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y r) REc �� EI VFD San Joaquin Valley C°mrn0r Z 8 ZO05 Air Pollution Control District rnty��y��am�ntD October 27, 2005 Reference No. C200501390 Kathy Allen San Joaquin County Community Development Department 1810 East Hazelton Avenue Stockton, CA 95205 Subject: PA 0500686 (UP)APN: 063-100-19, 063-080-25 & 063-130-01 Cortopassi Partners CDear Ms Allen: k The San Joaquin Walley 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 increased . traffic and on operational emissions :Th6're is currently not;er�ougfi information for the District to adequately,or accurately.anaiyze the'project for`potential air_quality impacts The District recommends using the URBEMI.S 2002 Ve[sion 8.7 program to.calculate project area and { operational emissions .and to identify mitigation measures that reduce, impacts. , URBEMIS can be downloaded from www.urbemis.com or the South Coast"Air Quality Management District's website at http://www.@_qmd.gov/cega/urbem is.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 not stated in the appiicatiori. The Caiiforriia Alf Resowoes Burd (CAA-b)has designated diesel particulate emissions as a toxic air contaminant: The proposedproject 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 ptant to.be a food processing.facility; not a farming operatibm as it,does not involve the growing of crops or raising.of fowl or animals;,therefore, the. . blive`oil'pracessing'facility'is subject to Rule 4102(Nuisance); `Thd provisions of''Rule 4102.3.1 do not apply,to,odors emanating from agricultural operations in the growing of craps or raising of fowl or animals as defined in Rule 4103.3.2 (O,pen Burhhg). Ruie:4103.3:3 de 'i�es'agricultural waste as "any vegetative materials'produced wholly from agricultural•operations, the operation'o,r maintenance of a" tern for the delivery of water in agricultural operatior!�':. ;" Per Rule 4102.4: E a Person shall not discharge from any w