HomeMy WebLinkAboutStaff Report 5.A 01/28/2019 Attachment 13RUTAN
RUTAN & TUCKER, LLP
October 10, 2018
VIA EMAIL AND FEDERAL EXPRESS
Heather Hines
Planning Manager
City of Petaluma
11 English Court
Petaluma, CA 94952
ATTACHMENT 13
Matthew D. Francois
Direct Dial: (650) 798-5669
E-mail: mfrancois@rutan.com
Re: Safeway Fuel Center Project—Responses to Comments of Bay Area Air
Quality Management District and Phyllis Fox/Ray Kapahi
Dear Ms. Hines:
We write on behalf of our client, Safeway, Inc., regarding the proposed Safeway Fuel
Center Project (the "Project") at 335 S. McDowell Boulevard (the "Property") in the City of
Petaluma (the "City"). We write to provide responses to the September 17, 2018 comments from
the Bay Area Air Quality Management District ("BAAQMD") and Phyllis Fox and Ray Kapahi
("Fox/Kapahi") on the health risk assessment ("HRA") prepared by Illingworth & Rodkin, an
expert air quality consulting firm, for the Project.
As you know, the Project has been reviewed by the City for nearly six years and was the
subject of numerous studies prepared by expert consultants as well as a detailed mitigated negative
declaration ("MND") prepared by M -Group, the City's contract planning staff. One of the
supporting studies is the HRA. Employing conservative assumptions and accepted methodologies
per federal, state, and local guidelines, the HRA concludes that the Project meets all thresholds
and will result in less than significant impacts with respect to community risk for all categories of
sensitive receptors.
After continuing its May 8, 2018 hearing to obtain more information regarding air quality
and traffic, and to allow additional review by Petaluma City Schools, the Planning Commission
approved the Project on June 26, 2018. On July 9, 2018, an appeal of the Planning Commission's
action was filed by JoAnn McEachin and others. The appeal was originally scheduled for
consideration by the City Council at its September 17, 2018 hearing.
On September 14, 2018, the City received a comment letter from Patrick Soluri on behalf
of JoAnn McEachin and No Gas Here, a recently -formed super political action committee, which
was followed on September 17, 2018 by a comment letter on the HRA from Fox and Kapahi. On
September 17, 2018, the City also received a comment letter from BAAQMD on the HRA.
In its comment letter, BAAQMD recommends use of the American Meteorological Society
Regulatory Model ("AERMOD") instead of the Industrial Source Complex Short -Term 3
("ISCST3") model to evaluate the Project's health risk impacts. BAAQMD also requests that a
13-1
RUTAN
RUTAN 5 7--, LLP
Heather Hines
October 10, 2018
Page 2
health risk analysis of workers/teachers at nearby schools be performed. Fox/Kapahi likewise
assert that the AERMOD model should have been used and purport to include a health risk
assessment indicating that the Project will result in significant cancer risks at nearby sensitive
receptors.
As explained in the October 10, 2018 response from James Reyff of Illingworth & Rodkin,
attached hereto as Exhibit A, ISCST3 is a U.S. EPA -approved and BAAQMD -recommended
model. It was used since there is representative meteorological data readily available for Petaluma
that is suitable for use with that model. It is also the model that was used for every recent Petaluma
project for which a quantitative health risk analysis was prepared.
Nonetheless, in response to BAAQMD and Fox/Kapahi, and at further expense to Safeway,
Illingworth & Rodkin contracted with Lakes Environmental to develop a custom meteorological
data set for the Project site and conducted a supplemental health risk analysis using the AERMOD
model. This supplemental analysis evaluated the health risk to residents, school children, and
workers/teachers. As with the original analysis using the ISCST3 model, the supplemental
analysis using the AERMOD model concludes that the Project meets all thresholds and will not
result in any significant impacts related to health risk.
In preparing the AERMOD analysis, it was discovered that the HRA analysis overstated
the health risk associated with constructions emissions by using standard default values instead of
assuming the use of Tier 2 construction equipment. Neither City staff, BAAQMD, nor Fox/Kapahi
raised this issue in their comments on the HRA. Since the Planning Commission conditioned the
Project to use Tier 3 construction equipment, the updated analysis assumes the use of Tier 3
equipment under both model scenarios.
As also explained in Illingworth & Rodkin's response, the commenters' claims of
significant impacts are based on speculative, unsubstantiated, unsupported, and erroneous
assumptions. Specifically, Fox/Kapahi wrongly base their analysis on Santa Rosa wind data as
opposed to Petaluma data even though analysis of health risk is heavily dependent on the use of
correct meteorological information. Commenters also overestimate diesel emissions by an
approximate factor of ten by overestimating the amount of diesel sales and number of vehicles as
well as by incorrectly averaging the emission rate for all vehicle types. Commenters likewise
overstate the amount of benzene emissions, citing higher emission factors from another air district,
and then modeling even higher emissions than the cited values.
The F6x/Kapahi comment letter asserting that the Project will result in significant impacts
is based on argument, speculation, unsubstantiated opinion, clearly inaccurate and erroneous
information, and evidence that is not credible. As a result, the letter does NOT constitute
substantial evidence of a fair argument that the Project may result in a significant environmental
impact. (Public Resources Code §§ 21080(e), 21082.2(c); CEQA Guidelines §§ 15064(f)(5), and
15384; Friends of `B" Street v. City of Hayward (1980) 106 Ca1.App.3d 988.) As such, the City
must adopt the MND for the Project. (Public Resources Code §§ 21080(c), 21064.5; CEQA
2696/031700-0001
12940707.1 a10/10/18
13-2
RUTAN
RUTAN 6 TUC -R, LLP
Heather Hines
October 10, 2018
Page 3
Guidelines §§ 15063(b)(2), 15064(f)(3); Parker Shattuck Neighbors v. Berkeley City Council
(2013) 222 Ca1.AppAth 768, 785.)
Thank you very much for your assistance on this matter. Please do not hesitate to contact
me with any questions regarding the enclosed information.
Very truly yours,
RUTAN & TUCKER, LLP
1
f r.
Matthew D. Francois
MDF:mtr
cc (via email only):
Natalie Maffei
John Brown
Eric Danly
David Glass
Olivia .Ervin
Adam Petersen
Teresa Barrett
Shirlee Zane
Duncan Campbell
Yvette DiCarlo
Kevin Oei
David Vintze
Barry Young
2696/031700-0001
12940707.1 a10/10/18
13-3
I wl " I INA, liol,
13-4
//. uNG 1 A/t iRT1 � & RODKiN, &C.
I1 Acoustics . Air Quality I/
429 E. Cotati Ave
Cotati, California 94931
Tel: 707-794-0400 Fax: 707-794-0405
www. illingworthrodkin. com illro@illingworthrodkin.com
Date: October 10, 2018
To: Natalie Mattei
Senior Real Estate Manager
Albertsons Companies
11555 Dublin Canyon Road
Pleasanton, CA 94588
From: James A. Reyff
Illingworth & Rodkin, Inc.
429 E. Cotati Ave
Cotati, CA 94931
RE: Safeway Fuel Center CEQA document - Petaluma, CA
SUBJECT: Safeway Fuel Center Health Risk Assessment - Response to Comments made
by BAAQMD and Phyllis Fox/Ray Kapahi - ,TCD l)P d 3. 0
This memo provides our response to comments regarding the Petaluma Safeway gas station project
("Project") made by (i) the Bay Area Air Quality Management District (`BAAQMD") in a letter
dated September 17, 2018 and (ii) Phyllis Fox and Ray Kapahi in a report dated September 17,
2018,1
Responses to BAAQMD letter dated September 17, 2018
In the introduction of its letter, BAAQMD states that its review addressed stationary sources. It
should be noted that the Health Risk Assessment for the Project ("HRA") addressed construction
emissions, evaporative emissions from transfer and storage of gasoline, and emissions from Project
traffic.
Use of ISCST3
As explained below and in previous responses, Industrial Source Complex Short -Term 3
("ISCST3") is a U.S. EPA -approved and BAAQMD-recommended model. Nonetheless, in
response to the BAAQMD and Fox/Kapahi letters dated September 17, 2018, Illingworth &
Rodkin contracted with Lakes Environmental to develop a custom meteorological data set for the
I Comments on the Initial Study/Mitigated Negative Declaration (IS/MND) for the Safeway Fuel Center Petaluma,
California
13-5
Memo to Natalie Mattei
October 10, 2018 —Page 2
Project site and conducted a supplemental health risk analysis using the American Meteorological
Society (AMS)/EPA Regulatory Model ("AERMOD"). That supplemental analysis, attached
hereto as Exhibit A, similarly concludes that the Project meets all thresholds and will not result in
any significant impacts related to health risk.
Please see responses to Meridian comments regarding the use of the ISCST3 model, attached as
Exhibit B. Specifically, the ISCST3 model was used since there is representative meteorological
data readily available for Petaluma that is suitable for use with that model. ISCST3 is a U.S. EPA -
approved dispersion model and is included in BAAQMD's Tools and Methodologies section of
their website as Recommended Methods for Screening and Modeling Local Risks and Hazards.
This document describes in detail how to screen and model risk and hazards from stationary,
highway, and roadway sources. It also discusses the assumptions and methodologies used in
developing the stationary source, highway, and roadway screening tools for use in CEQA studies.
The website was last checked on 10/10/2018.
Volume Sources
BAAQMD recommends using two volume air sources (or 8) of the same size that the HRA used.
One (or 4) would be for refueling and the other one (or 4) would be for spillage. The HRA used
8 sources (4 for refueling and 4 for spillage) with one-fourth of the emissions assigned to each
(rather than two or four). Therefore, the recommended technique would yield the same results.
ESA Memo dated May 7, 2018
Based on BAAQMD's letter dated September 17, 2018, it appears that BAAQMD was in receipt
of ESA's memo dated May 7, 2018 as well as Illingworth & Rodkin's response to ESA dated May
8, 2018, which is attached herein as Exhibit C.
BAAQMD states that the HRA should be analyzed at 25.71 million gallons unless the City limits
the Project permit to 8.5 million gallons as studied in the HRA. Safeway estimates that they would
never exceed 8.5 million gallons. In response, the City has conditioned the Project to the annual
8.5 -million -gallon throughput studied.
The HRA evaluated the impact to sensitive receptors with respect to CEQA thresholds identified
in the BAAQMD CEQA Air Quality Guidelines. It was pointed out in the response to ESA
comments that teacher risks would be less than the child/student risk and that the most conseivative
evaluation of health risk would be for a child at the nearby preschool. Nonetheless, an analysis of
teacher/worker risk is included in the supplemental analysis attached as Exhibit A.
BAAQMD concurs that use of the full 2015 State Office of Environmental Health Hazards
Assessment ("OEHHA") health risk assessment procedures would provide conservative results
and would be acceptable for CEQA purposes. This was the methodology used by the HRA.
BAAQMD concurs with Illingworth & Rodkin's responses regarding receptor height and
pollutants of concern. (See Exhibit C.) Comment noted.
13-6
Memo to Natalie Mattei
October 10, 2018 —Page 3
Responses to Fox-Kapahi Comments dated September 17, 2018
In sections 1 and 2 of their letter, Fox and Kapahi ("Commenters") claim that they prepared a
health risk assessment ("Fox/Kapahi HRA") that identifies significant health risks at nearby
sensitive receptors. The primary response is that the Fox/Kapahi HRA is based on faulty
assumptions for diesel vehicle idling. In addition, they used poor dispersion modeling techniques
and overestimated benzene emissions. As such they significantly overestimate actual emissions
and resulting impacts, resulting in false claims of significant impacts.
Benzene and Dispersion Modeling
The HRA used benzene emission factors that were based on the latest California Air Resources
Board ("CARB") guidance (described in the report) and were the same factors used by BAAQMD
to compute effects for the facility's permit (note that BAAQMD based their emissions on 25.71
million gallons of annual throughput). The HRA computed 34 pounds of benzene emitted per year
using the same benzene emission factor BAAQMD used for the Project's Authority to Construct
permit. The Commenters used emission factors from the San Joaquin Valley Air Pollution Control
District ("SJVAPCD") that predict 43 pounds per year (see Commenter's Table 1). However, a
review of the Commenters' modeling output shows that they modeled 49 pounds of benzene with
no explanation for the discrepancies between the emissions computed and those modeled (see
Commenter's Exhibit C-- Excerpts of HARP2 Risk Model). BAAQMD's emission factors are the
appropriate factors to use for the Project, which is located within this air district.
Air Dispersion Model
The Commenters' dispersion modeling used the AERMOD model claiming it is the U.S. EPA's
primary model for permitting. However, as this is a CEQA study of health risks that addresses
thresholds identified in the BAAQMD CEQA Air Quality Guidelines and as explained in the HRA
and subsequent responses to comments, use of ISCST3 with local Petaluma meteorological data
is appropriate. The Commenters used AERMOD with meteorological data from Santa Rosa,
which experiences different meteorological conditions and is not appropriate for the Project site.
ISCST3 with local Petaluma meteorological data reflects an appropriate analysis for this Project.
As stated by the Commenters, the wind patterns are very different in Petaluma and Santa Rosa.
Thus, the results of the Commenters' modeling have no bearing on potential impacts that could
occur from the Project in Petaluma. As such, any modeling results or impacts cited by the
Commenters are meaningless and only provide speculative, unsubstantiated and unsupported
results.
As stated above, Illingworth & Rodkin conducted a supplemental health risk analysis using the
AERMOD model. That supplemental analysis, attached hereto as Exhibit A, similarly concludes
that the Project will not result in any significant impacts related to health risk.
Exposure Duration: Operating ours
In addition, the Commenters modeled the Project as operating 24 hours per day. This would
increase impacts because late night and early morning have relatively poor dispersion
characteristics. As outlined in the Project MND, the proposed hours of operation for the Project
are 6:00 a.m. to 11 p.m. Therefore, the Commenters' modeling is inaccurate and overstated.
13-7
Memo to Natalie Maffei
October 10, 2018 — Page 4
Furthermore, the Commenters suggest that the annual PM2.5 concentration from construction
activity (of 0.21 ug/m3) should be increased proportionally with an increase in hours of operation
(that would not be occurring during construction) from 19 hours to 24 hours and that concentration
should then be rounded upward to equal the threshold of 0.3 ug/m3. The hours of operation of the
Project, once constructed, have no bearing on the PM2.s concentration from construction activities
that would occur prior to operation of the Project. The Commenters' proposed approach is not
credible. In addition, the threshold for annual PM2.5 concentration is whether or not a project's
contribution would exceed 0.3 ug/m3, which the Project does not.
Type of Fuel
The HRA modeled this Project based on the sale of gasoline. In the event diesel fuel is sold,
Safeway estimates that would account for no more than 4 percent of the sales. A supplemental
analysis was conducted to account for the effects of diesel fuel sales from the Project. These
calculations were based on the same methodology used for other vehicles but applying DPM
emissions to light- and medium -duty diesel vehicles that would be at the facility and transiting the
area. Based on projections using the EMFAC2014 model travel assumptions, these would make
up 3.6 percent of the total vehicles.
As explained in previous responses, diesel fuel, unlike gasoline, has low reactive organic gas
("ROG") emissions, and therefore, emissions from storage, transfer, and dispensing would be
negligible. Idling diesel vehicles would be a source of diesel particulate matter ("DPM")
emissions. Based on the HRA's vehicle emissions modeling (contained in the report attachments),
the mix of light and medium duty diesel vehicles would comprise almost 4 percent (also noted by
the Commenters).
