Air Quality Technical Report. San Ysidro Rail Yard Improvement Project

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1 Air Quality Technical Report for the Submitted To: HELIX Environmental Planning, Inc El Cajon Blvd., Suite 200 La Mesa, CA Prepared By: 1328 Kaimalino Lane San Diego, CA June 30, 2010

2 Table of Contents 1.0 Introduction Existing Conditions Regulatory Framework Federal Regulations State Regulations Local Regulations Climate and Meteorology Background Air Quality Thresholds of Significance Impacts Consistency with the RAQS and SIP Violation of an Air Quality Standard Construction Impacts Operational Impacts Cumulatively Considerable Net Increase of Nonattainment Pollutants Exposure of Sensitive Receptors to Substantial Pollutant Concentrations Objectionable Odors Mitigation Measures Global Climate Change Sources and Global Warming Potentials of GHG Regulatory Framework National and International Efforts State Regulations and Standards Climate Change Significance Criteria Existing Conditions Potential Climate Change Impacts to Project Site Greenhouse Gas Impacts Summary and Conclusions References Air Quality Technical Report i 06/30/10 San Ysidro Railyard Improvement Project

3 1.0 Introduction This report presents an assessment of potential air quality impacts associated with the San Ysidro Rail Yard Improvement Project proposed by the San Diego Association of Governments (SANDAG) in the City of San Diego community of San Ysidro, California. The evaluation addresses the potential for air emissions during construction and operation of the project. The (Project) site encompasses approximately 54 acres along the San Diego and Arizona Eastern (SD&AE) railroad line in the southeast portion of the City of San Diego community of San Ysidro. The Project site is located southeast of Interstate 805, north of the United States (U.S.)-Mexico border, and east of East Beyer Boulevard. Undeveloped land borders the eastern Project site boundary. The purpose of the Project is to improve operational capacity and efficiency at the San Ysidro Rail Yard (Rail Yard) to accommodate existing and future freight rail operations in the region. The Rail Yard is located along SD&AE s South Line, which extends approximately 15 miles between downtown San Diego and the U.S. Mexico border at San Ysidro. This line connects to the Carrizo Gorge Railway in Mexico. The San Diego and Imperial Valley (SD&IV) railroad is the freight operator along this line and transports commodities such as propane, petroleum fuels, corn syrup, malt, and wood pulp. The existing Rail Yard includes a maintenance warehouse, a transload (rail to truck) facility, and storage tracks. Regional freight rail growth has stressed the current capacity of the existing 100-car Rail Yard. Much of the growth is from the increase in cross-border traffic to Mexico. The Rail Yard is operationally constrained by a 3.5-hour daily freight train operating window for rail traffic moving north to interchange in San Diego, and a 3-hour border crossing window for moving rail cars to and from Mexico. These operational constraints trap rail cars at the Rail Yard for the majority of the day, creating demands on its existing storage capacity. The Project would provide two new track extensions to the north that would provide additional storage capacity, as well as the ability to switch rail cars outside of the constrained operating Air Quality Technical Report 1 06/30/10

4 windows without interrupting the trolley line. The new storage tracks and other revisions to the track alignment would double rail car storage capacity. at the improved truck access to the Rail Yard would provide additional opportunities for cargo transfer (transloading) and would eliminate some regional truck traffic trips on freeways in the region. Access to the Rail Yard would be provided from East Beyer Boulevard via a new access road that would parallel the railroad tracks to the east. Other improvements, such as lighting and fencing, would be constructed for improved safety and security. Additionally, the Project would include drainage improvements to alleviate flood and siltation hazards that occur at the Rail Yard. Because of the Rail Yard s adjacency to steeper topography of the undeveloped hillsides to the east, the Project site is subject to inundation by water and silt during storm events. During these times, the Rail Yard and tracks are not in service, which further exacerbates the operational constraints, and limits the efficient movement of goods in the region. The Project would correct the drainage deficiencies by constructing drainage/desiltation basins and storm drain pipelines to accommodate flows during storm events. To accommodate the proposed improvements, acquisition of right-of-way from private property owners to the east would be required. This Air Quality Technical Report includes an evaluation of existing conditions in the project vicinity, an assessment of potential impacts associated with project construction, and an evaluation of project operational impacts. Air Quality Technical Report 2 06/30/10

5 2.0 Existing Conditions The following section provides information about the existing air quality regulatory framework, climate, air pollutants and sources, and sensitive receptors in the project area. 2.1 Regulatory Framework Federal Regulations Air quality is defined by ambient air concentrations of specific pollutants identified by the United States Environmental Protection Agency (EPA) to be of concern with respect to health and welfare of the general public. The EPA is responsible for enforcing the Federal Clean Air Act (CAA) of 1970 and its 1977 and 1990 Amendments. The CAA required the EPA to establish National Ambient Air Quality Standards (NAAQS), which identify concentrations of pollutants in the ambient air below which no adverse effects on the public health and welfare are anticipated. In response, the EPA established both primary and secondary standards for seven pollutants (called criteria pollutants). The seven pollutants regulated under the NAAQS are as follows: ozone (O 3 ), carbon monoxide (CO), nitrogen dioxide (NO 2 ), respirable particulate matter (or particulate matter with an aerodynamic diameter of 10 microns or less, PM 10 ), fine particulate matter (or particulate matter with an aerodynamic diameter of 2.5 microns or less, PM 2.5 ), sulfur dioxide (SO 2 ), and lead (Pb). Primary standards are designed to protect human health with an adequate margin of safety. Secondary standards are designed to protect property and the public welfare from air pollutants in the atmosphere. Areas that do not meet the NAAQS for a particular pollutant are considered to be nonattainment areas for that pollutant. On April 15, 2004, the San Diego Air Basin (SDAB) was designated a basic nonattainment area for the 8-hour NAAQS for O 3. The SDAB is in attainment for the NAAQS for all other criteria pollutants. Air Quality Technical Report 3 06/30/10

