imf - granicus

IMF

DATE: October 15, 2018

TO: . Honorable Mayor and Members of the City Council through City Manager

FROM: Heather Hines, Planning Manager

SUBJECT: Continuance of the Safeway Appeal to a date certain of December 3, 2018

RECOMMENDATION

It is recommended that the City Council continue the Safeway Appeal to a date certain ofDecember 3, 2018.

BACKGROUND

The Safeway Fuel Center project proposes a new gas station on the 0. 71 -acre parcel located at335 South McDowell Drive in the Washington Square Shopping Center. The site is currentlydeveloped with a 13, 077 square foot commercial building which would be fully demolished tofacilitate the new development. The Safeway Fuel Center project includes installation of aneight pump ( 16 fueling positions) facility under a 5, 932 square foot fueling canopy with anadjacent 697 square foot convenience store. Site Improvements include, but are not limited to

landscaping, off street parking, an electric vehicle charging station and relocation of twounderground storage tanks. Primary access to the pumps is from the existing drive aisle in theshopping center with egress either onto Maria Drive via an existing curb cut or into the interiorof the shopping center via a new access at the northwest corner of the parcel. Queuing space for12 vehicles has been accommodated through placement of the fueling canopy. The project alsoincludes improvements to the eastside transit center consisting of an off-street pull out for thethree bus stops, shelters, benches, and landscaping and solar powered arrival sign. A moredetailed project description is available in the May

8th

Planning Commission staff report and inthe Initial Study ( IS) that can be found on the City' s website, www.cityofpetaluma.net ( link: http://petaluma. granicus. com/ GeneratedAgendaViewer. php?view_ id= 31 & clip_ id= 2578)

On June 26, 2018 the Planning Commission adopted Resolution No. 2018- 21A approving theMitigated Negative Declaration ( MND) and Resolution No. 2018- 21 approving the Site Plan andArchitectural Review ( SPAR) for the project. Consistent with the requirements of the

Implementing Zoning Ordinance ( IZO) Section 24. 070, JoAnn McEachin filed an appeal within14 days of the Planning Commission' s approval. The appeal was filed on behalf of the

McDowell Elementary School, Little League Children and East Petaluma Residents, and

included 15 additional signatures from members of the public. The grounds for appeal, outlined

in the Letter of Appeal, included: questioning the community need for the project; the proximityof the project to a day care, school and Little League ball park; traffic increase; project emissions

and health impacts; traffic safety; and public awareness of the project. Comments submitted onSeptember 14, 2018 by Soluri Meserve, counsel for the appellants, challenged both the PlanningCommission' s Site Plan and Architectural Review approval and approval of the project

Mitigated Negative Declaration.

The appeal hearing before the City Council was duly noticed for the September 17, 2018meeting. A large volume of public comment letters was received, including technical analysisprepared by qualified consultants on behalf of the Petaluma School District and the appellants, inthe days and hours leading up to the Council meeting. Due to the volume of public commentletters and new information received and given that there was insufficient time to adequatelyreview new materials, the Council continued the item, without opening a public hearing, toOctober 15, 2018.

DISCUSSION

Leading up to the September 17, 2018 City Council hearing, a number of additional commentletters and documents were received, including substantial new information. The followingsummarizes new information received:

1. Various comment letters from members of the public, the vast majority of which

expressed opposition to the project on a number of grounds including air quality/healthrisks, safety, and circulation/ traffic, while a few expressed support of the project.

2. On behalf of the Petaluma School District, Meridian Consultants conducted a review of

the IS/ MND prepared for the Safeway Fuel Center. Meridian Consultant' s letter

September 12, 2018) identified concerns with the analysis presented in the IS/ MND for

air quality/ health risks, greenhouse gas emissions, hazards and hazardous materials, noise, and transportation/ traffic.

3. On behalf of the applicant, Rutan & Tucker issued a September 14, 2018 letter

responding to concerns raised in the Meridian letter including supporting technicalanalysis prepared by. Illingworth & Rodkin ( Air Quality/ Health Risk, GHG and Noise) and CHS Consulting ( transportation).

4. On behalf of the appellant, Soluri Meserve issued a letter on September 14, 2018

including supporting technical analysis prepared by Phyllis Fox and Ray Kapahi, September 17, 2018 and Errata thereto dated September 17, 2018. The letter asserts that

the City Council should overturn the SPAR approval under its land use discretionary

authority, and that there is substantial evidence to support a fair argument that the projectmay have significant adverse environmental impacts and that therefore an EIR must beprepared. The supporting technical analysis contains a Health Risk Analysis using theAERMOD dispersion model, which concludes that cancer risks exceed thresholds of

significance (greater than 10. 0 in one million, assuming a 70 -year lifetime exposure).

The Bay Area Air Quality Management District (BAAQMD) issued a comment letter onSeptember 17, 2018 regarding the methodology utilized in the Health Risk Assessment

N

prepared by Illingworth & Rodkin for the Safeway Fuel Center. The letter provides noticethat BAAQMD' s modeling analysis procedures have changed since the project wasinitially permitted by the District and that the AERMOD dispersion model is nowrecommended instead of the ISCST3 model, which was used in the Health Risk

Assessment.

In considering this information, the City consulted with staff at BAAQMD to receive input onthe appropriateness of the methodology utilized in the HRA prepared by Fox and Kapahi. BAAQMD was provided with the HRA to review the methodology, assumptions, and resultspresented. A written response has not been received from BAAQMD to date but is expected thisweek.

Additionally, Staff received a response from the applicant and including a memo fromIllingworth & Rodkin on behalf of Safeway in response to the Fox Report and the BAAQMDcomment letter. That response was received after business hours on October 10, 2018. The

applicant' s response is included as Attachment 2, however, it is important to note that the

document has not been reviewed by staff.

In order to allow review and consideration of forthcoming information by City staff, Citydecisionmakers, interested parties and members of the public, it is recommended that the CityCouncil continue the hearing on the Safeway appeal to December 3, 2018.

Public comments received throughout the proceedings related to the application are included in

prior staff reports. Public comments received since publication of the September 17, 2018 staff

report are included as Attachment 1.

Public notice for the September 17, 2018 City Council hearing was published in the ArgusCourier and mailed to all property owners and tenants within a 1; 000 -foot radius of the site andto 274 people on the interested parties list. Additionally, two public hearing signs were postedon the site in advance of the September 17, 2018 hearing. Because the appeal hearing wascontinued to October 15, 2018, re -noticing of the public hearing was not required. This will

continue to be the case if the Council accepts the recommendation to continue to December 3,

2018.

FINANCIAL IMPACTS

The appeal is a cost recovery project. The initial $235. 00 deposit was paid by the appellant uponsubmittal of the appeal while all additional costs of processing the appeal are paid by theapplicant.

ATTACHMENTS

1. Public Comment letters received after September 17, 2018

2. Applicant' s Response to Comments, October 10, 2018

No

ATTACHMENT 1

From: Crump, I< atie < I< CRUMP@ci. petaluma. ca. us>

Sent: Tuesday, October 9, 2018 8: 04 AMTo: - City Clerk <- CityClerl< @ci. petal uma. ca. us>

Cc: Heather Hines < hhines@m- 8roup. us>

Subject: FW: Say No to the Safeway Gas Station

From: Kevin Anderson [ mailto: kevin climate rotection. or9] Sent: Monday, October 08, 2018 12: 40 PMTo: CityCouncil

Subject: Say No to the Safeway Gas Station

Petaluma City Council,

Please do not allow the Safeway gas station to go up on the corner of S. McDowell and MariaDrive.

While seemingly a small, city -related issue, this is a metaphor for what we are facing as aspecies: Do we continue to allow fossil fuels to power our lives 1uZowing that there ISwidespread pollution (air, land, and water) with local and global ramifications.

While many point out the damage we are doing to future generations by leaving them a planetthat is increasingly polluted, this is a prime example of something that also will affect ourchildren here and now. Putting a gas station right across the street from schools and a parkWILL affect the community in negative ways; first and foremost, the children and families thatfrequent the area.

You have the power to take a stand and show that our community' s health and vitality is yourforemost concern.

Please consider NOT allowing this Safeway gas station to go forward.

Thanlc you for your time.

In gratitude,

Kevin Anderson

Kevin Anderson

ECO2School Program Coordinator

tittp:// v,vww, cliniatel) rotection. org

Phone: 707- 525- 16_65 x 122

Office: 831 Fourth Street; Santa Rosa, CA 95404

N- iailing: P. O. Box 3785, Santa Rosa, CA 95402

Original Message -----

From: Crump, Katie < KCRUMP@ci. petaluma. ca. us>

Sent: Tuesday, October 9, 2018 8: 04 AMTo: - City Clerk <- CityClerk@ci. petaluma. ca. us>

Cc: Heather Hines < hhines@m- graup. us>

Subject: FW: please no Safeway gas station in proposed location


From: Erica Vertiz [ mailto: ericavertiz@aol. com]

Sent: Monday, October 08, 2018 2: 01 PMTo: CityCouncil

Subject: Re: please no Safeway gas station in proposed location

Dear Petaluma City Council,

I have lived in Petaluma since I was 5 years old. I am now 39 and I am raising my own son here.

My husband and I do not live near this Safeway on McDowell nor will be sending our son to McDowellElementary, however, I am getting involved because I strongly think this plan to build a gas station nextto two ( 2) schools is wrong. What about the kids? Petaluma is a strong and kind town. This is not whatwe are about!

I live by the Safeway where G& G use to be. 1 am so opposed to this that I I have already stoped shoppingthere( I use to goat least twice a week).

I ask you to please oppose the plan to build a Safeway Gas Station next to a preschool and elementaryschool. This is not safe.

In addition, North McDowell and South McDowell can' t handle anymore traffic.

Lastly, I have been told that someone from the planning department (who voted in favor of the gasstation) is on the board of the preschool? Is this correct? Could someone please confirm or deny?

Thank you for taking the time to read this email.

Sincerely,

Erica Vertiz a long time resident of Petaluma

1417 Yarberry LanePetaluma

Sent from my iPhone!

From: Iftil<har Ahmed < iftia92@gmail. com>

Sent: Sunday, October 7, 2018 3: 48 PM

To: peetalumaplanning@ci. petaluma. ca. us

Cc: maser@ci. petaluma. ca. us

Subject: Safeway gas station at the corner of Maria Dr., S McDowell Blvd

Warning: Use caution before clicking any attachments. THIS EMAIL IS FROM OUTSIDE OUREMAIL SYSTEM. ---

Dear Sir / Ma' am,

I am oppose to the gas station, and I am not associated to any gas station or any oil company.

My comments are attached here with.

Thank you,

Best of regards,

Sincerely yours,

Iftikhar Ahmed

e- mail address: iftia92@gmail. com

Ph : ( 707) 762- 8234

Address : 1283 McGregor Ave, Petaluma CA 94954

Sent from Mail for Windows 10

The appeal against the Safeway gas station has been denied.

Like any project, or any business enterprise there are always two angles to it. Or you can saypros and cons or simply put good and bad.

In this case there are lot more cons than pros, lot worse than good. The pros the proponents

are suggesting is only one cheaper gas. And for the city is traffic impact fee, that they willcollect from the applicant Safeway. The arguments of the residents who are for it, revolve

around cheaper gas nothing else.

But look at the cons, the bad:

1. Its proximity to the children day care center, to the youth baseball field, to the youthplaying field and not to mention the McDowell elementary school.

2. It is in the heart of the densely populated residential area.

3. We already have more than enough numbers of gas station in this small city ofPetaluma, there is no need of another gas station.

4. The increased traffic that the gas station will bring in the city, when already the city is

facing traffic congestion problem.

The AQMD (Air Quality Management District) has OK' d the project even though a teacher of

McDowell elementary School, who said during the last presentation of Safeway, that quite agood percentage of the students complain of breathing problems and Asthma during the allergy

season every year.

As far the traffic congestion problems are concerned, we already have on the streets of

Petaluma specially on the S McDowell Blvd and E Washington Street, Lakeville and EWashington street, and Lakeville and D Street. Will this gas station contribute to the

problems? The answer is very simple, this station not only will attract the residents of

Petaluma but also will attract the residents from the neighboring cities like Penn Grove,

Cotati, Rohn ert Park, and Santa Rosa, and not to mention Novato and San Rafael as well. I

don' t know if the representatives of Safeway have shown any studies quantifying how many

vehicles usually are there these days on the streets of Petaluma during the peak hours. Andhow many more vehicles will be there once the gas station starts. And, I don' t know if theplanning commission has done any study in this regard. Furthermore, I don' t know howmany of the representatives of Safeway live in Petaluma, and drive on the streets ofPetaluma on daily basis, going East and West, and from West to East. If they drive inPetaluma on daily basis, then they will know what I am talking about. Mayer and the citycouncil members should know. Not to mention Maria Dr, two lane street. How many

vehicles this small street can hold during peak hours, whose one side is S McDowell Blvd

and the other side is E Washington Street.

Safeway representatives have said throughout the process that their project is backed bypoll of 500 residents who regularly leave Petaluma to buy cheaper gas. Did the Safewayhave provided the proof of that poll to the council?

The other thing is that during the applicant' s presentation, a lawyer of Safeway threatened

the city with litigation if the project was denied. So, I have a question or comment, if thosesaid kids of McDowell Elementary School, who get breathing problem and Asthma during

the allergy season, if their sickness gets aggravated after the Safeway gas station is open, who should they sue Safeway gas station or AQMD? And no money would bring back theirhealth once they get severely sick.

From: Heather Hines

Sent: Thursday, October 04, 2018 10: 50 AMTo: Evelyn Ellis

Subject: FW: Safeway Gas Station

For the Safeway file


From: Crump, Katie < I< CRUMP@ci. petaluma. ca. us>

Sent: Thursday, October 04, 20187: 14 AMTo: - City Clerk <- CityClerk@ci. petaluma. ca. us>

Cc: Heather Hines < hhines@m- group. us>

Subject: FW: Safeway Gas Station


From: Stephanie Taylor [ mailto: taylors4@sbcglobal. net]

Sent: Thursday, October 04, 2018 7: 12 AMTo: CityCouncil

Subject: Safeway Gas Station

Dear Council Members,

I would like to express my absolute disapproval of the proposed Safeway Gas Station on S. McDowell and Maria Dr. I live5 blocks away, both walk and drive this corridor regularly so I will personally be impacted. However, the overallenvironmental impacts are my real concern and I concur with the primary argument that gas stations ( of which there arealready an abundance of) DO NOT BELONG IN THE IMMEDIATE VICINITY OF SCHOOLS. PERIOD.

So many young children on the East side of Petaluma are already impacted by their proximity to Hwy. 101 and theirincreased exposure to particulate matter from that source has been shown repeatedly to have significant respiratoryhealth impacts. As our elected representatives ( you do represent us - not private business interests) it is your job toprotect your constituents from these and other environmental risks. Does Petaluma not have a law against idling cars? The number of drive- throughs would suggest not; we need to change this. The population of the town is growing, weare all feeling the effects of that and most people are complaining about the diminishing quality of life here due totraffic.

Please do the RIGHT THING, consider the materials, briefs, arguments and evidence presented to you at the last councilmeeting and reject Safeway' s strong arm tactic ( threatening to sue the City if project is rejected). A full boycott of

Safeway should ensue for this threat alone.

Please be advocates for a new, healthier, more livable Petaluma and reject Safeway' s proposed gas station. We justdon' t need it and we don' t want it.

Thank you for your service to the community.

Sincerely, stephanie taylor.

City of Petaluma records, including emails, are subject to the California Public Records Act. Unless exemptions apply, thisemail, any attachments and any replies are subject to disclosure on request, and neither the sender nor any recipientsshould have any expectation of privacy regarding the contents of such communications.

October 3, 2018,

RE: Safeway Appeal, October 15111, 2018

Dear John, Mayor Glass and City Council Members,

At the June 26111 planning commission meeting a commissioner berated Safeway fornot having their information in both English and Spanish. Can we expect alldocuments for the Safeway Appeal to be required in both English and Spanish? Will

the city have a Spanish interpreter at the meeting? I would appreciate a quickresponse.

Thank you,

Janice Cader Thompson

C. c. Heather Hines

Petaluma City AttorneyNatalie Mattei

Joanne McEachin

Andrian Saslow

Chris Thomas

PHS Board members

Argus Courier

Press Democrat

Evelyn EllisSOMMINEEM

From: Heather Hines

Sent: Thursday, October 04, 2018 12: 11 PMTo: Evelyn Ellis

Subject: FW: Safeway Gas Station Appeal

For the Safeway file.


Sent: Tuesday, October 02, 2018 1: 53 PMTo: - City Clerk <- CityClerl<@ci. petaluma. ca. us>

Cc: Heather Hines < hhines@m- group. us>

Subject: FW: Safeway Gas Station Appeal

From: Adriann Saslow [ mailto• madamesaslow@gmail. comj

Sent: Tuesday, October 02, 2018 1: 45 PMTo: CityCouncil

Subject: Safeway Gas Station Appeal

Dear City Council,

Please do not let Safeway built their gas station. They aren' t a good neighbor. They aren' t doing it as a favor tous. They are out to make money. As a part of the No Gas Here coaliton, I have become more and more awareof the environmental issues with this mega -station and its impact on the school children & surrounding

neighbors. There is overwhelming opposition to this project from the people it will have the greatest affect on. No Gas Here has done our best to give the Council a legal way to turn down the project without gettingsued. Getting sued by Safeway seemed to be the only reason the Planning Commission ended up approving thisin the first place. But even if the City of Petaluma does get sued, maybe its worth it to take a stand for thevulnerable members of our community.

I will be at the City Council Meeting, at least for a while until I have to get home to my own small children.

Sincerely, Adrianti Saslow

Petaluma Resident


Evelyn Ellis

From: Heather Hines

Sent: Thursday, October 04, 2018 12: 01 PMTo: Evelyn Ellis

Subject: FW: Safeway gas

For the Safeway appeal file


Sent: Wednesday, September 26, 2018 10: 06 AMTo: Heather Hines < hhines@m- group. us>

Cc: - City Clerk <- CityClerl< @ci. petaluma. ca. us>

Subject: FW: safeway gas

From: Jonathan Ruf [ mailto: jonoruf gmail. com]

Sent: Wednesday, September 26, 2018 9: 59 AMTo: CityCouncil

Subject: safeway gas

Greetings,

We recently moved to Petaluma, and part of our choice in where to live was the fact there is a school and parkin the neighborhood ( directly across the street from where we live), and it is pretty slow and quiet. A Safewaygas station will change all of that.

You have already been informed of the health effects such a project entails, and there is plenty of science toback up the harmful effects of auto emissions, especially to the young, elderly, and people with compromisedimmune systems. My wife lacks a gene receptor that helps humans to filter and detoxify toxins from your bodyShe will feel and manifest the effects from an increase in emissions in the neighborhood. Furthermore, Icommute via bicycle and a massive increase in traffic will increase the safety risks for cyclists and pedestriansalike (as well as drivers!).

The welfare of the people should supplant the welfare ( read bottom line) of corporations. EPA law states such aproject this close to schools is unlawful. The people who live in the neighborhood do not want it. Allowing sucha project to go through would be on its face completely undemocratic.

The people who live in the neighborhood, who send their children to school here, should be the one' s deciding, because it is us who will suffer the impacts from the increase in health and safety risks from the safeway gasstation.

Thank you for your time,

Jono Ruf


c .

Evelyn Ellis

From: Heather Hines

Sent: Thursday, October 04, 2018 11:52 AMTo: Evelyn Ellis

Subject: FW: Proposed gas station

For project file

From: Crump, Katie < KCRUMP@ci. petal uma. ca. us>

Sent: Monday, September 24, 2018 8: 55 AMTo: Heather Hines < hhines@m- group. us>

Cc: - City Clerk <- CityClerl<@ci. petaluma. ca. us>

Subject: FW: Proposed gas station

From: Kailea Frederick[ mailto• kailea. sonrisa( a)gmail. com]

Sent: Saturday, September 22, 2018 4: 48 PMTo: CityCouncil

Subject: Proposed gas station

Hello,

I am a Petaluma Resident and I don' t want a Safeway Gas Station in WashingtonSquare. Having the traffic and pollution next to the preschool, elementary school, softball fields, and homes is not a good environment for our children. Please do not allow a gas station to be

built here!

Thank you,

Kailea Frederick

Facilitator, Earth Is' Ohana

WIN w. earth i sohana. con3


Evelyn Ellis

From: Heather Hines

Sent: Thursday, October 04, 2018 11: 49 AMTo: Evelyn Ellis

Subject: FW: Gas station

For Safeway file



Sent: Monday, September 24, 2018 8: 08 AMTo: Heather Hines < hhines@m- group. us>

Cc: - City Clerk <- CityClerl<@ci. petaluma. ca. us>

Subject: FW: Gas station


From: loanna clark [ mailto: loannaclarl< @icloud. comj

Sent: Thursday, September 20, 2018 6: 10 PMTo: CityCouncil

Subject: Gas station

To whom it may concern, In this day and age when illogical decisions seem to be being made by

many politicians it is difficult to believe our very own Petaluma City Council would think it' s OK and viable to put a gasstation in that location. By my count we have a minimum of 15 gas stations within the city limits so this is clearly notabout Community need. Now as far as what revenue it may bring to the city I can' t say but to put it in this location withso many young people that study and do sports plus even older citizens that live on South McDowell etc. even I as a layperson am familiar with studies as to just how detrimental gas fumes and by products of auto traffic are to them. Theyalready are exposed to what my guess is the upper limit exposure anyway. We already have semi trucks using McDowellas a substitute for a Hwy. I have lived in Petaluma for over 30 years and I have seen a lot development most of which Ihave understood but this is negligent and I will vote accordingly.

If for some reason I am missing something you can email me back otherwise the above statement stands. Sincerely

Loanna Clark

Sent from my iPhone


John Cinnamon737 North Webster St.

Petaluma, California 94952- 1734

707) 202- 4359 Cell ( 916) 591- 5691

john. b. cinnamon@gmail. com>

September 18, 2018

Petaluma City CouncilCity Clerk, Claire Cooper, CMC SEP 2 a 201811 English Street

Petaluma, CA 94952 CITY C LE R K

Re: Appeal of Planning Connrission' s Approval of a Service Station in the Washington SquareShopping Center in the immediate vicinity of the North Bay Children' s Center, Petaluma ChildDevelopment Center, McDowell Elementary School and McDowell Park

Mayor Glass and Members of tine Council:

Submitted for consideration by the Counciland to made a part of the record in the matter of such appeal

Background

In the 1960s while I was out of state completing my education, my father died while my threesisters were still in grainipar.andhigh school.,My.iuother, long out of the -workforce, requiredemployment. Her age and inexperience worked against her in this regard until Safeway, then

operating a regior;al-v"'areliouse and distribution' ccnter in Sacramento, gave her a' chance. Safeway. trained her in the use of the then computer technology and, until reaching mandatoryretirement age, my mother was a valued, productive and content Safeway employee. When Safeway absorbed the former C & C market, I observed the enlightened and fair treatment

received by the Q & C staff who became members of the Safeway team. Interactions over the past several years with COTS, the Salvation Army, The Food Bank, etc.

disclose that Safeway has been a responsible Sonoma County citizen with regard to feeding thosewith inadequate resources in our communities.

