Draft Environmental Impact Report for Green Acres Farm Biosolids Land ...

Draft Environmental Impact Report for Green Acres Farm

Biosolids Land Application Project:

CEQA

Prepared for: City of Los Angeles Los Angeles, California

Prepared by: ENVIRON International Corporation

Los Angeles, California

Date: April 17, 2014

Project Number: 05-23210I

Bureau of Engineering Environmental Management Group

City of Los Angeles

Bureau of Sanitation

Contents

Contents

1 1.1 1.2 1.2.1 1.2.2 1.3 1.4 1.5

Introduction Purpose of an Environmental Impact Report (EIR) The CEQA Environmental Process Previous CEQA Actions Current CEQA Actions Project Outreach Areas of Known Controversy and Issues to be Resolved Organization of the EIR

2 2.1 2.2 2.3 2.3.1 2.3.2 2.4 2.5 2.6

Project Description Project Background Project Location Existing Environment Farming Activities Regulatory Setting Project Purpose Project Description Project Approvals Required

3 3.1 3.1.1 3.1.2 3.1.3 3.1.4 3.1.5 3.1.6 3.1.7 3.2 3.2.1 3.2.2 3.2.3 3.2.4 3.2.5 3.3 3.3.1 3.3.2 3.3.3 3.3.4 3.3.5 3.4 3.4.1

Environmental Setting, Impacts, and Mitigation Air Quality Existing Setting Regulatory Setting Environmental Impacts Impact Analysis Odor Assessment Significance Determination Mitigation Measures Greenhouse Gases Existing Setting Regulatory Setting Environmental Impacts Significance Determination Mitigation Measures Hydrology/Water Quality Existing Setting Regulatory Setting Environmental Impacts Significance Determination Mitigation Measures Land Use/Planning Existing Setting

Green Acres Farm Biosolids Land Application Project Draft EIR City of Los Angeles Department of Public Works ? Regulatory Affairs Division

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1 1 1 1 1 2 2 5

8 8 10 13 13 14 19 21 21

23 23 23 26 32 35 42 47 48 50 50 52 56 60 61 62 62 62 64 76 77 82 82

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Contents

3.4.2 3.4.3 3.4.4 3.4.5

Regulatory Setting Environmental Impacts Significance Determination Mitigation Measures

4

Alternatives

4.1 Introduction

4.2 Alternatives Considered and Rejected

4.2.1 Description of the Project Alternatives Evaluated

4.2.2 Project Alternatives Rejected

4.3 Comparison of Impacts: Alternatives to the Proposed Project

4.3.1 Agriculture and Forestry Resources

4.3.2 Air Quality

4.3.3 Greenhouse Gas Emissions

4.3.4 Hydrology and Water Quality

4.3.5 Land Use and Planning

4.4 Conclusion

5

Other CEQA Considerations

5.1 Cumulative Impacts

5.1.1 Aesthetics

5.1.2 Agriculture and Forestry Resources

5.1.3 Air Quality

5.1.4 Biological Resources

5.1.5 Cultural Resources

5.1.6 Geology/Soils

5.1.7 Greenhouse Gas Emissions

5.1.8 Hazards

5.1.9 Hydrology/Water Quality

5.1.10 Land Use/Planning

5.1.11 Mineral Resources

5.1.12 Noise

5.1.13 Population/Housing

5.1.14 Public Services

5.1.15 Recreation

5.1.16 Transportation/Traffic

5.1.17 Utilities/Service Systems

5.2 Significant Irreversible Environmental Changes

5.3 Growth-Inducing Impacts

6

Acronyms and Abbreviations

7

Preparers

8

References

Green Acres Farm Biosolids Land Application Project Draft EIR City of Los Angeles Department of Public Works ? Regulatory Affairs Division

82 84 85 87

90 90 90 93 93 95 95 96 98 99 101 101

104 104 105 105 105 105 105 106 106 106 106 106 107 107 107 107 107 107 108 108 108

109

113

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List of Tables

List of Tables

Table 2-1: Key Dates in Regulatory Setting

19

Table 3-1: Historical Ambient Air Concentration Levels - San Joaquin Valley Air Basin and

