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 Qualit y Management District Rule 1155, Particulate Matter (PM) Control Devices

Prepared by: Christine Vineyard

January 7 , 20152

AGENCY: South Coast Air Quality Management District (SCAQMD)

Rule 1155: Particulate Matter (PM) Control Devices

SIP

- a pproved Rule: None

Adopted by SCAQMD: December 4, 2009

Submitted by CARB July 20, 2010

EPA Completeness: August 25, 2010

A mended 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 particula te matter (PM) air pollution control devices (not the specific source causing the PM emissions) venting direct (non

combustion) PM

, to ensure the proper operation and maintenance of such equipment. These include baghouses, electrostatic precipitators, cyclo nes, scrubbers and other dust collecting equipment to control and capture PM emissions from non

- combustion

sources. SCAQMD estimates that t he rule applies to more than 1,500 existing permitted facilities with nearly 5,000 pieces of permitted PM air pollut ion control equipment from a wide range of industries.

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

 (c) Provides d efinitions for rule clarity.

 (d) Establishes g eneral r equirements 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, t he 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 m onitoring requirements including:

- The operator of any baghouse or other PM control device shall have at least one3

trained person to conduct a continuous f ive

- 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 emissi ons.

- 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 h ot 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 t ime 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 c ompliance and subsequent source tests every five years

thereafter.

 (f) Requires that r ecords 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

unti l 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

opera ting 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 em issions, 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 maint enance 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 Ringelm ann Chart as specified in Rule 401(b)(1) [shown as Rule 401(a) in the SIP

- approved4

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 de vice 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.

- Ai r 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 wit h 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 Electro plating 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 PM 2.5 and PM 10 nonattainment areas classified as moderate, the SIP must include Reasonably Available Control Measures (RACM) (see

Clea n Air Act (CAA) section 189(a)(1)). The SCAQMD regulates a PM 2.5 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 Ai r 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 quant ified, 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 emiss ion 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

. Howev er, 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 11555

contains specific, well

- defined requirements that establish performance criteria for PM air pollution control device s

, 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 st rengthen 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 combi nation 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 pr ovision 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 m odes 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 Provisio ns Appl ying 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 cer tain events. During startup and shutdown, Rule 1155 imposes particulate matter limits including the P M 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 11 5 5 creates no exemptions for emissions during any mode of source operation such as startup,

shutdown or malfunction.6

EPA Action

- The submitted Rule 1155 strengthens the SIP by requiring mi nimum 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 requireme nts

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

References

1. SCAQMD Rule 1155, Particulate Matter (PM) Control Devices a mended 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_blueboo k.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

E missions During Periods of Startup, Shutdown, and Malfunction; Proposed Rule, ” February 22, 2013 (78 FR 12460)

.