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residential, schools, hospitals, or nursing homes), as measured from the property line of the
<br />project to the property line of the nearest sensitive use, shall submit a health risk assessment
<br />(HRA) to the City of Santa Ana for review and approval...
<br />Proposed Project Applicability: Mitigation Measure AQ-3 is not applicable to the proposed
<br />Project because it would only generate 44 truck trips per day, as detailed in Section 5.17,
<br />Transportation" (p. 2-81).
<br />As demonstrated above, the EA claims the Project is not required to submit an HRA, as MM-AQ-3 is not
<br />applicable to the proposed Project. However, regardless of the EA's claims, the State of California
<br />Department of Justice recommends that all warehouse projects prepare a quantitative HRA pursuant to
<br />the Office of Environmental Health Hazard Assessment ("OEHHA"), the organization responsible for
<br />providing guidance on conducting HRAs in California, as well as local air district guidelines.' OEHHA
<br />released its most recent Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk
<br />Assessments in February 2015. This guidance document describes the types of projects that warrant the
<br />preparation of an HRA. Specifically, OEHHA recommends that all short-term projects lasting at least 2
<br />months assess cancer risks.2 Furthermore, according to OEHHA:
<br />"Exposure from projects lasting more than 6 months should be evaluated for the duration of the
<br />project. In all cases, for assessing risk to residential receptors, the exposure should be assumed
<br />to start in the third trimester to allow for the use of the ASFs (OEHHA, 2009)."'
<br />Thus, as the Project's anticipated construction duration exceeds the 2-month and 6-month
<br />requirements set forth by OEHHA, construction of the Project meets the threshold warranting a
<br />quantified HRA under OEHHA guidance and should be evaluated for the entire 12-month construction
<br />period (p. 2-53). Furthermore, OEHHA recommends that an exposure duration of 30 years should be
<br />used to estimate the individual cancer risk at the maximally exposed individual resident ("MEIR").4 While
<br />the Project documents fail to provide the expected lifetime of the proposed Project, we can reasonably
<br />assume that the Project would operate for at least 30 years, if not more. Therefore, operation of the
<br />Project also exceeds the 2-month and 6-month requirements set forth by OEHHA and should be
<br />evaluated for the entire 30-year residential exposure duration, as indicated by OEHHA guidance. These
<br />recommendations reflect the most recent state health risk policies, and as such, an EIR should be
<br />prepared to include an analysis of health risk impacts posed to nearby sensitive receptors from Project -
<br />generated DPM emissions.
<br />' "Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental
<br />Quality Act." State of California Department of Justice, available at:
<br />https://ogg.ca.gov/sites/all/files/a web/pdfs/environment/warehouse-best-practices,pdf, p. 6.
<br />z "Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February
<br />2015, available at: hops://oehha,ca,ov/media/downloads/crnr/2015uidancemanual,pdf, p. 8-18.
<br />' "Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February
<br />2015, available at: hops://oehha,ca,ov/media/downloads/crnr/2015uidancemanual,pdf, p. 8-18.
<br />4 "Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February
<br />2015, available at: hops://oehha,ca,ov/media/downloads/crnr/2015uidancemanual,pdf, p. 2-4.
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