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SCAQMD’s Work Plan for
Implementation of OEHHA’s
Revised Health Risk Assessment
Guidelines
March 18, 2015
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Agency Responsibilities
Develops Guidance
to Calculate
Health Risk
(Risk Assessment)
Health risk
assessment guidance
developed by Office of
Environmental Health
Hazard Assessment
(OEHHA)
Actions Based on
Risk Assessments
(Risk Management)
SCAQMD establishes risk
thresholds and risk
management
• Rule 1401 (New and Modified
Permitted Sources)
• Rule 1402 (AB2588 – Existing
Facilities)
• CEQA (New Projects)
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Background
• The Children’s Environmental Health Protection Act of 1999
requires susceptibility of infants and children be considered
in assessing the health risks associated with air toxics
• Scientific Review Panel (SRP) and Office of Environmental
Health Hazard Assessment (OEHHA) approved three
technical support documents
– 2008 - Noncancer Reference Exposure Levels
– 2009 - Cancer Potency Factors (age specific factors)
– 2012 - Exposure Assessment (breathing rates and
exposure duration)
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OEHHA’s
Revised Risk Guidelines
• On March 6, 2015 OEHHA approved a revision
to the Air Toxics Hot Spots Program Guidance
Manual for Preparation of Health Risk
Assessments
– Incorporated new studies on childhood
sensitivity
– Incorporated new data on exposure (e.g.
breathing rate and time at home)
• OEHHA’s health risk guidelines are used
statewide – all air districts throughout California
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How Will Health
Risks Change?
Age Specific Factors (2009 Cancer Potency Factors)
• Higher impacts to children
Breathing Rate (2012 Exposure Duration)
• Modified for different ages (e.g., higher for children)
Exposure Duration (2012 Exposure Duration)
• Reduced exposure duration (residential and worker)
Result: Residential Risk ~3X Higher*
* Preliminary estimate/subject to change. Up to ~6X for multi-pathway.
Worker risks decline ~2%
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OEHHA Revised Risk Guidelines
Impact On Cancer Risk
Residential / Sensitive
Receptor Cancer Risk
(Increased)
Worker Receptor
Cancer Risk
No Change
Revised
Quantification of
Facility
Emissions –
(No Increase in
Toxic Emissions)
Methodology
for Estimating
Cancer Risk
(Childhood
sensitivities and
breathing rates)
(Slight Change)
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“Umbrella Toxics Rules”
• Rule 1401 – Toxic requirements for new
and modified permitted sources
• Rule 1401.1 – Toxic requirements for new
and modified permitted sources near
schools
• Rule 1402 – Toxic requirements for
existing facilities
• Rule 212 – Noticing for new and modified
permitted sources
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Cancer Risk Limits for New and Modified
Sources and Existing Facilities
• Permitting (Individual equipment)
– New and modified sources (R1401):
• 1 in a million without TBACT*
• 10 in a million with TBACT
– New and relocated sources near a school
(R1401.1)
• 1 in a million (regardless of TBACT)
• Existing facilities (AB2588)
– 25 in a million facility-wide - risk reduction to
reduce risk <25
* TBACT is Toxics Best Available Control Technology
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Public Notification
Cancer Risk Thresholds
• Under AB2588, any facility with a facility-wide
MICR > 10 in one million must provide public
notice and a public notification meeting
• Rule 212 notification for new and modified permits
required if increase in toxic emissions causing:
– Cancer risk is > 1 in a million for facilities with more than
one permitted unit, unless total facility-wide MICR < 10
in a million; or
– Cancer risk is 10 in a million for facilities with a single
permitted unit
– Distribution of the public notice to each address within ¼
mile radius of the project
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Process
March
2015
• OEHHA
Approves
Revised
Guidelines
• HARP 2* to
be Released
to Public
April
2015
CARB and
CAPCOA
Approve Risk
Management
Guidelines
Air Districts
Implement
Guidelines
* Hot Spots Assessment Reporting Program 2 (HARP 2) will incorporate new
air dispersion model AERMOD and the Revised OEHHA Guidelines.
