35 MARIA DRIVE HOUSING PROJECT HEALTH RISK ANALYSIS AND GREENHOUSE GAS EMISSIONS ASSESSMENT PETALUMA, CALIFORNIA

Transcription

1 35 MARIA DRIVE HOUSING PROJECT HEALTH RISK ANALYSIS AND GREENHOUSE GAS EMISSIONS ASSESSMENT PETALUMA, CALIFORNIA October 22, 2012 Prepared for: Mike Kelley Pacific West Communities 555 Capitol Mall Drive, Suite 410 Sacramento, CA Prepared by: Joshua Carman and William Popenuck 505 Petaluma Boulevard South Petaluma, CA (707) Project

2 INTRODUCTION This report provides the results of an assessment of potential health risk impacts and greenhouse gas emissions from the proposed housing development project at 35 Maria Drive in Petaluma, California. The project proposes to demolish four existing buildings at the site and construct 144 apartment units on approximately 5.86 acres. The project would be located between the Washington Square Shopping Center to the south and Washington Creek to the north. This report addresses operational and construction-related air quality health risk and climate change environmental checklist questions for compliance with CEQA, assuming the ultimate development of the project as described above. Due to the relatively small size, the project is not anticipated to have impacts to regional air quality in terms of criteria air pollutant emissions or cause local air quality impacts that would have been associated with traffic (i.e., cause violations of ambient air quality standards for carbon monoxide). SETTING Sensitive Receptors There are groups of people more affected by air pollution than others. CARB has identified the following persons who are most likely to be affected by air pollution: children under 14, the elderly over 65, athletes, and people with cardiovascular and chronic respiratory diseases. These groups are classified as sensitive receptors. Locations that may contain a high concentration of these sensitive population groups include residential areas, hospitals, daycare facilities, elder care facilities, elementary schools, and parks. The closest sensitive receptors to the project site are residences located to the north and east of the project construction site (see Figure 1 in Attachment 1). Greenhouse Gases Global temperatures are affected by naturally occurring and anthropogenic-generated (generated by humankind) atmospheric gases, such as water vapor, carbon dioxide, methane, and nitrous oxide. Gases that trap heat in the atmosphere are called greenhouse gases (GHG). Solar radiation enters the earth s atmosphere from space, and a portion of the radiation is absorbed at the surface. The earth emits this radiation back toward space as infrared radiation. Greenhouse gases, which are mostly transparent to incoming solar radiation, are effective in absorbing infrared radiation and redirecting some of this back to the earth s surface. As a result, this radiation that otherwise would have escaped back into space is now retained, resulting in a warming of the atmosphere. This is known as the greenhouse effect. The greenhouse effect helps maintain a habitable climate. Emissions of GHGs from human activities, such as electricity production, motor vehicle use and agriculture, are elevating the concentration of GHGs in the atmosphere, and are reported to have led to a trend of unnatural warming of the earth s natural climate, known as global warming or global climate change. The term global climate change is often used interchangeably with the term global warming, but global climate change is preferred because it implies that there are other consequences to the global climate in addition to rising temperatures. Other than water vapor, the primary GHGs contributing to global climate change include the following gases: Carbon dioxide (CO2), primarily a byproduct of fuel combustion; Nitrous oxide (N2O), a byproduct of fuel combustion; also associated with agricultural operations such as the fertilization of crops; Methane (CH4), commonly created by off-gassing from agricultural practices (e.g. livestock), wastewater treatment and landfill operations; 2

