appendix air quality assessment and technical …

Appendix C

AIR QUALITY ASSESSMENT AND TECHNICAL MEMORANDUM

BLUE MOUNTAIN MINERALS AGRICULTURAL FILL REVISION AIR ASSESSMENT

Prepared for Portola Minerals Company 24599 Marble Quarry Road Columbia, CA 95310

May 11, 2012

URS Corporation 1333 Broadway, Suite 800 Oakland, CA 94611 510-893-3600

TABLE OF CONTENTS

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Executive Summary ............................................................................................................................... ES-1

Section 1 Settings/Affected Environment .............................................................................................. 1-1

1.1 Introduction .............................................................................................. 1-1 1.2 Regulatory Setting ................................................................................... 1-3

1.2.1 Federal.......................................................................................... 1-3 1.2.2 State.............................................................................................. 1-7 1.2.3 Local ............................................................................................ 1-8 1.2.4 Greenhouse Gases ........................................................................ 1-8

1.3 Physical Environment ............................................................................ 1-11 1.3.1 Climate, Topography, and Atmospheric Conditions

Affecting Dispersion .................................................................. 1-11 1.3.2 Existing Conditions .................................................................... 1-12 1.3.3 Emissions Inventory................................................................... 1-12 1.3.4 Sensitive Receptors .................................................................... 1-13 1.3.5 Toxic Air Contaminants (TACs) ............................................... 1-13

Section 2 Impacts ..................................................................................................................................... 2-1

2.1 Significance Criteria ................................................................................ 2-1 2.1.1 CEQA Thresholds ........................................................................ 2-1 2.1.2 Greenhouse Gas ........................................................................... 2-1 2.1.3 Offensive Odors ........................................................................... 2-1 2.1.4 Toxic Air Contaminants ............................................................... 2-1

2.2 Methodology ............................................................................................ 2-2 2.2.1 Hauling Exhaust Emissions (Criteria Pollutants and GHGs) ...... 2-2 2.2.2 Fugitive Dust ................................................................................ 2-3

2.3 Impacts ..................................................................................................... 2-3 2.3.1 Material Handling Emissions – Equipment, Fugitive Dust,

and Haul Trucks ........................................................................... 2-3 2.3.2 Greenhouse Gases ........................................................................ 2-6 2.3.3 Toxics – Diesel Particulate Matter ............................................... 2-6 2.3.4 Naturally-occurring Asbestos ...................................................... 2-6

2.4 Cumulative ............................................................................................... 2-6

Section 3 References ............................................................................................................................... 3-1

TABLE OF CONTENTS

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Tables Page Table 1-1 National and California Ambient Air Quality Standards ............................................ 1-4

Table 1-2 Criteria Pollutants Health Effects ................................................................................ 1-6

Table 1-3 Federal and State Attainment Status............................................................................ 1-7

Table 1-4 Summary of State of California Relevant Greenhouse Gas Regulations .................... 1-9

Table 1-5 Tuolumne County 2010 Emissions Inventories ........................................................ 1-12

Table 1-6 Summary of Pollutant Monitoring Data in Sacramento Sonora-Barretta Street Monitoring Station ..................................................................................................................... 1-13

Table 2-1 Tuolumne County CEQA Mass Emissions Thresholds .............................................. 2-1

Table 2-2 Unmitigated Material Handling Equipment Exhaust Emissions (tons/year) .............. 2-4

Table 2-3 Unmitigated On-Site Haul Truck Emissions ............................................................... 2-4

Table 2-4 Unmitigated Fugitive Dust Emissions (tons/year) ..................................................... 2-4

Table 2-5 Revision Summary: Unmitigated Emissions (tons/year) ............................................ 2-5

Table 2-6 Revision Summary: Unmitigated Emissions (lbs/day)................................................ 2-5

Appendices A Air Quality Emissions and Calculations

Acronyms and Abbreviations APCD Air Pollution Control District

BMP best management practice

CAAQS California Ambient Air Quality Standards

CARB California Air Resources Board

CCAA California Clean Air Act

CEQA California Environmental Quality Act

CO carbon monoxide

EPA Environmental Protection Agency

GHG greenhouse gas

NAAQS National Ambient Air Quality Standards

NO2 nitrogen dioxide

NOA naturally occurring asbestos

O3 ozone

OEHHA Office of Environmental Health Hazard Assessment

Pb lead

TABLE OF CONTENTS

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Acronyms and Abbreviations (continued) PM particulate matter

PM2.5 fine particulate matter

PM10 inhalable particulate matter

SIP State Implementation Plan

SO2 sulfur dioxide

TAC toxic air contaminants

Air Quality Assessment

ES-1

EXECUTIVE SUMMARY The proposed Agricultural Fill Area revision is to the southeast of the existing Agricultural Fill Area and will include fill placed on 26.7 acres of the natural hillside to an elevation of about 2,100 feet. An air quality impact analysis was performed for the proposed revision and includes:

• Estimation of activity schedule, equipment, and effort as measured in hours

• Descriptions of the affected environment

• Analysis of air quality attainment status for criteria pollutants

• Description of methodology and calculation of air quality emissions

• Potential air quality impacts

• Cumulative effects This report analyzes federal and state criteria pollutants, as well as toxic air contaminants (TACs) identified by the Federal Clean Air Act and California Clean Air Act (CCAA). The revision would temporarily increase both criteria pollutants and TACs. The TAC of interest to this revision is diesel particulate matter. Source of air pollutants include equipment operations, on-site haul trucks, and earth disturbance activities (entrained road dust and material handling) that create fugitive dust. All pollutant emissions would be below the Tuolumne County Air Pollution Control District (APCD) daily and annual (California Environmental Quality Act (CEQA) thresholds, requiring no mitigation measures. Greenhouse gas (GHG) emissions would occur as a result of the revisions activities, but these emissions would be less than 0.01% of the state GHG inventory, and therefore would not prevent the attainment of AB32 goals.

The estimated emission inventories are presented below.

Revision Summary: Unmitigated Emissions (tons/year)

Activity ROG NOx CO PM10 PM2.5 SO2 CO2 Material Handling Equipment Exhaust 0.03 0.31 0.44 5.18E-04 5.18E-04 0.02 50.80

On-Site Haul Truck Delivery 0.03 0.19 0.06 5.60E-04 5.15E-04 0.00E+00 39.50

Fill Material Handling 0.02 3.01E-03

On-Site Haul Truck Fugitive Dust 13.17 1.32

TOTALS 0.06 0.50 0.49 13.20 1.32 0.02 90

TCAPCD CEQA Thresholds 100 100 100 100 N/A N/A N/A

Air Quality Assessment

ES-2

Revision Summary: Unmitigated Emissions (lbs/day)

Activity ROG NOx CO PM10 PM2.5 SO2 CO2 Material Handling Equipment Exhaust 1.25 13.18 18.57 0.02 0.02 0.79 2,162

On-Site Haul Truck Delivery 1.19 8.15 2.37 0.02 0.02 - 1,680.77

Fill Material Handling 0.84 0.13


TOTALS 2.44 21.33 20.94 396.13 39.70 0.79 3,842


Notes: CEQA = California Environmental Quality Act CO = carbon monoxide CO2 = carbon dioxide NOx = nitrogen dioxide PM10 = respirable particulate matter measuring less than 10 microns PM2.5 = fine particulate matter measuring less than 2.5 microns ROG = reactive organic gas SO2 = sulfur dioxide TCAPCD = Tuolumne County Air Pollution Control District

SECTIONONE Air Quality Assessment Settings/Affected Environment

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1. Section 1 ONE Settings/Affected Environment

1.1 INTRODUCTION Portola Minerals Company (“PMC”), dba Blue Mountain Minerals, owns and operates a

carbonate rock quarry located at 24599 Marble Quarry Road, near the community of Columbia in Tuolumne County, California. The quarry is commonly referred to as the Blue Mountain Minerals quarry. The mining operations currently include an agricultural fill area that encompasses approximately 48 acres, located at the southeast edge of the quarry site. PMC proposes to revise the fill area by including approximately 27± acres to the southeast of the approved fill area.

By way of background, reclamation of the quarry was first approved in 1984. In 2005, the County approved a conditional use permit and reclamation plan. The 2005 approvals consolidated mining operations on two contiguous mining operations – the Blue Mountain Minerals quarry and the Columbia Quarry – under one use permit. In 2008, the County approved a minor amendment to the reclamation plan. The reclamation plan specifies depositing waste materials in the agricultural fill area or in other authorized waste sites (e.g., fully excavated mine pits), and for the progressive revegetation of the new landscape created by these deposited waste piles.

The agricultural fill material is primarily comprised of rock, clay, and soils mined directly from the pit, along with other waste rock products from the processing plant such as silt and clay excavated from wash-water settling ponds. The fill is placed in a manner to limit surface runoff, and slope preparation and revegetation are ongoing as the fill is placed. At its highest point, the finished grade of the approved agricultural fill area will reach approximately 2,055 feet. Maximum slopes of the approved fill are a 2 to 1 ratio for most of the perimeter, (with a 3 to 1 slope ratio on the perimeter near two springs located within lands owned by PMC), and a gently sloping 5 to 1 slope ratio designed for the top surface of the fill.

In order to maximize the use of the carbonate rock resource in compliance with the Surface Mine and Reclamation Act as mandated by both the State of California and Tuolumne County, PMC now seeks to revise the approved agricultural fill area to accommodate its current operations. The type of material deposited in the agricultural fill area will not change, only its shape. The revision will include fill placed on 26.7 additional acres of the natural hillside to an elevation of about 2,100 feet. This revision would result in a portion of the fill currently proposed to be deposited in the “east fill” area under the current reclamation plan to be shifted to the revised agricultural fill area. The total volume of fill material would not change; only the location would change. Also, an additional amount of fill will be placed on top of the currently permitted fill surface. At its highest point, the finished grade of the revised agricultural fill area will reach an elevation of 2,135 feet. Maximum slopes of the revised fill area will not exceed natural slopes on adjacent hillsides, and will be less steep than the currently approved fill design. A 3 to 1 slope ratio will be followed around the perimeter, instead of a 2 to 1 ratio. The final upper surface of the revised fill area will be nearly flat.

