Abate Technologies International, Inc.

ATI QUARTERLY
4TH QUARTER 2003

 

 

NEW SOLVENT-CLEANING REQUIREMENTS

The South Coast Air Quality Management District proposes amendments to Rule 1171, which regulates emissions from solvent cleaning operations. The proposal targets clean up of architectural coatings and industrial maintenance coatings. It is expected to achieve emission reductions of 8.39 tons per day.

The currently, the Volatile Organic Compound (VOC) limit for clean up of coating and adhesive application equipment is 550 grams per liter, going down to 25 grams/liter by July 2005. Spray guns, rollers and brushes used in clean up of wood, metal coatings and auto refinish and related operations fall under this category. Architectural-related clean up operations are presently exempted from Rule 1171 requirements and allowed a VOC limit of 950 grams per liter. This exemption will be removed by July 1, 2005. The new limit will be 25 grams/liter. AQMD staff concluded that reformulation would be more cost effective than installation of a control device, such as an afterburner.

Industry representatives have expressed concern over the use of acetone as a compliant option. They pointed out the high flammability of acetone as a fire hazard. Industry believes that good housekeeping practices would result in VOC reductions, without the need to reformulate. In addition, they assert that the available waterborne solvents are of questionable effectiveness.

Staff anticipates a “continued increase in the use of readily available compliant solvents to meet the 2005 VOC requirements” and that additional low-VOC materials will be available when the new VOC limits take effect in 2005.

 

TECHNICAL ASSESSMENT FOR WOOD COATINGS

The 1996 amendments to SCAQMD’s Rule 1136 (Wood Products Coatings) included a staff commitment to complete a technology assessment, evaluating the viability of compliant coating technologies, by July 2003. Industry was required to submit progress reports to the District by January 2003.

The following are examples of operations subject to Rule 1136:

  • Household furniture
  • Office and contract furniture
  • Kitchen and bathroom cabinets
  • Architectural millwork and store fixtures
  • Shutters, blinds, doors, windows and moldings
  • Specialty products (musical instruments, toys, speaker cabinets, picture frames, skateboards)
  • Repair and finishing operations
  • Job shop (a combination of above operations)

SCAQMD staff identified various compliant technologies (waterborne systems, light curable processes, acetone formulations, high solids, thermally cured) as part of their findings. Out of 780 facilities subject to the rule, 366 responded to an SCAQMD survey. According to the survey, 16% of respondents are in full compliance with the 2005 VOC limits. The rest are either in partial compliance (32% of respondents) or not yet meeting the 2005 limits (52% of respondents). One percent of respondents comply with the limits via the use of add-on control equipment.

The Technology Assessment concluded that “Technology exists and is in use today in the form of many resin and solvent systems to meet the July 1, 2005 future VOC limits that are primarily 275 grams VOC per liter, less water and less exempt solvents.”

 

CUMMULATIVE IMPACTS REGULATIONS

In a recently released White Paper, the South Coast Air Quality Management District defines a cumulative impact as “an adverse health effect, risk or nuisance from exposure to pollutants released into the air from multiple air pollution sources.” The SCAQMD board directed staff to produce the White Paper as part of efforts to address cumulative impacts from air emissions. The program seeks to identify high cumulative impact areas and develop corrective strategies. Cumulative Impact Reduction Strategies will include:

      • Cancer risk
      • Hazard Index from non-cancer risk sources
      • Odors
      • Enforcement

District staff has proposed a set of “early-action” control strategies for immediate development and implementation. First on the list is an air toxics control rulemaking for back-up diesel generators. In addition, the following actions were recommended for immediate development:

  • More stringent requirements for new sources located near schools and possibly other sensitive receptors.
  • Chromium spray coating operations.
  • Yard hostlers at ports, rail yard and distribution centers.
  • Increased compliance assurance for repeat emission violations.
  • Prioritization of resources for California Environmental Quality Act (CEQA) document review in high cumulative impact areas.
  • Voluntary partnerships between AQMD and local government.
  • Pilot odor abatement program.

