HomeMy WebLinkAboutStaff Report 5.A 01/28/2019 Attachment 06-08ATTACHMENT 8
RESPONSE TO COMMENTS ON
SAFEWAY FUEL CENTER PUBLIC DRAFT IS/MND
This document provides a response to comments received on the Public Draft Initial
Study/Mitigated Negative Declaration (IS/MND) that was prepared for the Safeway Fuel Center
Project. In accordance with the California Environmental Quality Act (CEQA) of 1970 (as
amended) (California Public Resources Code 21000 et. seq.), the Public Draft IS/MND was
circulated for a 30 -day public review and comment period from April 5, 2018 to May 4, 2018.
Notice of availability, notice of intent to adopt and notice of public hearing for the IS/MND was
posted with the Sonoma County Clerk, mailed to property owners within 500 feet of the project
site, published in the Argus Courier, posted to the City's website and submitted to the State
Clearinghouse for distribution to State Agencies.
COMMENTS RECEIVED
A number of written comment letters were received during the public review and comment period
for the IS/MND. Comments were also received orally from the general public and the Planning
Commissioners at the May 8, 2018 Planning Commission public hearing. The individuals providing
comments included neighbors, community members, school personnel and parents of students.
Agencies, organizations and individuals that submitted written or oral comments on the IS/MND
are listed below;
Agencies
1. California State Clearinghouse
2. California Department of Toxic Substances Control
3. California Department of Transportation
Local Entities & Individuals
1. Petaluma City Schools (Chris Thomas, Chief Business Official)
a. Environmental Science Associates (ESA) Memo (Heidi Rous and Tina Su)
2. McDowell Elementary School (Lauri C. Anderson, Principal)
3. Nancy Manchester
4. Kathleen Coon
5. Melodic Kee
6. Michael and Leone Gannon
7. Chris Thomas
8. Jean Bisel
9. Talia Page
10. Laura Gavre
11. Erin Chmielewski
12. Maureen Maguire
13. Robin Aquino
14. Jennifer Benedetti
15. Corinne Reif
16. Laura Steinfels
17. Jennifer Stock
18. Linda Hartrich
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19. Rebecca Hachmyer
20. Stacey Earl
21. Christy Giambastiani
22. Betsy Boyle
23. Public Speakers from Planning Commission Hearing (May 8, 2018):
a. Lauri Anderson
b.
Chris Thomas
c.
Genie Praetzel
d.
Matthew Pederson
e.
Dale Wannen
f.
Elizabeth Ambrosi
g.
Carol Waxman
h.
Frances Frazier
i.
Adriann Saslow
j.
Horst Steinfels
k.
Oliver Steinfels
1. Rebecca Hachmeyer
m. Alexander Saslow
n. Maureen Rudder
o. Tim Harvey
p. Ginee Harvey
q. Anna Simson
r. Maribel Baron
s. Makenna Pearson
24. McDowell Adult Students, Parents, and Community Members (petition dated 2/27/14,
403 signatories, submitted 5/8/18)
25. Parents of children who attend educational programs at McDowell School (petition dated
5/7/18, 116 signatories)
SUMMARY OF COMMENTS AND RESPONSES
The responses to public comments have been prepared in consultation with Illingworth & Rodkin,
CHS Consulting Group, and the Bay Area Air Quality Management District (BAAQMD).
Information in this Responses to Comments document is based on the references to the IS/MND
and the following documents:
• Technical Memorandum, Petaluma Safeway Fuel Center: Pedestrian Counts and Safety
Analysis, prepared by CHS Consulting Group, June 6,2018.
• Memo, Safeway Fuel Center Health Risk Assessment, Response to Comment Made by
ESA, prepared by Illingworth & Rodkin, May 8, 2018.
• Memo, Safeway Fuel Center Health Risk Assessment, Response to Follow -Up Questions,
prepared by Illingworth & Rodkin, June 6, 2018.
• BAAQMD Permit Application for Safeway Fuel Center, submitted by Safeway, Inc.,
July 15, 2013.
• BAAQMD, Evaluation Report, Application #405215, Safeway Fuel Center #3011, Facility
ID #200026, S. McDowell Blvd. & Maria Drive, Petaluma CA 94954, 2013.
• BAAQMD, Public Notice for Permit Application #405215, Gasoline Dispensing Facility,
Safeway Fuel Center #3011, S. McDowell Blvd. & Maria Drive, Petaluma CA 94954, dated
August 22, 2013.
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• BAAQMD, Authority to Construct for Permit Application #405215, Facility ID #200026,
Safeway Fuel Center #3011, S. McDowell Blvd. & Maria Drive, Petaluma CA 94954, dated
October 10, 2013.