The revised fill area plan will be consistent with the standards set forth in the approved reclamation plan, including fill timing and procedures, grading, erosion control, and revegetation. The reclamation plan includes procedures for ensuring erosion and sedimentation control along and on the fill surface through perimeter berms, revegetation, maximization of


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sheet flow, designed spillways, silt fencing and/or straw wattles, and containment of runoff. Upon the conclusion of reclamation activities, the agricultural fill area will recreate a combined landscape of mixed oak woodland and annual grassland as wildlife habitat and agricultural open space.


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1.2 REGULATORY SETTING Air quality management and protection responsibilities exist in federal, state, and local levels of government. The primary statutes that establish ambient air quality standards and establish regulatory authorities to enforce regulations designed to attain those standards are the federal Clean Air Act (CAA) and California Clean Air Act (CCAA).

The enforcement of federal and state air statutes and regulations is complex and the various agencies have different, but inter-related responsibilities. The U.S. EPA is responsible for establishing the National Ambient Air Quality Standards (NAAQS), setting minimum New Source Review permitting and Operating Permit requirements for stationary sources; establishing New Source Performance Standards, National Emission Standards for Hazardous Pollutants and the Acid Deposition Control program; and administering regional air quality initiatives. The California Air Resources Board’s (CARB’s) role includes development, implementation, and enforcement of California’s motor vehicle pollution control program, administration of the state’s air pollution research program, adoption and updating, as necessary, of California Ambient Air Quality Standards (CAAQS), review of local air pollution control district (APCD) activities, and coordination of the development of the State Implementation Plan (SIP) for achievement of the national ambient standards. Local APCDs are responsible for implementing federal and state regulations at the local level, permitting stationary sources of air pollution, and developing the local elements of the SIP. Emissions from indirect sources, such as automobile traffic associated with development projects, are addressed through the APCD’s air quality plans, which are each air quality district’s contribution to the SIP.

1.2.1 Federal

1.2.1.1 Clean Air Act As required by the Federal CAA, the U.S. EPA has established and continues to update the NAAQS for specific “criteria” air pollutants: ozone (O3), carbon monoxide (CO), nitrogen dioxide (NO2), sulfur dioxide (SO2), inhalable particulate matter (PM10), fine particulate matter (PM2.5), and lead (Pb). The NAAQS for these pollutants are listed in Table 1-1 and represent the levels of air quality deemed necessary by U.S. EPA to protect the public health and welfare with an adequate margin of safety. The health effects associated with these pollutants are summarized in Table 1-2 and discussed in more detail below.


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Table 1-1 National and California Ambient Air Quality Standards

Pollutant Avg Time

Standard, as parts per million by volume

(ppmv)

Standard, as micrograms per cubic

meter (ug/m3) Violation Criteria

California National California National California National

Ozone (O3)

1 Hour 0.09 N/A 180 N/A If exceeded N/A

8 Hour 0.07 0.075 137 147 If exceeded If exceeded on

more than 3 days in 3 years

Carbon monoxide (CO)

1 Hour 20 35 23,000 40,000 If exceeded If exceeded on

more than 1 day per year

8 Hour 9 9 10,000 10,000 If exceeded If exceeded on


8 Hour (Lake

Tahoe) 6 N/A 7,000 N/A If exceeded N/A

Nitrogen dioxide (NO2)

1 Hour 0.18 0.10 339 188 If exceeded

If exceeded based on 3-year average of 98th percentile of daily maximum

hourly values Annual 0.03 0.053 57 100 If exceeded If exceeded

Sulfur dioxide (SO2)

1 Hour 0.25 0.075 655 196 If exceeded

If exceeded based on 3-year average of 99th percentile of daily maximum

hourly average values

3 Hour(1) N/A 0.5 N/A 1300 N/A If exceeded on


24 Hour 0.04 N/A 105 365

If exceeded on more

than 1 day per year

If exceeded

Respirable particulate matter (PM10)

24 Hour N/A N/A 50 150 If exceeded

If exceeded more than once per year on average over

3 years.

Annual N/A N/A 20 N/A If exceeded

If exceeded based on 3-year average

on weighted annual mean concentration


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Table 1-1 National and California Ambient Air Quality Standards

Pollutant Avg Time

Standard, as parts per million by volume

(ppmv)

Standard, as micrograms per cubic

meter (ug/m3) Violation Criteria

California National California National California National

Fine particulate matter (PM2.5)

24 Hour N/A N/A N/A 35 N/A


of the 98th percentile of

24-hour concentrations

Annual N/A N/A 12 15 If exceeded


on weighted annual mean concentration

Lead

30 Day Average N/A N/A 1.5 N/A If exceeded

or equaled N/A

Calendar Quarter N/A N/A N/A 1.5 N/A If exceeded

Rolling 3-Month

Average N/A N/A N/A 0.15 N/A If exceeded

Sulfates 24 hour N/A N/A 25 N/A If exceeded or equaled N/A

Hydrogen sulfide 1 Hour 0.03 N/A 42 N/A If exceeded

or equaled N/A

Vinyl chloride 24 Hour 0.01 N/A 26 N/A If exceeded or equaled N/A

(1) Secondary standard Source: CARB 2010

In 2005, the U.S. Environmental Protection Agency (EPA) approved changes to the O3 and PM10 NAAQS. In place of the 1-hour ozone standard, the U.S. EPA approved an 8-hour standard of 0.08 parts per million (ppm). In 2008, the 8-hour standard was lowered to 0.075 ppm. In addition to the current PM10 standard, the U.S. EPA has approved standards for PM2.5. The U.S. EPA also established new NO2 and SO2 standards in 2010. Although these changes have been approved, implementation of the new standards and monitoring of ambient conditions relative to these new standards is an ongoing process.

1.2.1.2 Health Effects The following table (Table 1-2) provides a general description (including possible physical effects as well as potential health effects) of the air pollutants that could be emitted from the revision or are known in the area.


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Table 1-2 Criteria Pollutants Health Effects

Pollutant Characteristics Health Effects Major Sources

Carbon Monoxide Odorless, colorless gas that is highly toxic. Formed by the incomplete combustion of fuels.

Impairment of oxygen transport in the bloodstream. Aggravation of cardiovascular disease Fatigue, headache, dizziness.

Automobile exhaust, combustion of fuels, and combustion of wood in woodstoves and fireplaces.

Nitrogen Dioxide Reddish-brown gas formed during combustion.

Increased risk of acute and chronic respiratory disease.

Automobile and diesel truck exhaust, industrial processes, and fossil-fuel powerplants.

Ozone A highly reactive photochemical pollutant crated by the action of sunshine on zone precursors (reactive organic gases and oxide of nitrogen)

Eye irritation Respiratory function impairment

Combustion sources, such as factories, automobiles and evaporation of solvents and fuels

PM10 and PM2.5 Small particles that measure 10 microns or less are termed PM10 (fine particles less than 2.5 microns are PM2.5). Solid and liquid particles of dust, soot, aerosols, smoke, ash, and pollen and other matter that are small enough to remain suspended in the air for a long period.

Aggravation of chronic disease and heart/lung disease symptoms..

Dust, erosion, incinerators, automobile and aircraft exhaust, and open fires.

Sulfur Dioxide Colorless gas with a pungent odor. Increased risk of acute and chronic respiratory disease.

Diesel vehicle exhaust, oil-powered powerplants, industrial processes.

1.2.1.3 Attainment Status The Federal CAA requires states to classify air basins (or portions thereof) as either “attainment” or “non-attainment” with respect to criteria air pollutants, based on whether the NAAQS have been achieved for the air basins, and to prepare air quality plans containing emission reduction strategies for those areas designated as “non-attainment.” The Mountain Counties Air Basin and Tuolumne County, in which the Blue Mountain Mineral Project is located, is designated as a “Former Subpart 1” non-attainment area for the O3 NAAQS. This means that the area was formerly covered under Subpart 1, Part D, Title I of the Clean Air Act. “Subpart 1” is not a classification. Reclassification was proposed in January 16, 2009, and Tuolumne County would be reclassified as “marginal” nonattainment for O3 NAAQS. The Mountain Counties Air Basin and Tuolumne County attainment status for all criteria pollutants is listed in Table 1-3.


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Table 1-3 Federal and State Attainment Status

Pollutant State Status Federal Status

O3 Non-attainment Non-attainment (Former Subpart 1)

PM10 Unclassified Unclassified

PM2.5 Unclassified Unclassified/Attainment

CO Attainment Unclassified/Attainment

NO2 Attainment Unclassified/Attainment

SO2 Attainment Unclassified Notes: CO = carbon monoxide NO2 = nitrogen dioxide O3 = ozone

PM2.5 = Fine particulate matter, measuring less than 2.5 microns PM10 = Respirable particulate matter, measuring less than 10 microns SO2 = sulfur dioxide

1.2.1.4 State Implementation Plans Counties or regions that are designated as federal non-attainment areas for one or more criteria air pollutants must prepare a plan that demonstrates how the area will achieve attainment of the standards by the federally mandated deadlines. In addition, those areas that have been redesignated as attainment will have maintenance plans that demonstrate how the area will maintain the standard. These regional plans, prepared by local air districts, go into the SIP, which is compiled by the CARB and eventually approved by the U.S. EPA. These regional plans are themselves sometimes referred to as SIPs. SIPs are not single documents; rather, they are a compilation of new and previously submitted plans, programs (such as monitoring, modeling, permitting, etc.), district rules, state regulations, and federal controls. The proposed reclassification for the area has not been implemented yet. Therefore no approved SIP for O3 currently exists.

