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<br /> <br /> <br />Memorandum <br />March 25, 2025 <br />Page 13 <br />21202-23 North County Landfill_AQ_0307 <br />condition, the conservatively estimated maximum emissions from the flare are below the Valley <br />Air District’s thresholds of significance. Therefore, the impact associated with LFG-related <br />criteria air pollutant emissions would be less than significant. <br />Table 3. Estimated Annual Criteria Air Pollutant and Precursor Emissions from <br />Permitted LFG Collection System (tons per year) <br />Emission Scenario Emissions (tons per year) <br />ROG2 NOx PM10 CO SOx <br />Baseline Condition1 <0.01 0.04 0.09 <0.01 0.02 <br />Project Condition 1.41 6.41 3.63 9.62 3.21 <br />Net Difference 1.41 6.37 3.54 9.62 3.19 <br />Valley Air District Thresholds 10 10 15 100 27 <br />Threshold Exceeded? No No No No No <br />1 Based on 2023 inventory for the North County Landfill. <br />2 ROG emissions based on total VOC emissions. <br />Source: Attachments A and B. <br />Exposure to Toxic Air Contaminants <br />Project operation would generate LFG-related emissions and DPM emissions from the exhaust <br />of on-road heavy-duty diesel haul trucks and on-site off-road diesel construction equipment. As <br />discussed above, the closest sensitive receptor is a residence located on-site approximately <br />2,100 feet northeast from the top of Lined Area 1, and approximately 1,800 feet northeast from <br />the existing LFG flare station (Figure 1). Because the closest sensitive receptor is not located <br />within 1,000 feet of the fill area and flare station, exposure to on-site TACs during project <br />operation was not evaluated. Although LFG may contain trace amount of TACs, the health risk <br />from flare emissions is typically very low as the combustion process would destroy most toxic <br />substances contained in the flared gas. Per the project’s Title V permit, VOC destruction <br />efficiency for the flare shall be at least 98 percent by weight. <br />For sensitive receptors along the haul route, a health risk assessment was conducted to <br />estimate the incremental increase in cancer risk and chronic hazard index (HI) from exposure to <br />DPM emissions from trucks in accordance with guidance from the Valley Air District 8 and the <br />Office of Environmental Health Hazard Assessment (OEHHA).9 <br /> <br />8 Joaquin Valley Air Pollution Control District (Valley Air District), 2015. Guidance for Assessing and Mitigating Air <br />Quality Impacts (CEQA Guidance), March 19. <br />9 Office of Environmental Health Hazard Assessment (OEHHA), 2015. Air Toxics Hot Spots Program Guidance Manual <br />for Preparation of Health Risk Assessments, May.