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v San Joaquin Valley Air Pollution Control District June 30, 2006 Reference No. 0200601487 Rick Griffin RECIEVED San Joaquin County Community Development Dept. JUL 0 6 2D06 1810 East Hazelton Avenue Stockton, CA 95205 Community Development Dept Subject: PA-0600346 (SU); Circle JM Dairy Property; APN 257-150-02 Dear Mr. Gruen: The San Joaquin Valley Unified Air Pollution Control District (District) has reviewed the project referenced above and offers the following comments: The entire San Joaquin Valley Air Basin is designated non-attainment for ozone and particulate matter (PM10 and PM2.5). This project would contribute to the overall decline in air quality due to construction activities in preparation of the site, and ongoing traffic and other operational emissions. Based on the size of the project, the District expects that the project would not exceed the District's thresholds of significance for ozone precursors of 10 tans per year of reactive organic gases (ROG) and oxides of nitrogen (NOx). Although the proposed project will produce less than significant amounts of pollution, it is located in close proximity to three major dairies. As a result of the location, the 17 proposed residential homes may be considered sensitive receptors. There may be health risks to future occupants due to the emissions produced through normal dairy operations. On page 43 of the District's Guide for Assessing and Mitigating Air Quality Impacts, 2002 Revision (GAMAQI), the District addresses and defines sensitive receptors with respect to CEQA. If the project is near a pollution producing facility and HAPS are a concern, the project developer should perform a Health Risk Assessment (HRA). HRA guidelines promulgated by the California Office of Environmental Health Hazard Assessment (OEHHA) and OEHHA toxicity criteria must be used. The District recommends use of the latest version of the Hot Spots Analysis and Reporting Program (HARP) released by the Air Resources Board for a health risk assessment because it is the only software that is compliant with the OEHHA guidelines. An HRA should include a discussion of the toxic risk associated with the proposed project, including project equipment, operations, and vehicles. The GAMAQI defines the significance levels for toxic impacts as a cancer risk greater than 10 in a million and/or a hazard index (HI) of 1.0 or greater for chronic non-carcinogenic or acute risks. The project consultant should contact the District to review the proposed modeling approach before modeling begins. For more information on HAPs analyses, please contact Mr. Leland Villalvazo, Supervising Air Quality Specialist, at (559) 230-6000 or hramodeler anvallevair.ora. Regulation VIII (Fugitive PM10 Prohibitions) Rules 8011-8081 are designed to reduce PM10 emissions (predominantly dust/dirt) generated by human activity, including construction and demolition activities, road construction, bulk materials storage, paved and unpaved roads, carryout and trackout, landfill operations, etc. The District's compliance assistance bulletin for construction sites can be found at http//www vallevair orq/busind/comply/PM10/Req%20VIII%20CAB Pdf. If a residential site is 1.0 to less than 10.0 acres, an owner/operator must provide written notification to the District at least 48 hours prior to his/her intent to begin any earthmoving activities as specked in Section 6.4.1 of Rule 8021. A template of the District's Construction Notification Form is available at http•//www vallevair.orq/busind/comply/PM10/forms/Notification%20Form%2OFina1%2012.01.2005.doc. Northern Region Office Central Region Office Southern Region Office 4800 Enterprise Way 1990 East Gettysburg Avenue 2700 M Street,Suite 275 Modesto,CA 95356-8718 Fresno,CA 937260244 Bakersfield,CA 93301-2373 1209)557-6400 • FAX (209)557-6475 (559)230-6000 • FAX (559)230-6061 (661)326-6900 • FAX(661)326-6985 svww.va11eyaicnrg