ecd general permit framework - ourair.org

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Authority to Construct 14542

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EQUIPMENT OWNER:

John Bodger & Sons Co.

EQUIPMENT OPERATOR:

Donan Environmental Services, Inc.

EQUIPMENT LOCATION:

1851 W. Olive Avenue, Lompoc

STATIONARY SOURCE/FACILITY:

AUTHORIZED MODIFICATION:

This permit grants approval to install and temporarily operate a Phase III soil vapor extraction system

with carbon canister controls.

PROJECT/PROCESS DESCRIPTION:

The equipment covered by this permit is designed to remediate contaminated soil and groundwater

in-situ at 1851 W. Olive Avenue in Lompoc from contamination by leaking underground gasoline

storage tanks. The contaminated soil and groundwater will be remediated by using a vapor extraction

system (VES) and extraction wells to remove the contaminated vapor from the unsaturated soil zone

and sending the vapors to two (2) carbon canisters in series. Inlet ROC, Benzene, Toluene,

Ethylbenzene concentrations are expected in the ranges of 1400 ppmv, 3ppmv, 1 ppmv and 1 ppmv,

respectively.

EQUIPMENT DESCRIPTION:

1. Water Pump: Manufacturer: Goulds Model: C0348662; 10 horsepower electric motor; maximum

flow 3.26 scfm)

SSID: 11258

Olive Ave, 1851 W. (CSC) FID: 11516

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2. Seven (7) vapor extraction wells, 4 in diameter, 65 feet deep, radius of influence of 9 feet

3. High Flow Rotary Lobe Blower: Manufacturer: Baldor Model: 21727; 1/4 horsepower electric

motor; maximum flow 250 scfm)

4. Monitoring devices to monitor common manifold and vapor extraction system temperature,

vacuum, and flows.

5. Piping, valves, fittings and connections.

Phase III Emissions Control

6. Two (2) carbon canisters: Manufacturer: Pure Effect; Model PEV1000; maximum capacity

1,000 scfm each; dimensions 4.0 feet diameter by 4.0 feet in height; each unit contains

approximately 1000 pounds of activated carbon; the canisters are arranged in series)

PHASE III CONTROL PARAMETERS - CARBON CANISTERS

Maximum Influent Gas flow rate: 250 scfm

Maximum Exhaust Gas flow rate: 250 scfm

Stack diameter: 19 inches

Stack height: 13 feet

Stack outlet temperature: 60 °F (minimum)

CONDITIONS:

1. Emission Limitations. At no time shall emissions to the atmosphere exceed any of the

following:

TABLE 1. PERMITTED EMISSIONS

Carbon Canisters ROC Benzene Toluene Ethylbenzene

lb/hr 0.48 0.0009 0.0004 0.0004

lb/day 11.46 0.0223 0.0088 0.0101

tpy 2.09 0.0041 0.0016 0.0018

ppmv 140 0.30 0.10 0.10

Compliance with these emission limits shall be determined by sampling and laboratory analysis

required in the Monitoring Condition as well as the other conditions of this permit.

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2. Fugitive Emissions. Contaminated excavated soils and soil borings shall be covered with

20-mil heavy duty plastic sheeting, or two sheets of 10-mil heavy duty plastic sheeting, or placed

in a sealed container. The plastic sheeting shall be completely secured to prevent fugitive

emissions. Contaminated excavated soils and soil borings shall be disposed of within ten days at

an approved treatment/disposal facility unless an extension is requested and granted by the

District.

a. ROC Emissions. All equipment that comes in contact with hydrocarbons shall not have

detectable leaks. A leak is defined as any reading greater than 100 ppmv above

background by a portable photoionization detector (PID) that is calibrated to isobutylene.

b. Particulate Matter Emissions. During dry periods (defined here as no measurable

precipitation during past three calendar days), water sprays or other adequate measures

shall be applied twice daily to all areas disturbed by construction with the potential to emit

fugitive dust. Additionally, adequate dust control shall be used to prevent fugitive dust

from being transmitted offsite. Upon completion of soil-disturbing activities in each area,

soil shall be stabilized to prevent wind erosion.

3. Operation Limitations. The permittee shall comply with the following operational limits:

Carbon Adsorption

a. The stack exhaust gas flow rate to the atmosphere shall not exceed 250 scfm.

b. The stack exhaust gas temperature shall be maintained at or above 60 °F.

c. The ROC removal efficiency across the carbon canisters shall be greater than 90 percent

(mass basis), or outlet stack ROC concentrations shall be ≤ 10 ppmv, whichever is

attainable.

d. This permit may only be used to remediate contaminated soil in-situ exclusively from

contamination caused by leaking gasoline storage tanks.

