Abate Technologies International, Inc.

ATI QUARTERLY
3rd QUARTER 2012

 

GREENHOUSE GAS POLICIES ARB AMENDMENTS TO VERIFICATION PROCEDURE RELATED TO DIESEL ENGINES

 

RULE 1147—NOX REDUCTIONS FROM MISCELLANEOUS SOURCES

South Coast Air Quality Management District (AQMD) Rule 1147 (Nitrogen Oxides Reduction from Miscellaneous Sources) applies to small and medium size combustion equipment using gaseous or liquid fuels that require an AQMD permit. This includes ovens, dryers, dehydrators, heaters, kilns, calciners, furnaces, crematories, incinerators, heated pots, cookers, roasters, fryers, closed and open heated tanks and evaporators, distillation units, afterburners, degassing units, vapor incinerators, catalytic or thermal oxidizers, absorption chillers, soil and water remediation units. Rule 1147 does not apply to combustion equipment operated at RECLAIM facilities and to boilers, steam generators, process heaters and water heaters subject to AQMD Rules 1146, 1146.1 or 1146.2.
Some of the requirements of the rule took effect July 1, 2012. Units emitting less than 1 pound per day were given until 2017 to comply. The AQMD reports that a technology assessment is underway, which includes a review of 2,700 permits. A public workshop is expected in summer 2012.

 

REGULATIONS FOR FORKLIFTS AND OTHER INDUSTRIAL EQUIPMENT

Off-road Large Spark Ignition (LSI) engines (> 25 HP) powering forklifts and other industrial equipment are regulated by the ARB. Operators of gasoline, propane, or compressed natural gas-fueled equipment are subject to the rule. ARB fleet requirements impact 4 types of equipment: 1) forklifts 2) sweepers/scrubbers 3) industrial tugs (tow tractors) and 4) Ground Support Equipment.
By 1/1/2013 the requirements for (HC + NOx), depending on the size of the fleet, are as follows:

  • Large forklift fleet (26+ units): 1.5 grams/kw-hr (or 1.1 grams/bhp-hr)
  • Mid-size forklift fleet (4-25 units): 1.9 grams/kw-hr (or 1.4 grams/bhp-hr)
  • Non-forklift fleet (4+ units): 3.4 grams/kw-hr (or 2.5 grams/bhp-hr)

There are exemptions for the following:

  • Fleets with one to three pieces of forklift and/or non-forklift equipment;
  • Operators of agricultural crop preparation services fleets (do not have to meet the fleet averages either, but must address their uncontrolled 1990 and newer LSI forklifts through retrofit);
  • In-field agricultural forklifts;
  • Equipment that is leased or rented for a period of no more than 30 aggregated calendar days per year (exempt from the fleet average requirement);
  • Equipment that is leased or rented for more than 30 days but less than one year may be excluded subject to specified conditions.

Compliance options include reducing fleet average by phasing out uncontrolled equipment; retrofitting (available for 1990 and newer model year engines), repowering with a complying engine, or replacement with a new or used controlled piece of equipment. Fleets may also incorporate zero-emission equipment (such as electric forklifts), where feasible.

 

AMENDMENTS TO COMPOSITE WOOD PRODUCTS ATCM

In 2007 the California Air Resources Board (ARB) adopted the Airborne Toxic Control Measure (ATCM) to regulate formaldehyde emissions from composite wood products including:

  • Hardwood plywood
  • Particleboard
  • Medium density fiberboard
  • Thin medium density fiberboard (thickness ≤ 8mm)
  • Furniture and other finished products made with composite wood products

The ATCM applies to panels or finished goods that are "sold, supplied, offered for sale, used or manufactured for sale in California." The ATCM is comprised of two phases. Phase I requirements went into effect back in 2009. The more stringent Phase II requirements began taking effect in 2010 with some portions taking effect in 2012. The following table summarizes the requirements:

Category Limit in parts per million of Formaldehyde
Hardwood Plywood—Composite Core 0.05
Hardwood Plywood—Veneer Core 0.05
Particle Board 0.09
Medium Density Fiberboard 0.11
Thin Medium Density Fiberboard 0.13

The proposed changes include:

  • Retaining the current exemption for curved plywood and adding an exemption for plywood with lumber core;
  • Exempting packaging materials;
  • New requirement for manufacturers to label each panel produced;
  • Specifying that bar codes cannot be sole form of labeling;
  • Requiring fabrication date to be month/year format;
  • Requiring finished goods made with "No Added Formaldehyde" resins or "Ultra-Low Emitting Formaldehyde" resins be labeled as such;
  • Requiring Third Party Certifiers to report steps taken if exceedances occur;
  • Recordkeeping of background concentrations of formaldehyde measurements and additional annual reporting requirements;

ARB staff estimates that the proposal will be considered by the board for adoption in late 2012 or early 2013.

 

ARB REQUIREMENTS FOR MULTI-PURPOSE LUBRICANTS OR PENETRANTS

ARB regulates multi-purpose lubricants or penetrants under the consumer products regulations. A "Responsible party" or formulator of a Multi-Purpose Lubricant or a Penetrant product that was sold for use in California during calendar year 2011 is required to submit reports to ARB. The due date for the 2011 report was June 26, 2012.

Responsible parties are also required to provide a written update of the research and development efforts undertaken to achieve the 25 percent by weight VOC limit for these products scheduled to become effective on December 31, 2013. ARB will use the data to assess the feasibility of a 25 percent by weight volatile organic compound (VOC) limit.

