Redwood Landfill FEIR Addendum

320 Pages·2013·5.38 MB·English

REDWOOD LANDFILL COMPOST FACILITY EXPANSION
AND MATERIALS RECOVERY FACILITY PROJECT
Addendum to the 2008 Redwood Landfill
Final Environmental Impact Report

Prepared for May 2013
Marin County
Community Development Agency
REDWOOD LANDFILL COMPOST FACILITY EXPANSION
AND MATERIALS RECOVERY FACILITY PROJECT
Addendum to the 2008 Redwood Landfill
Final Environmental Impact Report

Prepared for May 2013
Marin County
Community Development Agency

350 Frank H. Ogawa Plaza
Suite 300
Oakland, CA 94612
510.839.5066
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Woodland Hills
D210666
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TABLE OF CONTENTS
Redwood Landfill Compost Facility Expansion
and Materials Recovery Facility Project:
Addendum to the 2008 Redwood Landfill
Final Environmental Impact Report
Page

1. Introduction and Project History 1-1
Project History 1-1
Environmental Review of the Proposed Project 1-3
References 1-5

2. Project Description 2-1
Project Location and Environmental Setting 2-1
Project Objectives 2-3
Project Elements 2-4
Discretionary Approvals 2-16
References 2-17

3. Environmental Checklist for Supplemental Environmental Review 3-1
Explanation of Checklist Evaluation Categories 3-1
Discussion and Mitigation Sections 3-3
1. Aesthetics 3-4
2. Agriculture 3-7
3. Air Quality 3-8
4. Biological Resources 3-20
5. Cultural Resources 3-26
6. Geology and Soils 3-27
7. Greenhouse Gas Emissions 3-29
8. Hazards and Hazardous Material 3-35
9. Hydrology and Water Quality 3-38
10. Land Use and Planning 3-49
11. Mineral Resources 3-52
12. Noise 3-53
13. Population and Housing 3-57
14. Public Services 3-58
15. Recreation 3-59
16. Transportation/Traffic 3-60
17. Utilities and Service Systems 3-63
18. Mandatory Findings of Significance 3-66
Summary Findings of Checklist 3-67
References 3-69

4. Revised Mitigation Measures 4-1
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EIR Addendum May 2013
Table of Contents

Page
Appendices
A. Criteria Pollutant and GHG Emissions A-1
B. Revised Mitigation Monitoring and Reporting Program B-1
C. Draft General Waste Discharge Requirements for the Discharge of Wastes
at Compost Management Units, and Monitoring and Reporting Program
for the General Waste Discharge Requirements C-1
List of Figures
1. Project Location 2-2
2. Existing Site Plan 2-5
3. Proposed Site Plan 2-6
4. MRF Conceptual Site Plan 2-9
5. Possible Configurations for Aerated Static Pile Composting System 2-12
List of Tables
1. Proposed Changes to the 2008 Solid Waste Facility Permit 2-7
2. Existing and Proposed Waste and Traffic Limits 2-7
AQ-1 Summary of Average Daily Construction-related Pollutant Emissions
for Proposed Project 3-12
AQ-2 Operations-Related Emissions for Proposed Composting Facility Expansion
and MRF 3-14
GHG-1 Operations-related GHG Emissions 3-31
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EIR Addendum May 2013
CHAPTER 1
Introduction and Project History
Marin County is the lead agency, pursuant to the State Guidelines for the California Environmental
Quality Act (CEQA Guidelines Section 15050), for the preparation of this Addendum to the 2008
Redwood Landfill Final Environmental Impact (2008 FEIR; SCH #1991033042). The Addendum
reviews proposed changes to the approved “Mitigated Alternative,” which was analyzed in the 2008
FEIR. The changes reviewed in this Addendum are referred to as the Redwood Landfill Compost
Facility Expansion and Materials Recovery Facility Project (hereinafter, “Project”). This Addendum
has been prepared by the County of Marin in accordance with CEQA, the State of California CEQA
Guidelines, and the Marin County Environmental Impact Review Guidelines.
Project History
Beginning in the 1940s or 1950s, the site where Redwood Landfill is located was converted
from wetlands to agricultural land. To accomplish this conversion, a perimeter levee partially
surrounding the site was constructed using Bay Mud dredged from the surrounding sloughs. The
landfill originally operated pursuant to a Use Permit issued in 1958 by Marin County and a
garbage dump permit issued by the County’s Environmental Health Services (EHS). The landfill
began receiving waste in 1958, and has handled the majority of Marin County’s solid waste since
then.
Redwood Landfill also holds a quarry permit (permit #Q-76-01, originally issued in 1976) from
the Marin County Department of Public Works to quarry soil on an adjacent property for landfill
cover material. The quarry is located immediately north of the landfill access road. When needed,
cover soil is removed from the borrow area and transported by off-road trucks to the working face
of the landfill, where it is stockpiled for use as daily cover when alternative cover is not used. At
present, little quarrying occurs due to the availability of other cover materials.
Since 1978, the landfill’s operations have been governed by a Solid Waste Facility Permit
(SWFP). The facility’s first SWFP was issued by the Local Enforcement Agency (Marin County
EHS) with the concurrence of the California Waste Management Board, the predecessor of the
California Integrated Waste Management Board (CIWMB), which has since been renamed the
California Department of Resources, Recycling and Recovery (CalRecycle). In 1990, Redwood
Landfill applied to the LEA for a revised SWFP to incorporate changes that had occurred at the
facility since 1978 as well as additional proposed changes, and also to respond to regulatory
changes promulgated in the Integrated Waste Management Act of 1989 (Assembly Bill 939). An
EIR was prepared to analyze potential environmental impacts of the proposed permit revisions
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EIR Addendum May 2013
1. Introduction and Project History