• BAAQMD, Authority to Construct Extension Application, submitted by Safeway, Inc.,
October 6, 2017.
• BAAQMD, Authority to Construct for Permit Application #405215, (AC Extension),
Facility ID #200026, Safeway Fuel Center #3011, S. McDowell Blvd. & Maria Drive,
Petaluma CA 94954, dated November 9, 2017.
California State Clearinghouse
The letter from this agency acknowledges that the City of Petaluma complied with the State
Clearinghouse review requirements for review of draft environmental documents. The State
Clearinghouse also forwarded a copy of the comment letter from the California Department of
Transportation. No response is necessary.
California Department of Toxic Substances Control (DTSC)
The letter from DTSC requests that a copy of the Phase I Environmental Site Assessment (ESA) be
provided to the DTSC. The Phase I ESA was subsequently provided to the DTSC. A follow up
letter states that the DTSC received the Phase I Environmental Site Assessment for the project and
that the DTSC has no further comments at this time. No further response is necessary.
California Department of Transportation(Caltrans)
The letter from Caltrans requests that copies of the Traffic Study prepared by TJKM Transportation
Consultants and the Technical Memorandum prepared by CHS Consulting Group be submitted to
Caltrans for review. These two documents were provided to Caltrans upon request, and no further
response from Caltrans has been received to date.
The letter also states that the project should be conditioned to contribute fair share traffic impact
fees toward future improvements for the U.S. 101/East Washington Street interchange. As stated in
the IS/MND, and confirmed by CHS Consulting Group in their Technical Memorandum dated
March 16, 2018, the proposed project would not result in any significant impacts to the
transportation network, and no mitigation is required.
Improvements at the East Washington Street/U.S. 101 interchange (northbound and southbound
on- and off -ramps) have already been completed. The signal timing changes at the East Washington
Street/U.S. 101 interchange (northbound and southbound ramps) and the East Washington
Street/North McDowell Boulevard intersection, have also been completed.
As stated on page 55 of the IS/MND, as a standard condition of approval, the applicant shall pay
all development impact fees. These fees will contribute to improvements to City roadways and
assure that the project's fair share of increased traffic and use of the circulation system has been
accounted for. As described in the IS/MND, the payment of impact fees in addition to proposed site
design measures will ensure the project's impact to traffic and circulation will be less than
significant, and no other improvements or fees specific to Caltrans' facilities are required.
Master Response to Comments on Health Risk Exposure
This master response has been prepared to address issues that were raised by multiple commenters
regarding the health risks associated with the proposed Safeway Fuel Center. A number of
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commenters expressed concerns regarding the proximity of the proposed Safeway Fuel Center to
the surrounding neighborhood and the public facilities located at the McDowell Elementary School
Campus, including the Elementary School (421 S. McDowell, Petaluma, Ca 94954), the North Bay
Children's Center (405 S. McDowell, Petaluma, CA 94954), Petaluma Adult School (classes held
at McDowell Elementary). The commenters assert that operation of the proposed project would
cause a significant environmental impact to residents and students, staff, and parents of the
McDowell Elementary School and North Bay Children's Center.
Bay Area Air Quality Management District
As stated in Section 3.3 Air Quality of the IS/MND, the Bay Area Air Quality Management District
(BAAQMD) is charged with managing air quality for the region, including the City of Petaluma.
The BAAQMD has established air quality thresholds of significance for carbon monoxide (CO),
ozone precursors (ROG and NOx) and particulate matter (PMI 0 and PM2.5) from construction and
operation of proposed projects. These thresholds are identified in the BAAQMD CEQA Air Quality
Guidelines established in May 2010, and most recently updated in May 2017. As concluded on
pages 18-19 of the IS/MND, and as shown on Tables 3 and 4 therein, none of the pollutant
concentrations generated during construction or operation of the proposed project would result in
emissions that exceed air quality thresholds established by the BAAQMD.
The BAAQMD also regulates stationary sources of air pollution such as factories, industrial sites,
and gasoline stations. In addition to the Guidelines, BAAQMD has established rules in order to
ensure that stationary source emitters conform to air quality regulations. The Safeway Fuel Center
Project is subject to several of the rules established by BAAQMD including Regulation 8, Rule 7
to control for the emission of reactive organic compound (ROG) from a stationary source emitter
due to fuel dispensing onsite, and Regulation 7 which controls for odors. In accordance with
BAAQMD regulation (Regulation 2, Rule 2), the proposed project is subject to an Authority to
Construct permit for the gasoline dispensing facility, which is a pre -construction permit that is
issued before equipment is installed.
