Port of Richmond Terminal 3 Log Processing and Export Facility

Home , Golden Gate, Point Potrero, Richmond Ferry Terminal, Richmond Inner Harbor, San Pablo Reservoir

CITY OF RICHMOND, CALIFORNIA

INITIAL STUDY & MITIGATED NEGATIVE DECLARATION

APRIL 2016

California Environmental Quality Act (CEQA) Environmental Checklist Form

1. Project Title: Terminal 3 Log Processing and Export Facility (PLN15-420)

2. Lead Agency Name and Address: City of Richmond Planning and Building Services Department 450 Civic Center Plaza, Second Floor Richmond, CA 94804-1630

3. Contact Person and Phone Number: Lina Velasco, Senior Planner (510) 620-6841 [email protected]

4. Project Location: 1411 Harbour Way South Richmond, CA 94804

Assessor’s Parcel Number: 560-270-060

The project site is located on the west side of Harbour Way South, near its southern terminus, on the southern shoreline of the City of Richmond. The site is located on the east side of Harbor Channel, adjacent to the Richmond Inner Harbor on San Francisco Bay. It is approximately 3,500 feet (0.66 miles) south of Interstate 580, at the intersection of Harbour Way South and Hall Avenue.

5. Project Sponsor’s Name and Address: RJJ Resource Management Corporation 1411 Harbour Way South Richmond, CA 94804

Contact: Richard Lyu, President (510) 816-6671 [email protected]

6. General Plan Designation: Port

7. Zoning: M-4 Marine Industrial

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 1

8. Description of Project: Introduction This Initial Study has been prepared in compliance with the California Environmental Quality Act (CEQA) and the CEQA Guidelines, which are codified in Title 14, Chapter 3 of the California Code of Regulations. A recent legal ruling will alter the scope of environmental review pursuant to CEQA in comparison with how it has been practiced throughout the State in recent decades. In California Building Industry Association v. Bay Area Quality Management District (CBIA v. BAAQMD)((2015) 60 Cal.4th 1086), the California Supreme Court ruled that CEQA does not require an analysis of the existing environment's impact on a potential project, except in limited circumstances. The Court found the term "environmental effects" to mean only the impacts arising from the project's effect on the environment, and not the environment's effect on the project (sometimes referred to as a "CEQA-in-reverse" analysis).

Although this ruling limits the scope of CEQA review, the Court noted that a reverse analysis is still required in certain conditions, such as when a project could exacerbate or worsen existing environmental hazards. In addition, a lead agency has authority other than CEQA to require measures to protect public health and safety, as well as the environment. The CBIA v. BAAQMD decision notwithstanding, one of the primary functions of a CEQA document continues to be for informational purposes, to disclose environmental effects of a proposed project to the public. Accordingly, the City of Richmond is publishing this Initial Study, which includes an evaluation of the environment's impacts on a project, consistent with the current version of CEQA Guidelines Appendix G, including mitigation recommendations to reduce or avoid these impacts where feasible. The Initial Study assesses both the existing setting and the project's impacts, and thus addresses the extent to which a project could "exacerbate" an existing environmental condition that is otherwise excluded by the CBIA v. BAAQMD decision.

Project Overview RJJ International (RJJ), the project applicant, is proposing to develop and operate a log export facility at Terminal 3 of the Port of Richmond. The proposed project would be located at an already developed site at 1411 Harbour Way South that would be leased from the Port of Richmond. As shown on Figures 1 and 2, the project site is located adjacent to Harbor Channel on the City of Richmond’s southern shoreline along San Francisco Bay. RJJ will operate the log export facility jointly with J.W. Bamford, Inc., which would be responsible for managing the work crews and the day-to-day operations at the site. The proposed project would not require new construction; however, minor repairs to the existing building and facility improvements are proposed as further described in the facility improvement section below.

The proposed facility would receive harvested timber from California forests that would be prepared for shipment, then loaded onto ocean-going ships that would berth at Terminal 3. Once loading of a ship is complete, the processed logs would be exported to China. It is anticipated that no more than six shiploads of timber would be exported each year. The tree species to be exported by RJJ would include Douglas fir, white fir, ponderosa pine, sugar pine, and cedar. The trees would be harvested in accordance with an approved Timber Harvest Plan (THP). Additional information about THPs is provided below.

Terminal 3 Facilities The proposed project would be implemented at an existing facility at Terminal 3, shown on Figure 3. The approximately 12.4-acre site is enclosed by a 6-foot-high chain-link security fence topped with barbed wired. (Another 1.1 acres at the southern end of the Terminal 3 property

Initial Study 2 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY W

T I

T T

T S T L G R A T T N T A V T

S T S S S S S S T S T S S T T H S O

H S S T D

H H S T S H H D T H

T N S

1 H T T R

N T T H H R S T 6

D 1 H

1 4 8 T 3 T 2 0 A 4 T T 3 8 3 T *

1 5 N S 2 H 2 3 6 8 3 V *

T 0 3 2 T * 2 2 O 4

S 2 7 R 10A B A AR 3 T RE T TT T A T S V S S

A MAC DONALD AV S N E H C V IN D T A V T R

T S 80 9

T 3

BISSELL AV S 3 1 4

S R 4 R H

F T

6TH ST 8TH ST

1ST ST S 8

1 N W OHIO AV 1 B OHIO AV CENTER AV FLORIDA AV * * * * * MAINE AV WALL AVE * * * C

580 S 7TH ST A VIRGINIA AV R

S 2ND ST L W. CUTTING BLVD S CUTTING BLVD O N B POTRERO AVE L V D S a n t a S

F S 4TH ST P

e * WRIGHT AV T POTRERO AVE T C C S h F a O R n A n R H e R W l

PIERSON AV

HARBOR WAY S.

DR 580 C H

F MARINA WY S. F A LI N a C r V A A E L b A HALL AV S B o N L A V r N D R C O Richmond D h a Marina n

n Bay

Ford Channel PROJECT SITE r Point Potrero r H a r b o R i c h m o n d I n n e

San Pablo Bay

0 300 600 1200 PINOLE

FEET

i SITE f

i S a c n F r O a n c c i e s c a o n B a y

Figure 1

Site Location Source: Douglas Herring & Associates Maine Ave

Harbour Way

Marina Way Cutting Blvd

23rd St

580

Wright Ave RICHMOND

Harbor Channel

Marina Way Regatta Blvd

Harbour Way

PROJECT LOCATION

Inner Harbor Basin

Richmond Inner Harbor

0 1000

Feet

Figure 2

Aerial Overview of Site and Surroundings Source: Google Earth 0 200

FEET

Figure 3

Site Plan Source: BKF will be used as a parking lot serving the planned future ferry terminal at the southern end of Harbour Way South. Gated entrances to the site are located near the northern and southern ends of the site. A small guard house is located at the southern entrance, with a small three- story administration building located about 180 feet north of the guard house. A truck scale is located along the east side of the administration building.

A large one-story corrugated metal warehouse building is located along the eastern edge of the Terminal 3 site. This flat-roofed building is 800 feet long and has a floor area of approximately 88,000 square feet. A recently-installed shoreline 480-volt, three-phase power terminal is located at the edge of the ship berth. This terminal provides power to ships while they are docked at Terminal 3 so they don’t need to idle the ship engines for power. The remainder of the site consists of asphalt pavements.

Proposed Operations The proposed facility would receive logs both with and without bark. Logs without bark would arrive by truck from an RJJ site in West Sacramento. Loaded trucks would enter the facility through the northern gated entrance to Terminal 3, and would first be weighed by staff at the truck scales at the southeastern corner of the site. Trucks would then proceed to the Debarked Logs Deck area shown on Figure 3, where crews would unload the logs using a front loader, stacking them in piles not to exceed 25 feet in height. The unloaded trucks would be weighed again prior to departing from the site in order to determine the weight of the unloaded logs. It would take approximately 15 minutes to unload each truck. Logs would remain stockpiled in this area until ready for shipment; they would generally be stockpiled for no longer than one month.

Logs arriving with bark still on would also be weighed upon arrival at Terminal 3. They would then be unloaded by a front loader equipped with claws and stacked at the Log Layout Area shown on Figure 3. When sufficient logs have been accumulated, staff would use front loaders to move the logs into the north end of the large shed where a conveyor would feed them into a 43-inch electric-power Salem debarker that would mechanically strip the bark. Removed bark would be discharged into a debris container that would be regularly emptied. A street sweeper would clean the site daily to keep it free of debris and to control dust.

The removed bark would be picked up by Agra Marketing Group (Agra), a recycler based in Chico, California, and conveyed in 25-ton semi-trailer trucks to end markets in the Bay Area or central California. Agra would haul away one to two truck loads per day, Monday through Friday, from the log export facility. The recycled bark would be ground up, screened, and used for landscape mulch and potting soil.

Log export shipments would occur only during the timber harvesting season in California, which starts in April and continues to the end of November. With six shipments anticipated each year, there would be less than one shipment a month.

Processed logs would be stacked in the Debarked Logs Deck area by an excavator. Once a sufficient quantity of processed logs has accumulated in the Debarked Logs Deck area, they would be loaded into a Handymax class vessel for shipment to China. Handymax vessels carry dry bulk goods and are typically between 492 and 656 feet long, with a capacity of 40,000 to 50,000 deadweight tons (DWT). The ships would be loaded by unionized longshoremen using ship-board cranes. It would take up to ten days to load a ship. As noted above, while in dock, the ships would be connected to shoreline electrical power and the ship’s engines would not be idled.

Initial Study 6 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY Normal operating hours for the proposed log export facility would be Monday through Friday from 6:00 a.m. to 6:00 p.m. Receiving hours for loaded log trucks would be from 7:00 a.m. to 5:00 p.m. It is anticipated that approximately 10 truck loads of logs would be delivered to the proposed facility each weekday, with some of the loads arriving on log trucks and others arriving on flatbed trucks.

During standard operational periods, there would be five employees working at the facility. During the periodic ship-loading operations, 16 longshoremen would be temporarily employed, for a total of 21 workers on site.

As discussed above, the operational equipment on the site would consist of an excavator, front loader with claws, and street sweeper. All equipment would be from 2011 model years or more recent and would meet the current requirements of the California Air Resources Board for Marine Cargo Handling Equipment, which requires Tier 4 Alt PM engines and annual opacity testing of particulate matter (PM) in the diesel exhaust.

Facility Improvements As previously noted, Terminal 3 is already a fully developed Port of Richmond facility. To accommodate the proposed facility, RJJ would construct tenant improvements in the first floor of the terminal building, which would include reinstallation of the electrical system. In addition, exterior lighting would be installed along the west side of the terminal shed, along with a surveillance system. The existing scales adjacent to the administration building would also be repaired. A debarker is also proposed to be installed within the warehouse building to support the operations at the site. No other construction or improvements are proposed as part of the proposed project.

Timber Harvest Plans The timber to be exported from the facility would originate from privately-owned forest lands in northern California, both coastal areas and the Sierra Nevada. Each forest that would supply the proposed project has a Timber Harvest Plan (THP) prepared by a Registered Professional Forester (RPF) and approved by the California Department of Forestry and Fire Protection (CALFIRE).

THPs have been certified by the State as being the “functional equivalent” of an Environmental Impact Report (EIR). Their purpose is to disclose to the public all of the potential direct and cumulative environmental impacts that could result from implementation of the logging plan. The THP includes provisions to protect water, wildlife, archaeology sites, plants, and the health and safety of workers and the public. THPs are prepared in coordination with community groups and regulatory agencies such as the California Department of Fish and Wildlife, Regional Water Quality Control Board, and CALFIRE. THPs are also intended to provide sufficient information for the Director of CALFIRE to make a determination that the proposed logging conforms to the Forest Practice Act and the harvesting rules promulgated by the State Board of Forestry and Fire Protection. The THP goes through a two-tier review process that can take up to two years to achieve approval. Once a THP has been approved, CALFIRE Unit Forest Practice Inspectors periodically inspect the logging operation to ensure compliance with the THP and all applicable laws and regulations. Enforcement actions are taken on any identified violations, which can range from violation notices requiring corrective actions to assessment of civil fines to criminal charges. Replanting of trees is required on all forest lands following implementation of a THP.

Upon approval of the THP, the timber owner retains a Licensed Timber Operator (LTO) to harvest the timber. The harvest is subject to the guidelines defined in the THP and, as noted

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 7 above, is subject to State penalty if the LTO does not comply. The facility at Terminal 3 would only accept logs from sites with an approved THP harvested by a LTO. During initial operations at the proposed facility, RJJ would process and export logs that originate from forests burned in fires that occurred in 2014.

Planning Approvals Conditional Use Permit: The project would require approval of a Conditional Use Permit (CUP) by the Richmond Planning Commission for a log processing and export facility use in the M-4 zoning district.

Other Approvals Richmond Fire Department: The project will require approval of a Permit to Operate from the Richmond Fire Department for storage of wood products, including hogged material.

San Francisco Bay Conservation and Development Commission (BCDC): Although the project is not expected to require authorization from the San Francisco Bay Conservation and Development Commission, it is possible that compliance with one of the mitigation measures identified in this Initial Study may require approval from BCDC. See Section IX, Hydrology and Water Quality, for additional information.

State Water Resources Control Board (SWRCB): The project will require filing of a Notice of Intent (NOI) with the State Water Resources Control Board for coverage under the National Pollutant Discharge Elimination System (NPDES) Industrial General Permit (IGP) administered by the SWRCB. This requires preparation and implementation of a Stormwater Pollution Prevention Plan (SWPPP) that addresses control of stormwater pollution through implementation of Best Management Practices (BMPs). See Section IX, Hydrology and Water Quality, for additional information.

U.S. Environmental Protection Agency (EPA): The project will require filing of a Notice of Intent (NOI) with the U.S. Environmental Protection Agency (EPA) to obtain coverage under the NPDES Vessel General Permit (IGP) issued by the EPA. This permit authorizes incidental operational discharges from ocean-going vessels.

9. Site Description and Surrounding Land Uses: The project site is an industrial port property developed with a large warehouse and a small administrative office building. Aside from these buildings and a small guard house, the majority of the approximately 20-acre Terminal 3 site consists of asphalt pavements. The concrete wharf at the waterfront measures 1,009 feet long by 105 feet wide. Additional details about the property are provided above in the discussion of the existing Terminal 3 facilities.

Immediately north of Terminal 3 is Terminal 2, another Port of Richmond property occupying approximately 8 acres that is developed with storage tanks, warehouses, and two cranes, and is used for the storage and distribution of bulk liquids. Immediately to the south of the project site is a portion of Terminal 3 that is leased separately from the Port and is used for temporary storage of imported Toyota automobiles. South of this southern end of Terminal 3 is a public parking lot and a short shoreline segment of the San Francisco Bay Trail, with access to a fishing pier. This site is also planned to include the Richmond Ferry terminal and associated parking lot.

The eastern side of Terminal 3 is bounded Harbour Way South, which has its southern terminus just to the south of Terminal 3. On the west side of Harbour Way South is the historic Ford Assembly Building (FAB) that was used for the assembly of jeeps and tanks during World War

Initial Study 8 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY II. It now houses the Rosie the Riveter WWII Home Front National Historical Park and offices for businesses including Sunpower Corporation and Mountain Hardware, Inc. It also includes the Craneway Pavillion, a 45,000-square-foot space available for a wide range of events including conferences, banquets, fairs, exhibitions, performances, sporting events, workshops, dance classes, etc. A large parking lot is located on the north end of the FAB that has parking for 1,200 autos.

Terminal 3 is located on the west side of a small peninsula on the southern Richmond shoreline that is defined by Harbor Channel and Santa Fe Channel on the west and by Marina Bay, which harbors the Richmond Yacht Club, on the east. West of the FAB are a large vacant parcel adjacent to the shoreline and a large office building that previously housed municipal offices for the City of Richmond and is now partially used by Comcast. To the east of this building, on the east side of Marina Way South, are offices leased by Chevron and West Contra Costa Unified School District. Other uses occupying the buildings include Amethod Charter School and Babbaloo Cafe. Lucretia Edwards Shoreline Park is located on the southeast corner of the peninsula.

East of the northern end of Terminal 3 is a large warehouse/light industrial building that appears to house several companies and has space available for lease. To the east of this building is a large two-story building housing offices of Contra Costa County public agencies.

Just to the north of Terminal 2 is the California Oils Corporation (CalOils), which imports, processes, and distributes vegetable oils in bulk. Adjacent to CalOils is the Levin Richmond Terminal Corporation, which operates a dry bulk cargo marine terminal on the Santa Fe Channel. There are a variety of other industrial uses, many of them port-related, located to the north of Terminal 2.

West of the project site, on the other side of the Harbor Channel that feeds into the Santa Fe Channel, is Point Potrero, another peninsula defining the southern Richmond shoreline. The east side of the peninsula is developed entirely with industrial uses, most of which utilize the port facilities on the Harbor Channel/Santa Fe Channel for transport of products and materials. Companies in this area include Arco (petroleum), Conoco/Phillips (petroleum), Kinder Morgan (natural gas), National Gypsum (drywall, cement board), BP Castrol (petroleum), and Burlington Northern Santa Fe Railroad (BNSF). The southern end of Point Potrero is developed with the Point Potrero Marine Terminal, which is used to import and distribute automobiles from Asia, including Honda, Hyundai, and Kia brands.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 9

ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED:

The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a “Potentially Significant Impact” as indicated by the checklist on the following pages.

Aesthetics Agricultural Resources X Air Quality

Biological Resources Cultural Resources X Geology/Soils

Greenhouse Gas Emissions Hazards & Haz. Materials X Hydrology/Water Quality

X Land Use/Planning Mineral Resources Noise

Population/Housing Public Services Recreation

Transportation/Traffic Utilities/Service Systems

X Mandatory Findings of Significance

Initial Study 10 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

(This page intentionally left blank.)

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 11

DETERMINATION:

On the basis of the initial evaluation:

 I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.  I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.  I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.  I find that the proposed project MAY have a “potentially significant impact” or “potentially significant unless mitigated” impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on the attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.  I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.

Signature Date

Printed name For

Initial Study 12 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

EVALUATION OF ENVIRONMENTAL IMPACTS:

I. AESTHETICS — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Have a substantial adverse effect on a scenic vista?    

Explanation: The project site is situated near the shoreline of San Francisco Bay, which provides many scenic vistas. However, in the immediate vicinity of the project site the availability of scenic views is quite limited. The existing shed warehouse on the eastern edge of the site serves to block views across most of the project site from public vantage points on Harbour Way South.

South of the warehouse, one can view west across the site to the hillsides on the opposite side of Harbor Channel and can see the more distant mountains in Marin County, more than 10 miles to the west. The scenic quality of the more proximate hillsides of Point Potrero is substantially reduced by the presence of large petroleum tank fields both on top of the hills and in the foreground along the western shoreline of Harbor Channel. Other industrial development along the western shoreline of the channel further mars the views in this area.

North of the warehouse, the views across the project site would not be considered scenic by most viewers. The view is dominated by two large cranes and several warehouse buildings on the Terminal 2 property and by the existing Terminal 3 warehouse. The Point Potrero hillsides are substantially obscured by shoreline industrial development and moored ships, and are dominated by the tank farm at the top of the hills.

While public views from Harbour Way South to the north, east, and south are dominated by industrial and light industrial development and would by no means be considered scenic, the proposed project would in any event have no effect whatsoever on these views.

The proposed project would not develop new structures with the potential to block or adversely affect scenic vistas. The site has been used for various port-related uses for many years; the proposed project would introduce new uses and activities that would be consistent with the historical use of the site. As noted above, the availability of scenic views across the project site is limited at best, but the proposed stockpiles of logs awaiting shipment would have very little effect on existing views because the stockpile area would be located to the west of the existing warehouse, which already blocks views to the west entirely. Although the front loaders and other equipment would be parked to the southwest of the warehouse, and thus visible from Harbour Way South, views from the roadway across this portion of the project site are already constrained by the two-story administrative office building, and the addition of construction equipment on the far side of the paved terminal area would not substantially alter existing views.

As described above, the availability of scenic views in the immediate vicinity of the project is very limited at best, and it could be argued that there are no scenic vistas in the vicinity. The project would have a minor effect on the public views that are available across the project site. For these reasons, the project would have a less-than-significant impact on a scenic vista.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 13

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Substantially damage scenic resources, including but not limited to, trees, rock outcroppings, and historic     buildings within a state scenic highway?

Explanation: There are no State-designated scenic highways in the vicinity of the project site.1 Furthermore, there are no scenic resources on the project site. Therefore, the project would have no effect on scenic resources.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Substantially degrade the existing visual character or quality of the site and its surroundings?    

Explanation: The existing visual quality of the project site is generally low, dominated by the large warehouse present on the east side of the site. The harshness of the view of the site from Harbour Way South is substantially softened by street trees planted every 10 to 15 feet along the site frontage, interspersed with shrubs. Other than the warehouse, the site primarily consists of a small office building, a guard house, and an extensive expanse of asphalt pavement. The only trees on or adjacent to the site are those along the west side of Harbour Way South, within the public right-of-way.

The proposed project would not substantially alter the existing visual character of the site. The large warehouse and two smaller structures would be retained and no new structures would be constructed. While the applicant would make some tenant improvements to the first floor of the administrative office building, these improvements would be to the interior of the building and would not be visible on the exterior of the building or from offsite locations.

The only substantial change to the site would result from the stockpiling of logs. The majority of the logs would be stockpiled on the Debarked Logs Deck that would be located west of the warehouse building. As discussed in Section I-a, above, this building would block most views of the log stockpile from offsite locations. Oblique views of the southern end of the stockpile would be visible from Harbour Way South at select vantage points south of the warehouse, though the office building would obscure the view from most locations.

There would also be some short-term stockpiling of logs that still have bark on in the Log Layout Yard at the north end of the site, though the piles of logs would be shorter in height than those stored on the Debarked Logs Deck. As previously noted, the view from Harbour Way South across this northern portion of Terminal 3 is dominated by ship cranes and warehouse buildings. The visual quality of the site is therefore low, and the intermittent presence of stockpiled logs would not substantially deteriorate the visual character of the site.

1 California Department of Transportation, Officially Designated State Scenic Highways, accessed September 7, 2015 at: http://www.dot.ca.gov/hq/LandArch/16_livability/scenic_highways/schwy.htm.

Initial Study 14 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

The project site is located in an industrialized neighborhood characterized by large buildings and expansive parking areas, with no appealing natural features or aesthetic amenities in the immediate vicinity (though appealing Bay views are available elsewhere on the peninsula). The only people who would typically see the project site would be passing motorists—dominated by truck drivers—on Harbour Way South. These drivers would have only a passing glance at the portions of the site not already obscured from view, and would be unlikely to notice the visual changes that would be caused by the project.

There are no residences in the area and, based on numerous visits to the site and vicinity, there appear to rarely be any pedestrians on the sidewalks adjacent to the site. While occupants of the northwest corner of the Ford Assembly Building on the east side of Harbour Way South would be able to see the southern end of logs stockpiled on the Debarked Logs Deck, the minor visual changes would be noticeable only to a small number of workers in the business(es) located in this corner of the FAB.

For all of the considerations enumerated above, the project would have a less-than-significant impact on the visual character of the site.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the     area?

Explanation: The proposed project would not result in the introduction of new glare or a substantial source of new nighttime lighting. New exterior lighting would be installed on the west side of the existing warehouse building to illuminate the Debarked Logs Deck. The visibility of this new lighting would be limited by the same factors discussed in Section I-a, above. Since there are no residences in the vicinity of the project and no residences on Point Potrero west of Harbor Channel with visual sight lines to the project site, there are no sensitive visual receptors in the vicinity of the site who would be affected by new nighttime lighting. The lighting would not be extensive or out of character with outdoor security lighting present at many of the industrial sites in the project area. Furthermore, the lighting would be required to conform with the lighting and glare standards established in Richmond Municipal Code Section 15.04.840.040, which prohibit the production of glare on public streets and adjacent parcels. The regulations also require lighting to be shielded at lot lines so as not to be directly visible from an adjoining residential district. Therefore, the project’s light and glare impacts would therefore be less than significant.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 15

II. AGRICULTURAL RESOURCES — In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the State’s inventory of forest land, including the Forest and Range Assessment Project and the Forestry Legacy Assessment Project, and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the     California Resources Agency, to non-agricultural use?

Explanation: The project site and all surrounding lands are designated “Urban and Built–Up Land” on the maps prepared pursuant to the Farmland Mapping and Monitoring Program (FMMP) by the Department of Conservation (DOC), a department of the California Resources Agency.2 The DOC updates the maps every two years; the most recent map was prepared in 2012 and published in 2014. Since the project site does not contain any Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, there is no potential for conversion of these types of farmlands.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Conflict with existing zoning for agricultural use, or a Williamson Act contract?    

Explanation: The project property is not zoned for agricultural use or under a Williamson Act contract.

2 California Department of Conservation, Division of Land Resource Protection, Farmland Mapping and Monitoring Program, “Contra Costa County Important Farmland 2012” (map), April 2014.

Initial Study 16 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined in Public Resources Code Section 4526), or timberland zoned     Timberland Production (as defined by Government Code Section 51104(g))?

Explanation: The project site is not zoned as forest land and there is no forest land on the site. The proposed project would therefore have no impact on forest or timber land.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Result in the loss of forest land or conversion of forest land to a non-forest use?    

