SLO APCD Planning Department Standard Language File
COMMENT TYPE
Construction
Asbestos and Demolition Activities
CAMP
Con_Equipment_BACT
Con Permit Requirements
Con Phase Idling Limitations
Con Phase Mitigation Measures
Developmental Burning
Dust Control Long
Dust Control Short
Hydrocarbon Contaminated Soil
Lead Demolition
Naturally_Occuring_Asbestos
South County Particulate Matter
Support for alternative transportation project component
Trucking Routing
..Operational
Ag Burning
Diesel PM
Equestrian_Facility
Gas_Stations
Health_Risk_Assessment_TypeA
Health_Risk_Assessment_TypeB
Mixed Use Incompatibility
New_School_Site
Nuisance
Op_Permit_Requirements
Op_Phase_Impacts_Below
Op_Phase_Impacts_Exceeds
Op Phase Truck Idling
Residential Wood Combustion
SLO Car Free Program
Unpaved Roads Driveways Parking Areas
UST Removal Degassing
Demolition Activities
Demolition / Asbestos
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 buildings 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 these activities, then it may be subject to various
regulatory jurisdictions, including the requirements stipulated in the National Emission
Standard for Hazardous Air Pollutants (40CFR61, Subpart M - asbestos NESHAP). These
requirements include, but are not limited to: 1) written notification, within at least 10 business days of
activities commencing, to the APCD, 2) asbestos survey conducted by a Certified Asbestos Consultant,
and, 3) applicable removal and disposal requirements of identified ACM. Please contact the APCD
Enforcement Division at (805) 781-5912 for further information.
Construction Activity Management Plan
If the estimated construction emissions from the actual fleet are expected to exceed either of the APCD
Quarterly Tier 2 thresholds of significance (ROG+NOx and/or PM) after the standard and BACT measures
are factored into the estimation, then an APCD approved CAMP (See the APCD’s 2012 CEQA Handbooks
Technical Appendix 4.5 for CAMP Guidelines) and off-site mitigation need to be implemented in order to
reduce potential air quality impacts to a level of significance. The CAMP should be submitted to the
APCD for review and approval prior to the start of construction and should include, but not
be limited to, the following elements:
 A Dust Control Management Plan that encompasses all, but is not limited to, dust control
measures that were listed above in the “dust control measures” section;
 Tabulation of on and off-road construction equipment (age, horse-power and miles and/or
hours of operation);
 Schedule construction truck trips during non-peak hours to reduce peak hour emissions;
 Limit the length of the construction work-day period, if necessary; and,
 Phase construction activities, if appropriate.
Best Available Control Technology (BACT) for Construction Equipment
If the estimated construction phase ozone precursor emissions from the actual fleet for a given Phase are
expected to exceed the APCD’s threshold of significances after the standard mitigation measures are
factored into the estimation, then BACT needs to be implemented to further reduce these
impacts. The BACT measures can include:
1. Further reducing emissions by expanding use of Tier 3 and Tier 4 off-road and 2010 on-road
compliant engines;
2. Repowering equipment with the cleanest engines available; and
Installing California Verified Diesel Emission Control Strategies. These strategies are listed at:
http://www.arb.ca.gov/diesel/verdev/vt/cvt.htm
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.
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).
To minimize potential delays, prior to the start of the project, please contact the APCD
Engineering Division at (805) 781-5912 for specific information regarding permitting
requirements.
Construction Phase Idling Limitations
This project is in close proximity to nearby sensitive receptors (XXXXXXXXXXXXXXXXXXXXX). Projects
that will have diesel powered construction activity in close proximity to any sensitive receptor shall
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implement the following mitigation measures to ensure that public health benefits are realized by
reducing toxic risk from diesel emissions:
To help reduce sensitive receptor emissions impact of diesel vehicles and equipment used to
construct the project, the applicant shall implement the following idling control techniques:
1.
California 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.
b. 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.
d. The specific requirements and exceptions in the regulations can be reviewed at the following
web sites: www.arb.ca.gov/msprog/truck-idling/2485.pdf and
www.arb.ca.gov/regact/2007/ordiesl07/frooal.pdf.
AND/OR
2.
Diesel Idling Restrictions Near Sensitive Receptors (List sensitive receptors here based on the
following list: schools, residential dwellings, parks, day care centers, nursing homes, and
hospitals – if none, then eliminate “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.
