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 Air Toxics Emission Inventory Report (ATEIR).  The purpose of the 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 (HRA) using CARB’s Hotspots Analysis and Reporting Program (HARP) software.  The District’s Modeling Guidelines for Health Risk Assessments describes the requirements for performing 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 exceed the Board-approved significant health risk thresholds, then risk reduction and public notification are required (see steps 4.a and 4.b below).  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 shows a cancer risk result below 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 results exceed any of 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 results exceed any of 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 RRAP 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 update 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.