Explanation: Public Resources Code Section 12220(g) defines forest land as land that can support 10-percent native tree cover of any species, including hardwoods, under natural conditions, and that allows for management of one or more forest resources, including timber, aesthetics, fish and wildlife, biodiversity, water quality, recreation, and other public benefits. There is no forest land on the project site as defined in Public Resources Code Section 12220(g).

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or     conversion of forest land to non-forest use?

Explanation: The project site does not contain farmland or forest land, and implementation of the proposed project would therefore have no potential to convert such lands to other uses.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 17

III. AIR QUALITY — Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Conflict with or obstruct implementation of the applicable air quality plan?    

Explanation: The Bay Area Air Quality Management District (BAAQMD) adopted its 2010 Bay Area Clean Air Plan (CAP) in accordance with the requirements of the California Clean Air Act (CCAA) to implement all feasible measures to reduce ozone; provide a control strategy to reduce ozone, particulate matter, air toxics, and greenhouse gas (GHG) emissions in a single, integrated plan; and establish emission control measures to be adopted or implemented in the 2010 through 2012 timeframe.3 The primary goals of the 2010 Bay Area CAP are to: • Attain air quality standards; • Reduce population exposure and protect public health in the Bay Area; and • Reduce GHG emissions and protect the climate. When a public agency contemplates approving a project where an air quality plan consistency determination is required, BAAQMD recommends that the agency analyze the project with respect to the following questions: (1) Does the project support the primary goals of the air quality plan; (2) Does the project include applicable control measures from the air quality plan; and (3) Does the project disrupt or hinder implementation of any 2010 CAP control measures? If the first two questions are concluded in the affirmative and the third question concluded in the negative, the BAAQMD considers the project consistent with air quality plans prepared for the Bay Area.

Any project that would not support the 2010 CAP goals would not be considered consistent with the 2010 CAP. The recommended measure for determining project support of these goals is consistency with BAAQMD CEQA thresholds of significance. As presented in the subsequent impact discussions, the proposed project with mitigations would not exceed the BAAQMD significance thresholds; therefore, the proposed project with mitigations would support the primary goals of the 2010 CAP.

The proposed project would support the primary goals of the 2010 CAP and would be consistent with all applicable 2010 CAP control measures, and would not disrupt or hinder implementation of any 2010 CAP control measures. Therefore, there would be a less-than- significant impact associated with, conflicting with, or obstructing implementation of the applicable air quality plan. The air quality setting and regulatory context are described in Appendix AQ–1. A number of regulations and rules promulgated by BAAQMD, California Air Resources Board (CARB), US Environmental Protection Agency (USEPA), and other agencies with direct

3 In 2015, the BAAQMD initiated an update to the 2010 CAP. On February 28, 2014, the District held a public meeting to report progress on implementing the control measures in the 2010 CAP, to solicit ideas and strategies to further reduce ozone precursors, particulate matter, toxic air contaminants, and greenhouse gases, and to seek input on innovative strategies to reduce greenhouse gases, mechanisms for tracking progress in reducing GHGs, and how the District may further support actions to reduce GHGs. The culmination of this effort will be an updated CAP.

Initial Study 18 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

application of emission sources within ports, in general, and the Port of Richmond, specifically, are discussed further within Appendix AQ–1. They include the following: • Fuel Sulfur and Other Operational Requirements for Ocean-going Vessels within California Waters and 24 Nautical miles of the California Baseline (California Code of Regulations [CCR], Title 13, Section 2299.2) • Airborne Toxic Control Measure for Auxiliary Diesel Engines Operated on Ocean-Going Vessels At-Berth in a California Port (CCR, Title 17, Section 93118.3) • Airborne Toxic Control Measure for Commercial Harbor Craft (CCR, Title 17, Section 93118.5) • California’s Drayage Truck Regulation (CCR, Title 13, Section 2027) • Mobile Cargo Handling Equipment at Ports and Intermodal Rail Yards • Heavy-Duty Vehicle Idling Emission Reduction Program • General Requirements for In-Use Off-Road Diesel Fueled Fleets (CCR, Title 13, Section 2449) • On-Road Heavy-Duty Diesel Vehicles (In-Use) Regulation • Off-Road Large Spark-Ignition (Gasoline and Propane) Equipment Regulation • California Low Sulfur Diesel Regulations • Standards for Nonvehicular Diesel Fuel Used in Diesel-Electric Intrastate Locomotives and Harbor Craft (CCR Title 13, Section 2299)

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Violate any air quality standard or contribute substantially to an existing or projected air quality     violation?

Explanation: The following discussion describes the project parameters that were factored in to the quantified analysis of the air pollutant emissions that would be generated by the proposed project. The project includes the development and operation of a log export facility at an existing facility at the Port of Richmond, on an approximately 12.2-acre site. The proposed facility would receive logs by truck from a site in West Sacramento that would be prepared for shipment, then loaded onto ocean-going ships while berthed at Terminal 3. It is anticipated that approximately 14 truckloads of logs would be delivered to the proposed facility each weekday. Log trucks would begin travel at a site in West Sacramento, which is within the Yolo-Solano Air Quality Management District (YSAQMD). Approximately half way to the proposed facility, logging trucks would cross over into the BAAQMD. Log truck trip lengths were estimated to be 148 miles per round trip (80 miles within BAAQMD and 68 miles within YSAQMD). Within EMFAC2014, the log trucks were classified as T7 tractor trucks; which is a heavy-heavy-duty tractor truck. The emissions associated with log truck trips were based on a CARB Truck and Bus Regulation Reporting inventory for RJJ International, the project applicant, which includes a total of twelve logging trucks of varying model year from 1996 to 2016.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 19

Logs arriving with bark still on would be debarked and removed bark would be picked up in 25-ton semi-trailer trucks and hauled to end markets in the Bay Area. It is anticipated that one to two truckloads of bark would be hauled away each week. Bark trucks were assumed to begin in Tracy, pick up their loads at the proposed project site, and drop them off in Milpitas. Therefore, bark truck trip lengths were estimated to be 113 miles per round trip; entirely within the BAAQMD. Within EMFAC2014, the bark trucks were also classified as T7 tractor trucks.

Log export shipments would occur during the timber harvesting season in California, which starts in April and continues through November. With six shipments anticipated each year, there would be one shipment every five weeks. While in dock, the ships would be connected to shoreline electrical power and the ship’s engines would not be idled; thus, eliminating auxiliary engine emissions associated with hoteling at the berth.4 It would take up to ten days to load a ship.

Normal operating hours for the proposed facility would be Monday through Friday from 6 a.m. to 6 p.m. and receiving hours for loaded log trucks would be from 7 a.m. to 5 p.m. During standard operational periods, there would be five employees working at the proposed facility and during periodic ship-loading operations, 16 longshoremen would be temporarily employed, for a total of 21 workers on site.

Mobile Equipment Emissions Operational equipment at the proposed facility would include an excavator, front loader with claws, debarker, and street sweeper. The debarker is addressed separately below in the discussion of fugitive dust emissions. All mobile equipment would be from 2011 model years or more recent and would meet the current requirements of CARB for marine cargo handling equipment, which require Tier 4 engines5 and annual opacity testing of particulate matter in the diesel exhaust.6

Analyzed air quality pollutants include: carbon monoxide (CO), reactive organic compounds (ROG), nitrogen oxides (NOx), sulfur dioxide (SO2), particulate matter equal to or less than 10 micrometers (coarse particulates or PM10), and particulate matter equal to or less than 2.5 micrometers (fine particulates or PM2.5). The emissions generated from the proposed project include combustion emissions of criteria air pollutants (ROG, NOx, CO, PM10, and PM2.5) primarily from operation of onsite equipment, marine vessels (bulk carriers),7 harbor craft, haul trucks, (primarily diesel-operated), and worker automobile trips (primarily gasoline-operated).

The construction activities associated with the proposed project would be minimal and the air emissions would be considered less than significant.8 Thus, the air quality analysis focuses on operational impacts on air quality.

CARB’s OFFROAD emissions inventory model was used to estimate emissions from off-road operational equipment such as excavators and loaders.9 CARB’s EMFAC2014 emissions

4 Shore power reduces annual NOx emissions by 1.0 tons and other pollutants by less than 0.1 tons. 5 Emission Standards Nonroad Diesel Engines, https://www.dieselnet.com/standards/us/nonroad.php 6 Tier 4 onsite equipment reduces annual NOx emissions by 1.5 tons and other pollutants by less than 0.1 tons. 7 Bulk carriers are vessels used to transport bulk items such as mineral ore, fertilizer, wood chips, or grain. 8 Terminal 3 is already a fully developed Port of Richmond facility. To accommodate the proposed facility, improvements in the first floor of the terminal building, which would include reinstallation of the electrical system, would be made. In addition, exterior lighting would be installed along the west side of the terminal shed, along with a surveillance system. The existing scales adjacent to the administration building would also be repaired. No other construction or improvements would be required for the proposed project. 9 California Air Resources Board, OFFROAD Instructions, http://www.arb.ca.gov/msprog/ordiesel/info_1085/oei_write_up.pdf.

Initial Study 20 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

inventory model was used to estimate emissions from truck trips and worker automobile trips.10 USEPA’s Current Methodologies in Preparing Mobile Source Port-Related Emissions and other guidance was used to estimate emissions from marine vessel operations.11 Air quality calculations and assumptions are described in Appendix AQ–2.

Estimated average daily and annual operational emissions associated with the proposed project that would occur within the YSAQMD are presented in Tables AQ–1 and AQ–2 and are compared to the YSAQMD thresholds of significance. Only log truck operations would occur within YSAQMD. As indicated in Tables AQ–1 and AQ–2, the estimated proposed project operational emissions would be below the YSAQMD’s significance thresholds and would have a less-than-significant impact on air quality within the YSAQMD jurisdiction.

Fugitive Dust Emissions A conveyor would feed logs not already stripped of bark into a 43-inch electric-power Salem debarker that would mechanically strip the bark. Removed bark would be discharged into a debris container that would be regularly emptied. Some fugitive dust would be generated by these stripping and discharge activities. A street sweeper would clean the site daily to keep it free of debris and to control dust. To estimate the PM10 and PM2.5 emissions from the debarker, the emission factor from USEPA’s AP-42 and other appropriate guidance of 0.024 pounds total suspended particulate (TSP) per ton of logs was applied to the throughput quantity of wood expected to be processed.12, 13 Approximately 50 percent of the particulate emissions are assumed to be PM10 and approximately 25 percent of the particulate emissions are assumed to be PM2.5. Water suppression, enclosures, or other methods would provide 50-percent abatement of particulate emissions.

Air emissions generated from truck movement, material handling, and debarker operations may include dust (including PM10 and PM2.5) from “fugitive” sources (i.e., emissions released through means other than through a stack or tailpipe) such as from truck movement, material handling, and debarker operations as well as combustion emissions from marine vessels, onsite equipment, and haul trucks.

Fugitive dust emissions would vary from day to day, depending on the level and type of activity, silt content of the material, and the weather. In the absence of mitigation, activities may result in significant quantities of dust, and as a result, local visibility and PM10 concentrations may be adversely affected on a temporary and intermittent basis. In addition, the fugitive dust generated by truck movement, material handling, and debarker operations would include not only PM10, but also larger particles, which would fall out of the atmosphere within several hundred feet of the site and could result in nuisance-type impacts. Absent appropriate mitigation, the fugitive dust emissions from the proposed project would be a potentially significant impact. BAAQMD’s CEQA Air Quality Guidelines require a number of best

10 California Air Resources Board, EMFAC User’s Guide, December 30, 2014, http://www.arb.ca.gov/ msei/emfac2014_users_guide.pdf. 11 US Environmental Protection Agency, Current Methodologies in Preparing Mobile Source Port-Related Emissions, April 2009, http://trid.trb.org/view.aspx?id=927750, Emissions Estimation Methodology for Ocean-Going Vessels, May 2008, http://www.arb.ca.gov/regact/2008/fuelogv08/appdfuel.pdf, and Analysis of Commercial Marine Vessels Emissions and Fuel Consumption Data, February 2000, http://www3.epa.gov/otaq/models/nonrdmdl/c- marine/r00002.pdf. 12 US Environmental Protection Agency, Particulate Matter Potential to Emit Emission Factors for Activities at Sawmills, Excluding Boilers, Located in Pacific Northwest Indian County, May 8, 2014, http://www3.epa.gov/ region10/pdf/air/technical/spmpteef_memo.pdf. 13 Bay Area Air Quality Management District, Permit Handbook, Section 11.13 Tub Grinders, April 15, 2008, http://hank.baaqmd.gov/pmt/handbook/rev02/PH_00_05_11_13.pdf.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 21

management practices to control fugitive dust emissions. Accordingly, implementation of the following measures would reduce the impact to a less-than-significant level:

Mitigation Measure AQ–1: Fugitive Dust Control Measures: The Applicant shall reduce air emissions by implementing the following fugitive dust control measures, including: • Compliance with Bay Area Air Quality Management District’s (BAAQMD’s) Particulate Matter and Visible Emissions Regulation shall be maintained. • All haul trucks transporting mulch/bark material off site shall be covered. • All visible 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. • All vehicle speeds within the facility property shall be limited to 15 miles per hour. • Use dust enclosures, curtains, and dust collectors as necessary to control dust generation associated with the debarker, including stockpiling from conveyors, front-end loading of materials to vehicular transport, and bin transfer to vehicular transport. Minimize drop heights when transferring any mulch/bark materials. • Inactive mulch/bark material stockpiles (no disturbance of stockpile for more than seven days) shall be wetted, covered, or contained. • 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 pertaining to idling time shall be provided for haul trucks at all access points. • All 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. • A publically visible sign shall be posted with the telephone number and person to contact at the Lead Agency regarding dust complaints. This person shall respond and take corrective action with 48 hours. The BAAQMD’s phone number shall also be visible to ensure compliance with applicable regulations.

Initial Study 22 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

Table AQ–1 Estimated Average Daily Project Operational Emissions in the YSAQMD (pounds per day)

Condition ROG NOx PM10 PM2.5 CO

Log Trucks 0.76 18.1 0.21 0.20 2.65 Total Proposed Project 0.76 18.1 0.21 0.20 2.65 Significance Threshold –– –– 80 –– –– Significant (Yes or No)? No No No No No

Source: CARB EMFAC2014

Notes: See Appendix AQ–2 for air quality calculations and assumptions. Average daily emissions over the project duration of 160 days per year.

Table AQ–2 Estimated Average Daily Project Operational Emissions in the YSAQMD (tons per year)

Condition ROG NOx PM10 PM2.5 CO

Log Trucks 0.06 1.45 0.02 0.02 0.21 Total Proposed Project 0.06 1.45 0.02 0.02 0.21 Significance Threshold 10 10 –– –– –– Significant (Yes or No)? No No No No No

Source: CARB EMFAC2014

Note: See Appendix AQ–2 for air quality calculations and assumptions.

Estimated average daily and annual operational emissions associated with the proposed project that would occur within the BAAQMD are presented in Tables AQ–3 and AQ–4 and are compared to BAAQMD’s thresholds of significance. As indicated in Tables AQ–3 and AQ–4, the estimated proposed project operational emissions would be below the BAAQMD’s significance threshold and thus, would have a less-than-significant impact on air quality within the BAAQMD jurisdiction.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 23

Table AQ–3 Estimated Average Daily Project Operational Emissions in the BAAQMD (pounds per day)

Condition ROG NOx PM10 PM2.5 CO

Onsite Equipment 0.61 1.31 0.07 0.06 12.1 Debarker — — 2.31 1.16 Marine Vessels 1.49 25.4 0.52 0.48 2.48 Harbor Craft 0.02 1.61 0.05 0.05 0.38 Log Trucks 0.89 21.3 0.24 0.23 3.11 Bark Trucks 0.14 3.53 0.04 0.04 0.49 Worker Automobiles 0.05 0.25 0.02 0.02 0.80 Total Proposed Project 3.20 53.4 3.25 2.04 19.4 Significance Threshold 54 54 82 54 –– Significant (Yes or No)? No No No No No

Source: CARB EMFAC2014 Notes: See Appendix AQ–2 for air quality calculations and assumptions. Average daily emissions over the project duration of 160 days per year.

Table AQ–4 Estimated Average Daily Project Operational Emissions in the BAAQMD (tons per year)

Condition ROG NOx PM10 PM2.5 CO Onsite Equipment 0.05 0.10 0.01 <0.01 0.97 Debarker — — 0.18 0.09 Marine Vessels 0.12 2.03 0.04 0.04 0.20 Harbor Craft <0.01 0.13 <0.01 <0.01 0.03 Log Trucks 0.07 1.71 0.02 0.02 0.25 Bark Trucks <0.01 0.06 <0.01 <0.01 0.01 Worker Automobiles <0.01 0.02 <0.01 <0.01 0.06 Total Proposed Project 0.27 4.05 0.28 0.18 1.52 Significance Threshold 10 10 15 10 –– Significant (Yes or No)? No No No No No

Source: CARB EMFAC2014 Note: See Appendix AQ–2 for air quality calculations and assumptions.

Initial Study 24 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

The BAAQMD has identified preliminary screening criteria for determining whether CO emissions would be exceeded. The screening criteria provide a conservative indication of whether the implementation of the proposed project would result in CO emissions that are potentially significant. This methodology utilizes the following screening criteria: 1. The proposed project is consistent with an applicable congestion management program established by the county congestion management agency for designated roads or highways, regional transportation plan, and local congestion management agency plans. 2. The proposed project traffic would increase traffic volumes at affected intersections to more than 44,000 vehicles per day. 3. The proposed project traffic would increase traffic volumes at affected intersections to more than 24,000 vehicles per day where vertical and/or horizontal mixing is substantially limited (e.g., tunnel, parking garage, bridge underpass, natural or urban street canyon, below-grade roadway).

The proposed project traffic would not cause the daily traffic volumes to exceed the screening criteria shown in items 1 through 3 based on the circulation infrastructure and the projected traffic volumes. Therefore, the proposed project would have a less-than-significant impact on air quality due to long-term operational CO exhaust emissions.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing     emissions which exceed quantitative thresholds for ozone precursors)?

Explanation: As shown in Tables AQ–1 through AQ–4, project-related operational emissions would be below the BAAQMD significance thresholds per BAAQMD’s CEQA Air Quality Guidelines. The BAAQMD CEQA Air Quality Guidelines recommend that cumulative air quality effects from criteria air pollutants also be addressed by comparison to the project-level daily and annual emission thresholds. These significance thresholds were developed to identify a cumulatively considerable contribution to a significant regional air quality impact. For this proposed project, as discussed in the preceding subsection, operational emissions from the project would be less than significant. Therefore, the proposed project would not be cumulatively considerable and cumulative impacts would be less than significant. Secondly, the health risk assessment was compared to the project-level thresholds and cumulative thresholds (See Appendix A, Table A-1). Cumulative health risk assessment sources (see item d below) include other Port of Richmond operations (including marine vessels, cargo handling, and rail activities), nearby permitted stationary sources, and traffic on Interstate 580. Additional analysis that includes other nearby planned projects is not required. Therefore, the project would have a less- than-significant cumulative impact on air quality.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 25

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Expose sensitive receptors to substantial pollutant concentrations?    

Explanation: According to BAAQMD’s CEQA Air Quality Guidelines and Air Toxics New Source Review Program Health Risk Screening Analysis Guidelines, health effects from carcinogenic air toxics are usually described in terms of individual cancer risk. Individual cancer risk is the likelihood that a person exposed to concentrations of toxic air contaminants (TACs) such as diesel particulate matter (DPM) over a 70-year lifetime will contract cancer, based on the use of standard risk-assessment methodology.14 The maximally exposed individual represents the worst-case risk estimate, based on a theoretical person continuously exposed for 30 years at the point of highest compound concentration in the air. This is a highly conservative assumption, since most people do not remain at home all day and on average residents change residences every 11 to 12 years. In addition, this assumption assumes that residents are experiencing outdoor concentrations for the entire exposure period.

BAAQMD considers the relevant zone of influence for an assessment of air quality health risks to be within 1,000 feet of a project site. Sensitive receptors such as residences, schools, and outdoor recreational areas near the proposed project were chosen as the receptors to be analyzed. The project site is located on the west side of Harbour Way South at its southern terminus, on the southern shoreline of the City of Richmond. The site is located on the east side of Harbor Channel, adjacent to the Richmond Inner Harbor on San Francisco Bay. The proposed project is approximately 3,500 feet (0.7 miles) south of Interstate 580. Sensitive receptors include the Ford Assembly Building, residences near Marina Park and Vincent Park (to the east), and recreational use at Lucretia Edwards Park and Vincent Park. The Benito Juarez Elementary School (at 1450 Marina Way South) is located approximately 1,350 feet to the southeast of the project site, outside of the 1,000-foot radius recommended by BAAQMD.

The BAAQMD has established a significance threshold for individuals exposed to TAC sources as the increased incremental cancer risk of 10 in one million or greater. This health risk assessment (HRA) analyzed the potential incremental cancer risks to sensitive receptors in the vicinity of the proposed project, using emission rates from CARB’s EMFAC2014 and OFFROAD emission models and USEPA’s guidance for marine vessels. Emission rates were input into the USEPA’s AERMOD (Version 15181) atmospheric dispersion model to calculate ambient air concentrations at receptors in the project vicinity.15

This HRA is intended to provide a worst-case estimate of the increased exposure by employing a standard emission estimation program, an accepted pollutant dispersion model, approved toxicity factors, and exposure parameters. These conservative health risk methodologies were used in order to estimate maximum potential health risks. These methodologies overestimate both non-carcinogenic and carcinogenic health risk, possibly by an order of magnitude or more. Therefore, for carcinogenic risks, the actual probabilities of cancer formation in the populations

14 Bay Area Air Quality Management District. Air Toxics New Source Review Program Health Risk Screening Analysis Guidelines. January 2010. http://www.baaqmd.gov/~/media/Files/Engineering/Air%20Toxics%20Programs/hrsa_guidelines.ashx 15 US Environmental Protection Agency, AERMOD Modeling System, http://www.epa.gov/scram001/dispersion_prefrec.htm.

Initial Study 26 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

of concern due to exposure to carcinogenic pollutants are likely to be lower than the risks derived using the risk assessment methodology. The extrapolation of toxicity data in animals to humans, the estimation of concentration prediction methods within dispersion models, and the variability in lifestyles, fitness and other confounding factors of the human population also contribute to the overestimation of health impacts. Therefore, the results of this HRA are highly overstated.

In accordance with California Office of Environmental Health Hazard Assessment’s (OEHHA) Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments, this HRA was accomplished by applying the highest estimated concentrations of air toxics at the receptors analyzed to the established cancer potency factors and acceptable reference concentrations for non-cancer health effects.16 Appendix AQ–3 provides additional information on the methodology and assumptions used for this HRA.

Cumulative Health Impact Methodology The BAAQMD’s CEQA Air Quality Guidelines also include standards and methods for determining the significance of cumulative health risk impacts. The method for determining cumulative health risk requires the tallying of health risk from permitted stationary sources, major roadways, and any other identified substantial TAC sources in the vicinity of a project site (i.e., within a 1,000-foot radius) and then adding the individual sources to determine whether the BAAQMD’s cumulative health risk thresholds are exceeded. Results are summarized for the maximally exposed individual receptor.

Other operations within the Port of Richmond such as marine vessels (bulk carriers), harbor craft, cargo handling equipment, and rail operations were included as cumulative sources of health impacts.17 Secondly, the BAAQMD has developed a geo-referenced database of permitted stationary emissions sources throughout the San Francisco Bay Area and the Stationary Source Risk & Hazard Analysis Tool (May, 2012) for estimating cumulative health risks from the permitted sources. One permitted source is located within approximately 1,000 feet of the project site.

Lastly, BAAQMD has also developed a geo-referenced database of major roadways in the Bay Area and the Highway Screening Analysis Tool (May 2011) for estimating cumulative health risks from such roadways. No major roadways are within 1,000 feet of the project site. BAAQMD’s CEQA Air Quality Guidelines also require the inclusion of surface streets within 1,000 feet of the proposed project with annual average daily traffic of 10,000 vehicles or more.18 No nearby roadways meet these criteria.

Incremental Cancer Risk Cancer risk is the lifetime probability of developing cancer from exposure to carcinogenic substances. Following HRA guidelines established by OEHHA in Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments and by the BAAQMD in Recommended

16 Office of Environmental Health Hazard Assessment, 2015. Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments, http://oehha.ca.gov/air/hot_spots/hotspots2015.html. 17 The Port of Richmond operates a limited number of cargo-handling equipment. According to the 2005 inventory, these comprise two propane powered forklifts (operating for 810 hours per year) and three diesel-fueled general industrial equipment such as tractors (operating for 60 hours per year). 18 BAAQMD County Surface Street Screening Tables, May 2011 and CEHTP Traffic Linkage Service Demonstration, http://www.ehib.org/traffic_tool.jsp.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 27

Methods for Screening and Modeling Local Risks and Hazards, incremental cancer risks were calculated by applying established toxicity factors to modeled concentrations. 19

Health Impacts on Existing Residences, Schools, and Recreational Areas The construction activities associated with the proposed project would be minimal and the health impacts would be considered less than significant. The following describes the health risk assessment associated with existing receptors in the vicinity as a result of proposed project operations. Project operations include marine vessels, harbor craft, onsite equipment such as loaders, and haul (bark and log) trucks. The maximum DPM concentrations would occur at a residential receptor (also known as the MEI (maximally exposed individual)) within the Ford Assembly Building to the southeast of the proposed project. The maximum cancer risk from DPM emissions as a result of the proposed project for a residential receptor would be 2.9 per million persons. The maximum cancer risk from DPM emissions as a result of the proposed project for a school child receptor would be 0.1 per million persons. Thus, the cancer risk due to proposed project operations would be well under the BAAQMD threshold of 10 per million, and this would be a less-than-significant impact.