South Coast Air Basin

25

Table 3-2: 2000 Baseline Operating Scenario

26

Table 3-3: California Ambient Air Quality Standards

27

Table 3-4: Criteria Pollutants, Their Precursors, and Related Health Effects [1]

29

Table 3-5: SJVAPCD Project Emissions Significance Thresholds

34

Table 3-6: SCAQMD Significance Thresholds

34

Table 3-7: Annual Emissions Resulting from the Proposed Project - San Joaquin Valley Air

Basin

37

Table 3-8: Mass Daily Emissions Resulting from the Proposed Project - South Coast Air

Basin

39

Table 3-9: Annual TAC Emissions Resulting from the Proposed Project - San Joaquin Valley

Air Basin

41

Table 3-10: Annual TAC Emissions Resulting from the Proposed Project ? South Coast Air

Basin

41

Table 3-11: Mitigation measures from 1989 and 1996 PEIRs

48

Table 3-12: 2000 Baseline Operating Scenario

52

Table 3-13: Annual Emissions Resulting from the Proposed Project - San Joaquin Valley Air

Basin

59

Table 3-14: Annual Emissions Resulting from the Proposed Project ? South Coast Air Basin

59

Table 3-15: Annual Emissions Resulting from the Proposed Project ? Total Emissions

60

Table 3-16: Mitigation Measures from 1989 and 1996 PEIRs and CAPCOA's Guidance

61

Table 3-17: Pollutants of Concern Evaluated for Land Application of Biosolids

68

Table 3-18: 2011-2012 Hyperion Treatment Plant Biosolids Monitoring Data and Applicable

Pollutant Limits

71

Table 3-19: Cumulative Metals Loading at Green Acres Farm, 2000-2012

72

Table 3-20: Mitigation measures included in 1989 PEIR

78

Table 3-21: Permit Requirements included in State Water Board Order No. 94-0012-DWQ and

Central Valley RWQCB Orders No. 88-172, 94-286, and 95-140

80

Table 3-22: Mitigation measures included in 1989 PEIR if land use impacts were determined

to be significant

88

Table 41: Equipment and Associated Parameter Comparison of the Baseline, Project, and

Alternatives

92

Table 4-2: Comparison of Maximum Annual Emissions - SJVAB

96

Table 4-3: Comparison of Maximum Daily Emissions - SCAB[1]

96

Table 4-4: Comparison of Total Annual GHG Emissions

98

Table 4-5: Comparison of Alternatives to the Proposed Project - SJVAB Impacts

102

Table 4-6: Comparison of Alternatives to the Proposed Project - SCAB Impacts

103

List of Figures

Figure 2-1: Regional Map of Green Acres

11

Figure 2-2: Vicinity Map of Green Acres

12

Figure 2-3: Aerial Image of Green Acres

13

Figure 3-1: Percent of Time Odors Would Exceed 1 D/T

46

Figure 3-2: Percent of Time Odors Would Exceed 4 D/T

46

Figure 3-3: 2000-2011 Chloride Concentrations in Groundwater from City Well No. 7

74

Figure 3-4: 2000-2011 Electrical Conductivity in Groundwater from City Well No. 7

74

Figure 3-5: 2000-2011 Nitrate Concentration in Groundwater from City Well No. 7

75

Figure 3-6: 2000-2011 pH in Groundwater from City Well No. 7

75

Figure 3-7: Location of sensitive receptors in the vicinity of the Farm

89

Green Acres Farm Biosolids Land Application Project Draft EIR City of Los Angeles Department of Public Works ? Regulatory Affairs Division

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List of Appendices

List of Appendices

Appendix A: Appendix B: Appendix C: Appendix D:

Initial Study and Notice of Preparation Response to Comments Emissions Calculations ? Project Emissions Calculations - Alternatives

Green Acres Farm Biosolids Land Application Project Draft EIR City of Los Angeles Department of Public Works ? Regulatory Affairs Division

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Introduction

1 Introduction

1.1 Purpose of an Environmental Impact Report (EIR) This Environmental Impact Report (EIR) has been prepared by the City of Los Angeles Department of Public Works, Bureau of Sanitation (BOS) to evaluate potential environmental effects that would result from the proposed Green Acres Farm Biosolids Land Application Project (proposed project). This EIR has been prepared in conformance with the California Environmental Quality Act of 1970 (CEQA) statutes (Public Resources Code ?21000 et seq.) and the State CEQA Guidelines (Title 14, California Code of Regulations, ?15000 et seq.). The City of Los Angeles (the City) is the lead agency under CEQA.

