Elk Grove Transfer Station Project by wulinqing

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									Final Environmental Impact Report for the
Elk Grove Transfer Station Project




                             SCH #2009042008




                                   Prepared by:
                              EDAW │ AECOM
                                  2022 J Street
                         Sacramento, CA 95811

                                  October 2009
                  Final Environmental Impact Report for the
                Elk Grove Transfer Station Project




                                           SCH #2009042008

                                                     Prepared for:
                                                  City of Elk Grove
                                          8401 Laguna Palms Way
                                             Elk Grove, CA 95758

                                               Attn: Taro Echiburú
                                   Environmental Planning Manager
                                                    (916) 478-3619




                                                      Prepared by:
                                                 EDAW │ AECOM
                                                    2022 J Street
                                            Sacramento, CA 95811


                                                          Contact:
                                                   Douglas Brown
                                                  Project Manager
                                                   (916) 414-5800



                                                     October 2009




P 08110055.01
10.01.09
                                                  TABLE OF CONTENTS
Section                                                                                                                                             Page

1        INTRODUCTION ................................................................................................................................... 1-1

2        COMMENTS AND RESPONSES TO ENVIRONMENTAL ISSUES .............................................. 2-1
         2.1 List of Comments on the Draft EIR ............................................................................................. 2-1
         2.2 Comments and Responses on the Draft EIR ................................................................................ 2-4

3        CORRECTIONS AND REVISIONS TO THE DRAFT EIR .............................................................. 3-1


Appendices

A        Mitigation Monitoring and Reporting Program

Exhibits

4.4-2    Nearest Sensitive Receptors to the Potential Project Sites ........................................................................ 3-5

Tables

1        Written and Oral Comments Received on the Draft EIR .......................................................................... 2-1

3-1      Vehicle Counts for the Elk Grove Transfer Station Facility in the Year 2025.......................................... 3-1

4.2-7    Intersection Control Delay and Level of Service – Baseline Plus Project Conditions .............................. 3-2




Elk Grove Transfer Station Final EIR                                                                                                               EDAW
City of Elk Grove                                                            i                                                          Table of Contents
                                       1       INTRODUCTION
In accordance with §15088 of the State California Environmental Quality Act (CEQA) Guidelines, the City of Elk
Grove, as the lead agency, has reviewed the comments received on the Draft Environmental Impact Report (Draft
EIR) for the Elk Grove Transfer Station Project and has prepared written responses to the comments received.

On July 1, 2009, the City of Elk Grove as the lead agency released for public review the Draft EIR for the Elk
Grove Transfer Station Project. The Draft EIR public review period ended on August 17, 2009.

Chapter 2 of the Final EIR consists of all of the written and oral comments received on the Draft EIR and presents
responses to significant environmental issues raised in the comments (as required by the State CEQA Guidelines
Section 15132). The focus of the responses to comments is on the disposition of significant environmental issues
that are raised in the comments, as specified by Section 15088(c) of the State CEQA Guidelines. Detailed
responses are not provided to comments on the merits of the proposed project. However, when a comment is not
directed to significant environmental issues, the responses indicate that the comment has been noted and that no
further response is necessary.

Each comment letter has been reproduced and is followed by the responses to the comments in order of
occurrence. For example, the response to the fourth comment of the second letter would be indicated as Response
to Comment 2-4. In some instances, responses to comments may warrant modification of the text of the Draft
EIR. In those cases, the text of the Draft EIR is revised and the changes compiled in Chapter 3, Corrections and
Revisions to the Draft EIR. The text deletions are shown in strikeout (strikeout) and additions are shown in bold
underline (bold underline).

This document and the Draft EIR together constitute the Final EIR that is being considered by the City of Elk
Grove.




Elk Grove Transfer Station Final EIR                                                                         EDAW
City of Elk Grove                                      1-1                                              Introduction
                           2           COMMENTS AND RESPONSES TO
                                        ENVIRONMENTAL ISSUES
This section of the Final EIR contains comment letters received during the public review period for the Draft EIR,
which commenced on July 1, 2009 and concluded on August 17, 2009. This section also includes the oral
comments received during the Elk Grove Planning Commission Meeting held on July 6, 2009 to receive
comments on the Draft EIR. In conformance with State CEQA Guidelines Section 15088(a), written responses to
comments on environmental issues received from reviewers of the Draft EIR were prepared.

2.1      LIST OF COMMENTS ON THE DRAFT EIR
Table 1 indicates the number designation for each comment letter received, the author of the comment letter, the
comment letter date, the comment number and the comment topic.

                                                      Table 1
                                 Written and Oral Comments Received on the Draft EIR
Letter                                 Commenter                       Date     Comment        Comment Topic
  #                                                                              Number
  1      California Department of Transportation, District 3,         8/20/09     1-1              Traffic
         Sacramento Area Office; Alyssa Begley
                                                                                  1-2              Traffic
                                                                                  1-3              Traffic
                                                                                  1-4              Traffic
  2      County of Sacramento, Countywide Services Agency,            8/14/09     2-1     Public Health and Hazards
         Environmental Management Department, Environmental
         Compliance Division; Dennis Green
                                                                                  2-2              Other
                                                                                  2-3            Air Quality
                                                                                  2-4        Project Description
                                                                                  2-5        Project Description
                                                                                  2-6              Noise
                                                                                  2-7     Public Health and Hazards
                                                                                  2-8        Project Description
                                                                                  2-9        Project Description
                                                                                 2-10        Project Description
                                                                                 2-11        Project Description
                                                                                 2-12        Project Description
                                                                                 2-13              Other
                                                                                 2-14              Traffic
                                                                                 2-15            Air Quality
                                                                                 2-16              Other
                                                                                 2-17              Noise
                                                                                 2-18       Hydrology and Water
                                                                                                  Quality




Elk Grove Transfer Station Final EIR                                                                       EDAW
City of Elk Grove                                               2-1                        Comments and Responses
                                                  Table 1
                             Written and Oral Comments Received on the Draft EIR
Letter                           Commenter                           Date     Comment         Comment Topic
  #                                                                            Number
                                                                               2-19        Hydrology and Water
                                                                                                 Quality
                                                                               2-20     Public Health and Hazards
                                                                               2-21         Project Description
                                                                               2-22                 Other
                                                                               2-23         Project Description
                                                                               2-24                 Other
                                                                               2-25                 Other
  3      County of Sacramento, Municipal Services Agency,           8/5/09      3-1             Alternatives
         Department of Waste Management & Recycling; Paul Philleo
                                                                                3-2              Air Quality
  4      George H. Larson & Associates, Inc.; George H. Larson      8/14/09     4-1                 Other
                                                                                4-2             Alternatives
                                                                                4-3         Project Description
                                                                                4-4         Project Description
                                                                                4-5                 Other
                                                                                4-6         Project Description
                                                                                4-7             Alternatives
                                                                                4-8             Alternatives
                                                                                4-9              Air Quality
                                                                               4-10         Project Description
                                                                               4-11              Air Quality
                                                                               4-12              Air Quality
                                                                               4-13                 Noise
                                                                               4-14               Land Use
                                                                               4-15                 Other
                                                                               4-16              Air Quality
                                                                               4-17              Air Quality
                                                                               4-18          Noise and Traffic
                                                                               4-19              Air Quality
                                                                               4-20                 Noise
                                                                               4-21         Project Description
                                                                               4-22         Public Services and
                                                                                                 Utilities
                                                                               4-23     Public Health and Hazards
                                                                               4-24     Public Health and Hazards
                                                                               4-25        Hydrology and Water
                                                                                                 Quality
                                                                               4-26                 Other
                                                                               4-27         Project Description


EDAW                                                                              Elk Grove Transfer Station Final EIR
Comments and Responses                                    2-2                                        City of Elk Grove
                                                      Table 1
                                 Written and Oral Comments Received on the Draft EIR
Letter                                 Commenter                     Date     Comment        Comment Topic
  #                                                                            Number
  5      Sacramento Cities/County Solid Waste Advisory Committee    8/10/09     5-1              Other
         & AB 939 Task Force; Patrick Maxfield
                                                                                5-2              Noise
                                                                                5-3              Noise
                                                                                5-4           Alternatives
                                                                                5-5           Alternatives
                                                                                5-6            Air Quality
                                                                                5-7            Air Quality
  6      Sacramento Area Sewer District; Salam Khan, P.E.           7/22/09     6-1        Public Services and
                                                                                                Utilities
                                                                                6-2        Public Services and
                                                                                                Utilities
                                                                                6-3        Public Services and
                                                                                                Utilities
                                                                                6-4        Public Services and
                                                                                                Utilities
  7      Sterns, Donna                                              8/7/09      7-1              Noise
                                                                                7-2              Other
                                                                                7-3              Other
                                                                                7-4              Other
                                                                                7-5        Public Services and
                                                                                                Utilities
                                                                                7-6           Alternatives
                                                                                7-7            Air Quality
  8      Elk Grove Planning Commission Public Hearing               8/6/09      8-1              Traffic
                                                                                8-2     Public Health and Hazards
                                                                                8-3              Noise
                                                                                8-4           Alternatives
                                                                                8-5         Noise and Traffic
  9      California Integrated Waste Management Board, John Loane   8/13/09     9-1        Project Description
                                                                                9-2        Project Description
                                                                                9-3        Project Description
                                                                                9-4        Project Description
                                                                                9-5        Project Description
                                                                                9-6        Project Description
                                                                                9-7        Project Description
                                                                                9-8     Public Health and Hazards
                                                                                9-9              Other
                                                                               9-10              Other



Elk Grove Transfer Station Final EIR                                                                     EDAW
City of Elk Grove                                           2-3                          Comments and Responses
2.2     COMMENTS AND RESPONSES ON THE DRAFT EIR
The written comments received on the Draft EIR and the responses to those comments are provided in this
section. Each comment letter is reproduced in its entirety and is followed by the response(s) to the letter. Where a
commenter has provided multiple comments, each comment is indicated by a line bracket and an identifying
number in the margin of the comment letter.




EDAW                                                                                  Elk Grove Transfer Station Final EIR
Comments and Responses                                   2-4                                             City of Elk Grove
                                                                                                             1




                                                                                                              1-1




________________________________________________________________________________________________________________
Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 1-1                              Responses to Comments
                                                                                                                    1-2



                                                                                                                    1-3



                                                                                                                    1-4




________________________________________________________________________________________________________________
EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 1-2                                        City of Elk Grove
  Letter
      1                California Department of Transportation, District 3, Sacramento Area Office; Alyssa Begley
Response               8/20/09



1-1       The commenter raises concerns regarding the use of SR 99/Elk Grove Boulevard Interchange by vehicles
          generated from the project. The proposed project does not create an impact at the SR 99/Elk Grove
          Boulevard interchange as identified in the traffic analysis included in the Draft EIR (Section 4.2, Traffic
          and Circulation); as such no mitigations for this intersection were identified. A Project Study Report is in
          the process of being completed for the SR 99/Elk Grove Boulevard northbound loop on-ramp project,
          which should be submitted to Caltrans shortly. In addition, this intersection is currently included in the
          City of Elk Grove’s Roadway Fee program.

1-2       The commenter raises a concern regarding the impact of the proposed project on the Grant Line Road/
          State Route 99 interchange based on information included in Table 4.2-7 on page 4.2-45 of the Draft EIR.
          The Grant Line Road/NB State Route 99 Ramps are identified as Intersection 27 in Table 4.2-7. The
          impact results identified for this intersection are incorrectly represented for all scenarios. The information
          provided in Table 7 on page 38 of the Traffic Impact Study (Appendix B to the Draft EIR) correctly
          displays the information. Under Baseline conditions, the Level of Service from without project to with
          project stays the same. As such, no impact occurs at this intersection, as defined by the City of Elk
          Grove’s Traffic Impact Guidelines. In response to this comment, Table 4.2-7 on page 4.2-45 of the Draft
          EIR is hereby revised to incorporate the correct information. The revised table is included in Chapter 3,
          Corrections and Revisions to the Draft EIR, of this Final EIR.

1-3       The commenter recommends that haul trips avoid using State Route 99 between Grantline Road and Elk
          Grove Boulevard between peak hours. Because waste collection activities typically occur during off peak
          periods, few vehicles generated from the proposed facility would be traveling during peak periods on the
          local freeway network. However, the recommendation provided by the commenter is noted by the City.

1-4       The commenter states that if Site 3 or Site 5 are chosen for the project, supplemental traffic analysis
          should occur to identify any impacts to the transportation system. For a discussion of the traffic impacts
          associated with these two alternatives, the commenter is referred to Chapter 6, Alternatives, of the Draft
          EIR. In addition, the Traffic Impact Study included as Appendix B to the Draft EIR included a detailed
          analysis of the project’s impacts if it were to be constructed at Sites 2, 3, 4 or 5. The commenter is
          referred to page 20 of the Traffic Impact Study under Project Description and Traffic Characteristics for
          more information regarding these impacts.




Elk Grove Transfer Station Final EIR                                                                            EDAW
City of Elk Grove                                        Letter 1-3                             Comments and Responses
                         This page intentionally left blank.




EDAW                                                           Elk Grove Transfer Station Final EIR
Comments and Responses                Letter 1-4                                  City of Elk Grove
                                                                                                                                         2
         Countywide Services Agency                                                                  Terry Schutten, County Executive
                                                                                                               Jim Hunt, Acting Agency
         Environmental Management
         Department
                                                                                                                         Administrator
                                                                                                    Val F. Siebal, Department Director
         Environmental Compliance Division
         Dennis Green, Chief                           County of Sacramento

         Taro Echiburú                                                                                              August 14, 2009
         Environmental Planning Manager
         City of Elk Grove
         8401 Laguna Palms Way
         Elk Grove, CA 95758

         Dear Mr. Echiburú:

         SUBJECT:           DRAFT ENVIRONMENTAL IMPACT REPORT (EIR) FOR THE ELK GROVE
                            TRANSFER STATION PROJECT
         Sacramento County Environmental Management Department (EMD) staff have reviewed the
         Draft Environmental Impact Report (DEIR) for the Elk Grove Transfer Station Project in Elk
         Grove, CA. EMD is the Local Enforcement Agency (LEA) for the California Integrated Waste
         Management Board (CIWMB) and has authority and responsibility for regulatory oversight of
         all solid waste handling and disposal sites within the Cities and County of Sacramento. In
         addition, EMD is responsible for the permitting and periodic inspections of hazardous
         materials storage and hazardous waste generating activities at the Transfer Station and the
         household hazardous waste (HHW) area.
                                                                                                                                         2-1
         In addition to the above comments, EMD staff also conducted a data review of its California
         Accidental Release Prevention (Cal ARP) Program and found that two facilities regulated by
         the Cal ARP Program could have potential release impacts on the two proposed locations of
         the Transfer Station. A more detailed presentation of the potential impacts is attached.

         EMD staff will be available to answer any questions related to the attached comments and the
         solid waste facility permit process that follows the approval of the Conditional Use Permit and
         certification of the final EIR. Please feel free to contact Lisa Todd at (916) 876-7883 if you
         have any questions.

         Sincerely,

         [SIGNED]
         Dennis Green
         Chief, Environmental Compliance Division

         DG:LG:gfb

         Attch 1: Comments Regarding Solid Waste Issues
         Attch 2: Comments Regarding Potential Impacts from Cal-ARP Sites
         Attch 3: Comments Regarding Waste/Used Tire Processing and Disposal

         W:\Data\Gibson_Lea\Solid Waste\Special Projects\Elk Grove Transfer Station EIR\DEIR Response Letter August 2009 (4)x.doc



             10590 Armstrong Ave Suite A • Mather, CA 95655 • phone (916) 875-8550 • fax (916) 875-8513 • www.emd.saccounty.net

________________________________________________________________________________________________________________
Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 2-1                              Responses to Comments
                                            ATTACHMENT 1

                             Proposed Elk Grove Transfer Station Sites
                             Comments Regarding Solid Waste Issues


The final EIR (FEIR) will be used by the LEA to make its determination on the issuance of the
project’s Solid Waste Facility Permit (SWFP). Therefore, the proposed transfer station
operations and impacts from the operations as they relate to solid waste regulations need to
be adequately addressed in the FEIR. The following are the LEA staff’s comments on the Draft
EIR:
1.     Table 2-1 p. 2-11: The statement regarding routine cleaning refers to CCR Title 27. The
cleaning requirements for Transfer Stations are actually found in CCR Title 14, Section                             2-2
17407.2.
2.      Table 2-1, p. 2-11: It states that odor control measures will be implemented if
“excessive complaints are received, as defined by the City.” Please define “excessive
complaints.” Additionally, the LEA monitors odors at Transfer Stations and may require odor                         2-3
control measures in response to violations of the State Minimum Standards, per Title 14 CCR
Article 6.2, Section 17408.5.
3.      Section 3.5.1, p.3-6 through 3-9: The first paragraph refers to a “permitted peak
tonnage” of 1,000 tons per day, with an “ultimate peak capacity” of 2,000 tons per day. If the
Operator plans to change their permitted tonnage in the future, they will have to revise their
Solid Waste Facility Permit. This Section also states that self-haul and commercial vehicles
will be “separated from each other.” The facility’s Transfer Processing Report (TPR), which is
required as part of the Solid Waste Facility Permit application package, must include additional
information on traffic flow and traffic safety measures to meet the State Minimum Standards for                     2-4
traffic control (CCR Title 14, Section 17418.3). The TPR must also include additional
information on the load checking program (CCR Title 14 Section 17409.5) and on-site dust
control measures (CCR Title 14 17407.4). Finally, this Section mistakenly asserts that “State
regulations allow waste to remain onsite for no longer than 72 hours,” however, CCR Title 14
Section 17410.1 requires facilities to remove waste within 48 hours. Please correct this error
for the FEIR.
4.      Section 3.5.2 p. 3-9 and 3-10: This Section refers to a “permitted peak tonnage” versus
an “ultimate peak” tonnage. The SWFP must specify the maximum allowable tonnage. If the                             2-5
“permitted peak tonnage” is specified in the SWFP instead of the “ultimate peak” tonnage, then
a SWFP revision would be required to increase the maximum allowable site tonnage.
The fifth paragraph of this Section states that “selected walls of the building may be insulated
to reduce fugitive noise emissions and off-site noise impacts.” Noise control measures should
be further explained in the FEIR. The final paragraph states that some recycled materials may                       2-6
be stored outside of the building. The effects of outdoor storage of recycled materials should
be evaluated, including but not limited to potential vector, odor, and noise issues. Additionally,
please specify removal times for the recycled material.
5.     Section 3.5.3, p 3-10-11: This Section should include the legal definitions of household
hazardous waste (HHW) and a Permanent Household Hazardous Waste Collection Facility
                                                                                                                    2-7
(PHHWCF), as defined in 22CCR 6626010 (Definitions). The FEIR should also reference the
specific regulatory requirements required to operate a PHHWCF as listed under 22CCR

