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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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Indoor Air Quality Impact Mitigation Measures <br />The following are recommended mitigation measures to minimize the impacts upon indoor <br />quality: <br />Indoor Formaldehyde Concentrations Mitigation. Use only composite wood materials (e.g. <br />hardwood plywood, medium density fiberboard, particleboard) for all interior finish <br />systems that are made with CARB approved no -added formaldehyde (NAF) resins (CARB, <br />2009). CARB Phase 2 certified composite wood products, or ultra -low emitting <br />formaldehyde (ULEF) resins, do not insure indoor formaldehyde concentrations that are <br />below the CEQA cancer risk of 10 per million. Only composite wood products <br />manufactured with CARB approved no -added formaldehyde (NAF) resins, such as resins <br />made from soy, polyvinyl acetate, or methylene diisocyanate can insure that the OEHHA <br />cancer risk of 10 per million is met. <br />Alternatively, conduct the previously described Pre -Construction Building <br />Material/Furnishing Chemical Emissions Assessment, to determine that the combination of <br />formaldehyde emissions from building materials and furnishings do not create indoor <br />formaldehyde concentrations that exceed the CEQA cancer and non -cancer health risks. <br />It is important to note that we are not asking that the builder "speculate" on what and how <br />much composite materials be used, but rather at the design stage to select composite wood <br />materials based on the formaldehyde emission rates that manufacturers routinely conduct <br />using the California Department of Health "Standard Method for the Testing and <br />Evaluation of Volatile Organic Chemical Emissions for Indoor Sources Using <br />Environmental Chambers", (CDPH, 2017), and use the procedure described above (i.e. <br />Pre -Construction Building Material/Furnishing Formaldehyde Emissions Assessment) to <br />insure that the materials selected achieve acceptable cancer risks from material off gassing <br />of formaldehyde. <br />13 of 19 <br />
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