Complying with Regulations from California’s Office of Environmental Health

Hazard Assessment (OEHHA)

For

2014 Golden Empire AWMA Conference

September 16, 2014

Leland Villalvazo, Supervising AQS

San Joaquin Valley APCD

Background

• 2008 OEHHA started work on revisions– Included updates to the non-cancer health

effects, cancer potency factors, and exposure assessment procedures

– Approved by SRP– Largely aimed at providing additional

protections for children

Background(cont’d)

• “Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments” forms the basis by which HRAs are performed in California:– AB2588– CEQA– Permitting health risk assessments

District’s Risk Management Philosophy

• Minimize health risk from new and modified sources of air pollution

• Health risk impact from a new and modified source must not be significant

• Avoid unreasonable restrictions on permitting

• Public has a right to know about existing air toxics risk in their neighborhoods

• High risk facilities must reduce risk

So What Are The Changes

Proposed Key Changes

• Years of Exposure (30 vs. 70 years)• Age Groups(Bins)• Age Sensitivity Factors (ASF)• Breathing Rates• Chronic Reference Exposure Levels (8-

hour) • Fraction of Time at Home

Proposed Key Changes(cont’d)

• Worker Exposure Duration (25 vs. 40 years)

• Worker Modeled Concentration Adjustment

• Dispersion Model Change (EPA’s AERMOD)

• Spatial Averaging• Poly Aromatic Hydrocarbons (PAH),

Creosotes & Lead

Overview

Age Groups (Bins)

Age Groups (Bins)

Current Method 

Proposed Method

Age Group Age Group

0 – 70 years (Resident)3rd Trimester – 0 years

0<2 years

0 – 9 years (Children)2<9 years

2<16 years

40 years (Worker)16<30 years

16-70 years

Age Sensitivity FactorsAge Sensitivity Factors

Current Method Proposed method

Age GroupAge Sensitivity

FactorAge Group

Age Sensitivity Factor

0 – 70 years (Resident)

1

3rd Trimester – 0 year 10

0<2 years 10

0 – 9 years (Children)2<9 years 3

2<16 years 3

40 years (Worker)16<30 years 1

16-70 years 1

Breathing Rates

Method Group Measure

Long-Term Daily Breathing Rate (L/kg-day)By age Bin

3rd Trimester

0<2 2<9 2<16 16<30 16-70

Current

Adult 95th pctl.

NA

393

Adult 80th pctl. 302

Children 581 NA

Proposed

Adult

Mean 225 658 535 452 210 185

95th pctl. 361 1090 861 745 335 290

80th pctl. 273 758 631 572 261 233

Worker / Children

Mean 170 890 470 380 170 170

95th pctl. 240 1200 640 520 240 230

Adult 95th / 80th pctl.* 361 1090 631 572 261 233

Fraction of Time at Home

Fraction of Time at Home

Current Method Proposed method

Age GroupFraction of Time at

HomeAge Group

Fraction of Time at Home

0 – 70 years (Resident)

1

3rd Trimester - 00.851

0<2 years

0 – 9 years (Children)2<9 years

0.7212<16 years

40 years (Worker)16<30 years

0.73016-70 years

Ambient Air Cancer Risk, San Joaquin Valley (The California Almanac of Emissions and Air Quality, CARB, 2009)

1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 20120

500

1000

1500

2000

2500

3000

Reduction in Ambient Risk

Current Risk

New OEHHA

Years

Can

cer

Ris

k In

a M

illi

on

Potential Impact of Changes

SJV Risk Assessment Thresholds• Permitting of stationary sources

– BACT for toxics (T-BACT) at above 1 in a million– Will not issue permits if facility’s cumulative

increase in risk is above 10 in a million• California Environmental Quality Act (CEQA):

– 10 in a million defined as significant• Air Toxics “Hot Spots” Act (AB2588):

– Public notification of significant risk facilities at 10 in a million

– Risk reduction required if over 100 in a million

Board Guidance on District’s Risk Management Policies

• Incorporate OEHHA’s Risk Assessment Guideline updates designed to provide protection of infants and children

• Permitting and CEQA– Adjust thresholds as necessary to prevent

unreasonable restrictions– No relaxation of current health protections (no

increase in actual air toxics exposure, compared to current policies)

Board Guidance on District’s Risk Management Policies (cont’d)

• Air Toxics “Hot Spots”– Enhance public right-to-know and health

protections by retaining current notification and risk-reduction thresholds

• Incorporate all possible streamlining efforts in incorporating OEHHA updates

• Develop effective outreach tools and processes to communicate changes to all interested parties