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HomeMy WebLinkAbout08. Authorize professional consulting services agreements with 1) Yorke Engineering, LLC for $780,000 and 2) GHD, Inc. for $500,000, each for five years for as-needed air quality compliance services Page 1 of 4 Item 8. CENTRAL SAN BOARD OF DIRECTORS POSITION PAPER MEETING DATE: JUNE 2, 2022 SUBJECT: AUTHORIZE THE GENERAL MANAGER TO EXECUTE TWO PROFESSIONAL CONSULTING SERVICES AGREEMENTS WITH: 1) YORKE ENGINEERING, LLC., IN AN AMOUNT NOT TO EXCEED $780,000 AND 2) GHD, I NC., IN AN AMOUNT NOT TO EXCEED $500,000, EACH FOR A FIVE-YEAR PERIOD TO PROVI DE AS-NEEDED Al R QUALITY COMPLIANCE, GREENHOUSE GAS, AND HEALTH RISK ASSESSMENT SERVICES; AND FIND THE AGREEMENTS ARE EXEMPT FROM THE CALIFORNIA ENVIRONMENTAL QUALITYACT SUBMITTED BY: INITIATING DEPARTMENT: RITA CHENG, REGULATORY COMPLIANCE ENGINEERING AND TECHNICAL SERVICES- PROVISIONAL SENIOR ENGINEER ERC-REGULATORY COMPLIANCE REVIEWED BY: LORI SCHECTEL, ENVIRONMENTALAND REGULATORY COMPLIANCE DIVISION MANAGER JEAN-MARC PETIT, DIRECTOR OF ENGINEERINGAND TECHNICAL SERVICES Roger S. Bailey General Manager ISSUE The Board of Directors'authorization is required for the General Manager to execute a technical consulting services agreement in an amount exceeding $200,000. BACKGROUND Central San's Treatment Plant operates under a Title V Major Facility Review Permit issued by the Bay Area Air Quality Management District (BAAQMD) and is subject to additional local, state, and federal air regulations not captured in the Title V permit. BAAQMD recently implemented new air regulations aimed at reducing public health risks from toxic air contaminants emissions, which are described below: June 2, 2022 Regular Board Meeting Agenda Packet- Page 62 of 236 Page 2 of 4 BAAQM D Regulation 11, Rule 18 Health Risk Assessments BAAQMD Regulation 11, Rule 18: Reduction of Risk from Air Toxic Emissions at Existing Facilities (Rule 11-18) requires that facilities found to pose a significant health risk to nearby residents and off- site workers reduce their toxic air contaminant emissions and associated health impacts. Previously, Central San worked with Black and Veatch to develop a baseline treatment plant health risk assessment (HRA) model and evaluate risk reduction strategies. The internal HRA helped Central San gather intelligence prior to the official Rule 11-18 HRA. The new consultant(s)will update the treatment plant air dispersion model and the baseline HRA model with the most recent fuel throughput and meteorological data and update risk reduction HRA scenarios to prepare for Rule 11-18 compliance. In addition to HRA modeling services, the consultant(s) may need to provide technical support during the official Rule 11-18 HRA process. Under Rule 11-18, BAAQMD will publish facilities' HRA results and risk reduction plans for public comment. Central San may ask the consultant(s)to provide support that may include, but is not limited to, a review of BAAQMD's HRA, development support of Central San's Rule 11-18 risk reduction plan, post-capital improvement HRA modeling to demonstrate resulting health risk reductions after wet scrubber installation, as well as support during Rule 11-18 HRA and risk reduction plan public comment period. BAAQM D Regulation 2, Rule 5 Health Risk Assessments I n December 2021, BAAQMD amended Regulation 2, Rule 5 (Rule 2-5) risk reduction requirements, which lowered the cancer risk limit to six in a million for projects with new and modified emissions sources located in and within 1,000 feet of overburdened communities. The southern part of the treatment plant, which includes the Solids Conditioning Building that houses the furnaces and other combustion equipment, is located within 1,000 feet of an overburdened community across from Highway 4. 1 n the near term, Rule 2-5 amendments will affect the permitting process of the Solids Handling Facility Improvements Project, Phase 1 A, which will replace critical solids handling and emissions abatement equipment. Therefore, a new HRA is needed to evaluate project-specific health risks to assist with the permitting of the Solids Handling Facility Improvements Project. The consultant(s)will update the baseline HRA on the furnaces and confirm health risk reduction associated with the wet scrubber replacement. During the permitting process, BAAQMD will conduct the official HRA prior to issuing an Authority-to-Construct permit. The consultant(s)will be asked to review and confirm BAAQMD's HRA findings. Public notification may be required for certain projects subject to Rule 2-5 HRAs.As such, it is imperative for Central San to determine project-specific health risk impacts and be prepared to address any potential public questions or concerns. Additionally, the consultant(s) may be asked to perform greenhouse gas evaluations for the treatment plant and on incineration as described below: Scientific Review of Senate Bill (SB) 1383 Lifecycle Greenhouse Gas Analysis SB 1383 establishes a statewide effort to reduce emissions of short-lived climate pollutants by reducing organic waste disposal 50% by 2020 and 75% by 2025. Starting in January 2022, all jurisdictions will be required to divert organic materials away from landfills and into recycling and recovery activities. Currently, incineration of sewage sludge does not constitute a reduction in landfill disposal. CalRecycle, the oversight agency for SB 1383, will consider additional technologies that are not currently considered a reduction in landfill disposal. For a technology or process to constitute a reduction in landfill disposal, the permanent lifecycle greenhouse gas emission reductions must be equal to or greater than the emission reductions from avoidance of landfilling or composting organic waste. Submittal of an application to CalRecycle is required to consider a technology a reduction in landfill