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` maximum short-term emissions should have been based on operation 24 hours per day. It was not. Maximum daily emissions are therefore at least three times higher than disclosed in the Draft EIR. The daily emission calculation spreadsheets in Exhibit 1 assume all of the �- equipment operates only 8 hours per day. The Draft EIR contains no restrictions whatsoever on the number of hours per day that the processing equipment can operate, nor the number of days per year that the facility will operate. Thus, it is reasonably foreseeable that the Project could operate up to 24 hours a day, 6 days a B-28 week,year round. The Draft EIR should be revised to restrict Project operation to the oont. 6. conditions assumed in the emission calculations, or the emissions should be recalculated based on potential maximum emissions and the Draft EIR should be recirculated. IBM The Draft EIWs annual emission estimates assume that the concrete and recycling plants would operate 2,089 hours per year, and the asphalt plant would operate 2,000 hours per year or only about a quarter of the time. The design process rates of these facilities indicate that they could operate for many more hours than assumed in the emission calculations. The Draft EIR should be revised to evaluate ` air quality and other impacts for the maximum production rate or the production rate should be restricted to the level evaluated in the Draft EIR. r. IV.A.2 Quarry Production Rate 6. The Draft EIWs operational emission estimates are based on a hypothetical quarry with production rates of 1.7, 2.85, and 4.0 million ton/year. (Draft EIR, p. 4.6- 23 -4.6-24.) The facility will be designed with a processing capacity of 8,000 tons per to hour of materia1.29 Thus, these production rates correspond to operating only 212.5 hours, 356.25 hours, and 500 hours per year, respectively, or up to only 21 days B-29 6, per year assuming operation for 24 hours per day or 63 days per year for operation, 8 hours per day, as assumed in the emission calculations 30 Clearly, the facility could operate for more days than only 63 days. Thus, the hypothetical production rates significantly understate the potential output of this facility and hence all impacts, including noise and transportation. The Draft EIR does not restrict the Applicant to a maximum production rate of 4.0 million L 29 See Excel spreadsheets,Estimated PM10 Emissions from Quarry Processing Operations-Baseline, in file labeled"Vernalis Process.xls." ` 30 The annual PM10 emissions from quarry processing operations were incorrectly calculated in the Excel spreadsheets by assuming that hours of operation(212.5,356.25,500)were days of operation. 21 L