________________________________________________________________________________________________________________
EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 2-2                                        City of Elk Grove
                                         ATTACHMENT 1

66270.60(6), 22CCR 67450.25, and 22CCR 67450.30. Additionally, please provide a more
complete description of how the PHHWCF will document and operate its waste acceptance
from Conditionally Exempt Small Quantity Hazardous Waste Generators (CESQG). This                             2-7
facility will be required to obtain a 'Consolidated Permit' for storage of hazardous materials,               Cont'd
generation of hazardous waste, and a tiered permit for Permit by Rule (PBR) operations of a
Permanent Household Hazardous Waste Collection Facility from EMD.
6.     Section 3.5.6 p. 3-11 and 3-12: The information contained in the DEIR is insufficient to
issue a SWFP that would include these processes. Additional CEQA documentation may be                         2-8
required before the facility is allowed to include these activities. Please see the attached
document for information on accepting and/or shredding waste tires.
7.     Section 3.6 p. 3-12: Please clarify whether the impacts evaluated in the DEIR are
based on a 365 day per year operating schedule or an operating schedule based on the                          2-9
current waste volumes, as described in this Section. Also, please be aware that the days and
hours of the facility operations must be specified in the SWFP.
8.      Section 3.8.1 p. 3-13: Please see comment 3 regarding “permitted peak tonnage”
versus “ultimate peak” tonnage. Also, the Section states the peak daily tonnage could
increase in certain situations, requiring extended hours of operation. Exceeding the permitted                2-10
daily tonnage would constitute a violation of the SWFP. Emergency waivers of any terms or
conditions of the SWFP can only be granted by the LEA during declared emergencies, as
defined in CCR Title 14 Section 17210.
9.     Section 3.8.3, p. 3-14: This Section provides a general overview of the projected
volumes for the PHHWCF and how the facility will accommodate these volumes with staffing
and days of operation. Is it assumed that the proposed square footage of the PHHWCF will be
adequate to account for the expected increases in HHW volume as the population of residents
in Elk Grove increases? The PHHWCF site-specific location should be clearly documented                        2-11
early in the planning process as to how the facility will organize and accumulate the various
hazardous wastes (HHW) and plan for issues such as incompatible wastes (i.e. reactive
cyanides and water reactives) and larger volume wastes such as used oil, bulked paints, and
electronic wastes.
10.    Section 3.10 p. 3-15: Specifies the maximum number of vehicle trips per day and
defines a “vehicle trip” in the terms you intend to use in the SWFP application. The FEIR must                2-12
address the maximum allowable vehicle trips per day to support the vehicle limits in the SWFP.
11.    Section 3.14 p. 3-18 and Section 4.7.2 p. 4.7-8: The document refers to “Sacramento
County Environmental Management Department’s Hazardous Materials Division.” The
                                                                                                              2-13
Hazardous Materials Division is now the Environmental Compliance Division. Please make
this correction in the FEIR.
12.    Section 4.2 p 4.2-25: Please clarify if the total number of vehicles per day is based on
round trips or one way trips, as this information will be used for the permitted traffic volume in            2-14
your SWFP.
13.    Section 4.3.2: The LEA may also issue violations to the facility under CCR Title 14
                                                                                                              2-15
Section 17408.5 for failure to control odors.
14.    Section 4.3.3 p. 4.3-22: This Section references Title 27 regarding routine cleaning
                                                                                                              2-16
requirements; it should reference CCR Title 14, Section 17407.2.
________________________________________________________________________________________________________________
Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 2-3                              Responses to Comments
                                              ATTACHMENT 1

15.    Section 4.4.2 p 4.4-8&9: There is no mention of noise control standards under CCR                            2-17
Title 14 Section 17408.3 in the State Plans, Policies, Regulations, and Laws sub-Section.
16.    Section 4.8.2 p 4.8-5: The facility operator must submit a Notice of Intent and obtain a
General Industrial Permit from the Regional Water Quality Control Board, in addition to a
General Construction Permit. The General Industrial Permit is not specified in this Section.                        2-18
Additionally, once the facility gains coverage under the General Industrial Permit, it will be
inspected triennially by EMD as part of the City of Elk Grove’s stormwater management
program.
17.   Section 4.8.3 p 4.8-13: The Section improperly refers to Article 6 in reference to
drainage requirements. The drainage requirements under Title 14 are found in Article 6.35,
Section 17407.3. This Section also states that the project contractor will obtain a “general                        2-19
NPDES permit.” During project construction, the project contractor may have to obtain
coverage under the General Construction Permit, but once the facility is erected it will require
coverage under the General Industrial Permit. See comment 14.

Please contact Lea Gibson, at (916) 875-8468, regarding comments relating to LEA
observations, and Ryan Artz, at (916) 875-8487, for more information about permitting the
PHHWCF.


DG:LG:gfb
W:\Data\Gibson_Lea\Solid Waste\Special Projects\Elk Grove Transfer Station EIR\Atch 1 Solid Waste Comments.doc




________________________________________________________________________________________________________________
EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 2-4                                        City of Elk Grove
                                           ATTACHMENT 2

                    Proposed Elk Grove Transfer Station Sites
   Comments Regarding Potential Impacts From Nearby California Accidental Release
                               Prevention Facilities

   The two potential sites being considered for this project are near the southern terminus of
   Iron Rock Way (Site 4) and directly southeast of Grant Line Road, northeast of Survey
   Road (Site 2). In addition to these two proposed sites, there are two additional alternative
   sites suggested in the EIR in the event that the two proposed sites are eliminated from
   consideration. This review only addresses the two more likely proposed sites (Sites 2 and
   4) and does not address the two alternative sites.

   Data Summary

   A review of the Environmental Management Department’s (EMD) data shows that the
   proposed project is located near two facilities that use, store, and/or handle regulated
   substances that are specified in Title 19, Section 2770.5 of the California Code of
   Regulation (CCR). These two facilities are:
      •   Georgia-Pacific Resins Inc.                                                                         2-20
      •   Suburban Propane

   Facilities that use, store, and/or handle these regulated substances at or above the
   threshold quantities are subject to the California Accidental Release Prevention (Cal ARP)
   Program (Title 19 CCR, Chapter 4.5, Section 2735 et seq.) and are required to evaluate
   the hazard and impact of accidental releases of regulated substances to the surrounding
   community and to develop and implement risk management measures to prevent these
   accidental releases from occurring. The hazard/impact evaluation and risk management
   measures are documented in a comprehensive plan called the Risk Management Plan
   (RMP).

   As part of the RMP evaluation, the stationary source is required to model and assess worst
   case and alternative case release scenarios.              The model uses an established
   concentration called an end point for that regulated substance and calculates the distance
   that a worst case or alternative case release would take to reach that end point. In broad
   terms, the distance to an end point is the distance a toxic vapor cloud, fire, or explosion
   from an accidental release would travel before dissipating to the point that serious injuries
   from short-term exposure would no longer occur. Using this distance to the end point as
   the radius, a circular impact area, called the vulnerability zone, can be developed.

   To determine if the two proposed sites would be impacted by a worst case or an
   alternative case release from the two Cal ARP facilities, the distance from the vessel
   containing the regulated substance to the property line of the proposed Elk Grove transfer
   station sites are measured using Sacramento County GIS Applications (Parcel Viewer).
   These distances are shown on Table 1. The distances derived by Parcel Viewer are
   approximate only and further study may be necessary to obtain exact distances.
________________________________________________________________________________________________________________
Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 2-5                              Responses to Comments
                Table 1: Distance from Vessel Containing Regulated Substance to
                         Property Line of Proposed Transfer Station Sites
                                                                  Southern Terminus of              Southeast of Grant
                                                                  Iron Rock Way1 (mile)              Line Road1 (mile)
          Georgia-Pacific Resins Inc.
              Phenol Storage and Handling                                    0.152                           0.225
              Formaldehyde Storage and Handling                              0.146                           0.256
              Resin Manufacturing                                            0.181                           0.237

          Suburban Propane
              Propane Storage                                                0.194                           0.100
         1. Distances are approximate and were measured using Sacramento County GIS Applications (Parcel Viewer).


         Next, a summary of the distances to the end points for the worst case and
         alternative case releases from Georgia-Pacific Resins Inc. and Suburban
         Propane as reported in the RMPs are presented in Table 2. Note that the worst
         case release scenario distances were calculated by modeling the release of the
         largest vessel holding the regulated substance. The alternative case release
         scenario distances were obtained by modeling scenarios that are more likely to
         occur than the worst case release scenario.

                                       Table 2: DISTANCE TO END POINTS                                                      2-20
                                                                                                                            Cont'd
                                                Worst Case Release Scenario
                                                                       Regulated                          Distance to End
                              Process                                  Substance                           Point2 (miles)
         Georgia-Pacific Resins Inc.
             Phenol Storage and Handling                                           Phenol                         0.45
             Formaldehyde Storage and Handling                                  Formaldehyde                      0.28
             Resin Manufacturing                                                   Phenol                         0.14
             Resin Manufacturing                                                Formaldehyde                      0.40

         Suburban Propane
             Propane Storage                                                       Propane                        0.80

                                     Alternative Case Release Scenario
                                                                Regulated                                 Distance to End
                              Process                           Substance                                  Point2 (miles)
         Georgia-Pacific Resins Inc.
             Phenol Storage and Handling                         Phenol                                           0.01
             Formaldehyde Storage and Handling                Formaldehyde                                        0.12
             Resin Manufacturing                                 Phenol                                           0.01
             Resin Manufacturing                              Formaldehyde                                        0.03

         Suburban Propane
             Propane Storage                                                Propane                               0.60
           2. The distance to the end point is taken from the Risk Management Plan submitted by the facility to EMD.



                                                                   2
________________________________________________________________________________________________________________
EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 2-6                                        City of Elk Grove
    For propane, the model estimates the distance to an endpoint to an overpressure level of 1
    pound per square inch (psi) from the explosion of the vapor cloud. An overpressure of 1
    psi is unlikely to have serious direct effects on people, but may cause property damage
    such as partial demolition of houses, which can result in injuries to people, and shattering
    of glass windows (EPA General Guidance On Risk Management Programs For Chemical
    Accident Prevention, 2004).

    For toxic substances, such as the ones stored at Georgia-Pacific Resins Inc., the endpoint
    for formaldehyde is 0.012 mg/l (Appendix A of the California Code of Regulations (CCR),
    Title 19, Division 2, Chapter 4.5, Subchapter 1). A toxic endpoint for phenol has not been
    established under CCR Title 19; however, based on studies conducted by the American
    Industrial Hygiene Association Emergency Response Planning Committee, the ERPG-2 for
    Phenol is 50.0 ppm. The ERPG-2 is the maximum airborne concentration below which it is
    believed that nearly all individuals could be exposed for up to 1 hour without experiencing
    or developing irreversible or other serious health effects or symptoms which could impair
    an individual’s ability to take protective action.

    Comparing the distances reported in Table 1 with the distances to the end points as
    reported in Table 2, the distances that fall within the vulnerability zones are bolded, which
    indicate release scenarios that have endpoints reaching the proposed sites for the Elk
    Grove transfer station.
                                                                                                              2-20
    The above comparisons show that a worst case release from three processes (Phenol                         Cont'd
    Storage and Handling, Formaldehyde Storage and Handling, and Resin Manufacturing) at
    the Georgia-Pacific Resins Inc. could impact both proposed transfer station sites.
    However, no alternative case release scenarios reported by Georgia-Pacific Resins Inc.
    would impact either of the proposed transfer station sites. Furthermore, both the worst
    case release scenario and the alternative case release scenario for the release of propane
    could impact either of the proposed sites for the transfer station.

    Discussion

    To understand the information presented above, it needs to be put in proper perspective.
    In California, businesses that engage in storage, usage, and handling of hazardous
    materials are regulated. To protect public safety, the Legislature has enacted several
    pieces of legislation that safeguard the public health and protect the environment. One
    piece of legislation that the California Legislature put in place was the Cal ARP program,
    which regulates a group of acutely hazardous materials. Inherent in this program was the
    recognition that prevention of accidental releases of acutely hazardous materials must be
    a priority. This premise led to a series of stringent requirements that are designed to
    prevent accidental releases from Cal ARP stationary sources.

    Among these requirements is a comprehensive assessment of “what-if“ scenarios. The
    purpose of this assessment, performed by a team of experts in the area of engineering,
    risk analysis, operations, and management from the Cal ARP stationary sources, is to
    identify potential hazards associated with the system and to develop potential release
    scenarios that may result in an off-site release. In each stationary source, at least two

                                                     3
________________________________________________________________________________________________________________
Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 2-7                              Responses to Comments
     release scenarios must be developed and analyzed. However, in reality, many more
     scenarios are developed and studied before the selection and documentation of the two
     required scenarios.

     One such required scenario is the Worst Case Release Scenario, which is defined as the
     release of the largest quantity of a regulated substance from a vessel or process line
     failure that results in the greatest distance to an endpoint (19 CCR 2735.3). In effect, this
     is the catastrophic release scenario. Modeling is required to predict the off-site impact
     area under this release scenario. The modeling information is then graphically presented
     as the vulnerability zone. It is important to note that current engineering advances and
     operational practice make this release scenario unlikely. However, for planning purposes,
     this is useful in establishing the outermost impact area.

     The second required release scenario is the Alternative Release Scenario, which is a
     release other than the worst case. In the development of this scenario, a Cal ARP
     stationary source may have to assess many potential release cases and select one that is
     most likely to occur based on the best judgment of the assessment team. Modeling of
     these many alternative releases are also required, although only one such case is required
     to be documented in the RMP.

     The rigorous hazard assessment and modeling process described above serves as the
     basis for which the Cal ARP stationary source can develop preventive measures and plan
     for emergencies. These preventive measures are documented in a comprehensive                                   2-20
     prevention program, which addresses the hazards identified during the assessment                               Cont'd
     process and, to the degree possible, eliminate these hazards. Facility employees are
     continuously trained in these preventive measures to ensure a level of operational
     competency.

     If an emergency still were to occur after all these safeguards, the Cal ARP stationary
     source has an emergency response program that is designed to rapidly contain the
     release in a well-coordinated manner that is protective of public safety.

     Conclusion

     In summary, our review of the RMPs submitted from the Cal ARP Stationary sources
     concludes that releases from both stationary sources could impact the proposed transfer
     station when considering the unlikely, but possible worst case scenario, a scenario
     involving a catastrophic release. When considering the alternative release scenarios, the
     more likely release scenarios, a release at Suburban Propane could impact both proposed
     sites.

     If you have any questions, please contact Anthony Chu at (916) 875-8405.

     DG:LG:gfb

     W:\Data\Gibson_Lea\Solid Waste\Special Projects\Elk Grove Transfer Station EIR\Atch 2 CAL ARP Comments.doc




                                                           4
________________________________________________________________________________________________________________
EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 2-8                                        City of Elk Grove
                                                    ATTACHMENT 3

                                   Elk Grove Transfer Station-sites
                      Comments Regarding Waste/Used Tire Processing and Disposal

      (Referencing specifically proposed information on page 58 of draft EIR)

      1.     What is the proposed waste/used tire storage limit? 0-499? 500-4999? Or >5000+?
      (Question: What maximum allowable amount of waste/used tires is the facility proposing to allow                          2-21
      on-site at anytime?)

      2.     If a facility is planning to have waste tires brought to, stored at, or disposed of, they must
      obtain a Tire Program ID number (TPID), free of charge, from the CIWMB. If they are planning
      to have 500+ tires (or the equivalent in cubic yards or weight) on-site at any time, they must
      apply to be a ‘Permitted facility’, (minor or major facility permitting). The following must be
      completed and submitted to the California Integrated Waste Management Board:
                                                                                                                               2-22
       A.     A ‘Permit Application’ must be completed and submitted (CIWMB Form 501).
       B.     Complete an ‘Operations Plan’. Must be completed and updated as necessary (CIWMB
              Form 502).
       C.     An ‘Emergency Response Plan’. Must be completed and updated as necessary (CIWMB
              Form 503).

      3.    The third sentence within the paragraph states: ‘Tires could also be shredded on-site to
      consolidate them prior to shipment’.

        A.  Given this processing, what will be the shred size? Shreds larger than ¼ inch or 6mm in
            diameter have a tire equivalency that is determined by volume or weight.
        (1) For volume, shreds 2 inches or smaller are equal to 40 tires per cubic yard. Shreds less                           2-23
             than ¼ inch or 6mm in diameter are not regulated.
        (2) For weight, number of pounds (lbs.) divided by 20 lbs = PTE (Passenger Tire Equivalent).
            1 PTE = 1 Waste Tire.

      Depending upon the decided amount of waste/used tire numbers/volume and shred size on-site
      this may or may not be determined as an activity regulated as a ‘permitted facility’.
      4.    In the last sentence, ‘Tire shredding would be conducted inside of a containment area
      (bunker/building) for safety and noise control’.
                                                                                                                               2-24
        A.    Comment: If this occurs as a ‘Permitted facility’, specific requirements within the Permit
              Application (CIWMB form 501, Section IV. Indoor Storage (17356)) must be met.

      5.     The facility, regardless of permitting requirements, will be required to complete CIWMB
      Form 204 ‘Unregistered Hauler & Comprehensive Trip Log Substitution Form’. This Form                                     2-25
      requires all landfills, transfer stations and disposal facilities to record documentation of
      unregistered haulers disposing of 10 or more tires when entering any disposal facility.