disposal. CalRecycle will then evaluate the application in consultation with the California Air Resources Board. June 2, 2022 Regular Board Meeting Agenda Packet- Page 63 of 236 Page 3 of 4 Central San plans to submit an application requesting CalRecycle to consider incineration of biosolids as a reduction in landfill disposal. Staff is currently finalizing a lifecycle greenhouse gas emission analysis on incineration and ash disposal in comparison to landfill disposal of dewatered sewage sludge. This analysis will be scientifically reviewed by the consultant(s) prior to submission to CalRecycle. Lastly, Central San may utilize consultant support for the upcoming Title V permit renewal and BAAQMD Authority-to-Construct permits. Central San submitted a Title V Major Facility Review Permit renewal application to BAAQMD in 2019, and BAAQMD recently began the review of the Title V permit renewal application. Central San is currently operating under the 2015 Title V Major Facility Review Permit until a new Title V permit is issued. Central San may require the consultant's assistance during the renewal process, specifically with draft permit review and emissions calculations verifications. Additionally, the consultant's assistance may be needed with obtaining Authority-to-Construct permits from BAAQMD for capital improvements that would impact air emissions. I n February 2022, Central San issued a Request for Qualifications to four firms for as-needed air quality compliance, greenhouse gas, and health risk assessment services. Central San received two Statements of Qualifications and interviewed Yorke Engineering, LLC. (Yorke) and GHD, Inc. (GHD). While both firms can provide all of the aforementioned air quality related services, each firm displayed unique capabilities in certain air quality related specialties. Yorke is a small-sized specialty firm with expertise in air quality projects, HRAs, and BAAQMD permit applications and renewals. The firm has worked with over 60 Title V facilities and completed over 300 HRAs in California. Every year, Yorke completes over 1,000 air quality projects in California. Yorke recently assisted a facility under Phase 1 of Rule 11-18 with the official HRA and evaluated risk reduction scenarios. Yorke has worked with other wastewater treatment plants in the Bay Area, such as East Bay Municipal Utility District, Delta Diablo, Union Sanitary District, the City of San Mateo, and the City of Santa Rosa, on Title V permitting and HRA projects. Yorke has assisted Central San with air quality compliance projects in the past. GHD is an international firm with engineering, environmental, and construction expertise and has toxicologists on their staff to assist with potential health risk related concerns that may arise during Rule 11-18 HRA. GHD is an expert in greenhouse gas management, with extensive experience in emissions evaluations as well as reduction and net zero strategies. GHD is currently assisting Central San with the Solids Handling Facility Improvements, Phase 1, and has experience assisting other biosolids incineration plants with their Title V permits. The combined capabilities and experience of both Yorke and GHD will help better position Central San to address any potential air quality challenges and public or regulatory concerns that may arise during the permitting and health risk assessment processes. Therefore, staff recommends establishing agreements with both Yorke and GHD to support Central San's near-term needs. California Environmental Quality Act(CEQA): Staff has concluded that these actions are exempt from CEQA under District CEQA Guidelines Section 15262 since they allow for further planning and feasibility studies for possible future actions which Central San has not approved, adopted, or funded, and the outcome of these tasks will not have a legally binding effect on later activities. Approval of these actions will establish the Board's independent finding that these agreements are exempt from CEQA. Central San will conduct an environmental evaluation of any environmental-altering, physical project that is proposed in the future as a result of these studies to determine the need for any additional CEQA documentation. June 2, 2022 Regular Board Meeting Agenda Packet- Page 64 of 236 Page 4 of 4 ALTERNATIVES/CONSIDERATIONS The Board could decide to reject the proposal, but based on the qualifications at this time, we would likely not receive additional proposals if the RFP was republished. Therefore, this alternative is not recommended by staff. FINANCIAL IMPACTS The total estimated cost for the agreement with Yorke is $780,000, and the total estimated cost for the agreement with GHD is $500,000 if both agreements are fully utilized. Both agreements will cover as- needed services over the next five fiscal years (FYs 2022-27) and will be funded by the Environmental and Regulatory Compliance Division under the Regulatory Compliance Section's FY 2022-2027 budgets. COMMITTEE RECOMMENDATION The Real Estate, Environmental and Planning Committee reviewed this item at its May 18, 2022 meeting and recommended approval. RECOMMENDED BOARD ACTION Staff recommends the following Board action: A. Find the agreements are exempt from CEQA; and B. Authorize the General Manager to execute two professional consulting services agreements with: 1) Yorke Engineering, LLC. in an amount not to exceed $780,000 and 2) GHD, Inc. in an amount not to exceed $500,000, each for a five-year period (FYs 2022-27)to provide as-needed air quality compliance, greenhouse gas, and health risk assessment services. Strategic Plan re-In GOAL ONE: Customer and Community Strategy 2—Maintain a positive reputation GOAL TWO: Environmental Stewardship Strategy 1—Achieve 100% compliance in all regulations, Strategy 2—Anticipate and prepare for potential regulatory changes June 2, 2022 Regular Board Meeting Agenda Packet- Page 65 of 236