to seek the means to achieve the goals of the RWQCP. Our current goals include: ¯Reduce water, materials, and energy usage ¯Reduce quantities of wastewater incoming to the plant ¯Prevent pollution by reducing toxic compounds in the incoming wastewater ¯Reduce use of chemicals in wastewater treatment or solids handling ¯Reduce pollutant emission ¯Increase beneficial reuse options for byproducts, including wastewater and solids ¯Support local reuse ofbio-solids, treated water, and grey water ¯.Provide cost-effective treatment 7 The goals for the RWQCP must be presented to Council..for rev.iew and approval. Goal setting needs to be accomplished so that the appropriate alternatives are adequately researched. The alternatives selected for the RWQCP should be tested and evaluated for technical soundness, environmental safety, and economic feasibility. A process-needs.to be in place to ensure that: the interest and health of the corfirnunities and the environment are addressed ~. ¯sufficient time is allowed for each phase of planning all sectors of the communities are represented Proper planning for an environmen~lly, technically, and socioeconomically sound future is a time consuming process. During,the long term planning process, there willbe interim projects that must occur within the RWQCP to maintain the sewage treatment services to ¯ the communities. Long term goals need to be established for the RWQCP so that the interim projects are consistent with the future plant design. 8 RWQCP LONG TERM PLAN Note: This preliminary time line is intended to show the relationship~ and the scales of events only, it is not an official time line. SOLIDS FACILITY P~J~N PLANNING DESIGN CONSTRUCTION DISCHARGE STANDARDS. : RWQCP PERMIT RENEWAL ¯WATERSHED MANAGEMENT INITIATIVE CALIFORNIA TOXICS RULE LONG TERM PLAN ADOPT A PROCESS = GOAL SETI’ING RESEARCH AND TESTING DEVELOP PLAN INSTITUTIONAL & REGULATORY DEVELOP’T ENVIRONMENTAL REVIEW I ! ! i Printed: 11/12/97 Page 8 Milestone A Fixed Delay Summary Slack ATTACHMENT D City of Palo Alto City Manager’s Report TO:HONORABLE CITY COUNCIL ATTN:POLICY AND SERVICES COMMITTEE FROM:CITY MANAGER DEPARTMENT: PUBLIC WORKS DATE: SUBJECT: FEBRUARY 8, 2000 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 .Mto Regional Water Quality Control Plant (RWQCP). BACKGROUND In February 1998, Council directed staff to establish a processfor develo ing the long term goals for the RWQCP, CMR: 141:98. The long term goals wi~be used by the RWQCP to guide the long 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~ i969,: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 wi!l become consistent with the concept of sustainability in ttie future. The RWQCP is starting to plan for its future system. The first step of the RWQCP’s planning effort is to develop !ong term goals. The scope of the consultant services includes: -CMR:440:99 Page 1 of 2 ¯ Identify regulatorY requirements and uncertainties Assist the City in public meet’.mgs and workshops, and document issues and concerns (e.g. chlorine, incineration, etc,) Evaluate, develop, and assist the City to prioritize goals Assist the City to obtain supports ~om.stakeholders Prepare a "Goals Report". RESOURCE 17VIPACT Funding for this project is included in the RWQCp FY I999-FY2000 operating funds. POLICY IMPLICATIONS The recommendations of this. staff report are consistent with City policies. may lead to the development of new.policies for the City. The study TIMELINE .It is anticipated that the study will take one year to complete in order to accommodate public inputs and inter-department participation. ATTAC]~vI~NTS Attachment A: ,Drat~ Request for Proposal Attachment B: CMR:141:98 .. PREPARED BY: Bill Miks, Manager RWQCP Phil Bobel, Manager ECD DEPARTMENT HEAD GLENN S. ROBERTS Director of Public Works CITY MANAGER APPROVAL: HARRISON Assistant City Manager C!vIR:440:99 Page 2 of 2 ATTACHMENT A PALO ALTO A STUDY to develop THE LONG TERM GOALS for the, 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 RVCQCP service area. This Request for Proposal (R_FP) 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 pla .nned to operate under its current design through the year 2020. At that time the existing t~eatment system will be updated or replaced..The RWQCP envisions that the wastewater sy,stem 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 goal~ 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. EXISTING TREATMENT SYSTEM The RWQCP is a tertiary treatment facility with an average dry weather flow (ADWF) design capacity of 38 million gallons per day (mgd). The current ADWF is about 25 mgd. The attached schematic depicts the plant’s processes. The main treatment process consists of bar screens, primary sedimentation, fixed film reactors, activated sludge, secondary sedimentation, and filtration. The filtered effluent is chlorinated, and then dechlorinated with sulfur dioxide prior to discharge to the Bay. A portion of the treated final effluent is diverted to the reclamation facility for reuse. Additional information about the RWQCP can be found on the web site www.PARWQCP.org. CONSULTANT SERVICES APPROACH The long range goals will need to address a broad range of issues, gain the support from stakeholders with opposing viewpoints, and withstand the test of time and uncertainties. The goals need to be comprehensive in order to guide the long range plan..The goal development process shall take a participatory and collaborative approach, involving, all stakeholders and identifying their concerns. The tools used to prioritize the issues-shall be simplistic, user friendly, and graphic in nature. The final decision analysis shall provide a balanced picture that has gone through the reality check against sound technologies to integrate the environmental values, socioeconomic values, and evolving regulations:...< " CONSULTANT RESPONSIBILITIES The Consultant’s scope of work shall include, but not be limited to, the following: Task 1: Establish the Process The process shall provide leadership, establish authority and roles, and obtain commitments. Consultant shall assist the City to identify the stakeholders and adopt a process that encourages inputs in an open forum. A "Goals Report" shall be developed which shall document and adhere to the adopted process. Task 2: Document Regulatory Requirements and Identify Elements of.Uncertainties. Consultant shall research, illuminate, and document al! appropriate current regulations, and potential future regulations. Consultant shall discuss the trend and the uncertainties of those regulations that are changing or likely to change. Discussion shall include the 2 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- is sues ". 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 tha "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 shal! 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 Manager. Meetings and workshops will most likely be held in the evenings to accommodate the public and/or council and the city commissions. Sufficient funds shall be included in the Consultant’s proposal, for inclusion in the contract if awarded, for the Consultant’s team to attend and participate in four meetings and four workshops. ADDITIONAL SERVICES Consultant may be required to perform additional services listed below. Additional ~ervices shall be performed only upon written authorization by the City. Payment for the additional services shall be time and expense based on the schedule of charges but not to exceed a negotiated maximum. The maximum limit for each additional task shall be negotiated and agreed -upon prior to providing the service. Consultant shall provide a schedule of charges with the fee information.-Additional services may include: Prepare environmental studies Attend/conduct additional meetings or workshops SUBSEQUENT. CONSULTANT SERVICES Upon completion of the study, the city will review .the time schedule and the tasks for the .development of the long range plan,./and may determine to proceed with the preparation of the .long range plan. City may issue a reques~.