Safeway, Inc. submitted a permit application to BAAQMD for the proposed Safeway Fuel Center
on July 15, 2013 (Application #405215), including documentation of proposed measures for
compliance with the above referenced BAAQMD rules and regulations. In BAAQMD's review of
Safeway's application, it was determined that the Best Available Control Technology requirement
of BAAQMD's Regulation 2-2-301 was triggered. The triggering of this regulation requires Best
Available Control Technology for Gasoline Dispensing Facilities, which considers the use of
California Air Resources Board (CARE) -certified Phase -I and Phase -II vapor recovery equipment.
BAAQMD concluded that the Safeway Fuel Center would best meet the - requirement of this
regulation by using CNI enhanced vapor recovery (EVR) Phase I equipment and VST Balance EVR
Phase II equipment with the Veeder-Root Vapor Polisher and Veeder-Root ISD controls. These
two systems are certified by CARB under Executive Orders VR -104 and VR -204 respectively.
As part of the Authority to Construct application review process, BAAQMD performed a Toxic
Risk Screening Analysis, as specified in Regulation 2-5, Table 2-5-1. For a Gasoline Dispensing
Facility that meets the best available control technology for toxics requirement, it must also achieve
a toxic risk screening level of less than ten in one million. The BAAQMD concluded that the
proposed project meets the screening level with a cap on throughput of 25.71 million gallons.
annually. As such, the BAAQMD determined that the Safeway Fuel Center would be conditioned
to 25.71 million gallons per year, which would not exceed Health Risk standards per the
BAAQMD's Risk Management Policy.
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On August 2013, and in accordance with state law (California Health & Safety Code and District's
Regulation 2-1-412), BAAQMD distributed Public Notice to the parents or guardians of students
enrolled at McDowell Elementary School and all residences and businesses located within 1,000
feet of the proposed Safeway Fuel Center. The Public Notice stated that a permit application for the
Safeway Fuel Center had been filed with BAAQMD. Individuals and businesses were alerted that
there was a 30 -day period for public response to the proposal. The public comment period on
BAAQMD's notice ended on September 23, 2013. During the public comment period, the
BAAQMD received the following responses: 1
• Two emails
• Six voice mails
• One letter from a nearby day care center accompanied by 31 signed form letters
• One petition signed by 21 individuals
One commenter was in favor of the new gas station and the balance were opposed to the project.
The primary concerns were increased traffic, with its associated impacts on air quality, safety, and
parking. Many commenters were also concerned about the increased gasoline vapor emissions and
the proposed gas station's proximity to the McDowell Elementary School and North Bay Children's
Center (preschool). None of the commenters identified any potential compliance issues with
BAAQMD regulations or any deficiency or error in BAAQMD's evaluation of the project.
BAAQMD responded to the comments received during the public comment period by email,
voicemail, or U.S. mail.
After consideration and responding to the comments received during the public comment period,
BAAQMD issued an Authority to Construct permit for the Safeway Fuel Center on October 10,
2013, as a ministerial action under Regulation 2-1-311. BAAQMD conditioned the Safeway Fuel
Center to a gasoline throughput not to exceed 25.71 million gallons of fuel per year. Issuance of
this permit confirms that BAAQMD reviewed proposed fuel dispensing equipment, considered the
source emitter, recommended specific equipment, and determined that the use of that equipment
would comply with all air quality rules and regulations.
An extension for the Authority to Construct permit was filed by Safeway, Inc. on October 6, 2017.
On November 9, 2017, BAAQMD granted the extension for the Authority to Construct permit; the
Authority to Construct permit issued by BAAQMD will expire on November 9, 2019.
Sensitive Receptors
This discussion regarding facilities at the McDowell Elementary School Campus is intended to
bolster the description contained in the IS/MND. As stated on page 19 of the IS/MND, the nearest
sensitive receptors in proximity to the project site, and their distances from the project's limits of
work, include the North Bay Children's Center located at the northeast corner of South McDowell
and Maria Drive (60 feet), McDowell Elementary School (475 feet) and associated recreational
playfield (60 feet), and residences along South McDowell Boulevard (80 feet).
McDowell Elementary School is located at 421 South McDowell Boulevard. The outdoor
recreational school facilities include a ball field; playground with adjacent grass area; and an asphalt
blacktop area with basketball courts, tetherball courts, and other outdoor recreational games. The
1 Duncan Campbell, BAAQMD, Email correspondence, May 25, 2018.
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school also contains multiple buildings, an asphalt parking lot, and raised garden beds. In addition
to providing education for students in Early Transitional Kindergarten (4 years old) through sixth
grade, the school supports the McDowell Family Resource Center, which offers classes through the
Petaluma Adult School. Some of the classes offered include English as a Second Language,
Computer Applications, Parent Education, and Health Care Education. Additionally, the school
provides after-school care on its campus for McDowell and McKinley students from dismissal until
6:00 pm, in partnership with the Boys & Girls Club of Central Sonoma County.
