FROM: Robert Thompson, General Manager
Originator: Lan C. Wiborg, Director of Environmental Services
SUBJECT:
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CASA STATEWIDE POOLED EMISSIONS STUDY
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GENERAL MANAGER'S RECOMMENDATION
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RECOMMENDATION:
A. Approve the Memorandum of Agreement (MOA) between Orange County Sanitation District and California Association of Sanitation Agencies for CY 2025-2029 to complete the Statewide Wastewater Air Toxics Pooled Emissions Study (Study); and
B. Approve funding for a total amount not to exceed $800,000.
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BACKGROUND
As a Title V facility, Orange County Sanitation District (OC San) is subject to stringent reporting requirements for both criteria air pollutants and toxic air emissions. The California State Air Toxics "Hot Spots" Information and Assessment Act of 1987 (AB 2588) established a regulatory framework to track and assess emissions of over 400 toxic air contaminants across various facilities. In response, a Pooled Emissions Estimation Program study was developed by 25 wastewater agencies, including OC San, to identify and quantify air toxic emissions associated with wastewater treatment processes. The success of this study led SCAQMD to approve a shortlist of 20 toxic substances, which continues to serve as the basis for permitting assessments and compliance with AB 2588 reporting requirements.
In 2022, CARB updated the Emission Inventory Criteria and Guidelines (EICG) and the Reporting of Criteria Air Pollutants and Toxic Air Contaminants Regulations, expanding the scope of reportable air toxics to over 1,700 substances. To comply with these new requirements, wastewater agencies, including OC San, must complete a two-step emissions evaluation process by 2028:
* Step 1: Conduct an emissions scan across various wastewater treatment processes to identify detectable air toxic compounds; and
* Step 2: Quantify the detectable air toxic compounds identified in Step 1.
To enhance compliance across 114 wast...
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