HomeMy WebLinkAbout1-25-2017 PC Correspondence - Item 2 (Air Pollution Control District)Meeting: p Z� 1T
Item: I
From: Ingrid Schumann
Sent: Wednesday, January 18, 2017 2:51 PM
To: Scott, Shawna <sscott slocit .or >
Cc: Melissa Guise < ; Rubi Rajbanshi <
Subject: APCD Comments Regarding the Imel Ranch Subdivision (SBDV-2586-2016, Tract 3095)
Hello: I have attached the signed electronic version of the above referenced comment letter to meet
today's deadline. Your hard copy, along with any applicable attachments, will be sent to you via US
mail. If you have any questions or comments, please do not hesitate to call our office. Thank -you.
Best, Ingrid
Ingrid Schumann
Air Pollution Control District
805-781-5728
slocleanair.or�
Ingrid Schumann
Air Pollution Control District
3433 Roberto Court
San Luis Obispo CA 93401
805-781-5728
slocleanair.ore
RECEIVED
CITY OF SAN LUIS OBISPO
JAN 2 3 2017
COMMUNITY DEVELOPMENT
SLO COUN
apcd
January 18, 2017
Air Pollution Control District
San Luis Obispo County
Shawna Scott, Associate Planner
City of San Luis Obispo
919 Palm St.
San Luis Obispo Ca 93401
SUBJECT: APCD Comments Regarding the Imel Ranch Subdivision (SBDV-2586-2016,
Tract 3095)
Dear Ms. Scott:
Thank you for including the San Luis Obispo County Air Pollution Control District (APCD) in
the environmental review process. We have completed our review of the proposed
project on the west side of Orcutt Road immediately southwest of Tiburon Way in San Luis
Obispo. The City of San Luis Obispo has completed the Draft Initial Study/Mitigated
Negative Declaration (IS/MD) for the proposed Imel Ranch Subdivision. The IS/MND is
tiered off of the Orcutt Area Specific Plan (OASP) Final Environmental Impact Report. The
applicant, Ambient Communities, proposes to subdivide an existing 5.49 -acre parcel into
23 lots including: 18 residential lots for the development of 18 single-family homes, two
lots to support onsite detention basins, and three open space lots.
The following are APCD comments that are pertinent to this project.
GENERAL COMMENTS
As a commenting agency in the California Environmental Quality Act (CEQA) review process
for a project, the APCD assesses air pollution impacts from both the construction and
operational phases of a project, with separate significant thresholds for each. Please
address the action items contained in this letter that are -highlighted ley bald and
underlined text.
As noted on page 12 of the Initial study, the project is in close proximity to existing
residential units and could potentially expose sensitive receptors. Therefore, the project
proponent will be required, by the OASP mitigate measures, to submit final tract
construction plans to SLOCAPCD for comment and/or approval prior to grading and
construction of the project. The following is a list of items that should be addressed in the
tract construction plans.
ConstrucfignPbase Emissions
NaturallyOccurring Asbestos
Naturally occurring asbestos (NOA) has been identified by the California Air Resources
Board as a toxic air contaminant. Serpentine and ultramafic rocks are very common
805.781.5912 805.781.1002 slocleanair.org 3433 Roberto Court, San Luis Obispo, CA 93401
Initial Study / Mitigated Negative Declaration for Imel Ranch Subdivision
January 17, 2017
Page 2 of 5
throughout California and may contain naturally occurring asbestos. The SLO County APCD has
identified areas throughout the county where NOA may be present (see the APCD's 2012 CEQA
Handbook, Technical Appendix 4.4). If the project site is located in a candidate area for Naturally
Occurring Asbestos (NOA), the following requirements apply. Under the CARB Air Toxics Control
Measure (ATCM) for Construction, Grading, Quarrying, and Surface Mining Operations (93105), iLgr
to any construction activities at the site the eject roponent Shall eniUre that a geologic
evaluation - conducttd to determinedisturbed ifrom-the-negulation, An
exgmpt_ign request must be fled with the APCD If the site is not exempt from the requirements
of the regulation, the applicant must comply with all requirements outlined in the Asbestos ATCM.
This may include development of an Asbestos Dust Mitigation Plan and an Asbestos Health and
Safety Program for approval by the APCD. More information on NOA can be found at
slocleana9r.org/busines.s/asbestos.php-.
DernolitJQ„n/A5be5tQs
Demolition activities can have potential negative air quality impacts, including issues surrounding
proper handling, abatement, and disposal of asbestos containing material (ACM). Asbestos
containing materials could be encountered during the demolition or remodeling of existing
structures or the disturbance, demolition, or relocation of above or below ground utility
pipes/pipelines (e.g., transite pipes or insulation on pipes). if this project will include any of thepe
activities. thea it may be subjectn
to various regulatory iyrisdictios. including the
requirements stipulated in the National Emission Standard for Hazardous Air Pollutants
(NQCFR61—su part M - asbestos NESHAPI These requirements include, but are not limited to: 1)
written notification, within at least 10 business days of activities commencing, to the APCD, 2) an
asbestos survey conducted by a Certified Asbestos Consultant, and, 3) applicable removal and
disposal requirements of identified ACM. Please contact the APCD Engineering & Compliance
Division at (805) 781-5912 or go to slocleanair,org es-regulations/aestos.php for further
information. To obtain a Notification of Demolition and Renovation form go to the "Other Forms”
section of slgclaanoir.org/libracy-/download-forms.php.
Develgp.mental Burning
Effective February 25, 2000, the APCD prohibited developmental burning of vegetative material
within San_Luis Obispo County. If you have any questions regarding these requirements, contact
the APCD Engineering & Compliance Division at (805) 781-5912.
