1

Updates on November 18, 2014 Based on the 2012 Annual Emission Report (AER), 211 facilities emitted more than 10 tpy of VOC or NOx in SCAQMD and are considered major sourc es. 203 major source facilities are

identified in the 2013 AER.

Rule 1115 Motor Vehicle Assembly Line Coating Opera tions Background : Rule 1115 is not as stringent as the 2008 EPA CTG s for a few coating processes for facilities emitting > 15 lbs/day. CTG has more str ingent limits for electro-deposition primer at 84 g/L (145 g/L in Rule 1115); sprayable primer, pr imer-surfacer, and topcoat at 1440 g/L (1800 g/L in Rule 1115); and trunk coatings, interior coa tings, sealers, and deadeners at 650 g/L (Rule 1115 provides an exemption for these categories).

Analysis : Six facilities are subject to Rule 1115 in SCAQMD . Three of the 6 facilities reported VOC emissions of more than 15 lbs/day. They accoun t for a small inventory of about 0.031 tpd. One facility, emitting 0.45 lbs/day under Rule 1115 , is a major source. EPA CTGs highlight two major VOC emission sources in auto and light-duty a ssembly coating: coating and cleaning activities. While CTGs provide only work practice recommendations for cleaning materials, SCAQMD has strict emission limits on solvent cleani ng procedures (Rule 1171, emission limit = 25 g/L for general solvent cleaning).

Conclusion : Together with Rule 1171 (Solvent Cleaning Operati ons, general limit = 25 g/l), Rule 1115 meets the federal RACT requirements.

2012 VOC Emissions

Name lbs/year tpd

AMREP INC 9906 0.014

THE PAINT DEPARTMENT 6919 0.009

ELDORADO NATIONAL 5897 0.008

MERCEDES-BENZ 4773 0.007
TABC, INC 578 0.001
U.S. GOVT, DEPT OF NAVY 164 0.000

Grand Total 28237 0.0392

Rule 1118 Control of Emissions from Refinery Flares Background : SJVAPCD Rule 4311 (amended 6/18/09) regulates fla res emitting greater than 10 tpy of VOC or NOx with the exemption of municipal s olid waste landfills. SCAQMD Rule 1118 covers flare emissions from refineries, sulfur reco very plants and hydrogen production plants.

Analysis: Other than refinery flares, SJVAPCD identified flar e events in the following industries: wastewater treatment plans, cheese production, wine , dairy operations, flat glass production and correctional facility 1 . Staff evaluated potential flare emissions from s ources other than refineries, sulfur recovery plants, hydrogen production plants and municipal solid waste landfills in SCAQMD. Wastewater treatment plant is another sour ce category with potential flare emissions of greater than 10 tpy of VOC or NOx. In 2012, 5 m ajor source wastewater treatment facilities used flares. Total VOC emission was 0.015 tpd and 92% was attributable to Hyperion Treatment

Plant.

Conclusion : Rule 1118 was determined to fulfill RACT requirem ents in April 2007 2 . In the

evaluation of the recent revision of SJVAPCD Rule 4 311 in August 2011, EPA determined SJVAPCD Rule 4311 to be as stringent as requirement s in SCAQMD Rule 1118 3 . Flare emissions from wastewater treatment plants (not cov ered in Rule 1118) have a small inventory of about 0.015 tpd.

Next step : Rule 1118 appears to be RACT and given this determi nation there does not appear to be any reason to further analysis. If the EPA determinati on does not provide a basis for Rule 1118 as representing RACT, then

1. Identify the major source with flare other than ref ineries, landfills and wastewater treatment plant.

2012 VOC Emissions

Name lbs/year tpd

LA CITY, SANITATION BUREAU (HTP) 10269 0.0141

LA CITY, TERMINAL ISLAND TREATMENT PLANT 136 0.0002

LA CO. SANITATION DIST 17 0.0000

ORANGE COUNTY SANITATION DISTRICT 689 0.0009

Grand Total 11110 0.01523

Rule 462 Organic Liquid Loading
Background : Bay Area, Regulation 8, Rule 33 (Amended 4/15/09) regulates VOC emissions from gasoline bulk terminals with an emission limit of 0.04 lbs per 1000 gallons of liquid loaded. The limit in SCAQMD Rule 462 is 0.08 lbs per 1000 g allons of liquid loaded for Class A facility loading of 20,000 gallons or more. This limit is n ot applicable to small facilities (Class B and C). Rule 462 regulates emissions from additional so urces, including chemical plants, that load organic liquid with a vapor pressure above 1.5 psia

.