The North Bay Children's Center is located at 405 South McDowell Boulevard. The facility offers
a half day preschool for children ages 3 to 5, and is open 8:00 am to 3:00 pm, Monday through
Friday. The North Bay Children's Center includes three buildings, an outdoor playground, an
asphalt play area, and raised garden boxes.
The McDowell Elementary School Campus is considered a sensitive receptor location since it
contains people (children and adults) that have an increased sensitivity to air pollution. Schools,
parks, playgrounds, day care centers, preschools and residential homes are all considered sensitive
receptor locations. The school facility and nearby residential units were evaluated as sensitive
receptors by BAAQMD and by the project level Health Risk Assessment, as disclosed in the
IS/MND.
Health Risk Assessment
A number of individuals submitted comments seeking clarification on the Health Risk Assessment
(IRA), primarily with regards to the established thresholds for the creation of a Health Risk,
methodology used in the HRA, and the health risks for each person (student, teacher, resident) from
implementation of the project.
One commenter, Petaluma City Schools, submitted a peer review, performed by ESA, on the HRA
that was prepared by Illingworth & Rodkin. ESA's peer review asserts that there were errors and
omissions in Illingworth & Rodkin's HRA prepared for the project, and that these errors prevented
a proper analysis of the project's impacts on students, staff, and teachers of the schools. ESA's peer
review asserts that the HRA is noncompliant with industry standards, makes inaccurate and
misleading assumptions, and that the toxic air contaminant (TAC) impact is likely a significant
environmental impact.
The following discussion clarifies the thresholds and methodology used in the HRA prepared by
Illingworth & Rodkin, elaborates on the health risks to sensitive receptors from the proposed
project, and addresses specific comments and questions on the HRA raised by the commenters.
BAAQMD Thresholds offSlicance for Health Risk Exposure
The HRA prepared by Illingworth & Rodkin relies on the BAAQMD-established thresholds of
significance for local community risk and hazard impacts, which apply to the siting of a new
stationary source emitter (gasoline station). These thresholds are identified in the BAAQMD's
CEQA Air Quality Guidelines established in May 2010, and most recently updated in May 2017.
As detailed in the"BAAQMD CEQA Guidelines (pages 2-4 and 2-5), local community risk and
hazard impacts are associated with TACs and PM2.5 because emissions of these pollutants can
have significant health impacts at the local level. If emissions of TACs or fine particulate matter
with an aerodynamic resistance diameter of 2.5 micrometers or less (PM2.5) exceed any of the
ow,
ATTACHMENT 8
thresholds of significance listed below, the proposed project would result in apotentially significant
health risk impact:
Non-compliance with a qualified risk reduction plan; or
An excess cancer risk level of more than 10 in one million, or a non -cancer (i.e., chronic or
acute) hazard index greater than 1.0 would be a cumulatively considerable contribution; or
An incremental increase of greater than 0.3 micrograms per cubic meter (µg/m3) annual
average PM2.5 would be a cumulatively considerable contribution.
As described on page 2-5 of the BAAQMD CEQA Guidelines, a project would have a cumulative
considerable impact if the aggregate total of all past, present, and foreseeable future sources within
a 1,000 foot radius from the fence line of a stationary source emitter plus the contribution from the
project, exceeds the following:
Non-compliance with a qualified risk reduction plan; or
An excess cancer risk levels of more than 100 in one million or a chronic non -cancer hazard
index (from all local sources) greater than 10.0; or
• 0.8 µg/m3 annual average PM2.5.
Health Risk AssessmentMethodolo
The HRA evaluated the exposure of sensitive receptors to substantial air quality pollutants based
on an annual fuel throughput of approximately 8.5 million gallons, which is approximately one-
third of the throughput conditioned by the BAAQMD. The throughput was based on Safeway's
anticipated maximum demand, which is derived from market research and data from other operating
Safeway Fuel Centers.
As stated on page 2 of the HRA, emissions of toxic pollutants potentially associated with the project
were estimated using various emissions models. Concentrations of these pollutants in the ambient
air were estimated using the U.S. EPA ISCST3 dispersion model. The ISCST3 dispersion model is
a BAAQMD-recommended model for use in modeling analysis of these types of emission activities
for CEQA projects. Health risks were evaluated for a hypothetical maximum exposed individual
(MEI) located at the maximum impact of the sensitive receptor. The hypothetical MEI is an
individual assumed to be located where the highest concentrations of air pollutants associated with
Project emissions are predicted to occur, based on air dispersion modeling. As described in the
LIRA, increased cancer risks were calculated using the modeled annual concentrations and
BAAQMD recommended risk assessment methods for an infant exposure (3rd trimester through 2
years of age), student exposure (9 years) and for adult exposure.
