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San Joaquin County January 27, 2003Page 2 PA-02-00632 (UP) One of the issues that will arise in conjunction with any proposed renovation/demolition of the existing building in the project area is compliance with the National Emission Standards for Hazardous Air Pollutants (NESHAPS). Specifically, the primary air pollutant of concern is asbestos. To ascertain whether this project is subject to NESHAPS, the project applicant is advised to review the enclosed Asbestos - Compliance Assistance Bulletin, dated December 1994. Leaf Sexton is the Northern Region's District contact for the program and is available should you need further assistance. The proposed facility may have the potential to generate odors during the processing phase of the operation. The County should carefully evaluate this potential and the impact that any odors could have on sensitive receptors in the area. The District encourages the County to monitor the operation of the facility carefully to ensure that odors do not become an issue. The processing facility will be subject to District Rule 4102 (Nuisance). The purpose of this rule is to protect the health and safety of the public and applies to any source operation which emits or may emit air contaminants or other material. A possible violation could occur if the project proponent discharges quantities of air contaminant that result in the following nuisances: • Injury, detriment, or annoyance to any considerable number of persons or to the public. • Endangers the comfort, repose, health, or safety of any such person or the public. • Has a natural tendency to cause injury or damage to business or property. Finally, the District strongly recommends that the project applicant implement as many feasible mitigation measures, such as the following, to reduce on site emissions/energy usage. • Energy efficient design including automated control system for heating/air conditioning and energy efficiency beyond Title 24 requirements, lighting controls and energy-efficient lighting in buildings, increased insulation beyond Title 24 requirements, and light colored roof materials to reflect heat. Planting of deciduous trees on the south and westerly facing sides of buildings. Provide low nitrogen oxide (NOx) emitting and/or high efficiency water heaters. Thank you for the opportunity to comment. If you have any questions, please feel free to contact me at (209) 557-6400. Sincerely, John Cadrett Environmental Planner APCD REF#20030019 Northern Region