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concentration of an air pollutant be estimated by multiplying the single -hour concentration by 10%.24 <br />According to the Addendum, the nearest sensitive receptors are located approximately 55 feet, or 17 <br />meters, from the Project boundary (p. 3.2-6). However, review of the AERSCREEN output files <br />demonstrates that the MEIR is located approximately 75 meters from the Project site. Thus, the single - <br />hour concentration estimated by AERSCREEN for Project construction is approximately 3.914 µg/m3 <br />DPM at approximately 75 meters downwind. Multiplying this single -hour concentration by 10%, we get <br />an annualized average concentration of 0.3914 µg/m3 for Project construction at the MEIR. For Project <br />operation, the single -hour concentration estimated by AERSCREEN is 2.332 µg/m3 DPM at approximately <br />75 meters downwind. Multiplying this single -hour concentration by 10%, we get an annualized average <br />concentration of 0.2332 µg/m3 for Project operation at the MEIR. <br />We calculated the excess cancer risk to the MEIR using applicable HRA methodologies prescribed by <br />OEHHA. Consistent with the Addendum's proposed 21- to 24-month construction schedule, the <br />annualized average concentration for Project construction was used for the entire third trimester of <br />pregnancy (0.25 years) and the first 1.49 years of the infantile stage of life (0 — 2 years) (p. 2-11). The <br />annualized averaged concentration for operation was used for the remainder of the 30-year exposure <br />period, which makes up the remaining 0.51 years of the infantile stage of life, the entire child stage of <br />life (2 —16 years), and the entire the adult stage of life (16 — 30 years). <br />Consistent with OEHHA, as recommended by the SCAQMD, BAAQMD, and SJVAPCD guidance, we used <br />Age Sensitivity Factors ("ASF") to account for the heightened susceptibility of young children to the <br />carcinogenic toxicity of air pollution.",z6," According to this guidance, the quantified cancer risk should <br />be multiplied by a factor of ten during the third trimester of pregnancy and during the first two years of <br />life (infant) as well as multiplied by a factor of three during the child stage of life (2 —16 years). We also <br />included the quantified cancer risk without adjusting for the heightened susceptibility of young children <br />to the carcinogenic toxicity of air pollution in accordance with older OEHHA guidance from 2003. This <br />guidance utilizes a less health protective scenario than what is currently recommended by SCAQMD, the <br />air quality district with jurisdiction over the City, and several other air districts in the state. Furthermore, <br />in accordance with the guidance set forth by OEHHA, we used the 95`h percentile breathing rates for <br />""Screening Procedures for Estimating the Air Quality Impact of Stationary Sources Revised." EPA, 1992, available <br />at: htti)://www.ei)a.gov/ttn/scram/guidance/guide/EPA-454R-92-019 OCR.pdf; see also "Risk Assessment <br />Guidelines Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February 2015, available at: <br />htti)s://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.1)df p. 4-36. <br />25 "Draft Environmental Impact Report (DEIR) for the Proposed The Exchange (SCH No. 2018071058)." SCAQMD, <br />March 2019, available at: http://www.agmd.gov/docs/default-source/cega/comment- <br />letters/2019/march/RVC190115-03.pdf?sfvrsn=8, p. 4. <br />26 "California Environmental Quality Act Air Quality Guidelines." BAAQMD, May 2017, available at: <br />http://www.baagmd.gov/—/media/files/planning-and-research/cega/cega guidelines may2017-pdf.pdf?la=en, p. <br />56; see also "Recommended Methods for Screening and Modeling Local Risks and Hazards." BAAQMD, May 2011, <br />available at: <br />http://www. baag md.gov/—/media /Files/Planning%20a nd%2OResea rch/CEQA/BAAQMD%20M ode I i ng%2OApp roa c <br />h.ashx, p. 65, 86. <br />27 "Update to District's Risk Management Policy to Address OEHHA's Revised Risk Assessment Guidance <br />Document." SIVAPCD, May 2015, available at: https://www.vallevair.org/busind/pto/staff-report-5-28-15.pdf, p. 8, <br />20, 24. <br />17 <br />75C-92 <br />