DEADLINE FOR NOX REDUCTION FROM WATER HEATERS AND BOILERS APPROACHES

Large water heaters and boilers (between 1 million Btu/hr and 2 million Btu/hr) manufactured between 1992 and 1999 will have to meet a Nitrogen Oxides (NOx) limit of 30 ppm (3% dry oxygen) and 400 ppm of Carbon Monoxide (3% dry oxygen).

The units may be subjected to further reductions if the District decides to amend Rule 1146.2, which regulates equipment ranging from 75,000 Btu/hr to 2 million Btu/hr. Possible amendments under consideration include:

• A NOx limit of 20 ppm for new equipment
• Replacement or retrofitting of existing equipment after 10 or more years to meet a NOx limit of 20 ppm

Equipment previously retrofitted to 30 ppm of NOx, would not be subject to any more stringent requirements. The proposed amendments will tentatively be presented at a public hearing in January 2005.

CALIFORNIA CONSIDERS CONSUMER PRODUCT REGULATION FOR WOOD PRODUCTS

The California Air Resources Board proposes to regulate composite wood products such as particleboard, medium density fiberboard, hardwood plywood and composite veneer. The state estimates that 2.5 billion square feet of composite wood products are sold in California annually and generate an estimated 400 tons of formaldehyde—an air toxic.

The state identified formaldehyde as a Toxic Air Contaminant in 1992. Formaldehyde exposure has been linked to nasopharyngeal cancer, acute eye irritation and chronic respiratory health problems. It is ranked the number one indoor air pollutant. The ARB points to the urea-formaldehyde resins used in the manufacture of these wood products as the culprit in generation of formaldehyde emissions.

In 2001, the ARB began a survey to evaluate alternatives in order to reduce formaldehyde exposure. The agency is in the process of developing an Air Toxics Control Measure to reduce formaldehyde emissions from composite wood products and encouraging the use of formaldehyde-free products in homes and construction as a pollution prevention measure.

Present day technologies identified by ARB:

• Copolymer blends
• Melamine additive
• Post-production treatment
• Scavengers
• Alternative resins
• Lamination

NEW REGULATIONS FOR PLASTIC, RUBBER, LEATHER AND GLASS COATINGS IN SOUTHERN CALIFORNIA

The South Coast Air Quality Management District proposes amendments to their rule 1145 — Plastic, Rubber, Leather, and Glass Coatings — which will lower the VOC limits for various applications. Leather coatings (previously not regulated by the District) have been added to the rule, with the following VOC limits:

Sealer coatings and color coatings = 0.5 pounds per gallon
Stain coatings = 1.8 pounds per gallon
Antique coatings = 1.3 pounds per gallon

These limits for leather coatings will be effective upon rule amendment adoption by the SCAQMD board.

The new VOC limits for general, mirror backing and optical coatings will take effect on January 1, 2007.

Table 2. VOC limits for Rule 1145 categories

Additionally, a limited exemption is provided for polyurethane shoe sole coating operations.

The District estimates emissions from 1145 operations to decrease from 2.46 tons per day to 1.27 tons per day. The District reports the annual cost of compliance to the industry to be $1,801,951, with an average cost effectiveness of $3,900 per ton of VOC reduced.

PHASING OUT CHROMATED PRIMERS IN THE METAL PLATING INDUSTRY

Spraying of paints and coatings containing chromium or hexavalent chromium occurs in a variety of industries. Southern California metal platers in industries such as electroplating, aircraft and coating & engraving will have to control these toxic emissions.

According to the South Coast Air Quality Management District, hexavalent chromium is a “potent carcinogen.” The substance is used as a pigment in paints, inks and plastics and as an anti-corrosion agent in protective coatings and in chrome plating. The District’s proposed rule 1469.1 — Spraying Operations Using Toxic Chemicals — is expected to reduce hexavalent chrome emissions from chrome spraying processes by at least 85%. Spray application techniques under the rule’s umbrella include low volume/high pressure (commonly referred to as conventional air spray), high volume/low pressure (HVLP), airless spray and electrostatic spray.