6 The following specific descriptions of health effects for each of the criteria air pollutants associated with project construction and operations are based on EPA (EPA 2007a) and the California Air Resources Board (ARB) (ARB 2005). Ozone. O 3 is considered a photochemical oxidant, which is a chemical that is formed when reactive organic gases (ROG) and oxides of nitrogen (NOx), both by-products of combustion, react in the presence of ultraviolet light. O 3 is considered a respiratory irritant and prolonged exposure can reduce lung function, aggravate asthma and increase susceptibility to respiratory infections. Children and those with existing respiratory diseases are at greatest risk from exposure to O 3. Carbon Monoxide. CO is a product of combustion, and the main source of CO in the SDAB is from motor vehicle exhaust. CO is an odorless, colorless gas. CO affects red blood cells in the body by binding to hemoglobin and reducing the amount of oxygen that can be carried to the body s organs and tissues. CO can cause health effects to those with cardiovascular disease, and can also affect mental alertness and vision. Nitrogen Dioxide. NO 2 is also a by-product of fuel combustion, and is formed both directly as a product of combustion and in the atmosphere through the reaction of nitrogen oxide (NO) with oxygen. NO 2 is a respiratory irritant and may affect those with existing respiratory illness, including asthma. NO 2 can also increase the risk of respiratory illness. Respirable Particulate Matter and Fine Particulate Matter. Respirable particulate matter, or PM 10, refers to particulate matter with an aerodynamic diameter of 10 microns or less. Fine particulate matter, or PM 2.5, refers to particulate matter with an aerodynamic diameter of 2.5 microns or less. Particulate matter in this size range has been determined to have the potential to lodge in the lungs and contribute to respiratory problems. PM 10 and PM 2.5 arise from a variety of sources, including road dust, diesel exhaust, combustion, tire and brake wear, construction operations and windblown dust. PM 10 and PM 2.5 can increase susceptibility to respiratory infections and can aggravate existing respiratory diseases such as Air Quality Technical Report 4 06/30/10

7 asthma and chronic bronchitis. PM 2.5 is considered to have the potential to lodge deeper in the lungs. Sulfur dioxide. SO 2 is a colorless, reactive gas that is produced from the burning of sulfurcontaining fuels such as coal and oil, and by other industrial processes. Generally, the highest concentrations of SO 2 are found near large industrial sources. SO 2 is a respiratory irritant that can cause narrowing of the airways leading to wheezing and shortness of breath. Long-term exposure to SO 2 can cause respiratory illness and aggravate existing cardiovascular disease. Lead. Pb in the atmosphere occurs as particulate matter. Pb has historically been emitted from vehicles combusting leaded gasoline, as well as from industrial sources. With the phaseout of leaded gasoline, large manufacturing facilities are the sources of the largest amounts of lead emissions. Pb has the potential to cause gastrointestinal, central nervous system, kidney and blood diseases upon prolonged exposure. Pb is also classified as a probable human carcinogen State Regulations California Clean Air Act. The California CAA was signed into law on September 30, 1988, and became effective on January 1, The California CAA requires that local air districts implement regulations to reduce emissions from mobile sources through the adoption and enforcement of transportation control measures. The California CAA required the SDAB to achieve a five percent annual reduction in ozone precursor emissions from 1987 until the standards are attained. If this reduction cannot be achieved, all feasible control measures must be implemented. Furthermore, the California Clean Air Act required local air districts to implement a Best Available Control Technology rule and to require emission offsets for nonattainment pollutants. The ARB is the state regulatory agency with authority to enforce regulations to both achieve and maintain air quality in the state. The ARB is responsible for the development, adoption, and enforcement of the state s motor vehicle emissions program, as well as the adoption of Air Quality Technical Report 5 06/30/10

8 the California Ambient Air Quality Standards (CAAQS). The ARB also reviews operations and programs of the local air districts, and requires each air district with jurisdiction over a nonattainment area to develop its own strategy for achieving the NAAQS and CAAQS. The CAA allows states to adopt ambient air quality standards and other regulations provided they are at least as stringent as federal standards. The ARB has established the more stringent CAAQS for the six criteria pollutants through the California Clean Air Act of 1988, and also has established CAAQS for additional pollutants, including sulfates, hydrogen sulfide, vinyl chloride and visibility-reducing particles. The SDAB is currently classified as a nonattainment area under the CAAQS for O 3, PM 10, and PM 2.5. It should be noted that the ARB does not differentiate between attainment of the 1-hour and 8-hour CAAQS for O 3 ; therefore, if an air basin records exceedances of either standard the area is considered a nonattainment area for the CAAQS for O 3. The SDAB has recorded exceedances of both the 1-hour and 8-hour CAAQS for O 3. The following specific descriptions of health effects for the additional California criteria air pollutants are based on the ARB (ARB 2009). Sulfates. Sulfates are the fully oxidized ionic form of sulfur. In California, emissions of sulfur compounds occur primarily from the combustion of petroleum-derived fuels (e.g., gasoline and diesel fuel) that contain sulfur. This sulfur is oxidized to sulfur dioxide (SO 2 ) during the combustion process and subsequently converted to sulfate compounds in the atmosphere. The conversion of SO 2 to sulfates takes place comparatively rapidly and completely in urban areas of California due to regional meteorological features. The ARB s sulfates standard is designed to prevent aggravation of respiratory symptoms. Effects of sulfate exposure at levels above the standard include a decrease in ventilatory function, aggravation of asthmatic symptoms and an increased risk of cardio-pulmonary disease. Sulfates are particularly effective in degrading visibility, and due to fact that they are usually acidic, can harm ecosystems and damage materials and property. Hydrogen Sulfide. H 2 S is a colorless gas with the odor of rotten eggs. It is formed during bacterial decomposition of sulfur-containing organic substances. Also, it can be present in sewer gas and some natural gas, and can be emitted as the result of geothermal energy exploitation. Breathing H 2 S at levels above the standard would result in exposure to a very Air Quality Technical Report 6 06/30/10

