HomeMy WebLinkAbout1987-05-19; City Council; 8928-1; Environmental Review San Marcos Trash to Energy EIRA &j@3/ CI ' OF CARLSBAD - AGENL I BILL
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MTG. 5/19/87
DEPT. PLN
TITLE: ENVIRONMENTAL CONSULTANTS REVIEW DEPT. HD.
CITY ATTYm AND EVALUATION OF THE SAN MARCOS TRASH TO ENERGY EIR
CITY MGR.~
RECOMMENDED ACTION:
The City Council adopt a neutral position in regards to the San Marcos Trash to Energy project.
ITEM EXPLANATION
On March 24, 1987 the City Council directed staff to hire a
consultant to review and evaluate a multi-volumed environmental impact report being prepared by the City of San Marcos. This document dealt with a number of major revisions to San Marcos' General Plan and the North County Recycling and Energy Recovery Center, better known as the San Marcos Trash to Energy Plant.
Many of the proposed revisions to San Marcos' General Plan in the
Questhaven were due to the proposed trash to energy plant. When reviewing the EIR, the City s consultant examined how Carlsbad would be impacted by these General Plan land use changes as well as the impacts of the trash to energy plant.
area
After evaluating bids from three companies, the firm of RECON was hired to prepare this review. During the past month the staff of RECON has completely reviewed all volumes of the EIR as well as
supplemental information from various sources. They have also met with the City of San Marcos and their consultants and met with representatives of North County Concerned Citizens. RECON
employees have completed several field examinations of the area involved.
Based on this work they have come up with a number of findings
and recommendations:
THE EIR:
1. The EIR is legally adequate. Revisions which would be anticipated for the final EIR are not likely to change the conclusions of the report.
MOST SIGNIFICANT ISSUES :
2. The most significant issues concerning the City of Carlsbad are land use and traffic, both of which result from proposed land use changes, not from the NCRERC project.
3. Regarding proposed land use changes relating to residential use, the City of Carlsbad should support
adoption of either Alternative 2 or 3 (lower density
alternatives) as identified in Volume I of the EIR or request a better statement of development criteria and
dwelling unit limits to be applied in the Specific Plan Area to be designated in the Questhaven/La Costa Meadows community.
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Page Two of Agenda Bill No. c 92P /
CONCERNS RELATED TO NCRERC:
4. The fundamental question related to this or any other
trash-to-energy project is whether or not its adverse
environmental effects are worse than those of continued use of landfills. Strong public opposition to the siting of new landfills has made their development very
difficult for the county. Consequently, a very real and
very extreme shortage of landfill capacity is expected
within a few years. The only alternative which can consume a significant volume of solid waste is incineration, or trash-to-energy processing. It is possible that the overall environmental effects of
trash-to-energy processing are less damaging than comparable land filling.
5. Intense citizen opposition to this trash-to-energy
project focuses on air pollution, public health, and
economics.
6. Review and regulation by the Air Pollution Control District, Air Resources Board, Environmental Protection Agency, State Department of Health Services, County of San Diego, and City of San Marcos addressed these issues. Work currently under way on a new health risk
assessment is not likely to change previous conclusions.
7. Several questions and comments have been made which should necessitate specific revisions or clarification in the final EIR. This information may be useful to concerned citizens but does not warrant a formal position for or against the NCRERC project by the City of Carl sbad .
Based on the findings and recommendations of the City's consultant, the consultant recommends that the City Council adopt
a neutral position in regards to the North County Recycling and
Energy Recovery Center. The consultants specific comments on the
EIR will be transmitted by staff to the City of San Marcos.
For more details see the attached report dated, May 7, 1987.
FISCAL IMPACT
None.
EXHIBITS
1. Report, dated May 7, 1987
REVIEW OF THE 1987 EIR FOR
SAN MARCOS GENERAL PLAN AMENDMENTS
ZONING ORDINANCE AND MAP AMENDMENT
NCRERC CONDITIONAL USE PERMIT
Prepared for
CITY OF CARLSBAD
PLANNING DEPARTMENT
2075 LAS PALMAS DRIVE
CARLSBAD, CA 92009
Prepared by
JOHN P. LARSON
VICE PRESIDENT
R€C0N
Regional Environmental Consultants
1276 Mor- BoUbv8rd. SUI DI.go. CA 82110-3815 275-3732
RECON NUMBER R-1684
MAY 7, 1987
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TABLE OF CONTENTS
SUMMARY
1. SYNOPSIS OF THE EIR
A. PROJECT DESCRIPTION
1. Land Use Designation Changes
2. Designations, Ordinances, and Policies Related to
Solid Waste Management (El R Volume I I)
B. IMPACTS WHICH CANNOT BE MITIGATED (AFFECTING
CARLSBAD)
1. Land Use/Community Character
2. Traffic and Circulation
C. ALTERNATIVES CAPABLE OF AVOIDING THE IMPACTS
(TO CARLSBAD)
II. CONCERNS RELATED TO NCRERC
A. ENVIRONMENTAL
B. PUBLIC HEALTH
C. ECONOMIC EFFECTS
111. SPECIFIC QUESTIONS OR ISSUES REGARDING THE EIR
A. VOLUME I
B. VOLUME II
C. APPENDIX D TO VOLUME II
IV. ISSUES FROM SUPPLEMENTARY MATERIAL
Paqe
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2
3
3
3
4
6
6
7
9
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SUMMARY
This report reviews the City of San Marcos Environmental Impact Report
03-85 dealing with a variety of General Plan and other amendments. The
purpose of these amendments is to update several community plans and
provide for solid waste management facilities, including the North County
Recycling and Energy Recovery Center (NCRERC)
The major findings and recommendations of this review are as follows:
THE EIR:
1. The EIR is legally adequate. Revisions which would be antici-
pated for the final EIR are not likely to change the conclusions
of the report.
