HomeMy WebLinkAboutOCSD 18-07RESOLUTION NO. OCSD 18-07
A RESOLUTION OF THE BOARD OF DIRECTORS OF THE
ORANGE COUNTY SANITATION DISTRICT CERTIFYING
THE PROGRAM ENVIRONMENTAL IMPACT REPORT FOR
THE BIOSOLIDS MASTER PLAN, PROJECT NO. PS15-01;
ADOPTING A STATEMENT OF FACTS AND FINDINGS ;
ADOPTING A MITIGATION MONITORING AND REPORTING
PROGRAM; AND APPROVING THE BIOSOLIDS MASTER
PLAN, PROJECT NO. PS15-01
WHEREAS, the Orange County Sanitation District (the "District") is presently
considering the approval of a project known as the Biosolids Master Plan, Project No.
PS15-01 (the "Project).
WHEREAS, pursuant to the California Environmental Quality Act (Public
Resources Code Sections 21000 et seq. ("CEQA")) and the CEQA Guidelines (California
Code of Regulations , Title 14, Sections 15000 et seq.), the District, as lead agency,
prepared a Draft Program Environmental Impact Report ("Draft PEIR") (State
Clearinghouse Number 2017071026) that reflected the independent judgment of the
District as to the potential environmental impacts of the Project and applicable mitigation
measures. The Draft PEIR determined that the Program would not have significant
impacts on the environment with the incorporation of feasible mitigation measures ; and
WHEREAS, the District has consulted with other public agencies and the general
public, and provided such agencies and the public with the opportunity to provide written
and oral comments on the Project and the Draft PEIR as required by CEQA, including a
public review period of 45 days which commenced on February 14, 2018 and ended on
April 2, 2018; and
WHEREAS, on March 15 , 2018, District staff held a public meeting to provide a
further opportunity for public agencies and the general public to comment on the Draft
PEIR; and
WHEREAS, the District has reviewed the comments received and has responded
in the Final Program Environmental Impact Report ("Final PEIR ") to all significant
environmental issues raised during the review and consultation process;
WHEREAS, the comments received on the Draft PEIR , either in full or in summary ,
together with the District 's responses, have been included in the Final PEIR for the
proposed Project; and
OCSD 18-07-1
1313972.1
WHEREAS, the Final PEIR, including the comments received by the District on the
Draft PEIR, has been presented to the District's Board of Directors (the "Board") for review
and consideration prior to the approval of, and commitment to, the Project, and the
certification of the Final PEIR, adoption of the Statement of Facts and Findings, and
approval of the Mitigation Monitoring Program is consistent with the provisions of CEQA.
NOW, THEREFORE, the Board of Directors of the Orange County Sanitation
District DOES HEREBY RESOLVE, DETERMINE AND ORDER:
1313972.l
1. The Board of Directors certifies that the Final Program Environmental Impact
Report, attached to this Resolution as Exhibit A, including comments and
responses thereto, has been completed in compliance with CEQA and
represents a complete and adequate description of the environmental
conditions of the proposed Project;
2. The Board of Directors has independently reviewed and considered the Final
Program Environmental Impact Report together with all comments received
during the public review process;
3. The Final Program Environmental Impact Report reflects the independent
judgment and analysis of the Board;
4. The Board of Directors adopts the Facts and Findings Regarding the
Environmental Effects for the Biosolids Master Plan Project ("Statement of
Facts and Findings"), attached to this Resolution as Exhibit B, including all
findings regarding the potentially significant environmental impacts of the
proposed Project;
5. The Board of Directors has independently reviewed and considered the
Statement of Facts and Findings prepared for the proposed Project;
6. The Board of Directors finds on the basis of the whole record before it that there
is no substantial evidence that the Project, as mitigated, will have a significant
effect on the environment;
7. The Board of Directors finds that the recommended mitigation measures
contained in the Final Program Environmental Impact Report shall be
implemented and adopts the Mitigation Monitoring and Reporting Program (the
"MMRP"), included in Exhibit A, to ensure that all mitigation measures will be
i mplemented;
8. The Final Program Environmental Impact Report has been completed in
compliance with the requirements of CEQA and is hereby certified;
OCSD 18-07-2
9. The Board of Directors approves the Biosolids Master Plan Project, Project No.
PS15-01.
10. The documents and other materials that constitute the record of proceedings
on which the Board of Directors decision is based are located at the District
Administration Offices, 10844 Ellis Avenue, Fountain Valley, CA 92708 and the
custodian for these documents is the Clerk of the Board.
11. District staff is authorized and directed to file the Notice of Determination (NOD)
and any other documents in accordance with the requirements of CEQA.
PASSED AND ADOPTED at a regular meeting of the Board of Directors held
June 27, 2018.
ATTEST:
OCSD 18-07-3
1313972.1
STATE OF CALIFORNIA }
) SS
COUNTY OF ORANGE )
I, Kelly A. Lore, Clerk of the Board of Directors of the Orange County Sanitation
District, do hereby certify that the foregoing Resolution No. OCSD 18-07 was passed and
adopted at a regular meeting of said Board on the 27 1h day of June 2018, by the following
vote, to wit:
AYES:
NOES:
ABSTENTIONS:
ABSENT:
Beard (Alternate); Bernstein; Collacott; Deaton; Ferryman;
Hawkins; Kim; Krippner (Alternate); R . Murphy; Parker;
Peterson; Sebourn; Shaw; Shawver; F. Smith; T. Smith;
Wagner; Wanke; Withers; and Yarc
None
None
Barnes; Benavides (Alternate); Nagel; Peotter and Steel
IN WITNESS WHEREOF, I have hereunto set my hand and affixed the official seal
of Orange County Sanitation District this 27th day of June 27, 2018.
1313972. [
e· ,
Board of Directors
ounty Sanitation District
OCSD 18-07-4
Final
ORANGE COUNTY SANITATION DISTRICT
BIOSOLIDS MASTER PLAN
PROJECT NO. PS15-01
Final Program Environmental Impact Report
State Clearinghouse No. 2017071026
Prepared for May 2018
Orange County Sanitation District
Final
ORANGE COUNTY SANITATION DISTRICT
BIOSOLIDS MASTER PLAN
PROJECT NO. PS15-01
Final Program Environmental Impact Report
State Clearinghouse No. 2017071026
Prepared for May 2018
Orange County Sanitation District
626 Wilshire Boulevard
Suite 1100
Los Angeles, CA 90017
213.599.4300
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150626
OUR COMMITMENT TO SUSTAINABILITY | ESA helps a variety of
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OCSD Biosolids Master Plan i ESA / 150626
Final Program Environmental Impact Report May 2018
TABLE OF CONTENTS
OCSD Biosolids Master Plan
Final Environmental Impact Report
Page
Chapter 1. Introduction to Response to Comments ....................................................... 1-1
1.1 CEQA Requirements ......................................................................................... 1-1
1.2 CEQA Process................................................................................................... 1-2
1.3 Evaluation and Response to Comments ............................................................ 1-2
1.4 Final PEIR Certification and Approval ................................................................ 1-3
1.5 Notice of Determination ..................................................................................... 1-3
Chapter 2. Comment Letters ............................................................................................. 2-1
Chapter 3. Responses to Comments ................................................................................ 3-1
Letter 1: State Clearinghouse, Office of Planning and Research ................................ 3-1
Letter 2: California Department of Resources Recycling and Recovering
(CalRecycle) ...................................................................................................... 3-1
Letter 3: California Department of Fish and Wildlife (CDFW) ...................................... 3-2
Letter 4: South Coast Air Quality Management District (SCAQMD) ............................ 3-6
Letter 5: Orange County Health Care Agency ........................................................... 3-13
Letter 6: Orange County Transportation Authority .................................................... 3-14
Letter 7: Gae Brummett ............................................................................................. 3-18
Letter 8: Patrick Osullivan ......................................................................................... 3-18
Chapter 4. Corrections and Additions to the Draft PEIR ................................................ 4-1
3.0 Environmental Setting, Impacts and Mitigation Measures ................................. 4-1
3.2 Air Quality .......................................................................................................... 4-1
3.11 Traffic and Transportation .................................................................................. 4-5
Chapter 5. Mitigation Monitoring and Reporting Program ............................................. 5-1
CEQA Requirements .................................................................................................. 5-1
Attachments
1. Roadway Traffic Noise Levels
2. Air Quality Information
List of Tables
2-1 Comment Letters Received .......................................................................................... 2-1
5-1 Mitigation Monitoring and Reporting Program for the OCSD BMP Program EIR ......... 5-2
OCSD Biosolids Master Plan 1-1 ESA / 150626
Final Program Environmental Impact Report May 2018
CHAPTER 1
Introduction to Response to Comments
This Final Program Environmental Impact Report (Final PEIR) has been prepared in accordance
with the California Environmental Quality Act (CEQA) as amended (Public Resources Code
Section 21000 et seq.) and CEQA Guidelines (California Code of Regulations Section 15000 et
seq.). The Final PEIR incorporates, by reference, the Draft PEIR (State Clearinghouse No.
2017071026) prepared by the Orange County Sanitation District (OCSD) for the Biosolids Master
Plan (BMP), Project No. PS15-01 (proposed program), as it was originally published and the
following chapters, which include revisions made to the Draft PEIR.
1.1 CEQA Requirements
Before OCSD may approve the program, it must certify that the Final PEIR: a) has been completed in
compliance with CEQA; b) was presented to the OCSD Board of Directors who reviewed and
considered it prior to approving the project; and c) reflects OCSD’s independent judgment and
analysis. (CEQA Guidelines Section 15090)
CEQA Guidelines Section 15132 specifies that the Final PEIR shall consist of the following:
The Draft PEIR or a revision of that draft;
Comments and recommendations received on the Draft PEIR;
A list of persons, organizations, and public agencies commenting on the Draft PEIR;
The response of the Lead Agency to significant environmental points raised in the review and
consultation process; and
Any other information added by the Lead Agency.
This Final PEIR for the OCSD BMP presents Chapter 1 through Chapter 5:
Chapter 1: Introduction and CEQA process
Chapter 2: A list of persons, organizations, and public agencies commenting on the Draft
PEIR, and the written comments received on the Draft PEIR
Chapter 3: Written responses to each comment identified in Chapter 2
Chapter 4: Revisions made to the Draft PEIR in response to comments received or initiated
by the Lead Agency
Chapter 5: Mitigation Monitoring and Reporting Program
1. Introduction to Response to Comments
OCSD Biosolids Master Plan 1-2 ESA / 150626
Final Program Environmental Impact Report May 2018
1.2 CEQA Process
Public Participation Process
Notice of Preparation and Public Scoping
In accordance with Section 15082 of the CEQA Guidelines, a Notice of Preparation (NOP) of a
PEIR was prepared and circulated for review by applicable local, state and federal agencies and
the public. The 30-day project scoping period, which began with the distribution of the NOP,
remained open through August 13, 2017. One public scoping meeting was held on July 31, 2017
at the OCSD Plant No. 2, Operations Center Training and Conference Room. The NOP provided
the public and interested public agencies with the opportunity to review the proposed project and
to provide comments or concerns on the scope and content of the environmental review document
including: the range of actions; alternatives; mitigation measures, and significant effects to be
analyzed in depth in the PEIR.
Notice of Availability of the Draft PEIR
The Notice of Availability (NOA) of the Draft PEIR was posted on February 14, 2018 with the
County Clerk in Orange County. The Draft PEIR was circulated to federal, state, and local
agencies and interested parties requesting a copy of the Draft PEIR. Copies of the Draft PEIR
were made available to the public at the following locations:
OCSD Website (https://www.ocsd.com/ceqa)
OCSD, Administrative Office Building at Plant No. 1, Engineering Planning Division – 10844
Ellis Avenue, Fountain Valley, CA 92708
OCSD, Plant No. 2, Operations Center – 22212 Brookhurst Street, Huntington Beach, CA 92646
Huntington Beach Central Library – 7111 Talbert Avenue, Huntington Beach, CA 92648
Huntington Beach Banning Library – 9281 Banning Avenue, Huntington Beach, CA 92646
Fountain Valley Public Library – 17635 Los Alamos Street, Fountain Valley, CA 92708
The Draft PEIR was circulated for public review from February 14, 2018 through April 2, 2018.
OCSD established a 45-day review period, as required by Section 21091 of the Public Resources
Code. During this period, OCSD held one public meeting to provide interested persons with an
opportunity to comment orally or in writing on the Draft PEIR and the project. The public
meeting was held at the OCSD Plant No. 2, Operations Center Training and Conference Room in
Huntington Beach on March 15, 2018.
1.3 Evaluation and Response to Comments
CEQA Guidelines Section 15088 requires OCSD, as the Lead Agency, to evaluate comments on
environmental issues received from parties that have reviewed the Draft PEIR and to prepare a
written response. The written responses to commenting public agencies shall be provided at least
ten (10) days prior to the certification of the Final PEIR (CEQA Guidelines §15088(b)).
1. Introduction to Response to Comments
OCSD Biosolids Master Plan 1-3 ESA / 150626
Final Program Environmental Impact Report May 2018
1.4 Final PEIR Certification and Approval
Prior to considering the project for approval, OCSD, as the Lead Agency, will review and
consider the information presented in the Final PEIR and will certify that the Final PEIR:
(a) Has been completed in compliance with CEQA;
(b) Has been presented to the Board of Directors as the decision-making body for the Lead
Agency, which reviewed and considered it prior to approving the project; and
(c) Reflects OCSD’s independent judgment and analysis.
Once the Final PEIR is certified, OCSD’s Board of Directors may proceed to consider program
approval (CEQA Guidelines §15090). Prior to approving the proposed program, OCSD must
make written findings and adopt statements of overriding considerations for each unmitigated
significant environmental effect identified in the Final PEIR in accordance with Sections 15091
and 15093 of the CEQA Guidelines. Because the Final PEIR does not identify any unmitigated
significant environmental effects, a statement of overriding considerations is not required.
1.5 Notice of Determination
Pursuant to Section 15094 of the CEQA Guidelines, OCSD will file a Notice of Determination
(NOD) with the Office of Planning and Research and Orange County Clerk within five working
days of program approval.
OCSD Biosolids Master Plan 2-1 ESA / 150626
Final Program Environmental Impact Report May 2018
CHAPTER 2
Comment Letters
The Draft Program Environmental Impact Report (PEIR) for the Orange County Sanitation
District (OCSD) Biosolids Master Plan (BMP), Project No. PS15-01 (proposed program) was
circulated for public review for 45 days (February 14, 2018 through April 2, 2018) in accordance
with the requirements of CEQA Guidelines Section 15105(a). The OCSD received eight comment
letters during the public review period, which are listed in Table 2-1 and included within this
chapter. The letters have been marked with brackets that delineate comments pertaining to
environmental issues and the information and analysis contained in the Draft PEIR. Responses to
such comments are provided in Chapter 3.
A public meeting on the Draft PEIR was also held on March 15, 2018 at the OCSD Plant No. 2
Operations Center Training & Conference Room. An overview of the proposed program and a
summary of the Draft PEIR findings were provided during the meeting. Verbal comments
received during the meeting were related to clarifications of the activities proposed. Comment
cards were made available at the meeting; however, no written comments were provided during
the meeting.
TABLE 2-1
COMMENT LETTERS RECEIVED
Comment
No. Commenting Agency Date of Comment
1 State Clearinghouse, Office of Planning and Research April 2, 2018
2 California Department of Resources Recycling and Recovering (CalRecycle) March 5, 2018
3 California Department of Fish and Wildlife (CDFW) March 29, 2018
4 South Coast Air Quality Management District (SCAQMD) March 30, 2018
5 Orange County Health Care Agency March 23, 2018
6 Orange County Transportation Authority March 28, 2018
7 Gae Brummett March 13, 2018
8 Patrick Osullivan March 14, 2018
OCSD Biosolids Master Plan 3-1 ESA / 150626
Final Program Environmental Impact Report May 2018
CHAPTER 3
Responses to Comments
A summary of the comments contained within the comment letters received during the public
review period for the Draft PEIR are included in this section (see Chapter 2). OCSD provides
individual responses to the bracketed comments in each letter. In some instances, in response to
the comment, OCSD has made additions or deletions to the text of the Draft PEIR; additions are
included as underlined text and deletions as stricken text. The revisions do not significantly alter
the conclusions in the Draft PEIR.
Letter 1: State Clearinghouse, Office of Planning and
Research
Comment 1-A
The comment acknowledges the State Clearinghouse distributed the EIR as required under CEQA
to pertinent agencies. The CalRecycle comment letter is attached.
Response 1-A
The comment is noted and saved in the program record. No response is required because there are
no specific comments on the contents in the Draft PEIR. The CalRecycle letter is responded to as
Letter 2 below.
Letter 2: California Department of Resources
Recycling and Recovering (CalRecycle)
Comment 2-A
The comment reiterates the program description provided in the Draft PEIR and introduces
comments on the proposed program for OCSD’s consideration.
Response 2-A
No response is required because there are no specific comments on the contents in the Draft
PEIR.
Comment 2-B
The comment states that the County of Orange, Environmental Health Division, Local
Enforcement Agency (LEA), and CalRecycle are responsible for providing regulatory oversight
3. Responses to Comments
OCSD Biosolids Master Plan 3-2 ESA / 150626
Final Program Environmental Impact Report May 2018
of solid waste handling activities, such as transfer/processing operations/facilities and in-vessel
digestion operations/facilities, including permitting and inspections. Further, the comment states
that the LEA will make a determination as to whether the proposed program falls under the in-
vessel digestion requirements as described in Title 14, California Code of Regulations, Chapter
3.2 (commencing with section 17896.1). The comment then provides a contact number to discuss
any permitting requirements.
Response 2-B
The proposed program does not include solid waste handling activities. The food waste
component of the proposed program includes pre-processed food waste that will be conveyed into
the Food Waste Receiving Facility through a hose. OCSD will comply with any applicable permit
requirements from the LEA and CalRecycle.
Comment 2-C
The comment thanks OCSD for the opportunity to review and comment on the Draft PEIR and
requests copes of subsequent environmental documents and/or notices for the program. The
comment further requests that CalRecycle be given notice 10 days’ notice of program adoption.
Response 2-C
The comment is noted and saved in the program record. OCSD will provide a notice of the OCSD
Board meeting to deliberate on the proposed program.
Letter 3: California Department of Fish and Wildlife
(CDFW)
Comment 3-A
The comment acknowledges that the CDFW has received and reviewed the Draft PEIR and
summarizes the program description of the proposed program. Additionally, the comment
provides background information on various species that are located within the vicinity of the
program area, such as the light-footed Ridgway’s rail and Belding’s savannah sparrow. Last, the
comment begins to introduce various environmental concerns of the proposed program, but the
concerns are provided in Comments 3-B through 3-E below.
Response 3-A
The comment is noted. No response is required because there are no specific comments on the
contents in the Draft PEIR.
Comment 3-B
The comment states that the Draft PEIR does not specifically discuss impacts to the Light-Footed
Ridgway’s Rail beyond Table 3.3-2, even though they were identified in Brookhurst Marsh,
which is located approximately 0.2 mile from the program area. Given recent restoration efforts,
3. Responses to Comments
OCSD Biosolids Master Plan 3-3 ESA / 150626
Final Program Environmental Impact Report May 2018
the Huntington Beach Wetlands, including Talbert Marsh, has become more suitable habitat for
this species. Similarly, the Draft PEIR does not mention Belding’s Savannah Sparrow. The
comment expresses concern regarding potential edge effects and indirect impacts to Talbert
Marsh and the Santa Ana River, particularly noise-related impacts associated with proposed
construction activities. CDFW is particularly concerned that elevated noise levels will impact the
Belding’s Savannah Sparrow and Light-Footed Ridgway’s Rail. The comment requests further
discussion and analysis of the impacts of noise generated by the program on birds and other
wildlife in the Final PEIR and that the analysis should include a mitigation measure or measures
that minimize impacts to, and takings of, CESA-listed endangered and fully protected species.
The mitigation measures should designate the entire Huntington Beach Wetlands area as a
sensitive noise receptor and include best management practices design features to ensure noise
levels are maintained at or below ambient conditions.
Response 3-B
As stated by the commenter, Table 3.3-2 in the Draft PEIR identifies the potential for the
presence of the Light-Footed Ridgeway’s Rail (previously known as the Light-Footed Clapper
Rail) within the Talbert Marsh as moderate. The Draft PEIR recognizes that nesting activities
associated with this species as well as other species have a potential to be impacted by
construction activities associated with the implementation of the proposed program. The potential
effect is identified in Impact 3.3-1, which explains that construction noise could result in indirect
impacts to birds nesting in the vicinity of the proposed project. The commenter recommends a
specific noise level as the threshold of potential impact. The use of a specific noise level is not
appropriate because the ambient noise levels at the location of the nesting birds need to be taken
into account. Currently noise is primarily generated by motor vehicle traffic along Pacific Coast
Highway and Brookhurst Street. Along Pacific Coast Highway, traffic noise extends into Talbert
Marsh. Based on the average daily traffic volumes of 37,000 trips along Pacific Coast Highway,
the noise levels are currently 73.5 dBA CNEL at 50 feet, 69.2 dBA CNEL at 200 feet and 66.5
dBA CNEL at 400 feet (see Attachment 1). Along Brookhurst Street, traffic noise extends into
Talbert Marsh. Based on the average daily traffic volumes of 11,000 trips, the noise levels are
currently 67.1 dBA CNEL at 50 feet, 62.9 dBA CNEL at 200 feet, and 60.2 dBA CNEL at 400
feet (see Attachment 1).
Mitigation Measure BIO-1 is included in the Draft PEIR to provide protection to nesting birds
and to avoid any potential taking. The measure requires a qualified biologist to conduct a nesting
survey if construction activities are scheduled during the nesting season (i.e., February 15 to
August 31). If active nests are detected, a minimum buffer must be provided and a qualified
biologist would then monitor any active nests within the buffer area. The biologist will have the
authority to increase or decrease the buffer and/or make other recommendations to minimize
impacts (e.g., to curtail, modify, or cease particular activities, such as pile driving, or to provide
temporary noise attenuation) if nest activity appears to be adversely affected. The presence of a
qualified biological monitor provides a more effective means to ensure that nesting birds are not
adversely affected during construction activities compared to arbitrarily limiting construction
noise levels without considering existing ambient noise levels and accounting for tolerance of
locally nesting to ambient noise. If existing ambient noise levels in suitable nesting habitat are
3. Responses to Comments
OCSD Biosolids Master Plan 3-4 ESA / 150626
Final Program Environmental Impact Report May 2018
greater than 60 dBA, exposure to additional construction noise that does not significantly increase
ambient levels may not disturb this nesting activity. The presence of a qualified biological
monitor provides the ability to determine if nesting birds are actually being disturbed, and is more
practical than specifying an arbitrary noise threshold.
Comment 3-C
The comment states that indirect impacts to biological resources from stormwater runoff and/or
hazardous materials were not analyzed in the draft PEIR. Due to the diverse number of species
that use the Santa Ana River and Huntington Beach Wetlands for nesting and foraging, and the
program’s proximity to a California least tern/western snowy plover colony, the Department
requests that the Final PEIR include an analysis and discussion of whether or not impacts to
biological resources could result from potential storm water impacts. The comment recommends
the following mitigation measure be included in the Final PEIR: “All surface runoff generated
from program activities shall be captured on site and diverted away from Huntington Beach
Wetlands”.
Response 3-C
As discussed in Section 3.8 Hydrology and Water Quality on page 3.8-12, OCSD’s standard
practice is to capture runoff within each treatment plant site and deliver the runoff to the onsite
wastewater treatment system for treatment. Therefore, stormwater runoff increases due to the
implementation of the proposed program would not impact the adjacent Santa Ana River or
Talbert Marsh.
Comment 3-D
The comment states that it is unclear if long-term indirect impacts to wildlife inhabiting
surrounding open space could occur due to artificial lighting associated with program operation.
The comment requests that the Final PEIR discuss and analyze lighting impacts on biological
resources and require that all program-related temporary and permanent lighting adjacent to
native habitat utilize the lowest illumination necessary for human safety and shield/direct the
lighting away from Talbert Marsh and the Santa Ana River.
Response 3-D
Currently, the program site includes visual barriers separating the proposed facilities from Talbert
Marsh and the Santa Ana River. These visual barriers include vegetation and/or walls. As
discussed in the Final PEIR in Section 3.1, the program could introduce additional sources of
lighting. The proposed lighting would be for operational and security purposes. The level of
lighting would be similar to the operational and security lighting that currently exists at Plant No.
2. Mitigation measures are included to ensure that lighting does not affect adjacent areas such as
the Talbert Marsh and the Santa Ana River. These measures include complying with the City of
Huntington Beach’s existing and future lighting ordinances as well as shielding and directing
lighting downward to avoid light intrusion to the surrounding uses. The implementation of the
mitigation measures would reduce potential indirect impacts to biological resources within
Talbert Marsh and the Santa Ana River.
3. Responses to Comments
OCSD Biosolids Master Plan 3-5 ESA / 150626
Final Program Environmental Impact Report May 2018
Comment 3-E
The comment states that the proposed program has the potential to increase the density of
American crows in the program vicinity as a result of food waste from construction workers. The
CDFW is concerned that program-related increases in crows during construction could impact
nesting/foraging species in the marshes, particularly California Least Tern and Western Snowy
Plover productivity at the nearby Huntington State Beach nest site. The comment states that there
is a direct correlation between the density of crows and the availability of human-generated food
and trash; therefore, the comment recommends that the Final PEIR include an analysis and
discussion of the potential of the program to attract crows which could prey upon the nearby
California Least Tern/Western Snowy Plover colony. The comment recommends the following
mitigation measure be included in the Final PEIR: “On-site workers shall store food and trash
such that it is inaccessible to crows. Food and trash shall be removed from the construction site
on a daily basis. Waste management practices shall be monitored throughout construction
activities.”
Response 3-E
Construction activities associated with the proposed program would occur over approximately 20
years. Construction activities related to various programs within Plant No. 1 and Plant No. 2 have
occurred for many years. OCSD’s standard practice is to include construction specifications that
include requirements for housekeeping, rubbish control and sanitation. To date, there have not
been issues related to increases in American crows due to food and trash. Each construction
program associated with the program would include similar requirements. They include keeping
the worksite and other areas used in a neat and clean condition, and free from any accumulation
of rubbish and debris. Contractors are required to dispose of all rubbish and waste materials of
any nature generated on the work sites and to regularly collect and dispose of such materials and
waste. The implementation of these standard practices would reduce potential increases of the
American crow population in the program vicinity, and therefore, would not adversely impact
nesting/foraging species in the marshes, particularly California Least Tern and Western Snowy
Plover productivity at the nearby Huntington State Beach nest site.
Comment 3-F
The comment thanks OCSD for the opportunity to comment on the Draft PEIR and provides a
CDFW contact and provides references to the background information on biological species
within the program area in previous comments.
Response 3-F
The comment is noted for the record. No response is required because there are no specific
comments on the contents in the Draft PEIR.
3. Responses to Comments
OCSD Biosolids Master Plan 3-6 ESA / 150626
Final Program Environmental Impact Report May 2018
Letter 4: South Coast Air Quality Management District
(SCAQMD)
Comment 4-A
The comment summarizes the program description of the proposed program components.
Response 4-A
No response is required because there are no specific comments on the contents in the Draft
PEIR.
Comment 4-B
The comment summarizes the significance determinations of the proposed program in regards to
air quality and emissions. The comment then states that the SCAQMD has comments on the air
quality methodology of the Draft PEIR and provides reference to an attachment to the comment
letter. The comment then requests that OCSD provide SCAQMD with written responses to all
comments on the Final PEIR before program certification. The comment provides a staff contact
number for questions or concerns.
Response 4-B
The comment is noted and saved in the program record. No response is required because there are
no specific comments on the contents in the Draft PEIR.
Comment 4-C
The comment states that based on a review of Table 2-4 in the Draft PEIR, SCAQMD staff found
that there is a reasonable possibility that construction activities of later-phase biosolids facilities
could overlap with operation of earlier-phase facilities. In the event an overlapping construction
and operation scenario is reasonably foreseeable, OCSD should analyze a scenario where
construction activities overlap with operational activities, unless OCSD expressly prohibits
overlapping construction and operational activities. The comment recommends that OCSD
identify the overlapping years among the nine programs, combine construction emissions with
operational emissions, and compare the combined emissions to SCAQMD’s air quality CEQA
operational thresholds of significance to determine the level of significance in the Final PEIR.
Response 4-C
In order to evaluate the overlap of construction and operational emissions, the following
information will be added to Section 3.2.3 of the Draft PEIR under Impact 3.2 -2 starting on 3.2-
28.
Construction and Operational Emissions Overlap
Because the program will be implemented in phases, there is a reasonable possibility that
construction activities of later phase biosolids facilities could overlap with operation of
3. Responses to Comments
OCSD Biosolids Master Plan 3-7 ESA / 150626
Final Program Environmental Impact Report May 2018
earlier phase facilities. In order to determine the combined significance of these activities, the
construction and operational activities are combined and compared to the SCAQMD’s
operational threshold.
Operational activities would begin with the construction of the Interim Food Waste Receiving
Facility by 2020. This would increase daily truck activities by 8 daily trips. There would be
no new flare operations, new natural gas usage, nor new area source emissions as the food
waste receiving facility is strictly tanks and electric pumps. Total new trips at buildout in
2038 would be 34. Therefore, between 2020 and 2038, total operational emissions would
represent approximately 24 % of the program’s total mobile source emissions.
Additionally, maximum daily construction emissions used a default 2018 aggregate truck
fleet to determine emissions from haul trucks. Because trucks used to haul debris from
construction waste and deliver construction equipment would be contracted, the default fleet
mix would change with each subsequent year. Therefore, emissions from the aggregate truck
fleet in 2021 (for a new program within the master plan beginning in 2021) would differ from
the emissions for the aggregate fleet mix for the max year 2018. Therefore, in order to
accurately predict haul and vendor emissions future construction activities, the emissions for
haul and vendor trucks have been adjusted accordingly. Calculation assumptions and
calculations are included in Attachment 2. Table 3.2-7A shows the unmitigated combined
construction and operational emissions. As shown, the proposed program would exceed the
SCAQMD’s daily regional significance threshold for NOx. Therefore, construction phase
emissions for NOx would be significant without Mitigation Measure AQ-1.
TABLE 3.2-7A
PROPOSED PROGRAM UNMITIGATED CONSTRUCTION AND OPERATIONAL EMISSIONS
Emissions Source
Estimated Emissions (lbs/day)
ROG NOX CO SO2 PM10 PM2.5
2021 Combined Emissions
Operational Emissions <1 3 1 <1 <1 <1
Construction Onsite & Worker 17 175 116 0.21 21 13
Construction Haul & Vendor 1 36 34 <1 1 <1
2038 Combined Emissions
Operational Emissions <1 11 5 <1 1 1
Construction Onsite & Worker 17 175 116 <1 21 13
Construction Haul & Vendor 1 16 33 <1 <1 <1
2021 Total Combined Emissions 18 213 151 <1 22 13
2038 Total Combined Emissions 18 201 154 <1 22 14
Regional Significance Threshold 55 55 550 150 150 55
Significant Impact? No Yes No No No No
SOURCE: ESA Modeling 2018 (based on Attachment 2)
3. Responses to Comments
OCSD Biosolids Master Plan 3-8 ESA / 150626
Final Program Environmental Impact Report May 2018
The following information will be added to Section 3.2.3 of the Draft PEIR under Impact 3.2-2
starting on 3.2-29.
Construction and Operational Emissions Overlap
With the implementation of mitigation measure AQ-1, the proposed program’s maximum
daily construction and operational emissions would be reduced to below regulatory thresholds
as shown in Table 3.2-8A.
TABLE 3.2-8A
PROPOSED PROGRAM MITIGATED CONSTRUCTION AND OPERATIONAL EMISSIONS
Emissions Source
Estimated Emissions (lbs/day)
ROG NOX CO SO2 PM10 PM2.5
2021 Combined Emissions
Operational Emissions <1 3 1 <1 <1 <1
Construction Onsite & Worker 4 10 99 <1 13 6
Construction Haul & Vendor 1 36 34 <1 1 <1
2038 Combined Emissions
Operational Emissions <1 11 5 <1 1 1
Construction Onsite & Worker 4 10 99 <1 13 6
Construction Haul & Vendor 1 16 33 <1 <1 <1
2021 Total Combined Emissions 5 49 134 <1 14 6
2038 Total Combined Emissions 5 37 138 <1 15 7
Regional Significance Threshold 55 55 550 150 150 55
Significant Impact? No No No No No No
SOURCE: ESA Modeling 2018 (based on Attachment 2)
Based on the reduction of the total NOx emissions with the implementation of Mitigation
Measure AQ-1, impacts related to a violation of air quality standards from combined
construction and operational activities associated with the proposed program would be less
than significant.
