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8. B. - Page 183 Dr. Clarlc's atialysis of long-term 70 year period exposL�re did not L�se the adL�lt breathing rate 80 percentile values, but used different breathu�g rates for children and adults. Dr. Clarlc's suggested methodology assL�mes that a pregna�lt woma�� in her third trimester would move ulto the proposed apa� bL�ilding durulg the first yea� of project occupancy in the inaxiinum concentration location and that her child, once boi7�, woL�ld continue to live in the same location for the ne�t 70 years. BAAQNID rejects this assumption wluch is why BAAQMD uses the gp percentile value of fl�e adi�lt breathing rate range of values to provide a more representative long-terin exposi�re rislc. ii This approach is oL�tlined in the BAAQNID Air Toxics NSR Program Health Rislc Screeiung Analysis (HRSR) GL�idelines (JanL�ary 2010). li1 addition, pages 67-71 of BAAQMD's kecon�n�ended Methods for Screenir�g and Modelir�g Local Risks and Hazaids provide an exanlple procedL�re which nses one single breathulg rate. Furthermore, a�lalyses prepared by BAAQMD and reviewed by the City's air quality expert show that ca��cer risk calculations prepa�ed by BAAQMD use a breathing rate of 302 (the gp percentile valL�e) for the entire 70-year exposure period. Therefore, the use of the 8p percentile breathing rate for the project's long-term operational TAC a�7alysis was correct and consistent with BAAQMD methodologies. li� the case of shoi�t-term construction enussions, however, use of child breathing rates is appropriate. Because it is plausible that a pregna�lt woinan coL�ld live adjacent to the project site a��d her child (both in-utero and after birth) could be exposed to TACs for the full duration of project construction (anticipated to be 19 months), it is reasonable to use the age specific breathing rates for cluldren and adults to analyze construction cancer risk. Comment A-13: To calculate TAC enussions duru�g construction, the City used the sta�idard risk assessment methodology from Cal/EPA and U. S. EPA. With fliis methodology, the City found that the potential iinpacts from constrL�ction activities reach 9.03 in 1,000,000 in oi�ly 19 inonths. Utilizing the methodology applied by proponents in Attachment 2 of Appendix G, it is deinonstrable that the cumulative risk from DPM «lone ivill excee�l 10 in 1,000,000. Clark has noted the coinment from the City regarding the breatlung rates. While, Clark doesn't agree that the breathing rate identified by the City is achially identified, it is being i�sed here just to elinunate dispute. Year Exposure DPM Exposure Factor Annual Risk Cumulative Risk Duration Concentration Ad'ustment ( er million ( er million) In Uetero-0 025 0.0224 10 0.49 0.49 0-1 1 0.0186 10 1.63 2.12 1-2 1 0.0186 10 1.63 3.75 2-3 1 0.0186 3 0.49 4.24 3-4 1 0.0186 3 0.�9 �.72 4-5 1 0.0186 3 0.49 �.21 J-6 1 0.0127 3 0.33 S.J� 6-7 1 0.0127 3 0.33 5.88 7-8 1 0.0127 3 0.33 621 8-9 1 0.0127 3 0.33 6.�5 11 BAAQNID. 2010. Air Tosics NSR Proaram Health Risk Screeiun� Anal��sis (HRSR) Gnidelines, Bay Area Air Qualin-• Management Disriict, Jannai�� 2010, page 2. 2580 El Cainino Real Residenrial Project 15 Response to Conmients Recei��ed on Final EIR Cin� of Red��ood Cin� Jannai� 2012