MOST SIGNIFICANT ISSUES:
2. The most significant issues concerning the City of Carlsbad are
land use and traffic, both of which result from proposed land use
changes, not from the NCRERC project.
3. The City of Carlsbad should support adoption of either Alter-
native 2 or 3 (lower density alternatives) as identified in
Volume I of the EIR or request a better statement of development
criteria and dwelling unit limits to be applied in the Specific
Plan Area to be designated in the Questhaven/La Costa Meadows
community.
CONCERNS RELATED TO NCRERC:
4. Intense citizen opposition to this trash-to-energy project
focuses on air pollution, public health, and economics.
5. Review and 'regulation by the Air Pollution Control District, Air
Resources Board, Environmental Protection Agency, State Depart-
ment of Health Services, County of San Diego, and City of San
Marcos addressed these issues. Work currently under way on a
new health risk assessment is not likely to change previous
conclusions.
6. Several Questions and comments have been made which should
necessitate specific revisions or clarification in the final EIR.
This information may be useful to concerned citizens but does ap t
warrant a formal position for or aqainst the NCRERC project by
the City of Carlsbad.
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I. SYNOPSIS OF THE EIR
A. PROJECT DESCRIPTION
1. Land Use Designation Chanqes (EIR Volume I)
In the Questhaven/La Costa Meadows community planning area,
the major changes in land use designations proposed are:
Current Proposed
Acres in Rural Residential
or Estate Residential 2,300 380
Acres in SPA (max. 2.15 du/ac) 0 1,500
Acres in SPA-LU 0 427
Potential dwelling units 3,468-6,271 3,456-3,853
The intent of the above changes is to promote clustering of
development over the less steep portions of the hillsides in this
community, preserving larger areas in open space. These changes are not
related to the trash-to-energy project.
Other changes in this community involve reductions in areas
of medium and higher density residential and the addition of 70 acres of
industrial designation. These other changes would have little or no
effect on the City of Carlsbad.
Similar changes in land use designations are proposed in other communities within San Marcos. These other changes are not likely
to affect the City of Carlsbad.
2. Desiqnations, Ordinances. and Policies Related to Solid Waste Management (EIR Vdume II)
A variety of actions are proposed to regulate uses associated
with the San Marcos Landfill. These are intended to avoid adverse
impacts at the landfill site and to minimize the potential for conflicts
as adjacent land to the north and northeast develops. Other than limit-
ing the site to a single trash-to-energy plant, these changes do not
directly involve the NCRERC project. The NCRERC project would be
regulated through a new Conditional Use Permit to be issued by the City
of San Marcos, the Authority to Construct which has already been issued
by the APCD, the contract with the County which is being renegotiated,
and other applicable laws.
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B. IMPACTS WHICH CANNOT BE MITIGATED (AFFECTING CARLSBAD)
1. -- Land UsedCormunfty Character
In those portions of the QuesthavenlLa Costa Meadows SPA where
residential clustering would occur, significant adverse impacts
to community character would occur'@ (EIR Volume I, page XXI).
The EIR further states, '@The proposed project would not
-result in adverse impacts to land use compatibility along the shared
border of the City of Carlsbad and the QuesthavenlLa Costa Meadows
Community@@ (EIR Volume I , page 84) + This latter conclusion is based only
on the uses immediately adjacent to Rancho Santa Fe Road, without consid-
eration of the broader views and aesthetics in the nearby residential
neighborhoods of Carlsbad.
2. Traffic and Circulation
Buildout in accordance with the proposed land use desig-
nations will result in a level of service (LOS) E on Rancho Santa Fe Road
(projected 58,000 average daily traffic (ADT) on a prime arterial, LOS C
would be 42,000 ADT, EIR Volume I, pages 154-156). Most of the growth in
traffic would be related to the land use changes, not the trash-to-energy
plant which would only generate a net increase of a few hundred daily
trips (EIR Volume II, pages V-98.99).
C. ALTERNATIVES CAPABLE OF AVOIDING THE IMPACTS (TO
CARLSBADI
Adoption of either Alternative 2 or 3, described in Volume I,
would avoid or greatly reduce impacts on land use and traffic. Alter-
native 2 (Lower Density, 1,053-3,126 dwelling units, EIR Volume I, page
39) would apparently more closely match the assumptions used in the
traffic forecast of buildout under the existing designations (44,000 ADT
on Rancho Santa Fe Road, EIR Volume I, page 167). Alternative 3 would
place low density residential densities over all vacant land in the
Questhaven/La Costa Meadows community (283-837 dwelling units, EIR
Volume I, page 54) and have even less effects on land use and traffic.
Either of these alternatives could include the solid waste
management programs and the trash-to-energy project.
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1
II. CONCERNS RELATED TO NCRERC
A. ENVIRONMENTAL
The fundamental question related to this or any trash-to-energy
project is whether or not its adverse environmental effects are worse
than those of continued use of landfills. For trash-to-energy projects,
their worst environmental effect is on air quality.
Unfortunately, it appears that the decisions relating to land-
fills and trash-to-energy are based on which has the least opposition
rather than on which has the least environmental. costs. Strong public
opposition to the siting of new landfills has made their development very
difficult for the County. Consequently, a very real and very extreme
shortage of landfill capacity is expected within a few years. The only
alternative which can consume a significant volume of solid waste is
incineration, or trash-to-energy processing. Recycling, another neces-
sary component of the overall waste strategy, is only capable of elimi-
nating perhaps 15 to 20 percent of the solid waste volume by itself.
It is possible that ' the overall environmental effects of trash-
to-energy processing are less damaging than comparable landfilling. The
EIR (Appendix D to Volume 11, page 5-2 ff.) presented a reasonable
discussion of various landfill alternatives and concluded they were not
feasible without analyzing their environmental effects in detail. This
discussion could not, however, address the more fundamental issue of
landfilling vs. incineration.