1.2.2 State

1.2.2.1 CCAA and State Standards The CCAA substantially increased the authority and responsibilities of the state’s air pollution control districts. The CCAA establishes an air quality management process that generally parallels the federal process. The CCAA, however, focuses on attainment of the CAAQS that, for certain pollutants and averaging periods, are more stringent than the comparable NAAQS. Similar to the designations for NAAQS, areas are designated as non-attainment, attainment or unclassified with respect to the CAAQS. The unclassified designation is given for a region where the data are absent or too limited for designation. Tuolumne County has been designated as non-


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attainment for CAAQS for O3 and is unclassified for PM10 and PM2.5. The CAAQS are included in Table 1-1 alongside the NAAQS.

1.2.3 Local

1.2.3.1 Tuolumne County Air Pollution Control District The Tuolumne County Air Pollution Control District (APCD) is responsible for implementing emissions standards and other requirements of federal and state laws regarding most types of stationary emission sources. CARB has determined that the ozone levels in Tuolumne County are caused by "overwhelming transport" from the San Joaquin Valley. Therefore, the APCD is relieved from preparing an attainment plan for ozone, and no other levels are high enough to require an attainment plan. Although there are no required attainment plans, or other local plans specifically addressing air quality, Tuolumne County must conform to existing state and federal air quality standards.

1.2.3.2 Tuolumne County General Plan The Tuolumne County General Plan provides goals, objectives, and policies designed to protect air quality in the area. The goal of the Air Quality Element is to strive to achieve and maintain ambient air quality standards established by the CARB and to minimize public exposure to toxic or hazardous air pollutants and air pollutants that create unpleasant odors. The objectives of the Air Quality Element include provisions for reducing vehicular emissions through land use and transportation planning. These objectives include the promotion of public transit; increased pedestrian and bicycle access to residences, schools, and civic centers; and the reduction of emissions from residential woodstoves and fireplaces, as well as open burning activities commonly associated with forest management practices. (Tuolumne County 1996)

1.2.4 Greenhouse Gases The U.S. EPA does not currently regulate greenhouse gas (GHGs) pollutants, those pollutants that could contribute significantly to global warming. However, in Massachusetts v. U.S. Environmental Protection Agency, et al., 549 U.S. 497 (2007), the United States Supreme Court ruled that GHG does fit within the CAA’s definition of a pollutant, and that EPA has the authority to regulate GHG. On December 7, 2009, the Final Endangerment and Cause or Contribute Findings for Greenhouse Gases (endangerment finding), under Section 202(a) of the CAA went into effect. The endangerment finding states that current and projected concentration of the six key well-mixed GHGs in the atmosphere (CO2, CH4, N2O, HFCs, PFCs, and SF6) threaten the public health and welfare of current and future generations. Furthermore, it states that the combined emissions of these well-mixed GHGs from new motor vehicles and new motor vehicle engines contribute to the GHG pollution that threatens public health and welfare (EPA 2011a).

Under the endangerment finding, EPA is developing vehicle emission standards under the CAA. EPA and the Department of Transportation’s National Highway Traffic Safety Administration have issued a joint proposal to establish a national program that includes standards that will reduce GHG emissions and improve fuel economy for light-duty vehicles in model years 2012


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through 2016. This proposal marks the first GHG standards proposed by the EPA under the CAA as a result of the endangerment and “cause or contribute” findings (EPA 2011b).

The State of California has been proactive in the study of impacts of climate change; it has a 20-year history of doing so. State actions to address global climate change target automobile emissions, stationary sources and power generation, land-use planning, and the development of sustainable communities. Table 1-4 presents summaries of the pertinent state legislation dealing with global climate change.

California is a substantial contributor of global greenhouse gases as it is the second largest contributor in the U.S. and the sixteenth largest in the world (CEC 2006). From 1990 to 2003, California’s gross state product grew 83 percent while GHG emissions grew 12 percent. While California has a high volume of GHG emissions, it has low emissions per capita. The major source of GHG in California is transportation, contributing 41 percent of the state’s total GHG emissions (CEC 2006). Electricity generation is the second largest generator, contributing 22 percent of the state’s GHG emissions. Emissions from fuel use in the commercial and residential sectors in California decreased 9.7 percent over the 1990 to 2004 period (CEC 2006). The decrease in greenhouse gases could demonstrate the effectiveness of energy conservation in buildings (Title 24 requirements) and appliances.

Table 1-4 Summary of State of California Relevant Greenhouse Gas Regulations

Bill, Year Action AB 4420, 1988, Directed California Energy Commission, in consultation with the CARB and other agencies,

to “study and report…on how global warming trends may affect California’s energy supply and demand, economy, environment, agriculture, and water supplies.”

Executive Order S-3-05, 2005

Establishes total greenhouse gas emission targets Emissions reduced to 2000 levels by 2010, 1990 levels by 2020, 80 percent below 1990 levels by 2050 Directs CalEPA to coordinate a multi-agency effort to reduce GHG emissions to target levels.

AB 32, 2006 California Global Warming Solutions Act of 2006

Requires statewide GHG emissions be reduced to 1990 levels by 2020 Requires reduction accomplished via enforceable statewide cap on GHGs to be phased in starting in 2012. Directs CARB to develop and implement regulations to reduce statewide emissions from stationary sources. Specifies that regulations adopted in response to AB 1493 be used to address GHG emissions from vehicles Requires CARB adopt a quantified cap on GHG emissions representing 1990 emissions levels Includes guidance to institute emissions reductions in an economically efficient manner and conditions to ensure that businesses and consumers are not unfairly affected by the reductions.

Senate Bill 1368, 2007

Companion bill to AB32. Requires CPUC to establish GHG emission performance standards for investor and publicly owned electrical generation facilities June 30, 2007. Requires all electricity provided to California, including imported, be generated by plants standards set by CPUC and California Energy Commission.


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Table 1-4 Summary of State of California Relevant Greenhouse Gas Regulations

Bill, Year Action Executive Order S-01-07, 2007

Governor Schwarzenegger set forth the low-carbon fuel standard for California. Under this executive order, the carbon intensity of California’s transportation fuels is to be reduced by at least 10% by 2020.

Senate Bill 375, 2008

Requires coordination between transportation planning and land use planning. Directs CARB to develop regional greenhouse gas emission reduction targets to be achieved from automobile and light truck sectors by 2020 and 2035 CARB will work with California’s 18 metropolitan planning organizations to align their regional transportation, housing and land-use plans and prepare a “sustainable communities strategy” to reduce vehicle miles traveled in their respective communities.

AB 1493, 2009 California adopted amendments to reduce GHG emissions in new passenger vehicles from 2009 through 2016.

Notes: CalEPA = California Environmental Protection Agency CARB = California Air Resources Board CPUC = California Public Utilities Commission GHG = greenhouse gas

1.2.4.1 Scoping Plans The CARB is the lead agency for implementing AB 32, which set the major milestones for establishing the program. AB 32 requires the CARB to prepare a Scoping Plan containing the main strategies that will be used to achieve reductions in GHG emissions in California. On June 26, 2008 ARB staff presented the initial draft of the AB 32 Scoping Plan to its Board for review. ARB has been revising this draft Scoping Plan based on continuing analysis and public input, which resulted in the development of the Proposed Scoping Plan, released in November 2008. The measures in the Proposed Scoping Plan will be developed over the next 3 years and be in place by 2012.

1.2.4.2 Climate Change and CEQA Greenhouse gas emissions are now being considered as a relatively new issue in CEQA documents because of their impacts to climate change. The CEQA amendments of December 30, 2009, specifically require lead agencies to address GHG emissions in determining the significance of environmental effects caused by a project, and to consider feasible means to mitigate the significant effects of GHG emission (California Natural Resources Agency 2011).

Provisions of the CEQA amendments include the following (Office of Planning and Research 2009):

• A lead agency may consider the following when assessing the significance of impacts from GHG emissions:


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(1) The extent to which the project may increase or reduce greenhouse gas emissions as compared to the existing environmental setting;

(2) Whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project;

(3) The extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of greenhouse gas emissions …

• When an agency makes a statement of overriding considerations, the agency may consider adverse environmental effects in the context of region-wide or statewide environmental benefits.

• Lead agencies shall consider feasible means of mitigating greenhouse gas emissions that may include, but not be limited to:

(1) Measures in an existing plan or mitigation program for the reduction of emissions that are required as part of the lead agency’s decision;

(2) Reductions in emissions resulting from a project through implementation of project features, project design, or other measures;

(3) Offsite measures, including offsets;

(4) Measures that sequester greenhouse gases;

(5) In the case of the adoption of a plan, such as a general plan, long-range development plan, or greenhouse gas reduction plan, mitigation may include the identification of specific measures that may be implemented on a project-by-project basis. Mitigation may also include the incorporation of specific measures or policies found in an adopted ordinance or regulation that reduces the cumulative effect of emissions.

1.3 PHYSICAL ENVIRONMENT

1.3.1 Climate, Topography, and Atmospheric Conditions Affecting Dispersion The general climate of the Mountain Counties Air Basin varies considerably with elevation and proximity to mountain peaks. The terrain features of the basin make it possible for various climates to exist within the general area. The pattern of mountains and hills is primarily responsible for the wide variations of rainfall, temperatures, and localized winds that occur throughout the region. Temperature variations have an important influence on basin wind flow, dispersion along mountain ridges, vertical mixing, and photochemistry. The Sierra Nevada mountain range receives large amounts of precipitation from storms moving over the continent from the Pacific Ocean. Precipitation in the basin is highly variable, depending on elevation and location. Areas in the eastern portion of the basin, have relatively high elevations, and receive the most precipitation. Precipitation levels decline toward the western areas of the basin. Climates vary from alpine in the high elevations of the eastern areas to more arid at the western edge of the basin.


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1.3.2 Existing Conditions

1.3.2.1 Constituents of Interest The existing air quality conditions for a project area are typically the result of meteorological conditions and existing emission sources in an area. For the current revision, the constituents of interest are the following:

• Carbon monoxide (CO)

• Ozone, including precursors nitrogen oxide (NOx) and reactive organic gas (ROG)

• Respirable particulate matter, measuring less than 10 microns (PM10)

• Fine particulate matter, measuring less than 2.5 microns (PM2.5)

1.3.3 Emissions Inventory Estimates of existing emissions in Tuolumne County for 2010 are presented in Table 1-5. There are two main categories of emission sources in any area: stationary and mobile. Mobile sources are the major source of NOx and ROG emissions in Tuolumne County. Miscellaneous sources, such as managed burning, are responsible for the majority of the CO, SO2, PM10, and PM2.5 emissions.

