4TH QUARTER 2008
|ATI IS 15 YEARS OLD
Abate Technologies International Inc. (ATI) has been in the environmental engineering and consulting business for over 15 years now. ATI staff, which is comprised of former South Coast Air Quality Management District (AQMD) engineers, recently celebrated the 15th anniversary of the establishment of the company. We would like to take this opportunity to thank all of our clients for their business, some of which have been with us since the very beginning. It has been a wonderful ride and we hope to be assisting our clients for at least the next 15 or 30 years!
Some of ATI services are:
- Recordkeeping (using special software developed for printing and coating operations)
- Annual Emissions Reports (AQMD)
- Environmental audits and emission inventories
- RECLAIM (general compliance, quarterly reports, electronic transmissions)
- Title V (compliance, reports, etc.)
|SOUTH COAST DISTRICT ISSUES EMISSION FACTOR POLICY FOR UV/EB INKS AND COATINGS
Ultraviolet/Electron Beam materials are essentially zero VOC processes used in the printing and coatings industry. The Environmental Protection Agency (EPA) and the South Coast Air Quality Management District have recognized that, for inks and coatings which are applied as a “thin” film (typically 8 to 10 microns or less of wet film thickness), the traditional test method (Method 24) is inadequate. For several years, the South Coast Air Quality Management District has had a policy of using a 5% VOC default emission factor for thin film materials. Industry representatives raised concern that this emission factor inaccurately allocated non-existent emissions to their facilities.
In response to the concerns raised, the Engineering and Compliance Division of the AQMD reduced the emission factor to 2% by weight. A policy memorandum dated July 17, 2008, indicates “the default factor should be used when acceptable test data is not available.”
|CHANGES TO SCAQMD RULE 222
Rule 222 – Filing Requirements for Specific Emission Sources Not Requiring a Written Permit Pursuant to Regulation II - is a registration type program of the South Coast Air Quality Management District. The rule identifies specific types of equipment that emit low levels of criteria emissions and low toxic risks. Operators of such equipment are required to file information with the AQMD, which includes a description of the equipment, facility information and other pertinent data.
Currently, Rule 222 includes four equipment categories:
- Negative air machines
- Boilers/steam generators and process heaters with rated heat input capacity from 1,000,000 up to and including 2,000,000 btu/hr
- Oil production well groups.
The proposed rule will add new equipment categories to the filing program to incorporate requirements in AQMD Rule 219 (as amended on July 14, 2006 and June 1, 2007) and in the California Air Resources Board (CARB) Airborne Toxic Control Measure (ATCM) for Stationary Compression Ignition Engines.
The following additional equipment filing categories are being proposed for inclusion in Rule 222:
- Printing and related coating and/or laminating equipment and associated dryers and curing equipment exempt from written permit pursuant to Rule 219(h)(1)(E);
- Roller to roller coating systems that create 3-dimensional images exempt from written permit pursuant to Rule 219(j)(13)(C);
- Coating or adhesive application or laminating equipment exempt from written permit pursuant to Rule 219(l)(6)(F);
- Drying equipment such as flash-off ovens, drying ovens, or curing ovens associated with coating or adhesive application, or laminating equipment exempt from written permit pursuant to Rule 219(l)(11)(F);
- Certain equipment, processes, or operations emitting in aggregate four tons or more of VOCs per year at a single facility, and having no written permit from the District for any other equipment, processes or operations, as specified in Rule 219(s)(3);
- Stationary or portable emergency diesel–fired internal combustion engines rated greater than or equal to 50 brake horsepower (bhp) at any agricultural facility or source exempt from written permit requirements pursuant to Rule 219(q)(1);
- Stationary or portable non-emergency diesel–fired internal combustion engines rated greater than or equal to 50 brake horsepower (bhp) at agricultural sources with actual emissions less than the amounts listed in the table pursuant to Rule 219(q)(2);
- Existing (installed on or before 7/7/2006) gasoline storage and dispensing equipment with a capacity greater than or equal to 251 gallons at agricultural sources.
