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This is 1.84 times the NSRL (OEHHA, 2017a) of 40 µg/day and represents a cancer risk <br />of 18.4 per million, which exceeds the CEQA cancer risk of 10 per million. This impact <br />should be analyzed in an environmental impact report ("EIR"), and the agency should <br />impose all feasible mitigation measures to reduce this impact. Several feasible mitigation <br />measures are discussed below and these and other measures should be analyzed in an EIR. <br />While measurements of the indoor concentrations of formaldehyde in residences built with <br />CARE Phase 2 Formaldehyde ATCM materials (Chan et. al., 2018), indicate that indoor <br />formaldehyde concentrations in buildings built with similar materials (e.g. hotels, <br />residences, offices, warehouses, schools) will pose cancer risks in excess of the CEQA <br />cancer risk of 10 per million, a determination of the cancer risk that is specific to this project <br />and the materials used to construct these buildings can and should be conducted prior to <br />completion of the environmental review. <br />The following describes a method that should be used prior to construction in the <br />environmental review under CEQA, for determining whether the indoor concentrations <br />resulting from the formaldehyde emissions of the specific building materials/furnishings <br />selected for the building exceed cancer and non -cancer guidelines. Such a design analyses <br />can be used to identify those materials/furnishings prior to the completion of the City's <br />CEQA review and project approval, that have formaldehyde emission rates that contribute <br />to indoor concentrations that exceed cancer and non -cancer guidelines, so that alternative <br />lower emitting materials/furnishings may be selected and/or higher minimum outdoor air <br />ventilation rates can be increased to achieve acceptable indoor concentrations and <br />incorporated as mitigation measures for this project. <br />Pre -Construction Building Material/Furnishing Formaldehyde Emissions Assessment <br />This formaldehyde emissions assessment should be used in the environmental review under <br />CEQA to assess the indoor formaldehyde concentrations from the proposed loading of <br />building materials/furnishings, the area -specific formaldehyde emission rate data for <br />building materials/fitrnishings, and the design minimum outdoor air ventilation rates. This <br />5 <br />