Standard Mitigation Measures for Construction Equipment
The standard construction equipment mitigation measures for reducing nitrogen oxide (NO x), reactive
organic gases (ROG), and diesel particulate matter (DPM) emissions are listed below and in section 2.3.1
of the APCD’s 2012 CEQA Handbook. These measures are applicable to all projects where
construction phase emissions exceed APCD thresholds:
 Maintain all construction equipment in proper tune according to manufacturer’s specifications;
 Fuel all off-road and portable diesel powered equipment with ARB certified motor vehicle diesel
fuel (non-taxed version suitable for use off-road);
 Use diesel construction equipment meeting ARB's Tier 2 certified engines or cleaner off-road
heavy-duty diesel engines, and comply with the State off-Road Regulation;
 Use on-road heavy-duty trucks that meet the ARB’s 2007 or cleaner certification standard for onroad heavy-duty diesel engines, and comply with the State On-Road Regulation;
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Construction or trucking companies with fleets that that do not have engines in their fleet that
meet the engine standards identified in the above two measures (e.g. captive or NO x exempt
area fleets) may be eligible by proving alternative compliance;
All on and off-road diesel equipment shall not idle for more than 5 minutes. Signs shall be
posted in the designated queuing areas and or job sites to remind drivers and operators of the 5
minute idling limit;
Diesel idling within 1,000 feet of sensitive receptors is not permitted;
Staging and queuing areas shall not be located within 1,000 feet of sensitive receptors;
Electrify equipment when feasible;
Substitute gasoline-powered in place of diesel-powered equipment, where feasible; and,
Use alternatively fueled construction equipment on-site where feasible, such as compressed
natural gas (CNG), liquefied natural gas (LNG), propane or biodiesel.
Developmental 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 Enforcement Division at 781-5912.
Dust Control Measures
Construction activities can generate fugitive dust, which could be a nuisance to local residents and
businesses in close proximity to the proposed construction site. Projects with grading areas that are
greater than 4-acres or are within 1,000 feet of any sensitive receptor shall implement the
following mitigation measures to manage fugitive dust emissions such that they do not
exceed the APCD’s 20% opacity limit (APCD Rule 401) or prompt nuisance violations (APCD
Rule 402):
a. Reduce the amount of the disturbed area where possible;
b. Use of water trucks or sprinkler systems in sufficient quantities to prevent airborne dust from
leaving the site and from exceeding the APCD’s limit of 20% opacity for greater than 3 minutes in
any 60 minute period. Increased watering frequency would be required whenever wind speeds
exceed 15 mph. Reclaimed (non-potable) water should be used whenever possible;
c. All dirt stock pile areas should be sprayed daily and covered with tarps or other dust barriers as
needed;
d. Permanent dust control measures identified in the approved project revegetation and landscape
plans should be implemented as soon as possible, following completion of any soil disturbing
activities;
e. Exposed ground areas that are planned to be reworked at dates greater than one month after
initial grading should be sown with a fast germinating, non-invasive, grass seed and watered until
vegetation is established;
f. All disturbed soil areas not subject to revegetation should be stabilized using approved chemical
soil binders, jute netting, or other methods approved in advance by the APCD;
g. All roadways, driveways, sidewalks, etc. to be paved should be completed as soon as possible.
In addition, building pads should be laid as soon as possible after grading unless seeding or soil
binders are used;
h. Vehicle speed for all construction vehicles shall not exceed 15 mph on any unpaved surface at
the construction site;
i. All trucks hauling dirt, sand, soil, or other loose materials are to be covered or should maintain at
least two feet of freeboard (minimum vertical distance between top of load and top of trailer) in
accordance with CVC Section 23114;
j. Install wheel washers where vehicles enter and exit unpaved roads onto streets, or wash off
trucks and equipment leaving the site;
k. Sweep streets at the end of each day if visible soil material is carried onto adjacent paved roads.
Water sweepers shall be used with reclaimed water should be used where feasible. Roads shall
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be pre-wetted prior to sweeping when feasible;
l. All PM10 mitigation measures required should be shown on grading and building plans; and,
m. The contractor or builder shall designate a person or persons to monitor the fugitive dust
emissions and enhance the implementation of the measures as necessary to minimize dust
complaints, reduce visible emissions below the APCD’s limit of 20% opacity for greater than 3
minutes in any 60 minute period. Their duties shall include holidays and weekend periods when
work may not be in progress. The name and telephone number of such persons shall be
provided to the APCD Compliance Division prior to the start of any grading, earthwork or
demolition.
Dust Control Measures
The project, as described in the referral, will not likely exceed the APCD’s CEQA significance threshold for
construction phase emissions. However, construction activities can generate fugitive dust, which could
be a nuisance to local residents and businesses in close proximity to the proposed construction site.