The project site is located at Green Acres Farm (the Farm), which consists of nearly 4,700 acres of land in unincorporated western Kern County where active farming has occurred since 1988. The two interrelated subsequent activities in the City's biosolids program (described further in Section 2.6) are the components of this proposed project. These two subsequent activities are: (1) the City's approval in 2000 of Amendment No. 2 to City Contract C-94375, a pre-existing contract between the City and the contractor, Responsible Biosolids Management, Inc. (RBM), for the loading, transportation, and beneficial reuse of the City's biosolids at the Farm; and (2) the City's purchase of the Farm in 2000.1 As a result of a Tulare County Court Superior Court Writ of Mandate in 2005 (Writ) and Court Order on Return to Writ of Mandate in 2012 (Court Order), an Initial Study (IS) was prepared for these two actions (Section 1.2.1). Based on the conclusions of the IS, this EIR has been prepared. This is a retrospective EIR for a project that commenced in 2000 and resulted from the Writ and Court Order.

1.2 The CEQA Environmental Process

1.2.1 Previous CEQA Actions A Program EIR (PEIR) was prepared in 1989 (1989 PEIR) to analyze off-site options for use and/or disposal of biosolids produced at the City's wastewater treatment plants, including land application.2 A second PEIR was prepared in 1996 (1996 PEIR) to further analyze the environmental impacts associated with the City's management and use of biosolids.3 In response to the Writ, an addendum to the 1989 and 1996 PEIRs was prepared in 2010 (Addendum). In 2012, the Court Order ruled that the Addendum was inadequate to discharge the Writ and the City was directed to prepare an IS. This current CEQA analysis has been prepared to address the Writ and Court Order.

1.2.2 Current CEQA Actions CEQA requires preparation of an EIR when there is substantial evidence supporting a fair argument that a proposed project may have a significant effect on the environment. The purpose of an EIR is to provide decision makers, public agencies, and the general public with an

1 Note that all documents and references used in the EIR will be available upon request through the Bureau of Sanitation contact person(s) listed for this EIR

2 City of Los Angeles. 1989. Program EIR: Offsite Sludge Transportation and Disposal Program. March 1989. State Clearinghouse No. 88021018.

3 City of Los Angeles. 1996. Program EIR: Biosolids Management Program. State Clearinghouse No. 93051010.

Green Acres Farm Biosolids Land Application Project Draft EIR City of Los Angeles Department of Public Works ? Regulatory Affairs Division

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Introduction

objective and informational document that fully discloses the environmental effects of the proposed project. The EIR process is intended to facilitate the objective evaluation of potentially significant direct, indirect, and cumulative impacts of the proposed project, and to identify feasible mitigation measures and alternatives that would reduce or avoid the proposed project's significant effects. In addition, CEQA specifically requires that an EIR identify those adverse impacts determined to be significant after mitigation.

In accordance with the CEQA Guidelines, an IS was prepared and a Notice of Preparation (NOP) distributed on February 14, 2013, to public agencies, interested organizations, and the general public. The purpose of the IS/NOP was to provide notification that the City plans to prepare an EIR and to solicit input on the scope and content of the EIR. The IS/NOP was distributed to agencies, property owners, and occupants via mail (530 recipients) and e-mail (655 recipients); 19 written comment letters and e-mails were received from various agencies, organizations, and individuals. The IS/NOP is included in Appendix A and the letters and emailed comments are included in Appendix B of this EIR.

1.3 Project Outreach

A public agency scoping meeting was held near the project site at the Frazier Park Library in Frazier Park in Kern County on March 6, 2013. The purpose of this meeting was to seek input from public agencies and the general public regarding the environmental issues and concerns that may potentially result from the proposed project. One person submitted oral comments at the scoping meeting.

1.4 Areas of Known Controversy and Issues to be Resolved

The following list summarizes the main public comments and questions that were received in response to the IS/NOP and at the scoping meeting related to environmental issues:

? Aesthetics. Comments were raised about the proximity of the project to off-site receptors and whether the smell or appearance of the Farm will interfere with visitors' enjoyment of the nearby recreation areas.