Analysis : In BAAQMD, the VOC emissions are 0.52 tpd from ga soline bulk terminals in 2008. Eight of the 13 gasoline bulk terminals in BAAQMD a re regulated under the BACT limit of 0.02-0.04 lbs per 1000 gallons of gasoline loaded. Source test results showed that 12 of the 13 gasoline bulk terminals are in compliance of their (then) proposed limit of 0.04 pounds of organic compounds per 1,000 gallons of liquid loade d. Based on the above information, the cost of reductions was $13,200 per ton for BAAQMD. In S CAQMD, Rule 462 applies to 23 major source bulk loading terminals, and 8 out of 23 faci lities are regulated under the emission limit of 0.02 to 0.065 lbs per 1000 gallons. Source test re sults for 9 bulk loading terminals in SCAQMD showed that mass emission rates were in the range o f 0.0004 to 0.029 lbs per 1000 gallons, well below their corresponding emission limits. Accordi ng to the 2012 emission inventory, organic liquid loadings in major source bulk loading termin als accounted for about 0.33 tpd of VOC emissions. Since the emissions in the SCAQMD are s maller than those in the BAAQMD, the cost per ton would likely be higher.

Conclusion: Rule 462 has more stringent requirements than those stated in federal CTGs and meets the core requirements of RACT. Although it m ay not be as stringent as Bay Area Regulation 8-33 with respect to the emission limit for Class A facilities, Rule 462 covers additional emission sources (chemical plants) and t ypes (organic liquid such as ethanol and kerosene).4

Rule 223 Emission Reduction Permits for Large Confi ned Animal Facilities Background : Rule 223 applies to large confined animal facilit ies (CAF). It requires owners/operations to obtain a permit describing the control strategies the facility chooses to implement from a list of mitigation measure (Class One and/or Class Two) requirements. Class One menu options includes a mitigation measure or c ombination of measures for the specific source category that, at the time of rule adoption, are considered to be the best available retrofit control technology (BARCT), as defined in the Calif ornia Health and Safety Code Section

40406. Class Two measures are considered to be mor e stringent than BARCT. Administrative requirements such as recordkeeping and noticing are also required. SJVAPCD Rule 4570 (Amended 10/21/10) regulates both large and medium CAF, and its timeframe for feeding total mixed rations in the dairy feed menu is 2 hours. T his is more restricted than the 24 hours timeframe in SCAQMD Rule 223. Rule 4570 also specif ies both mandatory and optional mitigation measures.

Analysis : As the largest agricultural area in California, S JVAPCD Rule 4570 requires facilities to choose more mitigation measures and makes several m itigation measures mandatory. Rule 4570 mitigation measures have been approved by EPA as BA CT 4 . The mitigation measures in SCAQMD are mostly comparable to the ones in Rule 45 70, but Rule 223 requires no mandatory measures. In 2010, SJVAPCD revised Rule 4570 to lo wer the regulatory threshold for dairy and poultry facilities and place more emphasis on silag e emissions. Dairies in San Joaquin are larger and use wet silage operations. In SCAQMD, much of the feed is dried, bailed and shipped to local dairies. The dry feed has very low moisture content and thus negligible VOC emissions. Therefore, the more stringent feeding requirements in SJVAPCD Rule 4570 would not result in significant emission reduction if implemented in SC AQMD. In 2010, SJVAPCD also lowered the applicability threshold of dairies (500 milk co ws in SJV vs. 1000 milk cows in SCAQMD) and poultry (400,000 birds in SJVAPCD vs. 650,000 b irds in SCAQMD) to cover all major sources. In SCAQMD, facilities that fall between t hese applicability thresholds are not major source facilities (2012 AER). Additionally, SCAQMD regulates emissions from livestock waste through Rule 1127, which requires best management p ractices for dairies regarding manure removal, processing, and composting. Rule 1127’s m inimum regulatory threshold of 50 cows, heifers, and/or calves is significantly lower than Rule 4570 (500 milk cows, 7500 heifers, calves and/or other support stock).

