VOC Emissions & Percentage Increased From All American Asphalt Between 2010 – 2019

March 2021

Why Do We Need More Comprehensive Air Testing and Monitoring?

March 2021

Below are some of the slides shared by our volunteer UCI advisor, Dr. Barbara Barletta from Dr. Blake’s Group. If you were at the public meeting hosted by the SCAQMD on March 3, 2021, you would have seen these. As indicated in the first slide, a grab sample was collected on December 16, 2020, in Eastwood Village, when a strong chemical odor and irritation were detected. The lab result came back with high levels of Ethylbenzene, m-Xylene + p-Xylene, o-Xylene, and Acetone, in comparison to the “baseline”/typical background sample, or even air samples from other US urban centers as shown on the second slide. Yes, Acetone is a common solvent widely used, but is it normal to have this level (230,272 pptv) and at that hour in a residential neighborhood? Where could it come from? Just because the EPA removed Acetone from the Toxics Release Inventory (TRI) reporting, does that mean that cumulative and constant exposure to it wouldn’t have any effects on the residents in the long run, especially the most vulnerable such as children and pregnant women?

What Caused the Elevated VOCs Readings on Our Low-Cost Sensors in Orchard Hills Reserves?

April 2021

Four consecutive days in a row, with the exception of Sunday, between February 26 (Fri) and March 2 (Tue) 2021, all three of our low-cost sensors in Orchard Hills Reserves showed elevated VOCs readings during the morning hours, with the highest recorded at 25.9 ppm!!! We find this really strange because we used to see this trend quite consistently sometime back in November of 2020 when our UCI advisors just started collecting the VOCs data. Coincidently, the crumb rubber system at the facility was turned off between November 25, 2020 to February 17, 2021.

So far, the SCAQMD’s air sampling results show nothing beyond the acceptable thresholds, but per our understanding, they didn’t have any sampling done in Orchard Hills Reserves. We have also asked them to explain what caused the VOCs to spike in that neighborhood to such levels. They have somewhat been pointing to constructions, but we have two low-cost sensors in Eastwood Village, which has considerable and comparable amount of ongoing constructions as well. As a matter of fact, the sensors we have in Eastwood are only about 0.1 mile (and definitely less than 0.2 miles) away from two different constructions sites, and yet, we have NEVER seen any VOCs readings near what Orchard Hills Reserves recorded. What caused the spikes?

A Mistake? Would the SCAQMD Even Caught the Mistake If We Didn’t Make Enough Noise?

April 2021

All American Asphalt in Irvine was added to the AB2588 Program, also known as the Air Toxics ‘Hot Spots’ Program sometime in February of 2020. According to SCAQMD, “it is their 2016 quadrennial report (their most recent) that brought them into the program. Initially the emissions on that report indicated that the facility was low priority and did not need further action. We audited the report and found a mistake in one of their emission calculations. We have since been working with the facility per our AB 2588 program requirements, and in February 2020 required them to submit an Air Toxics Inventory Report (ATIR) – a very detailed emissions inventory.” (Quoted from AQMD’s email to our group on April 6, 2021)

Fast forward fourteen months later, the ATIR is still not complete. Based on the latest update provided by the SCAQMD on April 20, 2021, “the ATIR should be finalized in a couple of months.” We have been asking if this is a typical time period for such reports to be prepared and approved for facilities that have been found to violate air pollution standards, had multiple formal community complaints, or submitted erroneous air emission data, but the SCAQMD did not provide a response.

All American Asphalt was also last prioritized in 2017, when most homes in Orchard Hills Reserves and Eastwood Village were not yet built. Besides the “potency, toxicity, quantity and volume of hazardous materials released from the facility; the proximity of the facility to potential receptors, including, but not limited to, hospitals, schools, daycare centers, worksites and residences;” are factors the SCAQMD should take into account while establishing the priorities. Obviously, this part is outdated as well, as we now have homes just within 0.5 miles away from the facility, and yet, they have not been included in the prioritization.

What’s “Default Emission Factors?” Are Those Fake Reports?

May 2021

SCAQMD has stopped responding to our questions; many of which were sent in March 2021, and we wonder if they still exist. LOL. Anyway, we started communicating with The California Air Resources Board (CARB) since then and they have been really helpful. At the end of April, CARB had a meeting with AQMD regarding our concerns and questions and said AQMD conveyed this to them: “The Air Toxics Inventory Reports (ATIRs) submitted by the facility for the last three years are based on default emission factors, and the district deemed them defective.”

What does “default emission factors” actually mean? Does it mean that the emissions reports All American Asphalt submitted in the last 3 years were not the true emissions reports from the facility? What have we really been exposed to then? Where’s the oversight?

AAA “received a “Notice of Exemption”

Sept 2021

AAA “received a “Notice of Exemption” from the South Coast Air Quality Management District on Friday, Aug. 27, which stated that it posed no threat to the environment.” Funny enough, that same morning, before this notice came out, 8 complaints were filed.

“The South Coast AQMD has determined that the Proposed Project is exempt from CEQA pursuant to CEQA Guidelines Sections 15061(b)(3) – Common Sense Exemption and 15301 – Existing Facilities. In addition, no unusual circumstances would occur that would create significant effects and none of the exceptions to the Class 1 categorical exemption pursuant to CEQA Guidelines Section 15300.2 – Exceptions apply to the Proposed Project.”

At the end of September of 2021, Kevin Lien, Kim Konte and Lesley Tan submitted an appeal to the South Coast AQMD on the crumb rubber blending system permit of All American Asphalt. $305.50 was withdrawn from the pool of funds we received from residents to pay for the filing fee.

As we worked on the appeal, we came across the term Title V; “a federal program designed to standardize air quality permits and the permitting process for major sources of emissions across the country.” Based on AAA’s 2018 and 2019 VOCs emissions alone should have qualified AAA under Title V, but when we emailed South Coast AQMD asking about it, their response was, “AAA was notified by South Coast AQMD staff on February 4, 2021 that the facility was required to submit an initial Title V application. Please see the attached email. The facility submitted that application on May 5, 2021 and it is currently under review. If it is determined that actual emissions have exceeded the Title V threshold, the Irvine location for All American Asphalt will be brought into the Title V permitting program.”

Is the South Coast AQMD a couple years late again in catching another “error?” Or would they come back and say AAA’s 2018 and 2019 emissions data posted on their website is incorrect? Let’s wait and see.