All American Asphalt - AB 2588 and Health Risk Assessment

Recent Updates

South Coast AQMD has approved the revised Air Toxics Inventory Report (ATIR) for the All American Asphalt facility in Irvine (AAA) on December 7, 2021 with minor corrections. The facility was required to submit a Health Risk Assessment (HRA) based on the approved ATIR, which was submitted on February 1, 2022. Following a review, South Coast AQMD rejected the HRA on February 23, 2022 because it did not meet the general guidelines and did not include the correct emissions information. AAA will have 60 days to correct the deficiencies and resubmit the HRA.


  • As noted by some community reports, there are some emission differences reported by AAA between 2016 and 2017. South Coast AQMD is requiring AAA to correct these emissions reports using the most up-to-date information. Once the new information has been received and approved , the emissions data on the agency’s F.I.N.D. database will also be updated.

  • Potential health impacts depend on the type of pollutant, the amount released and the potency of the chemical, which can vary by many orders of magnitude. AAA was required to submit a Health Risk Assessment (HRA), based on the approved ATIR, to incorporate site-specific source testing results. An HRA is a technical study that evaluates how toxic emissions are released from a facility, how they disperse throughout the community and the potential for those toxic pollutants to impact human health.

  • Recent community air sampling efforts from South Coast AQMD show that average levels of air toxics at each community monitoring site are within background levels and below long-term health thresholds.

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

Emissions Or Throughput  Calendar Year 2016  Calendar Year 2017


Correctly reported using South Coast AQMD ‘default’ emission factor for natural gas combustion in the rotary dryer burners

Incorrectly used South Coast AQMD ‘default’ emission factor that includes ammonia from selective catalytic reduction (SCR) controls for the rotary dryer burners, leading to overestimation of ammonia emissions. The dryer burners are not controlled by SCR. This did not affect other emissions estimates

(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 dryer and silos.

Health Risk Assessment (HRA)

Based on the preliminary results of the ATIR received on October 22, 2021 which 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, AAA was required to prepare an HRA. The HRA will evaluate to what extent toxic emissions from AAA impact health risks in the surrounding community, and whether those risks exceed South Coast AQMD thresholds. If thresholds are exceeded, additional actions from AAA would be required, including public notification processes and potentially risk reduction actions.

An HRA was submitted, but following agency review, it was rejected on February 23, 2021 for not meeting agency rule requirements. AAA has 60 days to correct its deficiencies and resubmit an updated HRA.

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 

AAA must revise its HRA, and resubmit it by April 26, 2022.

If the results of the HRA indicate that risks are above notification thresholds, South Coast AQMD will notify the public and require that the facility take steps to reduce the potential risk.

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