9 disagreeable odor. In 1984, an ARB committee concluded that the ambient standard for H 2 S is adequate to protect public health and to significantly reduce odor annoyance. Vinyl Chloride. Vinyl chloride, a chlorinated hydrocarbon, is a colorless gas with a mild, sweet odor. Most vinyl chloride is used to make polyvinyl chloride (PVC) plastic and vinyl products. Vinyl chloride has been detected near landfills, sewage plants and hazardous waste sites, due to microbial breakdown of chlorinated solvents. Short-term exposure to high levels of vinyl chloride in air causes central nervous system effects, such as dizziness, drowsiness and headaches. Long-term exposure to vinyl chloride through inhalation and oral exposure causes liver damage. Cancer is a major concern from exposure to vinyl chloride via inhalation. Vinyl chloride exposure has been shown to increase the risk of angiosarcoma, a rare form of liver cancer, in humans. Visibility Reducing Particles. Visibility-reducing particles consist of suspended particulate matter, which is a complex mixture of tiny particles that consists of dry solid fragments, solid cores with liquid coatings, and small droplets of liquid. These particles vary greatly in shape, size and chemical composition, and can be made up of many different materials such as metals, soot, soil, dust, and salt. The CAAQS is intended to limit the frequency and severity of visibility impairment due to regional haze. A separate standard for visibility-reducing particles that is applicable only in the Lake Tahoe Air Basin is based on reduction in scenic quality. Table 1 presents a summary of the ambient air quality standards adopted by the federal and California CAA. Air Quality Technical Report 7 06/30/10

10 POLLUTANT AVERAGE TIME Ozone (O 3 ) Carbon Monoxide (CO) Nitrogen Dioxide (NO 2 ) Sulfur Dioxide (SO 2 ) 1 hour 8 hour 8 hours 1 hour Annual Average 1 hour Annual Average 24 hours 3 hours 1 hour Table 1 Ambient Air Quality Standards CALIFORNIA STANDARDS Concentration Measurement Method 0.09 ppm (180 g/m 3 ) Ultraviolet ppm Photometry (137 g/m 3 ) 9.0 ppm Non-Dispersive (10 mg/m 3 ) Infrared 20 ppm Spectroscopy (23 mg/m 3 ) (NDIR) ppm (56 g/m 3 ) Gas Phase 0.18 ppm Chemiluminescence (338 g/m 3 ) ppm (105 g/m 3 ) ppm (655 g/m 3 ) Ultraviolet Fluorescence NATIONAL STANDARDS Primary Secondary Measurement Method 0.12 ppm 0.12 ppm (235 g/m 3 ) (235 g/m 3 ) Ethylene ppm ppm Chemiluminescence (147 g/m 3 ) (147 g/m 3 ) 9 ppm Non-Dispersive (10 mg/m 3 ) Infrared None 35 ppm Spectroscopy (40 mg/m 3 ) (NDIR) ppm ppm (100 g/m 3 ) (100 g/m 3 ) Gas Phase Chemiluminescence 0.03 ppm (80 g/m 3 ) 0.14 ppm (365 g/m 3 ) ppm (1300 g/m 3 ) Pararosaniline Respirable Particulate Matter (PM 10 ) Fine Particulate Matter (PM 2.5 ) Gravimetric or Beta Attenuation Annual Arithmetic 20 g/m Mean Annual Arithmetic Mean 12 g/m 3 Gravimetric or Beta 150 g/m g/m 3 Inertial Separation and Gravimetric Analysis 15 g/m 3 15 g/m 3 Inertial Separation and Gravimetric Analysis Attenuation 24 hours g/m 3 35 g/m 3 Sulfates 24 hours 25 g/m 3 Ion Chromatography day Average 1.5 g/m Lead Calendar g/m Quarter Atomic Absorption 1.5 g/m 3 (Pb) 3-month Atomic Absorption Rolling Average g/m 3.15 g/m 3 Hydrogen Sulfide (H 2 S) 1 hour 0.03 ppm (42 g/m 3 ) Ultraviolet Fluorescence Vinyl Chloride 24 hours ppm (26 g/m 3 ) Gas Chromatography ppm= parts per million g/m 3 = micrograms per cubic meter mg/m 3 = milligrams per cubic meter Source: California Air Resources Board 2009 Air Quality Technical Report 8 06/30/10

11 Toxic Air Contaminants. In 1983, the California Legislature enacted a program to identify the health effects of Toxic Air Contaminants (TACs) and to reduce exposure to these contaminants to protect the public health (AB 1807: Health and Safety Code sections ). The Legislature established a two-step process to address the potential health effects from TACs. The first step is the risk assessment (or identification) phase. The second step is the risk management (or control) phase of the process. The State of California has identified diesel particulate matter as a TAC. Diesel particulate matter is emitted from on- and off-road vehicles that utilize diesel as fuel. Following identification of diesel particulate matter as a TAC in 1998, the ARB has worked on developing strategies and regulations aimed at reducing the emissions and associated risk from diesel particulate matter. The overall strategy for achieving these reductions is found in the Risk Reduction Plan to Reduce Particulate Matter from Diesel-Fueled Engines and Vehicles (State of California 2000). A stated goal of the plan is to reduce the cancer risk statewide arising from exposure to diesel particulate matter by 75 percent by 2010 and by 85 percent by The Risk Reduction Plan contains the following three components: New regulatory standards for all new on-road, off-road and stationary diesel-fueled engines and vehicles to reduce diesel particulate matter emissions by about 90 percent overall from current levels; New retrofit requirements for existing on-road, off-road and stationary diesel-fueled engines and vehicles where determined to be technically feasible and cost-effective; and New Phase 2 diesel fuel regulations to reduce the sulfur content levels of diesel fuel to no more than 15 ppm to provide the quality of diesel fuel needed by the advanced diesel particulate matter emission controls. A number of programs and strategies to reduce diesel particulate matter are in place or are in the process of being developed as part of the ARB s Diesel Risk Reduction Program. Some Air Quality Technical Report 9 06/30/10

