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Appendix C - Health Risk Assessment
November 2022 HEALTH RISK ASSESSMENT SANTA ANA AND LIVE OAK WAREHOUSE PROJECT FONTANA, CALIFORNIA November 2022 HEALTH RISK ASSESSMENT SANTA ANA AND LIVE OAK WAREHOUSE PROJECT FONTANA, CALIFORNIA Submitted to: EPD Solutions, Inc. 2 Park Plaza, Suite 1120 Irvine, California 92614 Prepared by: LSA 2565 Alluvial Avenue, Suite 172 Clovis, California 93611 (559) 490-1210 Project No. ESL2201.25 HEALTH RISK ASSESSMENT NOVEMBER 2022 SANTA ANA AND LIVE OAK WAREHOUSE PROJECT FONTANA, CALIFORNIA P:\ESL2201.25\PRODUCTS\ESL2201.25 HRA_111022.docx «11/10/22» i TABLE OF CONTENTS TABLE OF CONTENTS ............................................................................................................................... i LIST OF ABBREVIATIONS AND ACRONYMS ............................................................................................ iii INTRODUCTION .......................................................................................................... 1 Project Location And Description .................................................................................................. 1 Existing Land Uses in the project area .......................................................................................... 4 BACKGROUND ............................................................................................................ 5 California Air Resources Board Handbook and Technical Advisory .............................................. 5 Office of Environmental Health and Hazard Assessment Guidelines ........................................... 5 California Air Pollution Control Officers Association .................................................................... 5 South Coast Air Quality Management District .............................................................................. 6 SETTING ...................................................................................................................... 7 Regional Air Quality ....................................................................................................................... 7 Climate/Meteorology ......................................................................................................................... 7 Toxic Air Contaminants ....................................................................................................................... 8 THRESHOLDS OF SIGNIFICANCE ................................................................................... 9 METHODOLOGY ........................................................................................................ 10 Construction Health Risk Assessment ......................................................................................... 10 Operational Health RIsk Assessment .......................................................................................... 10 General Information ......................................................................................................................... 10 Emission Sources .............................................................................................................................. 12 HEALTH RISK IMPACTS .............................................................................................. 13 Construction Health RIsk Assessment ......................................................................................... 13 Operational Health Risk Assessment........................................................................................... 14 Conclusion ................................................................................................................................... 15 APPENDIX A: HRA Model Output HEALTH RISK ASSESSMENT NOVEMBER 2022 SANTA ANA AND LIVE OAK WAREHOUSE PROJECT FONTANA, CALIFORNIA P:\ESL2201.25\PRODUCTS\ESL2201.25 HRA_111022.docx «11/10/22» ii FIGURES AND TABLES FIGURES Figure 1: Project Location ....................................................................................................................... 2 Figure 2: Site Plan ................................................................................................................................... 3 Figure 3: Project Area Wind Patterns ..................................................................................................... 7 TABLES Table A: Health Risks from Project Construction to Off-Site Receptors using Tier 2 ........................... 13 Table B: Health Risks from Project Construction with Best Management Practices ........................... 14 Table C: Health Risks from Project Operation to Off-Site Receptors ................................................... 