AB 2588 Air Toxics “Hot Spots” Program

Air Toxics Intro | Air Toxics and Health | Air Toxics for Business | Air Toxics Regulations | AB 2588 Air Toxics “Hot Spots” Program

The District has published Guidelines for Preparing Air Toxics Emission Inventory Plans and Reports, which describe how to prepare an Air Toxics Emission Inventory Plan and Report for the AB 2588 Air Toxics “Hot Spots” Program.  The completed Modeling Protocol Tables for ATEIP must be submitted with the Air Toxics Emission Inventory Plan.

The District’s Approved Emission Factors for Toxic Air Contaminants and associated spreadsheet with emission factors, SBCAPCD-Approved TAC Emission Factors.xlsx, were updated.  Updates include emission factors for Hot Mix Asphalt Plants, Aggregate Materials and Haul Roads.  A complete list of changes can be found in the history of updates to approved emission factors for toxic air contaminants.  More information can be found on the District’s Toxic Air Contaminant Emission Factors webpage.

Overview

picture-this-what-are-we-doing-airtoxics-healthriskThe AB 2588 Air Toxics “Hot Spots” Information and Assessment Act of 1987 requires businesses and industries throughout the state to: 1) quantify and report their emissions of air toxics; 2) assess the possible health risks from their emissions; 3) notify members of the public who are exposed to significant risks attributable to their emissions; and, 4) take steps to reduce this risk.  The AB 2588 Flow Diagram shows the process in Santa Barbara County.  Implementation of this program has resulted in significant reductions in the amount of air toxics emitted in Santa Barbara County.  In 1991, 51 sources subject to the Air Toxics “Hot Spots” Program exceeded the Board-approved significant health risk thresholds.  Currently, there are no significant risk facilities in Santa Barbara County.

The AB 2588 Process

The first step in the AB 2588 process is developing in Air Toxics Emission Inventory Plan (ATEIP).  The purpose of the ATEIP is to ensure that the emission factors, calculation methodology, and all parameters that are included in quantifying the toxics emissions are provided to the District and approved by the District prior to implementation in the Air Toxics Emission Inventory Report.  The District’s approved toxic air contaminant emission factors may be used in the preparation of the ATEIP.  The District’s Guidelines for Preparing Air Toxics Emission Inventory Plans and Reports describes the requirements for preparing an ATEIP in Santa Barbara County.  In addition, the California Air Resources Board’s (CARB’s) Emission Inventory Criteria and Guidelines is the statewide resource for preparing an ATEIP and an ATEIR.

The second step of the AB 2588 process is preparing the ATEIR.  The purpose of the Air Toxics Emission Inventory Report (ATEIR) is to execute the emission calculation methodology described in the District-approved ATEIP.  The ATEIR includes documentation of all process data (e.g., annual reports, purchase records) and detailed emission calculation spreadsheets.  The District’s Guidelines for Preparing Air Toxics Emission Inventory Plans and Reports describes the requirements for preparing an ATEIR in Santa Barbara County.  In addition, CARB’s Emission Inventory Criteria and Guidelines is the statewide resource for preparing an ATEIP and an ATEIR.

In Santa Barbara County, the third step in the AB 2588 process is conducting a health risk assessment using the CARB’s Hotspots Analysis and Reporting Program (HARP) software.  The District’s Modeling Guidelines for Health Risk Assessments describes the requirements for performing health risk assessments (HRAs) in Santa Barbara County.  HRAs performed for AB 2588 are reviewed by the District and by the Office of Environmental Health Hazard Assessment (OEHHA).  If the HRA results are at or above the Board-approved significant health risk thresholds, then risk reduction and public notification are required.  If the HRA results are below the Board-approved significant health risk thresholds, then the AB 2588 process is complete for the specified inventory year.  If the HRA results are below a cancer risk of 1 in a million and all hazard indices are below 0.1 in a million, the facility is exempt from AB 2588.

If the facility’s risk is at or above the District’s significant risk thresholds, public notification is required.  Once OEHHA has approved the HRA, the facility operator must notify all exposed persons of any significant risk results.  The District’s Public Notification Procedures for AB 2588 explain the process of notifying the public in Santa Barbara County.

If the facility’s risk is at or above the District’s significant risk thresholds, the facility is required to conduct a risk reduction audit and develop a plan to implement risk reduction measures.  Implementation of these measures must reduce the risks below the significance health risk thresholds within five years of the date the plan is submitted to the District.  CARB’s General Guidance for Preparing Risk Reduction Plan is the statewide resource for preparing an Risk Reduction Audit and Plan (RRAP).  CARB’s website has additional resources for risk reduction.

If the facility does not qualify for the exemption based on their current risk results and the risk results are below the Board-approved significant health risk thresholds, the facility will submit a quadrennial updates summary every four years.  The quadrennial update summary is a short form that discusses changes in facility operations and other parameters that impact the health risk.  If minimal or no changes have occurred since the prior HRA, then an updated ATEIP, ATEIR and HRA are not required.  If significant changes have occurred that may impact the risk results, the facility is required to update their ATEIP, ATEIR and HRA.

“Hot Spots” Reassessment in Santa Barbara County

The reassessment status of all stationary sources in Santa Barbara County can be found on the District’s AB 2588 Reassessment Tracking webpage.

OEHHA updated their Air Toxics Hot Spots Program: Risk Assessment Guidelines in 2015 to ensure infants and children are explicitly addressed in assessing health risk, as required by Senate Bill 25.  In response, the District is reevaluating facilities under the AB 2588 program.  The District’s Board-approved Prioritization Procedures for AB 2588 were used with the District’s approved toxic air contaminant emission factors and the annual report data submitted by operators to identify “high priority” facilities.  “High priority” facilities are required to submit an Air Toxics Emission Inventory Plan (ATEIP) and Report (ATEIR), and then conduct a Health Risk Assessment (HRA).

Significant Risk Thresholds

In June 1993, the Santa Barbara County Air Pollution Control Board of Directors (District’s Board) adopted health risk notification levels.  Risk reduction thresholds were adopted by the District’s Board on September 17, 1998.  These risk reduction thresholds were set at the same level as the public notification thresholds. The District’s significant risk thresholds are:

Risk Significance Threshold
Cancer Risk
≥ 10/million
Chronic Non-Cancer Risk
> 1
Acute Non-Cancer Risk
> 1

Prioritization

At the start of the AB 2588 program in the 1990’s, facilities were prioritized based the potency, toxicity, and quantity of toxic pollutants released from the facility, along with the proximity of the facility to potential receptors.  Today the same prioritization calculation is still used as a tool to determine if a facility is subject to submitting an updated ATEIP, ATEIR and HRA.  The District’s Prioritization Procedures for AB 2588 were approved by the District’s Board in 1990.

Fees

The AB 2588 Air Toxics “Hot Spots” Act required that CARB develop and adopt a fee regulation that recovers the state’s costs to implement the program.  The state fees are described in detail on CARB’s “Hot Spots” State Fees webpage and in the Air Toxics “Hot Spots” Fee Regulations.  AB 2588 fees are assessed based on the facility’s risk results and the complexity of the facility.  In addition, there are special classes of categories such as industrywide, small business or exempt.  If the District is currently in the process of reviewing an ATEIP, ATEIR, HRA, RRAP or conducting public notification for a facility, the District fees for the facility are assessed on a cost reimbursable basis based on the actual time worked on the facility’s project.  For facilities that are not assessed fees on a cost reimbursable basis, the District fees are equal to the state fees.

For more information or assistance, please contact Charlotte Mountain at (805) 961-8877 or at [email protected] (Air Toxics Section).