      For more information, contact Derek Jacks or Mike Simpson at (916) 875-8550.

      DG:LG:gfb

      W:\Data\Gibson_Lea\Solid Waste\Special Projects\Elk Grove Transfer Station EIR\Atch 3 Waste Tire Response Comments.doc

________________________________________________________________________________________________________________
Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 2-9                              Responses to Comments
  Letter
      2              County of Sacramento, Countywide Services Agency, Environmental Management Department,
Response             Environmental Compliance Division; Dennis Green 8/14/09



2-1       The commenter identifies their authority in relation to the proposed project. This comment is noted. The
          commenter further states that two existing facilities have the potential to impact the potential project sites.
          More detail regarding this issue is provided in Comment 2-20. For a detailed response to this comment,
          please see Response to Comment 2-20.

2-2       The commenter corrects a reference identified on page 2-11 of the Draft EIR. In response to this
          comment, the first bullet in the Mitigation Measures column on page 2-11 and the last bullet on page 4.3-
          22 is hereby revised as follows:

                  “Routine cleaning of floors, walls, and equipment shall be conducted per the requirements of
                  CCR Title 14, Section 17407.2 27; and”

2-3       The commenter requests that the term excessive be defined as it relates to Mitigation Measure 4.3-5 on
          page 2-11 of the Draft EIR. Mitigation Measure 4.3-5 articulates how the City will respond to odor
          complaints associated with facility operations. However, if multiple complaints are received over a short
          period of time (e.g., three complaints over a one-week period), indicating that there is an operational
          problem that is causing noticeable odors for surrounding land uses, the City would implement the
          additional measures outlined in Mitigation Measure 4.3-5. In addition, as stated by the commenter, the
          Local Enforcement Agency monitors odors at transfer stations and may require odor control measures in
          response to violations of the State Minimum Standards, per Title 14 CCR, Article 6.2, Section 17408.5.

2-4       The commenter states that if the City plans to change the permitted tonnage in the future, they will have
          to revise their Solid Waste Facility Permit. The commenter also identifies the requirements of the
          Transfer Processing Report, which is required as part of the Solid Waste Facility Permit. The City
          appreciates and notes the clarification provided by the commenter on this issue.

          The commenter states that CCR Title 14, Section 17410.1 requires facilities to remove waste within 48
          hours. In response to this comment, the last sentence of the first paragraph on page 3-9 of the Draft EIR
          is hereby revised as follows:

                  “State regulations allow waste to remain onsite for no longer than 48 72 hours following its
                  arrival.”

2-5       The commenter states that the Solid Waste Facility Permit must specify the maximum allowable tonnage
          and that a permit revision would be required to increase the tonnage limit if the permitted tonnage is
          lower than the maximum tonnage. The City appreciates and notes the clarification provided by the
          commenter regarding this requirement and will prepare the Transfer Processing Report for the site
          accordingly.

2-6       The commenter states that noise control measures should be further explained in the Final EIR. As
          identified in Mitigation Measure 4.4-3 on page 4.4-18 of the Draft EIR, the City would be required to
          contract with an acoustical engineering firm to identify the variety of construction solutions that would be
          implemented to reduce offsite noise levels. These measures would typically include the installation of
          sound berms, designing the buildings so they block offsite noise propagation, insulating the building
          walls, limiting the areas where high noise-generating activities could occur, and limiting the operational
          hours, as necessary.


EDAW                                                                                     Elk Grove Transfer Station Final EIR
Comments and Responses                                  Letter 2-10                                         City of Elk Grove
         The commenter states that the effects of the outdoor storage of recycled materials should be evaluated and
         the removal times for recycled materials should be specified. The noise impacts associated with the
         storage of recyclable materials outdoors is associated with the equipment used to move the materials. The
         commenter is referred to Impacts 4.4-3 and 4.4-4 for a discussion of the operational noise impacts
         anticipated with implementation of the proposed project including the use of equipment to move materials
         outside of the facility buildings. The recyclable materials generally do not generate odors or emit other
         air emissions. Therefore, they would not be expected to have any adverse air quality impacts. The
         removal of recyclable materials is generally dictated by market demand but would not be expected to
         remain on the site for periods of greater than six months. The quality of recyclable paper materials can
         degrade quickly if exposed for extended periods of time to the elements. Therefore, they would generally
         be removed from the site on a fairly regular basis.

2-7      The commenter requests that specific definitions be included in the EIR. The definitions provided below
         are derived from CCR Title 22, Section 66260.10.

         Household Hazardous Waste - Any hazardous waste generated incidental to owning and/or maintaining a
         place of residence. Household hazardous waste does not include any waste generated in the course of
         operating a business at a residence.

         Permanent Household Hazardous Waste Facility - A facility operated by a public agency or its contractor
         which: (a) is operated in accordance with section 67450.25; and (b) is permanently sited at a location.

         The commenter also requested that the specific regulatory requirements required to operate a Permanent
         Household Hazardous Waste Facility be referenced in the Final EIR. These regulations include CCR
         Title 22, Sections 66270.60(6), 67450.25 and 67450.30. Due to their substantial length, these regulations
         are not repeated here. However, as a regulated facility, the proposed project would be required to comply
         with all of the applicable requirements listed in these regulations.

         The commenter requests a more complete description of how the Permanent Household Hazardous Waste
         Facility will document and operate its waste acceptance from Conditionally Exempt Small Quantity
         Hazardous Waste Generators. Detailed operational procedures have not yet been developed for the
         acceptance of waste from Conditionally Exempt Small Quantity Hazardous Waste Generators. However,
         the facility would be required to operate consistent with the regulatory requirements applicable to the
         acceptance of waste from Conditionally Exempt Small Quantity Hazardous Waste Generators.

         The commenter clarifies the permitting requirements for the Permanent Household Hazardous Waste
         Facility. This clarification is appreciated and noted by the City.

2-8      The commenter states that the information is insufficient to issue a Solid Waste Facilities Permit for the
         processes identified in Section 3.5.6 of the Draft EIR. The commenter further states that additional
         CEQA analysis may be required before the facility is allowed to include these activities. The activities in
         question include a recyclables drop-off-buy back center, green waste/wood waste drop-off, additional
         resource recovery/processing activities, a repair shop and a HHW re-use area, a truck and equipment
         maintenance center, white goods and scrap metal yard, electronic waste drop-off, tire acceptance,
         construction and demolition waste acceptance, and future waste management and waste conversion. The
         majority of these processes are consistent with the typical operational activities of a transfer
         station/material recovery facility and household hazardous waste collection facility. The environmental
         impacts associated with these processes have been fully evaluated in the Draft EIR with the exception of
         the future waste management and waste conversion activities. Therefore, the need for additional CEQA
         compliance for these activities is not anticipated. As stated on page 3-12 of the Draft EIR, depending
         upon the types of uses that ultimately occur within the future waste management and waste conversion
         areas, subsequent CEQA analysis may be necessary prior to their implementation.


Elk Grove Transfer Station Final EIR                                                                          EDAW
City of Elk Grove                                     Letter 2-11                             Comments and Responses
2-9     The commenter requests clarification regarding the facility’s assumed operating schedule. As stated in
        the last paragraph on page 3-12, the facility may be in operation 365 days per year at some point in the
        future. Therefore, the Draft EIR assumed the facility would be operating 365 days per year and evaluated
        the project’s environmental impacts accordingly. The comment regarding the need to specify the days
        and hours of operation in the Solid Waste Facilities Permit is noted.

2-10    The commenter raises concerns regarding permitted peak tonnage versus ultimate peak tonnage. For a
        response to this concern, please see Response to Comment 2-5. The commenter further states that only
        the LEA can grant emergency waivers to any terms or conditions of the Solid Waste Facilities Permit and
        only during declared emergencies. The City appreciates and notes the clarification provided by the
        commenter regarding this requirement and will prepare the Transfer Processing Report for the site
        accordingly.

2-11    The commenter asks if the proposed square footage of the Household Hazardous Waste Collection
        Facility (HHWCF) will accommodate expected increases in household hazardous waste (HHW) volume
        associated with population growth in the City. The HHWCF is proposed to include an approximately
        30,000 square foot collection center building that would include the collection, processing and storage of
        HHW materials. The size of the HHWCF is intended to accommodate growth in the waste stream.
        Initially the HHWCF is proposed to be open to the public two days per week for all typical HHW, with
        the option of being open daily for the collection of antifreeze, batteries, oil and latex paint. The HHWCF
        would be open to Conditionally Exempt Small Quantity Generators one day a week. In the future, the
        operational hours could increase to accommodate increases in demand associated with population growth.
        However, the analysis in the Draft EIR adequately addresses impacts associated with buildout conditions.

        The commenter states that the facility organization and how it will plan for incompatible and large-
        quantity wastes should be clearly documented. As described on page 3-10 of the Draft EIR, when
        accepting HHW, trained staff would unload the containers onto roll-around carts and bring them inside
        the facility. The materials would then be examined and segregated by type before being packed into
        sealable drums or bulked into larger tanks in preparation for being shipped to regulated disposal sites or
        other processing centers. Accepted hazardous materials would be segregated according to strict protocol
        and would be required to be stored in conformance with all local, state and federal regulations. The
        facility would not accept explosives, radioactive materials or unacceptable medical wastes. For used oil
        and other bulk fluids, a number of above-ground tanks in or near the facility would be used for storage
        prior to being shipped off of the site.

2-12    The commenter states that the Final EIR must address the maximum allowable vehicle trips per day to
        support the vehicle limits in the Solid Waste Facilities Permit. As identified in Table 4.2-6 on page 4.2-
        26 of the Draft EIR, the maximum number of vehicles that would be permitted to access the site is 801.
        This equates to a total of 1,602 one-way vehicle trips being generated by the facility on a daily basis. The
        Draft EIR specifically evaluated the impacts associated with the generation of 1,602 new one-way vehicle
        trips on the local roadway network. Therefore, the impact analysis supports the vehicle limits identified
        in Table 4.2-6 that would be included in the Solid Waste Facilities Permit.

2-13    The commenter corrects a reference identified in the Draft EIR. In response to this comment, the text
        following the first sub-bullet on page 3-18 is hereby revised as follows:

                “a Solid Waste Facilities Permit (SWFP) from the Local Enforcement Agency (Sacramento
                County Environmental Management Department, Environmental Compliance Hazardous
                Materials Division) with concurrence from the California Integrated Waste Management Board
                (CIWMB);”




EDAW                                                                                 Elk Grove Transfer Station Final EIR
Comments and Responses                               Letter 2-12                                        City of Elk Grove
         In addition, the fourth sentence of the first paragraph on page 4.7-8 of the Draft EIR is hereby revised as
         follows:

                   “The LEA for solid waste facilities within Sacramento County is the Sacramento County
                   Environmental Management Department, Environmental Compliance Hazardous Materials
                   Division.”

2-14     The commenter requests clarification regarding the total vehicles per day assumed in Table 4.2-5 on page
         4.2-25 of the Draft EIR. The third column in Table 4.2-5 identifies the total vehicles anticipated to arrive
         at the facility on a daily basis based on vehicle types. The total daily vehicles is 699, assuming two-way
         trips for each vehicle and the use of a franchised commercial hauler. This equates to 1,398 one-way trips.
         For the total daily vehicles anticipated if multiple commercial haulers are used, the commenter is referred
         to Table 4.2-6 on page 4.2-26 of the Draft EIR and Response to Comment 2-12.

2-15     The commenter’s statement that the LEA may also issue violations to the facility under CCR Title 14
         Section 17408.5 for failure to control odors is noted.

2-16     The commenter corrects a reference identified in the Draft EIR. Please see Response to Comment 2-2 for
         a discussion of this correction.

2-17     The commenter cites 14 California Code of Regulations, Section 17408.3 as setting State noise control
         standards applicable to the project site. This section states: “Noise shall be controlled to prevent health
         hazards and to prevent nuisance to nearby residents. Measures to control noise include but are not limited
         to: posting of warning signs that recommend or require hearing protection; separation by barriers that
         limit access to authorized personnel only; or, enclosures to reduce noise transmission. Compliance with
         specific provisions regarding noise control in a local land use approval, such as a conditional use permit
         or CEQA mitigation measures, shall be considered compliance with this standard.” As stated in the Draft
         EIR, the proposed project would be required to comply with these standards.

2-18     The commenter provides clarification regarding the storm water permitting requirements for the proposed
         project. The City appreciates and notes the clarification provided by the commenter.

2-19     The commenter corrects a reference identified in the Draft EIR. In response to this comment, the first
         sentence in the first full paragraph on page 4.8-13 is hereby revised as follows:

                   “The Local Enforcement Agency’s Solid Waste Facilities permit for the potential project sites
                   would prohibit the discharge of drainage containing solids, wash water, or leachate emanating
                   from solid wastes (14 CCR Article 6.35, Section 17407.3).”

         The commenter clarifies the site permitting requirements. For more information on this issue, please see
         Response to Comment 2-18.

2-20     The commenter summarizes information regarding potential impacts from nearby California Accidental
         Release Prevention Facilities. The City appreciates the commenter providing this additional information.
         This information is consistent with the impact analysis included under Impact 4.7-5 on page 4.7-15 of the
         Draft EIR, which concludes that there is a risk of a release of toxic or hazardous materials from either the
         Suburban Propane or Georgia Pacific Resin facilities that could affect the project sites. Although there
         would be a risk associated with locating the proposed project near these facilities, by zoning the potential
         project sites as industrial, the City has determined that industrial land uses are appropriate adjacent to
         these facilities. Therefore, the Draft EIR concluded that the potential risk associated with developing the
         project sites would be considered a less-than-significant impact.



Elk Grove Transfer Station Final EIR                                                                          EDAW
City of Elk Grove                                      Letter 2-13                            Comments and Responses
2-21    The commenter asks that the proposed waste/used tire storage limit be identified. As described on page
        3-12 of the Draft EIR, tires may be accepted at a designated, covered area on the site. However, a
        specific tire limit has not been identified for the proposed project. As described in Comment 2-22, if
        more than 500 used tires are stored on the site at any time in the future, the City will be required to apply
        to be a permitted facility. The commenter does not raise a significant environmental issue; therefore, no
        additional response is necessary.

2-22    The commenter identifies the permit requirements for the facility if it stores more than 500 used tires on
        the site at any time in the future. The proposed project would be required to comply with these
        requirements if the storage threshold is exceeded. The commenter does not raise a significant
        environmental issue; therefore, no additional response is necessary.

2-23    The commenter asks that the shred size be identified for the used tires accepted at the site. The specific
        shred size has not yet been identified for the proposed facility. However, if tire shredding occurs at the
        site in the future, it will be required to comply with all applicable permit requirements. The commenter
        does not raise a significant environmental issue; therefore, no additional response is necessary.

2-24    The commenter states that if tire shredding occurs at the site under the terms of a ‘Permitted facility’,
        specific requirements within the Permit Application must be met. This comment is noted. The City
        would comply with all applicable permit requirements if tire shredding occurs at the site in the future.

2-25    The commenter identifies the reporting requirements for haulers delivering waste tires to the facility. The
        City notes the reporting requirements identified by the commenter on this issue.




EDAW                                                                                   Elk Grove Transfer Station Final EIR
Comments and Responses                                Letter 2-14                                         City of Elk Grove
                                                                                                             3




                                                                                                              3-1




                                                                                                              3-2




________________________________________________________________________________________________________________
Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 3-1                              Responses to Comments
  Letter
      3              County of Sacramento, Municipal Services Agency, Department of Waste Management &
Response             Recycling; Paul Philleo, 8/5/09



3-1       The commenter suggests an alternative to the proposed project that would consist of the direct haul of
          residential and commercial waste from the individual collection routes to the Kiefer Landfill. The City
          currently has the option of hauling collected waste directly to the Kiefer Landfill. However, the City has
          determined that it is more efficient operationally to transfer the waste into transfer trucks prior to
          delivering it to a landfill due to the increased travel distance. The majority of the municipal solid waste
          generated by the residents and business in Elk Grove is currently transported by franchised, commercial
          haulers and private self-haul vehicles to the privately-owned and operated Elder Creek Transfer Station
          located in south Sacramento. The drive from Elk Grove’s city center to this facility is approximately 18
          miles round trip. The direct haul to the Kiefer Landfill would be approximately double this distance.
          Because direct hauling waste from Elk Grove collection vehicles to the Kiefer Landfill would not
          improve the operational efficiencies of the City’s current solid waste management system, it would not
          meet any of the City’s project objectives identified on page 6-2 of the Draft EIR and would not be
          considered a feasible alternative to the proposed project.

3-2       The commenter states that the Final EIR would be more complete if it identifies and compares the
          environmental impacts, particularly the air quality and greenhouse gas impacts, of alternative landfill
          disposal site locations. The specific environmental impacts associated with the delivery of waste
          materials to individual landfills is difficult to determine due to the multiple variables associated with
          landfill operations and their specific geographic locations. For example, some landfills may be easily
          accessible from regional highways while others could be more remotely located, resulting in greater
          impacts on local roads. This also applies to air quality impacts with the impact depending upon the
          typical congestion on the roadways accessing the landfill and the characteristics of the air basin within
          which the landfill is located. However, it can generally be assumed that the further vehicles have to travel
          to access a landfill, the greater the air emissions and associated greenhouse gas impacts that would be
          generated from the haul vehicles.




