Abate Technologies International, Inc.

ATI QUARTERLY
1ST QUARTER 2006

 

 

NEW RISK ASSESSMENT PROCEDURE PUBLISHED BY AQMD

The South Coast Air Quality Management District has released a new risk assessment procedure under Rule 1401-- New Source Review for Toxic Air Contaminants. The rule evaluates health risk impacts to nearby exposed individuals.

Rule 1401 has a limitation of Maximum Individual Cancer Risk (MICR) of 1 in a million without Toxics Best Available Control Technology (T-BACT). A risk of 10 in a million is allowed if T-BACT is employed. MICR numbers depend on source and receptor location, emission rate, emission species, meteorology, stack parameters and operating schedule. The cancer burden, defined as excess cancer cases in the population subject to a risk greater than one in a million, is limited to 0.5. Additionally, the rule imposes limits for acute and chronic hazard index of less than one. Rule 1401 includes exemptions for various types of equipment such as emergency internal combustion engines, modifications with no net increase in toxic emissions and functionally identical replacements. Toxic air contaminants are broken down into three categories: Carcinogenic (153 chemicals), Acute (58 chemicals) and Chronic (125 chemicals.) Formaldehyde, methanol, benzene and methylene chloride are some common toxics from internal combustion.
The District has released a guidance document to:

  • assist applicants and engineers to evaluate Rule 1401 compliance;
  • provide explanations and sample calculations; and
  • Provide industry worksheets.

The document describes the procedures for preparing risk assessments under Rule 1401 and Rule 212 – Standards for Approving Permits. The District plans to update the document as new toxic air contaminants (TACs) are added, risk values are changed, or procedures are revised.

 

 

STATEWIDE PORTABLE EQUIPMENT REGISTRATION PROGRAM

The Statewide Portable Equipment Registration Program (PERP) is administered by the Air Resources Board to regulate portable engines and portable engine-driven equipment units. Engines registered in the program are allowed to operate throughout the state of California. Individual permits are not required. Districts are pre-empted from permitting, registering, or regulating ARB-registered units. However, local air districts are responsible for the enforcement of PERP regulations.

Recently proposed amendments will incorporate comments submitted by the California Air Pollution Control Officers Association (CAPCOA). Applicants will be required to designate a “Home District” defined as the district where the portable engine resides most of the time. Hour meters or their equivalent will be required on all engines. Equipment vendors will have to notify ARB of sales and notify buyers of PERP requirements.

Staff projects that draft regulatory language will be available in January 2006 with a draft staff report in May 2006 and Board adoption hearing in June 2006.

 

 

AQMD RULE 1151 - AUTOMOTIVE COATINGS - (AMENDED):

The South Coast Air Quality Management District has adopted amendments to their Rule 1151—Motor Vehicle and Mobile Equipment Non-Assembly Line Coating Operations. The changes incorporate stricter standards for materials used in nearly 1,800 body shops in the Basin. “Technology advancements in recent years will help transition this industry away from conventional solvent-based products to the less-polluting materials currently available for automotive refinishing.” Said Barry Wallerstein, SCAQMD executive officer. The limits are fashioned after the California Air Resources Board recently adopted Suggested Control Measure (SCM). They will implement, in part, requirements in the Air Quality Management Plan. The requirements will take effect in July 2008.

Rule 1151 was originally adopted in 1988 and regulates volatile organic compound (VOC) emissions from commercial and non-commercial refinishing coating applications. The affected industries are composed of auto body repair/paint shops, production auto body paint shops, new car dealer repair/paint shops, fleet operators repair/paint shops, custom- made car fabrication facilities, truck body builders and any other motor vehicle or mobile equipment non-assembly line painting operation. The rule was broken into two segments: Group I) Includes large-sized trucks, buses and mobile equipment; Group II) includes passenger cars, small-sized and medium-sized trucks and vans, motor homes, and motorcycles. The new version eliminates these two categories and focuses on types of coatings instead.

