BOARD MEETING DATE: September 10, 1999 AGENDA NO. 39
PROPOSAL:
Amend Rule 1418 – Halon Emissions From Fire Extinguishing Equipment
SYNOPSIS:
The AQMD is proposing to amend Rule 1418 to address conflicting local and federal requirements on discharge testing of total flooding systems used in aircraft and military vehicles. The proposed amendments will allow the use of halons during discharge testing of total flooding systems provided specified criteria are met. In addition, minor revisions are proposed to streamline the reporting requirements, provide consistency with EPA’s halon rule, and clarify rule language.
COMMITTEE:
Stationary Source, July 23, 1999, Reviewed
RECOMMENDED ACTION:
Adopt the attached resolution:
- Certifying the Final Environmental Assessment for Proposed Amended Rule 1418 – Halon Fire Extinguishing Equipment; and
- Amending Rule 1418 – Halon Fire Extinguishing Equipment.
Barry R. Wallerstein, D.Env.
Executive Officer
Background
Rule 1418 was adopted on January 10, 1992 to reduce an estimated 750 tons per day of halon emissions from fire extinguishing systems. Halons are ozone depleting gases which harm the stratospheric ozone layer.
Rule 1418 requires that halons be recovered or recycled during servicing, maintenance or removal of fire extinguishing equipment. Rule 1418 also prohibits the sale of non-rechargeable portable fire extinguishing equipment that contains less than 5 pounds of halons. Rule 1418 allows sources to conduct discharge tests with any halons except Halon 1301. Thus, alternatives to Halon 1301 must be used when conducting discharge tests.
EPA’s Protection of Stratospheric Ozone
The EPA issued a regulation (40 CFR Part 82) that covers the manufacturing, handling, and disposing of halons. Specifically, the rule bans the manufacturing of halon blends, establishes certain training provisions for technicians handling halons, prohibits halon releases during testing and maintenance, and restricts halon disposal. With the exception of the discharge testing provisions, District staff believes that requirements under Rule 1418 are as or more stringent than EPA’s halon rule.
Affected Facilities
Staff has identified approximately 760 facilities which own and operate total flooding systems and about 23 companies which service, test, or install total flooding systems or portable fire extinguishers. Staff is aware of only one facility in the Basin which manufactures aircraft and military total flooding systems that conducts Halon 1301 discharge testing. This facility applied for and was granted a variance from the discharge test requirements of Rule 1418 in June 1995. As part of Federal Aviation Administration (FAA) certification requirements, Department of Defense (DOD) military specifications, and contractual obligations, this manufacturer is required to use Halon 1301 in their total flooding systems and to conduct discharge tests using Halon 1301. Through the variance process, this facility has developed techniques to recover up to 95% of halon used in discharge tests. This manufacturer has attempted to obtain permission from the FAA and DOD to use a surrogate gas for discharge purposes for some time, but no change in FAA and/or DOD policy is forthcoming.
Since June 1995, the AQMD Hearing Board has issued several extensions to the original variance and in 1998 stipulated that the company formally request an amendment to Rule 1418 in order for the company to operate without needing a variance. The company complied and petitioned the AQMD for an amendment to Rule 1418 in July 1998. This proposal is a direct result of that request.
Proposal
Staff is proposing to amend Rule 1418 to address conflicting federal and AQMD requirements concerning the use of Halon 1301 during discharge testing of fire extinguishing total flooding systems. The proposed amendments will provide regulatory relief to the company which has been under variance from the discharge testing requirements of Rule 1418 by allowing discharge tests provided specific criteria are met. In addition, the AQMD is proposing to provide more consistency between Rule 1418 and EPA’s halon rule, streamline the reporting requirements, clarify the recovery efficiency determination, and make minor editorial changes to clarify existing rule language.
Policy Issues
Staff has made significant effort to notify the public and industry of the proposed amendments with over 1200 Notices of Public Workshop mailed to affected facilities and the public at large. A public workshop on Proposed Amended Rule 1418 was held on June 30, 1999. The proposal was well received at the workshop and no significant issues were raised.
AQMP & Legal Mandates
Not applicable.
CEQA & Socioeconomic Analysis
The AQMD has reviewed the proposed project pursuant to the California Environmental Quality Act (CEQA) Guidelines Section 21000. The AQMD has determined that the proposed project does not generate any significant adverse environmental impacts. The AQMD published a Draft Environmental Assessment to address the potential environmental impacts associated with the proposed project. The Draft Environmental Assessment was circulated for a 30-day public review and comment period. No comments were received on the Draft EA and it is now a Final Environmental Assessment included as Attachment G in this Board package.
The AQMD has determined that the proposed amendments would result in insignificant cost impacts for the one affected facility currently operating under variance. In addition, streamlining reporting requirements is expected to result in a savings for other affected facilities. Therefore, the proposed amendments will not result in any adverse socioeconomic impacts.
Implementation Plan
The proposed amendments will decrease the resource impacts on the AQMD by eliminating the need to attend hearings and monitor conditions associated with the variance as well as the resources associated with reviewing and maintaining reports submitted by sources complying with the current requirements of the rule.
A. Summary of Proposal
B. Rule Development Flow Chart
C. Key Contacts List
D. Resolution
E. Rule Language
F. Staff Report
G. Final Environmental Assessment
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