I am not unaware that Safeway and most conventional large- scale grocery retailers are undersiege from the big -box retailers who aie able to sell product at price levels unsustainable byconventional retailers. I understand that the availability of ancillary services and products to itscustomers as a meansici attract them to their stores, is essential - for continued profitability. - I

understand too, that Sateway has found that offering gasolene for its customers' vehicles hasbeen one of these successful ancillary services.

I am myself presently aud'plan to continue to be a regular Safeway customer.

Accordingly, i regard myself as having no negative disposition toward Safeway, its management or its

gasolene sales business generally.

Proposed Service Station

Tt is my view however, that:failure' fo reverse tlie-'actioir of,'the Planning C6mmis9i6n allowing -theproposed site for Safeways: Petahuna - station Nvill, be `an egregioiis dereliction ofyour dutyto ,actin the

Petaluma City Council September 18, 2018

City Clerk, Claire Cooper, CMC

Page 2

common good. The arguments against such a business enterprise in the proxin7ity of the school,

children' s and child development centers and park are well known to you, need not be repeated here, and

are, to my mind, compelling.

I am also aware of the City' s' elvonically precarious financial reality, of the potential cost associated with

defending any litigation that Safeway may bring, and of the projected lost sales and property tax

revenues, development fees and perhaps other potential economic advantages to our City.

Nonetheless, there is a time that these considerations must be secondary to doing what is the " right thing"

for our children' s health and safety, our cornmunity and our future. I respectfully request that you do so

in this instance and sustain this appeal thereby denying the construction of a service station at this

location.

7Cinnamon


From: tonya parnak < tonyaparnak@yahoo. com>

Sent: Tuesday, October 09, 2018 12: 55 PMTo: - City Clerk <- CityClerk@ci. petaluma. ca. us>

Subject: Gas stations vent far more toxic fumes than previously thought

Warning: Use caution before clicking any attachments. THIS EMAIL IS FROM OUTSIDE OUR EMAILSYSTEM. ---

Dear City Council Members,

Please read the following research article that just came out on Oct. 4th, from Columbia University' sMailman School of Public Health. Thank you for your time!

Sincerely, Tonya Parnak

Article copied below from the following website without the pictures: https:// Phys.org/ news/ 2018- 10-gas- stations-vent-toxic-fumes. html .

October 4, 2018, Columbia University' s Mailman School of Public Health

Gas stations vent far more toxic fumes than previously thought

A study led by environmental health scientists at Columbia University Mailman School of Public Healthexamined the release of vapors from gas station vent pipes, finding emissions were 10 times higher thanestimates used in setback ... more A study led by environmental health scientists at Columbia UniversityMailman School of Public Health examined the release of vapors from gas station vent pipes, findingemissions were 10 times higher than estimates used in setback regulations used to determine how close

schools, playgrounds, and parks can be situated to the facilities. Findings appear in the journal Science of

the Total Environment.

Gasoline vapors contain a number of toxic chemicals, notably benzene, a carcinogen.

The researchers attached gas flow meters to venting pipes at two large gas stations in the Midwest and

Northwest and took measurements over a three- week period. They report average daily evaporative

losses of 7 and 3 gallons of liquid gasoline, respectively, or 1. 4 pounds and 1. 7 pounds per 1, 000 gallons

dispensed at the pump. By comparison, the California Air Pollution Control Officers AssociationCAPCOA) used an estimate of 0. 11 pounds per 1, 000 gallons. Based on CAPCOA emission estimates, the

California Air Resources Board ( CARB) determined their setback regulation of 300 feet ( 91 meters) from

large gas stations. Similar laws exist in many, but not all states and localities. In urban areas like NewYork City, some gas stations are located directly adjacent to apartment buildings. The study also simulated how the fuel vapor was carried in the air to assess the potential for short- andmedium- term benzene exposures, comparing their measurements to three established thresholds. TheCalifornia Office of Environmental Health Hazard Assessment one- hour Reference Exposure Level ( REL)

for benzene— defined as a continuous hour of exposure to the chemical— was exceeded at both gas

stations at distances greater than 50 meters. At the Midwest gas station, REL was exceeded on two

different days at distances greater than 50 meters, and once as far as 160 meters. The Agency for Toxic

Substances and Disease Registry' s Minimal Risk Level ( MRL) for benzene exposure over a periodbetween two weeks and a year was exceeded within 7 or 8 meters of the two gas stations. A less

stringent measure used for short- term exposures of first responders, the American Industrial Hygiene

Association' s Emergency Response Planning Guidelines ( ERPG), was not exceeded. We found evidence that much more benzene is released by gas stations than previously thought. In

addition, even during a relatively short study period, we saw a number of instances in which peoplecould be exposed to the chemical at locations beyond the setback distance of 300 feet," said first author

Markus Hilpert, Ph. D., associate professor of Environmental Health Sciences at the Columbia Mailman

School. " Officials should reconsider their regulations based on these data with particular attention to

the possibility of short spikes in emissions resulting from regular operations or improper proceduresrelated to fuel deliveries and the use of pollution prevention technology."

In previous work, Hilpert and colleagues documented the release of gasoline as fuel is stored and

transferred between tanker trucks, storage tanks, and vehicle tanks, and how these spills can

contaminate the surrounding environment. Next, the researchers will explore additional short- termmeasures of vapor spread to determine the bounds of safe setbacks.

Explore further: Small spills at gas stations could cause significant public health risks over time More

information: Markus Hilpert et al, Vent. pipe emissions from storage tanks at gas stations: Implications

for setback distances, Science of The Total Environment ( 2018). DOI: 10. 1016A.scitotenv.2018. 09. 303

Read more at: https:// phys.org/ news/ 2018- 10- gas- stations- vent- toxic- fumes. html# iCp

RUTANRUTAN & TUCKER, LLP

October 10, 2018

VIA EMAIL AND FEDERAL EXPRESS

Heather Hines

Planning ManagerCity of Petaluma11 English Court

Petaluma, CA 94952

ATTACHMENT 2

Matthew D. Francois

Direct Dial: ( 650) 798- 5669

E- mail: mfi-ancois@i- utan. comiutan. com

Re: Safeway Fuel Center Project— Responses to Comments of Bay Area Air

Quality Management District and Phyllis Fox/ Ray Kapahi

Dear Ms. Hines:

We write on behalf of our client, Safeway, Inc., regarding the proposed Safeway FuelCenter Project ( the " Project") at 335 S. McDowell Boulevard ( the " Property") in the City ofPetaluma ( the " City"). We write to provide responses to the September 17, 2018 comments from

the Bay Area Air Quality Management District (" BAAQMD") and Phyllis Fox and Ray KapahiFox/ Kapahi") on the health risk assessment (" HRA") prepared by Illingworth & Rodkin, an

expert air quality consulting firm, for the Project.

As you know, the Project has been reviewed by the City for nearly six years and was thesubject ofnumerous studies prepared by expert consultants as well as a detailed mitigated negativedeclaration (" MND") prepared by M -Group, the City' s contract planning staff. One of the

supporting studies is the HRA. Employing conservative assumptions and accepted methodologiesper federal, state, and local guidelines, the HRA concludes that the Project meets all thresholds

and will result in less than significant impacts with respect to community risk for all categories ofsensitive receptors.

After continuing its May 8, 2018 hearing to obtain more information regarding air qualityand traffic, and to allow additional review by Petaluma City Schools, the Planning Commissionapproved the Project on June 26, 2018. On July 9, 2018, an appeal of the Planning Commission' saction was filed by JoAnn McEachin and others. The appeal was originally scheduled for

consideration by the City Council at its September 17, 2018 hearing. .

On September 14, 2018, the City received a comment letter from Patrick Soluri on behalfof JoAnn McEachin and No Gas Here, a recently -formed super political action committee, whichwas followed on September 17, 2018 by a comment letter on the HRA from Fox and Kapahi. OnSeptember 17, 2018, the City also received a comment letter from BAAQMD on the HRA.

In its comment letter, BAAQMD recommends use of the American Meteorological Society

Regulatory Model (" AERMOD") instead of the Industrial Source Complex Short -Tenn 3

ISCST3") model to evaluate the Project' s health risk impacts. BAAQMD also requests that a

RUTANRUTAN 6 TUCKER, LLP

Heather Hines

October 10, 2018

Page 2

health risk analysis of workers/ teachers at nearby schools be performed. Fox/Kapahi likewise

assert that the AERMOD model should have been used and purport to include a health risk

assessment indicating that the Project will result in significant cancer risks at nearby sensitivereceptors.

As explained in the October 10, 2018 response from James Reyff of Illingworth & Rodkin,

attached hereto as Exhibit A, ISCST3 is a U. S. EPA -approved and BAAQMD- recommended

model. It was used since there is representative meteorological data readily available for Petalumathat is suitable for use with that model. It is also the model that was used for every recent Petalumaproject for which a quantitative health risk analysis was prepared.

Nonetheless, in response to BAAQMD and Fox/ Kapahi, and at further expense to Safeway, Illingworth & Rodkin contracted with Lakes Environmental to develop a custom meteorologicaldata set for the Project site and conducted a supplemental health risk analysis using the AERMODmodel. This supplemental analysis evaluated the health risk to residents, school children, and

workers/ teachers. As with the original analysis using the ISCST3 model, the supplementalanalysis using the AERMOD model concludes that the Project meets all thresholds and will notresult in any significant impacts related to health risk.

In preparing the AERMOD analysis, it was discovered that the HRA analysis overstatedthe health risk associated with constructions emissions by using standard default values instead ofassuming the use of Tier 2 construction equipment. Neither City staff, BAAQMD, nor Fox/Kapahiraised this issue in their comments on the HRA. Since the Planning Commission conditioned theProject to use Tier 3 construction equipment, the updated analysis assumes the use of Tier 3

equipment under both model scenarios.

As also explained in Illingworth & Rodkin' s response, the commenters' claims of

significant impacts are based on speculative, unsubstantiated, unsupported, and erroneous

assumptions. Specifically, Fox/Kapahi wrongly base their analysis on Santa Rosa wind data asopposed to Petaluma data even though analysis of health risk is heavily dependent on the use ofcorrect meteorological information. Commenters also . overestimate diesel emissions by anapproximate factor of ten by overestimating the amount of diesel sales and number of vehicles aswell as by incorrectly averaging the emission rate for all vehicle types. Commenters likewise

overstate the amount of benzene emissions, citing higher emission factors from another air district, and then modeling even higher emissions than the cited values.

The Fox/ Kapahi comment letter asserting that the Project will result in significant impactsis based on argument, speculation, unsubstantiated opinion, clearly inaccurate and erroneousinformation, and evidence that is not credible. As a result, the letter does NOT constitute

substantial evidence of a fair argument that the Project may result in a significant environmentalimpact. ( Public Resources Code §§ 21080( e), 21082. 2( c); CEQA Guidelines §§ 15064( f)(5), and

15384; Friends of B̀" Street v. City ofHayward ( 1980) 106 Ca1. App. 3d 988.) As such, the Cityinust adopt the MND for the Project. ( Public Resources Code §§ 21080( c), 21064. 5; CEQA

2696/ 031700- 0001

12940707. 1 a10/ 10/ 18

RUTANRUTAN 6 TUCKER. LLP

Heather Hines

October 10, 2018

Page 3

Guidelines §§ 15063( b)( 2), 15064( f)(3); Parker Shattuck Neighbors v. Berkeley City Council2013) 222 Cal.App.4th 768, 785.)

Thank you very much for your assistance on this matter. Please do not hesitate to contactme with any questions regarding the enclosed information.

Very truly yours,

RUTAN & TUCKER, LLP

Matthew D. Francois

MDF: mtr

cc ( via email only):

Natalie Maffei

John Brown

Eric DanlyDavid Glass

Olivia Ervin

Adam Petersen

Teresa Barrett

Shirlee Zane

Duncan Campbell

Yvette DiCarlo

Kevin Oei

David Vintze

Barry Young

2696/ 031700- 0001

12940707. 1 a10/ 10/ 18

kLt1iVG11 oRTH& Romwfl Acoustics • Air Quality ll

429 E. Cotati Ave

Cotati, California 94931

Tel: 707- 794- 0400 Fax: 707- 794- 0405

www.illingworthrodIcin. com illro@illingworthr• odlcin. coin

Date: October 10, 2018

To: Natalie Mattei

Senior Real Estate Manager

Albertsons Companies

11555 Dublin Canyon Road

Pleasanton, CA 94588

From: James A. ReyffIllingworth & Rodkin, Inc.

429 E. Cotati Ave

Cotati, CA 94931

RE: Safeway Fuel Center CEQA document - Petaluma, CA

SUBJECT: Safeway Fuel Center Health Risk Assessment - Response to Comments made

by BAAQMD and Phyllis Fox/ Ray Kapahi Z20")

This memo provides our response to comments regarding the Petaluma Safeway gas station projectProject") made by ( i) the Bay Area Air Quality Management District (" BAAQMD") in a letter

dated September 17, 2018 and ( ii) Phyllis Fox and Ray Kapahi in a report dated September 17, 2018, 1

Responses to BAAQMD letter dated September 17, 2018

In the introduction of its letter, BAAQMD states that its review addressed stationary sources. Itshould be noted that the Health Risk Assessment for the Project (" HRA") addressed construction

emissions, evaporative emissions from transfer and storage of gasoline, and emissions from Projecttraffic.

Use of ISCST3

As explained below and in previous responses, Industrial Source Complex Short -Term 3

ISCST3") is a U.S. EPA -approved and BAAQMD- recommended model. Nonetheless, in

response to the BAAQMD and Fox/ K apahi letters dated September 17, 2018, Illingworth & Rodkin contracted with Lakes Environmental to develop a custom meteorological data set for the

I Continents on the Initial Study/ Mitigated Negative Declaration ( IS/ MND) for the Safeway Fuel Center Petaluma, California

Memo to Natalie Mattei

October 10, 2018 — Page 2

Project site and conducted a supplemental health risk analysis using the American MeteorologicalSociety ( AMS)/ EPA Regulatory Model (" AERMOD"). That supplemental analysis, attached

hereto as Exhibit A, similarly concludes that the Project meets all thresholds and will not result inany significant impacts related to health risk.

Please see responses to Meridian comments regarding the use of the ISCST3 model, attached asExhibit B. Specifically, the ISCST3 model was used since there is representative meteorologicaldata readily available for Petaluma that is suitable for use with that model. ISCST3 is a U. S. EPA - approved dispersion model and is included in BAAQMD' s Tools and Methodologies section of

their website as Recommended Methods for Screening and Modeling Local Rislfs and Hazards. This document describes in detail how to screen and model risk and hazards from stationary,

highway, and roadway sources. It also discusses the assumptions and methodologies used indeveloping the stationary source, highway, and roadway screening tools for use in CEQA studies. The website was last checked on 10/ 10/ 2018.

Volume Sources

BAAQMD recommends using two volume air sources ( or 8) of the same size that the HRA used. One (or 4) would be for refueling and the other one ( or 4) would be for spillage. The HRA used8 sources ( 4 for refueling and 4 for spillage) with one-fourth of the emissions assigned to eachrather than two or four). Therefore, the recommended technique would yield the same results.

ESA Memo dated Mav 7, 2018

Based on BAAQMD' s letter dated September 17, 2018, it appears that BAAQMD was in receipt

ofESA' s memo dated May 7, 2018 as well as Illingworth & Rodkin' s response to ESA dated May8, 2018, which is attached herein as Exhibit C.

BAAQMD states that the HRA should be analyzed at 25. 71 million gallons unless the City limitsthe Project permit to 8. 5 million gallons as studied in the HRA. Safeway estimates that they wouldnever exceed 8. 5 million gallons. In response, the City has conditioned the Project to the annual8. 5 -million -gallon throughput studied.

The HRA evaluated the impact to sensitive receptors with respect to CEQA thresholds identified

in the BAAQMD CEQA Air Quality Guidelines. It was pointed out in the response to ESA

comments that teacher risks would be less than the child/ student risk and that the most conservative

evaluation of health risk would be for a child at the nearby preschool. Nonetheless, an analysis ofteacher/worker risk is included in the supplemental analysis attached as Exhibit A.

BAAQMD concurs that use of the full 2015 State Office of Environmental Health Hazards

Assessment (" OEHHA") health risk assessment procedures would provide conservative results

and would be acceptable for CEQA purposes. This was the methodology used by the HRA.

BAAQMD concurs with Illingworth & Rodkin' s responses regarding receptor height andpollutants of concern. ( See Exhibit C.) Comment noted.



Responses to Fox-Kapahi Comments dated September 17, 2018

In sections 1 and 2 of their letter, Fox and Kapahi (" Commenters") claim that they prepared ahealth risk assessment (" Fox/ Kapahi HRA") that identifies significant health risks at nearbysensitive receptors. The primary response is that the Fox/ Kapahi LIRA is based on faultyassumptions for diesel vehicle idling. In addition, they used poor dispersion modeling techniquesand overestimated benzene emissions. As such they significantly overestimate actual emissionsand resulting impacts, resulting in false claims of significant impacts.

Benzene and Dispersion Modelin

The HRA used benzene emission factors that were based on the latest California Air Resources

Board (" CARB") guidance (described in the report) and were the same factors used by BAAQMDto compute effects for the facility' s permit (note that BAAQMD based their emissions on 25. 71million gallons of annual throughput). The HRA computed 34 pounds of benzene emitted per year

using the same benzene emission factor BAAQMD used for the Project' s Authority to Constructpermit. The Commenters used emission factors from the San Joaquin Valley Air Pollution ControlDistrict (" SJVAPCD") that predict 43 pounds per year ( see Commenter' s Table 1). However, a

review of the Commenters' modeling output shows that they modeled 49 pounds of benzene withno explanation for the discrepancies between the emissions computed and those modeled ( seeCommenter' s Exhibit C — Excerpts of HARP2 Risk Model). BAAQMD' s emission factors are the

appropriate factors to use for the Project, which is located within this air district.

Air Dispersion Model

The Commenters' dispersion modeling used the AERMOD model claiming it is the U.S. EPA' sprimary model for permitting. However, as this is a CEQA study of health risks that addressesthresholds identified in the BAAQMD CEQA Air Quality Guidelines and as explained in the HRAand subsequent responses to comments, use of ISCST3 with local Petaluma meteorological data

is appropriate. The Commenters used AERMOD with meteorological data from Santa Rosa,

which experiences different meteorological conditions and is not appropriate for the Project site.

ISCST3 with local Petaluma meteorological data reflects an appropriate analysis for this Project.

As stated by the Commenters, the wind patterns are very different in Petaluma and Santa Rosa. Thus, the results of the Commenters' modeling have no bearing on potential impacts that couldoccur from the Project in Petaluma. As such, any modeling results or impacts cited by theCommenters are meaningless and only provide speculative, unsubstantiated and unsupportedresults.

As stated above, Illingworth & Rodkin conducted a supplemental health risk analysis using theAERMOD model. That supplemental analysis, attached hereto as Exhibit A, similarly concludesthat the Project will not result in any significant impacts related to health risk. Exposure Duration: Operating Hours

In addition, the Commenters modeled the Project as operating 24 hours per day. This would

increase impacts because late night and early morning have relatively poor dispersioncharacteristics. As outlined in the Project MND, the proposed hours of operation for the Project

are 6: 00 a.m. to 11 p.m. Therefore, the Commenters' modeling is inaccurate and overstated.



Furthermore, the Commenters suggest that the annual PM2. s concentration from construction

activity ( of 0. 21 ug/ m3) should be increased proportionally with an increase in hours of operationthat would not be occurring during construction) from 19 hours to 24 hours and that concentration

should then be rounded upward to equal the threshold of 0. 3 ug/ m3. The hours of operation of the

Project, once constructed, have no bearing on the PM2. 5 concentration from construction activitiesthat would occur prior to operation of the Project. The Commenters' proposed approach is not

credible. In addition, the threshold for annual PM2.5 concentration is whether or not a project' scontribution would exceed 0. 3 ug/ m3, which the Project does not.

Type of Fuel

The HRA modeled this Project based on the sale of gasoline. In the event diesel fuel is sold,

Safeway estimates that would account for no more than 4 percent of the sales. A supplemental

analysis was conducted to account for the effects of diesel fuel sales from the Project. These

calculations were based on the same methodology used for other vehicles but applying DPMemissions to light- and medium -duty diesel vehicles that would be at the facility and transiting thearea. Based on projections using the EMFAC2014 model travel assumptions, these would makeup 3. 6 percent of the total vehicles.

As explained in previous responses, diesel fuel, unlike gasoline, has low reactive organic gasROG") emissions, and therefore, emissions from storage, transfer, and dispensing would be

negligible. Idling diesel vehicles would be a source of diesel particulate matter (" DPM")

emissions. Based on the HRA' s vehicle emissions modeling ( contained in the report attachments), the mix of light and medium duty diesel vehicles would comprise almost 4 percent ( also noted bythe Commenters).

The Fox/ Kapahi HRA overestimates diesel emissions by an approximate factor of 10. This

obviously skews their resulting health risk assessment.

First, they erroneously estimate 924, 405 vehicles per year would be served by the Project. Bymisrepresenting " trips" for " vehicles", the Commenter overstates emissions. Unlike vehicles, a

trip refers to a single vehicle entering and exiting a site. Vehicles idling would be at least one- halfthat number and that is if all vehicles are assumed to idle for 5 minutes before fueling for everyhour of the day. This is an error that results in emissions at least 2 times higher.

Second, the Commenters assumed that diesel sales would comprise 12 percent of all fuel sales

based on total retail sales from CEC data for Solano County. This station would only serve light - and medium -duty vehicles in Sonoma County. Fleet and large trucks (or haul trucks), which makeup much of the vehicle travel in Sonoma County, would not be fueling at this station. Safewayestimates diesel sales as up to 4 percent, which is in line with CARB' s EMFAC2014 model thatpredicts 3. 6 percent and was used in the HRA. It is also conservative in that diesel sales at

comparable Safeway gas stations in Pleasant Hill and Campbell only average approximately 2percent of sales. Commenters' error in projections of diesel sales results in emissions that are

over 3 times higher.

