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8. B. - Page 180 The City did not comply with this step. Instead they mL�ltiplied the SWF by the caticer rislc. This cal�sed the overall computation to be lower tha�� if the City had applied the SWF' to the emissions rate. Step 3. To predict the 70-year average concentrations at downwind receptor locations, the i�ser must scale the emissions i�sed in the base year run i�sing CAL3QHCR by the 70-year a�erage einissions. The City has not complied with tlus step a�1d does not detail it in its analysis. If the City had adopted the methodology L�sed to calcL�late TAC impacts dL�ring the construction phase, the City woL�ld have had to inclL�de that impacts to residential receptors during Project operation would be significa��t. Resuonse A-12: The commentor states that "according to the BAAQMD the age sensitivity factors are designed to increase the 70 year average concentration of chemicals a��alyzed". The BAAQMD gL�idance document does not say or imply that the age sensitivity were �le.signe�l to u�crease the concentration, but that the effect of L�su�g the age sensitivity values is that it "increased the 70-year a�erage concentrations predicted by the model to accotu7t for the a��ticipated special sensitivity e�periences by infants and children to carcinogens" �. This is a�l importa�7t distinction u1 that the age sensitivity factors used by the BAAQNID are designed to account for the increased susceptibility to ca�lcer risk in ulfa�lts a�ld cluldren compared to adults. They are not designed to increase TAC concentrations. The conui�entor states that applying the SWF to the cancer risks instead of the enussion rate underestimates the potential health risks and that the SWF shoL�ld be applied to the enussions. The age adjustinent factors (ASF) and the SWFs, which are based on the ASFs, are meant to be applied to the ca��cer risks. The ASFs were developed by the California Environmental Protection Agency's Office of Environmental Health Hazard Assessment (OEHHA) to address ii�lierent susceptibility of the sensitivity of infa�7ts, children, a��d adolescents to carcinogens during their ea�ly life stages and the increased potential to develop ca�icer relative to adults The ASFs were not developed based on TAC enussion rates, rather they are based on epidenuological a�ld toxicological stl�dies of health effects from exposure to toxic air conta�lunants. I�i calculatulg ca�lcer risks fl�e ASFs a�e mea�lt to be applied to the carcinogenic compound exposures'. For the City's analysis of ca�lcer risks, the TAC exposure concentrations were mi�ltiplied by SWFs in order to calclilate increased ca�lcer risk froin the proposed project. ThL�s, the City L�sed correct methodology in applying age sensitivity factors to their ca�lcer risk calcL�lations. � BAAQNID. 2011. Recommended Methods for Screeiuna and Modelin� Local Rislis and Hazards. Ba� Area Air Qualin-• Management Disriict. Ma��, 2011, page 69. � OEHHA. 2009. Tecluucal Si��ort Docmnent for Cancer Potenc�° Factors: Methodolo�ies for derivation, listin� of a� ailable � ah�es, and adjt�stments to allo�� for earl� life sta�e eiposnres. Office of Health Hazard Assessment. Ma� 2009, page � 1. `� BAAQNID. 2010. BAAQNID Air To�ics NSR Pro�am, Health Risk Screerun� Analvsis (HSRA) Gnidelines. Bay Area Air Qi�alin Manageinent District Jarn�ary, 2010 page �. s OEHHA. 2009. Tecluucal Si��ort Doci�ment for Cancer Potenc� Factors: MethodoloQies for deri� ation, listin� of a��ailable � ah�es, and adji�stments to allo�� for ear1�- life sta�e esposures. Office of Health Hazard Assessment. Ma�� 2009, page 61. 2580 El Cainino Real Residenrial Project 12 Response to Conmients Recei��ed on Final EIR Cin� of Red��ood Cin� Jannai� 2012