Abate Technologies International, Inc.

ATI QUARTERLY 3rd QUARTER 2017

 

NEW CHANGES TO RULE 1147 - NOX REDUCTIONS FROM MISCELLANEOUS SOURCES BACT GUIDELINES
CHANGES TO ADHESIVES RULE RULE 219/222 AMENDMENTS
EXEMPTION for tBAc FEE INCREASES APPROVED

 

NEW CHANGES TO 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, and 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.

Under the rule, regulated equipment must meet an emission limit of 30 to 60 parts per million (ppm) of NOx based on the type of equipment and process temperature. Compliance dates for emission limits are based on the date of equipment manufacture and emission limits are applicable to older equipment first. Rule 1147 also establishes test methods and provides alternate compliance options including a process for certification of equipment NOx emissions through an approved testing program. Other requirements include equipment maintenance and recordkeeping.

Since its inception, the rule has generated strong opposition from businesses, ranging from auto body shops to crematories, who argued the requirements were not cost effective and may result in them going out of business. In 2011, SCAQMD adopted amendments to "delay compliance dates, provide alternative compliance options, clarify requirements for small units, reduce testing requirements and require a technology assessment for small sources." Food products preparation, printing, textile processing, product coating and material processing were some of the affected categories. Staff estimated that approximately 5,000 units in 2,200 facilities were expected to require retrofit of burners in their equipment.

In 2016, the "Draft Technology Assessment for Rule 1147" which was conducted by a third party, was released. The assessment identified the affected types and numbers of equipment and burners, emission characteristics, cost effectiveness of replacing old burners and recommendations regarding changes in emission limits. SCAQMD staff is now proposing to amendments to Rule 1147, including but not limited to:

  • Remove the requirement to comply with an emission limit for units with a heat input rating of less than 325,000 Btu/hour [Table 1, (c)(1)]. These units would still be subject to maintenance and recordkeeping requirements;
  • Change the NOx emission limit for low temperature afterburners, burn-off ovens, incinerators, and related equipment from 30 ppm to 60 ppm [ Table 1, (c)(1)];
  • Change the compliance date for small in-use units (with NOx emissions of less than one pound per day) from a schedule based on a 20 year lifetime to a 30 year lifetime or when the units are replaced or retrofitted [ (c)(1) and (c)(6)];
  • Change the compliance date for existing in-use heated process tanks and pressure washers from a schedule based on a 15 to 20 year lifetime to when the units are replaced or retrofitted. These units would not be required to comply with an emission limit at any
  • pecific age and may be relocated with a facility move [(g) (8) and (g)(11)];
  • Add a testing exemption for ultra-low NOx infrared burners [(g) (9)];
  • Provide compliance flexibility for low emission units by clarifying options for demonstrating emissions less than one pound per day [ (c)(6)];
  • Add an exemption for units with emission less than 1 pound per day when a company relocates a facility and remains under the same ownership [(g) (11)];
  • Add an exemption for units that become subject to the rule upon amendment of Rule 219 [(g) (10)];

The public hearing, originally scheduled for June 4th, was moved to July due to a disturbance caused by protesters on a different issue.

 

BACT GUIDELINES

At the December 2016 Governing Board meeting, the Board approved amendments to the BACT Guidelines to make them consistent with recent changes to SCAQMD rules and state and federal requirements, as well as establishing a charter for the BACT Scientific Review Committee. The Board also directed staff to continue work on updating the BACT Guidelines, reviewing BACT determinations done by other air districts with an emphasis on UV/EB inks and coatings technology and report back to Stationary Source Committee by June 2017. Staff is proposing new listings in the major source classification for:

  • Furnace (Heat Treating Aluminum ≤ 900F)
  • Food Ovens (Bakery, tortilla chip, snack food)
  • Flares (Landfill, biogas)
  • Boilers

Inks used in flexographic printing at non-major facilities (Part D of the Guidelines) will need to have a VOC content of 1.5 pound per gallon (lb/gal) or less; or employ Ultraviolet/Electron Beam (UV/EB) or water based inks and comply with District rules 1130 (Graphic Arts) and 1171 (Solvent Cleaning). Regenerative thermal oxidizer with a destruction efficiency of at least 95% is being added to the listing for flexographic printing. The option to use of UV/EB and waterborne coatings is also being added to the Screen Printing section of Part D. The use of a regenerative thermal oxidizer with 99% overall control is being added for Lithographic Printing (Offset or Heatset).

