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All American Asphalt - Permitting and Source Testing

Title V Permitting

Title V is a federal program designed to standardize air quality permits and the permitting process for major sources of emissions across the country. A “major source,” is defined as a facility that emits, or has the potential to emit pollutants above a certain threshold. For more information on the  Title V program, please visit South Coast AQMD’s Title V Permitting Page.

AAA’s 2018 and 2019 self-reported emissions under South Coast AQMD’s Annual Emissions Reporting Program, has triggered Title V applicability.   Therefore, on Feb 4, 2021, AAA was notified to submit an Initial Title V permit application, which was submitted on May 5, 2021. The Initial Title V permit application is the first step in bringing the facility into the Title V Program. 

South Coast AQMD has completed review of the initial Title V permit application and found errors to the emissions data and corrected those errors.  As part of the Title V permit process, the facility is required to distribute a public notice and the proposed permit will be available for a 30-day public comment period beginning on September 28, 2022 and ending on October 28, 2022. South Coast AQMD will review and respond to all public comments received before the permit is issued. Additionally, the permit was provided to U.S. EPA for their review.  

No new equipment will be permitted under the Title V permit. Instead, additional permit conditions will be placed on existing equipment such as increased monitoring, record keeping and reporting requirements. 

A public notice is required to be distributed and published by the facility.  A copy of the public notice and proposed Title V permit is located on South Coast AQMD’s Permitting Public Notices webpage (Facility ID 82207). All existing permits can be found on South Coast AQMD’s through F.I.N.D. tool (Facility ID 82207).   

Once approved and final, the Title V permit will be required to be renewed every five years using the same public noticing process.  

More information on all Title V public notification requirements and processes for public hearings are discussed under Rule 3006 – Public Participation (PDF).


Permitting Update

On August 27, 2021, South Coast AQMD issued a number of permits for the AAA facility. The permits were approved for: the crumb rubber system/asphalt blending system and the associated asphalt oil heater, electrostatic precipitators, and the carbon adsorption air pollution control equipment. Permit conditions have been included to ensure that the equipment continues to comply with all South Coast AQMD rules and regulations. The permit conditions include periodic monitoring of the exhaust of the carbon adsorption system, carbon change out requirements, throughput limits, and operating temperature limits. The equipment permitted is expected to reduce compounds associated with odors. 

The permits for the above listed equipment can be found below. 


Source Testing Update

As part of the permit evaluation, source tests were conducted at both the inlet and outlet of the new carbon adsorption unit. Testing was performed by an agency approved, independent, third party contractor and the tests were observed by South Coast AQMD staff. Source testing was conducted using EPA and CARB approved methodology. The results have shown that the capture and control system in place (known as the carbon adsorption unit) reduces odorous VOC and sulfur emissions from the crumb rubber/asphalt blending system by 97.9% and 98.6%, respectively. In addition, tests showed that 100% of the emissions created by the blending process are captured and vented to the carbon adsorption unit.

Additionally, source testing for toxic compounds such as metals, polycyclic aromatic hydrocarbon compounds, and speciated organic toxics were performed at the exhaust of the crumb rubber/asphalt blending system. Many of the toxic compounds were so low, they were below the analytical limits and considered to be non-detectable. For those toxic compounds that were detected, an evaluation was performed to determine the potential health risks from the crumb rubber blending system based on the worst-case emission numbers (meaning higher numbers than those actually emitted were used to demonstrate highest possible exposure). Emissions from the natural gas-fired oil heater, which heats the oil for the crumb rubber/asphalt blending system were calculated using emission factors for the combustion of natural gas. 

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)].)

How is the cancer risk calculated?

South Coast AQMD Rule 1401 lists compounds that are considered toxic air contaminants (TAC) and includes health risk thresholds for permitted equipment. TAC emission information for the crumb rubber/asphalt blending system and oil heater is inputted into a computer-based model that estimates the amount of exposure over a 30 year period also referred to as the potential Maximum Individual Cancer Risks (MICR) for the community closest to the facility.

Cancer risk is the probability of a person developing cancer from continuous, maximum exposure to one or more toxic air contaminants over 30 years and is expressed as the probability per million. The MICR threshold established under Rule 1401 is 1.0 in one million.

Health Impact of Crumb Rubber/Asphalt Blending System

The results of the evaluation show that the cancer risk from the crumb rubber/asphalt blending system with the capture and control unit is 0.135 in a million, and 0.002 in a million for the oil heater; both below the threshold of 1.0 in a million. (See charts below).

Crumb Rubber-Asphalt Blending System

* Chromium was analyzed as elemental chromium. For purposes of cancer risk analysis, all chromium was assumed to be hexavalent chromium (Cr+6) as a worst-case scenario, but actual emissions of Cr+6 are expected to be less.

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