Table 1-5 Tuolumne County 2010 Emissions Inventories

Source Type Category

Average Emission in Tons Per Day (TPD)

VOC/ROG CO NOx SOx PM10 PM2.5

Stationary Fuel Combustion 0.0 0.7 1.2 0.4 0.4 0.4

Stationary Cleaning and Surface Coatings 0.2 - - - - -

Stationary Petroleum Production and Marketing 0.1 - - - - -

Stationary Industrial Processes 0.1 0.0 0.0 0.0 1.0 0.3

Area-wide Solvent Evaporation 1.2 - - - - -

Area-Wide Miscellaneous Processes 7.0 99.1 2.2 0.4 17.2 10.2

Mobile On-Road Motor Vehicles 2.1 19.1 2.4 0.0 0.1 0.1

Mobile Other Mobile Sources 6.3 40.0 3.4 0.0 0.4 0.3

Total 17.0 159.0 9.3 0.9 19.1 11.2

Notes: Numbers might not add up exactly due to rounding CEQA = California Environmental Quality Act CO = carbon monoxide CO2 = carbon dioxide NOx = nitrogen dioxide PM10 = respirable particulate matter measuring less than 10 microns

PM2.5 = fine particulate matter measuring less than 2.5 microns ROG = reactive organic gas SO2 = sulfur dioxide VOC = volatile organic compound Source: CARB 2011a


1-13

Monitoring Data – Criteria Pollutants Air quality data from the Sonora-Barretta Street monitoring station, which is about 8 miles from the site, are summarized in Table 1-6. The monitoring station was selected to best represent the regional conditions of the area of analysis and all relevant pollutants are sampled there.

The 1-hour ozone CAAQS had been exceeded up to 10 times in 2008 at the individual monitoring station shown in Table 1-6. The recorded 8-hour ozone concentrations exceeded the NAAQS up to 23 times in 2008. Substantial year-to-year variations in monitored ozone levels are common. However, no clear trend in ozone levels is demonstrated by monitoring results from 1992 through 2010.

Table 1-6 Summary of Pollutant Monitoring Data in Sacramento

Sonora-Barretta Street Monitoring Station

Criteria Air Pollutant

Yearly Monitoring Data(1)

2008 2009 2010

Ozone – 1 Hour Highest concentration (ppm) Days above CAAQS Days above NAAQS

0.149 10 2

0.091 0 0

0.103 2 0

Ozone – 8 Hour Highest concentration (ppm) Days above CAAQS Days above NAAQS

0.115 38 23

0.079 21 5

0.085 11 3

(1) Highest concentration displayed from the state and federal monitoring data. N/A – Not Available Source: CARB 2011b

1.3.4 Sensitive Receptors Some locations are considered more sensitive to adverse effects from air pollution than the others. These locations are termed sensitive receptors. For CEQA purposes, a sensitive receptor is generically defined as a location where human populations, especially children, seniors, and sick persons are found, and there is reasonable expectation of continuous human exposure according to the averaging period for the ambient air quality standard (e.g., 24-hour, 8-hour, and 1-hour). These typically include residences, hospitals, and schools. Locations of sensitive receptors may or may not correspond with the location of the maximum offsite concentration. The air quality analysis evaluates impacts at the worst-case location, typically adjacent to the source of emissions, regardless of the presence of a sensitive receptor.

1.3.5 Toxic Air Contaminants (TACs) In addition to the federal and state criteria pollutants, the federal Clean Air Act and California CCA have identified another class of pollutants. Hazardous air pollutants is a term used by the


1-14

federal Clean Air Act that includes a variety of pollutants that are known or suspected carcinogens and are generated or emitted by a wide variety of industries. Called TACs under the California Clean Air Act, 10 have been identified through ambient air quality data as posing the greatest health risk in California. Direct exposure to these pollutants has been shown to cause cancer, birth defects, damage to brain and nervous system and respiratory disorders. The TAC of interest to this project is diesel particulate matter.

TACs do not have ambient air quality standards because often no safe levels of TACs have been determined. Instead, TAC impacts are evaluated by calculating the health risks associated with a given exposure. The requirements of the Air Toxic “Hot Spots” Information and Assessment Act apply to facilities that use, produce, or emit toxic chemicals. Facilities that are subject to the toxic emission inventory requirements of the Act must prepare and submit toxic emission inventory plans and reports, and periodically update those reports.

The Tuolumne County area has been identified as an area where the local geology supports the formation of naturally occurring asbestos (NOA). Asbestos is a term used for several types of naturally fibrous minerals that are a human health hazard when airborne. The most common type of asbestos is chrysotile, but other types such as tremolite and actinolite are also found in California. Asbestos is classified as a known human carcinogen by state and federal international agencies and was identified as a toxic air contaminant by the CARB in 1986. All types of asbestos are hazardous and may cause lung disease and cancer. Serpentinite may contain chrysotile asbestos. Ultramafic Rock, a rock closely related to serpentinite, may also contain asbestos minerals.

As stated above, the Tuolumne County area has been identified as an area where the local geology supports the formation of NOA, Ultramafic rock specifically. However, no NOA has been found in the site area.

1.3.5.1 Diesel Particulate Matter Diesel particulate matter is emitted from both mobile and stationary sources. In California, on-road, diesel-fueled engines contribute approximately 24 percent of the statewide total, with an additional 71 percent attributed to other mobile sources such as construction and mining equipment, agricultural equipment, and transport refrigeration units. Stationary sources contribute about 5 percent of total diesel particulate matter.

In California, diesel exhaust particles have been identified as a carcinogen (California OEHHA and the American Lung Association 2005). Diesel exhaust and many individual substances contained in it (including arsenic, benzene, formaldehyde, and nickel) have the potential to contribute to mutations in cells that can lead to cancer. Long-term exposure to diesel exhaust particles poses the highest cancer risk of any toxic air contaminant evaluated by the California Office of Environmental Health Hazard Assessment (OEHHA). CARB estimates that about 70 percent of the cancer risk that the average Californian faces from breathing toxic air pollutants stems from diesel exhaust particles.

Exposure to diesel exhaust can have immediate health effects. Diesel exhaust can irritate the eyes, nose, throat, and lungs, and it can cause coughs, headaches, lightheadedness, and nausea. In studies with human volunteers, diesel exhaust particles made people with allergies more


1-15

susceptible to the materials to which they are allergic, such as dust and pollen. Exposure to diesel exhaust also causes inflammation in the lungs, which may aggravate chronic respiratory symptoms and increase the frequency or intensity of asthma attacks.

Diesel engines are a major source of fine-particle pollution. The elderly and people with emphysema, asthma, and chronic heart and lung disease are especially sensitive to fine-particle pollution. Numerous studies have linked elevated particle levels in the air to increased hospital admissions, emergency room visits, asthma attacks, and premature deaths among those suffering from respiratory problems. Because children’s lungs and respiratory systems are still developing, they are more susceptible than healthy adults to fine particles. Exposure to fine particles is associated with increased frequency of childhood illnesses and can also reduce lung function in children.

SECTIONTWO Air Quality Assessment Impacts

2-1

2. Section 2 TW O Impacts

2.1 SIGNIFICANCE CRITERIA Significance criteria are presented below for state levels, as the revision must comply with CEQA requirements.

2.1.1 CEQA Thresholds The CEQA thresholds of significance were obtained from the Tuolumne County APCD. The revision would only consider operational emissions from the material handling and hauling.

The Tuolumne County APCD has established daily and annual emission thresholds for ROG, NOx, PM10, and CO for projects in the county.

Table 2-1 Tuolumne County CEQA Mass Emissions Thresholds

Pollutant Daily Emission Thresholds

(lbs/day) Annual Emission

Thresholds (tons/year)

ROG 1,000 100

NOx 1,000 100

PM10 1,000 100

CO 1,000 100

Notes: CO =-carbon monoxide NOx = nitrogen dioxide PM10 = respirable particulate matter measuring less than 10 microns ROG = reactive organic gas Source: Tuolumne County APCD 2011

2.1.2 Greenhouse Gas A threshold of 7,000 metric tons of GHG emissions exists for stationary sources, but there are no GHG thresholds for mobile sources within Tuolumne County. For cases where there is no significance threshold, the GHG emissions are required to meet AB32 emission goals.

2.1.3 Offensive Odors Specific significance thresholds are not available for offensive odors; however, a project would be considered to have significant adverse air quality impacts if it causes detriment, nuisance, or annoyance to a considerable number of persons. Since the revision is not expected to have any short- or long-term impacts associated with offensive odors, no further analysis was conducted.

2.1.4 Toxic Air Contaminants The recommended significance thresholds for TACs include:

• Lifetime probability of contracting cancer is greater than 10 in one million;


2-2

• Ground-level concentration of non-carcinogenic toxic air pollutants would result in a Hazard Index of greater than 1.

These thresholds are based on long-term (70-year) exposure to TACs. The period of time for which diesel particulates would be emitted from the revision would occur only during the activity period, which would be less than 70 years. Cancer risk evaluations are based on a 70-year exposure period.

2.2 METHODOLOGY In general, the emissions were estimated from various emission models and spreadsheet calculations, depending on the source type and data availability. The CARB EMFAC2011 model (on-road vehicle emission factor model) and CARB OFFROAD2011 emissions model were used along with emission factors obtained from U.S. EPA AP-42 and Tuolumne County APCD CEQA guidelines. Daily and annual project emissions were estimated from appropriate emission factors, features being worked, and the associated schedules. The following sources and activities were analyzed for emissions:

• On-site material handling equipment emissions (all pollutants) – based on OFFROAD2011 emission factors for construction equipment in the Tuolumne County APCD and estimated equipment schedules.