Third, in computing the grams per mile emission rate, the Commenters simply averaged the



emission rate for all vehicle types ( see their Table 2). The LDT vehicle type, which accounts for

very high emission rates because most of these vehicles are quite old, has a very small fraction oftravel. The Project HRA more accurately based the vehicle emission rate calculations proportionalto the vehicle miles traveled ( i.e., proportional to their use relative to other vehicles) by the typesof vehicles that would be accessing the gas station. The Commenters' error in averaging theemission rate for all vehicle types results in emissions that are 2 tinges as high.

Exnosure Duration

The HRA was first prepared and submitted in 2014 and addressed the 70 -year exposure period.

Subsequently, OEHHA released new guidance in 2015 that recommends a 30 -year exposure periodwith more protective modeling assumptions for infants and children. Based on numerous

discussions with BAAQMD, these assumptions were applied in the Project HRA. When

permitting new gasoline fueling sources, which only applies to the source being permitted ( i.e., benzene from gasoline dispensing facilities or GDFs), BAAQMD still applies the 70 -year exposureperiod and less protective exposure parameters. The HRA was updated to apply the new OEHHAguidance to all sources for the purposes of this CEQA analysis. As pointed out by BAAQMDcomments, this yields more conservative results. BAAQMD' s Air Toxics NSR Prop-ain HealthRisk Assessment Guidelines ( December 2016); Section 2. 1. 1. 3 describes the exposure durations

that BAAQMD relies upon to make risk management decisions.

It should be noted that neither of the daycare facilities provide care for children younger than two

2) years of age ( i.e., they have no infants present). For school children, the Commenters

suggested a 18 -year exposure period where they assume North Bay Children' s Center acceptsinfants and that students attending the daycare or schools would live across the street. This wasaddressed in previous responses attached hereto as Exhibit C. The analysis concluded that anysuch cumulative health exposure risks would likewise be less than significant.

Finally, the Commenter' s appear to have erroneously used a 70 -year exposure period that is basedon OEHHA' s 2003 risk assessment guidance but applied the full set of the newer more

conservative 2015 OEHHA exposure parameters in the HARP2 model that are intended to applywith the 30 -year exposure. As discussed in the project HRA, BAAQMD has adopted the 2015

OEHHA exposure parameters, health effect values and age sensitivity factors using 30 -yearexposure duration for sensitive receptors. Essentially, the Commenter' s analysis included 40years of additional exposure beyond what is recommended by the BAAQMD

and CARB. BAAQMD' s September 17, 2018 comment letter noted it was acceptable to either

use the 70 -year exposure ( 2003 risk guidance) for only gasoline stations health risk ( and not trafficor construction) or it would be conservative and acceptable to use the current 2015 OEHHA risk

guidance method for all such factors. The Commenters' analysis combined both methods to

achieve the highest outcome.

Construction Emissions

The Commenters state that with regard to construction emissions the same sensitive receptors will

be present in the same locations during both construction and operation of the Project and that theHRA failed to include exposures that would occur during the construction phase of the Project, thus underestimating health risks. This claim is erroneous. In the HRA, the construction health



risk impacts were clearly discussed and the maximum impacts identified in Table 2 of the HRA. Additionally, as clearly shown in Table 3 of the HRA, the maximum construction impacts wereincluded with, and added to, the maximum operational health impacts from the Project in order to

evaluate the overall maximum health impacts from construction and operation of the Project.

Furthermore, the HRA did not include the effect of control measures that Safeway included in theirproject description ( i.e., BAAQMD basic control measures and use of Tier 2 diesel construction

equipment) that substantially reduce construction impacts.

Health Risk Assessment and Emissions

The Commenters state that the OEHHA guidelines require that output from the AERMOD model

be entered into the HARP2 model to estimate health risks. The Commenters also state that the

calculations in the HRA did not follow standard HRA procedures and guidelines cited in the HRA.

Commenters are incorrect on both claims.

OEHHA identifies the HARP2 model as a software tool that can be used for health risk

assessments, but it does not require its use. The HRA used the procedures outlined in the OEHHA

and BAAQMD guidance for calculating cancer risk and other non -cancer impacts. The details ofthe cancer risk calculations are provided in Attachment 1 of the HRA for construction emissions

and Attachment 2 for operational emissions. The tables provided in the attachments include a

description of the calculations used, a listing of the specific exposure parameters and values usedfor the calculations, identification of the maximum modeled toxic air contaminant (" TAC")

concentrations used for the calculations, and the results of the calculations for each year of

exposure. The methods and equations used exposure parameters and values that are based on

OEHHA and BAAQMD guidance.

Moreover, as noted above, Illingworth & Rodkin conducted a supplemental health risk analysis

using the AERMOD model. That supplemental analysis, attached hereto as Exhibit A, similarlyconcludes that the Project will not result in any significant impacts related to health risk

Modeling Grid

The Commenters state that the HRA fails to disclose the location( s) of nearby sensitive receptors, points of maximum impact, or how they were identified. They also state that the HRA fails todisplay the results of its analysis on a map or identify the physical locations of the sensitivereceptors. Again, Commenters are incorrect with respect to these claims.

The physical locations of the nearby residential receptors, McDowell Elementary School receptorsand receptors at the preschools were identified from aerial mapping and are clearly shown in Figure1 of the HRA. Additionally, the locations where maximum health impacts (maximum cancer risk, maximum PM2. 5 concentration, and maximum non -cancer health impacts) for residential

receptors and school child/ dayeare receptors occur are also identified in Figure 1. The age of

children present at the daycare facilities was provided by the City of Petaluma Planning Staff andconfirmed by Safeway.

Since a health risk assessment is an assessment of chronic exposures, the receptor selection

included locations where children and residents would spend extended periods of time. Outdoor



areas would have relatively short exposure periods.

It is worth noting that the Commenters did not identify the type or location of sensitive receptorsused ( residential or school/ daycare child) in their modeling and did not identify the points ofmaximum impact in the modeling figures they provided in their report ( Fox/ Kapahi HRA, Figures4 and 5).

The Commenters claim that it is common practice to summarize health risks on isopleths maps

and that the absence of an isopleths map deprives the public and potentially affected parties ofdetermining if they are at risk.

Isopleths of cancer risk and PM2. 5 concentration are a useful way of graphically depicting the areaand extent of potential impacts from a project. The presentation of isopleths in a HRA is not a

regulatory requirement, rather, it is a useful means of presenting the results of the HRA. For thisProject, the maximum cancer risk and PM2. 5 impacts were below significance levels. Thus, there

were no areas where significant impacts would occur and the use of isopleths would not show anyareas of significant impact. Additionally, for the HRA modeling, individual sensitive receptorlocations were used with the modeling to identify the specific locations where sensitive receptorscould be potentially affected. Typically, if isopleths are going to be calculated, a large grid ofreceptors encompassing, the entire project area is needed to provide sufficient data resolution inorder for creating accurate isopleths. Thus, isopleths were not used as part of the presentation ofhealth impacts.

HRAs for Similar Facilities

The screening health risk analysis for the Cottle Safeway was conducted in 2012 and used theCARB' s Land Use and Air Quality Handbook and older emission factors developed by CAPCOAin 1997 that does not account for current control features that further reduce benzene emissions

from gasoline dispensing facilities. This effect was explained in Illingworth & Rodkin' s response

to ESA Comments on the HRA (Exhibit B). Furthermore, the analysis for the Cottle Safeway wasa screening level assessment to demonstrate that there would be no significant health risks. The

analysis also stated that " Subsequent to the CEQA process, BAAQMD would confirm this effect

prior to issuing their regulatory permit to construct such a facility, under Regulation 8, Rule 7." The Cottle gas station applied to BAAQMD in 2013 and subsequently opened in 2014 withappropriate permits.

Use of Dispersion Modeling and Evaluation of Community Health Risks in RecentEnvironmental Projects in Petaluma

Based on the City of Petaluma Planning Division' s website listing recent major developmentprojects ( http:// cityofpetaluma.net/ edd/ major- projects. html), the following projects were

identified:

Sid Commons Apartment Project (January 2018)* Davidson/ Scott Ranch Revised Draft Environmental Impact Report ( March 2018)*

Cagwin & Dorward Project ( June 2017)*



Spring Hill School Project (August 2017) North River Apartments Project ( August 2017)

Brody Ranch Residential Project September 2016)*

Of these six projects, four of them ( identified in the list with a *) had quantitative health risk

assessments prepared that utilized air quality dispersion modeling to evaluate impacts to addressthe exposure ofsensitive receptors to substantial pollutant concentrations. The remaining projectsdid not have detailed health risk assessments prepared. Potential health risks from these projects

were evaluated using health risk screening methods or qualitatively discussed. Each of the projectsis briefly discussed below.

Sid Commons Apartment Proms

The health risk assessment for this project relied on a previous study prepared for the project in2014. The air quality dispersion modeling for the 2014 study used the ISCST3 dispersion modelto calculate DPM concentrations for use in evaluating health impacts.

Davidson/ Scott Ranch Revised Draft Environmental Impact Report.

A Draft Environmental Impact Report was prepared for a residential development with 66 single-

family homes. A detailed health risk assessment was prepared to evaluate health impacts from

project construction activities. The air quality dispersion modeling for the study used the ISCST3dispersion model with 1990 — 1994 meteorological data from the Petaluma Airport to calculate

DPM concentrations for use in evaluating health impacts.

Cerin & Doi -ward Project.

An Initial Study/ Mitigated Negative Declaration was prepared for a new office/ landscapemaintenance operations facility including a 22, 724 square foot building for approximately 100employees, as well as parking for maintenance, trucks and trailers, and shop and warehouse spacefor vehicle maintenance. The project includes a 19, 440 square foot office building, and 2, 340square foot warehouse. A detailed health risk assessment was prepared to evaluate health impactsfrom project construction activities. The air quality dispersion modeling for the study used theISCST3 dispersion model with 1990 — 1994 meteorological data from the Petaluma Airport to

calculate DPM concentrations for use in evaluating health impacts.

Spring Hill School Project. An Initial Study/Mitigated Negative Declaration was prepared for the project which includes a 9to 12 month construction project to demolish an existing building and construct a new 7, 869 squarefoot building for classroom instruction at a middle school. Construction of the project would occurover a 9 to 12 month period. In addition to students at the Springhill School itself, the Valley Vista

Elementary School and Petaluma Junior High School are located directly northeast and west of theproject site, respectively. Residential land uses are also located in the nearby vicinity of the projectsite. Potential health risks to school children at the project site or other schools, as well as for

nearby residents, were not evaluated.

North River Apartments Project.

An Initial Study/ Mitigated Negative Declaration was prepared for the construction of twoapartment buildings. The nearest sensitive receptors to the project are elementary school studentsat a school that is 250 feet from the project site and residences that are about 175 feet west of the

Memo to Natalie Matted


project site. Although the project will have construction equipment exhaust PM10 emissions

diesel particulate matter, DPM) of 0. 22 tons per year during construction, which are 5. 4 timeshigher than,those for the Safeway Gas Station Project construction equipment, a quantitative healthrisk evaluation was not performed to assess health impacts on the elementary school students or

nearby residents. Health risks were stated to be a less than significant impact, without

quantification.

Brody Ranch Residential Project.

An Initial Study/ Mitigated Negative Declaration was prepared for this residential developmentproject with 199 residential units. A detailed health risk assessment was prepared to evaluate

health impacts from project construction activities. The air quality dispersion modeling for the

study used the ISCST3 dispersion model with 1990 — 1994 meteorological data from the Petaluma

Airport to calculate DPM concentrations for use in evaluating health impacts.

Summary

Based on review of recent City of Petaluma projects and to the best of our knowledge theAERMOD air quality dispersion model has not been used for modeling potential impacts from anyCEQA project in the City of Petaluma. This is primarily due to the lack of available, localmeteorological data needed by the AERMOD model. In lieu of using the AERMOD model, theISCST3 model is an EPA -refined dispersion model that is considered an alternative model that can

be used when approved by the reviewing regulatory agency ( i. e. BAAQMD).2

The current

BAAQMD modeling guidance recommends the use of either the AERMOD or ISCST3 modelsfor CEQA related health risk assessments. 3

Nonetheless, as noted above, Illingworth & Rodkin conducted a supplemental health risk analysis

using the AERMOD model. That supplemental analysis, attached hereto as Exhibit A, similarlyconcludes that the Project will not result in any significant impacts related to health risk

2 Guideline on Air Quality Models. Appendix W of 40 CFR Part 51. Recommended Methods for Screening and Modeling Local Risks and Hazards. Bay Area Air Quality Management DistrictBAAQMD). May 2012.

iiamionim

14

ILLIVGwoRTH& RommINC. WIN Acoustics • Air Quality ll

429 E. Cotati Ave

Cotati, California 94931

Tel: 707- 794- 0400 Fax: 707- 794- 0405

www. illingu, orthrodldn. com illro@illiiigworthrodldii. com

Date: October 10, 2018

To: Natalie Maffei






429 E. Cotati Ave

Cotati, CA 94931


SUBJECT: Safeway Fuel Center Health Risk Assessment — Updated Modeling Resultsusing U. S. EPA' s AERMOD Dispersion Model E# i, 13 205

This memo provides results of a newly -modeled health risk assessment (" HRA") for the Petaluma

Safeway Fuel Center (" Project") based on application of the U. S. EPA' s American Meteorological

Society (AMS)/ EPA Regulatory Model (" AERMOD") dispersion model. AERMOD is the U.S.

EPA' s preferred near -field dispersion modeling system, but requires enhanced meteorologicalinputs. The reasons for not using the AERMOD model previously were ( i) based on the lack ofsuitable meteorological data for the City of Petaluma ( while the Bay Area Air Quality ManagementDistrict [" BAAQMD"] provides suitable meteorological data for use in the Industrial Source

Complex Short -Term 3 [" ISCST3"] model, historically those data sets have not been suitable foruse in AERMOD), and ( ii) confirmation by BAAQMD and the City of Petaluma PlanningDepartment that use of the ISCST3 model was appropriate and acceptable for the Project.

Nevertheless, comments were received in September 2018 that suggested the AERMOD model

should have been used to assess the Project.

In addition, the updated modeling accounts for construction control requirements that include theuse of newer equipment with lower emissions. The September 2017 HRA assumed default

conditions.

Meteorological Data

In a letter from Phyllis Fox and Ray Kapahi dated September 17, 2018, a health risk assessmentofthe Project utilizing meteorological data from the City of Santa Rosa, California, was performed. Santa Rosa experiences different meteorological conditions than Petaluma and is not appropriate

for use at the Project site in Petaluma. Illingworth & Rodkin subsequently sought out

Natalie Mattei



meteorological data for the City of Petaluma that could be used in AERMOD.

Recently, new U.S. EPA modeling guidelines ( 40 CFR Part 51, Appendix W, effective February16, 2017) allows the use ofprognostic meteorological data using the U.S. EPA' s Mesoscale ModelInterface Program (" MMIF") pre-processor to generate inputs for regulatory modelingapplications using the meteorological preprocessor model (" AERMET") and AERMOD.

Prognostic meteorological data can be used when ( i) there is no representative National Weather

Service station data available for use in developing AERMOD meteorological data, and ( ii) site- specific data are not available. The U. S. EPA recommends using no fewer than three years ofmeteorological data for modeling when using prognostic modeled derived data for AERMOD. This new option now provides the opportunity to develop meteorological data suitable forAERMOD that are representative of the Project site.

The Weather Research and Forecasting (" WRF") grid model was used to develop a 5 -year data set2013 through 2017) for meteorological conditions at the Project site. The WRF model pulls in

observations and archived meteorological model data from the region around the Project site, and

uses the same physical equations that are used in weather forecasting to model the historicalweather conditions at the specific project location. Development of this data set was performed

by Lakes Environmental using the WRF model and the MMIF program to process data for inputto the AERMOD meteorological data preprocessor, AERMET. The WRIT modeling uses a nested

grid with a 4 -kilometer grid spacing at the highest resolution ( inner grid).

The wind data produced can be illustrated by a windrose that illustrates the joint frequencydistribution of wind flow ( by direction and speed). The " petals" of the windrose extend in the

direction that wind flows from. The windrose developed for modeling with AERMOD iscompared against the windrose from the available meteorological data obtained from BAAQMD

and used in ISCST3. The two data sets are comparable with a slightly greater westerly componentand less of a northerly component) depicted with the AERMOD data set.

Sale of Diesel Fuel

The sale of diesel fuel, which was not considered in the original Project HRA, was included in this

updated analysis. The sale of diesel fuel would add emissions of diesel particulate matter (" DPM")

from customer vehicles that travel to and from the Project and potentially idle at the Project site. There are negligible evaporative emissions from storage and transfer of diesel fuel. The same

assumptions for gasoline vehicle activity (i.e., travel and idling activity) were applied to dieselvehicles.

Emissions from diesel vehicles were computed based on the default travel fractions that the

EMFAC2014 model produces for the assumed mix of vehicles that would be served by the Project. Note that the Project would not serve heavy- duty necks or buses as the station design does notaccommodate the circulation of large vehicles. The vehicle mix generated by EMFAC2014includes 3. 6 percent diesel vehicles. This is consistent with Safeway estimates of diesel fuel salesand is conservative in that diesel sales at comparable Safeway gas stations in Pleasant Hill andCampbell only average approximately 2 percent of sales.

Natalie Mattei



Figure 1. Windrose for Petaluma

Assessment of Teachers

In accordance with CEQA and U. S. EPA guidelines, children at the preschools and nearby

residents were assessed as sensitive receptors. In September 2018, concerns were brought up aboutthe risk for preschool or school teacher/ workers. Although the exposure to teachers/ workers is

less than children and nearby residents, Illingworth & Rodkin assessed teachers/ workers in Table

1 below. The community risk impact to teachers/ workers is substantially below thresholds.


The 2017 HRA used unmitigated construction emissions computed using CalEEMod default

modeling conditions for the project. Safeway proposed a construction control plan that includedBAAQMD basic control measures for construction projects including use of Tier 2 dieselconstruction equipment along with a limit of diesel generator use. Subsequently, the PlanningCommission conditioned the project to use Tier 3 equipment. The updated modeling analysis

includes the effect of using diesel equipment that meets U. S. EPA Tier 3 standards.

Results of AERMOD Modeling

Table 1 provides results using the AERMOD model with diesel fuel sales and Table 2 providesthe original HRA results based on use of the ISCST3 model without diesel fuel sales. The results

shown in Table 1 demonstrate that the maximum Project health impacts would ( i) be consistent

with those results obtained using the ISCST3 model, and ( ii) below the applicable BAAQMDsignificance thresholds. The results from both the AERMOD and ISCST3 models conclude that

the Project will not result in any significant impacts related to health risk.

Figure 1 below shows the Project site, modeled truck and customer vehicle routes, sensitive

receptor locations used in the modeling, and locations where the maximum cancer risks and PM2.5

WRf 0, 41— w' dof : o17 Nil VP. d k'**°+ 6v«+.. a+( t+.,.t 6... rz, l04AtA PN><'° u+f a' ROII P-k M • WA& GN IIM, IPN) rrsn 7iIn-rvw i.' w v kamv)

iFY+ 1i1

MI

1

EaT

l1M1? 5in'

IY' A

Iti

41na=' f' tk4

Ir: xl

na

s5tn OfJ

vr. rn Ii v

tn- a. S liN

2013- 2017 data set produced for AERMOD at Project 1990- 1994 data set produced for ISCST3 for Petaluma

Site Municipal Airport 1 mile northeast of prqject site

Assessment of Teachers

In accordance with CEQA and U. S. EPA guidelines, children at the preschools and nearby

residents were assessed as sensitive receptors. In September 2018, concerns were brought up aboutthe risk for preschool or school teacher/ workers. Although the exposure to teachers/ workers is

less than children and nearby residents, Illingworth & Rodkin assessed teachers/ workers in Table

1 below. The community risk impact to teachers/ workers is substantially below thresholds.


The 2017 HRA used unmitigated construction emissions computed using CalEEMod default

modeling conditions for the project. Safeway proposed a construction control plan that includedBAAQMD basic control measures for construction projects including use of Tier 2 diesel

construction equipment along with a limit of diesel generator use. Subsequently, the PlanningCommission conditioned the project to use Tier 3 equipment. The updated modeling analysis

includes the effect of using diesel equipment that meets U. S. EPA Tier 3 standards.

Results of AERMOD Modeling

Table 1 provides results using the AERMOD model with diesel fuel sales and Table 2 providesthe original HRA results based on use of the ISCST3 model without diesel fuel sales. The results

shown in Table 1 demonstrate that the maximum Project health impacts would ( i) be consistent

with those results obtained using the ISCST3 model, and ( ii) below the applicable BAAQMDsignificance thresholds. The results from both the AERMOD and ISCST3 models conclude that

the Project will not result in any significant impacts related to health risk.

Figure 1 below shows the Project site, modeled truck and customer vehicle routes, sensitive

receptor locations used in the modeling, and locations where the maximum cancer risks and PM2. 5

Natalie Mattei



concentrations occur for nearby residents and preschool/ school children. Note the modeled truckand customer vehicle routes depict the original circulation pattern with trucks and vehicles

accessing the site through Maria Drive. This is a conservative scenario as the PlanningCommission imposed conditions restricting truck and vehicles from accessing the site throughMaria Drive which is the point of entry closest to the elementary school and preschools. The

maximum cancer risks and PM2.5 concentrations for preschool or school teacher/ workers wouldoccur at the same location where the maximum impacts would occur for preschool/ school children.