Comment 4-D
The comment states that SCAQMD should be identified as a Responsibly Agency for the
proposed program because the SCAQMD will provide permits. The comment provides the
following permits and compliance requirements that the proposed program is subject to:
a) The proposed excavations at Plant No. 1 and No. 2 will require a SCAQMD Rule 1166 –
VOC Contaminated Soil Excavation Plan, if VOC contaminated soil is expected to be
encountered during the excavation activities, and/or may be subject to SCAQMD Rule 1466
if the soil contains other toxics.
b) The proposed demolition of structures will be subject to SCAMQD Rule 1403 – Asbestos
Emissions from Demolition/Renovation Activities.
3. Responses to Comments
OCSD Biosolids Master Plan 3-9 ESA / 150626
Final Program Environmental Impact Report May 2018
c) The proposed construction of the interim food waste facility with 250 wet tons per day
capacity will require complete and timely applications for permit to construct and operate.
Any grinders and separators that are not part of the processing system may also need their
own permits.
d) The proposed construction of any odor control treatment systems at the interim food waste
facility will require complete and timely applications for permits to construct and operate.
e) The proposed alteration/modification of the existing food waste facility at Plant No. 2 will
require complete and timely applications for permits to construct and operate. Any grinders
and separators that are not part of the processing system may also need their own permits.
f) The proposed construction or alteration of any odor control treatment systems at the modified
Plant No. 2 will require complete and timely applications for permit to construct and operate.
The comment then provides a contact number for the SCAQMD Engineering and Permitting
staff.
Response 4-D
As discussed in Section 3.2 Air Quality, the SCAQMD is primarily responsible for planning,
implementing and enforcing air quality standards within the South Coast Air Basin. This includes
the review and approval/denial of permits under their jurisdiction. According to CEQA
Guidelines Section 15381, a “’Responsible agency’ means a public agency, other than the lead
agency, which has the responsibility for carrying out or approving a program. For the purposes of
CEQA, the term ‘responsible agency’ includes all public agencies other than the lead agency
which have discretionary approval power over the program.” Because the SCAQMD has
jurisdiction over several permits that may be required for the individual programs under the
Master Plan, the SCAQMD should be considered a Responsible Agency with respect to the
Program. SCAQMD will be identified as a Responsible Agency for the Program.
Comment 4-E
The comment states that the Final PEIR should discuss how OCSD will comply with applicable
SCAQMD rules and regulations, including, but not limited to, the following:
a. Rule 201: Permit to Construct
b. Rule 203: Permit to Operate
c. Rule 212: Standards for Approving Permits and Issuing Public Notice
d. Rule 401: Visible Emissions
e. Rule 402: Nuisance
f. Rule 403: Fugitive Dust
g. Rule 1166: Volatile Organic Compound Emissions from Decontamination of Soil
h. Regulation 13: New Source Review
i. Rule 1401: New Source Review of Toxic Air Contaminants
j. Rule 1403: Asbestos Emissions from Demolition/Renovation Activities
k. Regulation 30: Title V Permits
3. Responses to Comments
OCSD Biosolids Master Plan 3-10 ESA / 150626
Final Program Environmental Impact Report May 2018
The comment provides common odor management methods and discusses potential
environmental issues with these methods. The comment states that if specific odor management
methods that contribute to air quality are used then the Final PEIR should calculate the
operational emissions, or demonstrate that the products used for proposed program construction
and operations will have no adverse environmental impacts because the formulations will be free
of toxic compounds, VOC, and fragrances.
Response 4-E
The program is required to comply with all applicable laws, regulations and administrative
mandates, including rules adopted by the SCAQMD, as discussed in the Draft PEIR on page 3.2-
13. The commenter identified additional rules, and they are discussed below. A description of
how the program will comply with the rules cited in the comment is addressed below:
Discussion of Rules 201, 203, and 212 are added to the Draft PEIR as follows. The Program will
comply with these rules by submitting the appropriate applications for construction and operation
of new emissions sources in a timely manner prior to the start of construction or operation
activities. Permits to construct and operate were identified in the Draft PEIR on page 2-32.
Activities covered under the permits will not begin until a permit has been approved by the
SCAQMD.
Rule 401 is discussed in the Draft PEIR, and the Program will comply with this rule during
construction by ensuring all equipment is properly maintained in accordance with the
manufacturer’s standards. During operation, the Program will comply with this rule through the
implementation of filtration and scrubber units for odor and flaring operations to reduce or
eliminate visible emissions in accordance with Rule 401.
Rule 402 is discussed in the Draft PEIR, and the Program will comply with this rule by
containing sources of odors, and when necessary, providing appropriate odor treatment.
Implementation of mitigation measure AQ-3, which ensures contractors promptly remove
salvaged/demolished equipment from the treatment plant, will also reduce objectionable odors
associated with the Program.
Rule 403 is discussed in the Draft PEIR, and the Program will comply with this rule by
implementing fugitive dust controls and best management practices, such as the application of
water and other applicable measures as listed in Rule 403.
Rule 1166 is added to the Draft PEIR as follows. As discussed in Section 3.7 Hazards and
Hazardous Materials in the Draft PEIR, Plant No. 1 has one open LUST cleanup site.
Construction activities associated with the proposed Collections Yard Relocation on Plant No. 1
could encounter contaminated soil during excavation. The Program will comply with this rule by
evaluating the VOC content of all soils that will be excavated under the Program and preparing a
VOC Contaminated Soil Mitigation Plan for any soils containing VOC concentrations greater
than 50 ppm (“VOC Contaminated Soil”). The VOC Contaminated Soil Mitigation Plan will
outline measures to minimize VOC emissions to the atmosphere during excavation and
subsequent handling of VOC Contaminated Soil. OCSD shall submit the Contaminated Soil
3. Responses to Comments
OCSD Biosolids Master Plan 3-11 ESA / 150626
Final Program Environmental Impact Report May 2018
Mitigation Plan for SCAQMD’s approval before beginning excavation of any VOC
Contaminated Soils. During excavation activities near the LUST site, the Program will also
provide notification of excavation dates to the SCAQMD and monitor for VOC emissions as
outlined in Rule 1166. The Program will comply with all applicable handling and removal
requirements identified in Rule 1166 when excavating and handling VOC Contaminated Soils.
Rule 1401 is added to the Draft PEIR as described below. As stated in the Draft PEIR on page
3.2-34, the operation of the program includes the continued use of chemicals and the flaring of
gases associated with the processing of biosolids. Additionally, the onsite CenGen facility could
result in continued toxic air contaminant (TAC) emissions. The chemicals and processes
associated with these operations already occur onsite and are permitted to the extent SCAQMD
deems appropriate. Therefore, the implementation of the Program is not anticipated to introduce
new sources of TACs. However, should the increase in facility throughput exceed the currently
permitted levels, the Program will be required to apply for a new or updated permit to operate
using the new parameters as outlined under Regulation II, Lists and Criteria Identifying
Information Required of Applicants Seeking a Permit to Construct from the South Coast Air
Quality Management District. Because the proposed program would not introduce new sources
of TACs, the proposed program would not be required to comply directly with Rule 1401 – New
Source Review of Toxic Air Contaminants.
Rule 1403 is added to the Draft PEIR as described below. As discussed in Section 3.7 Hazards
and Hazardous Materials in the Draft PEIR, based on the age of the structures at Plant No. 2,
there is a potential for asbestos to be located on site. The Program will comply with this rule by
conducting an initial survey of the structures to be demolished in order to determine the presence
or absence of asbestos following the guidelines outlined in Rule 1403. Should asbestos be found
in the facilities to be demolished, the SCAQMD shall be notified as outlined in Rule 1403.
Asbestos shall be removed from the facility to be demolished before demolition commences
following the appropriate removal and handling procedures detailed in Rule 1403.
Regulation VIII governs the pre-construction review requirements for new, modified, or
relocated facilities. The Program will comply with this regulation through air quality analysis
provided in the Draft PEIR. If OCSD determines that there are new emissions or emissions that
are in addition to those identified in the PEIR, then OCSD will provide subsequent air quality
analysis for the individual programs associated with the proposed program. These additional
analyses would occur prior to the initiation of the individual program construction.
Regulation XXX is the air pollution control permit system required to impleme nt the federal
Operating Permit Program as required by Title V of the federal Clean Air Act as amended in
1990. The proposed modifications and improvements to the OCSD facility that are part of the
Biosolids Master Plan are not subject to Title V because the proposed operations of the facilities
would not increase stationary emissions, and therefore, would not be required to comply with this
regulation.
With respect to odor management methods, Section 3.2.3 of the PEIR, under Impact 3.2-5, page
3.2-38, states that “Source separated organics (SSO or food waste) odors can result from
3. Responses to Comments
OCSD Biosolids Master Plan 3-12 ESA / 150626
Final Program Environmental Impact Report May 2018
volatilization of nitrogen and sulfur rich organic compounds that are common in many types of
food wastes. Therefore, the proposed program was designed to implement odor control treatment
technologies (carbon canisters) in order to treat foul air in the SSO tanks. The activated carbon
may serve as a passive odor control system as the tanks are filled and drawn down.” The passive
odor control systems associated with the closed SSO system would not result in additional
operational emissions.
In addition, the PEIR states: “Further, odor control systems are being implemented in the
proposed [Digester Feed Facility (DFF)], which blends primary sludge with thickened waste
activated sludge. These odor control facilities would be implemented within facility processes
where necessary to reduce potential odor impacts.” While the exact nature of the odor control
systems for the DFF have not yet been identified, if the odor system requires additional
permitting or results in additional operational emissions, OCSD will ensure these issues are
addressed in subsequent environmental documentation prior to permit approval.
The following rules and regulations are hereby included in Section 3.2.2 Regulatory Framework
under the SCAQMD’s Rules and Regulations section starting on page 3.2-13.
Regulation II – Lists and Criteria Identifying Information Required of Applicants
Seeking a Permit to Construct from the South Coast Air Quality Management District:
This regulation identifies information required of applicants seeking permits to construct air
pollution sources and requires submission of such information before an application can be
determined to be complete.
Rule 201 – Permit to Construct: This rule states that a person shall not build, erect,
install, alter or replace any equipment or agricultural permit unit, the use of which may
cause the issuance of air contaminants or the use of which may eliminate, reduce or
control the issuance of air contaminants without first obtaining written authorization for
such construction from the Executive Officer. A permit to construct shall remain in effect
until the permit to operate the equipment or agricultural permit unit for which the
application was filed is granted or denied, or the application is canceled.
Rule 203 – Permit to Operate: This rule states that:
A) A person shall not operate or use any equipment or agricultural permit unit, the
use of which may cause the issuance of air contaminants, or the use of which may
reduce or control the issuance of air contaminants, without first obtaining a written
permit to operate from the Executive Officer or except as provided in Rule 202.
B) The equipment or agricultural permit unit shall not be operated contrary to the
conditions specified in the permit to operate.
Rule 212 – Standards for Approving Permits: This rule identifies the standards that
will be used by the SCAQMD to approve or deny a permit to construct or operate.
Regulation XI – Source Specific Standards: Regulation XI sets emissions standards for
specific sources. The following is a list of rules which may apply to the proposed program:
Rule 1166 – Volatile Organic Compound Emissions from Decontamination of Soil:
This rule sets requirements to control the emission of Volatile Organic Compounds
(VOC) from excavating, grading, handling and treating VOC contaminated soil as a
3. Responses to Comments
OCSD Biosolids Master Plan 3-13 ESA / 150626
Final Program Environmental Impact Report May 2018
result of leakage from storage or transfer operations, accidental spillage, or other
deposition.
Regulation XIV – Toxics and Other Non-Criteria Pollutants: Regulation XIV sets
requirements for new permit units, relocations, or modifications to existing permit units
which emit toxic air contaminants or other non-criteria pollutants. The following is a list of
rules which may apply to the proposed program:
Rule 1401 – New Source Review of Toxic Air Contaminants: This rule specifies limits
for maximum individual cancer risk (MICR), cancer burden, and noncancer acute and
chronic hazard index (HI) from new permit units, relocations, or modifications to existing
permit units which emit toxic air contaminants listed in Table I. The rule establishes
allowable risks for permit units requiring new permits pursuant to Rules 201 or 203.
Rule 1403 – Asbestos Emissions from Demolition/Renovation Activities: The purpose
of this rule is to specify work practice requirements to limit asbestos emissions from
building demolition and renovation activities, including the removal and associated
disturbance of asbestos-containing materials (ACM). The requirements for demolition
and renovation activities include asbestos surveying, notification, ACM removal
procedures and time schedules, ACM handling and clean-up procedures, and storage,
disposal, and landfilling requirements for asbestos-containing waste materials (ACWM).
All operators are required to maintain records, including waste shipment records, and are
required to use appropriate warning labels, signs, and markings.
Regulation XIII – New Source Review: This regulation sets forth pre-construction review
requirements for new, modified, or relocated facilities, to ensure that the operation of such
facilities does not interfere with progress in attainment of the national ambient air quality
standards, and that future economic growth within the South Coast Air Quality Management
District (District) is not unnecessarily restricted. The specific air quality goal of this
regulation is to achieve no net increases from new or modified permitted sources of
nonattainment air contaminants or their precursors.
In addition to nonattainment air contaminants, this regulation will also limit emission
increases of ammonia, and Ozone Depleting Compounds (ODCs) from new, modified or
relocated facilities by requiring the use of Best Available Control Technology (BACT).
Letter 5: Orange County Health Care Agency
Comment 5-A
The comment explains that the Orange County Solid Waste Local Enforcement Agency (LEA) is
responsible for enforcing State solid waste regulations.
Response 5-A
The comment is noted and saved in the program record. No response is required because there are
no specific comments on the contents in the Draft PEIR.
Comment 5-B
The comment states that the OCSD plant operations appear to fall within the “Excluded
Activities” of the California Solid Waste Regulations and quotes various definitions as described
3. Responses to Comments
OCSD Biosolids Master Plan 3-14 ESA / 150626
Final Program Environmental Impact Report May 2018
in the California Code of Regulations, Title 14, Section 17896.6, Excluded Activities. The
comment then advises OCSD that Excluded Activities do not preclude the LEA from inspecting
plant operations. The comment requests that updates on the proposed program be provided in the
future and provides a contact number for questions.
Response 5-B
The proposed Interim and Ultimate Food Waste Receiving Facility will receive pre-processed
food waste as a slurry. The slurry is proposed to be delivered by truck in leak-proof containers.
The slurry would be pumped through a hose that is connected directly to the side of the holding
tanks. From the holding tanks, the food waste is fed into the digesters.
The commenter states that solid waste would be received at the facilities. The commenter is
technically correct. The food waste slurry is classified as a solid waste. However, the proposed
processing of the food waste at Plant No. 2 would be exempt from CalRecycle’s regulations. In
accordance with California Code of Regulation, Title 14, Sections 17403.1 (a)(8) and 17896.6
(a)(1), a Publicly Owned Treatment Works (POTW) like OCSD is exempt from CalRecycle’s
transfer/storage/processing permits when it receives vehicle-transported solid waste material for
the purpose of anaerobic co-digestion with POTW Treatment Plant wastewater. OCSD will work
closely with OCHCA (LEA) and CalRecycle during the planning, construction, and operation of
the proposed food waste processing facilities at Plant No. 2. In addition, OCSD will be required
to work with Environmental Protection Agency (EPA) Region 9 and the Regional Board (Region
8) to incorporate language in its draft National Pollutant Discharge Elimination System
(NPDES)/Waste Discharge Requirements (WDR) permit regarding the proposed project.
OCSD understands that the LEA could inspect the operations of the proposed facilities in the
future. As more detailed design is provided, OCSD will evaluate if the PEIR adequately addresses
the potential effects of each program. If subsequent CEQA documentation is prepared, OCSD
will provide the LEA updates related to the proposed food waste facilities.
Letter 6: Orange County Transportation Authority
Comment 6-A
The comment requests that the program name for “I-405, New I-405 South Entrance” be changed
to “I-405 Improvement Program”, and that the program description be changed to read
“Improvements to I-405 and Euclid/Ellis interchange” (page 3-3, Table 3-2).
3. Responses to Comments
OCSD Biosolids Master Plan 3-15 ESA / 150626
Final Program Environmental Impact Report May 2018
Response 6-A
To accurately reference the I-405 project, the eighth item in Table 3-2 on page 3-3 of the Draft
PEIR is revised as follows:
I-405, New I-405
Improvement Program South
Entrance
Plant No. 1 Wastewater Treatment
Facilities
Public Right-of-way
improvements to I-405 south
entrance along Ellis Avenue
Improvements to I-405 and
Euclid/Ellis interchange
Comment 6-B
The comment requests that “Orange County Transportation Agency” be revised to “Orange
County Transportation Authority” (page 3.11-1).
Response 6-B
To accurately reference the Orange County Transportation Authority, the first sentence of the last
paragraph on page 3.11-1 of the Draft PEIR is revised as follows:
Beach Boulevard (SR 39) is an eight lane north-south principal arterial designated as a
“Smart Street corridor” by the Orange County Transportation Agency Authority.
Comment 6-C
The comment requests that Hamilton Avenue/Victoria Street is defined as a four-lane primary
arterial in Huntington Beach and a four-lane secondary arterial extending east to SR-55 in the
City of Costa Mesa (page 3.11-3).
Response 6-C
This comment requests that the correct roadway classification is provided for the Hamilton
Avenue/Victoria Street segment. The fifth paragraph on page 3.11-3 of the Draft PEIR is revised
as follows:
Hamilton Avenue/Victoria Street is a four-lane primary major arterial in Huntington Beach
and a four-lane secondary primary arterial extending east west to SR-55 in the City of Costa
Mesa.
Comment 6-D
The comment states that there is currently no bike path along the Santa Ana River adjacent to
Plant No. 1, but rather a “well utilized soft-surface county-designated Riding and Hiking Trail”.
A paved bike path is provided on the east bank of the Santa Ana River and adjacent to Plant No.
1, and is on the west bank of the Santa Ana River adjacent to Plant No. 2. Additionally, an all-
weather paved shared-use path connecting the Santa Ana River Trail and Brookhurst exists along
the southern edge of Plant No. 2.
3. Responses to Comments
OCSD Biosolids Master Plan 3-16 ESA / 150626
Final Program Environmental Impact Report May 2018
Response 6-D
This comment provides a correction to the reference to the Santa Ana River Bike Path. The last
sentence on page 3.11-4 is revised as follows:
The Santa Ana River Bike Path is located on the east side of the Santa Ana River adjacent to
Plant No. 1 and the west and east sides of the Santa Ana River adjacent to Plant No. 1 and
Plant No. 2.
Comment 6-E
The comment requests that “Congestion Management Plan” be revised to “Congestion
Management Program” (page 3.11-5).
Response 6-E
This comment requests that the PEIR correctly reference the Congestion Management Program.
The third sentence in the second paragraph on page 3.11-5 is revised as follows:
The purpose of the state-mandated Congestion Management Program Plan (CMP) is to
monitor roadway congestion and assess the overall performance of the region’s transportation
system.
Comment 6-F
The comment explains that “Bicycle lanes” refer to one type of bikeway classification and does
not encompass all bicycle facilities such as off-street Class I bikeways described on page 3.11-4.
The comment recommends modifying the terminology to illustrate impacts will not affect
“bicycle facilities” instead of the more specific “bicycle lanes” (page 3.11-14).
Response 6-F
To correct the reference to bicycle lanes to bicycle facilities, the first, second and third paragraphs
on page 3.11-14 of the Draft PEIR are revised as follows:
Construction
Construction trucks and employee vehicles associated with the proposed program would interact
with public transportation vehicles as well as bicyclists on the roadway system in the program
vicinity, but would not alter the physical configuration of the existing bus routes or stops or
bicycle facilities lanes. While construction vehicles will utilize existing roadways, these program
vehicles would not impact the use of public transportation or bicycle facilities lanes; and
therefore, no impact on existing adopted policies, plans or programs or a reduction of safety in
using public transportation or bicycle facilities lanes would occur during construction activities.
Operation
Operational trips associated with food waste trucks would interact with public transportation
vehicles as well as bicyclists on the roadway system in the program vicinity, but would not
3. Responses to Comments
OCSD Biosolids Master Plan 3-17 ESA / 150626
Final Program Environmental Impact Report May 2018
alter the physical configuration of the existing bus routes or stops or bicycle facilities lanes.
While the food waste trucks during operational activities will utilize existing roadways, these
program vehicles would not impact the use of public transportation or bicycle facilities lanes; and
therefore, no impact on existing adopted policies, plans or programs or a reduction of safety in
using public transportation or bicycle facilities lanes would occur.
As future growth in the program vicinity occur, development programs as well as roadway
and pipeline improvements could impact public transportation bus stops and bicycle facilities
lanes during construction activities. These potential cumulative impacts would be significant.
Because the proposed construction and operational activities would not impact the use of
public transportation or bicycle facilities lanes and would have no impact on existing adopted
policies, plans or programs or a reduction of safety in using public transportation or bicycle
facilities lanes, the program would not contribute to potential cumulative impacts on public
transportation or bicycle facilities lanes.
Comment 6-G
The comment recommends that the Final PEIR include language disclosing if construction
activities will require any short-term or long-term closures.
Response 6-G
The proposed construction and operational activities associated with the proposed program would
include vehicles traveling along roadways to access Plant No. 1 or Plant No. 2. These vehicles,
similar to other vehicles utilizing the public street system, have the potential to interact with
existing public transit, bicycle and pedestrian facilities. Because all construction activities would
occur within the treatment plant sites, no short-term or long-term closures along any existing
street or trails/paths would occur.
Comment 6-H
The comment states that if the program has any impacts to nearby bus stops, OCSD must
coordinate with OCTA to employ measures to reduce potential transit service disruptions. The
comment also recommends that OCSD keep OCTA informed of any potential bus stop
interruptions or street closures that may require detours. The comment then provides a contact
number.
Response 6-H
The proposed program would not result in construction or operational activities that would
disrupt bus stops or disrupt transit service in the program area.
3. Responses to Comments
OCSD Biosolids Master Plan 3-18 ESA / 150626
Final Program Environmental Impact Report May 2018
Letter 7: Gae Brummett
Comment 7-A
The comment requests that Gae Brummett be included in OCSD’s mailing list to stay informed of
how to control local programs within Huntington Beach.
Response 7-A
The comment is noted and saved in the program record. No response is required because there are
no specific comments on the contents in the Draft PEIR.
Letter 8: Patrick Osullivan
Comment 8-A
The comment states that the Southeast neighborhood of Huntington Beach is being adversely
impacted by truck traffic, dust, noise and other adverse conditions due to the cumulative effect of
multiple programs in the area: Poseidon, AES, Ascon, and Shopoff. The comment states the “the
unneeded Poseidon should be eliminated from the cumulative programs list before any Statement
of Overriding Considerations is certified”.
Response 8-A
The impacts identified in the Biosolids Master Plan Draft PEIR will be reduced to less than
significant after the implementation of the proposed mitigation measures. There are no impacts
that would remain significant and therefore, no Statement of Overriding Considerations will be
required with the proposed Biosolids Master Plan. The cumulative analysis provided in the Draft
PEIR includes references to the Poseidon Desalination Plant as a known program that is currently
in the planning process, but not approved. This Draft PEIR appropriately includes the Poseidon
Desalination Plant as a cumulative program. Section 3 of the Draft PEIR includes an evaluation
of effects associated with the implementation of cumulative programs and also includes a
discussion of the program’s contribution toward the cumulative impacts.
OCSD Biosolids Master Plan 4-1 ESA / 150626
Final Program Environmental Impact Report May 2018
CHAPTER 4
Corrections and Additions to the Draft PEIR
This chapter contains a compilation of revisions made to the text of the Draft PEIR by OCSD as
the Lead Agency, in response to the comments received during the 45-day public review period
as well as minor edits. All revisions are previously introduced in Chapter 3 of this Final PEIR but
are summarized here for convenience of the reader. Where the responses indicate additions or
deletions to the text of the Draft PEIR, additions are indicated in underline and deletions in
strikeout.
3.0 Environmental Setting, Impacts and Mitigation
Measures
Page 3-3
To accurately reference the I-405 project, the eighth item in Table 3-2 on page 3-3 of the Draft
PEIR is revised as follows:
I-405, New I-405
Improvement Project South
Entrance
Plant No. 1 Wastewater Treatment
Facilities
Public Right-of-way
improvements to I-405 south
entrance along Ellis Avenue
Improvements to I-405 and
Euclid/Ellis interchange
3.2 Air Quality
Page 3.2-13
The following additions to rules and regulations is hereby included in Section 3.2.2 Regulatory
Framework under the SCAQMD’s Rules and Regulations section starting on page 3.2-13.
Regulation II – Lists and Criteria Identifying Information Required of Applicants
Seeking a Permit to Construct from the South Coast Air Quality Management District:
This regulation identifies information required of applicants seeking permits to construct air
pollution sources and requires submission of such information before an application can be
determined to be complete.
Rule 201 – Permit to Construct: This rule states that a person shall not build, erect,
install, alter or replace any equipment or agricultural permit unit, the use of which may
cause the issuance of air contaminants or the use of which may eliminate, reduce or
control the issuance of air contaminants without first obtaining written authorization for
such construction from the Executive Officer. A permit to construct shall remain in effect
4. Corrections and Additions to the Draft PEIR
OCSD Biosolids Master Plan 4-2 ESA / 150626
Final Program Environmental Impact Report May 2018
until the permit to operate the equipment or agricultural permit unit for which the
application was filed is granted or denied, or the application is canceled.
Rule 203 – Permit to Operate: This rule states that:
A) A person shall not operate or use any equipment or agricultural permit unit, the
use of which may cause the issuance of air contaminants, or the use of which may
reduce or control the issuance of air contaminants, without first obtaining a written
permit to operate from the Executive Officer or except as provided in Rule 202.
B) The equipment or agricultural permit unit shall not be operated contrary to the
conditions specified in the permit to operate.
Rule 212 – Standards for Approving Permits: This rule identifies the standards that
will be used by the SCAQMD to approve or deny a permit to construct or operate.
Regulation XI – Source Specific Standards: Regulation XI sets emissions standards for
specific sources. The following is a list of rules which may apply to the proposed program:
Rule 1166 – Volatile Organic Compound Emissions from Decontamination of Soil:
This rule This rule sets requirements to control the emission of Volatile Organic
Compounds (VOC) from excavating, grading, handling and treating VOC contaminated
soil as a result of leakage from storage or transfer operations, accidental spillage, or other
deposition.
Regulation XIV – Toxics and Other Non-Criteria Pollutants: Regulation XIV sets
requirements for new permit units, relocations, or modifications to existing permit units
which emit toxic air contaminants or other non-criteria pollutants. The following is a list of
rules which may apply to the proposed program:
Rule 1401 – New Source Review of Toxic Air Contaminants: This rule specifies limits
for maximum individual cancer risk (MICR), cancer burden, and noncancer acute and
chronic hazard index (HI) from new permit units, relocations, or modifications to existing
permit units which emit toxic air contaminants listed in Table I. The rule establishes
allowable risks for permit units requiring new permits pursuant to Rules 201 or 203.
Rule 1403 – Asbestos Emissions From Demolition/Renovation Activities: The
purpose of this rule is to specify work practice requirements to limit asbestos emissions
from building demolition and renovation activities, including the removal and associated
disturbance of asbestos-containing materials (ACM). The requirements for demolition
and renovation activities include asbestos surveying, notification, ACM removal
procedures and time schedules, ACM handling and clean-up procedures, and storage,
disposal, and landfilling requirements for asbestos-containing waste materials (ACWM).
All operators are required to maintain records, including waste shipment records, and are
required to use appropriate warning labels, signs, and markings.
Regulation XIII – New Source Review: This regulation sets forth pre-construction review
requirements for new, modified, or relocated facilities, to ensure that the operation of such
facilities does not interfere with progress in attainment of the national ambient air quality
standards, and that future economic growth within the South Coast Air Quality Management
District (District) is not unnecessarily restricted. The specific air quality goal of this
regulation is to achieve no net increases from new or modified permitted sources of
nonattainment air contaminants or their precursors.
4. Corrections and Additions to the Draft PEIR
OCSD Biosolids Master Plan 4-3 ESA / 150626
Final Program Environmental Impact Report May 2018
In addition to nonattainment air contaminants, this regulation will also limit emission
increases of ammonia, and Ozone Depleting Compounds (ODCs) from new, modified or
relocated facilities by requiring the use of Best Available Control Technology (BACT).
Page 3.2-28
In order to evaluate the overlap of construction and operational emissions, the following
information will be added to Section 3.2.3 of the Draft PEIR under Impact 3.2 -2 starting on page
3.2-28.
Construction and Operational Emissions Overlap
Because the program will be implemented in phases, there is a reasonable possibility that
construction activities of later phase biosolids facilities could overlap with operation of
earlier phase facilities. In order to determine the combined significance of these activities, the
construction and operational activities are combined and compared to the SCAQMD’s
operational threshold.
Operational activities would begin with the construction of the Interim Food Waste Receiving
Facility by 2020. This would increase daily truck activities by 8 daily trips. There would be
no new flare operations, new natural gas usage, nor new area source emissions as the food
waste receiving facility is strictly tanks and electric pumps. Total new trips at buildout in
2038 would be 34. Therefore, between 2020 and 2038, total operational emissions would
represent approximately 24 % of the total program mobile sources.
Additionally, maximum daily construction emissions used a default 2018 aggregate truck
fleet to determine emissions from haul trucks. Because trucks used to haul debris from
construction waste and deliver construction equipment would be contracted, the default fleet
mix would change with each subsequent year. Therefore, emissions from the aggregate truck
fleet in 2021 (for a new program within the master plan beginning in 2021) would differ from
the emissions for the aggregate fleet mix for the max year 2018. Therefore, in order to
accurately predict haul and vendor emissions future construction activities, the emissions for
haul and vendor trucks have been adjusted accordingly. Calculations assumptions and
calculations are included in Attachment 2. Table 3.2-7A shows the unmitigated combined
construction and operational emissions. As shown, the proposed program would exceed the
SCAQMD’s daily regional significance threshold for NOx. Therefore, construction phase
emissions for NOx would be significant without mitigation.
TABLE 3.2-7A
PROPOSED PROGRAM UNMITIGATED CONSTRUCTION AND OPERATIONAL EMISSIONS
Emissions Source
Estimated Emissions (lbs/day)
ROG NOX CO SO2 PM10 PM2.5
2021 Combined Emissions
Operational Emissions <1 3 1 <1 <1 <1
Construction Onsite & Worker 17 175 116 0.21 21 13
Construction Haul & Vendor 1 36 34 <1 1 <1
4. Corrections and Additions to the Draft PEIR
OCSD Biosolids Master Plan 4-4 ESA / 150626
Final Program Environmental Impact Report May 2018
2038 Combined Emissions
Operational Emissions <1 11 5 <1 1 1
Construction Onsite & Worker 17 175 116 <1 21 13
Construction Haul & Vendor 1 16 33 <1 <1 <1
2021 Total Combined Emissions 18 213 151 <1 22 13
2038 Total Combined Emissions 18 201 154 <1 22 14
Regional Significance Threshold 55 55 550 150 150 55
Significant Impact? No Yes No No No No
SOURCE: ESA Modeling 2018 (based on Attachment 2)
The following information will be added to Section 3.2.3 of the Draft PEIR under Impact 3.2-2
starting on 3.2-29.
Construction and Operational Emissions Overlap
With the implementation of mitigation measure AQ-1, the proposed program’s maximum
daily construction emissions would be reduced to below regulatory thresholds as shown in
Table 3.2-8A.
TABLE 3.2-8A
PROPOSED PROGRAM MITIGATED CONSTRUCTION AND OPERATIONAL EMISSIONS
Emissions Source
Estimated Emissions (lbs/day)
ROG NOX CO SO2 PM10 PM2.5
2021 Combined Emissions
Operational Emissions <1 3 1 <1 <1 <1
Construction Onsite & Worker 4 10 99 <1 13 6
Construction Haul & Vendor 1 36 34 <1 1 <1
2038 Combined Emissions
Operational Emissions <1 11 5 <1 1 1
Construction Onsite & Worker 4 10 99 <1 13 6
Construction Haul & Vendor 1 16 33 <1 <1 <1
2021 Total Combined Emissions 5 49 134 <1 14 6
2038 Total Combined Emissions 5 37 138 <1 15 7
Regional Significance Threshold 55 55 550 150 150 55
Significant Impact? No No No No No No
SOURCE: ESA Modeling 2018 (based on Attachment 2)
Based on the reduction of the total NOx emissions with the implementation of Mitigation
Measure AQ-1, impacts related to a violation of air quality standards from combined
construction and operational activities associated with the proposed program would be less
than significant.