• On-site and haul truck engine emissions (all criteria pollutants and CO2) – based on EMFAC2011 and estimated vehicle miles traveled.

• On-site haul truck entrained fugitive dust emissions for unpaved road travel – based on AP-42 methodology and estimated vehicle miles traveled.

• On-site material fill handling – based on AP-42 methodology, volume and surface area of storage pile, wind speed, and moisture content.

2.2.1 Hauling Exhaust Emissions (Criteria Pollutants and GHGs)

2.2.1.1 Off road Material Handling Equipment Off road equipment exhaust emissions were estimated using the OFFROAD2011 model. Forty-seven working days were used for the estimate for year 2012 in the Mountain Counties Air Basin. The type of equipment and horsepower were provided through discussions with Blue Mountain Minerals staff on July 7, 2011.

2.2.1.2 On-site Haul Trucks On-site haul truck exhaust emissions were estimated using EMFAC2011 model for Tier 4 heavy-heavy duty single unit construction diesel trucks in Tuolumne County. The emission factors were based on the EMFAC mode with a speed of 5 mph. Currently material is transported roughly 0.4 mile and will be transported an additional 1.2 miles (one-way) to the new site. According to discussions with Blue Mountain Minerals 220,000 tons of material will be transported over the 47 day per year period in haul trucks, each with a capacity of 60 tons. A maximum of 55 loads of material per day will be hauled. The haul trucks were assumed to make two one-way trips,


2-3

therefore the on-site haul trucks will travel a total distance of approximately 8,800 miles over the 47 day per year period and approximately 130 miles per day.

2.2.2 Fugitive Dust

2.2.2.1 Material Fill Handling Material handling emissions were estimated using AP-42 emission factors and the amount of material handled (EPA 2011c). The emission factor was based on the mean wind speed and material moisture content. The mean wind speed was taken from the Stockton airport historical measurements and the material moisture content value was obtained from the AP-42 factors for miscellaneous fill material. The amount of material being handled was provided (220,000 tons). Material handling emissions will be controlled by watering the storage pile and by planting vegetation. Watering controls will contribute to 90% emissions control efficiency according to the study “Evaluation of Watering to Control Dust in High Winds” by Fitz, D., K (April, 2000).

2.2.2.2 Unpaved Road Fugitive Dust Unpaved road entrained fugitive dust emissions were estimated using AP-42 emission factors and the vehicle miles traveled (EPA 2011c). The emission factor was calculated based on the silt content of the road, the weight of the vehicle, and the number of days where precipitation was over 0.01 inch. The silt content of the unpaved roads was obtained from the WRAP Fugitive Dust Emissions Handbook for roads to and from a stone processing or quarry site (WRAP 2004). The on-site haul trucks were assumed to be heavy-heavy duty diesel trucks with an average weight of 60 tons. The number of days where precipitation was over 0.01 inch (“wet” days) was obtained from AP-42 Figure 13.2.1-2 and was found to be 90 days for the project area (EPA 2011c). The vehicles miles traveled for the on-site haul trucks were calculated to be approximately 8,800 miles (see methodology for on-site haul truck exhaust emissions).

2.3 IMPACTS

2.3.1 Material Handling Emissions – Equipment, Fugitive Dust, and Haul Trucks Emissions of criteria pollutants would occur during material handling and hauling activities at the proposed site. These activities include equipment travel on the site and haul truck transport of material to the new site. Impacts were estimated following the methodology described above. In cases where emission factors were only provided for PM10, it is considered a surrogate for PM2.5. Detailed emission calculation tables are included in Appendix A. Each of the tables (2-2 through 2-4) below present emissions from the various activities associated with the revision.


2-4

Table 2-2 Unmitigated Material Handling Equipment Exhaust Emissions

(tons/year)

Activity ROG NOx CO PM10 SO2 CO2 Material Handling Equipment Exhaust 0.03 0.31 0.44 5.18E-04 0.02 50.80

Notes: Emissions were estimated using EMFAC2011 for type of vehicles present and horsepower rating in the Mountain Counties Air Basin.

CO = carbon monoxide CO2 = carbon dioxide NOx = nitrogen dioxide

PM10 = respirable particulate matter measuring less than 10 microns ROG = reactive organic gas SO2 = sulfur dioxide

Table 2-3 Unmitigated On-Site Haul Truck Emissions

Activity

VMT ROG NOx CO PM10 PM2.5 SO2 CO2

miles/year tons/year tons/year tons/year tons/year tons/year tons/year tons/year On-Site Haul Truck Delivery 8,778 0.03 0.19 0.06 0.00 5.15E-04 0.00E+00 39.50

Notes: Emissions were estimated using emission factors for on-road vehicles from EMFAC Emissions Model 2011 (for vehicles traveling 5 mph) for heavy-heavy duty single unit construction diesel trucks in Tuolumne County 2012.

Table 2-4 Unmitigated Fugitive Dust Emissions

(tons/year)

Activity PM10 PM2.5 Fill Material Handling 0.02 3.01E-03


TOTAL 13.19 1.32

Notes: Material handling and entrained fugitive road dust emissions were estimated using AP-42 methodology. PM2.5 = Fine particulate matter measuring less than 2.5 microns PM10 = Respirable particulate matter measuring less than 10 microns

Tables 2-5 and 2-6 summarize revision period total unmitigated emissions and peak daily unmitigated emissions for VOC, NOx, CO, SO2, PM10, and PM2.5 from all the activities described above.


2-5

Emissions in Table 2-5 are compared to the Tuolumne County (TC) APCD annual CEQA thresholds for determination of significance of impacts and emissions in Table 2-6 are compared to TCAPCD daily CEQA thresholds. All pollutant emissions were below both the annual and daily Tuolumne County CEQA thresholds.

Table 2-5 Revision Summary: Unmitigated Emissions (tons/year)

Activity ROG NOx CO PM10 PM2.5 SO2 CO2 Material Handling Equipment Exhaust 0.03 0.31 0.44 5.18E-04 5.18E-04 0.02 50.80

On-Site Haul Truck Delivery 0.03 0.19 0.06 5.60E-04 5.15E-04 0.00E+00 39.50

Fill Material Handling 0.02 3.01E-03


TOTALS 0.06 0.50 0.49 13.20 1.32 0.02 90


Notes: CO = carbon monoxide CO2 = carbon dioxide NOx = nitrogen dioxide

PM2.5 = fine particulate matter measuring less than 2.5 microns PM10 = respirable particulate matter measuring less than 10 microns ROG = reactive organic gas SO2 = sulfur dioxide

Table 2-6 Revision Summary: Unmitigated Emissions (lbs/day)

Activity ROG NOx CO PM10 PM2.5 SO2 CO2 Material Handling Equipment Exhaust 1.25 13.18 18.57 0.02 0.02 0.79 2,162

On-Site Haul Truck Delivery 1.19 8.15 2.37 0.02 0.02 - 1,680.77

Fill Material Handling 0.84 0.13


TOTALS 2.44 21.33 20.94 396.13 39.70 0.79 3,842


Notes: CO = carbon monoxide CO2 = carbon dioxide NOx = nitrogen dioxide

PM2.5 = fine particulate matter measuring less than 2.5 microns PM10 = respirable particulate matter measuring less than 10 microns ROG = reactive organic gas SO2 = sulfur dioxide


2-6

2.3.2 Greenhouse Gases The GHG emissions associated with the activities at the revision site would be short term in nature. As shown in Table 2-5, the GHG emissions would not be greater than 82 metric tons of CO2e per year (90 short tons of CO2e per year). The total GHG emissions for this revision would be less than 0.01% of the annual statewide GHG emissions.1 Therefore, it is unlikely to impact the AB32 GHG goals.

2.3.3 Toxics – Diesel Particulate Matter Diesel particulate matter would be emitted from material handling equipment and on-site haul trucks; this is the only TAC associated with the revision. Diesel particulate matter is considered a carcinogen and the revision would expose nearby receptors to these emissions during the activity period. However, cancer risk is typically evaluated based on a 70-year exposure. The revision construction would only take place over a 47 day per year period, on average. As such, exposure to diesel particulate matter is considered less than significant.

2.3.4 Naturally-occurring Asbestos The Tuolumne County has been identified as an area where the local geology supports the formation of NOA, ultramafic rock specifically. However, no NOA has been located within the confines of the Blue Mountain Minerals area. Nevertheless, dust minimization measures would be used onsite including the use of a water truck, as well as watering and vegetation of the material pile.

2.4 CUMULATIVE Tuolumne County is designated as nonattainment of the O3 NAAQS and CAAQS. The revision would increase emissions of criteria pollutants, including O3 precursors (VOC, NOx), CO, SO2, and PM emissions, from fill material handling and transport, but these emissions would be below significance thresholds levels.

The population of Tuolumne County is expected to increase by approximately 2% from 2010 to 2015(Caltrans 2011). Given the modest growth in the area, the past, present and reasonably foreseeable future projects are not expected to worsen air quality in the area.

Additionally, the revision will not exceed CEQA thresholds and will have a less than significant impact on air quality. Since the revision as well as past, present and reasonably foreseeable future projects are not expected to exacerbate air quality; the revision will have a less than significant cumulative impact.

1 A GHG emission inventory for the Tuolumne County APCD was not available at the time of the release of this document, so the comparison was made to the most recent CARB emissions inventory (2008), which estimated the annual CO2e emissions in California are about 478 million metric tons (CARB 2011c).

SECTIONTHREE Air Quality Assessment References

3-1

3. Section 3 THR EE References

California Air Resources Board (CARB). 2011a. 2010 Estimated Annual Average Emissions. http://www.arb.ca.gov/app/emsinv/emseic1_query.php. Accessed August 2011

_______. 2011b. Air Quality Data Statistics. http://www.arb.ca.gov/aqd/aqdpage.htm. Accessed August 2011

_______. 2011c. ARB Programs, Climate Change. Assembly Bill 32: Global Warming Solutions Act.” http://www.arb.ca.gov/cc/ab32/ab32.htm. Accessed August 2011

_______. 2010. Ambient Air Quality Standards. http://www.arb.ca.gov/research/aaqs/aaqs2.pdf. Accessed August 2011

California Department of Transportation (Caltrans). 2011. Tuolumne County Economic Growth. http://www.dot.ca.gov/hq/tpp/offices/ote/socio_economic_files/2010/Tuolumne.pdf. Accessed August 2011.

