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November 2008
Localized Significance Threshold Analysis
SUMMARY
The proposed Project is located northwest of the existing Andora Avenue and Plummer Street in the City
of Los Angeles, west of the community of Chatsworth in the San Fernando Valley. The project consists of
the development of 45 single-family detached residential units on an approximately 15 acre site. The
project is located in the South Coast Air Basin (SoCAB). The local air quality enforcement agency in the
SoCAB is the South Coast Air Quality Management District (SCAQMD). For projects located in the
SoCAB, the SCAQMD recommends the evaluation of localized air quality impacts to sensitive receptors
in the immediate vicinity of the project site as a result of construction activities. This evaluation requires
that anticipated ambient air concentrations, determined using a computer-based air quality dispersion
model, be compared to localized significance thresholds for respirable particulate matter (PM10), fine
particulate matter (PM2.5), nitrogen dioxide (NO 2), and carbon monoxide (CO).1 The significance
threshold for PM10 represents compliance with SCAQMD Rule 403 (Fugitive Dust). The threshold for
PM2.5 is intended to constrain emissions so as to aid in progress toward attainment of the ambient air
quality standards. The thresholds for NO2 and CO represent the allowable increase in concentrations
above background levels in the vicinity of the project that would not cause or contribute to an exceedance
of the relevant ambient air quality standards.
Project construction would begin in 2009 and be complete in mid 2010. This study analyzed the impacts
of the construction emissions (fugitive dust and motor vehicle and equipment exhaust) on ambient air
quality concentrations in the vicinity of the construction site. The maximum impacts for PM10 and PM 2.5
were associated with the grading phase of the project while the maximum impacts for NO2 and CO were
associated with simultaneous building construction and asphalt paving. The Localized Significance
Threshold (LST) analysis showed that the maximum PM10, PM 2.5, NO2, and CO concentrations due to
construction of the project would not exceed the thresholds of significance established by SCAQMD at
nearby sensitive receptors exterior to the project area.
1 South Coast Air Quality Management District, Final Localized Significance Threshold Methodology, (2008).
1.0 General...........................................................................................................................................................1
1.1 Project Description.........................................................................................................................1
1.2 Regional Air Quality......................................................................................................................1
1.3 Thresholds of Significance ............................................................................................................2
4.0 Conclusions.................................................................................................................................................12
Appendices
LIST OF TABLES
Table Page
1.0 GENERAL
The proposed Project is located northwest of the existing Andora Avenue and Plummer Street in the City
of Los Angeles, west of the community of Chatsworth in the San Fernando Valley. The project consists of
the development of 45 single-family detached residential units on an approximately 15 acre site. Specific
details regarding project construction are unavailable; however, it was assumed that project construction
would begin in 2009 and be complete in mid-2010. Sources utilized in the localized significance threshold
(LST) analysis include the South Coast Air Quality Management District’s (SCAQMD) California
Environmental Quality Act (CEQA) Air Quality Handbook and Final Localized Significance Threshold
Methodology, air quality data from the California Air Resources Board (CARB), and the URBEMIS2007
Environmental Management Software. Air quality modeling conducted for the analysis was conducted
using the Industrial Source Complex – Short Term (ISCST3) model, which is an SCAQMD-approved
Gaussian dispersion model.
The proposed Project is located within the South Coast Air Basin (SoCAB). An air basin is a land area
with similar meteorological and geographic conditions throughout. To the extent possible, air basins
include both the air pollutant source and immediate receptor areas. The determination of whether an air
basin’s air quality is healthful or unhealthful is evaluated by comparing contaminant levels in ambient air
samples to national and state standards. Health-based air quality standards have been established by
California and the federal government for the following seven criteria air pollutants: (1) ozone (O3),
(2) carbon dioxide (CO), (3) nitrogen dioxide (NO2), (4) sulfur dioxide (SO2), (5) respirable particulate
matter (PM10), (6) fine particulate matter (PM2.5 ), and (7) lead. These standards were established to protect
sensitive receptors from adverse health impacts due to exposure to air pollution with a margin of safety.
California standards are more stringent than the federal standards and in the case of PM10 and SO2, much
more stringent. California has also established standards for sulfates, visibility reducing particles,
hydrogen sulfide and vinyl chloride, none of which have corresponding federal standards.
The US Environmental Protection Agency (US EPA) makes designations for 7 criteria pollutants based on
the National Ambient Air Quality Standards (NAAQS). CARB makes designations for 10 criteria
pollutants for air basins in California based on the California Ambient Air Quality Standards (CAAQS).
