Prado Planned Deviation Project Air Quality/Greenhouse Gas Emissions

Transcription

1 August 17, 2015 Daniel Bott Principal Planner Orange County Water District Ward Street Fountain Valley, California VIA Subject: Prado Planned Deviation Project Air Quality/Greenhouse Gas Emissions Dear Mr. Bott: This report provides the results of the air pollutant and greenhouse gas (GHG) emissions analysis for the Orange County Water District s (OCWD s) Planned Deviation to the 2 Prado Dam Interim Water Control Plan (Deviation Project). The Deviation Project would increase the surface water elevation in the buffer pool from 498 ft. to 505 ft. during flood season and excavate and remove approximately 20,000 cubic yards (cy) of sediment from the Prado Basin and transport it to the El Sobrante Landfill in Corona. The 20,000 cy of sediment would be removed from a location that has been evaluated as part of OCWD proposed Prado Basin Sediment Management Demonstration Project (PMSMDP) which evaluates the removal of up to 500,000 cy of sediment. An air quality and GHG analysis was prepared for the PMSMDP by First Carbon Solutions (First Carbon 2014). It is understood that OCWD will prepare California Environmental Quality Act (CEQA) and National Environmental Protection Act (NEPA) documents for the Deviation Project using the data in this analysis combined with applicable elements of the PMSMDP analysis. This Deviation Project analysis uses data from the PMSMDP analysis as well as data provided by OCWD. METHODS Emissions were calculated by using California Emissions Estimator Model (CalEEMod) version (SCAQMD 2013). CalEEMod is a computer program accepted by the South Coast Air Quality Management District (SCAQMD) that can be used to estimate anticipated emissions associated with land development projects in California. CalEEMod has separate databases for specific counties and air districts. The Orange County database was used for the Project. The model calculates emissions of carbon dioxide (CO); respirable particulate matter with a diameter of 10 microns or less (), and fine particulate matter with a diameter of 2.5 microns or less (); the ozone (O 3 ) precursors volatile organic compounds (VOC) and nitrogen oxides (NOx); and GHGs. The results are expressed in pounds per day (lbs/day) and tons per year (tpy) and are compared with the applicable thresholds to determine impact significance. 3 Hutton Centre Drive Suite 200 Santa Ana, CA Tel

2 Daniel Bott August 17, 2015 Page 2 Specific inputs to CalEEMod include land uses and areas of impact. Construction input data include but are not limited to (1) the anticipated start and finish dates of each Project construction activity (e.g., site preparation, sediment removal); (2) inventories of construction equipment to be used during each activity; (3) areas to be graded; (4) volumes of materials to be exported from and imported to the Project area; and (5) truck and worker vehicle trips. The input data and assumptions are discussed below and in Attachment A. The CalEEMod model has the capability to calculate reductions in construction emissions from the effects of dust control, diesel-engine classifications, and other selected emissions reduction measures. CalEEMod was developed using EMFAC 2011 and OFFROAD 2011 for calculating emissions from onroad vehicles and off-road construction equipment, respectively. AIR QUALITY IMPACT ANALYSIS Two phases of the Deviation Project are analyzed: site preparation and sediment removal. These phases correlate with the Clearing and Grubbing element of Phase II and the Optional Dry Excavation element of Phase V in the First Carbon Report, respectively. Based on discussions with OCWD staff, it is assumed that 12 acres would be impacted and that the project would occur in If the project does not occur until 2017, the calculated emissions would be the same or less than for Site preparation would take 5 days followed by 30 working days of sediment removal. Sediment would be removed at a rate of 8 truckloads per hour for 6 hours per day. The sediment would be hauled a distance of 18 miles to the El Sobrante Landfill. Approximately 1.4 miles of the haul would be on unpaved roads. Equipment types and horsepower data are similar to those specified for the corresponding elements of the PMSMDP. OCWD would comply with SCAQMD Rule 403, Dust, which requires dust control measures on active grading/sediment excavation areas and on unpaved roads. Rule 403 dust control measures are processed in CalEEMod as mitigation measures and include the following requirements: Apply soil stabilizer to unpaved roads Water the exposed grading/sediment removal area three times daily Limit vehicle speed on unpaved roads to 15 miles per hour Clean trackout from paved roads Mass Emissions Thresholds California Environmental Quality Act Analysis The results of the Deviation Project criteria pollutant calculations as the maximum anticipated daily emissions for each phase are shown in Table 1. These values are compared with the SCAQMD mass daily thresholds. 1 As shown in Table 1, all pollutant estimated emissions would be less than the applicable SCAQMD CEQA significance thresholds 1 Background information for the SCAQMD thresholds is included in the PMSMDP air quality analysis.