EDAW                                                                                   Elk Grove Transfer Station Final EIR
Comments and Responses                                  Letter 3-2                                        City of Elk Grove
                                                                                                             4




                                                                                                              4-1




                                                                                                              4-2




                                                                                                              4-3




________________________________________________________________________________________________________________
Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 4-1                              Responses to Comments
                                                                                                                    4-4




                                                                                                                    4-5




                                                                                                                    4-6




                                                                                                                    4-7


                                                                                                                    4-8




                                                                                                                    4-9




                                                                                                                    4-10




________________________________________________________________________________________________________________
EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 4-2                                        City of Elk Grove
                                                                                                              4-10
                                                                                                              Cont'd

                                                                                                              4-11


                                                                                                              4-12

                                                                                                              4-13

                                                                                                              4-14




                                                                                                              4-15




                                                                                                              4-16




                                                                                                              4-17




                                                                                                              4-18




________________________________________________________________________________________________________________
Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 4-3                              Responses to Comments
                                                                                                                    4-19




                                                                                                                    4-20




                                                                                                                    4-21




                                                                                                                    4-22




                                                                                                                    4-23




                                                                                                                   4-24




________________________________________________________________________________________________________________
EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 4-4                                        City of Elk Grove
                                                                                                              4-24
                                                                                                              Cont'd




                                                                                                              4-25




                                                                                                              4-26




________________________________________________________________________________________________________________
Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 4-5                              Responses to Comments
                                                                                                                    4-26
                                                                                                                    Cont'd




                                                                                                                    4-27




________________________________________________________________________________________________________________
EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 4-6                                        City of Elk Grove
  Letter
      4
Response               George H. Larson & Associates, Inc.; George H. Larson 8/14/09



4-1       The commenter asks how the City plans to implement public outreach to the community regarding the
          impacts and mitigation measures for the proposed project. The City has held ten community meetings to
          discuss the proposed project and the EIR process. The City has also developed a link on the City’s
          Integrated Waste Division website that provides detailed information regarding the proposed project and
          the community outreach process. The Integrated Waste Division’s website can be accessed at the
          following address: http://www.egtrashrecycleservices.org/index.asp. The project link on this website is
          identified as “Transfer Station Project”. This link includes a digital version of the Draft EIR.

4-2       The commenter states that the Draft EIR should fully describe the environmental impacts of a rail haul
          option. Both potential project sites are located adjacent to a Union Pacific Rail Line. However, the
          project proposes to use transfer trucks to transport residual waste material from the site. The project does
          not include rail haul as an option and therefore, the environmental impacts associated with hauling waste
          by rail were not evaluated in the Draft EIR. If the City decides to explore a rail haul option in the future,
          additional environmental review consistent with the requirements of CEQA and the State CEQA
          Guidelines would be necessary.

4-3       The commenter’s opinion that the square footage of the proposed buildings seems high in relation to the
          tonnage to be processed is noted. The sizes of the proposed buildings on the sites are intended to
          accommodate peak-period waste volumes and growth in the waste stream. As described on page 3-13 of
          the Draft EIR, the proposed peak tonnage for the facility would initially be 1,000 tons per day. This peak
          tonnage limit would ultimately increase to 2,000 tons per day of municipal solid waste and 500 tons per
          day of recyclable materials.

          The commenter requests that the costs and environmental impacts be justified on a per square foot basis.
          The analysis of the facility’s costs is outside of the scope of this EIR. Therefore, no additional response is
          provided.

          The commenter requests that justification be provided regarding why the project should not be
          constructed in phases. The commenter is referred to the last paragraph on page 3-5 of the Draft EIR,
          which states that the construction of the facility is proposed to be implemented in phases, with the timing
          of specific project components dictated by the City’s evolving waste management requirements. As this
          paragraph in the Draft EIR states, because the City’s future waste management requirements cannot be
          determined at this time, there is the possibility that some of the project components may never be
          constructed.

4-4       The commenter states that the environmental impacts of the proposed project should be considered in the
          context of the regional solid waste management priorities and questions the justification for the facility.
          For a discussion of the project purpose, the commenter is referred to page 3-4 of the Draft EIR. The City
          is proposing the project consistent with the objectives identified on page 3-5 of the Draft EIR.
          Specifically, the City is proposing the project in order to provide convenient, cost-effective and
          environmentally sound waste management services for the citizens of Elk Grove. In considering the
          proposed project, the City has taken into consideration the regional solid waste management facilities that
          are currently in place and how the proposed project would fit within the context of these facilities.




Elk Grove Transfer Station Final EIR                                                                            EDAW
City of Elk Grove                                       Letter 4-7                              Comments and Responses
4-5     The commenter asks if there is a need to establish buffer lands around the facility. The potential project
        sites are both located within industrial areas on parcels zoned for industrial uses. The proposed project is
        consistent with these uses. Therefore, the establishment of buffer lands is not necessary or required.

4-6     The commenter requests a matrix or flow diagram that identifies current and future waste material flows
        for the City of Elk Grove. For a discussion of the current waste material flows within the City, the
        commenter is referred to the project history and purpose described on page 3-4 of the Draft EIR. For a
        discussion of the materials that would be processed at the proposed facility, the commenter is referred to
        the discussion of project components commencing on page 3-5 of the Draft EIR.

        The commenter requests that distances to disposal locations be identified in the Draft EIR. As identified
        on page 3-17 of the Draft EIR, possible destinations for disposal of residual wastes include the Potrero
        Hills Landfill located approximately 70 miles to the west in Solano County, the Kiefer Landfill located
        approximately 18 miles to the east in Sacramento County, the Lockwood Landfill located approximately
        130 miles to the northeast in Reno Nevada, and the Forward Landfill located approximately 40 miles to
        the south in San Joaquin County.

4-7     The commenter requests that construction of the HHW facility be considered at the existing corporation
        yard or another location such as the separate property under Alternative #4. As described on page 2-4 of
        the Draft EIR, the City has considered building a HHWCF at the existing corporation yard located
        directly west of Site 4. This alternative was not evaluated in the Draft EIR but could be considered by the
        City, subject to subsequent CEQA environmental review. Regarding the reference to Alternative #4, the
        commenter is assumed to be referencing the construction of a HHWCF on either Site 4 or 2. For a
        detailed discussion of the environmental impacts associated with this alternative, please see pages 6-10
        through 6-14 of the Draft EIR.

4-8     The commenter states that information regarding prospective conversion or alternative energy
        technologies would be helpful. The proposed project does not include the use of conversion or alternative
        energy technologies. However, the commenter is referred to the discussion of alternative solid waste
        management technologies included on page 6-14 of the Draft EIR. These technologies include
        incineration, pyrolysis and gasification.

4-9     The commenter requests an analysis that compares the emissions reductions associated with reduced truck
        trips to the new emissions associated with facility construction and operations. For a detailed discussion
        of the project’s cumulative greenhouse gas impacts associated with project construction and operations,
        the commenter is referred to page 5-39 of the Draft EIR.

4-10   The commenter requests that the mileage savings for the transport and recycling of materials under the
       proposed facility operations be described. For a detailed estimate of the vehicle miles traveled both with
       and without the facility, the commenter is referred to Table 4.3-5 on page 4.3-18 of the Draft EIR. The
       commenter requests that the end user markets for all recyclable materials be identified. The end user
       markets for recyclable materials vary according to fluctuations in market conditions. Following
       construction of the facility, the City would identify the recyclable materials companies best suited to
       receive processed recyclable materials from the facility.

4-11    The commenter requests that the practices to address noise and odor issues be explained. For a detailed
        discussion of the project’s noise and air quality impacts and associated mitigation measures, the
        commenter is referred to Section 4.4, Noise, and Section 4.3, Air Quality, of the Draft EIR.

4-12   The commenter requests that specific mitigation measures be provided should concrete and wood waste
       grinding equipment be brought onto the site. As described on page 3-12 of the Draft EIR, any grinding or
       crushing operations would be conducted inside of a containment area (bunker/building) for safety and
       noise control. In addition, as required by Mitigation Measure 4.4-3 on page 4.4-18 of the Draft EIR (for

EDAW                                                                                  Elk Grove Transfer Station Final EIR
Comments and Responses                                Letter 4-8                                         City of Elk Grove
         Site 4 only), high noise generating activities, such as the use of grinding equipment, shall occur in the
         southern portion of Site 4 to minimize noise levels for sensitive receptors to the north and northwest.

4-13     The commenter requests that the methods for noise control be described. The commenter is referred to
         Mitigation Measures 4.4-1, 4.4-3 and 4.4-4 included in Section 4.4, Noise, of the Draft EIR for a
         discussion of noise control measures identified for the proposed project.

4-14     The commenter requests that the land use issues associated with full buildout of the new shopping mall be
         fully evaluated. The partially constructed Elk Grove Promenade Shopping Mall is located west of State
         Route 99. Therefore, other than the shopping mall’s impacts on regional traffic patterns following its full
         buildout, it would not be expected to have any land use ramifications on the proposed project. For a
         discussion of the cumulative traffic impacts associated with development of the shopping mall and the
         proposed project, the commenter is referred to Chapter 5, Cumulative and Growth-Inducing Impacts, of
         the Draft EIR. For more information on this issue, the commenter is also referred to the EIR that was
         prepared for the Elk Grove Promenade Shopping Mall, which is available on the City of Elk Grove’s
         website.

4-15     The commenter raises concerns regarding ordinances that have not been adopted by the City. Because the
         ordinances referenced by the commenter have not been adopted, they are considered speculative at this
         time and their effects on the proposed project are unknown.

4-16     The commenter requests that cumulative construction emissions be identified. The commenter is referred
         to Table 4.3-4 on page 4.3-15 of the Draft EIR for an identification of the project’s cumulative
         construction emissions. The commenter further identifies specific construction air quality requirements
         for the proposed project. These suggested requirements are noted. For the project’s construction air
         quality mitigation requirements, the commenter is referred to Mitigation Measure 4.3-1 commencing on
         page 4.3-16 of the Draft EIR.

4-17     The commenter requests that detailed studies be conducted and detailed monitoring be performed for the
         proposed project. However, the commenter provides no specific justification for these studies or
         monitoring requirements. For the project’s construction air quality mitigation requirements, the
         commenter is referred to Mitigation Measure 4.3-1 commencing on page 4.3-16 of the Draft EIR.

4-18     The commenter recommends limiting construction activities to specified hours of the day and week. As
         identified in Mitigation Measure 4.4-1 on page 4.4-15 of the Draft EIR, construction activities would be
         limited to between the hours of 7:00 a.m. and 7:00 p.m., Monday through Friday, and between the hours
         of 7:00 a.m. and 7:00 p.m. on Saturday and Sunday, in accordance with the City’s General Plan noise
         policies and the City’s Noise Ordinance.

4-19     The commenter requests that the site’s odor control systems be fully described. As described on page
         4.3-22 of the Draft EIR, odor impacts associated with transfer stations typically occur as a result of poor
         management, if waste is maintained onsite for extended periods of time (i.e., greater than 48 hours), or if
         waste is processed in exterior areas. Compliance with existing regulatory requirements (i.e., 14 CCR §
         17408.5) would require maintenance and operational practices that would ensure that the proposed facility
         would not have a nuisance odor-related impact to nearby receptors.

         In addition, to control odorous emissions from the proposed facility, all municipal solid waste materials
         would be unloaded, processed, and loaded onto transport vehicles completely inside the main building.
         Interior operations would include a water vapor misting system to reduce air-borne dust. In addition,
         passive air exhaust systems would be used to maintain a negative pressure at the exterior openings of the
         building to minimize fugitive dust and odors. All wastes would be required to be removed from the
         facility within 48 hours of receipt.


Elk Grove Transfer Station Final EIR                                                                           EDAW
City of Elk Grove                                      Letter 4-9                              Comments and Responses
        The commenter further states that keeping doors closed in order to minimize odors seems unlikely due to
        the projected number of vehicles arriving at the site. The measure to which the commenter refers is just
        one of four separate odor mitigation measures identified in Mitigation Measure 4.3-5. Closing the
        facility’s doors to control odors would be effective during periods of low traffic volume, such as during
        the summer afternoons when the collection vehicles have finished tipping their loads (usually by 3:00
        p.m.). However, implementation of the other odor control measures would be necessary during periods of
        high traffic volume.

4-20    The commenter requests that the City of Elk Grove noise level standards for night operations be fully
        described. The commenter also asks how each site will fully comply with the City’s noise standards. For
        a discussion of the City’s noise standards, the commenter is referred to the discussion of the City’s Noise
        Element and Noise Control Ordinance commencing on page 4.4-11 of the Draft EIR. For a discussion of
        how the project would comply with the City’s noise standards, the commenter is referred to Mitigation
        Measures 4.4-1, 4.4-3 and 4.4-4 commencing on page 4.4-15 of the Draft EIR.

4-21   The commenter states that the Draft EIR should include a matrix and flow diagram identifying waste
       types and disposal locations. For a discussion of the waste generation within the City of Elk Grove and
       the disposal locations for these materials, the commenter is referred to the discussion of operational
       capacities commencing on page 3-13 of the Draft EIR.

4-22    The commenter requests specific details regarding fire protection services within the City of Elk Grove
        and their capability to manage fires at the proposed facility. The commenter also requests a map showing
        the location and fire suppression capabilities of specific fire stations. The commenter is referred to page
        4.5-4 of the Draft EIR for a detailed description of the fire and emergency medical response services
        provided by the Cosumnes Community Services District in the City of Elk Grove. This description
        identifies all of the fire stations that would be responsible for responding to an incident at the potential
        project sites, the staffing and equipment for these stations, the service capabilities for each station, and
        their addresses. The discussion also identifies the number of calls received in 2006 (the last year for
        which data are available), the response standard goal, and the funding sources for the District’s fire and
        emergency response services. In addition, page 4.5-9 of the Draft EIR includes a discussion of the
        emergency response and evacuation plans for the City and the applicable fire codes and guidelines. For a
        discussion of the Draft EIR’s conclusion regarding the project’s impacts on fire protection services, the
        commenter is referred to Impact 4.5-4 on page 4.5-13 of the Draft EIR.

4-23    The commenter states that the environmental document should include an assessment by an independent
        expert of the potential threat to the project sites associated with the Suburban Propane and Georgia Pacific
        Resin facilities. The Draft EIR includes a detailed summary of the Quest Consultants’ study prepared in
        2003 that identified the potential risks associated with these facilities. The commenter is referred to this
        summary commencing under Impact 4.7-5 on page 4.7-15 of the Draft EIR. Although there would be a
        risk associated with locating the proposed project near these facilities, by zoning the potential project sites
        as industrial, the City has determined that industrial land uses are appropriate adjacent to these facilities.
        Therefore, the Draft EIR concluded that the potential risk associated with developing the project sites
        would be considered a less-than-significant impact.

4-24    The commenter requests that the funding sources be identified for the additional demands on City staff
        associated with project implementation. The discussion of the facility’s costs is outside of the scope of
        this EIR. Therefore, no additional response is provided.

4-25    The commenter raises concerns regarding water quality and drainage associated with site development.
        For a detailed discussion of the water quality mitigation measures that would be required during both
        construction and site operations, the commenter is referred to Mitigation Measures 4.8-2 and 4.8-3
        commencing on page 4.8-11 of the Draft EIR. For a discussion of the facility requirements related to


EDAW                                                                                   Elk Grove Transfer Station Final EIR
Comments and Responses                                Letter 4-10                                         City of Elk Grove
         accidental releases and spills of hazardous substances, the commenter is referred to the discussion under
         Impact 4.7-3 commencing on page 4.7-13 of the Draft EIR. For a discussion of the facility’s State and
         federal water quality permitting requirements, the commenter is referred to the regulatory setting
         discussion commenting on page 4.8-4 of the Draft EIR’s Hydrology Section.

4-26     The commenter states that the Draft EIR fails to identify the environmental impacts of the proposed
         project on a regional basis because there is no demonstrated need for additional transfer facility capacity.
         For a discussion of the project purpose, the commenter is referred to page 3-4 of the Draft EIR. The
         analysis of environmental impacts in the Draft EIR included an assessment of the regional impacts
         anticipated with project implementation including the project’s impacts on the regional roadway network
         and the regional air basin. In addition, regional impacts were considered when evaluating the cumulative
         impacts in the Draft EIR. Specifically, Chapter 5, Cumulative and Growth-Inducing Impacts, evaluated
         the regional impacts that would occur when the project’s impacts where combined with the impacts
         anticipated with the regional development that would occur over the next 20 years in the project area.

4-27     The commenter states that the size of the project does not seem to be justified based on the volume of
         waste generated in the City and suggests implementing the project in phases. The construction of the
         facility is proposed to be implemented in phases, as identified in the last paragraph on page 3-5 of the
         Draft EIR, with the timing of specific project components dictated by the City’s evolving waste
         management requirements. As this paragraph in the Draft EIR states, because the City’s future waste
         management requirements cannot be determined at this time, there is the possibility that some of the
         project components may never be constructed.

         The commenter requests that the costs to service the debt on the proposed facility be disclosed. The
         discussion of the facility’s costs is outside of the scope of this EIR. Therefore, no additional response is
         provided.




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Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 5-3                              Responses to Comments
  Letter
      5              Sacramento Cities/County Solid Waste Advisory Committee & AB 939 Task Force; Patrick
Response             Maxfield 8/10/09



5-1       The commenter states that the Solid Waste Advisory Committee may, at a future date, elect to make a
          recommendation to the Elk Grove City Council regarding the merits of the proposed project. Based on
          the Solid Waste Advisory Committee’s expertise regarding regional solid waste management, the City
          would greatly appreciate receiving recommendations from the Committee on the merits of the proposed
          project in the future.

5-2       The commenter suggests that Exhibit 4.4-2 be revised to include reference to and identification of
          sensitive receptors such as Soaring Oaks Church. In response to this comment, Exhibit 4.4-2 on page 4.4-
          7 of the Draft EIR is hereby revised to incorporate the commenter’s suggested edits. The revised exhibit
          is included in Chapter 3, Corrections and Revisions to the Draft EIR, of this Final EIR.

5-3       The commenter encourages the City to develop, refine and consider additional noise mitigation measures
          to reduce the severity of Impact 4.4-3. As the commenter states, the analysis of noise impacts
          conservatively estimated the facility’s operational noise levels based on noise data collected at the
          Sacramento Recycling and Transfer Station. Although the noise data from this facility may overestimate
          the noise levels associated with the proposed project due to differences in facility design, they provide
          quantitative measurements of transfer station noise levels that are useful in conducting the environmental
          impact analysis. Even with the use of this conservative noise data, the daytime operational noise impacts
          at the nearest residential land uses were determined to be less than significant.

