BOARD MEETING DATE: December 4, 2009
AGENDA NO. 36
PROPOSAL:
Adopt Rule 1155 – Particulate Matter (PM) Control Devices
SYNOPSIS:
Proposed Rule 1155 will implement 2007 AQMP Control Measure BCM-01 by establishing requirements for PM control devices that will ensure their proper maintenance and operation.
COMMITTEE:
Stationary Source, September 25 and November 20, 2009, Reviewed
RECOMMENDED ACTIONS:
Adopt the attached resolution:
Certifying the CEQA Final Environmental Assessment for Proposed Rule 1155 – Particulate Matter (PM) Control Devices; and
Adopting Proposed Rule 1155 – Particulate Matter (PM) Control Devices.
Barry R. Wallerstein, D.Env.
Executive Officer
Background
Proposed Rule (PR) 1155 – Particulate Matter (PM) Control Devices would implement control measure BCM-01 in the 2007 Air Quality Management Plan (AQMP).
PR 1155 would apply to more than 1,500 facilities with nearly 5,000 PM control devices. Baghouses and other filtration-type controls account for the majority (76 percent) of the permitted PM control devices subject to this rule, and baghouses account for 82 percent of all filtration control units. Other control devices, such as cyclones, electrostatic precipitators, and scrubbers, account for the remaining 24 percent. Industries affected most by PR 1155 are within the manufacturing sector, including nonmetallic mineral products, fabricated metal products, petroleum and coal products, and chemical products.
Ensuring proper operation of PM control devices is important because the South Coast Air Basin (Basin) has not yet attained the state or federal ambient air quality standards for fine and coarse particulate matter (PM2.5 and PM10). This rule will help prevent equipment malfunctions by establishing minimum performance, and operation and maintenance (O&M) for PM control devices that control directly emitted non-combustion PM.
While no emission reductions are quantified, this rule is expected to reduce emissions. Good maintenance and housekeeping practices, visible emissions monitoring, baghouse or bag upgrades, and installation of BLDS will lead to early repair of baghouses and help decrease the frequency of unexpected upsets due to bag tears and other problems.
Proposal
This rule requires that, beginning April 1, 2010, no visible emissions be observed from any PM air pollution control device requiring an AQMD permit. To implement this requirement, the facility operator must have at a minimum of one person trained in the reading of visible emissions pursuant to EPA Method 22. A once a week, five-minute visible emissions observation using EPA Method 22 is required for any baghouse or other PM control device. Visible emissions monitoring is the primary ongoing compliance requirement for more than 80% of the air pollution control devices subject to this proposed rule.
For proper functioning of PM control devices, all permitted PM air pollution control devices must be operated and maintained pursuant to the manufacturer’s or distributor’s O&M manual or written O&M procedures provided by the operator. Material collected in PM control devices must be discharged for disposal or reprocessed through a controlled transfer system to prevent fugitive emissions during material transfer. PR 1155 requires new baghouse controls to be, at a minimum, an automated shaker. Any existing manual shaker baghouse must be upgraded or replaced with an automated shaker baghouse by 2012 or the end of its useful life, whichever comes sooner.
PR 1155 requires baghouses with a filter area greater than 7,500 square feet to comply with the 0.01 grains per dry standard cubic foot (gr/dscf) PM limit by January 1, 2011. The operator of hot mix asphalt production equipment must comply with the 0.01 gr/dscf limit by January 1, 2013. In the event that the hot mix asphalt facility installed new bags within a year prior to rule adoption, the compliance date would be January 1, 2014 or at the end of the bag’s useful life, whichever comes sooner. Relative to the emissions limit, baghouses at Title V facilities would be required to demonstrate compliance via source test by January 1, 2011 and test again every five years thereafter.
An effective way of minimizing emissions from baghouses is to promptly identify and quickly repair any malfunction and leaks. To that end, PR 1155 would require baghouses with a filter area greater than 7,500 square feet to install a bag leak detection system (BLDS). A BLDS is a system that continuously monitors bag leakage and failure by detecting the increases of particulate matter concentration in the exhaust stack. A BLDS must be installed, operated, and maintained, pursuant to the manufacturer’s written recommendations, to monitor baghouse performance, ensure no visible emissions, and minimize PM emissions. At a minimum, BLDS must have a sensor capable of detecting PM mass in the exhaust gas, and an alarm that will activate automatically before visible emissions can be seen in the exhaust of a baghouse.
To encourage proactive and good inspection and maintenance practices, PR 1155 provides that if a facility operator discovers visible or excess emissions problem that is resolved within 24 hours, the facility would not be in violation of the corresponding rule requirements and not have other subsequent requirements triggered.