The Fox/Kapahi HRA overestimates diesel emissions by an approximate factor of 10. This
obviously skews their resulting health risk assessment.
First, they erroneously estimate 924,405 vehicles per year would be served by the Project. By
misrepresenting "trips" for "vehicles", the Commenter overstates emissions. Unlike vehicles, a
trip refers to a single vehicle entering and exiting a site. Vehicles idling would be at least one-half
that number and that is if all vehicles are assumed to idle for 5 minutes before fueling for every
hour of the day. This is an error that results in emissions at least 2 times higher.
Second, the Commenters assumed that diesel sales would comprise 12 percent of all fuel sales
based on total retail sales from CEC data for Solano County. This station would only serve light -
and medium -duty vehicles in Sonoma County. Fleet and large trucks (or haul trucks), which make
up much of the vehicle travel in Sonoma County, would not be fueling at this station. Safeway
estimates diesel sales as up to 4 percent, which is in line with CARB's EMFAC2014 model that
predicts 3.6 percent and was used in the HRA. It is also conservative in that diesel sales at
comparable Safeway gas stations in Pleasant Hill and Campbell only average approximately 2
percent of sales. Commenters' error in projections of diesel sales results in emissions that are
over 3 times higher.
Third, in computing the grams per mile emission rate, the Commenters simply averaged the
13-8
Memo to Natalie Maffei
October 10, 2018 — Page 5
emission rate for all vehicle types (see their Table 2). The LDT vehicle type, which accounts for
very high emission rates because most of these vehicles are quite old, has a very small, fraction of
travel. The Project HRA more accurately based the vehicle emission rate calculations proportional
to the vehicle miles traveled (i.e., proportional to their use relative to other vehicles) by the types
of vehicles that would be accessing the gas station. The Commenters' error in averaging the
emission rate for all vehicle types results in emissions that are 2 times as high.
Exposure Duration
The HRA was first prepared and submitted in 2014 and addressed the 70 -year exposure period.
Subsequently, 0EH14A released new guidance in 2015 that recommends a 30 -year exposure period
with more protective modeling assumptions for infants and children. Based on numerous
discussions with BAAQMD, these assumptions were applied in the Project HRA. When
permitting new gasoline fueling sources, which only applies to the source being permitted (i.e.,
benzene from gasoline dispensing facilities or GDFs), BAAQMD still applies the 70 -year exposure
period and less protective exposure parameters. The HRA was updated to apply the new OEHHA
guidance to all sources for the purposes of this CEQA analysis. As pointed out by BAAQMD
comments, this yields more conservative results. BAAQMD's Air Toxics NSR Program Health
Risk Assessment Guidelines (December 2016), Section 2.1.1.3 describes the exposure durations
that BAAQMD relies upon to make risk management decisions.
It should be noted that neither of the daycare facilities provide care for children younger than two
(2) years of age (i.e., they have no infants present). For school children, the Commenters
suggested a 18 -year exposure period where they assume North Bay Children's Center accepts
infants and that students attending the daycare or schools would live across the street. This was
addressed in previous responses attached hereto as Exhibit C. The analysis concluded that any
such cumulative health exposure risks would likewise be less than significant.
Finally, the Commenter's appear to have erroneously used a 70 -year exposure period that is based
on OEH A's 2003 risk assessment guidance but applied the full set of the newer more
conservative 2015 OEHIIA exposure parameters in the HARP2 model that are intended to apply
with the 30 -year exposure. As discussed in the project HRA, BAAQMD has adopted the 2015,
OEHHA exposure parameters, health effect values and age sensitivity factors using 30 -year
exposure duration for sensitive receptors. Essentially, the Commenter's analysis included 40
years of additional exposure beyond what is recommended by the BAAQMD
and CARB. BAAQMD's September 17, 2018 comment letter noted it was acceptable to either
use the 70 -year exposure (2003 risk guidance) for only gasoline stations health risk (and not traffic
or construction) or it would be conservative and acceptable to use the current 2015 OEIIIIA risk
guidance method for all such factors. The Commenters' analysis combined both methods to
achieve the highest outcome.
Construction Emissions
The Commenters state that with regard to construction emissions the same sensitive receptors will
be present in the same locations during both construction and operation of the Project and that the
HRA failed to include exposures that would occur during the construction phase of the Project,
thus underestimating health risks. This claim is erroneous. In the IIRA, the construction health
13-9
Memo to Natalie Maffei
October 10, 2018 —Page 6
risk impacts were clearly discussed and the maximum impacts identified in Table 2 of the HRA.
Additionally, as clearly shown in Table 3 of the HRA, the maximum construction impacts were
included with, and added to, the maximum operational health impacts from the Project in order to
evaluate the overall maximum health impacts from construction and operation of the Project.
Furthermore, the HRA did not include the effect of control measures that Safeway included in their
project description (i.e., BAAQMD basic control measures and use of Tier 2 diesel construction
equipment) that substantially reduce construction impacts.
Health Risk Assessment and Emissions
The Commenters state that the OEHHA guidelines require that output from the AERMOD model
be entered into the HARP2 model to estimate health risks. The Commenters also state that the
calculations in the HRA did not follow standard HRA procedures and guidelines cited in the HRA.
Commenters are incorrect on both claims.
OEHHA identifies the HARP2 model as a software tool that can be used for health risk
assessments, but it does not require its use. The HRA used the procedures outlined in the OEHHA
and BAAQMD guidance for calculating cancer risk and other non -cancer impacts. The details of
the cancer risk calculations are provided in Attachment 1 of the HRA for construction emissions
and Attachment 2 for operational emissions. The tables provided in the attachments include a
description of the calculations used, a listing of the specific exposure parameters and values used
for the calculations, identification of the maximum modeled toxic air contaminant ("TAC")
concentrations used for the calculations, and the results of the calculations for each year of
exposure. The methods and equations used exposure parameters and values that are based on
OEHHA and BAAQMD guidance.
Moreover, as noted above, Illingworth & Rodkin conducted a supplemental health risk analysis
using the AERMOD model. That supplemental analysis, attached hereto as Exhibit A, similarly
concludes that the Project will not result in any significant impacts related to health risk
Modeling -Grid
The Commenters state that the HRA fails to disclose the location(s) of nearby sensitive receptors,
points of maximum impact, or how they were identified. They also state that the HRA fails to
display the results of its analysis on a map or identify the physical locations of the sensitive
receptors. Again, Commenters are incorrect with respect to these claims.
The physical locations of the nearby residential receptors, McDowell Elementary School receptors
and receptors at the preschools were identified from aerial mapping and are clearly shown in Figure
1 of the HRA. Additionally, the locations where maximum health impacts (maximum cancer risk,
maximum PM2.5 concentration, and maximum non -cancer health impacts) for residential
receptors and school child/daycare receptors occur are also identified in Figure 1. The age of
children present at the daycare facilities was provided by the City of Petaluma Planning Staff and
confirmed by Safeway.
Since a health risk assessment is an assessment of chronic exposures, the receptor selection
included locations where children and residents would spend extended periods of time. Outdoor
13-10 ,
Memo to Natalie Maffei
October 10, 2018 — Page 7
areas would have relatively short exposure periods.
It is worth noting that the Commenters did not identify the type or location of sensitive receptors
used (residential or school/daycare child) in their modeling and did not identify the points of
maximum impact in the modeling figures they provided in their report (Fox/Kapahi HRA, Figures
4 and 5).
The Commenters claim that it is common practice to summarize health risks on isopleths maps
and that the absence of an isopleths map deprives the public and potentially affected parties of
determining if they are at risk.
Isopleths of cancer risk and PM2.5 concentration are a useful way of graphically depicting the area
and extent of potential impacts from a project. The presentation of isopleths in a HRA is not a
regulatory requirement, rather, it is a useful means of presenting the results of the HRA. For this
Project, the maximum cancer risk and PM2.5 impacts were below significance levels. Thus, there
were no areas where significant impacts would occur and the use of isopleths would not show any
areas of significant impact. Additionally, for the HRA modeling, individual sensitive receptor
locations were used with the modeling to identify the specific locations where sensitive receptors
could be potentially affected. Typically, if isopleths are going to be calculated, a large grid of
receptors encompassing the entire project area is needed to provide sufficient data resolution in
order for creating accurate isopleths. Thus, isopleths were not used as part of the presentation of
health impacts.
HRAs for Similar Facilities
The screening health risk analysis for the Cottle Safeway was conducted in 2012 and used the
CARB's Land Use and Air Quality Handbook and older emission factors developed by CAPCOA
in 1997 that does not account for current control features that further reduce benzene emissions
from gasoline dispensing facilities. This effect was explained in Illingworth & Rodkin's response
to ESA Comments on the HRA (Exhibit B). Furthermore, the analysis for the Cottle Safeway was
a screening level assessment to demonstrate that there would be no significant health risks. The
analysis also stated that "Subsequent to the CEQA process, BAAQMD would confirm this effect
prior to issuing their regulatory permit to construct such a facility, under Regulation 8, Rule 7."
The Cottle gas station applied to BAAQMD in 2013 and subsequently opened in 2014 with
appropriate permits.
Use of Dispersion Modeling and Evaluation of Community Health Risks in Recent
Environmental Projects in Petaluma
Based on the City of Petaluma Planning Division's website listing recent major development
projects (http://cityofpetaluma.net/edd/major-projects.html), the following projects were
identified:
Sid Commons Apartment Project (January 2018)*
Davidson/Scott Ranch Revised Draft Environmental Impact Report (March 2018)*
Cagwin & Dorward Project (June 2017)*
13-11
Memo to Natalie Mattei
October 10, 2018 — Page 8
• Spring Hill School Project (August 2017)
• North River Apartments Project (August 2017)
• Brody Ranch Residential Project September 2016)*
Of these six projects, four of them (identified in the list with a *) had quantitative health risk
assessments prepared that utilized air quality dispersion modeling to evaluate impacts to address
the exposure of sensitive receptors to substantial pollutant concentrations. The remaining projects
did not have detailed health risk assessments prepared. Potential health risks from these projects
were evaluated using health risk screening methods or qualitatively discussed. Each of the projects
is briefly discussed below.
Sid Commons Apartment Project
The health risk assessment for this project relied on a previous study prepared for the project in
2014. The air quality dispersion modeling for the 2014 study used the ISCST3 dispersion model
to calculate DPM concentrations for use in evaluating health impacts.
Davidson/Scott Ranch Revised Draft Environmental Impact Report.
A Draft Environmental Impact Report was prepared for a residential development with 66 single-
family homes. A detailed health risk assessment was prepared to evaluate health impacts from
project construction activities. The air quality dispersion modeling for the study used the ISCST3
dispersion model with 1990 — 1994 meteorological data from the Petaluma Airport to calculate
DPM concentrations for use in evaluating health impacts.
Cagwin & Dorward Project.
An Initial Study/Mitigated Negative Declaration was prepared for a new office/landscape
maintenance operations facility including a 22,724 square foot building for approximately 100
employees, as well as parking for maintenance, trucks and trailers, and shop and warehouse space
for vehicle maintenance. The project includes a 19,440 square foot office building, and 2,340
square foot warehouse. A detailed health risk assessment was prepared to evaluate health impacts
from project construction activities. The air quality dispersion modeling for the study used the
ISCST3 dispersion model with 1990 — 1994 meteorological data from the Petaluma Airport to
calculate DPM concentrations for use in evaluating health impacts.
Spring Hill School Proms.
An Initial Study/Mitigated Negative Declaration was prepared for the project which includes a 9
to 12 month construction project to demolish an existing building and construct a new 7,869 square
foot building for classroom instruction at a middle school. Construction of the project would occur
over a 9 to 12 month period. In addition to students at the Springhill School itself, the Valley Vista
Elementary School and Petaluma Junior High School are located directly northeast and west of the
project site, respectively. Residential land uses are also located in the nearby vicinity of the project
site. Potential health risks to school children at the project site or other schools, as well as for
nearby residents, were not evaluated.
North River Apartments Proms.
An Initial Study/Mitigated Negative Declaration was prepared for the construction of two
apartment buildings. The nearest sensitive receptors to the project are elementary school students
at a school that is 250 feet from the project site and residences that are about 175 feet west of the
13-12
Memo to Natalie Mattei
October 10, 2018 — Page 9
project site. Although the project will have construction equipment exhaust PMlo emissions
(diesel particulate matter, DPM) of 0.22 tons per year during construction, which are 5.4 times
higher than those for the Safeway Gas Station Project construction equipment, a quantitative health
risk evaluation was not performed to assess health impacts on the elementary school students or
nearby residents. Health risks were stated to be a less than significant impact, without
quantification.
Brody Ranch Residential Prosect.
An Initial Study/Mitigated Negative Declaration was prepared for this residential development
project with 199 residential units. A detailed health risk assessment was prepared to evaluate
health impacts from project construction activities. The air quality dispersion modeling for the
study used the ISCST3 dispersion model with 1990 —1994 meteorological data from the Petaluma
Airport to calculate DPM concentrations for use in evaluating health impacts.
Summary
Based on review of recent City of Petaluma projects and to the best of our knowledge the
AERMOD air quality dispersion model has not been used for modeling potential impacts from any
CEQA project in the City of Petaluma. This is primarily due to the lack of available, local
meteorological data needed by the AERMOD model. In lieu of using the AERMOD model, the
ISCST3 model is an EPA -refined dispersion model that is considered an alternative model that can
be used when approved by the reviewing regulatory agency (i.e. BAAQMD).2 The current
BAAQMD modeling guidance recommends the use of either the AERMOD or ISCST3 models
for CEQA related health risk assessments. 3
Nonetheless, as noted above, Illingworth & Rodkin conducted a supplemental health risk analysis
using the AERMOD model. That supplemental analysis, attached hereto as Exhibit A, similarly
concludes that the Project will not result in any significant impacts related to health risk
2 Guideline on Air Quality Models. Appendix W of 40 CFR Part 51.
3 Recommended Methods for Screening and Modeling Local Risks and Hazards. Bay Area Air Quality Management District
(BAAQMD). May 2012.
13-13
Imil 11 1.
13-14
ILU1NGWORTH & RODKIN, INC.
11111 Acoustics • Air Quality 11
429 E. Cotati Ave
Cotati, California 94931
Tel: 707-794-0400 Fax: 707-794-0405
www. illingm orthrodkin. com illro@illingworthrodkin.com
Date: October 10, 2018
To: Natalie Mattei
Senior Real Estate Manager
Albertson Companies
11555 Dublin Canyon Road
Pleasanton, CA 94588
From: James A. Reyff
Illingworth & Rodkin, Inc.
429 E. Cotati Ave
Cotati, CA 94931
RE: Safeway Fuel Center CEQA document - Petaluma, CA
SUBJECT: Safeway Fuel Center Health Risk Assessment — Updated Modeling Results
using U.S. EPA's AERMOD Dispersion Model = lob#1 3 " I E0J
This memo provides results of a newly -modeled health risk assessment ("HRA") for the Petaluma
Safeway Fuel Center ("Project") based on application of the U.S. EPA's American Meteorological
Society (AMS)/EPA Regulatory Model ("AERMOD") dispersion model. AERMOD is the U.S.
EPA's preferred near -field dispersion modeling system, but requires enhanced meteorological
inputs. The reasons for not using the AERMOD model previously were (i) based on the lack of
suitable meteorological data for the City of Petaluma (while the Bay Area Air Quality Management
District ["BAAQMD"] provides suitable meteorological data for use in the Industrial Source
Complex Short -Term 3 ["ISCST3"] model, historically those data sets have not been suitable for
use in AERMOD), and (ii) confirmation by BAAQMD and the City of Petaluma Planning
Department that use of the ISCST3 model was appropriate and acceptable for the Project.