(Marin County, 1994). The FEIR was certified in 1994 and a revised SWFP was issued by the
LEA, with the concurrence of the CIWMB, in 1995.
In 1999, the County EHS determined that changes that had occurred and new changes that were
being proposed at the landfill necessitated another revision to the SWFP. Environmental review
1
of the proposed revisions was completed in June 2008, when the LEA certified the FEIR. A draft
version of the revised SWFP was received by the CIWMB on November 16, 2008. On December
18, 2008, the LEA issued the SWFP, after receiving concurrence from the CIWMB on December
16, 2008. The San Francisco Bay Regional Water Quality Control Board (RWQCB) issued new
2
Waste Discharge Requirements (WDRs) for the facility in July 2009. Redwood Landfill also
operates under a federal Clean Air Act Title V permit and other permits from the Bay Area Air
Quality Management District (BAAQMD), as well as other permits.
The revised SWFP issued in 2008 permits the ‘Mitigated Alternative” that was described and
analyzed as an alternative to the proposed project that was the subject of the 2008 FEIR. The
Mitigated Alternative involves a smaller increase in total landfill capacity than Redwood Landfill
3
had originally requested as part of their proposal to expand the landfill. The approved Mitigated
Alternative does not include any increase in the maximum daily tonnage of waste accepted for
disposal each day, whereas Redwood Landfill had originally proposed an approximate doubling
of the maximum daily tonnage. The 2008 SWFP permits a much lower maximum daily tonnage
(2,310 tons per day4) than Redwood Landfill had proposed. Redwood Landfill is currently
permitted to receive the following:
 1,390 tons per day total waste for disposal;
 170 tons per day total material for composting;
 400 tons per day total material for recycling;
 350 tons per day total cover materials.
The 2008 SWFP required Redwood Landfill to shift its emphasis from landfill disposal to recovery
of energy and materials from waste. The 2008 SWFP includes conditions that direct Redwood
Landfill to develop facilities that would utilize landfill gas for electricity generation, and to develop