In accordance with ARB’s guidance, the District rule:

  • Combines Group I and Group II categories, establishing limits by coating categories only;
  • Eliminates the composite VOC limit for multistage coating systems and establishes independent VOC limits for both the color and clear parts of the multistage coating system;
  • Combines the primer, primer surfacer and primer sealer categories into a single primer category and establishes a single VOC limit for primers;
  • Eliminates the general specialty coating category and replaces it with specific categories and VOC limits;
  • Adds a prohibition of possession that will prohibit possession of non-compliant coatings unless specific conditions are met.

The District rule differs from the Suggested Control Measure in that:

  • VOC limits for color and clear coatings in Rule 1151 will become effective by July 1, 2008, with a sell through provision of six months with full implementation for the limits by January 1, 2009.
  • Tertiary butyl acetate is partially exempted as a VOC (for coating categories other than color and clear coatings) rather than completely exempted as in the CARB Suggested Control Measure.

Tertiary Butyl Acetate

District staff heard extensive comments in regards to tertiary butyl acetate (TBAc). Environmental groups commented that it should not be de-listed while industry asserted that it should be fully de-listed. The exemption for TBAc provided in Rule 1151 deviates from the exemption provided in CARB’s SCM in that it adds TBAc to the list of exempt compounds. An Environmental Impact Assessment concluded that the data concerning the adverse health effects from exposure to TBAc were limited; and therefore, that it is not possible to characterize the potential for non-cancer health effects resulting from the potential exposures. However, because a metabolite of TBAc, tert-butyl alcohol, has been shown to induce tumors in laboratory animals, exposure to tert-butyl alcohol may result in a cancer risk to humans, if a significant amount metabolizes into the alcohol. At this point, AQMD staff decided to examine the impacts of TBAc as a VOC to be evaluated specifically for this industry as opposed to a complete exemption under District Rule 102.

The following table shows Rule 1151 coating categories and VOC limits.

Table 1. Coating categories and VOC limits for Rule 1151

New Coating Category
VOC limit as Applied (lbs/gal)
Effective Date
Color Coating
3.5
July 1, 2008
Clear Coating
2.1
July 1, 2008
Pretreatment Coating
5.5
January 1, 2009
Temporary Protective Coating
0.5
January 1, 2009
Any other Coating Type
2.1
January 1, 2009
Multi-color Coating
5.7
January 1, 2009
Truck Bed Liner Coating
2.6
January 1, 2009
Uniform Finish Coating
4.5
January 1, 2009
Underbody Coating
3.6
January 1, 2009
Primer
2.1
January 1, 2010
Adhesion Promoter
4.5
January 1, 2010
Single Stage Coating
2.8
January 1, 2010

The staff analysis includes projections from industry that the waterborne technology will be the likely choice for compliance. But, the report also mentions that Ultraviolet coatings may be available that can meet the current and future VOC limits in Rule 1151.

The total average annual cost for all facilities is projected to be $3.58 million between 2006 and 2020. The industry of repair and maintenance bears the majority of the compliance cost (74%) followed by the retail trade (18%). It is also projected that 33 jobs would be forgone annually in the four-county region as a result of the new requirements.

 

 

RULE 1146.2 - EMISSIONS OF OXIDES OF NITROGEN (NOX) FROM LARGE WATER HEATERS AND SMALL BOILERS (AMENDMENT)

The South Coast AQMD is in the process of developing changes to Rule 1146.2, which currently regulates nitrogen oxides emissions from large water heaters and small boilers. The proposed requirements are expected to reduce NOx emissions from new boilers, water heaters and process heaters. New pool heaters rated at less than 400,000 Btu/hour will not be impacted.

Staff seeks comments on the following areas:

  • Proposed NOx emission limits
  • Maintenance and recordkeeping of units greater than 400,000 Btu/hour
  • Compliance demonstration for therm exemption for units potentially subject to retrofit requirements
  • Use of mitigation fee as a compliance option
  • Generation of emission credits from the manufacture of new ultra low NOx limits.

The changes are scheduled for adoption in early 2006.

 

 

TECHNOLOGY ASSESSMENT FOR SOLVENT DEGREASERS

In response to a Board resolution adopted in 2001, AQMD staff has released a report on a technical assessment report for Rule 1122—Solvent Degreasers. The report focuses on the feasibility for the 2006 VOC limits for vapor degreasers and the limited exemption for cleaning of electronic space components. Vapor degreasers are used to remove contaminants from parts, products, tools, machinery and equipment.

