3 - The Bowery_PUBLIC COMMENT_RAMSEY

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10 the SCAQMD’s specific numeric threshold of 10 in one million.15 Thus, the DEIR cannot conclude less than significant health risk impacts resulting from Project construction without quantifying emissions to compare to the proper threshold. Screening-Level Assessment Indicates Significant Impact In an effort to demonstrate the potential risk posed by Project construction and all Project operation to nearby sensitive receptors, we prepared a simple screening-level HRA. The results of our assessment, as described below, provide substantial evidence that the Project’s construction and operational DPM emissions may result in a potentially significant health risk impact not previously identified by the DEIR. In order to conduct our screening level risk assessment, we relied upon AERSCREEN, which is a screening level air quality dispersion model. 16 The model replaced SCREEN3, and AERSCREEN is included in the OEHHA 17 and the California Air Pollution Control Officers Associated (CAPCOA)18 guidance as the appropriate air dispersion model for Level 2 health risk screening assessments (“HRSAs”). A Level 2 HRSA utilizes a limited amount of site-specific information to generate maximum reasonable downwind concentrations of air contaminants to which nearby sensitive receptors may be exposed. If an unacceptable air quality hazard is determined to be possible using AERSCREEN, a more refined modeling approach is required prior to approval of the Project. We prepared a preliminary HRA of the Project’s construction and operational health-related impact to residential sensitive receptors using the annual PM10 exhaust estimates from CalEEMod. For the Project’s construction emissions, we used the CalEEMod output files provided in the DEIR. For the Project’s operational emissions, we used SWAPE’s updated operational CalEEMod output files and subtracted SWAPE’s updated existing (passenger cars) and updated existing (trucks) CalEEMod output files. According to the DEIR, the closest sensitive receptor is located approximately 440 meters south of the Project site (p. 5.2-11). Consistent with recommendations set forth by OEHHA, we assumed exposure begins during the third trimester stage of life. The Project’s construction CalEEMod output files indicate that construction activities will generate approximately 507 pounds of diesel particulate matter (DPM) over the 795-day construction period. The AERSCREEN model relies on a continuous average emission rate to simulate maximum downward concentrations from point, area, and volume emission sources. To account for the variability in equipment usage and truck trips over Project construction, we calculated an average DPM emission rate by the following equation: 15 “South Coast AQMD Air Quality Significance Thresholds.” SCAQMD, April 2019, available at: http://www.aqmd.gov/docs/default-source/ceqa/handbook/scaqmd-air-quality-significance- thresholds.pdf?sfvrsn=2 16 “AERSCREEN Released as the EPA Recommended Screening Model,” USEPA, April 11, 2011, available at: http://www.epa.gov/ttn/scram/guidance/clarification/20110411_AERSCREEN_Release_Memo.pdf 17 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf 18 “Health Risk Assessments for Proposed Land Use Projects,” CAPCOA, July 2009, available at: http://www.capcoa.org/wp-content/uploads/2012/03/CAPCOA_HRA_LU_Guidelines_8-6-09.pdf