3 Chlorofluorocarbons (CFCs) were used as refrigerants, propellants and cleaning solvents, but their production has been mostly prohibited by international treaty; Hydrofluorocarbons (HFCs) are now widely used as a substitute for chlorofluorocarbons in refrigeration and cooling; and Perfluorocarbons (PFCs) and sulfur hexafluoride (SF6) emissions are commonly created by industries such as aluminum production and semiconductor manufacturing. These gases vary considerably in terms of Global Warming Potential (GWP), a term developed to compare the propensity of each GHG to trap heat in the atmosphere relative to another GHG. GWP is based on several factors, including the relative effectiveness of a gas to absorb infrared radiation and the length of time of gas remains in the atmosphere. The GWP of each GHG is measured relative to CO 2. Accordingly, GHG emissions are typically measured and reported in terms of CO 2 equivalent (CO 2 e). For instance, SF 6 is 22,800 times more intense in terms of global climate change contribution than CO 2. IMPACTS AND MITIGATIONS Community Risk Thresholds of Significance BAAQMD identified significance thresholds for exposure to Toxic Air Contaminants (TACs) and fine particulate matter (PM 2.5 ) as part of its CEQA Air Quality Guidelines 1 that were recently vacated. The Guidelines include thresholds to evaluate single source and cumulative source impacts of TACs and PM 2.5 on existing sensitive receptors and proposed sensitive receptors. The single source impact thresholds are based on BAAQMD Risk Management Policy and are currently used by BAAQMD to evaluate impacts from new air pollution sources. The cumulative community risk thresholds that were identified by BAAQMD are the only thresholds of this kind. Therefore, these thresholds are used to evaluate both impacts from this project. The following are the significance criteria that are used to judge this project s impacts: Expose sensitive receptors to substantial pollutant concentrations; Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment; and Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases. Single Source Impacts If emissions of TACs or PM 2.5 exceed any of the thresholds of significance listed below, the proposed project would result in a significant impact and mitigation would be required. An excess cancer risk level of more than 10 in 1 million, or a non-cancer (chronic or acute) hazard index greater than 1.0. An incremental increase of more than 0.3 micrograms per cubic meter (µg/m 3 ) annual average PM 2.5. Cumulative Source Impacts 1 BAAQMD, BAAQMD CEQA Air Quality Guidelines. May. Updated: May 2012 after the 2011 version was vacated by a 2012 court ruling. 3

4 A project would have a cumulatively considerable impact if the aggregate total of all past, present, and foreseeable future sources within a 1,000 foot radius of the fence line of a source or from the location of a receptor, plus the contribution from the project, exceeds the following thresholds. An excess cancer risk levels of more than 100 in one million or a chronic non-cancer hazard index (from all local sources) greater than µg/m 3 annual average PM 2.5. Greenhouse Gas Emissions The BAAQMD had also adopted thresholds for evaluating GHG emissions from projects and developed guidelines for assessing these impacts. 2 The recommendations include a bright line emissions threshold of 1,100 metric tons (MT) of CO 2 e per year or an emission efficiency metric of 4.6 MT of CO 2 e per year per service population if the bright-line threshold is exceeded. Service population is the sum of new residents and full time workers. There are no other quantified thresholds adopted by other agencies or the City to evaluate GHG emissions from land use projects. Impact 1: Expose sensitive receptors that are part of the Proposed Project to substantial pollutant concentrations? Less than significant The operation of the project is not expected to cause any localized emissions that could expose sensitive receptors to unhealthy air pollutant levels. However, the proposed project would locate new residences near the loading dock of the adjacent Safeway. Proximity to loading docks is associated with exposure to TACs or PM 2.5, predominantly from diesel emissions. In addition, stationary sources, such as gasoline stations and dry cleaners, are a source of TACs. The BAAQMD recommends using a 1,000-foot radius around a project site for purposes of identifying community health risk from siting a new sensitive receptor or a new source of TACs. A review of the area indicates that the proposed project would place new residences near one stationary source with a substantial reported risk (i.e., greater than the BAAQMD thresholds at a distance of 50 feet) is located within 1,000 feet of the project site. The analysis of this source used screening data provided by BAAQMD to identify the potential cancer risk and PM 2.5 exposure risks posed by stationary sources located within 1,000 feet. Impacts from Safeway Loading Dock The U.S. EPA ISCST3 dispersion model was used to predict concentrations of diesel particulate matter (DPM) from future loading activities at new project residences. Modeling was conducted using 5 years ( ) of hourly meteorological data from the Petaluma Airport obtained from BAAQMD. Truck emissions were modeled as a line source (a series of volume sources along a line) representing a travel route from Safeway to the north along Maria Drive (which is considered a conservative assumption since they may also travel to the south, but that would be away from new receptors). DPM concentrations were calculated at receptors within the project site at a height of 1.8 meters. Cancer risks were calculated for a 70-year exposure assuming constant emissions at 2015 levels over the entire 70 year period. A cancer risk adjustment factor of 1.7 was used for this analysis. The location of maximum risk is in the southern end of the proposed project (see Figure 1 in Attachment 1). 2 BAAQMD, 2011, op cit. 4

