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San Joaquin Valley IM� is 91 <br /> AIR POLLUTION CONTROL DISTRICT HEALTH' AIR LIVING'" <br /> November 16,2011 <br /> Ms. Kerry Sullivan,Director <br /> San Joaquin County Community Development Department <br /> 1801 E.Hazelton Ave <br /> Stockton CA 95205 <br /> Subject: Final EIR Munn&Perkins Quarry Excavation Permit. <br /> Dear Ms. Sullivan, <br /> The San Joaquin Valley Air Pollution Control District(District)has reviewed the Final <br /> Environmental Impact Report for the Munn and Perkins Quarry Excavation Permit and offers the <br /> following comments: <br /> 1. The existing facility has a significant history of odor complaints. In 2008 the District <br /> received a total of 3 complaints regarding operations at this site and alleging that odors form <br /> the facility are posing a nuisance. In 2009 there were 7 additional complaints, and in 2011 <br /> the District has received a total of 11 complaints to date. The District's threshold of <br /> significance for odor impacts is more than one confirmed complaint per year averaged <br /> over a three year period, or three unconfirmed complaints per year averaged over a three- <br /> year period. Thus, odors from the existing facility should be considered to have a <br /> significant impact on nearby residential areas and other sensitive receptors. <br /> 2. Under the proposal being considered an increase in odor complaints would be <br /> expected. Because this proposal allows for the night time operations with rubberized <br /> asphalt, the District is concerned that reduced winds and low-level inversion conditions <br /> may increase the potential for exposing nearby residential areas and other sensitive <br /> receptors to objectionable odors. An increase in the number and frequency of odor <br /> nuisance complaints regarding this facility would exacerbate an existing significant <br /> impact. Under these circumstances, the facility operator would potentially be subject to <br /> enforcement action public nuisance violations under District Rule 4102 and/or California <br /> Health and Safety Code Section 41700. <br /> 3. The discussion of alternatives and mitigation should be expanded. Section 3.3.3 Impacts <br /> and Mitigation Measures, should include a discussion on potential odor control equipment <br /> that may be available to reduce odor impacts from the use of rubberized asphalt. Project <br /> design elements that can reduce odorous emissions include add-on controls or process <br /> changes, such as carbon absorption, incineration, and engineering modifications to <br /> stacks/vents. <br /> Northern Region Central Region(Main Citice) Southern Region <br /> 4800 Enterprise Way 1990 E.Gettysburg Avenue 34946 Flyover Court <br /> Modesto,CA 953568718 Fresno,CA 937260244 Bakersfield,CA 93308-9725 <br /> Tel:(209)557 FAX:(209)557-6475 Tel:155912306000 FAX:15591230 6061 Tel:661-3925500 FAX:661-3925585 <br /> www.valleyair.org www.healthyairliving.com <br />