3 Daniel Bott August 17, 2015 Page 3 TABLE 1 DEVIATION PROJECT ESTIMATED MAXIMUM DAILY EMISSIONS (LBS/DAY) Phase: Activities VOC NOx CO * * II: Site Preparation/ Clearing and Grubbing V: Sediment Removal SCAQMD Thresholds Exceeds Threshold? No No No No No lbs/day: pounds per day; VOC: volatile organic compound; NOx: nitrogen oxides; CO: carbon monoxide; : respirable particulate matter with a diameter of 10 microns or less; : fine particulate matter with a diameter of 2.5 microns or less; SCAQMD: South Coast Air Quality Management District. * and emissions include Rule 403 dust control measures. Source (thresholds): SCAQMD See Attachment A for CalEEMod model outputs. Mass Emissions Thresholds General Conformity and National Environmental Policy Act Analysis Table 2 shows the results of the Deviation Project criteria pollutant calculations as the maximum anticipated annual emissions for each phase. These values are compared with the General Conformity de minimis annual thresholds. 2 Annual emissions for General Conformity are also provided in Attachment B, in the table format often required by federal agencies. TABLE 2 DEVIATION PROJECT ESTIMATED ANNUAL EMISSIONS (TONS) Phase: Activities VOC NOx CO * * II: Site Preparation/ Clearing and Grubbing V: Sediment Removal General Conformity de minimis Thresholds (tons per year) Emissions Exceeds Threshold? No No No No No VOC: volatile organic compound; NOx: nitrogen oxides; CO: carbon monoxide; : respirable particulate matter with a diameter of 10 microns or less; : fine particulate matter with a diameter of 2.5 microns or less. Some totals do not add due to rounding. * and emissions include Rule 403 dust control measures. Source (thresholds): USEPA See Attachment A for CalEEMod model outputs. It should be noted that some General Conformity de minimis thresholds shown in Table 2 differ from those shown in the PMSMDP analysis. The changes are due to the following: (1) is an attainment/maintenance pollutant for national standards and it was shown as being in serious nonattainment in the PMSMDP analysis and (2) General Conformity thresholds were established in 2010 and the PMSMDP analysis indicates that there is no threshold. The current State and federal attainment status for the Riverside County portion of the South Coast Air Basin are shown in Table 3. 2 Background information for the General Conformity thresholds is included in the PMSMDP air quality analysis.

4 Daniel Bott August 17, 2015 Page 4 TABLE 3 ATTAINMENT STATUS OF CRITERIA POLLUTANTS IN THE RIVERSIDE COUNTY PORTION OF THE SOUTH COAST AIR BASIN Pollutant State Federal O3 (1 hour) O3 (8 hour) Nonattainment No standard Extreme Nonattainment Nonattainment Attainment/Maintenance Nonattainment a Nonattainment CO Attainment Attainment/Maintenance NO2 Attainment b Attainment/Maintenance SO2 Attainment Attainment Lead Attainment Attainment All others Attainment/Unclassified No standards O 3 : ozone; : respirable particulate matter 10 microns or less in diameter; : fine particulate matter 2.5 microns or less in diameter; CO: carbon monoxide; NO 2 : nitrogen dioxide; SO 2 : sulfur dioxide; USEPA: U.S. Environmental Protection Agency; SoCAB: South Coast Air Basin; CARB: California Air Resources Board. a On November 30, 2014, the USEPA proposed a finding that the SoCAB has attained the 1997 standards. If approved, the SoCAB would remain a nonattainment area for the 2006 standard. b CARB Executive Order R (February 25, 2014) reclassified the SoCAB to attainment for NO 2 and lead. The redesignation was effective July 1, Source: CARB 2015; USEPA GREENHOUSE GAS EMISSIONS IMPACT ANALYSIS As described above, GHG emissions were calculated using CalEEMod. For both CEQA and NEPA consideration, GHG emissions are quantified as metric tons of carbon dioxide equivalent (MTCO 2 e) per year. The calculated GHG emissions for the Deviation Project are shown in Table 4. TABLE 4 DEVIATION PROJECT ESTIMATED ANNUAL GREENHOUSE GAS EMISSIONS (TONS) Emissions Phase: Activities (MTe) II: Site Preparation/ Clearing and Grubbing 12 V: Sediment Removal SCAQMD CEQA Threshold (MTe/year) 3,000 or 10,000 * Exceeds Threshold? No CEQ NEPA Threshold (MTe/year) 25,000 Exceeds Threshold? No MTCO 2 e: metric tons of carbon dioxide equivalent; SCAQMD: South Coast Air Quality Management District; CEQA: California Environmental Quality Act; CEQ: Council on Environmental Quality; NEPA: National Environmental Policy Act. * See text following this table. See Attachment A for CalEEMod model outputs