4. Corrections and Additions to the Draft PEIR
OCSD Biosolids Master Plan 4-5 ESA / 150626
Final Program Environmental Impact Report May 2018
Page 3.2-38
The Odor Control Master Plan (OCMP) includes technologies to reduce odor from activities
within Plant No. 1 and Plant No. 2; however, the OCSD Board of Directors has not adopted
the OCMP. Therefore, the second and third paragraphs on page 3.2-38 of the Draft PEIR are
revised to read as follows:
As described above, OCSD has prepared an OCMP for both Plant No.1 and Plant No. 2.
New facilities including carbon canisters associated with the Interim and Ultimate Food
Waste Facilities and DFF were designed and will be implemented to reduce odors.
constructed in compliance with the OCMP. Further, the proposed program’s new and
updated facilities will be implemented into future updates to the OCMP.
Therefore, with the implementation of the upgraded odor control system and, new odor
control systems associated with the proposed program, and compliance with the updated
OCSD OCMP, potential odor impacts to sensitive receptors would be less than
significant.
3.11 Traffic and Transportation
Page 3.11-1
To accurately reference the Orange County Transportation Authority, the first sentence of the last
paragraph on page 3.11-1 of the Draft PEIR is revised as follows:
Beach Boulevard (SR 39) is an eight lane north-south principal arterial designated as a
“Smart Street corridor” by the Orange County Transportation Agency Authority.
Page 3.11-3
This comment requests that the correct roadway classification is provided for the Hamilton
Avenue/Victoria Street segment. The fifth paragraph on page 3.11-3 of the Draft PEIR is revised
as follows:
Hamilton Avenue/Victoria Street is a four-lane primary major arterial in Huntington Beach and
a four-lane secondary primary arterial extending east west to SR-55 in the City of Costa Mesa.
Page 3.11-4
This comment provides a correction to the reference to the Santa Ana River Bike Path. The last
sentence on page 3.11-4 is revised as follows:
The Santa Ana River Bike Path is located on the east side of the Santa Ana River
adjacent to Plant No. 1 and the west and east sides of the Santa Ana River adjacent to
Plant No. 1 and Plant No. 2.
4. Corrections and Additions to the Draft PEIR
OCSD Biosolids Master Plan 4-6 ESA / 150626
Final Program Environmental Impact Report May 2018
Page 3.11-5
This comment request to correctly refer to the Congestion Management Program. The third
sentence in the second paragraph on page 3.11-5 is revised as follows:
The purpose of the state-mandated Congestion Management Program Plan (CMP) is to
monitor roadway congestion and assess the overall performance of the region’s
transportation system.
Page 3.11-14
To correct the reference to bicycle lanes to bicycle facilities, the first, second and third paragraphs
on page 3.11-14 of the Draft PEIR are revised as follows:
Construction
Construction trucks and employee vehicles associated with the proposed program would interact
with public transportation vehicles as well as bicyclists on the roadway system in the program
vicinity, but would not alter the physical configuration of the existing bus routes or stops or
bicycle facilities lanes. While construction vehicles will utilize existing roadways, these program
vehicles would not impact the use of public transportation or bicycle facilities lanes; and
therefore, no impact on existing adopted policies, plans or programs or a reduction of safety in
using public transportation or bicycle facilities lanes would occur during construction activities.
Operation
Operational trips associated with food waste trucks would interact with public transportation
vehicles as well as bicyclists on the roadway system in the program vicinity, but would not
alter the physical configuration of the existing bus routes or stops or bicycle facilities lanes.
While the food waste trucks during operational activities will utilize existing roadways, these
program vehicles would not impact the use of public transportation or bicycle facilities lanes; and
therefore, no impact on existing adopted policies, plans or programs or a reduction of safety in
using public transportation or bicycle facilities lanes would occur.
As future growth in the program vicinity occur, development projects as well as roadway and
pipeline improvements could impact public transportation bus stops and bicycle facilities
lanes during construction activities. These potential cumulative impacts would be significant.
Because the proposed construction and operational activities would not impact the use of
public transportation or bicycle facilities lanes and would have no impact on existing adopted
policies, plans or programs or a reduction of safety in using public transportation or bicycle
facilities lanes, the program would not contribute to potential cumulative impacts on public
transportation or bicycle facilities lanes.
OCSD Biosolids Master Plan 5-1 ESA / 150626
Final Program Environmental Impact Report May 2018
CHAPTER 5
Mitigation Monitoring and Reporting Program
CEQA Requirements
Section 15091(d) and Section 15097 of the CEQA Guidelines require a public agency to adopt a
program for monitoring or reporting on the changes it has required in the project or conditions of
approval to substantially lessen significant environmental effects. This Mitigation, Monitoring
and Reporting Program (MMRP) summarizes the mitigation commitments identified in the
OCSD Biosolids Master Plan (proposed program; BMP) Program EIR (State Clearinghouse No.
2017071026). Mitigation measures are presented in the same order as they occur in the Final
PEIR.
The columns in the MMRP table provide the following information:
Mitigation Measure(s): The action(s) that will be taken to reduce the impact to a less-than-
significant level.
Implementation, Monitoring, and Reporting Action: The appropriate steps to implement
and document compliance with the mitigation measures.
Responsibility: The agency or private entity responsible for ensuring implementation of the
mitigation measure. However, until the mitigation measures are completed, OCSD, as the
CEQA Lead Agency, remains responsible for ensuring that implementation of the mitigation
measures occur in accordance with the MMRP (CEQA Guidelines, Section 15097(a)).
Monitoring Schedule: The general schedule for conducting each task, either prior to
construction, during construction and/or after construction.
5. Mitigation Monitoring and Reporting Program
OCSD Biosolids Master Plan 5-2 ESA / 150626
Final Program Environmental Impact Report May 2018
TABLE 5-1
MITIGATION MONITORING AND REPORTING PROGRAM FOR THE OCSD BMP PROGRAM EIR
Mitigation Measures Implementation, Monitoring, and Reporting Action Responsibility Monitoring Schedule
Aesthetics
AES-1: All new permanent exterior lighting associated with proposed program
components shall be shielded and directed downward to avoid any light intrusion to
surrounding uses.
Include mitigation measure in project design
specifications.
Ensure design specifications are included in
construction contractor specifications.
Retain copies of design and contractor specifications in
project files.
Perform site inspections to verify contractor
compliance. Retain inspection records in the project
file.
OCSD;
Construction
Contractor
Before, During, and
After Construction
AES-2: Development of the proposed program and associated facilities shall comply
with existing and future lighting ordinances for the cities of Fountain Valley and
Huntington Beach.
Include mitigation measure in project design
specifications.
Ensure design specifications are included in
construction contractor specifications.
Retain copies of design and contractor specifications in
project files.
Perform site inspections to verify contractor
compliance. Retain inspection records in the project
file.
Perform periodic site inspections to ensure ongoing
compliance with future lighting ordinances. Retain
inspections records in the project file.
OCSD;
Construction
Contractor
Before, During and
After Construction
Air Quality and Greenhouse Gas Emissions
AQ-1: Mobile off-road construction equipment (wheeled or tracked) used during
construction of the individual projects of the proposed program shall meet the USEPA
Tier 4 final standards, either as original equipment or equipment retrofitted to meet the
Tier 4 final standards. A copy of each unit’s certified tier specification or model year
specification shall be available upon request at the time of mobilization of each
applicable unit of equipment.
Include mitigation measure in construction contractor
specifications.
Retain copies of contractor specifications in project
files.
Perform site inspections to verify contractor
compliance. Retain inspection records in the project
file.
OCSD;
Construction
Contractor
Before and During
Construction
5. Mitigation Monitoring and Reporting Program
OCSD Biosolids Master Plan 5-3 ESA / 150626
Final Program Environmental Impact Report May 2018
Mitigation Measures Implementation, Monitoring, and Reporting Action Responsibility Monitoring Schedule
AQ-2: When grading activities associated with the nine projects of the proposed program
occur within 50 meters of the nearest sensitive receptors, the number of scrapers active
onsite is restricted to a maximum of 5 and the number of dozers is restricted to a
maximum of 2.
Include mitigation measure in construction contractor
specifications.
Retain copies of contractor specifications in project
files.
Perform site inspections to verify contractor
compliance. Retain inspection records in the project
file.
OCSD;
Construction
Contractor
Before and During
Construction
AQ-3: OCSD shall ensure that contractors promptly remove salvaged/demolished
equipment associated with the proposed program from the treatment plants to minimize
potential odors during the removal of existing facilities. Staging areas shall not be used
to store salvaged/demolished equipment.
Include mitigation measure in construction contractor
specifications.
Retain copies of contractor specifications in project
files.
Perform site inspections to verify contractor
compliance. Retain inspection records in the project
file.
OCSD;
Construction
Contractor
Before and During
Construction
Biological Resources
BIO-1: If removal of onsite trees and vegetation associated with the proposed program
occurs during the non-nesting season (September 1 to February 14 for songbirds;
September 1 to January 14 for raptors), no nesting survey or biological monitor are
required.
If the removal of onsite trees and vegetation associated with the proposed program
occurs during the nesting season (February 15 to August 31 for songbirds; January 15 to
August 31 for raptors), a qualified biologist shall conduct a survey prior to vegetation
removal activities to determine if there are active nests within the onsite trees and
vegetation proposed for removal. If an active nest is not found, no biological monitor is
required. If active nests are detected, a minimum buffer (e.g., 300 feet for songbirds or
500 feet for raptors) around the nest shall be delineated and flagged, and no
construction activity shall occur within the buffer area until a qualified biologist
determines the nesting species have fledged and is no longer active or the nest has
failed. The buffer may be modified (i.e., increased or decreased) and/or other
recommendations proposed (e.g., a temporary soundwall) as determined appropriate by
the qualified biologist to minimize impacts. The qualified biologist shall monitor the
removal of onsite trees and vegetation. Nest buffer distance will be based on species,
specific location of the nest, the intensity of construction activities, existing disturbances
unrelated to the proposed program present in the program area, and other factors.
If grading/excavation or pile driving activities associated with the proposed program are
scheduled outside the nesting season, no nesting survey or biological monitor are
required.
If grading/excavation or pile driving activities associated with the proposed program are
scheduled during the nesting season, a qualified biologist shall conduct a survey, prior to
grading/excavation or pile driving activities, of suitable nesting habitat within 500 feet of
construction activities for the presence of nesting birds. If no active nests are detected,
no biological monitor is required. If an active nest is detected, a minimum buffer (e.g.,
300 feet for songbirds or 500 feet for raptors) around the nest shall be delineated and
Include mitigation measure in construction contractor
specifications.
Retain copies of the survey(s) in the project file.
Prepare reports to document any nesting bird species
prior to construction activities.
Perform additional survey(s) if there is a lapse of
construction activities for seven days or more.
Prepare reports to document any nesting bird species
prior to resuming construction activities.
Retain surveys and reports in the project file.
OCSD;
Construction
Contractor
Before and During
Construction
5. Mitigation Monitoring and Reporting Program
OCSD Biosolids Master Plan 5-4 ESA / 150626
Final Program Environmental Impact Report May 2018
Mitigation Measures Implementation, Monitoring, and Reporting Action Responsibility Monitoring Schedule
the active nest shall be flagged, and no construction activity shall occur within the buffer
area until a qualified biologist determines the nesting species have fledged and is no
longer active or the nest has failed. The qualified biologist shall monitor the activities of
the active nests within the buffer area. The buffer may be modified (i.e., increased or
decreased) and/or other recommendations proposed (e.g., a temporary soundwall) as
determined appropriate by the qualified biologist to minimize impacts. Nest buffer
distance will be based on species, specific location of the nest, the intensity of
construction activities, existing disturbances unrelated to the proposed program present
in the program area, and other factors.
If there is a lapse of construction activities associated with the proposed program during
the nesting season for seven days or more, an additional nesting bird survey shall be
conducted to determine if a nest is present prior to construction activities resuming. The
procedure identified above for no active nest and an active nest shall be followed.
Cultural Resources
CUL-1: Prior to start of grading or excavation activities associated with the proposed
program and within Plant No. 1 and Plant No. 2, OCSD shall retain a qualified
archaeologist meeting the Secretary of the Interior’s Professional Qualifications
Standards for archaeology (U.S. Department of the Interior 2008) to carry out all
mitigation related to archaeological resources.
Include mitigation measure in construction contractor
specifications.
Retain documentation of retaining a qualified
archaeologist in the project file.
OCSD;
Construction
Contractor
Before and During
Construction
CUL-2: Prior to start of grading or excavation activities associated with the proposed
program and within Plant No. 1 and 2, the qualified archaeologist (or an archaeologist
working under the direct supervision of the qualified archaeologist) shall conduct cultural
resources sensitivity training for all construction personnel. Construction personnel shall
be informed of the types of archaeological resources that may be encountered, the
proper procedures to be enacted in the event of an inadvertent discovery of
archaeological resources or human remains, and safety precautions to be taken when
working with archaeological monitors. OCSD shall ensure that construction personnel
are made available for and attend the training and retain documentation demonstrating
attendance.
Include mitigation measure in construction contractor
specifications.
Retain documentation demonstrating attendance of
construction personnel to cultural resources sensitivity
training.
OCSD;
Construction
Contractor
Before and During
Construction
CUL-3: Archaeological and Native American monitoring shall be conducted for grading
or excavation activities associated with the proposed program at Plant No. 1 and Plant
No. 2. Archaeological monitoring shall be conducted by an archaeologist familiar with the
types of archaeological resources that could be encountered within the program area,
and under the direct supervision of the qualified archaeologist. The frequency of
monitoring shall take into account the rate of excavation and grading activities, the
materials being excavated (native versus artificial fill soils and older versus younger
soils), and the depth of excavation. The frequency of the monitoring shall be determined
by the qualified archaeologist in consultation with the Native American monitor and in
coordination with OCSD. The Native American monitor shall be selected from a tribe that
is culturally and traditionally affiliated with the program area as indicated by the NAHC.
In the event that archaeological resources are unearthed during ground-disturbing
activities, the archaeological monitor and/or Native American monitor shall be
empowered to halt or redirect ground-disturbing activities away from the vicinity of the
discovery until OCSD, a qualified archaeologist, and a Native American monitor have
evaluated the discovery and determined appropriate treatment (as prescribed in CUL-4).
Include mitigation measure in construction contractor
specifications.
Perform site inspections to ensure compliance with
cultural sensitivity requirements.
Retain all archeological and tribal inspection forms in
the project file.
Retain copy of final archaeological report in the project
file.
OCSD;
Construction
Contractor
Before and During
Construction
5. Mitigation Monitoring and Reporting Program
OCSD Biosolids Master Plan 5-5 ESA / 150626
Final Program Environmental Impact Report May 2018
Mitigation Measures Implementation, Monitoring, and Reporting Action Responsibility Monitoring Schedule
The archaeological monitor shall keep daily logs detailing the types of activities and soils
observed, and any discoveries. After monitoring has been completed, the qualified
archaeologist shall prepare a report that details the results of monitoring for submittal to
OCSD, the South Central Coastal Information Center, and any Native American tribe
that requests a copy.
CUL-4: In the event of the unanticipated discovery of archaeological materials during
grading or excavation activities associated with the proposed program, OCSD shall
immediately cease all work activities in the area (within approximately 100 feet) of the
discovery until it can be evaluated by the qualified archaeologist. Construction shall not
resume until the qualified archaeologist has conferred with OCSD on the significance of
the resource.
In the event that preservation in place is determined to be infeasible and data recovery
through excavation is the only feasible mitigation available, an Archaeological Resources
Treatment Plan shall be prepared and implemented by the qualified archaeologist in
consultation with OCSD that provides for the adequate recovery of the scientifically
consequential information contained in the archaeological resource. OCSD shall consult
with appropriate Native American representatives in determining treatment for prehistoric
or Native American resources to ensure cultural values ascribed to the resource are
considered.
Include mitigation measure in construction contractor
specifications.
Perform site inspections to ensure compliance with
cultural sensitivity requirements.
Retain inspection forms in the project file.
Retain correspondence between archeologist and
Native American representative.
Retain a copy of Archeological Resources Treatment
Plan (if one is required) in the project file.
OCSD;
Construction
Contractor
Before and During
Construction
CUL-5: Prior to start of excavation activities associated with the proposed program that
exceed 10 feet in depth in previously undisturbed sediments, OCSD shall retain a
qualified paleontologist meeting the Society for Vertebrate Paleontology (SVP)
Standards (SVP 2010) to carry out all mitigation related to paleontological resources.
The qualified paleontologist shall be selected from the list of County of Orange certified
paleontologists.
Include mitigation measure in construction contractor
specifications.
Retain documentation of retaining a qualified
paleontologist in the project file.
OCSD;
Construction
Contractor
Before and During
Construction
CUL-6: Prior to start of excavation activities associated with the proposed program that
exceed 10 feet in depth in previously undisturbed sediments, the qualified paleontologist,
or his or her designee, shall conduct training for construction personnel regarding the
appearance of fossils and the procedures for notifying paleontological staff should fossils
be discovered by construction staff. OCSD shall ensure that construction personnel are
made available for and attend the training and retain documentation demonstrating
attendance.
Include mitigation measure in construction contractor
specifications.
Retain documentation demonstrating attendance of
construction personnel to fossil discovery training.
OCSD;
Construction
Contractor
Before and During
Construction
CUL-7: Paleontological resources monitoring shall be performed during excavation
activities associated with the proposed program that exceed 10 feet in depth in
previously undisturbed sediments by a qualified paleontological monitor (or cross-trained
paleontological/archaeological monitor) meeting the standards of the SVP 2010 under
the direction of the qualified paleontologist. The monitor shall have the authority to
temporarily halt or divert work away from exposed fossils in order to recover the fossil
specimens. The qualified paleontologist, based on observations of subsurface soil
stratigraphy and/or other factors, may increase, reduce, or discontinue monitoring in
coordination with OCSD, as warranted.
If construction or other project personnel discover any potential fossils during
construction, regardless of the depth of work, all work shall cease at that location (within
100 feet) until the qualified paleontologist has assessed the discovery and made
Include mitigation measure in construction contractor
specifications.
Retain copies of all paleontological research and
survey in the project file.
Perform site monitoring to ensure compliance with
paleontological requirements.
Retain inspection forms in the project file.
OCSD;
Construction
Contractor
Before and During
Construction
5. Mitigation Monitoring and Reporting Program
OCSD Biosolids Master Plan 5-6 ESA / 150626
Final Program Environmental Impact Report May 2018
Mitigation Measures Implementation, Monitoring, and Reporting Action Responsibility Monitoring Schedule
recommendations as to the appropriate treatment and re-assessed the depth at which
monitoring shall be required.
CUL-8: In the event of a fossil discovery by the paleontological monitor or construction
personnel associated with the proposed program, all work in the immediate vicinity of the
find shall cease. The qualified paleontologist shall evaluate the find before restarting
construction activity in the area. If it is determined that the fossil(s) is (are) scientifically
significant, the qualified paleontologist shall recover significant fossils following standard
field procedures for collecting and curating paleontological resources, as described by
the SVP (2010).
Include mitigation measure in construction contractor
specifications.
Paleontological monitoring reports and logs will be
retained in project file.
Retain fossil recovery logs in the project file.
OCSD;
Construction
Contractor
Before and During
Construction
CUL-9: If human remains are encountered during construction activities associated with
the proposed program, OCSD or its contractor shall halt work in the vicinity (within 100
feet) of the find and contact the Orange County Coroner in accordance with PRC Section
5097.98 and Health and Safety Code Section 7050.5. If the County Coroner determines
that the remains are Native American, the NAHC will be notified in accordance with
Health and Safety Code Section 7050.5, subdivision (c), and PRC Section 5097.98. The
NAHC will designate a Most Likely Descendant (MLD) for the remains per PRC Section
5097.98. Until the landowner has conferred with the MLD, OCSD shall ensure that the
immediate vicinity where the discovery occurred is not disturbed by further activity, is
adequately protected according to generally accepted cultural or archaeological
standards or practices, and that further activities take into account the possibility of
multiple burials.
Include mitigation measure in construction contractor
specifications.
Retain inspection forms in the project file.
Retain NAHC correspondence in project files, if
necessary.
OCSD;
Construction
Contractor
Before and During
Construction
Hazards and Hazardous Materials
HAZ-1: Prior to the initiation of any construction requiring ground-disturbing activities
associated with the proposed program, OCSD shall complete an environmental
assessment of the proposed site to locate the potential for soil and groundwater
contamination in the program area. The recommendations set forth in the site
assessment shall be implemented to the satisfaction of applicable agencies before and
during construction.
Include mitigation measure in construction contractor
specifications.
Retain copies of all environmental site assessments in
the project file.
OCSD;
Construction
Contractor
Before Construction
HAZ-2: If the site assessments determine that the site has contaminated soil and/or
groundwater, a Soil and Groundwater Management Plan shall be prepared that specifies
the method for handling and disposing of contaminated soil and groundwater prior to
demolition, excavation, and construction activities. OCSD shall be responsible for
ensuring implementation of the Plan in compliance with applicable regulations.
Include mitigation measure in construction contractor
specifications.
Retain copies of Soil and Groundwater Management
Plan in the project file.
Perform site inspections to verify contractor compliance
with hazardous materials.
Retain inspection forms in the project file.
OCSD;
Construction
Contractor
Before and During
Construction
Attachment 1
Roadway Traffic Noise Levels
Roadway Traffic Noise Calculations
TENS 1.1 Biosolids Final PEIR - Noise levels at 50 and 200 feet.xlsx 4/17/2018
Speed
Roadway/Segment MPH AM PM ADT ROW 50 Feet 200 Feet ROW 50 Feet 200 Feet
Brookhurst Street 50 11000 69.5 65.9 61.6 70.7 67.1 62.9
PCH 55 37000 75.8 72.2 68.0 77.0 73.5 69.2
0 0 0 ------
0 0 0 ------
0 0 0 ------
Speed
Roadway/Segment MPH AM PM ADT ROW 50 Feet 200 Feet ROW 50 Feet 200 Feet
Brookhurst Street 50 0 ------
PCH 55 0 ------
0 0 0 ------
0 0 0 ------
0 0 0 ------
Speed
Roadway/Segment MPH AM PM ADT ROW 50 Feet 200 Feet ROW 50 Feet 200 Feet
Brookhurst Street 50 0 ------
PCH 55 0 ------
0 0 0 ------
0 0 0 ------
0 0 0 ------
CNEL
Summary 50 ft. from ROW 200 ft. from ROW % of ADTProject Cumulative Project Cumulative Vehicle Type Day Eve Night Sub total
Roadway/Segment Increment Increment Increment Increment Auto 77.6%9.7%9.7%97.0%
Brookhurst Street ----Medium Truck 1.6%0.2%0.2%2.0%
PCH ----Heavy Truck 0.8%0.1%0.1%1.0%
0 ----80.0%10.0%10.0%100.0%
0 ----
0 ----
Dist 1 50
Dist 2 200
Predicted Exisiting Noise Levels Table
Roadway/Segment ROW 50 Feet 200 Feet
Brookhurst Street 70.7 67.1 62.9
PCH 77.0 73.5 69.2
0 ---
0 ---
0 ---
CNEL
Leq
Existing
Future No Project
Future With Project
Leq
Traffic Volumes
Traffic Volumes
CNEL
CNEL
CNEL
Leq
Traffic Volumes
Roadway Traffic Noise Calculations
TENS 1.1 Biosolids Final PEIR - Noise levels at 50 and 200 feet.xlsx 4/17/2018
Predicted Future Noise Levels Table
Roadway/Segment Existing
Future No
Project
Future With
Project
Project
Increment
Cumulative
Increment
Brookhurst Street 67.1 ----
PCH 73.5 ----
0 -----
0 -----
0 -----
Roadway Traffic Noise Calculations
TENS 1.1 Biosolids Final PEIR - Noise levels at 50 and 400 feet.xlsx 4/17/2018
Speed
Roadway/Segment MPH AM PM ADT ROW 50 Feet 400 Feet ROW 50 Feet 400 Feet
Brookhurst Street 50 11000 69.5 65.9 59.0 70.7 67.1 60.2
PCH 55 37000 75.8 72.2 65.3 77.0 73.5 66.5
0 0 0 ------
0 0 0 ------
0 0 0 ------
Speed
Roadway/Segment MPH AM PM ADT ROW 50 Feet 400 Feet ROW 50 Feet 400 Feet
Brookhurst Street 50 0 ------
PCH 55 0 ------
0 0 0 ------
0 0 0 ------
0 0 0 ------
Speed
Roadway/Segment MPH AM PM ADT ROW 50 Feet 400 Feet ROW 50 Feet 400 Feet
Brookhurst Street 50 0 ------
PCH 55 0 ------
0 0 0 ------
0 0 0 ------
0 0 0 ------
CNEL
Summary 50 ft. from ROW 400 ft. from ROW % of ADTProject Cumulative Project Cumulative Vehicle Type Day Eve Night Sub total
Roadway/Segment Increment Increment Increment Increment Auto 77.6%9.7%9.7%97.0%
Brookhurst Street ----Medium Truck 1.6%0.2%0.2%2.0%
PCH ----Heavy Truck 0.8%0.1%0.1%1.0%
0 ----80.0%10.0%10.0%100.0%
0 ----
0 ----
Dist 1 50
Dist 2 400
Predicted Exisiting Noise Levels Table
Roadway/Segment ROW 50 Feet 400 Feet
Brookhurst Street 70.7 67.1 60.2
PCH 77.0 73.5 66.5
0 ---
0 ---
0 ---
CNEL
Leq
Existing
Future No Project
Future With Project
Leq
Traffic Volumes
Traffic Volumes
CNEL
CNEL
CNEL
Leq
Traffic Volumes
Roadway Traffic Noise Calculations
TENS 1.1 Biosolids Final PEIR - Noise levels at 50 and 400 feet.xlsx 4/17/2018
Predicted Future Noise Levels Table
Roadway/Segment Existing
Future No
Project
Future With
Project
Project
Increment
Cumulative
Increment
Brookhurst Street 67.1 ----
PCH 73.5 ----
0 -----
0 -----
0 -----
Attachment 2
Air Quality Information
1 Construction and Operational Emissions Overlap
2 EMFAC Output
3 CalEEMod Runs (See Appendix B of the Draft PEIR)
Attachment 2
CalEEMod 2016.3.1
Title: OCSD ‐ Operational Buildout 10/4/2017
ROG NOx CO
SO2 PM10 PM2.5
2018 Fleet Emissions Rate 0.17 4.58 0.76 0.01 0.05 0.05
2021 Fleet Emission Rate 0.11 3.16 0.62 0.01 0.01 0.01
% Reduction 35.81% 30.98% 18.06% 3.37% 73.15% 73.15%
2038 Fleet Emission Rate 0.07 1.38 0.61 0.01 0.00 0.00
% Reduction 59.99% 69.96% 20.39% 10.78% 90.98% 90.98%
*Emissions Rates taken from EMFAC 2014
ROG NOx CO
SO2 PM10 PM2.5
0.07 2.59 1.31 0.01 0.29 0.24
0.31 10.80 5.44 0.04 1.22 0.99
17 175 116 0.21 21 13
252420.133 1
1363401 0
1163300 0
2021 Total 18 211 150 0 22 13
2038 Total 18 190 149 0 21 13
18 213 151 0 22 13
18 201 154 0 22 14
Threshold 55 55 550 150 150 55
Exceed Threshold?No Yes No No No No
OCSD ‐ Biosolids Master Plan EIR
Construction and Operational Overlap Emissions Summary
Interim Emissions (2038)
Additionally, maximum daily construction emissions used a default 2018 aggregate truck fleet to determine
emissions from haul trucks. Because trucks used to haul debris from construction waste and deliver construction
equipment would be contracted, the default fleet mix would change with each subsequent year. Therefore,
emissions from the aggregate truck fleet in 2021 (for a new project within the master plan beginning in 2021)
would differ from the emissions for the aggregate fleet mix for the max year 2018. Therefore, in order to
accurately predict haul and vendor emissions from these trucks during future construction years, the emissions
for haul and vendor trucks are adjusted accordingly. These adjustments include:
Operational activities would begin with the construction of the Interim Food Waste Receiving Facility by 2020.
This would increase daily truck activities by 8 daily trips. There would be no new flare operations, new natural gas
usage, or new area source emissions as the food waste receiving facility is strictly tanks and electric pumps. Total
new trips at buildout in 2038 would be 34. Therefore Between 2020 and 2038, total operational emissions would
represent approximately 24 % of the total project mobile sources.
Interim Emissions (2021)
Unmitigated Operational Emissions
2038
Unmitigated Construction Emissions
2018 Onsite + Worker
2021 Haul & Vendor
2038 Haul & Vendor
Unmitigated Construction/Operational Overlap
2021
2018 Haul & Vendor
OCSD ‐ Biosolids Master Plan EIR
Construction and Operational Overlap Emissions Summary
ROG NOx CO
SO2 PM10 PM2.5
0.07 2.59 1.31 0.01 0.29 0.24
0.31 10.80 5.44 0.04 1.22 0.99
410990.2113 6
252420.133 1
1363401 0
1163300 0
2021 Total 5 46 133 0 14 6
2038 Total 5 26 132 0 13 6
5 49 134 <1 14 6
5 37 138 <1 15 7
Threshold 55 55 550 150 150 55
Exceed Threshold?No No No No No No
Mitigated Construction/Operational Overlap
2021
2038
Unmitigated Operational Emissions
Interim Emissions (2021)
Interim Emissions (2038)
2018 Haul & Vendor
2021 Haul & Vendor
2038 Haul & Vendor
Mitigated Construction Emissions
2018 Onsite + Worker
EMFAC2014 (v1.0.7) Emission Rates
Region Type: County
Region: Los Angeles
Calendar Year: 2038
Season: Annual
Vehicle Classification: EMFAC2007 Categories
Units: miles/day for VMT, trips/day for Trips, g/mile for RUNEX, PMBW and PMTW, g/trip for STREX, HTSK and RUNLS, g/vehicle/day for IDLEX, RESTL and DIURN
Region CalYr VehClass MdlYr Speed Fuel Population VMT Trips ROG_RUNECO_RUNEX NOx_RUNE PM10_RUNPM2_5_RU SOx_RUNEX
Los Angeles 2038 HHDT AggregatedAggregatedDSL 63801.4 10006155 0 0.087956 0.82796 1.733531 0.005514 0.005275 0.013749
Los Angeles 2038 MHDT AggregatedAggregatedDSL 107556.6 5293561 0 0.035243 0.185413 0.701476 0.002938 0.002811 0.010615
% HHDT 0.654009 5.752412 54.14937 113.3745 0.360599 0.344999 0.899195
%MHDT 0.345991 1.219388 6.415116 24.27041 0.10164 0.097243 0.367263
Weighted Average 0.069718 0.605645 1.376449 0.004622 0.004422 0.012665
EMFAC2014 (v1.0.7) Emission Rates
Region Type: County
Region: Los Angeles
Calendar Year: 2021
Season: Annual
Vehicle Classification: EMFAC2007 Categories
Units: miles/day for VMT, trips/day for Trips, g/mile for RUNEX, PMBW and PMTW, g/trip for STREX, HTSK and RUNLS, g/vehicle/day for IDLEX, RESTL and DIURN
Region CalYr VehClass MdlYr Speed Fuel Population VMT Trips ROG_RUNECO_RUNEX NOx_RUNE PM10_RUNPM2_5_RU SOx_RUNEX
Los Angeles 2021 HHDT AggregatedAggregatedDSL 52019.25 7199666 0 0.150207 0.868512 4.209498 0.018031 0.017251 0.015271
Los Angeles 2021 MHDT AggregatedAggregatedDSL 73768.84 4152017 0 0.045353 0.198192 1.345779 0.006351 0.006076 0.011019
% HHDT 0.634238 9.52667 55.08429 266.9822 1.143579 1.094108 0.968561
%MHDT 0.365762 1.658849 7.249112 49.2235 0.232281 0.222233 0.403021
Weighted Average 0.111855 0.623334 3.162058 0.013759 0.013163 0.013716
OCSD ‐ Biosolids Master Plan EIR
EMFAC 2014 Values
OCSD ‐ Biosolids Master Plan EIR
EMFAC 2014 Values
EMFAC2014 (v1.0.7) Emission Rates
Region Type: County
Region: Los Angeles
Calendar Year: 2018
Season: Annual
Vehicle Classification: EMFAC2007 Categories
Units: miles/day for VMT, trips/day for Trips, g/mile for RUNEX, PMBW and PMTW, g/trip for STREX, HTSK and RUNLS, g/vehicle/day for IDLEX, RESTL and DIURN
Region CalYr VehClass MdlYr Speed Fuel Population VMT Trips ROG_RUNECO_RUNEX NOx_RUNE PM10_RUNPM2_5_RU SOx_RUNEX
Los Angeles 2018 HHDT AggregatedAggregatedDSL 47954.14 6454031 0 0.174478 0.874386 5.305616 0.026488 0.025343 0.015927
Los Angeles 2018 MHDT AggregatedAggregatedDSL 67928.9 3691211 0 0.173854 0.562008 3.315401 0.094541 0.090451 0.011166
% HHDT 0.636163 11.09967 55.62521 337.5238 1.6851 1.612204 1.013186
%MHDT 0.363837 6.325457 20.44793 120.6264 3.439748 3.290946 0.406272
Weighted Average 0.174251 0.760731 4.581503 0.051248 0.049031 0.014195
Final
ORANGE COUNTY SANITATION DISTRICT
BIOSOLIDS MASTER PLAN
PROJECT NO. PS15-01
Environmental Findings of Fact
State Clearinghouse Number 2017071026
Prepared for May 2018
Orange County Sanitation District
Final
ORANGE COUNTY SANITATION DISTRICT
BIOSOLIDS MASTER PLAN
PROJECT NO. PS15-01
Environmental Findings of Fact
State Clearinghouse Number 2017071026
Prepared for May 2018
Orange County Sanitation District
626 Wilshire Boulevard
Suite 1100
Los Angeles, CA 90017
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OCSD Biosolids Master Plan PEIR i ESA / 150626
Environmental Findings May 2018
TABLE OF CONTENTS
OCSD Biosolids Master Plan
Project No. PS15-01
Environmental Findings of Fact
Page
1. Background and Introduction ..................................................................................... 1
1.1 Project Overview ................................................................................................... 1
1.2 Public Involvement and PEIR Scoping ................................................................. 1
1.3 PEIR Certification and Project Approval Process ................................................. 2
1.3.1 Findings Required Under CEQA ................................................................ 2
1.3.2 Significant Effects and Mitigation Measures ............................................... 2
1.3.3 Mitigation Monitoring and Reporting Program ............................................ 3
1.3.4 Certification of the PEIR and Adoption of Findings .................................... 3
2. Program Summary ....................................................................................................... 4
2.1 Program Location ................................................................................................. 4
2.2 Program Description ............................................................................................. 4
2.3 Program Objectives .............................................................................................. 4
2.4 Record of Proceedings ......................................................................................... 6
2.5 Custodian and Location of Records ...................................................................... 7
3. Environmental Findings .............................................................................................. 7
3.1 Findings Regarding Environmental Impacts Which Can Be Mitigated to
Less than Significant ............................................................................................. 7
3.1.1 Project Impacts .......................................................................................... 7
3.1.2 Cumulative Impacts ................................................................................. 21
List of Tables
1 OCSD BMP Projects ................................................................................................ 5
OCSD Biosolids Master Plan PEIR 1 ESA / 150626
Environmental Findings May 2018
OCSD BIOSOLIDS MASTER PLAN PEIR
Environmental Findings
1. Background and Introduction
1.1 Project Overview
The Orange County Sanitation District (OCSD) has completed a Program Environmental Impact
Report (PEIR) (State Clearinghouse Number 2017071026) for the Biosolids Master Plan (BMP),
Project No. PS15-01. The OCSD is the Lead Agency for the purposes of preparing and certifying
the PEIR pursuant to Sections 15050 and 15367 of the California Environmental Quality Act
(CEQA) Guidelines (California Code of Regulations, Title 14, Section 15000 et seq.).