5 Emissions were calculated using emission rates from EMFAC2011 for 2015 for trucks in Sonoma County. Five (5) diesel-fueled medium duty trucks (MHDT) and 5 diesel-fueled heavy duty trucks (HHDT) were assumed to operate daily for 365 days per year between the hours of 8am to 5pm. Emissions were calculated assuming a travel speed of 25 mph on Maria Drive and 5 mph along the back of Safeway to the loading dock (see Figure 1 in Attachment 2). Emissions for years beyond 2015 were assumed to be the same as those for The maximum increased DPM cancer risk for a new residential receptor at the project site from delivery truck emissions is 0.40 per million and PM 2.5 concentration of µg/m 3. Impacts from Stationary Sources The BAAQMD s Google Earth Screening Tool also provides locations of stationary sources of TACs and screening level exposures that do not account for the distance from the source. This tool was used to identify sources within 1,000 feet of the site. This tool identified one source, Plant G4887, that is a Chevron gas station located at 1440 East Washington Street about 600 feet west of the project. Based on these data, the nearby gas station is predicted to have a cancer risk of 3.4 in one million, a hazard index of less than 0.1, and a PM 2.5 concentration of less than 0.1 µg/m 3 at the proposed project. Cumulative Community Risk Impacts Based on screening data provided by BAAMQD, the combination of exposures from Safeway loading dock activity and the nearby stationary source would result in excess cancer risks of less than 4 per million, PM 2.5 exposures of less than 0.1 µg/m 3 and a Hazard Index well below 1.0. These exposures are well below the cumulative source thresholds that were identified by BAAQMD. Impact 2: Expose existing sensitive receptors to substantial pollutant concentrations caused by the project? Less than significant with Mitigation Construction activity is anticipated to include demolition of existing buildings, excavation, grading, building construction, paving and application of architectural coatings. During demolition, excavation, grading and some building construction activities, substantial amounts of dust could be generated. Most of the dust would result during grading activities. The amount of dust generated would be highly variable and would be dependent on the size of the area disturbed at any given time, amount of activity, soil conditions and meteorological conditions. To address fugitive dust emissions that lead to elevated PM 10 and PM 2.5 levels near construction sites the BAAQMD CEQA Air Quality Guidelines identify best control measures. If included in construction projects, these impacts will be considered less than significant. In addition, construction equipment and associated heavy-duty truck traffic generates diesel exhaust which is a TAC. BAAQMD has developed screening tables for evaluating potential impacts from toxic air contaminants emitted at construction projects. 3 The screening tables are described by BAAQMD as environmentally conservative interim guidance and are meant to be used to identify potentially significant impacts that should be modeled using refined techniques. These screening tables indicate that construction activities similar to this project could have significant impacts at the distances of nearby residences, with the primary impact being excess cancer risk. Since project construction activities would include demolition, excavation, grading and building construction that would last longer than 6 months and would occur adjacent to neighboring residences, a more refined-level study of community risk assessment was conducted. Because the gross analysis indicated that impacts were possible, a refined 3 BAAQMD Screening Tables for Air Toxics Evaluation During Construction. May. 5

6 analysis was conducted to evaluate whether impact would be significant, and if so, identify the project features or mitigation measures that would be necessary to avoid significant impacts in terms of community risk impacts to nearby sensitive receptors (e.g., adjacent residences). The health risk assessment focused on modeling on-site construction activity using construction fleet information included in the project design features. Construction period emissions were computed using the California Emissions Estimator Model Version (CalEEMod) along with projected construction activity. Construction of the project is expected to occur over a fifteen month period during 2013 and Construction activities were assumed to occur 5 days per week between 8 am - 5 pm. The CalEEMod model provided annual PM 2.5 exhaust emissions (assumed to be diesel particulate matter) for the off road construction equipment used for construction of the project of 0.13 and tons per year for 2013 and 2014 construction years, respectively. On-road PM 2.5 exhaust emissions were calculated by CalEEMod as 0.01 and tons per year for 2013 and 2014, respectively. These on-road emissions are a result of on-road haul truck travel during demolition activities and vendor deliveries during construction. Since only a portion of the total on-road vehicle exhaust emissions would affect local residents near the project site, emissions from vehicles traveling on Maria Drive near the project site were calculated based on the length of roadway travelled relative to the total travel distance used by CalEEMod to calculate total emissions. Details of the emission calculations are provided in Attachment 2. CalEEMod input and output worksheets are provided in Attachment 3. The U.S. EPA ISCST3 dispersion model was used to predict concentrations of DPM at existing residences near the project site. The ISCST3 dispersion model is a BAAQMD recommended model for use in refined modeling analysis of CEQA projects 4. The ISCST3 modeling of construction activities used a single area source with a release height of 6 meters to represent the project construction area. The elevated source height reflects the height of the equipment exhaust pipes and buoyancy of the exhaust plume. Emissions from trucks traveling near the project site were assumed to travel along Maria Drive and were modeled as a line source (represented by a series of volume sources) as indicated in Figure 1 in Attachment 2. Emissions were modeled as occurring daily between 8 am - 5 pm for each of the construction years modeled. The ISCST3 model used a 5-year data set ( ) of hourly meteorological data from the Petaluma Airport, located about 0.85 miles northwest of the project site. Period average concentrations from construction activities were predicted for 2013 and 2014, with the concentrations for each construction year based on the 5-year average concentrations from modeling 5 years of meteorological data. DPM concentrations were calculated at receptors placed at nearby residences for two receptor heights, 5.9 feet (1.8 meters) and 15.9 feet (4.8 meters), representative of the first and second floor levels of apartments and multi-level homes. Increased cancer risks were calculated using the maximum modeled annual concentration and BAAQMD recommended risk assessment methods using age sensitivity factors for child exposure (3rd trimester through 2 years of age) and for an adult exposure. Since the modeling was conducted assuming emissions occurred 365 days per year, the default OEHHA 5 exposure period of 350 days per year was used. Infant and child exposures were assumed to occur at residences through the entire construction period. 4 BAAQMD. Recommended Methods for Screening and Modeling Local Risks and Hazards. Version 2.0, May OEHHA Air Toxics Hot Spots Program Risk Assessment Guidelines, The Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments. Office of Environmental Health Hazard Assessment. August