12 of these programs and strategies include those that would apply to construction and operation of the San Ysidro Rail Yard, including the following: In 2001, the ARB adopted new particulate matter and NOx emission standards to clean up large diesel engines that power big-rig trucks, trash trucks, delivery vans and other large vehicles. The new standard for particulate matter takes effect in 2007 and reduces emissions to 0.01 gram of particulate matter per brake horsepower-hour (g/bhp-hr.) This is a 90 percent reduction from the existing particulate matter standard. New engines will meet the 0.01 g/bhp-hr particulate matter standard with the aid of diesel particulate filters that trap the particulate matter before exhaust leaves the vehicle. ARB has worked closely with the EPA on developing new particulate matter and NOx standards for engines used in offroad equipment such as backhoes, graders, and farm equipment. EPA has proposed new standards that would reduce the emission from off-road engines to similar levels to the on-road engines discussed above by These new engine standards were adopted as part of the Clean Air Nonroad Diesel Final Rule in Once approved by EPA, ARB will adopt these as the applicable state standards for new off-road engines. These standards will reduce diesel particulate matter emission by over 90 percent from new off-road engines currently sold in California. EPA has implemented a program to replace locomotive engines with Tier 3 engines for all new locomotives. This program will reduce emissions of particulate matter and NOx. As an ongoing process, the ARB reviews air contaminants and identifies those that are classified as TACs. The ARB also continues to establish new programs and regulations for the control of TACs, including diesel particulate matter, as appropriate Local Regulations The local air pollution control district (APCD) has the primary responsibility for the development and implementation of rules and regulations designed to attain the NAAQS and CAAQS, as well as the permitting of new or modified sources, development of air quality management plans, and adoption and enforcement of air pollution regulations. The San Diego APCD is the local agency responsible for the administration and enforcement of air quality regulations in San Diego County. Air Quality Technical Report 10 06/30/10

13 The APCD and SANDAG are responsible for developing and implementing the clean air plan for attainment and maintenance of the ambient air quality standards in the SDAB. The San Diego County Regional Air Quality Strategy (RAQS) was initially adopted in 1991, and is updated on a triennial basis. The RAQS was updated in 1995, 1998, 2001, 2004, and most recently in 2009 (APCD 2009). The RAQS outlines APCD s plans and control measures designed to attain the state air quality standards for O 3. The RAQS does not address the state air quality standards for PM 10 or PM 2.5. The APCD has also developed the air basin s input to the State Implementation Plan (SIP), which is required under the Federal Clean Air Act for areas that are out of attainment of air quality standards. The SIP includes the APCD s plans and control measures for attaining the O 3 NAAQS. The SIP is also updated on a triennial basis. The latest SIP update was submitted by the ARB to the EPA in 1998, and the APCD is in the process of updating its SIP to reflect the new 8-hour O 3 NAAQS. To that end, the APCD has developed its Eight-Hour Ozone Attainment Plan for San Diego County (hereinafter referred to as the Attainment Plan) (APCD 2007). The Attainment Plan forms the basis for the SIP update, as it contains documentation on emission inventories and trends, the APCD s emission control strategy, and an attainment demonstration that shows that the SDAB will meet the NAAQS for O 3. Emission inventories, projections, and trends in the Attainment Plan are based on the latest O 3 SIP planning emission projections compiled and maintained by ARB. Supporting data were developed jointly by stakeholder agencies, including ARB, the APCD, the South Coast Air Quality Management District (SCAQMD), the Southern California Association of Governments (SCAG), and SANDAG. Each agency plays a role in collecting and reviewing data as necessary to generate comprehensive emission inventories. The supporting data include socio-economic projections, industrial and travel activity levels, emission factors, and emission speciation profiles. These projections are based on data submitted by stakeholder agencies including projections in municipal General Plans. The ARB compiles annual statewide emission inventories in its emission-related information database, the California Emission Inventory Development and Reporting System (CEIDARS). Emission projections for past and future years were generated using the California Emission Forecasting System (CEFS), developed by ARB to project emission trends and track progress Air Quality Technical Report 11 06/30/10

14 towards meeting emission reduction goals and mandates. CEFS utilizes the most current growth and emissions control data available and agreed upon by the stakeholder agencies to provide comprehensive projections of anthropogenic (human activity-related) emissions for any year from 1975 through Local air districts are responsible for compiling emissions data for all point sources and many stationary area-wide sources. For mobile sources, CEFS integrates emission estimates from ARB s EMFAC2007 and OFFROAD models. SCAG and SANDAG incorporate data regarding highway and transit projects into their Travel Demand Models for estimating and projecting vehicle miles traveled (VMT) and speed. The ARB s on-road emissions inventory in EMFAC2007 relies on these VMT and speed estimates. To complete the inventory, estimates of biogenic (naturally occurring) emissions are developed by ARB using the Biogenic Emissions Inventory Geographic Information System (BEIGIS) model. Because the ARB mobile source emission projections and SANDAG growth projections are based on population and vehicle trends and land use plans developed by the cities and by the County as part of the development of General Plans, projects that propose development that is consistent with the growth anticipated by the general plans would be consistent with the RAQS and the Attainment Plan. In the event that a project would propose development which is less dense than anticipated within the general plan, the project would likewise be consistent with the RAQS and the Attainment Plan. If a project proposes development that is greater than that anticipated in the general plan and SANDAG s growth projections, the project might be in conflict with the RAQS and SIP, and might have a potentially significant impact on air quality. Air Quality Technical Report 12 06/30/10