1 A separate project, involving construction of a new access road and bridge at the intersection of U.S. 101 and
Sanitary Landfill Road, was the subject of another EIR (Marin County, 2002), which was certified by the Marin
County Board of Supervisors in 2002. Construction of the access road and bridge were completed and became
operational in June, 2006.
2 In 2009 following certification of the FEIR and approval of the 2008 SWFP and 2009 WDRs, No Wetlands
Landfill Expansion; Sustainability, Parks, Recycling and Wildlife Legal Defense Fund (SPAWLDEF); and
Northern California Recycling Association filed suit in Marin County Superior Court seeking to reverse these
actions, to require additional environmental review, and to allow appeal of the LEA’s certification of the FEIR to
the Marin County Board of Supervisors. The case was remanded to Marin County Superior Court after a hearing
before the First District Court of Appeal in March 2012 in which the court denied Petitioners’ request for an appeal
to the Board of Supervisors. In December 2012, the Marin County Superior Court ruled that the FEIR failed to
fulfill the requirements of CEQA. That ruling is pending appeal. No Wetlands Landfill Expansion, et al. v. County
of Marin, et al. (Marin County Superior Court Case No. CV090198).
3 Under the 1995 SWFP, the permitted capacity of the landfill was 20.455 million cubic yards, including the final
landfill cover. Redwood Landfill had requested an increase to 34.77 million cubic yards, including the final cover. The
project ultimately approved includes an increase in total landfill capacity to 26.077 million cubic yards, including final
cover.
4 This figure does not include concrete, asphalt, and minimally-contaminated soil, which are used for construction
material and cover material.
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1. Introduction and Project History

a facility to recover recyclable and reusable materials from construction and demolition debris,
specifically Condition U:
The operator shall apply for additional permits needed to construct and implement a
construction and demolition material resource and recovery operation (C&D operation)
within the landfill property within two years of issuance of the SWFP and make every
effort to complete implementation within three (3) years of SWFP issuance. The C&D
operation will be regulated under a separate permit. At the time a separate permit is issued
for the C&D operation, the entitlement to receive 400 tons per day of recyclable materials
described in the SWFP will terminate, and the maximum tonnage received under this
SWFP will revert to 1,910 tons per day.
The proposed permit changes, described in Chapter 2, Project Description, make up the Project
analyzed in this Addendum, and consist of the following:
(1) Development and operation of a MRF with a capacity of 400 tons per day;
(2) Modification of the existing composting facility, including use of a different composting
method and increasing maximum daily acceptance of materials for composting from
170 tons per day to 514 tons per day; and
(3) An increase in the maximum daily number of vehicles entering the facility from
662 vehicles per day to 690 vehicles per day.
The MRF now being proposed is consistent with what was analyzed as part of the Mitigated
Alternative in the 2008 FEIR, and with Condition U of the 2008 SWFP. The increase in
composting levels being proposed is consistent with the composting levels that were analyzed in
the 2008 FEIR as part of the original proposal (which was not approved), and would serve to
accommodate increased demand for composting in the local area. Redwood Landfill is also
seeking permits from the BAAQMD to allow it to construct and operate a landfill gas-to-energy
plant, consistent with the analysis in the 2008 FEIR. Because the proposed gas plant was
analyzed in the 2008 FEIR, and no changes are proposed, it is not included as part of the changes
that make up the Project discussed in this document.
Environmental Review of the Proposed Project
The proposed Project, which is summarized above and described in detail in Chapter 2, Project
Description, requires environmental analysis under CEQA. The County has determined that an
Addendum to the 2008 FEIR is warranted. Pursuant to Section 15164 of the State CEQA
Guidelines, the Lead Agency shall prepare an Addendum to a previously certified EIR if some
changes or additions are necessary but none of the conditions described in Section 15162 calling
for preparation of a subsequent EIR have occurred. CEQA Guidelines Section 15162 lists the
following conditions, which require preparation of a subsequent or supplemental EIR:
(1) Substantial changes are proposed in the project which will require major revisions of the
previous EIR or negative declaration due to the involvement of new significant
environmental effects or a substantial increase in the severity of previously identified
significant effects;
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1. Introduction and Project History