~for proposal for the subsequent consultant services, or request the Consultant to perform the subsequent services. The detailed Consultant services for the long range plan will be established at such time. In general, Consultant services for the long range plan may include the following tasks: Develop alternatives encompassing both programanatic and.engineering concepts in source control, reuse, treatment, and solids management Perform environmental and economic studies Organize and conduct pilot tests PROJECT SCHEDULE The schedule of the study shall be staged to accommodate the public and is anticipated to- be a relatively long process.. The City envisions the study to take as long as one year to complete. The Consultant shall establish a detailed schedule showing the critical path and time line for each task. The Consultant shal! update and maintain the schedule throughout the project. PAYMENT 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: 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. o Qualifications of the project manager and team. Ability to organize and present material. Good understanding of the objectives as evidenced by the completeness and clarity of the proposal,, and the inclusion of specifics and details that are essential for proposal evaluation. The team’s approach to the project. *** END *** ATTACHMENT B City of Palo Alto City Manager’s Report TO:HONORABLE CITY COUNCIL FROM:CITY MANAGER DEPARTMENT: PUBLIC WORKS DATE:FEBRUARY 23, 1998 CMR:141:98 SUBJECT:ADOPTION OF THE NEGATIVE DECLARATION - REGIONAL WATER QUALITY CONTROL PLANT, AND APPROVAL OF THE SOLIDS. FACILITY PLAN’S RECOMMENDATION TO REHABILITATE THE INCINERATORS REPORT IN BRIEF The Solids Facility Plan evaluates options and recommends a plan to manage the solid residue at the Regional Water.Quality Control Plant (RWQCP). The RWQCP currently uses two incinerators to bum and reduce the sludge to a manageable amount of ash product for beneficial reuse. After 26 years of continuous operation, the incinerators have deteriorated significantly prompting the preparation 0f 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, Staffwas 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 RECOMMENDATIONS Staff recommends that Council: Approve the recommendations of the Solids Facility Plan to rehabilitate the sewage -sludge incinerators at the RWQCP immediately, and add a thermal dryer when peak loading capacity is required, or if pilot testing of a sludge dryer is desired. Adopt the negative, declaration for the recommended project to rehabilitate the incinerators at the RWQCP immediately, and add a thermal dryer, if needed. o Direct staff to forward the amendments to the Partners’ Agreements to Parmer agencies for approval. Direct staff to develop policies for reducing environmental releases of mercury, dioxins, polychlorinated biphenols. Direct staff to establish a process for developing long term goals for the RWQCP, and then return to Council for approval of the process. BACKGROUND The RWQCP is required to continuously process all incoming sewage. It currently operates two incinerators to treat the solid residue (sludge) of the sewage. The sludge is burned and reduced to a manageable amount of ash suitable for beneficial reuse. The sludge, before burning, is unsuitable for disposal in landfills. The incinerators are the RWQCP’s only means to treat and prepare the sludge for proper disposal. The reliability and redundancy of these incinerators are extremely important to the RWQCP. Concerns with the incinerators were discussed in earlier staffreports, (CMR:278:96 and CMR:236:97), and are summarized below. The first concern is reliability: The incinerators were constructed in 1971 and have become more and more difficult to keep in operating condition. Large cracks have developed in the half-inch steel shell, and the chances of both incinerators being down at the same time have increased to a point of very serious concern. Given the 24-hour per day, 365 day per year nature of the operation, inability to operate the incinerators would present immediate emergency conditions and,- within 24 hours, human health concerns. The second concern is redundancy: The wastewater flow going into the RWQCP varies daily and seasonally. While the two existing incinerators are permitted to operate concurrently to meet varying flow requirements, this operating mode does not allow for emergencies or repairs.. Currently, one of the incinerators is so frequently under repair that a back-up almost never exists. The RWQCP is required to provide reliable, uninterrupted service. CMR:141:98 Page 2 of 8 The third concern is pollutant releases: The RWQCP incinerators are in compliance with current regulations. However, the existing emission control devices on the incinerators are outdated and therefore, maximum reduction of pollutants cannot be achieved. The solids treatment and disposal options are currently heavily regulated, and future regulations are uncertain. The issues associated with the pollutant releases to air, land, and watdr 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 of technologies for handling the sludge, and reduced down the number of feasible options. The recommendation of the feasibility study formed the basis of the second study, the Plan. Two technologies are considered feasible options besides incineration: sludge digestion and sludge drying. Sludge digestion is the anaerobic breakdown of sludge in large holding tanks over long periods. The end product is digested sludge, commonly called bi0solids. Sludge drying uses low heat to evaporate the water out of the sludge without burning the organics. The residue from the dryer is in the form of pellets. The residue from both processes are typically used on agricultural land as soi! 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 i’esidue. Recent studies demonstrate that another advantage of incineration is that pathogens, and most organic pollutants in the sludge such as polychlorinated biphenols (PCBs) and organochlorine pesticides (e.g. DDT), are destroyed. in the incinerators. Thus, when the ash from the incinerators is applied to land, it contains less pollutants than the residue from digestion or drying. It is difficult to compare the environmental effects of the three options. Staff was unable to conclude that one technology is "better" for the environment than another. All options have certain negative environmental impacts. Each releases, different pollutants to different media - air, land or water. Incineration produces air pollutants, consumes energy, and does not preserve the organic material for sludge reuse. Digestion does not destroy organic pollutants, or dioxin. Dryers consume even more energy and apparently have never been tested for dioxin air emissions. The inability to draw conclusions is also due to the difficulty of comparing different types of environmental releases. The pathways for the final impact CMR:I41:98 Page 3 of 8 resulting from initial pollutant releases are numerous and difficult to trace. All three options can meet all current environmental, health and safety requirements Therefore, staff focussed on the following criteria in comparing the options: Cost Land use Visual impact Potential odor The table below is the comparison of the three options: Options Incinerator Rehab. Plus Dryer Digesters Dryers I! TotalCost. i[ $11.4 million $29.7 milIion $17.2 million Footprint 800 sf> existing 45,000 sf > existing 1500 sf> existing Visual iImpact Low High Low Odor Low High Medium .The incinerator rehabilitation, plus dryer option, will meet the current and the known future regulations; it is the lowest cost, has the smallest footprint, least visual impact, and least odor. Staff, therefore, recommends the project to rehabilitate the incinerators immediately, and to add the dryer if needed. The project will include three major elements: 1.Repair the existing incinerators to ensure safe and reliable operation. Relocate the emission control device to outside of the incinerator to allow full utilization of the entire incinerator for combustion. The improved efficiency will enable a single incinerator to take care of the varying flow most of the time, leaving one incinerator as a reliable standby. A dryer may be installed, if the City decides to pilot test the dryer, or when it is needed to help treat the solids. o Replace the existing emission control devices with new state-of-the-art devices to improve the emission. The Parmers’ staff support City staff’s recommendation and have agreed to participate in a joint financial plan entailing debt financing. City staff is presently working with the Partners on the amendment to finance the project. Palo Alto would issue the debt, and Partner agencies would pay Palo Alto in accordance with the amendment to the Partners’ CMR: 141:98 Page 4 of l; agreements, which is consistent with past capital financing. The draft amendment was prepared jointlyby Palo Alto’s City Attorney’s office and outside counsel at Jones, Hall, Hill & White. It incorporates comments from the City’s financial advisor, Stone & Youngberg. The amendment will be presented to the Council in March 1998. Many environmental advocacy groups (EAGs) raised the concern that a non-incineration option may be better for the environment (CMR:356:97). In response to their concerns, additional data was collected and a Response Study was prepared. Many of the EAGs made the point that, if the sludge were made substantially.cleaner by keeping pollutants out of the wastewater, non-incineration technologies (principally sludge digestion or sludge drying) would be better for the environment. The non-incineration option uses less energy, produces less air emission, and would allow reuse of the organic matter as a soil supplement without the current negative side-effect of putting pollutants on the soil as well, if the wastewater is "cleaner." While .this logic is sound, it depends upon making the sludge cleaner through source control. Staff investigated the potential for source control of key pollutants (dioxins, mercury, organochlorine pesticides, polychlorinated biphenols - PCB ) and found that there was no reason to assume that major reductions would occur quickly. Action items for implementation by Palo Alto were developed, but it is not anticipated that those reductions will be greater than approximately 20 percent. Thus, non-incineration options will continue to have the draw-back of placing the pollutants on the soil. For this and other reasons described in the Response Study, staff’s recommendation has not been changed. Given currently available data, the current pollutant levels in sludge, and the current ability to evaluate impact on the environment, staff