SU0004094 - Laserfiche WebLink

Home Browse Search

hour ("lb/ht") or 2,353 pounds per day ("lb/day"). (Draft EIR, p. 4.6-20.) Emission calculations are presented in attached Table A-1. The SJVAPCD has not established PM10 significance criteria for either construction or operation. (SJVAPCD 1/10/02: GAMAQI, Sec. 4.3.)Thus, we relied on construction-specific thresholds established by other air districts to evaluate the significance of these emissions. Four air districts currently recommend significance thresholds that apply specifically to short-term construction emissions. The SMAQMD has a PM10 construction emission significance threshold of 275 lb/day. (SMAQMD 1994,9 p. A-2, Table A-2.) The South Coast Air Quality Management District ("SCAQMD") has a PM10 construction emission significance threshold of 150 lb/day. (SCAQMD 4/93,10 p. 6-4.)The San Luis Obispo County Air Pollution Control District("SLOCAPCD") has a PM10 construction emission significance threshold of 2.5 tons per quarter, concluding that"any project with a grading area -22 greater than 4.0 acres of continuously worked area will exceed the 2.5 ton PM10 quarterly threshold." (SLOCAPCD 4/03,11 p. 64.) Finally, the Monterey Bay Unified Air Pollution Control District("MBUAPCD") has a PM10 construction emission significance threshold of 82 lb/day. This is equivalent to 2.2 acres per day for sites with grading and excavation and 8.1 acres per day for sites with minimal earthmoving. (MBUAPCD 9/02,12 p. 5-3.) The fugitive dust emission estimates in Table A-1 greatly exceed the construction emission significance thresholds of every air district that has such thresholds. The fugitive dust emissions from the Project would have to be controlled by over 96 percent to reduce fugitive dust PM10 emissions to below the above cited — air districts' significance thresholds for PM10. This is not feasible because large amounts of fugitive dust are generated during site preparation, particularly grading. Comparison of mitigation measures contained in Regulation VIII with control efficiencies determined by other agencies for these mitigation measures13 shows that the mitigation measure with the highest control efficiency applicable to site _ preparation,watering, has a control efficiency of about 69 percent. Conservatively 9 Sacramento Metropolitan Air Quality Management District,Air Quality Thresholds of Significance, 1994. 10 South Coast Air Quality Management District,CEQA Air Quality Handbook,April 1993. _ 11 San Luis Obispo Air Pollution Control District,CEQA Air Quality Handbook,a Guide for Assessing the Air Quality Impacts for Projects Subject to CEQA Review, April 2003. 12 Monterey Bay Unified Air Pollution Control District,CEQA Air Quality Guidelines,revised September 2002. 13 WRAP 11/04,Table 3-6;South Coast Air Quality Management District,CEQA Air Quality _ Handbook,April 1993,Table 114. 12