The estimated cancer risk impacts at the existing residence of the maximally exposed individual due to other Port of Richmond activities and other cumulative sources is 9.0 per million. The cumulative cancer risk from the proposed project and other nearby cumulative sources is 11.9 per million and thus, below the BAAQMD significance threshold of 100 per million. The cumulative cancer risk would therefore also be less than significant. The health impacts from the proposed project are generally low due to project design elements such as the use of shore power instead of marine vessel hoteling and Tier 4 onsite equipment which eliminate or reduce DPM emissions.

Non-Cancer Health Hazard Potential non-cancer health effects due to chronic exposure to DPM were also evaluated in the HRA. Both acute (short-term) and chronic (long-term) adverse health impacts unrelated to cancer were measured against a hazard index (HI), which is defined as the ratio of a project’s incremental DPM exposure concentration to a published reference exposure level (REL), as determined by OEHHA. To compute the total HI, individual ratios or Hazard Quotients (HQs) of each individual air toxic are added to produce an overall HI. If the overall HI is greater than 1.0, then the impact is considered to be significant.

The chronic reference exposure level for DPM as determined by OEHHA is 5 µg/m3. There is no acute REL for DPM. However, diesel exhaust does contain acrolein and other compounds, which do have an acute REL. Based on BAAQMD’s DPM speciation data, acrolein emissions are approximately 1.3 percent of the total DPM emissions. The acute REL for acrolein as determined by OEHHA is 2.5 µg /m3.20 Appendix AQ–3 provides additional information on the methodology used for the HRA.

The HRA modeling determined that the chronic HI would be 0.01, well below the BAAQMD significance threshold of 1. The cumulative chronic health impacts would also be well below the BAAQMD threshold of 10. The proposed project would therefore have a less-than-significant adverse chronic health impact.

19 Bay Area Air Quality Management District, Recommended Methods for Screening and Modeling Local Risks and Hazards, May 2012. http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/CEQA/Risk%20Modeling%20Approac h%20May%202012.ashx?la=en. 20 California Office of Environmental Health Hazards Assessment, Toxicity Criteria Database, 2010. http://www.oehha.ca.gov/tcdb/index.asp

Initial Study 28 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

PM2.5 Concentration Dispersion modeling also estimated the exposure of sensitive receptors to project-related concentrations of PM2.5. The BAAQMD CEQA Air Quality Guidelines require inclusion of only PM2.5 exhaust emissions in this analysis; fugitive dust emissions are addressed under BAAQMD dust control measures and are required by law to be implemented during project construction. The annual PM2.5 concentration from proposed project operational activities would be 0.01 3 3 µg/m , while the annual cumulative PM2.5 concentration would be 0.3 µg/m . These concentrations would be below the respective BAAQMD significance thresholds of 0.3 µg/m3 and 0.8 µg/m3. The project would therefore have a less-than-significant impact on human health as a result of PM2.5 exhaust emissions from operation of the project.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact e) Create objectionable odors affecting a substantial number of people?    

Explanation: Though offensive odors from stationary and mobile sources rarely cause any physical harm, they still remain unpleasant and can lead to public distress, generating citizen complaints to local governments. The occurrence and severity of odor impacts depend on the nature, frequency, and intensity of the source; wind speed and direction; and the sensitivity of receptors. Generally, odor emissions are highly dispersive, especially in areas with higher average wind speeds. However, odors disperse less quickly during inversions or during calm conditions, which hamper vertical mixing and dispersion.

The BAAQMD’s significance criteria for odors are subjective and are based on the number of odor complaints generated by a project. Generally, the BAAQMD considers any project with the potential to frequently expose members of the public to objectionable odors to cause a significant impact. With respect to the proposed project, diesel-fueled equipment exhaust would generate some odors. However, these emissions typically dissipate quickly and would be unlikely to affect a substantial number of people. Therefore, odor impacts associated with the location of the proposed project would be less than significant.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 29

IV. BIOLOGICAL RESOURCES — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or     regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?

Explanation: The project site is a previously disturbed industrial port property and the majority of the site is covered with impervious surfaces (i.e., buildings and pavements). Other than a small grass lawn in front of the office building near the southern end of the site, there is no vegetation or natural habitat on the project site. There is no habitat on the site to support any special-status species.

Although special-status marine mammal species such as California sea lions (Zalophus californianus) and harbor seals (Phoca vitulina) may occasionally visit the Harbor Channel waters adjacent to Terminal 3, the proposed project does not include any modifications to the Terminal 3 wharf or any activities that would affect the marine habitat next to the site. While the project would include the temporary berthing of up to six cargo ships per year during log loading operations, this would represent a reduction in the number of vessels currently berthed at Terminal 3. Currently, approximately 10 to 12 ships are lay berthed (i.e., parked) at Terminal 3 each for varying periods of days or weeks.21 These ships are not idling while berthed, but may be connected to an existing shoreline power terminal.

Due to the lack of any supportive habitat, there is no potential for special-status plant or wildlife species to be present at or frequent the project site. Therefore, the project would have no impact on special-status species.

21 Jim Matzorkis, Director, Port of Richmond, personal communication, September 8, 2015.

Initial Study 30 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies,     regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?

Explanation: There is no riparian habitat or other sensitive natural community present on or in proximity to the project site. There is therefore no potential for such habitats to be adversely affected by the project.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct     removal, filling, hydrological interruption, or other means?

Explanation: There are no wetlands or other waters subject to regulation by the U.S. Army Corps of Engineers or Regional Water Quality Control Board under Section 404 of the Clean Water Act present on the project site. Although regulated waters are immediately adjacent to the project site and would be utilized by ships operated as part of the proposed project, as discussed in Section IV-a, above, the project would not increase or substantially alter the existing use of the wharf at Terminal 3. Therefore, the proposed project would have no effect on wetlands or other waters regulated under the Clean Water Act.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with any established native resident or migratory     wildlife corridors, or impede the use of native wildlife nursery sites?

Explanation: There is no suitable habitat on or in the vicinity of the project site with the potential to function as a migratory wildlife corridor.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 31

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact e) Conflict with any local policies or ordinances protecting biological resources, such as a tree     preservation policy or ordinance?

Explanation: The proposed project would not require the removal of any trees and would not have any adverse effects on biological resources. Therefore, the project would not conflict with any local policies or ordinances protecting biological resources.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional,     or state habitat conservation plan?

Explanation: There is no adopted habitat conservation plan (HCP) applicable to the City of Richmond. Furthermore, as discussed in Section IV-a, above, there is virtually no natural habitat on the site, and no potential for the proposed project to adversely affect valuable habitat.

V. CULTURAL RESOURCES — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Cause a substantial adverse change in the significance of a historical resource as defined in     §15064.5?

Explanation: In order to be considered a significant historical resource as defined in Section 15064.5 of the CEQA Guidelines, a building must be at least 50 years old. In addition, Section 15064.5 defines an historical resource as, “… a resource listed in, or determined to be eligible for listing in, the California Register of Historical Resources,” properties included in a local register of historical resources, or properties deemed significant pursuant to criteria set forth in Public Resources Code Section 5024.1(g). According to CEQA Guidelines Section 15064.5(a)(3), a lead agency can determine that a resource is significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California, provided that the determination is supported by substantial evidence in light of the whole record.

Initial Study 32 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

In order to be eligible for listing in the California Register of Historical Resources, a property must meet at least one of the following criteria: • Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage; • Is associated with the lives of persons important in our past; • Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; • Has yielded, or may be likely to yield, information important in prehistory or history.22

Based on a review of historical records, including historical aerial photographs of the project site, the existing administrative office building was constructed sometime between 1974 and 1982. The northern portion of the large warehouse building was constructed between 1982 and 1993, and the building was expanded to its current size between 1993 and 1998.23 Therefore, the existing structures are less than 50 years old. They are not architecturally distinct, are not associated with historic events or persons, and are not listed on the City’s Historic Resources Inventory.24 Furthermore, the proposed project would not demolish or alter the existing building.

The former Ford Motor Co. Assembly Plant is located immediately to the east of the project site, at 1414 Harbour Way South. This property is a registered City Landmark and is on the National Register of Historic Places (NRHP) and the California Register of Historic Properties (CRHP). In addition, the Filice and Perrelli Cannery, which supplied canned fruit and tomatoes to the military during World War II and is listed as a City Resource on the City of Richmond’s Historic Resources Inventory, is located across from the project site at 1200 Harbour Way South. However, the proposed project would have no effect on either of these historic resources. There is therefore no potential for the proposed project to adversely affect historic resources, either on the project site or at adjacent properties.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to     §15064.5?

Explanation: The San Francisco Bay area was occupied by Native Americans as far back as 3,000 to 4,000 years ago. Recorded archaeological sites in Richmond and the surrounding region indicate that at the time of initial Euroamerican incursion into the project area (circa 1770), the

22 California Resources Agency, CEQA Guidelines, Section 15064.5(a)(3), as amended October 23, 2009. 23 KC Engineering Company, Phase I Environmental Site Assessment of APNs 560-270-059 and -060, Terminal 3, Port of Richmond, 1411 Harbour Way South, Richmond, Contra Costa County, California, September 21, 2015. 24 City of Richmond, Historic Resources Inventory, accessed November 3, 2015 at: http://www.ci.richmond.ca.us/ DocumentCenter/View/5510

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 33

region was occupied by Native Americans who spoke Chochenyo.25 These people were a subset of the Penutian–speaking Bay Miwok (referred to as “Costanoans” by the Spanish) residing in northern California at the time the Spanish arrived in the region.26 The Miwok territory encompassed much of the San Francisco Bay area and extended eastward to the Central Valley.

With the arrival of the Spanish at the turn of the nineteenth century, the Native Americans in the area were either forced from the area or conscripted to work on one of the large “rancherias” established in the region, where many Chochenyo died from overwork and introduced European diseases. By the beginning of the California Gold Rush in 1848, the Costanoan culture, including the Chochenyo subset, no longer survived in the region. Artifacts from the prehistoric occupation of the Bay Area by the Costanoans remain buried throughout the region, particularly in areas proximate to the historic margins of tidal marshlands around what is now San Francisco Bay, and near other water sources and at locations otherwise suitable for human subsistence habitation. Various Native American archaeological sites have been recorded within the City of Richmond, including sites that have been deemed eligible for the NRHP.27

An archival search was conducted by the Northwest Information Center (NWIC) at Sonoma State University, which is part of the California Historical Resources Information System (CHRIS), to evaluate the potential for significant archaeological resources to be present on the project site.28 Because no ground disturbance would be required for the proposed project, the NWIC determined that archival search for pre-historic cultural resources was not warranted, and limited the archival search to a review of buildings and structures. As discussed in Section V(a), above, although an historic property is located about 175 feet east of the project site, there is no potential for the proposed project to adversely affect this resource.

While the possible presence of buried prehistoric cultural materials at the project site cannot be ruled out, any such resources, were they to exist, would not be adversely affected by the proposed project, since no subsurface disturbance would occur. Therefore, the proposed project would have no impact on archeological resources.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Directly or indirectly destroy a unique paleontological resource or site or unique geologic     feature?

Explanation: Paleontological resources are the fossilized remains of vertebrate or invertebrate organisms from prehistoric environments found in geologic strata. They are valued for the information they yield about the history of the earth and its past ecological settings. They are

25 City of Richmond, Honda Port of Entry at the Point Potrero Marine Terminal Draft Environmental Impact Report, State Clearinghouse No. 2008022063, Volume I, July 2008. 26 In anthropological literature, the Costanoans are often referred to as the Ohlone. 27 City of Richmond, Richmond General Plan Update Draft Environmental Impact Report, Section 3.5, Cultural Resources, February 2011. 28 Northwest Information Center, Sonoma State University, Record Search Results for the Proposed Port of Richmond Terminal 3 Log Export Facility, City of Richmond, Contra Costa County, California, NWIC File No. 15-0416, October 8, 2015.

Initial Study 34 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

most typically embedded in sedimentary rock foundations, and may be encountered in surface rock outcroppings or in the subsurface during site grading. There are no rock outcroppings at the project site and there would be no subsurface disturbance required for the proposed project. Therefore, although the potential for paleontological resources to be buried under the project site was not evaluated, there is no potential for the project to adversely affect any such resources that may be present.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Disturb any human remains, including those interred outside of formal cemeteries?    

Explanation: As noted in Section V(b), above, there would be no subsurface disturbance performed as part of the proposed project and, therefore, there is no potential for the project to adversely affect any human remains that might lie buried within the project site.

VI. GEOLOGY AND SOILS — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other     substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.

Explanation: There is no known active earthquake fault located on or near the project site. The nearest seismically active fault is the Hayward-Rodgers Creek fault, located approximately 3.3 miles northeast of the site, while the San Andreas fault lies about 14.4 miles to the southwest.29 There is therefore no potential for fault rupture at the project site.

29 Fugro West, Inc., Geotechnical Study, Port of Richmond Operations and Security Center, Richmond, California, Fugro Project No. 04.B1413007, February 2011.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 35

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact ii) Strong seismic ground shaking?    

Explanation: The San Francisco Bay Area is recognized by geologists and seismologists as one of the most seismically active region in the United States. Similar to most urban locations throughout the Bay Area, the project site is potentially subject to moderate to high seismic ground shaking during an earthquake on one of the major active earthquake faults that transect the region. Major earthquakes have occurred on the Hayward, Calaveras, and San Andreas faults during the past 200 years, and numerous minor earthquakes occur along these faults every year. At least five known earthquakes of Richter magnitude (RM) 6.5, four of them greater than RM 7.0, have occurred within the San Francisco Bay Area within the last 150 years. This includes the great 1908 San Francisco earthquake (moment magnitude 7.8) and the 1989 Loma Prieta earthquake (RM 6.9).

According to a 2014 analysis by the Working Group on California Earthquake Probabilities (WGCEP), an expert panel co-chaired by U.S. Geological Society seismologists, there is a 72 percent probability that an earthquake of magnitude 6.7 or greater will occur in the San Francisco Bay Area in the next 30 years and a 20 percent probability that an RM 7.5 earthquake will occur (starting from 2014).30 The WGCEP estimates there is a 14.3-percent chance of an RM 6.7 quake occurring on the Hayward fault in the next 30 years. It is therefore likely that a major earthquake will be experienced in the region during the life of the project that could produce strong seismic ground shaking at the project site.

A major earthquake on any of the active faults in the region could result in very strong to violent ground shaking. The intensity of earthquake ground motion would depend upon the characteristics of the generating fault, distance of the site to the earthquake epicenter and rupture zone, magnitude and duration of the earthquake, and site-specific geologic conditions. The California Geological Survey’s Interactive Probabilistic Seismic Hazards Ground Motion Interpolator (2008) indicates there is a 2-percent probability that seismic ground shaking will produce a peak horizontal ground acceleration of at least 0.882 g at the site within the next 50 years.31 This represents a large amount of ground movement, but translates to an event that would be expected to occur once every 475 years; it also means there is a 90-percent chance this level of ground motion will not be exceeded in the next 50 years.

Engineers use the estimated peak horizontal ground acceleration to design buildings for larger ground motions than are expected to occur during a 50-year interval in order to maximize a building’s ability to withstand seismic ground shaking that may occur at a project site. However, no new construction is proposed as part of the log export facility project. While there is existing risk of strong seismic shaking at the site, similar to any location in the San Francisco Bay Area, the proposed project would not result in an increase in the risk of seismic shaking or in the potential structural damage that could occur during a strong earthquake on one of the region’s earthquake faults. However, at times when logs were stockpiled on the site, these logs

30 Edward H. Field and Members of the 2014 Working Group on California Earthquake Probabilities, U.S. Geological Survey, California Geological Survey, UCERF3: A New Earthquake Forecast for California’s Complex Fault System, USGS Open File Report 2015-3009, 2015. 31 California Department of Conservation, California Geological, Survey, Probabilistic Seismic Hazard Map Ground Motion Interpolator (2008), accessed September 9, 2015 at: http://www.quake.ca.gov/gmaps/PSHA/psha_interpolator.html.

Initial Study 36 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

could potentially be dislodged during strong seismic shaking that could occur during an earthquake. A collapsing log pile would have the potential to crush workers that could be nearby, killing or maiming them or causing other serious injury. Structural damage could also occur to the Terminal 3 warehouse building from dislodged logs rolling into the building’s east side. A ship berthed at the site could also be damaged by rolling logs. This would be a potentially significant impact.

This potential impact would not be limited to the effects of seismic shaking. Stacked logs are potentially unstable even in the absence of seismic shaking, particularly in the case of logs stacked to a height of 25 feet, as proposed for the Terminal 3 project. Debarked logs are more slippery than logs with the bark left on, and are therefore less stable when stacked. Instability of the stack could be increased during operations to add or remove logs, when the pile could be jostled. Workers climbing on the stacked logs could also potentially dislodge the stack.

Numerous log drivers and logging workers are killed every year, often during log unloading and stacking operations. The National Institute for Occupational Safety and Health (NIOSH) reported that 70 deaths occurred in the logging industry in 2010, resulting in a fatality rate of 73.7 deaths per 100,000 workers that year, more than 21 times the nationwide rate of 3.4 deaths per 100,000 population.32 Workers have been killed climbing on stacks that shifted, unloading trucks, and moving logs. Logs have spilled from trucks where the logs were stacked higher than the vertical standards (stakes) in the truck bed and the chains securing the logs snapped.

While the potential collapse of a log stack or accidental spill of one or more logs could have catastrophic effects, with appropriate engineering and administrative controls, this risk could be minimized to an acceptable level. Accordingly, the following measures are recommended to reduce this impact to a less-than-significant level:

Mitigation Measure GS–1: Prior to commencement of project operations, the project sponsor shall retain the services of a qualified structural engineer to design appropriate and effective engineering controls for stacked logs, such as steel braces, that would prevent logs from rolling. The braces or other structural controls shall be designed to withstand the expected loads and pressures from stacked logs. The engineer shall determine safe stacking heights and angles, and the project sponsor shall adhere strictly to these limits. In no case shall stack angles exceed 45º. During project operations, logs shall not be stacked higher than the steel braces or other structural controls. Maximum log stack height should be determined by the height at which logs can be safely grabbed.

The final plans shall be subject to review and approval by the City of Richmond Building Division of the Planning and Building Services Department. The Building Division shall verify construction of the braces or other engineering controls in accordance with the approved plans prior to the commencement of project operations.

32 National Institute for Occupational Safety and Health (NIOSH), Logging Safety, Accessed November 11, 2015 at: http://www.cdc.gov/niosh/topics/logging/default.html.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 37

project sponsor shall perform the following additional mitigation prior to conducting any subsurface disturbance of the site: a) The project sponsor shall retain the services of a qualified geotechnical engineer or engineering geologist to prepare a design-level geotechnical investigation for purposes of determining whether the subsurface soils can support the proposed structures and identifying project-specific site preparation requirements and/or foundation design features needed to withstand the expected pressures and loads from the fully loaded log containment structure, both under normal conditions and in conditions of strong seismic ground shaking in the event of a large design-level earthquake. The final plans shall incorporate all of the site preparation, foundation design, and structural design recommendations identified by the geotechnical investigation. The final plans shall be subject to review and approval by the City of Richmond Building Division of the Planning and Building Services Department. During construction, all site preparation work shall be performed under the observation of the Geotechnical Engineering firm of record. The Building Division shall field verify implementation of all of the site preparation, foundation design, and structural design features in accordance with the approved plans prior to the commencement of project operations. b) The project sponsor shall retain the services of a qualified archaeologist to evaluate the potential for subsurface disturbance to adversely affect Native American or historic cultural resources that could lie buried beneath the site. The results of the cultural resources evaluation shall be documented in a report submitted to the City of Richmond Planning Division. Any recommendations in the report for further evaluation or for mitigation measures to document and prevent any significant adverse effects on the resource(s) shall be implemented prior to the initiation of subsurface work. c) The project sponsor shall develop and implement a work plan for remediating any residual petroleum hydrocarbon contamination in the site’s subsurface soils and/or groundwater (discussed in Section VIII(b) of this Initial Study) in consultation the Contra Costa County Health Services Department and/or the San Francisco Bay Regional Water Quality Control Board, as applicable. The project sponsor shall obtain written clearance from these agencies prior to initiating subsurface work for the proposed project, and shall provide a copy of the clearance(s) to the City of Richmond Planning Division.

Initial Study 38 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

Mitigation Measure GS–3: Prior to commencement of project operations, the project sponsor shall prepare and implement a worker training and safety program in accordance with guidelines published by the Occupational Safety and Health Administration (OSHA). The training and safety program shall evaluate all tasks performed by workers, identify all potential hazards, and then develop, implement, and enforce a written safety and health program that meets applicable OSHA standards and addresses these hazards. A comprehensive written occupational safety and health program must be developed for all workers and include training in hazard recognition, avoidance of unsafe conditions, safe performance of assigned tasks, and safe use and maintenance of tools or equipment. Hazards to be addressed should include the potential for rolling logs, worker falls from log stacks, the potential for a front-end loader to tip over, and other hazards associated with operating front-end loaders.

The operator shall comply with all applicable Occupational Safety and Health Administration (OSHA) log unloading regulations stipulated for the logging industry in Code of Federal Regulations (CFR) Chapter 29, Part 1910.266, and the procedures promulgated therein shall be incorporated into the worker training and safety program.

The project sponsor shall train each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to their work environment to control or eliminate any hazards or other exposure to injury or illness. The safety program shall include the following provisions, among others: • Safety procedures shall be established for log handling and movement, including ensuring other employees are not within a safe clearance area around the operations. • Transport vehicles shall be positioned to provide working clearance between the vehicle and the deck. • Only essential personnel shall be allowed in the loading/unloading work area. • No transport vehicle operator shall remain in the truck cab during loading and unloading if logs are moved over the truck cab.

Mitigation Measure GS–4: All new employees shall undergo training prior to performing work; existing employees shall undergo training prior to being assigned new work tasks or use of new tools, equipment, machines, or vehicles. Any employee who exhibits unsafe job performance shall undergo retraining in the appropriate health and safety provisions and procedures. The site operator shall be responsible for ensuring that each current and new employee can properly and safely perform the work tasks and operate the tools, equipment, machines, and vehicles used in their job. New employees and employees undergoing retraining shall work

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 39

under the close supervision of a designated person until the employee demonstrates to the employer the ability to safely perform their new duties independently.

The project sponsor shall ensure that the trainer who provides employee training is qualified through education and/or experience to conduct training.

The site operator shall document the names and dates of employees completing the training program and shall retain the training records on site.

Mitigation Measure GS–5: The employer shall ensure that each employee, including supervisors, receives or has received first-aid and CPR training meeting at least the requirements specified in 29 CFR 1910.266 Appendix B. The employer shall assure that each employee's first-aid and CPR training and/or certificate of training remain current. A first-aid kit shall be maintained on site at all times and shall contain, at a minimum, all of the contents listed in 29 CFR 1910.266 Appendix A.

Mitigation Measure GS–6: The front loader used for moving and stacking logs shall be equipped with a falling object protective structure (FOPS) that is tested, installed, and maintained in accordance with the Society of Automotive Engineers SAE J231 (January 1981) Minimum Performance Criteria for Falling Object Protective Structures (FOPS). The debarking machine shall be equipped with guarding to protect employees from flying wood chunks, chips, bark, and other materials and the guarding shall be in place at all times the machine is in operation. Workers shall wear appropriate personal protection, including steel-toed boots, hard hats, work gloves, and eye protection.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact iii) Seismic-related ground failure, including liquefaction?    

Explanation: Liquefaction occurs when clean, loose, saturated, uniformly graded, fine-grained soils are exposed to strong seismic ground shaking. The soils temporarily lose strength and cohesion due to buildup of excess pore water pressure during earthquake-induced cyclic loading, resulting in a loss of ground stability that can cause building foundations to fail. Soil liquefaction may also damage roads, pavements, pipelines, and underground cables. Soils susceptible to liquefaction include saturated, loose to medium dense sand and gravel, low- plasticity silt, and some low-plasticity clay deposits.

Initial Study 40 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

The project site is mapped by the U.S. Geological Survey as having a high potential for liquefaction.33 However, this is a pre-existing condition at the site that the proposed project would not alter. No new construction is proposed that could be adversely affected by soil liquefaction. As noted above in Section VI(a)(ii), if the engineering controls stipulated in Mitigation Measure GS–1 would require subsurface disturbance, then the project sponsor will required as part of Mitigation Measure GS–2 to conduct a geotechnical investigation for purposes of determining whether the subsurface soils can support the proposed structures and identifying project-specific site preparation requirements and/or foundation design features needed to withstand the expected pressures and loads from the fully loaded log containment structure. As currently proposed, the project would not increase the hazard related to seismic- related ground failure, including liquefaction.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact iv) Landslides?    

