December 07, 2006

To:Interested Parties

From:Bay Area Air Quality Management District

Subject:Emissions Inventory Report for Pacific Steel Casting Company

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1.Background

The Bay Area Air Quality Management District (District) has required Pacific Steel Casting Company (PSC) to prepare a Health Risk Assessment (HRA) to meet requirements of the Air Toxics Hot Spots (ATHS) program. PSC recently submitted a document entitled: “Emissions Inventory Report: Pacific Steel Casting Company, 1333 Second Street, Berkeley, California,” November 16, 2006 (EIR). This document contains descriptions and estimates of the toxic air contaminant emissions from PSC that are proposed for use in the HRA. The District is conducting a comprehensive review of this report in order to determine its adequacy. Concurrent with this review, the District is providing the Emissions Inventory Report (Public Copy), together with the approved source test reports, for public review and comment. It should be noted that the Public Copy of the Emissions Inventory Report does not contain information that PSC claims is protected from disclosure under Trade Secret/Confidential Information provisions of State law.

The District will accept comments on the Emissions Inventory Report until December 31, 2006. Comments should be submitted in writing to Scott Lutz, Manager of Toxic Evaluation Section at the District, at the following address, or by e-mail at :

Mr. Scott Lutz

Bay Area Air Quality Management District

939 Ellis Street

San Francisco, CA 94109

An overview of the ATHS program, and further information regarding the HRA that is being prepared to meet the requirements of the ATHS program for PSC, follows.

2.Air Toxics Hot Spots Program Overview

The Air Toxics "Hot Spots" Information and Assessment Act (also known as AB 2588, 1987, Connelly) established a formal regulatory program for site-specific air toxics emissions inventory and health risk quantification that is managed by California air districts. Under this program, a wide variety of industrial, commercial, and public facilities are required to report the types andquantities of toxic substances their facilities routinely release into the air. The goals of the ATHS program are to collect emissions data, to identify facilities having potential for localized health impacts, to ascertain health risks, to notify nearby residents of risks that are determined to warrant such notification, and to reduce significant risks.

There are five steps to implementing the ATHS program. Guidelines have been developed for all five steps to establish a consistent, science-based, methodology for implementing the program. The five steps are briefly described as follows.

  • Air Toxics Emissions Inventory. Subject facilities are required to prepare and submit a comprehensive emissions inventory plan followed by a toxics emissions inventory report. Each facility’s emissions inventory must be updated on a regular basis (e.g., to reflect changes in equipment, materials, and production levels at the facility).
  • Prioritization. Each facility is prioritized for potentially significant health impacts based on the quantity and toxicity of emissions, and the proximity of nearby residents and workers.
  • Health Risk Assessment. Facilities that are determined to be “high priority” are required to prepare and submit a comprehensive HRA. This is generally preceded by an HRA protocol that describes the HRA methodology including identification of key inputs and assumptions. The HRA is reviewed by the air district and Cal/EPA’s Office of Environmental Health Hazard Assessment (OEHHA).
  • Notification. If the health risks resulting from the facility’s emissions exceed action levels established by the air district, the facility is required to perform notification to all exposed persons regarding the results of the HRA.
  • Risk Reduction. If the health risks resulting from the facility’s emissions exceed significance levels established by the air district, the facility is required to conduct an airborne toxic risk reduction audit and develop a plan to implement measures that will reduce emissions from the facility to a level below the significance level within five years.

3.Pacific Steel Casting Company: Health Risk Assessment

In 2005, based on their most recently reported production levels, the District re-prioritized the Pacific Steel Casting facility under the ATHS program, and determined that the requirement to prepare an HRA had been triggered. Accordingly, the District notified PSC of this requirement, and established a schedule for submittal of an HRA, and several preceding documents. The District and PSC agreed that a comprehensive supplemental source-testing program should be part of the HRA process, in order to update and refine the emissions estimates that would be used in the HRA. The schedule established by the District for completion of the HRA (including District-approved extensions to the schedule) is as follows.

HRA protocol:Aug. 26, 2005

Source test plan and protocol:Sep. 15, 2005

Updated emissions inventory report: May 19, 2006

HRA:Jun. 30, 2006

PSC submitted a proposed updated emissions inventory report on September 5, 2006. However, the District determined that this report was incomplete because not all of the source test results used to establish emissions from the facility had been submitted for District review. PSC subsequently provided this information and submitted a revised emissions inventory report on Nov. 16, 2006. The District is reviewing this report for technical adequacy. The approved source test reports are enclosed with the EIR for public review and comment. The District expects PSC to submit the HRA report within six weeks of the District’s completion of the EIR review.

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