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Correspondence - #18
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10/03/2023 Regular
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Correspondence - #18
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10/11/2023 4:38:15 PM
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City Clerk
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10/3/2023
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With respect to the Cabrillo Town Center Project, Santa Ana, CA, the buildings consist of <br />residential and commercial spaces. <br />The residential occupants will potentially have continuous exposure (e.g., 24 hours per day, <br />52 weeks per year). These exposures are anticipated to result in significant cancer risks <br />resulting from exposures to formaldehyde released by the building materials and furnishing <br />commonly found in residential construction. <br />Because these residences will be constructed with CARB Phase 2 Formaldehyde ATCM <br />materials and be ventilated with the minimum code required amount of outdoor air, the <br />indoor residential formaldehyde concentrations are likely similar to those concentrations <br />observed in residences built with CARB Phase 2 Formaldehyde ATCM materials, which <br />is a median of 24.1 µg/m3 (Singer et. al., 2020). <br />Assuming that the residential occupants inhale 20 m3 of air per day, the average 70-year <br />lifetime formaldehyde daily dose is 482 µg/day for continuous exposure in the residences. <br />This exposure represents a cancer risk of 120 per million, which is more than 12 times the <br />CEQA cancer risk of 10 per million. For occupants that do not have continuous exposure, <br />the cancer risk will be proportionally less but still substantially over the CEQA cancer risk <br />of 10 per million (e.g., for 12/hour/day occupancy, more than 6 times the CEQA cancer <br />risk of 10 per million). <br />The employees of the commercial spaces are expected to experience significant indoor <br />exposures (e.g., 40 hours per week, 50 weeks per year). These exposures for employees are <br />anticipated to result in significant cancer risks resulting from exposures to formaldehyde <br />released by the building materials and furnishing commonly found in offices, warehouses, <br />residences and hotels. <br />Because the commercial spaces will be constructed with CARB Phase 2 Formaldehyde <br />ATCM materials, and be ventilated with the minimum code required amount of outdoor <br />air, the indoor formaldehyde concentrations are likely similar to those concentrations <br />observed in residences built with CARB Phase 2 Formaldehyde ATCM materials, which <br />4of19 <br />
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