Figure 1— Project Site, Sensitive Receptor Locations, Project Vehicle Travel Routes, and

Locations of Maximum Cancer Risk and PM2. 5 Concentrations

532800 532850 532900 532950 533000 533050 533100 533150 533200 533250 53330

UVA - East ( meters)

Natalie Mattei


October 10, 2018 - Page 5

Table 1. Updated HRA Results Based on AERMOD Modeling

Receptor/ Source

Excess Cancer

Riskper million)

C nununity Risk Im' Annual PM2.5Concentration

M3)

act

Hazard Index

highest of Acute or

Chronic)

Residential ( 30 -year exposure

Construction Impacts 1. 06 0. 01 0. 00

Traffic TOG vehicle trips & idling) 1. 66 0. 00 0. 01

Traffic DPM vehicle trips & idling) 1. 38 0. 02 0. 00

Traffic DPM truck deliveries) 0. 03 0. 00 0. 00

Benzene fiom fuel evaporation) 1. 94 0. 00 0. 04

Total Project - Residential 6. 1 0. 03 0. 05

School Child ( 9 - year exposure)

School Child ( 9 -year exposure)

3. 2 0. 12 0. 02




Traffic DPM truck deliveries 0. 01 0. 00 0. 00

Benzene from fuel evaporation) 0. 16 0. 00 0. 02

Total Project - School Child 4. 0 0. 08 0. 05

Worker - Teacher ( 25 -year exposure)





Benzene fiom fuel evaporation) 0. 11 0. 00 0. 02

Total Project - Worker - Teacher 0. 50 0. 08 0. 05

Si ni tcance Threshold Project 10 0. 3 1. 0

Table 2. HRA Results Based on ISCST3 Modeling

Receptor/ Source

Excess Cancer

Risk

per million)

Community Risk ImAnnual PM2.5Concentration

M)

act

Hazard Index

highest of Acute or

Chronic

Residential ( 30 -year exposure)





Total Project - Residential 4. 0 0. 03 0. 10

School Child ( 9 - year exposure)

Construction Impacts 2014 3. 2 0. 12 0. 02




Total Project - School Child 3. 9 0. 13 0. 13

Si ni tcance Tlureshold Project 10 0. 3 1. 0

Attachment

Construction Health Risk Information

Safeway, Petaluma

Iwivi Uonstructton Emissions ana iviotienng Emission Rates - witn mitigation

Construction Homs

lir/ day = 9

days/ yr = 365

hours/ year = 3285

lam - 4pm)

rivtz. v ugitive t) ust uonstrucnon Emissions for mooeung - wun mitigation

DPM

Modeled Emission

Construction DPM Area DPM Emissions Area Rate

Year Activity ( ton/ year) Source ( lb/ yr) ( lb/ hr) ( g/ s) ( g/ s/ mz)

Emission

Construction Area PM2. 5 Emissions

2019 Construction 0. 0228 CON DPM 45. 6 0. 01388 1. 75E- 03 2, 956 5. 92E- 07

Construction Homs

lir/ day = 9

days/ yr = 365

hours/ year = 3285

lam - 4pm)

rivtz. v ugitive t) ust uonstrucnon Emissions for mooeung - wun mitigation

PM2.5

Modeled Emission

Construction Area PM2. 5 Emissions Area Rate

Year Activity Source ( ton/ year) ( lb/ yr) ( lb/hr) ( g/ s) zm) g/ s/ m z

2019 Construction CON ' FUG 0. 00071 1. 4 0. 00043 5. 45E- 05 2, 956 1. 84E- 08

Construction Homs

hr/ day = 9 ( lam - 4pm)

days/ yr= 365

hours/ year = 3285

Safeway - Petaluma - Construction Impacts

ISCST3 Modeling

Maximum DPM Cancer Risk Calculations From Construction

Off -Site Residential Receptor Locations - 1. 5 meters

Cancer Risk ( per million) = CPF x inhalation Dose x ASF x ED/ AT x FAH x I. OE6

Where: CPF = Cancer potency factor ( mg/ kg -day)-'

ASF = Age sensitivity factor for specified age groupED = Exposure duration ( years)

AT = Averaging time for lifetime cancer risk ( years) FAH = Fraction of time spent at home ( unitless)

Inhalation Dose = C,;, x DBR x A x ( EF/365) x 10- 6

Where: C,;, = concentration in air ( pg/ nt3)

DBR= daily breathing rate ( L/ kg body weight - day) A = Inhalation absorption factor

EF = Exposure frequency ( days/ year)

10- 6 = Conversion factor

Values

95th percentile hreathing rates for infants and 80th percentile for children and adults

Construction Cancer Risk by Year - Maximum Impact Receptor Location

Infant/ Child Adult

Age -> 3rd Trimester 0- 2 2- 9 2- 16 16- 30

Parameter

ASF = 10 10 3 3 1

CPF = 1. 10E+ 00 1. 10E+ 00 1. 10E+ 00 1. 10E+ 00 1. 10E+ 00

DBR*= 361 1090 631 572 261

A= 1 I I 1 1

EF = 350 350 350 350 350

AT= 70 70 70 70 70

FAH= 1. 00 1. 00 1. 00 1. 00 0. 73

95th percentile hreathing rates for infants and 80th percentile for children and adults


Third trimester of pregnancy

Fugitive Total

PD12. 5 PM2. 5

0. 0003 0. 009

Infant/ Child- ExposureInformatio Infant/ Child Adult - Exposure Information Adult

Modeled AgeExposure Age Cancer Cancer

DPM Cone ( ug/ m3) Exposure DurationDPM Cole( ug/ m3) Sensitivity Risk Sensitivity Risk

Year7 AnnualYear years) Age Year Annual Factor per million) Factor per million)

0 0. 25 0. 25 - 0* 10

1 1 0- 1 2019 0.0083 10 1. 36 2019 0.0083 I 0.02

2 1 1- 2 0.0000 10 0. 00 0. 0000 1 0.00

3 I 2- 3 0. 0000 3 0. 00 0.0000 1 0.00

4 1 3- 4 0.0000 3 0. 00 0.0000 I 0.00

5 1 4- 5 0. 0000 3 0. 00 0.0000 I 0.00

6 1 5- 6 0.0000 3 0. 00 0.0000 1 0.00

7 1 6- 7 0.0000 3 0. 00 0. 0000 1 0. 00

8 1 7- 8 0. 0000 3 0. 00 0. 0000 1 0. 00

9 1 8- 9 0. 0000 3 0.00 0. 0000 1 0. 00

10 1 9- 10 0. 0000 3 0. 00 0. 0000 1 0. 00

11 1 10- 11 0. 0000 3 0. 00 0. 0000 1 0. 00

12 1 11- 12 0. 0000 3 0. 00 0. 0000 1 0. 00

13 I 12- 13 0. 0000 3 0.00 0. 0000 1 0. 00

14 1 13- 14 0.0000 3 0. 00 0. 0000 1 0. 00

15 I 14- 15 0. 0000 3 0. 00 0.0000 1 0.00

16 1 15- 16 0.0000 3 0.00 0. 0000 I 0.00

17 1 16- 17 0.0000 1 0. 00 0. 0000 1 0.00

18 1 17- 18 0.0000 I 0. 00 0.0000 1 0. 00

19 1 18- 19 0.0000 1 0. 00 0. 0000 l 0. 00

20 1 19- 20 0. 0000 1 0. 00 0.0000 1 0.00

21 1 20- 21 0. 0000 1 0. 00 0. 0000 1 0.00

22 1 21- 22 0. 0000 1 0. 00 0. 0000 1 0.00

23 1 22- 23 0.0000 1 0.00 0. 0000 1 0.00

24 1 23- 24 0.0000 1 0. 00 0. 0000 1 0.00

25 1 24- 25 0.0000 I 0.00 0. 0000 1 0. 00

26 1 25- 26 0.0000 1 0.00 0. 0000 1 0. 00

27 1 26- 27 0.0000 1 0. 00 0.0000 I 0.00

28 I 27-28 0.0000 1 0. 00 0. 0000 1 0.00

29 1 28-29 0.0000 1 0. 00 0. 0000 I 0. 00

301

1 29- 30 0.0000 1 0. 00 0. 0000 1 0. 00

Total Increased Cancer Risk 1. 4 0. 02

Third trimester of pregnancy

Fugitive Total

PD12. 5 PM2. 5

0. 0003 0. 009


ISCST3 ModelingMaximum DPM Cancer Risk Calculations From Construction

Daycare/ School Child Receptor Locations

Cancer Risk ( per million) = CPF x Inhalation Dose x ASF x ED/AT x FAH x I. OE6

Where: CPF = Cancer potency factor (mg/kg -day)-' ASF = Age sensitivity factor for specified age group „ ED = Exposure duration ( years)

AT= Averaging time for lifetime cancer risk (years) FAH = Fraction of time spent at home ( unitless)

Inhalation Dose = C.., x DBR x A x ( EF/ 365) x 10- s

Where: CoR= concentration in air ( gghn )

DBR = daily breathing rate ( lAg body weight -day) A= Inhalation absorption factor


104 = Conversion factor

Values

95th percentile breathing rates for infants and 80th percentile for children and adults


Exposure

Year

Exposure

Duration

years)

Infant/ Child

Infant/ Child

Cancer

Risk

per million)

Adult- Exposure Information

Adult

Age --> 3rd Trimester 0- 2 2- 9 2- 16 16- 30

Parameter

2019 0. 1129 3 3. 22

3. 22

2019

ASF = 10 10 3 3 1

CPF = 1. 10E+ 00 I. IOE+ 00 1. 10E+ 00 1. 10E+ 00 1. 10E+ 00

DBR* = 361 1090 631 572 261

A= 1 1 1 1 1

EF = 350 350 350 350 350

AT= 70 70 70 70 70

FAH = 1. 00 1. 00 1. 00 11. 00 0. 73

95th percentile breathing rates for infants and 80th percentile for children and adults


Exposure

Year

Exposure

Duration

years)

Infant/ Child - Exposure Informatio

Age

DPM Cone ( ug/ m3) SensitivityAge Year Annual Factor

Infant/ Child

Cancer

Risk

per million)

Adult- Exposure Information Adult

Cancer

Risk

per million

Modeled Age

SensitivityFactor

DPM Cone ( ug1m3)

Year I Annual2019 I 5- 6

Total Increased Cancer Risk

2019 0. 1129 3 3. 22

3. 22

2019 0. 1129 1 0. 32

0. 32

Fugitive Total

PD12. 5 PI%12. 5

0. 0051 0. 118


AERMOD ModelingMaximum DPM Cancer Risk Calculations Front Construction

Off -Site Residential Receptor Locations - 1. 5 meters

Cancer Risk ( per million) = CPF x Inhalation Dose x ASF x ED/AT x FAH x I. OE6

Where: CPF = Cancer potency factor (mg/kg -day)-' ASF = Age sensitivity factor for specified age groupED = Exposure duration ( years)

AT = Averaging time for lifetime cancer risk (years) FAH = Fraction of time spent at home ( unitless)

Tnhalation Dose = C,;, x DBR x A x ( EF/ 365) x 10- 6

Where: C,;, = concentration in air ( pg/ m3)

DBR = daily breathing rate ( L/kg body weight -day) A = Inhalation absorption factor



Values

95th pe - mile breathing rates for infants and 80th percentile for child- and adults


Infant/Child Adult

Age -> 3rd Trimester 0- 2 2- 9 2- 16 16- 30

Parameter

ASF = 10 10 3 3 1

CPF = 1. 10E+ 00 1. 10E+ 00 1. 10E+ 00 1. 10E+ 00 1. 10E+ 00

DBR* = 361 1090 631 572 261

A= I I I 1 I

EF = 350 350 350 350 350

AT= 70 70 70 70 70

FAH = 1. 00 1. 00 1. 00 1. 00 0. 73

95th pe - mile breathing rates for infants and 80th percentile for child- and adults


Third trimester ofpregnancy

Fugitive Total

PM2. 5 PM2. 5

0. 0002 0. 0067

Infant/ Child - Exposure Infinmatitu Infant/ Child Adult - Exposure Information Adult

Modeled AgeExposure Age Cancer Cancer

DPM Cone ( ug/ m3) Exposure Duration DPM Cone ( u / m3) Sensitivity Risk Sensitivity Risk

Year AnnualYear years) Age Year Annual Factor per million) Factor per million)

0 0. 25 0. 25 - 0* 10

1 1 0 - 1 2019 0. 0064 10 1. 06 2019 0.0064 1 0.02

2 1 1- 2 0.0000 10 0.00 0.0000 1 0.00

3 1 2- 3 0.0000 3 0.00 0.0000 1 0.00

4 1 3- 4 0. 0000 3 0.00 0.0000 1 0.00

5 1 4- 5 0:0000 3 0.00 0.0000 1 0.00

6 1 5- 6 0. 0000 3 0. 00 0.0000 1 0.00

7 1 6- 7 0. 0000 3 0. 00 0.0000 1 0. 00

8 1 7- 8 0. 0000 3 0. 00 0.0000 1 0.00

9 1 8- 9 0. 0000 3 0. 00 0.0000 1 0.00

10 1 9- 10 0. 0000 3 0.00 0. 0000 1 0.00

11 1 10- 11 0. 0000 3 0.00 0.0000 1 0.00

12 I 11 - 12 0. 0000 3 0.00 0.0000 1 0. 00

13 1 12- 13 0. 0000 3 0. 00 0.0000 1 0.00

14 1 13- 14 0.0000 3 0.00 0.0000 1 0. 00

15 1 14- 15 0. 0000 3 0. 00 0. 0000 1 0.00

16 1 15- 16 0. 0000 3 0.00 0.0000 1 0.00

17 1 16- 17 0. 0000 1 0.00 0. 0000 1 0. 00

18 1 17- 18 0. 0000 1 0.00 0.0000 1 0. 00

19 1 18- 19 0. 0000 1 0.00 0.0000 1 0. 00

20 1 19- 20 0. 0000 1 0. 00 0. 0000 l 0. 00

21 1 20- 21 0. 0000 1 0.00 0.0000 1 0. 00

22 1 21- 22 0.0000 1 0.00 0. 0000 1 0. 00

23 1 22- 23 0. 0000 1 0.00 0. 0000 1 0. 00

24 1 23- 24 0.0000 1 0.00 0. 0000 1 0. 00

25 1 24- 25 0.0000 1 0. 00 0. 0000 1 0. 00

26 1 25- 26 0.0000 1 0. 00 0. 0000 1 0. 00

27 1 26- 27 0.0000 1 0. 00 0. 0000 1 0.00

28 1 27- 28 0.0000 1 0.00 0.0000 1 0.00

29 1 28- 29 0.0000 1 0. 00 0. 0000 1 0. 00

301

1 29- 30 0. 0000 1 0. 00 0. 0000 1 0. 00

Total Increased Cancer Risk 1. 06 0. 02


Fugitive Total

PM2. 5 PM2. 5

0.0002 0. 0067


AERMOD ModelingMaximum DPM Cancer Risk Calculations From Construction

Daycare/ School Child Receptor Locations

Cancer Risk ( per million) = CPF x Inhalation Dose x ASF x ED/AT x FAH x LOE6

Where: CPF = Cancer potency factor (mg/kg -day)-' ASF = Age sensitivity factor for specified age groupED = Exposure duration ( years)

AT = Averaging time for lifetime cancer risk ( years) FAH = Fraction of time spent at home ( mritless)

Inhalation Dose = C,;, x DBR x A x (EF/ 365) x 10

Where: C,;,= concentration inair ( pg/ m3)

DBR = daily breathing rate ( Llkg body weight - day) A = Inhalation absorption factor


10' 8 = Conversion factor

Values

95th pesentile breathing nat a for ini is and 80th percentile for children and adults


Exposure

Year

Infant/ Child Adult

Age —> 3rd Trimester 0- 2 2- 9 2- 16 16- 30

Parameter

ASF = 10 10 3 3 I

CPF= 1. 10E+ 00 1. 10E+ 00 1. 10E+ 00 1. 10E+ 00 1. 10E+ 00

DBR* = 361 1090 631 572 261

A= I I I I l

EF -

1350 350 350 350 350

AT= 70 70 70 70 70

FAH = 1. 00 1. 00 1. 00 1. 00 0. 73

95th pesentile breathing nat a for ini is and 80th percentile for children and adults


Exposure

Year

Exposure

Duration

years)

Infant/ Child - Exposure Informatio

Age

DPM Cone ( u / nr3) SensitivityAge Year Annual Factor

Infant/ Child

Cancer

Risk

per million)

Adult - Exposure Information Adult

Cancer

Risk

per million)

Modeled Age

SensitivityFactor

DPM Conc ( ug/ m3

2019 1 5- 6

Total Increased Cancer Risk

2019 0. 0697

13 1. 99

1. 99

2019 0. 0697 1 0. 20

0. 20

Fugitive Total

PX12. 5 PA12. 5

0. 0025 0.072

Operational Emissions Modeling, Dispersion Modeling Information, and Health Risk Calculations

Vehicle Idle Emissions From Queing at Gas Station

EMFAC2014 ( 0.0. 7) Emission Rates

Region Type: County

Region: Sonoma

Calendar Year: 2019

Season: Annual

Units: miles/ day forVMT, g/ mile for RUNEX, PMBW and PMTW

Assumed % CO2_ RUNEX(

Area CalYr ' Season Veh Fuel Speed VMT of Vehicles ROG_ RUNEX TOG_ RUNEX NOX_ RUNEX Pavley l+ LCFS) PM10_ RUNEX PM2_ 5_ RUNEX

Sonoma 2019 Annual LDA GAS 5 0. 58 0.0949 0. 1383 0. 1376 922. 5062 0. 0118 0. 0109

Sonoma 2019 Annual LDA DSL 5 0. 01 0.2849 0.3243 0.2861 721. 2901 0. 0918 0.0878

Sonoma 2019 Annual LDTS GAS 5 0. 05 0. 2184 0. 3153 0. 3473 1098. 2722 0. 0172 0.0158

Sonoma 2019 Annual LDT1 DSL 5 0 0. 9391 1. 0691 0.8146 957. 4096 0. 6896 0. 6598

Sonoma 2019 Annual LDT2 GAS 5 0.18 0. 1247 0. 1810 0.2264 1240. 5727 0. 0115 0. 0106

Sonoma 2019 Annual LDT2 DSL 5 0 0.2691 0. 3063 0. 1883 882. 2919 0. 0296 0. 0283

Sonoma 2019 Annual MDV GAS 5 0.12 0.2850 0. 3994 0.4497 1665. 3488 0. 0122 0.0112

Sonoma 2019 Annual MDV DSL 5 0 0.2141 0. 2438 0.1690 1094. 7699 0. 0240 0.0229

Sonoma 2019 Annual MCY GAS 5 0.01 13. 7447 16. 6018 1. 5620 543. 2175 0. 0104 0. 0097

Sonoma 2019 Annual LHDT1 GAS 5 0.02 0.49548 0. 71731 0. 85168 1400. 99808 0. 01178 0. 01083

Sonoma 2019 Annual LHDT1 DSL 5 0.02 0. 83210 0. 94729 3. 81068 1290. 25429 0.13931 0. 13328

Sonoma 2019 Annual LHDT2 GAS 5 0 0. 19449 0. 28380 0. 48389 1482. 32785 0.00715 0. 00657

Sonoma 2019 Annual LHDT2 DSL 5 0. 01 0.77184 0. 87869 2. 66373 1345. 06716 0. 09704 0. 09284

Sonoma 2019 Annual . 100%

0. 297 0. 388 0. 330 1093. 033 0.016 0. 015

IdleVehicle Emission Rate= 1. 486 1. 939 1. 651 5465. 165 0. 081 0. 076

gram/ hr based ao5 ph emEslan ratefor i hours mlles)

Assume 12 vehicles constantly Idling per peak demand hour= 17. 83 23. 27 19. 82 65581. 97 0. 98 0. 91

gram/ hr

Assume peak demand hour is SO% of dally emission rate= 178. 29 232. 68 198. 16 655819. 75 9. 77 9. 09

gram/ day

0. 07 0. 09 0.08 239. 16 0. 004 11. 104

tons/ yea r ( metric tons COie)

Source of Id le e missions ( from GARB, see http:// v . orb- gov/ msellmodeling. him)

Idling Emission Rates for EMFAC2011- LDV Vehicle Categoriesstep 1 - Extract 5 MPH Runnlog emission rates from Emission Rate Web Database at

http:/ A-.., b. ca. govt,p. b/ webapp// EM FAC2011W ebApp/. tesel. tl. nPage_ 3. JIP.

Step 2- CaWate the by model year IDV Idling emlW an rates by mult] pM, g the 5 MPH Runningemission rates by 5 klmlle X mile/ hr= g/ hr).

d Fd

Vehicle Idle Emissions From Clueing at Gas Station

EMFAC2014 ( v1. 0. 7) Emission Rates

Region Type: County

Region: Sonoma

Calendar Year: 2019

Season: Annual

Units: miles/ day for VMT, g/ mile for RUNEX, PMBW and PMTW

Area CalYr Season Veh Fuel Speed VMT

Assumed %

of Vehicles TOG Evap RL

Sonoma 2019 Annual LDA GAS 5 0. 58 0,048473207

Sonoma 2019 Annual LDA DSL 5 0. 01 0

Sonoma 2019 Annual LDT1 GAS 5 0. 05 0. 313470559

Sonoma 2019 Annual LDT1 DSL 5 0 0

Sonoma 2019 Annual LDT2 GAS 5 0, 18 0. 101229584

Sonoma 2019 Annual LDT2 DSL 5 0 0

Sonoma 2019 Annual MDV GAS 5 0. 12 0. 161045132

Sonoma 2019 Annual MDV DSL 5 0 0

Sonoma 2019 Annual MCY GAS 5 0. 01 1. 031992068

Sonoma 2019 Annual LHDT1 GAS 5 0, 02 0.928532625

Sonoma 2019 Annual LHDT1 DSL 5 0. 02 0

Sonoma 2019 Annual LHDT2 GAS 5 0 0. 390995228

Sonoma 2019 Annual LHDT2 DSL 5 0. 01 0

Average 5 mph Emission Rate 100% 0. 110

IdleVehicle Emission Rate = 0. 551

gram/ hr

Assume 12 vehicles constantly idling per peak demand hour = 6. 61

gram/ hr

Assume peak demand hour is 10% of daily emission rate = 66. 14

gram/ day

ource of idle emissions ( from CARE, see http:// www. arb. ca. govlmseilmodeling. htm )

cling Emission Rates for EMFAC2011- LDV Vehicle Categories

ep 1 — Extract 5 MPH Running emission rates from Emission Rate Web Database attp:// www. a rb. ca. gov/ jpub/ weba pp// EM FAC2011W ebApp/ rateSelectionPage_ Lisp.

ep 2— Calculate the by model year LDV Idling emission rates by multiplying the 5 MPH Running emission ratesj 5 ( g/ mile X mile/ hr = g/ hr).

Diesel Vehicle DPM Idle Emissions From Clueing at Gas Station

EMFAC2014 (v1. 0. 7) Emission Rates

Region Type: CountyRegion: Sonoma

Calendar Year: 2019

Season: Annual

Units: miles/ day for VMT, g/ mile for RUNEX, PMBW and PMTWAssumed

of Diesel DPM

Area CalYr Season Veh Fuel Speed VMT Vehicles PM2 5 RUNEX

Sonoma 2019 Annual LDA GAS 5 0 0. 0109

Sonoma 2019 Annual LDA DSL 5 0. 2077 0. 0878

Sonoma 2019 Annual LDT1 GAS 5 0 0.0158

Sonoma 2019 Annual LDT1 DSL 5 0. 0016 0. 6598

Sonoma 2019 Annual LDT2 GAS 5 0 0. 0106

Sonoma 2019 Annual LDT2 DSL 5 0. 0088 0.0283

Sonoma 2019 Annual MDV GAS 5 0. 0112

Sonoma 2019 Annual MDV DSL 5 0. 056 0. 0229

Sonoma 2019 Annual MCY GAS 5 0 0. 0097


Sonoma 2019 Annual LHDTS DSL 5 0. 5698 0. 13328


Sonoma 2019 Annual LHDT2 DSL 5 0. 1558 0. 09284

Sonoma 2019 Annual 100%

0. 111

IdleVehicle Emission Rate = 0. 556

based on 5 mph emission rate for 1 hour ( 5 miles) gram/ hr

Assume 0. 432 ( 3. 6% of 12/ hour) vehicles constantly idling per peak demand hour = 0. 24

4% of all vehicles are diesel) gram/ hr

Assume peak demand hour is 10% of daily emission rate = 2. 40

gram/ day

Hourly rate based on GDF operotion fc

Source of idle emissions ( from CARE, see http:// www. arb. ca. gov/ msei/ modeling. htm )

Idling Emission Rates for EMFAC2011- LDV Vehicle CategoriesStep 1 — Extract 5 MPH Running emission rates from Emission Rate Web Database at

http:// www. arb. ca. gov/ jpub/ webapp// EMFAC20ilW ebApp/ rateSelectionPage_ 1. jsp.

