The South Coast Air Quality Management District (SCAQMD) Board passed proposed amendments to Rule 1402, Control of Toxic Air Contaminants from Existing Sources, on October 7, 2016. Rule 1402 implements elements of the California AB2588 Air Toxic Hot Spots Program, and has been revised for changes in State Health Risk Assessment Guidelines.
SCAQMD has been incorporating new HRA procedures into revised Risk Prioritization Guidelines and Health Risk Assessment Guidelines, and will be requiring facilities to use the new HRA procedures. SCAQMD will begin sending out letters to covered facilities offering the new Voluntary Risk Reduction Program, requiring Air Toxic Emissions Inventory updates, updated health risk assessment (HRAs) submittals, and other actions. The requirements will depend upon the level of reported health risk impacts, based upon an approved Air Toxic Inventory Report (ATIR) or HRA.
This webinar will answer your questions and provide you with helpful information you can use for compliance with Rule 1402 requirements:
- Description of Rule 1402 program steps, from emissions inventory, to prioritization, and health risk assessment.
- Your status in the Rule 1402 program, is your facility now a Significant Risk facility?
- How to work with SCAQMD to change status to a non-Significant Risk facility.
- Should your facility opt for Voluntary Risk Reduction, what are the benefits?
- Updating the Air Toxics Emissions Inventory or Health Risk Assessment, things you should know.
- What are the options to reduce health risk impacts?
- Timelines under the various Rule 1402 facility risk categories and compliance options.
The instructor for the webinar is James A. Westbrook, President of BlueScape Environmental. Since 1987, Mr. Westbrook has managed or completed more than 50 AB2588 ATIR and HRA projects for petroleum refineries, rock and gravel facilities, power plants, petroleum refineries, building material manufacturers, coating manufacturers, aerospace companies and many others.
BlueScape can be reached at training@bluescapeinc.com or 877-486-9257 for questions, customized training, and support for your air permitting, compliance and HRA projects.
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BlueScape California Revised SCAQMD Rule 1402 for Air Toxics Webinar 102716
1. Revised SCAQMD
Rule 1402 for Air
Toxics
Will You be Required to Take Action?
October 27, 2016
James A. Westbrook, CPP
jwestbrook@bluescapeinc.com
877-486-9257
2. Webinar
Topics
• Intro
AB2588
Regula9on
and
South
Coast
AQMD
Rule
1402
• Summary
of
Rule
1402
Revisions
• Ac9ons
Required
under
Rule
1402
– Updated
Air
Toxic
Inventory
Reports
(ATIRs)
– Updated
Health
Risk
Assessments
(HRAs)
– Voluntary
Risk
Reduc9on
op9on
– Early
Risk
Reduc9on
op9on
• Methods
to
reduce
reported
air
toxics
and
health
risks
• Summary
&
Next
Steps
4. AB2588
and
Rule
1402
Regulatory
Timeline:
• 1987
–
CA
Air
Toxics
“Hot
Spots”
Informa9on
and
Assessment
Act
(AB2588)
• 1994
-‐
South
Coast
AQMD
Rule
1402,
Control
of
Toxic
Air
Contaminants
from
Exis9ng
Sources
– Amended
in
2000,
2005,
June
2015
• March
2015
–
Revised
OEHHA
Health
Risk
Assessment
(HRA)
Guidelines
• June
2015
–
Updated
SCAQMD
AB2588
Priori9za9on
Procedures,
Supplemental
Guidelines
for
Preparing
HRAs
• October
7,
2016
–
Rule
1402
Amendment,
Voluntary
Risk
Reduc9on
Guidelines,
Public
No9fica9on
Procedures
• Future
–
updates
to
AB2588
Priori9za9on
Procedures,
Supplemental
Guidelines
for
HRAs
6. Rule
1402
Summary
• Implements
the
AB2588
Air
Toxics
Hot
Spots
Program
in
South
Coast
– Exis9ng
facili9es,
unlike
Rule
1401
for
new/
modified
units
or
facili9es
• Process
for
submieng
ATIRs
and
HRAs
– High
priority
facili9es
submit
an
HRA
• Key
Risk
Thresholds
– Public
No9fica9on
– Risk
Reduc9on
7. Health
Risk
Impact
–
Where
do
you
fit?
400
facili)es
in
South
Coast
AB2588
Program
Current
Breakdown
based
on
Cancer
Risk
Priori)za)on
Changes
–
Current
to
Future
Priori)za)on
Source:
SCAQMD
Working
Group
Mee9ng
Presenta9on,
9/28/16
80%
below
Public
No)fica)on
Threshold
9. Rule
1402
Revision
Summary
• Streamline,
consistency,
clarify
• Updated
Air
Toxics
Inventory
requirements
– AQMD
can
require
an
ATIR
outside
usual
process
– Provision
for
source
test
requirements
• Updated
HRA
requirements,
more
details
• Risk
Reduc9on
requirements,
minor
changes
• Addi9onal
requirements,
Poten9ally
High
Risk
Level
Facili9es
(or
Significant
Risk
Level
Facili9es)
– Process
to
designate
Poten9ally
High
Risk
Facility
– Early
Ac9on
Reduc9on
Plan
• New
Voluntary
Risk
Reduc9on
Program
• Updated
No9fica9on
Procedures
Guidance
10. Updated
Rule
1402
Risk
Thresholds
Source:
SCAQMD
Public
Workshop
and
CEQA
Scoping
Session
8/10/16
11. Voluntary
Risk
Reduc9on
• Eligibility:
– Approved
HRA
below
the
Ac9on
Risk
Level
• but
AQMD
may
consider
no
approved
HRA
– Not
a
Poten9ally
High
Risk
Level
Facility
– Facility
Owner
must
accept
the
challenge
to
reduce
below
No9fica9on
Risk
Level,
30
days
from
no9ce
– Compliance
with
Voluntary
Risk
Reduc9on
Requirements
• In
lieu
of
tradi9onal
path,
ATIR
to
HRA
and
Risk
Reduc9on
• 150
days
from
no9fica9on
to
submit
Voluntary
Risk
Reduc9on
Plan,
2.5
years
to
implement
• Submit
Plan
-‐
Facility
informa9on,
current
and
proposed
risks,
source
informa9on,
required
files
– AQMD
does
heavy
liking
on
the
technical
analysis
work
• Modified
Public
No9fica9on,
implement
risk
reduc9on
• See
the
Voluntary
Risk
Reduc6on
Program
Guidelines
15. POLL:
South
Coast
AQMD
Ac9ons
Under
Rule
1402
Has
your
facility
received
an
AB2588
or
Rule
1402
ac6on
leDer
from
South
Coast
AQMD
within
the
last
three
months?
