ENVIRONMENTAL JUSTICE PROGRAM CAN IMPACT SOUTHLAND BUSINESSES

New enhancements to the South Coast Basin’s environmental justice program will be put in place in the summer of 2003. In addition, the state has published a draft document for resolution of air pollution complaints as an outgrowth of their commitment to work with local air districts and other interested stakeholders on environmental justice policies.

Some of the local changes included:

• Regulating the use of hydrogen fluoride by requiring the use of additives or alternative processes to reduce the community health risk in the event of accidental release.
• Sponsoring research to develop small, low-cost outdoor air monitoring devices that can be placed in residential areas to assist AQMD in identifying the source of air pollution complaints.
• Posting information on facility health risk assessments and validated violation notices on AQMD’s website.
• Developing a Model Air Quality Element for inclusion in city and county general plans. The Element would assist local government in making land use decisions that minimize the potential for health risk or nuisance for air pollution.
• Developing a program for expedited environmental review for proposed projects in exchange for emission reductions that exceed legal requirements.

The Air Resources Board draft complaint resolution protocol identifies the local air districts as the primary and appropriate agencies to contact regarding complaints. The SCAQMD reportedly receives over 8,000 complaints against Southland businesses yearly. The protocol represents a framework of best management practices for the local air districts and ARB to respond to complaints received from the public about sources of air pollution. Moreover, ARB policy documents emphasize pollution prevention in the handbook for local land-use agencies.

The Bay Area Air Quality Management District is considering community proposals of so called “toxic tours.” In the community’s view, these tours of sites of concern would help educate the public and ensure meaningful public participation. BAAQMD staff is looking into making a video of a toxic tour so that more people could see the sites of concern.

ENFORCEMENT AND COMPLIANCE HISTORY ON-LINE (ECHO)

The Environmental Protection Agency is seeking public comments on their pilot information service, which will enable anyone with Internet access to obtain compliance information on regulated facilities.

Enforcement and Compliance History Online (ECHO) is an electronic tool, which retrieves EPA and state compliance data under the Clean Air Act, Clean Water Act, and Resource and Conservation and Recovery Act. It also provides links to additional state information.

The data covers a two-year period and includes the following information:

• Information on compliance with air permits for various stationary sources of air pollution, such as electric
• power plants, steel mills and factories, and information about the air pollutants they produce;
• National Pollutant Discharge Elimination System permit issuance, permit limits, self-monitoring data and
• enforcement and inspection activity for facilities regulated under the Clean Water Act;
• Hazardous waste generators and handlers;
• Federal enforcement actions taken under all major environmental regulations;
• Demographic information surrounding a facility based on the 2000 Block Group U.S. Census data.

The program includes an online error reporting process that allows users to alert EPA and the States to possible errors.

BEST AVAILABLE CONTROL TECHNOLOGY GUIDELINES UPDATE

In keeping its commitment to provide periodic updates to the BACT Guidelines, the SCAQMD has posted the following listings on their Clearinghouse. The listings are applicable for new, relocated or modified Major Sources.

ARCHITECTURAL COATINGS RULE AMENDMENTS

Architectural coating operations are reported to be the largest emission source among stationary and area sources. An Appellate Court decision ordered the South Coast Air Quality Management District to vacate the 1999 amendments to their Architectural Coatings Rule (Rule 1113). The District filed a petition to the California Supreme Court to review the Appellate Court decision. The petition was denied. As a result, the District will have to re-adopt the May 14, 1999 VOC limits.

In 1998 the emissions from these sources were approximately 58 tons per day. The number could jump to 79.4 tons per day if rule limits are not tightened. The SCAQMD seeks a 22-ton reduction per day of VOC’s from architectural coating operations through a rule amendment. Changes include:

• Re-adopt interim and final VOC limits and Averaging Compliance Option.
• Change the compliance dates for interim limits to January 1, 2003 and for Industrial Maintenance Coatings to January 1, 2004.
• Deletion of the Essential Public Services and Chemical Storage Tank definition.
• Establishing lower interim and final limits for new and existing coating categories such as bituminous roof, high-temperature industrial maintenance, Zinc-rich primers, pretreatment wash primers, swimming pool repair, to conform to state standards.

At its December meeting, the South Coast Board heard concerns from industry groups about the final rule limits, which will become effective in 2006. The board granted a sixty-day continuance for industry to resolve remaining issues with staff. The rule will then be brought back to the board.

EXTENSION FOR DEGREASER EXEMPTION

SCAQMD Rule 1122- Solvent Degreasers, originally adopted in 1979, mandated VOC reductions from solvent degreasing operations. Solvent degreasing operations can be found at industrial, commercial or institutional facilities, to remove contaminants, which are by-products of their processes. The rule specifies equipment and operating requirements for all solvent degreasing processes. Recent amendments to the rule called for lower VOC limits and the control of toxic air contaminants from the use of NESHAP (National Emission Standards for Hazardous Air Pollutants) halogenated solvents.