Step 2— Calculate the by model year LDV idling emission rates by multiplying the 5 MPH Runningemission rates by 5 ( g/ mile X mile/ hr = g/ hr).

lehicle DPM Exhaust Emission Factor Calculations

composite DPM Emission Factor ( g/ VMT)

No. diesel vehicle trips

35, 054

Total Project Veh Diesel VMT= 302645

Total Project Veh Gas VMT= 8196407 984, 405 = No. Total project trips/ year

Total Project Veh Type VMT= 8499052 3. 6% % diesel based on tf trips

Safeway, Petaluma - Operational Emissions - Customer Vehicle Travel DPM Emissions

Line

Source

Name

vehicle

Type

Diesel VMT Project Ann Diesel Veh DPM

Annual

Diesel VMT Fraction of Fraction of Diesel Veh Project Trips Emission

Vehicle Fraction All Diesel of All Proj Type Based on Factor

Type of Class VMT Vehicles VMT Distribution VMT Fraction g/ VMT)

LDA 0. 012541755 0.20769489 0.0073959 0. 208 7, 281 0. 024008291

LDT1 0. 002363006 0.00155173 0. 0000553 0. 002 54 0. 182301927

LDT2 0. 001406215 0.00882815 0.0003144 0.009 309 0.00937924

LHDT1 0. 545068081 0.56977774 0. 0202894 0. 570 19,973 0.046698045

LHDT2 0. 678912473 0. 155812 0.0055484 0. 156 5, 462 0. 034327422

MDV 0. 011766193 0. 05633521 0.0020061 0.056 1, 975 10. 008876395

0. 03781

11

1876 0. 36 0. 52 7. 48E- 05

Total 1. 00 0. 03561 1. 00 35,054

composite DPM Emission Factor ( g/ VMT)

No. diesel vehicle trips

35, 054

Total Project Veh Diesel VMT= 302645

Total Project Veh Gas VMT= 8196407 984, 405 = No. Total project trips/ year

Total Project Veh Type VMT= 8499052 3. 6% % diesel based on tf trips

Safeway, Petaluma - Operational Emissions - Customer Vehicle Travel DPM Emissions

Default EMFAC2014 vehicle mix for diesel vehicles ( LDA, LDT1, LDT2, LHDTI, LHDT2, and MDV)

Annual one- way trips

3 Emission factors developed from EMFAC2014 for Sonoma County

4 Station operation assumed to be from 5 am to 12 am, 365 days per year

Safeway, Petaluma - Operational Emissions - Fuel Delivery Truck DPM Emissions 2019

Line

Source

Name

vehicle

Type

Annual

Trips'

Daily

Operation

Schedule

los/day)

PM2. 5

Annual

Average Hourly Emissions( ih/ hr) 4

Annual Average

TOG Start

Exhaust

trip)

Line

Emissions

TOG

Exhaust

Number

Emissions Average Hourly

Operation

TOG

Starting

Exhaust

DPM Hourly

Factors'

Source Truck

Ib/year) Emissions ( lb/hr)4

Total

Factor' Schedule Travel Distance

Line

Emissions

Annual Operation' Round Trip

Name

Source Vehicle Diesel DPM Schedule Travel Distance Total Total

feet) miles) Route Name Type' Trips' VMT hrs/ da) DPM DPDI

West Route West Diesel 35, 054 0.0378 19 2695 0. 51 0. 75 1. 08E- 04

East Route East Diesel 35, 054 0.0378 19 1876 0. 36 0. 52 7. 48E- 05

Default EMFAC2014 vehicle mix for diesel vehicles ( LDA, LDT1, LDT2, LHDTI, LHDT2, and MDV)


3 Emission factors developed from EMFAC2014 for Sonoma County

4 Station operation assumed to be from 5 am to 12 am, 365 days per year

Safeway, Petaluma - Operational Emissions - Fuel Delivery Truck DPM Emissions 2019

HHDT = heavy heavy duty truck

Annual trips - Based on 365 days of operation

l Emission factor from EMFAC2014 for Sonoma County for operation in 2019 and assumes all trucks me diesel.

4 Gas truck delivery hours assumed to be 24 hours per day, 365 days per year

Safeway, Petaluma - Operational Emissions - Customer Vehicle Travel

Route

Line

Source

Name

vehicle

Type

Annual

Trips'

Daily

Operation

Schedule

los/day)

PM2. 5

Annual Emissions( lb/ year) Average Hourly Emissions( ih/ hr) 4

Annual Average

TOG Start

Exhaust

trip)

Line

Total

PA12, 5

TOG

Exhaust

Number Total Emission Operation

TOG

Starting

Exhaust

DPM Hourly

miles)

Source Truck Vehicle Round Annual Factor' Schedule Travel Distance Emissions Emissions

feet) miles) Truck Route Name Deliver Type Trucks Trips' Waal) hrs/ da) lb/ ear) lb/ hr)

Gas truck Route TRUCKS Gas Station HHDT 2 730 0. 03221 24 3132 0.59 0. 031 3. 51E- 06

HHDT = heavy heavy duty truck

Annual trips - Based on 365 days of operation

l Emission factor from EMFAC2014 for Sonoma County for operation in 2019 and assumes all trucks me diesel.

4 Gas truck delivery hours assumed to be 24 hours per day, 365 days per year

Safeway, Petaluma - Operational Emissions - Customer Vehicle Travel

Route

Line

Source

Name

vehicle

Type

Annual

Trips'

Emissions Factors'

Operation

Schedule

los/day)

Round TripTravel Distance

Annual Emissions( lb/ year) Average Hourly Emissions( ih/hr)4Total

PM2. 5

M[ T)

TOG

Exhaust

h[ T)

TOG Start

Exhaust

trip)

TOG

Run Loss

V11ST)

Total

PA12, 5

TOG

Exhaust

TOG'

Starting

Exhaust

TOG

Running

Loss

Total

PDt2. 5

TOG

Exhaust

TOG

Starting

Exhaust

TOG

Running

Losse[) miles)

West Route

East Route

West

East

Default

Default

984, 405

984, 405

0. 0217

0. 0217

0. 0467

0. 0467

0. 2632

0. 2632

0. 1196

0. 1196

19

19

2695

76

0. 51

0. 36

12

8

26

18

286

286

66

46

1. 73E- 03

1. 21E- 03

3. 73E- 03

2. 60E- 03

4. 12E- 02

4. 12E- 02

9. 55E- 03

6. 65E- 03

Default EMFAC2014 vehicle mix for IDA, LDT, and MDT


Emission factors developed fmm EMFAC2014 for Son,= County

4 Station ope, ntion assumul to be fiom 5 am to 12 am, 365 day peryear

starting emissions occur at gas station, assumed to occur once per round trip

EVALUATION REPORT

Safeway Fuel Center ; 83011

Facility TDr200026Application 4405215

S. McDoAvell Blvd & Maria Drive, Petaluma, CA 94954

BACKGROU\ I)

Safeway hie. has subulitted this application to construct a new gasoline dispensing facility — Safeway

Fuel Center # 3011

This station is within 1. 000 feet of McDowell Elementarlr School and the project increases Precursor

Organic Compound ( POC) and Benzene emissions. Thus, the projects trigger the Public Notice

requirements under California Health &C Safety Code and District' s Regulation 2- 1412.

The facility will be equipped with two ( 2) 20, 000. Qallon underground storage tanks, eight ( 8) triple - product gasoline nozzles Phase I CN=I EVR. Phase II VST Balance with Veeder Root Vapor Polisher and

Veeder- Root ISD EVR.

A Health Risk Screening Analysis ( HRSA) was perfoinied for this application indicates that a throughputof 25. 71 inillion- trallons per year is acceptable per District' s Risk Management Policy. Accordingly, thisstation will be conditioned to 25. 71 million gallons per year.

Before this project call be approved, a 30 -day public cormnent period will be held. Notice describing theproject and announcing the public comment period will be mailed to the parents of students attending theabove schools and residential and business neighbors within 1, 000 feet of the . station. The cost of

preparing and distributing this notice will be paid by the applicant.

EMISSIOi\ CALCULATIONS

Emission factors are taken from the Gasoline Service Station Industry -wide Risk Assessment Guidelines

developed by the California Air Pollution Officers Association' s ( CAPCOA) Toxics Cbuunittee_

Emissions of Precursor Organic Compound ( POC) include emissions from loading, breathing, refrftelingand spillage. The annual gasoline throughput of 25. 71 mlillion gal per year is based oil the results of the

Air Toxics Risk Screening.

Table 1 - Emissions Calculation

Pollutant Emissions Factors Emissions Emissions Emissions

lbAllousand ballon) lb/ day) lb, ear) ton year)

POC 0. 670 4719 17,_' 25. 7 8, 613

Benzene 0. 00369 0, 26 94, 87 0, 047

BEST AVAILABLE CONTROL TECHNOLOGY ( BACT

The proposed mutual throughput ennits more than 10 pounds of VOC in a single day. Thus the Best

Available Control Teclniolog.y ( BACT) requirement of Regulation 2- 2- 301 is triggered.

SACT for Gasoline Dispensing Facilities ( GDFs) is considered the use of C' ARB- certified Phase - I and

Phase -H vapor recovery equipment. r

Safeway Fuel Center 43011 will meet the requirement by using CNI EVR Phase I equipment and VSTBalance EVR Phase II equipment with the Veeder- Root Vapor Polisher and Veeder- Root ISD controls.

These two systems are certified by GARB raider Executii e Orders VR -104 and VR -204 respectively.

BEST AVAILABLE CONTROL TECHNOLOGY FOR TOXICS ( TRACT)

The expected increased health risk from this project exceeds 1 per million; triggering the use of TBACTequipment. TBACT for GDFs is considered the use of GARB - certified Phase - I and Phase- lI vapor

recovery equipment.

Safeway Fuel Center 03011 will meet this through the use of CNI EVR Phase I equipment and VSTBalance EVR Phase II equipment with the Veeder- Root Vapor Polisher and Veeder- Root ISD controls.

The two systems are certified by GARB under Executive Order VR -104 and VR -204 respectively.

HEALTH RISK SCREENING ANALYSIS ( HRSA)

An HRSA was required since the increased benzene emissions exceed the toxic air contaminant risk

triggering level specified in Regulation 2- 5 table 2- 5- 1. For a GDF that meets the TBACT requirement. itmust also pass the toxic risk screening level of less thavn ten in a million. The facility meets the riskstandards with 25. 71 mullion gallons of annual throughput.

PUBLIC NOTIFICATION

This Station is within 1, 000 feet of McDowell Elementary School and the project increases einnissions.

Thus, the projects trigger the Public Notice requirements under California Health S, Safety Code tend

District' s Regulation 2- 1- 412. Before this project can be approved, a 30 -day public continent period willbe held. Notice describing the project and announcing the public continent period will be mailed to the

parents of students attending the above schools and people living within 1, 000 feet of the station. The costof preparing and distributing this notice will be paid by the applicant-

Safeway, Petaluma - Operational Emissions - Gas Station Benzene Emissions

Annual

Gasoline Annual

Benzene

Emission Operation"

Benzene Emissions

Annual Average

Throughput ROG Emissions Factor Schedule Average Hourly

Source ( 10' gallons/ year) Ib/ year) Ib/ 103 Gallon) lirs/ day) lb/ year) lb/ hr)

16 -Pump Fuel Station 8, 500 5, 695 0. 00369 19 31. 4 0. 00452

Notes:

1. BAAQMD 2013. Authority to Construct for Permit Application No. 405215 at S. McDowell Blvd & Maria Drive, Petaluma, CA 94954. Dated October 10, 2013.

2. Daily operation hours assumed to be 5: 00 AM to 12: 00 AM, 365 days per year

Gas Station Modeling Emissions and Volume Source Parameters

Operation

Number of

Volume

Sources

Annual Eudssions lb

Total Average Number of Emissions Volume Source Dimensions Volume Source'

Percent of Hourly Emissions Volume per Volume meters) Release Height

Emission Source Total Emissions ( Ib/ hr) Sources Ib/ hr) Length Width Height meters)

Pefueling 67% 0. 0030 4 0. 00076 13. 0 13 4 1

Spillage 33% 0. 0015 4 0. 00037 13 13 4 0

Notes:

1. CAPCOA Air Toxics " Hot Spots" Program, Gasoline Service Station Industrywide Risk Assessment Guidelines, November 1997.

Safeway, Petaluma - Operational Emissions - Gas Station Customer TOG and PM2. 5 Emissions

Annual Operation

Number of

Volume

Sources

Annual Eudssions lb year)

Length

vera a Hour l Emissions Ob/ hour)

Height

PM2. 5 TOG TOG TOG PM2. 5 TOG TOG TOG

Vehicles Schedule Idle Idle Starting Running Total Idle Idle Starting Running

Source ( vehicles/ ear) rs/da) Exhaust Exhaust Exhaust Loss TOG Exhaust Exhaust Exhaust Loss

Customer Vehicles 492, 203 19 7. 30 186. 15 285. 61 54. 75 526. 51 0. 0011 0. 0268 0. 0412 0. 0079

votes:

1. Daily operation hours assumed to be 5: 00 AM to 12: 00 AM, 365 days per year

e

Emission Source

Average

Hourly EmissionsOh/ hr)

Number of

Volume

Sources

Emissions

per Volume

lb/ hr)

Volume Source Dimensions

meters)

Volume Source

Release Ht

meters) Length AVidth Height

Idle - PM2. 5 0.0011 1 0. 00105 20 20 2 1

Idle - TOG Exhaust 0. 0268 1 0. 02684 20 20 2 1

Idle - TOG Running Loss 0. 0079 1 0. 00789 20 20 2 1

Statting - TOG Exhaust 0. 0412 4 0. 01030 13 13 4 1

f '

Safeway, Petaluma

Health Risk Impact Summary - Project Operation

Maximum Cancer Risks

Maximum Non - Cancer Health Effects

Maximum Cancer Risks ( per million)

Total

DPM Benzene TOG Operational

Sensitive Receptor Type Vehicles GDF Total Cancer Risk

Off -Site Residential ( 30 -year exposure) 1. 41 1. 94 1. 66 5. 0

Daycare/ Student ( 9 -year exposure) 0. 12 0. 16 0. 14 0. 4

Daycare Worker/ Teacher ( 25 -year exposure) 0. 09 0. 11 0. 10 0. 3

Maximum Non - Cancer Health Effects

Maximum Chronic Hazard Index

Total

DPM Benzene TOG Hazard

Sensitive Receptor Type Vehicles GDF Total Index

Off -Site Residential ( 30 -year exposure) 3. 80E- 04 0. 010 0. 002 0. 012

Daycare/ Student ( 9 -year exposure) 2. 02E- 04 0. 005 0. 001 0. 006

Daycare Worker/ Teacher ( 25 - year exposure) 2. 02E- 04 0. 005 0. 001 0. 006

Maximum Acute Hazard Index

Total

DPM Benzene TOG Hazard

Sensitive Receptor Type Vehicles GDF Total Index

Off -Site Residential ( 30 -year exposure) 0. 044 0. 007 0. 051

Daycare/ Student( 9- year exposure) 0. 020 0. 019 0. 039

Daycare Workerfreacher ( 25 -year• exposure) 0. 020 0. 019 0. 039

Maximum Annual PM2. 5 ( gghn)

PM2. 5

PM2. 5 Customer Travel Total

Sensitive Receptor Type Trucks and Idling PM2. 5

Off -Site Residential ( 30 -year exposure) 0. 00004 0. 018 0. 018

Daycare/ Student ( 9 -year exposure) 0. 00005 0. 010 0. 011

Daycare Worker/ Teacher ( 25 -year exposure) 0. 00005 0. 010 0. 011

Safeway, Petaluma

AERMOD Risk Modeling Parameters and Maximum TAC ConcentrationsOff -Site Residential Receptors

Receptor at Location of Maximum Cancer Risk from Project Operation

Receptor Information

Number of Receptors

Receptor Height =

Receptor distances =

Meteoroloeical Conditions

Petaluma Meteorological Data

Land Use Classification

Wind speed =

Wind direction =

63

1. 5 meters

variable - at nearby residences

2013- 2017

urban

variable

variable

MEI Maximum Concentrations

Non - Cancer Health Effects

TAC

Concentration ( ltglm)

Project O peration

DPM

TACMax Period Average

Max 1 - hour

ei

DPM 0. 001900

Vehicle TOG Exhaust 0. 383580 14. 81

Vehicle TOG Evaporative 0. 108600 2. 19

Benzene 0. 028600 1. 18

PM2.5

Delivery Trucks 0. 00004

Customer Vehicles 0. 0184

PM2. 5 Total 0. 01844


TAC

Project Operation

Hazard Index

Acute Chronic

DPM 3. 80E- 04

Vehicle TOG Exhaust 4. 51E- 03 1. 35E- 03

Vehicle TOG Evaporative 2. 88E- 03 9. 05E- 04

Benzene 4. 35E- 02 9. 53E- 03

Total 0. 051 0. 0122

Safeway, PetalumaMaximum Cancer & Non - Cancer Health Impacts

at Location of Maximum Cancer Risk from Project Operation

30 -Year Residential Exposure

Cancer Risk Calculation Method

Cancer Risk ( per million) = CPF x Inhalation Dose x ASF x ED/ AT x FAH x LOE6




Inhalation Dose = C,; r x DBR x A x ( EF/ 365) x 10"

Where: Cg,= concentration in air ( pghn )

DBR = daily breathing rate ( L/ kg body weight - day) A = Inhalation absorption factor

EF = Exposure frequency ( days/ year) 10' 6 = Conversion factor

Values

95th percentile breathing rales for infant, and 80th percentile for children and adults

Cancer I' menev Factors and Reference Exoosure Levels ( REL)

Infam/ Child Adult

Age--> 3rd Trimester 0-< 2 2-< 16 16- 70

Parameter

ASF 10 10 3 1

DBR-= 361 1090 572 261

A= I l I I

EF= 350 350 350 350

ED= 0.25 2 14 14

AT= 70 70 70 70

FAH = 1 1. 00 1. 00 1 1. 00 1 0. 73

95th percentile breathing rales for infant, and 80th percentile for children and adults

Cancer I' menev Factors and Reference Exoosure Levels ( REL)

CPF

REL ( p',/ m3) Acute Chronic

TAC mg/ kg -day)' 1 - hour) arm ave)

DPM 1. 10E+ 00 5

Vehicle TOG Exhaust 6. 28E- 03 3283 284

Vehicle TOG Evaporative 3. 70E- 04 762 120

Benzene LOOE- 01 27 3

P.• nioet ( lor.•a rt.. n (' ane... RIc4 - M- imnm PR• nieet ( lneratinn Inrnaet Residential Recentnr Location

Exposure

Exposure

Duration

Age

Sensitivity

ilfaximun - Exposure Information

Annual Cone ( u / m3) Cancer Risk (per million)

Exhaust Evaporative Exhaust Evaporative

Year Year years) Age Factor DPM TOG TOG Benzene DPM TOG TOG Benzene Total

0 2019 0. 25 0. 25- 0- 10 0.00190 0.383580 0. 10860 0.02860 0. 0258 0. 0298 0.0005 0. 0354 0.09

1 2019 1 1 10 0.00190 0.383530 0. 10860 0.02860 0.3121 0. 3597 0.0060 0. 4270 1. 10

2 2020 1 2 10 0.00190 0.383580 0. 10860 0.02860 0.3121 0.3597 0.0060 0. 4270 1. 10

3 2021 1 3 3 0.00190 0.383580 0. 10860 0.02860 0.0491 0.0566 0.0009 0.0672 0. 17

4 2022 1 4 3 0.00190 0.383580 0. 10860 0. 02860 0.0491 0. 0566 0. 0009 0. 0672 0. 17

5 2023 1 5 3 0.00190 0.383580 0. 10860 0. 02860 0.0491 0.0566 0.0009 0. 0672 0. 17

6 2024 1 6 3 0.00190 0.383580 0. 10860 0.02860 0. 0491 0.0566 0.0009 0. 0672 0. 17

7 2025 1 7 3 0.00190 0.383580 0. 10860 0. 02860 0. 0491 0.0566 0. 0009 0. 0672 0. 17

8 2026 1 8 3 0.00190 0. 383580 0. 10860 0. 02860 . 0. 0491 0.0566 0. 0009 0. 0672 0. 17

9 2027 1 9 3 0.00190 0.383580 0. 10860 0. 02860 0.0491 0. 0566 0. 0009 0. 0672 0. 17

l0 2028 1 10 3 0.00190 0. 383580 0. 10860 0. 02860 0.0491 0. 0566 0. 0009 0. 0672 0. 17

11 2029 1 11 3 0.00190 0. 383580 0. 10860 0.02860 0.0491 0.0566 0. 0009 0. 0672 0. 17

12 2030 1 12 3 0.00190 0. 383580 0. 10860 0. 02860 0. 0491 0. 0566 0. 0009 0. 0672 0. 17

13 2031 1 13 3 0.00190 0. 383580 0. 10860 0.02860 0.0491 0. 0566 0. 0009 0. 0672 0. 17

14 2032 1 14 3 0. 00190 0. 383580 0. 10860 0. 02860 0.0491 0. 0566 0. 0009 0.0672 0. 17

15 2033 1 15 3 0. 00190 0. 383580 0. 10860 0.02860 0.0491 0. 0566 0. 0009 0.0672 OA7

16 2034 1 16 3 0. 00190 0. 383580 0. 10860 0.02860 0.0491 0. 0566 0. 0009 0.0672 0. 17

17 2035 1 17 1 0. 00190 0. 383580 0. 10860 0.02860 0.0055 0. 0063 0. 0001 0. 0075 0.02

18 2036 1 18 1 0. 00190 0. 383580 0. 10860 0.02860 0. 0055 0. 0063 0. 0001 0. 0075 0.02

19 2037 1 19 1 0. 00190 0. 383580 0. 10860 0.02860 0. 0055 0. 0063 0. 0001 0.0075 0.02

20 2038 1 20 1 0.00190 0. 383580 0. 10860 0.02860 0. 0055 0. 0063 0.0001 0. 0075 0. 02

