Abate Technologies International, Inc.

ATI QUARTERLY
2nd QUARTER 2003

 

 

ADDED SECURITY FOR HAZARDOUS WASTE AND MATERIALS

The California Department of Toxic Substances Control (DTSC) announced new requirements that are expected to enhance the security of hazardous waste handling. DTSC Director, Ed Lowry commented: “We are complying with Governor Davis’ directives to increase vigilance over hazardous materials and hazardous waste by making the system more secure.”

Senate Bill 1257 (Murray) became law on January 1, 2003 and requires the enclosed cargo body of transport vehicles to remain locked except during loading and unloading. Drivers must open the doors at the directions of a peace officer, an authorized employee of the Highway Patrol, the DTSC, Certified Unified Program Agencies, or local health officers. In addition, hazardous waste generators and facility operators must perform additional checks of transporter’s driver’s licenses and special endorsements prior to allowing loads to leave their facilities.

Also on January 1, 2003, Senate Bill 489 (Romero) became law. This bill requires that the DTSC establish a list of “hazardous wastes of concern” (those requiring special handling for security reasons) by July 1, 2003. Hazardous waste facility permit applicants involved in the handling of wastes on the list must submit a disclosure statement that includes fingerprints. A criminal check will then be conducted by the DTSC. SB 489 addresses the issue of missing hazardous wastes of concern occurring during transport. In such a case, the transporter or personnel at the hazardous waste facility must notify the DTSC by telephone and submit a written report within 15 days.

 

STATE CONSIDERS NEW STANDARDS FOR DIESEL-FUELED ENGINES
The California Air Resources Board will propose an Airborne Toxics Control Measure (ATCM) to reduce diesel particulate matter emissions from in-use and new stationary diesel-fueled engines. The ARB is considering establishing diesel particulate emission standards that are based on the use of best available control technologies and lowest-emitting diesel-fueled engines. The measure will cover new and existing stationary engines but will not apply to permit exempt agricultural engines.

Depending on annual hours of operation, some stationary engines rated at 50 brake horse power-hour (bhp-hr) or greater, will be required to reduce diesel PM emission by 85%.

Emergency engines operating less than 15 hours per year will be exempt form the proposed requirements. Engines operating over 15 hours per year will be subject to the following emission limits:

DIESEL PM EMISSION RATE (g/bhp-hr)
MAXIMUM ALLOWABLE ANNUAL HOURS OF OPERATION (Maintenance and Testing)
>0.50
15
0.50
30
0.40
40
0.15
100
0.01
>100

Engines located within 1,000 feet of a school, will not be allowed to operate during school hours for maintenance and testing. The regulation is expected to take effect early to mid 2004 for new engines. The compliance proposed schedule for in-use engines follows:

  • Pre-1989: January 1, 2006
  • 1990 thru 1995: January 1, 2007
  • Post 1995: January 1, 2008
  • Additional time will be given for owners of four or more engines

The Air Resources Board will consider the ACTM in July 2003.

 

CALIFORNIA AIR RESOURCES BOARD REQUIREMENTS FOR AUTOMOTIVE COATINGS

Suppliers, distributors and coating manufacturers of automotive coatings used in California will have to comply with the state’s new regulations for automotive coatings. The recent ruling seeks to minimize emissions of Hexavalent Chromium and Cadmium (both considered toxic substances). It applies to “motor vehicle and/or mobile equipment coating facilities” such as: autobody repair/paint shops, new car dealer repair/paint shops, custom-made car fabrication facilities, truck-body builders, and residences at which coatings are applied to motor vehicles and/or mobile equipment.

The regulation specifically prohibits the selling, supplying or manufacturing for sale in California of any motor vehicle and/or mobile equipment coating that contains hexavalent chromium or cadmium. There is a “sell-through” provision in the regulation that allows materials manufactured prior to January 1, 2003 to be sold. The date of manufacture must appear on the container in order to take advantage of the sell-through provision.

 

LINK BETWEEN AIR POLLUTION AND ASTHMA AND BRAIN CANCER

Citing studies which found a link between air pollution and asthma risk as well as recent studies suggesting a possible link between air pollution and brain cancer, the SCAQMD
Board adopted the establishment of research funds. The money will come from penalty fees.

An “Asthma and Outdoor Air Quality Consortium” will include researchers involved in air pollution and health research projects. A “Brain Tumor and Air Pollution Foundation” will focus on generating data to define the relationship between air pollution and brain cancer. The Foundation will support research on the epidemiology of brain tumors taking into consideration molecular and genetic factors.

The Board also approved funding to replace diesel buses (responsible for emitting diesel particulate—a known carcinogen). Seventy (70) percent of penalty fees collected in 2003 will go to the “Lower-Emission School Bus Replacement & Retrofit Program Fund” used to help school districts purchase cleaner buses or retrofit existing ones. Since 1999, the AQMD has approved more than $43 million for school bus projects.

 

SOURCE REDUCTION PLANNING FOR HAZARDOUS WASTE
The assumption that hazardous waste generators will voluntarily carry out source reduction procedures that save the company money, is the foundation of Senate Bill (SB) 14. The bill (Hazardous Waste Source Reduction and Management Review Act of 1989) enables businesses to document their source reduction planning activities.