14 HEALTH RISK ASSESSMENT NOVEMBER 2022 SANTA ANA AND LIVE OAK WAREHOUSE PROJECT FONTANA, CALIFORNIA P:\ESL2201.25\PRODUCTS\ESL2201.25 HRA_111022.docx «11/10/22» iii LIST OF ABBREVIATIONS AND ACRONYMS AB Assembly Bill AERMOD American Meteorological Society/Environmental Protection Agency Regulatory Model Basin South Coast Air Basin CalEEMod California Emissions Estimator Model CAPCOA California Air Pollution Control Officers Association CARB California Air Resources Board CARB Handbook Air Quality and Land Use Handbook CEQA California Environmental Quality Act DPM diesel particulate matter EMFAC2021 California Emissions Factor Model, Version 2021 ft foot/feet HARP Hotspots Analysis and Reporting Program (Version 2) HI Hazard Index HRA Health Risk Assessment MEI maximally exposed individual MICR maximum individual cancer risk mph miles per hour OEHHA California Office of Environmental Health Hazard Assessment PM10 particulate matter less than 10 microns in diameter project Santa Ana and Live Oak Warehouse Project ROG reactive organic gas SCAQMD South Coast Air Quality Management District sf square foot/feet TAC toxic air contaminant URF unit risk factor USEPA United States Environmental Protection Agency HEALTH RISK ASSESSMENT NOVEMBER 2022 SANTA ANA AND LIVE OAK WAREHOUSE PROJECT FONTANA, CALIFORNIA P:\ESL2201.25\PRODUCTS\ESL2201.25 HRA_111022.docx «11/10/22» 1 INTRODUCTION LSA has prepared a construction and operational health risk assessment (HRA) for the proposed Santa Ana and Live Oak Warehouse Project (project) in Fontana, California. An HRA is a process used to estimate the increased health risk levels for people living and/or working near a project that emits toxic air contaminants (TACs). An HRA combines results of studies on the health effects of various animal and human exposure to TACs with results of studies that estimate the exposure levels at different distances from the source of pollutants. The purpose of the HRA is to document the increased cancer and noncancer health risk levels from project-related emissions of TACs on existing nearby sensitive receptors, including residents and/or workers. The City of Fontana recommends the preparation of an HRA in accordance with policies and procedures of the State Office of Environmental Health Hazard Assessment (OEHHA) and the South Coast Air Quality Management District (SCAQMD). This HRA evaluates all of these criteria in compliance with applicable requirements. PROJECT LOCATION AND DESCRIPTION The proposed project is within the southern portion of Fontana at the northwest intersection of Santa Ana Avenue and Live Oak Avenue. Figure 1 illustrates the project site location. The project site consists of 3 parcels totaling 13.8 acres. The lots are currently developed with a trucking company, Tiger Group Transport, Inc. Existing site access is available via Live Oak Avenue along the center of the project site. All existing site improvements would be removed prior to grading operations. The proposed project would consist of demolishing the existing structures and other site improvements and constructing a new warehouse with related on-site improvements. The project would consist of a 319,956-square-foot (sf) industrial building inclusive of 10,000 sf of first-floor office space and 5,000 sf of second-floor office space. The project is within the Southwest Industrial Park Specific Plan and falls within the Slover Central Manufacturing/Industrial District. The project would be accessible via three new points of ingress and egress. There would be two access points along Santa Ana Avenue: a 50 foot (ft) driveway at the western end and a 35 ft driveway farther east. A 40 ft driveway would also be placed at the northern end of Live Oak Avenue. For emergency vehicle access only, a 30 ft driveway would be placed along Like Oak Avenue near the intersection of Live Oak and Santa Ana. A turf block would be present to prohibit use by non- permitted vehicles. Figure 2 depicts the proposed project’s site plan. The project would include 102 automobile parking spaces situated along the northern and southern ends of the project site and 65 trailer stalls along the western side of the site. The project would also include 46 dock doors along the western side of the warehouse oriented away from the public right-of-way. Typical operational characteristics include employees travel to and from the site, delivery of materials and supplies to the site, truck loading and unloading, and distribution. The project is assumed to operate 24 hours a day, 7 days a week; however, this may shift depending on the tenant, as the hours of operation are unknown. Service Layer Credits: Copyright:(c) 2014 Esri © 2022 Microsoft Corporation © 2022 SOURCE: Bing Maps (2022) I:\ESL2201.25\GIS\MXD\Regional_Project_Location.mxd (6/8/2022) FIGURE 1 Santa Ana and Live Oak Warehouse Project Regional Project Location LEGEND Project Location 0 750 1500 FEET SanBernardinoCounty RiversideCounty ÃÃ142 ÃÃ241 ÃÃ18 ÃÃ71 ÃÃ210 ÃÃ60 ÃÃ91 Project Location §¨¦15 §¨¦215 §¨¦10 Project Vicinity 120060FEETSOURCE: HPA Architecture, January 2022I:\ESL2201.25\G\Fig 2_Site Plan.ai (6/7/2022)FIGURE 2Santa Ana and Live Oak Warehouse ProjectCity of Fontana, San Bernardino County, CaliforniaSite Plan HEALTH RISK ASSESSMENTNOVEMBER 2022 SANTA ANA AND LIVE OAK WAREHOUSE PROJECT FONTANA, CALIFORNIA P:\ESL2201.25\PRODUCTS\ESL2201.25 HRA_111022.docx «11/10/22» 4 EXISTING LAND USES IN THE