APCD staff recommends the following measures be incorporated into the project to control
dust:
Projects with grading areas that are less than 4-acres and that are not within 1,000 feet of any sensitive
receptor shall implement the following mitigation measures to significantly reduce fugitive dust emissions,
to manage fugitive dust emissions such that they do not exceed the APCD 20% opacity limit (APCD Rule
401) and minimize nuisance impacts:
a. Reduce the amount of the disturbed area where possible;
b. Use water trucks, APCD approved dust suppressants (see Section 4.3 in the CEQA Air Quality
Handbook), or sprinkler systems in sufficient quantities to prevent airborne dust from leaving the
site and from exceeding the District’s limit of 20% opacity for greater than 3 minutes in any 60
minute period. Increased watering frequency would be required whenever wind speeds exceed
15 mph. Reclaimed (non-potable) water should be used whenever possible;
c. All dirt stock-pile areas should be sprayed daily and covered with tarps or other dust barriers as
needed;
d. All roadways, driveways, sidewalks, etc. to be paved should be completed as soon as possible,
and building pads should be laid as soon as possible after grading unless seeding, soil binders or
other dust controls are used;
e. All of these fugitive dust mitigation measures shall be shown on grading and building plans; and,
f. The contractor or builder shall designate a person or persons to monitor the fugitive dust
emissions and enhance the implementation of the measures as necessary to minimize dust
complaints, reduce visible emissions below 20% opacity. Their duties shall include holidays and
weekend periods when work may not be in progress.
Hydrocarbon Contaminated Soil
Should hydrocarbon contaminated soil be encountered during construction activities, the
APCD must be notified as soon as possible and no later than 48 hours after affected material
is discovered to determine if an APCD Permit will be required. In addition, the following
measures shall be implemented immediately after contaminated soil is discovered:
 Covers on storage piles shall be maintained in place at all times in areas not actively involved in
soil addition or removal;
 Contaminated soil shall be covered with at least six inches of packed uncontaminated soil or
other TPH –non-permeable barrier such as plastic tarp. No headspace shall be allowed where
vapors could accumulate;
 Covered piles shall be designed in such a way to eliminate erosion due to wind or water. No
openings in the covers are permitted;
 The air quality impacts from the excavation and haul trips associated with removing the
contaminated soil must be evaluated and mitigated if total emissions exceed the APCD’s
construction phase thresholds;
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During soil excavation, odors shall not be evident to such a degree as to cause a public nuisance;
and,
Clean soil must be segregated from contaminated soil.
The notification and permitting determination requirements shall be directed to the APCD
Engineering Division at 781-5912.
CASE #2: We know project is going to have hydrocarbon contaminated soil
APCD Permitting of Hydrocarbon Contaminated Soil Processes
This (project type) project shall require an APCD permit to address proper management of
the hydrocarbon contaminated soil prior to the start of any earthwork. This permit shall
include conditions to minimize emissions from any excavation, disposal or related process.
To the extent feasible, (Company Name) shall contact the APCD Engineering Division at 7815912 within 120 days before the start of excavation to begin the permitting process. In
addition, the air quality impacts from the excavation and haul trips associated with
removing the contaminated soil must be evaluated and mitigated if total emissions exceed
the APCD’s construction phase thresholds.
Lead During Demolition
Demolition of structures coated with lead based paint is a concern for the APCD. Improper demolition
can result in the release of lead containing particles from the site. Sandblasting or removal of paint by
heating with a heat gun can result in significant emissions of lead. Therefore, proper abatement of lead
before demolition of these structures must be performed in order to prevent the release of lead from the
site. Depending on removal method, an APCD permit may be required. Contact the APCD
Engineering Division at (805) 781-5912 for more information. Approval of a lead work plan
by the APCD is required and must be submitted ten days prior to the start of the demolition.
For more information, contact the APCD Enforcement Division at (805) 781-5912 or for
specific information regarding lead removal, please contact Cal-OSHA at (818) 901-5403.
Additional information can also be found on line at http://www.epa.gov/lead.
Naturally Occurring Asbestos
Naturally occurring asbestos (NOA) has been identified by the state Air Resources Board as a toxic air
contaminant. Serpentine and ultramafic rocks are very common 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 ARB Air Toxics Control Measure (ATCM) for Construction, Grading, Quarrying, and Surface
Mining Operations (93105), prior to any construction activities at the site, the project proponent
shall ensure that a geologic evaluation is conducted to determine if the area disturbed is
exempt from the regulation. An exemption request must be filed 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 http://www.slocleanair.org/business/asbestos.php.
South County Particulate Matter
Environmental Setting
The project is located in an area that is impacted by periods of high particulate matter concentrations.
The APCD has been investigating the source of the high particulate matter concentrations on the Nipomo
Mesa for the past decade. Several studies performed by the APCD in the Nipomo Mesa area have shown
the source of the elevated particulate matter (PM) pollution to be windblown dust from the open sand
areas of the Oceano Dunes State Vehicular Recreation Area (SVRA). The studies provided a
comprehensive picture of the characteristics of a typical dust event.