Nevertheless, comments were received in September 2018 that suggested the AERMOD model
should have been used to assess the Project.
In addition, the updated modeling accounts for construction control requirements that include the
use of newer equipment with lower emissions. The September 2017 HRA assumed default
conditions.
Meteorological Data
In a letter from Phyllis Fox and Ray Kapahi dated September 17, 2018, a health risk assessment
of the Project utilizing meteorological data from the City of Santa Rosa, California, was performed.
Santa Rosa experiences different meteorological conditions than Petaluma and is not appropriate
for use at the Project site in Petaluma. Illingworth & Rodkin subsequently sought out
13-15
Natalie Mattei
Albertsons Companies
October 10, 2018 —Page 2
meteorological data for the City of Petaluma that could be used in AERMOD.
Recently, new U.S. EPA modeling guidelines (40 CFR Part 51, Appendix W, effective February
16, 2017) allows the use of prognostic meteorological data using the U.S. EPA's Mesoscale Model
Interface Program ("MMIF") pre-processor to generate inputs for regulatory modeling
applications using the meteorological preprocessor model ("AERMET") and AERMOD.
Prognostic meteorological data can be used when (i) there is no representative National Weather
Service station data available for use in developing AERMOD meteorological data, and (ii) site-
specific data are not available. The U.S. EPA recommends using no fewer than three years of
meteorological data for modeling when using prognostic modeled derived data for AERMOD.
This new option now provides the opportunity to develop meteorological data suitable for
AERMOD that are representative of the Project site.
The Weather Research and Forecasting ("WRF") grid model was used to develop a 5 -year data set
(2013 through 2017) for meteorological conditions at the Project site. The WRF model pulls in
observations and archived meteorological model data from the region around the Project site, and
uses the same physical equations that are used in weather forecasting to model the historical
weather conditions at the specific project location. Development of this data set was performed
by Lakes Environmental using the WRF model and the MMIF program to process data for input
to the AERMOD meteorological data preprocessor, AERMET. The WRF modeling uses a nested
grid with a 4 -kilometer grid spacing at the highest resolution (inner grid).
The wind data produced can be illustrated by a windrose that illustrates the joint frequency
distribution of wind flow (by direction and speed). The "petals" of the windrose extend in the
direction that wind flows from. The windrose developed for modeling with AERMOD is
compared against the windrose from the available meteorological data obtained from BAAQMD
and used in ISCST3. The two data sets are comparable with a slightly greater westerly component
(and less of a northerly component) depicted with the AERMOD data set.
Sale of Diesel Fuel
The sale of diesel fuel, which was not considered in the original Project HRA, was included in this
updated analysis. The sale of diesel fuel would add emissions of diesel particulate matter ("DPM")
from customer vehicles that travel to and from the Project and potentially idle at the Project site.
There are negligible evaporative emissions from storage and transfer of diesel fuel. The same
assumptions for gasoline vehicle activity (i.e., travel and idling activity) were applied to diesel
vehicles.
Emissions from diesel vehicles were computed based on the default travel fractions that the
EMFAC2014 model produces for the assumed mix of vehicles that would be served by the Project.
Note that the Project would not serve heavy-duty trucks or buses as the station design does not
accommodate the circulation of large vehicles. The vehicle mix generated by EMFAC2014
includes 3.6 percent diesel vehicles. This is consistent with Safeway estimates of diesel fuel sales
and is conservative in that diesel sales at comparable Safeway gas stations in Pleasant Hill and
Campbell only average approximately 2 percent of sales.
13-16
Natalie Mattei
Albertson Companies
October 10, 2018 — Page 3
Figure 1. Windrose for Petaluma
Assessment of Teachers
In accordance with CEQA and U.S. EPA guidelines, children at the preschools and nearby
residents were assessed as sensitive receptors. In September 2018, concerns were brought up about
the risk for preschool or school teacher/workers. Although the exposure to teachers/workers is
less than children and nearby residents, Illingworth & Rodkin assessed teachers/workers in Table
1 below. The community risk impact to teachers/workers is substantially below thresholds.
Construction Emissions
The 2017 LIRA used unmitigated construction emissions computed using CalEEMod default
modeling conditions for the project. Safeway proposed a construction control plan that included
BAAQMD basic control measures for construction projects including use of Tier 2 diesel
construction equipment along with a limit of diesel generator use. Subsequently, the Planning
Commission conditioned the project to use Tier 3 equipment. The updated modeling analysis
includes the effect of using diesel equipment that meets U.S. EPA Tier 3 standards.
Results of AERMOD Modeling
Table 1 provides results using the AERMOD model with diesel fuel sales and Table 2 provides
the original HRA results based on use of the ISCST3 model without diesel fuel sales. The results
shown in Table 1 demonstrate that the maximum Project health impacts would (i) be consistent
with those results obtained using the ISCST3 model, and (ii) below the applicable BAAQMD
significance thresholds. The results from both the AERMOD and ISCST3 models conclude that
the Project will not result in any significant impacts related to health risk.
Figure 1 below shows the Project site, modeled truck and customer vehicle routes, sensitive
receptor locations used in the modeling, and locations where the maximum cancer risks and PM2.5
13-17
lSWLP tak,ma Siuw Data 201J.R017 1y +µkm 7 1
@M040 Pt11'sinu AUPOII Stri4en •YhnMtM �1490.1i911 Wmr d
�il1s
. 1I l'4
wax
�s2Yd '
1.IS
Y.]1
1Y '.
'.151:5! FASt
----------------
StttU yFL44
innl
.... •.. .-,.- L� aa•7re
cm, 011.
e..n oel�
2013-2017 data set produced for AERMOD at Project
1990-1994 data set produced for ISCST3 for Petaluma
Site
Municipal Airport 1 mile northeast of project site
Assessment of Teachers
In accordance with CEQA and U.S. EPA guidelines, children at the preschools and nearby
residents were assessed as sensitive receptors. In September 2018, concerns were brought up about
the risk for preschool or school teacher/workers. Although the exposure to teachers/workers is
less than children and nearby residents, Illingworth & Rodkin assessed teachers/workers in Table
1 below. The community risk impact to teachers/workers is substantially below thresholds.
Construction Emissions
The 2017 LIRA used unmitigated construction emissions computed using CalEEMod default
modeling conditions for the project. Safeway proposed a construction control plan that included
BAAQMD basic control measures for construction projects including use of Tier 2 diesel
construction equipment along with a limit of diesel generator use. Subsequently, the Planning
Commission conditioned the project to use Tier 3 equipment. The updated modeling analysis
includes the effect of using diesel equipment that meets U.S. EPA Tier 3 standards.
Results of AERMOD Modeling
Table 1 provides results using the AERMOD model with diesel fuel sales and Table 2 provides
the original HRA results based on use of the ISCST3 model without diesel fuel sales. The results
shown in Table 1 demonstrate that the maximum Project health impacts would (i) be consistent
with those results obtained using the ISCST3 model, and (ii) below the applicable BAAQMD
significance thresholds. The results from both the AERMOD and ISCST3 models conclude that
the Project will not result in any significant impacts related to health risk.
Figure 1 below shows the Project site, modeled truck and customer vehicle routes, sensitive
receptor locations used in the modeling, and locations where the maximum cancer risks and PM2.5
13-17
Natalie Mattei
Albertsons Companies
October 10, 2018 — Page 4
concentrations occur for nearby residents and preschool/school children. Note the modeled truck
and customer vehicle routes depict the original circulation pattern with trucks and vehicles
accessing the site through Maria Drive. This is a conservative scenario as the Planning
Commission imposed conditions restricting truck and vehicles from accessing the site through
Maria Drive which is the point of entry closest to the elementary school and preschools. The
maximum cancer risks and PM2.5 concentrations for preschool or school teacher/workers would
occur at the same location where the maximum impacts would occur for preschool/school children.
Figure 1— Project Site, Sensitive Receptor Locations, Project Vehicle Travel Routes, and
Locations of Maximum Cancer Risk and PM2.5 Concentrations
UTM - East (meters)
13-18
Natalie Mattei
Albertsons Companies
October 10, 2018 - Page 5
Table 1. Updated HRA Results Based on AERMOD Modeline
Receptor/Source(per
Excess Cancer
Risk
million
C mmunity Risk Im
Annual PM2.5
Concentration
/m3
act
Hazard Index
(highest of Acute or
Chronic
Residential (30 -year exposure)
Construction Impacts
1.06
0.01
0.00
Traffic TOG vehicle trips & idling)
1.66
0.00
0.01
Traffic DPM vehicle trips & idling)
1.38
0.02
0.00
Traffic DPM truck deliveries
0.03
0.00
0.00
Benzene fiom fuel evaporation)
1.94
0.00
0.04
Total Project - Residential
6.1
0.03
0.05
School Child (9 -year exposure)
School Child (9 -year exposure)
3.2
0.12
0.02
Construction Impacts
1.99
0.07
0.01
Traffic TOG vehicle trips & idling)
0.14
0.00
0.02
Traffic DPM vehicle trips & idling)
0.12
0.01
0.00
Traffic DPM truck deliveries
0.01
0.00
0.00
Benzene from fuel evaporation)
0.16
0.00
0.02
Total Project - School Child
4.0
0.08
0.05
Worker - Teacher (25 -year exposure)
Construction Impacts
0.20
0.07
0.01
Traffic TOG vehicle trips & idling)
0.10
0.00
0.02
Traffic DPM vehicle trips & idling)
0.09
0.01
0.00
Traffic DPM truck deliveries
0.00
0.00
0.00
Benzene from fuel evaporation)
0.11
0.00
0.02
Total Project - Worker - Teacher
0.50
0.08
0.05
Si ni tante Threshold Project
10
0.3 1
1.0
Table 2. HRA Results Based on ISCST3 Modelinj4
Receptor/Source
Excess Cancer
Risk
(per million)
Community Risk Im
Annual PM2.5
Concentration
( /m)
act
Hazard Index
(highest of Acute or
Chronic)
Residential (30 -year exposure)
Construction Impacts
1.4
0.01
0.00
Traffic TOG vehicle trips & idling)
1.2
0.02
0.01
Traffic DPM truck deliveries
0.02
0.00
0.00
Benzene from fuel evaporation)
1.4
0.00
0.08
Total Project - Residential
4.0
0.03
0.10
School Child (9 -year exposure)
Construction Impacts 2014
3.2
0.12
0.02
Traffic TOG vehicle trips & idling)
0.3
0.01
0.02
Traffic DPM truck deliveries
0.01
0.00
0.00
Benzene from fuel evaporation)
0.4
0.00
0.09
Total Project - School Child
3.9
0.13
0.13
Si nifrcarrce Threshold Project
10
0.3
1.0
13-19
Attachment
13-20
Construction Health Risk Information
Safeway, Petaluma
DFNI Lonstruction Emissions and Modeitng Emission xates - Witli mitigation
DPM
Modeled
Emission
Construction DPM Area DPM Emissions Area
Rate
Year Activity (ton/year) Source (lb/yr) (lb/hr) (g/s) (m2)
(g/s/m2)
Modeled
2019 Construction 0.0228 CON DPM 45.6 0.01388 1.75E-03 2,956
5.92E-07
Construction Hous
hr/day = 9
days/yr = 365
hours/year = 3285
(lam - 4pm)
rivtz.� vugtttve must uonstructton Emissions for ivioaenng - wun ivlttigatton
PM2.5
Modeled
Emission
Construction Area PM2.5 Emissions
Area
Rate
Year Activity Source (ton/year) (]b/yr) (lb/hr) (g/s)
(m2)
g/s/m2
2019 Construction CON_FUG 0.00071 1.4 0.00043 5.45E-05
2,956
1.84E-08
Construction Hours
hr/day = 9 (lam - 4pm)
days/yr = 365
hours/year = 3285
13-21
Safeway- Petaluma -Construction Impacts
ISCST3 Modeling
Maximum DPM Cancer Risk Calculations From Construction
Off -Site Residential Receptor Locations -1.5 meters
Cancer Risk (per million) = CPF x Inhalation Dose x ASF x ED/AT x FAH x I.OE6
Where: CPF = Cancer potency factor (mg/kg -day)-'
ASF = Age sensitivity factor for specified age group
ED = Exposure duration (years)
AT = Averaging time for lifetime cancer risk (years)
FA14= Fraction of time spent at home (unittess)
Inhalation Dose = C.; x DBR x A x (EF/365) x 10
Where: Carr = concentration in air (pg/m�)
DBR= daily breathing rate (I✓1:g body weight -day)
