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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
- 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.
- 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.
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.
ARB’s Consumer and Commercial Products Survey Deadlines and Extensions
Wednesday, February 25, 2015
The California Air Resources Board (ARB) is conducting a mandatory Consumer and Commercial Products Survey to gather data regarding consumer and commercial products that were supplied or sold for use in California during calendar years 2013 through 2015.
The deadlines for the surveys are as follows:
- 2013 Survey:
- Responsible Party – March 2, 2015
- Small Businesses – July 1, 2015
- Formulators – April 1, 2015
- 2014 Survey:
- Responsible Party and Formulators – November 1, 2015
Small businesses and formulators have been granted an extension for the 2013 survey due to insufficient time to collect data and do not need to submit any extension requests. A small business is defined as a company with 25 or fewer full-time, part-time, and contract employees combined. All responsible parties have the option to request an extension of the original due date for the 2013 survey. These requests must be emailed to email@example.com by February 27, 2015. More information on extension requests can be found here.
For more information or assistance regarding this survey, contact Trinity at (949) 567-9880.
SCAQMD Proposed Amended Rule 1148.1 - Oil and Gas Production Wells
Wednesday, February 25, 2015
The South Coast Air Quality Management District (SCAQMD) is proposing to amend Rule 1148.1 - Oil and Gas Production Wells, in order to reduce nuisance and potential exposure near sensitive receptors. Rule 1148.1 applies to onshore oil producing wells, well cellars, and produced gas handling operation and maintenance activities. The amended rule would strengthen the regulatory language, add odor prevention measures and monitoring, and set-up a tiered requirement system based on sensitive receptor proximity and how many odor complaints a facility has received in the past 12 months. The highest tier would require an Odor Mitigation Plan for sources within 1,500 feet of a sensitive receptor who have experienced five (5) confirmed odor complaints within prior 12 month, or received a Notice of Violation (NOV) for odor. The proposed amendment would also expand the definition of Sensitive Receptor by including residential homes along with K-12 schools, hospitals, daycare centers, and convalescent homes. By including residences as sensitive receptors plus adding new odor mitigation and other requirements, SCAQMD hopes to lessen the amount of odor complaints it receives from the operation of oil and gas production wells.
The SCAQMD has held two working group meetings regarding this amendment, and a public hearing will be held in quarter two of 2015.
For more information regarding this amendment and future compliance, please click here for more information.