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All American Asphalt - AB 2588 and Health Risk Assessment

Recent Updates

On August 19, 2022, South Coast AQMD conditionally approved the revised Health Risk Assessment (HRA), submitted on April 25, 2022 for the All American Asphalt facility in Irvine. The facility was required to submit the HRA based on the approved Air Toxics Inventory Report (ATIR), which was submitted on February 1, 2022.

EMISSIONS REPORTING ERRORS

There were some emission differences reported by AAA between 2016 and 2017. South Coast AQMD subsequently required AAA to correct emissions reports from 2015 through 2021 using the most up-to-date information.

The emissions data on the agency’s F.I.N.D. database from 2015 through 2021 has been updated with the corrected emissions. These updated emissions reports and methods are consistent with those used in the approved Health Risk Assessment. 

Details regarding the key differences in the previous emissions reports originally submitted to South Coast AQMD are outlined in the table below.

Emissions Or Throughput   Calendar Year 2016 Calendar Year 2017 
 Ammonia
 
Correctly reported using South Coast AQMD ‘default’ emission factor for natural gas combustion in the hot oil heater.
 
Incorrectly used South Coast AQMD ‘default’ emission factor that includes ammonia from selective catalytic reduction (SCR) controls for the hot oil heater, leading to overestimation of ammonia emissions. The hot oil heater is not controlled by SCR. This did not affect other emissions estimates.
Metals (arsenic, cadmium,
hex chrome)
Incorrectly assumed additional air pollution control (baghouse) applied to EPA ‘default’ emission factors for the rotary dryer, leading to underestimation of metals emissions. The ‘default’ emission factors already accounted for baghouse controls. Correctly reported using EPA AP-42 ‘default’ emission factor for the dryer
Benzene and Formaldehyde Incorrectly assumed air pollution control (baghouse) applied to EPA ‘default’ emission factors for the rotary dryer and silo emissions, leading to underestimation of benzene emissions. Baghouses do not control benzene emissions.
Correctly reported using EPA AP-42 emission factor for the rotary dryer and silos with the exception of formaldehyde which incorrectly states is from AP-42 resulting in an underestimation of formaldehyde emissions.

Health Risk Assessment (HRA)

The preliminary results of the ATIR received on October 22, 2021 contained enough information to indicate that nickel, formaldehyde, and benzene emissions from the facility could potentially cause an exceedance of the Rule 1402 Notification Risk Level. Rule 1402 establishes three health risk levels: Significant Risk Level, Action Risk Level, and Notification Risk Level (which is the lowest of the three thresholds). AAA was therefore required to prepare a HRA to quantify the facility’s potential health risk impacts to the surrounding community and compare those health risks to South Coast AQMD Rule 1402 risk levels. The HRA was submitted on February 1, 2022. Following a review, South Coast AQMD rejected the HRA on February 23, 2022 because it did not meet South Coast AQMD guidance and did not include the correct emissions information.

AAA submitted the revised HRA* on April 25, 2022. Following review by both the state Office of Environmental Health Hazard Assessment (OEHHA) and South Coast AQMD, the HRA was conditionally approved on August 19, 2022 (PDF). Consistent with South Coast AQMD and state guidance, the HRA used air toxic emissions from the 2016 calendar year. The results of the HRA found potential non-cancer health impacts 300 feet southwest from the facility, triggering public notifications. Specifically, the non-cancer health risk exceeds the Notification Risk Level set in the agency’s Rule 1402 for short-term (acute) exposure, primarily due to nickel emissions. The 300 ft impact zone is limited to the immediate surrounding area of the facility with limited access to the public and does not impact nearby residential areas or other areas where people may be regularly exposed.  AAA must notify any affected parties within 30 days of approval of the HRA.

* This document includes redacted sections that the facility has identified as Trade Secret or Confidential Business Information. As part of the South Coast AQMD’s Public Records Guidelines, information which constitutes trade secrets and which is used to calculate air emission data are not public records and not available to the public ([Gov. Code Sec. 6254.7(e)].)


Air Toxic Inventory Report (ATIR)

South Coast AQMD sent a Notice to Prepare an ATIR in February 2020. The facility submitted its ATIR in July 2020—which was within rule requirements. The preliminary ATIR used allowable default emission factors rather than site-specific factors to estimate emissions. Non-site-specific, default emissions factors often result in overestimation of emissions for facilities. South Coast AQMD asked AAA to conduct site-specific source testing of the rotary dryer to develop a more accurate emissions profile. Information from the source testing was used in the updated, approved ATIR.  

The source testing of the rotary dryer was completed over several dates (see below). AAA submitted a revised ATIR on October 22, 2021, however, technical deficiencies were identified and the ATIR was rejected (click here for a copy of this letter). South Coast AQMD received a revised ATIR on December 7, 2021, which was approved with minor corrections (click here for a copy of this letter).  

Source Testing

A source test is a procedure where air samples are collected from a specific emissions source (i.e. piece of equipment or exhaust stack), then analyzed in a laboratory. Prior to conducting the source test, a facility is required to submit information about their source test to South Coast AQMD for approval to ensure proper protocols will be followed (e.g., the test conditions are representative of normal operating conditions, etc.). Additionally, the source test must be conducted by a third-party company that has been certified/approved by South Coast AQMD through our Laboratory Approval Program.

The facility has conducted several source tests as part of permitting requirements (see Permitting & Source Testing for more information including the source test results).

On several dates in June and July 2021, independent source testing was also conducted on AAA’s rotary dryer for the ATIR. Results from this source test were submitted by the facility on August 20, 2021. South Coast AQMD identified errors in reporting of polycyclic aromatic hydrocarbons (PAH) and corrected results were provided by the facility on November 2, 2021. Following a review of the corrected report, an amended evaluation approval was provided to the facility on November 5, 2021. These amended results were included in the required correction to the ATIR, which was received on December 7, 2021.

Source Test Reports*:

* These documents include redacted sections that were identified as Trade Secret or Confidential Business Information. As part of the South Coast AQMD’s Public Records Guidelines, information which constitutes trade secrets and which is used to calculate air emission data are not public records and not available to the public ([Gov. Code Sec. 6254.7(e)].)

Next Steps 

South Coast AQMD anticipates hosting a community meeting in September to provide updates on AAA. To be notified with details of this meeting as they become available, please sign up at www.aqmd.gov/sign-up.









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