CARB will designate an air basin or a portion of an air basin as nonattainment for a pollutant if
monitoring data shows that a violation of the CAAQS for a particular pollutant occurred at least once
during the previous three years. The status of the SoCAB with respect to attainment with the CAAQS,
which is more stringent than the NAAQS, is summarized below in Table 1, California Ambient Air
Quality Standards Designation – South Coast Air Basin (Los Angeles County).
Table 1
California Ambient Air Quality Standards Designation
South Coast Air Basin (Los Angeles County)
Source: California Air Resources Board, “Area Designations Maps/State and National,” http://www.arb.ca.gov/desig/adm/adm.htm . 2007.
1 CARB has not issued area classifications based on the new state 8-hour standard. The previous classification for the 1-hour ozone standard
was Extreme.
2 CARB has identified lead and vinyl chloride as “toxic air contaminants” with no threshold level of exposure for adverse health effects
determined.
CARB is required to periodically review ambient air quality standards and make recommendations based
on the latest health-based studies to ensure sensitive populations are adequately protected with a margin
of safety. In February 2007, CARB approved new standards for NO 2, which took effect in March 2008. The
revised 1-hour NO 2 standard was lowered from 0.25 parts per million (ppm) to 0.18 ppm and a new
annual arithmetic mean standard was set at 0.030 ppm. However, CARB has not issued new area
designations based on the new state 1-hour and annual arithmetic mean NO2 standard. Therefore, the
designation of attainment for the SoCAB is based on the previous 0.25 ppm 1-hour standard.
The SoCAB is under the jurisdiction of the SCAQMD. For projects located in the SoCAB, the SCAQMD
recommends the evaluation of localized air quality impacts to sensitive receptors in the immediate
vicinity of the project site as a result of construction activities. This evaluation requires that anticipated
ambient air concentrations, determined using a computer-based air quality dispersion model, be
compared to localized significance thresholds for PM10, PM2.5 , NO2, and CO. 2 The significance thresholds
for NO2 and CO represent the allowable increase in concentrations above background levels in the
vicinity of the project that would not cause or contribute to an exceedance of the relevant ambient air
quality standards. The threshold for PM10 represents compliance with Rule 403 (Fugitive Dust), while the
threshold for PM2.5 is intended to constrain emissions so as to aid in progress toward attainment of the
ambient air quality standards.3
To monitor the concentrations of the pollutants, the SCAQMD has divided the SoCAB into Source
Receptor Areas (SRAs) in which air quality monitoring stations are operated. The project site is located in
the West San Fernando Valley SRA (SRA 6). The peak background concentrations measured in SRA 6 for
NO2 and CO are listed in Table 2, Peak Background Concentrations for SRA 6 for the Period of 2005 to
2007. The LSTs for NO2 and CO are based on these values.
Table 2
Peak Background Concentrations for SRA 6 for the Period of 2005 to 2007
Averaging Peak
Pollutant Period Unit 2005 2006 2007 Concentration
Nitrogen Dioxide (NO 2) 1 hour ppm 0.09 0.07 0.08 0.09
Carbon Monoxide (CO) 1 hour ppm 5 5 4 5
Carbon Monoxide (CO) 8 hours ppm 3.5 3.4 2.8 3.5
Source: South Coast Air Quality Management District, “Historical Data by Year,” 2008. http://www.aqmd.gov/smog/historicaldata.htm.
Note: ppm = parts per million
As a conservative approach, the significance thresholds for NO2 and CO are based on the difference
between the ambient air quality standard and the maximum concentration that occurred during the three
previous years for which data is available (2005 to 2007) as shown in Table 2. These values represent the
allowable increase in NO2 and CO ambient concentrations above current levels that could occur in SRA 6
without causing or contributing to exceedances of the CAAQS. The threshold for PM 10 is a 24-hour
average concentration of 10.4 micrograms per cubic meter (µg/m3) based on compliance with Rule 403.
The threshold for PM2.5, also set at 10.4 µg/m3, is intended to constrain emissions so as to not cause or
contribute to an exceedance of the ambient air quality standards. The thresholds are listed in Table 3,
Localized Significance Thresholds. On-site construction emissions that result in an exceedance of these
2 South Coast Air Quality Management District, Final Localized Significance Threshold Methodology, (2008).
3 Ibid.
thresholds have the potential to generate significant adverse local impacts on ambient air quality. For
reference, the most stringent ambient air quality standards (CAAQS or NAAQS) are listed in Table 3.