PROJECT AREA For the purposes of this analysis, sensitive receptors are areas of the population that have an increased sensitivity to air pollution or environmental contaminants. Sensitive receptor locations include residences, schools, daycare centers, hospitals, parks, and similar uses that are sensitive to air quality. Impacts on sensitive receptors are of particular concern because those receptors are the population most vulnerable to the effects of air pollution. The project site is surrounded primarily by general industrial facilities. The areas adjacent to the project site include the following uses: •North: An existing lumber yard; •East: Existing industrial uses opposite Live Oak Avenue; •South: Existing warehouse uses opposite Santa Ana Avenue; and •West: Existing single-family residence and logistics warehouse. The nearest sensitive receptors are: •West: Single-family residential use at 14790 Santa Ana Avenue approximately 100 ft away from the project boundary line and a single-family residential use at 10880 Redwood Avenue 720 ft away from the project boundary line. •Southwest: Single-family residence at 11046 Redwood Avenue 1,165 ft away from the project boundary line. In order to provide a conservative analysis, the residence to the west was analyzed as a sensitive receptor. However, per Ordinance No. 1906 adopted by the City on October 25, 2022, the residence is no longer considered a sensitive receptor as it is located on an existing unpermitted use. HEALTH RISK ASSESSMENTNOVEMBER 2022 SANTA ANA AND LIVE OAK WAREHOUSE PROJECT FONTANA, CALIFORNIA P:\ESL2201.25\PRODUCTS\ESL2201.25 HRA_111022.docx «11/10/22» 5 BACKGROUND This section provides a discussion of regulatory guidance from the California Air Resources Board (CARB), the OEHHA, the California Air Pollution Control Officers Association (CAPCOA), and the SCAQMD. CALIFORNIA AIR RESOURCES BOARD HANDBOOK AND TECHNICAL ADVISORY CARB has developed an Air Quality and Land Use Handbook (CARB Handbook;)1 and a supplement, Strategies to Reduce Air Pollution Exposure Near High-Volume Roadways: Technical Advisory2, which are intended to serve as general reference guides for evaluating and reducing air pollution impacts associated with new projects that are part of the land use decision-making process. According to the CARB Handbook, recent air pollution studies have shown an association between both respiratory and other noncancer health effects and proximity to high-traffic roadways and other land uses associated with high volume truck traffic. Other studies have shown that diesel exhaust and other cancer-causing chemicals emitted from cars and trucks are responsible for much of the overall cancer risk from airborne toxics in California. The CARB Handbook recommends that planning agencies recognize that the configuration of warehouse and distribution centers can reduce population exposure and risk. For example, locating the main entry and exit points away from sensitive land uses helps to reduce cancer risks and other health impacts. OFFICE OF ENVIRONMENTAL HEALTH AND HAZARD ASSESSMENT GUIDELINES The OEHHA developed the Air Toxics Hot Spots Program Guidance Manual3 in conjunction with the CARB for use in implementing the Air Toxics Hot Spots Program (Health and Safety Code Section 44360). The manual describes health effect values, exposure pathway variates (e.g., breathing rates), and a tiered approach for performing HRAs based on current science and policy assessment. The intent of the guidance manual is to incorporate children’s health concerns, update risk assessment practices, and provide consistent risk assessment procedures. CALIFORNIA AIR POLLUTION CONTROL OFFICERS ASSOCIATION In 2009, the CAPCOA published guidance4 on assessing the health risk impacts from and to proposed land use projects, focusing on the acute, chronic, and cancer impacts of sources affected by California Environmental Quality Act (CEQA). The document recommends procedures to identify when a project should undergo further risk evaluation, procedures for conducting an HRA, 1 California Air Resources Board (CARB). 2005. Air Quality and Land Use Handbook: A Community Health Perspective. April. Website: www.arb.ca.gov/ch/handbook.pdf (accessed June 2022). 2 CARB. 2017. Strategies to Reduce Air Pollution Exposure Near High-Volume Roadways: Technical Advisory. April. Website: www.arb.ca.gov/ch/rd_technical_analysis_fact_sheet.pdf (accessed June 2022). 3 California Office of Environmental Health Hazard Assessment (OEHHA). 2015. Air Toxics Hot Spots Program Guidance Manual. March. Website: oehha.ca.gov/air/crnr/notice-adoption-air-toxics-hot-spots- program-guidance-manual-preparation-health-risk-0 (accessed June 2022). 4 California Air Pollution Control Officers Association (CAPCOA). 