Abate Technologies International, Inc.

ATI QUARTERLY
3RD QUARTER 2001

 

 

AQMD ANNUAL EMISSIONS REPORTS

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;

- Facilities emitting 4 tons or more per year of criteria pollutants (VOCs, NOx, SOx, CO, PM, Specific Organics);

- Facilities which had emissions of specific Toxic Air Contaminants or ozone depleting compounds listed in form TAC;

- Facilities that receive a 2000-2001 Annual Emissions Report Package.

What if I miss the deadline?

The SCAQMD 2000-2001 Annual Emissions Report is due August 31 of this year. If a facility misses the deadline and owes an emission fee, 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)(8)(B) and are as follows:

Payment received
Less than 30 days after 8/31/01
30 to 90 days after 8/31/01
91 days to 1 year after 8/31/01
More than 1 year after 8/31/01

Penalties
5% of fees due
15% of fees due
25% of fees due
50% of fees due


After submitting my report I found out I estimated emissions incorrectly:
Companies who pay their emissions fees on time but underestimated their emissions, which resulted in underpayment to SCAQMD, can re-submit the report subject to underpayment penalties. If the underpayment is corrected within one year from the filing deadline and more than 90% of the amount due was paid, there are no penalties. However, if payment was less than 90% of the amount due, the penalty is 15% of the underpayment amount. When the underpayment is determined more than one year after the deadline, a 50% penalty applies.

A facility can file a refund request when overestimating of the emissions resulted in overpayment to AQMD. The refund request must be submitted in writing as set forth in Rule 301. Form A can also be used to request refunds associated with the current reporting period.

Special circumstances:
In some cases, facilities may be able to avoid late penalties even if they file a late emissions report. The AQMD has a Fee Review Committee to handle appeals, extensions and other special situations. When requesting an exemption from late penalties, it is important to provide all relevant documentation to support the validity of the request.
EMERGENCY GENERATORS REQUIREMENTS MODIFIED


Emergency generators normally have a 200 hours per year operation limit under AQMD rule 1110.2. In light of the energy crisis, the agency issued an executive order, which extends the annual operation time. The District Executive Officer exercised the discretion afforded to him under Rule 118, which allows for suspension of AQMD rules in response to a state of emergency declared by the state or federal government. The Governor made such declaration in January of this year. The District's executive order, which only lasts for 10 days, is being continually renewed as the energy crisis continues.

The executive order allows emergency generators at hospitals, police stations, firehouses and other essential public services to operate up to 500 hours in a calendar year, during an imminent or actual power blackout.

The District will also approve applications submitted by any emergency generator operator that is not an essential public service to allow operation for up to 200 hours per year.

The California Air Pollution Control Officers Association (CAPCOA) has estimated the air quality impact of emergency generator (most of which are diesel fueled) use during rolling blackouts and load shedding. Nitrogen Oxides (NOx) and diesel particulate matter (diesel PM) are principally the contaminants of concern.

CAPCOA estimates that there are 5,500 stationary and 2,380 portable engines in the South Coast District. Different scenarios were used to gain a sense of the magnitude of the emissions:

Scenario
Number of engines in use
NOx emissions
PM emissions
Rolling blackout; 25% of engines operate 2 hours per day
1,375
11.6
tons/day
0.64
tons/day
Rolling blackout; 100% of engines operate 4 hours per day
5,500
93
tons/day
5.1
tons/day
Load shedding; 100% of engines operate 150 hours per year
5,500
3,476
tons/year
194
tons/year

In comparison to gas turbines, diesel fueled engines can generate up to six hundred (600) times the amount of NOx per Megawatt-hour produced. The total NOx daily emissions for RECLAIM sources are 43 tons per day. Emergency generators can potentially emit 26 tons of NOx per hour. Thus, during a couple of hours of operation, the emissions from emergency generators could surpass the daily emissions form all RECLAIM sources combined. Based on these figures, CAPCOA reports that air quality would suffer as a result of emergency generator use.
AQMD RULE 222 FILING REQUIREMENTS FOR BOILERS, ETC.
Rule 222 "FILING REQUIREEMTNS FOR SPECIFIC EMISSION SOURCES NOT REQUIRING A WRITTEN PERMIT PURSUANT TO REGULATION II" is an alternative to obtaining an SCAQMD permit. Some sources which currently do not need a District permit (exempted under Rule 219) may be subject to Rule 222 (see table below).
Source subject to Rule 222
Compliance date
Boilers & Process Heaters with a rated heat input capacity from 1,000,000 to 2,000,000 (RECLAIM facilities excluded)
1/1/01
Charbroilers
1/1/99
Negative Air Machines (Asbestos)
1/1/99

