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6 project's health risk impact, which supports the necessity of a construction and operational HRA in addition to the LST analysis.7 Therefore, in order to determine the proposed Project’s health-related impact, the Addendum should have conducted an assessment that compares the Project’s construction and operational health risk to the SCAQMD’s specific numerical threshold of 10 in one million. Third, as previously discussed, the Addendum’s analysis relies upon emission estimates from a flawed CalEEMod model to estimate the excess cancer risk posed to nearby residents as a result of emissions generated during construction-related activity. Because the emissions estimates from the Project’s CalEEMod model are underestimated, the Addendum’s analysis comparing emissions from the model to thresholds are thus incorrect. As a result, we find the Addendum’s health-related air quality analysis and subsequent significance determination to be incorrect. Finally, the omission of a quantified HRA is inconsistent with the most recent guidance published by the Office of Environmental Health Hazard Assessment (OEHHA), the organization responsible for providing guidance on conducting HRAs in California. In February of 2015, OEHHA released its most recent Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments, which was formally adopted in March of 2015.8 This guidance document describes the types of projects that warrant the preparation of an HRA. Construction of the Project will produce emissions of DPM, a human carcinogen, through the exhaust stacks of construction equipment over a construction period of approximately two-years (p. 2-10). The OEHHA document recommends that all short-term projects lasting at least two months be evaluated for cancer risks to nearby sensitive receptors.9 Therefore, per OEHHA guidelines, health risk impacts from Project construction should have been evaluated by the Addendum. Furthermore, once construction of the Project is complete, the Project will operate for a long period of time. As previously stated, Project operation will generate approximately 1,420 vehicle trips, which will generate additional exhaust emissions and continue to expose nearby sensitive receptors to DPM emissions (Appendix E-1-, p. 19, Table 5-1). The OEHHA document recommends that exposure from projects lasting more than 6 months be evaluated for the duration of the project, and recommends that an exposure duration of 30 years be used to estimate individual cancer risk for the maximally exposed individual resident (MEIR).10 Even though we were not provided with the expected lifetime of the Project, we can reasonably assume that the Project will operate for at least 30 years, if not more. Therefore, health risks from Project operation should have also been evaluated by the Addendum, as a 30-year exposure duration vastly exceeds the 2-month and 6-month requirements set forth by OEHHA. These recommendations reflect the most recent health risk policy, and as such, an 7 “South Coast AQMD Air Quality Significance Thresholds.” SCAQMD, Revised April 2019, available at: http://www.aqmd.gov/docs/default-source/ceqa/handbook/scaqmd-air-quality-significance- thresholds.pdf?sfvrsn=2 8 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: http://oehha.ca.gov/air/hot_spots/hotspots2015.html 9 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: http://oehha.ca.gov/air/hot_spots/2015/2015GuidanceManual.pdf, p. 8-18 10 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: http://oehha.ca.gov/air/hot_spots/2015/2015GuidanceManual.pdf, p. 8-6, 8-15