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To keep the public informed of periods of deteriorating air quality, the APCD provides a daily air quality
forecast for SLO County. SLO County is partitioned into nine air quality forecast zones, and an air quality
forecast for a six-day period is provided for each zone. In the Nipomo Mesa area, there are four forecast
zones as shown in the map below, and are named CDF, MESA2, NRP and SLO:
https://maps.google.com/maps?q=docs:%2F%2F0B16hLxE59xFQdHpWeWFXTS1mRjg&hl=enUS&ll=35.006851,-120.470667&spn=0.317766,0.587769&t=m&gl=US&mapclient=embed&z=11
The darker colors (purple/pink) in the map signify the location of the greatest dust impacts during a
typical blowing dust event. The public can experience adverse health impacts in areas with blowing dust.
The blue color represents the SLO forecast area, which is in most cases is not impacted by the dust
plume.
Children and individuals with compromised cardiac and respiratory systems or related health problems
are called sensitive receptors. Sensitive receptors can experience greater health impacts than the
general population during blowing dust events. Sensitive receptor locations include schools, residential
dwellings, parks, day care centers, nursing homes, and hospitals.
The blowing dust events are typically most frequent in the spring; however, dust events can occur at any
time of the year. The greatest impacts occur when the strong winds blow from the northwest which
directs the dust plume inland over the Nipomo Mesa (as shown in the map above) where it can impact
residents. A typical event tends to start around noon and end by the early evening, with peak impacts
between 1 pm to 5 pm. The strongest events can result in blowing dust from 9 am to 7 pm, with peak
impacts between noon and 6 pm. Being aware of typical dust plume characteristics, residents can plan to
avoid peak dust impacts. Particulate concentrations typically return to background levels from the late
evening to the morning, so these times are best (health wise) for outdoor activities and exercise.
On November 16, 2011, the APCD Board approved the Coastal Dunes Dust Control Rule 1001 to require
implementation of dust control measures on coastal dunes where vehicle activity occurs, to mitigate the
impacts of the blowing dust. Mitigation efforts are currently underway.
Proposed Project
---Project Name------ is located in the ----CDF(use appropriate zone name)---- zone, which typically
receives the highest particulate matter concentrations during blowing dust events. To minimize the
public health impact …….
Support for alternative transportation project component
APCD staff commends the City of Arroyo Grande Community Development Department
for the promotion of bicycle and pedestrian transportation. When people can walk or bicycle to nearby
stores, parks and work, traffic is reduced and the potential for mass transit use increases which is
consistent with several of the APCD's land use goals and policies in the Clean Air Plan. In addition,
promotion of bicycle and pedestrian transportation helps meet the greenhouse gas emission targets set
by California legislation.
The APCD supports the City of Arroyo Grande Bicycle & Trails Master Plan and its efforts to implement
measures to support California Senate Bill 375 and Assembly Bill 32, California Global Warming Solutions
Act (2006). California Assembly Bill 32 requires statewide Green House Gas emissions to be reduced to
1990 levels by year 2020.
Truck Routing
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
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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.
Agricultural Burning
Agricultural operations must obtain an APCD Agricultural Burn Permit to burn agricultural
vegetation on Permissive Burn Days. The ARB provides educational handbooks on
agricultural burning (English and Spanish) to growers which are available at the following
websites: www.arb.ca.gov/smp/progdev/pubeduc/agburnhandbook.pdf
Diesel Particulate Matter
Diesel particulate matter (DPM) is a toxic air contaminant and carcinogen, and exposure to DPM may lead
to increased cancer risk and respiratory problems. Certain industrial and commercial projects may emit
substantial quantities of DPM through the use of stationary and mobile on-site diesel-powered equipment,
as well as diesel trucks and other vehicles that serve the project. At a minimum, fleets must meet the
diesel emission reduction requirements that have been adopted in the State’s Diesel Risk Reduction Plan.
Projects that emit more than the APCD’s DPM significance threshold need to implement on-site Best
Available Control Technology measures to reduce the project impacts below the threshold. If sensitive
receptors are within 1,000 feet of the project site, a Health Risk Assessment (HRA) may also be required.
Sections 3.6.1 and 3.7.4 of the APCD’s 2012 CEQA Handbook provide more background on HRAs in
conjunction with CEQA review. Guidance on the preparation of a HRA may be found in the CAPCOA
report HEALTH RISK ASSESSMENT FOR PROPOSED LAND USE PROJECTS , which can be downloaded
from the CAPCOA website at www.capcoa.org.
Equestrian Facility
Another potential source of fugitive dust can come from equestrian facilities, which may be a nuisance to
local residents. To minimize nuisance impacts and to reduce fugitive dust emissions from equestrian
facilities the following mitigation measures should be incorporated into the project:
 Reduce the amount of the disturbed area where possible;
 Use water trucks or sprinkler systems in sufficient quantities to prevent airborne dust emissions
from exceeding the APCD 20% opacity limit for greater than 3 minutes in any 60 minute period
(APCD Rule 401) or prompt nuisance violations (APCD Rule 402). Increased watering frequency
whenever wind speeds exceed 15 mph. Reclaimed (non-potable) water shall be used whenever
possible;
 Permanent dust control measures shall be implemented as soon as possible following completion
of any soil disturbing activities;
 All disturbed soil areas not subject to revegetation shall be stabilized using approved chemical
soil binders, jute netting, or other methods approved in advance by the Air District;
 All access roads and parking areas associated with the facility shall be paved to reduce fugitive
dust; and,
 A person or persons shall be designated to monitor for dust and implement additional control
measures as necessary to prevent transport of dust offsite. The monitor's duties shall include
holidays and weekend. The name and telephone number of such persons shall be provided to
the Air District prior to operation of the arena.