Compliance with the above conditions shall be determined through monitoring, recordkeeping

and reporting conditions of this permit.

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4. Monitoring. The permittee shall implement a monitoring program consistent with the "Guidance

Document for Emission Verification of Contaminated Soil/Groundwater Cleanup Process”

(Guidance Document, August 1991 and all updates thereof) and the District-approved "Emission

Verification Test" (EVT) Plan for this facility. The following components shall be monitored for

the life of the project:

a. Stack Exhaust Flow: At least once per week (during carbon breakthrough testing), the

stack exhaust flow rate (in units of scfm) from the carbon control system shall be monitored

using District-approved methods.

b. Sampling – Lab Analyses. The ROC, Benzene, Toluene, Ethylbenzene and all other VOC

content (ppmv and lb/hr), and other parameters required by the District, of both the control

device influent and effluent shall be sampled using gas tedlar bags (or District approved

equivalent) within 15 minutes of each other at least once per month. A state certified

laboratory shall analyze these samples for ROC, Benzene, Toluene, Ethylbenzene and all

other VOCs. During sampling, all system process parameters shall be recorded (including

stack exhaust flow rates in units of scfm and temperature). Test results shall be available

within 10 days of sampling. The permittee shall immediately assess compliance with the

requirements of this permit upon receipt of the test results and shall initiate the required

actions for carbon replacement and/or system shutdown. This sampling shall be done

monthly.

c. PID Sampling. Conduct weekly PID sampling at the “carbon in”, “carbon mid”, and

“carbon out” sampling ports. The permittee shall immediately assess compliance with the

requirements of this permit and shall initiate the required actions for carbon replacement

and/or system shutdown.

The permittee shall notify the District via e-mail ([email protected], Attn: CSC Project

Manager) within 24 hours of discovery of being out of compliance with the requirements of this

permit.

Upon showing reasonable need, the District may require an increased (or decreased) monitoring

frequency. Backup documentation such as instrument calibration, equipment maintenance, flow

rate calculations, chain of custody records and sampling logs shall be available for District

review. If documentation is not onsite, the permittee shall produce the required documentation

within 7 days of request by the District. The instruments shall be maintained according to

manufacturer's specifications.

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5. Recordkeeping. The permittee shall record and maintain the following information. This data

shall be maintained for a minimum of three (3) years from the date of each entry and made

available to the District upon request:

a. A copy of the manufacturer- or permittee-designed operations procedures for the process

monitoring and control equipment and a copy of the District-approved EVT Plan. These

records shall be maintained for the life of the project.

b. Weekly PID sampling results from “carbon in”, “carbon mid”, and “carbon out” sampling

ports. A District-approved log shall be maintained (tabular format) that contains the

following information on an ongoing basis: site location, permit number, monitoring date,

PID concentration results at the three monitoring points in units of ppmv, stack exhaust

flow rate in units of scfm 1, the calculated system control efficiency, whether the unit was

in compliance (Y/N).

c. Monthly ROC, Benzene, Toluene, Ethylbenzene and all other VOC laboratory sampling

results for the control device influent and effluent vapor in units of ppmv and lbs/hr as well

as the calculated ROC control efficiency (mass basis). A District-approved log shall be

maintained (tabular format) that contains the following information on an ongoing basis:

site location, permit number, sampling date, ROC concentration results at the inlet and

outlet of the control system in units of ppmv, stack exhaust flow rate in units of scfm, stack

exhaust temperature, the mass emissions at the inlet and exhaust to the atmosphere of ROC,

Benzene, Toluene, Ethylbenzene and all other VOC’s in units of lb/hr, the calculated

system control efficiency for ROC, whether the unit was in compliance (Y/N). The

sampling results data shall be maintained using a District-approved tabular format that

documents the monthly results on an ongoing basis. All lab reports, including chain of

custody documentation, shall be maintained.

d. Actions taken to remedy non-compliance based on weekly PID sampling (efficiency) and

monthly lab analysis tests (ppmv, lb/hr, efficiency). These actions shall be documented in a

District-approved CSC Non-Compliance Reporting Form.

6. Reporting. By March 1 of each year or completion of the project, a written report documenting

compliance with the terms and conditions of this permit for the previous calendar year shall be

provided by the permittee to the District (Attn: Annual Report Coordinator). The report shall

contain information necessary to verify compliance with the emission limits and other

requirements of this permit. The report shall be in a format approved by the District.

