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CORRESPONDENCE - 75C
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CORRESPONDENCE - 75C
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8/18/2020 3:38:45 PM
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City Clerk
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8/18/2020
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Because these residences will be constructed with CARB Phase 2 Formaldehyde ATCM <br />materials, and be ventilated with the minimum code required amount of outdoor air, the <br />indoor residential formaldehyde concentrations are likely similar to those concentrations <br />observed in residences built with CARB Phase 2 Formaldehyde ATCM materials, which <br />is a median of 22.4 µg/m3 (Chan et. al., 2019) <br />Assuming that the residential occupants inhale 20 in of air per day, the average 70-year <br />lifetime formaldehyde daily dose is 448 µg/day for continuous exposure in the residences. <br />This exposure represents a cancer risk of 112 per million, which is more than 11 times the <br />South Coast Air Quality Management District CEQA cancer risk of 10 per million <br />(SCAQMD, 2015). For occupants that do not have continuous exposure, the cancer risk <br />will be proportionally less but still substantially over the SCAQMD CEQA cancer risk of <br />10 per million (e.g. for 12/hour/day occupancy, more than 5 times the SCAQMD CEQA <br />cancer risk of 10 per million). <br />The employees of the commercial spaces are also expected to experience significant indoor <br />exposures (e.g., 40 hours per week, 50 weeks per year). These exposures for employees are <br />anticipated to result in significant cancer risks resulting from exposures to formaldehyde <br />released by the building materials and furnishing commonly found in offices, warehouses, <br />residences and hotels. <br />Because these commercial will be constructed with CARB Phase 2 Formaldehyde ATCM <br />materials, and be ventilated with the minimum code required amount of outdoor air, the <br />indoor warehouse formaldehyde concentrations are likely similar to those concentrations <br />observed in residences built with CARB Phase 2 Formaldehyde ATCM materials, which <br />is a median of 22.4 µg/m3 (Chan et. al., 2019). <br />Assuming that the commercial space employees work 8 hours per day and inhale 20 in of <br />air per day, the formaldehyde dose per work -day at the offices is 149 µg/day. <br />Assuming that the commercial space employees work 5 days per week and 50 weeks per <br />year for 45 years (start at age 20 and retire at age 65) the average 70-year lifetime <br />4of19 <br />
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