7 Results of this assessment indicate an incremental child cancer risk of 21.3 excess cancer cases in a million and the adult incremental cancer risk is 1.1 excess cancer cases in a million would occur at the location of the Maximum Exposed Individual (MEI). The predicted excess child cancer risk of 21.3 in one million would exceed the significance threshold of 10 in one million and would be considered significant. The annual average PM 2.5 concentration at the MEI location was modeled as 0.17 µg/m 3, which is below the BAAQMD threshold of 0.3 µg/m 3. The maximum non-cancer risk evaluated using BAAQMD s hazard index would be 0.03, while the threshold is 1.0. The location of the MEI is on the first floor of the multi-family residences on the west side of Maria Drive and is shown on Figure 1 in Attachment 2. Implementation of Mitigation Measure AQ-1 is considered to reduce exhaust emissions by 5 percent. Implementation of Mitigation Measure AQ-2 would further reduce on-site diesel exhaust emissions. The computed maximum excess child cancer risk with implementation of Mitigation Measure AQ-1 and AQ-2 would be 9.3 in one million 6 and a maximum PM 2.5 concentration of 0.07 µg/m 3. As a result, the project with mitigation measures would have a less-than-significant impact with respect to community risk caused by construction activities. Mitigation Measure AQ-1: Implement BAAQMD Recommended Best Control Measures for reducing fugitive dust emissions. The project design features for construction include BAAQMD recommended Best Management Practices along with construction equipment selection, techniques and scheduling that reduce impacts. This construction design features is intended to establish a process that minimizes fugitive dust and exhaust emissions that protects the health and safety of nearby sensitive receptors such that temporary construction emissions would not exceed the BAAQMD significance thresholds for community risk and hazard impacts. These features will include some combination of the following: 1. All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day. 2. All haul trucks transporting soil, sand, or other loose material off-site shall be covered. 3. All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited. 4. All vehicle speeds on unpaved roads shall be limited to 15 mph. 5. All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used. 6. Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations). Clear signage shall be provided for construction workers at all access points. 7. All construction equipment shall be maintained and properly tuned in accordance with manufacturer s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation. 8. Post a publicly visible sign with the telephone number and person to contact at the Lead Agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District s phone number shall also be visible to ensure compliance with applicable regulations. 6 Note that implementation of Mitigation Measure AQ-2 would reduce cancer risks to 9.79 per million and Mitigation Measure AQ-1 would reduce risks by another 5 percent. 7