21 2039 1 21 1 0.00190 0. 383580 0. 10860 0.02860 0. 0055 0. 0063 0. 0001 0.0075 0.02

22 2040 1 22 1 0.00190 0. 383580 0. 10860 0.02860 0. 0055 0. 0063 0. 0001 0.0075 0.02

23 2041 1 23 1 0.00190 0. 383580 0. 10860 0.02860 0. 0055 0. 0063 0. 0001 0. 0075 0. 02

24 2042 1 24 1 0.00190 0.383580 0. 10860 0.02860 0.0055 0. 0063 0. 0001 0.0075 0. 02

25 2043 I 25 1 0.00190 0.383580 0. 10860 0. 02860 0.0055 0. 0063 0. 0001 0. 0075 0. 02

26 2044 1 26 1 0.00190 0.383580 0. 10860 0. 02860 0. 0055 0. 0063 0. 0001 0. 0075 0. 02

27 2045 1 27 1 0.00190 0.383580 0. 10860 0. 02860 0.0055 0. 0063 0. 0001 0. 0075 0. 02

28 2046 1 28 1 0.00190 0. 383580 0. 10860 0. 02860 0.0055 0. 0063 0. 0001 0. 0075 0. 02

29 2047 1 29 1 0.00190 0. 383580 0. 10860 0. 02860 0. 0055 0. 0063 0. 0001 0. 0075 0. 02

30 2048 1 30 1 0. 00190 0. 383580 0. 10860 0. 02860 0.0055 0. 0063 0. 0001 0.0075 0. 02

Total Increased Cancer Risk I I 1 1 1. 41 1 1. 63 1 0. 03 1 1. 94 1 5. 0


Safeway, Petaluma

AERMOD Risk Modeling Parameters and Maximum TAC ConcentrationsOff -Site School/Daycare Receptors

Receptor at Location of Maximum Cancer Risk from Project Operation


Number of Receptors

Receptor Height =


Meteoroloeical Conditions



Wind speed =

Wind direction =

80

1. 0 meters

variable - within daycare and school areas

2013- 2017

urban

variable

variable



TAC

Concentration ( µg/ ut )

Project Operation

Chronic

DPM

Max Period AverageMax I-

ourTAC

DPM 0. 001010



Benzene 0. 014280 0. 55

PM2. 5

Delivery Trucks 0. 000051Customer Vehicles 0. 01046

PM2. 5 Total 0. 01051


TAC

Project Operation

Hazard Index

Acute Chronic

DPM 2. 02E- 04



Benzene 2. 04E- 02 4. 76E- 03

Total 0. 0391

0. 006

Safeway, PetalumaMaximum Cancer & Non - Cancer Health Impacts

at Location of Maximum Cancer Risk from Project Operation

9 - Year Daycare/ School Child Exposure


Cancer Risk (per million) = CPF x Inhalation Dose x ASF x ED/ AT x FAH x LOE6




Inhalation Dose = Car x DBR x A x ( EF/ 365) x 10

Where: Car= concentration in air ( µg/ rn )

DBR = daily breathing rate ( Ukg body weight - day) A= Inhalation absorption factor



Values

Cancer Potencv Factors and Reference Exposure Levels ( REL)

Infant/ Child Adult

Age --> 3rd Trimestet 0-< 2 2-< 16

school child)

16- 70

Parameter

ASF 10 10 3 1

DBR* = 361 1090 572 261

A= I I 1 I

EF= 350 350 180 350

ED= 0. 25 2 14 14

AT= 70 70 70 70

FAH = 1. 00 1. 00 1. 00 0. 73

95th percentile breathine rates for infants and 80th mrcentile for children and adults

Cancer Potencv Factors and Reference Exposure Levels ( REL)

Prniect Oneratian Cancer Risk - Maximum Proiect Oneration Impact Daveare/ School Child Receptor Location

Exposure

CPF

REL ( µ /

m}) Acute

Chronic TAC mg/ kg - day)" 1 - hour) arm

ave) DPM 1. 10E+ 00

5 Vehicle TOG Exhaust 6.28E- 03 3283

284 Vehicle TOG Evaporative 3.70E- 04 762

120 Benzene 1.00E- 01 27

3 Prniect Oneratian Cancer Risk - Maximum Proiect Oneration Impact Daveare/ School Child Receptor

Location

Exposure

Exposure

Duration

Age

Sensitivity Maximum - Exposure

Information Annual Cone (ug/ m3) Cancer Risk ( er u '

Ilion) Exhaust Evaporative Exhaust

Evaporative Year Year years) Age Factor DPM TOG TOG I Benzene DPM TOG TOG Benzene

Total 1 2019 1 5 3 0.00101 0. 204010 0. 06152 0. 01428 0. 0134 0. 0155 0. 0003 0. 0173 0.

05 2 2020 1 6 3 0.00101 0.204010 0. 06152 0. 01428 0. 0134 0. 0155 0. 0003 0. 0173 0.

05 3 2021 1 7 3 0.00101 0.204010 0. 06152 0. 01428 0. 0134 0. 0155 0. 0003 0. 0173 0.

05 4 2022 1 8 3 0. 00101 0. 204010 0. 06152 0. 01428 0. 0134 0. 0155 0. 0003 0. 0173 0.

05 5 2023 1 9 3 0.00101 0. 204010 0. 06152 0. 01428 0. 0134 0. 0155 0. 0003 0. 0173 0.

05 6 2024 1 10 3 0.00101 0. 204010 0. 06152 0. 01428 0. 0134 0. 0155 0. 0003 0. 0173 0.

05 7 2025 1 11 3 0. 00101 0. 204010 0. 06152 0. 01428 0. 0134 0. 0155 0. 0003 0. 0173 0.

05 8 2026 1 12 3 0.00101 0. 204010 0. 06152 0. 01428 0. 0134 0. 0155 0. 0003 0. 0173 0.

05 9 2027 1. 13 3 0. 00101 0. 204010 0. 06152 0. 01428 0. 0134 0. 0155 0. 0003 0. 0173 0.

05 Total Increased Cancer Risk 0. 12 0. 14 0. 002 0. 155 0.

Safeway, Petaluma

AERMOD Risk Modeling Parameters and Maximum TAC ConcentrationsOff -Site School/ Daycare Receptors

Location of Maximum Daycare/ School Cancer Risk from Project Operation


Number of Receptors

Receptor Height =


Meteorological Conditions



Wind speed =

Wind direction =

80

1. 0 meters

variable - within daycare and school areas

2013- 2017

urban

variable

variable



TAC

Concentration ( µg/

Project Operation

Chronic

Max Period Average MAveax -

houer

TAC

DPM 0. 001010



Benzene 0. 014280 0. 55

PM2. 5

Delivery Trucks 0. 00005

Customer Vehicles 0. 01046

PM2. 5 Total 0. 01051


TAC

Project Operation

Hazard Index

Acute Chronic

DPM 2. 02E- 04



Benzene 2. 04E- 02 4. 76E- 03

Total 1 0. 039 1 0. 006

Safeway, PetalumaMaximum Cancer & Non -Cancer Health Impacts

at Location of Maximum Daycare/School Cancer Risk from Project Operation

25 -Year Daycare Worker/ School Teacher Exposure


Cancer Risk ( per million) = CPF x Inhalation Dose x ASF x ED/ AT x FAH x I. OE6


ASF = Age sensitivity factor for specified age groupED = Exposure duration (years)

AT = Averaging time for lifetime cancer risk ( years) FAH = Fraction of time spent at home (unitless)

Inhalation Dose = C,;, x DBR x A x ( EF/ 365) x 10- 6

Where: C,;, = concentration in air ( pg/ m3)

DBR = daily breathing rate ( L/ kg body weight -day) A = Inhalation absorption factor

EF = Exposure frequency ( days/ year) 10- 6 = Conversion factor

Values

Adult

16- 70

DBR* =

CPF

230

A=

Acute

1

EF =

mg/ kg - da )- t

350

ED=

DPM

25

AT =

5

70

FAH =

3283

breathing rate ( U g- 8 houm)

Cancer Potency Factors and Reference Exposure Levels ( REL)

Proiect Oneration Cancer Risk - Maximum Proiect Operation Impact Daveare Worker/ School Teacher Receptor Location

CPF

REL ( gIm')

Acute Chronic

TAC mg/ kg - da )- t 1 -hour ann ave

DPM 1. 10E+ 00 5

Vehicle TOG Exhaust 6. 28E- 03 3283 284

Vehicle TOG Evaporative 3. 70E- 04 762 120

Benzene 1. 00E- 01 27 3

Proiect Oneration Cancer Risk - Maximum Proiect Operation Impact Daveare Worker/ School Teacher Receptor LocationMaximum - Exposure Information

Exposure Initial

ExposureEFactorAnnual Cone ( u / m3) Cancer Risk ( per million)

Exhaust Exhaust EvaporativeYear Exposure Duration

Age Year years) DPM TOG

IF

TOG Benzene DPM TOG TOG Benzene Total

16 2019 25 0. 00101 0. 204010 0. 06152

10.01428 0. 0875 0. 1009 0. 0018 0. 1125 0. 30

Total Increased Cancer Risk 0. 09 0. 10 0. 002 0. 112 0. 3

CalEEMod Version: CalEEMod. 2016. 3. 2

Page 1 of 1

Petaluma Safeway - Sonoma - San Francisco County, Annual

Petaluma SafewaySonoma - San Francisco County, Annual

1. 0 Project Characteristics

1. 1 Land Usage

Date: 10/ 10/ 2018 9: 32 AM

1. 2 Other Project Characteristics

Urbanization Urban Wind Speed ( m/ s) 2. 2 Precipitation Freq ( Days) 75

Climate Zone 4 Operational Year 2020

Utility Company Pacific Gas & Electric Company

CO2 Intensity 290 CH4Intensity 0. 029 N20 Intensity 0. 006

Ib/ M W hr) ( Ib/ M Whr) ( Ib/ M W hr)

1. 3 User Entered Comments & Non -Default Data

Project Characteristics - PG& E Rate

Land Use - Disturbed site acreage

Construction Phase -

Trips and VMT - added paving trips and adjusted trips to 1 mile for HRA ( local travel)

Demolition - estimated based on 180ft x 75 ft

Vehicle Trips - No trips generated by market

Construction Off-road Equipment Mitigation - Tier 3 and BMP

Grading - based on 9- 14- 2018 email

Table Name Column Name Default Value New Value

tblConslDustMitigation WaterUnpavedRoadVehicleSpeed 0 15

tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1. 00


tblConstEquipMitigation NumberOfEquipmentMitigated 0. 00 2. 00

tblConstEquipMitigation NumberOfEquipmenlMitigaled 0.00 1. 00

tblConstEquipMitigation NumberOfEquipmenlMitigated 0.00 2. 00


tblConstEquipMitigation NumberOfEquipmentMitigated 0. 00 1. 00

tblConstEquipMitigation NumberOfEqulpmentMitigated 0. 00 1. 00

tblConstEqulpMitlgation NumberOfEquipmentMitigated 0. 00 2. 00

tblConstEquipMitigation NumberOfEquipmenlMiligated 0. 00 8. 00

tblConstEquipMitigation Tier No Change Tier 3



tblConstEqulpMitlgation Tier No Change Tier 3




tblConstEqulpMitlgation Tier No Change Tier 3



tblGrading Matedalimported 0. 00 1, 200. 00

tblLandUse LandUseSquareFeet 700. 00 697. 00

tblLandUse LotAcreage 0. 05 0. 70

tblLandUse LotAcreage 0. 02 0. 00

tblProjectCharacteristics CO21ntensityFactor 641. 35 290

tblTripsAndVMT HaulingTr pLength 20. 00 1. 00

tblTripsAndVMT HaulingTripLength 20. 00 1. 00




tblTripsAndVMT HaulingTripLength 20.00 1. 00

tblTripsAndVMT VendorTripLength 7. 30 1. 00




tblTripsAndVMT VendorTripLength 7.30 1. 00


tblTripsAndVMT WorkerTripLength 10. 80 1. 00






tblVehicleTdps ST TR 42. 04 0. 00

tblVehicleTdps SU TR 20.43 0. 00

tblVehicleTrips WD -TR 44.32 0. 00

2. 0 Emissions Summary

2. 1 Overall Construction

Unmitigated Construction

ROG 1NOx CO 3 S02 I:, Fugitive Exhaust PMtO Fugitive Exhaust PM2. 5 Blo- G02 NBio- CO2 Total CO2'. CH4 N20 G02e 1

PM10 PM10 Total PM2. 5I PM2. 5 TotalI I IYear ' tonslyr MTM

2019 0.0727 0. 5826 0.4516 7.0000e- . 7. 9400.- 0.0351 0. 0431 116100e- 0. 0325 0. 0340 0. 0000 62. 2583 62. 2583 0. 0185 0. 0000 62. 7204

004 003 1 003

Maximum 0. 0727 0. 5826 0. 4516 7. 000Oe- 7. 9400e- 0. 0351 0. 0431 1. 5100e- 0. 0325 0. 0340 0. 0000 62. 2583 62. 2583 0.0185 0. 0000 62. 7204

004 003

1 1003

Mitigated Construction

Quarter Start Date. rEnd Date

ROG

N077CO SO2 Fugitive - Exhaust I PM10 Fugitive Exhaust PM2. 5 Blo- CO2 NBIo- CO2 Total

CO27777

CH4 N20

02e

5 1

3

I I 1

PM10 PM10 Total PM2. 5 PM2. 5 Total

6/ 6/ 2019 5 100

Year tonslyr MT/yr

2019 0. 0323 0. 3713 0. 4742 7. 000Oe- 3. 6800e- 0. 0228 0. 0265 7. 1000e- 0.0228 0. 0235 0. 0000 62. 2583 62.2583 0.0185 0. 0000 62. 7203

1 1

004 003

1

004

I I I

Maximum j 0. 0323 0. 3713 0. 4742 7.000Oe- 3. 6800e- 0. 0228 0. 0265 7. 1000e- 0. 0228 0. 0235 0. 0000 62, 2563 62. 2583 0. 0185 0. 0000 62. 7203

004 003 004 1

Quarter Start Date. rEnd Date

ROG NOx CO SO2 '- Fugitive ; Exhaust PM10 Eugltive Exhaust PM2. 5 Bio - 0O2 NBio 02 Total CO2 CH4 N20 CO2e

5 1

3

I I 1 PM10 PM10 Total PM2. 5 PM2. 5 Total

6/ 6/ 2019 5 100

Percent 55, 50 36. 27 5. 02 0. 00 53. 65 35. 13 3850 52. 98 29. 79 30. 84 0. 00 0. 00 0. 00 0, 00 0. 00 0. 00

Reduction 1 1 1 1 1 1 I I IQuarter Start Date. rEnd Date Maximum Unmitigated ROG + NOX( tons/quarter) Maximum Mitigated ROG +' NOX (tonslquarter)

1 1. 1. 2019 331- 2019 0. 3483 0. 2137

2 4. 1- 2019 630. 2019 0. 3005 0. 1850

Highest 0. 3483 0. 2137

3. 0 Construction Detail

Construction Phase

Phase :

Number;

Phase Name Phase Type Start Date End Date Num Days Num Days Phase Description

Week

1 Demolition Demolition 1/ 1/ 2019 1/ 14/ 2019 5 10

2 Site Preparation Site Preparation 1/ 15/ 2019 1/ 15/ 2019 5 1

3 Grading Grading 1/ 16/ 2019 1/ 17/ 2019 5 2

4 Building Construction Building Construction 1/ 18/ 2019 6/ 6/2019 5 100

7

Acres of Grading ( Site Preparation Phase): 0. 5

Acres of Grading ( Grading Phase): 0

Acres of Paving: 0

Residential Indoor: 0; Residential Outdoor: 0; Non - Residential Indoor: 4, 434; Non - Residential Outdoor: 1, 478; Striped Parking Area: 0

OffRoad Equipment

Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor

Demolition Concrete/ Industrial Saws 1 8. 00 81 0. 73

Demolition Rubber Tired Dozers 1 1. 00 247 0. 40

Demolition Tractors/ Loaders/ Backhoes 2 6. 00 97 0. 37

Site Preparation Graders 1 8. 00 187 0. 41

Site Preparation Tractors/ Loaders/ Backhoes 1 8. 00 97 0. 37

Grading Concrete/ Industrial Saws 1 8. 00 81 0. 73

Grading Rubber Tired Dozers 1 1. 00 247 0. 40

Grading Tractors/ Loaders/ Backhoes 2 6. 00 97 0. 37

Building Construction Cranes 1 4. 00 231 0. 29

Building Construction Forklifts 2 6. 00 89 0. 20

Building Construction Tractors/ Loaders/ Backhoes 2 8. 00 97 0. 37

Paving Cement and Mortar Mixers 4 6. 00 9 0. 56

Paving Pavers 1 7. 00 130 0. 42

Paving Rollers 1 7. 00 80 0.38

Paving Tractors/ LoadersBackhoes 1 7. 00 97 0. 37

Architectural Coating Air Compressors 1 6. 00 78 0. 48

Trips and VMT

Demolition 4 10. 00 0. 00 61. 00 1. 00 1. 00 1. 00 LID Mix HDT_ Mix HHDT

Site Preparation 2 5. 00 0. 00 0. 00 1. 00 1. 00 1. 00 LID Mix HDT_ Mix HHDT

Grading 4 10. 00 0.00 150. 00 1. 00 1. 00 1. 00 LD - Mix HDT_ Mix HHDT

Building Construction 5 1. 00 0. 00 0. 00 1. 00 1. 00 1. 00 LD_ Mix HDT_ Mix HHDT

Paving 7 18. 00 0. 00 0. 00 1. 00 1. 00 1. 00 LD_ mix HDT_ Mix HHDT

Architectural Coating 1 0. 00 0.00 0.00 1. 00 1. 00 1. 00 LD_ Mix HDT_ Mix HHDT

3. 1 Mitigation Measures Construction

Use Cleaner Engines for Construction Equipment

Water Exposed Area

Reduce Vehicle Speed on Unpaved Roads

3. 2 Demolition - 2019

Unmitigated Construction On -Site

ROG NOx CO ;- SO2 f Fugitive :: I Exhaust I PM10 Fugitive Exhaust PM2. 5 Blo- CO2 Nato- CO2 Total CO2r CH4 N20 CO2e

I PM10 : PM10

ITotal PM2. 5 PM2, 5 Total I

Category tonslyr MT/ Yr

Fugitive Dust 6 0. 0000 6. 6400e- 1. 0010030- 0.

00001. 000a- 0.0000 0. 0000 0. 0000 0. 0000 0.0000 0. 0000

003e- I I 03 I

Off-Road4,7700e- 0. 0430 0.0385 6.00000- 2. 6900e- 2. 6900e- 2. 5600e- 2. 5600e- 0. 0000 5. 2601 5. 2601 1. 0000e- 0. 0000 5. 2852

003 005 003 003 003 003 003

Total 4. 7700e. 0, 0430 0. 0365 6. 000Oe- 6. 6400e- 2. 6900.- 9.3300e- 1. 0100.- 2. 5600.- 3. 5700e- 0. 0000 5. 2601 5.2601 1. 000Oe- 0, 0000 5. 2852

003 005 003 003 003 003 003 003 003

Unmitigated Construction Off -Site

ROG NOx

ICO

ISO2

IFugitive Exhaust PM10 Fugitive

IExhaust

IPM2. 5 Bio- CO2 NBlo- CO2 TotaiCO2r CH4 N20 CO2e ':

PM10 ': PM10 Total PM2.5 PM2. 5. Total

Category tons/ yr MT/ yr

Hauling 7.0000e-

005

3. 2300e-

003

5. 7000e-

004

0. 0000 3. 000Oe-

005

1- 00OOe-

005

3.0000e- 1. 0000e- 1. 0000.-

005 005 005

1. 0000e-

005,

0. 0000 0. 3432 0. 3432 6. 000Oe-

005

0. 0000 0. 3448

Vendor 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

Worker 9. 000Oe-

005

4. 000Oe-

005

5. 4000e-

004

0. 0000 4. 0000e-

005

0. 0000 4. 000Oe- 1. 000Oe- 0. 0000

005 005

1. 0000e-

005

0.0000 0. 0443 0. 0443 0.0000 0.0000 0. 0444

Total 1. 6000.-

004

3. 2700e-

003

1. 1100e-

003

0. 0000 7.000Oe-

005

1. 000Oe-

005

7.000Oe- 2.000Oe- 1. 000Oe-

005 005 005

2. 000Oe-

005

0. 0000 0. 3875 0. 3875 6. 000Oe-

005

0. 0000 0. 3891

Mitigated Construction On -Site

ROG NOx CO :: SO2 `. Fugitive :: Exhaust PM10 Fugitive Exhaust PM2. 5 Bio- CO2 NBIo- CO2 Total CO2 CH4 N20 CO2e f

Hauling 7. 0000e-

005

I I

0. 0000

PM10 PM10 Total PM2. 5 PM2. 5I TotalI

0. 3432 0. 3432 6. 000Oe-

005

0. 0000

I ICategory tons/ yr MT/yr

Fugitive Dust

0. 0000 0. 0000 0. 0000

2. 9900e- 0. 0000 2. 9900e- 4. 5000e- 0. 0000 4. 5000e- 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

4.000Oe-

005

0. 0000 4. 0000e-

005

1. 0000e-

005

003

1. 000Oe- 0. 0000

005

003 004

0. 0000

004

0. 0444

Off - Road , 1. 3300e- 0. 0298 0.0397 6.000Oe- 2.0100e- 2.0100e- 2. 01OOe- 2. 0100e- 0. 0000 5. 2601 5. 2601 1. 000Oe- 0. 0000 5. 2852

003 005' 003 003 003 003 003

Total 1. 3300e- 0. 0298 0. 0397 6. 0000e- 2. 9900e- 2. 0100a- 5. 000Oe- 4. 5000e- 2. 0100e- 2. 4600e- J 0. 0000 5.2601 5. 2601 1. 000Oe- 0. 0000 5.2852

003 005 003 003 003 004 003 0031

003

Mitigated Construction Off -Site

ROG

INOX

ICO

ISO2 f: Fugitive'

PM10

Exhaust

PM10

PM10

Total

Fugitive

PM2. 5

Eichaust

IPM2. 5 I

PM2.5 Blo- CO2ITotal

NBio- CO2 Total CO2.: CH4 N20 C02e

Category tonstyr MT/yr

Hauling 7. 0000e-

005

3. 2300e-

003

5. 7000e-

004

0. 0000 3. 000Oe-

005

1. 0000e-

005

3.000Oe-

005

1. 0000e-

005

1A000e-

005

1. 0000e- 0. 0000

005

0. 3432 0. 3432 6. 000Oe-

005

0. 0000 0. 3448

Vendor 0.0000 0.0000 0.0000 0.0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0.0000 0. 0000 0. 0000 0. 0000 0.0000