16. Rule
1402
Ac9ons
Required
by
AQMD?
• No9ce
lelers
going
out
to
around
60
facili9es
– Exceed
No9fica9on
Risk
Level
– Many
due
to
the
changes
in
HRA
Guidelines
– Past
ATIRs,
HRAs
approved
or
not
approved
•
AQMD
Requirements:
– Prepare
an
updated
ATIR,
or
– Prepare
an
HRA,
or
– Opt
for
Voluntary
Risk
Reduc9on,
or
– Begin
designa9on
process
for
Poten9ally
High
Risk
Facili9es,
Early
Reduc9on
op9on
• Otherwise,
tradi9onal
AB2588
process
and
no9ces
may
go
out
17. Opt
for
Voluntary
Risk
Reduc9on?
• Things
to
Consider:
– Challenge
-‐
reduce
from
What
and
How?
– ATIR
current
enough,
or
updated
ATIR
will
show
no
HRA
needed?
– Updated
HRA
will
show
no9fica9on
level
not
exceeded?
– Reducing
actual
emissions
anyway?
– You
are
concerned
about
no9fying
the
public
about
risk
impacts?
– Costs?
• Going
tradi9onal
ATIR/HRA
path
can
get
expensive
– Source
test,
ATIR,
HRA,
$50,000
-‐
$100,000
• But
emission
controls
to
reduce
risk
can
be
even
more
expensive,
only
consider
if
needed
• Bolom
Line
–
how
can
you
best
officially
get
below
the
no9fica9on
risk
level?
– Facts,
analysis
changes,
risk
reduc9on
op9ons
available
• You
have
30
days,
think
it
through
and
weigh
the
benefits
and
costs
• Can
you
quickly
update
previous
submiled
ATIRs
or
HRAs,
nego9ate
with
AQMD
on
re-‐priori9za9on?
• Answer
for
most
is
likely
NO
voluntary
reduc9on
19. Air
Toxics
Emissions
and
Health
Risk
Reduc9on
• Air
Toxic
Emission
Factors
• Opera9onal
Changes
• Air
Quality
Modeling
Assump9ons
• Health
Risk
and
Exposure
Assump9ons
• Emissions
Control
Equipment
• Meet
with
AQMD
to
discuss
Op9ons
– Informa9on
accuracy
– Re-‐priori9za9on
of
risk
scores
– Refine
technical
analysis
before
having
to
do
risk
reduc9on
– Timing,
take
credit
for
permanent
emission
reduc9ons
20. Risk
Modeling
Refinements
Parameter
Technique
Effect
Source
Type
Change
to
Volume
or
Area
Refine
for
ini9al
dilu9on
Source
Height
Increase
Reduce
impacts
Emissions
Decrease
Decreases
impacts
linearly
Gas
Velocity
Increase
Decrease
impacts
Source
Loca9on
Relocate
Move
further
from
receptors
Time
of
Opera9on
Change
Dispersion
beler
during
day
Max.
Receptors
Spa9al
Averaging
Can
either
increase
or
decrease
impacts
22. Summary
&
Next
Steps
• The
thrust
of
Rule
1402
is
Risk
Reduc9on
– Goal:
Stay
out
of
Rule
1402
Ac6on
Requirements!
• New
priori9za9on
procedures
may
help
you
– Work
with
AQMD
and
refine
–
before
choosing
a
path
• “Look
forward”
to
a
more
interac9ve
process
with
AQMD
– Air
Toxic
emission
factors
and
source
tes9ng
– HRA
methods
and
formal
reports
– Risk
Reduc9on
and
No9fica9on
process
– Streamlined,
faster,
but
s9ll
long
9melines
• Voluntary
Risk
Reduc9on
–
weigh
benefits
and
costs
– Could
be
a
good
thing
in
right
circumstance
– Take
advantage
of
planned
emission
reduc9ons
– See
if
you
expect
to
get
below
the
Public
No9fica9on
Threshold
– Avoid
expensive
controls,
tradi9onal
path
may
be
beler
for
you
• Get
help
from
an
air
toxics
emissions
and
HRA
expert!
23. Ques9ons?
Contact
Informa9on
James
A.
Westbrook,
CPP,
President
BlueScape
Environmental
877-‐486-‐9257
jwestbrook@bluescapeinc.com
www.bluescapeinc.com
Connect
with
me
on
Linkedin!
The
webinar
presenta6on
will
be
posted
on
Slideshare
and
YouTube