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<br />SENT VIA E-MAIL AND USPS: May 14, 2019 <br />JGuevara@santa-ana.org <br />Jerry C. Guevara, Assistant Planner I <br />City of Santa Ana, Planning Division <br />20 Civic Center Plaza (P.O. Box 1988) <br />Santa Ana, CA 92701 <br /> <br />Mitigated Negative Declaration (MND) for the Proposed <br />7-Eleven Convenience Store and Service Station <br /> <br />South Coast Air Quality Management District (South Coast AQMD) staff appreciates the opportunity to <br />comment on the above-mentioned document. The following comments are meant as guidance for the <br />Lead Agency and should be incorporated into the Final MND. <br /> <br />South Coast AQMD Staff’s Summary of Project Description <br />The Lead Agency proposes to demolish a 1,610-square-foot restaurant, and construct a 2,480-square-foot <br />convenience store, an 810-square-foot gasoline service canopy with two pumps, and two 20,000-gallon <br />underground storage tanks on 0.15 acres (Proposed Project). Construction of the Proposed Project is <br />expected to begin in October 2019 and last seven months1. <br /> <br />Responsible Agency, Air Permit, and Compliance with South Coast AQMD Rules <br />Since the Proposed Project includes the operation of a gasoline service station with two pumps and <br />installation of underground storage tanks, a permit from South Coast AQMD will be required, and South <br />Coast AQMD should be identified as a Responsible Agency for the Proposed Project in the Final MND. <br />Should there be any questions on permits, please contact South Coast AQMD’s Engineering and <br />Permitting staff at (909) 396-3385. For more general information on permits, please visit South Coast <br />AQMD’s webpage at: http://www.aqmd.gov/home/permits. The Final MND should also include <br />discussions to demonstrate compliance with applicable South Coast AQMD Rules, including, but not <br />limited to, Rule 201 – Permit to Construct2, Rule 203 – Permit to Operate3, Rule 461 – Gasoline Transfer <br />and Dispensing4, Rule 1170 – Methanol Compatible Fuel Storage and Transfer5, and Rule 1401 – New <br />Source Review of Toxic Air Containments6. It is important to note that assumptions used in the air quality <br />and health risks analyses in the Final MND will be used as the basis for permit conditions and limits. If <br />there is any information in the permitting process suggesting that the Proposed Project would result in <br />significant adverse air quality and/or health risks impacts not discussed in the Final MND or substantially <br />more severe air quality and/or health risks impacts than those discussed in the Final MND, the Lead <br />Agency should commit to reevaluating the Proposed Project’s air quality and health risks impacts through <br />a CEQA process (CEQA Guidelines Section 15162). The 2015 revised Office of Environmental Health <br /> <br />1 MND. Page. 26. <br />2 South Coast AQMD. Rule 201 – Permit to Construct. Accessed at: http://www.aqmd.gov/docs/default-source/rule-book/reg- <br />ii/rule-201.pdf. <br />3 South Coast AQMD. Rule 203 – Permit to Operate. Accessed at: http://www.aqmd.gov/docs/default-source/rule-book/reg- <br />ii/rule-203.pdf. <br />4 South Coast AQMD. Rule 461 – Gasoline Transfer and Dispensing. Accessed at: http://www.aqmd.gov/docs/default- <br />source/rule-book/rule-iv/rule-461.pdf. <br />5 South Coast AQMD. Rule 1170 – Methanol Compatible Fuel Storage and Transfer. Accessed at: <br />http://www.aqmd.gov/docs/default-source/rule-book/reg-xi/rule-1170.pdf. <br />6 South Coast AQMD. Rule 1401 – New Source Review of Toxic Air Contaminants. Accessed at: <br />http://www.aqmd.gov/docs/default-source/rule-book/reg-xiv/rule-1401.pdf. <br />1-93