APPENDIX I RECORD OF NON APPLICABILITY

APPENDIX I RECORD OF NON APPLICABILITY

RECORD OF NON-APPLICABILITY FOR CLEAN AIR ACT CONFORMITY (RONA) AND AIR QUALITY DATA SIO/UCSD MARFAC BERTHING WHARF AND PIER REPLACEMENT UCSD Project Number: 963990/4425 University of California San Diego Physical and Community Planning 9500 Gilman Drive Pepper Canyon Hall, Suite 464 La Jolla, California 92093-0074 U.S. Department of the Navy Naval Base Point Loma 140 Sylvester Road San Diego, California 92106-3521 February 2013

The University of California San Diego Scripps Institution of Oceanography s Nimitz Marine Facility (MarFac) is the support and management center for its fleet of research vessels and platform. The original pier and wharf serving MarFac were constructed in 1965. In 1973, the wharf was expanded and the pier was replaced with a concrete-pile-supported pier. Since then, few improvements have been made. In 2009, an inspection confirmed widespread degradation of the structures. In addition to the structural problems, the existing utility systems, including the telecommunications lines, potable water, sewage, and stormwater management systems, do not meet current operational requirements. The proposed project (action) would replace the existing SIO/UCSD MarFac pier and wharf with a concrete-pilesupported pier and wharf of the same size and in the same location as the existing structures. Construction is anticipated to begin in spring 2014 and would take approximately 20 months to complete. There would be no changes in operations as a result of the proposed action. The proposed action falls under the Record of Non-Applicability (RONA) category and is documented with this RONA. In 1993, the U.S. Environmental Protection Agency (USEPA) published Determining Conformity of General Federal Actions to State or Federal Implementation Plans; Final Rule, (40 CFR Parts 6, 51, and 93). In 2007, the U.S. Navy published Clean Air Act Conformity Guidance in Appendix F, OPNAVINST 5090.1C (October 2007). These publications provide implementing guidance to document Clean Air Act (CAA) Conformity Determination requirements. Under 40 Code of Federal Regulations (CFR) Part 93 and the provisions of Part 51, Subchapter C, Chapter I, Title 40, Appendix W of the CFR, of the CAA as amended, federal agencies are required to demonstrate that federal actions conform with the applicable SIP. CAA general conformity requirements apply to projects in areas either not meeting federal national ambient air quality standards or that are subject to a maintenance plan. An analysis is required for each criteria pollutant for which an area is considered as being in federal non-attainment or maintenance. 40 CFR Part 93.153(b)(2) defines de minimis levels, that is, the minimum thresholds for which a conformity determination must be performed for criteria pollutants, based on the federal attainment status of the pollutant in the air basin. If project emissions are below the de minimis level and less than 10 percent of the emissions inventory for the pollutants for which the area is in non-attainment, then further general conformity analysis is not required. If project emissions are above the de minimis level, then

a conformity determination for the project must be made. Table 1 includes the federal de minimis levels for the criteria pollutants that may be generated by the proposed action. A federal conformity determination is only required for the pollutants for which a basin in nonattainment or maintenance. The San Diego Air Basin (SDAB) is in nonattainment for ozone and a maintenance area for carbon monoxide. VOCs and NOx are ozone precursors. A project that would exceed the de minimis thresholds for NOx or VOCs would be considered to have a significant impact related to ozone. Table 1 Federal De Minimis Levels Pollutant Volatile Organic Compounds (VOCs) Nitrogen Oxides (NO X ) Carbon Monoxide (CO) Source: 40 CFR Part 93.153(b)(2) Threshold 100 tons/year 100 tons/year 100 tons/year

PROPOSED ACTION Action Proponent: U.S. Navy Location: Point Loma, San Diego, California Proposed Action Name: SIO/UCSD MARFAC Berthing Wharf and Pier Replacement Proposed Action and Emissions Summary: The proposed MARFAC Berthing Wharf and Pier Replacement project consists of removal, reconstruction, upgrading, and modernization of the existing Scripps Institute of Oceanography/ University of California, San Diego pier and berthing wharf The existing pier and wharf consists of a concrete deck supported by precast concrete piles with fender and mooring systems provided along the waterside edge. The new pier and wharf would consist of a reinforced concrete deck supported by vertical pre-stressed concrete piles. The new wharf and pier would have the same footprint as the existing facilities. Following construction, the new wharf and pier would have the same footprint and function as the existing pier and wharf. The Proposed Action would not include any operational components that would generate additional criteria air pollutant emissions. Construction of the berthing wharf and pier is estimated to take approximately 20 months beginning in April 2014 and ending in December 2015. Construction would consist of eight phases: 1) Demolition; 2) Rip Rap Slope Regrading; 3) Pile Installation (Wharf, Pier, and Indicator Piles); 4) Construct Wharf and Pier Deck; 5) Install Wharf and Pier Features; 6) Utilities Installation; 7) Site Civil Work; and 8) Fender Pile Installation. Demolition, pile installation, and wharf and pier deck construction would occur sequentially, although installation of wharf and pier features, utilities installation, and site civil work may overlap with other phases. Air Emissions Summary: The Proposed Action would result in air emissions from construction activities. Because no changes in operations are proposed as part of the Proposed Action, operational emissions would not differ from the baseline. The construction required for the Proposed Action was assumed to commence in FY 2014 and be completed by FY 2016. Based on the air quality analysis for the proposed action, the maximum estimated emissions would be below conformity de minimis levels (Table 2).

