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C mocT � 8 zo `� AFD San Joaquin Valley o munity o Air Pollution Control District ��velopm�ntDe At October 27, 2005. Reference No_'.C200501390 F Kathy Allen San Joaquin County. Community Development Department 1810 East Hazelton Avenue Stockton, CA 95.205 Subject: PA 0500686 (UP)APN: 063-100-19, 063-080-25 & 063-130-01.Cortopass i Partners Dear Ms Allen: 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 PM2.5J. 7his`.protect would;contribute to the overall decline in.air quality due to increased,,, traffic and ongoing operatianaf emissions Vere is currently not enough.information for the District to adequately or accurately.analyze.:the"p�oje.t,for_potential air-q661 .impacts, The District recommends using the URBEMIS 2002 "Version 8.7 program tb.calculate project".area and operational .emissions .and to identify mitigation measures that".reduce impacts. . URBEMIS b6n be downloaded from www.urbbmis.com or the South Coast-Air Quality Management District's website at http:llwww.agmd.goWc6ga/urbemis.htmi. If the analysis- reveals that the emissions generated by this project will exceed the District's thresholds, this project may significantly impact the ambient air quality if not sufficiently mitigated. The project applicant or consultant is encouraged to consult with District staff for assistance in determining appropriate methodology and model inputs. The applicant stated that during the seasonal months (October through December) the facility would operate 7 days per week and 12-hour shifts. The number of semi-trucks that may make deliveries on a daily basis is ilut stated in the appiicatiun. The California Alk Resoutces hoard (CARR) nas designated diesel particulate emissions as a toxic air-contaminant. The proposed project should be analyzed to see if it is considered near a location of sensitive receptors and if diesel toxicity is a potential source of concern. On page 43 of the"Guide for Assessing and Mitigating Air Quality Impacts" (GAMAQI), the District addresses and defines sensitive receptors with respect to CEQA. If the project is near sensitive receptors and diesel toxicity is a concern, the project developer should perform a Health Risk Assessment(HRA). The applicant stated: "The solid agriculture waste will be spread and tilled under on the adjacent parcel to eliminate odors." The District considers an olive oil processing "p)ant to.be a food processing.facility, not a farming operation„as it does not involve the growing of crops or raising of fowl or animals;,therefore, the. olive oil processing'facility is subject to Rule 4102 (Nuisan"ce)` The provisions of Rule-4102.3.1 do not apply to odors emanating from pgrico.Itural operations in the"growing.of crops or raising of fowl or animals as defined in Rule 4103.3.2.(Open.Burh rig). 'Rine 4103 3:3`c�efines'agricultural waste as "any.yegetative :materials produced wholly from agricultural-operations; the`aperatiori or maintenance of a systeri for the delivery of water in agricultural operations :.,." Per Rule 4102.4.i a.person shall not discharge from any