Explanation: The project site is virtually level, and the area surrounding the site is also level, with similar to identical elevations to those on the project site. There are no slopes on or anywhere near the project site. There is therefore no potential for landslide at the site.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Result in substantial soil erosion or the loss of topsoil?    

Explanation: The proposed project would occur on a level site that is fully developed with impervious surfaces including buildings and pavements. The project would not expose surface soils, and therefore would not create any potential for erosion from wind and stormwater runoff.

33 U.S. Department of Interior, U.S. Geological Survey, Preliminary Maps of Quaternary Deposits and Liquefaction Susceptibility, Nine-County San Francisco Bay Region, California, Open File Report 00-444, 2000.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 41

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site     landslide, lateral spreading, subsidence, liquefaction, or collapse?

Explanation: The proposed project would not construct new structures on the site. The project therefore has no potential to increase the hazard related to unstable subsurface conditions.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994),     creating substantial risks to life or property?

Explanation: The proposed project would not construct new structures on the site. The project therefore has no potential to increase the hazard related to expansive soils.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the     disposal of wastewater?

Explanation: The project site is served by a municipal sewer system, and the proposed project would not require the use of a septic or alternative wastewater disposal system.

Initial Study 42 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

VII. GREENHOUSE GAS EMISSIONS — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the     environment?

Explanation: The California Air Resources Board’s (CARB) OFFROAD34 and EMFAC201435 emissions inventory models were used to quantify greenhouse gas (GHG) emissions associated with operational activities of the proposed project. The U.S Environmental Protection Agency’s (USEPA) Current Methodologies in Preparing Mobile Source Port-Related Emissions was used to estimate GHG emissions from marine vessel (bulk carriers) and harbor craft operations.36 GHG emissions would be generated primarily by operation of onsite off-road equipment (such as excavators and loaders), marine vessels, harbor craft, haul trucks, (primarily diesel-operated), and worker automobile trips (primarily gasoline-operated). Air quality calculations and assumptions are described in Appendix AQ–2. The setting and regulatory context for GHG emissions and climate change are described in Appendix AQ–4.

As previously discussed in Section III, logging trucks would begin at a site in West Sacramento, which is within the Yolo-Solano Air Quality Management District (YSAQMD). Approximately half way to the proposed facility, logging trucks would cross over into the Bay Area Air Quality Management District (BAAQMD). Log truck trip lengths were estimated to be 148 miles per round trip (80 miles within BAAQMD and 68 miles within YSAQMD). Within EMFAC2014, the log trucks were classified as T7 tractor trucks. Logs arriving with bark still on would be debarked and removed bark would be picked up in 25-ton semi-trailer trucks and dropped off to end markets in the Bay Area. Within EMFAC2014, the bark trucks were also classified as T7 tractor trucks.

Log export shipments would occur during the timber harvesting season in California, which starts in April and continues through November. With six shipments anticipated each year, there would be an estimated one shipment each five weeks. While in dock, the ships would be connected to shoreline electrical power and the ship’s engines would not be idled; thus, eliminating auxiliary engine emissions associated with hoteling at the berth.37 Marine vessel GHG emissions were quantified within California waters (to a distance of approximately 12

34 California Air Resources Board, OFFROAD Instructions, http://www.arb.ca.gov/msprog/ordiesel/info_1085/oei_write_up.pdf. 35 California Air Resources Board, EMFAC User’s Guide, December 30, 2014, http://www.arb.ca.gov/msei/emfac2014_users_guide.pdf. 36 US Environmental Protection Agency, Current Methodologies in Preparing Mobile Source Port-Related Emissions, April 2009, http://trid.trb.org/view.aspx?id=927750 37 Reduces annual GHG emissions by 46 metric tons.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 43

miles from Golden Gate).38 Operational equipment at the proposed project would include an excavator, front loader with claws, street sweeper, and an electric powered debarker.

The YSAQMD currently does not have an adopted or recommended GHG threshold of significance. Only log truck operations occur within YSAQMD. The estimated annual GHG emissions in the YSAQMD from the proposed project would be approximately 250 metric tons of carbon dioxide equivalent (CO2e) per year.

Estimated annual GHG emissions associated with the proposed project that would occur within the BAAQMD are presented in Table GH–1 and are compared to BAAQMD’s GHG significance threshold. The BAAQMD has an adopted operational GHG significance threshold of 1,100 metric tons of CO2e per year.

Table GH–1 Estimated Annual Greenhouse Gas Emissions in the BAAQMD

Source Annual CO2e Metric Tons

Onsite Equipment 162 Marine Vessels 86.2 Harbor Craft 12.9 Log Trucks 294 Bark Trucks 12.2 Worker Automobiles 21.6 Total Emissions 589 BAAQMD Significance Threshold 1,100 Potentially Significant? No

Source: CARB OFFROAD 2011,CARB EMFAC2014

Note: See Appendix AQ–2 for air quality calculations and assumptions.

As shown in Table GH–1, the estimated GHG emissions in the BAAQMD from the proposed project would be approximately 589 metric tons of CO2e per year, which is below the BAAQMD’s significance threshold of 1,100 metric tons of CO2e per year. Thus, the proposed project would have a less-than-significant impact from GHG emissions in the BAAQMD. Even with the addition of the GHG emissions that would occur within the YSAQMD (250 metric tons), the total GHG emissions of 839 metric tons would be below the significance threshold of

1,100 metric tons of CO2e per year.

38 According to BAAQMD, emissions from water travel occurring entirely within the local government’s geographic boundary should be included. Emissions from water travel occurring outside the geographic boundaries of the community (such as with sea travel) should not be included.

Initial Study 44 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

According to the proposed project design and methodology assumptions, the estimated marine vessel and harbor craft fuel usage within California waters would be approximately 9,340 gallons. The estimated fuel usage for truck trips would be 56,600 gallons. The estimated fuel usage for onsite equipment would be 15,900 gallons.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of     greenhouse gases?

Explanation: The City of Richmond is developing a Climate Action Plan (CAP) intended to reduce GHG emissions in the City.39 The CAP will be a roadmap for how the City will reduce energy consumption and GHG emissions to meet State GHG emissions targets established by Assembly Bill 32 (AB 32), which is the principal planning and policy document adopted for the purpose of reducing GHG emissions Statewide. The quantitative goal of AB 32 is to reduce GHG emissions to 1990 levels by 2020. Statewide plans and regulations such as GHG emissions standards for vehicles and the low carbon fuel standard are being implemented at the Statewide level, and compliance at the specific plan or project level is not addressed. The assumption is that AB 32 will be successful in reducing GHG emissions and reducing the cumulative GHG emissions Statewide by 2020. The State has taken these measures, because no project individually could have a major impact (either positively or negatively) on the global concentration of GHGs. Therefore, the proposed project would result in a significant impact if it would be in conflict with AB 32 State goals. The proposed project was reviewed relative to the AB 32 measures and it was determined that the proposed project would not conflict with the goals of AB 32.

39 City of Richmond. Climate Action Plan. http://www.richmondclimateaction.org/

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 45

VIII. HAZARDS AND HAZARDOUS MATERIALS — Would the project:

The proposed project would have a potentially significant health and safety impact that is not addressed by the standard CEQA Initial Study Environmental Checklist. The handling and movement of large logs and the creation of large stacks of stored logs that could be unstable are potentially hazardous to the health and safety of workers on the site. Please see Section VI(a)(ii) for further discussion of the potential impact and appropriate mitigation requirements.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Create a significant hazard to the public or the environment through the routine transport, use, or     disposal of hazardous materials?

Explanation: The proposed project would not involve the routine transport, use, or disposal of hazardous materials. Fuels for trucks and equipment would be purchased at licensed off-site dispensaries. No fuel or other hazardous substances would be stored or used on the site in quantities requiring permitting; there would just be small, containerized quantities of fluids typically used for vehicle and equipment maintenance.40, 41 Therefore, there is no potential for the project to create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of     hazardous materials into the environment?

Explanation:

Phase I Environmental Site Assessment A Phase I Environmental Site Assessment (ESA) of the project site was performed by KC Engineering Company in September 2015.42 The purpose of the ESA was to identify recognized environmental conditions on the project site, including the presence or likely presence of any hazardous substances that could create a significant hazard to the public or the environment,

40 Richard Lyu, President, RJJ Resource Management Corp., personal communication, November 10, 2015. 41 Eric Mendoza-Govan, Fire Inspector, Richmond Fire Department, personal communication, January 26, 2016. 42 Stantec Consulting Services, Inc., Op. Cit.

Initial Study 46 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

whether through an existing release, past release, or threat of a release into structures, into the ground, or into surface or groundwater.

The Phase I ESA included a review of publicly available local, State, and federal environmental databases; historical topographic maps from 1895 through 1995; aerial photographs from 1939 through 2012; fire insurance maps dated 1930 to 1970; City directories spanning 1980 to 2013; and other City and County records. KC Engineering also conducted a reconnaissance of the property and an interview with the current occupant of the property regarding his knowledge of the site history and conditions.

Regulatory Database Records As part of the records search, 111 federal, State, local, tribal, and proprietary databases were reviewed by Environmental Data Resources, Inc. (EDR). The project site was identified on numerous databases, including: the Resource, Conservation, and Recovery Act (RCRA) Small Quantity Generator (SQG) database; Emergency Response Notification System (ERNS) database; Leaking Underground Storage Tank (LUST) database; Spills, Leaks, Investigations and Cleanup (SLIC) database; Statewide Environmental Evaluation and Planning System (SWEEPS UST) database; Hazardous Substance Storage Container (HIST UST) database; CA Facility Inventory Database (FID UST) database; CA Hazardous Material Incident Report System (CHMIRS) database; Facility Index System (FINDS) database; HAZNET database; Hazardous Waste and Substance Site List (HIST CORTESE) database; National Pollutant Discharge Elimination System (NPDES) database; Contra Costa County Site List database; and Waste Discharge System (WDS) database. The property address of 1411 Harbour Way South is listed under the names of: The Alecto/Hull #710546; Stevedoring Services of America; South Seas Steamship Co.; Richmond Multi-Terminals; Terminal 3 City of Richmond; Octopus IMO#1007213; Pacific Battleship Center – USS Iowa; Pacific IMO#996165; Metropolitan CA; and Port of Richmond.

The project site is listed by the Contra Costa County Environmental Health Department as an inactive Underground Storage Tank (UST) facility and as an inactive hazardous waste generator site. A 10,000-gallon diesel UST and a 1,650-gallon gasoline UST were installed on the property in 1978; both were removed in September 1998 under the oversight of the San Francisco Bay Regional Water Quality Control Board (RWQCB). Soil and groundwater samples collected from the area of the former USTs determined that the groundwater was contaminated with elevated levels of petroleum hydrocarbons, including total petroleum hydrocarbons as diesel (TPHd), total petroleum hydrocarbons as gasoline (TPHg), benzene, toluene, ethylbenzene, xylenes, and methyl tertiary butyl ether (MTBE). Although the Phase I ESA does not report on whether any site remediation activities were implemented, it does note that additional soil and groundwater samples were collected from the area of the former UST pit in September 2007 and, based on the laboratory results, the case eventually received regulatory closure from the San Francisco Bay RWQCB in 2010.

The RWQCB closure report notes that the pollutants had attenuated to non-detectable levels in the soil and to low or non-detectable levels in the groundwater, and states that the site does not represent a significant risk to public health, the environment, or water resources. However, the closure summary does state that “there may be residual contamination in both soil and groundwater at the site that could pose an unacceptable risk under certain development activities such as site grading, excavation, or installation of water wells.” Absent this type of changes to use of the property, the RWQCB closure report stated that no corrective action was necessary. Since the proposed project would not require any grading, excavation, or installation of water wells, no further investigation or remediation of potential contamination of soil and/or groundwater at the site is warranted.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 47

With respect to the other regulatory database listings of the property, the Phase I ESA noted that no institutional controls or engineering controls were identified for the site, and concluded that there were no unmitigated, historical, or controlled recognized environmental conditions (RECs) present on the site, and no further environmental investigation of the property was recommended.

Off-Site Hazardous Materials Sites The regulatory database search identified 43 offsite hazardous materials use, storage, disposal, or release sites within the applicable search radius (0.25 mile to 1 mile) from the project site. Twenty-five (25) of the 43 sites were identified as having had a reported spill or release of hazardous materials. The Phase I ESA determined that the 18 hazardous materials use, storage, or disposal sites where no spill or release of hazardous materials has been reported are not considered a recognized environmental condition (REC) for the project site. Of the 25 identified hazardous materials release sites, 20 of them have received regulatory agency closure, and are therefore not considered a REC for the project site. The five release sites that have not received regulatory agency closure are discussed below:

1. United Heckathorn Company, located at South 8th Street and Wright Avenue, is identified on several databases including the National Priorities List (NPL) database. The United Heckathorn site was used from approximately 1947 to 1966 to formulate and package pesticides including DDT. Various solvents were used to dissolve DDT and other pesticides into liquid formulations. Contaminated soil and groundwater were identified at this site, as well as contaminated wastewater that was discharged into Lauritzen Channel. The former processing facilities have been demolished and the area has been capped. Contaminated soils have been excavated and removed from this site. At its closest point, the contamination plume from this site is located approximately 0.25-mile north of the subject property. Based on the distance of this site from the property, and the reported groundwater flow direction beneath the property (west), the Phase I ESA concluded that this site is not considered a REC for the subject property.

2. Richmond Bulk Terminal, located approximately 0.25-mile west of the property at 1306 Canal Boulevard, is identified as an open remediation site on the SLIC database. Harbor Channel is located between this site and the subject property, and therefore the Phase I ESA concluded that this site is not considered a REC for the subject property.

3. Unocal Richmond Terminal, located approximately 0.35-mile west of the property at 1300 Canal Boulevard, is identified as an open remediation site on the SLIC database. Harbor Channel is located between this site and the subject property, and the Phase I ESA concluded that therefore this site is not considered a REC for the subject property.

4. Time Oil Company/Shore Terminals Mart, located approximately 0.35-mile northwest of the property at 488 Wright Avenue, is identified as an open site on the SLIC database. Verification monitoring is ongoing at this facility. Based on the distance of this site from the subject property, and the reported groundwater flow direction beneath the property (west), the Phase I ESA concluded that it is not considered a REC for the subject property.

5. Sun Oil Company Tank, located approximately 0.45-mile north of the property at 810 Wright Avenue, is identified as an open remediation site on the SLIC database. Based on the distance of this site from the subject property, and the reported

Initial Study 48 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

groundwater flow direction beneath the property (west), the Phase I ESA concluded that it is not considered a REC for the subject property.

Historical Use of the Site Based on a review of historical topographic maps, aerial photos, fire insurance maps, and City directories, development on the project site dates at least to 1930, when the northwest portion of the site was occupied by a large building identified as Parr-Richmond Inner Harbor Terminal, Municipal Wharf No. 3. Scott Avenue was located on the central portion of the site, which was bordered on the east by South 10th Street. By 1946, four small buildings had been added to the site south of Scott Avenue; a storage yard was also on the southern portion of the site. Harbour Way South adjoined the property to the east, although Sanborn fire insurance maps continued to identify it as 10th Street. Two railroad spurs were located in the north half of the site, on either side of the large warehouse. These spurs appeared to be no longer present at the time a 1958 aerial photograph of the site was taken, nor do they appear on subsequent aerial photos, though they are depicted on all historical topographic maps of the area from 1949 on. (No railroad spurs are currently present on the site.)

Two warehouses had been added to the property by 1968, one east and one southeast of the original warehouse building, while the remainder of the site was used for parking and storage. By 1982, all of the buildings previously on the site had been removed and a new office building, extant today, had been added to the southeast portion of the site. Four large cranes had been installed in the northwest portion of the site. The remainder of the site was paved and used for storage of shipping containers. The aerial photo from 1993 as well as the 1993 USGS topo map both show a warehouse building added to the northeast edge of the site. This building had been enlarged to its current size by 1998 by an addition to the southern end of the warehouse. Two of the cranes present in 1982 had been removed. By 1998, the site appeared largely as it does today.

Based on the review of historic maps and other records, the Phase I ESA determined that no obvious RECs are present on the site. It also noted that no significant data gaps or failures hindered the environmental assessment.

Environmental Conditions on the Site During the reconnaissance of the project site, KC Engineering observed no improper drainage discharge from the site and no evidence of USTs or other subsurface structures other than common utilities (sewer and storm drains). KC Engineering also found no evidence of electrical or hydraulic equipment on the site with the potential to contain polychlorinated biphenyls (PCBs). Nine metal grates identified as “deep well” were observed on the western portion of the site, but their purpose was unknown. Utility pole-mounted transformers that would be unaffected by the proposed project were observed along Harbour Way South.

The Phase I ESA found no evidence of use, storage, or disposal of regulated quantities of hazardous materials on the site, including petroleum products, and no above-ground storage tanks (ASTs). No obvious wastewater discharge was observed on the property, nor were elevators, sumps, basements, hoists, or hydraulic lifts were observed. There were no stained soils; stained pavement; discolored water; stressed vegetation; or strong, pungent, or noxious odors noticeable on the property during the site reconnaissance conducted as part of the Phase I ESA. Nor were standing surface waters—including pits, ponds, and lagoons—observed on the property. Several storm drains are located on the property that discharge onto adjacent parcels, streets, and into the adjoining channel.

Conclusions

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 49

The Phase I ESA found no evidence on the project site of unmitigated RECs, historical RECs, or controlled RECs. While it noted that residual subsurface contamination may remain in the north end of the site in the vicinity of the former USTs, the proposed project would not expose workers to potential safety hazards from exposure to residual contaminants because the project would not entail any subsurface disturbance. As noted above, the soil and groundwater contamination with petroleum hydrocarbons received regulatory case closure from the San Francisco Bay RWQCB in 2010.

If any future changes in land use or other activities were proposed for the site, the Contra Costa County Health Services Department should be notified and an appropriate work plan approved by that agency. However, for the proposed log processing and export facility, the Phase I ESA concluded that no further environmental investigation or remediation of the site is warranted.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed     school?

Explanation: Benito Juarez Elementary School, at 1450 Marina Way South, is located approximately one-quarter mile east of the project site. However, the proposed project would not emit hazardous emissions, handle hazardous materials, or generate hazardous waste. There would be no project impact on schools related to hazardous materials.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result,     would it create a significant hazard to the public or the environment?

Explanation: As discussed in more detail in Section VIII(b), above, the Phase I ESA performed for the project included a search of multiple federal and State agency databases for hazardous materials release sites, hazardous materials use and storage sites, or hazardous waste generation, including those compiled pursuant to Government Code Section 65962.5. Although the project site is listed on numerous regulatory databases due to historical storage of hazardous materials and leaking underground storage tanks, there are no current hazards on the site related to hazardous materials. Please see Section VIII(b) for additional information.

Initial Study 50 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact e) For a project within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would     the project result in a safety hazard for people residing or working in the project area?

Explanation: There are no airports within 2 miles of the project site; the nearest public airport is Oakland International Airport, in the City of Oakland, located approximately 15 miles southeast of the site.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact f) For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people     residing or working in the project area?

Explanation: There are no private airstrips in the vicinity of the project site. The nearest private airstrip is San Rafael Airport, formerly Smith Ranch Airport, located about 11 miles northwest of the project site.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact g) Impair implementation of or physically interfere with an adopted emergency response plan or emergency     evacuation plan?

Explanation: In the event of a large-scale disaster, emergency response to the site would be coordinated by City responders with other response in the City. With two entrance gates, the site currently provides adequate emergency access and egress. Implementation of the project would not alter existing streets or otherwise interfere with emergency evacuation routes. There is therefore no potential for the project to impair implementation of emergency evacuation or emergency response plans

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 51

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact h) Expose people or structures to significant risk of loss, injury, or death involving wildland fires, including where wildlands are adjacent to urbanized areas or     where residences are intermixed with wildlands?

Explanation: The project is located in a fully built-out area with industrial, light industrial, and institutional development in the vicinity of the site. There are no wildlands in the project area, and therefore there is no potential for the proposed project to result in the exposure of people or structures to wildland fires.

IX. HYDROLOGY AND WATER QUALITY — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Violate any water quality standards or waste discharge requirements?    

Explanation:

Pollution Potential Urban development has a high potential to adversely affect water quality in surface water bodies, due to the concentration and characteristics of water pollution sources in the urban environment. The most widespread and pervasive source of pollutants is from trucks, automobiles, off-road construction equipment, and other vehicles. These vehicles can deposit oil and grease, fuel residues, heavy metals (e.g. lead, copper, cadmium, and zinc), tire particles, and other pollutants onto roadways and parking areas. The contaminants can be washed by stormwater runoff into storm drains that ultimately discharge to surface waterways, degrading water quality in the receiving water bodies that may be used for swimming, fishing, drinking water, and other beneficial uses. Polluted urban stormwater runoff can cause changes in hydrology and water quality that result in habitat modification and loss, increased flooding, decreased aquatic biological diversity, increased sedimentation and erosion, and potential adverse effects on human health and safety.

Due to its location adjacent to the Richmond Inner Harbor, the project site has a direct pathway for releasing pollutants into San Francisco Bay, which is on the list of impaired water bodies compiled by the San Francisco Bay Regional Water Quality Control Board (RWQCB) pursuant to Section 303(d) of the federal Clean Water Act (CWA). It is listed as impaired for a wide range of pollutants, including chlordane, dichloro-diphenyl-trichloroethane (DDT), dieldrin, dioxin

Initial Study 52 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

compounds, polychlorinated biphenyls (PCBs), mercury, selenium, furan compounds, and trash.43

Industrial properties can be significant sources of water quality pollutants, both from the direct discharge of effluents as well as from surface runoff and emissions of air pollutants that subsequently get washed out of the atmosphere by rainfall. Other common sources of water pollutants are vehicle fueling areas common at many industrial sites, where spills can occur during delivery and when topping off fuel tanks, leaks can occur from leaking storage tanks, and uncontrolled discharge can result from hosing down the fuel area and from rainfall running off from the fuel area. Some of the industries that have a significant potential to adversely affect water quality include cement, fertilizer, petroleum, and phosphate manufacturing; coal and mineral mining; roofing and paving with tars and asphalt; landfills; and airport de-icing. Marine port operations are typically treated as industrial land uses for purposes of regulating discharges to surface waters.

Regulatory Framework Protection of surface water quality is regulated by the U.S. Environmental Protection Agency (EPA) pursuant to the federal Clean Water Act (CWA), which prohibits certain discharges of stormwater containing pollutants except in compliance with a National Pollutant Discharge Elimination System (NPDES) permit. The NPDES stormwater program regulates some stormwater discharges from three potential sources: municipal separate storm sewer systems (MS4s), construction activities, and industrial activities. The NPDES permitting program establishes discharge limits and conditions for industrial and commercial sources with specific limitations based on the type of facility/activity generating the discharge.

In California, the EPA has authorized the State Water Resources Control Board (SWRCB) to administer the NPDES industrial stormwater permitting program. On April 1, 2014 the SWRCB adopted the NPDES General Permit for Stormwater Discharges Associated with Industrial Activities (NPDES Permit No. CAS000001), which became effective on July 1, 2015. The permit replaced the previous permit, issued under Water Quality Order 97-03-DWQ by the SWRCB on April 17, 1997. In the San Francisco Bay Area, the permit is enforced by the RWQCB. Among other changes, the new permit requires dischargers to implement a set of minimum Best Management Practices (BMPs) intended to prevent or reduce pollutants in industrial stormwater discharges. The minimum BMPs are primarily non-structural BMPs, but they also include advanced structural BMPs, consisting of treatment controls, exposure reduction, and stormwater containment BMPs. The minimum and advanced BMPs required in the Industrial General Permit are consistent with the EPA’s 2008 Multi-Sector General Permit for Stormwater Discharges Associated with Industrial Activity (2008 MSGP), guidance developed by the California Stormwater Quality Association, and recommendations by RWQCB inspectors.

The required BMPs include: Minimization of Exposure to Storm Water; Good Housekeeping; Preventive Maintenance; Spill and Leak Prevention and Response; Erosion and Sediments Controls; Management of Runoff; Salt Storage Piles or Piles Containing Salt; Sector Specific Non-Numeric Effluent Limits; Employee Training Program; Non-Stormwater Waste Discharges (NSWDs); Material Handling and Waste Management; Waste, Garbage and Floatable Debris; Dust Generation and Vehicle Tracking of Industrial Materials; and more. All of these BMPs are described/defined in the permit.

43 San Francisco Bay Regional Water Quality Control Board, Final 2010 Integrated Report (CWA Section 303(d) List/305(b) Report), Category 5 2010 California 303(d) List of Water Quality Limited Segments, USEPA Final Approval October 11, 2011, accessed December 10, 2015 at: http://www.waterboards.ca.gov/water_issues/programs/tmdl/2010state_ir_reports/category5_report.shtml.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 53

The NPDES Industrial General Permit (IGP) also requires implementation of Best Available Technology Economically Achievable (BAT) and Best Conventional Pollutant Control Technology (BCT) to reduce or eliminate pollutants in stormwater discharges and authorized non-storm water discharges (NSWDs). Section 402(p)(3)(A) of the CWA also requires discharges covered by the IGP to include requirements necessary to meet water quality standards. The IGP does not cover discharges from construction and land disturbance activities, which require separate application for and coverage under the RWQCB’s NPDES Construction General Permit.

