Abate Technologies International, Inc.

ATI QUARTERLY
3rd QUARTER 2002

 

AQMD ANNUAL EMISSIONS REPORTS
POTENTIAL FEE INCREASE FOR STATIONARY SOURCES
CHANGES TO SOLVENT CLEANING RULE (Rule 1171)
RETROFITS FOR ELECTRICAL GENERATION FACILITIES
TITLE V REPORTS
NEW REQUIREMENTS FOR SOUTHERN CALIFORNIA DRYCLEANERS

 

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 2001-2002 Annual Emissions Report Package.


What if I miss the deadline?

The SCAQMD 2001-2002 Annual Emissions Report is due on August 30, 2002. 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 Penalties
Less than 30 days after 8/31/02 5% of fees due
30 to 90 days after 8/31/02 15% of fees due
91 days to 1 year after 8/31/02 25% of fees due
More than 1 year after 8/31/02 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.

 

New changes

Beginning with the reporting period of 2001-2002, and thereafter, all facilities with emissions greater than or equal to 4 tons per year (100 tons per year for Carbon Monoxide) will start to pay fees for non-permitted emissions, in addition to the permitted emissions fees. The fee will be phased in over a three year period and the calculation will be as follows:

Fiscal Year
Total Facility Emissions for Emissions Fee Calculation
2001-2002 Permitted + 33% of total Non-permitted
2002-2003 Permitted + 66% of total Non-permitted
2003-2004 and later Permitted + 100% of total Non-permitted

Each facility with at least one permit will be assessed a flat annual emission fee of $75 for FY 2002-2003 and after. These facilities have been billed $37.50 for 2001-2002.

 

CHANGES TO SOLVENT CLEANING RULE (Rule 1171)

In 1999 the SCAQMD adopted changes to their solvent cleaning rule, setting future limits for various cleaning categories. The reduction in VOC content was structured in two phases. The first reduction took place in 2001, while the second phase was scheduled to occur on July 1, 2005. The District is currently proposing to lower VOC content limits for various cleaning operations two years ahead of schedule.

The main changes consist of advancing the compliance date (originally July 1, 2005) to January 1, 2003. The cleaning materials will be required to have a VOC content of 25 grams/liter or less for the following categories:

  • General product cleaning and surface preparation
  • General repair and maintenance cleaning.
  • General cleaning of ink application equipment
  • Cleaning of flexographic and gravure printing (packaging) ink application equipment.
  • Cleaning of removable press components in lithographic or letterpress printing
  • Cleaning of polyester resin application equipment

The date for the exemption on the cleaning of photocurable resins for stereolithography equipment and models will be changed from June 30, 2005 to December 31, 2003.

In addition, a new definition for electron beam inks is being added and the existing definition for field handwipe cleaning is being removed. Language has been added to require solvent-laden cloth and paper to be stored in "closed, non-absorbent, non-leaking containers."

Staff is also proposing to add rule language that will require compliance with the state's Airborne Toxic Control Measure for Emissions of Chlorinated Toxic Air Contaminants from Automotive Maintenance and Repair Activities. The ATCM is contained in Title 17 of the California Code of Regulations, section 93111. It applies to chlorinated compound emissions from the use of automotive consumer products during automotive maintenance and repair activities.

The District estimates that the proposed changes will achieve a total VOC emission reduction of 1.94 tons per day in 2003. The amendments are scheduled for adoption in August 2002.

 

TITLE V REPORTS

Facilities under the TitleV program are subject to specific monitoring and reporting requirements. These are delineated in the facility permit under the heading "Section K: Title V Administration." Operators are to submit reports of any required monitoring to the AQMD at least twice per year.

These reports must include:

  1. A statement whether all monitoring required by the permit was conducted; and
  2. Identification of all instances of deviations from permit or regulatory requirements.

    A report covering the first six calendar months of the year is due by August 31 and one for the last six calendar months of the year is due by February 28 of the following year. These reports must be submitted to the AQMD and EPA.