8 Mitigation Measure AQ-2: Selection of equipment during demolition, grading and trenching construction phases to minimize emissions. Such equipment selection would include the following: 1. Diesel-powered off-road equipment larger than 50 horsepower and operating at the site more than two days that are used for demolition and mass grading/excavation shall meet U.S. EPA particulate matter emissions standards for Tier 4 engines or equivalent; 2. Minimize the number of hours that equipment will operate including the use of idling restrictions. 3. Line power shall be installed at the site as soon as possible after construction start and would be used to power equipment to avoid use of diesel-powered generator engines. Note that the construction contractor could use other measures to minimize construction period diesel particulate matter emissions to reduce the predicted cancer risk below the thresholds. Such measures may be the use of alternative powered equipment (e.g., LPG powered forklifts), alternative fuels (e.g., biofuels), added exhaust devices, or a combination of measures, provided that these measures are approved by the City. Impact 3: Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? Less than Significant GHG Significance Thresholds In 2010, BAAQMD adopted its updated CEQA Guidelines that contain methodology and thresholds of significance for evaluating GHG emissions from land use type projects. The BAAQMD thresholds were developed specifically for the Bay Area after considering the latest Bay Area GHG inventory and the effects of AB 32 scoping plan measures that would reduce regional emissions. BAAQMD intends to achieve GHG reductions from new land use developments to close the gap between projected regional emissions with AB 32 scoping plan measures and the AB 32 targets. The BAAQMD applies GHG efficiency thresholds to projects with emissions of 1,100 MT of CO 2 e or greater. Projects that have emissions below 1,100 MT of CO 2 e per year are considered to have less than significant GHG emissions. Methodology The California Emissions Estimator Model Version (CalEEMod) was used to predict net GHG emissions from operation of the site assuming full build-out of the project. The project land use types and size, trip generation rate and other project-specific information were input to the model. The use of this model for evaluating emissions from land use projects is recommended by the BAAQMD. Unless otherwise noted below, the CalEEMod model defaults for Sonoma County were used. CalEEMod provides emissions for transportation, areas sources, electricity consumption, natural gas combustion, electricity usage associated with water usage and wastewater discharge, and solid waste land filling and transport. CalEEMod output worksheets are included in Attachment 3. Land Use Descriptions The proposed project land uses were input into CalEEMod, which included 144 residential units entered as Apartments Mid-Rise. 8

9 Trip Generation Rates GHG emissions from changes in traffic were computed. Trip generation rates produced by W-Trans were input to CalEEMod. Trip generation represents the daily number of trips generated when the land use is fully operational minus trips from existing uses. Model Year The model uses mobile emission factors from the California Air Resources Board s EMFAC2007 model and adjusts these based on the effect of new regulations to reduce GHG emissions. These regulations include the Pavley Rule that increases fleet efficiency (reducing fuel consumption) and the low carbon fuel standard. This model is sensitive to the year selected, since vehicle emissions have and continue to be reduced due to fuel efficiency standards and low carbon fuels. The Year 2015 was analyzed since it is the first year that the project could conceivably be occupied. The Year 2012 was analyzed for the existing model run. Energy Default rates for energy consumption were assumed in the model. Emissions rates associated with electricity consumption were adjusted to account for Pacific Gas & Electric utility s (PG&E) projected 2015 CO 2 intensity rate. This 2015 rate is based, in part, on the requirement of a renewable energy portfolio standard of 33 percent by the year CalEEMod uses a default rate of pounds of CO 2 per megawatt of electricity produced. The derived 2015 rate for PG&E was estimated at pounds of CO 2 per megawatt of electricity delivered and is based on the California Public Utilities Commission (CPUC) GHG Calculator. 7 The derived 2012 existing rate for PG&E was estimated at pounds of CO 2 per megawatt of electricity delivered. Other Inputs Default model assumptions for GHG emissions associated with area sources, solid waste generation and water/wastewater use were applied to the project. Construction Emissions GHG emissions associated with construction were computed to be 488 MT CO 2. These are the emissions from on-site operation of construction equipment, hauling truck trips, vendor truck trips, and worker trips. The BAAQMD does not have an adopted Threshold of Significance for construction-related GHG emissions. The District recommends calculating the emissions and disclosure that GHG emissions would occur during construction. BAAQMD also encourages the incorporation of best management practices to reduce GHG emissions during construction where feasible and applicable. Best management practices assumed to be incorporated into construction of the proposed project include, but are not limited to: using local building materials of at least 10 percent and recycling or reusing at least 50 percent of construction waste or demolition materials. Operational Emissions The CalEEMod model, along with the project vehicle trip generation rates, was used to predict annual emissions associated with operation of the fully-developed site under the proposed project. In 2015, net annual emissions resulting from the proposed project are predicted to be 639 MT of CO 2 e. These emissions would be below the BAAQMD threshold of 1,100 MT of CO 2 e/yr. Table 1 shows these GHG emissions. 7 California Public Utilities Comissions GHG Calculator version 3c, October 7, Available on-line at: Accessed: September

10 Table 1 Annual Project GHG Emissions in Metric Tons 2015 Unmitigated Source Category Emissions Area 2 Energy Consumption 177 Mobile 409 Solid Waste Generation 30 Water Usage 21 Total 639 BAAQMD Threshold 1,100 MT CO 2 e/year Impact 4: Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases? No Impact The project would be subject to new requirements under rule making developed at the State and local level regarding greenhouse gas emissions and be subject to local policies that may affect emissions of greenhouse gases. 10

11 ATTACHMENT Operational Health Risk Analysis Data Construction Health Risk Analysis Data CalEEMod Modeling Output 11