A = Inhalation absorption factor
EF = Exposure frequency (days/year)
104 = Conversion factor
Values
* 95th percentile breathing rates for infants and 80th percentile for children and adults
Construction Cancer Risk by Year - Maximum Impact Receptor Location
Infant/Child
Adult
Age-->
3rd Trimester
0-2
2-9
2-16
16-30
Parameter
ASF =
10
10
3
3
1
CPF =
1.10E+00
1.10E+00
1.I OE+00
I.I OE+00
1.10E+00
DBR* =
361
1090
631
572
261
A=
1
1
I
I
I
EF=
350
350
350
350
350
AT =
70
70
70
70
70
FAH=
1.00
1.00
1 1.00
1 1.00
1 0.73
* 95th percentile breathing rates for infants and 80th percentile for children and adults
Construction Cancer Risk by Year - Maximum Impact Receptor Location
' Third trimester ofpregnancy
Fugitive Total
PM2.5 PM2.5
0.0003 0.009
13-22
Infant/Child - Exposure lnformatio
Infant/Child
Adult - Exposure Information
Adult
Modeled
Age
Exposure
Age
Cancer
Cancer
DPM Conc (u m3)
Exposure
Duration
DPM Cole u /m3 Sensitivity
Risk
Sensitivity
Risk
Year
Annual
Year
(years)
A e Year Annual Factor
(per million)
Factor
(per million)
0
0.25
-0.25-0-
-
10
-
-
-
-
1
1
0 - 1
2019
0.0083
IO
1.36
2019
0.0083
1
0.02
2
1
1-2
0.0000
10
0.00
0.0000
1
0.00
3
1
2-3
0.0000
3
0.00
0.0000
1
0.00
4
1
3-4
0.0000
3
0.00
0.0000
1
0.00
5
1
4-5
0.0000
3
0.00
0.0000
1
0.00
6
1
5-6
0.0000
3
0.00
0.0000
I
0.00
7
I
6-7
0.0000
3
0.00
0.0000
1
0.00
8
1
7-8
0.0000
3
0.00
0.0000
1
0.00
9
1
8-9
0.0000
3
0.00
0.0000
1
0.00
10
1
9-10
0.0000
3
0.00
0.0000
1
0.00
11
1
10-11
0.0000
3
0.00
0.0000
I
0.00
12
1
11-12
0.0000
3
0.00
0.0000
I
0.00
13
1
12-13
0.0000
3
0.00
0.0000
I
0.00
14
1
13-14
0.0000
3
0.00
0.0000
1
0.00
IS
1
14-15
0.0000
3
0.00
0.0000
1
0.00
16
1
15-16
0.0000
3
0.00
0.0000
1
0.00
17
1
16-17
0.0000
1
0.00
0.0000
1
0.00
18
1
17-18
0.0000
1
0.00
0.0000
1
0.00
19
1
18-19
0.0000
1
0.00
0.0000
1
0.00
20
1
19-20
0.0000
1
0.00
0.0000
I
0.00
21
1
20-21
0.0000
I
0.00
0.0000
1
0.00
22
1
21-22
0.0000
1
0.00
0.0000
1
0.00
23
1
22-23
0.0000
1
0.00
0.0000
1
0.00
24
1
23-24
0.0000
1
0.00
0.0000
1
0.00
25
1
24-25
0.0000
1
0.00
0.0000
1
0.00
26
1
25-26
0.0000
1
0.00
0.0000
I
0.00
27
1
26-27
0.0000
1
0.00
0.0000
1
0.00
28
1
27-28
0.0000
I
0.00
0.0000
1
0.00
29
1
28-29
0.0000
1
0.00
0.0000
1
0.00
30 1
1
29-30
0.0000
1
0.00
0.0000
1
0.00
Total Increased
Cancer Risk
IA
0.02
' Third trimester ofpregnancy
Fugitive Total
PM2.5 PM2.5
0.0003 0.009
13-22
Safeway- Petaluma -Construction Impacts
ISCST3 Modeling
Maximum DPM Cancer Risk Calculations From Construction
Daycare/School Child Receptor Locations
Cancer Risk (per million) = CPF x Inhalation Dose x ASF x ED/AT x FAH x 1.0E6
Where: CPF = Cancer potency factor (mg/kg -day)"'
ASF = Age sensitivity factor for specified age group
ED= Exposure duration (years)
AT = Averaging time for lifetime cancer risk (years)
FAH = Fraction of time spent at home (unitless)
Inhalation Dose = C� x DBR x A x (EF/365) x 10"
Where: Cev= concentration in air (pg/ma)
DBR= daily breathing rate (Ltkg body weight -day)
A= Inhalation absorption factor
EF = Exposure frequency (days/year)
10 = Conversion factor
Values
* 95th percentile b=tlting rates for infants and 80th percentile for children and adults
Construction Cancer Risk by Year - Maximum Impact Receptor Location
Exposure
Year
Infant/Child
Adult
Age --
3rd Trimester
0-2
2-9
2-16
16-30
Parameter
ASF =
10
10
3
3
1
CPF =
I.10E+00
1.10E+00
1.10E+00
1.10E+00
I.IOE+00
DBR` =
361
1090
631
572
261
A=
I
1
1
1
I
EF=
350
350
350
350
350
AT =
70
70
70
70
70
FAH=
1.00
1.00
1 1.00
1 1.00
0.73
* 95th percentile b=tlting rates for infants and 80th percentile for children and adults
Construction Cancer Risk by Year - Maximum Impact Receptor Location
Exposure
Year
Exposure
Duration
(years)
Infnnt/Child-Ex osure Informatio
Age
DPM Cone (u m3) Sensitivity
A e Year Annual Factor
InfantfChild
Cancer
Risk
(per million
Adult - Exposure Information
Adult
Cancer
Risk
(per million
Modeled
Age
Sensitivity
Factor
DPM Cone (u m3
Year
Annual
2019 1 5 - 6
Total Increased Cancer Risk
2019
0.1129
3
3.22
3.22
2019
0.1129
1
0.32
0.32
Fugitive Total
PnM2.5 PM2.5
0.0051 0.118
13-23
Safeway- Petaluma -Construction Impacts
AERMOD Modeling
Maximum DPM Cancer Risk Calculations From Construction
Off -Site Residential Receptor Locations - 1.5 meters
Cancer Risk (per million) = CPF x Inhalation Dose x ASF x ED/AT x FAH x LOE6
Where: CPF = Cancer potency factor (mg/kg -day)-'
ASF = Age sensitivity factor for specified age group
ED = Exposure duration (years)
AT = Averaging time for lifetime cancer risk (years)
FAH=•Fraction of time spent at home (unitless)
Inhalation Dose = Cc, x DBR x A x (EF/365) x 10
Where: C,;r=concentration in air (pg/m")
DBR= daily breathing rate (L/kg body weight -day)
A= Inhalation absorption factor
EF = Exposure frequency (days/year)
10'� = Conversion factor
Values
* 95th peu:cntile bicathing rates for intvds and 80th pe¢entile for children and adults
Construction Cancer Risk by Year - Maximum Impact Receptor Location
Infant/Child
Adult
Age-->
3rd Trimester
0-2
2-9
2-16
16-30
Parameter
ASF =
10
10
3
3
1
CPF =
l.1 OE+00
I.I OE+00
1.10E+00
1.10E+00
1.10E+00
DBR* =
361
1090
631
572
261
A=
I
I
1
1
I
EF=
350
350
350
350
350
AT =
70
70
70
70
70
FAH=
1.00
1.00
1 1.00
1 1.00
1 0.73
* 95th peu:cntile bicathing rates for intvds and 80th pe¢entile for children and adults
Construction Cancer Risk by Year - Maximum Impact Receptor Location
* Third trimester of pregnancy
Fugitive Total
PM2.5 PM2.5
0.0002 0.0067
13-24
Infant/Child-Exposure Informatio
Infant/Child
Adult - Exposure In formation
Adult
Modeled
Age
Exposure
Age
Cancer
Cancer
DPMI Cone (ug/n21
Exposure
Duration
DPM Cone (n /m3) Sensitivity
Risk
Sensitivity
Risk
Year
Annual
Year
(years)
A e Year Annual Factor
ler million)
Factor
ler million)
0
0.25
-0.25-0*
-
10
-
-
-
-
I
I
0 - 1
2019
0.0064
10
1.06
2019
0.0064
1
0.02
2
1
1-2
0.0000
10
0.00
0.0000
1
0.00
3
1
2-3
0.0000
3
0.00
0.0000
1
0.00
4
1
3-4
0.0000
3
0.00
0.0000
1
0.00
5
1
4-5
0.0000
3
0.00
0.0000
1
0.00
6
1
5-6
0.0000
3
0.00
0.0000
1
0.00
7
1
6-7
0.0000
3
0.00
0.0000
1
0.00
8
1
7-8
0.0000
3
0.00
0.0000
1
0.00
9
I
8-9
0.0000
3
0.00
0.0000
1
0.00
10
1
9-10
0.0000
3
0.00
0.0000
1
0.00
11
1
10-11
0.0000
3
0.00
0.0000
1
0.00
12
I
11-12
0.0000
3
0.00
0.0000
1
0.00
13
I
12-13
0.0000
3
0.00
0.0000
1
0.00
14
1
13-14
0.0000
3
0.00
0.0000
1
0.00
15
1
14-15
0.0000
3
0.00
0.0000
1
0.00
16
1
15-16
0.0000
3
0.00
0.0000
1
0.00
17
1
16-17
0.0000
1
0.00
0.0000
1
0.00
18
1
17-18
0.0000
1
0.00
0.0000
1
0.00
19
1
18-19
0.0000
1
0.00
0.0000
1
0.00
20
1
19-20
0.0000
1
0.00
0.0000
1
0.00
21
1
20-21
0.0000
1
0.00
0.0000
1
0.00
22
1
21-22
0.0000
1
0.00
0.0000
1
0.00
23
1
22-23
0.0000
1
0.00
0.0000
1
0.00
24
1
23-24
0.0000
1
0.00
0.0000
1
0.00
25
I
24-25
0.0000
1
0.00
0.0000
1
0.00
26
I
25-26
0.0000
1
0.00
0.0000
1
0.00
27
1
26-27
0,0000
1
0.00
0.0000
I
0.00
28
1
27-28
0.0000
1
0.00
0.0000
I
0.00
29
1
28-29
0.0000
1
0.00
0.0000
1
0.00
30
1 I
29-30
0.0000
1
0.00
0.0000
1
0.00
Total Increased
Cancer Risk
1.06
0.02
* Third trimester of pregnancy
Fugitive Total
PM2.5 PM2.5
0.0002 0.0067
13-24
Safeway- Petaluma -Construction Impacts
AERMOD Modeling
Maximum DPM Cancer Risk Calculations From Construction
Daycare/School Child Receptor Locations
Cancer Risk (per million) = CPF x Inhalation Dose x ASF x ED/AT x FAH x I.OE6
Where: CPF = Cancer potency factor (mg/kg -day)-'
ASF = Age sensitivity factor for specified age group
ED = Exposure duration (years)
AT = Averaging time for lifetime cancer risk (years)
FAH = Fraction of time spent at home (unitless)
Inhalation Dose = Cj, x DBR x A x (EF/365) x le
Where: C, —'concentration in air (µg/m)
DBR = daily breathing rate (Ukg body weight -day)
A = Inhalation absorption factor
EF = Exposure frequency (days/yea)
10 =Conversion factor
Values
* 95th percentile bmathing rates for infants and 80th percentile for children and adults
Construction Cancer Risk by Year - Maximum Impact Recentor Location
Exposure
Year
Infant/Child
Adult
Age --
3rd Trimester
0-2
2-9
2-16
16-30
Parameter
ASF=
10
10
3
3
1
CPF=
1.10E+00
1.10E+00
1.10E+00
HOE+00
1.10E+00
DBR* =
361
1090
631
572
261
A=
1
1
1
I
I
EF=
350
350
350
350
350
AT =
70
70
70
70
70
FAH =
1.00
1.00
1.00
1.00
0.73
* 95th percentile bmathing rates for infants and 80th percentile for children and adults
Construction Cancer Risk by Year - Maximum Impact Recentor Location
Exposure
Year
Exposure
Duration
(years)
Infant/Child -Exposure Informntin
Age
DPDI Cone (u m3) Sensitivity
A e Year Annual Factor
Infant/Child
Cancer
Risk
(per million)
Adtdt- Exposure Intorotation
Adult
Cancer
Risk
( er million)
Modeled
Age
Sensitivity
Factor
DPM Conc u m3
Year
Anmtal
2019 1 5 - 6
Total Increased Cancer Risk
2019
0.0697
1 3
1.99
1.99
20190.0697
1
0.20
0.20
Fugitive Total
PM2.5 PM2.5
0.0025 0.072
13-25
Operational Emissions Modeling, Dispersion Modeling Information, and Health Risk Calculations
Vehicle Idle Emissions From Queing at Gas Station
EMFAC2014 (v1.0.7) Emission Rates
Region Type: County
Region: Sonoma
Calendar Year: 2019
Season: Annual
Units: miles/day for VMT, g/mile for RUNEX, PMEW and PMTW
13-26
Assumed %
CO2_RUNEX(
Area Ca1Yr Season Veh Fuel Speed
VMT of Vehicles
ROG_RUNEX TOG_RUNEX
NOX_RUNEX
PaAcyl+LCF5)PM30_RUNEX PM2_5RUNEX
Sonoma 2019 Annual LDA GAS
5 0.58
0.0949
0.1383
0.1376
922.5062
0.0118
0.0109
Sonoma 2019 Annual LDA DSL
5 0.01
0.2849
0.3243
0.2861
721.2901
0.0918
0.0878
Sonoma 2019 Annual LDTS GAS
5 0.05
0.2184
0.3153
0.3473
1098.2722
0.0172
0.0158
Sonoma 2019 Annual LDT1 DSL
5 0
0.9391
1.0691
0.8146
957.4096
0.6896
0.6598
Sonoma 2019 Annual LDT2 GAS
5 0.18
0.1247
0.1810
0.2264
1240.5727
0.0115
0.0106
Sonoma 2019 Annual LDT2 DSL
5 0
0.2691
0.3063
0.1883
882.2919
0.0296
0.0283
Sonoma 2019 Annual MDV GAS
5 0.12
0.2850
0.3994
0.4497
1665.3488
0.0122
0.0112
Sonoma 2019 Annual MDV DSL
5 00.2141
0.2438
0.1690
1094.7699
0.0240
0.0229
Sonoma 2019 Annual MCY GAS
5 0.01
13.7447
16.6018
1.5620
543.2175
0.0104
0.0097
Sonoma 2019 Annual LHDT1 GAS
5 0.02
0.49548
0.71731
0.85168
1400.99808
0.01178
0.01083
Sonoma 2019 Annual LHDT1 DSL
5 0.02
0.83210
0.94729
3.81068
1290.25429
0.13931
0.13328
Sonoma 2019 Annual LHDT2 GAS
5 0
0.19449
0.28380
0.48389
1482.32785
0.00715
0.00657
Sonoma 2019 Annual LHDT2 DSL
5 0.01
0.77184
0.87869
2.66373
1345.06716
0.09704
0.09284
Sonoma 2019 Annual
100%
0.297
0.388
0.330
1093.033
0.016
0.015
IdleVehicle Emission Rate=
1.486
1.939
1.651
5465.165
0.081
0.076
gram/hr
hosed
on 5mph
emission mteforl hour(5mifes)
Assume 12 vehicles constantly Idling per peak demand hour=
17.83
23.27
19.82
65581.97
0.98
0.91
gram/hr
Assume peak demand hour is 10% of daily emission rate=
178.29
232.58
198.16
655819.75
9.77
9.09
gram/day
0.07
0.09
0.08
239.16
0.004
0.004
tons/year (metric
tons COte)
Source of idle emissions (from CARE, see http,,Ilt" w.arb.ca.gov/mse(/modeling.htm )
Idling Emission Rates for EMFAC2O11-LDV Vehicle
Categories
Step 1 -E-5 MPH Running emission rates from Emission Rate Web Database at
http://-.arb.ca.gov%jpubMw bapp//EMFAC2011WehApp/r.teSelectl.nPage_1.Jsp.
Step 2 -Calculate the by model year LDV Idling emission rates by muidplying the 5 MPH Punning
mission rates by 5 (g/mile X mile/hr= g/hr)•
13-26
Vehicle Idle Emissions From Clueing at Gas Station
EMFAC2014 (v1.0.7) Emission Rates
Region Type: County
Region: Sonoma
Calendar Year: 2019
Season: Annual
Units: miles/day for VMT, g/mile for RUNEX, PMBW and PMTW
Area
CalYr
Season Veh Fuel
Speed VMT
Assumed %
of Vehicles
Toy Evap RL
Sonoma
2019
Annual LDA GAS
5
0.58
0.048473207
Sonoma
2019
Annual LDA DSL
5
0.01
0
Sonoma
2019
Annual LDT1 GAS
5
0.05
0.313470559
Sonoma
2019
Annual LDT1 DSL
5
0
0
Sonoma
2019
Annual LDT2 GAS
5
0.18
0.101229584
Sonoma
2019
Annual LDT2 DSL
5
0
0
Sonoma
2019
Annual MDV GAS
5
0.12
0.161045132
Sonoma
2019
Annual MDV DSL
5
0
0
Sonoma
2019
Annual MCY GAS
5
0.01
1.031992068
Sonoma
2019
Annual LHDT1 GAS
5
0.02
0.928532625
Sonoma
2019
Annual LHDTI DSL
5
0.02
0
Sonoma
2019
Annual LHDT2 GAS
5
0
0.390995228
Sonoma
2019
Annual LHDT2 DSL
5
0.01
0
Average 5 mph Emission Rate
100%
0.110
IdleVehicle Emission Rate =
0.551
gram/hr
Assume 12 vehicles constantly idling per peak demand hour =
6.61
gram/hr
Assume peak demand hour is 10% of daily emission
rate =
66.14
gram/day
ource of idle emissions (from CARE, see http://Www.arb.co.govlmsellmodeling.htm)
Ming Emission Rates for EMFAC2011-LDV Vehicle Categories
:ep 1 — Extract 5 MPH Running emission rates from Emission Rate Web Database at
ttp://www. a rb. ca.gov/j pub/weba pp//EM FAC2011 W ebAp p/ra teSel ectionPa ge_Lisp.
:ep 2—Calculate the by model year LDV idling emission rates by multiplying the 5 MPH Running emission rates
J5 (g/mile X mile/hr = g/hr).
