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generate 1,112 daily vehicle trips, or 1,171 daily vehicle trips without the non -auto trip adjustment, which will generate additional exhaust emissions and continue to expose nearby sensitive receptors to DPM emissions (Appendix F, p. 10, Table 5-1). Furthermore, the omission of a quantified operational HRA is inconsistent with the most recent guidance published by the Office of Environmental Health Hazard Assessment ("OEHHA"). The OEHHA document recommends that exposure from projects lasting more than 6 months be evaluated for the duration of the project, and recommends that an exposure duration of 30 years be used to estimate individual cancer risk for the maximally exposed individual resident ("MEIR").'9 Even though we were not provided with the expected lifetime of the Project, we can reasonably assume that the Project will operate for at least 30 years, if not more. Therefore, we recommend that health risk impacts from Project operation also be evaluated, as a 30-year exposure duration vastly exceeds the 6-month requirement set forth by OEHHA. These recommendations reflect the most recent state health risk policies, and as such, we recommend that an updated assessment of health risk impacts posed to nearby sensitive receptors from Project operation be included in an EIR for the Project. Fourth, by claiming a less than significant impact without conducting a quantified HRA to disclose the exposure levels to nearby, existing sensitive receptors as a result of Project construction and operation, the Addendum fails to compare the excess health risk to the SCAQMD's specific numeric threshold of 10 in one million.20 Thus, the Addendum cannot conclude less than significant health risk impacts resulting from Project construction and operation without quantifying emissions to compare to the proper threshold. Screening -Level Analysis Demonstrates Significant Impacts In an effort to accurately estimate the emissions associated with the Project, we prepared an updated CaIEEMod model, using the Project -specific information provided by the Addendum. In our updated model, we corrected the CO2 intensity factor, residential land use size, and operational vehicle trip rates; proportionally revised the construction phase lengths to achieve an overall construction period of 21 months; and omitted the unsubstantiated construction -related and operational mitigation measures. Utilizing our updated model, and in an effort to demonstrate the potential health risk posed by Project construction and operation to nearby, existing sensitive receptors utilizing a site -specific emissions estimates, we prepared a simple screening -level HRA. The results of our assessment as described below, demonstrate that the proposed Project may result in a significant impact not previously identified or addressed in the Addendum. In order to conduct our screening -level risk assessment we relied upon AERSCREEN, which is a screening level air quality dispersion model." The model replaced SCREEN3, and AERSCREEN is included in the 19 "Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February 2015, available at: http://oehha.ca.gov/air/hot spots/2015/2015GuidanceManual.pdf, p. 8-6, 8-15 21 "South Coast AQMD Air Quality Significance Thresholds." SCAQMD, April 2019, available at: htti)://www.a a m d.gov/d ocs/defa ul t-source/cea a/hand book/scan and -a i r-a ua I ity-si gni fi ca nce-threshold s. pd f. 21 U.S. EPA (April 2011) AERSCREEN Released as the EPA Recommended Screening Model, http://www.epa.gov/ttn/scram/guidance/clarification/20110411 AERSCREEN Release Memo.pdf 15 75C-90