5 Daniel Bott August 17, 2015 Page 5 The SCAQMD CEQA threshold in Table 4 is shown as 3,000 or 10,000 because 3,000 MTCO 2 e/year is used in the PMSMDP analysis and 10,000 MTCO 2 e/year is the SCAQMD threshold for industrial projects and the Deviation Project is an industrial project. It is also noted that the PMSMDP analysis adds the GHG emissions over multiple years and then amortizes the emissions over 30 years, which is an accepted practice for development projects with an estimated 30-year operational lifetime. Because the Deviation Project would be a one-time, short-duration operation, the amortization method is not used here. The NEPA threshold in Table 4 is different from the 10,000 MTCO 2 e/year threshold used in the PMSMDP NEPA GHG analysis. In regulatory discussions, the PMSMDP analysis correctly cites the White House Council on Environmental Quality s (CEQ s) Draft NEPA Guidance on the Consideration of the Effects of Climate Change and Greenhouse Gas Emissions as the source for a 25,000 MTCO 2 e/year project-level screening threshold. However, in the NEPA GHG analysis section of the PMSMDP analysis, a 10,000 MTCO 2 e/year screening level is quoted. It is noted that CEQ repeated the 25,000 MTCO 2 e threshold in the December 2014 Revised Draft Guidance on the Consideration of Greenhouse Gas Emissions and the Effects of Climate Change in NEPA Reviews (CEQ 2014). Thank you for the opportunity to assist on this project. If you have any questions or comments, please contact me at (714) Sincerely, BonTerra Psomas James P. Kurtz Director, Air Quality & Acoustical Programs Attachments: A CalEEMod Outputs B OCWD Deviation Project General Conformity Table R:\Projects\OCW_OCWD\3OCW011\AQ GHG\Prado Planned Deviation Air Quality docx

6 Daniel Bott August 17, 2015 Page 6 REFERENCES California Air Resources Board (CARB) (January 9, page last reviewed). Air Quality Standards and Area Designations. Sacramento, CA: CARB. Council on Environmental Quality (December). Revised Draft Guidance for Greenhouse Gas Emissions and Climate Change Impacts. Washington, D.C.: CEQ. administration/eop/ceq/initiatives/nepa/ghg-guidance. First Carbon Solutions (First Carbon) (February 4). Air Quality and Greenhouse Gas Analysis Report Prado Basin Sediment Management Demonstration Project, Riverside County, California South Coast Air Quality Management District (SCAQMD) (March). SCAQMD Air Quality Significance Thresholds. Diamond Bar, CA: SCAQMD California Emission Estimator Model (CalEEMod) TM Version Developed by Environ International Corporation in Collaboration with SCAQMD and other California Air LACFCDs. Diamond Bar, CA: SCAQMD (May, as amended through 2). Rule 403: Dust. Diamond Bar, CA: SCAQMD. U.S. Environmental Protection Agency (USEPA) (December 9). Clean Data Determination for 1997 PM 2.5 Standards; California South Coast; Applicability of Clean Air Act Requirements. Federal Register 79(236): Washington, D.C.: USEPA (last updated May 6). General Conformity: Regulatory Actions. Washington, D.C.: USEPA.

