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I. L COMMENTS i 6. San Joaquin County ("County") as the Lead Agency under the California Environmental Quality Act ("CEQA") has prepared a Draft Environmental Impact L Report("Draft EIR")' for the RMC Pacific Vernalis Quarry Mining and Reclamation Project("Project'). RMC Pacific Materials ("Applicant') proposes to establish a new open-pit aggregate quarry on approximately 688 acres of land approximately two miles east-northeast of the Highway 580/Highway 5 interchange south of Tracy. B-1 The proposed Project would extract and process 1.7 to 4.0 million tons per year ("ton/year') of sand and gravel over a 26-to 60-year time period. In addition, the Project would operate a ready-mix concrete batch plant with an estimated production of 350,000 cubic yards per year ("yd3/year"), an asphalt batch plant with an estimated production of 400,000 ton/year, and a portable recycling plant estimated to process about 100,000 ton/year of broken concrete/asphalt pavement. The hours of operation for both excavation and processing would be 24 hours per day Monday through Saturday with maintenance occurring on Sundays. (Draft EIR, pp. 3-1, 3-8, 3-17, 3-22.) The comments below indicate that the air quality analysis is fundamentally flawed due to numerous errors and omissions. Construction and operation of the Project would result in significant air quality impacts due to the emission of nitrogen L oxides ("NOx"), reactive organic gases ('ROG"), particulate matter with an aerodynamic diameter of 10 micrometers or less "PM10" B-2 yn ( ), and carbon monoxide ("CO") that were not disclosed in the Draft EIR. The Project also would result in significant odor impacts. The Draft EIR failed to identify and require all feasible 6. mitigation measures to reduce these significant impacts. The Draft EIR should be revised to address the issues raised below and recirculated for review. I. THE DRAFT EIR'S AIR QUALITY IMPACT ANALYSIS IS NOT SUFFICIENTLY DOCUMENTED The Draft EIR presents a discussion of potential air quality impacts from B-3 s construction and operation of the Project in Section 4.6. This section summarizes annual emission estimates for NOx, ROG, and PM10 from construction (grading of the Project site and demolition of existing buildings) in Table 4.6-4. Tables 4.6-5A, 6. L1 San Joaquin County,Draft Environmental Impact Report,RMC Pacific Vernalis Quarry Mixing and Reclamation Expansion Project,SCH No.2002122122,May 2006. L L