15 2.2 Climate and Meteorology The project site is located in the SDAB. The climate of the SDAB is dominated by a semipermanent high pressure cell located over the Pacific Ocean. This cell influences the direction of prevailing winds (westerly to northwesterly) and maintains clear skies for much of the year. Figure 1 provides a graphic representation of the prevailing winds in the project vicinity, as measured in Chula Vista. The high pressure cell also creates two types of temperature inversions that may act to degrade local air quality. Subsidence inversions occur during the warmer months as descending air associated with the Pacific high pressure cell comes into contact with cool marine air. The boundary between the two layers of air creates a temperature inversion that traps pollutants. The other type of inversion, a radiation inversion, develops on winter nights when air near the ground cools by heat radiation and air aloft remains warm. The shallow inversion layer formed between these two air masses also can trap pollutants. As the pollutants become more concentrated in the atmosphere, photochemical reactions occur that produce ozone, commonly known as smog. 2.3 Background Air Quality The APCD operates a network of ambient air monitoring stations throughout San Diego County. The purpose of the monitoring stations is to measure ambient concentrations of the pollutants and determine whether the ambient air quality meets the CAAQS and the NAAQS. The nearest ambient monitoring station to the project site is the Chula Vista monitoring station, located at 80 East J Street in Chula Vista, which measures all criteria pollutants. Ambient concentrations of pollutants between 2004 and 2008 are presented in Table 2. It should be noted that the 8-hour federal ozone standard was lowered in 2008 from 0.08 ppm to ppm. The previous 8-hour federal ozone standard was exceeded once in 2004 and once in The new federal ozone standard of ppm was exceeded three times in Exceedances of the California 24-hour PM 10 standard were measured in 2007 during conditions that led to reentrainment of ash from the Cedar Fire. The California 24-hour PM 10 standard was also exceeded once in 2002, twice in 2005, and twice in 2006 at the Chula Vista Air Quality Technical Report 13 06/30/10

16 monitoring station. The NAAQS for PM 2.5 was exceeded in 2003 during the Cedar Fire event. The PM 2.5 standard has not been exceeded in the past three years. The data from the monitoring station indicates that air quality is in attainment of all other air quality standards. Figure 1. Wind Rose Chula Vista Air Quality Technical Report 14 06/30/10

17 Pollutant Averaging Time Table 2 Ambient Background Concentrations (ppm unless otherwise indicated) Most Stringent Ambient Air Quality Standard Monitoring Station Ozone 8 hour Chula Vista 1 hour Chula Vista 1 PM 10 Annual μg/m 3 Chula Vista μg/m 3 μg/m 3 μg/m 3 μg/m 3 μg/m 3 24 hour 44 μg/m 3 53 μg/m 3 52 μg/m 3 58 μg/m 3 54 μg/m 3 50 μg/m 3 Chula Vista 1 PM 2.5 Annual μg/m 3 Chula Vista μg/m 3 μg/m 3 μg/m 3 μg/m 3 μg/m 3 24 hour μg/m 3 Chula Vista μg/m 3 μg/m 3 μg/m 3 μg/m 3 μg/m 3 NO 2 Annual Chula Vista 1 hour Chula Vista CO 8 hour Chula Vista 1 hour Chula Vista SO 2 Annual Chula Vista 24 hour Chula Vista 3 hour Chula Vista 1 hour Chula Vista 1 The maximum particulate matter measurements occurred in 2007 during the southern California fire events. 2 Secondary NAAQS Source: (Measurements of all pollutants at Chula Vista station ) (1-hour and 3-hour SO 2 and 1-hour CO) Table 3 provides a summary of the air quality measurements recorded at the Chula Vista Monitoring Station for O 3, CO, NO 2, PM 10, and PM 2.5. Air Quality Technical Report 15 06/30/10

18 Table 3 Summary of Air Quality Measurements Recorded at the Chula Vista Monitoring Station Pollutant/Standard Ozone Days 1-hour State Standard Exceeded (0.09 ppm) Maximum 1-hour Measurement (ppm) Days 8-hour State Standard Exceeded (0.070 ppm) Days 8-hour Federal Standard Exceeded (0.070 ppm) Maximum 8-hour Measurement (ppm) Carbon Monoxide Days 8-hour State Standard Exceeded (9.0 ppm) Days 8-hour Federal Standard Exceeded (9 ppm) Maximum 8-hour State Measurement (ppm) Maximum 8-hour Federal Measurement (ppm) Nitrogen Dioxide Days 1-hour State Standard Exceeded (0.18 ppm) Maximum 1-hour State Measurement (ppm) Annual Average PM 10 Days 24-hour State Standard Exceeded (50 µg/m 3 ) Days 24-hour Federal Standard Exceeded ( µg/m 3 ) 1 Maximum 24-hour State Measurement (µg/m 3 ) Maximum 24-hour Federal Measurement (µg/m 3 ) State Annual Average (µg/m 3 ) Federal Annual Average (µg/m 3 ) PM 2.5 Days 24-hour Federal Standard Exceeded (35 µg/m 3 ) Maximum 24-hour State Measurement (µg/m 3 ) Maximum 24-hour Federal Measurement (µg/m 3 ) State Annual Average (µg/m 3 ) Federal Annual Average (µg/m 3 ) Source: ARB 2009, 1 Federal Standard refers to the primary federal standard. In the case of O 3 and PM 10, the secondary federal standards are the same as the primary federal standards. There are no secondary federal standards for carbon monoxide. 2 Calculated days measurements are typically collected every six days. Calculated days are the estimated number of days that a measurement would have been greater than the level of the standard had measurements been collected every day. The number of days above the standard is not necessarily the number of violations of the standard for the year. 3 Data provided for the previous Federal Standard of 65 µg/m 3 as the standard is not applied retroactively. 4 Insufficient data to provide a result 3.0 Thresholds of Significance The State of California has developed guidelines to address the significance of air quality impacts based on Appendix G of the State CEQA Guidelines. According to Appendix G of the CEQA Guidelines, the proposed Project would have a significant impact on air quality if: Air Quality Technical Report 16 06/30/10