13-27
Diesel Vehicle DPM Idle Emissions From Clueing at Gas Station
EMFAC2014 (v1.0.7) Emission Rates
Region Type: County
Region: Sonoma
Calendar Year: 2019
Season: Annual
Units: miles/day for VMT,
g/mile for RUNEX, PMBW and PMTW
Assumed
of Diesel
DPM
Area
CalYr Season
Veh
Fuel
Speed
VMT Vehicles
PM2_5_RUNEX
Sonoma
2019 Annual
LDA
GAS
5
0
0.0109
Sonoma
2019 Annual
LDA
DSL
5
0.2077
0.0878
Sonoma
2019 Annual
LDT1
GAS
5
0
0.0158
Sonoma
2019 Annual
LDT1
DSL
5
0.0016
0.6598
Sonoma
2019 Annual
LDT2
GAS
5
0
0.0106
Sonoma
2019 Annual
LDT2
DSL
5
0.0088
0.0283
Sonoma
2019 Annual
MDV
GAS
5
0.0112
Sonoma
2019 Annual
MDV
DSL
5
0.056
0.0229
Sonoma
2019 Annual
MCY
GAS
5
0
0.0097
Sonoma
2019 Annual
LHDT1
GAS
5
0
0.01083
Sonoma
2019 Annual
LHDT1
DSL
5
0.5698
0.13328
Sonoma
2019 Annual
LHDT2
GAS
5
0
0.00657
Sonoma
2019 Annual
LHDT2
DSL
5
0.1558
0.09284
Sonoma
2019 Annual
100%
0.111
IdleVehicle Emission Rate =
0.556
based on 5 mph emission rate for 1 hour (5 miles) gram/hr
Assume 0.432 (3.6% of 12/hour) vehicles constantly idling per peak demand hour = 0.24
(4% of all vehicles are diesel) gram/hr
Assume peak demand hour is 10% of daily emission rate = 2.40
gram/day
wn
Hourly rate based on GDF operation fc
Source of idle emissions (from CARE, see http://www.arb.co.govlmseilmodeling,htm )
Idling Emission Rates for EMFAC2011-LDV Vehicle Categories
Step 1 — Extract 5 MPH Running emission rates from Emission Rate Web Database at
http://www. a rb.ca.gov/j p u b/weba pp//EM FAC2011 W ebAp p/rateSelecti o nPage_l.jsp.
Step 2—Calculate the by model year LDV idling emission rates by multiplying the 5 MPH Running
emission rates by 5 (g/mile X mile/hr = g/hr).
13-28
Customer Vehicle DPM Exhaust Emission Factor Calculations
= Composite DPM Emission Factor (g/VMT)
= No, diesel vehicle trips
35,054
Total Project Veh Diesel VMT = 302645
Total Project Veh Gas VMT= 8196407 984,405 = No. Total project trips/year
Total Project Veh Type VMT= 8499052 3.6% %diesel based on d trips
Safeway, Petaluma - Operational Emissions - Customer Vehicle Travel DPM Emissions
Diesel VMT
Project
Ann Diesel Veh
DPM
Annual
Diesel VMT
Fraction of
Fraction of
Diesel Veh
Project Trips
Emission
Vehicle
Fraction
All Diesel
of All Frei
Type
Based on
Factor
Type
of Class
VMT
Vehicles VMT
Distribution
VMT Fraction
(g/VMT)
LDA
0.012541755
0.20769489
0.0073959
0.208
7,281
0.024008291
LDT1
0.002363006
0.00155173
0.0000553
0.002
54
0.182301927
LDT2
0.001406215
0.00882815
0.0003144
0.009
309
0.00937924
LHDTS
0.545068081
0.56977774
0.0202894
0.570
19,973
0.046698045
LHDT2
0.678912473
0.155812
0.0055484
0.156
5,462
0.034327422
MDV
0.011766193
0.05633521
0.0020061
0.056
1,975
0.008876395
19
1876
0.36
0.52
7.48E-05
12
0.03781
Total
-
1.00
0.03561
1.00
35,054
<---
= Composite DPM Emission Factor (g/VMT)
= No, diesel vehicle trips
35,054
Total Project Veh Diesel VMT = 302645
Total Project Veh Gas VMT= 8196407 984,405 = No. Total project trips/year
Total Project Veh Type VMT= 8499052 3.6% %diesel based on d trips
Safeway, Petaluma - Operational Emissions - Customer Vehicle Travel DPM Emissions
I Default EMFAC2014 vehicle mix for diesel vehicles (LDA, LDTI, LDT2, LHDTI, LHDT2, and MDV)
2 Annual one-way trips
3 Emission factors developed from EMFAC2014 for Sonoma County
4 Station operation assumed to be from 5 am to 12 am, 365 days per year
Safeway, Petaluma - Operational Emissions - Fuel Delivery Truck DPM Emissions 2019
Daily
PM2.5
Annual
Average Hourly Emissions (Ih/hr)4
Annual
Average
Line
Emissions
TOG
Number
Emissions
Average Hourly
Operation'
DPM
Hourly
Factors'
Source
Truck
(Ib/year)
Emissions (Ib/hr)4
Total
Factor
Schedule
Travel Distance
Line
Emissions
Annual
Operation
Round Trip
Name
Source
Vehicle
Diesel
DPM
Schedule
Travel Distance
Total
Total
feet
miles
Route
Name
Type'
Trips
/VNI
hrs/da
DPM
DPM
West Route
West
Diesel
35,054
0.0378
19
2695
0.51
0.75
1.08E-04
East Route
East
Diesel
35,054
0.0378
19
1876
0.36
0.52
7.48E-05
I Default EMFAC2014 vehicle mix for diesel vehicles (LDA, LDTI, LDT2, LHDTI, LHDT2, and MDV)
2 Annual one-way trips
3 Emission factors developed from EMFAC2014 for Sonoma County
4 Station operation assumed to be from 5 am to 12 am, 365 days per year
Safeway, Petaluma - Operational Emissions - Fuel Delivery Truck DPM Emissions 2019
I HHDT = heavy heavy duty truck
2 Annual trips - Based on 365 days of operation
3 Emission factor from EWAC2014 for Sonoma County for operation in 2019 and assumes all trucks are diesel.
4 Cas truck delivery hours assumed to be 24 hours per day, 365 days per year
Safeway, Petaluma - Operational Emissions - Customer Vehicle Travel
Daily
PM2.5
Annual Emissions Ob/year)
Average Hourly Emissions (Ih/hr)4
Annual
Average
Line
Total
TOG
Number
Total
Emission
Operation'
DPM
Hourly
TOG
Source
Truck
Vehicle
Round
Annual
Factor
Schedule
Travel Distance
Emissions
Emissions
(feet)
(miles)
Truck Route
Name
Delivery
Type'
Trucks
Trips
(g/mi)
(hrs/da)
lb/year)
Ib/hr)
Gas truck Route
TRUCKS
Gas Station
HHDT
2
730
0.03221
24
3132
0.59
0.031
3.51E-06
I HHDT = heavy heavy duty truck
2 Annual trips - Based on 365 days of operation
3 Emission factor from EWAC2014 for Sonoma County for operation in 2019 and assumes all trucks are diesel.
4 Cas truck delivery hours assumed to be 24 hours per day, 365 days per year
Safeway, Petaluma - Operational Emissions - Customer Vehicle Travel
'Default EMFAC2014 vehicle nix for LDA, LOT, and MDT
'Annum one- ly trips
' Endssian factors developed from ENIFAC2014 for Samara County
'Station operation uxuaned to be from 5 am b 12 an, 365 days per pear
' Starting endssions occurat gex station, auum d to occur once perround trip
13-29
Emissions Factors'
Annual Emissions Ob/year)
Average Hourly Emissions (Ih/hr)4
Line
Total
TOG
TOG Start
TOG
Operation4
Round Trip
TOG'
TOG
TOG
TOG
Source
Vehicle
Annual
P512.5
Exhaust
Exhaust
Run Loss
Schedule
Travel Distance
Total
TOG
Starting
Running
Total
TOG
Starting
Running
(fceU
6nilcs)
Route
Name
Type'
Trips'
( 1T)
(gMM
( tip)
(gfVAM
(hrsldav)
PN12.5
Exhaust
Exhaust
Loss
Pa12.5
Ehaustli
Exhaust
Loss
West Route
West
Default
984,405
0.0217
0.0467
0.2632
0.1196
19
2695
MI
12
26
286
66
1.73E-03
3.73E-03
4.12E-02
9.55E-03
East Route
East
Default
984,405
0.0217
0.0467
0.2632
0.1196
19
1876
0.36
8
18
286
46
1.21E-03
2.60E-03
4.12E-02
6.65E-03
'Default EMFAC2014 vehicle nix for LDA, LOT, and MDT
'Annum one- ly trips
' Endssian factors developed from ENIFAC2014 for Samara County
'Station operation uxuaned to be from 5 am b 12 an, 365 days per pear
' Starting endssions occurat gex station, auum d to occur once perround trip
13-29
BAAQMB Permit Evaluation
EVALUATION REPORT
Safeway Fuel Center #3011
Facility ID#200026
Application #405'215
S. McDowell Blvd & Maria Drive, Petaluma, CA 94954
BACKGROUND
Safeway Inc. has submitted this application to construct a new gasoline dispensing facility — Safeway
Fuel Center #3011
This .station is within 1,000 feet of McDowell Elementary School and the project increases Precursor
Organic Compound (POC) and Benzene emissions. Thus, the projects trigger the Public Notice
requirements under California Health &- Safety Code and District's Regulation 2-1-412.
The facility will be equipped with two (2) 20,000 gallon underground storage tanks, eight (8) triple -
product gasoline nozzles Phase I C'S'I EVR, Phase II VST Balance with Veeder Root Vapor Polisher and
Veeder-Root ISD EVR.
A Health Risk Screening Analysis (HRSA) was performed for this application indicates that a throughput
of 25.71 million -gallons per year is acceptable per District's Risk Management Policy. Accordingly, this
station will be conditioned to 25.71 million gallons per year.
Before this project can be approved, a 30 -day public coinuent period will be held. Notice describing the
project and announcing the public coniment period will be mailed to the parents of students attending the
above schools and residential and business neighbors within 1,000 feet of the station. The cost of
preparing and distributing this notice will be paid by the applicant.
EMISSION CALCULATIONS
Emission factors are taken from the Gasoline Service Station hidustry-wide Risk Assessment Guidelines
developed by the California Air Pollution Officers Association's (CAPCOA) Toxics Committee.
Emissions of Precursor Organic .Compound (POC) include emissions from loading, breathing; refiueling
and spillage. The annual gasoline throughput of 25.71 million gal per year is based on the results of the
Air Toxics Risk Screening.
Table 1 - Emissions Calculation
Pollutant Emissions Factors
Emissions
Emissions
Emissions
(111/thousandgallon)
(lb/day)
(lb/year)
(ton/year)
POC 0.670
47.19
17,225.7
8.613
Benzene 0.00369
026
94.87
0.047
13-30
BEST AVAILABLE CONTROL TECHNOLOGY (BACT
The proposed annual throughput emits more than 10 pounds of VOC in a single day_ Thus the Best
Available Control Tech nology (BACT) requirement of Regulation 2-2-301 is triggered.
BACT for Gasoline Dispensing Facilities (GDFs) is considered the nue of GARB -certified Phase -I and
Phase -II vapor recovery equipment.
Safeway Fuel Center 43011 will meet the requirement by using CNI 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 GARB under Executive Orders VR -104 and VR -204 respectively.
BEST AVAILABLE CONTROL TECHNOLOGY FOR TOXICS (TBACT)
The expected increased health risk from this project exceeds 1 per million, triggering the use of TBACT
equipment. TBACT for GDFs is considered the use of CARB-ceftified Phase -I and Phase -II vapor
recovery equipment.
Safeway Fuel Center #3011 will meet this through the use of CNI EVR Phase I equipment and VST
Balance EVR Phase H equipment with the Veeder-Root Vapor Polisher and Veeder-Root ISD controls.
The t« o systems are certified by CARB under Executive Orders VR -104 and VR -204 respectively.
HEALTH RISK. SCREENING ANALYSIS (HRSA)
An HRSA was required since the increased benzene emissions exceed the toxic air contaminant risk
triggering level specified in Regulation 2-5 table 2-5-1. For a GDF that meets the TBACT requirement, it
mist also pass the toxic risk screening level of less than ten in a million. The facility meets the risk
standards with 25.71 million gallons of annual throughput.
PUBLIC NOTIFICATION
This station is within 1,000 feet of McDowell Elementary School and the project increases emissions.
Thus, the projects trigger the Public Notice requirements under California Health & Safety Code and
District's Regulation 2-1-412. Before this project can be approved, a 30 -day public continent period will
be held. Notice describing the project and announcing the public conunnent period will be mailed to the
parents of students attending the above schools and people living within 1,000 feet of the station. The cost
of preparing and distributing this notice will be paid by the applicant.
13-31
Safeway, Petaluma - Operational Emissions - Gas Station Benzene Emissions
Annual
Gasoline
Annual
Benzene
Emission
Operation"
Benzene Emissions
Annual
Average
Throughput
ROG Emissions
Factor
Schedule
Average
Hourly
Source (103 gallons/year)
(lb/ ear)
(Ib/103 Gallon)
hrs/da
lb/ ear)
(lb/hr)
16 -Pump Fuel Station 8,500
5,695
0.00369
19
31.4
0.00452
'votes:
1. BAAQ.MD 2013. Authority to Construct for Permit Application No. 405215 at S. McDomil Blvd & Maria Drive, Petaluma, CA 94954. Dated October 10, 2013.
2. Daily operation hours assumed to be 5:00 AM to 12:00 AM, 365 days per year
'as Station Modeling Emissions and Volume Source Parameters
Operation
Number of
Volume
Sources
Annual Emissions (Ib/ ear)
Avera a Hourly Emissions (1b/hour)
Volume Source
Release Ht
(meters)
PM2.5 TOG
Total Average
Number of
Emissions
Volume Source Dimensions
Volume Source'
Idle
Percent of
Hourly Emissions
Volume
per Volume
(meters)
Release Height
:mission Source
Total Emissions
(lb/hr)
Sources
(lb/hr)
Length Width Height
(meters)
refueling
67%
0.0030
4
0.00076
13.0 13 4
1
!pillage
33%
0.0015
4
0.00037
13 13 4
0
Notes:
1. CAPCOA Air Toxics "Hot Spots" Program, Gasoline Service Station Industrywide Risk Assessment Guidelines, November 1997.
Safeway, Petaluma - Operational Emissions - Gas Station Customer TOG and PM2.5 Emissions
Annual
Operation
Number of
Volume
Sources
Annual Emissions (Ib/ ear)
Avera a Hourly Emissions (1b/hour)
Volume Source
Release Ht
(meters)
PM2.5 TOG
I TOG TOG PnI2.5 TOG TOG
TOG
Vehicles
Schedule
Idle
Idle
Starting Running Total
I
Idle
Idle
Starting
Running
Source (vehicles/ ear)
(lurs/da)
Exhaust
Exhaust
Exhaust Loss TOG
Exhaust
Exhaust
Exhaust
Loss
Customer Vehicles 492,203
19
7.30
186.15
285.61 54.75 526.51
0.0011
1 0.0268 1
0.0412 1
0.0079
Notes:
1. Daily operation hours assumed to be 5:00 ANI to 12:00 AM, 365 days per year
- Cr.,H.... TTnanl:n n Fm:cci.....a V.h- e-.... P.,- -.
