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I Ms.Allen December 20, 2005 PA-0500809 (SA) Page 2 particulate emissions as a- toxic air contaminant). The project consultant:Should contact ,the. District to.verify the appropriate th';:holds. to use, as'wetl as review the; proposed modeling approach-before modeling begins i=or.rnore information on HRAs; please coritact'Mr.:Lelarid ViNalvazo Supervising Air Quality Specialist' at (559). 230-59D0, or Ieland.vi1161V. io vane air or Odor Analysis' The proposed project should, be analyzed,to see,.if'it is considered near:a, location of sensitive recap#ors'and if'odo`r is a concern. On:page'43_of"the GAMAQi the District' . aeEdresses:and':defines sensitirie receptors:with respect t&CEQA. if the:projeet is near a'location of'sensitive recep#ors and there is a:potential o'doi impact,`an Odor Impact'Arialysis should 6e contlucted. The aocatio'n of.sens!five receptors sh661' be explained in terms that demonstrate th&I relationship (e.g: proximity, topography,:or upwind and downwind location) between the:project site and potential airxquali#y.iimpacts.'The od&impact analysis.shodld include the processes that: the"project will;emp oy,'6M:measures included to.reduce odor impacts. Odor imposts "should.be quantified,when'possible." To'estimate odor1mpacts, a three-step-approach can be used. First; the emissions of specific' odorous ,coimpounds (e.g., hydrogen. sulfide) should be estimated'. Second, these 'emissions should`be modeledusing the Iridtistrial`'Source Complex Short-TerrTi (ISCST3);model with.a full year of the most,appropriate meteorological .data. (Meteorological data can be obtained from our website at www.Valleyair,oro.) Third, the predicted concentrations should be cornpared'to odor thresholds. Odor thresholds can vary greatly depending upon the compounds considered and the source of odor thresholds. The following website contains sources of information for odor thresholds http://response.restoration.n6aa.gov/cariieo/dr alohalodorlodor.htmi. The project consultant should contact the District to verify the appropriate thresholds to use, as well as review the proposed modeling;approach before modeling begins. For more information on odor impact analyses, please contact Mr. Leland Villalvazo, Supervising Air Quality Specialist, at (559) 230- 5900, or leland.vilialvaxoavalleyair.org. Based on the information provided, the proposed project will be subject to the following District rules. The following items are rules that have been adopted by the District to reduce emissions throughout the San ,Joaquin Valley, and are required. This project may be subject to additional District Rules. To identify additional.rules or regulations that apply to this project, or for further information, the applicant is strongly encouraged to contact the District's Small Business Assistance Office at (209) 557-6446. Current District rules can be found at http://www.valleyair.orm/rules/1ruieslist.htm. Rule 2201 (New and Modified Stationary Source Review Rule) This rule applies to all new stationary sources and all modifications of existing stationary sources which are subject to the District permit requirements and after construction emit or may emit one or more affected pollutant. The applicant must contact the District's Small Business Assistance Office at (559) 230-5888 to receive additional inform a tionlinstructions. Rule 3135 (Dust Control Plan Fee) This rule requires the applicant to submit a fee in addition to a Dust Control Plan. The purpose of this fee is to recover the District's cost for reviewing these plans and conducting compliance inspections. More information on the fee is available on the District website at: htt ://www.valle air.or /rules/currntrules/Rule%203135%20'1005. df. Rule 3190 (Conservation Management Practices Plan Fee) This rule requires the applicant to submit a fee in addition to a Conservation Management Practices application. The purpose of this fee is to recover the District's cost for the review and management of these applications. More information on the fee is available on the District website at: http://www.valleyair.org/rules/currntrutes/r3l9O.pdf. Rule 4102 (Nuisance) applies to any source operation that emits or may emit air contaminants or other materials. In the event that the project or construction of the project creates a public nuisance, it could be in violation and be subject to District enforcement action.