The consideration of trash-to-energy as a realistic alternative
to landfilling has been the subject of federal, state, and local legis-
lation dating back to 1965, which is summarized in the EIR (Appendix D to
Volume 11, page 3-4 ff.). The County of San Diego acts as both the
regional Solid Waste Management Agency and the Air Pollution Control
Board. In considering the conflicting goals of disposing solid waste and
preserving air quality, the County has decided to promote trash-to-energy
technology at least on an initial scale at San Marcos (and in the SANDER
project in the City of San Diego). There was no organized opposition to
adoption of the original policies leading up to this decision, only to
specific trash-to-energy projects which have been proposed.
Thus, for the present time the policies favor proceeding with
trash-to-energy processing as a means to relieve demand for landfills.
The basic air quality question remains, however: Given the fact that the
San Diego Air Basin is a nonattainment area for some pollutants (par-
ticulates and ozone), is it acceptable to introduce any new major source
of air emissions if alternatives are available?
6. PUBLIC HEALTH
While formal health risk assessments have been prepared since at
least 1974, they have only recently been done for trash-to-energy plants.
Because of their reliance on data which has a very high degree of
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uncertainty, they are susceptible to very strong criticism. The 1984
health risk assessment for the NCRERC project had some serious flaws--the
most significant of which was that it considered inhalation as the sole
exposure pathway for carcinogenic or toxic substances. That report,
however, was one of the earlier studies done for trash-to-energy plants
and it was prepared voluntarily by the applicant, not in response to any
regulations.
A new health risk assessment is being prepared that will presum-
.ably be more thorough and up to date. A question is raised in this
review about the propriety of finalizing the EIR and committing to the
NCRERC project without having the benefit of this new study. While the question may be valid, the results of the new health risk assessment are
not likely to alter the conclusions reached in the original approval of
the NCRERC project for two reasons:
1. It is not likely that the new health risk assessment will
conclude the NCRERC project poses a significant health risk,
since no such recent assessment for a trash-to-energy plant
has done so. The increased cancer risk is likely to be in
the range of a few per million. Such an increase is
indistinguishable from the uncertainty in the cancer rate
attending modern life in a metropolitan area, which is 100-
1,000 times greater. The important function of the health
risk assessment will be to identify any unique aspects of the
project emissions or exposures which may be controlled to
further protect public health--its use in aiding risk
management .
2. The City of San Marcos must still approve the Conditional Use
Permit for the NCRERC project. If any additional restric-
tions are identified which would further protect public
health, they will be included within the CUP.
C. ECONOMIC EFFECTS
Benefits to the County would accrue from electricity and recycled
material revenues, to the City of San Marcos from property tax increment
and various fees, and to districts through taxes and/or service fees
(Appendix D to Volume 11, pages 6.2-15 ff.). Revenue to the operator
would come from tipping fees. The original source of the above monies
would be the ultimate purchasers of the waste disposal service--the
public.
Leaving aside the question of recyclable materials market and
future energy values, a major uncertainty remains in identifying the
economic value to the County. The question of disposal costs for residue
materials appears not to have been addressed in the economic analysis.
The original contract between the county and NCRRA stipulated that the
contractor would bear these costs, while the County would make a disposal
site available. Regardless of which entity bears this cost, it would
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increase greatly in the event that combined ash material from the facil-
ity becomes defined as a hazardous material, requiring special disposal
procedures. The ultimate bearers of this cost would again be the public.
A very legitimate question can be raised regarding the sense of proceed-
ing with the project before this major potential cost increase is
resolved.
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111. SPECIFIC QUESTIONS OR ISSUES REGARDING THE EIR
The following comments are generally ordered by the page numbers
within Volume I and Volume II of the EIR. Appendix D to Volume 11, which
is a reprint of the original 1984 EIR for the NCRERC project, was also
reviewed. Comments which warrant a specific response are noted in bold
type.
A. VOLUME I
The major questions, regarding land use and traffic impacts and
their reduction through implementation of project alternatives, were
noted above.
The General Summary of Impacts and Mitigation (p. XXVIII) states:
Buildout of the eight community plans comprising the City's Land
Use Element in conjunction with all other past, present, and
reasonable foreseeable future projects, will significantly impact
the City's Circulation System.
' On the same page, under the heading "Level of Significance After
Mitigation," the General Summary states:
The proposed [project] would incrementally contribute to a
significantly cumulative adverse impact.
This conclusion is consistent with the statement in Volume I1
(page 11-3) under the heading "Unavoidable Adverse Impacts":
6. TransportationICirculation - Construction and operation
traffic from the solid waste management facilities permitted by
the "SWM" General Plan designation will result in a significant,
unavoidable cumulative impact to Rancho Santa Fe Road. It is
anticipated that even with planned road improvements, this
roadway will operate at LOS "E" by the late 1990s.
The text of Volume I, however (on page 1741, states under the
heading "6. Level of Significance after Mitigation: Proposed Project":
Implementation of the above mitigation measures will reduce
potential adverse impacts to a level of insignificance.
Two revisions should be made in Volume I to clarify the issue of
traffic and provide greater amsistency: (1) the General Summary (page
XXVl 11) should specifically identify the cumulative impact on Rancho
Santa Fe Road and (2) the text (page 174) should be revised to identify that even with the mitigation measures proposed, there will still be a
significant cumulative impact on Rancho Santa Fe Road.
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B. VOLUME I1
The Summary of Volume I1 (page 11-5) contains a listing of
purported "beneficial impactsll which may be paraphrased as follows:
1.
2.
3.
4.
5.
6.
7.
Land Use. Delay the costs and impacts of siting a new
landfill, prevent gas migration off the landfill site, set
new standards for solid waste facilities, and limit land use
conflicts .
Water Resources. Remove CO2 from the landfill, reducing the
potential for the creation of carbonic acid.
Bioloqy. Promote clustering to preserve open space and
sensitive habitats.
Visual Resources, Promote clustering to reduce the potential
for future grading.
Health and Safety. Reduce the potential for disposal of
hazardous / toxic materials at the San Marcos Landfill and
create a buffer area to limit potential health and safety
impacts.
