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SCAQMD Recently Amended
Rules to Implement Revised
OEHHA Guidelines
Presentation to AWMA
October 15, 2015
Ian MacMillan
Planning and Rules Manager, SCAQMD
SCAQMD’s Approach to Reducing Public Risk from Air Toxics
• #1 Objective: Protect public health
• Multifaceted RegulatoryApproach
• Comprehensive
• Technology and Science Based
Permitting
AB
258
8
Source-Specific Rules
EJ Initiatives
1990 1994 1997 2000 2003 2004 2010
2010 Clean Communities
Plan
1998
Cumulative Impacts
Strategies White Paper
2000 Air Toxics
Control Plan2004 ATCP Addendum
MATES I
MATES IIRule 1402
(AB 2588 Toxics
“Hot Spots”)
2005
MATES III
Represents adoption of a stationary source-specific toxic rule
Rule 1401
SCAQMD’s Air Toxics Program
2014
MATES IV
14 Source Specific Toxics Rules and 4 Umbrella Rules
• Rule 1401 – Toxic requirements for new and modified permitted sources
• Rule 1401.1 – Toxic requirements for new and modified permitted sources near schools
• Rule 1402 – Toxic requirements for existing facilities (AB2588 “Hot Spots”)
• Rule 212 – Noticing for new and modified permitted sources
“Umbrella” Toxics Rules
121,000+ permits have been issued under Rule 1401
AB2588 Hot Spots Program308 Facilities with Approved HRAs*
1 to <10 in a
million
62%
<1 in a million
32%
10 to <25 in a
million
5%
>25 in a million
1%
95% of AB2588 Facilities Health Risks <10 in a million
* Health risks based on previous OEHHA Guidelines
Trends in Air Toxic Cancer Risk Since 1990
(Excludes diesel PM)
0
200
400
600
800
1000
1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010 2012
Inha
latio
n C
ance
r R
isk
(in a
mill
ion)
Year
Burbank Los Angeles
Long Beach Riverside
Simi Valley75 to 86% Reduction
MATES III (2005)Old OEHHA
SCAQMD Multiple Air Toxics
Exposure Studies (MATES)
MATES IV (2012-2013)Old OEHHAMATES IV (2012-2013)New OEHHA
http://www.aqmd.gov/docs/default-source/air-quality/air-toxic-studies/mates-iv/mates-iv-final-draft-report-4-1-15.pdf
Localized Air Quality IssuesResidential
Residential
Com
mer
cial
/In
dust
rial
Proximity Matters for Health Risks
11
Monitored Data Shows Focus Needs to Be on
Point and Fugitive Emission Sources
Historically, Primary Focus has Been on Point Source Emissions
Who Establishes the Health Risk Assessment Guidance?
• The California Office of Environmental Health Hazard Assessment (OEHHA) is responsible for developing and updating HRA guidance under the Air Toxics Hot Spots program
• State law requires that HRAs required under Toxics Hot Spots Program be prepared in accordance with OEHHA Guidelines (Health and Safety Code §44360(b)(2))
• OEHHA’s health risk guidelines are used by all air districts statewide
• Inhalation Risks
• Other changes that may affect risk• Change in dispersion model from ISC to AERMOD• Multi-pathway pollutants
How Will Cancer Risks Change
with New OEHHA Guidance?
Permitting
• Rule 1401 – New and Modified Permitted Sources
• Rule 1401.1 – New and Relocated Facilities Near Schools
AB2588
• AB2588 Industry-Wide Facilities
• AB2588 Core Facilities
• Rule 1402 – Control of Toxic Air Contaminants from Existing Sources
Public Noticing
• Rule 212 – New or Modified Permits
• AB2588 Facilities
CEQA
• Air Toxics Analysis for
• Construction Phases
• Operational Phases
Revised OEHHA Guidance
Affected SCAQMD Programs
• Rule 1401 and
1401.1
(Permitting)
• Rule 1402
(AB2588)
• Rule 1401 and
1401.1
(Permitting)
• Rule 1402
(AB2588)
• SCAQMD
Permitting Risk
Assessment
Procedures
(Version 8.0)
• SCAQMD Risk
Assessments for
the Air Toxics
(AB2588)
• SCAQMD
Permitting Risk
Assessment
Procedures
(Version 8.0)
• SCAQMD Risk
Assessments for
the Air Toxics
(AB2588)
General Approach
OEHHA Guidelines
SCAQMD Risk
Guidelines
SCAQMD Rules
How Will New SCAQMD Permits be Affected?
• SCAQMD staff reviewed past five years of permitted data (2009 to 2014)
• Majority of permits issued well below Rule 1401 permitting risk thresholds
• Most source types will not require additional controls to meet current thresholds
• Additional pollution controls may be needed for small number of new permits
• Special provisions for two source categories
Permitting Approach
• Implementation of Revised OEHHA Guidelines will be forward looking– Applies to permit applications deemed complete 30
days after rule adoption
• Rule 212 notifications will continue for new and modified sources
• SCAQMD permitting approach for toxics uses a 4 Tier screening approach – each screening level incorporates more specificity and analysis– Currently developing screening criteria that are more
equipment specific to streamline implementation
• Amended Rule 1401 requires use of new SCAQMD HRA Procedures (Version 8.0) with two exceptions– Allow use of current Procedures (Version
7.0) for spray booths and retail gas stations• Return to Board as quickly as practicable
• Rule and/or procedures
• ~28 new permits per year may need Toxics Best Available Controls (~$225K annually)
• ~10 to 30 permits per year may require public notification under Rule 212 (~$51K annually)
Amended Rules 1401, 1401.1, and 212
New Risk Calculatorhttp://www.aqmd.gov/home/permits/risk-assessment
Amended Rule 1402 (AB2588)
• Continue implement quadrennial review process• Estimates below are conservative
– Some reductions not captured since last HRA approved
– May choose between process changes, add-on controls, throughput limits or combination
~87 facilities may need to prepare HRA (~$264,000 annually)
~42 facilities may require public notice (~$8,400 annually)
~22 facilities may require risk reduction (~$1.4 M annually)
Early and Additional Risk Reduction
• Some industry representatives requesting opportunity to reduce risks earlier and in addition to Rule 1402 to lower health risks below the public notification level of 10 in-a-million
• Rule adoption Resolution includes commitment to continue to work with stakeholders to:– Incentivize early risk reductions beyond those required
under Rule 1402– Assess current public notification procedures– Explore alternatives for such facilities
• Report back to the Stationary Source Committee no later than September 2015
SCAQMD Contacts
Permitting Guidelines
Mohan Balagopalan, [email protected] (909) 396-2704
Jillian Wong, [email protected] (909) 396-3176
AB2588 Guidelines and Prioritization Procedures
Ian MacMillan, [email protected] (909) 396-3324
Victoria Moaveni, [email protected] (909) 396-2455
CEQA
Ian MacMillan, [email protected] (909) 396-3324
Barbara Radlein, [email protected] (909) 396-2716
Rule Development
Susan Nakamura, [email protected] (909) 396-3105