Gas Stations
Authority to Construct – Inside the City of San Luis Obispo
A new or modified gasoline dispensing facility (GDF) with a capacity of 1,500 gallons or more will require
an APCD permit. Prior to approval by your agency, the applicant must apply for an Authority to Construct
from the APCD. In addition, gas stations and other facilities which emit toxic or hazardous air pollutants
have the potential to cause increased cancer risk for those who live or work in the surrounding area. The
significance of this potential health risk depends upon several factors, including the annual gasoline
throughput of the GDF and the location of the receptors. Using this information, the APCD will run a
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health-based screening level risk assessment for the facility, following the California Air Pollution Control
Officer's Association (CAPCOA) guidelines. Depending on the APCD's screening risk determination,
applicants may be subject to throughput limitations or may be required to submit a more refined Health
Risk Assessment. Please have the applicant contact our Engineering Division, at 781-5912 to discuss
these issues further. Consideration of potential health risk with respect to equipment location is
recommended before the facility design is finalized.
State law requires that the APCD notify affected parties prior to issuing a permit for any new or modified
source of hazardous air contaminants within 1,000 feet of a school (H&SC Section 42301.6).
Authority to Construct - Outside of the City of San Luis Obispo
A new or modified gasoline dispensing facility (GDF) with a capacity of 1,500 gallons or more will require
an APCD permit. Prior to approval by your agency, the applicant must apply for a Combined Authority to
Construct from the APCD and the San Luis Obispo County Environmental Health Service (EHS). Contact
EHS at 781-5544 for a combined application form. A Combined Authority to Construct, issued by EHS,
must be obtained by the applicant prior to the start of construction.
In addition, gas stations and other facilities which emit toxic or hazardous air pollutants have the
potential to cause increased cancer risk for those who live or work in the surrounding area. The
significance of this potential health risk depends upon several factors, including the annual gasoline
throughput of the GDF and the location of the receptors. Using this information, the APCD will run a
health-based screening level risk assessment for the facility, following the California Air Pollution Control
Officer's Association (CAPCOA) guidelines. Depending on the APCD's screening risk determination,
applicants may be subject to throughput limitations or may be required to submit a more refined Health
Risk Assessment. Please have the applicant contact our Engineering Division, at 781-5912 to discuss
these issues further. Consideration of potential health risks with respect to equipment location is
recommended before the facility design is finalized.
State law requires that the APCD notify affected parties prior to issuing a permit for any new or modified
source of hazardous air contaminants within 1,000 feet of a school (H&SC Section 42301.6).
Health Risk Assessment –Type A - New Toxic Source that Impacts Sensitive Receptors
This project has the potential to emit toxic or hazardous air pollutants and is located in close proximity to
sensitive receptors. Sensitive receptor locations include schools, residential dwellings, parks, day care
centers, nursing homes, and hospitals. Health impacts may be significant due to increased cancer risk for
the affected population, even at a very low level of emissions. Such projects are required to prepare a
health risk assessment to determine the potential level of risk associated with their operations.
In July 2009, the California Air Pollution Control officers Associations (CAPCOA) adopted a guidance
document, “HEALTH RISK ASSESSMENTS FOR PROPOSED LAND USE PROJECTS,” to provide uniform
direction on how to assess the health risk impacts from and to proposed land use projects. The CAPCOA
guidance document focuses on how to identify and quantify the potential acute, chronic, and cancer
impacts of sources under CEQA review. As defined in the CAPCOA guidance document there are basically
two types of land use projects that have the potential to cause long-term public health risk impacts and
are named Type A and Type B.
This project is considered a Type A project, a new proposed land use project that generate toxic air
contaminants (such as loading docks, gasoline stations, distribution facilities or asphalt batch plants) that
impact sensitive receptors. Air districts across California are uniform in their recommendation to use the
significance thresholds that have been established under each district’s “Hot Spots” and permitting
programs. The APCD has defined the excess cancer risk significance threshold at 10 in a million for
Type A projects in San Luis Obispo County.
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Prior to completion of the project’s environmental assessment, the APCD recommends that
the project proponent perform a screening level health risk assessment to determine the
potential health risks to residents of the development. If the screening assessment is above
10 in a million, a more comprehensive health risk analysis shall be required. Results of the
screening and/or the refined health risk assessment need to be provided to the APCD for
review and approval.