Staff recommended the inclusion of a cumulative impacts component to the Air Toxics Control Plan process, updating it periodically to incorporate the latest technical information and toxic control strategies. The toxics plan update will tentatively be presented to the Governing Board by the end of 2003. In addition, an update to the Multiple Air Toxics Exposure Study (MATES) is planned in an effort to improve data and technical tools.

 

ENVIRONMENTAL PROTECTION AGENCY MACT STANDARDS

The EPA promulgates Maximum Achievable Control Technology (MACT) Standards to regulate emissions of 188 listed toxic air pollutants from major sources nationwide. A “major source” emits 10 tons per year or more of a single toxic air pollutant or 25 tons per year or more of a combination of these pollutants. “By the end of August, EPA will have issued 92 MACT standards. When fully implemented, these rules will keep nearly two million tons of toxic compounds out of our nation’s air each year,” said Acting EPA Administrator Marianne Lamont Horinko. A summary of some of the new MACTs follows:

Surface Coating of Miscellaneous Metal Parts and Products
The surface coating of miscellaneous parts and products is a process of applying a protective, decorative, or functional coating to metal parts of items such as railcars, steel drums, construction equipment, iron and steel pipe, structural steel, extruded aluminum products, motorcycles and musical instruments. Paints, stains, sealers, topcoats, basecoats, primers, inks and adhesives are some of the coatings subject to the regulation.

The rule mandates a 48-percent (approximately 26,000 tons per year) reduction of total air toxics emissions from the 1997 baseline. Many of the air toxics are also Volatile Organic Compounds (VOCs).

EPA estimates that 1,500 existing facilities nationwide and 225 newly constructed ones in the next five years will be impacted by the changes. The total annualized cost will be approximately $57.3 million per year.

Surface Coating of Metal Cans
The can manufacturing process involves the coating of metal cans or ends. Various coating operations (basecoating, decorative inks, end seal or end lining compounds, side seam stripes, inside sprays, interior lacquers, overvarnishes, repair spray coatings) associated with can manufacturing can result in emissions of air toxics. The processes regulated by MACT are:

  • One and two-piece draw iron can body coating;
  • Sheetcoating;
  • Three-piece can assembly;
  • End coating.

The projected toxics reductions of 6,800 tons per year will come from 142 existing facilities and represent a 70 percent reduction from the 1997 baseline year. A total annualized cost of $58.7 million is projected.

Surface Coating of Metal Furniture
Metal furniture operations include the production of office furniture, hospital furniture, shelving and lockers. Approximately 3,000 facilities nationwide produce metal furniture but only 655 are major sources subject to the requirements. The new MACT standard is 0.10 kilogram toxic compound per liter of coating solids used (0.83 pound/gallon) for existing facilities. Affected facilities are given 3 years to comply.
New facilities will be required to use coatings with no air toxics. Upon demonstration that toxics-free coatings are not available for specific operations, an emissions limit of 0.094 kilograms toxics per liter (0.78 pound/gallon) will be allowed. The estimated annualized cost (over a 5-year period) is $14.8 million.

Miscellaneous Organic Chemical Manufacturing Facilities
This MACT rule will require control for process vents, storage tanks, equipment tanks, equipment leaks, wastewater systems, and transfer operations from organic chemical manufacturing facilities. Chlorinated paraffin production, rubber chemical production, polyester resin production and alkyd resin production are examples of processes covered by this rule. The primary air toxics associated with these operations are methanol, vinyl acetate, hexane, methylene chloride, hydrogen chloride and toluene.

An estimated air toxics reduction of 16,800 tons per year is expected. The annualized cost for industry to implement changes, such as solvent use reduction, will be roughly $75 million.

Printing, Coating, and Dyeing of Fabric and other Textiles
Facilities subject to this rule include those involved in the process of applying a coating or printing material to one or both sides of a continuous web substrate, such as a roll of fabric. Dyeing and finishing of a textile (yarn, thread, cord, fiber, fabric) are also subject to the requirements. The agency projects emission reductions of 4,100 tons per year and an annualized cost of $14.5 million from this particular measure.