The purpose of the PEIR is to evaluate the potential environmental impacts of the proposed BMP.
In compliance with Section 21002.1 of CEQA and Section 15002 of the CEQA Guidelines, the
OCSD, as Lead Agency, has prepared the PEIR to: (1) inform the general public, the local
community, responsible and interested public agencies and the OCSD’s decision-making bodies
and other organizations, entities, and interested persons of the potential environmental effects of
the proposed program, feasible measures to reduce potentially significant environmental effects,
and alternatives that could reduce or avoid the significant effects of the proposed program,
(2) enable OCSD to consider environmental consequences when deciding whether to approve the
proposed program, and (3) to satisfy the substantive and procedural requirements of CEQA.
1.2 Public Involvement and PEIR Scoping
The PEIR complies with the provisions of CEQA (California Public Resources Code, Section
21000 et seq.), the CEQA Guidelines and OCSD’s Procedures for Implementing the CEQA
Guidelines. In compliance with CEQA, OCSD has solicited and considered comments from
Responsible and Trustee Agencies, members of the public, and other interested parties during the
proposed program’s various environmental review processes:
In accordance with CEQA Guidelines Sections 15063 and 15082, OCSD prepared and
distributed a Notice of Preparation (NOP) of a PEIR. The NOP was distributed on July 14,
2017 to governmental agencies, organizations, and persons who may be interested in the
program.
In compliance with Section 21083.9 of CEQA and Section 15082 (c)(1) of the CEQA
Guidelines, OCSD held a public scoping meeting on July 31, 2017, to receive public and
agency comments.
Comments received from the public and agencies during the public review period for the
NOP and the public scoping meeting were considered in the preparation of the PEIR for the
proposed program.
Environmental Findings
OCSD Biosolids Master Plan PEIR 2 ESA / 150626
Environmental Findings May 2018
In February 2018, a Draft PEIR was prepared for the proposed program in accordance with
then-current CEQA regulations and guidelines. The Draft PEIR was circulated for a 45-day
public review period on February 14, 2018. Notification was provided to the State
Clearinghouse; to local, state, and federal agencies; and to all interested parties and
jurisdictions pursuant to the requirements of Section 15087 of the CEQA Guidelines. There
were eight letters/correspondences received by OCSD during the 45-day review period.
Comments within each letter/correspondence were evaluated and responded to in accordance
with Section 15088 of the CEQA Guidelines.
1.3 PEIR Certification and Project Approval Process
1.3.1 Findings Required Under CEQA
The Board of Directors (the decision-making body) of OCSD (the CEQA Lead Agency) will
determine whether to certify the Final PEIR for the program. The Final PEIR, as required by
CEQA Guidelines Sections 15089 and 15132, consists of the Draft Program Environmental
Impact Report (Draft PEIR) (SCH No. 2017071026), the Response to Comments document, and
any other information added by OCSD. The Response to Comments document includes
comments received on the Draft PEIR, a list of persons, organizations, and public agencies
commenting on the Draft PEIR, and the responses of OCSD as “Lead Agency” to significant
environmental points raised in the review and consultation process. Because the Draft PEIR
identified potentially significant environmental impacts, the Board of Directors must also make
certain “findings” as part of its action to certify that the PEIR has been completed in compliance
with CEQA and to approve the proposed program. Pursuant to CEQA Section 21081 and CEQA
Guidelines Section 15091, no public agency shall approve or carry out a project for which an
environmental impact report has been certified, which identifies one or more significant effects
on the environment that would occur if the project is approved or carried out, unless the public
agency makes one or more findings for each of those significant effects, accompanied by a brief
explanation of the rationale of each finding. The possible findings, which must be supported by
substantial evidence in the record, are:
(1) Changes or alterations have been required in or incorporated into, the project which avoid
or substantially lessen the significant environmental effect as identified in the Final PEIR.
(2) Such changes or alterations are within the responsibility and jurisdiction of another public
agency and not the agency making the finding. Such changes have been adopted by such
other agency or can and should be adopted by such other agency.
(3) Specific economic, legal, social, technological, or other considerations, including
provision of employment opportunities for highly trained workers, make infeasible the
mitigation measures or program alternatives identified in the Final PEIR.
1.3.2 Significant Effects and Mitigation Measures
As part of the approval of the BMP and the certification of the PEIR for the proposed program,
CEQA requires the Lead Agency—in this case, OCSD, acting through the Board of Directors—to
make written findings with respect to each significant environmental impact of the program.
These findings need to be accompanied by a brief explanation of the rationale for each finding,
and any mitigation measures used to reduce or substantially lessen the impact. The significance of
the potential impacts of the proposed program was determined through application of the
appropriate thresholds of significance for each resource area, as defined in CEQA Appendix G.
Environmental Findings
OCSD Biosolids Master Plan PEIR 3 ESA / 150626
Environmental Findings May 2018
Section 15093(a) of the CEQA Guidelines states that if specific economic, legal, social,
technological, or other benefits of the proposed program outweigh the unavoidable adverse
environmental effects, the adverse environmental effects may be considered “acceptable” and the
OCSD Board of Directors may adopt a Statement of Overriding Considerations to that effect. The
Draft PEIR identified several significant environmental effects (or “impacts”) resulting from
implementation of the proposed program. All of these significant effects can be reduced to less
than significant through the adoption of feasible mitigation measures. The Draft PEIR found that
the proposed program would not result in any significant and unavoidable impacts, and therefore,
a Statement of Overriding Considerations would not need to be adopted. Section 3 describes the
program and cumulative effects and outlines OCSD’s findings with respect to each of these
environmental effects of the proposed program.
1.3.3 Mitigation Monitoring and Reporting Program
A Mitigation Monitoring and Reporting Program (MMRP) has been prepared to monitor and
report the implementation of the mitigation measures identified for the proposed program. The
MMRP will be adopted by the Board of Directors concurrently with these findings, and will be
implemented by OCSD during the proposed program’s planning horizon; and through the
program review, construction and post-construction periods of individual projects. To the extent
that these findings conclude that all mitigation measures outlined in the PEIR are feasible and
have not been modified, superseded, or withdrawn, OCSD hereby binds itself to implement these
measures. These findings, in other words, are not merely informational, but rather constitute a
binding set of obligations that will come into effect when the Board of Directors formally
approves the proposed program.
1.3.4 Certification of the PEIR and Adoption of Findings
The Board of Directors will review and consider the information contained in the PEIR, as well
as submissions from public officials, public agencies and the general public. Prior to program
approval, the Board of Directors shall certify that the PEIR reflects OCSD’s independent
judgment and analysis. Having considered the foregoing information, as well as any and all other
information in the record, the Board of Directors shall make findings pursuant to CEQA Section
21081. In accordance with the provisions of CEQA and the CEQA Guidelines, the Board of
Directors shall adopt the findings as part of its certification of the PEIR for the proposed program.
Environmental Findings
OCSD Biosolids Master Plan PEIR 4 ESA / 150626
Environmental Findings May 2018
2. Program Summary
2.1 Program Location
OCSD facilities are located in northwestern Orange County, California. All proposed projects
would be located within OCSD Plant No. 1 and Plant No. 2 boundaries. Therefore, for purposes
of the PEIR, the “program area” includes Plants No. 1 and No. 2. Plant No. 1 is located at 10844
Ellis Avenue, Fountain Valley, California, and is bound by Ellis Avenue to the north, Ward Street
to the west, Garfield Avenue to the south, and the Santa Ana River (SAR) and SAR Trail to the
east. Residential neighborhoods are located west of Ward Street. Plant No. 1 is located within the
City of Fountain Valley. The Fountain Valley General Plan designates Plant No. 1 as a Specific
Plan Area and the area is zoned as Specific Plan-Orange County Sanitation District.
Plant No. 2 is located at 22212 Brookhurst Street, Huntington Beach, California, and bound by
residential neighborhoods located approximately 375 feet north of the intersection of Baybreeze
Drive and Brookhurst Street to the north, Brookhurst Street and residential neighborhoods to the
west, the SAR and SAR Trail to the east, and Talbert Marsh, Pacific Coast Highway (PCH) and
the Pacific Ocean to the south. The City of Huntington Beach General Plan designates Plant No. 2
as a Public (P) land use and zoned for Industrial Limited (IL) and Residential Agriculture with an
Oil Overlay (RA-O). The program area is also located within the City of Huntington Beach’s
Coastal Zone and is subject to the City’s Local Coastal Program.
The majority of the proposed program components would be constructed entirely within the
existing Plant No. 2 property. The proposed facilities would be implemented within the southwest
corner of Plant No. 2 adjacent to the existing biosolids handling facilities. Within Plant No. 2, the
program area encompasses approximately 16 acres. Within Plant No. 1, the program area
encompasses approximately 2 acres.
2.2 Program Description
The proposed program consists of nine projects that are necessary to upgrade Plant No. 2 solid
handling facilities to align with OCSD’s goals and objectives. These nine projects would be
implemented over the next 20 years. Table 1 summarizes the individual BMP projects.
2.3 Program Objectives
Section 15124(b) of the CEQA Guidelines states that the project description shall contain “a
statement of the objectives sought by the proposed project.” Section 15124(b) further states that
“the statement of objectives should include the underlying purpose of the project.” The
underlying purpose of the proposed program is to provide for flexible and sustainable biosolids
handling in the future. As set forth by the CEQA Guidelines, the list of objectives that OCSD
seeks to achieve for the proposed program is provided below.
Replace aging facilities and mitigate the structural and seismic risks for onsite biosolids
structures.
Phase-out the diversion of biosolids organics as an alternative daily cover for landfills.
Environmental Findings
OCSD Biosolids Master Plan PEIR 5 ESA / 150626
Environmental Findings May 2018
Transition from Class B to Class A biosolids quality at Plant No. 2 to increase biosolids
management diversity for end users of biosolids.
Receive pre-processed food waste (source separated organics) for co-digestion to assist in
diverting organics from landfills and to increase digester gas production used as a renewable
energy.
TABLE 1
OCSD BMP PROJECTS
OCSD
Funding
No.
Project
No. Project Name Description Construction Years
P2-125 P2-501 Plant No. 2
Southwest
Perimeter
Screening
P2-501 would improve or replace the perimeter
screening to provide a visual buffer for all proposed
facilities and associated construction activities along
Brookhurst Street and Talbert Marsh. The perimeter
screening would be extended along Brookhurst
Street and up to approximately 1,030 feet along
Talbert Marsh.
2019 to 2020
P2-124 P2-502 Interim Food Waste
Receiving Facility
An interim food waste facility with a capacity up to
250 wet tons per day will be built to satisfy initial co-
digestion needs. The food facility would include two
20,000-gallon tanks and ancillary facilities such as
pumps and odor control treatment. The interim food
waste facility will be replaced with an ultimate food
waste facility (P2-506).
2018 to 2020
P2-126 P2-503A Plant No. 2
Warehouse
Relocation
The existing 21,000-square-foot, above-grade
warehouse would be demolished and then
reconstructed at a new location on Plant No. 2
approximately 1,600 feet north of the existing
facility.
2021 to 2023
P2-127 P2-503B Plant 2 Collections
Yard Relocation
The existing 38,000-square-foot collections yard
(parking lot) would be relocated, potentially to Plant
No. 1. The specific location is not known at this
time. The relocated collections yard would provide
adequate space and truck paths to and from Plant
No.1 or Plant No. 2, similar to the existing footprint.
2021 to 2023
P2-128 P2-504,
504A,
504B
Temperature
Phased Anaerobic
Digestion (TPAD)
Digester Facility at
Plant No. 2
This project would construct six 110-foot-diameter,
40-foot-tall (above ground) digesters designed to
operate in either mesophilic or thermophilic
operation, and TPAD sludge cooling facilities, which
include a pump station, ultrafiltration/nanofiltration
facilities, sludge cooling heat exchangers, and a
power building.
All new digesters (pairs) would share an electrical
control room that would house various pumps, fans,
pipelines, and other ancillary facilities.
2025 to 2030
Six 400,000-gallon, 37-feet above ground, Class A
batch tanks would be constructed to produce Class
A biosolids per U.S. Environmental Protection
Agency (USEPA) 503 regulations through batch
holding over a specified time and temperature. The
Class A batch tanks would require other ancillary
equipment such as pumps, heat exchangers, and
grinders.
The proposed 33-foot-diameter, 30-foot-high (above
ground) Digester Feed Facility (DFF) would replace
the existing Sludge Blending Facility where primary
sludge and scum is blended and fed to the
digesters.
Environmental Findings
OCSD Biosolids Master Plan PEIR 6 ESA / 150626
Environmental Findings May 2018
OCSD
Funding
No.
Project
No. Project Name Description Construction Years
The DFF would include thickened sludge tanks, and
ancillary facilities, such as fans, grinders, pumps,
and carbon and bioscrubbers.
P2-129 P2-504C,
P2-505
Digester P, Q, R,
and S Replacement
P2-504C would relocate the existing ferric facility,
which currently feeds three digester segments. The
new structure would be 38 by 51 feet. The
relocation will include all of the match pumps, tanks,
and existing equipment.
2038 to 2040
P2-505 would consist of the demolition of four
existing digesters (P, Q, R, and S) and Power
Building C. Digesters P, Q, R, and S will be rebuilt
in place, two at a time. Digesters P, Q, R, and S
would have an inner diameter of 105 feet and height
of 38 feet above ground.
2028 to 2033
P2-506 P2-506 Ultimate Food
Waste Receiving
Facility
Following operation of the interim food waste
receiving facility (P2-502), P2-506 will allow for
expansion of the Source Separated Organics (SSO)
receiving program through construction of a larger
capacity food waste receiving station to replace the
interim facility.
The ultimate food waste facility would include a total
of four, 12-foot-diameter, 30-foot-tall 20,000-gallon
tanks, recirculation and digester feed pumps, and
odor-control treatment carbon canisters.
2035 to 2037
P2-507 P2-507 Replace Digesters I,
J, K (Relocate
Digester Holders)
P2-507 would consist of the demolition of seven
digesters (I, J, K, M, N, O, and T) and relocation of
three digesters (I, J, and K) with a diameter of 84
feet and height of 37 feet (above ground). These
new digesters would serve as mesophilic digesters
and holders capable of operation as mesophilic
digesters.
An above-grade equipment room would be built
between each pair of digesters. The equipment
rooms would house ancillary facilities such as fans,
pumps and pipelines. Each equipment room would
be 40 feet by 50 feet and up to 40 feet in height
above ground.
2033 to 2038
P2-508 P2-508 Digester Demolition P2-508 demolishes the six remaining digesters,
Digesters C, D, E, F, G, and H, to free up site
footprint for future treatment process facilities.
2035 to 2040
2.4 Record of Proceedings
For purposes of CEQA and these findings, the Record of Proceedings for the proposed program
consists of the following documents and other evidence, at a minimum:
The NOPs and all other public notices issued by OCSD in conjunction with the proposed
program.
The Final PEIR document for the proposed program which consists of an Introduction to
Response to Comments, a Comment Letters listing, Response to Comments, Corrections and
Additions to the Draft PEIR, and the MMRP.
The Draft PEIR, and all appendices thereto.
The documents, reports, and technical memoranda included or referenced in the technical
appendices of the Draft PEIR.
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All documents, studies, Environmental Impact Reports (EIRs), or other materials
incorporated by reference in the Draft PEIR and Response to Comments.
OCSD Staff Reports for the program.
Any documents expressly cited in these findings.
Any other relevant materials required to be in the record of proceedings by Public Resources
Code Section 21167.6(e) (excluding privileged materials).
2.5 Custodian and Location of Records
The documents and other materials that constitute the administrative record for OCSD’s actions
related to the program are located at the OCSD, Administrative Office Building at Plant No. 1,
Engineering Planning Division – 10844 Ellis Avenue, Fountain Valley, California. OCSD is the
custodian of the record of proceedings for the program. Copies of these documents, which
constitute the record of proceedings are, and at all relevant times have been and will be, available
upon request at OCSD’s administrative office. This information is provided in compliance with
Public Resources Code Section 21081.6(a)(2) and CEQA Guideline Section 15091(e).
3. Environmental Findings
3.1 Findings Regarding Environmental Impacts Which Can
Be Mitigated to Less than Significant
Environmental impacts identified in the PEIR as potentially significant, but which OCSD finds
can be mitigated to less than significant through the imposition of feasible mitigation measures
identified in the PEIR and set forth herein, are described in this section.
3.1.1 Project Impacts
3.1.1.1 Aesthetics
a. Potentially Significant Impact: The proposed program could create new sources of
substantial light or glare and result in adverse effects on daytime or nighttime views in
the program area.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: The proposed facilities would be located within the
existing Plant No. 1 and Plant No. 2 boundaries, which currently contain lighting within
the interior and exterior of structures. Plant No. 1 and Plant No. 2 are located within an
urban area, developed with residential, commercial, and industrial uses. Implementation
of the proposed projects could result in new exterior nighttime lighting for operational
and security purposes within Plant No. 1 and Plant No. 2. Though not anticipated, the
increase in lighting within the plants could result in spillover lighting onto neighboring
residential or commercial uses, or the SAR Trail and Talbert Marsh. Therefore, increase
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lighting within Plant No. 1 and Plant No. 2 could represent a potential significant lighting
impact.
As identified in Section 3.1 in the Draft PEIR, Mitigation Measures AES-1 and AES-2
are included to reduce potential impacts to less than significant levels.
AES-1: All new permanent exterior lighting associated with proposed program
components shall be shielded and directed downward to avoid any light
intrusion to surrounding uses.
AES-2: Development of the proposed program and associated facilities shall
comply with existing and future lighting ordinances for the cities of
Fountain Valley and Huntington Beach.
The implementation of Mitigation Measures AES-1 and AES-2 will limit the maximum
light beyond the property boundary and comply with existing and future lighting
ordinances so that lighting impacts on adjacent uses would be less than significant.
3.1.1.2 Air Quality
a. Potentially Significant Impact: The proposed program could have significant effects on
implementation of the South Coast Air Quality Management Plan (AQMP) because the
proposed program could conflict with or obstruct implementation of the AQMP.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: As described in Section 3.2 of the Draft PEIR, the
AQMP was adopted by the South Coast Air Quality Management District (SCAQMD) as
a program to lead the Air Basin into compliance with several criteria pollutant standards
and other federal requirements. It relies on emissions forecasts based on demographic and
economic growth projections provided by SCAG’s Regional Transportation Program
(SCAQMD, 2012). SCAG is charged by California law to prepare and approve “the
portions of each AQMP relating to demographic projections and integrated regional land
use, housing, employment, and transportation programs, measures and strategies”
(SCAQMD, 2012). As discussed previously, projects whose growth is included in the
SCAG projections used in the formulation of the AQMP are considered to be consistent
with the plan and not to interfere with its attainment. The SCAQMD recommends that,
when determining whether a project is consistent with the current AQMP, a Lead Agency
must assess whether the project would directly obstruct implementation of the plan and
whether it is consistent with the demographic and economic assumptions upon which the
plan is based.
The construction activities associated with the proposed program could obstruct
implementation of the AQMP because, as detailed in Impact 3.2-2 of the Draft PEIR, its
construction emissions would exceed the daily nitrogen oxides NOx regional emissions
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significance threshold. Because the proposed program’s NOx regional emissions exceed
the threshold and NOx contributes to the formation of ozone, the proposed program
would contribute to the Air Basin’s nonattainment of the National Ambient Air Quality
Standards for ozone. Therefore, the proposed program could result in a significant impact
on the implementation of the AQMP.
As identified in Section 3.2 in the Draft PEIR, Mitigation Measure AQ-1 is included to
reduce potential impacts to less than significant levels.
AQ-1: Mobile off-road construction equipment (wheeled or tracked) used
during construction of the individual projects of the proposed program
that may exceed SCAQMD daily thresholds for NOx shall meet the
USEPA Tier 4 final standards, either as original equipment or equipment
retrofitted to meet the Tier 4 final standards. A copy of each unit’s
certified tier specification or model year specification shall be available
upon request at the time of mobilization of each applicable unit of
equipment. For projects that would not individually emit NOx above the
SCAQMD daily threshold, OCSD or the contractor shall prepare
emissions calculations based on equipment to be used that show
emissions are below the threshold. These emissions estimates must be
maintained at OCSD headquarters for reference, and OCSD must
confirm that the equipment used during actual construction is adequately
characterized.
Implementation of Mitigation Measures AQ-1 would reduce regional construction
emissions of NOx to comply with the SCAQMD thresholds. Implementation of this
mitigation measure would reduce impacts to less than significant levels.
b. Potentially Significant Impact: The proposed program could violate an air quality
standard or contribute substantially to an existing or projected air quality violation.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: Construction activities associated with the proposed
program would generate pollutant emissions from the following construction activities:
(1) demolition, site preparation, grading, and excavation (as discussed in the
Methodology section above, only grading is modeled for maximum daily emissions); (2)
construction workers traveling to and from project site; (3) delivery and hauling of
construction supplies to, and debris from, the project site; (4) fuel combustion by onsite
construction equipment; (5) building construction, application of architectural coatings,
and paving. These construction activities would temporarily create emissions of dust,
fumes, equipment exhaust, and other air contaminants. The amount of emissions
generated on a daily basis would vary, depending on the intensity and types of
construction activities occurring simultaneously.
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Construction emissions are considered short term and temporary, but have the potential to
represent a significant impact with respect to air quality. Particulate matter (PM) (i.e.,
PM10 and PM2.5) are among the pollutants of greatest localized concern with respect to
construction activities. Particulate emissions from construction activities can lead to
adverse health effects and nuisance concerns, such as reduced visibility and soiling of
exposed surfaces. Particulate emissions can result from a variety of construction
activities, including excavation, grading, demolition, vehicle travel on paved and unpaved
surfaces, and vehicle and equipment exhaust. Construction emissions of PM can vary
greatly depending on the level of activity, the specific operations taking place, the
number and types of equipment operated, local soil conditions, weather conditions, and
the amount of earth disturbance. Construction assumptions are summarized in the
Methodology section and detailed in Appendix B of the Draft PEIR.
Emissions of ozone precursors such as reactive organic gases (ROGs)/volatile organic
compounds (VOCs) and NOX are primarily generated from mobile sources and vary as a
function of vehicle trips per day associated with debris hauling, delivery of construction
materials, vendor trips, and worker commute trips, and the types and number of heavy-
duty, off-road equipment used and the intensity and frequency of their operation. A large
portion of construction-related ROG emissions also result from the application of
architectural coatings and vary depending on the amount of coatings applied each day.
It is mandatory for all construction projects in the South Coast Air Basin (SCAB) to
comply with SCAQMD Rule 403 for controlling fugitive dust. Specific Rule 403 control
requirements include, but are not limited to, applying water in sufficient quantities to
prevent the generation of visible dust plumes, applying soil binders to uncovered areas,
reestablishing ground cover as quickly as possible, using a wheel-washing system to
remove bulk material from tires and vehicle undercarriages before vehicles exit the
construction site, covering all trucks hauling soil with a fabric cover and maintaining a
freeboard height of 12 inches, and maintaining effective cover over exposed areas.
Compliance with Rule 403 and Rule 1113 (governing VOC content of architectural
coatings), as pre-existing regulatory requirements, were accounted for in the construction
emissions modeling. Rule 1113 is included as part of the default modeling scenario.
Table 3.2-6 of the Draft PEIR summarizes the modeled peak daily emissions of criteria
air pollutants and ozone precursors associated with the proposed program’s worst-case
construction scenario (using the significance criteria provided in Table 3.2-4 of the Draft
PEIR). The peak daily emissions generated for the proposed program’s construction
period are identified. The proposed program would exceed the SCAQMD’s daily regional
significance threshold for NOx. Therefore, construction phase emissions for NOx would
be significant.
Further, because the program will be implemented in phases, there is a reasonable
possibility that construction activities of later phase biosolids facilities could overlap with
operation of earlier phase facilities. In order to determine the combined significance of
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these activities, the construction and operational activities are combined and compared to
the SCAQMD’s operational threshold.
Operational activities would begin with the construction of the Interim Food Waste
Receiving Facility by 2020. This would increase daily truck activities by eight daily trips.
There would be no new flare operations, new natural gas usage, or new area source
emissions as the food waste receiving facility is strictly tanks and electric pumps. Total
new trips at buildout in 2038 would be 34. Therefore, between 2020 and 2038, total
operational emissions would represent approximately 24 percent of the total program
mobile sources.
Additionally, maximum daily construction emissions used a default 2018 aggregate truck
fleet to determine emissions from haul trucks. Because trucks used to haul debris from
construction waste and deliver construction equipment would be contracted, the default
fleet mix would change with each subsequent year. This means that emissions from the
aggregate truck fleet in 2021 (for a new program within the master plan beginning in
2021) would differ from the emissions for the aggregate fleet mix for the max year 2018.
Therefore, to accurately predict haul and vendor emissions future construction activities,
the emissions for haul and vendor trucks have been adjusted accordingly. Calculations
assumptions and calculations are included in Attachment 2 of the Final PEIR. Table 3.2-
7A of the Final PEIR shows the unmitigated combined construction and operational
emissions. As shown, the proposed program would exceed the SCAQMD’s daily regional
significance threshold for NOx. Therefore, construction phase emissions for NOx would
be significant without mitigation.
As identified in Section 3.2 in the Draft PEIR and Chapter 4 of the Final PEIR,
Mitigation Measure AQ-1 is required to reduce potential impacts to less than significant
levels.
With the implementation of Mitigation Measure AQ-1, the proposed program’s
maximum daily construction emissions would be reduced to below regulatory thresholds
as shown in Table 3.2-8 of the Draft PEIR and Table 3.2-8A of the Final PEIR. Based on
the reduction of the total NOx emissions with the implementation of Mitigation Measure
AQ-1, impacts related to a violation of air quality standards from combined construction
and operational activities associated with the proposed program would be less than
significant.
c. Potentially Significant Impact: The proposed program could result in significant effects
associated with the exposure of sensitive receptors to substantial pollutant concentrations.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: The daily onsite construction emissions generated by
the proposed program were evaluated against SCAQMD’s Localized Significance.
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Threshold (LSTs) for a 2-acre site as a screening-level analysis to determine whether the
emissions would cause or contribute to adverse localized air quality impacts. The nearest
off-site sensitive receptors are the residential dwelling located directly west of the Plant
No. 2 across Brookhurst Street. Because the mass rate look-up tables provided by
SCAQMD only provide LSTs at receptor distances of 82, 164, 328, 656, and 1,640 feet,
the LSTs for a receptor distance of 82 feet are used to evaluate the potential localized air
quality impacts associated with the proposed program’s peak day construction emissions.
Table 3.2-9 of the Draft PEIR identifies the daily localized onsite emissions that are
estimated to occur during the proposed program’s worst-case construction scenario. The
daily emissions would exceed regulatory thresholds for NOx, PM10 and PM2.5.
Further, the proposed program would expose sensitive receptors to substantial
concentrations of toxic air contaminants if the proposed program would emit
carcinogenic materials or TACs that exceed the maximum incremental cancer risk of
10 in one million or a cancer burden greater than 0.5 excess cancer cases (in areas greater
than or equal to 1 in 1 million) or an acute or chronic hazard index of 1.0. Construction-
related cancer risk and acute/chronic hazards were estimated and compared to this
threshold. Health risk calculations were performed using a spreadsheet tool consistent
with the Office of Environmental Health Hazard Assessment (OEHHA) guidance. The
spreadsheet tool incorporates the algorithms, equations and a variable described above, as
well as in the OEHHA guidance, and incorporates the results of the AERMOD dispersion
model.
The process of assessing health risks and impacts includes a degree of uncertainty. The
level of uncertainty is dependent on the availability of data and the extent to which
assumptions are relied upon in cases where the data are incomplete or unknown. All
health risk assessments rely upon scientific studies in order to reduce the level of
uncertainty; however, it is not possible to completely eliminate uncertainty from the
analysis. Where assumptions are used to substitute for incomplete or unknown data, it is
standard practice in performing health risk assessments to err on the side of health
protection to avoid underestimating or underreporting the risk to the public by assessing
risk on the most sensitive populations, such as children and the elderly.
For carcinogenic exposures, the cancer risk from diesel particulate matter (DPM)
emissions from construction activities associated with the proposed program is estimated
to result in a maximum carcinogenic risk of 320.7 per one million. This maximum level
is considered worst-case since it assesses health risks based upon annual emissions levels
from the year with the maximum expected emissions. The lifetime exposure under the
OEHHA guidance takes into account early life (infant and children) exposure. It should
also be noted that the calculated cancer risk conservatively assumes that sensitive
receptors (residential uses) would not employ mechanical filtration which normally
reduce the cancer risk. Based on the evaluation within the Draft PEIR, impacts would be
considered potentially significant because the maximum carcinogenic risk of 320.7 per
one million would be greater than the risk threshold of 10.0 in one million.
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As identified in Section 3.2 in the Draft PEIR, Mitigation Measure AQ-1 (defined above)
and AQ-2 is included to reduce potential impacts to less than significant levels.
AQ-2: When grading activities occur within 50 meters of the nearest sensitive
receptors, the number of scrapers active onsite is restricted to a
maximum of 5 and the number of dozers is restricted to a maximum of 2.
