Initial Concepts for Proposed Regulation XXXV

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Initial Concepts forProposed Regulation XXXV

• Public WorkshopMarch 8, 2005

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Background

• Diesel particulate identified as a Toxic Air
  Contaminant (TAC) since 1998
• Long-term exposure to diesel particulate poses
  highest cancer risk of any TAC evaluated by OEHHA
• ARB conducted JR Davis Railyard study in
  Roseville
• High cancer risks (500 in a million)
• Idling represented 45 of diesel particulate
  emissions
• Locomotives are significant sources of criteria
  pollutants

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Purpose of Workshop

• Initiate parallel process to Working Group
  Meetings
• Update on Working Group discussions
• Preliminary concepts based on input received (not
  yet reviewed by working group members)
• Future Public Workshops/Consultation Meetings
  planned

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Objective of Proposed Reg XXXV

• Monitor and record locomotive idling
• Minimize locomotive idling
• Conduct emissions inventory and health risk
  assessment at major railyards in the district
• Reduce the cancer and non-cancer risk from all
  emission sources at major railyards in the
  district

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Proposed Rules

• PR 3500 - General
• PR 3501 - Recordkeeping For Locomotive Idling
• PR 3502 - Minimization of Long Duration Idling
• PR 3503 - Emissions Inventory and
  Risk Assessment For Railyards
• PR 3504 - Railyard Risk Reduction

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Applicability

• Diesel Locomotives
• Operated in the district
• Class I freight railroads
• Switching and terminal freight railroads
• Four railroads meet applicability
• Railyards
• Major railyards in the district
• Operated by Class I and switching and terminal
  freight railroads
• 7-9 railyards

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PR 3500 - General

• Definitions terms used in Reg XXXV
• Key definitions
• Locomotive is a diesel locomotive
• Idling Event is a locomotive that idles more
  than 15 minutes
• Long Duration Idling Event is a locomotive that
  idles more than 30 minutes

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PR 3501-RecordkeepingPurpose and Applicability

• Purpose to record idling events to identify
  opportunities to reduce emissions
• Applicability
• Any diesel locomotive operated in the district by
  Class I or switching and terminal freight
  railroad
• Locomotives with anti-idling device (lt15 min)
  exempt

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PR 3501-Recordkeeping Idling Monitoring and
Recording Plan

• Operator of locomotive describes the method
  and/or devices of their choice to record each
  idling event
• Must submit on or before 3 months after rule
  adoption
• One-time submittal

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PR 3501-RecordkeepingRecordkeeping Requirements

• Record following information for each idling
  event (idling gt15 minutes)
• Name and owner of locomotive
• Identification of locomotive
• Idling event information such as location, time
  and date and duration of idling
• Begin recordkeeping 30 days from approval of
  Idling Monitoring and Recording Plan

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PR 3501-RecordkeepingReporting Requirements

• Weekly Report
• Identification of all Idling Events
• Explanation for all Long Duration Idling Event
• Annual Report
• Locomotive engine information
• List of locomotive equipped with anti-idling
  devices

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PR 3502 Minimization of Long Duration Idling

• Purpose is to reduce emissions from long duration
  idling events
• Beginning January 1, 2006, no locomotive is
  allowed to idle more than 30 minutes unless
• Being used as emergency vehicle
• Idling by mechanic for maintenance and diagostics
• Pre-empted by federal law
• Approved Alternative Compliance Plan (i.e.
  equivalent emission reductions)

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PR 3503 Emissions Inventory and Health Risk
Assessment (HRA)

• Purpose
• Determine criteria pollutant and toxic emissions
  from railyards
• Conduct health risk assessments to estimate the
  cancer risk, chronic and acute hazard indices,
  and cancer burden at railyards
• Applies to major railyards operated by Class I
  railroads and switching and terminal railroads in
  the district

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PR 3503 Inventory and HRAEmissions Inventory
Requirements

• Emissions inventory for all sources at railyard
• stationary sources such as combustion equipment,
  processes, storage tanks, fueling stations, etc.
• on- and off-road mobile sources such as trucks,
  motor vehicles, locomotives, yard equipment, etc.
• Criteria pollutants (VOC, NOx, SOx, CO, and PM10)
• Toxic air contaminants

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PR 3503 Inventory and HRA Health Risk
Assessment

• Health Risk Assessment for railyard
• Maximum Individual Cancer Risk (MICR)
• Hazard Index for acute and chronic risks
• Updates
• Emission inventory annually
• Health Risk Assessment if emissions increase
• Public notification requirement
• Cancer risk gt10 in-a-million

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PR 3504 Risk ReductionPurpose and Applicability

• Purpose is to reduce health risks from railyard
  operations
• Applies to major railyards with approved HRA
  above Action Risk Level
• Cancer risk of 25 in-a-million
• Acute or chronic hazard index of 3.0
• Cancer burden of 0.5

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PR 3504 Risk ReductionRisk Reduction Plan

• Operator of locomotive identifies risk reduction
  measures to reduce risk below Action Risk Level
• 3 years to implement Risk Reduction Plan
• 2 year extensions incrementally, provided meet
  specific criteria
• Reduction measures exempt if preempted by federal
  law
• Submit 180 days of approved Health Risk
  Assessment
• Annual progress report

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PR 3504 Risk ReductionCommunity Air Emissions
Action Plan

• Objective is to establish a plan to work with
  surrounding community on air issues related to
  railyard
• Designation of Community Liaison
• Schedule for community briefings
• Protocol for complaint resolution
• Submit January 1, 2006

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PR 3504 Risk ReductionFenceline Monitoring

• Required if approved Health Risk Assessment shows
  risk greater than 100 in-a-million or Hazard
  Index of 5.0
• Objective is to monitor air pollutants at
  fenceline
• Pollutant concentrations to be measured case
  specific

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Next Steps

• 2nd Public Workshop End of March
• Working Group Meeting March 23, 2005
• Set Hearing Summer 2005
• Public Hearing Summer 2005