Public Services/Utilities. Utilize reclaimed wastewater from
the San Marcos County Water District Meadowlark treatment
plant, produce electricity for sale, and reduce electricity
consumption through me tal recycling .
Socioeconomics. -- Delay costs in developing new landfill and
increased revenues through tax increments, leases, and
royal ties.
If it is necessary to recite any benefits from the project, the
dlscusslon of "benefits" should be revised to reflect clearer thinking.
Specific points to consider in forming this revision are thus:
1.
2.
3,
6.
Costs associated with the need to establish a new landfill
will clearly not be delayed if the NCRERC does not begin
operation until the present landfill closes.
The beneficial effect of removing CO2, and carbonic acid,
from groundwater via landfill gas extraction is very ques-
tionable, or at least not documented.
4, and 5. Several "benefits" may occur from other General
Plan Amendment or policy actions; they are not part of the
solid waste aspects of the project and some, related to
biology and aesthetics, would be better defined in Volume 1.
The use of potential reclaimed water should certainly be
explored, as it has been for several projects in the past.
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Until the cost of reclaimed water is more competitive with
imported water, however, it is likely that this "benefit"
will not occur.
7. As noted earlier, the economic tlbenefitsl' depend on one's
point of view and may be problematic.
Table 111-1 (Volume II, page 111-11) presents a summary compari-
son of the original 1984 NCRERC project with the current project design.
.This table indicates that the original plan for two processing lines each
handling 100 tons/day would be replaced with three lines at 70 tons/day
each . Corresponding increases in the related materials and energy
outputs are reflected in the table. The number of employees, however,
more than doubles from 75 to 160 persons. Either the figures should be
corrected or perhaps more explanation regarding what the employees would
be doing can be provided.
The text of the project description states (page 111-14):
Uses [in the SPA-LU designation] that are not specifically listed
as l'compatiblelt or ''incompatible" [with solid waste facilities]
may be considered by the City pending a review of the proposed
use and its potential impact on solid waste management facilities
as well as its compatibility with other existing uses and land
use requirements.
The findings necessary to approve uses in the SPA-LU area, cited on the
same page, include:
1. Criteria to protect the proposed use from the impacts of
sol id waste facilities ,
2. Disclosure of the proximity and nature of the solid waste
activities, and
3. Compatibility with continued operation of the solid waste
faci I i t ies .
An additional finding regarding annpatbility with other adjacent land
uses should be added to the list to make it consistent with the discus-
sion in the previous paragraph.
Page V-20 makes reference to a possible land use impact from ex-
pansion of the San Marcos Landfill. Elsewhere, it appears that landfill
expansion is clearly not part of the project. In the Alternatives dis-
cussion of this matter (Figure IX-1 , page IX-15) , the "North Expansion"
would be into the area proposed for designation as SPA-LU by the project.
It is understood that there is a difference between the City of San
Marcos land use jurisdiction and the County operation of the landfill. A
careful revlew, and minor revisions to the EIR, would help eliminate the
occasional confusion between the two.
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To mitigate potential recreation impacts, item 13 on page V-34
(repeated on page V-141) states:
To offset the indirect impact of postponing the potential devel-
opment of a park facility at the San Marcos landfill, applicants
for solid waste management projects that would result in a park
facility development delay should be conditioned to contribute
funds or property to be used for park development elsewhere in
the Questhaven/La Costa Meadows Community; the amount of any
. contribution or the appropriateness of any property dedication
shall be approved by the City Council.
For purposes of clarity, a brief discussion should be provided regarding
the park mitigation specifily associated with the NCRERC project
and the status of pak planning for the Questhaven/La Costa Meadows
community.
Either under Water Resources (page V-42 ff.) or Air Quality (page
V-78 ff.) , some reference should be made to potential degradation of
surface waters through deposition of particulate air emissions. While
not necessarily significant, this effect should at least be identified,
if not quantified.
In the impacts discussion for Resource Recovery (page V-79 ff.) ,
the unstated assumption is that since the plant will conform with APCD
emission standards, no significant impact will occur. The Authority to
Construct was issued for the plant prior to the preparation of this new
EIR and included Best Available Control Technology (BACT) for the control
of certain pollutants. Since issuing the Authority to Construct, how-
ever, the APCD has subsequently determined (for the SANDER project) that
BACT for control of nitrogen oxides includes techniques not proposed for
the NCRERC (use of ammonia injection, or "thermal de-NOX") . The question
may be raised, then, whether or not the NCRERC project provides controls
to meet current standards and whether impacts from potential nitrogen
oxide emissions would be adequately mitigated.
C. - APPENDIX - - ---- 0 TO VOLUME II (contains Volume V, Final EIR for
NCRERC, October 1984)
The major questions that may be raised regarding the original
EIR which have relevance at the present time all relate to the analysis
of air quality and public health impacts. This analysis is presented in
the original EIR (page 6.6-1 ff.), Appendix C to the original EIR (which
was not available for this review but is presumably accurately summarized
in the EIR), and the separate report "Risk Assessment for Trace Element
and Organic Emissions." The first two of the following questions are
from contemporaneous reviews of the health risk assessment and do not
appear to have been resolved yet:
1. The health risk assessment fails to consider exposure
pathways other than inhalation, some of which may be very
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significant. This question was raised in reviews by both the
Center for the Biology of Natural Systems and the Environ-
mental Defense Fund.
2. The estimate of toxic equivalents for total emissions of
polychlorinated dibenzo-dioxins and dibenzofurans depends on
an unconfirmed and hypothetical distribution of the congeners
of these compounds. While the overall technique of calcu-
lating toxic equivalencies may be acceptable, this aspect of
the data used appears to be inconsistent with subsequent work
(Czuczwa, J. M., and Ronald A. Hites, Airborne Dioxins and
Dibenzofurans: Sources and Fates, Environmental Science and
Technoloqy 20(2) 1
Presumably, these objections will be resolved in the updated
health risk assessment that is currently being prepared--which raises a
third major issue:
3. Since the results of the health risk assessment are an
integral part of the EIR, or at least an integral part of the
decision-making process, the EIR should not be finalized
prior to completion of the new health risk assessment. The
health risk assessment should also be subject to the same
type of review as the EIR itself.