With the implementation of Mitigation Measures AQ-1 and AQ-2, the proposed
program’s localized construction emissions for NOx, PM10, and PM2.5 would be
reduced to below regulatory thresholds, as shown in Table 3.2-11 of the Draft PEIR.
Implementation of Mitigation Measure AQ-1 would also result in a reduction in overall
health risk due to the incorporation of Tier 4 equipment which significantly reduces DPM
emissions. With the implementation of Mitigation Measure AQ-1, the maximum
carcinogenic risk associated with the proposed program would reduce from 320.7 per
one million to 9.6 per million, which is below the regulatory threshold of 10 per million.
Therefore, the cancer risk for nearby sensitive receptors would not contribute to a
significant health risk during construction activities.
d. Potentially Significant Impact: The proposed program could result in significant effects
from the creation of objectionable odors affecting a substantial number of people.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: During construction activities, only short-term,
temporary odors from vehicle exhaust and construction equipment engines would occur.
These odors would be temporary, would be transitory throughout Plant No. 1 and Plant
No. 2 as construction occurs for each project. The odors would also disperse rapidly and
would be typical of the existing operational truck activities within the program area.
However, existing digesters on Plant No. 2 could potentially harbor odors. The
demolition of these facilities could result in the release of odors into the surrounding
environment. Therefore, odor emissions from construction activities could be potentially
significant.
As identified in Section 3.2 in the Draft PEIR, Mitigation Measure AQ-3 is included to
reduce potential impacts to less than significant levels.
AQ-3: OCSD shall ensure that contractors remove salvaged/demolished
equipment from the treatment plants to minimize potential odors during
the removal of existing facilities. Staging areas shall not be used to store
salvaged/demolished equipment.
Implementation of Mitigation Measure AQ-3 would minimize the generation of nuisance
odors during and after demolition of existing digesters, thereby reducing potential
impacts to less than significant levels.
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3.1.1.3 Biological Resources
a. Potentially Significant Impact: The proposed program could have significant effects on
some avian species during nesting activities.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: Construction activities would include the disturbance
of approximately 19.5 acres; approximately 2.0 acres at Plant No. 1 and approximately
17.5 acres at Plant No. 2. The proposed disturbance could include the removal of several
non-native ornamental trees at Plant No. 1, several non-native ornamental trees mostly
located within the confines of Plant No. 2, and a row of trees within Plant No. 2 along
Brookhurst Street located on the southern boundary of Plant No. 2. The removal of trees
could result in direct impacts to nesting birds if any are present. In addition, indirect
impacts to birds nesting in the vicinity of the proposed disturbance could result from
construction noise.
Nesting activity typically occurs from February 15 to August 31 for songbirds and from
January 15 to August 31 for raptors. Disturbing or destroying active nests is a violation of
the Migratory Bird Treaty Act. In addition, nests and eggs are protected under California
Fish and Game Code Section 3503 and 3503.5. As such, direct impacts (removal of
active nests) and indirect impacts (e.g., by noise causing abandonment of the nest) to
nesting birds would be considered potentially significant.
As identified in Section 3.3 in the Draft PEIR, Mitigation Measure BIO-1 is included to
reduce potential impacts to less than significant levels.
BIO-1: If removal of onsite trees and vegetation associated with the proposed
program occurs during the non-nesting season (September 1 to February
14 for songbirds; September 1 to January 14 for raptors), no nesting
survey or biological monitor are required.
If the removal of onsite trees and vegetation associated with the proposed
program occurs during the nesting season (February 15 to August 31 for
songbirds; January 15 to August 31 for raptors), a qualified biologist
shall conduct a survey prior to vegetation removal activities to determine
if there are active nests within the onsite trees and vegetation proposed
for removal. If an active nest is not found, no biological monitor is
required. If active nests are detected, a minimum buffer (e.g., 300 feet for
songbirds or 500 feet for raptors) around the nest shall be delineated and
flagged, and no construction activity shall occur within the buffer area
until a qualified biologist determines the nesting species have fledged
and is no longer active or the nest has failed. The buffer may be modified
(i.e., increased or decreased) and/or other recommendations proposed
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(e.g., a temporary soundwall) as determined appropriate by the qualified
biologist to minimize impacts. The qualified biologist shall monitor the
removal of onsite trees and vegetation. Nest buffer distance will be based
on species, specific location of the nest, the intensity of construction
activities, existing disturbances unrelated to the proposed program
present in the program area, and other factors.
If grading/excavation or pile driving activities associated with the
proposed program are scheduled outside the nesting season, no nesting
survey or biological monitor are required.
If grading/excavation or pile driving activities associated with the
proposed program are scheduled during the nesting season, a qualified
biologist shall conduct a survey, prior to grading/excavation or pile
driving activities, of suitable nesting habitat within 500 feet of
construction activities for the presence of nesting birds. If no active nests
are detected, no biological monitor is required. If an active nest is
detected, a minimum buffer (e.g., 300 feet for songbirds or 500 feet for
raptors) around the nest shall be delineated and the active nest shall be
flagged, and no construction activity shall occur within the buffer area
until a qualified biologist determines the nesting species have fledged
and is no longer active or the nest has failed. The qualified biologist shall
monitor the activities of the active nests within the buffer area. The
buffer may be modified (i.e., increased or decreased) and/or other
recommendations proposed (e.g., a temporary soundwall) as determined
appropriate by the qualified biologist to minimize impacts. Nest buffer
distance will be based on species, specific location of the nest, the
intensity of construction activities, existing disturbances unrelated to the
proposed program present in the program area, and other factors.
If there is a lapse of construction activities associated with the proposed
program during the nesting season for 7 days or more, an additional
nesting bird survey shall be conducted to determine if a nest is present
prior to construction activities resuming. The procedure identified above
for no active nest and an active nest shall be followed.
Implementation of Mitigation Measure BIO-1 would reduce impacts to nesting birds to
less than significant by either conducting construction activities during the non-nesting
season or conducting a survey to establish a suitable nesting habitat buffer as well as
having a qualified biologist to monitor the activities of the active nests within the buffer
area during nesting season when construction activities occur.
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3.1.1.4 Cultural Resources
a. Potentially Significant Impact: The proposed program could result in a significant
effect on an archaeological resource because the proposed program has the potential to
cause a substantial adverse change in the significance of an archeological resource
pursuant to CEQA Guidelines Section 15064.5.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: No archaeological resources were identified in the
proposed program area or close proximity and the proposed program would not result in
an impact to known archaeological resources. However, based on the results of the
records search, which identified six prehistoric archaeological resources within a ½-mile
radius, and geoarchaeological review, which indicated that the proposed program area is
highly sensitive for subsurface archaeological resources, there is the potential to impact
unknown buried archaeological resources. If previously undiscovered artifacts or cultural
remains are uncovered during excavation or construction, the proposed program could
result in significant impacts to archaeological resources that could qualify either as
historical resources or unique archaeological resources under CEQA.
As identified in Section 3.4 in the Draft PEIR, Mitigation Measures CUL-1 through
CUL-4 are included to reduce potential impacts to less than significant levels.
CUL-1: Prior to start of grading or excavation activities associated with the
proposed program within Plant No. 1 and Plant No. 2, OCSD shall retain
a qualified archaeologist meeting the Secretary of the Interior’s
Professional Qualifications Standards for archaeology (U.S. Department
of the Interior 2008) to carry out all mitigation related to archaeological
resources.
CUL-2: Prior to start of grading or excavation activities associated with the
proposed program within Plant No. 1 and 2, the qualified archaeologist
(or an archaeologist working under the direct supervision of the qualified
archaeologist) shall conduct cultural resources sensitivity training for all
construction personnel. Construction personnel shall be informed of the
types of archaeological resources that may be encountered, the proper
procedures to be enacted in the event of an inadvertent discovery of
archaeological resources or human remains, and safety precautions to be
taken when working with archaeological monitors. OCSD shall ensure
that construction personnel are made available for and attend the training
and retain documentation demonstrating attendance.
CUL-3: Archaeological and Native American monitoring shall be conducted for
grading or excavation activities associated with the proposed program at
Plant No. 1 and Plant No. 2. Archaeological monitoring shall be
conducted by an archaeologist familiar with the types of archaeological
resources that could be encountered within the program area, and under
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the direct supervision of the qualified archaeologist. The frequency of
monitoring shall take into account the rate of excavation and grading
activities, the materials being excavated (native verses artificial fill soils
and older verse younger soils), and the depth of excavation. The
frequency of the monitoring shall be determined by the qualified
archaeologist in consultation with the Native American monitor and in
coordination with OCSD. The Native American monitor shall be selected
from a tribe that is culturally and traditionally affiliated with the program
area as indicated by the Native American Heritage Commission
(NAHC). In the event that archaeological resources are unearthed during
ground-disturbing activities, the archaeological monitor and/or Native
American monitor shall be empowered to halt or redirect ground-
disturbing activities away from the vicinity of the discovery until OCSD,
a qualified archaeologist, and a Native American monitor have evaluated
the discovery and determined appropriate treatment (as prescribed in
CUL-4). The archaeological monitor shall keep daily logs detailing the
types of activities and soils observed, and any discoveries. After
monitoring has been completed, the qualified archaeologist shall prepare
a report that details the results of monitoring for submittal to OCSD, the
South Central Coastal Information Center, and any Native American
tribe that requests a copy.
CUL-4: In the event of the unanticipated discovery of archaeological materials
during grading or excavation activities associated with the proposed
program, OCSD shall immediately cease all work activities in the area
(within approximately 100 feet) of the discovery until it can be evaluated
by the qualified archaeologist. Construction shall not resume until the
qualified archaeologist has conferred with OCSD on the significance of
the resource.
In the event that preservation in place is determined to be infeasible and
data recovery through excavation is the only feasible mitigation
available, an Archaeological Resources Treatment Plan shall be prepared
and implemented by the qualified archaeologist in consultation with
OCSD that provides for the adequate recovery of the scientifically
consequential information contained in the archaeological resource.
OCSD shall consult with appropriate Native American representatives in
determining treatment for prehistoric or Native American resources to
ensure cultural values ascribed to the resource are considered.
Implementation of CUL-1, CUL-2, CUL-3, and CUL-4 would include the retention of a
qualified archaeologist, conducting archaeological resources sensitivity training for all
construction personnel, archaeological and Native American monitoring during ground-
disturbing activities, and establishing the proper protocol in the event of an unanticipated
discovery of archaeological materials. The implementation of these measures would
reduce impacts to archaeological resources that could qualify as historical resources or
unique archaeological resources to less than significant.
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b. Potentially Significant Impact: The proposed program could result in a significant
effect on a unique paleontological resource because the proposed program could directly
or indirectly destroy a unique paleontological resource or site or unique geologic feature.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: Based on the results of the paleontological database
search, there are no known fossil localities in proposed program area. However, several
fossil localities from older Quaternary deposits, similar to those that are likely present in
the subsurface of the proposed program area, are located approximately 1.5 to 3.5 miles
away. These localities have yielded a wide variety of vertebrate fossils, from marine taxa
such as leopard shark to fish such as the three-spined stickleback and terrestrial animals
such as garter snake, turtle, desert shrew, pocket gopher, mammoth, bison, horse, camel,
and elephant. Due to the young age of the surficial sediments underlying the proposed
program area, there is a low potential to uncover significant vertebrate fossil remains
during surface grading or shallow excavations. However, excavations that extend down
into the older Quaternary deposits may encounter significant fossil vertebrate specimens.
Since the proposed program includes ground-disturbing activities, there is a potential for
discovery of fossils that may be considered significant paleontological resources. If
previously unknown potentially unique paleontological resources are uncovered during
excavation or construction, significant impacts could occur.
As identified in Section 3.4 in the Draft PEIR, Mitigation Measures CUL-5 through
CUL-8 are included to reduce potential impacts to less than significant levels.
CUL-5: Prior to start of excavation activities associated with the proposed
program that exceed 10 feet in depth in previously undisturbed
sediments, OCSD shall retain a qualified paleontologist meeting the
Society for Vertebrate Paleontology (SVP) Standards (SVP 2010) to
carry out all mitigation related to paleontological resources. The
qualified paleontologist shall be selected from the list of County of
Orange certified paleontologists.
CUL-6: Prior to the start of excavation activities associated with the proposed
program that exceed 10 feet in depth in previously undisturbed
sediments, the qualified paleontologist, or his or her designee, shall
conduct training for construction personnel regarding the appearance of
fossils and the procedures for notifying paleontological staff should
fossils be discovered by construction staff. OCSD shall ensure that
construction personnel are made available for and attend the training and
retain documentation demonstrating attendance.
CUL-7: Paleontological resources monitoring shall be performed during
excavation activities associated with the proposed program that exceed
10 feet in depth in previously undisturbed sediments by a qualified
paleontological monitor (or cross-trained paleontological/archaeological
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monitor) meeting the standards of the SVP 2010 under the direction of
the qualified paleontologist. The monitor shall have the authority to
temporarily halt or divert work away from exposed fossils in order to
recover the fossil specimens. The qualified paleontologist, based on
observations of subsurface soil stratigraphy and/or other factors, may
increase, reduce, or discontinue monitoring, as warranted. Monitoring
may be reduced or discontinued by the qualified paleontologist, in
coordination with OCSD, based on observations of subsurface
conditions.
If construction or other project personnel discover any potential fossils
during construction, regardless of the depth of work, all work shall cease
at that location (within 100 feet) until the qualified paleontologist has
assessed the discovery and made recommendations as to the appropriate
treatment and re-assessed the depth at which monitoring shall be
required.
CUL-8: In the event of a fossil discovery by the paleontological monitor or
construction personnel, all work in the immediate vicinity of the find
shall cease. The qualified paleontologist shall evaluate the find before
restarting construction activity in the area. If it is determined that the
fossil(s) is (are) scientifically significant, the qualified paleontologist
shall recover significant fossils following standard field procedures for
collecting and curating paleontological resources, as described by the
SVP (2010).
Implementation of Mitigation Measures CUL-5 through CUL-8 would reduce impacts to
paleontological resources by requiring identification and treatment of significant
resources. Implementation of CUL-5 through CUL-8 would also require the retention of a
qualified paleontologist, paleontological monitoring during construction, and
establishment the proper protocol if paleontological resources are encountered.
Therefore, incorporation of CUL-5 through CUL-8 would reduce this impact to a level of
less than significant.
c. Potentially Significant Impact: The proposed program could result in a significant
effect on human remains because the proposed program could disturb human remains,
including those interred outside of dedicated cemeteries.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: No human remains are known to be located within the
proposed program area; however, since archaeological sites with human remains have
been documented within a ½-mile radius and given the high sensitivity of the area, there
is the possibility that human remains could be encountered by construction activities at
Plant No. 1 and Plant No. 2 for the proposed program. In the event that human remains
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are inadvertently discovered during proposed program construction activities, they could
be inadvertently damaged, which could result in a significant impact.
As identified in Section 3.4 in the Draft PEIR, Mitigation Measures CUL-9 is included to
reduce potential impacts to less than significant levels.
CUL-9: If human remains are encountered during construction activities
associated with the proposed program, OCSD or its contractor shall halt
work in the vicinity (within 100 feet) of the find and contact the Orange
County Coroner in accordance with PRC Section 5097.98 and Health
and Safety Code Section 7050.5. If the County Coroner determines that
the remains are Native American, the NAHC will be notified in
accordance with Health and Safety Code Section 7050.5, subdivision (c),
and PRC Section 5097.98. The NAHC will designate an MLD for the
remains per PRC Section 5097.98. Until the landowner has conferred
with the MLD, OCSD shall ensure that the immediate vicinity where the
discovery occurred is not disturbed by further activity, is adequately
protected according to generally accepted cultural or archaeological
standards or practices, and that further activities take into account the
possibility of multiple burials.
Implementation of Mitigation Measure CUL-9 would ensure that the proposed program’s
potential impacts to human remains impacts would be reduced to less than significant by
requiring proper treatment of human remains.
3.1.1.5 Hazards and Hazardous Materials
a. Potentially Significant Impact: The proposed program would be located on a site which
is included on a list of hazardous materials sites compiled pursuant to Government Code
Section 65962.5 and may result in potentially significant hazard impacts to the public or
the environment.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: The proposed program would be implemented entirely
within Plant No.1 and Plant No. 2, with a majority of the projects being implemented at
Plant No. 2. A database search of hazardous materials sites using the online DTSC
EnviroStor and SWRCB GeoTracker databases identified Plant No. 1 as having two
closed leaking underground storage tanks (LUST) sites, one open LUST Cleanup site and
one permitted underground storage tank (UST). Plant No. 2 has two closed LUST cases
and one permitted UST.
Construction activities associated with the proposed Collections Yard Relocation on Plant
No. 1 could encounter contaminated soil and/or groundwater during excavation, thereby
posing a health threat to construction workers, the public, and the environment. The
analysis of operational impacts associated with hazardous materials sites, mobilization of
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soil and groundwater contaminants, and groundwater quality can be found in Section 3.8,
Hydrology and Water Quality of the Draft PEIR. Impacts would be potentially
significant.
As identified in Section 3.7 in the Draft PEIR, Mitigation Measures HAZ-1 and HAZ-2
are included to reduce potential impacts to less than significant levels.
HAZ-1: Prior to the initiation of any construction requiring ground-disturbing
activities, OCSD shall complete an environmental assessment of the
proposed site to locate the potential for soil and groundwater
contamination in the program area. The recommendations set forth in the
site assessment shall be implemented to the satisfaction of applicable
agencies before and during construction.
HAZ-2: If the site assessments determine that the site has contaminated soil
and/or groundwater, a Soil and Groundwater Management Plan shall be
prepared that specifies the method for handling and disposing of
contaminated soil and groundwater prior to demolition, excavation, and
construction activities. OCSD shall be responsible for ensuring
implementation of the Plan in compliance with applicable regulations.
The implementation of Mitigation Measures HAZ-1 and HAZ-2 would require site-
specific studies to identify known hazardous materials risks or the potential for risk
related to hazardous materials. These studies would identify recommendations and
cleanup measures to reduce risk to the public and the environment from development on
hazardous materials sites. Implementation of Mitigation Measures HAZ-1 and HAZ-2
would reduce potential impacts to construction workers and the public from exposure to
unknown affected soils. Therefore, impacts to the public or the environment related to
hazardous materials sites would be less than significant.
3.1.2 Cumulative Impacts
3.1.2.1 Aesthetics
a. Potentially Significant Impact: The proposed program could create new sources of
substantial light or glare and could result in cumulatively considerable adverse effects on
day or nighttime views in the program area.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: The program vicinity is largely urbanized with
residential, commercial and industrial development. As the area continues to develop, the
addition of more residential, commercial, and industrial development could increase
additional sources of light and glare. With regard to the overall sources of light and glare
of the program vicinity, cumulative development (see Table 3-2 in Chapter 3 of the Draft
PEIR) would result in more new sources of light and glare and could result in
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cumulatively significant light and glare impacts. Because the program could result in
increased local light levels, the program’s contribution is considered cumulatively
considerable.
As identified in Section 3.1 in the Draft PEIR, Mitigation Measures AES-1 and AES-2
(defined above) are included to reduce potential cumulative impacts to less than
significant levels.
The implementation of Mitigation Measures AES-1 and AES-2 would ensure that the
proposed facilities’ contribution to cumulative light impacts would be reduced to less
than cumulatively considerable by limiting the maximum light beyond the property
boundary and complying with existing and future lighting ordinances.
3.1.2.2 Air Quality
a. Potentially Significant Impact: The proposed program could have cumulatively
considerable effects on implementation of the South Coast Air Quality Management Plan
(AQMP) because the proposed program could conflict with or obstruct implementation of
the AQMP.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: See the regional impact discussion under 3.1.2.2 (c.)
below. As discussed, the project’s contribution to cumulative regional construction
emissions of NOx would be cumulatively considerable. As identified in Section 3.2 in the
Draft PEIR, Mitigation Measure AQ-1 (defined above) is included to reduce potential
cumulative impacts to less than significant levels.
Implementation of Mitigation Measure AQ-1 would require the use of construction
equipment that would emit less NOx emissions. Mitigation Measure AQ-1 would reduce
the proposed program’s contribution to cumulative regional construction emissions of
NOx to comply with the SCAQMD thresholds as discussed in Impact 3.2-2 and Impact
3.2-3 of the Draft PEIR. With the implementation of this mitigation measure, the
proposed program’s contribution to cumulative impacts is less than cumulatively
considerable.
b. Potentially Significant Impact: The proposed program could result in cumulatively
considerable effects because the proposed program could violate an air quality standard
or contribute substantially to an existing or projected air quality violation.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
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Facts in Support of the Finding: See the regional impact discussion under 3.1.2.2 (c.)
below. As discussed, the project’s contribution to cumulative regional construction
emissions of NOx would be cumulatively considerable. As identified in Section 3.2 in the
Draft PEIR, Mitigation Measure AQ-1 (defined above) is included to reduce potential
cumulative impacts to less than significant levels.
Based on the reduction of the total NOx emissions with the implementation of Mitigation
Measure AQ-1, the proposed program’s incremental contribution to cumulative impacts
related to a violation of air quality standards from operational activities would be less
than cumulatively considerable.
c. Potentially Significant Impact: The proposed program could result in a cumulatively
considerable net increase of a criteria pollutant for which the project region is non-
attainment under an applicable federal or state ambient air quality standard.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: The SCAQMD neither recommends quantified
analyses of cumulative construction or operational emissions nor provides methodologies
or thresholds of significance to be used to assess cumulative construction or operational
impacts. Individual cumulative projects that exceed the SCAQMD recommended daily
thresholds for an individual project would cause a cumulatively considerable impact.
The program area is located within the SCAB, which is considered the cumulative study
area for air quality. The SCAB is currently classified as a state nonattainment area for
ozone, PM10, and PM2.5, and is a federal nonattainment area for ozone and PM2.5. Based
on SCAQMD’s cumulative air quality impact methodology, SCAQMD recommends that
if an individual project results in air emissions of criteria pollutants (ROG, CO, NOx,
SOX, PM10, and PM2.5) that exceed the SCAQMD’s recommended daily thresholds for
project-specific impacts, then it would also result in a cumulatively considerable net
increase of these criteria pollutants for which the program region is in nonattainment
under an applicable federal or state ambient air quality standard. As shown in Table 3.2-6
of the Draft PEIR, regional construction emissions of NOx would exceed the
SCAQMD’s daily thresholds. In addition, as shown in Table 3.2-10 of the Draft PEIR,
localized construction emissions of PM10 and PM2.5 would exceed the SCAQMD daily
thresholds. Therefore, the proposed program’s contribution to cumulative NOx for
regional construction emissions and to cumulative PM10 and PM2.5 for localized
construction emissions would be cumulatively considerable.
In addition, as discussed in Impact 3.2-4 below, the proposed program’s localized health
impact associated with construction activities would exceed regulatory thresholds.
Because the SCAQMD’s recommended cumulative impact methodology is if an
individual project results in the exceedance of regulatory thresholds then the project
would result in a cumulatively considerable impact. Therefore, because the proposed
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project would exceed the regulatory thresholds for localized health impacts during
construction, the proposed program would result in cumulatively considerable health
impacts during construction.
As identified in Section 3.2 in the Draft PEIR, Mitigation Measures AQ-1 and AQ-2
(defined above) are included to reduce potential cumulative impacts to less than
significant levels.
With implementation of Mitigation Measure AQ-1, regional emissions of NOx during the
proposed program construction would be reduced to below regulatory thresholds as
detailed in Impact 3.2-2 of the Draft PEIR. With implementation of Mitigation Measure
AQ-2, localized PM0 and PM2.5 emissions during proposed program construction
activities would be reduced to below SCAQMD’s LSTs, as detailed in Impact 3.2-4 of
the Draft PEIR. Therefore, impacts would be less than significant.
d. Potentially Significant Impact: The proposed program could result in significant and
cumulatively considerable effects associated with the exposure of sensitive receptors to
substantial pollutant concentrations.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the EIR.
Facts in Support of the Finding: As Lead Agency, the SCAQMD uses the same
significance thresholds for project-specific and cumulative impacts for all environmental
topics analyzed in an Environmental Assessment or EIR. Projects that exceed the project-
specific significance thresholds are considered by the SCAQMD to be cumulatively
considerable. This is the reason project-specific and cumulative significance thresholds
are the same. Conversely, projects that do not exceed the project-specific thresholds are
generally not considered to be cumulatively significant. As detailed under Impact 3.2-4 of
the Draft EIR, construction related localized criteria pollutants and TACs associated with
the proposed program would be significant at a project level and would be cumulatively
considerable.
As identified in Section 3.2 in the Draft PEIR, Mitigation Measures AQ-1 and AQ-2
(defined above) are included to reduce potential cumulative impacts to less than
significant levels.
As stated previously, the cumulative thresholds for air quality are identical to the program
level thresholds, therefore projects that are less than significant with or without
mitigation at the project level would be less than cumulatively considerable. Therefore,
consistent with the program level analysis, with the implementation of Mitigation
Measures AQ-1 and AQ-2, the proposed program’s contribution to cumulative localized
construction emissions associated with criteria air pollutants and TACs would be reduced
to below regulatory thresholds and the proposed program’s contribution to cumulative
impacts would be less than cumulatively considerable.
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e. Potentially Significant Impact: The proposed program could result in cumulatively
considerable effects from the creation of objectionable odors affecting a substantial
number of people.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: Future cumulative development in the vicinity of the
proposed program has the potential to create odors. Construction activities associated
with future development are expected to result in less than significant odor impacts.
Operational impacts from cumulative development could result in significant odor
impacts. Because the proposed program would result in potentially significant odor
impacts due to the demolition of existing digesters, the proposed program’s incremental
contribution to cumulative odor impacts would be cumulatively considerable without
mitigation.
As identified in Section 3.2 in the Draft PEIR, Mitigation Measure AQ-3 (defined above)
is included to reduce potential cumulative impacts to less than significant levels.
Implementation of Mitigation Measure AQ-3 would minimize the generation of nuisance
odors during and after demolition of existing digesters, thereby reducing the program’s
potential impacts to less than significant levels. Therefore, the program’s contribution to
cumulative impacts regarding odor would be considered less than cumulatively
considerable.
3.1.2.3 Biological Resources
a. Potentially Significant Impact: The proposed program could have cumulatively
considerable effects on some avian species during nesting activities but would not have
an adverse effect, either directly or through habitat modifications, on species identified as
a candidate, sensitive, or special-status species in local or regional plans, policies, or
regulations, or by the CDFW or USFWS.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: Future construction and operational activities
associated with cumulative development (see Table 3-2 in Chapter 3 of the Draft PEIR)
may result in impacts to nesting birds as well as sensitive plant and wildlife species.
These potential cumulative impacts could result from removal of habitat or indirect
through noise-generating activities. Because the construction activities associated with
the proposed program could result in significant impacts to nesting birds, the proposed
program would contribute to cumulative impacts to nesting birds.
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As identified in Section 3.3 in the Draft PEIR, Mitigation Measure BIO-1 (defined
above) is included to reduce potential cumulative impacts to less than significant levels.
Implementation of Mitigation Measure BIO-1 would reduce the program’s contribution
to cumulative impacts to nesting birds to less than significant by either conducting
construction activities during the non-nesting season or conducting a survey to establish a
suitable nesting habitat buffer as well as having a qualified biologist to monitor the
activities of the active nests within the buffer area during nesting season when
construction activities occur.
3.1.2.4 Cultural Resources
a. Potentially Significant Impact: The proposed program could result in a cumulatively
considerable effect on an archaeological resource because the proposed program has the
potential to cause a substantial adverse change in the significance of an archeological
resource pursuant to CEQA Guidelines Section 15064.5.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: The proposed program vicinity is located within a
favorable area (near water sources) for prehistoric inhabitance and the proposed program
vicinity is known to contain archaeological resources. Thus, there is the potential for
ongoing and future development projects in the vicinity to disturb known or unknown
archaeological resources.
The potential construction impacts of the proposed program, in combination with other
projects in the area, could contribute to a cumulatively significant impact on
archaeological resources. Because the proposed program could result in significant
impacts to archaeological resources, the proposed program’s contribution to cumulative
impacts would be cumulatively considerable.
As identified in Section 3.4 in the Draft PEIR, Mitigation Measures CUL-1 through
CUL-4 (defined above) are included to reduce potential cumulative impacts to less than
significant levels.
The implementation of Mitigation Measures CUL-1 through CUL-4 would include the
retention of a qualified archaeologist, conducting archaeological resources sensitivity
training for all construction personnel, archaeological and Native American monitoring
during ground-disturbing activities, and establishing the proper protocol in the event of
an unanticipated discovery of archaeological materials. The implementation of these
measures would reduce the program’s contribution to cumulative impacts to
archaeological resources that could qualify as historical resources or unique
archaeological resources to less than cumulatively significant.
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b. Potentially Significant Impact: The proposed program could result in a significant and
cumulatively considerable effect on a unique paleontological resource because the
proposed program could directly or indirectly destroy a unique paleontological resource
or site or unique geologic feature.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the EIR.
Facts in Support of the Finding: As future cumulative development occurs in the
program area, there is a potential that future growth could require excavation activities.
These activities could be required within older Quaternary deposits that may encounter
significant fossil vertebrate specimens. Therefore, cumulative development could result
in potential significant cumulative impacts to paleontological resources. Because the
proposed program includes excavations that could occur within older Quaternary
deposits, significant fossil vertebrate specimens could be found. Therefore, the proposed
program could result in cumulatively considerable effects on paleontological resources.
Implementation of Mitigation Measures CUL-5 through CUL-8 would reduce the
program’s contribution to cumulative impacts to paleontological resources by requiring
identification and treatment of significant resources. Implementation of CUL-5 through
CUL-8 would also require the retention of a qualified paleontologist, paleontological
monitoring during construction, and establishment the proper protocol if paleontological
resources are encountered. Therefore, incorporation of CUL-5 through CUL-8 would
reduce the program’s contribution to cumulative paleontological resources impacts to less
than cumulatively significant.
c. Potentially Significant Impact: The proposed program could result in a cumulatively
significant effect on human remains because the proposed program could disturb human
remains, including those interred outside of dedicated cemeteries.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: The proposed program area is largely urbanized with
industrial development. However, since archaeological sites with human remains have
been documented within a ½-mile radius of the proposed program and given the high
sensitivity of the area, there is the possibility that construction activities associated with
cumulative development could impact unknown human remains. Because the proposed
program could encounter and significantly impact human remains, the program could
contribute to significant cumulative impacts to human remains and result in result in
cumulatively considerable could result in cumulatively considerable impacts to human
remains.
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As identified in Section 3.4 in the Draft PEIR, Mitigation Measure CUL-9 (defined
above) is included to reduce potential cumulative impacts to less than significant levels.
Implementation of Mitigation Measure CUL-9 would ensure that the proposed program’s
contribution to cumulative human remains impacts would be reduced to less than
cumulatively considerable by requiring proper treatment of human remains.
3.1.2.5 Hazards and Hazardous Resources
a. Potentially Significant Impact: The proposed program would be located on a site which
is included on a list of hazardous materials sites compiled pursuant to Government Code
Section 65962.5 and may result in cumulatively considerable hazard impacts to the public
or the environment.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: The program vicinity is largely urbanized with
residential, commercial and industrial development. As the area continues to develop, the
addition of developments could be located on sites that are included on a list of hazardous
materials sites. Remediation of contamination found on site as required under Mitigation
Measures HAZ-1 and HAZ-2 would reduce any contribution to the cumulative condition.
Impacts would be less than cumulatively considerable.
As identified in Section 3.4 in the Draft PEIR, Mitigation Measures HAZ-1 and HAZ-2
(defined above) are included to reduce potential cumulative impacts to less than
significant levels.
The implementation of Mitigation Measures HAZ-1 and HAZ-2 would ensure that the
proposed facilities’ contribution to cumulative development on the open LUST site at
Plant No. 1 would be reduced to less than cumulatively considerable by requiring site-
specific studies to identify known hazardous materials risks or the potential for risks
related to hazardous materials and affected soils and groundwater. These studies would
include recommendations and cleanup measures to reduce risk to the public and the
environment from development on hazardous materials sites. Implementation of
Mitigation Measures HAZ-1 and HAZ-2 would reduce potential impacts to construction
workers and the public from exposure to unknown affected soils.