California Energy Commission (CEC). 2006. Inventory of California Greenhouse Gas Emissions And Sinks: 1990 To 2004 – Final Staff Report.

California Natural Resources Agency. 2011. “CEQA Guidelines. 2009 SB 97 Rulemaking.” http://ceres.ca.gov/ceqa/guidelines. Accessed August 2011.

California OEHHA and the American Lung Association, 2005. Health Effect of Diesel Exhaust.

Fitz, D., 2000, Evaluation of Watering to Control Dust in High Winds, Journal of Air and Waste Management Association, Volume 50, Number 4

Office of Planning and Research. 2009. “CEQA Guidelines and Greenhouse Gases, Proposed CEQA Amendments.” April 13, 2009.

Tuolumne County. 1996. Tuolumne County General Plan Policy Document. Adopted December 26, 1996.

Tuolumne County Air Pollution Control District (Tuolumne County APCD). 2011. Air Pollution CEQA Thresholds. http://portal.co.tuolumne.ca.us/ps/psft/V241770010/TCAPCD_Significance_Thresholds__2_.pdf. Accessed August 2011

U.S. Environmental Protection Agency (EPA) 2011a. “Greenhouse Gas Reporting Program.” U.S. Environmental Protection Agency (EPA) http://www.epa.gov/climatechange/emissions/ghgrulemaking.html. Accessed August 2011.

_______. 2011b. “EPA and NHTSA [National Highway Traffic Safety Administration] Propose Historic National Program to Reduce Greenhouse Gases and Improve Fuel Economy for Cars and Trucks.” Available from web site, http://epa.gov/otaq/climate/regulations/420f09047.htm. Accessed August 2011

_______. 2011c. Office of Air Quality Planning and Standards, AP 42, Fifth Edition, Volume I. http://www.epa.gov/ttn/chief/ap42/. Accessed August 2011

Western Governors Association. 2004. WRAP Fugitive Dust Handbook. Table 3-6.

Appendix A Air Quality Emissions and Calculations

APPENDIX A

Appendix A Blue Mountain Minerals Additional Hauling EmissionsSummary

Page A-1 8/24/2011

Summary of Blue Mountain Minerals Additional Hauling Emissions Summary

Material Handling Equipment Exhaust Unmitigated Emission Summary

ROG NOx CO PM10 SO2 CO2tons/year tons/year tons/year tons/year tons/year tons/year

Fill Material Handling / Road Watering 0.08 0.73 0.37 0.03 0.00 69.37 TOTAL 0.08 0.73 0.37 0.03 0.00 69.37

On-Site Haul Truck Unmitigated Emission Summary

VMT ROG NOx CO PM10 PM2.5 SO2 CO2miles/year tons/year tons/year tons/year tons/year tons/year tons/year tons/year

Heavy-Heavy Duty Diesel Trucks 6,196 0.14 0.39 0.22 0.04 3.51E-02 2.53E-04 26.26

Fugitive Dust Unmitigated Emission Summary

PM10 PM2.5tons/year tons/year

Fill Material Handling 0.02 3.01E-03On-Site Haul Truck Fugitive Dust 10.88 1.09TOTAL 10.90 1.09

Activity

Activity

Activity

Appendix A Blue Mountain Minerals Additional Hauling EmissionsSummary

Page A-2 8/24/2011

Summary of Blue Mountain Minerals Additional Hauling Emissions Summary

Blue Mountain Minerals Additional Hauling Emissions Summary: Unmitigated Emissions

ROG NOx CO PM10 PM2.5 SO2 CO2tons/year tons/year tons/year tons/year tons/year tons/year tons/year

Material Handling Equipment Exhaust 0.08 0.73 0.37 0.03 0.03 0.00 69.37 On-Site Haul Truck Delivery 0.14 0.39 0.22 0.04 0.04 2.53E-04 26.26Fill Material Handling 0.02 3.01E-03On-Site Haul Truck Fugitive Dust 10.88 1.09TOTALS 0.22 1.11 0.58 10.96 1.15 0.00 96TCAPCD CEQA Thresholds 100 100 100 100 N/A N/A N/A

Blue Mountain Minerals Additional Hauling Emissions Summary: Unmitigated Emissions

ROG NOx CO PM10 PM2.5 SO2 CO2lbs/day lbs/day lbs/day lbs/day lbs/day lbs/day lbs/day

Material Handling Equipment Exhaust 3.45 30.87 15.65 1.22 1.12 - 2,952 On-Site Haul Truck Delivery 5.90 16.57 9.23 1.63 1.49 0.01 1,117.64 Fill Material Handling 0.84 0.13 On-Site Haul Truck Fugitive Dust 462.31 46.23 TOTALS 9.36 47.44 24.88 466.01 48.98 0.01 4070TCAPCD CEQA Thresholds 1000 1000 1000 1000 N/A N/A N/A

Activity

Activity

Appendix A Blue Mountain Minerals Additional Hauling Emissions On-site Haul Trucks

Page A-3 8/24/2011

Blue Mountain Minerals Additional Hauling Emissions: On-Site Truck Emissions

Transportation Information Comment- Additional Miles per Trip (1-way) = 1.197 miles/1-way trip- Annual tonnage transported = 220,000 tons

- Maximum daily loads = 55 loads per day- Truck Capacity = 85 tons Assumed haul truck were heavy-heavy duty diesel trucks- Total Miles Per Day = 132 miles/day- Total Miles Per Year = 6,196 miles/year The trip-rate was assumed to be 2 one-way trips

Equipment Description CO CO2 CH4 N2O NOx PM10 PM2.5 SOx ROG (1)

Heavy-Heavy Duty Diesel Truck 2011 31.75 3845.36 0.94 4.80E-03 57.01 5.62 5.14 0.04 20.31

Note:

Equipment Description CO CO2 CH4 N2O NOx (2) PM10

(2) PM2.5 (2) SOx ROG (1)

Heavy-Heavy Duty Diesel Truck 2011 (Unmitigated) 9.22 1116.24 0.27 1.39E-03 16.55 1.63 1.49 0.01 5.90

Equipment Description CO CO2 CH4 N2O NOx (2) PM10

(2) PM2.5 (2) SOx ROG (1)

Heavy-Heavy Duty Diesel Truck 2011 (Unmitigated) 0.22 26.26 6.44E-03 3.28E-05 0.39 0.04 0.04 0.00 0.14

Note:

Where: M = Mass emissions rate from trucks in tons per year or pounds per day (for daily calculations, the conversion to tons is omitted) EF= emission factor in pounds per mile D = Distance traveled by trucks in miles per year or day.

(1) Assuming ROGs are equivalent to VOCs

Tons Emitted Per Year

- The following equation was used to obtain the emissions estimates:

BLUE MOUTAIN ON-SITE HAUL TRUCK ADDITIONAL ANNUAL EMISSIONS

BLUE MOUTAIN ON-SITE HAUL TRUCK ADDITIONAL DAILY EMISSIONSPounds Emitted Per Day

DATA FROM EMFAC2007

Emissions Summary

Information provided by Carey Haughy from Blue Mountain Minerals on July 7, 2011

- N2O and CH4 factors are derived from California Climate Action Registry General Reporting Protocol Version 3.1 (January 2009), Table C.4 for diesel fueled heavy-heavy duty trucks in Tuolumne County.

gram/mile

- Emission factors for on-road, heavy-heavy-duty vehicles are based on results from Emfac Emissions Model 2007 Version 2.3, EMFAC mode for 5 mph. The values are the projected values for the HHDT vehicles within Tuolumne County in the respective year. PM10 values include break wear and tire wear.

Information provided by Carey Haughy from Blue Mountain Minerals on August 16, 2011

2000/* DEFM =

Appendix A Blue Mountain Minerals Additional Hauling Emissions Material Handling

Page A-4 8/24/2011

Blue Mountain Minerals Additional Hauling Emissions: Fill Material Handling Emissions Emissions Summary

Fill Material Handling

Stockpile handling estimated using AP-42 Fifth Edition, Volume I Chapter 13.2.4: Aggregate Handling And Storage PilesWhere:E = Emission Factork = Particle Size MultiplierU = Mean Wind Speed M = Material Moisture Content

k = 0.35 dimensionless AP 42, Chapter 13.2.4: default k value for PM10

k = 0.053 dimensionless AP 42, Chapter 13.2.4: default k value for PM2.5

U = 7.7 mph Western Regional Climate Center Average Wind Speed at Stockton AirportM = 11 % Table 13.2.4-1 of AP-42 Aggregate Handling and Storage Piles, for Misc. Fill MaterialsTotal Amount Disturbed = 220,000 ton/ year Information provided by Carey Haughy from Blue Mountain Minerals on July 7, 2011.

