Abate Technologies International, Inc.

ATI QUARTERLY 1ST QUARTER 2019

 

AQMD ANNUAL EMISSIONS REPORTS (AER) - CALENDAR 2018 RECLAIM EXIT UNDERWAY
CARB LAUNCHES BACT/BARCT CLEARINGHOUSE HEXAVALENT CHROMIUM RULE PASSES
METAL MELTING RULE NEW REQUIREMENTS FOR ASBESTOS OPERATIONS

 

AQMD ANNUAL EMISSIONS REPORTS (AER) - CALENDAR 2018

The web-based annual emissions reporting system is now equipment-based. In other words, the criteria and toxic emissions from each piece of equipment at a facility will be reported separately from all other sources of emissions. The requirements are expected to remain almost the same as in the previous year.

Who is required to file?

  • Facilities in the Annual Operating Permit Emission Fee Program. Those are companies who pay annual emissions for permitted equipment. Such facilities are subject to AQMD Rule 301(e) and are required to file when exceeding the corresponding reporting thresholds.
  • Facilities whose permitted plus non-permitted emissions equal 4 tons or more per year of criteria pollutants (VOCs, NOx, SOx, PM, Specific Organics); or 100 tons or more per year of CO.
  • Facilities that receive an Annual Emissions Report Package. However, it is the operator's responsibility to file a report if necessary, even if the facility does not receive a notification from SCAQMD.
  • Facilities which prior to July 1, 2000 had equipment listed as exempt. There is no fee associated with these exempt emissions but they must be reported.

What if I miss the deadline?
The SCAQMD 2017 Annual Emissions Reports (AER) are due by 5:00 p.m. on March 19, 2019. This report corresponds to Calendar Year 2018 reporting period (January 1, 2018 - December 31, 2018). If a facility misses the deadline and owes emission fees, late payment penalties in the form of a percentage of the emission fees will apply. The penalties are set forth in AQMD Rule 301(e)(10)(B) and are as follows:

Payment received date Penalties
Less than 30 days late 5% of reported amount
30 to 90 days late 15% of reported amount
91 days to 1 year late 25% of reported amount
More than 1 year late 50% of reported amount

Fees are determined based on rates in effect for the year when the emissions are actually reported, not the year wherein the emissions occurred.

Special circumstances

The AQMD has a Fee Review Committee to handle issues regarding fees and penalties. The agency requires records related to the AER to be kept for a minimum of five years.
What is new this year?

  • New Emission Fee Rates: New emission fee rates are in effect for the 2018 Annual Emission Reporting Program for criteria pollutants, toxic air contaminants, and ozone depleting compounds in accordance with AQMD Rule 301(e).
  • B2588 Quadrennial Report: For 2018 AER, facilities in Phase 3 are required to file their Quadrennial Reports.
  • AB617 facility designations start this year. This Assembly Bill requires "community-focused" emissions reduction programs to reduce exposure to air pollution in disproportionately burdened communities throughout the state.
  • The PIN codes will remain the same as in previous year.

 

RECLAIM EXIT UNDERWAY

Several months ago, the South Coast Air Quality Management District announced the end of their Regional Clean Air Incentives Market (RECLAIM) program. RECLAIM facilities, which were previously allowed a facility-wide emissions cap, will now be transitioned to a command-and-control regulatory structure. As part of the transition, the district proposes to amend Rules 1146 (Emissions of Oxides of Nitrogen from Industrial, Institutional and Commercial Boilers, Steam Generators, and Process Heaters), 1146.1 (Emissions of Oxides of Nitrogen from Small Industrial, Institutional, and Commercial Boilers, Steam Generators, and Process Heaters), and 1146.2 (Emissions of Oxides of Nitrogen from Large Water Heaters and Small Boilers and Process Heaters) to update NOx emission limits for boilers, heaters and steam generators applicable to these rules.

The revised NOx emission limits represent Best Available Retrofit Control Technology (BARCT) and apply to RECLAIM and non-RECLAIM facilities. Proposed Rule 1100 - Implementation Schedule for NOx Facilities will establish the compliance schedule for equipment at RECLAIM facilities that are subject to Proposed Amended Rules 1146 and 1146.1. PAR 1146.2 includes the compliance schedule for equipment regulated under this rule.

