SOME SOLVENT CLEANING REQUIREMENTS POSTPONED FOR A YEAR (RULE 1171)

The South Coast Air Quality Management District (“District”) held a public workshop on its proposed amendments to Rule 1171—Solvent Cleaning Operations. The proposal includes reductions of the VOC contents for various cleaners from the current standard of 500 grams per liter to 100 grams per liter. The limit for adhesives (including medical devices) is being proposed at 25 grams per liter by June of this year. The District proposes to extend the effective date for the 100 grams per liter requirement (originally scheduled to take effect July 1, 2006) by one year until 7/1/07. Under the current proposal, the VOC limit for cleanup solvent for ALL adhesives, including pressure sensitive labels and medical devices is 25 grams per liter starting June 30, 2006.

Industry representatives requested an 18 month moratorium on the 100 grams per liter standard, raising the VOC content of roller and blanket wash in automated systems to 650 grams per liter, accept VOC facility averaging, and add a provision in the rule that low VOC requirements be adopted only after solvents have been demonstrated to work in practice. Various printers reported that the low VOC solvents do not clean adequately, cause lithographic problems (e.g., stripping, tinting, and scumming), and harm the equipment.

The changes will be presented to the AQMD board in June for adoption

PROPOSED AMENDMENTS TO SOUTH COAST PERMIT EXEMPTIONS – RULE (219)

South Coast Air Quality Management District Rule 219 — Equipment Not Requiring a Written Permit Pursuant to Regulation II — lists specific operations and equipment that are exempt from air permits. The general rule of thumb is that if the equipment in question does not appear on the list, it will most likely require a permit. The District held a public workshop in February to present the proposed amendments to the rule.

A notable change is the proposal to eliminate exemptions for facilities with Volatile Organic Compound (VOC) or Particulate Matter emissions of 4 tons or more. Under the current proposal, affected facilities (with emissions of 4 tons per year or more), which previously had some exempt equipment would lose those exemptions. Staff’s rationale is that the aggregate emissions from individual equipment will result in significant emissions thus needing a permit to ensure compliance. These facilities (approximately 100) will be required to obtain an “operational permit” for all of their previously exempted equipment. They will need to file one comprehensive application for all previously exempt equipment. For these facilities fees will be as follows:

The District anticipates revenues of $150,000 in fees as a result of the change.

Staff also proposes to repeal the current exemption for anhydrous ammonia storage and/or transfer equipment. Anhydrous Ammonia is listed in Rule 1401—Air Toxic Contaminants—as a toxic. Monitoring devices are required for storage and vaporization systems as well as daily inspection and maintenance of all valves and components.

Industry has expressed some opposition to this rule change and the AQMD staff is considering the comments.

Staff proposes to exempt the following equipment:

• Passive underground gases collection and ventilation system
• Hand held plasma arc cutting equipment used for maintenance and repair work
• Shot peening, flywheel type equipment and control equipment exclusively venting such equipment
• Corona treating equipment and associated air pollution control equipment used for surface treatment in printing, laminating, or coating operations
• Hand application of materials used in printing
• Modified atmosphere food packaging equipment
• Hand lay-up, brush, daubers and roll up of adhesives, dyes and coatings operations
• Water-based fluorosilicic acid storage and transfer
• Solvent reclamation systems, including dryers serving low VOC cleaners
• Hand application of solvent for cleaning purposes
• Air cooled/liquid cooled solvent recovery systems
• Large agricultural gasoline tanks and IC Engines
• Unheated nitric acid tanks used in surface preparation processes
• Control equipment to the basic equipment exempt under Rule 219

NEW BACT LISTINGS

The SCAQMD presented new Best Available Control Technology Guidelines to the Scientific Review Committee (one of its advisory groups made up of industry and academia). Table 1 below summarizes the BACT determinations for major sources. Table 2 shows new requirements for various types of emergency engines at non-Major facilities and Table 3 show the requirements for printing at non-Major facilities.

Table 1. BACT determinations for major polluting facilities*

* Text in italics indicates new change
Table 2. BACT guidelines for engines at non-Major facilities*

* Text in italics indicates new change
Table 3. Graphic Arts BACT Guidelines for non-Major facilities*

* Text in italics indicates new change

STATE AIR RESOURCES BOARD CONCLUDES PM DEVICES CANNOT MEET NO2 LIMITS

As part of their Diesel Risk Reduction Plan, the Air Resources board developed a procedure to verify the effectiveness of control systems for diesel particulate matter (PM). The procedure includes emissions test procedures, warranty requirements, and in-use compliance requirements.

Nitrogen dioxide formation from some diesel emission control systems is one of the issues staff has been looking into. NO2 falls under the nitrogen oxides (NOx) category, thereby making it a criteria pollutant. Staff has recently concluded that “most verified PM control devices remain unable to meet the NO2 limit that begins next year.”

The proposed amendments to the verification procedure include revisions to the NO2 emission limit for verified emission control systems. As of January 1, 2007, a maximum increase of NO2 emissions equivalent to 30 percent of the total baseline NOx emission level, will be allowed. As of January 1, 2009, the maximum increase will be reduced to 20 percent. Staff also proposes additional pre-conditioning requirements for emission control systems whose NO2 emissions may be influenced by the presence of soot and ash at the time of testing. The agency expects that most of the currently verified filters would be able to meet the limits and therefore be available for use as diesel PM control strategies.

AMENDMENTS TO COATINGS OF METAL PARTS AND PRODUCTS – RULE (1107)

In response to public comments last year that the low-VOC technology required by Rule 1107 was not available for liquid photoresist coatings, the District has proposed to exempt the operations from rule requirements.

Liquid photoresist coatings are used in the manufacture of precision-etched parts from their metal substrates. District staff deems the emissions from the operations to be minimal. The exemption will be limited to usages of up to 10 gallons per year per facility.

REGULATORY DEADLINES

May 14, 2006 – All existing Continuous Emissions Monitoring Systems (CEMS) will need to comply with rule 218.1. Operators may be able to apply for a waiver.

June 1, 2006 – Refiners or importers in the South Coast shall not produce or distribute diesel fuel which exceeds 15 ppm sulfur by weight.

July 1, 2006 – Several exemptions in Rule 1107 (Coating of Metal Parts and Products) will expire.

April 1, 2006 – Manufacturers of clear brushing lacquers to submit annual reports to AQMD. As of July 1, 2006, an averaging compliance option will may available for some categories. The small container (one quart or less) exemption will expire on July 1, 2006.

January 1, 2007 – Plastic, Rubber and Glass Coatings limits go into effect (Rule 1145).

January 1, 2006 – VOC limit of 25 grams per liter for vapor degreasers goes into effect (Rule 1122).

February 2, 2006 – Cement Manufacturing facilities required to comply with requirements for all inactive open storage piles and keep records.

January 1, 2006 – Compression ignition engines over 50 bhp will need to comply with rule requirements. Sellers of engines have to report sales by January 31 of every year, starting in 2006, for sales which took place in 2005 (Rule 1470).

January 1, 2006 – Rule 1146.2 (Emissions of Oxides of Nitrogen from Large Water Heaters and Small Boilers) limits for existing equipment take effect. Units ranging from 400,000 to 1,000,000 Btu/hr must be retrofitted to meet the following limits:

• NOx = 30 ppm or less at 3% oxygen, dry
• CO = 400 ppm or less at 3% oxygen, dry

Units rated at less than 400,000 BTU/hr can operate until replaced by a compliant unit.