South Coast Air Quality Management District
South Coast Air Quality Management District
BOARD MEETING DATE: January 19, 2001 AGENDA NO. 25
Adopt Rule 1132 – Further Control of VOC Emissions from High Emitting Spray Booth Facilities
SYNOPSIS:
Proposed Rule 1132 will further reduce VOC emissions from spray booths operated by the highest-emitting facilities. Facilities subject to the rule will be required to install add-on control systems, use low VOC-products, or otherwise demonstrate compliance through an alternative compliance plan. The proposed rule will establish a two-tiered compliance schedule that will become effective in 2003 for the higher emitting facilities and 2004 for the remaining facilities subject to the rule. The proposal implements portions of Control Measure CTS-09 of the 1999 AQMP Amendments.
COMMITTEE:
Stationary Source, September 22, 2000, October 27, 2000, and December 1, 2000, Reviewed
RECOMMENDED ACTION:
Adopt the attached resolution:
- Certifying the CEQA Final Environmental Assessment for Proposed Rule 1132 – Further Control of VOC Emissions from High-Emitting Spray Booth Facilities; and
- Adopting Rule 1132 - Further Control of VOC Emissions from High-Emitting Spray Booth Facilities
Barry R. Wallerstein, D.Env.
Executive Officer
Background
Proposed Rule 1132 – Further Control of VOC Emissions from High-Emitting Spray Booth Facilities, has been developed to implement Phase I of Control Measure CTS-09 of the 1999 Amendments to the 1997 Ozone State Implementation Plan for the South Coast Air Basin (Basin). Control Measure CTS-09 is a two-phase control measure that calls for emission reductions beyond those emission reductions required under existing rules and regulations. With the exception of petroleum industry facilities, which are covered under Control Measure FUG-05, Control Measure CTS-09 is directed toward the top VOC-emitting facilities in the basin that operate spray coating booths.
Based on the emissions inventory reports for 1998-99, AQMD staff has identified 79 facilities in the basin that would be subject to the proposed rule. These facilities are distributed among four main manufacturing industries: aerospace, metal and plastics, fiberglass-reinforced plastics, and wood products. The 1998-99 annual emissions inventory for the affected facilities, including emissions from permitted and non-permitted equipment or operations, is estimated at 10.5 tons per day. Based on this inventory, the proposed rule would reduce 3.7 tons per day of VOC from these facilities. This level of reductions is expected to meet the Phase I emission reduction target under Control Measure CTS-09 for year 2010.
Although classified in distinct industrial categories, the methods of controlling VOC emissions from these facilities are technically similar. Several air pollution control strategies may be used to reduce VOC emissions from spray booths. They include add-on control technologies such as carbon or zeolite adsorption, thermal oxidation, catalytic oxidation, biofiltration, cryogenic condensation, ultraviolet oxidation, and hybrid concentrator/oxidation systems. VOC emission reductions at these facilities may also be achieved by source reduction techniques including use of lower VOC products, process change, good housekeeping, source elimination, and other operational changes at the facility.
As part of the rule development process for Proposed Rule 1132, AQMD staff has worked with the affected industries to ensure that the proposed rule is technically sound, cost-effective, practical and enforceable. A working group consisting of several representatives of the affected industries, governmental agencies, and environmental organizations was formed to help in the development of the proposed rule. Although, not all of the members were active in the rule development process and the proposed rule may not reflect a consensus, many of the recommendations and concerns of the working group and other individuals are incorporated in the proposed rule.
Proposal
Proposed Rule 1132 applies to facilities that operate spray booths and emit over 20 tons per year of VOC in any emission inventory year 1998/99 or thereafter. The proposed rule requires the affected facilities to reduce their spray booth emissions by 65 percent by installing add-on control equipment, use of low VOC products, or a combination thereof. Alternatively, a facility may demonstrate emission reductions equivalent to at least 10 percent more than the basic requirements through the application of facility-wide measures. Existing facilities already emitting more than the 20 tons per year threshold will have until July 1, 2003 or July 1, 2004 to comply with the requirements, depending on the emission levels. Facilities that later become subject to the rule would have two and a half years after the threshold is exceeded to demonstrate compliance.