Emission Source
Average
Hourly Emissions
(Ib/hr)
Number of
Volume
Sources
Emissions
per Volume
(Ib/hr)
Volume Source Dimensions
(meters)
Volume Source
Release Ht
(meters)
Len th
Width
Height
Idle-PM2.5
0.0011
1
0.00105
20
20
2
1
Idle -TOG Exhaust
0.0268
1
0.02684
20
20
2
1
Idle -TOG Running Loss
0.0079
1
0.00789
20
20
2
1
Slatting - TOG Exhaust
0.0412
4
0.01030
13
13
4
I
13-32
Safeway, Petaluma
Health Risk Impact Summary - Project Operation
Maximum Cancer Risks
Maximum Non -Cancer Health Effects
Maximum Cancer Risks (per million)
Total
DPM
Benzene
TOG
Operational
Sensitive Receptor Type
Vehicles
GDF
Total
Cancer Risk
Off -Site Residential (30 -year exposure)
1.41
1.94
1.66
5.0
Daycare/Student(9-year exposure)
0.12
0.16
0.14
0.4
Daycare Worker/Teacher (25 -year exposure)
0.09
0.11
0.10
0.3
Maximum Non -Cancer Health Effects
13-33
Maximum Chronic Hazard Index
Total
DPM
Benzene
TOG
Hazard
Sensitive Receptor Type
Vehicles
GDF
Total
Index
Off -Site Residential (30 -year exposure)
3.80E-04
0.010
0.002
0.012
Daycare/Student (9 -year exposure)
2.02E-04
0.005
0.001
0.006
Daycare Worker/Teacher (25 -year exposure)
2.02E-04
0.005
0.001
0.006
Maximum Acute Hazard Index
Total
DPM
Benzene
TOG
Hazard
Sensitive Receptor Type
Vehicles
GDF
Total
Index
Off -Site Residential (30 -year exposure)
0.044
0.007
0.051
Daycare/Student (9 -year exposure)
0.020
0.019
0.039
Daycare Worker/Teacher (25 -year exposure)
-
0.020
0.019
0.039
Maximum Annual PM2.5 ( g/m3)
PM2.5
PM2.5
Customer Travel
Total
Sensitive Receptor Type
Trucks
and Idling
PM2.5
Off -Site Residential (30 -year exposure)
0.00004
0.018
0.018
Daycare/Student (9 -year exposure)
0.00005
0.010
0.011
Daycare Worker/Teacher (25 -year exposure)
0.00005
0.010
0.011
13-33
Safeway, Petaluma
AERMOD Risk Modeling Parameters and Maximum TAC Concentrations
Off -Site Residential Receptors
Receptor at Location of Maximum Cancer Risk from Project Operation
Receptor Information
Number of Receptors
Receptor Height =
Receptor distances =
Meteoroloeical Conditions
Petaluma Meteorological Data
Land Use Classification
Wind speed =
Wind direction =
63
1.5 meters
variable - at nearby residences
2013-2017
urban
variable
variable
MEI Maximum Concentrations
Non -Cancer Health Effects
TAC
Concentration gtglm3)
Project O eration
Chronic
TAC
Max Period Average
Max 1 -hour
Average
DPM
0.001900
-
Vehicle TOG Exhaust
0.383580
14.81
Vehicle TOG Evaporative
0.108600
2.19
Benzene
0.028600
1.18
PM2.5
Delivery Trucks
0.00004
Customer Vehicles
1
0.0184
PM2.5 Total
0.01844
Non -Cancer Health Effects
TAC
Project Operation
Hazard Index
Acute
Chronic
DPM
3.80E-04
Vehicle TOG Exhaust
4.51E-03
1.35E-03
Vehicle TOG Evaporative
2.88E-03
9.05E-04
Benzene
4.35E-02
9.53E-03
Total
0.051
0.0122
13-34
Safeway, Petaluma
Maximum Cancer & Non -Cancer Health Impacts
at Location of Maximum Cancer Risk from Project Operation
30 -Year Residential Exposure
Cancer Risk Calculation Method
Cancer Risk (per million) = CPF x Inhalation Dose x ASF x ED/AT x FAH x LOE6
Where: CPF =Cancer potency factor (mg/kg -day)-'
ASP = Age sensitivity factor for specified age group
ED = Exposure duration (years)
AT = Averaging time for lifetimecancer risk (years)
FAH =Fraction of time spent at home (unitless)
Inhalation Dose =C, xDBRx Ax(EF/365)x70'6
Where: C&= concentration in air (pg/m')
DBR= daily breathing rate (L /kg body weight -day)
A = Inhalation absorption factor
EF = Exposure frequency (days/year)
10-6 =Conversion factor
Values
• 95th percentile b=thing rates for infams and 80th percentile for etuldren and adults
Cancer Potency Factors and Reference Exposure Levels (REL)
Infant/Child Adult
Age .->
3rd Trimester
0-<2
2-<16 16-70
Parameter
ASF
10
10
3 1
DBR' =
361
1090
572 261
A=
1
1
1 I
EF=
350
350
350 350
ED=
0.25
2
14 14
AT=
70
70
70 70
FAH=l
1.00
I 1.00
1 1.00 1 0.73
• 95th percentile b=thing rates for infams and 80th percentile for etuldren and adults
Cancer Potency Factors and Reference Exposure Levels (REL)
Project Operation Cancer Risk- Maximum Project Operation Impact Residential Receptor Location
Exposure
CPF
REL
(pg/m)
Acute
Chronic
TAC
mglkg-day)-r
1 -hour)
(ann ave
DPM
1.10E+00
-
5
Vehicle TOG Exhaust
6.28E-03
3283
284
Vehicle TOG Evaporative
3.70E-04
762
120
Benzene
1.00E-01
27
3
Project Operation Cancer Risk- Maximum Project Operation Impact Residential Receptor Location
Exposure
Exposure
Duration
Age
Sensitivity
Maximum - Exposure Information
Annual Cone (ug/m3
Cancer Risk(per million
Exhaust
Evaporative
Exhaust
Evaporative
Year
Year
ears
Age
Factor
DPM
TOG
TOG
Benzene
DPM
TOG
TOG
Benzene
Total
0
2019
0.25
-0.25-0-
10
0.00190
0.383580
0.10860
0.02860
0.0258
0.0298
0.0005
0.0354
0.09
1
2019
1
1
10
0.00190
0.383580
0.10860
0.02860
0.3121
0.3597
0.0060
0.4270
1.10
2
2020
1
2
10
0.00190
0.383580
0.10860
0.02860
0.3121
0.3597
0.0060
0.4270
1.10
3
2021
1
3
3
0.00190
0.383580
0.10860
0.02860
0.0491
0.0566
0.0009
0.0672
0.17
4
2022
1
4
3
0.00190
0.383580
0.10860
0.02860
0.0491
0.0566
0.0009
0.0672
0.17
5
2023
1
5
3
0.00190
0.383580
0.10860
0.02860
0.0491
0.0566
0.0009
0.0672
0.17
6
2024
1
6
3
0.00190
0.383580
0.10860
0.02860
0.0491
0.0566
0.0009
0.0672
0.17
7
2025
1
7
3
0.00190
0.383580
0.10860
0.02860
0.0491
0.0566
0.0009
0.0672
0.17
8
2026
1
8
3
0.00190
0.383580
0.10860
0.02860
0.0491
0.0566
0.0009
0.0672
0.17
9
2027
1
9
3
0.00190
0.383580
0.10860
0.02860
0.0491
0.0566
0.0009
0.0672
0.17
10
2028
1
10
3
0.00190
0.383580
0.10860
0.02860
0.0491
0.0566
0.0009
0.0672
0.17
11
2029
1
11
3
0.00190
0.383580
0.10860
0.02860
0.0491
0.0566
0.0009
0.0672
0.17
12
2030
1
12
3
0.00190
0.383580
0.10860
0.02860
0.0491
0.0566
0.0009
0.0672
0.17
13
2031
1
13
3
0.00190
0.383580
0.10860
0.02860
0.0491
0.0566
0.0009
0.0672
0.17
14
2032
1
14
3
0.00190
0.383580
0.10860
0.02860
0.0491
0.0566
0.0009
0.0672
0.17
15
2033
1
15
3
0.00190
0.383580
0.10860
0.02860
0.0491
0.0566
0.0009
0.0672
0.17
16
2034
1
16
3
0.00190
0.383580
0.10860
0.02860
0.0491
0.0566
0.0009
0.0672
0.17
17
2035
1
17
1
0.00190
0.383580
0.10860
0.02860
0.0055
0.0063
0.0001
0.0075
0.02
18
2036
1
18
1
0.00190
0.383580
0.10860
0.02860
0.0055
0.0063
0.0001
0.0075
0.02
19
2037
1
19
1
0.00190
0.383580
0.10860
0.02860
0.0055
0.0063
0.0001
0.0075
0.02
20
.
2038
.
.
1
.
20
.
.
1
.
0.00190
.
0.383580
.
.
0.10860
.
0.02860
.
0.0055
.
0.0063
.
0.0001
.
0.0075
.
0.02 -
.
.
.
21
.
2039
.
.
1
.
21
.
.
1
.
.
0.00190
.
0.383580
.
.
0.10860
.
.
0.02860
.
.
0.0055
.
.
0.0063
.
.
0.0001
.
.
0.0075
.
.
0.02
22
2040
1
22
1
0.00190
0.383580
0.10860
0.02860
0.0055
0.0063
0.0001
0.0075
0.02
23
2041
1
23
1
0.00190
0.383580
0.10860
0.02860
0.0055
0.0063
0.0001
0.0075
0.02
24
2042
1
24
1
0.00190
0.383580
0.10860
0.02860
0.0055
0.0063
0.0001
0.0075
0.02
25
2043
1
25
1
0.00190
0.383580
0.10860
0.02860
0.0055
0.0063
0.0001
0.0075
0.02
26
2044
1
26
1
0.00190
0.383580
0.10860
0.02860
0.0055
0.0063
0.0001
0.0075
0.02
27
2045
1
27
1
0.00190
0.383580
0.10860
0.02860
0.0055
0.0063
0.0001
0.0075
0.02
28
2046
1
28
1
0.00190
0.383580
0.10860
0.02860
0.0055
0.0063
0.0001
0.0075
0.02
29
2047
1
29
1
0.00190
0.383580
0.10860
0.02860
0.0055
0.0063
0.0001
0.0075
0.02
30
2048
1
30
1
0.00190
0.383580
0.10860
0.02860
0.0055
0.0063
0.0001
0.0075
0.02
Total Increased
Cancer Risk
I
1
1
1.41 1
1.63 1
0.03 1
1.94
5.0
Thud trimester of pregnancy
13-35
Safeway, Petaluma
AERMOD Risk Modeling Parameters and Maximum TAC Concentrations
Off -Site SchooVDaycare Receptors
Receptor at Location of Maximum Cancer Rislc from Project Operation
Receptor Information
Number of Receptors
Receptor Height =
Receptor distances =
Meteorological Conditions
Petaluma Meteorological Data
Land Use Classification
Wind speed =
Wind direction =
80
1.0 meters
variable - within daycare and school areas
2013-2017
urban
variable
variable
MEI Maximum Concentrations
Non -Cancer Health Effects
TAC
Concentration ( /m3)
Project Operation
Chronic
Max Period Average
Max 1 -hour
Average
TAC
DPM
0.001010
-
Vehicle TOG Exhaust
0.204010
30.92
Vehicle TOG Evaporative
0.061520
7.13
Benzene
0.014280
0.55
PM2.5
Delivery Trucks
0.00005
Customer Vehicles
0.01046
PM2.5 Total
0.01051
Non -Cancer Health Effects
TAC
Project Operation
Hazard Index
Acute
Chronic
DPM
2.02E-04
Vehicle TOG Exhaust
9.42E-03
7.18E-04
Vehicle TOG Evaporative
9.36E-03
5.13E-04
Benzene
2.04E-02
4.76E-03
Total
1 0.039
0.006
13-36
Safeway, Petaluma
Maximum Cancer & Non -Cancer Health Impacts
at Location of Maximum Cancer Risk from Project Operation
9 -Year Daycare/School Child Exposure
Cancer Rish Calculation Method
Cancer Risk (per million) = CPF x Inhalation Dose x ASF x ED/AT x FAH x LOE6
Where: CPF =Cancer potency factor(mg/kaday)-t
ASF = Age sensitivity factor for specified age group
ED = Exposure duration (years)
AT = Averaging time for lifetime cancer risk (years)
FAH = Fraction of time spent at home (unilless)
Inhalation Dose = C.; x DBR x A x (EF/365) x 10-6
Where: Ci, =concentration in air (pa)
DBR daily breathing rate (L/kg body weight -day)
A = Inhalation absorption factor
EF =Exposure frequency (days/year)
10b = Conversion factor
Values
Cancer Potenev Factors and Reference Exnosure Levels (REL)
Infant/Child
Adult
Age --
3rd Trimester
0-<2
2-<16
(school child)
16-70
Parameter
ASF
10
10
3
1
DBR* =
361
1090
572
261
A=
1
I
1
1
EF =
350
350
180
350
ED=
0.25
2
14
14
AT=
70
70
70
70
FAH =
1.00
1.00
1.00
0.73
95th -tile
hreathinu rates forinfants
and 80th D-atile
for children and
adults
Cancer Potenev Factors and Reference Exnosure Levels (REL)
Proiect Operation Cancer Risk- Maximum Proiect Operation Impact Daycare/School Child Recentor Location
Exposure
_•-•_
CPF
REL (t ma)
Acute
Chronic
TAC
(-g/kg-day)-'
1 -hour)
(ann ave
DPM
1.10E+00
-
5
Vehicle TOG Exhaust
6.28E-03
3283
284
Vehicle TOG Evaporative
3.70E-04
762
120
Benzene
1.00E-01
27
3
Proiect Operation Cancer Risk- Maximum Proiect Operation Impact Daycare/School Child Recentor Location
Exposure
Exposure
Duration
Age
Sensitivity
Maximum - Exposure Information
Annual Cone (ug/m3
Cancer Risk ter million)
Exhaust
Evaporative
Exhaust
Evaporativ
Year
Year
(years)
Age
Factor
DPM
TOG
TOG Benzene
DPM
TOG.