Worker 9. 0000e-

005

4. 000Oe-

005

5.4000.-

004

0. 0000 4. 000Oe-

005

0. 0000 4. 0000e-

005

1. 0000e-

005

0. 0000 1. 000Oe- 0. 0000

005

0. 0443 0. 0443 0. 0000 0. 0000 0. 0444

004 i 003 1 003 i 1 005 1 005 i 005 1 005 1 005 i 005 1 i i 1 005

3. 3 Site Preparation - 2019


ROG NO CO :. S02 Fugitive Exhaust PM10 Fugitive Exhaust PM2. 5 Blo- CO2 NBlo- CO2 Total CO2 CH4 N20 CO2e

MT/ yr

I

0. 0000 0. 0000

PM10I PM10 Total PM2.5 PM2. 5I Total

0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

ICategory tonslyr MT/ yr

Fugitive Dust

0. 0000 0. 0000 0. 0000

2.7000e- 0. 0000 2. 70000- 3. o000e- 0. 0000 3. 00000- 0. 0000 0.0000 0. 0000 0. 0000 0. 0000 0. 0000

0. 0000 3. 000Oe-

005

0. 0000 0. 0000

004

0. 0000

004 005

0. 0000

005

2. 2100e-

003

2. 2100e-

003

0. 0000 0. 0000 2. 2200e-

003

Total 0. 0000

Off - Road 3.6000e- 4.4600e- 2. 0700e- 0. 0000

0. 0000

1. 8000e- 1. 8000e-

0. 0000

1. 7000e- 1. 70000- 0. 0000 0. 4376 0.4378 1. 4000e- 0. 0000 0. 4413

004 003 003 004 004 004 004 004

Total 3. 6000e- 4. 4600e• 2. 0700e. 0.0000 2.7000e. 1. 8000e• 4.5000e- 3. 000Oe- 1. 7000e• 2. 00000• 0. 0000 0. 4378 0.4378 1 1. 4000e• 0. 0000 0. 4413

004 003 003 004 004 004 005 004 004 004


ROG

INOx CO

ISO2 c'. Fugitive :' Exhaust

PM10 ': PM10

iPM10

Total

Fugitive

PM2. 5

Exhaust

PM2. 5

PM2. 5

Total

Bio- CO2 NBlo- CO2 Total CO2: CH4

IN20

ICO2e


Hauling 0.0000 0. 0000 0. 0000 0. 0000 0.0000 0.0000 0. 0000. 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

Vendor 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0.0000 0.0000 0. 0000 0. 0000 0. 0000 0. 0000 0.0000 0. 0000 0.0000 0. 0000 0. 0000

Worker 0. 0000 0. 0000 3. 000Oe-

005

0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 2. 2100e-

003

2. 2100e-

003

0. 0000 0. 0000 2. 2200e-

003

Total 0. 0000 0. 0000 3. 00000•

005

0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 2. 21000•

003

2. 21000-

003

0. 0000 0. 0000 2. 22000-

003


Mitigated Construction Off - Site

ROG

ROG NOX CO: SO2 :: Fugitive Exhaust I PM10 Fugitive Exhaust PM2: 5 Blo- 0O2 NBlo- CO2 Total CO2 CH4 N20 sCO2e r

MTlyr

Hauling 0. 0000

I

0. 0000 0. 0000

PM10 PM10 Total PM2. 5 PM2. 5 Total

0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

Category

0. 0000 0. 0000 0. 0000 0. 0000

tonslyr

0. 0000 O. 00W 0. 0000 0. 0000 0. 0000 0. 0000

MT/ yr

0. 0000 0. 0000

Fugitive Dust

Worker 0. 0000 0. 0000 3. 00OOe-

005

0. 0000

1, 2000e- 0.0000 1. 2000e- 1. 0000' 0. 0000 1. 0000e- 0. 0000 0. 0000 0.0000 0. 0000 0. 0 000 000.00

Total 0. 0000 0. 0000 3. 0000e-

005

0. 0000 0. 0000

004

0. 0000

004 005

0. 0000

005

2. 2100e-

003

2. 2100e-

003

0. 0000 0. 0000 2. 2200e.

003

Off -Road 1. 2000e- 2. 4400e- 2. 9300e- 0. 0000 1. 2000e- 1. 2000e- 1. 2000e- 1. 2000e- 0. 0000 0. 4378 0. 4378 1. 4000e- 0. 0000 0. 4413

004 003 003 004 004 004 004 004

Total 1. 2000e. 2. 4400e- 2. 9300e. 0. 0000 1. 2000e. 1. 2000e. 2. 4000e- 1. 00OOe- 1. 200Oe- 1. 3000e. 0. 0000J 0. 4378 0. 4378 1. 4000e- 0. 0000 0. 4413

004 003 003 004 004 004 005 004 004 004

Mitigated Construction Off - Site

ROG NOx

ICO ': SO2 '- Fugitive

PM10

Exhaust

PM10

r PM10

Total

Fugitive

PM2. 5

Exhaust

PM2. 5

PM2. 5

Total

BIo- CO2 NBlo- CO2 Total CO2 CH4 N20 CO2e

Category tonslyr MTlyr

Hauling 0. 0000 0. 0000 0. 0000 0. 0000 0.0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

Vendor 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 O. 00W 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

Worker 0. 0000 0. 0000 3. 00OOe-

005

0. 0000 0. 0000 0. 0000 0.0000 0. 0000 0.0000 0.0000 0.0000 2.2100e-

003

2. 2100e-

003

0. 0000 0. 0000 2. 2200e-

003

Total 0. 0000 0. 0000 3. 0000e-

005

0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 2. 2100e-

003

2. 2100e-

003

0. 0000 0. 0000 2. 2200e.

003

3. 4 Grading - 2019

Unmitigated Construction On - Site

ROG

INOx

ICO

ISO2 : Fugitive

PM10

Exhaust

PM10

I PM10

I Total

Fugitive

PM2. 5 IExhaust

PM2. 5

I PM2. 5Total

BIo- 0O2 NBio- CO2 Total CO2c CH4

IN20

Category tonslyr MT/yr

Fugitive Dust

NOx CO SO2 Fugitive :<.

8.2000e-

004

0.0000 8.2000e-

004

4. 2000e-

004

0. 0000 4. 2000e-

004

0. 0000 0. 0000 0. 0000 0. 0000 0.0000 0. 0000

Off -Road 9.5000e- 8.6000e- 7. 6900e- 1. 000Oe-

Total

5. 4000e- 5. 4000e-

ITotal

5.1000e- 5. 1000e- 0. 0000 1. 0520 1. 0520 2. 000Oe- 0. 0000 1. 0570

Hauling 1. 8000e-

004 003 003 005

2. 0000e-

004 004

1. 000Oe-

004 004

0. 8440 0. 8440 1. 5000.-

004

0. 8478

004

Total 9. 5000.- 8. 6000e- 7. 6900e- 1. 0000e- 8. 2000e- 5. 4000e• 173600e- 4. 2000e- 5. 1000e- 9. 3000.- 0. 0000 1. 0520 1. 0520 2. 0000.- 0.0000 1. 0570

0. 0000

004 003 003 005 004 004 003 004 004 004

0. 0000 0. 0000 0. 0000

004

1. 000Oe- 1. 1000e-


ROG NOx CO SO2 Fugitive :<. Exhaust PM10Fugitive Exhaust PM2. 5 Bto- 0O2 NBlo- CO2 TotaICO2 CH4 N20 CO2e

I

I

I I PM10 - PM10 Total PM2.5 PM2.5

ITotal

Category tonslyr MT/ YT

Hauling 1. 8000e- 7. 9500e- 1. 41OOe- 1. 000Oe- 6. 000Oe- 2. 0000e- 8. 000Oe- 2. 000Oe- 1. 000Oe- 3. 0000e- 0. 0000 0. 8440 0. 8440 1. 5000.- 0.0000 0. 8478

004 003 003 005 1 005 005 005 005 005 005 004

Off - Road 2.7000e- 5. 9600e-

Vendor 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0.0000 0. 0000 0.0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

Worker 2. 000Oe- 1. 000Oe- 1. 1000e- 0. 0000 1. 000Oe- 0. 0000 1. 000oe- 0. 0000 0.0000 0. 0000 0. 0000 8. 8500e- 8. 8500e- 0. 0000 0.0000 8. 8700e-

005 005 004

4. 000Oe•

005

0. 0000

005

1. 0520 2. 000Oe- 0, 0000 1. 0570

003 003

003 005

003

Total 1 2. 0000.- 7. 9600.- 1. 5200e- 1. 0000e- 7. 0000e- 2. 000Oe- 9. 0000e- 2. 000Oe- 1. 0000e- 3. 000Oe- 0. 0000 0. 8529 0. 8529 1. 5000e- 0. 0000 0. 8566

004 003 003 005 005 005 005 005 005 005 004


ROD NOx CO a SO2 '' Fugitive - I Exhaust PM10Fugitive Exhaust PM2. 5 Bio- CO2 NBIo- CO2 Total CO2 CH4 : N20 CO2e

I I PM10 PM10 TotalI PM2.5 PM2. 5

ITotal

Category tonslyr MT/ Yr

Fugitive Dust 3. 7000e- 0.0000 3.7000e- 1. 9000e- 0.0000 1. 9000e- 0. 0000 0. 0000 0. 0000 0. 0000 0.0000 0. 0000

004 004 004 004

Off - Road 2. 7000e- 5. 9600e- 7. 9400e- 1. 0000e- 4.0000.- 4.0000.- 4. 0000e- 4. 000Oe- 0. 0000 1. 0520 1. 0520 2. 000Oe- 0. 0000 1.0570

004 003 003 005 004 004 004 004 004

Total 2, 7000.- 5. 9600e- 7. 9400.• 1. 0000.- 3. 7000.- 4.0000.- 7. 7000.• 1. 9000.- 4. 000Oe• 5. 9000.• 0. 0000 1. 0520 1. 0520 2. 000Oe- 0, 0000 1. 0570

004 003 003 005 004 004 004 004 004 004 004


ROG NOx CO SO2 -: Fugitive `: I Exhaust I PM10 Fugitive Exhaust PM2. 5 Bio - CO2 NBio- CO2 Total CO2 CH4 r N20 CO2e

CO2e

I PM10 . PM10 Total PM2. 5 PM2. 5I Total

PM2. 5

I ICategory I tonslyr MT/yr

Hauling 1. 8000e- 7. 9500e- 1.

410011. 0000e- 6. 000Oe- 2. 000Oe- 8. 00000- 2. 0000e- 1. 000Oe- 3. 000Oe- 0.0000 0.8440 0. 8440 1. 5000e- 0. 0000 0. 8478

004 003 003 005 005 005 005 00, 5 005 005 I 004

Vendor 0. 0000 0.0000 0. 0000 0. 0000 0.0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

Worker 2. 000Oe- 1. 0000a- 1. 1000e- 0. 0000 1. 00000- 0.0000 1. 000Oe- 0. 0000 0. 0000 0. 0000 0. 0000 8. 8500e- 8. 6500e- 0. 0000 0. 0000 8. 8700e-

005 005 004 005 005 003 003 003

Total 2. 0000e. 7. 9600e- 1. 5200x- 1. 0000e. 7. 0000e- 2. 0000e. 9. 00000- 2. 0000e- 1. 0000e- 3. 0000e- 0. 0000 0. 8529 0. 8529 1. 5000e- 0. 0000 0. 8566

004 003 003 005 005 005 005 005 005 005 004

3. 5 Building Construction - 2019


ROG NOx CO SO2 >' Fugitive : Exhaust PM10 Fugitive Exhaust PM2.5 Blo- C7NBlo- CO2 Total CO2i CH4 t: N20 CO2e

PM10 PM10 Total PM2. 5 PM2. 5 TotalI ICategory tonslyr MT/ yr

Off -Road 0. 0479 0. 4910 0. 3772 5. 70000- 0. 03030. 0303 0. 0279 0. 0279 0.0000 51. 1502 51. 1502 0. 0152 0.0000 51. 5548

004

Total 0. 0479 0. 4910 0. 3772 5. 70000- 0.0303 0. 0303 0. 0279 0. 0279 0. 0000 51. 1502 51. 1502 0. 0162 0. 0000 51. 5548

004


ROG

INOx CO ':. SO2 Fugitive:) Exhaust

IPM10

IFugitive

IExhaust

1PM2. 5

IBio - CO2 NBlo- CO2 Total CO2 CH4 N20 '. 0O2e s

PM10 PM10 ('. Total PM2.5 PM2. 5 Total


Hauling 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

Vendor 0. 0000 0. 0000 0. 0000 0.0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

Worker 9. 0009e-

005

4. 0000e-

005

5. 4000e- 0. 0000

004

4. 000Oe-

005

0. 0000 4. 0000e- 1. 000Oe-

005 005

0. 0000 1. 000Oe-

005

0.0000 0. 0443 0. 0443 0. 0000 0.0000 0. 0444

Total 9.000ee-

005

4. 000Oe-

005

5. 4000e- 0. 0000

004

4.000Oe-

005

0.0000 4.000Oe- 1. 000Oe-

005 005

0. 0000 1. 000Oe-

005

0. 0000 0. 0443 0. 0443 0. 0000 0. 0000 0. 0444


ROG NOX CO SO2 Fugitive' Exhaust PMlr Fugitive Exhaust PM2. 5 Bio - CO2 NBlo- CO2 Total CO2: CH4 N20 CO2e

Hauling 0. 0000 0. 0000 0. 0000 0. 0000

PM10 : PM10 Total PM2.5 PM2. 5 Total

0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

Vendor 0. 0000

Category tonslyr MT/ yr

Off - Road 0. 0140 0. 3065 0. 3981 5. 7000x,

0. 0000

0. 0193 0. 0193

0. 0000

0. 0193 0. 0193 0. 0000 51. 1502 51. 1502 0. 0162 0. 0000 51. 5548

4. 000Oe-

005

0. 0000 4. 0000e-

005

004

0. 0000 1. 0000e- 0. 0000

005

0. 0443 0. 0443 0. 0000 0. 0000 0. 0444

Total 0. 0140 0. 3065 0. 3981 5.7000e- 0. 0193 0. 0193 0. 0193 0. 0193 0. 0000 51. 1502 51. 1502 0. 0162 0. 0000 51. 5548

004


ROG

INOx

ICO

ISO2

IFugitive

PM10

Exhaust IPM10 I

PM10

Total

Fugitive

PM2, 5

Exhaust

PM2. 5

PM2. 5 BIo- CO2

Total

NBlo- CO2 Total CO2- CH4 N20

ICO2e <:


Hauling 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0.0000 0. 0000 0.0000 0.0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

Vendor 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0.0000 0. 0000 0.0000

Worker 9. 000Oe-

005

4. 0000e-

005

5.4000e-

004

0.0000 4. 000Oe-

005

0. 0000 4. 0000e-

005

1. 0000e-

005

0. 0000 1. 0000e- 0. 0000

005

0. 0443 0. 0443 0. 0000 0. 0000 0. 0444

005 1 005 1 004 1 1 005 1 1 005 1 005 1 1 005

3. 6 Paving - 2019


ROG N

IC0= SO2 <' Fugitive-

PM10 ':

Exhaust

PM10

PM10

Total IFugitive

PM2. 5 IExhaust

PM2. 5

PM2. 5

I Total

Blo-: CO2 NBlo- CO2 Total CO2 CH4 ': N20

ICO2e


Off -Road 2, 0700e-

003

0. 0196 0. 0179 3. 000Oe-

005

0. 0000 0. 0000

1. 110Oe-

003

1. 1100e-

003

0. 0000

1. 0300e-

003

1. 0300e-

003

0. 0000 2. 3931 2. 3931 6. 8000a-

004

0. 0000 2. 4102

Paving 0. 0000

0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

0. 0000 0. 0000

0. 0000

0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

Total 2.0700e-

003

0. 0196 0. 0179 3. 0000e-

005

1. 0000e-

005

1. 1100e-

003

1. 1100e-

003

0. 0000

1. 0300e-

003

1. 0300e.

003

0. 00001 2. 3931 2. 3931 6. 8000e-

004

0. 0000 2. 4102


ROG

INOx

ICO '< SO2

IFugitive ;.

PM10

Exhaust

PMtO

PM10

Total

Fugitive

FM2. 6

Exhaust

PM2.5

PM2, 5

Total

Bio- CO2 NBio- CO2 Total CO2

ICH4 N20

ICO2e +:


Hauling 0. 0000 0. 0000 0.0000 0. 0000 0. 0000 0. 0000 0.0000 0. 0000 0. 0000 0. 0000 0. 0000 0.0000 1 0. 0000 0. 0000 0. 0000 0. 0000

Vendor 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0.0000 0. 0000 0. 0000 0. 0000 0.0000 0.0000 0.0000 0. 0000

Worker 8. 000Oe-

005

4.000Oe-

005

4. 9000e-

004

0. 0000 3. 0000, e- 0. 0000

005

3. 000Oe-

005

1. 0000e-

005

0. 0000 1. 000Oe-

005

0. 0000 0.0398 0.0398 0.0000 0. 0000 0.0399

Total 8. 000Oe-

005

4.000Oe-

005

4. 9000e-

004

0. 0000 3.0000e- 0. 0000

005

3. 0000e-

005

1. 0000e-

005

0, 0000 1. 000Oe-

005

0. 0000 0. 0398 0. 0398 0. 0000 0. 0000 0. 0399

Mitigated Construction Ori -Site

ROG NOx CO -: SO2 :: Fugitive

PM10 '.

Exhaust

PM10

PM70

IFugitive

Total PM2. 5 IExhaust

PM2. 5

PM2. 5

Total

BIo- CO2 NBlo- CO2 TotaICO2 CH4

IN20

ICO2e


Off -Road 5. 6000e-

004

0. 0119 0. 0173 3. 000Oe-

005

0. 0000

7. 3000e-

004

7. 3000e-

004

0. 0000

7. 3000a-

004

7. 30000-

004

0. 0000 2. 3931 2. 3931 6. 8000e- 0. 0000

004

2. 4102

Paving 0. 0000

0. 0000

0. 0000 0. 0000

0. 0000 0. 0000

0. 0000

0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

Total 5. 6000e-

004

0. 0119 0. 0173 3. 000Oe-

005

4. 000Oe-

005

7. 3000e-

004

7. 3000e-

004

3. 00006-

005

7. 3000e-

004

7. 3000e•

004 10. 0000 2. 3931 2. 3931 6. 8000e- 0, 0000

004

2. 4102


ROG

INOz

ICO

ISO2 -. Fugitive

PM10

Exhaust

PM10

I PM10

I Total IFugitive

PM2. 5

Exhaust

PM2. 5

PM2. 5

Total

BIo- CO2

INBio- CO2 Total CO2 CH4 , 1 N20

ICO2e


Hauling 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

Vendor 0.0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0.0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

Worker 8. 0000e,

005

4. 000Oe-

005

4.90000-

004

0.0000 3. 00006-

005

0. 0000 3. 0000e-

005

1. 00000-

005

0.0000 1. 0000a-

005

0. 0000 0. 0398 0. 0398 0. 0000 0. 0000 0. 0399

Total 8. 0000e-

005

4. 000Oe•

005

4. 9000e-

004

0. 0000 3. 000Oe-

005

0. 0000 3. 000Oe-

005

1. 000Oe-

005

0. 0000 1. 0000e-

005

0. 0000 0. 0398 0. 0398 0. 0000 0. 0000 0.0399

3. 7 Architectural Coating - 2019


r '

ROG

INOX

ICO

ISO2

IFugitive C.I

PM1O

Exhaust IPM70

PM10

Total

Fugitive

IPM2. 5

Exhaust

PM2. 5

I PM2. 5Total

I Blo CO2 NBio- CO2

1Total CO2i CH4 f N20 CO2e


r '

Archit. Coating 0.0154

ICO S'. SO2 r' Fugitive

PM10 I.

0. 0000 0. 0000 0.0000 0. 0000 0.0000 0. 0000 0. 0000 0. 0000 0.0000 0. 0000

Off -Road 6. 70000- 4. 5900e- 4. 6000e- 1. 000Oe- 3. 2000e- 3. 2000e- 3. 20000- 3. 2000e- 0. 0000 0. 6383 0.6383 5.0000e- 0. 0000 0.6397

0. 0000

004 003 003 005 004 ' 004 004 004

0. 0000 0. 0000 0. 0000

005

0. 0000 0. 0000

Total 0. 0161 4.59000- 4.60000- 1. 000Oe- 3. 2000e- 3. 2000e- 3. 2000e- 3. 20000- 0. 0000 0. 6383 0. 6383 5700e- 0, 0000 0. 6397

0. 0000 0. 0000

003 003 005 004 004 004 004

0. 0000 0. 0000 0. 0000

005

0. 0000 0. 0000


ROG

INOX

ICO S'. SO2 r' Fugitive

PM10 I.

I ExhaustPM10

I PM10Total

Fugitive

PM2.5Exhaust

PM2. 5

PM2.5

Total

Bio- CO2

INBio- CO2 Total CO2- CH4 N20 0O2e


Hauling 0. 0000 0. 0000 0. 0000 0.0000 0.0000

10. 0000 0. 0000 0. 00000. 0000

0. 0000

0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

Vendor 0. 0000 0. 0000 0. 0000 0.0000 0. 0000 0. 0000 0. 0000 0. 0000 0.0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

Worker 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000. 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

Total 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 1 0. 0000 0. 0000

171: 000 0. 0000 0. 0000


ROG

INOx CO r SO2

IFugitive : rExhaust

PM10 °. PM10

I PM10Total

Fugitive

PM2.5Exhaust

PM2. 5

TT5Total

Bio CO2 NBlo- CO2 Total CO2( CH4 1 N20 CO2e

Category tons/ yr MT/ Yr

Archit. Coating 0. 0154 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

Off - Road 1. 5000e-

004

3. 39000-

003

4.5800e- 1. 0000e-

003 005

2.4000e-

004

2.4000e-

004

2.4000e- 2A000e-

004 004

0. 0000 0. 6383 0. 6383 5. 0000e-

005

0. 0000 0. 6397

Total 0. 0156 3. 3900e-

003

4. 5800.- 1. 000Oe-

003 005

2.4000e-

004

2. 4000e-

004

2. 4000.- 2A000e-

004

1004

0. 0000

10. 6383 0. 6383 5. 00008-

005

0. 0000 0. 6397

1


ROG NOX CO SO2 - Fugitives

PM10 '::

Exhaust

PM10

F. 1M10

Total

Eugi- Uv e

PM2. 5

Exhaust

PM2. 5

PM2. 5

Total

Bto-. CO2 NBIo- 0O2 Total CO2 CH4 N20

ICO2e ' s


Hauling I 0. 0000I

0. 0000 0. 0000 0. 0000 0. 0000 0.0000 0. 0000 0. 0000 0.0000 0. 0000 0. 0000 0.0000 0. 0000 0.0000 0. 0000 0. 0000

Vendor 0.0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0.0000 0.0000 0. 0000 0. 0000 0. 0000

Worker 0. 0000 0. 0000 0. 0000 0.0000 0. 0000 0.0000 0. 0000 0. 0000 0.0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

Total 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0.0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000 0. 0000

ILL INGWt) / , / NG. 1111B Acoustics ® Air Quality 11

I bVillolvbrook Courl, ,Suile 120

Petaluma, California 94954

Tel: 707- 794- 0400 Iiat:: 707- 794- 0405

rtnvw. 111ing vorthroclkin. coin ilhrn@illingworthrodkin. com

Date: September 14, 2018

To: Natalie MatteiSenior Real Estate Manager




From: James A. Reyff & Fred M. SvinthIllingworth & Rodkin, Inc.