As stated on page 3 of the HRA, the State of California Office of Environmental Health Hazard
Assessment (OEHHA) and CARB develop recommended methods for conducting health risk
assessments. The most recent OEHHA risk assessment guidelines were published in February of
2015. These guidelines incorporate substantial changes designed to provide for enhanced protection
of children, as required by State law. CARB has provided additional guidance on implementing
OEHHA's recommended methods. The LIRA for this project used the 2015 OEHHA risk
assessment guidelines and CAR13 guidance. BAAQMD has adopted recommended procedures for
applying the 2015 OEHHA guidelines as part of Regulation 2, Rule 5: New Source Review of Toxic
Air Contaminants. Exposure parameters from the OEHHA guidelines and the recent BAAQMD
HRA Guidelines were used in the HRA evaluation.
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Breathing Rate Factor
The HRA followed BAAQMD Air Toxics New Source Review (NSR) Program Health Risk
Assessment (HRA) Guidelines (December 2016) in evaluating health impacts at sensitive receptors
(see page 3 of HRA). The commenter is correct in that BAAQMD HRA guidance (section 2.2) for
gasoline dispensing facilities specifies using older 2003 & 2009 OEHHA risk assessment guidance.
For student (child) exposure, the only difference between the current BAAQMD guidance and the
previous 2003 & 2009 OEHHA guidance is in the value used for a child breathing rate. The current
BAAQMD guidance specifies a child breathing rate of 572 L/kg-day while the 2003 OEHHA
guidance specifies a breathing rate of 581 L/kg-day.
The HRA focused on identifying the maximum health impacts that would occur from
implementation of the project, both during construction and operation. The maximum health
impacts were identified for a child located at the North Bay Children's Center, as opposed to an
adult working at the school (teacher) or an adult or child residing in the adjacent neighborhood. An
adult exposure would occur for a longer duration (30 years instead of 9 years) at a lower age
sensitivity factor (ASF =1 for adult and 3 for a child/student) and at a lower breathing rate (261
L/kg for an adult instead of 572 L/lcg for a child). Thus, the teacher cancer risk would be below
established thresholds, 70% that of a student and similarly less than significant.
The HRA used a breathing rate of 572 L/kg for a child (see Table 1 on page 5 of HRA). In their
memo dated May 8, 2018, Illingworth & Rodkin calculated health risk assuming a breathing rate
of 581 L/kg-day for a child. Illingworth & Rodkin determined that the school child cancer risk from
benzene emissions from the proposed gasoline dispensing facility would increase by 0.01 in one
million when using the 2003 OEHHA breathing rate of 581 L/kg-day compared to the current
BAAQMD guidance. That is, the contribution to increased cancer risk would change from 0.39 in
one million (BAAQMD Guidelines 2016) to 0.40 in one million (2003 & 2009 OEHHA guidance).
The change in cancer risk from this adjustment in the child breathing rate is negligible and impacts
remain well below the ten in one million threshold. Thus, applying OEHHA's breathing rate does
not change the conclusions of the HRA, nor alter any of the conclusions presented in the IS/MND.
Release Height Factor
Regarding construction -related health risk impacts, there have been various methods applied to
address dispersion modeling of construction sites. The HRA (page 8) used a release height of 6
meters (20 feet) to reflect the elevated exhaust stacks of equipment plus the plume rise associated
with the exhaust momentum and thermal buoyancy. The use of a 6 -meter release height is consistent
with release heights used by the CARB when modeling diesel particulate matter (DPM) health risk
impacts from construction activities. In describing the methodology used for modeling of DPM
emissions from area sources, CARB states "Sensitivity studies have shown that there is an initial
plume rise from the equipment due to upward buoyancy and momentum. The release heights of
these area sources were determined to be 5 — 10 meters depending on equipment type during
operation times." Thus, use of a 6 -meter area source release height is considered appropriate and
consistent with CARB regulatory modeling.
Regarding release heights for passenger truck and light-duty vehicles, for modeling exhaust and
fugitive PM2.5 dust emissions from vehicles on nearby roads, the emission release height for heavy-
duty vehicles (trucks) was 3.4 meters (11 feet) and the release height for light-duty vehicles was
1.3 meters (4.3 feet), as detailed on page 13 of the HRA. These values are based on release heights
recommended by the US Environmental Protection Agency for use in modeling vehicle PM2.5
emissions and are representative of the release heights from the mix of different types of trucks and
ATTACHMENT 8
other vehicles that comprise the general categories of heavy-duty and light-duty vehicles used in
construction.