19 1. It conflicts with or obstructs the implementation of the San Diego RAQS or applicable portions of the SIP; 2. It violates any air quality standard or contributes substantially to an existing or projected air quality violation; 3. It results in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard. In the SDAB, the project region is non-attainment for the federal standard for O 3 and the state standards for O 3, PM 10, and PM It exposes sensitive receptors (including, but not limited to, residents, schools, hospitals, resident care facilities, parks, or day-care centers) to substantial pollutant concentrations; or 5. It creates objectionable odors affecting a substantial number of people. SANDAG has not adopted specific emission thresholds by which to evaluate the significance of air quality impacts of projects within its jurisdiction. However, stationary source thresholds identified by the local air pollution control agency are often used as quantitative significance thresholds to evaluate whether emissions have the potential to result in a significant impact on the ambient air quality. The San Diego APCD has established emission thresholds for stationary sources in Rules 20.2 and 20.3, above which a source would be required to conduct an air quality impact assessment to demonstrate that the project would not cause or contribute to a violation of an air quality standard. These emission thresholds provide a basis for evaluating whether a project s emissions could result in an adverse air quality impacts. The San Diego APCD emission thresholds are shown in Table 4. While these thresholds do not apply to mobile sources specifically, they are used by the City of San Diego as significance thresholds (City of San Diego 2007) and because SANDAG has not adopted significance thresholds, the City s thresholds are used to evaluate the potential for significant impacts. Should emissions exceed the thresholds in Table 4, further evaluation may be conducted to determine whether, as discussed above under Appendix G of the CEQA Guidelines, the Air Quality Technical Report 17 06/30/10

20 Project would violate any air quality standard or contributes substantially to an existing or projected air quality violation. To conduct this further evaluation for attainment pollutants such as CO and SOx, an air quality impact assessment may be conducted to determine whether the Project would result in an exceedance of an air quality standard. Table 4 Quantitative Significance Thresholds Pollutant Total Emissions Lb. per Day Respirable Particulate Matter (PM 10 ) 100 Fine Particulate Matter (PM 2.5 ) a 55 Oxides of Nitrogen (NOx) 250 Oxides of Sulfur (SOx) 250 Carbon Monoxide (CO) 550 Reactive Organic Gases (ROG) b 137 a Threshold for PM 2.5 from SCAQMD Threshold for ROG from City of San Diego Significance Determination Thresholds (City of San Diego 2007) For nonattainment pollutants (ozone, with ozone precursors NOx and ROG) and PM 10, modeling is not generally conducted because background ambient levels already exceed the air quality standards. If emissions of nonattainment pollutants or precursors exceed the thresholds shown in Table 4, the project would have the potential to result in a cumulatively considerable net increase in these pollutants and thus would have a significant impact on the ambient air quality. In addition to impacts from criteria pollutants, project impacts may include emissions of pollutants identified by the state and federal government as TACs or Hazardous Air Pollutants (HAPs). In San Diego County, APCD Regulation XII establishes acceptable risk levels and emission control requirements for new and modified facilities that may emit additional TACs. Under Rule 1200, permits will be granted to a source with a risk of 10 in 1 million or less provided the source implements Toxics-Best Available Control Technology. Under Rule 1210, emissions of TACs that result in a cancer risk of 10 in 1 million or less and a health hazard index of one or less would not be required to notify the public of potential health risks. If a project has the potential to result in emissions of any TAC or HAP which result in a Air Quality Technical Report 18 06/30/10

21 cancer risk of greater than 10 in 1 million, the project would be deemed to have a potentially significant impact. With regard to evaluating whether a project would have a significant impact on sensitive receptors, air quality regulators typically define sensitive receptors as schools (Preschool-12 th Grade), hospitals, resident care facilities, parks, or day-care centers, or other facilities that may house individuals with health conditions that would be adversely impacted by changes in air quality. Any project which has the potential to directly impact a sensitive receptor located within 1 mile and results in a health risk greater than 10 in 1 million would be deemed to have a potentially significant impact. The following sensitive receptors are located within 1 mile of the San Ysidro Rail Yard: San Ysidro Head Start, 249 Willow Road, San Ysidro Willow Elementary School, 2312 E. Beyer, San Ysidro Beyer Elementary School, 2312 E. Beyer, San Ysidro Our Lady of Mt. Carmel School, 4141 Beyer Blvd., San Ysidro San Ysidro Middle School, 4345 Otay Mesa Road, San Ysidro La Mirada Elementary School, 222 Avenida De La Madrid, San Ysidro Smythe Elementary School, 1880 Smythe Avenue, San Ysidro Sunset Elementary School, 3825 Sunset Lane, San Ysidro New Life Christian Academy, 3747 Sunset Lane, San Ysidro APCD Rule 51 (Public Nuisance) also prohibits emission of any material which causes nuisance to a considerable number of persons or endangers the comfort, health or safety of any person. A project that proposes a use which would produce objectionable odors would be deemed to have a significant odor impact if it would affect a considerable number of offsite receptors. The APCD is also in the process of adopting Rule 55, which regulates emissions of fugitive dust. The impacts associated with construction and operation of the Project were evaluated for significance based on these significance criteria. Air Quality Technical Report 19 06/30/10

22 4.0 Impacts The proposed could potentially result in both construction and operational impacts. Air quality impacts are mainly associated with construction of the improvements to the Rail Yard. Activities associated with Rail Yard improvements include grading and construction of two new track extensions, a new access road, and installation of lighting and fencing. According to SANDAG, the facility would allow storage of an additional 89 rail cars. Operational impacts will be associated with truck traffic and rail operations. For the purpose of estimating rail emissions, it was assumed that operations would not change from existing operations. 4.1 Consistency with the RAQS and SIP The proposed Project would have a significant impact if it conflicts with or obstructs implementation of the applicable air quality plans (the RAQS and SIP). As discussed in Section 2.1, the SIP is the document that sets forth the state s strategies for attaining and maintaining the NAAQS. SANDAG and the APCD is responsible for developing the San Diego portion of the SIP, and has developed an attainment plan for attaining the 8-hour NAAQS for O 3. The RAQS sets forth the plans and programs designed to meet the state air quality standards. Through the RAQS and SIP planning processes, the APCD adopts rules, regulations, and programs designed to achieve attainment of the ambient air quality standards and maintain air quality in the SDAB. Conformance with the RAQS and SIP determines whether a project will conflict with or obstruct implementation of the applicable air quality plans. The basis for the RAQS and SIP is the distribution of population in the San Diego region as projected by SANDAG. Growth forecasting is based in part on the land uses established by the General Plan. For transportation-related projects such as the, Air Quality Technical Report 20 06/30/10