Compliance with all limitations and restrictions shall be documented in the submittals. All logs

and other basic source data not included in the report shall be made available to the District upon

request. The report shall include the following information:

1 Also include relevant process data if this value was calculated (e.g., pressure, temperature)

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a. Results from weekly PID sampling from “carbon in”, “carbon mid”, and “carbon out”

sampling ports. Include the District-approved reporting log.

b. Results of monthly sampling lab analyses. Include the District-approved reporting log.

c. Copies of all CSC Non-Compliance Reporting Forms that documented the actions taken to

remedy non-compliance based on weekly PID sampling and monthly lab analysis tests.

7. Source Compliance Demonstration Period. The equipment covered by this permit shall be

allowed to temporarily operate for 60 calendar days after initial operations (subject to the

requirements of this condition). This time period is termed the "Source Compliance

Demonstration Period" (SCDP). During the SCDP, the permit holder is not considered in

violation of this permit if the emission limits stated in this permit are exceeded while testing

and/or debugging the system. However, enforcement action may be taken against operations that

result in a violation of any emission limit stipulated by a prohibitory rule in the District’s Rules

and Regulations.

The permit holder is responsible for ensuring the following actions are taken during the SCDP:

a. Provide written notification to the District (Attn: CSC Project Manager), prior to initial

operations under the SCDP, of the startup date of the equipment permitted herein. Initial

operations are defined as the first day vapors are introduced into the carbon canisters.

b. Initiate all required monitoring and recordkeeping as required under this permit.

c. Conduct daily PID sampling for the duration of one (1) week. After a week of daily

samples, weekly PID sampling shall be taken as stated in the Monitoring and

Recordkeeping conditions of this permit. Samples shall be taken from “carbon in”,

“carbon mid”, and “carbon out” sampling ports.

d. Arrange for District inspection not more than thirty (30) calendar days (or other mutually

agreed to time period) after the SCDP begins. A minimum of three calendar days

advance notice shall be given to the District. This inspection is required to verify that the

equipment and its operation are in compliance with District Rules and Permit Conditions;

e. Conduct an Emissions Verification Test and submit results of the test to the District. The

District shall be notified by e-mail ([email protected]) at least ten (10) calendar

days prior to the start of EVT to arrange for a mutually agreeable EVT date when a

District representative may observe the EVT.

f. Submit a complete application for a Permit to Operate. All records required by the

Recordkeeping condition and a copy of the EVT Report shall be submitted to the District

as an attachment to the Permit to Operate application (District Form -01). Facility

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operations beyond the SCDP without a PTO are considered a violation of District

Rule 201.

If items (a) through (f) of this condition are not satisfied within sixty (60) calendar days of the

initiation of the SCDP, the SCDP shall terminate and the operation of any equipment covered

by this permit will be considered a violation of District rules and regulations. If the District has

determined that the application for the Permit to Operate is complete, the SCDP shall remain

valid until the District issues (or denies) the Permit to Operate. The SCDP may be extended at

either the District’s discretion or at the request of the permittee provided such a request is

submitted, in writing (Attn: CSC Project Manager) to the District two weeks prior to the end of

the SCDP and sufficient justification is provided.

8. Emission Verification Test and Report. Within the first 14 calendar days after the

commencement of each phase of equipment operation, the permittee shall conduct system testing

for a 3-hour time period. This testing is termed the "Emission Verification Test". The EVT shall

be consistent in content and format with guidelines contained in the "Guidance Document” and

the District-approved EVT Plan for this permit. The permittee shall obtain written District

approval of the EVT plan prior to performing the EVT. The District shall be notified at least ten

(10) calendar days prior to the start of EVT to arrange for a mutually agreeable EVT date when a

District representative may observe the EVT. The District, at its discretion, may participate in the

sampling of the influent and effluent gases as well as the monitoring of other system parameters.

Test results shall be prepared and presented in the EVT Report, consistent in form and content

with the Guidance Document and the District-approved EVT Plan submitted with the ATC

application. Data shall be compiled using the tables provided in the Guidance Document (or

equivalent). The EVT Report for each phase of equipment operation shall contain results of all

testing and field monitoring performed to date. The EVT Report shall be received by the District

within 10 days after test completion if continued equipment operations are desired. The permittee

shall clearly state in the Executive Summary of the report whether or not the facility is in

compliance with all permit and rule requirements.

