What’s all of the buzz related to air toxics and the new health risk guidelines put out earlier this year?
Does it have the ability to impact the operations at your facility?
Let’s take a look.
The Back Story
Earlier this year, the California agency responsible for assessing environmental health hazards released an updated guidance document related to assessing the health risk from air toxics.
If you’re dying to know the name of this agency, it’s called, the “Office of Environment Heath and Hazards Assessment” otherwise known as “OEHHA.”
Now, this health risk assessment document is not new. In fact, this health risk document has been around since 2003.
The big news for this year is that OEHHA simply updated the document.
The updated guidance document now incorporates new data and studies related to childhood sensitivity. The updated guidance document also incorporates new data related to the ways that people are exposed to air toxics.
So what is the net result from all of their work?
The calculated health risks from facilities have now been revised for residents and workers.
- For residents, the revised risk is now ~3-times higher than previously calculated.
- For workers, the revised risk is now ~2% lower than previously calculated.
But if this is too abstract, just know that there are potential material impacts to an industrial facility within the South Coast Air Quality Management District (SCAQMD), because of the latest work from OEHHA.
Why the Change?
These changes are due to the work that OEHHA has been doing to incorporate children and infants into the health risk calculation for the past 10 or so years.
From this work, it’s important to know that the emissions of air toxics have not increased, only the way that the health risk from these emissions is quantified.
As a regulated entity within the SCAQMD the new OEHHA guidelines have the ability to impact your facility because of one or more of the following rules.
- Rule 212
- Rule 1401
- Rule 1401.1
- Rule 1402
These rules are called the “umbrella rules,” for air toxics and are applicable to a facility when assessing compliance or during the SCAQMD’s permitting process.
As a side note, all of the SCAQMD rules related to air toxics have been updated to reflect the new health risk guidance, and should be referenced during permitting or when assessing compliance to avoid problems.
So let’s look at the 3 ways that the new rules for air toxics and impact your next big project.
1. General Permitting Strategies Could Change
First, if you are preparing a permit for the SCAQMD, the new guidelines may change the health risk calculated from your application due to the emissions of air toxics from your project.
Some of the direct outcomes of this change include:
- More stringent controls to meet permitting requirements.
- Changes to the manufacturing process or products used within the process
- Requirements for more extensive modeling
- Reduced throughput to lower health risk levels
- The issuance of more public notices
- Generation of new risk-reduction plans and measures.
Also, depending on the equipment being permitted, there is a risk that some sources may not be able to obtain permits for the following reasons.
- Throughput limits are too low to operate profitably.
- Control equipment may be too expensive or unavailable for your project.
2. AB 2588 Health Risk Assessments May Need To Be Resubmitted
In addition, if you are one of the facilities that have a pending AB2588 health risk assessment (HRA) filed with the SCAQMD, then you may need to revise your HRA with the new data and resubmit it to the SCAQMD.
Again, depending on the specific compounds being emitted by your facility, your overall health risk could change.
And upon re-submission of your HRA, you may also be required to complete the following:
- Distribution of more public notices.
- Implementation of new risk reduction plans.
3. CEQA Documents May Be Needed For Your Project
Lastly, if you have a project that is subject to the California Environmental Quality Act (CEQA), the new guidelines will affect the construction and operational phases of the project that have diesel and mobile sources.
From these construction projects, the diesel emissions alone are enough to drive up the health risk significantly.
As a result, the new guidelines may require more projects to prepare CEQA documents based on construction emissions.
Let’s Take It Over To You
A 3-fold increase in health risk is nothing to ignore.
The potential impacts due to the new health risk guidance should drive the development of a robust permitting strategy when considering new equipment (or even modifying existing equipment).
Are you prepared to “pivot” within your project in the event that the new health risk from your project is too high?
Are you prepared to reduce your throughput or even purchase additional equipment as a means of “lowering” the health risk from your project?
Whatever the case, meeting with the SCAQMD’s staff, proper planning, and most important, flexibility, will mostly likely be the three keys to a successful project when dealing with these new guidelines.
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