    Facilities must also submit an annual compliance certification to both the SCAQMD and the Environmental Protection Agency (EPA). For RECLAIM facilities, the certification is due when the Annual Permit Emissions Program report is due and is to cover the same reporting period. For non-RECLAIM sources, the certification is due on March 1 for the previous calendar year. Each compliance certification is to include:

    • Identification of each permit term or condition that is the basis of the certification
    • The compliance status during the reporting period
    • Whether compliance was continuous or intermittent
    • The method(s) used to determine compliance over the reporting period
    • Any other facts required to determine compliance

Additionally, reports for breakdowns or other deviations from permit or rule emission limitations are to be submitted. Unless otherwise specified, the deviations must be reported within 72 hours of discovery by contacting the SCAQMD. A written report of these deviations and any corrective actions or preventative measures taken, is to be submitted to AQMD within 14 days of discovery of the deviation

 

POTENTIAL FEE INCREASE FOR STATIONARY SOURCES

Earlier this year, Governor Davis released his draft budget proposal, after which the Legislative Analyst's Office reported an estimated shortfall of $5 billion. The LAO report included recommendations to the legislature and state departments on how to cover the shortfall. The report estimated a savings of $18.7 million to the General Fund if the California Air Resources Board (CARB) were to levy fees on stationary sources of pollution. Thus, the funding from the General Fund would be replaced.

The recommendation before the legislature is to enact legislation to apply the "polluter pays principle." The changes would be implemented by CARB through their Stationary Source program. Of the $18.7 million estimated to replace funding from the General Fund, approximately $8.1 million would be assessed in the South Coast Air Basin. Three scenarios are under consideration:

Scenario #1 Assessment of fees on sources emitting 25 tons per year or greater. Approximately 216 facilities would be impacted. These facilities currently pay an estimated $17 million in emissions fees. The proposed fee would result in a 48 percent increase in fees for these sources.
Scenario #2 Assessment of fees on sources emitting 4 tons per year or greater. Approximately 1,500 facilities would be impacted. These facilities currently pay an estimated $21 million in emission fees. The proposed fee would result in a 38 percent increase in fees for these sources.
Scenario #3 Assessment of fees on all facilities in the basin that pay emissions fees and annual operating fees. Approximately 26,000 facilities would be impacted. These facilities currently pay an estimated $47 million in emission fees. The proposed fee would result in a 17 percent increase in fees for these sources.

SCAQMD staff has recommended opposition to the concept of a fee increase, citing a concern "about the potential unintended consequences of increased fees on local sources to fund the state's stationary source program."

 

RETROFITS FOR ELECTRICAL GENERATION FACILITIES

Governor Davis has recently signed Senate Bill 28X which directs the Air Resources Board to establish a process for dealing with retrofits at electrical generation facilities. The new requirements apply to 1 Megawatt or greater units (all fuel types). These include:

  • Reciprocating engines
  • Boilers
  • Turbines

The following table summarizes information in the current ARB power plant database.

TYPE
NO. OF UNITS
MW
Turbine
428
13,153
Boiler
188
21,786
Internal Combustion Engine
200
245

The ARB has identified several retrofit NOx controls that can achieve NOx limits ranging from 2.5 to 25 parts per million.

 

NEW REQUIREMENTS FOR SOUTHERN CALIFORNIA DRYCLEANERS

There are approximately 2,200 drycleaners in the SCAQMD. The majority of which use perchloroethylene (PERC). The SCAQMD is proposing amendments to Rule 1421 "Control of Perchloroethylene Emissions from Dry Cleaning Systems" which would prohibit the use of PERC machines.

Within three years of the rule adoption 1) the use of converted equipment (these have the highest PERC emissions) would be banned 2) all replacements of existing PERC equipment must be non-PERC systems and 3) all PERC equipment that is 15 years old must be replaced with non-PERC counterparts. Effective January 1, 2003, any new machines must also be non-PERC.

Compliant alternatives include: wet cleaning, petroleum solvent, volatile methyl siloxane, glycol ether and carbon dioxide systems.

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