UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

EPA’s Proposed Rulemaking

for the

California State Implementation Plan

South Coast Air Quality Management District Rule 1155,

Particulate Matter (PM) Control Devices

Prepared by: Christine Vineyard 

January 7, 2015
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AGENCY: South Coast Air Quality Management District (SCAQMD)

Rule 1155: Particulate Matter (PM) Control Devices

SIP-approved Rule: None

Adopted by SCAQMD: December 4, 2009

Submitted by CARB July 20, 2010

EPA Completeness: August 25, 2010

Amended by SCAQMD: May 2, 2014

Submitted by CARB: July 25, 2014

EPA Completeness: September 11, 2014

Rule Summary – Rule 1155 is a new rule that establishes minimum performance and 

maintenance requirements for permitted particulate matter (PM) air pollution control 

devices (not the specific source causing the PM emissions) venting direct (noncombustion) PM, to ensure the proper operation and maintenance of such equipment. 

These include baghouses, electrostatic precipitators, cyclones, scrubbers and other 

dust collecting equipment to control and capture PM emissions from non-combustion 

sources. SCAQMD estimates that the rule applies to more than 1,500 existing 

permitted facilities with nearly 5,000 pieces of permitted PM air pollution control 

equipment from a wide range of industries.

A summary of the major provisions of the rule is provided below.

 (c) Provides definitions for rule clarity.

 (d) Establishes general requirements including:

- No visible emissions are to be allowed or caused from any PM air pollution 

control device.

- The outlet concentration of any Tier 3 baghouses (> 7,500 square feet) cannot 

exceed 0.01 gr/dscf.

- All permitted PM control devices are to be operated and maintained pursuant to 

the manufacturer’s O&M manual or other similar written material supplied by the 

manufacturer or distributor of the control device.

- Existing manual shaker baghouses are to be upgraded to automated/mechanical 

shaker units.

- When a new process is vented to a new baghouse, the operator shall install and 

maintain a ventilation system that meets a minimum capture and velocity 

requirement. 

- Materials collected in a permitted PM control device must be discharged for 

disposal or brought back to the process through a controlled material transfer 

system to prevent fugitive emissions during material transfer.

 (e) Establishes monitoring requirements including:

- The operator of any baghouse or other PM control device shall have at least one 
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trained person to conduct a continuous five-minute visible emissions observation 

pursuant to EPA Method 22, and shall maintain records for each observation.

- Any baghouse outfitted completely with verified filtration products shall only be 

required to conduct visible emission observations one per month, maintain 

records for each Method 22 observation, and any subsequent actions taken to 

eliminate visible emissions.

- The operator of any Tier 3 baghouse shall install, operate, calibrate and maintain 

a Bag Leak Detection System (BLDS) pursuant to the manufacturer’s written 

recommendations to monitor baghouse performance and ensure compliance.

- The operator of hot asphalt production equipment may conduct daily visible 

emissions monitoring, in lieu of immediate BLDS installation. The operator must 

file a permit application for a BLDS and install the BLDS within three months of 

issuance of the permit. Additional time was given to hot mix asphalt industry 

because of unique stack characteristics, such as high moisture, organic gases, 

and frequent change of particle size. 

- Tier 3 baghouses at a Title V facility must conduct an initial source test to 

demonstrate compliance and subsequent source tests every five years 

thereafter.

 (f) Requires that records and information to demonstrate compliance must be kept 

and maintained at the facility for a minimum of five years. 

 (g) Describes alternative requirements including that:

- Any baghouse with a filter surface area < 100 square feet need only comply with 

the no visible emissions requirement in section (d)(1).

- The operator of a PM air pollution control device venting a noncontinuous 

process is exempt from weekly five-minute visible emissions observation 

requirement, provided no visible emissions occur when the activity takes place.

- Any equipment with an active permit to operate that is not in operation is exempt 

until operations commence.

- Facility operations that are subject to other SCAQMD Rules 1105.1 – Fluid 

Catalytic Cracking Units, and 1156 – Cement Manufacturing Facilities are 

exempt from this rule because these rules already establish requirements and 

operating parameters for PM control devices in these specific applications.

- Operators of Tier 1 and Tier 2 baghouses that voluntarily install and operate a 

BLDS need not comply with the one per week five-minute visible emissions 

observation requirement.

- Bin vents are exempt from the once per week, five-minute visible emissions 

observation requirement because characteristics of the PM control device (such 

as being placed in the top of a silo) makes it difficult to read.

- The provisions of no visible emissions, not exceeding 0.01 gr/dscf at the 

baghouse outlet, a five-minute visible emissions observation, and BLDS 

operations are not applied during start-up of the equipment, including after a 

repair to fix an equipment breakdown or after a scheduled maintenance activity. 

During that one-half hour starting period, PM air pollution control devices under 

this rule remain subject to the PM concentration (grain loading) requirements of 

Rule 404 and an opacity requirement of no greater than No. 1 on the Ringelmann 

Chart as specified in Rule 401(b)(1) [shown as Rule 401(a) in the SIP-approved 
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version of Rule 401].

- The provisions of the 0.01 gr/dscf limit, bag upgrade and a five-minute visible 

emissions monitoring apply only to the PM air pollution control device exhausting 

to the atmosphere. The BLDS installation provisions apply to the Tier 3 

baghouse only if it is in the last in the series to vent to the atmosphere.

- Paint spray or powder spray booths are exempt from the provisions of this rule.

- Air pollution control equipment exclusively venting organic gases from hot mix 

asphalt load-out operations and directly related equipment is exempt from the 

provisions of this rule.

- Any portable dust collector, fume extractor, or negative air machine with a 

maximum rated capacity of less than or equal to 3,000 cfm is exempt from all 

provisions of this rule except the no visible emissions requirement.

