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10 3rd Trimester Duration 0.25 2.7E-07 3rd Trimester Exposure 2.7E-06 Construction 1.75 0.1954 1090 5.6E-06 10 5.6E-05 Operation 0.25 0.1606 1090 6.6E-07 10 6.6E-06 Infant Exposure Duration 2.00 6.3E-06 Infant Exposure 6.3E-05 Operation 14.00 0.1606 572 1.9E-05 3 5.8E-05 Child Exposure Duration 14.00 1.9E-05 Child Exposure 5.8E-05 Operation 14.00 0.1606 261 6.5E-06 1 6.5E-06 Adult Exposure Duration 14.00 6.5E-06 Adult Exposure 6.5E-06 Lifetime Exposure Duration 30.00 3.2E-05 Lifetime Exposure 1.3E-04 * We, along with CARB and SCAQMD, recommend using the more updated and health protective 2015 OEHHA guidance, which includes ASFs. As indicated in the tables above, the excess cancer risk posed to adults, children, infants, and during the third trimester of pregnancy at the closest receptor, located approximately 100 meters away, over the course of Project construction and operation, utilizing age sensitivity factors, are approximately 6.5, 58, 63, and 2.7 in one million, respectively. The excess cancer risk over the course of a residential lifetime (30 years) at the closest receptor, with age sensitivity factors, is approximately 130 in one million. The adult, child, infant, and lifetime cancer risks, using age sensitivity factors, exceed the SCAQMD threshold of 10 in one million, thus resulting in a potentially significant impact not previously addressed or identified by the Addendum. Utilizing age sensitivity factors is the most conservative, health-protective analysis according to the most recent guidance by OEHHA and recommendations from the air district. Results without age sensitivity factors are presented in the table above, although we do not recommend utilizing these values for health risk analysis. An agency must include an analysis of health risks that connects the Project’s air emissions with the health risk posed by those emissions. Our analysis represents a screening-level HRA, which is known to be conservative and tends to err on the side of health protection. The purpose of the screening-level construction HRA shown above is to demonstrate the link between the proposed Project’s emissions and the potential health risk. Our screening-level HRA demonstrates that construction of the Project could result in a potentially significant health risk impact, when correct exposure assumptions and up- to-date, applicable guidance are used. Therefore, since our screening-level construction HRA indicates a potentially significant impact, an updated CEQA analysis should include a reasonable effort to connect the Project’s air quality emissions and the potential health risks posed to nearby receptors. Thus, an updated CEQA analysis should include a quantified air pollution model as well as an updated, quantified refined health risk assessment which adequately and accurately evaluates health risk impacts associated with both Project construction and operation.