Final
ORANGE COUNTY SANITATION DISTRICTBIOSOLIDS
MASTER PLAN PROJECT NO. PS15-01
Environmental Findings
State Clearinghouse Number 2017071026
Prepared for May 2018
Orange County Sanitation District
Final
ORANGE COUNTY SANITATION DISTRICTBIOSOLIDS
MASTER PLAN PROJECT NO. PS15-01
Environmental Findings
State Clearinghouse Number 2017071026
Prepared for May 2018
Orange County Sanitation District
626 Wilshire Boulevard
Suite 1100
Los Angeles, CA 90017
213.599.4300
www.esassoc.com
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OCSD Biosolids Master Plan PEIR i ESA / 150626
Environmental Findings May 2018
Preliminary − Subject to Revision
TABLE OF CONTENTS
OCSD Biosolids Master Plan
Project No. PS15-01
Environmental Findings
Page
1. Background and Introduction ....................................................................................... 1
1.1 Project Overview ................................................................................................ 1
1.2 Public Involvement and PEIR Scoping .............................................................. 1
1.3 PEIR Certification and Project Approval Process .............................................. 2
1.3.1 Findings Required Under CEQA .......................................................... 2
1.3.2 Significant Effects and Mitigation Measures ........................................ 3
1.3.3 Mitigation Monitoring and Reporting Program ..................................... 3
1.3.4 Certification of the PEIR and Adoption of Findings.............................. 3
2. Program Summary ......................................................................................................... 4
2.1 Program Location ............................................................................................... 4
2.2 Program Description ........................................................................................... 4
2.3 Program Objectives ............................................................................................ 4
2.4 Record of Proceedings ....................................................................................... 6
2.5 Custodian and Location of Records ................................................................... 7
3. Environmental Findings ................................................................................................ 7
3.1 Findings Regarding Environmental Impacts Which Can Be Mitigated to
Less than Significant .......................................................................................... 7
3.1.1 Project Impacts ..................................................................................... 7
3.1.2 Cumulative Impacts ............................................................................ 21
4. Feasibility of Alternatives ............................................................................................ 28
4.1 Alternative 1: No Program Alternative .............................................................. 29
4.1.1 Description.......................................................................................... 29
4.1.2 Impact Analysis .................................................................................. 29
4.1.3 Findings for Alternative 1: No Program Alternative............................ 32
4.2 Alternative 2: Baselines, Mesophilic Digestion, Class B .................................. 32
4.2.1 Description.......................................................................................... 32
4.2.2 Impact Analysis .................................................................................. 33
4.2.3 Findings for Alternative 2: Baseline, Mesophilic Digestion,
Class B ............................................................................................... 37
4.3 Alternative 3: Proposed Program Without Food Waste Facilities .................... 37
4.3.1 Description.......................................................................................... 37
4.3.2 Impact Analysis .................................................................................. 38
4.3.3 Findings for Alternative 3: Proposed Program Without Food
Waste Facilities .................................................................................. 41
4.4 Environmentally Superior Alternative ............................................................... 41
List of Tables
1 OCSD BMP Projects .................................................................................................. 4
OCSD Biosolids Master Plan PEIR 1 ESA / 150626
Environmental Findings May 2018
Preliminary − Subject to Revision
OCSD BIOSOLIDS MASTER PLAN PEIR
Environmental Findings
1. Background and Introduction
1.1 Project Overview
The Orange County Sanitation District (OCSD) has completed a Program Environmental Impact
Report (PEIR) (State Clearinghouse Number 2017071026) for the Biosolids Master Plan (BMP),
Project No. PS15-01. The OCSD is the Lead Agency for the purposes of preparing and certifying
the PEIR pursuant to Sections 15050 and 15367 of the California Environmental Quality Act
(CEQA) Guidelines (California Code of Regulations, Section 15000 et seq.)
The purpose of the PEIR is to evaluate the potential environmental impacts of the proposed BMP.
In compliance with Section 21002.1 of CEQA and Section 15002 of the State CEQA Guidelines,
the OCSD, as Lead Agency, has prepared the PEIR to: (1) inform the general public, the local
community, responsible and interested public agencies and the OCSD’s decision-making bodies
and other organizations, entities, and interested persons of the potential environmental effects of
the proposed program, feasible measures to reduce potentially significant environmental effects,
and alternatives that could reduce or avoid the significant effects of the proposed program,
(2) enable OCSD to consider environmental consequences when deciding whether to approve the
proposed program, and (3) to satisfy the substantive and procedural requirements of CEQA.
1.2 Public Involvement and PEIR Scoping
The PEIR complies with the provisions of CEQA (California Public Resources Code, Sections
21000 et seq.), the State CEQA Guidelines (California Code of Regulations, Section 15000
et seq.) and OCSD’s Procedures for Implementing the State CEQA Guidelines. In compliance
with CEQA, OCSD has solicited and considered comments from Responsible and Trustee
Agencies, members of the public, and other interested parties during the proposed program’s
various environmental review processes:
• In accordance with CEQA Guidelines Sections 15063 and 15082, OCSD prepared and
distributed a Notice of Preparation (NOP) of a PEIR. The NOP was distributed on July 14,
2017 to governmental agencies, organizations, and persons who may be interested in the
program.
• In compliance with Section 21083.9 of CEQA and Section 15082 (c)(1) of the State CEQA
Guidelines, OCSD held a public scoping meeting on July 31, 2017, to receive public and
agency comments.
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• Comments received from the public and agencies during the public review period for the
NOP and the public scoping meeting were considered in the preparation of the PEIR for the
proposed program.
• In February 2018, a Draft PEIR was prepared for the proposed program in accordance with
then-current CEQA regulations and guidelines. The Draft PEIR was circulated for a 45-day
public review period on February 14, 2018. Notification was provided to the State
Clearinghouse; to local, state, and federal agencies; and to all interested parties and
jurisdictions pursuant to the requirements of Section 15087 of the State CEQA Guidelines.
There were eight letters/correspondences received by OCSD during the 45-day review period.
Comments within each letter/correspondence were evaluated and responded to in accordance
with Section 15088 of the State CEQA Guidelines.
1.3 PEIR Certification and Project Approval Process
1.3.1 Findings Required Under CEQA
The Board of Directors (the decision-making body) of OCSD (the CEQA Lead Agency) will
determine whether to certify the Final PEIR for the program. The Final PEIR, as required by State
CEQA Guidelines Sections 15089 and 15132, consists of the Draft Program Environmental
Impact Report (Draft PEIR) (SCH No. 2017071026), the Response to Comments document, and
any other information added by OCSD. The Response to Comments document includes
comments received on the Draft PEIR, a list of persons, organizations, and public agencies
commenting on the Draft PEIR, and the responses of OCSD as “Lead Agency” to significant
environmental points raised in the review and consultation process. Because the Draft PEIR
identified potentially significant environmental impacts, the Board of Directors must also make
certain “findings” as part of its action to certify that the PEIR has been completed in compliance
with CEQA and to approve the proposed program. Pursuant to CEQA Section 21081 and State
CEQA Guidelines Section 15091, no public agency shall approve or carry out a project for which
an environmental impact report has been certified, which identifies one or more significant effects
on the environment that would occur if the project is approved or carried out, unless the public
agency makes one or more findings for each of those significant effects, accompanied by a brief
explanation of the rationale of each finding. The possible findings, which must be supported by
substantial evidence in the record, are:
(1) Changes or alterations have been required in or incorporated into, the program which
avoid or substantially lessen the significant environmental effect as identified in the Final
PEIR.
(2) Such changes or alterations are within the responsibility and jurisdiction of another public
agency and not the agency making the finding. Such changes have been adopted by such
other agency or can and should be adopted by such other agency.
(3) Specific economic, legal, social, technological, or other considerations, including
provision of employment opportunities for highly trained workers, make infeasible the
mitigation measures or program alternatives identified in the Final PEIR.
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1.3.2 Significant Effects and Mitigation Measures
As part of the approval of the BMP and the certification of the PEIR for the proposed program,
CEQA requires the Lead Agency—in this case, OCSD, acting through the Board—to make
written findings with respect to each significant environmental impact of the program. These
findings need to be accompanied by a brief explanation of the rationale for each finding, and any
mitigation measures used to reduce or substantially lessen the impact. The significance of the
potential impacts of the proposed program was determined through application of the appropriate
thresholds of significance for each resource area, as defined in CEQA Appendix G.
Section 15093(a) of the CEQA Guidelines state that if specific economic, legal, social,
technological, or other benefits of the proposed program outweigh the unavoidable adverse
environmental effects, the adverse environmental effects may be considered “acceptable” and the
OCSD Board of Directors may adopt a Statement of Overriding Considerations to that effect. The
Draft PEIR identified several significant environmental effects (or “impacts”) resulting from
implementation of the proposed program. All of these significant effects can be reduced to less
than significant through the adoption of feasible mitigation measures. The Draft PEIR found that
proposed program would not result in any significant and unavoidable impacts, and therefore, a
Statement of Overriding Considerations would not be required to be adopted. Section 3 describes
the program and cumulative effects and outlines OCSD’s findings with respect to each of these
environmental effects of the proposed program.
1.3.3 Mitigation Monitoring and Reporting Program
A Mitigation Monitoring and Reporting Program (MMRP) has been prepared to monitor and
report the implementation of the mitigation measures identified for the proposed program. The
MMRP will be adopted by the Board of Directors concurrently with these findings, and will be
implemented by OCSD during the proposed program’s planning horizon; and through the
program review, construction and post-construction periods of individual projects. To the extent
that these findings conclude that all mitigation measures outlined in the PEIR are feasible and
have not been modified, superseded, or withdrawn, OCSD hereby binds itself to implement these
measures. These findings, in other words, are not merely informational, but rather constitute a
binding set of obligations that will come into effect when the Board of Directors formally
approves the proposed program.
1.3.4 Certification of the PEIR and Adoption of Findings
The Board of Directors will review and consider the information contained in the PEIR, as well
as submissions from public officials, public agencies and the general public. Prior to program
approval, the Board of Directors shall certify that the PEIR reflects OCSD’s independent
judgment and analysis. Having considered the foregoing information, as well as any and all other
information in the record, the Board of Directors shall make findings pursuant to CEQA Section
21081. In accordance with the provisions of CEQA and the State CEQA Guidelines, the Board of
Directors shall adopt the findings as part of its certification of the PEIR for the proposed program.
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2. Program Summary
2.1 Program Location
OCSD facilities are located in northwestern Orange County, California. All proposed projects
would be located within OCSD Plant No. 1 and Plant No. 2 boundaries. Therefore, for purposes
of the PEIR, the “program area” includes Plants No. 1 and No. 2. Plant No. 1 is located at 10844
Ellis Avenue, Fountain Valley, California, and is bound by Ellis Avenue to the north, Ward Street
to the west, Garfield Avenue to the south, and the Santa Ana River (SAR) and SAR Trail to the
east. Residential neighborhoods are located west of Ward Street. Plant No. 1 is located within the
City of Fountain Valley. The Fountain Valley General Plan designates Plant No. 1 as a Specific
Plan Area and the area is zoned as Specific Plan-Orange County Sanitation District.
Plant No. 2 is located at 22212 Brookhurst Street, Huntington Beach, California, and bound by
residential neighborhoods located approximately 375 feet north of the intersection of Baybreeze
Drive and Brookhurst Street to the north, Brookhurst Street and residential neighborhoods to the
west, the SAR and SAR Trail to the east, and Talbert Marsh, Pacific Coast Highway (PCH) and
the Pacific Ocean to the south. The City of Huntington Beach General Plan designates Plant No. 2
as a Public (P) land use and zoned for Industrial Limited (IL) and Residential Agriculture with an
Oil Overlay (RA-O). The program area is also located within the City of Huntington Beach’s
Coastal Zone and is subject to the City’s Local Coastal Program.
The majority of the proposed program components would be constructed entirely within the
existing Plant No. 2 property. The proposed facilities would be implemented within the southwest
corner of Plant No. 2 adjacent to the existing biosolids handling facilities. Within Plant No. 2, the
program area encompasses approximately 16 acres. Within Plant No. 1, the program area
encompasses approximately 2 acres.
2.2 Program Description
The proposed program consists of nine projects that are necessary to upgrade Plant No. 2 solid
handling facilities to align with OCSD’s goals and objectives. These nine projects would be
implemented over the next 20 years. Table 1 summarizes the individual BMP projects.
2.3 Program Objectives
Section 15124(b) of the CEQA Guidelines states that the project description shall contain “a
statement of the objectives sought by the proposed project.” Section 15124(b) further states that
“the statement of objectives should include the underlying purpose of the project.” The
underlying purpose of the proposed program is to provide for flexible and sustainable biosolids
handling in the future. As set forth by the CEQA Guidelines, the list of objectives that OCSD
seeks to achieve for the proposed program is provided below.
• Replace aging facilities and mitigate the structural and seismic risks for onsite biosolids
structures.
• Phase-out the diversion of biosolids organics as an alternative daily cover for landfills.
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• Transition from Class B to Class A biosolids quality at Plant No. 2 to increase biosolids
management diversity for end users of biosolids.
• Receive pre-processed food waste (source separated organics) for co-digestion to assist in
diverting organics from landfills and to increase digester gas production used as a renewable
energy.
TABLE 1
OCSD BMP PROJECTS
OCSD
Funding
No.
Project
No. Project Name Description Construction Years
P2-125 P2-501 Plant No. 2
Southwest
Perimeter
Screening
P2-501 would improve or replace the perimeter
screening to provide a visual buffer for all proposed
facilities and associated construction activities along
Brookhurst Street and Talbert Marsh. The perimeter
screening would be extended along Brookhurst
Street and up to approximately 1,030 feet along
Talbert Marsh.
2019 to 2020
P2-124 P2-502 Interim Food Waste
Receiving Facility
An interim food waste facility with a capacity up to
250 wet tons per day will be built to satisfy initial co-
digestion needs. The food facility would include two
20,000-gallon tanks and ancillary facilities such as
pumps and odor control treatment. The interim food
waste facility will be replaced with an ultimate food
waste facility (P2-506).
2018 to 2020
P2-126 P2-503A Plant No. 2
Warehouse
Relocation
The existing 21,000-square-foot, above-grade
warehouse would be demolished and then
reconstructed at a new location on Plant No. 2
approximately 1,600 feet north of the existing
facility.
2021 to 2023
P2-127 P2-503B Plant 2 Collections
Yard Relocation
The existing 38,000-square-foot collections yard
(parking lot) would be relocated, potentially to Plant
No. 1. The specific location is not known at this
time. The relocated collections yard would provide
adequate space and truck paths to and from Plant
No.1 or Plant No. 2, similar to the existing footprint.
2021 to 2023
P2-128 P2-504,
504A,
504B
Temperature
Phased Anaerobic
Digestion (TPAD)
Digester Facility at
Plant No. 2
This project would construct six 110-foot-diameter,
40-foot-tall (above ground) digesters designed to
operate in either mesophilic or thermophilic
operation, and TPAD sludge cooling facilities, which
include a pump station, ultrafiltration/nanofiltration
facilities, sludge cooling heat exchangers, and a
power building.
All new digesters (pairs) would share an electrical
control room that would house various pumps, fans,
pipelines, and other ancillary facilities.
2025 to 2030
Six 400,000-gallon, 37-feet above ground, Class A
batch tanks would be constructed to produce Class
A biosolids per U.S. Environmental Protection
Agency (USEPA) 503 regulations through batch
holding over a specified time and temperature. The
Class A batch tanks would require other ancillary
equipment such as pumps, heat exchangers, and
grinders.
The proposed 33-foot-diameter, 30-foot-high (above
ground) Digester Feed Facility (DFF) would replace
the existing Sludge Blending Facility where primary
sludge and scum is blended and fed to the
digesters.
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OCSD
Funding
No.
Project
No. Project Name Description Construction Years
The DFF would include thickened sludge tanks, and
ancillary facilities, such as fans, grinders, pumps,
and carbon and bioscrubbers.
P2-129 P2-504C,
P2-505
Digester P, Q, R,
and S Replacement
P2-504C would relocate the existing ferric facility,
which currently feeds three digester segments. The
new structure would be 38 by 51 feet. The
relocation will include all of the match pumps, tanks,
and existing equipment.
2038 to 2040
P2-505 would consist of the demolition of four
existing digesters (P, Q, R, and S) and Power
Building C. Digesters P, Q, R, and S will be rebuilt
in place, two at a time. Digesters P, Q, R, and S
would have an inner diameter of 105 feet and height
of 38 feet above ground.
2028 to 2033
P2-506 P2-506 Ultimate Food
Waste Receiving
Facility
Following operation of the interim food waste
receiving facility (P2-502), P2-506 will allow for
expansion of the Source Separated Organics (SSO)
receiving program through construction of a larger
capacity food waste receiving station to replace the
interim facility.
The ultimate food waste facility would include a total
of four, 12-foot-diameter, 30-foot-tall 20,000-gallon
tanks, recirculation and digester feed pumps, and
odor-control treatment carbon canisters.
2035 to 2037
P2-507 P2-507 Replace Digesters I,
J, K (Relocate
Digester Holders)
P2-507 would consist of the demolition of seven
digesters (I, J, K, M, N, O, and T) and relocation of
three digesters (I, J, and K) with a diameter of 84
feet and height of 37 feet (above ground). These
new digesters would serve as mesophilic digesters
and holders capable of operation as mesophilic
digesters.
An above-grade equipment room would be built
between each pair of digesters. The equipment
rooms would house ancillary facilities such as fans,
pumps and pipelines. Each equipment room would
be 40 feet by 50 feet and up to 40 feet in height
above ground.
2033 to 2038
P2-508 P2-508 Digester Demolition P2-508 demolishes the six remaining digesters,
Digesters C, D, E, F, G, and H, to free up site
footprint for future treatment process facilities.
2035 to 2040
2.4 Record of Proceedings
For purposes of CEQA and these findings, the Record of Proceedings for the proposed program
consists of the following documents and other evidence, at a minimum:
• The NOPs and all other public notices issued by OCSD in conjunction with the proposed
program.
• The Final PEIR document for the proposed program which consists of an Introduction to
Response to Comments, a Comment Letters listing, Response to Comments, Corrections and
Additions to the Draft PEIR, and the MMRP.
• The Draft PEIR, and all appendices thereto.
• The documents, reports, and technical memoranda included or referenced in the technical
appendices of the Draft PEIR.
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• All documents, studies, Environmental Impact Reports (EIRs), or other materials
incorporated by reference in the Draft PEIR and Response to Comments.
• OCSD Staff Reports for the program.
• Any documents expressly cited in these findings.
• Any other relevant materials required to be in the record of proceedings by Public Resources
Code Section 21167.6(e) (excluding privileged materials).
2.5 Custodian and Location of Records
The documents and other materials that constitute the administrative record for OCSD’s actions
related to the program are located at the OCSD, Administrative Office Building at Plant No. 1,
Engineering Planning Division – 10844 Ellis Avenue, Fountain Valley, California. OCSD is the
custodian of the record of proceedings for the program. Copies of these documents, which
constitute the record of proceedings are, and at all relevant times have been and will be, available
upon request at OCSD’s administrative office. This information is provided in compliance with
Public Resources Code Section 21081.6(a)(2) and CEQA Guideline Section 15091(e).
3. Environmental Findings
3.1 Findings Regarding Environmental Impacts Which Can
Be Mitigated to Less than Significant
Environmental impacts identified in the PEIR as potentially significant, but which OCSD finds
can be mitigated to less than significant through the imposition of feasible mitigation measures
identified in the PEIR and set forth herein, are described in this section.
3.1.1 Project Impacts
3.1.1.1 Aesthetics
a. Potentially Significant Impact: The proposed program could create new sources of
substantial light or glare and result in adverse effects on daytime or nighttime views in
the program area.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: The proposed facilities would be located within the
existing Plant No. 1 and Plant No. 2 boundaries, which currently contain lighting within
the interior and exterior of structures. Plant No. 1 and Plant No. 2 are located within an
urban area, developed with residential, commercial, and industrial uses. Implementation
of the proposed projects could result in new exterior nighttime lighting for operational
and security purposes within Plant No. 1 and Plant No. 2. Though not anticipated, the
increase in lighting within the plants could result in spillover lighting onto neighboring
residential or commercial uses, or the SAR Trail and Talbert Marsh. Therefore, increase
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lighting within Plant No. 1 and Plant No. 2 could represent a potential significant lighting
impact.
As identified in Section 3.1 in the Draft PEIR, Mitigation Measures AES-1 and AES-2
are included to reduce potential impacts to less than significant levels.
AES-1: All new permanent exterior lighting associated with proposed program
components shall be shielded and directed downward to avoid any light
intrusion to surrounding uses.
AES-2: Development of the proposed program and associated facilities shall
comply with existing and future lighting ordinances for the cities of
Fountain Valley and Huntington Beach.
The implementation of Mitigation Measures AES-1 and AES-2 will limit the maximum
light beyond the property boundary and comply with existing and future lighting
ordinances so that lighting impacts on adjacent uses would be less than significant.
3.1.1.2 Air Quality
a. Potentially Significant Impact: The proposed program could have significant effects on
implementation of the South Coast Air Quality Management Plan (AQMP) because the
proposed program could conflict with or obstruct implementation of the AQMP.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: As described in Section 3.2 of the Draft PEIR, the
AQMP was adopted by the South Coast Air Quality Management District (SCAQMD) as
a program to lead the Air Basin into compliance with several criteria pollutant standards
and other federal requirements. It relies on emissions forecasts based on demographic and
economic growth projections provided by SCAG’s Regional Transportation Program
(SCAQMD, 2012). SCAG is charged by California law to prepare and approve “the
portions of each AQMP relating to demographic projections and integrated regional land
use, housing, employment, and transportation programs, measures and strategies”
(SCAQMD, 2012). As discussed previously, projects whose growth is included in the
SCAG projections used in the formulation of the AQMP are considered to be consistent
with the plan and not to interfere with its attainment. The SCAQMD recommends that,
when determining whether a project is consistent with the current AQMP, a Lead Agency
must assess whether the project would directly obstruct implementation of the plan and
whether it is consistent with the demographic and economic assumptions upon which the
plan is based.
The construction activities associated with the proposed program could obstruct
implementation of the AQMP because, as detailed in Impact 3.2-2 of the Draft PEIR, its
construction emissions would exceed the daily nitrogen oxides NOx regional emissions
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significance threshold. Because the proposed program’s NOx regional emissions exceed
the threshold and NOx contributes to the formation of ozone, the proposed program
would contribute to the Air Basin’s nonattainment of the National Ambient Air Quality
Standards for ozone. Therefore, the proposed program could result in a significant impact
on the implementation of the AQMP.
As identified in Section 3.2 in the Draft PEIR, Mitigation Measure AQ-1 is included to
reduce potential impacts to less than significant levels.
AQ-1: Mobile off-road construction equipment (wheeled or tracked) used
during construction of the individual projects of the proposed program
that may exceed SCAQMD daily thresholds for NOx shall meet the
USEPA Tier 4 final standards, either as original equipment or equipment
retrofitted to meet the Tier 4 final standards. A copy of each unit’s
certified tier specification or model year specification shall be available
upon request at the time of mobilization of each applicable unit of
equipment. For projects that would not individually emit NOx above the
SCAQMD daily threshold, OCSD or the contractor shall prepare
emissions calculations based on equipment to be used that show
emissions are below the threshold. These emissions estimates must be
maintained at OCSD headquarters for reference, and OCSD must
confirm that the equipment used during actual construction is adequately
characterized.
Implementation of Mitigation Measures AQ-1 would reduce regional construction
emissions of NOx to comply with the SCAQMD thresholds. Implementation of this
mitigation measure would reduce impacts to less than significant levels.
b. Potentially Significant Impact: The proposed program could violate an air quality
standard or contribute substantially to an existing or projected air quality violation.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: Construction activities associated with the proposed
program would generate pollutant emissions from the following construction activities:
(1) demolition, site preparation, grading, and excavation (as discussed in the
Methodology section above, only grading is modeled for maximum daily emissions); (2)
construction workers traveling to and from project site; (3) delivery and hauling of
construction supplies to, and debris from, the project site; (4) fuel combustion by onsite
construction equipment; (5) building construction, application of architectural coatings,
and paving. These construction activities would temporarily create emissions of dust,
fumes, equipment exhaust, and other air contaminants. The amount of emissions
generated on a daily basis would vary, depending on the intensity and types of
construction activities occurring simultaneously.
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Construction emissions are considered short term and temporary, but have the potential to
represent a significant impact with respect to air quality. Particulate matter (PM) (i.e.,
PM10 and PM2.5) are among the pollutants of greatest localized concern with respect to
construction activities. Particulate emissions from construction activities can lead to
adverse health effects and nuisance concerns, such as reduced visibility and soiling of
exposed surfaces. Particulate emissions can result from a variety of construction
activities, including excavation, grading, demolition, vehicle travel on paved and unpaved
surfaces, and vehicle and equipment exhaust. Construction emissions of PM can vary
greatly depending on the level of activity, the specific operations taking place, the
number and types of equipment operated, local soil conditions, weather conditions, and
the amount of earth disturbance. Construction assumptions are summarized in the
Methodology section and detailed in Appendix B of the Draft PEIR.
Emissions of ozone precursors such as reactive organic gases (ROGs)/volatile organic
compounds (VOCs) and NOX are primarily generated from mobile sources and vary as a
function of vehicle trips per day associated with debris hauling, delivery of construction
materials, vendor trips, and worker commute trips, and the types and number of heavy-
duty, off-road equipment used and the intensity and frequency of their operation. A large
portion of construction-related ROG emissions also result from the application of
architectural coatings and vary depending on the amount of coatings applied each day.
It is mandatory for all construction projects in the South Coast Air Basin (SCAB) to
comply with SCAQMD Rule 403 for controlling fugitive dust. Specific Rule 403 control
requirements include, but are not limited to, applying water in sufficient quantities to
prevent the generation of visible dust plumes, applying soil binders to uncovered areas,
reestablishing ground cover as quickly as possible, using a wheel-washing system to
remove bulk material from tires and vehicle undercarriages before vehicles exit the
construction site, covering all trucks hauling soil with a fabric cover and maintaining a
freeboard height of 12 inches, and maintaining effective cover over exposed areas.
Compliance with Rule 403 and Rule 1113 (governing VOC content of architectural
coatings), as pre-existing regulatory requirements, were accounted for in the construction
emissions modeling. Rule 1113 is included as part of the default modeling scenario.
Table 3.2-6 of the Draft PEIR summarizes the modeled peak daily emissions of criteria
air pollutants and ozone precursors associated with the proposed program’s worst-case
construction scenario (using the significance criteria provided in Table 3.2-4 of the Draft
PEIR). The peak daily emissions generated for the proposed program’s construction
period are identified. The proposed program would exceed the SCAQMD’s daily regional
significance threshold for NOx. Therefore, construction phase emissions for NOx would
be significant.
Further, because the program will be implemented in phases, there is a reasonable
possibility that construction activities of later phase biosolids facilities could overlap with
operation of earlier phase facilities. In order to determine the combined significance of
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these activities, the construction and operational activities are combined and compared to
the SCAQMD’s operational threshold.
Operational activities would begin with the construction of the Interim Food Waste
Receiving Facility by 2020. This would increase daily truck activities by eight daily trips.
There would be no new flare operations, new natural gas usage, or new area source
emissions as the food waste receiving facility is strictly tanks and electric pumps. Total
new trips at buildout in 2038 would be 34. Therefore, between 2020 and 2038, total
operational emissions would represent approximately 24 percent of the total program
mobile sources.
Additionally, maximum daily construction emissions used a default 2018 aggregate truck
fleet to determine emissions from haul trucks. Because trucks used to haul debris from
construction waste and deliver construction equipment would be contracted, the default
fleet mix would change with each subsequent year. This means that emissions from the
aggregate truck fleet in 2021 (for a new program within the master plan beginning in
2021) would differ from the emissions for the aggregate fleet mix for the max year 2018.
Therefore, to accurately predict haul and vendor emissions future construction activities,
the emissions for haul and vendor trucks have been adjusted accordingly. Calculations
assumptions and calculations are included in Attachment 2 of the Final PEIR. Table 3.2-
7A of the Final PEIR shows the unmitigated combined construction and operational
emissions. As shown, the proposed program would exceed the SCAQMD’s daily regional
significance threshold for NOx. Therefore, construction phase emissions for NOx would
be significant without mitigation.
As identified in Section 3.2 in the Draft PEIR and Chapter 4 of the Final PEIR,
Mitigation Measure AQ-1 is required to reduce potential impacts to less than significant
levels.
With the implementation of Mitigation Measure AQ-1, the proposed program’s
maximum daily construction emissions would be reduced to below regulatory thresholds
as shown in Table 3.2-8 of the Draft PEIR and Table 3.2-8A of the Final PEIR. Based on
the reduction of the total NOx emissions with the implementation of Mitigation Measure
AQ-1, impacts related to a violation of air quality standards from combined construction
and operational activities associated with the proposed program would be less than
significant.
c. Potentially Significant Impact: The proposed program could result in significant effects
associated with the exposure of sensitive receptors to substantial pollutant concentrations.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: The daily onsite construction emissions generated by
the proposed program were evaluated against SCAQMD’s Localized Significance.
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Threshold (LSTs) for a 2-acre site as a screening-level analysis to determine whether the
emissions would cause or contribute to adverse localized air quality impacts. The nearest
off-site sensitive receptors are the residential dwelling located directly west of the Plant
No. 2 across Brookhurst Street. Because the mass rate look-up tables provided by
SCAQMD only provide LSTs at receptor distances of 82, 164, 328, 656, and 1,640 feet,
the LSTs for a receptor distance of 82 feet are used to evaluate the potential localized air
quality impacts associated with the proposed program’s peak day construction emissions.
Table 3.2-9 of the Draft PEIR identifies the daily localized onsite emissions that are
estimated to occur during the proposed program’s worst-case construction scenario. The
daily emissions would exceed regulatory thresholds for NOx, PM10 and PM2.5.
Further, the proposed program would expose sensitive receptors to substantial
concentrations of toxic air contaminants if the proposed program would emit
carcinogenic materials or TACs that exceed the maximum incremental cancer risk of
10 in one million or a cancer burden greater than 0.5 excess cancer cases (in areas greater
than or equal to 1 in 1 million) or an acute or chronic hazard index of 1.0. Construction-
related cancer risk and acute/chronic hazards were estimated and compared to this
threshold. Health risk calculations were performed using a spreadsheet tool consistent
with the Office of Environmental Health Hazard Assessment (OEHHA) guidance. The
spreadsheet tool incorporates the algorithms, equations and a variable described above, as
well as in the OEHHA guidance, and incorporates the results of the AERMOD dispersion
model.
The process of assessing health risks and impacts includes a degree of uncertainty. The
level of uncertainty is dependent on the availability of data and the extent to which
assumptions are relied upon in cases where the data are incomplete or unknown. All
health risk assessments rely upon scientific studies in order to reduce the level of
uncertainty; however, it is not possible to completely eliminate uncertainty from the
analysis. Where assumptions are used to substitute for incomplete or unknown data, it is
standard practice in performing health risk assessments to err on the side of health
protection to avoid underestimating or underreporting the risk to the public by assessing
risk on the most sensitive populations, such as children and the elderly.
For carcinogenic exposures, the cancer risk from diesel particulate matter (DPM)
emissions from construction activities associated with the proposed program is estimated
to result in a maximum carcinogenic risk of 320.7 per one million. This maximum level
is considered worst-case since it assesses health risks based upon annual emissions levels
from the year with the maximum expected emissions. The lifetime exposure under the
OEHHA guidance takes into account early life (infant and children) exposure. It should
also be noted that the calculated cancer risk conservatively assumes that sensitive
receptors (residential uses) would not employ mechanical filtration which normally
reduce the cancer risk. Based on the evaluation within the Draft PEIR, impacts would be
considered potentially significant because the maximum carcinogenic risk of 320.7 per
one million would be greater than the risk threshold of 10.0 in one million.
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As identified in Section 3.2 in the Draft PEIR, Mitigation Measure AQ-1 (defined above)
and AQ-2 is included to reduce potential impacts to less than significant levels.
AQ-2: When grading activities occur within 50 meters of the nearest sensitive
receptors, the number of scrapers active onsite is restricted to a
maximum of 5 and the number of dozers is restricted to a maximum of 2.
With the implementation of Mitigation Measures AQ-1 and AQ-2, the proposed
program’s localized construction emissions for NOx, PM10, and PM2.5 would be
reduced to below regulatory thresholds, as shown in Table 3.2-11 of the Draft PEIR.
Implementation of Mitigation Measure AQ-1 would also result in a reduction in overall
health risk due to the incorporation of Tier 4 equipment which significantly reduces DPM
emissions. With the implementation of Mitigation Measure AQ-1, the maximum
carcinogenic risk associated with the proposed program would reduce from 320.7 per
one million to 9.6 per million, which is below the regulatory threshold of 10 per million.
Therefore, the cancer risk for nearby sensitive receptors would not contribute to a
significant health risk during construction activities.
d. Potentially Significant Impact: The proposed program could result in significant effects
from the creation of objectionable odors affecting a substantial number of people.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: During construction activities, only short-term,
temporary odors from vehicle exhaust and construction equipment engines would occur.