TOG
Benzene
Total
1 2019
1
5
3
0.00101
0.204010
0.06152
0.01428
0.0134
0.0155
0.0003
0.0173
0.05
2 2020
1
6
3
0.00101
0.204010
0.06152
0.01428
0.0134
0.0155
0.0003
0.0173
0.05
3 2021
1
7
3
0.00101
0.204010
0.06152
0.01428
0.0134
0.0155
0.0003
0.0173
0.05
4 2022
1
8
3
0.00101
0.204010
0.06152
0.01428
0.0134
0.0155
0.0003
0.0173
0.05
5 2023
1
9
3
0.00101
0.204010
0.06152
0.01428
0.0134
0.0155
0.0003
0.0173
0.05
6 2024
1
10
3
0.00101
0.204010
0.06152
0.01428
0.0134
0.0155
0.0003
0.0173
0.05
7 2025
1
11
3
0.00101
0.204010
0.06152
0.01428
0.0134
0.0155
0.0003
0.0173
0.05
8 2026
1
12
3
0.00101
0.204010
0.06152
0.01428
0.0134
0.0155
0.0003
0.0173
0.05
9 2027
1
13
3
0.00101
0.204010
0.06152
0.01428
0.0134
0.0155
0.0003
0.0173
0.05
Total Increased Cancer Risk
1
1 0.12
0.14
0.002
1 0.155
1 OA
13-37
Safeway, Petaluma
AERMOD Risk Modeling Parameters and Maximum TAC Concentrations
Off -Site School/Dayeare Receptors
Location of Maximum Daycare/School Cancer Risk from Project Operation
Receptor Information
Number of Receptors
Receptor Height =
Receptor distances =
Meteorological Conditions
Petaluma Meteorological Data
Land Use Classification
Wind speed =
Wind direction =
80
1.0 meters
variable - within daycare and school areas
2013-2017
urban
variable
variable
MEI Maximum Concentrations
Non -Cancer Health Effects
TAC
Concentration (µg/m3
Project Operation
Chronic
Max Period Average
Max 1 -hour
Average
TAC
DPM
0.001010
-
Vehicle TOG Exhaust
0.204010
30.92
Vehicle TOOT Evaporative
0.061520
7.13
Benzene
0.014280
0.55
PM2.5
Delivery Trucks
0.00005
Customer Vehicles
0.01046
PM2.5 Total
0.01051
Non -Cancer Health Effects
TAC
Project Operation
Hazard Index
Acute
Chronic
DPM
2.02E-04
Vehicle TOG Exhaust
9.42E-03
7.18E-04
Vehicle TOG Evaporative
9.36E-03
5.13E-04
Benzene
2.04E-02
4.76E-03
Total
1 0.039
1 0.006
13-38
Safeway, Petaluma
Maximum Cancer & Non -Cancer Health Impacts
at Location of Maximum Daycare/School Cancer Risk from Project Operation
25 -Year Daycare Worker/School Teacher Exposure
Cancer Risk Calculation Method
Cancer Risk (per million) = CPF x hihalation Dose x ASF x ED/AT x FAH x LOE6
Where: CPF = Cancer potency factor (mg/kg-dayyl
ASF = Age sensitivity factor for specified age group
ED = Exposure duration (years)
AT = Averaging time for lifetime cancer risk (years)
FAH = Fraction of time spent at home (unitless)
Inhalation Dose = Co;, x DBR x A x (EF/365) x 10'6
Where: Co;, = concentration in air (pg/m3)
DBR = daily breathing rate (L/kg body weight -day)
A = Inhalation absorption factor
EF = Exposure frequency (days/year)
10-6 = Conversion factor
Values
Adult
16-70
ASF
CPF
1
DBR* =
Acute
230
A=
(mg/kg -da )-u
1
EF =
DPM
350
ED=
5
25
AT=
3283
70
FAH=
3.70E-04
-
Cancer Potency Factors and Reference Exposure Levels (REL)
_._.._
CPF
REL (pg/m)
Acute
Chronic
TAC
(mg/kg -da )-u
1 -hour)
(ann ave
DPM
1.10E+00
-
5
Vehicle TOG Exhaust
6.28E-03
3283
284
Vehicle TOG Evaporative
3.70E-04
762
120
Benzene
I 1.00E-01
27
3
Project Operation Cancer Risk - Maximum Project Operation Impact Daycare Worker/School Teacher Receptor Location
13-39
Maximum - Exposure Information
Exposure
Initial
Exposure
Age
Annual Cone u /m3
Cancer Risk(per million
Exhaust
Evaporative
Exhaust
vaporative
Year
Exposure
Duration
Sensitivity
Age
Year
(years)
Factor
DPM
TOG
TOG I Benzene
DPM
TOG
TOG Benzene
Total
>16 2019 25
1
0.00101
0.204010
0.06152
0.01428
0.0875
1
0.1009
0.0018
0.1125
0.30
1
Total Increased Cancer Risk
1
0.09
0.10
1 0.002
0.112
0.3
13-39
k
/
a
c
\
8
/
\
O
»
\
/
\
E
§ /
C \
\ � 7
/ R R
± J o
U k
% ® U
E _
\ \
c?
\ E
\ '(
M U)
E
f
\
A
Lo p
\
.
\
E
ƒ
\
»
E
a
a
M
$
Gy
s'
£k
)
m
o r
LL
0
.
p¥
k
,
�
I
\
ƒ
�
e
�
\
I
�
■
I
k
f
J
u
»
—
£
®
7
@2
7
�
kk
\
2
m
7§
9
<
\§
k
o
\
E
»
§
\
n
\
q
°
%
\
\
'
os
k
f\-
An
n
$
±
e
o
/
E
\
c
w
2
%
\
\
/
k
2
E
\
%
'§
)
°
%
\
/
E
\
Co
/
_
k
o
o
§
\
\
c
n
E
k
w/
c
m
C
a
.Q-
/
2
k
\
/
k
\
\
\
\
\
u
\ §
/
C
/
E
/
\
\
§
\
/
\
0
a
G
q
E
\
/
/
O
i Cl) Cl) i co E (1) Cl) 2 co 2 CY) 1,2
11 j C3 1 CD
O C:) C:) c) C3 c) CD 1 C, cl ic, ic, i C�l
C, (:� C� C� i
i i C� a) (L) a) fc� C�aO
C14 C\i 04 00 04
F F is F F F IF F I F F
I
.0
11
r-
m
CD
0)
c
CD
r_
CF)
C:
0)
c
z
:
Lo
(D
0 o
c)
-(D
!
so
i
-
No
i
C�
-
ho
-
m
ca
cu
cu
(13
ca
m
m
€m
C)
q
1 L,
C, 0
C�
6
�
S
C3
C�
(Z�
C�
lo
i
CD
C�
C�
CD
6
C3
c)
c)
c)
o
c)
C)
C)
C)
6
Z,
C',
C,4
0
C)
z
0
z
OO
z
z
0
z
z
LZ
. ..... .... ........
L
. . ......
.. !......�
........... 4L.-...4 ..........
. .......... ...... .....
.. . ...... ..... . .. ...... .....
4 . ............
. 0 .... ..... ....
..... ...... ..........
'0
�o
1_0
�a
-.,o
ami
w co
(U
ca
-2
I
16
I
16
W
t
W
-2
(1)
16
F
its
i
f (1)
LL
i
i
M
C,
4)
-4)
m
C:
c
c
W a)
E E
4)
!
i
€m
i
co
! m
O. CL
i.9
!.2
!.2
!.2
i.2
N
iN
EL
Le
!p
C:
C
1 a
2 12
2
2
-0
10
lo
o
o
o
:3
_j
E E
E
E
E
E
E
E
E
E
:3
=3
Zz
z
z
z
EZ
gZ
LZ
iZ
5Z
..... ....... . 1 . ...........
........ ....
.... .... ....
.
c
r
C:
r
i
i
a
0 o
0
0
0
0
lo
0
OC
0
0
0
0
0
0
o
0
c)
L)
•(a
CO
10
-.9
2
(1
1
(a
(a
m
co
(a
m
co
cc
(U
so)
co
ca
.2) 1.2)
LLM
LO
ip
LLM
11
.2)
M
L
.2)
3)
LL
:3)
LL
-.2)
-
.9)
Lp
1
(n
CIO
t
>
>
>
Q_ CL
D�
E
0-
rL
c
c
c
.5
5
;,5
i's
;*5
i's
i*5
5
.5
<
ty €a
w
C7
w
17
w
w
a
w
€i?'
;w
cr
;w
cr
u
cr
-W
i
a-
-W
0-
w
-a-
w
0-
i w
-07
w
C3
WWW—
u
07
M
(13
(a
0)
(n
c
C:
E
Z
F--
F—
F—
0 0
0
0
0
0
i
0
i
0
C)
o
0
1 o
o
o
10
o
1 0
0
0
,
1
:6
B
C)
L)
L)
;9
i
'L)
L)
Eo•Z
i
Fa
s9
N
M
r
Y
i
M
M
4)
U)
M
0
M
I-
M
Q.
(L
0
4..
0
0
d)
zo
CD
C:
M
M
e0
;r'I,
cq
co
C)
'r,
�m
�CD
i r—
Ic?
-11
-
7
(D
1 C)
C:)
;c)
I(D
1
i c)
i(D
0
c)
-0
c)
c,
LL
W
0
i
J
�
[_
(
i
f
........
r
. . ...........
. ..... ... . .... ............. .. . . .....
€r'(3)
(3) 1 co co
0)
10
co
lCD
-00
-
r-
-(3)
co
r-
0
CL
It
0
C�
c)
C�
c�
0
0
lo
(D
.......
c)
-0
.... .......
EO
i<D
i
. . ............
c)
15
............
-C)
C)
. ......
-C)
0
. . .....
0
10
... .....
-
-0
;CS
..... ......
: c,
i C3
..........
C:)
ZD
. .. ..... ......
-0
i
C�
—
(5,",
C�
0
0
00
(D
C6
lo
IC6
106
6
24
16
106
1(0,
f,
r-
!r-
(0
U)
... . ........
.. ........
. ...........
. . .......
..... .....
...........
------
. . ........
. ........
.. . .......
].Eo
0
E
w
o
1 w
o
... .....
..
...... .....
0
. . ...........
. . .....
..
E
CO
Flo
ca
cu
co
cr
0
7a
0
Q
U)
t:
0
LU
to
O
a)
'a
w
(D
_0
w
co
_0
O
a)
"o
ca
_0
m
0
U)
0
0
0
0
0
a)
0
=3
0
4)
,C3
0
-6
0
E2
E
(1)
>
(a
E2
LL
;F -
W
LL:)
jo
2
52
-2
if
0
i 0
10
1
1
i
C)
3O
0
CL
EU
EU
EU
7
E
E
7E)
0
E2
E2
12
1
ani
KD
(D
KD
co
m
=3
co
cu
m
CL
Cc
cu
C:
M
c
a)
E
Q.
.::i
Q'
W
C:
O
U
7
c
O
U
O
4-
U)
a)
c
c
W
a)
C
(6
a)
U
m
I
LO
�r
M
m
�i
m
T
N
m
0
N
c
:.a
ca
'Ln
V
M
00
5E
d
N
4
O
G
O
u
v
m
41
c
O
U
m
m
E
6_
CD
V-
40
N
a)
UP
C
Lo,
u
CD
LO
A
m
r
U)
4
O
c
O
U
L
-F+
C
O
U
'a
m
m
LO
M
T
N
N
LO
M
r
m
T
N
a,
Y
LO
ri
CYi
LO
LO
ri
13-56
L //NGW /
1111M Acoustics • Air Quality 11
1 II'illotii,brook Court, Shite 120
Petaluma, California 94954
Tel: 707-794-0400 Tai: 707-794-0405
www. ill ing vorthrodkin. coin illro@illingworthrodkin. tout
Date: September 14, 2018
To: Natalie Mattei
Senior Real Estate Manager
Albertsons Companies
11555 Dublin Canyon Road
Pleasanton, CA 94588
From: James A. Reyff & Fred M. Svinth
Illingworth & Rodkin, Me.
1 Willowbrook Court, Suite 120
Petaluma, CA 94954
RE: Safeway Fuel Center CEQA document - Petaluma, CA
SUBJECT: Safeway Fuel Center Health Risk Assessment, Air Quality and Greenhouse
Gas Emissions Assessment, and Noise Study - Response to Comments made
by Meridian Consultants - Job#13-205
This memo addresses continents made by Meridian Consultants in a letter dated September 12,
2018 to the Petaluma City Council regarding the City's Mitigated Negative Declaration that used
information contained in studies prepared by Illingworth & Rodkin, Inc. (I&R). These studies
included the Health Risk Assessment (HRA), Air Pollutant and Greenhouse Gas Emissions
Assessment and the Environmental Noise Assessment.
.AIR QUALITY AND HEALTI3 RISK
CalEEMod Modelina
The HRA and Air Pollutant and Greenhouse Gas Emissions Assessment modeled the project as a
16 -pump fitel station using default CalEEMod modeling settings. The 16 -pump fuel station land
use is assumed to include some sort of building structure, as is typical for such land uses. The
operational air pollutant and greenhouse gas (GHG) emissions are associated with traffic generated
by the fuel station (including idling of vehicles) and not the kiosk building. The addition of the
697 -square foot building would have a negligible effect on the emissions modeling. CalEEMod
generates construction default conditions for projects based on the size range in acreage, which is
13-57
Memo to Natalie Mattei
September 14, 2018 — Page 2
based on surveys conducted by the South Coast Air Quality Management District (SCAQMD)1.
The project falls into the category of a 1 -acre project. Changing the acreage to 0.7 acres or adding
in the additional square footage of the kiosk building would not change the construction period
emissions (this was verified with the model). Note that Safeway offered and the City's Planning
Commission conditioned the project to use, at a minimum, construction equipment that meets U.S.
EPA Tier 3 standards to reduce construction period emissions and associated health risks even
fitrther than the less than significant amounts reflected in the reports.
As described above, the CalEEMod default construction assumptions were used. This included a
grading phase where the Conunenter suggests a trenching phase should have been used in lieu of
the CalEEMod defaults. CalEEMod does not have a defined trenching phase and the model default
site preparation, grading and paving phases were assumed to include activity associated with the
ground work phase of the project. The Conunenter notes that there would be some export of
material not reflected in the modeling; however, that material would be used to balance the site.
There would be approximately 75 truckloads of material need to complete the site balance that was
not included in the modeling. This amount would not substantially affect the construction
emissions estimate. As shown in the HRA results for operation, the contribution of truck traffic
associated with annual operation of the project is negligible and the amount of truck traffic required
during construction would be less.
Health Risk Assessment
The Commenter claims that the HRA should have used the AERIVIOD dispersion model instead
of the ISCST3 model used. This was conducted in accordance with the Bay Area Air Quality
Management District's (BAAQMD) guidance, since there are representative meteorological data
available for Petaluma that are suitable for use with the ISCST3 model. There are no representative
meteorological data available for Petaluma that are suitable for use with the AERMOD model.
As described in the BAAQMD recommended Methods for• Screening and .Modeling local Risks
and Hazards, refined modeling is recommended for projects in which the screening analysis
exceeds the thresholds or a more site-specific characterization is required because it is complex
with multiple sources. Refined models such as ISCST3 and AERMOD require much more site-
specific information, but yield greater characterization of the project and more representative
results. The BAAQMD recommended models for use in refined modeling analysis include the
ISCST3 and AERMOD models.2
While the AERMOD dispersion is the current EPA recommended refined dispersion model for
regulatory applications, as described in the EPA Guideline on Air Qualio) Models, the EPA's
ISCST3 refined dispersion model is considered an alternative model that can be used when
approved by the reviewing regulatory (i.e., the BAAQMD).3 As detailed above, the current
BAAQMD modeling guidance recommends the use of either the AERMOD or ISCST3 models
for CEQA related health risk assessments.
CaIEEMod Users Guide, Appendix E, Technical Source Documentation, Appendix E1, pp7-1 through E -a.
2 Recommended Methods l'or Screening and Modeling Local Risks and Flazards. Bay Area Air Quality Management District
(BAAQMD). May 2012.
a Guideline on Air Quality Models. Appendix w of 40 CPR Part 51.
13-58
Memo to Natalie Mattei
September 14, 2018 — Page 3
For this project, local meteorological data for use in the AERMOD model was not available from
the BAAQMD. However, hourly meteorological data for use with the ISCST3 model from the
Petaluma Airport meteorological station were available from the BAAQMD and used for the
refined modeling in the HRA.