Receptor Height Factor
The I -IIIA used a receptor height of 1.5 meters for the nearby residences and a receptor height of
1.0 meter for children at the daycare and school areas. While the BAAQMD's Recommended
Methods for Screening and Modeling Local Risks and Hazards (May 2012) states that "the default
value is assumed to be 0.0 in (i.e., ground -level receptors), the user may enter 1.5 meter to represent
the height of an average adult." That is, use of a representative breathing height of a representative
individual is appropriate for use in calculating health risks. In this case, as used in the HRA, an
average breathing height of 1.5 meters for an adult is acceptable. For a child, use of 1.0 -meter
breathing height is a reasonable assumption for a child sitting or standing in the school area. It
would be unreasonable to assume that the children at the school were at a breathing height of 0.0
meters (i.e., lying down on the floor).
In their memo dated May 8, 2018, Illingworth & Rodkin calculated health risk assuming a 0.0 -
meter breathing height. Use of a 0.0 -meter receptor height instead of a 1.0 -meter receptor height
would result in benzene concentration being increased by a small amount (i.e., 0.0002 micrograms
per cubic meter), such that the computed cancer risk would not change. Therefore, the result of
under this scenario (throughput of 25.71 million gallons per year, with a child receptor height of
0.0 meters) as opposed to the previously calculated 1.0 -meter receptor height, does not change the
conclusions of the HRA, nor alter any of the conclusions presented in the IS/MND.
Throughput Volume
In their memo dated May 8, 2018, Illingworth & Rodkin estimated health risks assuming a
throughput of 25.71 million gallons per year, the amount conditioned by the BAAQMD, as opposed
to the 8.5 million gallons per year Safeway anticipates using and which was analyzed in the HRA.
Under this scenario (throughout of 25.71 million gallons per year), the operational risks at the
school would increase by a factor of 3 from 0.69 chances per million to 2.04 chances per million
such that the overall excess cancer risk, including project construction (5.8 per on million), would
be 7.9 chances per million. This remains below the excess cancer risk of 10 per one million
threshold and would similarly have a less than significant impact. This corroborates the conclusion
of BAAQMD's Toxic Risk Screening Analysis that was conducted as part of the Authority to
Construct Permit review, which determined that operation of a gasoline station with an annual
throughput of 25.71 million gallons would not pose a health risk to the community. Even with a
throughput of up to 25.71 million gallons per year, the conclusions of the HRA would not change.
Therefore, the conclusions related to health risk as presented in the IS/MND, that the proposed
gasoline station would not result in health risk impacts, would not be altered.
Methodology Summar
In summary, Illingworth & Rodkin appropriately performed the Health Risk Assessment in
accordance with industry standards and acceptable practices and in line with guidance provided by
regulatory agencies including BAAQMD, OEEHHA, and CARB. In response to comments
received, Illingworth & Rodkin performed additional modeling that incorporated suggested
adjustments to the methodology, as suggested by ESA's peer review letter, including: a slightly
higher child breathing rate, a child receptor height of 0.0 meters, and a throughput of 25.71 million
gallons per year. Even with the adjustments to the methodology as suggested by ESA's peer review
comment letter, the resulting health risk level remain below established thresholds and air quality
impacts are therefore considered to be less than significant.
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Community Health Risk Summary
The discussion below summarizes information contained in the HRA to clarify existing health risks
without the project, new health risks introduced by the project, and why the health risks are
considered less than significant under CEQA. The thresholds for health risk, at both the individual
and cumulative level are described above under "BAAQMD Thresholds of Significance for Health
Risk Exposure."
The HRA evaluated the project's potential to increase health risks to nearby sensitive receptors
from construction and operation of the project. For the short-term exposures associated with
construction, a one-year exposure and higher exposure factors (i.e., age sensitivity factors and
breathing rate for infants or children) were used for the health risk calculation.
Table 2 in the HRA (page 9) identifies the exposure risks associated with construction activities for
the maximally exposed individual (MEI), which consists of a child at the North Bay Children's
Center (preschool) and an infant and adult inhabiting a residence along South McDowell Boulevard
south of Maria Drive. All other nearby sensitive receptors would be exposed to health risks below
those presented in Table 2, and are therefore not discussed in the HRA. Results in the HRA
predicted excess cancer risks, annual PM2.5 concentrations, and the Hazard Index to be below the
BAAQMD significance thresholds for each sensitive receptor. Therefore, as presented in the
IS/MND, the project would have a less than significant impact with respect to community health
risks caused by construction activities of the Safeway Fuel Center project.
