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2009. Likewise, the onsite borings (completed in May 2019) show that the depth to groundwater was in the range of 24 to 33 feet. The boring records are provided in Appendix C of the Draft EIR. However, in the case that groundwater is encountered during Project construction, it would be treated and discharged, similar to the previous clean up activity detailed in the RWQCB No Further Action letter. As described in Responses 14 and 16, the federal Occupational Safety and Health Act Safety and Health Regulations for Construction contains requirements for construction activities, including health and safety plan(s). In addition, the CalOSHA required Injury and Illness Prevention Program (IIPP) would maintain worker safety related to potentially contaminated groundwater. Thus, implementation of construction pursuant to existing regulations as ensured through the permitting process would reduce potential impacts related to construction workers who may encounter contaminated groundwater when excavation is conducted to a less than significant level. The comment has not identified a potentially new impact not described in the EIR. Thus, none of the requirements for recirculation, as listed in CEQA Guidelines Section 15088.5, 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. 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 took effect on January 1, 2020 and were adopted by the City), which would far 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, all Project buildings would be fully ventilated with air filtration systems with efficiencies that meet or exceed the California Building Code standards at the time of permitting. 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. The proposed Project would be required through federal product standards to 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 75C-115