If the EVT does not demonstrate compliance, operations may continue for no more than thirty

days after the test date provided that time is used for testing, process debugging, or other

activities required to bring the facility into compliance with the requirements of the permit

(including providing documentation of compliance). During the 30-day period, the permit holder

is not considered in violation of this permit if the emission limits stated in this permit are

exceeded or the required control efficiency is not met due to testing and/or process debugging

operations. However, enforcement action may be taken against operations which result in a

violation of any emission limit stipulated by a prohibitory rule in the District's Rules and

Regulations. The permittee shall notify the District via e-mail (e-mail: [email protected],

Attn: CSC Project Manager) within 24 hours of discovery of being out of compliance with the

requirements of this permit.

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If the results of the EVT(s) indicate discrepancies in the data, specifications, or assumptions

included with the application (and supplements thereof) or the District’s Permit Evaluation under

which this permit is issued, then the project may be subjected to reevaluation and require the

permittee to apply for a permit modification or perform additional EVT(s).

9. IC Engines. Any internal combustion engine with a rated brake horsepower of 50 or greater

which is used on-site (i.e. drill rig engines) must have a valid District Permit to Operate, or must

be registered in the Statewide Portable Equipment Registration Program. Engines used to propel

vehicles do not require a permit.

10. Consistency with Analysis. Operation under this permit shall be conducted consistent with all

data, specifications and assumptions included with the application and supplements thereof (as

documented in the District's project file) and the District's analyses under which this permit is

issued as documented in the Permit Analyses prepared for and issued with the permit.

11. Equipment Maintenance. The equipment listed in this permit shall be properly maintained and

kept in good condition at all times. The equipment manufacturer’s maintenance manual,

maintenance procedures and/or maintenance checklists (if any) shall be kept on site.

12. Compliance. Nothing contained within this permit shall be construed as allowing the violation

of any local, state or federal rules, regulations, air quality standards or increments.

13. Severability. In the event that any condition herein is determined to be invalid, all other

conditions shall remain in force.

14. Conflict Between Permits. The requirements or limits that are more protective of air quality

shall apply if any conflict arises between the requirements and limits of this permit and any other

permitting actions associated with the equipment permitted herein.

15. Access to Records and Facilities. As to any condition that requires for its effective enforcement

the inspection of records or facilities by the District or its agents, the permittee shall make such

records available or provide access to such facilities upon notice from the District. Access shall

mean access consistent with California Health and Safety Code Section 41510 and Clean Air Act

Section 114A.

16. Emission Factor Revisions. The District may update the emission factors for any calculation

based on USEPA AP-42 or District emission factors at the next permit modification or permit

reevaluation to account for USEPA and/or District revisions to the underlying emission factors.

17. Reimbursement of Costs. All reasonable expenses, as defined in District Rule 210, incurred by

the District, District contractors, and legal counsel for the activities listed below that follow the

issuance of this permit, including but not limited to permit condition implementation, compliance

verification and emergency response, directly and necessarily related to enforcement of the

permit shall be reimbursed by the permittee as required by Rule 210. Reimbursable activities

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include work involving: permitting, compliance, CEMS, modeling/AQIA, ambient air

monitoring and air toxics.

18. Nuisance. Except as otherwise provided in Section 41705 of the California H&SC, no person

shall discharge from any source whatsoever such quantities of air contaminants or other material

which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or

to the public, or which endanger the comfort, repose, health, or safety of any such persons or the

public, or which cause, or have a natural tendency to cause, injury or damage to business or

property.

19. Grounds for Revocation. Failure to abide by and faithfully comply with this permit or any Rule,

Order, or Regulation may constitute grounds for revocation pursuant to California Health &

Safety Code Section 42307 et seq.

20. Transfer of Owner/Operator. This permit is only valid for the owner and operator listed on this

permit unless a Transfer of Owner/Operator application has been applied for and received by the

District. Any transfer of ownership or change in operator shall be done in a manner as specified

in District Rule 203. District Form –01T and the appropriate filing fee shall be submitted to the

District within 30 days of the transfer.

Air Pollution Control Officer

Date

Attachments:

- Permit Evaluation for Authority to Construct 14542

Notes: - This permit is valid for one year from the date stamped above if unused.

- Stationary sources are subject to an annual emission fee (see Fee Schedule B-3 of Rule 210).

