Abate Technologies International, Inc.

ATI QUARTERLY
2nd QUARTER 2005

 

 

CHANGES TO DIESEL GENERATOR RULE PROPOSED

Rule 1470- Requirements for Stationary Diesel-Fueled Internal Combustion and Other Compression Ignition Engines- was originally adopted in April 2004. The South Coast Air Quality Management District recently adopted changes to the rule for consistency with the state’s Air Toxic Control Measure (ATCM). Rule 1470 is characterized by more stringent requirements than those of the ATCM, for engines located on school grounds or within 100 meters of existing schools. Affected industries include manufacturing, food processing and production, power generation, building management, hospitals, refineries, water treatment facilities, telecommunications, quarries, military installations and schools.

The amendments incorporate a prohibition of non-emergency operation of emergency engines on school grounds whenever school sponsored activities are taking place. At SCAQMD’s request, the California Air Resources Board clarified that “school sponsored activities” are those directly related to the school, including but not limited to, education of students (e.g. classroom education, physical education, outdoor education), sports teams (e.g. practices, games, school-sponsored tournaments), school events (e.g., open houses, performances, and exhibitions), and school sponsored clubs. Activities not considered include parks and recreation sports teams, community events, and weekend and after school programs. Renting and using facilities such as classrooms, auditorium, sports facilities and playing fields would not be considered as school sponsored activities. Additionally, emission limits for in-use emergency standby engines enrolled in a demand response program will become effective on January 1, 2006. Compliance requirements were modified to require reporting for emergency standby engines to include fuel used and amount of fuel purchased.

Rule 1470 also contains grant provisions for schools or school districts which own emergency standby engines on school grounds. To date, the District has awarded approximately $382,500 to schools to install Particulate Matter traps. The staff now recommends an additional $150,000 for the school grant program.

The ATCM allows engine operators with four or more engines model years 1989 and earlier, to bring 25 percent of the engines into compliance by January 1, 2007. The SCAQMD will retain the more stringent local compliance date of January 1, 2006 for this category of engines. Staff commented that “because Rule 1470 was adopted in April 2004, engine owners or operators will have 20 months to comply…….In addition, Rule 1470 provides flexibility to owners by allowing them to select which engines they would like to bring into compliance first.” Owners or operators of three or more engines will have to be in compliance by January 1, 2008 for all 1996 and later model year engines. The schedule for post-2007 model year engines has been removed.

The original effective date of April 2, 2004 for operating requirements and particulate matter emission standards for in-use emergency engines enrolled in a demand response program, prior to January 1, 2005, has been extended to January 1, 2006. Rule language relating to emergency engines operated in response to an impending rotating outage, was modified to allow operation “in anticipation of” a rotating outage. The same applies to engines enrolled in a demand response program (DRP). Under the amendments, DRP engines will not be allowed to operate outside control areas (electrical region that regulates its power generation) with impending power outages.

Recordkeeping, reporting and monitoring changes include:

  • Facilities will not need to re-submit records previously submitted to SCAQMD.
  • Reporting of type of fuel used is now required.
  • Reporting of amount of fuel purchased is now required.
  • Original reporting date of January 31, 2005 changed to February 1, 2005 for emergency engines used to fulfill the requirements of interruptible service contracts. The change is applicable for engines enrolled in interruptible service contracts prior to January 1, 2005.

Portions of the exemptions section of the rule were modified to ensure consistency with the state’s ATCM as follows:

  • The previous exemptions for training operations for the United States Air Force, United States Navy, United States Army and Unites States Department of Defense, have been collapsed into a general category for the United States Department of Defense.
  • Language pertaining to a “Request for Delay” in implementation (which can be filed prior to January 1, 2006) now includes a list of information required by the ATCM.

The changes were formally adopted by the South Coast Air Quality Management District Board at their March 4, 2005 meeting.

 

SOLVENT CLEANING UPDATE

The South Coast Air Quality Management District held a public workshop to discuss changes to their solvent cleaning rule (Rule 1171), some of which will become effective in July 2005. Industry representatives raised a variety of concerns in regards to the successful implementation of low Volatile Organic Compound (VOC) cleaners.

The District proposes to delay the compliance date for low VOC solvents for cleaning screen printing, lithographic/letterpress, and ultraviolet/electron beam ink application equipment and establish an interim VOC limit of 500 grams per liter of material for such cleaning applications. The added exemptions for cleaning of adhesive application equipment used for thin metal laminating operations allows facilities to use solvents containing up to 950 grams per liter VOC’s. A limit of 400 grams per liter applies to the cleaning of electronic or electrical cables. Additionally, the cleaning of metering rollers, dampening rollers and printing plates with solvents containing less than 800 grams per liter in VOCs, is exempt until June 30 2006.

The proposed changes would eliminate the exemption for solvents used to clean solar cells, laser hardware, scientific instruments, and high precision optics. The current exemption (originally granted until June 2005) for the cleaning of photocurable resins from stereolithography equipment and models will be extended to December 1, 2008.

The District staff has deemed methylene chloride and perchloroethylene as toxic air contaminants. In an effort to reduce these toxic emissions, the proposed rule will prohibit their use as of the date of adoption. It should be noted that the use of these substances may be allowed in other operations (e.g. solvent welding used to bond certain plastic fabrications as exempted in the District’s adhesives rule 1168). The public hearing for the proposed amendments is scheduled for May 6, 2005.