Obtaining Coverage Under the NPDES Industrial General Permit Certain categories of industrial activities are required to obtain coverage under the IGP; there are 11 general categories that are further defined according to the Standard Industrial Classification (SIC) code. The codes are applicable to all primary activities and auxiliary functions at any facility. A number of SIC codes appear to apply to the proposed project, all of which fall under the umbrella category of Water Transportation (SIC Code 44). These include Deep Sea Foreign Transportation of Freight (SIC Code 4412), Marine Cargo Handling (SIC Code 4491), and a variety of subcategories. The RWQCB has confirmed that SIC Code 4491 would apply to the proposed project, which would require coverage under the Industrial General Permit.44

New Dischargers applying for coverage under the IGP that will be discharging to an impaired water body with a 303(d) listed impairment are ineligible for coverage unless the Discharger submits data and/or information, prepared by a Qualified Industrial Storm Water Practitioner (QISP), demonstrating that the facility will not cause or contribute to the impairment. The QISP must demonstrate one of the following: 1. The Discharger has eliminated all exposure to storm water of the pollutant(s) for which the water body is impaired, has documented the procedures taken to prevent exposure onsite, and has retained such documentation with the SWPPP at the facility; 2. The pollutant for which the water body is impaired is not present at the Discharger’s facility, and the Discharger has retained documentation of this finding with the SWPPP at the facility; or 3. The discharge of any listed pollutant will not cause or contribute to an exceedance of a water quality standard. This is demonstrated if: (1) the discharge complies with water quality standards at the point of discharge, or (2) if there are sufficient remaining waste load allocations in an approved Total Maximum Daily Load (TMDL) and the discharge is controlled at least as stringently as similar discharges subject to that TMDL.

The IGP requires that all Dischargers to develop, implement, and retain onsite a site-specific Stormwater Pollution Prevention Plan (SWPPP). The SWPPP requirements generally follow EPA’s five-phase approach to developing SWPPPs, with modifications to reflect the requirements of the IGP. The approach provides the flexibility necessary to establish appropriate BMPs for different industrial activities and pollutant sources. The SWPPP must include a site map, authorized NSWDs at the facility, and an identification and assessment of potential pollutants sources resulting from exposure of industrial activities to stormwater. The SWPPP must clearly describe the BMPs that are being implemented, who is responsible for the BMPs, where the BMPs will be installed, and when and how often the BMPs will be implemented.

44 Michelle Rembaum-Fox, QSP, Engineering Geologist, California Regional Water Quality Control Board, San Francisco Bay Region, personal communication, November 19, 2015.

Initial Study 54 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

The SWPPP must also provide for training of employees for the Pollution Prevention Team responsible for implementing and monitoring the SWPPP and BMPs, record keeping, monitoring, and an annual evaluation. The monitoring requirements are quite detailed and prescribed, and must occur during at least four annual Qualifying Storm Events (QSEs) that are defined by the permit, unless there are fewer than four QSEs during the monitoring period. A detailed Monitoring Implementation Plan must be included in the SWPPP.

In order to obtain coverage under the Industrial General Permit, a Discharger must prepare, certify, and electronically file Permit Registration Documents (PRDs) via the SWRCB’s Storm Water Multiple Application and Report Tracking System (SMARTS), which include a Notice of Intent (NOI), a risk assessment, site map, signed certification, Stormwater Pollution Prevention Plan (SWPPP), and other site-specific PRDs that may be required.

Exemption From Coverage Under the NPDES Industrial General Permit Entities that operate facilities generating stormwater associated with industrial activities that is not discharged to waters of the United States are not required to obtain Industrial General Permit coverage. In addition, some Dischargers may file a claim of “No Discharge” in order to obtain an exemption from the majority of the IGP requirements. The IGP applies EPA Phase II regulations regarding a conditional exclusion for facilities that have no exposure of industrial activities and materials to stormwater.45

Any type of industry can claim a conditional exclusion by filing a Notice of Non-Applicability (NONA). The Discharger must submit and certify in SMARTS a NONA Technical Report that contains the analysis and details of the containment design supporting the “No Discharge” eligibility determination. Because containment design will require hydraulic calculations, soil permeability analysis, soil stability calculations, appropriate safety factor consideration, and the application of other general engineering principles, State law requires the technical report to be signed with a wet signature and license number by a California licensed professional engineer. The No Exposure Certification (NEC) requires enrollment for coverage before a Discharger can be excluded from the majority of the Industrial General Permit requirements.

Additional Requirements for Port Facilities The California Ocean Plan was adopted by the SWRCB on October 16, 2012 for purposes of protecting water quality and marine communities in all near coastal ocean waters. Effective as of August 19, 2013, the Ocean Plan prohibits the discharge of waste to Areas of Special Biological Significance (ASBS). ASBSs are defined in the California Ocean Plan as “those areas designated by the SWRCB as ocean areas requiring protection of species or biological communities to the extent that alteration of natural water quality is undesirable.”

For discharges related to waterfront and marine operations, Dischargers must develop a Waterfront and Marine Operations Management Plan (Waterfront Plan) that identifies appropriate management measures and practices to reduce or eliminate non-point source pollutant discharges to the affected ASBS. These include any waste discharges associated with the operation and maintenance of vessels, moorings, piers, launch ramps, and cleaning stations. The requirements are intended to ensure that beneficial uses are protected and natural water quality is maintained in the affected ASBS.

The California Ocean Plan does not apply to enclosed bays or estuaries meeting certain criteria. It does not apply to San Francisco Bay and, therefore, the proposed project would not be required to prepare a Waterfront Plan.

45 40 C.F.R. § 122.26(g).

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 55

Regulation of Vessel Discharges Pursuant to the federal Clean Water Act, the EPA regulates discharges incidental to the normal operation of vessels via a Vessel General Permit (VGP), which is applicable to non-recreational ships operating in Waters of the U.S., including the territorial seas that extend 3 miles outward from the U.S. coastline. The EPA also administers a streamlined Small Vessel General Permit (sVGP) that applies to commercial vessels less than 79 feet in length. The Handymax class vessels that would be used for the proposed project would be subject to the VGP. The VGP was initially issued in December 2008 and expired on December 19, 2013, when the current VGP became effective. The current permit will expire on December 19, 2018. EPA estimates that the domestic vessel population subject to the VGP is approximately 60,000 vessels, and another 12,400 foreign flagged vessels are also subject to the VGP requirements.

The VGP is an NPDES permit issued under EPA’s regulatory authority under Section 402 of the CWA. It applies to vessels operating in a capacity as a means of transportation, including commercial fishing vessels, cruise ships, ferries, barges, mobile offshore drilling units, oil and petroleum tankers, bulk carriers, cargo ships, container ships, other cargo freighters, refrigerant ships, research vessels, emergency response vessels, including firefighting and police vessels, and any other vessels operating in a capacity as a means of transportation. Vessels of the Armed Forces of the United States are not covered by the permit.

The VGP establishes effluent limitations to control a variety of materials that fall into the following categories: Aquatic Nuisance Species (ANS), nutrients, pathogens (including E. coli & fecal coliform), oil and grease, metals, most conventional pollutants (Biochemical Oxygen Demand, pH, Total Suspended Solids), and other toxic and non-conventional pollutants with toxic effects. EPA has established effluent limitations to control these materials because, depending on the particular vessel, such materials are constituents in the industrial waste, chemical waste and/or garbage “pollutant” discharge resulting from the activities of these vessels. “Industrial waste,” “chemical waste” and “garbage” are expressly included in the CWA’s definition of “pollutant,” which governs, among other things, which discharges are properly subject to the CWA. The CWA authorizes the EPA to issue permits for the “discharge of any pollutant” to navigable Waters of the U.S.

The VGP covers a broad range of incidental vessel discharges, such as ballast water, bilge water, gray water (e.g., water from sinks, showers), and deck wash-down and runoff. The VGP also sets forth requirements applicable to 25 specific states, including California. Among other things, it requires vessel discharges in California to comply with the requirements and discharge prohibitions established in the California Clean Coast Act of 2005, and prohibits vessel discharges from Water Quality Protection Areas defined in Public Resources Code Sections 36700-36900. It prohibits discharge of bilge water and discharges containing hazardous waste as defined in California Code of Regulations Title 22, Section 66261 and in Water Code Section 13173. A variety of other regulations pertaining to vessels operating in California are included in the VGP.

To obtain authorization to discharge under the VGP, the owner or operator of any vessel of 300 gross tons or more or with a ballast water capacity of more than 8 cubic meters (2,113 gallons) must submit a Notice of Intent (NOI) to the EPA via its Electronic Notice of Intent (eNOI) system at: http://www.epa.gov/npdes/vessels/eNOI. Vessel discharges occurring prior to seven days after EPA processes the NOI will be in violation of the VGP. Submittal of paper NOIs is permitted only if the discharger meets one of the electronic reporting exemptions list in Part 1.14 of the permit, in which case, the NOI must be processed by the EPA at least 30 days prior to any discharge. If a vessel is exempt from the NOI requirement due to its size, it must maintain a signed copy of the Permit Authorization and Record of Inspection (PARI) form onboard the vessel.

Initial Study 56 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

The NOI includes information about the owner/operator of the vessel, a variety of details about the vessel, general voyage information (i.e., destination ports, crew capacity, etc.), specific information about the different discharges from the vessel and any onboard treatment systems, and certification under penalty of law that the information in the NOI is complete and accurate and that the discharge limits and other applicable terms of the VGP will be adhered to during vessel operations.

Potential Water Quality Impacts Operation of the proposed project would have the potential to adversely affect water quality in San Francisco Bay and in ocean waters near coastal California. Such impacts could occur from the uncontrolled discharge of stormwater from the site that could be contaminated by leaking equipment or trucks or from accidental spills. Bay and seawater could also be contaminated by uncontrolled discharges from the ships carrying processed logs to China. These effects would be a potentially significant adverse impact on water quality. The impact would be reduced to a less-than-significant level with implementation of Mitigation Measures WQ–1 and WQ–2, below.

Mitigation Measure WQ–1: The project sponsor shall obtain National Pollutant Discharge Elimination System (NPDES) coverage under the Industrial General Permit (IGP) No. CAS000001, adopted by State Water Resources Control Board (SWRCB) Order No. 2014-0057-DWQ. Pursuant to the Order, the project applicant shall electronically file the Permit Registration Documents (PRDs) via the SWRCB’s Storm Water Multiple Application and Report Tracking System (SMARTS) at: https://smarts.waterboards.ca.gov/smarts/faces/SwSmartsLogi n.jsp. The required PRDs include a Notice of Intent (NOI), a risk assessment, site map, signed certification, Stormwater Pollution Prevention Plan (SWPPP), and other site-specific PRDs that may be required. At a minimum the SWPPP shall include a site map, authorized NSWDs at the facility, and an identification and assessment of potential pollutants sources resulting from exposure of industrial activities to stormwater. The SWPPP must clearly describe the Best Management Practices (BMPs) that are being implemented, who is responsible for the BMPs, where the BMPs will be installed, and when and how often the BMPs will be implemented. The PRDs shall be submitted at least seven days prior to commencing discharge.

Mitigation Measure WQ–2: For all ships used to transport processed logs to customers in China, the project sponsor shall obtain National Pollutant Discharge Elimination System (NPDES) coverage under the 2013 Vessel General Permit (IGP) issued by the U.S. Environmental Protection Agency (EPA), which became effective on December 18, 2013. To obtain coverage, the project sponsor shall complete and submit a Notice of Intent (NOI) to the EPA via its Electronic Notice of Intent (eNOI) system at: http://www.epa.gov/ npdes/vessels/eNOI. No discharges from project vessels may occur until seven days after the EPA has processed the NOI.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 57

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of pre-existing nearby     wells would drop to a level that would not support existing land uses or planned uses for which permits have been granted)?

Explanation: The majority of the project site is already covered with impervious surfaces, consisting of pavements and buildings. A small strip of exposed soil is located adjacent to the shoreline south of the ship wharf, and a landscape strip runs along the eastern boundary of the site, adjacent to Harbour Way South. Due to its current condition, the project site does not provide for any appreciable amount of groundwater recharge. Because the proposed project would not create any new impervious surfaces at the project site, the project would have no effect on groundwater recharge or groundwater supplies.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which     would result in substantial erosion or siltation on- or off-site?

Explanation: As noted in Section IX(b), above, the proposed project would not create any new impervious surfaces at the project site or otherwise alter the existing drainage patterns on the project site.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a     manner which would result in flooding on- or offsite?

Initial Study 58 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

Explanation: The project would not alter the course of a stream or river and would not alter the existing drainage pattern of the site. There is therefore no potential for the project to increase the risk of on- or off-site flooding.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact e) Create or contribute runoff water that would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional     sources of polluted runoff?

Explanation: As discussed above in Section IX(a), stormwater runoff from the site is discharged to San Francisco Bay. Normal operational deposits of oil, grease, heavy metals, and other contaminants would occur from the operation of diesel-powered trucks and equipment such as the front-end loader and excavator. These deposits along with potential accidental spills could potentially result in the pollutants being entrained in stormwater that would be discharged into the Bay. Although this would be a potentially significant impact, implementation of Mitigation Measure WQ–1 would ensure that the impact would remain less than significant, while implementation of Mitigation Measure WQ–2 would ensure that storm runoff and other discharges from ships transporting logs to China would not be a substantial source of pollutants.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact f) Otherwise substantially degrade water quality?    

Explanation: See Section IX(a). Other than the impacts identified therein, the project would not have the potential to substantially degrade water quality.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact g) Place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation     map?

Explanation: The project site is within a larger surrounding area mapped as Zone X by the Federal Emergency Management Agency (FEMA), which is the designation assigned to areas

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 59

that have been determined to be outside of the 0.2 percent annual chance flood plain (i.e., the 500-year flood plain).46 In any event, the project would not create new housing.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact h) Place within a 100-year flood hazard area structures which would impede or redirect flood flows?    

Explanation: As discussed in Section IX(g), above, the project site is not located within a 100- year or 500-year flood hazard area. In addition, the project would not create new structures.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact i) Expose people or structures to a significant risk of loss, injury, or death involving flooding, including     flooding as a result of the failure of a levee or dam?

Explanation: According to the General Plan EIR, although portions of the City of Richmond are located within the dam failure inundation zone for the San Pablo Reservoir dam, the East Bay Municipal Utilities District (EBMUD) completed a seismic upgrade of the dam foundation and buttress in September 2010, and the dam is now fully operational.47 General Plan Policy SN1.E requires the City to meet regularly with EBMUD staff to discuss dam failure hazards and EBMUD’s Emergency Action Plan. The General Plan EIR concluded that with implementation of applicable General Plan policies, new development in the City would be exposed to a less- than-significant impact from dam failure inundation. Furthermore, the project site is outside the dam failure inundation zone for San Pablo Reservoir, as determined by the California Office of Emergency Services.48 Therefore, the proposed project would not expose people or structures to risks associate with inundation from a dam failure.

46 Federal Emergency Management Agency, Flood Insurance Rate Map, Contra Costa County, California and Incorporated Areas, Community Panel Number 06013C0236G, revised September 30, 2015. 47 City of Richmond, Richmond General Plan Update Draft Environmental Impact Report, Section 3.9, Hydrology and Water Quality, February 2011. 48 California Office of Emergency Services, Dam Inundation Register Images and Boundary Files in ESRI Shapefile Format, September 2015.

Initial Study 60 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact j) Inundation by seiche, tsunami, or mudflow?    

Explanation: Tsunamis (seismic sea waves) are long-period waves that are typically caused by underwater disturbances (landslides), volcanic eruptions, or seismic events. Areas that are highly susceptible to tsunami inundation tend to be located in low-lying coastal areas such as tidal flats, marshlands, and former bay margins that have been artificially filled but are still at or near sea level. The project site is not located within a tsunami inundation area, as mapped by the California Emergency Management Agency.49 The site is also outside tsunami evacuation areas mapped by the Association of Bay Area Governments.50 Therefore, the project would not be subjection to inundation by tsunami.

A seiche is a free or standing wave oscillation(s) of the surface of water in an enclosed or semi- enclosed basin that may be initiated by an earthquake. Given its location adjacent to San Francisco Bay, the potential for a seiche run-up at the project site would not be greater than the potential for inundation by tsunami. The General Plan EIR also reported that there are no designated seiche risk areas within the City. Therefore, there is no potential for inundation by seiche at the project site.

Debris flows, mudslides, and mudflows begin during intense rainfall as shallow landslides on steep slopes. The rapid movement and sudden arrival of debris flows can pose a hazard to life and property during and immediately following a triggering rainfall. The project site is essentially flat, as is the surrounding area. There is therefore no potential for mudslides or debris flows.

X. LAND USE AND PLANNING — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Physically divide an established community?    

Explanation: The project site is currently developed with a large one-story warehouse, small three-story administration building, small guard house, and large areas of pavements. The project would not include any new construction such as new off-site roadways that could physically divide an existing neighborhood, nor would it otherwise create any barriers to

49 California Emergency Management Agency, Tsunami Inundation Map for Emergency Planning, State of California, San Francisco Bay Area, December 9, 2009. 50 Association of Bay Area Governments, Resilience Program, Tsunami Evacuation Area (Interactive Map), accessed December 28, 2015 at: http://gis.abag.ca.gov/website/Hazards/?hlyr=tsunami.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 61

existing circulation within the community. Therefore, implementation of the proposed project would not physically divide an established community.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to, the general plan, specific plan, local coastal program, or zoning     ordinance) adopted for the purposed of avoiding or mitigating an environmental effect?

Explanation:

General Plan: Land Use The General Plan land use designation of the site is Port, which is one of six Business and Industry land use classifications defined in the Richmond General Plan 2030. The Port category is applied to working waterfront uses, such as private and publicly-owned port terminals, warehousing, commercial fishing, ship repair, and related office uses. It has a height limit of 100 feet and an allowable floor area ratio (FAR) of 0.25 to 1.0. The proposed project is a principal permitted use within the Port land use designation. The project site is already developed with structures that conform to the height and FAR restrictions, and no new construction is proposed. The proposed project would conform to the Port General Plan land use designation.

The project site is located within the City’s Port Priority Use Area, one of six districts established in the City that provide a unique mix of uses that serve the entire community and/or where there is a concentration of related or complementary activities and uses. Some of these districts are considered “change areas” that provide significant economic development opportunities. Others, such as the San Pablo Peninsula Area offer opportunities for open space preservation, recreation, and natural habitat protection. The Port Priority Use Area, which centers on the Santa Fe Channel adjacent to San Francisco Bay, is intended as an area providing opportunities for economic development. The General Plan notes that new improvements within this change area should focus on strengthening the overall economic vitality of the Port of Richmond. It states that the Port Priority Use Area is designated as Port to recognize and reflect the Port’s continuing role as a major hub of port and related industrial uses. The proposed log export facility is consistent with this objective.

The project site is adjacent to, but outside of, the Ford Peninsula in Marina Bay Change Area Major Activity Center (CA-3), one of three change areas identified in the General Plan as concentrated, high-intensity community hubs that generate revenue and jobs, and serve as the focal point of cultural, commercial, and social activities.

General Plan Policies All of the Richmond General Plan 2030 policies were reviewed to identify those applicable to the proposed project and evaluate the project’s consistency with those policies.

In particular, the project would further the City’s goal expressed in Land Use and Urban Design Policy LU3.5, An Economically Viable and Modern Port, which calls for developing the Ford

Initial Study 62 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

Peninsula area as a working waterfront that supports the Port’s operations and provides opportunities for job-generating uses and other uses. It would also support Economic Development Policy ED8.6, An Economically Viable and Modern Port, which encourages growth and modernization of private port businesses and the Port of Richmond.

No conflicts with adopted General Plan policies were identified for the proposed project.

Other Planning Documents Due to its shoreline location adjacent to San Francisco Bay, land use at the project site is subject to the provisions of several additional local and regional plans, including the San Francisco Bay Plan, the South Richmond Shoreline Special Area Plan, the Knox Freeway/Cutting Boulevard Corridor Specific Plan, the San Francisco Bay Area Seaport Plan, and the San Francisco Bay Trail Plan. Each of these plans is discussed below.

San Francisco Bay Plan Established temporarily by the State by the 1965 McAteer-Petris Act, and permanently by the 1969 McAteer-Petris Act, the San Francisco Bay Conservation and Development Commission (BCDC) was established to halt the unregulated filling of San Francisco Bay, which had occurred at the average rate of 4 square miles per year between 1850 and 1960, resulting in a loss of over 235 square miles of Bay area since the California Gold Rush. The enabling legislation charged BCDC with the responsibility of preparing a plan for the long-term protection and use of the Bay. The result was the San Francisco Bay Plan (Bay Plan), completed in 1969 and periodically amended over the past four decades.

The Bay Plan also references a number of special area plans formally adopted by BCDC that provide more detailed guidance for fill and development in the areas governed by the plans. Among others, these special area plans included the South Richmond Shoreline Special Area Plan, which encompasses the Terminal 3 site and is discussed separately below.

The Bay Plan is the mechanism by which BCDC controls both Bay filling and dredging and shoreline development along the Bay. The Commission has jurisdiction over these activities within the Bay and within a shoreline band extending 100 feet landward from the mean high tide line of the Bay. The Commission’s jurisdiction also includes marshlands lying between mean high tide and 5 feet above mean sea level, diked salt ponds, managed wetlands, and the portions of certain creeks or rivers that discharge to the Bay that are subject to tidal action.

Bay Plan Map 4, which encompasses the north central portion of San Francisco Bay, including the south Richmond shoreline, designates Terminal 3 for Port Priority Use. The proposed log processing and export facility is consistent with this designation and with Bay Plan policies prioritizing water-related industry and port uses at sites designated for such use.

As part of this environmental review, the Bay Plan was reviewed to identify policies and other plan provisions that may apply to the proposed project and evaluate potential conflicts. Although no policy conflicts were identified, based on Safety of Fills Policy 1, the BCDC may want to review and comment on the project proposal. Policy 1 states, in part, “The Commission has appointed the Engineering Criteria Review Board . . . empowered to . . . review all except minor projects for the adequacy of their specific safety provisions, and make recommendations concerning these provisions . . .” The Plan does not define what constitutes a “minor project,” but given the proposed project’s lack of new construction, it may qualify for this exception.

While Bay Plan policies, as well as the McAteer-Petris Act, require any project built on the shoreline or on Bay fill to provide public access “to the maximum extent feasible,” the proposed project would be implemented on an existing port property that has been used for port uses for

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 63

decades. No new construction or expansion of the existing facilities is proposed and the nature of port operations in general and the proposed project operations in particular are not conducive to public access to the shoreline. It is therefore assumed that it would be neither feasible nor appropriate to provide public access to the shoreline at Terminal 3, and no Bay Plan policy conflict is identified. However, there is existing public access to the shoreline about 300 feet south of the project site, at Sheridan Observation Point, located at the southern end of the Ford Peninsula. This small parklet provides a lawn and fishing pier.

In addition to restricting Bay filling, the policies promulgated in the Bay Plan are particularly focused on protecting aquatic habitats and water quality in and around the Bay, among other policy directives. Although project operations, including the operation of ships used for conveying processed logs to end markets in China, have the potential to adversely affect water quality in the Bay and the offshore coastal waters, implementation of Mitigation Measures WQ– 1 and WQ–3 (see Section IX, Hydrology and Water Quality) would ensure that project-related impacts to water quality in the Bay and ocean would be less than significant and no policy conflicts would occur.

The BCDC requires a permit for dredging or filling of the Bay, the latter of which can include placement of piers or pilings or the extended mooring of floating structures. A permit is also required for any new development within the 100-foot shoreline band under the Commission’s jurisdiction. Permitting requirements for new development are essentially the same as the permit system for dredging or filling of the Bay. Because the proposed project would not require modifications to the pier at Terminal 3, and it does not propose any new construction or improvements other than outdoor lighting and electrical upgrades, the project is not expected to require permitting by BCDC. However, the engineering controls for stacked logs required by Mitigation Measure GS–1 could potentially require a BCDC permit, particularly if the design solution requires subsurface disturbance.

Implementation of Mitigation Measure GS–1, required to protect worker safety from a potential collapse of stacked logs, could potentially trigger the need for a permit from BCDC. Failure to obtain authorization from BCDC, which was created for the purposes of reducing or avoiding adverse environmental effects on San Francisco Bay, would constitute a potentially significant impact. Implementation of the following mitigation measure would ensure that the impact would remain less than significant:

Mitigation Measure LU–1: Once plans have been developed for appropriate and effective engineering controls for stacked logs at Terminal 3, as required by Mitigation Measure GS–1, City Planning staff shall consult with the San Francisco Bay Conservation and Development Commission (BCDC) to identify any BCDC concerns and/or permit requirements applicable to the proposed project. The project sponsor shall obtain any required BCDC permit and shall comply with any other requirements identified by the Commission prior to initiating project operations.