- Annual reports are due by March 1st of each year. - CSC monthly monitoring form ENF-89 and CSC Non-Compliance Reporting Form ENF-88 are available

on the District website here: www.ourair.org/eng/compliance/csc/csc.htm. \\Nt\shares\Groups\ENGR\WP\CSC\ATC\ATC 14542\ATC 14542 - Draft Permit - 8-12-2015.doc

http://www.ourair.org/eng/compliance/csc/csc.htm

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PERMIT EVALUATION FOR

AUTHORITY TO CONSTRUCT 14542

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1.0 BACKGROUND

1.1 General: Donan Environmental Services, Inc. is installing in-situ remediation equipment for the

treatment of VOC-containing soil from a former gasoline and diesel fueling station which supported

agricultural equipment at 1851 W. Olive Street in Lompoc. The operation will consist of seven (7)

vapor extraction wells controlled by two carbon adsorption canisters in series. A duel phase

extraction (DPE) pilot test was conducted at the site from June 22 to June 29, 2015. The Authority

to Construct application was received on November 24, 2014 and deemed complete following the

submittal of the pilot test report on August 10, 2015.

1.2 Permit History:

PERMIT FINAL ISSUED PERMIT DESCRIPTION

Exempt 14642 05/22/2015 15 day pilot test using carbon canister controls.

1.3 Compliance History: The permitted equipment has no compliance history.

2.0 ENGINEERING ANALYSIS

2.1 Equipment/Processes: The contaminated soil will be remediated using two carbon adsorption

canisters in series. The vapor extraction system transfers the vapors to the carbon adsorption

canisters. The exhaust flow rate is based on the rated capacity of the vapor extraction blower. The

emission of the effluent was calculated from the exhaust flow rate.

2.2 Emission Controls: Carbon adsorption canisters with an effluent Benzene concentration ≤ 0.30

ppmv and effluent Benzene emission rate ≤ 0.0223 lb/day.

2.3 Emission Factors: Emissions are based on engineering calculations using inlet concentration data,

flow rates and emission control efficiencies.

2.4 Reasonable Worst Case Emission Scenario: The emission operations scenario for this project is

24 hr/day, 365 days/year.

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2.5 Emission Calculations: Emissions were calculated using influent concentrations, flow rates,

supplemental fuel use and assumed control efficiencies. Detailed emission calculation spreadsheets

may be found in the Emission Calculations Attachment. These emissions define the Potential to

Emit for the permitted equipment.

2.6 Special Calculations: The concentration of the effluent was calculated from the system exhaust

flow rate. See the Emission Calculations Attachment for details.

2.7 BACT Analyses: Best Available Control Technology was not required for this project.

2.8 Enforceable Operational Limits: The permit has enforceable operating conditions that ensure the

equipment is operated properly.

2.9 Monitoring Requirements: Monitoring of the equipment’s operational limits are required to ensure

that these are enforceable.

2.10 Recordkeeping and Reporting Requirements: The permit requires that the data which is monitored

be recorded and reported to the District.

3.0 REEVALUATION REVIEW (not applicable)

4.0 REGULATORY REVIEW

4.1 Partial List of Applicable Rules:

Rule 201. Permits Required

Rule 202. Exemptions to Rule 201

Rule 205. Standards for Granting Permits

Rule 301. Circumvention

Rule 302. Visible Emissions

Rule 303. Nuisance

Rule 801. New Source Review

Rule 802. Nonattainment Review

Rule 803. Prevention of Significant Deterioration

4.2 Rules Requiring Review:

4.2.1 Rule 345 - Control of Fugitive Dust from Construction and Demolition Activities: This rule

requires fugitive dust control for any activity associated with construction or demolition of a

structure or structures. The soil vapor extraction activities allowed by this permit do not

constitute construction or demolition, and are therefore not subject to the requirements of this

rule. Any construction or demolition of structures (including but not limited to grading,

excavating or paving) is subject to the requirements and standards of this rule.

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4.3 NEI Calculations: The net emission increase calculation is used to determine whether certain

requirements must be applied to a project (e.g., offsets, AQIA, PSD BACT). The NEI for the

stationary source is equal to the permitted emissions.

5.0 AQIA

The project is not subject to the Air Quality Impact Analysis requirements of Regulation VIII.

6.0 OFFSETS/ERCs

6.1 Offsets: The emission offset thresholds of Regulation VIII are not exceeded.

6.2 ERCs: This source does not generate emission reduction credits.

7.0 AIR TOXICS

Health risk assessments (HRA) are done for all contaminated soil remediation projects. The HRA

showed an estimated excess cancer risk of 4.38 in a million which is below the District adopted

significance threshold for excess cancer risk of 10 in a million was not exceeded. Further

discussion and calculations may be found in the HRA Documentation Attachment.