2009. Health Risk Assessments for Proposed Land Use Projects. July. Website: www.capcoa.org/wp-content/uploads/2012/03/CAPCOA_HRA_LU_ Guidelines_8-6-09.pdf (accessed June 2022). HEALTH RISK ASSESSMENT NOVEMBER 2022 SANTA ANA AND LIVE OAK WAREHOUSE PROJECT FONTANA, CALIFORNIA P:\ESL2201.25\PRODUCTS\ESL2201.25 HRA_111022.docx «11/10/22» 6 guidelines to engage the public, presentation guidelines for results from the HRA, and mitigation measures that may be appropriate for various land use projects. SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT The SCAQMD has risk assessment guidelines, AB 2588 and Rule 1402 Supplemental Guidelines5. These guidelines incorporate the OEHHA guidance and the options to be used when using the CARB’s Hotspots Analysis and Reporting Program Version 2 (HARP) program for risk assessment calculations.6 5 South Coast Air Quality Management District (SCAQMD). 2018. AB2588 and Rule 1402 Supplemental Guidelines. July. Website: www.aqmd.gov/docs/default-source/planning/risk-assessment/ab2588 supplementalguidelines.pdf (accessed June 2022). 6 CARB. n.d. Hot Spots Analysis & Reporting Program. Website: www.arb.ca.gov/toxics/harp/harp.htm (accessed June 2022). HEALTH RISK ASSESSMENT NOVEMBER 2022 SANTA ANA AND LIVE OAK WAREHOUSE PROJECT FONTANA, CALIFORNIA P:\ESL2201.25\PRODUCTS\ESL2201.25 HRA_111022.docx «11/10/22» 7 SETTING REGIONAL AIR QUALITY The project site is in Fontana, California, which is part of the South Coast Air Basin (Basin) and is under the jurisdiction of the SCAQMD. Climate/Meteorology Air quality in the planning area is not only affected by various emission sources (e.g., mobile and industry), but also by atmospheric conditions (e.g., wind speed, wind direction, temperature, and rainfall). The nearest representative meteorological station that provides the American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD) ready meteorological data is the Fontana Meteorological Station, approximately 4 miles north of the project site. Figure 3, Project Area Wind Patterns, shows the windrose7 from data measured at this station and the wind patterns for the project area. Source: SCAQMD Meteorological Data for AERMOD. Website: www.aqmd.gov/home/air-quality/air-quality-data-studies/meteorological-data/data-for-aermod (accessed June 2022). Figure 3: Project Area Wind Patterns 7 A windrose provides a succinct view of how wind speed and direction are typically distributed at a particular location. Presented in a circular format, the windrose shows the frequency of winds blowing from particular directions. HEALTH RISK ASSESSMENT NOVEMBER 2022 SANTA ANA AND LIVE OAK WAREHOUSE PROJECT FONTANA, CALIFORNIA P:\ESL2201.25\PRODUCTS\ESL2201.25 HRA_111022.docx «11/10/22» 8 Toxic Air Contaminants The public’s exposure to TACs is a significant environmental health issue in the State of California. In 1983, the California Legislature enacted a program to identify the health effects of TACs and to reduce exposure to these contaminants to protect the public health. The Health and Safety Code defines a TAC as “an air pollutant which may cause or contribute to an increase in mortality or in serious illness, or which may pose a present or potential hazard to human health.” A substance that is listed as a hazardous air pollutant pursuant to subsection (b) of Section 112 of the Federal Act (42 United States Code Section 7412) is a TAC. Under State law, the California Environmental Protection Agency, acting through CARB, is authorized to identify a substance as a TAC if it determines the substance is an air pollutant that may cause or contribute to an increase in mortality or an increase in serious illness, or which may pose a present or potential hazard to human health. California regulates TACs primarily through Assembly Bill (AB) 1807 (Tanner Air Toxics Act), AB 2588 (Air Toxics “Hot Spot” Information and Assessment Act of 1987), and Senate Bill 25, the Children's Environmental Health Protection Act. The Tanner Air Toxics Act sets forth a formal procedure for CARB to designate substances as TACs. Once a TAC is identified, CARB adopts an “airborne toxics control measure” for sources that emit designated TACs. If there is a safe threshold for a substance at which there is no toxic effect, the control measure must reduce exposure to below that threshold. If there is no safe threshold, the measure must incorporate toxics best available control technology to minimize emissions. Air toxics from stationary sources are also regulated in California under AB 2588. Under AB 2588, TAC emissions from individual facilities are quantified and prioritized by the designated air quality management district or air pollution control district. High-priority facilities are required to perform an HRA and, if specific thresholds are exceeded, are required to communicate the results to the public in the form of notices and public meetings. To date, CARB has designated nearly 200 compounds as TACs. Additionally, CARB has implemented control measures for a number of compounds that pose high risks and show potential for effective control. The majority of the estimated health risks from TACs can be attributed to relatively few compounds, the most important being particulate matter from diesel-fueled engines (diesel particulate matter or DPM). HEALTH RISK ASSESSMENT NOVEMBER 2022 SANTA ANA AND LIVE OAK WAREHOUSE PROJECT FONTANA, CALIFORNIA P:\ESL2201.25\PRODUCTS\ESL2201.25 