23 provided the Project is listed within the Regional Transportation Plan, its emissions have been accounted for in the growth forecasts accounted for within the RAQS and SIP. The is listed within the 2030 San Diego Regional Transportation Plan (RTP): Pathways for the Future (Table B.1-San Diego Regional Goods Movement Action Plan List of Prioritized Projects and Revenue Scenarios), and is therefore accounted for within the RAQS and SIP. The Project would therefore not conflict with the RAQS and SIP and would therefore not cause a significant air quality impact. 4.2 Violation of an Air Quality Standard The proposed Project would have a significant impact if it violates any air quality standard or contributes substantially to an existing or projected air quality violation. To address this significance threshold, an evaluation of emissions associated with both the construction and operational phases of the Project was conducted Construction Impacts Emissions of pollutants such as fugitive dust and heavy equipment exhaust that are generated during construction are generally highest near the construction site. Construction equipment, truck traffic, and manpower requirements were provided by SANDAG. It was assumed that the Project would require 18 months for construction. The following assumptions were used to develop estimates of construction equipment based on construction phases: Phase 1 Grading and Drainage Work 9 months 90,000 cubic yards cut 3,000 cubic yards fill 2 backhoe/loaders 2 dozers 2 dump trucks 2 scrapers Air Quality Technical Report 21 06/30/10

24 2 graders 2 compactors 2 front loaders 1 water truck Workforce: 25 workers Phase 2 Access Road Grading and Track Work 6 months 80,000 cubic yards cut 6,000 cubic yards fill 2 dozers 2 dump trucks 2 front loaders 2 cranes 1 water truck Workforce: 15 people Phase 3 Paving of Access Road and Alternative Design Areas 3 months 2 compactors 2 dump trucks Workforce: 15 people Emissions from construction were evaluated using the URBEMIS Model, Version (Rimpo and Associates 2007). The URBEMIS Model includes emission factors from the California ARB s OFFROAD model (ARB 2007) and the EMFAC2007 Model; however, it should be noted that because the model does not include San Diego-specific emission factors, California state-wide emission factors were used to estimate construction emissions. Emission calculations were conducted assuming standard fugitive dust control measures would be implemented during construction. These measures include the following: Application of soil stabilizers to inactive areas Replace ground cover in disturbed areas as soon as possible Water exposed surfaces a minimum of twice daily Control of dust during equipment loading/unloading Reduce speed on unpaved surfaces to 15 mph Water unpaved roads a minimum of twice daily Air Quality Technical Report 22 06/30/10

25 As shown in Table 5, based on the estimates of the emissions associated with Project construction, the emissions of criteria pollutants would be below the San Diego APCD s significance thresholds (refer to Table 4) and would therefore result in a less than significant air quality impact. Air Quality Technical Report 23 06/30/10

26 Table 5 Estimated Maximum Daily Construction Emissions San Ysidro Rail Yard PM 10 Dust PM 10 Exhaust PM 10 Total PM 2.5 Dust PM 2.5 Exhaust Construction Activity ROG NOx CO SO 2 Grading and Drainage Work Fugitive Dust Off-Road Diesel On-Road Diesel Worker Trips TOTAL Significance Threshold Above Threshold? No No No No - - No - - No Access Road Grading and Track Work Fugitive Dust Off-Road Diesel On-Road Diesel Worker Trips TOTAL Significance Threshold Above Threshold? No No No No - - No - - No Paving Asphalt Offgassing Paving Off-Road Diesel Paving On-Road Diesel Worker Trips TOTAL Significance Threshold Above Threshold? No No No No - - No - - No PM 2.5 Total Air Quality Technical Report 24 06/30/10

27 4.2.2 Operational Impacts Operational impacts associated with the would include impacts associated with vehicular traffic, emissions associated with operation of the facility and routine maintenance, and emissions from rail engines operating at the railyard. Rail emissions will be unchanged from existing conditions and will not result in an emission increase. Average daily trips for the project were estimated in the Traffic Impact Study (Kimley Horn and Associates 2009). Based on the study, an additional 28 large truck trips would be associated with the Project. According to the Traffic Impact Study, no additional passenger car or small truck trips would be associated with the project; therefore, the only additional emissions from on-road vehicles would be associated with 28 heavy-duty truck trips. Emissions from heavy-duty truck were calculated using the EMFAC2007 Model, which is the ARB s model for mobile source emissions. Emissions from other activities such as maintenance were considered to be minor. Emissions are summarized in Table 6. Table 6 Operational Emissions San Ysidro Rail Yard ROG NOx CO SO x PM 10 PM 2.5 Lbs/day 1 Truck Emissions TOTAL Significance Screening Criteria Above Screening Criteria? No No No No No No Tons/year Truck Emissions TOTAL Significance Screening Criteria Above Screening Criteria? No No No No No No Air Quality Technical Report 25 06/30/10

28 Based on the estimates of the emissions associated with Project operations, the emissions of criteria pollutants would be below the San Diego APCD s significance thresholds and would therefore result in a less than significant air quality impact. 4.3 Cumulatively Considerable Net Increase of Nonattainment Pollutants The proposed Project would have a significant impact if it results in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors. As discussed in Section 2.0, the SDAB is considered a nonattainment area for the 8-hour NAAQS for O 3, and is considered a nonattainment area for the CAAQS for O 3, PM 10, and PM 2.5. An evaluation of emissions of nonattainment pollutants was conducted in Section 4.2, and it was determined that emissions of ozone precursors ROG and NOx would be below the significance thresholds during both construction and operation construction. Emissions of PM 10 and PM 2.5 are also less than the significance thresholds. Because construction is temporary, and because it is unlikely that construction of other nearby would be occurring at the same time and level of intensity as the San Ysidro Rail Yard Improvement Project, emissions would be less than cumulatively significant. Because the Project has been considered in the RTP for the San Diego region, the Project s emissions have been considered in the cumulative analysis of impacts for nonattainment pollutants included in the attainment demonstration for the SDAB. The Project would therefore not result in a cumulatively considerable impact related to nonattainment pollutants. Air Quality Technical Report 26 06/30/10