1 Willowbrook Court, Suite 120

Petaluma, CA 94954


SUBJECT: Safeway Fuel Center Health Risk Assessment, Air Quality and GreenhouseGas Emissions Assessment, and Noise Study - Response to Comments made

by Meridian Consultants - Job# 13- 205

This memo addresses comments made by Meridian Consultants in a letter dated September 12, 2018 to the Petaluma City Council regarding the City' s Mitigated Negative Declaration that usedinformation contained in studies prepared by Illingworth & Rodkin, Inc. ( I& R). These studies

included the Health Risk Assessment ( HRA), Air Pollutant and Greenhouse Gas Emissions

Assessment and the Environmental Noise Assessment.

AIR QUALITY AND HEALTI-t RISK

CalEEMod Modeling

The I -IRA and Air Pollutant and Greenhouse Gas Emissions Assessment modeled the project as a

16 -pump fuel station using default CalEEMod modeling settings. The 16 -pump fuel station landuse is assunned to include some sort of building structure, as is typical for such land uses. ' rhe

operational air pollutant and greenhouse gas ( GHG) emissions are associated with traffic generated

by the fuel station ( including idling of vehicles) and not the kiosk building. The addition of the697 - square foot building would have a negligible effect on the emissions modeling. CalEEMod

generates construction default conditions for projects based on the size range in acreage, which is


September 14, 2018 -- Page 2

based on surveys conducted by the South Coast Air Quality Management District ( SCAQMD) I. The project falls into the category of a I - acre project. Changing the acreage to 0. 7 acres or addingin the additional square footage of the kiosk building would not change the construction periodemissions ( this was verified with the model). Note that Safeway offered -and the City' s PlanningCommission conditioned the project to use, at a minimum, construction equipment that meets U. S.

EPA Tier 3 standards to reduce construction period emissions and associated health risks even

further than the less than significant amounts reflected in the reports.

As described above, the CalEEMod default construction assumptions were used. This included a

grading phase where the Commenter suggests a trenching phase should have been used in lieu ofthe CalEEMod defaults. CaIEEMod does not have a defined trenching phase and the model defaultsite preparation, grading and paving phases were assumed to include activity associated with theground work phase of the project. The Conunenter notes that there would be some export of

material not reflected in the modeling; however, that material would be used to balance the site. There would be approximately 75 truckloads of material need to complete the site balance that wasnot included in the modeling. This amount would not substantially affect the constructionemissions estimate. As shown in the HRA results for operation, the contribution of truck traffic

associated with annual operation of the project is negligible and the amount of truck traffic required

during construction would be less.

Health Risk Assessment

The Commenter claims that the HRA should have used the AERMOD dispersion model insteadof the ISCST3 model used. This was conducted in accordance with the Bay Area Air QualityManagement District' s ( BAAQMD) guidance, since there are representative meteorological data

available for Petaluma that are suitable for use with the ISCST3 model. There are no representative

meteorological data available for Petaluma that are suitable for use with the AERMOD model.

As described in the BAAQMD Recommended Methods for Screening and Modeling Load Risksand Hazards, refined modeling is recommended for projects in which the screening analysisexceeds the thresholds or a more site- specific characterization is required because it is complex

with multiple sources. Refined models such as ISCST3 and AERMOD require much more site-

specific information, but yield greater characterization of the project and more representativeresults. The BAAQMD recommended models for use in refined modeling analysis include theISCST3 and AERMOD models. 2

While the AE1640D dispersion is the current EPA recommended refined dispersion model for

regulatory applications, as described in the EPA Guideline on Air Qualio Models, the EPA' sISCST3 refined dispersion model is considered an alternative model that can be used when

approved by the reviewing regulatory ( i. e., the BAAQMVm As detailed above, the current

BAAQMD modeling guidance recommends the use of cither the AERMOD or ISCST3 modelsfor CEQA related health risk assessments.

CalEEMod Users Guide, Appendix. E, Technical Source Documentation, Appendix E1, ppE- 1 through E- 4.

2 Recommended Methods for Screening and Modeling Local Risks and Hazards, Bay Area Air Quality Management DistrictBAAQMD). May 2012.

l Guideline on Air Quality Models, Appendix W of 40 CFR Part 51.

Memo to Matalie Mattei

September 14, 2018 -- Page 3

For this project, local meteorological data for use in the AF,RMOD model was not available from

the BAAQMD. However, hourly meteorological data for use with the ISC,ST3 model from thePetaluma Airport meteorological station were available from the BAAQMD and used for the

refined modeling in the IIRA. Diesel. Fuel

Operation of the project was modeled as only dispensing gasoline, The reactive organic gas ( ROG) emissions from diesel are negligible when compared to gasoline. For this reason, the BAAQMD

permit does not specifically address diesel fuel storage and dispensing. Volatility is a property ofa liquid fuel that defines its evaporation characteristics and emissions potential. The vapor

pressure of a fuel is a common measure of the volatility or potential for evaporative emissions tooccur. The higher the vapor pressure of the fuel, the greater the potential for evaporative

emissions, The vapor pressure of diesel fuel is about 500 tidies lower than that of gasoline,

depending on the gasoline formulation being used and time of year'. Therefore, evaporative ROG

emissions from diesel fuel are negligible. This is the reason why fuel nozzles for diesel fuel pumpsgreen nozzles) do not have vapor recovery devices on them while the gasoline nozzles do,

GREENHOUSE GAS Em-ISSIONS

A full analysis of the project' s greenhouse gas ( GHG) emissions was conducted. The project' s

Air Pollutant and Greenhouse Gas Emissions Assessment computed air pollutant and GHG

emissions with the CalEEMod model using a 16 -pump Gasoline/ Service Station land use andfound them to be less than the 1, 100 metric ton threshold. So, the MNID' s finding that theseemissions are below the thresholds is well supported by the modeling results contained in the airquality studies. We note that the computations of operational emissions included conservative

assumptions:

Use of the CalEEMod default customer travel length of over 7 miles instead ofa 3 milesdistance for the typical travel length in Petaluma ( i. e., the emissions modeling assumes

customers, on average, would travel 7 miles to purchase fuel) and

The addition of idling emissions that assume maximum queuing is occurring all day, whilethe default CalEEMod mobile emissions account for some idling.

NOISE

Calculation of Noise bevels at Sensitive Receptors vs. Proper1y binesThe noise analysis considers impacts at the location of the actual sensitive receptors which follows

the intent of the City' s IZO that impacts should be evaluated at public or private open/ outdoorspaces where noise sensitive users will actually be present. As such the front yards of the

residences across South McDowell Blvd, while technically private open space, are not truly usedfor outdoor enjoyment due to visual and noise exposure to South McDowell traffic. Similarly, theschool lands between the Maria Drive property line and the school building are generally used forstorage and other passive use with active outdoor play areas beyond the building setbacks.

However, even if the analysis were to consider noise levels at the property tines of these usesaverage project -operational noise levels in these areas would only increase by up to 2 dBA, would

4t1. S. FPA AP -42 Volume of Emission Factors, Section 7. 1 Organic. Liquid Tanks, September 1997.

4

Mento to Natalie Mattci

September 14, 2018 — Page 4

remain either below or within the range of current daytime and nighttime noise levels at the

adjacent noise sensitive uses as found in the analysis and would not result in noise impacts greater

than what are discussed in the MND.

Construction Noise Impacts

The establishment of intermittent high noise levels of 70 to 85 dBA is based on the Typical Ranges

of Leq Construction Noise Levels per the U.SYPA document and accepted fixed sourceattenuation rates referenced in the report. The use of the criteria, which holds that temporaryconstruction activities that produce noise levels exceeding 60 dBA Leq or the ambient noiseenviromnent by 5 dBA Leq for a period greater than I year, is established to address CEQA noisechecklist item d1 and in doing so defines temporary as less than I calendar year ( or building season) and substantial as 60 dBA Leq ( the City general Plan Ambient) or 5 dBA (considered a significantincrease). This significance criteria is a well- established measure for evaluating construction noisesignificance and I& R has used it in many past and current noise studies in Petaluma and throughoutCalifornia. Although existing residences and the adjacent school have the potential to beintermittently exposed to noise levels ranging from 70 to 85 dBA, project construction would notexceed 60 dBA Leq or the ambient noise environment by 5 dBA Lcq for a period greater than Iyear.

Noise Source Levels

Vehicle noise source levels used in the report are based on I& R' s measurement experience and

California Reference Energy Mean Emissions Level ( RJMELS) modeling values. Though our

measurement experience with vehicular levels vary ( thus the range given), the REMELS model

predicts sound levels of 57 dBA at 25 feet due to a passenger car traveling at 15 mph, and soundlevels of 74 dBA at 50 feet due to a heavy truck traveling at 15 mph. These levels are well withinthe sound level range given in the report.

We would further note that heavy traffic noise source level of 60 dBA at 300 feet referenced bythe commenter are from the CalTrans Technical Noise Supplement, which relates to heavy

highway or roadway traffic and not sound levels produced by individual vehicles or even lighttraffic.

The mechanical equipment noise source levels used in the report are also based on I& R' s

measurement and design experience with commercial HVAC equipment and were given as a wide

range of sound levels to conservatively allow for the possibility of very loud equipment use. Asnoted in the report, equipment sound levels will vary significantly depending upon the equipmenttype and size and could not be fully determined at the time of the report due to schematic natureof the design. In practice we expect that mechanical equipment will produce levels at or below 70

to 80 dBA at 3 feet as noted in the report.

Increases and Decreases in Traffic Noise Levels

As per commonly accepted acoustical practice, the increases and decreases in traffic noise levelswere calculated as a function of the logarithmic relationship of the relative increases in A.M. andP. M. peak hour existing and cumulative traffic volumes with the project compared to the existingand cumulative conditions A.M. and P. M. peak hour conditions without the project.

5 " Would the project result in a substantial temporary or periodic increase in ambient noise levels in the projectvicinity above levels existing without the project?"


September 14, 2018 — Page S

Reduction of "Conditionally Acceptable" to " Normally Acceptable" Noise LevelsBased on the results of the noise measurement survey and noise analysis, the noise sensitive usesin the project area are currently exposed to " conditionally acceptable" noise levels. The

implementation of the project will not cause a significant noise increase, and not would not

decrease the acceptability of the noise environment at these uses. Furthermore, the project is notrewired to reduce the existing noise envirouunent at the adjacent noise sensitive uses to levelsbelow those which currently exist.

Exhibit C

mwoRTH & RoDKiN / vc. 1l Acoustics - Air Quality / 1

1 PHIlowbr• ook Court, Suite. 120

Petalurun, California 94954

Tel: 707- 794- 0400 Iax: 707- 794- 0405

tvx, iv.illirrgnt, ortlu•odk-irn. eonr illr,o a illingtt, or•tlu,odlcirr. eonr

Date: May 4, 2014

To: Natalie Mattei


Albeitsons Companies




I Willowbrook Court, Suite 120

Petaluma, CA 94954


SUBJECT: Safeway Fuel Center Health Risk Assessment, Response to Comment madeby ESA - Jobll13- 205

We reviewed the comments made by ESA, dated May 7, 2014, and have the followingresponses:

1, Inconsistency with CARB' s Air Quality and Iaand Use Handbook. The commenter

states that the fueling station being 50 feet away from North Bay Children' s Center and McDowellElementary School is too close, citing the California Air Resources Board' s ( CARR) Air Qualityand Land Use Handbook: A Community Health Perspective, April 2005 ( CARB Handbook).

Response: The recommendations in the referenced handbook are inapplicable and outdated. As

an advisory, non- binding document, the CARR Handbook recommends to avoid siting newsensitive land uses within certain proximity of specified gas stations. The Project fuel center doesnot qualify as a sensitive land use such that the recommended guidance does not apply.

Moreover, the analysis conducted for the CARB Handbook ( 2005) was developed using emissionfactors developed in 1999. Since then, CARB has adopted a number of significant advancements

as part of the Enhanced Vapor Recovery ( EVR) program. Phase I EVR, which addresses transferof bulk fuel from transfer tracks, requires more durable and leak - tight components, along with an

Memo to Natalie Matlei

May 8, 2013 -- Page 2

increased collection efficiency of 98 percent. Phase 11 EVR, which addresses fueling of vehicleswho purchase gasoline, includes three major advancements: ( 1) dispensing nozzles with lessspillage and required compatibility with onboard refueling vapor recovery ( ORVR) vehicles, ( 2) a processor to control the static pressure of the ullage, or vapor space, in the underground storage

tank, and ( 3) an in -station diagnostic (. ISD) system that provides warning alatins to alert the

facility operator of potential vapor recovery system malfunctions. Phase I EVR was fullyimplemented in 2005. Phase II EVR was fully implemented between 2009 and 2011. In addition, a majority of the vehicles on the road today have onboard vapor recovery systems. These systemswere phased in beginning with 1998 model year passenger vehicles, and are now installed on allpassenger, light- duty, and medium -duty vehicles manufactured since the 2006 model year. Whenan ORVR vehicle is fueled, almost all the gasoline vapor displaced from the fuel tank is routedto a carbon canister in the vehicle fuel system. As a result of these achievements, emissions of

TACs from gasoline fueling stations are substantially reduced, as indicated in newer emissionfactors developed by CARB in 2013. The guidance in the CARB Handbook thus is out of date,

and it should be noted that the Bay Area Air Quality Management District ( BAAQMD) issued apermit for the facility and allowed a throughput of over 3 times what the facility is anticipated togenerate. BAAQMD was aware of the sensitive receptors nearby when evaluating the permit andnotified the school district and school parents of the pending permit application on August 22, 2013. The City also provided Notice of Intent to Adopt Mitigated Negative Declaration andPublic Hearing to the school district on April 5, 2018.

2. Predicted fuel throughput. The conunenter claims that the analysis underestimated

risks by one- third because it did not use the annual throughput that BAAQMD permitted.

Response:

As stated in the report, the analysis used the throughput that Safeway anticipates generatingbased on market research data. The throughput permitted by BAAQMD is an unrealistic amountthat was calculated based on results of their screening assessment. Safeway does not anticipateto sell anywhere near that much gasoline. Even under the hypothetical scenario, the operational.

risks at the school would increase by a factor of 3 from 0. 69 chances per million to 2. 04 chancesper million such that the overall risk that includes project construction would be 7. 9 chances per

million. This is less than the significance threshold of 10 chances per million. The result of this

unreal scenario does not change the study conclusions.

3. Emission source release height. The comment states that the HRA modeling used

higher release heights that what are normally used.

Response:

Construction: There have been various methods applied to address dispersion modeling ofconstruction sites. The assessment used a release height of 6 meters ( 20 feet) to reflect the elevated

exhaust stacks of equipment plus the plume rise associated with the exhaust momentum and

thermal buoyancy. The 6meter release height used for modeling of the project' s construction

Memo to Natalie Maffei

May 8, 2018 — Page 3

equipment exhaust DPM emissions is considered a conservative estimate of the overall plume

height and incorporates both the release height from the construction equipment ( i. e., the height ofthe exhaust pipe) and plume rise after it leaves the exhaust pipe. Plume rise is due to both the

temperature of the exhaust and the high velocity of the exhaust gas. It should be noted that whenmodeling an area, source plume rise is not calculated by the dispersion model as it is for a pointsource. Therefore, the release Height from an area source used to represent emissions from sources

with plume rise, such as construction equipment, is properly based on Nle expected height of theexhaust plume, not just the height of the top of the exhaust pipe.

The use of a 6 -meter release height is consistent with release heights used by the GARB whenmodeling diesel particulate matter ( DPM) health risk impacts from construction activities. In

describing the methodology used for modeling of DPM emissions from area sources, CARB statesSensitivity studies have shown that there is an initial plume rise fi•om the equipment due to upward

buoyancy and momentum. The release heights of these arca sources were determined to be 5 —

10 meters ( m) depending on equipment type during operation times."' Thus, use of a 6 meter area

source release height is considered appropriate and consistent with CARB regulatory modeling.

On -Road Traffic: Again, there are various methods used to model dispersion fi-om traffic. For

modeling exhaust and fugitive PM2, 5 dust emissions from vehicles on nearby roads the emissionrelease height for heavy- duty vehicles ( trucks) was 3. 4 meters ( 11 feet) and the release height forlight- duty vehicles was 1. 3 meters ( 4. 3 feet). These values are based on release heights

recommended by the US EPA for use in modeling vehicle PM2, 5 emissions ( TransportationConformity Guidance for Quantitative Hot -spot Analyses in PMzs and PMro Nonattainnrent andMaintenance Areas, Appendix J: Additional Reference Information on Air Quality Models andData Inymts.' US EPA December 2010). These release heights are representative of the release

heights from the mix of different types of trucks and other vehicles that comprise the general

categories of heavy-duty and light-duty vehicles.

4. Receptor height for school children.

Response:

The comment is correct in that in the BAAQMD' s Reco n vended Methods for Screening andModeling Local Risks and Hazards ( May 2012) states that " the default value is assumed to be 0. 0m ( i. e., ground -level receptors), but the user may enter 1. 5 meter to represent the height of an averageadult." That is, use of a representative breathing height of a representative individual is appropriatefor use in calculating health risks. In this case, an average breathing height of 1. 5 meters for an adultis acceptable. For a child, use of 1. 0 -meter breathing height is a reasonable assumption for a childsitting or standing in the school area. It would be unreasonable to assume that the children at the schoolwere at a breathing height of 0. 0 meters ( i. e., lying down on the floor) for 10 hours per day.

IJowever, even if a 0. 0 -meter breathing height were used for the modeling there would be no changein the reported cancer risk. Use of a 0. 0 -meter receptor height instead of a 1. 0 -meter receptor height

1 Technical Support Document; Proposed Regulation for 1n - Use Off -Road Diesel Vehicles. California Air Resources Board.

April 2007.


May 8, 2018 m Page 4

would result in benzene concentration being increased by such a small amount ( i. e., 0. 0002 nicrogramsper cubic meter) that the computed cancer risk would not change.

S. Teacher exposure omitted or under estimated.

Response:

The evaltration focused on identifying the maximum health impacts that would occur and thesewould be for a child. An adult exposure would occur for a longer duration ( 40 years instead of 9

years) at a lower age sensitivity factor (ASF = 1 for adult and 3 for a child/ student) and at a lowerbreathing rate ( 261 L/ kg for an adult instead of 572 L/kg for a child). Thus, the teacher cancer risk

would be 70% that of a student and similarly less than significant. It would actually be a little bitlower since the receptor height for a teacher would be greater than 1. 0 meter and the concentration

at the increased height would be marginally lower.

6. Meteorological ( MET) data.

Response:

The meteorological data used for the HRA were obtained from the BAAQMD and are the same

data that the BAAQMD used in modeling impacts from roadways and developing health riskscreening tables described in Reconnnended Methods for Screening and Modeling Local Risks andHazards ( May 2012). As described by the BAAQMD, " Meteorological data used were the latest

year available for each of 64 stations in the Bay Area. Most of the observed meteorological datawere from the period 2000 to 2008, but earlier years were used to maximize spatial coverage. The

earliest data set used was from 1970. These years were all assumed to be representative ofcurrentmeteorological conditions." ( emphasis added.)

7. Pollutant of Concern,

Response:

The comment is correct that there are other TAG components present in gasoline vapors. The

health risk evaluation for gasoline vapors followed the recommendations of CARB' s Gasoline

Service Station Industy-wide Risk Assessment Guidelines, California Air Pollution ControlOfficers Association ( December 1997 and revised November 1, 2001). As discussed in the

Guidelines, " the cancer risk from benzene is by far the determining risk factor compared to theother substances identified in gasoline. Therefore, only benzene emissions are used in this riskassessment procedure." Other compounds in gasoline vapor would insignificantly contribute tocancer and non -cancer health impacts and were not evaluated as part the HRA per the CARR

guidance.


May 8, 2018 — Page 5

8. Omitted cumulative impacts from nearby gas stations.

Response:

The gasoline stations that the commenter is referring are over 1, 000 feet from the project and thesensitive receptors and therefore, were not considered in the analysis. The Chevron Station is over

1, 100 feet from North Bay Children' s Center/ McDowell Elementary and the Plaza Gas stationUnocal) is about 1, 400 feet. Using screening data obtained from BAAQMD' s Google Earth

Stationary Source Tool and adjusting the distance for 1, 000 feet ( furthest that BAAQMD

adjustment factors apply) indicates that the increase in cumulative cancer risk caused by thosestations would be less than 2 chances per million — an insignificant amount.

9. HRA guidance.

Response:

This assessment addresses the BAAQMD CEQA Guidelines thresholds for community riskimpacts that apply to sensitive receptors ( e. g., school children and residents). It should be noted

that BAAQMD issued a permit for the facility that would have addressed impacts from gasolinedispensing for all types of receptors. The assessment followed the BAAQMD Air Toxies NSR

Program Health Risk Assessment ( HRA) Guidelines ( December 201 G) in evaluating healthimpacts at sensitive receptors. Impacts to worker receptors were not evaluated. The comment is

correct in that the BAAQMD HRA guidance ( section 2. 2) for gasoline dispensing facilitiesspecifies using older 2003 & 2009 OEI4FIA risk assessment guidance. For a student ( child)

exposure the only difference between the current BAAQMD guidance and the previous 2003 & 2009 OEHHA guidance is in the value used for a child breathing rate. The current BAAQMD

guidance specifies a child breathing rate of 572 L/ kg-day while the 2003 OEFIHA guidancespecifies a breathing rate of 581 L/kg-day.

The school child cancer risk from benzene emissions fi•onn the proposed gasoline dispensingfacility would increase by 0. 01 in one million when using the 2003 OEHHA guidance comparedto the current BAAQMD guidance. That is the contribution to increased cancer risk would change

from 0. 39 in one million (new BAAQMD guidance) to 0. 40 in one million ( 2003 & 2009 OEHHA

guidance. The increased cancer risk is still far less than significant.

imf - granicus

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