HRA_111022.docx «11/10/22» 9 THRESHOLDS OF SIGNIFICANCE Both the State and federal governments have established health-based ambient air quality standards for seven air pollutants. For other air pollutants without defined significance standards, the definition of substantial pollutant concentrations varies. For TACs, “substantial” is taken to mean that the individual health risk exceeds a threshold considered to be a prudent risk management level. The following limits for maximum individual cancer risk (MICR) and noncancer acute and chronic Hazard Index (HI) from project emissions of TACs are considered appropriate for use in determining the health risk for projects in the Basin: • MICR: MICR is the estimated probability of a maximally exposed individual (MEI) contracting cancer as a result of exposure to TACs over a period of 30 years for adults and 9 years for children in residential locations and over a period of 25 years for workers. The MICR calculations include multipathway consideration, when applicable. The cumulative increase in MICR that is the sum of the calculated MICR values for all TACs would be considered significant if it would result in an increased MICR greater than 10 in 1 million (1 x 10-5) at any receptor location. • Chronic HI: Chronic HI is the ratio of the estimated long-term level of exposure to a TAC for a potential MEI to its chronic reference exposure level. The chronic HI calculations include multipathway consideration, when applicable. The project would be considered significant if the cumulative increase in total chronic HI for any target organ system would exceed 1.0 at any receptor location. • Acute HI: Acute HI is the ratio of the estimated maximum 1-hour concentration of a TAC for a potential MEI to its acute reference exposure level. The project would be considered significant if the cumulative increase in total acute HI for any target organ system would exceed 1.0 at any receptor location. The SCAQMD CEQA Air Quality Handbook8 states that emissions of TACs are considered significant if an HRA shows an increased risk of greater than 10 in 1 million. Based on guidance from SCAQMD in the document Health Risk Assessment Guidance for Analyzing Cancer Risks from Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis9, for the purposes of this analysis, the threshold of 10 in 1 million was used as the cancer risk threshold for the proposed project. 8 SCAQMD. 1993. CEQA Air Quality Handbook (currently under revision). 9 SCAQMD. 2003. Health Risk Assessment Guidance for Analyzing Cancer Risks from Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis. August. HEALTH RISK ASSESSMENT NOVEMBER 2022 SANTA ANA AND LIVE OAK WAREHOUSE PROJECT FONTANA, CALIFORNIA P:\ESL2201.25\PRODUCTS\ESL2201.25 HRA_111022.docx «11/10/22» 10 METHODOLOGY The methodology used to estimate health risk impacts is described below. CONSTRUCTION HEALTH RISK ASSESSMENT A construction HRA, which evaluates construction-period health risk to off-site receptors, was performed for the proposed project. To estimate the potential cancer risk associated with construction of the proposed project from equipment exhaust (including DPM), a dispersion model was used to translate an emission rate from the source location to a concentration at the receptor location of interest (i.e., a nearby residence and worksites). Dispersion modeling varies from a simpler, more conservative screening-level analysis to a more complex and refined detailed analysis. This refined assessment was conducted using the CARB exposure methodology with the air dispersion modeling performed using the United States Environmental Protection Agency’s (USEPA) AERMOD air dispersion model. The model provides a detailed estimate of exhaust concentrations based on site and source geometry, source emissions strength, distance from the source to the receptor, and meteorological data. The California Emissions Estimator Model version 2020.4.0 (CalEEMod) computer program was used to calculate emissions from on-site construction equipment and emissions from worker and vehicle trips to the site, which was included in AERMOD. This analysis assumes that construction would begin December 2022 and occur for 18 months. This analysis also assumes the use of Tier 2 construction equipment and that the proposed project would comply with SCAQMD dust control regulations. All other construction details are not yet known; therefore, default assumptions (e.g., construction worker and truck trips and fleet activities) from CalEEMod were used. OPERATIONAL HEALTH RISK ASSESSMENT General Information For the purposes of an HRA, short-term emissions are of concern for analyzing acute health impacts, and long-term emissions are of concern for analyzing chronic and carcinogenic health impacts. A screening-level multipathway assessment has been conducted. This technique was chosen as recommended in the OEHHA Air Toxic Hot Spots Program Risk Assessment Guidelines.10 This HRA has been conducted using three models: the CARB’s California Emissions Factor Model, Version 2021 (EMFAC2021) for vehicle emissions factors and percentages of fuel type within the overall vehicle fleet; AERMOD to determine how the TACs would move through the atmosphere after release from sources both on site and along the truck routes; and the CARB’s HARP model to translate the pollutant concentrations from AERMOD into individual health risks at the nearby sensitive receptor locations. 