Table 3
Localized Significance Thresholds
Sources: South Coast Air Quality Management District, Final Localized Significance Threshold Methodology, (2008).
Notes: ppm = parts per million; µg/m3 = micrograms per cubic meter; n/a = not applicable
1 California has not adopted a 24-hour CAAQS for PM2.5; the 24-hour PM2.5 value shown is the NAAQS. All other standards are the
California standards.
2 LSTs for NO2 and CO are based on the difference between CAAQS and the Peak Concentration.
The localized impacts of a project are evaluated based on the maximum daily emissions that could be
generated during construction. Therefore, to determine the maximum daily emissions of NO2, CO, PM10,
and PM2.5 , unmitigated construction emissions during grading and other earthwork activities were
estimated based on the URBEMIS2007 (Version 9.2.4) Environmental Management Software. Model input
parameters were based on default URBEMIS2007 values recommended by the SCAQMD and reasonably
conservative assumptions. The key assumptions used to estimate the construction emissions for the
project are as follows:
Specific details regarding project construction are unavailable; however, it was assumed that project
construction would begin in 2009. The grading phase was assumed to last for approximately 2 months.
The SCAQMD has developed a default construction equipment mix based on surveys of construction
sites throughout the SoCAB. The equipment mix represents the number and types of equipment that
would be in operation simultaneously on any given day that would generally result in the highest
emissions. The number and types of on-site construction equipment used in this analysis was based on
SCAQMD default equipment mix. In addition, on-site fugitive dust generation is based on the SCAQMD
default value. The following bullet-list provides the key factors used in this analysis.
On-site fugitive dust: 20 pounds per acre disturbed per day (default value).
In addition to the above, the URBEMIS2007 analysis also includes dust control measures required by
SCAQMD Rule 403. Compliance with Rule 403 is mandatory for all construction projects. In the
URBEMIS2007 model, the emission calculations take into account compliance with Rule 403 by
incorporating the watering of exposed surfaces and unpaved roads three times daily, which is estimated
to reduce fugitive dust emissions (both PM10 and PM2.5 ) by a maximum of 61 percent per guidance from
the SCAQMD. The emission calculations also take into account the use of soil stabilization measures
during equipment loading and unloading, which is estimated to reduce fugitive dust emissions (both
PM10 and PM 2.5) by a maximum of 69 percent per guidance from the SCAQMD. Rule 403 contains other
best available control measures to minimize fugitive dust emissions; however, they are not accounted for
in the URBEMIS2007 model.
Building construction was assumed to follow grading and end in mid-2010. The number and types of on-
site construction equipment used in this analysis was based on SCAQMD default equipment mix. The
following bullet-list provides the key factors used in this analysis.
Assumed building construction schedule: March 2009 through June 2010; and
Asphalt paving was assumed to occur during the initial month of building construction. The number and
types of on-site construction equipment used in this analysis was based on SCAQMD default equipment
mix. The amount of paving was also based on a default value. The following bullet-list provides the key
factors used in this analysis.
Paving equipment: 4 Cement and Mortar Mixers, 1 Paver, 2 Paving Equipment, 1 Roller, and 1
Tractor/Loader/Backhoe;
Area to be paved: 3.75 acres (25 percent of the total project size);
Architectural coating was assumed to begin 6 months after building construction and last until the end of
construction, in mid-2010. The emissions associated with architectural coating are based on SCAQMD
rules that govern coating applications and default surface area calculations for single-family structures.
URBEMIS2007 does not require any user inputs, except for the schedule, to determine the emissions
associated with this phase.
Based on the analysis, the results indicate that estimated maximum daily on-site emissions of PM10 and
PM2.5 are expected to occur in 2009 during the grading phase. The estimated maximum daily on-site
emissions of NOX and CO are expected to occur in 2009 during the first month of building construction
when asphalt paving is assumed to occur. Only emissions from on-site equipment and activity are
applicable to the LST analysis, as per the SCAQMD Final Localized Significance Threshold Methodology. The
estimated maximum daily on-site emissions for PM10, PM2.5 , NOX, and CO are presented in Table 4,
Estimated Maximum Daily On-Site Construction Emissions.
Table 4
Estimated Maximum Daily On-Site Construction Emissions
Source: Construction emissions were estimated based on URBEMIS2007 (Version 9.2.4). Emissions reflect the worst-case scenario (i.e., highest
daily emissions associated with the project). The worst-case daily emissions may occur in different project construction phases.