Based on a study by District staff, the agency now proposed to extend the sunset date for an exemption in section (k)(1)(D) of the rule to January 1, 2005. Said exemption was to expire on January 1, 2003. It applies to small batch-loaded cold cleaners and vapor degreasers with open-top surface areas less than 1 square foot, or with a capacity of less than 2 gallons. In order for the exemption to apply, the equipment must be used only for electrical, high precision optics or electronics applications; or aerospace and military applications for cleaning solar cells, laser hardware, space vehicle components, fluid systems, or components used solely in research and development programs, or laboratory tests in quality assurance laboratories. The exemption will apply to degreasing equipment that does not use NESHAP halogenated solvents.

The exemption is expected to give facilities additional time to evaluate, on a case-by-case basis, the transition to aqueous cleaners and exempt solvents. In some cases, such a transition will necessitate process changes.

REGULATORY FRAMEWORK FOR CUMMULATIVE IMPACTS FROM AIR TOXIC EMISSIONS

In response to a Board directive, AQMD staff has issued a report in reference to investigating the feasibility of rulemaking regarding cumulative impacts of air toxics beyond current AQMD requirements. The report analyzes further health risk reduction that would be implemented on a regional basis. Permitted sources, area sources and California Environmental Quality Act (CEQA) projects may fall within the scope of the tentative regulation. Unlike current District rules, which look at individual risk, cumulative impact regulations may look at the cancer risk burden for a particular neighborhood or community.

Industry groups have asked for the scope to be limited to cancer impacts while environmental and community groups have requested the scope to be expanded to chronic impacts and particulates. Although talks of cumulative impacts are at their infancy, the District is considering various options such as a toxic reduction trust fund to invest in clean technologies in Environmental Justice areas.

POWER PLANT EMISSION CONTROL TECHNOLOGY

A recent SCAQMD report looked at ways of controlling emissions from power plants. Currently, clean power generation equipment such as photovoltaic units, wind power, fuel cells and micro turbines are exempt from AQMD permits. Reciprocating engines (greater than 50 HP) and gas turbines (greater than 2,975,000 Btu/hr) represent examples of power generation equipment, which require AQMD permits.

SCAQMD staff has researched emission controls, which comply with their standards. According to their findings, fuel NOx and thermal NOx are of greatest concern. Fuel NOx is created from the oxidation of bound nitrogen in fuels. Thermal NOx results from the combustion of nitrogen and oxygen at temperatures exceeding 200 degrees Fahrenheit.

Pre-combustion control of NOx can be achieved through:

• * Fuel/feed modifications (excess air or air preheat reduction and ultra low nitrogen fuels).
• * Combustion temperature absorption such as flue gas recirculation or water or steam injection.
• * Combustion staging/modification (overfire air, low and ultra low NOx burners, catalytic combustion).

Post combustion control of NOx can be achieved through:

• * Selective Non-Catalytic Reduction. This method can reduce NOx emissions by 40 to 70 percent. NOx is selectively reduced by injecting ammonia or urea into flue gas. It requires a controlled residence time and temperature (between 1600 and 2000 degrees Fahrenheit). If not properly controlled, ammonia slip and additional NOx generation can be issues. In addition, flue gases with high sulfur content coupled with ammonia slip can produce ammonia sulfates that will plug and corrode equipment. This technology can be applied to boilers, heaters and furnaces.
• * Selective Catalytic Reduction. Selective Catalytic Reduction consists of ammonia or urea injection into the flue gas upstream of the catalyst. NOx reductions range from 80 to 95%. The temperature operating range is between 300 and 1100 degrees Fahrenheit. There are ammonia slip considerations and proper mixing of flue gas and ammonia is critical. This technology can be applicable to boilers, gas turbines, duct burners, heaters, furnaces and internal combustion engines.
• * Non-Selective Catalytic Reduction (3-way catalyst, SCONOx.) The 3-way catalyst derives its name from its ability to reduce NOx, CO and VOC’s. It is limited to rich burn engines and can reduce NOx by 80-95%. The SCONOx process oxidizes NO to NO2 by means of a catalyst at an operational temperature range of 300-700 F. Ammonia is not used. CO and VOC’s are also oxidized. The process requires additional quantities of natural gas and steam to generate reformer gas. This technology can be applicable to boilers, gas turbines, duct burners and internal combustion engines.
• * Emerging technologies include ozone oxidation of NOx, non-thermal plasma and phosphorous injection.

District staff pointed out that currently, ammonia emissions from NOx controls account for 5% of the total emissions of ammonia from industrial sources in the Basin. This number is expected to jump to 14% by 2004.