believes this recommendation to be the appropriate one. However, it is not at all certain that incineration should be the long term technology of choice for the RWQCP. Air emissions, high energy use, and failure to reuse organic matter are features of incineration that raise significant concerns about its long term use. Therefore, staffis also recommending the development of long term goals to guide future design work at the RWQCP. Staff is also recommending the development of specific policies to achieve reductions of releases of mercury, dioxins, and organochlorine pesticides to the environment. These policies will also assist staff in the long term planning that must be accomplished for the RWQCP. ALTERNATIVES TO STAFF RECOMMENDATION If Council does not adopt the Negative Declaration and approve the recommendations, the RWQCP would continue to attempt to keep the incinerators in operation. Downtime, repair costs, and safety issues would continue to escalate. Should an incinerator fail, the RWQCP is required by law to repair the incinerator immediately. At that time, the cost of the repair would almost certainly be higher than the planned repair, and any work to improve the air emissions would most likely not be implemented because of the urgency of the situation. CMR:141:98 Page 5 of 8 With respect to the alternatives to incineration, both digestion and drying options would have a significant affect on the environment, odor control, and visual impact. Without full environmental review by the public, these options cannot be considered, as an alternate project. Therefore; staff would be required to restart data gathering, conceptual design and em)ironmental review. It would be several years before staff could return to Council with an alternative digestion or drying option. RESOURCE IMPACT The capital project is estimated to cost approximately $6.2 million for the rehabilitation of the incinerators, and $5.2 million for the dryer (in 1998 dollars). The attached cash flow anaiysis (Attachment B) shows the Parmers’ share of a twenty-year bond funding for the project. If the rehabilitation is constructed in 1999 it is estimated that the sewer rate impact to the Palo Alto rate payers will be an increase of less than three percent. POLICY IMPLICATIONS The recommended project is consistent with City policies. The recommendation to establish a process for determining long term goals will lead to the adoption of new policies. TIMELINE If approved, the.rehabilitation of the incinerators will proceed immediately at the following schedule: Final design starts Permitting Debt financing Bid Construction starts Bond Sale May 1998 February 1999 May 1999 May 1999 August 1999 Fall 1999 ENVIRONMENTAL REVIEW An environmental check list was prepared for the recommended project (Project). Compared to the existing incinerators, the check list showed that the Project has no major increase in impact. The Project will result in better emissions compared to the existing facility. There will be some temporary impact due to construction activities that will be mitigated. A Negative Declaration (N.D.) has, therefore, been prepared for the Project. The N.D. (Attachment A) was distributed and notice was given to the public for review and comments. The review period started on January 16, 1998 and ended on February 14, 1998. Staff received some questions related to the details of the design and repair. A pre-design was performed on the Project prior to the preparation of the N.D. Final design will be CMR: 141:98 Page 6 of 8 performed upon Council approval of the Project. The final design will include all the details for the repair and the construction. A letter was received from the League of Women Voters of Palo Alto. The letter stated that the incineratorrehabilitation 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 thefollowing five suggestions: 1.Develop dioxin reduction policy for the City of Palo Alto, and request neighboring cities to do the same. 2.Build a solids thermal dryer to pilot test a non-dioxin creating alternative to handling sewage sludge. 3. Explore alternatives to safely dispose of sludge or ash which contains dioxins. 4.Educate other public agencies and the public about dioxins and provide information on how to reduce them. 5. Continue to monitor the influent and effluent from the RWQCP for dioxins. Staff believes that these suggestions can be addressed in the. long-term goals and policy development process described in staff recommendations 4 and 5. ATTACHMENTS A - Initial Study/Negative Declaration B - 20 year cash flow analysis C - Letter from the League of Women Voters of Palo Alto D - Letter from Bay Area Action E - November informational booklet Response Study - A copy is available for review at the Public Works Engineering, 6th floor counter PREPARED BY: Bill Miks, Manager Regional Water Quality Control Plant Phil Bobel, Manager Environmental Compliance Division CMR: 141:98 Page 7 of 8 REVIEWED BY: GLENN S. ROBERTS Director of Public Works CITY MANAGER APPROVAL:__ FLEMING ~.,6. ity Manager CMR:141:98 Page 8 of 8 ATTACHMENT Initial Study!Negative Declaration (IS/ND) Palo Alto Regional Water Quality Control Plant Solids Facility Plan City of Palo Alto Project Title: Palo Alto Regional Water Quality Control Plant (PARWQCP) Solids Facility Plan Lead Agency Name and Address:City of Palo Alto Public Works Department Regional Water.Quality Control Plant 2501 Embarcadero Way Palo Alto; California 94303 Contact Person and Phone Number: Daisy Stark, PARWQCP Engineer, 650-329-2598 Project Location: 2501 Embarcadero Way, Palo Alto, California Application Number(s): Not Applicable Project Sponsor’s Name and Address: City of Palo Alto, PuNic Works Department, Regional Water Quality Control Plant, 2501 Embarcadero Way, Palo Alto, California, 943O3 7.General Plan Designation: Major Institution/Special Facilities ¯ 8.Zoning: Public Facilities with Site Design overlay (PF(D)) 9.Desc.ription of Project: PARWQCP Background The Palo Alto Regional Water Quality Control Plant (PARWQCP) provides advanced wastewater treatment for Palo Alto, Mountain View, Los Altos, Stanford University, Los Altos Hills, and much of East Palo Alto (Figure 1). The Project is located at the PARWQCP in the City of Palo Alto at the east end of Embarcadero Way, east of Highway 101 (Figure 2). The PARWQCP separates the solid substances from the incoming wastewater (influent) EAST PALO ALTOSANITARY DIST. To San Francisco WATER QUAL/TY CONTROL PLANT San Francisco Bay Not To Scale PALO To San Jose PALO ALTO Figure 1 Service Area Palo Alto Regional Water Quality Control Plant (see Figure 3). The liquid and solid portions are then treated. The treated wastewater is discharged via an 0Uffall to the San Francisco Bay. The solid substance removed from the wastewater is called sewage sludge an~t is treated in the solids facility of the PARWQCP. The solids facility includes gravity thickeners and belt presses which remove more of the 9cater from the sludge, two existing incinerators which bum the sludge to an ash product, and an ash storage silo and bagging system. The ash product is trucked to the Central Valley and applied to agricultural lands as a soil amendment. Figure 3 Simplified PARWQCP Schemagc PARWOCP Wastewater Wastewater Treatment Processes . Solids Incineration Treated San Francisco Wastewater ~Bay . . Ash . A more detailed discussion of the incineration process and the need for the Project is provided in the following sections of this IS/ND. 4 The Incineration Process and the Need for Project The Incineration Process Figure 4 shows the location of the incineration building at the PARWQCP-. The incLueration process, depicted graphically in Figure 5, consists of two multiple-hearth incinerators, each with two air pollution control devices .to minimize emissions into the atmosphere. The two incinerators each consist of six hearths (separate chambers) in a vertical column where natural gas can be used in varying amounts to ignite the residual solids. Currently, the top hearth in each incinerator is used as an afterburner to bum organic molecules in the stack gas and prevent their release into the environment. In addition, each incinerator has a wet scrubber that removes pollutants from the incinerator stack gases. Need for the Proiect The PARWQCP incinerators, which have been in service since 1971, have become more and more difficult to maintain in recent years and require frequent, costly repairs. Equipment downtime has increased dramatically .because of the frequent repairs. The chance of both " incinerators being out of service at the same time has increased to the point, of causing concerns about safe operations of the plant. The wastewater treatment plant must be able to continuously process all incoming sewage. Given the 24-hour-per-day, 365-day-per-year nature of the operation, the inability to operate the incinerators would present immediate emergency conditions and, within 24 hours, human health concerns. Project Goals The proposed Project the following goals: involves improvements to the solids facility., and is designed to meet 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 Cu~ent Incinerator Residual Solids ~ / Incinerator f Atmosphere Air Scrubber StaciGas Afterburner Cooling Hearth Residual Solids Air Scrubber Afterburner. Cooling Hearth Burning Hearths Incinerator The first goal of the proposed Project is to make repairs