Choose a different state:
For assistance in CA, contact
Vineet Masuraha
949-567-9880
Local Offices
California - Bakersfield
5500 Ming Ave
Suite 140

Bakersfield, CA 93309
Phone: 661-282-2200
California - Irvine
20 Corporate Park
Suite 200

Irvine, CA 92606
Phone: 949-567-9880
California - Sacramento
1801 J Street
Sacramento, CA 95811
Phone: 916-444-6666
California - Oakland
1330 Broadway
Suite 1001

Oakland, CA 94612
Phone: 510-285-6351
Publications

California Environmental News

San Diego APCD Proposed Amendments to NSR Rules 20.1, 20.2, 20.3, and 20.4

Friday, April 24, 2015

The San Diego County Air Pollution Control District (SDAPCD) will be holding a public workshop on Thursday, May 7, 2015 to discuss proposed amendments to New Source Review (NSR) Rules 20.1, 20.2, 20.3, and 20.4. The rule updates are anticipated to remove insufficiencies, meet regulatory requirements, and improve consistency between federal, state, and local regulations.

Rule 20.1 New Source Review – General Provisions will be amended to include emission thresholds and compliance requirements for fine particulates (PM2.5). PM2.5 triggers will be included for air quality increments, Prevention of Significant Deterioration (PSD), major source thresholding, major modification thresholding, and Air Quality Impact Analysis (AQIA). The definition for Best Available Control Technology (BACT) will be revised to incorporate cost-effectiveness and practicable control approaches. The potential to emit (PTE), actual emissions, emission increases and emission reduction sections of this rule will also be updated to improve clarity of requirements and maintain consistency between different agencies.

Rule 20.2 New Source Review – Non-Major Stationary Sources will be updated to also apply to replacement emission units. The rule does not apply to portable emission units. Rule 20.3 New Source Review – Major Stationary Sources and PSD Stationary Sources will be amended to clarify the LAER requirements and how BACT exemptions to LAER will be obtained. The emission offset section in Rule 20.3 will be revised to consolidate requirements and add new provisions regarding emission reduction credits (ERC). Rule 20.4 New Source Review – Portable Emission Units clarified applicability section to include certain portable units at stationary sources and replacement portable emission units. Additional revisions to exemptions and definitions will also be incorporated into the proposed amendments for all four rules.

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

Ventura County APCD Draft Amendments to Rules 71, 71.1, and 71.3

Friday, April 24, 2015

The Ventura County Air Pollution Control District (VCAPCD) advisory committee met on March 24, 2015 to discuss draft revisions to Rule 71, Crude Oil and Reactive Organic Compound Liquids; Rule 71.1, Crude Oil Production and Separation; and Rule 71.3, Transfer of Reactive Organic Compound Liquids. These rules apply to facilities that process, produce, transfer, store or separate petroleum materials and organic liquids.

Rule 71.1 requires crude oil storage tanks and wastewater separators to reduce vapor emissions using control devices. The rule currently exempts tanks for which vapor recovery is not economically feasible. Due to recent public concern, the draft revisions would eliminate this exemption for storage tanks within 300 feet of a sensitive receptor. Rule 71.3 similarly requires crude oil loading facilities above a specific throughput to use vapor recovery systems. Facilities below the throughput limit are currently exempt from installing recovery systems. Revisions to Rule 71.3 would eliminate the potential low throughput exemption for loading facilities within 300 feet of a sensitive receptor. Rule 71 will also be revised to include a new definition for “sensitive receptor” based closely on the SCAQMD Rule 1148.2 definition.

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

SCAQMD Proposed Rule 415 – Odors from Rendering Facilities

Tuesday, March 24, 2015

The South Coast Air Quality Management District (SCAQMD) is proposing a new rule: Proposed Rule (PR) 415 – Odors from Rendering Facilities. PR 415 aims at reducing odors from facilities which render animal waste tissue. PR 415 would be applicable to new and existing facilities that cook raw rendering materials, process trap grease, and treat wastewater from processes associating with these operations.

PR 415 sets Odor Best Management Practices (BMP), which include washdown of receiving areas and floor drains and preventing accumulation of materials within enclosures. Permanent enclosure of processes, ventilation to specific odor control equipment, and requirements for the transport and transfer of rendering materials are also included as odor control measures. Existing facilities will have 12 months upon adoption of the rule to submit applications for permanent enclosures, and 24 months for ventilation systems. In the case of a facility receiving a Notice of Violation for odor nuisance, or three or more odor complaints within 180 days, the facility will be required to submit an Odor Mitigation Plan (OMP) within 90 days in order to remedy the issue.

PR 415 does not apply to facilities which collect, store or process trap grease not located at a rendering facility, nor does PR 415 apply to facilities conducting only edible rendering operations or collection centers for animal carcasses.

For more information regarding this amendment and future compliance, click here.

