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Publications

California Environmental News

CARB Adopts New Risk Management Guidance for Stationary Source Air Toxics

Tuesday, August 25, 2015

California air toxic emissions have decreased by at least 75 percent since 1990, according to California Air Resources Board (CARB) staff, even though the economy, vehicle ownership and total population levels have grown. Facilities have been installing control equipment and CARB has been adopting mobile emission controls for new vehicles.

CARB adopted new Risk Management Guidance for Stationary Source Air Toxics at its July 23, 2015 meeting. This guidance supports the 35 individual air districts in meeting the requirements of the previously revised Office of Environmental Health Hazards Assessment (OEHHA) Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments (revised OEHHA Manual) released February 2015 (available here). This revised methodology reflects advances in science about increased cancer risk from higher air toxic exposure levels to children and elderly. The CARB's July 2015 Risk Management Guidance supports California air district health risk programs including stationary source permitting (Risk Management Review), California Environmental Quality Act (CEQA) compliance and AB2588 compliance. Some air districts have already updated their air toxics thresholds and rules (e.g., San Joaquin Valley Air Pollution Control District [SJVAPCD], and South Coast Air Quality Management District [SCAQMD]); many more air districts will be updating their air toxics rules and thresholds over the next 12 to 24 months. SCAQMD updated its Toxic Air Contaminant (TAC) rules, i.e. Rule 1401, 1401.1 and 1402. The averaging period for maximum individual cancer risk was revised from 70 years to 30 years. Under Rule 1401, spray booths and retail gasoline transfer and dispensing facilities may continue to use old OEHHA guidelines. For existing facilities, emission reporting thresholds have been updated for specific TACs. The SJVAPCD recently revised its health risk thresholds for air permits and CEQA projects from 10 in a million to 20 in a million for cancer risk; its AB2588 thresholds remain at 10 in a million for cancer risk.

The revised OEHHA Manual is predicted to lead to 1.5 to 3 fold increase in predicted cancer risk for the same emission levels. More facilities will be subject to public notification and emission reduction requirements under the new OEHHA Manual for AB2588 compliance even though their operations in 2015 will be the same as 2014. As a result, many existing facilities, new projects and project modifications, which previously might have had no air toxic triggers, could now be required to:  (1) provide more complex AB2588 reporting; (2) prepare a health risk assessment or risk management review; or (3) trigger a CEQA project review with its next air permit modification. This CARB guidance focuses on communication challenges from anticipated higher predicted cancer risk levels and more complex permitting and regulatory compliance.

The California Air Pollution Control Officers Association will be updating its Risk Communication Guidelines. If your facility now requires a preliminary risk evaluation or a health risk assessment or other expanded AB 2588, air permit, or CEQA compliance as a result of your air toxic emission risk levels, contact Trinity at (949) 567-9880.

South Coast Air Quality Management District – Proposed Amendments to Rules 1148.1 and 1148.2

Tuesday, August 25, 2015

The South Coast Air Quality Management District (SCAQMD) is proposing amendments to Rule 1148.1 Oil and Gas Production Wells and 1148.2 Notification and Reporting Requirements for Oil and Gas Wells and Chemical Suppliers. The rule updates are anticipated to reduce odor and nuisance complaints from oil and gas production well operations.

Rule 1148.1 reduces Volatile Organic Compound (VOC) emissions from well operations at oil and gas production facilities through visual inspection and maintenance requirements. The proposed rule changes would decrease the potential for odor nuisance and exposures through additional prevention measures and best practices. Rule 1148.2 requires operators of oil and gas wells to make notifications when well drilling, reworking, and completion activities take place. Operators and chemical suppliers must also report chemical information used during well event activity. Proposed rule changes will no longer require chemical mass maximum concentration within the product trade name and instead report the mass of each chemical ingredient. The changes will also disaggregate the reporting of the trade main product from the product chemical ingredients, make information not deemed trade secret available to public, and revise the notification timeframe to 72 hours.

For more information regarding compliance with this rule, click here.