to the two incinerators that will eliminate the frequent and costly short-term repairs, great.ly 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 flow requirements, this operating mode does not allow for emergencies or repairs. Currently, one of the incinerators is under such frequent .repair that a back-up incinerator almost never exists and urgent conditions are the norm. To relieve these urgent conditions, two Project components are proposed. The first component, a.true (separate) afterburner, will be constructed to allow the top hearth tO be used to burn the solids. This will increase the throughput (the amount of solids that can be handled by one incinerator) and will .also reduce the need to run both incinerators simultaneously. The second component, a solids thermal .dryer, will be added if the City decides to pilot test the dryer or when it is needed to help treat the solids from anticipated population growth in the PARWQCP service area. The dryer will further reduce the water ¯ content of some of the solids before feeding the solids to the incinerators. The drier solids are much easier for the incinerator to handle and further decrease the likelihood that both incinerators would have to be operated simultaneously. The third goal of the proposed Project is to uparade the solids facility’s air pollution control equipment. This goal will be met with two Project components for each incinerator. First, the new afterburners, which will help to meet the second goal, will be more efficient than the current afterburner and will operate at a higher temperature to completely oxidize the organics in the stack gas. Second, new two-stage wet scrubbers will be installed that capture substantially more gases and particulate matter than the current scrubbers. Figure 6 shows the improvedincineration system upon completion of the Project. Impact of the Proposed Proiect on PARWQCP Treatment Capacity. The proposed project will not increase the PARWQCP’s treatment capacity. The incineration system is a component of the PARWQCP, and a modification to the incineration system would only cause an increase in the PARWQCP capacity if it were currently the only limiting component of the plant. The average dry weather flow to the PARWQCP in 1996 was 24 million gallons per day (MGD) from the PARWQCP’s service area of approximate 220,000 Figure 6 Proposed Incinera#on System Residual Soli Incinerator 2-Stage Scrubber [Afterburner [ Stack Gas Cooling Hearth Atmosphere 2-StageScmbber [ Afterburner Stack Gas Residual Sohds Cooling Hearth S Ash Farmland Burning Hearths Incinerator people. The wastewater treatment processes (as distin~mxished 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 serve 220,000 people. The proposed Project will increase the peak capacity of one incinerator to 32 DT/D. While it could be arg’ued that the capacity of incinerator system would then be 64 DT/’D (32 X 2 incinerators), this is not the case for two reasons. First, only one incinerator would be operated at a time. The purpose of the project components is to insure a back-up incinerator is ready at all times. Second, the Bay Area.Air Quality. Management District (BAAQMD)Permit to Operate for the PARWQCP limits maximum throughput to 60 DT/D. No modification to that permit is being sought. Therefore, the incinerator system capacity would remain at 60 DT/D. This system could serve a population as great as approximately 410,000. The incinerator capacity can supporta larger additional population than the available capacity in the wastewater treatment processes. The incineration system could serve a population as great as approximately 410,000, while the wastewater treatment process could only serve a population of approximately 350,000 (see Table 1). Therefore, it is the wastewater treatment Table 1 Current Throughput and Maximum Capa~ty Wastewater Treatment Processes Incineration System 1996 VALUES Throughput Average 24 MGD 17 DTD Population 220,000 220,000 CURRENT MAXIMUM CAPACITY Throughp~ CapaciW 38 MGD* 60 DTD** Approximate Population Equivalency 350,000 410,000 ’*Average "60 DTD = Maximum Peak Daily Capacity. Average capacity associated with this peak capacity used to determine Population Equivalency 10 processes, not the incineration system, that limit the PARWQCP’s capacity. The proposed Project does not increase the capacity of the PARWQCP. A major capital improvement project for the wastewater treatment processes and regulatory agency approval would both be required to increase the capacity of the wastewater.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 Existin~ 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 combus.tion. 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 Modification of Incineration System The modification will increase the efficiency of the existing incinerators and improve air emissions..It will consist of the following: Construction of a new structure (possible location shown on Fig~tre 4) immediately adjacent to the existing building to house the new air pollution control equipment, including an external afterburner, Venmri-Pak scrubber, and exhaust ducting. The new structure will be an 800 square foot addition to the existing 5,300 square foot incinerator building. It will be about the same height as the existing building (46 feet), and will be sheltered from the street and the public by other treatment plant structures and trees surrOunding the plant. The new air pollution control equipment .will provide significant reductions in emissions compared to current emissions. Operational changes to use the top hearth as a burning hearth. Installation of an equalization storage tank. The quantity of dewatered sludge to be incinerated will vary hourly. The ability to temporarily store, or equalize, these variations will enhance operating results, p.articularly at peak conditions. A new equalization storage tank will be constructed adjacent to the south side of the incinerator building as shown on Figure 4. It will consist of a steel storage tank with a closed top and mixers. It will be 25 feet in diameter and 30 feet tall, providing 100,000 gallons of storage. It will be sized for the projected average annual day’s sludge production of 18.5 DT/D. The tank will be vented to the incinerator inlet combustion air to make use of the incinerators’ new air pollution control equipment. The height of the .tank is lower than the existing incinerator building and the surrounding structures. It will not be visible from the street or by the public. Addition of a Thermal Dryer A small thermal dryer unit would be added if the City decides to pilot test the dryer or when a single incinerator is unable to meet peak loads during the project life (through 2020). The purpose of the thermal dryer is to increase the dryness of sludge beyond that which can be 12 achieved with the existing 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. Therma! 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 fn’e hazard. Second, nitrogen padding of the storage hopper air space canalso be implemented as a means to reduce the fire hazard. The proposed thermal dryer uses indirect drying, in which fuel is combusted in a boiler to produce steam or in a thermal oil heater to heat oil. The steam or heated oil is passed through an indirect dryer, where hollow metal disks or paddles are heated from the inside and conduct heat to the solids on the outside of the paddles. The thermal drying facility can be located inside or outside the existing sludge incinerator building. A site just north of and adjacent to the existing incinerator building, as shown in Figure 4, has been identified for an outside location. Conveyors will be installed to transport 13 the dewatered solids to the thermal drying system from the belt presses and to return the dried solids to the incinerator. Also, for odor control, the foul air created during the thermal drying process will be discharged to the incinerator inlet air stream as part of the inlet combustion air. This air eventually flows to the incinerator air emissions control system and helps in. fuel savings in incinerator operations since it is heated. The dryer unit includes abatement equipment for the boiler, which bums natural gas to heat the dryer. If the outdoor location is selected, the facility will be lower in height than the existing incinerator building and other surrounding structures. It will be sheltered from the street and the public by other treatment plant structures and trees surrounding the plant. California Environmental Quality Act (CEQA) Requirements The California Environmental Quality Act (CEQA) requires that potential significant environmental effects of a project proposed .by a public agency be identified and disclosed to the public. A significant effect on the environment is generally defined as a substanu or potentially substantial adverse ch,.an.