Changes to Rules 1146 and 1146.1 include:

  • New NOx limits based on BARCT technology assessment, which includes cost-effectiveness analysis;
  • Add ammonia slip emission limit of 5 ppm;
  • Exclude units at refineries and electricity generating facilities - addressed in respective industry-specific rule;

Changes to Rule 1146.2 include:

  • No changes to NOx concentration limit of 30 ppm at this time;
  • Commitment to conduct a technology assessment by January 1, 2022;
  • If BARCT is the same as existing rule requirements (30 ppm), compliance by December 31, 2023;
  • If BARCT is less than 30 ppm, a new compliance schedule will be developed;
  • Any unit at a RECLAIM or former RECLAIM facility that is subject to a NOx emission limit in a different rule for an industry-specific category is exempt from Rule 1146.2.

Industry representatives commented that transition rules should not proceed without resolution of new source review (NSR) issues. Staff contends that state law requires the implementation of BARCT for facilities in the state greenhouse gas cap and trade program by December 31, 2023 and that there is already an option (under Rule 2002) for facilities to remain in RECLAIM for a limited time until future provisions in Regulation XIII pertaining to NSR are adopted.

According to staff, they are focused on accounting for and achieving the 12 tons per day reduction commitment from the 2015 RECLAIM amendments and implementing the control measure for the entire RECLAIM program to achieve the additional five tons per day as adopted in the 2016 Air Quality Management Plan.

Several publicly owned utilities expressed concern for dual fuel units to meet the new 7 ppm NOx limit when firing only on natural gas. They requested a detailed review of actual installations that demonstrate viability of retrofitted dual fuel units to meet a 7 ppm NOx limit when firing only on natural gas. Staff acknowledged the challenges faced by publicly owned utilities and stated that they are considering establishing a sector-specific rule for publicly treatment works and landfills in order to better address the concerns of these stakeholders.

Rule 1110.2 (Emissions from Gaseous and Liquid-Fueled Engines) covers internal combustion engines in the RECLAIM program. It is expected to go to the Governing Board sometime during the first quarter of 2019 but has not been set for public hearing. The current rule limits are as follows:

Pollutant Rule 1110.2 (ppmv)
PM Emission limits per Rule 1470
NOx1 11
VOC2 30
CO1 250

1Parts per million by volume, corrected to 15% oxygen on a dry basis and averaged over 15
Minutes.
2Parts per million, measured as carbon, corrected to 15% oxygen on a dry basis and averaged
over the sampling period required by the test method.

Staff announced that future rule development will focus on prime engines (those not used as emergency, stand‐by engines) located at RECLAIM facilities that were previously exempt from Rule 1110.2 requirements. PM standards for diesel engines are contained in Rule 1470 and will not be part of Proposed Amended Rule (PAR) 1110.2. As part of the analysis, staff will look at non-RECLAIM engines as well and will be looking for any lower emissions technology. Staff reports that there are diesel engines at a RECLAIM facility permitted at 12.3 ppmv (@15% O2) but testing is still underway. Source test results for a recently permitted Tier 4 diesel engine, for which the current NOx limit is 22 ppmv, showed the emissions were less than 5 ppmv NOx (@ 15% O2). The district sent out a survey to all affected R1110.2 sources - RECLAIM and non‐RECLAIM. The survey was due on October 28, 2018.

The rule update (excluding R1110.2) to transition the RECLAIM facilities into a commend-and-control structure are scheduled for board adoption in December 2019.

 

CARB LAUNCHES BACT/BARCT CLEARINGHOUSE

The California Air Resources Board (CARB) established the Community Air Protection Program (CAPP or Program) in response to requirements under AB 617 (Garcia)- a recent state law. According to CARB, the Program's "focus is to reduce exposure in communities most impacted by air pollution." The Legislature has appropriated funding to support early actions to address localized air pollution through "incentive funding" to deploy cleaner technologies in these communities, as well as grants to support community participation in the AB 617 process. AB 617 also includes new requirements for accelerated retrofit of pollution controls on industrial sources, increased penalty fees, and greater transparency and availability of air quality and emissions data.

As part of its AB 617 initiative, CARB has launched a statewide "Technology Clearinghouse" (database) of Best Available Control Technology (BACT), Best Available Control Technology for toxics (T-BACT), and Best Available Retrofit Control Technology (BARCT) for stationary sources. The Technology Clearinghouse includes area-wide and mobile source rules, and airborne toxic control measures (ATCM).

The Interim Technology Clearinghouse contains emission limits and control technologies for stationary sources including:

  • Facility-specific BACT and T-BACT decisions, as determined by air districts on a case-by-case basis for new or modified sources.
  • General outline of BACT and T-BACT requirements, based on previous determinations by air districts for commonly permitted new or modified sources.
  • Current list of air district rules, including BARCT and T-BARCT emissions limits.

