HomeMy WebLinkAboutStaff Report 5.A 01/28/2019 Attachment 12ATTACHMENT 12
September 17, 2018
BAY AREA
Mr. John Brown
AIR QUUAL,ITY City Manager
City of Petaluma
MANAGEMENT 11 English Street
Petaluma, CA 94952
D I S T R I C T
SUBJECT: Comments Regarding Safeway Fuel Center Project
ALAMEDA COUNTY
John J. Bauters Dear Mr, Brown:
Pauline Russo Cutter
Scott Haggerty
Nate Miley Bay Area Air Quality Management District (Air District) staff offers the
CONTRA COSTA COUNTY following comments regarding the City of Petaluma's consideration of
John Gioia Agenda Item # 6B," Resolution Denying the Appeal and Upholding the
David Hudson Planning Commission's Approval of the Planning Site Plan and Architectural
(Chair) 9 pp 9
Karen Mltchoff Review for the Safeway Fuel Center Project" at the September 17, 2018,
Mark Ross
City Council meeting.
MARIN COUNTY
Katie Rice
(Vice Chair) Safeway has an existing Air District Authority to Construct (Application No.
NAPA COUNTY 405215) for two (2) 20,000 -gallon underground storage tanks, eight (8)
Brad Wagenknecht triple -product gasoline nozzles, Phase 1 CNI EVR, Phase II VST Balance
SAN FRANCISCO COUNTY with Veeder-Root Vapor Polisher and Veeder-Root ISD EVR, which is valid
Hillary Ronen until November 10, 2019, If Safeway's current project proposal differs from
Tyrone Jue this equipment descri ton the Air District will require that a permit
(SF Mayor's Appointee)i
description, q
SAN MATEOCOUNTY application to request authorization for change be submitted.
David Canepa
Carole Groom Air District staff reviewed the Health Risk Assessment (HRA) and two
Doug Kim related documents from consultants ESA's and Illingworth & Rodkin. The
SANTA CLARA COUNTY Air District has the following comments on the HRA for the stationary source
Margaret Abe-Koga
Cindy Chavez emissions (i.e., evaporative emissions from the transfer and storage of
Liz Kniss gasoline):
Rod G, Sinks
(Secretary)
SOLANO COUNTY General comments on the HRA:
Pete Sanchez
James Spering 1.. The Air District recommends the AERMOD dispersion model
SONOMA COUNTY analysis instead of ISCST3. Air District permit modeling analysis
Teresa Barrett
Teres
eze procedures have changed since the project was initially permitted by
the Air District. The current procedure uses AERMOD.
Jack P. Broadbent
EXECUTIVE OFFICER/APCO
Connect with the
Bay Area Air District:
1
12-1
375 BEALE STREET, SUITE 600 • SAN FRANCISCO CA • 94105 • 415.771.6000 • www. haaglnd.gov
John Brown
Page 2
September 17, 2018
2. Based on the Gas Station Modeling Emissions and Volume Source
Parameters table in the Safeway Fuel Center Health Risk
Assessment, revised on September 19, 2017, it appears that the
dispersion modeling was conducted with 8 volume sources, each with
a dimension of 13m x 13m x 4m. This is the dimension'of the entire
gas station. If so, the Air District recommends the model be run with
only 2 volume sources (one representing refueling and one
representing spillage) to represent the entire GDF according to the
CAPCOA Air Toxics "Hot' Spots" Program, Gasoline Service Station
Industrywide Risk Assessment Guidelines, November 1997.
Alternatively, the modeling can be done with 16 volume sources (two
volume sources at each dispenser) — 8 refueling and 8 spillage
volume sources with the dimension of 5m x 5m x 4m. This is the
dimension of one dispenser.
ESA's Memo dated Maxi 7, 2018, "Peer Review of the HRA Impact Analysis":
The Air District concurs with ESA's comment #2 that the HRA was
based on a predicted throughput and not the BAAQMD-permitted
throughput limit. If the proposed Safeway gas station is not limited by
the City's permit to the predicted throughput, then the HRA should be
run at the maximum permitted throughput limit.
2. The Air District concurs with ESA's comment #5 regarding the teacher
exposure being omitted and underestimated. Off-site
workers/teachers' maximum health impact should be addressed and
included in the assessment. For permitting, the Air District includes
off-site workers (i.e., teachers) in its HRAs.
3. The Air District's current HRA Guidance for gas station health risk
assessments is specified in the BAAQMD Air Toxics NSR Program
Health Risk Assessment (HRA) Guidelines (December 2016), Section
2.2 for gasoline dispensing facilities, which specifies using 2003
OEHHA risk assessment guidance with 2015 health effects values,
and age sensitivity factors. Using the full 2015 OEHHA health risk
assessment procedures (specified in Section 2.1 of the Air District's
2016 HRA Guidelines would likely be more conservative and would
also be acceptable for CEQA purposes.
12-2
John Brown
Page 3
September 17, 2018
Illingworth & RQdkin's Memo dated May 8. 2018, "Response to ESA
Comments":
The Air District concurs with the city consultant's responses to ESA
comments regarding the receptor height for children (comment #4)
and pollutant of concern (comment #7). However, these changes are
not expected to have a significant impact on the final HRA results.
Air District staff is available to assist the City in addressing these comments.
If you have any questions, please do not hesidtate to contact me at
(415) 749-5041.
Thank you for your consideration of our request.
Sincerely,
Damian Breen
Deputy Air Pollution Control Officer
cc: Director Teresa Barrett
Director Shirlee Zane
12-3