~ ge in the physical environment." "Environment" means the physical conditions, including both natural and man-made conditions, that exist within the area affected by a proposed project. The environmental assessment for the proposed project has identified no significant environmental effects. A Negative Declaration must include a written statement briefly explaining why a proposed project will not have a significant environmental effect when compared to the existing environment. It must include a description of the project and location, identification of the project proponent, and proposed finding of no significant effect. It must also include a copy of the Initial Study checklist that justifies the finding of no significant effect. This Negative Declaration contains all of the required information. I4 11.Other agencies whose approval is required (e.g., permits, financing approval, or participation agreement.) State/Regional Agencies Bay Area Air Quality Management District San Francisco Bay Regional Water Quality Control Board City of Palo Alto City of Palo Alto Public Works Department City of Palo Alto Department of Planning and Community Development City of Palo Alto Architectural Review Board City of Palo Alto Fire Department Other Local Agencies City .of Mountain View City of Los Altos East Palo Alto Sanitary District Town of Los Altos Hills Authority to Construct (A/C) and Permit to Operate(P/O) - if grandfather status is not maintained, then will be needed (existing facility attained grandfather status because it was constructed before 1972, and will retain this status as long as it is not modified in a manner that results in an air emission increase of a regulated pollutant or the repair costs are not greater than 50% of the capital cost of a new incinerator) clean Water Act: 40 CFR Part 503 Rules--proposed revisions to CWA Part 503 will be incorporated into the existing NPDES Permit; will require Continuous Emissions Monitoring for CO and NOx along with existing requirements for Total Hydrocarbons by 2000 Grading and Drainage Review Building Use Permit Site and Design Review Architectural Review Hazardous Materials Disclosure Checklist/Inspection Approval and Funding Approval and Funding Approval and Funding Approval and Funding 15 Environmental Factors Potentially Affected: The environmental factors checked below would be potentially affected by this project as indicated by the checklist on the following pages. []Land Use and Planning []Population and Housing []Geologic Problems []Water []Air Quality []Transportation!Circulation []Biological Resources []Energy and Mineral Kesources []Hazards []Noise [] Mandatory Findings of Significance []Public Services []Utilities and Service Systems []Aesthetics []Cultural Kesources []Recreation 16 Determination: On the basis of this initial evaluation: I fred that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared. I find that although the proposed project could have a significant effect on the envkonment, 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 DECL/LRATION will be prepared. I fred that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required. I find that the proposed project MAY have a significant effect(s) on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets, if the effect is a "potentially significant impact", or "potentially significant unless mitigated." An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.. Project Planner Director of Planning & Community Environment Date Date 17 Evaluation of Environmental Impacts: 1)A brief explanation is required for all answers except "No Impact" answers that are adequately supported by the information sources a lead agency cities in the parentheses following each question. A "No Impact" answer is adequately, supported if the referenced information sources show that.the impact simply does not apply to projects like the one involved (e.g. the project falls outside a fault rupture zone). A "No Impact" answer should be explained where it is based on project-specific factors as well as general standards (e.g. the project will not expose-sensitive receptors to pollutants, based on a project- specific screening analysis). All answers must take account of the whole action involved, including off-site as well as on-site, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts. 3)"Potentially Significant Impact" is appropriate if there is substantial evidence that an effect is significant. If there are one or more "Potentially Significant Impact" entries when thedetermination is made, an EIR is. required. 4) 5) "Negative Declaration: Potentially Significant Unless Mitigation Incorporated" applies where the incorporation of mitigation measures has reduced an effect from "Potentially Significant Impact" to a "Less than Significant Impact." The lead agency must describe the mitigation measures, and briefly explain how they reduce the effect to a less than significant level (mitigation measures from Section XVII, "Earlier Analyses," may be cross-referenced). Earlier analyses may be used where, p~suant to the tiering, program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration. Section 15063(c)(3)(D). Earlier analyses are discussed in Section XVII at the end ofthe checklist. 6)Lead agencies are encouraged to incorporate into the checklist references to information sources for potential impacts (e.g. g~neml plans, zoning ordinances). Reference to a previously prepared or outside document should, where appropriate, include a reference to the page or pages where the statement is substantiated. See the sample question below. A source list should be attached, and other sources used or individuals contacted should be cited in the discussion. 7)This is only a suggested form, and lead agencies are free to use different ones. 18 Issues (and Supporting Information Sources): II. 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)Be incompatible with. existing land use in the vicinity? d) III. e) a) b) Affect agricultural resources or operations (e.g. impacts to soils or farmlands, or impacts from incompatible land uses)? Disrupt or divide the physical arrangement of an established community (including a low-income or ¯ minority community? POPULATION AND HOUSING. Would the proposal: Cumulatively exceed official regional or local population projections? Induce substantial growth in an area either directly or indirectly (e.g. through projects in an undeveloped area or extension of major infrastructure)? c)Displace existing housing, especially affordable housing? GEOLOGIC ’PROBLEMS. Would the proposa! result in or expose people to potential impacts involving: a) Fault rupture? b) Seismic ~ound shaking? Sources 2 1,2 3 3 Potentially Significant Impact Negative Declaration: Potentially Significant Unless Mitigation Incorporated Les~ Than Significant Impact NO Impact 19 Issues (and Supporting Information Sources): c) Seismic ground failure, including liquefaction? d) Seiche, tsunami, or volcanic hazard? e) Landslides or mudflows? f) Erosion~ changes in topography or unstable soil conditions from excavation, grading, or fill? g) Subsidence of the land? h) Expansive soils? i) Unique geologic or physical features?- SOUFCeS 3 3 3 1,3 3 3 1,3 Potentially Significant Impact Negative Declaration: Potentially Significant Unless Mitigation Incorporated Less Than Significant Impact No Impact IV. WATER. Would the proposal result in: - a)Changes in absorption rates, drainage patterns, or the rate and amount of surface runoff?. b)Exposure of people or property, to water related hazards such as flooding? c)Discharge into surface waters or other alteration of surface water quality (e.g. temperature, dissolved oxygen or turbidity)? d)Changes in the amount of surface water in any water body? e)Changes in currents, or the course or direction of water movements? Change in the quantity of ground waters, either through direct additions or withdrawals, or through interception of an aquifer by cuts or excavations or through substantial loss of groundwater recharge capability? g) Altered direction or rate of flow of~groundwater? h) Impacts to groundwater quality? 2O Issues (and Supporting Information Sources): i) Substantial reduction in th.e amount of groundwater otherwise available for public water supplies? V. AIR QUALITy. Would the proposal: a)Violate any air quality stan.dard or contribute to an existing or projected air quality violation? b) Expose sensitive receptors to pollutants? c)Alter air movement, moisture, or temperature, or cause any change in climate? d) Create objectionableodors? VI. TRANSPORTATION/CIRCULATION. Would the proposal resi~lt 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)? 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)? g) Sources Potentially Significant Impact 1 1,2 1,2 Negative Declaration: Potentially Significant Unless Mitigation Incorporated Less Than Significant Impact 1,2 N( Imp: I ¯ 1 ¯ ¯ 21 Issues (and Supporting Information Sources): e) VIII. b) Locally designated species (e.g. heritage trees)? .c)Locally designated natural communities (e.g. oak forest, coastal habitat, etc.)