ParameterFill Material

Amount E Controls Unmitigated Emissionstons/year

Stockpile (PM10) 220,000 1.81E-04 90% 1.99E-02

ParameterFill Material

Amount E Controls Unmitigated Emissionstons/year

Stockpile (PM10) 220,000 2.73E-05 90% 3.01E-03

PM2.5 Fill Material Emissions

Equation Values CommentFill Material Handling

PM10 Fill Material Emissions

Appendix A Blue Mountain Minerals Additional Hauling Emissions Unpaved Roads: Fugitive Entrained Dust

Page A-5 8/24/2011

Blue Mountain Minerals Additional Hauling Emissions: Fugitive Entrained Dust Emissions

Where:E =size specific particulate emission factorEext = annual or other long-term average emission factork = particle size multiplier for particle size range and units of interests = surface material silt contentW = average weight (tons) of the vehicles traveling the roadP = number of “wet” days with at least 0.01 in of precipitation during the averaging periodVMT = vehicle mile traveled on paved roads

k = 1.5 lb/VMTk = 0.15 lb/VMTs (mean) = 5.8 %W = 85 tonP = 90 wet days

VMT = 132 miles/day

VMT= 6,196 miles/year

Scenario VMT EBase

Emissions Eextmile/period lb/VMT ton/period lb/VMT

Unpaved Roads (Daily) 132 3.51 0.23 2.65Unpaved Roads (Annual) 6,196 3.51 10.88 2.65

Scenario VMT EBase

Emissions Eextmile/period lb/VMT ton/period lb/VMT

Unpaved Roads (Daily) 132 0.35 0.02 0.26Unpaved Roads (Annual) 6,196 0.35 1.09 0.26

WRAP Fugitive Dust Handbook, Table 6-1. Haul road to and from Taconite mining pit

Equation Values CommentAP 42, Table 13.2.2-2: default k value for PM10

AP 42, Table 13.2.2-2: default k value for PM2.5

Unmitigated Fugitive Dust PM10

Total daily VMT is calculated based on the trip information, total volume moved and truck capacity as provided by Carey Haughy from Blue Mountain Minerals on July 7 2011 and the assumption of 2 one-way trips/day.

Mitigated Fugitive Dust PM2.5

AP-42, Figure 13.2.2-1. Mean number of days with 0.01 inch or more of precipitation in United States.

Total annual VMT is calculated based on the trip information, total volume moved and truck capacity as provided by Carey Haughy from Blue Mountain Minerals on July 7 2011 and the assumption of 2 one-way trips/day.

Truck weight provided by Carey Haughy from Blue Mountain Minerals on July 7, 2011.

Emissions Summary

Entrained Dust Calculation - Dry Unpaved Road

Entrained dust estimates calculated using guidance from AP 42, Fifth Edition, Volume I Chapter 13.2.2: Unpaved Roads

Entrained Dust Calculation - Natural Mitigation With Precipitation

Unpaved Roads

( ) ( ) 45.09.0

312WskE =

( )[ ]365/365 PEEExt −=

Appendix A Blue Mountain Minerals Additional Hauling EmissionsHaul TrucksEMFAC 2007

Page A-6 8/24/2011

Title : Blue Mountain Haul TrucksVersion : Emfac2007 V2.3 Nov 1 2006Run Date : 2011/08/17 11:00:22Scen Year: 2011 -- All model years in the range 1967 to 1998 selectedSeason : AnnualArea : Tuolomne County APCD*****************************************************************************************Year: 2011 -- Model Years 1967 to 1998 Inclusive -- Annual Emfac2007 Emission Factors: V2.3 Nov 1 2006

District AverageTuolomne County APCD

Table 1: Running Exhaust Emissions (grams/mile)

Pollutant Name: Reactive Org Gases Temperature: 58F Relative Humidity: 79%

Speed LDA LDA LDA LDA LDT1 LDT1 LDT1 LDT1 LDT2 HHD HHD HHD HHD ALL ALL MPH NCAT CAT DSL ALL NCAT CAT DSL ALL NCAT NCAT CAT DSL ALL DSL ALL

5 0 0 0 0 0 0 0 0 0 98.666 35.845 20.312 32.363 20.312 32.363

Pollutant Name: Methane Temperature: 58F Relative Humidity: 79%


5 0 0 0 0 0 0 0 0 0 3.822 1.463 0.943 1.373 0.943 1.373

Pollutant Name: Carbon Monoxide Temperature: 58F Relative Humidity: 79%


5 0 0 0 0 0 0 0 0 0 2390.456 559.318 31.746 410.122 31.746 410.122


Page A-7 8/24/2011



Table 1: Running Exhaust Emissions (grams/mile)Pollutant Name: Oxides of Nitrogen Temperature: 58F Relative Humidity: 79%


5 0 0 0 0 0 0 0 0 0 17.459 14.356 57.009 41.876 57.009 41.876

Pollutant Name: Carbon Dioxide Temperature: 58F Relative Humidity: 79%


5 0 0 0 0 0 0 0 0 0 2513.51 2513.51 3845.361 3362.912 3845.361 3362.912

Pollutant Name: Sulfur Dioxide Temperature: 58F Relative Humidity: 79%


5 0 0 0 0 0 0 0 0 0 0.063 0.034 0.037 0.039 0.037 0.039

Pollutant Name: PM10 Temperature: 58F Relative Humidity: 79%


5 0 0 0 0 0 0 0 0 0 0.101 0.109 5.559 3.584 5.559 3.584


Page A-8 8/24/2011



Table 1: Running Exhaust Emissions (grams/mile)

Pollutant Name: PM10 - Tire Wear Temperature: 58F Relative Humidity: 79%


5 0 0 0 0 0 0 0 0 0 0.012 0.012 0.036 0.027 0.036 0.027

Pollutant Name: PM10 - Brake Wear Temperature: 58F Relative Humidity: 79%


5 0 0 0 0 0 0 0 0 0 0.028 0.028 0.028 0.028 0.028 0.028

Pollutant Name: PM2.5 Temperature: 58F Relative Humidity: 79%


5 0 0 0 0 0 0 0 0 0 0.076 0.101 5.115 3.296 5.115 3.296


Page A-9 8/24/2011



Table 1: Running Exhaust Emissions (grams/mile)Pollutant Name: PM2.5 - Tire Wear Temperature: 58F Relative Humidity: 79%


5 0 0 0 0 0 0 0 0 0 0.003 0.003 0.009 0.007 0.009 0.007

Pollutant Name: PM2.5 - Brake Wear Temperature: 58F Relative Humidity: 79%


5 0 0 0 0 0 0 0 0 0 0.012 0.012 0.012 0.012 0.012 0.012

Pollutant Name: Gasoline - mi/gal Temperature: 58F Relative Humidity: 79%


5 0 0 0 0 0 0 0 0 0 1.346 2.528 0 2.194 0 2.194

Pollutant Name: Diesel - mi/gal Temperature: 58F Relative Humidity: 79%


5 0 0 0 0 0 0 0 0 0 0 0 2.621 2.621 2.621 2.621

Appendix A Blue Mountain Minerals Additional Hauling EmissionsMaterial Handling Equipment URBEMIS2007

Page A-10 8/24/2011

ROG NOx CO SO2 PM10 Dust PM10 Exhaust PM10 Total PM2.5 PM2.5 Exhaust PM2.5 Total CO20.08 0.73 0.37 0.00 0.00 0.03 0.03 0.00 0.03 0.03 70.570.08 0.73 0.37 0.00 0.00 0.03 0.03 0.00 0.03 0.03 70.570.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.000.08 0.72 0.35 0.00 0.00 0.03 0.03 0.00 0.03 0.03 69.370.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.000.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1.20

Page: 18/5/2011 08:02:59 AM

File Name: C:\Documents and Settings\jonathan_tamimi\Desktop\Blue Mountain\Blue Mountain Emissions.urb924

Project Name: Blue Mountain Minerals

Urbemis 2007 Version 9.2.4

Detail Report for Annual Construction Unmitigated Emissions (Tons/Year)

Project Location: Mountain Counties Air Basin

On-Road Vehicle Emissions Based on: Version : Emfac2007 V2.3 Nov 1 2006

Off-Road Vehicle Emissions Based on: OFFROAD2007

CONSTRUCTION EMISSION ESTIMATES (Annual Tons Per Year, Unmitigated)

2011Fine Grading 10/03/2011-12/06/2011Fine Grading Dust

Fine Grading Off Road DieselFine Grading On Road DieselFine Grading Worker Trips

Phase: Fine Grading 10/3/2011 - 12/6/2011 - Type Your Description Here

Phase Assumptions

1 Rubber Tired Dozers (580 hp) operating at a 0.59 load factor for 8 hours per day1 Water Trucks (325 hp) operating at a 0.5 load factor for 8 hours per day

Total Acres Disturbed: 41.59Maximum Daily Acreage Disturbed: 10.4Fugitive Dust Level of Detail: Default 0 lbs per acre-dayOn Road Truck Travel (VMT): 0Off-Road Equipment:

Privileged and Confidential

August 7, 2014

Mr. David P. Temblador Attorney; Harrison, Temblador, Hungerford & Johnson LLP 980 9th Street Suite 1400 Sacramento, CA 95814 Ms. Carey Haughy Vice President and Geologist Blue Mountain Minerals 24599 Marble Quarry Road Columbia, California 95310 Subject: Memo to Support the Blue Mountain Minerals Agricultural Fill Revision Environmental

Impact Report Air Quality Analysis

Dear Mr. Temblador and Ms. Haughy:

The purpose of this memo is to assist in the preparation of Blue Mountain Mineral’s Environmental Impact Report (EIR) by (1) responding to questions posed by the County’s CEQA consultant (i.e., Helix) on the 2012 analysis and (2) by updating calculations using the more recent versions of the emission calculation software (specifically, CalEEMod v. 2013.2.2). Below are URS’ responses to the consultant’s six questions (sent to URS by Ms. Haughy). The output emission results of the updated modeling reruns are also provided below in tabular form. The updated modeling also incorporated modified assumptions from Ms. Haughy. URS Response to Six Helix Questions:

1. The analysis does not include any discussion of the construction activity that would be needed to

prepare the proposed fill site expansion area, such as tree removal, grading, etc. Any equipment

associated with site prep/grading needs to be discussed in the air quality report.

URS Response:

URS Corporation performed modeling to reassess emissions from the proposed project using

updated modeling software, CalEEMod, version 2013.2.2. This updated modeling accounts for

construction activity that would be needed to prepare the proposed fill site expansion area,

such as tree removal, grading, etc. Specifically, the exhaust emissions modeling includes site-

specific equipment lists from the project proponent that would be required to clear the land as

well as dispose of the fill, including 3 haul trucks, 1 water truck, 1 track dozer, and 5 chainsaws

These are the pieces of equipment used for the Project. The modeling assumes that all of this

equipment would operate during the day of maximum daily construction activity.