? Agriculture and Forestry Resources. A comment stated that the proposed EIR must analyze the impacts to public health of applying biosolids to food-chain crops. An additional comment stated that an analysis of the constituents of the harvested crop should be conducted and their final environmental fate should be determined. Additionally, comments raised the concern that existing farmland and at least one canal used for crop irrigation could be impacted by the project.

? Air Quality. Comments were raised associated with the potential criteria pollutant and greenhouse gas (GHG) emissions from transporting the biosolids; criteria pollutants that are able to escape after the spread material is covered; whether hot and windy days will increase the release of microbes and toxics; potential construction and operation related air quality impacts; and possible alternatives such as using the biosolids for fuel or treating them with high heat and pressure to produce hydrogen and carbon dioxide. In addition, it was suggested that California Emissions Estimation Model (CalEEModTM) be used for estimating emissions; that emissions of particulate matter less than 2.5 microns (PM2.5) should be quantified and compared to the recommended South Coast Air Quality Management District (SCAQMD) significance thresholds; and that a localized air quality analysis and a mobile source health risk assessment (HRA) be done if the proposed project

Green Acres Farm Biosolids Land Application Project Draft EIR City of Los Angeles Department of Public Works ? Regulatory Affairs Division

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Introduction

generates or attracts vehicle trips. Comments expressed concerns about the potential for airborne pathogen release and contamination by microbes, nutrients, and toxins.

? Biological Resources. Comments stated that the PEIR found a significant impact to biological resources where nondegradable constituents would assimilate into vegetation onsite, and that the EIR must discuss appropriate mitigation measures. A commenter also stated that the EIR must include a full chapter on biological resources including current surveys on the use of the site and the potential impacts of the last 12 years of biosolids spreading on wildlife.

? Cultural Resources. Suggestions were submitted that the Native American Heritage Commission (NAHC), Native American tribes in the area, and the appropriate Information Center should be consulted to examine whether any archaeological fixtures, cultural resources or burial sites exist in the project location.

? Geology/Soils. One comment stated that the PEIR found that land application rates greater than 25 wet tons per acre would result in significant heavy metal contamination in soils so the loading rate must be strictly controlled. Other comments state that the EIR must address the site-specific impacts of the project on soils and their mitigation measures. A commenter stated the EIR must also address the conflict between the actual land application rate and the rate imposed as a mitigation measure in the PEIR.

? Greenhouse Gases. Concerns were raised about the potential GHG emissions resulting from transporting and land applying the biosolids at the Farm and that the emissions need to be examined in the EIR.

? Hazards and Hazardous Materials. No comments related to hazards and hazardous materials was received.

? Hydrology/Water Quality. Questions were raised regarding whether the water supply was based on groundwater, surface water, or treated wastewater; whether any potential water seepage to water supplies and resources were being considered; and whether there were any effects on water quality. One comment suggested consideration of project alternatives such as anaerobic digestion and incineration, or alternative project locations to minimize water contamination and human ingestion.

? Land Use/Planning. One comment states that the EIR must analyze whether the impacts to land use from the acquisition of the Farm would be less than that analyzed in the PEIR.

? Noise. One commenter stated that the PEIR found that noise impacts would be significant but would be mitigated through using sufficient buffers of 3,000 feet. However, the IS stated that the nearest sensitive receptor is 1,850 feet from the Farm, so commenter stated the EIR must analyze the significant noise impacts.

? Population/Housing. No comments related to population/housing were received.

? Public Services. No comments related to public services were received.

? Recreation. Comments expressed concern that the location of the project is adjacent to the Buena Vista Aquatic Recreation Area (BVARA).

? Transportation/Traffic. One comment stated that reliance on the PEIR analysis of truck traffic is inadequate and the EIR must analyze the site specific impacts of truck traffic. Another comment stated that the EIR must consider the cost of maintaining Kern County roads.

? Utilities/Service Systems. No comments related to utilities/service systems were received.

Green Acres Farm Biosolids Land Application Project Draft EIR City of Los Angeles Department of Public Works ? Regulatory Affairs Division

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