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Letter No. 2 SENT VIA E-MAIL AND USPS: May 14, 2019 JGuevara(&s anta-ana.org Jerry C. Guevara, Assistant Planner I City of Santa Ana, Planning Division 20 Civic Center Plaza (P.O. Box 1988) Santa Ana, CA 92701 Mitigated Negative Declaration (NIND) for the Proposed 7-Eleven Convenience Store and Service Station South Coast Air Quality Management District (South Coast AQMD) staff appreciates the opportunity to comment on the above -mentioned document. The following comments are meant as guidance for the Lead Agency and should be incorporated into the Final MND. South Coast AOMD Staff's Summary of Project Description The Lead Agency proposes to demolish a 1,610-square-foot restaurant, and construct a 2,480-square-foot convenience store, an 810-square-foot gasoline service canopy with two pumps, and two 20,000-gallon underground storage tanks on 0.15 acres (Proposed Project). Construction of the Proposed Project is expected to begin in October 2019 and last seven months'. Responsible Agency, Air Permit, and Compliance with South Coast AOMD Rules Since the Proposed Project includes the operation of a gasoline service station with two pumps and installation of underground storage tanks, a permit from South Coast AQMD will be required, and South Coast AQMD should be identified as a Responsible Agency for the Proposed Project in the Final MND. Should there be any questions on permits, please contact South Coast AQMD's Engineering and Permitting staff at (909) 396-3385. For more general information on permits, please visit South Coast AQMD's webpage at: htip://www.agmd.gov/bome/pemmts. The Final MND should also include discussions to demonstrate compliance with applicable South Coast AQMD Rules, including, but not limited to, Rule 201 — Permit to Construct, Rule 203 — Permit to Operate;, Rule 461 — Gasoline Transfer and Dispensing', Rule 1170 — Methanol Compatible Fuel Storage and Transfers, and Rule 1401 — New Source Review of Toxic Air Containments6. It is important to note that assumptions used in the air quality and health risks analyses in the Final MND will be used as the basis for permit conditions and limits. If there is any information in the permitting process suggesting that the Proposed Project would result in significant adverse air quality and/or health risks impacts not discussed in the Final MND or substantially more severe air quality and/or health risks impacts than those discussed in the Final MND, the Lead Agency should commit to reevaluating the Proposed Project's air quality and health risks impacts through a CEQA process (CEQA Guidelines Section 15162). The 2015 revised Office of Environmental Health ' MND. Page. 26. 1 South Coast AQMD. Rule 201 —Permit to Construct. Accessed at: htty://www.a(jmd.eov/dots/default-source/mle-book/ree- ii/rule-201.ndf. 7 South Coast AQMD. Rule 203 —Pemut to Operate. Accessed at: htto://www.agmd.eov/docs/default-source/rule-book/ree- ii/rule-203.pdf. 4 South Coast AQMD. Rule 461 —Gasoline Transfer and Dispensing. Accessed at: httr)://vnvw.acimd.gov/docs/default- source/mle-book/mle-iv/rule-46 Lodf. 6 South Coast AQMD. Rule 1170 — Methanol Compatible Fuel Storage and Transfer. Accessed at: http://www.agmd.gov/does/default-source/mle-book/reg-xi/mle- 1170.pdf. 6 South Coast AQMD. Rule 1401 — New Source Review of Toxic Air Contaminants. Accessed at: btty://www.ag md.gov/dots/default-source/rule-book/reg-xiv/rule-1401.r)df. 75B-165