Cap-and-Trade February 2015 Joint-Auction Results Released

Tuesday, March 24, 2015

On February 25, 2015, the California Air Resources Board (ARB) released the results of its second joint auction for greenhouse gas (GHG) allowances between ARB and Québec’s Ministère du Développement durable, de l’environnement et de la Lutte contre les changements climatiques (Ministry of Sustainable Development, Environment and the Fight against Climate Change, MDDELCC). The auction was held on February 18, 2015. The results detail the total allowances available for sale, total allowances sold, the settlement price, and other market statistics in the auction for the 2015 and 2018 vintage allowances. All 75,640,528 metric tons of 2015 allowances that were available for sale were sold. The settlement price was $12.21 per metric ton, an 11 cent increase from the first Joint Auction which occurred in November 2014. Similarly, all 10,431,500 vintage 2018 allowances that were available for sale were sold. The settlement price for 2018 allowances was $12.10 per metric ton, a 24 cent increase from the November 2014 auction. The next joint auction is planned for May 21, 2015. The auction notice is available on the ARB Cap-and-Trade website.

For any additional questions, please contact Trinity at (949) 567-9880.

OEHHA's Air Toxics Hot Spots Guidance Manual Adopted

Tuesday, March 24, 2015

The Office of Environmental Health Hazard Assessment (OEHHA) adopted the revised Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments (Revised OEHHA Guidance Manual). The final version of this Revised OEHHA Guidance Manual, which can be found here, was developed by OEHHA, in conjunction with the California Air Resources Board (ARB) for use in implementing the Air Toxics Hot Spots Program. This manual updates health effects values, exposure pathway variates (e.g., breathing rates), and continues to use a tiered approach for performing HRAs based on current science and policy assessment.

In comparison to the OEHHA 2003 document, the exposure pathways remain the same while revisions were made to the exposure and risk algorithms to accept new data or variables that are used in the tiered risk assessment approach.

The Revised OEHHA Guidance Manual incorporates the new scientific information about age sensitivity to early life exposures of air toxics and its impacts on lifetime risk of developing cancer and other adverse health effects. The Revised OEHHA Guidance Manual accounts for age sensitivity factors which can result in an increase of cancer risk estimates to residential and sensitive receptors by approximately three times, and more than three times in some cases where toxic air contaminant has multiple pathways of exposure.

ARB has released an updated version of the Hot Spots Analysis and Reporting Program (HARP 2). This version replaces the prior version and incorporates the information presented in the 2015 Revised OEHHA Guidance Manual. HARP 2 is now available for use in developing facility emission inventories and conducting health risk assessments. HARP 2 can calculate Tier 1 and Tier 2 risk assessments. The ability to conduct Tier 3 and Tier 4 risk assessments should be completed by summer 2015. The HARP software is available for download here.

The intent of the Revised OEHHA Guidance Manual and the HARP software is to incorporate children’s health concerns, update risk assessment practices, and to provide consistent risk assessment procedures. Various California air districts are either currently working or planning on extensive outreach efforts and conducting workshops to discuss the implementation of Revised OEHHA Guidance Manual into risk assessment procedures for various risk-based programs such as permitting, CEQA, and AB2588.

SJVAPCD Final Draft Staff Report – Update to District’s Risk Management Policy to Address OEHHA’s Revised Risk Assessment Guidance Document

Tuesday, March 24, 2015

San Joaquin Valley Air Pollution Control District (SJVAPCD) has released the final draft staff report on the proposed update to the Risk Management Policy to address the Office of Environmental Health Hazard Assessment’s (OEHHA’s) newly adopted Risk Assessment Guidance document. The updates to the Risk Management Policy (below) include the Governing Board’s directives and response to public comment:

SJVAPCD’s AB2588 Air Toxics Hot Spots program

  • The AB2588 thresholds will remain the same.

Permitting and CEQA

  • T-BACT
    • The SJVAPCD will require T-BACT for an increase greater than one (1) in a million cancer risk for a new or modified emissions unit.
  • Permitting and CEQA Project Approval Thresholds
    • For permitting purposes, the SJVPACD will not approve projects that result in a 20 in a million or greater cancer risk (cumulative for a facility since 1995, and with exceptions as noted in Policy APR 1905).
    • For CEQA purposes, projects that result in a 20 in a million or greater cancer risk should be considered to have a significant air quality impact.

Adjustment Factors

  • Residential Exposure Period
    • The SJVAPCD will continue using the 70-year exposure period as the default setting.
    • Age Groups (Bin)
    • The SJVAPCD will change from using a lifetime exposure to the use of age bins as the default setting.
  • Age Sensitivity Factors
    • The SJVAPCD will use OEHHA’s new age sensitivity factors as the default setting
  • Breathing Rates
    • The SJVAPCD will change from using a single lifetime breathing rate to using different breathing rates for each age group as the default setting.

The new age sensitivity factors can result in an increase in cancer risk estimates to residential and sensitive receptors by approximately three times, and more than three times in some cases where toxic air contaminant has multiple pathways of exposure.

Comments must be received by 5:00pm Pacific Time on April 1, 2015. More information can be found here.