Reinforced Plastic Composites Production
Facilities manufacturing fiberglass bath tubs and showers, automobile and recreational vehicle parts, storage tanks, and engine and tool covers fall under the EPA’s regulation. This rule will affect 435 existing facilities and requires incorporating pollution prevention techniques (use of non-toxic raw materials, non-atomized resin applications and covering of open resin baths and tanks) in the manufacturing process. New large (emitting 100 tons per year or more of air toxics) facilities that perform processes such as open molding, pultrusion, centrifugal casting and continuous lamination/casting, will have to install air pollution control equipment. Large new manufacturers of sheet molding compound and bulk molding compound must also install controls. A projected 7,680 tons per year toxics reduction is projected for the reinforced plastic composites industry. The EPA estimates that the total annualized cost of said reductions will be $21.5 million.

Semiconductor Manufacturing
Semiconductor manufacturing operations emit various air toxics, which will be regulated by the MACT rule. Hydrochloric acid, hydrofluoric acid, glycol ethers, methanol and xylene comprise over 90 percent of all emissions, according to EPA staff. The product of semiconductor operations is the integrated circuit used in electronics (computers, appliances, radios, CD players) manufacturing. Although 170 semiconductor facilities have been identified by EPA, only one will be subject to the rule. The rest are not considered major sources.

Surface Coating of Wood Building Products
The rule will impact major sources using more than 1,100 gallons of coatings per year. Exterior siding and primed door skins, flooring, interior wall paneling, tileboard, windows fall under the EPA’s definition of wood building products. 215 facilities performing coating operations associated with wood building products will be subject to the MACT. An estimated 4,900 tons per year of air toxics will be reduced by implementing the more stringent emission standards. The annualized cost to industry will be approximately $22.5 million.

CHANGES TO SCAQMD ADHESIVES RULE

SCAQMD Rule 1168 (Adhesive and Sealant Applications) regulates all commercial and industrial sales and applications of adhesives, adhesive bonding primers, adhesive primers, sealants and sealant primers. SCAQMD staff proposes two main changes to the rule: 1) Modify the exemption for light curable adhesives and 2) Postpone requirements for automotive and marine top and trim adhesives.

The first change was prompted by EPA’s limited disapproval of the rule due to what they considered an overly broad exemption for light curable (Ultraviolet, electron beam or light cured) adhesives. New language limiting the VOC content for exempt materials to 50 grams per liter and requiring recordkeeping as set forth in the recordkeeping rule (rule 109) is expected to address EPA’s concerns.

The 250 gram/liter requirement for top and trim adhesives will be postponed one year until January 1, 2005. Staff expects the added year will afford industry the opportunity to further experiment with low VOC adhesives.

The rule is scheduled for adoption by the Governing Board in October 2003.

 

EPA PROPOSES 8-HOUR NATIONAL AMBIENT AIR QUALITY STANDARD FOR OZONE

Originally adopted in 1979, the current federal ozone standard is 0.12 parts per million (ppm) measured over one hour. The Clean Air Act contains control requirements and deadlines for attainment of this “one-hour” standard. The timelines for attainment depend on severity of air pollution. In the South Coast’s case (the only area in “extreme” non-attainment) the deadline for attainment is 2010.

EPA has published its Proposed Rule to Implement the Eight-Hour Ozone National Ambient Air Quality Standard. According to the agency, the 8-hour standard (0.08 ppm measured over an eight-hour period) is more stringent and thus more protective of public health.

At this point, SCAQMD staff is unsure whether or not the 8-hour standard approach is the most appropriate for the region. Staff estimates that, under the new standard, the deadline for attainment would be 2021.

 

GREEN CARPET PROJECTS

With environmental groups’ support, SCAQMD is allowing flexibility for super mitigation, or clean air action projects. The so-called “Green Carpet” projects are voluntary actions by project proponents. Facilities that go above and beyond what is legally required as mitigation measures are eligible for program enrollment. These projects will enjoy expedited permit and CEQA review. District staff has compiled a list of specific projects that have been identified as super clean air actions in order to avoid individual negotiations with project proponents.

 

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