          The noise level threshold is exceeded at the Soaring Oaks Presbyterian Church due to the unusual
          circumstance of the church being located in an industrially-zoned area near the site and the City’s Noise
          Control Ordinance specifically restricting noise levels at churches while in use. The City of Elk Grove
          Noise Control Ordinance states in Section 6.68.110 that noise levels at churches while in use can not
          exceed 55 dBA between 7:00 a.m. and 10:00 p.m., and can not exceed 50 dBA between 10:00 p.m. and
          7:00 a.m. Because the Soaring Oaks Presbyterian Church is located only approximately 300 feet from Site
          4, it could experience intermittent exterior noise levels as high as 70 dBA, depending upon how the
          facility is designed and the location of noise-generating activities in relation to the church. Because this
          noise level would clearly exceed the City’s permitted noise level for churches and it could not be
          guaranteed that mitigation measures would reduce the noise levels to below the City’s Noise Ordinance
          requirements, the Draft EIR concluded that this impact would be considered significant and unavoidable
          for Site 4.

          The noise threshold applied in the Draft EIR is applicable at the property boundary of the receiving
          property. Being located within an industrial area, the Soaring Oaks Presbyterian Church does not include
          any outdoor activity areas and would not typically be in use during the nighttime (10:00 p.m. to 7:00
          a.m.) when the more restrictive 50 dBA exterior threshold would apply. Therefore, all of the activities at
          the church would occur indoors generally during daytime hours. As noise passes from the exterior into
          the interior of a building, the noise levels are typically reduced by approximately 15 decibels. In addition,
          noise Mitigation Measures 4.4-3 and 4.4-4 identified on pages 4.4-18 and 4.4-19, respectively, of the
          Draft EIR, would further reduce the interior noise levels experienced at the church by limiting the noise
          generation from the facility. A 10 decibel reduction in the noise generation from the facility with
          implementation of the mitigation measures identified would be a reasonable estimate of the mitigation
          effectiveness, which would reduce the peak noise levels of 70 dBA at the church property line to 60 dBA.
          Based on the 15 decibel reduction at the interior of the church, the interior noise levels would likely not
          exceed the generally accepted interior noise level threshold of 45 dBA and would not be expected to


EDAW                                                                                    Elk Grove Transfer Station Final EIR
Comments and Responses                                  Letter 5-4                                         City of Elk Grove
         disturb church activities. This being said, if the noise levels at the church property line remained at 60
         dBA, they would continue to exceed the City’s Noise Ordinance requirements. Based on the City’s
         conservative approach in evaluating the noise impacts of the proposed project, this noise impact would
         remain significant and unavoidable and no changes have been made in the Draft EIR’s noise impact
         conclusions.

5-4      The commenter suggests that the Final EIR consider an alternative consisting of the household hazardous
         waste collection facility being located at Site 4 and all other project elements being located at Site 3.
         Chapter 6, Alternatives, of the Draft EIR includes an Offsite Development Alternative - Site 3 that
         assumes development of either the proposed transfer station operations or the household hazardous waste
         collection facility at Site 3. This chapter also includes a Household Hazardous Waste Collection Facility
         Only Alternative that assumes the development of a household hazardous waste collection facility at Site
         4 or 2. The environmental impacts associated with both of these options is described in detail in Chapter
         6 of the Draft EIR. Although the specific alternative identified by the commenter that includes the
         development of two separate project components on two separate sites is not discussed in the Draft EIR,
         sufficient information is provided in the Draft EIR to allow the City’s decision makers to understand and
         consider the potential impacts associated with this combined alternative in their deliberations on the
         proposed project.

5-5      The commenter’s suggestion that rail haul alternatives be considered in the Final EIR is appreciated by
         the City. For more information regarding a rail haul alternative, the commenter is referred to Response to
         Comment 4-2.

5-6      The commenter requests that an explanation be provided regarding why the URBEMIS model was chosen
         for this project and the merits of this modeling program relative to others. The URBEMIS 2007 program
         was used because it was recommended by the Sacramento Metropolitan Air Quality Management District
         for assessing the air quality impacts associated with land development. The URBEMIS program is
         specifically designed to model construction emissions for land use development projects. URBEMIS
         allows land use selections that include project location specifics and trip generation rates. In addition,
         because it quantifies carbon monoxide emissions, it facilitates the analysis of greenhouse gas emission
         impacts.

5-7      The commenter provides more precise CO2 emission factors for electricity generation that are available
         from the Sacramento Municipal Utility District. The City appreciates the commenter providing these
         emission factors for electricity generation. This information does not substantially alter the conclusions
         of the Draft EIR. Therefore, no change has been made to the analysis of greenhouse gases in the Final
         EIR.




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EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 6-2                                        City of Elk Grove
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Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 6-3                              Responses to Comments
  Letter
      6
Response             Sacramento Area Sewer District; Salam Khan, P.E. 7/22/09



6-1       The commenter corrects a reference identified in the Draft EIR. In response to this comment, the first
          sentence of the fifth paragraph on page 4.5-1 of the Draft EIR is hereby revised as follows:

                  “The collection system within the area of the potential project sites includes trunks, which are
                  designed to carry flows from 1 to 10 mgd, and collectors, laterals, which are designed to carry
                  flows of less than 1 mgd.”

6-2       The commenter states that because the flow quantity from equipment washing is not known and could be
          larger than what is typically used to design District pipes, a capacity analysis may be needed to determine
          if there is enough available capacity in the existing sewer pipes. The equipment washing system would
          include a holding tank to capture wash water. The wash water would be recycled and reused in the
          washing process, minimizing the discharge of wash water into the sewer system. Because only small
          quantities of wash water would be disposed of in the sewer system, the existing sewer pipes are
          anticipated to have sufficient capacity to accommodate the project’s wastewater generation.

6-3       The commenter states that hydraulic modeling may need to be done in order to determine if the future
          trunk sewer lines in Grant Line Road will need to be constructed prior to the proposed project if Site 2 is
          selected. As noted under Impact 4.5-1 on page 4.5-12 of the Draft EIR, implementation of the proposed
          project would not generate a substantial demand on water supplies. Therefore, the project would not be
          expected to generate substantial wastewater. Wastewater would primarily be generated from the proposed
          restroom facilities, which would be designed to accommodate the demands of up to 100 employees and
          facility visitors, and from equipment washing. As described in Response to Comment 6-2, the equipment
          washing system would include a holding tank to capture wash water and the wash water would be
          recycled and reused in the washing process, minimizing the discharge of wash water into the sewer
          system. Site 2 is located in a developed industrial area with established wastewater service. A trunk line
          extends under Grant Line Road directly adjacent to the site. This trunk line has been designed to
          accommodate the planned industrial development on Site 2. As stated in their comment letter on the
          project’s Notice of Preparation (Appendix A to the Draft EIR), the Sacramento Area Sewer District
          anticipates that the project will result in less-than-significant impacts on sewage facilities, assuming that
          the project complies with all required policies, ordinances and conditions of approval. Therefore, the
          proposed project’s wastewater demands would not be expected to exceed the wastewater treatment
          system’s capacities and would not be expected to require or result in the expansion of existing trunk lines.

          The commenter states that there may be the need to keep an easement for the future trunk sewer along the
          Grant Line Road frontage of Site 2. The City appreciates the commenter providing this information. If
          the City decides to develop the proposed project on Site 2, the City would coordinate with the Sacramento
          Area Sewer District during the site design process to ensure all appropriate easements are integrated into
          the site design.

6-4       The commenter states that the project may need to meet certain Industrial Waste Discharge requirements
          or may require an Industrial Waste Discharge permit. The City appreciates this information regarding the
          project’s required permitting. The commenter does not raise any substantive comments on the contents of
          the Draft EIR or otherwise raise a significant environmental issue; therefore, no additional response is
          necessary.




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EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 7-2                                        City of Elk Grove
  Letter
      7
Response               Sterns, Donna 8/7/09


7-1       The commenter states that since Site 4 has a significant and unavoidable noise impact, it should not be
          given the same consideration as Site 2. However, if this situation could be mitigated, then it should be
          given equal consideration in regards to noise. These comments are appreciated and noted by the City.
          The commenter does not raise any substantive comments on the contents of the Draft EIR or otherwise
          raise a significant environmental issue; therefore, no additional response is necessary.

7-2       The commenter asks how much waste the City currently generates. As identified on page 3-13 of the
          Draft EIR, the City generated 138,094 tons of municipal solid waste, green waste and alternative daily
          cover in 2006. This equates to between 378 and 444 tons per day that would be processed by the proposed
          facility, depending upon whether the facility operated 365 or 311 days per year. The commenter further
          raises concerns regarding the fiscal soundness of the proposed project. The analysis of the facility’s fiscal
          soundness is outside of the scope of this EIR. Therefore, no additional response is provided.

7-3       The commenter asks what the fiscal projections are for this project by category of waste. The commenter
          also asks whether there are sufficient quantities of waste to justify the expenditure of funds. The
          discussion of the facility’s fiscal issues is outside of the scope of this EIR. Therefore, no additional
          response regarding fiscal issues is provided. The commenter further states that it is prudent to purchase
          the property at this time and hold it until there is sufficient need to justify the large expenditure. The City
          appreciates and notes this comment.

7-4       The commenter states that construction of the household hazardous waste facility would be very expensive
          based on its limited operations. The discussion of the facility’s fiscal issues is outside of the scope of this
          EIR. Therefore, no additional response regarding fiscal issues is provided.

7-5       The commenter states that the presence of petroleum hydrocarbons at Site 2 is disturbing, the long-term
          costs of cleanup could be significant, and these facts could eliminate this site from consideration. These
          comments are appreciated and noted by the City. For detailed information regarding the contamination at
          Site 2, the commenter is referred to the discussion of Land Uses and Conditions on the Project Sites for
          Site 2 commencing on page 4.7-1 of the Draft EIR.

7-6       The commenter identifies preferences for different site locations. The alternative site locations identified
          by the commenter were evaluated in detail in Chapter 6 of the Draft EIR. These comments are appreciated
          and noted by the City. The commenter does not raise any substantive comments on the contents of the
          Draft EIR or otherwise raise a significant environmental issue; therefore, no additional response is
          necessary.

7-7       The commenter suggests that it would be appropriate to further develop the details on transporting the
          waste stream by rail. The City appreciates and notes the commenter’s suggestion. For a detailed
          discussion of this issue, the commenter is referred to Response to Comment 4-2.




Elk Grove Transfer Station Final EIR                                                                              EDAW
City of Elk Grove                                         Letter 7-3                              Comments and Responses
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EDAW                                                           Elk Grove Transfer Station Final EIR
Comments and Responses                Letter 7-4                                  City of Elk Grove
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Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 8-1                              Responses to Comments
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EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 8-2                                        City of Elk Grove
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Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 8-3                              Responses to Comments
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EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 8-4                                        City of Elk Grove
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Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 8-5                              Responses to Comments
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EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 8-6                                        City of Elk Grove
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Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 8-7                              Responses to Comments
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EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 8-8                                        City of Elk Grove
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Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 8-9                              Responses to Comments
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EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 8-10                                       City of Elk Grove
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Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 8-11                             Responses to Comments
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EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 8-12                                       City of Elk Grove
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Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 8-13                             Responses to Comments
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EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 8-14                                       City of Elk Grove
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Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 8-15                             Responses to Comments
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EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 8-16                                       City of Elk Grove
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Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 8-17                             Responses to Comments
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EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 8-18                                       City of Elk Grove
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Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 8-19                             Responses to Comments
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EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 8-20                                       City of Elk Grove
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Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 8-21                             Responses to Comments
                                                                                                                    8-5
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EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 8-22                                       City of Elk Grove
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Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 8-23                             Responses to Comments
  Letter
      8
Response             Elk Grove Planning Commission Public Hearing 8/6/09



8-1       The commenter asks if there are any particular traffic matters that are greater for one site than the other
          and raises concerns regarding project vehicles traveling through residential areas. These comments were
          responded to by City staff during the Planning Commission hearing. For a more detailed discussion of
          the traffic impacts for both potential project sites, the commenter is referred to pages 4.2-30 through 4.2-
          52 of the Draft EIR.

8-2       The commenter raises concerns regarding the storage of recyclable materials. These concerns were
          addressed by City staff during the Planning Commission hearing. Therefore, no additional response is
          necessary.

8-3       The commenters raise concerns regarding the significant and unavoidable noise impact anticipated at Site
          4 with project implementation. These concerns were addressed by City staff during the Planning
          Commission hearing. Therefore, no additional response is necessary.

8-4       The commenter discusses the use of rail to haul waste from the sites. For more information on this issue,
          the commenter is referred to Response to Comment 4-2.

8-5       The commenter raises concerns regarding noise associated with truck traffic. These concerns were
          addressed by City staff during the Planning Commission hearing. Therefore, no additional response is
          necessary.




EDAW                                                                                    Elk Grove Transfer Station Final EIR
Comments and Responses                                 Letter 8-24                                         City of Elk Grove
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Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 9-1                              Responses to Comments
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EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 9-2                                        City of Elk Grove
                                                                                                              9-1
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Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 9-3                              Responses to Comments
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EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 9-4                                        City of Elk Grove
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EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 9-6                                        City of Elk Grove
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City of Elk Grove                                   Letter 9-7                              Responses to Comments
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EDAW                                                                               Elk Grove Transfer Station Final EIR
Responses to Comments                               Letter 9-8                                        City of Elk Grove
________________________________________________________________________________________________________________
Elk Grove Transfer Station Final EIR                                                                        EDAW
City of Elk Grove                                   Letter 9-9                              Responses to Comments
  Letter
      9
Response             California Integrated Waste Management Board, John Loane, 8/13/09



9-1       The commenter summarizes the project description, the proposed facility entitlements, and the applicable
          State Minimum Standards as listed in CCR Title 14. The commenter does not raise any substantive
          comments on the contents of the Draft EIR or otherwise raise a significant environmental issue; therefore,
          no additional response is necessary.

9-2       The commenter asks how transfer trailers that are stored overnight would minimize odors. The storage of
          transfer trailers overnight is not anticipated to occur on a regular basis. On the rare occasions when
          loaded transfer trailers would be stored overnight, they would be covered with plastic (non-mesh) tarps in
          order to contain odors within the trailer. Also, the trailers would be parked as far away as possible from
          residences to minimize odor propagation.

9-3       The commenter requests that the area of outside storage be identified on a site map. Outside storage
          would occur, if necessary, in the paved areas within the vicinity of the loading docks identified on
          Exhibits 3-3 and 3-4 on pages 3-7 and 3-8, respectively, of the Draft EIR.

9-4       The commenter provides clarification regarding the permitting requirements for the operation of the
          Household Hazardous Waste Collection Facility if it is constructed prior to the construction of a transfer
          station. This City appreciates and notes the commenter’s clarification regarding the permitting
          requirements for the Household Hazardous Waste Collection Facility. The project is anticipated to be
          constructed in phases depending upon the City’s evolving waste management requirements and the City
          is committed to ensuring that each component of the proposed project would be constructed and operated
          consistent with all permitting requirements.

9-5       The commenter asks how a concrete crushing building or bunker will control the dust generated by this
          operation. The industry standard dust control for concrete crushing operations is the direct application of
          water to materials through fine mist sprays and air-capture of airborne dust through misting. Water
          requirements are calculated to provide adequate dust control without creating run-off conditions. These
          fine mist sprayers are typically integrated into the crushing equipment, though supplemental stand-alone
          misters are also available.

          The CDC Workplace Safety and Health, IC 9465, (NIOSH) indicates that water sprays in crushing
          operations can be used for two purposes (1) to wet materials prior to being crushed and (2) to facility
          airborne capture of dust. Of these two roles wetting of material is known to be a far more effective dust
          suppression measure, because “the vast majority of dust particles created during breakage are not
          released into the air, but stay attached to the surface of the broken material. Wetting this broken material
          ensures that it stays attached” (NIOSH). The strategy to be used at the Elk Grove Transfer Station for any
          concrete crushing operations would be to apply standard operating procedures for crushing equipment by
          uniformly pre-wetting material during the crushing process. Wetting would be accomplished through
          misting equipment that is integrated into the crushing equipment and/or through supplemental misters.
          Further dust control can be supplied through misting during the crushing procedure to facilitate airborne
          capture as necessary. Crushing equipment may also incorporate local exhaust ventilation as a back up to
          the wetting procedure.

9-6       The commenter requests that specific boundaries be drawn for the project components as required for the
          Solid Waste Facilities Permit. If the City approves the proposed project, they will submit specific facility
          boundaries as part of Solid Waste Facilities Permit application.


EDAW                                                                                   Elk Grove Transfer Station Final EIR
Comments and Responses                                 Letter 9-10                                        City of Elk Grove
         The commenter questions whether the total vehicles per day limit of 801 identified in Table 4.2-6 is the
         amount of vehicles expected to access the facility in one day. The total daily vehicle limit for the
         proposed facility is 801 including vehicles generated by the Household Hazardous Waste Collection
         Facility.

9-7      The commenter raises concerns regarding composting activities occurring at the proposed facility and
         recommends that operations for uncovered waste materials be designed to prevent contact water and
         rainwater absorption. No composting operations are proposed at the facility and the recommendations
         provided by the commenter would be taken into consideration when a detailed facility design is prepared.

9-8      The commenter suggests testing previously utilized bare ground to determine if there is a presence of
         hazardous materials. The commenter is referred to the discussion of site conditions included on page 4.7-
         1 and the discussion regarding the exposure to hazardous materials during project construction and
         operations included on pages 4.7-12 through 4.7-15 of the Draft EIR.

         The commenter further states that the local enforcement agency should be notified if hazardous
         substances are found on the potential project sites. The City will comply with all applicable regulations if
         hazardous substances are found on the potential project sites including contacting the local enforcement
         agency.

9-9      The commenter references the requirement to submit a Mitigation Reporting and Monitoring Program.
         The Mitigation Reporting and Monitoring Program for this project is included in Appendix A of this Final
         EIR.

9-10     The commenter requests that the California Integrated Waste Management Board be notified of the date,
         time and location of any future hearings on the proposed project. The Board shall be so notified of any
         project hearings by the City.