10 OEHHA. 2015. op cit. HEALTH RISK ASSESSMENT NOVEMBER 2022 SANTA ANA AND LIVE OAK WAREHOUSE PROJECT FONTANA, CALIFORNIA P:\ESL2201.25\PRODUCTS\ESL2201.25 HRA_111022.docx «11/10/22» 11 This HRA includes analyzing the inhalation, dermal soil, mother’s milk, and homegrown produce pathways. This technique was chosen as prescribed in SCAQMD’s AB2588 and Rule 1402 Supplemental Guidelines.11 The OEHHA has determined that long-term exposure to diesel exhaust particulates poses the highest cancer risk of any TAC it has evaluated. Exposure to diesel exhaust can also have immediate health effects. Diesel exhaust can irritate the eyes, nose, throat, and lungs, and it can cause coughs, headaches, lightheadedness, and nausea. In studies with human volunteers, diesel exhaust particles (also known as DPM) made people with allergies more susceptible to the materials to which they are allergic, such as dust and pollen. Exposure to diesel exhaust also causes inflammation in the lungs, which may aggravate chronic respiratory symptoms and increase the frequency or intensity of asthma attacks. For risk assessment procedures, the OEHHA specifies that the surrogate for whole diesel exhaust is DPM. The conservative nature of this analysis is due primarily to the following three factors: • The CARB-adopted diesel exhaust unit risk factor (URF) of 300 in 1 million per microgram per cubic meter is based on the upper 95th percentile of estimated risk for each of the epidemiological studies used to develop the URF. Therefore, the risk factor is already representative of the conservative risk posed by DPM. • The risk estimates assume sensitive residence receptors would be subject to DPM for 24 hours per day, 350 days per year and worker receptors for 8 hours per day, 350 days per year. As a conservative measure, SCAQMD does not recognize indoor adjustments for residents or workers. However, typical people spend the majority of their time indoors versus remaining outdoors for 24 hours per day, 350 days per year.12 Therefore, the actual exposure any person would experience would be less than considered in this analysis. This results in much lower actual health risk levels than presented in this analysis. • The exposure to DPM is assumed to be constant for the given period analyzed (i.e., 30 years). However, emissions from DPM are expected to substantially decrease in the future with the implementation of standard regulatory requirements and technological advancement to reduce DPM. Therefore, the health risk levels from these future trucks would be less than presented in this analysis. Improvements over the last 40 years to diesel fuel and diesel engines have resulted in lower emissions of some of these TACs.13 These improvements resulted in a 75 percent reduction in 11 SCAQMD. 2018. op. cit. 12 In May 1991, the CARB Research Division, in association with the University of California, Berkeley, published research findings titled Activity Patterns of California Residents. The findings of that study indicate that, on average, adults and adolescents in California spent almost 15 hours per day inside their homes and 6 hours in other indoor locations, for a total of 21 hours (87 percent of the day). About 2 hours per day were spent in transit, and just over 1 hour per day was spent in outdoor locations. 13 United States Environmental Protection Agency (USEPA). n.d. Learn About Impacts of Diesel Exhaust and the Diesel Emissions Reduction Act (DERA). Website: www.epa.gov/dera/learn-about-impacts-diesel- exhaust-and-diesel-emissions-reduction-act-dera (accessed June 2022). HEALTH RISK ASSESSMENT NOVEMBER 2022 SANTA ANA AND LIVE OAK WAREHOUSE PROJECT FONTANA, CALIFORNIA P:\ESL2201.25\PRODUCTS\ESL2201.25 HRA_111022.docx «11/10/22» 12 particle emissions from diesel-powered trucks and other equipment in 2010 and an 85 percent reduction in 2020 compared to 2000 levels.14 These improvements are anticipated to continue into the foreseeable future. Electric trucks are also being phased in and, once in use, would eliminate the emissions of DPM associated with truck travel. Emission Sources The first step of an HRA is to characterize the project-related emissions of TACs. The proposed project would generate approximately 547 average daily trips, including 397 passenger vehicle trips, 25 two-axle truck trips, 31 three-axle truck trips, and 94 four-axle truck trips. It is assumed that the truck trips would travel approximately 40 miles per trip. The trucks would access the site by Santa Ana Avenue. The proposed project would provide 46 dock doors; as the project would contain multiple loading docks, off-site queuing of trucks is not anticipated. While the TAC emissions from gasoline-powered vehicles have a small health effect compared to DPM, this HRA