The proposed rule also provides additional compliance options that allow for a more streamlined implementation process with equivalent or higher emission reductions. Specifically, composite manufacturing facilities that commit to early reduction by January 1, 2002 through the implementation of a series of pollution prevention strategies identified in the rule will have till July 1, 2004 to demonstrate compliance with the final 65 percent reduction requirement of the rule. Additional time for compliance until December 31, 2004 is also provided for facilities that commit to reducing their emissions through process change by more than 85 percent. These compliance options, along with other associated revisions were added to the proposed rule in response to public comments received after the notice of public hearing was published on November 17, 2000.
Facilities may also be deemed in compliance by applying for an enforceable permit condition limiting their facility-wide VOC emissions to 20 tons per year or less. The proposed rule also provides an exemption from the emission reduction requirements for low-concentration spray booths. Although technically feasible, the control of emissions from low-concentration spray booths is cost-ineffective. The proposed rule establishes emission thresholds based on the exhaust flow rate to exempt these low-concentration, low VOC loading and intermittently operated spray booths. In addition, in order to address an unique situation, spray booths equipped with voluntarily installed emission control systems will be exempt provided that the remaining spray booths at the facility are converted through process change that reduces emissions by more than 85 percent.
The proposed rule requires affected facilities to keep appropriate records and demonstrate compliance with either the applicable requirements or exemptions on an annual basis. Standard test methods, protocols and procedures issued by the US EPA, CARB and the AQMD are used to determine compliance.
Policy Issues
During the rule development process, industry commented extensively on the feasibility and high cost of controlling low concentration and, especially, high flow rate spray booths. While the state of add-on control technologies has evolved to render such controls technically feasible, staff analysis indicates that such controls are still cost-ineffective. To address this issue staff incorporated an exemption for low concentration spray booths. This exemption is estimated to apply to the least cost-effective 40 percent of the spray booths subject to PR 1132. While the low-concentration spray booth exemption is expected to lower the estimated emission reductions by approximately 15 percent, it reduces the annualized implementation costs by approximately 50 percent and greatly improves the overall cost-effectiveness of the rule.
In response to industry requests for additional compliance options including the ability to use pollution prevention/source reduction for compliance, staff has augmented its original proposal with additional compliance options. Specifically, staff has worked closely with the Fiber Reinforced Plastics Industry and developed a two tiered compliance option that results in accelerated emission reductions through the use of lower VOC materials and application technologies by January 1, 2002, to be followed by a second tier due July 1, 2004. An alternative compliance option that provides more time for compliance through December 31, 2004 for greater emission reductions (85 percent or more) has also been added to the rule.
AQMP and Legal Mandates
The California Health and Safety Code requires the AQMD to adopt an Air Quality Management Plan (AQMP) to meet state and federal ambient air standards in the Basin. In addition, the California Health and Safety Code requires that the AQMD adopt rules and regulations that carry out the objectives of the AQMP. Proposed Rule 1132 implements Phase I of Control Measure CTS-09 which is part of the 1999 Amendments to the 1997 Ozone State Implementation Plan for the South Coast Air Basin.
CEQA & Socioeconomic Analysis
Pursuant to the California Environmental Quality Act (CEQA) and the AQMD’s Certified Regulatory Program (Rule 110), staff has prepared an Environmental Assessment (EA) for Proposed Rule 1132. The Draft EA, which was made available for a 30-day review period, concluded that Proposed Rule 1132 would not have any significant adverse affect on the environment. Comments received on the Draft EA were responded and included in the Final EA. The Final EA is included as part of the attached package for the public hearing considering the adoption of Proposed Rule 1132.
The cost effectiveness of the proposed rule is $5,484 per ton of VOC reduced. The total cost from implementing the proposed amendments is estimated at an annual average of $13.1 million from 2003 to 2015. The annualized costs are less than five percent of sales for the majority of affected facilities. On average, between 2003 and 2015, a total of 141 jobs could be foregone as a result of the proposed rule. The proposed rule could result in slight increases in product prices and reductions in profits of those directly affected industries.
Implementation Plan
The proposed rule will affect spray booth facilities that emit more than 20 tons per year. Staff has been working with those facilities and trade organizations that are known to be affected by the proposed rule, and will continue to be available should a need for assistance arise during implementation. Any other facilities will be informed of the rule by mail, outreach, and Internet posting on the AQMD website.
Resource Impacts
When fully implemented, Proposed Rule 1132 is expected to increase the workload for AQMD engineering and compliance staff. However, the workload increase is expected to be handled by the existing staff and is not expected to have an impact on AQMD fiscal resources.
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