01-14-19_AGENDA PACKET - Laserfiche WebLink

Home Browse Search

Response to Comment City of Santa Ana 8 Magnolia at the Park Multi-Family Residential Project December 2018 and described in Master Response 2: Draft EIR Recirculation of the Final EIR (page 2-4), have been triggered, and recirculation of the Draft EIR is not required. Comment 19: This comment provides background information related to indoor air quality that is general in nature. The comment refers to the California New Home Study completed in 2009 by Mr. Offermann (the commenter) in which many of the homes exceeded No Significant Risk Levels of formaldehyde. The comment asserts that based on findings from the previous study, the proposed project would expose future residents to a significant airborne cancer risk of 180 per million, which is above the threshold of 10 per million. The comment further asserts that the impact should be evaluated, and mitigation measures should be imposed. Response 19: The circumstances of the 2009 study referenced by this comment and the residences evaluated in the 2009 study are different than and not applicable to the proposed project. The residences surveyed were built between 2002 and 2004 and 64 percent of the ventilation systems in the homes did not meet 2008 Building Efficiency Standards. The proposed project would be developed pursuant to the most recent building standards at the time of development (the 2019 standards take effect on January 1, 2020, which would replace the 2016 standards) and would exceed the function of the older systems evaluated in the study. The study found that formaldehyde concentrations were significantly higher in residences with non-mechanically ventilated and ducted outdoor air units. However, the project would be fully ventilated with air filtration systems with efficiencies equal to or exceeding a Minimum Efficiency Reporting Value (MERV) 16 as defined by the American Society of Heating, Refrigerating and Air Conditioning Engineers (ASHRAE) Standard 52.2 within all buildings (included as Project Description Feature [PDF] 3). Thus, the lack of filtered ventilation that occurred during the study referenced by this comment, would not occur by the proposed project. In addition, page 7 of the study states that “the research team was not able to determine the extent to which formaldehyde-based resins were used in the composite wood identified in the homes”. Therefore, the assertion in this comment that the levels of formaldehyde identified in the 2009 study were from wood composite products that would be used in the proposed project is unfounded. It should be noted that the recommendations of the 2009 study are consistent with the project. The study recommends that mechanical air ventilation systems that provide a dependable and continuous flow of air should be included in residences, which would occur with the proposed project. The recommendations of the 2009 study also include regulating emissions of formaldehyde from wood products, which has been done by the U.S EPA and became effective in 2018. As detailed in Response 4, the proposed project would utilize products that have to be manufactured or imported pursuant to TSCA Title VI and California Proposition 65 safe harbor standards, which would not exceed the SCAQMD significance threshold of 10 per million and the project would result in less than significant impacts related to formaldehyde and no mitigation is required. Comment 20: This comment states that formaldehyde can be an eye and respiratory irritant and that many of the residences in the 2009 study exceeded non-cancer reference levels. The comment also states that the primary source of formaldehyde indoors is composite wood products manufactured with urea-formaldehyde resins, and that the CARB standards adopted in 2009 have reduced emissions from composite wood products sold in California, but they do not preclude that homes built with composite wood products meeting the CARB ATCM will have indoor formaldehyde concentrations that are below cancer and non-cancer exposure guidelines. Response 20: Refer to Responses 4 and 19. The U.S. EPA requires all products manufactured or imported into the United States to meet TSCA Title VI and California Proposition 65 safe harbor standards that include regulations related to composite wood products manufactured with urea-formaldehyde resins, would preclude the project from resulting in indoor formaldehyde emissions that would exceed the SCAQMD significance threshold of 10 per million. Thus, impacts would be less than significant. 2-304