? d)Wetland habitat (e.g. marsh, riparian and vernal pool)? Wildlife dispersal or migration corridors? ENERGY AND MINERAL RESOURCES. Would the proposal: a) Conflict with adopted energy conservation plans? b)Use non-renewable resources in a wasteful and inefficient manner? c)Result in the loss of availability of a known mineral resource that would be of future value to the re~ion and the residents of the State? IX. HAZARDS. Would the proposal involve: a) b) c) A risk of accidental explosion or release of hazardous substances (including, but not limited to: oil, pesticides, chemicals or radiation)? Possible interference with an emergency response plan or emergency evacuation plan? The creation of any health hazard or potential health hazards? d)Exposure of people to existing sources of potential health hazards? e)Increased fire hazard in areas with flammable brush, grass, or trees? NOISE. Would the proposal result in: Sources 1 I 1,2 1 Potentially Significant Impact Negative Declaration: Potentially Significant Unless Mitigation Incorporated a) Increases in existing noise levels? Less Than Significant Impact NO Impact 22 Issues (and Supporting Information Sources): b) Exposure of people to severe noise levels? . XI.PUBLIC SERVICES. Would the proposal have an effect upon, or result in a need for new or altered ~,overnment services in any of the following areas a) Fire protection? b) Police protection? c) Schools? d) Maintenance of public facilities, including roads? e) Other governmental services? XII.UTILITIES AND SERVICE SYSTEMS. Would the proposal result in a riced for new systems or supplies, or substantial alterations to the following utilities: a) Power or natural gas? b) Communications systems.’? c)Local or regional water treatment or distribution facilities? d) Sewer or septic tanks? e) Storm water drainage? f) Solid waste disposal? g) Local or regional water supplies? ~IIl. AESTHETICS. Would the proposal: a) Affect a scenic vista or scenic highway? b) Have a demonstrable negative aesthetic effect? Sources 1 l l 1 1 1 1 1 I 1 1 l Potentially Significant Impact Negative Declaration: Potentially Significant Unless Mitigation Incorporated Less Than Significant Impact No Imw ¯ 23 Issues (and Supporting Information Sources): c) Create light or glare? XIV. CULTURAL RESOURCES. Would the proposal: a) Disturb paleontological resources? b) Disturb archaeological resources? c) Affect historical resources? d)Have the potential to cause a physical change which would affect unique ethnic cultural values? e)Restrict existing religious or sacred uses within the potential impact area? XV. RECREATION. Would the proposal: a)Increase the demand for neighborhood or regi~.nal parks or other recreational facilities? " b) XVI. a) Affect existing recreational opportunities? MANDATORY FINDINGS OF sIGNIFICANCE. Does the project have the potential to degrade the qualit3, Of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? Sources 1 1 1,2 1,2 1,2 1,2 1,2 Potentially Significant Impact Negative Declaration: Potentially. Significant Unless Mitigation Incorporated Less Than Significant Impact No Impact 24 b)Does the project have t~y..potential to achieve short- term, to the disadvantage of long-term, environmental goals? c) d) Does the project have impacts that are individually limited, but cumulatively considerable? ("Cumulatively considerable" means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly? XVII. a) b) c) EARLIER ANALYSES. Earlier analyses may be used where, pursuant to the tiering, program EIR, or other CEQA process, one or more effects have been adequately analyzed in an earlier EIR or negative declaration. Section 15063(C)(3)(D). In this case a discussion should identify the following .on attached sheets: Earlier analyses used. Identify earlier analyses a..nd state where they are available for review. Impacts adequately addressed. Identify which effects from the above checklist were within the scope of and adequately analyzed in an earlier document pursuant tot he applicable legal standards, and state whether such effects were addressed by mitigation measured based on the earlier analysis. Mitigation measures. For effects that are "Negative Declarations: Less than Significant with Mitigation Incorporated," describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the project. XVIII. SOURCE REFERENCES 1 Palo Alto Regional Water Quality Control Plant, Solids Facility Plan, May 1997 2 Palo Alto Comprehensive Plan, 1980-1995 3 Palo Alto Comprehensive Plan Update Draft Environmental Impact Report, December 1996 4 Voice mail message from Jim Gilliland (City of Palo Alto) regarding zoning, on June 24, 1997 5 Voice mail message from Jim Gilliland (City of Palo Alto) regarding zoning, on June 26, 1997 25 iXX. EXPLANATIONS FOR CHECKLIST RESPONSES --I a The proposed project is consistent with the existing Major Institution/Special Facilities general plan designation of the PARWQCP and the Public Facilities with Site Design Overlay (PF(D)) zoning. The.PAKWQCP site is.bordered on the west by one- and two-story office buildings, on the south by the City landfill, on the east by the Bay and Baylands- Nature Preserve, and on the north by the Palo Alto Airport. The Pal0 Alto Golf Course is also located jfist west of the airport. Much of the PARWQCP site is screened from these.land uses by trees along its perimeter. However, the access road to the landfill runs directly along the east plant boundary, so some PARWQCP facilities, such as the fixed film reactors, are clearly visible. The proximity to the airport places height restrictions on the treatment facilities. The top of the existing incinerators are generally considered the maximum height allowed. 1 b The proposed project does not conflict with any applicable environmental plans or policies adopted by agencies with jurisdiction over the project. I c The proposed project would not be incompatible with existing land use in the vicinity. Modifications to PARWQCP facilities would be limited to the existing treatment plant site. I d The proposed project would not impact agricultural resources or operations. I e The p.roposed project has no impact on the physical arrangement of any established communities. II a The proposed project will not cumulatively exceed official regional or local population projections. See discussion for Issue II b below. II b The proposed project will not induce growth directly or indirectly. See discussion on pages 5 to’7 of the attached project description. II c The proposed project is limited to the existing treatment plant site and would not displace any existing housing. III a The proposed project is not located on a fault and would not result in or expose people to fault rupture. III b The Palo Alto Comprehensive Plan designates the project area to be prone to viotent shaking in the event of a major earthquake. This shaking could cause significant damage to structures if not properly designed or constructed. A geotechnical report for the project will be prepared and the recommended design measures identified in that report will be incorporated into the project. III c Liquefaction can occur when loose, saturated, relatively clean cohesionless soils are subjected to ground vibrations. The project area is situated adjacent to the San Francisco Bay and is underlain in part by Bay mud, an organic clay which is so~t and compressible. Sand lenses are interspersed throughout the Bay mud; these-lenses carry groundwater in the vicinity of the Bay and, during seismic events, have the potential to liquefy. According to’ the City of Palo Alto Comprehensive Plan, the site has a high liquefaction potential. The geotechnical investigation to be prepared for the project will identify appropriate design measures that will be incorporated into the project to address liquefaction issues. Ill d The proposed project would not result in or expose people to seiche, Tsunami, or volcanic hazard. IlI e The proposed project would not result in or expose people to landslides or mudflows. IIl f The proposed project would not result in or expose people to erosion, changes in ¢opography or unstable soil conditions from excavation, grading, or fill. III g The proposed project wou!d not result in or expose people to subsidence of land. III h The proposed project would not result in or expose people to potential impacts from expansive soils. III i No unique geologic or physical features exist at the project site, so the proposed project would not result in or expose people to potential impacts from unique geologic or physical features. IV a The proposed project would be constructed on currently paved ground and would not add paved area. Hence the l~roposed project would not result inany changes in absorption rates, drainage patterns, or the rate and amount of IXX. EXPLANATIONS FOR CHECKLIST RESPONSES IV b IV c IV d IVe IV f IVg IVh IV i ga Vb surface runoff. The treatment plant site is in a flood zone, as designated by FEMA. However, the proposed project would not result iJ 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 theaddition of scrubber water treatment there will be no increase in metals in the wastewater discharged to the Bay and the adjacent Baylands Nature Preserve The wastewater discharged will still meet permit requirements for metals. The proposed project would not change the amount of surface water in any water body. The proposed project would not change currents or the course or direction of water movements. 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. The proposed project would not alter the direction or rate of flow of groundwater. The proposed project would not result in impacts to groundwater quality. The proposed project would not result in substantial reduction in the amount of groundwater otherwise available for public water supplies. Construction-related emissions, such as dust (fine particulate 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 areas’, will be required by the Bay Area Air Quality Management District (BAAQMD) to reduce any potential dust emissions. Applying effective and comprehensive control measures during project construction would prevent violations of any air standards. There will be no net increase in emissions as compared with current emission levels based on recent source test data. Table 1 at the end of this checklist summarizes the current and future emissions associated with this project. The project will be designed with a new air emissions abatement system that 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. 