Staff is also proposing to modify the rule applicability to include certain agricultural engines subject to the CARB ATCM.
Additionally, facilities that have no AQMD written permits, but emit 4 tons or more of aggregate VOC emissions per year from specific equipment or processes, will be required to file under Rule 222 if they meet the following criteria:
- Printing operations individually exempted under Rule 219(h)(1) and (h)(7);
- Coating or adhesive or laminating equipment exempted under Rule 219(l)(6) and (l)(10);
- Hand application of solvents for cleaning purposes exempted under Rule219(o)(4).
|CALIFORNIA LEGISLATURE WILL NOT BAN BISPHENOL-A AND PERFLUORINATED COMPOUNDS AT THIS TIME
The California State Assembly did not pass two bills that dealt with compounds (Bisphenol-A and Perfluorocarbons) used by the printing and packaging industry.
Bisphenol A –Senate Bill 1713
Senate Bill 1713 by Sen. Carole Migden, D-San Francisco, would have enacted the Toxin-Free Toddlers and Babies Act, prohibiting the use of Bisphenol-A and imposing “least toxic alternative” requirements to certain child care articles that contain Bisphenol-A in detectable levels. The act would have prohibited (with some exceptions) the manufacture, sale, or distribution in commerce of any bottle, cup, or other container that contains Bisphenol-A at a level above 0.1 parts per billion (ppb), if the container is designed or intended to be filled with any liquid, food, or beverage primarily for consumption from that container by infants or children 3 years of age or younger.
Perfluorinated compounds—Senate Bill 1313
Senate Bill 1313, by Sen. Ellen Corbett, D-San Leandro, targeted perfluorinated compounds, or PFCs, from food packaging. It proposed to prohibit the manufacture, sale, or distribution of any food contact substance that contains perfluorinated compounds, in any concentration exceeding 10 parts per billion as of January 1, 2010.
Proponents of both measures said there was enough evidence to suggest potential health hazards from the chemicals and that the state should not wait for federal action. Both bills could be brought back for another vote.
|GREENHOUSE GAS POLICY MAKING CONTINUES
The South Coast Air Quality Management District adopted a voluntary program where facilities could undertake projects to voluntarily reduce greenhouse gas emissions in advance of any regulations. The “Southern California Climate Solutions Exchange,” would follow protocols developed by the California Air Resources Board. The SCAQMD staff would oversee the certification, registration, and tracking of the reductions.
Additionally, the California Air Resources Board recently provided a briefing on the implementation of the state’s plan to reduce greenhouse gas emissions. The California Air Resources Board (CARB) is the lead agency for implementing AB32, which set the major milestones for establishing the program. Under AB32, CARB must develop a Scoping Plan to lower the state’s greenhouse gas emissions to 1990 levels by the year 2020. CARB has released a Draft Scoping Plan. This means cutting approximately 10 percent from today’s levels. ARB has developed preliminary estimates of the costs and savings of the various measures considered in the Draft Plan and concluded that the overall savings from improved efficiency and developing alternatives to petroleum will, on the whole, outweigh the costs — the agency attributed the result to the current high cost of energy.
Offsets, use of revenues from auctions, sector-specific regulatory measures and cap-and-trade were all part of the comprehensive plan to get the state down to 1990 levels. California is working with six other states and three Canadian provinces in the Western Climate Initiative (WCI) to design a regional greenhouse gas emission reduction program that includes a cap-and-trade approach.
CARB staff reported that over 800 comments had been posted on the website. Staff was looking for public comment to move recommended items into the “under consideration” category and vice versa. CARB will revise this Draft Plan based on continuing analysis and public input and will take the proposed Scoping Plan, which will be released in early October, to the Board for consideration at its meeting in November, 2008. The measures in the Scoping Plan adopted by the Board will be developed over the next three years and are expected be in place by 2012.