Elk Grove Transfer Station Final EIR                                                                          EDAW
City of Elk Grove                                     Letter 9-11                             Comments and Responses
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EDAW                                                           Elk Grove Transfer Station Final EIR
Comments and Responses               Letter 9-12                                  City of Elk Grove
           3         CORRECTIONS AND REVISIONS TO THE DRAFT EIR

This section contains changes to the text of the Draft EIR that are being made based upon agency and public
comments received and responded to in Chapter 2 of this Final EIR. The changes are presented in the order in
which they appear in the Draft EIR and are identified by Draft EIR page number. Text deletions are shown in
strikeout (strikeout) and additions are shown in bold underline (bold underline).

Page 2-11 of the Draft EIR, the first bullet in the Mitigation Measures column on page 2-11 and the last bullet on
page 4.3-22 are hereby revised as follows:

           “Routine cleaning of floors, walls, and equipment shall be conducted per the requirements of CCR Title
           14, Section 17407.2 27; and”

Page 3-9 of the Draft EIR, the last sentence of the first paragraph is hereby revised as follows:

           “State regulations allow waste to remain onsite for no longer than 48 72 hours following its arrival.”

Page 3-15 of the Draft EIR, Table 3-1 is hereby revised as follows:

                                                      Table 3-1
                      Vehicle Counts for the Elk Grove Transfer Station Facility in the Year 2025
                                    Vehicles Types                                                             Vehicles/Day2
Residential Route Trucks                                                                                             99
                                1
Commercial Route Trucks (Single/Multiple)                                                                         97/199
Commercial Self Haul                                                                                                 44
Residential Self Haul                                                                                               144
Self-Haul (Household Hazardous Waste)                                                                                60
Employee Vehicles (cars and pickup trucks)                                                                          100
Buy-Back (cars and pickup trucks)                                                                                    40
Outbound Transfer Truck/Trailers (18 Wheelers)                                                                     91 27
Outbound from MRF Transfer Truck/Trailers (Up to 18 Wheelers)                                                       23 6
Outbound HHW Vans and Flatbeds (Up to 18 Wheelers)                                                                    1
1
    If there is a single commercial franchised hauler, the number of trucks per day entering the facility is anticipated to be less than with
    multiple commercial franchised haulers.
2
    Residential vehicles are assumed to access the site 259 days per year and commercial vehicles are assumed to access the site 311 days
    per year.
Source: Fehr & Peers Transportation Consultants 2009




Page 3-18 of the Draft EIR, the text of the first sub-bullet is hereby revised as follows:

           “a Solid Waste Facilities Permit (SWFP) from the Local Enforcement Agency (Sacramento County
           Environmental Management Department, Environmental Compliance Hazardous Materials Division)
           with concurrence from the California Integrated Waste Management Board (CIWMB);”

Page 4.2-25 of the Draft EIR, Table 4.2-7 is hereby revised as follows:


Elk Grove Transfer Station Final EIR                                                                                                       EDAW
City of Elk Grove                                                        3-1                            Corrections and Revisions to the Draft EIR
                                                 Table 4.2-7
              Intersection Control Delay and Level of Service – Baseline Plus Project Conditions
                                                  Baseline No Project   Baseline Plus Franchise    Baseline Plus Multiple
                                                     Conditions          Commercial Haulers         Commercial Haulers
                                    Traffic
         Intersection                            AM Peak      PM Peak    AM Peak     PM Peak       AM Peak        PM Peak
                                    Control
                                                  Hour         Hour       Hour        Hour          Hour           Hour
                                                Delay1/LOS2 Delay1/LOS2 Delay1/LOS2 Delay1/LOS2 Delay1/LOS2 Delay1/LOS2
1. State Route 99 SB
   Ramps/                           Signal       > 80 / F     >80 / F     >80 / F     >80 / F       >80 / F       >80 / F
   Elk Grove Boulevard
2. State Route 99 NB On-
   Ramp / Elk Grove                 Signal        19 / B       23 / C     19 / B       24 / C       18 / B         24 / C
   Boulevard
3. Elk Grove Boulevard /
                                    Signal        50 / D       75 / E     51 / D       77 / E       52 / D         78 / E
   East Stockton Boulevard
4. State Route 99 NB Off-
                                  Side-Street
   Ramp / East Stockton                           >80 / F     >80 / F     >80 / F     >80 / F       >80 / F       >80 / F
                                     Stop
   Boulevard
5. Elk Grove Boulevard /
                                    Signal        32 / C      >80 / F     32 / C      >80 / F       32 / C        >80 / F
   Elk Grove-Florin Road
6. Elk Grove Boulevard /
                                    Signal        31 / C       39 / D     32 / C       40 / D       32 / C         40 / D
   Waterman Road
7. Elk Grove Boulevard /           All-Way
                                                  15 / B       33 / D     15 / B       33 / D       15 / B         34 / D
   Bradshaw Road                    Stop
8. Elk Grove Florin Road /        Side-Street
                                                  32 / D      >80 / F     35 / E      >80 / F       36 / E        >80 / F
   East Stockton Boulevard           Stop
9. Site 4 - Union Parkway /       Side-Street
                                                  14 / B       21 / C     14 / B       21 / C       14 / B          21 / C
   East Stockton Boulevard           Stop
9. Site 5 - Union Parkway /       Side-Street
                                                    --           --       14 / B       21 / C       14 / B          21 / C
   East Stockton Boulevard           Stop
9. Sites 2 and 3 - Union
                                  Side-Street
   Parkway / East Stockton                          --           --       14 / B       21 / C       14 / B          21 / C
                                     Stop
   Boulevard
10. Site 4 - Elkmont Way /         All-Way
                                                  12 / B       44 / E     16 / C      >80 / F       17 / C        >80 / F
    East Stockton Boulevard         Stop
10. Site 5 - Elkmont Way /        Side-Street
                                                    --           --       13 / B       48 / E       13 / B         48 / E
    East Stockton Boulevard          Stop
10. Sites 2 and 3 - Elkmont
                                  Side-Street
    Way / East Stockton                             --           --       13 / B       47 / E       13 / B         47 / E
                                     Stop
    Blvd
13. Grant Line Road /
                                    Signal        14 / B       25 / C     14 / B       26 / C       14 / B          26 / C
    Waterman Road
14. Grant Line Road /             Side-Street
                                                  44 / E       56 / F     49 / E       65 / F       49 / E         65 / F
    Bradshaw Road                    Stop
15. Elk Grove Boulevard /          All-Way
                                                  78 / F      >80 / F     >80 / F     >80 / F       >80 / F       >80 / F
    Grant Line Road                 Stop
16. Grant Line Road /
                                    Signal        38 / D       34 / D     40 / D       36 / D       40 / D         36 / D
    Bond Road


EDAW                                                                                       Elk Grove Transfer Station Final EIR
Corrections and Revisions to the Draft EIR                     3-2                                            City of Elk Grove
                                                    Table 4.2-7
                 Intersection Control Delay and Level of Service – Baseline Plus Project Conditions
                                                      Baseline No Project         Baseline Plus Franchise         Baseline Plus Multiple
                                                         Conditions                Commercial Haulers              Commercial Haulers
                                       Traffic
             Intersection                           AM Peak         PM Peak        AM Peak         PM Peak        AM Peak        PM Peak
                                       Control
                                                     Hour            Hour           Hour            Hour           Hour           Hour
                                                   Delay1/LOS2 Delay1/LOS2 Delay1/LOS2 Delay1/LOS2 Delay1/LOS2 Delay1/LOS2
17. Grant Line Road /
                                       Signal        >80 / F         >80 / F        >80 / F        >80 / F        >80 / F         >80 / F
    Wilton Road
18 Grant Line Road /               Side-Street
                                                     >80 / F         >80 / F        >80 / F        >80 / F        >80 / F         >80 / F
   Sheldon Road                       Stop
19 Grant Line Road /
                                       Signal         20 / B         10 / A          21 / C         10 / A         21 / C          10 / A
   Calvine Road
20. Bilby Road /
                                       Signal        >80 / F         >80 / F        >80 / F        >80 / F        >80 / F         >80 / F
    Bruceville Road
21. Kammerer Road /                Side-Street
                                                      12 / B         40 / E          12 / B         41 / E         12 / B          42 / E
    Bruceville Road                   Stop
25. Site 4 - Grant Line Road
    / East Stockton                    Signal         24 / C         37 / D          27 / C         41 / D         27 / C          42 / D
    Boulevard
25. Site 5 - Grant Line Road
    /                                  Signal           --              --           27 / C         41 / D         27 / C          41 / D
    East Stockton Boulevard
25. Sites 2 and 3 - Grant
    Line Road / East                   Signal           --              --           32 / C         36 / D         33 / C          36 / D
    Stockton Blvd.
26 Grant Line Road /
   NB State Route 99                   Signal         50 / D         73 / E         48 / D3         71 / E3        47 / D3        71 / E3
   Ramps
27. Grant Line Road /
                                                   46 / D 54 /     47 / D 51 / 45 / D3 48 / 51 / D 65 / 45 / D3 48 / 52 / D 64 /
    SB State Route 99                  Signal
                                                        D               D           D            E           D3           E
    Ramps
28. Kammerer Road /
                                       Signal        >80 / F         >80 / F        >80 / F        >80 / F         >80 / F        >80 / F
    Promenade Parkway
29. Kammerer Road /
                                       Signal         15 / B         14 / B          15 / B         14 / B         15 / B          14 / B
    Lent Ranch Parkway
30. Kammerer Road /
                                       Signal         16 / B         12 / B          16 / B         12 / B         16 / B          12 / B
    Lotz Parkway
         1
Notes:   For signalized and all-way stop-controlled intersections, the overall average intersection control delay is reported in seconds per
         vehicle. For side-street stop-controlled intersections, the average control delay for the worst movement is reported in seconds per
         vehicle. >80 is reported when Synchro is unable to calculate the average control delay for stop-controlled intersections due to
         oversaturated conditions.
       2
          Level of Service based on Highway Capacity Manual (Transportation Research Board 2000).
       3
         Project trips were added to non-critical movements which have low vehicle delay. Because the overall intersection delay is an
         average of all the movements, the addition of the project volume decreases the overall intersection delay.
       Shading indicates that the intersection operates unacceptably based on the significance criteria.
       Bold italic indicates project impact based on the significance criteria.
Source: Fehr & Peers 2009




Elk Grove Transfer Station Final EIR                                                                                                  EDAW
City of Elk Grove                                                    3-3                           Corrections and Revisions to the Draft EIR
Page 4.4-7 of the Draft EIR, Exhibit 4.4-2 is hereby revised and is replaced with new Exhibit 4.4-2 below:

Page 4.5-1 of the Draft EIR, the first sentence of the fifth paragraph is hereby revised as follows:

         “The collection system within the area of the potential project sites includes trunks, which are designed to
         carry flows from 1 to 10 mgd, and collectors, laterals, which are designed to carry flows of less than 1
         mgd.”

Page 4.7-8 of the Draft EIR, the fourth sentence of the first paragraph is hereby revised as follows:

         “The LEA for solid waste facilities within Sacramento County is the Sacramento County Environmental
         Management Department, Environmental Compliance Hazardous Materials Division.”

Page 4.8-3 of the Draft EIR, the first sentence in the first full paragraph is hereby revised as follows:

         “The Local Enforcement Agency’s Solid Waste Facilities permit for the potential project sites would
         prohibit the discharge of drainage containing solids, wash water, or leachate emanating from solid wastes
         (14 CCR Article 6.35, Section 17407.3).”




EDAW                                                                                    Elk Grove Transfer Station Final EIR
Corrections and Revisions to the Draft EIR                3-4                                              City of Elk Grove
Source: Prepared by EDAW 2009


Nearest Sensitive Receptors to the Potential Project Sites                            Exhibit 4.4-2

Elk Grove Transfer Station Final EIR                                                            EDAW
City of Elk Grove                                3-5         Corrections and Revisions to the Draft EIR
                                                   APPENDIX A
Elk Grove Transfer Station Mitigation Monitoring and Reporting Program
                                 ELK GROVE TRANSFER STATION

          MITIGATION MONITORING AND REPORTING PROGRAM

INTRODUCTION
In accordance with the California Environmental Quality Act (CEQA) (Public Resources Code Section 21000 et
seq.) and the State CEQA Guidelines (14 California Code of Regulations [CCR] Section 15000 et seq.), the City
of Elk Grove (City) prepared a Final Environmental Impact Report (Final EIR) that identifies significant
environmental impacts related to construction and operation of the Elk Grove Transfer Station Project. The Final
EIR also identifies mitigation measures that would reduce these impacts to a less-than-significant level, or
eliminate the adverse impacts altogether.

CEQA Guidelines require public agencies “to adopt a reporting and monitoring program for changes to the
project which it has adopted or made a condition of project approval in order to mitigate or avoid significant
effects on the environment.” A Mitigation Monitoring and Reporting Program (MMRP) is required for the
proposed project because the Final EIR identifies significant adverse impacts related to the construction and
operation of the proposed project, and mitigation measures have been identified to reduce those impacts.
Adoption of the MMRP would occur along with approval of the proposed project.

PURPOSE OF MITIGATION MONITORING AND REPORTING PROGRAM
This MMRP has been prepared to ensure that all required mitigation measures are implemented and completed in
a satisfactory manner. The MMRP may be modified by the City during project implementation, as necessary, in
response to changing conditions or other refinements. Table 1 (included at the end of this document) has been
prepared to assist the responsible parties in implementing the mitigation measures. The table identifies individual
mitigation measures, monitoring/mitigation timing, responsible person/agency for implementing the measure,
monitoring and reporting procedure, and space to confirm implementation of the mitigation measures. The
numbering of mitigation measures follows the numbering sequence found in the Final EIR.

ROLES AND RESPONSIBILITIES
Unless otherwise specified herein, the City is responsible for taking all actions necessary to implement the
mitigation measures according to the specifications provided for each measure and for demonstrating that the
action has been successfully completed. The City, at its discretion, may delegate implementation responsibility or
portions thereof to a licensed contractor or other designated agent.

The City would be responsible for overall administration of the MMRP and for verifying that City staff members
and/or the construction contractor has completed the necessary actions for each measure. The City would
designate a project manager to oversee implementation of the MMRP. Duties of the project manager include the
following:

►   Ensure that routine inspections of the construction site are conducted by appropriate City staff; check plans,
    reports, and other documents required by the MMRP; and conduct report activities.

►   Serve as a liaison between the City Public Works Department, Planning Department, and the construction
    contractor regarding mitigation monitoring issues.

►   Complete forms and maintain reports and other records and documents generated by the MMRP.

►   Coordinate and ensure that corrective actions or enforcement measures are taken, if necessary.

Elk Grove Transfer Station Project                                                                                  EDAW
City of Elk Grove                                        1                    Mitigation Monitoring and Reporting Program
The responsible party for implementation of each item would identify the staff members responsible for
coordinating with the City on the MMRP.

REPORTING
The City’s project manager shall prepare a monitoring report, upon completion of the project, on the compliance
of the activity with the required mitigation measures. Information regarding inspections and other requirements
shall be compiled and explained in the report. The report shall be designed to simply and clearly identify whether
mitigation measures have been adequately implemented. At a minimum, each report shall identify the mitigation
measures or conditions to be monitored for implementation, whether compliance with the mitigation measures or
conditions has occurred, the procedures used to assess compliance, and whether further action is required. The
monitoring report shall be presented to the City Council.

MITIGATION MONITORING AND REPORTING PLAN TABLE
The categories identified in Table 1 are described below.

►   Mitigation Number – This column lists the mitigation measures by number as identified in the Final EIR.

►   Mitigation Measure – This column provides the text of the mitigation measures identified in the Final EIR.

►   Timing/Schedule – This column identifies the time frame in which the mitigation will take place.

►   Implementation Responsibility – This column identifies the entity responsible for complying with the
    requirements of the mitigation measure.

►   Verification –The “Action” column describes the type of action taken to verify implementation. The “Date
    Completed” column is to be dated and initialed by the project manager, or his/her designee, based on the
    documentation provided by the construction contractor, its agents (qualified individuals), or through personal
    verification by the City.




EDAW                                                                                  Elk Grove Transfer Station Project
Mitigation Monitoring and Reporting Program              2                                            City of Elk Grove
City of Elk Grove
Elk Grove Transfer Station Project

                                                                                                       Mitigation Monitoring and Reporting Program

                                              Mitigation                                                                                                       Implementation               Verification
                                                                                      Mitigation Measure                                Timing/Schedule
                                               Number                                                                                                           Responsibility     Action          Date Completed
                                              4.2. Traffic and Circulation
                                              4.2-2:       Install a traffic signal at the Elk Grove-Florin Road / East Stockton        Prior to the initiation Elk Grove Public
                                                           Boulevard intersection as planned for in the City’s Capital Improvement of Transfer Station Works Department
                                                           Program. Currently this improvement is included in the fee program           operations.
                                                           and is anticipated to be constructed prior to the operations of the transfer
                                                           station. If the improvement is not in place, this project will be required
                                                           to construct it.
                                              4.2-3        Install a traffic signal at the Elkmont Way / East Stockton Boulevard     Prior to the initiation Elk Grove Public
                                                           intersection.                                                             of Transfer Station Works Department
                                                                                                                                     operations.
                                              4.2-4        Install a traffic signal and widen the southbound and eastbound         Prior to the initiation Elk Grove Public
                                                           approaches to the Grant Line Road / Bradshaw Road intersection to       of Transfer Station Works Department
                                                           provide the following lane configurations:                              operations.
                                                           ►    One left-turn lane and one right-turn lane on the southbound
                                                                approach.
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                                                           ►    One left-turn lane and one through lane on the eastbound approach.
                                                           Currently these improvements are included in the fee program and are
                                                           anticipated to be constructed prior to the operations of the transfer
                                                           station. If the improvements are not in place, this project will be
                                                           required to construct them.
                                              4.2-5        Install a traffic signal and widen the eastbound approach to the Grant  Prior to the initiation Elk Grove Public
                                                           Line Road / Elk Grove Boulevard intersection to provide the following of Transfer Station Works Department
Mitigation Monitoring and Reporting Program




                                                           lane configurations:                                                    operations.
                                                           ►    One left-turn lane and one through lane on the eastbound approach.
                                                           Currently these improvements are included in the fee program and are
                                                           anticipated to be constructed prior to the operations of the transfer
                                                           station. If the improvements are not in place, this project will be
                                                           required to construct them.
                                     EDAW
Mitigation Monitoring and Reporting Program
EDAW

                                                                                                         Mitigation Monitoring and Reporting Program

                                              Mitigation                                                                                                        Implementation              Verification
                                                                                       Mitigation Measure                                 Timing/Schedule
                                               Number                                                                                                            Responsibility    Action          Date Completed
                                              4.2-6        Widen the eastbound approach to the Grant Line Road / Wilton Road            Prior to the initiation Elk Grove Public
                                                           intersection to provide the following lane configurations:                   of Transfer Station Works Department
                                                           ►    One left-turn lane, one through lane, and one right-turn lane on the    operations.
                                                                eastbound approach.
                                                           Currently this improvement is included in the fee program and is
                                                           anticipated to be constructed prior to the operations of the transfer
                                                           station. If the improvement is not in place, this project will be required
                                                           to construct it.
                                              4.2-7        Install a traffic signal at the Grant Line Road / Sheldon Road               Prior to the initiation Elk Grove Public
                                                           intersection.                                                                of Transfer Station Works Department
                                                           Currently this improvement is included in the fee program and is             operations.
                                                           anticipated to be constructed prior to the operations of the transfer
                                                           station. If the improvement is not in place, this project will be required
                                                           to construct it.
                                              4.2-8        Widen the eastbound approach to the Bilby Road / Bruceville Road             Prior to the initiation Elk Grove Public
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                                                           intersection to provide the following lane configurations:                   of Transfer Station Works Department
                                                           ►    A shared through-left lane and a right-turn lane on the eastbound       operations.
                                                                approach.