These odors would be temporary, would be transitory throughout Plant No. 1 and Plant
No. 2 as construction occurs for each project. The odors would also disperse rapidly and
would be typical of the existing operational truck activities within the program area.
However, existing digesters on Plant No. 2 could potentially harbor odors. The
demolition of these facilities could result in the release of odors into the surrounding
environment. Therefore, odor emissions from construction activities could be potentially
significant.
As identified in Section 3.2 in the Draft PEIR, Mitigation Measure AQ-3 is included to
reduce potential impacts to less than significant levels.
AQ-3: OCSD shall ensure that contractors remove salvaged/demolished
equipment from the treatment plants to minimize potential odors during
the removal of existing facilities. Staging areas shall not be used to store
salvaged/demolished equipment.
Implementation of Mitigation Measure AQ-3 would minimize the generation of nuisance
odors during and after demolition of existing digesters, thereby reducing potential
impacts to less than significant levels.
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3.1.1.3 Biological Resources
a. Potentially Significant Impact: The proposed program could have significant effects on
some avian species during nesting activities.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: Construction activities would include the disturbance
of approximately 19.5 acres; approximately 2.0 acres at Plant No. 1 and approximately
17.5 acres at Plant No. 2. The proposed disturbance could include the removal of a couple
of non-native ornamental trees at Plant No. 1, a couple of non-native ornamental trees
mostly located within the confines of Plant No. 2, and a row of trees within Plant No. 2
along Brookhurst Street located on the southern boundary of Plant No. 2. The removal of
trees could result in direct impacts to nesting birds if any are present. In addition, indirect
impacts to birds nesting in the vicinity of the proposed disturbance could result from
construction noise.
Nesting activity typically occurs from February 15 to August 31 for songbirds and from
January 15 to August 31 for raptors. Disturbing or destroying active nests is a violation of
the Migratory Bird Treaty Act. In addition, nests and eggs are protected under California
Fish and Game Code Section 3503 and 3503.5. As such, direct impacts (removal of
active nests) and indirect impacts (e.g., by noise causing abandonment of the nest) to
nesting birds would be considered potentially significant.
As identified in Section 3.3 in the Draft PEIR, Mitigation Measure BIO-1 is included to
reduce potential impacts to less than significant levels.
BIO-1: If removal of onsite trees and vegetation associated with the proposed
program occurs during the non-nesting season (September 1 to February
14 for songbirds; September 1 to January 14 for raptors), no nesting
survey or biological monitor are required.
If the removal of onsite trees and vegetation associated with the proposed
program occurs during the nesting season (February 15 to August 31 for
songbirds; January 15 to August 31 for raptors), a qualified biologist
shall conduct a survey prior to vegetation removal activities to determine
if there are active nests within the onsite trees and vegetation proposed
for removal. If an active nest is not found, no biological monitor is
required. If active nests are detected, a minimum buffer (e.g., 300 feet for
songbirds or 500 feet for raptors) around the nest shall be delineated and
flagged, and no construction activity shall occur within the buffer area
until a qualified biologist determines the nesting species have fledged
and is no longer active or the nest has failed. The buffer may be modified
(i.e., increased or decreased) and/or other recommendations proposed
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(e.g., a temporary soundwall) as determined appropriate by the qualified
biologist to minimize impacts. The qualified biologist shall monitor the
removal of onsite trees and vegetation. Nest buffer distance will be based
on species, specific location of the nest, the intensity of construction
activities, existing disturbances unrelated to the proposed program
present in the program area, and other factors.
If grading/excavation or pile driving activities associated with the
proposed program are scheduled outside the nesting season, no nesting
survey or biological monitor are required.
If grading/excavation or pile driving activities associated with the
proposed program are scheduled during the nesting season, a qualified
biologist shall conduct a survey, prior to grading/excavation or pile
driving activities, of suitable nesting habitat within 500 feet of
construction activities for the presence of nesting birds. If no active nests
are detected, no biological monitor is required. If an active nest is
detected, a minimum buffer (e.g., 300 feet for songbirds or 500 feet for
raptors) around the nest shall be delineated and the active nest shall be
flagged, and no construction activity shall occur within the buffer area
until a qualified biologist determines the nesting species have fledged
and is no longer active or the nest has failed. The qualified biologist shall
monitor the activities of the active nests within the buffer area. The
buffer may be modified (i.e., increased or decreased) and/or other
recommendations proposed (e.g., a temporary soundwall) as determined
appropriate by the qualified biologist to minimize impacts. Nest buffer
distance will be based on species, specific location of the nest, the
intensity of construction activities, existing disturbances unrelated to the
proposed program present in the program area, and other factors.
If there is a lapse of construction activities associated with the proposed
program during the nesting season for 7 days or more, an additional
nesting bird survey shall be conducted to determine if a nest is present
prior to construction activities resuming. The procedure identified above
for no active nest and an active nest shall be followed.
Implementation of Mitigation Measure BIO-1 would reduce impacts to nesting birds to
less than significant by either conducting construction activities during the non-nesting
season or conducting a survey to establish a suitable nesting habitat buffer as well as
having a qualified biologist to monitor the activities of the active nests within the buffer
area during nesting season when construction activities occur.
3.1.1.4 Cultural Resources
a. Potentially Significant Impact: The proposed program could result in a significant
effect on an archaeological resource because the proposed program has the potential to
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cause a substantial adverse change in the significance of an archeological resource
pursuant to CEQA Guidelines Section 15064.5.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: No archaeological resources were identified in the
proposed program area or close proximity and the proposed program would not result in
an impact to known archaeological resources. However, based on the results of the
records search, which identified six prehistoric archaeological resources within a ½-mile
radius, and geoarchaeological review, which indicated that the proposed program area is
highly sensitive for subsurface archaeological resources, there is the potential to impact
unknown buried archaeological resources. If previously undiscovered artifacts or cultural
remains are uncovered during excavation or construction, the proposed program could
result in significant impacts to archaeological resources that could qualify either as
historical resources or unique archaeological resources under CEQA.
As identified in Section 3.4 in the Draft PEIR, Mitigation Measures CUL-1 through
CUL-4 are included to reduce potential impacts to less than significant levels.
CUL-1: Prior to start of grading or excavation activities associated with the
proposed program within Plant No. 1 and Plant No. 2, OCSD shall retain
a qualified archaeologist meeting the Secretary of the Interior’s
Professional Qualifications Standards for archaeology (U.S. Department
of the Interior 2008) to carry out all mitigation related to archaeological
resources.
CUL-2: Prior to start of grading or excavation activities associated with the
proposed program within Plant No. 1 and 2, the qualified archaeologist
(or an archaeologist working under the direct supervision of the qualified
archaeologist) shall conduct cultural resources sensitivity training for all
construction personnel. Construction personnel shall be informed of the
types of archaeological resources that may be encountered, the proper
procedures to be enacted in the event of an inadvertent discovery of
archaeological resources or human remains, and safety precautions to be
taken when working with archaeological monitors. OCSD shall ensure
that construction personnel are made available for and attend the training
and retain documentation demonstrating attendance.
CUL-3: Archaeological and Native American monitoring shall be conducted for
grading or excavation activities associated with the proposed program at
Plant No. 1 and Plant No. 2. Archaeological monitoring shall be
conducted by an archaeologist familiar with the types of archaeological
resources that could be encountered within the program area, and under
the direct supervision of the qualified archaeologist. The frequency of
monitoring shall take into account the rate of excavation and grading
activities, the materials being excavated (native verses artificial fill soils
and older verse younger soils), and the depth of excavation. The
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frequency of the monitoring shall be determined by the qualified
archaeologist in consultation with the Native American monitor and in
coordination with OCSD. The Native American monitor shall be selected
from a tribe that is culturally and traditionally affiliated with the program
area as indicated by the Native American Heritage Commission
(NAHC). In the event that archaeological resources are unearthed during
ground-disturbing activities, the archaeological monitor and/or Native
American monitor shall be empowered to halt or redirect ground-
disturbing activities away from the vicinity of the discovery until OCSD,
a qualified archaeologist, and a Native American monitor have evaluated
the discovery and determined appropriate treatment (as prescribed in
CUL-4). The archaeological monitor shall keep daily logs detailing the
types of activities and soils observed, and any discoveries. After
monitoring has been completed, the qualified archaeologist shall prepare
a report that details the results of monitoring for submittal to OCSD, the
South Central Coastal Information Center, and any Native American
tribe that requests a copy.
CUL-4: In the event of the unanticipated discovery of archaeological materials
during grading or excavation activities associated with the proposed
program, OCSD shall immediately cease all work activities in the area
(within approximately 100 feet) of the discovery until it can be evaluated
by the qualified archaeologist. Construction shall not resume until the
qualified archaeologist has conferred with OCSD on the significance of
the resource.
In the event that preservation in place is determined to be infeasible and
data recovery through excavation is the only feasible mitigation
available, an Archaeological Resources Treatment Plan shall be prepared
and implemented by the qualified archaeologist in consultation with
OCSD that provides for the adequate recovery of the scientifically
consequential information contained in the archaeological resource.
OCSD shall consult with appropriate Native American representatives in
determining treatment for prehistoric or Native American resources to
ensure cultural values ascribed to the resource are considered.
Implementation of CUL-1, CUL-2, CUL-3, and CUL-4 would include the retention of a
qualified archaeologist, conducting archaeological resources sensitivity training for all
construction personnel, archaeological and Native American monitoring during ground-
disturbing activities, and establishing the proper protocol in the event of an unanticipated
discovery of archaeological materials. The implementation of these measures would
reduce impacts to archaeological resources that could qualify as historical resources or
unique archaeological resources to less than significant.
b. Potentially Significant Impact: The proposed program could result in a significant
effect on a unique paleontological resource because the proposed program could directly
or indirectly destroy a unique paleontological resource or site or unique geologic feature.
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Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: Based on the results of the paleontological database
search, there are no known fossil localities in proposed program area. However, several
fossil localities from older Quaternary deposits, similar to those that are likely present in
the subsurface of the proposed program area, are located approximately 1.5 to 3.5 miles
away. These localities have yielded a wide variety of vertebrate fossils, from marine taxa
such as leopard shark to fish such as the three-spined stickleback and terrestrial animals
such as garter snake, turtle, desert shrew, pocket gopher, mammoth, bison, horse, camel,
and elephant. Due to the young age of the surficial sediments underlying the proposed
program area, there is a low potential to uncover significant vertebrate fossil remains
during surface grading or shallow excavations. However, excavations that extend down
into the older Quaternary deposits may encounter significant fossil vertebrate specimens.
Since the proposed program includes ground-disturbing activities, there is a potential for
discovery of fossils that may be considered significant paleontological resources. If
previously unknown potentially unique paleontological resources are uncovered during
excavation or construction, significant impacts could occur.
As identified in Section 3.4 in the Draft PEIR, Mitigation Measures CUL-5 through
CUL-8 are included to reduce potential impacts to less than significant levels.
CUL-5: Prior to start of excavation activities associated with the proposed
program that exceed 10 feet in depth in previously undisturbed
sediments, OCSD shall retain a qualified paleontologist meeting the
Society for Vertebrate Paleontology (SVP) Standards (SVP 2010) to
carry out all mitigation related to paleontological resources. The
qualified paleontologist shall be selected from the list of County of
Orange certified paleontologists.
CUL-6: Prior to the start of excavation activities associated with the proposed
program that exceed 10 feet in depth in previously undisturbed
sediments, the qualified paleontologist, or his or her designee, shall
conduct training for construction personnel regarding the appearance of
fossils and the procedures for notifying paleontological staff should
fossils be discovered by construction staff. OCSD shall ensure that
construction personnel are made available for and attend the training and
retain documentation demonstrating attendance.
CUL-7: Paleontological resources monitoring shall be performed during
excavation activities associated with the proposed program that exceed
10 feet in depth in previously undisturbed sediments by a qualified
paleontological monitor (or cross-trained paleontological/archaeological
monitor) meeting the standards of the SVP 2010 under the direction of
the qualified paleontologist. The monitor shall have the authority to
temporarily halt or divert work away from exposed fossils in order to
recover the fossil specimens. The qualified paleontologist, based on
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observations of subsurface soil stratigraphy and/or other factors, may
increase, reduce, or discontinue monitoring, as warranted. Monitoring
may be reduced or discontinued by the qualified paleontologist, in
coordination with OCSD, based on observations of subsurface
conditions.
If construction or other project personnel discover any potential fossils
during construction, regardless of the depth of work, all work shall cease
at that location (within 100 feet) until the qualified paleontologist has
assessed the discovery and made recommendations as to the appropriate
treatment and re-assessed the depth at which monitoring shall be
required.
CUL-8: In the event of a fossil discovery by the paleontological monitor or
construction personnel, all work in the immediate vicinity of the find
shall cease. The qualified paleontologist shall evaluate the find before
restarting construction activity in the area. If it is determined that the
fossil(s) is (are) scientifically significant, the qualified paleontologist
shall recover significant fossils following standard field procedures for
collecting and curating paleontological resources, as described by the
SVP (2010).
Implementation of Mitigation Measures CUL-5 through CUL-8 would reduce impacts to
paleontological resources by requiring identification and treatment of significant
resources. Implementation of CUL-5 through CUL-8 would also require the retention of a
qualified paleontologist, paleontological monitoring during construction, and
establishment the proper protocol if paleontological resources are encountered.
Therefore, incorporation of CUL-5 through CUL-8 would reduce this impact to a level of
less than significant.
c. Potentially Significant Impact: The proposed program could result in a significant
effect on human remains because the proposed program could disturb human remains,
including those interred outside of dedicated cemeteries.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: No human remains are known to be located within the
proposed program area; however, since archaeological sites with human remains have
been documented within a ½-mile radius and given the high sensitivity of the area, there
is the possibility that human remains could be encountered by construction activities at
Plant No. 1 and Plant No. 2 for the proposed program. In the event that human remains
are inadvertently discovered during proposed program construction activities, they could
be inadvertently damaged, which could result in a significant impact.
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As identified in Section 3.4 in the Draft PEIR, Mitigation Measures CUL-9 is included to
reduce potential impacts to less than significant levels.
CUL-9: If human remains are encountered during construction activities
associated with the proposed program, OCSD or its contractor shall halt
work in the vicinity (within 100 feet) of the find and contact the Orange
County Coroner in accordance with PRC Section 5097.98 and Health
and Safety Code Section 7050.5. If the County Coroner determines that
the remains are Native American, the NAHC will be notified in
accordance with Health and Safety Code Section 7050.5, subdivision (c),
and PRC Section 5097.98. The NAHC will designate an MLD for the
remains per PRC Section 5097.98. Until the landowner has conferred
with the MLD, OCSD shall ensure that the immediate vicinity where the
discovery occurred is not disturbed by further activity, is adequately
protected according to generally accepted cultural or archaeological
standards or practices, and that further activities take into account the
possibility of multiple burials.
Implementation of Mitigation Measure CUL-9 would ensure that the proposed program’s
potential impacts to human remains impacts would be reduced to less than significant by
requiring proper treatment of human remains.
3.1.1.5 Hazards and Hazardous Materials
a. Potentially Significant Impact: The proposed program would be located on a site which
is included on a list of hazardous materials sites compiled pursuant to Government Code
Section 65962.5 and may result in potentially significant hazard impacts to the public or
the environment.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: The proposed program would be implemented entirely
within Plant No.1 and Plant No. 2, with a majority of the projects being implemented at
Plant No. 2. A database search of hazardous materials sites using the online DTSC
EnviroStor and SWRCB GeoTracker databases identified Plant No. 1 as having two
closed leaking underground storage tanks (LUST) sites, one open LUST Cleanup site and
one permitted underground storage tank (UST). Plant No. 2 has two closed LUST cases
and one permitted UST.
Construction activities associated with the proposed Collections Yard Relocation on Plant
No. 1 could encounter contaminated soil and/or groundwater during excavation, thereby
posing a health threat to construction workers, the public, and the environment. The
analysis of operational impacts associated with hazardous materials sites, mobilization of
soil and groundwater contaminants, and groundwater quality can be found in Section 3.8,
Hydrology and Water Quality of the Draft PEIR. Impacts would be potentially
significant.
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As identified in Section 3.7 in the Draft PEIR, Mitigation Measures HAZ-1 and HAZ-2
are included to reduce potential impacts to less than significant levels.
HAZ-1: Prior to the initiation of any construction requiring ground-disturbing
activities, OCSD shall complete an environmental assessment of the
proposed site to locate the potential for soil and groundwater
contamination in the program area. The recommendations set forth in the
site assessment shall be implemented to the satisfaction of applicable
agencies before and during construction.
HAZ-2: If the site assessments determine that the site has contaminated soil
and/or groundwater, a Soil and Groundwater Management Plan shall be
prepared that specifies the method for handling and disposing of
contaminated soil and groundwater prior to demolition, excavation, and
construction activities. OCSD shall be responsible for ensuring
implementation of the Plan in compliance with applicable regulations.
The implementation of Mitigation Measures HAZ-1 and HAZ-2 would require site-
specific studies to identify known hazardous materials risks or the potential for risk
related to hazardous materials. These studies would identify recommendations and
cleanup measures to reduce risk to the public and the environment from development on
hazardous materials sites. Implementation of Mitigation Measures HAZ-1 and HAZ-2
would reduce potential impacts to construction workers and the public from exposure to
unknown affected soils. Therefore, impacts to the public or the environment related to
hazardous materials sites would be less than significant.
3.1.2 Cumulative Impacts
3.1.2.1 Aesthetics
a. Potentially Significant Impact: The proposed program could create new sources of
substantial light or glare and could result in cumulatively considerable adverse effects on
day or nighttime views in the program area.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: The program vicinity is largely urbanized with
residential, commercial and industrial development. As the area continues to develop, the
addition of more residential, commercial, and industrial development could increase
additional sources of light and glare. With regard to the overall sources of light and glare
of the program vicinity, cumulative development (see Table 3-2 in Chapter 3 of the Draft
PEIR) would result in more new sources of light and glare and could result in
cumulatively significant light and glare impacts. Because the program could result in
increased local light levels, the program’s contribution is considered cumulatively
considerable.
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As identified in Section 3.1 in the Draft PEIR, Mitigation Measures AES-1 and AES-2
(defined above) are included to reduce potential cumulative impacts to less than
significant levels.
The implementation of Mitigation Measures AES-1 and AES-2 would ensure that the
proposed facilities’ contribution to cumulative light impacts would be reduced to less
than cumulatively considerable by limiting the maximum light beyond the property
boundary and complying with existing and future lighting ordinances.
3.1.2.2 Air Quality
a. Potentially Significant Impact: The proposed program could have cumulatively
considerable effects on implementation of the South Coast Air Quality Management Plan
(AQMP) because the proposed program could conflict with or obstruct implementation of
the AQMP.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: See the regional impact discussion under 3.1.2.2 (c.)
below. As discussed, the project’s contribution to cumulative regional construction
emissions of NOx would be cumulatively considerable. As identified in Section 3.2 in the
Draft PEIR, Mitigation Measure AQ-1 (defined above) is included to reduce potential
cumulative impacts to less than significant levels.
Implementation of Mitigation Measure AQ-1 would require the use of construction
equipment that would emit less NOx emissions. Mitigation Measure AQ-1 would reduce
the proposed program’s contribution to cumulative regional construction emissions of
NOx to comply with the SCAQMD thresholds as discussed in Impact 3.2-2 and Impact
3.2-3 of the Draft PEIR. With the implementation of this mitigation measure, the
proposed program’s contribution to cumulative impacts is less than cumulatively
considerable.
b. Potentially Significant Impact: The proposed program could result in cumulatively
considerable effects because the proposed program could violate an air quality standard
or contribute substantially to an existing or projected air quality violation.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: See the regional impact discussion under 3.1.2.2 (c.)
below. As discussed, the project’s contribution to cumulative regional construction
emissions of NOx would be cumulatively considerable. As identified in Section 3.2 in the
Draft PEIR, Mitigation Measure AQ-1 (defined above) is included to reduce potential
cumulative impacts to less than significant levels.
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Based on the reduction of the total NOx emissions with the implementation of Mitigation
Measure AQ-1, the proposed program’s incremental contribution to cumulative impacts
related to a violation of air quality standards from operational activities would be less
than cumulatively considerable.
c. Potentially Significant Impact: The proposed program could result in a cumulatively
considerable net increase of a criteria pollutant for which the project region is non-
attainment under an applicable federal or state ambient air quality standard.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: The SCAQMD neither recommends quantified
analyses of cumulative construction or operational emissions nor provides methodologies
or thresholds of significance to be used to assess cumulative construction or operational
impacts. Individual cumulative projects that exceed the SCAQMD recommended daily
thresholds for an individual project would cause a cumulatively considerable impact.
The program area is located within the SCAB, which is considered the cumulative study
area for air quality. The SCAB is currently classified as a state nonattainment area for
ozone, PM10, and PM2.5, and is a federal nonattainment area for ozone and PM2.5. Based
on SCAQMD’s cumulative air quality impact methodology, SCAQMD recommends that
if an individual project results in air emissions of criteria pollutants (ROG, CO, NOx,
SOX, PM10, and PM2.5) that exceed the SCAQMD’s recommended daily thresholds for
project-specific impacts, then it would also result in a cumulatively considerable net
increase of these criteria pollutants for which the program region is in nonattainment
under an applicable federal or state ambient air quality standard. As shown in Table 3.2-6
of the Draft PEIR, regional construction emissions of NOx would exceed the
SCAQMD’s daily thresholds. In addition, as shown in Table 3.2-10 of the Draft PEIR,
localized construction emissions of PM10 and PM2.5 would exceed the SCAQMD daily
thresholds. Therefore, the proposed program’s contribution to cumulative NOx for
regional construction emissions and to cumulative PM10 and PM2.5 for localized
construction emissions would be cumulatively considerable.
In addition, as discussed in Impact 3.2-4 below, the proposed program’s localized health
impact associated with construction activities would exceed regulatory thresholds.
Because the SCAQMD’s recommended cumulative impact methodology is if an
individual project results in the exceedance of regulatory thresholds then the project
would result in a cumulatively considerable impact. Therefore, because the proposed
project would exceed the regulatory thresholds for localized health impacts during
construction, the proposed program would result in cumulatively considerable health
impacts during construction.
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As identified in Section 3.2 in the Draft PEIR, Mitigation Measures AQ-1 and AQ-2
(defined above) are included to reduce potential cumulative impacts to less than
significant levels.
With implementation of Mitigation Measure AQ-1, regional emissions of NOx during the
proposed program construction would be reduced to below regulatory thresholds as
detailed in Impact 3.2-2 of the Draft PEIR. With implementation of Mitigation Measure
AQ-2, localized PM0 and PM2.5 emissions during proposed program construction
activities would be reduced to below SCAQMD’s LSTs, as detailed in Impact 3.2-4 of
the Draft PEIR. Therefore, impacts would be less than significant.
d. Potentially Significant Impact: The proposed program could result in significant and
cumulatively considerable effects associated with the exposure of sensitive receptors to
substantial pollutant concentrations.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the EIR.
Facts in Support of the Finding: As Lead Agency, the SCAQMD uses the same
significance thresholds for project-specific and cumulative impacts for all environmental
topics analyzed in an Environmental Assessment or EIR. Projects that exceed the project-
specific significance thresholds are considered by the SCAQMD to be cumulatively
considerable. This is the reason project-specific and cumulative significance thresholds
are the same. Conversely, projects that do not exceed the project-specific thresholds are
generally not considered to be cumulatively significant. As detailed under Impact 3.2-4 of
the Draft EIR, construction related localized criteria pollutants and TACs associated with
the proposed program would be significant at a project level and would be cumulatively
considerable.
As identified in Section 3.2 in the Draft PEIR, Mitigation Measures AQ-1 and AQ-2
(defined above) are included to reduce potential cumulative impacts to less than
significant levels.
As stated previously, the cumulative thresholds for air quality are identical to the program
level thresholds, therefore projects that are less than significant with or without
mitigation at the project level would be less than cumulatively considerable. Therefore,
consistent with the program level analysis, with the implementation of Mitigation
Measures AQ-1 and AQ-2, the proposed program’s contribution to cumulative localized
construction emissions associated with criteria air pollutants and TACs would be reduced
to below regulatory thresholds and the proposed program’s contribution to cumulative
impacts would be less than cumulatively considerable.
e. Potentially Significant Impact: The proposed program could result in cumulatively
considerable effects from the creation of objectionable odors affecting a substantial
number of people.
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Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: Future cumulative development in the vicinity of the
proposed program has the potential to create odors. Construction activities associated
with future development are expected to result in less than significant odor impacts.
Operational impacts from cumulative development could result in significant odor
impacts. Because the proposed program would result in potentially significant odor
impacts due to the demolition of existing digesters, the proposed program’s incremental
contribution to cumulative odor impacts would be cumulatively considerable without
mitigation.
As identified in Section 3.2 in the Draft PEIR, Mitigation Measure AQ-3 (defined above)
is included to reduce potential cumulative impacts to less than significant levels.
Implementation of Mitigation Measure AQ-3 would minimize the generation of nuisance
odors during and after demolition of existing digesters, thereby reducing the program’s
potential impacts to less than significant levels. Therefore, the program’s contribution to
cumulative impacts regarding odor would be considered less than cumulatively
considerable.
3.1.2.3 Biological Resources
a. Potentially Significant Impact: The proposed program could have cumulatively
considerable effects on some avian species during nesting activities but would not have
an adverse effect, either directly or through habitat modifications, on species identified as
a candidate, sensitive, or special-status species in local or regional plans, policies, or
regulations, or by the CDFW or USFWS.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: Future construction and operational activities
associated with cumulative development (see Table 3-2 in Chapter 3 of the Draft PEIR)
may result in impacts to nesting birds as well as sensitive plant and wildlife species.
These potential cumulative impacts could result from removal of habitat or indirect
through noise-generating activities. Because the construction activities associated with
the proposed program could result in significant impacts to nesting birds, the proposed
program would contribute to cumulative impacts to nesting birds.
As identified in Section 3.3 in the Draft PEIR, Mitigation Measure BIO-1 (defined
above) is included to reduce potential cumulative impacts to less than significant levels.
Implementation of Mitigation Measure BIO-1 would reduce the program’s contribution
to cumulative impacts to nesting birds to less than significant by either conducting
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construction activities during the non-nesting season or conducting a survey to establish a
suitable nesting habitat buffer as well as having a qualified biologist to monitor the
activities of the active nests within the buffer area during nesting season when
construction activities occur.
3.1.2.4 Cultural Resources
a. Potentially Significant Impact: The proposed program could result in a cumulatively
considerable effect on an archaeological resource because the proposed program has the
potential to cause a substantial adverse change in the significance of an archeological
resource pursuant to CEQA Guidelines Section 15064.5.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: The proposed program vicinity is located within a
favorable area (near water sources) for prehistoric inhabitance and the proposed program
vicinity is known to contain archaeological resources. Thus, there is the potential for
ongoing and future development projects in the vicinity to disturb known or unknown
archaeological resources.
The potential construction impacts of the proposed program, in combination with other
projects in the area, could contribute to a cumulatively significant impact on
archaeological resources. Because the proposed program could result in significant
impacts to archaeological resources, the proposed program’s contribution to cumulative
impacts would be cumulatively considerable.
As identified in Section 3.4 in the Draft PEIR, Mitigation Measures CUL-1 through
CUL-4 (defined above) are included to reduce potential cumulative impacts to less than
significant levels.
The implementation of Mitigation Measures CUL-1 through CUL-4 would include the
retention of a qualified archaeologist, conducting archaeological resources sensitivity
training for all construction personnel, archaeological and Native American monitoring
during ground-disturbing activities, and establishing the proper protocol in the event of
an unanticipated discovery of archaeological materials. The implementation of these
measures would reduce the program’s contribution to cumulative impacts to
archaeological resources that could qualify as historical resources or unique
archaeological resources to less than cumulatively significant.
b. Potentially Significant Impact: The proposed program could result in a significant and
cumulatively considerable effect on a unique paleontological resource because the
proposed program could directly or indirectly destroy a unique paleontological resource
or site or unique geologic feature.
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Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the EIR.
Facts in Support of the Finding: As future cumulative development occurs in the
program area, there is a potential that future growth could require excavation activities.
These activities could be required within older Quaternary deposits that may encounter
significant fossil vertebrate specimens. Therefore, cumulative development could result
in potential significant cumulative impacts to paleontological resources. Because the
proposed program includes excavations that could occur within older Quaternary
deposits, significant fossil vertebrate specimens could be found. Therefore, the proposed
program could result in cumulatively considerable effects on paleontological resources.
Implementation of Mitigation Measures CUL-5 through CUL-8 would reduce the
program’s contribution to cumulative impacts to paleontological resources by requiring
identification and treatment of significant resources. Implementation of CUL-5 through
CUL-8 would also require the retention of a qualified paleontologist, paleontological
monitoring during construction, and establishment the proper protocol if paleontological
resources are encountered. Therefore, incorporation of CUL-5 through CUL-8 would
reduce the program’s contribution to cumulative paleontological resources impacts to less
than cumulatively significant.
c. Potentially Significant Impact: The proposed program could result in a cumulatively
significant effect on human remains because the proposed program could disturb human
remains, including those interred outside of dedicated cemeteries.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: The proposed program area is largely urbanized with
industrial development. However, since archaeological sites with human remains have
been documented within a ½-mile radius of the proposed program and given the high
sensitivity of the area, there is the possibility that construction activities associated with
cumulative development could impact unknown human remains. Because the proposed
program could encounter and significantly impact human remains, the program could
contribute to significant cumulative impacts to human remains and result in result in
cumulatively considerable could result in cumulatively considerable impacts to human
remains.
As identified in Section 3.4 in the Draft PEIR, Mitigation Measure CUL-9 (defined
above) is included to reduce potential cumulative impacts to less than significant levels.
Implementation of Mitigation Measure CUL-9 would ensure that the proposed program’s
contribution to cumulative human remains impacts would be reduced to less than
cumulatively considerable by requiring proper treatment of human remains.
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3.1.2.5 Hazards and Hazardous Resources
a. Potentially Significant Impact: The proposed program would be located on a site which
is included on a list of hazardous materials sites compiled pursuant to Government Code
Section 65962.5 and may result in cumulatively considerable hazard impacts to the public
or the environment.
Finding: Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have
been required in, or incorporated into, the project which avoid or substantially lessen the
significant environmental effect as identified in the PEIR.
Facts in Support of the Finding: The program vicinity is largely urbanized with
residential, commercial and industrial development. As the area continues to develop, the
addition of developments could be located on sites that are included on a list of hazardous
materials sites. Remediation of contamination found on site as required under Mitigation
Measures HAZ-1 and HAZ-2 would reduce any contribution to the cumulative condition.
Impacts would be less than cumulatively considerable.
As identified in Section 3.4 in the Draft PEIR, Mitigation Measures HAZ-1 and HAZ-2
(defined above) are included to reduce potential cumulative impacts to less than
significant levels.
The implementation of Mitigation Measures HAZ-1 and HAZ-2 would ensure that the
proposed facilities’ contribution to cumulative development on the open LUST site at
Plant No. 1 would be reduced to less than cumulatively considerable by requiring site-
specific studies to identify known hazardous materials risks or the potential for risks
related to hazardous materials and affected soils and groundwater. These studies would
include recommendations and cleanup measures to reduce risk to the public and the
environment from development on hazardous materials sites. Implementation of
Mitigation Measures HAZ-1 and HAZ-2 would reduce potential impacts to construction
workers and the public from exposure to unknown affected soils.
4. Feasibility of Alternatives
In accordance with CEQA Guidelines (Section 15126.6), an EIR must describe and compare a
range of reasonable alternatives to a project, or alternative locations for a project, that could
feasibly attain most of the basic project objectives while avoiding or substantially lessening any
significant environmental impacts associated with the project. An EIR must consider a reasonable
range of feasible alternatives to facilitate informed decision making and public participation. An
EIR need not consider every conceivable alternative to a project and is not required to consider
alternatives which are infeasible. The Lead Agency shall select a range of project alternatives and
disclose its reasoning for selecting those alternatives. As set forth in these findings, the selection
of such alternatives is described further below.
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4.1 Alternative 1: No Program Alternative
4.1.1 Description
An analysis of the No Program Alternative is required under CEQA Guidelines Section
15126.6(e). According to Section 15126.6(e)(2) of the CEQA Guidelines, the “no program”
analysis shall discuss:
what is reasonably expected to occur in the foreseeable future if the project were
not approved, based on current plans and consistent with available
infrastructure and community services.