South Coast Air Quality Management District – Proposed Amendments to Rules 1110.2 and 1420.2

Tuesday, August 25, 2015

Proposed Amendments to Rule 1110.2 – Emissions from Gaseous and Liquid Fueled Engines

The South Coast Air Quality Management District (SCAQMD) is proposing to amend Rule 1110.2 – Emissions from Gaseous and Liquid Fueled Engines. Proposed changes include extending the compliance date for NOx, VOC, and CO emission limits, implementing alternate compliance options, and adding emission exceedance allowances.

For more information regarding compliance with this rule, please contact Trinity at (949) 567-9880 or click here.

Proposed Amendments to Rule 1420.2 – Emission Standards for Lead from Metal Melting Facilities

The South Coast Air Quality Management District (SCAQMD) is proposing to amend Rule 1420.2 – Emission Standards for Lead from Metal Melting Facilities. Proposed changes include limiting ambient air lead concentrations, establishing housekeeping and maintenance provisions, requirements for total enclosures, and ambient air lead sampling and monitoring requirements.

For more information regarding compliance with this rule, please contact Trinity at (949) 567-9880 or click here.

South Coast Air Quality Management District – Proposed Amendments to Regulation XX

Tuesday, August 25, 2015

The South Coast Air Quality Management District (SCAQMD) held a public workshop on Wednesday, July 22, 2015 to discuss proposed amendments to Regulation XX, Regional Clean Air Incentives Market (RECLAIM). The rule updates are anticipated to reduce NOx emissions to help the South Coast area meet federal and state air quality standards.

Regulation XX includes provisions to regulate NOx emissions from facilities through the implementation of RECLAIM Trading Credits (RTC). The RECLAIM program is a market-based incentive program, which allows facilities to trade RTCs within the area. The rules also include monitoring, reporting, and recordkeeping requirements for RECLAIM facilities. The SCAQMD is proposing a NOx shave, or reduction in RTCs available within the district. They are proposing to reduce NOx emissions by 14 tons per day by 2022, starting with 4 tons per day in 2016. Refineries and investors would be shaved by 67%, and non-refineries and power plants among the top 90% of RTC holders will be shaved 47%.

For more information regarding compliance with this rule, click here.

Consumer Product Survey Update

Friday, July 24, 2015

The California Air Resources Board (ARB) is conducting a Consumer and Commercial Products Survey to update the state's consumer products inventory and help determine emission inventories for calendar year (CY) 2013, 2014 and 2015. The main objective of the survey is establish the scientific foundation for the new State Implementation Plans (SIPs) that address additional reduction of oxides of nitrogen (NOx) and Volatile Organic Compounds (VOCs) necessary to meet the new National Ambient Air Quality Standards (NAAQS) set by the USEPA.

Reporting period for CY 2014 sales has begun on July 1, 2015 and the survey must be completed by November 1, 2015. Reporting period for CY 2015 will begin on July 1, 2016 and dead line for survey completion will be November 1, 2016. This survey is mandatory for all entities listed on any consumer and commercial products sold or supplied for use in California during calendar years 2013 through 2015 and on the List of Survey Categories. For more information regarding compliance with this survey, please contact our office at (949) 567-9880.

SB14 Hazardous Waste Source Reduction Reminder

Friday, July 24, 2015

All facilities subject to the California SB-14 Hazardous Waste Source Reduction Program are required to submit program documents by September 1, 2015. Facilities exceeding routine generation of 12,000 kg of hazardous waste or 12 kg of extremely hazardous waste in 2014 are subject to SB-14. This applies to most large quantity generators and those with extreme hazardous waste. Generators must complete all three SB-14 documents which are the (1) Source Reduction Evaluation Plan, (2) Hazardous Waste Management Report, and (3) Summary Progress Report. The Summary Progress Report is no longer required to be sent to California Department of Toxic Substances; it only needs to be maintained onsite. Trinity has experts specializing in preparation of SB14 documents and program development. Please contact us at (949) 567-9880 with any questions or concerns.