Facilities subject to the rule will need to submit the following information to the District:
-Description of the source and any associated air pollution control equipment
-Emissions data
-Information to determine compliance with District, state and federal rules
For changes of location or changes of ownership/operator a new filing is required prior to operating the equipment. The filing should include:
-Hours of operation
-Materials used or processed
-Fuel usage
-Throughput
-Operating parameters

The rule allows for a one year grace period for those sources installed prior to the compliance dates. For boilers the compliance date was January 1 2001. Therefore, owners/operators of boilers will have to submit the filing by January 1, 2002.
CHANGES TO RECLAIM PROGRAM

Prompted by the power crisis, SCAQMD recently amended the RECLAIM rules. The District's intent is to grant "additional flexibility to power plants so they can help meet the tremendous demand for energy" according to Board Chairman William Burke. "In return, power plants will be put on a fast-track schedule to reduce their emissions by installing state-of-the-art pollution controls" commented Burke. The District reported that between 1994 and 1999, NOX emissions for RECLAIM facilities were below allocations, with relatively stable RECLAIM Trading Credit (RTC) prices. In 1999, RECLAIM facilities began experiencing increases in RTC prices. The increase was a result of a soaring demand for power generation. The electric power industry purchased a large quantity of RTC's thereby depleting the RTC's available to the rest of the RECLAIM universe.


Specifically, AQMD made the following changes to the RECLAIM rules:
  • Existing large power plants (> 50 megawatts) will be separated from the rest of the RECLAIM market until 2003. In July 2003, the District will hold a hearing to determine whether or not these facilities should re-enter the RECLAIM universe. These facilities will have to submit compliance plans. Best Available Retrofit Control Technology (BARCT) will be required by 2003 for boilers and 2004 for turbines.
  • Compliance plans will also be required for facilities generating less than 50 megawatts which have emissions greater than or equal to 50 tons per year.
  • Informational forecast reports will be required for facilities emitting between 25 and 50 tons of pollutants per year. These reports must be updated annually.
  • Power plants will pay mitigation fees of $7.50 per pound of pollutant (in excess of their allocations)
    AQMD will create a "mitigation fund" enabling them to use the money to reduce pollution in other areas. Tug boats, yard hostlers used to move containers in shipping yards, trash trucks and agricultural water pumps are some of the areas being considered to produce emission reductions.
  • New power plants will have access to mobile and area source credits via a temporary pilot RECLAIM Air Quality Investment Program. Facilities that participate would pay $7.50 per pound of NOx to use the RECLAIM AQIP, if reductions are available.
  • The rule includes registration requirements for pooled trading and contractual agreements for future transfer of RTC's. This requirement was included to improve registration and reporting of RTC trades.
  • Procedures for late electronic reports will be modified.
  • New peaking generation units capable of beginning operation by September 1, 2001, will have access to the credits in the Emission Reduction Credit bank.
In response to business community concerns, the compliance plans will only be locally enforceable. The plans will not be part of the Title V program or the State Implementation Plan.

District staff plans to expedite review of compliance plans and report to the Governing Board in November of 2001 on projected emission reductions, schedule and impact on overall program compliance. At that point, the Board may take further action to improve the program.

CARB EXAMINES INDOOR AIR

The California Air Resources Board (ARB) is considering setting standards to reduce indoor sources of volatile organic compounds (VOC's). During their most recent board meeting, ARB staff provided a summary of findings presented at a symposium entitled "Indoor Air Quality: Risk Reduction in the 20th Century." Staff reported that indoor sources account for up to 98 percent of exposure to many VOCs. Kirk Smith--UC Berkeley professor-estimates that a typical pollutant released indoors is 1,000 times as effective in causing human exposure as the same release to urban outdoor air.

