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18 inconsistent with CEQA’s requirement to correlate the increase in TAC emissions with potential adverse impacts on human health. Third, the Office of Environmental Health Hazard Assessment (“OEHHA”), the organization responsible for providing guidance on conducting HRAs in California, released its most recent Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments in February 2015, as referenced by the Checklist (p. 4‐17).29 The OEHHA document recommends that exposure from projects lasting more than 6 months be evaluated for the duration of the project and recommends that an exposure duration of 30 years be used to estimate individual cancer risk for the maximally exposed individual resident (“MEIR”).30 Even though we were not provided with the expected lifetime of the Project, we can reasonably assume that the Project will operate for at least 30 years, if not more. Therefore, we recommend that health risk impacts from Project operation also be evaluated, as a 30‐ year exposure duration vastly exceeds the 6‐month requirement set forth by OEHHA. This recommendation reflects the most recent state health risk policies, and as such, we recommend that an analysis of health risk impacts posed to nearby sensitive receptors from Project operation be included in a full CEQA analysis for the Project. Fourth, while the Checklist includes an HRA evaluating the health risk impacts to nearby, existing receptors as a result of Project construction, the HRA fails to evaluate the cumulative lifetime cancer risk to nearby, existing receptors as a result of Project construction and operation together. According to OEHHA guidance, as referenced by the Checklist, “the excess cancer risk is calculated separately for each age grouping and then summed to yield cancer risk at the receptor location” (p. 4‐17).31 However, the Checklist’s HRA fails to sum each age bin to evaluate the total cancer risk over the course of the Project’s total construction and operation. This is incorrect and thus, an updated analysis should quantify the entirety of the Project’s construction and operational health risks and then sum them to compare to the BAAQMD threshold of 10 in one million, as referenced by the Checklist (p. 4‐17, Table 4‐3; p. 4‐19, Table 4‐4). Failure to Identify Significant Health Risk Impact As previously stated, the Checklist estimates that Project construction would result in a mitigated excess cancer risk of 4.9 in one million, which would not exceed the BAAQMD threshold of 10 in one million (p. 4‐19, Table 4‐4). However, as previously discussed, the “Callan and E 14th Street Infill Checklist Project Mitigated Construction” model incorrectly assumes that the Project’s off‐road construction equipment fleet would meet Tier 4 Interim emissions standards without properly committing to the mitigation measure. As a result, the Checklist should have relied upon the unmitigated construction HRA in order to determine the significance of the Project’s health risk impact. The Project’s unmitigated construction 29 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: http://oehha.ca.gov/air/hot_spots/hotspots2015.html 30 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at: http://oehha.ca.gov/air/hot_spots/2015/2015GuidanceManual.pdf, p. 8‐6, 8‐15 31 “Guidance Manual for preparation of Health Risk Assessments.” OEHHA, February 2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf p. 8‐4 133