BlueScape California Revised SCAQMD Rule 1402 for Air Toxics Webinar 102716
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.
Recommended
More Related Content
More from BlueScape
More from BlueScape (20)
Recently uploaded
Recently uploaded (20)
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
- 3. Air Toxic Hot Spots Program (AB2588) and Rule 1402
- 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
- 5. AB2588 Process Note: risk thresholds vary by air district
- 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
- 8. Summary of Rule 1402 Revisions
- 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
- 12. Source: SCAQMD Working Group Mee9ng Presenta9on, 7/27/16 Risk Reduc9on Pathways
- 13. Risk Reduc9on Timelines Source: SCAQMD Public Workshop and CEQA Scoping Session 8/10/16
- 14. Actions Required by SCAQMD under Revised Rule 1402
- 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
- 18. Methods to Reduce Reported Emissions and Health Risks
- 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
- 21. Summary & Next Steps
- 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