Health Risk Assessment –Type B - New Project that places Sensitive Receptors Near Toxic Source
This project has the potential to place sensitive receptors in close proximity to toxic or hazardous air
pollutants. Sensitive receptor locations include schools, residential dwellings, parks, day care centers,
nursing homes, and hospitals. Health impacts may be significant due to increased cancer risk for the
affected population, even at a very low level of emissions. Such projects may be required to prepare a
health risk assessment to determine the potential level of risk associated with their operations.
In July 2009, the California Air Pollution Control Officers Associations (CAPCOA) adopted a guidance
document, “Health Risk Assessments For Proposed Land Use Projects ,” to provide uniform
direction on how to assess the health risk impacts from and to proposed land use projects. The CAPCOA
guidance document focuses on how to identify and quantify the potential acute, chronic, and cancer
impacts of sources under CEQA review. As defined in the CAPCOA guidance document there are basically
two types of land use projects that have the potential to cause long-term public health risk impacts and
are named Type A and Type B.
This project is considered a Type B project, new land use projects that will place sensitive receptors in
close proximity to existing toxics sources. The APCD has established a CEQA health risk threshold of 89
in-a-million for the analysis of projects proposed in close proximity to toxic sources. This value
represents the population weighted average health risk caused by ambient background concentrations of
toxic air contaminants in San Luis Obispo County.
In April 2005, the California Air Resources Board (ARB) issued a guidance document titled Air Quality
and Land Use Handbook (ARB Handbook). In this document, the development of sensitive land uses,
such as homes, in close proximity to rail yards, gasoline dispensing facilities and dry cleaners etc. was
highlighted as a health concern due to the increased exposure to air pollution and diesel exhaust. ARB
studies show that air pollution levels can be significantly higher in close proximity to these sources and
the ARB recommends that agencies avoid siting sensitive land uses within 500 feet of a highway, within
1,000 feet of a rail yard, within 300 feet of a large gas station (3.6 million gallons per year) or within 500
feet of a dry cleaning operation.
Since this proposed facility is located close to sources of air toxics, a screening level health
risk assessment will need to be performed prior to project approval to determine potential
health risks to residents of the development. If the screening assessment is above 89 in a
million, a more comprehensive health risk analysis shall be required. Results of the
screening and/or the refined health risk assessment needs to be provided to the APCD for
review and approval.
Mixed Use Incompatibility
As individual projects move forward, it is important to keep in mind that some uses may not be
compatible and could result in potential nuisance problems (i.e. odors and/or dust). Therefore, it is
essential that individual uses be carefully evaluated prior to issuance of a use permit. The following uses
could be problematic if residential quarters are included in the same building.
 Nail Salons
 Dry-cleaners
 Coffee Roasters
 Gasoline Stations
Revised August 2015
 Furniture refurbishing/refinishing
 Any type of Spray Paint Operation
To minimize potential delays, prior to the start of the project, please contact the APCD
Engineering Division at (805) 781-5912 for specific information regarding permitting
requirements.
New School Site
The Public Resources Code Sec. 21151.8 requires any agency preparing an Environmental Impact Report
or negative declaration for a proposed school site to consult with the city, county, and the APCD to
identify both permitted and non-permitted facilities within one-quarter mile of the proposed school site
which may emit hazardous air emissions or handle hazardous materials (e.g., pipelines). Impacts from
such a facility may be significant due to increased cancer risk for the affected population, even at a very
low level of emissions. If a potentially hazardous facility is within one-quarter mile of the new
school site, the APCD may require that a risk assessment to determine the potential level of
risk associated with that school location. Information on permitted facilities is available by
contacting the APCD Engineering Division at 805-781-5912.
Nuisance
(Add your specific circumstance )As defined in APCD’s Rule 402, a person shall not discharge, from any
source whatsoever, such quantities of air contaminant or other material which cause injury, detriment,
nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the
comfort, repose, health or safely of any such persons or public, or which cause or have a natural
tendency to cause, injury or damage to business or property. If this project causes nuisance
impacts, the project proponent needs to proactively take steps to reduce these impacts.
Operational Permit Requirements
Based on the information provided, we are unsure of the types of equipment that may be present at the
site. Operational sources may require APCD permits. 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 Appendix, page 4-4, in the APCD's 2012
CEQA Handbook.
 New wineries or expanding wineries with the capacity of 26,000 gallons (10,000 cases at
twelve 750 milliliter bottles per case) year or more require a Permit to Operate for
fermentation and storage of wine;
 Portable generators and equipment with engines that are 50 hp or greater;
 Chemical product processing and or manufacturing;
 Electrical generation plants or the use of standby generator;
 Food and beverage preparation (primarily coffee roasters);
 Furniture and fixture products;
 Metal industries, fabrication;
 Small scale manufacturing;
 Auto and vehicle repair and painting facilities;
 Fuel dealers;
 Dry cleaning;
 Pipelines;
 Public utility facilities;
 Boilers;
 Internal combustion engines;
 Sterilization units(s) using ethylene oxide and incinerator(s);
 Cogeneration facilities;
 Unconfined abrasive blasting operations;
 Concrete batch plants;
 Rock and pavement crushing;
Revised August 2015
 Tub grinders; and
 Trommel screens.