Table 2 Estimated Construction Maximum Air Pollutant Emissions Maximum Annual Emissions (tons/year) Phase VOC NO X CO SOx PM10 PM2.5 2014 1 18 4 <1 2 <1 Federal Threshold 100 100 100 100 100 100 Impact? No No No No No No 2015 <1 7 3 0 1 <1 Federal Threshold 100 100 100 100 100 100 Impact? No No No No No No Date RONA prepared: 4 February 2013

EMISSIONS EVALUATION AND CONCLUSION The Navy concludes that de minimis thresholds for applicable criteria pollutants would not be exceeded as a result of implementation of the Proposed Action. The emissions data supporting that conclusion is shown in Table 2 above, which is a summary of the calculations, methodology, data, and references included in the attachment to the RONA. Therefore, the Navy concludes that further formal Conformity Determination procedures are not required, resulting in this Record of Non-Applicability. RONA APPROVAL (NAVY) Date: Signature: RONA APPROVAL (UCSD) Date: Signature:

Air Quality Data

Pounds Per Day Tons Per Year Pounds per Day Tugboat Emissions Equipment Type Hours of Operation Per Day Horsepower Number of Days in Phase Emissions Factors - Pounds per Horse Power per Hour VOC CO Nox SO2 PM10 PM2.5 CO2 0.001 0.004 0.02 0 0.001 0.001 0.99 Phase 1 - Demolition 8 800 90 6 26 128 0 6 6 -- Phase 2: Rip Rap 8 800 20 6 26 128 0 6 6 -- Phase 3: Pile Installation 8 800 30 6 26 128 0 6 6 -- Phase 4 - Construct Wharf and Pier Deck 8 800 115 6 26 128 0 6 6 -- Phase 8: Fender Pile Installation 8 800 20 6 26 128 0 6 6 -- Phase 1 - Demolition 8 800 90 0 1 6 0 0 0 285 Phase 2: Rip Rap 8 800 20 0 0 1 0 0 0 63 Phase 3: Pile Installation 8 800 30 0 0 2 0 0 0 95 Phase 4 - Construct Wharf and Pier Deck 8 800 115 0 1 7 0 0 0 364 Phase 8: Fender Pile Installation 8 800 20 0 0 1 0 0 0 63 Source: Ben C. Gerwick, Inc., 2012. Based on Starcrest 2006. POLA OGV Assist Tug Power Characteristics Mitigated Tugboat Emissions (Mitigation Measure Air-1) Equipment Type Hours of Operation Per Day Horsepower Number of Days in Phase Emissions Factors - Pounds per Horse Power per Hour VOC CO Nox SO2 PM10 PM2.5 CO2 0.001 0.004 0.02 0 0.001 0.001 0.99 Phase 2: Rip Rap 4 800 20 -- -- 64 -- -- -- -- Source: Ben C. Gerwick, Inc., 2012. Based on Starcrest 2006. POLA OGV Assist Tug Power Characteristics

CalEEMod Version: CalEEMod.2011.1.1 Mitigated Worst Case Cumulative Scenario San Diego County APCD Air District, Summer 1.0 Project Characteristics 1.1 Land Usage Land Uses Size Metric Other Non-Asphalt Surfaces 0.75 Acre 1.2 Other Project Characteristics Urbanization Urban Wind Speed (m/s) 2.6 Utility Company San Diego Gas & Electric Climate Zone 13 Precipitation Freq (Days) 40 1.3 User Entered Comments Project Characteristics - Land Use - Construction Phase - Based on schedule provided by client Off-road Equipment - Based on equipment list provided by contractor Off-road Equipment - Based on list provided by contractor Trips and VMT - Based on import/export information from contractor Grading - Based on site plan Date: 10/25/2012 1 of 10

Construction Off-road Equipment Mitigation - 2.0 Emissions Summary 2.1 Overall Construction (Maximum Daily Emission) Unmitigated Construction 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 Year lb/day lb/day 2014 85.80 Total NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA Mitigated Construction 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 Year lb/day lb/day 2014 81.73 Total NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA 2 of 10

3.1 Mitigation Measures Construction Use Cleaner Engines for Construction Equipment Use DPF for Construction Equipment Use Oxidation Catalyst for Construction Equipment 3.2 Phase 2 - Rip Rap Slope Regrading - 2014 Unmitigated Construction On-Site 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 Category lb/day lb/day Off-Road 21.56 Total 21.56 Unmitigated Construction Off-Site 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 Category lb/day lb/day Hauling 64.19 Vendor 0.00 Worker 0.06 Total 64.25 4 of 10

3.2 Phase 2 - Rip Rap Slope Regrading - 2014 Mitigated Construction On-Site 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 Category lb/day lb/day Off-Road 17.49 Total 17.49 Mitigated Construction Off-Site 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 Category lb/day lb/day Hauling 64.19 Vendor 0.00 Worker 0.06 Total 64.25 4.0 Mobile Detail 4.1 Mitigation Measures Mobile 5 of 10