8.0 CEQA / LEAD AGENCY

The District is the lead agency under CEQA for this project, and has prepared a Notice of

Exemption. This project is exempt from CEQA pursuant to the Environmental Review Guidelines

for the Santa Barbara County District (revised April 30, 2015). Appendix A (District Projects

Exempt from CEQA and Equipment or Operations Exempt from CEQA) provides an exemption

specifically for onsite remediation of contaminated groundwater or soil using vapor extraction and

treatment or water extraction and treatment. No further action is necessary.

9.0 SCHOOL NOTIFICATION

A school notice pursuant to the requirements of H&SC §42301.6 is required. The impacted K-12

school is Miguelito Elementary School.

10.0 PUBLIC and AGENCY NOTFICATION PROCESS/COMMENTS ON DRAFT PERMIT

10.1 This project is subject to public notice.

10.2 Draft comments, if any, may be found in the appendix.

11.0 FEE DETERMINATION

Fees for this permit are assessed under the cost reimbursement provisions of Rule 210. The Project

Code is 205680 (CSC 1851 Olive Ave/Donan Env).

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12.0 RECOMMENDATION

It is recommended that this permit be granted with the conditions as specified in the permit.

William Sarraf 9/29/2015

AQ Engineer/Technician Date Supervisor Date

13.0 ATTACHMENT(S)

Emission Calculations

HRA Documentation

IDS Tables

Draft Comments

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ATTACHMENT

Emission Calculations CALCULATION SUMMARY FOR PROJECT TOTAL ROC AND TOXIC EMISSIONS

ATC 14542, Contaminated Soil Remediation Project at 1851 W. Olive Street

1. Maximum Project ROC Emissions

C6H14

Molecular

Wt

Control Efficiency

(lb/lb-mol) (%)

Carbon Canisters Ph III 86.17 90

2. Maximum Projected Toxics Emissions

Phase I - Thermal Oxidizer Toxic Emissions

Toxic Molecular

Wt

Flow Rate Control

Efficiency

Total Effluent Concentration

from Control Device

(lb/lb-mol) (scfm) (%) (ppm)

Toluene 92.1 250 90 0.10

Benzene 78.1 250 90 0.30

EthylBenzene 106.2 250 90 0.10 0.0101 0.00181 0.0042 0.0004

ROC Effluent from

Control Device

ROC Effluent

Concentration from

Control Device

(ppm as C6H14)

ROC Effluent from

Control Device

ROC Effluent from

Control Device

Source Total ROC Influent into Control

Device

System Flow Rate ROC Influent into

Control Device

lb/day

Total Effluent from

Control Device

11.4590

(ppm as C6H14) (cfm) (lbs/hr) (lb/hr)

Total Effluent from

Control Device

Total Effluent from

Control Device

TPY

1400 250 4.7746 0.4775 140.0 2.0913

1

3

0.0036 0.0004

Control Device

Influent

Concentration

(ppmv)

Total Influent into

Control Device

(lbs/hr) (lbs/hr) TPY

0.0016

0.0093 0.0009 0.0223 0.0041

0.0088

lb/day

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ATTACHMENT

HRA Documentation

Santa Barbara County District Health Risk Assessment

Company: Donan Environmental Services, Inc Facility: 1851 W. Olive Ave Permit Type: Authority to Construct Permit No: 14542 FID No: 11516 SSID No: 11258

I. Background

The District Board of Directors has chosen a significance threshold of ten in a million (10 x 10-6) for

excess cancer risk that must not be exceeded. Health risk assessments are done for all contaminated soil

remediation projects through computer modeling. The EPA-approved dispersion model Screen3 was

used to determine the maximum ambient air pollutant concentration under different meteorological

conditions. The Office of Environmental Health Hazard Assessment (OEHHA) and the Air Resources

Board (ARB) risk assessment health values were used as the basis for making the initial screening risk

assessment for cancer risk and acute and chronic non-cancer effects. The source type chosen for

consideration by the Screen3 model is a point source due to the nature of the exhaust stack. The Screen3

model was run using a standardized emission rate of 1.0 g/s. Actual pollutant specific impacts were

determined based on the ratio of their mass emissions (in g/s) to the modeled Screen3 result. The model

was run to predict the cumulative cancer risk from toluene, ethylbenzene and benzene.

Section VI contains a link to more information on health risk assessments.

II. Input Data

The input data used for this health risk assessment includes:

Stack dimensions (height, length and width).

Stack exit velocity and stack gas exit temperature.

Nearby building information was not included in the application. All nearby building dimensions

were entered as zero.