Conclusion : Since the dairies in SCAQMD are largely dry feed lot operations, the more stringent control measures of silage emissions in SJVAPCD are not applicable in SCAQMD. Given the lack of CTGs/ACTs for CAF and considering the gener al national RACT policy and precedent, the Class One and Class Two mitigation measures in Rule 223 ensures that controls that are economically and technically feasible are required and therefore Rule 223 meets the core requirements of RACT.5

Rule 1148.1 Oil and Gas Production Wells Background : VCAPCD’s Rule 71.5 (Adopted 12/13/94) controls re active organic compound (ROG) emissions from glycol dehydrators used in nat ural gas dehydration through condenser/vapor disposal, flare/incinerator, or emi ssion control system that controls glycol regenerator vent ROC emissions by at least 95%. In SCAQMD, VOC emissions from wellheads, well cellars and untreated produced gas at oil and gas production operations are subject to Rule 1148.1. This rule requires concent ration of total organic compounds (TOC) to be

≤ 500 ppm in well cellar, and other good management practices for the storage and transfer of organic liquids. Emissions of produced gas shall b e collected and controlled by a system handling gas for fuel, sale, or underground injecti on; or a device with a VOC vapor removal efficiency demonstrated to be at least 95% by weigh t or by demonstrating an outlet VOC concentration of 50 ppm.

Analysis : SCAQMD emissions from glycol dehydrators are regu lated under Rules 1148.1 (Oil and Gas Production Wells). The 95% control efficie ncy in Rule 1148.1 is as stringent as VC Rule 71.5. VOC leaks and releases from components at petroleum facilities are regulated under

Rule 1173. Both Rule 1148.1 and Rule 1173 were det ermined to fulfill RACT requirements by the US EPA in August 2011 5 and March 2010 6 , respectively.

Conclusion : VOC emission from glycol dehydrations in oil and gas production is regulated under Rule 1148.1 and Rule 1173; both rules fulfill the f ederal requirements of RACT.6

Rule 2002 Allocations for Oxides of Nitrogen (NOx) and Oxides of Sulfur (SOx) Background : BAAQMD, Regulation 9, Rule 13 (Adopted 9/17/12) l imits the emissions of nitrogen oxides, particulate matter, and toxic air contaminants from the manufacture of Portland cement. According to this rule, the 30-operating d ay rolling average of nitrogen oxides (NOx) emissions from the kiln must not exceed 2.3 pounds per ton of clinker produced. In SCAQMD, NOx emission is regulated under the RECLAIM (REgion al CLean Air Incentives Market) Program. According to RECLAIM Rule 2002, cement ki lns’ current BARCT emission limit is 2.73 lb NOx per ton clinker. Within the SCAQMD, th ere is only one facility with two Portland

cement kilns.

Analysis: The current NOx emission rate limit for cement kil ns in SCAQMD is slightly higher when compared to BAAQMD Regulation 9, Rule 13 (2.73 vs. 2.3 lbs/ton of clinker). The SCAQMD averaging time for the NOx limit is one year using a continuous emission monitoring system while BAAQMD is 30 days. Staff is proposing a NOx limit of 0.5 lb NOx per ton of clinker. The regulated facility has proposed that B ARCT should be 1.5 – 1.8 lb NOx per ton of clinker. Both NOx limits are below the BAQMD Regul ation 9 limit. The proposed amendment to the NOx RECLAIM is currently underway and schedu le for completion by the second quarter

of 2015.

Conclusion: Under the proposed amendment to Rule 2002, the federal RACT requirements for

Portland cement kilns would be achieved.7

References

1 Rule 4311 (Flares) Further Study. San Joaquin Valle y Air Pollution Control District. September 16, 2014.

2 Technical Support Document for EPA's Notice of Dir ect Final Rulemaking on revisions to the California State Implementation Plan- EPA's Analysi s of South Coast Air Quality Management District's Rule 1118, Control of Emissions from Ref inery Flares. United States Environmental Protection Agency, Region IX, April 2007.

3 Technical Support Document for EPA's Notice of Dire ct Final Rulemaking on revisions to the California State Implementation Plan- EPA's Analysi s of San Joaquin Valley Unified Air Pollution Control District’s Rule 4311, Flares. Uni ted States Environmental Protection Agency, Region IX, August 2011.

4 Final Draft Staff Report, Amended Revised Proposed Amendments to Rule 4570 (Confined Animal Facilities), Appendices G, October 21, 2010.

5 Technical Support Document for EPA’s Direct Final Rulemaking for the California State
Implementation Plan- South Coast Air Quality Manage ment District Rule 1148.1 Oil and Gas

Production Wells, United States Environmental Prote ction Agency Region IX Air Division,
August 2011.

6 Technical Support Document for EPA’s Direct Final Rulemaking for the California State Implementation Plan- South Coast Air Quality Manage ment District Rule Rule 1173, Controls of Volatile Organic Compound Leaks and Releases from C omponents at Petroleum Facilities and Chemical Plants, United States Environmental Protec tion Agency Region IX Air Division,

March 2010.