4. A final question involves what appears to be a major discre-
pancy in the emission results presented in the EIR (Table
6.6-16, on page 6.6-34) compared with those in the health
risk assessment (Table 1.3-5, on page 11). The tabulation
below summarizes these results, which should be identical--or
at least similar--since they are supposedly based on the same
project using the same modeling techniques. The stated
acceptable ambient concentrations from both sources also
vary, but not as dramatically. The discrepancies in the
above projections should be resolved.
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COMPARISON OF TRACE METAL CONCENTRATION PREDICTIONS
IN EIR VS. HEALTH RISK ASSESSMENT
Maximum Concentration (ugl m3)
Draft EIR HRA Ratio
Sub stance Avg. Time (5 184) (6184) EIR/HRA
. AS Annual 2.4E-4 9.62E-6 24.9
Sb Annual 3.3E-3 1 15E-4 28.7
Be 24 hr 3.8E-4 2.7E-6 140.7
Cd Annual 2.2E-3 7 14E-5 30.8
Cr 1 hr 8.8E-2 1 0353 85.4
Annual 6.6E-4 9.52E-6 69.3 cu 1 hr 3.1E-1 1.11E-2 27.9
Annual 2.3E-3 1.05E-4 21.9
Mn 1 hr 1.6E-1 1.98E-2 8.1
Hg Annual 7.5E-3 5.31E-4 14.1
Ni Annual 3.9E-4 9.98E-7 390.8 Sn . Annual 1 1E-2 9.62E-5 114.3
Va Annual 8.1E-5 4.22E-6 19.2
Zn 1 hr 1.64E1 2.73E-1 60.1
30 day 9.2E-6 6.OE-7 15.3
24 hr 2.2EO 4.46E-2 4
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IV. ISSUES FROM SUPPLEMENTARY MATERIAL
The following information is summarized from a variety of sources, as
indicated in the headings. Since most of these reports and letters were
prepared independently of the EIR, their review does not always directly
relate to the purpose of this report.
Some of the points noted below have been incorporated into the EIR
review. The remaining are presented for information purposes.
A. MARCH 24, 1987 LETTER FROM TOM ERWIN TO THE -- CARLSBAD-CiTY COUNCIL
This letter questions the logic of building the NCREKC project at
the chosen location, with the capacity limited to 364,000 tons/year by
APCD, and to produce electricity at an excessive cost. It asks a series
of questions regarding the relative tipping fees at landfills vs. the
trash-to-energy plant. It questions the lack of on-site weather data and
seeks the results of the air dispersion modeling for a variety of emis-
sions over Carlsbad and their accompanying health effects. Two questions
are asked regarding heavy-truck traffic on the future Melrose Avenue and
other streets within Carlsbad. Finally, it questions the number of other
possible polluting and toxic-producing facilities which may be allowed in
the new designations proposed by San Marcos.
Most of these questions are answered in the various volumes of
the EIR and accompanying technical reports. Data on the tipping fees
were not presented in any of the reports.
6. APRIL 20. 1987 MEETING
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Attending the meeting were George Boase, Jonathan Wiltshire,
Bruce Hamilton, and Frank Odd0 representing the North County Concerned
Citizens, Inc., and Citizens for Healthy Air in San Marcos. Mike Howes
from the City of Carlsbad and John Larson from RECON attended. A variety
of questions were raised dealing with the health risk assessment, air
quality analysis, traffic, project description and approval process, land
use, and other issues.
Many issues raised in this meeting have been reflected in the EIR
review. These groups expressed no concern regarding the land use issues
other than those associated with the NCRERC project.
C. REVIEWS - OF RISK ASSESSMENT
These reports, prepared by the Center for the Biology of Natural
Systems (CBNS) and the Environmental Defense Fund, raised several
questions regarding the risk assessment. The most important of these
have been mentioned in this report.
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D, AIR POLLUTION REGULATORY ANALYSIS
Thls undated document was apparently a portion of a review of the
original draft EIR, prepared by Radian Corporation. Presumably, these
comments were incorporated as appropriate in the final EIR
E, MISCELLANEOUS NEWSPAPER ARTICLES
Two opinion pieces arguing against trash-to-energy facilities
.were reviewed.
F. RECYCLING REPORTS I
Under a letter dated March 18, 1987, from George W. Boase to the
City of Carlsbad, a report by North County Concerned Citizens, Inc.,
dealing with recycling was submitted. This report provides an analysis
of recycling and its ability to reduce landfilled waste and attempts to
outline a program which would reduce the volume of waste as much as the
proposed NCRERC project would. This goal would require that the 60% of
the waste stream which is potentially recyclable be recovered with over
80% efficiency. Such a goal is quite optimistic and would be beyond most
projections which have been made in this area.
Included within this submittal was a CBNS report promoting a
trash separation and recycling system for the town of East Hampton, New
York
G. ENVIRONMENTAL DEFENSE FUND PRESS -- RELEASE, MARCH 12, 1987
This press release summarizes recent measurements of lead and
cadmium in fly ash and combined fly ash/bottom ash from municipal waste
incinerators. Because some of the samples exceeded concentrations
allowed in a specified EPA extraction procedure, EDF contends that fly
ash and combined ash should be defined as hazardous materials subject to
the 1984 Hazardous Waste Amendments to the Resource Conservation and
Recovery Act.
At the present time, the state Department of Health Services'
(DOHS) most recent determination is that combined ash from incinerators
is not a hazardous material. This determination could change, however,
pending further tests. The implications for projects such as NCRERC
involve disposal costs for the ash residue. Under the present DOHS
determination, combined ash may be buried at a local municipal landfill.
