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RECEIVED San Joaquin Valley AUG I Air Pollution Control District Community I)evelogment Dept, August 15, 2005 Reference No. 020050791 Rick Griffin i San Joaquin County Community Dev. Dept. 1810 East Hazelton Avenue ` Stockton, CA 95205 Subject: PA-0500462—Musco Family Olive Company Dear Mr. Griffin: 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 classified non-attainment for ozone and fine particulate matter (PM10). This project will contribute to the overall decline in air quality due to increased traffic and ongoing operational emissions. This project may generate significant air emissions and it will reduce the air quality in the San Joaquin Valley. The project will make it more difficult to meet mandated emission reductions and air quality standards. Preliminary analysis indicated that the potential emissions from this project exceed the District's Thresholds of Significance for ozone precursors. These thresholds are 10 tons per year for either of the following two ozone precursor emissions: reactive organic gases (ROG) or oxides of nitrogen (NOx). The District recommends the preparation of an Air Quality Impact Assessment (AQIA) and a Traffic Impact Study to determine impacts when projects are of this size, unless an analysis has been accomplished for a recent previous approval such as a general plan amendment or zone change. Please indicate to the District if the project has been analyzed and what the results were from any previous study. Ozone Precursors (ROG, NOx)- The information received by the District did not include the annual estimated tonnage for the proposed facility. As such, District calculations were based on the windrow sizes provided. The applicant should identify the throughput expected by the facility, and the maximum annual tonnage they may receive. This information is necessary to determine an accurate ROG emissions estimate for the project. The District recommends using the South Coast Air Quality Management District Source Testing emission factor (3.84 lbs ROG/yr/ton) for estimating ROG emissions from green waste composting. NOx emissions estimates should include internal combustion emissions (from equipment and vehicles) and from composting processes. For more information on estimating ROG and NOx emissions from composting operations, please contact Ms. Lucinda Roth, Air Quality Specialist, at (559) 230-5800. 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. Hazardous Air Pollutants (HAPs)- The proposed project should be analyzed to see if it is considered near a location of sensitive receptors and if HAPs are a concern. Potential HAPs sources include project equipment, operations, and vehicles (the Air Resources Board (ARB) has designated diesel particulate emissions as a toxic air contaminant). On page 43 of the District's Guide for Assessing and Mitigating Air Quality Impacts, 2002 Revision (GAMAQI), the District