Per the recommendation of the SCAQMD, ambient PM10, PM2.5 , NO2, and CO concentrations due to the
construction of the project were analyzed using methods described in its Final Localized Significance
Threshold Methodology. The SCAQMD-approved dispersion model, Industrial Source Complex – Short
Term (ISCST3),4 was used to model the air quality impacts of PM10, PM 2.5 , NOX, and CO emissions.
ISCST3 can estimate the air quality impacts of single or multiple point, area, or volume sources using
historical meteorological conditions. Volume sources were used to represent the emissions from trucks
and heavy-duty construction equipment. Area sources were used to model fugitive dust emissions of
PM10 and PM2.5 .
For the purpose of the dispersion modeling, the maximum daily emissions that could occur due to
construction activities from any construction phase were selected for the LST analysis, as listed in
Table 4. The average workday was assumed to be 8 hours long. Therefore, the maximum daily emissions
from Table 4 were divided by 8 to obtain maximum emission rates in units of pounds per hour.
3.1.1 Sources
Volume sources were used to represent emissions from construction equipment. Volume sources were
placed in areas where construction activity is anticipated to occur. The volume sources covered
approximately 3.75-acres representing the maximum daily disturbed area on any given day. An area
source was co-located with the volume sources to model fugitive dust emissions of PM10 and PM 2.5. Two
groups of sources were modeled to determine the maximum impacts at nearby sensitive receptors. One
source group was located in the eastern portion of the project site near to existing receptors along Andora
Avenue and Trigger Street the east. A second source group was located at the southeastern portion of the
project site to model impacts at the existing receptors along Plummer Street to the east and southeast.
Emissions from heavy-duty vehicles and construction equipment, modeled as volume sources, were
given a 5-meter release height, 4.65-meter initial horizontal dimension, and 1.4-meter initial vertical
direction. Fugitive dust emissions from grading activities, modeled as area sources, were given a ground-
level release height and a 1-meter initial vertical dimension. There parameters are standard values for use
in volume and area sources.
3.1.2 Receptors
Discrete Cartesian receptors were used to determine air quality impacts in the vicinity of the project site.
Near-field receptors were placed at 25-meter intervals outside the boundary of the project site to a
minimum distance of 250 meters from the project site. Mid-field receptors were spaced 50 meters apart
out to 500 meters. Extended-field receptors were spaced 100 meters apart out to 1.0 kilometers and 250
meters apart out to 2 .0 kilometers in order to cover other potential sensitive receptors. Flagpole receptors
were given a height of 2 meters, as recommended in the Final Localized Significance Threshold Methodology. 5
Reseda was identified as the nearest meteorological monitoring station for the project. Monitoring data
were obtained from SCAQMD website.6 For the vicinity of the site, the “Reseda 1981” meteorological
data file was selected. In this data set, the surface wind speeds and directions were collected at the
SCAQMD Reseda Monitoring Station (Station ID 51107), while the upper air sounding data used to
estimate hourly mixing heights were gathered from the Ontario International Airport (Station 99999). The
surface wind directions are presented graphically in a polar diagram generated by the Wind Rose
software. This diagram is shown in Figure 1, Wind Rose for the Pomona Monitoring Station.
The SCAQMD has published guidelines for dispersion modeling in the SoCAB. The following SCAQMD
model options were used in this analysis and are consistent with SCAQMD modeling policy:
No stack-tip downwash (the LST analysis does not incorporate point sources);
Buoyancy-induced dispersion;
5 South Coast Air Quality Management District, Final Localized Significance Threshold Methodology, (2008) 2-3.
6 South Coast Air Quality Management District, “Meteorological Data for Dispersion Modeling,”
http://www.aqmd.gov/smog/metdata/MetDataTable1.html. 2005.
NORTH
15%
12%
9%
6%
3%
WEST EAST
WIND SPEED
(Knots)
>= 22
17 - 21
11 - 17
SOUTH
7 - 11
4-7
1-4
Calms: 12.84%
SOURCE: WRPLOT View - Lakes Environmental Software, Impact Sciences, Inc. - January 2009
FIGURE 1
Wind Rose for the Pomona Monitoring Station
947-002•01/09
Localized Significance Threshold Analysis
Terrain heights for all receptors were derived from digital terrain elevations developed by the
US Geological Survey by using its Digital Elevation Model (DEM). The DEM data provides terrain
elevations with 1-meter vertical resolution and 10-meter horizontal resolution based on a Universal
Transverse Mercator (UTM) coordinate system. The UTM coordinates are referenced to either the World
Geodetic System of 1984 (WGS 84) or the North American Datum of 1983 (NAD 83). For each receptor
location, the terrain elevation was set to the elevation for the closest DEM grid point.