(2) Substantial changes occur with respect to the circumstances under which the project is
undertaken which will require major revisions of the previous EIR or Negative Declaration
due to the involvement of new significant environmental effects or a substantial increase in
the severity of previously identified significant effects; or
(3) New information of substantial importance, which was not known and could not have been
known with the exercise of reasonable diligence at the time the previous EIR was certified
as complete or the Negative Declaration was adopted, shows any of the following:
(A) The project will have one or more significant effects not discussed in the previous
EIR or negative declaration;
(B) Significant effects previously examined will be substantially more severe than shown
in the previous EIR;
(C) Mitigation measures or alternatives previously found not to be feasible would in fact
be feasible, and would substantially reduce one or more significant effects of the
project, but the project proponents decline to adopt the mitigation measure or
alternative; or
(D) Mitigation measures or alternatives which are considerably different from those
analyzed in the previous EIR would substantially reduce one or more significant
effects on the environment, but the project proponents decline to adopt the mitigation
measure or alternative.
As discussed in detail in Chapter 3, Environmental Checklist, of this document, the County has
conducted a preliminary environmental review of the proposed Project and has found that the
Project would not meet any of the conditions in CEQA Guidelines Section 15162; therefore, an
Addendum is warranted, and neither a Subsequent EIR, nor a Supplemental EIR (pursuant to
CEQA Guidelines Section 15163) is required.
The Environmental Checklist evaluates the CEQA checklist categories in terms of any “changed
condition” (i.e. changed circumstances, project changes, or new information of substantial
importance) that may result in a different environmental impact significance conclusion from the
certified 2008 FEIR. As discussed in Chapter 3, the proposed changes that constitute the Project,
in combination with other changed conditions, would not result in new or substantially more
severe significant environmental effects requiring revisions to the 2008 FEIR. The continued
implementation or application of mitigation measures identified in the 2008 FEIR would be
necessary to avoid or reduce potential effects of the proposed Project. These mitigation measures
are identified, and their full, final, adopted text is provided, in Section 3, Environmental
Checklist.
Following certification of the FEIR in June, 2008, the County prepared Findings, pursuant to
CEQA Guidelines Section 15091, and approved the Mitigated Alternative. The Findings state that
several of the mitigation measures identified in the FEIR were not applicable to the Mitigated
Alternative, because the Mitigated Alternative did not involve any increase in maximum daily
disposed tonnage and only a small increase in average daily tonnage for the composting facility.
These mitigation measures were not adopted and currently are not in effect. The text of several
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EIR Addendum May 2013
1. Introduction and Project History

other mitigation measures was revised as part of approval of the Mitigated Alternative to make
the measures more easily enforceable or applicable to the Mitigated Alternative. In Chapter 3 of
this Addendum, where the continuation of previously adopted 2008 FEIR mitigation measures is
assumed or application of mitigation measures from the 2008 FEIR that were not previously
adopted for the Mitigated Alternative is found to be necessary to reduce or avoid impacts of the
current Project, the text of the applicable mitigation measures is provided. In several instances,
minor revisions are made to the text of previously adopted mitigation measures. These revisions
are for clarity, to make the measures consistent with current regulations, or to make them
applicable to the current Project. All revisions to mitigation measures are also compiled in
Chapter 4. The text of all adopted mitigation measures, with minor revisions as shown in
Chapters 3 and 4, is provided in a revised Mitigation Monitoring and Reporting Program
(MMRP), which is included as Appendix B hereto.
CEQA does not require a formal public review and comment period on an EIR Addendum.
However, the 2008 FEIR and this EIR Addendum are available for review during the hours of
8:00 am to 4:00 pm, Monday through Thursday, at the Marin County Community Development
Agency at 3501 Civic Center Drive, Room 308, San Rafael, CA 94903, and on the Community
Development Agency’s website at http://www.co.marin.ca.us/depts/CD/main/comdev/eir.cfm.
_________________________
References – Introduction and Project History
Marin County, 1994. Redwood Landfill Solid Waste Facilities Permit Expansion Project Final
Environmental Impact Report, SCH #91033042, prepared by Woodward Clyde, February
1994.
Marin County, 2002. Marin County Community Development Agency, Redwood Landfill Inc.
Interim Access Road Improvements, Final Supplemental EIR, June, 2002.
Marin County, 2008, Redwood Landfill, Final Environmental Impact Report, 2008.
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