Operational community risk impacts identified in the HRA were based on traffic generated by the
proposed project (traffic traveling to/from project site, traffic idling at project site, truck traffic
accessing the site for importing fuel) and evaporative emissions from gasoline (vehicle fueling,
transfer and storage of gasoline). Using the maximum modeled diesel particulate matter (DPM),
total organic gases (TOG), and benzene concentrations, individual cancer risks were computed
using the most recent methods recommended by BAAQMD and OEHHA that include nearly
continuous exposures with adjustments for infants and children. Cancer risks were calculated for a
30 -year exposure assuming constant emissions at 2019 levels over the entire 30 -year period for
residences and a 9 -year period for school children (see page 13 of HRA). The risks were identified
as a worst-case exposure for each person (be it a resident, infant or adult, or a child attending
school). The community risk impacts are not additive (e.g., a child who attends North Bay
Children's Center and lives at a residence along South McDowell Boulevard south of Maria Drive
would either be exposed as a resident or a child attending school, not both). This is because each
receptor is modeled under constant exposure for 30 -years in the case of an adult, and 9 -years in the
case of the child.
Table 3 in the HRA (page 14) displays the operational health risk impacts. Table 3 also identifies
the combined health risks from construction activity and operation of the proposed project.
(Additional details regarding the assumptions used in the HRA for the combined health risks from
construction and operation, are presented in Illingworth & Rodkin's Memo dated June 6, 2018 in
Appendix B.) Table 3 of the HRA summarizes impacts from the proposed project (considered a
single -source emitter) at the individual level: Residential (a person inhabiting a residence on South
McDowell Boulevard) and School Child (a child attending the North Bay Children's Center). The
excess cancer risk, maximum annual PM2.5 concentration, and Hazard Index were compared with
z Single source emitters are individually permitted facilities, such as the proposed Safeway Fuel Center.
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BAAQMD's thresholds related to single sources. The results in the HRA (Table 3) predicted excess
cancer risks, annual PM2.5 concentrations, and the Hazard Index to be below the BAAQMD
significance thresholds for each sensitive receptor. Therefore, the project would have a less than
significant impact with respect to community risk caused by construction and operation of the
proposed project.
Additionally, the HRA (Table 3) identifies other sources of TACs or PM2.5 within 1,000 feet of
the project site (cumulative sources 3): traffic on South McDowell and traffic on U.S. 101. (Note:
The health risks associated with these sources demonstrate the existing risks (without the project)
to children at the school. and people inhabiting the residences along South McDowell Boulevard.)
Table 3 also demonstrate the effects of cumulative sources on the identified sensitive receptors
(Residential and School Child) combined with traffic along S. McDowell Boulevard and traffic
along US 101. The excess cancer risk, maximum annual PM2.5 concentration, and Hazard Index
were compared with BAAQMD's thresholds related to cumulative sources. The results in the HRA
(Table 3) predicted cumulative excess cancer risks, annual PM2.5 concentrations, and the Hazard
Index to be below the BAAQMD significance thresholds for each sensitive receptor. Therefore, as
concluded in the IS/MND, the project would have a less than significant impact with respect to
community risk caused by construction and operation of the proposed project, when combined with
other sources of TACs and PM2.5 within 1,000 feet of the project site.
Conclusion
As explained herein, based on the record, the City finds that all potentially significant impacts
related to health risk have been adequately addressed in the IS/MND and this Response to
Comments. As such, none of the conclusions of the air quality discussion in the Draft IS/MND have
changed, and no further analysis is necessary.
Master Response to Comments on Traffic
This master response has been prepared to address issues that were raised by commenters regarding
trip generation and pedestrian safety associated with the proposed Safeway Fuel Center project.
This response relies on information contained in the Traffic Impact Study (TIS) prepared by TJKM
Transportation Consultants for the Safeway Fuel Center in August 13, 2014 and the Technical
Memorandum (TM) updating the Safeway Fuel Center TIS, prepared by CHS Consulting Group in
March 16, 2018; both of these documents were included and referenced in the Public Draft
IS/MND. Additionally, the following is informed by a memo from CHS, dated June 6, 2018,
responding to comments raised during the public review period relating to pedestrian facilities and
safety.
Safeway Fuel Center Trip Generation Methodology
The 2014 TIS and the 2018 Technical Memorandum use the same methodology to estimate trip
generation. The 2014 TIS estimated the Project's trip generation based on the Institute of
Transportation Engineers (ITE) trip rates published in Trip Generation, 9th Edition and empirical
data from field surveys of two existing Bay Area Safeway gas stations in Pleasant Hill and
Campbell. The Pleasant Hill and Campbell gas stations are similar to the proposed project in terms
of size, hours of operation, circulation layout, adjacent grocery store size, and local setting (in a
shopping plaza).4
3 Cumulative source emitters consists of the combination of individually permitted facilities within 1,000 feet along with other area source emissions
such as vehicles exhaust from roadways.