The Final Localized Significance Threshold Methodology discusses an adjustment of the NO2 impacts due to
the fact that most of NOX in the combustion exhaust will occur in the form of nitric oxide (NO), rather
than as NO2. Nitric oxide is converted in the atmosphere through chemical reactions to NO2. The LST
methodology discusses this adjustment as follows:
NOX emissions are simulated in the air quality dispersion model and the NO2 conversion rate is
treated by a NO2-to-NO X ratio, which is a function of downwind distance. Initially, it is assumed
that only 5 percent of the emitted NO X is NO 2. At 5,000 meters downwind, 100 percent
conversion of NO-to-NO 2 is assumed.7
Table 5, NO2-toNO X Ratio as a Function of Downwind Distance, from the Final Localized Significance
Threshold Methodology, demonstrates how the NO2-to-NOX ratio varies with distance from the source. To
determine the NO2-to-NOX ratios for this analysis, the maximum impacted residential and school
receptors were determined. The distance from the center of the source area to the particular receptor was
determined and each corresponding NO2-to-NOX ratio from Table 5 was applied to the modeled
concentrations. Ratios at distances between the values in Table 5 were interpolated.
7 South Coast Air Quality Management District, Final Localized Significance Threshold Methodology, (2003) 2-8. The
NO2 conversion rates are adapted by the SCAQMD from Arellano, J.V., A.M. Talmon, and P.J.H. Builtjes, “A
Chemically Reactive Plume Model for the NO-NO 2-O3 System,” Atmospheric Environment 24A, 2237-2246.
Table 5
NO 2-to-NO X Ratio as a Function of Downwind Distance
Downwind Distance
(meters) NO2-to-NO X Ratio
20 0.053
50 0.059
70 0.064
100 0.074
200 0.114
500 0.258
1,000 0.467
2,000 0.750
3,000 0.900
4,000 0.978
5,000 1.000
Source: South Coast Air Quality Management District, Final Localized Significance
Threshold Methodology, (2008) Table 2 -4, p. 2-9.
The results of the dispersion modeling are present in Table 6 , Modeling Results – Maximum Impacts at
Sensitive Receptors. Table 6 shows the maximum PM 10, PM2.5 , NO2, and CO concentrations at sensitive
receptors due to emissions associated with the project. When the results of the modeling analysis are
compared to the thresholds, the maximum PM 10, PM2.5 , NO2, and CO concentrations are not expected to
exceed the thresholds of significance at any sensitive receptor. It should be noted that the NO 2
concentrations reflect the use of the SCAQMD guidance on NOX-to-NO 2 conversion, as outlined in the
previous section.
Table 6
Modeling Results – Maximum Impacts at Sensitive Receptors
4.0 CONCLUSIONS
The results of the modeling analysis indicate that the maximum PM10, PM 2.5 , NO2, and CO concentrations
are not expected to exceed the thresholds of significance at any sensitive receptor. The project is still
required to implement fugitive dust control mitigation measures, as recommended by SCAQMD Rule 403
(Fugitive Dust). The full effect of these mitigation measures is not taken into account in the dispersion
modeling, which would tend to reduce the PM10 and PM2.5 concentrations listed in Table 6.
Table LST-1
LST Emission Rates
Notes:
* Maximum CO and NOX emissions are associated with building construction and paving. Maximum PM10 and PM2.5 emissions are associated with grading and excavation.
** For modeling purposes, two source groups were analyzed. One was located at the northern end of the project site and a second was located at the southern end of the project site to determine impacts at the downwind receptors.
Table LST-2
PM10 Dry Depletion Parameters
Table LST-3
Maximum Modeled Impacts at Sensitive Receptors and NO2 Conversion
Project Model Receptor Modeled Impacts at Sensitive Receptors (All Source Groups)
Component Source Type CO NOX PM10 PM2.5
Group 1-Hr 8-Hr 1-Hr 24-Hr 24-Hr
3 3 3 3 3
µg/m µg/m µg/m µg/m µg/m
Southeast VOL37-72, Area2 Residential 180.22 0.16 23.02 0.02 299.11 6.00 1.70