If determined to be hazardous, however, it would have to be hauled to a
hazardous waste landfill at a much greater cost.
13
H. ADDITIONAL INFORMATION PROVIDED BY NORTH COUNTY
CONCERNED CITIZENS, INC-, ON APRIL 27, 1987
1. February 24, 1987 letter from R. J. Somrnerville to Barney B arnett
The Air Pollution Control District has no authority to
require a revised risk assessment or to withdraw approval of the Author-
ity to Construct. NCRAA is doing a revised risk assessment; APCD has
.agreed to review it and will request the participation of the state Air
Resources Board and Department of Health Services.
2. Comments/ Questions on the NCRRA Trash-to-Energy Plant Risk
Study
This undated and unsigned study reviewed the 1984 health risk
assessment. It raised several questions, the most serious of which have
been noted in the review above. In addition, it also noted the great
uncertainty in this type of study, the fact that criteria pollutants
(those which have ambient air quality standards) are not addressed in
this type of risk assessment and that synergistic effects are not consid-
ered. It noted further that a more reasonable comparison of risk might
be with nuclear power or a similar technology rather than with accidents.
3. Data Base of Dioxin and - Furan Emissions from Municipal Refuse
Incinerators
This reference provides an excellent compilation of measured
emissions, generally citing references published since the 1984 health
risk assessment.
4. 1985 Amended and Restated Agreement to Provide a Waste-to-
Enerqy Sekice on the County Landfill at San Marcos
The original contract between the County and the NCRAA was
only briefly reviewed. It did stipulate that the contractor was respon-
sible for costs of ash disposal. The citizens indicated in the April 20
meeting that the amended contract currently being negotiated would shift
that cost to the county.
I. EVALUATION OF THE NORTH COUNTY RECYCLING AND
ENERGY RECOVERY-ZENTER -e- APPLICATIOK-
This report, prepared by APCD in October 1984, sets forth the
Authority to Construct and its conditions on the project. While there are a variety of conditions which might be altered if the permit were to
be issued today, for the most part they would only serve to make the
conditions more understandable. Recent contact with APCD confirms that
the Authority to Construct was approved in 1985 through their hearing
process, with the conditions as stated in the October 1984 report. The
Authority to Construct is valid for a period of five years, during which
suitable progress towards vesting the permit must be demonstrated.
14
CARLSBAD CITY COUNCIL
Meeting - May 19, 1987
, North County Concerned Citizens requests that the City of Carlsbad
take the following actions:
1. Advise the County that a new landfill site determination
must be expedited and not delayed by the NCRRA project.
2. Advise the County that your city will support a mandatory
curbside recycling program.
3. Reaffirm your position that you are opposed to incineration
as the first alternative to reducing the waste stream.
4. Mitigate for a share of San Marcos road maintenance
allocation if the plant is built.
5. Mitigate for a park in the La Costa/Questhaven area to
replace the park promised to be built on the San Marcos landfill when
full.
6. Advise San Marcos that the following should be complete
before approving the EIR:
(a) Complete a new risk study which includes La Costa;
(b) Finalize the decision on the closing date and/or
expansion of the San Marcos landfill.
(c) Finalize the disposition of the ash.
.
Table 4.1-1. Composition of selected sornplcs of waste received at
the City of Sori Dicgo's Mirarnar landfill in 1981
(percent by weight).
,
'I
Waste Category Percent Composition !
Newspaper
Corrugnted Paper
Other Paper
Plastic
Ynrd Waste
0 ther Combustibles
Tot a1 Corn bus tibles
Ferrous Metal
A lu m i num
Ghss
Other Noncombustibles '
Total N oncornbus tibles
Total
T7 006/2-2-84
I
/
6.36
9.03
25.07
7.37
19.61 *.
18.10
5.01
1 :od
6.51
1.94
!
I
I!
,1
85.54 '.
I
I
14.46 '
,
100.00
I
i ,
I I
I
I j
I
!
I i
1
r
Source: Trinklein, 1982.
_c ..-
I
t
i
I jP
-. i
I
I
v5.L. G du. 3 J
Paper
To produce one ton of paper
packaging requires: 3,688 pounds of
wood, 216 pounds of lime, 360
pounds of salt cake, 76 pounds of
soda ash, 24,000 gallons of water,
28 million BTUs of energy.
Pollutants include: 84 pounds of
air pollutants, 36 pounds of water ,
pollutants, 176 pounds of solid
wastes.
Recycling of paper (rather than
producing new paper): can reduce
water use by 60 percent, energy use by 70 percent, pollutants by 50
percent.
Glass
To produce one ton of glass
requires: 1,330 pounds of sand, 433
pounds of soda ash, 433 pounds of
limestone, 15 1 pounds of feldspar,
15.2 million BTUs of energy.
Pollutants generated include: 384
pounds of mining wastes, 27.8
pounds of air pollutants.
The use of 50 percent recycled
glass in the manufacturing process:
can reduce water consumption by 50 percent, mining wastes by 79 percent and air pollution by 14
percent.
Aluminum
To produce one ton of alumi-
num requires: 8,766 pounds of
bauxite, 1,020 pounds of petroleum
coke, 966 pounds of soda ash, 327
pounds of pitch, 238 pounds of
lime, 197 million BTUs of energy.
Pollutants generated include:
3,290 pounds of red mud, 2900
pounds of carbon dioxide, 81
pounds of air pollutants, 789
pounds of solid wastes.
Recycling of aluminum (rather
than new production): can reduce
energy use by 95 percent with simi-
lar reductions in water and air
pollution.
Steel To produce one ton of steel
requires: 1970 pounds of iron ore,
791 pounds of coke, 454 pounds of
lime, 29 million BTUs of energy.
Pollutants produced include: 538
pounds of solid wastes, 242 pounds of air pollutants.