                                              4.3 Air Quality
                                              4.3-1        In accordance with SMAQMD recommendations, the following                  Prior to and during     Construction
                                                           mitigation measures shall be implemented during construction of the       site construction       Contractor, Elk
                                                           proposed project for Site 2 only, if selected.                            activities.             Grove Integrated
                                                           ►    The contractor shall develop a plan, in consultation with                                    Waste Division and
Elk Grove Transfer Station Project DEIR




                                                                SMAQMD, demonstrating that the heavy-duty (>50 horsepower                                    Sacramento
                                                                [hp]), off-road vehicles to be used in the construction project                              Metropolitan Air
                                                                (including owned, leased, and subcontractor vehicles) shall achieve                          Quality
                                                                a project-wide fleet-average 20% NOX reduction and 45%                                       Management
                                                                particulate reduction compared to the most recent ARB fleet                                  District (SCAQMD)
                                                                average at the time of construction. Acceptable options for reducing
                                                                emissions include the use of late-model engines, low-emission
                                                                diesel products, alternative fuels, particulate-matter traps, engine
                       City of Elk Grove




                                                                retrofit technology, after-treatment products, and/or such other
                                                                options as become available.
                                                           ►    A comprehensive inventory of all off-road construction equipment
                                                                equal to or greater than 50 hp that will be used for an aggregate of
City of Elk Grove
Elk Grove Transfer Station Project

                                                                                                        Mitigation Monitoring and Reporting Program

                                              Mitigation                                                                                                  Implementation             Verification
                                                                                      Mitigation Measure                                Timing/Schedule
                                               Number                                                                                                      Responsibility   Action          Date Completed
                                                               40 or more hours during any portion of project construction shall be
                                                               submitted to SMAQMD. The inventory shall be updated and
                                                               submitted monthly throughout the duration of the project, except
                                                               that an inventory shall not be required for any 30-day period in
                                                               which no construction operations occur. At least 48 hours before
                                                               heavy-duty off-road equipment is used, the City shall provide
                                                               SMAQMD with the anticipated construction timeline, including the
                                                               start date, and the name and phone number of the contractor’s
                                                               project manager and on-site foreman.
                                                           ►   In accordance with SMAQMD recommendations, the following
                                                               mitigation measures shall be implemented at either site during
                                                               construction of the proposed project to minimize cumulative
                                                               impacts from PM10. The ground-disturbing activities (i.e., grading,
                                                               trenching) shall not exceed a total actively disturbed area of 5 acres
                                                               per day.
                                                           ►   Construction activities shall comply with SMAQMD’s Rule 403,
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                                                               Fugitive Dust. Rule 403 requires implementation of reasonable
                                                               precautions so as not to cause or allow emissions of fugitive dust
                                                               from being airborne beyond the property line of the project site. In
                                                               accordance with SMAQMD-recommended mitigation measures for
                                                               the control of fugitive dust, reasonable precautions shall include,
                                                               but shall not necessarily be limited to, the following (SMAQMD
                                                               2004):
                                                               • Apply water, chemical stabilizer/suppressant, or vegetative
Mitigation Monitoring and Reporting Program




                                                                    cover to disturbed areas, including storage piles that are not
                                                                    being actively used for construction purposes, as well as any
                                                                    portions of the construction site that remain inactive for longer
                                                                    than 3 months.
                                                               • Water exposed surfaces sufficient to control fugitive dust
                                                                    emissions during demolition, clearing, grading, earth-moving,
                                                                    or excavation operations. Actively disturbed areas should be
                                                                    kept moist at all times.
                                                               • Cover all vehicles hauling dirt, sand, soil or other loose
                                                                    material or maintain at least two feet of freeboard in
                                                                    accordance with the requirements of California Vehicle Code
                                     EDAW




                                                                    Section 23114.
Mitigation Monitoring and Reporting Program
EDAW

                                                                                                       Mitigation Monitoring and Reporting Program

                                              Mitigation                                                                                                  Implementation              Verification
                                                                                     Mitigation Measure                               Timing/Schedule
                                               Number                                                                                                      Responsibility    Action          Date Completed
                                                               •   Limit or expeditiously remove the accumulation of project-
                                                                   generated mud or dirt from adjacent public streets at least once
                                                                   every 24 hours when construction operations are occurring.
                                                               •   Limit onsite vehicle speeds on unpaved surfaces to 15 miles
                                                                   per hour, or less.

                                              4.3-5        The following measures shall be implemented to reduce the project’s      During facility     Facility Operator,
                                                           potential odor impacts:                                                  operations.         Elk Grove
                                                           ►   Building doors shall be closed when not receiving waste materials;                       Integrated Waste
                                                           ►   Loaded transfer vehicles shall be covered and properly maintained                        Division, SCAQMD
                                                               to ensure that both liquid and solid waste materials are contained                       and Local
                                                               entirely within the vehicle for the duration of its transport;                           Enforcement
                                                                                                                                                        Agency
                                                           ►   Routine cleaning of floors, walls, and equipment shall be conducted
                                                               per the requirements of CCR Title 27; and
                                                           ►   Odor complaints received by the City or SMAQMD shall be
                                                               responded to within 24 hours. This response shall include an
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                                                               inquiry into the source of the odor and identification of the
                                                               measures necessary to eliminate the odor source. If excessive
                                                               complaints are received, as defined by the City, additional measures
                                                               shall be implemented to control odors. Additional measures may
                                                               include, but are not limited to: (a) install plastic curtains on
                                                               entrances and exits to contain odors when doors are opened to allow
                                                               vehicles to enter and exit, (b) use of deodorants to mask or
                                                               neutralize odors as needed, and (c) daily removal of waste from
                                                               tipping floor to allow for daily washing/cleaning.
Elk Grove Transfer Station Project DEIR
                       City of Elk Grove
City of Elk Grove
Elk Grove Transfer Station Project

                                                                                                         Mitigation Monitoring and Reporting Program

                                              Mitigation                                                                                                         Implementation              Verification
                                                                                       Mitigation Measure                                 Timing/Schedule
                                               Number                                                                                                             Responsibility    Action          Date Completed
                                              4.4 Noise
                                              4.4-1        The following measures shall be implemented to reduce construction-       During site               Construction
                                                           generated noise levels at nearby land uses:                               construction              Contractor and Elk
                                                           ►   Construction activities (excluding activities that would result in a  activities.               Grove Integrated
                                                               safety concern to the public or construction workers) shall be                                  Waste Division
                                                               limited to between the hours of 7:00 a.m. and 7:00 p.m., Monday
                                                               through Friday, and between the hours of 7:00 a.m. and 7:00 p.m.
                                                               on Saturday and Sunday, in accordance with the City’s General
                                                               Plan noise policies.
                                                           ►   Construction equipment shall be properly maintained and equipped
                                                               with noise-reduction intake and exhaust mufflers and engine
                                                               shrouds, in accordance with manufacturers’ recommendations.
                                                           ►   Construction equipment staging areas shall be located at the farthest
                                                               distance possible from nearby noise-sensitive land uses.

                                              4.4-3        For Site 4 Only:                                                             Prior to and during    Elk Grove Planning
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                                                           The facility shall be designed to minimize noise generation in the           facility operations.   Department and
                                                           northwestern portion of Site 4. This shall be accomplished by limiting                              Integrated Waste
                                                           the site uses in the northern portion of the site, concentrating high noise-                        Division
                                                           generating activities in the southern portion of the site, and locating
                                                           buildings so they block offsite noise propagation to the northwest.
                                                           The City shall contract with an acoustical engineering firm that will
                                                           identify a variety of construction solutions (e.g., sound berms) to be
Mitigation Monitoring and Reporting Program




                                                           implemented as part of the project to reduce the offsite noise levels by a
                                                           minimum of 8 dBA, if feasible.
                                                           Site 2: No mitigation measures are required.
                                              4.4-4        The site operations shall comply with the requirements of the City’s        Prior to and during     Elk Grove Planning
                                                           noise ordinance regarding nighttime operations. This shall include          facility operations.    Department and
                                                           limiting substantial noise-generating outdoor activities at the site during                         Integrated Waste
                                                           nighttime hours (10:00 p.m. to 7:00 a.m.) and designing the facility to                             Division
                                                           ensure high noise generating activities are screened by buildings from
                                                           noise-sensitive land uses.
                                                           The City shall contract with an acoustical professional to collect
                                                           nighttime noise measurements at the site for two months following the
                                     EDAW




                                                           initiation of site operations. If the noise level measurements determine
Mitigation Monitoring and Reporting Program
EDAW

                                                                                                          Mitigation Monitoring and Reporting Program

                                              Mitigation                                                                                                        Implementation              Verification
                                                                                       Mitigation Measure                                 Timing/Schedule
                                               Number                                                                                                            Responsibility    Action          Date Completed
                                                           that the nighttime noise levels are exceeding City standards at noise-
                                                           sensitive land uses (residential and park uses), the noise generating
                                                           activities shall be either curtailed until after 7:00 a.m. or other noise
                                                           reducing measures (e.g., relocating noise generating uses on the site,
                                                           installing noise barriers adjacent to noise generating uses) shall be
                                                           implemented to ensure the nighttime noise standard is not exceeded.
                                              4.7 Public Health and Hazards
                                              4.7-1        Construction monitors trained in the identification of hazardous           During site            Construction
                                                           materials will be present during the excavation and site development       construction           Contractor, Elk
                                                           phase of the project. Monitors will observe all excavation, trenching,     activities.            Grove Integrated
                                                           and grading for the potential presence of hazardous materials and                                 Waste Division and
                                                           petroleum products. If during site preparation and construction activities                        California
                                                           previous undiscovered or unknown evidence of hazardous materials                                  Department of Toxic
                                                           contamination is observed or suspected through either obvious or                                  Substances Control
                                                           implied measures (e.g., stained or odorous soil, unknown storage tanks,
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                                                           etc.), construction activities shall immediately cease in the area of the
                                                           find.
                                                           City of Elk Grove staff shall be immediately consulted and the project
                                                           contractor shall contract with a qualified consultant registered in
                                                           DTSC’s Registered Environmental Assessor Program to assess the
                                                           situation. If necessary, risk assessments shall include a DTSC
                                                           Preliminary Endangerment Assessment or no further action
                                                           determination, or equivalent. Any required remediation shall include a
                                                           DTSC Remedial Action Work Plan or equivalent. Based on consultation
Elk Grove Transfer Station Project DEIR




                                                           between the Registered Environmental Assessor and DTSC, remediation
                                                           of the site shall be conducted consistent with all applicable regulations.
                                              4.7-8        ►   City Code Enforcement shall monitor illegal dumping in the project       During site           Elk Grove Code
                                                               area on a monthly basis for the first year of operations. If illegal     construction          Enforcement and
                                                               dumping increases along the site access routes, Code Enforcement         activities and during Police Departments
                                                               shall increase sweeps of the area by the City’s illegal dumping          facility operations.
                                                               contractors. In addition, the City shall develop, in consultation with
                       City of Elk Grove




                                                               the Elk Grove Police Department, an illegal dumping enforcement
                                                               program that includes implementing a surveillance program along
                                                               site access routes and increased fines for perpetrators.
                                                           ►   Perimeter fencing shall be installed with slates.
City of Elk Grove
Elk Grove Transfer Station Project

                                                                                                        Mitigation Monitoring and Reporting Program

                                              Mitigation                                                                                                      Implementation              Verification
                                                                                      Mitigation Measure                                 Timing/Schedule
                                               Number                                                                                                          Responsibility    Action          Date Completed
                                                           ►   All transfer trucks shall be tightly covered before leaving the
                                                               transfer station building.
                                                           ►   All loads brought to the facility are to be brought in covered
                                                               vehicles. This is a requirement of State law, and signs at the facility
                                                               will remind users of the requirement.
                                                           ►   Employees of the facility will make regular litter pick-up “sweeps”
                                                               of the site access roads and surrounding areas, as needed.
                                                           ►   The facility will be appropriately maintained to ensure the
                                                               accumulation of litter does not occur on the site.
                                                           ►   The paved areas on the site will be swept on a regular basis.

                                              4.8 Hydrology and Water Quality
                                              4.8-1        If the drainage system improvements identified in the Elk Grove Flood During site                Elk Grove
                                                           Control and Storm Drainage Master Plan are not implemented prior to          construction        Integrated Waste
                                                           the initiation of project construction, then storm water detention           activities.         Division
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                                                           facilities shall be constructed on the project sites to capture any increase
                                                           in storm water runoff associated with site development. The detention
                                                           facilities shall be located either in the areas designated for future waste
                                                           management and waste conversion (Exhibits 3-3 and 3-4), or in other
                                                           areas of the site with sufficient capacity to accommodate the site’s
                                                           necessary storm water detention requirements. Following the installation
                                                           of the drainage system improvements identified in the Master Plan, the
                                                           detention areas on the sites can be converted to their intended waste
Mitigation Monitoring and Reporting Program




                                                           management uses.
                                              4.8-2        a. The project contractor shall demonstrate compliance, through its        Prior to and during   Construction
                                                              erosion control plan and SWPPP, with all requirements of the City’s site construction         Contractor and Elk
                                                              Drainage Manual and Land Grading and Erosion Control Ordinance, activities.                   Grove Integrated
                                                              which may include (1) restricting grading to the dry season; (2)                              Waste Division
                                                              protecting all finished graded slopes from erosion using such
                                                              techniques as erosion control matting and hydroseeding; (3)
                                                              protecting downstream storm drainage facilities from sedimentation;
                                                              (4) use of silt fencing and hay bales to retain sediment on the project
                                                              sites; (5) use of temporary water conveyance and water diversion
                                                              structures to eliminate runoff; and (6) any other suitable measures.
                                                              The SWPPP shall be submitted to the City for review.
                                     EDAW




                                                           b. Prior to the issuance of a grading permit or any construction activity,
Mitigation Monitoring and Reporting Program
EDAW

                                                                                                       Mitigation Monitoring and Reporting Program

                                              Mitigation                                                                                                 Implementation             Verification
                                                                                      Mitigation Measure                               Timing/Schedule
                                               Number                                                                                                     Responsibility   Action          Date Completed
                                                              the project contractor shall obtain from the Central Valley RWQCB
                                                              the appropriate regulatory approvals for project construction
                                                              including a Section 401 water quality certification, and an NPDES
                                                              stormwater permit for general construction activity, including
                                                              construction dewatering activities.
                                                           c. As required under the NPDES stormwater permit for general
                                                              construction activity, the project contractor shall prepare and submit
                                                              the appropriate Notice of Intent and prepare the SWPPP and the
                                                              erosion control plan for pollution prevention and control prior to
                                                              initiating site construction activities. The SWPPP shall identify and
                                                              specify the use of erosion sediment control BMPs, means of waste
                                                              disposal, implementation of approved local plans, nonstormwater
                                                              management controls, and inspection and maintenance
                                                              responsibilities. The SWPPP shall also specify the pollutants that are
                                                              likely to be used during construction and that could be present in
                                                              stormwater drainage and nonstormwater discharges. A sampling and
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                                                              monitoring program shall be included in the SWPPP that meets the
                                                              requirements of SWRCB Order 99-08-DWQ to ensure the BMPs are
                                                              effective.
                                                           d. Construction techniques shall be identified that would reduce the
                                                              potential runoff and the SWPPP shall identify the erosion and
                                                              sedimentation control measures to be implemented. The SWPPP
                                                              shall also specify spill prevention and contingency measures,
                                                              identify the types of materials used for equipment operation, and
                                                              identify measures to prevent or clean up spills of hazardous
                                                              materials used for equipment operation and hazardous waste.
Elk Grove Transfer Station Project DEIR




                                                              Emergency procedures for responding to spills shall also be
                                                              identified. BMPs identified in the SWPPP shall be used in
                                                              subsequent site development activities. The SWPPP shall identify
                                                              personnel training requirements and procedures that would be used
                                                              to ensure that workers are aware of permit requirements and proper
                                                              installation and performance inspection methods for BMPs specified
                                                              in the SWPPP. The SWPPP shall also identify the appropriate
                       City of Elk Grove