7 ATTACHMENT A CALEEMOD DATA

8 CalEEMod Version: CalEEMod Date: 7/29/2015 8:10 AM OCWD Prado Planned Deviation Riverside-South Coast County, Winter 1.0 Project Characteristics 1.1 Land Usage Land Uses Size Metric Lot Acreage Floor Surface Area Population User Defined Industrial 1.00 User Defined Unit Other Project Characteristics Urbanization Urban Wind Speed (m/s) 2.4 Precipitation Freq (Days) 28 Climate Zone 10 Operational Year 2017 Utility Company Southern California Edison Intensity (lb/mwhr) CH4 Intensity (lb/mwhr) N2O Intensity (lb/mwhr) User Entered Comments & Non-Default Data Project Characteristics - Land Use - 12 acre area for dry excavation Construction Phase - Schedule per OCWD Off-road Equipment - Equipment per OCWD Off-road Equipment - Equipment and HP per OCWD Grading - Disturbance for dust estimated Trips and VMT - 48 round trips per day; 18 miles to El Sobrante On-road Dust miles unpaved Construction Off-road Equipment Mitigation - Page 1 of 8

9 Table Name Column Name Default Value New Value tblconstructionphase NumDays tblconstructionphase PhaseEndDate 10/19/ /20/2016 tblgrading AcresOfGrading tblgrading AcresOfGrading tblgrading MaterialExported , tblgrading MaterialExported tbllanduse LotAcreage tbloffroadequipment HorsePower tbloffroadequipment HorsePower tbloffroadequipment HorsePower tbloffroadequipment HorsePower tbloffroadequipment LoadFactor tbloffroadequipment OffRoadEquipmentType Excavators tbloffroadequipment OffRoadEquipmentUnitAmount tbloffroadequipment OffRoadEquipmentUnitAmount tbloffroadequipment OffRoadEquipmentUnitAmount tbloffroadequipment OffRoadEquipmentUnitAmount tbloffroadequipment UsageHours tbloffroadequipment UsageHours tblonroaddust HaulingPercentPave tblonroaddust HaulingPercentPave tblprojectcharacteristics OperationalYear tbltripsandvmt HaulingTripLength tbltripsandvmt HaulingTripLength tbltripsandvmt HaulingTripNumber tbltripsandvmt HaulingTripNumber 2, , Page 2 of 8

10 2.0 Emissions Summary 2.1 Overall Construction (Maximum Daily Emission) Unmitigated Construction ROG NOx CO SO2 Bio- NBio- CH4 N2O e Year lb/day lb/day , , , , Mitigated Construction ROG NOx CO SO2 Bio- NBio- CH4 N2O e Year lb/day lb/day , , , , ROG NOx CO SO2 Bio- NBio- CH4 N20 e Percent Reduction Page 3 of 8

11 3.0 Construction Detail Construction Phase Phase Number Phase Name Phase Type Start Date End Date Num Days Week Num Days Phase Description 1 Clearing and grubbing Site Preparation 9/1/2016 9/7/ Sediment removal Grading 9/8/ /20/ Acres of Grading (Site Preparation Phase): 0 Acres of Grading (Grading Phase): 0 Acres of Paving: 0 Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0 (Architectural Coating sqft) OffRoad Equipment Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Clearing and grubbing Excavators Sediment removal Excavators Sediment removal Rubber Tired Dozers Sediment removal Graders Sediment removal Tractors/Loaders/Backhoes Clearing and grubbing Tractors/Loaders/Backhoes Clearing and grubbing Rubber Tired Dozers Sediment removal Scrapers Trips and VMT Phase Name Offroad Equipment Count Worker Trip Number Vendor Trip Number Hauling Trip Number Worker Trip Length Vendor Trip Length Hauling Trip Length Worker Vehicle Class Vendor Vehicle Class Hauling Vehicle Class Clearing and grubbing LD_Mix HDT_Mix HHDT Sediment removal , LD_Mix HDT_Mix HHDT Page 4 of 8

12 3.1 Mitigation Measures Construction Use Soil Stabilizer Water Exposed Area Reduce Vehicle Speed on Unpaved Roads Clean Paved Roads 3.2 Clearing and grubbing Unmitigated Construction On-Site ROG NOx CO SO2 Bio- NBio- CH4 N2O e Category lb/day lb/day Dust Off-Road , , , , Unmitigated Construction Off-Site ROG NOx CO SO2 Bio- NBio- CH4 N2O e Category lb/day lb/day Hauling e e Vendor Worker e e e e e e Page 5 of 8