Listings for Internal Combustion Engines include:

Stationary, Non-Emergency Electrical Generators, ≥ 50 brake horsepower (Compliance with Rule 1110.2, Rule 431.1 and Rule 1470)

Stationary, Non-Emergency Non-Electrical Generators, ≥ 50 brake horsepower
(Compliance with Rule 1110.2, Rule 431.1 and Rule 1470)

 

CHANGES TO ADHESIVES RULE

The South Coast Air Quality Management District (SCAQMD) is proposing changes to Rule 1168 (Adhesives). The rule applies to any "person who sells, stores, supplies, offers for sale or manufactures for sale" any adhesives, adhesive bonding primers, adhesive primers, caulks, sealants, or sealant primers. The proposal includes extensive new labeling and recordkeeping requirements for products manufactured after January 1, 2019, such as:

  • Each container shall display the VOC content of the regulated product as recommended for application.
  • VOC content shall be displayed as grams of VOC per liter of regulated product, excluding water and exempt compounds, or grams of VOC per liter of material for low-solids products.
  • Each container or an associated product data sheet shall display a statement of the manufacturer's recommendations regarding thinning, reducing, or mixing with any other VOC containing material, if applicable. Mixing recommendations shall specify a ratio which results in a compliant, as applied product.
  • Each container shall display the date or a date code of manufacture of the contents. A manufacturer utilizing a date code shall file with the Executive Officer of the District an explanation of each date code.
  • A Quantity and Emission Report (QER) shall be submitted every two years from the years 2018 to 2024, every four years subsequently, and every five years starting from 2028 and thereafter. The report shall include the following information: (i) Product manufacturer (as listed on the label); (ii) Product name and code; (iii) Applicable Rule 1168 category; (iv) VOC content less water and exempt solvents as determined by calculation based on product formulation or laboratory analysis; (v) VOC content of material as determined by calculation based on product formulation or laboratory analysis; (vi) Total volume sold for use within the District reported in gallons of container size; (vii) The volume of regulated product with a VOC content higher than the applicable limit in Rule 1168 sold under the sell-through provisions of this rule; and (viii) The annual quantity of each product including products sold through big box retailers with distribution centers located within or outside the District. Regulated product manufacturers shall use the list of big box retailers maintained by the Executive Officer. There are even more requirements for "Big Box" retailers.

The following table summarizes some of the proposed changes:

Category Proposed VOC Limit (grams/liter) Less Water & Exempt Solvents
Wood Flooring Adhesive 20
Other, Outdoor Floor Covering 50
Grout 65
Reinforced Plastic Composite 200
Contact Adhesive 80
Edge Glue 250
Rubber Vulcanization 250
Other, Roof Adhesive 200
Foam Sealants 50

District staff plans to bring the rule for adoption at the October Board meeting.

 

RULE 219/222 AMENDMENTS

Rule 219 (Equipment Not Requiring a Written Permit Pursuant to Regulation II) and Rule 222 (Filing Requirements for Specific Emission Sources Not Requiring a Written Permit Pursuant to Regulation II) were recently amended by SCAQMD. Rule 219 identifies equipment, processes, and operations that do not require a written permit from the agency. Rule 222 allows certain equipment to register the emission source in the Rule 222 filing program.

The amendments added exemptions for: sub-slab ventilation systems of a specific size, passive carbon filters used to control odors from food waste slurry storage tanks, hand-held plasma-arc cutting and laser cutting equipment depending on metals cut, coffee roasters up to 15 kg batch capacity, breweries over a specified threshold, equipment used to manufacture dehydrated meats, tanks for aqueous urea storage, and low VOC inks and coatings (some restrictions apply). Furthermore, the changes brought in various operations into the permitting system including:

  • Cutting of stainless steel and alloys containing toxics
  • Portable asphalt recycling equipment
  • Shredding or grinding of green waste, and wood that is painted or treated for exterior exposure
  • Separation or segregation of plastics that involves cutting, shredding, grinding, or odors
  • Recycling of expanded polystyrene
  • Pavement stripers where supplemental heat is used
  • Mobile platforms with VOC-containing tanks of combined storage greater than 251 gallons
  • Equipment used for cleaning of diesel particulate filters
  • Tanks containing chromium or certain other toxic metals
  • Carpet and fabric recycling