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 sensiti~;e receptors. Sensitive receptors include schools, daycare centers, hospitals, and nursing homes. The PARWQCP staffwill adhere to 27 IXX. EXPLANATIONS FOR CHECKLIST RESPONSES proper abatement equipment installation (including scheduled shutdown of incinerators during installation), testing, and operating procedures to minimize any potential air emission impacts to workers in the light industrial businesses near the project site. V c The project does not include the addition or modification ofmajor heat or moisture sources and would not result in a significant alteration of air movement, moisture, temperature, or other climatic changes. v d The dryer, which would only be operated only occasionally (typically maximum 4 weeks per year), is the only new potential odor source, but is not expected to create an impact. The project will be designed to handle odor sources (i.e., dryer, scum handling, and feed tank) by venting the exhaust d!rectly to the incinerator inlet air. There it will be combusted and then sent to the incinerator emissions abatement system for added destruction of combustion by- products. Because of this configuration, the potential for odor outside of the abatement system will not be created. Therefore, no additional odors will be released beyond current operating conditions. Objectionable odors are not expected to occur. V1 a Facility construction Will have a less than significant impact on traffic. The number of trucks to haul solids by-products (ash) will be the same as the current number, which is one truck per week. Traffic related to construction activities are expected to be similar to the traffic that occurs during annual maintehance and rehabilitation of the Plant’s existing systems. This could include up to 8-10 workers entering thesite per day and a limited number of trucks delivering concrete, other materials, and equipment to the site. Traffic impacts from construction would be less than significant. The proposed project does not contain any transportation design features and would not result in hazards to safety from design features such as sharp curves or dangerous intersections. Vl b VI c Project construction activities and operations at PARWQCP would not interfere with emergency access or access tO nearby uses, nor are they expected to interfere with emergency access at the PARWQCP. VI d PARWQCP currently has adequate parking capacity and would not add any additional employees as a result ofthc project. Parking needs for construction activities would not exceed current parking needs for rehabilitation and maintenance activities. VI e VI f VI o VII a VII b VII c VII d Facilities at PARWQCP would not be expanded outside the current plant boundaries and would not be a hazard to pedestrians or bicyclists. There are no pedestrian or bicycle paths within the PARWQCP. The project does not conflict ~vith City. of Pa!o Alto adopted policies supporting alternative transportation. The project would have no impacts on rail or waterborne traffic. Traffic at the adjacent airport would not be impacted by the project construction or operation. No part of the rehabilitation or expansion would be greater in height than the existing incinerators, which are considered the maximum height allowable to avoid impacting airport traffic. The proposed project will result in a 99.9% decrease in dioxin and furan emissions, an average 54 percent decrease in metals air emissions, and an average 48 percent decrease in criteria pollutant emissions compared to current emissions, resulting in a project benefit. As a result, no impacts to endangered, threatened, or rare species in the adjacent marshes are expected. The proposed project would require the removal of one or two eucalyptus trees next to the incinerator on the PARWQCP site. However, these trees are not heritage trees and they are less than 20 years old. They will need to be removed with or without this project, since they pose a fire hazard due to their proximity, to the incinerator chimney, and the tree roots are invasi~e and have the potential to damage building foundations, pipes, and high voltage conduits. The proposed project would not result in impacts to locally designated natural communities such as oak forest 0r coastal habitat. The incinerator abatement air scrubber would recycle trace amounts of metals removed from the air stream back to the plant headworks. Use of scrubber water treatment to precipitate, concentrate, and remove metals from the recycle water will result in no increase in metals in the wastewater discharged to the Bay and the adjacent Baylands Nature Preserve. This is a mitigation measure to prevent discharge of the metals to air or water. The wastewater discharged will still 28 IXX. EXPLANATIONS FOR CHECKLIST RESPONSES VII e VIII a VIII b Vlll c IX a IX b IXc IXd IXe Xa Xb XI a XI b XIc Xld Xle Xll a 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. The proposed project would not result in the loss of availability of a known mineral resource that would be of future value to the region and tO the residents of the State. The thermal dryer may present a small risk of accidental explosion or fire. However, the proposed project would be desizned 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. The proposed project woultt not interfere with an emergency response plan or emergency evacuation plans. The proposed project will result in a 99.9% decrease in dioxin and furan emissions, an average 54 percent decrease in metals air emissions, and an average 48 percent decrease in Criteria pollutant emissions compared to current emissions from the incinerators, resulting in a project benefit. As a result, the project will result in no new impacts to health. " Neither the proposed project nor the PARWQCP create metals; any metals emissions result from metals in the plant influent. However, the metals, primarily mercury, that would be removed by scrubber water treatment discussed in Vlld may need to be ~:ecycled or handled as a hazardous waste. Amounts that would be removed would be small and are estimated to be approximately 0.1 lb/year for the lightest metals and approximately 30 lb/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 regulatibns that govern the use, storage, and disposal of such materials. As a result, no significant impacts are expected. The proposed project area does not contain flammable brush, grass, or trees, and the proposed project would not increase fire hazard in areas with flammable brush, grass, or trees. The proposed project may result in short-term increases in existing noise levels associated with c.onstruction activities. However, the impacts are expected to be minor and not noticeably different than current noise associated with rehabilitation and maintenance activities. No-sensitive receptors are located near the project area. Therefore, impacts to existing noise levels are expected to be less than significant. The proposed project would not result in exposure of people to severe noise levels. The proposed project would not affect or result in a need for new or altered fire protection services. The proposed project would not affect or result in a need for new or altered police protection services. The proposed project would not affect or result in a need for new or altered schools. The proposed project consists of rehabilitation and modifications to a public facility (a portion of the PARWQCP). The rehabilitation and modifications are expected to improve the operations and reduce the maintenance needs of the ~olids handling facility. As a result, the proposed project would not affect or result in a need for new or altered maintenance of public facilities. The proposed project would not affect or result in a need for any other new or altered governmental services. The proposed project would not result in a need for new systems or supplies of or substantial alterations to power or natural gas utilities. 