South Richmond Shoreline Special Area Plan Terminal 3 is located within the area governed by the South Richmond Shoreline Special Area Plan (SRSSAP), a joint planning document adopted in 1977 by both BCDC and the City of Richmond.51 The aim of the plan was to achieve consistency between BCDC’s San Francisco Bay

51 South Richmond Shoreline Special Area Plan Citizens’ Advisory Committee, South Richmond Shoreline Special Area Plan, An Amendment to the City of Richmond General Plan and the San Francisco Bay Conservation and Development

Initial Study 64 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

Plan and the Richmond General Plan and, accordingly, amended both of those plans by resolution of BCDC and the Richmond City Council, respectively. Previous incompatibility between the two planning documents pertained to future plans for Richmond’s Inner Harbor Basin, which designated the basin area for future port use, while the City desired to develop the water– oriented complex that exists today and includes a major marina, park and public access uses, commercial areas, and residential development at varying densities. The adoption of the SRSSAP permitted this development to move forward with BCDC approval, including the removal of the Inner Harbor Basin as a Port Priority Use Area.

The SRSSAP divides the South Richmond shoreline into four subareas: Brooks Island, Point Isabel, Inner Harbor, and Santa Fe, with Terminal 3 being located within the latter subarea. Policies promulgated in the SRSSAP are specific to one of these subareas. The SRSSAP reasserts the applicability of policies established in the San Francisco Bay Plan, Richmond General Plan, and the Urban Renewal Plan for Redevelopment Project Area 11–A (Redevelopment Plan 11–A). However, with the dissolution of all California redevelopment agencies by the State in 2012, Redevelopment Plan 11–A is no longer in effect.

The major policy direction for the Santa Fe Sub-Area as established in the SRSSAP is: (1) to retain the Harbor and Santa Fe Channels as a port priority area, and (2) to encourage public access where feasible. Although Bay fill is permitted for expansion of port facilities in the shoreline port priority areas, the proposed project would not require any placement of fill. Similar to the discussion of the Bay Plan, above, it would not be appropriate to provide public shoreline access at Terminal 3, so the project would not conflict with Public Recreation, Other Open Space and Public Access Policy 1 for the Santa Fe Sub-Area, which reads: Require waterfront developments, as part of any project approval process, to provide the maximum feasible public access to the shoreline consistent with the project, with adequate links to inland areas. (Continuing Policy)

The proposed project would not conflict with the SRSSAP or any of the policies promulgated therein.

Knox Freeway/Cutting Boulevard Corridor Specific Plan The project site is also included within the planning area covered in the Knox Freeway/Cutting Boulevard Corridor Specific Plan.52 As implied by the name, this specific plan centers on the Knox Freeway (Interstate 580) and Cutting Boulevard, encompassing an area of 1,894 acres that includes much of Richmond’s southern shoreline. Although the plan is 25 years old, is not fully consistent with the recently adopted General Plan, and is expected to be superseded in the future by a Ferry Terminal Specific Plan and a Southern Gateway Specific Plan—both called for in the Land Use and Urban Design Element of the Richmond General Plan 2030—it currently remains in effect for the project area. Accordingly, its applicability to the proposed project is discussed below.

The Knox-Cutting Specific Plan supplements the General Plan by establishing planning policies and zoning regulations specific to the Knox-Cutting corridor. It was adopted to achieve the following goals: 1. Protect and improve the quality of the existing residential neighborhoods.

Commission Bay Plan, adopted by the Richmond City Council on April 25, 1977 and by the San Francisco Bay Conservation and Development Commission (BCDC) on May 5, 1977, amended by BCDC on August 20, 1987. 52 HGHB, et. al., prepared for The Citizens’ Advisory Committee for the Knox Freeway/Cutting Boulevard Corridor Specific Plan, Knox Freeway/Cutting Boulevard Corridor Specific Plan, adopted by the Richmond City Council on September 23, 1991.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 65

2. Conserve and enhance the character of existing areas. 3. Enhance the identity, image and development potential of the Specific Plan Area. 4. Enhance employment opportunities for residents of the City, with emphasis on opportunities for the unemployed. 5. Protect existing and new land uses by providing adequate buffer zones that avoid or mitigate conflicts in land uses. 6. Conserve and protect the wetlands and marsh areas along the shoreline.

The planning area is divided into five sub-areas, each with a distinctive land use character; Terminal 3 is located in the Ford Peninsula Sub-Area, which is dominated by light industrial and port-maritime uses. For this sub-area and the adjacent South Shoreline Sub-Area, the Specific Plan envisions gradual redevelopment of existing underutilized or vacant property into an integrated urban high-technology center capitalizing on the accessibility, location, and land availability for large-scale development in these two sub-areas.

The Specific Plan assigns a land use designation of Port/Maritime to the project site. The description of this designation states that maritime and maritime-support uses as defined by BCDC in the Seaport Plan (see below) are permitted uses. These include container facilities, automobile off-loading and storage, commodity handling activities, and ship/boat sales and service activities. Conditional uses include light and heavy industry and commercial/office activities related to maritime uses. Residential use is prohibited.

The Specific Plan also establishes development standards for the different land use designations. For the Port/Maritime designation, it establishes a minimum lot size of 10,000 square feet and a maximum intensity of a floor area ratio (FAR) no larger than 0.50. The maximum allowable building coverage is 50 percent for all sites. For buildings within 250 feet of the shoreline or within 100 feet of paths, parks, dedicated open space, or residential use may not exceed 35 feet in height except in Port/Maritime areas, where a height of 75 feet is allowed when directly related to a viable port use. The project site conforms to these regulations.

The development standards in the Specific Plan also require screening on non-residential uses from abutting residential uses. Although there are currently no residential uses adjacent to the site, live/work uses have been approved for the Ford Assembly Building located just to the east of the project site; therefore, residential uses could be located there in the future. The Zoning Ordinance (discussed below) also requires screening of industrial properties. The City will require, as a condition of project approval, slats or other opaque media to be installed on the fence extending along the Terminal 3 frontage on Harbour Way South in order to minimize visibility through the fence, and will also require additional landscape screening. Through adherence to the condition of approval, the project would conform to the Specific Plan and Zoning Ordinance screening requirements.

The Specific Plan development standards also stipulate, in Section 5.6, that at least 15 percent of the lot shall be landscaped. Existing landscaping at the site does not cover 15 percent of the lot, and the project does not propose to create additional landscaping. However, given the nature of the site and the proposed activities, the City intends to process an exemption to this standard. Section 5.15 of the Specific Plan states that where undue hardships, practical difficulties, or consequences inconsistent with the general purposes of the Specific Plan would result from the literal interpretation and enforcement of the site and facility requirements established in the plan, the City may grant adjustments in accordance with Richmond Municipal Code, under such conditions and safeguards as it may determine, consistent with the general purposes and intent of the Specific Plan.

Initial Study 66 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

Harbour Way South is designated a Street Linkage on the Open Space/Urban Design Diagram (Figure 4.2) of the Specific Plan. The Plan calls for bold and simple streetscape improvements to enhance the image and “provide legibility” to the area. Streetscape improvements within the public right-of-way should be an integrated system that includes tree planning, street light fixtures, signal standards, street furniture, and signage. Improvements are intended to be implemented as part of an integrated, City-led program. Nothing in the Specific Plan indicates that new development is expected to implement these improvements.

One Open Space/Urban Design policy, Policy 9, may be directly applicable to the proposed project. Policy 9 reads, “Public access facilities shall be provided as part of the development of the Richmond Terminal No. 3. As an example, an overlook for viewing water-borne traffic could be provided.” As part of a separate project, the existing southern 150-plus linear feet of Terminal 3 will be assigned for expanded public parking for the future Richmond Ferry Terminal, and the existing shoreline trail will be extended north to this Project’s southern boundary. In addition, the Sheridan Point outlook provides an overlook for viewing water-borne traffic. The M-4 zoning district also states that access may not be required in new development where “a) water- oriented uses such as docks, shipping terminals, pipelines between ship and shore require the uses of the bay and cannot reasonably allow for public access; and b) public pedestrian access would create a safety hazard.”53 Based on these considerations, no conflict with Open Space/Urban Design Policy 9 is identified for the project.

The project would assist the City in meeting Economic Development Objective 4, which reads: “Achieve an increase in the number of medium-sized industrial establishments with growth potential in the West Cutting Boulevard, Ford Peninsula and South Shoreline Sub-areas where the plan identifies research and development, light industrial, heavy industrial, and port-maritime uses.”

No potential policy conflicts were identified in evaluating the proposed project’s consistency with the Knox Freeway/Cutting Boulevard Corridor Specific Plan. Although the plan contains design guidelines and streetscape guidelines, these have been superseded by more detailed guidelines contained in the South Richmond Transportation Connectivity Plan, which is discussed below.

Section 5.14 of the Specific Plan references mitigation measures from the Environmental Impact Report (EIR) for the Specific Plan, noting that they identify additional requirements necessary to mitigate potential impacts relating to land use, economic development, noise, community services and facilities, geology/hydrology/seismology, air quality, vegetation and wildlife, cultural resources, and hazardous materials. All of the mitigation measures from the Specific Plan EIR were reviewed to identify those that may apply to the proposed project. The following relevant measures were identified, all of which are in the form of adopted land use policies. Prior to approving the Conditional Use Permit for the project, the City will ensure that the project conforms to these policies.

Community Services and Facilities Mitigation Measure 3.5-3: Land Use Policy: Point source reduction, which uses industrial byproducts and wastes as resources in other areas before these wastes enter the disposal system, shall be encouraged in the Specific Plan area. Manufacturers that generate any quantities of byproducts and wastes shall prepare lists of those excess materials to be made available to the City of Richmond and to other firms which request the list. Listings shall include all waste or byproduct materials except those which have U.S. Government classified security status. All existing manufacturers in Richmond shall

53 Richmond Municipal Code Section 15.04.340.050(1).

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 67

receive copies of the listings, and new manufacturers locating within the Specific Plan Area shall receive the listing upon occupancy. Any materials appearing on the list shall be made available for little or no fee to other potential users; transport and handling of materials shall be the responsibility of potential users. Incentives for producers of waste or byproduct materials shall be in the form of waste collection fee reductions for those firms which reuse or provide other firms with the materials.

Land Use Policy: Recycling, which involves the gathering and grouping of items such as glass, paper, and aluminum to be converted into new raw materials, shall be encouraged in the Specific Plan area. Composting of leaves and grass cuttings is also considered recycling, and shall be encouraged. Public education through mailing and newspaper advertisements shall be implemented, as well as a periodic curbside collection for recyclable materials. Recycling shall be encouraged through increases in waste collection fees, with fee reduction incentives for waste separation and participation in roadside pickup. Increased fees for waste pickup shall be used to fund curbside pickup. Recycling of waste paper at offices and other firms which dispose of paper shall be encouraged through the use of graduated fees for waste paper reduction; information on area waste paper pickup services shall be provided to such firms.

Vegetation and Wildlife Mitigation Measure 3.9-3: Open Space/Urban Design Policy: Only species that require a minimum of irrigation (drought tolerant species) and pesticide and fertilizer application shall be used in landscaping. For these reasons and to increase wildlife habitat quality, it is recommended that drought tolerant native Californian species be used where appropriate.

Hazardous Materials Mitigation Measure 3.11-9: Land Use Policy: All new and existing industrial facilities within the Plan Area shall prepare Hazardous Materials Reduction Plans (HMRP), which shall be subject to review and approval by the Fire Chief or agent thereof. Each facility which chooses not to prepare an HMRP must provide justification to the Fire Department for validation, upon which the Fire Department shall have power to issue a partial or total exemption from plan preparation.

As noted in the project description, the waste bark generated by the project would be recycled for use as landscape mulch and potting soil, consistent with Mitigation Measure 3.5-3.

Bicycle Master Plan The City of Richmond Bicycle Master Plan (BMP) was adopted by the City in 2011, with the basic purpose of setting in motion the policies and action items identified in the current General Plan.54 The BMP provides a blueprint for completing a 145-mile system of bikeways and support facilities within the City of Richmond. For purposes of planning the bicycle network, the City is divided into four geographic sub-areas. The project site is located within the Central Richmond sub-area. Harbour Way South is identified as one of the City’s key bicycle corridors, where a variety of bicycle-friendly roadway treatments are recommended.

The BMP identifies an existing northbound Class II bike lane on Harbour Way South between Hall Avenue and Wright Avenue, and an existing southbound Class III bike route on the same roadway segment. A Class I bike path extends on Harbour Way South from Wright Avenue to

54 City of Richmond, City of Richmond Bicycle Master Plan, October 2011.

Initial Study 68 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

its southern terminus, continuing along the southern and eastern shores of the Ford Peninsula. These routes are identified as ongoing bikeway projects (since 2009), as are these additional projects in the vicinity of the Terminal 3 site: Ferry Point Loop Trail Guide, Ford Point Bay Trail Loop, and Hall Avenue Bike Lane Racks.

While the BMP identifies several alternative configurations for improved bicycle facilities along Harbour Way South between Wright Avenue and Pennsylvania Avenue (north of the project site), these plans have subsequently been superseded by the more recent South Richmond Transportation Connectivity Plan, which is discussed below. The proposed project would not conflict with any of the goals and policies set forth in the BMP.

South Richmond Transportation Connectivity Plan The South Richmond Transportation Connectivity Plan (SRTCP) was developed to address deficiencies in the existing transportation systems in South Richmond, shortcomings that are expected to become more critical when the planned ferry terminal on the Ford Peninsula becomes operational in 2018 and when the planned Berkeley Global Campus at Richmond Bay is developed.55 The SRTCP planning area extends from Richmond’s Inner Harbor on San Francisco Bay north to Maine Street, and from Harbor Channel and South 6th Street on the west to San Pablo Avenue on the east. The planned ferry terminal is identified in the SRTCP as one of the key opportunities for increasing transportation connectivity within South Richmond and improving regional access.

In the project area, the SRTCP identifies Harbour Way South as a key multi-modal transportation corridor, with the planned ferry terminal at the southern end of Harbour Way South providing regional transit access. Challenges for this corridor and a parallel corridor on Marina Way include balancing the movement of goods with auto access to the ferry terminal while maintaining bicycle and pedestrian access and safety and addressing conflicts at rail crossings and I-580 ramps.

Harbour Way South, Hall Avenue, and Wright Avenue are all identified as proposed truck routes in the SRTCP. Hall Avenue and Harbour Way South south of Hall Avenue are identified as primary transit corridors. The Plan identifies the Ford Peninsula east of Harbour Way South as a Pedestrian Improvement District and Harbour Way South as a Key Pedestrian Route. A variety of both pedestrian enhancements and improved bicycle facilities are recommended for the planning area. The SRTCP provides updated recommendations for the types of bicycle facilities previously identified for Harbour Way South in the Bicycle Master Plan discussed above, consistent with changes in best practices in bicycle and pedestrian facility design and implementation since 2011.

Within the project vicinity, the SRTCP calls for the following improvements to Harbour Way South:

Near-Term (2015-2024)  Maintain as a Primary Truck Route  Ford Point to Hoffman Boulevard:  Add two-way separated bikeway on east side  Formalize parking on west side, with parking restrictions near driveways and intersections to improve sight lines, and enhance safety of truck turning movements.  Hoffman/Harbour:

55 City of Richmond, South Richmond Transportation Connectivity Plan (SRTCP), July 2015.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 69

 Stripe triple-four trail crossings on east and north side of intersection  Stripe large corner bulb/queue on both SE and SW corners of the intersection to allow cyclists to make two-stage left turn crossings.  Stripe curb extension on SE corner, to slow and improve safety of auto turning movements.

Long-Term (2030+)  Maintain as a Primary Truck Route  Ford Point to Hoffman Boulevard: Raised two-way cycletrack on the east side of the roadway  Hoffman Boulevard to Cutting Boulevard:  Raised one-way cycletracks through I-580  Square up On- and Off Ramps per Pedestrian Plan with hardscape curb extensions  Stripe large sidewalk extension with soft-hit posts in the northbound direction, north of off-ramp  Hoffman Boulevard/Harbour Way Intersection  Modify signal to allow bike phase concurrent with NB protected left-turn  Formalize curb extensions with curb and gutter

The SRTCP identifies signalization of the Harbour Way/Wright Avenue intersection as a planned improvement, noting that there is a need for improvements such as coordinated traffic signals, warning lights, and rail crossing gates at this intersection, where the BNSF rail line crosses at grade through the currently unsignalized intersection. As discussed in Section XVI, Transportation/Traffic, the City will require the proposed project to make a fair-share contribution to the signalization of this intersection as a condition of project approval.

The Urban Design Framework presented in the SRTCP designates Harbour Way South as a Shoreline Connector passing through an industrial neighborhood. For Shoreline Connectors, the following streetscape elements are recommended to help achieve this goal: convey a positive first impression and establish a distinctive sense of place.

 A consistent, evenly spaced street tree palette that includes tall, narrow-canopy sidewalk and median trees interspersed with palm trees;  A planting palette that features coastal-tolerant species commonly found along the Richmond waterfront and around San Pablo Bay;  Prominently featured lighting fixtures with a design that draws strongly from industrial and maritime influences and reinforces the formal sense of entry;  Prominent, consistently-designed wayfinding signage that directs visitors to key South Shoreline destinations; and  Overpass and underpass crossing enhancements that create a more welcoming entry experience to the South Shoreline area and reflect the local community and heritage.

The Plan provides a recommended street tree palette for inclusion in the streetscape elements. For Shoreline Connectors, the recommended species include Raywood ash (Fraxinus augustifolio ‘Raywood’), water gum tree (Trisaniopsis laurina), sour gum tree (Nyssa sylvatica), and Brisbane box tree (Lophostemon), with Robinson flowering crabapple (Malus ‘Robinson’) and Natchez crape myrtle (Lagerstromia ‘Natchez’) as small accent trees. For medians and parkways within Shoreline Connectors, the recommended species include water gum tree and Monterey cypress (Cupressus macrocarpa). Canary date palm (Phoenix canariensis) and Guadalupe palm (Brahae edulis) are recommended accent palms.

Initial Study 70 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

Detailed corridor profiles are presented in the SRTCP for all of the key transportation routes within the planning area. For the segment of Harbour Way South from its southern terminus to Hoffman Boulevard, the Plan depicts a recommended 75-foot-wide right-of-way with 10-foot sidewalks on both sides, a single 11-foot travel lane in each direction separated by an 11-foot turning lane, and an 8-foot parking lane on the southbound side. On the northbound side, a 2- foot buffer with a physical barrier separates vehicle traffic from a two-way raised cycletrack, with 6-foot bicycle lanes in both the northbound and southbound directions.

The proposed project would not conflict with or impair implementation of the planned improvements on the Ford Peninsula identified in the SRTCP. As discussed above for the Knox Freeway/Cutting Boulevard Corridor Specific Plan, the City will require the project applicant to install additional landscape screening along Harbour Way South as a condition of approval of the Conditional Use Permit for the project. The improvements will be required to conform to the Urban Design Framework presented in the SRTCP. As previously noted, the applicant will also be required to make a fair-share contribution to the future signalization of the Harbour Way/Wright Avenue intersection.

BCDC Seaport Plan The San Francisco Bay Area Seaport Plan was developed cooperatively between BCDC and the Metropolitan Transportation Commission (MTC) and serves as the primary port policy document for BCDC and as the maritime element of MTC’s Regional Transportation Plan.56

The Seaport Plan calls for BCDC’s Seaport Planning Advisory Committee to monitor the region’s maritime cargo volumes, marine terminal use, and ship calls on an ongoing basis. The monitoring is intended to determine whether there has been a shift in the method of transporting bulk cargoes and ensure that the Seaport Plan’s marine terminal designations continue to adequately accommodate needed port and marine terminal development. Seaport Plan states that no changes in use or deletions of port priority use areas should be considered until the cargo monitoring process has been implemented.

The Seaport Plan is intended to promote the following goals: 1. Ensure the continuation of the San Francisco Bay port system as a major world port and contributor to the economic vitality of the San Francisco Bay region; 2. Maintain or improve the environmental quality of San Francisco Bay and its environs; 3. Provide for the efficient use of finite physical and fiscal resources consumed in developing and operating marine terminals through the year 2020; 4. Provide for integrated and improved surface transportation facilities between San Francisco Bay ports and terminals and other regional transportation systems; and 5. Reserve sufficient shoreline areas to accommodate future growth in maritime cargo, thereby minimizing the need for new Bay fill for port development.

To achieve these goals, the Seaport Plan assigns land use designations to appropriate shoreline areas under BCDC jurisdiction and promulgates enforceable policies. Consistent with the San Francisco Bay Plan, Figure 6 of the Seaport Plan designates Terminal 3 and other Port properties surround the Santa Fe and Harbor channels as a Port Priority Use Area. Port Priority Use Area policies call for the protection and preservation of these areas for marine terminals and other directly related port activities. Public access and commercial recreation development may be

56 San Francisco Bay Conservation and Development Commission and Metropolitan Transportation Commission, San Francisco Bay Area Seaport Plan, April 18, 1996, as amended through January 2012.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 71

allowed provided that the use would not impair existing or future use of the area for port purposes.

Of Seaport Plan policies pertaining specifically to the Port of Richmond, only one has any bearing on the proposed project. Port of Richmond Policy 1 states that the Port of Richmond should have the annual cargo throughput listed in an accompanying table (Table 15). For the combined Terminal 2 and Terminal 3, with two ship berths, the expected 2020 throughput capability is 209,000 metric tons of container capacity and 286,000 metric tons of neo-bulk capacity. The proposed project would contribute to the Port’s ability to achieve the target neo- bulk capacity. Therefore, the project would be consistent with the Seaport Plan.

San Francisco Bay Trail Plan The Bay Trail Plan was prepared in 1989 in response to California Assembly Bill 100 (1987), which mandated the creation of regional hiking and bicycling trail around San Francisco Bay.57 The Plan proposes the alignment for an approximately 500-mile network of recreational trails encircling San Francisco and San Pablo Bays. The trail is planned to pass through all nine Bay Area counties and 47 cities, and cross seven toll bridges. To date, 343 miles of the trail have been completed, including over 32 miles within the City of Richmond. When completed, the Bay Trail system will provide connections between more than 90 parks and public open space areas, as well as to a burgeoning network of “water trails” on the Bay itself.

Maps developed by the San Francisco Bay Trail Project to implement the Bay Trail Plan designate an existing on-street segment of the Bay Trail that extends along Harbour Way South from Hoffman Boulevard (just south of I-580) south to the southern end of the Ford Peninsula, where it becomes a paved trail that extends along the southern and eastern edges of the peninsula, then connects with other trail segments, including another on-street segment on Hall Avenue.58

The Bay Trail Plan contains policies to guide implementation of the planned trail system that fall into one of the following five categories: trail alignment, trail design, environmental protection, transportation access, and implementation. Because the Terminal 3 site is located adjacent to two existing segments of the Bay Trail and no other segments are planned for the project vicinity, there is no potential for the project to conflict with the trail alignment or trail design policies. The environmental protection, transportation access, and implementation policies were reviewed to identify any that would be relevant to the proposed project. None of the policies would apply to the project and the project would not conflict with any of the provisions of the Bay Trail Plan.

Zoning Ordinance The project site is zoned M-4 Marine Industrial. The M-4 zoning district is intended to create, preserve and enhance areas containing a wide range of municipal or private maritime uses such as marine terminals, cargo handling, ancillary manufacturing, or related establishments in areas having extensive rail or transport facilities. Manufacturing uses that are dependent on direct port access for import and export of raw materials and finished products are also found in the M-4 district.

The M-4 zone encompasses land area around the Santa Fe and Harbour Channels. The M-4 regulations are intended to strengthen the unique physical and environmental quality of these

57 Association of Bay Area Governments (ABAG) and the San Francisco Bay Trail Project, The Bay Trail: Planning for a Recreational Ring Around San Francisco Bay, July 1989. 58 http://baytrail.org/get-on-the-trail/map-by-number/albany-to-richmond/

Initial Study 72 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

areas, which are extensions of adjacent San Francisco Bay. They are also intended to ensure the aesthetic quality of development and ensure compatibility of development with nearby residential areas. Adjacent zoning districts should provide buffering between residential districts and the M-4 district. There are no overlay districts assigned to the project site that would impose additional regulations.

The zoning ordinance provides a lengthy list of industrial, manufacturing, transportation, communications, public utilities, wholesale durable goods, civic, public, and semi-public uses that are permitted in the M-4 zoning district, along with an equally lengthy list of uses that may be permitted by a Conditional Use Permit. The lists of permitted and conditionally permitted uses in the M-4 district do not include log processing facilities, log export facilities, lumber storage terminals, or similar uses, nor are such uses defined as allowed uses in the Knox Cutting Specific Plan (KCSP). However, pursuant to Section 15.04.012 of the Richmond Municipal Code, the Planning Director may determine that a specific use shall be deemed to be within a classification if its characteristics are substantially compatible with those uses named within that classification. The site is designated Port and Maritime in the KCSP which conditionally allows light and heavy industrial uses. Warehousing facilities are conditional uses in the M-4 Zoning. Because the proposed project is similar to a warehouse use, the City has determined that the proposed use is subject to a Conditional Use Permit to ensure compatibility with surrounding uses.

The M-4 district has a height limit of 75 feet plus 30 feet for appurtenances. However, there is a 35-foot height limit for structures located within 100 feet of shoreline, public park, recreational trail, recreational right-of-way, or residential development. Marine terminal equipment such as cranes is exempt from the height limits. The maximum allowable floor area ratio (FAR) is 0.5. A side setback of 10 feet is required, reduced to 5 feet where there is a solid fence. There is no rear setback required except for parcels abutting residential development, public park, recreational trail, recreational right-of-way, or shoreline, in which case a 15-foot setback is required. Minimum setbacks from minor streets and collector streets are 10 feet and 25 feet, respectively. Although these development standards would not apply to the proposed project, which would not include any new development, the existing development on the Terminal 3 site appears to conform to all of these standards.