includes all the traffic information described and both gasoline- and diesel-powered vehicle emissions. For the diesel exhaust emissions, it is sufficient to only consider the DPM (particulate matter less than 10 microns in diameter [PM10]) portion of the exhaust; all the TACs for the gasoline exhaust emissions are contained in the reactive organic gas (ROG) emissions. Using speciation data from CARB, the emission rates of the TAC components are derived from the total ROG emissions. Project trucks would operate in two modes: stationary idling and moving on and off the site. The emissions from trucks while idling result in a much higher concentration of TACs at nearby sensitive receptors compared to the emissions from moving trucks. This is due to the dispersion of emissions that occurs with distance and with travel of the vehicle. For this HRA, the truck travel emissions were modeled as a series of volume sources along the on-site driveway, along North American Way going east and west of the site driveway. LSA assumed vehicles traveling on site would maneuver slowly, averaging approximately 5–15 miles per hour (mph), and that vehicles traveling on roadways would average 5–55 mph. EMFAC2021 was used to determine the emissions factors of idling and operating diesel trucks to determine the total emissions of PM10. Although the TAC of concern from diesel trucks is DPM, EMFAC2021 does not include emissions factors for this TAC. DPM is a component of the overall exhaust from the project-related trucks. This HRA conservatively assumes the DPM emissions to be equal to the PM10 emissions when actually the DPM is only a portion of the overall PM10 in the truck exhaust. While it is expected that the truck emissions rate will continue to reduce over time, an HRA only allows for a single emission rate to represent the entire 25- or 30-year exposure period. The use of emissions factors for the earliest year the proposed project could start operations (2022) was selected for this HRA to be conservative. For instance, based on operations starting in 2022, using emissions factors for a 2027 vehicle fleet (the midpoint of the 9-year exposure period) or using emissions for a 2038 vehicle fleet (the midpoint of the 30-year exposure period) could be used; however, either of these would be less conservative. 14 OEHHA. 2001. Health Effects of Diesel Exhaust. May 21, 2001. Website: oehha.ca.gov/air/health-effects- diesel-exhaust, (accessed June 2022). HEALTH RISK ASSESSMENT NOVEMBER 2022 SANTA ANA AND LIVE OAK WAREHOUSE PROJECT FONTANA, CALIFORNIA P:\ESL2201.25\PRODUCTS\ESL2201.25 HRA_111022.docx «11/10/22» 13 HEALTH RISK IMPACTS The following section describes the potential impacts on sensitive and worker receptors from construction and operation of the proposed project. As identified above, the closest sensitive receptor includes the single-family residential use at 14790 Santa Ana Avenue approximately 100 ft away from the project boundary line. The HRA analysis and results are presented below; data outputs are attached. CONSTRUCTION HEALTH RISK ASSESSMENT A construction HRA, which evaluates construction-period health risk to off-site receptors, was performed for the proposed project. Table A, below, identifies the results of the analysis assuming the use of Tier 2 construction equipment, at the MEI, which is the nearest sensitive receptor. Model snap shots of the sources are attached. Table A: Health Risks from Project Construction to Off-Site Receptors using Tier 2 Location Carcinogenic Inhalation Health Risk in 1 Million Chronic Inhalation Hazard Index Acute Inhalation Hazard Index Worker Receptor Risk 0.72 0.040 0.000 Sensitive Receptor Risk 17.0 0.02 0.000 SCAQMD Significance Threshold 10 in 1 million 1.0 1.0 Significant? Yes No No Source: Compiled by LSA (June 2022). SCAQMD = South Coast Air Quality Management District As shown in Table A, the maximum cancer risk for the sensitive receptor MEI would be 17 in 1 million, which would exceed the SCAQMD cancer risk threshold of 10 in 1 million. The worker receptor risk would be lower at 0.72 in 1 million and would not exceed the threshold. The total chronic hazard index would be 0.040 for the worker receptor MEI and 0.02 for the sensitive receptor MEI, which is below the threshold of 1.0. In addition, the total acute hazard index would be nominal (0.000), which would also not exceed the threshold of 1.0. Implementation of a best management practice, where the project contractor ensures all off-road diesel-powered construction equipment of 50 horsepower or more used for project construction, at a minimum meets the California Air Resources Board (CARB) Tier 2 emissions standards or the equivalent and is equipped with Level 3 diesel particulate filters, would reduce potential health risks. Table B identifies the results of the analysis with implementation of this best management practice. HEALTH RISK ASSESSMENT NOVEMBER 2022 SANTA ANA AND LIVE OAK WAREHOUSE PROJECT FONTANA, CALIFORNIA P:\ESL2201.25\PRODUCTS\ESL2201.25 HRA_111022.docx «11/10/22» 14 Table B: Health Risks from Project Construction with Best