Recycling of steel: can reduce
energy consumption by 70 percent
with similar reductions in solid
waste, and air and water pollution.
I- I
. ,-
Selling The Public
on Cornposted Sludge
“You’ve got to promote and educate. People aren’t stupid. They can be shown we have
a serious waste problem that we can’t solve by digging holes in the ground.”
>.HEN you walk into the headquar- w ters of the Southwesterly Com-
posting Facility south of Columbus,
Ohio, the first thing you notice on your
way to Duane Goodridge’s office is a toi-
let commode sitting unabashedly and all
alone on the floor-with a fern growing
out of it. It’s a tipoff to the reason for tlic
grqwing success of a sludge-handling sys-
tem that not so long ago seemed to have
less chance of survival than a woodchip in
a 500-ton stack of cornposting sludge.
“Public awareness,” says Goodridge,
leaning back in his chair under the Bronze
Star on the wall he received for military
service in Vietnam. “You’ve got to pro-
mote and educate. People aren’t stupid.
They can be shown that we have a serious
waste problem in this country that we
can’t go on solving just by digging holes
in the ground and burying it. Columbus
produces 500 tons of sludge a day and
you must put it someplace. When you can
show the public this waste is a possible
resource, they start listening. But you
have to get their attention first. That’s
what that potted plant out in the entrance-
way is for.” One of the slickest details in Columbus’
promotional efforts stands right there at
plant headquarters-a tower from which
visitors (and they are coming from all
over the world) can survey the huge piles
of steaming sludge standing on several
acres of concretc pad. Goodridgc can
show them, with a sweep of his arm, how
the plant operates.
“The trucks bringing in sludge from
the wastewater plant put1 in and wcigti on
the scales right down them,” he bcgins
his description. “Then you can watch
them drive to the far cnd, and dump.
Then the sludge is niixcd with wood-
chips-4’h parts chips to I pafl,\ludge.
See those front end loaders bringing the
chips? The slutlgc is then pilcd in stacks
and covcrcd with a blanket of conipostcd
sludge from the finishing piles. You can
GENE LOGSDON
see those front cnd loadcrs doing that.
Eventu;illy convcyor belts will spccd up
this pn~ccss treiiicntlously.
“The compost blankets over thc piles
hclp control odor. After those stacks com-
post for 2 1-28 chys, they arc moved over
to the other side and rcstiickcd or biriricd
in that building for 30 more days. The fin-
ishcd compost is then scrccncd and
b;iggcd or niovcd out in hulk. SCC that fcl-
low down lhcrc with his pickup? tlc’s
getting a load of the finished product,
Com-Til. ’’
Goodridge finishcs his “tour” then re-
niarks. “Not oiily is it easier to get a
quick grasp of the business, but it saves
AioCycle 52
%=
walhg IiiiII:i iiiilc itrott1itI tIic pIiicc.”
* Prnhlotiis tliiit h;ivc pliijye(l thr 1;icility
an: visildr l’to~ii tlic 1owt.r IO, ‘I IIC Iiiiyc
conveyor I~lt systciii, which cvcii~tiiilly
will do away with the slow and incfficicnt
movement of sliitlgc with front end 1o:id-
ers, still h:ivc iiiecli:inic:il hugs thiit hvc
not becri workcd out. ’rhc solar heating
and drying system, much touted thrcc
years ago, is still untlcrgoiiig “design
modifications,” an cnginccring cuphc-
mism that usually translates into trouble.
Even if the problems arc ironed out,
there‘s good reason to suspect that thc so-
lar panels will not be fully implemcntcd
year-round. “We’ve got only the equiva-
lent of 66 sun days in Columbus,” says
Goodridge, in the only moment all day
when he was not brimming with ebul-
lience and optimism.
‘
for Duane Goodridge. Just think of it as
:in act of civic pridc.”
But David Yost, staff writer for the Cili-
-
‘Total Concept Recycling”
A iicw itlc;i 11i;it siivt~ iiiciii(.y ;iiiiI iii
voIv(*s tlir 1)iiI)lic is it’( yt litijt, (‘liii\~ii)m
trccs. “Wc piiy out iihiiit :I 11;111 rilillioii
tlollars for 25.000 tons of woodchips a
ycar,” says Gootlritlgc. “Whcn ~icoplc
don;itc tlicit ol(l Clitisttiiiis IKC, thilt S;IVCS
011 chips ;iritl it iilso cuts costs at tlic rclusc
collection stations and ;it thc trash lwrn-
ing pl;iiit. We ligurc $S per ttcc s;ivctl.”
Goodridgc calls it “total concept rccy-
cling,” and at the heart of it is a vcry
practical attack on waste: Dorr ’f depcrrd
rotnliy oti my otic systortI to hrrrr(lle il. Co-
lumbus incineratcs, has a vigorous land
application program and thc compost fa-
cility in addition to hands-on scparation
and recycling programs. '!After we expc-
rienced incinerator breakdowns, we knew
V‘ ’’ ‘. -- s I .* u: - -y‘c
wc had to have :I prcssurc viilvc to rclcase
sliidgc to in ciiicrgcncics. Now we coiii-
post alwul 20 to 30 pcrcciit of tlic daily lian supply. chiefly hccauw of the 1;irgc iiiounts thc Ohio Division of Natural Rc-,
ou~cs is buying to reclaim stripminc
<ind in southcrn Ohio. “Thcy’rc waiting
or 8,000 yards right now,” says Good-
flow from southwc\tc;ly WWTP iind with
our expansion, we can tnkc more whcn
and if ncccsvry.
“Without hiiht, fiicl price\ arc going
to go back up. Landfills arcn’t thc an-
Maintaining Quality Control I1
No‘t everyone in Colunihus has coiiic to
love sludge. People inimcdiatcly down-
wind, for example. Or pcoplc in Jackson
Township in gcncral who fclt-and sonic
still do-tliat thcy wcrc being dumped on.
The facility has been sued once, the case settled in favor of compost.