Outdoor storage of raw or finished goods is permitted in the M-4 district. A variety of other development regulations apply to the M-4 zone, such as landscaping, street trees and other trees, fencing, front yards, open space, etc. Since the proposed project does not entail any new development or site modifications, these regulations would not apply to the project. Regulations on the use or storage of hazardous materials would not apply to the project because it would not entail use or storage of hazardous materials. However, some performance standards established in Chapter 15.04.840 of the Zoning Ordinance, specifically those pertaining to noise (Section 15.04.840.020), would apply to the project. Those standards are addressed in Section XII of this Initial Study.

Section 15.04.840.013 of the Zoning Ordinance, which establishes fencing and landscaping standards for commercial and industrial properties, may apply to the project. Some of the provisions are contradictory. For example, it establishes standards for solid walls and high solid screens, which may be 6 to 8 feet high, but also states that no fence or wall shall exceed 3 feet in height unless the Development Review Board (DRB) grants an adjustment when such installation is deemed necessary. There is currently a 6-foot-tall chain-link fence enclosing the site along its Harbour Way South frontage. The DRB may require the provision of a sight- obscuring fence, screen, or wall, which will be determined during development review of the proposed project. As discussed above, City staff will be recommending the addition of wood slats to the existing chain-link fence enclosing the site along the Harbour Way South frontage.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 73

Because the site is not currently visually sensitive and there are no visually sensitive receptors in the site vicinity, whether or not additional screening requirements will be imposed by the City pursuant to Section 15.04.840.013 of the Zoning Ordinance is not an environmental issue that needs to be further addressed in this Initial Study. It is presumed that the project will be required to comply with the applicable provisions of the Zoning Ordinance as a condition of project approval.

Based on the review of the General Plan, Zoning Ordinance, and other local and regional planning documents summarized above, the proposed project would not conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project adopted for the purposed of avoiding or mitigating an environmental effect.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Conflict with any applicable habitat conservation plan or natural community conservation plan?    

Explanation: There is no adopted habitat conservation plan (HCP) applicable to the City of Richmond.

XI. MINERAL RESOURCES — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Result in the loss of availability of a known mineral resource that would be of value to the region and the     residents of the state?

Explanation: No regionally significant mineral deposits have been mapped on or in the vicinity of the project site. The site is within a large area classified as Mineral Resource Zone MRZ-1 by the California Department of Conservation’s Division of Mines and Geology (DMG).59 The MRZ-1 designation is assigned to areas where sufficient data exists for a determination that no significant mineral deposits exist, or where it is judged that there is little likelihood for their presence. Furthermore, the site is in a fully developed, urbanized area where mineral extraction would not be practical. Therefore, the project would not have an effect on the availability of mineral resources.

59 California Department of Conservation, Division of Mines and Geology, Generalized Mineral Land Classification Map of the South San Francisco Bay Production-Consumption Region (Plate 1 of 29), 1996.

Initial Study 74 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Result in the loss of availability of a locally- important mineral resource recovery site delineated on a local general plan, specific plan, or other land     use plan?

Explanation: The Richmond General Plan does not identify any local mineral resources in the project vicinity, and the Richmond General Plan EIR reports that the City’s significant sectors of sandstone and shale aggregates are located in the San Pablo-Potrero Hills Ridge Area, well away from the project site. The map of geology and mineral resource sectors presented in the General Plan EIR indicates that the project site is underlain by Bay Mud. In any event, the project site has been developed with marine-related uses for many decades. There is no potential for the project to have an adverse effect on the availability of significant mineral resources.

XII. NOISE — Would the project result in:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of     other agencies?

Explanation:

Introduction to Noise Descriptors Noise is defined as unwanted sound. Airborne sound is a rapid fluctuation of air pressure above and below atmospheric pressure. Sound levels are usually measured and expressed in decibels (dB) with 0 dB corresponding roughly to the threshold of hearing.

Most of the sounds that we hear in the environment do not consist of a single frequency, but rather a broad band of frequencies, with each frequency differing in sound level. The intensities of each frequency add together to generate a sound. The method commonly used to quantify environmental sounds consists of evaluating all of the frequencies of a sound in accordance with a weighting that reflects the facts that human hearing is less sensitive at low frequencies and extreme high frequencies than in the mid-range frequency. This is called "A" weighting, and the decibel level so measured is called the A-weighted sound level (dBA). In practice, the level of a sound source is conveniently measured using a sound level meter that includes an electrical filter corresponding to the A-weighting curve. Typical A-weighted levels measured in the environment and in industry are shown in Table N–1 for different types of noise.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 75

Although the A-weighted noise level may adequately indicate the level of environmental noise at any instant in time, community noise levels vary continuously. Most environmental noise includes a conglomeration of noise from distant sources that create a relatively steady background noise in which no particular source is identifiable. To describe the time-varying character of environmental noise, the statistical noise descriptors, L01, L10, L50, and L90, are commonly used. They are the A-weighted noise levels equaled or exceeded during 1 percent, 10 percent, 50 percent, and 90 percent of a stated time period. A single number descriptor called the Leq is also widely used. The Leq is the average A-weighted noise level during a stated period of time.

In determining the daily level of environmental noise, it is important to account for the difference in response of people to daytime and nighttime noises. During the nighttime, exterior background noises are generally lower than the daytime levels. However, most household noise also decreases at night and exterior noise becomes very noticeable. Further, most people sleep at night and are very sensitive to noise intrusion. To account for human sensitivity to nighttime noise levels, a descriptor, DNL (day/night average sound level), was developed. The DNL divides the 24-hour day into the daytime of 7:00 AM to 10:00 PM and the nighttime of 10:00 PM to 7:00 AM. The nighttime noise level is weighted 10 dB higher than the daytime noise level.

The Community Noise Equivalent Level (CNEL) is another 24-hour average which includes both an evening and nighttime weighting, adding 5 decibels to the average noise levels during the evening and 10 decibels to the average noise levels during the nighttime period. CNEL and DNL descriptors are similar and are often used interchangeably. Noise standards established in the Richmond General Plan are expressed using the CNEL descriptor. For obvious reasons, the DNL and CNEL descriptors are only relevant in cases where residential or other noise-sensitive land uses are nearby.

Table N–1 Typical Noise Levels

Noise Level (dBA) Outdoor Activity Indoor Activity

90+ Gas lawn mower at 3 feet, Rock Band jet flyover at 1,000 feet

80-90 Diesel truck at 50 feet Loud television at 3 feet Garbage disposal at 3 feet, 70-80 Gas lawn mower at 100 feet, noisy urban area vacuum cleaner at 10 feet

60-70 Commercial area Normal speech at 3 feet

40-60 Quiet urban daytime traffic Large business office, at 300 feet dishwasher next room Concert hall (background), library, 20-40 Quiet rural, suburban nighttime bedroom at night 10-20 Broadcast/recording studio 0 Lowest threshold of human hearing Lowest threshold of human hearing

Source: (modified from Caltrans Technical Noise Supplement, 2011)

Initial Study 76 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

Noise levels that are generally considered acceptable or unacceptable can characterize various environments. Lower levels are expected in rural or suburban areas than would be expected in commercial or industrial zones. Nighttime ambient levels in urban environments are about 7 decibels lower than the corresponding average daytime levels. The day-to-night noise level difference in rural areas away from roads and other human activity can be considerably less. Noise levels above 45 dBA at night can result in the onset of sleep interference.60 At 70 dBA, sleep interference becomes considerable.

State and Federal Regulation of Industrial Noise Exposure The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) regulates exposure of general industry employees, such as those working in the manufacturing, utilities, and service sectors. Exposure standards are promulgated in Code of Federal Regulations (CFR) Title 29, Section 1910.95. OSHA sets legal limits on noise exposure in the workplace, based on a worker's time-weighted average exposure over an 8-hour day. OSHA's permissible exposure limit (PEL) for noise is 90 dBA for all workers.61 The OSHA standard uses a 5-dBA exchange rate, which means that when the noise level is increased by 5 dBA, the amount of time a person can be exposed to the higher noise level is cut in half. Thus, workers can be exposed to a time-weighted average noise level of 95 dBA for a maximum of 4 hours; exposure to 100 dBA would be limited to 2 hours per day.

OSHA implemented additional noise protections for industrial workers in 1981. In facilities where workers are exposed to a time-weighted average noise level of 85 dBA or higher over an 8-hour work shift, the employer is required to implement a Hearing Conservation Program. The Hearing Conservation Program requires the employer to measure noise levels, provide free annual hearing exams and free hearing protection, provide training, and conduct evaluations of the adequacy of the hearing protectors in use. Alternatively, the employer can implement changes to tools, equipment, and schedules to reduce worker noise exposure of less than 85 dBA.

Worker noise exposure is also regulated by the State of California’s Department of Industrial Relations. Noise exposure limits are promulgated in Title 8, Subchapter 7, Group 15, Article 105 of the California Code of Regulations (CCR). The State regulations effectively mirror the federal regulations. Both sets of regulations require an employer to administer a continuing hearing conservation program whenever employee noise exposures equal or exceed an 8-hour time- weighted average sound level of 85 dBA. The program must include noise exposure monitoring, audiometric testing of employees, provision of personal hearing protection, and other provisions.

City of Richmond Noise Standards Section 15.04.840.010 of the Richmond Municipal Code establishes exterior noise limits that are not to be exceeded more than 30 minutes in any hour, as measured at the property line. In the case of M-3 and M-4 zoning districts (the project is in an M-4 district), the noise limits apply at the district boundary rather than the property line. For these heavy and marine industrial districts, the standards establish a maximum noise level of 75 dBA; at any boundary of a residential zone, the limit is 65 dBA.

The Public Safety and Noise Element of the Richmond General Plan incorporates the community noise exposure guidelines recommended by the Governor’s Office of Planning and

60 U.S. Environmental Protection Agency, Community Noise, 1971. 61 29 CFR 1910.95.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 77

Research. For industrial land uses, CNEL noise levels up to 80 dB are considered Normally Acceptable, while noise exposure up to 85 dB is Conditionally Acceptable, subject to an assessment of appropriate noise-insulation features.

Existing Conditions Existing ambient noise levels in the project vicinity are generally fairly low, with intermittent noise generated from Port operations, including operations of ships and cranes. Traffic volumes on Harbour Way South are low and traffic is not a significant source of noise in the area. Although noise measurements were not taken during environmental review of the proposed log processing and export facility, 24-hour measurements were previously taken by Miller Environmental Consultants that are considered representative of the ambient noise levels in the vicinity of the project. The measurements, which were taken 50 feet from the centerline of Harbour Way South adjacent to the project site, determined that the 24-hour CNEL was 67 dBA 62 and hourly Leq values were between 46 and 66 dBA. These noise levels are well within the noise limits for the M-4 zoning district.

The only noise-sensitive receptor in the project vicinity is Sheridan Observation Point, located at the southern end of the Ford Peninsula, about 300 feet south of the project site, which has a lawn and fishing pier. Although there is an elementary school on the east side of the Ford Peninsula—Benito Juarez Elementary School, at 1450 Marina Way South—it is located approximately 1,350 feet from the front property line of the project site and more than 1,500 feet from the nearest anticipated log handling operations. Furthermore, the two-story historic Ford Assembly Building, which is approximately 950 feet long, lies between the school and the southern project entrance. (This southern portion of the project site, south of the terminal building, provides the greatest opportunity for sound generated by project operations to migrate off-site. North of this relatively open area, the terminal building provides a very effective noise shield.) Due to the considerable distance and the intervening Ford Assembly Building, there is no potential for project noise to adversely affect students at Benito Juarez Elementary School.

In addition to these two sensitive receptors, there could be future residents in the Ford Assembly Building, which is located about 250 feet east of the Terminal 3 truck scales, about 380 feet east of the proposed equipment storage area, and about 400 feet from the nearest log storage deck. Although there are currently no residents occupying the building, live/work is an approved use in the building, and it is likely that residential receptors will be present in the building in the future.

Project-Generated Noise Operation of the proposed project would generate noise from multiple sources, including the following: • arrival and departure of log-hauling trucks; • operation of a front loader to unload trucks and move logs from the log layout deck to the debarking shed; • operation of the debarker; • operation of an excavator to moved debarked logs to the Debarked Log Deck; • periodic emptying of the bark debris container;

62 City of Richmond, Ford Assembly Building Reuse Project Mitigated Negative Declaration, Table N-2: Summary of Existing Noise Measurements, June 2004.

Initial Study 78 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

• daily operation of the street sweeper to clean the site; and • loading of ships.

The loudest noise would be generated by operation of the debarker. Noise comes from the handling chain, the debarking rotor, and the associated drive and transmission systems.

In a noise study of debarking machines at nine different sawmills, operators were equipped with personal noise dosimeters in order to measure actual noise exposure levels over the course of 8-hour work days.63 The microphones for the noise dosimeters were placed approximately 10 centimeters from the operators’ ears. Noise data was collected during two separate work days, one in summer and one in winter. Data was collected from a total of 213 sawmill workers in 13 different job categories, including debarker operator.

Debarker operators had the lowest noise exposure of the 13 job categories. During the summer monitoring, their average noise exposure was 73.6 dB Leq. The collected data reflected both time spent inside the operator cab, where noise exposure was substantially lower, and outside the cab, where noise exposure was more direct. The study noted that the results were skewed upward by variables such as operation of a chainsaw nearby, operation of loud radios inside the operator cabs, leaving the cab door open, and performance of other, noisier jobs during the 8- hour work shift.

The debarker that would be used for the proposed project at Terminal 3 would be equipped with an operator cab that a facility employee would occupy during debarking operations. Based on the noise study cited above, the noise exposure levels for project employees would be expected to be well below the 90-dBA 8-hour PEL and the 85-dBA 8-hour threshold for conducting noise monitoring or implementing a Hearing Conservation Program. Therefore, the proposed project would have a less-than-significant impact from exposure of project employees to operational noise at the proposed log processing facility.

With respect to offsite noise, the debarker would be located inside the existing warehouse building at Terminal 3; its operation would not be audible at the site property line. While the operation of trucks, the front loader, and the excavator would generate noise that would be audible at the property line, it would not be expected to exceed the 30-minute 75-dBA threshold for industrial properties. Shipboard cranes used to load logs onto ships would likely operate on shoreline electric power and would not be audible at the property line. However, in the event they were operated on diesel power, they would generate approximately the same noise level as the excavator, discussed below, but would be located further from the property line on Harbour Way South, and thus would generate lower off-site noise levels than the excavator.

The most significant source of operational noise migrating off-site would be from operation of the excavator and front loader in the vicinity of the outdoor log storage decks. Based on noise data from the Federal Highway Administration’s Roadway Construction Noise Model (RCNM), a typical front loader generates a maximum sound level (Lmax) of 79 dBA at 50 feet, while an 64 excavator has an Lmax of 81 dBA at 50 feet. The Lmax is the highest instantaneous peak noise measurement during any measurement period, and is higher than the average DNL or CNEL noise levels. With attenuation for distance, the noisier excavator could generate an Lmax of 63

63 Niels Kevin Koehncke, University of Alberta, An Investigation of Noise Levels in Alberta Sawmills, Fall 1999. 64 U.S. Department of Transportation, Federal Highway Administration, Construction Noise Handbook, Table 9.1 RCNM: Default Noise Emission Reference Levels and Usage Factors, August 2006.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 79

dBA at the façade of the Ford Assembly Building located on the east side of Harbour Way South, while the average noise level can be assumed to be lower.65

Sound transmission through exterior walls and windows of average construction is reduced by about 20 dBA with windows closed; given the brick exterior of the Ford building, the attenuation is likely more than 25 dBA. Thus, conservatively assuming the lower value, the nearest interior spaces at the Ford Assembly Building could experience maximum instantaneous noise levels of up to 43 dBA. This would be within interior noise limits for residential uses; Title 24, Part 2, California Code of Regulations establishes an interior noise standard of 45 dBA for residential space (CNEL or DNL). In the likely event that future live/work units would be more than 400 feet away from project activity, the actual noise levels would be lower.

These sound levels would be intermittent as equipment moved in and out of the terminal building and around the site. The RCNM indicates that Lmax values for construction equipment, minus 1 dBA, are approximately equivalent to an L10 noise value, assuming the equipment is operated during 40 percent of the measurement period. The L10 is a statistical noise descriptor that is the A-weighted noise level equaled or exceeded during 10 percent of the measurement period. Therefore, the L10 value at the nearest façade of the Ford building could be 62 dBA, while the CNEL or DNL values would be lower. The Ford Assembly Building site has a land use designation of Business/Light Industrial, which allows DNL noise levels up to 80 dBA as Normally Acceptable. The land use compatibility standards established in the General Plan establish a Normally Acceptable DNL of 70 dBA for multi-family residential land use and a Normally Acceptable DNL of 65 dBA for single-family residential land use. Thus, even the higher Lmax values that would be generated by project operations would be well within allowable noise levels for single-family residential land uses.

Based on the preceding analysis, both the interior and exterior noise levels at the Ford Assembly Building due to operational noise from the project would be well within acceptable levels. Therefore, the proposed project would have a less-than-significant impact due to generation of noise levels in excess of applicable local, State, or federal standards.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels?    

Explanation: The proposed project would not generate substantial amounts of groundborne vibration. While workers could experience periodic groundborne vibration from the movement of heavy logs, such vibration would be momentary, intermittent, and not of sufficient intensity to cause damage, unduly annoy workers, or result in perceptible vibration at offsite locations. No railroads operate in proximity to the site and there are no other existing sources of substantial groundborne vibration. The project would have a negligible impact related to groundborne vibration .

65 For point noise sources, the sound level is reduced by approximately 6 to 7.5 dBA for every doubling of distance from the source, assuming level ground, hard surfaces, and no intervening buildings, structures, or vegetation; the attenuation factor is increased by the presence of any of those features. The discussion above conservatively assumes an attenuation factor of 6 dBA.

Initial Study 80 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) A substantial permanent increase in ambient noise levels in the project vicinity above levels existing     without the project?

Explanation: The noise that would be generated by onsite operations is discussed in Section XII(a), above. Trucks hauling logs to the proposed facility would also generate noise along I-580 and Harbour Way South en route to the site. With respect to traffic noise sources, a doubling of traffic volumes is generally required before an increase in ambient noise will be perceived by the average person, corresponding to a noise level increase of 3 dB. As discussed in more detail in Section XVI, Traffic/Transportation, during normal operations, the proposed project is expected to generate a total of 14 truck and auto vehicle trips during both the AM and PM peak hours, with a passenger car equivalent (PCE) of 26 trips. During the limited periods when ship- loading operations would occur, there would be 31 total trips and 43 PCE trips during both peak hours. Existing peak-hour traffic volumes on Harbour Way South are about 408 vehicles and 415 vehicles during the AM and PM peak hours, respectively, at the intersection of Wright Avenue. At Hall Avenue, opposite the project site, the existing volumes on Harbour Way South are about 190 vehicles and 91 vehicles during the AM and PM peak hours, respectively.66 As these figures demonstrate, the proposed project would not come close to doubling existing traffic volumes on Harbour Way South, and the additional traffic on I-580 would represent a minute fraction of existing traffic on this regional freeway. Therefore, the noise that would be generated by the project would have no discernable effect on the ambient noise levels at the site.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) A substantial temporary or periodic increase in ambient noise levels in the project vicinity above     levels existing without the project?

Explanation: The project’s potential noise impacts are addressed in Sections XII(a) and (c), above. The project would not require new construction or other potential sources of substantial temporary noise.

66 Fehr & Peers, Amethod Charter School Transportation Impact Analysis, Figure 2: Peak Hour Traffic Volumes, Intersection Controls, and Lane Configurations–Existing Conditions, June 17, 2015.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 81

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport,     would the project expose people residing or working in the project area to excessive noise levels?

Explanation: The project site is not located within the area governed by an airport and use plan or within 2 miles of an airport.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact f) For a project within the vicinity of a private airstrip, would the project expose people residing or working     in the project area to excessive noise levels?

Explanation: There are no private airstrips in the vicinity of the project.

XIII. POPULATION AND HOUSING — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through     extension of roads or other infrastructure)?

Explanation: The proposed project would not induce population growth. It would not create new housing and would not construct new infrastructure. While it would create employment for five workers, they would likely be already living in the area. Even in the unlikely event that all five employees relocated from outside the area to take the jobs, this would represent minuscule growth relative to the existing population of Richmond and the surrounding region. The longshoremen who would be hired on an intermittent and temporary basis to load ships would be expected to already reside in the area.

Initial Study 82 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Displace substantial numbers of existing housing, necessitating the construction of replacement     housing elsewhere?

Explanation: There is no existing housing on the project site; the project would have no effect on housing.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere?    

Explanation: See Section XIII(b), above.

XIV. PUBLIC SERVICES - Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the following public services:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Fire protection?    

Explanation: Fire response to the project site would be provided by the Richmond Fire Department (RFD), which operates seven stations located throughout the City of Richmond’s geographical area of 56 square miles. The Department currently has a staff of 93 sworn personnel and 4 non-sworn administrative staff.67 The General Plan EIR reported that in 2009 the Department had an acceptable staffing ratio of 1 fire personnel per 4,200 residents.

The RFD responds to approximately 11,000 alarms each year, about 77 percent of them for emergency medical service.68 The Department has a response time goal of responding to 85 percent of emergency calls within 6 minutes or less.

67 Richmond Fire Department, Department Facts, accessed November 25, 2015 at: http://ca- richmond2.civicplus.com/1483/Department-Facts. 68 City of Richmond, Richmond General Plan Update Draft Environmental Impact Report, Section 3.12; Public Services, February 2011.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 83

Fire Station No. 67, located at 1131 Cutting Boulevard, about 4,000 feet (0.76 mile) north of the project, would provide first response to the project in the event of a fire or medical emergency. Fire response time to the site would be well within the Department’s response time goal established in the General Plan.

The RFD has conducted a preliminary review of the proposed project, and identified the following conditions that must be satisfied.69 These will become conditions of approval for the required Conditional Use Permit. Additional fire safety requirements may be identified by the RFD prior to project approval.

1) The applicant shall provide adequate and approved dust collection for any dust producing equipment and/or appliances if the wood process will be occurring within any building on site. All dust producing equipment shall be reviewed by the Richmond Fire Department for compliance prior to installation.

2) In and around all areas which produce possible explosive/combustible dust particles, electrical wiring shall be installed to meet the requirements of Class Division I/II. Plans and specifications for this wiring requirement shall be submitted to the Richmond Fire Department for review and approval prior to installation.

3) All automatic fire sprinkler systems shall require a California State Fire Marshal certification as required by State law. A copy of this certification shall be submitted to the Richmond Fire Department for review prior to allowing occupancy within the fire sprinklered buildings on the premises.

4) Fire extinguishers shall be provided and mounted throughout the site and shall have a service tag affixed to them verifying they have received their annual servicing.

The proposed project would not cause a substantial increase in demand for fire protection services. It would be developed on an existing marine industrial site that has been used for marine cargo operations for many decades. The project would not develop any new structures, and temporary log piles would not create a fire hazard. While the movement and handling of logs would create some potential for worker injury, with just five workers and a health and safety plan required to be prepared and implemented (see Section VI, Geology and Soils), this would not be expected to significantly increase the calls for emergency medical response, and any calls for service that might be generated by the project could readily be accommodated with the RFD’s existing facilities, equipment, and personnel. Therefore, the project’s potential impact on fire protection services would be less than significant.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Police protection?    

Explanation: Police protection would be provided to the project by the Richmond Police Department (RPD), which operates out of a central station at 1701 Regatta Boulevard and has a force of 195 sworn officers.70 The General Plan EIR reported that the RPD had a staffing ratio of

69 John Fitch, Fire Service Specialist, Richmond Fire Department, personal communication, February 8, 2016. 70 Chris Magnus, Chief of Police, Richmond Police Department, RPD Update, Spring 2014.

Initial Study 84 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

1.6 sworn officers per 1,000 residents in 2008.71 The RPD had an average response time in 2009 of 6 minutes and 43 seconds for Priority 1 calls—such as shootings, robberies, burglaries, and assaults—and 14 minutes and 50 seconds for Priority 2 calls.

The proposed project would not cause a substantial increase in demand for police protection services. Although it would generate employment for five workers, there are currently workers at the Terminal 3 site. The project would not create new security concerns and does not entail any uses of the site that might attract criminal activity. It would be expected to have a negligible effect on demand for police protection. Therefore, the project’s potential impact on police protection services would be less than significant.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Schools?    

Explanation: The project would not create new housing and, as discussed in Section VIII(a), is not expected to result in an increase in the population of the City of Richmond. There is therefore no potential for the project to adversely affect schools.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Parks?    

Explanation: As noted in Section IX(c), above, the project would not increase the population of Richmond, and therefore the project would have no effect on the demand for park services.