Diesel Fuel
Operation of the project was modeled as only dispensing gasoline. The reactive organic gas (ROG)
emissions from diesel are negligible when compared to gasoline. For this reason, the BAAQMD
pernait does not specifically address diesel fuel storage and dispensing. Volatility is a property of
a liquid fuel that defines its evaporation characteri sties and emissions potential. The vapor
pressure of a fuel is a conunon measure of the volatility or potential for evaporative emissions to
occur. The higher the vapor pressure of the fiiel, the greater the potential for evaporative
emissions. The vapor pressure of diesel fuel is about 500 times lower than that of gasoline,
depending on the gasoline formulation being used and time of year 4. Therefore, evaporative ROG
emissions from diesel fitel are negligible. This is the reason wiry fuel nozzles for diesel fuel pumps
(green nozzles) do not have vapor recovery devices on them while the gasoline nozzles do.
GREENHOUSE GAs EMISSIONS
A Rill analysis of the project's greenhouse gas (GHG) emissions was conducted. The project's
Air Pollutant and Greenhouse Gas Emissions Assessment computed air pollutant and GHG
emissions with the CalEEMod model using a 16 -pump Gasoline/Service Station land use and
found them to be less than the 1,100 metric ton threshold. So, the MND's finding that these
emissions are below the thresholds is well supported by the modeling results contained in the air
quality studies. We note that the computations of operational emissions included conservative
assumptions:
• Use of the CalEEMod default customer travel length of over 7 miles instead of a 3 miles
distance for the typical travel length in Petaluma (i.e., the emissions modeling assumes
customers, on average, would travel 7 miles to purchase fuel) and
• The addition of idling emissions that assume maximum queuing is occurring all day, while
the default CalEEMod mobile emissions account for some idling.
Noin
Calculation of Noise Levels at Sensitive Receptors vs. Property Lines
The noise analysis considers impacts at the location of the actual sensitive receptors which follows
the intent of the City's IZO that impacts should be evaluated at public or private open/outdoor
spaces where noise sensitive users will actually be present. As such the front yards of the
residences across South McDowell Blvd, while technically private open space, are not truly used
for outdoor enjoyment due to visual and noise exposure to South McDowell traffic. Similarly, the
school lands between the Maria Drive property line and the school building are generally used for
storage and other passive use with active outdoor play areas beyond the building setbacks.
However, even if the analysis were to consider noise levels at the property lines of these uses
average project operational noise levels in these areas would only increase by up to 2 dBA, would
4U.S. EPA AP -42 Volume of Emission Factors, Section 7.1 Organic Liquid Tanks. September 1997.
13-59
Memo to Natalie Mattei
September 14, 2018 •- Page 4
remain either below or within the range of current daytime mid nighttime noise levels at the
adjacent noise sensitive uses as found in the analysis and would not result in noise impacts greater
than what are discussed in the MND.
Construction Noise Impacts
The establishment of intermittent high noise levels of 70 to 85 dBA is based on the Typical Ranges
of Leq Construction Noise Levels per the U.S.EPA document and accepted fixed source
attenuation rates referenced in the report. The use of the criteria, which holds that temporary
construction activities that produce noise levels exceeding 60 dBA Leq or the ambient noise
environment by 5 dBA Leq for a period greater than 1 year, is established to address CEQA noise
checklist item ds and in doing so defines temporary as less than 1 calendar year (or building season)
and substantial as 60 dBA Leq (the City general Plan Ambient) or 5 dBA (considered a significant
increase). This significance criteria is a well-established measure for evaluating construction noise
significance and I&R has used it in many past and current noise studies in Petaluma and throughout
California. Although existing residences and the adjacent school have the potential to be
intermittently exposed to noise levels ranging from 70 to 85 dBA, project construction would not
exceed 60 dBA Leq or the ambient noise environment by 5 dBA Leq for a period greater than 1
year.
Noise Source Levels
Vehicle noise source levels used in the report are based on I&R's measurement experience and
California Reference Energy Mean Emissions Level (R) ;MELS) modeling values. Though our
measurement experience with vehicular levels vary (thus the range given), the REMELS model
predicts sound levels of 57 dBA at 25 feet due to a passenger car traveling at 15 mph, and sound
levels of 74 dBA at 50 feet due to a heavy truck traveling at 15 mph. These levels are well within
the sound level range given in the report.
We would further note that heavy traffic noise source level of 60 dBA at 300 feet referenced by
the commenter are from. the CalTrans Technical Noise Supplement, which relates to heavy
highway or roadway traffic and not sound levels produced by individual vehicles or even light
traffic.
The mechanical equipment noise source levels used in the report are also based on I&R's
measurement and design experience with commercial HVAC equipment and were given as a wide
range of sound levels to conservatively allow for the possibility of very loud equipment use. As
noted in the report, equipment sound levels will vary significantly depending upon the equipment
type and size and could not be fully determined at the time of the report due to schematic nature
of the design. In practice we expect that mechanical equipment will produce levels at or below 70
to 80 dBA at 3 feet as noted in the report.
Increases and Decreases in Traffic Noise Levels
As per commonly accepted acoustical practice, the increases and decreases in traffic noise levels
were calculated as a function of the logarithrrric relationship of the relative increases in A.M. and
P.M. peak hour existing and cumulative traffic volumes with the project compared to the existing
and cumulative conditions AM, and P,M. peak hour conditions without the project.
s "Would the project result in a substantial temporary or periodic increase in ambient noise levels in the project
vicinity above levels existing without the project?"
13-60
Memo to Natalie Mattei
September 14, 2018 — Page 5
Reduction of "Conditionally Acceptable" to "Normally cceptable" Noise Levels
Based on the results of the noise measurement survey and noise analysis, the noise sensitive uses
in the project area are currently exposed to "conditionally acceptable" noise levels. The
implementation of the project will not cause a significant noise increase, and not would not
decrease the acceptability of the noise environment at these uses. Furthermore, the project is not
required to reduce the existing noise environment at the adjacent noise sensitive uses to levels
below those which currently exist.
13-61
Exhibit C
13-62
1LuNGwoRTH&RoDKiN/NC.
1111M Acoustics • Air Quality 11
1 Willowbrook Court, Suite 120
Petaluma, California 94954
Tel: 707-794-0400 17ax: 707-794-0405
wnvty. illirrgt,or•tlrrodkin. com illro@illilrgtvorthr•odkin. Coln
Date: May 8, 2018
To: Natalie Mattei
Senior Real Estate Manager
Albertsons Companies
11555 Dublin Canyon Road
Pleasanton, CA 94588
From: James A. Reyff
Illingworth & Rodkin, Inc.
I Willowbrook Court, Suite 120
Petaluma, CA 94954
RE: Safeway Fuel Center CEQA document - Petaluma, CA
SUBJECT: Safeway Fuel Center Health Risk Assessment, Response to Comment made
by ESA - Job#13-205
We reviewed the comments made by ESA, dated May 7, 2018, and have the following
responses:
1. Inconsistency with CARB's Air Quality and Land Use Handbook. The commenter
states that the fueling station being 50 feet away from North Bay Children's Center and McDowell
Elementary School is too close, citing the California Air Resources Board's (CARE) Air Quality
and Land Use Handbook: A Community Health Perspective, April 2005 (CARB IIandbook),
Response: The recommendations in the referenced handbook are inapplicable and outdated. As
an advisory, non-binding document, the CARE Handbook recommends to avoid siting new
sensitive land uses within certain proximity of specified gas stations. The Project fuel center does
not qualify as a sensitive land use such that the recommended guidance does not apply.
Moreover, the analysis conducted for the GARB Handbook (2005) was developed using emission
factors developed in 1999. Since then, CARB has adopted a number of significant advancements
as part of the Enhanced Vapor Recovery (EVR) program. Phase I EVR, which addresses transfer
of bulls fuel from transfer trucks, requires more durable and leak -tight components, along with an
13-63
Memo to Natalie Maffei
May 8, 2018 — Page 2
increased collection efficiency of 98 percent. Phase II EVR, which addresses fueling of vehicles
who purchase gasoline, includes three major advancements: (1) dispensing nozzles with less
spillage and required compatibility with onboard refueling vapor recovery (ORVR) vehicles, (2)
a processor to control the static pressure of the ullage, or vapor space, in the underground storage
tank, and (3) an in -station diagnostic (ISD) system that provides warning alarms to alert the
facility operator of potential vapor recovery system malfunctions. Phase I EVR was frilly
implemented in 2005. Phase 11 EVR was fully implemented between 2009 and 2011. In addition,
a majority of the vehicles on the road today have onboard vapor recovery systems. These systems
were phased in beginning with 1998 model year passenger vehicles, and are now installed on all
passenger, light-duty, and medium -duty vehicles manufactured since the 2006 model year. When
an ORVR vehicle is fueled, almost all the gasoline vapor displaced from the fuel tard( is routed
to a carbon canister in the vehicle fuel system. As a result of these achievements, emissions of
TACs from gasoline fueling stations are substantially reduced, as indicated in newer emission
factors developed by CARB in 2013. The guidance in the CARB Handbook thus is out of date,
and it should be noted that the Bay Area Air Quality Management District (BAAQMD) issued a
permit for the facility and allowed a throughput of over 3 tunes what the facility is anticipated to
generate. BAAQMD was aware of the sensitive receptors nearby when evaluating the permit and
notified the school district and school parents of the pending permit application on August 22,
2013. The City also provided Notice of Intent to Adopt Mitigated Negative Declaration and
Public Hearing to the school district on April 5, 2018.
2. Predicted fuel throughput. The commenter claims that the analysis underestimated
risks by one -thud because it did not use the annual throughput that BAAQMD permitted.
Response:
As stated in the report, the analysis used the throughput that Safeway anticipates generating
based on market research data. The throughput permitted by BAAQMD is an unrealistic amount
that was calculated based on results of their screening assessment. Safeway does not anticipate
to sell anywhere near that much gasoline. Even under the hypothetical scenario, 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 risk that includes project construction would be 7.9 chances per
million. This is less than the significance threshold of 10 chances per million. The result of this
unreal scenario does not change the study conclusions.
3. Emission source release height. The comment states that the HRA modeling used
higher release heights that what are normally used.
Response:
Construction: There have been various methods applied to address dispersion modeling of
construction sites. The assessment 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 iometer release height used for modeling of the project's construction
13-64
Memo to Natalie Mattei
May 8, 2018 -- Page 3
equipment exhaust DPM emissions is considered a conservative estimate of the overall plume
height and incorporates both the release height from the construction equipment (i.e., the height of
the exhaust pipe) and plume rise after it leaves the exhaust pipe. Plume rise is due to both the
temperature of the exhaust and the high velocity of the exhaust gas. It should be noted that when
modeling an area, source plume rise is not calculated by time dispersion model as it is for a point
source. Therefore, the release height fi•om an area source used to represent enmissions from sources
with plume rise, such as construction equipment, is properly based on the expected height of the
exhaust plume, not just the height of the top of the exhaust pipe.
The use of a 6 -meter release height is consistent with release heights used by the CARE when
modeling diesel particulate matter (DPM) health risk impacts fi•om 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 (m) 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.
On -Road Traffic: Again, there are various methods used to model dispersion fi-om traffic. 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 (l l feet) and time release height for
light-duty vehicles was 1.3 meters (4.3 feet). These values are based on release heights
recommended by the US EPA for use in modeling vehicle PM2.5 emissions (Transportation
Conformity Guidance for Quantitative Hot -spot Analyses in PM2.5 and PMIo Nonattainnient and
Maintenance Areas, Appendix J: Additional Reference Infoinration on Air Quality Models and
Data Inputs. US EPA December 2010). These release heights are representative of the release
heights from the mix of different types of trucks and other vehicles that comprise the general
categories of heavy-duty and light-duty vehicles.
4. Receptor height for school children.
Response:
The comment is correct in that in 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), but 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. hr this case, 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) for 10 hours per day.
However, even if a 0.0 -meter breathing height were used for the modeling there would be no change
in the reported cancer risk. Use of a 0.0-nmeter receptor height instead of a 1.0 -meter receptor height
I Technical support Document: Proposed Regulation for In -Use Off -Road Diesel Vehicles. Califomia Air Resources Board.
April 2007.
13-65
Memo to Natalie Mattei
May 8, 2018 — Page 4
would result in benzene concentration being increased by such a small amount (i.e., 0.0002 micrograms
per cubic meter) that the computed cancer risk would not change.
5. Teacher exposure omitted or under estimated.
Response:
The evaluation focused on identifying the maximum health impacts that would occur and these
would be for a child. An adult exposure would occur for a longer duration (40 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/kg for a child). Thus, the teacher cancer risk
would be 70% that of a student and similarly less than significant. It would actually be a little bit
lower since the receptor height for a teacher would be greater than 1.0 meter and the concentration
at the increased height would be marginally lower.
6. Meteorological (MET) data.
Response:
The meteorological data used for the I -IRA were obtained from the BAAQMD and are the same
data that the BAAQMD used in modeling impacts from roadways and developing health risk
screening tables described in Recommended Methods for Screening and Modeling Local Risks and
Hazards (May 2012). As described by the BAAQMD, "Meteorological data used were the latest
year available for each of 64 stations in the Bay Area. Most of the observed meteorological data
were from the period 2000 to 2008, but earlier years were used to maximize spatial coverage. The
earliest data set used was from 1970. These years were all assumed to be representative ofeterrent
meteorological conditions." (emphasis added.)
7. Pollutant of Concern.
Response:
The comment is correct that there are other TAC components present in gasoline vapors. The
health risk evaluation for gasoline vapors followed the recommendations of CARB's Gasoline
Service Station Industry -wide Risk Assessment Guidelines, California Air Pollution Control
Officers Association (December 1997 and revised November 1, 2001). As discussed in the
Guidelines, "the cancer risk from benzene is by far the determining risk factor compared to the
other substances identified in gasoline. Therefore, only benzene emissions are used ill this risk
assessment procedure." Other compounds in gasoline vapor would insignificantly contribute to
cancer and non -cancer health impacts and were not evaluated as part the IIRA per the GARB
guidance.
13-66
Memo to Natalie Mattei
May 8, 2018 — Page 5
8. Omitted cumulative impacts from nearby gas stations
Response:
The gasoline stations that the commenter is referring are over 1,000 feet from the project and the
sensitive receptors and therefore, were not considered in the analysis. The Chevron Station is over
1,100 feet frons North Bay Children's Center/McDowell Elementary and the Plaza Gas station
(Unocal) is about 1,400 feet. Using screening data obtained from BAAQMD's Google Earth
Stationary Source Tool and adjusting the distance for 1,000 feet (farthest that BAAQMD
adjustment factors apply) indicates that the increase in cumulative cancer risk caused by those
stations would be less than 2 chances per million — an insignificant amount.
9. HRA guidance.
Response:
This assessment addresses the BAAQMD CEQA Guidelines thresholds for community risk
impacts that apply to sensitive receptors (e.g., school children and residents). It should be noted
that BAAQMD issued a permit for the facility that would have addressed impacts from gasoline
dispensing for all types of receptors. The assessment followed the BAAQMD Air Toxics NSR
Program Health Risk Assessment (HRA) Guidelines (December 2016) in evaluating health
impacts at sensitive receptors. Impacts to worker receptors were not evaluated. The comment is
correct in that the BAAQMD HRA guidance (section 2.2) for gasoline dispensing facilities
specifies using older 2003 & 2009 OEIIIIA risk assessment guidance. For a student (child)
exposure the only difference between the current BAAQMD guidance and the previous 2003 &
2009 OEIHTA 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 OEIIIIA guidance
specifies a breathing rate of 581 L/kg-day.
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 guidance compared
to the current BAAQMD guidance. That is the contribution to increased cancer risk would change
from 0.39 in one million (new BAAQMD guidance) to 0.40 in one million (2003 & 2009 OEHHA
guidance. The increased cancer risk is still far less than significant.
13-67