Management Practice Location Carcinogenic Inhalation Health Risk in 1 Million Chronic Inhalation Hazard Index Acute Inhalation Hazard Index Worker Receptor Risk 0.15 0.009 0.000 Sensitive Receptor Risk 3.46 0.004 0.000 SCAQMD Significance Threshold 10 in 1 million 1.0 1.0 Significant? No No No Source: Compiled by LSA (June 2022). SCAQMD = South Coast Air Quality Management District As shown in Table B, the cancer risk at the sensitive receptor MEI would be 3.46 in one million, which would not exceed the SCAQMD cancer risk threshold of 10 in one million. Therefore, with implementation of construction best management practices, construction of the proposed project would not exceed SCAQMD thresholds and would not expose nearby sensitive receptors to substantial pollutant concentrations. No significant health risk would occur from project construction emissions. OPERATIONAL HEALTH RISK ASSESSMENT To determine the potential health risk to people living and working near the proposed project associated with the exhaust of diesel-powered trucks and equipment, an operational HRA was conducted for the proposed project. The carcinogenic and chronic health risks from the proposed project are shown in Table B. The residential risk incorporates both the risk for a child living in a nearby residence for 9 years (the standard period of time for child risk) and an adult living in a nearby residence for 30 years (considered a conservative period of time for an individual to live in any one residence). Table C: Health Risks from Project Operation to Off-Site Receptors Location Carcinogenic Inhalation Health Risk in 1 Million Chronic Inhalation Hazard Index Acute Inhalation Hazard Index Worker Receptor Risk 0.39 0.001 0.000 Sensitive Receptor Risk 1.54 0.000 0.000 SCAQMD Significance Threshold 10.0 in 1 million 1.0 1.0 Significant? No No No Source: Compiled by LSA (June 2022). SCAQMD = South Coast Air Quality Management District As shown in Table C, the maximum cancer risk for the sensitive receptor MEI would be 1.54 in 1 million, less than the threshold of 10 in 1 million, which would not exceed the SCAQMD cancer risk threshold of 10 in 1 million. The worker receptor risk would be lower at 0.39 in 1 million, which would also not exceed the threshold. The total chronic hazard index would be 0.001 for the worker receptor MEI and nominal (0.000) for the sensitive receptor MEI, which is below the threshold of HEALTH RISK ASSESSMENT NOVEMBER 2022 SANTA ANA AND LIVE OAK WAREHOUSE PROJECT FONTANA, CALIFORNIA P:\ESL2201.25\PRODUCTS\ESL2201.25 HRA_111022.docx «11/10/22» 15 1.0. In addition, the total acute hazard index would be nominal (0.000), which would also not exceed the threshold of 1.0. As these results show, all health risk levels to nearby residents from operation- related emissions of TACs would be well below the SCAQMD’s HRA thresholds. No significant health risk would occur from project operation emissions. CONCLUSION As these results show, all health risk levels to nearby residents from project-related emissions of TACs would be well below the SCAQMD’s HRA thresholds. As such, no significant health risk would occur from project-related emissions. The HARP modeling reports and AERMOD information are attached. HEALTH RISK ASSESSMENT NOVEMBER 2022 SANTA ANA AND LIVE OAK WAREHOUSE PROJECT FONTANA, CALIFORNIA P:\ESL2201.25\PRODUCTS\ESL2201.25 HRA_111022.docx «11/10/22» APPENDIX A HRA MODEL OUTPUT 6/23/22 (P:\ESL2201.25\PRODUCTS\Model Snapshots.docx) 1 Project Location/Site Plan 6/23/22 (P:\ESL2201.25\PRODUCTS\Model Snapshots.docx) 2 Sensitive Receptors Worker Receptors 6/23/22 (P:\ESL2201.25\PRODUCTS\Model Snapshots.docx) 3 Construction Cancer Risk – Sensitive Receptors Construction Chronic Hazard Index – Sensitive Receptors 6/23/22 (P:\ESL2201.25\PRODUCTS\Model Snapshots.docx) 4 Construction Cancer Risk – Worker Receptors Construction Chronic Hazard Index – Worker Receptors 6/23/22 (P:\ESL2201.25\PRODUCTS\Model Snapshots.docx) 5 Operational Cancer Risk – Sensitive Receptors Operational Chronic Hazard Index – Sensitive Receptors 6/23/22 (P:\ESL2201.25\PRODUCTS\Model Snapshots.docx) 6 Operational Acute Hazard Index – Sensitive Receptors Operational Cancer Risk – Worker Receptors 6/23/22 (P:\ESL2201.25\PRODUCTS\Model Snapshots.docx) 7 Operational Chronic Hazard Index – Worker Receptors Operational Acute Hazard Index – Worker Receptors 6/23/22 (P:\ESL2201.25\PRODUCTS\Model Snapshots.docx) 8 Heath Risk Assessment Summary Construction Worker Receptor Sensitive Receptor Yard Receptor Cancer Risk (in a Million) 0.721 3.95 17 Chronic HI 0.0397 0.0057 0.02 Acute HI 0 0 0 Construction (T2L3) Worker Receptor Sensitive Receptor Yard Receptor Cancer Risk (in a Million) 0.15 0.791 3.46 Chronic HI 8.50E-03 9.92E-04 4.26E-03 Acute HI 0 0 0 Construction (T4) Worker Receptor Sensitive Receptor Yard Receptor Cancer Risk (in a Million) 0.0648 0.346 1.48 Chronic HI 3.69E-03 4.31E-04 1.85E-03 Acute HI 0 0 0 Operational Worker Receptor Sensitive Receptor Yard Receptor Cancer Risk (in a Million) 0.39 1.54 1.09 Chronic HI 1.28E-03 4.66E-04 3.24E-04 Acute HI 1.41E-04 5.09E-05 2.43E-05