Emissions rates of benzene, ethylbenzene and toluene.

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ATTACHMENT

HRA Documentation

III. Calculations

R = [Xa] x [ET / ES] x 0.1 x [UR]

Where,

R = Individual excess lifetime cancer risk

Xa = Max 1 hour concentration from Screen3 model results (µg/m3)

ET = Actual toxic emission rate from source stack (g/sec)

ES = Default Screen3 emission rate (established at 1 g/sec)

UR = Unit Risk Value

Phase II (Catalytic Oxidizer)

IV. Results

The maximum ground level concentration predicted by the SCREEN3 model is 12,869 µg/m3 for Phase

III (at the standardized 1.0 g/s emission rate). The results of the analysis showed a combined cancer risk

of 4.38 x 10-6.

V. Conclusion

The District’s significant risk cancer threshold of ten in a million was not exceeded. Therefore, this ATC

application passes the health risk assessment.

VI. Reference

CARB HRA Information: http://www.arb.ca.gov/ab2588/riskassess.htm

Xa ET Es UR R

ug/m3 g/sec g/sec per million

Toluene 12869 0.00005 1 2.6E-07 0.02

Benzene 12869 0.00012 1 2.9E-05 4.36

EthylBenzene 12869 0.00005 1 2.1E-05 1.43

Total 4.38

http://www.arb.ca.gov/ab2588/riskassess.htm

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ATTACHMENT

HRA Documentation

VII. Attachment Screen3 Output Data File

08/25/15

09:16:12

*** SCREEN3 MODEL RUN ***

*** VERSION DATED 96043 ***

ATC 14542 – W. Olive Street

SIMPLE TERRAIN INPUTS:

SOURCE TYPE = POINT

EMISSION RATE (G/S) = 1.00000

STACK HEIGHT (M) = 3.9624

STK INSIDE DIAM (M) = 0.4826

STK EXIT VELOCITY (M/S)= 0.6451

STK GAS EXIT TEMP (K) = 288.7056

AMBIENT AIR TEMP (K) = 293.1500

RECEPTOR HEIGHT (M) = 0.0000

URBAN/RURAL OPTION = URBAN

BUILDING HEIGHT (M) = 0.0000

MIN HORIZ BLDG DIM (M) = 0.0000

MAX HORIZ BLDG DIM (M) = 0.0000

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED.

THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED.

TA > TS!!! BUOY. FLUX SET = 0.0

BUOY. FLUX = 0.000 M**4/S**3; MOM. FLUX = 0.024 M**4/S**2.

