The filtration issue & Syar
on the web at: https://sodacanyonroad.org/forum.php?p=1242
George Caloyannidis | May 3, 2016

To Diane Dillon 4/29/16:

Diane

Thank you for pointing out to me that you believe that my statement during the Syar hearing on April 26 contending that air filtration as a mitigation at the Napa Pipe homes is a result of the Syar operation.

I am in the process of researching the issue and will get back to you as I certainly do not wish inaccurate statements attributed to me inserted in the record.

You mentioned that you would email me David Morrison's related analysis on but I have not received it. It would be very helpful in getting to the truth of the matter.

Diane Dillon to George 4/29/16:

Hi, George

I asked David Morrison about the home filtration mitigation that you mentioned. This is what he sent to me.

    Mitigation Measure AQ-4 in the Napa Pipe EIR requires the following:

    To lessen air quality nuisances from exposure to adjacent heavy industrial uses, the following measures shall be implemented prior to construction of new residences near barge loading/unloading areas:

    Prior to occupation of the project by sensitive receptors (e.g., residents), the applicant will develop a detailed site plan that includes features to reduce dust nuisance exposures to future potential residences located near industrial activities. These features shall include the following:

    • Wind break in the form of mature trees with sufficient density to reduce wind flow. BAAQMD recommends consideration of tiered plantings of trees such as redwood, deodar cedar, and live oak to reduce TAC and PM exposure.
    • Buffers to avoid placement of residences near or adjacent to active or planned active industrial uses. Adequate buffers shall be determined through site-specific studies that take into account designs for new residences and anticipated future industrial activities or establish a 200-foot buffer.
    • Install and maintain air filtration systems of fresh air supply either on an individual unit-by-unit basis, with individual air intake and exhaust ducts ventilating each unit separately, or through a centralized building ventilation system. The ventilation system should be certified to achieve a certain effectiveness, for example, to remove at least 80 percent of ambient PM25 concentrations from indoor areas. The air intake for these units shall be located away from areas producing the air pollution (i.e. toward the south).
    • Require re-routing of nearby heavy-duty truck routes.
    • Enforce illegal parking and/or idling of heavy-duty diesel trucks in the vicinity.

      [Emphasis added for your ease of reading]

      This mitigation measure only applies to residences built near the barging operation.


George Caloyannidis to Diane Dillon 5/2/16:
Dear Diane,

Below is the rationale regarding the need of home air filtration mitigation at the Napa Pipe development as a result of Syar expanded mining operations:

The barge facility operation which is the trigger for the Napa Pipe home air filtration mitigation requirement was purchased by Syar from the Basalt Rock Company in 1986. The pollutants created from that facility are mainly created as a result of importing sand which is an essential ingredient to the Syar products. Asphalt for example consists of 95% aggregates and only 5% of asphalt oils. Lacking sand, Syar is reduced to a mere rock producing quarry.

It follows that the transport, storage and handling of any materials essential to the Syar products and operation - the barge operation in this case - ought to have been part of the Syar expansion EIR. Transportation by barge is not exempt from scrutiny.

All mitigation measures in both kind and duration are contingent on the continued presence of the impacting activity. Once such activity ceases to exist, so does the requirement for its mitigation.

As David Morrison confirmed, the home filtration systems are required as a result of the adjacent industrial facilities and specifically at ones "near barge loading/unloading areas". Any increase in the quantity of imported sand as well as in the duration of this activity, also extends the need for the filtration systems for some 35 years. I may point out that while the filtration systems mitigate indoor activities, they do not do so for outdoor activities for which the Napa Pipe development prides itself. This impact on outdoor activities remained unmitigated. and extending it due to the Syar expansion is a defect in the scope of the Syar expansion EIR.

While one can argue that the barge activity predates and constituted the CEQA baseline for the Napa Pipe development, the expanded activity as a result of the Syar application under consideration does not. No grandfathering argument may be made for the Syar expansion. Outdoor human activity mitigation at Napa Pipe continues to lack and indoor mitigation by air filtration is being extended.

In short, since the barging operation triggers the requirement for the air filtration systems and since that same barging operation is essential in the manufacture of the Syar products, the Syar operation is directly tied to the filtration requirement. While the existing Syar/barge operation predated the Napa Pipe project and may be grandfathered, its expanded activity under consideration does not.

The further issue which I did not hear addressed, is whether homes other than at Napa Pipe which are "near" the barge operation are also negatively impacted and would require air filtration systems. To my knowledge, while "near" is a serious safety issue, it has to be quantified in the EIR.

George
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