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CORRESPONDENCE - 60A
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CORRESPONDENCE - 60A
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Agenda Packet
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12/3/2019
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for an additional 28 years, approximately. The Project's operational CalEEMod emissions indicate that <br />operational activities will generate approximately 78 pounds of DPM per year throughout operation. <br />Applying the same equation used to estimate the construction DPM rate, we estimated the following <br />emission rate for Project operation: <br />grams 78.2 lbs 453.6 grams 1 day 1 hour <br />Emission Rate (second) = x x x = 0.001125 g/s <br />second 365 days lbs 24 hours 3,600 seconds <br />Using this equation, we estimated an operational emission rate of 0.001125 g/s. Construction and <br />operational activity was simulated as a 1.7-acre rectangular area source in AERSCREEN with dimensions <br />of 83 meters by 83 meters. A release height of three meters was selected to represent the height of <br />exhaust stacks on operational equipment and other heavy-duty vehicles, and an initial vertical <br />dimension of one and a half meters was used to simulate instantaneous plume dispersion upon release. <br />An urban meteorological setting was selected with model -default inputs for wind speed and direction <br />distribution. <br />The AERSCREEN model generates maximum reasonable estimates of single -hour DPM concentrations <br />from the Project site. EPA guidance suggests that in screening procedures, the annualized average <br />concentration of an air pollutant be estimated by multiplying the single -hour concentration by 10%.14 AS <br />previously stated, there are residential sensitive receptors located approximately 100 meters from the <br />Project site. The single -hour concentration estimated by AERSCREEN for Project construction is <br />approximately 1.954 µg/m3 DPM at approximately 100 meters downwind. Multiplying this single -hour <br />concentration by 10%, we get an annualized average concentration of 0.1954 µg/m3 for Project <br />construction at the nearest sensitive receptor. For Project operation, the single -hour concentration is <br />estimated by AERSCREEN is approximately 1.606 µg/m3 at approximately 100 meters downwind. <br />Multiplying this single -hour concentration by 10%, we get an annualized average concentration of <br />0.1606 µg/m3 for Project operation at the nearest sensitive receptor. <br />We calculated the excess cancer risk to the residential receptors both maximally exposed and located <br />closest to the Project site using applicable HRA methodologies prescribed by OEHHA and the SCAQMD. <br />Consistent with the construction schedule proposed by the Addendum, the annualized average <br />concentration for construction was used for the entire third trimester of pregnancy (0.25 years) and for <br />1.75 years of the infantile stage of life (0 — 2 years). The annualized average concentration for operation <br />was used for the remainder of the 30-year exposure period, including the remaining infantile stage of <br />life, child stage of life (2 —16 years), and adult stage of life (16 — 30 years). <br />Consistent with OEHHA, SCAQMD, BAAQMD, and SJVAPCD guidance, we used Age Sensitivity Factors <br />(ASFs) to account for the heightened susceptibility of young children to the carcinogenic toxicity of air <br />14 "Screening Procedures for Estimating the Air Quality Impact of Stationary Sources Revised." EPA, 1992, available <br />at: http://www.epa.gov/ttn/scram/guidance/guide/EPA-454R-92-019 OCR.pdf; see also "Risk Assessment <br />Guidelines Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February 2015, available at: <br />https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 4-36 <br />W <br />
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