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November 8, 2024 Page 20 7357-013acp printed on recycled paper excavators, welders, and rollers will be more significant than analyzed in the DEIR.100 Moreover, DEIR Appendix B provides, “Several equipment are adjusted to be electric as a common construction practice. Number of forklift, generator sets, tractors, and welders are increased to 5 each day to account for overlapped construction during building construction phase.”101 The DEIR provides that electric welders and air compressors would be utilized.102 But the DEIR does not require that welders or air compressors be electric. Under the DEIR’s mitigation plan, the applicant is therefore free to utilize non-electric equipment, including welders or air compressors. SWAPE concludes that the DEIR’s modeling therefore underestimates peak daily emissions associated with construction and is not supported by substantial evidence.103 The daily emissions associated with construction will therefore be more significant than analyzed in the DEIR. The DEIR must be revised and recirculated to accurately quantify and mitigate significant construction air quality impacts. iii. The DEIR Fails to Include an Operational Health Risk Assessment The Alameda County General Plan requires preparation of a Health Risk Assessment for projects that generate substantial toxic air contaminant (“TAC”) emissions within 1,000 feet of sensitive receptors or for sensitive receptor uses proposed to be located within 1,000 feet of an existing major source of toxic air contaminants. The Project’s sewer treatment plant could emit Volatile Organic Compounds (VOCs), Hydrogen Sulfide (H₂S), Ammonia (NH₃), Methane (CH₄), but the DEIR fails to quantify these potential emissions. Noxious emissions from the sewer treatment plant would directly adversely affect residents on the Project site and residents at the Senior East County Lakes Project. An operational health risk assessment should be prepared to quantify the Project’s impacts to public health from the development and operation of the sewer treatment plant. B. The DEIR Fails to Adequately Analyze and Mitigate Potentially Significant Hazards Impacts The DEIR fails to include any analysis whatsoever regarding the potentially significant hazards and water quality impact of the Project associated with perfluorinated and polyfluorinated alkyl substances (“PFAS”). The State Water 100 SWAPE Comments, p. 9. 101 DEIR, Appendix B: Air Quality, Greenhouse Gas, and Energy Supporting Information, p. 93. 102 DEIR, p. 3.2-25. 103 SWAPE Comments, p. 7.