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11-26-18_AGENDA PACKET
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11-26-18_AGENDA PACKET
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<br />6 <br /> <br />It should be noted that our analysis represents a screening‐level HRA, which is known to be more <br />conservative, and tends to err on the side of health protection.12 The purpose of a screening‐level HRA, <br />however, is to determine if a more refined HRA needs to be conducted. If the results of a screening‐ <br />level health risk are above applicable thresholds, then the Project needs to conduct a more refined HRA <br />that is more representative of site‐specific concentrations. Our screening‐level HRA demonstrates that <br />construction and operation of the Project could result in a potentially significant health risk impact, <br />when correct exposure assumptions and up‐to‐date, applicable guidance are used. As a result, refined <br />construction and operational HRAs must be prepared to examine air quality impacts generated by <br />Project construction and operation using site‐specific meteorology. An updated EIR should be prepared <br />to adequately evaluate the Project’s health risk impact and should include additional mitigation <br />measures to reduce these impacts to a less‐than‐significant level. <br />Mitigation Measures Available to Reduce Diesel Particulate Matter Emissions <br />Our HRA demonstrates that the Project’s construction‐related DPM emissions could result in significant <br />health risk impacts. Therefore, additional mitigation measures must be identified and incorporated into <br />an updated EIR to reduce these emissions to a less than significant level. Additional mitigation measures <br />can be found in CAPCOA’s Quantifying Greenhouse Gas Mitigation Measures, which attempt to reduce <br />Greenhouse Gas (GHG) levels, as well as reduce Criteria Air Pollutants such as particulate matter.13 DPM <br />is a byproduct of diesel fuel combustion, and is emitted by on‐road vehicles and by off‐road construction <br />equipment. Mitigation for DPM emissions should include consideration of the following measures in an <br />effort to reduce construction emissions. <br />Require Implementation of Diesel Control Measures <br />The Northeast Diesel Collaborative (NEDC) is a regionally coordinated initiative to reduce diesel <br />emissions, improve public health, and promote clean diesel technology. The NEDC recommends that <br />contracts for all construction projects require the following diesel control measures:14 <br /> All diesel onroad vehicles on site for more than 10 total days must have either (1) engines that <br />meet EPA 2007 onroad emissions standards or (2) emission control technology verified by EPA15 <br />or the California Air Resources Board (CARB)16 to reduce PM emissions by a minimum of 85 <br />percent. <br /> All diesel generators on site for more than 10 total days must be equipped with emission control <br />technology verified by EPA or CARB to reduce PM emissions by a minimum of 85 percent. <br /> <br />12 http://oehha.ca.gov/air/hot_spots/2015/2015GuidanceManual.pdf p. 1‐5 <br />13http://www.capcoa.org/wp‐content/uploads/2010/11/CAPCOA‐Quantification‐Report‐9‐14‐Final.pdf <br />14 Diesel Emission Controls in Construction Projects, available <br />at:http://www2.epa.gov/sites/production/files/2015‐09/documents/nedc‐model‐contract‐sepcification.pdf <br />15 For EPA’s list of verified technology: http://www3.epa.gov/otaq/diesel/verification/verif‐list.htm <br />16 For CARB’s list of verified technology: http://www.arb.ca.gov/diesel/verdev/vt/cvt.htm
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