Dust Control
Please note that since water use is a concern due to drQmgh# conditions the contractor ar
builder shall ,consider the use of an APCs -approved dust suppressant where feasible t -o
reduce the amount of water used for dust control. For a list of suppressants, see Section 4.3 of
the CEQA Air Quality Handbook;
Construction Permit Requirements
Based on the information provided, we are unsure of the types of equipment that may be present
during the project's construction phase. Portable equipment, 50 horsepower (hp) or greater, used
during construction activities may require California statewide portable equipment registration
(issued by the California Air Resources Board) or an APCD permit.
Initial Study / Mitigated Negative Declaration for Imel Ranch Subdivision
January 17, 2017
Page 3of5
The following list is provided as a guide to equipment and operations that may have permitting
requirements, but should not be viewed as exclusive. For a more detailed listing, refer to the
Technical Appendices, page 4-4, in the APCD's 2012 CEQA Handbook.
• Power screens, conveyors, diesel engines, and/or crushers;
• Portable generators and equipment with engines that are 50 hp or greater;
• Electrical generation plants or the use of standby generator;
• Internal combustion engines;
• Rock and pavement crushing;
• Unconfined abrasive blasting operations;
• Tub grinders;
• Trommel screens; and,
• Portable plants (e.g. aggregate plant, asphalt batch plant, concrete batch plant, etc).
ini I delays. priorhplease
En ineering fi Commence Division at (805) 7$1-5972 for snerific information regarding
permitting requirement .
Construction Phage Idling Limitations
This project is in close proximity to nearby sensitive receptors. Projects that will have diesel
powered construction activity in close proximity to any sensitive receptor shall implement the
following mitigation measures to ensure that public health benefits are realized by reducing toxic
risk from diesel emissions:
To lsensitiver emissions impact gf diesel -vehicles and equipment Usgd tp
cots -trust the protect, the al2plicant shall implement the follovving idling control techniques:
-Ulifnrnia_Diesel Idling Regulations
a. On -road diesel vehicles shall comply with Section 2485 of Title 13 of the California Code
of Regulations. This regulation limits idling from diesel -fueled commercial motor vehicles
with gross vehicular weight ratings of more than 10,000 pounds and licensed for
operation on highways. It applies to California and non -California based vehicles. In
general, the regulation specifies that drivers of said vehicles:
1. Shall not idle the vehicle's primary diesel engine for greater than 5 -minutes at any
location, except as noted in Subsection (d) of the regulation; and,
2. Shall not operate a diesel -fueled auxiliary power system (APS) to power a heater, air
conditioner, or any ancillary equipment on that vehicle during sleeping or resting in a
sleeper berth for greater than 5.0 minutes at any location when within 1,000 feet of a
restricted area, except as noted in Subsection (d) of the regulation.
Off-road diesel equipment shall comply with the 5 -minute idling restriction identified in
Section 2449(d)(2) of the California Air Resources Board's In -Use Off -Road Diesel
regulation.
c. Signs must be posted in the designated queuing areas and job sites to remind drivers
and operators of the state's 5 -minute idling limit.
Initial Study / Mitigated Negative Declaration for Imel Ranch Subdivision
January 17, 2017
Page 4 of 5
d. The specific requirements and exceptions in the regulations can be reviewed at the
following web sites: www.arb.ca.goy/mstiroe/tru_ck-id-ling/facLaLe", f and
e ov/r 2 7/ i 17 r
AND/OR
2. Di 1 Idling i n r Sensitive R rs (List-s-ensitive rece.prou h r based Qn
.rgIi fi Is. residential dwelfiM, pack -&r 'n and hospitals
-i(none, then ,eliia2inare'b"
In addition to the state required diesel idling requirements, the project applicant shall
comply with these more restrictive requirements to minimize impacts to nearby sensitive
receptors:
a. Staging and queuing areas shall not be located within 1,000 feet of sensitive
receptors;
b. Diesel idling within 1,000 feet of sensitive receptors shall not be permitted;
C. Use of alternative fueled equipment is recommended; and
d. Signs that specify the no idling areas must be posted and enforced at the site,
Truc gla ng
Proposed truck routes should be evaluated and selected to ensure routing patterns have the least
impact to residential dwellings and other sensitive receptors, such as schools, parks, day care
centers, nursing homes, and hospitals. If the project has significant truck trips where hauling/truck
trips are routine activity and operate in close proximity to sensitive receptors, toxic risk needs to be
evaluated.
Operational Phase Emi55
In addition, to the operational phase mitigation measures outline in the OASP FEIR Mitigation and
Monitoring Program, the APCD recommends the following measure be included.
Residential Wood Combustion
Under APCD Rule 504, pn1y AF_CQ_ip.ppr.cved w..o:od burning devices can be installed in new
dwelling units. These devices include:
• All EPA -Certified Phase II wood burning devices;
• Catalytic wood burning devices which emit less than or equal to 4.1 grams per hour of
particulate matter which are not EPA -Certified but have been verified by a nationally -
recognized testing lab;
• Non -catalytic wood burning devices which emit less than or equal to 7.5 grams per hour
of particulate matter which are not EPA -Certified but have been verified by a nationally -
recognized testing lab;
• Pellet -fueled woodheaters; and
• Dedicated gas-fired fireplaces.
If yo.0 have any auctions about approved wood burning devices .�leA�$_e�gntact this APED
EnWineerine and Compliance Division at (805) 781-5912.
Initial Study / Mitigated Negative Declaration for Imel Ranch Subdivision
January 17, 2017
Page 5of5
Again, thank you for the opportunity to comment on this proposal. If you have any questions or
comments, feel free to contact me at (805) 781-5912.
Sincerely,
Melissa Guise
Air Quality Specialist
MAG/ihs
cc: Todd Smith
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