HomeMy WebLinkAboutStaff Report 5.A 01/28/2019 Attachment 06-11ATTACHMENT 11
KuNGINURTHfirROmm /NC.
1111B Acoustics • Air Quality 11
I Willowbrook Court, Suite 120
Petaluma, California 94954
Tel: 707-794-0400 Fax: 707-794-0405
www.illingworthrodkin.com illro@illingwoi°throdkin. coni
Dater 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.
1 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 (CARB) Air Quality
and Land Use Handbook: A Community Health Perspective, April 2005 (CARB Handbook).
Response: The recommendations in the referenced handbook are inapplicable and outdated. As
an advisory, non-binding document, the CARB 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 CARB 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
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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 fully
implemented in 2005. Phase II 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 tank 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 CARE 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 times 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-third 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 6meter release height used for modeling of the project's construction
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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 the dispersion model as it is for a point
source. Therefore, the release height from an area source used to represent emissions 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 CARB when
modeling diesel particulate matter (DPM) health risk impacts from construction activities. In
describing the methodology used for modeling of DPM emissions from area sources, CARB states
"Sensitivity studies have shown that there is an initial plume rise from the equipment due to upward
buoyancy and momentum. The release heights of these area sources were determined to be 5 —
10 meters (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 from 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 (1 I feet) and the 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 Nonattainment and
Maintenance Areas, Appendix J: Additional Reference Information 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. In 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 -meter receptor height instead of a 1.0 -meter receptor height
1 Technical Support Document: Proposed Regulation for In -Use Off -Road Diesel Vehicles. California Air Resources Board.
April 2007.
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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 HRA 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 of current
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 in 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 LIRA per the CARB
guidance.
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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 from 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 (furthest 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 OEHHA risk assessment guidance. For a student (child)
exposure the only difference between the current BAAQMD guidance and the previous 2003 &
2009 OEHHA guidance is in the value used for a child breathing rate. The current BAAQMD
guidance specifies a child breathing rate of 572 L/kg-day while the 2003 OEHHA guidance
specifies a breathing rate of 581 L/kg-day.
The 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.
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