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daily diesel PM emissions, would not be sufficient to result in substantial pollutant concentrations at off -site <br />locations nearby. <br />Furthermore, according to SCAQMD methodology, health risks from carcinogenic air toxics are usually <br />described in terms of individual cancer risk. "Individual Cancer Risk" is the likelihood that a person exposed <br />to concentrations of TACs over a 30-year period will contract cancer based on the use of standard risk - <br />assessment methodology. The entire duration of construction activities associated with implementation of <br />the Project is anticipated to be approximately 36 months, and the magnitude of daily diesel PM emissions <br />will vary over this time period. No residual emissions and corresponding individual cancer risk are anticipated <br />after construction. Because there is such a short-term exposure period, construction TAC emissions would <br />result in a less than significant impact. Therefore, construction of the Project would not expose sensitive <br />receptors to substantial diesel PM concentrations, and this impact would be less than significant. <br />Operation <br />The Project Site would be redeveloped with multi -family residences, retail, and office uses, land uses <br />that are not typically associated with TAC emissions. Typical sources of acutely and chronically <br />hazardous TACs include industrial manufacturing processes (e.g., chrome plating, electrical <br />manufacturing, petroleum refinery). The Project would not include these types of potential industrial <br />manufacturing process sources. It is expected that quantities of hazardous TACs generated on -site (e.g., <br />cleaning solvents, paints, landscape pesticides) for the types of proposed land uses would be below <br />thresholds warranting further study under California Accidental Release Program. <br />When considering potential air quality impacts under CEQA, consideration is given to the location of <br />sensitive receptors within close proximity of land uses that emit TACs. CARB has published and adopted <br />the Air Quality and Land Use Handbook: A Community Health Perspective, which provides <br />recommendations regarding the siting of new sensitive land uses near potential sources of air toxic <br />emissions (e.g., freeways, distribution centers, rail yards, ports, refineries, chrome plating facilities, dry <br />cleaners, and gasoline dispensing facilities).39The SCAQMD adopted similar recommendations in its <br />Guidance Document for Addressing Air Quality Issues in General Plans and Local Planning.40 Together, <br />the CARB and SCAQMD guidelines recommend siting distances for both the development of sensitive <br />land uses in proximity to TAC sources and the addition of new TAC sources in proximity to existing <br />sensitive land uses. <br />The primary sources of potential air toxics associated with Project operations include DPM from delivery <br />trucks (e.g., truck traffic on local streets and idling on adjacent streets) and to a lesser extent, facility <br />operations (e.g., natural gas fired boilers). However, these activities, and the land uses associated with <br />the Project, are not considered land uses that generate substantial TAC emissions. It should be noted <br />that the SCAQMD recommends that health risk assessments (HRAs) be conducted for substantial <br />individual sources of DPM (e.g., truck stops and warehouse distribution facilities that generate more <br />than 100 trucks per day or more than 40 trucks with operating transport refrigeration units) and has <br />39 California Air Resources Board, Air Quality and Land Use Handbook, a Community Health Perspective, April <br />2005. <br />40 South Coast Air Quality Management District, Guidance Document for Addressing Air Quality Issues in <br />General Plans and Local Planning, May 6, 2005. <br />Cabrillo Town Center Project PAGE 31 City of Santa Ana <br />Air Quality Iv I.0I u C18 — 677 10/3/2023 July 2o2s <br />