*** FULL METEOROLOGY ***

**********************************

*** SCREEN AUTOMATED DISTANCES ***

**********************************

*** TERRAIN HEIGHT OF 0. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES

***

DRAFT


ATTACHMENT

HRA Documentation

DIST CONC U10M USTK MIX HT PLUME SIGMA SIGMA

(M) (UG/M**3) STAB (M/S) (M/S) (M) HT (M) Y (M) Z (M) DWASH

------- ---------- ---- ----- ----- ------ ------ ------ ------ -----

1. 0.000 1 1.0 1.0 320.0 4.07 0.33 0.25 NO

100. 3406. 5 1.0 1.0 10000.0 4.07 10.79 7.46 NO

200. 1027. 5 1.0 1.0 10000.0 4.07 21.17 14.04 NO

300. 501.5 5 1.0 1.0 10000.0 4.07 31.18 19.93 NO

400. 304.0 5 1.0 1.0 10000.0 4.07 40.85 25.30 NO

500. 207.8 5 1.0 1.0 10000.0 4.07 50.21 30.24 NO

600. 153.2 5 1.0 1.0 10000.0 4.07 59.27 34.82 NO

700. 118.9 5 1.0 1.0 10000.0 4.07 68.06 39.11 NO

800. 95.88 5 1.0 1.0 10000.0 4.07 76.59 43.15 NO

900. 79.53 5 1.0 1.0 10000.0 4.07 84.89 46.97 NO

1000. 67.45 5 1.0 1.0 10000.0 4.07 92.97 50.60 NO

1100. 58.23 5 1.0 1.0 10000.0 4.07 100.83 54.06 NO

1200. 51.01 5 1.0 1.0 10000.0 4.07 108.50 57.37 NO

1300. 45.22 5 1.0 1.0 10000.0 4.07 115.99 60.55 NO

1400. 40.50 5 1.0 1.0 10000.0 4.07 123.30 63.61 NO

1500. 36.59 5 1.0 1.0 10000.0 4.07 130.44 66.56 NO

1600. 33.31 5 1.0 1.0 10000.0 4.07 137.43 69.42 NO

1700. 30.52 5 1.0 1.0 10000.0 4.07 144.27 72.18 NO

1800. 28.12 5 1.0 1.0 10000.0 4.07 150.97 74.86 NO

1900. 26.05 5 1.0 1.0 10000.0 4.07 157.54 77.47 NO

2000. 24.23 5 1.0 1.0 10000.0 4.07 163.98 80.00 NO

2100. 22.64 5 1.0 1.0 10000.0 4.07 170.30 82.47 NO

2200. 21.22 5 1.0 1.0 10000.0 4.07 176.50 84.88 NO

2300. 19.96 5 1.0 1.0 10000.0 4.07 182.59 87.22 NO

2400. 18.84 5 1.0 1.0 10000.0 4.07 188.57 89.52 NO

2500. 17.82 5 1.0 1.0 10000.0 4.07 194.45 91.77 NO

2600. 16.90 5 1.0 1.0 10000.0 4.07 200.24 93.97 NO

2700. 16.07 5 1.0 1.0 10000.0 4.07 205.93 96.12 NO

2800. 15.31 5 1.0 1.0 10000.0 4.07 211.54 98.23 NO

2900. 14.61 5 1.0 1.0 10000.0 4.07 217.05 100.30 NO

3000. 13.97 5 1.0 1.0 10000.0 4.07 222.49 102.34 NO

3500. 11.43 5 1.0 1.0 10000.0 4.07 248.52 112.00 NO

4000. 9.639 5 1.0 1.0 10000.0 4.07 272.88 120.95 NO

4500. 8.317 5 1.0 1.0 10000.0 4.07 295.82 129.32 NO

5000. 7.303 5 1.0 1.0 10000.0 4.07 317.54 137.20 NO

5500. 6.503 5 1.0 1.0 10000.0 4.07 338.21 144.67 NO

6000. 5.857 5 1.0 1.0 10000.0 4.07 357.94 151.79 NO

6500. 5.324 5 1.0 1.0 10000.0 4.07 376.84 158.60 NO

7000. 4.878 5 1.0 1.0 10000.0 4.07 395.00 165.14 NO

DRAFT


ATTACHMENT

HRA Documentation

7500. 4.500 5 1.0 1.0 10000.0 4.07 412.50 171.43 NO

8000. 4.175 5 1.0 1.0 10000.0 4.07 429.40 177.50 NO

8500. 3.893 5 1.0 1.0 10000.0 4.07 445.74 183.38 NO

9000. 3.646 5 1.0 1.0 10000.0 4.07 461.59 189.08 NO

9500. 3.428 5 1.0 1.0 10000.0 4.07 476.98 194.62 NO

10000. 3.235 5 1.0 1.0 10000.0 4.07 491.94 200.00 NO

15000. 2.062 5 1.0 1.0 10000.0 4.07 623.64 247.54 NO

20000. 1.510 5 1.0 1.0 10000.0 4.07 733.33 287.37 NO

25000. 1.191 5 1.0 1.0 10000.0 4.07 829.16 322.33 NO

30000. 0.9828 5 1.0 1.0 10000.0 4.07 915.26 353.86 NO

40000. 0.8032 4 1.0 1.0 320.0 4.07 1552.23 1553.16 NO

50000. 0.7141 4 1.0 1.0 320.0 4.07 1745.74 1750.00 NO

MAXIMUM 1-HR CONCENTRATION AT OR BEYOND 1. M:

14. 0.1287E+05 3 1.0 1.0 320.0 4.07 3.30 3.01 NO

DWASH= MEANS NO CALC MADE (CONC = 0.0)

DRAFT


ATTACHMENT

IDS Tables

Page 1 of 1

PERMIT POTENTIAL TO EMIT NOx ROC C0O SOx PM PM10

lb/day 11.46

lb/hr

TPQ

TPY 2.09

FACILITY POTENTIAL TO EMIT NOx ROC CO SOx PM PM10

lb/day 11.46

lb/hr

TPQ

TPY 2.09

FACILITY NEI90 NOx ROC CO SOx PM PM10

lb/day 11.46

lb/hr

TPQ

TPY 2.09

Notes:

(1) Emissions in these tables are from IDS.

(2) Because of rounding, values in these tables shown as 0.00 are less than 0.005, but greater than zero.

DRAFT


ATTACHMENT

Comments on Draft Permit

Page 1 of 1

ecd general permit framework - ourair.org

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