The following operations will be required to register pursuant to Rule 222:

  • Engines registered with the Statewide Portable Equipment Registration Program (PERP) used
    in the Outer Continental Shelf (OCS)
  • Tanks for aqueous urea storage
  • Industrial water cooling towers located in a chemical plant, refinery or other industrial facility
  • Natural gas production equipment, including natural gas pipeline transfer pumps and natural
    gas re-pressurizing equipment

At the request of the Printing Industry Association, District staff committed to preparing an advisory detailing the changes for printers and coaters.

 

EXEMPTION for tBAc

Tertiary-Butyl Acetate (tBAc) is a solvent used to formulate coatings, lubricants, cleaners, degreasers and adhesives. In 2004, the U.S. Environmental Protection Agency (EPA) removed tBAc as a Volatile Organic Compound (VOC) after finding it less reactive than ethane in the atmosphere and not significantly contributing to ozone formation. The South Coast Air Quality Management District (SCAQMD) has refrained from granting a full exemption and has instead issued case by case exemptions in various rules. A limited exemption in Rules 1113 (Architectural Coatings) and 1151 (Motor Vehicle and Mobile Equipment Non-Assembly Line Coating Operations) was allowed for tBAc. Proposed amendments to Rules 1168 (Adhesive and Sealant Applications) and 1107 (Coating of Metal Parts and Products) were put on hold due to toxicity concerns and worker exposure issues involving tBAc.

In August 2015, the Office of Environmental Health Hazard Assessment (OEHHA) released a draft Technical Support Document for Cancer Potency Factors (CPF) for public review that contained higher numbers (more carcinogenic) than previously estimated. This raised concerns regarding the existing limited exemption for tBAc. SCAQMD recently released a White Paper to "re-examine the partial exemption of tertiary-Butyl Acetate (tBAc) as a VOC in current and proposed SCAQMD rules based on the 2015 health risk assessment (HRA) guidelines and potential action to list tBAc as a carcinogen by the Office of Environmental Health Hazard Assessment (OEHHA)."

SCAQMD staff announced that it will not conduct an on-site worker health risk assessment at this time, but will rely on the Occupational Safety and Health Administration (OSHA) for enforcing occupational exposure. In the future, if an approved on-site health risk assessment methodology and significance threshold is developed, occupational risk could be conducted. "Going forward, a precautionary approach will be used when considering exempt compounds. Unless otherwise specifically directed by the Governing Board, staff will not propose any potential increases in health risks to achieve VOC reductions. Therefore, if the SRP finalizes a CPF for tBAc, defining it as a carcinogen, further VOC exemptions for tBAc will not be considered"—stated the White Paper.

Several District Board members have expressed an interest in removing the limited exemptions that currently exist for tBAc, if the SRP finalizes the draft CPF released by OEHHA in August 2015. However, at this time the limited tBAc exemptions in Rule 1151 and 1113 will remain. If the Stationary Committee directs staff to remove the current limited exemptions, a full rulemaking process will take place along with stakeholder input. Staff was directed to also provide a summary of the options to add tBAc to Rule 102—Definition of Terms, as a Group II exempt compound. The SRP's final review of the new draft CPF is expected to be completed by mid-2017.

 

FEE INCREASES APPROVED

Changes to SCAQMD fees were recently approved by the Board. Due to a protest by environmental groups which caused a disruption, the Board voted on Regulation III (Fees) while cloistered in a conference room. Citing a provision is state law that exempts the Board from having to hear comments by the public, the agency passed the item without taking comments from stakeholders. Most fees saw a by 2.5% increase consistent with the Consumer Price Index. Title V sources are subject to a fee increase of 16% in Fiscal Year 2017-18; an additional 16% in FY 2018-19. Sources outside of the Title V program will have a 4% increase fees for FY 2017-18 and an additional 4% increase in FY 2018-19. The agency's annual revenue has increased by 7.7% to $147 million as compared to last year's. Fees and fines to stationary sources account for $92.2 million. Budget documents estimate that over the past two decades fees to stationary sources have increased by 29%.

 

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