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City of Santa Ana -The Bowery <br />May 11, 2020 <br />nxge 11 of 2s <br />construction period of approximately 26 months (Appendix B, pp. <br />24 ). The OEHHA document recommends that all short -tern <br />projects lasting at least two months be evaluated for cancer risks to <br />nearby sensitive receptors. Therefore, per OEHIdA guidelines, we <br />recommend that health risk impacts from. Project construction be <br />evaluated by the DEIR. Furthermore, once construction of the <br />Project is complete, the Project will operate for a long period of <br />time. As previously stated, Project operation will generate <br />approximately 11,546 daily vehicle trips, which will generate <br />additional exhaust emissions and continue to expose nearby <br />sensitive receptors to DPM emissions (p. 5.14-11, Table 5.14-5). <br />The OEHHA document recommends that exposure from projects <br />lasting more than 6 months be evaluated for the duration of the <br />project, and recommends that an exposure duration of 30 years be <br />used to estimate individual cancer risk for the maximally exposed <br />individual resident (MEIR). Even though we were not provided <br />with the expected lifetime of the Project, we can reasonably assume <br />that the Project will operate for at least 30 years, if not more. <br />Therefore, we recommend that health risks from Project operation <br />also be evaluated, as a 30-year exposure duration vastly exceeds the <br />2-month and 6-month requirements set forth by OEIIIIA. This <br />guidance reflects the most recent health risk policy, and as such, we <br />recommend that an updated assessment of health risks to nearby <br />sensitive receptors from Project construction and operation be <br />included in a revised CEQA evaluation for the Project. <br />claiming a less than significant impact without conducting a <br />quantified I IRA to nearby, existing sensitive receptors as a result of <br />Project construction, the DEIR fails to compare the excess health <br />risk to the SCAQ:14CYs specific numeric threshold of 10 in one <br />million. Thus, the DFJR cannot conclude less Ihan sigmificant <br />health risk impacts resulting from Project construction without <br />quantifying emissions to compare to the proper threshold. <br />(Hagemann at 8-10.) <br />75C-131 <br />