Table 1. Control Options for Rule 1469.1

District staff is currently conducting public workshops and a date for Board approval has not been finalized at this point.

RULE 1122 – SOLVENT DEGREASERS AMENDMENTS

The South Coast Air Quality Management District recently concluded a study focusing on conversion of solvent degreasing operations to less polluting processes. The affected industries (13 facilities) include electrical, electronics, aerospace, space vehicle components, military and research & development operations. The total VOC emissions from these operations amount to approximately 25 pounds per day.

The District proposes to add the use of control devices as a compliance option. A limited exemption for cleaning of electronic components for space applications will be allowed and the current exemption for stereolithography will be extended. Research and development or quality assurance work will be permanently exempted from the rule requirements. The District reports “many successful conversions to alternative cleaners” and that “most companies can readily convert.”

RECLAIM AMENDMENTS

Adopted in 1993, the Regional Clean Air Incentives Market (RECLAIM) is a cap and trade NOx and SOx program, which replaced command and control rules for various industries. The program applies to facilities with over 4 tons per year emissions of NOx or SOx. There are approximately 330 facilities in the NOx program and 35 facilities in the SOx program.

The SCAQMD proposes amendments to the program to implement Best Available Retrofit Control Technology, which consists of emission limits based on technological feasibility and cost effectiveness. The state requires the program to meet reductions that would have otherwise occurred under the traditional command and control rules. The availability of low NOx burners and Selective Catalytic Reduction (SCR) has prompted a further look into RECLAIM to ensure that BARCT requirements are met. An additional 7.8 tons per day of NOx reduction is currently proposed by the staff. Four tons per day would be reduced by 2007 and the remainder would be reduced in equal increments from 2006 to 2010. Equipment for which new BARCT is achievable includes: Boilers & heaters (including equipment located at refineries), fluid catalytic cracking units, metal melting and heating processes, kilns, calciners, dryers and furnaces. Equipment for which no new BARCT has been identified include: Gas turbines, cement kilns, internal combustion engines, glass melting furnaces and curing ovens.

The proposed changes will not deal with the reduction of credits needed to reflect new BARCT. The District proposes to continue existing trading restrictions for power plants at this time.

Industry concerns include the amount and timing of reductions, whether to apply rates of reduction equally to all facilities or to have variable reductions per facility and whether there should be any potential exemptions from reductions. A general concern from industry stakeholders is that the reductions not be too large to disrupt the market.

AIR QUALITY MANAGEMENT PLAN UPDATE

The Environmental Protection Agency (EPA) has finalized the area designations for the new 8-hour ozone standard. The South Coast Basin has been classified as “Severe-17” with a 2021 attainment date. In comparison, the Coachella Valley has been classified as “Serious” with an attainment date of 2013.

The EPA has also begun the designation and rule development process for the PM 2.5 (particulate matter less than 2.5 microns in diameter) standard. The PM 2.5 State Implementation Plan is due in 2008 with attainment date of 2010-2015 for non-attainment areas. The South Coast Air Basin will be classified as a non-attainment area for PM 2.5. The EPA is currently preparing guidance that local air Districts will have to follow when preparing attainment demonstrations for the new standards. Efforts by SCAQMD are currently underway to update the emissions inventory and meteorological data used to develop the 8-hour ozone and PM 2.5 attainment demonstrations.

COMPLIANCE CORNER: GRAPHIC ARTS

ATI experts can help your company comply with stringent government regulations in a myriad of ways. One of the compliance avenues we explore is pollution prevention. Pollution prevention is the concept of conversion to processes, which do not need add on controls and already comply with regulations.

ATI clients involved in the graphic arts industry can turn to us for help on identifying low VOC inks and coatings, which reduce regulatory burdens on industry. As an example, Ultraviolet/Electron Beam (UV/EB) inks and coatings can offer certain process advantages and very low emissions (typically less than 50 grams/liter of VOCs). From a regulatory perspective, many UV/EB processes are exempt from SCAQMD requirements.