4 Page 12 of the 2014 Traffic Study prepared by TJKM , August 13, 2014.
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The 2018 Traffic Memo (page 3) clarifies that the 2014 TIS did not apply industry standard trip
reductions for commercial uses on or formerly occupying the Project site, nor did the 2014 TIS
apply reductions for internal, pass by, or diverted trips. Definitions of internal, pass -by, and diverted
trips are provided in the 2018 Memo in an effort to demonstrate that the analysis is conservative
and precludes industry standard trip reductions for gas station projects. The Traffic Memo explains
that internal, pass by, and diverted trips could result in the following reduction (but were not
applied):
• 39 percent of the trips to the Fuel Center will be internal trips
• 25 percent of the trips to the Fuel Center will be pass -by trips
• 25 percent of the trips to the Fuel Center will be diverted trips
• 11 percent of the trips to the Fuel Center will be "new" trips
The 2014 TIS and the 2018 Traffic Memo do not take any reductions for internal, pass by, and/or
diverted trips. The trip generation of the proposed Safeway Fuel Center project consists of 210
weekday a.m. peak hour trips, 276 p.m. peak hour trips, and 336 Saturday afternoon peak hour trips,
all of which are considered and analyzed in the level of service analysis of the 2018 TM. While the
internal, pass -by, and diverted vehicle trips were identified in the 2018 TM, these deductions were
not taken in the 2018 analysis.
Pedestrian Access
Commenters expressed concern regarding pedestrian safety at the intersection of South McDowell
and Maria Drive. Presently, this intersection is signalized, contains sidewalk on both sides and
contains pedestrian improvements including striping for pedestrian crosswalk; pedestrian signals
and curb ramps. The crosswalk distance is approximately 50 feet when crossing Maria Drive and
80 feet when crossing S. McDowell Boulevard.
To understand the existing collision and accident frequency at this intersection, CHS reviewed
collision data from the Statewide Integrated Traffic Records System (SWITRS) between 2012 to
2016 for the intersection of South McDowell Boulevard and Maria Drive. Results of collision data
are detailed in CHS's memo dated June 6, 2018.
CHS concluded that pedestrian counts at the Maria Drive/McDowell Boulevard intersection
indicate a low level of pedestrian activity during the a.m., midday, and p.m. peals periods, which is
reflective of a free flow level of service with no impedances to pedestrian movements during all
peal-, periods. The five-year collision history at the Maria Drive/McDowell Boulevard intersection
indicates a low rate of collisions over the last five-year reporting period with four vehicle collisions
per year on average. CHS concluded that there were no patterns of pedestrian involved collisions
that would suggest a safety concern at the Maria Drive/McDowell Boulevard intersection.
The City's Safe Routes to School Plan provides recommendations for pedestrian safety at the
McDowell Boulevard/Maria Drive intersection. The suggestions include minor sidewalk repairs,
widening the sidewalks, and including a pedestrian phase at the signal. Consistent with these
recommendations, as a condition of approval, the proposed project would be required to achieve
the following: 1) replace the existing sidewalks, driveways, and curb ramps that are broken or
cracked along the project site frontage to Maria Drive and South McDowell Boulevard; 2) install a
new, accessible, and directional pedestrian ramp at the McDowell/Maria intersection; and 3) install
a pedestrian crossing warning sign at the proposed driveway entrances.
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With the conditions of approval, pedestrian facilities at the intersection of Maria Drive/McDowell
Boulevard will be improved. There are no significant impacts identified related to pedestrian access,
safety concerns or lack of connectivity. Therefore, the MND concluded that impacts of the proposed
project to transit, bicycle and pedestrian facilities would be less than significant.
RESPONSE TO COMMENTS SUMMARY
The City of Petaluma carefully reviewed the information developed through the response to
comments process and determined that the project does not meet any of the conditions under
CEQA Section 15073.5. Therefore, the recirculation of a revised IS/MND or the preparation of an
Environmental Impact Report (EIR) is not required. Consistent with the CEQA Guidelines, this
Response to Comments document clarifies the information and analyses in the IS/NIND.
The City of Petaluma will consider the Public Draft IS/MND, together with this Response to
Comments document, prior to making a decision on the IS/MND and the proposed project.
REFERENCES
The following materials are incorporated by reference and included as attachments to the June 26,
2018 Planning Commission staff report.
• Comment Letters
• Illingworth & Rodkin Response to Comments, May 8, 2018
• Illingworth & Rodkin Response to Follow Up Comments, June 6, 2018
• CHS Technical Memo, June 6, 2018
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