Mr. David P. Temblador and Ms. Carey Haughy August 7, 2014 Page 2

For fugitive (i.e., dust) emissions, the modeling assumed a maximum of 10.4 acres clearing and

disposal activity per day. This is over one-third of the total expansion area acreage, which is

otherwise anticipated to be disturbed over several decades. As such, this maximum daily

fugitive dust emissions approach is more than adequate to model all fugitive emissions

associated with ongoing grading activities.

Emissions from chainsaws used to clear the vegetation in the expanded agricultural fill area

were modeled assuming that five 6 HP chainsaws would be used for 5 days. Emissions due to

chainsaws have a minimal impact on overall emission from the proposed project. The

estimated emissions are presented in the attached summary table.

2. The report should identify the locations of the nearest sensitive receptors.

URS Response:

One residential structure is located approximately 600 feet east of the proposed expanded

site. The nearest haul truck would pass at least 600 feet away from the residence. The location

of the residential structure in relation to the existing and proposed project sites is shown in the

following figure.



Note: The yellow circle represents the nearest residential structure to the proposed project site.

3. What is the basis of the assumption of 47 working days a year for the material handling equipment

and haul trucks (Section 2.2.1.1)? Over how many years would these working days occur?

Blue Mountain Minerals Response:

The material hauled to the project area is waste, and therefore is only a small portion of the

total material hauled by Blue Mountain Minerals' operation. The amount of time spent hauling

waste equates to 47 full working days out of a whole year. The deposition of material in the

revised ag. fill area is expected to be completed within 25 to 40 years from the time of project

approval.

URS Response:



The proposed project is estimated to have an average yearly haul of 220,000 tons. The

maximum amount hauled per day is 78 haul trips per day at 60 tons per trip, which is 4,680 tons

per day. The yearly project material (220,000 tons) divided by the maximum daily amount

hauled (4,680 tons per day) is 47 days. This approach was taken because this approach

conservatively estimates the maximum daily emissions; the project’s maximum daily emissions

are what are used to compare to CEQA significance thresholds.

4. What is the basis for the use of Tier 4 heavy-duty diesel trucks - has the quarry committed to using

these?


Blue Mountain Minerals owns and operates three Tier 4 haul trucks.

URS Response:

URS agrees with Blue Mountain Mineral’s response to this comment.

5. The ratio method of comparing greenhouse gas emissions to the statewide inventory is not an

appropriate means of assessing a significant impact [as decided in numerous court cases including

Friends of Oroville v. City of Oroville, 219 Cal. App. 4th 832 (2013)]. A more appropriate method, in

the absence of a threshold established by the County or air district, would be to either adapt a

threshold used by another agency or to use the quantitative threshold recommended by California

Air Pollution Control Officers Association (CAPCOA) of 900 metric tons per year.


This was addressed by the Errata sheets included with the Final IS/MND.

URS Response:

URS reviewed the errata and agrees with Blue Mountain Mineral’s response to this comment.

6. Appendix A is outdated, and the emission models (e.g., EMFAC2007 vs EMFAC2011), emission

factors, VMT, and project emissions do not match between the appendix and report.

URS Response:

URS Corporation performed modeling to reassess emissions from the proposed project using

updated modeling software, CalEEMod, version 2013.2.2. The updated modeling provides

comparable results to prior modeling. The attached summary table summarizes and compares

the results of prior and updated modeling.



URS Results of New Model Runs: URS remodeled the proposed project in order to update emissions estimates. The results of URS’ modeling are provided below. Tables 1 and 2 provide overall emissions results in pounds per day and tons per year. Below the summary tables are three sets of tables that show side by side comparisons between the current and prior models for the following activities: (1) Total Project (2) On-site Haul Truck (3) Material Handling The following are key distinctions between updated and prior modeling efforts: (1) CalEEMod v. 2013.2.2 was used for updated modeling whereas Urbemis was used for prior modeling (plus some other calculation methods). (2) Used the year 2015 when determining fleet-wide emission factors whereas the prior modeling used 2011. (3) Model assumptions (number of haul trips per day and tons per trip) were corrected by the client for the updated modeling. (4) Chainsaws were added as an additional activity not previously modeled. The model results compared to previous modeling result show minor changes in all pollutants. The values are higher for some pollutants (due in part to corrected model assumptions), but lower for other pollutants. Overall, the results of the new modeling are very similar to the prior modeling results. The results also show that emissions from the proposed project will not exceed any of the CEQA significance thresholds set by the Tuolumne County Air Pollution Control District. The project emissions are well below the applicable thresholds and therefore likely to have a less-than-significant impact on air quality, both for the proposed project and cumulatively.



Tables 1 and 2 - Blue Mountain Minerals Model Rerun Summary Emissions – Maximum Daily and Annual Emissions

Summary

Emissions (pounds per day)

ROG NOx CO SO2 Fugitive PM10

Exhaust PM10

PM10 Total

Fugitive PM2.5

Exhaust PM2.5

PM2.5 Total

Bio- CO2

NBio- CO2

Total CO2

CH4 N2O CO2e

Chainsaw 0.41 1.4 2.9 0.00 18.2 0.11 18.3 10.0 0.10 10.1 307 0.05 308

Worker Commute - Chain Saw

0.12 0.14 1.69 0.00 0.17 0.00 0.17 0.04 0.00 0.05 180 0.01 180

Hauling 1.5 4.6 19.5 0.01 275.6 0.05 275.6 27.5 0.04 27.5 705 0.01 706

Worker Commute - Hauling

0.05 0.06 0.65 0.00 0.06 0.00 0.06 0.02 0.00 0.02 69 0.01 69

Fugitive Dust 17.5 0.00 17.5 4.6 0.00 4.6 0 0

Off-Road 4.2 56.2 22.5 0.04 2.1 2.1 1.9 1.9 4,572 1.36 4,600

Overall Project 6.3 62.4 47.3 0.06 311.5 2.2 313.7 42.1 2.0 44.1 5,833 1.44 5,864

Tuolumne Co Thresholds of Significance (lbs/day)

1,000 1,000 1,000 N/A N/A N/A 1,000 N/A N/A N/A N/A N/A N/A N/A N/A N/A

Summary

Emissions (tons per year) Emissions (metric tons per year)


Exhaust PM10

PM10 Total

Fugitive PM2.5

Exhaust PM2.5

PM2.5 Total

Bio- CO2

NBio- CO2

Total CO2

CH4 N2O CO2e

Chainsaw 0.00 0.00 0.01 0.00 0.04 0.00 0.04 0.02 0.00 0.02 0.6 0.00 0.6

Worker Commute - Chain Saw

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.3 0.00 0.3

Hauling 0.03 0.11 0.46 0.00 6.48 0.00 6.48 0.65 0.00 0.65 15 0.00 15

Worker Commute - Hauling

0.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1.5 0.00 1.5

Fugitive Dust 0.41 0.00 0.41 0.11 0.00 0.11 0.0 0.00 0.0

Off-Road 0.10 1.32 0.53 0.00 0.05 0.05 0.04 0.04 97 0.03 98

Overall Project 0.14 1.4 1.0 0.00 6.9 0.0 7.0 0.8 0.0 0.8 115 0.03 115

Tuolumne Co. Thresholds of Significance (tons/year)

100 100 100 N/A N/A N/A 100 N/A N/A N/A N/A N/A N/A N/A N/A N/A



Tables 3 and 4 - Comparison of Older Versus Newer Daily and Annual Emissions Modeling – Total Construction

Total Project



Exhaust PM10

PM10 Total

Fugitive PM2.5

Exhaust PM2.5

PM2.5 Total

Bio- CO2

NBio- CO2

Total CO2

CH4 N2O CO2e

Updated Model

6.3 62 47 0.06 311 2.2 314 42.1 2.0 44 5,833 1.44 5,864

Prior Model

9.4 47 25 0.01 466 49 4,070

Total Project



Exhaust PM10

PM10 Total

Fugitive PM2.5

Exhaust PM2.5

PM2.5 Total

Bio- CO2

NBio- CO2

Total CO2

CH4 N2O CO2e

Updated Model

0.14 1.4 1.0 0.00 6.9 0.0 7.0 0.8 0.0 0.8 115 0.03 115

Prior Model

0.22 1.1 0.6 0.00 11.0 1.2 96

Tables 5 and 6 - Comparison of Older Versus Newer Daily and Annual Emissions Modeling – Hauling

Hauling



Exhaust PM10

PM10 Total

Fugitive PM2.5

Exhaust PM2.5

PM2.5 Total

Bio- CO2

NBio- CO2

Total CO2

CH4 N2O CO2e

Updated Model

1.5 4.6 19 0.01 276 0.05 276 28 0.04 28 705 0.01 706

Prior Model

5.9 17 9.2 0.01 462 1.6 466 46 1.5 49 1,118

Hauling



Exhaust PM10

PM10 Total

Fugitive PM2.5

Exhaust PM2.5

PM2.5 Total

Bio- CO2

NBio- CO2

Total CO2

CH4 N2O CO2e

Updated Model

0.0 0.1 0 0.00 6.5 0.00 6.5 0.6 0.00 0.6 15 0.00 15

Prior Model

0.1 0 0.2 0.00 10.9 0.04 10.9 1.1 0.0 1.1 26



Tables 7 and 8 - Comparison of Older Versus Newer Daily and Annual Emissions Modeling – Off-Road Equipment

Off-road



Exhaust PM10

PM10 Total

Fugitive PM2.5

Exhaust PM2.5

PM2.5 Total

Bio- CO2

NBio- CO2

Total CO2

CH4 N2O CO2e

Updated Model

4.2 56 22 0.04

2.1 2.1

1.9 1.9 4,572 1.36 4,600

Prior Model

3.5 31 16

1.2 1.1 2,952

Off-road



Exhaust PM10

PM10 Total

Fugitive PM2.5

Exhaust PM2.5

PM2.5 Total

Bio- CO2

NBio- CO2

Total CO2

CH4 N2O CO2e

Updated Model

0.10 1.3 0.5 0.00

0.05 0.05

0.04 0.04 97 0.03 98

Prior Model

0.08 0.7 0.4 0.00 0.03 0.03 69