On the federal side, the Environmental Protection Agency published a “Notice of Proposed Rulemaking” in the Federal Register to analyze how greenhouse gases would be regulated under the Clean Air Act. The agency states that its goal is to “collect comprehensive and accurate data relevant to future climate policy decisions.... .” Fossil fuels and chemical producers and importers, as well as direct emitters and industrial facilities would fall within the scope of the regulation. All EPA regions are working on developing climate change strategies. The proposed rule is expected sometime in September 2008 and the final rule in June 2009.
|COURT DECISION DISALLOWS USE OF CREDITS IN SOUTH COAST
A court decision in a lawsuit filed by environmental groups has found the South Coast Air Quality Management District in violation of state law. The lawsuit was brought forth as a result of the District’s adoption of Rules 1309.1 (Priority Reserve) and 1315 (Federal New Source Review Tracking System) and alleged that the district violated the California Environmental Quality Act (CEQA) by failing to conduct appropriate environmental and health analysis.
The subject rules would have accommodated power plants (11 in the Los Angeles Basin and two in the outlying areas of Desert Hot Springs and Victorville) built by private companies, which would sell the power to Southern California Edison and other utilities. The Clean Air Act requires offsets for new sources. Several years ago, the SCAQMD set aside what it called “Priority Reserve credits” intended for essential public service projects such as hospitals and police stations. Last year, the District sold $420 million worth of credits to energy companies.
The court stated that the District inaccurately described the project and consequently distorted the “substantial and significant environmental effects that are present in these two rules.” The court further stated: “Rather than conduct a complete analysis, the District fails to even disclose all of the relevant data in its possession.” The decision vacates both rules and enjoins the District from taking any further action to implement the rules pending compliance with CEQA. The District has not commented on the impacts of this decision on other District credit trading rules such as RECLAIM.
|BOILERS, STEAM GENERATORS AND HEATERS RULES ADOPTED
The South Coast Air Quality Management District adopted rule 1146 — Emissions of Oxides of Nitrogen from Industrial , Institutional, and Commercial Boilers, Steam Generators, and Process Heaters — as well as the companion rule 1146.1 — Emissions of Oxides of Nitrogen from Small, Industrial, Institutional, and Commercial Boilers, Steam Generators, and Process Heaters. Staff commented that the rules are necessary as they have seen non-compliance rates of approximately 30%.
Rule 1146 addresses units with maximum rated heat input capacities greater than or equal to 5 million BTU/HR. The rule applies to facilities with multiple units totaling in a heat input greater than 8 million BTU/HR, even though individual unit’s ratings might be less than 5 million BTU/HR. This rule does not apply to electric utility boilers, refinery boilers and process heaters with a rated heat input greater than 40 million BTU/HR, sulfur plant reaction boilers, or waste heat recovery boilers serving combustion turbines. Rule 1146.1 deals with units with maximum rated heat input capacities between 2 and 5 million BTU/HR. The rules do not impact RECLAIM units/facilities.
The rules drop the NOx limits from the currently allowable (except for low fuel burning equipment) 30 parts per million (ppm) to 12 ppm, 9 ppm or 5 ppm, depending on equipment size and operational characteristics, as well as recognizing energy efficiency. The future compliance limits for units burning landfill or digester gas are 25 ppm and 15 ppm, respectively. The current CO limit for all Rule 1146 equipment is 400 ppm.
Other changes include requiring annual tune-up procedures and monthly maintenance procedures, limiting time to de-rate equipment, and applying a 30 ppm limit to low fuel usage equipment during burner replacements, but no later than a 15 year equipment life. The compliance schedule is staged over a six-year period, taking into consideration size range and unit operation. Facilities with multiple units are offered an option for a later compliance date at a more stringent limit. Units with low fuel usage (less than 90,000 Therms per year) can take advantage of an exemption in the rule. The frequency of monitoring has increased to monthly monitoring under Rule 1146 and quarterly monitoring for Rule 1146.1.