State Air Board Evaluates Mendocino APCD, Makes Recommendations to Improve Air Quality
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SACRAMENTO – The California Air Resources Board (ARB) has released an evaluation report of the Mendocino Air Pollution Control District (APCD), a rural area situated along the northern California coast. The ARB conducted the review last fall after a request by the Mendocino district. The district's last program review occurred in 1988.
Board Executive Officer Mike Kenny said, "Air quality must be protected throughout the state. The Mendocino APCD is a good example of a small district that is trying to protect air quality with limited resources. Rural districts like Mendocino must deliver the same protection to its residents as large districts, sometimes without the financial support afforded those urban operations," he added.
ARB data shows that most of the district's ozone-forming emissions, including over 90 percent of its nitrogen oxides and one half of its hydrocarbons, are produced by motor vehicles. With the introduction of lower emitting vehicles and cleaner burning fuels, however, the percentage of industrial pollution is expected to rise.
The Mendocino district has about 135 industrial pollution sources that include five major facilities. Many of the industrial sites inspected by ARB staff were relatively large facilities involved in wood product manufacturing and related operations. The remaining facilities were smaller sources, primarily auto body repair shops, dry cleaners and gasoline service stations. State inspectors found the defect rate of service station Phase 2 vapor recovery systems comparable to those in other districts at 10 percent, with emission-related defects at about 1 percent.
The ARB suggests quarterly inspections of all large industrial sites and yearly reviews of smaller facilities. ARB inspectors found that some small sources, which are inspected less frequently, had emission-related violations of 57 percent. The ARB recommends the district reduce its noncompliance rate for all sources to 5 percent or less. Presently, only sources which emit over 25 tons of pollution per year are inspected annually.
Another area that concerned the ARB is the relatively small fines assessed to facilities once a violation has been settled. In addition, the ARB believes the district's average citation fee of $192 should be higher to encourage violators to repair problems, rather than repeat their offenses. The Board also recommends that violations which can increase emissions be settled for at least $500.
The ARB also found that while the district tracks and records citizen complaints and has good written enforcement policies for handling complaints, about 25 percent of all complaints were not investigated by district staff. The ARB recommends that all complaints be investigated, with 90 percent investigated within 24 hours.
ARB inspectors approved of the district's variance procedures, but suggested the district notify small businesses that assistance in filing for variances is available. ARB staff also recommended excessive emission calculations be included in applications, written staff reports and other paperwork. Staff also suggested several ways to improve the district's agricultural burning program including developing formal agreements with fire stations that issue permits to alert the public of impending burns.
Inspectors found administrative procedures associated with issuing permits to be in good order, however, they suggest some changes to its engineering policies to include better permit processing, permit evaluation and the use of Best Available Control Technology (BACT) determinations. ARB also recommends the district hire an engineer to oversee these functions. Currently there are none on staff.
Among the many positive findings by the ARB team were increases in resources of more than 100 percent since the 1988 program review and a low defect rate among the district's Phase 2 vapor recovery equipment at gasoline service stations. High noncompliance rates among this equipment, particularly bootless nozzles, have been found at other northern California districts reviewed by the ARB.