Most facilities applying for an Authority to Construct or Permit to Operate with stationary diesel engines
greater than 50 hp, should be prioritized or screened for facility wide health risk impacts. A diesel engineonly facility limited to 20 non-emergency operating hours per year or that has demonstrated to have
overall diesel particulate emissions less than or equal to 2 lb/yr does not need to do additional health risk
assessment. To minimize potential delays, prior to the start of the project, please contact the
APCD Engineering Division at (805) 781-5912 for specific information regarding permitting
requirements.
Nuisance Odors from Wineries
Wine production facilities can generate nuisance odors during various steps of the process. Proven
methods for handling wastewater discharge and grape skin waste need to be incorporated
into the winery practices to reduce off-site odor. Odor complaints could result in a violation of the
SLO County APCD Rule 402 Nuisance.
OPERATIONAL PHASE IMPACTS - Below Threshold
Based on the (APCD/project proponent/DEIR/mitigated negative declaration) operational phase emission
estimates using (the most recent CalEEMod computer model, a tool OR a spreadsheet model for
estimating operational emissions related to the development of land uses OR Table 1-1 in the APCD’s
2012 CEQA Handbook), the operational phase would likely be less than the APCD’s significance threshold
values identified in Table 3-2 of the CEQA Air Quality Handbook. Therefore, APCD is not requiring
any operational phase mitigation measures for this project.
OR
Therefore, with the exception of the requirements below, the APCD is not requiring other
operational phase mitigation measures for this project.
OPERATIONAL PHASE IMPACTS - Exceeds Threshold
Based on the (APCD/project proponent/DEIR/mitigated negative declaration) operational phase emission
estimates using (the most recent CalEEMod computer model, a tool OR a spreadsheet model for
estimating operational emissions related to the development of land uses OR Table 1-1 in the APCD’s
2012 CEQA Handbook), the operational phase would likely exceed the APCD’s (daily/quarterly)
operational emission threshold(s) identified in Table 3-2 of the CEQA Air Quality Handbook. APCD
recommends the implementation of on-site mitigation measures to the greatest extent
possible. Potential APCD operational phase mitigation measures are listed in Chapter 3 of
the APCD CEQA Handbook.
Operational Phase Residential/Operational Mitigation
APCD staff has determined the operational impacts of this development by running the CalEEMod
computer model, a tool for estimating vehicle travel, fuel use and the resulting emissions related to this
project’s land uses. The results of the model using conservative County average trip distances
demonstrated that the operational impacts will likely exceed the APCD’s thresholds in Table 3-2 in the
CEQA Handbook.
As a result of this estimated threshold exceedance for ROG+NOx or PM10, this project must
implement Standard Mitigation Measures, which can be found in Table 3-5 in the APCD’s
2012 CEQA Handbook, to bring the project below the significance threshold. If DPM
significance threshold is exceeded, the project applicant must demonstrate the inclusion of
mitigation measures to bring the project below the threshold. Should this project move forward,
the APCD will consider the overall air quality impacts from this project to have been reduced to a level of
insignificance with the implementation of these mitigation measures. Other measures may be proposed
as replacements by contacting the APCD Planning Division at 781-5912.
Revised August 2015
Operational Phase Idling Limitations
Public health risk benefits can be realized by idle limitations for diesel engines. To help reduce the
emissions impact of diesel vehicles that will access the facility or off-road equipment used at
the facility, the applicant shall implement the following idling control techniques:
1.
California 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.
b. Off-road diesel equipment shall comply with the 5 minute idling restriction identified in
Section 2449(d)(3) 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.
d. The specific requirements and exceptions in the regulations can be reviewed at the following
web sites: www.arb.ca.gov/msprog/truck-idling/2485.pdf and
www.arb.ca.gov/regact/2007/ordiesl07/frooal.pdf.
AND/OR
2.
Diesel Idling Restrictions Near Sensitive Receptors (List sensitive receptors here based on the
following list: schools, residential dwellings, parks, day care centers, nursing homes, and
hospitals – if none, then eliminate “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 and electrification of loading docks (e.g., electrical plugins for truck refrigeration units and electrification of loading equipment) is recommended;
and
d. Signs that specify the no idling areas must be posted and enforced at the site.
AND/OR
3.
Diesel Bus Idling Restrictions
a. Buses pulling into the transit center need to be shut down immediately and would not be
started again until they are ready to depart;
b. Post no idling signs visible to the drivers; and
c. As feasible, vary bus schedules to reduce the number of buses at the transit center at any one
time.