- Facility operations subject to District Rule 1469, Hexavalent Chromium 

Emissions from Chromium Electroplating and Chromic acid Anodizing 

Operations, are exempt for all but the no visible emissions requirements in this 

rule.

- High efficiency particulate air (HEPA) equipment is exempt from all but the no 

visible emissions requirement of this rule.

Rule Evaluation – EPA is evaluating this rule primarily against the three criteria 

discussed below.

1. Rule Stringency – In PM2.5 and PM10 nonattainment areas classified as 

moderate, the SIP must include Reasonably Available Control Measures (RACM) (see 

Clean Air Act (CAA) section 189(a)(1)). The SCAQMD regulates a PM2.5 nonattainment 

area classified as moderate (see 40 CFR 81.305), so the RACM requirement applies to 

this area.

Rule 1155 is intended to implement control measure BCM-01 of the 2007 

SCAQMD Air Quality Management Plan (AQMP). It will help prevent equipment 

malfunctions by establishing minimum performance, and operation and maintenance for 

PM control devices that control directly emitted noncombustion PM. While no emission 

reductions are quantified, 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.

SCAQMD does not claim specific emission reductions from Rule 1155 and has 

not committed to specific reductions in the plan. (See, e.g., SCAQMD staff report, 

page 23). Therefore, we are not evaluating the rule with respect to a specific emission 

reduction target from an approved SIP. However, we have determined that Rule 1155 

implements RACM-level controls because we are aware of no other local, State or 

federal guidance or requirement that establishes more stringent requirements for this 

broad range of controls.

2. Enforceability – CAA § 110(a)(2)(A) states that regulations submitted to EPA 

for SIP approval must be clear and legally enforceable. EPA finds that Rule 1155 
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contains specific, well-defined requirements that establish performance criteria for PM 

air pollution control devices, such as no visible emissions exiting to the atmosphere and 

for the larger baghouse units, the outlet concentration venting to the atmosphere cannot 

exceed 0.01 gr/dscf.

3. Anti-Backsliding – CAA § 110 (l) prohibits EPA from approving any SIP 

revision that would interfere with any applicable requirements concerning attainment 

and reasonable further progress (RFP) or any other applicable requirement of the CAA. 

In addition, CAA § 193 prohibits relaxing existing requirements in some circumstances. 

The submitted new rule strengthens the SIP by adding control measures and work 

practice standards to reduce emissions from PM air pollution control devices. 

We propose to determine that our approval of the submittal would comply with 

CAA §§110(l) and 193 because (1) the proposed SIP revision would not interfere with 

the on-going process for ensuring that requirements for RFP and attainment of the 

NAAQS are met, and (2) the emission limits and other requirements in the submitted 

rule, on balance, clearly strengthen the SIP.

The CAA requires SIPs to contain emission limitations that apply continuously, 

consistent with the definition of section 302(k). EPA interprets the CAA to allow SIP 

emission limitations that are formulated as numerical limits or a combination of 

numerical limits with other specific control requirements or work practices that apply 

during defined modes of source operation, so long as the resulting emission limitation 

meets the applicable level of stringency required for the type of SIP provision at issue 

and is legally and practically enforceable. If the SIP provision creates an emission 

limitation that includes appropriate components that work together to impose controls 

that apply to the source continuously, without exemptions for any modes of operation, 

this meets fundamental requirements applicable to SIP provisions. (See, e.g., EPA 

Proposed Rule: State Implementation Plans: Response to Petition for Rulemaking; 

Findings of Substantial Inadequacy, and SIP Calls to Amend Provisions Applying to 

Excess Emissions During Periods of Startup, Shutdown, and Malfunction; Supplemental 

Proposal..., 79 FR 55920, September 17, 2014). The SIP provision at issue in this 

action meets the requirements for an emission limitation that applies continuously to the 

affected sources. Rule 1155 imposes an opacity limit of zero that applies during most 

modes of source operation, and alternative limits that apply during startup and 

shutdown, which are specifically defined as a half hour period measured from certain 

events. During startup and shutdown, Rule 1155 imposes particulate matter limits 

including the PM concentration (grain loading) requirements of Rule 404 and also 

imposes an opacity limit of no greater than No. 1 on the Ringelmann Chart as specified 

in Rule 401(b)(1). Rule 1155 thus explicitly includes, or cross references, limits on 

opacity and particulate matter that apply during all modes of source operation. These 

requirements work together to impose continuous emission controls consistent with the

requirements of the CAA applicable to SIP provisions. Rule 1155 creates no 

exemptions for emissions during any mode of source operation such as startup, 

shutdown or malfunction. 
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EPA Action - The submitted Rule 1155 strengthens the SIP by requiring minimum 

performance and maintenance requirements for permitted PM air pollution control 

devices venting direct (non-combustion) PM to ensure the proper operation and 

maintenance of such equipment. The rule fulfills the relevant CAA §110 and part D 

requirements. Therefore, EPA staff recommends full approval of Rule 1155.

References

1. SCAQMD Rule 1155, Particulate Matter (PM) Control Devices amended May 2, 

2014.

2. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations,” (a.k.a., 

Bluebook) EPA OAQPS, May 25, 1988. 

http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf

3. Rule 1155 Final Staff Report, (from rule adopted December 4, 2009), SCAQMD, 

December 2009.

4. “State Implementation Plans: Response to Petition for Rulemaking; Findings of 

Substantial Inadequacy; and SIP Calls for Amend Provisions Applying to Excess 

Emissions During Periods of Startup, Shutdown, and Malfunction; Proposed Rule,”

February 22, 2013 (78 FR 12460).