 

CALIFORNIA MAY PROPOSE FORMALDEHYDE STANDARD FOR WOOD PRODUCTS

Prompted by recent symposium findings that state level leadership and solutions are sorely needed, ARB is in the process of evaluating methods to reduce formaldehyde exposure. Staff determined that formaldehyde emissions from composite wood products are key contributors to an individual's exposure to formaldehyde. They are currently developing an Air Toxics Control Measure to limit the emissions from formaldehyde-containing composite wood products. Staff plans to form a working group and hold a public workshop and have a proposal before the board by the summer of 2002.

 

NEW REQUIREMENTS FOR DEGREASERS
Rule 1122 is applicable to Solvent Degreasers and regulates the removal of contaminants from parts, products, tools, machinery, and equipment. The rule currently establishes VOC limitations for batch loaded cold cleaners, open-top vapor degreasers, conveyorized degreasers, and air tight and airless cleaning systems that carry out solvent degreasing operations.

The SCAQMD is considering various changes to the rule. The new proposed rule would regulate, NESHAP halogenated solvent cleaners (methylene chloride, carbon tetrachloride, chloroform, perchloroethylene, trichloroethylene, and 1,1,1-trichloroethane). The use of airless or airtight cleaning systems for NESHAP halogenated solvents, and for open-top vapor degreasers would be required by July 2003. The District also proposes to lower the material VOC limit for cold cleaners from 50 grams/liter to 25 grams/liter by 2005.

Changes include the addition of an exemption for film cleaning and printing equipment that use perchloroethylene to process motion picture films.


UPCOMING STATE LEGISLATION FOR GREENHOUSE EMISSIONS
Rule 1122 is applicable to Solvent Degreasers and regulates the removal of contaminants from parts, products, tools, machinery, and equipment. The rule currently establishes VOC limitations for batch loaded cold cleaners, open-top vapor degreasers, conveyorized degreasers, and air tight and airless cleaning systems that carry out solvent degreasing operations.

The SCAQMD is considering various changes to the rule. The new proposed rule would regulate, NESHAP halogenated solvent cleaners (methylene chloride, carbon tetrachloride, chloroform, perchloroethylene, trichloroethylene, and 1,1,1-trichloroethane). The use of airless or airtight cleaning systems for NESHAP halogenated solvents, and for open-top vapor degreasers would be required by July 2003. The District also proposes to lower the material VOC limit for cold cleaners from 50 grams/liter to 25 grams/liter by 2005.

Changes include the addition of an exemption for film cleaning and printing equipment that use perchloroethylene to process motion picture films.

UPCOMING STATE LEGISLATION FOR GREENHOUSE EMISSIONS
Currently, greenhouse emission reductions which occurred after 1990 are registered and recorded by the California Action Registry-a public nonprofit organization. Earlier this year, democratic senator Byron Sher introduced a bill (Senate Bill 532) to amend the existing law. Thus far, the bill has seen two amendments, the most recent taking place on May 15, 2001.

The proposed changes include: (1) adoption of bylaws to ensure public participation (2) recognition of the procedures established by the registry as the sole procedures for monitoring, reporting, and verifying greenhouse gas emissions by the state (3) development of specific guidance to assist registry participants.

The bill attempts to encourage, not mandate, voluntary reductions of greenhouse gas emissions from California sources. Organizations that voluntarily reduce their greenhouse emissions would receive appropriate considerations for emissions reductions made prior to the implementation of any mandatory program.

A seven-member board of directors would govern the registry and appoint an executive director who would hire and direct staff. The registry will design programs to establish emission baselines and to monitor and track greenhouse gas emissions. It will also establish emission reduction goals based on "international best practices for specific industries and economic sectors."

Companies who choose to participate in this program must report their actual emissions for the most recent year (after January 1, 1990) for which they have complete energy use and fuel consumption data. After a baseline is established, the participants will report emissions in each subsequent year to record changes in emissions. The emissions will be expressed as follows:

    1. Private corporations and cooperatives (except electric generators): Report carbon dioxide emissions per dollar of revenue.
    2. Electric generators: Report carbon dioxide emissions per kilowatt-hour.
    3. Non-profit organizations and governmental agencies: Report carbon dioxide emissions per dollar of budgetary expenditure plus amortized capital expenditure
Participants will need to report direct and indirect emissions including emissions from onsite combustion, fugitive non-combustion emissions and emissions resulting from offsite steam generation.

In addition to carbon dioxide emissions, the registry would encourage participants to monitor methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons and sulfur hexafluoride.

SB 532 passed with a majority vote in the Senate and currently awaits the governor's signature.

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