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Residential Wood Combustion
Under APCD Rule 504, only APCD approved wood 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 nationallyrecognized 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 nationallyrecognized testing lab;
 Pellet-fueled woodheaters; and
 Dedicated gas-fired fireplaces.
If you have any questions about approved wood burning devices, please contact the APCD
Enforcement Division at 781-5912.
San Luis Obispo Car Free Program
Vehicle emissions are often the largest source of emissions from the operational phase of development.
This project has the potential to increase the amount of vehicle trips to our County and appropriate
mitigation measures must be considered. San Luis Obispo (SLO) Car Free is a program to encourage carfree transportation to and around San Luis Obispo County. SLO Car Free provides tools to travelers on
the pleasures and availability of traveling to our area without their cars, or by parking their cars once
they arrive. By pledging to travel to, or around SLO County without a car, visitors receive special
incentives from participating hotels, restaurants, transportation services and attractions. In addition,
businesses who join SLO Car Free as a participating business receive free advertisement on their website,
highlighting the businesses efforts to encourage “green,” tourism to San Luis Obispo County. Your
business is also promoted through several social media networks and at the numerous events that SLO
Car Free participates in each year.
The SLO Car Free website (SLOCarFree.org) is a hub for information and web-links on transportation,
lodging, attractions and other visitor needs. Visitors can use the website to find out what they can do in
SLO County and how they can do it without a car. To mitigate the potential vehicle trips to the
proposed (business/facility, etc) the business must sign up to participate in the SLO Car Free
Program, provide incentives to car-free travelers, and promote the program in their
communication tools. To get signed up for SLO Car Free, please contact Meghan Field in the
APCD Planning Division at 805-781-5912.
Unpaved Roads, Driveways, and Parking Areas (this applies for light-duty operational only, construction
module would be used to quantify heavy-duty trucks – or run the equation in a spreadsheet)
This project is accessed by an unpaved road (X miles) and or has unpaved driveways or parking areas. A
particulate matter (PM10) emission estimate needs to be conducted using the unpaved travel distance in
the CalEEMod model and the following values for model variables in order to yield the California Air
Resources Board’s unpaved road emission factor that is used in their statewide emissions inventory.
Under CalEEMod’s “Unpaved Road Dust” section:
- Use a value of 9.3 for “Material Silt Content (%)”
- Use a value of 0.1 for “Material Moisture Content (%)”
- Use a value of 32.4 for “Mean Vehicle Speed (mph)”
If the model’s emission estimate demonstrates an exceedance of the APCD’s PM 10 significance thresholds
of 25 lbs/day or 25 tons/year, then the following mitigation is required:
For these unpaved sections, implement one of the following:
a. For the life of the project, pave and maintain the roads, driveways, and/or parking areas; or,
Revised August 2015
b. For the life of the project, maintain the unpaved roads, driveways, and/or parking areas with a
dust suppressant (See Technical Appendix 4.3 of the APCD’s CEQA Handbook for a list of APCDapproved suppressants) such that fugitive dust emissions do not exceed the APCD 20% opacity
limit for greater than 3 minutes in any 60 minute period (APCD Rule 401) or prompt nuisance
violations (APCD Rule 402).
c. Also, to improve the dust suppressant’s long-term efficacy, the applicant shall also implement
and maintain design standards to ensure vehicles that use the on-site unpaved road are
physically limited (e.g., speed bumps) to a posted speed limit of 15 mph or less.
.
If the project’s access involves a city or county owned and maintained road, the applicant shall work with
the applicable Public Works Department to ensure that the mitigation follows the agency’s road standards
for that section of road. The applicant may propose other measures of equal effectiveness as
replacements by contacting the APCD’s Planning Division at 781-5912.
Underground Storage Tank (UST) Removal and Degassing
The Certified Unified Program Agency (CUPA) should be contacted prior to removal or degassing of
underground fuel storage tanks. The San Luis Obispo County Environmental Health Division of the Public
Health Department is the CUPA for most locations in San Luis Obispo County. You may contact
Environmental Health Services at (805) 781-5544 for more information.
Degassing and cleaning of USTs must be done under an APCD permit for tank degassing and cleaning
equipment. The removal of the liquid product, sludge, and vapor components from USTs must be
performed in a safe, controlled fashion in order to avoid nuisance odors and the uncontrolled release of
gaseous hydrocarbons. The bulk transfer of liquid gasoline must be performed using a vapor collection
and transfer system capable of returning the displaced vapors to the stationary storage container.
Vacuum trucks or pumps used to remove sludge and/or gasoline vapors must be vented to a District
permitted control system to prevent odors and hydrocarbon emissions. For more information concerning
permit requirements, please contact the Engineering Division at (805) 781-5912.
Revised August 2015