13 Mitigated Construction On-Site ROG NOx CO SO2 Bio- NBio- CH4 N2O e Category lb/day lb/day Dust Off-Road , , , , Mitigated Construction Off-Site ROG NOx CO SO2 Bio- NBio- CH4 N2O e Category lb/day lb/day Hauling e e Vendor Worker e e e e e e Sediment removal Unmitigated Construction On-Site ROG NOx CO SO2 Bio- NBio- CH4 N2O e Category lb/day lb/day Dust Off-Road , , , , Page 6 of 8

14 Unmitigated Construction Off-Site ROG NOx CO SO2 Bio- NBio- CH4 N2O e Category lb/day lb/day Hauling , , Vendor Worker e e e e , , Mitigated Construction On-Site ROG NOx CO SO2 Bio- NBio- CH4 N2O e Category lb/day lb/day Dust Off-Road , , , , Page 7 of 8

15 Mitigated Construction Off-Site ROG NOx CO SO2 Bio- NBio- CH4 N2O e Category lb/day lb/day Hauling , , Vendor Worker e e e e , , Page 8 of 8

16 CalEEMod Version: CalEEMod Page 1 of 1 Date: 7/29/2015 8:26 AM OCWD Prado Planned Deviation Riverside-South Coast County, Annual 1.0 Project Characteristics 1.1 Land Usage Land Uses Size Metric Lot Acreage Floor Surface Area Population User Defined Industrial 1.00 User Defined Unit Other Project Characteristics Urbanization Urban Wind Speed (m/s) 2.4 Precipitation Freq (Days) 28 Climate Zone 10 Operational Year 2017 Utility Company Southern California Edison Intensity (lb/mwhr) CH4 Intensity (lb/mwhr) N2O Intensity (lb/mwhr) User Entered Comments & Non-Default Data Project Characteristics - Land Use - 12 acre area for dry excavation Construction Phase - Schedule per OCWD Off-road Equipment - Equipment per OCWD Off-road Equipment - Equipment and HP per OCWD Grading - Disturbance for dust estimated Trips and VMT - 48 round trips per day; 18 miles to El Sobrante On-road Dust miles unpaved Construction Off-road Equipment Mitigation - Page 1 of 8

17 Table Name Column Name Default Value New Value tblconstructionphase NumDays tblconstructionphase PhaseEndDate 10/19/ /20/2016 tblgrading AcresOfGrading tblgrading AcresOfGrading tblgrading MaterialExported , tblgrading MaterialExported tbllanduse LotAcreage tbloffroadequipment HorsePower tbloffroadequipment HorsePower tbloffroadequipment HorsePower tbloffroadequipment HorsePower tbloffroadequipment LoadFactor tbloffroadequipment OffRoadEquipmentType Excavators tbloffroadequipment OffRoadEquipmentUnitAmount tbloffroadequipment OffRoadEquipmentUnitAmount tbloffroadequipment OffRoadEquipmentUnitAmount tbloffroadequipment OffRoadEquipmentUnitAmount tbloffroadequipment UsageHours tbloffroadequipment UsageHours tblonroaddust HaulingPercentPave tblonroaddust HaulingPercentPave tblprojectcharacteristics OperationalYear tbltripsandvmt HaulingTripLength tbltripsandvmt HaulingTripLength tbltripsandvmt HaulingTripNumber tbltripsandvmt HaulingTripNumber 2, , Page 2 of 8

18 2.0 Emissions Summary 2.1 Overall Construction Unmitigated Construction ROG NOx CO SO2 Bio- NBio- CH4 N2O e Year tons/yr MT/yr e e Mitigated Construction ROG NOx CO SO2 Bio- NBio- CH4 N2O e Year tons/yr MT/yr e e ROG NOx CO SO2 Bio- NBio- CH4 N20 e Percent Reduction Page 3 of 8