 

THERMAL SPRAYING REQUIREMENTS

Thermal spraying is a process by which materials are heated to molten or nearly molten condition and sprayed onto a substrate, thereby forming a coating. Thermal spraying is used in the manufacture of aerospace components, gas turbines, printing equipment, electronics and automotive parts. The technique is used for corrosion resistance, water resistance, as undercoats for paint and for electrical conductance.

The California Air Resources Board adopted an Air Toxics Control Measure to reduce exposure to hexavalent chromium and nickel from thermal spraying. Portable thermal spray operations are not subject to the ATCM. The SCAQMD has decided to implement the ARB requirements, rather than developing their own regulation.

The new ATCM requires that existing thermal spray coating operations install Best Available Control Technology and obtain permits (if they have not already done so) by January 1, 2006. Furthermore, existing facilities will be subject to a maximum nickel emission rate of 0.1 pounds per hour for sources with a stack (point sources) and 0.01 pounds per hour for sources without a stack (volume sources).

The ATCM requires new and modified facilities to install controls (HEPA filters) with a 99.97 percent efficiency. No new facilities are allowed to operate within 500 feet from the border of a residential or mixed use zone.

The SCAQMD estimates that 32 facilities may be subject to the new requirements. Staff reports that four of the five largest facilities appear to be located in industrialized areas, and one is located near a school. Public notices may be required in some cases.

 

CHANGES TO NEW SOURCE REVIEW RULE

The New Source Review regulation applies to new, modified and relocated sources in the South Coast Basin. In administrative changes to Rules 1304 (Exemptions) and Rule 1306 (Emission Calculations), the SCAQMD will clarify emissions calculation procedures for concurrent facility modifications.

A concurrent facility modification is a change at a facility, which results in an overall emission reduction. Under this scenario a facility submits an application for a new source and then (after application submittal) makes a change that results in an overall emissions decrease at the facility.

A facility can take advantage of the exemption for concurrent facility modification as long as the emission reductions are not:

  • Required by a control measure of the Air Quality Management Plan,
    1304 (c) (2) (A)
  • Required by a proposed District rule (this section applies after the first public workshop and 12 months thereafter), 1304 (c) (2) (B)
  • Required by an adopted federal, State or District mandate, 1304 (c) (2) (C).
  • From a class of equipment included in a demonstration project required by the District, 1304 (c) (2) (D).

Changes to Rule 1304 and 1306 clarify that the net emission change after modifications or equipment removal, is to be calculated based on the “post-modification potential to emit.” Thus, the equipment maximum rated capacity as well as the maximum daily or monthly hours of operation must be used.

 

SAND AND GRAVEL FACILITIES SUBJECTED TO PM REGULATION

Nearly 400 sand and gravel facilities in the Southland will be impacted by a new measure to reduce particulate matter (PM) emissions from those operations. “Sand and gravel-related operations in the Southland produce significant amounts of particulate pollution that can be both a nuisance to neighboring communities as well as a health threat,” said Barry Wallerstein, executive officer of the South Coast Air Quality Management District. The measure is expected to achieve emission reductions of 18 tons per day.

Requirements include:

  • A maximum opacity of 20 percent from dust emissions based on an average of 12 consecutive visual readings OR, 50 percent based on five consecutive visual readings.
  • Dust plumes shall not extend more than 100 feet from any emission source.
  • Application of dust suppressants or other dust control measures to conveyors, crushers, storage piles and other activities.
  • Depending on the facility’s size, paved roads will be swept daily or every other day.
  • Chemical stabilizers or gravel pads will be used for all unpaved roads, parking and staging areas.

-The amount of dust-causing materials tacked out of the facility by trucks onto public roadways must be mitigated (rumble gates and wheel washers are examples of mitigation measures)

The ruling (Rule 1157) became effective on January 7, 2005 and will take effect in two phases in July and December 2005. It will impact sand and gravel mining and processing operations, concrete batch plants and hot-mix asphalt plants.

 

PRESIDENT NOMINATES STEVE JOHNSON AS EPA ADMINISTRATOR

President Bush has nominated Steve Johnson as administrator of the Environmental Protection Agency (EPA). Mr. Johnson had been serving as Acting Administrator and has 24 years of experience with the agency. He is the first career EPA employee to hold the office of the Administrator.

In his new role, Mr. Johnson will lead federal efforts to ensure the security of the water supply. The budget includes a new program to monitor urban water systems and to detect water contamination. Mike Leavitt (the former EPA Administrator) will continue on as the Secretary of Health and Human Services.

 

COMPLIANCE DEADLINES HIGHLIGHTS

Continuous Emission Monitoring
By May 14, 2005 facilities are required to certify, in writing, that existing CEMS meets rule 218 requirements. Otherwise, an application with fees for CEMS modification or an application for waiver (with supporting documentation) is to be submitted.

Aerospace Assembly and Component Manufacturing Operations
A VOC limit of 710 grams per liter is now effective for non-spray rubber solution fuel tank coatings. This applies to fuel tanks with maximum capacity of 35 gallons at facilities using less than 150 gallons per year.

Wood Products Coatings
As of July 1, 2005 the exemptions for touch up and repair, alternative limits for wood shutters and exemption for classic guitars will expire. The VOC limits for all coating categories (except inks and mold-seal coatings) are decreased (generally to 275 grams per liter).

Adhesive and Solvent Applications
The VOC limits for PVC welding, CPVC welding, Plastic Cement Welding, Adhesive Primer for Plastic, and Top and Trim Adhesive are decreased. Prohibitions of sales are now applicable to solvent welding formulations containing methylene chloride used to bond hard acrylic, polycarbonate, and polyethylene terephalate glycol plastic fabrications.

 

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