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Odors are also potential concern, as the potential medical center could include waste handling facilities and food services. Based on similar existing sources of odors in the region and the proximity of sensitive receptors, the likelihood for new odor complaints to be generated by the project will be discussed but are not anticipated to be a significant concern. The analysis of potential impacts will be qualitative. The health risks related to potential toxic air contaminant emissions from routine operation of the potential medical center will be assessed in the EIR. In order to complete this task, EIP will inventory the air emission sources associated with the proposed uses and identify the regulatory programs that would be applicable to the sources. Based on the source inventory and the applicable requirements (e.g., California Code of Regulations, 17 CCR, Section 93108, for control of ethylene oxide sterilizers), the foreseeable emissions of toxic air contaminants would be estimated. Upon estimating potential emissions after regulatory control, the emissions would be compared to the trigger levels specified by the BAAQMD in Rule 2-1-316. Potential effects of the medical center on toxic air contaminant emissions will be discussed on a programmatic level. This scope of work assumes that potential emissions would not exceed the trigger levels, and that a more detailed risk assessment would not be necessary to demonstrate insignificant effects. Recent air pollution studies have shown an association between health effects and proximity to high traffic roadways. New sensitive receptors, such as the residences, deserve special attention because of the time spent at home and the long-term exposure rate. In addition, the potential medical center deserves special attention because children, pregnant women, the elderly, and those with existing health problems are especially vulnerable to the effects of air pollution. The project site would be discussed in relation to its proximity to high traffic roadways, in particular, 1- 880. A qualitative impact discussion would be included to address potential effects as they relate to recent guidance provided by the Air Resources Board in relation to diesel particulate matter. EIP anticipates that the hospital would include a steam generating facility (e.g., boilers for heating), emergency generators, miscellaneous laboratory and fume hoods, and possibly ethylene oxide sterilizers, and that the BAAQMD's new source review-permitting program would apply to the new sources. Written consultation with the BAAQMD may be necessary to determine appropriate emission factors for laboratory and fume hoods, should they be included in the project. If a new medical waste incinerator is included as part of the medical center, we assume most of the analysis would be completed as part of the BAAQMD permitting process, and not as part of the EIR. The potential of the project motor vehicle trips to cause localized carbon monoxide "hot spots" will be evaluated at up to four of the most severely impacted intersections. The Air Resource Board's CALINE4 dispersion model will be used to model the effects of project-level carbon monoxide at four of the worst performing intersections affected by the project during either Consulting Services Agreement between City of San Leandro and Erp Associates Page 31 of 43