7-32 HRAP dated June 26, 2015
7-32 Section 3.0, the Lifespan of the facility is identified as 25-30 years and was used to determine exposure scenario for pollutants. This may understate actual exposure to contaminants if plant operates longer. That is, this is significantly less than typical “human lifespan” exposure scenario used in most risk assessments. Please provide basis or source of this assumption.
RESPONSE 7-32
| The use of this timeframe, which was approved by RIDEM, was consistent with Section II.A of RIDEM’s “Guideline for Assessing Health Risks from Proposed Air Pollution Sources” states the following:
“The focus of the risk assessment is the impact to the theoretical “most exposed individual” (“MEI”). For the purpose of this guideline, RI DEM is defining MEI as a person who lives for thirty years, including childhood, at the location of the facility’s maximally impacted residential receptor …”
Section 3(1) of the RIDEM Guideline states the following:
“All multi-pathway risk assessment must focus on the MEI, a theoretical person who lives for thirty years, including childhood, at the facility’s residential (or potentially residential) point of maximum impact …”
|
RESPONDENT:
| Michael Feinblatt, ESS Group, Inc.
|
DATE: | May 17, 2016
|