The goals are to:

  1. Reduce the generation of hazardous waste at its source,
  2. Reduce the release to the environment of chemicals that have adverse and serious health or environmental effects, and
  3. Document hazardous waste management information and make the information available

Implementation of SB 14 comes in the form of regulations adopted by the Department of Toxic Substances Control (DTSC), which allow generators the flexibility to use their knowledge of their own operations to reduce hazardous waste generation and prevent the release of pollutants to the environment. Rather than mandating specific actions to reduce waste, the regulation stipulates the format for documenting source reduction measures.

As an example, a plating (nickel, copper, silver, and gold) company took the following source reduction steps:

  • Improved bath maintenance
  • Fog rinsing above heated process baths
  • Re-use of drag-out solutions in heated baths
  • Re-use of spray rinses in rinse tanks
  • Electrocleaner purification
  • Counter-current rinsing
  • Electrowinning to recover precious metals from rinse tanks

The Office of Pollution Prevention and Technology Development, developed a Guidance Manual to assist generators in the preparation of source reduction documents. A flow chart from the manual follows:

Generated over 12,000 kilograms of hazardous waste or 12 kilograms of extremely hazardous waste in 2002
No

 

Not required to prepare SB 14 documents
   
Yes
Are wastes exempted under Chapter 2.3 of Guidance Manual?

Yes
   
No
       
Is an SB 14 report required according to the Guidance Manual?
Yes
Is your company a small business?
Yes
You may choose to complete the compliance checklist as your plan (DTSC Doc. No.004)
No
 
No
   
Not required to prepare SB 14 documents
 
Prepare the full plan and report
   

 

ARB’S CONTROL MEASURE FOR CHLORINATED AIR CONTAMINANTS
The California Air Resources Board (ARB) adopted an Airborne Toxics Control Measure (ATCM) for automotive consumer products (aerosol and liquid brake cleaners, carburetor cleaners, engine degreasers, and general-purpose degreasers). The regulated toxic air contaminants are found in automotive consumer products commonly used in automotive maintenance and repair activities. They are generally available as pre-packaged aerosol sprays or bulk liquid products that are easily added to refillable pump sprayers. The state reports that majority of these products are used in commercial facilities with much smaller usage from do-it-yourselfers.

The measure prohibits formulating products that contain perchloroethylene (Perc), methylene chloride (MeCl) or trichloroethylene (TCE) in California after December 31, 2002. Automotive consumer products containing Perc, MeCl or TCE manufactured on or before December 31, 2002 are not to be sold in California after June 30, 2004. The ATCM was based on staff’s evaluation of Best Available Control Technology. The staff concluded that alternative products that use non-chlorinated formulations and alternative processes such as aqueous-based portable brake cleaning units and parts washers are currently in use. The agency reports that 62 to 90 percent of automotive consumer products are non-chlorinated and that 60 percent of automotive repair and maintenance facilities use aqueous-based processes.

The requirement accounts for the detection limits of the prescribed test method by providing that a product is considered non-compliant, if it has one percent or more (by weight) of any of the three aforementioned toxic compounds (either alone or in combination). This provision also addresses the issue of inadvertent contamination that may occur when manufacturers convert a production line from one product formulation to another.

 

PHOSPHINE AND TRIETHYLAMINE RISK VALUES IN RULE 1401
SCAQMD Rule 1401—New Source Review of Toxic Air Contaminants includes a list of toxic compounds. The District adopted changes to Rule 1401, based on the Office of Environmental Health Hazard Assessment’s (OEHHA) updated chronic reference exposure levels for phosphine and triethylamine.

 

DATES TO REMEMBER
Hazardous Waste and Materials requirements—Effective January 1, 2003 new transport measures and loading/unloading requirements.

Polyester Resin Operations (Rule 1162)—Effective July 1, 2003 lower monomer contents for gel coats and resins as well as nonatomization requirements, vapor suppression and other alternative means of VOC reductions.

Solvent Degreasers (Rule 1122)—Effective January 1, 2003, 25 grams/liter or less VOC content for materials used in batch-loaded or conveyorized cold cleaners. Hazardous Air Pollutant halogenated solvents are only to be used in airless/air tight cleaning systems or approved alternative equipment.


Solvent Cleaning Operations (Rule 1171)—Effective January 1, 2003 VOC limits are lowered to 25 grams/liter for various cleaning categories such as: printing operations, surface preparation, repair and maintenance cleaning and polyester resin application equipment.

Emissions from Gaseous and Liquid-fueled Engines (Rule 1110.2)—By April 20, 2003 operators not choosing to replace engines with electric motors must submit applications for engine modification or add-on controls in order to comply with section (e)(1)(B) of the rule.

Control of Toxic Air Contaminants from Existing Sources (Rule 1402)—Effective March 17, 2003 industries listed in Table II of the rule (for example metal plating and wood furniture stripping) will be subject to 1402 requirements, if no source specific standards have been promulgated.

Film Cleaning and Printing Operations (Rule 1425)—By March 18, 2003 emissions of perchloroethylene from film printing equipment are to be reduced by 85%. Facilities can choose the alternative route of complying with emission levels specified in Table I of the rule.

Reclaim reports—January 1, 2003 through March 1, 2003 Annual Permit Emission Program report for Cycle I facilities. By March 31, 2003 Cycle II facilities (if subject to Rule 2009.1(e), as well as Cycle II power producing facilities are to submit annual update forecast report. By June 30, 2003 Cycle I facilities are to complete source testing on NOx sources for the period of 2000-2002. July 1, 2003 through August 29, 2003 Annual Permit Emission Program reports for Cycle I facilities. By November 30, 2003 Cycle II facilities [if subject to Rule 2009.1(e)], as well as Cycle II power producing facilities are to submit annual update forecast report.

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