29 4.4 Exposure of Sensitive Receptors to Substantial Pollutant Concentrations The proposed Project would have a significant impact if it exposes sensitive receptors (including, but not limited to, schools, hospitals, resident care facilities, parks, or daycare centers) to substantial pollutant concentrations. The threshold concerns whether the Project could expose sensitive receptors to substantial pollutant concentrations of TACs. If a project has the potential to result in emissions of any TAC which result in a cancer risk of greater than 10 in 1 million or substantial non-cancer risk, that project would be deemed to have a potentially significant impact. Truck traffic and locomotives may result in emissions of diesel particulate matter, which is characterized by the State of California as a TAC. Certain types of projects are recommended to be evaluated for impacts associated with TACs. In accordance with the SCAQMD s Health Risk Assessment Guidance for Analyzing Cancer Risks from Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis (SCAQMD 2003), projects that should be evaluated for diesel particulate emissions include truck stops, distribution centers, warehouses, and transit centers which diesel vehicles would utilize and which would be sources of diesel particulate matter from heavy-duty diesel trucks. In addition, the ARB in their Air Quality and Land Use Handbook (ARB 2005) has identified railyards as a source of TAC emissions. These sources represent operational sources of diesel particulate matter that would result in the potential for long-term emissions, and therefore long-term exposure, to diesel particulate matter. A Health Risk Assessment (HRA) was conducted to determine if the Project would result in potentially significant air quality impacts related to TACs. This HRA was prepared in accordance with the California Office of Environmental Health Hazard Assessment s (OEHHA) Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments (OEHHA 2003a), the SCAQMD Health Risk Assessment Guidance for Analyzing Cancer Risks from Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis (SCAQMD 2003), and the HotSpots Analysis and Reporting Program User Guide Air Quality Technical Report 27 06/30/10

30 (California Air Resources Board 2003a). The primary objective of this HRA is to estimate upper-bound incremental excess cancer risks and non-cancer health hazards associated with operation of the proposed Project. The health risk calculations utilize the U.S. EPA s AERMOD Model, which is the currently approved regulatory model for air dispersion modeling. The AERMOD Model allows the user to identify point, volume, and area sources. The AERMOD Model utilizes estimates of emissions arising from sources and, using hourly meteorological data that includes wind speed, wind direction, and atmospheric conditions, calculates downwind concentrations of pollutants at receptor locations specified by the user. For the San Ysidro Rail Yard analysis, the model was used to calculate concentrations of diesel particulate matter from projectrelated truck trips. To estimate emissions from truck traffic associated with the San Ysidro Rail Yard Improvements Project, emissions of diesel particulate were calculated for the additional truck trips as described in Section using the diesel particulate exhaust emission factors from EMFAC2007. For conservative purposes, emission factors for 2012 were used to represent diesel particulate emissions from trucks; emissions would decrease in future years as predicted by the EMFAC model. Because the emission factors provided are based on grams per vehicle mile traveled, emissions were allocated to the individual volume sources used to represent the each roadway segment. The volume sources were placed at 50-meter intervals along the roadways that will be used for project traffic at the project site. Each volume therefore represents mile of vehicle travel per volume source. For this HRA, the exposure assumptions dictated by the OEHHA guidelines (OEHHA 2003) were used to assess potential human health risks. In order to determine the total dose to the receptor, the applicable pathways of exposure need to be identified. As stated in the guidelines, the inhalation pathway must be evaluated from all TACs emitted by Project operations. Because this risk assessment focuses on diesel particulate risks, multi-pathway exposures (i.e., exposure through soil dermal exposure, ingestion of plants, etc.) were not considered in this risk assessment. Diesel particulate has not been identified by the OEHHA Air Quality Technical Report 28 06/30/10

31 as a multi-pathway TAC and therefore has no health identified effects associated with dermal exposure or ingestion. Methods used in this HRA are conservative in that they are more likely to overestimate than underestimate the potential human health risks. For example, risks and hazards are calculated for individuals at locations where ground-level concentrations of TACs are predicted by the air dispersion modeling to be the highest. Further, individuals are assumed to be exposed in residential exposure scenarios for long durations. Resulting incremental cancer risk estimates represent upper-range predictions of exposure and therefore health risks which may be associated with exposure to emissions from Project truck traffic. Furthermore, the toxicity values (i.e., the values for each chemical at which an adverse health risk is predicted) are designed to be health-protective and are therefore also conservative. Thus the risks calculated for the Project are anticipated to represent upper-bound risks rather than actual values for each individual. To estimate potential incremental cancer risks and the potential for adverse chronic noncancer health hazards to exposures, the dose through inhalation of TACs was calculated. The equation for dose through inhalation (Dose-inh) is as follows: Dose-inh = (C x DBR x A x EF x ED)/(AT) Where: Dose-inh = Chronic daily intake, mg/kg body weight per day C = Ground-level concentration of TAC to which the receptor is exposed, micrograms/cubic meter DBR = Daily breathing rate, liters per kilogram body weight per day A = Inhalation absorption factor (assumed to be 1) EF = Exposure frequency, days/year ED = Exposure duration, years AT = Averaging time, days (assumed to be 25,550 days for a 70-year cancer risk) Air Quality Technical Report 29 06/30/10

32 The analysis focused on exposure to residents living near the San Ysidro Rail Yard, and students and staff at schools identified in the vicinity of the rail yard. Residents would be exposed to TACs mainly through inhalation. As discussed above, multi-pathway risks would not contribute to the overall incremental cancer or non-cancer risks associated with the Project site. In accordance with OEHHA guidelines, residents are assumed to be exposed for 24 hours per day, 350 days per year, for a 70-year period. Figure 2 provides an aerial view of the site showing the location of sources and receptors used in the analysis. On the figure, sources are represented by red points, and receptors by black points. Air Quality Technical Report 30 06/30/10

33 Figure 2. San Ysidro Rail Yard HRA Modeling Configuration Air Quality Technical Report 31 06/30/10

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