|Subject||Computing the Cancer Risk for my facility|
Let's look at the risk from our facility using the data that CARB provides on pages 173 to 175 of the ISOR. CARB breaks the risk up into two pieces, the risk to residents, and the risk to off-site workers in the area. We are located in an industrial zone in the 90813 zip code area. There are no residential buildings within 500 meters. According to figure V.1 that means that our cancer risk to residents is ZERO. Yes, zero risk to residents. But, let's go on and look at offsite worker risks. At the bottom of page 175, CARB states, and I quote, "For the 2019 baseline, the estimated potential cancer risks range approximately from less than one in a million to 17 chances per million, depending on the level of plating operations at the facility." So, we can use this to compute the cancer risk. Even though 17 in a million is the worst case, and even though it would be better for my illustration to use one in a million, we will use the higher number; even though we are a smaller facility. How many offsite workers are there around us? We don't know for sure but we can make a useful estimate. The 90813 zip code is one of the densest in the state (#31 as a matter of fact) and has a density of 18,175 people per square mile. If we draw a circle around our facility at a radius of 500 meters, the area is 0.3 square miles. Applying a little arithmetic, we can compute an estimate of 5,452 workers within that circle if the work force is dispersed at a similar density to residents. But maybe it is not, so let's make an extreme assumption about the number of workers within 500 meters of us and say it is 25,000. Our assumption is between 5,000 and 25,000 people work within 500 meters of us. Using the highest figure, we can compute that 0.425 offsite workers (25,000 X 0.000017 = 0.425) might get cancer. Let me repeat that number 0.425. And looking at a previous sentence CARB states that, and I quote: "The guidelines assume that a worker at a nearby worksite is exposed to the emissions for 25 years, 250 days per year, and 8 hours per day." So, in order to get 0.425 cases of cancer, we need 25,000 people to stay within 500 meters of this facility for 8 hours a day, 250 days per year, for 25 years! There it is, for my facility, using CARB's numbers and conservative assumptions, we get less than 1/2 of one cancer case. I hope you get the point. So why after more than three years of engagement in this ATCM process with CARB and the preceding rule 1469 process with AQMD and CARB is this small business dealing with the existential threat of a ban? Who is in charge? Is anyone at CARB capable of making a decision to stop this madness? Is this what AB 617 hath wrought? We are being damaged.
|Original File Name|
|Date and Time Comment Was Submitted||2022-12-21 15:23:31|
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