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Item No. 2 Public Comment_Yundt
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Item No. 2 Public Comment_Yundt
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4 <br /> <br />Using this equation, we estimated an operational emission rate of 0.00489 g/s. Construction and <br />operation were simulated as a 5.13-acre rectangular area source in AERSCREEN, with approximate <br />dimensions of 204- by 102-meters. A release height of three meters was selected to represent the <br />height of stacks of operational equipment and other heavy-duty vehicles, and an initial vertical <br />dimension of one and a half meters was used to simulate instantaneous plume dispersion upon release. <br />An urban meteorological setting was selected with model-default inputs for wind speed and direction <br />distribution. The population of Santa Ana was obtained from U.S. 2020 Census data.10 <br />The AERSCREEN model generates maximum reasonable estimates of single-hour DPM concentrations <br />from the Project Site. The U.S. EPA suggests that the annualized average concentration of an air <br />pollutant be estimated by multiplying the single-hour concentration by 10% in screening procedures.11 <br />According to the Air Quality Assessment (“AQA”), provided as Appendix A to the EA, the nearest <br />sensitive receptor is located 700 feet, or 213 meters, from the Project site (p. 9). Thus, the single-hour <br />concentration estimated by AERSCREEN for Project construction is approximately 1.049 µg/m3 DPM at <br />approximately 200 meters downwind. Multiplying this single-hour concentration by 10%, we get an <br />annualized average concentration of 0.1049 µg/m3 for Project construction at the MEIR. For Project <br />operation, the single-hour concentration estimated by AERSCREEN is 2.849 µg/m3 DPM at approximately <br />200 meters downwind. Multiplying this single-hour concentration by 10%, we get an annualized average <br />concentration of 0.2849 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, as recommended by SCAQMD.12 Specifically, guidance from OEHHA and the California Air <br />Resources Board (“CARB”) recommends the use of a standard point estimate approach, including high- <br />point estimate (i.e. 95th percentile) breathing rates and age sensitivity factors (“ASF”) in order to <br />account for the increased sensitivity to carcinogens during early-in-life exposure and accurately assess <br />risk for susceptible subpopulations such as children. The residential exposure parameters, such as the <br />daily breathing rates (“BR/BW”), exposure duration (“ED”), age sensitivity factors (“ASF”), fraction of <br />time at home (“FAH”), and exposure frequency (“EF”) utilized for the various age groups in our <br />screening-level HRA are as follows: <br /> <br />10 “Santa Anna.” U.S. Census Bureau, 2020, available at: https://datacommons.org/place/geoId/0669000. <br />11 “Screening Procedures for Estimating the Air Quality Impact of Stationary Sources Revised.” U.S. EPA, October <br />1992, available at: http://www.epa.gov/ttn/scram/guidance/guide/EPA-454R-92-019_OCR.pdf. <br />12 “AB 2588 and Rule 1402 Supplemental Guidelines.” SCAQMD, October 2020, available at: <br />http://www.aqmd.gov/docs/default-source/planning/risk-assessment/ab-2588-supplemental- <br />guidelines.pdf?sfvrsn=19, p. 2.
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