The 2001 amendments of Rule 1122 established a 25 gram per liter VOC limit for solvents used in vapor degreasing, effective January 1, 2006. Staff reported that the 25 gram per liter limit is feasible and is being implemented by industry. The rule included a limited exemption for equipment designed to travel over 100 miles above the earth’s surface. Staff now recommends that this exemption be kept.

Staff also reports a decrease (originally 3,000 to 342 in 2001 down to 157 presently) in the number of degreasing equipment using either high-VOC cleaners or halogenated solvents regulated by the federal National Emission Standard for Hazardous Air Pollutants.

Facilities can continue to use high-VOC solvents for vapor degreasing only if used in an airless or air-tight cleaning system.

 

 

NEW SOURCE PERFORMANCE STANDARDS AND NESHAP CHANGES INCORPORATED TO AQMD RULES

The District adopted changes to Regulation IX- New Source Performance Standards and Regulation X- National Emission Standards for Hazardous Air Pollutants in order to update the regulations to comply with recently promulgated amendments by the United States Environmental Protection Agency.

Electric services, natural gas transmission, crude petroleum and natural gas industries are among the regulated industries. Amendments will impact stationary gas turbines (40 CFR Part 60 41346) and include alternative testing and procedures and changes in nitrogen oxides (NOx) emission control technologies and turbine design.

Specifically, the regulation was amended to allow the use of NOx continuous emission monitoring systems (CEMS) to demonstrate compliance. Owners or operators of turbines installed or modified between 10/3/97 and 7/8/04 which, use water or steam injection to control NOx emissions will be allowed to continue to use the NOx monitoring system they had in place.

perators can choose either steam to fuel ratio monitoring or CEMS for turbines (using water and steam injection for NOx control) installed after 7/8/04. For turbines (installed after 7/8/04) that do not use water and steam injection, either CEMS or continuous monitoring of fuel consumption and water, or steam to fuel ratio can be used.

Some of the provisions included are:

  • Frequency of Fuel Nitrogen and Sulfur Content Sampling
  • Nitrogen and Sulfur Content of Turbine Firing Fuel Oil
  • Optional Fuel-Bound Nitrogen Allowance
  • Nitrogen and Sulfur content for Turbines Firing Fuel Oil
  • Test methods for Sulfur Content and Nitrogen Content of Fuel
  • Performance Testing

 

 

FEDERAL MAJOR MODIFICATIONS

The AQMD adopted Rule 1316 (Federal Major Modifications) which implements mandatory regulatory reforms from the Environmental Protection Agency for major sources. These were legally challenged by the California Air Resources Board, AQMD and other local and state agencies.

The EPA proposal, known as the New Source Review (NSR) reform, changed the definition of major modification. On this definition, hinge requirements for Lowest Achievable Emissions Rate (LAER) and its state counterpart Best Available Control Technology (BACT). Affected sources must provide offsets (emission reduction credits) from other sources to more than offset the increased emissions from the new source or modification. The source must demonstrate, through modeling that emissions will not cause a violation or make significantly worse an existing violation of national ambient air quality standards.

The AQMD reports that “U.S. EPA promulgated the NSR Reforms in response to complaints it had received over the years from regulated industry, that the methods of calculating whether a change at a source constituted a “modification” had the effect of disincentivizing sources from making changes that improved efficiency and reduced emissions.”

The rule references the definition of federal major modification under 40 CFR § 51.165. Under this section a major modification is “any physical change in or change in the method of operation of a major stationary source that would result in:

  1. A significant emissions increase of a regulated NSR pollutant [as defined in paragraph (a)(1)(xxxvii) of this section]; and
  2. A significant net emissions increase of that pollutant from the major stationary source.

Significant emissions increases from any unit or net emissions increase at a major stationary source that is significant for volatile organic compounds is considered significant for ozone.

It is the responsibility of the applicant to demonstrate that modification of an existing stationary source is not a federal major modification. The rule allows plant-wide applicability limit (PAL) for demonstrating that modification of an existing stationary source is not a federal major modification. Routine maintenance, repair and replacements are not considered major modifications.

 

 

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