California Air Resources Board (CARB) is updating the AB 2588 Emissions Inventory Criteria and Guidelines Regulation and Report (EICG) to improve air toxics emissions estimates, enhance public right-to-know, and streamline the program with other reporting programs. AB 2588, the Air Toxics "Hot Spots" Information and Assessment Act, is designed to reduce localized air toxics exposure and risk from stationary sources by requiring stationary source facilities to report the types and quantities of toxic substances they routinely release into the air to CARB. The EICG provides applicability provisions for facilities subject to reporting requirements for preparing Emission Inventory Plans and Reports, source testing and emission factors, definitions, and other requirements. The amendments to the EICG may require facilities to develop new or updated toxic emissions inventory plans and report after implementation, which is anticipated to begin in 2022 for calendar year 2021 data.
CARB is proposing multiple amendments to the EICG, and following is a summary of these amendments.
Appendix A provides the list of substances that must be reported and is split into three sections:
- Substances for which emissions must be quantified (Appendix A-I)
- Substances for which production, use, or other presence must be reported (Appendix A-II)
- Substances which need not be reported unless manufactured by the facility (Appendix A-III)
AB 2588 statute specifies six source lists for CARB to review to compile Appendix A, which was last updated in November of 2006. Since then, CARB has evaluated over 1,500 potential substances and screened out approximately 600 substances. The proposed updates to Appendix A will add approximately 730 substances to Appendix A-I, 10 substances to Appendix A-II, and 60 substances to Appendix A-III. CARB is also proposing the addition of three new chemical functional group categories: isocyanate compounds, PAH derivatives, and PFAS related compounds. In addition, CARB is planning to develop a non-regulatory technical supplement for Appendix A to provide helpful information on health effects and known uses of different chemicals.
Appendix B addresses reporting formats and instructions. The proposed amendments include removing the requirement for hard copy reporting, adding building height and parameters as part of reporting to ensure that downwash is considered, and including provisions regarding Limit of Detection (LOD) for sampling. Detailed Appendix B amendments are not currently available but are in development.
Appendix C provides “look up” guidance tables for air toxic chemicals expected to be associated with particular processes (e.g. combustion, solvent use) or specific industry sectors. CARB is providing additional details with the proposed amendments to Appendix C.
Appendix D provides guidelines for source testing. The proposed amendments will update the stationary source emissions measurement and fuel analysis methods to current versions. In addition, a new source testing requirement for “open” types of sources such as wastewater treatment plants, landfills, and composting is being introduced. As part of this addition, CARB is implementing a new two-step process for chemical review at facilities that receive waste streams. This two-step process will include an initial, broad, qualitative screening for detectable chemicals, which are then reviewed to determine a list of chemicals for quantitative testing. CARB is also allowing for the use of a “pooled” source test approach for similar facilities.
Appendix E provides reporting thresholds for smaller facilities, emitting less than 10 tons per year of a single criteria pollutant. CARB is amending Appendix E to harmonize with the AB 617 Criteria and Toxics Reporting (CTR) Regulation and to reflect 2015 updates from the Office of Environmental Health Hazard Assessment (OEHHA). This update will include expanding the sector list to match AB 617 and reducing select process thresholds for reporting. CARB is also considering adding a sector for facilities that emit more than 4 tons per year of a single criteria pollutant (but less than 10 tons per year) to further align with the CTR regulation. In addition, CARB is reducing the process thresholds for select processes, including solvent degreasing using a carcinogenic material, crematoria, and diesel engines. Facilities that were previously exempt from reporting due to being below Appendix E thresholds may be affected by the proposed Appendix E amendments and may be required to report under AB 2588.
Section XI of the EICG
This section includes requirements for diesel engine reporting and are being updated to reflect OEHHA risk methods, latest AERMOD modeling guidance, building downwash effects, and more engine scenarios. The updates will require “stationary” portable diesel engines with greater than 50 horsepower to report emissions. If this requirement is aligned to AB617, then the criteria will apply to PERP registered engines that are used at a facility in any three different months of the year. This will apply to predictable or routine use at all facilities subject to the CARB MRR or facilities with greater than 250 tons per year of criteria pollutants that have PERP registered engines at their stationary source.
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