PR 1155 also provides several exemptions to all or part of the provisions of the rule based on specific operation conditions. These exemptions are intended to reduce impacts and costs where warranted.
Public Input
During the development of PR 1155, staff worked with a Working Group and invited participation from environmental and community group representatives, representatives from industry associations and potentially affected facilities, government (US EPA and CARB) staff, and consultants. Four Working Group meetings were held. District staff made several site visits and met with industry representatives numerous times to address key issues related to the proposed rule requirements. A Public Workshop was held on September 10, 2009 with approximately 65 people attending. Twenty-two comment letters were received during the public comment period.
Key Issues
Several key issues were raised and addressed during the rule development process. Attachment B provides additional information.
Several changes have been made to the rule since the October 6, 2009 Set Hearing, based on the additional comments received. These changes do not significantly change the meaning of the proposed rule or affect the conclusions in the CEQA document. These revisions were released November 4, 2009 for a subsequent 30-day public notice and review period in advance of the December 4, 2009 Public Hearing:
The proposed 0.01 gr/dscf limit would apply to Tier 3 baghouses.
For a Tier 3 baghouse located at a Title V facility, the facility operator would conduct an initial source test no later than January 1, 2011 and subsequent source tests every five years to demonstrate compliance with the proposed 0.01 gr/dscf standard.
Two new exemptions were added to the rule. Facility operations subject to District Rule 1469 and high efficiency particulate air (HEPA) equipment are exempt from most requirements of the rule. However, these operations are still subject to the no visible emissions requirement only.
During the rule development process, staff received comments that there is not much information on BLDS systems in an asphalt baghouse environment. Staff is working with industry members to conduct a demonstration project by bringing together BLDS vendors and asphalt plant operators. So far, four vendors and three asphalt facilities volunteered to participate in the project. Staff is currently coordinating with them to initiate the program. As directed in the resolution for PR 1155, staff will report to the Stationary Source Committee with the results of the project no later than January 2011.
California Environmental Quality Act (CEQA)
Pursuant to the California Environmental Quality Act (CEQA) and AQMD Rule 110, the AQMD has prepared a Draft Environmental Assessment (EA) for the proposed adoption of Rule 1155. The Draft EA concludes that implementation of the proposed project would not result in significant adverse environmental impacts. The Draft EA was released for a 30-day public review and comment period. No comments were received and the Final EA has been prepared.
Proposed Rule 1155 would affect facilities in nearly all sectors of the South Coast’s regional economy. Of the estimated 1,500 affected facilities, approximately two-thirds are in the manufacturing sector. Affected facilities are concentrated in the following manufacturing industries: nonmetallic mineral product manufacturing, fabricated metal product manufacturing, food manufacturing, and chemical manufacturing.
Socioeconomic Analysis
Costs associated with implementation of this rule involve a visible emissions observation, a one-time cost for BLDS installation, baghouse modernization, permit adjustment for BLDS and bag upgrades, and source testing. The visible emissions observation labor cost is estimated at $325 per unit per year (4,474 units). The cost of installing BLDS is estimated at $9,000 per unit (240 units). The cost of baghouse modernization is estimated at $8,500 per unit (66 units). The cost of permit adjustment is estimated at $670.50 (256 units). Source testing is estimated at $5,000 per test (32 units).
The total annualized cost of the proposed rule is projected to be $2.39 million from 2010 to 2025. Of the $2.39 million annual average cost to implement the proposed rule, the cost of source testing, bag replacements, automated shaker, BLDS, weekly and daily visible emissions monitoring are, respectively, $0.055 million, $0.087 million, $0.122 million, $0.314 million, and $1.80 million. Overall, 27 jobs, 0.00025 percent of total jobs in the four-country region, could be foregone annually, on average, between 2010 and 2025. Very few changes are expected in the relative costs of production and prices of goods in the local economy. It should be noted that most (~83 percent) of the facilities will only be required to conduct visible emissions monitoring at a cost of $325 per unit per year.
AQMP and Legal Mandates
Proposed Rule 1155 is a PM control device rule that would implement control measure BCM-01 of the Air Quality Management Plan.
Implementation Plan
Existing AQMD resources will be sufficient to implement the new rule.
Attachments (EXE, 1.9m)
Summary of Proposal
Key Issues and Responses
Rule Development Process
Key Contacts List
Resolution
Proposed Rule 1155
Final Staff Report
Final Socioeconomic Assessment of Proposed Rule 1155
Final EA for Proposed Rule 1155