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SCAQMD’s
Air Toxics Program
MATES I
EJ
Initiatives
Rule 1401
1990
1994
Rule 1402
(AB 2588
Toxics
“Hot Spots”)
1997
2000 Air
Toxics
Control Plan
1998
MATES II
2000
Draft 2010
Clean
Communities
Plan
2004 ATCP
Addendum
2003
2004
Cumulative
Impacts
Strategies
White Paper
2005
2010
2014
Mates III
Represents adoption of a stationary source-specific toxic rule
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Trends in Cancer Risks Since 1990
(Excludes diesel PM)
Inhalation Cancer Risk (in a million)
1000
800
600
Burbank
Los Angeles
Long Beach
Riverside
Simi Valley
400
200
0
1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010 2012
Year
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Affected Programs
Permitting
AB2588 (Toxics Hot Spots)
• Rule 1401 – New and Modified
Permitted Sources
• Rule 1401.1 – New and Relocated
Facilities Near Schools
• AB2588 Core Facilities
• AB2588 Industry-Wide Facilities
• Rule 1402 – Control of Toxic Air
Contaminants from Existing Sources
Revised OEHHA
Guidance
Public Noticing
CEQA
• Rule 212 – New or modified permits
• AB2588 Facilities
• Air Toxics Analysis for
• Construction Phases
• Operational Phases
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General Approach
• Maintain public health protection – no back
sliding
• Ensure Revised OEHHA Guidelines do not
impede business activities
• Streamline implementation to minimize
business impacts and AQMD resources
• Provide outreach and communication to all
stakeholders
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Near-Term Needs
Interim permitting
provisions for specific
source categories*
Address inconsistencies
with Revised OEHHA
Guidelines
Implement AB2588
using Revised OEHHA
Guidelines
Policy for CEQA Projects
• Amend Rule 1401
• Develop source-specific rules, if needed
• Update supporting materials
• Amend Rule 1401 and 1401.1
• Amend Rule 1402
• Amend Rule 212
• Amend Rule 1402
• Revise Prioritization Procedures
• Revise Public Notification Guidelines
• Develop guidance for CEQA Guidelines
• Implement SCAQMD Lead Agency
Projects first
* Interim permitting provisions if needed, SCAQMD staff still analyzing
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Permitting Approach
• Implementation of Revised OEHHA
Guidelines will be forward looking
• Rule 212 notifications will continue to be for
new and modified sources
• SCAQMD permitting approach for toxics
uses a 4 Tier level screening approach –
each screening level incorporates more
specificity
– Developing screenings that are more equipment
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specific to streamline implementation
Permitting
• Interim provisions may be needed for
specific source categories that cannot
meet Rule 1401 risk limits
• Reviewing permit data to identify
sources that may have difficulties
meeting Rule 1401 risk limits under
Revised OEHHA Guidelines
• SCAQMD staff identifying approaches
to streamline implementation
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Permitting (Continued)
• Proposed Amended Rule 1401
– Narrowly provide temporary relief from
Revised OEHHA Guidelines for new and
modified sources that cannot be
permitted, if needed
– Allow use of previous OEHHA Guidelines
– Ensure “no backsliding” of health risks
• Update supporting documents
• Risk Assessment Procedures for Rules
1401 & 212
• Modeling screening tables
• Schedule: May 2015
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Rule Amendments to
Address Inconsistencies
• Rules 1401, 1401.1, 1402, and 212 include
references based on current health risk
guidelines such as exposure duration
• Recommendation:
– Amend Rules 1401, 1401.1, 1402, and
212 to reference Revised OEHHA
Guidelines
Schedule: May 2015
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AB2588 Background
• About 400 “Core AB2588” facilities
• Hot Spots Program is continuous
– Core facilities submit quadrennial reports -more
detailed toxics inventory ~177 TACs
– Prioritization of quadrennial reports
• Implementation of Revised OEHHA Guidelines
would occur through normal quadrennial
prioritization review
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AB2588
• Health risk assessments required under
Toxics Hot Spots Program shall be prepared
in accordance with Guidelines established
by OEHHA (Health and Safety Code
§44360(b)(2))
– SCAQMD must use Revised OEHHA Guidelines
for HRAs under the Hot Spots Program
• Recommendation:
– All HRAs not yet approved will be required to
use Revised OEHHA Guidelines
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AB2588 (Continued)
• Other action items to implement Revised
OEHHA Guidelines:
– Update Supplemental HRA Guidelines for
AB2588
– Revise Prioritization Procedures
– Revise AB2588 Public Notification Procedures
Schedule: May 2015
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CEQA
• Revised OEHHA Guidelines will affect
construction and operational phases,
particularly diesel and mobile sources
• SCAQMD’s CEQA Handbook references
Rule 1401 for risk assessment methodology
• Cancer risk threshold for CEQA significance
is 10 in a million
• Revised OEHHA Guidelines recommends
calculating cancer risk from construction
projects >2 months
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CEQA (Continued)
• SCAQMD staff evaluating options and will
develop recommendations
–Considerations – project size, availability of
cleaner construction equipment, implementation
schedule, etc. (Risk management)
–Recommendations presented to SCAQMD
Governing Board for approval
• Action items
–Reference Revised OEHHA Guidelines
–Develop recommendations – risk management
decisions (SCAQMD Governing Board)
–Implement SCAQMD Lead agency projects first,
then other lead agency projects
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–Schedule: May 2015
Outreach and Communication
• CARB and CAPCOA to develop a statewide
outreach and communication effort
• Messaging is important – Air toxic emissions have
not increased, state has changed how air toxics
risks are estimated
• Action Items:
–Regional Public Workshops March 31 to April 1st
–Conduct individual stakeholder meetings
–Develop outreach and communication materials
–Continue working with CARB and CAPCOA to develop
a statewide outreach and communication effort
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Regional Public Workshops
March 31, 2015 – 10:00 a.m.
Norton Regional Events Center
Auditorium
1601 E. 3rd Street
San Bernardino, CA 92408
April 2, 2015 – 10:00 a.m.
Buena Park Community Center
Ballroom
6688 Beach Boulevard
Buena Park, CA 90621
March 31, 2015 – 2:00 p.m.
Louis Robidoux Public Library
Community Room
5840 Mission Boulevard
Riverside, CA 92509
April 2, 2015 – 4:00 p.m.
Wilmington Senior Citizen Center
Community Room
1371 Eubank Avenue
Wilmington, CA 90744
April 1, 2015 – 10:00 a.m.
SCAQMD Auditorium
21865 Copley Drive
Diamond Bar, CA 9176
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Schedule
• April 24, 2015
• Mar 31-Apr 2
• April 3, 2015
• April 17, 2015
• May 1, 2015
Release of Proposed Amended
Rules: April 24, 2015
Public Workshops and Outreach
Set Hearing for Proposed
Amended Rules
Public Comment Ends
(Encourage early comments)
Adoption Hearing for Proposed
Amended Rules
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Next Steps
• Implement enhanced outreach and risk
communication activities
• Proceed with development of adjustments to
SCAQMD’s various programs related to Risk
Assessment
• SCAQMD Contacts:
– Victoria Moaveni – (909) 396-2455
Email: vmoaveni@aqmd.gov
– Susan Nakamura – (909) 396-3105
Email: snakamura@aqmd.gov
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