The No Program Alternative represents a “no build” scenario in which the proposed program
would not be constructed or operated. It assumes that all proposed facilities along with other
elements of the program would not be implemented and no program components would be
constructed. Under the No Program Alternative, OCSD would continue to treat wastewater at
Plant No. 1 and Plant No. 2. There would be no change in the type of biosolids handling facilities
being used and no updates to the efficiency of the technology, structural integrity of the
structures, or diversification of biosolids end-uses.
4.1.2 Impact Analysis
The No Program Alternative excludes the proposed facilities upgrades. As a result, there would
be less construction activity when compared to the proposed program. Fewer projects and no new
facilities result in fewer construction-related impacts and fewer operational-related impacts. The
relative difference in environmental impacts associated with the No Program Alternative when
compared to the proposed program is provided below.
4.1.2.1 Aesthetics
The proposed program would result in a less than significant impact to aesthetics with mitigation
(see Section 3.1 of the Draft PEIR). Under the No Program Alternative, Plant No. 1 and Plant
No. 2 would remain the same as existing conditions, retaining their current visual character;
therefore, no views of the sites would be altered. Additionally, no new sources of light and glare
would be created. Therefore, this alternative would have no impacts to aesthetics, and would have
fewer impacts compared to the proposed program.
4.1.2.2 Air Quality
The proposed program would result in a less than significant impact to air quality with mitigation
(see Section 3.2 of the Draft PEIR). Under the No Program Alternative, there would be no
construction-related emissions (from construction activities, vehicles and equipment). Therefore,
Alternative 1 would result in no impacts to an air quality plan, air quality standards/violations,
cumulative increased of criteria pollutants, impacts to sensitives receptors, or changes to odors.
However, air emissions associated with energy demands would remain high compared to the
proposed program’s objective of implementing renewable energy supplies via excess biogas.
Therefore, this alternative would have less than significant impacts to air quality, and would have
fewer impacts compared to the proposed program.
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4.1.2.3 Biological Resources
The proposed program would result in less than significant impacts to biological resources with
mitigation (see Section 3.3 of the Draft PEIR). Under the No Program Alternative, Plant No. 1
and Plant No. 2 would not undergo construction or operation of new facilities onsite; therefore,
this Alternative would not expose candidate, sensitive, or special-status species currently located
adjacent to the program area to potential indirect noise impacts. Similar to the proposed program,
Alterative 1 would not conflict with biological resource regulations, ordinances, or conservation
plans. Overall, this alternative would have no impacts to areas containing biological resources,
and would have less impacts compared to the proposed program.
4.1.2.4 Cultural Resources
The proposed program has the potential to encounter human remains and archaeological and
paleontological resources during ground disturbing activities, however, the proposed program
would result in less than significant impacts to cultural resources with mitigation (see Section 3.4
of the Draft PEIR). Under the No Program Alternative, no ground disturbing activities would
occur to any known or unknown human remains, or archaeological or paleontological resources.
Therefore, this alternative would result in no impacts to cultural resources and less impacts as
compared to the proposed program.
4.1.2.5 Geology, Soils, and Seismicity
The proposed program would result in less than significant impacts related to exposure to
geologic hazards with mitigation incorporated (see Section 3.5 of the Draft PEIR). Under the No
Program Alternative, there would be no development, and the potential effects associated with
geology and soils, such as soil erosion during construction would not occur. However, Alternative
1 would result in greater impacts regarding earthquakes, because Alternative 1 would not upgrade
existing facilities or build new facilities to the current California Building Code standards.
Therefore, if an earthquake event were to occur, the outdated structures may fail and result in
more impacts such as to hazardous waste spills. Therefore, this alternative would have fewer
impacts to geology and soils but greater impacts regarding earthquakes as compared to the
proposed program.
4.1.2.6 Greenhouse Gas Emissions
The proposed program would result in less than significant impacts related to greenhouse gases
(see Section 3.6 of the Draft PEIR). Under the No Program Alternative, there would be no
construction-related emissions (from construction activities, vehicles and equipment). Therefore,
Alternative 1 would result in no impacts related to greenhouse gases. Therefore, this alternative
would have no impacts related to greenhouse gases, and would have fewer impacts compared to
the proposed program.
4.1.2.7 Hazards and Hazardous Materials
The proposed program would result in a less than significant impact related to hazards and
hazardous materials with mitigation (see Section 3.7 of the Draft PEIR). Under the No Program
Alternative, no construction would occur; therefore, no new facilities would be placed on or near
the hazardous material site located at Plant No. 1. Further, because no construction would occur,
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Alterative 1 would not expose structures or persons to hazardous materials. Therefore, this
alternative would result in no impacts related to hazards and hazardous materials and less impacts
compared to the proposed program.
4.1.2.8 Hydrology and Water Quality
The proposed program would result in less than significant impacts to hydrology and water
quality (see Section 3.8 of the Draft PEIR). Under the No Program Alternative, there would be no
development and thus no changes to the natural drainage patterns of Plant No.1 or Plant No. 2, or
to the potential to contribute to runoff into existing stormwater drainage systems. Further,
Alternative 1 would not place additional facilities within flood hazard areas or put people or
structures at risks due to the failure of the SAR levee or tsunami of the Pacific Ocean. This
alternative would result in no impacts to hydrology and water quality and less impacts compared
to the proposed program.
4.1.2.9 Land Use and Planning
The proposed program would result in no impact to land use and planning (see Section 3.9 of the
Draft PEIR). The proposed program would not conflict with the City of Huntington Beach Local
Coastal Program’s policies or regulations. Under the No Program Alternative, no development
would occur and Plant No. 1 and No. 2 would remain in their current state. As such, this
alternative would not change existing land use or have an effect on land use plans and policies
related to the program area. Therefore, this alternative would result in similar impacts regarding
land use as compared to the proposed program.
4.1.2.10 Noise and Vibration
The proposed program would result in a less than significant impacts regarding noise and
vibration (see Section 3.10 of the Draft PEIR). Under the No Program Alternative, there would be
no development and no change to existing ambient noise levels. No noise and vibration impacts
would occur under Alternative 1. Therefore, this alternative would result in fewer impacts from
noise and vibration compared to the proposed program.
4.1.2.11 Transportation and Traffic
The proposed program would result in a less than significant impact to traffic and transportation
(see Section 3.11 of the Draft PEIR). Under the No Program Alternative, there would be no
development, thus no additional traffic would be generated by uses on Plant No. 1 or Plant No. 2,
and no impacts related to traffic and transportation of biosolids would occur. Therefore, this
alternative would result in fewer transportation and traffic impacts as compared to the proposed
program.
4.1.2.12 Tribal Cultural Resources
The proposed program would result in a no impact to tribal cultural resources (see Section 3.12 of
the Draft PEIR). Under the No Program Alternative, no ground disturbing activities would occur
to any known or unknown tribal cultural resources. Therefore, this alternative would result also in
no impacts to tribal cultural resources similar to the proposed program.
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4.1.2.13 Utilities, Service Systems, and Energy
The proposed program would result in a less than significant impacts to utilities, service systems,
and energy (see Section 3.13 of the Draft PEIR). Under the No Program Alternative, no
development would occur and no changes to stormwater drainage facilities would need to be
implemented. Further, Alternative 1 would not require additional water supplies. No demolition
or construction would occur, so there would no impacts regarding landfill capacity or compliance
with solid waste regulations. Lastly, no additional energy would be required to operate facilities
as facilities would not be build or upgrades. Therefore, this alternative would result in fewer
impacts related to utilities and energy than the proposed program.
4.1.3 Findings for Alternative 1: No Program Alternative
The No Program Alternative (Alternative 1) would reduce or eliminate most proposed program
impacts, but it would result in new potentially significant impacts that could result from aging
equipment including process malfunctions and inefficiencies that could result in geologic hazards,
hazardous material spills, increased energy usage, and increased air emissions. Alternative 1
would meet none of the program’s objectives.
4.2 Alternative 2: Baselines, Mesophilic Digestion, Class B
4.2.1 Description
The Baseline, Mesophilic Digestion, Class B Alternative represents a scenario in which the
proposed program facilities associated with the Temperature Phased Anaerobic Digestion
(TPAD) process would not be constructed or operated. This alternative would not construct the
following facilities that are included in the proposed program: six, new thermophilic digesters;
Class A batch tanks; Digester Feed Facility; and TPAD Sludge Cooling facilities. These specific
facilities are contained within the following proposed projects:
• P2-504/504A/504B, TPAD Digester Facility at Plant No. 2
Furthermore, project P2-503A, Plant No. 2 Warehouse Relocation and P2-503B, Plant No. 2
Collections Yard Relocation would not be implemented. These projects were proposed as part of
the proposed program to provide space for the construction and operation of the thermophilic
digesters and Class A batch tank facilities.
Alternative 2 would implement project P2-124 and P2-506, which include the construction and
operation of food waste facilities. In addition, Alternative 2 would implement project P2-505,
Digester P, Q, R, and S Replacement. The four existing mesophilic digesters would be
demolished and reconstructed to current California Building Code standards in order to address
existing structural impairments. Furthermore, the remaining digesters (L, M, O, T, J, K, N, I, E,
H, C, F, and G) would be demolished and rebuilt at the same location as they require extensive
structural modifications and ground improvements to mitigate potential seismic risks. Digester D
would be demolished and relocated to the west side of Digester S or a suitable alternative
location. This would be necessary to ensure that no digesters or other facilities would be
constructed and operated on an active fault.
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A total of 10 acres would be graded for Alternative 2. Under Alternative 2, OCSD would
continue to treat wastewater at Plant No. 2 with mesophilic digestion and would continue to
produce Class B biosolids. There would be no change in the type of biosolids handling facilities
being used and no diversification of biosolids end-uses. However, this alternative would allow for
the mitigation of structural and seismic risk for onsite biosolids at Plant No. 2 facilities over time.
This alternative would meet three of the four objectives of the proposed program. This alternative
would meet two of the four objectives of the proposed program; the Alternative would not meet
the objective to phase out the diversion of biosolids used as daily cover for landfills, nor would it
support the transition from Class B to Class A biosolids.
4.2.2 Impact Analysis
The relative difference in environmental impacts associated with the Baseline, Mesophilic
Digestion, Class B Alternative when compared to the proposed program is provided below.
4.2.2.1 Aesthetics
The proposed program would result in a less than significant impact to aesthetics with mitigation
(see Section 3.1 of the Draft PEIR). Alternative 2 would construct less facilities and result in the
grading of approximately 9.5 acres less area than the proposed program. Demolition of digesters
would still occur, and then the digesters would be rebuilt. P2-501, Perimeter Screening would still
take place, and therefore, would partially screen construction equipment and processes during
demolition and construction. Similar to the proposed program, Alternative 2 would result in less
than significant impacts regarding scenic vistas and visual character of the area. Because
Alternative 2 would result in less facilities being constructed, Alternative 2 would introduce
fewer new sources of light or glare to the program area. Overall, Alternative 2 would result in less
than significant impacts regarding scenic vistas, visual character, and light or glare, and would
result in fewer impacts than the proposed program.
4.2.2.2 Air Quality
The proposed program would result in a less than significant impact to air quality with mitigation
(see Section 3.2 of the Draft PEIR). Alternative 2 would construct less facilities and result in the
grading of approximately 9.5 acres less area than the proposed program. Under Alternative 2, less
haul trucks would be required for demolition material (the warehouse would not need to be
demolished and relocated on Plant No. 2), import of material, and export of material, thereby
reducing the total amount of vehicle miles traveled (VMT). Less construction material trucks
would be required as well. Further, the proposed program would generate Class A biosolids
which could be delivered to more local end-users in California. Alternative 2 would continue to
generate Class B biosolids which are sent to end-users in Arizona and some parts of California.
The total VMT for operational biosolids delivery trips specifically, would be greater for
Alternative 2 than the proposed program. Overall, Alternative 2 would have less than significant
impacts to air quality and would result in fewer impacts than the proposed program.
With less grading under this alternative, less construction NOx emissions would be generated;
however, this reduction would still require the proposed program mitigation measures to reduce
potential regional construction emissions to less than significant. In addition, localized
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construction emissions of PM10 and PM2.5 would be less compared to the proposed program;
however, Alternative 3 would still require the proposed program mitigation measures to reduce
increases of PM10 and PM2.5 to less than significant. Alternative 3 would result in less localized
construction emissions impacts compared to the proposed program.
4.2.2.3 Biological Resources
The proposed program would result in less than significant impacts to biological resources with
mitigation (see Section 3.3 of the Draft PEIR). Under Alternative 2, less construction would take
place overall; therefore, fewer non-native ornamental trees would need to be removed for
construction activities. Indirect impacts to bird nesting in the vicinity of the program area would
be less under Alternative 2 compared to the proposed program. Further, noise levels due to
construction activities would be reduced. The reduced noise levels would have less of a potential
impact on nearby nesting birds. Further, operational noise of the facilities would stay the same
because no new facilities would be implemented within the proposed program area. Overall,
Alternative 2 would result in less than significant impacts to biological resources and would result
in fewer impacts than the proposed program.
4.2.2.4 Cultural Resources
The proposed program has the potential to encounter human remains and archaeological and
paleontological resources during ground disturbing activities, however, the program would result
in less than significant impacts to cultural resources with mitigation (see Section 3.4 of the Draft
PEIR). The proposed program would result in less excavation and ground disturbance at Plant
No. 2 compared to the excavation and ground disturbance under Alternative 2. Therefore, the
potential for encountering human remains, archeological and paleontological resources during
construction activities would be reduced. Overall, Alternative 2 would result in less than
significant impacts to cultural resources and fewer impacts than the proposed program.
4.2.2.5 Geology, Soils, and Seismicity
The proposed program would result in less than significant impacts related to exposure to
geologic hazards with mitigation incorporated (see Section 3.5 of the Draft PEIR). Alternative 2
would not construct new facilities, but would demolish and rebuild existing digester facilities to
current California Building Code standards. Further, Digester D would be relocated on Plant No.
2 to address potential structural issues if a ground shaking event were to occur. Therefore,
Alternative 2 would result in similar impacts regarding earthquakes, unstable geologic locations,
and expansive soils as the proposed program. Because Alternative 2 would result in less ground
disturbance and excavation overall, the potential for soil erosion or topsoil loss would be reduced.
Therefore, Alternative 2 would result in less impacts regarding soil erosion as compared to the
proposed program. Overall, Alterative 2 would result in less than significant impacts regarding
geology, soils, and seismicity, and would result in fewer impacts overall than the proposed
program.
4.2.2.6 Greenhouse Gas Emissions
The proposed program would result in a less than significant impacts to greenhouse gases (see
Section 3.6 of the Draft PEIR). Under Alternative 2, the total amount of VMT and biosolids truck
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trips would be the same as existing VMT and truck trips because the export of biosolids to the
end users would be the same. When compared to the proposed program, Alternative 2 would
result in greater VMT and increased trips. As a result, Alternative 2 would have a greater amount
of greenhouse gas emissions compared to the proposed program. Alternative 2 would result in
similar impacts regarding plans, policies, and regulations related to the reduction of greenhouse
gas emissions. Overall, Alternative 2 would result in less than significant impacts to greenhouse
gas emissions, but the emissions would be greater than those that would occur with the proposed
program.
4.2.2.7 Hazards and Hazardous Materials
The proposed program would result in a less than significant impact to hazards and hazardous
materials with mitigation (see Section 3.7 of the Draft PEIR). The proposed program would result
in a potentially significant impact regarding a hazardous materials site listing if the collections
yard is relocated to the northern location of Plant No. 1. Under Alternative 2, the collections yard
would not be relocated to Plant No. 1; therefore, Alternative 2 would result in no potential
significant hazardous materials impact because the collection yard would not be constructed
under Alternative 2. Alternative 2 would result in similar impacts as the proposed program
regarding the routine use of hazardous materials, accidental release of hazardous materials, the
use of hazardous materials near a school, and conflicts with emergency plans. Overall,
Alternative 2 would result in less than significant impacts to hazards and hazardous materials and
fewer impacts than the proposed program.
4.2.2.8 Hydrology and Water Quality
The proposed program would result in less than significant impacts to hydrology and water
quality (see Section 3.8 of the Draft PEIR). Under Alternative 2, there would be less acres of area
disturbed because it does not add any new facilities, it only rebuilds and renovates existing
facilities. Thus, the potential for sedimentation and erosion to occur due to exposed soil during
construction activities would be reduced. Further, because less facilities would be implemented
on Plant No. 1 and Plant No. 2, the natural drainage courses of the sites would remain largely the
same and existing stormwater drainage facilities would not need to be altered. Because
Alternative 2 would result in less excavation for new facility implementation, the impacts to
groundwater levels would be reduced because construction watering during dry and windy
conditions for dust and debris control would be minimized and less dewatering would occur
overall. This alternative would result in similar impacts regarding water quality standards and
waste discharge requirements, and flood and tsunami hazards compared to the proposed program.
Overall, Alternative 2 would result in less than significant impacts regarding hydrology and water
quality and fewer impacts than the proposed program.
4.2.2.9 Land Use and Planning
The proposed program would result in no impact to land use and planning (see section 3.9 of the
Draft PEIR). The proposed program would not conflict with the City of Huntington Beach Local
Coastal Program’s policies or regulations. Under Alternative 2, no development would occur and
Plant No. 1 and No. 2 would not develop any new facilities. As such, this alternative would not
change existing land use or have an effect on land use plans and policies related to the program
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area. Overall, this alternative would result in similar impacts regarding land use as compared to
the proposed program.
4.2.2.10 Noise and Vibration
The proposed program would result in less than significant impacts regarding noise and vibration
(see Section 3.10 of the Draft PEIR). Under the Alternative 2, there would be 100 less days of
pile driving required for TPAD facility implementation, therefore, vibration levels would be
greatly reduced as compared to the proposed program. Further, because less construction noise
would take place overall and less construction haul trucks would be required, temporary increases
of ambient noise levels within the program area would be reduced. Alternative 2 would result in
similar, less than significant impacts regarding noise standards and permanent noise levels as the
proposed program. Overall, this alternative would result in less than significant impacts regarding
noise and vibration and fewer impacts compared to the proposed program.
4.2.2.11 Transportation and Traffic
The proposed program would result in a less than significant impact to traffic and transportation
(see Section 3.11 of the Draft PEIR). The amount of biosolids truck trips would be the same for
Alternative 2 compared to the proposed program. An increase of 44 one-way truck trips would
occur because of the implementation of the food waste facilities at Plant No. 2. This increase in
truck trips is nominal and would not substantially impact traffic in the program area. Overall, this
alternative would result in similar transportation and traffic impacts compared to the proposed
program.
4.2.2.12 Tribal Cultural Resources
The proposed program would result in no impact to tribal cultural resources (see Section 3.12 of
the Draft PEIR). Under Alternative 2, less ground disturbing activities would occur. Therefore,
this alternative would result also in no impacts to tribal cultural resources similar to the proposed
program.
4.2.2.13 Utilities, Service Systems, and Energy
The proposed program would result in a less than significant impacts to utilities, service systems,
and energy (see Section 3.13 of the Draft PEIR). Because less facilities would be implemented on
Plant No. 1 and Plant No. 2 under Alternative 2, the natural drainage courses of the sites would
remain the same and existing stormwater drainage facilities would not need to be altered. Further,
Alternative 2 would not be demolishing the existing warehouse at Plant No. 2, therefore, the
potential increase in demolition debris to impact landfill capacity serving the proposed program
would be reduced. Alternative 2 would result in similar impacts to wastewater treatment
requirements, water supplies, compliance with solid waste regulations, and energy as the
proposed program. Overall this alternative would result in less than significant impacts to
utilities, service systems, and energy and fewer impacts than the proposed program.
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4.2.3 Findings for Alternative 2: Baseline, Mesophilic Digestion,
Class B
Alternative 2 would reduce but not eliminate potential significant impacts of the proposed
program. By not implementing all individual projects within the proposed program, there would
be a reduction in the total amount of construction; therefore, impacts to air quality, cultural
resources, and other environmental resources would be proportionately reduced. However, the
transition from Class B biosolids to Class A biosolids ultimately results in a reduction of VMT
because Class A biosolids can be transported to closer end-users. Alternative 2 would result in
continuation of Class B biosolids being generated and transported to end-users in Arizona.
Alternative 2 would not decrease the amount of VMT; therefore, the amount of truck trips/VMT
would stay the same as existing conditions and have a potentially greater impact on greenhouse
gases and traffic than the proposed program. Alternative 2 would meet three of the four proposed
program objectives; however, it would not meet the objective of transitioning from Class B to
Class A biosolids quality at Plant No. 2 and would not be able to increase biosolids management
diversity for end users of biosolids.
4.3 Alternative 3: Proposed Program Without Food Waste
Facilities
4.3.1 Description
The Reduced TPAD Alternative represents the proposed program projects without the
incorporation of food waste facilities. This alternative would not construct the proposed Interim
and Ultimate food waste receiving and ancillary facilities. These facilities are contained within
the following proposed projects:
• P2-502 Interim Food Waste Facility
• P2-506, Ultimate Food Waste Facility
Under Alternative 2, OCSD would transition into treating wastewater at Plant No. 2 with
thermophilic digestion and would begin to produce Class A biosolids. This alternative would
change the type of biosolids handling facilities being used, update the efficiency of the
technology, and diversify biosolids end-uses. However, this alternative would not receive pre-
process food waste (source separated organics) for co-digestion to assist in diverting organics
from landfills. This alternative would meet three of the four objectives of the proposed program.
This alternative would meet three of the four objectives of the proposed program. It would not
accommodate the object to receive pre-processed food waste for co-digestion.
A total of 16.5 acres would be graded for Alternative 3. Because the food waste facilities would
not be implemented under Alternative 2, the amount of excavation and grading would be reduced.
By not implementing the new food waste facilities, there would be a reduction in the total amount
of cubic yards of soil that would need to be excavated. Furthermore, trucks would no longer need
to enter Plant No. 2 to deliver the pre-process food waste.
The addition of SSO to the digestion process increases the amount of biogas generated that can be
captured, converted, and used as energy to operate facilities on Plant No. 2. Alternative 3 would
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not incorporate SSO (food waste), and therefore, digestion would result in less biogas being
generated. Although less biogas would be generated, this alternative would not require offsite
energy for the proposed facilities.
4.3.2 Impact Analysis
The relative difference in environmental impacts associated with the Proposed Program Without
Food Waste Facilities Alternative when compared to the proposed program is provided below.
4.3.2.1 Aesthetics
The proposed program would result in a less than significant impact to aesthetics with mitigation
(see Section 3.1 of the Draft PEIR). Alternative 3 would not construct the interim or ultimate food
waste facilities and result in the grading of approximately 3.0 less acres than the proposed
program. Similar to the proposed program, Alternative 3 would result in less than significant
impacts regarding scenic vistas and visual character of the area. Because Alternative 3 would
result in less facilities being constructed, Alternative 3 would introduce fewer new sources of
light or glare to the program area. Overall, Alternative 3 would result in less than significant
impacts regarding scenic vistas, visual character, and light or glare, and would result in fewer
impacts than the proposed program.
4.3.2.2 Air Quality
The proposed program would result in a less than significant impact to air quality with mitigation
(see Section 3.2 of the Draft PEIR). Alternative 3 would not construct the interim or ultimate food
waste facilities and result in the grading of approximately 3.0 less acres than the proposed
program. Under Alternative 3, less grading would reduce the amount of construction NOx
emissions; however, this reduction would still require the proposed program mitigation measures
to reduce potential regional construction emissions to less than significant. In addition, localized
construction emissions of PM10 and PM2.5 would be less compared to the proposed program;
however, Alternative 3 would still require the proposed program mitigation measures to reduce
increases of PM10 and PM2.5 to less than significant. Alternative 3 would result in less localized
construction emissions impacts compared to the proposed program.
The food waste facilities would store SSO, which could contribute to odors in the program area.
Therefore, because Alternative 3 would not implement the food waste facilities, potential impacts
regarding odors would be reduced as compared to the proposed program. Overall, Alternative 3
would have less than significant impacts to air quality and would result in fewer impacts than the
proposed program.
4.3.2.3 Biological Resources
The proposed program would result in less than significant impacts to biological resources with
mitigation (see Section 3.3 of the Draft PEIR). Under Alternative 3, less construction would take
place overall; therefore, noise levels due to construction activities would be reduced. The reduced
noise levels would have less of a potential impact on nearby nesting birds. Overall, Alternative 3
would result in less than significant impacts to biological resources and would result in fewer
impacts than the proposed program.
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4.3.2.4 Cultural Resources
The proposed program has the potential to encounter human remains and archaeological and
paleontological resources during ground disturbing activities, however, the program would result
in less than significant impacts to cultural resources with mitigation (see Section 3.4 of the Draft
PEIR). Under Alternative 3, less excavation and ground disturbance would occur at Plant No. 2;
therefore, the potential for encountering human remains, archeological and paleontological
resources during construction activities would be reduced. Overall, Alternative 3 would result in
potentially significant impacts to historical resources and less than significant impacts to
archeological and paleontological resources and human remains, and fewer impacts than the
proposed program.
4.3.2.5 Geology, Soils, and Seismicity
The proposed program would result in less than significant impacts related to exposure to
geologic hazards with mitigation incorporated (see Section 3.5 of the Draft PEIR). Alternative 3
would result in similar impacts regarding earthquakes, unstable geologic locations, and expansive
soils as the proposed program. Because Alternative 3 would result in less ground disturbance and
excavation overall, the potential for soil erosion or topsoil loss to occur would be reduced.
Therefore, Alternative 3 would result in less impacts regarding soil erosion as compared to the
proposed program. Overall, Alterative 3 would result in less than significant impacts regarding
geology, soils, and seismicity, and would result in fewer impacts overall than the proposed
program.
4.3.2.6 Greenhouse Gas Emissions
The proposed program would result in a less than significant impacts to greenhouse gases (see
Section 3.6 of the Draft PEIR). Alternative 3 would result in lesser amounts of greenhouse gas
emissions because less construction truck haul trips would be required. Alternative 3 would result
in similar impacts regarding plans, policies, and regulations related to the reduction of greenhouse
gas emissions. Overall, Alternative 3 would result in less than significant impacts to greenhouse
gas emissions and less impacts than the proposed program.
4.3.2.7 Hazards and Hazardous Materials
The proposed program would result in a less than significant impact to hazards and hazardous
materials with mitigation (see Section 3.7 of the Draft PEIR). The proposed program would result
in a potentially significant impact regarding a hazardous materials site listing if the collections
yard is relocated to the northern location of Plant No. 1. Under Alternative 3, the collections yard
would be relocated to Plant No. 1; therefore, Alternative 3 would result in a similar potential
significant impact regarding construction near or on a hazardous materials site. Further,
Alternative 3 would result in similar impacts as the proposed program regarding the routine use
of hazardous materials, accidental release of hazardous materials, the use of hazardous materials
near a school, and confliction with emergency plans. Overall, Alternative 3 would result in less
than significant impacts to hazards and hazardous materials and similar impacts than the proposed
program.
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4.3.2.8 Hydrology and Water Quality
The proposed program would result in less than significant impacts to hydrology and water
quality (see Section 3.8 of the Draft PEIR). Under Alternative 3, there would be less acres of
disturbed area because the food waste facilities would not be implemented. The potential for
sedimentation and erosion to occur due to exposed soil during construction activities would be
reduced. Further, because less facilities would be implemented on Plant No. 2, impacts regarding
the alteration of stormwater drainage facilities would be reduced. Because Alternative 3 would
result in less excavation for food waste facility implementation, the impacts to groundwater levels
would be reduced because construction watering during dry and windy conditions for dust and
debris control would be minimized and less dewatering would occur overall. This alternative
would result in similar impacts regarding water quality standards and waste discharge
requirements, and flood and tsunami hazards compared to the proposed program. Overall,
Alternative 3 would result in less than significant impacts regarding hydrology and water quality
and fewer impacts than the proposed program.
4.3.2.9 Land Use and Planning
The proposed program would result in no impact to land use and planning (see Section 3.9 of the
Draft PEIR). The proposed program would not conflict with the City of Huntington Beach Local
Coastal Program’s policies or regulations. Under Alternative 3, similar development would occur
at Plant No. 1 and Plant No. 2 as the proposed program. As such, this alternative would not
change existing land uses or have an effect on land use plans and policies related to the program
area. Overall, this alternative would result in similar impacts regarding land use as compared to
the proposed program.
4.3.2.10 Noise and Vibration
The proposed program would result in less than significant impacts regarding noise and vibration
(see Section 3.10 of the Draft PEIR). Under the Alternative 3, there would be 10 less days of pile
driving required for food waste facility implementation, therefore, vibration levels would be
reduced as compared to the proposed program. Further, because less construction noise would
take place overall and less construction haul trucks would be required, temporary increases of
ambient noise levels within the proposed program area would be reduced. Alternative 3 would
result in similar, less than significant impacts regarding noise standards and permanent noise
levels as the proposed program. Overall, this alternative would result in less than significant
impacts regarding noise and vibration and fewer impacts compared to the proposed program.
4.3.2.11 Transportation and Traffic
The proposed program would result in a less than significant impact to traffic and transportation
(see Section 3.11 of the Draft PEIR). The amount of biosolids truck trips would be the same for
Alternative 3 compared to the proposed program. A decrease of 44 one-way truck trips would
occur because the food waste facilities associated with the proposed program would not be
implemented at Plant No. 2 under Alternative 3. This decrease of incoming truck trips would
lessen traffic in the immediate program area. Overall, this alternative would result in less than
significant impacts to traffic and transportation and fewer impacts compared to the proposed
program.
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4.3.2.12 Tribal Cultural Resources
The proposed program would result in no impact to tribal cultural resources (see Section 3.12 of
the Draft PEIR). Under Alternative 3, less ground disturbing activities would occur. Therefore,
this alternative would result also in no impacts to tribal cultural resources similar to the proposed
program.
4.3.2.13 Utilities, Service Systems, and Energy
The proposed program would result in a less than significant impacts to utilities, service systems,
and energy (see Section 3.13 of the Draft PEIR). Because less facilities would be implemented on
Plant No. 2, impacts regarding the alternation of stormwater drainage facilities would be reduced.
Alternative 3 would result in similar impacts to wastewater treatment requirements, water
supplies, landfill capacity, and compliance with solid waste regulations. However, because
Alternative 3 would not incorporate SSO (food waste), digestion would result in less biogas being
generated. Biogas can be sent to the CenGen facility to be converted to energy. Alternative 3
would result in a reduction of biogas and potentially greater impact to energy as compared to the
proposed program. Overall, this alternative would result in less than significant impacts to
utilities and service systems and fewer impacts than the proposed program and this alternative
would result in less than significant impacts regarding energy, but greater impacts compared to
the proposed program.
4.3.3 Findings for Alternative 3: Proposed Program Without
Food Waste Facilities
Alternative 3 would reduce but not eliminate potential significant impacts of the proposed
program. By not implementing all individual projects within the proposed program, there would
be a reduction in the total amount of construction; therefore, impacts to air quality, cultural
resources, and other environmental resources would be proportionately reduced. However, the
inclusion of food waste facilities significantly increases the amount of renewable energy that can
be used for Plant No. 2 facilities. Alternative 3 would not generate as much biogas as the
proposed program and therefore could result in a potentially greater impact on energy. Alternative
3 would meet three of the four proposed program objectives; however, it would not meet the
objective of receiving pre-processed food waste for co-digestion to assist in diverting organics
from landfills and to increase digester gas production used as a renewable energy.
4.4 Environmentally Superior Alternative
CEQA requires that an EIR identify an environmentally superior alternative of a project other
than the No Project Alternative (CEQA Guidelines Section 15126.6(e)(2)). Table 5-3 of the Draft
PEIR shows an impact determination comparison for potentially significant impacts of the
proposed program to all the proposed program alternatives. The following is a summary of the
impacts associated with each proposed program alternative compared to the proposed program.
Based on the comparative analysis provided in Section 4.3 above, Alternative 2 (Baseline,
Mesophilic Digestion, Class B Alternative), would result in less significant environmental effects
compared to the proposed project and other alternatives. Alternative 2 would lessen the proposed
program’s environmental impacts in areas such as aesthetics, air quality, biological resources,
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cultural resources, geology, soils and seismicity, greenhouse gas emissions, hazards and
hazardous materials, hydrology and water quality, noise and vibration, traffic and transportation,
tribal cultural resources, and utilities and service systems. Alternative 2 would be the
environmentally superior alternative. This alternative would meet three of the four proposed
program objectives, but it would not meet the objective of transitioning from Class B to Class A
biosolids quality at Plant No. 2, and would not be able to increase biosolids management diversity
for end users of biosolids. Because a primary objective of the program is to provide Class A
biosolids quality, this alternative has been rejected.