There is an existing park, Sheridan Observation Point, located about 300 feet south of the project site, at the end of Harbour Way South. Aside from a parking lot and a small observation/fishing pier, this site consists of a strip of sparse grass about 30 feet wide, with some shrubs and a few trees. The site appears to get very little use; in numerous visits by the environmental consultant, no visitors were ever observed at Sheridan Observation Point. Visitors to the small park would likely be able to hear operations at the project site during periods of ship loading or during movement of logs into the Debarked Logs Deck. As discussed in more detail in Section XII, Noise, at this distance the noise levels would not be significant, and would be intermittent. The project would therefore have a negligible effect on park users.

71 City of Richmond, Ibid.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 85

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact e) Other public facilities?    

Explanation: As noted in Section IX(c), above, the project would not increase the population of Richmond, and therefore the project would have no effect on the demand for other public facilities such as libraries.

XV. RECREATION —

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration     of the facility would occur or be accelerated?

Explanation: As discussed in Section IX(c), above, the project would not increase the population of Richmond, and therefore it would have no effect on existing parks or other recreational facilities.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect     on the environment?

Explanation: The proposed project does not include construction of any recreational facilities.

Initial Study 86 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

XVI. TRANSPORTATION/TRAFFIC — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Conflict with an applicable plan, ordinance, or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation, including mass transit and non-motorized travel and relevant     components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit?

Explanation: All truck traffic and most other traffic (i.e., employee trips) would travel to and from the project site via Interstate 580 (I-580) and Harbour Way South. The transportation consulting firm of Fehr & Peers conducted a transportation assessment for the proposed project to identify potential traffic impacts on these roadways, the results of which are summarized in this section.72 The evaluation represents a worst-case analysis because at the time of preparation of the transportation assessment, it was assumed that there would be up to 40 log truck deliveries per day. The project was subsequently revised to entail a maximum of 10 truck deliveries per day. Thus, the analysis presented in this section exaggerates the potential traffic effects of the proposed project.

Earlier in 2015 Fehr & Peers had conducted a traffic impact analysis for the Amethod Charter School project that included an evaluation of existing operating conditions at the intersections of Harbour Way South at Hall Avenue and Harbour Way South at Wright Avenue, the two primary intersections that would be affected by project-related traffic. In that analysis, Fehr & Peers determined that both intersections were currently operating at Level of Service (LOS) A, representing free-flowing conditions, and both would continue to operate at LOS A with the additional traffic that would be generated by the proposed school.

Fehr & Peers estimated the vehicle trip generation for the proposed project based on the project information provided by the project applicant. Because the trucks hauling logs are larger and slower than passenger cars, Fehr & Peers converted the haul truck trips to a passenger car equivalent (PCE), using a PCE of 2.5 vehicle trips per truck, the rate recommended in the 2010 Highway Capacity Manual (HCM). Employees were assumed to travel individually to and from the site in private autos. It was conservatively assumed that each employee (and longshoreman, during ship-loading operations) would leave the site for lunch each day in separate cars, resulting in four daily vehicle trips per employee. It is likely that some employees would remain on site during the lunch break and others would travel offsite in shared vehicles, resulting in fewer actual daily trips generated by the project.

72 Fehr & Peers, Terminal 3 Transportation Assessment, October 2, 2015.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 87

The project is expected to generate 284 daily vehicle trips (PCE), with a maximum of 31 peak- hour trips (43 PCE trips) during both the AM and PM peak hours. This would only potentially occur during ship-loading operations, when an additional 16 longshoremen would work at the facility for about 10 days to load each vessel, which would occur seven to eight times per year. During other times of regular operations, there would be a total of 14 peak-hour vehicle trips (26 PCE trips) during both peak hours and a daily total of about 220 trips. A breakdown of the trips is presented in Table T–1.

Table T–1 Estimated Project Trip Generation

Weekday AM Peak Hour PM Peak Hour Trip Type Daily Trips In Out Total In Out Total

Normal Daily Operations

Workers 20 5 1 6 1 5 6 Trucks 80 4 4 8 4 4 8 PCE1 200 10 10 20 10 10 20 Total Vehicles 100 9 5 14 5 9 14 PCE1 220 15 11 26 11 15 26

Ship-Loading Operations

Workers 84 21 2 23 2 21 23 Trucks 80 4 4 8 4 4 8 PCE1 200 10 10 20 10 10 20 Total Vehicles 164 25 6 31 6 25 31 PCE1 284 31 12 43 12 31 43

Source: Fehr & Peers, 2015 Notes: 1 Truck trips converted to a passenger car equivalent (PCE) of 2.5 trips per truck trip.

Fehr & Peers determined that the 26 to 43 PCE peak-hour trips added to I-580 and the intersections on Harbour Way South would not noticeably affect these facilities or cause a degradation in LOS. Therefore, the proposed project would have a less-than-significant impact on traffic.

Although the project would not have a significant adverse effect on operation of the Harbour Way South/Wright Avenue intersection, the May 2014 Richmond Ferry Terminal Project Initial Study/Mitigated Negative Declaration determined that this intersection would operate unacceptably at LOS F following implementation of the planned Ferry Terminal at the southern end of Harbour Way South. That document found that signalization of this intersection would improve operating conditions to acceptable levels (LOS A). Accordingly. the mitigation for the ferry project consisted of requiring the project to contribute the fair-share amount of funding

Initial Study 88 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

towards the signalization of the intersection. Because the proposed log export facility would add traffic to this intersection projected to be overburdened once the ferry terminal is established, the City intends to require the project applicant to also make a fair-share contribution to the signalization of the intersection. Fehr & Peers calculated the proposed log export facility’s contribution to traffic at the intersection to be 5 percent of total traffic volumes.73

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Conflict with an applicable congestion management program, including but not limited to level of service standards and travel demand measures, or other standards established by the county congestion     management agency for designated roads or highways?

Explanation: A study of Congestion Management Program (CMP) roadways and freeway segments overseen by the Contra Costa County Transportation Authority (CCTA), the applicable congestion management agency, was not required for the project because it would generate fewer than 100 peak-hour trips, the CCTA threshold for CMP analysis. Thus, although the project would cause an incremental increase in traffic on I-580, which is a CMP roadway, the project would not conflict with the Contra Costa County CMP.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Result in a change in air traffic patterns, including either an increase in traffic levels or a change in     location that results in substantial safety risks?

Explanation: The proposed project would have no effect on air traffic patterns.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections)     or incompatible uses (e.g., farm equipment)?

Explanation: Fehr & Peers evaluated the proposed site plan as part of the transportation analysis in order to identify any potential safety hazards or access/circulation problems. The

73 Fehr & Peers, Terminal 3 – Fair Share Contribution Assessment [draft technical memorandum], March 24, 2016.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 89

project would not create new offsite roads or intersections or alter existing offsite roadways. It would utilize two existing driveways to the Terminal 3 site.

Primary access to the project would be provided by a full-access driveway on Harbour Way South, 250 feet north of the Harbour Way South/Hall Avenue intersection. The driveway is 33- feet wide and trucks are expected to turn right into the facility and turn left onto Harbour Way South to exit the facility. This driveway provides adequate sight distance for entering and exiting vehicles. A second driveway, located about 1,200 feet south of the primary driveway would only be used by site workers and visitors. The driveway would not be used by trucks.

Trucks carrying debarked logs would use the primary driveway to enter the facility and drive towards the truck scales on the south side of the site, as illustrated on the site plan (Figure 3). Facility employees would weigh the fully loaded trucks, unload the logs, and weigh the empty trucks before departure. Trucks carrying logs with bark would enter the scale yard north of the truck entrance to be weighed and logs would be unloaded and left in this area until a sufficient amount have been collected to be debarked.

Based on the project site plan, Fehr & Peers determined that the proposed facility would provide for safe vehicle circulation during typical operations. Trucks would enter and exit the facility staggered at 15-minute intervals. It is estimated that a typical truck would spend about 15 minutes on the site. The project site would provide adequate space for trucks to maneuver through the entrance toward the truck scales and exit the log facility. Fehr & Peers noted that the proposed truck route within the project site should be maintained clear of obstructions in order to continue to provide adequate vehicle circulation into, out of, and within the project site. Based on the expected frequency of trucks during peak delivery periods, trucks are not expected to queue within the facility or along Harbour Way South.

Based on the above considerations, the project would not create or increase traffic hazards.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact e) Result in inadequate emergency access?    

Explanation: As discussed in Section XVI(d), above, Fehr & Peers concluded that the plan exhibits adequate site access and on-site circulation for motor vehicles, including fire trucks and other emergency vehicles, and would not alter offsite access routes. Furthermore, prior to project approval, the Richmond Fire Department will be required to sign off on the adequacy of the project plans as they pertain to site access and fire safety issues.

Initial Study 90 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact f) Conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or     safety to such facilities?

Explanation: According to Map 4.1 of the Richmond General Plan 2030, Harbour Way South is designated as an existing Class I bicycle route south of Hall Avenue (opposite the project site) and as a Class III bicycle route between Hall Avenue and Wright Avenue. A short segment of Harbour Way South north of Wright Avenue is designated as a Class II bicycle route. Map 4.1 also designates much of the Ford Peninsula east of Harbour Way South as a Pedestrian Improvement District. Map 10.1 of the General Plan designates Harbour Way South south of Hoffman Boulevard as an existing bicycle and pedestrian trail.

The General Plan does not contain any policies or guidance pertaining to Pedestrian Improvement Districts. In any event, Harbour Way South, the access route for the proposed project, is located outside of the designated Pedestrian Improvement District. Class I Bikeways (Bike Paths) provide a completely separate right-of-way and are designated for the exclusive use of bicycles and pedestrians, with cross-flow of vehicles minimized. Class II Bikeways (Bike Lanes) provide a restricted right-of-way and are designated for the use of bicycles with a striped lane on a street or highway. They are generally 5 feet wide, and vehicle parking and vehicle/pedestrian cross-flow are permitted. The Class III Bikeway (Bike Route) provides a right-of-way designated by signs or pavement markings for shared use of the roadway with pedestrians or motor vehicles.

Implementation of the proposed project would not conflict with the use of Harbour Way South by pedestrians and bicyclists. It is a wide, lightly traveled thoroughfare with a curb-to-curb width of 55 feet, with continuous sidewalks on both sides of the street. North of Hall Avenue there is a striped bike lane on the east side of the roadway. There is ample space along Harbour Way South for bicyclists and pedestrians, with good distance separation from vehicle traffic. While the project would add up to four trucks per hour to the roadway during weekdays, based on multiple visits to the project vicinity during weekdays by the environmental consultant, there is negligible pedestrian and bicycle traffic Harbour Way South at these times. The minor incremental increase in truck traffic along the roadway would not interfere with pedestrian and bicycle travel along this roadway. Although the General Plan notes that there is a need for warning lights, gates, and other improvements at BNSF rail crossing at Harbour Way South and Wright Avenue, the proposed project would not exacerbate safety hazards at this intersection and would not result in any increase in pedestrian or bicycle traffic at this crossing.

Map 4.2 of the General Plan designates Harbour Way South as a Transit Priority Street. Hall Avenue and Harbour Way South north of Hall Avenue are part of a Bay Area Rapid Transit (BART) shuttle route providing connections to the Richmond and El Cerrito Del Norte BART stations.

As previously discussed in Section X(b), all of the Richmond General Plan 2030 policies, including those pertaining to public transit, bicycle, and pedestrian facilities, were reviewed to identify those applicable to the proposed project and evaluate the project’s consistency with those

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 91

policies. In particular, the project would further the City’s goal expressed in Land Use and Urban Design Policy LU3.5, An Economically Viable and Modern Port, which calls for developing the Ford Peninsula area as a working waterfront that supports the Port’s operations and provides opportunities for job-generating uses and other uses. It would also support Economic Development Policy ED8.6, An Economically Viable and Modern Port, which encourages growth and modernization of private port businesses and the Port of Richmond. No conflicts with adopted General Plan policies were identified for the proposed project.

XVII. UTILITIES AND SERVICE SYSTEMS — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board?    

Explanation: Wastewater from the project would be treated at the Richmond Municipal Sewer District’s (RMSD) Wastewater Treatment Plant (WWTP) located at 601 Canal Boulevard, approximately 1 mile northwest of the project site. The RMSD provides wastewater collection service to approximately 68,000 Richmond residents. Veolia Water West Operating Services, Inc., an independent company, operates, maintains, and manages the WWTP as well as the wastewater and stormwater collections systems for a significant portion of the City of Richmond, including the project site. The wastewater treatment plant is permitted by the Regional Water Quality Control Board (RWQCB) and effluent from the plant is regularly monitored to ensure that water quality standards are not violated.

In August 2013 the RMSD adopted a Sewer System Management Plan (SSMP) to comply with RWQCB sanitary sewer overflow (SSO) reporting requirements and also to ensure the WWTP meets the General Waste Discharge Requirements (Statewide WDRs) established by the State Water Resources Control Board (SWRCB). The SSMP lays out a detailed operation, maintenance, and training program for complying with the Statewide WDRs. It also includes an Overflow Emergency Response Plan and plans for ensuring adequate collection and treatment capacity and for monitoring needs for system upgrades. Other goals of the SSMP are to minimize the frequency and severity of SSOs and to mitigate the impacts of SSOs.

Based on a search of violation reports over the past five years, the San Francisco Bay Regional Water Quality Control Board (RWQCB) shows one National Pollutant Discharge Elimination System (NPDES) violation for the WPCP in the past five years.74 In April 2012 a Category 3 violation was logged for deficient monitoring due to failure to report biochemical oxygen demand (BOD) removal. This represented an oversight in monitoring but did not involve a violation of effluent limitations for regulated pollutants. No other violations were reported over the past five years.

74 California Environmental Protection Agency, State Water Resources Control Board, California Integrated Water Quality System Project (CIWQS), Violation Reports, accessed December 7, 2015 at: https://ciwqs.waterboards.ca.gov/ciwqs/readOnly/CiwqsReportServlet?inCommand=reset&reportName=Publi cVioSummaryReport.

Initial Study 92 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

The plant operator is responsible for complying with the applicable wastewater treatment requirements. As indicated by the search results, the Richmond WWTP is generally in compliance with these requirements, as confirmed by the San Francisco Bay RWQCB. Wastewater generated by the proposed project would be typical of wastewater generated throughout the WPCP service area. There is no potential for the project to cause the WPCP to exceed wastewater treatment requirements.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could     cause significant environmental effects?

Explanation: The proposed project would have a negligible effect on demand for water and wastewater treatment capacity. Water consumption would consist of domestic use in bathrooms by employees. Similarly, project employees would generate minor incremental demand for wastewater treatment. The proposed project would be consistent with development envisioned in the Richmond General Plan EIR, which concluded that implementation of the General Plan would not require or result in construction or expansion of water or wastewater treatment facilities. Therefore, the project would have a less-than-significant impact on water treatment and distribution facilities.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Require or result in the construction of new stormwater drainage facilities or expansion of existing facilities, the construction of which could     cause significant environmental effects?

Explanation: The proposed project would not affect existing stormwater drainage facilities. It would not create new impervious surfaces or otherwise affect long-established drainage patterns on the site. The project would not cause any increase in the generation of stormwater. It would therefore have no effect on stormwater drainage facilities.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 93

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Have sufficient water supplies available to serve the project from existing entitlements and resources, or     are new or expanded entitlements needed?

Explanation: The proposed project would be consistent with development envisioned in the Richmond General Plan EIR, which concluded that implementation of the General Plan would not require water supplies in excess of existing entitlements. As noted in Section XVII(b), above, the project would have a negligible effect on water demand for minor domestic use; no process water would be required for the project. Therefore, the project would have a less-than- significant impact on water supplies.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact e) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the     project’s projected demand in addition to the provider’s existing commitments?

Explanation: See Section XVII(b), above.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact f) Be served by a landfill with sufficient permitted capacity to accommodate the project’s solid waste     disposal needs?

Explanation: The majority of waste that would be generated by the proposed project would consist of bark and wood debris stripped from logs. This byproduct would be collected once or twice a week by a recycler based (Agra Marketing Group) and conveyed in 25-ton semi-trailer trucks to end markets in the Bay Area or central California, where the waste bark would be ground up, screened, and used for landscape mulch and potting soil. Other waste generated at the facility would consist of incidental office waste, most of which would also be recycled. The project would generate a negligible amount of solid waste requiring disposal in a landfill.

Solid waste generated in the City of Richmond is currently disposed of at the Potrero Hills Landfill in Solano County. As of early 2011, the landfill had an approved capacity that would

Initial Study 94 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

add 35 years to the remaining capacity of 10 years that was estimated at that time.75 In addition, the City has access to numerous other regional waste disposal facilities used by the West Contra Costa Integrated Waste Management Authority (WCCIWMA), of which the City of Richmond is a member. Given the collective capacities of these facilities, there is more than sufficient landfill capacity to accommodate the City’s landfill disposal needs through buildout of the General Plan in 2030. The proposed project would be consistent with development envisioned in the Richmond General Plan EIR, which concluded that implementation of the General Plan would not require or result in construction or expansion of landfill disposal capacity. Therefore, the project would have a less-than-significant impact on landfill disposal capacity.

XVIII. MANDATORY FINDINGS OF SIGNIFICANCE —

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal     community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory?

Explanation: The project site is an industrial port site that contains no valuable or sensitive habitats, and there is no potential for impacts to biological resources. Although there is a possibility for historic/prehistoric cultural resources to be buried under the site, the project would not require any subsurface disturbance.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Does the project have impacts that are individually limited but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when     viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.)

75 City of Richmond, Richmond General Plan Update Draft Environmental Impact Report, Section 3.13, Public Utilities, February 2011.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 95

Explanation: No significant cumulative impacts were identified for the proposed project. The less-than-significant cumulative impacts are discussed individually in the dedicated resource sections, including air quality, greenhouse gases, traffic, and others.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Does the project have environmental effects that will cause substantial adverse effects on human beings,     either directly or indirectly?

Explanation: Stacked logs on the project site could potentially collapse, particularly in response to strong seismic shaking that could occur during the life of the project, which could potentially injure or kill nearby workers. Measures have been identified in this Initial Study to address this potentially significant impact. Mitigation measures have also been identified to address potentially significant impacts on water quality, which could result in indirect health effects in swimmers in the San Francisco Bay (waterborne diseases) and to those consuming fish or shellfish. Mitigation measures have been identified to reduce these potential impacts to less- than-significant levels. With implementation of all mitigation measures identified in this Initial Study, the project would not have environmental effects that would cause substantial adverse effects on human beings, either directly or indirectly.

Initial Study 96 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

REPORT PREPARATION

This Initial Study/Mitigated Negative Declaration was prepared under the direction of Douglas Herring & Associates, with assistance from the City of Richmond and the Port of Richmond. In addition, the technical consultants listed below contributed to preparation of the Initial Study or produced separate technical reports.

Project Manager: Douglas Herring & Associates 1331 Linda Vista Drive El Cerrito, CA 94530

Doug Herring, AICP, Principal

City of Richmond: Lina Velasco, Senior Planner

Air Quality & Greenhouse Gases: The RCH Group, Inc. 11060 White Rock Road, #150-A Rancho Cordova, CA 95670

Mike Ratte, Senior Air Quality Scientist

Hazardous Materials: KC Engineering 865 Cotting Lane, Suite A Vacaville, CA 95688

Amy Lee, REPA, Environmental Assessor

Traffic/Transportation: Fehr & Peers 1330 Broadway, Suite 833 Oakland, CA 94612

Jackson Lo, Transportation Engineer

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 97

MITIGATION MEASURES

Air Quality Mitigation Measure AQ–1: Fugitive Dust Control Measures: The Applicant shall reduce air emissions by implementing the following fugitive dust control measures, including: • Compliance with Bay Area Air Quality Management District’s (BAAQMD’s) Particulate Matter and Visible Emissions Regulation shall be maintained. • All haul trucks transporting mulch/bark material off site shall be covered. • All visible 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. • All vehicle speeds within the facility property shall be limited to 15 miles per hour. • Use dust enclosures, curtains, and dust collectors as necessary to control dust generation associated with the debarker, including stockpiling from conveyors, front-end loading of materials to vehicular transport, and bin transfer to vehicular transport. Minimize drop heights when transferring any mulch/bark materials. • Inactive mulch/bark material stockpiles (no disturbance of stockpile for more than seven days) shall be wetted, covered, or contained. • 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 pertaining to idling time shall be provided for haul trucks at all access points. • All 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. • A publically visible sign shall be posted with the telephone number and person to contact at the Lead Agency regarding dust complaints. This person shall respond and take corrective action with 48 hours. The BAAQMD’s phone number shall also be visible to ensure compliance with applicable regulations.

Initial Study 98 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

Geology and Soils Mitigation Measure GS–1: Prior to commencement of project operations, the project sponsor shall retain the services of a qualified structural engineer to design appropriate and effective engineering controls for stacked logs, such as steel braces, that would prevent logs from rolling. The braces or other structural controls shall be designed to withstand the expected loads and pressures from stacked logs. The engineer shall determine safe stacking heights and angles, and the project sponsor shall adhere strictly to these limits. In no case shall stack angles exceed 45º. During project operations, logs shall not be stacked higher than the steel braces or other structural controls. Maximum log stack height should be determined by the height at which logs can be safely grabbed.

Mitigation Measure GS–2: If the engineering controls stipulated in Mitigation Measure GS–1 require subsurface disturbance, which could result in secondary environmental impacts not addressed in this Initial Study, the project sponsor shall perform the following additional mitigation prior to conducting any subsurface disturbance of the site: a) The project sponsor shall retain the services of a qualified geotechnical engineer or engineering geologist to prepare a design-level geotechnical investigation for purposes of determining whether the subsurface soils can support the proposed structures and identifying project-specific site preparation requirements and/or foundation design features needed to withstand the expected pressures and loads from the fully loaded log containment structure, both under normal conditions and in conditions of strong seismic ground shaking in the event of a large design-level earthquake. The final plans shall incorporate all of the site preparation, foundation design, and structural design recommendations identified by the geotechnical investigation. The final plans shall be subject to review and approval by the City of Richmond Building Division of the Planning and Building Services Department. During construction, all site preparation work shall be performed under the observation of the Geotechnical Engineering firm of record. The Building Division shall field verify implementation of all of the site preparation, foundation design, and structural design features in accordance with the approved plans prior to the commencement of project operations.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 99

b) The project sponsor shall retain the services of a qualified archaeologist to evaluate the potential for subsurface disturbance to adversely affect Native American or historic cultural resources that could lie buried beneath the site. The results of the cultural resources evaluation shall be documented in a report submitted to the City of Richmond Planning Division. Any recommendations in the report for further evaluation or for mitigation measures to document and prevent any significant adverse effects on the resource(s) shall be implemented prior to the initiation of subsurface work. c) The project sponsor shall develop and implement a work plan for remediating any residual petroleum hydrocarbon contamination in the site’s subsurface soils and/or groundwater (discussed in Section VIII(b) of this Initial Study) in consultation the Contra Costa County Health Services Department and/or the San Francisco Bay Regional Water Quality Control Board, as applicable. The project sponsor shall obtain written clearance from these agencies prior to initiating subsurface work for the proposed project, and shall provide a copy of the clearance(s) to the City of Richmond Planning Division.

Initial Study 100 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY

• Safety procedures shall be established for log handling and movement, including ensuring other employees are not within a safe clearance area around the operations. • Transport vehicles shall be positioned to provide working clearance between the vehicle and the deck. • Only essential personnel shall be allowed in the loading/unloading work area. • No transport vehicle operator shall remain in the truck cab during loading and unloading if logs are moved over the truck cab.

The project sponsor shall ensure that the trainer who provides employee training is qualified through education and/or experience to conduct training.

The site operator shall document the names and dates of employees completing the training program and shall retain the training records on site.

Initial Study TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY 101

protection, including steel-toed boots, hard hats, work gloves, and eye protection.

Hydrology and Water Quality Mitigation Measure WQ–1: The project sponsor shall obtain National Pollutant Discharge Elimination System (NPDES) coverage under the Industrial General Permit (IGP) No. CAS000001, adopted by State Water Resources Control Board (SWRCB) Order No. 2014-0057-DWQ. Pursuant to the Order, the project applicant shall electronically file the Permit Registration Documents (PRDs) via the SWRCB’s Storm Water Multiple Application and Report Tracking System (SMARTS) at: https://smarts.waterboards.ca.gov/smarts/faces/SwSmartsLogi n.jsp. The required PRDs include a Notice of Intent (NOI), a risk assessment, site map, signed certification, Stormwater Pollution Prevention Plan (SWPPP), and other site-specific PRDs that may be required. At a minimum the SWPPP shall include a site map, authorized NSWDs at the facility, and an identification and assessment of potential pollutants sources resulting from exposure of industrial activities to stormwater. The SWPPP must clearly describe the Best Management Practices (BMPs) that are being implemented, who is responsible for the BMPs, where the BMPs will be installed, and when and how often the BMPs will be implemented. The PRDs shall be submitted at least seven days prior to commencing discharge.

Land Use and Planning Mitigation Measure LU–1: Once plans have been developed for appropriate and effective engineering controls for stacked logs at Terminal 3, as required by Mitigation Measure GS–1, City Planning staff shall consult with the San Francisco Bay Conservation and Development Commission (BCDC) to identify any BCDC concerns and/or permit requirements applicable to the proposed project. The project sponsor shall obtain any required BCDC permit and shall comply with any other requirements identified by the Commission prior to initiating project operations.

Initial Study 102 TERMINAL 3 LOG PROCESSING AND EXPORT FACILITY