Laserfiche WebLink
r Table 2 <br /> CO Emissions <br /> L Emissions <br /> Source (ton/yr) <br /> On-site equipment 11.90 <br /> Off-site trucks 31.51 <br /> 6. Plant site 3.25 <br /> Pit site 8.65 B_31 <br /> I Asphalt drum 80 cont. <br /> 6 Oil heater 0.25 <br /> Fugitives 0.17 <br /> Total 135.7 <br /> C <br /> 1. <br /> The Draft EIR does not contain any significance thresholds for CO emissions. <br /> However, other air districts have published CEQA significance thresholds for CO, <br /> ,L including the BAAQMD and the SCAQMD, both of which consider emissions <br /> greater than 550 lb/day to be significant. The CO emissions disclosed in the Excel <br /> spreadsheets amount to 7441b/day, assuming 365 days per year. However, as <br /> 6" discussed in Comment IV.A.1, these emissions are based on less than 365 days per <br /> year. Thus, peak daily emissions would be higher. Thus, CO emissions from the <br /> Project are significant. This is a new impact that was not disclosed in the Draft EIR. <br /> IV.0 PM10 Emissions Are Significant <br /> The Draft EER presented PM10 emission estimates (Table 4.6-5), but is <br /> generally silent as to their significance,31 instead arguing that the SJVAPCD does not <br /> �. have a significance threshold for PM10. (Draft EIR, p. 4.6-22.) However, the absence <br /> of an agency significance threshold does not excuse the County from analyzing the <br /> impact of PM10 emissions. The County could have adopted the PM10 emission <br /> thresholds of other similarly situated areas,e.g., the SCAQMD (150 lb/day or <br /> 27 ton/yr), or it could have used dispersion modeling to determine whether PM10 B-32 <br /> ` emissions cause or contribute to violations of PM10 ambient air quality standards. It <br /> did neither. <br /> Instead, the Draft EIR insinuates that compliance with SCVAPCD Rule VIII <br /> and air permitting requirements in the Authority-to-Construct ("ATC') permit <br /> adequately mitigates PM10 emission impacts. (Draft EIR, p. 4.6-22.) This is incorrect. <br /> r <br /> First, Rule VIII only applies to fugitive dust emissions, which account for less <br /> than 20% of the total PM10 emissions. The emission calculations in the Draft EIR <br /> L <br /> V31 The cumulative impact analysis states that emissions of PM10, PM23 and DPM from the Project are <br /> not significant.(Draft EIR,p.611.)However,we were unable to find any support for this conclusion. <br /> 23 <br /> I <br />