                                                              personnel responsible for supervisory duties related to
                                                              implementation of the SWPPP. All construction contractors shall
                                                              retain a copy of the approved SWPPP on the construction site.
City of Elk Grove
Elk Grove Transfer Station Project

                                                                                                          Mitigation Monitoring and Reporting Program

                                              Mitigation                                                                                                             Implementation                Verification
                                                                                       Mitigation Measure                                    Timing/Schedule
                                               Number                                                                                                                 Responsibility      Action          Date Completed
                                              4.8-3        Before issuance of a grading permit, the project contractor shall obtain        Prior to the issuance   Construction
                                                           from the Central Valley RWQCB a general NPDES permit and shall                  of a grading permit     Contractor and Elk
                                                           comply with all of the permit requirements in order to minimize storm           and approval of the     Grove Integrated
                                                           water discharges associated with site operations. In addition, the project      final project design.   Waste Division
                                                           contractor shall prepare a SWPPP and implement Best Management
                                                           Practices designed to minimize sedimentation and release of products
                                                           used during site operations.
                                                           Before approval of the final project design, the project contractor shall
                                                           identify storm water runoff BMPs selected from the Stormwater Quality
                                                           Design Manual for the Sacramento and South Placer Regions
                                                           (Sacramento Stormwater Quality Partnership et al. 2007). Typical BMPs
                                                           that could be used on the project site shall include, but are not limited to,
                                                           catchbasin inserts, compost storm water filters, sand filters, vegetated
                                                           filter strips, biofiltration swales, oil/water separators, biodetention
                                                           basins, or other equally effective measures. Other BMPs shall include,
                                                           but would not be limited to, administrative controls such as signage at
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                                                           inlets to prevent illicit discharges into storm drains, parking lot and
                                                           other pavement area sweeping, public education, and hazardous waste
                                                           management and disposal programs. BMPs shall identify and implement
                                                           mechanisms for the routine maintenance, inspection, and repair of
                                                           pollution control mechanisms. In addition, the BMPs shall be reviewed
                                                           for adequacy by the City of Elk Grove, Public Works Department prior
                                                           to issuance of a grading permit for the site to ensure that they will
                                                           effectively remove pollutants from the site’s stormwater runoff.
Mitigation Monitoring and Reporting Program




                                              4.9 Biological Resources
                                              4.9.2        For Site 2 Only:                                                                Prior to the            Construction
                                                           1) Prior to the commencement of construction activities, the City shall         commencement of         Contractor, Elk
                                                              consult with the U.S. Fish and Wildlife Service and California               construction            Grove Integrated
                                                              Department of Fish and Game to determine the agencies’ opinion on            activities.             Waste Division,
                                                              the suitability of the habitat on the project site to support giant garter                           U.S. Fish and
                                                              snake, and the likelihood of injury for giant garter snakes that may                                 Wildlife Service and
                                                              be moving through the project site during construction. If the                                       California
                                                              agencies determine that the project site does not support giant garter                               Department of Fish
                                                              snake habitat, then no additional mitigation is required.                                            and Game
                                                           2) If U.S. Fish and Wildlife Service and California Department of Fish
                                     EDAW




                                                              and Game determine that implementation of the proposed project
Mitigation Monitoring and Reporting Program
EDAW

                                                                                                         Mitigation Monitoring and Reporting Program

                                              Mitigation                                                                                                    Implementation             Verification
                                                                                       Mitigation Measure                                 Timing/Schedule
                                               Number                                                                                                        Responsibility   Action          Date Completed
                                                              could affect giant garter snake, the City shall undertake the
                                                              following measures prior to project grading within 200 feet of Grant
                                                              Line Channel:
                                                              ► Construction personnel shall participate in a USFWS-approved
                                                                 worker environmental awareness program. Under this program,
                                                                 workers shall be informed about the potential presence of giant
                                                                 garter snake and habitat associated with the species and that
                                                                 unlawful take of the animal or destruction of its habitat is a
                                                                 violation of the Endangered Species Act. Prior to construction
                                                                 activities, a qualified biologist approved by the USFWS shall
                                                                 instruct all construction personnel about: (1) the life history of the
                                                                 giant garter snake; (2) the importance of Grant Line Channel to
                                                                 the giant garter snake; and (3) the required avoidance/protection
                                                                 measures. Proof of this instruction shall be submitted to the City
                                                                 and the Sacramento U.S. Fish and Wildlife Service Office.
                                                           3. The City shall mitigate to standard guidelines identified in the
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                                                              USFWS’s Programmatic Formal Consultation for U.S. Army Corps
                                                              of Engineers 404 Permitted Projects with Relatively Small Effects
                                                              on the Giant Garter Snake within Butte, Colusa, Glenn, Fresno,
                                                              Merced, Sacramento, San Joaquin, Solano, Stanislaus, Sutter and
                                                              Yolo Counties, California (1997). Loss of upland basking and retreat
                                                              site habitat resulting from project grading and construction would be
                                                              considered a “Level 3” impact.
                                                              Standard mitigation shall consist of:
                                                              a) replacement of affected giant garter snake habitat at a 3:1 ratio;
Elk Grove Transfer Station Project DEIR




                                                              b) all replacement habitat must include both upland and aquatic
                                                                   habitat components. Upland and aquatic habitat components
                                                                   must be included in the replacement habitat at a ratio of 2:1
                                                                   upland acres to aquatic acres;
                                                              c) if restoration of habitat is a component of the replacement
                                                                   habitat, one year of monitoring restored habitat with a photo
                                                                   documentation report due one year from implementation of the
                       City of Elk Grove




                                                                   restoration with pre- and post-project area photos; and
                                                              d) Five years of monitoring replacement habitat with photo
                                                                   documentation report due each year. Loss of habitat resulting
                                                                   from the project implementation must be replaced at a location
City of Elk Grove
Elk Grove Transfer Station Project

                                                                                                         Mitigation Monitoring and Reporting Program

                                              Mitigation                                                                                                          Implementation              Verification
                                                                                       Mitigation Measure                                 Timing/Schedule
                                               Number                                                                                                              Responsibility    Action          Date Completed
                                                                   deemed appropriate by the USFWS;
                                                              e)   Evidence of compliance with this mitigation measure shall
                                                                   provided prior to grading activities that will remove giant garter
                                                                   snake habitat.
                                              4.9.3        The City shall implement one of the following options prior to ground- Prior to ground               Elk Grove
                                                           disturbing activities:                                                      disturbing activities.   Integrated Waste
                                                           1) Preserve 1.0 acre of similar habitat for each acre lost. This land shall                          Division and
                                                               be protected through a fee title or conservation easement acceptable                             California
                                                               to the DFG and the City of Elk Grove as set forth In Chapter                                     Department of Fish
                                                               16.130.040(a) of the City of Elk Grove Municipal Code as such may                                and Game
                                                               be amended from time to time and to the extent that said Chapter
                                                               remains in effect, or
                                                           2) Submit payment of Swainson’s hawk impact mitigation fee per acre
                                                               of habitat impacted (payment shall be at a 1:1 ratio) to the City of
                                                               Elk Grove’s Swainson’s hawk mitigation fund in the amount set
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                                                               forth in Chapter 16.130 of the City of Elk Grove Code as such may
                                                               be amended from time to time and to the extent that said chapter
                                                               remains in effect, or
                                                           3) Submit proof that mitigation credits for Swainson’s hawk foraging
                                                               habitat have been purchased at a DFG approved mitigation bank.
                                                           For Site 4 Only:
                                                           In order to avoid impacts to nesting habitat for raptors, the City shall
                                                           also implement the following measures prior to construction and site
Mitigation Monitoring and Reporting Program




                                                           grading activities:
                                                           1) Retain a qualified biologist to conduct a focused survey for active
                                                               nests within the single oak tree on Site 4. The survey shall occur no
                                                               more than two weeks prior to ground disturbance.
                                                           2) If no active nests are found, tree removal may proceed. If active
                                                               nests are found, DFG shall be notified, and the tree shall not be
                                                               removed until the nest is no longer active, as determined by a DFG-
                                                               approved biologist. No construction activities shall take place within
                                                               a 500-foot (152-meter) radius of the active nest (or another distance
                                                               determined appropriate during consultation with DFG).
                                     EDAW
Mitigation Monitoring and Reporting Program
EDAW

                                                                                                       Mitigation Monitoring and Reporting Program

                                              Mitigation                                                                                                      Implementation               Verification
                                                                                      Mitigation Measure                               Timing/Schedule
                                               Number                                                                                                          Responsibility     Action          Date Completed
                                              4.9.4        1) Before construction begins, focused surveys for burrowing owls         Prior to and during    Elk Grove
                                                              shall be conducted by a qualified biologist in areas of suitable       site construction      Integrated Waste
                                                              habitat on and within 250 feet of the proposed project site. Surveys activities.              Division and
                                                              shall be conducted in accordance with DFG protocol (DFG 1995).                                California
                                                           2) If no occupied burrows are found in the survey area, a letter report                          Department of Fish
                                                              documenting survey methods and findings shall be submitted to                                 and Game
                                                              DFG, and no further mitigation is required.
                                                           3) If occupied burrows are found, impacts to them shall be avoided by
                                                              establishing a buffer of 165 feet during the non-breeding season
                                                              (September 1 through January 31) or 250 feet during the breeding
                                                              season (February 1 through August 31). The size of the buffer area
                                                              may be adjusted if a qualified biologist and DFG determine that
                                                              project activity would not be likely to have adverse effects. No
                                                              project activity shall commence within the buffer area until a
                                                              qualified biologist confirms that the burrow is no longer occupied. If
                                                              the burrow is occupied by a nesting pair, a minimum of 6.5 acres of
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                                                              foraging habitat contiguous to the burrow shall be preserved until
                                                              the breeding season is over.
                                                           4) If impacts on occupied burrows are unavoidable, onsite passive
                                                              relocation techniques approved by DFG shall be used to encourage
                                                              owls to move to alternative burrows outside of the impact area.
                                                              However, no occupied burrows shall be disturbed during the nesting
                                                              season unless a qualified biologist verifies through non-invasive
                                                              methods that the burrow is no longer occupied. Foraging habitat for
                                                              relocated pairs shall be provided in accordance with guidelines
Elk Grove Transfer Station Project DEIR




                                                              provided by the California Burrowing Owl Consortium (1993),
                                                              which range from 6.5 acres to 19.5 acres per pair.
                                              4.9.6        For Site 2 Only:                                                        Prior to ground          Elk Grove
                                                           To minimize, avoid and mitigate impacts to potential waters of the      disturbing activities.   Integrated Waste
                                                           United States or waters of the state, the City shall implement the                               Division, U.S. Army
                                                           following measures:                                                                              Corps of Engineers
                                                           1) The City shall conduct a formal wetland delineation to determine the                          and Central Valley
                       City of Elk Grove




                                                               extent of jurisdictional waters on Site 2. The wetland delineation                           Regional Water
                                                               report and map shall be submitted to the Sacramento district office                          Quality Control
                                                               of the USACE for verification.                                                               Board
                                                           2) For those waters of the United States that cannot be avoided during
City of Elk Grove
Elk Grove Transfer Station Project

                                                                                                         Mitigation Monitoring and Reporting Program

                                              Mitigation                                                                                                      Implementation             Verification
                                                                                       Mitigation Measure                                 Timing/Schedule
                                               Number                                                                                                          Responsibility   Action          Date Completed
                                                              construction, authorization for fill of jurisdictional waters of the
                                                              United States shall be secured from USACE via the Section 404
                                                              permitting process prior to project implementation.
                                                           3) The acreage of jurisdictional habitat removed shall be replaced or
                                                              rehabilitated on a “no-net-loss” basis in accordance with USACE
                                                              regulations and Policy CAQ-9 of the City of Elk Grove General
                                                              Plan. Habitat restoration, rehabilitation, and/or replacement shall be
                                                              at a location and by methods agreeable to USACE.
                                                           4) Section 401 water quality certification from the Central Valley
                                                              RWQCB shall be obtained.
                                              4.9.7        For Site 4 Only:                                                           Prior to and during   Elk Grove
                                                           1) If feasible, the city shall design project facilities to retain the oak site construction     Integrated Waste
                                                              tree. The oak tree shall be fenced 5 feet beyond the dripline to        activities.           Division
                                                              minimize disturbance to the tree and its root zone. The fence shall be
                                                              maintained until all project activities are complete. No grading,
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                                                              trenching, or movement of heavy equipment shall occur within the
                                                              fenced area.
                                                           2) If removal of the oak tree cannot be avoided, offsite mitigation or
                                                              payment of an in-lieu fee shall be implemented in accordance with
                                                              the City’s Tree Preservation Ordinance.
                                              4.10 Cultural Resources
                                              4.10-2       If an inadvertent discovery of cultural materials (e.g., unusual amounts During site             Elk Grove
Mitigation Monitoring and Reporting Program




                                                           of shell, charcoal, animal bone, bottle glass, ceramics, burned soil,         construction       Integrated Waste
                                                           structure/building remains) is made during project-related construction activities.              Division
                                                           activities, ground disturbances in the area of the find shall be halted and
                                                           a qualified professional archaeologist shall be notified regarding the
                                                           discovery. The archaeologist shall determine whether the resource is
                                                           potentially significant as per CEQA (i.e., whether it is an historical
                                                           resource or a unique archaeological resource) and shall develop specific
                                                           measures to ensure preservation of the resource or to mitigate impacts to
                                                           the resource if it cannot feasibly be preserved in light of costs, logistics,
                                                           technological considerations, the location of the find, and the extent to
                                                           which avoidance and/or preservation of the find is consistent or
                                                           inconsistent with the design and objectives of the project. Specific
                                     EDAW




                                                           measures for significant or potentially significant resources could
Mitigation Monitoring and Reporting Program
EDAW

                                                                                                         Mitigation Monitoring and Reporting Program

                                              Mitigation                                                                                                          Implementation               Verification
                                                                                       Mitigation Measure                                   Timing/Schedule
                                               Number                                                                                                              Responsibility     Action          Date Completed
                                                           include, but are not necessarily limited to, preservation in place, in-field
                                                           documentation, archival research, subsurface testing, and excavation.
                                                           The specific type of measure necessary would be determined according
                                                           to evidence indicating degrees of resource integrity, spatial and temporal
                                                           extent, and cultural associations, and would be developed in a manner
                                                           consistent with CEQA guidelines for preserving or otherwise mitigating
                                                           impacts to historical and unique archaeological resources.
                                              4.10-3       In accordance with the California Health and Safety Code, if human         During ground          Elk Grove
                                                           remains are uncovered during ground disturbing activities all such         disturbing activities. Integrated Waste
                                                           activities in the vicinity of the find shall be halted immediately and the                        Division
                                                           City or the City’s designated representative shall be notified. The City
                                                           shall immediately notify the county coroner and a qualified professional
                                                           archaeologist. The coroner is required to examine all discoveries of
                                                           human remains within 48 hours of receiving notice of a discovery on
                                                           private or state lands (Health and Safety Code Section 7050.5[b]). If the
                                                           coroner determines that the remains are those of a Native American, he
16




                                                           or she must contact the Native American Heritage Commission by
                                                           phone within 24 hours of making that determination (Health and Safety
                                                           Code Section 7050[c]). The responsibilities of the Agency for acting
                                                           upon notification of a discovery of Native American human remains are
                                                           identified in detail in the California Public Resources Code Section
                                                           5097.9. The City or their appointed representative and the professional
                                                           archaeologist shall consult with a Most Likely Descendant determined
                                                           by the NAHC regarding the removal or preservation and avoidance of
                                                           the remains and determine if additional burials could be present in the
Elk Grove Transfer Station Project DEIR




                                                           vicinity.
                                              4.10-4       If, during the course of ground-disturbing activities associated with          During ground          Elk Grove Planning
                                                           project implementation, any paleontological resources (fossils) are            disturbing activities. Department
                                                           discovered, work shall be halted immediately within 50 feet of the
                                                           discovery, and the City Planning Department shall be immediately
                                                           notified. At that time, the City will coordinate any necessary
                                                           investigation of the discovery with a qualified paleontologist.
                       City of Elk Grove




                                                           The City shall consider the mitigation recommendations of the qualified
                                                           paleontologist for any unanticipated discoveries of paleontological
                                                           resources. The City shall consult with the paleontologist and agree upon
City of Elk Grove
Elk Grove Transfer Station Project

                                                                                                       Mitigation Monitoring and Reporting Program

                                              Mitigation                                                                                                      Implementation               Verification
                                                                                      Mitigation Measure                               Timing/Schedule
                                               Number                                                                                                          Responsibility     Action          Date Completed
                                                           implementation of a measure or measures that are deemed feasible and
                                                           appropriate. Such measures may include avoidance, preservation in
                                                           place, excavation, documentation, curation, data recovery, or other
                                                           appropriate measures.
                                              5 Cumulative Impacts
                                              5-1          Install a traffic signal at the Elk Grove-Florin Road/East Stockton         Prior to the initiation Elk Grove Public
                                                           Boulevard intersection as planned for in the City’s Capital Improvement of Transfer Station Works Department
                                                           Program and as identified in Mitigation Measure 4.2-2. Currently this       operations.
                                                           improvement is included in the fee program and is anticipated to be
                                                           constructed prior to the operations of the transfer station. If the
                                                           improvement is not in place, this project will be required to construct it.
                                              5-2          Site 4 Only                                                               Prior to the initiation Elk Grove Public
                                                           Install a traffic signal at the Elkmont Way/East Stockton Boulevard       of Transfer Station Works Department
                                                           intersection, as identified in Mitigation Measure 4.2-3.                  operations.
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                                              5-3          ►   Restripe the southbound approach to the Grant Line Road/Survey       When warranted      Elk Grove Public
                                                               Road intersection to provide one left-turn lane, one shared through- based on cumulative Works Department
                                                               right turn lane, and one right-turn lane on the southbound approach. traffic volumes.
                                                           ►   Change the signal operation from six to eight phases including any
                                                               necessary intersection restriping.
                                                           ►   Modify the timing of other coordinated signals along Grant Line
                                                               Road, as necessary and appropriate.
Mitigation Monitoring and Reporting Program
                                     EDAW

								
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