19 3.0 Construction Detail Construction Phase Phase Number Phase Name Phase Type Start Date End Date Num Days Week Num Days Phase Description 1 Clearing and grubbing Site Preparation 9/1/2016 9/7/ Sediment removal Grading 9/8/ /20/ Acres of Grading (Site Preparation Phase): 0 Acres of Grading (Grading Phase): 0 Acres of Paving: 0 Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0 (Architectural Coating sqft) OffRoad Equipment Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Clearing and grubbing Excavators Sediment removal Excavators Sediment removal Rubber Tired Dozers Sediment removal Graders Sediment removal Tractors/Loaders/Backhoes Clearing and grubbing Tractors/Loaders/Backhoes Clearing and grubbing Rubber Tired Dozers Sediment removal Scrapers Trips and VMT Phase Name Offroad Equipment Count Worker Trip Number Vendor Trip Number Hauling Trip Number Worker Trip Length Vendor Trip Length Hauling Trip Length Worker Vehicle Class Vendor Vehicle Class Hauling Vehicle Class Clearing and grubbing LD_Mix HDT_Mix HHDT Sediment removal , LD_Mix HDT_Mix HHDT Page 4 of 8

20 3.1 Mitigation Measures Construction Use Soil Stabilizer Water Exposed Area Reduce Vehicle Speed on Unpaved Roads Clean Paved Roads 3.2 Clearing and grubbing Unmitigated Construction On-Site ROG NOx CO SO2 Bio- NBio- CH4 N2O e Category tons/yr MT/yr Dust Off-Road e e e e e e e e e e Unmitigated Construction Off-Site ROG NOx CO SO2 Bio- NBio- CH4 N2O e Category tons/yr MT/yr Hauling e e e e e e e e e Vendor Worker e e e e e e e e e e e e e e e e e Page 5 of 8

21 Mitigated Construction On-Site ROG NOx CO SO2 Bio- NBio- CH4 N2O e Category tons/yr MT/yr Dust e e Off-Road e e e e e e e e e e e Mitigated Construction Off-Site ROG NOx CO SO2 Bio- NBio- CH4 N2O e Category tons/yr MT/yr Hauling e e e e e e e e e e e Vendor Worker e e e e e e e e e e e e e e e e e e e Sediment removal Unmitigated Construction On-Site ROG NOx CO SO2 Bio- NBio- CH4 N2O e Category tons/yr MT/yr Dust Off-Road e e Page 6 of

22 Unmitigated Construction Off-Site ROG NOx CO SO2 Bio- NBio- CH4 N2O e Category tons/yr MT/yr Hauling e e e e Vendor Worker e e e e e e e e e e e e e e Mitigated Construction On-Site ROG NOx CO SO2 Bio- NBio- CH4 N2O e Category tons/yr MT/yr Dust Off-Road e e Page 7 of 8

23 Mitigated Construction Off-Site ROG NOx CO SO2 Bio- NBio- CH4 N2O e Category tons/yr MT/yr Hauling e e e e Vendor Worker e e e e e e e e e e e e e e Page 8 of 8

24 ATTACHMENT B OCWD DEVIATION PROJECT GENERAL CONFORMITY TABLE

25 OCWD DEVIATION PROJECT GENERAL CONFORMITY ANNUAL EMISSIONS Prado Planned Deviation Project Criteria Pollutant Federal Status (Attainment, Nonattainment, Maintenance, or Unclassified) Nonattainment Rates (i.e., moderate, serious, severe, or extreme) De minimis threshold (Tons/Year) Project Emissions (Tons/Year) Ozone (O3) Nonattainment Extreme Note a N/A Oxides of Nitrogen (NOx) Note b Reactive Organic Gases (ROG) Volatile Organic Compounds (VOC) Notes b and c Notes b and c Carbon Monoxide (CO) Maintenance N/A Lead (Pb) Attainment d N/A N/A N/A Particulate Matter equal to or less than 2.5 microns in diameter () Particulate Matter equal to or less than 10 microns in diameter () Nonattainment N/A Maintenance Serious Sulfur Dioxide (SO2) Attainment N/A N/A N/A N/A: Not Applicable a. There are no thresholds for O3; the NOx and VOC (ROG) thresholds are applicable to O3 conformity. b. NOx, ROG, and VOC are not criteria pollutants and concentrations are not measured. NOx and VOC are the principal precursors of O3 and thresholds are established for their emissions. c. For purposes of this report, ROG and VOC are identical. d. Status for Riverside County Sources: U.S. Environmental Protection Agency 2015 (as of January 30). The Green Book Nonattainment Areas for Criteria Pollutants (last updated May 6). General Conformity, Regulatory Actions. Washington, D.C.: USEPA. B-1 General Conformity Table