 

RULE 1107—COATING OF METAL PARTS AND PRODUCTS

South Coast Air Quality Management District Rule 1107 applies to metal coatings operations other than those performed on aerospace assembly, magnet wire, marine craft, motor vehicle, metal container, and coil coating operations. Typical facilities include metal furniture manufacturers, fabricated metal product manufacturers, small and large appliance manufacturers, metal finishers and the paint and coating manufacturers that supply products to the metal manufacturing shops.

There have been new proposals included in the draft rule. The definition for Extreme-Performance coating has been expanded to include multi-substrate metal and carbon composite surfaces and other operations approved by the Executive Officer. A standard for heavy abrasion has been included and the requirement for facilities to apply for approval to utilize this provision has been modified to apply only to those requiring Executive Officer's approval. Shops that qualify under one of the specified applications will no longer need to apply for approval beforehand.
Also, the definition for Extreme High-Gloss coating has been modified to require a higher reflectance, 95 instead of 75. In addition, a new category, "High-Gloss" has been included for coatings with reflectance between 75 and 95.

Super-Compliant Material was included in the definitions to streamline recordkeeping provisions. Super-Compliant Material will apply to metal coatings with a material VOC content of 50 grams per liter or less. A limited exemption will be included for coatings containing dimethyl carbonate (DMC) and tertiary-butyl acetate (t-BAC). A newly approved test method (ASTM D 7767-11) will be listed for thin film Ultraviolet/Electron Beam coatings. (For additional details please see article in ATI Newsletter for the Third Quarter 2011).

 

RULE 1110.2-- EMISSIONS FROM GASEOUS AND LIQUID-FUELED ENGINES

Rule 1110.2 regulates oxides of nitrogen (NOx), carbon monoxide (CO), and volatile organic compound (VOC) emissions from liquid and gas fueled internal combustion engines operating in the AQMD producing more than 50 rated brake horsepower (bhp). The rule applies to stationary and portable reciprocating internal combustion engines (ICEs) over 50 brake horsepower (bhp) and affects the subset that contains engines fueled with biogas, which are those that are operated by landfills and wastewater treatment plants.

The concentration limits and compliance schedule for landfill and digester gas (biogas)-fired engines will be:
NOx: 11 PPM by volume (corrected to 15% oxygen on a dry basis and averaged over 15 minutes)

VOC: 30 PPM by volume (measured as carbon, corrected to 15% oxygen on a dry basis and averaged over the sampling time required by the test method)

CO: 250 PPM by volume (corrected to 15% oxygen on a dry basis and averaged over 15 minutes)

The changes provide a compliance option with a longer averaging time to engine operators that can demonstrate through continuous emission monitoring systems (CEMS) data mass emission levels at least 10 percent lower than allowable under the rule's proposed concentration limits for NOx and CO. The longer averaging time would be allowed provided that the CEMS data routinely shows emission levels below 11 ppm for NOx and below 250 ppm for CO.

 

GREENHOUSE GAS POLICIES
On the Federal Side:

The Environmental Protection Agency proposed a carbon pollution standard for new sources. The limit of 1,000 pounds of carbon dioxide per MW-hour would apply to new fossil fuel- fired boilers and integrated gasification combined cycle.

On the State Side:

ARB staff is recommending the prioritization of "short-lived climate forcers" (carbon black and methane) for policy making. The current GHG program is expected to be "scaled-up" with more stringent requirements. ARB is also looking at harmonizing California's program with Quebec's Cap-and-Trade program by implementing changes to the tracking system and certain policies.

The agency recently proposed amendments to the greenhouse gas emissions Cap-and-Trade program and market-based compliance mechanisms. The proposed amendments include detailed "Know Your Customer" (KYC) requirements for information gathering during registration. The regulation will limit registrants to individuals with a primary residence in the United States to enhance the ability of ARB to enforce the regulation. Rules for a first auction on November 14, 2012 were presented. Staff also included additional amendments to the regulation to implement the allowance and offset registry, market monitoring provisions of the regulation and collection of information necessary for the financial services operator.

ARB will now be responsible for tracking information regarding compliance instrument ownership, including transfers of ownership. The proposed regulation will require entities to register with ARB and provide information to the agency regarding ownership and submittal of compliance instruments. ARB will also require reporting information regarding certain transactions between market participants. Some participants submitting information could be entities that do not have compliance obligations or that are not located within California.

 

ARB AMENDMENTS TO VERIFICATION PROCEDURE RELATED TO DIESEL ENGINES

The ARB held a public workshop to discuss the proposed amendments to the Verification Procedure, Warranty, and In-Use Compliance Requirements for In-Use Strategies to Control Emissions from Diesel Engines. The Verification Procedure is used by ARB to evaluate diesel emission control strategies and determine their suitability for use by regulated fleets. Under the guidance of the Verification Procedure, emission control manufacturers perform emissions, durability and field testing to quantify emission reductions and validate the durability of their retrofit strategies. Manufacturers of verified control technologies are required to conduct in-use testing using devices that have been in operation for a prescribed period of time, once a predetermined sales threshold has been reached. Any control technologies used to satisfy the requirements of ARB's in-use fleet rules must be verified under the Verification Procedure.

New changes include:

  • Additional changes to the in-use compliance testing requirements, including specifying when testing is required and providing a new in-field testing option;
  • New recall provisions;
  • Changes to the pre-installation compatibility assessment provisions, including additional requirements for installers of verified control strategies;
  • Clarification of the definition of a warrantable event and revised warranty reporting requirements;
  • Changes to the backpressure monitoring requirements for filter-based diesel emission control strategies;

Staff estimates the changes will be brought to the board for adoption later this year.

 

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