This information will be periodically revised as CARB staff works with districts to update it. The complete clearinghouse can be found at the following link:

https://www.arb.ca.gov/techclearinghouse/

HEXAVALENT CHROMIUM RULE PASSES

On Nov. 2, 2018 the South Coast Air Quality Management District (SCAQMD) adopted amendments to its Rule 1469 - Hexavalent Chromium Emissions from Chromium Electroplating and Chromic Acid Anodizing Operations. The rule affects 115 facilities and has been developed to address heated sodium dichromate seal tanks and other tanks with similar operating properties that were not previously known to be sources of hexavalent chromium emissions. It was the third time that staff had brought the proposed rule before the board for adoption. Previous attempts to pass the rule failed as the board heard extensive testimony from industry and environmental groups who voiced different concerns and opposed the rule proposal alike.

Staff authored the rule to "address findings during air monitoring and emissions testing at metal-finishing facilities in Newport Beach, Paramount, Compton and Long Beach." The district ordered a metal-finishing facility in Paramount to temporarily curtail all operations and processes emitting the toxic compound hexavalent chromium. In seven separate orders (February, June and December 2017; January, February and August in 2018), the facility was ordered to shut down all equipment with the potential to emit hexavalent chromium "because the agency's air monitors, on average, recorded levels of the compound above a trigger threshold of 1.0 nanograms per cubic meter." According to the Metal Finishing Association, they have been fighting this rule amendment for more than a year and a half and "spent close to $600,000." At the November hearing, the association did not support the rule but
withdrew its opposition.

Rule 1469 has new requirements to control hexavalent chromium-containing tanks that were previously not regulated. It establishes requirements for building enclosures, housekeeping and best management practices, periodic source testing, and perimeter monitoring of pollution control equipment. There are provisions for a revised chemical fume suppressant certification process that further considers toxicity and exposure, provisions to encourage the elimination of hexavalent chromium in Rule 1469 processes, and revisions to align Rule 1469 with the U.S. EPA National Emission Standards for Hazardous Air Pollutant for Chromium Electroplating.

The rule categorizes tanks as Tier I, Tier II or Tier III. The following table summarizes the definitions:

Type of Hexavalent Chromium Tank Definition
Tier I Permitted as containing a hexavalent chromium concentration of 1,000 parts per million (ppm) or greater and is not a Tier II or Tier III Hexavalent Chromium Tank.
Tier II Operated or permitted to operate by the SCAQMD within the range of temperatures and corresponding hexavalent chromium concentrations specified in Appendix 10 and is not a Tier III Hexavalent Chromium Tank.
Tier III Meets any of the following:
(A) Is operated or permitted to operate by SCAQMD within the range of temperatures and corresponding hexavalent chromium concentrations specified in Appendix 10;
or
(B) Contains a hexavalent chromium concentration greater than 1,000 ppm, and uses air sparging as an agitation method or is electrolytic; or
(C) Is a hexavalent chromium electroplating or chromic acid anodizing tank.

 

METAL MELTING RULE

Proposed Rule 1407.1 - Emissions of Toxic Air Contaminants from Chromium Alloy Melting Operations, is an "information gathering" rule that will require a one-time source test and submittal of information to quantify arsenic, cadmium, chromium, hexavalent chromium and nickel emissions from chromium alloy melting operations. According to SCAQMD, information obtained will be used to establish emission standards and other provisions. Proposed Rule 1407.1 also includes requirements for metals composition testing, recordkeeping and reporting.

 

NEW REQUIREMENTS FOR ASBESTOS OPERATIONS

The SCAQMD unveiled proposed changes to Rule 1403 - Asbestos Emissions from Demolition/Renovation Activities. Asbestos can be found at facilities in the form of drywall joint compound, pipe insulation, cement pipe, popcorn ceiling material, floor tile, gaskets, paint coatings and insulation materials. Revisions will align the requirements with the applicable U.S. Environmental Protection Agency (EPA) National Emission Standard for Hazardous Air Pollutants (NESHAP) and with other state and local agency regulations.

The current rule applies only to "owners and operators" but the proposed changes will include
property owners and lessors, as well as those individuals involved in performing asbestos abatement work. A category of "asbestos consultants" will be subject to the new requirements either in whole or in part, as specified. New rule language will allow a two (2) working day notification timeframe to accommodate routine renovations for underground pipe renovation activities. The rule is scheduled for public hearing and adoption in January 2019.

 

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