29 -IXX. EXPLANATIONS FOR CHECKLIST RESPONSES XII b The proposed project would not result in a need for new systems or supplies of or substantial alterations to communications systems. Xtl c The proposed project would not result in a need for new systems or supplies of or substantial alterations to local or reoional water treatment or distribution facilities. XII d The proposed project would not result in a need for new systems or supplies of or substantial alterations to server or septic tanks. . XI] e The proposed project would not result in a need for new systems or supplies of or substantial alterations to storm water drainage. XII f The proposed project would not result in a need for new systems or supplies of or substantial alterations to solid waste disposal. XII g .The proposed project would not result in a need for new systems or supplies of or substantial alterations to local or regional water supplies. XIII a The proposed project would not affect a scenic vista or scenic highway. XI]I b The proposed project would not have a demonstrable.negative aesthetic effect. The new facilities would be within the existing plant boundaries and would not be visible to the general public. New structures would be attached or adjacent to existing structures, would match existing exteriors, would be the same as or lower iia height than the existing structures, and would be sheltered from view by other existing structui’es in the plant and by trees that surround the plant. XIII c The proposed project would not create light or glare. XIV a The proposed project Would be located on the existing PARWQCP site and would not disturb paleontological resources. XIV b The proposed project would be located on the existing PARWQCP site and would not disturb archaeological resources. XIV c The proposed project would be located on the existing PARWQCP site and would not affect historical resources. XIV d The proposed project would not have the potential to cause a physical change which would affect unique ethnic culturai .... values. XIV e The proposed project would not restrict existing religious or sacred uses within the. potential impact area. XV a The proposed project would not eliminate any existing parks or recreational facilities and would not induce growth in the region. As a result, the proposed project would not increase the demand for neighborhood or regional parks or other recreational facilities. XV b The proposed project would not affect existing recreational opportunities. 3O Criteria Pollutants Carbon monoxide Nitrous Oxides Sulfur oxides THC Particulate matter Volatile O~anic Carbons Hazardous Air Pollutants Dioxin Table 1: Current and Future Emissions, PARWQCP Incinerator Rehabilitation Pollutant Current Emissions (Ib/day) 116.98 87.96 52.99 2.16 16.2 0.54 2.34 x 10-8 Furans 1.03 x 10-7 Metals Arsenic 4.51 x 10-3 Beryllium 4.33 x 10-6 Cadmium 1.53 x 10-2 ~ Chromium 2.34 x 10-3 Copper 1.23 x 10-2 Manganese 9.01 x 10-3 Mercury 4.15 x 10-2 Nickel 2.34 x 10-3 Selenium 8.47 x 10-3 Zinc 6.49 x 10"1 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"11 3.48.x 10-3 3.98 x 10-6 4.11 x 10-3 5.37 x 10-4 1.18 x 10 - 3.52 x 10--4 4.05 x 10-2 2.96 x 10-4 3.69 x 10-4 1.64 x 10"1 Authority: Public Rcsourccs Codc Scctions 21083 and 21087. Rcfcrencc: Public P, esourccs Code Sections 21080(c). 21080.1.21080.3.21082.1, 21083, 21083.3, 21093, 21094, 21151 ; Sundstrom v. County of Mendocino, 202 Cal. App. 3d 296 (1988); Leonoffv. Monterey Board of Supervisors, 222 Cal. App. 3d 1337 (1990) 31 ATTACHMENT B ATTACHMENT- C February 4, 1998 Palo Alto City Council 250 Hamilton Avenue Palo Alto, CA 94301 Dear Mayor Rosenbaum and members.of the City Council: The League of Women Voters of Palo Alto supports comprehensive measures to provide maximum protection to human health and the environment from the adverse effects of hazardous materials. Because certain hazardous materials are associated with the treatment and disposal of sewage sludge, we have some concerns about the proposal to repair and improve the existing sewage sludge incinerators at the Palo Alto Regional Water Quality Control Plant. The proposed solution to the problem of how to handle the sludge from sewage treatment when the present incinerators are on the verge of breaking down, may not be the best solution from an environmental perspective, but when space requirements, time, and cost are considered, it is probably the appropriate solution at the present time. We are concerned that the performance figures presented in the EIR are estimates and projections that may have no relation to how the rehabilitated incinerators, with the addition of an afterburner and new scrubbers, will actually work. If you approve this proposal, we believe it is imperative that you include a regular and frequent monitoring program to ensure that the system is working as well or better than advertised. Although the dryer is included in the negative declaration, it appears that the addition of this dryer needs more study to avoid safety problems and will not be added to the system unless volume makes it necessary. However, there is a possibility that the addition of such a dryer could act as a pilot project for possible elimination of the incinerators in the future. This idea should be considered in deliberations over a long range plan. The repaired system and the existing treatment plant are expected to last less than twenty years. In the context of planning for major changes, that is not a long time. It is not necessary to wait twenty years to make changes; the establishment of long range environmental goals and the search for more effective ways to recycle the sludge should be an ongoing process. We encourage you to instruct the staff of the Regional Water Quality Control Plant to begin now to work on a long range plan for waste water management that will meet the needs of the area in an environmentally friendly way. We commend Phil Bobel and his staff for the efforts they made to meet with local citizens to try to address the concerns of those who are worried about the effects of incineration. Dioxin production is a major concern. The staff was able to show that so much dioxin comes into the plant in the waste water (from toilet, paper,.laundry water, human waste, etc.) that the proposed system will actually reduce the total dioxin level, even though some new dioxins will likely be produced in the incinerator. We hope this reduction will be true. The League of Women Voters of Palo Alto believes that the public has the right to know the potentially harmful effects of materials they encounter in the home, the workplace and the community, and so encourages you to help educate them in ways to reduce toxins in waste water. We also encourage you to include citizens in the planning and decision-making processes of hazardous material management.. Sincerely, Ruth Lacey Geri Stewart Co-Presidents, League of Women Voters of Palo Alto cc:Phil Bobel, Manager, Environmental Compliance Division, PARWQCP Daisy Stark, Engineer, PARWQCP J main telephone no. " 65o.32z..r994 facsimile 650.321.1995Schools Group 650".325~5680 Palo Alto City.Council City, Hall 250 Hamilton Ave. Palo Alto, CA 94301 PEOPLE FOR THE E HVI I OHMEHT _ATTACHMENT D "?1~ Colorado Avanua. Sulta 1 " Palo Alto, California 94303:3913 emeil baaction~,’igc.or~ http://www.be a ction.org Dear City Council, On February 23, Palo Altd City Council i’s scheduled to consider the "WQCP Solids Management l~roject.’’ Bay Area Adtion and a number of other local environmental groups ir~ conjuction with City staff, have been reviewing the proposed plan torepair.the, incinerators at the Palo Alto Regional Water Quality Control Plant (RWQCP). According tO reports prepared for the RWQCP, as w~l! as numerous other supporting documents, there areserious health and environmhntal co.rie’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 decisi6n about this projec~t, r ...., -According taiox]ns Source Identification," a report written for the RWQCP in ~ept. 1997, dioxin~ enter the RWQCP through the following sources: laundry graywater, storm water, human waste, shower water, and toilet paper. The, incineration of the..: sludge destroys some of the dioxins coming into the plant, but also creates more in the burning process. The city staff estimates that th.e incinerators release hal(as many dioxins ihtothe environment as come into the plant from the above mentioned soui’ces; however, there is a high level of uncertainty of how man’y dioxins re-form after being released intothe, a, lr, which may skew~ this . approximation. Dioxins are also released from lhe incinerators through the water effluefit andthrough the ash.The water effluent - POllutes the bay, and the ash is shipped to the Central Valleyand used in agriculture, thus Completing the circle of. c~ntaminating our food supply. , Dioxins are a highly toxi~ by-product created frbm the production and incineration’of"chlorine-contfiining products,’sucfi as organochlorine pesticides, polyvinyl chloride’(PVC) plastics, and polychlorinated biphenyls (PCBs).’’~ Dioxins are dangerous to, humans and wildlife because they bioaccumulate in fatty tissue. "In humans, dioxins have been shown to cause cancer, weaken tile 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 the-council review.this document fis well as tile :’Dioxins Polluti.on Prevention Plan," which was prepared for the RWQCP in October 1997 before th~ Feb.’23 council .. ¯ meeting. Both docurhents elucidate the necessity to reduce the amount of dioxins going to and coming fromthe RW(~CP. : ’ " \ In addition to the sources of di~xins directly affecting the RWQCP,-69% of dioxins emitted locally come fri~m diesel-fueled" motor vehicles, and another 15% from residential wood burning. Although these sources fall outsid~ the scope ofthe.WQC15 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: -" f ¯Develop a dioxins reduction policy for the City of Palo Alto, and r(quest neighboring cities ti3 do the same ¯Build a soiids thermal dryer to pilot eat a non-d]oxm creatfng alternative to handling sewage sludge ¯Explore alternatives, to safely dispose of sludg~ or’ash which contain dioxins¯Educate other plablic agencies and the public abou~dioxins and provid~ information how to reduce them ¯Continue to monitor the influent arid effluent from the RWQCP for.dioxins ,., "Please give this serious issue your full consideration. Thank you’, ’ Susan Stansbury I~ay Area Action Executive Director ~ EIP Associates. 1997. Dioxhls Source Identificatio’n : Ibid. ’ ,ts ,/