Oct. 6, 2017 – -Recently, some Almond Alliance  members have received notifications from the San Joaquin Valley Air Pollution Control District (SJVAPCD) that they need to submit a Toxics Emissions Inventory Plan (TEIP) to comply with AB 2588, the Air Toxics “Hot Spots” Information & Assessment Act. AB 2588 was passed in 1987, and until recently, most almond huller/shellers and processors did not have compliance requirements under AB 2588. In March 2015, the Office of Environmental Health Hazard Assessment (OEHHA) adopted changes to the Air Toxics “Hot Spots” Program Guidance Manual for the Preparation of Risk Assessments (Risk Assessment Guidelines). These revisions were mainly designed to provide enhanced protection to children as required by “The Children’s Environmental Health Protection Act.” Generally, the new adopted methodologies result in an increase in calculated health risk compared to previously estimated risk. As a result, the District is reassessing all facilities’ risk under the revised health risk estimation method.

All facilities emitting air toxics will be evaluated through the “Hot Spots” process in coordination with the District. Under this process, affected facilities are required to prepare a TEIP and Toxics Emissions Inventory Report (TEIR) to quantify site-specific inventories of air toxics emitted. Facilities currently on a quadrennial cycle under the “Hot Spots” program will remain on their current schedule for “Hot Spots” reassessment. For other facilities subject to “Hot Spots” reassessment, the District will follow the phased schedule below, starting in 2016-2017:

–    Year 1, Phase I Facilities: more than 25 Tons of Emissions per Year

–    Year 2, Phase II Facilities: more than 10 and less than 25 Tons of Emissions per Year

–    Year 3, Phase III Facilities: less than 10 Tons of Emissions per Year

–    Year 4, Phase IV Facilities: Industry-Wide and Agricultural Operations

The SJVAPCD will provide each facility with a customized TEIP template, which is basically an outline of all the equipment you have on-site based on your permits. The TEIP requires the facility to report both permitted and non-permitted equipment, describing what the equipment does, the type of emissions it has, and how to calculate the emissions. Once the TEIP is submitted, the District will review the TEIP, approve it, and then a TEIR will be due. The District will review the TEIR and then perform a prioritization analysis. Facilities will be classified as low-priority, intermediate-priority, or high-priority facilities. For low-priority facilities, no further information will be required. For intermediate-priority facilities, a toxics survey will be required every 4 years. For high-priority facilities, a health risk assessment will be required.

The Almond Alliance is partnering with Yorke Engineering to provide our members with a complimentary one-hour webinar to further explain the requirements of AB 2588 and answer any questions you may have. Yorke Engineering can also provide our members with compliance assistance.