“We have a vigorous Odor Control
Board which meets regularly and con-
siders all complaints scriously,” says
Goodridgc. “Our policy is that if pcople
say thcy srncll odors that are offcnsive,
thcn they do. We don’t shrug off com-
plaints. Wc invcstigatc. Thcrc are numer-
ous SOIII’CCS of polcntiiil otlors-a rcn-
dering plant, plastic factories, the waste-
water treatment plant-in addition to our
compost ing facil ity.
“Wc’vc hccn cffcctivc: in kccpiiig odor
controllcd. Do you smell anything really
offensive here? With this much sludge
around, we must be doing something
right. But it’s a continuing effort. This
stuff ain’t Ivory Snow, you know.”
Has the much ado about Milorganite
and ALS causcd any repercussions in the
sale of Con-Til? “No.” says Goodridge.
“Our process is different and we are well
within stiitc stanthrtls. Coin-Til has hccn
inarkcted for Iantlscapc usc only. In othcr
words, our cadinium lcvcls arc betwcen
12.5-25 ppni. nut anyway. I bclicvc that
bit of sciis;itioiial reporting about Mil-
organitc has bccn pretty well laid to rcst.
It reminds me of the story of the airplane
crash after evcryonc on board had eaten
pickles with their meal, Soinconc dc-
tluccd picklcs caused the wreck. Wc havc
to keep scnitinizing slutlgc with thc hcst
scicntilic knowledge nvailahlc. Wc’vc got
to strive for hcttcr stiind;ir(k a11 the time.”
A (nick pulls oilt ol‘tlic Iiicilily to get
iiiiollicr loid ol‘ slutlgc. (;ootli.idgc iiotls ;it
it. “Yotl’vc hcaid ;I lot almit piivatimtioii
in the sludge business? Well, wc practice
nnti-privati7i\tioii, We took over tlic
sliitlgc hauling oursclvcs-city trucks.
city driven;. It saves us $120,000 a year,
and wc always have trucks on hand whcn
wc wi1nt thcn1.”
tie tosses a little s;iiiiplc twg of Com-
Til into this rcportcr’s lap. “Whcrc
clsc.” lic says with ii wink. “can you give
so~~icoiic n s:iiiiplc of slirdgc (riot pre-
ciscly ttic word he uscs) and thcy’ll say-
thanks?” H
I
,
!
,,’ 18
I, , ,
To: Carlsbad City Council
From: Tom Erwin 7703 Garboso P1.
Carlsbad, CA. 92009
I request that the following specific items be included in the consultants' study and review of the North County recycling and Energy Recovery Center. It is important that we ascertain what damages this Facility will do to our citizens now, and not at some later date after the
damage has been done.
1) the landfill is almost full, and at least l/3 of everything trucked in will have to be trucked back out again to another landfill?
2) What is the logic of building a Plant that, because of its location, can only burn a maximum of 364,000 tons per year, as set by the AFCD?
What is the logic of building this Plant in a location where
3) What is the logic in building this Plant to produce electricity, when it costs 2* to 3 times more to produce it than SDG&E pays
other sources for the same product?
4) What is the average tiping fee per ton in a sanitary landfill now?, in 2 years?, in five years?, in ten years?
What would be the monthly cost to each residential customer for their share of the tiping fee, for each time period?
5) What is the average tiping fee per ton in a trash burning plant now?, in 2 years?, in five years?, in ten years?
What would be the monthly cost to each residential customer for their share of the tiping fee, for each time period?
6) Why were no wind current tests conducted at the proposed site, or anywhere near the proposed site, including Carlsbad?
7) If the trash plant is constructed, what will the increase to
Carlsbads air be of the following? 1) Heavy metals 6) Hydrochloric Acid 2) Trace metals 7) Nitrogen oxides 3) Dioxins 8) Carbon Monoxide 4) Sulfur Dioxide 9) Hydrocarbons 5) Hydrofloric Acid 10) Particulates
8) What impact do each of the items listed in question #7 have on the health of the human body?
9) If the trash plant is constructed, and if Melrose is designated a truck route, what,will the increase in heavy truck traffic be on
Carlsbads' roads directly attributable to the trash plant?
page 2 of 2
10) If Melrose is designated a truck route, will the majority of trash trucks from the North county use Carlsbads' roads, or San . Marcos' s roads?
11) Does the zoning that San Marcos established to allow the trash plant to be built, also allow other possible pollution and toxic producing facilities to be built in that same area?
that would qualify to be constructed in that area, and what their impact on the citizens of Carlsbad would be?
If so, may we have a list of all other types of facilities
Sincerely, 7-m:
An Independent Agency
M. S. CWIEK AGENCY
1926 Bemardo Ave.
Escondido, CA 92025
(619) 489-1722
e,?, /316p -
July 4, 1987
Ms Marjorie Gaines
Mayor of Encinitas
535 Encinitas blvd.
Encinitas, Ca. 92024
Dear Mayor Gaines:
C-Span broadcast coverage of a hearing before a Congressional subcommittee
headed by Representative Waxman of California on the subject of trash-to-energy
plants on either July 1 or July 2. During the hearing the testimony presented
against such air polution plants was powerful.
could get a copy of the tape covering this hearing and perhaps arrange for the
correct people to watch excerpts locally. It could go a long way toward more
serious evaluation of the dangers posed by this project.
I think it would be useful if you
When the matter comes to a vote of the people of San Marcos, it would be extremely helpful if portions of that tape were broadcast on local television.
Considering the fact that air polution generated by such a plant will effect
people in the entire north county area, it seems that you could make a case for the courts to rule that the vote of only San Marcos citizens could not or should not be binding action effecting the lives of all the citizens who live within range of the polution which would be emitted by such a plant.
- Sincere 1 y,
Mitchell S. Cwiek
MSC/njc
cc: City Councils of: San Diego
Escondido
Poway Del Mar Carlsbad
Oceanside
Vista San Marcos
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